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False Claims Act Investigations and Defense


Practice Leader: J. Andrew Jackson

In recent years, Congress has expanded the False Claims Act’s (FCA’s) reach and penalties, and the Department of Justice (DOJ) has trumpeted the enormous sums it has recovered through alliances with private FCA whistleblowers. In fiscal year 2009, approximately $2 billion was recovered in lawsuits filed under the federal FCA’s qui tam provisions. Nearly every state legislature has enacted false claims legislation, many including qui tam provisions, and state FCA claims are on the rise.

It is more critical than ever that companies and boards of directors engage experienced counsel who have demonstrated the ability both to forestall government suits (for example, by convincing the DOJ to terminate an investigation or not to intervene in a sealed qui tam case) and to litigate aggressively and effectively when necessary.

For more than two decades, Dickstein Shapiro has represented companies and individuals in FCA investigations and litigation. Our False Claims Act Investigations and Defense Practice draws upon the experience of more than 25 former federal and state prosecutors and leverages experience from the firm’s Complex Dispute Resolution, Government Contracts, and State Attorneys General Practices to provide comprehensive service and advice to our clients.

Our attorneys represent companies in all phases of FCA investigations and litigate cases in federal and state courts around the country. More importantly, we have resolved FCA cases prior to intervention and costly litigation—effectively and quietly convincing enforcement officials to agree not to proceed or to resolve the matter short of litigation.

Dickstein Shapiro has successfully represented clients against FCA allegations involving nearly all forms of alleged misconduct, including: cost and labor mischarging, false representations and certifications, false statements, GSA schedule violations (including those based upon pricing and discounting disclosures), kickbacks, Medicare/Medicaid fraud, organizational conflicts of interests, and Truth in Negotiation Act violations. We have worked with clients in a wide array of industries, including professional services, hardware and software, pharmaceuticals and health care, and defense and civilian agency contracting.

Representative FCA Experience

Our FCA Practice has represented:

  • An international pharmaceutical company charged with Medicare and Medicaid fraud in the AWP false pricing cases. This qui tam case remained under seal for more than a decade. The DOJ intervened in multiple cases against other pharmaceutical companies, but we convinced them not to intervene against our client. This same qui tam case produced a multitude of federal and state private class actions, federal MDL proceedings, and multiple state attorney general actions alleging state FCA and common law fraud claims. We litigated these cases, narrowed issues and damages, and settled on favorable terms, not only for our litigation client but also for other pharmaceutical companies that retained us for our settlement expertise.
  • One of the world’s largest systems integrators in an FCA lawsuit alleging kickbacks, TINA violations, false statements, and anti-competitive activity. 
  • One of the world’s largest software companies in parallel criminal and civil FCA actions involving GSA schedule contract pricing and discounts. On behalf of our client, we cooperated with the DOJ’s investigation, prepared witnesses for grand jury appearances, and made detailed presentations that convinced the government to resolve the matter without criminal liability. The civil FCA claims were resolved out of court and at a small fraction of DOJ’s initial demand. 
  • A major hardware and software reseller defending FCA claims based upon alleged Trade Agreements Act and Buy American Act violations. Claims were dismissed after we filed early procedural motions. 
  • An international software, hardware, and networking company accused of false claims relating to GSA schedule contract pricing and discounts. Following the receipt of inspector general subpoenas and civil investigative demands, we prepared witnesses and defended depositions, and convinced the DOJ to settle at a substantially reduced amount. 
  • A major construction company regarding its affirmative damages claim relating to owner interferences. 
  • A fighter aircraft manufacturer concerning allegations of illegal gratuities, time mischarging, and improper progress payment requests. The district court granted our motion to dismiss, and we successfully defended that dismissal in the court of appeals. 
  • An aviation company, following the crash of one of its aircraft, concerning allegations that the aircraft was operating under false performance charts and weight documents, as well as in related wrongful death cases and other civil litigation arising from the crash.
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