IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

_____________________________________ 

UNITED STATES OF AMERICA ex rel.

SIDESOLVE, LLC, 

 Plaintiffs, 

v. 

EMPIRE ROOFING, INC.; EMPIRE ROOFING 

COMPANIES, INC.; EMPIRE ROOFING OF 

OKLAHOMA, INC.; EMPIRE ROOFING AND 

SHEET METAL, INC.; SR DISPOSAL, LTD 

f/k/a EMPIRE DISPOSAL, LTD; EMPIRE 

ROOFING COMPANY SOUTHEAST, LLC; 

EMPIRE ROOFING COMPANY OF GEORGIA, 

LLC; RONNIE MCGLOTHLIN; SANDRA 

SEDILLO-MCGLOTHLIN; AND TECTA 

AMERICA CORP., 

 Defendants.

Civil Case No. 3:22-CV-2060-B 

JOINT STIPULATION OF VOLUNTARY DISMISSAL 

BY THE UNITED STATES AND RELATOR 

On November 30, 2023, the United States of America filed its Notice of Partial 

Intervention for Purpose of Settlement, and intervened in this action as to certain claims 

asserted on behalf of the United States against Defendants Empire Roofing, Inc., Empire 

Roofing Companies, Inc., Empire Roofing Company Southeast, LLC, Empire Roofing 

Company of Georgia, Inc., Empire Roofing of Oklahoma, Inc., Empire Roofing and 

Sheet Metal, Inc., SR Disposal, Ltd. (f/k/a Empire Disposal, Ltd.), Ronnie McGlothlin, 

Sandra Sedillo McGlothlin, and Tecta America Corp (Defendants). 

Case 3:22-cv-02060-B Document 26 Filed 12/06/23 Page 1 of 4 PageID 94
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Pursuant to the Settlement Agreement executed by and amongst the United States, 

Defendants, and Relator Sidesolve, LLC (Relator) on November 30, 2023, the United 

States and Relator by and through their respective attorneys, hereby jointly stipulate and 

agree, pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii) and the qui tam

provisions of the False Claims Act, 31 U.S.C. § 3730(b)(1), to an entry of an order: (1) as 

to the United States, dismissing with prejudice any claims asserted against Defendants 

that are included within the Covered Conduct as defined in the Settlement Agreement, 

and otherwise dismissing without prejudice to the United States any other claims asserted 

within this action; (2) as to the Relator, dismissing with prejudice any claims asserted in 

this action against Defendants; and (3) providing that the Court retain jurisdiction over 

any disputes that may arise regarding the Settlement Agreement referenced herein. 

Relator stipulates and agrees that the Settlement Agreement referenced herein and 

the terms and conditions described therein are fair, adequate, and reasonable under all the 

circumstances in this case, that Relator will not challenge the settlement pursuant to 31 

U.S.C. § 3730(c)(2)(B), and that Relator expressly waives the opportunity for a hearing 

on any objection to the settlement under 31 U.S.C. § 3730(c)(2)(B). 

A proposed order accompanies this joint stipulation. 

Case 3:22-cv-02060-B Document 26 Filed 12/06/23 Page 2 of 4 PageID 95
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Respectfully submitted, 

LEIGHA SIMONTON

UNITED STATES ATTORNEY 

 

/s/ William C. Admussen 

William C. Admussen 

Illinois Bar No. 6335479 

Andrew S. Robbins 

New York Bar No. 4836508 

Assistant United States Attorneys

1100 Commerce Street, Third Floor 

Dallas, Texas 75242-1699 

Telephone: 214-659-8600 

Facsimile: 214-659-8807 

william.admussen@usdoj.gov 

andrew.robbins@usdoj.gov 

Attorneys for the United States of 

America 

/s/ Jason Marcus 

Jason Marcus 

Georgia Bar No. 949698 

Bracker & Marcus LLC 

3355 Lenox Road, Suite 660 

Atlanta, Georgia 30326 

Telephone: (770) 988-5035 

Facsimile: (678) 648-5544 

Jason@fcacounsel.com 

Attorney for Relator Sidesolve, LLC

Case 3:22-cv-02060-B Document 26 Filed 12/06/23 Page 3 of 4 PageID 96
CERTIFICATE OF SERVICE 

On December 6, 2023, I electronically submitted the foregoing document with the 

clerk of court for the U.S. District Court, Northern District of Texas, using the electronic 

case filing system of the court. I hereby certify that I have served all parties 

electronically or by another manner authorized by Federal Rule of Civil Procedure 

5(b)(2). 

/s/ William C. Admussen 

 WILLIAM C. ADMUSSEN 

 Assistant United States Attorney 

Case 3:22-cv-02060-B Document 26 Filed 12/06/23 Page 4 of 4 PageID 97