Complaint — United States ex rel. The Tarbell Group, LLC v. Glen Allen Community Center (Document 1)

Summary

Complaint under the False Claims Act brought by Relator The Tarbell Group, LLC against Defendant Glen Allen Community Center and Unknown John and Jane Does, in the United States District Court for the Eastern District of Virginia, Document 1, filed August 18, 2025. The caption states that it is filed under seal. The Relator alleges that Glen Allen Community Center, described as a Tax-Exempt 501(c)(4) Organization, was legally ineligible for a PPP loan that was approved on February 24, 2021 in the amount of $7,230.00, with forgiveness approved on January 26, 2022 in the amount of $7,296.16. It alleges that each defendant knowingly presented a false or fraudulent claim and asks for relief including thrice the amount of the PPP loans and interest forgiven or otherwise not repaid under 31 U.S.C. § 3729(a)(1).

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“Complaint — United States ex rel. The Tarbell Group, LLC v. Glen Allen Community Center (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-3-25-cv-00652-dkt-1-e-d-va-293a86480f/, SHA-256 0e7811e0826e139ce5bec213c96ec6e0f06cf25d5ed891c70af248b3c4983ec3.

Full text

Case 3:25-cv-00652-REP Document 1 Filed 08/18/25 Page 1 of 4 PageID# 48

UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA

United States of America ex rel.
The Tarbell Group, LLC,

Plaintiff
Case no.
V.

FILED UNDER SEAL PURSUANT TO
Glen Allen Community Center and 31 U.S.C. § 3730(b)(2)
Unknown John and Jane Does,

Defendants

COMPLAINT

Nature of the Case

1. Relator The Tarbell Group, LLC, brings this action for itself and the United States

under the False Claims Act, 31 U.S.C. §§ 3729-3733, to recover funds illegally obtained by the

defendant under federal COVID-19 relief laws.

Jurisdiction and Venue

9
The Court has jurisdiction of, and is the appropriate venue for, this matter because

it arises under a federal law, because the United States is a plaintiff, and because in this judicial

district any one defendant can be found, resides, transacts business in, or committed an act

proscribed by the False Claims Act. 28 U.S.C. §§ 1331, 1345; 31 U.S.C. § 3732(a).

Parties—Relator

3. Relator The Tarbell Group, LLC, is a limited liability company located in and

organized under the laws of the Commonwealth of Virginia.

I
Case 3:25-cv-00652-REP Document 1 Filed 08/18/25 Page 2 of 4 PageID# 49

Party—Defendants

4. Defendant Glen Allen Community Center is an organization exempt from tax under

section 501(c)(4) ofthe Internal Revenue Code (“Tax-Exempt 501(c)(4) Organization’’) located at

10800 Brookley Road in Glen Allen, Virginia.

5. Defendants Unknown John or Jane Does were at all relevant times directors.

officers, employees, or otherwise agents by and through whom Defendant Glen Allen Community

Center acted. On information and belief, they include Treasurer William Candler.

Background

6. To provide economic relief and stimulate the economy during the COVID-19

pandemic. Congress in 2020 enacted the Coronavirus Aid, Relief, and Economic Security Act,

Pub. L. 116-136, amended by, inter alia, the Paycheck Protection Program Flexibility Act of 2020,

Pub. L. 116-142 and the American Rescue Plan Act of 2021, Pub. L. 117-2 (2021) (together with

implementing regulations, referred to herein as the “PPP Program”). The PPP Program effectively

transferred money from the federal government to eligible recipients via the United States Small

Business Administration (“SBA”). The transfers took the form of private loans guaranteed,

forgiven and reimbursed by SBA (“PPP Loans”).

7. As a condition of receiving PPP Loans and forgiveness thereof, each applicant was

required to certify its eligibility under the PPP Program.

The PPP Program always excluded Tax-Exempt 501(c)(4) Organizations from

eligibility.

9. Defendants applied for and received a PPP Loan for which Defendant Glen Allen

Community Center was legally ineligible.

2
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PPP Loan

10. Defendant Glen Allen Community Center, acting by and through and under the

direction and control of Defendants Unknown John and Jane Does, applied and received approval

for, and forgiveness of, its PPP Loan, despite being legally ineligible for the same. The loan,

numbered 3826658509, was approved on February 24, 2021, in the amount of $7,230.00. SBA

approved Defendant Glen Allen Community Center’s application for forgiveness of the loan on

January 26, 2022, in the amount of $7,296.16.

Cause of Action
False Claims Act, 31 U.S.C. § 3729

11. Relator repeats and realleges each of the foregoing paragraphs.

12. Defendant Glen Allen Community Center knew that it was ineligible to receive its

PPP Loan at the time it applied and received approval for, and forgiveness of, the same.

13. Each defendant did knowingly present, or cause or be presented, a false or

fraudulent claim for payment or approval, to the injury of the United States, by falsely certifying

that Defendant Glen Allen Community Center was eligible for its PPP Loans and forgiveness

thereof and thereby receiving the same.

14. Each defendant did knowingly make, use, or cause to be made or use, a false record

or statement material to a false or fraudulent claim, to the injury of the United States, by falsely

certifying that Defendant Glen Allen Community Center was eligible for its PPP Loans and

forgiveness thereof and thereby receiving the same.

15. Each defendant did knowingly make, use, or cause to be made or used, a false

record or statement material to, or did knowingly conceal, or did knowingly and improperly avoid

or decrease, an obligation to pay or transmit money or property to the United States government.

3
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by falsely certifying that Defendant Glen Allen Community Center was eligible for its PPP Loans

and forgiveness thereof and thereby receiving the same.

Prayer for Relief

16. WHEREFORE, Relator prays for the following relief against each defendant:

a. A declaration that each defendant did violate the False Claims Act;

b. An amount thrice the amount of PPP Loans and interest forgiven or

otherwise not repaid with respect to each defendant, lending fees paid by

SBA, foregone interest, and all other damages suffered by the United States

government, plus civil penalties and applicable interest, under 31 U.S.C. §

3729(a)(1);

c. The cost of this civil action, apportioned to each defendant respectively in

proportion to its share of the aggregate damages recouped herein, under 31

U.S.C. § 3729(a)(3);

d. An award to relator, including its reasonable expenses, attorneys’ fees, and

costs, under 31 U.S.C. § 3730(d)(1) or (2), as applicable; and

e. Such other and further relief as may be just and proper.

Demand for Jury Trial

17. Relator demands a trial by jury.

Respectfully submitted.
6.

Bruce Ellis Fein
Law Office of Bruce Ellis Fein, PLLC
P.O. Box 506
Great Falls, VA 22066
bruce@newdream.net
703-248-0390
Attorney for Relator The Tarbell Group, LLC

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