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Further, on its application, LB&B represented that Ms. Brandon would be responsible for the day-to-day operation of the company and described Mr. Brandon’s role as limited to assisting the president. Id. ¶¶ 48-49. However, the Government alleges that Ms. Brandon had “no meaningful substantive role” in the daily operations of the company, and did not: (i) make specific decisions regarding bidding on new business; (ii) oversee [LB&B’s] performance of its government contracts . . . ; (iii) play any substantive role in the negotiation and formulation of [LB&B’s] government contracts; (iv) set and enforce expectations for the company’s general managers; (v) formulate specific company practices regarding collective bargaining and interactions with unions; or (vi) oversee the financial performance of [LB&B] on its government contracts. Id. ¶ 50. Those functions were instead overseen by Mr. Brandon and others. Id. ¶ 51. Thus, the Government alleges that Ms. Brandon’s actual role at the company “failed to satisfy the statutory and regulatory requirements of control sufficient to participate in the Section 8(a) business development program.” Id. ¶ 52.

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