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US Wins FCA Judgment Against California Rehab Center over Improper PPP Loan

The United States District Court for the Central District of California granted summary judgment to the United States against JMG Investments Inc., a California corporation which runs a rehabilitation center, and its owner, Jeffrey Schwartz, on Jan. 15, finding that they violated the False Claims Act when they knowingly received and retained more than one Paycheck Protection Program (PPP) loan prior to Dec. 31, 2020, in violation of PPP rules. The District Court ordered Schwartz and his company to pay the United States a total of $1,565,294.38 in damages and penalties. In August 2024, the United States filed a complaint against JMG Investments and Schwartz alleging that they violated the False Claims Act when Schwartz, on behalf of JMG Investments Inc., improperly received two PPP loans in 2020 in violation of PPP rules, and thereafter knowingly and improperly retained the proceeds of the duplicate loan. According to the government’s complaint, Schwartz and JMG Investments Inc. failed to repay the duplicate loan as they were required, which resulted in a loss to the SBA when it purchased the loan guaranty on the duplicate loan. The District Court ruled that the United States had shown it was entitled to judgment on all claims asserted against the Defendants and, accordingly, awarded the United States summary judgment.