Information — United States v. Jennifer Marie Edwards (Central District of California, Document 1)

Summary

An Information in United States of America v. Jennifer Marie Edwards, also known as "Juice Lady" and "120 Lady," No. 8:21-cr-00067-CJC, in the U.S. District Court for the Central District of California, filed 4/16/2021 as Document 1. It charges conspiracy to distribute and to possess with intent to distribute oxycodone under 21 U.S.C. § 846. The Information alleges that from in or around October 2018 to at least May 2019 the defendant, Justin Douglas Cozart, Damoon Joe Navarchi, John Michael Korzelius and others conspired to distribute oxycodone through medical clinics, using cappers who recruited sham patients. Listed overt acts describe recorded calls and texts, including Cozart instructing Navarchi to pay the defendant $500 or $600 in cash. The signature block names Tracy L. Wilkison, Acting United States Attorney.

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Case 8:21-cr-00067-DOC Document1 Filed 04/16/21 Pagelof9 Page ID#:1

FILED

CLERK, U.S. DISTRICT COURT

4/16/2021

CENTRAL DISTRICT OF CALIFORNIA
BY: eva DEPUTY

UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, No. 8:21-cr-00067-CJC
Plaintiff, INFORMATION
Vv. [21 U.S.C. § 846: Conspiracy to
Distribute and to Possess with
JENNIFER MARIE EDWARDS, Intent to Distribute Oxycodone]

aka “Juice Lady” and
“120 Lady,”

Defendant.

The Acting United States Attorney charges:
[21 U.S.C. § 846]

A. INTRODUCTORY ALLEGATIONS

At times relevant to this Information:

1. Oxycodone was the generic name for a highly addictive
prescription analgesic which was classified as a Schedule II
controlled substance, meaning that it had a high potential for abuse,
the drug had an accepted medical use with severe restrictions, and
abuse of the drug or other substances could lead to severe
psychological or physical dependence. The highest dose of short-
acting oxycodone available, and the dose most popular for the drug

abusing population, was the 30 milligram (“30mg”) tablet.
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Case 8:21-cr-00067-DOC Document1 Filed 04/16/21 Page 2o0f9 Page ID #:2

2. “Cappers” were individuals who recruited indigent, drug-
addicted, or otherwise vulnerable individuals (the “sham patients” or
“capper-controlled patients”) to obtain prescriptions for oxycodone
from medical clinics. Sham patients who obtained prescriptions did
not have a legitimate medical need for oxycodone and intended to sell
oxycodone obtained pursuant to the prescriptions (the “fraudulent
oxycodone prescriptions”) on the black market.

3. ChiroMed was a group of chiropractic, medical, and wellness
clinics in Los Angeles, Orange, and San Bernardino Counties.

ChiroMed provided pain management services at medical clinics in
Santa Ana, Fontana, Huntington Park, Redondo Beach, and Inglewood,
among other clinics.

B. OBJECTS OF THE CONSPIRACY

4. Beginning in or around October 2018, and continuing to at
least in or around May 2019, in Los Angeles, Orange, and Riverside
Counties, within the Central District of California, and elsewhere,
defendant JENNIFER MARIE EDWARDS, also known as “Juice Lady” and “120
Lady,” Justin Douglas Cozart, Damoon Joe Navarchi, John Michael
Korzelius, Mayra Barrios, Maricela Barrios, Lashirley Marie Price,
Xavier Mabale, and others conspired with each other to knowingly and
intentionally distribute oxycodone, a Schedule II narcotic drug
controlled substance, in violation of Title 21, United States Code,

Sections 841(a) (1), (b) (1) (C).

on MEANS BY WHICH THE OBJECTS OF THE CONSPIRACY WERE TO BE
ACCOMPLISHED
5. The objects of the conspiracy were to be accomplished, in

substance, as follows:
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Case 8:21-cr-00067-DOC Document1 Filed 04/16/21 Page 3o0f9 Page ID #:3

a. Cozart and Navarchi would operate medical clinics in
Los Angeles, Orange, and Riverside Counties, in part for the purpose
of profiting from the sale of fraudulent oxycodone prescriptions.

b. Mayra Barrios, under the supervision of Cozart and
Navarchi, would oversee the day-to-day management of the medical
clinics, including the issuance of fraudulent oxycodone prescriptions
to sham patients.

on Cozart would retain corrupt doctors and physician
assistants to write fraudulent oxycodone prescriptions in exchange
for cash payments.

d. Price, Xavier Mabale, and other cappers (including co-
conspirators “Capper-2” and “Capper-3”) would recruit sham patients
to obtain fraudulent oxycodone prescriptions from the medical
clinics.

e. Maricela Barrios would schedule appointments for sham
patients, obtain vital signs of sham patients before the sham
patients met with a medical professional, and collect cash payment
from Price, Mabale, and other cappers.

f. Korzelius and other licensed physicians (including co-
conspirator “Doctor-1”), while acting and intending to act outside
the usual course of professional practice and without a legitimate
medical purpose, would meet with fraudulent patients and provide them
with prescriptions for oxycodone, among other drugs.

g. Defendant EDWARDS and other licensed physician
assistants, while acting and intending to act outside the usual
course of professional practice and without a legitimate medical

purpose, and without supervision or direction from any licensed
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Case 8:21-cr-00067-DOC Document1 Filed 04/16/21 Page 4of9 Page ID #:4

physician including Korzelius, would meet with fraudulent patients
and provide them with prescriptions for oxycodone, among other drugs.

D. OVERT ACTS

6. In furtherance of the conspiracy, and to accomplish the
object of the conspiracy, on or about the following dates, defendant
EDWARDS, and others known and unknown to the Acting United States
Attorney, committed various overt acts within the Central District of
California, and elsewhere, including, but not limited to, the
following:

Overt Act No. 1: On or about November 20, 2018, ina

telephone call using coded language, Price told Cozart that Doctor-1
would not verify the legitimacy of fraudulent oxycodone prescriptions
when called by pharmacies, and for that reason, Price preferred for
defendant EDWARDS to write fraudulent oxycodone prescriptions for
Price’s sham patients. Cozart instructed Price to take her sham
patients to the Redondo Beach Clinic because defendant EDWARDS would
be there and Price’s patients would have priority. Cozart also told
Price that Doctor-1 was paid an incentive based on the volume of
prescriptions written.

Overt Act No. 2: On or about November 20, 2018, ina

telephone call using coded language, Navarchi confirmed that Doctor-1
was writing fraudulent oxycodone prescriptions that day, not
defendant EDWARDS. Cozart instructed Navarchi to pay defendant
EDWARDS $500 or $600 in cash and “send her out.”

Overt Act No. 3: On or about November 26, 2018, ina

telephone call using coded language, Cozart told defendant EDWARDS
that she should “just see pain patients” whenever she wanted at the
Redondo Clinic because Doctor-1 was “greedy” and wanted the

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Case 8:21-cr-00067-DOC Document1 Filed 04/16/21 Page5of9 Page ID #:5

Huntington Park Clinic “all to himself.” Cozart advised defendant
EDWARDS that she should not prescribe 120 or more oxycodone pills in
a single prescription because Cozart did not “want somebody coming in
to us and say[ing] we’re over-utilizing opioids.” Cozart said the
other reasons not to prescribe 120 oxycodone pills in one fraudulent
prescription was because “these people, these patients, they start
running their mouth. And then they’re going to say, ‘Yeah, she wrote
me 120.’ And then you got all these jackasses coming to you [saying]
‘Oh, no, increase mine.’” Defendant EDWARDS asked whether the rule
applied “regardless of the marketer” who brought the patient. Cozart
responded that defendant EDWARDS had to “be careful. Make sure it’s
all documented. There has to be, you know, [a] significant reason
why they would get that.”

Overt Act No. 4: On or about November 27, 2018, ina

telephone call using coded language, Cozart told Navarchi that Price
had obtained defendant EDWARDS’s telephone number and was requesting
that defendant EDWARDS write prescriptions “on the side.” Cozart
said that, according to Capper-2, Price had gone to prison for three
years “for doing this shit.” Cozart further observed that Price’s
association with the medical clinics would bring unneeded attention
to them.

Overt Act No. 5: On or about November 28, 2018, ina

telephone call using coded language, Cozart and Navarchi discussed
the text message Mayra Barrios had received from Capper-3. Cozart
said Capper-3 has been complaining about Korzelius’s fraudulent
oxycodone prescriptions “for a while.” Navarchi said they should
stop seeing Capper-3’s sham patients if Capper-3 was not “on board”
and was not “savvy enough with the script.” Cozart suggested that

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Case 8:21-cr-00067-DOC Document1 Filed 04/16/21 Page 6of9 Page ID #:6

Capper-3 should talk to Mabale because Mabale did not have problems
filling fraudulent oxycodone prescriptions, and that maybe Capper-3
needs to “work under” Mabale. Cozart and Navarchi also discussed
fraudulent oxycodone prescriptions for 120 oxycodone pills written by
defendant EDWARDS. Although those patients claimed to have had
“terminal cancer,” Navarchi said “[t]here’s no paperwork in the file.
I looked in the files. Like, they need to have some kind of
bloodwork. Some kind of documentation. Cuz if they, if, God forbid,
someone audits us .. . But the patient just told the doctor [about
the terminal cancer diagnosis.] I mean, you know? I can say I have
cancer too.” Cozart and Navarchi agreed that all sham patients lie
about their maladies.

Overt Act No. 6: On or about December 6, 2018, in a telephone

call using coded language, Cozart and Navarchi discussed the need to
monitor defendant EDWARDS’s files and charts so that her fraudulent
oxycodone prescriptions would not raise suspicions about Doctor-l,
which could cause Cozart and Navarchi to close down the medical
clinics. Navarchi informed Cozart that defendant EDWARDS was
referred to on the streets as the “juice lady” or the “120 lady,”
referring to, respectively, promethazine with codeine cough syrup and
oxycodone.

Overt Act No. 7: On or about December 21, 2018, ina

telephone call using coded language, Cozart instructed defendant
EDWARDS to cease communication with Price and Capper-2 in order to
protect herself. According to Cozart, people like Price and Capper-2
were “supposed to be ghosts” who were “not even supposed to be in the

equation.” Cozart also explained that he wanted to “tighten up”
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Case 8:21-cr-00067-DOC Document1 Filed 04/16/21 Page 7 of9 Page ID #:7

protocols including restricting “our doctors” from “communicat [ing]
with the patients or the marketers.”

Overt Act No. 8: On or about January 17, 2019, in a telephone

call, Cozart told Navarchi that defendant EDWARDS should not be given
any cash because she was always paid by check. Cozart and Navarchi
agreed to pay defendant EDWARDS $1,000 for her services that day.

Overt Act No. 9: On or about January 21, 2019, in a text

message using coded language, Price sent the name of a sham patient

(A

to defendant EDWARDS and wrote underneath “oxc and juice,” referring
to promethazine with codeine cough syrup and oxycodone, respectively.

Overt Act No. 10: On or about January 24, 2019, in a telephone

call using coded language, Cozart advised defendant EDWARDS that
Price planned to bring ten to fifteen sham patients to a clinic to
obtain fraudulent oxycodone prescriptions the next day. Cozart said
that defendant EDWARDS did not have to see the patients but could
just write the refills.

Overt Act No. 11: On or about February 5, 2019, in a telephone

call using coded language, Cozart informed defendant EDWARDS that she
would be providing patients pain injections in the future. Cozart
said pain injections would “look[] good for the file” and that it
would not appear as if defendant EDWARDS prescribed only oxycodone to
patients.

Overt Act No. 12: On or about February 6, 2019, in a telephone

call using coded language, Cozart and Navarchi discussed a report
that Doctor-1 had advised a pharmacy that he did not know defendant
EDWARDS, who was writing fraudulent oxycodone prescriptions under
Doctor-1’s name. Cozart told Navarchi that Doctor-1 had never met
defendant EDWARDS. On or about February 6, 2019, in a telephone

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Case 8:21-cr-00067-DOC Document1 Filed 04/16/21 Page 8of9 Page ID #:8

call, Cozart told Korzelius that Korzelius needed to meet defendant
EDWARDS.

Overt Act No. 13: On or about February 7, 2019, in a text

message using coded language, Price wrote in a text message to
defendant EDWARDS, “oxy,” followed by five sham patient names and

(A

birth dates, and “norco/juice,” followed by two sham patient names.

Overt Act No. 14: On or about February 8, 2019, in a telephone

call using coded language, Cozart discussed with Price the pharmacies
that filled fraudulent oxycodone prescriptions Price had obtained
using sham patients. Cozart explained to Price that Cozart did not
want pharmacies to call doctors associated with the medical clinics.
Price informed Cozart that there were no questions asked of Price
when Price dropped off fraudulent oxycodone prescriptions. Price
informed Cozart that Price had asked defendant EDWARDS to prescribe
different medications alongside oxycodone.

Overt Act No. 15: On or about February 26, 2019, in a text

message using coded language, Price wrote to defendant EDWARDS,
//
//
Case 8:21-cr-00067-DOC Document1 Filed 04/16/21 Page 9of9 Page ID #:9

“Mommy I need for Oxys 120 in the last one or Norco in a juice and I

have the package for you now so I can send me and there to get it.”

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TRACY L. WILKISON
Acting United States Attorney

BRANDON D. FOX
Assistant United States Attorney
Chief, Criminal Division

BENJAMIN R. BARRON
Assistant United States Attorney
Chief, Santa Ana Branch Office

JENNIFER L. WAITER

Assistant United States Attorney
Deputy Chief, Santa Ana Branch
Office

SCOTT D. TENLEY

ANDREW BESHAT

Assistant United States Attorneys
Santa Ana Branch Office


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