=o 29- oR seein Sonatan ang ' 05/07/2019 ‘onan ronan SUPERIOR COURT OF CALIFORNIA, COUNTY OF ALAMED. EAST COUNTY HALL OF JUSTICE FILED i! ALAMEDA COUNTY PEOPLE OF THE STATE OF CALIFORNIA | NO. 19-CR-006653A. | COMPLAINT APR 26 2019 v. | ‘CLERK "ERIOR COURT By ‘all Lee a NATHAN RABAH | brn. psw300 CEN: 9398599" CONAEZ, Oopiay | True PFN: AXES68 RABAH | prN. Dsw30! CEN: 9396399 M True PEN: BIES62 SANA NATHAN RABAH, | PFN: Dsw302 CEN: 9396400 ROWANNE JASER | DEN: Dsw3o3 CEN: 9396401 ARRAIGNMENT ‘The Undersigned, being sworn says, on information and belief, that NATHAN RABAH, MOHMOUD RABAH, SANA NATHAN RABAH and ROWANNE JASER did, in the County of Alameda, State of California, between December 2, 2011 and November 20, 2015, commit.a Felony, to wit: INSURANCE FRAUD, a violation of section 550(a)(1) of the PENAL CODE of California, in that said defendant(s) did aid, abet, solicit, conspire with another and did knowingly present and cause to be presented a false and fraudulent claim for the payment of a loss and injury, including payment of a loss under a contract of insurance. Med Express inflated the mileage on billings for patients Wilftedo A., Jacqueline B., Louie C., Vidya D., Sherwin E:, Anna F., Gebrai O., Anthony H., Dwight H., Tupou I, Kenneth 5,, Qui L., Shanze M., Rodrigo M., Ronald M., Lashawn M., Gary N., Eloy P., Kimberly P., Laksman S., Miguel S., Harminder S., Sione T., and Linda T, STATUTE OF LIMITATIONS-DATE OF DISCOVERY CLAUSE AS TO DEFENDANT NATHAN RABAH It is further alleged that a material element of said violation is fraud and breach of a fiduciary obligation within the meaning of Penal Code Sections 801.5 and 803(c). The acis comprising this offense were not discovered until January 16, 2016 when Alameda County District Attoméy's Office was notified by the Anthem Blue Cross Investigator that while looking at billings for deceased patients, that he noticed Med Express was systematically inflating the mileage/distance transported in’ billings they submitted. The billing fraud could not have been discovered earlier, even in the exercise of reasonable diligence. AGGRAVATED WHITE COLLAR CRIME CLAUSE AS TO DEFENDANT NATHAN RABAH It is further alleged, pursuant te Penal Code 186.11(a)(2), that the offenses set forth in counts 1 - § are related felonies, a material element of which is fraud and embezzlement, which involve a pattem of related felony conduct, and the pattern of related felony conduct involves the taking of and results in the loss by another of more than five lnundred thousand dollars ($500,000).EXCESSIVE LOSS OVER $200,000 CLAUSE 4S TO DEFENDANT NATHAN RABAH It is further alleged as to count one, , that in the commission of the above offense(s) the said defendant NATHAN RABAH, with the intent to do so, took, damaged and destroyed property of a value exceeding $200,000, within the meaning of Penal Code Section 12022.6(a)(2). EXCESSIVE LOSS-OVER $100,000 CLAUSE AS TO DEFENDANT NATHAN RABAH It is further alleged as to count one, that the above offense is a theft of over $100,000, within the meaning of Penal Code section 1203.045(a). STATUTE OF LIMITATIONS-DATE OF DISCOVERY CLAUSE AS TO DEFENDANT MOHMOUD RABAR It is further alleged that a material clement of said violation is fraud and breach of a fiduciary obligation within the meaning of Penal Code Sections 801.5 and 803(c}. The acts comprising this offense were not discovered ‘until January 16, 2016 when Alameda County District Attorney's Office was notified by the Anthem Blue Cross Investigator that while looking at billings for deceased patients, that he noticed Med Express was systematically inflating the mileage/distance transported in billings they submitted. The billing fraud could: not have been discovered earlier, even in the exercise of reasonable diligence. AGGRAVATED WHITE COLLAR CRIMP CLAUSE AS TO DEFENDANT MOHMOUD RABAH It is further alleged, pursuant to Penal Code 186.11(a)(2), that the offenses set forth in counts 1 - 8 are related felonies, a material element of which is fraud and embezzlement, which involve a pattem of related felony conduct, and the pattem of related felony conduct involves the taking of and results in the loss by another of ‘more than five hundred thousand dollars (6500,000), EXCESSIVE LOSS OVER $200,000 CLAUSE AS TO DEFENDANT MOBMOUD RABAH It is futher alleged as to count one, that in the commission of the above offense(s) the said defendant MOHMOUD RABAH, with the intent to do so, took, damaged and destroyed property of a value exceeding $200,000, within the meaning of Penal Code Section 12022.6(a)(2). ileged as to count one, that the above offense is a theft of over $100,000, within the meaning of Penal Code section 1203.045¢a). STATUTE OF LIMITATIONS-DATE OF DISCOVERY CLAUSE AS TO DEFENDANT SANA RABAH cig further alleged that a matcrial clement of said violation is fraud and breach of a fiduciary obligation within the meaning of Penal Code Sections 801.5 and 803(c). The acts comprising this offense were not discovered until January 16, 2016 when Alameda County District Attomey's Office was notified by the Anthem Blue Cross Investigator that while looking at billings for deceased patients, that he noticed Med Express was systematically inflating the mileageldistance transported in billings they submitted, The billing fraud could not neve been discovered carlicr, even in the exercise of reasonable diligence. AGGRAVATED WHITE COLLAR CRIME CLAUSE AS TO DEFENDANT SANA RABAH It is further alleged, pursuant to Penal Code 186.11(a)(2), that the offenses set forth in counts 1 - 8 are related felonies, a material element of which is fraud and embezzlement, which involve a pattem of related felony conduct, and the pattern of related felony conduct involves the taking of and results in the loss by another of more than five hundred thousand dollars ($500,000)EXCESSIVE LOSS OVER $200,000 CLAUSE AS TO DEFENDANT SANA RABAH It is further alleged a8 to count one, that in the commission of the above offense(s) the said defendant SANA NATHAN RABAH, with the intent to do so, took, damaged and destroyed property of a value exceeding $200,000, within the meaning of Penal Code Section 12022.6(a)(2). EXCESSIVE LOSS-OVER $100,000 CLAUSE AS TO DEFENDANT SANA RABAH It is further alleged as to count one, that the above offense is a theft of over $100,000, within the meaning of Pena} Code section 1203.045(a) STATUTE OF LIMITATIONS-DATE OF DISCOVERY CLAUSE AS TO DEFENDANT ROWANNE JASER It is further alleged that a material clement of said violation is fraud and breach of a fiduciary obligation within the meaning of Penal Code Sections 801.5 and 803(c). The acts comprising this offense were not discovered until January 16, 2016 when Alameda County District Attomey’s Office was notified by the Anthem Blue Cross Investigator that while looking at billings for deceased patients, that he noticed Med Express was systematically inflating the mileage/distance transported in billings they submitted, The billing freud could not have been discovered earlier, even in the exercise of reasonable diligence. AGGRAVATED WHITE COLLAR CRIME CLAUSE AS TO DEFENDANT ROWANNE JASER It is further alleged, pursuant to Penal Code 186.11(@), that the offenses set forth in counts 1 - & are related felonies, a material element of which is fraud and embezzlement, which involve a pattem of related felony conduct, and the pattern of related felony conduct involves the taking of and results in the loss by another of more than five hundred thousand dollars ($500,000). EXCESSIVE LOSS OVER $200,000 CLAUSE AS TO DEFENDANT ROWANNE JASER It is further alleged as to count one, that in the commission of the above offense(s) the said defendant ROWANNE JASER, with the intent to do so, took, damaged and destroyed property of a value exceeding $200,000, within the meaning of Penal Code Section 12022.6(a)(2). EXCESSIVE LOSS-OVER $100,000 CLAUSE AS TO DEFENDANT ROWANNE JASER Jt is further alleged as to count one, that the above offense is a theft of over $100,000, within the meaning of Penal Code section 1203.045(a),