Indictment of False Memory therapists for insurance fraud

1993

The United States Grand Jury Charges:

At all times material herein:

1. Judith A. Peterson, Ph.D. (Peterson), defendant herein, was a resident of Houston, Texas. Peterson was a psychologist licensed to practice by the State of Texas, who treated patients at Spring Shadows Glen and was its clinical director of the Dissociative Disorders Treatment Program. Peterson claimed to be an expert in treating individuals with disorders related to a diagnosis of "multiple personality disorder" usually caused by involvement in "satanic ritual abuse and related cult activity". Peterson operated her practice through Peterson Psychological Associates, P.C., and her staff included among others, defendant Davis.
2. Richard E. Seward, M.D. (Seward), defendant herein, was a resident of Houston, Texas. Seward was board certified in general adult and child psychiatry and was licensed to practice by the State of Texas. Seward had admitting privileges at Spring Shadows Glen and was the clinical medical director of the Dissociative Disorders Treatment Program. Seward operated his practice through Richard E. Seward, M.D., P.A.
3. George Jerry Mueck (Mueck), defendant herein, was a resident of Houston, Texas. Mueck was the hospital administrator at Spring Shadows Glen and was responsible, among other things, for hiring Peterson and Seward as directors of the Dissociative Disorders Treatment Program. Mueck’s responsibilities included oversight of the business side of the hospital including the billing of insurance companies for patient treatment. Mueck was also a certified public accountant.
4. Gloria Keraga, M.D. (Keraga), defendant herein, was a resident of Houston, Texas. Keraga specialized in the practice of psychiatry and was licensed to practice by the State of Texas. Keraga had admitting privileges at Spring Shadows Glen and admitted patients to its Dissociative Disorders Unit. Keraga operated her practice through Houston Psychiatric Resources, P.A.
5. Sylvia Davis, M.S.W. (Davis), defendant herein, was a resident of Houston, Texas.Davis was a psychotherapist licensed to practice by the State of Texas. Davis worked with Peterson in treating patients at Spring Shadows Glen. Davis specialized in a form of psychotherapy called "psychodrama", which she used in treating individuals with disorders related to a diagnosis of "multiple personality disorder" caused by involvement in "satanic ritual abuse and related cult activity." Davis operated her practice largely through Peterson Psychological Associates, P.C., performing psychotherapy on Peterson’s patients.
6. Spring Shadows Glen Psychiatric Hospital (Spring Shadows Glen), was doing-business-as entity owned by Memorial City General Hospital Corporation, a corporation once duly certified to do business in the state of Texas. Spring Shadows Glen was principally set up to offer medical services in a hospital setting to patients with various kinds and degrees of psychiatric conditions and disorders and was located at 2801 Gessner, Houston, Texas.

The following terms as used in this Indictment are defined below to clarify the nature of the conspiracy and the schemes and artifices designed by the defendants, as detailed in the Manner and Means section of this Indictment:

7. The Diagnostic and Statistical Manual of Mental Disorders, Third Edition, Revised (DSM-3R): The principal handbook used in the mental health profession. It provides the basic definitional information utilized by mental health practitioners. The DSM-3R was updated to the Diagnostic and Statistical Manual of Mental Disorders, Fourth Edition (DSM-4) in May, 1994.
8. "Multiple Personality Disorder" (MPD), is defined by the DSM-3R as involving the existence within a person of two or more distinct personalities or personality states (each with its own relatively enduring pattern of perceiving, relating to, and thinking about the environment and self) and at least two of these personalities or personality states recurrently take full control of the person’s behavior. MPD is now called "Dissociative Identity Disorder" (DID) by the DSM-4 and is defined as a disorder that is characterized by the presence of two or more distinct identities or personality states that recurrently take control of the individual’s behavior accompanied by an inability to recall personal information that is too extensive to be explained by ordinary forgetfulness.
9. "The Dissociative Disorder Unit" or "Unit E", refers to a unit within Spring Shadows Glen that was designed to house adult patients the medical staff determined had a dissociative disorder and often a diagnosis of MPD, and who needed extensive attention and therapy, often with 24-hour attention from the staff. The long-term patients housed on this unit were most often women diagnosed with MPD allegedly caused by satanic cult-related abuse.
10. "A Review Company" also called a "Utilization Review Company" describes a company formed to provide professional services and consultations to a health insurance company or a business with self-insured health coverage for its employees. These companies generally were staffed with licensed nurses and doctors so that the client insurer could have the review company’s professionals speak directly with hospitals and doctors regarding coverage and treatment of insured individuals and to advise the client insurer as to the appropriateness of treatment plans, payment, need for independent opinions, or other similar medical necessity opinions and options, so that the insurer could manage the costs related to its beneficiaries.
11. "Satanic Cult" and "Satanic Ritual Abuse" describe a group of people alleged to be worshipers of Satan or similar mythological devil-like character. The defendants alleged that the cult: was secretive and kept track of its members and ex-members; engaged in mind-control techniques, including control and communication by hand movements, language patterns, use of certain identifiable objects or other "signaling" known only to the cult and its members; tortured its members including holding ceremonies wherein ritual abuses were performed including human sacrifices, at times involving cannibalism of the victim/sacrifices; forced women by rape and other means to have babies to provide the cult with new members and victim/sacrifices for ceremonies. The defendants stated that the cult was pervasive throughout society and that cult members could be found in every walk-of-life and profession.

12. The Grand Jury adopts, realleges, and incorporates herein the allegations in the Introduction, paragraphs 1-11 of this Indictment.
13. Beginning in or about the middle part of 1991, the exact time being unknown to the grand jury, and continuing through the latter part of 1993, in the Southern District of Texas and elsewhere,

defendants herein, did knowingly, intentionally, and willfully combine, conspire, confederate and agree with each other, and with Spring Shadows Glen, and other persons known and unknown to the grand jury to commit and aid and abet in the commission of certain offenses against the United States, as follows:

1. to knowingly and intentionally devise and intend to devise a scheme and artifice to defraud and to obtain money by means of false and fraudulent pretenses and representations, from United States insurance companies and plans, well knowing at the time that the pretenses and representations were false when made, and, in furtherance of the scheme and artifice to defraud, used and caused the United States Postal Service mail to be used, in violation of Title 18, United States Code, Section 1341 (mail fraud);
2. to knowingly and intentionally devise and intend to devise a scheme and artifice to defraud and to obtain money by means of false and fraudulent pretenses and representations, from United States insurance companies and plans, well knowing at the time that the pretenses and representations were false when made, and, in furtherance of the scheme and artifice to defraud, used and caused interstate wire communication facilities to be used, in violation of Title 18, United States Code, Section 1343 (wire fraud); and, as further set forth hereafter:

14. The manner and means of the conspiracy and (the various schemes to defraud) included, but was not limited to, the following:

1. It was a part of the conspiracy that the defendants and others would and did devise various means to obtain fraudulent insurance payments from various United States insurance companies and insurance plans.
2. It was a further part of the conspiracy that the defendants and others would and did utilize a special unit called the Dissociative Disorders Unit or Unit E at Spring Shadows Glen psychiatric hospital to conduct their fraudulent insurance payment enterprise.
3. It was a further part of the conspiracy that the defendants and others would and did utilize other units at Spring Shadows Glen psychiatric hospital, including the children's, adolescent, and adult units, in order to conduct their fraudulent insurance payment enterprise.
4. It was a further part of the conspiracy that the defendants and others would and did recruit psychiatrists, a psychologist and related psychotherapists to lend their names, titles, professional licenses, credibility, and an appearance of legitimacy to the hospital and its special and other units, in order to conduct their fraudulent insurance payment enterprise.
5. It was a further part of the conspiracy that the defendants and others would and did seek to recruit potential patients and their families from various locations when they had health insurance policies that provided for large or unlimited lifetime policy limits for in-patient mental healthcare, in order to conduct their fraudulent insurance payment enterprise.
6. It was a further part of the conspiracy that the defendants and others would and did utilize the psychiatrists and the psychologist to improperly diagnose such patients who had the large or unlimited lifetime policy limits for in-patient mental healthcare, in order to conduct their fraudulent insurance payment enterprise.
7. It was a further part of the conspiracy that the defendants and others would and did utilize the United States mail and interstate telecommunications facilities to communicate these improper psychiatric diagnoses to the patients’ insurance companies and to review companies and to seek certification from insurance companies for hospital admission for in-patient mental healthcare and subsequent re-certification for continued hospitalization, all of which was paid out of the large or unlimited lifetime policy limits for in-patient mental healthcare, in order to conduct their fraudulent insurance payment enterprise.
8. It was a further part of the conspiracy that the defendants and others would and did fraudulently induce and manipulate some insured patients into consenting to the admission of their children into the hospital, when these children had little medical or psychiatric need to be housed in an in-patient mental health facility and were actually admitted to the hospital in order for the defendants to conduct their fraudulent insurance payment enterprise.
9. It was a further part of the conspiracy that the defendants and others would and did utilize the staff psychiatrists and the psychologist to improperly diagnose these admitted children, who were covered under their parents’ policy with the large or unlimited lifetime in-patient mental healthcare limits, in order to conduct their fraudulent insurance payment enterprise.
10. It was a further part of the conspiracy that the defendants and others would and did utilize the United States mail and interstate telecommunications facilities to communicate the improper diagnoses of the insured patients’ children in order to seek certification from insurance companies for hospital admission for the in-patient mental healthcare of these children and to seek re-certification for their continued hospitalization, all to be paid out of the large or unlimited lifetime policy limits for in-patient mental healthcare, in order for the defendants to conduct their fraudulent insurance payment enterprise.
11. It was a further part of the conspiracy that the defendants and others would and did fraudulently treat the insured patients for MPD caused by unsubstantiated and unrealistic allegations and abuses, including satanic ritual abuse and cult activity, while at the same time creating medical records to substantiate such treatment; and the defendants did issue unnecessary physician orders and otherwise fraudulently create in medical records entries falsely indicating the need for expensive treatments, such as suicide watches and similar staff-intensive treatments, in order to conduct their fraudulent insurance payment enterprise.
12. It was a further part of the conspiracy that the defendants and others would and did fraudulently elicit statements of satanic ritual abuse and cult activities from the admitted patients, through non-traditional treatment modalities, including the use of leading or suggestive questions during therapy sessions while the patients were: under hypnosis; under the influence of a drug or combination of drugs; isolated from their families, friends and the outside world; denied certain privileges and freedoms, including uninterrupted sleep; held down by excessive or medically unnecessary physical restraints; or, otherwise by employing the use of techniques commonly associated with mind control and "brain-washing", in order to conduct their fraudulent insurance payment enterprise.
13. It was a further part of the conspiracy that the defendants and others would and did assure the compliance of the fraudulently treated, insured patients with the orders of the hospital, its staff, psychiatrists, psychologist and related psychotherapists by using non-traditional treatment modalities, including the use of: hypnosis; drugs; isolation from family, friends and the outside world, including the screening of visitors, mail and telephone privileges; threats; excessive use of physical or medically unnecessary restraints; and, otherwise by employing the use of techniques commonly associated with mind control and "brain-washing", in order to conduct their fraudulent insurance payment enterprise.
14. It was a further part of the conspiracy that the defendants and others would and did utilize the positions of administrator and various directorships in the hospital to carry out the policies and non-traditional treatment plans of these insured patients, including threatening other psychiatrists, psychologists, psychotherapists, nurses, and other hospital staff with the loss of their jobs, positions or remuneration to attempt to coerce them into creating or changing medical charts, records, observations of behaviors and otherwise to create a fraudulent medical record for the patient, in order to conduct the defendants’ fraudulent insurance payment enterprise.
15. It was a further part of the conspiracy that the defendants and others would and did instruct, coach, guide and encourage the patients and children of patients to fraudulently inform Child Protective Services of alleged satanic ritual abuse, cult participation, and unsubstantiated and unrealistic abuses of children and others, in order to give an air of legitimacy to statements being made by the defendants and others to insurance companies, and related review companies, that official child abuse investigations were under way, in order to conduct their fraudulent insurance payment enterprise.
16. It was a further part of the conspiracy that the defendants and others would and did instruct, coach, guide and encourage the insured patients through leading questions, suggestions, availability of books on cult-related topics, group discussion, and allowing discussion among roommates and unit-mates, to relate "stories" during therapy sessions of alleged satanic ritual abuse and cult participation, and unsubstantiated and unrealistic abuses of children and others, so that the "diagnosis" of the insured patients would be backed up with medical records in the form of charts and therapy notes and tapes in order to make it difficult or impossible for the insurance and review companies to question the diagnosis or to request an independent medical opinion.
17. It was a further part of the conspiracy that the defendants and others would and did utilize titles such as "expert in the field," "national expert" and other similar titles, and to invite or intimate that other psychiatrists and psychologists claiming such titles had been to the hospital to "consult", to lend credence to the stories of satanic ritual abuse, cult participation, and unsubstantiated and unrealistic abuses of children and others, so that the insurance and review companies would be misled about the "diagnoses" and treatment of the insured patients and, therefore would not request an independent evaluation.
18. It was a further part of the conspiracy that the defendants and others would and did submit in whole or part the various charts and records containing reports of behaviors and events that were unsubstantiated, unrealistic or had never occurred to various United States insurance and review companies, often by use of United States mail and interstate telecommunications facilities, in order to conduct their fraudulent insurance payment enterprise.
19. It was a further part of the conspiracy that the defendants and others would and did provide false information and did falsely respond to inquiries made by insurance and review companies concerning the policy claims submitted, in order to conduct their fraudulent insurance payment enterprise.
20. It was a further part of the conspiracy that the defendants and others would and did receive insurance payment checks from the various insurance companies, totaling millions of dollars in payments, often through the United States mail, based on the fraudulent claims and records submitted, in order to conduct their fraudulent insurance payment enterprise.
21. It was a further part of the conspiracy that the defendants and others would and did conceal from insurance and review companies that hospital funds had been converted into cashier’s checks which were then submitted to pay the insurance policy premium payments of patients, in order to conduct their fraudulent insurance payment enterprise.
22. It was a further part of the conspiracy that the defendants and others would and did utilize the fraudulently obtained insurance payment funds to enrich the hospital and the psychiatrists and psychologists and related employees, in order to conduct their fraudulent insurance payment enterprise.
23. It was a further part of the conspiracy that the defendants and others would and did utilize various means of interstate commerce in order to conduct their fraudulent insurance payment enterprise, including: the United States Postal Service; interstate wire communications facilities, including interstate telephone calls and facsimile machine transmissions; and, interstate common carriers such as Federal Express delivery service.

15. In furtherance of the conspiracy and to effect the objects thereof, the following Overt Acts, among others, were committed in the Southern District of Texas, and elsewhere:

1. In or about early 1992, Spring Shadows Glen, Mueck, Peterson, and Seward arranged to utilize the unit for dissociative disorder patients at the hospital for the purpose of conducting a fraudulent insurance payment scheme.
2. On or about February 1, 1992, Mueck agreed to employ Peterson at Spring Shadows Glen as the clinical director of the Dissociative Disorders Treatment Program.
3. On or about February 1, 1992, Peterson agreed to be employed by Spring Shadows Glen as the clinical director of the Dissociative Disorders Treatment Program.
4. On or about February 13, 1992, Seward admitted patient no. 90123548 to Spring Shadows Glen for in-patient care, in part stating in the medical record the patient was admitted for protection from the cult.
5. On or about February 13, 1992, Seward admitted patient no. 90123530 to Spring Shadows Glen for in-patient care, in part stating in the medical record the patient was admitted after a consultation with Peterson revealed the patient was apparently an active satanic cult member.
6. On or about February 13, 1992, Seward and Peterson began treating patient no. 90123548 at Spring Shadows Glen as an in-patient.
7. On or about February 18, 1992, Seward admitted patient no. 90123654 to Spring Shadows Glen for in-patient care, in part stating in the medical record to keep the patient safe from the cult.
8. On or about February 18, 1992, Seward and Peterson began treating patient no. 90123654 at Spring Shadows Glen as an in-patient.
9. On or about late February, 1992, Spring Shadows Glen, Seward and Peterson began billing the insurance company for in-patient treatment for patient no. 90123654.
10. On or about late February, 1992, Spring Shadows Glen, Seward and Peterson began billing the insurance company for in-patient treatment for patient no. 90123548.
11. On or about March 1, 1992, Mueck agreed to employ Seward at Spring Shadows Glen as the clinical medical director of the Dissociative Disorders Treatment Program.
12. On or about March 1, 1992, Seward agreed to be employed by Spring Shadows Glen as the clinical medical director of the Dissociative Disorders Treatment Program.
13. On or about June 8, 1992, Keraga admitted Patient no. 100000080 to Spring Shadows Glen for in-patient care, stating in part in the medical record that the patient had been subjected to cult, satanic, ritualistic events and horrors.
14. On or about June 8, 1992, Keraga and Peterson began treating Patient no. 100000080 at Spring Shadows Glen as an in-patient.
15. On or about June 14, 1992, Keraga admitted Patient no. 100000112 to Spring Shadows Glen for in-patient care stating in part in the medical record that the patient had a history of catastrophic satanic cult abuse with torture since infancy.
16. On or about June 14, 1992, Keraga and Peterson began treating Patient no. 100000112 at Spring Shadows Glen as an in-patient for, among other things, cult abuses.
17. On or about late June, 1992, Spring Shadows Glen, Keraga and Peterson began billing the insurance company for in-patient treatment for patient no. 100000112, including treatment for cult abuses.
18. On or about late June, 1992, Spring Shadows Glen, Keraga and Peterson began billing the insurance company for in-patient treatment for patient no. 100000080, including treatment for cult abuses.
19. On or about July 24, 1992, Seward checked into the possibility of continued insurance coverage for three related patients in the event the patients were removed as dependents from the insurance policy covering the patients.
20. On or about August 4, 1992, Mueck failed to take adequate action, so that insurance money for the patients would continue to be a source of revenue for the hospital, when informed of problems between the staff and nurses of the hospital and Seward and Peterson, including the request to chart behaviors the staff and nurses had not observed, regarding the treatment of dissociative disorder patients and their children.
21. On or about September 3, 1992, Seward entered into the medical record for patient no. 90123654 a fraudulent statement regarding prior sexual activity by the patient.
22. On or about September 4, 1992, a Spring Shadows Glen employee repeated to a review company in an interstate phone call the fraudulent statement entered into the medical record by Seward for patient no. 90123654 regarding prior sexual activity by the patient.
23. On or about September 21, 1992, Mueck failed to take adequate action, so that insurance money for Seward and Peterson’s patients would continue to be a source of revenue for the hospital, when informed of problems other psychiatrists at the hospital had regarding the treatment of Seward and Peterson’s dissociative disorder patients.
24. On or about October 15, 1992, Peterson attended meetings with a Child Protective Services worker and three patients.
25. On or about October 22, 1992, Davis entered into the medical record for patient no. 90123654 a fraudulent statement regarding prior drug use by the patient.
26. On or about October 29, 1992, Mueck approved the payment using Spring Shadows Glen funds of a COBRA insurance plan premium for three patients then in the hospital as in-patients.
27. On or about October 30, 1992, a Spring Shadows Glen employee read to a review company, among other things, the fraudulent statement entered by Davis into the medical record for patient no. 90123654.
28. On or about November 1, 1992, Spring Shadows Glen submitted a bill for room and board in the amount of $9132 for patient no. 90123654 to an insurance company for a treatment period that included the date of the fraudulent statement entered into the patient’s medical record by Davis.
29. On or about November 1, 1992, Spring Shadows Glen submitted a bill for room and board in the amount of $16,979.45 for patient no. 90123530 to an insurance company for a treatment period that included the date of the fraudulent statements made to a review company by Keraga.
30. On or about November 3, 1992, Mueck caused the demotion of a nurse manager critical of Seward, Keraga and Peterson’s treatment of their patients, so that insurance money for Seward, Keraga and Peterson’s patients would continue to be a source of revenue for the hospital.
31. On or about November 19, 1992, Keraga submitted a bill for in-patient treatment for patient no. 90112830 to an insurance company for a time period she had arranged for another physician to treat this patient.
32. On or about November 30, 1992, Peterson’s entity on behalf of Davis submitted a bill to an insurance company totaling $1650 for in-patient treatment for patient no. 90112699.
33. On or about December 3, 1992, Mueck failed to take adequate action, so that insurance money for Seward, Keraga and Peterson’s patients would continue to be a source of revenue for the hospital, after being informed of problems a subcommittee composed of staff at the hospital had regarding the treatment by Seward, Keraga and Peterson of their patients.
34. On or about December 4, 1992, Keraga submitted a bill for in-patient treatment in the amount of $1575 for patient no. 90123530 to an insurance company.
35. On or about December 21, 1992, Mueck approved the payment using Spring Shadows Glen funds of a COBRA insurance plan premium for three patients then in the hospital as in-patients.
36. On or about June 21, 1992 continuing to on or about December 20, 1992, Spring Shadows Glen submitted various bills for room and board totaling $108,087.30 for patient nos. 100000112 and 100000080 to an insurance company for a treatment period that included fraudulent treatments performed by Keraga and Peterson.
37. On or about September 19, 1992 continuing to on or about December 26, 1992 Spring Shadows Glen submitted bills for room and board totaling $107,791.20 for patient no. 100000112 to an insurance company for a treatment period that included fraudulent treatments performed by Keraga and Peterson.
38. On or about January 19, 1993, a Spring Shadows Glen employee under the supervision of Mueck falsely answered an inquiry as to the source of the payment of COBRA insurance plan premiums for three patients then in the hospital as in-patients.
39. On or about January 28, 1993, Mueck approved the payment using Spring Shadows Glen funds of a COBRA insurance plan premium for three patients then in the hospital as in-patients.
40. On or about February 15, 1993, Seward entered into patient no. 90123548’s medical record a statement that on admission the patient had thousands of individual parts and fragments of personalities and had not gotten significantly better, in order to substantiate nearly ten months of hospitalization and associated bills submitted to the patient’s insurance company for treatment of MPD related to cult abuses.
41. On or about February 15, 1993, Seward entered into patient no. 90123654’s medical record a statement that the patient’s prognosis was grim, to substantiate nearly ten months of hospitalization and associated bills submitted to the patient’s insurance company for treatment of MPD related to cult abuses.
42. On or about February 18, 1993, Keraga falsely entered into Patient no. 0090112830’s medical record that the patient was subject to a restraining order concerning the patient’s children.
43. On or about February 19, 1993, Keraga sent a letter to Patient no. 0090112830’s review company that included, among other things, the false statement about a restraining order.
44. On or about February 21, 1993, Keraga entered into Patient no. 0090123530’s medical record a statement that the patient had taken part in various satanic cult rituals and manic ritualistic types of abuse, in order to substantiate nearly a year of hospitalization and associated bills submitted to the patient’s insurance company for treatment of MPD related to cult abuses.
45. On or about February 28, 1993, Peterson submitted bills to two insurance companies totaling $1000 for the same time period of in-patient treatment for patient no. 90112699.
46. On or about March 11, 1993, Keraga submitted bills for in-patient treatment for patients no. 90112830, 100000112, and 100000080 to an insurance company for time periods she had arranged for another physician to treat these patients.
47. On or about March 18, 1993, Keraga entered a letter written to Child Protective Services by patient 0090112830 into that patient’s medical record, in order to substantiate nearly two years of hospitalization and associated bills submitted to the patient’s insurance company for treatment of MPD related to cult abuses.
48. On or about May 7, 1993, Kerega sent a letter to Patient no. 100000080 and Patient no. 100000112’s review company, stating among other things the patients had suffered abuses perpetrated by a satanic cult.
49. On or about June 30, 1993, Peterson submitted a bill to an insurance company totaling $800 for in-patient treatment for patient no. 100000080.
50. On or about July 11, 1993, Keraga entered into patient no. 90112699’s medical record a statement that the patient had been ritualistically abused, in order to substantiate over two years of hospitalization and associated bills submitted to the patient’s insurance companies for treatment of cult abuses.

All in violation of Title 18, United States Code, Sections 371 and 2.

16. The Grand Jury adopts, realleges, and incorporates herein paragraphs 1-11 of the Introduction to this Indictment.
17. Beginning in or about the middle part of 1991, the exact time being unknown to the grand jury, and continuing through the latter part of 1993, in the Southern District of Texas and elsewhere,

Defendants herein, aided and abetted by Spring Shadows Glen, and each other, devised and intended to devise a scheme and artifice to defraud United States insurances companies, as detailed below, and to obtain money and property from United States insurance companies by means of false and fraudulent pretenses and representations, well knowing at the time that the pretenses and representations were false when made, which scheme and artifice to defraud so devised and intended to be devised was, in substance, as follows:

18. The Grand Jury adopts, realleges, and incorporates herein paragraphs 14A-W of the Manner and Means of the Conspiracy listed above.

19. On or about the dates listed below, in the Southern District of Texas, for the purpose of executing the aforementioned scheme and artifice to defraud, the defendants did knowingly mail or cause to be mailed or did receive through the United States Postal Service, in the normal course of business, a thing or matter as described below:

All in violation of Title 18, United States Code, Sections 1341 and 2.

A TRUE BILL,

JAMES H. DEATLEY

UNITED STATES ATTORNEY

LARRY EASTEPP FOREPERSON OF THE GRAND JURY

ASSISTANT U.S. ATTORNEY

AMY LECOCQ

ASSISTANT U.S. ATTORNEY