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Settlement Document 1
Settlement Document 1
Pursuant to Federal Rule of Civil Procedure 41(a)(2), the False Claims Act, 31 U.S.C. §§
3729, et seq., and in accordance with the terms and conditions of the Settlement Agreement with
(collectively, “Methodist”), in this case, the United States and Relators jointly stipulate to the
dismissal of this action with prejudice subject to the terms of that agreement. A copy of the
Settlement Agreement with Methodist is attached. See Ex. 1 (Settlement Agreement with
Methodist). On January 3, 2024, under the terms of the Settlement Agreement, Methodist made
its total settlement payment. Therefore, this action can now be dismissed in its entirety.
The Relators, on behalf of themselves, their heirs, successors, attorneys, agents, and
assigns, stipulate and agree that the Settlement Agreement referenced above and the terms and
conditions described therein are fair, adequate, and reasonable under all of the circumstances of
this case, that they will not challenge the settlement pursuant to 31 U.S.C. § 3730(c)(2)(B), and
that they expressly waive the opportunity for a hearing on any objection to the settlement under 31
U.S.C. § 3730(c)(2)(B).
Relators now stipulate to the entry of an order that (1) dismisses the Complaint-in-Intervention in
this action; and (2) provides that the Court retains jurisdiction over this action to the extent
necessary to enforce the terms and conditions of the Settlement Agreement. A proposed order is
attached.
Respectfully submitted,
s/ Brian A. Vrooyn
BRIAN A. VROOYN
Law Offices of Bryan A. Vroon, LLC
1380 West Paces Ferry Road, Suite 2270
Atlanta, GA 30327
Email: bryanvroon@gmail.com
I hereby certify that on January 4, 2024, a true and correct copy of the foregoing was served
via email to the following:
Pursuant to Federal Rule of Civil Procedure 41(a)(2), the False Claims Act, 31 U.S.C. §§
3729, et seq., and in accordance with the terms and conditions of the Settlement Agreement fully
executed on December 22, 2023, among the United States, Relators, and Defendants Methodist Le
this case, the United States and Relators filed a Stipulation of Dismissal of the Civil Action.
IT IS HEREBY ORDERED that, subject to the terms of the December 22, 2023 Settlement
Agreement executed by the United States, Methodist, and Relators, the civil action is now
dismissed with prejudice as to all remaining claims in this action. This Court retains jurisdiction
over any disputes that may arise regarding the Settlement Agreement.
It is so ORDERED.