' ,.., :} 1 t:: Thomas E. Fraysse- SBN 1 R. Patrick Snook- SBN 1 KNOX RICKSEN LLP 1 Clay Street, Suite Oakland, CA 1-1 Telephone: (1) - Facsimile: (1) - Los" name="description"> ' ,.., :} 1 t:: Thomas E. Fraysse- SBN 1 R. Patrick Snook- SBN 1 KNOX RICKSEN LLP 1 Clay Street, Suite Oakland, CA 1-1 Telephone: (1) - Facsimile: (1) - Los">

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES I. INTRODUCTION

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1 l... c. --'... 1 so Q L.LI " 1 Vl 1 u > ' ,.., :} 1 t:: Thomas E. Fraysse- SBN 1 R. Patrick Snook- SBN 1 KNOX RICKSEN LLP 1 Clay Street, Suite Oakland, CA 1-1 Telephone: (1) - Facsimile: (1) - Los ANf:L{ ft D ERIOR COURT SEP. K JOHNA C KE, CLERK BYSHAUN Attorneys for Plaintiffs PEOPLE OF THE STATE OF CALIFORNIA, ex rei., ALLSTATE INSURANCE COMPANY, ALLSTATEINSURANCECOMPANY SUPERIOR COURT OF THE STATE OF CALIFORNIA PEOPLE OF THE STATE OF CALIFORNIA, ex rei. ALLSTATE INSURANCE COMPANY, ALLSTATE INSURANCE COMPANY vs. Plaintiffs, DANIEL H. DAHAN, an individual; PROGRESSIVE DIAGNOSTIC IMAGING, INC., a California Corporation; and DOES ONE through FIVE HUNDRED, inclusive, Defendants. FOR THE COUNTY OF LOS ANGELES Case No. C SLEY, Ep Ury COMPLAINT FOR VIOLATION OF CALIFORNIA INSURANCE FRAUDS PREVENTION ACT, VIOLATION OF THE CALIFORNIA UNFAIR COMPETITION ACT, FRAUD AND DECEIT, CONSTRUCTIVE TRUST, AND EQUITABLE LIEN; DEMAND FOR JURY TRIAL FILED IN CAMERA AND UNDER SEAL Plaintiffs Allstate Insurance Company (hereinafter "Allstate") and People of the State of California, ex rel. Allstate Insurance Company (hereinafter collectively "plaintiffs"), allege as follows: 1. I. INTRODUCTION ;gg n--to-t!'t'i:::a::i't'ii"t'i... CgJ'"Q!:(: onnog};:-;::r This is an action by Allstate Insurance Company to reco -ge 1!\cf. cjjtil c;:l :=-t: Co.l ('") I'T1 N CN penalties on its own behalf and on behalf of the People of the State of Califrnia ex l'd.si'ate C) :fxr --a (,.,1 ci (. Insurance Company, arising from an insurance fraud scheme planned and ca$ed ou'f g ;;, defendants involving the production of false and misleading medical reports and bills tci!supiort c.:-'1.. a- personal injury claims against insurance companies. As a direct result of the defendan!if'?fonduct,. I.

2 1 c.. -' ---' 1 '-L.l " 1 VJ 1 u - 1 e:: > ,.., "' --.- false and fraudulent claims have been made against insurance policies issued by Allstate and other insurance companies. As a further direct result of the defendants' conduct, Allstate has incurred substantial financial losses. Allstate, therefore, brings this action on its own behalf as well as on behalf of the People of the State of California to recover monetary damages and to enjoin, deter, and/or prevent the defendants, and each of them, from engaging in such conduct in the future.. The defendants have knowingly engaged in these illegal and fraudulent practices since 1. Defendants' conduct was and is in direct violation of California law including, but not limited to, California Penal Code Section ; the Moscone-Knox Professional Corporations Act, codified as California Corporations Code Section 1 et seq.; the California Insurance Frauds Prevention Act, codified as California Insurance Code Section I 1.; the California Unfair Competition Act, codified as California Business and Professions Code Section 1 et seq.; California Business and Professions Code Section ; as well as common law causes of action for fraud and deceit.. At all times herein relevant the defendants engaged in the conduct herein alleged with the intent to present or to cause to be presented false or fraudulent claims for the payment of a loss or injury under a contract of insurance. The defendants prepared, made, subscribed to writings, or allowed such writings to be presented to Allstate and other insurance companies in support of false or fraudulent claims. In doing so, the defendants aided, abetted, solicited, or conspired with one another to engage in such conduct, all for financial gain.. The California Insurance Frauds Prevention Act, Article 1, Section 1, et seq., was originally enacted in. In, the Act was amended to add Section 1.. This section allows the Attorney General, a County District Attorney, the Insurance Commissioner, or any other interested party to enhance the government's ability to prosecute violations of, and recover losses from, certain specified fraudulent insurance practices. In enacting Section 1., the California Legislature envisioned that insurance companies, working with law enforcement agencies, could contribute to efforts to combat the prevalent and serious problem of insurance fraud. As such, Insurance Code section 1. provides for a qui tam civil action permitting individuals to - prosecute proscribed conduct in a civil action without fear of reprisal or government inaction. --

3 1 c.. -' -' 1 t-u 1 Vl 1-1 u 1 ::: 1 1- > ; Insurance Code section 1. provides that anyone who violates Penal Code section is liable for a civil penalty of up to $1, for each claim plus an assessment up to three times the amount of the damages sustained by the victim in addition to any other penalties that might be prescribed by law.. Section 1. allows any interested person, including an insurer, to bring a civil action for violation of the section for that person and the State of California. The complaint is to be filed in camera and under seal for days to allow the government to conduct its own investigation without the knowledge of defendants, and to determine whether to join in the suit. Further, a copy of the complaint and written disclosure of substantially all material evidence shall be served on the District Attorney and Insurance Commissioner.. Allstate has complied with the requirements of Insurance code section 1.. Simultaneously with the filing of this action, Allstate provided all material information regarding the allegations contained in this complaint to the Los Angeles County District Attorney's Office and to the Insurance Commissioner of the State of California. Allstate has also offered complete cooperation in any potential investigation instituted by the above-referenced government entities.. This complaint for damages arises from an investigation that Allstate initiated in. As a result of the investigation, Allstate uncovered an insurance fraud scheme that was originated, planned and developed by defendant Daniel H. Dahan and carried out by him and other defendants through his wholly-owned general corporation and alter ego, defendant Progressive Diagnostic Imaging, Inc. In substance, the scheme involves the preparation of medical 1 documentation by the defendants that contains misleading, false and fraudulent information, knowing that such documentation would be submitted to insurance companies in support of claims made under policies of insurance. The conduct of the defendants, and each of them, was -::.,..a. ' i:"'... undertaken with the intent to deceive insurance carriers for financial gain and with a conscious disregard of the rights of Allstate and other insurance carriers, to accommodate the needs of plaintiff personal injury attorneys and law firms in the business of representing individuals with personal injury claims against insurance companies and their insureds, and to purportedly enhance the ability of chiropractors to increase personal injury work. - -

4 1. Allstate, Allstate policyholders, other insurance companies and their insureds, the motoring public, and the State of California were and are the direct victims of the illegal and fraudulent scheme conducted by defendants, and each of them. I. II. Allstate is the original source for all of the information contained in this complaint. II. JURISDICTION AND VENUE This is a civil action arising under the laws of the State of California to redress U " 1 Vl >- 1 u >- 1 :::: 1 >- > > :::: ;.. u:,., violations of California law including but not limited to, California Penal Code Section ; the Moscone-Knox Professional Corporations Act, codified as California Corporations Code Section 1 et seq.; the California Insurance Frauds Prevention Act, codified as California Insurance Code Section 1 et seq.; the California Unfair Competition Act, codified as California Business and Professions Code Section 1 et seq.; as well as common law causes of action for fraud and deceit. This Court has jurisdiction over the subject matter of this civil claim pursuant to the California Constitution Article VI, Section 1; Insurance Code Section 1.; as well as California Business and Professions Code Section 1 et seq. 1. Jurisdiction over the person and venue are proper in this district pursuant to Los Angeles Superior Court Local Rule.(c) and because defendants reside in, can be found in, transact business in, and/or maintain their principal office in Los Angeles County; and while in the County of Los Angeles, the defendants engaged in illegal and fraudulent conduct prohibited by Penal Code Section, Insurance Code Section 1., Business and Professions Code Section 1 et seq., as well as common law fraud and deceit. III. PARTIES 1. Allstate is a corporation organied and existing under the laws of the State of Illinois with its principal place of business in the State of Illinois. Allstate is an insurance company which, inter alia, issues automobile insurance policies and is licensed to conduct business in the State of California. It brings this action for its own benefit and for the benefit of the People of the State of California under the provisions of California Insurance Code Section 1.(e)(l). 1. Defendant Daniel H. Dahan, ("Dahan") is a resident of the City of Long Beach, County of Los Angeles, State of California. --

5 1 c.. -'... 1 '-U 1 Vl u cg > \' j -',-....:: 1. Defendant Progressive Diagnostic Imaging, Inc. ("PDI") is and at all times herein relevant, was a corporation organied and existing under the laws of the State of California with its principal place of business in the City of Long Beach, County of Los Angeles, State of California that is and was owned, operated, and controlled or directed by Dahan at all times herein relevant. 1. The true names or capacities, whether individual, corporate, associate, or otherwise, of defendants sued herein as DOES ONE through FNE HUNDRED, inclusive, are unknown to Allstate, who therefore sues such defendants by such fictitious names. Plaintiff is informed and believes and upon such information and belief alleges that each of the defendants designated herein as a DOE is legally responsible in some manner for the conduct herein alleged. 1. DOES ONE HUNDRED AND ONE through TWO HUNDRED were or are individuals or entities acting as agents or employees of Dahan and/or PDI, acting within the scope of agency or employment and engaging in the conduct hereinafter alleged. Each individual acted with full knowledge ofthe illegality of the activities and conduct undertaken in connection with the aforementioned entities, and conspired in, acquiesced, ratified, or approved of the conduct herein alleged undertaken by the other defendants.. DOES TWO HUNDRED AND ONE through THREE HUNDRED were or are individuals or entities that owned or operated PDI.. DOES THREE HUNDRED AND ONE through FIVE HUNDRED were or are individuals or entities who aided, abetted, assisted, otherwise participated in, or were or are involved in the fraudulent conducted hereinafter described; and aided, abetted, or assisted the other defendants with full knowledge of the illegality of the activities and conduct.. Defendants knowingly, willfully, and intentionally conspired with each other defendant and agreed to a course of action to defraud Allstate and other similarly situated insurance companies through illegal schemes as well as fraudulent and/or unlawful claims made against insurance policies, including, but not limited to, automobile liability policies, as hereinafter alleged. 1. Allstate is further informed and believes, and thereon alleges that, at all times herein relevant, there was a unity of interest and ownership between PDI and Dahan such that any individuality and separateness between this entity and individual has ceased. - -

6 " ' 1 t..u 1 Vl >- ::.:: 1 u r 1 - ::: " 1 c.- > >- 1 1 ::.::. PDI is, therefore, the alter ego of Dahan, and is and was a mere shell, instrumentality, and conduit through which Dahan carries on his business.. Adherence to the fiction of the separate existence of PDI, as distinct from Dahan, would permit an abuse of the corporate privilege, and would promote injustice by protecting Dahan from liability for the wrongful acts committed by him under the name of PDI. Any references or allegations regarding or relating to PDI apply equally to Dahan.. Allstate is further informed and believes, and thereon alleges, that PDI and Dahan have common supervision, control, management, officers, and a unity of interest in ownership, which is reflected in the pooling of their earnings, expenses, and losses, such that for all intents and purposes they are one and the same and but the alter ego of one another.. The "alternative" alter ego relationship between Dahan and PDI should be recognied to prevent an injustice. If the alter ego relationship between such defendants should not be recognied, an inequity would result because an entity responsible for wrongdoing would be shielded from liability. When considering an award of punitive damages, the entire net worth of a defendant is considered. If the corporate structure of the alter ego defendants, and each of them, is disregarded, punitive damages will be based solely on the assets of the "fronting" entity; assets which are much smaller than the other entities' assets. Because punitive damages are meant to punish and make an example of the wrongdoer, it would be inequitable to allow entities responsible for the wrongdoing complained of to shield their assets and escape punitive damages liability. IV. FACTUAL ALLEGATIONS 1 ;.. c " t -,_: A. History of Defendants' Conduct. At all times herein relevant and since at least I, PDI was and is engaged in the business of preparing and generating false and fraudulent medical documentation to support personal injury claims submitted to insurance companies and to purportedly enhance the ability of chiropractors to increase personal injury work. This insurance fraud scheme was originated by Dahan, a chiropractor licensed by the State of California, and carried out by him through PDI, a general corporation organied under the laws of the State of California, which, at all times herein relevant, was wholly-owned by Dahan. The false and fraudulent medical reports created by Dahan - -

7 . -' -' 1 1 and unlicensed "technicians" purport to interpret and analye x-rays through the use of alleged "patented technology." Though the purported medical reports usually bear the name and signature of a licensed physician, they are uniformly prepared without the input, review, approval or knowledge of the licensed physician whose name appears on the report. Instead the purported medical reports are generated by a computer software application utilied by an unlicensed employee of defendants. To create the appearance of legitimacy, however, defendants intentionally and willfully place the name of a practicing physician or other health care provider on the purported medical report and billing statement, without the knowledge or authoriation of the physician, and forge that physician's signature. The purported medical documentation is then furnished to the referring chiropractor, knowing that such documentation will be submitted to insurance companies W-l Vl u /. cc: " > r in support of a claim against a policy of insurance.. The bogus medical reports prepared by defendants contain medical diagnoses, medical findings, and medical opinions, including opinions concerning permanent impairment of individuals, purportedly based on the American Medical Association Guide to the Evaluation of Permanent Impairment. The purported medical reports, as well as the diagnoses, findings, and opinions contained therein, are not generated by a licensed physician as is consistently represented by the defendants through the placement of the name and/or signature of a licensed physician or other health care provider on the reports, but by a software program, the involvement of Dahan, and by untrained, unlicensed technicians, at least one of which has nothing more than a high school degree. The bogus medical reports contain multiple material misrepresentations of fact, which were and are known to be false by the defendants, yet were and are submitted to Allstate and other insurance carriers with them intent to deceive them into believing such reports to be true. At all times herein relevant, Allstate reasonably relied on such reports submitted in support of claims made under policies of insurance issued by Allstate and as a consequence, paid POI's bills, and i},.-, '.:..-' :.: -. considered the findings, opinions and diagnoses in evaluating personal injury claims, including, but not limited to bodily injury claims, uninsured motorist claims and underinsured motorist claims. The purported medical reports prepared by defendants had the effect of fraudulently increasing the settlement value of claims, causing Allstate to pay substantially more than would have been paid, - -

8 w.l 1 Vl 1 u >- 1 ::: " 1 > had Allstate known that the purported medical reports were false and fraudulent.. At all times herein relevant, defendants and each of them, were aware that they were producing false and fraudulent medical reports, and knew that the reports were being submitted to insurance companies in support of claims made on policies of insurance.. In addition to producing bogus medical documentation, defendants submitted and continue to submit fraudulent billing statements to give the appearance that a licensed physician actually performed professional services when, in fact, no licensed physician or other health care provider performed such professional services. Defendants have consistently engaged in fraudulent billing practices in connection with PDI, including, but not limited to, billing for services which were not provided, up-coding, double and triple billing for services rendered, and billing for the interpretation of more films than exist for a particular patient. Like the bogus medical reports, defendants used the names of licensed physicians without authoriation on billing statements to give the appearance that the licensed physician had actually performed the professional services.. At all times herein relevant, defendants, and each of them, were aware that they were producing false and fraudulent medical billings, and knew that such billings were being submitted to insurance companies in support of claims made on policies of insurance. 1. Defendants, and each of them, have engaged in this insurance fraud scheme with the intent to bilk money out of Allstate and other similarly situated insurance companies, to create the appearance of a serious injury or impairment where it does not otherwise exist, and to falsely and fraudulently inflate the value of claims submitted to insurance companies. The fraudulent conduct of defendants has caused substantial financial losses to Allstate, other insurance companies, the motoring public, and the State of California. B. The Manufacture of Bogus Medical Reports,,, :.;. The defendants solicit business from chiropractors across the United States by offering services including the reading and interpreting of x-ray films by board certified radiologists / u u _-,., and tout POI's "patented" report-generating software applications as being helpful to the treating chiropractor in obtaining business from personal injury attorneys and payment by insurance companies. They advertise the advantage of utiliing PDI's services as including increased - -

9 "- """' """' U-l V1 u,_ ct:: c >,_ personal injury referrals and the ability to provide attorneys with professional documentation. At all times herein relevant, PDI has held itself out as "the nation's technological leader in x-ray interpretation and analysis reporting and documentation." Defendants do business in this fashion with extensive advertising to chiropractors across the country and also as part of other businesses owned and operated by Dahan, including, but not limited to a chiropractic consulting business entitled "Practice Perfect.". At all times herein relevant, the defendants' advertising for PDI was false, fraudulent, and misleading, designed to lure and entice chiropractors into using PDI for x-ray analysis and interpretation. When defendants represent that a "doctor" uses PDI's "patented technology" to produce reports, the representation was and is false. When defendants represent that, "Our radiologist reads the films for pathologies and produces a biomechanical report," the representation was and is false. From its inception in or about 1, to the present, defendants have consistently utilied false, fraudulent and misleading advertising for PDI, calculated to induce and entice chiropractors and other health care providers to refer x-rays for interpretation and analysis.. To manufacture the fraudulent medical reports, unlicensed PDI employee(s) scan and "digitie" x-rays sent via FedEx from locations throughout the United States. Once digitied, PDI, as directed and controlled by Dahan, undertakes two separate and distinct report-generating processes that are subsequently made to appear as having all been part of the same process. One step is to send, via , the digitalied image of an x-ray made from scanning the actual x-ray film, to a "reading" radiologist, usually a board-certified radiologist working as an independent contractor, who is paid a flat rate to interpret or read the scanned digital image. The "reading" radiologist reviews the digitalied image and dictates a standard x-ray report that contains findings for each film or series of films for different regions of the patient's body. A flat rate paid by PDI to the radiologist is often as little as $ to $1 per x-ray or "pathology" report. u - u '. The other process undertaken by PDI after the x-rays are scanned and digitied does not involve a licensed physician or the "reading" radiologist. PDI independently prepares its own purported radiology reports using PDI's computer software application which is operated by an unlicensed technician. This alleged radiology report is created without the knowledge, authority or - - UNFAIR COMPETITION ACT, FRAUD AND DECEIT. CONSTRUCTIVE TRUST, AND EQUITABLE LIEN; DEMAND FOR JURY TRIAL

10 "- --' --' :: 1-U Vl,_ u - > :::.- >,_ ratification of the "reading" radiologist and more often than not, the computer-generated radiology reports are created at PDI before the "reading" radiologist has reviewed the digitied x-ray received from PDI for review. Without any involvement or input by the "reading" radiologist, the purported radiology reports prepared by PDI contain medical findings, medical opinions, and medical diagnoses relating to various medical conditions and often include permanent impairment ratings purportedly based upon utiliation of the American Medical Association Guide to the Evaluation of Permanent Impairment. Despite the fact that the "reading" radiologist has no knowledge of and has never seen the PDI computer-generated reports for review or approval, the defendants intentionally affix the "reading" radiologist's name and/or signature to the radiology reports to give the appearance that the reports were authored by a licensed physician or board-certified radiologist. Defendants have knowingly created thousands of bogus medical reports bearing the name of a licensed physician or other health care provider knowing that the use of the licensed physician's name and signature was not authoried, permitted or approved by the physician. As a result of the practices of defendants, Allstate has received in excess of claims supported by purported medical documentation generated by defendants through PDI.. PDI's bogus radiology reports frequently feature an opinion regarding permanent impairment, often as high as a % "whole person" impairment, represented by defendants as being based on the American Medical Association Guide to the Evaluation of Permanent Impairment. In setting forth a purported medical impairment rating, including representing that the rating is based on the AMA guidelines, and affixing the name and/or signature of a licensed physician who never authoried, saw or performed an impairment evaluation of the patient, defendants falsely and fraudulently represent to insurers and anyone reviewing the reports that the medical report reflects the professional medical judgment, opinions and conclusion of the healthcare professional whose name appears on the report, when in fact the report was prepared by ''; '.. L: ;:J an unlicensed employee of the defendants. The representations were and are material, and were and are made intentionally and with the intent to deceive anyone reviewing the reports, including insurance companies, their representatives and medical utiliation reviewers. At all times herein relevant, Allstate and other insurers reasonably relied on the false representations to their detriment. - 1-

11 As a direct consequence of the material misrepresentation of fact as herein alleged, Allstate has c.. _,... 1 ::= 1-U 1 Vl u 1 c- 1 p::: 1 > suffered substantial financial loss. C. Illegal Practice of Medicine. Defendants, through PDI, engage in the practice of medicine despite being prohibited from doing so by California law. The bogus medical reports created by PDI contain medical findings, medical opinions, and medical diagnoses of medical conditions. These findings, opinions, and diagnoses are literally manufactured by a computer software application and an untrained, unlicensed technician in the employ of defendants, acting at the direction and control of Dahan and other defendants. The conduct of defendants in rendering medical findings, medical opinions and medical diagnoses constituted and continue to constitute the illegal practice of medicine in violation of California Business and Professions Code Section. D. Illegal Ownership of a Medical Practice. By virtue of the fact that defendant, through PDI, provide professional medical services, form medical diagnoses and offer opinions on permanent impairment, defendants were and are engaged in the practice of medicine. Under the laws of the State of California, PDI was and is required to be organied as a professional corporation, not a general corporation, subject to strict ownership requirements designed to protect the public from lay-ownership of medical practices. Defendants organied PDI as a general corporation in violation of California law. Under California law, Dahan could hold an ownership interest in a professional medical corporation, but only up to %, as a chiropractor licensed by the State of California. A chiropractor may not, under California law, have a I % interest in a professional medical corporation. At all times herein relevant, and to the present, no licensed physician in the State of California has held an interest in PDI. As such, PDI is an illegally-owned medical corporation under the laws of the State of California and any billing statements generated by POI were and are void. ":l "",-,_.., -" ' v' E. Fraudulent Billing Practices. The defendants, through PDI, have, at all times herein relevant, routinely engaged in fraudulent billing practices including improper use of CPT Codes on billing statements for medical services purportedly rendered by PDI. Such improper use of CPT Codes includes, but is not limited - II - COMPLArNT FOR VIOLATION OF CALIFORNIA rnsurance FRAUDS PREVENTION ACT, VIOLATION OF THE CALIFORNIA

12 to, double and triple billing for services rendered, billing for services which PDI does not perform, and billing for the interpretation of more films than exist for a particular patient. In addition, the billing statements submitted to Allstate for payment or as support for a personal injury claim were and are false and fraudulent as the billing statement represents that the service was rendered by a licensed professional, which was false.. "Reading" radiologists whose names appear on purported radiology reports prepared by defendants deny that they performed services listed on the billing statements and report that they did not prepare the billing statements submitted by PDI and did not authorie the use of their names on the billing statements. 1. At all times herein relevant, defendants have prepared billing statements that include charges for professional medical services involving face-to-face consultations, using CPT Codes that include a face-to-face evaluation as a component to the service rendered. Neither the "reading" radiologists' review of digitied x-rays, nor PDI's creation of computer-generated radiology reports involves face-to-face time with a patient. PDI has never been engaged in any face-to-face evaluation, meeting, or even telephone conversation with a patient. Indeed, a "reading" radiologist's review of digitied x-rays could never, under any circumstance, be described to include a face-to-face evaluation with the patient. Yet, defendants routinely billed for services which involve a face-to-face evaluation, knowing that such services were never rendered by a licensed physician. Defendants were, at all times, knowledgeable concerning billing and use of CPT codes and knowingly included such charges on billing statements to falsely give the appearance that such services were, in fact, rendered by a licensed physician. Defendants, nonetheless, produced such billing statements with intent to defraud and deceive insurance companies, including Allstate. Allstate, at all times herein relevant, reasonably relied on the representations contained in the PDI billing statements and as a consequence, suffered significant financial losses.. At all times herein relevant, defendants have included charges in PDI billing statements under a CPT Code for the delivery, fitting, and adjustment of a device, including orthotics. At no time, however, did PDI perform any service that involved the delivery, fitting and - 1-

13 "- --' ;;: W-1 1 VJ r 1 u r 1 p:; " r 1 >,_ 1 1 1,.- - ' L. ' -- 'e adjustment of a device, including orthotics, in connection with the work done by the "reading" radiologists and the generation of false and fraudulent medical reports. The charges, as such were material misrepresentation of fact intended to deceive insurance companies.. At all times herein relevant, defendants have routinely included charges in PDI billing statements for the interpretation of more x-rays than actually exist for a given patient. For example in instances in which the treating chiropractors had exposed the patient to only four or five views, a PDI billing statement will be generated in which PDI bills for review of a full seven view Davis Series_ In creating billing statements through PDI, defendants routinely billed and continue to bill for services which were not rendered, including, but not limited to billing for the review of more x-rays than were supplied to PDI by the treating chiropractor for review. The billing for services not rendered was not the result of mistake, neglect or inadvertence, but was part of a scheme to charge insurance companies for work that had not been performed. The PDI billing statements, were, at all times herein relevant, carefully crafted by defendants to falsely give the appearance that work was actually performed and that such services were rendered by a licensed professional, knowing at all times that such representations were not true. They, nonetheless, generated false and fraudulent medical documentation and billing statements knowing that the medical documentation and billing statements were false and fraudulent and that they would be submitted to an insurance company in support of a claim. The billing statements were produced by defendants as part of the scheme or plan to create false and fraudulent documentation to assist persons making personal injury claims and to purportedly help chiropractors increase their personal injury referrals from attorneys. FIRST CAUSE OF ACTION (California Insurance Frauds Prevention Act) (California Insurance Code 1. ) (Alleged Against All Defendants by Plaintiffs). Plaintiffs re-allege and incorporate paragraphs 1 through above as though fully set forth herein.. This is a claim for damages and penalties nnder the Insurance Frauds Prevention Act, California Insurance Code

14 1. By virtue of the conduct alleged herein, defendants, and each of them, intentionally and repeatedly violated California Insurance Code Section 1.(b) in that defendants, and each of them, knowingly violated California Penal Code Sections. As of the time of filing this. --"... 1 ::: u..j 1 VJ >- 1 u r 1 a:: 1 e- X e ' " d complaint, Allstate has identified in excess of claims in which defendants have engaged in some or all of the following conduct: A. Knowingly presented or cause to be presented false or fraudulent claims for the payment of a loss of injury under a contract of insurance; and/or B. Knowingly prepared, made or subscribed writings, with the intent to present or use them, or allow them to be presented, in support of a false or fraudulent claim; and/or C. Presented or caused to be presented written or oral statements as part of, or in support of claims for payment or other benefit pursuant to an insurance policy, knowing that the statement contains false or misleading information concerning material facts; and/or D. Prepared or made any written or oral statements that were intended to be presented to an insurer in connection with, or in support of, claims or benefit pursuant to an insurance policy, knowing that the statements contain false or misleading information concerning material facts; and/or in A through D above. E. Aiding, abetting, soliciting, assisting or conspiring with any person to engage. As a result of such conduct on the part of the defendants, plaintiffs have been damaged in substantial amounts, and are entitled to damages and penalties in accordance with California Insurance Code Section 1., to be determined at trial. SECOND CAUSE OF ACTION (California Unfair Competition Act) (California Business and Professions Code 1 et seq.) (Alleged Against All Defendants by Plaintiff Allstate only). Allstate re-alleges and incorporates paragraphs 1 through above as though fully set forth herein.. California Business and Professions Code Section 1 et seq. was enacted by the -;, California State Legislature in to protect businesses from the unfair business practices of - 1- COMPLAINT FOR VIOLATION OF CALIFORNIA INSURANCE FRAUDS PREVENTION ACT. VIOLATION OF THE CALIFORNIA

15 1 c " (..U 1 U),_ 1 u 1 ::: 1 c,_ >,_ competitors. By the late 's the statute was expanded to protect consumers from any "unlawful, unfair or fraudulent business act or practice" and any "unfair, deceptive, untrue or misleading advertising.". Under California Business and Professions Code Section 1, "[a]ny person who engages, has engaged, or proposes to engage in unfair competition may be enjoined in any court of competent jurisdiction. The court may make such orders or judgments, including the appointment of a receiver, as may be necessary to prevent the use or employment by any person of any practice which constitutes unfair competition, as defined in this chapter, or as may be necessary to restore to any person in interest any money or property, real or personal, which may have been acquired by means of such unfair competition." 1. Under California Business and Professions Code Section, Allstate is a "person" as defined by the statute.. The conduct of defendants, and each of them, as alleged herein, constitutes "unfair competition" under California Business and Professions Code Section 1, which includes, "any unlawful, unfair or fraudulent business act or practice and unfair, deceptive, untrue or misleading advertising... ". As a result of the conduct of defendants, and each of them, as alleged herein, Allstate has suffered the loss of substantial amounts of money. Under California Business and Professions Code Section 1, Allstate is a "person who has suffered injury in fact and has lost money or property as a result of such unfair competition." Accordingly, Allstate asks this court to issue orders and enter judgment in favor of Allstate and against defendants as hereinafter set forth. THIRD CAUSE OF ACTION (Fraud and Deceit) (Alleged Against All Defendants by Plaintiff Allstate only). Allstate re-alleges and incorporates paragraphs 1 through above as though fully,_ set forth herein.. Defendants, and each of them, engaged in the conduct alleged herein with the intent to defraud and deceive insurance companies, including Allstate, and the general public as to the true -. ' -. nature of the business conducted by defendants, and each of them. The multiple misrepresentations. 1.

16 1. --' --' 1 w 1 Vl u cg > _.i,..; -, ''---'' of fact concerning the practices of the defendants, and each of them, including specific representations made in records, narrative reports, billings statements, and other documents generated by defendants, and each of them, at all times herein relevant, were intentional and made with the intent to have insurance companies, including Allstate, rely on such representations. At all times herein relevant, the representations made by defendants, and each of them, as to the practices of the defendants, and each of them, were false and misleading and the falsity of the representations was known to the defendants, and each of them, at the time such representations were made.. Defendants, and each of them, repeatedly made misrepresentations of fact concerning the nature of the services rendered and/or the billings for such services; and/or concealed from Allstate material facts concerning the nature of the services rendered and/or the billings in records and bills provided to Allstate; all in connection with claims for the payment of benefits under contracts of insurance, as herein alleged. Affirmative representations were repeatedly made in connection with services and billing which were untrue, and known to be untrue by defendants, and each of them, at the time such affirmative representations were made, as herein alleged.. At all times herein relevant, Allstate reasonably relied on the representations made by defendants. Had Allstate known the true facts concerning the services and billing, it would have materially affected its analysis and payment of claims made under contracts of insurance.. As a result of the conduct of the defendants, and each of them, Allstate has suffered substantial financial injury through the payment of claims that would not have otherwise been paid.. In engaging in such fraudulent conduct, as herein alleged, defendants acted with malice, oppression, or fraud sufficient warrant the imposition of punitive damages. FOURTH CAUSE OF ACTION (Constructive Trust) (Alleged Against All Defendants by Plaintiffs). Plaintiffs re-allege and incorporate paragraphs 1 through above as though fully set forth herein. 1. On information and belief, with monies and proceeds from the conduct alleged above, defendants, and each of them, have acquired title to real property, personal property, and - 1-

17 ,_ 1 --' 1 i-ll 1 Vl ;- u - L 1 1 ::: 1 ;- > ; ::::! have deposited funds into various accounts including, but not limited to, checking accounts, savings accounts, mutual fund accounts, and other accounts. Thus, defendants, and each of them, are involuntary trustees holding said property and profits in constructive trust for Plaintiffs with the duty to convey the same to plaintiff forthwith.. On information and belief, defendants, and each of them, have used monies and proceeds from the wrongful conduct herein alleged to acquire title to real property, including but not limited to real property located at Cedar Avenue, Long Beach, California, ; 1 East Wardlow Road, Long Beach, California, ; West th Street, Long Beach, California; and I 1 Pacific Avenue, Long Beach, California.. On information and belief, defendants, and each of them, have used monies and proceeds from the wrongful conduct alleged herein to deposit monies into accounts at various banks, including but not limited to accounts under the name Daniel H. Dahan, Progressive Diagnostic Imaging, Inc., and Practice Perfect, Inc.. Plaintiffs are entitled to, and request, equitable relief in the form of a constructive trust, upon all real property, personal property, and accounts, including but not limited to those alleged herein, that were acquired with proceeds or monies from the wrongful conduct alleged herein.. Plaintiffs are presently unaware of the location of any further monies and proceeds wrongfully taken from Allstate and other insurers by the defendants. As further investigation and discovery is conducted on this matter, plaintiffs will amend this complaint to allege the location and nature of the monies and proceeds wrongfully taken by the defendants.. On information and belief, and due to the nature of the defendants' conduct alleged herein, plaintiffs have not been able to identify all real property, personal property, or accounts acquired by defendants, and each of them, with monies or proceeds from the wrongful conduct alleged herein; and plaintiffs are entitled to, and requests, equitable relief in the form of a L' ---:: constructive trust, upon all real property, personal property, and accounts which are identified at the time of trial. /Ill COMPLAINT FOR VIOLATION OF CALIFORNIA INSURANCE FRAUDS PREVENTION ACT. VIOLA T!ON OF THE CALIFORNIA UNFAIR COMPETITION ACT. FRAUD AND DECEIT, CONSTRUCTIVE TRUST, AND EQUITABLE LIEN; DEMAND FOR JURY TRIAL

18 1 FIFTH CAUSE OF ACTION (Equitable Lien) (Alleged Against All Defendants by Plaintiffs). Plaintiffs re-allege and incorporate paragraphs 1 through above as though fully set forth herein.. On information and belief, Allstate's monies and funds acquired by defendants, and each of them, as alleged herein, can be traced to the purchase, improvement, betterment, or deposit into real property, personal property, or accounts at banks, savings and loans, mutual fund companies, corporations, partnerships, or other accounts or business entities.. The retention by defendants, and each of them, of the real property, personal ::: 1 o property, or accounts purchased, improved, bettered, or added to with monies or funds that defendants have wrongfully acquired from Allstate would result in unjust enrichment. 1. Plaintiffs are entitled to, and request, equitable relief in the form of an equitable lien, 1 upon all real property, personal property, and accounts identified above which were acquired with 1 proceeds or monies from the wrongful conduct alleged above On information and belief, and due to the nature of the defendants' conduct alleged b > 1 herein, plaintiffs have not been able to identify all real property, personal property, or accounts 1 acquired by defendants with monies or proceeds from the wrongful conduct alleged above; and plaintiffs are entitled to, and requests, equitable relief in the form of an equitable lien, upon all real property, personal property, and accounts which are identified at the time oftrial. PRAYER 1 WHEREFORE, Plaintiffs pray for the following relief: Under the First Cause of Action for Violation of California Insurance Code Section 1. I. For all damages, penalties and assessments allowable under California Insurance Code Section 1.(b) as to each defendant found to have violated California Penal Code Sections, or 1 for each fraudulent claim presented to Allstate;. A temporary injunction to prevent the transfer, concealment, or dissipation of illegal proceeds by Dahan and PDI; - -

19 1 -- : U 1 Vl 1 u >- 1 p::: 1 > f A temporary injunction to protect the public prohibiting Dahan and PDI from engaging in the practice of medicine; prohibiting Dahan from having an ownership interest in any medical practice or corporation, including, but not limited to PDI; and prohibiting Dahan and PDI from further violating California Penal Code Section ;. Attorney's fees;. Costs of suit; and. Such further and other relief as may be deemed appropriate by the court; Under the Second Cause of Action for Violation of California Business and Professions Code Section 1 et seq. I. For a permanent injunction prohibiting Dahan from working in, or otherwise being involved with any health-related field, including, but not limited to, medicine, chiropractic, physical therapy and radiology;. For a permanent injunction prohibiting Dahan from having any ownership interest in any business in a health-related field, including, but not limited to, medicine, chiropractic, physical therapy and radiology; Section ;. For a permanent injunction prohibiting Dahan from practicing medicine;. For a permanent injunction prohibiting Dahan from violating California Penal Code. For a permanent injunction prohibiting Dahan from working in, or otherwise being involved with any insurance-related business, including, but not limited to, working for an insurance company, working for a law firm engaged in a personal injury practice, advising claimant or their representative concerning claims, advising chiropractors concerning claims, capping, running, and advising any person or entity concerning the use of CPT or other billing codes;,., "". For a permanent injunction prohibiting PDI from engaging in the corporate practice of medicine absent proof to the court that PDI is owned in accordance with the Moscone Knox Professional Corporations Act and all other applicable California state law;. For a permanent injunction prohibiting Dahan, PDI and any other person or entity --.".,_, from using the claimed "patented technology" to generate medical reports absent proof to the - -

20 1 satisfaction of this court that the report has been reviewed, approved and authoried by a boardcertified radiologist licensed by the State of California as a physician and surgeon; PDI;. For a permanent injunction prohibiting Dahan from having an ownership interest in. For a permanent injunction prohibiting Dahan from starting any other business related to radiology in any respect; I. For a judicial declaration and judgment that any and all bills, billing statements,_ --' -' 1 ;;: '-Ll 1 Vl >- - 1 u ' 1 ::: 1 > :; c:,_:. and/or billing invoices generated by PDI were and are void as a matter of law;. For restitution, including, but not limited to, all monies paid by Allstate to Dahan, PDI, any claimant, any claimant's attorney or any other person in connection with any and all claims made against policies of insurance in which any document generated or produced by PDI was presented to Allstate in connection with a claim, including, but not limited to, all amounts paid under medical payments provisions, all settlements paid on uninsured motorist claims, all settlements paid on underinsured motorist claims, and all bodily injury settlements. 1. For Attorney's fees; 1. For costs of suit; and 1. For such further and other relief as may be deemed appropriate by the court; Under the Third Cause of Action for Fraud and Deceit 1. For all actual damages, according to proof;. For punitive damages. For costs of suit; and. For such other and further relief as the court may deem appropriate. Under the Fourth Cause of Action for Constructive Trust 1. That the court impose a constructive trust on Dahan and PDI, as constructive trustee for the benefit of plaintiffs with respect to any real or personal property, to prevent the transfer,.- :,..- --, concealment and/or dissipation of property that was acquired with the illegal proceeds gained through the acts of Dahan. - ; ' -, --

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