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Are the Rewards for a Qui Tam Whistleblower Worth the Risks?

Qui Tam Whistleblower

Qui Tam WhistleblowerIf you’re thinking of becoming a qui tam whistleblower, you’re probably wondering about the ramifications of your choice. It’s natural to be curious about all the impacts when making a life-altering decision, and there’s certainly plenty of literature out there detailing the potential pitfalls. However, there’s also significant upside.

To help you along, we’ve gone ahead and compiled a list of pros and cons to becoming a whistleblower. While we certainly can’t tell you whether to proceed (or not), we can at least offer you more information for your consideration. Take a look, think it through carefully, and then you can decide how best to proceed.

Pros to Becoming a Qui Tam Whistleblower

  1. Whistleblowers Rewarded with Lots of Money (Potentially)

This is usually one of the number one reasons people decide to become a whistleblower. The rewards for doing so can be staggering; as much as 30% of the dollars recovered. This has been a staple of the False Claims Act since inception, with the prevailing thought at the time being you must use a scoundrel to catch a scoundrel, and all scoundrels are motivated primarily by money.

Whether or not you’ve been complicit in the fraud, you may still be entitled to a healthy sum of money. In fact, the current record award to an individual currently stands at over $100 million. However, the size of your reward will ultimately depend on the amount of money reclaimed.

  1. If You Speak Up, You’ll Have a Clear Conscience

There’s quite a lot to be said for being able to have peace of mind and an undisturbed night’s sleep. Many people feel they have a moral obligation to report fraud once they have uncovered it. Not doing so leaves them with a heavy psychological weight that can be detrimental to health and wellbeing over time.

  1. Protect the Innocent by Filing a False Claims Suit

Many (though not all) cases involve taking advantage of individuals without their knowledge or consent. Whether it’s issuance of substandard materials, or prescribing an aggressive but unneeded course of treatment, there are people out there who are at the mercy of the system. And sometimes the only person willing and able to protect them is you.

Cons of Becoming a Qui Tam Whistleblower

  1. If You Blow the Whistle, Your Life Will Change Forever

Whether you like it or not, eventually it will come out that you played a role in this lawsuit. This can mean all kinds of things for you on a personal level. Unwanted media attention. Alienation by former friends and co-workers. Industry blacklisting. These are all possible pitfalls associated with filing suit. You need to be sure the risk is worth the reward.

  1. You Can Still Lose as a Whistleblower

Contrary to what some people might tell you, there is no guarantee when it comes to filing a qui tam lawsuit. If your case isn’t rock-solid, the court may still find the company’s favor. Or, the court might determine the scope of your case to be quite small, meaning your reward could be 30% of almost nothing.

Still Wondering Whether to File a Qui Tam Suit?

Call 770-643-1606 to learn more about the pros and cons that come with being a qui tam whistleblower by contacting Bothwell Law Group online.

What Determines Who Pays Whistleblower Attorney Fees?

Whistleblower Attorney Fees

Whistleblower Attorney FeesIf you’re wondering how whistleblower attorney fees work, and how much a qui tam lawsuit might cost you, the short answer is virtually nothing. While we can’t say it will never cost you anything, there is no initial charge to bring a case. In the event you do need to pay costs, it usually comes directly from the money recovered by the lawsuit.

Here is an overview of how the process usually works:

The Start: Filing a False Claims Act Case

The costs to get started on an FCA or qui tam case are relatively small, including a small federal filing fee and possible administrative expenses. However, when you file a qui tam case, your lawyer is likely to ask you to agree to something called a contingent fee arrangement. This means in the event you win your case, your lawyer will both get a share of the recovered funds, as well as the cost of fees and expenses.

It’s also possible the court will order the defendant to pay statutory fees if your settlement or case verdict is favorable. Regardless of which scenario occurs, you can file a case and carry it through to the end without needing to pay any money up front.

Government Intervention: Whether Uncle Sam Decides to Join Your Case

FCA claims are a bit different than the normal court case or civil litigation. When you file, you inform the government of your case, but not the defendant. You must inform them of the particular facts surrounding your case, so the government can investigate the claims. The entire time the government is conducting its investigation, the case is considered “under seal”; this means you can’t talk to anyone about it, except your lawyer.

Based on the results of their investigation, the government will then decide to join (or not). If they join, they will work with your attorney to settle the claims in your case. This also significantly increases the chances the court will find in your favor during the proceedings. The government may decide to take over the prosecution, and determine whether they are willing to settle or take it to full trial. Your portion of the recovery will be between 15% and 25% of the recovered amount, and you will pay your lawyer out of the proceeds.

In most cases, the government decides not join, or intervene, in a case. However, this doesn’t mean you can’t proceed. Many cases have been successfully settled without government intervention. In the event you decide to carry it forward, you and your lawyer will have another conversation about likely outcome and cost burden during the proceedings. Without the government’s help, you may need to cover some costs during the trial, but if you win the recovery, you’ll get as much as 30% of the recovered amount. You can then recoup your costs from the proceeds and pay any outstanding legal invoices.

More Questions on Whistleblower Attorney Fees?

No problem! Contact the skilled attorneys at Bothwell Law Group by calling 770.643.1606, and ask about how we handle whistleblower attorney fees.

What Is the False Claims Act and When Did It Take Effect?

What Is the False Claims Act

What Is the False Claims ActIf you’ve been wondering, “ What is the False Claims Act, and why do I care? ” then this post is for you! Originally called the “Lincoln Law,” it was originally enacted in 1863, as a result of shady dealings the government had with suppliers during the Civil War.

At its most basic level, it codifies a process for investigating fraud in all kinds of government claims and contracts, giving Uncle Sam the teeth needed to get money back when it’s due. It establishes clear liability for any person or entity who receives funds from, or avoids payments to, the federal government on a fraudulent basis. And it affords individuals incentives, and protection, in exchange for a detailed reporting of fraud against the government. (The one notable exception to this is tax fraud; it’s governed by a different set of laws and statutes).

Qui Tam Provision

One of the most important features, the qui tam provision, permits private citizens to sue individuals and businesses on behalf of the U.S. Government. If the suit brings damages or compensation, the petitioner is paid a percentage of the recovered funds. This was due in large part to Senator Jacob M. Howard, who believed anyone who had knowledge of unethical activities were likely engaged in them already. His qui tam compensation plan was aimed at “setting a rogue to catch a rogue.”

It also outlines strict provisions for protecting the whistleblower. Lawsuits are filed in secret, without the suspect party being notified. The filer also is shielded from retaliation by the defendant. They cannot be harassed, lose their job, or otherwise be discriminated against as a result of filing suit. Any form of retaliation against the plaintiff will result in an award of damages for hardship and suffering, as well as any owed back pay, including interest.

False Claims Act: Billions in Recovered Dollars

Throughout the decades, the FCA has been revised on a number of occasions. While originally designed and used against defense contractors, the rise of healthcare fraud in mid-90’s led to a shift in focus. However, in 2015, the Justice Department recovered over $3.5 billion in false claims, with $1.1 billion of that number still coming from false claims made by federal defense contractors.

A majority of the recoveries were made under qui tam lawsuits, which entitled the filers to anywhere from 15% to 30% of the recovered monies. Whistleblower awards totaled $597 million this year; a little over 17% of total money recovered.

Think You Have a Case Covered by the False Claims Act and Qui Tam?

The first thing you need is an experienced lawyer, and Bothwell Law group can help. Find out what you need to know by calling 770.643.1606, and we’ll explain what the False Claim Act is, and help determine if it applies to you.

What Is a Qui Tam Lawsuit and Are There Consequences for the Whistleblower?

What Is a Qui Tam Lawsuit

What Is a Qui Tam LawsuitIf you’re new to the medical industry, you may be wondering what a qui tam lawsuit actually is. Even if you’re an industry veteran, the term “qui tam” is not exactly intuitive, and you might be wondering who this Qui Tam person is. Keep reading for the details you need to know to get some clarification on this important topic.

What Is the False Claim Act, and Where Does Qui Tam Fit In?

The False Claim Act is a law protecting whistleblowers, and aimed at preventing and punishing anyone trying to defraud the government. Qui tam lawsuits are a particular type of civil lawsuit, covered under the FCA, which allow an individual or group to bring suit on behalf of the government.

The term “qui tam” is actually an abbreviation of the Latin phrase “qui tam pro domino rege quam pro se ipso in hac parte sequitur” – or – he who brings a case on behalf of our lord the King, as well as for himself. Perhaps you can see why “qui tam” is the shortened abbreviation?

Protection for Qui Tam Whistleblowers

Under the FCA, whistleblowers are explicitly protected from retaliation and discrimination. This protection begins right from the start, with lawsuits being filed under seal. In other words, only the person filing and the government are aware of the allegations and ongoing investigation.

Once filed, an anti-retaliation provision takes effect. This protects the person filing (also known as a relator) from things such as being fired, harassment or other negative job-related problems resulting from reporting the fraudulent activities to the government. Anyone found to be in violation of the retaliation provision can be liable for double damages, plus additional attorney fees. Damages can include both lost wages, as well as other harm suffered.

Rewards for Favorable Qui Tam Lawsuits

In the event the relator wins their case, they can be awarded as much as 30% of the recovery money. How large the award is will depend on a few factors.

Firstly, whether or not the government decides to intervene, or “join,” your case. Generally speaking, the government is conservative in their case selection for intervention. They make the decision based heavily on how well researched the case is at the start, as well as the size, scope, and impact of the lawsuit. However, this only happens in a small minority of cases. It also significantly increases the chances a court will find in your favor. As a result, your percentage of the award is capped at 25%. If the government chooses not to intervene, you can be awarded as much as 30% of funds.

The lucrative nature of qui tam lawsuits means most attorneys take the cases based on outcome. Put another way? Your out of pocket expenses are likely to be less than other civil lawsuits.

Wondering If Your Case Qualifies?

Contact Bothwell Law Group at 770.643.1606 to find out more about what a qui tam lawsuit is and if your case qualifies.

Hospice Pays $3 Million in Fraud Claims Settlement

fraud claims settlement

fraud claims settlementIn a recent fraud claims settlement by Bothwell Law Group, Georgia area hospice center Guardian Hospice has reached a $3 million settlement. Together with their affiliated organizations, Guardian Home Care Holdings and AccentCare, Guardian Hospice was accused by a whistleblower of submitting false claims to Medicare and Medicaid.

The false claims submitted were for hospice patients in their care who were not terminally ill and they obtained government funds by providing this false information. Bothwell Law Group used the settling of this lawsuit to pursue justice for two former Guardian employees whose sealed case was filed in 2012. Although Guardian did not admit to being liable for the fraud, they still agreed to a $3 million settlement.

What can we learn from this fraud claims settlement?

Since the whistleblowers in this case filed their claim under the False Claims Act, Bothwell law was able to obtain a $510,000 reward for their actions. In addition to this, two of the whistleblowers believed Guardian wrongfully terminated them. As a result, Bothwell was able to negotiate an additional $50,000 for Rose Betts and $40,000 for Jennifer Williams to resolve the retaliation they claimed to have faced at the hands of their former employers.

In a statement to the media, Bothwell shared that their clients had grown accustom to watching their employer offer hospice care to non-terminal patients. In order to receive reimbursement for their care, the hospice center submitted false claims to Medicare and Medicaid, communicating that these patients were in the last six months of their lives.

In a statement concerning the case, Derrick Jackson, special agent who was placed in charge of the U.S. Department of Health and Human Services Office of the Inspector General, explained why this is such a gross misuse of funds.

“Hospice care is only medically appropriate—and reimbursed by Medicare—for terminally ill patients who are in the last months of their lives,” Jackson stated.

Mike Bothwell, and the entire team at Bothwell Law were honored to work closely with the honest and brave whistleblowers who brought the fraud to the attention of the United States government. Throughout the case if was very clear the U.S. government was not the only victim of the fraudulent actions.

Patients who do not meet criteria for hospice care, but are admitted anyway, miss out on the treatment a traditional hospital would provide, potentially missing a chance for their illness to be cured. Without the actions of the whistleblowers, who were wise when they selected a law firm that was experienced in whistleblower law and fraud claims settlement, this fraud might have continued to be committed in the future.

If you have reason to believe your employer may be committing Medicare or Medicaid fraud, call 770.643.1606 to learn more about filing a fraud claims settlement with our legal team Bothwell Law Group.

What does Qui Tam Mean?

what does qui tam mean

what does qui tam meanOne of the questions that Bothwell Law Group receives on a regular basis is “What does Qui Tam mean?” The answer is actually very simple. Qui Tam is a lawsuit against a person or company believed to have violated the law while under a contract with the government, or in violation of a government regulation. A qui tam lawsuit is brought forth by a private citizen. However, sometimes the federal government may intervene and become party to the suit.

Have you ever asked yourself, “What does Qui Tam mean?”

The term qui tam is Latin for “who as well.” As such, a qui tam lawsuit is brought “for the government as well as the plaintiff.” This means, the person who is bringing forth the lawsuit will be entitled to part of the recovery of the penalty.

Qui Tam lawsuits do not involve technical errors or technical violations. They deal with fraudulent and / or criminal acts against the government.

Someone who is filing a qui tam lawsuit is informally known as a “whistleblower.” Due to the potential loss of jobs whistleblowers face, the False Claims Act has protections in place to make sure whistleblowers have job protection for the personal and professional risks they are taking in order to expose and put a stop to fraud against the government.

Now that we’ve answered the question, “What does Qui Tam mean?”, what happens when a qui tam lawsuit is filed?

When a qui tam lawsuit is filed, it is “under seal.” This means it is kept a secret from everyone except the government. This is done to give the Justice Department time to investigate the allegations.

The government, along with the whistleblower’s attorney will begin investigating the case. The government decides to intervene in only a small percentage of qui tam cases. However, the chances of successfully pursuing a qui tam case are increased if the government does decide to join your case.

In a qui tam lawsuit, the government does have the right to request a partial lift of the seal to discuss allegations and a possible settlement with the individual or the entity accused of the fraud.

A majority of qui tam cases are resolved through settlements, meaning they don’t go to a court trial.

A qui tam lawsuit can result in anywhere between 15 to 30 percent of the recovery going to the whistleblower. If the government does not intervene in the case, the whistleblower gets a reward of 25 to 30 percent. If the government does decide to intervene in the qui tam case, the reward going to the whistleblower is lowered to 15 to 25 percent of the recovery.

Multi-million dollar rewards have been given to whistleblowers in recent years. With an experienced whistle-blower attorney, you could be on your way to successfully putting a stop to some of the fraud happening against the government.

The next time you hear someone ask, “What does Qui Tam mean?”, direct them to Bothwell Law Group for a free consultation to see if we can help.

Whistleblower Gets Over $30 Million

whistleblower awards

whistleblower awardsDid you know whistleblowers get between 10 and 30 percent of the amount the government collects from securities law violators?  Now more than ever, it can pay big to be a whistleblower.

Last year, a whistleblower was awarded more than $30 million for assistance and information that exposed and ended a massive securities fraud. The client was represented by Phillips & Cohen. To date, that is the largest SEC award ever made.

According to attorney Erika A. Kelton “The SEC acted quickly as a result of the information and assistance our client provided. The fraud was such that it’s unlikely that it ever would have been detected if our client hadn’t come forward.”

Recently, another whistleblower represented by Phillips & Cohen was awarded more than $3 million by the Securities and Exchange Commission (SEC).  The whistleblower provided assistance and information that led to a significant enforcement action.

This is the second largest award the SEC has made to a client of Phillips & Cohen in the past 10 months.

The whistleblowers in both cases chose to remain anonymous in order to protect their careers and their jobs. Confidentiality is highly important. The Dodd-Frank Act makes sure the SEC doesn’t disclose any information that would tie whistleblowers to particular actions taken against individuals or companies.

Dodd-Frank encourages everyday private citizens to report any wrongdoing to the SEC in exchange for anonymity, rewards and job protection.

If you need to report wrongdoing, contact a whistleblower attorney to find out your legal rights and help you through the process.


Game Changer for Whistleblowers

False Claims Act | SEC Whistleblower Claim

It looks like there has never been a better time to be a whistleblower. This is especially true for public companies or within the securities industry.

In 2010 the Securities & Exchange Commission’s (SEC) established a whistleblower awards program.  As a result, whistleblowers now have unprecedented financial incentives to disclose potential misconduct to the government.  Also, they are enjoying extraordinary legal protection for doing so.

Nowadays even compliance personnel, the employees tasked with identifying internal misconduct within a company, are receiving substantial payouts for reporting their own companies in some instances.

However, if you are the company being faced with a whistleblower, the situation has never been more difficult. The companies face several problems. One is the legal minefield when trying to deal with reports of misconduct. Another is the consequence of increased financial incentives for the whistleblowers to report actual or perceived misconduct. On top of it all, the companies are dealing with all this under an extremely tight reporting timeline.

Before Financial Incentives, Whistleblowers Were Scared To Speak Out

Before the awards program was established in 2010, whistleblowers had very little incentive to speak out.  Quite the opposite. They had incentive to stay quiet in order to avoid retaliation.

In 2002, the Sarbanes-Oxley Act of 2002 went into effect and whistleblowers were protected against retaliation. However, this provision was not only weak, it was often ineffective.

Paradigm Shift In 2010

The passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 changed everything for whistleblowers. This was the first time whistleblowers were offered a financial reward for whistleblowing relating to securities violations.

Million Dollar Settlements

Dodd-Frank directed the Commission to pay eligible individuals when the original information they provided lead to SEC and other enforcement actions to a monetary sanction over $1,000,000.  What does that mean for the whistleblower? With awards ranging from 10 to 30 percent of the total amount of money collected in a case, it means a lot!

Non-US Awards

The Commission determined that whistleblower awards need not be limited to those in the United States. Four of the 17 whistleblower awards to date were to whistleblowers living in foreign countries.

Penalties for Retaliation

Beyond the Sarbanes-Oxley Act of 2002, Dodd-Frank broadly prohibited retaliation against whistleblowers who report possible wrongdoing.

Thanks to the stringent protection and the financial incentives, 17 whistleblowers have received awards under Dodd-Frank, paying out nearly $50 million. The number of whistleblowers continues to rise.  The first quarter of 2015 saw a 20 percent increase in the number of whistleblower tips over the same quarter last year.

What companies subject to the SEC’s oversight should be concerned about:

  • The SEC has expressed intense interest in retaliation cases.
  • The SEC has recently granted awards to a company’s own compliance officers.
  • The SEC has voices a serious concern about the use of confidentiality agreements that may suppress SEC whistleblowers.


If you are a whistleblower or are considering being a whistleblower, contact a specialized whistleblower attorney as soon as possible.

Endangering Babies For Profit

Bottom line: Medicaid pays the same amount for a Midwife as for an Ob-Gyn. Thus, some hospitals have a financial incentive to push even the high-risk patients to use Midwives rather than doctors. Unfortunately, this is happening at considerable risk and sometimes serious damage to patients.

$100 Million Lawsuit Filed

$100 Million federal law suit was filed against Indiana University Health and 2 associated medical organizations, Healthnet and MDWise.  Allegations state “Contrary to their carefully crafted image of offering compassionate care for the indigent, two of the largest healthcare providers in Indianapolis put poor, pregnant women and their newborn babies at risk with a fraud scheme designed to increase revenues, regardless of the law or the risks to the most medically-fragile patients.”

A doctor at the hospital filed a complaint after what she saw there. Dr. Judy Robinson is the former medical director at the hospital. “I’m filing this lawsuit because of the abysmal care I witnessed these people receiving. And, after approaching IU Health, nobody would do anything.” Robinson pointed out that patients who should have received monitoring during their pregnancy didn’t receive the monitoring. “There was little to no physician involvement in the obstetrical care of these high-risk patients.”

Under the state Medicaid reimbursement rules, “Nurse midwives may not provide services to members with medically high-risk pregnancies. However, according to the lawsuit, lower-cost nurse midwives handled high-risk patients, in violation of the Medicaid regulations.

To make it worse, the hospital filed false-claims with the state and federal government for doctor services the patients never received. The hospitals are using midwives but getting reimbursed for using doctors.

Babies Permanently Damaged

According to Dr. Robinson, at least 3 babies suffered permanent neurological damage and 17 infants nearly missed a tragic outcome.

Watch the TV interview here. 

Thanks to whistleblowers like Dr. Judy Robinson, the lives of children may be dramatically changed for the better.

If you think you may have a whistleblower case, have a confidential talk with a whistleblower attorney as soon as possible. These are time-sensitive matters. A whistleblower attorney knows how to protect your rights and get results.

$9 Million Settlement Then Bankruptcy

United States Claims Global Computer Enterprises Utilized Non-Cleared Employees on Sensitive Projects

The United States, along with the Federal Bureau of Investigation (FBI), claims that Global Computer Enterprises (GCE) and its president, Raed Muslimani, knowingly put non-cleared employees on projects and software service contracts, a violation of the False Claims Act. As such, Muslimani and GCE have agreed to a settlement for $9 million.

What Happened?

According to representatives for the United States, Muslimani and GCE provided the US Department of Labor (DOL) and the Equal Employment Opportunity Commission (EEOC) with cloud software services for financial management. Later, GCE entered into software development contracts with the General Services Administration (GSA), the United States Secret Service, and the United States Coast Guard (USCG). According to the claims, Muslimani and GCE knowingly allowed engineers and other employees access to the files, even after they were specifically denied access to those files due to their immigration and citizenship statuses, overseas locations, and security clearance statuses.

Why Is This a Problem?

Many United States agencies regularly utilize information that is confidential for a purpose; the clearance levels assigned to such information prevent it from getting into the wrong hands and paving the way for terrorism and/or fraud. When the US Government hires companies to handle sensitive information, they expressly allow and/or deny certain individuals from handling this information due to its sensitivity. According to these civil claims, GCE, headed by Muslimani, allowed engineers and other employees access to sensitive information even though the contracts between the two specifically forbade it. As such, GCE’s actions indicate a breach of contract and an alleged violation of the civil False Claims Act.

What Is the Outcome?

GCE filed for Chapter 11 bankruptcy on Sept. 4, 2014. On Feb. 27 of this year, the United States filed a proof of claim to the Bankruptcy Court, which in turn approved the settlement (not a judgement) on Apr. 22. The FBI notes that there has been no determination of civil liability and the settlement is not an indication of such. The civil claims are allegations only. Government offices such as the FBI, the DOL, the EEOC, the USCG, and the Secret Service were all involved in the investigation of GCE and its president.

Although giving employees access to files during the software development process may not seem like a major offense, bear in mind that sensitive financial information is secret for a reason. If it falls into the wrong hands, the information could be used against the country as a whole.

If you are aware of a violation of the civil False Claims Act, contact a Whistleblower attorney as soon as possible.  Bothwell Law Group helps whistleblowers across the entire United States.

(Our firm did not represent parties listed in the article above).

Drug Company Cephalon Suffers Hefty Blows

Federal conspiracy claims and a Federal Trade Commission disgorgement action are a current problem for drugmaker Cephalon.

In April 2015, Cephalon failed to swat down a Federal Trade Commission disgorgement action and federal conspiracy claims. Although the story isn’t new news, the cases dating back to 2008 are still ongoing and new decisions were recently reached.

The FTC took issue with so-called “reverse-payment” settlements Cephalon struck with competing drug makers. Cephalon paid millions trying to stop the competing drug makers from introducing generic versions of their narcolepsy drug Povigil until the year 2012.

Even though U.S. District Judge Mitchell Goldberg found one Cephalon patent invalid in a related 2011 trial, the judge stayed the FTC action pending the U.S. Supreme Court’s guidance regarding reverse-payment settlement claims.

Cephalon is claiming the court should dismiss the FTC’s action since the generic of Provigil, modafinil, entered the market in 2012. Cephalon says injunctive relief is now moot and damages would be inappropriate. They also argue that consumers could obtain duplicative relief in private-plaintiff actions. To this, Goldberg responded “There is no way to predict the outcome of the private plaintiff’s antitrust lawsuits.”

U.S. District Judge Mitchell Goldberg kept the case going last year, saying Cephalon cannot stop the FTC from seeking disgorgement. He also stated “Moreover, the FTC explains that any award obtained pursuant to its proposed disgorgement remedy would be placed in a Consumer Relief Fund and would be used to satisfy any claims in the private plaintiff cases.”

Cephalon’s former employees accuse Cephalon of defrauding the U.S. government by submitting false claims for reimbursement for prescriptions of Provigil and its successor since 2007, Nuvigil, based on illegal off-label promotion. U.S. District Judge Thomas Goldstein is presiding over this False Claims Act complaint against Cephalon.

In 2008, Cephalon pleaded guilty to the misbranding through off-label promotion of Provigil, Actiq and Gabitril.

In April, 2015, Judge Goldstein tossed a few of the claims against Cephalon. However, he allowed many of the big-ticket allegations to advance. Goldstein also advanced the FCA conspiracy claims and claims under the New York False Claims Act based on conduct occurring before April 1, 2007.