Complaint — United States v. Tameca Liptrot (S.D. Fla., Dkt. 1)

Summary

A complaint for entry of consent judgment in United States of America v. Tameca Liptrot, Case No. 25-cv-62064, in the U.S. District Court for the Southern District of Florida, entered on the docket October 14, 2025 (Doc. 1). It alleges that in October, 2024, the defendant entered a settlement agreement resolving a dispute under the False Claims Act, 31 U.S.C. § 3729 et seq., and agreed to pay $66,000.00. The complaint alleges a single $400.00 payment on December 5, 2024, and no additional payments, and asks the Court to enter the consent judgment appended as Exhibit 3 for $65,600.00 plus interest. The signature block names Assistant United States Attorney Brett R. Geiger.

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Case 0:25-cv-62064-XXXX Document 1 Entered on FLSD Docket 10/14/2025 Page 1 of 4




                            UNITED STATES DISTRICT COURT
                            SOUTHERN DISTRICT OF FLORIDA

                                     CASE NO. 25-cv-62064

   UNITED STATES OF AMERICA,

          Plaintiff

   vs.

   TAMECA LIPTROT,

         Defendant,
   ____________________________________/

                  COMPLAINT FOR ENTRY OF CONSENT JUDGMENT

         The United States of America, by and through the undersigned Assistant United States

  Attorney for the Southern District of Florida, sue Defendant, Tameca Liptrot, (“Defendant”)

  and alleges as follows:

         1.     The Defendant Temeca Liptrot resides within the Southern District of Florida.

         2.     This Court has jurisdiction over this case under 31 U.S.C. §§ 3732(a) and 28

  U.S.C. §§ 1331, 1345.

         3.     In October, 2024, Defendant entered into a settlement agreement with Plaintiff

  United States of America for the purpose of resolving a dispute under the False Claims Act,

  31 U.S.C. § 3729 et seq. and common law causes of action (the “Settlement Agreement”). A

  copy of the Settlement Agreement is attached as Exhibit 1 to this Complaint and incorporated

  by reference herein.

         4.     Defendant consents to the jurisdiction of the United States District Court for

  the Southern District of Florida for the resolution of this dispute. See Exhibit “1”, ¶ 10.
Case 0:25-cv-62064-XXXX Document 1 Entered on FLSD Docket 10/14/2025 Page 2 of 4




         5.     Under the terms of the Settlement Agreement, Defendant agreed to pay to the

  United States the aggregate sum of $66,000.00. See Exhibit “1” at 3-4, ¶ 1.

         6.     Also under the terms of the Settlement Agreement, Defendant agreed that in

  the event that Defendant defaulted and failed to pay the Settlement Amount within three (3)

  business days of Defendant’s failure to cure the default pursuant to the cure provisions of the

  Settlement Agreement, the government may enter a consent judgment for the difference

  between the remaining unpaid balance of the Settlement Amount and $66,000.00, plus

  interest at the rate of 10% per annum, compounded daily from the date of default. See Exhibit

  “1”, ¶ (1)(B), (C). The Defendant made a single $400.00 payment on December 5, 2024, but

  has made no additional payments. Accordingly, the Plaintiff is entitled to a judgment in the

  sum of $65,600.00 plus interest.

         7.     The United States has given Defendant written notice of default under the

  terms of the Settlement Agreement and demanded that Defendant cure that default by

  tendering payment in full on the cure amount under the terms of the Settlement Agreement.

  A true copy of the Notice of Default the United States provided to Defendant is attached

  hereto as Exhibit “2.” The United States has given Defendant three business days to cure the

  default, as provided in the Settlement Agreement, but Defendant has failed to respond or to

  make arrangements to comply with the terms of the Settlement Agreement.

         8.     Upon execution of the Settlement Agreement, Defendant voluntarily entered

  into a Stipulation for Entry of Consent Judgment in the amount of the unpaid balance, a copy

  of which is attached hereto as Exhibit “3.” Also, under the terms of the Settlement Agreement,

  Defendant agreed that in the event that Defendant defaulted and failed to pay the Settlement
Case 0:25-cv-62064-XXXX Document 1 Entered on FLSD Docket 10/14/2025 Page 3 of 4




  Amount within three (3) calendar days of Defendant’s failure to cure the default, the United

  States may file the Stipulation for Entry of Consent Judgment in the form appended hereto as

  Exhibit “3” against Defendant in the amount of the remaining unpaid balance of the

  Settlement Amount and accrued interest. Defendant agreed not to contest any offset imposed

  and not to contest any Consent Judgment and/or collection action undertaken by the United

  States pursuant to the Settlement Agreement, either administratively or in any state or federal

  court, except on the grounds of actual payment to the United States. See Exhibit “3.”

         9.     The United States files as Exhibit “4” hereto, a statement of debt showing the

  amount due and owing under the Settlement Agreement as of the date of default.

         10.    Defendant is indebted to the Plaintiff, the United States of America in the

  principal amount of $65,600.00 plus interest accruing at the rate of 10% per annum,

  compounded daily from the date of Default, in accordance with the terms of the Settlement

  Agreement. See Exhibit “1” attached hereto.

         11.    Demand has been made upon the Defendant by the United States for the sum

  due, but the amount due remains unpaid.

         12.    Pursuant to the Soldier’s and Sailor’s Civil Relief Act of 1940, Brett R. Geiger,

  Assistant United States Attorney, has researched and has advised that the Defendant is not

  on active Military Duty. See Military Status Report Exhibit “5” attached hereto.

         WHEREFORE, Plaintiff, the United States of America requests the Court to enter the

  Consent Judgment appended as Exhibit “3” and thereby enter judgment for the United States

  against Defendant Tameca Liptrot, in the amount of $65,600.00, plus pre-judgment interest

  which has accrued since the date of default, plus interest at the post-judgment rate of interest
Case 0:25-cv-62064-XXXX Document 1 Entered on FLSD Docket 10/14/2025 Page 4 of 4




  from the date this Consent Judgment is entered until it is satisfied.

  Dated at Miami, Florida on this 14th day of October, 2025.

                                                  Respectfully submitted,

                                                  JASON A. REDING QUIÑONES
                                                  UNITED STATES ATTORNEY


                                                  By: __________________________
                                                        Brett R. Geiger
                                                        Court No.: A5502622
                                                        Assistant United States Attorney
                                                        Brett.Geiger@usdoj.gov
                                                        99 N.E. 4th Street, 3rd Floor
                                                        Miami, FL 33132-2111
                                                        Tel No.: 305.961.9190


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