Evidence of Intentional Fraud (all parties)

 

1. False Staffing Certs from Day One

“At no point during my employment did Intellect Solutions provide active labor support for the contract's core deliverables. The only individuals from Intellect Solutions were myself, a BI analyst unfamiliar with revenue cycle, and another employee who handled congressional briefings — neither of whom had relevant subject matter expertise.”
📌 This means Intellect had no operational plan to meet FAR 52.219-14’s 50% labor rule — from the outset.


2. Shell Prime Setup with No Revenue Cycle Capability

“Intellect Solutions had zero internal capacity in revenue cycle management — the entire contract was staffed and executed by Tria Federal employees. Intellect functioned as a paperwork shell to access WOSB set-aside benefits.”
📌 This was not incidental; it reflects willful certification fraud: claiming to be the prime contractor while subcontracting nearly 100% of the work to another firm.


3. Fake Contract Leadership by Ghost Manager

“Until the day I was fired, I had never once communicated with the person listed as leading the contract for Intellect Solutions. My first interaction with them was on the day of my termination.”
📌 This demonstrates that Intellect’s ‘prime’ presence was a legal fiction. There was no day-to-day oversight — a clear violation of self-performance requirements.


4. Active Misrepresentation to DHA

“Despite being warned, Intellect Solutions continued to submit certifications affirming compliance with FAR 52.219-14. These were knowingly false — no structural correction was ever made.”
📌 Every monthly invoice and certification was a separate act of fraud — misrepresenting who was doing the work.


5. COR Was Informed — Then Retaliation Escalated

“After I raised the issue, the COR forwarded my disclosure to the contractor I accused of fraud — violating whistleblower protections. The contractor responded by revoking my severance agreement.”
📌 This shows not only intent but coordinated retaliation — an effort to silence the source of the fraud report instead of correcting the violation.


6. Conscious Obfuscation of Labor Reality

“The attached org charts, submitted to DHA, clearly showed the full contract team. Nearly all staff were Tria Federal employees. Despite this, Intellect never disclosed the imbalance nor requested a compliance waiver.”
📌 Omitting this truth during audits or renewal cycles constitutes deliberate concealment, not oversight.


7. Repeated Use of Fraudulent Designation for Award

“Intellect exploited its WOSB designation to win the award — despite having no internal bench to perform the work. It was a front for Tria, who supplied the labor, the leadership, and the deliverables.”
📌 This is pass-through fraud by design — a known FAR violation used to exploit diversity contracting.


8. Patterned Misconduct Beyond a Single Contract

While this evidence centers on W81XWH19F0450, a forensic review of other Intellect-held contracts likely reveals similar labor outsourcing patterns, raising systemic fraud concerns beyond this contract.
📌 Pattern = Intent. One instance can be error. A pattern of misrepresentation = scheme.


9. Post-Termination Cover-up Attempt

“Once I reported the noncompliance after termination, Intellect attempted to frame my protected disclosure as inappropriate contact. They revoked severance, then re-offered it after I cited whistleblower law.”
📌 This retaliation-reversal maneuver reflects an attempt to suppress evidence after the fraud had been flagged.


10. No “Similarly Situated” Subcontractor Status for Tria

“Tria Federal was not a similarly situated subcontractor under the WOSB set-aside rules. Therefore, all labor performed by Tria counted against the 50% limit — and Intellect was fully aware of that distinction.”
📌 This invalidates any plausible defense based on subcontractor classification — proving the violation was deliberate.

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