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Case Study: Dr. Whyte's Staffing

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Whyte’s compliance with the reporting obligation and other terms of the Recruitment Agreement, even though Dr. Whyte reported minimal or non-existent Cash Collections during some months of the twelve-month Cash Collections Guarantee Period. When Dr. Whyte failed to properly report his Cash Collections, GVMC timely invoked the audit procedure. (Whyte Dep., 132:15-133:8; see also Physician Income Guarantee Audit Data Request, attached to Plf.’s Mot. as Exhibit C.)
3. The circumstances related to Dr. Whyte’s recruitment to GVMC, whether to assist with staffing in the Emergency Department or otherwise, have no bearing on the legal question before this Court.
GVMC contends that, in 2011, Mr. Followell developed a plan to create a vascular

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