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 38 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 litigation.”). 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.

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