Photo of Terra White Fulham

Terra White Fulham

Terra Fulham represents corporate and individual clients in complex litigations and investigations, with particular expertise in defending government contractors against allegations of fraud and False Claims Act violations. She has experience representing clients at all stages of internal and government investigations, including conducting witness interviews, managing government subpoena and CID responses, defending witnesses in government interviews, and advocating before government enforcement officials. She has represented clients in investigations and litigation brought under the False Claims Act, including matters alleging noncompliance with U.S. government cybersecurity regulations, small business fraud, quality assurance deficiencies, conflicts of interest, and cost mischarging. Terra also has experience with suspension and debarment matters, representing entities in such proceedings to ensure their continued eligibility to participate in federal programs.

She has also represented clients in a variety of litigation matters during motions practice, discovery, and final hearings.

Terra also maintains an active pro bono practice, with an emphasis on immigration-related impact litigation.

Contact:Read more about Terra White FulhamEmail

On July 14, 2025, the U.S. Department of Justice (DoJ) and General Services Administration (GSA) announced a $14.75 million settlement of Civil False Claims Act allegations against IT company Hill ASC Inc. (Hill).  This settlement is consistent with the current Administration’s focus on “fraud, waste, and abuse” in government procurement and the recent DoJ FCA initiative focused on cybersecurity fraud.  This also follows the Department’s Criminal Division announcement of corporate procurement fraud as an enforcement priority.

The government alleged that between 2018 and 2023 Hill provided information technology services to federal agencies through the GSA’s Multiple Award Schedule (MAS) program.  The settlement resolved allegations that: (i) Hill billed federal agencies for information technology personnel who lacked the experience and/or education required under the contract; (ii) Hill had not passed GSA’s required technical evaluations for contractors who sought to offer highly adaptive cybersecurity services to government customers; (iii) Hill submitted claims for cybersecurity services and other services that were not within the scope of the contract; and (iv) Hill charged the government for unapproved fees, failed to provide government customers with required information about discounts for prompt payment, and included unallowable incentive compensation in a cost submission in connection with a new contract proposal (which the settlement agreement acknowledges that Hill withdrew before any contract based on the proposal was awarded.)

To settle these allegations, Hill agreed to pay $14.75 million “plus additional amounts if certain financial contingencies occur.”  The settlement imposes additional financial requirements including that Hill pay the United States 2.5% of its annual gross revenue that exceeds $18,800,000.00 from January 1, 2026 to December 31, 2029 (named the “Revenue Contingency Period”).  It appears that the amount of damages initially sought by the government was higher because DoJ noted that the settlement amount was based on “the company’s ability to pay.” Continue Reading Recent Cybersecurity FCA Settlement Demonstrates Heightened FCA Risk to Government Contractors

On February 17, 2021, Senator Chuck Grassley (R-IA) and Brian Boynton, Acting Attorney General for the Department of Justice’s Civil Division, provided opening remarks at the Federal Bar Association’s annual Qui Tam Conference. Both emphasized the key role of the FCA in combating fraud against the Government, and noted an

…
Continue Reading Senator Grassley and Senior DOJ Official Discuss Potential False Claims Act Changes and Enforcement Priorities