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Civil Investigative Demand For Oral Testimony — Roderick Jefferson, No. NJ-2024-113 (D.N.J., Document 1-3)

Summary

Document 1-3, filed 03/18/25, in Case 1:25-cv-01931-ESK-SAK, is Exhibit 1: a Civil Investigative Demand For Oral Testimony, No. NJ-2024-113, issued to Roderick Jefferson by the United States Attorney's Office in Newark, NJ. It is issued under the False Claims Act in an investigation of whether false statements were made, or caused to be made, to obtain loans under the Paycheck Protection Program. It requires oral testimony under oath commencing thirty (30) days from receipt, with David V. Simunovich designated as the false claims law investigator. The testimony is to cover knowledge of PPP loan applications and receipt, steps taken to ensure the truthfulness of the applications, and how the proceeds were used. It carries a digital signature for Bernard Cooney, Chief, Health Care Fraud Unit.

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“Civil Investigative Demand For Oral Testimony — Roderick Jefferson, No. NJ-2024-113 (D.N.J., Document 1-3).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-united-states-v-jefferson-dkt-1-3-d-n-j-5a63769946/, SHA-256 fe629fd8fd0fe13fd47ebfd11e078c8b73d30e7ed775b9c8d3fa757bd4553522.

Full text

Case 1:25-cv-01931-ESK-SAK   Document 1-3   Filed 03/18/25   Page 1 of 2 PageID: 22




                         Exhibit 1
Case 1:25-cv-01931-ESK-SAK     Document 1-3     Filed 03/18/25   Page 2 of 2 PageID: 23

                           Civil Investigative Demand
                                For Oral Testimony
                        United States Department of Justice
                    United States Attorney’s Office - Newark, NJ

  To:   Roderick Jefferson                        Civil Investigative Demand
                                                  No. NJ-2024-113


       This Civil Investigative Demand is issued pursuant to the False Claims Act,
 31 U.S.C.§§ 3729-3733, in the course of a False Claims Act investigation to
 determine whether there is or has been a violation of 31 U.S.C. § 3729. The False
 Claims Act investigation focuses on whether the                                   or
 anyone acting on        behalf, violated the False Claims Act by making false
 statements, or causing false statements to be made, in order to obtain loans
 pursuant to Paycheck Protection Program, enacted pursuant to the CARES Act,
 Pub. L. No. 116-136 (March 27, 2020).

        This Demand requires you to provide oral testimony under oath, commencing
 thirty (30) days from the date of receipt of this Demand, at 10:00 am at the U.S.
 Attorney’s Office for the District of New Jersey, 970 Broad Street, Suite 700,
 Newark, NJ 07102, or at such time and location as may be agreed upon by Assistant
 U.S. Attorney David V. Simunovich and you. The testimony will be taken
 stenographically and also may be recorded audio-visually.

        Assistant U.S. Attorney David V. Simunovich has been designated as the
 false claims law investigator in this matter and will attend the examination. Mr.
 Simunovich will conduct the examination and is the custodian to whom the
 transcript of the examination will be delivered.

        Your attendance and testimony at the oral examination are necessary to the
 conduct of the False Claims Act investigation described above. You have the right to
 be accompanied by an attorney and any other personal representative at the oral
 examination. The general purpose and primary area of focus for which your
 testimony is sought concerns (i) your knowledge of          applications for, and
 receipt of PPP loans; (ii) what steps you took to ensure the truthfulness of the
 information in the         PPP applications, including with respect to
 eligibility; and (iii) how the PPP loan proceeds were used.

        Issued at Newark, New Jersey.          BERNARD Digitally   signed by
                                                           BERNARD COONEY

                                               COONEY      Date: 2024.12.09
                                              __________________________
                                                           17:36:23 -05'00'

                                              Bernard Cooney
                                              Chief, Health Care Fraud Unit
                                              United States Attorney’s Office
                                              District of New Jersey

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