MAY 2

2015

KSC: USAO# 2015R00358

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND UNITED STATES OF AMERICA v.

RIMINAL NO. 1

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DONALD RUSSELL, BRUCE KEVIN LEWIS, DANIELLE SILBERSTEIN, PETER SNYDER, ROBERT LONG, JAMIE DAVIS, RONALD TENNYSON, TERRELL DOWNING, JOHN FIELDS, RONALD RUST, RONALD KANS, WALTER MOFFETT, and MELISSA CATLETT,

Conspiracy to Distribute and Possess

with Intent to Distribute Oxycodone, 21

U.S.C. § 846; Health Care Fraud, 18

U.S.C. § 1347; Aiding and Abetting, 18

U.S.C. §2) Defendants.

.oOo.

INDICTMENT COUNT ONE

The Grand Jury for the District of Maryland charges that:

Introduction

1.

eginning in or about February 2014 through in or about May 2015, Defendants DONALD RUSSELL and BRUCE KEVIN LEWIS owned and operated PG Wellness Center,

LLC ( PG Wellness ), a purported pain management clinic located within the District of

Maryland, and A Plus Pain Clinic, LLC ( A Plus Pain ), a purported pain management clinic

located within the District of Columbia. In reality, PG Wellness and A Plus Pain operated as pill

mills. A pill mill is a physician's office, clinic, or health care facility that routinely engages in

 

the practice of prescribing and dispensing controlled substances outside the scope of professional practice and without a legitimate medical purpose.

2.

Defendant RUSSELL ran the day-to-day operations at A Plus Pain and defendant LEWIS ran the day-to-day operations at PG Wellness. They hired and supervised employees, and

approved and directed financial transactions on behalf of the companies. They also split the

profits from the businesses evenly. DOCTOR 1 has been the prescribing physician at PG

Wellness since February 2014. DOCTOR 2 has been the prescribing physician at A Plus Pain

since approximately August 2014.

3.

Members of the conspiracy such as defendants Danielle SILBERSTEIN, Peter

SNYDER, Robert LONG, Terrell DOWNING, Ronald RUST, Ronald KANS, and Walter

MOFFETT each acted as distributors who brought a number of runners to the clinics. A

runner is an individual who is recruited by a distributor to enter pill mill clinics with fictitious

complaints of pain in order to obtain prescriptions for Schedule II controlled substances, primarily

oxycodone. Runners typically then filled the prescription and gave the oxycodone tablets they received to the distributor. Runners were typically paid in either cash or oxycodone tablets for their services. The distributors then generally sold the pills for a profit. Several also sold pills or

prescriptions back to members such as RUSSELL and LEWIS.

4.

Jamie DAVIS and Ronald TENNYSON served as runners and worked with LONG to fund additional visits to pill mill clinics and distribute the pills obtained during those visits.

5.

John FIELDS was a runner who dealt directly with RUSSELL in order to obtain

oxycodone pills and distribute them.

6. Danielle SILBERSTEIN and Melissa CATLETT regularly purchased bulk

quantities of oxycodone pills from RUSSELL.

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Background

7.

Beginning in no later than February 2014, RUSSELL and LEWIS owned and

operated a pain management clinic called PG Wellness, and located at 5620 Saint Barnabas Road,

Suite 340, Oxon Hill, Maryland. PG Wellness was operated as a pill mill. In or about February

2014, RUSSELL and LEWIS hired DOCTOR 1 to serve as the prescribing physician at PG

Wellness. They have paid DOCTOR 1 up to $1,500 per day.

8.

Beginning in no later than August 2014, RUSSELL and LEWIS owned and operated a pain management clinic called A Plus Pain Center, and located at 6323 Georgia

Avenue, NW, Suite 105, Washington, D.C. A Plus Pain was operated as a pill mill. In or about

August 2014, RUSSELL and LEWIS hired DOCTOR 2 to serve as the prescribing physician at A

Plus Pain. They have paid up to $1,300 per day for DOCTOR 2's services.

9.

In or about October 2014, SNYDER arranged to open his own pill mill clinic in

Salisbury, Maryland.

Controlled Substances — General Terminology

10. The Controlled Substances Act governs the manufacture, distribution, and

dispensing of controlled substances in the United States, including narcotics that are prescribed by

physicians and other licensed health care providers. The Controlled Substances Act and its

implementing regulations set forth which drugs and other substances are controlled substances.

Controlled substances are assigned to one of five schedules, Schedule I, II, III, IV, or V, depending

on their potential for abuse, likelihood of physical or psychological dependency, accepted medical use, and accepted safety for use under medical supervision.

11. Title 21, United States Code, Section 841(a)(1), provides that [e]xcept as

authorized by this subchapter, it shall be unlawful for any person to knowingly or intentionally

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