36 MICHAEL A. HESTRIN DEFECT ATTORNEY County of Riverside State of California MICHAEL A. HESTRIN District Attorney County of Riverside 3960 Orange Street, First Floor Riverside, California 92501 Telephone: (951) 955-5400 John Aki Chief Assistant District Attorney State Bar No. 189395 BAIL: Touba Pahdel-Nabati $12,402,000.00 Quynam Nguyen Jason Yang $12,402,000.00 $12,402,000.00 SUPERIOR COURT OF CALIFORNIA - COUNTY OF RIVERSIDE (Riverside) THE PEOPLE .OF THE STATE OF CALIFORNIA, Plaintiff, Vt TOUBA DOB: 08/03/1978 I QUYNAM NGUYEN DOB: 06/1 1/19581: JASON YANG DOB: 02/24/1966 Defendants. - COUNT 1 NO. RIC INDICTMENT The Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses TOUBA and QUYNAM NGUYEN and JASON YAN of a violation of Penal Code section 182, subdivision subsection (1), a felony, in that on or about January 1, 2009 through and including July 15, 2014, in the County of Riverside, State of California, they did willfully and unlawfully conspire together and with another person and persons whose identity is unknown to commit the crime of KNOWINGLY MAKING OR CAUSING TO BE an 910202: WW 365 MICHAEL A. HESTRIN County of Riverside State of California HEIDARY. identical injuries. i MADE ANY FALSE OR FRAUDULENT CLAIMS FORPAYMENT OF HEALTH CARE violation of Penal Code section 550, subdivision subsection (6), a felony, . and that pursuant to and for the purpose of carrying Cut the obj ects and purposes of the I aforesaid conspiracy,?the said. defendants thereafter committed the fellowing overt act and acts at and in the County of Riverside: OVERT ACT NO. _1 CARY DAVID ABRAMOWITZ agreed and allowed PEYMAN HEIDARY, a non-attomey, to exert actual control over California Injury Lawyers, AKAOrange County Law Group, and AKA South?Western Law Group (collectively ?the Law PEYMAN HEIDARY controlled 'day?to-day operations including scheduling, hiring and ?ring. OVERT ACT NO. 2 The Law Firm directed patients to clinics ownedliand/or controlled by PEYMAN OVERT ACT No; 3. - CARY DAVID ABRAMOWITZ, as directed by paid Cappers $100 perpatient signed up as a client ofthe Law Firm. .OVERT ACT NO. 4. - . Cappers began working for PEYMAN HEIDARY when PEYMAN HEIDARY offered Cappers a job in a new law ?rm opened by HEIDARY and Kenneth Forbes. - OVERT ACT NO. _5 . had worker?s compensation claimants sign blank forms, C-appers returned these forms to the Law Firm, who ?lled them out and submitted them, along with other paperwork, to the Worker?s Compensation Appeals Board and various insurance companies. . OVERT ACT NO. 6? I The Law Firm ?led numerous workers? compensation claims alleging similar?or OVERT ACT No. 7 I "Cappers sought out additional claimants from previously identi?ed claimants. OVERT ACT No: 8 . PEYMAN HEIDARY owned and/or controlled Riverside Health Clinic, Corona Health Health Clinic, Bell?ower Health Clinic, Santa Ana Health Clinic, and k. Anaheim Health Clinic. A OVERT ACT NO. 9 I PEYMAN HEIDARY created the Clinics as Limited Liability Companies. . ACT No: 10 . PEYMAN HEIDARY moved employees betWeen the Clinics and 2. 36 MICHAEL A. HESTRIN ATTORNEY Caunty of Riverside State of California the Law Firm. OVERT ACT NO. 11 PEYMAN HEIDARY COntrolled scheduling of doctors at the Clinics. OVERT ACT NO. 12 . PEYMAN HEIDARY controlled payments of the medical professionals at the Clinics. OVERT ACT NO. 13 PEYMAN HEIDARY controlled patient care at the Clinics, including dictating treatments and referrals. He ordered his employees to ensure that each patient received the same or similar treatment and test studies regardless of injury. OVERT ACT NO. 14 TOUBA PAKDEL-NABATI contributed to patient care at the Clinics, including dictating treatments and referrals. She ordered her employees to ensure that each patient received the same or similar treatment and test studies regardless of injury. OVERT ACT NO. 15 QUYNAM NGUYEN received referrals for unnecessary treatment which led to the creation of med-legal reports he caused to be created which QUYNAM NGUYEN knew would later be submitted for billing. I OVERT ACT NO. 16 JASON YANG received referrals for unnecessary treatment which led to the creation of med?legal reports he caused to be created which JASON YANG knew would later be submitted for billing. OVERT ACT NO. 17 The Clinics submitted bills and liens for treatments ordered by PEYMAN HEIDARY to insurance companies ?and the WCAB. OVERT ACT NO. 18 The Law Firm received payments in part from Compromise and Releases from the WCAB and in part from legal fees billed to insurance companies. OVERT ACT NO. 19 When PEYMAN HEIDARY hired medical and chiropractic professionals to work at the Clinics, he ordered said professionals to create a checking account with PEYMAN HEIDARY as a signatory so he could maintain control of that account. Once created, said professionals were not allowed to make any changes or withdrawals to the account without PEYMAN permission. PEYMAN HEIDARY further ordered that any payments made to said professionals be deposited in that professional?s checking account and the professionals were paid out of that account. U.)me 014:0.) 36 MICHAEL A. HESTRIN DISTRICT ATTORNEY County of Riverside State of California subsection (2). I - OVERT ACT No, 20 . PEYMAN HEIDARY ordered said professionals to assign the all outstanding bills/ accounts receivables to him. HEIDARY wouldthen bundle the. outstanding bills and sell them to third party collections and/or medicalnfactoring COUNT 2 For a further, and separate cause of action, being a different offense from but connected . in its commission with the charge set forth in count 1 hereof, the Criminal Grand Jury of the county .of Riverside by this Indictment hereby accuses TQUBA and QUYNAM NGUYEN and JASON a violation-of Penal Code section 550, subdivision subsection (6), a felony, in that on?or about January 1, 2009 through and including July 15,, 2014, in the County of Riverside, State of California, the defendants did willfully and unlawfully and knowingly makeand cause to be made a false and fraudulent claim for payment of a health care bene?t, to wit, from ACE, and the claim andamount at issue exceeded Nine Hundred Fifty dollars ($950) and the aggregate- amount of Claims and amount at issue exceeded Nine Hundred Fifty dollars ($950) in a ?ve years and wsix-month consecutive period. I - a It is further alleged that in the commission and attempted commission of the above offense the said defendants, TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and JASON YANG, with intent so to do,~took, damaged and destroyed property of a value exceeding$200,000, within the meaning of Penal Code section 12022.6, Subdivision COUNT 3 ?1 For a further and separate cause _of action,.being a different offense'from but connected in its commission with the charges 'set forth in- counts 1 and- 2 hereof, the Criminal Grand Jury of?the County of Riverside by-this Indictment hereby accuses TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and JASON YANG of 'a violation of Penal Code sectionp550, I subdivision subsection (6), a felony, in that on or about anuary 1, 2009 through and including July 15, 2014, in the County of Riverside, State California, the. defendants did willfully ?and unlawfully and knowingly make and. cause to be made a. false and fraudulent claim. fer payment of a health care bene?t, to wit, frOm AMERICAN INTERNATIONAL A GROUP (AIG), and the claim and amount at?issue exceeded Nine. Hundred Fifty dollars ($950) and the aggregate amount of claims and amount atkissue exceeded Nine Hundred Fifty dollar's ($950) in ?ve years and six-month consecutive period. It is furtth alleged that in the Commission and attempted Commission of the aboVe offense the'said defendants, TOUBA and QUYNAM NGUYEN and JASON YANG, with" the intent so to?do, took, damagedand destroyed property. ofa value 4 36 MICHAEL A. HESTRIN County of Riverside State of California within the meaning of Penal Code section 12022.6, subdivision subsection (1). I . COUNT For a-?rrther and separate cause of action, being a different offenSe ?ombutbonnected in its commission the charges set?fforth in counts 1 through 3 hereof, the Criminal Grand - Jury of the County of Riverside by Indictment hereby accuses TOUBA and QUYNAM NGUYEN and JASON YANG of a violation of Penal Code section1550, subdivision Subsection (6), a felony, in that on or about anuar'y 1, 2009? through and including July 15, 2014, in the County of RiVerside', State of California, the defendants did willfully and unlawfully and knowingly make and cause to be?made a false and fraudulent claim forpayment of a health Care bene?t, to wit, from and the claim and amount at issue exceeded Nine Hundred Fifty dollars ($950) ands-the aggregate . amount of claims and amount at issue? exceeded Nine Hundred Fifty dollars ($950) in a ?ve years and ?six-month consecutive period. I It is further alleged that in the and attempted commission of the above offense the said defendants, TOUBA PARDEL-NABATI and QUYNAM NGUYEN and With the intent so to .do, took, damaged and destroyed property of a value exceeding $200,000, within thekmean'ing of Penal Code section 12022.6, subdivision subsection COUNT 5 For a further and separate cause of action, being a differentyoffense from but cOnnected in its comfnission' With the charges set forth! in counts 1 through 4 hereof, the Criminal Grand Jury of the County?lof Riverside by this Indictinent?hereby accuses TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and JASON YANG of a violation of Penal Code section 550, subdivision subsection (6), a felony, in-that on or about January 20.09 through and including July 15, 2014, in the County of RiVerside, 'State of California, the defendants did willfully and'unlawfully and knowingly make and cause to be made a false and ?audulent claim ?for payment of a health care benefit, to Wit, fr0m CNA INSURANCE, and the claim and amount at issue exceeded Nine Hundred Fifty dollars ($950) and theaggregate amOunt of claims and amount at issue exceeded Nine Hundred Fifty dollars ($950) me ?ve years and six? month consecutive period. 7 '1 _It is further alleged that in the commission and attempted commissiOn of the above offense the said defendants, TOUBA and NGUYEN and JASON YAN G, with the intent so to do, took, damaged and property of a value exceeding $200,000, within the meaning of Penal Code section 12022.6, subdivision subsection (2). 36 MICHAEL A. HESTRIN DISTRICT ATTORNEY County ofRiverslde State of California subsection (2). . COUNT 6 1 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 5 hereof, the Criminal Grand" Jury of the County of Riverside by this Indictment hereby accuSes and QUYNAM NGUYEN and JASON YANG of?a violation ofPenal Code section 550, subdivision subsection (6), a felony, inthat on or abdut January 1, 2009 through and including July 15, 2014, in the County of Riverside, State of. California, the defendants did willfully and-unlawfully andlmowingly make and cause to be made a false and fraudulent claim for payment of a health care bene?t, to wit, ?om CALIFORNIA RESTAURANT MUTUAL BENEFITS CORPORATION and the claim and amount at issue . exceededNine Hundred Fifty dollars ($950) and the aggregate amount of claims and amount at issue exceeded Nine Hundred Fifty dollars ($950) in a fiVe, years and six?month consecutive period; i I I It is further alleged that in the commission and attempted commission of the above offense the said defendants, TOUBA and NGUYEN and JASONYANG, with the intent so to do, took, damaged and destroyed property of a value exceeding $200,000, within the meaning of Penal Code section 12022.6, subdivision . I COUNT 7 . For a further andmseparate cause of action, being a different offense from but connected in its commisSiOn with the charges set forth in counts 1 through. 6'hereof, the Crimina1,Grand Jury of the County of "Riverside by this Indictment hereby accuses TOUBA - i and YANG of a violation?of Penal Code section 550, subdivision (6), a felony, in-that on or about January 1, 2009 through and . including July 15, 2014, in the County of. Riverside, State of California, the defendants did . Willfully and unlawfully make and cause to. be made a false and fraudulent claim for payment of a health care bene?t, to wit, ?'om CRUM FORESTER, and the claim? and amount at issue exceeded Nine Hundred Fifty dollars ($950) and the aggregate amount of claims and amount at. i3sue exceeded Nine'Hundred Fifty dollars ($95 in a five years and six? month conSecutive period. ltis further alleged that in the commission and attempted commission of the above offense the said defendants, TOUBA and QUYNAM NGUYEN and JASON YANG, With the intent so to -do,'took,_ damaged and destroyed'property of value exceeding $200,000, within the meaning of Penal Code section 12022.6, subdivision subsection (2). - - .mAmNt?aoxoreoxioxm ?36 MICHAEL A. HESTRIN DISTRICT ATTORNEY County of Riverside State ofCalifornla COUNT 8? "For a? further. and separateicause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 7 hereof, the Criminal Grand I Jury of the County of Riverside by this Indictmenthereby accuses TOUBA and NGUYEN and JASON YANG of a violation of Penal Code section 550, subdivisiOn subsection a felony, in that on or about January 1, 2009 through and including ,July ,1 5, 2014, in the County of Riverside, State er California,- the defendants did . - willfully and unlawfully and knOWingly make and cause to be made a false and fraudulent claim for payment of ahealth care bene?t, to wit, from. EMPLOYERS, and the claim and amount at issue exceeded Nine Hundred ?fty dollars ($950) and the aggregate amount of claims and amount at issue exceededNine Hundred Fifty dollars ($950) in a ?ve years and six- . month consecutive period. It is further alleged that in the commission and attempted commission of the above offense the said defendants, TOUBA and NGUYEN and I JASON YANG,'with the intent so to do, took, damaged and-destroyed property of a value exceeding $200,000, within the meaning of Penal Code section 12022.6, subdivision ?subsection (2). .- COUNT 9 . .For a further andtseparate cause of action, being a. differentoffense ?om but connected . in its comr-?nissibn with the charges set forth in counts 1 through 8fhereof, the Criminal-Grand - Jury of the County of Riverside by this Indictment hereby accuses TOUBA end QUYNAM NGUYEN and JASON YANG of a violation of Penal code section 550, Subdivision subsection (6), a felony; in that on or about January 1, 2009 through and including July 15, 2014, in the County of RiVerside, State of California, the defendants did willfully and unlawfully and knowingly make and cause to bemadea false and fraudulent claim for payment of a health care bene?t, to Wit, from EVEREST NATIONAL INSURANCE COMPANY (ENIC), and the claim and amount at issue exceeded'Nine Hundred Fifty dollars ($950) and the aggregate amount of claims and amount at iSSuetekceeded Nine .Hundred Fifty dollars ($950) in a ?ve years and six-month consecutive period. 1 It is further alleged that in the commission and attempted commission of the above offense the, said defendants, TOUBA and NGUYEN and JASON YANG, with the intent so to do, took, damaged and destroyed prOpertyof a'value exceeding sixty ?ve thousand dollars within the meaning of Penal Code section 12022.6, Subdivision subsection (1). COUNT 10 For a?further and separate cause of action, being a different offenSe from but connected 1 36 MICHAEL A. HESTRIN County of Rlverslde State in its commission with the charges set forth in counts 1 through 9 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and JASON YANG of a violation of Penal Code section 550, subdivision subsection (6), a felony, in that on or about January 1, 2009 through and including July 15, 2014, in the County of Riverside, State of California, the defendants did willfully and unlanully and knowingly make and cause to be made a false and ?audulent claim for payment of a health care bene?t, to wit, from and the claim and amount at issue exceeded Nine Hundred Fifty dollars ($950) and the aggregate amount of claims and amount at issue exceeded Nine Hundred Fifty dollars ($950) in a ?ve years and six-month consecutive period. It is further alleged that in the commission and attempted commission of the above offense the said defendants, TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and JASON YANG, with the intent so to do, took, damaged and destroyed property of a value exceeding $200,000, within the meaning of Penal Code section 12022.6, subdivision subsection (2). if. COUNT 11 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts ?1 through 10 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses TOUBA and QUYNAM NGUYEN and JASON YANG of a violation of Penal Code section 550, subdivision subsection (6), a felony, in that on or about January 1, 2009 through and including July 15, 2014, in the County of Riverside, State of California, the defendants did will?illy and unlawfully and knowingly make and cause to be made a false and fraudulent claim for payment of a health care bene?t, to Wit, from and the claim and amount at issue exceeded Nine Hundred Fifty dollars ($950) and the aggregate amount of claims and amount at issue exceeded Nine Hundred Fifty dollars ($950) in a ?ve years and six?month consecutive period. It is further alleged that in the commission and attempted commission of the above offense the said defendants, TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and JASON YANG, with the intent so to do, took, damaged and destroyed property of a value exceeding $65,000, within the meaning of Penal Code section 12022.6, subdivision subsection (1). COUNT 12 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 11 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses TOUBA 1 and NGUYEN and JASON YANG of a violation of Penal Codesection 550, .. 2 subdivision subsection (6), a felony, in that on or about January 1, 2009 through and 3 including July 15, 2014, in the County of Riverside, State of California, the defendants did 4 willfully and unlawfullyand knowingly make and cause to be made a false and fraudulent 5 - claim for payment of a health care bene?t, to wit, from HARTFORD, and the claim and amount 6 at issue exceeded Nine Hundred Fifty dollars ($950) and the aggregate amount of claims and 7 amount at issue exceeded Nine Hundred Fifty dollars ($95 0) in a ?ve years and six-month 8 consecutive periodfurther alleged that inlthe commission and attempted commission of the above 10 offense thesaid defendants, TOUBA PAKDEL-NABATI and QUYNAMNGUYEN and 11 JASON YANG, with the. intent so to do, took, damaged?, and destroyed-property of a value 12' within the meaning of Penal Code sectiOn 12022.6, subdivision 13 subsection (2): i I . i 14 COUNT 13 15 For a further and separate cause of action, being a different offense from but connected ?16 in its commission with-the-charges Set forth in counts 1 through 12 hereof, the Criminal Grand 17?. Jury of the County of Riverside by this Indictment hereby accuses TOUBA 18 and QUYNAM NGUYEN and JASON YANG of a Violation of Penal- Code section 550,? 19 subdivision subsection (6), a felony, in that on or about January 1, 2009? through and 20 including July 15, 2014, in the County of Riverside, State of California, the defendants did 21 - willfully and unlawfully and knowingly make and cause to be made a false and fraudulent 22 claim fa? payment of a health care bene?t, to wit, ?om INSURANCE CARRIES OF THE 23 .WEST (ICW) and the claim-land amount at issue exceeded Nine Hundred Fifty dollars ($950) 24 andthe aggregate aniount of claims and amount at isst1e exceeded?Nine Hundred Fifty dollars 25 ($950) in a ?ve years and six-month consecutive period. 26 it is further alleged that in the commission and attempted commission of the above 27 offense the said defendants, TOUBA and QUYNAM NGUYEN and 28. JASON YANG, with the intent so to do, took, damaged and destroyed property of a'value 29 exceeding $200,000, within the meaning of Penal Code section 12022.6, subdivision _30 subsection (2). if 31 COUNT 14 3:2 For a further and separate Cause of action, being a different offense from but connected 33 in its commission with the charges set forth in counts 1 through 13 hereof, the Criminal Grand 34 I Jury of "the County of Riverside by this Indictment hereby accuses 35 i and QUYNAM NGUYEN and. JASON YANG of a?violation-ofPenal Code section 550, 3 6 subdivision subsection (6), a felony, in that on or. about January 2009 through and I County of Riverside 9 State of California 36 MICHAEL A. HESTRIN ATTORNEY County of Riverside State of Callfornla including July 15, 2014, in the County of Riverside, State of California, the defendants did willfully and unlawfully and knowingly make and cause to be made 'a false and fraudulent claim for payment of a health care bene?t, to wit, from LIBERTY MUTUAL, and the claim and amount at issue exceeded Nine Hundred Fifty dollars ($950) and the aggregate amount of claims and amount at issue exceeded Nine Hundred Fifty dollars ($950) in a five years and six- month consecutive period. It is further alleged that in the commission and attempted commission of the above offense the said defendants, TOUBA and QUYNAM NGUYEN and JASON YANG, with the intent so to do, took, damaged and destroyed property of a value exceeding $1,300,000, within the meaning of Penal Code section 12022.6, subdivision subsection (3). COUNT 15 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 14 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses TOUBA PAKDELTNABATI and QUYNAM NGUYEN and JASON YANG of a violation of Penal Code section 550, subdivision subsection (6), a felony, in that on or about January 1, 2009 through and including July 15, 2014, in the County of Riverside, State of Califomia,_the defendants did willfully and unlawfully and knowingly make and cause to be made a false and fraudulent claim for payment of a health care bene?t, to wit, from REPUBLIC INDEMNITY, and the claim and amount at issue exceeded Nine Hundred Fifty dollars ($950) and the aggregate amount of claims and amount at issue exceeded Nine Hundred Fifty dollars ($950) in a ?ve years and six-month consecutive period. 5 It is further alleged that in the commission and attempted commission of the above offense the said defendants, TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and JASON YANG, with the intent so to do, took, damaged and destroyed property of a value exceeding sixty five thousand dollars within the meaning of Penal Code section 12022.6, subdivision subsection (1). COUNT16 For a further and separate cause of action, being a different offense from. but connected in its commission with the charges set forth in counts 1 through 15 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses TOUBA and QUYNAM NGUYEN and JASON YANG of a violation of Penal Code section 550, - subdivision subsection (6), a felony, in that on or about January 1, 2009 through and including July 15, 2014, in the County of Riverside, State of California, the defendants did willfully and unlawfully and knowingly make and cause to be made a false and fraudulent 10 .1 p?l -36' MICHAEL A. HESTRIN 1 DISTRICT ATTORNEY County .3: Riverside State of California claim for paymth of a health care bene?t, to wit, STATE INSURANCE FUND (S CIF), and the claim and amount at issue exceeded Nine Hundred Fifty I dollars ($950) and the aggregate amount of claims and amount at issue exceeded Nine Hundred, -.. ($950) in a ?ve years and six-month consecutive period. . It is further alleged that in the commission and attempted commissiOn of the above offense the said defendants, TOUBA PAKDELLNABATI and QUYNAM NGUYEN and JASON YANG, with the intent so to do, took, damaged and destroyed property of a value exceeding $1,300,000, within the meaning of Penal Code sectiOn? 12022.6, subdivision subsection - i I COUNT 17 For a .?rrther and separate cause of action, being a different offense from but conneCted in its commission charges .set forth in counts 1 through 1.6 hereof, the Criminal Grand Jury of . the County of Riverside by. this Indictment hereby accuses TOUBA and I QUYNAM NGUYEN and JASON YANG of- a Violation, of Penal Code section 550, subdivision subsection (6), a felony, in that on or about January 1, 2009 through and, including July 15, 2014, in the. County of Riverside, State of California, the defendants did Will?illy and unlawfully and knowingly makeand cause to bemade a false and fraudulent claim for payment of a health care bene?t, to wit, from and the claim and amount at issue exceeded Nine Hundred Fifty dollars the aggregate amount of claims and amount at issue exceeded Nine. Hundred Fifty dollars ($950) in a ?ve years and six-month consecutiVe period. It is further alleged that the commission and attempted commission of the above offense the Said defendants, TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and JASON YANG, with the intent so to do, took, damaged and. destroyed property of a value exceeding $1,300,000, within the meaning of Penal Code section 12022.6, subdivision subsection (3). COUNT 718 For-a further and separate causel'of action, being .a-different offense from but connected I in its commission with the charges setforth i'n? counts 1 through 17 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby aeouses TOUBA and NGUYEN and JASON YANG of 'a violation of Penal Code Section 550, subdivision subsection (6), a felony, ,in that on or about anuary'wl, 2009 through and; including July 15 2014, in the County of Riverside, State of California, the. defendants did will?illy and unlawfully and knowingly make and cause to be. made a false and fraudulent claim for payment of a health care bene?t, to wit, from ZENITH, and the claim and amount at issue exceeded. Nine Hundred Fifty dollars ($950) and theaggregate amount of claims and amount at issueexceeded~ Nine Hundred Fifty dollars ($950) in a ?ve yearsand six-month 11 36 MICHAEL A. HESTRIN DISTRICT ATTORNEY County of Riverside State of California subsection (1). consecutive periodfurther alleged that in the commission and attempted?commission of the above offense the said defendants, and QUYNAM NGUYEN and JASON YANG, with the intent so to do, took, damaged and destroyed property ofa value exceeding $65,000, Within the meaning of Penal Code section 12022.6, subdivision 1 COUNT 19 I For afurther and separate cause of action, being a different Ioffense from but connected in its commission with the charges set forth in Counts 1 through18 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby aCcuses TOUBA PAKDEL-NABATI and, QUYNAM NGUYEN and JASON YANG of a violation 'of Penal Code section 550, subdivision subsection (6), a felony, in that on or about January 1, 2009 through and including July 15, 2014, in the County of Riverside, State ,of California, the defendants did willfully and unlawfully and knowingly make and cause to be madea false and fraudulent I I claim for payment of a health care?bene?t, to wit, ?om ZURICH, and the claim and amount at I issue exceeded Nine Hundred Fifty dollars ($950) and the aggregate amount .of claims and amount at issue exceeded Nine Hundred Fifty dollars ($950) in a ?Ve years and six?month consecutive period. - I It is further alleged that in. the commission and attempted commission of the above offense the said defendants, TOUBA and QUYNAM NGUYEN Iand JASON YANG, with the intent so to do, took, damaged and" destroyed property of a value - exceeding 1,300,000, within the meaning of Penal Code section Subsection (3). I COUNT 20. For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 19 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses TOUBA and QUYNAM NGUYEN and JASON of a Violation of Insurance Code sectionJ1871.4, subdivision subsection felony, in that on or about January 2009 through and including July 15,2014, in the County of Riverside, State .of California, the defendants did I willfully and unlawfully make and cause toube made a knowingly false and fraudulent material statement and material representation, to wit, to ACE, for the purpose of obtaining-and denying compensation, as de?ned in Labor Code section "3207. I I COUNT '21 For a further and separate cause of action, being a different offense from but connected in: its commiSSion with the charges set forth in counts 1 through 20 hereof, the Criminal Grand 12 1 ury-of the Connty of Riverside this herebyvaccuses TOUBA PAKDEL-NABATI 2 I and QUYNAM NGUYEN and JASON YANG of a violation of Insurance Code section "1871.4,- 3 Subdivision subsection a felony, in that on or about (January 1, 2009 through and 4 1 including July 15, 2014, in the County of Riverside, State of California; the defendants did '5 willfully and unlawfully make and cause to be made a knowingly false fraudulent-material 6 statement and material representation, to wit, to AMERICAN INTERNATIONAL GROUP 7 (AIG) for the purpose of obtaining and denying compensation, as de?ned in?L?abor Code 8 a section 3207. 9, It is further alleged that in the commission and attempted commissionbf the above 1.0 ?offense the said defendants, TOUBA and QUYNAM NGUYEN and '11 JASON YANG, IvVith the intent'so to do, took, damaged and destroyed property of a value 12 exceeding $65,000, Within the meaning of Penal Code section 12022.6, subdivision 1?3 subsection (1). I 14 - COUNT 22 15 I i For a ?irther'and separate cause of action, being "a different offense from-but connected 16 in its commission'with the charges set forth in counts 1 through 21 hereof, the Criminal?Grand 17 3 Jury of the County of Riverside by this. Indictrnent hereby accuses TOUBA. ?18 and QUYNAM JASON YANG of a violation of Insurance Code sectiOn 1871.4, 19 subdivision subsectioii (1), a felony, in that on or about January 1, 2009 through and 20 including July-1.5, 2014, in the County of Riverside?, ?State of California, the defendants did ?2 1 i will?illy and unlawfully make and cause to be made a knowingly false and fraudulent material 22 statement and material representation, to wit, to .fOr the purpose of 23 obtaining and denying?compensation, as de?ned in Labor Code section 3207. 24 A COUNT 23 25 For a further and separate cause of action, being a different offense from but connected 26 . in its commission with the charges set? forth in counts 1 through 22 hereof, the Criminal Grand 27 . Jury of the County of Riverside by this'Indictment hereby accuses TOUBA RAKKDEL-NABATI 2 28 and NGUYEN and JASON YANG of a violation of Insurance Code'sect-ion. 1871.4, 29 - subdivision subsectiOn (1), a; felony, in that on ,or about January 1, 2009 through and 30 including July 15, 2014, in. the County of Riverside, State of California, the defendants did 31 . willfully and unlaw?illy- make and cause to be made a knowingly false and fraudulent material 32 statement and material representation, to wit, to CNA INSURANCE for the purpose of 33 obtaining and denying compensation, as de?ned inLabOr- Code section 3207. 34 COUNT 24 35 For a'further and separate cause of action, being a different offense from but connected 36 in its commission with the charges Set forth in counts 1through 23 hereof, the Criminal Grand County ol'Rlverslde 1. .7 13 State of California 36 MICHAEL A. HESTRIN DISTRICT ATTORNEY County of Riverside State of California Jury of the County of Riverside by this Indictment hereby accuses TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and JASON YANG of a violation of Insurance Code section 1871.4, subdivision subsection. (1), a felony, in that on or about January 1, 2009 through and I including July 15 2014, in the County of Riverside, State of California, the defendants did will?illy and unlawfully make and cause to be made a knowingly false and fraudulent material statement and material representation, to wit, to CALIFORNIA RESTAURANT MUTUAL BENEFITS CORPORATION for the purpose of obtaining and denying compensation, as de?ned in Labor Code section 3207. COUNT 25 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 24 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses PEYMAN HEIDARY and CARY DAVID ABRAMOWITZ and ANA SOLIS and GLADYS ROSS of a violation of InSurance Code section 1871.4, subdivision subsection (1), a felony, in that on or about January 1, 2009 through and including July 15, 2014, in the County of Riverside, State of California, the defendants did willfully and unlawfully make and cause to be made a knowingly false and fraudulentmaterial statement and material representation, to wit, to CRUM FORESTER for the purpose of obtaining and denying compensation, as de?ned in Labor Code section 3207. It is further alleged that in the commission and attempted commission of the above offense the said defendants, PEYMAN HEIDARY and CARY DAVID ABRAMOWITZ and ANA SOLIS and GLADYS ROSS, with the intent so to do, took, damaged and destroyed property of a value exceeding $200,000, within the meaning of Penal Code section 12022.6, subdivision subsection (2). COUNT 26 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 25 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and JASON YANG of a violation of Insurance Code section 1871.4, subdivision subsection (1), a felony, in that on or about January 1, 2009 through and including July 15, 2014, in the County of Riverside, State of California, the defendants 'did willfully and unlawfully make and cause to be made a knowingly false and ?audulent material statement and material representation, to wit, to EMPLOYERS INSURANCE for the purpose of obtaining and denying compensation, as de?ned in Labor Code section 3207 . I It is ?irther alleged that in the commission and attempted commission of the above offense the said defendants, TOUBA and QUYNAM NGUYEN and 14 36 MICHAEL A. HESTRIN DISTRICT ATTORNEY County of Riverside State of California . 12022.6", subdivision subsection (1). JASON YANG, with the intent. so to do, and destroyed property of a value exceeding sixty ?ve thousand dollars within the meaning ?of Penal Code section a . . COUNT 27 For a ?irther separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 26 hereof, the Criminal Grand Jury of the Countyof Riverside by this Indictment hereby accuses TOUBA . and QUYNAM NGUYEN and JASON YANG of a violation of Insurance Code section 1871.4, subdivision subsection (1), a felony, in that on or about January 1, 2009. through and 1? including .Ju1y_1 5, 2014, in the County of Riverside, Stateof California, the defendants did willfully and unlawfully make and cause to be made a knowingly false and fraudulent material- statement and material repre'Sentation, to wit, to EVEREST NATIONAL INSURANCE I COMPANY (ENIC), for the purpose .of obtaining and denying, compensation, as de?ned in Labor Code section 3207. - - i I COUNT 28 For a further and Separate cause of action, being a different offense from but connected in itscommission with the charges, set forth in counts 1 through .27 hereof, the Criminal Grand Jury of the county of Riverside by this Indictment hereby accuses TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and JASON YANG of a violation of Insurance Code section 1871.4, subsectiOn (1.), a felony, in; that on or about January 1, 2009 through and including July 15, 2014, in the County of Riverside, State of California, the defendants did willfully and unlawfully make and causeto be made a knowingly false and fraudulent material statement and material representation, to twit, to INSURANCE for thepurpose of obtaining and denying compensation, as de?ned in Labor Code section 3207. COUNT29 For a further and separate cause of action, being a different offense ?om but connected in its commission with the charges set forth in connts 1 through 28 hereof, the Grirninal Grand. Jury of the Conntyof Riverside by this Indictment hereby accuses TOUBA PAKDEL-NABATI and NGUYEN and JASON YANG of aiviolation of Insurance Code section 1871.4, subdivision subsection (1), a felony, in that .on or about January 1, 2009 through and 0 including July 15 2014, in the County of Riverside, 'State of California, the defendants did. willfully and unlawfully make and cause to be made a knowingly. false and fraudulent material statement and material representation, to wit, to for the purpose of obtaining and denying compensation, as de?ned in Labor Code section 3207. A It is further alleged that in the commission and attempted commission of the above offense the said defendants, TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and 15 36 MICHAEL A. HESTRIN DISTRICT ATTORNEY County of Riverside State of California JASON YANG, with the intent so to do, took, damaged and destroyed property of a value exceeding sixty ?ve thousand. dollars within the meaning of Penal Code section 12022.6, subdivision subsection (1). COUNT 30 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 29 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses PEYMAN HEIDARY and CARY DAVID ABRAMOWITZ and ANA SOLIS and GLADYS ROSS of a violation of Insurance Code section 1871.4, subdivision subsection (1), a felony, in that on or about January 1, 2009 through and including July 15, 2014, in the County of Riverside, State of California, the defendants did willfully and unlawfully make and cause to be made a knowingly false and fraudulent material statement and material representation, to wit, to HARFORD, for the purpose of obtaining and denying compensation, as de?ned in Labor Code section 3207. It is further alleged that in the commission and attempted commission of the above offense the said defendants, PEYMAN HEIDARY and CARY DAVID ABRAMOWIT and ANA SOLIS and GLADYS ROSS, with the intent so to do, took, damaged and destroyed property of a value exceeding sixty ?ve thousand dollars within the meaning of Penal Code section 12022.6, subdivision subsection (1). COUNT 31 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 30 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses TOUBA and QUYNAM NGUYEN and JASON YANG of a violation of Insurance Code section 1871.4, subdivision subsection (1), a felony, in that on or about January 1, 2009 through and including July 15, 2014, in the County of Riverside, State of California, the defendants did willfully and unlawfully make and cause to be made a knowingly false and fraudulent material statement and material representation, to wit, to INSURANCE CARRIERS OF THE, WEST (ICW), for the purpose of obtaining and denying compensation, as de?ned in Labor Code section 3207. I COUNT 32 For a ?irther and separate cause of action, being a different offense ?om but connected in its commission with the charges set forth in counts 1 through 31 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses TOUBA and QUYNAM NGUYEN and JASON YANG of a violationyof Insurance Code section 1871.4, subdivision subsection (1), a felony, in that on or about January 1, 2009 through and including July 15 2014, in the County of Riverside, State of California, the defendants did 16 36 MICHAEL A. HESTRIN ATTORNEY County of Riverside State of California I subdivision ?subsection willfully and unlawfully make and cause to be made a knowingly- false and ?audulent material statement and material representation, to wit, to LIBERTY MUTUAL for the purpose of I obtaining anddenying compensation, as defined in Labor Code section 3207. COUNT33 For a further and separate cause of "action, being a different offense from but connected in its commission with the Charges set forthin counts 1 through 32 hereof,the Criminal Grand Jury of- the County of Riverside by this Indictment hereby accuses TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and of a Violation of Insurance Code section 1871.4, I subdivision subsection (1), a felony, in that on or about January 1, 2009 through and including July 15, 2014, in the County of Riverside, State ,of California, the defendants did willfully and unlawfully make and cause to be made a knowingly false and fraudulent material statement and material representation, to wit, INDEMNITY for the purpose of obtaining and denying compensation,- as de?ned in Labor Code sectiOn 3207; COUNT34 For a-further and separate cause of action, being a different offense from but connected in its commission with the charges set. forth in counts 1 thrOugh 33 hereof, the Criminal Grand Jury of the County of?Riverside by this Indictment hereby accuses PEYMAN HEIDARY and CARY DAVID ABRAMOWITZ and ANA SOLIS and GLADYS ROSS of a violation of Insurance Code section "1871.4, subdivision subsection (1), a felony,?in that on or about January 1, 2009 through and including July 15, 2014, in the County of Riverside, State of I California, the defendants did willfully and unlawfully make and cause to be made a knowingly false and fraudulent material statement and material representatien, to wit, to STATE COMPENSATION INSURANCE FUND (SCIF), for the purpose of obtaining and denying compensation, as?de?ne?d in Labor Code section 3207. It is ?lrther?alleged that in the commission and attempted Commission of the above offense the said defendants, PEYMAN HEIDARY and CARY DAVID ABRAMOWITZ and ANA SOLIS ROSS, with the intent so to damaged ?and destroyed A property of a value'exceeding? $200,000, within the meaning of 'Penal Code section 12022.6, I COUNT35 For a further and separate cause?of action, being a different offense from but connected in its commission with the charges set forth in counts ,1 thrOugh 34 hereof, the Criminal Grand 'Jury of-tlie County of Riverside by this Indictment herebyaCcuses PEYMAN HEIDARY and - CARY DAVID ABRAMOWITZ and and GLADYS ROSS of a violation of Insurance Code section 1871.4, subdivision subsection (1), a felony, in that on or about January 1, 2009 through and including: July 15', 2014, in'the County of Riverside, State of ?17 36? MICHAEL A. HESTRIN County of Riverside State ofCallfornla California, the defendants did willfully and unlawfully make and cause to be made a knowingly false and fraudulent material statement and material representation, to wit, to TRAVELERS INSURANCE, for the purpose of obtaining and denying compensation, as de?ned in Labor Code section 3207. It is ?irther alleged that in the commission and attempted commission of the above offense the said defendants, PEYMAN HEIDARY and CARY DAVID ABRAMOWITZ and ANA SOLIS and GLADYS ROSS, with the intent so to do, took, damaged and destroyed pr0perty of a value exceeding sixty ?ve thousand dollars within the meaning, of Penal Code section 12022.6, subdivision subsection (1). COUNT 36 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 35 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses TOUBA and QUYNAM NGUYEN and JASON YANG of a Violation of Insurance Code section 1871.4, subdivision subsection (1), a felony, in that on or about January 1, 2009 through and including July 15, 2014, in the County of Riverside, State of California, the defendants did will?illy and unlawfully make and cause to be made a knowingly false and fraudulent material statement and material representation, to wit,'to ZENITH INSURANCE for the purpose of obtaining and denying compensation, as de?ned in Labor Code section 3207. COUNT 37 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in?counts 1 through 36 hereof, the Criminal Grand Jury?of the County of Riverside by this Indictment hereby accuses TOUBA PAKDEL-NABATI and QUYNAM NGUYEN and JASON YANG of a violation of Insurance Code section 1871.4, subdivision subsection (1), a felony, in that on or about January 1, 2009 through and including July 15, 2014, in the County of Riverside, State of California, the defendants did willfully and unlawfully make and cause to be made a knowingly false and fraudulent material statement and material representation, to Wit, to ZURICH for the purpose of obtaining and denying compensation, as de?ned in Labor Code section 3207. COUNT 38 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 37 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses TOUBA and QUYNAM JASON YANG of a violation of section 549 of the Penal Code, a felony, in that on or about January 1, 2009 through and including July 15, 2014, in the County of Riverside, State of California, the defendants, did willfully and unlawfully solicited, 18 1 accepted, or referred any business to or from any individual entity with the knowledge that, or 1 ?2 reckless disregard for Whether, the individual or entity for er from Whom: the solicitation or 3 i referral is made, or the individual or entity who is solicited? or referred, intended to Violate 4. section 550. of the Penal Code or section 1871.4 of the InsuranCejCode; 5 It is further alleged that the said defendants, TOUBA and 6 QUYNAM and AS ON committed tho or more related felonies, .amaterial element .of which-Was fraud or embezzlement, which involved a pattern'of related felony 8 Conduct, and this pattern of related felony conduct involved. the taking of more five - 9 hundred thousand dollars Within the meaning of Penal Code sectidn 186.11, 10 subdivision subsection (2). 1 1 Special Allegati'on: Zamora i 12 It is ?irther alleged that the above offense was not discovered b'ythe ?victim(s) until 13 March.26, 2012, when the State Compensation Insurance Fund Investigator Phillis Shorts 14 I beganwher inquiry into suspicious circumstances of fraudulentlactivityh 15' ?7 . Investigator Phillis Shorts discovered the fraudulent activity during an investigative 116 review into three individual worker?s compensation claimant ?les who all ?used the same I. 17 attorney service. and who Were all treated by providers associated with clinics owned and 18 operated by Peyman Heidary. . 19 On or-about August 28, 2012, SCIF Investigator. Phillis Shorts referred her ?ndings to 20 an inter-agency'team including the Office of the Riverside'County District Attorney. Further 21 - investigation by the Riverside County District Attorney uncovereda?highly sophisticated 22 A criminal organization. Over an approximately two year period, the investigation discovered I 23 the use of cappers, law of?ces, and? health clinics operated by support staff, chiropractors, 24 i and medical doctors all working as directed bvaeyman Heidary to bill for similar services 25? and treatment regardless of injury. I l? . 26 The scheme was not discovered prior to SCIF Investigator Phillis Shorts?. ?ndings due ?27 to multiple layers of ownership and control, voluminous legal ?les, medical records, billing 28 involving hundreds of patient victims, and multiple regulatory violations overseen by 29 multiple enforcement agenciesMICHAELAHESTRIN 19 . . Stat?ofCalifornla, . The Of?ce of the Riverside COunty District AttOmey ?led a c?min?l eom?laint in case number RIF 14.09778 against Peymari Heidary, Cary Abramowitz, Michael Tuosto, and Erica Torres on July 25, 2014. (Peoplejv. Zamora (1976) 18 Ca1_.3d 538.) May 16, 2016 MICHAEL A. HESTRIN District Attorney \omxloxuujzuowt?t i??O JAztc '36 MICHAEL A. HESTRIN DISTRICT ATTORNEY County of Riverside . 20 State of California 1 Names of witnesses examined by the Criminal Grand Jury on ?nding of the foregoing 2 Indictment: I 3 Kathan Lambert . 4 Erica Torres 5 Dennis Knotts 6 Jennifer Delgado 7 Angelica Celis '8 Sandra Rubalcaba 9 ?Todd Loveless i 10 Gissel Santibanez 1 1 Yamileth Petway 12 Ana sons 13 Yazmine Martinez. 14 Erica Lopez 15 Lany Roldan 16 Alejandra Palmerin 17 Corrine Guevara 18 Angelica Juarez 19 Banuelos 20 Perla Arroyo 7 21 Craig Johnson 22 Scott Adam 23 Clayton Johnson 24 Touba Pakdel-Nabati 25 Peter Park 26 Agatha Beltran 27 Eugene Sung 28 Kelly Ayers 29 Gladys Ross 30 Isidro Ramirez 31 Denise Rivera 32 Birender Singh 33 Jasmin Ballesteros 34 Oliver Glover 3 5 Janine Farrell 36 Daniel Gancourz oeunmmvem 21 State ofCalifomia 36 MICHAEL A. HESTRIN County of Riverside State of California HA Kristian Nielsen Ronda Loyd Danny Tran Jill Landeros Roger Gutierrez Maria Kramer Gina Gribble Anthony Hurtado A Gordon Oard Aaron Lewis Phillis Shorts Fidel Borr?go; Anne Luce Glen Smith DonTerrell obnAuirenin' Nicole snllivan Chris Dill Beeher Yanti S'omnan Denise Magdalene Ku'rt Lackinan. Sean Nealy John Standish David wall James Fisher (Kerry O?Brien- Lawrence Westcott Quynarn Nguyen Jason Yang Tushar Doshi Diane Zimmerman I Jennifer Finch James Munoz Tamara Cooper June Trujillo ?22 36 MICHAEL A. HESTRIN ATTORNEY County of Riverside State of California Mercedes Hernandez. Jasmine Valadez A TRUE BILL: Forepereon of the Criminal GrandiJilry 23 I MICHAEL A. HESTRIN 3 District Attorney 4 County'of Riverside 5 3960 Orange Street, First Floor 6 Riverside, California 92501 7 955-5400 8 01111 Aki - y. I 9 Chief Assistant District Attorney 10 State Bar No. 189395 SUPERIOR COURT OF CALIFORNIA 14 COUNTY OF RIVERSIDE 15 (RiversideTHE PEOPLE OF THE STATE OF CALIFORNIA, Case No. . 18 PlaintiffTOUBA PAKDEL-NABATI PROSECUTION DISCOVERY - 22. - DOB: 08/03/1978 (Pen. Code, 1054.3, 23. . 1054.5(a) I 24 QUYNAM NGUYEN 25. DOB: 06/11/1958 YANG 28 DOB: 02/24/1966 29 Defendants. 30 7 - . 31 TO: HONORABLE JUDGE OF THE SUPERIOR COURTS AND TO - 32 COUNSEL FOR ABOVE-NAMED 33 PLEASE BE INFORMED that?the "Of?ce of the District Attorney of Riverside'County, 34 acting on behalf of the Plaintiff, the People of the State of California, hereby .35 requests/moves for discovery/diSCIOSure of the following items from the defendants and 3 6 defendants intend to call as witnesses at trial; MICHAEL A.I1ESTRIN County ofRiverside 24 . State ofCallfornia .36 MICHAEL A. HESTRIN DISTRICT ATTORNEY County of Riverside . State of California 2. Any relevant written or recorded statements of the persons in N0. 1 above and/ or reports of the statement of such persons; . 3. Any reports or statement of experts made in connection with this case, including, but not limited to, the results of physical or mental examinations, scienti?c tests, experiments, or comparisons which the defendant or counsel intend to offer as evidence at the trial of this case; and I 4. Any ?real,? tangible or physical, evidence which the defendant or counsel intends to offer in evidence at the trial. PLEASE TAKE NOTE that pursuant to the provisions of Penal Code section 1054.5(b) if the above material and information requestedis not provided to counsel for the plaintiff within 15 days of this request, a court order will be sought to enforce the provisions of Penal Code section 1054.3. Dated: May 16, 2016 Respectfully submitted, MICHAEL A. HESTRIN District Attorney AKI . Assistant District Attorney JA:tc 25 36 MICHAEL A. HESTRIN DISTRICT ATTORNEY County of Riverside State ofCalifornla 26