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Home Source documents Court filing — No. 2:25-cv-16211 (Dkt. 7, D.N.J.)

Court filing — No. 2:25-cv-16211 (Dkt. 7, D.N.J.)

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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;
Case 2:25-cv-16211-BRM-CF       Document 7    Filed 05/07/26      Page 2 of 4 PageID: 90




      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



                                          2
Case 2:25-cv-16211-BRM-CF     Document 7    Filed 05/07/26   Page 3 of 4 PageID: 91




            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




                                        3
Case 2:25-cv-16211-BRM-CF       Document 7     Filed 05/07/26   Page 4 of 4 PageID: 92




                           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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