Joint Stipulation of Dismissal — United States ex rel. GNGH2, Inc. v. Dynamic Staffing in Virginia, Inc.

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A Joint Stipulation of Dismissal filed November 5, 2025 as Document 8 in United States of America ex rel. GNGH2, Inc. versus Dynamic Staffing in Virginia, Inc., Case 3:25-cv-00200-REP, in the United States District Court for the Eastern District of Virginia, Richmond Division. The United States, having intervened in part for purposes of settlement in this qui tam action under the False Claims Act, 31 U.S.C. §§ 3729-3733, and the Relator give notice of voluntary dismissal under Federal Rule of Civil Procedure 41(a). The Relator dismisses all of its claims with prejudice, and the United States dismisses with prejudice its claims for the Covered Conduct defined in the Settlement Agreement and without prejudice all other claims. The Court would retain jurisdiction to enforce the Settlement Agreement.

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 Case 3:25-cv-00200-REP              Document 8     Filed 11/05/25      Page 1 of 2 PageID# 30




                        IN THE UNITED STATES DISTRICT COURT
                        FOR THE EASTERN DISTRICT OF VIRGINIA
                                   Richmond Division

UNITED STATES OF AMERICA                      )
ex rel. GNGH2, Inc.,                          )
                                              )       CASE NO.: 3:25-cv-200
               Plaintiffs/Relator,            )
                                              )
                       v.                     )
                                              )
DYNAMIC STAFFING IN VIRGINIA,                 )
INC.,                                         )
                                              )
               Defendant.                     )

                             JOINT STIPULATION OF DISMISSAL

       Pursuant to Federal Rule of Civil Procedure 41(a), the United States, having intervened in

part for purposes of settlement in this qui tam action brought pursuant to the False Claims Act,

31 U.S.C. §§ 3729-3733 (“FCA”), and Relator GNGH2, Inc., (“Relator”), hereby notify the

Court of the voluntary dismissal of this action as set forth below:

       1.      Relator dismisses with prejudice all claims alleged in its Complaint as to itself

and against the Defendant named in the Complaint.

       2.      The United States dismisses with prejudice all claims against the Defendant for

the “Covered Conduct,” as that term is defined in the Settlement Agreement, and dismisses

without prejudice claims against the Defendant for all other conduct alleged in the Complaint.

       3.      Except as provided in the Settlement Agreement, the parties shall bear their

respective costs, including any possible attorneys’ fees or other expenses of litigation.

       4.      No Defendant has filed an answer or responsive pleading to the Complaint.
 Case 3:25-cv-00200-REP          Document 8        Filed 11/05/25     Page 2 of 2 PageID# 31




       5.      Pursuant to the Settlement and Kokkonen v. Guardian Life Insurance Co. of

America, 511 U.S. 375 (1994), the Court shall retain jurisdiction to enforce the terms of the

Settlement Agreement.

Dated: November 4, 2025.

                                      LINDSEY HALLIGAN
                                      United States Attorney


                              By:       /s/
                                      ______________________________________
                                      Robert P. McIntosh
                                      VSB No. 66113
                                      Assistant United States Attorney
                                      919 East Main Street, Suite 1900
                                      Richmond, Virginia 23219
                                      Telephone: (804) 819-7404
                                      Facsimile: (804) 771-2316
                                      E-mail: Robert.McIntosh@usdoj.gov
                                      Counsel for the United States of America


                                         /s/
                                      ______________________________________
                                      Damon Miller (VSB #98308)
                                      3998 Fair Ridge Drive, No. 250
                                      Fairfax, VA 22031
                                      Email: dmiller@benglasslaw.com
                                      Telephone: (703) 591-9829
                                      Counsel for Relators




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