Life Star Pharmacy v. Express Scripts, Inc.

District Court, E.D. Missouri·Decided March 24, 2025·No. 4:23-cv-00186·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

LIFE STAR PHARMACY, INC., ) doing business as, ) LIFE STAR PHARMACY, ) ) Plaintiff, ) ) v. ) Case No. 4:23CV186 JAR ) EXPRESS SCRIPTS, INC., ) ) Defendant. )

MEMORANDUM AND ORDER This matter is before the Court on Defendant’s motion to compel discovery [ECF No. 50], motion for hearing [ECF No. 54], and motion for leave to file under seal [ECF No. 52]. These motions are fully briefed and ready for disposition. I. Background and Facts Plaintiff Life Star Pharmacy, Inc. (“Life Star”) was a member of Defendant Express Scripts, Inc.’s (“Express Scripts”) pharmacy provider network from March 2018 until August 19, 2022, when Express Scripts terminated its contract with Life Star. The termination occurred after a fraud, waste, and abuse investigation, which Express Scripts initiated on March 23, 2022. As part of that investigation, Express Scripts requested that Life Star “provide a summary of all purchases, returns, and credits from November 16, 2020, through March 8, 2022, along with a photocopy of the prescription(s) enclosed in the letter, prescriber information, receipt of copayment, and the appropriate signature/shipping log entries.” ECF No. 56-8 at 97. After issuing its findings of insufficient proof of Life Star’s copayment collection or use of improper means to charge off patient copayments for 11 prescription drug claims, Express Scripts terminated its contract with Life Star. The provider manual required Life Star to “collect the full Copayment from Members, and that the Copayment is not changed or waived unless required by law.” ECF 53-2 at 3. The provider manual also stated that “[f]ailure to collect the Member Copayment is … a material breach of Network Provider’s obligations and may result in immediate termination.” Id. Life Star maintains that before it received notice of the termination, it had already submitted comprehensive documentation that resolved the alleged discrepancies.

ECF No. 23 at 14. Further, Life Star claims that Express Scripts acted in bad faith by unreasonably refusing to consider Life Star’s submissions. Id. at 15. On February 16, 2023, Life Star filed this action against Express Scripts, alleging three breach of contract claims (Counts One-Three), breach of the implied covenant of good faith and fair dealing (Count Four), and breach of New York Public Health Law § 280-a (Count Five). Life Star twice amended its Complaint. Express Scripts has asserted affirmative defenses. Express Scripts filed a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6) requesting the Court to dismiss Counts Three and Five of Life Star’s Second Amended Complaint. On March 4, 2024, the Court issued an Order granting Express Scripts’ motion and

dismissing Counts Three and Five of Life Star’s Second Amended Complaint with prejudice. ECF No. 39. Life Star then filed a motion requesting that the Court reconsider its Order dismissing Count Three and reinstate that claim. In the alternative, Life Star requested that the Court amend its Order to reflect that Count Three is dismissed without prejudice and allow Life Star an opportunity to amend its Complaint once again. The Court issued an Order granting Life Star’s motion to a limited extent to reflect that Counts Three and Five of the Second Amended Complaint are dismissed without prejudice and denying Life Star’s motion for reinstatement of Count Three and to amend its Second Amended Complaint. ECF No. 71. In its operative Second Amended Complaint, Life Star challenges Express Scripts’ termination. Life Star seeks declaratory relief and injunctive relief that would require Express Scripts to readmit Life Star into its pharmacy provider network. Life Star also seeks monetary damages, including an award of any and all amounts that were erroneously recouped and withheld from Life Star due to Express Scripts’ investigation, and compensatory and/or consequential damages, including lost profits or savings, injury to reputation, loss of customers and/or business resulting from Express Scripts’ termination.

Following the Rule 16 Conference and the issuance of the Case Management Order, Express Scripts served 46 Requests for Production on March 15, 2024. Life Star provided written responses and objections on April 15, 2024, and has amended its responses multiple times. The parties’ counsel met and conferred on May 15, 2024 and have shared subsequent email communications to discuss alleged deficiencies and discuss potential resolutions, but the parties were unable to see eye to eye. On June 21, 2024, Express Scripts filed a motion to compel discovery, a motion for hearing, and a motion for leave to file under seal. Life Star filed a memorandum in opposition to the motion to compel discovery, to which Express Scripts filed a reply. Life Star did not file any

opposition to the motion for hearing or the motion for leave to file under seal. II. Defendant’s Motion to Compel Discovery A. Standard Under Federal Rule of Civil Procedure 26(b)(1), “[p]arties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.” Fed.R.Civ.P. 26(b)(1). “Upon a showing by the requesting party that the discovery is relevant, the burden is on the party resisting discovery to explain why discovery should be limited.” CitiMortgage, Inc. v. Allied Mortg. Group, Inc., No. 4:10-CV-1863-JAR, 2012 WL 1554908, at *2 (E.D. Mo. May 1, 2012). “Bare assertions that the discovery requested is overly broad, unduly burdensome, oppressive, or irrelevant are ordinarily insufficient to bar production.” Natoli v. Kelley, No. 4:20-CV-01242- AGF, 2022 WL 2700312, at *1 (E.D. Mo. July 12, 2022).

B. Disputed Discovery Requests Express Scripts’ motion to compel discovery concerns thirteen Requests for Production (“RFPs”). Four RFPs (Nos. 31-34) seek Life Star’s copayment collection data, documents, and other information such as Life Star’s use of a house account to charge copayments. Another three RFPs (Nos. 28-30) seek documents and communications concerning Life Star’s owner Jose Solano’s statements during Express Scripts’ fraud, waste, and abuse investigation. The final six RFPs (Nos. 35-40) at issue in this motion seek documents related to Life Star’s claimed damages. All thirteen RFPs seek information from the start of the parties’ contractual relationship in March 2018 to the present.

1. Copayment collection information Express Scripts’ RFPs sent to Life Star that relate to copayment collection information include the following: RFP No. 31: Documents and Communications during the Relevant Time Period reflecting whether or not You collected the copayment due to You for any prescription You dispensed, provided, or sold to any Express Scripts member, including the date any copayment was due and the date any copayment was collected. By way of example only, this Request includes Documents such as invoices, bills, receipts, correspondence, patient statements, or account balances, as well as electronically stored information, such as Structured Data and Unstructured Data, that would reflect whether or not such copayments were collected and, if they were collected (in whole or in part), when they were collected.

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Life Star Pharmacy v. Express Scripts, Inc., (E.D. Mo. 2025).

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