Notice of Election Re: Intervention and Stipulation Re: Unsealing — Liberty Law Office v. The Bloom Firm (Document 40)

Summary

The United States of America's Notice of Election Re: Intervention and Joint Stipulation Re: Unsealing of Case, filed August 8, 2024 as Document 40 in United States ex rel. Liberty Law Office, Inc. v. The Bloom Firm; Lisa Bloom; and Braden Pollock, No. CV 21-06279 MEMF (PDx). Under the False Claims Act, the United States elects to intervene for settlement purposes, noting a settlement agreement among the United States, the defendants and the relator on or about August 2, 2024. The parties stipulate that the seal be lifted, the complaint and these papers be unsealed, and all other papers remain permanently under seal.

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“Notice of Election Re: Intervention and Stipulation Re: Unsealing — Liberty Law Office v. The Bloom Firm (Document 40).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-c-d-cal-no-2-21-cv-06279-dkt-40-c-d-cal-84bbc12325/, SHA-256 d04f3aeacaf5da29a4b16ad96fe320ea959f95f17cfcb63cb009d198a26953b5.

Full text

Case 2:21-cv-06279-MEMF-PD Document 40 Filed 08/08/24 Page 1 of 5 Page ID #:262

Fax: (213) 894-7819
9 Email: Aaron.Kollitz@usdoj.gov
10 Attorneys for the
United States of America
11
UNITED STATES DISTRICT COURT
12
FOR THE CENTRAL DISTRICT OF CALIFORNIA
13
WESTERN DIVISION
14
UNITED STATES OF AMERICA ex No. CV 21-06279 MEMF (PDx)
15 rel. [UNDER SEAL],
16 Plaintiffs, THE UNITED STATES OF
v. AMERICA’S NOTICE OF ELECTION
17 [UNDER SEAL], RE: INTERVENTION AND JOINT
Defendants. STIPULATION RE: UNSEALING OF
18 CASE
19 [FILED UNDER SEAL PURSUANT TO
THE FALSE CLAIMS ACT, 31 U.S.C. §§
20 3730(b)(2) AND (3)]
21 [LODGED CONCURRENTLY UNDER
SEAL: [PROPOSED] ORDER RE:
22 UNSEALING OF CASE]
23
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Case 2:21-cv-06279-MEMF-PD Document 40 Filed 08/08/24 Page 2 of 5 Page ID #:263

1 E. MARTIN ESTRADA
United States Attorney
2 DAVID M. HARRIS
Assistant United States Attorney
3 Chief, Civil Division
ROSS M. CUFF
4 Assistant United States Attorney
Chief, Civil Fraud Section
5 AARON KOLLITZ (Cal. SBN 238580)
6 Assistant United States Attorney
Room 7516, Federal Building
7 300 N. Los Angeles Street
Los Angeles, California 90012
8 Tel: (213) 894-2083
Fax: (213) 894-7819
9 Email: Aaron.Kollitz@usdoj.gov
10 Attorneys for the
United States of America
11
UNITED STATES DISTRICT COURT
12
FOR THE CENTRAL DISTRICT OF CALIFORNIA
13
WESTERN DIVISION
14
UNITED STATES OF AMERICA ex No. CV 21-06279 MEMF (PDx)
15 rel. LIBERTY LAW OFFICE, INC.,
16 Plaintiffs, THE UNITED STATES OF
v. AMERICA’S NOTICE OF ELECTION
17 THE BLOOM FIRM; LISA BLOOM; RE: INTERVENTION AND JOINT
AND BRADEN POLLOCK, STIPULATION RE: UNSEALING OF
18 Defendants. CASE
19 [FILED UNDER SEAL PURSUANT TO
THE FALSE CLAIMS ACT, 31 U.S.C. §§
20 3730(b)(2) AND (3)]
21 [LODGED CONCURRENTLY UNDER
SEAL: [PROPOSED] ORDER RE:
22 UNSEALING OF CASE]
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Case 2:21-cv-06279-MEMF-PD Document 40 Filed 08/08/24 Page 3 of 5 Page ID #:264

1 THE UNITED STATES OF AMERICA’S NOTICE OF ELECTION RE:
2 INTERVENTION
3 Pursuant to the False Claims Act, 31 U.S.C. § 3730(b)(4)(A), plaintiff the United
4 States of America (“the United States”), notifies the Court of its election to intervene in
5 this action for settlement purposes against Defendants The Bloom Firm, Lisa Bloom, and
6 Braden Pollock (collectively, “Defendants”). The United States, Defendants, and qui tam
7
plaintiff Liberty Law Office, Inc. (“Relator”) entered into a settlement agreement on or
8
about August 2, 2024 (the “Settlement Agreement”).
9
Further, the United States has completed its investigation and made its election;
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thus, there is no further need for the seal. See, e.g., 31 U.S.C. § 3730(b)(3) & (4).
11
Accordingly, the United States and Relator have entered the Joint Stipulation Re:
12
Unsealing of Case below, which requests that this case be unsealed and that certain
13
documents filed be unsealed.
14
15 JOINT STIPULATION RE: UNSEALING OF CASE

16 IT IS HEREBY STIPULATED AND AGREED by and among the United States

17 and Relator, through their respective attorneys of record and subject to the approval of
18 the Court, that this action and its documents should be unsealed as follows:
19 1. The seal should be lifted from this action in all respects, except as specified
20 in Paragraph 5 below;
21 2. Relator’s Complaint should be unsealed;
22 3. The United States’ Notice of Election Re: Intervention and Joint Stipulation
23 Re: Unsealing of Case should be unsealed; and
24 4. Any Order in which the Court unseals this action should be unsealed.
25 5. The United States and Relator further stipulate that all other papers filed or
26
lodged to date in this action should remain permanently under seal because
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such papers were provided by law to the Court alone for the sole purpose of
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discussing the content and extent of the United States’ investigation and
ensuing settlement discussions, and, thereby, evaluating whether the seal
1
Case 2:21-cv-06279-MEMF-PD Document 40 Filed 08/08/24 Page 4 of 5 Page ID #:265

1 and time for making an election to intervene should be extended. 31 U.S.C.
2 § 3730(b)(3) (providing that government’s motions for extension of time
3 may be made in camera).
4 A proposed Order accompanies this request.
5
6 Dated: August 6, 2024 Respectfully submitted,
7 E. MARTIN ESTRADA
8 United States Attorney
DAVID M. HARRIS
9 Assistant United States Attorney
Chief, Civil Division
10 ROSS M. CUFF
Assistant United States Attorney
11 Chief, Civil Fraud Section
12
13 /s/ Aaron Kollitz
AARON KOLLITZ
14 Assistant United States Attorney
15 Attorneys for the
16 United States of America

17 Dated: August 6, 2024 LIBERTY LAW OFFICE, INC.
18 /s/ Micha Liberty*
19
Attorneys for the Relator Liberty Law Office, Inc.
20
*The signatory listed, and on whose behalf this filing
21 is submitted, concurs in the filing’s content and has
authorized the filing.
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2
Case 2:21-cv-06279-MEMF-PD Document 40 Filed 08/08/24 Page 5 of 5 Page ID #:266

1 PROOF OF SERVICE ELECTRONIC MAIL
2 I am over the age of 18 and not a party to the within action. I am employed by the
3 Office of United States Attorney, Central District of California. My business address is
4 300 North Los Angeles Street, Suite 7516, Los Angeles, California 90012.
5 On August 8, 2024, I e-mailed a copy of THE UNITED STATES OF
6 AMERICA’S NOTICE OF ELECTION RE: INTERVENTION AND JOINT
7
STIPULATION RE: UNSEALING OF CASE
8
To: Michal Liberty
9
10 Email: micha@libertylaw.com
11 I declare under penalty of perjury under the laws of the United States of America
12 that the foregoing is true and correct.
13
I declare that I am employed in the office of a member of the bar of this court at
14
whose direction the service was made.
15
Executed on August 8, 2024 at Los Angeles, California.
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18 CONNIE HOM
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