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SBA Fraud Attorney
Id. ¶¶ 53-
56. With respect to the Chilkat joint venture, Relators allege
that Mr. Jahn was a senior vice president at LB&B during 2006,
and that LB&B and Chilkat entered into a joint venture agreement
in which he was listed as the project manager. Id. ¶¶ 63-64.
Relators allege that in late 2006 or early 2007, Mr. Jahn’s
employment was switched to Chilkat for the purposes of the joint
venture agreement. Id. ¶ 64. Relators do not provide a
specific date for the approval of the joint venture, noting only
that it was approved “in or about 2006.” Id. ¶ 64. Relators
also contend that Relator Buechler did in fact work with the
BSA/LB&B joint venture. See Relators’ Opp’n at 22 n.6 (citing
Compl. ¶¶ 61-62).
Relators additionally allege that although Mr. Krulic and
Mr. Jahn were listed as “general managers” by defendants, they
were, in actuality, project managers. According to Relators,
they were employees of LB&B and then moved over to the joint
venture, such that the relevant “project manager” was not from
an 8(a) protégé company. See id. at 20-21. Relators also
contend that they should be allowed to conduct discovery on the
work these men performed to see if Defendants were in
contravention of the applicable regulations. See id. at 21; see
also Allen v. Beta Constr., 309 F. Supp. 2d 42, 47 (D.D.C. 2004)
(“[W]hile significant details  will be necessary . . . these
details are not necessary at this very preliminary stage of
Further, Relators also allege that Defendants listed Andrew
F. Van Der Stuyf, Edward J. Keenan, Donald Wilson, and Donald
Krauth as project managers on contracts secured pursuant to the
mentor-protégé relationship. These contracts were entered into
in October, November, and December 2004. At the time of
contracting, Mr. Van Der Stuyf, Mr. Keenan, Mr. Wilson, and Mr.
Krauth were purportedly employees of LB&B, despite the fact that
they were listed as project managers. See Relators’ Compl. ¶¶
53-55. Relators allege that they did not “switch” their
employment to BSA until the end of January 2005.