After receiving LB&B’s initial application for certification, the SBA requested additional materials from the 9 company. The SBA specifically noted that Ms. Brandon’s résumé did not appear to indicate that she had the necessary skills to manage and operate the company. The SBA asked LB&B to provide a fuller explanation of who had such skills at the company. Id. ¶ 54. The Government alleges that in responding to this request for information, Defendants further misrepresented Ms. Brandon’s skills and role by stating that she had prior management experience in the manufacturing industry, that she had direct control over daily operations, that only she could sign company commitments and checks, and that she controlled the finances of the company. Id. ¶¶ 56-60.

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