`**E-FILED**
`18EV005732
`12/18/2019 5:03 PM
`
`LeNora Ponzo, Clerk
`Civil Division
`
`IN THE STATE COURT OF FULTON COUNTY
`
`STATE OF GEORGIA
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`DC MEDICAL MARKETING, LLC and
`its successor-in—interest LIBERTY
`
`WELLNESS SERVICES, LLC,
`
`Plaintiffs,
`
`V.
`
`DUNWOODY LABS, INC., and
`
`GEZ AGOLLI,
`Defendants.
`
`vvvvvvvvvvv
`
`CIVIL ACTION FILE
`
`NO.
`
`l8—EV—005732—E
`
`CONSENT ORDER ON PLAINTIFFS’ MOTION FOR SANCTIONS
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`Plaintiffs DC Medical Marketing, LLC, and its successor-in-interest, Liberty Wellness
`
`Services, LLC; as well as Defendants Dunwoody Labs, Inc., and Gez Agolli have submitted a
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`Consent Agreement on Plaintiffs’ Motion for Sanctions (filed November 4, 2019). The above—
`
`named Parties have jointly agreed:
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`1. Defendant Dunwoody Labs, Inc. shall supplement their document production to Plaintiffs
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`no later than January 15, 2019. This shall include, but not be limited to, all documents
`
`requested in Plaintiffs’ First Requests for Production of Documents, to be produced in
`
`their native file format.
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`2. The parties have also agreed Defendant Dunwoody Labs, Inc. shall produce the following
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`documents to Plaintiffs by January 15, 2019:
`
`a.
`
`all Explanation of Benefits (“EOBs”) for any patients or specimens that were
`
`provided and/or referred to Dunwoody Labs, Inc. by Plaintiffs;
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`b. any and all documents or correspondence reflecting any billing performed for any
`
`patients or specimens that were provided and/or referred to Dunwoody Labs, Inc.
`
`by Plaintiffs;
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`[Continued on Next Page]
`
`
`
`c.
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`any documents reflecting the identity of all billing staff who worked for
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`Dunwoody Labs, Inc. from the time period during which Plaintiffs provided
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`and/or referred any patients or specimens to Dunwoody Labs, Inc.; and
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`d. any and all bank statements or other such records that reflect any payments
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`(incoming or outgoing) to Dunwoody Labs, Inc. for any patients or specimens
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`provided and/or referred to Dunwoody Labs, Inc. by Plaintiffs.
`
`3. Defendant Dunwoody Labs,
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`Inc. shall produce a 30(b)(6) witness to continue its
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`deposition if requested by the Plaintiffs no later than February 28, 2020.
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`4. Defendant Gez Agolli shall be present for a deposition if requested by the Plaintiffs no
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`later than March 31, 2020, and Plaintiffs may depose additional witnesses by such date.
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`5. The Rule Nisi hearing scheduled for December 20, 2019, to hear the Plaintiffs’ Motion
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`for Sanctions is hereby continued until further order of the Court.
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`All parties must confer and submit a Proposed Joint Confidentiality Order protecting
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`patient confidentiality no later than December 30, 2019.
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`SO ORDERED, this 18th day of December, 2019.
`
` I
`
`@ Jane Morrison
`a e Court of Fulton County
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`Copies to counsel and pro se parties via E—File Georgia and/or First Class Mail.
`
`
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