Amended Criminal Complaint: State of Wisconsin v. Debbie Long (Milwaukee County Circuit Court, Case No. 2026CF002103)
Summary
The Wisconsin Department of Justice filed this amended criminal complaint against Debbie Long, an owner and the administrator of Pinnacle Home Health Care, LLC, in Milwaukee County Circuit Court on 05-05-2026 (Case No. 26-CF-2103). The State alleges that Long defrauded Wisconsin Medicaid of almost $2.2 million by billing for personal care services that did not take place, and fraudulently obtained a $219,072 Paycheck Protection Program loan by inflating Pinnacle’s workforce and payroll expenses. It also alleges that Long used the proceeds to buy a restaurant, a car and a car wash, moving money for the car and car wash through shell companies. The five counts charge theft by fraud, fraud against a financial institution, wire fraud against a financial institution and two counts of money laundering.
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Case 2026CF002103 Document 4 Filed 05-05-2026 Page 1 of 35
FILED
05-05-2026
Anna Maria Hodges
Clerk of Circuit Court
STATE OF WISCONSIN CIRCUIT COURT MILWAUKEE COUNTY 2026CF002103
STATE OF WISCONSIN,
Plaintiff,
v. Case No. 26-CF-2103
DEBBIE LONG
9048 W FOREST HOME AVE,
MILWAUKEE, WI 53228
DOB: 02-12-1982,
Defendant.
AMENDED CRIMINAL COMPLAINT
The Wisconsin Department of Justice, pursuant to its authority under Wis.
Stat. § 49.846(2), files this criminal complaint against Debbie Long (DOB: 02-12-
1982).
Debbie Long1 was an owner and the administrator of Pinnacle Home Health
Care, LLC (Pinnacle). The State alleges that she defrauded Wisconsin Medicaid of
almost $2.2 million by billing for personal care services which did not take place.
Furthermore, Long fraudulently obtained a $219,072 loan from the Paycheck
Protection Program by inflating the size of Pinnacle’s workforce and payroll expenses.
1 The defendant’s maiden name is Lewis, and she often went by “Debbie Lewis” or “Deb Lewis.” For
clarity and consistency, this complaint will use her married name even when referring to documents
or witness statements that use her maiden name.
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Lastly, the State alleges that Long used the proceeds from her unlawful
activities to purchase a restaurant, a car, and a car wash. As for the purchase of the
car and car wash, Long helped funnel her ill-gotten gains through several shell
companies in a series of transactions designed to conceal the origin of the funds.
Count 1
THEFT BY FRAUD
GREATER THAN $100,000
On or between approximately March 13, 2017, and August 12, 2022 , in the
city of Milwaukee, Milwaukee County, Wisconsin, the defendant, Debbie Long, did
obtain title to property of another person by intentionally deceiving the person with
a false representation which was known to be false, made with intent to defraud,
which did defraud the person to whom it was made, the value of which property
exceeded $100,000, belonged to the same owner, and was obtained pursuant to a
single intent and design and in execution of a single deceptive scheme, contrary to
Wis. Stat. §§ 943.20(1)(d), (3)(cm), and 971.36(3)(a).
Pursuant to Wis. Stat. § 939.50(3)(f), upon conviction for this offense, a Class F
felony, the defendant may be fined not more than $25,000, or imprisoned not more
than twelve years and six months, or both.
Count 2
FRAUD AGAINST A FINANCIAL INSTITUTION
GREATER THAN $100,000
On or about May 8, 2020, in the city of Milwaukee, Milwaukee County,
Wisconsin, the defendant, Debbie Long, did obtain money, funds, credits, assets,
securities, or other property owned by or under the custody or control of a financial
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institution by means of false pretenses, representations, or promises where the value
of the money exceeded $100,000, contrary to Wis. Stat. §§ 943.82(1) and 943.91(5).
Pursuant to Wis. Stat. § 939.50(3)(e), upon conviction for this offense, a Class E
felony, the defendant may be fined not more than $50,000, or imprisoned not more
than fifteen years, or both.
Count 3
WIRE FRAUD AGAINST A FINANCIAL INSTITUTION
On or about May 5, 2020, in the city of Milwaukee, Milwaukee County,
Wisconsin, the defendant, Debbie Long, did transmit or cause to be transmitted
electrically, electromagnetically, or by light any signal, writing, image, sound, or data
for the purpose of committing a financial crime, contrary to Wis. Stat. § 943.90.
Pursuant to Wis. Stat. § 939.50(3)(h), upon conviction for this offense, a
Class H felony, the defendant may be fined not more than $10,000, or imprisoned not
more than six years, or both.
Count 4
MONEY LAUNDERING GREATER THAN $100,000
On or about August 28, 2020, in the city of Milwaukee, Milwaukee County,
Wisconsin, the defendant, Debbie Long, did knowingly conduct a transaction
involving proceeds that the defendant knew were derived from unlawful activity, and
the total value of the proceeds exceeded $100,000, contrary to Wis. Stat.
§§ 943.895(2)(a)1 and (3)(e).
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Pursuant to Wis. Stat. § 939.50(3)(f), upon conviction for this offense, a Class F
felony, the defendant may be fined not more than $25,000, or imprisoned not more
than twelve years and six months, or both.
Count 5
MONEY LAUNDERING GREATER THAN $100,000
PARTY TO A CRIME
On or between approximately March 5, 2020, and December 23, 2020, in the
city of Milwaukee, Milwaukee County, Wisconsin, the defendant, Debbie Long, did
knowingly conduct a transaction involving proceeds that the defendant knew were
derived from unlawful activity that was designed in whole or in part to conceal or
disguise the nature, location, source, ownership, or control of the proceeds obtained
through unlawful activity, the total value of the proceeds exceeded $100,000, and the
violations were pursuant to a single intent and design, contrary to Wis. Stat.
§§ 943.895(2)(a)4.a., (2)(c), and (3)(e).
Furthermore, under Wis. Stat. § 939.05, the defendant may be charged and
convicted of the commission of the crime by directly committing the crime, by
intentionally aiding and abetting the crime, or by being a party to a conspiracy with
another to commit the crime or advising, hiring, counselling or otherwise procuring
another to commit the crime.
Pursuant to Wis. Stat. § 939.50(3)(f), upon conviction for this offense, a Class F
felony, the defendant may be fined not more than $25,000, or imprisoned not more
than twelve years and six months, or both.
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Facts Constituting the Charged Offenses
I, the Complainant, am an Investigator with the Wisconsin Department of
Justice, Medicaid Fraud Control and Elder Abuse Unit (MFCEAU). MFCEAU
investigates and prosecutes civil and criminal offenses related to Medicaid providers
and entities that receive Medicaid funding. 42 C.F.R. § 1007.11.
I base this complaint upon my investigation, my training and experience and
my review of business and State records. I have found business and State records to
be reliable in the past.
This case was also investigated by Special Agents Ken Folkers and David Hall
of the Division of Criminal Investigation at the Wisconsin Department of Justice,
Detective Brian Wallender of the Greenfield Police Department, and Data Analyst
Amber Dieter of MFCEAU. Special Agent Folkers conducted all the witness
interviews either alone or with Detective Wallender. As Special Agents Folkers and
Hall, Detective Wallender, and Analyst Dieter are all involved in law enforcement,
I consider them to be reliable and trustworthy.
The identities of the witnesses are known to me, and they are identified in this
complaint by pseudonyms.
This complaint contains a summary of facts necessary to establish probable
cause; it does not contain all facts related to the investigation.
Based upon information and belief, I state:
Background
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Wisconsin Medicaid is a joint federal and state program that provides medical
coverage to indigent Wisconsin residents and is administered by the Wisconsin
Department of Health Services (DHS). Residents that receive coverage from
Wisconsin Medicaid are called “members.”
Pinnacle Home Health Care, LLC (Pinnacle) provided “personal care services”
to Medicaid members. “Personal care services” are “medically oriented activities
related to assisting a recipient with activities of daily living” so that members may
continue to live in their home and community. Wis. Admin. Code DHS § 107.112(1)(a).
Personal care services may include assistance with bathing, getting in and out of bed,
mobility and ambulation, skin care, toileting, dressing and undressing, and meal
preparation. Wis. Admin. Code DHS § 107.112(1)(b). A worker who provides personal
care services is called a “personal care worker” (PCW).
At all times relevant to this complaint, Debbie Long was an owner and the
administrator of Pinnacle. Moreover, Pinnacle was located, and Long resided in, the
city of Milwaukee, Milwaukee County, Wisconsin.
Payment from Wisconsin Medicaid to Pinnacle
To receive compensation from Wisconsin Medicaid, Pinnacle submitted claims
for reimbursement to DHS via the online ForwardHealth Portal or submitted the
claims through a Health Maintenance Organization (HMO). See Wis. Admin. Code
DHS § 106.03. A claim for reimbursement may seek reimbursement for different
services for different Medicaid members on different days. But each individual service
for each individual member is denoted by its own individual detail line within the
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claim for reimbursement and contains the member’s Medicaid identification number,
the procedure code, the number of units, and the charge amount. See Wis. Admin.
Code DHS §§ 106.03(2), 108.02(4).
Pinnacle was responsible for the truthfulness and accuracy of its
reimbursement claims. Wis. Admin. Code DHS § 106.03(2)(c).
Medicaid providers cannot receive reimbursement for services that were never
performed or for expenses that were never incurred. See Topic #516 in the Personal
Care Section of the ForwardHealth Online Handbook for BadgerCare Plus and
Medicaid.2
Pinnacle’s Scheme to Defraud Wisconsin Medicaid
An analysis of Pinnacle’s claims for reimbursement and the witness interviews
show that Pinnacle committed widespread fraud against Wisconsin Medicaid by
submitting fraudulent claims for reimbursement.
From March 13, 2017, to August 12, 2022,3 Pinnacle was paid approximately
$8,277,000 in connection with approximately 204,222 detail lines. An analysis of
approximately 31,825 of those detail lines indicates that Pinnacle defrauded
Wisconsin Medicaid of at least $2.1 million during that time for services that were
never performed.
Pinnacle used several methods to commit this fraud.
2 All subsequent references to a specific topic number refer to a topic in the Personal Care Section for
BadgerCare Plus and Medicaid in the ForwardHealth Online Handbook,
https://www.forwardhealth.wi.gov/WIPortal/Subsystem/KW/Display.aspx?ia=1&p=1&sa=47.
3 There are three important dates for a claim for reimbursement: (1) the date that the service was
provided, (2) the date that the claim was submitted for payment, and (3) the date that the claim was
paid. For clarity and consistency, this complaint only refers to the date that the claim was paid.
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Method #1: Billing for Impossible or Improbable Hours of Service
The procedure code for personal care services is T1019, and each unit of that
code accounts for 15 minutes of personal care services. See Topic #2481. Thus, there
are four units in an hour and a maximum of ninety-six units in a day.
Pinnacle was paid approximately $750,752 for personal care services in
connection with individual detail lines that claimed that a PCW performed more than
ninety-six units of personal care services in a day for one member, which is
impossible. For example, Pinnacle submitted one claim (which was paid) for 54,200
units (which is equal to 13,550 hours) of personal care services in one day for one
member.
Pinnacle was also paid approximately $819,994 in connection with individual
detail lines that claimed a PCW performed 48 units of personal care services or more
(i.e., 12 hours and above) in one day for one member. This amount of service, given
the hands-on nature of personal care service, is highly improbable.
In total, Pinnacle was paid more than $1.57 million in connection with claims
for personal care services that were either impossible or improbable.
Method #2: Billing for Services When No Services Were Ever Rendered
Pinnacle was paid approximately $141,397 for services that the PCW, in an
interview, said he or she never provided.
Likewise, Pinnacle was paid approximately $14,006 for services that the PCW
could not have provided because the PCW said that he or she did not even know the
member.
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In addition, Pinnacle was paid approximately $92,569 for services that the
member said he or she never received.
In total, Pinnacle was paid in excess of $247,000 for services that either the
PCW or the member said never took place.
Method #3: Billing for Services in Excess of Those That Were Rendered
Pinnacle was paid approximately $67,198 for claimed services that the
member, in an interview, said were more than the services that were rendered by the
PCW.
In a similar vein, Pinnacle was paid approximately $62,223 for claimed
services that the PCW said were more than the services that he or she provided.
In total, Pinnacle was paid in excess of $129,000 for claimed services that were
more than the services that were rendered.
Method #4: Billing While the Member was in the Hospital or Incarcerated
Medicaid does not reimburse personal care services if the member is in the
hospital. Wis. Admin. Code DHS §§ 107.03(18), 107.112(4)(a). Medicaid also does not
reimburse personal care services if the member is incarcerated. Wis. Admin. Code
DHS § 107.03(13)–(15).
In total, Pinnacle was paid in excess of $28,000 for personal care services that
were purportedly provided while the member was either in the hospital or was
incarcerated.
Method #5: Billing for Misrepresentation of Need
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Pinnacle was paid in excess of $219,000 for services where the interview with
the member revealed that the member’s need for services was misrepresented.
For example, Pinnacle stated that one member lived alone, which increased
the level of services that the member qualified for, when the member actually lived
with two PCWs. For another member, a child, the level of services was not supported
by medical records or an Individual Education Plan from school.
Method #6: Billing for Travel Expenses That Were Never Incurred
In addition to personal care services, Pinnacle could seek reimbursement for
travel expenses incurred by PCWs travelling from their home to the home of the
member. See Topics #2481 and 2485. Witness interviews and claims analysis,
however, indicates that Pinnacle sought reimbursement for travel expenses that the
PCW never incurred because the PCW lived with the member.
In total, Pinnacle was paid in excess of $43,000 for travel expenses the PCW
never incurred.
Payroll Analysis
In addition to the claims data and witness interviews, a comparison between
Pinnacle’s payroll expenses and its reimbursement claims supports that Pinnacle
committed widespread fraud against Wisconsin Medicaid. Otherwise, if its claims
were legitimate, then Pinnacle paid its workers far less than the federal and state
minimum wage of $7.25 per hour. 29 U.S.C. § 206(a)(1)(C); Wis. Stat. § 104.035(1)(a).
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From March 13, 2017, to August 12, 2022, Pinnacle sought reimbursement for
628,019.5 hours of claimed personal care services.4 During that same time, Pinnacle
reported to the Wisconsin Department of Workforce Development (DWD) that it paid
$2,578,972.74 in total wages to its employees. See Wis. Stat. § 108.205; Wis. Admin.
Code DWD § 111.02. So, if both figures are accurate, then Pinnacle paid its employees
an average of $4.10 per hour.
The disparity between claimed personal care services and wages is even more
stark when examining Pinnacle’s bank accounts for potential payroll expenses.
(Pinnacle had seven bank accounts spread out across three banks.) After totaling all
checks that appeared to be for payroll expenses (i.e., something about payroll was
written in the memo line or it was a check to an employee) and cash withdrawals
(which might have been for payroll), I identified $1,870,086.17 as possible payroll
expenses. Using that as the total payroll amount, and assuming that Pinnacle’s
reimbursement claims were accurate, then Pinnacle paid its employees an average of
$2.98 per hour.
Put simply, Pinnacle’s lack of payroll expenses in comparison with its claims
for reimbursement undercuts the legitimacy of those claims. After all, if Pinnacle
performed all the personal care services it claimed, then attracting and maintaining
a workforce while paying far less than minimum wage would have been both illegal
and nearly impossible.
Red Dot Real Estate & Housing Program
4 Since each unit of personal care services accounts for 15 minutes of service, the total hours of personal
care services can be determined by dividing the total claimed units by four. See Topic #2481.
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Before summarizing some of the interviews with PCWs and members
associated with Pinnacle, it is important to note that many of them referred to the
Red Dot Real Estate & Housing Program (Red Dot).
Although the name suggests that the Red Dot is a charity or government
program, it is really a shell company controlled by Debbie Long. 5 Wisconsin
Department of Financial Institutions (DFI) records indicate that its principal office
is located at 4330 South 38th Street in Greenfield, Wisconsin, which was Debbie
Long’s home address. Furthermore, Red Dot had accounts at three different banks
(Educator’s Credit Union, US Bank, and BMO Harris Bank), and Debbie Long was
the sole authorized user for all the accounts except for a checking account at BMO
Harris Bank (BMO Harris). For that account, no. XXXXXX9624, no money was
withdrawn from the account during the alleged course of conduct, and the only
banking activity of note was a $200,000 deposit on August 31, 2020, from the Levi
Day Memorial Trust, which, as will be explained further below, was another shell
company controlled by Debbie Long.
Member Interviews
PCW 1
According to DHS records, PCW 1 provided care to Member 1. During an
interview, PCW 1 said that she started working for Pinnacle after she saw an
5 Charitable organizations must register with the Wisconsin Department of Financial Institutions
(DFI) before soliciting contributions in Wisconsin. Wis. Stat. § 202.12(1)(a). Red Dot has never
registered with DFI as a charitable organization.
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advertisement and contacted the manager “Deb.” PCW 1 said that “Deb” is a black
female.
PCW 1 said that “Deb” assigned her to work at a group home occupied by four
males. PCW 1 said that she worked seven to eight hours per shift and completed a
daily log that was ultimately given to “Deb.” PCW 1 said that she worked for Pinnacle
for a couple months at the group home, left, then came back and worked a couple
more months.
PCW 1 was asked whether she provided care to Member 1. PCW 1 said that
she did not recognize Member 1’s name. Detective Wallender then showed PCW 1 a
picture of Member 1, and PCW 1 said that she did not know the person in the
photograph.
In a subsequent interview, PCW 1 was shown numerous documents related to
her employment that were given to DHS, including her employment application,
employee orientation, and a performance review. PCW 1 said that she did not
recognize the signature that purportedly belonged to her on any of the documents.
PCW 1 was also shown signed timesheets regarding her purported care of
Member 1. PCW 1 denied signing any of the timesheets and reiterated that she does
not know Member 1.
Altogether, Pinnacle was paid $10,921.80 by Wisconsin Medicaid for PCW 1’s
purported care of Member 1.
PCW 2
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DHS records indicate that PCW 2 provided personal care services to Members
2 and 3.
PCW 2 said she worked for Pinnacle for three months in 2017 and provided
personal care to her neighbor, Member 2. PCW 2 said she worked six hours a day,
Monday through Friday. Pinnacle, however, continued to submit timesheets on into
2018.
During the interview, PCW 2 never mentioned providing care to Member 3.
In total, Pinnacle was paid $17,154.42 for care allegedly provided to Member 2
by PCW 2 after PCW 2 quit providing such care. Pinnacle was also paid $19,274 for
care to Member 3.
Member 4
DHS records show that Member 4 received personal care services from
Pinnacle. In an interview, Member 4 denied ever receiving personal care services
from Pinnacle (or any other agency). Member 4 said he knew Debbie Long because he
had a child with her sister.
Pinnacle was paid $15,874 for personal care services that were purportedly
provided to Member 4.
PCW 3 and Member 5
Member 5 received personal care services from his wife, PCW 3. Member 5 said
that his wife was paid by Pinnacle for her care services until DHS initiated a payment
suspension.
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SA Folkers and Detective Wallender later visited Pinnacle’s office at 6815 West
Capitol Drive in Milwaukee. They observed that there were timesheets in an open
folder outside of the office door. There were nine timesheets regarding PCW 3’s care
for Member 5, and all of them contained the signatures of PCW 3 and Member 5.
None of the timesheets indicated that PCW 3 incurred travel expenses, which makes
sense since they lived together as a married couple.
In a later interview, Member 5 said that he and PCW 3 continued to turn in
timesheets to Pinnacle in the hope of PCW 3 being paid again at some point.
Despite PCW 3 never incurring travel expenses while caring for her husband,
Member 5, Pinnacle received $11,745 in reimbursements from Wisconsin Medicaid
for travel expenses.
PCW 4 and Member 6
Member 6 told SA Folkers that he was introduced to Pinnacle after requesting
information about housing resources from the Red Dot. Member 6 said that he
subsequently received a $15 gift card, hygiene products, and a list of potential
housing.
Member 6 said that Debbie Long owned Pinnacle.
Member 6 said he received personal care services from PCW 4, his cousin,
through Pinnacle, for less than a year. Member 6 said that he left Pinnacle after it
stopped paying PCW 4.
PCW 4 said that after she quit working with Pinnacle, she was contacted by a
person from Pinnacle and was told that “services are back active.” PCW 4 said she
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had no further communication with Pinnacle and did not turn in any more timesheets
after her last payment on January 17, 2020.
Nevertheless, Pinnacle was paid $8,425 for personal care services that
supposedly took place after both Member 6 and PCW 4 said they ended their
association with Pinnacle.
PCW 5 and Member 7
PCW 5, through Pinnacle, provided services to her son, Member 7. PCW 5
stopped submitting timesheets to Pinnacle after PCW 5 was informed that Pinnacle
was being audited by the state.
However, Pinnacle continued to submit claims for PCW 5’s services after
PCW 5 stopped submitting timesheets. In total, Pinnacle was paid $16,920 for
personal care services after PCW 5 stopped submitting timesheets.
PCW 6 and Member 8
Member 8 received personal care services through her daughter, PCW 6.
Member 8 said she learned about Pinnacle after receiving a flyer in the mail.
Member 8 also said that she was part of the Red Dot. Member 8 said she picked up
$100 in cash at Pinnacle’s office as part of Red Dot. Member 8 said the money helped
with her rent, and it was the reason that she decided to receive care through Pinnacle.
Member 8 further said that she stopped receiving care through Pinnacle about
two years prior to the interview, which took place on February 10, 2022. PCW 6 said
that she provided two hours of personal care service a day to Member 8 and that they
have not been with Pinnacle for almost three years.
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Overall, Pinnacle was paid $47,698.04 for services that were billed after
Member 8 and PCW 6 stopped working with Pinnacle or for services that were billed
in excess of two hours per day.
PCW 7 and Member 9
DHS records show that Pinnacle billed for services on behalf of PCW 7 and
Member 9. Member 9 said he met with Debbie Long to fill out and sign paperwork.
Member 9 also said that Long came to his house, but he was never told that he was
approved for care services with Pinnacle. Member 9 said, “I got nothing.”
Likewise, PCW 7 said that she planned on proving care to Member 9, but
Member 9 was never approved for care services with Pinnacle. PCW 7 denied ever
providing care services to Member 9 and denied ever being paid by Pinnacle.
In total, Pinnacle was paid $32,593.42 for PCW 7’s “services” to Member 9.
PCW 8 and Member 10
PCW 8 provided care to his son, Member 10. PCW 8 said he provided care for
a year or two and left Pinnacle in the summer of 2019.
Pinnacle was paid $8,886.37 for services that PCW 8 ostensibly provided after
he quit.
PCW 9 and Member 11
PCW 9 provided care to her daughter, Member 11. PCW 9 said she worked
with Pinnacle from 2016 until December 4, 2020. PCW 9 said she did not turn in any
timesheets after her last paycheck and that she never documented travel time as she
lived with her daughter.
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Pinnacle was paid $15,767.20 in travel reimbursements for PCW 9.
Member 12
Member 12 said that she received care from Pinnacle from 2017 through 2019.
Prior to receiving care through Pinnacle, Member 12 met with Debbie Long, and Long
told her about Red Dot. Member 12 said that Red Dot was a financial program to help
adults with disabilities. Member 12 was paid $100 per month to help buy personal
items. Member 12 said she received personal checks from Long.
Member 12 also said that her PCW provided care three times a week. DHS
claims data, however, shows that Pinnacle claimed to have provided personal care
services for seven days a week.
Pinnacle was paid $66,774.61 for personal care services in excess of what
Member 12 said was rendered.
PCW 10 and Member 13
PCW 10 said that she provided personal care to Member 13 before PCW 10,
eventually, needed personal care services for herself. PCW 10 also said that
Member 13 lives at her residence.
DHS claims data shows that Member 13 received care services from Pinnacle
from April 12, 2017, to December 6, 2020. PCW 10, however, said that she was
unaware of Member 13 receiving any personal care services after PCW 10 started
receiving personal care services from Pinnacle on March 21, 2018.
Pinnacle was paid $111,482.63 for personal care services and travel expenses
related to Member 13 that never occurred.
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Member 14
Member 14 said he received personal care services from Pinnacle for just one
month. Pinnacle, however, submitted claims for reimbursement over the course of
ten months.
Pinnacle was paid $20,184.96 for personal care services that it ostensibly
provided over an additional nine months.
Member 15
Member 15 said she received personal care services, for twelve hours a day,
from Pinnacle from 2019 through 2020. Nevertheless, Pinnacle continued to bill for
personal care services for Member 15 after 2021, and also billed for more than twelve
hours of care in a day.
Pinnacle was paid $1,712.94 for fraudulent claim submissions in connection
with Member 15.
Member 16
Member 16 told SA Folkers that he started receiving personal care services
through Pinnacle in 2018 and was only with Pinnacle for a year. Pinnacle, however,
continued to submit claims for reimbursement regarding Member 16 into 2021.
Pinnacle was paid $29,974.36 for claims for reimbursement that took place
after Member 16 said he stopped receiving care through Pinnacle.
Debbie Long Submitted Fraudulent Claims for Reimbursement to DHS
As recounted below, several factors show that Debbie Long was responsible for
the fraudulent claims that Pinnacle made to DHS and to HMOs.
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Debbie Long Ran Pinnacle
According to records from DFI, Debbie Long filed articles of incorporation to
organize Pinnacle as a limited liability company in January 2015. Long also listed
herself as the registered agent and as an organizer (with an additional person listed
as an organizer). After incorporating the business, Long filed all of Pinnacle’s annual
reports with DFI.
Long also held herself out as the administrator of Pinnacle in all interactions
with DHS, with Health Maintenance Organizations (HMOs), and in hearings before
the Division of Hearings and Appeals (DHA).
Furthermore, as was explained above, interviews with witnesses show that
Long oversaw Pinnacle’s day-to-day operations.
Debbie Long Had the Ability to Submit Claims for Reimbursement
As mentioned above, Pinnacle had to submit claims for reimbursement to DHS
through the online ForwardHealth Portal. See Wis. Admin. Code DHS § 106.03. But
before someone can submit a claim through the portal, that person must register for
an account.
Records obtained from DHS show that Debbie Long had an active
administrator account and was, therefore, able to submit claims for reimbursement
through the ForwardHealth Portal. That said, four other people had clerk accounts
and could also submit claims. The other organizer listed in Pinnacle’s articles of
incorporation did not have an account.
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Debbie Long Controlled Pinnacle’s Bank Accounts
As mentioned above, Pinnacle had seven bank accounts spread out across three
banks. Four of the accounts (two checking accounts and two money market accounts)
were at BMO Harris Bank (BMO Harris), two (both checking accounts) were at
Educator’s Credit Union (Educator’s), and one (a checking account) was at US Bank.
According to the signature cards from these banks, Debbie Long was the sole
authorized user for six of the seven accounts.
For the Pinnacle account that had another authorized user, BMO Harris
money market acct. no. XXXXXX0290, Long appears to be the sole user. The account
was largely funded by a transfer from BMO Harris money market acct. no.
XXXXXX2919 (which Long controlled) and a check from DHS to Pinnacle (which Long
ran). Long also transferred money out of the account because her signature appears
on cashier’s checks and cash withdrawal slips for the account.
In addition, the records from the banks show that Long, on numerous
occasions, traveled to bank branches to make cash withdrawals, deposits, or to take
out cashier’s checks.
Debbie Long Benefitted from Large Purchases That Were Made Using Fraudulently
Obtained Funds
As will be explained in more detail below, Debbie Long purchased Kitt’s
Custard and helped launder the money that was used to purchase a luxury car and a
car wash. Even if her husband was the purchaser of the car and car wash, Long
acquired a one-half interest in both because Wisconsin is a marital property state.
Wis. Stat. § 766.31(3).
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Paycheck Protection Program
In addition to using Pinnacle to defraud the federal and state government
through the Medicaid program, during the same timeframe Long used Pinnacle to
defraud the federal government through the Paycheck Protection Program (PPP).
PPP was created by Congress to curb the economic disruption from the
coronavirus pandemic by providing low-interest loans to businesses to pay for
operating expenses and employee compensation. See 15 U.S.C. § 636(a)(36)(F)(i). PPP
was administered by the Small Business Administration, which relied on private
lenders to process loan applications.
In the application, applicants had to assert, in part, that “the uncertainty of
current economic conditions makes necessary the loan request to support the ongoing
operations of the eligible recipient,” and that “funds will be used to retain workers
and maintain payroll or make mortgage payments, lease payments, and utility
payments.” 15 U.S.C. § 636(a)(36)(G)(i). The maximum loan amount was based on a
2.5 multiplier of the business’s monthly payroll costs. 15 U.S.C. § 636(a)(36)(E).
Debbie Long Submitted a Fraudulent PPP Loan Application
In May 2020, Debbie Long applied for a PPP loan for Pinnacle. In the
application, Long claimed that Pinnacle had 120 employees and had an average
monthly payroll of $87,629. Long also provided the private lender, BMO Harris, with
a purported payroll summary for 2019 to support her claims regarding Pinnacle’s
monthly payroll costs.
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Application records show that Long applied for the loan through an online
platform, uploaded the 2019 payroll summary to the platform, and e-signed the
application using DocuSign on May 5, 2020.
Long listed Pinnacle’s address and her home address on the application. Both
are in the city of Milwaukee, Milwaukee County, Wisconsin.
As part of the application, Long certified that Pinnacle “was in operation on
February 15, 2020 and had employees for whom it paid salaries and payroll taxes or
paid independent contractors, as reported on Form(s) 1099-MISC,” that she
understood “that if the funds are knowingly used for unauthorized purposes, the
federal government may hold me legally liable, such as for charges of fraud,” and that
“the information provided in this application and the information provided in all
supporting documents and forms is true and accurate in all material respects.”
Based on Long’s representations, BMO Harris approved a $219,072 PPP loan
for Pinnacle at an interest rate of 1 percent. The proceeds of the loan were deposited
into a BMO Harris checking account for Pinnacle, acct. no. XXXXXX7723, on May 8,
2020. Long was the sole authorized user of the account.
Long’s claims about Pinnacle’s workforce and payroll expenses, however, are
directly contradicted by the information Pinnacle provided to the Wisconsin
Department of Workforce Development (DWD) for the same timeframe. Like all
employers in Wisconsin, Pinnacle had to submit quarterly wage reports to DWD. Wis.
Stat. § 108.205; Wis. Admin. Code DWD § 111.02. The wage reports included the
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names, social security numbers, and wages paid to each employee during the quarter.
Id.
According to Pinnacle’s wage reports, during the second quarter of 2020—when
Long applied for the PPP loan—Pinnacle had 46 employees (not 120) and paid
$108,350.37 in wages, which means the average monthly payroll was $36,116.79 (not
$87,629).
Pinnacle’s wage reports also undercut the 2019 payroll summary provided by
Long to BMO Harris. During the first quarter of 2019, Pinnacle reported to DWD that
it had 100 employees and a payroll of $247,741.18 (i.e., an average monthly payroll
of $82,580.39). During the second quarter, Pinnacle reported having 88 employees
and a reported payroll of $224,778.57 (i.e., an average monthly payroll of $74,926.19).
For the third quarter, Pinnacle claimed it had 87 employees and a payroll of
$244,707.40 (i.e., an average monthly payroll of $81,569.13). For the fourth quarter
of 2019, Pinnacle reported having 77 employees and a payroll of $199,577.27 (i.e., an
average monthly payroll of $66,525.76).
Furthermore, BMO Harris records for acct. no. XXXXXX7723 do not show any
banking activity consistent with paying $87,629 for payroll or business expenses on
a monthly basis. In fact, between May 2020 and September 2020, the largest
withdrawal, by far, was $176,000 on June 26, 2020. On that date, Long withdrew
$1,000 in cash and took out a cashier’s check for $175,000 to 7 Elite Medical Supply,
LLC.
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7 Elite Medical Supply, LLC (later renamed 7 Elite Construction Management,
LLC) was a company that was run, in part, by Long’s husband. Because Pinnacle was
a personal care agency, and would have little need for medical supplies, it does not
appear that this payment was for a legitimate business expense. 6
Moreover, after reviewing Pinnacle’s bank records from all seven accounts
from May 2020 through August 2020, and totaling all checks that appeared to be for
payroll expenses (i.e., something about payroll was written in the memo line or it was
a check to an employee) and cash withdrawals (which might have been for payroll),
I identified $54,495.16 in possible payroll expenses. Calculated in this fashion, the
average monthly payroll was $13,623.79 from May 2020 to August 2020.
In summary, Debbie Long inflated Pinnacle’s workforce and payroll expenses
to receive a larger PPP loan. Even more, as will be explained below, Long did not use
the money exclusively for payroll or business expenses as required.
Debbie Long Purchased Kitt’s Frozen Custard Using the Fraudulent PPP
Loan and Fraudulent Reimbursements from Wisconsin Medicaid
Debbie Long used money from the PPP loan and reimbursements from
Wisconsin Medicaid to purchase Kitt’s Frozen Custard (Kitt’s).
Kitt’s is located at 7000 West Capitol Drive in Milwaukee.
Debbie Long purchased Kitt’s on August 28, 2020, through two transactions.
In one transaction, Long used a cashier’s check for $18,747.79 to pay to the owner.
The cashier’s check was drawn on BMO Harris acct. no. XXXXXX2900, which is a
6 As will be explained in further detail below, 7 Elite Medical Supply/7 Elite Construction Management
was a shell company used to launder money.
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Case 2026CF002103 Document 4 Filed 05-05-2026 Page 26 of 35
checking account for Pinnacle. In the other transaction, Long initiated a wire transfer
of $691,033.73 to the owner. The funds for the wire transfer were drawn from acct.
no. XXXXXX7723, which is the same checking account that received the funds from
the PPP loan.
An analysis of acct. no. XXXXXX7723 by Analyst Dieter shows that Long used
the PPP loan to pay for Kitt’s because she would not have been able to fully fund the
wire transfer on August 28, 2020, without it. On May 7, 2020 (the day before the PPP
loan money was deposited in the account), the account’s balance was $533,590.93.
From May 7th until the purchase of Kitt’s on August 28th, the account received
$167,940.79 from Wisconsin Medicaid, and Long deposited $131,136.72, for a total
cash inflow of $299,077.51. During the same period, Long withdrew $239,341.61,
transferred $115,055.12, and paid $5,343.71 for various fees and payments, for a total
cash outflow of $359,740.44. Thus, there was a negative net cash flow of $60,662.93
from the day before the PPP loan money entered the account until Long purchased
Kitt’s. Therefore, without the $219,072 PPP loan, the account would have had a
balance of $472,928, and Long would have been unable to fund the $691,033.73 wire
transfer on August 28, 2020.
In addition, Long would not have been able to fund the wire transfer without
the reimbursements from Wisconsin Medicaid. When the PPP loan ($219,072) is
added to the balance from May 7, 2020 ($533,590.93), the balance on May 8, 2020
becomes $752,662.93. Without the reimbursements from Wisconsin Medicaid
($167,940.79), the total cash inflow was just $131,136.72 from May 7, 2020, to August
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Case 2026CF002103 Document 4 Filed 05-05-2026 Page 27 of 35
28, 2020, and the total cash outflow remains the same ($359,740.44). So, the account
would have had a negative net cash flow of $228,603.72. Therefore, without the
Medicaid reimbursements, the account balance would have been $524,059.21 on
August 28, 2020, and Long would have been unable to fund the $691,033.73 wire
transfer.
Thus, both the fraudulent PPP loan and the fraudulent reimbursements from
Wisconsin Medicaid were essential to Long’s purchase of Kitt’s.
Long Helped Funnel Fraud Proceeds Through Three Shell Companies to
Purchase a Mercedes Benz and an Octopus Car Wash
The acquisition of Kitt’s was not the only purchase that Long participated in
that involved money derived from fraud. Long also helped direct money, obtained
from her scheme to defraud Wisconsin Medicaid, from Pinnacle through three shell
companies and her own bank accounts to fund the purchase of a Mercedes Benz AMG
S63 and an Octopus Car Wash. Long, along with her husband, moved the money
around through numerous transactions designed to conceal the origin, ownership,
and control of the proceeds.
The Shell Companies
The three shell companies used by Long and her husband were 7 Elite
Construction Management, LLC (7 Elite Construction), 7 7 Global Properties, LLC
7 According to DFI records, on June 22, 2020, 7 Elite Medical Supply, LLC, changed its name to 7 Elite
Construction Management, LLC. The name change, which suggests an inexplicable shift in business
practices, also supports that it was a shell company.
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Case 2026CF002103 Document 4 Filed 05-05-2026 Page 28 of 35
(7 Global), and the Levi Day Memorial Trust. All three appear to be shell companies
for several reasons.
First, from looking at the bank records for the entities, none of them carried on
any significant business activities. There are no clear payroll or business expenses.
The withdrawals from these accounts are primarily either large cash withdrawals or
are point of sale purchases for personal expenses.
Second, none of these companies ever paid state or federal income taxes. In
fact, none of these companies even had a Federal Employer Identification Number or
a Federal Tax Identification Number, which is assigned by the Internal Revenue
Service for tax reporting.
Lastly, none of these companies ever filed a wage report with DWD, which
would indicate that none of these companies ever had any employees despite each
having millions of dollars in cash flow. See Wis. Stat. § 108.205; Wis. Admin. Code
DWD § 111.02.
Bank Accounts
In addition to the bank accounts for Pinnacle, Debbie Long controlled the bank
account for the Levi Day Memorial Trust and her own accounts.
Her husband was an authorized user for the bank accounts for 7 Elite
Construction and 7 Global Properties. The BMO Harris records indicate that he was
the primary user of those accounts.
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Proceeds Derived from Unlawful Activity
The money used to purchase the Mercedes Benz AMG S63 and the Octopus
Car Wash both came from three bank accounts for Pinnacle at BMO Harris: acct. no.
XXXXXX2919, acct. no. XXXXXX0290, and acct. no. XXXXXX2900.
On October 25, 2018, Debbie Long deposited the proceeds from twenty-five
checks, $318,310.41 in total, into XXXXXX2900 ($100,310.41) and XXXXXX2919
($218,000.00). Six of the checks came from DHS in connection with Pinnacle’s claims
for reimbursement for personal care services.
Analyst Dieter’s analysis of those six checks reveals that Pinnacle was paid, in
part, in connection with all the fraudulent schemes mentioned above: billing for
impossible or improbable hours, billing for services when no services were rendered,
billing for services in excess of those that were rendered, billing while the member
was in the hospital or incarcerated, and billing for misrepresentation of need.
The Flow of the Money Used to Purchase the Car and the Car Wash
After the money was paid to Pinnacle, Long and her husband moved it around
in sixteen different financial transactions over the course of nine to eleven months
before the car and car wash were purchased through a shell company.
January 23, 2020
To start, in three different transactions, Pinnacle transferred $906,038.71
(from BMO Harris acct. no. XXXXXX2919), $945,289.26 (from BMO Harris acct. no.
XXXXXX0290), and $150,000 (from BMO Harris acct. no. XXXXXX2900) to 7 Global
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Case 2026CF002103 Document 4 Filed 05-05-2026 Page 30 of 35
Properties (BMO Harris acct. no. XXXXXX9410). In total, Pinnacle transferred
$2,001,327.97 to 7 Global Properties.
February 11, 2020
7 Global Properties transferred $2,000,000 from its checking account (BMO
Harris acct. no. XXXXXX9410) to its savings account (BMO Harris acct. no.
XXXXXX3828).
August 24, 2020
7 Global Properties (from BMO Harris acct. no. XXXXXX3828) transferred
$1,990,547.05 to a personal account for Debbie Long (BMO Harris acct. no.
XXXXXX9688).
August 26, 2020
Long (from BMO Harris acct. no. XXXXXX9688) transferred $1,900,000 to the
Levi Day Memorial Trust (BMO Harris acct. no. XXXXXX9807). The time stamp on
the deposit and withdrawal slips show that the transaction occurred at 16:01.
The full $1,900,000 stayed put for six minutes. Then the Levi Day Memorial
Trust (from BMO Harris acct. no. XXXXXX9807) transferred $1,000,000 to 7 Global
Properties (BMO Harris acct. no. XXXXXX9882) and $500,000 to 7 Elite Construction
(BMO Harris acct. no. XXXXXX9890). The first transfer was at 16:07 and the second
was at 16:08.
Long (from BMO Harris acct. no. XXXXXX9688) also transferred $24,000 to
7 Elite Construction (BMO Harris acct. no. XXXXXX9890). This took place at 16:09.
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Case 2026CF002103 Document 4 Filed 05-05-2026 Page 31 of 35
August 27, 2020
7 Global Properties transferred $1,000,000 (from BMO Harris acct. no.
XXXXXX9882) to Debbie Long (BMO Harris acct. no. XXXXXX9688) at 9:50.
7 Elite Construction transferred $524,000 (i.e., the sum of the previous day’s
transfers into BMO Harris acct. no. XXXXXX9890) to Debbie Long (BMO Harris acct.
no. XXXXXX9688) at 9:52.
The Levi Day Memorial Trust (from BMO Harris acct. no. XXXXXX9807)
transferred $400,000 (i.e., the remaining amount from the previous day’s $1,900,000
transfer from Debbie Long’s account) back to Debbie Long (BMO Harris acct. no.
XXXXXX9688). This happened at 9:53.
In other words, Debbie Long transferred a total of $1,924,000 from her
personal checking account (BMO Harris acct. no. XXXXXX9688) on August 26, 2020,
to three separate shell companies, and got all the money back into the same personal
checking account less than twenty-four hours later.
Nevertheless, the $1,924,000 only stayed in Long’s personal checking account
for twelve minutes. Then Debbie Long (from BMO Harris acct. no. XXXXXX9688)
transferred the full amount to her money market account (BMO Harris acct. no.
XXXXXX9904) at 10:05.
August 31, 2020
Debbie Long (from BMO Harris acct. no. XXXXXX9904) transferred $1,914,000
to the Levi Day Memorial Trust (BMO Harris acct. no. XXXXXX9807) at 10:21.
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Case 2026CF002103 Document 4 Filed 05-05-2026 Page 32 of 35
Levi Day Memorial Trust then (from BMO Harris acct. no. XXXXXX9807)
transferred $1,000,000 to 7 Global Properties (BMO Harris acct. no. XXXXXX9882)
at 10:27.
October 16, 2020
7 Global Properties (from BMO Harris acct. no. XXXXXX9882) transferred
$100,000 to 7 Elite Construction (BMO Harris acct. no. XXXXXX9890).
So, from the $1,000,000 transfer to 7 Global Properties on August 31, 2020,
$900,000 remained with 7 Global Properties and $100,000 went to 7 Elite
Construction.
October 29, 2020
7 Elite Construction took out a cashier’s check (from BMO Harris acct. no.
XXXXXX9890) for $63,200 to purchase a Mercedes Benz AMG S63.
December 23, 2020
7 Global Properties (from BMO Harris acct. no. XXXXXX9882) initiated a wire
transfer of $900,000 to purchase an Octopus Car Wash in Milwaukee.
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Case 2026CF002103 Document 4 Filed 05-05-2026 Page 33 of 35
Flow Chart of the Money Used to Purchase the Car and Car Wash
Pinnacle transfers Pinnacle transfers Pinnacle transfers
$906,038.71 from $945,289.26 from $150,000 from
BMO 2919 on BMO 0290 on BMO 2900 on
1/23/20 1/23/20 1/23/20
To BMO 9410 for 7 Global. 7 Global deposits the $2,001,327.97 cashier’s check
on 1/29/20 and then transfers $2,000,000 on 2/11/20
To BMO 3828 for 7 Global. 7 Global then transfers $1,990,547.05 on 8/24/20
To BMO 9688 for Debbie Long. Long then transfers $1,900,000 on 8/26/20 @ 16:01
To BMO 9807 for Levi Day Memorial Trust. Transfer of $24,000 from
Levi Day Memorial Trust then transfers all BMO 9688 for Debbie
$1,900,000 to three accounts on 8/26-27/20 Long to BMO 9890 for 7
Elite Construction on
8/26/20 @ 16:09
$1,000,000 to BMO 9882 for 7 $400,000 to BMO 9688
Global on 8/26/20 @ 16:07. 7 for Debbie Long on $500,000 to BMO 9890 for 7 Elite
Global then transfers 8/27/20 @ 9:53 Construction on 8/26/20 @
$1,000,000 on 8/27/20 @ 9:50 16:08. 7 Elite Construction (along
with the $24,000 it received from
Debbie Long) then transfers
$524,000 on 8/27/20 at 9:52
To BMO 9688 for Debbie Long. Long then
transfers $1,924,00 on 8/27/20 @ 10:05
To BMO 9904 for Debbie Long. Long then
transfers $1,914,000 on 8/31/20 @ 10:21
To BMO 9807 for Levi Day Memorial Trust. Levi Day
Memorial Trust then transfers $1,000,000 on 8/31/20 @ 10:27
To BMO 9882 for 7 Global Transfer of $100,000 to BMO 9890 for
7 Elite Construction on 10/16/20
Octopus Car Wash purchased via a Mercedes Benz AMG S63 purchased
$900,000 wire transfer on 12/23/20 with a $63,200 cashier’s check on 10/29/20
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Case 2026CF002103 Document 4 Filed 05-05-2026 Page 34 of 35
As to Count 1
Count 1 encompasses Debbie Long’s scheme to defraud Wisconsin Medicaid on
or between March 13, 2017, and August 12, 2022. As stated above, the investigation
revealed that Long, through Pinnacle, was paid at least $2,195,760.87 in fraudulent
reimbursements.
Pursuant to Wis. Stat. § 971.36(3)(a), the State is alleging a continuing course
of conduct.
As to Counts 2 & 3
Counts 2 and 3 concern Debbie Long’s submission of a fraudulent PPP loan
application to BMO Harris, which contained material misrepresentations about
Pinnacle’s workforce, Pinnacle’s payroll expenses, and how the loan proceeds would
be used.
Long used DocuSign to sign the fraudulent PPP loan application on or about
May 5, 2020. The loan proceeds were deposited into a bank account for Pinnacle on
or about May 8, 2020.
As to Count 4
Count 4 is about Debbie Long conducting a transaction to purchase Kitt’s
Custard, on or about August 28, 2020, using money that she knew was obtained by
fraud against both PPP and Wisconsin Medicaid.
As to Count 5
Count 5 encompasses Debbie Long’s participation in a scheme, as a party to a
crime, on or between approximately January 23, 2020, and December 23, 2020, to
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Case 2026CF002103 Document 4 Filed 05-05-2026 Page 35 of 35
conduct a transaction that was designed in whole or in part to conceal or disguise the
nature, location, source, ownership, or control of the proceeds, which were obtained
through her scheme to defraud Wisconsin Medicaid.
Pursuant to Wis. Stat. § 943.895(2)(c), the State is alleging a continuing course
of conduct, and the value of the total laundered proceeds exceeded $100,000.
Based on the foregoing, the complainant believes this complaint to be true and
correct.
Subscribed and sworn to me telephonically on May 5, 2026.
Electronically Signed By:
s/ Benjamin Christianson
Benjamin Christianson
Investigator
Wisconsin Department of Justice
Electronically Signed By:
s/ Timothy J. Filipa
TIMOTHY J. FILIPA
Assistant Attorney General
Medicaid Fraud Control & Elder Abuse Unit
Wisconsin Department of Justice
State Bar No. 1097622
35
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