United States ex rel. Stewart v. The Louisiana Clinic,
No. CIV. A 99-1767 (E.D. La. Feb. 22, 2002)

Physicians moved to dismiss relators' claims of violations of the False Claims Act for failure to plead the counts with specificity. The United States District Court, Eastern District, Louisiana ruled that, while specificity was required, the standards of specificity were lessened for relators but that the relators must at least allege the "who, what, when, where, and how" of the alleged fraud. The court granted most of the motions to dismiss but gave the relators leave to amend their complaints to meet the minimum specificity requirements.