Elements of the Offense — United States v. Mark Mazzare (E.D. Tex., Dkt. 8, December 2, 2024)

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An Elements of the Offense filing, Document 8, filed 12/02/24, in United States of America v. Mark Mazzare, M.D., No. 6:24-CR-125, in the Eastern District of Texas, Tyler Division. It states that Mazzare is charged in Count One of the Information with a violation of 18 U.S.C. § 371, described as Conspiracy to Defraud the United States and to Purchase Medicare Beneficiary Identification Numbers. The listed elements are that the defendant and at least one other person agreed to commit that crime, that the defendant knew the unlawful purpose and joined in it willfully, and that at least one conspirator knowingly committed at least one overt act described in the Information. It is signed /s/ Brynn A. Schiess and /s/ Robert Austin Wells, with a certificate of service on counsel of record Louis Leichter dated December 2, 2024.

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Case 6:24-cr-00125-JCB-JDL        Document 8      Filed 12/02/24      Page 1 of 2 PageID #: 27




                      IN THE UNITED STATES DISTRICT COURT
                       FOR THE EASTERN DISTRICT OF TEXAS
                                 TYLER DIVISION


 UNITED STATES OF AMERICA                   §
                                            §
 v.                                         §       No. 6:24-CR-125
                                            §
 MARK MAZZZARE, M.D.                        §

                             ELEMENTS OF THE OFFENSE

        Defendant Mark Mazzare, M.D., is charged in Count One of the Information

 with a violation of 18 U.S.C. § 371 (42 U.S.C. § 1320a-7b(b)(4)) (Conspiracy to Defraud

 the United States and to Purchase Medicare Beneficiary Identification Numbers). The

 elements of the offense are as follows:

        1.     That the defendant and at least one other person agreed to commit the crime

               of defrauding the United States and purchasing Medicare Beneficiary

               Identification Numbers, as charged in the Information;

        2.     That the defendant knew the unlawful purpose of the agreement and joined

               in it willfully, that is, with the intent to further the unlawful purpose; and

        3.     That at least one of the conspirators during the existence of the conspiracy

               knowingly committed at least one of the overt acts described in the

               Information, in order to accomplish some object or purpose of the

               conspiracy.




 UNITED STATES V. MAZZARE:
 ELEMENTS OF THE OFFENSE                                                                 PAGE 1
Case 6:24-cr-00125-JCB-JDL       Document 8      Filed 12/02/24    Page 2 of 2 PageID #: 28




                                                  Respectfully submitted,

                                                  DAMIEN M. DIGGS
                                                  UNITED STATES ATTORNEY

                                                  GLENN S. LEON
                                                  CHIEF, FRAUD SECTION

                                                  /s/ Brynn A. Schiess________________
                                                  BRYNN A. SCHIESS
                                                  Assistant Chief
                                                  Pennsylvania Bar Number: 320654
                                                  U.S. Department of Justice
                                                  Fraud Section, Criminal Division
                                                  1100 Commerce Street, Third Floor
                                                  Dallas, Texas 75242-1699
                                                  (202) 374-3484 – direct
                                                  Brynn.Schiess@usdoj.gov

                                                  /s/ Robert Austin Wells____________
                                                  ROBERT AUSTIN WELLS
                                                  Assistant United States Attorney
                                                  Texas Bar Number: 24033327
                                                  Eastern District of Texas
                                                  110 N. College, Suite 700
                                                  Tyler, Texas 75702
                                                  (903) 590-1400 – main
                                                  (903) 590-1437 - fax
                                                  robert.wells3@usdoj.gov


                             CERTIFICATE OF SERVICE

        I certify that a copy of this document was served by electronic mail to counsel of
 record, Louis Leichter, by way of the Court’s CM/ECF on December 2, 2024.


                                                  /s/ Robert Austin Wells____________
                                                  ROBERT AUSTIN WELLS
                                                  Assistant United States Attorney

 UNITED STATES V. MAZZARE:
 ELEMENTS OF THE OFFENSE                                                             PAGE 2


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