United States of America ex rel. Amy C. Walden-Bing v. Horne, LLP, Deloitte, LLP, Cohn Reznick, and Witt O’Briens

District Court, S.D. Texas·Decided July 20, 2026·No. 4:23-cv-01792·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT July 20, 2026 FOR THE SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk HOUSTON DIVISION § United States of America ex rel. § Amy C. Walden-Bing, § § Plaintiff, § Civil Action No. 4:23-cv-01792 § v. § § Horne, LLP, Deloitte, LLP, Cohn § Reznick, and Witt O’Briens, § § Defendants. §

MEMORANDUM AND ORDER1 Plaintiff Amy C. Walden-Bing, as Relator, brought this qui tam suit under the False Claims Act. Dkt. 1. After Walden-Bing’s qui tam claims were dismissed, see Dkt. 66 (adopting Dkt. 53), Walden-Bing filed a motion for leave to amend her complaint to bring three claims in her personal capacity. Dkt. 58. She also moved to strike Defendants Horne, LLP’s and Deloitte, LLP’s motions (Dkts. 48 & 50) for extension of time to answer or otherwise respond to her complaint. Dkt. 57. After carefully considering the motions, the responses,

1 “[A] motion for leave to amend that does not dispose of an existing cause of action, counterclaim, or defense is within a magistrate judge’s authority because it is not exempted under [28 U.S.C.] § 636 and is non-dispositive as defined by Federal Rule 72.” Macias v. Bexar Cnty., 2023 WL 3103829, at *1 (W.D. Tex. Apr. 25, 2023) (citing Pyca Indus., Inc. v. Harrison Cnty. Waste Water Mgmt. Dist., 81 F.3d 1412, 1421 (5th Cir. 1996)). Dkts. 60, 61, the reply, Dkt. 63, and the applicable law, it is ordered that (a) Walden-Bing’s motion for leave to amend (Dkt. 58) be granted in part and

denied in part and (b) her motion to strike (Dkt. 57) be denied as moot. Background The following facts are taken as true. Walden-Bing was employed by Horne as a Quality Assurance/Quality Control Specialist to help process

applications for rental assistance under the Texas Rent Relief program, which is federally funded. Dkt. 58-1 at 2. During 2022, she “observed and documented” what she believed to be “serious compliance, control failures, and fraud risks in program processing,” including “funded applications with

irregularities” and “conflicting property or records information.” Id. at 3. She reported her concerns to management and human resources, including her concerns “about the volume of funded fraudulent applications and ongoing failure to investigate irregularities and reconcile conflicting property records.”

Id. Meanwhile, Walden-Bing made reports to the Office of Inspector General, the Securities and Exchange Commission, and the U.S. Department of Labor. Id. Walden-Bing was terminated around September 2, 2022. Id. at 5. Two months later, she “communicated” with the Office of Inspector General

regarding her concerns and termination. Id. Walden-Bing originally filed this case as a qui tam action under the False Claims Act (“FCA”), naming four defendants: Horne, Deloitte, Cohn Reznick, and Witt O’Briens. Dkt. 1 (filed May 8, 2023). The United States of America (“the Government”) declined to intervene, Dkt. 22, and this case was unsealed,

Dkt. 23. Thereafter, Walden-Bing’s attorney moved to withdraw as counsel, Dkt. 27, which this Court granted, Dkt. 31. The Court’s order also extended Walden-Bing’s deadline for effectuating service of process. See Dkt. 31 at 1-2. On December 8, 2025, Walden-Bing—acting pro se—filed an amended

complaint asserting that Horne and Deloitte violated the False Claims Act, 31 U.S.C. § 3729(a)(1)(A), (a)(1)(B), (a)(1)(G) (Counts I through III) and raising claims for payment by mistake (Count IV), unjust enrichment (Count V) and negligence (Count VI). Dkt. 42 at 23-26. Defendants Cohn Reznick and Witt

O’Briens were dropped from the amended complaint. See id. at 1. The Government then intervened solely to seek dismissal of the FCA claims, which a pro se litigant cannot pursue on the Government’s behalf. See Dkts. 45, 46. This Court agreed, dismissing the FCA claims on that basis but

also dismissing Walden-Bing’s common-law claims for lack of standing. Dkt. 66 (adopting Dkt. 53). The Court also denied, without prejudice, Walden-Bing’s barebones request for leave to amend, instructing Walden-Bing to file a standalone

motion for leave that included a proposed amended pleading stating her new claims. Dkt. 53 at 11. Separately, the Court granted Horne’s and Deloitte’s motions to extend the deadline to answer or otherwise respond to Walden- Bing’s amended complaint. Dkt. 49 (December 29, 2025 order granting Horne’s motion); Dkt. 53 at 12 (January 6, 2026 order granting Deloitte’s motion).

After this Court granted the extensions, Walden-Bing filed a motion to strike those requests. Dkt. 57 (filed January 7, 2026). On January 13, 2026, Walden-Bing moved for leave to file a second amended complaint. Dkt. 58. Her proposed pleading (the “proposed

complaint”) drops all previous claims and asserts a retaliation claim under the False Claims Act, 31 U.S.C. § 3730, a retaliation claim under the National Defense Authorization Act’s (“NDAA”) whistleblower provision, 41 U.S.C. § 4712, and an alternative wrongful discharge claim under Texas law. Dkt. 58-

1 at 6-7. Both Horne and Deloitte oppose Walden-Bing’s motion for leave to amend. Dkt. 60 (Horne’s response); Dkt. 61 (Deloitte’s response). Walden-Bing replied to Horne’s response. Dkt. 63. The motions are ripe for resolution. Legal Standard

Rule 15(c) of the Federal Rule of Civil Procedure provides that a party may amend her pleading once as a matter of course. Fed. R. Civ. P. 15(a)(1). Otherwise, a “party may amend its pleading only with the opposing party’s consent or the court’s leave,” which the court should freely give “when justice

so requires.” Fed. R. Civ. P. 15(a)(2). This rule “evinces a bias in favor of granting leave to amend.” Jones v. Robinson Prop. Grp., L.P., 427 F.3d 987, 994 (5th Cir. 2005) (quotation omitted). The relevant factors include “[(1)] whether permitting the pleading would cause undue delay in the proceedings or undue prejudice to the nonmovant, [(2)] the movant is acting in bad faith or

with dilatory motive, [(3)] the movant has previously failed to cure deficiencies by prior pleadings, or [(4)] the proposed pleading is futile in that it adds nothing of substance to the original allegations or is not germane to the original cause of action.” Lewis v. Knutson, 699 F.2d 230, 239 (5th Cir. 1983).

Amendment would be futile if a proposed new claim or allegations “could not survive a motion to dismiss” under Federal Rule of Civil Procedure 12(b)(6). Rio Grande Royalty Co. v. Energy Transfer Partners, L.P., 620 F.3d 465, 468 (5th Cir. 2010).

Analysis As both Horne and Deloitte observe, it is unclear whether Walden-Bing intends to assert claims against Deloitte in her proposed complaint. Because Walden-Bing’s proposed complaint contains no factual allegations concerning

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United States of America ex rel. Amy C. Walden-Bing v. Horne, LLP, Deloitte, LLP, Cohn Reznick, and Witt O’Briens, (S.D. Tex. 2026).

United States of America ex rel. Amy C. Walden-Bing v. Horne, LLP, Deloitte, LLP, Cohn Reznick, and Witt O’Briens (United States of America ex rel. Amy C. Walden-Bing v. Horne, LLP, Deloitte, LLP, Cohn Reznick, and Witt O’Briens) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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