Federal Fraud Lawsuit Filed: Hollingsworth v. Sanofi et al.

Filed December 11, 2025 — U.S. District Court, District of Oregon

Case No. 3:25-cv-2308-SB

On December 11, 2025, I filed a new federal lawsuit in the United States District Court for the District of Oregon against Sanofi-Aventis U.S. LLC, Chattem Inc., Quten Research Institute LLC, AMJ Services LLC, and Steven S. Dickert, in his capacity as Trustee of Basil Management Trust.

This case is not a wage dispute. It is a federal fraud and concealment action that arose only after a routine unpaid-wage issue exposed a much broader corporate structure operating behind the “Direct Demo” brand.

How This Case Began

The matter originated as a claim for approximately $637.15 in unpaid wages following my work as a W-2 product demonstrator inside Oregon Costco warehouses. When the entity listed on my paystubs—DRVM LLC—failed to pay, I reviewed public records to determine who was legally responsible.

That review showed that DRVM LLC was a revoked and unregistered shell entity during my entire period of employment. Further investigation revealed that DRVM was part of a larger, long-running network of Nevada-based entities sharing the same address, officers, trust ownership, and operational functions.

What the Investigation Revealed

The complaint alleges that a single, unified enterprise operated through layers of shell companies and trusts to conceal the identity of the true employer while directing a nationwide demonstrator workforce. According to public filings, payroll records, and corporate registrations:

• Multiple entities tied to the workforce shared the same Nevada address and officers.

• Employee-facing systems, training materials, and handbooks identified companies different from the entity listed on wage and tax documents.

• Payroll for different product lines was commingled and routed through defunct or inactive entities.

• After whistleblower disclosures and arbitration filings, the same shell entities were retroactively activated across multiple states, rather than being lawfully registered during the time employees were working.

The investigation further traced operational and financial control upstream to Sanofi-Aventis U.S., through its subsidiaries Chattem and Quten, following Sanofi’s 2023 acquisition of Quten Research Institute.

Multi-Forum Proceedings and Why This Case Is Separate

Before this filing, related issues were pending in:

• JAMS arbitration, limited solely to a narrow wage claim against DRVM LLC;

• A Department of Labor Taxpayer First Act & Sarbanes-Oxley retaliation proceeding, arising from federal whistleblower disclosures; and

• A prior petition to compel arbitration in federal court.

On November 24, 2025, the Court ruled that only DRVM LLC could be compelled to arbitrate—and only on the narrow wage issue, because the other entities were not signatories to the arbitration agreement. That ruling left all enterprise-level issues, including fraud, concealment, alter-ego liability, and civil conspiracy, outside arbitration and appropriate only for judicial review.

This new lawsuit addresses conduct that cannot be resolved in arbitration or administrative proceedings, including:

• Concealment of the true employer’s identity;

• Use of dissolved or unregistered entities to issue wage and tax documents;

• Coordinated corporate restructuring following whistleblower activity; and

• Contradictory representations made across arbitration, federal court, and the Department of Labor.

What This Case Seeks to Address

The complaint asserts claims for fraud, fraudulent concealment, civil conspiracy, alter-ego liability, and successor liability, and seeks to hold the upstream controllers of the enterprise accountable for conduct carried out through shell entities and trust-controlled companies.

This filing is intended to ensure that the full structure, rather than a single revoked shell, is evaluated by a federal court with jurisdiction to examine the complete factual record.

The filed complaint and exhibits are available for review and detail the corporate records, timelines, payroll evidence, and state-by-state filings underlying these allegations.  

Filing of the Federal Fraud Complaint

After filing the federal fraud case in December, I submitted:

• The Complaint

• All supporting exhibits

• The full structural record tied to the enterprise allegations

At that point, no defense counsel had formally appeared for AMJ Services LLC or Steven S. Dickert (Trustee of Basil Management Trust).

However, I already knew Fisher Phillips had been involved in related proceedings since April 2025.

December 12 – Inquiry to Fisher Phillips

On December 12, the same day the federal lawsuit was filed, I emailed Fisher Phillips directly.

I asked a straightforward question:

Are you representing AMJ Services and the Trustee in this federal case?

They did not respond.

This is notable because:

• They had been involved in arbitration matters since April 2025.

• They were aware of structural and payroll issues already raised.

• They had previously been served preservation-related communications.

There was no reply.

Early January – Formal Service

In early January, I formally served AMJ Services and Steven S. Dickert As Trustee of Basil Management Trust.

Shortly thereafter, Fisher Phillips appeared.

They initiated a new email thread stating that they represented:

• AMJ Services LLC

• Basil Management Trust (through the Trustee, Steven Dickert)

They then requested an extension to February 6, stating they had been “recently retained” and needed time to review the Complaint.

The Extension Request

The request stated they were recently retained.

However, Fisher Phillips had been involved in related matters since April 2025.

Rather than responding to my December 12 inquiry, they waited until after formal service and then characterized themselves as newly retained in their extension request to the Court.

The request was filed late in the evening.

Because I did not yet have electronic filing access, I began preparing an opposition but was unable to reach the courthouse in time the following day.

The Court granted the extension.

Fisher Phillips’ new response deadline became February 6.

Appearance of Faegre Drinker

After Fisher Phillips secured their extension, a second major law firm entered the case.

Faegre Drinker Biddle & Reath LLP contacted me stating they now represented:

• Sanofi-Aventis U.S. LLC

• Chattem Inc.

• Quten Research Institute LLC

They requested a 30-day extension.

That would have pushed their response deadline to February 20 — two weeks after Fisher Phillips’ February 6 deadline.


The Staggered Deadline Issue

If granted as requested:

• Fisher Phillips’ deadline: February 6

• Faegre Drinker’s deadline: February 20

This would have created staggered briefing and staggered motion practice.

From a procedural standpoint, staggered deadlines can:

• Multiply briefing cycles

• Increase procedural complexity

• Force overlapping responses

• Expand litigation burden

I responded with a counterproposal:

Instead of 30 days, I proposed 21 days.

That would align their deadline at February 11, reducing the staggered effect.
Faegre Drinker agreed.

They filed their extension request with the Court reflecting a February 11 deadline.

Procedural Posture at That Point

At that stage:

• Fisher Phillips had a February 6 deadline.

• Faegre Drinker had a February 11 deadline.

• Both major defense firms had formally appeared.

• Multiple defendants were now represented by large national law firms.

This marked the point where the upstream parent entities formally entered the litigation, and coordinated defense counsel began shaping the response strategy.

February 5 – Meet and Confer with Fisher Phillips

On February 5, I participated in a required meet-and-confer call with Fisher Phillips regarding their anticipated Motion to Dismiss.

These calls are intended to be conducted in good faith under Local Rule 7-1 — to clarify positions and determine whether any issues can be narrowed before motion practice.

This call was not routine.

Their Stated Position

During the call, counsel outlined the core structure of their defense:

• They intend to challenge standing.

• They intend to challenge fraud under Rule 9(b).

• They intend to argue alter ego and successor liability are not standalone claims.

• They intend to assert that any injury must be resolved exclusively through arbitration.

• They intend to challenge personal jurisdiction and structural allegations.

In short: they signaled a full Rule 12 attack — what is commonly referred to as “throwing the kitchen sink” at the complaint.

Tone and Conduct of the Call

Throughout the call, counsel repeatedly emphasized that I am not an attorney.

Statements were made along the lines of:

“I know you’re not an attorney, so I can explain this to you.”

They repeatedly suggested I was misunderstanding the law and misreading corporate structure.

I was also asked multiple times whether I would consider voluntarily withdrawing the case.

Meet-and-confer calls are supposed to be conducted in good faith to clarify legal positions. Instead, the tone of the call was adversarial and condescending.

There were multiple moments where counsel attempted to speak down to me or control the framing of the discussion.

I remained professional and focused on substance.

Structural Disputes Raised on the Call

One of the core issues discussed was ownership and control.

Counsel asserted that:

• Steven Dickert is not the “owner.”

• He serves as Trustee.

• The entities are separate.

• Corporate formalities are maintained.

At the same time, their own declarations acknowledge:

• He is CFO of DRVM and AMJ.

• He is Trustee of Basil Management Trust.

• The Trust holds a controlling interest in DRVM.

• AMJ provides payroll and HR services.

Those structural admissions are now part of the federal record.

The call made clear what their strategy would be:

Emphasize formal separateness.

Minimize enterprise coordination.

Narrow the case back to wage arbitration.

Challenge fraud pleading standards.

Attack standing.

Strategic Takeaway

What became clear during the call is that the defense intends to:

• Aggressively challenge the complaint at the pleading stage.

• Frame the case as a simple wage dispute.

• Avoid structural examination beyond DRVM.

• Seek dismissal before discovery.

The February 5 call was not about resolution.

It was about positioning.

And it confirmed exactly how the defense plans to approach this case moving forward.

On February 6, 2026
Fisher Phillips, one of the largest employment defense firms in the country, has filed a Motion to Dismiss on behalf of AMJ Services LLC and Steven S. Dickert (Trustee of Basil Management Trust).

In the motion, they argue:

• I lack standing.

• Only DRVM was my employer.

• Any injury must be resolved exclusively in arbitration with DRVM.

• The fraud-based claims fail under Rule 9(b).

• Civil conspiracy, alter ego, and successor liability are not properly pleaded.

• Alternatively, the entire case should be struck.

However, in the same filing, they also ask the Court to compel arbitration against AMJ and Dickert as third-party beneficiaries of the DRVM arbitration agreement.

That dual position is significant:

• For dismissal, they argue separateness.

• For arbitration enforcement, they argue interconnectedness.

The motion is supported by sworn declarations from the CFO/Trustee and from counsel. Those declarations confirm overlapping leadership roles, trust control, payroll servicing, and entity structure, all now part of the federal court record.

The Court must now decide whether:

• The case proceeds beyond DRVM,

• The structural fraud and concealment claims survive,

• AMJ and Dickert can enforce the arbitration agreement,

• Or the case is narrowed back to wage-only arbitration.

This filing formally locks in the defense’s structural position under oath — and moves the dispute from theory into sworn federal record.

A formal Notice of Fraud on the Court has now been filed in the federal case (3:25-cv-2308-SB).

The notice addresses the submission of an altered arbitration agreement and sworn testimony that materially misstates the effect of a prior court order, both filed in support of the defendants’ Motion to Dismiss and Motion to Compel Arbitration.

The Notice of Fraud on the Court was necessary because Fisher Phillips submitted an arbitration agreement that I had never seen before, despite the fact that for over a year the only agreement relied upon in arbitration and prior proceedings was the version bearing my middle name, a distinction even noted by the prior court.    This newly presented version was never provided to me, never used in arbitration, and never disclosed in earlier filings, yet is now being asserted as controlling after the fact. While Fisher Phillips reference an audit trail suggesting it was sent electronically, it was never represented to me that a separate or superseding agreement existed, nor was it ever produced or relied upon until it became strategically useful. At the same time, they submitted sworn statements mischaracterizing the Court’s prior order to suggest that all claims can be pushed into arbitration, despite that order narrowing the scope of arbitration and separating broader claims. Taken together, presenting a previously undisclosed agreement as controlling while misrepresenting the Court’s order goes directly to the integrity of the record, which is why the issue had to be formally placed before the Court.

The Court will determine the significance of the issues raised.

FISHER PHILLIPS RESPONSE TO THE FRAUD NOTICE

In response to the Notice of Fraud on the Court, Defendants did not simply dispute the issue, they escalated it.

Their filing characterizes the Notice as false, asserts that I misunderstand the law, and argues that the filing itself is improper and sanctionable. They go further, claiming the allegations are defamatory, that my filings are made in bad faith, and that my use of a website and social media to document the case constitutes harassment. They also request that I be required to remove public content about the case and issue a public apology. 

At the same time, their response attempts to explain the existence of two arbitration agreements. According to their version, an initial onboarding packet was completed under the middle name “Jorden Timothy,” followed by a second set of documents corrected to reflect my last name, which they claim was also signed electronically. 

In response, Defendants characterize the Notice as bad faith and suggest that the name discrepancy is an attempt to mislead, focusing on the use of my middle name, name consistently tied to my email and prior filings, and part of my legal name. At the same time, they ignore the broader context in which multiple individuals within their own structure operate under varying or inconsistent names, while dismissing the central issue: why a different version of the agreement was introduced only at this stage despite not being disclosed or relied upon in earlier proceedings.

The Notice of Fraud on the Court also attaches the audit trail Fisher Phillips rely on to support the existence of a second arbitration agreement, which they now claim is controlling. Notably, this is one of the few instances where detailed document tracking is produced, while, at the same time, key underlying materials relevant to payroll, control, and decision-making continue to be withheld or described as outside their possession.

Regardless of whether a second onboarding document was electronically processed, it was never provided back to me, never relied upon in arbitration, and never presented in prior proceedings. For over a year, the only agreement used across forums was the original version, which governed the arbitration process. The version now being introduced is materially different, has not been seen by the Court or arbitration, and is being asserted as controlling only after the fact, while the response focuses on attacking the Notice itself rather than addressing that discrepancy.

THE CORE DISPUTE

The issue is not whether two versions of paperwork exist.

The issue is which agreement actually governed—and what was consistently presented, relied upon, and recognized across the proceedings.

From the beginning of arbitration through federal court, the only agreement ever used was the version signed under “Jorden Timothy.” That is the agreement used to initiate arbitration. That is the agreement reviewed by the Court. That is the agreement that has governed the process for over a year.

For that entire time, no alternative version was introduced or relied upon.

THE WEBSITE AND PUBLIC RECORD

Fisher Phillips also focus heavily on the fact that I have documented the case publicly.

They characterize the website and social media updates as improper, alleging that they contain false or defamatory statements and should be removed. But the purpose of those updates has been straightforward: to explain, in plain terms, what is happening in the case based on publicly filed documents and procedural events.

The information shared is grounded in the record. It reflects filings, timelines, and positions taken in court, not personal attacks.

Even knowing there is a whistleblower case currently. Truly, what protections whistleblower really have? You really have to fight for them.

WHY THIS MATTERS

This is not about tone. It is about substance.

At the same time that Fisher Phillips are asking for content to be removed and framing public discussion as misconduct, they are introducing a version of a central contract that was not previously used in arbitration or earlier proceedings, and relying on it to support new arguments.

So the issue remains:

• which agreement actually governs
• what was presented to each forum
• and whether the record is being interpreted consistently

WHERE THIS LEAVES THINGS

What remains before the Court is not just a disagreement over documents.

It is whether the case will proceed based on the record as it developed over time, or whether new characterizations and materials will redefine that record after the fact.

At the same time, attempts are being made to shift focus away from those issues and toward the manner in which the case is being explained publicly.

Those are separate questions.

And only one of them determines the outcome of the case.

Federal Court Update: Extension Granted — Deadlines Aligned

Here is what ultimately happened with the second extension request filed by Faegre Drinker (Sanofi, Chattem, Quten).

Recap

• The parties had agreed to a February 11 deadline specifically to avoid staggered briefing.

• On February 9, during our meet-and-confer call, Faegre Drinker previewed their entire anticipated Motion to Dismiss in detail.

• At the end of that call, they requested an additional seven-day extension.

• I explained I did not oppose reasonable extensions — I opposed staggered deadlines.

• I proposed aligning opposition deadlines to avoid inefficiency.

• They declined.

They then filed their Second Motion for Extension, supported by declaration.

I filed an Opposition explaining the prior agreement and the risk of staggered briefing.

They filed a Reply.

They also emailed chambers requesting expedited ruling. Here’s a fight over an extension. I know exactly what they’re trying to do.

The Court’s Ruling

Right before 5:00 PM on February 11, the Court granted the extension.

However — and this is important, the Court also permitted me to move to align my opposition deadline to match the new Sanofi deadline.

In other words:

The extension was granted.

But the Court addressed the staggered-deadline issue.

The very alignment solution I proposed — which defense counsel declined — is now effectively in place through the Court’s management of the schedule.

What This Means

This was never about denying seven days.

It was about:

• Avoiding staggered briefing cycles.

• Avoiding overlapping opposition deadlines.

• Preventing unnecessary procedural complexity.

• Ensuring fair and efficient case management.

Had defense counsel agreed during our February 9 call to align opposition timing, this entire motion practice likely could have been avoided.

Instead:

• A motion was filed.

• An opposition was filed.

• A reply was filed.

• Chambers were contacted.

• Judicial resources were expended.

And the end result is what I proposed at the outset: aligned deadlines.

Where Things Stand Now

• Faegre Drinker has additional time to file their Motion to Dismiss.

• My opposition deadlines can now be aligned.

• The staggered briefing issue has been addressed.

The Court preserved efficiency.

And thankfully, the schedule is now structured in a way that avoids the procedural imbalance I raised from the beginning.

MOTION TO DISMISS BY SANOFI, CHATTEM, QUTEN

A motion to dismiss is a legal filing where the defendant asks the court to throw out a case at the very beginning, before any evidence is exchanged. It does not decide what actually happened, instead, it tests whether the complaint, as written, states valid legal claims. In other words, the court assumes the facts are true for purposes of the motion and determines whether those facts are sufficient to move the case forward.

Following the February filings, the case quickly moved beyond initial positioning and into full-scale motion practice across multiple fronts.

Faegre Drinker, representing Sanofi, Chattem, and Quten, filed their Motion to Dismiss on February 18, 2026. That motion focuses heavily on personal jurisdiction and attempts to remove the parent entities from the case entirely, arguing that there are no sufficient contacts tying them to Oregon and no factual basis connecting them to the alleged conduct.  

Defendants also submitted three declarations from senior executives at the highest levels of the pharmaceutical entities involved—including the North America CFO of Sanofi, the President of Quten Research Institute, and a senior executive of Chattem. Each declaration is narrowly framed, stating that the declarant has no direct contracts or formal relationships with DRVM. That framing, however, addresses only formal contractual ties, not the broader operational structure at issue. The absence of direct contracts does not resolve whether functions such as payroll, management, and control were carried out through intermediary entities. Notably, these declarations come from senior leadership of large pharmaceutical companies in response to what is otherwise characterized as a minor wage dispute involving an unrelated entity. At the same time, the declarations do not engage with the integrated enterprise theory or the underlying records that required extensive analysis to piece together how the entities operate in practice.

At the same time, Fisher Phillips continued advancing their position that the case should be dismissed outright or, alternatively, forced entirely into arbitration. Their motion makes a broad argument that there is no standing, no viable fraud claim, and no legal basis to proceed against AMJ or the Trust—while also asserting the right to enforce the arbitration agreement.  


MY CONSOLIDATED OPPOSITION
In response, I filed a consolidated opposition addressing both motions together. That filing brings the central issue into focus: whether an enterprise can designate a nominal employer while control, payroll authority, and economic benefit operate elsewhere—and then rely on arbitration and corporate separateness to avoid accountability.  

Alongside that opposition, a detailed declaration and 34 supporting exhibits were submitted, consisting of public filings, corporate records, and structural evidence connecting the entities involved.  

At that point, the dispute was no longer theoretical. The structure, the relationships between entities, and the competing narratives were all placed directly into the federal record.

At its core, the Opposition argues that this case is not a simple wage dispute tied to a single employer, but a structural challenge to how the enterprise operates. The Complaint alleges that DRVM was presented as the employer-of-record while lacking legal authority and independent operational control, with payroll, management, and economic benefit directed through related entities and upstream companies. It further argues that Defendants are attempting to use corporate separateness and arbitration to shield that structure from review, despite overlapping control, coordinated entity activity, and evidence of integration across the enterprise. At the pleading stage, these allegations—supported by public filings, timelines, and entity transfers—are sufficient to establish standing, jurisdiction, and viable claims for fraud, integrated enterprise liability, and related theories, and therefore the case should proceed beyond dismissal

All of their filings are attacking. I can’t do that because I’m representing myself. So I have to present myself in a completely different way. Plus that wouldn’t be my style anyway.

On March 18, 2026, Defendants Sanofi-Aventis US LLC, Chattem Inc., and Quten Research Institute LLC, filed the first reply in federal court, doubling down on their position that there is no jurisdiction, no wrongdoing, and no basis for any claim—characterizing the case as nothing more than an attempt to turn a minor wage dispute into a “far-flung” theory unsupported by facts.    This filing came after the Department of Labor had already moved forward under whistleblower statutes, yet the reply continues to ignore that posture and instead argues for full dismissal. At the same time, while Fisher Phillips sought extensions for other parties—as expected—the focus here was not on timing, but on ensuring that a single, consolidated opposition was placed on the record rather than fragmented responses. With briefing now effectively closed, the record is fully developed, and the next step will be how the Court chooses to address these competing narratives.

Defendants AMJ Services LLC and Steven S. Dickert/Basil Management Trust through Fisher Phillips LLP, filed their reply after seeking an extension, placing their arguments on the record after initial briefing had already begun.  In that filing, they characterize this case as a “meritless crusade,” a “Hail Mary attempt,” and an effort to transform a minor wage dispute into a “$15 billion” campaign, while asserting that no injury, no wrongdoing, and no viable claims exist. At the same time, these are the same attorneys representing the same structure across proceedings—including the Department of Labor matter now moving forward under SOX and TFA whistleblower statutes—yet the reply minimizes that proceeding, suggesting it was dismissed and proceeds only on appeal, without acknowledging that it has been advanced to hearing and discovery under federal whistleblower protections. The contrast between the posture of that proceeding and the language used in this reply highlights a broader pattern of narrowing the case and reframing the record despite the procedural reality now in place.

On the same day Fisher Phillips filed their reply, I submitted a Notice to the Court placing the Department of Labor proceeding on the record and clarifying its posture under the Sarbanes-Oxley and Taxpayer First Act whistleblower statutes.    The timing was the same, but the filing was going to be made regardless, to ensure the Court had an accurate understanding of what is actually occurring in the parallel proceeding. This was particularly important given the language used in the reply, which frames the case as meritless and limited, while those statements are being made in the context of an active whistleblower proceeding involving protected disclosures under federal law. The shocking thing is, Fisher Phillips knew since the 17th. And the way that they are characterizing it to the federal court on March 30. Just shocking…

The Court has taken both Defendants’ motions to dismiss, strike, and compel arbitration under advisement, determined that no oral argument is needed, and closed briefing with no further filings allowed without permission.

More to come.

They have unbelievable power with these courts. Even if the court goes their way at this moment, the appeal is next. The record that I have built should be enough for a strong appeal.