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Complaint and Demand for Jury Trial — United States of America v. Ramzy Peter Hattar and Zedan Outdoors, LLC, No. 3:26-cv-01881-AN (Dkt. 1, D. Or.)
Summary
A complaint and demand for jury trial in United States of America v. Ramzy Peter Hattar and Zedan Outdoors, LLC, No. 3:26-cv-01881, District of Oregon, Document 1, filed September 10, 2026. The United States, at the request of the Small Business Administration, brings two claims under the False Claims Act, 31 U.S.C. § 3729(a)(1)(A) and (B). It alleges that Hattar submitted EIDL and first draw PPP applications for Taylor's Bar & Grill with false certifications, including an EIDL advance of $10,000, EIDL proceeds of $202,500 and a PPP disbursement of $135,700. The complaint seeks treble damages and civil penalties.
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Record facts
| Court | U.S. District Court for the District of Oregon |
|---|---|
| Filed | 2026-09-10 |
Cite this document
“Complaint and Demand for Jury Trial — United States of America v. Ramzy Peter Hattar and Zedan Outdoors, LLC, No. 3:26-cv-01881-AN (Dkt. 1, D. Or.).”
U.S. District Court for the District of Oregon, No. 3:26-cv-01881, Doc. 1, filed 2026-09-10. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/ord-3-26-cv-01881/2026-09-10-complaint/
, SHA-256 7e19451cad2978557d7219ddc0bac319e297ad5024262fa424d3d1da75a42f1b.Full text
Case 3:26-cv-01881-AN Document 1 Filed 09/10/26 Page 1 of 9
SCOTT E. BRADFORD, OSB #062824
United States Attorney
District of Oregon
WILLIAM M. NARUS, CAB #243633
First Assistant United States Attorney
William.Narus@usdoj.gov
STACI SCHOFF, CAB #320692
Special Assistant United States Attorney
Staci.Schoff@usdoj.gov
1000 SW Third Ave., Suite 600
Portland, Oregon 97204-2902
Telephone: (503) 727-1000
Attorneys for Plaintiff United States of America
UNITED STATES DISTRICT COURT
DISTRICT OF OREGON
PORTLAND DIVISION
UNITED STATES OF AMERICA, Case No. 3:26-cv-01881
Plaintiff,
v. COMPLAINT AND
DEMAND FOR JURY
TRIAL
RAMZY PETER HATTAR; and ZEDAN
OUTDOORS, LLC d/b/a Talyor’s Bar &
Grill,
Defendants.
The United States of America, by authority of the Attorney General of the United States
and at the request of the United States Small Business Administration (“SBA”), files this
complaint and alleges as follows:
Case 3:26-cv-01881-AN Document 1 Filed 09/10/26 Page 2 of 9
NATURE OF ACTION
1. This is a civil action brought pursuant to False Claims Act, 31 U.S.C. §§ 3729-33
(“the FCA”), seeking damages and civil penalties arising from false claims presented or caused to
be presented by Defendant Ramzy Peter Hattar (“Hattar”) on behalf of Defendant Zedan Outdoors,
LLC, d/b/a Taylor’s Bar & Grill (“Taylor’s Bar & Grill”) (hereinafter referred to collectively as
“Defendants”) to the SBA in connection with its Paycheck Protection Program (“PPP”) and
Economic Injury Disaster Loan (“EIDL”) program.
JURISDICTION AND VENUE
2. This Court has jurisdiction over the subject matter of and parties to this action
pursuant to 28 U.S.C. §§ 1331, 1345, and 31 U.S.C. § 3732(a).
3. Venue is proper in this jurisdiction pursuant to 28 U.S.C. § 1391(b) because all the
acts alleged occurred in this judicial district and all defendants reside in or are located, registered,
and conduct business in this district.
PARTIES
4. Plaintiff is the United States of America (the “United States”), suing on behalf of the
SBA.
5. Defendant Ramzy Peter Hattar was at all relevant times a resident of the state of
Oregon and the owner, member, and manager of, and registered agent for defendant business
Zedan Outdoors, LLC d/b/a Taylor’s Bar & Grill, a domestic limited liability company formerly
registered to conduct business in the state of Oregon. It was administratively dissolved on or about
October 2, 2025.
COMPLAINT Page 2 of 9
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THE FALSE CLAIMS ACT
6. The False Claims Act, 31 U.S.C. § 3729(a)(1)(A) and (B), provides in pertinent part,
that a person who does any of the following is liable for three times the amount of the
government’s damages and mandatory civil penalties:
a. knowingly presents, or causes to be presented, a false or fraudulent claim for
payment or approval;
b. knowingly makes, uses, or causes to be made or used, a false record or statement
material to a false or fraudulent claim.
7. “Knowingly,” for purposes of the False Claims Act, does not require proof of specific
intent to defraud. Instead, knowingly means that a person:
a. Has actual knowledge of the information;
b. Acts in deliberate ignorance of the truth or falsity of the information; or
c. Acts in reckless disregard of the truth or falsity of the information.
31 U.S.C. § 3729(b)(1).
THE CARES ACT
8. On or about March 27, 2020, the CARES Act, Pub. L. 116-136, became law and
provided emergency financial assistance for individuals, families, and businesses affected by the
COVID-19 pandemic.
9. The EIDL program is an SBA program that provides low-interest loans of up to $2
million to small businesses, renters, and homeowners in regions affected by declared disasters.
COMPLAINT Page 3 of 9
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10. Section 1110 of the CARES Act authorized SBA to, among other things, waive
certain requirements for eligible EIDL borrowers for loans made in response to the COVID-19
pandemic. Section 1110 also authorized SBA to issue advances of up to $10,000 to small
businesses within three days of receiving an application for an EIDL based on the applicant’s
certification that the applicant is eligible. The advances do not have to be repaid.
11. An EIDL applicant was required to certify that all information in the application was
true and correct to the best of the applicant’s knowledge. The application included warnings that
any false statement or misrepresentation to the SBA may result in criminal and civil penalties.
12. EIDL loans obtained pursuant to the CARES Act were required to be used as
working capital to alleviate economic injury caused by disaster occurring in the month of January
2020 and continuing thereafter.
13. To be eligible for an EIDL loan the applicant certified that the funds would not be
used for personal purposes, that the borrower’s ownership in the collateral is free of all adverse
claims, liens, or security interests, and that all of the information in and submitted with the
application is true and correct.
14. The CARES Act also established the Paycheck Protection Program (“PPP”) for the
purpose of providing forgivable loans to small businesses to support job retention and cover other
specified expenses.
15. Congress made the PPP loans available in two separate rounds or “draws”
beginning in or about April 2020 and ending in or about March 2021. Qualified borrowers who
obtained a “first draw” loan were then eligible to apply for a “second draw” loan.
COMPLAINT Page 4 of 9
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16. To be eligible for a PPP loan, the applicant certified that it was in business as of
February 15, 2020 and would use the loan proceeds to retain workers and maintain payroll, or for
other limited, specifically enumerated business operating expenses.
GENERAL ALLEGATIONS
17. Taylor’s Bar & Grill was located in Eugene, Oregon, adjacent to the University of
Oregon. It was founded in 1922. As of February 25, 2020, Taylor’s Bar & Grill was permanently
closed after the Oregon Liquor and Cannabis Commission revoked its liquor license. A note
posted on the door that day stated, “Closed forever. No Trespassing.”
EIDL Loan
18. On or about March 31, 2020, Defendant Hattar submitted an EIDL application
number 3600257824 on behalf of Taylor’s Bar & Grill. In the application Hattar listed Taylor’s
Bar & Grill’s primary place of business as 529 NW 13th Avenue, Portland, Oregon, which is the
location of the River Pig Saloon, a separate business owned by Hattar. On the application Hattar
also falsely certified the following:
• The business has 26 employees;
• The proceeds will be used solely as working capital to alleviate economic
injury caused by disaster occurring in the month of January 2020 and
continuing thereafter;
• The proceeds will not primarily be used for personal, family or household
purposes;
• Borrower’s ownership in or title to the collateral is free of all adverse claims,
COMPLAINT Page 5 of 9
Case 3:26-cv-01881-AN Document 1 Filed 09/10/26 Page 6 of 9
liens, or security interests; and
• All information in the application and submitted with the application is true
and correct.
19. On or about April 13, 2020, Hattar received an EIDL Advance in the amount of
$10,000. On or about April 29, 2021, Hattar recertified the above information in an attempt to
obtain an increase in the EIDL loan amount. On or about May 9, 2020, the SBA disbursed EIDL
proceeds in the amount of $202,500, SBA loan number 23086974-00. The false statements
described above were material to SBA’s approval of the EIDL loan at issue because the SBA
would not have approved the loan had it been aware of the true facts described above.
First Draw PPP Loan
20. On or about May 5, 2020, Hattar submitted a first draw PPP application on behalf
of Taylor’s Bar & Grill. In the PPP application Hattar falsely certified the following:
• Applicant is eligible to receive a loan under the rules;
• Applicant had employees for whom it paid salaries and payroll taxes;
• Funds will be used to retain workers and maintain payroll or make mortgage interest
payments;
• Loan proceeds will be used only for business-related purposes as specified in the
loan application and consistent with the PPP rules; and
• The information provided in this application and the information provided in all
supporting documents and form is true and accurate in all material respects.
21. On or about May 6, 2020, Hattar received the PPP loan disbursement in the amount
COMPLAINT Page 6 of 9
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of $135,700 from Solera National Bank, SBA loan number 4359037302. At the time of
application Taylor’s Bar & Grill had been permanently closed. The first draw PPP loan was not
forgiven or repaid and was charged off by the SBA in the amount of $145,329.12.
22. The false statements described above were material to SBA’s approval of the PPP
loan at issue because the SBA would not have approved the loan had it been aware of the true
facts described above.
23. In total, Defendant fraudulently obtained approximately $348,200.
Second Draw PPP Loan:
24. On or about January 25, 2021, Hattar submitted a second draw PPP application on
behalf of Taylor’s Bar & Grill, containing the same false certifications described above, which
was denied.
FIRST CLAIM FOR RELIEF
False Claims Act – Presenting False or Fraudulent Claims to
the United States, 31 U.S.C. § 3729(a)(1)(A)
25. The United States realleges each of the preceding paragraphs as if fully set forth
herein.
26. Defendants presented to the United States for payment or approval the false or
fraudulent claims as described above, with knowledge that they were false, with deliberate
ignorance of their truth or falsity, or with reckless disregard for their truth or falsity.
27. Defendants’ false statements made in connection with the PPP and EIDL loan and
forgiveness applications were material.
28. Plaintiff United States has sustained damages as a result of Defendants’ false or
COMPLAINT Page 7 of 9
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fraudulent claims in an amount to be determined at trial, and owes the United States treble its
damages and civil penalties for each false and fraudulent claim.
SECOND CLAIM FOR RELIEF
False Claims Act – Making a False Record or Statement Material to
a False or Fraudulent Claim, 31 U.S.C. § 3729(a)(1)(B)
29. The United States realleges each of the preceding paragraphs as if fully set forth
herein.
30. Defendants knowingly made, used, or caused to be made or used, false records or
statements to get false or fraudulent claims paid or approved by the United States, and knowingly
made, used, or caused to be made or used, false records or statements material to false or fraudulent
claims to the United States.
31. Defendants’ false statements made in connection with the PPP and EIDL loan and
forgiveness applications were material.
32. Plaintiff United States has sustained damages as a result of Defendants’ false or
fraudulent claims in an amount to be determined at trial, and owes the United States treble its
damages and civil penalties for each false and fraudulent claim.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff, the United States of America, respectfully prays for judgment
against Defendants as follows:
a. On the First Claim for Relief, treble the amount of actual damages sustained by the
United States, plus such civil penalties as are allowable by law against Defendants;
b. On the Second Claim for Relief, treble the amount of actual damages sustained by
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the United States, plus such civil penalties as are allowable by law against Defendants;
c. An award to the United States of all its costs in this action to the maximum extent
permissible; and
d. Such other and further relief as the Court deems just and proper.
Dated this 10th day of September 2026.
SCOTT E. BRADFORD
United States Attorney
/s/ William M. Narus___
WILLIAM M. NARUS
First Assistant United States Attorney
/s/ Staci Schoff___
STACI SCHOFF
Special Assistant United States Attorney
COMPLAINT Page 9 of 9
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