Joint Stipulation of Dismissal of Defendants; Consent of the United States to Dismissal — United States ex rel. Chawla v. Unified Care Services, LLC (Dkt. 44, C.D. Cal.)

Summary

The United States and relator Ashwani Chawla filed a joint stipulation on April 16, 2025 in United States ex rel. Chawla v. Unified Care Services, LLC (C.D. Cal., No. 2:21-cv-05935-GW-RAO), agreeing under Rule 41(a)(1)(i) to the final dismissal of the action against the defendants, subject to a Settlement Agreement executed on January 14, 2025. The United States had intervened as to the Covered Conduct described in Recital Paragraph F of that agreement and declined to intervene on the relator's other allegations. Dismissal is with prejudice as to the United States on the Covered Conduct, without prejudice as to its other claims, and with prejudice as to the relator on all claims. Under 31 U.S.C. § 3730(b)(1), the Attorney General consented to the dismissal as commensurate with the public interest. A proposed order was filed concurrently.

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Case 2:21-cv-05935-GW-RAO       Document 44     Filed 04/16/25   Page 1 of 3 Page ID
                                           #:273


     YAAKOV M. ROTH
1    Acting Assistant Attorney General
     BILAL A. ESSAYLI
2    United States Attorney
     DAVID M. HARRIS, AUSA
3    Chief, Civil Division
     JACK D. ROSS, AUSA (CBN 265883)
4    Chief, Civil Fraud Section
           Room 7516, Federal Building
5          300 N. Los Angeles Street
           Los Angeles, California 90012
6          Tel: (213) 894-7395
           Fax: (213) 894-7819
7          Email: Jack.Ross@usdoj.gov
     JAMIE ANN YAVELBERG
8    COLIN M. HUNTLEY
     BENJAMIN C. WEI
9    Attorneys, Civil Division
     United States Department of Justice
10         P.O. Box 261, Ben Franklin Station
           Washington, D.C. 20044
11         T: 202.616.2875| F: 202.616.3085
           Email: Benjamin.C.Wei@usdoj.gov
12   Attorneys for the United States of America
13                             UNITED STATES DISTRICT COURT
14                     FOR THE CENTRAL DISTRICT OF CALIFORNIA
15                                     WESTERN DIVISION
16   UNITED STATES OF AMERICA ex                   No. LACV 21-5935 GW (RAOx)
     rel. ASHWANI CHAWLA,
17                                                 JOINT STIPULATION OF DISMISSAL
                 Plaintiffs,                       OF DEFENDANTS; CONSENT OF THE
18                                                 UNITED STATES TO DISMISSAL
                        v.
19                                                 [FILED CONCURRENTLY:
     UNIFIED CARE SERVICES, LLC, et                [PROPOSED] ORDER]
20   al.,
21               Defendants.
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25         Pursuant to Federal Rule of Civil Procedure 41(a)(1)(i), the United States of
26   America (“United States”) and Relator, hereby, and upon order of the Court, stipulate
27   and agree to the final dismissal of this action against Defendants, subject to the terms of
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     Case 2:21-cv-05935-GW-RAO        Document 44     Filed 04/16/25   Page 2 of 3 Page ID
                                            #:274



1    the Settlement Agreement among the United States, Relator, and Defendants, executed
2    on January 14, 2025. The United States previously intervened against Defendants
3    regarding the Covered Conduct described in Recital Paragraph F of the Settlement
4    Agreement, and declined to intervene as to Relator’s other remaining allegations against
5    Defendants.
6          The dismissal shall be:
7          (1)     with prejudice as to the United States as to all claims against Defendants
8                  regarding the Covered Conduct described in Recital Paragraph F of the
9                  Settlement Agreement;
10         (2)     without prejudice as to the United States as to all other claims against
11                 Defendants; and
12         (3)     with prejudice as to the Relator as to all claims against Defendants.
13         Except as specifically provided in the Settlement Agreement, each party shall bear
14   its own fees and costs. The Court shall retain jurisdiction to enforce the terms of the
15   Settlement Agreement.
16         Pursuant to 31 U.S.C. § 3730(b)(1), and in the interests of justice, the Attorney
17   General of the United States, through the undersigned attorney, hereby consents to
18   Relator’s dismissal of this action. The United States provides this consent based on its
19   determination that such a dismissal is commensurate with the public interest and that the
20   matter does not warrant the continued expenditure of government resources to pursue or
21   monitor the action based on currently available information.
22         A [Proposed] Order is filed concurrently herewith.
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     Case 2:21-cv-05935-GW-RAO       Document 44      Filed 04/16/25   Page 3 of 3 Page ID
                                           #:275



1                                       Respectfully submitted,
2    DATED: April 16, 2025               COTCHETT, PITRE & MCCARTHY, LLP
3
                                         /s/ Theresa E. Vitale
4                                        THERESA E. VITALE
                                         Attorneys for Relator
5
6    DATED: April 16, 2025               YAAKOV M. ROTH
                                         Acting Assistant Attorney General
7                                        BILAL A. ESSAYLI
                                         United States Attorney
8                                        DAVID M. HARRIS, AUSA
                                         Chief, Civil Division
9                                        JAMIE ANN YAVELBERG
                                         COLIN M. HUNTLEY
10                                       BENJAMIN C. WEI
                                         Attorneys, Civil Division
11                                       /s/ Jack D. Ross
12                                       JACK D. ROSS, AUSA
                                         Assistant United States Attorney
13                                       Chief, Civil Fraud Section
                                         Attorneys for the United States of America
14
15                                           Attestation
16         I hereby attest that the other signatory listed, on whose behalf the filing is
17   submitted, concurs in the filing’s content and has authorized the filing.
18    Dated: April 16, 2025
19
                                             /s/ Jack D. Ross
20                                           JACK D. ROSS
                                             Assistant United States Attorney
21                                           Chief, Civil Fraud Section
22                                           Attorneys for the United States of America

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