Complaint — United States ex rel. Sidesolve, LLC v. Empire Roofing, Inc. (No. 3:22-cv-02060, N.D. Tex.)

Summary

A qui tam complaint under the False Claims Act, 31 U.S.C. §§ 3729 et seq., by relator Sidesolve, LLC against Empire Roofing, Inc., its affiliated companies, Ronnie McGlothlin, Sandra Sedillo-McGlothlin and Tecta America Corp., filed under seal September 16, 2022 as Document 2 in Case 3:22-cv-02060-B in the U.S. District Court for the Northern District of Texas. The relator alleges that Empire Roofing received $6,705,700 in PPP funding, all forgiven, including two PPP loans to Empire Roofing, Inc. and a combined eight PPP loans across the Empire Roofing entities. It alleges that the entities were affiliates under the SBA's Affiliation Rules and, upon information and belief, employed more than 500 employees, so they were not eligible. It states that Tecta America Corp. purchased Empire Roofing, except, upon information and belief, SR Disposal, Ltd., in 2021.

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Case 3:22-cv-02060-B Do il@ O Page tof t5--Ragele s7rin 1
APIA AVERT A NORTHERN DISTRICT OF TEXAS

IN THE UNITED STATES DISTRICT CQURT SEP 16 2022
FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION CLERK, US. DISTRIB 4 OURT
y

UNITED STATES OF AMERICA Deputy

ex rel. SIDESOLVE, LLC,

Plaintiff-Relator,

EMPIRE ROOFING, INC.; EMPIRE
ROOFING COMPANIES, INC.; EMPIRE
ROOFING OF OKLAHOMA, INC.;
EMPIRE ROOFING AND SHEET METAL, )
INC.; SR DISPOSAL, LTD F/K/A EMPIRE )
DISPOSAL, LTD; EMPIRE ROOFING )
COMPANY SOUTHEAST, LLC; EMPIRE _ )
ROOFING COMPANY OF GEORGIA, LLC;)
RONNIE MCGLOTHLIN; SANDRA )
SEDILLO-MCGLOTHLIN; and TECTA )
)
)
)

JURY TRIAL DEMANDED
FILED UNDER SEAL

)
)
)
)
)
Vv. ) Case
)
)
)
)

AMERICA CORP.,

Defendants.

COMPLAINT

1. Relator Sidesolve, LLC brings this action on behalf of itself and the United
States of America against defendants Empire Roofing, Inc.; Empire Roofing
Companies, Inc.; Empire Roofing of Oklahoma, Inc.; Empire Roofing and Sheet
Metal, Inc.; SR Disposal, Ltd. f/k/a Empire Disposal, Ltd.; Empire Roofing
Company Southeast, LLC; Empire Roofing Company of Georgia, LLC; Ronnie
McGlothlin; Sandra Sedillo-McGlothlin; and Tecta America Corp. for violations

of the federal False Claims Act, 31 U.S.C. §§ 3729 et seq.
Case 3:22-cv-02060-B Document 2 Filed 09/16/22 Page2of15 PagelD4

2. This action seeks to recover funds that were loaned to Defendants through
the federal Government's Paycheck Protection Program (“PPP”) and forgiven as a
result of false applications.

2; Sidesolve LLC is a company that uses data to investigate large-scale
corporate fraud. Its goal is to use the technology it is developing to protect
individuals on private healthcare plans. It is currently developing its technology
using public databases. It uses computational statistics to match entities across
multiple resources such as databases, social media, corporate filings, and other
sources. From this broader picture, it finds fraud leads, which it follows up with a
more traditional manual investigation. In sum, Sidesolve LLC uses its expertise
and proprietary technology to both collect the scattered pieces of the fraud puzzle
and also to put them together into a complete picture of the alleged fraud.

4. While using its technology to search for potential PPP loan fraud in data
released by the SBA, Relator Sidesolve LLC came across Empire Roofing, Inc.,
which had applied for and received two PPP loans, and its affiliates, which had
applied for and received another six PPP loans.

5: Empire Roofing, Inc. and its affiliates applied for and received PPP loans
totaling $6,705,700, all of which, plus interest, was forgiven by the federal
Government.

6. Had these entities properly applied the SBA’s Affiliation Rules — the
Case 3:22-cv-02060-B Document 2 Filed 09/16/22 Page3of15 PagelD5

purpose of which is to prevent exactly this sort of “unbundling” of companies to
circumvent SBA requirements — then, upon information and belief, most of these
entities would not have been eligible to receive the loans or have received
forgiveness for the loans.

JURISDICTION AND VENUE

7. This Court has jurisdiction over this action pursuant to 31 U.S.C. § 3732(a)
and (b), and 28 U.S.C. §§ 1331, 1345.
8. Venue is proper in this district under 28 U.S.C. §§ 1391(b) and 31 U.S.C. §
3732(a), as one or more of the defendants resides or transacts business in this
jurisdiction and violations of the False Claims Act described herein occurred in
this district.

PARTIES
2. Defendants Empire Roofing, Inc.; Empire Roofing Companies, Inc.; Empire
Roofing of Oklahoma, Inc.; and Empire Roofing and Sheet Metal, Inc. are
commercial roofing companies co-founded by Ronnie McGlothlin and Sandra
Sedillo-McGlothlin.
10. SR Disposal, Ltd. f/k/a Empire Disposal Empire Disposal, Ltd. handles
commercial and construction waste disposal. It is also co-founded and operated
by the McGlothlins.

11. These entities all have a principal address of 4801 Esco Dr., Fort Worth, TX
Case 3:22-cv-02060-B Document 2 Filed 09/16/22 Page4of15 PagelD6

76140. This property consists of a single building owned at all relevant times by
Empire Roofing.

12. Empire Roofing Company Southeast, LLC has a principal address of 4615
NW 103rd Ave., Sunrise, FL 3351.

13. Empire Roofing Company of Georgia, LLC has a principal address of 150
James Aldredge Blvd. SW, Atlanta, GA 30336.

14. | Empire Roofing of Tennessee, LLC has a principal address of 3045
Norbrook Dr., Memphis, TN 38116.

15. These entities, collectively “Empire Roofing”, operate in thirteen locations
in the U.S. and one location in Mexico.

16. In2021, Empire Roofing — except, upon information and belief, SR
Disposal, Ltd.— was purchased by Tecta America Corp., a national commercial
roofing contractor.

17. Prior to the Tecta acquisition, different Empire Roofing affiliates had
different owners, although, upon information and belief, Ronnie McGlothlin and
Sandra Sedillo-McGlothlin owned and operated at least part of each of the
Empire Roofing entities.

THE PAYCHECK PROTECTION PROGRAM

18. During the COVID-19 pandemic, Congress passed the Coronavirus Aid,

Relief, and Economic Security Act (“CARES Act”). Section 1102 of the CARES
Case 3:22-cv-02060-B Document 2 Filed 09/16/22 Page5of15 PagelD 7

Act contains a program called the Paycheck Protection Program (“PPP”), a
program administered by the U.S. Small Business Administration (“SBA”) to
provide economic relief to small businesses nationwide adversely impacted by
the coronavirus pandemic.
19. Section 1102 of the CARES Act temporarily permitted SBA to guarantee
100% of the PPP loans. Section 1106 of the CARES Act provided for forgiveness
of up to the full principal amount of qualifying loans guaranteed under the PPP.
20. The CARES Act gives lenders delegated authority to process loan
applications for PPP funding. SBA allowed lenders to rely on certifications of the
borrowers in order to determine eligibility of the borrower and use of loan
proceeds, and to rely on specified documents provided by the borrower to
determine qualifying loan amount, and eligibility for loan forgiveness.
21. Lenders were compensated by the federal government via processing fees
based on the balance of the financing outstanding at the time of final
disbursement, in the following amounts:

e Five (5) percent for loans of not more than $350,000;

e Three (3) percent for loans of more than $350,000 and less than $2,000,000;

and
e One (1) percent for loans of at least $2,000,000.

22. Borrowers had to submit documentation necessary to establish eligibility
Case 3:22-cv-02060-B Document 2 Filed 09/16/22 Page6of15 PagelD8

such as payroll processor records, payroll tax filings, form 1099s, income and
expenses documentation.

23. In general, the maximum amount borrowers could borrow was calculated
by aggregating payroll costs from the previous year, with annual employee
salaries capped at $100,000. The borrower then calculated the average monthly
payroll cost and multiplied that amount by a factor of 2.5.

24. Each borrower certified on its PPP application that “[d]uring the period
beginning on February 15, 2020 and ending on December 31, 2020, the Applicant
has not and will not receive another loan under the Paycheck Protection
Program.”

25. Borrowers “further certify that the information provided in this
application and the information provided in all supporting documents and forms
is true and accurate in all material respects.”

26. Borrowers were then able to seek forgiveness of the loans if the funds were
used for eligible payroll costs, payments on business mortgage interest
payments, rent, or utilities during either the 8- or 24-week period after
disbursement.

FACTUAL ALLEGATIONS

27. Empire Roofing, Inc. was approved for a loan of $2,621,400 on April 7,

2020 by Frost Bank. It reported 237 jobs. The entire loan amount, plus interest,
Case 3:22-cv-02060-B Document 2 Filed 09/16/22 Page 7of15 PagelD9

was forgiven.

28. Empire Roofing, Inc. was approved for a second loan of $183,900 on April
9, 2020 by Frost Bank. It reported 29 jobs. The entire loan amount, plus interest,
was forgiven.

29. Empire Roofing Companies, Inc. was approved for a loan of $2,080,100 on
April 7, 2020 by Frost Bank. It reported 193 jobs. The entire loan amount, plus
interest, was forgiven.

30. Empire Roofing of Oklahoma, Inc. was approved for a loan of $538,900 on
April 11, 2020 by Frost Bank. It reported 52 jobs. The entire loan amount, plus
interest, was forgiven.

31. Empire Roofing and Sheet Metal, Inc. was approved for a loan of $70,600
on April 9, 2020 by Frost Bank. It reported 7 jobs. The entire loan amount, plus
interest, was forgiven.

32. Empire Disposal, Ltd. was approved for a loan of $67,600 on April 9, 2020
by Frost Bank. It reported 34 jobs. The entire loan amount, plus interest, was
forgiven.

33. Empire Roofing Company Southeast, LLC was approved for a loan of
$870,800 on April 10, 2020 by Frost Bank. It reported 78 jobs. The entire loan
amount, plus interest, was forgiven.

34. Empire Roofing Company of Georgia, LLC was approved for a loan of
Case 3:22-cv-02060-B Document 2 Filed 09/16/22 Page8of15 PagelD 10

$272,400 on April 9, 2020 by Frost Bank. It reported 26 jobs. The entire loan
amount, plus interest, was forgiven.

35. In total, Empire Roofing received $6,705,700 in PPP funding, all forgiven,
including interest forgiven.

36. Version one of the PPP Borrower Application Form, effective April 2, 2020,
required the applicant to certify in good faith that, inter alia:

a. The Applicant is eligible to receive a loan under the rules in effect
at the time this application is submitted that have been issued by
the Small Business Administration (SBA) implementing the
Paycheck Protection Program under Division A, Title I of the
Coronavirus Aid, Relief, and Economic Security Act (CARES Act)
(the Paycheck Protection Program Rule).

b. The Applicant (1) is an independent contractor, eligible self-
employed individual, or sole proprietor or (2) employs no more
than the greater of 500 or employees [sic] or, if applicable, the
size standard in number of employees established by the SBA in
13 C.F.R. 121.201 for the Applicant's industry.

c. During the period beginning on February 15, 2020 and ending on
December 31, 2020, the Applicant has not and will not receive
another loan under the Paycheck Protection Program.

d. I further certify that the information provided in this application
and the information provided in all supporting documents and
forms is true and accurate in all material respects. | understand
that knowingly making a false statement to obtain a guaranteed
loan from SBA is punishable under the law, including under 18
USC 1001 and 3571 by imprisonment of not more than five years
and/or a fine of up to $250,000; under 15 USC 645 by
imprisonment of not more than two years and/or a fine of not
more than $5,000; and, if submitted to a federally insured
institution, under 18 USC 1014 by imprisonment of not more than
thirty years and/or a fine of not more than $1,000,000.
Case 3:22-cv-02060-B Document 2 Filed 09/16/22 Page9of15 PagelD 11

37. Some or all of the above PPP certifications were false when made by the
various Empire Roofing affiliates. Empire Roofing, Inc. received two PPP loans,
and the various Empire Roofing entities received a combined eight PPP loans.
38. Empire Roofing violated the PPP rules by applying for more than one PPP
loan.

39. Lenders would not have funded or forgiven multiple loans for Empire
Roofing had they been aware of this fact.

40. This is a material term of the PPP loan application, as evinced by the
Department of Justice seeking both False Claims Act and Financial Institutions
Reform, Recovery and Enforcement Act penalties against entities and individuals
who applied for and received multiple PPP loans.

41. Moreover, Empire Roofing was not eligible to receive PPP funding.

42. In addition to small business concerns, a business only was eligible for a
First Draw PPP Loan if the business had 500 or fewer employees or the business
met the SBA employee-based or revenue-based size standard for the industry in
which it operates (if applicable).

43. Upon information and belief, Empire Roofing did not qualify for a PPP
loan under the employment test because it employed more than 500 employees,
as evinced by their own loan applications, website, and news media, and, upon

information and belief, its combined annual receipts exceeded the SBA limits, as
Case 3:22-cv-02060-B Document 2 Filed 09/16/22 Page10o0f15 PagelD 12

evinced by its own website and news media.

44. Under the SBA’s Affiliation Rules for PPP loans, codified at 13 C.F.R.

§ 121.301(f), the employees and revenues of Empire Roofing should have been
added together when determining whether any of the corporate entities
individually qualified for PPP loans.

45. When multiple entities are operated under common ownership or
management operate, the SBA generally applies “affiliation rules” that require
the various entities to consolidate their employee and revenue count when
evaluating their loan eligibility.

46. Each Empire Roofing location and entity qualified as an “affiliate” under
the SBA’s Affiliation Rules, under the ownership, management, or identity of
interest tests.

47. According to the Empire Roofing website as it existed at the time (which is
shared by the different entities), “Our affiliated locations are individually owned
and separately operated by long-time industry professionals, although some
administrative functions are centralized. Not including Empire Roofing HQ in
Fort Worth has affiliates in San Antonio, Houston, Austin, El Paso, Tulsa (OK),
Nashville (TN), Memphis (TN), Sunrise (FL), West Palm Beach (FL), Atlanta
(GA), Denver (CO) and Mexico.”

48. Inaddition to being owners, Ronnie McGlothlin and Sandra Sedillo-
Case 3:22-cv-02060-B Document 2 Filed 09/16/22 Page11lof15 PagelD 13

McGlothlin were generally listed in secretary of state filings as being managers.
For example, in 2020, they were iisted as managers for Empire Roofing Company
Southeast, LLC; CEO and Secretary, respectively, for Empire Roofing Company
of Georgia, LLC; President and Secretary, respectively, for Empire Roofing, Inc.;
President and Registered Agent, respectively, for Empire Roofing Companies,
Inc. and Empire Roofing of Oklahoma, Inc.; and Vice President and President,
respectively, for Empire Disposal, Ltd.

49. Empire Roofing routinely referred to its different corporate entities as
“locations” and “affiliates” of a single “Empire Roofing” business. When it
reported earnings and employees on its website and in the press, it would
combine them from the different entities to report a total number.

50. When Tecta purchased Empire Roofing, it indicated in its press release that
it had purchased the entire network, “Empire Roofing, Inc. and all of its U.S.
based affiliate roofing operations.”

51. Accordingly, Empire Roofing falsely applied for PPP funding when it did
not qualify for PPP funding — including receiving two PPP loans for a single
entity —and received forgiveness for the PPP loans under false pretenses.

52. Inits applications, Empire Roofing made false statements material to the
PPP lending decisions.

53. — Insofar as the affiliate rules cou!d have been considered unclear at the time

-11-
Case 3:22-cv-02060-B Document 2 Filed 09/16/22 Page12o0f15 PagelD 14

Empire Roofing applied for the loans, subsequent clarifications issued by the
SBA should have informed Linpire Roofing that it had improperly applied for
and received PPP funds so that it should have repaid those funds. Instead,
Empire Roofing not only kept the PPP funds, but it applied for and received
forgiveness for those funds under false pretenses.

COUNT I
VIOLATIONS OF 31 U.S.C. § 3729 - FEDERAL FCA

54. Relator hereby incorporates and realleges all other paragraphs as if fully
set forth herein.

55. As set forth above, Defendants knowingly presented or caused to be
presented false or fraudulent claims for payment or approval, in violation of 31
U.S.C. § 3729(a)(1)(A).

56. As set forth above, Defendants knowingly made, used, or caused to be
made or used, false records or statements material to numerous false claims, in
violation of the False Claims Act, 31 U.S.C. § 3729(a)(1)(B).

57. As set forth above, Defendants knowingly conspired to commit a violation
of the False Claims Act, in violation of 31 U.S.C. § 3729(a)(1)(C).

58. Asset forth above, Defendants knowingly made, used, or caused to be
made or used a false record or statement material to an obligation to pay or
transmit money or property to the Government, or knowingly concealed or

knowingly and improperly avoided or decreased an obligation to pay or

-12-
Case 3:22-cv-02060-B Document 2 Filed 09/16/22 Page130f15 PagelD 15

transmit money or property to the Government, in violation of the False Claims
Act, 31 U.S.C. § 3729(a)(1)(G).

59. Due to Defendants’ conduct, the United States Government has suffered
substantial monetary damages and is entitled to recover treble damages and a
civil penalty for each false claim, record, or statement. 31 U.S.C. § 3729.

60. Relator is entitled to reasonable attorneys’ fees, costs, and expenses. 31
U.S.C. § 3730(d)(1).

PRAYER FOR RELIEF

WHEREFORE, Relator prays for judgment against Defendants:

(a) awarding the United States treble damages sustained by it for each of
the false claims;

(b) awarding the United States a maximum civil penalty for each of the
false claims and statements;

(c) awarding Relator the maximum relator’s share of the proceeds of this
action and any alternate remedy or the settlement of any such claim;

(d) awarding Relator litigation costs and reasonable attorneys’ fees and
expenses; and

(e) granting such other relief as the Court may deem just and proper.

DEMAND FOR JURY TRIAL
Case 3:22-cv-02060-B Document 2 Filed 09/16/22 Page14o0f15 PagelD 16

Relator hereby respectfully demands trial by jury on all issues and

counts triable as of rigiit before a jury.

Respectfully submitted,

Jason Marcus (pro hac vice pending)
Georgia Bar No. 949698

Bracker & Marcus LLC

3355 Lenox Road, Suite 660
Atlanta, Georgia 30326

Telephone: (770) 988-5035
Facsimile: (678) 648-5544
Jason@fcacounsel.com
JS 44 (Rev. 10/20) -°

The JS 44 civil coveRsheet and the, a mation, conti ned herein neither replace nor supplement the filing and servjce o

hs reqiired by law, except as

ofo' ers
provided by local rules of Poourt) THe fort abprove the Judicial Conference of the United States in Sepitembe 197. ae. offthe Clerk of Court for the
purpose of initiating the civil docket sheet, (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.) i 4}
I. (a) PLAINTIFFS DEFEN ANTS ~

UNITED STATES OF AMERICA ex rel. SIDESOLVE, LLC

(b) County of Residence of First Listed Plaintiff

(c) Attorneys (Firm Name, Address, and Telephone Number)

EMPIRE

(EXCEPT IN U.S. PLAINTIFF CASES)

Bracker & Marcus LLC

3355 Lenox Rd., Suite 660, Atlanta, GA 30326, 770-988-5035

NOTE:

Attorneys (/f Known)

County of Residence of First Listed Defendant

LS ae COURT

Tarrant

(IN U.S. PLAINTIFF CASES ONLY)

IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

II. BASIS OF JURISDICTION (Place an “x”

U.S. Government
Plaintiff

| 2 U.S. Government
Defendant

(3 Federal Question

(U.S. Government Not a Party)

C] 4 Diversity

(Indicate Citizenship of Parties in Item II)

in One Box Only)

(lor Diversity Cases Only)

Citizen of This State C

Citizen of Another State

Citizen or Subject of a

Foreign Country

IH. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “x”

PTF

2

in One Box for Plaintiff
and One Box for Defendant)
PTF

DEF

DEF

Incorporated or Principal Place
of Business In This State

Incorporated and Principal Place
of Business In Another State

LJ 2 fis Os

Foreign Nation | 6 | 6

IV. NATURE OF SUIT (Place an “X”"

in One Box Only)

Click here for: Nature of Suit Code Descriptions.

| CONTRACT. TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY | ]625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane im 365 Personal Injury - of Property 21 USC 881 423 Withdrawal x] 376 Qui Tam (31 USC

130 Miller Act
140 Negotiable Instrument

LJ 150 Recovery of Overpayment
& Enforcement of Judgment

151 Medicare Act

152 Recovery of Defaulted
Student Loans
(Excludes Veterans)

H

C 153 Recovery of Overpayment

of Veteran’s Benefits
160 Stockholders’ Suits
190 Other Contract

|_| 196 Franchise

195 Contract Product Liability

360 Other Personal
Injury

362 Personal Injury -
Medical Malpractice

C] 385 Property Damage

Relations
las Railway Labor Act
751 Family and Medical

Leave Act

Property Damage

Product Liability

790 Other Labor Litigation

230 Rent Lease & Ejectment
240 Torts to Land

|_| 245 Tort Product Liability

[ 290 All Other Real Property

| REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS
|_} 210 Land Condemnation 440 Other Civil Rights Habeas Corpus:
[ _]220 Foreclosure 441 Voting | | 463 Alien Detainee

442 Employment

443 Housing/
Accommodations

445 Amer. w/Disabilities -
Employment

| 446 Amer. w/Disabilities -

Other

| 448 Education

T | 510 Motions to Vacate

T | 530 General
| 535 Death Penalty

791 Employee Retirement
Income Security Act

Sentence

IMMIGRATION

Other:

540 Mandamus & Other

550 Civil Rights

555 Prison Condition

560 Civil Detainee -
Conditions of
Confinement

462 Naturalization Application
465 Other Immigration
Actions

315 Airplane Product Product Liability | ]690 Other 28 USC 157 3729(a))
Liability C] 367 Health Care/ |] 400 State Reapportionment
320 Assault, Libel & Pharmaceutical 410 Antitrust
Slander Personal Injury 820 Copyrights |_| 430 Banks and Banking
| 330 Federal Employers’ Product Liability 830 Patent 450 Commerce
Liability 368 Asbestos Personal 835 Patent - Abbreviated | 460 Deportation
340 Marine Injury Product New Drug Application [_} 470 Racketeer Influenced and
345 Marine Product Liability 840 Trademark Corrupt Organizations
Liability PERSONAL PROPERTY LABOR 880 Defend Trade Secrets | 480 Consumer Credit
350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards Act of 2016 (15 USC 1681 or 1692)
355 Motor Vehicle 371 Truth in Lending Act | 485 Telephone Consumer
Product Liability im 380 Other Personal a 720 Labor/Management SOCIAL SECURITY Protection Act

490 Cable/Sat TV
850 Securities/Commodities/
Exchange
| 890 Other Statutory Actions
|_| 891 Agricultural Acts
893 Environmental Matters

861 HIA (1395ff)

862 Black Lung (923)

863 DIWC/DIWW (405(g))
864 SSID Title XVI

865 RSI (405(g))

TES
870 Taxes (U.S. Plaintiff
or Defendant)
871 IRS-—Third Party
26 USC 7609

895 Freedom of Information
Act

896 Arbitration

899 Administrative Procedure

Act/Review or Appeal of

Agency Decision

| 950 Constitutionality of
State Statutes

V. ORIGIN (Place an“
| Original
Proceeding

“in One Box Only)
ime Removed trom Cl 3
State Court

Remanded from
Appellate Court

Reopened

C4 Reinstated or Cc] 5 Transferred trom
Another District

(specify)

6 Multidistrict
Litigation -
Transfer

| 8 Multidistrict
Litigation -
Direct File

VI. CAUSE OF ACTION

31 U.S.C. 3729-33

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

Brief description of cause:

False Claims Act; PPP loan fraud

VII. REQUESTED IN

[] CHECK IF THIS IS A CLASS ACTION

DEMAND $

CHECK YES only if demanded in complaint:

COMPLAINT: UNDER RULE 23, F.R-Cv.P. JURY DEMAND: [klYes [No
VIII. RELATED CASE(S)

IF ANY (Seem GE DOCKET NUMBER
DATE Wir lt 1 2 SIGHS - © E ee ha NEY OF RECORD

FOR OFFICE USE ONLY

RECEIPT #

AMOUNT

APPLYING IFP JUDGE

MAG. JUDGE


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