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1 ALEXANDER ROBERTSON, IV (State Bar No. 127042) firstname.lastname@example.org 2 ROBERTSON & ASSOCIATES, LLP 880 Hampshire Road, Suite B 3 Westlake Village, California 91361 Telephone: (805) 418-9900 • Facsimile: (805) 418-9901
OF ORIGINAL FILED
Los Angeles SUperior Court
MAY 0 9 2012
John A: Clarke, EXecutive Officer/Clerk By M. Kurihara, Deputy
JOHN M. WALKER, Esq. (State Bar #89723) j email@example.com. . LAW OFFICES OF JOHN M. WALKER 6 5850 Canoga Ave., 4th Floor Woodland Hills, CALIFORNIA 91367 7 Telephone: (818) 719-9181- Facsimile: (818) 719-9164
8 Attorneys for PLAINTIFFS
SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, WEST DISTRICT Case No.
11 STEVE MANDEL, M.D.; JOELPOPSON,
M.D.; RANDY TAYLOR, M.D.; ARMAN 12 KARAPETYAN, M.D.,
,,-,(1111 ~OQ~O . ~)'vUh
COMPLAINT FOR IDENTITY THEFT
(Civil Code §1798.93)
15 MICHAEL o.MIDI, M.D.; KAMBIZ 16 ROBERT SILVERMAN, ESQ.;
BENlAMIA OMIDI, aka JULIAN OMIDI; CASE MANAGEMENT CONFERENCE
ALEXANDER WEISSE, ESQ.; ED 17 DeFRANK, ESQ.; INDEPENDENT MEDICAL SERVICES, INC.; CINDY 18 OMIDI; SURGERY CENTER MANAGEMENT, LLC.; GOLDEN STATE PRACTICE MANAGEMENT, LLC.; 19 ELLIOT ALPERT, M.D.; and DOES 1 through 100, inclusive, 20
?: ~tJp fI1 l=Date
21 22 23 24 25
COME NOW Plaintiffs, and each of them, and complain and allege as follows:
NATURE OF THE ACTION
The Plaintiffs are all medical doctors who reside in the County of Los Angeles and
26 provided medical services as independent contractors on an as-needed basis to patients of 27 ambulatory surgery centers CASC's") owned and operated by Defendants, MICHAEL OMIDI, 28 M.D., JULIAN OMIDI (collectively referred to herein as the "OMIDIS"). The Plaintiffs were
ROBERTSON & ASSOCIATES, LLP
typically informed on a weekly basis what their schedule would be-and which surgery center they were scheduled to report to on a given day.: Typically, the Plaintiffs.wouldnot knowthe identities
of the patients, or which specific type of surgery was scheduled for each patient until they arrived at the surgery centers on the day(s) they were scheduled. The Plaintiffs were typically paid on an hourly basis for the surgeries they performed from time to time at the various surgery centers owned and operated by the OMIDIS. Asindependent contractors, the Plaintiffs did not prepare
any of the bills sent to the patients' insurance companies by the OMIDIS; nor were the Plaintiffs made aware of the amount of the charges.made to, or payments received from the patients' insurance companies to the OMIDIS or their affiliated companies. 2. Plaintiffs are informed and believe, and thereon allege, that the OMIDISpaid the
. doctors who were independent contractors through TOP SURGEONS, INC. and/or SURGERY· CENTER MANAGEMENT, INC. between 2009 until the beginning of2011. However, Plaintiffs
are informed and believe that commencing sometime in 2011, the doctors who were independent contractors began receiving payment of their wages from INDEPENDENT MEDICAL SERVICES, INC., (hereinafter referred to as "IMS"). 3. Plaintiffs are-informed and believe, and.thereon alleges that in or about May 2011,
the doctors who provided medical services at the OMIDIS' surgery centers as independent contractors were contacted by one of the OMIDIS' in-house attorneys, ALEXANDER WEISSE, Esq. (hereinafter referred to as ."WEISSE") and were told that the OMIDIS needed to change the way they were billing their patients' insurance companies. Specifically, WEISSE told the Plaintiffs that certain insurance companies had "red flagged" the bills from.the OMIDIS and their affiliated companies and that the OMIDIS wanted to set up separate professional corporations for _ each doctor so they could bill the insurance companies under the name of each doctor's new corporation to avoid the insurance companies recognizing that these bills were for procedures performed at surgery centers owned and operated by the OMIDIS. 4.· As a result,WEISSE informed the Plaintiffs ofthe following scheme: The
OMIDIS would create new professional medical corporations for each ofthe doctors working
their various surgery centers at no cost to the doctors. The OMIDIS would then bill the patients'
1 insurance companies for the medical services provided by each doctor under the doctors' new 2 3 4 5 corporate name, however,the doctors would not be allowed to see any of those bills and 100% of the money paid by the patients' insurance companies to the doctors··corporations would be collected and kept by the OMIDIS or one of their affiliated companies, Further, WEISSE explained that the OMIDIS would pay all income tax owed by the new corporations for the explained to the Plaintiffs
6 payments made by the patients' insurance companies. Finally,WEISSE 7 that they wouldcontinue
to be paid their hourly rate, and would not receive any payment from
8 their professional medical corporations as all income would be assigned to and kept by one of the 9 10 11 OMIDIS'affiliated companies.
Not knowing the legality of this proposal, the Plaintiffs aUjointly retained an
experienced health law attorney to review this proposal and to advise them accordingly .. The
12 health law attorney engaged in numerous discussions with WEISSE and ED DEFRANK, ESQ., 13 who also was an in-house attorney for the OMIDIS,and repeatedly told WEISSE and DEFRANK 14 that this proposed scheme would violate Business & Professions Code §650 (anti-kickback
15 statute) and possibly state and federal income tax laws as well. 16.
17 6. Plaintiffs are informed and believe, and thereon allege, that on or about June 22,
2011, DefendantMI CHAEL OMIDI sent an email to the Plaintiffs, mocking the advice given to •
18 the Plaintiffs by their health law attorney and assured the Plaintiffs that the proposed scheme and
19 contract was legal and did not violate the "kick-back" law. 7. Plaintiffs are informed and believe, and thereon allege that on or about June 23,
21 22 23 24
2011, WEISSE transmitted a proposed contract to the Plaintiffs, which memorialized the abovereferenced scheme. Plaintiffs are further informed and believe that the Plaintiffs all refused to sign the proposed contract and refused to go along with the OMIDIS' proposed scheme and did not consent to allow the OMIDIS, or their agents, to create professional medical corporations for
25 . them, did not consent to allow the OMIDIS, or their agents, to bill patients' insurance companies 26 27 for the medical services rendered by the Plaintiffs under the name of a new professional medical corporations, and did not consent to the OMIDIS, or their agents, collecting and keeping 100% of
& AsSOCIATES, LLP
1 the payments made by the patients' insurance companies to any hew professional medical 2 corporation formed for the Plaintiffs by the OMIDIS, or their agents. 8. Plaintiffs are .informedand believe, and thereon allege, that in August, 2011~ they
received a letter from INDEPENDENT MEDICAL SERVICE, INC., threatening that unless they
5· agreed to sign the proposed new contract (which included the formation of the above-referenced 6 new professional medical corporations) the Plaintiffs' schedules would be reduced or cut and their 7 8 services terminated. Thereafter, because the Plaintiffs continued to refuse to sign the proposed contract, the OMIDIS caused the work schedules of most of the Plaintiffs to be greatly reduced,
9 .giving preference instead to those. doctors who did agree to, sign the proposed contract and go 10 11 12 along with the scheme alleged herein.
Plaintiffs are informed and believe, and thereon allege, that 1 800 GET THIN,
LLC, was organized
as a California limited liability company on or about March 11, 2010, by
13 ROBERT B. SILVERMAN, ESQ., who was at all times relevant in this case the CEO and 14 president of that company. Plaintiffs are informed and believethat at all relevant times alleged 15 herein, he was the sole manager of this company.
Plaintiffs are informed and believe, and thereon allege, that Defendant;
INDEPENDENT MEDICAL SERVICE, INC., ("IMS") is a corporation organized and existing under the laws of the State of California and is managed and controlled by the OMIDlS~ 11.
20 21 22 23 24 25 26 27 28
ROBERTSON & AssaCIA TIS, LLP
Plaintiffs are informed and believe,and thereon allege, that Defendant, SURGERY
CENTER MANAGEMENT, LLC., is a limited liability company organized and existing under the laws of the State of California and is managed and controlled 12.
by the OMIDIS.
Plaintiffs are informed and believe, and thereon allege, thatDefendant KAMBIZ
BENIAMlA OMIDl, aka "JULIAN OMIDI" (hereinafter referred to as "JULIAN OMlOI") isthe president of TOP SURGEONS, INC., the principal of TOP SURGEONS, LLC., the President of . ALMONT AMBULATORY SURGERY CENTER, and the Chief Executive Officer of BEVERL Y HILLS SURGERY CENTER, LLC. Plaintiffs are further informed and believe, and thereon allege, that the State
of California revoked JULIAN
OMIDI's physician and surgeon's
license on June 19, 2009, for dishonesty, unprofessional conduct, failing to disclose criminal
COMPLAINT FOR FRAUD
. 1 convictions and a "penchant for dishonesty, to bend his position and shade his statements to suit 2 3 4 5 6 7 8 9 10 his needs, without. consistent regard for the truth."· Despite the fact that his physicianand surgeon's certificate has been revoked by the Medical BoardofCalifornia, Plaintiffs are.informed
and believe, and thereon allege, that JULIAN OMIDI has a financial interest and participates in the management of all of the OMIDIS' surgery centers.
Plaintiffs are informed.and believe, and thereon allege,thatDefendantMICHAEL
OMIDI, M.D., is the Chief of Staff, Director of Surgery andholds an ownership interest in ofall of the OMID IS' ASC's. Plaintiffs are further informed and believe that the State of California
revoked MICHAEL OMIDI, M.D.'s physician and surgeon's license effective October 3,2008, for aiding and abetting the unlicensed practice of medicine and for gross negligence in the
11 treatment ofthree (3) patients, but his license revocation has been stayed for a period of three (3) 12 years of probation Which he recently completed in 2011. 14. Plaintiffs are informed and believe, and thereon allege that Defendant
14 15 16 17
ALEXANDER WEISSE is an attorney licensed under and by virtue of the laws of the Stateof California and residentof the County of Los Angeles and an employee of the OMIDIS. 15.' Plaintiffs are informed and believe, and thereon allege that Defendant ED
DeFRANK is an attorney licensed under and by virtue of the laws of the State of California and
18 resident of the County of Los Angeles and is an employee of the OMIDIS.
20 21 22 23 24 25 26 27
Plaintiffs are informed and believe, and thereon allege that Defendant ROBERT
SILVERMAN is an attorney licensed under and by virtue of the laws of the State of California and resident of the County of Los Angeles. Plaintiffs are further informed and believe that SILVERMAN was at all relevant times alleged herein, the CEO and President of 1 800 GET THIN, LLC., and an employee of the OMIDIS. 17. Plaintiffs are informed and believe, and thereon allege, that Defendants WEISSE,
SILVERMAN and DeFRANK acted at all times alleged herein as the employees andlor agents of the OMIDISand maintained their office within the OMIDis' in-house legal department located at 91 00 Wilshire Boulevard, Suite 530, Beverly Hills, CA.
ROBERTSON & ASSOCIATES, LLP
COMPLAINT FOR FRAUD
Defendant CINDY OMIDI is a resident of the County of Los Angeles, State of JULIAN OMID!. At all relevant times alleged herem,
California and mother of MICHAEtand
CINDY OMIDI acted as an employee and/or agent of the OMIDIS. 19. Defendant ELLIOT ALPERT, M.D., is a licensed medical doctor in the State of ..
California and resident of the County of Los Angeles, State of California. At all relevant times
alleged herein, DR. ALPERT acted as the employee andioragentofthe
OMIDIS by serving as the
. 7. "President" of each of the phantom corporations formed for each of the Plaintiffs herein.
Defendant GOLDEN STATE PRACTICE MANAGEMENT, LLC.; is a limited
liability company organized and existing under the laws of the State of California and is owned
10 .and controlled bytheOMIDIS. 11
12 13 14 15 16 17 18
FIRST CAUSE OF ACTION
(By Plaintiffs against Defendants MICHAEL OMIDI, M.D., JULIAN OMIDI, CINDY
OMIDI, ROBERT SILYERMAN, ALEXANDER WEISSE, ED DeFRANK, ELLIOT ALPERT~ M.D., INDEPENDENT MEDICAL SERVICES, INC., SURGERY CENTER MANAGEMENT,LLC., GOLDENSTATE PRACTICE MANAGEMENT, LLC., and DOES 1 through 100, . inclusive for IDENTITY THEFT)
21. Plaintiff're-alleges and incorporates by reference each of the allegations contained as though fully set forth herein.
20 . in paragraphs 1 throughZf
22 23 24 25 26
Plaintiffs are.all medical doctors licensed by the State of California and are
residents of the County of Los Angeles who provided medical services, including but not limited to anesthesiology and internal medicine to patients ofthe OMIDIS' surgery centers throughout Los Angeles County and elsewhere as independent contractors on an as-needed basis, for which they were compensated typically on an hourlybasis. . 23. Unbeknownst to the Plaintiffs, on or about May 16,2011, ALEX WEISSE; ESQ.,
27 acting as the OMIDISI agent, caused to be fanned approximately fifty (50) phantom corporations
on the same day with the California Secretary of State's Office. ALEX WEISSE, ESQ. is listed as
1 the "incorporator" for each of these phantom corporations in the Articles of Incorporation filed 2 with the Secretary of State. These phantom corporations included the followingprofessional
3 medical corporations formed on behalf of the Plaintiffs, using the first two initials of their first and' 4
last names: a. ARKAMedical, Inc. .; for Arman Karapetyan, M.D.; JOPO Medical, Inc. - forJoel Popson, M.D.; RATA Medical, Inc. _;for Randy Taylor, M.D.; STMA Medical, Inc. - for Steve Mandel, M.D.
Plaintiffs are informed and believe, and thereon allege, that the Articles of .
10 Incorporation for each of the above-referenced phantom corporations states 'The purpose of the
corporation is to engage in the Profession ofMedicine" and "The shares of this Corporation may
only be owned by the Corporation or 1:>Ya person who is licensed to practice medicine in
. 13· California. "
Business & Professions Code §2285 requires that a Fictitious Name Permit be
15 obtained from the Medical BOard of California for any professional medical corporation formed in
any name other than the name of the licensed physician and surgeon. Plaintiffs are further
17 informed and believe, and thereon allege that on or aboutJanuary 31, 2012, theOMIDIS caused to
18' be filed with the Medical Board of California Fictitious Name Permit applications for each of the 19 above-referenced phantom corporations. The Fictitious Name Permits issued by the Medical
. 20 Board of California for these phantom corporations all list theOMIDIS' BEVERYLYHILLS
SURGEY CENTER address of9001 Wilshire Blvd., Suite 106, Beverly Hills, CA., 90211 as the business address for all of the phantom corporations. Further, all of the Fictitious Name Permit
Applications state, under penalty ofperjury, that ELLIOT ALPERT, M.D. is the President and
100% owner of each of the phantom corporations. Additionally, the Fictitious Name Permit Applications signed by DR. ALPERT list all of the OMIDIS ASCs as "additional practice
26 addresses" for each of the phantom corporations.
'Plaintiffs are further informed and believe, and thereon allege that WEISSE listed
28 the business address with the Secretary of State's Office for all 50 phantom corporations as 27068
ROBERTSON & ASSOCIATES, LLP
1 La paz Road,#425, Aliso Viejo, California, 92656. Plaintiffs are informed and believe that based 2 3 upon their investigation,this address is a P.O. Box at a UPS Store and is the same address used by .
. . .
WEISSE for his law practice, as well as dozens of other entities owned and controlled by the
Plaintiffs are further informed and believe, and.thereonallege
that unbeknownst to
6 them, ROBERT SILVERMAN, ESQ., acting as the employee andlor agent of the OMlDIS, 7 caused National Provider Identifier ("NPl") numbers be issued for each of the 50 phantom
8· corporations, including those listed above for the Plaintiffs, from the National Plan and Provider 9 Enumeration System, cnNPPES"). The Health Insurance Portability and Accountability Act of 10 1996 ("HlPPA") mandated the adoption of standard unique identifiers for eachhealthcare
11 professional, These NPI numbers are used on medical billing to insurance companies to identify ,
12 the healthcare provider. Plaintiffs are Informed and.believe, and thereon allege, that on or about
13 June 28, 2011, SILVERMAN, acting as the OMlDIS'agent, obtained NPI numbers from NPPES
14 for each of the phantom corporations listed above despite the fact that the Plaintiffs already had 15 their own personal NFl numbers. Plaintiffs are further informed and believe, and thereon allege.
16 that when registering the NPI numbers for each of the phantom corporations, SILVERMAN listed
17 the mailing address for aU of the phantom corporations as P.O. Hoxes in the 900 range (e.g, 90118 19 20 21 22 23 24 25 26 998hereihaft~r referred to as the "900 series") at 8581 Santa Maruca Boulevard, West Hollywood, California, 90069. Based upon the Plaintiffs' investigation, this is a UPS Store; however, there are no actual P.O. Boxes in the 900 series at this UPS Store. 28. Plaintiffs are further informed and believe, and thereon allege; that in furtherance of
this scheme, on or about May 24,2011, WEISSE, acting as the agent of the OMIDIS, rented the entire 900 series of approximately ninety-eight (98) P.O. Boxes from the UPS Store located at 8581 Santa Monica Blvd, West Hollywood, .California, 90069. Plaintiffs are informed and believe, and thereon allege that WEISSE filled out in his own handwriting U.S. Postal Service Form 1583's for each of the 98 mail boxes he rented, Despite the fact that U.S. Postal regulations
27· require anyone renting a P.O. Box to furnish two forms of identification, no identification was 28
COMPLAINT FOR FRAUD
1 provided by WEISSE to prove that he was an authorized representative of the phantom 2 corporations to rent a mail box in their names.
Plaintiffs are further informed and believe, and thereon allege that Defendant
4 CINDY OMIDI personally negotiated the payment to rent the900 block of mail boxes for the
with Zorik Parsanian, the manager of the UPS Store referenced above,and
6 wrote a check of between $3,000 -$4,000 to rent the 900 block for one year.
7 8 9 10 11 J2 13 14 30. Plaintiffs are further informed and believe, and thereon allege, that Within the past
year, the OMIDIS, with the assistance of their co-conspirators SILVERMAN, WEISSE and DEFRANK, submitted bills to patients' insurance companies for medical services provided by the Plaintiffs under the name of each of their respective phantom corporations listed above without the · Plaintiffs' knowledge or consent. Plaintiffsare further informed and believe, and thereon allege that the bills submitted to the patients' insurance companies contained personal identifying informationof each of the Plaintiffs.Including their names, medical license numbers arid PNI's,
and that these bills requested that all payments be mailed back to the 900 series of P.O. Box
15 -addresses at the above-referenced UPS Store in West Hollywood,
16 17 .18 31. Plaintiffs are further informed andbelieve, and thereon allege, that the patients' the900 series of P.O. Boxes rented by the OMIDIS
insurance companies did in fact.mailchecksto at the above-referenced UPS Store and
the envelopes containing the checks were addressed to were then collected by the UPS
19 the individual Plaintiffsand their phantom corporations.which 20 21 .22 23 24 25 26 27
Store employees and put ina box in the back of the store office instead of in Ll.S: Mail receptacles for daily pickup by the OMIDIS' drivers. Plaintiffs are further informed and believe, and thereon . allege that despite the fact that the. checks from the insurance companies were made payable to the phantom corporations formed for each of the individual Plaintiffs (e.g. STMA Medical, Inc., etc.) the OMIDIS caused these cheeks to be endorsed and deposited into the bank. accounts for IMS, SURGERY CENTERMANAGEMENT,LLC. and/or GOLDEN STATEPRACTICE
MANAGEMENT, LLC., for the OMIDIS~s sole benefit in their accounts at Wells Fargo Bank, all without the knowledge or consent of the Plaintiffs.
. . ROBERTSON &AsSOClATES,LLP
this scheme within the past several months of filing this
.2 lawsuit and had no prior knowledge that the Defendants were perpetrating this scheme prior to that
3 time. Upon learning that the Defendants were perpetrating this scheme, the Plaintiffs have ail 4 . resigned as independent contractors and refused to do any further work at the OMIDIS' surgery·
6 33. Plaintiffs are informed and believe and thereon alleges that each of their "personal
7 identifying information" as that term is defined by Civil Code §1798,92 and Penal Code §530,55
8 has been stolen and that each of them is the victim of "identity theft" by the Defendants to
9 fraudulently obtain paymentfrom insurance companies.
Plaintiffs are informed and believe, and thereon allege that Defendants, and each of
11· them, actively concealed from Plaintiffs that they had created phantom professional corporations
12 for each of the Plaintiffs for the. sole purpose of billing out the Plaintiffs' medical services to 13 insurance companies, using the Plaintiffs' "personal identifying information" such as their name, 14 physician and surgeon license number, and personal NPI number. Each phantom corporation was
15 formed for the express purpose of billing insurance companies for the medical services performed
i6 by each of the respective Plaintiffs. For example, STMA Medical, Inc. only billed insurance
17 companies for the medical services performed by Steven Mandell, M.D., and so on.
Corporations Code §13408.5 makes it unlawful to form a professional corporation
for the purpose of causing any violation of law, including fee splitting, kickbacks or other similar practices by physicians and surgeons. Corporations Code §13405 provides that a professional
21 medical corporation can only render professional services through employees who are licensed
22 .physicians. Further, Corporations Code§ 13401.5 requires that a licensed physician and surgeon 23 24 own at least 51% of a professional medical corporation,· and that the remaining ownership percentages be held by a limited class of persons identified by the statute (e.g. registered nurse, medical
25 podiatrist, ect.). Lay persons are prohibited from owning any percentageofaprofessional
26 corporation. 36.
None of the Plaintiffs held.any ownership interest in, or were employed by the .
phantom corporations created on their behalves by the Defendants. All of the Plaintiffs were
.& ASSOCIATES, LLP
1 employed and paid as independent contractors by either TOP SURGEONS, INC., SURGERY 2 .3 4 5 CENTER MANAGEMENTandior IMSas alleged above. All ofthe phantom corporations were
wholly owned by ELLIOT ALPERT, M.D., who did not perform any of the anesthesiology orpreoperative clearances which were billed to the patients' insurance companies by the phantom corporations. The truth is that these medical. procedures Were performed by each of the Plaintiffs
6· herein, and not by DR. ALPERT. Accordingly, the OMIDIS' scheme of billing out the Plaintiffs' 7 medical services through these phantom corporations violated Corporations Code §§ 8 9 10 11 12 13 14 15 16 17 13408.5,134051 13401.5 as well as constituted illegal fee-splitting in violation of Business & Professions Code §650. Plaintiffs are further informed and believe, and thereon allege that the Defendants further have engaged in mail theft, identity theft in violation of Penal Code §530.5, conspiracy to commit these aforementioned crimes in violation of Penal Code. §182(a)(4) and . engaged in "criminal profiteering activity" as defined by Penal Code §186.2(a)(20), (31) and "organized crime" as defined by Penal Code §186.2(d). 37;. Plaintiffs are further informed and believe and thereon allege that the Defendants,
and each of them, intended to deceive the Plaintiffs and used their personal identifying information to commit insurance fraud upon healthcare insurance companies in violation of California Insurance Code and Penal Code §550; 38. Plaintiffs are further informed and believe and thereon allege that they clearly and
19 20 21 .22 23 24 25 26 27 28
unequivocally told the Defendants that they had rejected the Defendants' proposed contract and proposal to allow the Defendants to form new corporations so that the Defendants could bill the Plaintiffs' patients' insurance companies and keep the payments made by the insurance companies. ' Plaintiffs reasonably relied upon the fact that the Defendants would not create phantom corporations on their behalf over their objections and would not submit fraudulent bills to their patients' insurance companies for medical services tendered by the Plaintiffs without their knowledge or consent.
Plaintiffs have been harmed in that (1) their professional medica1licenses and
reputations have been put in jeopardy With the Medical Board of California, California Department of Insurance and with each insurance company billed by these phantom corporations
1 by the Defendants' theft and illegal use of their personal identifying information, which was used
2 to commit insurance fraud; (2) Defendants have only paid the Plaintiffs
a paltry hourly wage and
kept 100% of the amounts paid bypatients' insurance companies for the Plaintiffs' medical services without their knowledge or consent in violation of Bus. & Prof, Code §650; (3) the
5 Plaintiffs have been exposed to substantial state and federal income tax, interest and penalties for 6 non-payment of income taxes on income reported on IRS 1099's by the insurance companies for
7 payments made by the insurance companies for the Plaintiffs' services, which the Plaintiffs never 8· knew about or received; and (4) the Plaintiffs have been retaliated against by the OMIDIS for 9 10 11 .12 13 14 15 16 17 18 failing to go along withthe Defendants' illegal scheme by having their work schedules reduced or eliminated completely. 40. .ThePlaintiffs·are informed and believes ana thereon alleges that the Defendants'
concealment was a substantial factor in causing their harm. Defendants'acted with oppression.fraud and malice and therefore Plaintiffs are entitled to
recover damages for the sake of example and by way of punishing the Defendants. WHEREFORE, PLAINTIFFSPRA Y AS FOLLOWS: 1. 2. 3. 4. General damages in an amount according to proof; For Punitive damages; Reasonable attorney's fees and costs of suit per Civil Code §1798.92; For
20 21 . 22
from this Court that the Plaintiffs are the victims of identity theft
and that they did not participate in insurance fraud or any other illegal conduct alleged herein through the theft of their personal identifying information by the Defendants; 5. Such other and further orders that this Court may deem just andproper,
24 25 DATED: May.
ROBERTSON & ASSOCIATES, LLP
Attorneys for PLAINTIFFS
ROBERTSON & AsSOCIATES, LLP
COMPLAINT FOR FRAUD
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