Case 1:22-cv-00137-DLH-CRH Document 24 Filed 09/16/25 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NORTH DAKOTA
UNITED STATES OF AMERICA EX REL.
TZAC, INC.,
Plaintiff-Relator, Case No. 1:22-cv-00137-DLH-CRH
*FILED UNDER SEAL*
v.
EDUCATION FOR JUST PEACE IN [THE]
MIDDLE EAST A/K/A UNITED STATES
CAMPAIGN FOR PALESTINIAN RIGHTS,
Defendant.
FILED UNDER SEAL PURSUANT TO 31 U.S.C. § 3730(b)(3)
NOTICE OF INTERVENTION BY THE UNITED STATES OF AMERICA
FOR THE PURPOSE OF SETTLEMENT AND MOTION TO PARTIALLY UNSEAL
Pursuant to 31 U.S.C. § 3730(b)(2) and (4), the United States of America (“United
States”) notifies the Court of the United States’ election to intervene in this action for purposes
of settlement. The United States, relator TZAC, Inc. (“Relator”), and defendant Education for
Just Peace in the Middle East d/b/a US Campaign for Palestinian Rights (“EfJP”) (collectively,
“the Parties”) have entered into a settlement agreement. Upon completion of certain conditions
precedent in the settlement agreement, the United States and Relator expect to file a stipulation
for dismissal on terms, without EfJP being served. Filing of the stipulation is expected to occur
within the next 30 days.
The United States moves for the following relief:
1. That the Court unseal Relator’s Complaint (Docs. 1 through 1-2), Corporate
Disclosure (Doc. 2), and this Notice of Intervention by the United States of America for the
Purpose of Settlement and Motion to Partially Unseal (Doc. 24).
Case 1:22-cv-00137-DLH-CRH Document 24 Filed 09/16/25 Page 2 of 2
2. That all other papers previously filed in this action remain under seal. These
documents should 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.
3. That the seal be lifted on all other matters and filings occurring hereafter in this
action, unless otherwise directed by the Court.
Dated: September 16, 2025
JENNIFER KLEMETSRUD PUHL
Acting United States Attorney
By: __________________________
/s/ James Patrick Thomas
JAMES PATRICK THOMAS
ND Bar No. 06014
MICHAEL D. SCHOEPF
ND Bar No. 07076
Assistant United States Attorneys
PO Box 699
Bismarck, ND 58502-0699
(701) 530-2420
james.p.thomas@usdoj.gov
michael.schoepf@usdoj.gov
Counsel for United States of America
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