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IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

PENSACOLA DIVISION

United States of America

ex rel. Rayme M. Edler, M.D.

Plaintiffs, 

v. Case 3:20-cv-05503-RV-HTC

Escambia County

Defendant.

_____________________________/

Joint Status Report

The Scheduling Order entered October 27, 2022, directed the parties to file a 

joint status report by the end of every month, beginning January 31, 2023, which 

sets out whether the Order’s schedule is being met “and any new developments that 

need to be addressed or the times set out herein revisited.” Doc. 68 at 1-2.

Court’s September 30, 2022, Order on Production

The parties continue to discuss the nature of a stipulation which might 

obviate the production of at least a portion of the documents the Court ordered 

Escambia to produce on September 30, 2022. 

The most recent version of the proposed stipulation was sent to Escambia’s 

counsel by Edler counsel on December 12, 2022. Counsel held several calls to 

discuss the stipulation. Escambia informed Edler by email on March 15, 2023, that 

Case 3:20-cv-05503-RV-HTC Document 93 Filed 03/31/23 Page 1 of 5
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a “shade” session is scheduled with the Escambia’s Board of Commissioners to 

occur on April 13, 2023 where the proposed stipulation will be discussed.

Edler Document Request Sets 1-4

Dr. Edler’s counsel sent a letter to Escambia’s Counsel on November 30, 

2022, detailing deficiencies with respect to Escambia’s responses to, and production 

of, documents related to Dr. Edler’s First, Second, Third, and Fourth Requests for 

Production of Documents (all such requests then promulgated).1 Since December 

28, 2022, the parties have discussed via telephone and email the outstanding 

deficiencies. On March 25, 2023, Edler sent an email to Escambia. Regarding 

Edler’s First, Second, Third and Fourth Requests, Edler’s letter:

• Requested a date by which Escambia will provide supplemental 

productions and amended responses pursuant to Escambia’s email of 

March 15, 2023, committing to the same; and

• Proposed refined search terms and custodians for email, text messages, 

and other electronic data responsive to certain document requests.

Escambia responded on March 25, 2023, and among other things, committed to 

responding to the proposals on search terms and custodians the week of March 25th 

after consultation with Escambia’s e-discovery vendor. Escambia suggested a call 

1 Defendant’s counsel received the letter on December 7, 2022, due to the email 

ending up in their spam folder and not the inbox folder.

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between the parties early the week of April 3, 2023 to discuss the remaining 

outstanding issues.

Edler Document Request Set 5

On December 22, 2022, Dr. Edler promulgated a Fifth Request for 

Production of Documents largely related to the new allegations in the SAC. On 

March 3, 2023, Escambia requested a 30-day extension of time to respond to 

Plaintiff’s Fifth Set of Document Requests that were pending while Escambia’s

Motion to Reconsider was considered by the Court. Docs. 81 and 85. On March 13, 

2023, the Court granted Escambia's Motion and allowed 30 days from the date of 

the Order to produce the requested discovery. Doc. 88. Escambia is currently 

scheduled to respond to Edler’s Fifth Request for Production of Documents on April 

13, 2023. 

The parties continue to meet and confer about Escambia’s anticipated 

production. And assuming Escambia complies with the Court's Order by April 13, 

2023, Edler does not anticipate any further extensions of the fact discovery 

deadline.

Dispositive Motion Practice on Plaintiff’s Second Amended Complaint

The parties’ previous report filed February 28, 2023, indicated that the Court 

had not ruled on Escambia’s Motion for Reconsideration. Doc. 81. On March 3, 

2023, however, the Court denied Escambia’s motion and gave Escambia 21 days 

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from the date of the Order to file its response to the SAC. Doc. 84. On March 24, 

2023, Escambia responded to the SAC by filing a motion to dismiss. Doc. 91. Edler 

intends to oppose Escambia’s motion and will file her response on or before April 7, 

2023.

/s/ Jonathan Kroner

FBN 328677

Jonathan Kroner Law Office

6001 N Ocean Dr. Ste 806

Hollywood, FL 33019-4617

305.310.6046

jk@FloridaFalseClaim.com

Law Offices of Darth M. Newman 

LLC

Darth M. Newman

1140 Thorn Run Rd., #601

Coraopolis, PA 15108

412.436.3443

darth@dnewmanlaw.com

(admitted pro hac vice)

Attorneys for Qui Tam Plaintiff

Relator Rayme M. Edler, M.D

/s/ Katherine Gudaitis__

Katherine Gudaitis, ESQ.

FBN: 106954

kg@lydecker.com

Stephanie Pidermann

FBN :60414

sp@lydecker.com

Lydecker LLP

1221 Brickell Ave, Fl. 19

Miami, Florida 33131

Telephone: 305-416-3180

Attorneys for Escambia County

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LR 7.1 (F) Certificate of Word Count

I certify the LR 7.1 (F) word count is 604 words. I relied on MS Word’s count for 

this certification. 

/s/ Jonathan Kroner

Certificate of Service

I certify I electronically filed the foregoing document with the Clerk of Court using 

CM/ECF on the date stamped above to be served on all counsel of record.

/s/ Jonathan Kroner

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