Countrywide Whistleblower Awarded $58.6 million From Bank of America Settlement


Edward O’Donnell, the Countrywide whistleblower who tipped the government to the ‘Hustle’ program at the mortgage company, will receive a $58.6 million payout as a result of the historic $16.65 billion settlement between the U.S. Government and Bank of America in August.

The majority of the award, $57 million, is to be paid out under a False Claims Act lawsuit filed by O’Donnell in June.  The June lawsuit was the second he filed against Bank of America, the successor to Countrywide.   O’Donnell’s first lawsuit, filed in 2010, resulted in a $1.27 billion award now under appeal.  However, his potential reward from the case is limited because the judge dismissed the False Claims Act allegations back in 2013.  The jury trial proceeded on the allegations that Countrywide violated the Financial Institutions Reform, Recovery and Enforcement Act (FIRREA).

There is still the potential for at least two more awards since the Justice Department announced in August that the settlement resolved three qui tam lawsuits.

Overshadowed by the large reward paid under the False Claims Act may be the first FIRREA whistleblower award.  Although I haven’t seen a news report connect the dots yet, the additional $1.6 million to be paid to O’Donnell is the exact amount of the maximum reward under the law that has become the U.S. Government’s leading law against mortgage fraud.  The BofA settlement included a $5 billion penalty under FIRREA, the largest of its kind so far.

There have been a few other large settlements under FIRREA this year but this is the first announcement of an award that I have seen.  Earlier this year, I was unable to find a prior award announcement.  The law has been on the books for more than 20 years, so it seems likely that there have been prior payments.  But the law’s long history of disuse and recent revival suggest that even if there have been awards in the past, the number of people who have received them is still small.

In September, U.S. Attorney General Eric Holder proposed a modification of the payout calculation under the popular financial fraud law.  He suggested that the amount should instead be modeled after the False Claims Act and not limited to a maximum of $1.6 million.

Record Penalties Under FIRREA Boost Justice Department Collections to $24 Billion in FY2014


Record penalties under FIRREA helped make financial fraud the largest source of money collected by the Department of Justice through enforcement efforts in Fiscal Year 2014.  The DOJ statistics released today revealed that agency led enforcement actions and negotiated civil settlements resulted in collections of more than $24 billion during the fiscal year ending in September.

FIRREA had fallen into disuse until prosecutors began bringing enforcement actions against banks for conduct surrounding the financial crisis of 2008.  Now, it has become the nation’s leading tool against mortgage fraud.  It resulted in settlement amounts of $2 billion (JPMorgan), $4 billion (Citigroup) and $5 billion (Bank of America) over the past year as banks sought to put their misconduct involving residential mortgage backed securities behind them.  JPMorgan and Citigroup were cited by the DOJ as paying significant sums in 2014, with Bank of America unnamed.  Because the BofA settlement happened toward the end of the fiscal year, it may not have paid the money to the U.S. Government yet.

FIRREA’s increasing importance also led Attorney General Eric Holder to call for an increase in the law’s incentives for whistleblowers just days before he announced he was stepping down.  Rewards are currently capped at a maximum of $1.6 million.  The False Claims Act, SEC and IRS programs are all uncapped, with payments potentially reaching over $100 million on large cases.

In the press release, the Justice Department credited whistleblowers under the False Claims Act for bringing many of the cases leading to large civil collections.  Whistleblowers were involved in a number of large cases reaching a resolution in 2014, including investigations into Bank of America and JPMorgan Chase in the financial arena and Johnson & Johnson in health care.

The DOJ press release added another financial crime to the list of penalties paid by financial institutions: LIBOR manipulation.  UBS Securities Japan and RBS Securities Japan paid large amounts to end investigations into their manipulation of the London Interbank Offered Rate.

The $24 billion number includes money paid during FY2014 even if the settlement or enforcement action happened in a preceding year.  It excludes settlements agreed to in 2014 but not paid during the government’s fiscal year.  The DOJ received $13.7 billion while its civil and criminal enforcement efforts helped other federal agencies, states and additional parties receive another $11 billion.  It’s unclear to us how much, if any, overlaps with the $7 billion collected by the CFTC and SEC.

The amount was more than three times the $8.1 billion collected in 2013.  The ongoing antitrust investigation into the auto parts industry, environmental cleanups of pollution and criminal penalties for violations of the FCPA also led to significant collections.  Significant antitrust and environmental cases also led to more than $1 billion in 2013.

Last year, health care fraud topped the list of collections with large fines paid by Abbott and Amgen.  It’s absence from the list this year is noticeable because of the large amounts settlements gathered from this area in the past ten years for violations of the False Claims Act.

For additional information about today’s DOJ announcement, here is the press release.


Whistleblower Awaits Award in JPMorgan’s $614 Million Mortgage Fraud Settlement


The U.S. District Court for the Southern District of New York (Manhattan) unsealed a whistleblower lawsuit against financial services firm JPMorgan this week. The qui tam lawsuit, originally filed in January 2013 by Keith Edwards of Louisiana, accused JPMorgan of violations of the False Claim Act for mortgage fraud. In the settlement, JPMorgan acknowledged its wrongdoing and agreed to pay $614 million to the federal government.

Since 2002, JPMorgan originated thousands of residential home loans insured and guaranteed by the Federal Housing Administration and Department of Veterans Affairs that were not actually eligible based on the underwriting requirements of the relevant agency. JPMorgan falsely certified to the agencies that the loans met the required underwriting standard. When the loans defaulted, the government lost millions. An internal audit by JPMorgan revealed more than 500 loans improperly submitted to the FHA and VA for insurance, but JPMorgan did not notify the government about its discovery.

The percentage of money the government will pay to Edwards as a whistleblower reward has not yet been set. The False Claims Act provides for an award to the whistleblower of between 15 and 30 percent of the amount recovered by the government. Because the Justice Department intervened in the case, the relator is entitled to 15 to 25 percent. Edwards was employed by JPMorgan in Louisiana at the banks government insuring unit when he discovered the fraud.

The lawsuit is one of eight civil fraud cases brought by the Office of the U.S. Attorney for the Southern District of New York regarding improper residential mortgage lending by the nation’s banks. Citigroup, Deutsche Bank and Flagstar Bancorp have already agreed to pay settlements for their misconduct.

2014 has already been a busy year for fraud settlements by our nation’s banks. JPMorgan agreed to pay $2 billion to settle charges related to its failure to report the Ponzi scheme conducted by Bernard L. Madoff to the government. Bank of America recently settled with a group of mortgage securities investors for $8.5 billion. And Morgan Stanley agreed to pay $1.25 billion to the Federal Housing Finance Agency for its sale of mortgage securities to Fannie Mae and Freddie Mac.

McEldrew Young Purtell is a nationwide leader in the False Claims Act and has successfully represented clients in some of the nation’s largest qui tam cases for over a decade.  For a free confidential consultation, please call Eric L. Young, Esquire at (800) 590-4116 or complete the online form here.

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A federal judge has signaled that $1 million is too low of a penalty for those responsible for the Countrywide mortgage fraud debacle.  At a hearing last week in a Manhattan federal court, Judge Jed S. Rakoff, declared that such a penalty would be a “windfall” for Bank of America, Corp., (“BofA”) the entity legally responsible for its now defunct subsidiary, Countrywide Financial Corp. (“Countrywide”).  While he has not yet determined the penalty, Judge Rakoff stated, “[i]t would be a windfall to a perpetrator who made, hypothetically, $100 million, to just penalize them $1 million…[t]hat would have no deterrent effect at all.”

As reported earlier by Young Law Group, in October a jury unanimously found BofA and former Countrywide executive, Rebecca Mairone, liable for civil fraud after a lengthy trial focusing on the companies’ sale of junk mortgages leading up to the mortgage crisis of 2007 and 2008.  Former Countrywide executive turned whistleblower, Edward O’Donnell, initially filed the case in federal court.  The details of the case involve a program, internally deemed “Hustle,” wherein Countrywide eliminated substantive vetting of home loan recipients, but also pushed employees for higher loan volume by paying lucrative bonuses.  Shortly before the economy collapsed, Countrywide sold over 30,000 risky mortgages, worth hundreds of millions of dollars, to Fannie Mae and Freddie Mac.

U.S. Attorney Preet Bharara of the Southern District of New York prosecuted the case using an under-utilized weapon in the fight against fraud, the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (“FIRREA”).  Like the False Claims Act, FIRREA has a whistleblower provision, which will likely ensure O’Donnell receives a percentage of the government’s total recovery.  FIRREA makes it a crime to perpetrate fraud against a federally insured financial institution.

FIRREA generally sets the maximum penalty of $1.1 million, but gives the sentencing judge discretion if the defendant has caused losses or made gains in excess of this amount.  The Department of Justice is seeking $848.2 million in fines and penalties, a figure it roughly equates with the financial damages sustained by the Fannie Mae and Freddie Mac.  BofA argues that the losses suffered by Fannie and Freddie were a result of overall economic downturn and not any fraud on Countrywide’s part.  Thus, the financial giant’s lawyers maintain that it should pay no penalty, or at maximum the general statutory cap of $1.1 million.  Judge Rakoff’s statements in last week’s hearing, however, clearly indicate that he does not think the statutory cap binds his judgment and he believes BofA is liable for either gains it made as a result of its fraud, losses maintained by the government, or both.  However, the total amount that Judge Rakoff will ultimately order BofA to pay is unclear at this time.

Young Law Group is a nationwide leader in whistleblower representation and has successfully represented numerous clients in some of the nation’s largest qui tam cases for over a decade.  For a free confidential consultation, please call Eric L. Young, Esquire at (800) 590-4116 or complete the online form here.



Just weeks after being found liable for violations of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (“FIRREA”), Bank of America, Corp. (“BofA”) is again facing allegations of mortgage related fraud.  This time the lawsuit asserts that BofA defrauded the federal government and multitudes of borrowers by gaming the Home Affordable Refinance Program (“HARP”).  The Federal Housing Finance Agency (“FHFA”) established HARP in March of 2009 to help alleviate the troubles created by plummeting property values after the burst of the U.S. housing bubble in 2006.

Specifically, HARP facilitates refinancing for underwater homeowners, who are otherwise current on their payments, by offering favorable interest rates and refinancing without mortgage insurance.  In order to participate in HARP, an underwater homeowner’s mortgage must be owned or guaranteed by federally-backed Fannie Mae or Freddie Mac.  To further encourage refinancing, the FHFA substantially reduced loan level price adjustments (“LLPAs”), common risk-based fees, for HARP loans purchased by Fannie and Freddie.  The removal of LLPAs was designed as a cost reduction for lenders, who would in turn pass the savings on to borrowers.

However, one such homeowner, John J. Platz, alleges in his qui tam complaint filed under the False Claims Act that BofA profited illegally by first, pushing the FHFA to drop LLPAs, but then failing to pass along savings to consumers.  Platz contends that this violated the terms and conditions of payment for lenders under HARP and resulted in the submission of thousands of false claims to the federal government.

Young Law Group is a nationwide leader in whistleblower representation and has successfully represented numerous clients in some of the nation’s largest qui tam cases for over a decade.  For a free confidential consultation, please call Eric L. Young, Esquire at (800) 590-4116 or complete the online form here.

U.S. Department of Justice Scores Major Win Against Mortgage Fraud


This week the U.S. Department of Justice (“DOJ”) announced a significant victory in the fight against mortgage fraud.  A federal jury in the Southern District of New York found Bank of America Corp. (“BofA”) and former Countrywide executive, Rebecca Mairone, liable for civil fraud after a lengthy trial focusing on the companies’ actions leading up to the financial crisis of 2008.  BofA acquired Countrywide and assumed its liabilities just months before the financial collapse, from which the nation is still reeling.  While U.S. District Court Judge Jed Rakoff will determine the ultimate penalty, the DOJ is seeking $848.2 million from the financial giant.

The suit, U.S. ex rel. O’Donnell v. Bank of America Corp, originated with a whistleblower, former Countrywide executive Edward O’Donnell, who provided inside information into the firm’s fraudulent home loan practices and surely proved invaluable to the case.  The case surrounds a Countrywide program, known as the “High Speed Swim Lane,” or tellingly “Hustle” for short.  Under “Hustle” Countrywide originated millions of dollars in shoddy home mortgages, which were subsequently sold to government operated Fannie Mae and Freddie Mac.  At the time, Countrywide eliminated the substantive vetting of loan recipients, while simultaneously paying lucrative bonuses to employees to incentivize volume, a proverbial recipe for disaster.  Not surprisingly, about forty-three percent of the loans issued under “Hustle” had material defects.  After the economy collapsed, precipitating the federal government takeover of Fannie and Freddie, American taxpayers were left holding the bag.

To prosecute the case, DOJ utilized the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (“FIRREA”), an often overlooked weapon in its arsenal.  Among other provisions, FIRREA outlaws fraud against a federally insured financial institution.  Similar to other federal laws that fight fraud, FIRREA has a whistleblower provision through which knowledgably insiders are entitled to a percentage of the government’s recovery.

In a rare move for a bank facing legitimate fraud allegations, BofA opted not to settle out of court, but defend the case at trial with a highly paid team of corporate defense lawyers.  One must wonder whether it now regrets that decision, given an increasing climate of public hostility towards risky lending and investing practices.  Seemingly indicating the DOJ’s unwillingness to balk at the prospect of facing off against financial giants in court, U.S. Attorney Preet Bharara in the Southern District of New York recently stated, “[t]his office will never hesitate to go to trial to expose fraudulent corporate conduct and to hold companies accountable, particularly when it has caused such harm to the public.”

Young Law Group is a nationwide leader in whistleblower representation and has successfully represented numerous clients in some of the nation’s largest qui tam cases for over a decade.  For a free confidential consultation, please call Eric L. Young, Esquire at (800) 590-4116 or complete the online form here.

Government Settles $158 Million Mortgage Fraud Suit With Citigroup


This past week, Citigroup Inc. came to a $158 million settlement with the Justice Department over the Mortgage division’s fraudulent loan origination and lending practices. Thanks to the work of a courageous whistleblower, the government was able to hold Citigroup accountable. The settlement here comes on the heels of last week’s Justice Department settlement with Bank of America over its practices relating to underwriting and originating loans. It appears that Citigroup will also be involved in the country-wide settlement between the government and the nation’s largest mortgage lenders. This 40-state settlement is worth $25 billion, $2.2 billion of which will come from Citigroup. Because it falsely portrayed mortgages as meeting government insurance standards, which falls under the False Claims Act, Citigroup is finally being held accountable to the American public.

Credit is due to whistleblower Sherry Hunt, a quality-assurance worker at CitiMortgage, for providing information to the government about her company’s fraudulent activities. Ms. Hunt was able to assist the Justice Department due to the reforms put in place under the Dodd-Frank Wall Street Reform Act. This legislation created a special whistleblower program within the Securities and Exchange Commission (SEC) for purposes of cracking down on broken security laws, practices that cheat investors, and other illegal practices that go beyond government fraud which is described in the False Claims Act. This program has proven to be a boon to the government and to the American public, because it has opened the door to recovery of revenue that was unfairly taken by companies who chose to ignore the law. In the past, many of these companies were able to hide their fraud and if someone tried to expose their actions, the companies would retaliate against that person. Now, under Dodd-Frank, these whistleblowers come under the protection of the SEC Whistleblower Office. The program is not without its flaws and whistleblowers continue to suffer from various types of retaliatory actions, but it is a step in the right direction.

The American people have waited too long for the government to hold accountable those responsible for the recession. Millions have lost their homes, have gone into bankruptcy, and have lost their jobs. Citigroup contributed to this problem by ignoring the standards set for choosing borrowers and using the government’s insurance to back up their unnecessary risks. Action was needed in order to show Citigroup they could not risk the American taxpayers’ money, and that there would be consequences to knowingly defrauding the government. The creation of the SEC whistleblower program has been an important by-product of the recession, because now the government can effectively fight back.SEC Chairman Mary Schapiro has even said that the program has brought in thousands of tips from potential whistleblowers that have helped their investigate team prosecute offenders more efficiently. Hopefully, the recent actions against these mortgage giants will not only hold accountable those responsible for defrauding the government, but also act as a warning to other would-be perpetrators of mortgage fraud.

See Also:

Bank of America Settles Billion Dollar Mortgage Fraud Case


On February 9, 2012, the Justice Department announced the settlement of one of the largest False Claims Act cases relating to mortgage fraud in history. Bank of America (BOA) and its Countrywide Financial Subsidiaries will have to pay upwards of $1 billion for reckless behavior in underwriting loans to unqualified borrowers. These loans were insured by the Federal Housing Administration (FHA). When the borrowers could not pay back the loans, the FHA suffered hundreds of millions of dollars in damages. Originally, the FHA agreed to insure the loans without the knowledge that Countrywide was originating the mortgage loans based on inflated appraisals. Since BOA acquired Countrywide in 2008, they are responsible for the subsidiary’s actions. The $1 billion will be split between recovery for the FHA and a program to fund loan modification for anyone who is a Countrywide borrower.

This case is extremely important in holding the banks accountable for the resulting chaos of the recent mortgage crisis. What is interesting in this particular case is that the government has decided not to retrieve all of the money directly; instead it is building a program with part of the recovery to help the borrowers. While it is important for the government to restock the treasury and address the debt problem, the ultimate goal is to help the taxpayers who were hurt the most when the bubble burst. The way Countrywide conducted itself with regard to the FHA and to the borrowers, shows that it is more interested in producing solvent investments for the company, rather than adhering to the law regarding determining qualified borrowers. Not only is the settlement a victory for proponents of the False Claims Act as a necessary tool, but also for the American public.

Countrywide Financial Subsidiaries is not the only company being held responsible for its actions. Bank of America was also being investigated for its role in defrauding the government over the eligibility of homeowners involved with the Home Affordable Modification Program. It seems that even after BOA acquired Countrywide, the fraudulent practices did not end. The country is still reeling from the effects of the subprime mortgage crisis of 2008. Slowly the economy seems to be improving, but that is not the case for millions of Americans that became victims of practices like those utilized by Bank of America and Countrywide Financial. Were it not for the False Claims Act, the settlement may not have been this substantial and would not be on its way towards helping those borrowers in need. With the implementation of the Dodd-Frank Wall Street Reform bill and the strengthening of the False Claims Act, the tools are now available to expose and bring to justice these fraudulent acts.

See Also:

U.S. Intervenes in False Claims Act lawsuit against Allied Home Mortgage


As reported by Bob Van Voris and Patricia Hurtado here Allied Home Mortgage Capital Corp., which last year claimed to be the biggest closely held mortgage broker in the U.S., was sued by federal authorities for alleged fraudulent lending practices.

The U.S., by and through the Southern District of New York’s U.S. Attorney’s office, has intervened on a qui tam filing by former branch manager, Peter Belli against Allied, founder and Chief Executive Officer Jim Hodge and Jeanne Stell, Allied’s chief compliance officer. The government claims one-third of the 112,324 loans originated by Allied from 2001 to through 2010 defaulted, forcing the U.S. Department of Housing and Urban Development to pay $834 million in insurance claims, according to a complaint filed in federal court in Manhattan today.

“Allied has profited for years as one of the nation’s largest FHA lenders by engaging in reckless mortgage lending, flouting the requirements of the FHA mortgage insurance program, and repeatedly lying about its compliance,” the U.S. said in the complaint. “In the past decade, Allied has originated loans out of hundreds of branches it never disclosed to HUD.”

The government, represented by the office of U.S. Attorney Preet Bharara in Manhattan, claims Hodge created a “culture of corruption” and used offshore compliance employees who didn’t even know what mortgages were. The U.S. is seeking triple damages from Allied under the federal False Claims Act.

Hud Audit

A 2000 HUD audit of two branch offices in Arizona found that Allied was operating 13 unapproved satellite offices, one of which originated 221 loans in 24 months, the U.S. said.

By 2006, HUD required that every office originating or processing Federal Housing Administration loans be approved by the agency. Allied continued to operate satellite branches, the U.S. claimed.

In applying for a new HUD ID, the U.S. said, Stell allegedly changed the address of the branch slightly, by adding a suite number or changing “Street” to “St.”, so that the FHA system couldn’t detect that it was issuing multiple IDs to Allied branches. In late 2010 and early 2011, Allied switched all of its remaining approved branches from the ownership of Allied to Allied Home Mortgage, thereby obtaining new IDs for the branches.

Allied employed individuals with criminal convictions in violations of HUD and FHA requirements, the U.S. said. Washington State banned a Spokane branch manager from working as a mortgage broker in 2006 after he was convicted of stealing clients’ money and laundering it, according to the complaint.

The case is U.S. v. Allied Home Mortgage Corp., 11-cv-5443, U.S. District Court, Southern District of New York (Manhattan).

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If you feel you may have information concerning mortgage fraud, please call 800-590-4116 for a FREE AND CONFIDENTIAL attorney consultation today.

TARP fraud uncovered: Bank CEO pleads guilty in New York City


The  ironies of TARP — the Troubled Assets Relief Program—may take decades to be understood. In the same manner of most great American financial crises, from the days of railroad bribery and trust-busting to world war munitions graft… claims of rights and wrongs are usually obscure. The October 2010 conviction of a white collar TARP criminal, however, suggest the days of reckoning for TARP may not be as long in coming as is historically usual.

Acting with unusual speed, federal officials went from closing a prominent New York City bank (March 12, 2010) to arresting its CEO and President at his home (March 15, 2010). The president and CEO of New York’s Park Avenue Bank, Charles J. Antonucci (59), this fall took a plea agreement with federal prosecutors. Antonucci admitted to taking more than $11 million illegally from TARP.

Antonucci’s guilty plea was the conclusion of the first prosecution of misappropriated TARP funds.

As with TARP’s national premises, Antonucci’s offenses also crossed state lines…literally and figuratively. What remains shrouded, however, is the extent to which federal prosecutors will use their discretion to pursue a potential slew of unindicted co-conspirators. Count Three in the complaint gives an inkling to the potential breadth of this problem, given recent revelations into how high flying banks have cozied up with influential customers:

Antonucci accepted bribes from customers of the Bank, including but not limited to over $250,000 in cash bribes, free use of a customer’s airplane, and free use of another customer’s luxury automobile, in exchange for Antonucci’s approval of various banking transactions. Indeed, on more than ten occasions in 2008 and 2009, Antonucci used a private plane owned by a co-conspirator (“CC-1”) to fly to, among other places, Florida, Panama, Arizona (so that Antonucci could attend the Super Bowl), and Augusta, Georgia (so that Antonucci could attend the Masters Golf Tournament). All the while, Antonucci approved over $8 million in overdrafts on accounts for entities controlled by CC-1 at Park Avenue Bank.

One sophisticated and potentially aggressive component of the TARP program utilizes classic whistle blower techniques…meet the sleuth next door, SIGTARP. Though not a law enforcement agency, SITARP relies extensively on public input: and SIGTARP’s inspector has shown a  willingness to confront his peers at Treasury.

But critics have argued the enabling language of TARP may be  as guilty as Antonucci. Though in Antonucci’s case, obtaining a plea agreement was likely seen as being of the highest priority, subsequent prosecutions of TARP offenses may look toward fleshing out intent offenses under the legislation…making insider information, typically obtained best by whistle blowing, ever more vital. Whistle blowing for enforcing “intent” of TARP’s vague regulation will complicate the tasks of those given the responsibility of managing the language. And the police powers under TARP are already vague.

“Residential or commercial mortgages and any securities, obligations, or other instruments that are based on or related to such mortgages, that in each case was originated or issued on or before March 14, 2008, the purchase of which the Treasury Secretary determines promotes financial market stability. And any other financial instrument that the Treasury Secretary, after consultation with the Chairman of the Board of Governors of the Federal Reserve System, determines the purchase of which is necessary to promote financial market stability, but only upon transmittal of such determination, in writing, to the appropriate committees of Congress.”

The vagueness of TARP’s language has led one important voice to attack the intention of TARP: and by implication, similar bailouts. According to Neil Barofsky, who serves as the Special Inspector General for TARP:

“Inadequate oversight and insufficient information about what companies are doing with the money leaves the program open to fraud, including conflicts of interest facing fund managers, collusion between participants and vulnerabilities to money laundering.”

The Washington Post has reported (July 20, 2009) the Treasury Department refused to implement Barofsky’s recommendations to Congress for TARP reform. Instead, Treasury official insist, tracking TARP funds to banks is akin to tracking “water poured into the ocean.”

“TARP  and the Acronym of Trouble:  Good Rap, Bad Rap”

This article is brought to you by the QTT, the epicenter for whistleblowers and people interested in the False Claims Act, Qui Tam Provisions, and Medicare and Medicaid fraud. To discuss a potential case, please call Eric Young at 1 (800) 590-4116.

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