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.
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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,
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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
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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
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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.
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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.
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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.
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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.
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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)
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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.
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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
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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
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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.
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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
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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.
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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.
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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
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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
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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
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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
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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
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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.
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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
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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
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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
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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.
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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.
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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
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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.
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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.
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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.
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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,
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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
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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.
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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.
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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.
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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
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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.
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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.
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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
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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
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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
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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
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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.
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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.
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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
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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.”
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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
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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)
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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)
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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)
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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
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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.
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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
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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
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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
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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
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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
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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
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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
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