Dennis Madarang, MA, CFE | False Claims Act Litigation Consulting
Bridging the evidence gap in Section 8 False Claims Act cases. Specialized theories. Proven federal investigative standards. Higher intervention rates.
Most Qui Tam firms decline Section 8 fraud leads not for a lack of merit, but for a lack of clarity.The Problem: The "Data Fog"
Evidence in Housing Choice Voucher Program cases is often buried in hundreds of disparate HAP contracts, tenant ledgers, and HUD certifications.
Without a specialized investigative audit, the document trail is too dense, the scienter is too buried, and the materiality seems too cloudy to risk a filing.The Solution: The "DOJ-Ready" Bridge
I bridge the gap between a messy lead and a filed complaint. By applying federal investigative standards to your raw evidence, I deliver a DOJ-Ready Case that:
* Proves Intent: We don't just find errors; we pattern-match for scienter.
* Maps the Law: Every violation is tied to the specific federal regulations (24 CFR Part 982) that trigger intervention.Stop declining viable leads. Start filing with precision.
From case triage and intake to settlement or verdict, I work with you to deliver high-quality, pre-packaged cases that federal agencies and prosecutors won't ignore.
Phase I: Case Viability Audit
* The Deliverable: Expedited, flat-fee forensic vetting of evidence against 24 CFR Part 982 and related regulations.
* The Value: A detailed "Pass/Pursue" analysis of strengths, vulnerabilities, and investigative strategies—delivered before you incur significant litigation costs.Phase II: Disclosure Architecture
* The Deliverable: Comprehensive drafting of the Factual Disclosure Memorandum for DOJ/Agency submission.
* The Value: Transforming raw evidence into a "Prosecutive Summary" format specifically designed to align with DOJ intervention criteria and maximize agency engagement.Phase III: Litigation Partnership
* The Deliverable: Continuous subject-matter expertise throughout the lifecycle of the case.
* The Value: Expert support for DOJ presentations, damages modeling, and settlement negotiations to secure successful outcomes.
The "DOJ-Ready" StandardRetired HUD-OIG Special Agent and Program Manager with a proven record of leading complex investigations. I help Qui Tam counsel navigate the specific landscape of the False Claims Act and agency administrative remedies.Core Expertise* Pre-Filing Strategy: Case screening, viability audits, and intervention probability analysis.
* Deep-Domain Focus: Section 8 / Housing Choice Voucher Program landlord liability theories, including "Side Payments," HQS Certifications, Rent Comparability, and Sexual Harassment/Discrimination.
* Litigation Support: DOJ and Agency presentations, settlement negotiation support, and damages modeling.Proven Impact
Recognized by the Department of Justice for "first of their kind" applications of False Claims Act liability theories to HCVP landlord practices.Training & Instruction
Experienced instructor for investigators and attorneys in civil fraud applications, including the False Claims Act, FIRREA, and the Administrative False Claims Act.
Post-Declination Recovery
* The Challenge: Retained by Relator’s counsel after DOJ declined to intervene in a contentiously litigated Qui Tam action against a multi-state HCVP landlord.
* The Role: Advised counsel on Rent Comparability liability and evidence presentation.
* The Result: Successful settlement despite lack of government intervention.
Rent Comparability & "Side Payments"
* Lead Agent: U.S. v. Lukacs/Goodfish Enterprises et al (D. Del.)
* Pioneered the use of Rent Comparability liability theories on a mid-sized portfolio.
* Result: $430,000 settlement.
* Award: USAO Law Enforcement Award citing “first of its kind” use of the then-novel theory.Predatory Practices & Concealment Schemes
* Investigating Agent: U.S. v. Posner (E.D. Pa.)
* Uncovered egregious "sex for rent" quid pro quo arrangements and "fee for amenities" schemes used to conceal improper side payments.
* Result: $570,000 settlement and United States Attorney’s Office Law Enforcement Award.Prohibited Interests
* Lead Agent: U.S. v. Royzman / U.S. v. Geneles (E.D. Pa.)
* First use of proactive data matching to identify owners falsely certifying no family relationship with tenants.
* Result: Multiple resolutions totaling $218,000.
* Key Citation: Received USAO Award specifically citing the “settlement-ready” packaging of cases.Diversion of Utility Payments
* Lead Agent: U.S. v. Sherman Hills Realty et al (M.D. Pa.)
* Applied FCA remedies to a large-portfolio owner retaining Tenant Utility Assistance funds.
* Result: $125,000 settlement.Parallel Civil/Criminal Proceedings
* Lead Agent: Parallel Civil / Criminal Proceeding (M.D. Pa.)
* Investigated a landlord for side payments and subsequent witness tampering.
* Result: $171,000 Civil FCA settlement based on portfolio-wide damages + Guilty Plea to Tampering charge.
In a contingency environment, your most valuable asset is your focus. Our Expedited Case Viability Audits provide objective clarity to your "Pass or Pursue" decisions—empowering you to identify low-probability cases before you commit irrecoverable time, effort, and expense.
Follow my Section 8 FCA Updates on LinkedIn, or contact me below for a complimentary copy of my 2026 Section 8 Fraud Intake Checklist.
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