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1. Allegations in the Government’s Complaint in Intervention2 LB&B was incorporated in 1992. Govt. Compl. ¶ 28. Initially, the Board of Directors of the company had six members, only two of whom were socially and economically disadvantaged: Ms. Brandon and her son, F. Edward Brandon Jr. Relators and the Government allege that neither possessed sufficient skills or experience to run a company engaged in LB&B’s main lines of business -- government contracts, manufacturing, facilities management, and government services. Id. ¶¶ 29-30. Three of the other directors, including Defendant 2 These allegations relate to claims made in both the Relators’ complaint as well as in the United States’ complaint in intervention.

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