4615 documents - first choice medical - dir.ca.gov · vs. ) 10 ) 11 faramarz fred khalili 01/10/61...
TRANSCRIPT
4615 DOCUMENTS - FIRST CHOICE MEDICAL
EXH. DESCRIPTION
1. Felony Complaint in the criminal case of The People of the State of California v. Faramarz Fred Khaliliet al, Case No. 15CF2507, before the Superior Court of California, County of Orange.
2. Federal Docket Report in the criminal case of United States of America v. Khalili, Case No.96CR00156 EJG 1, before the United States District Court for the Eastern District of California.
3. Board of Chiropractic Examiners records re: Faramarz Fred
4. Board of Chiropractic Examiners Decision in the case of In the Matter of the Acquisition Against:Faramarz Khalili, Case No. 99 110.
5. Board of Chiropractic Examiners Decision in the case of In the Matter of the Petition for Reinstatementof Revoked License of: Faramarz Fred Khalili, Case No. 1999 110.
1 SUPERIOR COURT OF CALIFORNIA CO'DN'l'Y OF ORANGE, CEN'l'RAL JUSTICE CENTER 2
3
4
5
6 THE PEOPLE OF THE STATE OF CALIFORNIA, )
7 ) Plaintiff, )
8 ) 9 )
vs. ) 10 )
11 FARAMARZ FRED KHALILI 01/10/61 ) N9365659 )
12 AKA FARAMARZ KHALILI )
13 FAMARZ FRED KHALILI ) HALILI ARAMAR Z )
14 SANDRA GARCIA MARTINEZ 05/24/68 )
15 C6548229 ) AKA SANDRA MARTINEZ )
16 SANDRA GARCIA )
17 HITENDRA HIRACHAND SHAH MD 01/01/47 ) Cl825179 )
18 )
19
FILED SUPERIOR COURT OF CALIFORNIA
COUNTY OF ORANGE CENTRAL JUSTICE CENTER
MAR 01 2016 ALAN CARLSON, Clerk of lf!e Court
B ,fL Y: ,DEPUTY
FELONY COMPLAINT WAR AMENDMENT 1
OCDA WC14110013
20 The Orange County District Attorney charges that in Orange
21 County, California, the law was violated as follows:
22 /
23 I I
24 /
25 I I
26 /
21 I I
28 I I I
FELONY COMPLAINT WARRANT (DA CASE# 1SF01341) OC DNA NOT ON FILE: FARAMARZ KHALILI, SANDRA MARTINEZ, HffENDRA SHAH
Exhibit 1
FARAMARZ FRED ICHALILI OCDA WC14110013 PAGE 2
l COUNT 1: On or about and between September 13, 2012 and December 28, 2012, in violation of Section SSO(a) (5) of the
2 Penal Code (CONSPIRACY TO COMMIT INSURANCE FRAUD), a FELONY,
3 FARAMARZ FRED KHALILI, SANDRA GARCIA MARTINEZ and BIRACHAND SHAH MD did unlawfully conspire with BITENDR
4 BIRACBAND SHAH, SANDRA GARCIA MARTINEZ, FARAMARZ FRED KHALILI, s with the intent to defraud, to prepare, make, and subscribe a
material writing with the intent to present and use it to 6 WORKERS COMPENSATION CARRIERS in support of a false an 7 fraudulent claim. It is further alleged that pursuant to and for
the purpose of carrying out the objects and purposes of the 8 conl\Jpiracy, one and more of the conspirators committed the g following overt acts:
10 OVERT ACT 1
11 Fred Khalili entered into an agreement with Healthcare Finance
12 Management on 9/1/2012 to distribute transdermal compound creams
13 which were manufactured by Curt's Compounding Pharmacy in Orange County to the Workers Compensation patients seen at First Choice
14 Beal thcare Medical Group.
15 OVERT ACT 2
16
17 Under the guise of selling accounts receivables to Healthcare Finance Management, Fred Khalili received kickbacks to
18 prescribed transdermal compound cream manufactured by Curt's
19 Compounding Pharmacy in Orange County, California.
20
21
OVERT ACT 3
Healthcare Finance Management would not purchase accounts 22 receivables from Khalili unless they were for prescriptions
23 relating to transdermal compound creams manufactured by Curt's Compounding Pharmacy in Orange County, California.
24
25 OVERT ACT 4
26 Fred Khalili and Sandra Martinez ordered the physician• s assistants who worked at First Choice to prescribe at least two
27 compound transdermal creams to as many workers compensation
28 patients as possible regardless of medical necessity.
FELONY COMPLAINT WARRANT (DA CASE# 15F01341) OC DNA NOT ON FILE: FARAMARZ KHALILI, SANDRA MARTINEZ, HITENDRA SHAH
Exhibit 1
FARA.MARZ FRED ICHALILI OCDA WC14110013 PAGE 3
l OVERT ACT 5
2 Dr. Hitendra Shah and Dr. Craig Chanin prescribed these compound
3 transdermal creams to workers compensation patients per Fre Khalili1s instruction regardless of medical necessity.
4
5 OVERT ACT 6
6 curt• s Compounding Pharmacy manufactured a 3 '."day supply and gave 7 it to First Choice, so that the medical staff could hand the
workers compensation patients the transdermal creams at the 8 clinic and justify First Choice• s ability to bill insurance
9 carriers for distribution of these creams.
10 OVERT ACT 7
11 Healthcare Finance Management would only pay First Choice for
12 distribution of the transdermal Compound Creams manufactured by
13 Curt•s Compounding Pharmacy if the physicians at First Choice also prescribed a larger size of the transdermal creams to
14 patient which would then be directly shipped from Curt• s
15 Compounding Pharmacy in Orange County to each patient.
16
17
OVERT ACT 8
Between 9/1/12 and 12/28/12, Healthcare Finance Management paid 18 First Choice in excess of $774, 000 for prescribing compoun
19 transdermal creams.
20
21
OVERT ACT 9
The last payment issued by Healthcare Finance Management to 22 First Choice was on 12/28/12 in the amount of $49, 725.
23 COUNT 2: On or about and between September 07, 2012 an
24 December 18, 2012, in violation of Section 550(a) (5) of the
25 Penal Code (INSURANCE FRAUD - WRITTEN CLAIM), a FELONY, FARAMARZ FRED ICHALILI, SANDRA GARCIA MARTINEZ and HITENDRA HIRACEAND S
26 MD, with the intent to defraud, did knowingly and unlawfully
27 prepare, make, and subscribe a material writing, with the intent to present and use it, and to allow it to be presented to
28 AMERICAN CLAIMS MANAGEMENT, in support of a false and fraudulent claim, and did aid and abet, and solicit another to do the same.
FELONY COMPLAINT WARRANT (DA CASE# 15F01341) OC DNA NOT ON FILE: FARAMARZ KHALILI, SANDRA MARTINEZ, H/TENDRA SHAH
Exhibit 1
FARAMARZ FRED KHALILI OCDA WC14110013 PAGE 4
1 COUNT 3: On or about· and between September OS, 2012 and December 20, 2012, in violation of Section SSO(a) (S) of the
2 Penal Code (INSURANCE FRAUD - WRITTEN CLAIM) , a FELONY, FARAMARZ
3 FRED KHALILI, SANDRA GARCIA MARTINEZ and HITENDRA HIRACEAND S MD, with the intent to defraud, did knowingly and unlawfull
4 prepare, make, and subscribe·a material writing, with the intent s to present and use it, and to allow it to be presented to ALAS
INTERNATIONAL, in support of a false and fraudulent 6 did aid and abet, and solicit another to do the same. 7
COUNT 4: On or about and between September 21, 2012 an 8 December 10, 2012, in violation of Section SSO(a) (5) of the 9 Penal Code (INSURANCE FRAUD - WRITTEN CLAIM) , a FELONY, FARAMARZ
FRED KHALILI, SANDRA GARCIA MARTINEZ and HITENDRA HIRACEAND SHAH lO MD, with the intent to defraud, did knowingly and unlawfully
11 prepare, make, and subscribe a material writing, with the intent to present and use it, and to allow it to be presented to ANTH
12 BLUE CROSS, in support of a false and fraudulent claim, and did
13 aid and abet, and solicit another to do the same.
14 COUNT 5: On or about and between September 06, 2012 an
15 December 13, 2012, in violation of Section SSO(a) (5) of the Penal Code (INSURANCE FRAUD - WRITTEN CLAIM), a FELONY, FARAMARZ
16 FRED :KHALILI,· SANDRA GARCIA MARTINEZ and HITENDRA HIRACEAND SHAH
17 MD, with the intent to defraud, did knowingly and unlawfully prepare, make, and subscribe a material writing, with the intent
18 to present and use it, and to allow it to be presented to
19 APPLIED RISK MANAGEMENT, in support of a false and fraudulent claim, and did aid and abet, and solicit another to do the same.
20
21 COUNT 6: On or about and between September 06, 2012 and December 19, 2012, in violation of Section SSO(a) (5) of the
22 Penal Code (INSURANCE FRAUD - WRITTEN CLAIM), a FELONY, FARAMARZ
23 FRED KHALILI, SANDRA GARCIA MARTINEZ and HITENDRA HIRACEAND SHAH MD, · with the intent to defraud, did knowingly and unlawfully
24 prepare, make, and subscribe a material writing, with the intent
25 to present and use it, and to allow it to be presented to AIG/ CHARTIS, in support of a false and fraudulent claim, and did ai
26 and abet, and solicit another to do the same.
27 I
28 I I I
FELONY COMPLAINT WARRANT (DA CASE# 15F01341) OC DNA NOT ON FILE: FARAMARZ KHALILI, SANDRA MARTINEZ, HITENDRA SHAH
Exhibit 1
FARAMARZ FRED KHALILI OCDA WC14110013 PAGE 5
1 COUNT 7: On or about and between S eptember 04, 2012 and December 20, 2012, in violation of Section 550(a) (5) of the
2 Penal Code (INSURANCE FRAUD - WRITTEN CLAIM) , a FELONY, FARAMARZ
3 FRED KHALILI, SANDRA GARCIA MARTINEZ and BITENDRA BIRACHAND S MD, with the intent to defraud, did knowingly and unlawfull
4 prepare, make, and subscribe a material writing, with the intent 5 to present and use it, and to allow it to be presented to CHUBB
INS., in support of a false and fraudulent claim, and did 6 and abet, and solicit another to do the same. 7
COUNT 8: On or about and between S eptember 04, 2012 an 8 December 20, 2012, in violation of Section 550(a) (5) of the 9 Penal Code (INSURANCE FRAUD - WRITTEN CLAIM), a FELONY, FARAMARZ
FRED KHALILI, SANDRA GARCIA MARTINEZ and BITENDRA BIRACHAND S lO MD, with the intent to defraud, did knowingly and unlawfully
11 prepare, make, and subscribe a material writing, with the intent to present and use it, and to allow it to be presented to CNA
12 INS._, in support of a false and fraudulent claim, and did ai
13 and abet, and solicit another to do the same.
14 COUNT 9 : On or about and between S eptember 04, 2012 an
15 December 20, 2012, in violation of Section 550(a) (5) of the Penal Code (INSURANCE FRAUD - WRITTEN CLAIM), a FELONY, FARAMARZ
16 FRED KHALILI, SANDRA GARCIA MARTINEZ and BITENDRA BIRACHAND SB.AB
17 MD, with the intent to defraud, did knowingly and unlawfully prepare, make, and subscribe a material writing, with the intent
18 to present and use it, and to allow it to be presented to
19 COMPWEST INS., in support of a false and fraudulent claim, an did aid and abet, and solicit another to do the same.
20
21 COUNT 10: On or about and between September 04, 2012 and December 20, 2012, in violation of Section 550(a)(5) of the
22 Penal Code (INSURANCE FRAUD - WRITTEN CLAIM) , a FELONY, FARAMARZ
23 FRED KHALILI, SANDRA GARCIA MARTINEZ and HITENDRA HIRACHAND SB.AB MD, with the intent to defraud, did knowingly and unlawfully
24 prepare, make, and subscribe a material writing, with the intent
25 to present and use it, and to allow it to be presented to CRUM &
FORESTER, in support of a false and fraudulent claim, and 26 aid and abet, and solicit another to do the same.
27 I
28 I I I
FELONYCOMPLAINTWARRANT(DA CASE# 15F01341) OC DNA NOT ON FILE: FARAMARZ KHAUU, SANDRA MARTINEZ, HITENDRA SHAH
Exhibit 1
FARAMARZ FRED KHALILI OCDA WC14110013 PAGE 6
1 COUNT 11: On or about · and between September 04, 2012 and December 20, 2012, in violation of Section 550(a) (5) of the
2 Penal Code (INSURANCE FRAUD - WRITTEN CLAIM), a FELONY, FARAMARZ
3 FRED KHALILI, SANDRA GARCIA MARTINEZ and BITENDRA BIRACBAND S MD, with the intent to defraud, did knowingly and unlawfully
4 prepare, make, and subscribe a material writing, with the intent 5 to present and use it, and to allow it to be presented to
DISNEY, in support of a false and fraudulent claim, and did ai 6 and abet, and solicit another to do the same. 7
COUNT 12: On or about and between September 04, 2 012 an 8 December 20, 2012, in violation of Section 550(a) (5) of the 9 Penal Code (INSURANCE FRAUD - WRITTEN CLAIM), a FELONY, FARAMARZ
FRED KHALILI, SANDRA GARCIA MARTINEZ and BITENDRA BIRACBAND SSAB lO MD� with the intent to defraud, did knowingly and unlawfully 11 prepare, make, and subscribe. a material writing, with the intent
to present and use it, and to allow it to be presented to 12 EMPLOYERS, in support of a false and fraudulent claim, and did
13 aid and abet, and solicit another to do the same.
14 COUNT 13: On or about and between September 04, 2012 an
15 December 20, 2012, in violation of Section 550 (a) (5) of the Penal Code (INSURANCE FRAUD - WRITTEN CLAIM), a FELONY, FARAMARZ
l6 FRED ICBALILI, SANDRA GARCIA MARTINEZ and BITENDRA BIRACHAND .S
17 MD, with the intent to defraud, did knowingly and unlawfully prepare, make, and subscribe a material writing, with the intent
18 to present and use it, and to allow it to be presented to
19 FARMERS, in support of a false and fraudulent claim, and did ai and abet, and solicit another to do the same.
20
21 COUNT 14: On or about and between September 04, 2012 and December 20, 2012, in violation of Section 550(a) (5) of the
22 Penal Code (INSURANCE FRAUD - WRITTEN CLAIM), a FELONY, FARAMARZ
23 FREJj KHALILI, SANDRA GARCIA MARTINEZ and BITENDRA BIRACHAND SSAB MD, with the intent to defraud, did knowingly and unlawfully
24 prepar�, make, and subscribe a material writing, with.the intent
25 to present and use it, and to allow it to be presented to FIREMAN'S FOND, in support of a false and fraudulent claim, an
26 did aid and abet, and solicit another to do the same.
27 I
28 I I I
FELONY COMPLAINT WARRANT (DA CASE# 15F01341) OC DNA NOT ON FILE: FARAMARZ KHAUU, SANDRA MARTINEZ, HITENDRA SHAH
Exhibit 1
FARAMAR.Z FRED KHALILI OCDA WC14110013 PAGE 7
1 COUNT 15: On or about and between September 04, 2012 an December 20, 2012, in violation of Section 550{a) (5) of the
2 Penal Code {INSURANCE FRAUD - WRITTEN CLAIM) , a FELONY, FARAMARZ
3 FRED KHALILI, SANDRA GARCIA MARTINEZ and EITENDRA EIRACEAND S MD, with the intent to defraud, did knowingly and unlawfully
4 prepare, make, and subscribe a material writing, with the intent 5 to present and use it, and to allow it to be presented to
HARTFORD, in support of a false and fraudulent claim, and 6 aid and abet, and solicit another to do the same. 7
COUNT 16: On or about and between September 04, 2012 an 8 December 20, 2012, in violation of Section 550{a) (5) of the 9 Penal Code {INSURANCE FRAUD - WRITTEN CLAIM) , a FELONY, FARAMARZ
FRED KHALILI, SANDRA GARCIA MARTINEZ and EITENDRA EIRACEAND S lO MD, with the intent to defraud, did knowingly and unlawfully
11 prepare, make, and subscribe a material writing, with the intent to present and use it, and to allow it to be presented to ICW,
12 in support of a false and fraudulent claim, and did aid and
13 abet, and solicit another to do the same.
14 COUNT 17: On or about and between September 04, 2012 an
15 December 20, 2012, in violation of Section 550{a) (5) of the Penal Code {INSURANCE FRAUD - WRITTEN CLAIM), a FELONY, FARAMARZ
16 FRED KHALILI, SANDRA GARCIA MARTINEZ and BITENDRA BIRACEAND S
17 MD, with the intent to defraud, did knowingly and unlawfully prepare, make, and subscribe a material writing, with the intent
18 to present and use it, and to allow it to be presented to 19 LIBERTY MUTUAL, in support of a false and fraudulent claim, an
did aid and abet, and solicit another to do the same. 20
21 COUNT 18: On or about and between September 04, 2012 and December 20, 2012, in violation of Section 550{a) (5) of the
22 Penal Code {INSURANCE FRAUD - WRITTEN CLAIM), a FELONY, FARAMARZ
23 FRED KHALILI, SANDRA GARCIA MARTINEZ and EITENDRA EIRACEAND S MD, with the intent to defraud, did knowingly and unlawfully
24 prepare, make, and subscribe a material writing, with the intent
25 to present and use it, and to allow it to be presented to PACIFIC COMP, in support of a false and fraudulent
26 did aid and abet, and solicit another to do the same.
27 I
28 I I I
FELONY COMPLAINT WARRANT (DA CASE# 15F01341) OC DNA NOT ON FILE: FARAMARZ KHALIU, SANDRA MARTINEZ, HITENDRA SHAH
Exhibit 1
FARAMARZ FRED KHALILI OCDA WC14110013 PAGE 8
1 COUNT 19: On or about and between S eptember 04, 2012 an December 20, 2012, in violation of Section 5SO(a)(S) of the
2 Penal Code (INSORANCE FRAUD - WRITTEN CLAIM), a FELONY, FARAMARZ
3 FRED KHALILI, SANDRA GARCIA MARTINEZ and HITENDRA HIRACBAND S MD, with the intent to defraud, did knowingly and unlawfull
4 prepare, make, and subscribe a material writing, with the intent 5 to present and use it, and to allow it to be presented to
S�RIGHT, in support of a false and fraudulent claim, and did 6 aid and abet, and solicit another to do the same. 7
COUNT 20: On or about and between S eptember 04, 2012 an 8 December 20, 2012, in violation of Section 550(a) (5) of the 9 Penal Code (INSORANCE FRAUD - WRITTEN CLAIM) , a FELONY, FARAMARZ
FRED KHALILI, SANDRA GARCIA MARTINEZ and HITENDRA HIRACBAND SHAH lO MD, with the intent to defraud, did knowingly and unlawfully
11 prepare, make, and subscribe a material writing, with the intent to present and use it, and to allow it to be presented to
12 SEDWICK INS., in support of a false and fraudulent claim, an
13 did aid and abet, and solicit another to do the same.
14 COUNT 21: On or about and between September 04, 2012 an
15 December 20, 2012, in violation of Section 5SO(a) (5) of the Penal Code (INSORANCE FRAUD - WRITTEN CLAIM), a FELONY, FARAMARZ
16 FRED KHALILI, SANDRA GARCIA MARTINEZ and HITENDRA HIRACBAND SHAH
17 MD, with the intent to defraud, did knowingly and unlawfully prepare, make, and subscribe a material writing, with the intent
18 to present and use it, and to allow it to be presented to SENTRY
19 INS, in support of a false and fraudulent claim, and did aid an abet, and solicit another to do the same.
20
21 COUNT 22: On or about and between September 04, 2012 and December 20, 2012, in violation of Section 550(a) (5) of the
22 Penal Code (INSORANCE FRAUD - WRITTEN CLAIM), a FELONY, FARAMARZ
23 FRED KHALILI, SANDRA GARCIA MARTINEZ and HITENDRA HIRACHAND s MD, with the intent to defraud, did knowingly and unlawfull
24 prepare, make, and subscribe a material writing, with the intent
25 to present and use it, and to allow it to be presented to TRAVELERS, in support of a false and fraudulent claim, and di
26 aid and abet, and solicit another to do the same.
21 I
28 I
I
I
FELONY COMPLAINT WARRANT (DA CASE# 15F01341) OC DNA NOT ON FILE: FARAMARZ KHALILI, SANDRA MARTINEZ, HITENDRA SHAH
Exhibit 1
FARAMARZ FRED ICHALILI OCDA WC14110013 PAGE 9
1 COUNT 23: On or about and between September 04, 2012 an December 20, 2012, in violation of Section 550(a)(5) of the
2 Penal Code (INSURANCE FRAUD - WRITTEN CLAIM), a FELONY, FARAMARZ
3 FRED ICHALILI, SANDRA GARCIA MARTINEZ and BITENDRA BIRACBAND SHAH MD, with the intent to defraud, did knowingly and unlawfully
4 prepare, make, and subscribe a material writing, with the intent 5 to present and use it, and to allow it to be presented to YORK
RISK MGT, in support of a false and fraudulent claim, and di 6 aid and abet, and solicit another to do the same. 7
COUNT 24: On or about and· between September 04, 2012 8 December 20, 2012, in violation of Section 550 (a) (5) of the 9 Penal Code (INSURANCE FRAUD - WRITTEN CLAIM) , a FELONY, FARAMARZ
FRED KHALILI, SANDRA GARCIA MARTINEZ and HITENDRA BIRACBAND SHAH 10 MD, with the intent to defraud, did knowingly and unlawfully
11 prepare, make, and subscribe a material writing, with the intent to present and use it, and to allow it to be presented to
12 ZENITH, in support of a false and fraudulent claim, and did aid
13 and abet, and solicit another to do the same.
14 COUNT 25: On or about and between September 04, 2012 an
15 December 20, 2012, in violation of Section 550(a) (5) of the Penal Code (INSURANCE FRAUD - WRITTEN CLAIM), a FELONY, FARAMARZ
l6 FRED ICHALILI, SANDRA GARCIA MARTINEZ and BITENDRA BIRACBAND S
17 MD, with the intent to defraud, did knowingly and unlawfully prepare, make, and subscribe a material writing, with the intent
18 to present and use it, and to allow it to be presented to
19 ZURICH, in support of a false and fraudulent claim, and did aid and abet, and solicit another to do the· same.
20
21 COUNT 26: On or about November 15, 2012, in violation of Section 549 of the Penal Code (FALSE AND FRAUDULENT CLAIM), a FELONY,
22 FARAMARZ FRED KHALILI, S ANDRA GARCIA MARTINEZ and BITENDRA
23 HIRACHAND SHAH MD did unlawfully solicit, accept, and refer business to and from HEALTHCARE FINANCE MANAGEMENT, with the
24 knowledge that, and with reckless disregard for whether
25 HEALTHCARE FINANCE MANAGEMENT intended to violate Penal Code section 550 and Insurance Code section 1871.4.
26
21 I I
2a I I I
FELONY COMPLAINTWARRANT (DA CASE# 15F01341) OC DNA NOT ON FILE: FARAMARZ KHALILI, SANDRA MARTINEZ, HITENDRA SHAH
Exhibit 1
FARAMARZ FRED KHALILI OCDA WC14110013 PAGE 10
1 COUNT 27: On or about November 21, 2012, in violation of Section 549 of the Penal Code (FALSE AND FRAUDULENT CLAIM), a FELONY,
2 FARAMARZ FRED KHALILI, SANDRA GARCIA MARTINEZ and HITEND
3 HIRACBAND SHAH MD did unlawfully solicit, accept, and refer business to and from HEALTHCARE FINANCE MANAGEMENT, with the
4 knowledge that, and with reckless disregard for whether 5 HEALTHCARE FINANCE MANAGEMENT intended to violate Penal Code
section 550 and Insurance Code section .. 1871.4. 6
7 COUNT 28: On or about November 29, 2012, in violation of Section 549 of the Penal Code (FALSE AND FRAUDULENT CLAIM), a FELONY,
8 FARAMARZ FRED KHALILI I SANDRA GARCIA MARTINEZ and HITENDRA 9 HIRACHAND SHAH MD did unlawfully solicit, accept, and refer
business to and from HEALTHCARE FINANCE MANAGEMENT, with the lO knowledge that, and with reckless disregard for whether
11 HEALTHCARE FINANCE MANAGEMENT intended to violate Penal Code section 550 and Insurance Code section 1871.4.
12
13 COUNT 29: On or about December 06, 2012, in violation of Section 549 of the Penal Code (FALSE AND FRAUDULENT CLAIM), a FELONY,
14 FARAMARZ FRED KHALILI I SANDRA GARCIA MARTINEZ and HITEND
15 HIRACHAND SHAH MD did unlawfully solicit, accept, and refer business to and from HEALTHCARE FINANCE MANAGEMENT, with the
16 knowledge that, and with reckless disregard for whether
17 HEALTHCARE FINANCE MANAGEMENT intended to violate Penal Code section 550 and Insurance Code section 1871.4.
18
19 COUNT 30: On or about December 13, 2012, in violation of Section 549 of the Penal Code (FALSE AND FRAUDULENT CLAIM), a FELONY,
20 FARAMARZ FRED KHALILI, SANDRA GARCIA MARTINEZ and HITENDRA
21 HIRACBAND SHAH MD did unlawfully solicit, accept, and refer business to and from HEALTHCARE FINANCE MANAGEMENT, with the
22 knowledge that, and with reckless disregard for whether
23 HEALTHCARE FINANCE MANAGEMENT intended to violate Penal Code section 550 and Insurance Code section 1871.4.
24
25 COUNT 31: On or about December 20, 2012, in violation of Section 549 of the Penal Code (FALSE AND FRAUDULENT CLAIM), a FELONY,
26 FARAMARZ FRED KHALILI, SANDRA GARCIA MARTINEZ and HITENDRA
27 HIRACBAND SHAH MD did unlawfully solicit, accept, and refer business to and from HEALTHCARE FINANCE MANAGEMENT, with the
28 knowledge that, and with reckless disregard for whether HEALTHCARE FINANCE MANAGEMENT intended to violate Penal Code section 550 and Insurance Code section 1871.4.
FELONYCOMPLAINTWARRANT(DA CASE# 15F01341) OC DNA NOT ON FILE: FARAMARZ KHALILI, SANDRA MARTINEZ, HITENDRA SHAH
Exhibit 1
FARAMARZ FRED ICHALILI OCDA WC14110013 PAGE 11
1 COUNT 32: On or about December 28, 2012, in violation of Section
2 549 of the Penal· Code (FALSE AND FRAUDULENT CLAIM), a FELONY, FARAMARZ FRED KHALILI, SANDRA GARCIA MARTINEZ and HITENDRA
3 HIRACHAND SHAH MD did unlawfully solicit, accept, and refer business to and from HEALTHCARE FINANCE MANAGEMENT, with the 4 knowledge that, and with reckless disregard for whether
5 HEALTHCARE FINANCE MANAGEMENT intended to violate Penal Code section 550 and Insurance Code section 1871.4.
6
7 COUNT 33: On or about November 08, 2012, in violation of Section 650 of the Business & Professions Code (REBATES FOR
8 PATIENT REFERRALS) I a FELONY, HITENDRA HIRACHAND SHAH MD, a 9 person licensed under the Healing Arts Division of this Code an
the Chiropractic Initiative Act, did unlawfully offer, deliver, 10 receive, and accept any rebate, refund, commission, preference,
11 patronage dividend, discount, and other consideration as compensation and inducement for referring patients,
12 customers to HEALTHCARE FINANCE MANAGEMENT.
13 COUNT 34: On or about and between September 04, 2012 and
14 December 28, 2012, in violation of Section 2052(b) of the
lS Bus�ness and Professions Code (CONSPIRING IN THE UNAUTHORIZED PRACTICE OF MEDICINE), a FELONY, FARAMARZ FRED ICHALILI, SANDRA
16 GARCIA MARTINEZ and HITENDRA HIRACHAND SHAH MD did unlawfully
17 conspire .with another to practice, attempt to practice, hold himself or herself out as practicing a system and mode of
18 treating the sick and afflicted in the State of California, an
19 conspire with another to diagnose, treat, operate for, and prescribe for an ailment, blemish, deformity, disease,
20 dis�igurement, disorder, injury and physical or mental condition
21 of a person without a valid, unrevoked and unsuspended certificate provided in Chapter 5 of the California Business and
22 Professions Code or obtained in accordance with some other
23 provisions of la�. It is further alleged that pursuant to and for the purpose of carrying out the objects and purposes of the
24 conspiracy, one and more of the conspirators committed the
25 following overt acts:
26 OVERT ACT l
27 Fred Khalili formed Madison Management a California Corporation,
28 in 2009 and operated this business as.the owner and CEO.
FELONY COMPLAINT WARRANT (DA CASE# 15F01341) OC DNA NOT ON FILE: FARAMARZ KHALILI, SANDRA MARTINEZ, HITENDRA SHAH
Exhibit 1
FARAMARZ FRED KHALILI OCDA WC14110013 PAGE 12
1 OVERT ACT 2
2 Fred Khalili was in charge of First Choice Medical Group, a
3 Medical Corporation even though he was not a medical doctor.
4 OVERT ACT 3 5
First Choice Medical Group was operated as a clinic that 6 provided medical treatment to workers compensation patients. 7
OVERT ACT 4 8
9 Khalili instructed his attorney to file documents with the Secretary of State in California naming Dr. Julio Westerband,
lO M.D., as the owner and medical director of First Choice Medical
11 Group in 2009.
12 OVERT ACT 5
13 Khalili, and not Dr. Julio Westerband, M.D., controlled all of
l4 the bank accounts that were held by First Choice Medical Group.
15 OVERT ACT 6
16
17 Khalili only paid Dr. Julio Westerband, M.D., a per diem rate when Dr. Westerband, M.D., came to the clinic to see workers
18 compensation patients.
19 OVERT ACT 7
20
21 Dr. Julio Westerband, M.D., was not compensated as the owner an medical director of First Choice Medical Group by Khalili.
22
23 OVERT ACT 8
24 At Khalili's direction, Sandra Martinez hired Dr. Bitendra Shah,
25 M.D. to work as a physician with First Choice Medical Group.
26 OVERT ACT 9
27 Dr. Bitendra Shah and Dr. Craig Chanin prescribed these compoun
28 transdermal creams to workers compensation patients per Fred Khalili's instruction regardless of medical necessity.
FELONY COMPLAINT WARRANT (DA CASE# 15F01341) OC DNA NOT ON FILE: FARAMARZ KHALILI, SANDRA MARTINEZ HITENDRA SHAH
Exhibit 1
' f
FARAMARZ FRED KHALILI OCDA WC14110013 PAGE 13
1 OVERT ACT 10
2 Fred Khalili and Sandra Martinez were in charge of First Choice
3 Medical Group, and this medical clinic did not have a medical director between 9/1/12 through 1/1/13.
4
5 OVERT ACT 11
6 Khalili wrote a check (#2375) in the amount of $10, 000 to Curt's 7 Compounding Pharmacy on 12/12/12 for compound distributed in
First Choice Medical Group. 8
9 OVERT ACT 12
lO On 9 /1/12, Khalili entered into a contract with Healthcare
11 Finance Management, to distribute transdermal compound creams manufactured by Curt's Compounding Pharmacy, in Orange County.
12
13 ENHANCEMENT(S)
14 It is further alleged pursuant to Penal Code section 186.ll(a)
15 (1)/(2) (AGGRAVATED WHITE COLLAR CRIME - OVER $500, 000), that as to counts 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16,
16 17, 18, 19, 20, 21, 22, 23, 24 and 25, defendants FARAMARZ FRED
17 KHALILI, SANDRA GARCIA MARTINEZ and HITENDRA HIRACHAND SHAH MD engaged in a pattern of related fraudulent felony conduct
18 involving the taking of more than five hundred thousand dollars
19 ($500, 000).
20 As to Count(s) 26, 27, 28, 29 , 30, 31 and 32, it is further
21 alleged pursuant to Penal Code section 12022.6(a) (2) (PROPERT LOSS OVER $200, 000), that FARAMARZ FRED KHALILI, SANDRA GARCIA
22 MARTINEZ and HITENDRA HIRA:CBAND SHAH MD intentionally took,
23 damaged, and destroyed property valued in excess of two hundred thousand dollars ($200, 000) during the commission and attempted
24 commission of the above offense.
25 As to Count(s) 34, it is further alleged pursuant to Penal Code
26 section 12 022. 6 (a) (2) (PROPERTY LOSS OVER $2 00, 000), that FARAMARZ FRED KHALILI, SANDRA GARCIA MARTINEZ and HITENDRA
27 HIRACHAND SHAH MD intentionally took, damaged, and destroyed
28 property valued in excess of two hundred thousand dollars ($200, 000) during the commission and attempted commission of the above offense.
FELONY COMPLAINT WARRANT (DA CASE# 15F01341) OC DNA NOT ON FILE: FARAMARZ KHAUU, SANDRA MARTINEZ, HITENDRA SHAH
Exhibit 1
FARAMARZ FRED KHALILI OCDA WC14110013 PAGE 14
l
I declare under penalty of perjury, on information and belief, 2
that the foregoing is true and correct. 3
Dated 02- 18-2016 at Orange County, California. 4 KS/AC 15F01341 5
6
7
8
9 RESTITUTION
10
11 [ ] None [ ] $
12 [ x ] To be
13 BAIL RECOMMENDATION:
14
15 FARAMARZ FRED KHALILI $ 250,000.00 SANDRA GARCIA MARTINEZ $ 250,000.00
16 HITENDRA HIRACHAND SHAH MD $ 250,000.00
17 NOTICES:
18
19 The People request that defendant and counsel disclose, within 15 days, all of the materials and information described in Penal
20 Code section 1054.3, and continue to provide any later- acquired
21 materials and information subject to disclosure, and without
22
23
further request or order.
Pursuant to Welfare & Institutions Code §827 and California Rule 24 of Court 5.552, notice is hereby given that the People will see
25 a court order to disseminate the juvenile case file of the defendant/minor, if any exists, to all parties in this action,
26 through their respective attorneys of record, in the prosecution of this case. 27
28
FELONY COMPLAINT WARRANT (DA CASE# 15F01341) OC DNA NOT ON FILE: FARAMARZ KHALILI, SANDRA MARTINEZ, HITENDRA SHAH
Exhibit 1
CLOSED
U.S. District CourtEastern District of California - Live System (Sacramento)
CRIMINAL DOCKET FOR CASE #: 2:96-cr-00156-EJG-1
Case title: USA v. KhaliliOther court case numbers: 2:95-cr-00379 `6
2:95-cr-00433 `62:95-cr-00440 `62:96-cr-00153 `62:96-cr-00154 `62:96-cr-00157 `62:96-cr-00433 `6
Date Filed: 04/10/1996Date Terminated: 02/21/1997
Assigned to: Senior Judge Edward J. Garcia
Defendant (1)Faramarz Fred KhaliliTERMINATED: 02/21/1997
represented by Brian James Hennigan Irell and Manella 1800 Avenue of the Stars Suite 900 Los Angeles, CA 90067-4276 310-203-7040 TERMINATED: 02/21/1997LEAD ATTORNEYATTORNEY TO BE NOTICEDDesignation: Retained
Pending Counts Disposition
18:1341.F Mail Fraud(1)
8 Months Imprisonment to be served concurrently; TSR 36 Months; S/A $100; Fine waived; surrender date 3/17/97; appeal rights given
26:7206B.F False Statement on Tax Retruns(2)
8 Months Imprisonment to be served concurrently; TSR 36 Months; S/A $100; Fine waived; surrender date 3/17/97; appeal rights given
Highest Offense Level (Opening)Felony
Page 1 of 6LIVE 6.1 CM/ECF - U.S. District Court for Eastern California
1/24/2018https://ecf.caed.uscourts.gov/cgi-bin/DktRpt.pl?579646921545028-L_1_0-1Exhibit 2
LIVE 6. 1 CM/ECF - U.S. District Comi for Eastern California Page 2 of 6
Terminated Counts Disposition
None
Highest Offense Level (Terminated)
None
Complaints
None
Plaintiff
USA
Date Filed
04/10/1996
04/10/1996
04/12/1996
04/19/1996
04/23/1996
05/09/1996
#
1
2
3
4
5
6
Disposition
represented by Daniel S. Linhardt United States Attorney 501 I Street
Docket Text
Suite 10-100 Sacramento, CA 95814 916-554-2700 Email: [email protected] LEAD ATTORNEY ATTORNEY TO BE NOTICED
INFORMATION by US Attorney Daniel S Linhardt Faramarz Fred Khalili (1) count(s) 1, 2 (kb) (Entered: 04/12/1996)
LETTER to court from counsel for plaintiff USA re non-involvement by DFL and GEB (kb) (Entered: 04/12/1996)
NOTICE of hearing arraignment set for 2:00 5/3/96 for Faramarz Fred Khalili (kb) (Entered: 04/12/1996)
NOTICE OF RELATED CASES by plaintiff USA: 2:95-cr-378, 2:95-cr-433, 2:95-cr-435, 2:96-cr-12, 2:96-cr-153, 2:96-cr-1 54, 2:96-157 (old) (Entered: 04/22/1996)
NOTICE of hearing by USA: anaignment re-set for 2:00pm on 5/24/96 for Faramarz Fred Khalili (old) (Entered: 05/01/1996)
ORDER by Honorable Lawrence K. Karlton: IT IS ORDERED that the actions denominated CR Nos. S-96-0153 WBS, S-96-0154 LKK, S-96-0156 DFL and S-96-0157 DFL be, and the same hereby are, reassigned to Judge Edward J. Garcia for all fmiher proceedings, and any date currently set in this reassigned cases only are hereby VACATED, Hencefo11h, the caption on all documents filed in the reassigned cases shall be shown as CR Nos. S-96-01 53 EJG, S-96-0154 EJG, S-96-0156 EJG and S-96-0157 EJG respectively; IT IS FURTHER ORDERED that the Clerk of the Comi make appropriate adjustment in the
https://ecf.caed.uscomis.gov/cgi-bin/DktRpt.p~Ai~545028-L_l_O- l 1124/2018
LIVE 6.1 CM/ECF - U.S. District Comi for Eastern California Page 3of6
assignment of criminal cases to compensate for these reassignments (cc: all counsel) (old) (Entered: 05/09/ 1996)
05/28/ 1996 7 NOTICE of hearing by USA: anaignment VACATED (old) (Entered: 05/30/1996)
06/ 14/1996 8 NOTICE of hearing by USA the hearing set for 6/14/96 at 2:00pm is removed from calendar (kb) (Entered: 06/ 17 / 1996)
09/24/1996 9 NOTICE of hearing by USA arraignment set for 9:00 9/27/96 for Faramarz Fred Khalili (kb) (Entered: 09/25/1996)
09/27/ 1996 10 WAIVER oflndictment by defendant Faramarz Fred Khalili (old) (Entered: 09/30/1996)
09/27/1996 11 PLEA Agreement as to Faramarz Fred Khalili (old) (Entered: 09/30/ 1996)
09/27/ 1996 12 SCHEDULE FOR DISCLOSURE OF PSR as to defendant Faramarz Fred Khalili (old) (Entered: 09/30/ 1996)
09/27/1996 13 MINUTES before Judge Edward J Garcia: Faramarz Fred Khalili enters guilty plea to 2 counts of information anaignment was held on 9/27196; sentencing hearing set for 9:00am on 116/97 for Faramarz Fred Khalili; dft plead guilty to Rule 20 Indictment received (C3-95-l 14 District N DA) CIR P McNamara (old) (Entered: 09/30/ 1996)
09/27/ 1996 14 NOTICE TO DEFENDANT BEING RELEASED as to dft Faramarz Khalilt (old) (Entered: 09/30/1996)
10/04/1996 15 ORDER by Judge Edward J. Garcia relating case(s) with member case(s) number CR-S-96-157 EJG (cc: all counsel) (old) (Entered: 10/04/1996)
10/08/1996 16 PRESENTENCE NOTIFICATION as to defendant Faramarz Fred Khalili (kb) (Entered: 10/09/ 1996)
10/ 15/ 1996 17 TRANSCRIPT of Change of plea hearing on 9/27196 by CIR Margaret A McNamara (kb) (Entered: 10/ 16/1996)
01117/ 1997 18 NOTICE of hearing: sentencing hearing reset for 9:00am on 2/3/97 for Faramarz Fred Khalili (old) (Entered: 01122/ 1997)
01122/ 1997 19 RELATED CASE ORDER by Judge Edward J. Garcia relating case(s) with members cases 2:96-cr-378 EJG; 2:95-cr-433; 2:95-cr-435; 2:95-cr-440; 2:96-cr-012; 2:96-cr-153; 2:96-cr-154; 2:96-cr-156; 2:96-cr-1 57; 2:95-cr-431; 2:97-cr-018 EJG (cc: all counsel) (old) (Entered: 01122/1997)
01123/1997 20 NOTICE by plaintiff USA of related case 2:96-cr- l 98 GEB (old) (Entered: 01124/1997)
01124/ 1997 21 NOTICE OF MOTION AND MOTION pursuant to Seeton 5Kl.l of the Federal Sentencing Guidelines for a downward depa1ime by USA as to Faramarz Fred Khalili; hearing set for 9:00 1127/97 (kdc) (Entered: 01127/ 1997)
01129/1997 22 ORDER by Judge Edward J. Garcia relating case(s) 2:96cr156 with member case 2:96cr198 (cc: all counsel) (kb) (Entered: 01129/1997)
https : //ecf.caed.uscomis.gov/cgi-bin/DktRpt.p~Ai~545028-L_l_O-l 1124/2018
LIVE 6. 1 CM/ECF - U.S. District Comi for Eastern California Page 4of6
01129/1997 23 ORDER by Judge Edward J. Garcia sentencing hearing RESET for 9:00 2/18/97 for Faramarz Fred Khalili (cc: all counsel) (kb) (Entered: 01130/1997)
02/10/1997 24 NOTICE of hearing sentencing hearing continued to 9:00 2/21197 for Faramarz Fred Khalili (kb) (Entered: 02/12/1997)
02/10/1997 25 MOTION for coITection of presentence rep01i by defendant Faramarz Fred Khalili hearing set for 9:00 2/18/97 before Judge Edward J. Garcia (kb) (Entered: 02/13/1997)
02/2111997 26 MINUTES before Judge Edward J. Garcia sentencing Faramarz Fred Khalili (1) count(s) 1, 2. 8 Months Imprisonment to be served concurrently with CR S 96-198 EJG; TSR 36 Months; SIA $100; Fine waived; surrender date 3/17/97; appeal rights given , terminating defendant Faramarz Fred Khalili case te1minated ; CIR Peggy McNamara (old) (Entered: 02/26/1997)
02/2111997 27 SENTENCING memorandum regarding Faramarz Fred Khalili (old) (Entered: 02/26/1997)
02/27/1997 28 RELATED CASE ORDER by Judge Edward J Garcia relating lead case CRS 95-0379 EJG with member case CRS 97-043 MLS (cc: all counsel) (ljr) (Entered: 02/27/1997)
02/28/1997 29 JUDGMENT and Commitment issued as to Faramarz Fred Khalili by Judge Edward J Garcia (old) (Entered: 03/03/1997)
03/1111997 30 MOTION to modify sentence by defendant Faramarz Fred Khalili (kb) (Entered: 03/12/1997)
03/17/1997 31 OPPOSITION by USA to motion to modify sentence [30-1] (ndd) (Entered: 03/18/1997)
03/2111997 32 JUDGMENT and Commitment returned executed on 3/17 /97 as to Faramarz Fred Khalili (ndd) (Entered: 03/25/1997)
03/3111997 33 ORDER by Judge Edward J Garcia ORDERING: dft's motion to modify his sentence is DENIED (cc: all counsel) (old) (Entered: 03/3111997)
08/22/1997 34 RELATED CASE ORDER by Judge Edward J. Garcia ORDERED that relating 2:96cr156 with member of case 2:96cr466 (cc: all counsel) (ndd) (Entered: 08/22/1997)
09/18/1997 35 RELATED CASE ORDER by Judge Edward J. Garcia relating er 96-156 with member cases er 97-463 and er 97-464 (cc: all counsel) (ndd) (Entered: 09/18/1997)
11106/1997 36 RELATED CASE ORDER by Judge Edward J. Garcia RELATING new case 2:97-cr-512 with lead case 2:95-cr-379 (cc: all counsel) (kdc) (Entered: 11106/1997)
12/12/1997 37 RELATED CASE ORDER by Judge Edward J Garcia ORDERING: the action denominated 2:96-cr-104 GEB is reassigned to Judge Garcia; the clerk is to make the appropriate adjustment in the assignment of criminal cases (cc: all counsel) (old) (Entered: 12/12/1997)
https : //ecf.caed.uscomis.gov/cgi-bin/DktRpt.p~Ai~545028-L_l_O- l 1124/2018
LIVE 6. 1 CM/ECF - U.S. District Comi for Eastern California Page 5of6
01120/1998 38 PROBATION Form 22 - Transferring Faramarz Fred Khalili to Central District of California by Judge Edward J Garcia (old) (Entered: 01123/1998)
01130/1998 39 TRANSMITTAL of documents including ce1iified of indictment, transferral order, judgment and sentencing and docket sheet (ndd) (Entered: 01130/1998)
02/06/1998 40 RELATED CASE NOTICE by plaintiff USA (ljr) (Entered: 02/09/1998)
02/09/1998 41 RECEIPT of Acknowledgment of transmittal of documents for defendant Faramarz Fred Khalili by Central District of CA (ndd) (Entered: 02/10/1998)
02/1111998 42 RELATED CASE ORDER by Judge Edward J. Garcia ORDERED that relating case 2:96cr156 with member of case 2:97cr578 (cc: all counsel) (ndd) Modified on 02/ 13/1998 (Entered: 02/1111998)
04/16/1998 43 NOTICE OF RELATED CASES by plaintiff USA - relating cases 2:98CR175 and 2:98CR173 (old) (Entered: 04/17 /1998)
04/27/1998 44 RELATED CASE ORDER by Judge Edward J. Garcia that the actions denominated CRS 98-173 WBS and CRS 98-175 MLS be and the same hereby are REASSIGNED to Judge Edward J Garcia (cc: all counsel) (ljr) (Entered: 04/27 /1998)
05/08/1998 45 NOTICE by plaintiff USA relating CR F-98-5079 REC to this case (old) (Entered: 05/1111998)
07/10/1998 46 RELATED CASE ORDER by Judge Edward J. Garcia CRS 98-079 GEB is REASSIGNED to EJG (cc: all counsel) (ljr) (Entered: 07/10/1998)
07/14/1998 47 NOTICE of related cases by plaintiff USA re CRS 98-297 WBS (ljr) (Entered: 07/16/1998)
07/16/1998 48 RELATED CASE ORDER by Judge Edward J. Garcia CRS 98-297 WBS is REASSIGNED to EJG (cc: all counsel) (ljr) (Entered: 07/16/1998)
08/06/1998 49 NOTICE by plaintiff USA of related cases (old) (Entered: 08/07 /1998)
08/10/1998 50 RELATED CASE ORDER by Judge Edward J. Garcia ORDERING relating LEAD case(s) 2:95-cr-379 EJG with member cases 2:98-cr-143; CRS 98-143 DFL REASSIGNED to EJG; reassigned case shall be shown as CR S 98-143 EJGJ (cc: all counsel) (ljr) (Entered: 08/10/1998)
08/1111998 51 NOTICE by plaintiff USA of related cases (old) (Entered: 08/12/1998)
08/17/1998 52 RELATED CASE ORDER by Judge Edward J. Garcia ORDERING relating LEAD case 2:95-cr-379 with member cases 2:98-cr-346 ; CR S 98-346 LKK REASSIGNED to EJG (cc: all counsel) (ljr) (Entered: 08/17/1998)
10/0111998 53 NOTICE by plaintiff USA of related case CR S-98-383 DFL (kh) Modified on 10/19/1998 (Entered: 10/06/1998)
12/0111999 54 NOTICE ofrelated cases by plaintiff 96-cr-156 ... 99-cr-450 (ch) (Entered: 12/02/1999)
0113112000 55 RELATED CASE ORDER by Judge Edward J. Garcia ordering that case 2:96cr156 is related to member case numbers 2:95cr379, 2:95cr433, 2:95cr435,
https : //ecf.caed.uscomis.gov/cgi-bin/DktRpt.p~Ai~545028-L_l_O- l 1124/2018
LIVE 6.1 CM/ECF - U.S. District Comi for Eastern California Page 6of6
2:95cr440, 2:96cr0012, 2:96crl53, 2:96cr154, 2:96cr157, 2:95cr431, 2:97cr018, 2:97cr043, 2:97cr271, 2:97cr272, 2:97cr273, 2:97cr274, 2:97cr276, 2:97cr277, 2:96cr466, 2:97cr463, 2:97cr464, 2:97cr512, 2:96cr104, 2:97cr578, 2:98cr173, 2:98crl 75, 2:98cr079, 2:98cr297, 2:98cr143, 2:98cr346, 2:98cr383, 2:99cr450, 2:00cr025 (cc: all counsel) (as) (Entered: 01/31/2000)
I PACER Service Center
I Transaction Receipt
I 01/24/2018 14:56:19
IPAC:ER Logm: lldi0237:2536794:0llclient Code: llAFU
!Description: llDocket Report llSearch Criteria:
112: 96-cr-OO 15 6-EJG I
!Billable Pages: 114 llcost: 110.40 I
https://ecf.caed.uscomis.gov/cgi-bin/DktRpt.p~Ai~545028-L_l_O- l 1124/2018
2/20/2018 Board of Chiropractic Examiners
http://www2.dca.ca.gov/pls/wllpub/WLLQRYNA$LCEV2.QueryView?P_LICENSE_NUMBER=19178&P_LTE_ID=808 1/2
BOARD OF CHIROPRACTIC EXAMINERSLicensee Name: KHALILI FARAMARZ FREDLicense Type: ChiropractorLicense Number: 19178License Status: REVOKED DefinitionExpiration Date: January 31, 2001Issue Date: January 01, 1988Address: P.O. BOX 9711City: NEWPORT BEACHState: CAZip: 92658County: ORANGEActions: Yes
Related Licenses/Registrations/Permits
No records returned
Disciplinary Actions
May 18, 1999 ACCUSATION FILEDJuly 28, 2000 LICENSE REVOKEDJanuary 25, 2012 PET. FOR REINSTATEMENT FILEDFebruary 28, 2013 PET. FOR REINSTATEMENT DENIEDPublic Record Action(s)
CITATIONS
No records returned
Disclaimer for Disciplinary Action Summary The reports contained as part of this web site represent summaries of those formal disciplinary ordersissued by the Department of Consumer Affairs (DCA) and its participating programs, boards,committees, and commissions, imposing suspension, revocation or other discipline. Disciplinaryproceedings which are resolved by dismissal of the accusation or otherwise result in no actualdiscipline of a license are not reported at this web site. The lack of a summary for a particular licensedperson does not mean that the licensee has never been the subject of an accusation or administrativediscipline.
Summary information on recent orders is prepared approximately ninety (90) days after the finaldecision date of a disciplinary case. Therefore, although this web site may presently lack any suchreport, some licensees will actually be named in accusations, or be subject to disciplinary orders.
The brief summaries offered at this web site are not intended as substitutes for the actual decisionsand orders issued by the Department of Consumer Affairs. Copies of those decisions and orders areavailable at no cost by writing to the designated address for each program or board.
Also, the actions reported here may not be final and may not reflect any judicial action to stay ormodify the administrative order. You should not take any action based on information contained inthese summaries without verifying the information and determining whether the administrative orderhas been stayed or modified by a court.
As used in this summary, the term "accusation" is a formal document that notifies a licensee of theagency's charges against the licensee, and that requests a disciplinary order. The licensee is entitledto contest the charges in a formal hearing before an administrative law judge. An accusation is usuallyresolved by an agency decision following such a hearing or by an agency decision pursuant to asettlement agreement. Often there is a considerable period of time between the date of filing anaccusation and the resolution of the accusation.
The term "suspended" means that the licensee's right to practice has been suspended for a period oftime, usually for a specified number of days or months. A suspended licensee may not practice duringthe period of suspension. A suspension will usually be imposed in conjunction with a lengthy period ofprobation of two or more years.
The term "revoked" means that the licensee's right to practice has been completely taken away.Revocation is not necessarily permanent, however. A person whose license is revoked has the right,one year or more after the revocation, to apply for reinstatement. Some applications are successful.The applicant for reinstatement must, however, demonstrate to the BOARD OF CHIROPRACTICEXAMINERS that the applicant is rehabilitated and is fit to resume practice.
Contact Us | Enforcement | Laws & Regs
CONSUMERS APPLICANTS LICENSEES ABOUT US
SearchThis Site California
Exhibit 3
2/20/2018 Board of Chiropractic Examiners
For more information regar<ling these actions. please write to tile BOARD OF CHIROPRACTIC EXAMINERS at Ille following address:
901 P street, Suite 142A Sacramento. CA 95814 Attn: Enforcement Unit
This information is updated Monday through Friday· Last updated: FEB-19-2018
Disclaimer All information provided by the Department of Consumer Affairs on this web page, and on its other web pages and internet sites, is made available to provide immediate access for the convenience of interested persons. Wflile the Department believes the information to be reliable, fluman or mecflanical error remains a possibility, as does delay in the posting or updating of information. Tfleretore, the Department makes no guarantee as to the accuracy, completeness, timeliness, currency, or correct sequencing of the information. Neither the Department, nor any of the sources of the information, sfla// be responsible for any errors or omissions, or tor the use or results obtained from the use of this information. Other specific cautionary notices may be included on other web pages maintained by the Department. All access to and use of this web page and any other web page or internet site of the Department is governed by the Disclaimers and Conditions for Access and Use as set forth at California Department of Consumer Affairs' Disclaimer Information and Use Information.
I Back I
http://WWW2..dca.ca.gov/pls/wllpub/WLLQRYNA$LCEV2. QueryView?PEllWf'En'f ~ER=19178&P _LTE_ID=808 212
Exhibit 4
Exhibit 4
Exhibit 4
Exhibit 4
Exhibit 4
Exhibit 4
Exhibit 4
Exhibit 4
Exhibit 5
Exhibit 5
Exhibit 5
Exhibit 5
Exhibit 5
Exhibit 5