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Other Statutes: False Claims Act | California Central
Response in Opposition to Motion
OPPOSITION to MOTION IN LIMINE (#2) to Exclude EVIDENCE OF SETTLEMENT COMMUNICATIONS WITH THE GOVERNMENT AND COURTORDERED MEDIATION COMMUNICATIONS 165 filed by Plaintiff American Taxpayers Fighting Fraud LLC. (Attachments: # 1 Declaration of Charles Dender, # 2 Exhibit 1 - IEC EDD Form DE 1 Registration, # 3 Exhibit 2 - IEC DE 9C Wage Reports Q1 2019-Q2 2023, # 4 Exhibit 3 - IEC DE 9 Report (iLink_111786), # 5 Exhibit 4 - IEC PPP Affiliation Worksheet (iLink_111896), # 6 Exhibit 5 - AV - IBM PPP Loan Application dated 4-3-2020 (iLink_111903), # 7 Exhibit 6 - IEC 2d Draw PPP Borrower Application dated 1-24-2021 (iLink_112051), # 8 Exhibit 7 - IBM 2d Draw PPP Borrower Application dated 1-20-2021 (iLink_112057), # 9 Exhibit 8 - IEC 2020 Payroll Summary (iLink_112063), # 10 Exhibit 9 - Apr 22, 2020 Email from Ayala (iLink_061747), # 11 Exhibit 10 - June 11, 2020 Email Chain (iLink_052997, # 12 Exhibit 11 - BC - DOJ Letter dated Sept. 23, 2024 (iLink_095653))(Dender, Charles)
OPPOSITION to MOTION IN LIMINE (#1) to Exclude (1) SBA OFFICE OF HEARINGS AND APPEALS DECISION IN APPEAL OF WINDSOR COURT HOTEL PARTNERS LLC; (2) SBA FAQ 72; AND (3) UPDATED SBA FAQs EFFECTIVE MAY 9, 2024 164 filed by Plaintiff American Taxpayers Fighting Fraud LLC. (Attachments: # 1 Declaration of Charles Dender, # 2 Exhibit 1 - Windsor Court PFR Decision, # 3 Exhibit 2 - Apr 22, 2020 Email from Ayala, # 4 Exhibit 3 - June 11, 2020 Email Chain, # 5 Exhibit 4 - Ayala Depo Excerpts, # 6 Exhibit 5 - SBA PPP FAQs Version 25, # 7 Exhibit 6 - SBA PPP FAQs Version 26, # 8 Exhibit 7 - IEC PPP Loan Forgiveness Application Form 3508EZ)(Dender, Charles)
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