Response | Filed: August 31, 2026
| Entered: August 31, 2026
United States of America et al v. Ilink Employers Company et al
Other Statutes: False Claims Act | California Central
Memorandum in Opposition to Motion
MEMORANDUM in Opposition to NOTICE OF MOTION AND MOTION for Partial Summary Judgment 126 filed by Defendants Alvaro Gabriel Ayala, iLink Business Management, Inc., iLink Employers Company. (Attachments: # 1 Statement of Genuine Disputes in Opposition to Relator's Motion for Partial Summary Judgment, # 2 Defendants' Evidentiary Objections to Relator's Summary-Judgment Evidence, # 3 Defendants' Opposition to Relator's Request for Judicial Notice in Support of Motion for Partial Summary Judgment, # 4 Declaration of Rachel Fiset in Support of Defendants' Opposition to Relator's Motion for Partial Summary Judgment, # 5 Exhibit 1- Relator Interrogatory Responses, # 6 Exhibit 2- Defendants Interrogatory Responses, # 7 Exhibit 3- Ayala Deposition, # 8 Exhibit 4- IEC Loan Info, # 9 Exhibit 5- IBM Loan Info, # 10 Exhibit 6- IEC CA Registration, # 11 Exhibit 7- Pittsburgh Ave. Property Info, # 12 Exhibit 8- Relator Name Change, # 13 Exhibit 9- Relator Registration, # 14 Exhibit 10- Relator Statement of Info, # 15 Exhibit 11- Hakimi Deposition Vol. I, # 16 Exhibit 11.1- Hakimi Deposition Vol. II, # 17 Exhibit 12- IEC Tax Return, # 18 Exhibit 13- Email from L. Olsen, # 19 Exhibit 14- IEC Certificate of Qualification, # 20 Exhibit 15- BofA Application Addendum, # 21 Exhibit 16- Real Estate Schedule, # 22 Exhibit 17- Email from M. Vazquez, # 23 Exhibit 18- Email from BofA, #
Response | Filed: August 31, 2026
| Entered: August 31, 2026
United States of America et al v. Ilink Employers Company et al
Other Statutes: False Claims Act | California Central
Response in Opposition to Motion
OPPOSITION to NOTICE OF MOTION AND MOTION for Summary Judgment as to all causes of action of Relator's Second Amended Complaint 129 filed by Plaintiff American Taxpayers Fighting Fraud LLC. (Attachments: # 1 Statement of Genuine Facts, # 2 Declaration of Kathryn Lee Boyd, # 3 Exhibit A - Ayala Decl. re SBA Loan Appeal, # 4 Exhibit B - Jul 29, 2020 Harvest Emails, # 5 Exhibit C - Jul 27, 2020 IEC PPP App, # 6 Exhibit D - Jul 23, 2026 Ayala Depo Excerpts, # 7 Exhibit E - Apr 1, 2019 High Tech Agmt & IBM lawsuit, # 8 Exhibit F - Apr 2, 2020 Email to Harvest, # 9 Exhibit G - Mar 31, 2020 IBM PPP App, # 10 Exhibit H - Jul 29, 2020 Email from Ayala, # 11 Exhibit I - Jul 27, 2020 Updated IEC PPP App., # 12 Exhibit J - Aug PPB Stmt IEC, # 13 Exhibit K - Feb 24, 2020 Capitol Agmt, # 14 Exhibit L - Apr 22, 2020 Email from Ayala, # 15 Exhibit M - Apr 21, 2020 IBM Memo, # 16 Exhibit N - June 11, 2020 Email Chain, # 17 Exhibit O - IEC Q3 2020 Form 941, # 18 Exhibit P - IEC Q1 2020 Form 941, # 19 Exhibit Q - IEC Q4 2020 Form 941, # 20 Exhibit R - SBA Loan Docs, # 21 Exhibit S - IEC Delaware Cert of Incorp, # 22 Exhibit T - 2020 IEC Tax Return, # 23 Exhibit U - Sept 19, 2022 Borrower Appeal, # 24 Exhibit W - Mar 13, 2023 Email to BOA, # 2138 additional result(s)