Response | Filed: July 21, 2026
| Entered: July 21, 2026
United States of America et al v. Enzo Biochem Inc.
Other Statutes: False Claims Act | New York Southern
Declaration in Support of Motion
DECLARATION of John G. Martin in Support re: 111 MOTION to Dismiss First Amended Complaint.. Document filed by Enzo Biochem, Inc., Enzo Clinical Labs, Inc., Enzo Life Sciences, Inc.. (Attachments: # 1 Exhibit A- First Amended Complaint, # 2 Exhibit B- Centers for Medicare and Medicaid Services (CMS) ICD-10 Official Guidelines for Coding and Reporting for Fiscal Year 2021 (effective October 1, 2020 to September 30, 2021), # 3 Exhibit C- CMS ICD-10 Official Guidelines for Coding and Reporting for Fiscal Year 2022 (effective October 1, 2021 to September 30, 2022), # 4 Exhibit D- CMS ICD-10 Official Guidelines for Coding and Reporting for Fiscal Year 2023 (effective October 1, 2022 to September 30, 2023), # 5 Exhibit E- New York State Medicaid Update March 2020 Special Edition COVID-19 published by the New York State Department of Health (the DOH), # 6 Exhibit F- CMS guidance document entitled Coverage for COVID-19 Tests, published in April 2023, # 7 Exhibit G- DOHs New York State Medicaid Pharmacy Policy for Coronavirus Disease 2019 Testing, effective October 1, 2024, # 8 Exhibit H- New York State Medicaid Billing Guidance for COVID-19 Testing, Specimen Collection and Therapeutics, published by the DOH and updated on May 3, 2023, # 9 Exhibit I- Complaint addressed by the court in United States ex. rel. PCTLC, LLC v. Northwestern Memorial Healthcare, No. 19 Civ. 593, 2023 WL 6388328 (N.D. Ill. Sept. 29, 2023), # 10 Exhibit J- NPI search result for Enzo Clinical Labs, Inc., # 11 Exhibit K- Form 10-Q filed by Enzo with the U.S. Securities and Exchange Commission (the SEC) for the quarterly period ending on October 31, 2024, # 12 Exhibit L- Form 8-K and Asset Purchase Agreement, # 13 Exhibit M- Form 10-K/A filed by Enzo Biochem, Inc. with the SEC on November 29, 2021, # 14 Exhibit N- Form 10-K filed by Enzo Biochem, Inc. with the SEC on October 19, 2020, # 15 Exhibit O- U.S. Department of Health and Human Services, Office of Inspector General Advisory Opinion No. 15-04 (2015), # 16 Exhibit P- U.S. Department of Health and Human Services Special Fraud Alert: Arrangements for the Provision of Clinical Laboratory Services, # 17 Exhibit Q- Food & Drug Admin., COVID-19 Test Uses: FAQs on Testing for SARS-CoV-2, #
Response | Filed: July 21, 2026
| Entered: July 21, 2026
United States of America et al v. Enzo Biochem Inc.
Other Statutes: False Claims Act | New York Southern
Memorandum of Law in Support of Motion
MEMORANDUM OF LAW in Support re: 111 MOTION to Dismiss First Amended Complaint. . Document filed by Enzo Biochem, Inc., Enzo Clinical Labs, Inc., Enzo Life Sciences, Inc...(Martin, John)