Stipulation of Dismissal — United States ex rel. GNGH2 v. Coyne Public Relations (District of New Jersey)

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A Stipulation of Dismissal in United States of America ex rel. GNGH2 Inc. versus Coyne Public Relations, LLC, Civil Action No. 21-20422 (MCA) (CLW), in the United States District Court for the District of New Jersey, dated May 10, 2023. Under the qui tam provisions of the False Claims Act, 31 U.S.C. § 3730(b)(1), the United States and Relator GNGH2 Inc. stipulate to dismissal of the action against Coyne Public Relations, LLC with prejudice. It states that the parties have executed written settlement agreements resolving all claims, and the Relator stipulates that its settlement amount is fair, adequate and reasonable. It is signed by Assistant United States Attorney David E. Dauenheimer for United States Attorney Philip R. Sellinger.

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Case 2:21-cv-20422-MCA-CLW             Document 11     Filed 05/10/23   Page 1 of 2 PageID: 62




 PHILIP R. SELLINGER
 United States Attorney
 DAVID E. DAUENHEIMER
 Assistant United States Attorney
 970 Broad Street, Suite 700
 Newark, NJ 07102
 Tel. (973) 645-2925
 david.dauenheimer2@usdoj.gov

                          UNITED STATES DISTRICT COURT
                             DISTRICT OF NEW JERSEY


   UNITED STATES OF AMERICA ex rel.                  HON. MADELINE C. ARLEO
   GNGH2 INC.,
                                                     Civil Action No. 21-20422 (MCA) (CLW)
                          Plaintiff,
                                                     Stipulation of Dismissal
                 v.

   COYNE PUBLIC RELATIONS, LLC,

                          Defendants.


       Pursuant to Rule 41(a) of the Federal Rules of Civil Procedure and the qui

 tam provisions of the False Claims Act, 31 U.S.C. § 3730(b)(1), and in accordance

 with the terms of the settlement agreements between the parties, the United States

 and Relator, GNGH2 Inc., stipulate to the dismissal of the civil action against

 Defendant, Coyne Public Relations, LLC.

       1.     The Parties have executed written settlement agreements to resolve all

 claims in this action.

       2.     Relator stipulates that the settlement agreement and settlement

 amount allocated to it in this action are fair, adequate, and reasonable under all the

 circumstances as defined by 31 U.S.C. § 3730(c)(2)(B).
Case 2:21-cv-20422-MCA-CLW       Document 11     Filed 05/10/23   Page 2 of 2 PageID: 63




       3.      Accordingly, the Parties request that pursuant to FED. R. CIV. P. 41(a)

 and 31 U.S.C. § 3730(b)(1), the Civil Action be dismissed with prejudice. All parties

 shall bear their own costs except as otherwise agreed.

       The parties respectfully request that the Court enter an order in the form of

 the proposed order attached.

 Dated:     Newark, New Jersey
            May 10, 2023
                                                Respectfully submitted,

                                                PHILIP R. SELLINGER
                                                United States Attorney

                                         By:    /s/ David E. Dauenheimer
                                                DAVID E. DAUENHEIMER
                                                Assistant United States Attorney




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