Stipulation of Dismissal — Tarbell Group v. Cheers (E.D. Va.)

Summary

A joint stipulation of dismissal by the United States and relator The Tarbell Group, LLC in United States ex rel. The Tarbell Group, LLC v. Cheers, et al., No. 1:24-cv-849-LMB, in the United States District Court for the Eastern District of Virginia, Alexandria Division, dated and filed March 28, 2025 as Document 21. Under Fed. R. Civ. P. 41(a) and 31 U.S.C. § 3730(b)(1), the parties stipulate to dismissal with prejudice of the claims against Southampton Recreation Association under a March 17, 2025 Settlement Agreement and against The Metropolitan Business League under a March 19, 2025 Settlement Agreement. The court is asked to retain jurisdiction over disputes, and the United States and relator state they are filing a Notice of Intervention as to both defendants. It is signed by Assistant U.S. Attorney Gina Kim and relator's counsel Bruce Ellis Fein.

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Case 1:24-cv-00849-LMB-LRV             Document 21       Filed 03/28/25      Page 1 of 4 PageID# 76




                             IN THE UNITED STATES DISTRICT COURT
                             FORTHE EASTERN DISTRICT OF VIRGINIA
                                        Alexandria Division


 UNITED STATES OF AMERICA ex rel.                        )
 THE TARBELL GROUP, LLC,                                 )
                                                         )
                   Plaintiffs,                           )      No. 1:24-cv-849-LMB
                                                          )
                             v.                          )
                                                         )
 Cheers, et al.,                                         )      FILED EX PARTE
                                                         )
                             Defendants.                 )
                                                         )


                                    STIPULATION OF DISMISSAL

         A.        Pursuant to Fed. R. Civ. P. 41(a) and the qui tam provisions of the False Claims

 Act, 31 U.S.C. § 3730(b)(1), and in accordance with the terms and conditions of the March 17,

 2025 Settlement Agreement among the United States, Defendant Southampton Recreation

 Association (SRA), and Relator The Tarbell Group, LLC (the “March 17, 2025 Settlement

 Agreement”), the United States and Relator hereby stipulate to the entry of an order:

         As to Defendant SRA:

              (1) dismissing this action as against SRA with prejudice to the United States and the

                   Relator with respect to the covered conduct set forth in the March 17, 2025

                   Settlement Agreement; and

              (2) providing that the Court retain jurisdiction over any disputes that may arise

                   regarding the March 19, 2025 Settlement Agreement.

         B.        Pursuant to Fed. R. Civ. P. 41(a) and the qui tam provisions of the False Claims

 Act, 31 U.S.C. § 3730(b)(1), and in accordance with the terms and conditions of the March 19,

 2025 Settlement Agreement among the United States, Defendant The Metropolitan Business

 League (MBL), and Relator The Tarbell Group, LLC (the “March 19, 2025 Settlement
Case 1:24-cv-00849-LMB-LRV          Document 21        Filed 03/28/25      Page 2 of 4 PageID# 77




 Agreement”), the United States and Relator hereby stipulate to the entry of an order:

        As to Defendant MBL:

            (3) dismissing this action as against MBL with prejudice to the United States and the

                Relator with respect to the covered conduct set forth in the March 19, 2025

                Settlement Agreement; and

            (4) providing that the Court retain jurisdiction over any disputes that may arise

                regarding the March 19, 2025 Settlement Agreement.

        At the time of filing this Joint Stipulation of Dismissal, the United States and Relator are

 filing a Notice of Intervention as to Defendants SRA and MBL.

        A proposed Order is attached.




                                              Respectfully submitted,

 Dated: March 28, 2025

                                              ERIK S. SIEBERT
                                              United States Attorney

                                        By:
                                              /s/ Gina Kim
                                              GINA KIM
                                              Assistant U.S. Attorney
                                              Counsel for the United States
                                              2100 Jamieson Avenue
                                              Alexandria, Virginia 22314
                                              Tel: (571) 217-3540
                                              Fax: (703) 299-3983
                                              Email: Gina.Kim@usdoj.gov
Case 1:24-cv-00849-LMB-LRV   Document 21    Filed 03/28/25   Page 3 of 4 PageID# 78




                                    _/s/ Bruce Ellis Fein______________
                                    Bruce Ellis Fein
                                    P.O. Box 506
                                    Great Falls, VA 22066
                                    bruce@newdream.net
                                    703-248-0390
                                    Counsel for Relator
Case 1:24-cv-00849-LMB-LRV   Document 21   Filed 03/28/25   Page 4 of 4 PageID# 79


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