Pandemic Darlings The pandemic economy, in original documents
Home Source documents First Amended Complaint — No. 1:24-cv-11950 (Dkt. 24, D. Mass.)

First Amended Complaint — No. 1:24-cv-11950 (Dkt. 24, D. Mass.)

Summary

A first amended complaint filed August 20, 2026 as Document 24 in Case no. 1:24-cv-11950-LTS in the United States District Court for the District of Massachusetts, brought by The Tarbell Group, LLC, as relator for the United States, against Acoaxet Club Inc., et al. The relator sues under the False Claims Act, 31 U.S.C. §§ 3729-3733, to recover what it calls funds illegally obtained by the defendants under federal COVID-19 relief laws. The defendants are clubs, lodges, chambers of commerce and associations pleaded as entities exempt from taxation under section 501(c)(7) of the Internal Revenue Code and as private clubs limiting their memberships for reasons other than capacity. The complaint runs 69 pages and attaches a table of the defendants' PPP loans, ending with Young Men's Club of Hadley Inc., whose first-draw loan of $25,800.00 was forgiven on 8/24/2021 for $26,144.94.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

       Case 1:24-cv-11950-LTS       Document 24     Filed 08/20/26    Page 1 of 69




                         UNITED STATES DISTRICT COURT
                       FOR THE DISTRICT OF MASSACHUSETTS


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

       Plaintiff

               v.

Acoaxet Club Inc.,
Administrators of Special Education Inc.,
The Advertising Club of Greater Boston Inc.
    dba The Ad Club,
American Civic Association Inc. dba Sons of
    Italy,
Amherst Golf Club Inc.,
Arlington Chamber of Commerce Inc.,
Bar Association of Norfolk County Inc.,
Benevolent & Protective Order of Elks of the
    USA—Fall River Lodge No. 118,
Benevolent & Protective Order of Elks of the
    USA—Haverhill Lodge No. 165,
Benevolent & Protective Order of Elks of the
    USA—Waltham-Watertown Lodge No. 953,         Case no. 1:24-cv-11950-LTS
Berkshire County Board of Realtors Inc.,
Bertocci Memorial Club of Brockton Inc.,
Billerica Lodge No. 2648 Loyal Order of
    Moose,
Boston Madison Square Garden Club,
Bridgewater Citizens’ Club Inc.,
Brockton Country Club Inc.,
Builders and Remodelers Association of Greater
    Boston Inc.,
Cambridge Chamber of Commerce,
Cape Cod Cranberry Growers’ Association,
Club Franco American de Westford
    Massachusetts,
Clube Desportivo Faialense Inc.,
Cohasse Country Club,
Concord Chamber of Commerce,
Construction Industries of Massachusetts Inc.,
Cottage Park Yacht Club Inc.,
Curve Triangle & Rectangle Institute Inc.,
Dennis Yacht Club Inc.,
Edgewood Club Inc.,
       Case 1:24-cv-11950-LTS         Document 24   Filed 08/20/26   Page 2 of 69




Ellinwood Country Club Inc.,
Employers Association of the Northeast Inc.,
Everett Chamber of Commerce Inc.,
Fall River Country Club,
The Fay Club,
Forestdale Cemetery Association,
Grand Lodge of Theta Delta Chi Inc.,
Greater Chicopee Chamber of Commerce Inc.,
Greenfield Lodge No. 997 Loyal Order of
     Moose,
Gremio Lusitano Club Inc.,
Greylock Community Club Inc.,
H. E. Fletcher Social & Athletic Club Inc.,
Hampden County Bar Association Inc.,
Harvard Square Business Association Inc.,
Holyoke Canoe Club Inc.,
International Brotherhood of Electrical Workers
     Building Corporation,
Irish-American Club Inc. of Woburn,
Italian Naturalization Club Inc. of Taunton,
John Alden Sportsmen’s Club Inc.,
Jubilee Yacht Club,
Knights of Columbus dba Cardinal Spellman
     Council 347,
Lafayette Naturalization Club Inc.,
Lakeville Aerie No. 3944 Fraternal Order of
     Eagles,
Lenox Chamber of Commerce,
Lexington Golf Club,
Longwood Covered Courts Trust,
Ludlow Country Club Inc.,
Ludlow Fish & Game Club Inc.,
Ludlow Tennis Club Inc.,
Malden Lodge No. 1910 Loyal Order of Moose,
Marblehead Yacht Club Inc.,
Marshfield Country Club,
Massachusetts Association of Accountants Inc.,
Massachusetts Chiefs of Police Association Inc.,
Massachusetts Farm Bureau Federation Inc.,
Massachusetts LGBT Chamber of Commerce,
Massachusetts Laborers’ Health & Welfare
     Fund,
Massachusetts Systems Contractors Association
     Inc.,
Master, Wardens, and Members of The Grand
     Lodge of Masons in Massachusetts,



                                               2
      Case 1:24-cv-11950-LTS         Document 24   Filed 08/20/26   Page 3 of 69




Milton Hoosic Club Inc.,
Minute Man Sportsmans Club Inc.,
Nabnasset Lake Country Club Inc.,
National Board of Trial Advocacy Inc.,
New Bedford Sports Club Inc.,
The New England Affordable Housing
    Management Association Inc.,
North of Boston Convention & Visitors Bureau
    Inc.,
The North Shore Chamber of Commerce Inc.,
North Shore Skating Club Inc.,
North Shore Tennis & Squash Club Inc.,
Oak Grove Cemetery Association of Falmouth
    Inc.,
The Old Colony Yacht Club,
Orleans Yacht Club Inc.,
Outdoor Amusement Business Association Inc.,
Palmer’s Cove Yacht Club Inc.,
Pine Grove Cemetery Corporation,
Pleasant Park Yacht Club Inc.,
The Plymouth Area Chamber of Commerce
    Inc.,
Plymouth Country Club Inc.,
Point Independence Yacht Club Inc.,
Polish American Veterans of Webster Inc.,
The Polish Club Lodge 2058 Inc.,
Portuguese National Club,
Prince Hall Masonic Grand Lodge,
The Proprietors of Forest Hills Cemetery,
Realtor Association of Central Massachusetts,
Rowley Veterans’ Association Inc.,
Salem Chamber of Commerce & Civics,
Salem Office of Tourism & Cultural Affairs Inc.
    dba Destination Salem,
Sandy Bay Yacht Club Inc.,
Singletary Rod & Gun Club Inc.,
Sons of Italy in America—Grand Lodge of
    Massachusetts,
Sons of Italy in America—Methuen Lodge No.
    902,
Sons of Italy in America—Quincy Lodge No.
    1295,
Stockbridge Golf Club,
Stoneham Chamber of Commerce Inc.,
Supreme Council of the Royal Arcanum,
Swampscott Yacht Club,



                                              3
       Case 1:24-cv-11950-LTS          Document 24        Filed 08/20/26      Page 4 of 69




Tennis and Racquet Club,
Town River Yacht Club,
Volunteer Yacht Club,
Wampatuck Country Club of Canton Inc.,
Wayland Swimming and Tennis Club Inc.,
Wequaquet Lake Yacht Club,
West Dennis Yacht Club Inc.,
West End Beagle Club Inc. of Gardner,
Whitinsville Golf Club,
Winthrop Golf Club,
Winthrop Yacht Club Inc.,
Wood Products Manufacturers Association,
Worcester County Memorial Park Inc.,
Young Men’s Club of Hadley Inc., and
Unknown John or Jane Does,

       Defendants


                               FIRST AMENDED 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

defendants under federal COVID-19 relief laws.

                                     Jurisdiction and Venue

       2.      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 each defendant can be found, resides, transacts business in, or committed an act

proscribed by the False Claims Act. 28 U.S.C. §§ 1331, 1345, and 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.




                                                 4
       Case 1:24-cv-11950-LTS         Document 24         Filed 08/20/26    Page 5 of 69




                                 Parties—501(c)(2) Defendant

       4.      Defendant International Brotherhood of Electrical Workers Building Corporation

is an entity exempt from taxation under section 501(c)(2) of the Internal Revenue Code, 26

U.S.C. § 501(c)(2) (“Tax-Exempt 501(c)(2) Organization”). On the loan application(s) at issue

herein, this defendant gave its address as 256 Freeport Street, Dorchester, MA.

                                Parties—501(c)(5) Defendants

       5.      Defendant Cape Cod Cranberry Growers’ Association is an entity exempt from

taxation under section 501(c)(5) of the Internal Revenue Code, 26 U.S.C. § 501(c)(5) (“Tax-

Exempt 501(c)(5) Organization”). On the loan application(s) at issue herein, this defendant gave

its address as 265 South Meadow Road, Unit 2D, Plymouth, MA.

       6.      Defendant Massachusetts Farm Bureau Federation Inc. is a Tax-Exempt 501(c)(5)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 249

Lakeside Avenue, Marlborough, MA.

                                Parties—501(c)(6) Defendants

       7.      Defendant Administrators of Special Education Inc. is an entity exempt from

taxation under section 501(c)(6) of the Internal Revenue Code, 26 U.S.C. § 501(c)(6) (“Tax-

Exempt 501(c)(6) Organization”). On the loan application(s) at issue herein, this defendant gave

its address as 3 Allied Drive, Suite 303, Dedham, MA.

       8.      Defendant The Advertising Club of Greater Boston Inc. dba The Ad Club is a

Tax-Exempt 501(c)(6) Organization. On the loan application(s) at issue herein, this defendant

gave its address as 22 Batterymarch Street, Boston, MA.

       9.      Defendant Arlington Chamber of Commerce Inc. is a Tax-Exempt 501(c)(6)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 611

Massachusetts Avenue, Arlington, MA.


                                                5
       Case 1:24-cv-11950-LTS             Document 24    Filed 08/20/26      Page 6 of 69




       10.     Defendant Bar Association of Norfolk County Inc. is a Tax-Exempt 501(c)(6)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 420

Washington Street, Suite 304, Braintree, MA.

       11.     Defendant Berkshire County Board of Realtors Inc is a Tax-Exempt 501(c)(6)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 99

West Street, Suite 200, Pittsfield, MA.

       12.     Defendant Builders and Remodelers Association of Greater Boston Inc. is a Tax-

Exempt 501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its

address as 45 Dan Road, Canton, MA.

       13.     Defendant Cambridge Chamber of Commerce is a Tax-Exempt 501(c)(6)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 1

Kendall Square, Suite 6-105, Cambridge, MA.

       14.     Defendant Concord Chamber of Commerce is a Tax-Exempt 501(c)(6)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 35

Beharrell Street, Concord, MA.

       15.     Defendant Construction Industries of Massachusetts Inc. is a Tax-Exempt

501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address

as 1500 Boston Providence Turnpike, Suite 14, Norwood, MA.

       16.     Defendant Curve Triangle & Rectangle Institute Inc. is a Tax-Exempt 501(c)(6)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 101

Federal Street, Suite 1900, Boston, MA.




                                                 6
       Case 1:24-cv-11950-LTS          Document 24       Filed 08/20/26      Page 7 of 69




       17.     Defendant Employers Association of the Northeast Inc. is a Tax-Exempt

501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address

as 67 Hunt Street, Suite 111, P.O. Box 1070, Agawam, MA.

       18.     Defendant Everett Chamber of Commerce Inc. is a Tax-Exempt 501(c)(6)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 467

Broadway, Everett, MA.

       19.     Defendant Greater Chicopee Chamber of Commerce Inc. is a Tax-Exempt

501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address

as 48 Center Street, Chicopee, MA.

       20.     Defendant Hampden County Bar Association Inc. is a Tax-Exempt 501(c)(6)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 50

State Street, Springfield, MA.

       21.     Defendant Harvard Square Business Association Inc. is a Tax-Exempt 501(c)(6)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 18

Brattle Square, Cambridge, MA.

       22.     Defendant Lenox Chamber of Commerce is a Tax-Exempt 501(c)(6)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 4

Housatonic Street, Lenox, MA.

       23.     Defendant Massachusetts Association of Accountants Inc. is a Tax-Exempt

501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address

as 607 North Avenue, D16-4, Wakefield, MA.




                                                7
       Case 1:24-cv-11950-LTS          Document 24       Filed 08/20/26      Page 8 of 69




       24.     Defendant Massachusetts Chiefs of Police Association Inc. is a Tax-Exempt

501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address

as 353 Providence Road, South Grafton, MA.

       25.     Defendant Massachusetts LGBT Chamber of Commerce is a Tax-Exempt

501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address

as 50 Milk Street, 16th Floor, Boston, MA.

       26.     Defendant Massachusetts Systems Contractors Association Inc. is a Tax-Exempt

501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address

as 1 Merchant Street, Suite 112, Sharon, MA.

       27.     Defendant National Board of Trial Advocacy Inc. is a Tax-Exempt 501(c)(6)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 850

Franklin Street, Suite 8, Wrentham, MA.

       28.     Defendant The New England Affordable Housing Management Association Inc.

is a Tax-Exempt 501(c)(6) Organization. On the loan application(s) at issue herein, this

defendant gave its address as 400 Washington Street, Suite 202, Braintree, MA.

       29.     Defendant North of Boston Convention & Visitors Bureau Inc. is a Tax-Exempt

501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address

as 195 South Bound Exit 60, Salisbury, MA.

       30.     Defendant The North Shore Chamber of Commerce Inc. is a Tax-Exempt

501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address

as 5 Cherry Hill Drive, Danvers, MA.




                                                8
       Case 1:24-cv-11950-LTS          Document 24       Filed 08/20/26      Page 9 of 69




       31.     Defendant Outdoor Amusement Business Association Inc. is a Tax-Exempt

501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address

as 1305 Memorial Avenue, Suite 2, West Springfield, MA.

       32.     Defendant The Plymouth Area Chamber of Commerce Inc. is a Tax-Exempt

501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address

as 134 Court Street, Plymouth, MA.

       33.     Defendant Realtor Association of Central Massachusetts is a Tax-Exempt

501(c)(6) Organization. On the loan application(s) at issue herein, this defendant gave its address

as 492 Washington Street, Auburn, MA.

       34.     Defendant Salem Chamber of Commerce & Civics is a Tax-Exempt 501(c)(6)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 265

Essex Street, Suite 101, Salem, MA.

       35.     Defendant Salem Office of Tourism & Cultural Affairs Inc. dba Destination

Salem is a Tax-Exempt 501(c)(6) Organization. On the loan application(s) at issue herein, this

defendant gave its address as 81 Washington Street, Suite 204, Salem, MA.

       36.     Defendant Stoneham Chamber of Commerce Inc. is a Tax-Exempt 501(c)(6)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 335

Main Street, Suite 202, Stoneham, MA.

       37.     Defendant Wood Products Manufacturers Association is a Tax-Exempt 501(c)(6)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 14

East Broadway, Gardner, MA.

                                 Parties—501(c)(7) Defendants

       38.     Defendant Acoaxet Club Inc. is an entity exempt from taxation under section

501(c)(7) of the Internal Revenue Code, 26 U.S.C. § 501(c)(7) (“Tax-Exempt 501(c)(7)


                                                9
      Case 1:24-cv-11950-LTS           Document 24     Filed 08/20/26      Page 10 of 69




Organization”). It is also a private club or business which limits the number of its memberships

for reasons other than capacity (a “Private Club”). Under Defendant’s membership process, a

prospective member must be sponsored by a current full member and must satisfy a home-

ownership and residency requirement tied to membership boundaries drawn around Westport

Harbor and neighboring streets in Little Compton and Adamsville, Rhode Island. On the loan

application(s) at issue herein, this defendant gave its address as 152 Howland Road, Westport,

MA.

       39.    Defendant Amherst Golf Club Inc. is a Tax-Exempt 501(c)(7) Organization. On

the loan application(s) at issue herein, this defendant gave its address as 365 South Pleasant

Street, Amherst, MA.

       40.    Defendant Bertocci Memorial Club of Brockton Inc. is a Tax-Exempt 501(c)(7)

Organization and Private Club. On information and belief, Defendant limits the number of its

memberships for reasons other than capacity: it operates as a dues-paying fraternal social club

whose dining and recreational facilities are reserved to its membership. On the loan

application(s) at issue herein, this defendant gave its address as 594 Montello Street, Brockton,

MA.

       41.    Defendant Boston Madison Square Garden Club is a Tax-Exempt 501(c)(7)

Organization and Private Club. Under Defendant’s membership process, an applicant must be

sponsored by two current members, each of whom must submit a separate letter of

recommendation, and membership is limited to a select community of sports and entertainment

enthusiasts. On the loan application(s) at issue herein, this defendant gave its address as 180

Canal Street, Suite 302, Boston, MA.




                                               10
      Case 1:24-cv-11950-LTS          Document 24        Filed 08/20/26     Page 11 of 69




       42.     Defendant Bridgewater Citizens’ Club Inc. is a Tax-Exempt 501(c)(7)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 60

Hale Street, Bridgewater, MA.

       43.     Defendant Brockton Country Club Inc. is a Tax-Exempt 501(c)(7) Organization

and Private Club. On information and belief, Defendant limits the number of its memberships for

reasons other than capacity: it operates a private golf course at which play is limited to members

and their guests across several membership categories. On the loan application(s) at issue herein,

this defendant gave its address as 265 Samuel Avenue, Brockton, MA.

       44.     Defendant Club Franco American de Westford Massachusetts is a Tax-Exempt

501(c)(7) Organization. On the loan application(s) at issue herein, this defendant gave its address

as 55 West Prescott Street, Westford, MA.

       45.     Defendant Clube Desportivo Faialense Inc. is a Tax-Exempt 501(c)(7)

Organization and Private Club. Defendant admits new members only through personal referral

by an existing member, without open enrollment, and its membership is drawn from the

Azorean-Portuguese community of East Cambridge. On the loan application(s) at issue herein,

this defendant gave its address as 1121 Cambridge Street, Cambridge, MA.

       46.     Defendant Cohasse Country Club is a Tax-Exempt 501(c)(7) Organization and

Private Club. On information and belief, Defendant limits the number of its memberships for

reasons other than capacity: it is governed by a Board of Governors, charges an initiation fee,

and admits new members only through a written application. On the loan application(s) at issue

herein, this defendant gave its address as 393 Eastford Road, Southbridge, MA.

       47.     Defendant Cottage Park Yacht Club Inc. is a Tax-Exempt 501(c)(7) Organization

and Private Club. Under Defendant’s membership process, an applicant must obtain two member




                                                11
      Case 1:24-cv-11950-LTS           Document 24        Filed 08/20/26      Page 12 of 69




sponsors who each submit a written declaration recommending the applicant, sit for an interview

with the Membership Committee, and undergo a background check before the Board of Directors

elects the applicant to membership. On the loan application(s) at issue herein, this defendant

gave its address as 1 Bakers Square, Winthrop, MA.

       48.     Defendant Dennis Yacht Club Inc. is a Tax-Exempt 501(c)(7) Organization and

Private Club. On information and belief, Defendant limits the number of its memberships for

reasons other than capacity: it is a seasonal private club whose sailing, tennis, and beach

facilities are reserved to its membership. On the loan application(s) at issue herein, this defendant

gave its address as P.O. Box 556, 4 Harbor Road, East Dennis, MA.

       49.     Defendant Edgewood Club Inc. is a Tax-Exempt 501(c)(7) Organization. On the

loan application(s) at issue herein, this defendant gave its address as 266 Pleasant Street,

Raynham, MA.

       50.     Defendant Ellinwood Country Club Inc. is a Tax-Exempt 501(c)(7) Organization.

On the loan application(s) at issue herein, this defendant gave its address as 1928 Pleasant Street,

Athol, MA.

       51.     Defendant Fall River Country Club is a Tax-Exempt 501(c)(7) Organization and

Private Club. Under Defendant’s membership process, an applicant must name two sponsors on

a written application, be verified by the Membership Committee, and be elected at a meeting of

the Board of Directors before admission, and its memberships are divided into fixed categories

by age and voting status. On the loan application(s) at issue herein, this defendant gave its

address as 4232 North Main Street, Fall River, MA.

       52.     Defendant The Fay Club is a Tax-Exempt 501(c)(7) Organization and Private

Club. Under Defendant’s membership process, an applicant must name two current-member




                                                 12
      Case 1:24-cv-11950-LTS         Document 24       Filed 08/20/26      Page 13 of 69




sponsors on the written application, which is received by the Club Secretary and must be

approved by the Board of Directors before admission. On the loan application(s) at issue herein,

this defendant gave its address as 658 Main Street, Fitchburg, MA.

       53.    Defendant Grand Lodge of Theta Delta Chi Inc. is a Tax-Exempt 501(c)(7)

Organization and Private Club. Defendant is the governing corporation of a collegiate fraternity

whose chartered chapters admit members only by initiation, and membership is restricted to men

enrolled as undergraduates at institutions at which Defendant has chartered a chapter. On the

loan application(s) at issue herein, this defendant gave its address as 214 Lewis Wharf, Boston,

MA.

       54.    Defendant Gremio Lusitano Club Inc. is a Tax-Exempt 501(c)(7) Organization

and Private Club. On information and belief, Defendant limits the number of its memberships for

reasons other than capacity: it is a dues-supported social club founded to promote Portuguese

civic, cultural, and recreational life, and its membership is drawn from the Portuguese

community of Ludlow. On the loan application(s) at issue herein, this defendant gave its address

as 385 Winsor Street, Ludlow, MA.

       55.    Defendant Greylock Community Club Inc. is a Tax-Exempt 501(c)(7)

Organization and Private Club. On information and belief, Defendant limits the number of its

memberships for reasons other than capacity: it operates as a dues-based membership club whose

bar and pavilion are reserved to its membership. On the loan application(s) at issue herein, this

defendant gave its address as 548 State Road, North Adams, MA.

       56.    Defendant H. E. Fletcher Social & Athletic Club Inc. is a Tax-Exempt 501(c)(7)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 11

Brookside Road, Westford, MA.




                                               13
      Case 1:24-cv-11950-LTS          Document 24        Filed 08/20/26      Page 14 of 69




       57.     Defendant Holyoke Canoe Club Inc. is a Tax-Exempt 501(c)(7) Organization. On

the loan application(s) at issue herein, this defendant gave its address as 33 Old Ferry Road,

Holyoke, MA.

       58.     Defendant Irish-American Club Inc. of Woburn is a Tax-Exempt 501(c)(7)

Organization and Private Club. On information and belief, Defendant limits the number of its

memberships for reasons other than capacity: it is a recreational and social membership club

organized around Irish-American heritage. On the loan application(s) at issue herein, this

defendant gave its address as 147 Main Street, Woburn, MA.

       59.     Defendant Italian Naturalization Club Inc. of Taunton is a Tax-Exempt 501(c)(7)

Organization and Private Club. On information and belief, Defendant limits the number of its

memberships for reasons other than capacity: it is a members-only social club organized around

Italian ancestry that does not admit the general public. On the loan application(s) at issue herein,

this defendant gave its address as 46 Wales Street, Taunton, MA.

       60.     Defendant John Alden Sportsmen’s Club Inc. is a Tax-Exempt 501(c)(7)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 16

Minuteman Lane, Plymouth, MA.

       61.     Defendant Jubilee Yacht Club is a Tax-Exempt 501(c)(7) Organization and

Private Club. Under Defendant’s membership process, an applicant must submit a completed

application to the membership committee for review and approval before being admitted, and

Defendant does not admit the general public. On the loan application(s) at issue herein, this

defendant gave its address as 127 Water Street, Beverly, MA.

       62.     Defendant Lafayette Naturalization Club Inc. is a Tax-Exempt 501(c)(7)

Organization and Private Club. On information and belief, Defendant limits the number of its




                                                14
      Case 1:24-cv-11950-LTS            Document 24        Filed 08/20/26      Page 15 of 69




memberships for reasons other than capacity: only members are permitted to enter its premises,

and it was organized as a heritage-based association of French-Canadian immigrants. On the loan

application(s) at issue herein, this defendant gave its address as 11 High Street, Amesbury, MA.

       63.     Defendant Lexington Golf Club is a Tax-Exempt 501(c)(7) Organization and

Private Club. Under Defendant’s membership process, an applicant may join only from a general

wait list that opens periodically, each application must be sponsored by two regular members not

otherwise sponsoring another applicant, and Defendant selects among pooled applicants by

lottery rather than admitting all applicants. On the loan application(s) at issue herein, this

defendant gave its address as 55 Hill Street, Lexington, MA.

       64.     Defendant Longwood Covered Courts Trust is a Tax-Exempt 501(c)(7)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 28

Middlesex Road, Chestnut Hill, MA.

       65.     Defendant Ludlow Country Club Inc. is a Tax-Exempt 501(c)(7) Organization

and Private Club. Defendant is a private facility at which play is limited to members and invitees.

On the loan application(s) at issue herein, this defendant gave its address as 1 Tony Lema Drive,

Ludlow, MA.

       66.     Defendant Ludlow Fish & Game Club Inc. is a Tax-Exempt 501(c)(7)

Organization and Private Club. On information and belief, Defendant limits the number of its

memberships for reasons other than capacity: it is a dues-paying sporting club offering tiered

family, individual, senior, and junior memberships and requiring range-officer certification and

license verification before use of its shooting facilities. On the loan application(s) at issue herein,

this defendant gave its address as 200 Sportsmen's Road, Ludlow, MA.




                                                  15
      Case 1:24-cv-11950-LTS         Document 24       Filed 08/20/26      Page 16 of 69




       67.    Defendant Ludlow Tennis Club Inc. is a Tax-Exempt 501(c)(7) Organization. On

the loan application(s) at issue herein, this defendant gave its address as 40 Carmelinas Circle,

Ludlow, MA.

       68.    Defendant Marblehead Yacht Club Inc. is a Tax-Exempt 501(c)(7) Organization.

On the loan application(s) at issue herein, this defendant gave its address as 4 Cliff Street,

Marblehead, MA.

       69.    Defendant Marshfield Country Club is a Tax-Exempt 501(c)(7) Organization and

Private Club. Defendant is a private country club whose memberships are extended by invitation

only, and play is limited to members and their accompanied guests. On the loan application(s) at

issue herein, this defendant gave its address as 515 Moraine Street, Marshfield, MA.

       70.    Defendant Milton Hoosic Club Inc. is a Tax-Exempt 501(c)(7) Organization and

Private Club. Under Defendant’s membership process, an application may be submitted only at

the request of a sponsoring eligible member, defined as a person who has been a full member for

at least two years, and play at Defendant’s facility is limited to members. On the loan

application(s) at issue herein, this defendant gave its address as 70 Greenlodge Street, Canton,

MA.

       71.    Defendant Minute Man Sportsmans Club Inc. is a Tax-Exempt 501(c)(7)

Organization and Private Club. Under Defendant’s membership process, an applicant must

obtain recommendations from three members in good standing or be interviewed by the

membership committee before admission, and must pay a one-time initiation fee in addition to

annual dues. On the loan application(s) at issue herein, this defendant gave its address as 56 R

Francis Wyman Road, Burlington, MA.




                                               16
      Case 1:24-cv-11950-LTS         Document 24       Filed 08/20/26      Page 17 of 69




       72.    Defendant Nabnasset Lake Country Club Inc. is a Tax-Exempt 501(c)(7)

Organization and Private Club. Defendant extends memberships by invitation only, and its

memberships are allotted by fixed age-based categories including unrestricted, senior, student,

and junior tiers rather than by open admission. On the loan application(s) at issue herein, this

defendant gave its address as 47 Oak Hill Road, Westford, MA.

       73.    Defendant New Bedford Sports Club Inc. is a Tax-Exempt 501(c)(7) Organization

and Private Club. On information and belief, Defendant limits the number of its memberships for

reasons other than capacity: it is a social and recreational club supported by membership fees

whose facilities are reserved to its membership. On the loan application(s) at issue herein, this

defendant gave its address as 1790 Acushnet Avenue, New Bedford, MA.

       74.    Defendant North Shore Skating Club Inc. is a Tax-Exempt 501(c)(7) Organization

and Private Club. Under Defendant’s membership process, a prospective member must complete

a written application and be in good standing with U.S. Figure Skating, after which the

application is presented to Defendant’s Board of Directors for discretionary approval. On the

loan application(s) at issue herein, this defendant gave its address as 51 Symonds Way, Reading,

MA.

       75.    Defendant North Shore Tennis & Squash Club Inc. is a Tax-Exempt 501(c)(7)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 98

Swampscott Road, Salem, MA.

       76.    Defendant The Old Colony Yacht Club is a Tax-Exempt 501(c)(7) Organization

and Private Club. Defendant does not solicit membership from outside its existing membership,

and a prospective member must be brought into the club by an existing member and obtain two




                                               17
      Case 1:24-cv-11950-LTS            Document 24        Filed 08/20/26      Page 18 of 69




sponsors before being considered for admission. On the loan application(s) at issue herein, this

defendant gave its address as 235 Victory Road, Dorchester, MA.

       77.     Defendant Orleans Yacht Club Inc. is a Tax-Exempt 501(c)(7) Organization and

Private Club. Each of Defendant’s five voting membership categories, defined by age brackets, is

capped at a maximum number of members independent of the capacity of its facilities, and its

non-voting racing associate membership requires sponsorship by two current members in good

standing and approval by the Commodore. On the loan application(s) at issue herein, this

defendant gave its address as 39 Cove Road, Orleans, MA.

       78.     Defendant Palmer’s Cove Yacht Club Inc. is a Tax-Exempt 501(c)(7)

Organization and Private Club. Defendant admits new members only during an annual window

running from February through June, with applications due by May 1 to be considered in that

year, and, on information and belief, selects among applicants on criteria unrelated to the

capacity of its facilities. On the loan application(s) at issue herein, this defendant gave its address

as 74 Leavitt Street, Salem, MA.

       79.     Defendant Pleasant Park Yacht Club Inc. is a Tax-Exempt 501(c)(7) Organization

and Private Club. On information and belief, Defendant limits the number of its memberships for

reasons other than capacity: a prospective member must submit a completed application with

supporting documentation for review and is admitted only upon approval. On the loan

application(s) at issue herein, this defendant gave its address as 562 Pleasant Street, Winthrop,

MA.

       80.     Defendant Plymouth Country Club Inc. is a Tax-Exempt 501(c)(7) Organization

and Private Club. Defendant is a member-governed club that restricts associate membership to

working professionals between the ages of 23 and 40 and legacy junior membership to children




                                                  18
      Case 1:24-cv-11950-LTS          Document 24        Filed 08/20/26     Page 19 of 69




of a current member, categories unrelated to the capacity of its course. On the loan application(s)

at issue herein, this defendant gave its address as 221 Warren Avenue, Plymouth, MA.

       81.     Defendant Point Independence Yacht Club Inc. is a Tax-Exempt 501(c)(7)

Organization and Private Club. Under Defendant’s membership process, an applicant must be

sponsored by two members in good standing for at least one year, obtain letters of

recommendation from both sponsors, undergo review by an admissions committee, and submit to

a criminal offender record information check. On the loan application(s) at issue herein, this

defendant gave its address as 15 Independence Lane, Onset, MA.

       82.     Defendant Polish American Veterans of Webster Inc. is a Tax-Exempt 501(c)(7)

Organization and Private Club. On information and belief, Defendant limits the number of its

memberships for reasons other than capacity: it is a Polish-American veterans organization

whose membership is limited to honorably discharged veterans of Polish descent. On the loan

application(s) at issue herein, this defendant gave its address as 30 Ray Street, Webster, MA.

       83.     Defendant Portuguese National Club is a Tax-Exempt 501(c)(7) Organization and

Private Club. Membership in Defendant is restricted to applicants at least 16 years of age who

are of Portuguese descent, born in or immigrated to America, or connected by blood or marriage

to persons of Portuguese descent, and each application must be signed by two member sponsors

and approved by the directors and by a vote of the membership, with a separate social category

for applicants not of Portuguese descent. On the loan application(s) at issue herein, this

defendant gave its address as 21 Railroad Avenue, Stoughton, MA.

       84.     Defendant Rowley Veterans’ Association Inc. is a Tax-Exempt 501(c)(7)

Organization and Private Club. On information and belief, Defendant limits the number of its

memberships for reasons other than capacity: it is a veterans association whose membership is




                                                19
      Case 1:24-cv-11950-LTS           Document 24        Filed 08/20/26      Page 20 of 69




limited to veterans and their affiliates rather than to the general public. On the loan application(s)

at issue herein, this defendant gave its address as 19 Bradford Street, Rowley, MA.

       85.     Defendant Sandy Bay Yacht Club Inc. is a Tax-Exempt 501(c)(7) Organization

and Private Club. Under Defendant’s membership process, an applicant obtains an application

from a member of the Membership Committee who vouches for the applicant, the completed

application is posted at the clubhouse for one week, and the Membership Committee then acts

upon the application and elects new members. On the loan application(s) at issue herein, this

defendant gave its address as 5 T-Wharf Road, Rockport, MA.

       86.     Defendant Singletary Rod & Gun Club Inc. is a Tax-Exempt 501(c)(7)

Organization and Private Club. Under Defendant’s membership process, an applicant must be

sponsored by a current member in good standing and must pay an initiation fee in addition to

annual dues, and Defendant maintains separate senior and life member categories tied to age and

years of consecutive membership. On the loan application(s) at issue herein, this defendant gave

its address as 300 Sutton Avenue, Oxford, MA.

       87.     Defendant Stockbridge Golf Club is a Tax-Exempt 501(c)(7) Organization and

Private Club. Under Defendant’s membership process, an applicant must submit references from

two current members, the application is reviewed by a Membership Committee and then by the

Board of Governors for approval, and each accepted member must pay a non-refundable

initiation fee. Defendant is not open to the public. On the loan application(s) at issue herein, this

defendant gave its address as 3 Cherry Street, Stockbridge, MA.

       88.     Defendant Swampscott Yacht Club is a Tax-Exempt 501(c)(7) Organization and

Private Club. On information and belief, Defendant limits the number of its memberships for

reasons other than capacity: it is a private club offering distinct membership categories whose




                                                 20
      Case 1:24-cv-11950-LTS           Document 24        Filed 08/20/26      Page 21 of 69




facilities are reserved to its membership. On the loan application(s) at issue herein, this defendant

gave its address as 425 Humphrey Street, Swampscott, MA.

       89.     Defendant Tennis and Racquet Club is a Tax-Exempt 501(c)(7) Organization and

Private Club. Under Defendant’s membership process, an applicant must obtain two letters of

support from current members within one month of applying, sit for an interview with the

Membership Committee, be posted on the clubhouse bulletin board, and be approved by the

Board of Governors, and applicants are billed an initiation fee upon submitting an application.

On the loan application(s) at issue herein, this defendant gave its address as 939 Boylston Street,

Boston, MA.

       90.     Defendant Town River Yacht Club is a Tax-Exempt 501(c)(7) Organization and

Private Club. Under Defendant’s membership process, an applicant must be sponsored by a

current member, and the application is reviewed by a membership committee before admission.

On the loan application(s) at issue herein, this defendant gave its address as 60 Mound Street,

Quincy, MA.

       91.     Defendant Volunteer Yacht Club is a Tax-Exempt 501(c)(7) Organization and

Private Club. On information and belief, Defendant limits the number of its memberships for

reasons other than capacity: it is a member-owned social and recreational yacht club whose

facilities are reserved to its membership. On the loan application(s) at issue herein, this defendant

gave its address as 68 Lynnway, Lynn, MA.

       92.     Defendant Wampatuck Country Club of Canton Inc. is a Tax-Exempt 501(c)(7)

Organization and Private Club. Under Defendant’s membership process, an applicant must

obtain two sponsors who are members personally acquainted with the applicant and who have

belonged to Defendant for at least one year, and a limited number of memberships are reserved




                                                 21
      Case 1:24-cv-11950-LTS           Document 24        Filed 08/20/26      Page 22 of 69




for children of non-members under the age of 19. On the loan application(s) at issue herein, this

defendant gave its address as 99 Pleasant Garden Road, P.O. Box 56, Canton, MA.

       93.     Defendant Wayland Swimming and Tennis Club Inc. is a Tax-Exempt 501(c)(7)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 228

Glezen Lane, Wayland, MA.

       94.     Defendant Wequaquet Lake Yacht Club is a Tax-Exempt 501(c)(7) Organization

and Private Club. Defendant’s constitution caps membership at 110 families, and under

Defendant’s membership process an applicant must be sponsored by a current member in good

standing and must complete a probationary first year before the Membership Committee and the

Board of Directors determine whether to extend permanent membership. On the loan

application(s) at issue herein, this defendant gave its address as 57 Yacht Club Drive,

Centerville, MA.

       95.     Defendant West Dennis Yacht Club Inc. is a Tax-Exempt 501(c)(7) Organization

and Private Club. On information and belief, Defendant limits the number of its memberships for

reasons other than capacity: it is a member-owned club offering tiered memberships whose

facilities are reserved to its membership. On the loan application(s) at issue herein, this defendant

gave its address as 259 Loring Avenue, West Dennis, MA.

       96.     Defendant West End Beagle Club Inc. of Gardner is a Tax-Exempt 501(c)(7)

Organization and Private Club. On information and belief, Defendant limits the number of its

memberships for reasons other than capacity: it is a sportsman’s club organized around beagle-

hound breeding, hunting, and fishing activities for its members. On the loan application(s) at

issue herein, this defendant gave its address as 110 Clark Street, Gardner, MA.




                                                 22
      Case 1:24-cv-11950-LTS          Document 24        Filed 08/20/26     Page 23 of 69




       97.     Defendant Whitinsville Golf Club is a Tax-Exempt 501(c)(7) Organization and

Private Club. Defendant is a member-owned club, access to whose course requires being a

member, playing with a member, or being recommended by a member, and Defendant charges a

non-refundable fee to join its membership waiting list. On the loan application(s) at issue herein,

this defendant gave its address as 179 Fletcher Street, Whitinsville, MA.

       98.     Defendant Winthrop Golf Club is a Tax-Exempt 501(c)(7) Organization. On the

loan application(s) at issue herein, this defendant gave its address as 453 Main Street, Winthrop,

MA.

       99.     Defendant Winthrop Yacht Club Inc. is a Tax-Exempt 501(c)(7) Organization and

Private Club. Under Defendant’s membership process, an applicant for regular membership must

be sponsored by two current regular members, an applicant for associate membership must be

sponsored by one regular member and one associate member, and each category requires

payment of a one-time initiation fee. On the loan application(s) at issue herein, this defendant

gave its address as 649 Shirley Street, Winthrop, MA.

       100.    Defendant Young Men’s Club of Hadley Inc. is a Tax-Exempt 501(c)(7)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 138

East Street, Hadley, MA.

                                 Parties—501(c)(8) Defendants

       101.    Defendant American Civic Association Inc. dba Sons of Italy is an entity exempt

from taxation under section 501(c)(8) of the Internal Revenue Code, 26 U.S.C. § 501(c)(8)

(“Tax-Exempt 501(c)(8) Organization”) and Private Club. Under the uniform rules governing

membership in Defendant, admission as a voting member is restricted to persons of Italian birth

or descent and their spouses, applicants not of Italian descent may hold only a separate social

membership with reduced or no voting privileges, and every applicant must be certified eligible


                                                23
      Case 1:24-cv-11950-LTS        Document 24       Filed 08/20/26     Page 24 of 69




and recommended by a sponsoring member. On the loan application(s) at issue herein, this

defendant gave its address as 117 Swanton Street, Winchester, MA.

       102.   Defendant Benevolent & Protective Order of Elks of the USA—Fall River Lodge

No. 118 is a Tax-Exempt 501(c)(8) Organization and Private Club. Under the uniform rules

governing membership in Defendant, every applicant must be an American citizen at least 21

years of age who believes in God and is of good character, must be sponsored by a member in

good standing and vouched for by two additional member references, must submit to an

interview and investigation by Defendant’s investigating committee, and is admitted only upon a

favorable vote of Defendant’s membership. On the loan application(s) at issue herein, this

defendant gave its address as 4500 North Main Street, Fall River, MA.

       103.   Defendant Benevolent & Protective Order of Elks of the USA—Haverhill Lodge

No. 165 is a Tax-Exempt 501(c)(8) Organization and Private Club. Under the uniform rules

governing membership in Defendant, every applicant must be an American citizen at least 21

years of age who believes in God and is of good character, must be sponsored by a member in

good standing and vouched for by two additional member references, must submit to an

interview and investigation by Defendant’s investigating committee, and is admitted only upon a

favorable vote of Defendant’s membership. On the loan application(s) at issue herein, this

defendant gave its address as 24 Summer Street, Haverhill, MA.

       104.   Defendant Benevolent & Protective Order of Elks of the USA—Waltham-

Watertown Lodge No. 953 is a Tax-Exempt 501(c)(8) Organization and Private Club. Under the

uniform rules governing membership in Defendant, every applicant must be an American citizen

at least 21 years of age who believes in God and is of good character, must be sponsored by a

member in good standing and vouched for by two additional member references, must submit to




                                              24
      Case 1:24-cv-11950-LTS         Document 24       Filed 08/20/26      Page 25 of 69




an interview and investigation by Defendant’s investigating committee, and is admitted only

upon a favorable vote of Defendant’s membership. On the loan application(s) at issue herein, this

defendant gave its address as 101 School Street, Waltham, MA.

       105.   Defendant Billerica Lodge No. 2648 Loyal Order of Moose is a Tax-Exempt

501(c)(8) Organization and Private Club. Under the uniform rules governing membership in

Defendant, every applicant must be sponsored by an existing member, must be at least 21 years

of age, must profess a belief in a Supreme Being, and must be of good moral character, and his

membership is conditioned upon the approval of Defendant’s application review committee and

a favorable vote of Defendant’s membership. On the loan application(s) at issue herein, this

defendant gave its address as 104 Boston Road, North Billerica, MA.

       106.   Defendant Greenfield Lodge No. 997 Loyal Order of Moose is a Tax-Exempt

501(c)(8) Organization and Private Club. Under the uniform rules governing membership in

Defendant, every applicant must be sponsored by an existing member, must be at least 21 years

of age, must profess a belief in a Supreme Being, and must be of good moral character, and his

membership is conditioned upon the approval of Defendant’s application review committee and

a favorable vote of Defendant’s membership. On the loan application(s) at issue herein, this

defendant gave its address as 20 School Street, Greenfield, MA.

       107.   Defendant Knights of Columbus dba Cardinal Spellman Council 347 is a Tax-

Exempt 501(c)(8) Organization and Private Club. Under the uniform rules governing

membership in Defendant, membership is limited to practical Catholic men at least 18 years of

age who accept the teaching authority of the Catholic Church on matters of faith and morals and

remain in good standing in the Church, and admission requires a member’s proposal and a




                                               25
      Case 1:24-cv-11950-LTS         Document 24        Filed 08/20/26     Page 26 of 69




favorable vote of Defendant’s membership. On the loan application(s) at issue herein, this

defendant gave its address as 1195 Bedford Street, Whitman, MA.

       108.   Defendant Lakeville Aerie No. 3944 Fraternal Order of Eagles is a Tax-Exempt

501(c)(8) Organization and Private Club. Under the uniform rules governing membership in

Defendant, every applicant must be a person of good moral character who believes in a Supreme

Being, must be proposed by two existing members, must be interviewed by Defendant’s

membership committee, and is admitted only upon a favorable vote of Defendant’s membership.

On the loan application(s) at issue herein, this defendant gave its address as 217 County Street,

Lakeville, MA.

       109.   Defendant Malden Lodge No. 1910 Loyal Order of Moose is a Tax-Exempt

501(c)(8) Organization and Private Club. Under the uniform rules governing membership in

Defendant, every applicant must be sponsored by an existing member, must be at least 21 years

of age, must profess a belief in a Supreme Being, and must be of good moral character, and his

membership is conditioned upon the approval of Defendant’s application review committee and

a favorable vote of Defendant’s membership. On the loan application(s) at issue herein, this

defendant gave its address as 562 Broadway, Malden, MA.

       110.   Defendant The Polish Club Lodge 2058 Inc. is a Tax-Exempt 501(c)(8)

Organization and Private Club. Defendant is a chartered lodge of a fraternal benefit society

whose uniform bylaws restrict membership to persons of Polish lineage or affinity, require each

member to purchase a life insurance or annuity certificate issued by the society, and condition

admission upon Defendant’s approval. On the loan application(s) at issue herein, this defendant

gave its address as 14 1/2 Mill Street, Amesbury, MA.




                                               26
      Case 1:24-cv-11950-LTS         Document 24       Filed 08/20/26      Page 27 of 69




       111.   Defendant Prince Hall Masonic Grand Lodge is a Tax-Exempt 501(c)(8)

Organization and Private Club. Under the uniform rules governing membership in Defendant,

every applicant must submit a written petition declaring his belief in a Supreme Being, must be a

man of good moral character at least 18 years of age, must be recommended in writing by

members of the lodge petitioned, must submit to an investigation by a committee of the lodge,

and is admitted only upon a favorable ballot of the lodge’s membership. On the loan

application(s) at issue herein, this defendant gave its address as 24 Washington Street,

Dorchester, MA.

       112.   Defendant Sons of Italy in America—Grand Lodge of Massachusetts is a Tax-

Exempt 501(c)(8) Organization and Private Club. Under the uniform rules governing

membership in Defendant, admission as a voting member is restricted to persons of Italian birth

or descent and their spouses, applicants not of Italian descent may hold only a separate social

membership with reduced or no voting privileges, and every applicant must be certified eligible

and recommended by a sponsoring member. On the loan application(s) at issue herein, this

defendant gave its address as 93 Concord Avenue, Belmont, MA.

       113.   Defendant Sons of Italy in America—Methuen Lodge No. 902 is a Tax-Exempt

501(c)(8) Organization and Private Club. Under the uniform rules governing membership in

Defendant, admission as a voting member is restricted to persons of Italian birth or descent and

their spouses, applicants not of Italian descent may hold only a separate social membership with

reduced or no voting privileges, and every applicant must be certified eligible and recommended

by a sponsoring member. On the loan application(s) at issue herein, this defendant gave its

address as 459 Merrimack Street, Methuen, MA.




                                               27
      Case 1:24-cv-11950-LTS          Document 24       Filed 08/20/26     Page 28 of 69




       114.    Defendant Sons of Italy in America—Quincy Lodge No. 1295 is a Tax-Exempt

501(c)(8) Organization and Private Club. Under the uniform rules governing membership in

Defendant, admission as a voting member is restricted to persons of Italian birth or descent and

their spouses, applicants not of Italian descent may hold only a separate social membership with

reduced or no voting privileges, and every applicant must be certified eligible and recommended

by a sponsoring member. On the loan application(s) at issue herein, this defendant gave its

address as 120 Quarry Street, Quincy, MA.

       115.    Defendant Supreme Council of the Royal Arcanum is a Tax-Exempt 501(c)(8)

Organization and Private Club. Under the uniform rules governing membership in Defendant,

membership is limited to persons of sound bodily health and good moral standing who are

socially acceptable and at least eighteen years of age, each applicant must be recommended for

admission, and each must qualify for and purchase a minimum life insurance certificate

underwritten by Defendant as a condition of local council membership. On the loan

application(s) at issue herein, this defendant gave its address as 61 Batterymarch Street, Boston,

MA.

                                 Parties—501(c)(9) Defendant

       116.    Defendant Massachusetts Laborers’ Health & Welfare Fund is an entity exempt

from taxation under section 501(c)(9) of the Internal Revenue Code, 26 U.S.C. § 501(c)(9)

(“Tax-Exempt 501(c)(9) Organization”). On the loan application(s) at issue herein, this

defendant gave its address as 1400 District Avenue, Suite 200, Burlington, MA.

                                Parties—501(c)(10) Defendant

       117.    Defendant Master, Wardens, and Members of The Grand Lodge of Masons in

Massachusetts is an entity exempt from taxation under section 501(c)(10) of the Internal

Revenue Code, 26 U.S.C. § 501(c)(10) (“Tax-Exempt 501(c)(10) Organization”) and Private


                                               28
      Case 1:24-cv-11950-LTS         Document 24       Filed 08/20/26     Page 29 of 69




Club. Under the uniform rules governing membership in Defendant, every applicant must submit

a written petition declaring his belief in the existence of a Supreme Being, must be a man of

good moral character at least 18 years of age who is recommended by a Mason, must submit to

an investigation by a committee of the lodge petitioned, and is admitted only upon a unanimous

favorable ballot of the lodge’s membership. On the loan application(s) at issue herein, this

defendant gave its address as 186 Tremont Street, Boston, MA.

                               Parties—501(c)(13) Defendants

       118.   Defendant Forestdale Cemetery Association is an entity exempt from taxation

under section 501(c)(13) of the Internal Revenue Code, 26 U.S.C. § 501(c)(13) (“Tax-Exempt

501(c)(13) Organization”). On the loan application(s) at issue herein, this defendant gave its

address as 304 Cabot Street, Holyoke, MA.

       119.   Defendant Oak Grove Cemetery Association of Falmouth Inc. is a Tax-Exempt

501(c)(13) Organization. On the loan application(s) at issue herein, this defendant gave its

address as 46 Jones Road, Falmouth, MA.

       120.   Defendant Pine Grove Cemetery Corporation is a Tax-Exempt 501(c)(13)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 2

Oscars Road, Spencer, MA.

       121.   Defendant The Proprietors of Forest Hills Cemetery is a Tax-Exempt 501(c)(13)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 95

Forest Hills Avenue, Jamaica Plain, MA.

       122.   Defendant Worcester County Memorial Park Inc. is a Tax-Exempt 501(c)(13)

Organization. On the loan application(s) at issue herein, this defendant gave its address as 217

Richards Avenue, Paxton, MA.




                                              29
      Case 1:24-cv-11950-LTS          Document 24        Filed 08/20/26     Page 30 of 69




                                Parties—Individual Defendants

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

officers, employees, or otherwise agents by and through whom Defendants respectively acted.

                                           Background

       124.    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 the SBA (“PPP Loans”).

       125.    PPP Loan recipients could receive up to two loans, one in each of two tranches,

each called a “draw,” i.e., first-draw and second-draw PPP Loans.

       126.    A recipient could receive a second-draw loan only after having obtained a first-

draw loan.

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

was required to certify its eligibility under the PPP Program.

       128.    To receive a PPP Loan, each applicant was required to complete, sign, and submit

to a participating lender a borrower application form prescribed by the SBA. On that form, the

applicant was required to certify, among other things, that it was eligible to receive a PPP Loan

under the rules in effect at the time of the application. Such certification was material to, and a

prerequisite of, the approval and disbursement of each PPP Loan and the SBA’s guarantee

thereof. But for such certification, an applicant could not and would not receive a PPP Loan.


                                                30
      Case 1:24-cv-11950-LTS          Document 24        Filed 08/20/26     Page 31 of 69




       129.    To obtain forgiveness of a PPP Loan, each borrower was likewise required to

complete, sign, and submit to its lender a forgiveness application form prescribed by the SBA.

On that form, the borrower was required to certify, among other things, its compliance with the

requirements of the PPP Program, including its eligibility rules, and the truth and accuracy of the

information provided. Each forgiveness application form advised the borrower that the SBA

could direct the lender to disapprove the application if the SBA determined that the borrower

was ineligible for its PPP Loan. Such certifications were material to, and a prerequisite of,

forgiveness of each PPP Loan. But for such certifications, a borrower could not and would not

obtain forgiveness.

       130.    The PPP Program excluded Tax-Exempt 501(c)(2) Organizations from eligibility

until March 11, 2021.

       131.    The PPP Program excluded Tax-Exempt 501(c)(5) Organizations from eligibility

until March 11, 2021.

       132.    The PPP Program excluded Tax-Exempt 501(c)(6) Organizations from eligibility

until December 27, 2020.

       133.    The PPP Program excluded Tax-Exempt 501(c)(7) Organizations from eligibility

until March 11, 2021.

       134.    The PPP Program excluded Tax-Exempt 501(c)(8) Organizations from eligibility

until March 11, 2021.

       135.    The PPP Program excluded Tax-Exempt 501(c)(9) Organizations from eligibility

until March 11, 2021.

       136.    The PPP Program excluded Tax-Exempt 501(c)(10) Organizations from eligibility

until March 11, 2021.




                                                31
      Case 1:24-cv-11950-LTS         Document 24        Filed 08/20/26     Page 32 of 69




       137.    The PPP Program excluded Tax-Exempt 501(c)(13) Organizations from eligibility

until March 11, 2021.

       138.    The PPP Program at all times excluded Private Clubs from eligibility.

       139.    Each defendant, by and through the individual defendants who acted on its behalf,

applied for and received one or more PPP Loans for which it was legally ineligible.

       140.    Each Private Club defendant, by and through the individual defendants who acted

on its behalf, applied for and received one or more PPP Loans for which it was legally ineligible

as a Private Club.

       141.    Some defendants, by and through the individual defendants who acted on their

behalf, also applied for and received second PPP Loans for which they were ineligible as “fruit

of the poisonous tree,” because receipt of a first-draw loan was a prerequisite to receive a

second-draw loan.

                                          PPP Loans

       142.    Defendants received approval for, and forgiveness of, their PPP Loans on the

dates and in the amounts shown on the table attached hereto, despite being legally ineligible for

the same.

                                   First Cause of Action
                    False Claims Act, 31 U.S.C. § 3729(a)(1)(A) and (B)
                            First-Draw PPP Loan Applications
                 (Against All Defendants and Unknown John or Jane Does)

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

       144.    Each defendant applied for and received a first-draw PPP Loan, which the SBA

approved on the date and in the amount shown for that loan on the table attached hereto.

       145.    On its application form for its first-draw PPP Loan, each defendant other than

Edgewood Club Inc., Gremio Lusitano Club Inc., Italian Naturalization Club Inc. of Taunton,



                                               32
        Case 1:24-cv-11950-LTS        Document 24        Filed 08/20/26     Page 33 of 69




Lafayette Naturalization Club Inc., New Bedford Sports Club Inc., Polish American Veterans of

Webster Inc., Portuguese National Club, Volunteer Yacht Club, and West End Beagle Club Inc.

of Gardner certified that “The Applicant is eligible to receive a loan under the rules in effect at

the time this application is submitted that have been issued by the Small Business Administration

(SBA) implementing the Paycheck Protection Program . . .”

        146.   Defendants Edgewood Club Inc., Gremio Lusitano Club Inc., Italian

Naturalization Club Inc. of Taunton, Lafayette Naturalization Club Inc., New Bedford Sports

Club Inc., Polish American Veterans of Webster Inc., Portuguese National Club, Volunteer

Yacht Club, and West End Beagle Club Inc. of Gardner, which applied for their first-draw PPP

Loans in early 2021, each certified on their application forms: “The Applicant is eligible to

receive a loan under the rules in effect at the time this application is submitted that have been

issued by the Small Business Administration (SBA) and the Department of the Treasury

(Treasury) implementing the Paycheck Protection Program . . .”

        147.   Each such certification was required as a material prerequisite to receive a PPP

Loan.

        148.   Each such certification was false and known by the certifying defendant and the

individual defendants acting on its behalf to be false within the meaning of the False Claims Act.

Each defendant was ineligible for its first-draw PPP Loan because it was exempt from taxation

under a subsection of section 501(c) of the Internal Revenue Code that was excluded from PPP

eligibility until after the date on which the SBA approved the loan, as shown on the table

attached hereto.

        149.   By making the foregoing false certifications, each such defendant and the

individual defendants acting on its behalf did knowingly present, or cause to be presented, a false




                                                33
      Case 1:24-cv-11950-LTS               Document 24   Filed 08/20/26    Page 34 of 69




claim for payment or approval, and did knowingly make, use, or cause to be made or used, a

false record or statement material to a false claim, in violation of 31 U.S.C. § 3729(a)(1)(A) and

(B), to the injury of the United States.

                                 Second Cause of Action
                    False Claims Act, 31 U.S.C. § 3729(a)(1)(A) and (B)
                           Second-Draw PPP Loan Applications
          (Against the Defendants Listed Below and Unknown John or Jane Does)

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

       151.    The following defendants applied for and received second-draw PPP Loans,

which the SBA approved on the dates and in the amounts shown on the table attached hereto:

               a.      Acoaxet Club Inc.

               b.      Administrators of Special Education Inc.

               c.      American Civic Association Inc. dba Sons of Italy

               d.      Arlington Chamber of Commerce Inc.

               e.      Benevolent & Protective Order of Elks of the USA—Haverhill Lodge No.

                       165

               f.      Bertocci Memorial Club of Brockton Inc.

               g.      Boston Madison Square Garden Club

               h.      Builders and Remodelers Association of Greater Boston Inc.

               i.      Cambridge Chamber of Commerce

               j.      Cape Cod Cranberry Growers’ Association

               k.      Club Franco American de Westford Massachusetts

               l.      Concord Chamber of Commerce

               m.      Cottage Park Yacht Club Inc.

               n.      Dennis Yacht Club Inc.



                                                  34
Case 1:24-cv-11950-LTS     Document 24       Filed 08/20/26      Page 35 of 69




      o.    Employers Association of the Northeast Inc.

      p.    Everett Chamber of Commerce Inc.

      q.    Fall River Country Club

      r.    Grand Lodge of Theta Delta Chi Inc.

      s.    Greater Chicopee Chamber of Commerce Inc.

      t.    Greylock Community Club Inc.

      u.    H. E. Fletcher Social & Athletic Club Inc.

      v.    Hampden County Bar Association Inc.

      w.    Holyoke Canoe Club Inc.

      x.    Irish-American Club Inc. of Woburn

      y.    John Alden Sportsmen’s Club Inc.

      z.    Knights of Columbus dba Cardinal Spellman Council 347

      aa.   Lakeville Aerie No. 3944 Fraternal Order of Eagles

      ab.   Ludlow Fish & Game Club Inc.

      ac.   Malden Lodge No. 1910 Loyal Order of Moose

      ad.   Massachusetts Association of Accountants Inc.

      ae.   Massachusetts Chiefs of Police Association Inc.

      af.   Massachusetts LGBT Chamber of Commerce

      ag.   Massachusetts Systems Contractors Association Inc.

      ah.   Nabnasset Lake Country Club Inc.

      ai.   New Bedford Sports Club Inc.

      aj.   North Shore Tennis & Squash Club Inc.

      ak.   North of Boston Convention & Visitors Bureau Inc.




                                      35
Case 1:24-cv-11950-LTS     Document 24        Filed 08/20/26   Page 36 of 69




      al.   Orleans Yacht Club Inc.

      am.   Outdoor Amusement Business Association Inc.

      an.   Plymouth Country Club Inc.

      ao.   Salem Chamber of Commerce & Civics

      ap.   Salem Office of Tourism & Cultural Affairs Inc. dba Destination Salem

      aq.   Singletary Rod & Gun Club Inc.

      ar.   Sons of Italy in America—Quincy Lodge No. 1295

      as.   Stoneham Chamber of Commerce Inc.

      at.   Swampscott Yacht Club

      au.   Tennis and Racquet Club

      av.   The Advertising Club of Greater Boston Inc. dba The Ad Club

      aw.   The Fay Club

      ax.   The New England Affordable Housing Management Association Inc.

      ay.   The North Shore Chamber of Commerce, Inc.

      az.   The Old Colony Yacht Club

      ba.   The Plymouth Area Chamber of Commerce Inc.

      bb.   The Polish Club Lodge 2058 Inc.

      bc.   Town River Yacht Club

      bd.   Wequaquet Lake Yacht Club

      be.   West Dennis Yacht Club Inc.

      bf.   Wood Products Manufacturers Association

      bg.   Young Men’s Club of Hadley Inc.




                                      36
        Case 1:24-cv-11950-LTS        Document 24       Filed 08/20/26     Page 37 of 69




        152.   On its application form for its second-draw PPP Loan, each of these defendants

certified: “The Applicant is eligible to receive a loan under the rules in effect at the time this

application is submitted that have been issued by the Small Business Administration (SBA) and

the Department of the Treasury (Treasury) implementing Second Draw Paycheck Protection

Program Loans . . .”

        153.   Each such certification was required as a material prerequisite to receive a PPP

Loan.

        154.   Each such certification was false and known by the certifying defendant and the

individual defendants acting on its behalf to be false within the meaning of the False Claims Act.

Each of these defendants was ineligible for its second-draw PPP Loan because its first-draw PPP

Loan had been unlawfully obtained and receipt of a first-draw loan was a prerequisite to receive

a second-draw loan, rendering the second-draw PPP Loan unlawful as “fruit of the poisonous

tree.” Defendants American Civic Association Inc. dba Sons of Italy, Benevolent & Protective

Order of Elks of the USA—Haverhill Lodge No. 165, Bertocci Memorial Club of Brockton Inc.,

Club Franco American de Westford Massachusetts, Cottage Park Yacht Club Inc., Dennis Yacht

Club Inc., Fall River Country Club, Greylock Community Club Inc., H. E. Fletcher Social &

Athletic Club Inc., Holyoke Canoe Club Inc., Irish-American Club Inc. of Woburn, John Alden

Sportsmen’s Club Inc., Knights of Columbus dba Cardinal Spellman Council 347, Ludlow Fish

& Game Club Inc., Nabnasset Lake Country Club Inc., North Shore Tennis & Squash Club Inc.,

Orleans Yacht Club Inc., Sons of Italy in America—Quincy Lodge No. 1295, Swampscott Yacht

Club, Tennis and Racquet Club, The Old Colony Yacht Club, The Polish Club Lodge 2058 Inc.,

Town River Yacht Club, Wequaquet Lake Yacht Club, West Dennis Yacht Club Inc., and Young

Men’s Club of Hadley Inc. were also ineligible because each was exempt from taxation under a




                                               37
      Case 1:24-cv-11950-LTS               Document 24   Filed 08/20/26     Page 38 of 69




subsection of section 501(c) of the Internal Revenue Code that was excluded from PPP eligibility

until after the date on which SBA approved the loan, as shown on the table attached hereto.

       155.    By making the foregoing false certifications, each such defendant and the

individual defendants acting on its behalf did knowingly present, or cause to be presented, a false

claim for payment or approval, and did knowingly make, use, or cause to be made or used, a

false record or statement material to a false claim, in violation of 31 U.S.C. § 3729(a)(1)(A) and

(B), to the injury of the United States.

                                  Third Cause of Action
                    False Claims Act, 31 U.S.C. § 3729(a)(1)(A) and (B)
                  PPP Loan Applications of the Private Club Defendants
          (Against the Private Club Defendants and Unknown John or Jane Does)

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

       157.    The Private Club defendants are the following:

               a.      Acoaxet Club Inc.

               b.      American Civic Association Inc. dba Sons of Italy

               c.      Benevolent & Protective Order of Elks of the USA—Fall River Lodge No.

                       118

               d.      Benevolent & Protective Order of Elks of the USA—Haverhill Lodge No.

                       165

               e.      Benevolent & Protective Order of Elks of the USA—Waltham-Watertown

                       Lodge No. 953

               f.      Bertocci Memorial Club of Brockton Inc.

               g.      Billerica Lodge No. 2648 Loyal Order of Moose

               h.      Boston Madison Square Garden Club

               i.      Brockton Country Club Inc.



                                                  38
Case 1:24-cv-11950-LTS      Document 24       Filed 08/20/26     Page 39 of 69




      j.    Clube Desportivo Faialense Inc.

      k.    Cohasse Country Club

      l.    Cottage Park Yacht Club Inc.

      m.    Dennis Yacht Club Inc.

      n.    Fall River Country Club

      o.    Grand Lodge of Theta Delta Chi Inc.

      p.    Greenfield Lodge No. 997 Loyal Order of Moose

      q.    Gremio Lusitano Club Inc.

      r.    Greylock Community Club Inc.

      s.    Irish-American Club Inc. of Woburn

      t.    Italian Naturalization Club Inc. of Taunton

      u.    Jubilee Yacht Club

      v.    Knights of Columbus dba Cardinal Spellman Council 347

      w.    Lafayette Naturalization Club Inc.

      x.    Lakeville Aerie No. 3944 Fraternal Order of Eagles

      y.    Lexington Golf Club

      z.    Ludlow Country Club Inc.

      aa.   Ludlow Fish & Game Club Inc.

      ab.   Malden Lodge No. 1910 Loyal Order of Moose

      ac.   Marshfield Country Club

      ad.   Master, Wardens, and Members of The Grand Lodge of Masons in

            Massachusetts

      ae.   Milton Hoosic Club Inc.




                                      39
Case 1:24-cv-11950-LTS     Document 24       Filed 08/20/26   Page 40 of 69




      af.   Minute Man Sportsmans Club Inc.

      ag.   Nabnasset Lake Country Club Inc.

      ah.   New Bedford Sports Club Inc.

      ai.   North Shore Skating Club Inc.

      aj.   Orleans Yacht Club Inc.

      ak.   Palmer’s Cove Yacht Club Inc.

      al.   Pleasant Park Yacht Club Inc.

      am.   Plymouth Country Club Inc.

      an.   Point Independence Yacht Club Inc.

      ao.   Polish American Veterans of Webster Inc.

      ap.   Portuguese National Club

      aq.   Prince Hall Masonic Grand Lodge

      ar.   Rowley Veterans’ Association Inc.

      as.   Sandy Bay Yacht Club, Inc.

      at.   Singletary Rod & Gun Club Inc.

      au.   Sons of Italy in America—Grand Lodge of Massachusetts

      av.   Sons of Italy in America—Methuen Lodge No. 902

      aw.   Sons of Italy in America—Quincy Lodge No. 1295

      ax.   Stockbridge Golf Club

      ay.   Supreme Council of the Royal Arcanum

      az.   Swampscott Yacht Club

      ba.   Tennis and Racquet Club

      bb.   The Fay Club




                                      40
      Case 1:24-cv-11950-LTS           Document 24        Filed 08/20/26       Page 41 of 69




               bc.     The Old Colony Yacht Club

               bd.     The Polish Club Lodge 2058 Inc.

               be.     Town River Yacht Club

               bf.     Volunteer Yacht Club

               bg.     Wampatuck Country Club of Canton Inc.

               bh.     Wequaquet Lake Yacht Club

               bi.     West Dennis Yacht Club Inc.

               bj.     West End Beagle Club Inc. of Gardner

               bk.     Whitinsville Golf Club

               bl.     Winthrop Yacht Club Inc.

       158.    Each Private Club defendant applied for and received one or more PPP Loans,

which the SBA approved on the dates and in the amounts shown on the table attached hereto.

       159.    On its application form for each PPP Loan it received, each Private Club

defendant certified that “The Applicant is eligible to receive a loan under the rules in effect at the

time this application is submitted that have been issued by the Small Business Administration

(SBA) . . . ,” as quoted more fully in the First and Second Causes of Action. Each such

certification was required as a material prerequisite to receive a PPP Loan.

       160.    Each such certification was false and known by the certifying Private Club

defendant and the individual defendants acting on its behalf to be false within the meaning of the

False Claims Act, because each Private Club defendant was a Private Club, which was at all

times excluded from PPP eligibility.

       161.    By making the foregoing false certifications, each such defendant and the

individual defendants acting on its behalf did knowingly present, or cause to be presented, a false




                                                 41
      Case 1:24-cv-11950-LTS               Document 24   Filed 08/20/26    Page 42 of 69




claim for payment or approval, and did knowingly make, use, or cause to be made or used, a

false record or statement material to a false claim, in violation of 31 U.S.C. § 3729(a)(1)(A) and

(B), to the injury of the United States.

                                Fourth Cause of Action
                 False Claims Act, 31 U.S.C. § 3729(a)(1)(A), (B), and (G)
                     First-Draw PPP Loan Forgiveness Applications
(Against All Defendants Except Those Identified Below, and Unknown John or Jane Does)

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

       163.    Each defendant except Defendants Benevolent & Protective Order of Elks of the

USA—Fall River Lodge No. 118, Jubilee Yacht Club, Master, Wardens, and Members of The

Grand Lodge of Masons in Massachusetts, Sons of Italy in America—Methuen Lodge No. 902,

Stockbridge Golf Club, and The Proprietors of Forest Hills Cemetery applied for and obtained

forgiveness of its first-draw PPP Loan by submitting a forgiveness application form to its lender.

SBA forgave each such loan on the date and in the amount shown on the table attached hereto.

The forgiveness status of the first-draw PPP Loans of the six excepted defendants is unknown to

Relator, and those defendants are not included in this Count.

       164.    On the forgiveness application forms for their first-draw PPP Loans, the following

defendants each certified: “The Borrower has complied with all requirements in the Paycheck

Protection Program Rules (Sections 7(a)(36), (7)(a)(37), and 7A of the Small Business Act, the

PPP interim final rules, and guidance issued by SBA through the date of this application)”:

               a.      Administrators of Special Education Inc.

               b.      American Civic Association Inc. dba Sons of Italy

               c.      Arlington Chamber of Commerce Inc.

               d.      Benevolent & Protective Order of Elks of the USA—Haverhill Lodge No.

                       165



                                                  42
Case 1:24-cv-11950-LTS      Document 24       Filed 08/20/26   Page 43 of 69




      e.    Benevolent & Protective Order of Elks of the USA—Waltham-Watertown

            Lodge No. 953

      f.    Berkshire County Board of Realtors Inc

      g.    Bertocci Memorial Club of Brockton Inc.

      h.    Billerica Lodge No. 2648 Loyal Order of Moose

      i.    Boston Madison Square Garden Club

      j.    Bridgewater Citizens’ Club Inc.

      k.    Brockton Country Club Inc.

      l.    Cambridge Chamber of Commerce

      m.    Cape Cod Cranberry Growers’ Association

      n.    Clube Desportivo Faialense Inc.

      o.    Cohasse Country Club

      p.    Construction Industries of Massachusetts Inc.

      q.    Cottage Park Yacht Club Inc.

      r.    Curve Triangle & Rectangle Institute Inc.

      s.    Dennis Yacht Club Inc.

      t.    Edgewood Club Inc.

      u.    Ellinwood Country Club Inc.

      v.    Everett Chamber of Commerce Inc.

      w.    Forestdale Cemetery Association

      x.    Grand Lodge of Theta Delta Chi Inc.

      y.    Greater Chicopee Chamber of Commerce Inc.

      z.    Greenfield Lodge No. 997 Loyal Order of Moose




                                     43
Case 1:24-cv-11950-LTS     Document 24       Filed 08/20/26      Page 44 of 69




      aa.   Gremio Lusitano Club Inc.

      ab.   Hampden County Bar Association Inc.

      ac.   Harvard Square Business Association Inc.

      ad.   Italian Naturalization Club Inc. of Taunton

      ae.   Knights of Columbus dba Cardinal Spellman Council 347

      af.   Lafayette Naturalization Club Inc.

      ag.   Lakeville Aerie No. 3944 Fraternal Order of Eagles

      ah.   Longwood Covered Courts Trust

      ai.   Ludlow Country Club Inc.

      aj.   Ludlow Fish & Game Club Inc.

      ak.   Ludlow Tennis Club Inc.

      al.   Malden Lodge No. 1910 Loyal Order of Moose

      am.   Marblehead Yacht Club Inc.

      an.   Massachusetts Association of Accountants Inc.

      ao.   Massachusetts Chiefs of Police Association Inc.

      ap.   Massachusetts LGBT Chamber of Commerce

      aq.   Minute Man Sportsmans Club Inc.

      ar.   National Board of Trial Advocacy Inc.

      as.   New Bedford Sports Club Inc.

      at.   North Shore Tennis & Squash Club Inc.

      au.   North of Boston Convention & Visitors Bureau Inc.

      av.   Oak Grove Cemetery Association of Falmouth Inc.

      aw.   Outdoor Amusement Business Association Inc.




                                     44
Case 1:24-cv-11950-LTS     Document 24        Filed 08/20/26   Page 45 of 69




      ax.   Palmer’s Cove Yacht Club Inc.

      ay.   Pine Grove Cemetery Corporation

      az.   Pleasant Park Yacht Club Inc.

      ba.   Point Independence Yacht Club Inc.

      bb.   Polish American Veterans of Webster Inc.

      bc.   Portuguese National Club

      bd.   Prince Hall Masonic Grand Lodge

      be.   Rowley Veterans’ Association Inc.

      bf.   Salem Chamber of Commerce & Civics

      bg.   Salem Office of Tourism & Cultural Affairs Inc. dba Destination Salem

      bh.   Singletary Rod & Gun Club Inc.

      bi.   Sons of Italy in America—Grand Lodge of Massachusetts

      bj.   Stoneham Chamber of Commerce Inc.

      bk.   Swampscott Yacht Club

      bl.   Tennis and Racquet Club

      bm.   The Fay Club

      bn.   The New England Affordable Housing Management Association Inc.

      bo.   The North Shore Chamber of Commerce, Inc.

      bp.   The Old Colony Yacht Club

      bq.   The Polish Club Lodge 2058 Inc.

      br.   Volunteer Yacht Club

      bs.   Wampatuck Country Club of Canton Inc.

      bt.   West Dennis Yacht Club Inc.




                                    45
      Case 1:24-cv-11950-LTS           Document 24        Filed 08/20/26      Page 46 of 69




               bu.     West End Beagle Club Inc. of Gardner

               bv.     Whitinsville Golf Club

               bw.     Winthrop Golf Club

               bx.     Winthrop Yacht Club Inc.

               by.     Young Men’s Club of Hadley Inc.

       165.    Each of the other defendants included in this Count certified on the forgiveness

application form for its first-draw PPP Loan: “The information provided in this application and

the information provided in all supporting documents and forms is true and correct in all material

respects.”

       166.    Each forgiveness application form further advised the borrower that “SBA may

direct a lender to disapprove the Borrower’s loan forgiveness application if SBA determines that

the Borrower was ineligible for the PPP loan.”

       167.    Each certification described above was required as a material prerequisite to

obtain forgiveness of a PPP Loan.

       168.    Each such certification was false and known by the certifying defendant and the

individual defendants acting on its behalf to be false within the meaning of the False Claims Act,

because each such defendant had been ineligible to receive its first-draw PPP Loan, as set forth

in the First Cause of Action, and therefore was not entitled to forgiveness of that loan.

       169.    By making the foregoing false certifications, each such defendant and the

individual defendants acting on its behalf did knowingly present, or cause to be presented, a false

claim for payment or approval, did knowingly make, use, or cause to be made or used, a false

record or statement material to a false claim, and did knowingly conceal, or knowingly and

improperly avoid or decrease, an obligation to pay or transmit money or property to the United




                                                 46
      Case 1:24-cv-11950-LTS           Document 24        Filed 08/20/26     Page 47 of 69




States government, in violation of 31 U.S.C. § 3729(a)(1)(A), (B), and (G), to the injury of the

United States.

                                  Fifth Cause of Action
                False Claims Act, 31 U.S.C. § 3729(a)(1)(A), (B), and (G)
                   Second-Draw PPP Loan Forgiveness Applications
(Against the Defendants Listed in the Second Cause of Action and Unknown John or Jane
                                          Does)

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

       171.      The defendants listed in the Second Cause of Action each applied for and

obtained forgiveness of their second-draw PPP Loans by submitting forgiveness application

forms to their lenders. SBA forgave each such loan on the dates and in the amounts shown on the

table attached hereto.

       172.      On the forgiveness application forms for their second-draw PPP Loans,

Defendants Employers Association of the Northeast Inc., Fall River Country Club, Plymouth

Country Club Inc., and The Advertising Club of Greater Boston Inc. dba The Ad Club each

certified: “The information provided in this application and the information provided in all

supporting documents and forms is true and correct in all material respects.”

       173.      Each of the other defendants listed in the Second Cause of Action certified on the

forgiveness application form for its second-draw PPP Loan: “The Borrower has complied with

all requirements in the Paycheck Protection Program Rules (Sections 7(a)(36), (7)(a)(37), and 7A

of the Small Business Act, the PPP interim final rules, and guidance issued by SBA through the

date of this application)”.

       174.      Each forgiveness application form further advised the borrower that “SBA may

direct a lender to disapprove the Borrower’s loan forgiveness application if SBA determines that

the Borrower was ineligible for the PPP loan.”




                                                 47
      Case 1:24-cv-11950-LTS           Document 24        Filed 08/20/26     Page 48 of 69




       175.      Each certification described above was required as a material prerequisite to

obtain forgiveness of a PPP Loan.

       176.      Each such certification was false and known by the certifying defendant and the

individual defendants acting on its behalf to be false within the meaning of the False Claims Act,

because each of these defendants had been ineligible to receive its second-draw PPP Loan, as set

forth in the Second Cause of Action, and therefore was not entitled to forgiveness of that loan.

       177.      By making the foregoing false certifications, each such defendant and the

individual defendants acting on its behalf did knowingly present, or cause to be presented, a false

claim for payment or approval, did knowingly make, use, or cause to be made or used, a false

record or statement material to a false claim, and did knowingly conceal, or knowingly and

improperly avoid or decrease, an obligation to pay or transmit money or property to the United

States government, in violation of 31 U.S.C. § 3729(a)(1)(A), (B), and (G), to the injury of the

United States.

                                  Sixth Cause of Action
                 False Claims Act, 31 U.S.C. § 3729(a)(1)(A), (B), and (G)
            PPP Loan Forgiveness Applications of the Private Club Defendants
 (Against the Private Club Defendants Identified Below and Unknown John or Jane Does)

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

       179.      Each Private Club defendant except Defendants Benevolent & Protective Order of

Elks of the USA—Fall River Lodge No. 118, Jubilee Yacht Club, Master, Wardens, and

Members of The Grand Lodge of Masons in Massachusetts, Sons of Italy in America—Methuen

Lodge No. 902, and Stockbridge Golf Club applied for and obtained forgiveness of each of its

PPP Loans by submitting forgiveness application forms to its lender. SBA forgave each such

loan on the dates and in the amounts shown on the table attached hereto. The forgiveness status




                                                 48
      Case 1:24-cv-11950-LTS          Document 24        Filed 08/20/26   Page 49 of 69




of the PPP Loans of the five excepted defendants is unknown to Relator, and those defendants

are not included in this Count.

       180.    On the forgiveness application forms for the PPP Loans identified below, the

following Private Club defendants each certified: “The Borrower has complied with all

requirements in the Paycheck Protection Program Rules (Sections 7(a)(36), (7)(a)(37), and 7A of

the Small Business Act, the PPP interim final rules, and guidance issued by SBA through the

date of this application)”:

               a.      Acoaxet Club Inc. (second-draw)

               b.      American Civic Association Inc. dba Sons of Italy (first- and second-

                       draw)

               c.      Benevolent & Protective Order of Elks of the USA—Haverhill Lodge No.

                       165 (first- and second-draw)

               d.      Benevolent & Protective Order of Elks of the USA—Waltham-Watertown

                       Lodge No. 953 (first-draw)

               e.      Bertocci Memorial Club of Brockton Inc. (first- and second-draw)

               f.      Billerica Lodge No. 2648 Loyal Order of Moose (first-draw)

               g.      Boston Madison Square Garden Club (first- and second-draw)

               h.      Brockton Country Club Inc. (first-draw)

               i.      Clube Desportivo Faialense Inc. (first-draw)

               j.      Cohasse Country Club (first-draw)

               k.      Cottage Park Yacht Club Inc. (first- and second-draw)

               l.      Dennis Yacht Club Inc. (first- and second-draw)

               m.      Grand Lodge of Theta Delta Chi Inc. (first- and second-draw)




                                               49
Case 1:24-cv-11950-LTS     Document 24        Filed 08/20/26     Page 50 of 69




      n.    Greenfield Lodge No. 997 Loyal Order of Moose (first-draw)

      o.    Gremio Lusitano Club Inc. (first-draw)

      p.    Greylock Community Club Inc. (second-draw)

      q.    Irish-American Club Inc. of Woburn (second-draw)

      r.    Italian Naturalization Club Inc. of Taunton (first-draw)

      s.    Knights of Columbus dba Cardinal Spellman Council 347 (first- and

            second-draw)

      t.    Lafayette Naturalization Club Inc. (first-draw)

      u.    Lakeville Aerie No. 3944 Fraternal Order of Eagles (first- and second-

            draw)

      v.    Ludlow Country Club Inc. (first-draw)

      w.    Ludlow Fish & Game Club Inc. (first- and second-draw)

      x.    Malden Lodge No. 1910 Loyal Order of Moose (first- and second-draw)

      y.    Minute Man Sportsmans Club Inc. (first-draw)

      z.    Nabnasset Lake Country Club Inc. (second-draw)

      aa.   New Bedford Sports Club Inc. (first- and second-draw)

      ab.   Orleans Yacht Club Inc. (second-draw)

      ac.   Palmer’s Cove Yacht Club Inc. (first-draw)

      ad.   Pleasant Park Yacht Club Inc. (first-draw)

      ae.   Point Independence Yacht Club Inc. (first-draw)

      af.   Polish American Veterans of Webster Inc. (first-draw)

      ag.   Portuguese National Club (first-draw)

      ah.   Prince Hall Masonic Grand Lodge (first-draw)




                                     50
      Case 1:24-cv-11950-LTS         Document 24       Filed 08/20/26     Page 51 of 69




               ai.    Rowley Veterans’ Association Inc. (first-draw)

               aj.    Singletary Rod & Gun Club Inc. (first- and second-draw)

               ak.    Sons of Italy in America—Grand Lodge of Massachusetts (first-draw)

               al.    Sons of Italy in America—Quincy Lodge No. 1295 (second-draw)

               am.    Swampscott Yacht Club (first- and second-draw)

               an.    Tennis and Racquet Club (first- and second-draw)

               ao.    The Fay Club (first- and second-draw)

               ap.    The Old Colony Yacht Club (first- and second-draw)

               aq.    The Polish Club Lodge 2058 Inc. (first- and second-draw)

               ar.    Town River Yacht Club (second-draw)

               as.    Volunteer Yacht Club (first-draw)

               at.    Wampatuck Country Club of Canton Inc. (first-draw)

               au.    Wequaquet Lake Yacht Club (second-draw)

               av.    West Dennis Yacht Club Inc. (first- and second-draw)

               aw.    West End Beagle Club Inc. of Gardner (first-draw)

               ax.    Whitinsville Golf Club (first-draw)

               ay.    Winthrop Yacht Club Inc. (first-draw)

       181.    On the forgiveness application forms for the PPP Loans identified below, the

following Private Club defendants each certified: “The information provided in this application

and the information provided in all supporting documents and forms is true and correct in all

material respects”:

               a.     Acoaxet Club Inc. (first-draw)

               b.     Fall River Country Club (first- and second-draw)




                                              51
      Case 1:24-cv-11950-LTS          Document 24        Filed 08/20/26    Page 52 of 69




               c.     Greylock Community Club Inc. (first-draw)

               d.     Irish-American Club Inc. of Woburn (first-draw)

               e.     Lexington Golf Club (first-draw)

               f.     Marshfield Country Club (first-draw)

               g.     Milton Hoosic Club Inc. (first-draw)

               h.     Nabnasset Lake Country Club Inc. (first-draw)

               i.     North Shore Skating Club Inc. (first-draw)

               j.     Orleans Yacht Club Inc. (first-draw)

               k.     Plymouth Country Club Inc. (first- and second-draw)

               l.     Sandy Bay Yacht Club Inc. (first-draw)

               m.     Sons of Italy in America—Quincy Lodge No. 1295 (first-draw)

               n.     Supreme Council of the Royal Arcanum (first-draw)

               o.     Town River Yacht Club (first-draw)

               p.     Wequaquet Lake Yacht Club (first-draw)

       182.    Each forgiveness application form further advised the borrower that “SBA may

direct a lender to disapprove the Borrower’s loan forgiveness application if SBA determines that

the Borrower was ineligible for the PPP loan.”

       183.    Each certification described above was required as a material prerequisite to

obtain forgiveness of a PPP Loan.

       184.    Each such certification was false and known by the certifying Private Club

defendant and the individual defendants acting on its behalf to be false within the meaning of the

False Claims Act, because each Private Club defendant was a Private Club, which was at all




                                                 52
      Case 1:24-cv-11950-LTS           Document 24        Filed 08/20/26      Page 53 of 69




times excluded from PPP eligibility, and therefore was neither entitled to receive nor entitled to

forgiveness of any PPP Loan.

       185.      By making the foregoing false certifications, each such defendant and the

individual defendants acting on its behalf did knowingly present, or cause to be presented, a false

claim for payment or approval, did knowingly make, use, or cause to be made or used, a false

record or statement material to a false claim, and did knowingly conceal, or knowingly and

improperly avoid or decrease, an obligation to pay or transmit money or property to the United

States government, in violation of 31 U.S.C. § 3729(a)(1)(A), (B), and (G), to the injury of the

United States.

                                         Prayer for Relief

       186.      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

                        the 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.

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




                                                 53
      Case 1:24-cv-11950-LTS         Document 24      Filed 08/20/26   Page 54 of 69




                                   Demand for Jury Trial

       187.   Relator demands a trial by jury.

Respectfully submitted,

/s/

Bruce Ellis Fein

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




                                                 54
                              Case 1:24-cv-11950-LTS         Document 24          Filed 08/20/26      Page 55 of 69

                              United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.
                                                            Defendants՚ PPP Loans

                                                                             Date          Date            Loan         Forgiveness   Amount
           Name                 Type         Loan No.        Draw           Eligible     Approved         Amount           Date       Forgiven

Acoaxet Club Inc.             501(c)(7)      8024327705       1st            Never        5/1/2020        $192,096.00   11/12/2020    $193,090.69

Acoaxet Club Inc.             501(c)(7)      3575248803       2nd            Never        4/15/2021       $120,957.00    8/20/2021    $121,371.24

Administrators of Special
                              501(c)(6)      3499357410       1st          12/27/2020     5/7/2020         $20,877.00    3/25/2021     $21,060.60
Education Inc.

Administrators of Special
                              501(c)(6)      4646418602       2nd          12/27/2020     3/18/2021        $20,877.00    9/15/2021     $20,979.38
Education Inc.

The Advertising Club of
Greater Boston Inc. dba The   501(c)(6)      6537807104       1st          12/27/2020     4/14/2020       $269,000.00    2/23/2021    $271,262.55
Ad Club

The Advertising Club of
Greater Boston Inc. dba The   501(c)(6)      8124848505       2nd          12/27/2020     3/9/2021        $221,455.00    11/9/2021    $222,880.81
Ad Club

American Civic Association
                              501(c)(8)      3013757206       1st            Never        4/16/2020         $9,930.00    2/12/2021      $9,998.54
Inc. dba Sons of Italy

American Civic Association
                              501(c)(8)      6083108510       2nd            Never        3/2/2021          $9,930.00    9/22/2021      $9,985.44
Inc. dba Sons of Italy

Amherst Golf Club Inc.        501(c)(7)      5535637103       1st          3/11/2021      4/13/2020        $30,000.00    1/14/2021     $30,219.45

Arlington Chamber of
                              501(c)(6)      4072917200       1st          12/27/2020     4/27/2020         $9,932.00    1/28/2021     $10,006.56
Commerce Inc.

Arlington Chamber of
                              501(c)(6)      3143398308       2nd          12/27/2020     1/21/2021         $9,931.73   10/25/2021     $10,006.29
Commerce Inc.

Bar Association of Norfolk
                              501(c)(6)      2574527202       1st          12/27/2020     4/16/2020         $8,100.00   11/12/2020      $8,143.72
County Inc.




                                                                       1
                            Case 1:24-cv-11950-LTS         Document 24          Filed 08/20/26      Page 56 of 69

                            United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.
                                                          Defendants՚ PPP Loans

                                                                           Date          Date            Loan         Forgiveness   Amount
           Name               Type         Loan No.        Draw           Eligible     Approved         Amount           Date       Forgiven

Benevolent & Protective
Order of Elks of the USA—   501(c)(8)      6183517309       1st            Never        4/30/2020        $27,700.00    Unknown        Unknown
Fall River Lodge No. 118

Benevolent & Protective
Order of Elks of the USA—   501(c)(8)      4840527401       1st            Never        5/11/2020        $17,500.00    8/5/2021      $17,716.81
Haverhill Lodge No. 165

Benevolent & Protective
Order of Elks of the USA—   501(c)(8)      8998738301       2nd            Never        1/30/2021        $17,582.00    8/10/2021     $17,673.33
Haverhill Lodge No. 165

Benevolent & Protective
Order of Elks of the USA—
                            501(c)(8)      8976137203       1st            Never        4/28/2020        $21,000.00    6/16/2021     $21,236.47
Waltham-Watertown Lodge
No. 953

Berkshire County Board of
                            501(c)(6)      9267417304       1st          12/27/2020     5/1/2020         $30,705.00    3/31/2021     $30,986.46
Realtors Inc

Bertocci Memorial Club of
                            501(c)(7)      1253177209       1st            Never        4/15/2020        $18,750.00    7/28/2021     $18,990.10
Brockton Inc.

Bertocci Memorial Club of
                            501(c)(7)      7658898509       2nd            Never        3/6/2021         $13,750.00    11/3/2021     $13,838.61
Brockton Inc.

Billerica Lodge No. 2648
                            501(c)(8)      8244957403       1st            Never        5/18/2020         $5,284.00    2/9/2021       $5,322.46
Loyal Order of Moose

Boston Madison Square
                            501(c)(7)      7558847806       1st            Never        6/3/2020         $54,800.00    5/20/2021     $55,301.46
Garden Club

Boston Madison Square
                            501(c)(7)      4450188908       2nd            Never        4/29/2021        $54,800.00   10/22/2021     $55,052.23
Garden Club




                                                                     2
                                Case 1:24-cv-11950-LTS         Document 24          Filed 08/20/26      Page 57 of 69

                                United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.
                                                              Defendants՚ PPP Loans

                                                                               Date          Date            Loan         Forgiveness   Amount
           Name                   Type         Loan No.        Draw           Eligible     Approved         Amount           Date       Forgiven

Bridgewater Citizens’ Club
                                501(c)(7)      3300107300       1st          3/11/2021      4/29/2020        $14,200.00    8/18/2021     $14,381.68
Inc.

Brockton Country Club Inc.      501(c)(7)      1747607305       1st            Never        4/28/2020        $39,642.12    9/28/2021     $40,208.12

Builders and Remodelers
Association of Greater Boston   501(c)(6)      1709018104       1st          12/27/2020     7/10/2020        $50,900.00   11/17/2020     $51,068.25
Inc.

Builders and Remodelers
Association of Greater Boston   501(c)(6)      5390718500       2nd          12/27/2020     2/27/2021        $50,900.00    6/23/2021     $51,047.04
Inc.

Cambridge Chamber of
                                501(c)(6)      5765007206       1st          12/27/2020     4/27/2020        $77,500.00    5/10/2021     $78,287.74
Commerce

Cambridge Chamber of
                                501(c)(6)      5388768309       2nd          12/27/2020     1/25/2021        $98,028.33    10/6/2021     $98,705.13
Commerce

Cape Cod Cranberry Growers’
                                501(c)(5)      2427227304       1st          3/11/2021      4/29/2020        $58,873.00   11/17/2021     $59,771.42
Association

Cape Cod Cranberry Growers’
                                501(c)(5)      3193008806       2nd          3/11/2021      4/14/2021        $60,238.00    1/3/2022      $60,630.78
Association

Club Franco American de
                                501(c)(7)      1872287402       1st          3/11/2021      5/5/2020          $8,900.00   12/10/2020      $8,952.41
Westford Massachusetts

Club Franco American de
                                501(c)(7)      6219918408       2nd          3/11/2021      2/10/2021         $9,375.00    9/22/2021      $9,430.99
Westford Massachusetts

Clube Desportivo Faialense
                                501(c)(7)      3795418002       1st            Never        6/25/2020        $14,219.37    6/3/2021      $14,352.21
Inc.

Cohasse Country Club            501(c)(7)      1069827203       1st            Never        4/15/2020        $77,000.00    5/6/2021      $77,812.19




                                                                         3
                               Case 1:24-cv-11950-LTS         Document 24          Filed 08/20/26      Page 58 of 69

                               United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.
                                                             Defendants՚ PPP Loans

                                                                              Date          Date            Loan         Forgiveness   Amount
            Name                 Type         Loan No.        Draw           Eligible     Approved         Amount           Date       Forgiven

Concord Chamber of
                               501(c)(6)      5938017404       1st          12/27/2020     5/13/2020         $7,220.00   10/22/2020      $7,251.09
Commerce

Concord Chamber of
                               501(c)(6)      3878998508       2nd          12/27/2020     2/24/2021         $7,220.00    5/16/2022      $7,307.44
Commerce

Construction Industries of
                               501(c)(6)      9147017210       1st          12/27/2020     4/28/2020        $95,000.00    8/26/2021     $96,241.51
Massachusetts Inc.

Cottage Park Yacht Club Inc.   501(c)(7)      2648048200       1st            Never        8/3/2020         $48,600.00    6/2/2021      $48,998.12

Cottage Park Yacht Club Inc.   501(c)(7)      2551938407       2nd            Never        2/3/2021         $48,600.00    10/6/2021     $48,907.58

Curve Triangle & Rectangle
                               501(c)(6)      8677897306       1st          12/27/2020     5/1/2020         $24,225.00    1/25/2021     $24,399.55
Institute Inc.

Dennis Yacht Club Inc.         501(c)(7)      2980197401       1st            Never        5/6/2020         $62,680.00    2/4/2021      $63,144.88

Dennis Yacht Club Inc.         501(c)(7)      4440278406       2nd            Never        2/6/2021         $49,725.00   10/25/2021     $50,077.22

Edgewood Club Inc.             501(c)(7)      4595348408       1st          3/11/2021      2/6/2021         $27,377.00   12/14/2021     $27,605.77

Ellinwood Country Club Inc.    501(c)(7)      8072197000       1st          3/11/2021      4/8/2020         $31,565.00    2/16/2021     $31,753.98

Employers Association of the
                               501(c)(6)      1058497303       1st          12/27/2020     4/28/2020       $434,000.00   11/12/2020    $405,678.82
Northeast Inc.

Employers Association of the
                               501(c)(6)      3010768406       2nd          12/27/2020     2/4/2021        $417,098.57    6/23/2021    $418,618.41
Northeast Inc.

Everett Chamber of
                               501(c)(6)      6114697204       1st          12/27/2020     4/27/2020         $7,800.00    2/17/2021      $7,861.55
Commerce Inc.

Everett Chamber of
                               501(c)(6)      8218418408       2nd          12/27/2020     2/13/2021         $7,856.22   10/25/2021      $7,906.59
Commerce Inc.




                                                                        4
                              Case 1:24-cv-11950-LTS         Document 24          Filed 08/20/26      Page 59 of 69

                              United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.
                                                            Defendants՚ PPP Loans

                                                                             Date          Date            Loan         Forgiveness   Amount
           Name                 Type         Loan No.        Draw           Eligible     Approved         Amount           Date       Forgiven

Fall River Country Club       501(c)(7)      5181307002       1st            Never        4/5/2020        $314,400.00    1/20/2021    $249,680.56

Fall River Country Club       501(c)(7)      6259378308       2nd            Never        1/26/2021       $253,032.50    1/28/2022    $255,542.03

The Fay Club                  501(c)(7)      9463407004       1st            Never        4/9/2020         $41,500.00    4/5/2021      $41,902.32

The Fay Club                  501(c)(7)      1796328808       2nd            Never        4/11/2021        $44,005.00    8/23/2022     $44,611.29

Forestdale Cemetery
                              501(c)(13)     9450517809       1st          3/11/2021      6/8/2020         $50,700.00    7/22/2021     $51,252.84
Association

Grand Lodge of Theta Delta
                              501(c)(7)      9334437300       1st            Never        5/1/2020         $24,581.00    5/13/2021     $24,832.20
Chi Inc.

Grand Lodge of Theta Delta
                              501(c)(7)      8347738602       2nd            Never        3/24/2021        $27,200.00    9/1/2021      $27,318.49
Chi Inc.

Greater Chicopee Chamber of
                              501(c)(6)      6772447408       1st          12/27/2020     5/15/2020        $13,460.00    3/1/2021      $13,565.81
Commerce Inc.

Greater Chicopee Chamber of
                              501(c)(6)      5005908307       2nd          12/27/2020     1/23/2021        $13,460.00    10/6/2021     $13,547.86
Commerce Inc.

Greenfield Lodge No. 997
                              501(c)(8)      9078527205       1st            Never        4/28/2020        $13,815.00    5/6/2021      $13,953.53
Loyal Order of Moose

Gremio Lusitano Club Inc.     501(c)(7)      1523568401       1st            Never        2/2/2021         $14,870.00    1/11/2022     $15,010.44

Greylock Community Club
                              501(c)(7)      5947458002       1st            Never        6/29/2020        $17,400.00    1/7/2021      $17,488.93
Inc.

Greylock Community Club
                              501(c)(7)      8342198509       2nd            Never        3/9/2021         $15,623.00    8/9/2021      $15,686.79
Inc.




                                                                       5
                               Case 1:24-cv-11950-LTS         Document 24          Filed 08/20/26      Page 60 of 69

                               United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.
                                                             Defendants՚ PPP Loans

                                                                              Date          Date            Loan         Forgiveness   Amount
            Name                 Type         Loan No.        Draw           Eligible     Approved         Amount           Date       Forgiven

H. E. Fletcher Social &
                               501(c)(7)      8742027104       1st          3/11/2021      4/15/2020        $17,029.00   12/31/2020     $17,147.50
Athletic Club Inc.

H. E. Fletcher Social &
                               501(c)(7)      6694768301       2nd          3/11/2021      1/27/2021        $17,035.00    12/8/2021     $17,180.61
Athletic Club Inc.

Hampden County Bar
                               501(c)(6)      8283407209       1st          12/27/2020     4/28/2020       $103,000.00    4/6/2021      $66,877.63
Association Inc.

Hampden County Bar
                               501(c)(6)      6337348502       2nd          12/27/2020     3/3/2021         $58,107.00    1/19/2022     $58,608.47
Association Inc.

Harvard Square Business
                               501(c)(6)      4777887204       1st          12/27/2020     4/27/2020        $52,500.00    4/12/2021     $52,989.04
Association Inc.

Holyoke Canoe Club Inc.        501(c)(7)      1192927400       1st          3/11/2021      5/4/2020          $8,800.00   12/17/2020      $8,854.25

Holyoke Canoe Club Inc.        501(c)(7)      3534228507       2nd          3/11/2021      2/24/2021         $8,352.50    1/12/2022      $8,425.96

International Brotherhood of
Electrical Workers Building    501(c)(2)      6674497103       1st          3/11/2021      4/14/2020       $166,200.00   12/17/2020    $167,238.75
Corporation

Irish-American Club Inc. of
                               501(c)(7)      8490947210       1st            Never        4/28/2020        $17,517.00    11/2/2020     $17,604.10
Woburn

Irish-American Club Inc. of
                               501(c)(7)      1797418410       2nd            Never        2/2/2021         $16,100.00    1/18/2022     $16,253.40
Woburn

Italian Naturalization Club
                               501(c)(7)      4358648400       1st            Never        2/6/2021         $19,815.00    5/10/2022     $20,063.24
Inc. of Taunton

John Alden Sportsmen’s Club
                               501(c)(7)      8718727200       1st          3/11/2021      4/28/2020        $27,293.00   12/17/2020     $27,373.78
Inc.




                                                                        6
                                Case 1:24-cv-11950-LTS         Document 24          Filed 08/20/26      Page 61 of 69

                                United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.
                                                              Defendants՚ PPP Loans

                                                                               Date          Date            Loan         Forgiveness   Amount
            Name                  Type         Loan No.        Draw           Eligible     Approved         Amount           Date       Forgiven

John Alden Sportsmen’s Club
                                501(c)(7)      5403658506       2nd          3/11/2021      2/27/2021        $27,292.00    9/1/2021      $27,429.22
Inc.

Jubilee Yacht Club              501(c)(7)      9738897000       1st            Never        4/9/2020         $65,600.00    Unknown        Unknown

Knights of Columbus dba
Cardinal Spellman Council       501(c)(8)      5796807910       1st            Never        6/16/2020        $11,729.00    2/3/2022      $11,917.31
347

Knights of Columbus dba
Cardinal Spellman Council       501(c)(8)      6905598506       2nd            Never        3/4/2021         $11,310.00    2/3/2022      $11,413.49
347

Lafayette Naturalization Club
                                501(c)(7)      1756868409       1st            Never        2/2/2021         $16,200.00   12/28/2021     $10,153.02
Inc.

Lakeville Aerie No. 3944
                                501(c)(8)      1258607206       1st            Never        4/15/2020        $16,250.00    2/16/2021     $15,037.58
Fraternal Order of Eagles

Lakeville Aerie No. 3944
                                501(c)(8)      4962688702       2nd            Never        4/1/2021         $14,917.00    9/27/2021     $14,989.51
Fraternal Order of Eagles

Lenox Chamber of Commerce       501(c)(6)      4044067807       1st          12/27/2020     5/27/2020        $10,715.00   11/12/2020     $10,763.73

Lexington Golf Club             501(c)(7)      3956757201       1st            Never        4/27/2020        $12,800.00   11/27/2020     $12,875.02

Longwood Covered Courts
                                501(c)(7)      1282337404       1st          3/11/2021      5/4/2020         $12,148.42    5/20/2021     $12,275.30
Trust

Ludlow Country Club Inc.        501(c)(7)      4339237110       1st            Never        4/13/2020        $26,100.00    7/20/2021     $26,428.43

Ludlow Fish & Game Club
                                501(c)(7)      2807187405       1st            Never        5/6/2020         $15,917.00    6/17/2021     $16,093.18
Inc.




                                                                         7
                               Case 1:24-cv-11950-LTS         Document 24          Filed 08/20/26      Page 62 of 69

                               United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.
                                                             Defendants՚ PPP Loans

                                                                              Date          Date            Loan         Forgiveness   Amount
           Name                  Type         Loan No.        Draw           Eligible     Approved         Amount           Date       Forgiven

Ludlow Fish & Game Club
                               501(c)(7)      6016288300       2nd            Never        1/26/2021         $7,335.00   10/25/2021      $7,387.65
Inc.

Ludlow Tennis Club Inc.        501(c)(7)      4846367402       1st          3/11/2021      5/11/2020        $26,300.00    8/24/2021     $26,637.52

Malden Lodge No. 1910
                               501(c)(8)      6714318010       1st            Never        6/30/2020         $6,625.00    3/22/2021      $6,673.03
Loyal Order of Moose

Malden Lodge No. 1910
                               501(c)(8)      9706708601       2nd            Never        3/26/2021         $6,625.00    9/28/2021      $6,658.31
Loyal Order of Moose

Marblehead Yacht Club Inc.     501(c)(7)      8043577204       1st          3/11/2021      4/28/2020        $27,265.00    3/2/2021      $27,489.84

Marshfield Country Club        501(c)(7)      7167867009       1st            Never        4/7/2020        $366,490.00    6/23/2021    $370,817.59

Massachusetts Association of
                               501(c)(6)      1856317300       1st          12/27/2020     4/28/2020        $16,800.00    6/14/2021     $16,985.49
Accountants Inc.

Massachusetts Association of
                               501(c)(6)      1890198606       2nd          12/27/2020     3/13/2021        $16,852.50   12/28/2021     $16,987.32
Accountants Inc.

Massachusetts Chiefs of
                               501(c)(6)      3763237104       1st          12/27/2020     4/12/2020        $60,400.00    4/22/2021     $61,014.07
Police Association Inc.

Massachusetts Chiefs of
                               501(c)(6)      6740638506       2nd          12/27/2020     3/4/2021         $58,400.00   11/26/2021     $58,808.80
Police Association Inc.

Massachusetts Farm Bureau
                               501(c)(5)      1838017202       1st          3/11/2021      4/15/2020       $135,367.00   12/31/2020    $136,301.59
Federation Inc.

Massachusetts LGBT
                               501(c)(6)      7520967104       1st          12/27/2020     4/14/2020        $95,000.00    4/12/2021     $95,897.95
Chamber of Commerce

Massachusetts LGBT
                               501(c)(6)      2064048403       2nd          12/27/2020     2/3/2021         $55,252.00    3/22/2022     $55,860.53
Chamber of Commerce




                                                                        8
                               Case 1:24-cv-11950-LTS         Document 24          Filed 08/20/26      Page 63 of 69

                               United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.
                                                             Defendants՚ PPP Loans

                                                                              Date          Date            Loan         Forgiveness   Amount
            Name                 Type         Loan No.        Draw           Eligible     Approved         Amount           Date       Forgiven

Massachusetts Laborers’
                               501(c)(9)      9747417009       1st          3/11/2021      4/9/2020        $500,000.00    7/21/2021    $506,402.78
Health & Welfare Fund

Massachusetts Systems
                               501(c)(6)      2069077208       1st          12/27/2020     4/15/2020        $22,300.00   10/13/2020     $22,402.21
Contractors Association Inc.

Massachusetts Systems
                               501(c)(6)      2292448407       2nd          12/27/2020     2/3/2021         $22,300.00    8/18/2021     $22,417.92
Contractors Association Inc.

Master, Wardens, and
Members of The Grand Lodge     501(c)(10)     9342647108       1st            Never        4/15/2020       $266,600.00    Unknown        Unknown
of Masons in Massachusetts

Milton Hoosic Club Inc.        501(c)(7)      9188897103       1st            Never        4/15/2020       $181,660.00    4/29/2021    $183,522.02

Minute Man Sportsmans Club
                               501(c)(7)      9630277109       1st            Never        4/15/2020        $19,600.00    2/11/2021     $19,755.71
Inc.

Nabnasset Lake Country Club
                               501(c)(7)      8650027303       1st            Never        5/1/2020         $64,400.00    10/8/2020     $64,675.49
Inc.

Nabnasset Lake Country Club
                               501(c)(7)      1792028401       2nd            Never        2/2/2021         $64,471.00    8/13/2021     $64,807.68
Inc.

National Board of Trial
                               501(c)(6)      5112067706       1st          12/27/2020     5/1/2020         $58,777.00    3/19/2021     $59,292.91
Advocacy Inc.

New Bedford Sports Club Inc.   501(c)(7)      2424928510       1st            Never        2/20/2021         $3,045.00    8/11/2021      $3,058.51

New Bedford Sports Club Inc.   501(c)(7)      3520158901       2nd            Never        4/28/2021         $4,263.00    8/13/2021      $4,274.80

The New England Affordable
Housing Management             501(c)(6)      1413488008       1st          12/27/2020     6/22/2020        $31,000.00    3/1/2021      $31,205.53
Association Inc.




                                                                        9
                                Case 1:24-cv-11950-LTS         Document 24          Filed 08/20/26      Page 64 of 69

                                United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.
                                                              Defendants՚ PPP Loans

                                                                               Date          Date            Loan         Forgiveness   Amount
           Name                   Type         Loan No.        Draw           Eligible     Approved         Amount           Date       Forgiven

The New England Affordable
Housing Management              501(c)(6)      3339878410       2nd          12/27/2020     2/4/2021         $31,000.00   10/25/2021     $31,219.97
Association Inc.

North of Boston Convention
                                501(c)(6)      8511777109       1st          12/27/2020     4/15/2020        $54,070.00    2/23/2021     $54,529.59
& Visitors Bureau Inc.

North of Boston Convention
                                501(c)(6)      9739328710       2nd          12/27/2020     4/9/2021         $51,620.00    10/6/2021     $51,870.93
& Visitors Bureau Inc.

The North Shore Chamber of
                                501(c)(6)      5431667107       1st          12/27/2020     4/13/2020        $81,250.00    5/13/2021     $82,098.61
Commerce Inc.

The North Shore Chamber of
                                501(c)(6)      6966438410       2nd          12/27/2020     2/11/2021        $67,000.00   10/20/2021     $67,463.42
Commerce Inc.

North Shore Skating Club Inc.   501(c)(7)      9663987204       1st            Never        4/28/2020        $10,825.87   11/19/2020     $10,885.41

North Shore Tennis & Squash
                                501(c)(7)      4450347400       1st          3/11/2021      5/9/2020         $12,615.00    3/18/2021     $12,723.63
Club Inc.

North Shore Tennis & Squash
                                501(c)(7)      9208768300       2nd          3/11/2021      1/30/2021        $12,615.00   12/23/2021     $12,728.53
Club Inc.

Oak Grove Cemetery
                                501(c)(13)     8719457204       1st          3/11/2021      4/28/2020         $5,209.00    1/29/2021      $5,246.33
Association of Falmouth Inc.

The Old Colony Yacht Club       501(c)(7)      8480977106       1st            Never        4/15/2020        $25,700.00    9/7/2021      $26,054.09

The Old Colony Yacht Club       501(c)(7)      4251608508       2nd            Never        2/25/2021        $25,700.00   11/15/2021     $25,882.76

Orleans Yacht Club Inc.         501(c)(7)      1668537201       1st            Never        4/15/2020        $36,997.00   12/22/2020     $37,237.48

Orleans Yacht Club Inc.         501(c)(7)      6205518307       2nd            Never        1/26/2021        $36,997.50    10/7/2021     $37,255.45




                                                                        10
                                Case 1:24-cv-11950-LTS         Document 24          Filed 08/20/26      Page 65 of 69

                                United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.
                                                              Defendants՚ PPP Loans

                                                                               Date          Date            Loan         Forgiveness   Amount
           Name                   Type         Loan No.        Draw           Eligible     Approved         Amount           Date       Forgiven

Outdoor Amusement Business
                                501(c)(6)      6201077705       1st          12/27/2020     5/1/2020         $61,013.00    3/24/2021     $61,557.94
Association Inc.

Outdoor Amusement Business
                                501(c)(6)      8580698403       2nd          12/27/2020     2/13/2021        $61,012.00    8/18/2021     $61,319.57
Association Inc.

Palmer’s Cove Yacht Club
                                501(c)(7)      1541987210       1st            Never        4/15/2020        $20,337.50    4/6/2021      $20,534.10
Inc.

Pine Grove Cemetery
                                501(c)(13)     7732157001       1st          3/11/2021      4/8/2020          $2,500.00    6/4/2021       $2,528.12
Corporation

Pleasant Park Yacht Club Inc.   501(c)(7)      8954887705       1st            Never        5/1/2020         $13,871.00    3/11/2021     $13,985.77

The Plymouth Area Chamber
                                501(c)(6)      4087557104       1st          12/27/2020     4/12/2020        $58,062.50   12/16/2020     $58,446.36
of Commerce Inc.

The Plymouth Area Chamber
                                501(c)(6)      4945728405       2nd          12/27/2020     2/7/2021         $56,675.00   11/15/2021     $57,109.51
of Commerce Inc.

Plymouth Country Club Inc.      501(c)(7)      8546087103       1st            Never        4/15/2020       $329,595.00    8/2/2021     $333,839.10

Plymouth Country Club Inc.      501(c)(7)      9216188510       2nd            Never        3/12/2021       $329,595.00   11/26/2021    $331,888.62

Point Independence Yacht
                                501(c)(7)      9529387004       1st            Never        4/9/2020         $19,382.00    4/8/2021      $19,569.98
Club Inc.

Polish American Veterans of
                                501(c)(7)      6291328500       1st            Never        3/3/2021         $13,811.48    9/8/2021      $13,881.69
Webster Inc.

The Polish Club Lodge 2058
                                501(c)(8)      5270307407       1st            Never        5/12/2020        $10,000.00    2/17/2021     $10,071.67
Inc.

The Polish Club Lodge 2058
                                501(c)(8)      1945808510       2nd            Never        2/19/2021        $13,762.00    1/26/2022     $13,890.83
Inc.




                                                                        11
                                  Case 1:24-cv-11950-LTS         Document 24          Filed 08/20/26      Page 66 of 69

                                  United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.
                                                                Defendants՚ PPP Loans

                                                                                 Date          Date            Loan         Forgiveness   Amount
            Name                    Type         Loan No.        Draw           Eligible     Approved         Amount           Date       Forgiven

Portuguese National Club          501(c)(7)      8053438404       1st            Never        2/12/2021         $5,629.70    9/15/2021      $5,662.07

Prince Hall Masonic Grand
                                  501(c)(8)      5101678201       1st            Never        8/7/2020          $4,865.00   10/12/2021      $4,921.11
Lodge

The Proprietors of Forest Hills
                                  501(c)(13)     4199537201       1st          3/11/2021      4/27/2020       $385,180.00    Unknown        Unknown
Cemetery

Realtor Association of Central
                                  501(c)(6)      6237267106       1st          12/27/2020     4/14/2020        $60,200.00   10/13/2020     $60,480.93
Massachusetts

Rowley Veterans’ Association
                                  501(c)(7)      1657787200       1st            Never        4/15/2020        $26,006.00    9/24/2021      $2,102.60
Inc.

Salem Chamber of Commerce
                                  501(c)(6)      8915957002       1st          12/27/2020     4/9/2020         $49,000.00    2/11/2021     $49,408.33
& Civics

Salem Chamber of Commerce
                                  501(c)(6)      3052288304       2nd          12/27/2020     1/21/2021        $49,000.00    9/7/2021      $49,299.44
& Civics

Salem Office of Tourism &
Cultural Affairs Inc. dba         501(c)(6)      5401847308       1st          12/27/2020     4/30/2020        $38,228.00    2/25/2021     $38,536.97
Destination Salem

Salem Office of Tourism &
Cultural Affairs Inc. dba         501(c)(6)      9560608504       2nd          12/27/2020     3/12/2021        $36,551.00    9/22/2021     $36,737.26
Destination Salem

Sandy Bay Yacht Club Inc.         501(c)(7)      1883257105       1st            Never        4/10/2020        $24,400.00   12/23/2020     $24,567.12

Singletary Rod & Gun Club
                                  501(c)(7)      6146637409       1st            Never        5/14/2020        $15,212.00    2/12/2021     $15,325.78
Inc.

Singletary Rod & Gun Club
                                  501(c)(7)      1541498800       2nd            Never        4/10/2021        $15,212.52    8/20/2021     $15,266.61
Inc.




                                                                          12
                               Case 1:24-cv-11950-LTS         Document 24          Filed 08/20/26      Page 67 of 69

                               United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.
                                                             Defendants՚ PPP Loans

                                                                              Date          Date            Loan         Forgiveness   Amount
           Name                  Type         Loan No.        Draw           Eligible     Approved         Amount           Date       Forgiven

Sons of Italy in America—
Grand Lodge of                 501(c)(8)      9439897708       1st            Never        5/1/2020         $17,600.00    5/17/2021     $17,780.34
Massachusetts

Sons of Italy in America—
                               501(c)(8)      7790557208       1st            Never        4/28/2020        $13,800.00    Unknown        Unknown
Methuen Lodge No. 902

Sons of Italy in America—
                               501(c)(8)      9753217102       1st            Never        4/15/2020        $27,000.00    1/13/2021     $27,358.93
Quincy Lodge No. 1295

Sons of Italy in America—
                               501(c)(8)      8740638407       2nd            Never        2/13/2021        $27,165.00    8/10/2021     $27,291.77
Quincy Lodge No. 1295

Stockbridge Golf Club          501(c)(7)      7454647005       1st            Never        4/7/2020        $162,720.00    Unknown        Unknown

Stoneham Chamber of
                               501(c)(6)      9731177407       1st          12/27/2020     5/20/2020        $12,709.48    5/5/2021      $12,831.00
Commerce Inc.

Stoneham Chamber of
                               501(c)(6)      1349128500       2nd          12/27/2020     2/18/2021        $12,709.48    5/5/2022      $12,862.34
Commerce Inc.

Supreme Council of the Royal
                               501(c)(8)      1305588104       1st            Never        7/9/2020        $300,000.00    1/8/2021     $301,425.00
Arcanum

Swampscott Yacht Club          501(c)(7)      4606967210       1st            Never        4/27/2020         $6,890.00    5/13/2021      $6,962.34

Swampscott Yacht Club          501(c)(7)      4460018504       2nd            Never        2/25/2021         $6,897.00   11/10/2021      $6,941.26

Tennis and Racquet Club        501(c)(7)      7271127304       1st            Never        4/30/2020       $132,525.00    4/29/2021    $133,821.20

Tennis and Racquet Club        501(c)(7)      6528838303       2nd            Never        1/27/2021       $109,105.00    8/11/2021    $109,672.94

Town River Yacht Club          501(c)(7)      4476837305       1st            Never        4/29/2020        $29,822.00    11/5/2020     $29,977.74

Town River Yacht Club          501(c)(7)      1687478307       2nd            Never        1/19/2021        $22,100.00    6/15/2021     $22,189.01




                                                                       13
                               Case 1:24-cv-11950-LTS         Document 24          Filed 08/20/26      Page 68 of 69

                               United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.
                                                             Defendants՚ PPP Loans

                                                                              Date          Date            Loan         Forgiveness   Amount
           Name                  Type         Loan No.        Draw           Eligible     Approved         Amount           Date       Forgiven

Volunteer Yacht Club           501(c)(7)      5889208510       1st            Never        3/2/2021          $7,005.00   11/19/2021      $7,054.62

Wampatuck Country Club of
                               501(c)(7)      6477477305       1st            Never        4/30/2020        $79,300.00    2/11/2021     $79,918.98
Canton Inc.

Wayland Swimming and
                               501(c)(7)      5801547300       1st          3/11/2021      4/30/2020        $29,685.00   11/27/2020     $29,846.03
Tennis Club Inc.

Wequaquet Lake Yacht Club      501(c)(7)      8315677803       1st            Never        6/5/2020          $8,660.00    1/7/2021       $8,708.59

Wequaquet Lake Yacht Club      501(c)(7)      6533428303       2nd            Never        1/27/2021        $12,124.00   11/15/2021     $12,216.61

West Dennis Yacht Club Inc.    501(c)(7)      8141687304       1st            Never        5/1/2020         $41,272.00    3/10/2021     $41,612.35

West Dennis Yacht Club Inc.    501(c)(7)      9785768409       2nd            Never        2/17/2021        $41,272.00   11/10/2021     $41,570.52

West End Beagle Club Inc. of
                               501(c)(7)      8457908508       1st            Never        3/9/2021         $10,860.00    12/8/2021     $10,939.44
Gardner

Whitinsville Golf Club         501(c)(7)      5948197002       1st            Never        4/6/2020        $101,800.00    3/25/2021    $102,769.93

Winthrop Golf Club             501(c)(7)      7970937800       1st          3/11/2021      6/4/2020         $45,401.00   11/17/2021     $46,060.25

Winthrop Yacht Club Inc.       501(c)(7)      2707777201       1st            Never        4/16/2020        $90,400.00    6/14/2021     $91,415.45

Wood Products Manufacturers
                               501(c)(6)      6322577709       1st          12/27/2020     5/1/2020         $57,091.00    1/14/2021     $57,488.29
Association

Wood Products Manufacturers
                               501(c)(6)      5392498510       2nd          12/27/2020     2/27/2021        $57,090.00    9/22/2021     $57,404.39
Association

Worcester County Memorial
                               501(c)(13)     8270767006       1st          3/11/2021      4/8/2020        $210,982.50    2/16/2021    $212,205.29
Park Inc.




                                                                       14
                             Case 1:24-cv-11950-LTS         Document 24         Filed 08/20/26      Page 69 of 69

                             United States of America ex rel. The Tarbell Group, LLC v. Acoaxet Club Inc., et al.
                                                           Defendants՚ PPP Loans

                                                                           Date          Date            Loan         Forgiveness   Amount
          Name                 Type         Loan No.        Draw          Eligible     Approved         Amount           Date       Forgiven

Young Men’s Club of Hadley
                             501(c)(7)      9798257107       1st          3/11/2021     4/15/2020        $25,800.00    8/24/2021     $26,144.94
Inc.

Young Men’s Club of Hadley
                             501(c)(7)      6134308305       2nd          3/11/2021     1/26/2021        $25,800.00    3/28/2022     $26,094.05
Inc.




                                                                     15


File and source

File
24-first-amended-complaint.pdf
Size
492,666 bytes
SHA-256
401ce226cdbba06e2a32e9ee9b3a6bb80410ad96a7b980c9f0302b7f0a664396
Our copy
24-first-amended-complaint.pdf
Original
storage.courtlistener.com
Back to top