Leading FCA lawyer and civil fraud litigator widely recognized as a luminary in the FCA investigations and enforcement space.
Represents clients facing FCA and civil fraud investigations and litigation, bringing to bear more than 25 years of DOJ enforcement experience.
As Assistant Director in the DOJ’s Civil Division, Commercial Litigation Branch (Fraud Section), guided DOJ FCA enforcement efforts nationwide and supervised nearly five hundred civil fraud cases.
As a Fraud Section Trial Attorney, handled dozens of FCA and other fraud investigations, settlements and litigations.
Experience includes fraud claims involving health care (such as Stark Law and Anti-Kickback Act compliance), cybersecurity and data privacy, government contracts and grants, energy, mortgage fraud, education and trade.
Sara leverages her decades of DOJ experience to provide compliance counseling and representation to clients facing False Claims Act (FCA) and other civil fraud issues, investigations and litigation. With a proven track record of litigation success in FCA actions, Sara is one of the most experienced FCA lawyers and civil fraud litigators in the market.
Prior to joining Akin, Sara led the DOJ’s FCA enforcement as Assistant Director for 16 years of the Civil Fraud Section and for 10 years as a trial attorney responsible for FCA cases. She handled and supervised all aspects of FCA and civil fraud investigations.
Clients rely on Sara as a strategic advisor drawing on her high-level government experience and her instrumental role guiding FCA enforcement efforts. She has litigated and/or supervised FCA matters in the key areas of health care, cyber, education, procurement/government contracts, customs, trade, energy and financial fraud.
Sara offers her deep knowledge of the law and the government’s approach to these cases to help clients avoid risks and navigate these matters to a favorable result, whether that be a declination or dismissal by DOJ of a qui tam complaint filed under the FCA’s whistleblower provisions, a self-disclosure, a settlement or a win in litigation.
Sara negotiated and oversaw scores of settlements and won victories at every phase of litigation, including summary judgment, trial and appeal, securing approximately $2 billion in recoveries. She trained DOJ attorneys on settlement and developed language used in DOJ settlement agreements.
Her DOJ civil fraud practice ran the gamut of government programs and agencies. One focus was health care fraud matters, including alleged Stark Law and Anti-Kickback Act violations and other overbilling. She led DOJ’s civil cyber-fraud enforcement efforts involving data privacy and other cybersecurity violations. She handled and supervised matters alleging contract and grant fraud, mineral royalty underpayments and mortgage fraud, as well as claims against universities and for trade-related violations.
Sara began her legal career as a law clerk for the Honorable John W. Bissell in the U.S. District Court for the District of New Jersey. She holds a J.D. from Yale Law School and an A.B. summa cum laude from Princeton University.
Representative Work
Cybersecurity and Data Privacy: Oversaw investigations and negotiations that led to twelve False Claims Act cyber-fraud settlements, including with three Fortune 100 companies. Allegations concerned violations of government cybersecurity requirements with respect to sensitive health/personal information or sensitive defense and other government information. Several settlements gave credit under DOJ policy on self-disclosure, cooperation and remediation.
Stark Law and Anti-Kickback Act: Won summary judgment on False Claims Act and common law claims against a home health company accused of Stark Law violations. Supervised other False Claims Act litigations over alleged Anti-Kickback Act violations. These included litigation against a national diabetic supplier that settled for $160 million and litigation over alleged kickbacks for laboratory referrals that led to $59 million in settlements with over 50 physicians.
Education: Won a jury verdict for the government against a prominent university in litigation over alleged misuse of foreign aid funds. Settled with all parties for $33 million.
Government Contracts and Grants: Handled and supervised investigations, litigation, and hundreds of millions of dollars in settlements with leading IT contractors over alleged overcharges on General Services Administration multiple award schedule contracts.
Energy: Negotiated over $300 million in settlements with major oil companies in litigation over alleged underpayment of natural gas royalties.
List includes matters worked on prior to joining Akin.