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Case 1:20-cv-00231-AW-HTC Document 1 Filed 09/14/20 Page 1 of 26
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF FLORIDA
GAINESVILLE DIVISION
UNITED STATES OF
AMERICA, ex rel.
[UNDER SEAL], Civil No.
1/) D-c\/- ~3 l
Plaintiffs, P..\0l6~
v.
[UNDER SEAL] Filed Under Seal Pursuant to
31 U.S.C. § 3730(b)(2)
Defendant.
COMPLAINT AND JURY DEMAND
FILED UNDER SEAL
NOT TO BE FILED
ON PACER
Case 1:20-cv-00231-AW-HTC Document 1 Filed 09/14/20 Page 2 of 26
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF FLORIDA
GAINESVILLE DIVISION
UNITED STATES OF AMERICA
Plaintiff, Civil No. - - - -
ex rel. COMPLAINT
ANDREW HERSH. Jury Trial Demanded
Relator, Filed Under Seal Pursuant to
31 U.S.C. § 3730(b)(2)
v.
PATRICK WALSH,
AMERICAN BLIMP COMPANY
LLC,
WALSH FAMILY LAND CORP.,
AIRSIGN, INC.,
AIRSIGN AIRSHIP GROUP, LLC,
AIRSIGN GROUP LLC,
AIRSIGN AIRSHIPS LATIN
AMERICA, LLC,
AIRSIGN AIRSHIPS ASIA
PACIFIC, LLC
AIRSIGN AIRSHIPS REPAIR
STATION, LLC,
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AERO CAPITAL LLC,
EAGLE RIDGE MANAGEMENT
GROUP, LLC,
SHILOH OIL COMPANY LLC,
Defendants.
COMPLAINT AND JURY DEMAND
1. Relator Andrew Hersh, through his undersigned attorneys
and on behalf of the United States of America ("United States" or
"Government"), brings this qui tam action under the False Claims Act,
31 U.S.C. § 3729 et seq. ("FCA"), against Defendant Patrick Walsh and
various entities that Defendant Walsh owns and controls. Defendants
knowingly submitted or caused to be submitted false and fraudulent
applications for Paycheck Protection Program (PPP) and Economic
Injury Disaster Loans (EIDL) loans administered by the Small Business
Administration (SBA). Defendants submitted multiple PPP applications
for different companies using falsified documents based on the same
underlying payroll information, and made false statements as to the
number of employees and amount of payroll of the various entities in
order to fraudulently obtain funds intended for small businesses
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suffering economic harm due to the Covid-19 pandemic. Defendant
Walsh then appropriated these funds for his own personal use ,
funneling the loa~s into new business ventures, paying off old personal
debts, and siphoning PPP loan money to his immediate family members
by falsely paying them salaries as if they were actual employees.
2. The PPP loan program was instituted to prevent job losses
and wage cuts caused by the Covid-19 pandemic and economic
shutdown. A small business may apply for a PPP loan from an
authorized lender that is fully guaranteed by the SBA and forgivable if
certain conditions are met.
3. Defendant Walsh and the Defendant entities falsely certified
on their PPP loan applications the number of employees, the average
payroll, the intended use of the loans, and that the companies were in
operation and employing people on the date required by the program. In
order to receive PPP loans, Defendants submitted doctored payroll
sheets and fraudulent IRS Form 941s to participating lenders.
4. Defendant Walsh rushed to manufacture fraudulent PPP
loan packages for any entities that he controlled, apparently duping
various banks in the process. Defendant Walsh used his corporate
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entities interchangeably to mislead PPP lenders and spend the PPP
loans. Upon receipt of PPP loans, he did not maintain separate
corporate forms or accounts. Instead, he used the loans as a giant slush
fund for any purpose he chose, often himself.
5. Defendant Walsh did not spend the PPP loans on salaries -
unsurprising as almost all the entities had no employees. Instead, he
spent the disbursed PPP loan funds on unallowable expenses. As soon
as loan money came in, Defendant Walsh went on a personal spending
spree. He purchased oil wells in Texas, he added his wife and son to the
payrolls of multiple Defendant entities, and he settled multiple personal
debts.
I. JURISDICTION AND VENUE
6. This Court has subject matter jurisdiction action under 28
U.S.C. § 1331 and 31 U.S.C. § 3732. This Court has personal
jurisdiction over Defendants pursuant to 31 U.S.C. § 3732(a) and
because Defendants transacted business and committed acts proscribed
by 31 U .S.C. § 3729 in this District. Venue is proper under 31 U.S.C.
§ 3732(a) and 28 U.S.C. § 1391(b).
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7. As required by 31 U.S.C. § 3730(b)(2), a written disclosure of
substantially all material evidence and information in Relator's
possession was served on the Government prior to this filing. Relator
delivered material evidence and information to the SBA, and the United
States Attorney for the Northern District of Florida. Relator made a
previous disclosure to the SBA and Secret Service on July 22, 2020.
Relator continued to disclose documents to the SBA and Secret Service
throughout July and August.
8. This suit is not based upon prior public disclosures of
allegations or transactions as defined under 31 U.S.C. § 3730(e)(4)(A).
To the extent a public disclosure occurred, Andrew Hersh is an original
source under 31 U.S.C. § 3730(e)(4)(B). Relator Hersh possesses direct
and independent knowledge of the Complaint's allegations and
voluntarily and affirmatively disclosed them to the United States
Government before filing this Complaint.
II. THE PARTIES
9. Relator Andrew Hersh works under the direct supervision of
Patrick Walsh, providing various services including technical and
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internet support, and email administration services. Hersh is a resident
of Pennsylvania.
10. Defendant Patrick Walsh is a resident of Williston, Florida.
11. Defendant American Blimp Company LLC is a Smyrna,
Tennessee company that sells blimp advertisements. Defendant Walsh
owns and controls American Blimp Company. The company's principal
place of business is 12 NW 5th Place, Williston, Florida.
12. Defendant Walsh Family Land Corp is a Williston, Florida
company owned and controlled by Defendant Walsh. The company's
principal address is 12 NW 5th Place, Williston, Florida.
13. Defendant Airsign, Inc. is a Williston, Florida company
owned and controlled by Defendant Walsh. The company's principal
address is 12 NW 5th Place, Williston, Florida.
14. Defendant Airsign Airship Group, LLC is a Williston,
Florida company owned and controlled by Defendant Walsh. The
company's principal address is 12 NW 5th Place, Williston, Florida.
15. Defendant Airsign Group LLC is a Williston, Florida
company owned and controlled by Defendant Walsh. The company's
principal address is 12 NW 5th Place, Williston, Florida.
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16. Defendant Airsign Airships Latin America, LLC is a
Williston, Florida corporation owned and controlled by Defendant
Walsh. The company's principal address is 12 NW 5th Place, Williston,
Florida.
1 7. Defendant Airsign Airships Asia Pacific, LLC is a Williston,
Florida company owned and controlled by Defendant Walsh. The
company's principal address is 12 NW 5th Place, Williston, Florida.
18. Defendant Airsign Airships Repair Station, LLC is a
Williston, Florida company owned and controlled by Defendant Walsh.
The company's principal address is 12 NW 5th Place, Williston, Florida.
19. Defendant Eagle Ridge Management Group LLC is a
Wyoming company owned and controlled by Defendant Walsh. The
company's principal office address and mailing address is 12 NW 5th
Place, Williston, Florida.
20. Defendant Aero Capital LLC is a Williston, Florida company
owned and controlled by Defendant Walsh. The company's principal
address is 12 NW 5th Place, Williston, Florida.
21. Defendant Shiloh Oil Company is a Wyoming company
owned and controlled by Defendant Walsh. The company's principal
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office and mailing address is 5830 E 2nd St. STE 7000 #1820 Casper,
Wyoming.
III. APPLICABLE LAW
a. The Paycheck Protection Program
22. The Paycheck Protection Program (PPP) is a program
created by the Coronavirus Aid, Relief, and Economic Security (CARES)
Act, enacted in March 2020 in response to the Covid-19 pandemic. The
CARES Act authorized $349 billion in forgivable and fully guaranteed
loans to small businesses under the PPP, in order to maintain
employment and wages and offset the economic shutdown resulting
from the Covid-19 pandemic. In addition to PPP, the CARES Act
created the Economic Injury Disaster Loans (EIDL) program which
provides non-forgivable loans directly from SBA to meet obligations and
expenses that could have been met if the Covid-19 pandemic had not
occurred. In April 20~0, Congress authorized an additional $300 billion
in PPP funding after the program was depleted.
23. The PPP loan is calculated by multiplying the average
monthly payroll of the applying entity by 2.5, plus any Economic Injury
Disaster Loans received by the applying entity. The applying entity
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must certify additional information including the number of employees,
that the entity was in operation on February 15, 2020 and had
employees for whom it paid payroll taxes, that current economic
uncertainty makes the loan request necessary to support the ongoing
operation of the applicant, and that the funds will be used by the
applying entity to retain its workers and maintain payroll or make
mortgage interest payments, lease payments, and utility payments
owed by the applying entity.
24. In order to obtain a PPP loan, entities must submit a PPP
loan application (SBA Form 2483), which is signed by an authorized
representative of the entity. The application requires the applicant
(through its authorized representative) to affirm that "[t]he [PPP loan]
funds will be used to retain workers and maintain payroll or make
mortgage payments, lease payments, and utility payments. "
25. In the PPP loan application, the entity (through its
authorized representative) must state, among other things, its: (a)
average monthly payroll expenses; and (b) number of employees. These
figures are used to calculate the loan the entity is eligible to receive
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under the PPP. The entity must submit payroll documentation to the
participating lender which show its payroll expenses.
26. The business must also certify that it was in operation on
February 15, 2020 and had employees for whom it paid taxes.
27. A PPP loan application is processed by a participating lender
and then approved by the SBA. Information certified by the applying
entity is transmitted by the lender to the SBA prior to approval. If the
loan is approved, the participating lender funds the PPP loan at a one
percent (1 %) interest rate, but the loan is fully guaranteed by the SBA.
28. PPP loan proceeds may only be used by the business on
certain permissible expenses including payroll costs, interest on
mortgage obligations and debts incurred by the entity before the
covered period, rent, and utilities.
29. In order for the loan to qualify for Government forgiveness ,
proceeds must be spent on payroll. For the loan to be entirely forgiven,
at least 75% must be spend on payroll.
b. The False Claims Act
30. The False Claims Act provides that any person who
knowingly presents or causes another to present a false or fraudulent
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claim to the Government for payment or approval is liable for a civil
penalty for each false claim or statement and three times the amount of
the damages sustained by the Government. The Act also creates
liability for any person who knowingly makes or uses false records or
statements that are material to a claim for payment, or who conspires
to commit these acts or other acts for which there is False Claims Act
liability. 31 U.S.C. § 3729(a)(l)(A)-(C).
31. The False Claims Act's whistleblower provisions allow a
person who has information regarding a false or fraudulent claim
against the Government to bring an action for himself and on behalf of
the United States, and to share in any recovery.
IV. FACTUAL ALLEGATIONS
a. PPP Applications
32. Prior to the Covid-19 pandemic, Defendant Walsh and his
companies were struggling financially. Following the passage of the
CARES Act, Relator had a conversation with Mr. Walsh where Walsh
referred to PPP loans as "free money" and "grants."
33. In order to fraudulently obtain as much PPP loan money as
possible, Mr. Walsh raced to file applications. Mr. Walsh owns and
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controls numerous corporate entities that do not employ any
individuals. They are failed businesses ventures or empty shells that
were inactive prior to the passage of the CARES Act. Mr. Walsh altered
payroll documents to trick lenders and the SBA into approving PPP
loans.
34. In addition to applying for PPP loans, Mr. Walsh used a
similar scheme to apply for numerous EIDL loans, including fraudulent
loans purportedly from his wife, and companies she purportedly directs,
but also have no employees and are not in operation.
35. On April 30, 2020, Mr. Walsh and several of the corporate
Defendants filed reinstatement documents with the Florida Division of
Corporations. Prior to reinstatement, these companies had been
inactive and were reinstated for the purpose of filing fraudulent PPP
loan applications on their behalf. Mr. Walsh filed reinstatement
documents for: Walsh Family Land Corp, Airsign Airships Latin
America, Airsign Airships Asia Pacific, and Airsign Airships Repair
Station. These companies did not have any employees prior to the
passage of the CARES Act.
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36. Mr. Walsh repeatedly directed a February payroll sheet for
American Blimp Company be doctored. Mr. Walsh directed the company
name to be altered to one of his various other sham entities. One payroll
document was changed to a generic "Airsign" name. This document was
then repeatedly altered for different Defendant entities with "Airsign"
in their name.
37. Mr. Walsh had the company name on the payroll sheet
altered to Aero Capital and then altered to Walsh Family Land Corp.
Neither Aero Capital nor Walsh Family Land Corp had any employees
at this time.
38. Mr. Walsh also had the payroll data altered. Mr. Walsh
stated that he did not care what the listed employees were actually
paid, just that the concocted total amount of payroll, Social Security tax
and federal income tax were equal to a specific number.
39. Mr. Walsh used these documents to apply for PPP loans on
behalf of these companies.
40. Mr. Walsh submitted PPP loan applications for the
Defendant entities to different authorized lenders in an effort to conceal
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that he was submitting multiple applications for the same companies or
based on the same underlying payroll.
41. Entities owned and controlled by Mr. Walsh applied for and
received 1 at least the following PPP loans:
a. Defendant American Blimp Company received a $917,000
PPP loan from Celtic Bank Corporation. To obtain its PPP
loan, Defendant American Blimp Company fraudulently
represented its number of employees and average monthly
payroll.
b. Defendant Walsh Family Land Corp received a PPP loan of
between $150,000 and $350,000 from Celtic Bank
Corporation. Defendant Walsh Family Land Corp
fraudulently represented its number of employees and
average monthly payroll.
c. Defendant Airsign, Inc. received a PPP loan of between
$150,000 and $350,000 from Trustmark National Bank. Mr.
Walsh also received a loan for an "Airsign Inc." (without a
1Relator can confirm that PPP loans were received for all entities
except Aero Capital.
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comma) . "Airsign Inc." received a PPP loan from Newtek
SBF of between $350,000 and $1 million. Defendant Airsign,
Inc. and "Airsign Inc." fraudulently represented its number
of employees and average monthly payroll.
d. Defendant Airsign Airships Group received a PPP loan of
between $350,000 and $1 million from First Home Bank.
Defendant Airsign Airships Group was not in operation and
did not have any employees when its PPP loan application
was submitted.
e. Defendant Airsign Group LLC received a PPP loan of
between $350,000 and $1 million from Renasant Bank.
Defendant Airsign Group LLC was not in operation and did
not have any employees when its PPP loan application was
submitted.
f. Defendant Airsign Airships Latin America received a
$1 ,002,000 PPP loan from Fountainhead SBF LLC.
Defendant Airsign Airships Latin America was not in
operation and did not have any employees when its PPP loan
application was submitted.
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g. Defendant Airsign Airships Asia Pacific received a $502,297
PPP loan from Liberty SBF. Defendant Airsign Airships
Asia Pacific was not in operation and did not have any
employees when its PPP loan application was submitted.
h. Defendant Airsign Airships Repair Station received a
$1 ,038,808 PPP loan from Harvest SBF. To obtain its PPP
loan, Defendant Airsign Airships Repair Station
fraudulently represented its number of employees and
average monthly payroll.
1. Defendant Aero Capital applied for a PPP loan. Defendant
Aero Capital was not in operation and did not have any
employees when its PPP loan application was submitted.
42. Mr. Walsh also submitted applications for numerous
fraudulent EIDL loans under a similar scheme. For example, Mr. Walsh
applied for EIDL loans for Defendants Aero Capital and Eagle Ridge
Management with the fraudulently altered payroll documents.
43. Additionally, Mr. Walsh applied for EIDL loans under his
wife's name. None of the companies Mr. Walsh applied for EIDL loans
in his wife's name have any employees or are in operation.
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44. Each PPP loan application certified that the entity was in
operation on February 15, 2020 with employees for whom the entity had
paid payroll taxes.
45. On each PPP loan application, Defendant Walsh listed a
false number of employees and false average monthly payroll.
46. To support each PPP loan application, Defendant Walsh
submitted false and fraudulent payroll documentation.
4 7. On each PPP loan application, Defendant Walsh on behalf of
the applying entity certified that the loan would be used by the entity to
retain its employees and maintain payroll or employee health benefits,
and make mortgage interest payments, lease payments, and utility
payments owed by the entity. As discussed below, Defendant Walsh and
the corporate Defendants did not use the PPP loan funds for these
allowable uses.
b. Fraudulent Use of PPP Loan Proceeds
48. Instead of using the PPP loan funds for the uses permitted
by the CARES Act, Mr. Walsh redirected the money to profit himself
and his family. Mr. Walsh used the PPP loan funds to pay off old
personal debts , added his immediate family members to the payroll of
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his companies and paid them amounts well in excess of $100,000 within
a few months, increased his own compensation, and invested in various
new business ventures.
49. Throughout May and June, Defendant Walsh wired
hundreds of thousands of dollars from the PPP funds he had received to
various individuals. Defendant Walsh sent numerous six-figure wires,
including for $300,000, $182,439.04, and $148,154.64.
50. Between May 7, 2020 and July 10, 2020, Defendant Walsh
put his wife, Hannah Walsh, on the payroll of multiple Defendant
companies. Ms. Walsh was paid at least $157,692.15 between May 7
through July 10. Ms. Walsh is not an actual employee and does not
perform work at any Defendant entities.
51. Between April 24 and July 3, 2020, Defendant Walsh paid
himself $146,153.70.
52. In the end of July, Defendant Walsh added his son, Adrian
Walsh, to the payroll of one Defendant corporate entities. He was paid
$1 ,153.85 in the first pay period he was eligible.
53. On July 22, 2020, Defendant Walsh updated the corporate
registration of Eagle Ridge Management Group in order to facilitate the
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purchase of a ranch in Wyoming. Defendants Walsh and Eagle Ridge
Management wired $100,000 to initiate the purchase of the ranch with
funds from PPP loans.
54. Defendant Walsh established Shiloh Oil Company in
Wyoming to purchase oil wells using funds from the PPP loans. He has
wired at least $275,000 to Estacado Energy LLC to facilitate this
purchase.
V. CLAIMS FOR RELIEF
COUNT!
False Claims Act - Presentment of False Claims
31 U.S.C. § 3729(a)(I)(A)
55. The allegations of the preceding paragraphs are re-alleged
as if fully set forth below.
56. Through the acts described above and otherwise, Defendants
and their agents and employees knowingly presented or caused to be
presented to the United States false or fraudulent claims for payment
or approval in violation of 31 U.S.C. § 3729(a)(l)(A).
57. As a result of Defendants' conduct, the United States has
been damaged in an amount to be determined at trial, and is also
entitled to statutory penalties.
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COUNT II
False Claims Act- Making or Using False Records or
Statements Material to a False Claims
31 U.S.C. § 3729(a)(l)(B)
58. The allegations of the preceding paragraphs are re-alleged
as if fully set forth below.
59. Through the acts described above and otherwise, Defendants
and their agents and employees knowingly made, used, or caused to be
made or used, false records or statements material to false or
fraudulent claims, in violation of 31 U.S.C. § 3729(a)(l)(B).
60. As a result of Defendants' conduct, the United States has
been damaged in an amount to be determined at trial, and is also
entitled to statutory penalties.
COUNT III
False Claims Act - Conspiracy
31 U.S.C. § 3729(a)(l)(C)
61. The allegations of the preceding paragraphs are re-alleged
as if fully set forth below.
62. Through the acts described above and otherwise, Defendants
entered into a conspiracy or conspiracies to defraud the United States
by getting false or fraudulent claims allowed or paid in violation of 31
U.S.C. § 3729(a)(l)(C).
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63. Defendants and their agents and employees have taken
substantial steps in furtherance of these conspiracies, inter alia, by
preparing false records, by submitting claims for reimbursement to the
Government for payment or approval, and by directing their agents and
personnel not to disclose and/or conceal their fraudulent practices.
64. The United States, unaware of Defendants' conspiracy or the
falsity of the records, statements, and claims made by Defendants, their
agents and employees, and as a result thereof, has paid money that it
would not otherwise have paid. As a result of Defendants' conduct, the
United States has been damaged in an amount to be determined at
trial, and is also entitled to statutory penalties.
COUNT IV
False Claims Act - Making or Using False Record
or Statement to Conceal, Avoid and/or Decrease
Obligation to Repay Money
31 U.S.C. § 3729(a)(7), 31 U.S.C. § 3729(a)(l)(G)
65 . The allegations of the preceding paragraphs are re-alleged
as if fully set forth below.
66. Through the acts described above , in violation of 31 U .S.C. §
3729(a)(7) and as amended, 31 U.S.C. § 3729(a)(l)(G), Mr. Walsh and
his Defendant entities knowingly made, used, or caused to be made or
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used false records or statements to knowingly conceal, or knowingly and
improperly avoid, or decrease Mr. Walsh and his Defendant entities'
obligation to repay money to the United States Government that Mr.
Walsh improperly or fraudulently received. Mr. Walsh and the
Defendant entities failed to disclose material facts that would have
resulted in substantial repayments to the United States.
VI. REQUEST FOR RELIEF
WHEREFORE, Relator Andrew Hersh requests that judgment be
entered against Defendants ordering that:
1. Defendants cease and desist from violating the False Claims Act,
31 U.S.C. § 3729, et seq.;
2. The Court enter judgment against Defendants in an amount equal
to three (3) times the amount of damages the United States has
sustained as a result of Defendants' actions, as well as a civil
penalty against Defendants for each violation of 31 U.S.C. § 3729,
plus any increase as specified by Congress;
3. Relator be awarded the maximum amount allowed pursuant to
the False Claims Act, 31 U.S.C. § 3730(d);
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4. Relator be awarded all costs and expenses of this action, including
attorneys' fees , costs, and expenses pursuant to 31 U.S.C.
§ 3730(d);
5. The United States and Relator recover all such other relief as the
Court deems just and proper.
VII. REQUEST FOR JURY TRIAL
Relator hereby demands a trial by jury.
Date: September 11, 2020 Respectfully submitted,
By: Isl Adam D. Warden
Maya Saxena
Joseph E. White, III
Lester Hooker
Adam D. Warden
7777 Glades Road
Suite 300
Boca Raton, FL 33434
Telephone: (561) 394-3399
Facsimile: (561) 394-3382
msaxena@saxenawhite.com
jw hite@saxenawhite.com
lhooker@saxenawhite.com
awarden@saxenawhite.com
Mark Hanna (pro hac forthcoming)
Nicolas F. Mendoza (pro hac
forthcoming)
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Frederick Turner (pro hac
forthcoming)
Murphy Anderson PLLC
1401 K Street NW, Suite 300
Washington, DC 20005
Phone: (202) 223-2620
mhanna@murphypllc.com
nmendoza@murphypllc.com
wturner@murphypllc.com
Attorneys for Relator Andrew Hersh
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the Cenvet1don on the C!f"lrKl for t~e htternatillMI c . , . of ijoods by·~ (the "'(Ml (Oflftftt6on"), ~ cOMfnHitta, ted,noloty Of sottw••w•••.••pcwtt4
f,om tlM U.S. "' .KCIIH4Mce with lhe ~ Mministratlon . . . tfoA:.
OIV9Uion COOtfMY hi U.S. law prDh.Wted. 01019S1033
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1/1S TG United Porcol Sor,rlco
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