Notice of Intervention for the Purpose of Settlement — TZAC, Inc. v. Middle East Institute (No. 1:21-cv-03405)
Summary
Notice of Intervention for the Purpose of Settlement, Document 15, filed January 22, 2024, in United States of America ex rel. TZAC, Inc. v. Middle East Institute, Civil Action No. 21-3405 (JDB), in the U.S. District Court for the District of Columbia. Under 31 U.S.C. § 3730(b)(2) and (4), the United States notifies the Court that it intervenes for purposes of settlement, stating that the United States, Relator TZAC, Inc., and Defendant Middle East Institute have reached a settlement-in-principle. The alleged conduct is that in February 2021 the Middle East Institute falsely certified its eligibility when it applied for and received a second draw loan in the amount of $359,279.00 under the Paycheck Protection Program, and falsely certified in a loan forgiveness application. The signature line reads /s/ Darrell C. Valdez.
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“Notice of Intervention for the Purpose of Settlement — TZAC, Inc. v. Middle East Institute (No. 1:21-cv-03405).”
Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-d-d-c-no-1-21-cv-03405-dkt-15-d-d-c-386f7d1785/
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Case 1:21-cv-03405-JDB Document 15 Filed 01/22/24 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. 21-3405 (JDB)
)
v. )
) FILED UNDER SEAL
MIDDLE EAST INSTITUTE, )
)
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 Middle East Institute have reached a
settlement-in-principle that the parties are in the process of finalizing for execution. 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 February 2021, The Middle East Institute 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 $359,279.00 under the Paycheck
RECEIVED
JAN 22 2024
Clerk, U.S. District & Bankruptcy
Court for the District of Columbia
Case 1:21-cv-03405-JDB Document 15 Filed 01/22/24 Page 2 of 4
Protection Program (“PPP”) Disaster Relief Program.
2. Further, that The Middle East Institute 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 proposed 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 The Middle East Institute.
The United States also requests that the Relator’s Complaint, this Notice, and the
attached proposed Order be unsealed. The United States requests that all other 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-03405-JDB Document 15 Filed 01/22/24 Page 3 of 4
January 22, 2024 Respectfully submitted,
MATTHEW M. GRAVES, D.C. Bar #481052
United States Attorney
BRIAN P. HUDAK,
Chief, Civil Division
By: /s/ Darrell C. Valdez
DARRELL VALDEZ, DC Bar #420232
Assistant United States Attorney
United States Attorney’s Office – D.C.
Civil Division
601 D Street, N.W.
Washington, D.C. 20530
(202) 252-2507
Darrell.Valdez@usdoj.gov
Counsel for the United States of America
3
Case 1:21-cv-03405-JDB Document 15 Filed 01/22/24 Page 4 of 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 22nd day of January 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
Darrell C. Valdez
DARRELL VALDEZ
Assistant United States Attorney
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