Joint Stipulation of Dismissal (D. Mass., Dkt. 22, April 21, 2025)

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A Joint Stipulation of Dismissal, Document 22, filed 04/21/25 in Case 1:24-cv-11177-PBS, United States of America ex rel. Aidan Forsyth v. The Herb Chambers Companies, et al., No. 24-CV-11177-PBS, in the United States District Court for the District of Massachusetts. The United States and the relator state that, under the settlement agreement executed on April 9, 2025, the matter is dismissed with prejudice as to the Covered Conduct. They state that as to any other allegations it is dismissed with prejudice as to the relator but without prejudice as to the United States. The settling parties agree that the Court retains jurisdiction and venue for any dispute relating to the Settlement Agreement, and the stipulation is dated April 21, 2025.

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       Case 1:24-cv-11177-PBS           Document 22        Filed 04/21/25      Page 1 of 2




                         UNITED STATES DISTRICT COURT
                          DISTRICT OF MASSACHUSETTS
__________________________________________
                                           )
UNITED STATES OF AMERICA                   )
ex rel. AIDAN FORSYTH,                     )
                                           )
             Plaintiff,                    )
v.                                         )
                                           )
THE HERB CHAMBERS COMPANIES, et al.,       )    No. 24-CV-11177-PBS
                                           )
             Defendants.                   )
                                           )

                          JOINT STIPULATION OF DISMISSAL

       Pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure 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 settlement agreement executed on April 9, 2025 (“Settlement

Agreement”), the United States and the relator, Aidan Forsyth, hereby jointly stipulate to the

entry of an order dismissing this matter as follows:

       1. As to the Covered Conduct, as that term is defined in Recital Paragraph J of the

           Settlement Agreement, this matter is dismissed with prejudice; and

       2. As to any other allegations in the complaint, this matter is dismissed with prejudice

           as to the relator, but without prejudice as to the United States.

       By agreement of the settling parties, this Court shall retain jurisdiction and venue for any

dispute relating to the Settlement Agreement.
        Case 1:24-cv-11177-PBS           Document 22        Filed 04/21/25       Page 2 of 2




                                                       Respectfully submitted,

                                                       LEAH B. FOLEY
                                                       United States Attorney


Dated: April 21, 2025                          By:     /s/ Alexandra Brazier
                                                       Charles B. Weinograd
                                                       Alexandra Brazier
                                                       Assistant United States Attorneys
                                                       United States Attorney’s Office
                                                       1 Courthouse Way, Suite 9200
                                                       Boston, MA 02210
                                                       (617) 748-3100
                                                       Charles.Weinograd@usdoj.gov
                                                       Alexandra.Brazier@usdoj.gov



                                                       Counsel for Relator

                                                       /s/ Eric H. Jaso
                                                       Eric H. Jaso
                                                       Spiro Harrison & Nelson
                                                       Christine M. Kingston
                                                       Nystrom Beckman Paris LLP
                                                       363 Bloomfield Avenue, Suite 2C
                                                       Montclair, NJ 07042
                                                       973-310-4026
                                                       ejaso@shnlegal.com
                                                       ckingston@nbparis.com



                             LOCAL RULE 7.1 CERTIFICATION

        The undersigned counsel certifies, pursuant to Local Rule 7.1(a)(2), that counsel for the
United States has conferred with counsel for the relator, and the relator joins in the filing of this
stipulation of dismissal.


Dated: April 21, 2025                          By:     /s/ Alexandra Brazier
                                                       Alexandra Brazier
                                                       Assistant United States Attorney




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