Plea Agreement — United States v. Palacios (Dkt. 252, S.D. Fla.)

Summary

A plea agreement between the Fraud Section of the Criminal Division of the Department of Justice, the United States Attorney's Office and Omar Palacios in United States v. Omar Palacios, Case No. 24-CR-20155-RAR(s), in the U.S. District Court for the Southern District of Florida, entered February 27, 2025 as Document 252. The defendant agrees to plead guilty to Count 1 of the superseding indictment, which charges a conspiracy under Title 18, United States Code, Section 1349 to commit health care fraud against health care benefit programs, including Medicare and the HRSA COVID-19 Uninsured Program. The parties agree that the loss to the health care benefit programs was more than $1,500,000 but not more than $3,500,000, a sixteen (16) level increase, with a two (2) level Federal Health Care Fraud enhancement. The agreement runs 15 pages.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

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Case 1:24-cr-20155-RAR Document 252 Entered on FLSD Docket 02/27/2025 Page 1 of 15




                               UNITED STATES DISTRICT COURT
                               SOUTHERN DISTRICT OF FLORIDA
                                  Case No. 24-CR-20155-RAR(s)


   UNITED STATES OF AMERICA

   vs.

   OMAR PALACIOS


                  Defendant.
   - - - - - - - - - - - - - - - - -I
                                        PLEA AGREEMENT

          The United States of America, by and through the Fraud Section of the Criminal Division

   of the Department of Justice and the United States Attorney's Office for the Southern District of

   Florida (hereinafter referred to as the "United States"), and Omar Palacios (hereinafter referred to

   as the "Defendant"), enter into the following agreement:

          1.      The Defendant agrees to plead guilty to Count 1 of the Superseding Indictment.

   Count 1 charges that the Defendant knowingly and willfully combined, conspired, confederated,

   and agreed with others, in violation of Title 18, United States Code, Section 1349, to commit health

   care fraud, that is, to knowingly and willfully execute a scheme and artifice to defraud a health

   care benefit program affecting commerce, as defined in Title 18, United States Code, Section

   24(b ), including, Medicare and the COVID-19 Claims Reimbursement to Health Care Providers

   and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program

   ("HRSA COVID-19 Uninsured Program"), and to obtain, by means of materially false and

   fraudulent pretenses, representations, and promises, money and property owned by, and under the

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   custody and control of, said health care benefit programs, in connection with the delivery of and

   payment for health care benefits, items, and services, in violation of Title 18, United States Code,

   Section 134 7. The Defendant acknowledges that he has read the charges against him contained in

   the Superseding Indictment and that the charges have been fully explained to him by his attorney.

   The United States agrees to dismiss Counts 2-7, 8, 9, and 11 of the Superseding Indictment as to

   this Defendant after sentencing.

              2.      The Defendant is aware that the sentence will be imposed by the Court. The

   Defendant understands and agrees that federal sentencing law requires the Court to impose a

   sentence that is reasonable and that the Court must consider the United States Sentencing

   Guidelines and Policy Statements (hereinafter the "Sentencing Guidelines") in determining that

   reasonable sentence. The Defendant acknowledges and understands that the Court will compute

   an advisory sentence under the Sentencing Guidelines and that the applicable guidelines will be

   determined by the Court relying in part on the results of a presentence investigation by the United

   States Probation Office ("Probation"), which investigation will commence after the guilty plea has

   been entered. The Defendant is also aware that, under certain circumstances, the Court may depart

   from the advisory Sentencing Guidelines range that it has computed, and may raise or lower that

   advisory sentence under the Sentencing Guidelines.         The Defendant is further aware and

   understands that while the Court is required to consider the advisory guideline range determined

   under the Sentencing Guidelines, it is not bound to impose that sentence. Defendant understands

   that the facts that determine the offense level will be found by the Court at the time of sentencing

   and that in making those determinations the Court may consider any reliable evidence, including

   hearsay, as well as the provisions or stipulations in this Plea Agreement. The United States and


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   the Defendant agree to recommend that the Sentencing Guidelines should apply pursuant to United

   States v. Booker, that the Sentencing Guidelines provide a fair and just resolution based on the

   facts of this case, and that no upward or downward departures are appropriate other than the

   reductions for acceptance of responsibility. The Court is permitted to tailor the ultimate sentence

   in light of other statutory concerns, and such sentence may be either more severe or less severe

   than the Sentencing Guidelines' advisory sentence.          Knowing these facts, the Defendant

   understands and acknowledges that the Court has the authority to impose any sentence within and

   up to the statutory maximum authorized by law for the offense identified in paragraph 1 and that

   the Defendant may not withdraw the plea solely as a result of the sentence imposed.

          3.        The Defendant also understands and acknowledges, that as to the offense of

   conspiracy to commit health care fraud, as charged in Count 1, the Court may impose a statutory

   maximum term ofimprisonment of up to ten (10) years. In addition to any period of imprisonment

   the Court may also impose a period of supervised release of up to three (3) years to commence at

   the conclusion of the period of imprisonment.          In addition to a term of imprisonment and

   supervised release, the Court may impose a fine of up to the greater of $250,000, or twice the

   pecuniary gain or loss pursuant to 18 U.S.C. § 3571(d).

          4.        The Defendant further understands and acknowledges that, in addition to any

   sentence imposed under paragraph 3 of this Agreement, a special assessment in the total amount

   of $100. 00 will be imposed on the Defendant. The Defendant agrees that any special assessment

   imposed shall be paid at the time of sentencing.

          5.        The Defendant understands and acknowledges that, as a result of this plea, the

   Defendant will be excluded as a provider from Medicare, Medicaid, and all federal health care


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   programs. Defendant agrees to complete and execute all necessary documents provided by any

   department or agency of the federal government, including but not limited to the United States

   Department of Health and Human Services, to effectuate this exclusion within 60 days ofreceiving

   the documents. This exclusion will not affect Defendant' s right to apply for and receive benefits

   as a beneficiary under any federal health care program, including Medicare and Medicaid.

           6.     The Defendant recognizes that pleading guilty may have consequences with respect

   to the Defendant's immigration status if the Defendant is not a natural-born citizen of the United

   States. Under federal law, a broad range of crimes are removable offenses, including the crimes

   to which the Defendant is pleading guilty.           In addition, under certain circumstances,

   denaturalization may also be a consequence of pleading guilty to a crime.                 Removal,

   denaturalization, and other immigration consequences are the subject of a separate proceeding,

   however, and Defendant understands that no one, including the Defendant's attorney or the Court,

   can predict to a certainty the effect of the Defendant' s conviction on the Defendant's immigration

   status. The Defendant nevertheless affirms that the Defendant chooses to plead guilty regardless

   of any immigration consequences that the Defendant' s plea may entail, even if the consequence is

   the Defendant's denaturalization and automatic removal from the United States.

           7.     The Defendant shall cooperate with law enforcement officials, attorneys with the

   United States Department of Justice and United States Attorney' s Office for the Southern District

   of Florida, and with federal regulatory officials charged with regulating or overseeing the Medicare

   program by providing full, complete, and truthful information regarding his knowledge, conduct,

   and actions while involved in health care and by providing active cooperation in ongoing

   investigations if requested to do so. If called upon to do so, the Defendant shall provide complete


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   and truthful testimony before any grand jury or trial jury in any criminal case, in any civil

   proceeding or trial, and in any administrative proceeding or hearing. In carrying out his obligations

   under this paragraph, Defendant shall neither minimize his own involvement nor fabricate,

   minimize or exaggerate the involvement of others. If the Defendant intentionally provides any

   incomplete or untruthful statements or testimony, his actions shall be deemed a material breach of

   this Agreement and the United States shall be free to pursue all appropriate charges against him

   notwithstanding any agreements to forbear from bringing additional charges as may be otherwise

   set forth in this Agreement.

              8.   The Defendant shall provide the Probation Office and counsel for the United States

   with a full, complete, and accurate personal financial statement. If the Defendant provides

   incomplete or untruthful statements in his personal financial statement, this action shall be deemed

   a material breach of this Agreement and the United States shall be free to pursue all appropriate

   charges against him notwithstanding any agreements to forbear from bringing additional charges

   otherwise set forth in this Agreement.

              9.   Provided that the Defendant commits no new criminal offenses and provided that

   he continues to demonstrate an affirmative recognition and affirmative acceptance of personal

   responsibility for his criminal conduct, the United States agrees that it will recommend at

   sentencing that the Defendant receive a three-level reduction for acceptance of responsibility

   pursuant to Section 3E 1.1 of the Sentencing Guidelines, based upon the Defendant's recognition

   and affirmative and timely acceptance of personal responsibility. The United States, however, will

   not be required to make this sentencing recommendation if the Defendant: (1) fails or refuses to

   make a full, accurate, and complete disclosure to the United States and Probation of the


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   circumstances surrounding the relevant offense conduct and his present financial condition; (2) is

   found to have misrepresented facts to the United States prior to entering this Plea Agreement; or

   (3) commits any misconduct after entering into this Plea Agreement, including but not limited to

   committing a state or federal offense, violating any term of release, or making false statements or

   misrepresentations to any governmental entity or official.

              10.    The United States reserves the right to inform the Court and Probation of all facts

   pertinent to the sentencing process, including all relevant information concerning the offenses

   committed, whether charged or not, as well as concerning the Defendant and the Defendant's

   background. Subject only to the express terms of any agreed-upon sentencing recommendations

   contained in this Plea Agreement, the United States further reserves the right to make any

   recommendation as to the quality and quantity of punishment.

              11 .   The United States reserves the right to evaluate the nature and extent of the

   Defendant's cooperation and to make the Defendant' s cooperation, or lack thereof, known to the

   Court at the time of sentencing. If in the sole and unreviewable judgment of the United States the

   Defendant's cooperation is of such quality and significance to the investigation or prosecution of

   other criminal matters as to warrant the Court' s downward departure from the sentence advised by

   the Sentencing Guidelines, the United States may at or before sentencing make a motion pursuant

   to Title 18, United States Code, Section 3553(e), Section 5Kl.1 of the Sentencing Guidelines, or

   subsequent to sentencing by motion pursuant to Rule 35 of the Federal Rules of Criminal

   Procedure, reflecting that the Defendant has provided substantial assistance and recommending a

   sentence reduction. The Defendant acknowledges and agrees, however, that nothing in this

   Agreement may be construed to require the United States to file such a motion and that the United


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   States' assessment of the nature, value, truthfulness, completeness, and accuracy of the

   Defendant's cooperation shall be binding on the Defendant.

           12.    The Defendant understands and acknowledges that the Court is under no obligation

   to grant a motion by the United States pursuant to Title 18, United States Code, Section 3553(e),

   5Kl .1 of the Sentencing Guidelines or Rule 35 of the Federal Rules of Criminal Procedure, as

   referred to in paragraph 11 of this Agreement, should the United States exercise its discretion to

   file such a motion.

   13.     The Defendant admits and acknowledges that the following facts are true and that the

   United States could prove them at trial beyond a reasonable doubt:

                  a.     that the Defendant knowingly and willfully participated in a conspiracy to

                         commit health care fraud, as charged in the Superseding Indictment; and

                  b.     that the Defendant' s participation in the conspiracy to commit health care

                         fraud resulted in an actual or intended loss to the health care benefit

                         programs, including Medicare and HRSA COVID-19 Uninsured Program,

                         of more than $1 ,500,000, but not more than $3 ,500,000.

           14.    Based on the foregoing, the United States and the Defendant agree that, although

   not binding on Probation or the Court, they will jointly recommend that the Court impose a

   sentence within the advisory sentencing guideline range produced by application of the Sentencing

   Guidelines. Although not binding on Probation or the Court, the United States and the Defendant

   further agree that, except as otherwise expressly contemplated in this Plea Agreement, they will

   jointly recommend that the Court neither depart upward nor depart downward under the

   Sentencing Guidelines when determining the advisory Sentencing Guideline range in this case.


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          15.    The United States and the Defendant agree that, although not binding on Probation

   or the Court, they will jointly recommend that the Court make the following findings and

   conclusions as to the sentence to be imposed:

          (a)    Base Offense Level: That the Defendant's base offense level 1s six (6), m

                 accordance with U.S.S.G. § 2B1.1;

          (b)    Loss: That the Defendant's offense level shall be increased by sixteen (16) levels

                 pursuant to U.S.S.G. § 2B1.l(b)(l)(I) because the loss amount was more than

                  $1 ,500,000 but less than $3,500,000; and

          (c)    Federal Health Care Fraud Enhancement: That the Defendant's offense level shall

                 be increased by two (2) levels pursuant to U.S.S.G. § 2B1.l(b)(7)(B)(ii) because

                 the offense constituted a federal health care offense involving a Government health

                 care program, and the loss amount to the Government health care program exceeded

                  $1 ,000,000.

          TOTAL OFFENSE LEVEL - UNADJUSTED                                              24

          (e)    Adjustment for Certain Zero-Point Offenders: That the Defendant's offense level

                  shall be decreased by two (2) levels pursuant to U.S.S. G. § 4C 1.1 ; and

          (f)    Acceptance of Responsibility:          That the Defendant' s offense level shall be

                 decreased by three (3) levels pursuant to U.S.S.G. §§ 3El.l(a) and 3El.l(b)

                 because the Defendant has demonstrated acceptance of responsibility for his

                 offense and assisted authorities in the investigation of and prosecution of his own

                 misconduct by timely notifying authorities of his intention to enter a plea of guilty.

          TOTAL OFFENSE LEVEL - ADJUSTED                                                19


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              16.   The Defendant acknowledges and understands that additional or different

   enhancements or provisions of the Sentencing Guidelines might be applicable, and that neither the

   Court nor Probation are bound by the parties' joint recommendations.

              17.   The Defendant agrees, in an individual and any other capacity, to forfeit to the

   United States, voluntarily and immediately, any right, title, and interest to any property, real or

   personal, that constitutes or is derived, directly or indirectly, from gross proceeds traceable to the

   commission of the offense, in violation of Title 18, United States Code, Section 1349, pursuant to

   Title 18, United States Code, Section 982(a)(7). In addition, the Defendant agrees to forfeiture of

   substitute property pursuant to Title 21, United States Code, Section 853(p ). The property subject

   to forfeiture includes, but is not limited to, a forfeiture money judgment in the sum of

   approximately $280,890 in U.S. currency, which sum represents the value of the property subject

   to forfeiture (the "Forfeiture Money Judgment").

              18.   The Defendant further agrees that forfeiture is independent of any assessment, fine,

   cost, restitution, or penalty that may be imposed by the Court. The Defendant further agrees to

   waive: any constitutional, legal, and equitable claim or defense to the forfeiture of assets in any

   judicial or administrative proceeding; any applicable time limits for administrative or judicial

   forfeiture proceedings; any claim or defense under the Excessive Fines Clause of the Eighth

   Amendment to the United States Constitution; the requirements of Fed. R. Crim. P. 32.2; and any

   appeal of the forfeiture. The Defendant understands that this plea agreement shall serve as a

   withdrawal of any pending administrative forfeiture claim.

              19.   The Defendant also agrees to fully and truthfully disclose the existence, nature and

   location of all assets in which the Defendant has or had any direct or indirect financial interest or


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   control, and any assets involved in the offense of conviction. The Defendant agrees to take all

   steps requested by the United States for the recovery and forfeiture of all assets identified by the

   United States as subject to forfeiture . This includes, but is not limited to, the timely delivery upon

   request of all necessary and appropriate documentation to deliver good and marketable title,

   consenting to all orders of forfeiture, and not contesting or impeding in any way with any criminal,

   civil or administrative forfeiture proceeding concerning the forfeiture.

              20.   In furtherance of the collection of the Forfeiture Money Judgment and restitution

   judgment, the Defendant also specifically agrees to the following:

              (a)   The Defendant agrees that within 10 calendar days of the signing of this Plea

                    Agreement, the Defendant shall submit a completed Financial Disclosure Statement

                    (form provided by the United States), and shall fully disclose and identify all assets

                    in which he has any interest and/or over which the Defendant exercises control,

                    directly or indirectly, including those held by a spouse, nominee, or other third

                    party, whether located within or outside of the United States. The Defendant also

                    agrees to provide, in a timely manner, all financial information requested by the

                    United States Attorney ' s Office and U.S. Probation Office, and upon request, to

                    meet in person to identify assets/monies which can be used to satisfy the Forfeiture

                    Money Judgment and/or the restitution judgment. In addition, the Defendant

                    expressly authorizes the United States Attorney' s Office to obtain a credit report.

              (b)   The Defendant agrees that he will not sell, hide, waste, encumber, destroy, or

                    otherwise devalue any asset without prior approval of the government, until the

                    Forfeiture Money Judgment and his restitution judgment are paid in full. The


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                    Defendant shall also identify any transfer of assets valued in excess of $5,000.00

                    since the date of his Information or when he became aware of the criminal

                    investigation, including the identity of the asset, the value of the asset, the identity

                    of the third party to whom the asset was transferred, and the current location of the

                    asset.

              (c)   The Defendant also agrees to cooperate fully in the investigation and the

                    identification of assets to be applied toward restitution. The Defendant agrees that

                    providing false or incomplete information about his financial assets, or hiding,

                    selling, transferring or devaluing assets and/or failing to cooperate fully in the

                    investigation and identification of assets may be used as a basis for : (i) separate

                    prosecution, including, under 18 U.S.C. § 1001; or (ii) recommendation of a denial

                    of a reduction for acceptance of responsibility pursuant to Sentencing Guidelines §

                    3El.l.

              (d)   The Defendant further agrees to liquidate assets, or complete any other tasks which

                    will result in immediate payment of the Forfeiture Money Judgment and the

                    restitution judgment in full, or full payment in the shortest amount of time, as

                    requested by the government.

              (e)   The Defendant shall notify, within 30 days, the Clerk of the Court and the United

                    States Attorney's Office of: (i) any change of name, residence, or mailing address,

                    and (ii) any material change in economic circumstances that affects the ability to

                    pay the Forfeiture.

              21.   The Defendant acknowledges that because the offenses of conviction occurred after


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   April 24, 1996, restitution is mandatory without regard to the Defendant's ability to pay and that

   the Court must order the Defendant to pay restitution for the full loss caused by his criminal

   conduct pursuant to 18 U.S.C. § 3663A. Furthermore, the Defendant stipulates that he owes

   restitution in the amount of $2,100,000, jointly and severally with his co-conspirators.

          22.     The Defendant is aware that the sentence has not yet been determined by the Court.

   The Defendant is also aware that any estimate of the probable sentencing range or sentence that

   the Defendant may receive, whether that estimate comes from the Defendant's attorney, the United

   States, or Probation, is a prediction, not a promise, and is not binding on the United States,

   Probation or the Court. The Defendant understands further that any recommendation that the

   United States makes to the Court as to sentencing, whether pursuant to this Agreement or

   otherwise, is not binding on the Court and the Court may disregard the recommendation in its

   entirety. The Defendant understands and acknowledges, as previously acknowledged in paragraph

   2 above, that the Defendant may not withdraw his plea based upon the Court' s decision not to

   accept a sentencing recommendation made by the Defendant, the United States, or a

   recommendation made jointly by both the Defendant and the United States.

          23 .    The Defendant is aware that Title 18, United States Code, Section 3742 affords him

   the right to appeal the sentence imposed in this case. Acknowledging this, in exchange for the

   undertakings made by the United States in this Plea Agreement, the Defendant hereby waives all

   rights conferred by Section 3742 to appeal any sentence imposed, including any forfeiture or

   restitution ordered, or to appeal the manner in which the sentence was imposed, unless the sentence

   exceeds the maximum permitted by statute or is the result of an upward departure and/or a variance

   from the Sentencing Guidelines range that the Court establishes at sentencing. In addition to the


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    foregoing provisions, the Defendant hereby waives all rights to argue on appeal that the statute to

    which the Defendant is pleading guilty is unconstitutional and that the admitted conduct does not

    fall within the scope of the statute. The Defendant further understands that nothing in this

    Agreement shall affect the right of the United States and/or its duty to appeal as set forth in Title

    18, United States Code, Section 3742(b). However, if the United States appeals the Defendant's

    sentence pursuant to Section 3742(b), the Defendant shall be released from the above waiver of

    appellate rights. By signing this Agreement, the Defendant acknowledges that he has discussed

    the appeal waiver set forth in this Agreement with his attorney. The Defendant further agrees,

    together with the United States, to request that the Court enter a specific finding that the

    Defendant's waiver of his right to appeal the sentence to be imposed in this case was knowing and

    voluntary.

               24.   For purposes of criminal prosecution, this Plea Agreement shall be binding and

    enforceable upon the Fraud Section of the Criminal Division of the United States Department of

    Justice and the United States Attorney's Office for the Southern District of Florida. The United

    States does not release Defendant from any claims under Title 26, United States Code. Further,

    this Agreement in no way limits, binds, or otherwise affects the rights, powers or duties of any

    state or local law enforcement agency or any administrative or regulatory authority.

               25.   Defendant agrees that if he fails to comply with any of the provisions of this

    Agreement, including the failure to tender such Agreement to the Court, makes false or misleading

    statements before the Court or to any agents of the United States, commits any further crimes, or

    attempts to withdraw the plea (prior to or after pleading guilty to the charges identified in paragraph

    one (1) above), the Government will have the right to characterize such conduct as a breach of this


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   Agreement. In the event of such a breach: (a) the Government will be free from its obligations

   under the Agreement and further may take whatever position it believes appropriate as to the

    sentence and the conditions of the Defendant' s release (for example, should the Defendant commit

    any conduct after the date of this Agreement that would form the basis for an increase in the

   Defendant's offense level or justify an upward departure - examples of which include but are not

    limited to, obstruction of justice, failure to appear for a court proceeding, criminal conduct while

   pending sentencing, and false statements to law enforcement agents, the Probation Officer, or

    Court - the Government is free under this Agreement to seek an increase in the offense level based

   on that post-Agreement conduct); (b) the Defendant will not have the right to withdraw the guilty

   plea; (c) the Defendant shall be fully subject to criminal prosecution for any other crimes which

   he has committed or might commit, if any, including perjury and obstruction of justice; and (d) the

   Defendant waives any protections afforded by Section 1B 1.8(a) of the Sentencing Guidelines, Rule

    11 of the Federal Rules of Criminal Procedure and Rule 410 of the Federal Rules of Evidence, and

   the Government will be free to use against the Defendant, directly and indirectly, in any criminal

   or civil proceeding any of the information, statements, and materials provided by his pursuant to

   this Agreement, including offering into evidence or otherwise using the attached Agreed Factual

   Basis for Guilty Plea.

           26.     This is the entire Agreement and understanding between the United States and the

   Defendant. There are no other agreements, promises, representations or understandings.

                                                  HAYDEN O'BYRNE
                                                  UNITED STATES ATTORNEY
                                                  SOUTHERN DISTRICT OF FLORIDA

                                                  GLENNS. LEON, CHIEF
                                                  FRAUD SECTION, CRIMINAL DIVISION

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Case 1:24-cr-20155-RAR Document 252 Entered on FLSD Docket 02/27/2025 Page 15 of 15




                                       U.S. DEPARTMENT OF JUSTICE
                   ,_/


   Date: d- 11 1" 1~            By:   ~           //-ltr--
                                         hlESYHAYES
                                       ASSISTANT CHIEF
                                       REGINALD CUYLER JR.
                                       MATTHEW R. BELZ
                                       TRIAL ATTORNEYS
                                       FRAUD SECTION, CRIMINAL DIVISION
                                       U.S. DEPARTMENT OF JUSTICE



                                By:

                                       DEFENDANT



    Date: ~)   ~ttS             By:       ~              --
                                       MARISSEL DESCALZO, Esq.
                                       KASSANDRA CABRERA, Esq.
                                                                    ....



                                       COUNSEL FOR OMAR PALA CI OS




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