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CRIMINAL INDICTMENT
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08/08/ 2006 Document 1
29. In this ordering process, customers filled out an online order form and chose
the type, quantity, and dosage of the controlled substance the customer wished
to purchase. Customers also answered questions about their medical conditions.
No one associated with the defendants checked the accuracy of the information
customers provided, including their identities, ages, and qualifying medical
conditions, such as weight.
OMNIBUS RESPONSE TO DEFENDANTS' MOTIONS
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View REVEAL INFORMATION BEFORE THE GRAND JURY
03/14/2007 DOCUMENT 149
The Indictment alleges, generally, that Defendants Stoufflet and Sobert were
proprietors of businesses which sold controlled substances and other prescription
drugs to customers on demand. (See Indictment [Doc. 1] ¶¶ 18, 19, 27‐32, 34‐38.)
Defendants Andries, Hoang, Hollis, Rashid, and Smith are each physicians who
were employed at various times by Stoufflet and Sobert’s businesses to use their
state medical licenses and DEA registration numbers to facilitate the distribution
of the drugs requested by customers. (Id. ¶¶ 20‐ 33.) The doctors who distributed
the controlled substances did not meet nor speak with the customers, nor was
customer information confirmed, other than the validity of the customers’
payment information.
Reading through such extensive case law leads to the inescapable conclusion that
the type of conduct alleged in this Indictment is such that a reasonable person
could easily find the Defendants to have acted beyond the bounds of medical
practice. Even if the CSA, related case law, and § 1306.04 do not outline all of the
potential ways in which illegitimate prescriptions can be recognized, the conduct
here, authorizing thousands of orders of controlled substance drugs to people
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Defendants never saw, touched, examined, talked to, or had any reason to
believe were who they claimed to be, lies far from any possible vague grey area.
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View CRIMINAL INFORMATION
03/04/2008 Document 1
12. It was further part of the conspiracy ‐ ‐ ‐No one associated with the
conspirators checked the accuracy of the information customers provided,
including their identities, ages, and qualifying medical conditions, such as
weight.
Click to MOTION in Limine to Exclude as Irrelevant
View and Unfairly Prejudicial Testimony
of Paul Southern and Tom Bever by USA
08/19/2008 DOCUMENT 274
I. Background
Defendants are medical doctors charged with conspiracy to violate the Controlled
Substances Act, 18 U.S.C § 846. (Indictment [Doc 1], Count One.) Defendant Smith
is also charged with two substantive counts of distributing controlled substances.
(Indictment [Doc 1], Counts Two and Four.) Among other things, the Indictment
alleges that the Defendant doctors conspired to provide customers prescriptions
drugs, including controlled substances, through a company called eScripts. Id.
Through eScripts, customers requested drugs, including controlled substances,
which they were promptly delivered based solely on an on‐line questionnaire. Id.
The doctors who distributed the controlled substances did not meet nor speak
with the customers, nor was customer information confirmed, other than the
validity of the customers' payment information..
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PRESENTENCE REPORT
11/21/2008
25. The customers also provided information about their medical condition and
other identifying information, including credit card information for payment.
None of the participants determined the accuracy of the information provided
by the customers.
GOVERNMENT'S CLARIFICATION
The operation of the website in this fashion, blatantly enabling drug seekers to
alter and manipulate basic information such as height and weight, was readily
observable on the website, including to the doctors who agreed to approve the
dispensing of controlled substances based on such unverified information.
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