FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
UNITED STATES OF AMERICA
V. JUDITH A. PETERSON, Ph.D. |
) ) ) ) ) ) ) ) ) |
CRIM. NO. H-97-237
|
INDICTMENT
The United States Grand Jury Charges:
INTRODUCTION
At all times material herein:
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:
COUNT 1
THE CONSPIRACY
Judith A. Peterson, Ph.D.
Richard E. Seward, M.D.
George Jerry Mueck
Gloria Keraga, M.D.
and
Sylvia Davis, M.S.W.
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:
MANNER AND MEANS
All in violation of Title 18, United States Code, Sections 371 and 2.
COUNTS 2-60
THE MAIL FRAUD COUNTS
THE SCHEME
Judith A. Peterson, Ph.D.
Richard E. Seward, M.D.
George Jerry Mueck
Gloria Keraga, M.D.
and
Sylvia Davis, M.S.W.
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:
MANNER AND MEANS
MATTER/THING MAILED/REC’D | PATIENT[S] BY SSG NO.’S | INSURANCE
COMPANY |
To |
||
2 | Check for Room/Board 9/21/92 to 10/04/92 to SSG $12,355.78 | Patient No.
0090123654 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
3 | Check for Room/Board 10/05/92 to 10/18/92 to SSG $10,302.05 | Patient No.
0090123654 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
4 | Check for Dr. Seward services 10/01 to 10/06/92 $715 | Patient No.
0090123654 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
5 | Check to Peterson Psy. Assoc./ J. Peterson services 10/12 & 10/15/92 $400 | Patient No.
0090123654 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
6 | Check to Peterson Psy. Assoc./ S. Davis services on 09/03/92 $150 | Patient No.
0090123654 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
7 | Check for Room/Board 10/19/92 to 11/01/92 to SSG $8766.72 | Patient No.
0090123654 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
8 | Check for Room/Board 11/02/92 to 11/15/92 to SSG $8765.57 | Patient No.
0090123654 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
9 | Check to Dr. Seward for services 10/16 to 10/22/92 $180 | Patient No.
0090123654 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
10 | Check for Room/Board 09/21/92 to 10/04/92 to SSG $13,118.31 | Patient No.
0090123548 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
11 | Check for Room/Board 10/05/92 to 10/18/92 to SSG $10,189.73 | Patient No.
0090123548 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
12 | Check to Peterson Psy. Assoc./J. Peterson service on 10/15/92 $150 | Patient No.
0090123548 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
13 | Check to Dr. Seward for services 10/01 to 10/06/92 $715 | Patient No.
0090123548 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
14 | Check for Room/Board 09/21/92 to 10/04/92 to SSG $15,500.60 | Patient No.
0090123530 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
15 | Check for Room/Board 10/05/92 to 10/18/92 to SSG $16,001.66 | Patient No.
0090123530 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
16 | Check for Room/Board 10/19/92 to 11/01/92 to SSG $16,300.28 | Patient No.
0090123530 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
17 | Check to Dr. Keraga for services 09/26 to 10/02/92 $1575 | Patient No.
0090123530 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
18 | Check to Peterson Psy. Assoc./J. Peterson service var. dates 10/06-11/24/92 $1225 | Patient No.
0090123530 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
19 | Check to Dr. Keraga for services 10/24 to 10/30/92 $1575 | Patient No.
0090123530 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
20 | Check to Dr. Keraga for services 10/31 to 11/06/92 $1575 | Patient No.
0090123530 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
21 | Check to Dr. Keraga for services 11/07 to 11/13/92 $1575 | Patient No.
0090123530 |
Aon/Brookfield | Chicago, IL
Houston, TX |
|
22 | COBRA payment | Patient No. 0090123530 & other family members | Aon/Brookfield | Houston, TX Houston, TX | |
23 | COBRA payment | Patient No. 0090123530 & other family members | Aon/Brookfield | Houston, TX Houston, TX | |
24 | COBRA payment | Patient No. 0090123530 & other family members | Aon/Brookfield | Houston, TX Houston, TX | |
25 | Check for Room/Board 09/06/92 to 12/26/92 to SSG $107,791.20 | Patient no.
100000112 |
Traveler’s | New Haven, CT
Houston, TX |
|
26 | Check for Room/Board 04/18/93 to 05/19/93 to SSG $8273.20 | Patient no. 100000112 | US Behavioral Health | Emeryville, CA Houston, TX | |
27 | Check for Room/Board 01/10/93 to 03/31/93 to SSG $80,774.48 | Patient no. 100000112 | Traveler’s | New Haven, CT
Houston, TX |
|
28 | Check to Peterson Psy. Assoc./various dates of service & providers $7445 | Patient no. 100000112 | Traveler’s | New Haven, CT
Houston, TX |
|
29 | Check for Room/Board 12/28/92 to 12/31/92 to SSG $4419.20 | Patient no. 0090112830 | CIGNA | Sherman, TX Houston, TX | |
30 | Check for Room/Board 01/01/93 to 03/04/93 to SSG $28,520 | Patient no. 0090112830 | US Behavioral Health | Emeryville, CA Houston, TX | |
31 | Check to Houston Psy. Resources/Dr. Keraga service 12/12-12/18/92 $1575 | Patient no. 0090112830 | Traveler’s | New Haven, CT
Houston, TX |
|
32 | Check to Houston Psy. Resources/Dr. Keraga various dates of service $36,000 | Patient nos. 100000080 & 100000112 | Traveler’s | New Haven, CT
Houston, TX |
|
33 | Check to Dr. Keraga/ Houston Psy. Resources/ service 12/19-12/31/92 $2340 | Patient no. 0090112830 | CIGNA | Sherman, TX Houston, TX | |
34 | Check to Peterson Psy. Assoc./various dates of service include. J. Peterson, S. Davis $1120 | Patient no. 0090112830 | CIGNA | Sherman, TX Houston, TX | |
35 | Check for Room/Board various dates to SSG $108,087.30 | Patient nos. 100000080 & 100000112 | Traveler’s | New Haven, CT
Houston, TX |
|
36 | Check for Room/Board 04/12/93 to 04/25/93 to SSG $3260 | Patient no. 100000080 | US Behavioral Health | Emeryville, CA Houston, TX | |
37 | Check for Room/Board 05/12/93 to 06/06/93 to SSG $3360 | Patient no. 100000080 | US Behavioral Health | Emeryville, CA Houston, TX | |
38 | Check to S. Davis/ various dates of service/inc. J. Peterson $838.17 | Patient nos. 100000080 & 100000112 | US Behavioral Health | Emeryville, CA Houston, TX | |
39 | Check for Room/Board various dates to SSG $84,989.93 | Patient nos. 100000080 & 100000112 | Traveler’s | New Haven, CT
Houston, TX |
|
40 | Check for Room/Board 05/10/93 to 05/23/93 to SSG $3220 | Patient no. 100000080 | US Behavioral Health | Emeryville, CA Houston, TX | |
41 | Check to Houston Psy. Resources/ Dr. Keraga service 09/05-12/31/92 $24,975 | Patient no. 100000112 | Traveler’s | New Haven, CT
Houston, TX |
|
42 | Check to Houston Psy. Resources/ Dr. Keraga var. dates service 01/93-04/93 $14,580 | Patient no. 100000112 | Traveler’s | New Haven, CT
Houston, TX |
|
43 | Check to Houston Psy. Resources/ Dr. Keraga var. dates service 01/93-04/93 $16,038 | Patient no. 100000080 | Traveler’s | New Haven, CT
Houston, TX |
|
44 | Letter by Dr. Keraga regarding continuation of insurance | Patient no. 0090112830 | Traveler’s/US Behavioral Health | Houston, TX Emeryville, CA | |
45 | Letter by Dr. Keraga regarding continuation of insurance | Patient nos. 100000080 & 100000112 | US Behavioral Health | Emeryville, CA Houston, TX | |
46 | Check for Room/Board 01/11/93 to 01/24/93 to SSG $20,469.35 | Patient no. 0090112699 | Blue Cross-Blue Shield of Illinois | Chicago, IL
Houston, TX |
|
47 | Check for Room/Board 01/25/93 to 02/07/93 to SSG $21,503.85 | Patient no. 0090112699 | Blue Cross-Blue Shield of Illinois | Chicago, IL
Houston, TX |
|
48 | Check for Room/Board 02/08/93 to 02/21/93 to SSG $16,987.50 | Patient no. 0090112699 | Blue Cross-Blue Shield of Illinois | Chicago, IL
Houston, TX |
|
49 | Check for Room/Board 02/22/93 to 03/07/93 to SSG $15,376.55 | Patient no. 0090112699 | Blue Cross-Blue Shield of Illinois | Chicago, IL
Houston, TX |
|
50 | Check for Room/Board 03/08/93 to 03/21/93 to SSG $16,726.75 | Patient no. 0090112699 | Blue Cross-Blue Shield of Illinois | Chicago, IL
Houston, TX |
|
51 | Check for Room/Board 03/22/93 to 04/04/93 to SSG $16,454.15 | Patient no. 0090112699 | Blue Cross-Blue Shield of Illinois | Chicago, IL
Houston, TX |
|
52 | Check for Room/Board 05/31/93 to 06/13/93 to SSG $9671.60 | Patient no. 0090112699 | Blue Cross-Blue Shield of Illinois | Chicago, IL
Houston, TX |
|
53 | Check for Room/Board 06/14/93 to 06/23/93 to SSG $6689.30 | Patient no. 0090112699 | Blue Cross-Blue Shield of Illinois | Chicago, IL
Houston, TX |
|
54 | Check to Dr. Keraga/ Houston Psy. Resources/ var. dates service $1200 | Patient no. 0090112699 | Blue Cross-Blue Shield of Illinois | Chicago, IL
Houston, TX |
|
55 | Check to Dr. Seward/ var. dates of services $965 |
Patient no. 0090112699 | Gallagher Bassett Services, Inc. | Itasca, IL
Houston, TX |
|
56 | Check to Peterson Psy. Assoc./J. Peterson service 02/03-19/93 $775 | Patient no. 0090112699 | Blue Cross-Blue Shield of Illinois | Chicago, IL
Houston, TX |
|
57 | Check to S. Davis/ service 11/16-30/92 $1,650 | Patient no. 0090112699 | Blue Cross-Blue Shield of Illinois | Chicago, IL
Houston, TX |
|
58 | Check to Peterson Psy. Assoc./J. Peterson var. service 11/92 $815 | Patient no. 0090112699 | Blue Cross-Blue Shield of Illinois | Chicago, IL
Houston, TX |
|
59 | Check to S. Davis/ service 08/25-08/31/93 $750 |
Patient no. 0090112699 | Gallagher Bassett Services Inc. | Itasca, IL Houston, TX | |
60 | Check for Room/Board 08/10/93 to 08/23/93 to SSG $14,543.90 | Patient no. 0090112699 | Gallagher Bassett Services Inc. | Itasca, IL Houston, TX |
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