Thomas E. Zeno
Thomas Zeno has more than 25 years of experience in the US Attorney’s Office for the District of Columbia. During that time, Tom investigated and prosecuted economic crimes involving healthcare, financial institutions, credit cards, computers, identity theft and copyrighted materials. As the office’s Healthcare Fraud Coordinator for the last eight years, Tom supervised investigation strategies of agents from the Federal Bureau of Investigation, the Department of Health and Human Services, the Drug Enforcement Administration and the Medicaid Fraud Control Unit regarding healthcare offenses. He also served as the liaison with the office’s civil division on joint proceedings. In addition, Tom served for several years as the Executive Assistant US Attorney for Operations, where he helped supervise the criminal division of the office.
Tom’s significant prosecutions include the conviction of five codefendants accused of defrauding an integrated managed care consortium and the criminal portion of a global settlement by a pharmaceutical company for off-label marketing. Tom also has been involved in highly publicized matters including hearings related to the conditions of release for John Hinckley, Jr., attempted presidential assassin, and the prosecution of government officials.
At Squire Sanders, Tom represents companies, audit committees, medical providers and individuals by conducting internal investigations and defending against government investigations under the False Claims Act (qui tam) and Foreign Corrupt Practices Act (FCPA). Tom evaluates these actions through the lens of his extensive experience both as a supervisor as well as a line attorney who handled investigations personally by litigating scores of trials and contested hearings. His insight and judgment make him a powerful advocate when explaining flaws in qui tam
or FCPA actions to investigators from the government such as the Department of Justice and Office of the Inspector General.
Tom is the recipient of several commendations and special achievement awards given by the Department of Justice and was awarded Investigation of the Year, Honorable Mention by the National Healthcare Anti-Fraud Association in 2008. In 1998, he received the Harold J. Sullivan Award, the highest award presented annually by the Assistant United States Attorneys’ Association for career excellence. In 2007, he was awarded the Inspector General’s Integrity Award from the Department of Health and Human Services for his outstanding contributions in healthcare fraud investigations.
Tom is the co-author of articles on preventing and responding to data breaches published in 2014 in Title News
and online in Baseline Magazine
, “Preserving the Attorney-Client Privilege for In-House Counsel,” published in the December 2013 edition of Connections
, the American Health Lawyers Association Magazine, “Uncle Sam Becomes a Doctor: Governent Challenges to Medical Necessity,” published in the Bar Journal
of the Cleveland Metropolitan Bar Association in September 2013 and "Rx for Health Care Fraud: The Feds Get Personal,” published in Criminal Justice
, Winter 2012, by the American Bar Association. Tom served as a panelist for the 19th Sentencing Guidelines Seminar presented by the National Association of Criminal Defense Lawyers and the American Bar Association in 2010. He also authored “A Prosecutor’s View of the Sentencing Guidelines,” published in Federal Probation
As an adjunct professor at Georgetown University for eight years, Tom instructed student prosecutors in trial skills at the Criminal Justice Clinic.
- Representing a physician-owned joint venture during a federal qui tam investigation that resulted in declination by the government and dismissal by the relator following a presentation made to the government. Neither a settlement nor a Corporate Integrity Agreement was required.
- Representing a federal government contractor by successfully resolving a relator’s false claims act complaint that the company paid gratuities to influence award of a government contract.
- Representing the Audit Committee of a China-based US public company and performing an independent investigation concerning the FCPA and financial disclosures to the US Securities and Exchange Commission (SEC).
- Representing government employees by securing dismissal of the complaint suing them in their individual capacity under the Bivens doctrine for alleged violations of constitutional rights.
- Representing manufacturing companies defending against a federal qui tam complaint alleging they falsely certified that parts complied with government standards.
- Representing an individual defending against a federal qui tam complaint alleging that the individual and others submitted claims for services even though their conduct violated terms of the contract with the government.
- Representing a former employee during parallel criminal and civil investigations following a federal qui tam complaint alleging that the former employer, a government contractor, submitted claims for work that was not performed.
- Representing individuals by securing dismissal of more than 40 felony charges and return of all personal funds that had been seized in the largest case of its kind in Florida, involving the arrest of more than 50 people affiliated with Allied Veterans of the World who were accused of RICO violations, money laundering and illegal possession of slot machines following an investigation that lead to the resignation of the Florida Lieutenant Governor.
- Representing a former manager during questioning about billing practices by federal and state healthcare investigators under a common interest agreement with the former employer, a healthcare provider.
- Representing a former employee during a criminal and civil investigation into a qui tam allegation of false billing under a common interest agreement with the former employer, a government contractor
- Representing an individual who received a substantial downward variance after pleading guilty to healthcare fraud.