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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/, SHA-256 b07f8ee7d45e2702a63c430cd4abb10d2eed1f1ce6e915c8d83aac7f89f41e85.

Full text

            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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