Joint Stipulation of Voluntary Dismissal — ex rel. GNGH2 Inc. v. Carson Tahoe Physician Clinics (E.D. Cal.)

Summary

A Joint Stipulation of Voluntary Dismissal by the United States and Relator, filed Mar 05, 2025 in United States ex rel. GNGH2 Inc. v. Carson Tahoe Physician Clinics, Case No. 2:23-CV-1361 KJM CKD, U.S. District Court, Eastern District of California. The United States and Relator GNGH2, Inc. stipulate under Federal Rule of Civil Procedure 41(a) that the action shall be dismissed pursuant to the terms of a Settlement Agreement, with the dismissal with prejudice as to the Relator and without prejudice to the United States. The parties agree that the Court retains jurisdiction to enforce the Settlement Agreement, and the United States requests that Relator's Complaint, the Stipulation and the proposed order be unsealed while other papers remain under seal.

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“Joint Stipulation of Voluntary Dismissal — ex rel. GNGH2 Inc. v. Carson Tahoe Physician Clinics (E.D. Cal.).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-2-23-cv-01361-dkt-15-e-d-cal-bf41526a56/, SHA-256 30ab38ec70002161a3032715644ae02316530979ba2c6f4cd11cd340bccc00bb.

Full text

1 MICHELE BECKWITH
Acting United States Attorney
2 TARA A. AMIN
Assistant United States Attorney
3 501 I Street, Suite 10-100
FILED
Sacramento, California 95814 Mar 05, 2025
4 Telephone: (916) 554-2700 CLERK, U.S. DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
5 Attorneys for the United States

8 UNITED STATES DISTRICT COURT

9 EASTERN DISTRICT OF CALIFORNIA

11 UNITED STATES ex rel., GNGH2 INC., CASE NO. 2:23-CV-1361 KJM CKD

12 Plaintiff/Relator,
JOINT STIPULATION OF VOLUNTARY
13 v. DISMISSAL BY THE UNITED STATES AND
RELATOR
14 CARSON TAHOE PHYSICIAN CLINICS,

15 Defendants.

17 Pursuant to Federal Rule of Civil Procedure 41(a), the United States of America and Relator

18 GNGH2, Inc. (“Relator), hereby stipulate that the above-captioned action shall be dismissed pursuant to

19 the terms of the Settlement Agreement between the United States, Relator, and Carson Tahoe Physician

20 Clinics, Carson Tahoe Health System, and Carson Tahoe Continuing Care Hospital dated January 23,

21 2025.

22 The United States and Relator stipulate to the entry of the attached Proposed Order dismissing

23 the False Claims Act claims asserted in this action on behalf of the United States. The dismissal shall be

24 with prejudice as to the Relator and without prejudice to the United States.

25 Notwithstanding the entry of a dismissal herein, the Parties agree that the United States District

26 Court for the Eastern District of California shall retain jurisdiction to enforce the terms of the Settlement

27 Agreement, if necessary, and that this Court shall be the sole venue for any dispute arising thereunder.

28 The United States requests that Relator’s Complaint, this Stipulation, and the attached proposed

STIPULATION OF DISMISSAL
1 Order be unsealed. The United States requests that all other papers on file in this action remain under

2 seal because in discussing the content and extent of the United States’ investigation, such papers are

3 provided by law to the Court alone for the sole purpose of evaluating whether the seal and time for

4 making an election to intervene should be extended. Relator does not oppose this request.

5 A proposed order accompanies this stipulation.

7 Respectfully submitted,

8 Dated: March 5, 2025 MICHELE BECKWITH
Acting United States Attorney
9

10 By: /s/ Tara A. Amin
TARA A. AMIN
11 Assistant United States Attorney
12
Dated: March 5, 2025 COUNSEL FOR RELATOR
13 GNGH2, INC.
14

15 By: /s/ Yael Lerman
YAEL LERMAN
16

STIPULATION OF DISMISSAL 2
1 USA ex rel. GNGH2 Inc. v. Carson Tahoe Physician Clinics
2:23-cv-01361-KJM-CKD
2

3 CERTIFICATE OF SERVICE BY ELECTRONIC MAIL AND U.S. MAIL

4 The undersigned hereby certifies that he is an employee in the Office of the United States

5 Attorney for the Eastern District of California and is a person of such age and discretion to be competent

6 to serve papers;

7 That on March 5, 2025, he served a copy of:

8 JOINT STIPULATION OF VOLUNTARY DISMISSAL BY THE UNITED STATES AND
RELATOR
9
[PROPOSED] ORDER ON THE JOINT STIPULATION OF VOLUNTARY DISMISSAL BY THE
10 UNITED STATES AND RELATOR

11 by transmitting true and correct copies thereof from Isaac.Shu@usdoj.gov to the electronic mail address

12 listed, and

13 by placing a true and correct copy thereof in a postage paid, sealed envelope, addressed as stated below, which

14 are the last known address of the party being served, and placed said envelope in the United States mail, at

15 Sacramento, California.

16 ADDRESSEE(S):

17 Yael Lerman, Esq.
ylmazar@gmail.com
18 6505 Wilshire Boulevard
Los Angeles, CA 90048
19
Attorney for Relator GNGH2 Inc.
20

21
/s/ Isaac Shu
22 ISAAC SHU
23

Certificate of Service by Electronic Mail and U.S. Mail 1
USA ex rel. GNGH2 INC. v. Carson Tahoe Physician Clinics, 2:23-cv-01361-KJM-CKD

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File: 15.pdf
Size: 109,370 bytes
SHA-256: 30ab38ec70002161a3032715644ae02316530979ba2c6f4cd11cd340bccc00bb
Our copy: 15.pdf
Original: archive.org