Case 2:17-cv-02315 Document 1 Filed 09/01/17 Page 1 of 44 1 Pat Lundvall Nevada Bar No. 3761 2 MCDONALD CARANO LLP 2300 West Sahara Avenue, Suite 1200 3 Las Vegas, NV 89102 Telephone: (702) 873-4100 4
[email protected] 5 Robert N. Weiner Pending Admission Pro Hac Vice 6 Jeffrey L. Handwerker Pending Admission Pro Hac Vice 7 R. Stanton Jones Pending Admission Pro Hac Vice 8 ARNOLD & PORTER KAYE SCHOLER LLP 601 Massachusetts Avenue, NW 9 Washington, DC 20001 Telephone: (202) 942-5000 10
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[email protected] 12 Attorneys for Plaintiffs Pharmaceutical 13 Research and Manufacturers of America and Biotechnology Innovation Organization 14 15 UNITED STATES DISTRICT COURT 16 DISTRICT OF NEVADA 17 PHARMACEUTICAL RESEARCH AND Case No.: 18 MANUFACTURERS OF AMERICA, and COMPLAINT FOR DECLARATORY 19 AND INJUNCTIVE RELIEF BIOTECHNOLOGY INNOVATION 20 ORGANIZATION, 21 Plaintiffs, 22 vs. 23 BRIAN SANDOVAL, in his official capacity 24 as Governor of the State of Nevada, and 25 RICHARD WHITLEY, in his official capacity as Director of the Nevada Department for 26 Health and Human Services, 27 Defendants. 28 Case 2:17-cv-02315 Document 1 Filed 09/01/17 Page 2 of 44 1 Plaintiffs Pharmaceutical Research and Manufacturers of America (“PhRMA”) and 2 Biotechnology Innovation Organization (“BIO”) (together, “Plaintiffs”), on behalf of themselves 3 and their members, for their Complaint against Brian Sandoval, in his official capacity as Governor 4 of the State of Nevada (the “State”), and Richard Whitley, in his official capacity as Director of the 5 Nevada Department of Health and Human Services (together, “Defendants”), allege as follows: 6 INTRODUCTION 7 1.