a. Background information about the defendant (company
newsletters or annual reports to shareholders, company website
printouts, or a physician defendant’s curriculum vitae).
b. Background information about the whistleblower (your resume,
curriculum vitae, or copy of a recent job application, etc.)
c. E-mails and correspondence (in date order,
subdivided into appropriate categories, and then in date order within
each category).
d. Company or defendant documents about the fraud, divided by
type of documents or divided by fraud scheme, if there are several
different types of wrongdoing going on.
e. Information about witnesses, including addresses, home phone
numbers, and places of employment, particularly former employees
and those more likely to cooperate with government investigators.