Complaint — No. 1:24-cv-11950 (Dkt. 1, D. Mass.)

Summary

A 42-page complaint filed July 26, 2024 in the U.S. District Court for the District of Massachusetts, No. 1:24-cv-11950, by relator The Tarbell Group, LLC under the False Claims Act, 31 U.S.C. §§ 3729-3733, against Acoaxet Club Inc. and many other Massachusetts clubs, chambers of commerce and associations. The complaint seeks to recover funds it alleges the defendants obtained illegally under federal COVID-19 relief laws. It groups the defendants by tax status, including organizations exempt under section 501(c)(6) of the Internal Revenue Code and 501(c)(7) clubs, and tables each loan with its draw, dates and amounts.

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Case 1:24-cv-11950-LTS Documenti_ Filed 07/26/24 Page 1 of 42

FILED
IN CLERKS OFFICE

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS — 20174 JUL 26 PM 1:49

United States of America ex rel.
The Tarbell Group, LLC,

Plaintiff
v.

Acoaxet Club Inc.,

Administrators of Special Education Inc.,

The Advertising Club Of Greater Boston Inc.
dba The Ad Club,

American Civic Association Inc. dba Sons of
Italy,

Amherst Golf Club Inc.,

Arlington Chamber of Commerce Inc.,

Bar Association Of Norfolk County Inc.,

Benevolent & Protective Order of Elks of the
USA—Fall River Lodge No. 118,

Benevolent & Protective Order of Elks of the
USA—Haverhill Lodge No. 165,

Benevolent & Protective Order of Elks of the
USA—Waltham- Watertown Lodge No. 953,

Berkshire County Board of Realtors Inc,

Bertocci Memorial Club of Brockton Inc.,

Billerica Lodge No. 2648 Loyal Order of
Moose,

Boston Madison Square Garden Club,

Bridgewater Citizens’ Club Inc.,

Brockton Country Club Inc.,

Builders and Remodelers Association of Greater|
Boston Inc.,

Cambridge Chamber Of Commerce,

Cape Cod Cranberry Growers’ Association,

Club Franco American de Westford
Massachusetts,

Clube Desportivo Faialense Inc.,

Cohasse Country Club, _

Concord Chamber of Commerce,

Construction Industries of Massachusetts Inc.,

Cottage Park Yacht Club Inc., .. -

Curve Triangle & Rectangle Institute Inc.,

Dennis Yacht Club Inc.,

Edgewood Club Inc.,

U.S. DISTRICT COURT
DISTRICT OF MASS.

FILED UNDER SEAL PURSUANT TO
31 U.S.C. § 3730(b)(2)

Case no.

Case 1:24-cv-11950-LTS Document 1

Ellinwood Country Club Inc.,

Employers Association of the Northeast Inc.,

Everett Chamber of Commerce Inc.,

Fall River Country Club,

The Fay Club,

Forestdale Cemetery Association,

Grand Lodge of Theta Delta Chi Inc.,

Greater Chicopee Chamber of Commerce Inc.,

Greenfield Lodge No. 997 Loyal Order of
Moose,

Gremio Lusitano Club Inc.,

Greylock Community Club Inc.,

H. E. Fletcher Social & Athletic Club Inc.,

Hampden County Bar Association Inc.,

Harvard Square Business Association Inc.,

Holyoke Canoe Club Inc.,

International Brotherhood Of Electrical
Workers Building Corporation,

International Brotherhood Of Electrical
Workers Local 103,

Irish-American Club Inc. of Woburn,

Italian Naturalization Club Inc. of Taunton,

John Alden Sportsmen’s Club Inc.,

Jubilee Yacht Club,

Knights of Columbus dba Cardinal Spellman
Council 347,

Lafayette Naturalization Club Inc.,

Lakeville Aerie No. 3944 Fraternal Order of
Eagles,

Lenox Chamber of Commerce,

Lexington Golf Club,

Longwood Covered Courts Trust,

Ludlow Country Club Inc.,

Ludlow Fish & Game Club Inc.,

Ludlow Tennis Club Inc.,

Malden Lodge No. 1910 Loyal Order of Moose,

Marblehead Yacht Club Inc.,

Marshfield Country Club,

Massachusetts Association of Accountants Inc.,

Massachusetts Chiefs of Police Association Inc.,

Massachusetts Farm Bureau Federation Inc.,

Massachusetts LGBT Chamber Of Commerce,

Massachusetts Laborers’ Health & Welfare
Fund,

Massachusetts Systems Contractors Association
Inc., .

Filed 07/26/24

Page 2 of 42

Case 1:24-cv-11950-LTS Document 1

Master, Wardens, and Members of The Grand
Lodge of Masons in Massachusetts,

Milton Hoosic Club Inc.,

Minute Man Sportsmans Club Inc.,

Nabnasset Lake Country Club Inc.,

National Board Of Trial Advocacy Inc.,

New Bedford Sports Club Inc.,

The New England Affordable Housing
Management Association Inc.,

North of Boston Convention & Visitors Bureau
Inc.,

The North Shore Chamber of Commerce, Inc.,

North Shore Skating Club Inc.,

North Shore Tennis & Squash Club Inc.,

Oak Grove Cemetery Association of Falmouth
Inc.,

The Old Colony Yacht Club,

Orleans Yacht Club Inc., .

Outdoor Amusement Business Association Inc.,

Palmer’s Cove Yacht Club Inc.,

Pine Grove Cemetery Corporation,

Pleasant Park Yacht Club Inc.,

The Plymouth Area Chamber of Commerce
Inc.,

Plymouth Country Club Inc.,

Point Independence Yacht Club Inc.,

Polish American Veterans of Webster Inc.,

The Polish Club Lodge 2058 Inc.,

Portuguese National Club,

Prince Hall Masonic Grand Lodge,

The Proprietors of Forest Hills Cemetery,

Realtor Association of Central Massachusetts,

Rowley Veterans’ Association Inc.,

Salem Chamber of Commerce & Civics,

Salem Office of Tourism & Cultural Affairs Inc.
dba Destination Salem,

Sandy Bay Yacht Club, Inc.,

Singletary Rod & Gun Club Inc.,

Sons of Italy in America—Grand Lodge of
Massachusetts,

Sons of Italy in America—Methuen Lodge No.
902,

Sons of Italy in America—Quincy Lodge No.
1295,

Stockbridge Golf Club, -

Stoneham Chamber of Commerce Inc.,

Filed 07/26/24

Page 3 of 42

Case 1:24-cv-11950-LTS Documenti - Filed 07/26/24 Page 4of 42

Supreme Council of the Royal Arcanum,
Swampscott Yacht Club,

Tennis and Racquet Club,

Town River Yacht Club,

Volunteer Yacht Club,

Wampatuck Country Club of Canton Inc.,
Wayland Swimming and Tennis Club Inc.,
Wequaquet Lake Yacht Club,

West Dennis Yacht Club Inc.,

West End Beagle Club Inc. of Gardner,
Whitinsville Golf Club,

Winthrop Golf Club,

Winthrop Yacht Club Inc.,

Wood Products Manufacturers Association,
Worcester County Memorial Park Inc., and
Young Men’s Club of Hadley Inc.,

Defendants

COMPLAINT

Nature of the Case

1. Relator The Tarbell Group, LLC, brings this action for itself and the United States
under the False Claims Act, 31 U.S.C. §§ 3729-3733, to recover funds illegally obtained by the
defendants under federal COVID-19 relief laws.

Jurisdiction and Venue

2. The Court has jurisdiction of, and is the appropriate venue for, this matter because
it arises under a federal law, because the United States is a plaintiff, and because in this judicial
district each defendant can be found, resides, transacts business in, or committed an act
proscribed by the False Claims Act. 28 U.S.C. §§ 1331, 1345; 31 U.S.C. § 3732(a).

Parties—Relator

3. Relator The Tarbell Group, LLC, is a limited liability company located in and

organized under the laws of the Commonwealth of Virginia.

Case 1:24-cv-11950-LTS Documenti - Filed 07/26/24 Page 5 of 42

Parties—501(c)(2) Defendant

4, Defendant International Brotherhood Of Electrical Workers Building Corporation
is an entity exempt from taxation under section 501(c)(2) of the Internal Revenue Code, 26
U.S.C. § 501(c)(2) (“Tax-Exempt 501(c)(2) Organization”). On the loan application(s) at issue
herein, this defendant gave its address as 256 Freeport Street, Dorchester, MA.

Parties—501(c)(5) Defendants

5. Defendant Cape Cod Cranberry Growers’ Association is an entity exempt from
taxation under section 501(c)(5) of the Internal Revenue Code, 26 U.S.C. § 501(c)(5) (“Tax-
Exempt 501(c)(5) Organization”). On the loan application(s) at issue herein, this defendant gave
its address as 265 South Meadow Road, Unit 2D, Plymouth, MA.

6. Defendant International Brotherhood Of Electrical Workers Local 103 is a Tax-
Exempt 501(c)(5) Organization. On the loan application(s) at issue herein, this defendant gave its
address as 256 Freeport Street, Dorchester, MA.

7. Defendant Massachusetts Farm Bureau Federation Inc. is a Tax-Exempt 501(c)(5)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 249
Lakeside Avenue, Marlborough, MA.

Parties—501(c)(6) Defendants

8. Defendant Administrators of Special Education Inc. is an entity exempt from
taxation under section 501(c)(6) of the Internal Revenue Code, 26 U.S.C. § 501(c)(6) (“Tax-
Exempt 501(c)(6) Organization”). On the loan application(s) at issue herein, this defendant gave
its address as 3 Allied Drive, Suite 303, Dedham, MA.

9. Defendant The Advertising Club Of Greater Boston Inc. dba The Ad Club is a
Tax-Exempt 501 (c)(6) Organization. On the loan application(s) at issue herein, this defendant

gave its address as 22 Batterymarch Street, Boston, MA.

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10. Defendant Arlington Chamber of Commerce Inc. is a Tax-Exempt 501(c)(6)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 611
Massachusetts Avenue, Arlington, MA.

11. Defendant Bar Association Of Norfolk County Inc. is a Tax-Exempt 501(c)(6)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 420
Washington Street, Suite 304, Braintree, MA.

12. Defendant Berkshire County Board of Realtors Inc is a Tax-Exempt 501(c)(6)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 99
West Street, Suite 200, Pittsfield, MA.

13. Defendant Builders and Remodelers Association of Greater Boston Inc. is a Tax-
Exempt 501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its
address as 45 Dan Road, Canton, MA.

14. Defendant Cambridge Chamber Of Commerce is a Tax-Exempt 501(c)(6)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 1
Kendall Square, Suite 6-105, Cambridge, MA.

15. Defendant Concord Chamber of Commerce is a Tax-Exempt 501(c)(6)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 35
Beharrell Street, Concord, MA.

16. | Defendant Construction Industries of Massachusetts Inc. is a Tax-Exempt
501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address

as 1500 Boston Providence Turnpike, Suite 14, Norwood, MA.

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 7 of 42

17. Defendant Curve Triangle & Rectangle Institute Inc. is a Tax-Exempt 501(c)(6)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 101
Federal Street, Suite 1900, Boston, MA.

18. | Defendant Employers Association of the Northeast Inc. is a Tax-Exempt
501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address
as 67 Hunt Street, Suite 111, P.O. Box 1070, Agawam, MA.

19. Defendant Everett Chamber of Commerce Inc. is a Tax-Exempt 501(c)(6)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 467
Broadway, Everett, MA.

20. Defendant Greater Chicopee Chamber of Commerce Inc. is a Tax-Exempt
501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address
as 48 Center Street, Chicopee, MA.

21. | Defendant Hampden County Bar Association Inc. is a Tax-Exempt 501(c)(6)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 50
State Street, Springfield, MA.

22. Defendant Harvard Square Business Association Inc. is a Tax-Exempt 501(c)(6)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 18
Brattle Square, Cambridge, MA.

23. Defendant Lenox Chamber of Commerce is a Tax-Exempt 501(c)(6)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 4

Housatonic Street, Lenox, MA.

Case 1:24-cv-11950-LTS Documenti_ Filed 07/26/24 Page 8 of 42

24. Defendant Massachusetts Association of Accountants Inc. is a Tax-Exempt
501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address
as 607 North Avenue, D16-4, Wakefield, MA.

25. | Defendant Massachusetts Chiefs of Police Association Inc. is a Tax-Exempt
501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address
as 353 Providence Road, South Grafton, MA.

26. Defendant Massachusetts LGBT Chamber Of Commerce is a Tax-Exempt
501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address
as 50 Milk Street, 16th Floor, Boston, MA.

27. Defendant Massachusetts Systems Contractors Association Inc. is a Tax-Exempt
501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address
as 1 Merchant Street, Suite 112, Sharon, MA.

28. Defendant National Board Of Trial Advocacy Inc. is a Tax-Exempt 501(c)(6)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 850
Franklin Street, Suite 8, Wrentham, MA.

29. Defendant The New England Affordable Housing Management Association Inc.
is a Tax-Exempt 501(c)(6) Organization. On the loan application(s) at issue herein, this
defendant gave its address as 400 Washington Street, Suite 202, Braintree, MA.

30. Defendant North of Boston Convention & Visitors Bureau Inc. is a Tax-Exempt
501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address

as 195 South Bound Exit 60, Salisbury, MA.

Case 1:24-cv-11950-LTS Documenti _ Filed 07/26/24 Page 9 of 42

31. Defendant The North Shore Chamber of Commerce, Inc. is a Tax-Exempt
501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address
- as 5 Cherry Hill Drive, Danvers, MA.

32. | Defendant Outdoor Amusement Business Association Inc. is a Tax-Exempt
501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address
as 1305 Memorial Avenue, Suite 2, West Springfield, MA.

33. Defendant The Plymouth Area Chamber of Commerce Inc. is a Tax-Exempt
501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address
as 134 Court Street, Plymouth, MA.

34. Defendant Realtor Association of Central Massachusetts is a Tax-Exempt
501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address
as 492 Washington Street, Auburn, MA.

35. Defendant Salem Chamber of Commerce & Civics is a Tax-Exempt 501(c)(6)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 265
Essex Street, Suite 101, Salem, MA.

36. Defendant Salem Office of Tourism & Cultural Affairs Inc. dba Destination
Salem is a Tax-Exempt 501(c)(6) Organization. On the loan application(s) at issue herein, this
defendant gave its address as 81 Washington Street, Suite 204, Salem, MA.

37. Defendant Stoneham Chamber of Commerce Inc. is a Tax-Exempt 501(c)(6)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 335

Main Street, Suite 202, Stoneham, MA.

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 10 of 42

38. Defendant Wood Products Manufacturers Association is a Tax-Exempt 501(c)(6)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 14
East Broadway, Gardner, MA.

Parties—501(c)(7) Defendants

39. | Defendant Acoaxet Club Inc. is an entity exempt from taxation under section
501(c)(7) of the Internal Revenue Code, 26 U.S.C. § 501(c)(7) (“Tax-Exempt 501(c)(7)
Organization”). On the loan application(s) at issue herein, this defendant gave its address as 152
Howland Road, Westport, MA.

40. Defendant Amherst Golf Club Inc. is a Tax-Exempt 501(c)(7) Organization. On
the loan application(s) at issue herein, this defendant gave its address as 365 South Pleasant
Street, Amherst, MA.

41. Defendant Bertocci Memorial Club of Brockton Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 594
Montello Street, Brockton, MA.

42. Defendant Boston Madison Square Garden Club is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 180
Canal Street, Suite 302, Boston, MA.

43. Defendant Bridgewater Citizens’ Club Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 60
Hale Street, Bridgewater, MA.

44. Defendant Brockton Country Club Inc. is a Tax-Exempt 501(c)(7) Organization.
On the loan application(s) at issue herein, this defendant gave its address as 265 Samuel Avenue,

Brockton, MA.

10

Case 1:24-cv-11950-LTS Document1i Filed 07/26/24 Page 11 of 42

45. Defendant Club Franco American de Westford Massachusetts is a Tax-Exempt
501(c)(7) Organization. On the loan application(s) at issue herein, this defendant gave its address
as 55 West Prescott Street, Westford, MA.

46. Defendant Clube Desportivo Faialense Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 1121
Cambridge Street, Cambridge, MA.

47. Defendant Cohasse Country Club is a Tax-Exempt 501(c)(7) Organization. On
the loan application(s) at issue herein, this defendant gave its address as 393 Eastford Road,
Southbridge, MA.

48. Defendant Cottage Park Yacht Club Inc. is a Tax-Exempt 501(c)(7) Organization.
On the loan application(s) at issue herein, this defendant gave its address as 1 Bakers Square,
Winthrop, MA.

49. Defendant Dennis Yacht Club Inc. is a Tax-Exempt 501(c)(7) Organization. On
the loan application(s) at issue herein, this defendant gave its address as P.O. Box 556, 4 Harbor
Road, East Dennis, MA.

50. | Defendant Edgewood Club Inc. is a Tax-Exempt 501(c)(7) Organization. On the
loan application(s) at issue herein, this defendant gave its address as 266 Pleasant Street,
Raynham, MA.

51. | Defendant Ellinwood Country Club Inc. is a Tax-Exempt 501(c)(7) Organization.
On the loan application(s) at issue herein, this defendant gave its address as 1928 Pleasant Street,

Athol, MA.

11

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 12 of 42

52. Defendant Fall River Country Club is a Tax-Exempt 501(c)(7) Organization. On
the loan application(s) at issue herein, this defendant gave its address as 4232 North Main Street,
Fall River, MA.

53. Defendant The Fay Club is a Tax-Exempt 501(c)(7) Organization. On the loan
application(s) at issue herein, this defendant gave its address as 658 Main Street, Fitchburg, MA.

54. Defendant Grand Lodge of Theta Delta Chi Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 214
Lewis Wharf, Boston, MA.

55. | Defendant Gremio Lusitano Club Inc. is a Tax-Exempt 501(c)(7) Organization.
On the loan application(s) at issue herein, this defendant gave its address as 385 Winsor Street,
Ludlow, MA.

56. Defendant Greylock Community Club Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 548
State Road, North Adams, MA.

57. Defendant H. E. Fletcher Social & Athletic Club Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 11
Brookside Road, Westford, MA.

58. | Defendant Holyoke Canoe Club Inc. is a Tax-Exempt 501(c)(7) Organization. On
the loan application(s) at issue herein, this defendant gave its address as 33 Old Ferry Road,
Holyoke, MA. .

59. Defendant Irish-American Club Inc. of Woburn is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 147

Main Street, Woburn, MA.

12

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60. Defendant Italian Naturalization Club Inc. of Taunton is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 46
Wales Street, Taunton, MA.

61. Defendant John Alden Sportsmen’s Club Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 16
Minuteman Lane, Plymouth, MA.

62. Defendant Jubilee Yacht Club is a Tax-Exempt 501(c)(7) Organization. On the
loan application(s) at issue herein, this defendant gave its address as 127 Water Street, Beverly,
MA.

63. Defendant Lafayette Naturalization Club Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 11
High Street, Amesbury, MA.

64. Defendant Lexington Golf Club is a Tax-Exempt 501(c)(7) Organization. On the
loan application(s) at issue herein, this defendant gave its address as 55 Hill Street, Lexington,
MA.

65. Defendant Longwood Covered Courts Trust is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 28
Middlesex Road, Chestnut Hill, MA.

66. Defendant Ludlow Country Club Inc. is a Tax-Exempt 501(c)(7) Organization.
On the loan application(s) at issue herein, this defendant gave its address as 1 Tony Lema Drive,

Ludlow, MA.

13

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 14 of 42

67. Defendant Ludlow Fish & Game Club Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 200
Sportsmen's Road, Ludlow, MA.

68. Defendant Ludlow Tennis Club Inc. is a Tax-Exempt 501(c)(7) Organization. On
the loan application(s) at issue herein, this defendant gave its address as 40 Carmelinas Circle,
Ludlow, MA.

69. Defendant Marblehead Yacht Club Inc. is a Tax-Exempt 501(c)(7) Organization.
On the loan application(s) at issue herein, this defendant gave its address as 4 Cliff Street,
Marblehead, MA.

70. Defendant Marshfield Country Club is a Tax-Exempt 501(c)(7) Organization. On
the loan application(s) at issue herein, this defendant gave its address as 515 Moraine Street,
Marshfield, MA.

71. Defendant Milton Hoosic Club Inc. is a Tax-Exempt 501(c)(7) Organization. On
the loan application(s) at issue herein, this defendant gave its address as 70 Greenlodge Street,
Canton, MA.

72. Defendant Minute Man Sportsmans Club Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 56 R
Francis Wyman Road, Burlington, MA.

73. Defendant Nabnasset Lake Country Club Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 47

Oak Hill Road, Westford, MA.

14

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74. Defendant New Bedford Sports Club Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 1790
Acushnet Avenue, New Bedford, MA.

75. Defendant North Shore Skating Club Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 51
Symonds Way, Reading, MA.

76. Defendant North Shore Tennis & Squash Club Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 98
Swampscott Road, Salem, MA.

77. Defendant The Old Colony Yacht Club is a Tax-Exempt 501(c)(7) Organization.
On the loan application(s) at issue herein, this defendant gave its address as 235 Victory Road,
Dorchester, MA.

78. | Defendant Orleans Yacht Club Inc. is a Tax-Exempt 501(c)(7) Organization. On
the loan application(s) at issue herein, this defendant gave its address as 39 Cove Road, Orleans,
MA.

79. Defendant Palmer’s Cove Yacht Club Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 74
Leavitt Street, Salem, MA.

80. Defendant Pleasant Park Yacht Club Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 562

Pleasant Street, Winthrop, MA.

15

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81. | Defendant Plymouth Country Club Inc. is a Tax-Exempt 501(c)(7) Organization.
On the loan application(s) at issue herein, this defendant gave its address as 221 Warren Avenue,
Plymouth, MA.

82. Defendant Point Independence Yacht Club Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 15
Independence Lane, Onset, MA.

83. | Defendant Polish American Veterans of Webster Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 30
Ray Street, Webster, MA.

84. | Defendant Portuguese National Club is a Tax-Exempt 501(c)(7) Organization. On
the loan application(s) at issue herein, this defendant gave its address as 21 Railroad Avenue,
Stoughton, MA.

85. Defendant Rowley Veterans’ Association Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 19
Bradford Street, Rowley, MA.

86. | Defendant Sandy Bay Yacht Club, Inc. is a Tax-Exempt 501(c)(7) Organization.
On the loan application(s) at issue herein, this defendant gave its address as 5 T-Wharf Road,
Rockport, MA.

87. Defendant Singletary Rod & Gun Club Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 300

Sutton Avenue, Oxford, MA.

16

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88. Defendant Stockbridge Golf Club is a Tax-Exempt 501(c)(7) Organization. On
the loan application(s) at issue herein, this defendant gave its address as 3 Cherry Street,
Stockbridge, MA.

89. Defendant Swampscott Yacht Club is a Tax-Exempt 501(c)(7) Organization. On
the loan application(s) at issue herein, this defendant gave its address as 425 Humphrey Street,
Swampscott, MA.

90. | Defendant Tennis and Racquet Club is a Tax-Exempt 501(c)(7) Organization. On
the loan application(s) at issue herein, this defendant gave its address as 939 Boylston Street,
Boston, MA.

91. Defendant Town River Yacht Club is a Tax-Exempt 501(c)(7) Organization. On
the loan application(s) at issue herein, this defendant gave its address as 60 Mound Street,
Quincy, MA.

92. Defendant Volunteer Yacht Club is a Tax-Exempt 501(c)(7) Organization. On the
loan application(s) at issue herein, this defendant gave its address as 68 Lynnway, Lynn, MA.

93. Defendant Wampatuck Country Club of Canton Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 99
Pleasant Garden Road, P.O. Box 56, Canton, MA.

94. Defendant Wayland Swimming and Tennis Club Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 228
Glezen Lane, Wayland, MA.

95. Defendant Wequaquet Lake Yacht Club is a Tax-Exempt 501(c)(7) Organization.
On the loan application(s) at issue herein, this defendant gave its address as 57 Yacht Club

Drive, Centerville, MA.

17

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96. Defendant West Dennis Yacht Club Inc. is a Tax-Exempt 501(c)(7) Organization.
On the loan application(s) at issue herein, this defendant gave its address as 259 Loring Avenue,
West Dennis, MA.

97. | Defendant West End Beagle Club Inc. of Gardner is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 110
Clark Street, Gardner, MA.

98. Defendant Whitinsville Golf Club is a Tax-Exempt 501(c)(7) Organization. On
the loan application(s) at issue herein, this defendant gave its address as 179 Fletcher Street,
Whitinsville, MA.

99. Defendant Winthrop Golf Club is a Tax-Exempt 501(c)(7) Organization. On the
loan application(s) at issue herein, this defendant gave its address as 453 Main Street, Winthrop,
MA.

100. Defendant Winthrop Yacht Club Inc. is a Tax-Exempt 501(c)(7) Organization. On
the loan application(s) at issue herein, this defendant gave its address as 649 Shirley Street,
Winthrop, MA.

101. Defendant Young Men’s Club of Hadley Inc. is a Tax-Exempt 501(c)(7)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 138
East Street, Hadley, MA.

Parties—501(c)(8) Defendants

102. Defendant American Civic Association Inc. dba Sons of Italy is an entity exempt
from taxation under section 501(c)(8) of the Internal Revenue Code, 26 U.S.C. § 501(c)(8)
(“Tax-Exempt 501(c)(8) Organization”). On the loan application(s) at issue herein, this

defendant gave its address as 117 Swanton Street, Winchester, MA.

18

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 19 of 42

103. Defendant Benevolent & Protective Order of Elks of the USA—Fall River Lodge
No. 118 is a Tax-Exempt 501(c)(8) Organization. On the loan application(s) at issue herein, this
defendant gave its address as 4500 North Main Street, Fall River, MA.

104. Defendant Benevolent & Protective Order of Elks of the USA—Haverhill Lodge
No. 165 is a Tax-Exempt 501(c)(8) Organization. On the loan application(s) at issue herein, this
defendant gave its address as 24 Summer Street, Haverhill, MA.

105. Defendant Benevolent & Protective Order of Elks of the USA—Waltham-
Watertown Lodge No. 953 is a Tax-Exempt 501(c)(8) Organization. On the loan application(s) at
issue herein, this defendant gave its address as 101 School Street, Waltham, MA.

106. Defendant Billerica Lodge No. 2648 Loyal Order of Moose is a Tax-Exempt
501(c)(8) Organization. On the loan application(s) at issue herein, this defendant gave its address
as 104 Boston Road, North Billerica, MA.

107. Defendant Greenfield Lodge No. 997 Loyal Order of Moose is a Tax-Exempt
501(c)(8) Organization. On the loan application(s) at issue herein, this defendant gave its address
as 20 School Street, Greenfield, MA.

108. Defendant Knights of Columbus dba Cardinal Spellman Council 347 is a Tax-
Exempt 501(c)(8) Organization. On the loan application(s) at issue herein, this defendant gave its
address as 1195 Bedford Street, Whitman, MA.

109. Defendant Lakeville Aerie No. 3944 Fraternal Order of Eagles is a Tax-Exempt
501(c)(8) Organization. On the loan application(s) at issue herein, this defendant gave its address

as 217 County Street, Lakeville, MA.

19

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 20 of 42

110. Defendant Malden Lodge No. 1910 Loyal Order of Moose is a Tax-Exempt
501(c)(8) Organization. On the loan application(s) at issue herein, this defendant gave its address
as 562 Broadway, Malden, MA.

111. Defendant The Polish Club Lodge 2058 Inc. is a Tax-Exempt 501(c)(8)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 14 1/2
Mill Street, Amesbury, MA.

112. Defendant Prince Hall Masonic Grand Lodge is a Tax-Exempt 501(c)(8)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 24
Washington Street, Dorchester, MA.

113. Defendant Sons of Italy in America—Grand Lodge of Massachusetts is a Tax-
Exempt 501(c)(8) Organization. On the loan application(s) at issue herein, this defendant gave its
address as 93 Concord Avenue, Belmont, MA.

114. Defendant Sons of Italy in America—Methuen Lodge No. 902 is a Tax-Exempt
501(c)(8) Organization. On the loan application(s) at issue herein, this defendant gave its address
as 459 Merrimack Street, Methuen, MA.

115. Defendant Sons of Italy in America—Quincy Lodge No. 1295 is a Tax-Exempt
501(c)(8) Organization. On the loan application(s) at issue herein, this defendant gave its address
as 120 Quarry Street, Quincy, MA.

116. Defendant Supreme Council of the Royal Arcanum is a Tax-Exempt 501(c)(8)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 61
Batterymarch Street, Boston, MA.

Parties—501(c)(9) Defendant

117. Defendant Massachusetts Laborers’ Health & Welfare Fund is an entity exempt

from taxation under section 501(c)(9) of the Internal Revenue Code, 26 U.S.C. § 501(c)(9)

20

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 21 of 42

(“Tax-Exempt 501(c)(9) Organization”). On the loan application(s) at issue herein, this
defendant gave its address as 1400 District Avenue, Suite 200, Burlington, MA.

Parties—501(c)(10) Defendant

118. Defendant Master, Wardens, and Members of The Grand Lodge of Masons in
Massachusetts is an entity exempt from taxation under section 501(c)(10) of the Internal
Revenue Code, 26 U.S.C. § 501(c)(10) (“Tax-Exempt 501(c)(10) Organization”). On the loan
application(s) at issue herein, this defendant gave its address as 186 Tremont Street, Boston, MA.

Parties—501(c)(13) Defendants

119. Defendant Forestdale Cemetery Association is an entity exempt from taxation
under section 501(c)(13) of the Internal Revenue Code, 26 U.S.C. § 501(c)(13) (“Tax-Exempt
501(c)(13) Organization”). On the loan application(s) at issue herein, this defendant gave its
address as 304 Cabot Street, Holyoke, MA.

120. Defendant Oak Grove Cemetery Association of Falmouth Inc. is a Tax-Exempt
501(c)(13) Organization. On the loan application(s) at issue herein, this defendant gave its
address as 46 Jones Road, Falmouth, MA.

121. Defendant Pine Grove Cemetery Corporation is a Tax-Exempt 501(c)(13)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 2
Oscars Road, Spencer, MA.

122. Defendant The Proprietors of Forest Hills Cemetery is a Tax-Exempt 501(c)(13)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 95
Forest Hills Avenue, Jamaica Plain, MA.

123. Defendant Worcester County Memorial Park Inc. is a Tax-Exempt 501(c)(13)
Organization. On the loan application(s) at issue herein, this defendant gave its address as 217

Richards Avenue, Paxton, MA.

21

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 22 of 42

Background

124. To provide economic relief and stimulate the economy during the COVID-19
pandemic, Congress in 2020 enacted the Coronavirus Aid, Relief, and Economic Security Act,
Pub. L. 116-136, amended by, inter alia, the Paycheck Protection Program Flexibility Act of
2020, Pub. L. 116-142 and the American Rescue Plan Act of 2021, Pub. L. 117-2 (2021)
(together with implementing regulations, referred to herein as the “PPP Program”). The PPP
Program effectively transferred money from the federal government to eligible recipients via the
United States Small Business Administration (“SBA”). The transfers took the form of private
loans guaranteed, forgiven and reimbursed by SBA (“PPP Loans”).

125. PPP Loan recipients could receive up to two loans, one in each of two tranches,
each called a “draw,” i.e., first-draw and second-draw PPP Loans.

126. A recipient could receive a second-draw loan only after having obtained a first-
draw loan.

127. As a condition of receiving PPP Loans and forgiveness thereof, each applicant
was required to certify its eligibility under the PPP Program.

128. The PPP Program excluded Tax-Exempt 501(c)(2) Organizations from eligibility
until March 11, 2021.

129. The PPP Program excluded Tax-Exempt 501(c)(5) Organizations from eligibility
until March 11, 2021.

130. The PPP Program excluded Tax-Exempt 501(c)(6) Organizations from eligibility
until December 27, 2020.

131. The PPP Program excluded Tax-Exempt 501(c)(7) Organizations from eligibility

until March 11, 2021.

22

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 23 of 42

132. The PPP Program excluded Tax-Exempt 501(c)(8) Organizations from eligibility
until March 11, 2021.

133. The PPP Program excluded Tax-Exempt 501(c)(9) Organizations from eligibility
until March 11, 2021.

134. The PPP Program excluded Tax-Exempt 501(c)(10) Organizations from eligibility
until March 11, 2021.

135. The PPP Program excluded Tax-Exempt 501(c)(13) Organizations from eligibility
until March 11, 2021.

136. Defendants each applied for and received PPP Loans for which they were legally
ineligible.

137. Some defendants also applied for and received second PPP Loans for which they
were ineligible as “fruit of the poisonous tree,” because receipt of a first-draw loan was a
prerequisite to receive a second-draw loan.

PPP Loans

138. Defendants received approval for, and forgiveness of, their PPP Loans on the
dates and in the amounts shown on the table attached hereto, despite being legally ineligible for
the same.

First Cause of Action

False Claims Act, 31 U.S.C. § 3729
PPP Loan(s)

139. Relator repeats and realleges each of the foregoing paragraphs.
140. Each defendant was ineligible to receive its PPP Loan(s) at the time it applied and

received approval for the same.

23

Case 1:24-cv-11950-LTS Document1i Filed 07/26/24 Page 24 of 42

141. Each defendant did knowingly present, or cause or be presented, a false or
fraudulent claim for payment or approval, to the injury of the United States, by falsely certifying
that it was eligible for a PPP Loan and forgiveness thereof and thereby receiving the same.

142. Each defendant did knowingly make, use, or cause to be made or use, a false
record or statement material to a false or fraudulent claim, to the injury of the United States, by
falsely certifying that it was eligible for a PPP Loan and forgiveness thereof and thereby
receiving the same.

143. Each defendant did knowingly make, use, or cause to be made or used, a false
record or statement material to, or did knowingly conceal, or did knowingly and improperly
avoid or decrease, an obligation to pay or transmit money or property to the United States
government, by falsely certifying that it was eligible for a PPP Loan and forgiveness thereof and
thereby receiving the same.

Second Cause of Action

False Claims Act, 31 U.S.C. § 3729
Fruit of the Poisonous Tree

144. Relator repeats and realleges each of the foregoing paragraphs.
145. The following defendants received second-draw PPP Loans for which they were
ineligible due to their failure lawfully to obtain first-draw PPP Loans:
a. Acoaxet Club Inc.
b. Administrators of Special Education Inc.
Cc. The Advertising Club Of Greater Boston Inc. dba The Ad Club
d. Arlington Chamber of Commerce Inc.
e. Boston Madison Square Garden Club
f. Builders and Remodelers Association of Greater Boston Inc.

g. Cambridge Chamber Of Commerce

24

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 25 of 42

ab.
ac.

ad.

Cape Cod Cranberry Growers’ Association

Concord Chamber of Commerce

Employers Association of the Northeast Inc.

Everett Chamber of Commerce Inc.

The Fay Club

Grand Lodge of Theta Delta Chi Inc.

Greater Chicopee Chamber of Commerce Inc.
Hampden County Bar Association Inc.

International Brotherhood Of Electrical Workers Local 103
Lakeville Aerie No. 3944 Fraternal Order of Eagles
Malden Lodge No. 1910 Loyal Order of Moose
Massachusetts Association of Accountants Inc.
Massachusetts Chiefs of Police Association Inc.
Massachusetts LGBT Chamber Of Commerce
Massachusetts Systems Contractors Association Inc.
New Bedford Sports Club Inc.

The New England Affordable Housing Management Association Inc.
North of Boston Convention & Visitors Bureau Inc.
The North Shore Chamber of Commerce, Inc.
Outdoor Amusement Business Association Inc.

The Plymouth Area Chamber of Commerce Inc.
Plymouth Country Club Inc.

Salem Chamber of Commerce & Civics

25

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 26 of 42

ae. Salem Office of Tourism & Cultural Affairs Inc. dba Destination Salem
af. Singletary Rod & Gun Club Inc.

ag. | Stoneham Chamber of Commerce Inc.

ah. § Wood Products Manufacturers Association

146. Because these defendants received their first-draw PPP Loans via fraud and under
false pretenses, their second-draw PPP Loans constituted “fruit of the poisonous tree” and were
unlawfully obtained.

147. Each of these defendants did knowingly present, or cause or be presented, a false
or fraudulent claim for payment or approval, to the injury of the United States, by falsely
certifying that it was eligible for a second-draw PPP Loan and forgiveness thereof and thereby
receiving the same.

148. Each of these defendants did knowingly make, use, or cause to be made or use, a
false record or statement material to a false or fraudulent claim, to the injury of the United States,
by falsely certifying that it was eligible for a second-draw PPP Loan and forgiveness thereof and
thereby receiving the same.

149. Each of these defendants did knowingly make, use, or cause to be made or used, a
false record or statement material to, or did knowingly conceal, or did knowingly and improperly
avoid or decrease, an obligation to pay or transmit money or property to the United States
government, by falsely certifying that it was eligible for a second-draw PPP Loan and
forgiveness thereof and thereby receiving the same.

Prayer for Relief
150. WHEREFORE, Relator prays for the following relief against each defendant:

a. A declaration that each defendant did violate the False Claims Act;

26

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 27 of 42

b. An amount thrice the amount of PPP Loans and interest forgiven or
otherwise not repaid with respect to each defendant, lending fees paid by
SBA, foregone interest, and all other damages suffered by the United
States government, plus civil penalties and applicable interest, under 31
U.S.C. § 3729(a)(1);

c, The cost of this civil action, apportioned to each defendant respectively in
proportion to its share of the aggregate damages recouped herein, under 31
U.S.C. § 3729(a)(3);

d. An award to relator, including its reasonable expenses, attorneys’ fees, and
costs, under 31 U.S.C. § 3730(d)(1) or (2), as applicable; and

e. Such other and further relief as may be just and proper.

Demand for Jury Trial

151. Relator demands a trial by jury.

Respectfully submitted,

Derek T. Ho, Esq. Bruce Ellis Fein, Esq.

Massachusetts State Bar No. 652627 Pro hac vice admission pending
Kellogg, Hansen, Todd, Figel & Frederick, PLLC Law Office of Bruce Ellis Fein, PLLC
Sumner Square P.O. Box 506

1615 M Street, N.W., Suite 400 Great Falls, VA 22066

Washington, D.C. 20036 bruce@newdream.net

202-326-7900 703-248-0390
dho@kellogghansen.com Attorney for Relator

Attorney for Relator

2

Name
Acoaxet Club Inc.
Acoaxet Club Inc.

Administrators of Special
Education Inc.

Adminstrators of Special
Education Inc.

The Advertising Club Of
Greater Boston Inc. dba The
Ad Club

The Advertising Club Of
Greater Boston Inc. dba The
Ad Club

American Civic Association
Inc. dba Sons of Italy

American Civic Association
Inc. dba Sons of Italy

Amherst Golf Club Inc.

Arlington Chamber of
Commerce Inc.

Arlington Chamber of
Commerce Inc.

Bar Association Of Norfolk
County Inc.

Case 1:24-cv-11950-LTS | Document 1

United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.

Type
501(c)(7)

501(c)(7)

501(c)(6)

501(c)(6)

501(c)(6)

501(c)(6)

501(c)(8)

501(c)(8)

501(c)(7)

501(c)(6)

501(c)(6)

501(c)(6)

Loan No.

8024327705

3575248803

3499357410

4646418602

6537807104

8124848505

3013757206

6083108510

5535637103

4072917200

3143398308

2574527202

Defendants’ PPP Loans
Date

Draw Eligible
Ist 3/11/2021
2nd 3/11/2021
Ist 12/27/2020
2nd 12/27/2020
Ist 12/27/2020
2nd 12/27/2020
Ist 3/11/2021
2nd 3/11/2021
Ist 3/11/2021
Ist 12/27/2020
2nd 12/27/2020
Ist 12/27/2020

Filed 07/26/24

Date
Approved

5/1/2020

4/15/2021

35/7/2020

3/18/2021

4/14/2020

3/9/2021

4/16/2020

3/2/2021

4/13/2020

4/27/2020

1/21/2021

4/16/2020

Page 28 of 42

Loan
Amount

$192,096.00

$120,957.00

$20,877.00

$20,877.00

$269,000.00

$221,455.00

$9,930.00

$9,930.00

$30,000.00

$9,932.00

$9,931.73

$8,100.00

Forgiveness
Date

11/12/2020

8/20/2021

3/25/2021

9/15/2021

2/23/2021

11/9/2021

2/12/2021

9/22/2021

1/14/2021

1/28/2021

10/25/2021

11/12/2020

Amount
Forgiven

$193,090.69

$121,371.24

$21,060.60

$20,979.38

$271,262.55

$222,880.81

$9,998.54

$9,985.44

$30,219.45

$10,006.56

$10,006.29

$8,143.72

Name

Benevolent & Protective
Order of Elks of the USA—
Fal] River Lodge No. 118

Benevolent & Protective
Order of Elks of the USA—
Haverhill Lodge No. 165

Benevolent & Protective
Order of Elks of the USA—
Haverhill Lodge No. 165

Benevolent & Protective
Order of Elks of the USA—
Waltham-Watertown Lodge
No. 953

Berkshire County Board of
Realtors Inc

Bertocci Memorial Club of
Brockton Inc.

Bertocci Memorial Club of
Brockton Inc.

Billerica Lodge No. 2648
Loyal Order of Moose

Boston Madison Square
Garden Club

Boston Madison Square
Garden Club

Case 1:24-cv-11950-LTS Document 1

United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.

Type

501(c)(8)

50 1(c)(8)

501(c)(8)

501(c)(8)

501(c)(6)

501(c)(7)

501(c)(7)

501(c)(8)

501(c)(7)

501(c)(7)

Loan No.

6183517309

4840527401

8998738301

8976137203

9267417304

1253177209

7658898509

8244957403

7558847806

4450188908

Defendants’ PPP Loans
Date

Draw Eligible
Ist 3/11/2021
Ist 3/11/2021
2nd 3/11/2021
Ist 3/11/2021
Ist 12/27/2020
Ist 3/11/2021
2nd 3/11/2021
Ist 3/11/2021
Ist 3/11/2021
2nd 3/11/2021

Filed 07/26/24

Date
Approved

4/30/2020

5/11/2020

1/30/2021

4/28/2020

5/1/2020

4/15/2020

3/6/2021

5/18/2020

6/3/2020

4/29/2021

Page 29 of 42

Loan
Amount

$27,700.00

$17,500.00

$17,582.00

$21,000.00

$30,705.00

$18,750.00

$13,750.00

$5,284.00

$54,800.00

$54,800.00

Forgiveness
Date

Unknown

8/5/2021

8/10/2021

6/16/2021

3/31/2021

7/28/2021

11/3/2021

2/9/2021

5/20/2021

10/22/2021

Amount
Forgiven

Unknown

$17,716.81

$17,673.33

$21,236.47

$30,986.46

$18,990.10

$13,838.61

$5,322.46

$55,301.46

$55,052.23

Name

Bridgewater Citizens’ Club
Inc.

Brockton Country Club Inc.

Builders and Remodelers
Association of Greater Boston
Inc.

Builders and Remodelers
Association of Greater Boston
Inc.

Cambridge Chamber Of
Commerce

Cambridge Chamber Of
Commerce

Cape Cod Cranberry
Growers’ Association

Cape Cod Cranberry
Growers’ Association

Club Franco American de
Westford Massachusetts

Club Franco American de
Westford Massachusetts

Clube Desportivo Faialense
Inc,

Cohasse Country Club

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 30 of 42

United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.

Defendants’ PPP Loans
Date Date Loan Forgiveness
Type Loan No. Draw Eligible Approved Amount Date

501(c)(7) 3300107300 Ist 3/11/2021 4/29/2020 $14,200.00 8/18/2021
501(c)(7) 1747607305 Ist 3/11/2021 4/28/2020 $39,642.12 9/28/2021
501(c)(6) 1709018104 Ist 12/27/2020 7/10/2020 $50,900.00 11/17/2020
501(c)(6) 5390718500 2nd 12/27/2020 2/27/2021 $50,900.00 6/23/2021
501(c)(6) 5765007206 Ist 12/27/2020 4/27/2020 $77,500.00 5/10/2021
501(c)(6) 5388768309 2nd 12/27/2020 1/25/2021 $98,028.33 10/6/2021
501(c)(5) 2427227304 Ist 3/11/2021 4/29/2020 $58,873.00 11/17/2021
501(c)(5) 3193008806 2nd 3/11/2021 4/14/2021 $60,238.00 1/3/2022
501(c)(7) 1872287402 Ist 3/11/2021 5/5/2020 $8,900.00 12/10/2020
501(c)(7) 6219918408 2nd 3/11/2021 2/10/2021 $9,375.00 9/22/2021
501(c)(7) 3795418002 Ist 3/11/2021 6/25/2020 $14,219.37 6/3/2021
501(c)(7) 1069827203 Ist 3/11/2021 4/15/2020 $77,000.00 5/6/2021

Amount
Forgiven

$14,381.68

$40,208.12

$51,068.25

$51,047.04

$78,287.74

$98,705.13

$59,771.42

$60,630.78

$8,952.41

$9,430.99

$14,352.21

$77,812.19

Name

Concord Chamber of
Commerce

Concord Chamber of
Commerce

Construction Industries of
Massachusetts Inc.

Cottage Park Yacht Club Inc.
Cottage Park Yacht Club Inc.

Curve Triangle & Rectangle
Institute Inc.

Dennis Yacht Club Inc.
Dennis Yacht Club Inc.
Edgewood Club Inc.
Ellinwood Country Club Inc.

Employers Association of the
Northeast Inc.

Employers Association of the
Northeast Inc.

Everett Chamber of
Commerce Inc.

Everett Chamber of
Commerce Inc.

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 31 of 42

United States of America ex rel. The Tarbell Group, LLC vy. Acoaxet Club Inc., et al.

Defendants’ PPP Loans
Date Date Loan Forgiveness
Type Loan No. Draw Eligible Approved Amount Date

501(c)(6) 5938017404 ist 12/27/2020 5/13/2020 $7,220.00 10/22/2020
501(c)(6) 3878998508 2nd 12/27/2020 2/24/2021 $7,220.00 5/16/2022
501(c)(6) 9147017210 Ist 12/27/2020 4/28/2020 $95,000.00 8/26/2021
501(¢)(7) 2648048200 Ist 3/11/2021 8/3/2020 $48,600.00 6/2/2021
501(c)(7) 2551938407 2nd 3/11/2021 2/3/2021 $48,600.00 10/6/2021
501(c)(6) 8677897306 Ist 12/27/2020 5/1/2020 $24,225.00 1/25/2021
501(c)(7) 2980197401 Ist 3/11/2021 5/6/2020 $62,680.00 2/4/2021
501(c)(7) 4440278406 2nd 3/11/2021 2/6/2021 $49,725.00 10/25/2021
501(c)(7) 4595348408 Ist 3/11/2021 2/6/2021 $27,377.00 12/14/2021
501(c)(7) 8072197000 Ist 3/11/2021 4/8/2020 $31,565.00 2/16/2021
501(c)(6) 1058497303 Ist 12/27/2020 4/28/2020 $434,000.00 11/12/2020
501(c)(6) 3010768406 2nd 12/27/2020 2/4/2021 $417,098.57 6/23/2021
501(c)(6) 6114697204 Ist 12/27/2020 4/27/2020 $7,800.00 2/17/2021
501(c)(6) 8218418408 2nd 12/27/2020 2/13/2021 $7,856.22 10/25/2021

Amount
Forgiven

$7,251.09

$7,307.44

$96,241.51

$48,998.12

$48,907.58

$24,399.55

$63,144.88
$50,077.22
$27,605.77

$31,753.98

$405,678.82

$418,618.41

$7,861.55

$7,906.59

Name
Fall River Country Club
Fall River Country Club
The Fay Club
The Fay Club

Forestdale Cemetery
Association

Grand Lodge of Theta Delta
Chi Inc.

Grand Lodge of Theta Delta
Chi Inc.

Greater Chicopee Chamber of
Commerce Inc.

Greater Chicopee Chamber of
Commerce Inc.

Greenfield Lodge No. 997
Loyal Order of Moose

Gremio Lusitano Club Inc.

Greylock Community Club
Inc.

Greylock Community Club
Inc.

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 32 of 42

United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.
Defendants’ PPP Loans

Date Date Loan Forgiveness
Type Loan No. Draw Eligible Approved Amount Date
501(c)(7) 5181307002 Ist 3/11/2021 4/5/2020 $3 14,400.00 1/20/2021
501(c)(7) 6259378308 2nd 3/11/2021 1/26/2021 $253,032.50 1/28/2022
501(c)(7) 9463407004 Ist 3/11/2021 4/9/2020 $41,500.00 4/5/2021
501(c)(7) 1796328808 2nd 3/11/2021 4/11/2021 $44,005.00 8/23/2022
501(c)(13) 9450517809 Ist 3/11/2021 6/8/2020 $50,700.00 7/22/2021
501(c)(7) 9334437300 Ist 3/11/2021 5/1/2020 $24,581.00 5/13/2021
501(c)(7) 8347738602 2nd 3/11/2021 3/24/2021 $27,200.00 9/1/2021
501(c)(6) 6772447408 ist 12/27/2020 5/15/2020 $13,460.00 3/1/2021
501(c)(6) 5005908307 2nd 12/27/2020 1/23/2021 $13,460.00 10/6/2021
501(c)(8) 9078527205 Ist 3/11/2021 4/28/2020 $13,815.00 5/6/2021
501(c)(7) 1523568401 Ist 3/11/2021 2/2/2021 $14,870.00 1/11/2022
501(c)(7) 5947458002 Ist 3/11/2021 6/29/2020 $17,400.00 1/7/2021
501(c)(7) 8342198509 2nd 3/11/2021 3/9/2021 $15,623.00 8/9/2021

Amount
Forgiven

$249,680.56
$255,542.03
$41,902.32

$44,611.29

$51,252.84

$24,832.20

$27,318.49

$13,565.81

$13,547.86

$13,953.53

$15,010.44

$17,488.93

$15,686.79

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 33 of 42

United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.

Name

H. E. Fletcher Social &
Athletic Club Inc.

H. E. Fletcher Social &
Athletic Club Inc.

Hampden County Bar
Association Inc.

Hampden County Bar
Association Inc.

Harvard Square Business
Association Inc.

Holyoke Canoe Club Inc.
Holyoke Canoe Club Inc.

International Brotherhood Of
Electrical Workers Building
Corporation

International Brotherhood Of
Electrical Workers Local 103

International Brotherhood Of
Electrical Workers Local 103

Irish-American Club Inc, of
Woburn

Irish-American Club Inc. of
Woburn

Defendants’ PPP Loans
Date Date Loan Forgiveness
Type Loan No. Draw Eligible Approved Amount Date

501(c)(7) 8742027104 Ist 3/11/2021 4/15/2020 $17,029.00 12/31/2020
501(c)(7) 6694768301 2nd 3/11/2021 1/27/2021 $17,035.00 12/8/2021
501(c)(6) 8283407209 Ist 12/27/2020 4/28/2020 $103,000.00 4/6/2021
501(c)(6) 6337348502 2nd 12/27/2020 3/3/2021 $58,107.00 1/19/2022
501(c)(6) 4777887204 Ist 12/27/2020 4/27/2020 $52,500.00 4/12/2021
501(c)(7) 1192927400 Ist 3/11/2021 5/4/2020 $8,800.00 12/17/2020
501(c)(7) 3534228507 2nd 3/11/2021 2/24/2021 $8,352.50 1/12/2022
501(c)(2) 6674497103 Ist 3/11/2021 4/14/2020 $166,200.00 12/17/2020
501(c)(5) 8981297101 Ist 3/11/2021 4/15/2020 $1,102,500.00 Unknown
501(c)(5) 7175648608 2nd 3/11/2021 3/23/2021 $1,294,471.00 12/15/2022
501(c)(7) 8490947210 Ist 3/11/2021 4/28/2020 $17,517.00 11/2/2020
501(c)(7) 1797418410 2nd 3/11/2021 2/2/2021 $16,100.00 1/18/2022

Amount
Forgiven

$17,147.50

$17,180.61

$66,877.63

$58,608.47

$52,989.04

$8,854.25

$8,425.96

$167,238.75

Unknown

$1,3 16,636.60

$17,604.10

$16,253.40

Name

Italian Naturalization Club
Inc. of Taunton

John Alden Sportsmen’s Club
Inc.

John Alden Sportsmen’s Club
Inc.

Jubilee Yacht Club

Knights of Columbus dba
Cardinal Spellman Council
347

Knights of Columbus dba
Cardinal Spellman Council
347

Lafayette Naturalization Club
Inc.

Lakeville Aerie No. 3944
Fraternal Order of Eagles

Lakeville Aerie No. 3944
Fraternal Order of Eagles

Lenox Chamber of Commerce
Lexington Golf Club

Longwood Covered Courts
Trust

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 34 of 42

United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.

Defendants’ PPP Loans
Date Date Loan Forgiveness
Type Loan No. Draw Eligible Approved Amount Date

501(c)(7) 4358648400 Ist 3/11/2021 2/6/2021 $19,815.00 5/10/2022
501(c)(7) 8718727200 Ist 3/11/2021 4/28/2020 $27,293.00 12/17/2020
501(c)(7) 5403658506 2nd 3/11/2021 2/27/2021 $27,292.00 9/1/2021
501(c)(7) 9738897000 Ist 3/11/2021 4/9/2020 $65,600.00 Unknown
501(c)(8) 5796807910 Ist 3/11/2021 6/16/2020 $11,729.00 2/3/2022
501(c)(8) 6905598506 2nd 3/11/2021 3/4/2021 $11,310.00 2/3/2022
501(c)(7) 1756868409 Ist 3/11/2021 2/2/2021 $16,200.00 12/28/2021
501(c)(8) 1258607206 Ist 3/11/2021 4/15/2020 $16,250.00 2/16/2021
501(c)(8) 4962688702 2nd 3/11/2021 4/1/2021 $14,917.00 9/27/2021
501(c)(6) 4044067807 Ist 12/27/2020 5/27/2020 $10,715.00 11/12/2020
501(c)(7) 3956757201 Ist 3/11/2021 4/27/2020 $12,800.00 11/27/2020
501(c)(7) 1282337404 Ist 3/11/2021 5/4/2020 $12,148.42 5/20/2021

Amount
Forgiven

$20,063.24

$27,373.78

$27,429.22

Unknown

$11,917.31

$11,413.49

$10,153.02

$15,037.58

$14,989.51

$10,763.73

$12,875.02

$12,275.30

Name
Ludlow Country Club Inc.

Ludlow Fish & Game Club
Inc.

Ludlow Fish & Game Club
Inc.

Ludlow Tennis Club Inc.

Malden Lodge No. 1910
Loyal Order of Moose

Malden Lodge No. 1910
Loyal Order of Moose

Marblehead Yacht Club Inc.
Marshfield Country Club

Massachusetts Association of
Accountants Inc.

Massachusetts Association of
Accountants Inc.

Massachusetts Chiefs of
Police Association Inc.

Massachusetts Chiefs of
Police Association Inc.

Massachusetts Farm Bureau
Federation Inc.

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 35 of 42

United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.

Defendants’ PPP Loans
Date Date Loan Forgiveness
Type Loan No. Draw Eligible Approved Amount Date

501(c)(7) 4339237110 Ist 3/11/2021 4/13/2020 $26,100.00 7/20/2021
501(c)(7) 2807187405 Ist 3/11/2021 5/6/2020 $15,917.00 6/17/2021
501(¢)(7) 6016288300 2nd 3/11/2021 1/26/2021 $7,335.00 10/25/2021
501(c)(7) 4846367402 Ist 3/11/2021 5/11/2020 $26,300.00 8/24/2021
501(c)(8) 6714318010 ist 3/11/2021 6/30/2020 $6,625.00 3/22/2021
501(c)(8) 9706708601 2nd 3/11/2021 3/26/2021 $6,625.00 9/28/2021
501(c)(7) 8043577204 Ist 3/11/2021 4/28/2020 $27,265.00 3/2/2021
501(c)(7) 7167867009 Ist 3/11/2021 4/7/2020 $366,490.00 6/23/2021
501(c)(6) 1856317300 Ist 12/27/2020 4/28/2020 $16,800.00 6/14/2021
501(c)(6) 1890198606 2nd 12/27/2020 3/13/2021 $16,852.50 12/28/2021
501(c)(6) 3763237104 ist 12/27/2020 4/12/2020 $60,400.00 4/22/2021
501(c)(6) 6740638506 2nd 12/27/2020 3/4/2021 $58,400.00 11/26/2021
501(c)(5) 1838017202 Ist 3/11/2021 4/15/2020 $135,367.00 12/31/2020

Amount
Forgiven

$26,428.43

$16,093.18

$7,387.65

$26,637.52

$6,673.03

$6,658.31

$27,489.84

$370,817.59

$16,985.49

$16,987.32

$61,014.07

$58,808.80

$136,301.59

Name

Massachusetts LGBT
Chamber Of Commerce

Massachusetts LGBT
Chamber Of Commerce

Massachusetts Laborers’
Health & Welfare Fund

Massachusetts Systems
Contractors Association Inc.

Massachusetts Systems
Contractors Association Inc.

Master, Wardens, and
Members of The Grand Lodge
of Masons in Massachusetts

Milton Hoosic Club Inc.

Minute Man Sportsmans Club
Inc.

Nabnasset Lake Country Club
Inc.

Nabnasset Lake Country Club
Inc.

National Board Of Trial
Advocacy Inc.

New Bedford Sports Club Inc.

Case 1:24-cv-11950-LTS Document 1

United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.

Type

501(c)(6)

501(c)(6)

501(c)(9)

501(c)(6)

501(c)(6)

501(c)(10)

501(c)(7)

501(¢)(7)

501(c)(7)

501(¢)(7)

50 1(c)(6)

501(c)(7)

Loan No.

7520967104

2064048403

9747417009

2069077208

2292448407

9342647108

9188897103

9630277109

8650027303

1792028401

5112067706

2424928510

Defendants’ PPP Loans
Date

Draw Eligible
Ist 12/27/2020
2nd 12/27/2020
Ist 3/11/2021
Ist 12/27/2020
2nd 12/27/2020
Ist 3/11/2021
Ist 3/11/2021
Ist 3/11/2021
Ist 3/11/2021
2nd 3/11/2021
Ist 12/27/2020
Ist 3/11/2021

Filed 07/26/24

Date
Approved

4/14/2020

2/3/2021

4/9/2020

4/15/2020

2/3/2021

4/15/2020

4/15/2020

4/15/2020

5/1/2020

2/2/2021

5/1/2020

2/20/2021

Page 36 of 42

Loan
Amount

$95,000.00

$55,252.00

$500,000.00

$22,300.00

$22,300.00

$266,600.00

$181,660.00

$19,600.00

$64,400.00

$64,471.00

$58,777.00

$3,045.00

Forgiveness
Date

4/12/2021

3/22/2022

7/21/2021

10/13/2020

8/18/2021

Unknown

4/29/2021

2/11/2021

10/8/2020

8/13/2021

3/19/2021

8/11/2021

Amount
Forgiven

$95,897.95

$55,860.53

$506,402.78

$22,402.21

$22,417.92

Unknown

$183,522.02

$19,755.71

$64,675.49

$64,807.68

$59,292.91

$3,058.51

Name

New Bedford Sports Club Inc.

The New England Affordable
Housing Management
Association Ine.

The New England Affordable
Housing Management
Association Inc.

North of Boston Convention
& Visitors Bureau Inc.

North of Boston Convention
& Visitors Bureau Inc.

The North Shore Chamber of
Commerce, Inc.

The North Shore Chamber of
Commerce, Inc.

North Shore Skating Club Inc.

North Shore Tennis & Squash
Club Ine.

North Shore Tennis & Squash
Club Inc.

Oak Grove Cemetery
Association of Falmouth Inc.

The Old Colony Yacht Club

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 37 of 42

United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.

Defendants’ PPP Loans
Date Date Loan Forgiveness
Type Loan No. Draw Eligible Approved Amount Date
501(c)(7) 3520158901 2nd 3/11/2021 4/28/2021 $4,263.00 8/13/2021
501(c)(6) 1413488008 Ist 12/27/2020 6/22/2020 $31,000.00 3/1/2021
501(c)(6) 3339878410 2nd 12/27/2020 2/4/2021 $31,000.00 10/25/2021
501(c)(6) 8511777109 Ist 12/27/2020 4/15/2020 $54,070.00 2/23/2021
501(c)(6) 9739328710 2nd 12/27/2020 4/9/2021 $51,620.00 10/6/2021
501(c)(6) 5431667107 Ist 12/27/2020 4/13/2020 $81,250.00 5/13/2021
501(c)(6) 6966438410 2nd 12/27/2020 2/11/2021 $67,000.00 10/20/2021
501(c)(7) 9663987204 Ist 3/11/2021 4/28/2020 $10,825.87 11/19/2020
501(c)(7) 4450347400 Ist 3/11/2021 5/9/2020 $12,615.00 3/18/2021
501(o)(7) 9208768300 2nd 3/11/2021 1/30/2021 $12,615.00 12/23/2021
501(c)(13) 8719457204 Ist 3/11/2021 4/28/2020 $5,209.00 1/29/2021
501(c)(7) 8480977106 Ist 3/11/2021 4/15/2020 $25,700.00 9/7/2021

10

Amount
Forgiven

$4,274.80

$31,205.53

$31,219.97

$54,529.59

$51,870.93

$82,098.61

$67,463.42

$10,885.41

$12,723.63

$12,728.53

$5,246.33

$26,054.09

Name
The Old Colony Yacht Club
Orleans Yacht Cfub Inc.
Orleans Yacht Club Inc.

Outdoor Amusement Business
Association Inc.

Outdoor Amusement Business
Association Inc.

Palmer’s Cove Yacht Club
Inc.

Pine Grove Cemetery
Corporation

Pleasant Park Yacht Club Inc.

The Plymouth Area Chamber
of Commerce Inc.

The Plymouth Area Chamber
of Commerce Inc.

Plymouth Country Club Inc.
Plymouth Country Club Inc.

Point Independence Yacht
Club Inc.

Polish American Veterans of
Webster Inc.

Case 1:24-cv-11950-LTS Documenti1 Filed 07/26/24 Page 38 of 42

United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.

Defendants’ PPP Loans
Date Date Loan Forgiveness
Type Loan No. Draw Eligible Approved Amount Date

501(c)(7) 4251608508 2nd 3/11/2021 2/25/2021 $25,700.00 11/15/2021
501(c)(7) 1668537201 Ist 3/11/2021 4/15/2020 $36,997.00 12/22/2020
501(c)(7) 6205518307 2nd 3/11/2021 1/26/2021 $36,997.50 10/7/2021
501(c)(6) 6201077705 ist 12/27/2020 5/1/2020 $61,013.00 3/24/2021
501(c)(6) 8580698403 2nd 12/27/2020 2/13/2021 $61,012.00 8/18/2021
501(c)(7) 1541987210 Ist 3/11/2021 4/15/2020 $20,337.50 4/6/2021
501(c)(13) 7732157001 Ist 3/11/2021 4/8/2020 $2,500.00 6/4/2021
501(c)(7) 8954887705 Ist 3/11/2021 5/1/2020 $13,871.00 3/11/2021
501(c)(6) 4087557104 Ist 12/27/2020 4/12/2020 $58,062.50 12/16/2020
501(c)(6) 4945728405 2nd 12/27/2020 2/7/2021 $56,675.00 11/15/2021
501(c)(7) 8546087103 Ist 3/11/2021 4/15/2020 $329,595.00 8/2/2021
501(c)(7) 9216188510 2nd 3/11/2021 3/12/2021 $329,595.00 11/26/2021
501(c)(7) 9529387004 Ist 3/11/2021 4/9/2020 $19,382.00 4/8/2021
501(c)(7) 6291328500 Ist 3/11/2021 3/3/2021 $13,811.48 9/8/2021

1]

Amount
Forgiven

$25,882.76
$37,237.48

$37,255.45

$61,557.94

$61,319.57

$20,534.10

$2,528.12

$13,985.77

$58,446.36

$57,109.51

$333,839.10

$331,888.62

$19,569.98

$13,881.69

Name

The Polish Club Lodge 2058
Inc.

The Polish Club Lodge 2058
Inc.

Portuguese National Club

Prince Hall Masonic Grand
Lodge

The Proprietors of Forest
Hills Cemetery

Realtor Association of Central
Massachusetts

Rowley Veterans’ Association
Inc.

Salem Chamber of Commerce
& Civics

Salem Chamber of Commerce
& Civics

Salem Office of Tourism &
Cultural Affairs Inc. dba
Destination Salem

Salem Office of Tourism &
Cultural Affairs Inc. dba
Destination Salem

Sandy Bay Yacht Club, Inc.

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 39 of 42

United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.

Defendants’ PPP Loans
Date Date Loan Forgiveness
Type Loan No. Draw Eligible Approved Amount Date

501(c)(8) 5270307407 Ist 3/11/2021 5/12/2020 $10,000.00 2/17/2021
501(c)(8) 1945808510 2nd 3/11/2021 2/19/2021 $13,762.00 1/26/2022
501(c)(7) 8053438404 Ist 3/11/2021 2/12/2021 $5,629.70 9/15/2021
501(c)(8) 5101678201 Ist 3/11/2021 8/7/2020 $4,865.00 10/12/2021
501(c)(13) 4199537201 Ist 3/11/2021 4/27/2020 $385,180.00 Unknown
501(c)(6) 6237267106 Ist 12/27/2020 4/14/2020 $60,200.00 10/13/2020
501(c)(7) 1657787200 Ist 3/11/2021 4/15/2020 $26,006.00 9/24/2021
501(c)(6) 8915957002 Ist 12/27/2020 4/9/2020 $49,000.00 2/11/2021
501(c)(6) 3052288304 2nd 12/27/2020 1/21/2021 $49,000.00 9/7/2021
501(c)(6) 5401847308 Ist 12/27/2020 4/30/2020 $38,228.00 2/25/2021
501(c)(6) 9560608504 2nd 12/27/2020 3/12/2021 $36,551.00 9/22/2021
501(c)(7) 1883257105 Ist 3/11/2021 4/10/2020 $24,400.00 12/23/2020

12

Amount
Forgiven

$10,071.67

$13,890.83

$5,662.07

$4,921.11

Unknown

$60,480.93

$2,102.60

$49,408.33

$49,299.44

$38,536.97

$36,737.26

$24,567.12

Name

Singletary Rod & Gun Club
Inc.

Singletary Rod & Gun Club
Inc,

Sons of Italy in America—
Grand Lodge of
Massachusetts

Sons of Italy in America—
Methuen Lodge No. 902

Sons of Italy in America—
Quincy Lodge No. 1295

Sons of Italy in America—
Quincy Lodge No. 1295

Stockbridge Golf Club

Stoneham Chamber of
Commerce Inc.

Stoneham Chamber of
Commerce Inc.

Supreme Council of the Royal
Arcanum

Swampscott Yacht Club
Swampscott Yacht Club

Tennis and Racquet Club

Case 1:24-cv-11950-LTS Document 1

United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.

Type

501(c)(7)

501(c)(7)

501(c)(8)

501(c)(8)

501(c)(8)

501(c)(8)

501(c)(7)

501(c)(6)

501(c)(6)

501(c)(8)

501(c)(7)
501(c)(7)

501(c)(7)

Loan No.

6146637409

1541498800

9439897708

7790557208

9753217102

8740638407

7454647005

9731177407

1349128500

1305588104

4606967210

4460018504

7271127304

Defendants’ PPP Loans
Date

Draw Eligible
Ist 3/11/2021
2nd 3/11/2021
Ist 3/11/2021
Ist 3/11/2021
Ist 3/11/2021
2nd 3/11/2021
Ist 3/11/2021

Ist 12/27/2020

2nd 12/27/2020
Ist 3/11/2021
Ist 3/11/2021
2nd 3/11/2021
Ist 3/11/2021

13

Filed 07/26/24

Date
Approved

5/14/2020

4/10/2021

5/1/2020

4/28/2020

4/15/2020

2/13/2021

4/7/2020

5/20/2020

2/18/2021

7/9/2020

4/27/2020
2/25/2021

4/30/2020

Page 40 of 42

Loan
Amount

$15,212.00

$15,212.52

$17,600.00

$13,800.00

$27,000.00

$27,165.00

$162,720.00

$12,709.48

$12,709.48

$300,000.00

$6,890.00
$6,897.00

$132,525.00

Forgiveness
Date

2/12/2021

8/20/2021

5/17/2021

Unknown

1/13/2021

8/10/2021

Unknown

5/5/2021

5/5/2022

1/8/2021

5/13/2021
11/10/2021

4/29/2021

Amount
Forgiven

$15,325.78

$15,266.61

$17,780.34

Unknown

$27,358.93

$27,291.77

Unknown

$12,831.00

$12,862.34

$301,425.00

$6,962.34
$6,941.26

$133,821.20

Name
Tennis and Racquet Club
Town River Yacht Club
Town River Yacht Club
Volunteer Yacht Club

Wampatuck Country Club of
Canton Inc.

Wayland Swimming and
Tennis Club Inc.

Wequaquet Lake Yacht Club
Wequaquet Lake Yacht Club
West Dennis Yacht Club Inc.
West Dennis Yacht Club Inc.

West End Beagle Club Inc. of
Gardner

Whitinsville Golf Club
Winthrop Golf Club
Winthrop Yacht Club Inc.

Wood Products
Manufacturers Association _

Case 1:24-cv-11950-LTS Document 1

United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.
Defendants’ PPP Loans

Type
501(c)(7)
501(c)(7)
501(c)(7)

501(c)(7)

501(c)(7)

501(c)(7)

501(c)(7)
501(c)(7)
501(c)(7)

501(c)(7)

501(c)(7)}

501(c)(7)
501(c)(7)

501(c)(7)

501(c)(6)

Loan No.

6528838303

4476837305

1687478307

5889208510

6477477305

5801547300

83 15677803

6533428303

8141687304

9785768409

8457908508

5948197002

7970937800

2707777201

6322577709

Draw

2nd

Ist

2nd

Ist

Ist

Ist

Ist

2nd

Ist

2nd

Ist

Ist

Ist

Ist

Ist

Date
Eligible

3/11/2021
3/11/2021
3/11/2021

3/11/2021

3/11/2021

3/11/2021

3/11/2021
3/11/2021
3/11/2021

3/11/2021

3/11/2021

3/11/2021
3/11/2021

3/11/2021

12/27/2020

Filed 07/26/24

Date
Approved

1/27/2021
4/29/2020
1/19/2021

3/2/2021

4/30/2020

4/30/2020

6/5/2020
1/27/2021
5/1/2020

2/17/2021

3/9/2021

4/6/2020
6/4/2020

4/16/2020

3/1/2020

Page 41 of 42

Loan
Amount

$109,105.00
$29,822.00
$22,100.00

$7,005.00

$79,300.00

$29,685.00

$8,660.00
$12,124.00
$41,272.00

$41,272.00

$10,860.06

$101,800.00
$45,401.00

$90,400.00

$57,091.00

Forgiveness
Date

8/11/2021
11/5/2020
6/15/2021

11/19/2021

2/11/2021

11/27/2020

1/7/2021
11/15/2021
3/10/2021

11/10/2021

12/8/2021

3/25/2021
11/17/2021

6/14/2021

1/14/2021

Amount
Forgiven

$109,672.94
$29,977.74
$22,189.01

$7,054.62

$79,918.98

$29,846.03

$8,708.59
$12,216.61
$41,612.35

$41,570.52

$10,939.44

$102,769.93
$46,060.25

$91,415.45

$57,488.29

Case 1:24-cv-11950-LTS Document1 Filed 07/26/24 Page 42 of 42

United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.

Defendants’ PPP Loans
Date Date Loan Forgiveness Amount
Name Type Loan No. Draw Eligible Approved Amount Date Forgiven
Wood Products = 501(c)(6) 5392498510 2nd 12/27/2020 2/27/2021 $57,090.00 9/22/2021 $57,404.39
Manufacturers Association
vee County Memorial 501(c)(13) 8270767006 Ist 3/11/2021 4/8/2020 $210,982.50 2/16/2021 $212,205.29
be Men's Club of Hadley 501(c)(7) 9798257107 Ist 3/11/2021 4/15/2020 $25,800.00 8/24/2021 $26,144.94
ae Men's Club of Hadley 501(c)(7) 6134308305 2nd 3/11/2021 1/26/2021 $25,800.00 3/28/2022 $26,094.05

15

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