United States of America et al v. Paramedics Plus LLC et al
Filing
157
MEMORANDUM OPINION AND ORDER. ORDERED that Paramedics Plus, LLC's Motion to Compel the United States of America to Comply with Discovery (Dkt. #131) is hereby GRANTED IN PART. Signed by District Judge Amos L. Mazzant, III on 1/30/2018. (daj, )
United States District Court
EASTERN DISTRICT OF TEXAS
SHERMAN DIVISION
UNITED STATES OF AMERICA,
CALIFORNIA STATE OF, EX REL.,
FLORIDA STATE OF, EX REL.,
OKLAHOMA STATE OF, EX REL., and
STEPHEN DEAN, RELATOR
v.
PARAMEDICS PLUS LLC, EMERGENCY
MEDICAL SERVICES AUTHORITY,
EAST TEXAS MEDICAL CENTER
REGIONAL HEALTHCARE SYSTEM
INC, HERBERT STEPHEN WILLIAMSON,
and EAST TEXAS MEDICAL CENTER
REGIONAL HEALTH SERVICES INC
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
Civil Action No. 4:14-CV-00203
Judge Mazzant
MEMORANDUM OPINION AND ORDER
Pending before the Court is Paramedics Plus, LLC’s (“Paramedics Plus”) Motion to
Compel the United States of America (“the Government”) to Comply with Discovery (Dkt. #131).
The Court, having considered the motions and the relevant pleadings, finds that the motion to
compel should be granted in part.
BACKGROUND
Emergency Medical Services Authority (“EMSA”) owns ambulances but does not employ
drivers, emergency medical technicians, paramedics, or other personnel that perform health care
services. EMSA contracts with private companies to provide these services. EMSA contracted
with Paramedics Plus to provide ambulance services and as part of the agreement would pay
EMSA any profits over twelve percent (“profit cap”). 1 This profit cap was allegedly not disclosed
to EMSA’s board of directors and the profit cap was not reduced to writing. To receive Medicare
and Medicaid payments, EMSA certified compliance with the Anti-Kickback Statute (“AKS”).
The Government maintains that the profit cap was in violation of the AKS, and by falsely certifying
compliance with the AKS, Defendants in this case 2 violated the False Claims Act (“FCA”).
On April 4, 2014, relator Stephen Dean filed a complaint against Paramedics Plus, EMSA,
East Texas Medical Center Regional Healthcare System, Inc., Pinellas County Emergency Medical
Services Authority (“Pinellas County”) and County of Alameda, California (“Alameda County”)
(Dkt. #1) alleging, among other things, a violation of the FCA. On January 6, 2017, the
Government partially intervened removing Pinellas County and Alameda County as defendants
(Dkt. #25).
The Government filed its Complaint in Partial Intervention on January 23, 2017
(Dkt. #28).
As part of the litigation and discovery process, on June 30, 2017, Paramedics Plus served
Interrogatories and Requests for Admission (the “Interrogatories”) on the Government. The
Government served its objections and responses (the “Responses”) to the Interrogatories on July
27, 2017. The Interrogatories and Responses state:
10.
State the: (i) total number of Medicare and Medicaid claims, (ii) the total
dollar amount paid for such claims and (iii) dates of payments for all such
claims submitted by or on behalf of EMSA for which You paid or
authorized payment after You first learned of the profit-cap agreement
between AMR and EMSA.
RESPONSE: The United States objects to this interrogatory as it seeks information
outside the scope of Federal Rule of Civil Procedure 26. The information sought
concerns a different ambulance contractor not a party to the United States’ claims,
1
The parties disagree about the terminology used to describe the arrangement in place here. For simplicity’s sake,
the Court will use the term profit cap because that is the term used in the discovery requests, but the Court is in no
way making a finding on the events that took place.
2
Defendants in this case are EMSA, Paramedics Plus, East Texas Medical Center Regional Healthcare Services, Inc.,
East Texas Medical Center Regional Healthcare System, Inc., and Herbert Stephen Williamson (“Williamson”).
Paramedics Plus is the only defendant that filed the present motion.
2
an ambulance contract not at issue in this action, and a time period that is not
relevant to the false claims alleged in this case.
11.
State the: (i) total number of Medicare and Medicaid claims, (ii) the total
dollar amount paid for such claims and (iii) dates of payments for all such
claims submitted by or on behalf of Pinellas County for which You paid or
authorized payment after You first learned of the profit-cap agreement
between PMP and Pinellas County.
RESPONSE: The United States objects to this interrogatory as it seeks information
outside the scope of Federal Rule of Civil Procedure 26. The information sought
concerns conduct not at issue in this action from a municipal entity not located in
Oklahoma and during a time period that is not relevant to the false claims alleged
in this case.
12.
State the: (i) total number of Medicare and Medicaid claims, (ii) the total
dollar amount paid for such claims and (iii) dates of payments for all such
claims submitted by or on behalf of Alameda County for which You paid
or authorized payment after You first learned of the profit-cap agreement
between PMP and Alameda County.
RESPONSE: The United States objects to this interrogatory as it seeks
information outside the scope of Federal Rule of Civil Procedure 26. The
information sought concerns conduct not at issue in this action from a municipal
entity not located in Oklahoma and during a time period that is not relevant to the
false claims alleged in this case.
14.
Identify and describe any instance in which You denied a Medicare or
Medicaid claim for reimbursement because the medical provider had
entered into a profit-cap agreement with a third-party contractor.
RESPONSE: The United States objects to this interrogatory because it is
misleading. First, Paramedics Plus appears to have created the term “profit-cap”
for purposes of ambulance services contracts. To the extent sharing profit is
remuneration, then a “profit-cap” as created by Paramedics Plus satisfies the
remuneration element of the Anti-Kickback Statute. Second, as the United States
explains in its Complaint in Partial Intervention (Dkt. #28), Defendants’ conduct
(i.e., the knowing offer and exchange of remuneration with an unlawful purpose,
regardless of what Defendants called the arrangement) in this action violated the
Anti-Kickback Statute (“AKS”). The AKS does not enumerate the many ways
persons may exchange, or offer to exchange, remuneration.
The United States further objects to this interrogatory to the extent it seeks
information outside the scope of Federal Rule of Civil Procedure 26. This
information sought relates to conduct not at issue in this action regarding municipal
entities in various states other than Oklahoma and during a time period that is not
relevant to the false claims alleged in this case. The United States has denied
reimbursement for claims tainted by potential AKS violations resulting from
profit-cap arrangements. For example, the United States settled with Pinellas
EMSA in this action alleging Pinellas EMSA violated the AKS when it accepted
Paramedics Plus’s offer of entering into a profit-cap agreement and then accepting
3
money under that arrangement. Under the terms of that settlement agreement,
Pinellas EMSA not only paid a settlement amount to the United States, but Pinellas
EMSA also agreed not to submit certain claims that were tainted by potential AKS
violations arising from the acceptance of profit-sharing/profit-capping terms and
money offered by Paramedics Plus. Because AKS compliance is a prerequisite to
Medicare and Medicaid reimbursement, the United States through its settlement
agreement with Pinellas EMSA, denied payment—or even submission—of claims
tainted by potential AKS violations arising from the receipt of remuneration in the
form of a profit cap as well as money that was transmitted under the applicable
profit cap offered by Paramedics Plus. Pinellas EMSA represented that the
settlement prohibited the submission or payment of hundreds of thousands, if not
millions, of dollars in Medicare and Medicaid claims. Alameda County agreed to
similar settlement provisions.
(Dkt. #131, Exhibit A at pp.15–18).
Based on these objections and the parties’ inability to resolve the discovery dispute, the
Court held a telephone conference on November 14, 2017. At the conference, the Court ordered
briefing on the issue. On November 15, 2017, Paramedics Plus filed its motion to compel
(Dkt. #131). On November 22, 2017, the Government filed its response (Dkt. #132). Paramedics
Plus filed its reply on November 28, 2017 (Dkt. #133), and the Government filed its sur-reply on
November 30, 2017 (Dkt. #134).
APPLICABLE LAW
Under Federal Rule of Civil Procedure 26(b)(1), parties “may obtain discovery regarding
any nonprivileged matter that is relevant to any party’s claim or defense. . . .” FED. R. CIV. P.
26(b)(1). Relevance, for the purposes of Rule 26(b)(1), is when the request is reasonably
calculated to lead to the discovery of admissible evidence. Id.; Crosby v. La. Health & Indem.
Co., 647 F.3d 258, 262 (5th Cir. 2011). Further, the Court’s scheduling order requires that the
parties produce documents, as part of its initial disclosure, “documents containing, information
‘relevant to the claim or defense of any party.’” (Dkt. #115 at p. 3). The Local Rules of the Eastern
District of Texas provide further guidance suggesting that information is “relevant to any party’s
4
claim or defense: (1) it includes information that would support the disclosing parties’ contentions;
. . . (4) it is information that deserves to be considered in the preparation, evaluation or trial of a
claim or defense. . . .” LOCAL RULE CV-26(d). It is well-established that “control of discovery is
committed to the sound discretion of the trial court.” Freeman v. United States, 556 F.3d 326, 341
(5th Cir. 2009) (quoting Williamson v. U.S. Dep’t of Agric., 815 F.2d 368, 382 (5th Cir. 1987)).
Rule 37 of the Federal Rules of Civil Procedure allows a discovering party, on notice to
other parties and all affected persons, to “move for an order compelling disclosure or discovery.”
FED. R. CIV. P. 37(a)(1). The moving party bears the burden of showing that the materials and
information sought are relevant to the action or will lead to the discovery of admissible evidence.
Export Worldwide, Ltd. v. Knight, 241 F.R.D. 259, 263 (W.D. Tex. 2006). Once the moving party
establishes that the materials requested are within the scope of permissible discovery, the burden
shifts to the party resisting discovery to show why the discovery is irrelevant, overly broad, unduly
burdensome or oppressive, and thus should not be permitted. Id.
The federal rules follow a proportionality standard for discovery. FED. R. CIV. P. 26(b)(1).
Under this requirement, the burden falls on both parties and the Court to consider the
proportionality of all discovery in resolving discovery disputes. FED. R. CIV. P. 26(b)(1), advisory
committee note (2015). This rule relies on the fact that each party has a unique understanding of
the proportionality to bear on the particular issue. Id. For example, a party requesting discovery
may have little information about the burden or expense of responding. Id. “The party claiming
undue burden or expense ordinarily has far better information—perhaps the only information—
with respect to that part of the determination.” Id.
5
ANALYSIS
Paramedics Plus asks the Court to compel the Government to respond to Interrogatory
Numbers 10–12, and 14 3 and further asks for the Court to compel the Government to produce
documents regarding other profit caps. The Government argues that the information is not relevant
to its cause of action. Further, the Government argues that Paramedics Plus’s request for
documents will require the Government to produce its investigation and litigation files. Finally,
the Government argues that they already answered one of the disputed Interrogatories. The Court
will address each of the Government’s contentions in turn.
I.
Relevance of Information Surrounding Profit Caps
The Government maintains that the information Paramedics Plus is seeking is not relevant
because (A) the substance of the information has no bearing on the issues before the Court and
(B) the information sought is outside the relevant time period. The Court will discuss each of the
Government’s arguments regarding relevance.
A. Substance
Because the parties dispute the relevance as to a specific element of the Government’s
cause of action, for clarity, the Court will identify the elements. The FCA establishes liability for
“any person who—(A) knowingly presents, or causes to be presented, a false or fraudulent claim
for payment or approval; (B) knowingly makes, uses, or causes to be made or used, a false record
or statement material to a false or fraudulent claims; [or] (C) conspires to commit a violation of
[the FCA].” 31 U.S.C. § 3729(a)(1)(A)–(C). “Generally, in considering liability under the FCA,
the Fifth Circuit focuses on ‘(1) whether there was a false statement or fraudulent course of
3
Paramedics Plus initially sought to compel an answer to Interrogatory Number 13 as well, but withdrew its motion
as to Interrogatory Number 13 based on the Government’s assertion that there is no profit cap agreement between
Paramedics Plus and Three Rivers.
6
conduct; (2) made or carried out with the requisite scienter; (3) that was material; and (4) that
caused the government to pay out money or to forfeit moneys due (i.e., that involved a claim).’”
United States v. Vista Hospice Care, Inc., 2016 WL 3449833, at *16 (N.D. Tex. June 20, 2016)
(citing Gonzalez v. Fresenius Med. Care N. Am., 689 F.3d 470, 475 (5th Cir. 2012)).
The Government asserts that Paramedics Plus misunderstands the elements of the
Government’s case. The Government avers that materiality is an element of its FCA claim, but it
is the certification of compliance with the AKS that must be material to the Government’s payment
decisions, not profit caps. As such, the Government argues that the information about profit caps
is not relevant.
Paramedics Plus maintains that, after Escobar, information related to the
Government’s continued payment of claims after discovery of a profit cap is relevant to the issue
of materiality.
It is possible for the Government to prevail on a false certification theory if the Government
demonstrates “that the defendant has improperly certified compliance with a statute or regulation
(whether explicitly or impliedly), and that improper certification is material to the [G]overnment’s
payment decision.” Id. (citing United States ex rel. Bennett v. Boston Sci. Corp., 2011 WL
1231577, at *13 (S.D. Tex. Mar. 31, 2011)). Accordingly, the Court agrees with the Government
that it is the certification of compliance with the AKS that needs to be material to the Government’s
payment decisions. See Vista Hospice Care, 2016 WL 3449833, at *16.
However, the Court must permit discovery of evidence that is reasonably calculated to lead
to the discovery of admissible evidence, during the discovery process. See FED. R. CIV. P. 26(b)(1);
Crosby, 647 F.3d at 262. In Escobar, the Supreme Court of the United States provided guidelines
for determining materiality in this context:
In sum, when evaluating materiality under the False Claims Act, the Government’s
decision to expressly identify a provision as a condition of payment is relevant, but
7
not automatically dispositive. Likewise, proof of materiality can include, but is not
necessarily limited to, evidence that the defendant knows that the Government
consistently refuses to pay claims in the mine run of cases based on noncompliance
with the particular statutory, regulatory, or contractual requirement. Conversely, if
the Government pays a particular claim in full despite knowledge that certain
requirements were violated, that is very strong evidence that those requirement are
not material. Or if the Government regularly pays a particular type of claim in full
despite actual knowledge that certain requirements were violated, and has signaled
no change in position, that is strong evidence that the requirements are not material.
United Health Servs., Inc. v. United States ex rel. Escobar, 136 S.Ct. 1989, 2003–04 (2016).
Surprisingly absent from the Government’s response 4 is any discussion of how the Supreme Court
of the United States’ holding applies to the information Paramedics Plus is attempting to discover.
After a review of the analysis in Escobar, the Court finds that allowing discovery relating to the
Government’s continued payment after discovery of a profit cap is reasonably calculated to lead
to the discovery of admissible evidence. Although the issue at hand is whether certification of
compliance with the AKS is material, evidence of the Government’s continued payment after
discovery of a profit cap will likely lead to information about whether these specific entities
certified compliance with the AKS.
Further, the Government argues that the information is not relevant because “there is no
such thing as an immaterial violation of the AKS.” (Dkt. #132 at p. 9). The Government maintains
that not only was compliance with the AKS a condition of payment, but also “Congressional intent
surrounding [the AKS], plain language of the [AKS], and years of case law demonstrate that the
4
Escobar is briefly mentioned in the Government’s response; however, the Government does not address the relevant
portion of the holding. (Dkt. #132 at p. 11 (“Forty years of legislative history and decades of case law, both before
and after Escobar, demonstrate that false certifications of compliance with the AKS . . . influence [the Government’s]
payment decisions.”) (“Paramedics Plus’s fallback position—that in light of Escobar, AKS compliance is not
automatically material . . . is similarly misplaced because the [Government] is not arguing that the AKS is material
simply because it is a condition of payment.”)). Additionally, in its sur-reply, the Government mentions Escobar
stating that “Escobar is not an AKS case and did not change the applicable AKS compliance analysis.” (Dkt. #134 at
p. 2). However, the Government also uses the First Circuit’s opinion in Escobar, after it was remanded, even though
it is not specifically an AKS case. At this point in time, the Court does not find a reason to limit discovery because
Escobar presented the false certification of a different statue or regulation as a basis for liability under the FCA.
8
AKS is material to the [Government’s] payment decisions as a matter of law.” (Dkt. #132
at pp. 11–12). Paramedics Plus responds that this is a premature argument, as it involves the
Government’s theory of the case and the merits of the case, as opposed to a discovery dispute.
The Court agrees. The Court is not determining that this evidence proves or disproves the
materiality element in this case. Paramedics Plus must later persuade the Court and/or the jury
that the information it obtains during the discovery process is admissible and proves lack of
materiality. 5 Likewise it is the responsibility of the Government to prove that congressional intent
and case law prove materiality as a matter of law. However, this is an issue to be decided at a later
point in time, as opposed to during a discovery dispute.
At this stage, the Court’s sole
responsibility is to determine whether the discovery sought is relevant, which indeed it has done.
B. Time Period
The Government additionally argues that the relevant time period is the time period during
which the alleged profit cap scheme took place, 1997 through 2013. 6
Accordingly, the
Government argues that the information is not relevant because “payment decisions in other places
after the relevant time period is not relevant to the [G]overnment’s earlier payment decisions.”
(Dkt. #132 at p. 10 (citing United States ex rel. Escobar v. Universal Health Servs., Inc. (“Escobar
II”), 842 F.3d 103, 112 (1st Cir. 2016))). 7
5
For instance, the Government mentions that Alameda County and Pinellas County did not conceal their profit caps,
which tends to work in the Government’s favor (Dkt. #132 at p. 6). However, Paramedics Plus has no record or
evidence of that and neither does the Court. If such assertion is true, it will be Paramedics Plus that will need to
explain the relevance of the information it receives at a later stage in the proceeding, but the rules permit Paramedics
Plus to discover the information.
6
The Government argues about the relevant time period twice in its response. The Court will address both arguments
at once.
7
The Government further contends that Paramedics Plus has not responded to discovery after 2013 and that the parties
should be subject to the same time frame for discovery. However, the discovery limitations and time period regarding
Paramedics Plus’s discovery is not before the Court at this time, and thus the Court does not consider this argument.
9
However, after the Court’s review of the case, Escobar II does not stand for the proposition
that post-suit payments are never relevant. In that case, the First Circuit held that is was
unnecessary to “decide whether actual knowledge of the violations would in fact be sufficiently
strong evidence that the violations were not material to the government’s payment decision” for
the purposes of ruling on a motion to dismiss because there was no allegation in the complaint that
the government knew about the violation while it was paying the claim. Id. In fact, the complaint
in that case only referenced reimbursements prior to the filing of the litigation and the government
did not learn of the violations until after the filing of the litigation. Id. Accordingly, the complaint
necessarily would not include any allegations of payment after the government learned of the
violation. Id. As such, because the First Circuit took the allegations in the complaint as true and
did not look to any evidence outside the pleadings, as required on a motion to dismiss, the court
did not dismiss the case for lack of materiality. Id.
Here, the Court is deciding a discovery dispute as opposed to ruling on a motion to dismiss.
Accordingly, the Court is to determine if the information sought is relevant. Paramedics Plus is
seeking the exact information that would make it necessary for the Court to “decide whether actual
knowledge of the violations would in fact be sufficiently strong evidence that the violations were
not material to the [G]overnment’s payment decision.” Id. This is the exact type of information
that is reasonably calculated to lead to the discovery of admissible evidence regarding the
materiality element after Escobar.
Paramedics Plus argues that the issue of materiality goes beyond Paramedics Plus’s alleged
misconduct and, as such, the time frame should not be limited to 1997 through 2013. The Court
agrees. Determining the Government’s conduct after discovery of a profit cap is not necessarily
limited to the time frame of Paramedics Plus’s misconduct. Paramedics Plus met its burden to
10
establish that the Government’s continued payment of Medicare and Medicaid claims after
discovery of a profit cap is relevant and the Government did not meet its burden to establish that
the time frame should be restricted to 1997 through 2013. As such, information after 2013
regarding the Government’s discovery of a profit cap and continued payment after discovery is
relevant.
II.
Documents
“Paramedics Plus seeks non-privileged documents and communication in the
Government’s possession related to other Profit Caps in the ambulance industry.” (Dkt. #131
at p. 12). Paramedics Plus specifies that it is seeking documents obtained from communications
with third parties related to profit caps, which should not be privileged as they are communications
with a third party. Paramedics Plus continues that documents relating to when the Government
learned about other profit caps and the Government’s conduct after learning such information
would be relevant to its defense that certification of compliance with the AKS is not material to
the Government. Therefore, the documents should be produced as part of its discovery obligations
in the case.
The Government contends that it is improper for Paramedics Plus to receive documents
from its investigation and litigation files. 8 To support its argument that the Court should not permit
discovery on investigation and litigation files, the Government vaguely alludes 9 to the fact that
some information might be privileged; however, it makes no argument regarding privilege, has not
8
The Government also makes bold assertions regarding the “true goals” of Paramedics Plus’s discovery requests;
however, the Court will not engage in a discussion regarding the Government’s speculation behind Paramedics Plus’s
discovery request.
9
The Government states that it “is not aware of any responsive, non-privileged information in its passion, custody or
control relating to ‘profit caps’ in the ambulance industry that existed prior to Dean filing his qui tam in 2014.”
(Dkt. #132 at p. 4).
11
produced a privilege log, and has not asked the Court to review any documents in camera. Without
such specificity, the Court cannot and will not rule on such an objection.
As further support for the contention that discovery into the Government’s investigation
and prosecution of other entities is improper, the Government cites Renal Care Group, a case from
the Eastern District of Missouri. 10 United States ex rel. Williams v. Renal Care Grp., Inc., 2008
WL 5233028, at *2 (E.D. Mo. Dec. 12, 2008). However, Renal Care Group is not binding
precedent on the Court and the case was decided before the Supreme Court’s decision in Escobar.
“Materiality under the FCA has been a topic of increasing scrutiny since the Supreme Court’s
decision in Escobar.” United States ex rel. Harman v. Trinity Indus. Inc., 872 F.3d 645, 660–661
(5th Cir. 2017). The Government offers no explanation as to Escobar’s effect on the analysis in
Renal Care Group. The plain language of Escobar does not seem to place a limitation on
knowledge of this particular conduct: “if the Government regularly pays a particular type of claim
in full despite actual knowledge that certain requirements were violated, and has signaled no
change in position, that is strong evidence that the requirements are not material.” Escobar, 136
S.Ct. at 2004. As such, the Government’s reliance on Renal Care Group is unpersuasive.
The Court is not holding that the Government’s conduct regarding other entities will prove
or disprove materiality, but the Court finds that, pursuant to Escobar, the information is relevant
for discovery purposes. However, the Court notes that Paramedics Plus’s document request for
any communications regarding profit caps is broad.
Paramedics Plus has established that
information pertaining to the Government’s continued payment of claims after discovery of a profit
cap is relevant but has not sufficiently established that all communications related to profit caps
10
Renal Care Group states that “the focus is on the government’s knowledge of these defendants’ conduct and the
allegedly false claims at issue in the particular case, rather than of practices industry-wide or the practice of other
entities not involved in this case.” 2008 WL 5233028, at *2.
12
are relevant. Accordingly, the Court limits Paramedics Plus’s request to documents pertaining to
the Government’s continued payment of claims after discovery of a profit cap.
If this production requires the Government to produce any documents from its investigation
or litigation files, and the Government is concerned about this information being disseminated, the
Court reminds the Government that the evidence can be produced subject to the Court’s protective
order: “Except as otherwise indicated below, all documents or discovery responses designated by
the producing party as “Confidential” or “Attorneys Eyes Only” and which are disclosed to
produce to the attorneys for the parties to this litigation are Protected Information and are entitled
to confidential treatment as described below.” (Dkt. #11 at p. 2).
III.
Interrogatories
The Government maintains that it answered Interrogatory Number 14. 11 The Government
asserts that, in response to Interrogatory Number 14, it attempted to explain that the Government
would not deny payment simply based on a profit cap, and offered examples of times that it settled,
or in effect denied payment, with entities that submitted claims tainted by a violation of the AKS.
Paramedics Plus responds that pointing to settlement agreements does not answer the question of
whether the Government denied payment based on a profit cap agreement. The Court agrees that
this does not directly answer the question; however, the Court notes, as it did before, that denial
of a claim based on a profit cap is not the test for materiality here, but it could possibly lead to
relevant information. It will later be Paramedics Plus’s burden later to show that any information
it receives from this interrogatory proves that the Government cannot establish materiality of the
false certification of compliance with the AKS.
11
The Court notes that the Government stated it already answered two disputed interrogatories: “Interrogatories No. 12
and 14;” however, it proceeded to explain its answers to Interrogatories Number 13 and 14. Without any argument or
explanation, and the Court’s review of the responses, the Government did not answer Interrogatory Number 12.
13
CONCLUSION
It is therefore ORDERED that Paramedics Plus, LLC’s Motion to Compel the United
.
States of America to Comply with Discovery (Dkt. #131) is hereby GRANTED IN PART.
Accordingly, the Government is compelled to answer Interrogatory Numbers 10–12, and 14 and
produce documents in its possession, custody, or control related to the Government’s discovery of
a profit cap and continued payment after the fact within fourteen days of the date of this Order.
SIGNED this 30th day of January, 2018.
___________________________________
AMOS L. MAZZANT
UNITED STATES DISTRICT JUDGE
14
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?