COUNTY OF: ALLEGHENY COMMONWEALTH OF POLICE CRIMINAL COMPLAINT OF Hon. JAMES HANLEY . JR. VS- Magisterial District Number: 05-2-36 and ADDRESS): Address: 43?1 MURRAY AVENUE JOYCE ANN GALLAGHER LOWER LEVEL REAR First Name Middle Name Last Nana Gen. PITTSBURGH, PA 15217 412.521.??82 316 KRAMER WAY PETTSBURGH, PA 15211 559:3NCICg'EXtradition CodeTYlle Distance: Felony - Full Exttadition INFORMATION Pocket Number Dat Filed\ OTNILiveScan Number Number Request Lab Sewices? 824338'4 IF2018-0093 Yes GENDER FEMALE oo?a 07l01l1965 POB Add'l DOB Cooefendanus) RACE WHITE First Name Middle Name Last Name Gen. ETHNICITY AKA HAIRCOLOR snor ROWN) I EYECOLOR GRN (GREEN) I DNA Location Pregame'cta's'sm'caaoa F'latesiil State Hazmat StielgfI?mn Comm'l School 0th. Code 3:346 II Veh. Ind. Veh. as Def. VIN Year I Make Model Style Color I I Of?ce of the attorney for the Commnwealtl'tjApprovedD Disapproved because: (The attorney for the Commonwealth may require that the complaint, arrest warrant at?dadt. or both be approved by the attorney for the Commonwealth prior to ftiing. See Pa.R.Crim.P. 507). name of the attorney for the (Signature of the attorney for the Commonwealth) (Date) I, WILLIAM MCKEE 416- -. . .- - . (Name of the Affiant) (PSPIMPOEFC ~Assigned Attiant ID Number 8: Badge of ATTORNEY GENERAL pA02'224'00. (identify Department or Agency Represented and Politicat Subdivision) (Police Agency ORE Number) do hereby state: (check appropriate box) 1. accuse the above named defendant who lives at the address set forth above accuse the defendant whose name is unknown to me but who is described as i accuse the defendant whose name and popular designation or nickname are unknown to me and whom I have, therefore, designated as John Doe or Jane Doe with violating the penal laws of the Commonwealth of at 301 PETTSBURGH CITY (Subdivision Code) {Place-Politicat Subdivision) In Allegheny County 02 on or about 04/08/2014 12:00 (County Code) AOPC 412A - Rev. 07I18 Page 1 of 6 2% POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: OTNtLiveScan Number Numhe 824338-4 First: Middle: Last: JOYCE ANN GALLAGHER The acts committed by the accused are described below with each Act of Assembly or statute attegediy violated, if appropriate. When there is more than one offense, each offense should be numbered chronotogicaliy. (Set forth a brief summary of the facts suf?cient to advise the defendant of the nature of the offensefs) charged. A citation to the statute(s) allegedly violated. without more, Is not sufficient. in a summary case. you must cite the speci?c section(s) and subsection(s) of the statute(s) or ordinance(s) allegedly violated. In addition, sociat security numbers and ?nanctat information should not be tisted. If the identity of an account must he established. list only the East four digits. 204 ??213.1 213.7.) AOPC 412A - Rev. 09/08 Page 2 of 6 9% POLICE CRIMINAL COMPLAINT: Docket Number: Date Filed: OTNiLiveScan Number . umbe 824338-4 First: Middle: Last: 3 JOYCE ANN GALLAGHER I Attempt DSolicitation [:jConspiracy 1890118 1890214 18 903 A2 (lithe =18; F3 - Subsection PA Statute (litieI Counts Grade NCIC Offense Code UCRINIBRS Code Safety Zone Work Zone .. .. ?repairable . - Statute Description/Acts of the accused associated with this Offense; 18 4117A2 F3 4 COUNTS The actor, knowingly and with the intent to defraud an insurer or self-insured. namely UPMC insurance and/or its third party pharmaceuticai bene?ts manager Express Scripts. presented or caused to be presented to an insurer or self?insured a statement forming a part of, or in support of, an insurance claim that contained faise, incomplete or misleading information concerning a fact or thing material to an insurance ciaim, namely the Actor, presented various prescriptions for herself for the scheduled ii drugs Hydrocodone and OXyCOdone which were paid by UPMC andior Express Scripts purporting that they were properly prescribed andior authorized by Dr. Thomas Kramer, Dr. Sarah Davies, Dr. Patrick Friend, Dr. Smiga andior Dr. Martin Eichner, when in fact, the doctors did not prescribe and/or authorize such prescriptions, in violation of 18 . The actor, knowingiy and with the intent to defraud an insurer or seEf-insured, nameiy Highmark Insurance and/or its third party pharmaceutical bene?ts manager Express Scripts, presented or caused to be presented to an insurer or self?insured a statement forming a part of, or in support of, an insurance ciaim that contained faise. incomplete or misleading information concerning a fact or thing materiai to an insurance claim, namely the actor presented various prescriptions for the schedule it drugs Hydrocodone and Oxycodone which were paid by HigbmarkiExpress Scripts purporting that they were property presrlbed and/or authorized by Dr. Thomas Kramer, Dr. Sarah Davies, Dr. Patrick Friend, Dr. Eric Smiga andior Dr. Martin Eichner, when in fact, the doctors did not prescribe and/or authorize such prescriptions, in violation of 18 The actor, knowingly and with the intent to defraud an insurer or seif~insured, nameiy Highmark insurance andior its third party pharmaceutical benefits manager Express Scripts, presented or caused to be presented to an insurer orself?insured a statement forming a part of, or in support of, an insurance claim that contained iaise, incomplete or misleading information concerning a fact orthing material to an insurance claim, namely the actor presented various prescriptions tinder/using the name of her brother in-iaw (Joseph Petrone) for herself for the scheduied il drug Oxycodone which were paid by Petrone"s HighmarkiExpress Scripts coverage purporting that they were property prescribed andior authorized by Sarah Davies, Dr. Martin Eichner andlor Dr. Eric Smiga, when in fact, the doctors did not prescribe andlor authorize such prescriptions, in violation of '18 The actor, knowingly and with the intent to defraud an insurer or self?insured, namely UPMC insurance and/or its third party pharmaceutical bene?ts manager Express Scripts, presented or caused to be presented to an insurer or self?insured a statement forming a part of, or in support of, an insurance claim that contained false, incomplete or misleading information concerning a fact or thing materiai to an insurance claim, namely the actor presented various prescriptions under/using the name of her nephew (Anthony Petrone) for herself for the scheduled ii drug Oxycodone which were paid by Petrone"s UPMC/Express Scripts insurance coverage purporting that they were properly prescribed andior authorized by Dr. Sarah Davies, when in fact, the doctor did not prescribe and/or authorize such prescriptions, in vioiation of 18 AOPC 412A - Rev. 09(08 Page 3 of 6 POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: OTNILiveScan Number Numbe 824338-4 IF201850093 First: Middle: Last: JOYCE ANN GALLAGHER lnchoate Attempt [:JSolicitation DConspiracy Offense 18 901A 18 902 A 18 903 . Lead? Offensefi Section Subsection PA Statute (Title) Coums Grade NCIC Offense Code Code Data] Accident "Number . SafetyZone DWork Zone Statute DescriptionIActs of the accused associated with this Offense. 35 PROHIBITED ACTS 8 COUNTS The actor knowingly and intentionally acquired or obtained possession of Hydrocodone and Oxycodone. a controlled substance. from various pharmacies using her father"s name (Robert Gallagher) by misrepresentation. fraud. forgery, deception or subterfuge. in violation of 35 P.S. ?780?113(a) (12). The actor knowingly and intentionally acquired or obtained possession of Hyrocodone and Oxycodone, a controlled substance, from various pharmacies by misrepresentation. fraud. forgery. deception or subterfuge, in violation of 35 P.S. ?780~113(a) (12). The actor knowingly and intentionally acquired or obtained possession of Oxycodone. a controiied substance. from various pharmacies by misrepresentation, fraud. forgery. deception or'subterfuge. in violation of 35 P.S. ?780~113(a) (12). The actor knowingly and intentionally acquired or obtained possession of Oxycodone a controlled substance from various pharmacies by misrepresentation. fraud forgery, deception or subterfuge. in violation of 35 P. S. ~113(a) (12) The actor knowingly and intentionally acquired or obtained possession of Oxycodone and Hydrocodone. a controlled substance. from various pharmacies by misrepresentation, fraud. forgery, deception or subterfuge, in Violation of 35 RS. ?780-113(a) (12). The actor knowingly and intentionally acquired or obtained possession of Oxycodone, a controlled substance. from various pharmacies using her sister?s name (Donna Petrone) by misrepresentation. fraud. forgery, deception or subterfuge. in violation of 35 RS. ?780~113(a) (12). The actor knowingly and intentionally acquired or obtained possession of Oxycodone. a controlled substance, from various pharmacies using the name of her sister (Jamie Gallagher) by misrepresentation. fraud. forgery, deception or subterfuge. in violation of 35 53.8. ?780~113(a) (12). The actor knowingly and intentionally acquired or obtained possession of Hydrocodone. a controlled substance, from various pharmacies using the name of her sister (Karen Trego) by misrepresentation, fraud. forgery. deception or subterfuge, in violation of 35 13.8. ?780~113(a) (12). AOPC 412A - Rev. 09/08 Page 4 of 6 POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: OTNtLiveScan Number Number 3243334 $2013 0093: . First: Middle: . Last: JOYCE ANN GALLAGHER Inchoate Attempt DSolicitatton Offense 1903 Lead? . Section . Subsection PA Statute (Title) Counts Grade NCIC Offense Code UCRINIBRS Code . if'applloable) .. SafetyZOrte DWozk Zone Statute Desc?ptionIAots of the accused associated with this Offense: 18 3922M THEFT BY DECEPTION M2 1 COUNT The actor intenttonalty obtained or withheld property, nameiy monies with a total value greater than or equal to $50 and tees than $200, belonging to UPMC insurance/Express Scripts by deception1 in VloIatiOl?l of 18 Pa. 0.5. ?3922. Page 5 of 5 AOPC 412A - Rev. 09/08 li 3* POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: OTNiLiveScan Number Number 824338-4 iF2018 0093- T- 3i 5- :fi First: Middle: Defendant .. JOYCE ANN GALLAGHER 2. I ask that a warrant of arrest or a summons be issued and that the defendant be required to answer the charges I have made. 3. verify that the facts set forth' In this complaint are true and correct to the best of my knowledge or information and belief. This verification IS made subject to the penalties of Section 4904 of the Crimes Code (18 PA. C. ?4904) relating to unsworn falsification to authorities. 4. This complaint is comprised of the preceding page(s) numbered through 5. certify that this filing complies with the provisions of the Case Records Public Access Policy of the Unified Judicial System of that require confidential information and documents differently than nOn- -confidentiai information and documents. The acts committed by the accused as listed and hereafter were against the peace and dignity of the Commonwealth of and were contrary to the Act(s) of the Assembiy, or in violation of the statutes cited. (Before a warrant of arrest can be issued, an affidavit of probable cause must be completed sworn to before the issuing authority, and attached.) New 27,6w25? 3 KM, (Signature of Affiant) (Dale) AND NOW, on this date 21/5 1/ 2?7, ?25:7 f? i certify that the comptaint has been properly completed and veri?ed. An affidavit of probable cause must be completed before a warrant can be issued. \t {30 {Ci ?0 silq? mt (r .- \ka? c? gala .L-m sz I tdx?rj {:35 git I -.. . talk (\51 TX (Magisterial District Court Number) ()s?sei Agiif?rityt/ tit?) or: ca}? Ruth . - . witxaws it; Otil?diw "x t?Kt?i' nope 412A - Rev. 09:08 Page a of 2. 3. 4. POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: OTNiLiveScan Number Compialn?dlncident Number 824338-4 -IF2018 0093-. -- First: Middle: Last: JOYCE ANN GALLAGHER WHEN: Date when Af?ant received information: 031261201 8 03(26/2018 HOW: AFFIDAVIT of PROBABLE CAUSE b) Date when the source of information (Police Of?cers, Informant, Victim, (So-Defendant, Defendant, etc.) received information: How Af?ant knows this particular person commited crime: (personal observation, defendant's admissions, eta): witness interviews defendant's admissions How the source of information knows this particular person committed the crime: witness interviews defendant?s admissions How both Af?ant andr'or source of information knows that 8 particular crime has been commited: witness interviews defendani's admissions WHAT CRINIES: 18 3922 A1 THEFT BY DECEPTION 18 411? A2 INSURANCE FRAUD 35 780-113 A12 PROHIBITED ACTS 35 780-113 A12 PROHIBITED ACTS 35 780-113 A12 PROHIBITED ACTS 18 4117 A2 FRAUD 18 4117 A2 FRAUD 35 780-113 A12 PROHIBITED ACTS 18 4117 A2 INSURANCE FRAUD 35 780?113 A12 PROHIBITED ACTS 35 780-113 A12 PROHIBITED ACTS 35 780-113 A12 PROHIBITED ACTS 35 780?1 13 A12 PROHIBITED ACTS WHERE COMMITTED: 1185 MCKINNEY LANE. PITTSBURGH Page 1 of 13 POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: OTNiLiveScan Number Complamt?ncident Nu 824338-4 IF2018 0093 .. First: Middle: t. JOYCE ANN GALLAGHER 5. WHY AFFIANT BELIEVES THE SOURCE OF INFORMATION: Source is presumed reliabie, Le. other Police Of?cer, Eyewitness, Victim of Crime, etc. Source has given information in the past which has led to arrest andfor conviction Defendant's reputation for criminal activity This source made deciaration against h-isr?her penal interest to the above offense Af?ant and/or other Poiicc Officers corroborated details of the information Page 2 of 13 - - POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: OTNiLiveScan Number Number, 8243384 0093 =5 First: Middle: Last: - JOYCE ANN . GALLAGHER COMMONWEALTH OF VS JOYCE GALLAGHER COUNTY OF ALLEGHENY Date of Application: Date of Violations: On or about April 8, 2014 and dates thereafter Criminal Complaint No: Name ofAffiant: Special Agent William McKee Law Enforcement Agency: Office of Attorney General Insurance Fraud Section Western Regional Office Pittsburgh, PA A. Your Af?ant, who is employed as a Special Agent for the Office of Attorney General, insurance Fraud Section, Western Regional Office, located at 1251 Waterfront Place, Mezzanine Level, Pittsburgh. PA 15222, and who has been so employed since February 13, 2006, is the case agent assigned to the investigation involving the Actor, Joyce Gaiiagher. B. The investigation of the Actor was initiated by the Western Regional Cities of the insurance Fraud Section of the Of?ce of Attorney General based upon a referral of information to this office by Co-Afiiant James Embree, Narcotics Agent with the Office of Attorney General. On 3i26118 Narcotics Agent Jim Embree received a call from Dr. Eric Smiga of Pittsburgh Oral Surgery located at 5820 Centre Avenue, Pittsburgh. Dr. Smiga reported that he received two calls from two Pittsburgh area pharmacies regarding fraudulent prescriptions. The first from CVS Pharmacy located at 500 Brookline Blvd. stating that they had been filling prescriptions of Percocet 10f325, quantities of 25 tabiets for Joe Petrone, Donna Petrone and Anthony Petrone all listing 4493 Country Club Drive, Baldwin, 15236. Pharmacist Kerri Friess said that she is familiar with the Petrones and can identify them as the people picking up other prescriptions and paying for them with insurance Medea/Express Scripts. Dr. Smiga reviewed the prescriptions and observed that the prescriptions were his, but not authorized by him. and the three people were not his patients. Dr. Smiga also reported that fraudulent prescriptions were passedlfilied at the Giant Eagle located at the Parkway Center Mall. Pharmacist Liz (LNU) stated that the Actor, Robert Gallagher and Karen Trego eachhad prescriptions filled there which were all picked up by the Actor The prescriptions were written on Dr. Smiga? prescriptions but were not authorized by him. Or. Smiga said that Robert Galiagher and Karen Trego were never patients of his and that all the prescriptions in their names are COMPLAINT Docket Number: Date Filed: OTN/LiveScan Number Complaintl?lncident Number 1F 2018-0093 Defendant Name: First: JOYCE Middle: ANN Last GALLAGHER AOPC 412A Rev. W18 Page of fraudulent. Dr. Smiga reported that the Actor was a former employee and patient of his who left his practice about one year ago. Dr. Smiga, via Facebook, discovered that the Actor was friends with the Petrone family. Dr. Smiga said that he never issuediauthorized the Actor any prescriptions for Percocet 10/325 and that any prescriptions for her purportediy prescribed by him Page 3 of 13 $5 POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: OTNfLiveScan Number Number '5 824338-4. Ionis? 0093 . . .. H5 .2 First: Middle: Last: JOYCE ANN GALLAGHER are trauduient. C. Your Af?ants intervieWed the Actor and she provided the foltowing informaticn: - The Actor had surgery on her back severai years ago and was prescribed pain medication and therapy after the surgery. The doctors suddenly stopped prescribing the Actor pain medications and sent her to pain management. The Actor attended pain management for a while but did not like taking morphine 34 times per day. The effect of the morphine did not allow the Actor to function normaiiy and she was unabie to work. The pain management doctors offered h'er no other solution so she stopped attending pain management. 2. During this time the Actor was employed as an of?ce manager at the dental of?ce of Dr. Eric Smiga (Pittsburgh Orai Surgery). The Actor was employed there between 2013 thru 2016. Near the end of her employment at Dr. Smiga?s office the Actor took biank prescriptions from the office. The Actor began writing prescriptions for herself and members of her family in order to obtain Percocet. The Actor used the names of the doctors listed on the prescriptions purporting that the doctors prescribed her the Percocet. The Actor did this without the knowiedge of any of the doctors. of?ce staff members or her family. 3. The Actor passed fraudulent prescriptions for Percocet under her name, her father's name (Robert Gailagher), and her sister?s name (Karen Trego) at the Giant Eagle Pharmacy located at the Parkway Center Mali. The Actor paid the copays for the prescriptions under her father?s name and his Highmark insurance covered the rest. The Actor paid cash for the prescriptions she passed under her. sister?s name. The fraudulent prescriptions she passed under her own name were paid for by her Highmark insurance plan. 4. The Actor passed additionai fraudulent prescriptions for Percocet under the names other sister (Donna Petrone), Donna's husband (Joe Petrone). and their son (Anthony Petrone). The Actor had the prescriptions tilled at the CVS Pharmacies iocated at Brookline Blvd, Rt. 51. and Centre Avenue. The Actor paid the copays on ail the prescriptions and the remaining balances were paid by the Petrones? insurance coverage. The Actor did not know what insurance company was used, just that CVS had the Petrones' coverage information in their system because that is where the Petrones had their prescriptions tilted. 5. The Actor also passed fraudulent prescriptions for Percocet under the name of her sister (Jamie Gallagher). The Actor had these prescriptions at the Rite Aid Pharmacy located on Mt. Washington. The Actor paid the copays tor the prescriptions and the remaining amount was paid by POLICE COMPLAENT Docket Number: Date Filed: OTNfLiveScan Number Complaint/Incident Number iF 2018-0093 Defendant Name: First: JOYCE Middle: ANN Last GALLAGHER AOPC Rev 7/18 Page_ of_ her sister? insurance coverage. The Actor did not know what Insurance company was used, just that Rite Aid had Jamie's coverage information in their system because that is where she ?lled her prescriptions. 6. The Actor said that she was addicted to Percocet and that she obtained all of it for herself and did not sell or give any away. The Actor provided your Atfiants with approximately 70 blank prescriptions which she had located at her residence. Your Af?ants instructed the Actor to contact her PCP or a drug rehabilitation center immediately to get help for her addiction. D. The doctors of the Pittsburgh Oral Surgery Center provided your Atfiants with the following information: Page 4 of 13 POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: OTNiLiveScan Number Complalntlincldent Num 824338-4 IF2018 0093 - - First: Middle: Last: JOYCE ANN GALLAGHER 1. Dr. Eric Smiga, Dr. Sarah Davies Dr. Martin Eichner. Thomas Kramer and Dr. Patrick Friend ail provided a written statement re?ecting that they did not write andior authorize any prescriptions for Joyce Gatiagher, Robert Gailagher Jamie Gaiiagher Karen Trego or the Petrones (Donna. Joseph. and Anthony). E. Ati ant McKee interviewed the Actor' famiiy members and they provided the following information: 1. Robert Gaiiagher is the father of the Actor. Robert was not a patient of Pittsburgh Orat Surgery Center or any of the doctors empioyed at the practice. Robert was not prescribed any medications from any of the doctors at the practice and was unaware that his daughter (the Actor) had prescriptions for Oxycodone ?lled under his name. 2. Donna Petrone is the sister of the Actor and is married to Joseph Petrone. Joseph and Donna and their son. Anthony Petrone, were not patients of Pittsburgh Ora! Surgery Center or any of the doctors employed at the practice. The Petrones were not prescribed any medications from any of the doctors at the practice and were unaware that the Actor passed Oxycodone prescriptions under their names, including their son Anthony. Joseph was unaware that his Highmark insurance coverage paid for the prescriptions Joyce passed under his and Anthony's names. 3. Karen Trego is the sister of Joyce Gallagher. Trego has not lived in the Pittsburgh area for severai years. She was not a patient of Pittsburgh Oral Surgery Center or any of the doctors employed at the practice. Trego was not prescribed any medications from any doctors at the practice and was unaware that the Actor passed Oxycodone prescriptions under her name. Trego?s Aetna insurance was not used to pay for the prescriptions of Oxycodone. 4. Jamie Gaiiagher is the sister of the Actor. Jamie was not a patient of Pittsburgh Orat Surgery Center or any of the doctors employed at the practice. Jamie was not prescribed any medications from any of the doctors at the practice and was unaware that the Actor passed Oxycodone prescriptions under her name. POLECE CRIMINAL Docket Number: Date Filed: OTNiLiveScan Number Compiaintiincident Number iF 2018-0093 Defendant Name: First: JOYCE Middle: ANN Last GALLAGHER AOPC 412A Rev. "#18 Page of_ Jamie was unaware that her UPMC Heaith Pian insurance paid for the prescriptions the Actor passed under her name. F. Af?ant McKee interviewed Rick Shaheen and he provided the foiiowing information: 1. Shaheen is the Pharmacy Security Manager for Giant Eagle Pharmacy. 2. Shaheen provided a patient profile and copies of the Actor's prescriptions which she had at the pharmacy. The following chart detineates the prescriptions purportedly prescribed by Dr. Thomas Kramer: Dr. Patrick Friend and Dr. Sarah Davies. Date Pharmacy Rx. No. Medication Quantity Prescriber 4i8/2014 Giant Eagle-"r4 4313148 Hydrocodone 60 T. Kramer 4i29!2014 Giant Eagle-74 4313148 Hydrocodone 60 T. Kramer Giant Eagle-74 431392? Hydrocodone 60 T. Kramer ?/3i2014 Giant Eagie?74 431432? Hydrocodone 60 T. Kramer 8(5l2014 Giant Eagie?74 4314775 Hydrocodone 60 T. Kramer 8/23i2014 Giant Eagie?74 4314775 Hydrocodone 60 T. Kramer Page 5 of 13 4% POLICE CRIMINAL Docket Number: Date Filed: OTNiLiveScan Number Complaint?ncrdent Numbe 824338-4 0093 First: Middle: Last' 1. JOYCE ANN GALLAGHER 912212014 Giant Eagle?74 4315570 Hydrocodcne 60 T. Kramer 1011412014 Giant Eagle~74 2244250 Hydrocodone 90 T. Kramer 121212014 Giant Eagle-74 2244841 Hydrocodone 90 T, Kramer 1212912014 Giant Eagle?74 2245185 Hydrocodone 90 T. Kramer 112712015 Giant Eagle-74 2245574 Hydrocodone 90 T. Kramer 212712015 Giant Eagle-74 2242982 Hydrocodone 90 T. Kramer 411312015 Giant Eagle-74 2246527 Hydrocodcne 60 T. Kramer 1211712015 Giant Eagle-74 2249561 Oxycodone 20 P. Friend 41612016 Giant Eagie-74 2250849 Hydrococione 16 8. Davies 411212016 Giant Eagle-61 2283299 Hydrocodcne 15 P. Friend 71212016 Giant Eagle-74 2251779 Hydrocodone 20 P. Friend - 711212016 Giant Eagle-74 2251882 50' T. Kramer 712512016 Giant'Eagle-74 2252028 Hydrocodone 50 T. Kramer 1011212016 Giant Eagle-74 2252835 20 8. Davies 1212212016 Giant Eagle-61 2286805 Oxycodone 20 8. Davies TOTAL. 1141 2 The prescriptions listed in the above chart coincide with the prescriptions that were not prescribed and1cr authorized by Dr. Thomas Kramer Dr. Patrick Friend or Dr Sarah Davies. 3. Shaheen provided a patient pro?ie and copies of Robert Galiagher prescriptions which the Actor had ?iled at the Giant Eagle Pharmacy. The following chart delineates the prescriptions purportedly prescribed by Dr. Thomas Kramer. Dr. Patrick Friend Dr Sarah Davies and Dr. Eric Smiga. Fill Date Pharmacy Rx. No. Medication Quantity Prescriber 61812015 Giant Eagie-74 2247238 Hydrocodone 40 T. Kramer 912212015 Giant Eagie?74 2248479 Oxycodone 50 T. Kramer 1112412015 Giant Eagie-74 2249256 Hydrocodone 90 T. Kramer 611412016 Giant Eagle~40 2059979 Hydrocodone 20 E. Smiga POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: 11 I OTN1LiveScan Number Number IF 2018-0093 Defendant Name: First: JOYCE Middie: ANN Last GALLAGHER AOPC 412A Rev. 7118 Page of? 612712016 Giant Eagie-74 2251725 Hydrocodone 20 P. Friend 712612016 Giant Eagie-74 2252030 Hydrocodcne 40 T. Kramer 911812016 Giant Eagie?74 2252602 Oxycodone 20 E. Smiga 1112612016 Giant Eagle?74 2253258 Hydrocodone20 8. Davies TOTAL: 300 Page 6 of 13 ?it POLICE CRIMINAL COMPLAINT DocketNumber: Date Filed: OTN/LiveScan Number tribe 824338-4 First: Middle: Last: JOYCE ANN GALLAGHER ?2 The prescriptions listed in the above chart coincide with the prescriptions that were not prescribed and/or authorized by Dr. Thomas Kramer, Dr. Patrick Friend, Dr. Sarah Davies or Dr. Eric Smiga. . 4. Shaheen provided a patient profile and copies of Karen Trego?s prescriptions which the Actor had ?lled at the Giant Eagle Pharmacy. The following chart delineates the prescriptions purportedly prescribed by Dr. Patrick Friend, Dr. Sarah Davies and Dr. Eric Smiga. Fill Date Pharmacy Rx No. Medication Quantity Prescriber 5/12/2016 Giant Eagle?74 2251246 Hydrocodone 20 P. Friend 5/18/2016 Giant Eagle-40 2251337 Hydrocodone 15 P. Friend 8/10/2016 Giant Eagle?74 2061186 Hydrocodone 20 E. Smiga 12/7/2016 Giant Eagle-74 225338 7 Hydrocodone 20 8. Davies TOTAL: 75 The prescriptions listed in the above chart coincide with the prescriptions that were not prescribed and/or authorized by Dr. Patrick Friend. Dr. Sarah Davies or Dr. Eric Smiga. Af?ant McKee interviewed Kerri Friess and she provided the foilowing information: 1. Friess is a Registered Pharmacist (RPH) and is employed at CVS Pharmacy on Brookiine Blvd. in Pittsburgh. 2. Friess provided a patient profile and copies of the Actor's prescriptions which she had filled at CVS pharmacy. The foilowing chart detineates the prescriptions purportedly prescribed by Dr. Patrick Friend, Dr. Sarah Davies, Dr. Martin Eichner and Dr. Eric Smma Fili Date Pharmacy Rx. No. Medication Quantity Prescriber 5/19/2016 CVS-2333 1116370 Hydrocodone 20 P. Friend 5/28/2016 1118703 Hydrocodone 20 P. Friend 9/8/2017 977805 Oxycodone 25 8. Davies 10/17/2017 (NS-3189 1317749 Oxycodone 25 M. Eichner 12/13/2017 1332426 Oxycodone 25 E. Smiga 1/20/2018 CVS-2333 1288980 Oxycodone 25 E. Smiga TOTAL: 140 The prescriptions listed in the above chart coincide with the prescriptions that were not prescribed and/or authorized by Dr. Patrick Friend, Dr. Sarah Davies, Dr. Martin Eichner or Dr. Eric Smiga POLICE CRIMINAL COMPLAENT Docket Number: Date Filed: OTN/LiveScan Number Complaint/Incident Number iF 2018-0093 Defendant Name: First: JOYCE Middle: ANN Last GALLAGHER AOPC 412A - Rev. 7/?8 Page of__ 3. Friess provided a patient pro?le and copies of Donna Petrone's prescriptions which the Actor had tilted at CVS pharmacy. The fotiowing chart delineates the prescriptions purportedly prescribed by Dr. Sarah Davies and Dr. Eric Smiga. Filt Date Pharmacy Rx. No. Medication Quantity Prescriber Page 7 of 13 . .- POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: OTN/LiveScan Number Complaint/Incident Numbe - 824338-4 0093 First: Middle: L331: JOYCE - . ANN GALLAGHER 9/21/2016 (NS-4085 423431 Oxyoodone 20 8. Davies 5/9/2017 1213513 Oxycodone 20 8. Davies 5/17/2017 1215666 Oxycodone 20 8. Davies 5/24/2017 CVS-3189 1282009 Oxycodone 20 E. Smiga 7/12/2017 1292535 25 8. Davies 7/17/2017 961741 Oxycodone 25 E. Smiga 7/23/2017 CVS-3189 1294637 Oxycodone 25 E. Smiga 8/10/2017 1299289 Oxycodone 25 8. Davies 8/2?1/2017 CVS-3189 1302065 Oxycodone 25 E. Smiga 8/28/2017 1243440 Oxycodone 25 E. Smiga 10/3/2017 1313807 Oxycodone 25 8. Davies 10/12/2017 CVS-3189 1316374 Oxycodone 25 8. Davies 10/27/2017 CVS-4369 994027 Oxycodene 25 8. Davies 11/19/2017 504142 Oxycodone 25 8. Davies 12/11/2017 (NS-3189 1331741 Oxycodone 25 8. Davies 12/19/2017 CVS 2333 1278669 Oxycodone 25 E. Smiga . 12/30/2017 Oxycodone 25 Smiga 1/9/2018 CVS- 3189 1338851 Oxycodone 25 8 Davies 1/20/2018 CVS 3189 1341911 Oxycodone 25 E. Smiga 2/1/2018 CVS-3189 1345538 Oxycodone 25 8. Davies 2/12/2018 (NS-3189 1348544 Oxycodone 25 E. Smiga 2/23/2018 1032674 Oxycodone 25 8. Davies 3/1/2018 1034701 Oxycodone 25 E. Smiga 3/12/2018 CVS-4144 527258 Oxycodone 25 E. Smiga 3/20/2018 CVS-3189 1359065 Oxycodone 25 5. Davies TOTAL: 605 The prescriptions tisted in the above chart coincide with the prescriptions that were not prescribed and/or authorized by Dr. Sarah Davies or Dr. Eric Smiga - 4. Friess provided a patient profile and copies of Joseph Petrone' prescriptions which the Actor had filled at CVS pharmacy. The following chart delineates the prescriptions purportedly prescribed by Dr. Sarah Davies Dr. Martin Eichner and Dr. Eric Smiga. Fill Date Pharmacy Rx. No Medication Quantity Prescriber 5/31/2017 3189 1283436 Oxycodone 25 8. Davies 6/6/2017 CVS-4369 950907 Oxycodone 20 8. Davies 8/4/2017 1297696 Oxycodone 25 M. Eictmer 8/18/2017 CVS-4369 971260 Oxycodone 25 E. Smiga 9/5/2017 976663 Oxycodone 25 8. Davies 9/16/2017 493772 Oxycodone 25 E. Smiga 10/23/2017 2333 1260818 Oxycodone 25 8. Davies 2/8/2018 CVS 3189 1347581 Oxycodone 25 E. Smiga 3/1/2018 CVS- 3189 1353572 Oxycodone 25 E. Smiga 3/16/2018 1307103 Oxycodone 25 Smiga POLICE CRIMINAL COMPLAINT Docket Number: Date Fited: OTN/LiveScan Number Page 8 of 13 POLICE CRIMINAL COMPLAINT Docket Number: - Date Filed: OTN/LiveScan Number Complalnt/lnCIden 'Numbe 6 3243334 iF2018 -. - First: Middle: Last' t. JOYCE ANN GALLAGHER Complaint/incident Number iF 2018?0093 Defendant Name: First: JOYCE Middle: ANN Last GALLAGHER AOPC 412A Rev. 7/18 Page of? 3/25/2018 CVS-3189 1360141 Oxycodone 25 8. Davies TOTAL: 270 - The prescriptions listed In the above chart coincide with the prescriptions that were not prescribed and/or authorized by Dr. Sarah Davies Dr Martin Eichner or Dr. Eric Smiga 5. Friess provided a patient profile and copies of Anthony Petrone's prescriptions which the Actor had ?lled at CVS pharmacy. The foilowing chart delineates the prescriptions purportedly prescribed by Dr. Sarah Davies. Fiil Date Pharmacy Rx. No. Medication Quantity Prescriber 10/2/2016 CNS-2333 1150558 Oxycodone 20 S. Davies 8/29/2017 CNS-4369 974697 Oxycodone 25 8. Davies TOTAL: 55 2 The prescriptions iisted an the above chart coincide with the prescriptions that were not prescribed and/or authorized by Dr. Sarah Davies. H. Affiant McKee interviewed William Ashton and he provided the following information: 1. Ashton is a Registered Pharmacist (RPH) and is employed at Rite Aid Pharmacy' In South Side. 2 Ashton provided a patient profile and copies of the Actor?s prescriptions which she had flied at Rite Aid pharmacy The following chart delineates the prescriptions purportedty prescribed by Dr. Patrick Friend Dr. Sarah Davies Dr. Eric Smiga and Dr. Thomas Kramer. - Fili Date Pharmacy Rx No. Medication Quantity Prescriber 12/4/2015 Rite Aid-4965 749151 Oxycodone 12 8. Davies 4/21/2016 Rite Aid? 4965 772412 Hydrocodone 20 P. Friend 12/30/2016 Rite Aid- 4965 813153 Oxycodone 20 E. Smiga 2/23/2017 Rite Aid 4965 822404 Oxycodone 40 T. Kramer 11/22/2017 Rite Aid- 4965 866982 Oxycodone 25 M. Eichner TOTAL: 117 The prescriptions listed in the above chart coincide with the prescriptions that were not prescribed and/or authorized by Dr. Sarah Davies. Dr. Patrick Friend. Dr. Eric Smiga or Dr. Thomas Kramer. Afiiant McKee interviewed Keici Novak and she provided the ioliowing information: 1. Novak is a Registered Pharmacist (RPH) and is employed at Rite Aid Pharmacy on Mt. Washington. 2. Novak provided a patient profile and copies of Jamie Gallagher 3 prescriptions which the Actor had lied at Rite Aid pharmacy. The toltowing chart delineates the prescriptions purportediy prescribed by Dr. Sarah Davies Dr. Eric Smiga and Dr. Martin Eichner. POLICE COMPLAINT Docket Number: Date Filed: OTN/LiveScan Number Complaint/Incident Number Page 9 of 13 . POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: CTN/LiveScan Number Complaint/mettle mbe . 824338-4 First: Middle: Last: JOYCE ANN GALLAGHER IF 2018~0093 Defendant Name: First: JOYCE Middle: ANN Last GALLAGHER AOPC 412A - Rev. 7/18 Page of__ Fill Date Pharmacy Rx No. Medication Quantity Prescriber 10/8/2017 Rite Aid-4965 859022 Oxycodone 25 M. Eichner 40/12/2017 Rite Aid?4965 880002 Oxyoodone 25 E. Smiga 11/8/2017 Rite Aid-4965 864579 Oxycodone 25 M. Eichner 11/26/2017 Rite Aid-4965 867223 Oxycodone 25 M. Eiohrier 12/19/2017 Rite Aid-10943 317339 Oxycodone 25 8. Davies 1/13/2018 Rite Aid?4965 875199 Oxycodone 25 E. Smiga 2/2/2018 Rite Aid?4965 878826 Oxyoodone 25 E. Smiga 2/14/2018 Rite Aid-4965 880725 Oxycodone 25 E. Smiga 3/6/2018 Rite Aid-4965 883851 Oxycodone 25 E. Smiga 3/13/2018 Rite Aid~4965 885247 Oxycodone 25 M. Eichner TOTAL: 250 The prescriptions listed in the above chant coincide with the prescriptions that were not prescribed and/or authorized by Dr. Sarah Davies, Dr. Eric Smiga or Dr. Martin Eichner. J. Tammy DeCecco of UPMC Insurance Special investigations Unit provided the foilowing information: 1. The Actor was covered by UPMC Insurance from 3-1-14 through 4430-17. 2. A UPMC prescription profile was obtained of prescriptions for the Actor that were purportedly prescribed by Dr. Sarah Davies, Dr. Patrick Friend. Dr. Thomas Kramer and Dr. Eric Smiga and billed to and paid by UPMC. The information is delineated in the following chart: Date serviced Pharmacy Prescriber Rx Number Medication Strength Qty Amount 4/8/2014 Giant Eagle 0074 T. Kramer 4313148 Hydrocodone 7.5?325mg 60 10.32 4/29/2014 Giant Eagle 0074 T. Kramer 4313148 Hydrocodone 75-325 60 10.32 6/5/2014 Giant Eagle 0074 T. Kramer 4313927 Hydrocodone 75-325 60 2.3 7/3/2014 Giant Eagle 0074 T. Kramer 4314327 Hydrocodone 75-325 120 2.3 7/19/2014 Walmart 5040 E. Smiga 4440129 Hydrocodone 7.5?325 15 0 7/25/2014 Walmart 5040 E. Smiga 4440244 Hydrocodone 75?325 15 0 8/5/2014 Giant Eagle 0074 T. Kramer 4314775 Hydrocodone 75-325 120 2.3 8/23/2014 Giant Eagle 0074 T. Kramer 4314775 Hydrocodone 75?325 120 2.3 9/22/2014 Giant Eagle 0074 T. Kramer 4315570 Hydrocodone 7.5-325 60 1.51 10/14/2014 Giant Eagle 0074 T. Kramer 2244250 Hydrocodone 75-325 90 9.01 11/4/2014 Waimart 1770 T. Kramer 2238108 Hydrocodone 7.5?325 90 8.26 12/29/2014 Giant Eagle 0074 T. Kramer 2245185 Hydrocodone 75?325 90 9.01 1/27/2015 Giant Eagle 0074 T. Kramer 2245574 Hydrocodone 75?325 90 24.5 2/27/2015 Giant Eagle 0074 T. Kramer 2245982 7.5325 90 24.5 4/13/2015 Giant Eagle 0074 T. Kramer 2246527 Hydrocodone 75-325 60 11.59 12/4/2015 Rite Aid 4965 8. Davies 749151 Oxycodone 5-325 12 0 12/17/2015 Giant Eagle 0074 P. Friend 2249561 Oxycodone 10-325 20 8.66 Page :10 of 13 POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: OTN/LiveScan Number - 824338-4 . . First: Middle: Last: JOYCE ANN GALLAGHER 4/6/2016 Giant Eagle 0074 8. Davies 2250849 Hydrocodone 10-325 16 0 4/12/2016 Giant Eagle 0074 P. Friend 2283299 Hydrocodone 7.5-325 15 0 4/21/2016 Rite Aid 4965 P. Friend 772412 Hydrococione 10625 20 0 CRIMINAL COMPLAINT Docket Number: Date Filed: OTN/LiveSoan Number Complaint/Incident Number iF 2018-0093 Defendant Name: First: JOYCE Middie: ANN Last GALLAGHER AOPC 412A Rev. 7/18 Page of_ 6/20/2016 Walmart 2281 P. Friend 2222405 Hydrocodone 10-325 20 0 7/2/2016 Giant Eagle 0074 P. Friend 2251779 Hydrocodone 10-325 20 0 7/12/2016 Giant Eagle 0074 T. Kramer 2251882 Hydrocodcne 10?325mg 50 2.1 7/25/2016 Giant Eagle 0074 T. Kramer 2252028 Hydrocodone 7.5?325mg 50 6.62 9/3/2016 Hometown 8. Davies 2005949 Oxycodone 10?325 20 6.66 10/12/2016 Giant Eagle 0074 S. Davies 2252835 Oxycodone 10?325 20 6.66 12/14/2016 Walmart 5040 E. Smiga 2230765 Oxycodone 10-325 20 6.66 12/22/2016 Giant Eagle 0061 3. Davies 2286805 Oxycodone 10-325 20 6.66 12/30/2016 Rite Aid 4965 E. Smiga 813153 Oxycodone 10-325 20 6.66 2/23/2017 Rite Aid 4965 T. Kramer 822404 Oxycodone 5mg 40 0.45 4/17/2017 Giant Eagle 0074 E. Smiga 2254604 Oxycodone 10-325 25 4.47 4/27/2017 Giant Eagle 0074 E. Smiga 2254710 Oxycodcne 10-325 20 1.73 TOTAL: 1548 175.55 '2 The prescriptions listed in the above chart coincide with the prescriptions that were not prescribed and/or authorized by Dr. Sarah Davies. Dr. Eric Srniga. Dr. Patrick Friend and Dr. Thomas Kramer. K. Robert Krah of Highmark Insurance Special Investigations Unit provided the foiiowing information: 1. The Actor's coverage with Highmark began on 7/1/17 and is still in effect. L. Michelle Garmon of Express Scripts? Litigation Services provided the following information: 1. Express Scripts is a third party pharmacy benefits manager for Highmark insurance and UPMC insurance. 2. Garmon provided an Express Soripts/Highmark prescription profile of prescriptions which the Actor had ?tled that were purportedly prescribed by Dr. Sarah Davies, Dr. Eric Smiga and Dr. Martin Eichner which were bitled to and paid by Express Scripts/Highmark. The information is delineated in the following charts: Date Serviced Pharmacy RX No. Medication Strength Qty Prescriber Amount Paid Copay 9/8/2017 CVS 04369 977805 Oxycodone 10?325 25 8. Davies 0 8 9/17/2017 Giant Eagle 0074 2256070 10-325 25 3. Davies 5.25 8 9/30/2017 Wairnart 2281 2225345 Oxyoodone 10-325 25 8. Davies 3.51 8 11/3/2017 Giant Eagle 0074 2256492 Oxycodone 10-325 25 8. Davies 6.08 8 11/11/2017 Walmart 2281 2225597 Oxycodone 10-325 25 E. Smiga 4.62 8 Page 11 of 13 . POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: OTN/LiveScan Number Complamt/inc de 'r'nbe i 824338-4 lF2018 0093 First: Middie: Last: JOYCE ANN GALLAGHER 11/22/2017 Rite Aid 4965 4325857 Oxycodone 10?325 25 M. Eichner 0 8 1/20/2018 CVS 02333 1288980 Oxycodone 10-325 25 E. 8miga 8 2/14/2018 Giant Eagle 0074 2257445 Oxycodone 10625 25 E. 8miga 6.01 8 2/20/2018 Giant Eagie 0074 2257501 Oxycodone 10-325 25 8. Davies 6.01 8 TOTAL: 225 - . The prescriptions iisted 'in the above chart coincide with the prescriptions that were not prescribed and/or authorized by these doctors. . POLICE CRIMENAL COMPLAINT Docket Number: Date Filed: OTN/LiveScan Number Complaint/incident Number iF 2018-0093 Defendant Name: First: JOYCE Middle: ANN Last GALLAGHER AOPC 412A -- Rev. 7/18 Page of? . 3. Carmen provided an Express Scripts/Highmark prescription profile of prescriptions which the Actor had fiiled under the name of Joseph Petrone for her own use that were purportedly prescribed'by Dr. Sarah Davies and Dr. Eric 8miga which were billed to and paid by Express Scripts/Highmark. The information is delineated in the foilowing charts: Date Serviced Pharmacy Rx. No. Medication Strength Qty Provider Amount Paid - 6/6/2017 CV8 04369 950907 Oxycodone 10?325mg 20 8. Davies 0 8/18/2017 CV8 04389 971260 Oxycodone 10-325 25 E. Smiga 4.25 9/5/2017 CV8 04369 976663 Oxycodone 10-325mg 25 8. Davies 0 9/16/2017 CV8 04144 493772 Oxycodone 10-325 25 E. Smiga 0 10/23/2017 CV8 02333 1260818 Oxycodone 10?325 25 8. Davies 0 TOTAL: 120 The prescriptions iisted In the above chart coincide with the prescriptions that were not prescribed and/or authorized by these doctors. 4. Garmon provided an Express Scripts/UPMC prescription prof Ie of prescriptions which the Actor had filled under the name of Anthony Petrone for her own use that were purportedly prescribed by Dr Sarah Davies which were biiled to and paid by Express Scripts/UPMC. The information is delineated in the following charts: Date Serviced Pharmacy Rx. No. Medication Strength Qty Provider Amount Paid 10/2/2016 CV8 02333 1550558 Oxycodone 10-325mg 20 8. Davies 0 8/29/2017 CV8 04369 974697 Oxycodone 10-325 25 8. Davies 4.25 TOTAL: 45 . . '7 The prescriptions iisted in the above chart coincide with the prescriptions that were not prescribed and/or authorized by Dr. Sarah Davies. Page 12 of 13 $5 POLICE CRIMINAL COMPLAINT Docket Number: Date Fitedi OTNILiveScan Number CompIaInUInCIdentNurnbe 8243384 .. . - .. Middle: Last: ANN GALLAGHER I WILLIAM MCKEE BEING DULY SWORN ACCORDING TO THE LAW, DEPOSE AND SAY THAT THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. I CERTIFY THAT THIS FILING COMPLIES WITH THE PROVISIONS OF THE CASE RECORDS PUBLIC ACCESS POLICY OF THE UNIFIED JUDICIAL SYSTEM OF THAT REQUIRE FILING CONFIDENTIAL INFORMATION AND DOCUMENTS DIFFERENTLY THAN INFORMATION AND DOCUMENTS. Lb} 444 If LW (Signature of Af?ant) -. .457" . Sworn to me and subscribed before this was] 7 day of 4703414? pip. 7c}{3 II I I Date /6 .Magisterial District qudge . 5 I as Ed}. E213 QT My commiSSion eXpireS firSt ?d8 (?Jame . E53. rm A FIJI-DI .1 ?i a I qgwi?fiwpxg?x?wm 0 (1Page 13 of 13