Kelly v. Novartis Pharm. To register for a PACER account, go the Pacer website at # https://pacer.uscourts.gov/register-account.Pro Hac Vice Admission Request Instructions # https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. Instead, those services were provided free of charge. #57) filed by Appellant Martin Flanagan. Mem. 12% off. On February 5, 2021 a long-time former Fresenius Medical Care North America (Fresenius) employee, Martin Flanagan, filed a qui tam relator amended complaint (Complaint) against Fresenius alleging that the company had entered into arrangements with hospitals and physicians in order to secure dialysis patient referrals for Fresenius outpatient dialysis clinics, and that such arrangements violated the Federal False Claims Act (FCA) and the Federal Anti-Kickback Statute (AKS). CKD Project, LLC v. Fresenius Med. Attorneys admitted Pro Hac Vice must have an individual PACER account, not a shared firm account, to electronically file in the District of Massachusetts. Whistleblower Lawsuit Against Fresenius Alleges Unlawful 181). WebFlanagan v. Fresenius Medical Care Holdings, Inc. - Docket Entries . On February 5, 2021 a long-time former Fresenius Medical Care North America (Fresenius) employee, Martin Flanagan, filed a qui tam relator amended Furthermore, they do not directly disclose the existence of any of the alleged schemes, or any other form of fraud, nor do they describe facts from which the existence of a fraudulent scheme might be inferred. Among other things, the complaint uses the passive voice throughout: claims were submitted, rather than FMCNA submitted claims.. 142-43). Beginning in approximately 2007, FMCNA allegedly realized that the company's organic growth (that is, growth from adding new patients and not through acquisitions) was almost nonexistent. Bonuses and performance evaluations for mid-level managers were tied, in part, to patient growth and the increase in number of treatments at individual clinics. Martin Flanagan is a Senior National Account Manager at Quick International Courier based in Jamaica, New York. (McManus, Caetlin) (Entered: 11/02/2021), Docket(#9) ELECTRONIC NOTICE of Case Reassignment. . The objective of the essential facts test is to determine whether the statutorily required threshold for notifying the government of the fraud alleged in the later-filed suit has been met. In summary, the amended complaint fails to state allegations of fraud under the FCA with the particularity required by Rule 9(b). See 31 U.S.C. were false .); id. 232-35 (Diablo Nephrology in California); id. WebMartin Flanagan is a Director, National of Acute Dialysis Services at Liberty Dialysis based in Anchorage, Alaska. 45-49). . v. Balfour Beatty Infrastructure, Inc., 2014 WL 2611312, at *2 (N.D. Cal. . To register for a PACER account, go the Pacer website at # https://pacer.uscourts.gov/register-account.Pro Hac Vice Admission Request Instructions # https://www.mad.uscourts.gov/caseinfo/nextgen-pro-hac-vice.htm.A Notice of Appearance must be entered on the docket by the newly admitted attorney. at *3 (collecting cases). (McManus, Caetlin) (Entered: 11/22/2021), (#14) MOTION for Leave to Appear Pro Hac Vice for admission of Jamie Bennett Filing fee: $ 100, receipt number AMADC-9065597 by Martin Flanagan. Defendant also contends that the claims concerning joint-venture agreements are barred by the first-to-file rule. Essentially, that version of the complaint alleged that FMCNA's efforts to incentivize referrals to its clinics violated the Anti-Kickback Statute, 42 U.S.C. The question here is whether the complaint has met that standard. (Id. Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. Care Holdings, Inc., 551 F.Supp.3d 27, 43 (E.D.N.Y. Patients who were referred to non-FMCNA clinics were categorized as leakage. (Id. (Attachments: #1 Docket Sheet from District of Maryland, #2 Docket Entries 1-30, #3 Docket Entries 31-50, #4 Docket Entries 51-56, #5 Docket Entries 58-74) (Jones, Sherry) Modified on 10/7/2021 to correct docket text. 286 (Texas) (All such claims . The 2010 Patient Protection and Affordable Care Act amendment to the public-disclosure bar made two notable changes to that definition. WebFlanagan v. Fresenius Medical Care Holdings, Inc., No. 274 (North Carolina) ([E]ach of these claims was false .); id. Connect via Twitter or email . 41 (The fact that medical director compensation is lower where the physician actually shares the cost of his or her compensation through his or her joint venture (ownership) agreement shows that where there are arms-length negotiations between two more or less equal parties, a lower compensation rate results.)). To strike a balance between encouraging whistle-blowing and discouraging opportunistic behavior, the FCA contains a public-disclosure bar. Id. 2016); Fed.R.Civ.P. FMCNA then moved to dismiss the complaint. 9(b). Flanagan v. Fresenius Medical Care Holdings, Inc. :: Justia Dockets & Filings Notice of appeal (doc. It then alleges: Similarly, for North Carolina, the complaint provides a table of Medicaid (but not Medicare) revenue for a period of six years at fourteen dialysis centers. 01 Jun 2022. 2004), abrogated on other grounds by Allison Engine Co. v. United States ex rel. 85). Nov. 12, 2014) (ECF No. 3729(b)(2). The public-disclosure bar provides as follows: The public-disclosure bar of 3730(e)(4)(A) applies when (1) a public disclosure of the allegations or transactions in a relator's complaint . 217). 99-345, 1986 U.S.C.C.A.N. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia. Join Facebook to connect with Martin Flanagan and others you may know. Pilon v. Martin Marietta Corp., 60 F.3d 995, 998-99 (2d Cir. FRESENIUS MEDICAL CARE HOLDINGS, INC. doing business as Fresenius Medical Care North America, (#20) NOTICE of Appearance by Noah M Rich on behalf of Martin Flanagan (Rich, Noah) (Entered: 11/24/2021), (#19) NOTICE of Appearance by W. Scott Simmer on behalf of Martin Flanagan (Simmer, W.) (Entered: 11/22/2021), Affidavit Certificate of Noah M. Rich in Support of Motion for Appearance Pro Ha, Affidavit Certificate of Jamie Bennett in Support of Motion for Appearance Pro H, Affidavit Certificate of W. Scott Simmer in Support of Motion for Admission Pro, (#12) NOTICE of Appearance by Christopher P. Sullivan on behalf of Martin Flanagan (Sullivan, Christopher) (Entered: 11/18/2021), Affidavit Certification of Megan S. Heinsz, (#4) NOTICE of Appearance by Maria R. Durant on behalf of Fresenius Medical Care Holdings, Inc. (Durant, Maria) (Entered: 10/07/2021), (#3) NOTICE of Appearance by William H. Kettlewell on behalf of Fresenius Medical Care Holdings, Inc. (Kettlewell, William) (Entered: 10/07/2021), Docket(#20) NOTICE of Appearance by Noah M Rich on behalf of Martin Flanagan (Rich, Noah) (Entered: 11/24/2021), Docket(#19) NOTICE of Appearance by W. Scott Simmer on behalf of Martin Flanagan (Simmer, W.) (Entered: 11/22/2021), Docket(#18) Chief Judge F. Dennis Saylor, IV: ELECTRONIC ORDER entered granting #17 Motion for Leave to Appear Pro Hac Vice Added Noah M. Rich. Id. (Id.). However, the First Circuit has rejected the holding in Poteet, explaining that earlier-filed complaints must provide only the essential facts to give the government sufficient notice to initiate an investigation into allegedly fraudulent practices and emphasizing that Section 3730(b)(5) contains no exceptions. United States ex rel. (Id. The central issue is whether relator can sidestep the requirement to plead false claims with particularity by alleging that every single claim is necessarily false. Wilson v. Bristol-Myers Squibb, Inc., 750 F.3d 111, 118 (1st Cir. 2009) to support the contention that when a first-filed complaint is dismissed on jurisdictional grounds, it cannot bar a later-filed complaint. 361 (Dallas Nephrology Associates)). 40). However, general allegations of illegal or fraudulent practices, without more, are not sufficient to state a claim under the False Claims Act. Defendant further contends that the CIA it had entered into with the OIG relating to conduct of a company FMCNA later acquired (National Medical Care) qualified as a public disclosure. It employs more than 40,000 employees and treats nearly 190,000 patients at approximately 2,400 outpatient clinics in the United States, including 39 in Massachusetts. 44). 45). Flanagan and his colleagues were allegedly instructed by their superiors to obtain hospital contracts at any cost to secure the referrals of discharged patients. . According to the complaint, FMCNA offered physicians the opportunity to enter into free practice-management agreements, in return for which it obtained the practice's data from the prior three to five years. 128). 28, 38-40, 60-65). Access this case on the Massachusetts District Court's Electronic Court Filings (ECF) System. 14). The second issue is whether the public-disclosure bar of the statute precludes all or any of the claims-that is, whether relator is filing suit concerning matters that had been previously disclosed to the public. 3729(a)(1)(A), (a)(1)(B). Defendant further contends that the original complaint did not contain any allegations concerning medical-director agreements, and that all claims based on such agreements should likewise be dismissed. Another six described a scheme involving improper remuneration relationships with physicians who serve as medical directors at Fresenius clinics. (Id. 9(b). (Id. The following is a relevant excerpt from an SEC filing cited by the court in CKD: That excerpt discloses that the joint ventures do not qualify for safe-harbor protection and identifies the penalties that might be imposed should the company be found to be in violation of the relevant statutes. 233 (Diablo Nephrology) (Every claim for reimbursement [FMCNA] submitted to [f]ederal health care programs associated with the treatment of these patients was tainted by kickbacks and therefore false within the meaning of the FCA.); id. 15). Use the links below to access additional information about this case on the US Court's PACER system. As to some of those medical practices, the complaint provides some amount of additional detail, although again it does not describe any specific false claims. Martin Flanagan First, it alleges that FMCNA offered remuneration to hospitals in two ways: by entering into contracts that provided no-cost and/or below-cost inpatient dialysis services, and by providing significant free services, including free dischargeplanning services, free in-service training to staff, free training to patients, and free quality assessment and improvement data analysis to hospitals. Under Rule 9(b), the standard for allegations of fraud is higher than the normal pleading standard. Attorneys admitted Pro Hac Vice must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of Massachusetts. As to the appellee L. Martin Flanagan, we affirm. Gagne v. City of Worcester, 565 F.3d 40, 45 (1st Cir. 1320a-7b, and False Claims Act, 31 U.S.C. (Id.). Protecting Participants of Clinical Trials Conducted in the Free or Below-Cost Management Services. Martin Flanagan - Flower Mound, Texas, United States To do so, the complaint must both allege the existence of a scheme to defraud and identify particularized false claims. 2021) case opinion from the District of Maryland US Federal District Court 1998) (rev'd on other grounds, 529 U.S. 765 (2000)). 111-148, 124 Stat. If relator is correct, that means that the entire government-payor business of FMCNA-which appears to amount to more than $10 billion in revenue per year-is based on fraud. Paperback. (Id. MARTIN FLANAGAN, Plaintiff-Relator, v. FRESENIUS MEDICAL CARE HOLDINGS, INC., d/b/a FRESENIUS MEDICAL CARE NORTH AMERICA, Defendant. 2005)). (Id. Based on the allegations of the complaint, it appears that all of the patients in question would have received treatment at a facility operated by FMCNA or a competitor, and all of those treatments would have been paid by Medicare regardless. June 21, 2005). may be available from PACER. The fact that the CKD complaint was dismissed on jurisdictional grounds is therefore irrelevant. 3730(b). Saldivar v. Fresenius Med. Compl. The statute has a variety of strict requirements, however, that serve both to ensure that the government has a fair opportunity to control the litigation and to screen out claims that are incomplete, redundant, or parasitic. Martin Flanagan has been a director and President and Chief Executive Officer of Invesco since 2005. Under the circumstances, the Court concludes that the bar does not apply. The allegations in CKD described a scheme whereby FMCNA allegedly paid kickbacks to doctors with whom it had entered into joint-venture agreements. First, defendant contends that the salaries paid to all of its medical directors is a matter of public record and is available on the website of the Center for Medicare and Medicaid Services (CMS). 304 (Washington state) (All such claims . 170. 1999)). United States v. Fresenius Med. Care Holdings - casetext.com Counsel may need to link their CM/ECF account to their upgraded individual pacer account. 2013) (internal quotation marks and citations omitted). The Medicare ESRD program is administered through the Centers for Medicare & Medicaid Services (CMS), an agency within the Department of Health and Human Services (HHS). Duxbury v. Ortho Biotech Prods., L.P., 579 F.3d 13, 26 (1st Cir. The description of the alleged scheme consisted of 25 paragraphs. It is true that a violation of the Anti-Kickback Statute that results in a federal health care payment is a per se false claim. Guilfoile, 913 F.3d at 190. A subscription to PACER is required. Chief Judge F. Dennis Saylor, IV assigned to case. (Id.). 172, 206-13). According to ZoomInfo records, Sandra Martins professional experience began in 1986. Flanagan For example, medical directors at 160 FMCNA clinics made more than $300,000 in 2019, well above the average compensation of medical directors at similarly located clinics. by. Suppose, for example, that in a world free from kickbacks, 25% of the dialysis services business of FMCNA would have been captured by competitors. Rather, the complaint must allege both the existence of a scheme and the making of particular false claims resulting from the scheme. One problem lies in the phrase results in-that is, the requirement of causation. . martin flanagan fresenius Attorneys admitted Pro Hac Vice must have an individual upgraded PACER account, not a shared firm account, to electronically file in the District of Massachusetts. And, presumably, it has other weapons in its arsenal for dealing with fraudulent conduct. Unless otherwise noted, the following facts are alleged in the amended complaint. Those arguments, however, are unavailing. To avoid dismissal, the complaint must therefore establish the necessary degree of particularity, if at all, through allegations of factual or statistical evidence that strengthen[ ] the inference of fraud on the government beyond a mere possibility. Duxbury I, 579 F.3d at 29. 256-69 (IMN and other practices in Indiana); id. 40). (Id.). Dismissal is appropriate if the complaint fails to set forth factual allegations, either direct or inferential, respecting each material element necessary to sustain recovery under some actionable legal theory. Gagliardi v. Sullivan, 513 F.3d 301, 305 (1st Cir. However, even assuming compliance with those requirements, the claims concerning joint-venture agreements would be barred in any event. (Id. If the trial Judge issues an Order of Reference of any matter in this case to a Magistrate Judge, the matter will be transmitted to Magistrate Judge Judith G. Dein. Under the circumstances presented here, the Court concludes that he cannot. Fresenius Medical Care North America, Waltham, MA, USA See all articles by this author. 23). at 555 (citations omitted). The False Claims Act, 31 U.S.C. A subscription to PACER is required. (Id. Lutz v. United States, 853 F.3d 131, 135 (4th Cir. The amended complaint describes-in considerable detail-a multi-part scheme to compensate caregivers in return for referrals. were false .); id. It might also be entirely rational to shift the burden to the defendant: that is, once a relator has established the existence of a kickback scheme, arguably the burden should be shifted to the defendant to prove that certain referrals were not caused by payment of kickbacks. FMCNA has moved to dismiss the complaint for failure to state a claim upon which relief can be granted pursuant to Fed.R.Civ.P. D. Pleading Fraud with Particularity under Rule 9(b). Martin Flanagan United States of America Defendant FRESENIUS MEDICAL CARE HOLDINGS, INC. doing business as Fresenius Medical Care North America No published case in the First Circuit, however, has ever gone so far. If the trial Judge issues an Order of Reference of any matter in this case to a Magistrate Judge, the matter will be transmitted to Magistrate Judge Judith G. Dein. (Id. Jason S. Greis at 312.624.6412 orjgreis@beneschlaw.com. A more recent docket listing 02-11738, 2013 WL 682740, at *5 (D. Mass. Compl. If you do not agree with these terms, then do not use our website and/or services. (Attachments: #1 Affidavit Certificate of W. Scott Simmer in Support of Motion for Admission Pro Hac Vice)(Sullivan, Christopher) (Entered: 11/22/2021), (#11) Chief Judge F. Dennis Saylor, IV: ELECTRONIC ORDER entered granting #6 Motion for Leave to Appear Pro Hac Vice Added James F. Bennett. United States District Court, D. Massachusetts. Defendant correctly contends that the initial complaint did not contain any allegations concerning unlawful joint-venture agreements, or the provision of free services to hospitals, physicians, and patients. v. Fresenius Medical Care [$6,000,000.00] - San Diego Sexual Harassment Attorneys, Sexual Harassment Lawyers in San Diego, CA. 3730(b)(5). (Id. End-Stage Renal Disease (ESRD) is the stage of advanced kidney impairment that requires either continued dialysis treatments or a kidney transplant to sustain life. Counsel may need to link their CM/ECF account to their upgraded individual pacer account. Compl. claims . Dec. 2, 2022). 14-cv-6646 (E.D.N.Y. . Martin Flanagan is a journalist and author who writes on sport, Australian culture and the relationship between indigenous and non-indigenous Australia. Dialysis refers to a treatment regimen aimed at artificially replacing some of the functions performed by a healthy kidney. 353, 357 (Balboa); id. CKD Project v. FMCNA, No. Fresenius Medical Care Holdings, Inc., 1:14-cv-00665 Brought to you by the RECAP Initiative and Free Law Project, a non-profit dedicated to creating high quality of Cunningham v. Millennium Lab'ys of Cal., Inc., 713 F.3d 662, 669-70 (1st Cir. 293 (Washington state) (All such claims . It is sufficient to conclude that judgmental immunity is not applicable where, as here, there is evidence, if believed, that the attorneys fell below the standard of reasonable care in representing their client. June 16, 2011). (Id.). Whistleblower Lawsuit Against Fresenius Alleges Fresenius fired lawyer for reporting embezzlement, misconduct He is also a trustee and vice-Chair of the Inv Martin Flanagan's Phone Number and Email Last Update 4/3/2023 2:19 PM Contact Number (***) ***-**** Engage via Phone Mobile Number (***) ***-**** Engage via Mobile Test Drive (Id. In summary, because the new allegations concerning (1) joint-venture agreements, (2) free services to hospitals and patients, and (3) free practice-management services to physicians are not substantially similar to the allegations in the initial complaint, that portion of the complaint will be dismissed for failure to comply with the filing and service requirements of the FCA. See Kelly, 827 F.3d at 13. (Danieli, Chris) (Entered: 11/02/2021), Docket(#8) Judge Douglas P. Woodlock: ELECTRONIC ORDER FOR TRANSFER entered. Paperback. 3729(a)(1)(A) (Count 1); making or using false records material to a false or fraudulent claim in violation of the False Claims Act, 31 U.S.C. Co. Ltd., 737 F.3d 116, 123 (1st Cir. 332-75). 3730(b)(2); (2) the claims are barred by the FCA publicdisclosure bar, 31 U.S.C. As to the alleged scheme to provide other services to hospitals, the complaint alleges the following: As to the scheme to provide free or below-cost practice-management services, the complaint alleges the following: As noted, despite its length and detail, the description of the fraudulent scheme set out in the complaint, without more, is insufficient to state a claim under the False Claims Act. In substance, it is a dressed-up version of a generalized allegation: it essentially alleges that if a practice benefited financially from a relationship with FMCNA, and if it administered 104,000 treatments, and 93% of those were to patients who were beneficiaries of government-sponsored healthcare programs, then it submitted 96,720 false claims. It alleged that [t]hese problematic physician relationships generally break down into two areas. (Id.). 13). Access the Case Summary and Docket Report to access additional information about this case on the US Court's PACER system. It then provides a table of patients and patient treatments for the same facilities over the same time period. As to Medicaid, the complaint alleges in general terms that state administrators of the program obtain reimbursement from the federal government by submitting a quarterly Form 64 to the Centers for Medicare and Medicaid Services at Department of Health and Human Services. 3729 et seq., by a company that provides dialysis services to patients with kidney failure. While it is true that it did not use the term medical director agreements, its allegations concerning improper remuneration to physicians in the form of compensation above fair-market value and favorable leases are nonetheless substantially similar to those in the amended complaint. Flanagan filed the original complaint on March 6, 2014, alleging presentation of false claims in violation of the False Claims Act, 31 U.S.C. Defendant contends that the amended complaint should be dismissed for failure to comply with the pre-suit requirements of the FCA, 31 U.S.C. Rather than spend time at this point disputing and, if necessary clarifying rule language, however, I have simply consulted with the Chief Judge and under L.R. . To survive a motion to dismiss, the complaint must state a claim that is plausible on its face. Previously, Martin was a Senior Na tional Account Manager at QuickSTAT. to purchase . (Id. The qui tam provisions of the FCA permit relators, in some instances, to reap huge financial windfalls. Martin Flanagan 25) and five paragraphs addressing how the scheme resulted in false claims (Id. According to the United States Renal Data System, there were approximately 746,557 ESRD patients in the United States at the end of 2017. Flanagan In assessing whether a given later-filed suit is based upon' publicly disclosed allegations, [courts] look to whether those allegations are substantially similar' to said allegations. Cunningham, 713 F.3d at 670. (Am. A more recent docket listing 3730(d). Our Leadership Team - Fresenius Medical Care We remand for further proceedings. (Finn, Mary) (Entered: 10/05/2021). UniCourt uses cookies to improve your online experience, for more information please see our Privacy Policy. on the assumption that all the allegations in the complaint are true (even if doubtful in fact). Id. It then alleges: The complaint does not, however, identify a single specific false claim submitted in connection with any of those dialysis centers. The first was that these physicians were generally paid in excess of fair market value for the services they actually rendered. (Id.). That statute provides: The policy behind that requirement-allowing the government to investigate the claims and decide whether to intervene-is implicated when a relator amends a complaint to add completely new FCA claims. US$184.67 US$190.00. (McManus, Caetlin) (Entered: 11/22/2021), (#15) Chief Judge F. Dennis Saylor, IV: ELECTRONIC ORDER entered granting #13 Motion for Leave to Appear Pro Hac Vice Added W. Scott Simmer. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia. Moreover, the CKD complaint alleged that the scheme was nationwide. 23-7001 | 2023-01-06, U.S. District Courts | Personal Injury | 2007) (citing Rogan v. Menino, 175 F.3d 75, 77 (1st Cir. 9(b). Under the circumstances, the Court concludes that it does not. Dr. Michael D. Flanagan, MD | Bryn Mawr, PA - US News Health (Id. (CKD Compl. Why is this public record being published online? The portions of the claims based on those allegations will therefore be dismissed for failing to comply with the FCA's pre-suit requirements. Martin Flanagan Martin Flanagan - Director, Natio.. - Liberty Dialysis Rule 9(b) may be satisfied where, although some questions remain unanswered, the complaint as a whole is sufficiently particular to pass muster under the FCA. U.S. ex rel. Id. Counsel may need to link their CM/ECF account to their upgraded individual pacer account. MARTIN FLANAGAN, Plaintiff-Relator, v. FRESENIUS, Court:United States District Court, D. Massachusetts. (Id. were false.); id. 3730(b)(5); (4) the complaint has not pleaded fraud with particularity as required by Rule 9(b); and (5) the complaint fails to state a claim for FCA conspiracy. This is a qui tam action alleging violations of the Anti-Kickback Statute, 42 U.S.C. 3730(b)(2), (b)(4), (c)(1). Save US$5.33. (Woodlock, Douglas) (Entered: 11/02/2021), (#7) NOTICE of Appearance by Abraham R. George on behalf of United States of America (George, Abraham) (Entered: 10/18/2021), (#6) MOTION for Leave to Appear Pro Hac Vice for admission of James F. Bennett Filing fee: $ 100, receipt number AMADC-9005666 by Fresenius Medical Care Holdings, Inc.. (Attachments: #1 Affidavit Certification of James F. Bennett)(Durant, Maria) (Entered: 10/13/2021), (#5) MOTION for Leave to Appear Pro Hac Vice for admission of Megan S. Heinsz Filing fee: $ 100, receipt number AMADC-9005610 by Fresenius Medical Care Holdings, Inc.. (Attachments: #1 Affidavit Certification of Megan S. Heinsz)(Durant, Maria) (Entered: 10/13/2021), (#2) Case transferred in from District of Maryland; Case Number 14-cv-00665-GLR. And it means that relator stands to reap a reward of 15%-30% of any recovery-an amount that might well be measured in tens of billions of dollars. (Id. Physicians who wanted to terminate the non-competition agreements were forced to negotiate onerous buyouts. Phone: 1.619.238.4720 Email: inquiries@hoguebelonglaw.com Home Home Gonzales et al. The original complaint referred to joint-venture agreements between FMCNA and physicians, but only in order to contrast such agreements (which it referred to as a product of arms-length negotiations) with the higher compensation paid to medical directors in the absence of such agreements. (McManus, Caetlin) (Entered: 11/22/2021), (#17) MOTION for Leave to Appear Pro Hac Vice for admission of Noah M. Rich Filing fee: $ 100, receipt number AMADC-9065658 by Martin Flanagan.
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