United States, ex rel. et al v. Hebrard et al

Filing 81

ORDER RE STIPULATION OF DISMISSAL by Hon. William Alsup granting 80 Stipulation.(whalc1, COURT STAFF) (Filed on 2/2/2016)

1 BRIAN J. STRETCH (CABN 163973)
Acting United States Attorney
2 ALEX G. TSE (CABN 152348)
Chief, Civil Division
3 SARA WINSLOW (DCBN 457643)
MELANIE L. PROCTOR (CABN 228971)
4 Assistant United States Attorneys
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102
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Telephone: [phone]
Facsimile: [phone]
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e-mail: [e-mail]
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Attorneys for the United States of America
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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UNITED STATES ex rel. BONNIE
LAMMERS, M.D.,

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Plaintiff and Relator,

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v.
FARIDEH HEIDARPOUR, et al.,
Defendants.

) NO. CV 08-3411 WHA (DMR)
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) STIPULATION OF DISMISSAL;
) [PROPOSED] ORDER
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Subject to the Court’s approval, and pursuant to Fed. R. Civ. P. 41(a)(2), IT IS HEREBY

20 STIPULATED by the United States of America, qui tam Relator Bonnie Lammers, and Defendants
21 Michael Hebrard, M.D., Richard Lavigna, D.P.M., Advanced Physical Medicine & Rehab Group, Inc.,
22 Advanced Occupational Rehabilitation, Inc., Advanced Medicine and Rehabilitation of Texas, Inc., and
23 Advanced Medicine and Rehabilitation of Texas, P.A., that this action is dismissed with prejudice.
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1. This action named nine Defendants. The three Defendants not listed above (Defendants

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Farideh Heidarpour, Ali Heidarpour, and A.B.C. Billing, Inc.) were dismissed from this case

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by Order dated September 8, 2015, after those Defendants paid the amounts due under their

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August 28, 2013 settlement agreement.

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STIPULATION OF DISMISSAL; [PROPOSED ORDER]
C 08-3411 WHA (DMR)

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2. The remaining Defendants have now paid the amounts due under their July 11, 2012

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settlement agreement, and they are being dismissed with prejudice, pursuant to the terms of

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the July 11, 2012 settlement agreement. Accordingly, the entire case is now being dismissed

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with prejudice.

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IT IS SO STIPULATED.

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Respectfully submitted,
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BRIAN J. STRETCH
Acting United States Attorney

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Dated: February 1, 2016

By:

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/s/ signature on file
SARA WINSLOW
MELANIE L. PROCTOR
Assistant United States Attorneys
Attorneys for the United States

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MCBREEN & SENIOR

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14 Dated: February 1, 2016

By:

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/s/ signature on file
MATTHEW WESTON
Attorney for Relator

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LAW OFFICES OF DENISE EATON-MAY
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Dated: January 18, 2016

By:

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/s/ signature on file
DENISE EATON MAY
Attorney for Defendants Michael Hebrard, M.D.,
Advanced Physical Medicine & Rehab Group, Inc.,
Advanced Occupational Rehabilitation, Inc.,
Advanced Medicine and Rehabilitation of Texas,
Inc., and Advanced Medicine and Rehabilitation of
Texas, P.A.

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KNIGHT EMPLOYMENT LAW

24 Dated: January 21, 2016

By:

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STIPULATION OF DISMISSAL; [PROPOSED ORDER]
C 08-3411 WHA (DMR)

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/s/ signature on file
CODY D. KNIGHT
Attorney for Defendant Richard Lavigna, D.P.M.

[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS HEREBY ORDERED that this action is dismissed with

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IT IS SO ORDERED.

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Dated: February 2, 2016.
HONORABLE WILLIAM ALSUP
United States District Judge

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STIPULATION OF DISMISSAL; [PROPOSED ORDER]
C 08-3411 WHA (DMR)

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