Reply to Response — United States ex rel. James R. Berkley v. Ocean State, LLC (Dkt. 95, D.R.I.)

Summary

The defendants' reply in support of their motion for summary judgment, filed March 12, 2025 as Document 95 in C.A. No. 1:20-cv-00538-JJM-PAS in the U.S. District Court for the District of Rhode Island. The defendants argue that the relator's claims are barred by the public disclosure bar, 31 U.S.C. § 3730(e)(4)(A), and ask the Court to decline what the relator calls the mosaic theory. They argue that Ocean State and Fyzical qualified for an affiliation waiver under 15 U.S.C. § 636(a)(36)(D)(iv)(II) and that the relator has produced no evidence that Ocean State and Fyzical falsely certified their loans were necessary. They also argue that the government's actual knowledge defeats materiality, that the New Harbor Defendants are separate corporate entities, and that the reverse false claims are redundant. It is signed /s/ by Patricia K. Rocha.

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