Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 1 of 40
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`UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
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`
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`
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`Case No. ____________
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`COMPLAINT FOR
`PERMANENT INJUNCTION,
`MONETARY RELIEF, CIVIL
`PENALTIES AND OTHER
`RELIEF
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`
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`FEDERAL TRADE COMMISSION and
`STATE OF GEORGIA,
`
` Plaintiffs,
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` v.
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`STEVEN D. PEYROUX, individually and as
`an owner and officer of REGENERATIVE
`MEDICINE INSTITUTE OF AMERICA,
`LLC, also d/b/a Stem Cell Institute of
`America, LLC, PHYSICIANS BUSINESS
`SOLUTIONS, LLC, and SUPERIOR
`HEALTHCARE, LLC,
`
`BRENT J. DETELICH, individually and as
`an officer of REGENERATIVE MEDICINE
`INSTITUTE OF AMERICA, LLC, also
`d/b/a Stem Cell Institute of America, LLC,
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`REGENERATIVE MEDICINE INSTITUTE
`OF AMERICA, LLC, a limited liability
`company, also d/b/a Stem Cell Institute of
`America, LLC,
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`PHYSICIANS BUSINESS SOLUTIONS,
`LLC, a limited liability company, and
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`SUPERIOR HEALTHCARE, LLC, a
`limited liability company,
`
`
`
`Defendants.
`
`
`
`
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`1
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 2 of 40
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`Plaintiffs, the Federal Trade Commission (“FTC”) and the State of Georgia,
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`for their Complaint allege:
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`1.
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`The FTC brings this action under Section 13(b) of the Federal Trade
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`Commission Act (“FTC Act”), 15 U.S.C. § 53(b), which authorizes the FTC to
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`seek, and the Court to order permanent injunctive relief, and other relief for
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`Defendants’ acts or practices in violation of Sections 5(a) and 12 of the FTC Act,
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`15 U.S.C. §§ 45(a), 52. Defendants’ violations are in connection with the
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`advertising, marketing, and promotion of stem cell therapy.
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`2.
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`The State of Georgia, by and through its Attorney General,
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`Christopher M. Carr, brings this action under Georgia’s Fair Business Practices
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`Act (“FBPA”), O.C.G.A. §§10-1-390 through 10-1-408, to obtain permanent
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`injunctive relief; monetary relief by way of civil penalties, restitution to persons
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`adversely affected by the actions complained of herein, and other relief as the
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`Court deems just and equitable, including the disgorgement of ill-gotten monies.
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`JURISDICTION AND VENUE
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`3.
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`This Court has subject matter jurisdiction pursuant to 28 U.S.C.
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`§§ 1331, 1337(a), and 1345.
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 3 of 40
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`4.
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`This Court has supplemental jurisdiction over the State of Georgia’s
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`claims for violations of the FBPA pursuant to 28 U.S.C. § 1367(a) because those
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`claims are so related to the claims brought under federal law that they form part of
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`the same case or controversy, and because those claims arise out of the same
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`transactions or occurrences as the claims brought pursuant to 15 U.S.C. §§ 45(a),
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`52, and 53(b).
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`5.
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`Venue is proper in this District under 28 U.S.C. § 1391(b)(1), (b)(2),
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`(b)(3), (c)(1), (c)(2), and (d), and 15 U.S.C. § 53(b).
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`PLAINTIFF
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`6.
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`The FTC is an independent agency of the United States Government
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`created by the FTC Act, which authorizes the FTC to commence this district court
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`civil action by its own attorneys. 15 U.S.C. §§ 41–58. The FTC enforces Section
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`5(a) of the FTC Act, 15 U.S.C. § 45(a), which prohibits unfair or deceptive acts or
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`practices in or affecting commerce. The FTC also enforces Section 12 of the FTC
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`Act, 15 U.S.C. § 52, which prohibits false advertisements for food, drugs, devices,
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`services, or cosmetics in or affecting commerce.
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 4 of 40
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`7.
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`Plaintiff State of Georgia is one of fifty sovereign states of the United
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`States. Christopher M. Carr is the duly elected and qualified Attorney General
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`acting for Plaintiff State of Georgia and is authorized to enforce the FBPA.
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`8.
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`The State of Georgia, by and through its Attorney General,
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`Christopher M. Carr, is authorized to initiate federal district court proceedings to
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`implement the provisions of the FBPA and to secure such relief as the court deems
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`just and equitable, including, but not limited to, injunctive relief, restitution, and
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`the disgorgement of ill-gotten monies. O.C.G.A. §§ 10-1-390 through 10-1-408.
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`DEFENDANTS
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`9.
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`Defendant Steven D. Peyroux (“Peyroux”) is the founder and owner
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`of Regenerative Medicine Institute of America, LLC d/b/a Stem Cell Institute of
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`America, LLC (“SCIA”), Physicians Business Solutions, LLC (“PBS”), and
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`Superior Healthcare, LLC (“SHC”). At all times relevant to this Complaint, acting
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`alone or in concert with others, he has formulated, directed, controlled, had the
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`authority to control, or participated in the acts and practices set forth in this
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`Complaint. Defendant Peyroux resides in this District and, in connection with the
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`matters alleged herein, transacts or has transacted business in this District and
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`throughout the United States.
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 5 of 40
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`10. Defendant Brent J. Detelich (“Detelich”) co-founded SCIA with
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`Defendant Peyroux and served as SCIA’s president. At all times relevant to this
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`Complaint, acting alone or in concert with others, he has formulated, directed,
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`controlled, had the authority to control, or participated in the acts and practices set
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`forth in this Complaint. In connection with the matters alleged herein, Detelich
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`transacts or has transacted business in this District and throughout the United
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`States.
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`11. Defendant Regenerative Medicine Institute of America, LLC, d/b/a
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`Stem Cell Institute of America, LLC (“SCIA”), is a Nevada limited liability
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`company with its principal place of business at 151 Main Street, Suite 204, Canton,
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`GA 30114. SCIA has advised healthcare practices on how to add stem cell therapy
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`to the services offered to the public, including by providing sample advertising
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`with deceptive claims about the efficacy of stem cell therapy for treating certain
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`conditions. SCIA has transacted business in this District and throughout the
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`United States.
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`12. Defendant Superior Healthcare, LLC (“SHC”) is a Georgia limited
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`liability company with its principal place of business at 2050 Cumming Highway,
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 6 of 40
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`Suite 100, Canton, GA 30114. SHC has transacted business in this District and
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`throughout the United States.
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`13. Defendant Physicians Business Solutions, LLC (“PBS”) is a Nevada
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`limited liability company with its principal place of business at 151 Main Street,
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`Suite 204, Canton, GA 30114. PBS transacts or has transacted business in this
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`District and throughout the United States.
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`14. On August 30, 2019, Defendant SCIA filed a voluntary petition for
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`relief under Chapter 7 of the Bankruptcy Code in the United States Bankruptcy
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`Court for the Northern District of Georgia, Case 19-63685-jwc. The Bankruptcy
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`Trustee is Kathleen Steil.
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`15. On October 22, 2019, Defendant SHC filed a voluntary petition for
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`relief under Chapter 7 of the Bankruptcy Code in the United States Bankruptcy
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`Court for the Northern District of Georgia, Case 19-66877-sms. The Bankruptcy
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`Trustee is Edwin K. Palmer.
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`16. The instant action against Defendants SCIA and SHC is not stayed by
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`11 U.S.C. § 362(a) because it is an action to enforce Plaintiffs’ police and
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`regulatory power as governmental units pursuant to 11 U.S.C. § 362(b)(4), and
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`thus falls within an exemption to the automatic stay.
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 7 of 40
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`COMMON ENTERPRISE
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`17. Defendants SCIA, SHC, and PBS (collectively, “Corporate
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`Defendants”) have operated as a common enterprise while engaging in the
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`deceptive acts and practices alleged below. Corporate Defendants have conducted
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`the business practices described below through an interrelated network of
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`companies that have common ownership, officers, managers, business functions,
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`employees, and office locations. Because these Corporate Defendants have
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`operated as a common enterprise, each of them is liable for the acts and practices
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`alleged below.
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`COMMERCE
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`18. At all times relevant to this Complaint, Defendants have maintained a
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`substantial course of trade in or affecting commerce, as “commerce” is defined in
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`Section 4 of the FTC Act, 15 U.S.C. § 44 and O.C.G.A. § 10-1-392(a)(28).
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`DEFENDANTS’ BUSINESS ACTIVITIES
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`19. Defendant Peyroux, a chiropractor, founded Defendant SHC in
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`December 2005, and owned and managed the company. SHC was a clinic that
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`provided patients with a variety of health-related services, including chiropractic
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`care, physical therapy, weight loss, and, from approximately 2015 to July 2019,
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 8 of 40
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`therapy using products described as stem cells (“stem cell therapy”). SHC’s clinic
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`was located at 2050 Cumming Highway, Suite 100, Canton, GA 30114, and its
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`administrative offices were located at 151 Main Street, Suite 204, Canton, GA
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`30114. Peyroux was SHC’s owner and executive director, with authority over
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`advertising and marketing, the clinic’s products and procedures, and other aspects
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`of the business.
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`20.
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`In January 2009, while continuing to run SHC, Peyroux founded
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`Defendant PBS, which he has owned and managed since its formation from the
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`same business premises as SHC. PBS purports to be a consulting firm that advises
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`chiropractors and other healthcare practitioners on expanding their business model
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`and increasing revenue by integrating a variety of other health-related services into
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`their practices, including disc rehabilitation, weight loss, hormone replacement
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`therapy, and regenerative medicine. Through one- or two-year contracts, PBS
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`provides training and personalized guidance to its clients.
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`21. Defendant Detelich, a former chiropractor and Peyroux’s long-time
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`business associate, began working for PBS in approximately 2012 as a coach and
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`speaker. Detelich also manages PBS’ marketing and the company’s relationships
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`with the product and service vendors PBS promotes to clients.
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 9 of 40
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`22.
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`In or around September 2015, Defendants Peyroux and Detelich co-
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`founded Defendant SCIA. Peyroux was SCIA’s owner, and Detelich served as
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`president until January 2018, when Peyroux took over management of day-to-day
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`operations. Like PBS, SCIA instructed chiropractors and other healthcare
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`practitioners to expand their health offerings, but focused exclusively on stem cell
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`therapy. In addition to providing advertising materials, SCIA also provided clients
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`with the appearance of being part of a large nationwide healthcare network under
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`the SCIA name and logo. Defendants charged clients a monthly fee, ranging from
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`$1,500 to $5,500 for an “exclusivity radius” within which SCIA would not train
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`any other provider or allow them to use the SCIA name and logo. Alternatively,
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`SCIA charged a flat fee of $400 for each injection administered by its clients.
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`23. Defendants touted SCIA’s “turnkey” system and that “[t]here [was]
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`no need to re-invent the wheel. We have done it for you, from A-Z!” In addition
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`to advising its clients on the administrative and technical needs for integrating stem
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`cell therapy into their practices, SCIA trained its clients on how to recruit patients
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`through advertising, host free educational seminars, speak in public, and conduct
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`consultations with patients and ultimately win their business. SCIA also provided
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`its clients with access to a “vault” of sample advertisements, including newspaper
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 10 of 40
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`ads, videos, fact sheets that were given to consumers at seminars, and PowerPoint
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`slides that clients could present at seminars. Defendant Detelich was actively
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`involved in developing SCIA’s advertising and training materials, such as the
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`PowerPoint presentation he used in his own trainings for SCIA clients and
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`recommended they use in hosting seminars for consumers. Defendant Peyroux
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`also participated in developing advertising and training materials for SCIA.
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`24. Defendants started marketing SHC as an SCIA clinic starting in
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`approximately late 2015. To attract potential patients, they advertised and hosted
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`free educational seminars on stem cell therapy, often using the SCIA name and
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`logo and targeting consumers suffering from joint pain and other orthopedic
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`conditions, including seniors and retirement communities. Defendant Peyroux was
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`frequently the main speaker at the seminars, and SHC’s advertising materials at
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`times featured his name and photo. During a seminar, attendees were typically
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`asked to complete a survey detailing where and for how long they had been
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`experiencing pain. At the end of the seminar, SHC staff would attempt to schedule
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`seminar attendees for consultations at SHC’s clinic. The stem cell therapy
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`procedures cost approximately $5,000 per joint injection, with patients often
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`receiving more than one injection.
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 11 of 40
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`25. SHC also contracted with third-party clinics in various locations
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`throughout Georgia to administer injections to SHC’s patients in exchange for a
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`monthly rental fee plus a flat fee ranging from $150.00 to $300.00 per injection.
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`26. During the time period from January 11, 2017 through July 31, 2019,
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`SHC received payment for injections from no less than 444 consumers.
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`Approximately 70% of these consumers were over the age of 59.
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`27.
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`In January 2018, Defendant Detelich nominally stepped down from
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`his role as president of SCIA, but continued in his same de facto role. He
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`continued to recruit new clients and work on marketing for the company. Detelich
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`also continued to work at PBS, primarily recruiting new clients, signing client
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`contracts for the company, lecturing at conferences, and coaching clients on
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`marketing stem cell therapy and other regenerative medicine services to
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`consumers.
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`28.
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`In 2018, defendants began offering a stem cell therapy program
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`through PBS. PBS has provided its clients with in-person or online training
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`seminars, one-on-one consultations with its coaches, access to the “PBS
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`University” online platform containing training videos, manuals with detailed,
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`step-by-step instructions on how to set up and market regenerative medicine
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`11
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 12 of 40
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`services, sample documentation, as well as demonstrations held at SHC on how to
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`administer stem cell injections.
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`29. Regardless of ownership and formal titles, Peyroux and Detelich have
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`run SCIA, PBS, and SHC together and have shared in the profits and distributions
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`from the companies. The companies have shared staff, office space, and
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`marketing, administrative, and technical materials. They have frequently held joint
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`or co-branded conferences, training events, and patient seminars, and used and
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`recommended to their clients the same vendors for stem cell products, marketing,
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`and other business services.
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`30. Through various channels, including seminars, social media
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`platforms, an infomercial, websites, YouTube channels, email blasts, and print
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`media, Defendants have advertised the benefits of stem cell therapy for orthopedic
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`conditions to the public and to healthcare practitioners.
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`31. Defendants have disseminated or caused to be disseminated
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`advertisements, including, but not necessarily limited to, the attached Exhibits A
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`through K. These advertisements contain the following statements and depictions,
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`among others:
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`12
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 13 of 40
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`A. Excerpts from Defendant SCIA’s website,
`www.americastem.com, available from January 2016 to
`May 2019 (Ex. A)
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 14 of 40
`Case 1:21-cv-03329-AT Document1 Filed 08/16/21 Page 14 of 40
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`Whereis Your Pain?
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`Shoulder / Neck
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`Back
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`Wrist / Hand
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`
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`Elbow
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`Foot/Ankle
`
`Att
`| 1
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`Neck
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`Cervical Pain
`
`Regenerative medicine has revolutionized treatment
`options for those suffering from chronic neck pain.
`Regenerative Cell Therapy uses Regenerative cells to target
`the painful areas, help recharge the immune system, and
`greatly reduce inflammation. Read More
`
`Cervical DJD
`Amniotic Regenerative Cell Therapy is a revolutionary
`Solution to heal cervical joint degeneration, and a safe
`alternative to medications, steroid injections, and surgery.
`Read More
`
`Cervical Arthritis
`
`Regenerative Cell Therapy can reduce the inflammation
`that causes arthritic pain. By using the amniotic cell therapy
`with a high concentration ofimmunecellsand healing
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`factors, this procedure helps the body naturally repair the
`damaged tissue and cartilage between each vertebrae in
`the neck, Read More
`
`Shoulder
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`6
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 15 of 40
`Case 1:21-cv-03329-AT Document1 Filed 08/16/21 Page 15 of 40
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`aST 1
`
`Ob ARCS,
`
`TESTIMONIALS
`
`@)
`Ive suffered with chronic knee pain for the last 10 years. It started out with just Soreness and eventually led me to walking with a
`cane every day.
`| had tried injections before. nerve blocks and even orthovisc injections and each time. they would work for a few
`months and the pain would come back.
`| had heard about Stem Cell injections from a good friend who had tried it and had
`success with it.
`| was a litte concerned because other treatments had not really given me long term success. Not wanting to do
`surgery. | decided to try my right knee and do the treatment on one side to see how well it worked. Well, 6 months later,| did the
`other knee. I've been pain free for months now and no longer have to walk with a cane. [thas definitely given me mylife back.
`fve had such an improvement that my wife had her shoulder treated with stern cells and she feels younger because she's not
`longer in pain. This therapy can change yourlife.
`
`
`Sm tele emerlaremaee tL)
`
`
`STEM CELL
`Home
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`Rob M- Clearwater, FL
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`
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`
`
`@)
`Before | tried stem cell therapy. | was having trouble just walking even 5 minutes. Walking up stairs had gotten so painful that |
`moved my bedroom downstairs to avoid having to go up and down them. Every day,| just felt constant debilitating pain in both
`knees and eventually got to the point where | couldn't do my favorite activities anymore. Walking was next to impossible and
`Spending time with my family was alvrays difficult because | just couldn't put pressure on my legs. My Orthopedic surgeon told me
`that they would have to do a full knee replacement and take almost a year to rehabilitate me. | decided to try one more thing
`before going under the knife for a last time and that’s when | found the Stem Cell Institute. Its been almost 5 months since | had
`my first treatment and | can honestly say that I'm pain free for the first time in years. Losing my favorite activities and then having
`the chance to now do these again has felt like getting a second chance. Not only feeling better but seeing the changes on my x-
`rays has been incredible. | would definitely do it again if | had too. | recommend stem cells therapy to anyone with chronic knee
`pain.
`
`Jane C.-Crystal Lake, IL
`
`
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`15
`15
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 16 of 40
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`B. Newspaper ad for SCIA and SHC disseminated by
`SHC and provided by SCIA as a sample newspaper ad to
`SCIA clients (Ex. B)
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 17 of 40
`Case 1:21-cv-03329-AT Document1 Filed 08/16/21 Page 17 of 40
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`WetTa Ce)
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`Regenerative medicine uses stem cells to regenerate and repair tissues in
`your body that are damaged due to age, disease and defects. Stem cells have
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`Ta
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 18 of 40
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`C. Excerpts from an SCIA client’s infomercial posted on
`SCIA’s YouTube channel on or about June 14, 2017 (Ex. C)
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`FORBES RILEY: When you wake up in the morning, do you hurt? I
`mean, if you’re like me, maybe you’ve been in a car accident, a ski
`accident, or in my case I tore my ankle just stepping off a curb. [ON
`SCREEN: Do you Suffer from Pain? Knee-Back-Shoulder-Hip-
`Neuropathy-Joint Pain] Odds are that at a certain age, life has taken
`its toll on your body. You suffer from pain in your knees, your
`shoulders, your neck, and the worst part, when you’re in pain, it’s
`hard to get a good night’s sleep. What if I told you there was a
`solution, one that requires no surgery and no downtime? With this
`type of cutting edge, regenerative medicine, imagine that you can
`once again live life to the fullest and enjoy all those things you
`thought were not possible, like playing with your children, your
`grandchildren, taking a walk on the beach, playing a round of golf, or
`even just enjoying a good night’s sleep. In a moment, you’ll discover
`how this revolutionary breakthrough in medicine is now available to
`all of us, helping to diminish pain in your ankle, your knee, your hips,
`your shoulders, and even back pain, but it also helps with neuropathy
`and pain associated with arthritis. . . . [Y]ou no longer have to live
`with pain, thanks to the Stem Cell Institute of America. And on our
`show, you’re going to hear from top researchers, doctors, and patients
`who call this therapy nothing short of a miracle. . . .
`
`DR. JILL HOWE: . . . [patient] Gerry, who had 30 years of back pain,
`couldn’t even dry off after he got out of the shower, had tried
`everything from doctors, to shots, to surgery; now he’s feeling great.
`He’s walking around, he’s going to start playing golf again, and he got
`his life back.
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`FORBES RILEY: Just from a treatment?
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`DR. JILL HOWE: Just from one treatment. It’s incredible.
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 19 of 40
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`FORBES RILEY: Well, we continue to hear story after story of what
`patients are calling a miracle therapy, truly being able to live without
`pain. . . .
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`[Patient] GERRY: [On screen: PROBLEM: Chronic Lower Back
`Pain] We went ahead with the stem cell treatment on my back, and
`right now, I would say the pain is not there. When it first started, it
`was a good nine, ten, and now I just don’t have that pain at all. It’s
`gone. . . .
`
`[Patient] CHUCK: [On screen: PROBLEM: Arthritis in Hip/Poor
`Sleep] After treatments at the Stem Cell Institute of America, my pain
`level went from a ten down to perhaps a two or even a one. The
`major thing, however, is at the start, when I got where I could only
`walk, let’s say three blocks and get to a pain level of ten, now I can
`walk probably three miles before I get to any significant pain level.
`
`FORBES RILEY: Well, now, I’d like to introduce you to a podiatrist
`who uses amniotic tissue in the healing process in his practice. . . .
`
`[Podiatrist] DR. LOU CILIBERTI: I’ve seen amazing results. . . .
`decreased inflammation, improved healing, faster healing. . . . A
`woman that had come to me who had had leg pain for years,
`neuropathic-type pain, so this was more of a nerve-type of an issue.
`She was complaining of numbness and tingling in her leg. I used the
`amniotic tissue, and this woman went on to have a remarkable
`recovery, something that she was dealing with for years.
`
`FORBES RILEY: I mean, have you seen cartilage grow back in
`areas?
`
`LOU CILIBERTI: Oh, I’ve used this amniotic tissue to help
`regenerate bone, to help regenerate soft tissue.
`
`FORBES RILEY: But people who’ve been suffering with pain for a
`long time . . . have you seen it work for them, too?
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 20 of 40
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`LOU CILIBERTI: One of those patients that comes in that says, hey
`Doc, I’ve had this chronic pain for years; I’ve tried everything; I’ve
`tried physical therapy; I’ve tried surgery; I’ve tried corticosteroid
`injections; I’ve tried you name it, this is an alternative that you can
`offer to those folks.
`
`[Former Chicago Bears Announcer] HUB ARKUSH: I had been to
`several doctors who’d recommended complete knee replacements, and
`I said, no, I’m not going to do that, but I also reached the point where
`I couldn’t go much further. And I heard about Dr. Howe and her
`treatment, and I had stem cell injections in both knees. It’s a little
`over a year ago now. The left knee is 100 percent pain-free. It’s just
`a tremendous success.
`
`D. Video posted on SCIA YouTube channel from September
`23, 2016 to present (Ex. D)
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`FORBES RILEY: Stem cells. You know, they’re not what you might
`think. Fact: they can rejuvenate any part of the body. Fact: If you’re
`in pain, they might be your best solution. I know, you curious?
`Because I am, too.
`
`So here to tell us more about stem cells and the cutting-edge
`technology available to all of us is the founder and president of the
`Stem Cell Institute of America. Please welcome Dr. Bent Detelich.
`
`DR. BRENT DETELICH: Thank you.
`
`***
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`
`
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`FORBES RILEY: All right, so talk – let’s start with what is the Stem
`Cell Institute of America?
`
`DR. BRENT DETELICH: Okay, so we created this organization of
`fantastic physicians across the country who are dedicating theirselves
`[sic] to educating people in their community about the miracles of
`stem cells.
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 21 of 40
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`***
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`FORBES RILEY: That’s very true, and I appreciate you saying that.
`Is stem cell therapy right for everybody?
`
`DR. BRENT DETELICH: Well, here’s the answer to that, okay? If I
`needed surgery or I had a problem that was extremely painful –
`
`FORBES RILEY: Mm-hmm.
`
`DR. BRENT DETELICH: – and I had to use drugs or surgery as my
`option –
`
`FORBES RILEY: Right.
`
`DR. BRENT DETELICH: – if I thought that that might be the
`solution, I would look at the – the opportunity of using stem cells
`before that. I would always recommend patients to seek out and find
`out if stem cells are right for you before you start to take drugs
`because they all have bad side effects –
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`FORBES RILEY: Right.
`
`DR. BRENT DETELICH: – no matter even if it’s just aspirin, they
`have bad side effects. They start to break down the body. So the idea
`that you could regenerate the body and not just slow down the
`degeneration with a drug or a surgery –
`
`FORBES RILEY: Mm-hmm.
`
`DR. BRENT DETELICH: – should be – should be what people think
`of first and foremost. How can I fix this so it doesn’t come back?
`
`***
`
`
`
`
`FORBES RILEY: Okay, this just sounds, one, so exciting and almost
`a little too good to be true, because I’ve talked to a lot of the patients
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 22 of 40
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`who’ve had this, and they keep calling it [a] miracle. They say they
`went in, their pain was on a eight, nine, or ten out of ten, and now, six
`months later, they’re like at one or two. Do you know what that
`means for so many people?
`
`
`
`
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`DR. BRENT DETELICH: You know, even for a person who’s seen
`this in over 150 clinics, every time I hear about it, it amazes me. It
`just – an 87-year-old woman who’s got pain for 20 years –
`
`FORBES RILEY: Yeah.
`
`DR. BRENT DETELICH: – she’s on crutches, she can’t walk without
`assistance, she comes in and two days later she’s walking pain-free.
`That –
`
`FORBES RILEY: Wow.
`
`DR. BRENT DETELICH: – is what life is about for me as a
`physician. I got into this world so I could help people.
`
`
`
`DR. BRENT DETELICH: Okay. So what we did is myself and – and
`a few physicians decided that this was something we had to tell the
`world about.
`
`FORBES RILEY: Okay.
`
`DR. BRENT DETELICH: So we went on a six-month tour, lecturing
`all over the country, and taking the local physicians and training them
`at the seminar.
`
`FORBES RILEY: Okay.
`
`DR. BRENT DETELICH: At that point, when we – when we really
`refined the message in – in helping people truly understand what stem
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`***
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 23 of 40
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`cells are, so they could make the right decision for themselves, that
`seminar takes about one hour to do. I tell people to attend those
`seminars. They’re going to know more about stem cells than their
`own medical physicians because we’re dedicated to giving you all the
`information. So you’re going to learn everything about adult stem
`cells, placental stem cells, why they work better, which ones work
`better for different diseases and conditions. The information that you
`gain from this seminar is life-changing. I tell people it’s usually the
`most valuable hour they’re ever going to spend on their health in their
`entire lifetime.
`
`E. Video posted on SCIA’s website homepage, SCIA’s
`YouTube channel and played at the beginning of SCIA’s
`educational seminars from at least March 2, 2016 to present
`(Ex. E)
`
`NARRATOR: Do you suffer with chronic knee, shoulder, back, or
`other joint pain or arthritis? Has your pain stopped you from enjoying
`normal activities and lessened your quality of life? Are you taking
`prescription medication and harmful pain relievers with little to no
`effect on your pain? For several years, our doctors have helped local
`pain sufferers find relief from their chronic joint pain and stiffness.
`
`We understand your unique needs and how challenging it can be to
`find a physician that you can trust and can help you achieve the results
`that you’re looking for. Our clinic is proud to offer one of the most
`cutting-edge noninvasive and nonsurgical treatments for joint and
`arthritis pain. Stem cell therapy, or regenerative cellular medicine,
`works by using the body’s immune cells to increase cellular healing of
`damaged tissues and ligaments.
`
`When injured, your body sends immune cells to the affected area to
`aid in the recovery process. Regenerative cell therapy expedites
`healing by introducing regenerative cells to increase healing and
`regeneration of new tissue to repair damaged joint tissue and
`inflammation. In addition, our doctors use a combination of the most
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 24 of 40
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`cutting-edge knee rehabilitation techniques to help strengthen and
`support any weakness found, as well as reduce your pain and
`inflammation.
`
`To sign up for a free, no-charge regenerative cell therapy consultation,
`call our office today or schedule online. We look forward to helping
`you live a life free of pain.
`
`F.
`
`Excerpts of fact sheets provided to consumers at SCIA
`educational seminars nationwide (Ex. F)
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`G. Excerpts of PowerPoint presentation drafted by Brent
`Detelich and distributed by SCIA to its clients for their use
`at educational seminars (Ex. G)
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 25 of 40
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`H. Excerpts from Defendant SHC’s website,
`www.superiorhealthcarega.com, dated June 19, 2018 (Ex.
`H)
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 26 of 40
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`I.
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`Excerpts from Defendant Peyroux’s email to March 24,
`2018 seminar attendees (Ex. I)
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`Case 1:21-cv-03329-AT Document 1 Filed 08/16/21 Page 27 of 40
`Case 1:21-cv-03329-AT Document1 Filed 08/16/21 Page 27 of 40
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`like to spend just a couple of minutes with you, getti