On Sunday, photos and videos of Burgess partying on a yacht in Cabo were leaked.
In the images, the 30-year-old was seen celebrating the 50th birthday of NRL star Sean Garlick with his brother and fellow rugby player, Luke Burgess.
The men were surrounded by bikini-clad women, and the Rabbitohs player - who, according to The Daily Mail, has a dangerous shoulder injury - was carrying a particularly bouncy female on his shoulders.
Last week, the NRL star was issued with a temporary apprehended violence order after a clash with Mitchell Hooke, the father of Phoebe.
Police issued the order after an incident between Sam and Mitchell in Bowral on Saturday, with a court listing at Moss Vale on November 9, according to public records.
The Daily Mail reported that Burgess is due before Moss Vale Local Court on November 6, where a magistrate could confirm the AVO or dismiss it in its entirety.
An NSW Police spokeswoman told the publication that police are investigating and "there are no reports of any injuries."
Sam is thought to have ended the couple’s relationship just before Christmas, as Phoebe was not seen at the Burgess family Christmas dinner held at Watson’s Bay.
The split came after Sam was cleared of any wrongdoing in the sexting scandal that happened in September when Phoebe was 28 weeks pregnant.
Sam found himself at the centre of a video chat scandal after his Facebook account was reportedly used to send nude photos to a 23-year-old woman.
'I’m not angry. What hurts me the most is seeing my wife upset about what’s out there,' the father of two told reporters during a press conference at the Rabbitohs’ Redfern training headquarters.
The couple has been married for five years.