Dennis Madarang, MA, CFE | False Claims Act Litigation Consulting
Deconstructing the Government’s Playbook in Section 8 Civil or Criminal Investigations.
The Problem: Information Asymmetry
When defense counsel faces a HUD-OIG subpoena or an unsealed Qui Tam complaint, the greatest risk is information asymmetry. The government relies on highly specific, often opaque administrative rules, practices, and loss-calculation models to drive massive damage calculations in both criminal and Civil False Claims Act proceedings.The Solution: The "Insider Advantage"
You cannot dismantle an investigative methodology if you do not understand how it was built. By applying 20 years of HUD-OIG investigative experience and rigor, I provide defense counsel with the blueprint to attack the government’s underlying assumptions, challenge scienter, and aggressively mitigate exposure.
Phase I: Pre-Intervention Risk Assessment.
* The Deliverable: Forensic review of target portfolios (HAP contracts, tenant ledgers, utility allowances) concurrent with subpoena response.
* The Value: Identifying the exact exposure points the government is looking for before they find them, allowing counsel to frame the narrative early.Phase II: Methodology Deconstruction.
* The Deliverable: Deep-dive analysis of the Relator's or Agency's damage models and liability theories (e.g., Rent Comparability, Prohibited Interests, HQS Implied Certification).
* The Value: Exposing flawed investigative assumptions, lack of materiality, and regulatory misinterpretations to arm defense counsel for DOJ presentations and declination pitches.Phase III: Litigation & Settlement Leverage.
* The Deliverable: Continuous subject-matter consulting through discovery, deposition prep, and trial.
* The Value: Equipping lead counsel with the precise regulatory and administrative counter-arguments needed to drastically reduce settlement baselines or confidently go to trial.
Knowing The AdversaryAs a retired HUD-OIG Special Agent and Program Manager, I spent two decades building the exact types of cases your clients are now defending against. I know where the evidentiary gaps typically hide in federal housing investigations, how agents interpret the relevant regulations, and what specific factors compel the DOJ to intervene—or to decline.Core Defense Expertise
Defending "Side Payment" and Rent Comparability allegations.
Attacking systemic HQS (Housing Quality Standards) violation theories, Conflicts, or Status Frauds.
Navigating Parallel Civil/Criminal proceedings and OIG administrative remedies.
Defeating the Damage Model
Advised counsel on isolating administrative errors of limited materiality from systemic "knowing" violations in a multi-state HCVP portfolio, providing the data necessary to mitigate the Government's "single damages" calculation.Challenging the Baseline Assumptions
Equipped defense counsel with analysis necessary to dispute investigative assumptions about subjective intent under the SuperValu standard.
Dennis Madarang, CFE
Principal, CivilFrauds Litigation Consulting LLCDennis brings over two decades of specialized federal investigative experience to the defense of complex False Claims Act and white-collar matters. As a retired Special Agent and Program Manager with the U.S. Department of Housing and Urban Development, Office of Inspector General (HUD-OIG), he developed and led the exact types of high-stakes investigations that target housing providers, developers, and corporate landlords today.During his federal tenure, he pioneered "first of their kind" applications of civil fraud theories to the Section 8 Housing Choice Voucher Program, including groundbreaking cases involving Rent Comparability and concealed "Side Payments." This inside knowledge of the government’s investigative playbook—how agencies select targets, how they interpret relevant regulations including 24 CFR Part 982, and the specific metrics used to calculate treble damages—provides defense counsel with a critical, asymmetric advantage during early-stage investigations, subpoena responses, and settlement negotiations.As a Certified Fraud Examiner (CFE), his methodology moves beyond standard regulatory compliance. He deconstructs the financial and administrative evidence to attack the government’s core theories of scienter and materiality, isolating isolated administrative errors from systemic, knowing violations to aggressively mitigate exposure. In his consulting role he advises relator's counsel and the defense bar on the Section 8 rental assistance programs and the emerging liability theories in that landscape.A recognized subject-matter expert and instructor in civil fraud applications, including the False Claims Act and FIRREA, he currently serves as the Director of a law enforcement training academy. He translates complex analysis into clear, compelling, and highly defensible narratives for prosecutors, judges, and juries.Core Defense CompetenciesDeconstruction of Relator and Agency damage models.Parallel Civil / Criminal proceeding strategy and risk mitigation.Forensic analysis of HAP contracts, tenant ledgers, and Certifications.
In federal white-collar defense, early intervention is everything. A rigorously documented counter-analysis presented to the DOJ before intervention decisions are made, or during post-filing settlement negotiations, can be the difference between a multi-million dollar judgment and a declination. I provide the specialized analytical leverage needed to kill weak claims early and help you obtain the best possible outcomes for your client.
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