DOCUMENT INDEX In re: FIRSTLINE HEALTH INC. … · persons who identity is unknown to commit the crime of Insurance ... Selvin De Leon because ... and MARIA TURLEY directed Susan

DOCUMENT INDEX

In re: FIRSTLINE HEALTH INC. fna FRONTLINE MEDICAL ASSOCIATES INC., d/b/a US HEALTH AND ORTHOPEDIC MEDICAL

CLINICS / MUNIR UWAYDAH & PAUL TURLEY

EXH. #

DOCUMENT – EXHIBIT

1 LASC: THE PEOPLE OF THE STATE OF CALIFORNIA v. MUNIR UWAYDAH, ET AL., CASE NO. BA425397, INDICTMENT of 1. MUNIR UWAYDAH; 2. PAUL TURLEY; 3. MARIA TURLEY; 4. MARISA SCHERMBECK-NELSON; 5. PETER NELSON; 6. DAVID JOHNSON, M.D.; 7. LETICIA ALVAREZ LEMUS; 8. JEFF STEVENS; 9. WENDEE LUKE; 10. KELLY PARK; & 11. RON CASE

2 LASC: THE PEOPLE OF THE STATE OF CALIFORNIA v. RONNIE CASE, ET AL., CASE NO. BA455470, FELONY COMPLAINT FOR ARREST WARRANT

3 FICTITIOUS BUSINESS NAME RECORD: FRONTLINE doing business as US HEALTH AND ORTHOPEDIC MEDICAL CLINICS

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES

Tie People of the State of California, CASE NO. BA425397 Plaintiff,

v. INDICTMENT

,..

1. MUNIR UW A YDAH 2. PAUL TURLEY 3. MARIA TURLEY 4. MARISA SCHERMBECK-NELSON 5. PETER NELSON 6. DAVID JOHNSON, M.D. 7. LETICIA ALVAREZ LEMUS 8. JEFF STEVENS 9. WENDEE LUKE 10. KELLY PARK 11. RON CASE

COUNT 1

T

The said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECKNELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of CONSPIRACY TO COMMIT A CRIME, in violation of Penal Code Section 182(a)(l), a Felony, committed prior to the finding of this Indictment, and as follows:

A TRUE BILL

F.oreperson of the Grand Jury

Presented by the Foreperson of the Grand Jury in the presence of the Grand Jury, in open Superior Court of the State of California, within and for the County of Los Angeles, and filed as a record in said Court this 25111 day of February, 2015

SHERR1 R. CARTER, Executive Officer/Clerk

Deputy

'.. .·

On and between November l 5, 2004 and February 20, 2015, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MAlUA TURLEY, MAlUSA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE did unlawfully conspire together and with another person and persons who identity is unknown to commit the crime of Insurance Fraud, in violation of Section 550(a)(6) of the Penal Code, a fe lony; that pursuant to and for the purpose of carrying out the objectives and purposes of the aforesaid conspiracy, the said defendant(s) committed the following overt act and acts at and in the County of Los Angeles:

OVERT ACTS

I) On or about November 15, 2004, MUNIR UWA YDAH, an orthopedic surgeon, and PAUL TURLEY, incorporated Frontline Medical Associates.

2) Between November 15, 2004, and February 20, 2015, in order to obtain patients for Frontline Medical Associates, Firstline Health, Inc., and other related entities, MUNIR UW A YDAH and PAUL TURLEY paid "marketers" (aka "cappers") and attorneys for patient referrals.

3) Between February 1, 2006 and December 31, 2008, PAUL TUIU.EY AND MUNIR UW A YDAH made an agreement with Daniel Hitzke, a worker's compensation attorney, in which Hitzke would refer his clients to Frontline Medical Associates in exchange for a fee, or kickback. The agreement included bonuses for Hitzke for each client who would be a surgical candidate, with additional bonuses if the client had surgery.

4) Between February 1, 2006 and December31, 2008, PAUL TURLEY, MUNIR UWAYDAH, and MARISA SCHERMBECK-NELSON paid cash to Attorney Daniel Hitzke in exchange for client referrals to Frontline Medical Associates.

5) From September 2006, to March 2010, JEFF STEVENS referred clients from attorney Dennis Fusi's office to Frontline Medical in exchange for money.

6) PAUL TURLEY and MARISSA SCHERMBECK-NELSON directed Esther Ros to maintain capping lists for Frontline, which documented which attorney's office the patient came from, and which were used to determine how much was to be paid for each patient referral.

7) Between November 1, 2004 and June 30, 2010·, MUNIR UWAYDAH'S physician's assistant, PETER NELSON, performed surgical procedures on UW A YDAH'S patients while the patients were under general anesthesia and while MUNIR UW A YDAH was not present in the operating room.

8) Between November 1, 2004 and December 31, 2005, PETER NELSON performed surgical procedures on patients Hector Gonzalez, Ernesto Prado, and Rosalinda Munoz, while these patients were under general anesthesia.

9) Between May 1, 2006 and December 31, 2007, MUNIR U\VAYDAH and PETER NELSON performed unnecessary surgery on Mario Dominguez, Mario Polomo, Joaquin Peirera, and Selvin De Leon because there was no objective evidence that the injuries which were cited as the justification for the surggies 1vcre il]dicated in the patients' pre-operative MRI's.

-1:xh1b1t 1

10) Between September 11, 2007 and December 2010, under the direction of MUNIR UW A YDAH and PAUL TURLEY, Frontline Medical and Golden State Pharmaceutic a ls used Dr. Mills' name for prescribing medications and billing without his knowledge, consent or authorization.

11) On March 26, 2007, Golden State Pharmaceuticals was incorporated by MARISA SCHERMBECK-NELSON in order to serve Frontline patients exclusively.

12) On April 17, 2007, South Bay Surgical Center was incorporated by MUNIR UW A YDAH, MARISA SCHERMBECK-NELSON and Shelly Rosekelly, for the purpose of UW A YDAH performing surgeries on Frontline patients.

13) Between June 1, 2010 and December 31, 2011, LETICIA ALVAREZ LEMUS, Delmy Martinez and Jose Trujillo wrote DAVID JOHNSON'S name on prescriptions for medications.

14) Between January 1, 2009 and December 31, 2010, Kim Park and KELLY PARK prepared bills for Golden State Pharmaceuticals under the direction of MUNIR UWA YDAH.

I 5) From November 2004 to December 2010, DAVID JOHNSON over prescribed and over billed insurance companies for pharmaceuticals.

16) Between May 8, 2013 and December 31, 2014, DAVID JOHNSON billed insurance companies for office visits which he did not perform and for which he was not present.

17) Between January 1, 2007 and December 31, 2010, MUNIR UWAYDAH, PAUL TURLEY and MARIA TURLEY directed Susan Moreno to alter doctors' notes and reports in order to get surgery requests authorized by insurance companies. In return, she was paid monetary bonuses by MARISA SCHERMBECK-NELSON on behalf of Frontline Medical Associates.

18) Between January 1, 2009 and June 30, 2010, MARIA TURLEY directed Delmy Martinez to only include positive MRl's when seeking insurance company approval for surgeries.

19) Benvecn January 1, 2009 and June 30, 2010, MARIA TURLEY, as Surgery Director, told Delmy Martinez to refer all patients with minor medical issues for surgery authorization and to refer them to South Bay Surgical.

20) In 2009, California MRI was incorporated, with JEFF STEVENS as the owner. The business was physically located in a trailer behind Frontline Medical Associates' Snn Fernando clinic in order to exclusively serve Frontline patients.

21) Between January 1, 2007 and December 31, 2007, while he was employed at Frontline, Dr. Mills was directed by PAUL TURLEY and MARIA TURLEY to send all patients with positive MRl's to UWAYDAH for surgery.

Exhibit 1

. '

22) On February 23, 2010, Firstline Health, Inc. was incorporated and took over Frontline operations.

23) Between February 23, 2010 and December 31, 2011, PAUL TURLEY, WENDEE LUKE, and DAVID JOHNSON created U.S. Health and Orthopedics, as a DBA of Firstline Health, Inc.

24) On June 17, 2010, KELLY PARK and RONNIE CASE transported 921 prescription containers worth approximately $82,000 street value from their home. These prescription bottles were labeled with names of patients from Golden State Pharmaceuticals and Frontline Medical Associates.

25) On or between February 23, 2010, to December 31, 2014, WENDEE LUKE and Tatiana Torres Arnold caused money to be wired from Firstline bank accounts and/or related bank accounts to Estonia or Lebanon.

26) Between January 1, 2014 and January 15, 2014, PAUL TURLEY met with David Keller, a paralegal at a personal injury law firm, to discuss a possible business opportunity. During the meeting, PAUL TURLEY informed David Keller that MUNIR UWA YDAH and PAUL TURLEY were still involved in business together even though MUNIR UW A YD AH is in Lebanon, they were collecting on liens through U.S. Health and Orthopedics, and their involvement in the business was "silent."

27) Between January 1, 2014 and January 15, 2015, PAUL TURLEY travelled to Lebanon to meet with MUNIR UW A YDAH.

28) Between January 1, 2014 and January 15, 2015, PAUL TURLEY solicited David Keller to engage in a capping scheme.

29) Between August 21, 2008 and December 31, 2010, MUNIR UWAYDAH and KELLY PARK, and other co-conspirators planned to and did create a false arbitration agreement in the name of Jenniffer Milone.

30) Between August 1, 2008 and December 31, 2014, MUNIR UWA YDAH caused a fraudulent bill to be filed for payment for services rendered to patient Jenniffer Milone.

31) Between January 1, 2007 and June 30, 2010, KELLY PARK and RONNIE CASE, and other co-conspirators, planned to and did falsify documents in preparation for MUNIR UW A YDAH'S defense in a California Medical Board investigation.

32) Between January l, 2009 and December 31, 2010, MUNIR UWAYDAH, PAUL TURLEY, KELLY PARK, RONNIE CASE, JEFF STEVENS and Tatiana Arnold attempted to become the majority shareholders in Ventura County Business Bank.

Exhibit 1

33) Between November 1, 2004 and February 20, 2015, Frontline Medical Associates, Firstline and South Bay Surgical billed for surgeries performed by PETER NELSO N as if MUNIR UW A YDAH performed the surgeries.

34) Between March 26, 2007 and December 31 , 2014, MUNIR UWAYDAH and PAUL T URLEY and other co-conspirators caused prescription medications to be mailed to patients without being in child proof protection containers.

* * * * *

Medication Billing Counts 2-21

COUNT2

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as

the charge set forth in the a fa restated Count hereof, the said M UNIR UW A YDAH, PAUL TURLEY, MARIA

TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D.,

LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of

INSURANC E FRAUD, in violation of Penal Code Section SSO(a)(7), a Felony, committed prior to the finding

of this Indictment, and as fo llows:

On and between March 1, 2011 and January 31, 2015, in the County of Los Angeles, the said MUNIR

UWAYDAH, PAUL TURLEY, MARIA T URLEY, MARISA SCHERMBECK-NELSON, PETER

NELSON, DAVID JOHNSON, M .D., LETICIA ALVAREZ L EMUS, J EFF STEVENS, WENDEE LUKE, KELLY PARK and RON C ASE, did aid, abet, solicit, conspire with another and did knowingly

submit a claim to American Claims Management for a health care benefit which was not used by, or on behalf

of, the claimant.

It is further alleged that the claim or amount at issue exceeds nine hundred fifty dollars ($950).

* * * * *

COUNT 3

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UW A YDAH, PAUL TURLEY, MARIA

TURLEY, MARISA SCHERMBECK-NELSON, PET ER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, J EFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are

accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of

INSURANCE FRAUD, in violation of Penal Code Section 5SO(a)(7), a Felony, committed prior to the finding

of this Indictment, and as follows :

Exhibit 1

..

On and between March 1, 2011 and January 31, 2015, in the County of Los Angeles, the said MUNIR UW A YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly submit a claim to Berkshire Hathaway for a health care benefit which was not used by, or on behalf of, the claimant.


* * * * *

COUNT4

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UW A YDAH, PA UL TURLEY, MARIA

TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section SSO(a)(7), a Felony, committed prior to the finding of this Indictment, and as follows:

On and between March 1, 2011 and January 31, 2015, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly submit a claim to CNA Insurance for a health care benefit which was not used by, or on behalf of, the claimant.


* * * * *

COUNTS

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set fotih in the aforestated Count hereof, the said MUNIR UW A YDAH, PA UL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section SSO(a)(7}, a Felony, committed prior to the finding

of this Indictment, and as follows:

On and between March 1, 2011 and January 31, 2015, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly submit a claim to City of Los Angeles for a health care benefit which was not used by, or on behalf of, the claimant.

Exhibit 1

...


* * * * *

COUNT6

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section 550(a)(7), a Felony, committed prior to the finding of this Indictment, and as follows:


UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly submit a claim to Comp West Workers Compensation for a health care benefit which was not used by, or on behalf of, the claimant.


* * * * *

COUNT7

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UW A YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are

accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section 5SO(a)(7), a Felony, committed prior to the finding of this Indictment, and as follows:

On and between March 1, 2011 and January 31, 2015, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly

submit a claim to Employers Insurance for a health care benefit which was not used by, or on behalf of, the claimant.


* * * * *

Exhibit 1

COUNTS

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA

TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section 550(a)(7), a Felony, committed prior to the finding of this Indictment, and as follows:

On and between March 1, 2011 and January 31, 20 15, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly submit a claim to Farmer's Insurance for a health care benefit which was not used by, or on behalf of, the claimant.


* * * * *

COUNT9

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section 550(a)(7), a Felony, committed prior to the finding


On and between March 1, 201 1 and January 31 , 2015, in the County of Los Angeles, the said MUNIR

UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly submit a claim to Fireman's Fund Insurance for a health care benefit which was not used by, or on behalf of, the claimant.


* * * * *

Exhibit 1

..

COUNT IO

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section 550(a)(7), a Felony, committed prior to the finding of this Indictment, and as follows:


UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M .D. , LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly submit a claim to ICW Group Insurance for a health care benefit which was not used by, or on behalf of, the claimant.


*****

COUNT 11

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of

INSURANCE FRAUD, in violation of Penal Code Section SSO(a)(7), a Felony, committed prior to the finding of this Indictment, and as follows:

On and between March I, 2011 and January 31, 2015, in the County of Los Angeles, the said MUNIR

UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M .D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly submit a claim to Liberty Mutual for a health care benefit which was not used by, or on behalf of, the claimant.


* * * * *

Exhibit 1

COUNT 12


TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of

INSURANCE FRAUD, in violation of Penal Code Section SSO(a)(7), a Felony, committed prior to the finding


On and between March 1, 201 1 and January 31, 2015, in the County of Los Angeles, the said MUNIR

UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER

NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly

submit a claim to Republic Indemnity for a health care benefit which was not used by, or on behalf of, the

claimant.


* * * * *

COUNT 13

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWA YDAH, PAUL TURLEY, MARIA

TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are

accused by the Grand Jury of the County of Los Angeles, State of California, by this Ind ictment, of the crime of

INSURANCE FRAUD, in violation of Penal Code Section 550(a)(7), a Felony, committed prior to the finding of this Indictment, and as follows:


UWA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE

LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly submit a claim to State Compensation Insurance Fund for a health care benefit which was not used by, or on

behalf of, the claimant.


* * * * *

Exhibit 1

COUNT 14

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set fo rth in the aforestated Count hereof, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA

TURLEY, MARISA SCHERMBECK-NELSON, PETER NE LSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ L EMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section 550(a)(7}, a Felony, committed prior to the finding of this Ind ictment, and as follows:

On and between March 1, 2011 and January 31, 2015, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, J EFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly submit a claim to Sentry Insurance for a health care benefit which was not used by, or on behalf of, the claimant.

It is further alleged that the claim or amount at issue exceeds nine hundred fi fty dollars ($950).

* * * * *

CO UNT 15

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set fo rth in the aforestated Count hereof, the said MUNIR UW A YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JE FF STEVENS, WEND EE LUKE, KE LLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section 550(a)(7), a Felony, committed prior to the finding of th is Indictment, and as fo llows:

On and between March l, 2011 and January 31, 2015, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL T URLEY, MARIA TURLEY, MARISA SCHERMBECK-NE LSON, PETER NELSON, DAVID .JOHNSON, M.D., LETICIA ALVAREZ LEMUS, J E FF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly submit a claim to State Farm Insurance for a health care benefit which was not used by, or on behalf of, the claimant.

ft is further alleged that the claim or amount at issue exceeds nine hundred fifty dollars ($950).

* * * * *

Exhibit 1

COUNT16


the charge set forth in the aforestated Count hereof, the said MUNIR UW A YDAH, PA UL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, .JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are

accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in vio lation of Penal Code Section SSO(a)(7), a Felony, committed prior to the finding


On and between March I, 20 l l and January 31, 2015, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly

submit a claim to The Hartford Insurance for a health care benefit which was not used by, or on behalf of, the

claimant.


* * * * *

COUNT 17


the charge set forth in the aforestated Count hereof, the said MUNIR UW A YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are




On and between March I, 2011 and January 31, 2015, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly

submit a claim to Travelers Company for a health care benefit which was not used by, or on behalf of, the

claimant.


* * * * *

Exhibit 1

COUNT 18


the charge set forth in the aforestated Count hereof, the said MUNIR UW A YDAH, PA UL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D.,

LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of





NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly

submit a claim to York Risk Service Group for a health care benefit which was not used by, or on behalf of, the

claimant.


* * * * *

COUNT 19


the charge set forth in the aforestated Count hereof, the said MUNIR UWA YDAH, PAUL TURLEY, MARIA







NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly submit a claim to Zenith Insurance for a health care benefit which was not used by, or on behalf of, the

claimant.


* * * * *

Exhibit 1

COUNT20

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section 550(a)(7), a Felony, committed prior to the finding of this Indictment, and as follows:

On and between March 1, 2011 and January 31, 2015, in the County of Los Angeles, the said MUNIR UW A YDAH, PA UL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly submit a claim to Zurich North America for a health care benefit which was not used by, or on behalf of, the claimant.

It is fu11her alleged that the claim or amount at issue exceeds nine hundred fifty dollars ($950).

* * * * *

COUNT21

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section SSO(a)(7), a Felony, committed prior to the finding of this Indictment, and as follows:

On and between March 1, 2011 and January 31, 20 I 5, in the County of Los Angeles, the said MUNIR

UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly submit a claim to Sedgwick Insurance Company for a health care benefit which was not used by, or on behalf of, the claimant.


* * * * *

Exhibit 1

Office Visits Counts 22-30

COUNT22


the charge set forth in the aforestated Count hereof, the said MUNIR UW A YDAH, PA UL TURLEY, MARIA

TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are


INSURANCE FRAUD, in violation of Penal Code Section SSO(a)(6), a Felony, committed prior to the finding of this Indictment, and as follows:


UWA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER

NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly make

and cause to be made a false and fraudulent claim to American Claims Management for payment of a health

care benefit.


* * * * *

COUNT23


the charge set forth in the aforestated Count hereof, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA


accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section SSO(a)(6), a Felony, committed prior to the finding



UW A YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER

NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE

LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly make and cause to be made a false and fraudulent claim to Berkshire Hathaway for payment of a health care benefit.


* * * * *

Exhibit 1

COUNT24

For a fmther and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set fo1th in the aforestated Count hereof, the said MUNIR UW A YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section 550(a)(6), a Felony, committed prior to the finding of this Indictment, and as follows:

On and between March 1, 2011 and January 31, 2015, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly make and cause to be made a false and fraudulent claim to City of Los Angeles for payment of a health care benefit.


* * * * *

COUNT25

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section SSO(a)(6), a Felony, committed prior to the finding


On and between March 1, 2011 and January 31, 2015, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly make and cause to be made a false and fraudulent claim to Fireman' s Fund Insurance for payment of a health care benefit.


* * * * *

Exhibit 1

COUNT26


TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section 550(a)(6), a Felony, committed prior to the finding of this Indictment, and as follows:

On and between March 1, 201 1 and January 31, 2015, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly make and cause to be made a false and fraudulent claim to Republic Indemnity for payment of a health care benefit.


* * * * *

COUNT27

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section 5SO(a)(6), a Felony, committed prior to the finding of this Indictment, and as follows :


UWA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly mak : and cause to be made a false and fraudulent claim to Zenith Insurance for payment of a health care benefit.


* * * * *

Exhibit 1

COUNT28

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section 550(a)(6), a Felony, committed prior to the finding of this Indictment, and as follows:

On and between March 1, 2011 and January 31, 2015, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly make and cause to be made a false and fraudulent claim to CNA Insurance for payment of a health care benefit.


*****

COUNT29

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section 550(a)(6), a Felony, committed prior to the finding


On and between March 1, 2011 and January 31, 2015, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly make and cause to be made a false and fraudulent claim to Zurich North America for payment of a health care benefit.


* * * * *

Exhibit 1

COUNT 30

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UW A YDAH, PAUL TURLEY, MARJA TURLEY, MARISA .SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section SSO(a)(6), a Felony, committed prior to the finding of this Indictment, and as follows:

On and between March 1, 2011 and January 31, 2015, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE, did aid, abet, so licit, conspire with another and did knowingly make and cause to be made a false and fraudulent claim to Liberty Mutual for payment of a health care benefit.


* * * * *

Undercover Operation Counts 31-32

COUNT31


TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section SSO(a)(S), a Felony, committed prior to the finding

of this Ind ictment, and as follows:

On and between March 13, 2013 and April 2, 2013 , in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARJA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly prepare, make and subscribe a writing, with intent to present and use it, and to allow it to be presented in

support of a false and fraudulent claim to Zenith Insurance.

* * * * *

Exhibit 1

COUNT32


TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section SSO(a)(6), a Felony, committed prior to the finding of this Indictment, and as follows:

On and between March 13, 2013 and April 2, 2013, in the County of Los Angeles, the said MUNIR

UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly make and cause to be made a false and fraudulent claim to Zenith Insurance for payment of a health care benefit.

It is fm1her alleged that the claim or amount at issue exceeds nine hundred fifty dollars ($950).

* * * * *

Surgical Billing Count 33

COUNT33

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of INSURANCE FRAUD, in violation of Penal Code Section SSO(a)(S), a Felony, committed prior to the finding of this Indictment, and as follows:

On and between March l, 2011 and February 23, 2015, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did aid, abet, solicit, conspire with another and did knowingly prepare, make and subscribe a writing, with intent to present and use it, and to allow it to be presented in support of a false and fraudulent claim for patient Jaime Frias.

* * * * *

Exhibit 1

Aggravated Mayhem Counts 34-54

COUNT 34


the charge set forth in the aforestated Count hereof, the said MUNIR UWA YDAH, PAUL TURLEY, MARIA

TURLEY, MARISA SCHERMBECK-NELSON and PETER NELSON are accused by the Grand Jury of

the County of Los Angeles, State of California, by this Indictment, of the crime of AGGRAVATED

MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the finding of this Indictment, and as follows:

On or about March 12, 2005, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY,

MARIA TURLEY, MARISA SCHERMBECK-NELSON and PETER NELSON, did unlawfully and under

circumstances manifesting extreme indifference to the physical and psychological well being of another,

intentionally caused permanent disability and disfigurement and deprivation of a limb, organ and body member of Jaime Frias.

"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section 1192.?(c) and a violent felony within the meaning of Penal Code Section 667.S(c)."

* * * * *

COUNT35


the charge set forth in the aforestated Count hereof, the said MUNIR UW A YDAH, PAUL TURLEY, MARIA

TURLEY, MARISA SCHERMBECK-NELSON and PETER NELSON, are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of AGGRAVATED

MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the finding of this

Indictment, and as follows:


MARIA TURLEY, MARISA SCHERMBECK-NELSON and PETER NELSON, did unlawfully and under

circumstances manifesting extreme indifference to the physical and psychological well being of another,

intentionally caused permanent disability and disfigurement and deprivation of a limb, organ and body member of Jane Doe.

"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section 1192.7(c) and a violent felony within the meaning of Penal Code Section 667.5(c)."

* * * * *

Exhibit 1

COUNT36

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON and PETER NELSON are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the finding of this Indictment, and as follows:

On and between May 1, 2005 and May 31, 2005, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON and PETER NELSON, did unlawfully and under circumstances manifesting extreme indifference to the physical and psychological well being of another, intentionally caused permanent disability and disfigurement and deprivation of a limb, organ and body member of Constance Hicks.

"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section l 192.7(c) and a violent felony within the meaning of Penal Code Section 667.5(c)."

* * * * *

COUNT37


TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEN DEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of AGGR.A VA TED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the

finding of this Indictment, and as fo llows:

On or about February 20, 2008, in the County of Los Angeles, the said MUNIR UW A YDAH, PAUL

TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme indifference to the physical and psychological well being of another, intentionally caused permanent disability and disfigurement and deprivation of a limb, organ and body member of Arnulfo Martinez.

"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section l l 92.7(c) and a violent felony within the meaning of Penal Code Section 667.S(c)."

* * * * *

Exhibit 1

COUNT38

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the afore stated Count hereof, the said MUNIR UW A YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, J EFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the finding of this Indictment, and as follows:


MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme indifference to the physical and psychological well being of another, intentionally caused permanent disability and disfigurement and deprivation of a limb, organ and body member of Kimberly Pope.


* * * * *

COUNT39


TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the finding of this Indictment, and as fol lows:

On or about December 9, 2009, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme indifference to the physical and psychological well being of another, intentionally caused pennanent disability and disfigurement and deprivation of a limb, organ and body member of Rigoberto Campos.

"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section 1l92.7(c) and a violent felony within the meaning of Penal Code Section 667.S(c)."

* * * * *

Exhibit 1

COUNT40

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UW A YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the finding of this Indictment, and as follows:

On or about February 17, 2010, in the County of Los Angeles, the said MUNIR UW A YDAH, PAUL

TURLEY, MARJA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme indifference to the physical and psychological well being of another, intentionally caused permanent disability and disfigurement and deprivation of a limb, organ and body member of Manuel Jimenez.

"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section 1192.7(c) and a violent felony within the meaning of Penal Code Section 667.S(c)."

* * * * *

COUNT 41

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the finding of this Indictment, and as fol lows:

On or about March 17, 2010, in the County of Los Angeles, the said MUNIR UWA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme indifference to the physical and psychological well being of another, intentionally caused permanent disability and disfigurement and deprivation of a limb, organ and body member of Jose Aguayo.

"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section 1192. 7(c) and a violent felony within the meaning of Penal Code Section 667.S(c)."

* * * * *

Exhibit 1

COUNT42

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the finding of this Indictment, and as follows:

On or about March 26, 2010, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MAIUA TURLEY, MAIUSA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme indifference to the physical and psychological well being of another, intentionally caused permanent disability and disfigurement and deprivation of a limb,

organ and body member of Jose Unda.

"NOTICE: TI1e above offense is a serious felony within the meaning of Penal Code Section l 192.7(c) and a violent felony within the meaning of Penal Code Section 667 .5( c ). "

* * * * *

COUNT 43

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime o · AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the

finding of this Indictment, and as follows:

On or about March 26, 2010, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme indifference to the physical and psychological well being of another, intentionally caused permanent disability and disfigurement and deprivation of a limb, organ and body member of Leonel Zavala-Aguilar.

"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section 11 92.7(c) and a violent felony within the meaning of Penal Code Section 667.S(c) ."

* * * * *

Exhibit 1

COUNT44


the charge set forth in the aforestated Count hereof, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DA YID JOHNSON, M.D., LETICIA ALY AREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are


AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the


On or about April 23, 2010, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALY AREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme indifference to the physical and psychological

well being of another, intentionally caused permanent disabi lity and disfigurement and deprivation of a limb,

organ and body member of Ignacio Bobadilla.

"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section l 192.7(c) and a violent felony within the meaning of Penal Code Section 667.S(c)."

* * * * *

COUNT45


the charge set forth in the aforestated Count hereof, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DA YID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are

accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the


On or about May 5, 2010, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALY AREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme indifference to the physical and psychological

well being of another, intentionally caused permanent disability and disfigurement and deprivation of a limb,

organ and body member of Jesus Illescas.


* * * * *

Exhibit 1

COUNT 46

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MAIUSA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the finding of this Indictment, and as follows:

On or about May 5, 20 I 0, in the County of Los Angeles, the said MUNIR UW A YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme indifference to the physical and psychological well being of another, intentionally caused permanent disability and disfigurement and deprivation of a limb,

organ and body member of Jose Barrera.


* * * * *

COUNT47

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UW A YDAH, PA UL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the finding of this Indictment, and as follows:

On or about May 20, 2010, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY,

MAIUA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme indifference to the physical and psychological well being of another, intentionally caused permanent disability and disfigurement and deprivation of a limb, organ and body member of K im Ingle.


* * * * *

Exhibit 1

COUNT48

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWA YDAH, PAUL TURLEY, MARJA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the finding of this Indictment, and as follows:

On or about May 28, 2010, in the County of Los Angeles, the said MUNIR UWA YDAH, PAUL TURLEY,

MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme indifference to the physical and psychological

well being of another, intentionally caused permanent disability and disfigurement and deprivation of a limb, organ and body member of Alfonso Lopez.


* * * * *

COUNT49

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR U\VA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the finding of this Indictment, and as follows:

On or about June 11, 2010, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme indifference to the physical and psychological well being of another, intentionally caused permanent disability and disfigurement and deprivation of a limb, organ and body member of Angel Lopez.


* * * * *

Exhibit 1

COUNT 50

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UW A YDAH, PA UL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are

accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the


On and between February 8, 2007 and December 31, 2008, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme

indifference to the physical and psychological well being of another, intentionally caused permanent disability

and disfigurement and deprivation of a limb, organ and body member of Mario Dominguez.


* * * * *

COUNTS!


the charge set forth in the aforestated Count hereof, the said MUNIR UW A YDAH, PA UL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are


AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the


On or about September 20, 2007, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme indifference to the physical and

psychological well being of another, intentionally caused permanent disability and disfigurement and

deprivation of a limb, organ and body member of Selvin De Leon.


* * * * *

Exhibit 1

COUNT 52

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the finding of this Indictment, and as follows:

On or about July 13, 2007, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme indifference to the physical and psychological well being of another, intentionally caused permanent disability and disfigurement and deprivation of a limb, organ and body member of Mario Paloma.


*****

COUNT53


TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the finding of this Indictment, and as follows:

On and between March 8, 2007 and December 2008, in the County of Los Angeles, the said MUNIR UWA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme indifference to the physical and psychological well being of another, intentionally caused permanent disability and disfigurement and deprivation of a limb, organ and body member of Juaquin Peirera.


* * * * *

Exhibit 1

COUNT54

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set fo1ih in the aforestated Count hereof, the said MUNIR UWAYDAH, PAUL TURLEY, MARJA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DA YID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of AGGRAVATED MAYHEM, in violation of Penal Code Section 205, a Felony, committed prior to the finding of this Indictment, and as follows:

On or about August 21, 2008, in the County of Los Angeles, the said MUNIR UW A YDAH, PA UL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did unlawfully and under circumstances manifesting extreme indifference to the physical and psychological well being of another, intentionally caused permanent disability and disfigurement and deprivation of a limb, organ and body member of Jennifer Milone.


* * * * *

Capping Counts 55-57

COUNT55

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of UNLAWFUL CLIENT OR PATIENT REFERRAL, in violation of Labor Code Section 3215, a Felony, committed prior to the finding of this Indictment, and as follows:

On and between February 23, 2012 and February 23, 201 S, in the County of Los Angeles, the said MUNIR

UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did individually, and through employees and agents, offer, deliver, receive, and accept a rebate, refund, commission, preference, patronage, dividend, discount and other consideration, whether in the form of money or otherwise, as compensation and inducement for referring clients and patients to perform and obtain services and benefits.

* * * * *

Exhibit 1

COUNT 56

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WEND EE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of UNLAWFUL CLIENT OR PATIENT REFERRAL, in violation of Labor Code Section 3215, a Felony, committed prior to the finding of this Indictment, and as follows:

On and between February 23, 2012 and February 23, 2015, in the County of Los Angeles, the said MUNIR UWA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did individually, and through employees and agents, offer, deliver, receive, and accept a rebate, refund, commission, preference, patronage, dividend, discount and other consideration, whether in the form of money or otherwise, as compensation and inducement for referring clients and patients to perform and obtain services and benefits.

* * * * *

COUNT 57

For a further and separate cause of action, being a different offense of the same class of crimes and offenses as the charge set forth in the aforestated Count hereof, the said MUNIR UWA YDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE are accused by the Grand Jury of the County of Los Angeles, State of California, by this Indictment, of the crime of UNLAWFUL CLIENT OR PATIENT REFERRAL, in violation of Labor Code Section 3215, a Felony, conunitted prior to the finding of this Indictment, and as follows:

On and between February 23, 2012 and February 23, 2015, in the County of Los Angeles, the said MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON, DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY PARK and RON CASE, did individually, and tlu·ough employees and agents, offer, deliver, receive, and accept a rebate, refund, commission, preference, patronage, dividend, discount and other consideration, whether in the form of money or otherwise, as compensation and inducement for referring clients and patients to perform and obtain services and benefits.

It is further alleged, pursuant to Penal Code 186.11 (a), that the offenses set forth in counts 1-57 are related felonies, a material element of which is fraud and embezzlement, which involve a pattern of related felony conduct, and the pattern of related felony conduct involves the taking of more than Five Hundred Thousand Dollars ($500,000).

Exhibit 1

It is fmther alleged as to Counts 1-57 that in the commission of the above offenses the said defendants MUNIR UWAYDAH, PAUL TURLEY, MARIA TURLEY, MARISA SCHERMBECK-NELSON, PETER NELSON,

DAVID JOHNSON, M.D., LETICIA ALVAREZ LEMUS, JEFF STEVENS, WENDEE LUKE, KELLY

PARK and RON CASE, with the intent to do so, took, damaged and destroyed property of a value exceeding $3,200,000, within the meaning of Penal Code Section 12022.6(a)(4).

* * * * *

Exhibit 1

DEFENDANTS BOOKING NO. BAIL RECOM'D BAIL

1. MUNIR UWA YDAH . Q'.) $'2.1 , s;w' filJ \

2. PAUL TURLEY $'Zt I $(0\ aJJ,CO

3. MARIA TURLEY d;. 21 , !?CO I {;()().co

4. MARISA SCHERMBEC~NELSON 4. 21 , 9:0, av. Q)

5. PETER NELSON q 2.l ,~1a:o.co

6. DAVID JOHNSON, M.D. 410, S°C01 Q:;().CO

7. LETICIA ALVAREZ LEMUS ~10,Siv,ao .co

8. JEFF STEVENS ~l01~1a:o.co

9. WENDEE LUKE ~l0it;a:>,tW.~

10. KELLY PARK Et10 QXJ C()).o:J I

11. RON CASE ~l0 .g:oa;n.cv I I

Exhibit 1

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

THEPEOPLEOF THESTATE OFCALWORNIA,

Plaintiff, v.

CASE NO. BA455470

01 RONNIE CASE (DOB: 04/11/1976), 02 JEFF STEVENS (DOB: 04/04/1951), and

FELON Y COMPLAINT FOR ARREST WARRANT

03 LETICIA LEMUS ALVAREZ (DOB: 02/09/1977) Defendant s ).

The undersigned is informed and believes that:

COUNT 1

On or between November 15, 2004 and February 20, 2015, in the County of Los Angeles, the crime

of CONSPIRACY TO COMMIT A CRIME, in violation of PENAL CODE SECTION 182(a)(l), a Felony,

was corrunitted by RONNIE CASE, JEFF STEVENS and LETICIA LEMUS ALVAREZ, who did unlawfully

conspire together and with another person and persons whose identity is unknown to commit the crime of

CONSPIRACY TO COMMIT A CRIME, in violation of Section 550(a)(6) of the Penal Code Code, a felony;

that pursuant to and for the purpose of canying out the objectives and purposes of the aforesaid consp iracy,

the said defendants committed the following overt act and acts at and in the County of Los Angeles:

OVERT ACTS

I. On or about November 15, 2004, MUNIR UW A YDAH and PAUL TURLEY, incorporated Frontline Medical Associates.

2. Between November 15, 2004, and February 20, 2015, in order to obtain patients for Frontline Medical Associates, MUNIR UW A YDAH and PAUL TURLEY paid "marketers" (aka "cappers") and attorneys for patient referrals.

3. Between November 15, 2004 and January 31, 2010, PETER NELSON a physician' s assistant ("PA"), admitted to PA Tom Colivas that be was doing MUNIR UW A YD AB'S "surgeries" when UW A YDAB was not present. PAUL TURLEY admitted to PA Colivas that he was aware that NELSON was doing the purported "surgeries" that UW A YDAH should have been doing.

4. Between November 15, 2004 and June 30, 2010, MUNIR UW AYDAH'S physician' s assistant, PETER NELSON, performed purported "surgical procedures" on UW A YDAH'S patients while the patients were under general anesthesia and while UW A YDAH was not present in the operating room.

Rev. 920-6/03 DA Case 37348004 Page 1 FELONY COMPLAINT FOR ARREST WARRANT

Exhibit 2

Case No. BA455470

5. Between November 15, 2004 and December 31, 2005, PETER NELSON performed invasive fraudulent "surgical procedures" on patients Hector Gonzalez, Ernesto Prado, and Rosalinda Munoz, while these patients were under general anesthesia, and while UW A YDAH was not present.

6. On March 22, 2005, after being warned by the Chief of Staff of Tustin Hospital, PETER NELSON performed an invasive fraudulent "surgical procedure" on a woman at Tustin Hospital without MUNffi UW A YDAH being present in the operating room.

7. Between March 14, 2005 and June 30, 2010, despite being notified by the Chief of Staff of Tustin Hospital against the practice of allowing NELSON to perform surgeries, and despite being notified that the California Medical Board was investigating this practice which could cause MUNIR UW A YDAH to lose his medical license, MUNJR UW A YDAB allowed and caused PETER NELSON to perform fraudulent purported "surgical procedures" on UWAYDAB'S patients while the patients were under general anesthesia and while UW A YDAH was not present in the operating room.

8. Between March 1, 2005 and May 30, 2005, PETER NELSON was introduced to Constance Hicks as "Dr. Peter," and NELSON told Constance Hicks that he performed her purported "foot surgery" at Tustin Hospital because MUNm UW A YDAH bad to leave. NELSON also introduced himself to patient Manuel Jimenez as a doctor who would perform his purported "surgery."

9. Between May 1, 2006 and December 31, 2007, MUNIR UWAYDAH and PETER NELSON performed unnecessary "surgery" on Mario Dominguez, Mario Paloma, Joaquin Pereira and Selvin De Leon, based on no objective evidence that their injuries were indicated on their pre-operative MRI's requiring the performed " surgeries."

IO. Between November 2004 and December 2015, Frontline Medical Associates, Firstline, South Bay Surgical, and other entities billed for fraudulent "surgeries" performed by PETER NELSON as if an orthopedic surgeon performed actual surgeries.

11. Between February 1, 2006, and December 31, 2008, MUNm UWAYDAB and PAUL TURLEY made an agreement with Daniel Ritzke, a worker's compensation attorney, in which Attorney Ritzke would refer bis clients to Frontline Medical Associates. The agreement included bonuses to Attorney Ritzke for each client who became a surgical candidate with additional bonuses if the client had "surgery."

12. Between February 1, 2006, and December 31, 2008, MUNIR UWAYDAH, PAUL TURLEY AND MARISA SCHERMBECK-NELSON paid cash to Attorney Daniel Hitzke in exchange for client referrals to Frontline Medical Associates.

13. From September 1, 2006, to March 30, 2010, JEFF STEVENS referred clients from Attorney Dennis Fusi's office to Frontline Medical in exchange for money.

14. Between November 15, 2004 and July 30, 2010, PAUL TURLEY and MARISSA

Rev. 920-6/03 DA Case 37348004 Page 2 Case No. BA455470 FELONY COMPLAINT FOR ARREST WARRANT

Exhibit 2

SCHERMBECK-NELSON directed Esther Ros to maintain capping lists for Frontline, which documented which attorney's office the patient came from and how much was to be paid for each patient referral.

15. Between January 1, 2007 and December 31, 2007, while he was employed at Frontline, Dr. Mills was directed by PAUL TURLEY and MARIA TURLEY to send all patients with positive MRI's to MUNm UWAYDAH for "surgery."

16. Between January 1, 2007 and December 31, 2010, MUNffi UWAYDAB, PAUL TURLEY and MARIA TURLEY directed Susan Moreno to alter doctors' notes and reports in order to get "surgery" requests authorized by insurance companies. She was paid monetary bonuses by MARISA SCHERMBECKNELSON on behalf of Frontline Medical Associates.

17. Between January 1, 2007 and June 30, 2010, KELLY PARK and RONNIE CASE and other co-conspirators, planned to and did falsify documents in preparation for MUNIR UW A YDAH'S defense in a California Medical Board investigation.

18. On March 26, 2007, Golden State Pharmaceuticals was incorporated by MARISA SCHERMBECK-NELSON in order to serve Frontline patients exclusively.

19. Between June 2007 to March 2008, MUNffi UWAYDAH told Greg Redding, a pharmacist, that he owned Golden State Pharmacy but he did not have it recorded in bis name because California State law prohibits physicians from owning a pharmacy.

20. Between November 2004 to December 2015, MUNffi U\VAYDAH, WENDEE LUKE, KELLY PARK, LETICIA ALVAREZ LEMUS, and other coconspirators over-prescribed and over-billed insurance companies for pharmaceuticals.

21. Between September 11, 2007 and December 2010, under the direction ofMUNm UWAYDAH and PAUL TURLEY, Frontline Medical Associates and Golden State Pharmaceuticals used Dr. Mills' name for prescribing medications and billing without bis knowledge, consent or authorization.

22. Between January 1, 2009 and December 31, 2010, KELLY PARK and Kim Park prepared bills for Golden State Pharmaceuticals under the direction of MUNIR UWAYDAH.

23. On April 17, 2007, South Bay Surgical Center was incorporated by MUNIR UWAYDAH, MARISA SCHERMBECK-NELSON and Shelly Rosekelly, for the purpose of performing purported "surgeries" on Frontline patients.

24. In 2009, California MRI was incorporated, with JEFF STEVENS as the owner. The business was physically located in a trailer behind Frontline Medical Associates' San Fernando clinic in order to exclusively serve Frontline patients.

25 . Between January 1, 2009 and June 30, 2010, MARIA TURLEY told Delmy Martinez to refer all patients with minor medical issues for "surgery"

Rev. 920-6/03 DA Case 37348004 Page 3 Case No. BA455470 FELONYCOiWPLAINTFORARRESTWARRANT

Exhibit 2

authorization and to refer them only to South Bay Surgical.

26. Between January 1, 2009 and June 30, 2010, MARIA TURLEY directed Delmy Martinez to only include positive MRI's when seeking insurance company approval for "surgeries."

27. Between August 21, 2008 and December 31, 2010, MUNffi UWAYDAH, KELLY PARK and other co-conspirators planned to and did create a false arbitration agreement in the name of Jennifer Milone.

28. Between August 1, 2008 and December 31, 2014, MUNIR UW A YDAH caused a fraudulent billing to be filed for payment for services rendered to patient Jennifer Milone.

29. On February 23, 2010, Firstline Health, Inc. was incorporated and took over Frontline operations.

30. On or between February 23, 2010, to December 31, 2011, PAUL TURLEY, WENDEE LUKE and DAVID JOHNSON created U.S Health and Orthopedics, as a DBA of Firstline Health, Inc.

31 . Between January I, 2009 and December 31, 2010,MUNffi UWAYDAH, PAUL TURLEY, KELLY PARK, JEFF STEVENS, TATIANA ARNOLD, Ronnie Case, and other co-conspirators, attempted to become the majority shareholders in Ventura County Business Bank, and did buy shares in the bank.

32. On February 23, 2010, Firstline Health, Inc. was incorporated by TATIANA ARNOLD, MUNIR UW A YDAH'S personal lawyer, and took over Frontline Medical operations. On April 18, 2013, Firstline Health filed a Statement of Information with the California Secretary of State which listed TA TIANA ARNOLD as the Assistant Treasurer ofFirstline Health.

33. On or between February 2010, to August 2015, TATIANA ARNOLD, WENDEE LUKE and TERRY LUKE wired money from Firstline bank accounts and/or related bank accounts to Estonia, Lebanon, and other countries

34. Between February 10, 2010 and August 2015, TATIANA ARNOLD and Terry Luke made payments to Yolanda Groscost and/or YDG Marketing, and to Tony Folgar and/or AGD Marketing, or caused these payments to be made.

35. Between June 1, 2010 and December 31, 2011, Leticia Alvarez Lemus, Delmy Martinez and Jose Trujillo forged and/or wrote David Johnson's name on prescriptions for medications.

36. On June 17, 2010, KELLY PARK and RONNIE CASE transported 921 prescription containers worth approximately $82,000 street value from their home. These prescription bottles were labeled with names of patients from Golden State Pharmaceuticals and Frontline Medical Associates.

3 7. Between June 22, 2007 and March 31, 2011, LETICIA ALVAREZ LEMUS and Victor Alvarez rented a storage unit in Mission Hills wherein they stored approximately 4500 containers of both controlled and non-controlled substances

Rev. 920-6/03 DA Case 37348004 Page 4 Case No. 8A455470 FELONY COMPLAINT FOR ARREST WARRANT

Exhibit 2

from LA Health Care Partners, Frontline, Firstline and/or Golden State Pharmaceuticals.

38. Between March 6, 2013 and August 31, 2015, Firstline Health and related entities filed false bills with Zenith Insurance Company for patient Eddie Martinez.

39. Between May 8, 2013, and December 31, 2014, DAVID JOHNSON and Frontline/Firstline Medical billed insurance companies for office visits which DAVID JOHNSON did not perform and for which be was not present.

40. Between January 1, 2014 and January 15, 2015, PAUL TURLEY told David Keller that MUNm UW A YDAH and PAUL TURLEY were still involved in business together, even though MUNffi UW A YDAH was in Lebanon, that they were collecting on liens through U.S. Health and Orthopedics and that their involvement in the business was "silent."

41 . Between January 1, 2014 and January 15, 2015, PAUL TURLEY solicited David Keller to engage in a capping scheme.

42. Between January 1, 2014 and February 28, 2015, MARIA TURLEY traveled to Beirut, Lebanon to meet \vith MUNm UW A YDAH. While in Lebanon, she executed three quitclaim deeds, one to Wicklow Holdings, Inc., whose Officers included PAUL TURLEY, TATIANA ARNOLD and WENDEE LUKE, one to Connemara Holdings, Inc., and one to Notre Dame Properties L.L., whose Officers included PAUL TURLEY and TATIANA ARNOLD.

43. Between September 14, 2015 and October 17, 2015, Liberty Mutual and Zenith Insurance received medical billings for Dr. David Johnson for services rendered while he was in custody in the Los Angeles County Jail.

44. On January 21, 2016, Secretary of State documents were flied in Nevada for an ·active corporation and an LLC for Frontline Medical Associates, Inc., listing "MUNIR OUWAYDAH" (UWAYDAH) as the President, Treasurer and Director, along with Matt Rifat as Secretary.

45. On January 21, 2016, Secretary of State documents were filed in Nevada for an active corporation and an LLC for Firstline Medical Associates, Inc., listing David Johnson as the President, Treasurer and Director, along with Matt Rifat as Secretary.

46. Between February 17, 2012 and January 17, 2017, PETER NELSON and MARISSA SCHERMBECK-NELSON misrepresented to the U.S. Bankruptcy Trustee their relationship to MUNIR UWAYDAH and UWAYDAH controlled entities.

47. On or about February 20, 2014, PETER NELSON and MARISSA SCBER.MBECK-NELSON caused assets to be transferred for the price of $40,000 to a UW A YDAH controlled entity during bankruptcy proceedings.

48. Between June 14, 2013 and August 26, 2016, PAUL TURLEY, Ronnie Case, California Company, L.L.C., and other co-conspirators, on behalf of MUNIR UW A YDAH, sued Ventura County Business Bank and Royal Business Bank to

Rev. 920-6/03 DA Case 37348004 Page 5 Case No. BA455470 FELONYCOMPLAINTFORARRESTWARRANT

Exhibit 2

recover alleged financial losses.

49. Between November 15, 2004 and March 16, 2017, PAUL TURLEY, MUNIR UWAYDAB, MARISA SCHERMBECK-NELSON, TATIANA ARNOLD, TERRY LUKE, and other Co-Conspirators established lien collection companies including, but not limited to, Ventura Business Collections and Controlled Health Management, which collected liens for fraudulent billings from UW A YD AB-controlled entities.

50. Between 2008 and 2015, PAUL TURLEY, MARIA TURLEY, PETER NELSON, MARISSA SCHERMBECK-NELSON, KELLY PARK, TATIANA ARNOLD, and other co-conspirators filed California tax returns that did not accurately reflect their relationship with, or income from, Frontline Medical Associates, Firstlioe Health, or related entities.

51 . Between November 2004 and March 2017, MUNIR UW A YDAH and other coconspirators, caused false or fraudulent lawsuits to be filed.

* * * * *

SURGICAL BILLING FRAUD

COUNT2

On or about March 12, 2005 and February 26, 2015, in the County of Los Angeles, the crime of

INSURANCE FRAUD, in violation of PENAL CODE SECTION 550(a)(6), a Felony, was committed by

RONNIE CASE, JEFF STEVENS and LETICIA LEMUS ALVAREZ, who did aid, abet, solicit, conspire

with another and did knowingly make and cause to be made a false and fraudulent claim for payment of a

health care benefit.

(Jaime Frias)

*****


Exhibit 2

COUNT 3






(Kimberly Pope)

*****

COUNT4

On or about December 9, 2009 and February 25, 2015, in the County of Los Angeles, the crime of

INSURANCE FRAUD, in violation of PENAL CODE SECTION 5SO(a)(6), a Felony, was conunitted by




(Jose Aguayo)

* * * * *

COUNTS





health care benefit. (Jose Barrera)


*****


Exhibit 2

Case No. BA455470

COUNT6

On or about May 28, 2010 and February 25, 2015, in the County of Los Angeles, the crime of




health care benefit. (Alfonzo Lopez)


PHARMACEUTICAL BILLING FRAUD

COUNT7

On or between March 1, 2011 and January 31, 2015, in the County of Los Angeles, the crime of


RONNIE CASE, JEFF STEVENS, and LETICIA LEMUS ALVAREZ, who did aid, abet, solicit, conspire

with another and did knowingly make and cause to be made a false and fraudulent claim for payment of a . .

health care benefit. (American Claims Management)


*****

Rev. 920-6103 DA Case 37348004 Page 8 FELONY COMPLAJNT FOR ARREST WARRANT

Exhibit 2

Case No. BA455470

COUNTS





health care benefit. (Berkshire Hathaway)


*****

COUNT9



RONNIE CASE, JEFF STEVENS, and LETICIA LEMUS ALY AREZ, who did aid, abet, solicit, conspire


health care benefit. (CAN Insurance)


*****

COUNT IO

On or between March l, 2011 and January 31, 2015, in the County of Los Angeles, the crime of

fNSURANCE FRAUD, in violation of PENAL CODE SECTION 550(a)(6), a Felony, was committed by

RONNIE CASE, JEFF STEVENS, and LETICIA LEMUS ALVAREZ, who did aid. abet, solicit, conspire


health care benefit. (City of Los Angeles)


*****

Rev. 920-6/03 DA Case 37348004 Page 9 FELONYCOMPLAINTFORARRESTWARRANT

Exhibit 2

Case No. BA455470

COUNT 11





health care benefit. (Comp West)


*****

COUNT12





health care benefit. (Employer's Insurance)


*****

COUNT 13





health care benefit. (Farmer's Insurance)


• * * * ...

Rev. 920-6/03 DA Case 37348004 Page 10 Case No. BA455470 FELONY COMPLAINT FORARRESTWARRANT

Exhibit 2

COUNT14





health care benefit. (Fireman's Fund Insurance)


• • * * ...

COUNT 15





health care benefit. (ICW Group Insurance)


COUNT 16


INSURANCE FRAUD, in violation of PENAL CODE SECTION 5SO(a)(6), a Felony, was committed by



health care benefit. (Liberty Mutual Insurance)

It is further alleged that the claim or amount at issue exceeds nine hundred fifty dollars ($950) .

... ... * "' ...


Exhibit 2

COUNT17



RONN£E CASE, JEFF STEVENS, and LETICIA LEMUS ALVAREZ, who did aid, abet, solicit, conspire


health care benefit. (Republic Indemnity)


*****

COUNTl8



RONN£E CASE, JEFF STEVENS, and LETICIA LEMUS ALVAREZ, who did aid, abet, solicit, conspire


health care benefit. (Sedgwick Insurance)


*****

COUNT 19





health care benefit. (Sentry Insurance)


* * • • ...


Exhibit 2

COUNT20





health care benefit. (State Compensation Insurance Fund)


COUNT21





health care benefit. (State Farm)


... * * * *

COUNT22

On or between March I , 2011 and January 31, 2015, in the County of Los Angeles, the crime of




health care benefit. (The Hartford Insurance)


...........


Exhibit 2

COUNT23


fNSURANCE FRAUD, in violation of PENAL CODE SECTION 550(a)(6), a Felony, was committed by


with another and did knowingly make and cause to be made a fal se and fraudulent claim for payment of a

health care benefit. (Traveler's Insurance)


COUNT24





health care benefit. (York Risk Services Group)


COUNT25





health care benefit. (Zenith Insurance)


•••••

Rev. 920-6/03 DA Case 37348004 Page 14 Case No. BA455470 FELONY COMPLAINT FOR ARREST JV ARRANT

Exhibit 2

COUNT26





health care benefit. (Zurich North America)


* ... • * * OFFICE VISIT BILLING FRAUD

COUNT27





health care benefit. (American Claims Management)


* * * * *

COUNT28

On or between March 1, 2011 and January 31, 2015, in the CoWlty of Los Angeles, the crime of






*. * * *

Rev. 920-6/03 DA Case 37348004 Page 15 Case No. BA455470 FELONY COMPLAINT FOR ARREST WAR.RANT

Exhibit 2

COUNT29





health care benefit. (City of Los Angeles)


*****

COUNT30

On or about March 1, 2011 and January 31, 2015, in the County of Los Angeles, the crime of

INSURANCE FRAUD, in violation of PENAL CODE SECTION 550(a)(6), a Felony, was conunitted by



health care benefit. (Fireman's Fund)


* * * * *

COUNT 31


INSURANCE FRAUD, in violation of PENAL CODE SECTION 550(a)(6), a Felony, was conunitted by



health care benefit. (Liberty Mutual)


*****

Rev. 920-6/03 DA Case 37348004 Page 16 Case No. BA4554 70 FELONY COMPLAINT FOR ARREST WARRANT

Exhibit 2

COUNT32





health care benefit. (Republic Indemnity)


*****

COUNT33





health care benefit. (The Hartford Insurance)


*****

COUNT 34







* * ... * *


Exhibit 2

COUNT35

On or between March I, 2011 and January 31, 2015, in the County of Los Angeles, the crime of

INSURANCE FRAUD, in violation of PENAL CODE SECTION 550(a)(6), a Felony, was corrunitted by



health care benefit. (York Risk Services Group)


*****

COUNT36





health care benefit. (Zenith Insurance)


JOHNSON SURVEILLANCE BILLING FRAUD

COUNT37

On or between May 28, 2013 and June 10, 2013, in the County of Los Angeles, the crime of






*****


Exhibit 2

COUNT38

On or between May 28, 2013 and July 4, 2013, in the County of Los Angeles, the crime of

INSURANCE FRAUD in violation of PENAL CODE SECTION 550(a)(6), a Felony, was committed by





*****

UNDERCOVER OPERATION BILLING FRAUD

COUNT39

On or between March 6, 2013 and April 30, 2013, in the County of Los Angeles, the crime of



with another and did knowingly prepare, make and subscribe a writing, with intent to present and use it, and

to allow it to be presented in support of a false and fraudulent claim. (Zenith Insurance DOS: 3/6/13; Billed

3/14/13)

* * * * *

COUNT40

On or between April 3, 2013 and April 30, 2013, in the County of Los Angeles, the crime of




to allow it to be presented in support of a false and fraudulent claim. (Zenith Insurance DOS: 4/3113; Billed

4/15/13)

*****


Exhibit 2

Case No. BA455470

..

COUNT41

On or between May 8, 2013 and June 30, 2014, in the County of Los Angeles, the crime of




to allow it to be presented in support of a false and fraudulent claim. (Zenith Insurance DOS: 5/8/13; Billed

6/ 13/ 14)

* * * * *

COUNT42

On or between July 19, 2013 and August 31, 2015, in the County of Los Angeles, the crime of




to allow it to be presented in support of a false and fraudulent claim. (Zenith Insurance; DOS: 7/ 19/ l 3; Billed:

8/25/ 15)

***** UNLAWFUL PATIENT REFERRAL ("CAPPING") FRAUD

COUNT43

On or between February 23, 2012 and February 23, 2015, in the County of Los Angeles, the crime of

FALSE AND FRAUDULENT CLAIM, in violation of PENAL CODE SECTION 549, a Felony, was

committed by RONNIE CASE, JEFF STEVENS, and LETICIA LEMUS ALVAREZ, who did unlawfully

solicit, accept and refer business to and from an individual and entity with knowledge that, and with reckless

disregard for whether, the individual and entity for and from whom the solicitation and referral is made, and

the individual and entity who is solicited and referred, intended to violate Penal Code section 550 and the

Insurance Code section 1871.4.

* * * * *


Exhibit 2

Case No. BA455470

COUNT44



committed by RONNIE CASE, JEFF STEVENS, and LETICIA LEMUS ALVAREZ, who did unlawfully





* * * * *

COUNT45



conunitted by RONNIE CASE, JEFF STEVENS, and LETICIA LEMUS ALVAREZ, who did unlawfully





It is further alleged, pursuant to Penal Code section 186. l l(a), that the offenses set forth in counts

ONE THROUGH FORTY-FIVE are related felonies, a material element of which is fraud and embezzlement,

which involve a pattern of related felony conduct, and the pattern of related felony conduct involves the

taking of more than Five Hundred Thousand Dollars ($500,000).

It is further alleged that in the commission of the above offense(s) the said defendant(s), RONNIE CASE,

JEFF STEVENS and LETICIA LEMUS ALVAREZ, with the intent to do so, took, damaged and destroyed

property of a value exceeding $3,200,000, within the meaning of Penal Code Section 12022.6(a)(4).

It is further alleged as to count(s) 1 THROUGH 45, offenses described in Penal Code section 803(b), that no time during which prosecution of the same conduct is pending in a court of this state is a part of a limitation of time prescribed in this chapter under section 803(b) and that the People originally filed under the same facts and conduct in case BA425397 and BA435339 on September 15, 2015, and re-filed on the present case.

Rev. 920-6/03 DA Case 37348004 Page 21 Case No. BA455470 FELONYCOMPLAINTFORARRESTWARRANT

Exhibit 2

NOTICE: T he People of the State of California intend to present evidence of other incidents where Defendants RONNIE CASE, JEFF STEVENS AND LETICIA LEMUS ALVAREZ, along with coconspirators committed the same crimes alleged in this Complaint, civil wrong or other act when relevant to prove some fact (such as motive, opportunity, intent, preparation, plan, knowledge, identity or absence of mistake or accident...) other than his or her disposition to commit such an act, pursuant to Evidence Code Section l lOl (b).

NOTICE: The People of the State of California request reciprocal discovery pursuant to Penal Code Section 1054.3.

NOTICE: Conviction of this offense will require the defendant to provide DNA samples and print

impressions pursuant to Penal Code sections 296 and 296.1. Willful refusal to provide the samples and

impressions is a crime.

NOTICE: The People of the State of California intend to present evidence and seek jury findings

regarding all applicable circumstances in aggravation, pursuant to Penal Code section ll 70(b) and

Cr11111i11gliam v. California (2007) 549 U.S. 270.

NOTICE: A Suspected Child Abuse Report (SCAR) may have been generated within the meaning of

Penal Code §§ 11166 and 11168 involving the charges alleged in this complaint. Dissemination of a

SCAR is limited by Penal Code§§ 11167 and 11167.5 and a court order is required for full disclosure of

the contents of a SCAR.

NOTICE: Any allegation making a defendant ineligible to serve a state prison sentence in the county

jail shall not be subject to dismissal pursuant to Penal Code § 1385.

NOTICE: Conviction of this offense prohibits you from owning, purchasing, receiving, possessing, or

having under your custody and control any firearms, and effective January 1, 2018, will require you to

complete a Prohibited Persons Relinquishment Form ("PPR") pursuant to Penal Code§ 29810.

Rev. 920-6/03 DA Case 37348004 Page 22 Case No. BA4554 70 FELONY COMPLAJNTFORARREST WARRANT

Exhibit 2

Further, attached· hereto and incorporated herein are official reports and documents of a law enforcement agency which the undersigned believes establish probable cause for the arrest of defendant(s) RONNIE CASE, JEFF STEVENS, LETICIA LEMUS ALVAREZ for the above-listed crimes. Wherefore, a warrant of arrest is requested for RONNIE CASE, JEFF STEVENS, LETICIA LEMUS ALVAREZ.

I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT AND THAT THIS COMPLAINT, CASE NUMBER BA455470, CONSISTS OF 45 COUNT(S).

Executed at LOS ANGELES, County of Los Angeles, on March 16, 2017.

JACKlE LACEY, DISTRICT ATTORNEY

ROBERT T MC CR.ILLIS DECLARANT AND COMPLAINANT

AGENCY: LACO D.A. VO: ROBERT T MC ID NO.: 434172 PHONE: BUREAU OF CRJLLIS INVESTIGATION

DR NO.: 2010F2096 OPERATOR: MT PRELIM. TIME EST.: 12 WEEK(S)

BOOKING BAIL CUSTODY DEFENDANT CIINQ. DOB NO. RECOM'D B.'TNDAI& CASE, RONNIE 4/11/I 976 1,435,000

STEVENS, JEFF 4/4/ 1951 1,435,000

LEMUS ALY AREZ, LETICIA 2/911977 1,435,000


Exhibit 2

It appearing to the Court that probable cause exists for the issuance of a warrant of arrest for the above-named defendant(s), the warrant is so ordered.

RONNIE CASE

JEFF STEVENS

LETICIA LEMUS ALVAREZ

DATE: Judge of the Above Entitled Court


Exhibit 2

NON-WARRANT DEFENDANTS:

DEFENDANT CIINO.

Rev. 920-6/03 DA Case 37348004 Page 25

BOOKING NO.

FELONY COMPLAINT FOR ARREST WARRANT

Exhibit 2

BAIL CUSTODY RECOM'D R'TN DATE

Case No. BA455470

FELONY COMPLAINT -- ORDER HOLDING TO ANSWER - P.C. SECTION 872

It appearing to me from the evidence presented that the following offense(s) has/have been committed and that there is sufficient cause to believe that the following defendant(s) guilty thereof, to wit:

(Strike out or add as applicable)

RONNIE CASE Ct. Charge Charge Range All~gi!tion 6.lleg. Effect I PC 182(a)(l) Check Code County Jail PC +4 Yrs County

12022.6(a)(4) Jail PC 186.11 (a}(2) +2-3-5 State

Prison 2 PC 550(a)(6) County Jail PC 186.11 (a)(2) +2-3-5 State


Prison 4 PC 550(a)(6) County Jail PC 186.11 (a){2) +2-3-5 State

Prison 5 PC 550(a)(6) 2-3-5 County Jail PC !86.l l(a)(2) +2-3-5 State

Prison 6 PC 550(a)(6) 2-3-5 County Jail PC 186.l l (a)(2) +2-3-5 State

Prison 7 PC 550(a)(6) 2-3-5 County Jail PC 186. l l (a){2) +2-3-5 State

Prison 8 PC 550(a)(6) 2-3-5 County Jail PC 186.l l{a){2) +2-3-5 State

Prison 9 PC 550(a)(6) 2-3-5 County Jail PC 186. l l (a)(2) +2-3-5 State

Prison IO PC 550(a)(6) 2-3-5 County Jail PC 186.11 (a)(2) +2-3-5 State

Prison 11 PC 550(a)(6) 2-3-5 County Jail PC 186. l l (a)(2) +2-3-5 State

Prison 12 PC 550(a)(6) 2-3-5 County Jail PC 186.l l (a)(2) +2-3-5 State

Prison 13 PC 550(a)(6) 2-3-5 County Jail PC 186.l l(a)(2) +2-3-5 State


Prison 15 PC 550(a)(6) 2-3-5 County Jail PC 186.l 1(a)(2) +2-3-5 State

Prison 16 PC 550(a)(6) 2-3-5 County Jail PC 186.ll(a)(2) +2-3-5 State

Prison 17 PC 550(a)(6) 2-3-5 County Jail PC 186.11 (a)(2) +2-3-5 State


Prison 19 PC 550(a)(6) 2-3-5 County Jail PC 186. ll(a)(2) +2-3-5 State

Prison 20 PC 550(a)(6) 2-3-5 County Jail PC 186.11 (a)(2) +2-3-5 State


Prison


Exhibit 2

22 PC 550(a)(6) 2-3-5 County Jail PC 186.11 (a)(2) +2-3-5 State Prison

23 PC 550(a)(6) 2-3-5 County Jail PC 186.l l(a)(2) +2-3-5 State Prison




27 PC 550(a)(6) 2-3-5 County Jail PC 186. l l(a)(2) +2-3-5 State Prison



30 PC 550(a)(6) 2-3-5 County Jail PC 186.1 l(a)(2) +2-3-5 State Prison

31 PC 550(a)(6) 2-3-5 County Jail PC l 86. l l(a)(2) +2-3-5 State Prison

32 PC 550(a)(6) 2-3-5 County Jail PC l 86.1J(a)(2) +2-3-5 State Prison

33 PC 550(a)(6) 2-3-5 County Jail PC l86.ll(a)(2) +2-3-5 State Prison






39 PC 550(a)(5) 2-3-5 County Jail PC 186.ll(a)(2) +2-3-5 State Prison



42 PC 550(a)(5) 2-3-5 County Jail PC 186. l l (a)(2) +2-3-5 State Prison

43 PC549 16-2-3 County Jail PC 186.ll(a)(2) +2-3-5 State Prison

44 PC549 16-2-3 County Jail PC 186. l l(a)(2) +2-3-5 State Prison

45 PC 549 16-2-3 County Jail PC 186.ll(a)(2) +2-3-5 State Prison

JEFF STEVENS Q,_ Charge Charge Range Allegation A!leg. t;ffe!;;t 1 PC 182(a){l) Check Code County Jail PC +4 Yrs County

12022.6(a)(4) Jail PC 186.11 (a)(2) +2-3-5 State

Prison 2 PC 550(a){6) County Jail


Exhibit 2

3 PC 550(a)(6) County Jail PC 186.11 (a)(2) +2-3-5 State Prison

4 PC 550(a)(6) County Jail PC 186.l l (a)(2) +2-3-5 State Prison

5 PC 550(a)(6) 2-3-5 County Jail PC 186. I l(a)(2) +2-3-5 State Prison


7 PC 550(a}(6} 2-3-5 County Jail PC 186.11 (a)(2) +2-3-5 State Prison


9 PC 550(a)(6) 2-3-5 County Jail PC l 86.l l {a)(2) +2-3-5 State Prison

JO PC 550(a)(6) 2-3-5 County Jail PC 186.l l (a){2) +2-3-5 State Prison



13 PC 550(a)(6) 2-3-5 County Jail PC 186.l l (a)(2) +2-3-5 State Prison


15 PC 550(a)(6) 2-3-5 County Jail PC 186.1 l (a)(2) +2-3-5 State Prison


17 PC 550(a)(6) 2-3-5 County Jail PC 186. l I (a)(2) +2-3-5 State Prison

18 PC 550(a)(6) 2-3-5 County Jai l PC 186. l l (a)(2) +2-3-5 State Prison






24 PC 550(a)(6) 2-3-5 County Jail PC l86.l l(a)(2) +2-3-5 State Prison




28 PC 550(a)(6) 2-3-5 County Jail PC 186. l l(a)(2) +2-3-5 State

29 PC 550(a)(6) 2-3-5 County Jail Prison

PC 186. ll (a)(2) +2-3-5 State


PC 186.1 l(a)(2) +2-3-5 State Prison


Exhibit 2


32 PC 550(a){6) 2-3-5 County Jail PC !86.l l{a)(2) +2-3-5 State Prison

33 PC 550(a){6) 2-3-5 County Jail PC 186.ll(a)(2) +2-3-5 State Prison



36 PC 550(a)(6) 2-3-5 County Jail PC 186.1 l (a)(2) +2-3-5 State Prison



39 PC 550(a){5) 2-3-5 County Jail PC 186.l l{a)(2) +2-3-5 State Prison


41 PC 550(a){5) 2-3-5 County Jail PC 186.l l(a)(2) +2-3-5 State Prison

42 PC 550(a){5) 2-3-5 County Jail PC l86.l l(a)(2) +2-3-5 State Prison

43 PC 549 16-2-3 County Jail PC 186. I l (a)(2) +2-3-5 State Prison

44 PC 549 l 6-2-3 County Jail PC 186.11 (a)(2) +2-3-5 State Prison

45 PC 549 16-2-3 County Jail PC 186. 1 l (a)(2) +2-3-5 State Prison

LETICIA LEMUS ALVAREZ Ct. Charge Charge Range Allegation Alleg. Effect I PC l82(a){I) Check Code County Jail PC +4 Yrs County

12022.6(a)(4) Jail PC 186.l l{a){2) +2-3-5 State


Prison 3 PC 550(a)(6) County Jail PC 186.1 1 (a)(2) +2-3-5 State

Prison 4 PC 550(a)(6) County Jail PC 186.l l(a)(2) +2-3-5 State

Prison 5 PC 550(a)(6) 2-3-5 County Jail PC 186.11 {a)(2) +2-3-5 State

Prison 6 PC 550(a)(6) 2-3-5 County Jail PC 186.1 l{a)(2) +2-3-5 State


Prison 8 PC 5SO(a)(6) 2-3-5 County Jail PC I 86. l l(a)(2) +2-3-5 State

Prison 9 PC 550(a)(6) 2-3-5 County Jail PC 186. l l(a)(2) +2-3-5 State



Prison

Rev. 920-6/03 DA Case 37348004 Page29 Case No. BA455470 FELONYCOMPLAINTFORARRESTWARRANT

Exhibit 2

12 PC 550(a)(6) 2-3-S County Jail PC l 86.1 l(a)(2) + 2-3-5 State Prison

13 PC 550(a)(6) 2-3-S County Jail PC I 86. ll(a)(2) +2-3-5 State Prison

14 PC 550(a)(6) 2-3-5 County Jail PC 186. ll(a)(2) +2-3-5 State Prison

15 PC 550(a)(6) 2-3-5 County Jail PC l 86. ll(a)(2) +2-3-5 State Prison

16 PC 5SO(a)(6) 2-3-S County Jail PC 186.ll(a)(2) +2-3-S State Prison

17 PC S50(a)(6) 2-3-S County Jail PC 186. 11 (a)(2) +2-3-5 State Prison



20 PC 5SO(a)(6) 2-3-5 County Jail PC 186. l l(a)(2) +2-3-5 State Prison


22 PC 550(a}(6) 2-3-5 County Jail PC 186.11 (a)(2) +2-3-5 State Prison



25 PC 550(a)(6) 2-3-5 County Jail PC I 86.1 l(a)(2) +2-3-5 State Prison

26 PC 550(a)(6) 2-3-5 County Jail PC 186.1 1 (a)(2) +2-3-5 State Prison



29 · PC 550(a)(6) 2-3-5 County Jail PC 186.11 (a){2) +2-3-5 State Prison

30 PC 550(a)(6) 2-3-5 County Jail PC 186. l l(a)(2) +2-3-5 State


PC 186.1 l (a)(2) +2-3-5 State


PC 186.11 (a)(2) +2-3-5 State


PC 186.11 (a)(2) +2-3-5 State Prison

34 PC 550(a)(6) 2-3-5 County Jail PC 186.1 l{a)(2) +2-3-5 State


PC 186.11 (a)(2) +2-3-5 State Prison

36 PC 550(a)(6) 2-3-5 County Jail PC 186.ll(a)(2) +2-3-5 State

37 PC 550(a){5) 2-3-5 County Jail Prison

PC 186. l l(a)(2) +2-3-5 State Prison




Exhibit 2


41 PC 550(a)(5) 2-3-5 County Jail PC 186.l I{a)(2) +2-3-5 State Prison

42 PC 550{a){5) 2-3-5 County Jail PC 186.1 l(a)(2) +2-3-5 State Prison

43 PC 549 16-2-3 County Jail PC l86.l l(a)(2) +2-3-5 State Prison

44 PC 549 16-2-3 County Jail PC 186.ll(a)(2) +2-3-5 State Prison

45 PC 549 16-2-3 County Jail PC 186.l l(a)(2) +2-3-5 State Prison

I order that the defendant(s) be held to answer therefore and be admitted to bail in the sum of:

RONNIE CASE

JEFF STEVENS


and be committed to the custody of the Sheriff of Los Angeles County until such bail is given. Date of arraigrunent in Superior Court will be:

.RONNIE CASE

JEFF STEVENS


at: _ ____ A.M.

Date: ------Committing Magistrate


Exhibit 2

Case No. BA4554 70

Exhibit 3

Documents

DOCUMENT INDEX In re: FIRSTLINE HEALTH INC. … · persons who identity is unknown to commit the crime of Insurance ... Selvin De Leon because ... and MARIA TURLEY directed Susan