SUPERIOR COURT OF CALIFORNIA COUNTY OF RIVERSIDE Quynam... · CARY DAVID ABRAMOWITZ agreed with and allowed PEYMAN HEIDARY, a non-attorney, to exert actual control over California

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MICHAEL A. HESTRIN

District Attorney

County of Riverside

3960 Orange Street, First Floor

Riverside, California 92501

Telephone: (951) 955-5400

John Aki

Chief Assistant District Attorney

State Bar No. 189395

BAIL: Touba Pakdel-Nabati $12,402,000.00

Quynam Nguyen

Jason Yang

$12,402,000.00

$12,402,000.00

IF. ~ [b ~ [Q) SUPERIOR COURT OF CALIFORNIA

COUNTY OF RIVERSIDE

MAY 1 6 ·2016 J ~'ftn .. .s.~·

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SUPERIOR COURT OF CALIFORNIA

COUNTY OF RIVERSIDE

(Riverside)

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16 . THE PEOPLE OF THE STATE OF CALIFORNIA, NO. RI'(:: /{D']Qj/"/{O

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21 TOUBA PAKDEL..:NABATI

22 DOB: 08/03/1978

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24 QUYNAM NGUYEN

25 DOB: 06/11/1958:·

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27 JASON YANG

28 DOB: 02/24/1966

Plaintiff,

29 Defendants. ·

30 ·COUNT 1

INDICTMENT

AGENCY#: DAR2012258005/RDA

31 The Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses

32 TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and JASON YANG of a violation of

33 Penal Code section 182, subdivision (a), subsection (1), a felony, in that on or about January 1,

34 2009 through and inciuding July 15, 2014, in the County of Riverside, State of California, they

35 did willfully and unlawfully conspire together and with another person and persons whose

36 identity is unknown to commit the crime of KNOWINGLY MAKING OR CAUSING TO BE

MICHAEL A. HESTRIN

DISTRICT A ITORNEY

County or Riverside State of California

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MICHAEL A. HESTRIN

DISI'RICT ATIURNEY

County of Riverside State of California

MADE ANY FALSE OR FRAUDULENT CLAIMS FOR PA YMENt OF HEALTH CARE

BENEFITS, in violation of Penal Code section 550, subdivision (a), subsection (6), a felony,

and that pursuant to ·and for the purpose of carrying but the obj~cts and purposes of the

. aforesaid conspiracy, the said defendants thereafter committed the following ~vert act and acts

at and in the County of Riverside:

OVERT ACT NO. 1

CARY DAVID ABRAMOWITZ agreed with and allowed PEYMAN HEIDARY, a

non-attorney, to exert actual control over California Injury Lawyers, AKA Orange County Law

Group, and AKA South Western Law Group (collectively "the Law Finn::'). PEYMAN ··' - .

· HEID ARY controlled ·day-to-day operations including scheduling, hiring and firing.

OVERT ACT NO. 2

The Law Firm directed patients to clinics owned and/or controlled _by PEYMAN

HEIDARY.

oveRT ACT NO. 3

CARY DAVID ABRAMOWITZ, as directed by PEYMAN REIDAR\'.', paid Cappers " 1 ,

$100 per.Patient signed up as a client of the Law.Firm. · '

OVERT ACT NO. 4-'

Cappers began working for PEYMAN HEIDARY when PEYMAN HEIDARY offered

Cappers a job in a new law firm opened by PEYMAN HEIDARY and Kenneth Forbes.

OVERT ACT NO. 5

Capp~rs had worker's compensation claimants sign blank forms, Cappers returned these

forms to the Law Firm, who filled them out and submitted them, along with other paperwork, to

the Wor~er's Compensation Appeals Board and various insurance companies.

' OVERT ACT NO. 6

The Law Firm filed numerous workers' compensation claims alleging similar.or

,identical inj~es ..

OVERT ACT NO. 7

·cappers sought out additional claiina!ltS from previously identified claimants.

OVERT ACTN0.-8

·· PEYMAN HEIDARY owned and/or controlled Riverside Health Clinic, Corona Health . - . "

Cl~nic, Montebello Health Clinic, Bellflower Health Clinic, Santa Ana Health Clinic, and

Anaheim Health Clinic.

OVERT ACT NO. 9

PEYMAN REIDAR Y created the Clinics as Li111it~d Liability Companies.

OVERT ACT NO: 10

PEYMAN HEIDARY moved unqualified,.µntrained employees between the Clinics and

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MICHAEL A. HESTRIN

DISTRICT ATTORNEY

County of Riverside

State or California

the Law Firm.

OVERT ACT NO. 11

PEYMAN HEID ARY controlled scheduling of doctors at the Clinics.

OVERT ACT NO. 12

PEYMAN HEIDARY controlled payments of the medical professionals at the Clinics.

OVERT ACT NO. 13

PEYMAN HEIDARY controlled patient care at the Clinics, including dictating

treatments and referrals. He ordered his employees to ensure that each patient received the

same or similar treatment and test studies regardless of injury.

OVERT ACT NO. 14

TOUBA PAKDEL-NABATI contributed to patient care at the Clinics, including

dictating treatments and referrals. She ordered her employees to ensure that each patient

received the same or similar treatment and test studies regardless of injury.

OVERT ACT NO. 15

QUYNAM NGUYEN received referrals for unnecessary treatment which led to the

creation of med-legal reports he caused to be created which QUYNAM NGUYEN knew would

later be submitted for billing.

OVERT ACT NO. 16

JASON YANG received referrals for unnecessary treatment which led to the creation

of med-legal reports he caused to be created which JASON YANG knew would later be

submitted for billing.

OVERT ACT NO. 17

The Clinics submitted bills and liens for treatments ordered by PEYMAN HEIDARY to

insurance companies 'and the WCAB.

OVERT ACT NO. 18

The Law Firm received payments in part from Compromise and Releases from the

WCAB and in part from legal fees billed to insurance companies.

OVERT ACT NO. 19

When PEYMAN HEID ARY hired medical and chiropractic professionals to work at the

Clinics, he ordered said professionals to create a checking account with PEYMAN HEIDARY

as a signatory so he cou.ld maintain control of that account. Once created, said professionals

were not allowed to make any changes or withdrawals to the account without PEYMAN

HEIDARY'S permission. PEYMAN HEIDARY further ordered that any payments n:ade to

said professionals be deposited in that professional' s checking account and the professionals

were paid out of that account.

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MICHAELA. HESTRIN

DISTRICT ATTORNEY

County of Riverside

State ofCallfornla

OVERT ACT NO. 20

. PEYMAN HEIDARY ordered said professionals to assign the all outstanding

bills/accounts rt(ceivables to him. PEYMAN HEIDARY would then bundle the outstanding

bills and sell the~ to third party collections and/or medical .factoring firm ..

COUNT2

For a further and separate cause of action, being a different offense from but connected

'in its commission with the charge set forth.in count 1 hereof, the Criminal Grand Jury of the

County of Riverside by this Indictment hereby accuses TOUB~ P AKDEL-NABATI and

QQYNAMNGUYEN and JASON YANG of a violation,.~f Penal Code sectio~ 550, . .

subdivision (a), subsection (6), a felony, in .that on or about January 1, 2009 through and , . . ' . '

· including July 15, 201,4, in the County of Riverside, State of California, the defendants did

willfully _and unfawfully ~d knowingly make and cause to_ be made a false and fraudulent

clai~ for payment of a health care benefit, to wit,' from ACE, and the claim and amount at issue

exceeded Nine Hundred Fifty dollars ($950) and the aggregat~ amount of claims and amount at

issue exceeded Nine Hundred Fifty dollars ($950) in a five years and six-month consecutive

period.

H is furthpr alleg·ed that in the commission al!d attempted commission of the above

offense the said defend~mts, TOUBA PAKDEL-NABATI and QuYNAM NGUYEN and

JASON YANG, with the intent so to do,. took, damaged and destroyed property of a value

exceeding$200,000; within the meaning of Penal Code section 12022.6, subdivision (a),

sub~ection (2).

COUNT3

. \ For a further and separate cause of action, being a different offense from but connected

in its commission with the charges set forth in counts 1 and 2_ hereof, the Critpinal Grand Jury

of the County of Riverside by this Indictment hereby accuses TOUBA P AKDEL-NABATI and

QUYNAM NGUYEN and JASON YANG ofa violation of Penal Code section_ 550,

subdivision (a), subsection (6), a felony, in that on or about Jao.uaiy 1, 2009 through and

.in~luding July 15, 2014, in the County of Riverside, State ~f California, the defendants did

willfully ·and unlawfully and knowingly make and cause to be made a false 'and fraudulent

claim for payment o.f a health care benefit, to wit, from AMERICAN INTERNATIONAL

GROUP (AIG), and the claim and amount atissue exceeded Nine Hundred Fifty dollars (~950) · and the aggregate amount of claims and amount at. issue exceeded Nine Hundred Fifty dollars

($950) in five years-and six-month consecutive period.

· It is ·furth~r alleged that in the commission ~d attempted comµiission of the above

of~ense the· said defendants~ TOUBA P AKDEL-NABATI and· QUYNAM NGUYEN and

JASON YANG, with_ the intent so to do, took, damaged and destroyed property of a value

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MICHAEL A. HESTRIN

DISTRICT ATTORNEY

County of Riverside

State of California

·.t.··

exceeding $6_5,000, within the meaning of Penal Code section 12022.6, subdivision (a),

subsection (1).

COUNT4

For a furth~r and separate cause of action, being a different offense from but connected

in its commission.with the charges set.forth in counts 1through3 hereof, the Criminal Grand

Jury of the County of Riverside by thls Indictment hereby accuses TOUBA PAKDEL-NABATI

and QuyNAM NGUYEN and JASON YANG of a violation of Penal Code section 550,

subdivi_~fon (~),subsection (6); a felony, in that on or about January 1, 2009 through and

including July 15, 2014, in the County of Riverside, State of California, the defendants did

willfully and unlawfully ahd knowingly make and cause to be.made a false and fraudulent

claim for payment of a health care benefit, to wit, from BERK.SHIRE/HATHAWAY, and the

claim and amount at issue exceeded,_Nine Hundred.J:"ifty doll~s ($950) and the aggregate

amount of claims and amount at issue· exceed~d Nine Hundred Fifty dollars ($950) in a five

years ·and six-month consecutive peri.od.

It is furthe~ alleged that in the commission and attempted comµiission of the above

offense the said defendants, TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and

JASONY ANG, with the intent so to do, took, damaged and destroyed property of a value·

exceeding $200,000, within the_meaning of Penal Code section 12022.6, subdivision (a),

subsection (2);

COUNTS ' '

_For a further and separate cause of action, being a different_offense from but connected

in its co~ission with the charges set forth in counts 1 through 4 hereof, the Criminal Grand

Jury of the County-of Riverside by this Indictment-hereby acc~ses TOUBA P AKDEL-NABATI

and QUYNAM NGuYEN and JASON YANG of a violation of Penal Code section 550;

subdivision (a), subsection ( 6), a felony, in that on or about January 1 ~ 2009 through and

including July 15, 2014, in the County of Riverside, State of California, the defendants did - -

willfully and unlawfully .and knowingly make and cause to be made a false and frauchilent

claim for payment of a health care benefit, to wit, from CNA INSURANCE,. and the claim and

amount at issue exceeded Nine Hundred Fifty dollars ($950) and the aggregate amount of

claims ap_d amount at issue exceeded Nine Hundred Fifty dollars ($950) in a five years and six

month consecutive period. '

It is further alleged that in the co:rpmission and attempted commission of the above

offense the said defendants, TOUBA PAKDEL-NABATI and QUYNAM-NGUYEN and . -

J.A-SON YANG, with the intent so to do, took, damaged and destroyed property of a value

ex.ceeding $200,000, within-the meaning of Penal Code section 12022.6, subdivision (a),

subsedion (2).

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MICHAEL A. HESTRIN

DISTRICT ATTORNEY

Co~ty ofRiverSide

State of California

.COUNT6 . . . I

.· For a further and separate cause of action, be_ing a different offense from but connected

in its commission with the charges set forth in counts 1 through 5 hereof, the Criminal 6rand . . .

Jury of the Coµnt~ of Riverside by thi_s Indictment hereby accuses TOpBAPAKDEL-NABATI •I

and QUYNAM NGUYEN and JASO.NY ANG of a violation of Penal Code section 550,

subdivision (a), subsection (6), a felony, in that ori or abdut January 1, 2009 through and

including July 15, 2014, in the Cotinty of Riverside, State of California, the defendants did

willfully and.unlawfully and knowingly make and cause to be made a false and fraudulent

claim for payment of a health care benefit, to wit, from CALIFORNIA RESTAURANT ·.

MUTUAL BENEFITS CORPORATION (CRMBC), and the claim and amount at issue

exceeded Nine Hundred Fifty dollars ($950) and the aggregate amount of claims and amount at

issue exceeded Nine Hundred Fifty dollars ($950) in a five years and six-month consecutive

period:

It is further alleged that in the commission and attempted commission of the above

offense the said defendants, TOUBA P AKDEL-NABATI and QuYNAM NGUYEN and

JASON YANG, with the intent so to do, took, damaged and destroyed property of a value . .

exceeding $200,000, within the meaning of Penal Code sectiOn 12022.6, subdivision (a),

· subsection (2).

COUNT7

For a further and separate cause of action~ being a different offerise from but connected

. in its commission with the charges set forth in counts 1 through 6 her¢of, the Criminal,, Grand

Jury of the County of Riverside by this Indictment hereby accuses TOUBA P AKDEL-NABATI

and QUYNAM .. NGUYEN and JASdN YANG of a violation of Penal Code section 550,

subdivision (a), subsection (6), a felony, in that on or about January 1, 2009 through an.d

including July 15, 2014, in the County of Riverside, State of California; the defendants did .

willfully and unlawfully and knowingly make and cause to be made a false and fraudulent

claim for payment of a health care benefit, to wit,1 from CRUM & FORESTER, and the claim • I • • "t

and amount at issue exceeded Nine Hundred Fifty dollars ($950) and the aggregate amount of

claims and amount at issue exceeded Nine Hundred Fifty dollars ($950) in a five years and six

month consecutive period.

Itis further alleged that in the commission and attempted commission of the above

offense the said defenqants, TOUBA P AKDEL-NABATI and Q~AM NGUYEN and

JASON YANG, with the intent so to do, took, damaged ~nd destroyed property of a value

· exceeding $200,0.00, within the meaning of Penal Code section 12022.6, subdivision (a),

subsection (2).

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MICHAEL A. HESTRIN

DISTRICT ATIORNEY

County of Riverside

Stale of California,:

COUNTS

, For a further.and separate .cause of action, being a different offense from but connected

in its commis'sion with the charges set forth In counts 1 through 7 hereof, the Criminal Grand

Jury of the County of Riverside by this 1!1dictmenthereby ac~uses TOUBA P AKDEL-NABATI°

and QUYNAM NGUYEN and JASON YANG of a violation of Penal Code section 550,

subdi~ision (a), s'ubseetion (6), a felony, in that on or about January 1, 2009 thrqugh and - ' . . ~

includitig,Juiy 15, 2014, in the County of Riverside, State of California,- the defendants did · ' - ' -


claim for payment of a health care benefit, to wit, from EMPLOYERS, and the claim and

amount at issue exceeded Nine Hundred Fifty doHars ($950} and the aggregate amount of

claim~ and amount at issue exceeded Nine Hundred Fifty dollars ($950) in a five years and six-

. month c·onsecutive period.


offense the' said defendants, TOUBA P AKDEL-NABATI and QUYNAM NGUYEN and

·JASON YANG, with the intent so to do, took, ~amaged and destroyed property of a value

exceeding $200,000, within the meaning of P~nal Code section 12022.6, subdivision (a),

·subsection (2).

COUNT9

For a further imd·separate cause of ~ction, being a dl.fferent offense from but coooected .

in its commissi.on with the charges set forth in counts 1 through 8 .hereof, the Criminal Grand

Jµry of th.e County of Riverside by this Indictment hereby accuses TOUBA P AKDEL-NABATI


subdivisi?n (a), subsectio~ (6), a feIOny; in that on or about January 1, 2009 through arid

including July 15, 2014, in the ~ounty of Riverside, State of California, the defendants did

willfully and unlawfully and knowingly make and cause to b.emade·a false and fraudulent

claim for payment of a health care benefit, to wit, from EVEREST NATIONAL INSURANCE

COMP ANY (ENIC), and the claim and amount at is.sue exceeded Nin~ Hundred Fifty dollars

($950) and the aggregate amount of claims and amourit at issue exceeded Nine Hundred Fifty

dollars ($950) in a five years and s,ix-month consecutive period.

It is further alleged that in the commission and attempted commissi~n ofthe above

offense the said, defendants, TOUBA P AKDEL-NABATI and QUYNAM NGUYEN and

JASON YANG, with the intent so to do, took, damaged and destroyed p~operty of a value

. exceedhig sixty five t~ousand dollars ($65,000.00), within the meaning of Penal Code.section

12022.6~ subdivision (a), subsection (1).

COUNT 10

For a·further and separate cause of action, being a differel!t offense from but connected

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MICHAEL A. HESTRIN

DISTRICT ATTORNEY

County of Riverside

State of California

in its commission with the charges set forth in counts 1 through 9 hereof, the Criminal Grand



subdivision (a), subsection (6), a felony, in that on or about January 1, 2009 through and



claim for payment of a health care benefit, to wit, from FARMER'S, and the claim and amount

at issue exceeded Nine Hundred Fifty dollars ($950) and the aggregate amount of claims and

amount at issue exceeded Nine Hundred Fifty dollars ($950) in a five years and six-month

consecutive period.


offense the said defendants, TOUBA P AKDEL-NABATI and QUYNAM NGUYEN and

JASON YANG, with the intent so to do, took, damaged and destroyed property of a value

exceeding $200,000, within the meaning of P.enal Code section 12022.6, subdivision (a),

subsection (2).

COUNT 11


in its commission with the charges set forth in coul}ts · 1 through 10 hereof, the Criminal Grand






claim for payment of a health care benefit, to wit, from FIREMAN'S, and the claim and amount

at issue exceeded Nine Hundred Fifty dollars ($950) and the aggregate amount of claims and


consecutive period.




exceeding $65,000, within the meaning of Penal Code section 12022.6, subdivision (a),

subsection (1 ).

COUNT12




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MICHAEL A. HESTRIN

DISTRICT ATTORNEY

County of Riverside

State of California

-and QUYNAM NGUYEN and JASON YANG of a violation of Penal Code-~ection 550, .

subdivision (a), subsection (6), a felony,in that on or about January 1, 2009 through and

including July 15, 2014, in the County of Riverside, State of C::alifornia, the defendants did

willfully and unlawfully_and knowingly make and cause to be made a false and fraudulent

claim for payment of a health care benefit, to wit, from HARTFORD, and the claim and amount

at issue exceeded Nine Hundred Fifty dollars ($950) and the aggregate amount of claims and . . ~

amount at issue exceeded Nine Hundred Fifty dollars ($950) in a five years and six-month _

consecutive period.

It iS further alleged that in the commission and attempted commission of the above

offens~ the-said defendants, TOUBA P AKDEL-NABATI and QUYNAM NGUYEN and . - . j . . .

JASON YANG, with theintent so to do, fook, damaged.and destroyed property of a value

exceeding $200,000, within the meaning of Penal Code section 12022.6, subdivision (a),

subsection (2).

COUNT 13

For a. further and separate cause of action, being a different offense from but comiected

in its commission with the charges set forth in counts 1 through i_2 hereof, the Criminal Grand

Jury of the County of Riverside by this Indictment hereby accuses TOUBA P AKDEL-NA_BATI

and QUYNAM NGUYEN and JASON YANG of a violation of Pe?al Code section 550,'

subdivisjon (a), subsection (6), a felony, in that on or about Janufil.y 1, 2009_ through and


willfully and unlawfully and knowingly make and cause to be made a false and fraudule~t

claim for payment of a health care benefit, to wit, from INSURANCE CARRIES OF THE

. WEST (ICW) and the claim and amount at issue exceeded Nine Hundred Fifty dollars ($950)

and, the aggregate amount of claims and amount at issue exceeded'Nine Hundred Fifty dollars

.($950) in a five years and six-month consecutive period.

it is further alleged that in the commission and attempted commission of the above

offense the _said defendants, TOUBA P AKDEL-NABATI and QUYNAM NGUYEN and

JASON YANG, wit9 the intent so .to do, took, damaged and destroyed property of a·value

exceeding $200,000, within the meaning of Penal Code section 12022.6~ subdivision (a),

subsection (2). :

COUNT14

For a further and separate caus~ of action, being a different offense from but connected

in its commission with the charges set forth in counts 1 thr01,1gh 13 hereof, the Criminal Grand



subdivision (a), subsection (6); a felony, in that on or.about January 1, 2009 through and

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MICHAEL A. HESTRIN

DISTRICT ATTORNEY

County of Riverside

State of California

including July 15, 2014, in the County ofRiverside,-State of California, the defendants did


claim for payment of a health care benefit, to wit, from LIBERTY MUTUAL, and the claim

and amount at issue exceeded Nine Hundred Fifty dollars ($950) and the aggregate amount of

claims and amount at issue exceeded Nine Hundred Fifty dollars ($950) in a five years and six

month consecutive period.


offense the said defendants, TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and


exceeding $1,300,000, within the meaning of Penal Code section 12022.6, subdivision (a),

subsection (3).

COUNT 15

For a further and separate cause of action, being a different o"ffense from but connected


Jury of the County of Riverside by this Indictrrient hereby accuses TOUBA P AKDEL.,.NABATI



including July 15, 2014, in the County of Riverside, State of California,_ the defendants did


claim for payment of a health care benefit, to wit, from REPUBLIC INDEMNITY, and the

claim and amount at issue exceeded Nine Hundred Fifty dollars ($950) and the aggregate

amount of claims and amount at issue exceeded Nine Hundred Fifty dollars ($950) in a five

years and six-month consecutive period.




exceeding sixty five thousand dollars ($65,000.00), within the meaning of Penal Code section

12022.6, subdivision (a), subsection (1).

COUNT16



Jury of the County of Riverside by this Indictment hereby accuses TOUBA PAKDEL-NABATI


. subdivision (a), subsection (6), a felony, in that on or about January 1, 2009 through and



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Claim for payme~t of a health care benefit, to wi~, from STATE COMPENSATION

INSURANCE FOND (SCIF), and the claim and amount at issue exceeded Nine Hundred Fifty

· dollars ($950) and the aggregate amoiin.t of claims and amount at issue exceeded Nine Hundred, ' . -

Fifty dollars (~950) in a five years and six-month consecutive period.


offense the-said def~ndants, TOUBA PAK.DEL~NABATI and QUYNAM NGUYEN and

' JASON YANG, with the intent so to do, took, damaged and destroyed property of a value

exceeding $1,300,000, within the meaning of Penal Code section 12022.6, subdivision (a), . . . {

subsection (3).

C.OUNT 17

.For a further and separate cause of action, being a different offense from but conneCted in

·its commission with-the charges set forth in counts· 1 through i'6 hereof, the Criminal _Grand Jury of.

the County of Rlverside by. this Indictment hereby accuses TOUBA _P AK.DEL-NABATI and - .

QUYNAM NGUYEN and JASON YANG of a violation of Penal Code section 550, subdivision

(a), subsection (6), a felony, in that ori or about January 1, 2009 through and including July 15, . . '

2014, in the County of Rivets~de, State of California, the defendants did wilifully and unlawfully

aµd knowingly make and cause to be.made a ,false and fraudulent claim for payment of a health care

beriefit, to wit, ~from TRAVELER'S, and the clailn and amount at issue exceeded Nine Hundred

·Fifty dollars ($950) .and the aggregate amount C?f claims and amount at issue exceeded Nine.

Hundied Fifty dollars ($950) in a five years and six-month consecutive period. ' - . .

It is further alleged that in the commi~sion and attempted commission of the 8:bove

, offens.e the said defendants, TOUBA P AKDEL-NABATI and QUYNAM NGUYEN and

JASON YANG, with the intent so to do, took, damaged and destroyed property of a value . .

exceeding $1,300,000, within the meaning of Penal Code section 12022.6, subdivision (a),

subsection (3).

CODNTi8

For.a further and separate cause of action, being a different offense from but connected

in its commissiOn with the charges set.forth in counts 1through17 hereof, the Criminal Grand

Jury of the Coooty of Riverside by this Indictment .hereby accuses TOUBA P AK.DEL-NABATI

and QUYNAM NGUYEN and JASON YANG of a violation of Penal Code section 550, . - ~ .

subdivision (a), subsection (6), a felony, .in that on or about Jamiary_l, 200~ through and,


willfully and unlawfully and knowingly make and cause to be made a false and fraudulent 34 · claim for payment of a health care benefit, to wit, from ZENITH, and the claim and amount at 35 is~ue exceeded. Nine Hundred Fifty dollars ($950) and the aggregate amount of claim~ and

. 36

MICHAELA. HESTRIN

1 DISTRICT ATTORNEY

County Or Riverside

State of California

. -

amount at issue exceeded_ Nine Hundred Fifty dollars ($950) in a five years and six-month

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MICHAELA.HESTRIN

DIS1RICT ATTORNEY

County ofRiversid.e

State of California

consecutive period.

. It is further alleged that in the com.Iilission and attempted· commission of the above


JASON YANG, with the intent so to do, took, damaged and destroyed property of a value - '

exceeding $65,000,. within the meaning of-Penal Code .section 12022.6, subdivision (a),

. subsection (1 ).

COUNT19

· For a.further and separate cause of action, being a different _offense from but connected

in its commi,ssioii with the charges set forth in counts 1 through_ 18 hereof, the Criminal Grand


·and_ QUYNAM NGUYEN and JASON YANG of a violation of Penal Code section 550,


includins July 15, 2014, in the County of Riverside, State of California~- the defendants did -

willfully and unlawfully and knowingly make and cause to be made.a false and :fraudulent

claim for payment of a health care benefit, to wit, rrom ZURICH, and the claim and amount at

issu~ exceeded Nine Hundred Fifty dollars ($950) and the aggregate amount of claims and


consecutive period.

It is further alleged that in the commission and attempted cqinmission of the above


_ JASON YANG, with the intent so to do, took, damaged and destroyed property of a value

· exceeding.$1,300,0QO, withi~ the m~aning of Penal Code section 12022.6;subdivision (a),

subsection (3). · -

COUNT20


in its commission wi.th the charges set forth in counts 1 throu~ 19 hereof, the Criininal Grand

Jury of the County of Riverside by this Indictment hereby accuses TOUBA P Af(DEL-NABATI

and QUYNAM NGUYEN and JASON YANG of a violation of Insurance Code sectionJl 871.4,


including July 15, .2014~ in the County of Riverside, State .of California, the defendants did .

willfully and unlawfully make and cause to be made a knowingly fals·e ancf fraudulent material

statement ~nd material representation, to wit, to ACE, for the purpose of obtaining and denying

compensatjon, as defined in Labor Code section 3207.

COUNT21



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MICHAEL A. HESTRIN

DISTRICT ATTORNEY

County of Riverside

State of California

Jmyof the County of Riverside by this Indith!ient hereby-accuses TOUBA P AKDEL-NABATI . '

and QUYNAM NGUYEN and JASON YANG of a violation of Insurance Code section 1871.4;

subdivision (a), subsection (1), a felony, in that on or aboutJanuary 1, 2009 through and

including July 15, 2014, in the County of Riverside, State 0f California~ the defendants did

willfully and unlawfully make and cause to be made a knowingly false and fraudulent material

statement and material representation, to wit, to AMERICAN INTERNATIONAL GROUP ' . ' ....

(AIG) for the purpose of obtaining and denying compensation, as defined in Labor Code

section 3207.

It is further alleged that in the commission and attempted commission \,of the above

·offense the said defendants, TOUBA P AKDEL-NABATI and QUYNAM NGUYEN .and


exceeding $6.5,000, within the meaning of Penal Cod'e section 12022.6, subdivision (a),

subsection (1 ). ·

COUNT22

For a further and separate cause of action, being ·a different offense from but connected

in its commission with the charges set forth in counts i through 21 hereof, the Criminal Gr~nd

J'ury o{the County of Riverside by this Indictment hereby accuses TOUBA P AKDEL-NABATI

and QliYNAM NGUYEN and JASON Y ANQ of a violation of Insurance Code section 1871.4,

subdivision (a), subsectioh (1), a felony, ill that on or about January 1, 2009 through and

including Juiy 15, 2014; in the County of Riverside: State of California, the defendants did . . .

willfully and unlawfully make and cause to be made a knowingly false and. fraudulent material

statement and material representation, to wit, to BERKSHIRE/HATHAWAY for the purpose of

obtaining and denying compensation, as defined in Labor Code section 3207.

COUNT23


in its commission with the charges set forth in counts 1 through 22 hereof, the Criminal Grand . . . Jury of the County of Riverside by this-Indictment hereby accuses TOUBA PAKDEL-NABATI )

. .

and QUYNAMNGUYEN and JASON YANG ofa violation of Insurance Code section 1871.4,

subdivision (a), subse.ction (1), a,felony, in that on or about January 1, 2009 through and '·

including July 15, 2014, in the County of Riverside, State of C<:).lifornia, the-defendants did

willfully and unlawfully make and cause to be made a kn~wingly false and fraudulent material

statement and material representation, to wit, to CNA INSURANCE for the puipose of

obtaining and denying compensation, as defined inLabor Code section 3207.

COUNT24

For a.further and separate_ cause of action, being a different offens~ from but connected

in its commissiqn with the charges set forth in counts 1 through 23 hereof, the Criminal Grand ,, . '

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MICHAELA. HESTRIN

DISTRICT ATTORNEY

County of Riverside

State of California


and QUYNAMNGUYEN and JASON YANG of a violation of Insurance Code section 1871.4,

subdivision (a), subsection(!), a felony, in that on or about January 1, 2009 through and

including July 15, 2014~ in the County of Riverside, State of California, the defendants did

willfully and uri.lawfully make and cause to be made a knowingly false and fraudulent material

statement and material representation, to wit, to CALIFORNIA RESTAURANT MUTUAL

BENEFITS CORPORATION (CRMBC) for the purpose of obtaining and denying

compensation, as defined in Labor Code section 3207.

COUNT25



Jury of the County of Riverside by this Indictment hereby accuses PEYMAN HEIDARY and

CARY DAVID ABRAMOWITZ and ANA SOLIS and GLADYS ROSS of a violation of

Insurance Code section 1871.4, subdivision (a), subsection (1), a felony, in that on or about

January 1, 2009 through and including July 15, 2014, in the County of Riverside, State of

California, the defendants did willfully and unlawfully make and cause to be made a knowingly

false and fraudulent material statement and material representation, to wit, to CRUM &

FORESTER for the purpose of obtaining and denying compensation, as defined in Labor Code

section 3207.


offense the said defendants, PEYMAN HEIDARY and CARY DAVID ABRAMOWITZ and

ANA SOLIS and GLADYS ROSS, with the intent so to do, took, damaged and destroyed

property of a value exceeding $200,000, within the meaning of Penal Code section 12022.6,

subdivision (a), subsection (2).

COUNT26




and QUYNAM NGUYEN and JASON YANG of a violation of Insurance Code section 1871.4,


including July 15, 2014, in the County of Riverside, State of California, the defendants 'did


statement and material representation, to wit, to EMPLOYERS INSURANCE for the purpose

of obtaining and denying compensation, as defined in Labor Code section 3207.



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MICHAEL A. HESTRIN

DISTRICT ATTORNEY

County of Riverside

State of California

I •

JA,SON YANG, with the intent so to do, took,'damaged· and destroyed property of a value

expeeding sixty five thousand dollars ($65,000.00), w~thin the mealling·of Penal Code section

. '12022.6, subdivision (a), subsection (1).

GOUNT27 . .

For a further an~ separate cause of action, being a different offense from but COJ1llected

in its commission with the charges set forth in counts 1 through 26 hereof, the .Criminal Grand

Jury of the County ·of Riverside by this Indi~tment hereby accuses TO,UBA PAI~DEL-NABATI .

and QUYNAM NGUYEN and JASON.YANG of a violation of insurance Code section 1871.4,

subdivision (a), subsection (1), a felony, in that on or about January 1, 2009. through and

includingJuly)5, 2014, in the County of Riverside, State.of California, the defendants did

willfully and unlawfully make and c~use to be made a knowingly false and fraudulent material

statement and material representation, to wit, to EVEREST NATIONAL INSURANCE

COMP ANY (ENIC), for the purpose of obtaining and denying compensation, as defined in

Labor Code section 3207.

COUNT28

For a further and separate cause of action, being a different offense fr~ni but connected ' ' '

in its·commissiOn with the c~arges set forth iri counts 1 through27 hereof, the Criminal Grand

· Jury of the County of Riverside by this Indictment hereby accuses TOUBA P AKDEL-NABATI

and QUYNAM NGUYEN and JASON YANG of a violation oflnsurance Code section 1871.4,

.. subdivision'(a), subsection (1), a felony, in.that on or about January 1, 2009 through and

including July 15, 2014, in the County of Riverside, State of California, the defen~ants did

willfully and urilawfully make and cause to be made a knowingly false and fraudulent matyrial

statement and material representation, to wit, to FARMER'S INSURANCE for the purpose of


COUNT29


. in its commission with the charges set forth in counts 1 through 28 hereof, the Cnminal Grand

Jury of the County.ofRiverside by this Indictment hereby ac.cuses TOUBA P AKDEL-NABATI

and QUYNAM NGUYEN and JASON YANG of a violation oflrtsurance Code section 1871.4,

subdivision (a), subsection (1 ), a felony, in that .on or about January 1, 2009 through and

focJuding July 15, 2014, in the County ofRiversi~e, State of California, the defendants did.

willfully and unlawfully make and cause to be made a knowingly. false and fraudulent material

statement and.material representation, to wit, to FIREMAN'S, for the ptirpose of obtaining and

denying compensation, as defined in Labor Code section 3207.


offense the said defendarits, TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and

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11-llCHAEL A. HESTRIN

DISTRICT ATIORNEY

County of Riverside

State of California


exceeding sixty five thousand dollars ($65,000.00), within the meaning of Penal Code section

12022.6, subdivision (a), subsection (1).

COUNT30



Jury of the County of Riverside by this Indictment hereby accuses PEYMAN HEIDARY and

CARY DAVID ABRAMOWITZ and ANA SOLIS and GLADYS ROSS of a violation of

Insurance Code section 1871.4, subdivision (a), subsection (1), a felo.ny, in that on or about

January 1, 2009 through and including July 15, 2014, in the County of Riverside, State of


false and fraudulent material statement and material representation, to wit, to HARFORD, for

the purpose of obtaining and denying compensation, as defined in Labor Code section 3207.




property of a value exceeding sixty five thousand dollars ($65,000.00), within the meaning of

Penal Code section 12022.6, subdivision (a), subsection (1).

COUNT31


in its commission with the charges set forth in counts 1through30 hereof, the Criminal Grand






statement and material representation, to wit, to INSURANCE CARRIERS OF THE WEST

(ICW), for the purpose of obtaining and denying compensation, as defined in Labor Code

section 3207.

COUNT32







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MICHAELA. HESTRIN

DISTRICT ATIORNEY

County ofRlverside

State of California

willfully and unlawfully make and cause to be made a knowingly false _and fraudul~nt material

statement and material repre~entation, to wit, to LIBERTY MUTUAL for the purpose of

. obtaining and denying compensatiol;l, as defined in Labor Code section 3207.

COUNT33

For a further and separate cause ofaction, being a different offense from but connected

in its commission with the charges set forthin counts 1through32 hereof, the Cri~inal Grand


and QUYNAMNGUYEN and JASONYANG ofa violation of Insurance Code section 1871.4,

·subdivision (a), subsection (1 ), a felony, in that on or about January 1, 2009 through and

including July 15; 2014, in the County of Riverside, State of California, the defendants did


statement and material representation, to wit, to REPUBLIC INDEMNITY for the purpose of

obtaining and denying compensation, as defined in Labor Code section -3207.·

COUNT34

For a·further and separate cause of action, being a different offense from but connected

in its commission with 'the charges set forth in counts 1 through 33 hereof, the Criminal Grand

Jury ofth~ County of-Riverside by this Indictment hereby accuses PEYMAN HEID ARY and

CARY DAVID ABRAMOWITZ and ANA SOLIS and GLADYS ROSS of a violation of . , Insurance Code section 1871.4, subdivision (a), subsection (1), a felony,"in that on or about

January 1, 2009 thro~gh and including July 15, 2014, in the County of Riverside, State of

California, the defendants did willfully and unlawfully make and cau~e to be made a knowingly

false and fraudulent material statement 8?d material representation, to wit, to STATE

COMPENSATION INSURANCE FUND (SCIF), for the purpose of obtaining and denying

compensation, as.defined in Labor Code section 3207.

·It is further· alleged that in the commission and attempted commission of the above


ANA SOLIS and GLADYS ROSS, with the intent so to do, took, damaged·and destroyed·

property of a value exceeding· $200,000, within the meanfog of Penal Code section 12022.6,


COUNT 35

. For a further and separate cause ·of action, being a different offense· from but connected

in its commission with the charges set forth in counts. 1 'through 34 hereof, the Criminal Grand

Jury of the County of Riverside by this Indictment hereby accuses PEYMAN HEID ARY and

· CARY DA VIO ABRAMOWITZ arid ANA SOLIS and GLADYS ROSS of a violation of ,_.

ln~urance Code section 1871.4, subdivision (a), subsection (1), a felony, .in that on or about

January 1, 2009 through and including July 15, 2014, inthe County of Riverside, State of

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MICHAEL A. HESTRIN

DISTRICT ATTORNEY

County of Riverside

State ofCallfornla


false and fraudulent material statement and material representation, to wit, to TRAVELERS

INSURANCE, for the purpose of obtaining and denying compensation, as defined in Labor

Code section 3207.




property of a value exceeding sixty five thousand dollars ($65,000.00), within the meaning of

Penal Code section 12022.6, subdivision (a), subsection (1).

COUNT36


in its commission with the charges set forth in counts 1through35 hereof, the Criminal Grand





willfully and unlawfully make and cause to be made a knowingly false and :fraudulent material

statement and material representation, to wit,' to ZENITH INSURANCE for the purpose of


COUNT37


in its commission with the charges set forth in 'counts 1 through 36 hereof, the Criminal Grand

Jury1ofthe County of Riverside by this Indictment hereby accuses TOUBA PAKDEL-NABATI

and QUYNAM NGUYEN and JASON YANG of a violation oflnsurance Code section 1871.4,




statement and material representation, to wit, to ZURICH for the purpose of obtaining and

denying compensation, as defined in Labor Code section 3207.

COUNT38


in its commission with the charges set forth in counts 1 through 3 7 hereof, the Criminal Grand


and QUYNAM NGUYEN and JASON YANG of a violation of section 549 of the Penal Code,

a felony, in that on or about January 1, 2009 through and including July 15, 2014, in the County

of Riverside, State of California, the defendants, did willfully and unlawfully solicited,

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MICHAELA.HESTRIN

DISTRICT ATTORNEY

County of Riverside

State of California

accepted, or referred any business to or from any individual entity with the knowledge that, or

i:eckless disregard for whether, the individual of' entity for or from whom' the solicitation or

referral is made, or the individual or entity who is solicited or referred, intended to violate . . .

section 550 of the Penal Code or section 1871.4 of the Insurance· Code.

It is further alleged that the said defendants, TOUBA PAKDEL-NABATI and . . .

QUYNAM NGUYEN and JASON YANG, committed two or more related felop.ies, a material

element of which was fraud or embezzlement, which involved a pattern of related felony

conduct, and this pattern of related felony conduct involved the taking of more th~ five

hundred thQusand dollars ($500,000.00) within the meariing of Penal Code section 186.11,


Special Allegation: Zamora

It is further alleged that the above offense was not discov.ered by .the victim( s) until

March26, 20p, when. the State Compensation Insurance F~d Investigator Phillis Shorts

began-her inquiry into suspicious circumstances of fraudulent activity.

Investigator Phillis Shorts discovered the fraudulent activity during an investigative

review into three individual worker's compensation claimant files who all 'used the same

attorney ser'Vice. and who were all treated by providers associated with clinics owned and . .

operated by Peyman Heidary.

On or about August 28, 2012, SCIF Investigator Phillis Shorts referred her findings to

an int~r-agency. team including the Office of the Riverside· County District Attorney. Further

investigation by the Riverside County District Attorney uncovered a highly s~phisticated . . ~ .

criminal organization. Over an approximately two year period, the investigation discovered

the use of cappers, law offices, and health clinics operated by support staff, chiropractors, - •/ -

arid medical doctors all working as directed byPeyman Heidary to bill for similar services

and treatment regardless of injury.

The scheme.was not discovered prior to SCIF lnve~tigator Phillis Shorts' findings due

to multiple layers of ownership and control, voluminous legal files, medical records, billing

inv:()lving hqndreds of patient victims, and multiple regulatory violations overseen by

multiple enforcement agencies.

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MICHAEL A. HESTRIN

DISTRICT ATTORNEY

County of Riverside

State of California

. ' ' '

The Office of the Riverside County District Attorney filed a criminal complaint in case

number RIF1409778 against Peyman Heidary, Cary Abramowitz, Mich~el Tuosto, and Erica . - ,.

Torres on July 25, 2014. (People:v. Zamora (1976) 18 Cal.3d 538.)

May 16, 2016

JA:tc

MICHAEL A. HESTRIN

District Attorney

~~r a :sistant District Attorney .

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1 Nam es of witnesses examined by the Criminal Grand Jury on finding of the foregoing

2 Indictment: ·

3 Kathan Lambert

4 Erica Torres

5 Dennis Knotts

6 Jennifer Delgado

7 Angelica Celis

8 Sandra Rubalcaba

9 Todd Loveless

10 Gissel Santibanez

11 Y amileth Petway

12 Ana Solis

13 Y azmine Martinez

14 Erica Lopez

15 Lany Roldan

16 Alejandra Palmerin

17 Corrine Guevara

18 Angelica Juarez

19 Crystal Banuelos

20 Perla Arroyo

21 Craig Johnson

22 Scott Adam

23 Clayton Johnson

24 Touba Pakdel-Nabati

25 Peter Park

26 Agatha Beltran

27 Eugene Sung

28 Kelly Ayers

29 Gladys Ross

30 Isidro Ramirez

31 Denise Rivera

32 Birender Singh

33 ·Jasmin Ballesteros

34 Oliver Glover

35 Janine Farrell

36 Daniel Gancourz

MICHAEL A. HESTRIN

DISTRICT ATTORNEY

County of Riverside

State of California 21

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1 · :Kristian Nielson 2 Ronda Loyd £,;~--

3 Danny Tran 4 Jill Landeros 5 Roger Gutierrez 6 . Maria Kramer 7 Gina Gri.bble 8 Anthony Hurtado 9 Gordon Oard

10 Aaron Lewis 11 Phillis Shorts 12 Fidel Borrego 13 Anile Luce 14 Glen Smith 15 Don Terrell 16 John.Auveniri 17 Nicole Sullivan 18 Chris Dill 19 ·Cynthia Becher 20 y anti Soliman 21 Denise Magdaleno 22 Kurt Lackman. 23 Sean Nealy 24 John Standish ,;.,

25 David Wall 26 James Fisher 27 Kerry O'Brien· 28 Lawrence Westcott 29 Quynam ·Ngtiyen 30 Jason Yang 31 Tushar Doshi 32 Diane Zimmerman 33 j ennifer Finch · 34 James Munoz )5 · Tamara Cooper 36 June Trujillo

MICHAEL A. HESTRIN

DISTRICT ATTbRNEY

County of Riverside 22 State of California

1 :tviercedesllernandez .2 Jasmine Valadez

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MICHAELA.HESTRIN

DISTRICT ATTORNEY

County of Riverside 23 State ofCallfornla

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MICHAEL A. HESTRIN

DIS1RICT ATTORNEY

County of Riverside

State of California

MICHAEL A. HESTRIN

Distriet Attorney

County of Riverside

3960 Orange Street, First Floor

Riverside, California 92501

· _Telephone: (951) 955.-5400

JoJ.vi Aki

Chief Assistant District Attorney

State Bar No. 189395

SUPERIOR COURT OF CALIFORNIA

COUNTY OF RIVERSIDE

(Riverside)

THE PEOPLE OF THE STATE OF CALIFORNIA, Case No.

v.

TOUBA PAKDEL-NABATI

DOB: 08/03/1978

QUYNAM NGUYEN

DOB: 06/11/1958

JASON YANG

DOB: 02/24/1966-.

Plaintiff, ·

Defendants.

REQUEST/MOTION FOR

PROSECUTION DISCOVER\

(Pen. Code, §§ 1054.3, -

1054.5(a) & (b))

·TO: THE HONORABLE JUDGE OF THE SUPERIOR COURTS AND TO

COUNSEL FOR ABOVE-NAMED DEFENDANTS:

PLEASE BE INFORMED thattheUffice of the District Attorney pf Riverside County,

· acting on behalf of the Plaintiff, the People of the State of California, her~by

requests/moves for discovery/disclOsure of the following items from t4e defendants and

defendants intend to call as witnesses at trial;

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MICHAEL A. HESTRIN

DISTRICT ATTORNEY

County ofRlverslde

State ofCalifornla

2. Any relevant written or recorded statements of the persons in No. 1 above and/or

reports of the statement of such persons;

3. Any reports or statement of experts made in connection with this case, including,

but not limited to, the results of physical or mental examinations, scientific tests,

experiments, or comparisons which the defendant or counsel intend to offer as evidence at

the trial of this case; and

4. Any "real," i.e., tangible or physical, evidence which the defendant or counsel

intends to offer in evidence at the trial.

PLEASE TAKE NOTE that pursuant to the provisions of Penal Code section . .

1054.5(b) ifthe above material and information requestedis not provided to counsel for

the plaintiff within 15 days of this request, a court order will be sought to promptly enforce

the provisions of Penal Code section 1054.3.

Dated: May 16, 2016

JA:tc

Respectfully submitted,

MICHAEL A. HESTRIN

District Attorney

. ~9· ~KI ~ ~sistant District Attorney

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MICHAELA. HESTRIN

DISTRICT ATIORNEY

County of Riverside 26 State or California

Documents

SUPERIOR COURT OF CALIFORNIA COUNTY OF RIVERSIDE Quynam... · CARY DAVID ABRAMOWITZ agreed with and allowed PEYMAN HEIDARY, a non-attorney, to exert actual control over California