Berzas v. Health Care Options, Inc.

Filing 52

STIPULATED ORDER AND CONSENT JUDGMENT. Signed by Judge John W. deGravelles on 10/23/2019. (EDC)

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA
UNITED STATES OF AMERICA
ex rel. MELANIE BERZAS

CIVIL ACTION

VERSUS

NO. 14-199-JWD-RLB

HEALTH CARE OPTIONS, INC.;
HEALTH CARE OPTIONS OF
LAFAYETTE, INC.; HOME CARE
OPTIONS HOUSTON, INC.; and
HOWARD AUSTIN, II, IN HIS
CAPACITY AS EXECUTOR OF THE
ESTATE OF ANNETTE AUSTIN AND
IN HIS INDIVIDUAL CAPACITY

STIPULATED ORDER AND CONSENT JUDGMENT

This Stipulated Order and Consent Judgment is entered into among the United States of
America, acting through the United States Department of Justice and on behalf of the Office of
Inspector General (OIG-HHS) of the Department of Health and Human Services (HHS)
(collectively, the “United States”); Health Care Options, Inc.; Health Care Options of Lafayette,
Inc.; Home Care Options Houston, Inc.; and Howard Austin, II, in his capacity as executor of the
Estate of Annette Austin and in his individual capacity (collectively, “Defendants”); and Melanie
Berzas (“Relator”) (hereinafter collectively referred to as the “Parties”), through their authorized
representatives.
RECITALS
A.

Health Care Options, Inc.; Health Care Options of Lafayette, Inc.; and Home Care

Stipulated Order and Consent Judgment
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Options Houston, Inc. are providers of home health services in Louisiana and in Texas.

These

entities were owned or operated in part by Annette Austin and are owned or operated in part by
Howard Austin, II.
B.

Howard Austin, II, also serves as the executor of the Estate of Annette Austin.

On March 7, 2014, Melanie Berzas filed a qui tam action in the United States

District Court for the Middle District of Louisiana captioned United States of America ex rel.
Melanie Berzas v. Health Care Options, Inc., Civil Action No. 14-199-JWD-RLB, pursuant to the
qui tam provisions of the False Claims Act, 31 U.S.C. § 3730(b) (the “Civil Action”).

Relator

alleges that Health Care Options, Inc. has submitted, or has caused to be submitted, false or
fraudulent claims for payment to Federal health care programs.

The United States has intervened

in the Civil Action and has added claims against Health Care Options of Lafayette, Inc.; Home
Care Options Houston, Inc.; and Howard Austin, II, in his capacity as executor of the Estate of
Annette Austin and in his individual capacity.
C.

The United States contends that Defendants have submitted or have caused to be

submitted claims for payment to the Medicare Program, Title XVIII of the Social Security Act, 42
U.S.C. §§ 1395-1395kkk-1 (“Medicare”), and the Medicaid Program, 42 U.S.C. §§ 1396-1396w5 (“Medicaid”).
D.

The United States contends that it has certain civil claims against Defendants

arising from the submission of false and fraudulent claims for payment to Medicare and Medicaid
for home health services that did not comply with statutory and regulatory conditions of
payment—specifically, face-to-face physician-patient encounters—during the period from 2011
to 2018.

That conduct is referred to below as the “Covered Conduct.”

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E.

Relator claims entitlement under 31 U.S.C. § 3730(d) to a share of the proceeds of

this Stipulated Order and Consent Judgment and to Relator’s reasonable expenses, attorneys’ fees,
and costs.
F.

Defendants agree to accept service of the United States’ complaint and summons.

G.

In order to avoid the delay, uncertainty, inconvenience, and expense of protracted

litigation of the above claims, and in consideration of the mutual promises and obligations of this
Stipulated Order and Consent Judgment, the Parties agree and covenant as follows:
TERMS AND CONDITIONS
1.

Defendants consent to the entry of this judgment against them, jointly and severally,

and in favor of the United States in the amount of $2,500,000.00 (Two Million Five Hundred
Thousand Dollars) (the “Judgment Amount”), of which $1,711,567.49 is restitution.
2.

The Judgment Amount is a debt to the United States as defined in the Federal Debt

Collection Procedures Act of 1990, 28 U.S.C. §§ 3001-3008, and nothing in this Stipulated Order
and Consent Judgment precludes the United States from taking action to collect the debt as
authorized by law.
3.

Subject to the Terms and Conditions herein, the Judgment Amount shall be

considered fully satisfied upon completion of each of the following:
a.

On the Effective Date of this Stipulated Order and Consent Judgment,

Defendants shall pay to the United States $570,000.00 (Five Hundred Seventy Thousand Dollars)
by electronic funds transfer pursuant to written instructions to be provided by the United States
Attorney’s Office for the Middle District of Louisiana.

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b.

On the Effective Date of this Stipulated Order and Consent Judgment,

Defendants agree to immediately market for sale the residence at 12991 Highland Road, Baton
Rouge, Louisiana 70810 (the “Residence”).

The initial listing price for the Residence shall be

mutually acceptable to the United States and to Defendants.
(1)

Defendants agree to seek and receive prior approval by the United States
before reducing the listing price of the Residence at any time.

(2)

Should Defendants receive within twelve (12) months of the Effective Date
of this Stipulated Order and Consent Judgment an offer to purchase the
Residence at or above the listing price effective as of the date of that offer,
Defendants may accept the offer without prior approval by the United
States.

(3)

Defendants agree to seek prior approval by the United States before
accepting any offer to purchase the Residence below the listing price
effective on the date of the offer.

(4)

The net proceeds of any sale of the Residence, constituting gross proceeds
less taxes and the costs and fees of closing, shall first be payable toward
satisfaction of the primary mortgage on the Residence and any other
encumbrances outranking the debt created by this Stipulated Order and
Consent Judgment, then toward any commissions owed to real estate agents
or brokers in connection with the sale of the Residence, and finally toward
the satisfaction of the Judgment Amount.

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(5)

For the purpose of clarifying the Parties’ intent in entering into this
Stipulated Order and Consent Judgment, nothing under this Paragraph 3.b
other than payment of the net proceeds of the sale of the Residence toward
the Judgment Amount, in accordance with Paragraph 3.b.(4), shall
constitute a payment to the United States for purposes of Paragraph 3.e,
below.

c.

Within thirty (30) days of the Effective Date of this Stipulated Order and

Consent Judgment, Defendants agree to liquidate all funds in brokerage account number 17568396
with Raymond James Financial Services, Inc., 8280 YMCA Plaza Drive, Bldg. 4, Baton Rouge,
Louisiana 70810.

Following liquidation, Defendants will immediately pay a sum equal to the net

proceeds from that account, constituting gross proceeds less amounts owed to any lien holders,
taxes, fees, and costs, to the United States by electronic funds transfer pursuant to written
instructions to be provided by the United States Attorney’s Office for the Middle District of
Louisiana.
d.

Defendants have represented that the Estate of Annette Austin is a

beneficiary to a pending sale of certain assets related to Health Care Options Hospice of Lafayette,
Inc.

Defendants agree to immediately notify the United States upon the completion of that sale

and to pay a sum equal to the net proceeds from that sale, constituting gross proceeds less taxes,
fees, and costs, to the United States within ten (10) days of the effective date of that sale by
electronic funds transfer pursuant to written instructions to be provided by the United States
Attorney’s Office for the Middle District of Louisiana.

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e.

Notwithstanding any other provision of this Paragraph 3, in the event that

total payments to the United States under this Paragraph 3 do not equal or exceed $2,500,000.00
(Two Million Five Hundred Thousand Dollars) within twelve (12) months of the Effective Date
of this Stipulated Order and Consent Judgment, Defendants shall pay, within thirty (30) days
following twelve months after the Effective Date of this Stipulated Order and Consent Judgment,
to the United States an amount equal to the difference between $2,500,000.00 and all payments
made under this Paragraph 3.
f.

A total of $1,711,567.49 of all payments made under this Paragraph 3 is

restitution.
4.

Failure to fully comply with any term including in Paragraph 3 of this Stipulated

Order and Consent Judgment shall constitute both a material breach of the Parties’ agreements and
a Default of this Stipulated Order and Consent Judgment as described in Paragraph 15 below.
5.

Subject to the exceptions in Paragraph 7 (concerning excluded claims) below, and

conditioned upon Defendants’ full payment of the Judgment Amount or satisfaction thereof in
accordance with Paragraph 3, the United States releases Defendants from any civil or
administrative monetary claim the United States has for the Covered Conduct under the False
Claims Act, 31 U.S.C. §§ 3729-3733; the Civil Monetary Penalties Law, 42 U.S.C. § 1320a-7a;
the Program Fraud Civil Remedies Act, 31 U.S.C. §§ 3801-3812; or the common law theories of
payment by mistake, unjust enrichment, and fraud.
6.

Subject to the exceptions in Paragraph 7 below, and conditioned upon Defendants’

full payment of the Judgment Amount or satisfaction thereof in accordance with Paragraph 3,

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Relator, for herself and her heirs, successors, attorneys, agents, and assigns, releases Defendants
from any civil monetary claim Relator has on behalf of the United States for the Covered Conduct
under the False Claims Act, 31 U.S.C. §§ 3729-3733.
7.

Notwithstanding the releases given in Paragraphs 5-6 of this Stipulated Order and

Consent Judgment, or any other term of this Stipulated Order and Consent Judgment, the following
claims of the United States are specifically reserved and are not released:
a.

Any liability arising under Title 26, U.S. Code (Internal Revenue Code);

b.

Any criminal liability;

c.

Except as explicitly stated in this Stipulated Order and Consent Judgment,
any administrative liability, including mandatory or permissive exclusion
from Federal health care programs;

d.

Any liability to the United States (or its agencies) for any conduct other than
the Covered Conduct;

e.

Any liability based upon obligations created by this Stipulated Order and
Consent Judgment; and

f.

Any liability of individuals not Parties to this Stipulated Order and Consent
Judgment.

8.

Relator and her heirs, successors, attorneys, agents, and assigns shall not object to

this Stipulated Order and Consent Judgment but agree and confirm that this Stipulated Order and
Consent Judgment is fair, adequate, and reasonable under all the circumstances, pursuant to 31
U.S.C. § 3730(c)(2)(B).

In connection with this Stipulated Order and Consent Judgment and this

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Civil Action, Relator and her heirs, successors, attorneys, agents, and assigns agree that neither
this Stipulated Order and Consent Judgment, any intervention by the United States in the Civil
Action in order to dismiss the Civil Action, nor any dismissal of the Civil Action, shall waive or
otherwise affect the ability of the United States to contend that provisions in the False Claims Act,
including 31 U.S.C. § 3730(d)(3), (e), bar Relator from sharing in the proceeds of this Stipulated
Order and Consent Judgment.

Moreover, the United States and Relator and her heirs, successors,

attorneys, agents, and assigns agree that they each retain all of their rights pursuant to the False
Claims Act on the issue of the share percentage, if any, that Relator should receive of any proceeds
of the settlement of her claim(s), and that no agreements concerning Relator’s share have been
reached to-date.
9.

Relator, for herself and for her heirs, successors, attorneys, agents, and assigns,

releases Defendants and their officers, agents, and employees from any liability to Relator arising
from the filing of the Civil Action, except that the Relator, her heirs, successors, attorneys, agents,
and assigns shall retain all of her rights pursuant to the False Claims Act to recover from the
Defendants her reasonable expenses, attorneys’ fees, and costs pursuant to 31 U.S.C. § 3730(d), if
any.

No agreement concerning reasonable expenses, attorneys’ fees, and costs has been reached

to-date.
10.

Defendants waive and shall not assert any defenses Defendants may have to any

criminal prosecution or administrative action relating to the Covered Conduct that may be based
in whole or in part on a contention that, under the Double Jeopardy Clause in the Fifth Amendment
of the Constitution, or under the Excessive Fines Clause in the Eighth Amendment of the

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Constitution, this Stipulated Order and Consent Judgment bars a remedy sought in such criminal
prosecution or administrative action.
11.

Defendants fully and finally release the United States, its agencies, officers, agents,

employees, and servants, from any claims (including attorneys’ fees, costs, and expenses of every
kind and however denominated) that Defendants have asserted, could have asserted, or may assert
in the future against the United States, its agencies, officers, agents, employees, and servants,
related to the Covered Conduct and the United States’ investigation and prosecution thereof.
12.

The Judgment Amount shall not be decreased as a result of the denial of claims for

payment now being withheld from payment by any Medicare contractor (e.g., Medicare
Administrative Contractor, fiscal intermediary, carrier) or any state payer, related to the Covered
Conduct; and Defendants agree not to resubmit to any Medicare contractor or any state payer any
previously denied claims related to the Covered Conduct, agree not to appeal any such denials of
claims, and agree to withdraw any such pending appeals.
13.

The Parties warrant that, in evaluating whether to execute this Stipulated Order and

Consent Judgment, they have: (a) intended that the mutual promises, covenants, and obligations
set forth herein constitute a contemporaneous exchange for new value given to Defendants within
the meaning of 11 U.S.C. § 547(c)(1); and (b) concluded that these mutual promises, covenants,
and obligations constitute such a contemporaneous exchange.

Further, the Parties warrant that

the mutual promises, covenants, and obligations set forth herein are intended to and do, in fact,
represent a reasonably equivalent exchange of value that is not intended to hinder, delay, or defraud
any entity to which Defendants were or became indebted to on or after the date of this transfer,

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within the meaning of 11 U.S.C. § 548(a)(1).
14.

If within 91 days of the Court’s entry of this Stipulated Order and Consent

Judgment or of any payment made pursuant thereto, any Defendant or third party commences a
case, proceeding, or other action under any law relating to bankruptcy, insolvency, reorganization,
or relief of debtors: (a) seeking to have any order for relief of any Defendant’s debts, or seeking to
adjudicate any Defendant as bankrupt or insolvent; or (b) seeking appointment by a receiver,
trustee, custodian, or other similar official for any Defendant, or for all or any substantial part of
any Defendant’s assets, Defendants agree as follows:
a.

Defendants’ obligations under this Stipulated Order and Consent Judgment
may not be avoided pursuant to 11 U.S.C. § 547, and Defendants shall not
argue or otherwise take the position in any such case, proceeding, or action
that:
(1)

Any Defendant’s obligations under this Stipulated Order and
Consent Judgment may be avoided under 11 U.S.C. § 547;

(2)

Any Defendant was insolvent at the time the Court entered this
Stipulated Order and Consent Judgment, or became insolvent as a
result of any payment made to the United States; or

(3)

The mutual promises, covenants, and obligations set forth in this
Stipulated Order and Consent Judgment do not constitute a
contemporaneous exchange for new value given to any Defendant.

b.

Defendants’ obligations under this Stipulated Order and Consent Judgment

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are non-dischargeable under 11 U.S.C. § 523(a)(2) and 11 U.S.C.
§ 1141(d)(6)(A), regardless of whether or not the United States timely files
an adversary complaint to establish a claim under 11 U.S.C. § 523(c)(1).
c.

If any Defendant’s obligations under this Stipulated Order and Consent
Judgment are avoided for any reason, including, but not limited to, through
the exercise of a trustee’s avoidance powers under the Bankruptcy Code,
the United States, at its sole option and upon notice to the Court, may
rescind the releases contained within this Stipulated Order and Consent
Judgment and may bring any civil or administrative claim, action, or
proceeding against Defendants for the claims that would otherwise be
covered by the releases provided herein.
(1)

Any such claims, actions, or proceedings brought by the United
States are not subject to an “automatic stay” pursuant to 11 U.S.C.
§ 362(a) as a result of the action, case, or proceedings described in
this subparagraph, and Defendants or a related party shall not argue
or otherwise contend that the United States’ claims, actions, or
proceedings are subject to an automatic stay;

(2)

Defendants or a related party shall not plead, argue, or otherwise
raise any defenses under the theories of statute of limitations, statute
of repose, laches, estoppel, or similar theories, to any such civil or
administrative claims, actions, or proceedings that are brought by

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the United States; and
(3)

Any such claims against Defendants are valid in the full amount of
all federal funds used, trebled, plus the statutory maximum penalty
for each claim submitted or caused to be submitted to the United
States by Defendants, and the United States may pursue its claims
against Defendants in the complaint as well as in any other case,
action, or proceeding.

15.

Default.
a.

Subject to all other terms of this Stipulated Order and Consent Judgment, in

the event that Defendants fail to pay any amount due under this Stipulated Order and Consent
Judgment within 5 days of the date upon which such payment is due, Defendants shall be in default
of their payment obligations (“Default”).

In the event of Default, the Judgment Amount, with

interest accruing at the rate of 4% per annum compounded daily from the Effective Date of this
Stipulated Order and Consent Judgment (the “Judgment Interest”), shall become immediately due
and payable.

The United States, at its sole option, may do one or more of the following: (a) offset

the unpaid balance of the Judgment Amount and the Judgment Interest from any amounts due and
owing to Defendants by any department, agency, or agent of the United States at the time of the
Default; (b) seek an order or other relief from the Court, in which event the United States shall be
entitled to an award of reasonable attorneys’ fees and costs; or (c) exercise any other rights granted
by law or in equity, including the option of referring such matters for private collection.
Defendants agree not to contest any offset imposed and any collection action undertaken by the

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United States pursuant to this paragraph, either administratively or in any state or federal court.
Defendants shall pay the United States all reasonable costs of collection and enforcement under
this paragraph, including attorneys’ fees and expenses.
b.

In the event of Default, Defendants agree not to plead, argue, or otherwise

raise any defenses under the theories of statute of limitations, statute of repose, laches, estoppel,
or similar theories, to any civil or administrative claims, actions, or proceedings brought by the
United States as a result of Defendants’ Default.
c.

Additionally, in the event of Default, OIG-HHS may exclude Defendants

from participating in all Federal health care programs until Defendants pay the Judgment Amount,
the Judgment Interest, and all reasonable costs as set forth above.
notice of any such exclusion to Defendants.

OIG-HHS will provide written

Defendants waive any further notice of the exclusion

under 42 U.S.C. § 1320a-7(b)(7) and agree not to contest such exclusion either administratively or
in any state or federal court.

Reinstatement to program participation is not automatic.

If at the

end of the period of exclusion Defendants wish to apply for reinstatement, Defendants must submit
a written request for reinstatement to OIG-HHS in accordance with the provisions of 42 C.F.R.
§§ 1001.3001-.3005.

Defendants will not be reinstated unless and until OIG-HHS approves such

request for reinstatement.
16.

Defendants agree to the following:
a.

Unallowable Costs Defined:

All costs (as defined in the Federal

Acquisition Regulation, 48 C.F.R. § 31.205-47; and in Titles XVIII and XIX of the Social Security
Act, 42 U.S.C. §§ 1395-1395kkk and 1396-1396w-5; and the regulations and official program

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directives promulgated thereunder) incurred by or on behalf of Defendants, their present or former
officers, directors, employees, shareholders, and agents in connection with:
(1)

the matters covered by this Stipulated Order and Consent Judgment;

(2)

the United States’ audit(s) and civil investigation(s) of the matters covered
in this Stipulated Order and Consent Judgment;

(3)

Defendants’ investigation, defense, and corrective actions undertaken in
response to the United States’ audit(s) and civil investigation(s) in
connection with the matters covered by this Stipulated Order and Consent
Judgment (including attorneys’ fees);

(4)

the negotiation and performance of this Stipulated Order and Consent
Judgment; and

(5)

the payments that Defendants make to the United States pursuant to this
Stipulated Order and Consent Judgment and any payments that Defendants
may make to Relator, including costs and attorneys’ fees,

are unallowable costs for government contracting purposes and under the Medicare Program,
Medicaid Program, TRICARE Program, and Federal Employees Health Benefits Program
(FEHBP) (hereinafter referred to as “Unallowable Costs”).
b.

Future Treatment of Unallowable Costs:

Unallowable Costs shall be

separately determined and accounted for by Defendants, and Defendants shall not charge such
Unallowable Costs directly or indirectly to any contracts with the United States or any State
Medicaid program, or seek payment for such Unallowable Costs through any cost report, cost

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statement, information statement, or payment request submitted by Defendants or any of their
subsidiaries or affiliates to the Medicare, Medicaid, TRICARE, or FEHBP Programs.
c.

Treatment of Unallowable Costs Previously Submitted for Payment:

Defendants further agree that within 90 days of the Effective Date of this Stipulated Order and
Consent Judgment it shall identify to applicable Medicare and TRICARE fiscal intermediaries,
carriers, or contractors, and Medicaid and FEHBP fiscal agents, any Unallowable Costs included
in payments previously sought from the United States, or any State Medicaid program, including,
but not limited to, payments sought in any cost reports, cost statements, information reports, or
payment requests already submitted by Defendants or any of their subsidiaries or affiliates, and
shall request, and agree, that such cost reports, cost statements, information reports, or payment
requests, even if already settled, be adjusted to account for the effect of the inclusion of the
Unallowable Costs.

Defendants agree that the United States, at minimum, shall be entitled to

recoup from Defendants any overpayment plus applicable interest and penalties as a result of the
inclusion of such Unallowable Costs on previously-submitted cost reports, information reports,
cost statements, or requests for payment.

Defendants shall identify these Unallowable Costs

through: (1) accounting records, to the extent possible; (2) memorandum records, including diaries
and informal logs, regardless of whether such records are part of official documentation, where
accounting records are not available; and (3) good-faith, itemized estimates where no other
accounting basis is available.
Any payments due after the adjustments have been made shall be paid to the United States
pursuant to the direction of the Department of Justice or the affected agencies. The United States

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reserves its rights to disagree with any calculations submitted by Defendants or any of their
subsidiaries or affiliates on the effect of the inclusion of Unallowable Costs on Defendants or any
of their subsidiaries’ or affiliates’ cost reports, cost statements, or information reports.
d.

Nothing in this Stipulated Order and Consent Judgment shall constitute a

waiver of the rights of the United States to audit, examine, or re-examine Defendants’ books and
records to determine that no Unallowable Costs have been claimed in accordance with the
provisions of this paragraph.
17.

Defendants agree to cooperate fully and truthfully with the United States’

investigation of individuals and entities not released in this Stipulated Order and Consent
Judgment.

Upon reasonable notice, Defendants shall encourage, and agree not to impair, the

cooperation of their directors, officers, and employees, and shall use their best efforts to make
available, and encourage, the cooperation of former directors, officers, and employees for
interviews and testimony, consistent with the rights and privileges of such individuals.
Defendants further agree to furnish to the United States, upon request, complete and unredacted
copies of all non-privileged documents, reports, memoranda of interviews, and records in their
possession, custody, or control concerning any investigation of the Covered Conduct that they
have undertaken, or that has been performed by another on their behalf.
18.
Parties only.

The Stipulated Order and Consent Judgment is intended to be for the benefit of the
The Parties do not release any claims against any other person or entity, except to

the extent provided for in Paragraph 19 (waiver for beneficiaries paragraph), below.
19.

Defendants agree that they waive and shall not seek payment for any of the health

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care billings covered by this Stipulated Order and Consent Judgment from any health care
beneficiaries or their parents, sponsors, legally responsible individuals, or third party payors based
upon the claims defined as Covered Conduct.
20.

Each Party shall bear its own legal and other costs incurred in connection with this

matter, including the preparation and performance of this Stipulated Order and Consent Judgment.
21.

Each Party and signatory to this Stipulated Order and Consent Judgment represents

that it freely and voluntarily enters into this Stipulated Order and Consent Judgment without any
degree of duress or compulsion.
22.

This Stipulated Order and Consent Judgment constitutes the complete agreement

between the Parties.
23.

The undersigned counsel represent and warrant that they are fully authorized to

execute this Stipulated Order and Consent Judgment on behalf of the persons and entities indicated
below.
24.

This Stipulated Order and Consent Judgment is binding on Defendants’ successors,

transferees, heirs, and assigns.
25.

This Stipulated Order and Consent Judgment is binding on Relator’s successors,

transferees, heirs, and assigns.
26.

All Parties consent to the United States’ disclosure of this Stipulated Order and

Consent Judgment, and information about this Stipulated Order and Consent Judgment, to the
public.
27.

All agreements contained within this Stipulated Order and Consent Judgment are

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contingent upon the Court’s approval and entry of this Stipulated Order and Consent Judgment on
the case docket.

This Stipulated Order and Consent Judgment is effective from the date of the

Court’s approval and entry of this Stipulated Order and Consent Judgment on the case docket (the
“Effective Date”).
28.

Upon entry of this Stipulated Order and Consent Judgment, an Order of Dismissal

shall be entered dismissing without prejudice the United States’ and Relator’s claims against
Defendants as to those elements of the Civil Action that are coextensive with the Covered Conduct.
The Court shall retain jurisdiction to resolve any claims asserted by Relator that are not resolved
by this Stipulated Order and Consent Judgment, including Relator’s claim of reasonable expenses,
attorneys’ fees, and costs under 31 U.S.C. § 3730(d).
29.

The United States District Court for the Middle District of Louisiana shall retain

jurisdiction in this case to enforce the terms of this Stipulated Order and Consent Judgment.

Stipulated Order and Consent Judgment
United States of America ex rel. Melanie Berzas v. Health Care Options, Inc., et al.
Civil Action No. 14-199-JWD-RLB (M.D. La.)
Page 18 of 26

MELANIE BERZAS
DATED:W9

DATED:

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BY:

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;....______c_

THOMAS M. GREENE
Attorney for Melanie Berzas

23rd
SO ORDERED this __ day of ______, 2019 in Baton Rouge, Louisiana.
October

S
HON. JOHN W. deGRAVELLES
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA

Stipulated Order and Consent Judgment
United States ofAmerica ex rel. Melanie Berzas v. Health Care Options, Inc., et al.
Civil Action No. 14-199-JWD-RLB (M.D. La.)
Page 26 of26