agency#: dar2016125003a/rda4patientsafety.org/documents/doshi, tushar ramnik... · defendant,...

CASH BOND RECOMMENDED: $25.000.00 WARRANT

MICHAEL A. HESTRIN DISTRICT ATTORNEY

AGENCY#: DAR2016125003A/RDA

SUPERIOR COURT OF CALIFORNIA COUNTY OF RIVERSIDE

(Riverside)

THE PEOPLE OF THE STA TE OF CALIFORNIA, D.A.# 361668

TUSHAR RAMNIK DOSHI DOB: 07/ 1911956

v. Plaintiff, CASE NO.

FELONY COMPLAINT

OTHER- SPS

Defendant.

COUNT I

The undersigned, under penalty of perjury upon information and belief, declares: That the above named defendant, TUSHAR RAMNIK DOSHI, committed a violation of Penal Code section 550, subdivision (a), subsection ( 6), a felony, in that on or about January I, 2009 through and including July 15, 2014, in the County of Riverside, State of California, the defendant 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 ACE, 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 defendant, TUSHAR RAMNIK DOSHI, with the intent so to do, took, damaged and destroyed property of a value exceeding $3,200,000, within the meaning of Penal Code section 12022.6, subdivision (a), subsection (4).

COUNT2

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 AMERICAN INTERNATIONAL GROUP (AIG), 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 defendant, TUSHAR RAMNIK DOSHI, 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).

COUNT3

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 BERKSHIRE/HATHAWAY, 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.


COUNT4

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 CNA INSURANCE, 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.


COUNTS

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 BENEFIT 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.


2

COUNT6

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 CRUM & FORESTER, 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.


COUNT7

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 EMPLOYERS, 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 defendant, TUSHAR RAMNIK DOSHI, 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).

COUNT 8

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 EVEREST NATIONAL INSURANCE COMPANY (ENIC), 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 defendant, TUSHAR RAMNIK DOSHI, with the intent so to do, took, damaged and destroyed 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 ).

3

'

COUNT9

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 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.


COUNTlO

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 FIREMAN'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.


COUNT 11

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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.


4

COUNT12

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 INSURANCE CARRIERS 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.


COUNT 13

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 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.


COUNT14

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 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.

It is further alleged that in the commission and attempted commission of the above offense the said defendant, TUSHAR RAMNIK DOSHI, with the intent so to do, took, damaged and destroyed 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).

5

COUNT 15

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 ST A TE COMPENSATION INSURANCE FUND (SCIF), 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.


COUNT 16

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 TRAVELERS, 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.


COUNT17

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 ZENITH, 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 defendant, TUSHAR RAMNIK DOSHI, with the intent so to do, took, damaged and destroyed 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 ).

6

COUNT 18

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 ZURICH, 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 defendant, TUSHAR RAMNIK DOSHI, 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).

It is further alleged that the said defendant, TUSHAR RAMNIK DOSHI, committed two or more related felonies, 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 than five hundred thousand dollars ($500,000.00) within the meaning of Penal Code section 186.11 , subdivision (a), subsection (2).

Special Allegation: Zamora It is further alleged that the above offense was not discovered by the victim(s) until March 26, 2012,

when the State Compensation Insurance Fund 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 service 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 inter-agency team including the Office of the Riverside County District Attorney. Further investigation by the Riverside County District Attorney uncovered a highly sophisticated criminal organization. Over an approximately twoyear period, the investigation discovered the use of cappers, law offices, and health clinics operated by support staff, chiropractors, and medical doctors all working as directed by Peyman Heidary to bill for similar services and treatment regardless of injury.

The scheme was not discovered prior to SCIF Investigator Phillis Shorts' findings due to multiple layers of ownership and control, voluminous legal files, medical records, billing involving hundreds of patient victims, and multiple regulatory violations overseen by multiple enforcement agencies.

The Office of the Riverside County District Attorney filed a criminal complaint in case number RIF1409778 against Peyman Heidary, Cary Abramowitz, Michael Tuosto, and Erica Torres on July 25, 2014. (People v. Zamora (1976) 18 Cal.3d 538.)

7

MARSY' S LAW

Information contained in the reports being distributed as discovery in this case may contain confidential information protected by Marsy's Law and the amendments to the California Constitution Section 28. Any victim(s) in any above referenced charge(s) is entitled to be free from intimidation, harassment, and abuse. It is unlawful for defendant(s), defense counsel, and any other person acting on behalf of the defendant(s) to use any information contained in the reports to locate or harass any victim(s) or the victim(s)'s family or to disclose any information that is otherwise privileged and confidential by law. Additionally, it is a misdemeanor violation of California Penal Code § 1054.2a(3) to disclose the address and telephone number of a victim or witness to a defendant, defendant's family member or anyone else. Note exceptions in California Penal Code § 1054.2a(a) and (2).

I declare under penalty of perjury upon information and belief under the laws of the State of California that the foregoing is true and correct.

Dated: May 6, 2016

IW

8

Michael A. Hestrin District Attorney

By: Erika L. Mulhere Deputy District Attorney

agency#: dar2016125003a/rda4patientsafety.org/documents/doshi, tushar ramnik... · defendant,...

Documents