STIPULATION OF DISMISSAL; [PROPOSED ORDER]

C 08-3411 WHA (DMR) 

1 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

30

BRIAN J. STRETCH (CABN 163973) 

Acting United States Attorney 

ALEX G. TSE (CABN 152348) 

Chief, Civil Division 

SARA WINSLOW (DCBN 457643) 

MELANIE L. PROCTOR (CABN 228971) 

Assistant United States Attorneys 

 450 Golden Gate Avenue, Box 36055 

 San Francisco, California 94102 

 Telephone: (415) 436-6925 

 Facsimile: (415) 436-6748 

 e-mail: sara.winslow@usdoj.gov

 

Attorneys for the United States of America 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

UNITED STATES ex rel. BONNIE 

LAMMERS, M.D.,

Plaintiff and Relator,

v.

FARIDEH HEIDARPOUR, et al.,

Defendants.

)

)

)

)

)

)

)

)

)

)

)

NO. CV 08-3411 WHA (DMR)

STIPULATION OF DISMISSAL; 

[PROPOSED] ORDER

Subject to the Court’s approval, and pursuant to Fed. R. Civ. P. 41(a)(2), IT IS HEREBY 

STIPULATED by the United States of America, qui tam Relator Bonnie Lammers, and Defendants 

Michael Hebrard, M.D., Richard Lavigna, D.P.M., Advanced Physical Medicine & Rehab Group, Inc., 

Advanced Occupational Rehabilitation, Inc., Advanced Medicine and Rehabilitation of Texas, Inc., and 

Advanced Medicine and Rehabilitation of Texas, P.A., that this action is dismissed with prejudice.

1. This action named nine Defendants. The three Defendants not listed above (Defendants 

Farideh Heidarpour, Ali Heidarpour, and A.B.C. Billing, Inc.) were dismissed from this case 

by Order dated September 8, 2015, after those Defendants paid the amounts due under their 

August 28, 2013 settlement agreement. 

Case 3:08-cv-03411-WHA Document 81 Filed 02/02/16 Page 1 of 3
STIPULATION OF DISMISSAL; [PROPOSED ORDER]

C 08-3411 WHA (DMR) 

2 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

30

2. The remaining Defendants have now paid the amounts due under their July 11, 2012 

settlement agreement, and they are being dismissed with prejudice, pursuant to the terms of 

the July 11, 2012 settlement agreement. Accordingly, the entire case is now being dismissed 

with prejudice. 

IT IS SO STIPULATED. 

Respectfully submitted, 

 BRIAN J. STRETCH 

 Acting United States Attorney 

Dated: February 1, 2016 By: /s/ signature on file 

 SARA WINSLOW 

 MELANIE L. PROCTOR 

 Assistant United States Attorneys 

 Attorneys for the United States 

 MCBREEN & SENIOR 

Dated: February 1, 2016 By: /s/ signature on file 

MATTHEW WESTON 

 Attorney for Relator 

 

 LAW OFFICES OF DENISE EATON-MAY 

Dated: January 18, 2016 By: /s/ signature on file 

 DENISE EATON MAY 

Attorney for Defendants Michael Hebrard, M.D., 

Advanced Physical Medicine & Rehab Group, Inc., 

Advanced Occupational Rehabilitation, Inc., 

Advanced Medicine and Rehabilitation of Texas, 

Inc., and Advanced Medicine and Rehabilitation of 

Texas, P.A. 

 KNIGHT EMPLOYMENT LAW 

Dated: January 21, 2016 By: /s/ signature on file 

CODY D. KNIGHT 

Attorney for Defendant Richard Lavigna, D.P.M. 

Case 3:08-cv-03411-WHA Document 81 Filed 02/02/16 Page 2 of 3
STIPULATION OF DISMISSAL; [PROPOSED ORDER]

C 08-3411 WHA (DMR) 

3 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

30

[PROPOSED] ORDER 

PURSUANT TO STIPULATION, IT IS HEREBY ORDERED that this action is dismissed with 

prejudice. 

 IT IS SO ORDERED. 

Dated: 

 HONORABLE WILLIAM ALSUP 

 United States District Judge

February 2, 2016.

Case 3:08-cv-03411-WHA Document 81 Filed 02/02/16 Page 3 of 3