Sixth Circuit -- Richard Chesbrough v. VPA, P.C.

Richard Chesbrough v. VPA, P.C.

   Dismissal of qui tam suit under False Claims Act for insufficient particularity in pleading fraud under 9(b).

No implicit warrant that studies and reports submitted for reimbursement aren't substandard - no regs specifically ban it.

If realtor can establish that any of the reports were completely non diagnostic - totally worthless - qui tam claim would lie, but here, plaintiffs have not established that any were actually submitted.  Lax 9(a) should not apply to this situation.

No obligaiton under federal law for corporation to adhere to state rules.

Although 37(a)2(9) does not require presentment, it does require a showing that deft somehow ultimately prompted a presentment.