Joint Stipulation of Dismissal — No. 5:22-CV-659 (Dkt. 22, W.D. Tex.)

Summary

A Joint Stipulation of Dismissal dated December 20, 2024 in United States of America ex rel. Jesus Nunez-Unda v. Lafayette RE Management LLC, Brandywine Homes USA LLC, and Thibault Adrien, No. 5:22-CV-659-FB, in the U.S. District Court for the Western District of Texas, San Antonio Division. Under Fed. R. Civ. P. 41(a)(1)(A)(i) and 31 U.S.C. § 3730(b)(1), and subject to a Settlement Agreement attached as Exhibit A, the United States and the relator stipulate to dismissal of all claims against the three defendants. The dismissal is with prejudice to the United States as to the claims against Lafayette RE Management LLC and Thibault Adrien set forth in Paragraph 3 of the Settlement Agreement, without prejudice as to all other claims, and with prejudice to the relator. An unsigned [Proposed] Order for Judge Fred Biery would dismiss all claims and retain jurisdiction.

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

Full text

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION

UNITED STATES OF AMERICA ex rel. §
JESUS NUNEZ-UNDA, §
§
Plaintiff, §
§ 5:22-CV-659-FB
v. §
§
LAFAYETTE RE MANAGEMENT LLC, §
BRANDYWINE HOMES USA LLC, and §
THIBAULT ADRIEN, §
§
Defendants. §

JOINT STIPULATION OF DISMISSAL

Pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) and 31 U.S.C. § 3730(b)(1), and subject to the

terms and conditions of the Settlement Agreement attached hereto as Exhibit A, the United States

and relator Jesus Nunez-Unda (“Relator”) hereby stipulate to the dismissal of all claims in this

action against defendants Lafayette RE Management LLC, Brandywine Homes USA LLC, and

Thibault Adrien.

The United States and Relator further stipulate that such dismissal shall be (1) with

prejudice to the United States as to the claims against defendants Lafayette RE Management LLC

and Thibault Adrien set forth in Paragraph 3 of the Settlement Agreement; (2) without prejudice

to the United States as to all other claims asserted in this action; and (3) with prejudice to Relator

as to all claims asserted against all defendants.

The parties respectfully request that the Court retain jurisdiction to enforce the terms of the

Settlement Agreement.
Dated: December 20, 2024 Respectfully submitted,

JAIME ESPARZA
United States Attorney

/s/ Samuel M. Shapiro /s/ Max E. Rodriguez
SAMUEL M. SHAPIRO Max E. Rodriguez
Assistant United States Attorney New York Bar No. 5422811
Georgia Bar No. 717286 LAW OFFICE OF MAX RODRIGUEZ PLLC
601 N.W. Loop 410, Suite 600 575 5th Avenue, 14th Floor
San Antonio, Texas 78216 New York, New York 10017
Tel: (210) 384-7392 (646) 741-5167
Fax: (210) 384-7322 max@maxrodriguez.law
samuel.shapiro@usdoj.gov
Adam Pollock
Attorneys for the United States of America New York Bar No. 4518833
POLLOCK COHEN LLP
111 Broadway, Suite 1804
New York, NY 10006
(212) 337-5361
Email: adam@pollockcohen.com

Attorneys for Relator Jesus Nunez-Unda

2
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION

[PROPOSED] ORDER

This matter came before the Court on the United States’ and relator Jesus Nunez-Unda’s

Joint Stipulation of Dismissal of all claims against defendants Lafayette RE Management LLC,

Brandywine Homes USA LLC, and Thibault Adrien. It is hereby ORDERED that all claims

asserted in this action are dismissed as to all defendants. Such dismissal shall be (1) with prejudice

to the United States as to the claims against defendants Lafayette RE Management LLC and

Thibault Adrien set forth in Paragraph 3 of the Settlement Agreement; (2) without prejudice to the

United States as to all other claims asserted in this action; and (3) with prejudice to Relator as to

all claims asserted against all defendants.

The Court shall retain jurisdiction over the parties to enforce the terms of the Settlement

Agreement among them.

SO ORDERED this __________ day of __________________, 202__.

___________________________________
THE HONORABLE FRED BIERY
UNITED STATES DISTRICT JUDGE

File and source

File: 22.pdf
Size: 105,969 bytes
SHA-256: ec7a2d2c1886492decdb93bebf7c5ed0fd20a4147934f0c4aa533938b34d4524
Our copy: 22.pdf
Original: storage.courtlistener.com