CONSENT TO DISMISSAL; [PROPOSED] ORDER

FILED UNDER SEAL

ELIZABETH D. LAPORTE, Magistrate Judge.

Pursuant to 31 U.S.C. § 3730(b)(1), the United States consents to the dismissal of this action without prejudice to the United States. The United States has conferred with Steve Block, Deputy Attorney General for the State of California. Mr. Block has represented to the United States that the State of California also consents to dismissal of this action without prejudice.

The United States requests that the Court unseal: (1) Relator's Complaint; (2) the summons, if any; (3) the scheduling order; (4) Relator's Notice of Dismissal; and (5) this Consent to Dismissal and Proposed Order. The United States requests that all other contents of the Court's file in this matter (including, but not limited to, any applications filed by the United States for extensions of the sixty-day investigative period, any applications for partial lifting of the seal, and any orders previously entered in this matter) remain under seal and not be made public or served upon defendants. The United States and the State of California do not object to Relator's request to keep the action under seal until September 30, 2015.

A proposed order accompanies this notice.

[PROPOSED] ORDER TO UNSEAL

The United States and the State of California having consented to dismissal of this action without prejudice pursuant to the False Claims Act, 31 U.S.C. § 3730(b)(1), IT IS HEREBY ORDERED that:

1. The Complaint, the summons, the scheduling order, Relator's Notice of Dismissal, this Order, ind the accompanying Consent to Dismissal are hereby unsealed.

2. Any applications and/or declarations that have been filed under seal by the United States for in extension of the sixty-day investigative period or for any other reason shall remain under seal and not 3e made public or served upon the defendants.

3. The seal shall be lifted as to all other matters occurring in this action after the date of this Order.

IT IS SO ORDERED.