Settlement Agreement (PPP): United States, Seth A. Bernstein and Victoria Hablitzel, Relator
Summary
Settlement Agreement among the United States (acting through the Department of Justice on behalf of the Small Business Administration), Seth A. Bernstein and Relator Victoria Hablitzel, concerning qui tam action No. 20-cv-61420 filed July 13, 2020, in the Southern District of Florida. The United States contends that Bernstein submitted a PPP loan application for JetReady seeking $1,173,382 and on April 28, 2020 diverted $98,929 of the proceeds to personal, non-company related expenses. Bernstein agrees to pay $287,055, of which $98,929 is restitution, plus interest at 3 percent per annum from August 13, 2021. The United States will pay Relator $57,411; Bernstein pays McCabe Rabin, P.A. $66,720.75 and Nizel Law, P.A. $12,665.00 for attorney's fees and costs. On an uncured default, a consent judgment of $458,223 may be filed.
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“Settlement Agreement (PPP): United States, Seth A. Bernstein and Victoria Hablitzel, Relator.”
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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”), Seth A. Bernstein, and
Victoria Hablitzel (Relator) (hereafter collectively referred to as “the Parties”), through
their authorized representatives.
RECITALS
A. Seth A. Bernstein is the owner of All in Jets, LLC d/b/a JetReady.
JetReady is a jet charter operator with its principal place of business in Fort Lauderdale,
Florida. On August 9, 2020, JetReady filed a voluntary petition for bankruptcy relief
under Chapter 11 of the Bankruptcy Code in the United States Bankruptcy Court for the
Southern District of New York. In re: All in Jets, LLC, 20-bk-11831 (Bankr. EDNY).
B. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was
enacted on March 27, 2020, to provide emergency assistance to individuals, families, and
businesses affected by the coronavirus pandemic. Section 1102(a)(2) of the CARES Act
amended Section 7(a) of the Small Business Act, 15 U.S.C. §§ 631-657u, to establish the
Paycheck Protection Program (“PPP”). 15 U.S.C. § 636(a)(36). The Small Business
Administration administers the PPP to provide relief expeditiously to small businesses
experiencing economic hardship as a result of coronavirus measures. The Small Business
Administration guarantees the PPP loans, and eligible borrowers may qualify for
forgiveness of up to the full amount of the loan.
C. Under the requirements of the CARES Act, as modified by the Paycheck
Protection Program Flexibility Act of 2020, Pub. L. No. 116-142, 134 Stat. 641 (June 5,
2020), a company receiving a loan is required to use 60 percent of the loan proceeds on
payroll, and the remaining 40 percent on mortgage or rent payments, utilities, or other
obligations as specifically set forth in the Act.
D. On July 13, 2020, Victoria Hablitzel filed a qui tam action in the United
States District Court for the District of Southern District of Florida captioned United
States ex rel. Hablitzel v. All in Jets , LLC and Seth A. Bernstein, No. 20-cv-61420
(Under Seal) pursuant to the qui tam provisions of the False Claims Act, 31 U.S.C. §
3730(b) (the Civil Action). Relator alleges that that the defendants misappropriated PPP
loan funds.
E. The United States contends that it has certain civil claims against
Bernstein arising from his submitting, or causing the submission of, a false loan
application and misappropriation of PPP loan funds during the period of April 1, 2020,
through October 31, 2020. Specifically, the United States contends:
a. that Bernstein submitted, or caused the submission of, a PPP loan
application on behalf of JetReady in which JetReady sought a loan of $1,173,382. On the
loan application, JetReady stated the funds would be used for payroll.
b. JetReady’s PPP loan application was approved, and it received the funds
in its account on April 27, 2020.
c. On April 28, 2020, Bernstein diverted $98,929 of the loan proceeds to pay
for his personal, non-company related expenses.
That conduct is referred to below as the Covered Conduct.
F. This Settlement Agreement is neither an admission of liability by
Bernstein nor a concession by the United States that its claims are not well founded.
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G. 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.
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:
TERMS AND CONDITIONS
1. Bernstein shall pay to the United States ($287,055) (Settlement Amount),
of which $98,929, is restitution, plus interest on the Settlement Amount at a rate of 3
percent per annum from August 13, 2021, by electronic funds transfer pursuant to written
instructions to be provided by the Civil Division of the Department of Justice or the
United States Attorney’s Office for the Southern District of Florida no later than 3 days
after the Effective Date of this Agreement.
2. Conditioned upon the United States receiving the Settlement Amount,
Paragraph 17, and 91 days having elapsed since payment of the Settlement Amount, and
as soon as feasible thereafter, the United States shall pay $57,411 to Relator by electronic
funds transfer (Relator’s Share).
3. Bernstein shall pay to McCabe Rabin, P.A. $66,720.75 and to Nizel Law,
P.A. $12,665.00 in satisfaction of any claims Relator may have for attorney’s fees and
costs under 31 U.S.C. § 3730(d).
4. Subject to the exceptions in Paragraph 6 (concerning reserved claims) and
subject to Paragraph 15 (concerning default) and Paragraph 17 (concerning bankruptcy)
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below, and upon the United States’ receipt of the Settlement Amount, plus interest due
under Paragraph 1, the United States releases Bernstein 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 Paragraphs 6 and subject to Paragraphs 15 and
17 below, and upon the United States’ receipt of the Settlement Amount plus interest due
under Paragraph 1, Relator, for herself and for her heirs, successors, attorneys, agents,
and assigns, releases Bernstein and JetReady from any civil monetary claim the 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, 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;
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e. Any liability based upon obligations created by this Agreement;
f. Any liability of individuals, except Bernstein;
g. Any liability for express or implied warranty claims or other
claims for defective or deficient products or services, including
quality of goods and services;
h. Any liability for failure to deliver goods or services due;
i. Any liability for personal injury or property damage or for other
consequential damages arising from the Covered Conduct;
7. Relator and her 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 her heirs,
successors, attorneys, agents, and assigns fully and finally release, waive, and forever
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 herself, and for her heirs, successors, attorneys, agents, and
assigns, releases Bernstein, JetReady, and its officers, agents, and employees, from any
liability to Relator arising from the filing of the Civil Action, or under 31 U.S.C. §
3730(d) for expenses or attorneys’ fees and costs.
9. Bernstein waives and shall not assert any defenses Bernstein 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
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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.
10. Bernstein fully and finally releases 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 Bernstein has 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. Bernstein fully and finally releases the Relator from any claims (including
attorneys’ fees, costs, and expenses of every kind and however denominated) that
Bernstein has asserted, could have asserted, or may assert in the future against the
Relator, related to the Covered Conduct and the Relator’s investigation and prosecution
thereof.
12. 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 Bernstein and
his 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) Bernstein’s investigation, defense, and corrective actions
undertaken in response to the United States’ audit(s) and
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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 Bernstein makes to the United States pursuant
to this Agreement and any payments that Bernstein may
make to Relator, including costs and attorneys fees,
are unallowable costs for government contracting purposes (hereinafter referred to as
Unallowable Costs).
b. Future Treatment of Unallowable Costs: Unallowable Costs will
be separately determined and accounted for by Bernstein, and Bernstein 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, Bernstein shall
identify and repay by adjustment to future claims for payment or otherwise any
Unallowable Costs included in payments previously sought by Bernstein or any of its
subsidiaries or affiliates from the United States. Bernstein agrees that the United States,
at a minimum, shall be entitled to recoup from Bernstein 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 Bernstein’s books and records and to disagree with any calculations
submitted by Bernstein or any of its subsidiaries or affiliates regarding any Unallowable
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Costs included in payments previously sought by Bernstein, or the effect of any such
Unallowable Costs on the amount of such payments.
13. This Agreement is intended to be for the benefit of the Parties only.
JetReady is not a party to this Agreement, and no provisions in this Agreement may be
transferred to JetReady or any other person or entity. Nothing in this agreement affects
or limits any liability JetReady may have to the First Bank of the Lake.
14. Bernstein warrants that the payment he makes of the Settlement Amount
and interest set forth in Paragraph 1, and any payment to the Relator, are made from his
own personal assets and not from any assets in which JetReady owns or has any legal
claim of entitlement.
15. In the event that Bernstein fails to pay the Settlement Amount, plus
accrued interest, by the time set forth in Paragraph 1, Bernstein shall be in Default of this
Agreement. In the event of a Default, the United States will provide written notice of the
Default (“Notice of Default”) to Bernstein, and Bernstein shall have an opportunity to
cure the Default within seven (7) days from the date of receipt of the Notice of Default by
making the payment due under the payment schedule and paying any additional interest
accruing under the Settlement Agreement up to the date of payment. Notice of Payment
Default will be delivered to John Zach, Esq., Boies Schiller Flexner LLP, by email to
jzach@bsfllp.com, or to such other representative as Bernstein shall designate in advance
in writing. If Bernstein fails to cure the Default within seven (7) days of receiving the
Notice of Default and in the absence of an agreement with the United States to a modified
payment schedule (“Uncured Default”), the remaining unpaid balance of the Settlement
Amount shall become immediately due and payable, and interest on the remaining unpaid
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balance shall thereafter accrue at the rate of 12% per annum, compounded daily from the
date of Default, on the remaining unpaid total (principal and interest balance).
a. In the event of Uncured Default, Bernstein agrees that the United States, at
its sole discretion, may: (i) retain any payments previously made, rescind this Agreement
and pursue the Civil Action or bring any civil and/or administrative claim, action, or
proceeding against Bernstein for the claims that would otherwise be covered by the
releases provided in Paragraph 4 above with any recovery reduced by the amount of any
payments previously made by Bernstein to the United States under this Agreement; (ii)
take any action to enforce this Agreement in a new action or by reinstating the Civil
Action, including the filing of a consent judgment in the Civil Action or a separate action
in the amount of $458,223, in the form of Attachment A, which Bernstein shall sign
concurrently with this Agreement; (iii) offset the remaining unpaid balance from any
amounts due and owing to Bernstein and/or affiliated companies by any department,
agency, or agent of the United States at the time of Default or subsequently; and/or
(iv) exercise any other right granted by law, or under the terms of this Agreement, or
recognizable at common law or in equity. The United States shall be entitled to any other
rights granted by law or in equity by reason of Default, including referral of this matter
for private collection. In the event the United States pursues a collection action,
Bernstein agrees immediately to pay the United States the greater of (i) a ten-percent
(10%) surcharge of the amount collected, as allowed by 28 U.S.C. § 3011(a), or (ii) the
United States’ reasonable attorneys’ fees and expenses incurred in such an action. In the
event that the United States opts to rescind this Agreement pursuant to this paragraph,
Bernstein waives and agrees not to plead, argue, or otherwise raise any defenses of statute
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of limitations, laches, estoppel or similar theories, to any civil or administrative claims
that are (i) filed by the United States against Bernstein within 120 days of written
notification that this Agreement has been rescinded, and (ii) relate to the Covered
Conduct, except to the extent these defenses were available on July 13, 2020. Bernstein
agrees not to contest any offset, recoupment, and /or collection action undertaken by the
United States pursuant to this paragraph, either administratively or in any state or federal
court, except on the grounds of actual payment to the United States.
16. 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 subject to
the terms of the Settlement Agreement, and shall be: (1) with prejudice to the United
States and Relator for the Covered Conduct as to Bernstein; (2) with prejudice to the
Relator and without prejudice to the United States as to Bernstein for all conduct other
than the Covered Conduct; (3) with prejudice to the Relator and without prejudice to the
United States as to JetReady.
17. In exchange for valuable consideration provided in this Agreement,
Bernstein acknowledges the following:
a. Bernstein has reviewed his financial situation and warrants that he is
solvent within the meaning of 11 U.S.C. §§ 547(b)(3) and 548(a)(1)(B)(ii)(I) and shall
remain solvent following payment to the United States of the Settlement Amount.
b. In evaluating whether to execute this Agreement, the Parties intend that
the mutual promises, covenants, and obligations set forth herein constitute a
contemporaneous exchange for new value given to Bernstein, within the meaning of 11
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U.S.C. § 547(c)(1), and the Parties conclude that these mutual promises, covenants, and
obligations do, in fact, constitute such a contemporaneous exchange.
c. The mutual promises, covenants, and obligations set forth herein are
intended by the Parties to, and do in fact, constitute a reasonably equivalent exchange of
value.
d. The Parties do not intend to hinder, delay, or defraud any entity to which
Bernstein or JetReady was or became indebted to on or after the date of any transfer
contemplated in this Agreement, within the meaning of 11 U.S.C. § 548(a)(1).
e. If Bernstein’s obligations under this Agreement are avoided for any reason
(including but not limited to, through the exercise of a trustee’s avoidance powers under
the Bankruptcy Code) or if, before the Settlement Amount is paid in full plus 91 days,
Bernstein or a third party commences a case, proceeding, or other action under any law
relating to bankruptcy, insolvency, reorganization, or relief of debtors seeking any order
for relief of Bernstein’s debts, or to adjudicate Bernstein as bankrupt or insolvent; or
seeking appointment of a receiver, trustee, custodian, or other similar official for
Bernstein or for all or any substantial part of Bernstein’s assets; or to void this Agreement
or claw back the Settlement Amount payment in the action In re: All in Jets, LLC, 20-bk-
11831 (Bankr. EDNY):
(i) the United States may rescind the releases in this Agreement and bring
any civil and/or administrative claim, action, or proceeding against Bernstein for the
claims that would otherwise be covered by the releases provided in Paragraph 4 above;
(ii) the United States has an undisputed, noncontingent, and liquidated
allowed claim against Bernstein in the amount of $458,223, less any payments received
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pursuant to this agreement, provided, however, that such payments are not otherwise
avoided and recovered from the United States by Bernstein, a receiver, trustee,
custodian, or other similar official for Bernstein or JetReady; and
(iii) if any payments are avoided and recovered by Bernstein or JetReady,
a receiver, trustee, custodian, or similar official for Bernstein or JetReady, Relator shall,
within thirty days of written notice from the United States to the undersigned Relator’s
counsel, return any portions of such payments already paid by the United States to
Relator pursuant to Paragraph 2.
f. Bernstein agrees that any civil and/or administrative claim, action, or
proceeding brought by the United States under Paragraph 17.e is not subject to an
“automatic stay” pursuant to 11 U.S.C. § 362(a) because it would be an exercise of the
United States’ police and regulatory power. Bernstein shall not argue or otherwise
contend that the United States’ claim, action, or proceeding is subject to an automatic
stay and, to the extent necessary, consents to relief from the automatic stay for cause
under 11 U.S.C. § 362(d)(1). Bernstein waives and shall not plead, argue, or otherwise
raise any defenses under the theories of statute of limitations, laches, estoppel, or similar
theories, to any such civil or administrative claim, action, or proceeding brought by the
United States within 120 days of written notification to Bernstein that the releases have
been rescinded pursuant to this paragraph, except to the extent such defenses were
available on July 13, 2020.
18. Each Party shall bear its own legal and other costs incurred in connection
with this matter, including the preparation and performance of this Agreement.
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19. Each Party and signatory to this Agreement represents that it freely and
voluntarily enters in to this Agreement without any degree of duress or compulsion.
20. 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 Southern District of Florida. 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.
21. This Agreement constitutes the complete agreement between the Parties.
This Agreement may not be amended except by written consent of the Parties.
Forbearance by the United States from pursuing any remedy or relief available to it under
this Agreement shall not constitute a waiver of rights under this Agreement.
22. The undersigned counsel represent and warrant that they are fully
authorized to execute this Agreement on behalf of the persons and entities indicated
below.
23. This Agreement may be executed in counterparts, each of which
constitutes an original and all of which constitute one and the same Agreement.
24. This Agreement is binding on Bernstein’s successors, transferees, heirs,
and assigns.
25. This Agreement is binding on Relator’s successors, transferees, heirs, and
assigns.
26. All parties consent to the United States’ disclosure of this Agreement, and
information about this Agreement, to the public.
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27. This Agreement is effective on the date of signature of the last signatory to
the Agreement (Effective Date of this Agreement). PDFs and facsimiles of signatures
shall constitute acceptable, binding signatures for purposes of this Agreement.
THE UNITED STATES OF AMERICA
DATED: 8/25/2021 BY: ___ ___________________
Jonathan H. Gold
Trial Attorney
Commercial Litigation Branch
Civil Division
United States Department of Justice
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SETH A. BERNSTEIN – DEFENDANT
DATED: 08/24/2021 BY: _____________________________
Seth A. Bernstein
DATED: BY: _____________________________
John Zach
Boies Schiller Flexner LLP
Counsel for Seth A. Bernstein
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ATTACHMENT A
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 20-61410-CIV-ALTONAGA/Strauss
UNITED STATES, ex rel. )
VICTORIA HABLITZEL, )
)
Plaintiff, )
)
v. )
)
ALL IN JETS, LLC and )
SETH A. BERNSTEIN, )
)
Defendants. )
)
CONSENT JUDGMENT
Plaintiff, the United States of America (“Plaintiff” or the “United States”),
Relator Victoria Hablitzel (“Relator”) and Defendant Seth A. Bernstein (“Bernstein”),
(Plaintiff, Relator and Bernstein are collectively referred to as the “Parties”), through
their undersigned counsel, consent to the entry of this judgment based upon the
following uncontested allegations:
1. This Court has jurisdiction over this case under 28 U.S.C. § 1331 and
28 U.S.C. § 1345. Defendant Bernstein consents to the jurisdiction of the United States
District Court for the Southern District of Florida for the resolution of this dispute.
2. On the __ day of _______ 2021, Defendant entered into a Settlement
Agreement with the United States and Relator for the purpose of resolving certain
claims that were the subject of a qui tam complaint filed by Relator under the False
Claims Act, 31 U.S.C. §§ 3729, et seq. (the “Settlement Agreement”). A copy of the
Settlement Agreement was filed with the Parties’ Stipulation for Dismiss (D.E. _) and
is incorporated by reference in this Consent Judgment.
3. Under the terms of the Settlement Agreement, Defendant Seth A.
Bernstein agreed to pay to the United States the sum of $287,055.
4. Also under the terms of the Settlement Agreement, Bernstein agreed
that in the event that it defaulted and failed to pay the Settlement Amount, then within
five calendar days of his failure to cure the default pursuant to the cure provisions of
the Settlement Agreement, $458,223, plus interest of 12% beginning on the date the
judgment is entered and until paid, shall become due and payable by Bernstein.
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5. Under the terms of the Settlement Agreement, Bernstein additionally
agreed that in the event that he defaulted and failed to pay the Settlement Amount
within give calendar days of his failure to cure the default, the United States may file
this Consent Judgment against Bernstein in the amount of $458,223, plus interest of
5% beginning on the date the judgment is entered and until paid.
6. Bernstein has failed to make payment in accordance with the Settlement
Agreement, and therefore is in default under the terms of the Settlement Agreement.
7. The United States has given Bernstein written notice of default under
the terms of the Settlement Agreement, and demanded that Bernstein cure that default
by tendering payment in full on the cure amount under the terms of the Settlement
Agreement. The United States has given Bernstein the appropriate time under the
terms of the Settlement Agreement to cure the default, but Bernstein has failed to
comply with the terms of the Settlement Agreement.
Accordingly, this Court enters judgment for the United States against Seth A.
Bernstein, in the amount of $458,223.00, plus interest of 12% beginning on the date
this judgment is entered and until this judgment is satisfied. All in Jets, LLC is hereby
dismissed without prejudice.
DONE AND ORDERED in the Southern District of Florida this ___ day of
___________, 2021.
__________________________________
CECELIA M. ALTONAGA
UNITED STATES DISTRICT JUDGE
DATE: ________________________________
Consent to file
Pursuant to the CM/ECF Administrative Procedures Rule 3J.(3), Adam T.
Rabin, Esq., Counsel for Relator and John T. Zach, Esq., Counsel for Defendants,
have each consented to the undersigned Assistant United States Attorney’s electronic
filing of this Joint Stipulation and proposed Order.
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Dated: Respectfully submitted,
BOIES SCHILLER FLEXNER LLP JUAN ANTONIO GONZALEZ
Acting United States Attorney
John T. Zach, Esq. JAMES A. WEINKLE
Andrew Steinmetz, Esq. Assistant United States Attorney
55 Hudson Yards Fla. Bar No.: 0710891
New York, NY 10001 99 N.E. 4th Street, Suite 300
Tel.: 646.642.7183 Miami, Florida 33132
Email: jzach@bsfllp.com Tel: 305.961.9290
Email: asteinmetz@bsfllp.com Email: James.Weinkle@usdoj.gov
Counsel for Defendants Counsel for United States of America
BRIAN M. BOYTON
Acting Assistant Attorney General
JAMIE ANN YAVELBERG
ALLISON CENDALI
JONATHAN H. GOLD
Attorneys
U.S. Department of Justice
Civil Division
P.O. Box 261, Ben Franklin Station
Washington, DC 20044
Tel.: 202.353-7123
Email: Jonathan.Gold@usdoj.gov
Counsel for United States
Victoria Hablitzel
Adam T. Rabin
Lauren E. Johnson
McCabe Rabin, P.A.
1601 Forum Place, Suite 201
West Palm Beach, FL 33401
Telephone: 561.659-7878
Email: arabin@mccaberabin.com
Email: ljolmson@mccaberabin.com
Counsel for Relator
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