United States of America, et al. ex rel. Everest Principals, LLC v. Abbott Laboratories, et al.

District Court, S.D. California·Decided January 12, 2026·No. 3:20-cv-00286·Unknown

Opinion

UNITED STATES OF AMERICA, et al. ex rel. Case No.: 20cv286-W (MSB) Everest Principals, LLC, ORDER DENYING DEFENDANTS’ Plaintiffs, v. [ECF NO. 224] ABBOTT LABORATORIES, et al., Defendants. This is a qui tam case, wherein Plaintiff-Relator, Everest Principals, LLC (“Relator”) maintains causes of action against Defendants Abbott Laboratories, Abbott Laboratories Inc., Abbott Cardiovascular Systems Inc., and Abbott Vascular Inc. (collectively referred to as “Defendants” or “Abbott”) on behalf of the United States of America and several states for violations of the federal False Claims Act (“FCA”) and analogous state laws. (ECF No. 85 at 6.) Relator is a limited liability company whose sole member was employed by Defendants as a Therapy Development Specialist in its Structural Heart Division from August 2015 to April 2017. (Id. at 7.) Defendants are involved in the manufacturing and sale of medical devices, instruments, medications, and other health care products. (Id. at 8.) Rebuttal. (ECF No. 224, hereinafter “Motion to Strike.”) After reviewing letter briefs lodged by the parties, the Court held Telephonic Discovery Conferences on October 6, 2025, and October 14, 2025, to address various issues pertaining to expert reports. (ECF Nos. 216 & 219.) Following the conference, the parties jointly requested an opportunity for formal briefing as to the Court’s tentative order striking the entire August 29, 2025, report of Relator’s expert Dr. David Healy (“Healy Report”). (ECF No. 221.) For the reasons outlined below, the Court DENIES Defendants’ Motion to Strike. A. Defendants’ Motion to Strike In short, Defendants argue the Healy Report should be stricken because it improperly discloses affirmative expert opinions disguised as rebuttal opinions. (ECF No. 224-1 at 2.) On August 29, 2025, the rebuttal report deadline, Relator disclosed Dr. Healy for the first time. (Id.) The Healy Report contains two overarching opinions: (1) “Abbott’s Therapy Awareness Programs lacked many of the qualities necessary to meet an educational objective consistent with prevailing standards;” and (2) “Abbott’s Therapy Awareness Programs . . . [were] inconsistent with accepted educational standards” in other respects too. (Id. at 3 (citing Healy Report ¶¶ 14–15).) Defendants contend that “none of Abbott’s opening reports contained any opinions whatsoever on the subjects that Dr. Healy references.” (Id.) Moreover, Defendants argue that Dr. Healy makes “textbook affirmative expert opinions that should have been disclosed, if at all, by the June 30 [affirmative expert] deadline.” (Id. at 5.) Defendants dispute Relator’s contention that Dr. Healy’s opinions are based on the same subject matter as Defendants’ expert reports. (Id. at 5–6.) Instead, Defendants assert that Abbott’s experts “opined that education was necessary and explained why—not whether Abbott’s provision of education was or was not

appropriate as judged against the so-called ‘standards of medical education.’” (Id. Dr. Anupam Jena—Defendants argue “none of those references contradict or rebut evidence on the same subject matter identified in Abbott’s reports,” in violation of Rule 26(a)(2)(D)(ii). (Id. at 6–8.) Finally, Defendants contend striking the Healy Report is the proper remedy because Relator cannot establish substantial justification or harmlessness. (Id. at 9 (citing Yeti by Molly, Ltd. v. Deckers Outdoor Corp., 259 F.3d 1101, 1106 (9th Cir. 2001).) By disclosing Dr. Healy’s opinion on August 29 rather than June 30, Defendants contend “Relator deprived Abbott of the opportunity to rebut [the opinions].” (Id.) Further, Defendants claim Relator’s late disclosure harmed Defendants by forcing them to divert attention from expert depositions and dispositive motions and incur additional attorneys’ fees. (Id. at 10.) B. Relator’s Opposition In response, Relator argues the Healy Report is proper rebuttal testimony and Defendants’ Motion to Strike should be denied. (ECF No. 225 at 2.) Relator alleges that Defendants “seek[] an impermissibly narrow standard of what constitutes proper rebuttal that prevents a rebuttal expert from challenging affirmative experts’ underlying assumptions and methodology and presenting facts and data that they failed to consider altogether.” (Id.) Further, Relator maintains that accepting Defendants’ position “would turn the very purpose of rebuttal testimony on its head.” (Id.) More specifically, Relator argues that the Healy Report contains proper rebuttal testimony because it (1) addresses the same subject matter as Defendants’ affirmative experts’ reports—namely, the purported medical education need and fulfillment of such need by Abbott’s events—and (2) is intended solely to rebut Defendants’ affirmative experts’ reports. (Id. at 4–5.) On June 30, 2025, Relator contends five of Defendants’ medical experts offered affirmative opinions “on the supposed need for physician education on the MitraClip and whether Abbott’s events were conducted in a manner to

meet that need.” (Id. at 5, 6–9.) Relator argues it served the Healy Report on August Report is offered to show Defendants’ experts “consistently overlooked established principles of professional learning, substituting personal impressions or anecdotal experience for evidence-based evaluation.” (Id. at 10–11 (citing Healy Report ¶¶ 62– 63).) Furthermore, Dr. Healy’s Report shows that “Abbott’s events ‘deviated substantially from the standards of legitimate medical education.’ ” (Id. at 11 (citing Healy Report ¶¶ 62–63).) Even if the Court finds any of Dr. Healy’s opinions were improper rebuttal, Relator argues the Healy Report was served before the discovery cutoff, Dr. Healy’s deposition, and the final pretrial conference. (Id. at 11.) Thus, there is time to cure any possible prejudice, and the appropriate relief would be to permit Defendants to take Dr. Healy’s deposition and serve a rebuttal report in response to the Healy Report. (Id.) Federal Rule of Civil Procedure 26 governs the disclosure of expert testimony. “Unless otherwise stipulated or ordered by the court, this disclosure must be accompanied by a written report—prepared and signed by the witness . . . .” Fed. R. Civ. P. 26(a)(2)(B). The report must contain a “complete statement of all opinions the witness will express and the basis and reasons for them,” as well as “the facts or data considered by the witness in forming them.” Fed. R. Civ. P. 26(a)(2)(B)(i)–(ii). Additionally, the report must include the witness’s qualifications and “a statement of the compensation to be paid for the study and testimony in the case.” Fed. R. Civ. P. 26(a)(2)(B)(iv), (vi). “A party must make these disclosures at the times and in the sequence that the court orders.” Fed. R. Civ. P. 26(a)(2)(D). “A party need not disclose an expert within the deadline for initial expert reports, and can instead disclose an expert as a ‘rebuttal expert,’ when the expert’s testimony is ‘intended solely to contradict or rebut evidence on the same subject matter identified

Free access — add to your briefcase to read the full text and ask questions with AI

United States of America, et al. ex rel. Everest Principals, LLC v. Abbott Laboratories, et al., (S.D. Cal. 2026).

United States of America, et al. ex rel. Everest Principals, LLC v. Abbott Laboratories, et al. (United States of America, et al. ex rel. Everest Principals, LLC v. Abbott Laboratories, et al.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Laro v. New Hampshire
259 F.3d 1 (First Circuit, 2001)
Goodman v. Staples the Office Super-Store, LLC
644 F.3d 817 (Ninth Circuit, 2011)
California v. Kinder Morgan Energy Partners, L.P.
159 F. Supp. 3d 1182 (S.D. California, 2016)
San Diego County Credit Union v. Cefcu
65 F.4th 1012 (Ninth Circuit, 2023)