Criminal Indictment — United States v. Rajesh Motibhai Patel (N.D. Ga., Dkt. 1, April 19, 2023)

Summary

Criminal Indictment filed April 19, 2023, in the Northern District of Georgia against Rajesh Motibhai Patel, a Medical Doctor employed as a Primary Care Physician at the Atlanta Veterans Affairs Medical Center in Decatur, Georgia, between December 13, 2015, and February 4, 2020. Counts One through Eight charge, with dates from September 11, 2019, to January 14, 2020, that while acting under color of law he willfully deprived veteran patients of liberty without due process, including the right to bodily integrity (Title 18, United States Code, Section 242), and knowingly engaged in sexual contact without permission (Section 2244(b)). Each count alleges the conduct was without consent and without a legitimate medical purpose.

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       Case 1:23-cr-00133-WMR-JEM         Document 1     Filed 04/19/23   Page 1 of 5
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                      IN THE UNITED STATES DISTRICT COURT
                     FOR THE NORTHERN DISTRICT OF GEORGIA
                               ATLANTA DIVISION



        UNITED ST A TES OF AMERICA
                                                   Criminal Indictment
              V.

        RAJESH MOTIBHAI PA TEL
                                                   No.    1 ,esc 1ss
                                                   UNDER SEAL


    THE GRAND JURY CHARGES THAT:

                                        Introduction

    At all times relevant to this Indictment:

       1. The Veterans Health Administrat ion (VHA) was an agency of the United
    States that operated medical centers and provided health care to nine million
    enrolled veterans throughout the United States annually.
       2. The Atlanta Veterans Affairs Medical Center (V AMC), located in Decatur,
    Georgia, was a medical center operated by the VHA.

       3. Medical Doctors are physicians licensed to practice medicine in the United
    States.
       4. Defendant RAJESH MOTIBHAI PATEL is a Medical Doctor who was
    employed at the VAMC as a Primary Care Physician between December 13, 2015,

    and February 4, 2020.

       5. Defendant PATEL stopped providing patient care on February 4, 2020.

       6. While employed at the VAMC, Defendant PATEL provided medical care

    to veterans, including S.J., S.A., C.B., and A.H.
   Case 1:23-cr-00133-WMR-JEM           Document 1       Filed 04/19/23     Page 2 of 5




    7. Paragraphs 1 through 6 of this Indictment are realleged and incorporate d
into each count as though fully set forth therein.

                                       Count One

    Between on or about September 11, 2019, and on or about October 29, 2019, at

the Atlanta Veterans Affairs Medical Center, in Decatur, DeKalb County,

Georgia, within the Northern District of Georgia, the defendant, RAJESH
MOTIBHAI PATEL, while acting under color of law, willfully deprived S.J. of

liberty without due process of law, including the right to bodily integrity, a right
secured and protected by the Constitution and laws of the United States, by

rubbing S.J.' s clitoris, groping S.J.' s bare breasts, and digitally penetrating S.J.' s
vagina, all without S.J.'s consent and without a legitimate medical purpose,
resulting in bodily injury to S.J.

   All in violation of Title 18, United States Code, Section 242.

                                       Count Two
   Between on or about September 11, 2019, and on or about October 29, 2019, at

the Atlanta Veterans Affairs Medical Center, in Decatur, DeKalb County,
Georgia, within the Northern District of Georgia and the territorial jurisdiction of
the United States, the defendant, RAJESH MOTIBHAI PATEL, knowingly

engaged in sexual contact with S.J., without S.J.' s permission, by intentionally

rubbing S.J.'s clitoris, groping S.J.'s bare breasts, and digitally penetrating S.J.'s
vagina.

   All in violation of Title 18, United States Code, Section 2244(b).


                                            2
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                                       Count Three

    On or about Novem ber 20, 2019, at the Atlanta Vetera ns Affairs Medica l
 Center, in Decatu r, DeKalb County , Georgi a, within the Northe rn Distric t of

 Georgi a, the defend ant, RAJESH MOTIBHAI PATEL, while acting under color of

 law, willful ly depriv ed S.A. of liberty withou t due process of law, includi ng the

 right to bodily integrit y, a right secured and protect ed by the Consti tution and
 laws of the United States, by rubbin g S.A.' s clitoris, rubbin g S.A.' s breasts ,
 digitall y penetra ting S.A.' s vagina , and making sexuall y sugges tive comme nts to
S.A., all withou t S.A.' s consen t and withou t a legitim ate medica l purpos e.

    All in violati on of Title 18, United States Code, Section 242.

                                       Count Four
    On or about Novem ber 20, 2019, at the Atlanta Vetera ns Affairs Medica l
Center , in Decatu r, DeKalb County , Georgi a, within the Northe rn Distric t of
Georgi a and the territor ial jurisdic tion of the United States, the defend ant,
RAJESH MOTIB HAI PATEL, knowin gly engage d in sexual contac t with S.A.,
withou t S.A.' s permis sion, by intentio nally rubbin g S.A.' s clitoris, rubbin g S.A.' s

breasts , and digitall y penetra ting S.A.' s vagina.
   All in violatio n of Title 18, United States Code, Section 2244(b).

                                       Count Five

   Betwee n on or about Septem ber 24, 2019, and on or about Decem ber 19, 2019,
at the Atlanta Vetera ns Affairs Medica l Center, in Decatu r, DeKalb County ,

Georgi a, within the Northe rn Dish·ict of Georgi a, the defend ant, RAJESH

MOTIB HAI PATEL, while acting under color of law, willful ly depriv ed C.B. of

                                            3
   Case 1:23-cr-00133-WMR-JEM         Document 1     Filed 04/19/23     Page 4 of 5




 liberty without due process of law, including the right to bodily integrity, a right
secured and protected by the Constitut ion and laws of the United States, by

squeezing C.B.'s buttocks and touching C.B.'s clitoris, all without C.B.'s consent

and without a legitimate medical purpose.

    All in violation of Title 18, United States Code, Section 242.

                                      Count Six
   From on or about Septembe r 24, 2019, to on or about Decembe r 19, 2019, at
the Atlanta Veterans Affairs Medical Center, in Decatur, DeKalb County,

Georgia, within the Northern District of Georgia and the territorial jurisdictio n of

the United States, the defendant , RAJESH MOTIBH AI PATEL, knowingl y
engaged in sexual contact with C.B., without C.B.'s permissio n, by intentiona lly

squeezing C.B.'s buttocks and rubbing C.B.'s clitoris.
   All in violation of Title 18, United States Code, Section 2244(b).

                                    Count Seven

   On or about January 14, 2020, at the Atlanta Veterans Affairs Medical Center,

in Decatur, DeKalb County, Georgia, within the Northern District of Georgia, the
defendant , RAJESH MOTIBHAI PATEL, while acting under color of law,
willfully deprived A.H. of liberty without due process of law, including the right
to bodily integrity, a right secured and protected by the Constitut ion and laws of
the United States, by rubbing A.H.' s vagina and clitoris, squeezing A.H.' s nipple,

and digitally penetratin g A.H.' s vagina, all without A.H.' s consent and without a

legitimate medical purpose.

   All in violation of Title 18, United States Code, Section 242.

                                          4
  Case 1:23-cr-00133-WMR-JEM         Document 1     Filed 04/19/23      Page 5 of 5




                                    Count Eight
   On or about January 14, 2020, at the Atlanta Veterans Affairs Medical Center,
in Decatur, DeKalb County, Georgia, within the Northern District of Georgia and

the territorial jurisdiction of the United States, the defendant, RAJESH
MOTIBHAI PATEL, knowingly engaged in sexual contact with A.H., without
A.H.' s permission, by intentionally rubbing A.H.' s vagina and clitoris, squeezing
A.H.' s nipple, and digitally penetrating A.H.' s vagina.
   All in violation of Title 18, United States Code, Section 2244(b).




                                          A                                     BILL



RYAN K. BUCHANAN
  United States Attorney
c~A/.S ~M--
ERIN N. SPRITZER
 Assistant United States Attorney
Georgia Bar No. 152374

JE~
 Assistant United States Attorney
Georgia Bar No. 231778

600 U.S. Courthouse
75 Ted Turner Drive SW
Atlanta, GA 30303
404-581-6000; Fax: 404-581-6181




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