United States v. The Fidelity Deposit & Discount Bank

CourtDistrict Court, M.D. Pennsylvania
DecidedJune 12, 2025
Docket3:19-cv-01824
StatusUnknown

This text of United States v. The Fidelity Deposit & Discount Bank (United States v. The Fidelity Deposit & Discount Bank) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. The Fidelity Deposit & Discount Bank, (M.D. Pa. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA UNITED STATES OF AMERICA,: No. 3:19-CV-1824 ex rel. DIVYAKANT PATEL and : HARSHAD PATEL, : (Munley, J.) Plaintiffs (Caraballo, M.J.)

v. : THE FIDELITY DEPOSIT & DISCOUNT BANK, et al., : Defendants REPORT & RECOMMENDATION I. Introduction Defendant Fidelity D&D Bancorp, Inc. (““FDD Bancorp”) seeks to

Yecover $96,307.75 in attorneys’ fees and costs, after prevailing in a qui tam action filed by plaintiff-relators Harshad Patel and Divyakant Patel. As one of several defendants in this now-shuttered litigation, FDD Bancorp posits that the alleged False Claims Act (“FCA”) violations were limited to its codefendant and subsidiary, Fidelity Deposit & Discount Bank, thus rendering any claims against parent holding company FDD Bancorp, premised on that corporate structure alone, a frivolous, vexatious, and harassing endeavor.

Although the claims against FDD Bancorp did not survive the motion to dismiss stage of this litigation, the failure to assert a well- pleaded claim for relief against a defendant does not render the complaint frivolous per se. Moreover, as the relators offered a cognizable rationale for suing FDD Bancorp, albeit an ultimately unsuccessful one, these circumstances fall short of the exacting burden placed on a defendant to establish an action is clearly frivolous or vexatious, or primarily brought for the purpose of harassment. Accordingly, and for the reasons set forth below, it is recommended that the district court deny FDD Bancorp’s motion for attorneys’ fees. Il. Background After over five years of contested, and oftentimes convoluted litigation, this qui tam action ended with the relators dismissing the

case before the charging instrument was finalized or any defendant filed an answer. As the Court assumes the parties’ familiarity with the litigation, only the procedural history germane to the instant motion is set forth below; a labyrinthine exercise in and of itself. On October 18, 2019, relators Harshad Patel and Divyakant Patel filed a complaint alleging that defendants Fidelity Deposit & Discount

Bank, FDD Bancorp, Ankim Shah, Marina Capital LLC, and 1101 Northern Boulevard LLC defrauded the Small Business Administration (“SBA”) in connection with a loan program, among other things. See generally Doc. 1. The SBA loan at issue related to the purchase and renovation of a hotel facility by the Patels and their former business partner, Shah, with Fidelity Deposit & Discount Bank serving in a financing capacity. Jd. Fidelity Deposit & Discount Bank and its holding corporation, FDD Bancorp, were referenced collectively throughout the complaint’s allegations. Id. at { 8. The relators filed an amended complaint on February 18, 2020, containing substantially similar allegations. See generally Doc. 6. Again, Fidelity Deposit & Discount Bank and FDD Bancorp were referenced collectively throughout the amended complaint’s allegations. Id. at § 8. Specifically, the relators alleged that Fidelity Deposit & Discount Bank and FDD Bancorp, as the financing entities for the relators’ underlying hotel purchase and renovation venture, conspired with other defendants to defraud the SBA in connection with a loan for that project. Id . at J] 2-5.

In June and July 2020, the United States declined to intervene, and the case was unsealed. Docs. 12-13. Both Fidelity Deposit & Discount Bank and FDD Bancorp were subsequently represented by the

same attorneys throughout the course of the ensuing litigation. Docs. 17, 19, and 27. On October 8, 2020, Fidelity Deposit & Discount Bank and FDD Bancorp collectively moved to dismiss all claims against them. Doc. 28. Among the grounds advanced in support of dismissal, FDD Bancorp contended that, as a holding company of subsidiary Fidelity Deposit & Discount Bank, it did not itself engage in any banking activities. Id. at 18-19. Unlike Fidelity Deposit & Discount Bank, FDD Bancorp was neither a party to the documents referenced in the amended complaint, nor specifically alleged to have engaged in any of the false statements

or fraudulent conduct forming the premises for relators’ FCA claims. Id. at 19-20. Thus, FDD Bancorp sought dismissal, reasoning that relators could not “advance a prima facie cause of action.” Jd. at 21. The Court subsequently denied the motion to dismiss, without reaching the merits, to afford relators an opportunity to seek leave to amend their complaint. Doc. 38.

On November 25, 2020, relators moved for leave to file a second amended complaint. Doc. 45. The proposed pleading contained substantially similar allegations against Fidelity Deposit & Discount Bank and FDD Bancorp, again charging them as collective entities. Doc. 46 at 7. In opposition to the motion, FDD Bancorp reiterated its contention that, as nothing more than the parent holding company of Fidelity Deposit & Discount Bank, it should be dismissed as a defendant. Doc. 48 at 23-25. Relators did not address FDD Bancorp’s contention in their reply brief. Doc. 53. In consideration of both parties’ repeated failures to comply with the local rules, the Court denied relators’ motion for leave to amend, albeit without prejudice. Doc. 56. The merits of the motion to dismiss FDD Bancorp remained undecided. The Court simultaneously encouraged defendants to concur in a future motion for leave to amend that comported with the local rules, and reserve their merits arguments for subsequent motions to dismiss. Id. at 7. The parties followed the Court’s guidance and, on May 5, 2021, relators re-filed their second amended complaint, pursuant to a concurred-in motion granted by the Court. Docs. 57-59. This pleading

omitted many of the proposed changes in the original second amended complaint but, pertinently, contained substantially similar collective allegations against both Fidelity Deposit & Discount Bank and FDD Bancorp. Doc. 59 at 7-8. FDD Bancorp followed suit and renewed its motion to dismiss. Doc. 62. Again, FDD Bancorp contended that as a holding company of subsidiary Fidelity Deposit & Discount Bank, it did not itself engage in any banking activities, and thus could not have engaged in the conduct forming the premises for relators’ FCA claims. Id. at 20-22. In response, relators leveraged corporate veil-piercing principles to contend that FDD Bancorp remained an appropriate defendant. Doc. 68 at 31. Specifically, relators averred “that D&D Bancorp, a holding company, and Fidelity Deposit and Discount Bank, have the same directors and senior managers. Given the size of the loans [at issue] (over $8 million in total), it is plausible that the holding company was involved.” Id. Relators claimed that absent discovery, they could not determine whether any personnel of Fidelity Deposit & Discount Bank who allegedly participated in the conduct at issue did so “in their capacity as an officer or agent of the holding company.” Jd. In reply,

FDD Bancorp maintained that those conclusory allegations fell short of basic pleading standards. Doc. 74 at 15. Before the Court addressed the pending motions to dismiss, the relators sought leave to file a third amended complaint. Doc. 76. Through this pleading, relators sought to remedy several of the issues raised in the defendants’ motions to dismiss, but FDD Bancorp’s claim of corporate separateness, although acknowledged, went unaddressed. Id. at 5-7. Indeed, the proposed third amended complaint continued to treat Fidelity Deposit & Discount Bank and FDD Bancorp collectively, without any allegations discernibly specific to FDD Bancorp. Doc. 76-1. On July 27, 2022, and following oral argument on the motions to dismiss (Doc. 90), the Honorable Martin C. Carlson issued a report and recommendation that the motions be granted in part and denied in part. Doc. 98. Of relevance to the instant motion, Judge Carlson recommended that FDD Bancorp be dismissed from the action. Id.

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United States v. The Fidelity Deposit & Discount Bank, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-the-fidelity-deposit-discount-bank-pamd-2025.