Suzanne Jaffe Bloom

False Claims Act – Government Contracting, SBA, CARES Act (PPP, EIDL, etc.) – Representative Matters

• Representations of lenders in connection with government investigations related to CARES Act programs, including the Paycheck Protection Program and the Economic Injury Disaster Loan programs.
• Representations of borrowers in connection with investigations related to CARES Act programs, including the Paycheck Protection Program and the Economic Injury Disaster Loan programs.
• Provided compliance counseling for government contractor on issues related to the FCA, the Program Fraud Civil Remedies Act, the Federal Acquisition Regulations, the System for Award Management, the Central Contract Registration System, and the Small Business Act.
• Represented a Fortune 100 company in connection with parallel FCA investigations involving government contracts for technology and security equipment conducted on multiple fronts at once by federal and state authorities, including the Department of Justice, the U.S. Attorney’s Office for the Western District of New York, and the Office of the Attorney General for approximately 15 states and the District of Columbia. Secured declinations from the states, the District of Columbia, and the federal government on the merits and negotiated a favorable resolution that included dismissals of all of the claims in the pending qui tam.
• Represented an international client in the manufacturing industry in connection with a qui tam complaint filed in New York asserting violations of the New York state and city false claims acts with respect to product sales to state purchasers. Secured voluntary dismissal with prejudice of all of relator’s claims in the qui tam. 

False Claims Act – Health Care – Representative Matters

• Represented a multinational insurance company and certain affiliates in defense of a False Claims Act action based on alleged violations of the Medicare Secondary Payer Act, obtaining a pre-trial dismissal of the action with prejudice. Thereafter, successfully represented clients in connection with the appeal of the decision to the Second Circuit Court of Appeals, securing an affirmance of the lower court’s dismissal with prejudice. 
• Defended a Fortune 500 company in connection with confidential criminal and civil investigations by several U.S. Attorney’s Offices and State Attorney General’s Offices involving alleged violations of the Anti-Kickback Statute and the FCA and several related qui tam actions, preventing criminal charges against client and securing favorable resolutions of the various qui tam. 
• Represented a public company with global operations in connection with a confidential investigation of alleged violations of the FCA by the U.S. Attorney’s Office for the Southern District of New York. Secured a declination of intervention from the federal government and a favorable resolution with the qui tam. 
• Obtained a significant victory for a Fortune 500 company by securing a voluntary dismissal of qui tam claims brought under federal and state false claims acts based on allegations of health care fraud with respect to the purchase and sale of certain drugs. Secured dismissal of all claims against the company, without the company being required to make any settlement payments.
• Represented a Fortune 500 company in a qui tam action brought under federal and state false claims acts based on alleged unlawful kickback arrangements. Secured a declination of intervention from the relevant state and federal government authorities and a favorable resolution of the qui tam litigation.
• Represented a Fortune 500 company in connection with five qui tam actions consolidated in the District of Massachusetts, which were brought under federal and state false claims acts and involved wide-ranging allegations of health care fraud. Negotiated settlement agreements with the relevant federal and state government authorities and qui tam relators, securing a favorable disposition of all five matters for the company.
• Represented a rehabilitation therapy services provider servicing hundreds of facilities nationwide in connection with a government investigation by the DOJ and the US Attorney’s Offices for the Eastern and the Western Districts of Michigan and three related qui tam complaints asserting wide-ranging claims of FCA violations. Secured declinations from the government on the merits and negotiated a favorable resolution that included dismissals of all of the claims in the pending qui tam.

Financial Fraud, Theft, Embezzlement – Representative Matters

• Representations of companies in connection with State Attorney General investigations involving allegations of fraud and deceptive trade practices.
• Representation of international organization in connection with internal investigation of alleged fraud and theft and provided guidance related to proactive defense of allegations and related compliance measures.
• Represented a private company in connection with a confidential federal criminal investigation involving allegations of fraud, theft, and embezzlement, successfully preventing criminal charges against client.
• Represented individuals in connection with civil litigation involving claims of financial fraud and theft, obtaining dismissal of all claims.

Securities – Representative Matters

• Represented individuals in connection with confidential criminal investigations of allegations of insider trading and obstruction of justice, successfully avoiding charges against certain clients.
• Represented the board of directors of a public software company in connection with an internal investigation of the conduct and stock trading activities of the company’s CEO.
• Represented the audit committee of a Fortune 500 company with international operations in connection with an internal investigation of allegations of accounting and securities fraud.

FCPA – Representative Matters

• Represented an executive of a Fortune 100 company with worldwide operations in connection with a confidential DOJ investigation of alleged violations of the FCPA. No charges filed.
• Represented executive in financial services industry in connection with FCPA and related SEC investigation.
• Represented the Audit Committee of a Fortune 500 company in connection with the oversight of more than 40 internal investigations conducted worldwide, involving allegations of violations of the FCPA, money laundering, and accounting irregularities; the issuance of related financial restatements; and related SEC inquiries.

Medicare Secondary Payer Act – Representative Matters

• Represented insurance company affiliate of a multinational insurance company in two class actions in Southern District of Florida asserting claims for alleged violations of the Medicare Secondary Payer Act and subrogation based on purported assignments from Medicare Advantage Organizations and other related entities. Following arguments for dismissal, plaintiffs voluntarily dismissed both actions against client.
• Represented insurance company affiliates of a multinational insurance company in a class action in the Southern District of New York asserting claims for alleged violations of the Medicare Secondary Payer Act and subrogation based on purported assignments from Medicare Advantage Organizations. Secured a pre-trial dismissal of all pending claims against client.
• Represented a multinational insurance company and certain affiliates in defense of a False Claims Act action based on alleged violations of the Medicare Secondary Payer Act, obtaining a pre-trial dismissal of the action with prejudice. Thereafter, successfully represented clients in connection with the appeal of the decision to the Second Circuit Court of Appeals, securing an affirmance of the lower court’s dismissal with prejudice.

Official Corruption – Representative Matters

• Represented private equity firms in connection with a nationwide investigation by the SEC and State Attorney General’s Offices of allegations of official corruption related to public pension funds, successfully avoiding charges against clients.
• Represented a managing director of a financial institution in connection with an internal investigation of allegations regarding official corruption, securing favorable resolution.

Additional Areas – Representative Matters

• Sex Assault/Trafficking – Representations of clients in connection with federal government investigations of sex trafficking allegations.
• Tax – Represented an international financial institution in connection with a federal grand jury investigation and related civil litigations involving allegations of violations of civil and criminal tax laws, securing favorable resolutions.
• Tax; Organizational Governance; Compliance Counseling – Represented the executive committee of a large professional services firm in connection with its internal investigation of allegations of wrongdoing and the development and implementation of a remediation and compliance program.
• Corporate Governance; Investor Litigation – Represented an investor in a biotechnology company in connection with civil litigation involving organizational governance issues, securing favorable resolution.
• Compliance Counseling – Counseled the Audit Committee of a Fortune 500 company in connection with the development and implementation of worldwide compliance and remediation plans concerning, among other things, compliance with the FCPA, related anti-bribery laws, and anti-money laundering laws, following worldwide internal investigations.
• Insurance; Compliance Monitoring – Represented state regulator in connection with the examination and compliance monitoring of several insurance brokerage companies in the wake of a multistate investigation of alleged wrongdoing and the resulting settlement agreements.

U.S. Attorney’s Office for the S.D.N.Y. – Representative Matters

• Led joint criminal and civil investigations involving alleged government program fraud and violations of the federal False Claims Act and related statutes.
• Led investigation and successful prosecution of 15 present and former police officers and detectives with the New York City Police Department on various federal tax charges, including tax evasion and conspiracy to defraud the United States.
• Responsible for the successful prosecution of corrupt construction contractors and attorneys on charges of bribery relating to construction contracts with the New York City Board of Education and the School Construction Authority.
• Led an investigation of corruption within the International Ladies Garment Workers Union and the Ladies Apparel Contractors Association, resulting in the conviction of several labor union officials and garment contractors on labor racketeering charges, including conspiracy and bribery.
• Responsible for the successful prosecution of a DEA Special Agent and other DEA employees on charges relating to public corruption and narcotics conspiracies.
• Led an investigation of corruption at the New York Office of the U.S. Immigration & Naturalization Services (INS), resulting in arrests and convictions of INS employees and brokers on various charges, including conspiracy, bribery, trafficking in fraudulently obtained INS documents, and establishing a commercial enterprise to evade the immigration laws.

U.S. Attorney’s Office for the E.D.N.Y. – Representative Matters

• Led joint criminal and civil investigations involving alleged government program fraud and violations of the federal False Claims Act and related statutes.
• Led an investigation of corruption at the Village of Hempstead Housing Authority (HHA) resulting in conviction of a former HHA supervisor, the former Director of Public Relations at the Economic Opportunity Commission of Nassau County, and a local contractor on extortion, bribery, and tax charges.
• Led an investigation and prosecution of 53 individuals charged in connection with fraudulent securities offerings attempting to raise more than $48 million nationwide, resulting in convictions on various counts of securities fraud and related charges.
• Led several individual and corporate investigations and successful prosecutions involving conspiracies to defraud the United States and violations of the federal tax laws.
• Led an investigation and successful prosecution of individuals involved in money laundering and fraud on behalf of owners and investors of medical imaging companies.
• Led a joint federal and state investigation of a nationwide fraud perpetrated by the principals of several loan brokerages and funding companies operating out of New York, resulting in convictions of principals on several counts of conspiracy and mail fraud.