UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA, )
ex rel. LOUIS SCUTELLARO )
)
Plaintiff, )
v. ) Civ. No. 10cv0113 (JDB)
)
DIRECT RESOURCES, INC. ) UNDER SEAL
)
Defendant. )
____________________________________)
APPLICATION FOR DISMISSAL WITH PREJUDICE TO RELATOR
AND WITH PREJUDICE TO UNITED STATES ON CERTAIN CLAIMS
AND OTHERWISE WITHOUT PREJUDICE TO UNITED STATES
AND TO LIFT THE SEAL
Under Fed. R. Civ. P. 41(a)(1)-(2), the United States and Plaintiff-Relator Louis
Scutellaro hereby jointly move for dismissal of the above-captioned action against Defendant
Direct Resource, Inc. (incorrectly named Direct Resources, Inc. in Relator’s Complaint) pursuant
to the terms and conditions of the Settlement Agreement between the United States, Direct
Resource, Inc. and Relator effective April 25, 2012, attached hereto. Specifically, the Relator
Louis Scutellaro dismisses with prejudice as to himself. The United States dismisses with
prejudice the claims against Direct Resource for the Covered Conduct as the term is defined in
the Settlement Agreement between the United States, Direct Resource, Inc. and Relator effective
April 25, 2012, and otherwise dismisses the action against Direct Resource, Inc. without
prejudice to the United States.
In addition, the United States and Plaintiff-Relator Louis Scutellaro request that Relator’s
Complaint, this Application for Dismissal, the Settlement Agreement and the Order of this Court
dismissing this action be unsealed. The United States further requests that all other contents of
Case 1:10-cv-00113-JDB Document 19 Filed 04/30/12 Page 1 of 3
the Court's file in this matter made prior to this Application, including any applications filed by
the United States for an extension of the investigative period and supporting papers, remain
under seal and not be made public because such papers are submitted by law for the sole purpose
of evaluating whether the seal and the time frame for making an intervention decision be
extended.
No answer has been filed or served in this action.
Respectfully submitted,
STUART F. DELERY
Acting Assistant Attorney General
RONALD C. MACHEN JR., D.C. BAR # 447889
United States Attorney
DANIEL F. VAN HORN, D.C. Bar # 924092
Acting Chief, Civil Division
/s/ Darrell C. Valdez
DARRELL C. VALDEZ, D.C. BAR # 420232
Assistant United States Attorney
Judiciary Center Building
555 4th St., N.W., Civil Division
Washington, D.C. 20530
(202) 307-2843
JOYCE R. BRANDA
PATRICIA R. DAVIS
MARY CLARE GARTLAND CLAUD
Attorneys, Civil Division
Commercial Litigation Branch, Fraud Section
U.S. Department of Justice
P.O. Box 261
Ben Franklin Station
Washington, DC 20044
(202) 307-1088
Counsel for the United States
Case 1:10-cv-00113-JDB Document 19 Filed 04/30/12 Page 2 of 3
MCKNIGHT & KENNEDY, LLC
By: /s/ H. Vincent McKnight, Jr.
H. VINCENT MCKNIGHT, JR.
Counsel for Relator Louis Scutellaro
Dated: April 30, 2012
Case 1:10-cv-00113-JDB Document 19 Filed 04/30/12 Page 3 of 3
