Stipulation and Proposed Order of Dismissal (E.D. Va., Dkt. 140, November 7, 2025)

Summary

Stipulation and [Proposed] Order of Dismissal, filed November 7, 2025 as Document 140 in United States of America ex rel. Karen Bloomfield v. Engineered Structures, Inc., Civil Action No. 1:22-cv-00789-DJN-IDD, in the Eastern District of Virginia, Alexandria Division. It states that the United States, the Relator and the Defendant entered a settlement agreement resolving all False Claims Act claims, with a separate Side Agreement for a payment to Relator's counsel for fees and expenses. The proposed order dismisses all claims with prejudice as to the Relator, and as to the United States with prejudice for the Covered Conduct and otherwise without prejudice. The signature blocks include /s/ Gerard Mene for the United States.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Case 1:22-cv-00789-DJN-IDD           Document 140       Filed 11/07/25    Page 1 of 5 PageID#
                                           4011



                       IN THE UNITED STATES DISTRICT COURT
                      FOR THE EASTERN DISTRICT OF VIRGINIA
                               ALEXANDRIA DIVISION


    UNITED STATES OF AMERICA ex rel.               Civil Action No. 1:22-cv-00789-DJN-IDD
    KAREN BLOOMFIELD,

                Plaintiff-Relator,

         v.

    ENGINEERED STRUCTURES, INC.,

                Defendant.



               STIPULATION AND [PROPOSED] ORDER OF DISMISSAL



        Plaintiff-Relator, Karen E. Bloomfield (“Relator), and Defendant, Engineered Structures,

Inc. (“Defendant” or “ESI”), by and through their respective counsel, hereby respectfully notify

the Court that the United States of America (the “United States”), the Relator and the Defendant

have entered into a settlement agreement (hereinafter the “Settlement Agreement”) that resolves

all claims brought pursuant to the False Claims Act (“FCA”), 31 U.S.C. § 3730 et seq. The

Settlement Agreement requires Defendant to make an agreed-upon payment to the United States

and a separate agreement (the “Side Agreement”) requires Defendant to make an agreed-upon

payment to Relator’s counsel to satisfy claims for attorneys’ fees and expenses under 31 U.S.C. §

3730(d). 1




1
  As the parties have reached agreement regarding all material terms, including the amount of
attorneys’ fees and expenses to be paid by Defendant, the United States, Relator and Defendant
respectfully submit that the proposed Order attached as Exhibit “A” can be entered by the Court
and the hearing scheduled for November 17, 2025 can be taken off calendar at this time.
                                               1
Case 1:22-cv-00789-DJN-IDD            Document 140         Filed 11/07/25       Page 2 of 5 PageID#
                                            4012



        Pursuant to 31 U.S.C. § 3730(b)(1), Federal Rule of Civil Procedure 41(a), and the terms

and conditions of the parties’ Settlement Agreement, Relator and Defendant hereby stipulate,

consent and agree to the entry of an order providing as follows:

        1. As to the Relator, all claims are dismissed with prejudice; and

        2. As to the United States, the claims are dismissed with prejudice as to the Covered

            Conduct, as defined in Recital C of the Settlement Agreement, and otherwise without

            prejudice.

        Relator, Defendant and the United States have agreed that the Court shall specifically retain
and reserve jurisdiction to enforce the terms of the Settlement Agreement and Side Agreement.

See Kokkonen v. Guardian Life Ins. Co. of America, 511 U.S. 375 (1994).

        The United States hereby consents to dismissal as described herein since it has determined

that all terms of the parties’ resolution are fair and reasonable, and has authorized the filing of this

Stipulation.

        A proposed Order that the parties respectfully request be entered by the Court is attached

as Exhibit “A.”

Dated: November 7, 2025                                 Respectfully submitted,

                                                        /s/ Glenn Chappell
                                                        Glenn Chappell, VA Bar No. 92153
                                                        Tycko & Zavareei LLP
                                                        2000 Pennsylvania Ave. NW, Suite 1010
                                                        Washington, DC 20006
                                                        Telephone: (510) 588-5299
                                                        Facsimile: (202) 973-0950
                                                        Email: gchappell@tzlegal.com

                                                        Patricia D. Ryan
                                                        Virginia Bar No. 35945 (EDVA – Admitted)
                                                        6106 Harvard Ave., PO Box 633
                                                        Glen Echo, Maryland 20812
                                                        Telephone: (240) 481-6284
                                                        Email: patriciaryan@pdrlaw.com




                                                   2
Case 1:22-cv-00789-DJN-IDD   Document 140      Filed 11/07/25     Page 3 of 5 PageID#
                                   4013




                                            James E. Miller
                                            Miller Shah LLP
                                            65 Main Street
                                            Chester, CT 06412
                                            Telephone: (866) 540-5505
                                            Facsimile: (866) 300-7367
                                            Email: jemiller@millershah.com
                                            Admitted Pro Hac Vice

                                            Bruce D. Parke
                                            Miller Shah LLP
                                            1845 Walnut Street, Suite 806
                                            Philadelphia, PA 19103
                                            Telephone: (866) 540-5505
                                            Facsimile: (866) 300-7367
                                            Email: bdparke@millershah.com
                                            Admitted Pro Hac Vice
                                            Rachel V. Rose – Attorney at Law, PLLC
                                            P.O. Box 22718
                                            Houston, Texas 77227
                                            Telephone: (713) 907-7442
                                            Email: rvrose@rvrose.com
                                            Admitted Pro Hac Vice

                                            Attorneys for Plaintiff-Relator


                                            /s/ Jason M. Crawford
                                            Jason M. Crawford, VA Bar No. 83781
                                            Amy Laderberg O’Sullivan, VA Bar No.
                                            44267
                                            Agustin D. Orozco (admitted pro hac vice)
                                            Jessica Longoria (admitted pro hac vice)
                                            CROWELL & MORING LLP
                                            1001 Pennsylvania Avenue, N.W.
                                            Washington, D.C. 20004
                                            Telephone: (202) 624-2500
                                            Facsimile: (202) 628-5116
                                            JCrawford@crowell.com
                                            AOSullivan@crowell.com
                                            AOrozco@crowell.com
                                            JLongoria@crowell.com

                                            Attorneys for Engineered Structures Inc.


                                     3
Case 1:22-cv-00789-DJN-IDD   Document 140      Filed 11/07/25     Page 4 of 5 PageID#
                                   4014



                                            LINDSEY HALLIGAN
                                            United States Attorney


                                            By: /s/ Gerard Mene
                                            Assistant United States Attorney
                                            Counsel for the United States
                                            2100 Jamieson Avenue
                                            Alexandria, Virginia 22314
                                            Tel. 703-299-3777
                                            Fax: 703-299-3983
                                            Email: Gerard.Mene@usdoj.gov




                                     4
Case 1:22-cv-00789-DJN-IDD             Document 140        Filed 11/07/25     Page 5 of 5 PageID#
                                             4015




                                   CERTIFICATE OF SERVICE

          I hereby certify that on November 7, 2025, I electronically filed the foregoing with the

Clerk of Court using the CM/ECF system, which will send electronic filing to all counsel of

record.

                                                               /s/ Glenn Chappell
                                                               Glenn Chappell




                                                   5


File and source

File

140.pdf

Size

205,460 bytes

SHA-256

500b795253199b3148270455a3e0752fcd04c057d287f6bd400005971b07443d

Our copy

140.pdf

Original

archive.org