:'. i \ CONFIDENTIAL MC -060 HECEflY'Efl'RTUSEONLY ATIORNEY (Name, slate bar number, and address): Joseph W. Cotchett (SBN 36324) -Philip 1. Gregory (SBN 95217) COTCHETT, PITRE & McCARTHY, LLP 840 Malcolm Road Burlingame, CA 94010 TELEPHONI:! NO.: ( 650) 697-6000 FAX NO, (Optional): E-MAIL ADDRESS (Opllon&' regoryt:Jmlegal. COm AITORNEY FOR: X 00 PLAINTIFF IN DROP BOX 2 JUL 13 AH [Q: 34 (650) 692-3606 su OTHER (specify)·. Gt:SSC COURTHOUSE ERIOR GOURT OF CALIFORNIA ~;OUNTY OF SACilAMEIHO SUPERIOR COURT OF CALIFORNIA, COUNTY OF Sacramento STREET ADDRESS: 720 9th Street MAILING ADDRESS: CITY AND ZIP CODE: BRANCH NAME; SacrSJ:tit~-hto, CA 95814 Gorqcln'= ·_b. Schaber Sacramento County Courthous PLAINTIFF: [UNDER SEAL] DEFENDANT: [UNDER SEAL] CASE NUMBER: CONFIDENTIAL COVER SHEET-FALSE CLAIMS ACTION . INSTRUCTIONS: This civil action is brought under the False Claims Act, Government Code section 12650 et seq. The documents filed in this case are under seal and are confidential pursuant to Government Code section 12652(c). This Confidential Cover Sheet m.ust be affixed to the caption page of the complaint and to any other paper filed in this case until the seal is lifted. Seal to expire on (date): UNLESS: ( 1) Motion to extend time is pending; or (2) Exten.ded by court order You should check with the court to determine whether papers filed in False Claims Act cases must be filed at a particular location. 1. The document to which this cover sheet is affixed is: a. [][] Complaint for damages for violation of the·False Claims Act b. D Civil Case Cover Sheet (form 982.2(b)(1)) c. D Motion for an extension of time to intervene d. D Affidavit or other document in support of the motion for an extension of time e. D Order extending time to intervene (specify dale droer expires): . f. D Other order (describe): g. h. D D Notice from the Attorney General of additional prosecuting authority that may have access to the file Other (describe): 2. This Confidential Cover Sheet and the attached document must each be separately file-stamped by the clerk of the court. Date: July 13, 2012 Paga1 of1 Form Adopted for Mandatory Usa Judicial Council of California MC-060 [Rev. January 1, 2007] CONFIDENTIAL COVER SHEET FALSE CLAIMS ACTION Lemli . Soltt~~~- c®;;r;;(;;;I:\U: Gov. Coda,§ 12652(c); RECEIVED IN DROP 60X JOSEPH W. COTCHETT (SBN 36324) jcotchett@c_])mlegal.com 2 PHILIP I:. GREGORY (SBN 95217) 1 !?. JlJL. .. pgregoi):'la2c]Jml~_gal.com A" 13 1-1n !O: 34 · Ni}.N~l b.NISHlMURA (SBN 152621) ,. GDSSC COli~Pb0~~lfORNIA IilliShimura@Qpmlega1.com oUPg~ssica, Mildred, Uzet mayra, Maribel, me, bahardc, Eoh ~· Managers and M~d Rep, !'hi$ I$ a Vl!irbalwarning ll:> all Qi you. We nl!i~d Ill mak& make sut~ wa arl!l &chedullng GO patients lor the MD ollnics. The Show up 1'1lte lavery low anything t)e)(}w a 50% will result In a written notice or possible demotion. Also remember all the patieNs that come In for MD need to l)et UAend mads. The numbers are very off, you need lo monRoring this, this i.s pa.rt ofyoUJr )obi !!I Lat'me koow what the 1ssues are 24 25 ® LAW OFFICES COTCBETT, PITRE& MCCARTHY) LLP 5. The majority of the treatments are useless and only used to bill for the 26 alleged services. Physical therapy treatments, diagnostic tests, psychiatric 27 evaluations, and therapeutic massages are performed by uncertified low-wage 28 employees and provide no curative effect. Indeed, a number of the treatments COMPLAINT 2 require the use of complex and dangerous medical equipment that stimulate nerves 2 with electricity or use ultrasonic sound waves that can damage tissue. The 3 technicians who operate these machines have no understanding of how to treat 4 specific injuries using the different settings and functions of these machines. 5 Every patient receives treatment under the exact same setting regardless of 6 that patient's specific injury, e.g., thumb or hip injury, or whether his or her 7 pain is muscular, skeletal, or due to damaged nerves. Despite the carousel of 8 tests and treatments, most patients never see any improvement in their chronic 9 pain. 10 6. The Clinics bill excessive numbers of treatments, tests, and 11 prescriptions. The billing and collection personnel at the Clinics faced warnings, 12 demotions, and even tenninations if all treatments, tests, and prescriptions were 13 not billed, whether or not there was a doctor's order or other evidence of medical 14 necessity supporting the bill. Below is an excerpt from a December 13,2011 15 email from Defendant Danesh to several employees demanding the employees 16 performing billing and collections improve the billing numbers OR ELSE: 17 18 19 l3,l0ll~>t 7:46AM, Bahar wrolc: 23 .l)nfortU1!ately we have t!l make big changes llincc biHing ®part.ments Is fwl[!Jg and we arc gi vin this ooe last chance , numhers!W:!lded dont get accompUslled • department wlll be shut and billing outsourood,., Changes: - Jolla.na will manage lhe billing Department till\\'<: find a belter management sylllem •llu1ttbersu see on !he board 11re what needs to be dQ!lO, rtu are dose to max required u wm get 24 both billing and .maiilng ntuttbers. 20 21 22 25 26 27 ® On The, Dec Hi Everyone a b~mus, Ifu .llJ'¢ b¢low Min then unfortunate!~ we emi't keep u. in that depimment This is fo.r -No personal phtme Clllb, ·No tnore ~i!l\11!1\ld.,lnfb miasing u C!Ui't bill- t:rut it iu the Box f\lr central to fix, Otherwise Bill BiiLBill NO EXCUSE Mail Mail Mail NO EXCUS.E 28 LAW OFFICES COTCHETT, PITRE & MCCARTHY, LLP COMPLAINT 3 1 ·2 7. Defendants have also unlawfully misappropriated the credentials of unaffiliated physicians in an attempt to legitimize their operations. The Clinics 3 display the names of these physicians on their website to create the perception that 4 they actually treat patients at the Clinics. Further, the Clinics prescribe controlled 5 substances using the DEA Nmnbers of these physicians. In some instances, the 6 Clinics establish superficial or short-lived relationships with physicians, then, after 7 the relationship has ended, use the physician's name to order and bill for 8 . procedures 9 10 11 the physicians did not authorize. Other physicians allow untrained workers to perform their duties, then sign off and bill insurers and the State at their full rates. 8. After the Clinics write prescriptions for all of their patients, they 12 often dispense the medications directly from their office. The Clinics also have a 13 relationship with pharmacies that fill prescriptions without question. Patients are 14 never given the freedom to have written prescriptions filled at the pharmacy of 15 their choice, as required under California law. 16 9. The affiliated pharmacies carefully monitor the number of 17 medications each patient receives and stop filling prescriptions once the patient 18 crosses a predetermined threshold that might draw the attention of insurers or 19 regulators. Together, the Clinics and pharmacies ensure they are dispensing and 20 billing insurers for the maximum number of prescriptions possible for each 21 patient. 22 ® LAW OFFICES COTCHETT, PITRE& MCCAR'fHY, LLP 10. Qui Tam Plaintiff, through investigation and inside knowledge of 23 Defendants'operations, has obtained vast non-public evidence from various 24 sources supporting the allegations contained in this Complaint. Among other 25 evidence, Qui Tam Plaintiff is in possession of email correspondence from 26 Defendant Bahar Gharib-Danesh demanding her employees order medications and 27 urinalysis for each and every patient that is seen at her clinics, whether or not the 28 patient requires the medication or testing. Qui Tam Plaintiff also is. in possession COMPLAINT 4 1 of the Central Logs used to track treatments each patient allegedly receives. The 2 Clinics use a Central Log System to ensure each patient receives the maximum 3 number of billable medical services, and to direct patient care accordingly. 4 11. Additionally, Qui Tam Plaintiff has obtained bills and invoices 5 charging thousands of dollars per patient for a battery of psychological tests for 6 patients who sought care at the Clinics. The Clinics and their affiliated 7 psychologist consistently bill insurers for many more examinations than is s hwnanly possible, sometimes for hundreds of hours of evaluations in a single 9 10 11 ® from individuals involved in this chronic pain management scheme. 12. California's employers, including its public employers, are required 12 by law to carry workers' compensation insurance. In 2010, employers paid over 13 $7 billion in insurance premiums to private insurers or SCIF, to cover their 14 workers' compensation liability. In tum, these insurers have paid billions in 15 medical claims related to injured workers. As a result of the unlawful scheme 16 described herein, private workers' compensation insurers, other private insurers,. 17 SCIF, and Medi-Cal have paid for millions in medically unnecessary tests, 18 treatments, and medications. This unlawful and fraudulent scheme by Defendants 19 has increased the cost of mandatory workers' compensation coverage for 20 California's employers and insurance premiums in the private market for every 21 day working people. 22 LAW OFFICES COTCHETT) day. Qui Tam Plaintiff has also obtained detailed admissions and descriptions 13. The Legislature established the State Compensation Insurance Fund 23 in 1914. It is now the largest provider of workers' compensation coverage in 24 California. SCIF is a division of the California Department of Industrial Relations 25 and is considered a California state agency. Gilmore v. SCIF (1937) 23 26 Cal.App.2d 325, 329 (SCIF "is an agency of the state."). SCIF's mission is to 27 provide an available market for workers' compensation insurance at fair rates, and 28 to serve as a model for all workers' compensation carriers. SCIF includes PITRE& MCCARTHY, LLP COMPLAINT 5 1 approximately 150,000 policyholders, more than $1.2 billion in premiums, and 2 nearly $20 billion in assets. In addition to covering private employers, SCIF also 3 acts as the workers' compensation carrier for several California state agencies and 4 political subdivisions. See Ins. Code § 11870. SCIF has been fraudulently billed 5 for millions of dollars by Defendants. 14. 6 Additionally, many ofthe Defendants' patients received treatments 7 paid for by Medi-Cal- California's safety net for individuals unable to afford 8 health insurance. Medi-Cal is intended to provide essential care for California's 9 growing indigent population, but its funds are presently stretched to their limit. 10 Medi-Cal has been defrauded and abused by unscrupulous providers and others 11 involved in the healthcare system, including Defendants in this case, who put 12 profits above the public welfare. These unlawful schemes diminish the quality of 13 care, and substantially burden taxpayers. 14 II. 15 JURISDICTION AND VENUE 15. This Court has jurisdiction over the claims in this Complaint pursuant 16 to California Insurance Code§ 1871.7 (the "California Insurance Frauds 17 Prevention Act") and California Government Code § 12652 (the "California False 18 Claims Act"). 19 All of the entities named in this Complaint operate under the laws of 20 California and conduct substantial business within the State of California, as well 21 as maintain employees and offices within the State. The entities' unlawful, false, 22 andJor fraudulent conduct took place within the State of California. 23 24 25 ® 16. 17. All individuals named in this Complaint reside in California. Their unlawful, false, and/or fraudulent conduct took place within California. 18. Venue in the County of Sacramento is appropriate pursuant to the 26 California Insurance Frauds Prevent Act and the California False Claims Act. Qui 27 Tam Plaintiff brings this action to recover unlawful, false, andJor fraudulent claims 28 on behalf of the California Department of Insurance, the State Compensation LAW OFFICES COTCHETT, PITRE& MCCARTHY) LLP COMPLAINT 6 1 Insurance Fund, and Medi-Cal. These state agencies, as well as their special 2 investigative units, are located in the County of Sacr'lffiento. Moreover, any 3 recovery achieved under these statutes is returned to tqe State of California and the 4 appropriate public agency. 5 III. PARTIES 6 A. Qui Tam Plaintiff 7 19. The Plaintiff in this action is the State of California, by and through 8 Qui Tam Plaintiff Anna Maria Christina Sills, pursuant to Insurance Code § 9 1871.7(e)(1) and California Government Code§ 12652. 10 20. Qui Tam Plaintiff Anna Maria Christina Sills is an individual and 11 former employee of Defendant Pain Free Management Company LLC, an entity at 12 the center of this conspiracy ("Pain Free Management"). Her employment with 13 Pain Free Management provided her with the opportunity for m1derstanding all of 14 the related entities, also named as Defendants herein, owned and controlled by 15 Defendant Gharib-Danesh and others. Qui Tam Plaintiff Anna Maria Christina 16 Sills is an "original source" as that term is defined, and she has direct and 17 independent knowledge of the information on which these allegations are based. 18 The facts set forth herein are based entirely upon her personal observation, 19 investigation, documents, and other tangible things in her possession. 20 21. In November 2011, Qui Tam Plaintiffwas hired by Pain Free 21 Management, in Reseda, Califomia as the billing and collections manager. Her 22 duties at Pain Free Management were to structure the intemal billing and 23 collections department, implement billing software, and perform billing and 24 collections work for Pain Free Management and numerous other clinics under the 25 control of Defendant Gharib-Danesh. Prior to Qui Tam Plaintiffs employment, 26 Pain Free Management and the other clinics outsourced billing and collection 27 services. Qui Tam Plaintiff was hired to develop internal billing and collection 28 services for Pain Free Management and other related entities. ® LAW OFFICES COTCHETT1 PITRE& McCARTHY, LLP COMPLAINT , 7 1 22. · Qui Tam Plaintiff stayed at Pain Free Management through February 2 2012, during which time she had access to the books and records of Pain Free 3 Management, and numerous other clinics and entities who participated in the 4 schemes as hereinafter alleged. 5 23. During her employment at Pain Free Management, Qui Tam Plaintiff 6 raised concerns several times concerning the billing practices of Pain Free 7 Management and the other clinics. For example, as shown above, on December 8 13. 2011, Defendant Gharib-Danesh emailed Qui Tam Plaintiff and several other 9 employees, stating "[u]nfortunately we have to make big changes since billing 10 departments is failing and we are givin this one last chance, numbers needed don't 11 get accomplished [sic] .... " In response, Qui Tam Plaintiffwrote "[t]he problems 12 are that we don't get information to bill correctly .and efficiently .... " See Exhibit 13 A. Qui Tam Plaintiff was told directly and/or in substance or affect that her duties 14 as a billing and collections managers i(lcluded not only structuring the internal 15 billing work as stated above but: a) she was to sign doctors' name to prescriptions; 16 b) she was to use different coding; c) she was to make sure that each bill had the 17 maximum amount of tests; d) she was to engage in various different activities 18 which were illegal on their face; e) she was told to insert doctors' names where 19 necessary; and, above all else, f) she was instructed to keep quiet about the 20 operation. z-1 24. Qui Tam Plaintiff was terminated because she repeatedly raised 22 concerns and refused to participate in the fraud being perpetrated at Pain Free 23 Management and the other Defendants, as more fully alleged herein. 24 * LAW OFFICES 25. · Concurrently herewith, Qui Tam Plaintiff will provide the Attorney 25 General's office, the Sacramento County District Attorney, and the Insurance 26 Commissioner of California with a full disclosure of substantially all material 27 facts, as required by Cal. Ins. Code§ 1871.7(e)(2), and Government Code §12652. 28 COTCHETT, PITRE& MCCARTHY, LLP COMPLAINT 8 1 B. Individual Defendants 2 26. Defendant Bahar Gillarib-Danesh, D.C. ("Gharib-Danesh"), 3 California Board of Chiropractic Examiners License Number 283 61, is the owner 4 and operator of many of the Defendant Clinics and entities named herein, and she s is at the center of this medical billing fraud conspiracy. She is a chiropractor 6 practicing in Southern California. The entities owned and controlled by Gharib- 7 Danesh have instituted a pattern and practice of defrauding public and private s insurers, and California's consumers. Gharib-Danesh is also active in the scheme 9 as a chiropractor. She schedules patients that she never sees, signs off on 10 treatments and tests that she does not perform or supervise, and bills insurers 11 for her time and services. 12 27. Gharib-Danesh also pressures her office workers and medical 13 assistants into performing medical duties far beyond the scope of their training and 14 aptitude. She has instituted a number of policies requiring clerks and assistants to 15 bill insurers, forge and stamp the signatures of physicians, and provide medication 16 to patients. Gharib-Danesh is also responsible for the relationships with the 17 pharmacies that fill her patients' prescriptions. 18 28. Gharib-Danesh has knowingly and unlawfully: (a) employed 19 unlawful "runners, cappers, and steerers" to refer patients to her Clinics; (b) 20 engaged in a pattern and practice of ordering unnecessary medical tests and 21 treatments; (c) consistently allowing untrained workers to perform her licensed 22 duties for her; (d) fraudulently billed insurers for these tests and treatments; (e) 23 caused other physicians to order and perform um1ecessary and medically 24 insufficient medical treatments; and (f) caused others 25 fraudulent documents for the purpose of billing insurers. 26 27 ® LAW OFFICES COTCHETT, PITRE& MCCARTHY, LLP 29. to prepare and present Defendant Anthony Danesh ("Tony Danesh") is the brother of Gharib-Danesh. Tony Danesh is the senior operations manager of the Clinics. 28 COMPLAINT 9 1 Tony Danesh has knowingly engaged in the schemes described herein as well as 2 aided and abetted Gharib-Danesh in perpetuating this fraud. 3 4 30. Defendant Mohammad Gharib ("Mohammad Gharib") is the father of Gharib-Danesh. Mohammad Gharib owns some clinics as a straw person for s Gharib-Danesh. Mohammad Gharib has knowingly engaged in the schemes 6 7 described herein and aided and abetted Gharib-Danesh in perpetuating this fraud. 31. Defendant Khosrow Gharib ("Khosrow Gharib") is the mother of 8 Gharib-Danesh. Khosrow Gharib owns some of the clinics as a straw person for 9 Gharib-Danesh. Khosrow Gharib has knowingly engaged in the schemes described 10 11 herein as well as aided and abetted Gharib-Danesh in perpetuating this fraud. 32. Defendants Mohammad Gharib and Khosrow Gharib were 12 responsible for processing all mail and depositing all checks. They would arrive 13 at the Clinics with suitcases filled with mail and checks from insurers, and then 14 secretly process these payments through the various Defendant entities. 15 33. Defendant Joanna Munguia ("Munguia") is Operations Manager of 16 Defendant Pain Free Management and acts as Gharib-Danesh's right-hand. 17 Munguia has directed employees of the Clinics to engage in the schemes described 18 herein as well as aided and abetted Gharib-Danesh in perpetuating this fraud. 19 34. Defendant Nira Hariri ("Hariri"), California Board ofPhanmcy 20 License Number 52003, owns and operates Encino Care Pharmacy, located at 21 16001 Ventura Blvd., Suite 135, Encino, CA 91436-4481. She is responsible for 22 ensuring the fraudulently written prescriptions are filled without question and for 23 providing the Clinics with the necessary documents needed to bill the insurers. 24 ® 35. Defendant Hariri knowingly and unlawfully: (a) filled fraudulent 25 prescriptions for dangerous medications; (b) prepared fraudulent documents in 26 support of a false claim presented to insurers for payment; and (c) submitted false 27 claims to insurers for payment of fraudulently prescribed medications and 28 medications that Hariri never provided to patients. LAW OFFICES COTCHETT~ PITRE& MCCARTHY, LLP COMPLAINT 10 1 C. Defendant Doctors of Chiropractic Medicine 2 36. Each of the Defendant Chiropractors listed herein has participated in 3 the unlawful scheme to defraud insurers. Each Defendant Chiropractor has: 4 (a) ordered, or allowed others to order in their name, unnecessary medical tests; 5 treatments, prescriptions, and durable medical equipment; (b) allowed untrained 6 workers to perforn1 their licensed duties for them; (c) fraudulently billed insurers 7 for these medical products and services; (d) caused other physicians to order 8 unnecessary and medically insufficient medical products and perform unnecessary 9 procedures; and (e) caused others to prepare and present fraudulent documents for 10 11 the purpose of billing insurers. 3 7. Defendant Charles Michael Boyer, D.C. ("Boyer") California 12 Board of Chiropractic Examiners License Number 12366, is a chiropractor 13 practicing in Southern Califomia. His principal place of business is 1421 A 14 Redondo Avenue, Long Beach, California 90804. Boyer is currently employed by 15 Defendant Gharib-Danesh and practices at the Clinics. 16 38. Defendant Na Young Eoh, D.C. ("Eoh") California Board of 17 Chiropractic Examiners License Number 28688, is a chiropractor practicing in 18 Southern California. Eoh's principal place ofbusiness is 2920 F Street, #C-5, 19 Bakersfield, California 93301. Eoh is currently employed by Defendant Gharib- 20 Danesh and practices at the Clinics. 21 Defendant Laura Lyn Hazen, D.C. ("Hazen") California Board of 22 Chiropractic Examiners License Number 30826, is a chiropractor practicing in 23 Southern California. Her principal place of business is 7677 Cen.ter Avenue, Suite 24 402, Huntington Beach, California 92647. As of December 16, 2011, Hazen was 25 employed by Defendant Gharib-Danesh and practiced at the Clinics. 26 (£) 39. 40. Defendant Lana Elizabeth Montes, D.C. ("Montes") California 27 Board of Chiropractic Examiners License Number 30740, is a chiropractor 28 practicing in Southern California. Her principal place of business is 2211 Corinth LAWOFPICES COTCHETT, PITRE & MCCNUHY,LLP COMPLAINT 11 1 Avenue, #30 1, Los Angeles, California 90064. Montes is currently employed by 2 Defendant Gharib-Danesh and practices at the Clinics. 3 4 41. Defendant Jorge A. Rivas, D.C. ("Rivas") California Board of Chiropractic Examiners License Number 30558, is a chiropractor practicing in s Southern California. His principal place of business is 6944 Reseda Blvd., 6 Reseda, California 91335, which is the same address as Defendants Pain Free 7 Management Company LLC, Pain Relief Health Center, LLC, CA Orthopedic and s Pain Centres, Inc., and Southern CA Pain Centre, Inc. As of December 16. 2011, 9 10 Rivas was employed by Defendant Gharib-Danesh and practiced at the Clinics. 42. Defendant Rodrigo T. Sanchez, D.C. ("Sanchez") California Board 11 of Chiropractic Examiners License Number 26487, is a chiropractor practicing in 12 Southern California, and is the owner of Defendant Sanchez Chiropractic, Inc. 13 His. principal place of business is 42544 10'h Street West, Suite G, Lancaster, 14 California 93534. As of December 16, 2011, Sanchez was employed by 15 Defendant Gharib-Danesh and practiced at the Clinics. 16 D. 17 43. Defendant Doctors of Medicine Each of the Defendant Medical Doctors listed herein has 18 participated in the unlawful scheme to defraud insurers. The Defendant Medical 19 Doctors have each: (a) ordered, or allowed others to order in their name, 20 unnecessary medical tests, treatments, prescriptions, and durable medical 21 equipment; (b) allowed untrained workers to perform their licensed duties for 22 them; (c) fraudulently billed insurers for these medical products and services; (d) 23 caused other physicians to order and perform unnecessary and medically 24 insufficient medical products and services; (e) prepared and presented, or caused 25 others to prepare and present, fraudulent documents for the purpose of billing 26 insurers; and (f) failed to provide their patients with the statutorily mandated 27 fi·eedom to choose who fills their prescriptions. ® LAW OFFICES COTCHETT, PITRE& MCCARTHY, LLP 28 COMPLAINT 12 1 44. Defendant Tushar Ramnik Doshi, M.D. ("Doshi") Medical Board 2 of California License Number A53572, is a medical doctor practicing orthopedic 3 surgery in Southern California. Dr. Doshi's principal place of business is P.O. 4 Box 7547, Newport Beach, California 92658. Dr. Doshi attended medical school 5 in India at the University of Bombay, Seth G.S. Medical College. Dr. Doshi is 6 currently employed by Defendant Gharib-Danesh. 7 45. Defendant Boniface Okwudili Onobah, M.D. ("Onobah") Medical 8 Board of California License Number A52415, is a medical doctor practicing 9 neurology in Southern California. Dr. Onobah's principal place of business is 10 13428 Maxella Avenue, #909, Marina Del Ray, California 90292. Dr. Onobah 11 attended medical school in Nigeria, at the University ofilorin Faculty of Health 12 Sciences. Dr. Onobah is currently employed by Defendant Gharib-Danesh. 13 46. Defendant William Bernard Simpson, M.D. ("Simpson") Medical 14 Board of California License Number G431 01, is a medical doctor practicing 15 orthopedic surgery in Southern California. Dr. Simpson's principal place of 16 business is 34740 Carnaghi, Wildomar, California 92595. Dr. Simpson is 17 responsible for the shockwave therapy treatments at the Clinics, but does not 18 actually perfonn the treatments himself. Instead, he relies on low-wage workers to 19 perform the tests for him. Those workers then bring him the reports to sign. He 20 also instructs those workers to forge his name on reports when he is not seeing 21 patients at the Clinics. Dr. Simpson ordered shockwave therapy for over twenty 22 patients a day- even though he did not examine the patients beforehand- and 23 ordered four rounds of therapy for every patient. These treatments, given by 24 low-wage workers, were ineffective, lasting from two to five minutes. The 25 purpose of these treatments was to maximize the amount billed to insurers, not 26 cure the patients. 27 @ 28 LAW OFFICES COTCHETT, PITRE& MCCARTHY, LLP COMPLAINT 13 1 . 47. Defendant Behnoush Zarrini M.D. ("Zarrini") Medical Board of 2 California License Number A80739, is a medical doctor practicing pain medicine 3 in Southern California. Dr. Zarrini's principal place ofbusiness is 9808 Venice 4 Blvd., #707, Culver City, California 90232. Defendant Zarrini attended medical 5 school in Iran at Tehran University of Medical Sciences and Health Services. 6 Defendant Zarrini is primarily responsible for the prescription drug prong ofthe 7 scheme operating out of the Clinics. Under the scheme, Defendant Zarrini 8 writes prescriptions for patients he has not examined and allows office cierl{s 9 to use his signature and credentials to prescribe medications in his absence. 10 Under the scheme, Defendant Zarrini also orders medical tests and treatments for 11 patients without regard to their individual medical needs and allows untrained 12 office workers and medical assistants to perform these tests and treatments without 13 supervision. 14 E. Defendant Doctor of Psychology 15 48. Defendant John T. Terrence PsyD, PhD ("Terrence") is a 16 psychologist with California Board of Psychology License number PSY17840. 17 Tenence's principal place of business is 13900 Panay Way,# DS-35, Marina Del 18 Ray, CA 90292. Terrence purportedly performs psychiatric evaluations on patients 19 in the Clinics. Terrence operates the psychological evaluation arm of the 20 fraudulent billing scheme, performing sham psychiatric evaluations on as many 21 patients as possible and billing insurers for up to 20 hours in a day for services per 22 patient. Terrence also bills insurers for patients he does not actually evaluate. 23 49. When submitting bills to insurers, Tenence bills as if he sees up to a 24 dozen patients per day. For each of these patients, Terrence submits he provided 25 each patient with over twenty hours of psychological evaluations. In a period of 26 two weeks, Tenence billed in excess of 1,000 hours for services. See Exhibit B. 27 ® 28 LAW OFl''lCES COTCHETT, PITRE& McCARTHY, LLP COMPLAINT 14 1 50. 2 psychiatric evaluations; (b) fraudulently billed insurers in excess of the services 3 actually rendered; and (c) fraudulently billed for evaluations he did not perform. 4 F. 5 51. The Defendant Clinics and related Billing Entities herein each participate in the unlawful scheme to defraud insurers. Some of these entities are 7 clinics owned and operated by Defendant Gharib-Danesh. Others merely serve as 8 fictitious entities used to bill insurers. These Clinics and Billing Entities have no 9 purpose other than to divert some of Defendants' fraudulent bills through diverse 10 channels to avoid drawing attention to the immense volume of bills generated by 11 Defendants. Each entity listed knowingly submits false bills to insurers. 13 52. The addresses of the Clinics which Gharib-Danesh operates tmder the entity names listed below include the following: 14 a. 6944 Reseda Blvd., Reseda, California 91335 ("Reseda Office"); 15 b. 3580 Wilshire Blvd., Suite 100, Los Angeles, California 90010 ("Los Angeles Office"); 16 17 c. 19 d. e. f. g. 28 1801 E. Edinger Avenue, Suite 125, Santa Ana, California 92705 ("Santa Ana Office"); and 26 27 2323 W. Caldwell Avenue, Visalia, California 93277 ("Visalia Office"); 24 25 4201 Long Beach Blvd., Suite 430, Long Beach, California 90807 ("Long Beach Office"); 22 23 2920 F Street, Suite C-5, Bakersfield, California 93301 ("Bakersfield Office"); 20 21 1555 W. 5th Street, Suite 270, Oxnard, California 93030 ("Oxnard Office"); 18 ® Defendant Clinics and Other Billing Entities 6 12 LAW OFFICES COTCHETT, PlTRE& McCARTHY, LLP Terrence knowingly and unlawfully: (a) ordered unnecessary h. . 5339 N. Fresno Street, Suite 105, Fresno, California 93710 ("Fresno Office"). COMPLAINT 15 1 53. Defendant Bahar Gharib-Danesh Chiropractic, Inc. ("Danesh 2 Chiropractic") is located at 132 Vermont Avenue, Suite 204, Los Angeles, 3 California 90004. Danesh Chiropractic is owned and controlled by Defendant 4 Gharib-Danesh. Danesh Chiropractic is a suspended California corporation. 5 54. Defendant Pain Free Management Company LLC ("Pain Free 6 Management") is a California LLC located at 6944 Reseda Blvd., Reseda, 7 California 91335. Pain Free Management is owned and controlled by Defendants 8 Gharib-Danesh and Tony Danesh. 9 55. Defendant Pain Relief Health Center, LLC ("PRHC") is a 10 California LLC located at 6944 Reseda Blvd., Reseda, California 91335. PRHC is 11 owned and controlled by Defendant Gharib-Danesh. 12 56. Defendant Pain Free Diagnostic ("PFD") is a California corporation 13 located at 4335 Van Nuys Blvd., Suite 422, Sherman Oaks, California 91364. The 14 agent for service of process is Bardia Danesh. 15 57. Defendant CA Orthopedic and Pain Centres, Inc., a Medical 16 Corporation ("CA Orthopedic") is a California medical corporation located at 17 9644 Reseda Blvd., Reseda, California 91335. CA Orthopedic is owned and 18 controlled by Defendant Tushar Doshi, M.D. 19 58. Defendant Southern CA PainCentre, Inc. ("Southern CA Pain") is 20 a California medical corporation located at 6944 Reseda Blvd., Reseda, California 21 91355. Southern CA Pain is owned and controlled by Defendant Behnoush 22 Zarrini, M.D. 23 Defendant Mindwaves Psychologica[ Services, Inc. ("Mindwaves") 24 is a California professional corporation located at 4712 Admiralty Way, Suite 476, 25 Marina Del Rey, California 90292. Mindwaves is owned and controlled by 26 Defendant John Terrence, PsyD. 27 ® 59. 28 60. Defendant Sanchez Chiropractic, Inc.("Sanchez Chiropractic") is a California corporation located at 42544 lOth Street West, Suite G, Lancaster, LAW OFFICES COTCHETT, PITRE& MCCARTHY, LLP COMPLAINT 16 1 California 93534. Sanchez Chiropractic, Inc. is owned and controlled by 2 Defendant Rodrigo Sanchez, D.C. 3 61. Defendant United Health Services ("United Health") is a California 4 corporation located at 20929 Ventura Blvd., Suite 47385, Woodland Hills, 5 California 913 64. United Health Services is owned and controlled by Bardia 6 Danesh. 7 62. Defendant Omnipysch, a Medical Corporation ("Omnipysch") is a 8 California medical corporation located at 2312 W. Victory Blvd., Burbank, 9 California 91506. · 10 63. Defendant Southern California Industrial Clinic ("SoCal 11 Industrial") is a suspended California corporation located at 2717 Angelo Drive, 12 Los Angeles, California 90077. SoCal Industrial is owned and controlled by 13 Khosrow Gharib, the mother of Defendant Gharib-Danesh. 14 64. Defendant Encino Care Pharmacy, Inc. ("Encino Care Pharmacy") 15 is a California corporation located at 16025 Ventura Blvd., Suite 100, Encino, 16 Califomia 91436. Encino Care Pharmacy is owned and controlled by Defendant 17 Nira Hariri. 18 G. Defendant Does 19 65. The Defendants set forth above are just a few of the individuals and 20 entities Qui Tam Plaintiff knows are involved in the schemes alleged herein. Qui 21 Tam Plaintiff is ignorant of the names and capacities of additional individuals and 22 entities sued herein as DOES 1 through 60, inclusive, and therefore sues such 23 Defendants by fictitious names pursuant to California Code of Civil Procedure 24 § 474. Qui Tam Plaintiff will amend this Complaint to allege the true names and 25 capacities of the fictitiously named Defendants once they are ascertained. ® LAWOFFJCES COTCHETT, PITRE& MCCARTHY, LLP 26 H. Agents, Co-Conspirators. and Aiders and Abettors 27 66. Qui Tam Plaintiff is informed and believes, and on that basis alleges, 28 that at all times herein mentioned, Defendants, and each of them, were acting as COMPLAINT 17 1 each other's agents and within the course and scope of their agency with the full 2 knowledge, consent, permission, authorization, and ratification, either express or 3 implied, of each of the other Defendants in performing the acts alleged herein. 4 67. As members of the conspiracy alleged below, each of the Defendants 5 participated and acted with or in furtherance of said conspiracy, or aided or 6 assisted in carrying out the purposes ofthe conspiracy, and have performed acts 7 and made statements in furtherance of the conspiracy and other violations oflaw. 8 Each of the Defendants acted both individually and in alignment with other 9 Defendants with full knowledge of their respective wrongful conduct. As such, 10 the Defendants conspired together, building upon each other's wrongdoing, in 11 order to accomplish the acts outlined in this complaint. 12 68. Defendants are individually sued as principals, participants, and 13 aiders and abettors in the wrongful conduct complained of and the liability of each 14 arises from the fact that each has engaged in all or part of the improper acts, plans, 15 conspiracies, or transactions complained of herein. Defendants, and each of them, 16 have participated in or in furtherance of the conspiracy and other violations of 17 California law, or aided or assisted in carrying out its purposes as alleged in this 18 Complaint. The conspiracy "may be inferred from the nature of the acts done, the 19 relations of the parties, the interests of the alleged conspirators, and other 20 circumstances." Sales Corp. v. Olsen (1978) 80 Cal.App.3d 645, 649. 21 I. Un-Named Co-Conspirators 22 69. Various other persons, firms, and corporations, not named herein as ® 23 Defendants have participated as co-conspirators with Defendants, and each of 24 them, and have performed acts and made statements in furtherance of the 25 conspiracy. In the course of participating in the conspiracy and in furtherance of 26 the objective of the conspiracy, these co-conspirators made statements prior to or 27. during the time these co-conspirators were participating in the conspiracy that fall 28 within the provisions of California Evidence Code Section 1223. LAW OFFICES COTCHETT, PrrRE& MCCARTHY, LLP COMPLAINT 18 1 70. Some of these persons, firms, and corporations are as yet unidentified 2 because their identities are unknown to Qui Tam Plaintiff ai this time. Once the 3 identities of these unknown co-conspirators are ascertained, Qui Tam Plaintiff will 4 seek leave of court to add them as Defendants herein .. Others that have been 5 identified are set forth herein. Qui Tam Plaintiff reserves the right to bring claims 6 against these other persons, firms, and corporations at a later date. The following 7 persons, firms, and corporations have been identified as having knowledge of 8 some of the allegations in this Complaint. 9 71. RogerS. Ralm, D.C. ("Rahn"), California Board of Chiropractic 10 Examiners License Number 19253, is a chiropractor practicing in Southern 11 California. His principal place of business is 5339 N. Fresno Street, Suite 105-E, 12 Fresno, California 93 710. Rahn is employed by Defendant Gharib-Danesh and 13 practices at the Clinics. Dr. Rahn is not named as a defendant in this action. 14 72. Tram Tran Sotelo, D.C. ("Sotelo") California Board of Chiropractic 15 Examiners License Number 30533, is a chiropractor practicing in Southern 16 California. Sotelo's principal place of business is 1555 W. 17 Oxnard, California 93030. Sotelo is employed by Defendant Gharib-Danesh and 18 practices at the Clinics. Dr. Sotelo is not named as a defendant in this action. 19 73. srt' Street, #210, Catalino Dominic Dureza, M.D. ("Dureza") Medical Board of 20 California License Number A66607, is a medical doctor practicing neurological 21 surgery in Southern California. Dr. Dureza's principal place of business is 79935 22 De Sol A Sol, La Quinta, California 92253. Dr. Dureza is·employed by Defendant 23 Gharib-Danesh. Dr. Dureza is not named as a defendant in this action. 24 ® 74. · Raquel Christine Dureza-Muneses, M.D. ("Dureza-Muneses'') 25 Medical Board of California License Number G84893, is a medical doctor 26 practicing neurological surgery in Southern California. On the State· of California 27 Medical Board website, Dr. Dureza-Muneses' principal place of business is P.O. 28 Box 94, Wbite Marsh, Maryland 21162. Dr. Dureza-Muneses is currently LAWOFFlCES COTCHETT, PITRE& MCCARTHY, LLP COMPLAINT 19 1 employed by Defendant Gharib-Danesh. Dr. Dureza-Muneses is not named as a 2 defendant in this action. 3 7 5. Edwin Haronian, M.D. ("Haronian") Medical Board of California 4 License Number A71385, is a medical doctor practicing orthopedic surgery in 5 Southern California. Dr. Haronian's principal place of business is 16542 Ventura 6 Blvd., Suite 402, Encino, California 91436. As of April11. 2011, Dr. Haronian 7 was employed byDefendant Gharib-Danesh. Dr. Haronian is not named as a s defendant in this action. 9 License Number A47841, is a medical doctor practicing anesthesiology in 11 Southern California. Dr. Jain's principal place of business is 19716 Trammell 12 Lane, Chatsworth, California 91311. Dr. Jain is employed by Defendant Gharib- 13 Danesh. Dr. Jain is not named as a defendant in this action. 77. Stepan Ozcan Kasimian, M.D. ("Kasimian") Medical Board of 15 California License Number A77961, is a medical doctor practicing orthopedic 16 surgery in Southern California. Dr. Kasimian's principal place ofbusinessis 1505 17 Wilson Terrace, Suite 300, Glendale, California 91206. As of April11. 2011, Dr. 18 Kasimian was employed by Defendant Gharib-Danesh. Dr. Kasimian is not 19 named as a defendant in this action. 20 78. Abel R. Quesada, M.D. ("Quesada") Medical Board of California 21 License Number A1 00315, is a medical doctor practicing in Southern California. 22 Dr. Quesada's principal place of business is 1125 E. Broadway, #251, Glendale, 23 California 91205. Dr. Quesada attended medical school at the Autonomous 24 University of Guadalajara Faculty of Medicine. Dr. Quesada is employed by 25 Defendant Gharib-Danesh. Dr. Quesada is not named as a defendant in this 26 action. 27 ® Sanjiv Kumar Jain, M.D. ("Jain") Medical Board of California 10 14 LAW OFFICES COTCHETT, 76. 28 79. Parviz Salehi, M.D. ("Salehi") Medical Board of California License Number A3 9866, is a medical doCtor practicing surgery in Southern California. On PITRE& MCCARTHY, LLP COMPLAINT 20 1 the State of California Medical Board website, Dr. Salehi's principal place of 2 business is listed as P.O. Box 1026, Woodland Hills, Califomia 91365. Dr. Salehi 3 attended medical school in Iran at Shiraz University Faculty of Medicine, also 4 known as Pahlavi University. As of Aprilll, 2011, Dr. Salehi was employed by 5 Defendant Gharib-Danesh. Dr. Salehi is not named as a defendant in this 6 action. 7 Aflatoon Kamran, D.O. ("Kamran''), Osteopathic Medical Board of 8 California License Number 20A8503, practices osteopathic medicine in Southern 9 California. Dr. Karman's principal place of business is 520 Superior Avenue, 10 #245, Newport Beach, California 92663. As of Aprilll. 2011, Dr. Kamran was 11 employed by Defendant Gharib-Danesh. Dr. Kamran is not named as a . 12 13 defendant in this action. 81. Edward Nana Opoku, Jr., D.O. ("Opoku"), Osteopathic Medical 14 Board of California License Number 20A11418, practices osteopathic medicine in 15 Southern California. Dr. Opoku's principal place ofbusiness is 2222 Foothill 16 Blvd., #E122, La Canada Flintridge, California, 91011. Dr. Opoku is employed by 17 Defendant Gharib-Danesh. Dr. Opoku is not named as a defendant in this 18 action. 19 82. Rehab Acupuncture, Inc. ("Rehab Acupuncture") is a California 20 corporation located at 430 3211 ct Street, Suite 100, Newport Beach, California 21 92663. Rehab Acupuncture is owned and controlled by Nam Suk Lee, Lie. Ac., 22 California Acupuncture Board License Number 8662. Nam Suk Lee is among the 23 acupw1cturists employed by Defendant Gharib-Danesh. Rehab Acupuncture is 24 not named as a defendant in this action. 25 ® 80. 83. Advanced Management Group, LLC ("Advanced Managemene') is 26 a California corporation .located at 523 W. 6111 Street, Suite 626, Los Angeles, 27 California 90014. Advanced Management is not named as a defendant in this 28 action. LAW OFFICES COTCHETT, PITRE& MCCARTHY, LLP COMPLAINT 21 84. 1 Caring Health Services, LLC ("Caring Health") is a California LLC 2 located at 4335 Van Nuys Blvd #422, Shennan Oaks, California 91403. Caring 3 Health is not named as a defendant in this action. 85. 4 5 USS Orthopedic Physical Therapy, PC ("USS Orthopedic") is a California professional corporation located at 16835 Algonquin Street, Suite 499, 6 ·Huntington Beach, California 92649. USS Othopedic 7 is not named as a defendant in this action. s 86. San Fernando Diagnostic & Imaging, Inc. ("San Fernando") is 9 California corporation located at 16060 Ventura Blvd., Suite 105-338, Encino, 10 California 91436. San Fernando is not named as a defendant in this action. 87. 11 a Pacific RX, LLC ("Pacific RX") is a California corporation located 12 at 1700 N. Chrisman Road, Tracy, California 95304. Pacific RX is not named as 13 a defendant in this action. 14 IV. HOW THE SCHEME WORKS 15 A. Billing for Comf!ound Medications Off a Log 16 88. Every day billing clerks working at the Clinics are given a 17 Medications Log by one or more of the following Defendants: Gharib-Danesh, 18 Anthony Danesh, or Joanna Munguia. These billing clerks then consult the 19 Medications Log and bill insurers for the compmmd medications as listed. These 20 Medications Logs are spreadsheets shared through the Google Docs internet 21 application, listing what medications to bill insurers for each of the patients. 22 Although the Medications Logs purport to reflect the prescriptions of physicians, 23 in reality, the Medication Logs serve as a mechanism by which the Clinics ensure 24 billing for the maximum number of prescriptions for each patient. 25 26 ® 89. Qui Tam Plaintiff, in her responsibilities structuring the Clinics' ·internal billing department, initially sought to obtain the tmderlying prescriptions 27 that were necessary to construct the Medications Log and bill insurers. She found 28 that many of the drug entries on the Medications Log had no accompanying LAW OFFICES COTCHETT, PITRE& MCCARTHY, LLP COMPLAINT 22 1 prescription, and others had unsigned prescriptions. Qui Tam Plaintiff also 2 witnessed Defendant Munguia and other employees forge the signatures of 3 physicians and chiropractors, and was initially asked to do the same. 4 90. Attached as Exhibit Cis an example of a Medications Log used at the s Clinics for the purpose of billing insurers. According to this log, Dr. Pratley 6 allegedly examined 41 patients on April 1, 2011. Dr. Pratley never saw any of 7 these patients on Aprill. 2011. 8 9 91. Exhibit C also shows that of the 41 patients allegedly seen by Dr. Pratley on April I. 2011, 39 patients received exactly the same drugs; Capsacin 10 .069%, and 40 patients received Amitriptyline 2% and Flubiprofen-D. This 11 pattern demonstrates the fraudulent nature of the Clinics' practice, as every patient 12 is receiving the same medications irrespective of his or her actual condition. Every 13 claim submitted to insurers for prescriptions written without a legitimate medical 14 purpose is a false claim. 15 92. Additionally, the Medications Log is not supported by actual 16 legitimate prescriptions written by physicians. Many of the prescriptions that the 17 Medications Log is allegedly based upon are either forged or unsigned, and some 18 have no accompanying prescription. 19 93. Further, Dr. Pratley, the physician listed as the attending and 20 prescribing practitioner, did not practice at these Clinics. His credentials were 21 used without his consent to bill insurers for services and medications. Each and 22 every bill based off of the Medications Log showing Dr. Pratley as the treating and 23 prescribing physician constitutes a false claim. 24 ® 94. Exhibit Dis a printout of an email chain dated February 16,2012, 25 including replies by Defendant Gharib-Daneshand Defendant Munguia. In the 26 email chain, Munguia reports to Gharib-Danesh that they have found all the 27 prescriptions that exist.· In response, Gharib-Danesh states Munguia should "have 28 [the billers] stop looking and just bill by pharm report" (sic). She fmiher states LAW OFFICES CoTCHETT, PITRE& MCCARTHY, LLP COMPLAINT 23 1 "billers shouldn't waste time looking for RX." This email shows Defendants 2 billing insurers for medications that did not have prescriptions and using the 3 Medications Log to maximize billing. 4 95. Exhibit Eisa printout of an email dated June 22. 2012 by Defendant 5 Gharib-Danesh, chastising her employees for failing to comply with the Clinics' 6 prescription policy. In the email, Gharib-Danesh states "[i]f20 patients come in 7 Central needs to get 20 RX/20 Referal needed /20 eswt screening fonn /20pr2" s (sic). Gharib-Danesh is reminding her employees that every single patient seen 9 10 11 must receive a prescription, a referral to other Clinic services, a shockwave therapy screening, and a progress report follow-up appointment. 96. Every claim submitted to insurers for prescriptions that do not have a 12 signed prescription written by a physician is a false claim. Further, every 13 prescription and procedure billedto insurers that was ordered pursuant to the 14 Clinics' policy of uniform patient care, instead of independent medical judgment, 15 ·is a false claim. 16 B. Enforcement of Daily Patient Quotas 17 97. A central element of the Clinics' fraudulent scheme is to ensure that 18 as many patients as possible are processed through Defendants' sham medical 19 mill, irrespective of whether they actually need treatment. All managers and 20 schedulers are warned that they will be terminated if they fail to schedule 50 21 patients every day at each of the Clinics. 22 @ The managers and scheduling staff at each Clinic- not medical 23 professionals- are responsible for determining whether patients require 24 additional treatment and medical care. These managers and scheduling staff 25 receive care instructions for all oftheir patients from Defendant Gharib-Danesh, 26 even though Gharib-Danesh does not treat these patients. 27 LAW OFFICES COTCHETT, PITRE& McCARTIIY, LLP 98. 28 99. Exhibit F is a printout of an email chain dated November 17, 2011 written by Defendants Gharib-Danesh and Munguia, warning Doctor Eoh, as well COMPLAINT 24 1 as the managers and medical representatives at the Clinics, that they will be 2 disciplined if they fail to schedule 50 patients a day for each Clinic. This email 3 chain demonstrates patient throughput was the primary objective of the Clinics, 4 and also shows that treating physicians were not the individuals responsible for 5 ordering appointments and treatments for patients. See excerpt below: 6 7 Joanna Munguli jmunguiaprhc@gmall.com 8 10 Jessica, Mildred, Uz~t mayra, M!l.ribel, me, ballardc. Eoh 9 @TI}. 10 11 12 Managers and Ma Date: The, Dec 13, 2011 at 8:42AM Subject: Rc: Warning To: Christina Sills We'll talk In person. There arc things that we need to work on and improve. For now goa! Is sending All delayed pharm out Seen 1!0mt Sent from my !Phone On Dec 13,2011, at 7:53AM, Christina Sills ~naprhc@gmail.com> wrote: So this means you .are not happy with my job'? I did the best with this department that I could and I have only been here a month, you have hardly given me a chance. The problems are that we don't get information to bill correctly and efficiently. It takes us way too 111uch time to sort through this stuff. Let me know. Respectfully, Christina On Tue, Dec 13,201 l at 7:46AM, Bahar wrote: HI Everyone ·Unfurtunately we have to make big changes since billing departments is fililing and we are givin this one last chan.ce , numbers needed dont get accomplished • depanment will be shut and billing outsourced... Changes: - Johana will manage the billing Department till we find a better management system • numbers u see on the board are what needs to be done. If u are close to max requiJ'ed tt will get a bonus, lfu are below Min then unfortunately we can't keep u in that department, This Is for both billing and mailing numbers. ~No personal phone calls. -No more excused , lntb missing u Cll.ll't blll • put it in the Box for central to fix. Otherwise Bill Bill Bill NO EXCUSE Mail Mall Mail NO EXCUSE -Johana pls make sure everyone in billing department gets this email. Thanks Sent from my iPhone > 2 EXHIBIT =<-"- ·-~~ .. '"-"---..~----------------------------------------------------------------~~ • Mindwaves Psychological Services, Inc (Initial & P & S Medical-Legal Psychological Report} . '3 2 4 1.3? '32: -- L: .- jgi Rodrigo Sanchez DC 10I12i11 1 n.75 1.15 ms . 53,3150 JIZ 5? 5"3 Jorge Rivas DC 10112111 1.75 8.75 2.25 - $2,195.90 $313250 Jorg: IOIWII 1.?5 0.75 . . $2,195.00 $3,131.Vii." fi 3.35 1:33-75? I 3 I .. 35-2 I 10/1311 . 6.75 1 $2,155.00 $3,132.50 .1. 10/1311 10112111 3 . - 53.13150 $3,132.50 Mum . - 53.13250 Lana 10113111 - 1 - . $3,132.50 Lana MontesDC 10f13/I1 $3,132.50 53,132.33i I ?1 1011311 $2,195.00 $3,132.50 Charles Boyer DC 10/14f11 Charles Bayer DC 1011-4111 $3,132.50 Cha?es Boyer DC 10?4f11 1.. $3,132.50 Chm-tam DC iofwu . . 52,195.00 53,132.59 52.195110 53.13250 10/14111 Cherie: DC . . - Ty daarles Boyer DC min/'11 $2,195.00 53.13250 Charles ?oyer DC m??n $2,135.00 $3,132.53 mm?. . 1.75 0.?5 $2,155.00 $3,132.00 .- - . $2,150.00 $2,910.00 .. Chm-has Boyernc 10mm $93750 Charies BoyerDC 0313mm $750.00 125.3? . Cha Hes Boyer 07/25?? $750.00 $2,150.00 $2,910.00 Elham Men-sat DC 02/02/08 $360.00 06/ng 5750-00 $75000 $2,150.00 $2310.00 $2,150.00 $2,910.00. 52390-00 $93750 $2,020.00 $2,957.50 ., $937.50 $2,195.00 $3,132.50 mu Charles BoyerDC 59.3750 $2,195.00 Dennis Fus?t Atty ems/10 $93750 $2,195.00 $3,139.50 Tram SatechC 03/2010 $037.50 $2,155.00 53,1330 .- Na Young Eah Dc wows $937.50 $2,195.00 53, Charles Bayer 0c 05120110 $957.50 .. - $2,195.00 $3,332.50 Charles Boyer DC osiosxm 5937,50 - $249500 $3,132.50 T?m SuteloDC negoano 593730 - 52,195.00 55,132.50 Na Young th DC 10(241?10 $937.50 . . - $2,195.00 $3,131.50 1322/10 595750 . . $2,155.00 $5,132.50 01,0311 $93350 . . . $2,335.00 $5,132.50 ~c~..O:· "'"'"'-"". . ,·.,~.•~·-<~-~- - ·- ""·· ... - . -~ ·-• ' ·---~------------------------------------------------------------------ - .,.. ,. -··- ·.-~, ..,..;._..,._, EXHIBIT in Em'iwim )4 xiimm?.wa gnaw? may? ?ma? *3qu Eng? ?gmg? ?uwm?mw any uggmm . Eugw mm?m .. Ma? SEEK anaemia? ?1 5mg? mnw?m?un??a?w Emma? ~-------- ---~__,-~__,,_,_,---~_..__,,.,...~-~,.,-~~~ 'Ti)tal Nur...ber of Scripts. Per d ~· 0115%, ~ Ok:lQ{~ T~cCapsaidn a4 cf 1S%. Ranhidin.. ~ M7S.. zapmej Capsacin .Carnpfwr l~ ~ ~-Amltript f1Ufblpro :e51ltl50'75/150 _m:g _~_ __ ,12%. !llS~ -~-~- line 2 % :_rti~~ };m._:~ ,0..-69% Cydoben o· _ _ T<¥n~ Tram ad Mag /APAP of/APA 10/200 ;_??;!S?;_TL? . ,.~~ ·c~e;-c4 . ... nz/MS _Ambito :Traza , ""' T"""' fUSIDN FRODUcr ~ e ST"'f"Y .TabraOol'rt o~:fanatex fusepaq:~ ._2.SOml :;z5f}m! !f~'ktspes; f.aspaq -sOOml -~ 420;-rtl ~-·-· -~-~-li~---·". X X X -' ,x ' ' ' •' ' X •' ' ' ' ' ' X . X ~- ~- -~---- ,' X ' . t" :x ' .' _,' ··-·- .. <·· ---·· ' • X ' Total Number of- Xript$. Per Patient - rnclofat ;p-..j GJ15 %, Tr.un.adoJ Capsaicin lS"%, 0,075., CapsaOn 'Comphor T!1!<1li!do · Uips.acln Amitrip:y Amitrlpt · DOS:NE£0 0.~-~-- . --~-~-- _ilS(' ;Fiwbipro :~ Cydt:!bro ct -~. R:an!tidin ~!:Doe :T~ :Tram-ad .Mag ,e 501150 .15{15!) :/APAP iclfAPA 1fJ/'XIJ ~0:0?. ~-- ·rme2.~-- -~T!. 'fen-D _--~ mg _____________ ~?O.ms{!' - - -------- -~-g-. Synapry · C:yd:obe .C4 _nzif>!S '.Am~U M :run -------------·--. Dkopano:fanaw: .! fusepaq fw;p;;;q 150m! 420ml < ' • < f T.otai Numbff ofsmptsF~ ( LOS%, 'T~dol: Citpsa/pyrlo ;~ iFUS@aQ :f~ lhm:p;oq_fwpaq ,M nm "tren mg do:OO ZSOml ZSOmi 500mi ,150ntl ;420m! rng _mg_ ;zsr;:.a_llll:~ itn~. ..Q 15%, 0..075,. c..mptm> ·rr.un,acio ~ Amrtnpty Amftrlpt 12% il.5~ ~Ol:lS%~ ~lm:ef~__)'ili'!!:-TI~- ,,' ' X ' --~ X ---~--" X ,.,_, """'""" X x X ....~. X ' . . --· ···--·-· ......... ,' ,' ' ' ' '' X X X ' ,:!( X X X ' ' ' X x . X X , Patient . a . .w 2Q 331 mmaa?w . um ?mam? ma?a?? .n?a?mw . g? Exam, a. .H K?g?g mm mmw?mu wags wag? .. mm??mummg wywmu New?? gamma ma?a ?raga Mas. gum.? ?3mg \w?wwg?w?. .. am. wid?imfm-imiwi Mimim'm'mzmimimgm Joow. FUSJOO ~cr ~~--~1!9., "'-""" O.OS%. lram.adol: :Capsak:jn lS%, 011'15, Tramat~o .HS% Ddofl!n :Dido~ 'Cydoben- s,.,.., T"""' Oeptltin ·cj ;Z<~:prtne] G;ili-aper1 -e Tabtadol n Dl:cop;mc. f.andtex B:arntkfrn :R-arnt#;fule _Tr~i :Ttar.ad M~ Cydabe:C4 Dlpsadn !lmltrlpty!\mitript flurbipfn e 50!150 ;75/l5fJ /l!X X " X X , ' '"""' X X X """" ""' X X '· X X X X :•' fUOON PRODUCT ·"-"" 0.05%~ Tramadcl;~ Oidofun ,OQofena d ac:/ Cydo.ben mJMS 'Tn!':ab : Depritin S'fl'i ;mg_ -~_fiS:'f! ..... ?-1% '115% 0.05%, ;line_2% -~~!!-.. ~- Cydohe'_C4 :ben ~-~--.. -----rl~_____ j~-~----'~SOm1. of S;;ripts Per Patl wrote: On Wed, Feb 15, 2012 al5: ·.Melissa Jtmkins · II Universal Management Solutions Billing Dept. PH: IQ1§l §§§··81H!l FAX : 1818l66Q·8238 1 1a (7 days ir.0'~ I G Maribel Astorga maribel.prhc@gmail.com to Bahar, melissa, Tony, Joanna, ESMIDA, me ~ There are NO Khan files in LB therefore cannot scan. I don't know who they or where they are. I have advised Joanna already. (sJit•J~~~ H - - - - - - -. '''"'~""""'·· ""·'''-"•'- ,.,,,. :..... ' melissa jenkins melissaprhc@gmail.com to Bahar, Tony, Joanna, Maribel, ESMIDA, me rru. L.::.J . Uvalda is not billing CHM Dr. , he was billing Funding Refills which are all billed now. The rest of the day he did our Reprints for NCPDP forms HCFAs & made all corrections if needed. As for the CHM project Martha & Connie billed all that they could have billed with the folders & RXs they have. So they were looking for RXs in the server as well @Jl![==-==---~~~-=-----=--Bahar bahardc@gmail.com Fob 16 r ''''Toij.c r~1 • 0' . to melissa, Tony, Joanna, Maribel, ESMIDACASTILLO, me ~ [§] Pis have them stop looking and just bill by pharm report. extern will look for RX Scan and email Me 1 full Chm package including assignment pis Sent from my iPhone rrr.ii''' ····················· 10 f!w_, _. . . . ;.:. . .~ , . . : :. . . . :·. :. . . . . . . . .:. . .:. :. . . . . :;. .:, .:. . ;.,. .~............ · · · · ·-· -· · . . . . . . . . . Joanna Munguia jmunguiaprhc@gmail.com Feb 16 r d•Y, jr:;'~ to Bahar, melissa, Tony, Maribel, ESMIDACASTILLO, me ~ We are done looking for RX's all we found is all we have, So now Araceli is generating a list and we will send it to the pharmacy so they can print them. If you want to expedite we can send them without the RX. It is up to you. 2 ' ~ . ,l@l· ···------·· .····-················ i !~~"""" '" .., '., ..,...,,.,, ...,, "·"' " "~'"' "'" '"~'"'"·'" " "~" ':." "'". .:.,'"'· .... '"'"~·-····· j0 Cl.ict~ere io·R~pi)t,, Replyto a!!,gr F()r~~;-a· :· 3 ......... , .. '' EXHIBIT •• Missing RX or missing Comments in RX Inboxx Bahar drbahar@mpnproviders.com Jun 22 (6 days ago) to Joamta, Fresno, Danesh, Norma, Noel, Mayra, Bianca, me, Lizet, Dr, ESMIDA, Jessica, RachelRezaeinia, Sonia, Suzy, Araeeli, Mildred;Ramirez, Jose Bi.Johana i>er Dr Opoko he ordered mcds for aU patients he saw today so Not sure why fresno staff are saying 8 patients don't have RX because they don't need meds due to rashes /et.c ? Very disappointed beeause after all meetings ln central I see that the staff now making up excuses for their incomplete job 7 The question is Was RX placed in all flies fo.r Dr Opoku to either o.rder or write ln reasons why meds /creams not needed or some files were incomplete and were missing RX /other fom1s and manager that was suppose to audit and statfNever noticed the missing Rx and now they are making up excuses why no creams was nee®d and blaming it on the doctor when DR Opoku clearly stated that all patients seen today got the ereams ? How come 8 RX s are missing then ? lmjust shocked because Whe.re does fresno staff gets the statement of patients getting rashes exactly ftom'l Absolutely correct that not all patients needs meds /creams/etc but that's not decided by staff and we don't want stnffto make up things to justify their own missing paperwork and Jack of organization or make up medical decisions. We need to have doctors comments on every Rx so reasons are documented and tracked and followed up if needed. •• So managers from 11ow on any MD clinic lf20 patients come in Central needs to get 20 RX /20 Referal needed /20 Bswt screening form /20 pr2 s emailed back to central. Either with doctor orders md sign!Uure or with doctors reasons why med /procedure not needed and comments, To track from central. Mildred and Yessica pis track so numbers of PTA match with RX /PPW received with comments. If Issues bring it to my attention and the provider immediately. Thanks Sent from my iPhone On Jun 22, 2012, at 6:46PM, Joanna MWlguia wrote: What about Creams how many?? On l1ri, Jun 22. 2012 at 6:41 PM, Fresno PRHC wrote: GOOD AFTERNOON, HEAR IS THE TOTAL COUNT FOR TODAY.... SHOCKWAVE: 19 VSNCT: 11 THERAPY:37 DR. OPOKU: 27 SHOWED 38SCHEDULED DR. RAHN: 1 (PI) U.A: 23 ONLY (SHORT SUPPLIES) THANK YOU, LETTY Fresno Office 5339 N Ft·esno Street Suite lOS Fresno CA 93710 Tel: 559·222-9400 Fax:559·222-9404 Joanna Munguia jmunguiaprhc@gmail.com to Jessica, Mildred, Lizet, mayra, Maribel, me, bahardc, Eoh ~ . Managers and Med Rep, This is a verbal warning to all of you. We need to make make sure we are scheduling 50 patients for the MD clinics. The show up rate is very low anything below a 50% will result in a written notice or possible demotion. Also remember all the patients that come in for MD need to get UA and mads. The numbers are very off, you need to monitoring this, this is part of your job IIll Let me know what the issues are "'""" ,, ................. -,... " ......... Joanna Munguia Maribel Astorga maribel.prhc@gmail.com 11/17/' to Joanna, Jessica, Mildred, Lizet, mayra, me, bahardc, Eoh Issues are that there is not enough patients to put on schedule, not all pts need specialty m.d.'s and/or there are denied cases and cannot be seen by the surgeons. With the meds we have Simpson, Boniface and Zarrlni coming in different dates In one month and pts are already been seen so they cannot be seen again because that would create in duplicate meds. And there is also an issue with Zarrini PA taking way to long because he Is having to do a written report plus a typed and pts get frustrated because of the amount of time that it gets for 1 them to be seen and they either leave or ex or r/s. Zarrini's PA has even told us that he can't handle that many pts. . I .·l., 11/18/' Bahar cainjurysolution@gmail.com to Maribel, Joanna, Jessica, Mildred, Lizet, mayra, me, Eoh Managers We are talking about 50 pts on onubah I zarini and 40 simpson/ jain. U guys just need to make sure all med RX Is signed and all pts UA is taken. No Excuse Bcuz doctors have completely different RX and meds will never be ordered duplicate. Even if they see MD every week. Plus it all goes to same pharmacy and is tracked and never more than 3 gets processed per month. Your job is to make sure every single patient gets their UA done and RX gets signed. Regardless insurance or no ins. Your job is not to make sure pts don't get duplicates. Thafs central and pharmacy job. Pis don't tell me there's not enough pts to scheduled formed/ SW Bcuz when we audited the log 2 weeks ago Ia 200 pts needed to be scheduled and less busy offices 100. There was 600 pts that had never seen MD s. -Also there's no reason to not schedule 50. That's the reason I asked manager to be there with MD assisting them to go thru all pts. And make sure all pts get their medIus I SW and if any pts can't get it put notes on the script. But that's Usually 10%. I don't want MD come and go and 50% of papetwork incomplete , UA not done, etc .... Then what are managers there for??? U guys need to go in with MD and check every single file to make sure clinics are productive and not a waste. In regards to Yousef he doesn't do the computer program anymore so he should be able to see 40-50. If he falls behind tell him to rush and If he doesn't listen call me or johana. Managers u each have 1-2 Clinics to supervise and u need to be 100% on top of everything that's happening in hour clinics and what MD s do. We schedule MD s to supervise SW and formed/ UA I injection. No MD are allowed to do any other service there that we are not aware of. I just heard that dr simpson been performing EMG on pts without notifying us when we are contracting another company for EMG services. Is this true??? U guys are the managers and ur responsibility is physically be present with the MD and help and audit and u don't even know what MD s been doing In our clinics? If simpson is doing EMG how come non of the managers called and asked if that was allowed when u all know we use neurology companies for Ncv I emg. ??? Jessica? Maribel ? Mayra ? Liz ? Does simpson do emg there? 2 In regards to specialties pis update ur referral needed with case status and which pts been seen. And have 1 of ur staff continue doing the MRI finding typing so we can go thru them and see what other pts we can add. Thanks ;Sent from my iPho~e ',•· Maribel Astorga maribel.prhc@gmail.com 11/18/' to Laura, Bahar, Joanna, Jessica, Mildred, Lizet, mayra, me, Eoh So for the pts that have ins pending, we can put them for meds?? Is Encino going to be sending meds even vi/ no ins?? I have never seen Simpson do any EMG in SA or LB and pts have not mentioned that he is doing this to them. ' •• -.-moon "''"~,"''""""":~\""'"' ''"'' .,., •• , ·••~~'""m•"""" • •• • -·'--""- ',, *********************************************************** NOTICE: This e~mail, including attachments, contains information that may be confidential, protected by the attorney/client or other privileges, or exempt from disclosure under applicable law. .: ~' Further,· this e-mail may contain 3 "" information that is proprietary and/or constitutes a trade secret. This e-mail, including attachments, constitutes non-public information intended to be conveyed only to the designated recipient of this communication, please be advised that any disclosure, dissemination, distribution, copyi'ng, or other use of this conununication or any attached doCument is strictly prohibited. If you have received this communication in error, please notify the sender immediately by reply e-mail and promptly destroy all electronic and printed copies of this communication and attached documents. *********************************************************** 4 '·' EXHIBIT FCE 1 message Joanna Munguia <)munguiaprhc@gmail.com> Wed, May 4, 2011 at 11:36 AM To: YANIRA RAMIREZ , DENISE ROBLEDO , belinda felix , Rosa Torres , "adllene.prhc" , bahar danesh , Visalia PRHC , Juan Hernandez Cc: Jessica Caceres , Esmi new email , Bianca Rivas , Mildred Ramirez Cola Schedulers and Reps, Please schedule 20 paitents for FCE all finals. From 10-1 every 15 minutes. Please send the schedule to 562490-8589 along with the paitents Demo, PR2 and the claim form. Thank you, Joanna Munguia Pain Relief Health Center Operations Manager B1B-zz6-nn.Fax B1B-v6-u91 EXHIBIT f • Central Audit 2 messages Joanna Munguia Sat, Apr 16, 2011 at 9:19AM To: bahardc , Rosa Torres , YANIRA RAMIREZ , DENISE ROBLEDO , belinda felix , rxprhc New Patletns Total: VA-9 BKF-17 LA·25 Ox-9 Res-10 SA-1 Lb-7 MRI: VA· 919 BKF-17119 LA-20/25 OX-719 SA1/1 LB- 617 RES-1110 6 pending appt DME: BKF-18/19 LA-12/25 VA-819 OX-7/9 SA..0/1 LB-017 RES-9110 Schedules Last Week LA-Ther 103 Acu 45 RPT- 45 Testlngs LA- SW 30 Vsnct 15, LA RTW-23, terrance 7 SA· ther 50 testlngs ncv-emg-13, zarinnl1 0 VA· ther 92, acu37 testings- ncv-emg??? VA pratley 47 SW-??? Vsnct?? OX-Ther-55 acu 40 rpt 60 terrance-8 zarlnni 10 sw 11 vsnct 9 LB- THer 80 rpt34 acu20, terrance• 7, lb· sw vsnct Bakersfield- ther 65, acu 45 testlngs ncv-emg 10 Next week testlngsLA zarinni- 12-4 vsnct- 25 ncv-emg-23 praUey-25 sw- 26 OX- Ncv-emg 23 Terrance- 0 BKF· Pratley· 47 sw. 36 vsnct· zarlnni 30 terrance 25 RES· sw-46 vsnct-25 long beach· terrance-17 Joanna Munguia Pain Relief Health Center Operations Manager 818-zz§-1171 Fax 818-776-1191 bahardc@gmall.com Sat, Apr 16, 2011 at 9:59 PM Reply·To: bahardc@gmail.com To: Johana email , Rosa email Torres , Yanira email , Dennise prhc email , Belinda Felix email , rxprhc , Sonia Martinez oxn email , April Alonzo email , Jessica Caceres PRHC email Guys why ur number of new doesn't match ur DME and MRI- all of u already know if numbers don't match u need to FU and see why Dr didn't order" u guys need to be specific and detailed in this" we don't need to audit and see problems and remind u guys toFU with ur offices and PTP severy time. This shud be automatic. I need detailed explanation on all RX missing by Monday 6 pm. And next audit I don't wanna see · same issue again pleaseeeee ? La "number for next wk testings are low. Yanlra/Aprii/Jessica u guys need to double the #s" LA zarinni- 12-4 SW- 26 vsnct- 25 ncv·emg-23 pratley-25 Oxnard : Dennise /Sonia what's lhe problem. Numbers of testing specially Zarini Is very low. That's not acceptable. What's the problem ? Sent via BlackBerry from T-Mobile From: Joanna Munguia Date: Sat, 16Apr2011 09:19:35-0700 To: bahardc; Rosa Torres; YANIRA RAMIREZ; DENISE ROBLEDO; belinda fellx; rxprhc Subject: Central Audit [Quoted text htddenj EXHIBIT ' Elliot Wachtel! Complaint 1 message Joanna Munguia Fri, Mar 4, 2011 at 11:16 AM To: YANIRA RAMIREZ , DENISE ROBLEDO , belinda felix , Rosa Torres , Astrid Magana . Cc: bahardc Central Reps: Please read the email below form Dr .Danesh from now on all the new patients you receive you have to make a courtesy call and ask them if they have received all there following appointments if they have not please give it to them and let me know so I can follow up with the manager. Thank you, ------- Forwarded message ------From: Date: Fri, Mar 4, 2011 at 10:48 AM Subject: Schedulers of Ia, reseda, lb, oxn , Vis, bkf, santa. And Drs I managers To: Jessica Caceres PRHC email , Montes email , April Alonzo email , LA email , Bianca email Rivas , LB email , Junior email , Oxn email , Sonia Martinez oxn email , Mildred email Ramirez , Reseda email , RX email , Esmi new email , Eoh email , Bkf email , Visalia email , Johana email , Tony D email -I just got a call from attorney Elliot watchtel very upset. -This pi "hilda Contreras" saw Dr Montez and was never given an appointment to go back by our office. The pt is in Pain and even the ally called and our staff failed to provide return time and date , "our staff said , don't worry we'll call her 2 weeks before her pr2 is due " -that's exactly ther reason we are loosing all these pts. -What's that ? After all these meeting and emails everyone In the office should know ALL patients should be given an appointment to come back for PT and re eval before they leave. -1 DON'T WANT ANY PTS LEAVE THE OFFICE WITHOUT RETURN APOINTMENTS , and I will start auditing GR my self as of today. And IF schedulers are not scheduling all pts for testing and return appointment , there won't be Warning this time "too many warnings already" they will be replaced immediately. So schedulers make sure PTP and Therapy day just sit by computer "Gr" and check all pts in and out and give them return appointment for all in ref needed , PI and re-eval. And submit soaps and superbills. If u want to keep ur job. Managers and doctors, that's main job duty of schedulers so pis make sure 3 PTP days schedulers are not assigned to do other work." Just GR -scheduling- submitting soaps /supebills- return appointments " Johana Schedulers/Gr staff in each office is: LA: April LB: Belinda Santa :Junior Oxn :Sonia BkF: ?? Vis:?? Re: Astrid or yessica ? Sent via BlackBerry from T-Mobile Joanna Munguia Pain Relief Health Center Central Department Manager 818-776-1171 Fax 818-776-1191 --.-----··- ,. [. •!,· t; ... - EXHIBIT . ------.. ........................ ~~.-----------------------------._ .. ~------c-----------~ ...... -.--""--------~ 'C. . . .~--~~~""--. .~~~--~--:~ ·~~~~~ ... . ~~$'+~.:\:,:.;;~;:~!¥r-~~~- 4!2:112011 NO l 412112011 YES I 4/2112011 NO NO 121!2Q11 I 412112011- NO I FOLLOW UP PRATI..EY US, LT SHOULDER SHOULDER FOLLOW UP VITAL WRAP(NO BODYP) MTAL WAAP WRIST FOLLOW UP PRATLEY ViTAl WAAP(NO BODYPl f<:'S, US, 8 WRIST, 8 VITAL WRAP US, KNEE LTKNEE VrrAL WRAP KNEE 412112011 NO 412112011 NO ~ I 412112011 liO 412"1/2011 NO ~i2011 NO [41.,12011 .NO .;;;2tl2G'l1 NO I BWRlST FOLLOW UP FOLLOW UP FOLLOWUF PRATI..EY )• ,,1\.~llr' ~<: UIE.UE X X 2X FOR 6'1VKS 2XFOR6WKS 2XFOR6WKS 2XFOR6WKS B SHOULDERM'RIST/K NEE X VITAL WRAP US, KNEE LT WRJST, RT KNEE VITAL WRAP KNEE VITAL WRAP l.JS 2XFOR6WKS 2XFOR6WKS 2XFOR6WKS 2XFOR6WKS UJE,UE X 2XFQR6WKS 2XFOR6WKS IJS VrTAL WRAP KNEE 2XFOR6WKS 2XFOR6WKS X 2XFOR6WKS 2XFOR6WKS SELBOWS . NO 412'1J2!>t1 FOLLOW UP 2XFQR6WKS 2XFOR6WKS RTSHOULDER . ~112011 NO 412112011 .NO ---= 4.121/2011 NO -4'21/2011 412112011 NO NO -.12011 NO 4121-12011 NO 4J21l2011 NO 1412112011 NO FOLLOW UP FQLLOWUF fou-owUF FOLLOW UP FOLLOW UP X VITALWRAF X tilE ;< FOLLOW UP 2XFOR6WKS 2XFOR6WKS LIE X 2XFOR6WKS 2XFOR6WKS UiEUE X FOLLOW UP RO !FOLLOW uP NO 2XFOR6WKS 2XFOR6WKS RTWRIST 2XFOR6WKS 2XFOR6WKS 412112011 412112011 2XFORsWKS 2XFOR6WKS FOLLOW UP FOLLOW UP 412112011 NO BWRIST-. B SHOULDERS 2XFQR6WKS 2XFOR6WKS NO NO UIE,UE 2XFOR6WKS 2XFOR6WKS LTWRIST FOLLOW UP [41211:2011 412'1/2011 2XFOR6WKS 2XFOR6WKS iRT SHOULOER MRA CIS FOLLOWUF ?< LTELBOW X VITAlWRAF 2XFOR6WKS 2XFOR6WKS lx 2XFOR6WKS 2XFOR6WKS X FOLLOW UP FOLLOW UP X 2XFOR6WKS 2XFOR6WKS 2XFOR6WKS 2XFOR6WKS X 2XFOR6WKS 2X FORSWKS _1 :: ':': ·r . CIS, LTSHOULDER,LT LTWRtsT '' " \'*-' "?:'i!!Tf:TT 2XFORSWKS 2XFOR6WKS VITAL WRAP US, KNEE FOOT FOLlOW UP FOLLOW UP '.fl·'if'" & 2XFOR6WKS 2XFOR6WKS FOLLOW UP I I -<:r,. ':·51:··:---~,;~<- X I - 5!26J2011 NO 5/26/2011 NO 5/26/2011 NO 5126/2011 NO 5/2612011 NO 5/2612011 NO 512612011 NO 1•- 5126/2011 YES 5/26/2011 NO 5/26/2011 NO 512612011 YES 5/26/2011 YES 5!26J2011 NO 5!26i2D11 YES 5126/2011 YES 5!2S/2011 NO us 2XFOR6WKS 2XFOR6WKS 8 SHOULDERS/ELBOW U/E, UE SUS,CIS LTWRIST DME,BRACE LT WRIST 2XFOR6Wf FOR 4 WKS 6/312011 6/312011 613/2011 6!9/2011 NO NO NO NO FOLLOW UP FOLLOW UP FOLLOW UP FOLLOW UP 61912011 NO FOLLOW UP 619/2011 YES PRATLEY . 6!9/2011 NO FOLLOW UP 61912011 61912011 61912011 YES YES NO PRATLEY PRATLEY FOLLOW UP 6/912011 YES PRATLEY E:=:7--eso-f.Po;;:RA;s;TL;o:EY~ PRATLEY PRATLEY ~3=X~F~O~R~4~WK==s~-b---------------+---------+-------+.~~Nc=lTAL I3X FOR 4 WKS I WKS 4 WKS lsXFOR4WKS FOLLOW UP lxtNITAL IXINIT!ii 61312011 6}312011 XUS MED BRACE (x 8 SHOULDERS LTKNEE FOLLOW UP 61312011 r FOR 6WKS 2X FOR 6WKS XLT KNEE MEO BRACE XUS MED BRACE XUS LRG BRACE NO 61312011 - E_ IFOLLOWUP 3X FOB_4 WKS 3X FOR 4 WKS 3XFOR4 WKS 3XFOR4WKS 3X FOR 4 WKS 3XFOR4WKS 3XFOR4WKS 3X FOR 4 WKS 3X FOR 4 WKS 3XFOR4WKS 3X FOR 4 WKS j3X FOR 4 WKS XINITIA! ~SPINE XINITAL ~SPINE XlNITAL iXINITAL IXJNITAL iXINITAL iXlNITAL ~SPINE CARM IX--I - !-\ t ~IN!TAt I !XINIT~. X1NITIAL ICJS, US, RT SHDL oUS LRG CIS, US, 8 SHOULDEIBRACE US MED jBRACE KNEE MEO ICJS, US, B SHOULDEIXBRACE US XXI 3XFDR4WKS 3XFOR4WKS 3XFOR4WKS ~NITIAL IXINITAL K:.INITAL 3XFOR4WKS 3XFOR4WKS J3XFOR4WKS 3XFDR4WKS 3XFOR4WKS 3XFOR4WKS jXlNITIAL XINITfA.L XINrTlAL 51241201 M41201 51124201 41281201 51241201 311 71201 311 3"!201 51241201 41128291 4128:1201 3117301 5124! 20 1 5f24f2l31 1 6171201 1 51242311 1 617201 1 311 712011 6172291 1 51241201 1 4284201 1 3f1?f2011 6?12011 33'171?2011 $171201 1 3.11 71201 1 311 71201 1 41281201 1 4231201 1 5124:2111 1 53241201 1 51241201 1 51241201 1 51241201 1 5124201 1 51241201 1 1 657201 1 51241201 1?5/241?201 1 1-51242011 5124:1201 5.1241201 11-63120? 617201 1 61712011 11-53420? 1 161241201 1 51241201 1 1-6UIZD1 1 5124301 1 5241281 1 PTP FTP PTP PTP PTP PTP PTP PTP PTP Shoulder Rt- Shauider RT. Hand Lt. Wrist?M Rt Wrist-Rt Rt- Shoulder Rt. Wrist -RL R2. shoalder not need not order not order not order not doesn't need not order not ortier not order Brace US Brace US race US . Sheuider UIE Bil.- Shoulder Rt. Foot FeothlS Lt. Foot Lt. Shoulder? Elbow- Lt. Knee Rt Knee Rt Hand R1. Shoulder Knee-US- Shoutder Rt. Shoulder Li's-Lt. Wrist Pt. refused Bil- Bil- Wrist - Rt. Wrist Pt refused Shoulder Foot SIS-US 1···. · ... ~ I. k·: H-1-...J__L_I ·'II· . " I···•· •. I H-LLl..J·.i , ~ I .••..,.• ' I . , ,. .···'. · .' . • . ••• ·.' mwaamma? us LT KN EE RT HANS a 33 SHOULDER US - RT MRI req.notin DFR -DFRonly req. ashau!de r MRI req on _Df'!<.~­ 'Jt has MRI Teqon DFR --+-· -i- !!!fl1f'l'br £i ry w:1""W""'V~ "T'tr ~i!l11!itm·--·-m.·,;,~-Q'M·-----~~'"'"'""""------ _f~Jilfu\j_dlJ¥MiJ:riii¥~ :==F31ffii_ iWJJJMi~lllW"'fftiLWiiibiil\t4W - ;:;:m\1,;;;:; DFFfhis rep for ·MRI -MRire Mon, Jan 17, 2011 at 8:11 PM Reply-To: bahardc@gmail.com To: Fermin email , Providence email , Martha email , Dennise prhc email , Johana email Hi Everyone Please see the list of MPN our providers belong to and our locations are listed with them. All providers we use "Boyer, Eoh,Rivas,Sotelo,Montes" are either members under both individual/group or have been approved and we are waiting for MPN sites to be updated. To avoid problems with attorneys best Is to designate the 4600 letter to" Pain Relief Health Centre and its locations". In that case if there's MPN issue with one provider ,the patient can be switched to another provider within the MPN in our group. Also usually 95% of pts can be treated outside the MPN and attorneys appeal if insurance denies. We also appeal in our office and treat on lien , if pt is on disability we apply for state disability for them. So we should be able to retain 99% of pts , only big MPN s we don't cover at this time are Zenith and AAARLA. Pain Relief Health Centre Locations belong to all other MPNs. Please see our MPN list below. Please contact me If any questions. 8053028990 Thanks Sent via BlackBerry from T-Mobile From: Dr D Date: Mon, 17 Jan 2011 17:46:59 -0800 To: bahar danesh gharib ReplyTo: bahardc@gmail.com Subject: ·---··--····-·--·---· illlh Copy of Copy of MPN LIST PAIN RELIEF HEALTH CENTER UPDATED 6-16-10 new[1].xls '\1141 198K bahardc@gmail.com Mon, Jan 17,2011 at 8:14PM Reply-To: bahardc@gmail.com To: Johana email , Dennise prhc email , Martha email ,, ' ' Martha /Dennise I don't wanna see we lost anymore pts over MPN. Use the list below and if you are not sure which provider application is final just have them designate "Pain Relief Health Centre " as PTP and if any problems we'll switch within our group. Thanks Sent via BlackBerry from T-Mobile From: bahardc@gmail.com Date: Tue, 1B Jan 2011 04:11:44 +0000 To: Fermin email; Providence emaii; Martha emall; Dennise prhc email; Johana email ReplyTo: bahardc@gmail.com Subject: Fw: MPN list for PRHC (Quoted text hidden] -------·--·---illlft Copy of Copy of MPN LIST PAIN RELIEF HEALTH CENTER UPDATED 6·15·10 new[1].xls ~ 198K . EXHIBIT Intake ih BB 1 message bahardc@gmall.com Man, Jan 24, 2011 at 9:45AM Reply-To: bahardc@gmail.com To: Dennise prhc email , Johana email , Sidney Cobos email Hi Dennise -Please remember in all our locations PTP s are our chiros "Dr rivas preferably" . He covers most mpn S· If any denials later we can switch. And co - treat. -If Attys request MD be PTP explain to them chiros are there FT and in most MPN s so they'll become PTP and co-treat pts with• ortho /neuro and we'll incorporale specialities finding/Impairment into our reports- -If they still insist on MD PTP , please. make sure pts are scheduled for Chiro at the same time for 2ndary consult so we can still track the treatment. -Also please make sure Burbank manager is aware you are ONLY in charge of scheduling new pts for our clinics "and speciality" which are Reseda , Oxnard ,WM, LB ... and during extra time u'll be helping our schedulers with scheduling testing/speciality appointments for MPN SO Ca Drs/testing s in our locations. -Please Share new pt log with me and Martha please. Thanks Sent via BlackBerry from T-Mobile EXHIBIT Vital wrap 1 message bahardc@gmall.com Frl, Apr 29,2011 at 11:28 AM Reply•To: bahardc@gmail.com To: Johana email , Belinda Felix email , Dennise prhc email , Rosa email Torres , RX email , Yanira email Central rep staff All clinics all dr pratly pts they've ordered Vital. And Prime never processed. Pis make sure u send all those RX to post -surgical to process Vital wrap Only and keep track of all Pratly clinics and our PTP clinics for Vital pis. Johana/Rosa pis create a Vital Log and Add them and Rosa pis supervise to make sure Its all processed. Thanks Sent via BlackBerry from T-Mobile EXHIBIT. 0 . https://mail.google.com/ml li=2&ik=48e25533e3&view=pt&search'' ,x&th= 12da9... Page I of I Intake staff needs to work on newer pts "less than 24 visits " that stopped coming 1 message bahardc@gmail.com Frl, Jan 21, 2011 at 8:17AM Reply-To: bahardc@gmall.com To: Johana email , Dennlse prhc email , Martha email HI Martha/Dennis -As you know one of ur main job duties is the stop coming in all clinics "now specially Re and Bkf ,martha u can work on these 2clinics " and train Dennis to work on the rest. Lb is good no need to call. -The way u need to do this is u go thru pr2 log in all offices and see what pts stop treating for over 2 weeks and u call pts , call attys and mail pts "a standard letter that we have -mildred can give u" and u keep in ur pending list ,FU in 2 wks "put a reminder 4 ur self" if pts not back u give me and cc johana on the list of SC per ally. "Make notes in ur log " ·If pts switched clinic ask the reason or settled or changed atty make notes. -1 want to see how many pts u can actually bring back In 3 wks so keep ur list and ur notes. "But remember Notes R useless for me - I want the pts back " ·And please concentrate in the newer pts PRIORITY "new pts we had last 3-4 month with less than 24 chiro visits are Priority " Hi Johana Please give Martha/Dennis a copy of stop coming Protocol. -Have Dennis finish her schedule before she starts working on stop coming. -U might need to share pr2 log /sc log with dennis and martha so they can check. -All pts over 6 month SC and p&s have them update in google doc and share with Shannon to start final negotiation. Thanks Sent via BlackBerry from T-Mobile https://mail.google.comimai ll?ui=2&ik=48e25 533 e3&view=pt&search=inbox&th= 12da95d... 2/1/20 12 EXHIBIT I I .._... \J 1-' ' SCUQID ,_. coPHEALTH INSURANCE CLAIM FORM •~ BERKSHIRE HATHAWAY PO !lOX 88).716 SAN FRANCISCO CA 94~88 M'f'OOVt(I!N ,..~~ Ul'llf(l!W OtAI~ OOW\1'1'1!1: .Qfilj~ ~~~~~~~~~~~~~~~ 3312 WW 5 EQX gm FWCIQCQ CA 941388 maximum mm mm ax mmu uwam cm EB mm 2mm am ?ak} slugs-m mum {Gumamsmt was mm . i ammo . mt .. . MM: [jam mm am: a Mk macaw I {ZS-arm Igg- mm up. ?r'Es- 1K) 0! Hammer mm warms Wanna l3 3: Wk ON 1931.3 FLELH mama 1 tr. 1?0 T0 11 3.399 2'3 3f? 31. i 43mg?. .. 11 B??l "II-ain'2.051011 ?5 i ?13 .E WE p.53143131-6 9 Mindwm ?335 vane Muga- 811% (Jags. GA 91403 i it. and mm: on Wu ?kiln-ma?a at pm my 0 01324 04 t} 5 155?; $133 ST CA $3an a 3mm: manna: {141? Miami mewmr 90 go): 831;?? - 32m ma mm Hymn: mummies CLAIM mm: WED MW EUR EWME ?Ck I 83 $518 om m??mwm mm ammu?m or 9W E?vm Elm; ?lmmadam?: - m. mambmm-t mm mum on mm Mi 95!" 3-1- mm?mnm??Yang. .Av??i?wmm 5,15" m9 ms 23? 1:1. 90 53 gig-'1 MG magma? I NM 07 M, 1:1. 9%{90853 . . . i gt: 3 ma?a-3A; NPI catalog 903-253 gig .gz?ag?mlh mammal; $09.53 35 .29 man. 1% 31 16 Mindmm Pay I mauMnM-mw? 155$ 5TH $51. I I yx JOHN '14 TERRENCE QXNEXRD CA 93039 shaman a&/Qs/ . a 311W ?aw-armed: CW 1.1!2011. 1 llii:RIell!l. Any person breaching this confidence oould become responsible for the patient's subsequent reactions. Ple880 note mat the historl!!at Information contained horeln Is based 011 the pallent'• soW.feport and not takon from any collateral sources, suoh as medk:al records or third parly otat(!monts. Ms. Is suffering penman$nt ps)';' " '• . I;!!!!TQRY QF IHJYRV At\ 6!ibbT!!p 6::( It!§ l!blllit!T! Ms. ~PQI1& no prior Worlllnaatlon c!alma. !!he reperta no prevtou• psyehia!rie treatment. Sh& wa• In good physical and mental health When sho began employment with a secretary from 2006 to February 9, 2010, When she quit. Ms. she workeYlllng languege. She !elt as If ohe was performing the wort< of two or three peopte. Sho eamplalnod often about tho Uf11Ullt t~<~almont, but was !old, ·rr you don't like n, there's the door. Ms. -reports thai her manager was prejudk:ed against Latino people and dlscrlminaten. She also l>egan to expertence headaches, low ~nergy, dec!llased appet~e. and a loss of Interest In her usual aellvltltG. Sha began ro Isolate herself socially and her feelings of helplessness and hOonlessntu lncraasod. She began to become afraid due to har mental condition and her Jack ornnanclal resources needed to help support her family. She also notes that as her mentllt condition continued to deteriorate, she began to exfllldenca physiCll1i problems tMt she opine& Ire caused by the streas!ut working environmenL These symptom$ included gastrointestinal problems, Including aeld stomach and slomaot1 aches. Sha took over·lhe-counter medleatlon to tl'!lal those aymptlllllll, but reports that the problems perslat. She became lncreaaingly worried about her future and tha pesslbluty that hill' personal 11!1atlonshlpa would continue to detorlon~to, She roperts lhat ~ue to har deteriorating mental condition, her aHorney referred five !set, two Inches tall, welghe 1<1 worry •• ..,II. In rating her p~l condition on a ten-point scale, one being very bed and ten being very good, M&. -'eported that her psychofoljleal condition prior to her workplace Injury wu at a level of nloo, whereas her present psychological oondHion Is at a level of one. RI!CI!NT QC(lUPATIQN:AL H!SIn. A& to her mental health history, Ms. -donled &ver seeing a psychiatrist, psychologist or any other member of the mental health community prior to her current workplace problema. 6 BRUC RG~Qivudt 04/11/2011 El!MILY H!!!IQfl)': Mt.-was ralaed by both parents and with her siblings In Mexico and llle U.S., She hat o lllbllngs. Sho Is currently rnamed but Mports that her relaUonshlp Is curtently lllralned. She has one son and one daughler, bOth reportedly In good health. DIYELQPMEIQ'I.L tllltQEIX: Ma. - t a t e d that she had a happy childhOOd and to tile best of her knowledge, th<> reached all of the usual developmental milestones and had tho common childhood dlseases. such as chicken PO<, ooids and lnnuenu. She did not report enoy or J'llnnlng away. She o«ended twelve years of school In Mexico and fho u.s. I!OC!l!b f:!!S!Qfl)': Ms. - t a t e d that ahe has a few clos• frlendJ •na spends most of her Ume with her family of origin. P§YCHO§iiJWeb !l!§TQEIX; .1 l I Aa to her peychosexual history, M s . - reported that her ·parent~ had a consorvatlv& attftude toward se<, whit& ehe has malnl$1ned a poanlve attitude toward ·~x. However, alnoo euatl;llnlng her InjUries aJre sometimes experience& a deoneaae In her sexual I'on arrested and .hao never spent time In any prison. She has oover llted for bankruptcy. 7 l u "";::;: ... ,....1- ... ""' "'"' t;) PERI!ON(ll, I;IAQI:J:§: 1\\a. ~pOlled that she does not smoke cigarettes. She annilll no ooffee or al®hol, She Is not an alcoholic has never had any lege! problerns related to Intoxication. She has neller been .a~miHed to a detoxlflcaUon unit or Mspltal for alcohol abuse. MENIAL !i:J:ATU§ ~ISAM!NATION: Ms. - w a s cooparatlve throughout the Interview. She was oriented to time, place, parson and sHuauon. Sha moved as lhougl1 She were In pain. Her general boefy movements were marked by dlse<>mfort, decreased aetlvlty and repetitive actions. NO Indications of hyperaetlvity or psychomotor retardation wer~t noted. Her facial expression appeared WOifled and flat. Her quality or apaeoh was slOWed. Her mood and affect were doprnsS<~d, sad, withdrawn, and flat. Her thougl1t content was remarkable far somatic complaints and Ideas ofMpalesaness. There was no. evlrlence of flight of ldeu obsenlons, or ruminations. She de11Jed any current suicidal Ideation. Her lntellemual functioning appaarnd to be In the average range. Sh• exhlbHed poor recant memory and oone«n!ratlon deficits. Them wornststlng or 5!17 affinnatlve statements, Ia the moll! widely uaad and tho moot thoroughly researched of an peychologloat assessment Jnstrumoms. It Includes ellnloal aealea that are used to assess degreh Md lypss of psychopathOlogy, and valldl!y aeale&that lndleate the patienrs approach and aflkodo towards the lest. The MMPI·2 profllo Is not a substitute for a comprehensive porilonsllty asseasmen~ but It ean be useful In ldontllylng 11$pacls of pareonallty and emotional functioning that may be of clinical aiQnlfican()Gl, Th~ computer-generated profile was scored by Celdwell Report$ and a compuleri)tnomted lnterprotatlon of tht MMPI·2 wa& created wUh eoftwarn from Paychologlcal Allooeamer>t Rttourooa. I j j ! ... u -.., ,_. .· ,_. "....... . ro Il l t i 'l l 1 lI l' l I "'"' ill SCOR!!$: This MMPP1·2 Is <>f limited validity slnoe the VaUdily S<:alet fall out of the normaliVll ranges. HoWwas to dillcard as Invalid any prolllo with an olevaUon of 65 or gr•ater. This oppro~~<:h 1!1 now viewed aa somowhat simplistic and overly conservative l:>acauoe ill'llaults ,In tho ""elusion of many valid proflloa (Newmark, 1966). Profile validity Is a oontralcollllldoratlon In tM lllletprelatlon of Latlno/Uifnl MMPUMMPI·2 profllllt>. With regard to L Seal• 1001'. ., numerou$ studlea with l.allnOI/UIInn have foul'ld a ton<:illnQy for these proliluto ,..noct an effort toward positive seff·preaentatlon &l!prll8aed In L SQlll& scores that a,.. oflen higher than those of non-Lallnott.allna White subjects. Tnis tel'ldenoy toward overly pcaiUve seff·f'l'llSentatlon has been llnkfld to Latinolt.atlna soctooultural values assootated with 11001a1 aQlluse thero are high $00l'ell on the Validity SQl!IU, U1e MMP1·2 r...wUo ...., invaUd. If tho pronlelo oonlllltent With otllqr dota,ll may bJl»: She !<1 directly attributed to her report of a streu Injury. THE PAIN PATIIiNT PROFILii • 3 (PPP-3) : This tmls dealgned to identity patients who &!'OJ exparlooelng depression, anxiety, and uomatlullon, auao!lfated with primary experiences ofpsln. Research haa $hC>W1'1 that pain patients soore slgn!llcanfly higher than l\Qn·psln IndiVIdual& on an three scales of this test. The scol'll& on this test oon be compared to the avensge soores of pain patients and to non·psin lndMduals. This t~llt hat o mean of 50 and a standard deviation of10 and rate• Below Averege, Averege and Above Average. At. compared to Initial t e a two ar three l of the scales, Pl!presslon and Anxiety were elevated Indicating that Ms. Is experiern:lng higher levels of anxiety and depression u ro!lllH of her physical condition when compared to a population of thOse also suffertng from chronto ps!n. Stwla also very concerned about hor physical mlll>lllng poaelbly to tho point that her level of tunouonlno could be advorsely alfeotod. THE SYMPTOM CIIECKLIIIT·90·R(SCL·90·RI: Thla tout meaaiJO!s nine prlmacy symptoma: soma"~atlon, obseulvo-oompulslve, 10 ... u ....... ~·· ....!"+ .."' ~ l I l l \ l I ! l il'lterperaonalstn$1tlvlly, depret~slon. anxiety, hoaUIIty, phl:lblo anxiety, paranoid ld•aUon. and psyohotlclsm. In addition. !hera Is a Global Severity Index wh1oh illlba belli single lndlcalllr of the current level of eevorny of the disonlor, by combining Information concerrwng tho number of $ymptoma ,.ported, with U1e Intensity of the perceived distro$.11, Tho Pos!Hve Symptom Distress Index runotlons as a measUfll of rauponst style by lndloaUng whether tho patient was exaggerating or mlnlmi%1ng $ymptomatio dlalre$8. The PosHlve Symptom Total 11 a reflecllon of the number of aymptoms endoraod by the potlont.. This teet h.. a mean of 50 and a standard dovlatlon ol10. Any T·l«lore above 60 lo considered ollnloally slgnlfloanL Ao with lnHlat telling, tho following dimensions were olgnlf!Ctlnlly elevated: ll brain pathology, As with lnKiat !eating, M s . _ . •corea places her wfthln mildly Impaired ranges. OSM-IV·R DtAGNO$tS Axle 1: (311.00) 011Jl111Sslve Disorder, NOS (309.24) Adjustment Disorder With Anxiety (V62.2) Oooupational Problems Axis II: (V71.09) No dlagnoals. Axl& Ill: Pllyslcal pain, hOadachG& and fatlgoo. II Axis IV: Psychosocial SJreoso111' 1. Pain and Physloel Oleablllly 2. Financial OlffiQultlos 3. Soclalloolation Axis y, Global Assusmont ot Funotlontng: 64 RA TIONA~ II FOR OIAGNOSIIS experiencing significant depression as Ia oommon In the preponderance .of a industrial Injuries. Aooording to tho AOOM (Academy 01 Organizational and f's~~~~~~ Msotin9 Archives. 10103/2002), 'The psyohlatrlc cllnlolan treating Injured wotkors aware of oo~aln features common lo inj~nd workere. Mild to Severe Major Qapreeslon is present In most, If not all of thOsa retl111ed for psy.chlldrlc evaluation. The Injured worker In thl& referral pojllllatlon typically develops ma)Of depressive aymptoms betwoen eight and fou~en monlhs after the dille of the industrlellnjury. This depression rosult111Tom a mulllplio~y of causes lnciJidfng: 1. Loss of role alalutl, both In the family ana In the oommuntty: 2. LoS$ of seH-esteem based on the lnoroaslngly appsrenl disparity batwoan the damaged real seff and 1he lnlemallzod fJI'O"InJUIV n~ representation, The WOrker who Is already lacking In self-o8leem, or .roo I& functioning on a borderline level ptlor to the Injury Is palticularty' wlnemble to using. and PS expsrlenoling r!lgnlflcant anxiety, but not to the degree that would ooll ry~:~~Zn\n~~= Ther•lore, 1have aeoounted lor thtlu symptoms by diagnosing A' DillordQrWlthArudety. This d!Jlgnosls Ia appropriate when ltll'i following cliterla are pre&ent: 1, The develcpment of emotional or behavioral symptoms In resporn; a to an Identifiable stressor(&) oeouning within three monUis of the onset Olthutressor(s). 2. Theoo symptoms or behaviors are Clinically significant es evidenced by either Of the following: a) Marked dlalreil$ that Is In exceas of what would be expscted from exposure to the stressor(s), . b) Slgnl!lcant Impairment In social or ooo~patlonal functioning. 3. The stress.,.. tided diaturbanoe does not meet the crliena for another sPSclflo Axis I disorder and IS not merely an exaoerbatlon of a preexisting Axis I or Axis II disorder. 4. The symptoms do not represent bareavoment. 5. Once the streuor (or Its oonsequenct~~~) hao terminated, the symplo1116 do not pel$lstfor moff apportionment Is made 100 percent to industrial faclors. It waa solely the olross lf11urtu lhat Ms. -ustalned durtng the eoul'!le and •oope ot her employment, as welt as the reooKant chronic stress and llmllaUona thai ceuead her to beoome peyehologleally disabled on an Industrial basis. Pftl!DOMINANCI! As to too Issue Of predominance, the reported stress lnju~es Incurred lnloo workplace were the predominant cause of M s . - & current peyohologlool ulsablllty. The propendera11<>1 of the "&XIetlng paychologlcal Impairment. M s . - a s no hlatocy of neklng mental health counseling for pet\lonal reason.. She denied any history of depression, MJnsgolng Is provided pursuant to WQII!i! Rule o! Pfl!QII!III pnd Fro®lJY!ll 101loe. I declare under penalty of pe~ury that the !nfom1atlon eontlllned In this report and Ita attachments, II any, Is tr\lt and correct to the btl$! of my knowledge and belief, except "" to the lofol1l!lltkln W11ioh I have lndloated that I have 11!1lI CaiWomla Labor Code Section 139.3 with regard lo the evaluation of this paUent or preparetlon ol !his report. Signed !hie 6'' day or Aprtl2011, at Loe Angeles county John r. Terrence, .PoyO, Piii:),QM's PSY 17840; GIME 997956 18 WORK FUNCnON IMPAIRMI!NT fORM OliGRI!Ii! OF OISAIIILITY Data In support Qf the asse..monlof pl)lwlng, lntermlll ablllty 1o pelform jobo requiring pre<:i•• attainment of aet limits, standards). Level of Impairment: Vary Slight 19 5. !lblll\y to l'lllale to other people beyond giving and reoolvlnQ inotruotlona: (The ab!Oty to get etong with co·worl\elll or peers; the ebilily to perform work actlvRtn l'l!qutrtng negotiating with, explaining or penouadlng; the .onay to l'l!opond approprlalel)' to evaluation or ootiolsm). · Lttvel of Impairment: Vort Slight ' 6. The abill\yto lnflu..noe peopto: (The ability to convinoe or direct others; the ability to unden~tand the meaning ol words and to use tMm appropriately and effeetlvely; U1e abiil\y to Interact appropriately w!Rh people). Level of lmp•lnnont: Slight 7. !lbiUty to make generalluliona, evaluations or ~OI$lona without immediate supervision: (The ablll\y to recogniZe potential hi!UrdS and follow appropriate preosutlono; tho ablllty to understand and remember delailed lnstruottono; the ability to mal«< Independent deolslont or judgmanl& basad on approp~llle Information; the abtnty to set realistic goals or make plans Independent of others). Ltvtl of Impairment: SU!Ihllo alight 10 m~l'lhl 8. Ablllty to &coopt and carry out reaponslbiiHy tor diraction, control and planning: (Tho oblllty to sot ntollo~ogoolo or moke plonllnt.:tepenRI'!.AUGUST 1, 19117, GUIDI'!LINEII Descnptton of OisabiiUy: Minimal: 0% Annoyance, no handicap In performing aollvlty praolpitallng the problem, Very alight: 10% Mk:lway between minimal and slight. Slight: 20% Tolerated, •ome handicap In perfgrmlng aollvity precipitating the problam. Mo~rate: 50% Tolerated, markad handicap In !he activity preclphallng the problem. Severe: 65% l'rect~s tile aetivity preclpilatlng the problem, Pronounc$d; 100% Unemptoyeblo; oannot perform work acthiiUes. , Overall Disability: Vexy Slight 20 j .. REFERENCE$ oo "'"'g) American Poyohlatrlo At&oCiltlon. (2~100),Jl d!sordt!§.I!IXI !J'Ilslon (4" ed.). WMhington, Andorsaon, Gunnar & Coochlarella, Undo. (2000) AMA gukj.. 19 the eyaluaii90 Q{ ogrmanent Impalement 5" gd. Washington D.C.: AMA Pre.. ADOP (Academy or Drganlzat!onal and Occupational Psychiatry). (10103/2002) Meellng Arcbtyu Butcher, James. (Ed.). (2000). M.Mel:?: A OO!O!U!onees QUI~§. Washington DC: Amertcan Psychological Aosoc!allon. Caldwell, 2001, What do the MMPI scakls fundamenlally measure? Some hypotheses. Journal al Personal/ly A...®ment, 76 (1), H1. · Gatchell, R.J & Turk, D.C. (Eds.). (1999) London: Gu!~ord Press, Pavphosoclal factors jn 11111n. New York & Gatchell, R.J & Turk, D.C. (Eds.). (1900). Psychologl@l approaches lo P§IO management. New York & London: Guilford Preas. Galfney, Kenneth. (May, 1997). Understanding the Injured workar. PsychOlogy's rote Ill worner's camp. IN: The Au!horiN. Colorado Compen1at1oo lnsurarwe Authority lndUllttia! Medical Council {3"' Ed). (2001), j>llY§ieiM's QYI!I!! IQ.JPOdkl~l QraQ!Ige In tiJq Qilllpmla wort~m· ~Q!Jlll!lpsaUQn svtt~m. San Francisco: Cal[omla Oivlslon of Workers' Compcnaallon . Keefe, P.J.. E!eauprtt, P.M., & Gil. K. (1&00) Group therapy lor patients wilh chronic pain. IN IU Ga!chell & D.C. Turk (Eds.), ~!llglcal Aggrgpoheoto Pglp Management. (pp, 2§9.282). Leahy, Robllrt. {1Jl96). Cgoni!IXlJ!heraev; llaslg lll!O!IIRI•uo~ o!l!Jllo.t!ons. New Jereey; Jason Aaronson Inc. Price, D., Riley, J.L., Wedo, J.e. (2001~ Paychophyllcal approaches to moa•urement of the dimensions and stages of pain. IN: f'!andbook Q.{J;lllln asus§rotnU2" ed.). Malzaok & Turk (Eds.) Now York: Guilford Preas. pp.$3-76. Sullivan, Mark D: (2001). Aoaet&ment ofpayohiatric dl&ord&ra. IN: H!!O!!Mo~ O[JI!IIO 81'$0!!j!fU~Q!. (2"' !lid.). MQ!aaok & Tu11l (!ilda.) New York: Guilford Prees.pp.275·291. 21 83 9818 "Eif?i?f 5? 3% WW a; 5mg mama: mm mm: ?awiwd: ?dfili?okl ?km: .m?wm mar I i is? A gmg'?; mm m! 22 ?n?gi a?igo.; . I 5159351541:5 3 4:2: smug 3.wulmm {Irma} mhu?mluOr??$lli r'ulwl't: 2'5 a n: 11: ril:l . 3: i: rsn?gp m: ?HamIf. nTam i gallium" inaml?m?; am?? Entru- [Annunciationme ur- ?113! can} no; f?magr..u4e'u- 'lh- IRII In ?_Ir?j ?a $111; "gt lit; J1: ?nk? I I .l u? ?rip: ta 4 {at?ml?nugsvlt?w?; at? ?:I134g4a'l 1" in; 4.535% ?5 a - - 1? Muir's 1g Him grim gin 1:1 - . 3 a 5 a;?gs! 1 in? Lh-mmgl JOHN T. TERRENCE, PsyD, PhD CLINICAL PSYCHOLOGIST (PSY 17840) QUALIFIED MEDICAL !!VALUATOR (QMI! 99711&6) 3680 Wllahlre Blvd., LA 90010 BILLING STATEMENT To Whom It May Concern, Alt-, PhD DATl!$ OF SERVICili: Paycholhurapy Seulons: 3/4110, 3/11/10, 3118110,4/1110,418110, 4/tll/10, 4/2.2/10,4/29/10,5/20/10, 5127/10,6/3/10,6/10/10,6/17/10,6/23/10, 7/1/10,7/8/10, 7116110, 7129/10., 8/5/10, 8/12110, S/16/10, 9/30/10, 10114/10, 10/26/10, 11/4/10, 12/16/10, 1/13111,1/20/11,1/27/11,2110111,2124111. TOTAL llUii UPON RECEIPT WC llllllng Code 90853 . TAX ID: 2NI501767 (31telllont@ $71.86 •aqhl: z.a&Z,§§ PLEASE REMIT PAYMENT TO: MINDWAVES PSYCHOLOGICAL SERVICES, Inc. 4336 Van Nuys Blvd.,# 184 Shennan Oaks, CA 91403 EXHIBIT 0 CALIFORNIA liORXSRS• COMPSNSATlON QlX.L UVXDII •• • • llliPMANA'l'ION EOR ·-~!ll!l:fo!mlftk*-1- ,jli>'SHIRE,BLvtl 100 LOS l\NO~LES, CA 90010 ~·ih•204563!69·0002 ' ,,: '-itOHN'- T, "''JAA'ENC$t 9Sttli t"}LO. '4335' V!IN Nb¥S B[,V)), · ua• ~sHIIRMAN SrYt::la 0.1\l(S, CA 91402 n.at.eas05~20<2(Jl0 R•ceive4112-12~20l1 ~6VitW8df01~13w2012 To OS .. 20~20ll DEPRESSIVS DISORDER OTH ICU9t"311 309,24 VG2,2 AD@ST l)fSORllER W/l\NXIETY OTM OCCUPATION CIRCUMSTANCES , os ..-:;m .. ao1.o 96115 05-;!0w20l0 96101) p,s;.20M·2.010 9610(1 os~20~2010 05·20-~0iO 961.00 gnoo '59: .;;. 0$•20·2010 $.19080 SPECIAL REPORTS CRC 1tl1 :MLCB OSC20•20U 9~l04·ASSESSMENT APHASIA 05 ...20 .. 2011 9610!5ASSBSSM'RNT 1\I?HASIA OS·~0-2011 0!>·20.,2011 9Gl15NEUROBI!:W\VIORAL · 0$.. 20~2011 ,9-61-15 N~UROEIBHJ\VlOFU\W .,. ij5-?0~2gll 26109T5STINQ ~ "~~~·-· . ·w~~--·~· .. -·-·-·~- ... ~ ..... ... w • ... -.~-- "' 300.00 2tO, 00 1 ·l 100.00 .. 1.00;00 469:.75 l ,, . 2SO iM 12 9:ti,7$,' 200.09 150.,09 .09 ·;og 313.92 ,00 .no '.on. .00 .oo ', :.133.21 99.$1 • 00 0104 0104 0104 59 1 l 1 :I.SO,i)O l.SO.OO 59 litnit~t~d to sb;_ pages t!'xrll'!t}t :by· rnu.t.UU be_tween :.the,'_P~YC!x:'. and_ t.be prtiV1.4f):t; ~et 19~L{l9 ~@~~?: .. ~-~~.... CA G&t The do~~~.,mtacion does O~?t. l!.PO/MPN iDI agreetnent the criceria for MedwLegal · · DUPP_ort the level of se:n-1-ca Crovillor o204Sii3369•0 ~0 B JOHN TltRlmNCE . . 3590 WILlSHIRE. »tvo 1:00-... LOB. ANGE~.S~ qA .9001'0. .. P•y,..oaoetrlotlfllcatlon wanervod oun panloG. 1met With lnllllll report and a~~aln on May llO, 2010 at my Loa Angel&& office located at 3560 Wilshire l!ltYd, sune 100, L.A. OA 00010 for tht• eY!lluatlon of her psyohologloal ~ondlllon. This tvaluallon was dr•wn from a ollnl0411 psyohologl041llnl•rvlew In which her ~rmnt condnJon and her pl'ltllllntlng compllllnta. W!lnt evaluated. p~ testing was .,.., admlnlstel'ltd on that dale to aulsUn tho ovllluatlon. The re!ltdts of Mo. - t o t i n g , as Willi utholntonnatlon galheretl during the faoo-to-faoo Interview, Will bt dls~slllld Wllhln the bndy of lhl$ report. The lWlminee was advtsod of the purpooe and Jnuu of this psyohoiOQICal examination. TM examinee was l'lllorred !>tied upon the olleQatloo of psychologlolllin)ury arialng out of and In tho oour•• ul employment. I personally revlowed the oelf.report quastlonnall'lt that the patient com retell and I also revl\>wed that same QWstlonnalre directly with tho path>nt. llntonnod the patient that the results olthla examination would b6 summarized In a report, whklh woukl be provided to tho Worlgl* examination, tho cal'llflllrevlew and an anolyols of collateral data, tha analyols of ptyohologloal tullng n~sults, and may hav• naee..l!atod medical and legal r&aearoh on the Workers' Compensallon tuuoslnvolvod and/or tholsaue o1 dn oontolned Mreln Is basod on the pallonh ••lf·ropo~ and Ml takan fli)m any eollaleralsouron, Juoh u medical n1eords or 1hlro party tlatemool0111 pertonnlng her job ~uuos. She reports that the pain hagan to bother her and began to 3 ,_. .... "'... ""',_.,_. .."'w "' ~ ~ "''"" I I lmJ>IIC! h!lf ability to pertl>tm her r1J9ular dulln, but that silt dtcldad to 1ly to work through h•r pain• The noond ln)uoy ooourrad on Novtmber 2009, when fheln)u"'d hor loft wrist, hand, and ft(l11, when a food chopper that wao faulty slammed Into the cuUing board. Sha fliPOrled the Injury but "'ports that her omployVOrlll times thmugh "" night, worrying aboUt hl!tr work altuatlon. lilht alao began to oxparlanet~ headaches, low enO'liY• •ppoUII4C!I dottrtoratod. As her phytlclll condition continued to ctlll•rtoratli, so alllo did hormon!MI condlllon. She began laolat• herself .oclally and her feeliOQo of helpfo11noss and hopeleoanoulnCI'taood. At that pain~ ihl!t ratalnod tho aervloat of an atlomey to ensure that IW r!Qht& wore protectad. As a consoquenu of her lndustrlally..austalnod phy•lcal Jnjurlto, .and the rosultant chronic pain and limitations, Ms-..vetopad omo11onal complloauons, Which at$ dlscu11ed 4d length below. -••114 ' "'*'J\ll ] \ ' w Pe&QBIPUON OF f'ATf§Nil M t . - a 55 )'lar-old, 'Ingle LeUna-Amottean female, 11!pcrtad shO stood live feet, two loohu !all, and woiQhad approximately ~·· She appeared to be her staled ago. Htr body weight wu In l pmporllon to her holghl Ms. -preuntod as a olean and c.uuall)t ~ssad woman. She was on tim• fur IM lnlervlow and eoojl1)r~~li'le throughout tlln$. She wa•lllllable and angoy a& woll.llho reported prcblemslnlllatkl{l and molntalnln~t sleep. Shl!t beoarno !orvolfuland laoked molivotlon, She alsf tear!Uinel# and ion of Mil ·esteem. Additionally, oho reported that oh& eonUnlllil eondiUon on a ten-point $l>lllo, on• baing 'lllfY blld and ton being vllf)l good. Ms. -.ported that her poyohologicaloondiUon prior to her wol1lll llQndllion lo .at a lev•l of three. B!iQI!Nt Q9C!JPAII9NAb H!!ITOfl't: !'rlor to the cutten! employment, Ms-..porta that she worMd tor various employers and had no prior we laauas with any Qf them. lllllQI!W. tJINP Ml.iN!I\!- !!llAbTH HI!!TOBX: As to her hlstllf)l of prior hospitallzaUons, aurQertos and/or injuries, Ms-l'ltported she haa never bnn hospitalized In the past 11>r My serious lsaull$, Shlll history, Ma. - e n l a d suffeMng 110m any Cl'lr<>nlc Ulnonts oUton involved In a lawsuit She hal ntvtr l>lien arrested and has never spent time In lillY prtaon. She haa never ftltd fur banknJptey. move~ a• though She were In pain. Har general boQy movements wtl'6 malkllll by diS®mfort, do<:reullll•otlvlly ana repetflive aotlont, N<> lndloatlons of hyperactMty or psyohomotor re1llrdatloo wem notocl. Her facial exprtnlon appeared W«J''t<< and flit Hor qual«y or spe.eh was siowocl. Her mood and affect wart depl'6s!Hid, asci, withdrawn, end flat. Har lllought oontent was rtmarlrd•n.:t With tho guldollnea spociOed In the Industrial Mtdloal Com a neuropsyohologlt.allnvolvomellt mey be prastnt end If lurlhor neuropaychologloal evaluation lo appropriate. In Ms. """"· there wes no evklonoo Of aey nouropayoholog!c«llmpalrment. Her poa!Uva response& can bo lllreolly ai!Hbutod to hQr r.port of a physl<:4111njury, IIE!NDI!R GESTALT PERCli!PTUAL MOTOR FUNCTION TEST: As utilized In this Cllnlo,tht&l& 7 . w "' a rapil! serttnlng lnslrutm~nt for tho. tteleotlon of f>O'I&Iblo orvanlo brain dytfun~Uon. Nine simple dulgns are presented, end tho patient Is lnstruel•d to copy noll dt~lgn frt>m tho umplo. In thl& lnotance, !llproductlon of conllguratlonsls adequate. THE ROTTIIR SI!NTENCE COMPLETION TEST: The Ro«er Sontenoo Completion Tullo a ulf.raport, projective tutln which tho patltnlls allkad to ftrlsh, In hedhor own words, 40 lncompleto .enten- or 'stems.• The und4r1ylng hypothesis is that the patient's ani!Wers lliVial paychcloglcal conflicts, atran(lths and weaknouoa. Tho Rotter Sontonoe Completion Test responaoa sugrlflst significant ttepmulon and snxlety. WAH~ER PHYSICAL SYMPTOMS INIIENTORY1 Thlt mutul'&ll dulgnad to tllqft Information thai eugguts tho degr,.. of with physiological symptom#. Re#pon.. seor& in thlslnlltaneels 11"1 decile with regard to somatic precec.t~patlon when rated a large eompa~aon sample of psychological outpatlenta. aeons suggeS~a that the patient Is very strongly concemad wlth eemsllo symptoms and physical fllnollorling. REV 16-ITI!M VISUAl. MEMORY TEST: Tile Roy15-ltem Visual Momont Test was di!Witopsd •• a measuf!l of mllllr!Otr!ld memotY or lmplllrmtnt. It eonslsto fifteen symbols arrayed In htroe rows, which th•teat aubjeol el«!rnlnts for 10 seconds belor!l ho or aholo to reprodiJeo the oyrnbol• on a blank sheet of papor. 1111 trJidillonat quantitative a~ng method ill simply to total the numbor of oorre~ reproduced symbols. Ordlnatlly, lith• aubjeet mea lis 9 or fiiWtr of the symbolt, tilla relil&a tho poulblllly of lafllned memory problllms. on recall after having boen IIJVorlty Index which Ia the best alnglelndlcator of the currontlovel of ••vllrlty of lho dleerlltr, ~Y eomblnlng lntorrnaUon con'"'"'lng tho numbor of symptoms AlJlorled, wlth the lr~nslty of lhs perceived dlotooss. The Positive Symptom Distoou Index lunoiiOns as a mouure of response style by Indicating wholllor the patient was uaggoraUng or minimizing tymp\Qmatie distress. Tho P<>llltlvo Symptom Totallu refleelion of ths numbor of oyrnptom& endorsed by the patient.. ·rhls teal has a moan of 50 and a atandarll dovlallon of 10. Any T•SIOQI<:al fUnctioning and mtasure ~U aa spoclfto cognitive doftclts aoooclatod with organic brain pathology. Ms. - c o r e s place her wl!hlrt mildly lmpall1ld lllngoa. !NIT!A~ WQR!(Itj(i Q§M.JV·B ll!MNQSI§: Axis I: (311.00) Deprenlva Dl~~<>rdor, NOS (309.24) Adjustment Disorder With Anxiety (\1112.2) occupational Probloms Axis II: (V71.09) No diagnosis. Axis nl: Physical pain, h-ellO& and fatigue. Axis IV: Psyci1osoclal Stmsorn: L Pain and PhyBiaal Dlsabllll)r 2. FinanCial Dlffioultles 3. Son Axis V: Gl<>bal Asansm(l!!l of Functioning: 51 !Wlmll\bli FOR lti!l!A!. tl16QNIJIIJII: M . - 1 axperienclng tlgnlflcsnt deprtatlon es Is oommon In tho pnoponderanco of oes•• fn~~striallnJun ll>IUII$ from a multiptlell¥ of csusn Including: 1. Loss of mlo status, both In tho family and In the community; ~ss of nW·estaam based on tho increasingly IPPllrtOt dlsparily bolwoon tho damaged real salf and tholnlllmdled pi'IHnjury self nspnsuntatlon. The worker who lsalrelrty lacking In aeK-eatoam, or who Is f\fnollonlog on a borderline lovol prior to the Injury Is partioolorty' vulnerable to ullin g. and peroeMng fl1Q b~ury as a meana of justifying and rons pnovlously oompanul1!<1 for thnougll ••tabHohod a ouc<:..siUI work role ldontll)'; lna~>linvto ,...stabllalllhtlr frligll<> &atly oul:lllmotlona for thO expt$nlcn of 2. , also oxpelionoll1g slgnlncantonxloty, but not to the degree that would QIIJI tor o Ms. dllliiOO,slaiOfa prlml!ty Anxiety Olsorder. Tharafcml, I have aooountad for theaa symptoms by 9 w "' dlagrwalng AdjuatmMt Ol110rdor With Arudety. This dlsgnollsls approprillte When the following crHena art J)nlunc I. Tho development or emotional or behavloml symptoms ln'rosponoe to an identifiable atreuor(s) oceur~no Within thrta montht of tho twet of the llrtsiiOr(t), 2. Thosuymptoms or behovlors 1110 dlnloally •lor>fi¢11111 as evl®nced by either of the follOwing; o) Marked dlslrou that Is in excess of Wlhol would be expllillod from oxposuro to the atrusor(a). b) Slgnlfle~~nt Impairment in $oe/AI or occupational fllnoHonlng. 3, Tho atren•rtlatod dlstlltbanee does n01 meetthe crileM for an01hor apoolfto AXIal disorder and I• not mertly an <1 for nor utWII employment ftont 11/W; CT: 12106, ond mmtnulng. lfSI!IAL j\1\!A!,Y!I!S OF Ml!!llQAL P6UQAWN 11\QiillllQili In our Initial opinion, lhlslnltlal Y, was nat t•klng psycho!ropl~. modloa lonn,, and did not have any problaml With the taw. She wM al$0 functioning wall aoellllly. Mt. - . , d never Hlod any prtvlous Woli«l"*' compwa~on !.llalms. Slle wu 1\Jnctlonlng at 1\.111 QI!Jllldly at the dme or Mr lndustrtall)'i'elatad ln)t:rln This 11 a VIII)' stralghUorwsnl sltua~on. Thert ta no ssquent ohronlc pain. Regarotess or the opeclflo oyndrorno, ·~• of pain, or prsmotbld poycllologleal hlltlth of the psfl4104 renarot~ rtvealli that, m<>te <>nen !han not, ohronio pain rosultsln pii)'Cholol!ICIII Hquelao suoh at madlcal factora Olin doom even the bOJI tx~rtoroinary 10 tl'!la1ment ptan11. Tho ruuks ttom the lnaial psychological tooting 1.11'!1 oonslsln, Ms.-.l'!lsenlo her tlwallon and was flllllful for her lulul'!l, She !\til &llh<>ugh sho had IOJI control of hor lifo. CQnJequonlly, her "lf-osteem plummeted. llho continuo• to exp.Oence sympklmt olanxltl)' and doprnslon, such u lou of ..11 ateem. She feels hopeless about her future. Shola lvllrful of not being abhtto support hllf family. Sha continues to have probll!ms initiating and maintaining a geed night's sleiai sbusorsthat wen1 caualng distress or a mtntaf disorder prlpr to !hi> lnduatrialln)ury. The olalmant Is ruporling a stabllf wOric history. Thor• I& no known history of psrformmce problems, termination•. psriod$ or un•mployment, or ttP9alad disciplinary actions prior lo !ho •mploymant described In this evaluation. She reports getting along wen with other> and w. have no Information to ougrw$1 oU!frwlte until aftor Ute alloQed oosel of work atre..ors. If additional information becomes avalllll>le, thel is not consislStAntlall)' upon others tor basic needs. This inoreaoed nslanoe on othm and the cqnsequent feelings or low •olfo.worlh and leek of tonlidenet tddhlonally oontrii:Mo to one'• depmssed mood, Thla bomos 81pacl10ily problomeUo In • WQI1( setting, •uuch feelings lntorfer<~ with autonomoue doeltlon-maklng and pr~~oludo one from serving in a auporvisol)'otpoclly or holding a poslllon of responalbllll)'. Chfonlo pain and ltll dtproG&Ive •oquelae 'lao slgnlfir:antly lnterfllre will! one's flOIIOIIIve abllltias, aa constant physlool discomfort Impairs one's abi!Uy to oonoentrete and pay attention lor pariod1 oltlmo. Tht• would oonaldorably Impair one'e ~blllty to function, u one'sllblllly to team 1M proe&ss now tnlrlrmallon, follow Instructions, and oornplete tasks and a•tlllnmena.ln 11!'1 el!lllient and Umaly manntt would l>o dotrtmentall)' atreot4d. Ooo't dlstractlblllly and l'f'I'OCCUPallon 'Wilh one's poJn Is' al$0 Ukoly to iliad to r:areilln errors In lhll oondition• p,...ont in throolo•rth• or'"'"" t11fotrod for tre•tment A11>1iol)', P•ln and aubs!llnce ebuliE! dl$01dera are olher commonly en®untored comorbld l!Ondltlons roqulrln~ epeclfia . treatment. Tlwl nature and ooveMI!y of tho patienrs pS)'clllatrto eondltlon plng. Continued functioning I• required, with t11o patient being encouraged to talk through Intense feolings tather than 801 them out. Once 01' lwloe woell of this petltnt. I have not violated Labor Codellectlon 1311.3 and the contenls 01 the report and bill are true and oom~~otto tM best of my knowledge, This ttatemtnt Is mod& under pentlly <>f pe~ury. Ms.~ afforded thttntntlaiiQM son anlst In the ovllluatlon and to htlp M$ feel moro at eate. P~sllng wu also administered In Spanloh and/or with thfl asslstantli of tho lnlerpreW forMa. ~Iter compnohonslon. 1further doolare under the poruolly of perjury that I por.IOrlally Jl(>rfonned the evaluation Of the patient, or In tho c.~s• of a tuppl•m•ntll report, 1por110nally performed thfl cogoltlvo services nec.uary to produoalhmont ol the dlmll\Ci\ tQM ffi0Nlt~.un JllllllOU1HA!rr,lml,~l':lm~IIJ>,CA!1:1.'1(! l'flDNt,{llll!\f.MMIII»MII:.J.*l!ijUlHIU t'.Xo(.U.)rn•Ufl ., 11!11:1111'10(1(l},Af,tUW¥,1t'ftU.!IliKUI'il'tflW,CA11:13U I'IIONl.r·~ll'M31lAN<(M.1)MSil:Jta: Uflt.tmUII(;UJI..YU~IIll>f'.!fl,t(J:NG~H~C/I.'>MU tlltUU~I}MII·fl'M1.\X!{!lii4:~ WORKER$' COMPEQAT!ON INfORMATION SHF.liT Eld, ___.... Cnnh,W1 PMIOI'I __ .,.. ,__, !1n~~~~~~ Jn&wdnw Cmnpal'l)',_, ----·------- Atfdfttuto _ _ _ _ _ _ _ __ OffiCII(.....,_)..__._ _ _ , __Clly___ · - - - .. ll>.. _ _ __ f9x(.............J_~ iiO ~nua ReQe~vad: 1~/12/2011 !t"t~"Jun'~l.?,v~··L ·,,., ...., PROOF OF lll!~VJCE BY MAIL $1'AT5 OF CALIFORNIA·COUNTY OF LOS ANGELES PENALTIES ANI:liNTEF\I!STS WILL 6!! AODEO TO THIS CI.AIM IF PAYMENT IS NOT MADE WITHIN AS DAYS AND ReCeiVl!D IN THIS OFFICE IN 621lAY!I. PPO DISCOUNTS APPLY ONLY IF PAYMI!NT .IS MADE WITHIN 30 DAYS. I doclar• under penalty of pe~•Y h• aOCQlnglolrue ond corttcl• Ol1d that tho •tta- document• wore prepiU'e Qu./)12{) Seunghoon Ahn, LAc . SUck Lee, Ulc. ORTHOPEDIC Edwin Haronian, M.D .• QME Brenl Pm!ley, M.D., QME William Simpson, M.D-. QME. PAIN MANAGEMENT I Benoush Zarrini. M.D. OCCUPATIONAL MEDICINE Abel Quesada M.D QME I PSYCHOLOGIST John Terrence, Psych, PhD, QME I NUEROLOGIST Onubah. Boniface, M.D j Home 1 MPN list 1 Specialties I Aboutus I http://www.painreliefhealth.com/specialties.html ·- ·~-· Contactus www.painrealiefheafth.corn 2010 allrights reserved r 12/16/2011 -.--,.-- EXHIBIT SPECIALISTS CHIRO. Charles Boyer, D.C. BElhar Dant:lsh Gharib. D.c. Lana Montes. D.C. Nayoung Eoh. D.C Tram Sotelo. D.C. MAOM, L.Ac Roger Rahn. D.C. Kristy Tran. D.C. James lwanolf. D.C. Nounan Kambll:. D.C. Lolita Hoorfar. 0 C. ACUPUNCTURE Catherine Lu, L.Ao. Weor~seob lee, LAo. Ktm Jwoun. LAc Mary Jeong, LAc. 0 Saguen. LAc:. Saunghoon Ahn, L.Ac Suck Lee. LAc ORTHOPEDIC Doshi Tushar, M.D. Brant Pratley, M.D., QME William Simpson, M.D., QME. PAIN MANAGEMENT Marintl Rasmussan, M.D Sanjlv Jain. M.D OCCUPATIONA~ MEDICINE Edward Opoku, M.D. t\bal Quo~da, M.D. PSYCHOLOGIST Jof1n Terrence, Psych, PhD, QME. NEUROLOGIST Boniface Ot1ubah. M.D NEUROSURGEON Racllquel Dureza-MuMses. M D. Calolino Dureza. M.D. Home I MPN list 1 Spee~allles 1 About Us 1 Contpq Us http://mpnproviders.com/specialties.html www MPNProvtders.com 2010 allrlgh\s reserved 7/6/2012 EXHIBIT ITJ!MIZID BRI!'AIIDOWN STATEMENT PAIN FREE MANAGEMENT Date: 10121/2011 Patient Name: Claim#: 58 Number. OOB: Employer. DOl: 4/27/2010 4335 Van Nuys Blvd., #184 Sherman Oaks, CA 91403 Tel:(818) 668·8180 Fax: (818) 668-8238 Preferred Employers P.o. Box 85836 San Diego, CA 92186 Pro\llder Name: Charles Boyer D. C. LIC No. 0012366 NP 1: 1932273505 Please mahe checks payable to: PAIN FREE MANAGEMENT TIN: 26-2039129 Diagnosis: 06/25110 97680 08/25110 99080R Patient: 635.00 540.00 0.00 0.00 Chart Number: CONJOOOO Patient: Dates 12114110 12/14/10 12114110 12114/10 12114/10 12114110 12114/10 12114/10 12114/10 12114/10 12114/10 12114/10 Job Site Assessment RTW Report Procedure ML103 96100 9B115 96100 96100 96100 96115 96100 96105 96115 96115 96105 Procedure Mad-Legal Complex Beck Depression lnwntory Sentence Completion Test Beck Daprasslon lnwntory Beck Depression lnwntory Beck Depression inwntory Sentence Ccmpletion Test Beck Depression lnwntory Assesment of Aphasia Sentence Ccmpletlon Test Sentence Completion Test Assesment of Aphasia case: 540.00 PSYCH Remainder 937.50 100.00 0.00 225.00 0.00 0.00 0.00 0.00 0.00 0.00 250.00 0.00 0.00 300.00 0.00 150.00 195.00 250.00 225.00 150.00 250.00 0.00 0.00 0.00 100.00 0.00 0.00 0.00 0.00 0.00 Case: Charge 2,000.00 500.00 o.oo 0.00 o.oo Chart Number: CONJOOOO Procedure Procedure 02103111 23929 Extracorpeal Shockwaw 02103/11 99080S2 635.00 0.00 0.00 0.00 0.00 100.00 225.00· 100.00 250.00 300.00 150.00 195.00 250.00 225.00 150.00 250.00 SHOCKWAVE Remainder 0.00 2,000.00 500.00 0.00 Balance Dua 17,076.41 EXHIBIT Scheduler Print View ' .. https://grrncd4.tnps: Jy.net/!lfmed/newcal2/prlntview.php?day~... " HAZEN, L schedule for 12106/11 RESEDA 6944 Appointments 85 · No·show 0 Cancelled 0 Rescheduled 0 I of4 Electronic Forms Superbills SOAP Notes 2 (0 completed) 83 (0 121712011 2:04PM Scheduler Print Vtew 2of4 https://gnned4.mpl dy.ooVgrmedloowcal2/prlntview.pnp?da)l'"... 12/7/2011 2:()4 PM Scheduler Print View 3 of4 hups ://grmed4 .rnp> · Jy.nC1/gnned/newcal2/prlntview .php?dar... 12171201l2:04 PM Scheduler Print View https:llgrmed4.mp>. 1rllm~h••;,.,._,....,. _ _ ..,. Oral McdjcatiwC•> ~---_JQilliC».t~.......,lollcO.IMOO"'' ~lorl"i_..., _IO!Apl _~Cctju _1101:r/M llkliiMitlii!IOIW!UIIt '1$/l~ma OldolooiOI ....,ildlnr MUSCL< ~SAID PAIN $P.IMTIYr. IIYfNOTIQ\ OTHER: ___ - - - - - - - ---&1><1 Rtl•c.utm ·-i::~~JAnlll ..;m WCIIId\WN A.. 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Alu, c" lil10 \ l 0 Medication Prescription ~IIYIICIM'!W't1 _ _ _ _ - - - - - - - - - - - - - --~-"1>1'------- - R·1»4~ BL•4 ....I.Ci\~1))! _mrt..,., -1111<4 Stt~!O _maPS'!' C., _uil w$• Sl Oliroo!, CA 9l0l4 llllim!lld.CAtllH JlllWC!JI¢t>t~1 A,. ViNill~ CA 91.1'17 LMtU...ti,CA 90111\7 '"'* ...JliO Wll