Joint Stipulation of Dismissal — Middle East Institute (D.D.C.)

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A Joint Stipulation of Dismissal 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, dated and filed May 1, 2024 as Document 17. Under Federal Rule of Civil Procedure 41(a), the United States, having intervened for purposes of settlement in this False Claims Act qui tam, and the relator stipulate to dismissal under the terms of a Settlement Agreement. The intervened and settled claims described as Covered Conduct are dismissed with prejudice as to the United States and the relator, and any other claims are dismissed without prejudice as to the United States. The stipulation states that the defendant has not been served or filed an answer, and it is signed by Assistant United States Attorney Darrell C. Valdez and David Abrams, Counsel for Relator.

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       Case 1:21-cv-03405-JDB          Document 17       Filed 05/01/24      Page 1 of 2




                              UNITED STATES DISTRICT COURT
                              FOR THE DISTRICT OF COLUMBIA


 UNITED STATES OF AMERICA
 ex rel. TZAC, INC.,

                Plaintiff,
                                                        Civil Action No. 21-3405 (JDB)
        v.

 MIDDLE EAST INSTITUTE,

                Defendant.


                             JOINT STIPULATION OF DISMISSAL

       Pursuant to Federal Rule of Civil Procedure 41(a), the United States, having intervened

for purposes of settlement in this qui tam brought pursuant to the False Claims Act (“FCA”), 31

U.S.C. §§ 3729-3733, and Relator TZAC, Inc. (“Relator”), hereby notify the Court that pursuant

to the terms of the Settlement Agreement entered into by the parties in the above-captioned Civil

Action, the United States and Relator stipulate to dismissal of the intervened and settled claims,

as set forth below:

       1. All of the intervened and settled claims described as “Covered Conduct” in the

Settlement Agreement, are dismissed with prejudice as to the United States and Relator.

       2. All other claims in the Civil Action, to the extent any claims remain, shall be

dismissed without prejudice as to the United States.

       3. Except as provided in the Settlement Agreement, the parties shall bear their respective

costs, including any possible attorneys’ fees or other expenses of litigation with respect to the

intervened and settled claims.
       Case 1:21-cv-03405-JDB        Document 17      Filed 05/01/24    Page 2 of 2




       4. Defendant has not been served or filed an answer or responsive pleading to the

Relator’s qui tam Complaint.

       A proposed order of dismissal is submitted herewith.



May 1, 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



                                            /s/ David Abrams
                                          DAVID ABRAMS
                                          The Zionist Advocacy Center
                                          P.O. Box 3353
                                          Church Street Station
                                          New York, NY 10008
                                          dnabrams@gmail.com

                                          Counsel for Relator


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