Notice of Intervention for the Purpose of Settlement — United States ex rel. Tzac, Inc. v. A Jewish Voice for Peace, Inc. (Dkt. 12, D.D.C.)

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A notice of intervention for the purpose of settlement filed under seal on September 17, 2024 by the United States in United States ex rel. TZAC, Inc. v. A Jewish Voice for Peace, Inc., Civil Action No. 21-3403 (JMC), in the U.S. District Court for the District of Columbia. Citing 31 U.S.C. § 3730(b)(2) and (4) of the False Claims Act, the United States states that it, the relator and the defendant have executed a settlement and that it intervenes for settlement purposes. It describes the alleged conduct: that in January 2021 the defendant falsely certified it was not primarily engaged in political or lobbying activities when it applied for and received a second draw Paycheck Protection Program loan of $338,817.00, and a further alleged false certification on a loan form. It is signed by Assistant United States Attorney Stephen DeGenaro.

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Case 1:21-cv-03403-JMC           Document 12         Filed 09/17/24      Page 1 of 4




                             UNITED STATES DISTRICT COURT
                             FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA,                               )
     ex rel. TZAC, INC.,                                )
                                                        )
                       Plaintiffs,                      )     Civil Action No. 21-3403 (JMC)
                                                        )
                       v.                               )
                                                        )     FILED UNDER SEAL
A JEWISH VOICE FOR PEACE, INC.,                         )
                                                        )
                       Defendant.                       )
                                                        )


           NOTICE OF INTERVENTION FOR THE PURPOSE OF SETTLEMENT

       Pursuant to 31 U.S.C. § 3730(b)(2) and (4), Plaintiff the United States of America

notifies the Court of its decision to intervene in this action for purposes of settlement. The

United States, Relator TZAC, Inc., and Defendant A Jewish Voice For Peace, Inc., have

executed a settlement. For the purpose of effectuating and formalizing that resolution, pursuant

to the False Claims Act, 31 U.S.C. § 3730, the United States respectfully advises the Court of its

decision to intervene for the purposes of settlement.

       Specifically, the United States intervenes in this action as to the following alleged

conduct:

       1.      In January 2021, A Jewish Voice For Peace, Inc. falsely certified that it was “not

a business concern or entity primarily engaged in political or lobbying activities, including any

entity that is organized for research or for engaging in advocacy in areas such as public policy or

political strategy or otherwise describes itself as a think tank in any public documents,” when it

applied for and received a second draw loan in the amount of $338,817.00 under the Paycheck

Protection Program (“PPP”) Disaster Relief Program.

       Case 1:21-cv-03403-JMC            Document 12            Filed 09/17/24   Page 2 of 4




       2.      Further, that A Jewish Voice For Peace, Inc. falsely certified in a loan forgiveness

application that it met the conditions for receiving the second draw PPP loan, when in fact it had

not.

       The United States declines intervention as to all other claims asserted on behalf of the

United States in this action, to the extent that any other claims are asserted in the Relator’s

Complaint. Under the terms and conditions of the Settlement Agreement among the parties, the

United States and Relator will file a Notice of Dismissal of this action and settled claims

following the payment of the settlement amount by A Jewish Voice For Peace, Inc.

       Further, the United States respectfully requests that this Court maintain this case under

seal for an additional ninety days, to December 19, 2024, to permit the parties to complete the

administrative payment process that Defendant must follow pursuant to the settlement

agreement. Once the payment is received, the United States will move to lift the seal over

specified documents in this matter and will dismiss this action.

       The United States requests that all papers on file in this action remain under seal because

in discussing the content and extent of the United States’ investigation, such papers are provided

by law to the Court alone for the sole purpose of evaluating whether the seal and time for making

an election to intervene should be extended.

                                                *       *   *




                                                    2

      Case 1:21-cv-03403-JMC   Document 12     Filed 09/17/24     Page 3 of 4




September 17, 2024                 Respectfully submitted,

                                   MATTHEW M. GRAVES, D.C. Bar #481052
                                   United States Attorney

                                   BRIAN P. HUDAK,
                                   Chief, Civil Division


                                   By:     /s/ Stephen DeGenaro
                                   STEPHEN DEGENARO, D.C. Bar #1047116
                                   DARRELL VALDEZ, D.C. Bar #420232
                                   Assistant United States Attorneys
                                   United States Attorney’s Office – D.C.
                                   Civil Division
                                   601 D Street, N.W.
                                   Washington, D.C. 20530
                                   (202) 252-7229 (DeGenaro)
                                   (202) 252-2507 (Valdez)
                                   Stephen.DeGenaro@usdoj.gov
                                   Darrell.Valdez@usdoj.gov


                                   Counsel for the United States of America




                                      3

       Case 1:21-cv-03403-JMC         Document 12          Filed 09/17/24     Page 4 of 4




                               CERTIFICATE OF SERVICE

       I HEREBY CERTIFY that on this 17th day of September 2024, a true and correct copy

of the above and foregoing Notice of Intervention for the Purpose of Settlement and proposed

Order was served through electronic mail to:

              David Abrams
              The Zionist Advocacy Center
              dnabrams@gmail.com

              Counsel for Relator



                                                Stephen DeGenaro
                                               STEPHEN DEGENARO
                                               Assistant United States Attorney

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