Qui Tam Statue of Limitations

Id. at 849. The Frascella court found the government’s argument unavailing because a 1998 audit by the GSA had uncovered some of the same false statements alleged in relator’s complaint. The government, the court held, was thus on inquiry notice of these statements such that a reasonable person would investigate. Id. at 851-853. Despite Defendants’ contention that the facts of Frascella are identical to those here, there was no earlier filed qui tam action at issue in Frascella that the government claimed was the specific starting date for statute of limitations purposes. See Defs.’ MTD Govt.’s Compl. at 17. Similarly, the issue before the court in Purcell was analytically distinct.

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