[Proposed] Order re Joint Stipulation of Dismissal of Defendants — United States ex rel. Chawla v. Unified Care Services, LLC (Dkt. 44-1, C.D. Cal.)

Summary

A [proposed] order re joint stipulation of dismissal of defendants in United States ex rel. Ashwani Chawla v. Unified Care Services, LLC, et al., No. 2:21-cv-05935-GW-RAO, in the U.S. District Court for the Central District of California, filed April 16, 2025 as Document 44-1 by Department of Justice and U.S. Attorney's Office counsel for the United States. It recites that the United States and the relator submitted a joint stipulation of dismissal under Rule 41(a)(1) and 31 U.S.C. § 3730(b)(1), subject to a Settlement Agreement. The proposed order would dismiss the case with prejudice as to the United States for the Covered Conduct, without prejudice as to other claims, and with prejudice as to the relator, with each party bearing its own fees and the court keeping jurisdiction to enforce the settlement. The signature line is undated.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Record facts

Full text

Case 2:21-cv-05935-GW-RAO      Document 44-1     Filed 04/16/25   Page 1 of 2 Page ID
                                           #:276


      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                                                  [PROPOSED] ORDER RE JOINT
                  Plaintiffs,                       STIPULATION OF DISMISSAL OF
18                                                  DEFENDANTS
                         v.
19                                                  [FILED CONCURRENTLY: JOINT
      UNIFIED CARE SERVICES, LLC, et                STIPULATION OF DISMISSAL OF
20    al.,                                          DEFENDANTS; CONSENT OF THE
                                                    UNITED STATES TO DISMISSAL]
21                Defendants.
22
23
24
25          WHEREAS, the United States of America (“United States”) and Relator have
26    submitted a Joint Stipulation of Dismissal of Defendants pursuant to Rule 41(a)(1) of the
27
28

     Case 2:21-cv-05935-GW-RAO        Document 44-1    Filed 04/16/25   Page 2 of 2 Page ID
                                             #:277



1     Federal Rules of Civil Procedure, 31 U.S.C. § 3730(b)(1), in accordance with and
2     subject to the Settlement Agreement, and with the consent of the United States.
3           THEREFORE, IT IS ORDERED THAT:
4           The dismissal shall be:
5           (1)    with prejudice as to the United States as to all claims against Defendants
6                  regarding the Covered Conduct described in Recital Paragraph F of the
7                  Settlement Agreement;
8           (2)    without prejudice as to the United States as to all other claims against
9                  Defendants; and
10          (3)    with prejudice as to the Relator as to all claims against Defendants.
11          Except as specifically provided in the Settlement Agreement, each party shall bear
12    its own fees and costs. The Court shall retain jurisdiction to enforce the terms of the
13    Settlement Agreement.
14          IT IS SO ORDERED.
15
16    Dated: ____________                    _______________________________
                                             UNITED STATES DISTRICT JUDGE
17
18
19
20
21
22
23
24
25
26
27
28

File and source

File

44-att1.pdf

Size

141,934 bytes

SHA-256

35b6ba6327f41de88aab7ca6e5da3721a707a89d588d44030db154ddba112d6d

Our copy

44-att1.pdf