CASH BOND 
RECOMMENDED: $25 000.00
WARRANT

 

MICHAEL A. HESTRIN
DISTRICT ATTORNEY

SUPERIOR COURT OF CALIFORNIA
COUNTY OF RIVERSIDE
(Riverside)
THE PEOPLE OF THE STATE OF CALIFORNIA, 361668
Plaintiff, CASE NO.
FELONY COMPLAINT
TUSHAR RAMNIK DOSHI
DOB: 07/19/1956 OTHER - SPS

Defendant.

 

 

COUNT 1

The undersigned, under penalty of perjury upon information and belief, declares: That the above named
defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 ACE, and the claim and
amount at issue exceeded Nine Hundred Fifty dollars ($95 0) 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
defendant, TUSHAR RAMNIK DOSHI, with the intent so to do, took, damaged and destroyed prOperty of a
value exceeding $3,200,000, within the meaning of Penal Code section 12022.6, subdivision subsection (4).

COUNT 2

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant did willfully and unlawfully and
knowingly make and cause to be made a false and fraudulent claim for payment of a health care benefit, to wit,
from AMERICAN INTERNATIONAL GROUP (AIG), 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
defendant, TUSHAR RAMNIK DOSHI, 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 3

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant did willfully and unlawfully and
knowingly make and cause to be made a false and fraudulent claim for payment of a health care benefit, 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 five years and six month consecutive period.

It is further alleged that in the commission and attempted commission of the above offense the said
defendant, TUSHAR RAMNIK DOSHI, 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 4

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant did willfully and unlawfully and
knowingly make and cause to be made a false and fraudulent claim for payment of a health care benefit, to wit,
from CNA INSURANCE, 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
defendant, TUSHAR RAMN 1K DOSHI, 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 5

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 CALIFORNIA RESTAURANT MUTUAL BENEFIT CORPORATION 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
defendant, TUSHAR RAMN 1K DOSHI, 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 6

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 CRUM FORESTER, 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 ($95 0) 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
defendant, TUSHAR RAMNIK DOSHI, 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 7

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 EMPLOYERS, 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 ($95 0) 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
defendant, TUSHAR RAMNIK DOSHI, 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 8

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 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 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
defendant, TUSHAR RAMNIK DOSHI, 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 9

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant did willfully and unlawfully and
knowingly make and cause to be made a false and fraudulent claim for payment of a health care benefit, 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 five years and
six month consecutive period.

It is further alleged that in the commission and attempted commission of the above offense the said
defendant, TUSHAR RAMNIK DOSHI, 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 10

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant did willfully and unlawfully and
knowingly make and cause to be made a false and fraudulent claim for payment of a health care benefit, 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
defendant, TUSHAR RAMNIK DOSHI, 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 11

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 HARTFORD, 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
defendant, TUSHAR RAMNIK DOSHI, 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 12

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant did willfully and unlawfully and
knowingly make and cause to be made a false and fraudulent claim for payment of a health care benefit, to wit,
from INSURANCE CARRIERS OF THE WEST (ICW), 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
defendant, TUSHAR RAMN 1K DOSHI, 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 13

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 ?ve years
and six month consecutive period.

It is further alleged that in the commission and attempted commission of the above offense the said
defendant, TUSHAR RAMNIK DOSHI, 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 14

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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.

It is further alleged that in the commission and attempted commission of the above offense the said
defendant, TUSHAR RAMNIK 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).

COUNT 15

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant did willfully and unlawfully and
knowingly make and cause to be made a false and fraudulent claim for payment of a health care benefit, to wit,
from STATE COMPENSATION INSURANCE FUND (SCIF), 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
defendant, TUSHAR RAMNIK DOSHI, 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 16

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant 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 TRAVELERS, 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 ($95 0) 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
defendant, TUSHAR RAMNIK DOSHI, 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 17

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant did willfully and unlawfully and
knowingly make and cause to be made a false and fraudulent claim for payment of a health care benefit, to wit,
from ZENITH, 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 ($95 0) 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
defendant, TUSHAR RAMNIK DOSHI, 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 18

That the above named defendant, TUSHAR RAMNIK DOSHI, committed 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 defendant did willfully and unlawfully and
knowingly make and cause to be made a false and fraudulent claim for payment of a health care benefit, to wit,
from ZURICH, 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
defendant, TUSHAR RAMNIK DOSHI, 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).

It is further alleged that the said defendant, TUSHAR RAMNIK DOSHI, committed two or more related
felonies, a material element of which was fraud or embezzlement, which involved a pattern of related felony
conduct, and this pattern of related felony conduct involved the taking of more than ?ve hundred thousand
dollars within the meaning of Penal Code section 186.11, subdivision subsection (2).

Special Allegation: Zamora

It is further alleged that the above offense was not discovered by the victim(s) until March 26, 2012,
when the State Compensation Insurance Fund Investigator Phillis Shorts began her inquiry into suspicious
circumstances of fraudulent activity.

Investigator Phillis Shorts discovered the fraudulent activity during an investigative review into three
individual worker?s compensation claimant files who all used the same attorney service and who were all
treated by providers associated with clinics owned and operated by Peyman Heidary.

On or about August 28, 2012, SCIF Investigator Phillis Shorts referred her ?ndings to an inter?agency
team including the Of?ce of the Riverside County District Attorney. Further investigation by the Riverside
County District Attorney uncovered a highly sophisticated criminal organization. Over an approximately two-
year period, the investigation discovered the use of cappers, law of?ces, and health clinics operated by support
staff, chiropractors, and medical doctors all working as directed by Peyman Heidary to bill for similar services
and treatment regardless of injury.

The scheme was not discovered prior to SCIF Investigator Phillis Shorts? findings due to multiple layers
of ownership and control, voluminous legal files, medical records, billing involving hundreds of patient victims,
and multiple regulatory violations overseen by multiple enforcement agencies.

The Of?ce of the Riverside County District Attorney filed a criminal complaint in case number
RIF1409778 against Peyman Heidary, Cary Abramowitz, Michael Tuosto, and Erica Torres on July 25, 2014.
(People v. Zamora (1976) 18 Cal.3d 538.)

 LAW

Information contained in the reports being distributed as discovery in this case may contain con?dential
information protected by Marsy?s Law and the amendments to the California Constitution Section 28. Any
victim(s) in any above referenced charge(s) is entitled to be free from intimidation, harassment, and abuse. It is
unlawful for defendant(s), defense counsel, and any other person acting on behalf of the defendant(s) to use any
information contained in the reports to locate or harass any victim(s) or the family or to disclose any
information that is otherwise privileged and con?dential by law. Additionally, it is a misdemeanor violation of
California Penal Code 1054.2a(3) to disclose the address and telephone number of a victim or witness to a
defendant, defendant?s family member or anyone else. Note exceptions in California Penal Code 1054.2a(a)
and (2).

I declare under penalty of perjury upon information and belief under the laws of the State of California
that the foregoing is true and correct.

Michael A. Hestrin
District Attorney

Dated: May 6, 2016

 

By: Erika L. Mulhere
Deputy District Attorney