Settlement Agreement among the United States of America and West Coast Dental Administrative Services, LLC

Summary

A False Claims Act settlement, dated 7/30/24 for the United States, among the United States on behalf of the Small Business Administration, West Coast Dental Administrative Services, LLC and affiliates, three owners, City Real Estate Holdings, LLC and Relator LLC. West Coast Dental Services, Inc. received a first draw PPP loan of $7,343,627.50 in April 2020, and the dental companies and City Real Estate then received eight more PPP loans in 2021, all forgiven. The United States contends the dental companies were ineligible for second draw loans because they collectively employed more than 300 employees, and that City Real Estate was a passive business. The defendants agree to pay $6,335,149.82, of which $4,212,282.60 is restitution, and Relator LLC, which filed the qui tam case CV 22-3812-MCS (MARx), receives eight percent. The agreement is not an admission of liability.

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

Captured: 2026-09-25
Source site: www.justice.gov

Archived web capture. Preserved source — captured from www.justice.gov; archived 2026-09-25.

Full text

SETTLEMENT AGREEMENT

This Settlement Agreement (“Agreement”) is entered into among the United

States of America, acting through the United States Department of Justice and on behalf

of the Small Business Administration (collectively the “United States”); West Coast

Dental Administrative Services, LLC (as successor in interest to West Coast Dental

Services, Inc.), Cohen Sedgh Manavi & Pakravan Dental Corporation, Sol Cohen Sedgh

DDS, Inc., Soleyman Cohen Sedgh, DDS Inc., Sol Cohen Sedgh Dental Corporation,

Pakravan Dental Corporation, and Farid Pakravan Professional Dental Corporation

(collectively, the “Dental Company Defendants”); Soleyman Cohen-Sedgh, Farid

Pakravan, and Farhad Manavi, (collectively, the “Individual Defendants”) and City Real

Estate Holdings, LLC (“City Real Estate”); and Relator LLC (the “Relator”) (hereafter

collectively referred to as “the Parties”), through their authorized representatives. The

Dental Company Defendants, the Individual Defendants and City Real Estate are

hereafter collectively referred to as the “Defendants,”; and the United States, the

Defendants and the Relator are hereafter collectively referred to as the “Parties.”

RECITALS

A. In 2020 and 2021, the Individual Defendants owned and operated West

Coast Dental Services, Inc., located at 12121 Wilshire Blvd., Suite 1111, Los Angeles,

CA 90025, and other affiliated dental offices located throughout Southern California,

including: Cohen Sedgh Manavi & Pakravan Dental Corporation, Sol Cohen Sedgh DDS,

Inc., Soleyman Cohen Sedgh, DDS Inc., Sol Cohen Sedgh Dental Corporation, Pakravan

Dental Corporation, and Farid Pakravan Professional Dental Corporation. Farhad

7/15/2024
Manavi also owned City Real Estate Holdings, LLC, which has a mailing address at 9903

Santa Monica Blvd, #921, Beverly Hills, CA 90212.

B. Pursuant to the Paycheck Protection Program (“PPP”), a program

established in March 2020 under the Coronavirus Aid, Relief, and Economic Security Act

(“CARES Act”), Pub. L. No. 116-136 (March 27, 2020), West Coast Dental Services,

Inc., applied for and received Loan No. 3882547204 in the amount of $7,343,627.50, as a

first draw PPP loan in April 2020 (the “2020 PPP Loan”).

C. In February and March 2021, the Dental Company Defendants applied for

and received the following additional PPP loans:

Cohen Sedgh Manavi & Pakravan Dental Loan No. 3466528509 $1,995,000
Corp.
Farid Pakravan Professional Dental Corp. Loan No. 6899168607 $182,167
Pakravan Dental Corp. Loan No. 2611058700 $199,616
Sol Cohen Sedgh DDS, Inc. Loan No. 1440288710 $267,612
Sol Cohen Sedgh Dental Corp. Loan No. 2609628706 $173,235
Soleyman Cohen Sedgh DDS, Inc. Loan No. 9171388604 $148,481
West Coast Dental Services, Inc. Loan No. 8865508407 $1,043,518

In addition, City Real Estate applied for and received $20,833.32 for Loan No.

9229648701 in April 2021. The Small Business Administration paid a total of

$181,820.28 in processing fees and interest to the PPP lenders in connection with the

2021 loans. These eight loans are referred to collectively as the “2021 PPP Loans.” The

Small Business Administration subsequently forgave the full amount of each of the 2021

PPP Loans, including principal and accrued interest.

D. On or about June 3, 2022, Relator LLC filed a qui tam action in the United

States District Court for the Central District of California captioned United States ex rel.

Relator LLC v. West Coast Dental Svcs, Inc., et al., CV 22-3812-MCS (MARx), pursuant

to the qui tam provisions of the False Claims Act, 31 U.S.C. § 3730(b) (the “Civil

2
Action”). The Relator purported to state claims concerning the 2020 PPP Loan and the

2021 PPP Loans against the Defendants.

E. The United States contends that it has certain civil claims against

Defendants arising from their submission of false loan and forgiveness applications for

the 2021 PPP Loans. Specifically, the United States contends that the Dental Company

Defendants were ineligible for second draw PPP loans because they collectively

employed more than 300 employees. After West Coast Dental Services, Inc. received a

first draw loan in April 2020, the United States contends that the Dental Company

Defendants made false statements and representations in connection with Loan Nos.

3466528509, 6899168607, 2611058700, 1440288710, 2609628706, 9171388604, and

8865508407 to receive additional PPP loans for which the Dental Company Defendants

were ineligible. The United States further contends that City Real Estate was a passive

business operated for investment purposes by Farhad Manavi, and therefore ineligible for

the PPP loan it received (Loan No. 9229648701). This conduct is referred to below as

the “Covered Conduct.”

F. Relator claims entitlement under 31 U.S.C. § 3730(d) to a share of the

proceeds of this Settlement Agreement and to Relator’s reasonable expenses, attorneys’

fees and costs.

G. This Agreement is neither an admission of liability by Defendants nor a

concession by the United States and the Relator that their claims are not well founded.

To avoid the delay, uncertainty, inconvenience, and expense of protracted

litigation of the above claims, and in consideration of the mutual promises and

obligations of this Settlement Agreement, the Parties agree and covenant as follows:

3
TERMS AND CONDITIONS

1. Defendants shall pay to the United States $6,335,149.82 (“Settlement

Amount”) of which $4,212,282.60 is restitution, and interest on the

Settlement Amount as follows:

a. The Individual Defendants, on behalf of the Dental Company

Defendants and Individual Defendants, shall pay the United States

$6,300,000 (“Dental Company Settlement Amount”), of which

$4,188,849.39 is restitution, and interest on the Dental Company

Settlement Amount at a rate of 4.750% per annum from July 17, 2024,

by electronic funds transfer, pursuant to written instructions to be

provided by the Civil Division of the United States Department of

Justice, no later than two business days after the Effective Date of this

Agreement.

b. City Real Estate Holdings shall pay the United States $35,149.82

(“City Real Estate Settlement Amount”), of which $23,433.21 is

restitution, and interest on the City Real Estate Settlement Amount at a

rate of 4.750% per annum from July 17, 2024, by electronic funds

transfer, pursuant to written instructions to be provided by the Civil

Division of the United States Department of Justice, no later than two

business days after the Effective Date of this Agreement.

2. Conditioned upon the United States receiving the Settlement Amount and

accrued interest, and as soon as feasible after receipt, the United States shall pay to

4
Relator by electronic funds transfer eight percent of the Settlement Amount and accrued

interest (“Relator’s Share”).

3. Defendants agree to pay a total of $10,000 to Relator pursuant to 31

U.S.C. §3730(d) in satisfaction of attorneys’ fees, expenses, and costs incurred by the

Relator in connection with the Civil Action, no later than thirty (30) days after the

Effective Date. Payment under this Paragraph shall be made by electronic funds transfer

pursuant to written instructions provided by Relator’s counsel.

4. Subject to the exceptions in Paragraph 6 (concerning reserved claims)

below, and upon the United States’ receipt of the Settlement Amount, plus interest due

under Paragraph 1, the United States releases Defendants from any civil or administrative

monetary claim the United States has for the Covered Conduct under the False Claims

Act, 31 U.S.C. §§ 3729-3733; the Program Fraud Civil Remedies Act, 31 U.S.C. §§3801-

3812; or the common law theories of breach of contract, payment by mistake, unjust

enrichment, and fraud.

5. Subject to the exceptions in Paragraph 6 below, and upon the United

States’ receipt of the Settlement Amount, plus interest due under Paragraph 1, Relator,

for itself and for its heirs, successors, attorneys, agents, and assigns, releases Defendants

together with the Dental Company Defendants’ current and former parent corporations;

direct and indirect subsidiaries; brother or sister corporations; divisions; current or former

owners; and the successors and assigns of any of them; and all of their current and former

shareholders, members, directors, officers, employees and other agents, and the

predecessors, successors and assigns of each of them, from any civil monetary claim the

5
Relator has on behalf of the United States for the Covered Conduct under the False

Claims Act, 31 U.S.C. §§ 3729-3733.

6. Notwithstanding the releases given in Paragraph 4 of this Agreement, or

any other term of this Agreement, the following claims and rights of the United States are

specifically reserved and are not released:

a. Any liability arising under Title 26, U.S. Code (Internal Revenue

Code);

b. Any criminal liability;

c. Except as explicitly stated in the Agreement, any administrative

liability or enforcement right, or any administrative remedy,

including the suspension and debarment rights of any federal

agency;

d. Any liability to the United States (or its agencies) for any conduct

other than the Covered Conduct;

e. Any liability based upon obligations created by this Agreement;

and

f. Any liability of individuals other than Soleyman Cohen-Sedgh,

Farid Pakravan, and Farhad Manavi.

7. Relator and its heirs, successors, attorneys, agents, and assigns shall not

object to this Agreement but agree and confirm that this Agreement is fair, adequate, and

reasonable under all the circumstances, pursuant to 31 U.S.C. § 3730(c)(2)(B).

Conditioned upon Relator’s receipt of the Relator’s Share, Relator and its heirs,

successors, attorneys, agents, and assigns fully and finally release, waive, and forever

6
discharge the United States, its agencies, officers, agents, employees, and servants, from

any claims arising from the filing of the Civil Action or under 31 U.S.C. § 3730, and

from any claims to a share of the proceeds of this Agreement and/or the Civil Action.

8. Relator, for itself, and for its heirs, successors, attorneys, agents, and

assigns, releases Defendants, and all of their current and former shareholders, members,

directors, officers, employees and other agents, and the predecessors, successors and

assigns of each of them, from any liability to Relator arising from the filing of or the

conduct alleged in the Civil Action, or under 31 U.S.C. § 3730(d) for expenses or

attorneys’ fees and costs, and from any other conduct on or before the Effective Date of

this Agreement, including any and all causes of action, in law or in equity, suits, debts,

liens, liabilities, obligations, claims, demands, qui tam relator shares, rights of

subrogation, contribution and indemnity, damages, losses, costs or expenses, direct or

indirect, of any kind or nature whatsoever, whether known prior to or after the Effective

Date of this Agreement, fixed or contingent, based on state, or federal, common law,

statute or regulation, liquidated or unliquidated, claimed or concealed, including but not

limited to claims under the False Claims Act, 31 U.S.C. §§ 3729-3733.

9. Defendants waive and shall not assert any defenses Defendants may have

to any criminal prosecution or administrative action relating to the Covered Conduct that

may be based in whole or in part on a contention that, under the Double Jeopardy Clause

in the Fifth Amendment of the Constitution, or under the Excessive Fines Clause in the

Eighth Amendment of the Constitution, this Agreement bars a remedy sought in such

criminal prosecution or administrative action.

7
10. Defendants fully and finally release the United States, its agencies,

officers, agents, employees, and servants, from any claims (including attorneys’ fees,

costs, and expenses of every kind and however denominated) that Defendants have

asserted, could have asserted, or may assert in the future against the United States, its

agencies, officers, agents, employees, and servants, related to the Covered Conduct or the

United States’ investigation or prosecution thereof.

11. a. Unallowable Costs Defined: All costs (as defined in the Federal

Acquisition Regulation, 48 C.F.R. § 31.205-47) incurred by or on behalf of Defendants,

and their present or former officers, directors, employees, shareholders, and agents in

connection with:

(1) the matters covered by this Agreement;

(2) the United States’ audit(s) and civil investigation(s) of the

matters covered by this Agreement;

(3) Defendants’ investigation, defense, and corrective actions

undertaken in response to the United States’ audit(s) and

civil investigation(s) in connection with the matters

covered by this Agreement (including attorneys’ fees);

(4) the negotiation and performance of this Agreement;

(5) the payment Defendants make to the United States pursuant

to this Agreement and any payments that Defendants may

make to Relator, including costs and attorneys fees,

are unallowable costs for government contracting purposes (hereinafter referred to as

Unallowable Costs).

8
b. Future Treatment of Unallowable Costs: Unallowable Costs will

be separately determined and accounted for by Defendants, and Defendants shall not

charge such Unallowable Costs directly or indirectly to any contract with the United

States.

c. Treatment of Unallowable Costs Previously Submitted for

Payment: Within 90 days of the Effective Date of this Agreement, Defendants shall

identify and repay by adjustment to future claims for payment or otherwise any

Unallowable Costs included in payments previously sought by Defendants or any of their

subsidiaries or affiliates from the United States. Defendants agree that the United States,

at a minimum, shall be entitled to recoup from Defendants any overpayment plus

applicable interest and penalties as a result of the inclusion of such Unallowable Costs on

previously-submitted requests for payment. The United States, including the

Department of Justice and/or the affected agencies, reserves its rights to audit, examine,

or re-examine Defendants’ books and records and to disagree with any calculations

submitted by Defendants or any of its subsidiaries or affiliates regarding any Unallowable

Costs included in payments previously sought by Defendants, or the effect of any such

Unallowable Costs on the amount of such payments.

12. This Agreement is intended to be for the benefit of the Parties only.

13. Upon receipt of the payment described in Paragraph 1, above, the United

States and Relator shall promptly sign and file in the Civil Action a Joint Stipulation of

Dismissal of the Civil Action pursuant to Rule 41(a)(1). The dismissal shall be (a) with

prejudice to Relator as to all claims against the Defendants in the Civil Action, (b) with

9
prejudice to the United States only as to the Covered Conduct, and (c) without prejudice

to the United States as to all other claims or allegations in the Civil Action.

14. Subject to Paragraph 3, each Party shall bear its own legal and other costs

incurred in connection with this matter, including the preparation and performance of this

Agreement.

15. Each Party and signatory to this Agreement represents that it freely and

voluntarily enters into this Agreement without any degree of duress or compulsion.

16. This Agreement is governed by the laws of the United States. The

exclusive jurisdiction and venue for any dispute relating to this Agreement is the United

States District Court for the Central District of California. For purposes of construing

this Agreement, this Agreement shall be deemed to have been drafted by all Parties to

this Agreement and shall not, therefore, be construed against any Party for that reason in

any subsequent dispute.

17. This Agreement constitutes the complete agreement between the Parties.

This Agreement may not be amended except by written consent of the Parties.

18. The undersigned counsel represent and warrant that they are fully

authorized to execute this Agreement on behalf of the persons and entities indicated

below.

19. This Agreement may be executed in counterparts, each of which

constitutes an original and all of which constitute one and the same Agreement.

20. This Agreement is binding on Defendants’ successors, transferees, heirs,

and assigns.

10
21. This Agreement is binding on Relator’s successors, transferees, heirs, and

assigns.

22. All parties consent to the United States’ disclosure of this Agreement, and

information about this Agreement, to the public.

23. This Agreement is effective on the date of signature of the last signatory to

the Agreement (Effective Date of this Agreement). Facsimiles of signatures shall

constitute acceptable, binding signatures for purposes of this Agreement.

THE UNITED STATES OF AMERICA

DATED: 7/30/24 BY: ______________________________
Allie Pang
Trial Attorney
Commercial Litigation Branch
Civil Division
United States Department of Justice

DATED: 7/30/24 BY: Jack Ross/ap
______________________________
Jack Ross
Assistant United States Attorney
Deputy Chief, Civil Fraud Section
Central District of California

11
7/15/2024
7/18/2024

7/18/2024
7/18/2024

7/18/24

File and source

File: dl_c3ff59ac449b7fc9.pdf
Size: 689,184 bytes
SHA-256: 170eee8e95f69ae30c7cffa4b3fc910599de41cdddac1f7a60a7d42c67daf5da
Our copy: dl_c3ff59ac449b7fc9.pdf
Original: No public link identified.