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, #
Motion | 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
Leave to File Document Under Seal
APPLICATION to file document Opposition to MSJ, Statement of Genuine Fact, Exhibits AK, AQ, AV, BD, and BE to the Opposition to Motion for Summary Judgment under seal filed by Plaintiff American Taxpayers Fighting Fraud LLC. (Attachments: # 1 Opposition to MSJ (Redacted), # 2 Statement of Genuine Facts (Redacted), # 3 Exhibit AK - IEC 2020 Q1 Form 941 (Redacted), # 4 Exhibit AQ - 2020 IEC W2s (Redacted), # 5 Exhibit AV - IBM PPP Loan App, Apr 3 2020 (Redacted), # 6 Exhibit BD - IEC 2019 to 2023 Wage Reports (Redacted), # 7 Exhibit BE - IEC Report (Redacted), # 8 Proposed Order)(Nelson, Kristen)