United States of America, ex rel. et al v. Mayo Clinic Ambulance

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
United States of America and State of
Minnesota ex rel. Ashley Mothershed,
Plaintiff-Relator,
v.
Mayo Clinic Ambulance,
Defendant.
Case No. 22-cv-602 (DWF/JFD)
ORDER
This matter is before the Court on Plaintiff-Relator Ashley Mothershed’s Motion to
Compel Defendant Mayo Clinic Ambulance to produce discovery (Dkt. No. 106). The
Court heard the motion on August 20, 2025. Grace Chanin and Rebekah Bailey, Esqs.,
appeared on behalf of Plaintiff-Relator Ashley Mothershed. Manda Sertich and Rachel
Dougherty, Esqs., appeared on behalf of Mayo Clinic Ambulance. As set forth fully below,
the Court grants the motion in part and denies it in part.
I. 	Background
Ms. Mothershed worked for Mayo Clinic Ambulance (“Mayo”) in its billing
department from about November 2020 through June 2021 and from about September 2021
through May 2022. She initiated this qui tam action after learning that Mayo was
submitting allegedly false claims to government healthcare payors, in violation of the
federal and Minnesota False Claims Acts. In her Second Amended Complaint (“SAC”),
which is the operative pleading, Ms. Mothershed alleged that Mayo engaged in three
schemes: (1) billing for medically unnecessary ambulance transports, (2) upcoding non-
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emergency ambulance transports to emergency transports, and (3) upcoding basic life
support (“BLS”) ambulance services to advanced life support (“ALS”) services. (See SAC
¶ 2, Dkt. No. 72; Order at 3, Jan. 24, 2025, Dkt. No. 91 (“Dismissal Order”).) The
Honorable Donovan W. Frank, United States District Judge, dismissed the medical-
necessity theory on Mayo’s motion. (Dismissal Order at 18.) The two upcoding theories
remain in the case.
The case is now in the discovery phase. Giving rise to the present motion is the
parties’ disagreement about discovery’s temporal and substantive scope. As to the temporal
scope, Ms. Mothershed argues she is entitled to discovery for the entire 10-year statute-of-
limitations period, beginning on March 8, 2012, through the present. Mayo seeks to limit
discovery to November 2020 to May 2022. As to the substantive scope of claims, Ms.
Mothershed argues that discovery should not be limited to the specific examples of
improper billing described in the SAC; rather, discovery should encompass all upcoding
of non-emergency transports to emergency transports and all upcoding of BLS services to
ALS services. Mayo disagrees and asks the Court to limit substantive discovery to the
specific types of schemes described in the SAC. Also at issue in the motion to compel are
documents responsive to Request for Production No. 23, which asks for documents
concerning 	Mayo’s 	investigations 	into 	any 	of 	Ms. 	Mothershed’s 	complaints 	about
improper billing, not just the billing practices alleged here.
II. 	Legal Standards
Federal Rule of Civil Procedure 26(b)(1) defines the scope of discovery. “Parties
may obtain discovery regarding any nonprivileged matter that is relevant to any party’s
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claim or defense and proportional to the needs of the case.” Fed. R. Civ. P. 26(b)(1). In
determining 	proportionality, 	courts 	may 	consider 	several 	factors, 	including 	“the
importance of the issues at stake in the action, the amount in controversy, the parties’
relative access to the 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.” Id.
If a party believes that the opposing party has failed to respond to discovery or
served insufficient responses, it may “move for an order compelling disclosure or
discovery.” Fed. R. Civ. P. 37(a)(1). The moving party must make a threshold showing of
relevance. Sherman v. Sheffield Fin., LLC, 338 F.R.D. 247, 252 (D. Minn. 2021). Once
relevance is shown, then the burden shifts to the opposing party to show that the discovery
is not relevant or is unduly burdensome. Patterson Dental Supply, Inc. v. Pace, No. 19-
CV-1940 (JNE/LIB), 2020 WL 10223625, at *20 (D. Minn. June 17, 2020); St. Paul
Reinsurance Co., Ltd. v. Com. Fin. Corp., 198 F.R.D. 508, 511 (N.D. Iowa 2000).
III. 	Discussion
A. 	Temporal Scope
Ms. Mothershed argues that she is entitled to discovery from the entire statute-of-
limitations period, from March 8, 2012 (10 years before the case was filed) through the
present. (Pl.-Relator’s Mem. Supp. Mot. Compel at 8 (citing 31 U.S.C. § 3731(b)(2)), Dkt.
No. 122-2.1) Consistent with this timeline, her written discovery requests identified “March
1 Ms. Mothershed requested and received permission to file a corrected memorandum in
support of her motion, and the corrected memorandum is located at Dkt. No. 122-2.
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8, 2012 through the present and continuing” as the default time period for discovery. (E.g.,
Chanin Decl. Ex. 3 at 1, Dkt. No. 109-3.) This proposed timeframe would make the
temporal scope of discovery more than 13 years. Mayo objects to this timeframe on the
grounds of relevance and burden, among others.
The legal authority on temporal scope provided by Ms. Mothershed is of limited
value because many of the cases do not involve claims brought under the False Claims Act
(“FCA”). E.g., Deering v. Lockheed Martin Corp., No. 20-CV-1534 (DSD/BRT), 2021
WL 1440182, at *2 (D. Minn. Apr. 16, 2021) (employment discrimination claims);
Johnson v. Charps Welding & Fabricating, Inc., No. 14-CV-2081 (RHK/LIB), 2015 WL
13883903, at *6 (D. Minn. May 14, 2015) (joint venture and alter ego claims); Dryer v.
Nat’l Football League, No. 09-CV-2182 (PAM/SRN), 2010 WL 11469574, at *1 (D.
Minn. Oct. 25, 2010) (false advertising, right of publicity, and unjust enrichment claims);
Doe I v. Mulcahy, Inc., No. 08-CV-306 (DWF/SRN), 2008 WL 11463252, at *1 (D. Minn.
Nov. 6, 2008) (race discrimination, national origin discrimination, and retaliation claims).
This matters for several reasons. First, the nature of an FCA action provides context
for relevance and proportionality. “The qui tam provisions of the FCA . . . authorize private
citizens (called relators) to sue on behalf of the government and, as a bounty, share in any
recovery.” United States ex rel. Newell v. City of St. Paul, 728 F.3d 791, 794 (8th Cir.
2013). A “continuing conundrum in qui tam cases” is determining how wide a relator’s
insider knowledge should open the door to discovery, while preventing a “roving
commission” into the defendant’s billing practices. United States ex rel. Grandeau v.
Cancer Treatment Ctrs. of Am., No. 99-C-8287, 2003 WL 21504998, at *2 (N.D. Ill. June
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30, 2003). In setting the temporal scope of discovery, courts should be mindful not to
dissuade whistleblowing by, for example, limiting discovery to the relator’s duration of
employment, see Fiederer v. Healing Hearts Home Care, Inc., No. 2:13-CV-1848-APG-
VCF, 2014 WL 4666531, at *5 (D. Nev. Sept. 18, 2014), but must nonetheless guard
against broad inquiries into other time periods that do not “hew closely to matters
specifically described in the complaint,” United States ex rel. Dicken v. Northwest Eye
Clinic, P.A., No. 13-CV-2691 (JNE/KMM), 2018 WL 2980394, at *2 (D. Minn. June 14,
2018) (quotation omitted). A complaint’s cursory or superficial references to ongoing or
systemic fraud do not warrant discovery of fraudulent claims for an extended period.
United States ex rel. Spay v. CVS Caremark Corp., No. 09-CV-4672, 2013 WL 4525226,
at *2–4 (E.D. Pa. Aug. 27, 2013) (declining plaintiff’s request for seven years of discovery
as a “fishing expedition” and limiting discovery period to two years).
Second, the statutes of limitations and relevant time periods in the non-FCA cases
cited by Ms. Mothershed were significantly shorter than the 10-year statute of limitations
and 13 years of discovery proposed here. E.g., Deering, 2021 WL 1440182, at *2 (setting
a 7-year discovery period2); Johnson, 2015 WL 13883903, at *6 (setting a 6-year discovery
period based on a potential 6-year statute of limitations); Dryer, 2010 WL 11469574, at *3
(limiting discovery to the 6-year statute-of-limitations period); Doe I, 2008 WL 11463252,
at *1 (limiting discovery to the 4-year statute-of-limitations period). It stands to reason that
2 The Court estimated a seven-year discovery period between the start date of January 1,
2014, and “the date of service of the document requests,” which had to predate April 16,
2021, the date of the court’s order. See Deering, 2021 WL 1440182, at *2–3.
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the longer the requested timeframe, the greater the burden to show relevance and
proportionality.
Third, Ms. Mothershed’s authority does not hold that the time period for discovery
is necessarily the same as the statute-of-limitations period. To the contrary, “while a statute
of limitations can be a helpful point of reference,” the party seeking the information must
show it is “relevant and proportional.” Deering, 2021 WL 1440182, at *2.
To meet her burden to show relevance and proportionality, Ms. Mothershed relies
on several allegations in the SAC. One such allegation is made on paragraph 146:
146. 	[Mayo employee Tessa] Leutink talked to Relator on a Skype phone
call around September 2021, when Relator returned to work at Mayo Clinic
Ambulance. Leutink told Relator that she went to a seminar over ten years
ago about ambulance billing and realized that the manner in which Fennell [3]
trained Mayo’s billing department to bill constituted false billing. Leutink
told Relator that she raised these concerns with her supervisors at the time,
who told her she was wrong and overruled her concerns, similar to what had
happened to Relator.
(Pl.-Relator’s Mem. at 10; SAC ¶ 146) (emphasis added). After the motion to compel was
fully briefed, however, Ms. Mothershed clarified to Mayo that the conversation described
in paragraph 146 pertained only to the dismissed medical-necessity theory. (Mayo Ltr. at
2, Dkt. No. 118; Ex. A at 11, Dkt. No. 118-1.) At the motion hearing, Ms. Mothershed’s
counsel explained that the conversation was also about billing practices generally—not just
medical necessity. Counsel did not represent, however, that the conversation covered
Mayo’s ALS or emergency upcoding practices. Thus, the Court finds that the allegations
3 Thomas Fennell is identified in ¶ 59 of the SAC as Mayo’s Regulatory Officer.
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of paragraph 146, as clarified by Ms. Mothershed, are insufficient to establish relevance
for discovery going back to 2012 on the surviving upcoding theories.
Ms. Mothershed also relies on paragraph 6 of the SAC, which alleges that the
“relevant period” is “defined as the ten years prior to the filing of this lawsuit”; and
paragraphs 43 and 120, which allege a timeframe “beginning as early as 2015 (and perhaps
earlier) and continuing until at least 2022.” (Pl.-Relator’s Mem. at 10; SAC ¶¶ 6, 43, 120.)
There are no allegations, however, as to specific services, practices, or billing activities that
correspond with the years 2012 or 2015 (or, indeed, any year other than 2020, 2021, and
2022). In other words, there is no factual basis alleged in the SAC to support the conclusion
that fraudulent activity had been going on since 2012 or 2015. “[R]ote allegations of
‘ongoing’ 	illegal 	activity, 	unaccompanied 	by 	allegations 	of 	specific 	instances 	of
wrongdoing, are insufficient to justify discovery beyond the time period during which
specific instances of wrongdoing have been alleged.” United States ex rel. Bilotta v.
Novartis Pharms. Corp., No. 11-CV-0071 (PGG), 2015 WL 13649823, at *3 (S.D.N.Y.
July 29, 2015) (citing cases); cf. Dicken, 2018 WL 2980394, at *2 (limiting discovery to a
seven-year period from 2007 to 2014 where the complaint alleged dozens of examples of
fraud between 2002 and 2014).
In the memorandum filed in support of her motion, Ms. Mothershed explains that
she used data to support an extension of the relevant timeframe back to 2015, or earlier,
and she directs the Court to paragraphs 56 and 123 of the SAC for the relevant allegations.
(Pl.-Relator’s Mem. at 10.) Paragraph 56 alleges the percentage of time Mayo billed
ambulance transports as emergency (95.72%) or non-emergency (4.28%) for the timespan
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of 2013 to 2022. (SAC ¶ 56.) The SAC then compares Mayo’s numbers with Fairview
Health Services (30% emergency transports) and Ohio Ambulance Solutions (34% non-
emergency transports) and posits that the disparities “evidence[] Mayo’s practice of
routinely upcoding non-emergency transports and billing them as emergency.” (SAC
¶¶ 57–58.) The Court cannot agree; that conclusion is too speculative. There could be any
number of reasons for the billing disparities between Mayo and the two other ambulance
services. Simply because Mayo billed ambulance transports as emergency more—even
much more—than two other companies over a nine-year period does not mean Mayo must
have engaged in fraudulent billing practices dating back to 2013. Further detracting from
the relevance of paragraph 56, the data in paragraph 56 is not broken down by year but is
presented as a single nine-year block, from 2013 to 2022. The Court cannot identify from
that nine-year timespan the data for any given year, were the Court inclined to set a start
date for discovery based on the data. In sum, paragraph 56 does not open the door to
discovery dating back to 2012, 2013, 2015, or any other year.
Paragraph 123 of the SAC alleges that publicly available claims data for 2013–2022
reveals that Mayo bills 60% of its ambulance transports as ALS. (SAC ¶ 123.) The next
paragraph conclusorily alleges that “Mayo routinely billed using ALS codes for ambulance
transports that should have been billed as BLS.” (SAC ¶ 124.) The SAC includes two
examples of the alleged ALS billing practice occurring in 2021 (SAC ¶¶ 126–27), but there
are no well-pleaded allegations dating back to 2012, 2013, or even 2015. The Court finds
that paragraph 123 also does not warrant discovery dating back to any particular year other
than 2021.
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The last set of paragraphs identified by Ms. Mothershed as supporting the relevance
and proportionality of a 13-year timeframe describes Mayo’s “systemic” practices that,
according to her, likely did not begin on the day she started working at Mayo. (Pl.-Relator’s
Mem. at 10 (citing SAC ¶¶ 2, 4, 6, 40, 41, 43, 146, 162, 163).) These paragraphs do not
contain detailed factual matter sufficient to create a plausible allegation of fraudulent
activity dating back to 2012, however. Cf. Dalitz v. AmSurg Corp., No. 2:12-CV-2218-
TLN-CKD, 2015 WL 8717398, at *4 (E.D. Cal. Dec. 15, 2015) (where detailed, specific
allegations showed that the alleged fraudulent practices occurred before and after relator’s
employment, allowing discovery for a four-year period); Fiederer, 2014 WL 4666531, at
*6 (where relator’s “detailed allegations regarding . . . training and unwritten policies and
procedures to alter patient records provide[d] a plausible allegation that the alleged illicit
activity occurred in the past,” allowing a six-year period for discovery). Cursory or
superficial references to ongoing or systemic fraud do not warrant discovery of fraudulent
claims for an extended period. Spay, 2013 WL 4525226, at *2–4; Bilotta, 2015 WL
13649823, at *3.
Nonetheless, Ms. Mothershed’s position that, if there were fraud, it likely did not
begin on the day she started working at Mayo is well-taken. Therefore, the Court will
exercise its discretion and set the beginning of the relevant time period as November 1,
2018—two years before Ms. Mothershed began her employment at Mayo. If the discovery
produced by Mayo indicates that fraudulent billing practices existed before November 1,
2018, Plaintiff may move the Court to expand the temporal scope of discovery.
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The Court sets the end date for discovery as the date the original complaint was
filed: March 8, 2022. The same considerations have applied in choosing this date. Ms.
Mothershed has not identified well-pleaded allegations in the SAC from which the Court
could conclude that fraudulent billing practices have continued to the present date. On the
other hand, if fraud did occur, it probably did not stop on the date her employment ended.
Without a specific allegation about when the disputed billing practices ended, setting the
upper temporal limit for discovery as the date the initial complaint was filed is appropriate.
See, e.g., United States ex rel. Sirls v. Kindred Healthcare, Inc., No. 16-0683-KSM, 2024
WL 4438246, at *8 (E.D. Pa. Oct. 7, 2024).
B. 	Substantive Scope
Ms. Mothershed’s written discovery requests defined the subject matter of the case
as “the factual allegations made in the Second Amended Complaint, or any subsequent
amendments, Defendant’s answer, as well as facts and events reasonably related to the
allegations or defenses in this case.” (E.g., Chanin Decl. Ex. 1 at 4, Dkt. No. 109-1.) Mayo
objected to the discovery requests to the extent their substantive scope exceeded the claims
surviving the motion to dismiss and stated it would produce only documents that related to
the upcoding claims.
The question is how broadly or narrowly to construe the alleged upcoding schemes.
Mayo construes the schemes narrowly, using language from the representative examples
alleged in the SAC. Mayo proposes to limit the emergency upcoding scheme only to
situations when a patient was transferred from one hospital to another. Plaintiff, on the
other hand, contends the emergency upcoding claim covers all upcoded emergency claims,
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not just hospital-to-hospital transports. Mayo proposes to limit the ALS upcoding scheme
only to situations when the ALS assessment was performed by an EMT-Basic, instead of by
a paramedic,4 and no separate ALS intervention was performed. Plaintiff, by contrast,
describes her ALS upcoding claim as covering any time an ALS assessment or intervention
was not performed.
The Court first addresses the alleged scheme of upcoding non-emergency transports
to emergency, looking to the allegations in the SAC for guidance in determining relevance
and proportionality. There is no question that the allegations focus on hospital-to-hospital
transports. (E.g., SAC ¶¶ 47, 50–52, 65–67). Judge Frank said as much in the Dismissal
Order (Dismissal Order at 7), and all three representative examples in the SAC involved
hospital-to-hospital transfers (SAC ¶¶ 65–67). Ms. Mothershed also alleges, however, that
based on her knowledge and experience, Mayo coded ambulance transports as emergent
“even when transports were scheduled in advance, were not provided in immediate
response to a 911 call or equivalent, and/or did not begin as quickly as possible.” (SAC
¶ 53.) A specific example of the latter is described in paragraph 155: “[T]he requested
pickup time was changed multiple times, so ambulance crews could handle higher priority
transports, that the pickup did not occur until 2.5 hours later, and the patient was transported
straight to a room for a non-emergency admission, rather than going to the emergency
room.” (SAC ¶ 155.) Ms. Mothershed further alleges that she witnessed firsthand in emails
4 Only individuals trained as emergency medical technicians (“EMT”) at the Intermediate
and Paramedic levels can be ALS personnel. 42 C.F.R. § 414.605. Individuals trained at
the Basic level can provide only BLS ambulance services. Id.
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and weekly meetings “Mayo’s Regulatory Officer Tom Fennell direct[ing] Mayo’s billing
department to classify almost every transport as emergency, even when many transports
did not meet the criteria for an emergency Code.” (SAC ¶ 59.) The SAC alleges a transport
of a patient to dialysis as a specific example. (SAC ¶ 61.) It was Mayo’s “general practice,”
according to the SAC, “that when it dispatched an ambulance immediately after receiving
a call, it would classify that trip as an emergency.” (SAC ¶ 47.)
The Court finds that discovery of the emergency upcoding scheme should not be
limited to hospital-to-hospital transports. The SAC alleges a broader scheme. The alleged
scheme also includes transports dispatched immediately after a call, a transport to dialysis,
transports scheduled in advance, transports that were not provided in immediate response
to a 911 call, and transports that were not dispatched as quickly as possible. These
allegations are based on Ms. Mothershed’s personal knowledge and experience. Because
the SAC “describes a general fact pattern of alleged fraudulent behavior supported by
specific examples of that behavior,” United States ex rel. McCartor v. Rolls-Royce Corp.,
No. 1:08-CV-00133-WTL, 2013 WL 5348536, at *6 (S.D. Ind. Sept. 24, 2013), the Court
will allow discovery into the larger fraudulent scheme of upcoding non-emergency
transports to emergency. See United States ex rel. Bledsoe v. Cmty. Health Sys., Inc., 501
F.3d 493, 510 (6th Cir. 2007) (holding “where a relator pleads a complex and far-reaching
fraudulent scheme with particularity, and provides examples of specific false claims
submitted to the government pursuant to that scheme, a relator may proceed to discovery
on the entire fraudulent scheme”). The Court finds that discovery into the broader alleged
scheme is relevant and proportional.
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Next, the Court turns to the alleged scheme of upcoding BLS services to ALS
services and looks to the allegations in the SAC to assess relevance and proportionality.
The two specific examples alleged in the SAC describe situations where an EMT-Basic
assessed the patient and neither an ALS assessment nor an ALS intervention was
performed. (SAC ¶¶ 126–27.) Other than these two representative examples, the SAC
provides no other specific information to support a broader fraudulent scheme. Other
allegations conclusorily state that Mayo falsely characterized BLS services as ALS
services. (E.g., SAC ¶¶ 2, 6, 120, 124, 218, 236.) Thus, the Court will limit the scope of
ALS-upcoding discovery to situations where Mayo billed for an ALS service when an
EMT-Basic assessed the patient and neither an ALS assessment nor an ALS intervention
was performed.
C. 	Request for Production No. 23
Ms. 	Mothershed’s 	Request 	for 	Production 	No. 	23 	asked 	Mayo 	to 	produce
documents reflecting its investigations into any of her concerns that ambulance transports
were being improperly coded and billed. Mayo objected to the request as seeking irrelevant,
burdensome, and disproportionate information, but Mayo agreed to produce responsive
documents related to Plaintiff’s surviving upcoding claims. Plaintiff contends in her motion
that Mayo’s investigations into her complaints about false billing in general or about the
dismissed medical-necessity theory remain relevant to Mayo’s knowledge and scienter.
The Court denies this request. To establish liability under the FCA, a relator must
show that the defendant acted knowingly with respect to the particular false claim at issue.
See 31 U.S.C. § 3729(a)(1)(A). Ms. Mothershed has not shown how Mayo’s knowledge
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about alleged billing deficiencies in general or about the dismissed medical-necessity
theory is relevant or proportional to the surviving upcoding claims. Further, to the extent
Ms. Mothershed raised complaints that implicated multiple issues or billing submissions,
which included the surviving upcoding claims, Mayo has already agreed to produce the
documents.
Accordingly, based on all of the files, records, and proceedings here, IT IS
HEREBY ORDERED that:
1. 	Ms. Mothershed’s Motion to Compel (Dkt. No. 106) is GRANTED in part and
DENIED in part, as follows.
2. 	Mayo’s objection to the time period requested for Document Request Nos. 3–
12, 15–22, and 25 and Interrogatory Nos. 3–5, and 7, which is “March 8, 2012
through the present and continuing,” is overruled in part and sustained in part.
The temporal scope for this discovery is from November 1, 2018, to March 8,
2022.
3. 	Mayo’s objection that the scope for Document Request Nos. 3–12, 14–17, 19,
21, 23, and 25 and Interrogatory No. 7 should be limited to documents and
information related to emergent hospital-to-hospital transfers and to ALS
transfers 	where 	an 	EMT, 	rather 	than 	a 	paramedic, 	performed 	the ALS
assessment, is overruled in part and sustained in part, as set forth fully above.
4. 	In response to Document Request No. 23, Mayo need not produce documents
reflecting 	investigations 	into 	Ms. 	Mothershed’s 	concerns 	that 	ambulance
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transports were being improperly coded and billed other than responsive
documents related to Plaintiff’s surviving upcoding claims.
Dated: October 31, 2025 	_s/ John F. Docherty__________
JOHN F. DOCHERTY
United States Magistrate Judge
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