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Case 2:25-cv-16211-BRM-CF Document 7 Filed 05/07/26 Page 1 of 4 PageID: 89
ROBERT FRAZER
United States Attorney
DAVID V. SIMUNOVICH
Assistant United States Attorney
970 Broad Street, Suite 700
Newark, NJ 07102
Tel. (973) 645-2736
david.simunovich@usdoj.gov
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
UNITED STATES OF AMERICA ex rel.
VERITY INVESTIGATIONS, LLC,
HON. BRIAN R. MARTINOTTI
Plaintiffs,
Civil Action No. 25-16211
v.
LYNRED USA INC.,
Defendant.
JOINT STIPULATION OF DISMISSAL
WHEREAS on or about October 2, 2025, Relator Verity Investigations, LLC
(“Relator”), through counsel, filed a complaint in this action on behalf of the United
States pursuant to the qui tam provisions of the False Claims Act, 31 U.S.C. §
3730(b);
WHEREAS the United States investigated Relator’s allegations, reached a
resolution with Defendant Lynred USA Inc., and filed a notice of intervention in
this action for the purposes of effectuating a settlement agreement among the
parties;
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WHEREAS, 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 of the Settlement Agreement, the
United States and Relator hereby STIPULATE and AGREE as follows:
1. The United States, Relator, and Defendant have executed a
written Settlement Agreement that provides for the dismissal of this action
in its entirety.
2. Relator stipulates and agrees that the settlement of this action
is fair, adequate, and reasonable under all the circumstances as defined by 31
U.S.C. § 3730(c)(2)(B).
3. The United States and Relator request that, consistent with the
terms and conditions of the Settlement Agreement and pursuant to Rule
41(a) of the Federal Rules of Civil Procedure and the False Claims Act, 31
U.S.C. § 3730(b)(1), this action be dismissed as follows:
a. With prejudice to Relator as to all claims on behalf of the
United States as against the Defendant;
b. With prejudice to the United States as to the Defendant
and the “Covered Conduct,” as defined by the Settlement Agreement
and set forth in the United States’ Notice of Election to Intervene for
Purposes of Effectuating Settlement (filed with the Court on or about
February 27, 2026); and
c. Without prejudice as to the United States’ claims and
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parties that are not within the “Covered Conduct” and that are not
related to the Defendant.
4. No answer by the Defendant has been served or filed, and no
parties other than the United States and the Relator have appeared in this
Action.
Dated: Newark, New Jersey
May 7, 2026
ROBERT FRAZER
United States Attorney
By: /s/ David V. Simunovich /s/ Steven M. Shepard
David V. Simunovich Steven M. Shepard, Esq.
Assistant United States Attorney Susman Godfrey, LLP
970 Broad Street, Suite 700 One Manhattan West, 50th Floor
Newark, NJ 07102 New York, NY 10001
Tel. (973) 645-2736 Counsel for Relator
Counsel for the United States
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CERTIFICATE OF SERVICE
I, Assistant U.S. Attorney David V. Simunovich, hereby certify that on May
7, 2026, I caused a copy Joint Stipulation of Dismissal to be filed with the Court,
and served on relator, via ECF. I swear that the foregoing statements are true and
correct to the best of my knowledge. I am aware that I am subject to penalty for any
willful misstatement herein.
Dated: Newark, New Jersey
May 7, 2026
/s/ David V. Simunovich
DAVID V. SIMUNOVICH
Assistant United States Attorney
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