1 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Case No. 20-CV-23242-BLOOM/Louis 

UNITED STATES OF AMERICA ex rel.

SEDONA PARTNERS LLC, 

 Plaintiff, 

 vs. 

ABLE MOVING & STORAGE, INC.; 

ARPAN VAN LINES, INC.; 

CARTWRIGHT INTERNATIONAL VAN LINES, INC.; 

COLEMAN AMERICAN MOVING SERVICES, INC.; 

DEWITT COMPANIES LIMITED, LLC; 

HILLDRUP COMPANIES, INC.; 

J.K. MOVING & STORAGE INC.; 

MAYFLOWER TRANSIT, LLC; 

NEW WORLD VAN LINES, INC.; 

PARAMOUNT TRANSPORTATION SYSTEMS; 

PAXTON VAN LINES, INC.; AND 

WESTERN EXPRESS FORWARDING, LLC, 

 Defendants. 

DEFENDANT DEWITT COMPANIES LIMITED LLC’S MOTION TO DISMISS 

FIRST AMENDED COMPLAINT AND INCORPORATED MEMORANDUM OF LAW 

Defendant DeWitt Companies Limited, LLC (“DeWitt”) respectfully requests this Court 

dismiss Relator Sedona Partners LLC’s (“Relator” or “Sedona Partners”) First Amended 

Complaint for Money Damages and Civil Penalties for Violations of the False Claims Act (Dkt. 

No. 1) (the “Complaint”) with prejudice, pursuant to Federal Rules of Civil Procedure 8, 9(b), and 

12(b)(6). 

The Complaint fails to set forth causes of action against DeWitt. 

 There are no allegations that DeWitt improperly used a foreign vessel to ship goods 

internationally. 

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 There are no allegations that DeWitt submitted a false claim to the United States. 

 There are no allegations that DeWitt submitted a false certification attesting to the 

unavailability of a U.S. flag vessel. 

 There are no allegations of changes in DeWitt’s conduct that might suggest previous 

improper conduct. 

 There are no allegations of communications by DeWitt that might evidence the scheme 

Relator thinks may have occurred. 

There are no allegations showing that the United States suffered any harm caused by 

DeWitt’s conduct. 

 And there are no allegations indicating that Relator has non-public knowledge of DeWitt’s

practices. 

 Given Relator’s complete failure to establish a cause of action against DeWitt, and the 

apparent lack of due diligence done by Relator before filing this lawsuit against DeWitt, the 

Complaint against DeWitt should be dismissed with prejudice. 

STATEMENT OF FACTS1

The Complaint states that DeWitt is a private shipping company that provides domestic 

and international relocation services to the United States Department of State (“DOS”) and United 

States General Services Administration (“GSA”). (Compl. ¶ 18). DeWitt is an approved 

Transportation Service Provider (“TSP”) available through the Centralized Household Goods 

Traffic Management Program (“CHAMP”). (Id.). On July 24, 2019—several months after the 

government’s crackdown on any supposed scheme—the United States provided DeWitt with a 

Justification Certificate for Use of Foreign Flag Waiver. (Compl. ¶ 41). According to search 

1

 At this stage, DeWitt must assume all factual allegations in the Complaint. 

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results in a public database, DeWitt submitted to the United States a bid of $5,498.90 for the 

Washington D.C. to London surface or ocean-going portion of the lane, a rate which Relators 

believe was below market and would have lost DeWitt $1,701.10. (Compl. ¶ 53). 

 That is the extent to the allegations against DeWitt. Three references. 

 The remainder of the Complaint broadly alleges a scheme to acquire government shipping 

contracts at lower prices than the competition. TSPs that participate in CHAMP bid to acquire 

shipping routes, also known as lanes, from the GSA. (Id. ¶¶ 33–37). The TSPs selected for lanes 

must give preference to privately owned U.S. Flag vessels for their routes, but can request 

permission to use a foreign flag vessel if it certifies that “US flag shipping is not available or . . . 

the use of the foreign flag shipping is necessary to meet delivery requirements.” (Id. ¶ 38). These 

foreign flag vessels are, according to Relator, cheaper than their US counterparts. (Id. ¶ 39). 

Relator alleges that the Defendants—nominally including DeWitt—submitted “artificially low 

bids” to acquire the lanes and then knowingly “falsely certif[ied] that no U.S. flag vessel can 

complete the shipment” in order to a waiver to use a foreign flag vessel. (Id. ¶¶ 47–48). 

 That is the extent to the allegations regarding any “scheme.” 

ARGUMENT 

 Relator alleges two causes of action against DeWitt. First, Relator alleges DeWitt 

presented false claims for payment in violation of the False Claims Act (“FCA”), 31 U.S.C. § 

3729(a)(1)(A) (the “FCA presentment claim”). Second, Relator alleges DeWitt used/made false 

statements or records material to false or fraudulent claims in violation of the FCA, 31 U.S.C. § 

3729(a)(1)(B) (the “FCA use claim”). 

Both fail for several reasons. First, Relator does not plead its claims with sufficient 

particularity to pass Federal Rule of Procedure 9(b). Second, Relator does not state sufficient facts 

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to state a claim against DeWitt. Third, Relator is not an original source of information for claims 

against DeWitt.2

I. The Complaint does not state its claims against DeWitt with sufficient particularity. 

FCA complaints must meet the heightened pleading standard for fraud under Federal Rule 

of Civil Procedure 9(b). U.S. ex rel. Clausen v. Lab’y Corp. of Am., Inc., 290 F.3d 1301, 1309 

(11th Cir. 2002). Under Rule 9(b), a party alleging fraud “must state with particularity the 

circumstances constituting fraud.” “The key inquiry is whether the complaint includes ‘some 

indicia of reliability’ to support the allegation that an actual false claim was submitted.” U.S. v. 

HPC Healthcare, Inc., 723 Fed. Appx. 783, 789 (11th Cir. 2018) (quoting and citing Clausen, 290 

F.3d at 1311). To satisfy Rule 9(b) in a FCA case, a complaint must “set[] forth facts as to time, 

place, and substance of the defendant’s alleged fraud, specifically the details of the defendants’ 

allegedly fraudulent acts, when they occurred, and who engaged in them.” Hopper v. Solvay 

Pharm., Inc., 588 F.3d 1318, 1324 (11th Cir. 2009). 

The Complaint lacks any “indicia of reliability” for claims of fraud by DeWitt. 

First, the Complaint fails to set forth any facts that would indicate that DeWitt engaged in 

improper conduct. The Complaint only references DeWitt three times, none of which set forth the 

details of allegedly fraudulent acts. General, conclusory references to the conduct of 12 separate 

companies collectively defined as “Defendants” are not sufficient. 

Second, the Complaint fails to allege an example of a false claim that DeWitt presented to 

or submitted to the government or any false statement made by DeWitt. The Eleventh Circuit has 

repeatedly held that a FCA complaint cannot simply “portray[] the scheme and then summarily 

2

 In Cartwright International Van Lines, Inc.’s Motion to Dismiss, it argues that Relator’s claims also fail 

because it is a dissolved corporation, unable to bring any claims. (Dkt. No. 80 at 18–19). DeWitt 

wholeheartedly endorses and affirms this argument and urges the Court to dismiss Relator’s claims on that 

basis as well. 

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conclude[] that the defendants submitted false claims to the government.” U.S. ex rel. Atkins v. 

Mcinteer, 470 F.3d 1350, 1359 (11th Cir. 2006); see also HPC Healthcare, Inc., 723 Fed. Appx. 

at 790 (holding that although the complaint “detail[ed] a scheme, [the] complaint [did] not include 

specific examples of the conduct [the plaintiff] describe[d] or allege[d] the submission of any 

specific fraudulent claim”); U.S. ex rel. Seal 1 v. Lockheed Martin Corp., 429 Fed. Appx. 818, 

820–21 (11th Cir. 2011) (dismissing a complaint that did not allege “the amount of the claims, the 

number of claims presented,” “dates on when such claims were made,” “the terms of payment,” 

“what, if any, representations were made by [defendant] at the time it sought payment,” nor “how 

those representations were false or fraudulent.”) Such is the case here. Relator details a scheme 

but fails to provide any examples of DeWitt submitting fraudulent claims under the scheme. At 

one point, Relators attempt to ground their allegations by creating a chart of how certain rates 

“skyrocketed” when the DOS began to “crackdown” on the scheme. (Compl. ¶ 79). This chart—

a lynchpin to Relator’s allegations of fraud if one disregards the possibility of other factors for rate 

changes between 2016 and 2019—does not even mention DeWitt. 

This is a textbook failure to meet Rule 9(b)’s exacting standards, and Relator’s Complaint 

against DeWitt should be dismissed as a result. 

II. The Complaint fails to state a claim upon which relief can be granted under the FCA. 

To survive a motion to dismiss for failure to state a claim, the Complaint must “‘state a 

claim to relief that is plausible on its face,’ meaning it must contain ‘factual content that allows 

the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” 

Bishop v. Ross Earle & Bonan, P.A., 817 F.3d 1268, 1270 (11th Cir. 2016) (quoting Ashcroft v. 

Iqbal, 556 U.S. 662, 678 (2009)). Relator fails to allege sufficient facts to infer that DeWitt is 

liable under either count. 

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A. The Complaint does not sufficiently allege the elements of a FCA presentment 

claim. 

To establish a FCA presentment claim, Relator must allege that DeWitt presented a claim 

for payment that was “(1) a false or fraudulent claim; (2) which was presented, or caused to be 

presented, by the defendant to the United States for payment or approval; (3) with the knowledge 

that the claim was false.” U.S. v. Space Coast Med. Assocs., L.L.P., 94 F.Supp.3d 1250, 1256 

(M.D. Fla. 2015) (quotation and citation omitted). Relator fails to plead sufficient facts at each 

step. 

First, Relator, as discussed above, fails to identify any false or fraudulent claims submitted 

by DeWitt. They assume that DeWitt would have lost money on one transaction, but they allege 

no fraudulent or false claims regarding this transaction. They also provide one of DeWitt’s waivers 

by way of example, but that is also not a false claim. That waiver request occurred after the 

government began a supposed crackdown on fraudulent waiver requests. To believe Relator’s 

story, all the fraudulent actors had to stop its scheme after the government crackdown. Therefore, 

any waiver submitted after it—like the DeWitt example—would not be fraudulent. The Complaint 

does not identify any waiver requests or bids by DeWitt that are allegedly false or fraudulent. 

Second, because Relator does not allege any false or fraudulent claims by DeWitt, it does 

not allege any false or fraudulent claims were actually presented to the United States. 

Third, the Complaint fails to allege that DeWitt acted knowingly. There are no factual 

allegations that DeWitt knowingly submitted a below-market rate while intending to engage in 

improper conduct. See U.S. ex rel. McFarland v. Florida Pharm. Sols., 358 F.Supp.3d 1316, 1329 

(M.D. Fla. 2017) (holding an FCA complaint failed to allege sufficient facts to establish scienter).

The Complaint sets forth some factual allegations that might suggest this regarding other 

defendants, but no such allegations about DeWitt. 

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Fourth, the Complaint fails to allege that the United States suffered any damages caused 

by DeWitt. Even assuming that there are sufficient allegations about DeWitt’s conduct and state 

of mind in the Complaint, the United States actually would have paid less than it would have 

otherwise and would not have suffered any financial loss. The only entities that may have suffered 

any harm from the allegations in the Complaint are other companies that Relator believes should 

have won the business (see Compl. ¶ 49 referring to “tax payer money that should have gone to 

U.S. flag vessel carriers”), but Relator cannot sue on behalf of those companies here. Moreover, 

if Relator is simply seeking a fine for each false claim, Relator’s failure to allege any false claims 

by DeWitt establishes no basis for an FCA fine. Even if the conduct alleged by Relator actually 

happened, and even if the conduct was improper, there is no basis for this to be litigated under the 

False Claims Act. 

B. The Complaint does not sufficiently allege the elements of a FCA use claim. 

To establish a FCA use claim, the Relator must allege that “(1) the defendant made (or 

caused to be made) a false statement, (2) the defendant knew it to be false, and (3) the statement 

was material to a false claim.” U.S. ex rel. Phalp v. Lincare Hldgs., Inc., 857 F.3d 1148, 1154 

(11th Cir. 2017). Again, Relator presents no facts to sufficiently plead this claim as to DeWitt. 

First, Relator fails to allege any allegations of false statements made by DeWitt. It lumps 

DeWitt into general allegations of the scheme but cannot identify even one false statement. Relator 

includes a DeWitt waiver request, but only by way of example and without allegations of falsity. 

Second, as discussed in the preceding section, the Complaint fails to allege any facts 

regarding scienter. 

Third, Relator fails to make allegations regarding the materiality of DeWitt’s uncited false 

statements. If a relator cannot show that failing to comply with a statutory/regulatory requirement 

is material to the government’s decision to pay, their complaint cannot survive a motion to dismiss. 

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See U.S. v. Norman, No. 8:15–cv–1506–T–23AEP, 2018 WL 264253, at *2 (M.D. Fla. Jan. 2, 

2018) (“Escobar holds that liability under the False Claims Act requires proof that the United 

States would deny reimbursement if the United States were to uncover the defendant’s violation 

of a ‘particular statutory, regulatory, or contractual requirement.’ . . . In this action, the relator 

alleges no facts to show or permit an inference that the United States routinely refuses to reimburse 

a defendant for radiation therapy not supervised by a physician.”) (quoting and citing Universal 

Health Servs., Inc. v. U.S. ex rel. Escobar, 136 S. Ct. 1989, 2003 (2016)). “The FCA is not a wideranging tool to combat failures to comply with even important government regulations.” Ruckh v. 

Salus Rehab., LLC, 963 F.3d 1089, 1109 (11th Cir. 2020). Relator provides no facts to show the 

United States routinely rejected low-bids or waiver requests such as ones supposedly submitted by 

DeWitt. In fact, Relator alleges the opposite and states the United States routinely granted waiver 

requests. Therefore, Relator presents no facts to permit an inference that any false statements 

made by DeWitt were material to any false claims. 

III. The public disclosure bar prohibits Relator’s claims against DeWitt. 

 FCA’s public disclosure bar prevents qui tam lawsuits based solely on publicly disclosed 

information. Whether the bar applies depends on a three part test:3 “(1) have the allegations made 

by the plaintiff been publicly disclosed;” (2) are the allegations made by the plaintiff “substantially 

the same” as the allegations contained in the public disclosures; and (3) “if yes, is the plaintiff an 

‘original source’ of that information.” U.S. ex rel. Osheroff v. Humana Inc., 776 F.3d 805, 812 

(11th Cir. 2015) (quoting and citing Cooper v. Blue Cross Blue Shield of Florida, Inc., 19 F.3d 

562, 565 n. 4 (11th Cir.1994)). 

3

 The Complaint alleges DeWitt began providing relocation services to the GSA and Department of State 

in 2012. As this is after the 2010 amendments to the public disclosure bar, only the post-amendment 

standard will be considered. 

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The only non-public information contained in the Complaint has nothing to do with 

DeWitt. Relator cites to and describes communications among “top executives” in 2019. (Compl. 

¶ 84). But these executives are not associated with DeWitt. 

Regarding DeWitt, Relator has made no allegations indicating personal knowledge of any 

improper conduct by DeWitt or establishing information about DeWitt of which the government 

was not already aware. All that Relator appears to have done regarding DeWitt is check a 

government database for rates that looked low to the Relator. (See Compl. ¶ 53). Moreover, 

Relator’s own allegations shows that multiple people were raising concerns to the government 

about the allegedly improper conduct in 2018, possibly even before Relator did. (See Compl. ¶ 73 

(“In 2018, Relator and others began raising concerns about the fraudulent practices” (emphasis 

added)). 

To the extent Relator has any non-public information, it is not about DeWitt. Therefore, 

the public disclosure bar prevents Relator’s claims as to DeWitt. 

CONCLUSION 

 Whatever merits the Complaint may have against other defendants who actually are 

mentioned more than three times, the Complaint clearly fails with regards to DeWitt. Relator 

appears to have conducted a woefully inadequate investigation of DeWitt before lumping it into 

this action in the hopes of getting a share of a bigger settlement if the government had intervened. 

Accordingly, the Complaint against DeWitt should be dismissed with prejudice. 

Dated: August 24, 2021 Respectfully submitted, 

/s/ Matthew J. Langley 

Matthew J. Langley (FL #097331) 

Stephen Chahn Lee (admitted pro hac vice) 

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BENESCH, FRIEDLANDER, COPLAN & 

ARONOFF LLP 

71 South Wacker Drive, Suite 1600 

Chicago, IL 60606-4637 

Telephone: 312-212-4949 

Facsimile: 312-767-9192 

Email: mlangley@beneschlaw.com 

 slee@beneschlaw.com 

Michael B. Silverstein (admitted pro hac vice) 

BENESCH, FRIEDLANDER, COPLAN & 

ARONOFF LLP 

41 South High St., Suite 2600 

Columbus, OH 43215-6164 

Telephone: 614-223-9300 

Facsimile: 614-223-9330 

Email: msilverstein@beneschlaw.com 

 

Attorneys for Dewitt Companies Limited, LLC

 

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CERTIFICATE OF SERVICE 

 The undersigned attorney hereby certifies that the foregoing DEFENDANT DEWITT 

COMPANIES LIMITED LLC’S MOTION TO DISMISS FIRST AMENDED COMPLAINT AND 

INCORPORATED MEMORANDUM OF LAW was filed electronically on this 24th day of August, 

2021, with the Clerk of Court using the ECF system, which will send notifications of such to all 

counsel of record. 

 

 /s/ Matthew J. Langley 

 Matthew J. Langley 

 

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SERVICE LIST

James A. Weinkle 

Assistant United States Attorney 

Office of the United States Attorney 

Southern District of Florida 

99 N.E. 4th Street, Suite 300 

Miami, Florida 33132 

James.Weinkle@usdoj.gov 

Counsel for United States of America 

Ryon M. McCabe 

McCabe Rabin, P.A. 

1601 Forum Place, Suite 201 

West Palm Beach, FL 33401 

rmccabe@mccaberabin.com

Counsel for Sedona Partners LLC 

Justin T. Berger 

Cotchett, Pitre & McCarthy 

2716 Ocean Park Blvd., Suite 3088 

Santa Monica, CA 90405 

jberger@cpmlegal.com 

Counsel for Sedona Partners LLC 

Paul E. Pelletier 

Law Offices of Paul E. Pelletier 

3500 Morningside Drive 

Fairfax, VA 22031 

pepelletier3@gmail.com 

Counsel for Sedona Partners LLC 

Sarvenaz J. Fahimi 

Cotchett, Pitre & McCarthy 

840 Malcolm Road, Suite 200 

Burlingame, CA 94010 

sfahimi@cpmlegal.com 

Counsel for Sedona Partners LLC 

Irene Oria 

FisherBroyles, LLP 

199 E. Flagler St., #550 

Miami, FL 33131 

irene.oria@fisherbroyles.com 

Counsel for Able Moving & Storage Inc.

Noam B. Fischman 

Polsinelli PC 

1401 I St., NW, Suite 800 

Washington, DC 20005 

nfischman@polsinelli.com 

Counsel for Cartwright International Van 

Lines Inc.

Ghislaine Torres Bruner 

Polsinelli PC 

1401 Lawrence St., #2300 

Denver, CO 80202 

gbruner@polsinelli.com 

Counsel for Cartwright International Van 

Lines Inc.

Thomas C. Hill 

Alexis N. Wansac 

Pillsbury Winthrop Shaw Pittman LLP 

1200 Seventeenth Street NW 

Washington, DC 20036 

thomas.hill@pillsburylaw.com 

alexis.wansac@pillsburylaw.com 

Counsel for Coleman American Moving 

Services Inc.

Ariella Josefsberg Ederi 

Aryeh Lev Kaplan 

Pillsbury Winthrop Shaw Pittman LLP 

600 Brickell Avenue, Suite 3100 

Miami, FL 33131 

ariella.ederi@pillsburylaw.com 

aryeh.kaplan@pillsburylaw.com 

Counsel for Coleman American Moving 

Services Inc.

Gregory Alan Hearing 

GrayRobinson, P.A. 

401 E. Jackson Street, Suite 2700 

Tampa, FL 33602 

gregory.hearing@gray-robinson.com 

Counsel for Coleman American Moving 

Services Inc.

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Robert Thomas Wright, Jr. 

Stroock Stroock & Lavan 

200 S Biscayne Boulevard 

Suite 3100 Wachovia Financial Ctr 

Miami, FL 33131 

RWright@stroock.com 

Counsel for Able Moving & Storage Inc.

C. Quinn Adams 

Alan D. Albert 

Charles G. Meyer, III 

Charles M. Sims 

O’Hagen Meyer 

411 East Franklin Street, Suite 500 

Richmond, VA 23219 

CAdams@ohaganmeyer.com 

AAlbert@ohaganmeyer.com 

CMeyer@ohaganmeyer.com 

CSims@ohaganmeyer.com 

Counsel for J.K. Moving & Storage Inc. 

Michael Isaac Kessler 

O'Hagan Meyer 

21550 Oxnard Street, Suite 1050 

Woodland Hills, CA 91367 

mkessler@ohaganmeyer.com 

Counsel for J.K. Moving & Storage Inc.

Robert Mark Borak 

Spector Rubin, P.A. 

3250 Mary Street, Suite 405 

Miami, FL 33133 

robert.borak@spectorrubin.com 

Counsel for Paramount Transportation 

Systems 

Craig Bennett Shapiro 

Buchbinder & Elegant, P.A. 

46 S.W. 1 Street, 4th Floor 

Miami, FL 33130 

cshapiro@belaw.cc 

Counsel for Western Express Forwarding 

LLC

Justin Canner Sorel 

Cole Scott & Kissane 

1645 Palm Beach Lakes Boulevard, 2nd Floor 

West Palm Beach, FL 33401 

justin.sorel@csklegal.com 

Counsel for Hilldrup Companies Inc.

Barry Adam Postman 

Cole Scott & Kissane 

222 Lakeview Avenue, Suite 120 

West Palm Beach, FL 33417 

barry.postman@csklegal.com 

Counsel for Hilldrup Companies Inc.

Kristin D. Kiehn 

Maura K. Monaghan 

Melanie M. Burke 

Debevoise & Plimpton LLP 

919 Third Ave 

New York, NY 10022 

kdkiehn@debevoise.com 

mkmonaghan@debevoise.com 

mburke@debevoise.com 

Counsel for Hilldrup Companies Inc.

Andrew Michael Gordon 

Hinshaw & Culbertson LLP 

1 East Broward Blvd., Suite 1010 

Fort Lauderdale, FL 33301 

agordon@hinshawlaw.com 

Counsel for New World Van Lines Inc.

Brian R. Zeeck 

Hinshaw & Culbertson LLP 

151 North Franklin Street, Suite 2500 

Chicago, IL 60606 

bzeeck@hinshawlaw.com 

Counsel for New World Van Lines Inc.

Thomas F. Murphy 

Friedlander Misler, PLLC 

5335 Wisonsin Avenue, NW, Suite 600 

Washington, DC 20015 

tmurphy@dclawfirm.com 

Counsel for Western Express Forwarding 

LLC

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Stuart A. Berman 

Lerch, Early & Brewer, Chtd. 

7600 Wisconsin Avenue, Suite 700 

Bethesda, MD 20814 

saberman@lerchearly.com 

Counsel for Paxton Van Lines Inc. 

Robert Harris 

Sammy Epelbaum 

Stack Fernandez & Harris, P.A. 

1001 Brickell Bay Drive, Suite 2650 

Miami, FL 33131 

rharris@stackfernandez.com 

sepelbaum@stackfernandez.com 

Counsel for Paxton Van Lines Inc. 

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