p ki •

KSC USAOtt

2015R00357

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

wooer/ma . s...«.....1161NO

MAY 2 2 15

UNITED STATES OF AMERICA

•

,)-r

RIM. NO.

1

.

•

JOYCE VERCAUTEREN,

Conspiracy to Distribute and Possess with Intent to Distribute

Defendant.

Oxycodone, 21 U.S.C. § 846) ..oOo..

INDICTM ENT

COUNT ONE

The Grand Jury for the District of Maryland charges that:

Introduction

1.

Beginning in or about May 2014 through in or about May 2015, Defendant JOYCE

VERCAUTEREN owned and operated MPC Wellness Center, LLC ( MPC Wellness ), located at

7317 Hanover Parkway, Suite A, Greenbelt. Maryland, a purported pain management clinic located within the District of Maryland. In reality, MPC Wellness operated as a pill mill. 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 VERCAUTEREN ran the day-to-day operations at MPC Wellness.

She hired and supervised employees, and approved and directed financial transactions on behalf of

the company. Partner 1 worked with VERCAUTEREN to manage and operate MPC Wellness.

-1-

 

4e

 

s

dttiftat

I VW lift f.W.C:

 

VERCAUTEREN has employed a number of different prescribers, both doctors and nurse

practitioners.

3.

Prior to MPC Wellness, VERCAUTEREN operated other pill mill clinics,

including Simple Spine.

4.

VERCAUTEREN also regularly worked with CO-CONSPIRATOR 1 to purchase

bulk quantities of oxycodone from PHARMACIST 1 for re-sale.

5.

Members of the conspiracy 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.

Controlled Substances — General Terminology

6.

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. -2-