Indictment — United States v. Plastic Surgery Institute of Utah, Inc., et al., District of Utah (Document 1)
Summary
A sealed grand jury indictment filed January 11, 2023 as Document 1 in United States v. Plastic Surgery Institute of Utah, Inc., Michael Kirk Moore Jr., Kari Dee Burgoyne, Kristin Jackson Andersen and Sandra Flores, Case 2:23-cr-00010-HCN, in the U.S. District Court for the District of Utah. It charges conspiracy to defraud the United States under 18 U.S.C. § 371, conspiracy to convert government property under 18 U.S.C. §§ 371 and 641, and conversion of government property under 18 U.S.C. §§ 641 and 2. It alleges that from on or before May 12, 2021 to at least September 6, 2022 the defendants destroyed hundreds of doses of government-provided COVID-19 vaccines and handed out CDC vaccination record cards without vaccinating recipients, for cash or required $50 donations to a charitable organization. The forfeiture allegation seeks a money judgment of approximately $124,878.50.
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“Indictment — United States v. Plastic Surgery Institute of Utah, Inc., et al., District of Utah (Document 1).”
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Case 2:23-cr-00010-HCN Document 1 Filed 01/11/23 PageID.1 Page 1 of 19
TRINA A. HIGGINS, United States Attorney (#7349)
TODD C. BOUTON, Assistant United States Attorney (#17800)
Attorneys for the United States of America
Office of the United States Attorney
111 South Main Street, Suite 1800
Salt Lake City, Utah 84111-2176
Telephone: (801) 524-5682
Email: todd.bouton@usdoj.gov
SEALED
IN THE UNITED STATES DISTRICT COURT
DISTRICT OF UTAH
UNITED STATES OF AMERICA, INDICTMENT
Plaintiff, VIOLATIONS:
vs. Count 1: 18 U.S.C. § 371,
Conspiracy to Defraud the United States
PLASTIC SURGERY INSTITUTE OF ·
UTAH, INC.; MICHAEL KIRK MOORE Count 2: 18 U.S.C. §§ 371 and 641,
JR.; KARI DEE BURGOYNE; KRISTIN Conspiracy to Convert, Sell, Convey, and
JACKSON ANDERSEN; AND SANDRA Dispose of Government Property
FLORES,
Count 3: 18 U.S.C. §§ 641 and 2,
Defendants. Conversion, Sale, Conveyance, and
Disposal of Government Property and
Aiding and Abetting
Case: 2:23-cr-00010
Assigned To : Nielson, Howard c., Jr
Assign. Date: 1/10/2023
The Grand Jury Charges:
Introductory Allegations
At all times relevant to this Indictment:
1. Defendants herein and others !mown and unknown to the Grand Jmy ran a scheme
out of the Plastic Surgery Institute of Utah, Inc. to defraud the United States and the Centers for
Case 2:23-cr-00010-HCN Document 1 Filed 01/11/23 PageID.2 Page 2 of 19
Disease Control and Prevention ("CDC"), whereby they destroyed hundreds of doses of
government-provided COVID-19 vaccines, and in exchange for either direct cash payments or
required "donations" to a specified charitable organization, defendants distributed COVID-19
vaccination record cards to persons without administering a COVID-19 vaccine to them and
administered saline shots to minor children to trick them into thinking they had received a vaccine.
Defendants
2. Defendant PLASTIC SURGERY INSTITUTE OF UTAH, INC. ("PLASTIC
SURGERY INSTITUTE") is a corporation organized under the laws of the state of Utah with its
principal place of business in the state of Utah. PLASTIC SURGERY INSTITUTE operates out
of Midvale, Utah and provides cosmetic surge1y services to patients.
3. Defendant MICHAEL KIRK MOORE JR. ("DR. MOORE") was a resident of Salt
Lake County, Utah. DR. MOORE was a board-certified plastic surgeon who owned and operated
the PLASTIC SURGERY INSTITUTE. DR. MOORE was a member of Organization 1, a private
organization seeking to "liberate" the medical profession from government and industty conflicts
of interest.
4. Defendant KARI DEE BURGOYNE ("BURGOYNE") was a resident of Salt Lake
County, Utah. BURGOYNE was the Office Manager for the PLASTIC SURGERY INSTITUTE.
5. Defendant KRISTIN JACKSON ANDERSEN ("ANDERSEN") was a resident of
Salt Lake County, Utah. ANDERSEN lived in DR. MOORE's neighborhood and knew DR.
MOORE from her own membership in Organization 1.
6. Defendant SANDRA FLORES ("FLORES") was a resident of Utah County.
FLORES worked as a receptionist at the PLASTIC SURGERY INSTITUTE.
U.S. v. Michael Kirk Moore Jr. et al. 2
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The Federal COVID-19 Vaccination Program
7. On or about January 31, 2020, the Secretary of the United States Department of
Health and Hnman Services ("HHS") declared a national public health emergency under 42 U.S.C.
§ 247d as a result of the spread of a novel coronavims to and within the United States. This
coronavims was called SARS-CoV-2, and was also known as "COVID-19." On or about March
13, 2020, as a result of the rapid spread ofCOVID-19 within the United States, the President of
the United States issued Proclamation 9994, declaring a national emergency beginning on March
7, 2020. As part of the response to the pandemic, the federal government provided funding to
pharmaceutical and biotechnology companies capable of developing a vaccine for COVID-19.
8. On or about December 11, 2020, the United States Food and Dmg Administration
(the "FDA") approved the Pfizer COVID-19 vaccine for emergency use. On or about December
18, 2020, the FDA also approved the Moderna COVID-19 vaccine for emergency use. Each
vaccine was approved as a two-dose regimen.
9. Then, on or about Febmary 27, 2021, the FDA issued another emergency use
authorization (EUA) for the Janssen COVID-19 Vaccine. The Janssen COVID-19 Vaccine was
manufactured by Janssen Biotech Inc., a Janssen Phaimaceutical Company of Johnson & Johnson.
The Janssen COVID-19 Vaccine was approved as a single-dose regimen.
10. Consistent with these emergency authorizations, the Centers for Disease Control
and Prevention ("CDC") prepared for widespread administration of the COVID-19 vaccines, at a
variety oflocations. The intent was to make a COVID-19 vaccine available to all authorized adults
in the United States who wanted to receive a vaccine.
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11. The vaccines were made available exclusively through the United States Federal
Government. There are no third-party resellers of COVID-19 vaccines and no company or
organization is allowed to import COVID-19 vaccines from another country.
12. To make the COVID-19 vaccines available to authorized persons in the United
States, the government purchased millions of COVID-19 vaccine doses from Pfizer, Moderna, and
Johnson & Jolmson. The federal government determined that these COVID-19 vaccine doses were
to be distributed at no cost to vaccine recipients through the providers approved by the CDC to
receive and distribute the vaccine.
13. From approximately March 2021, the CDC paid at least:
a. $20.00 for each adult dose of the Pfizer COVID-19 vaccine with an
accompanying diluent;
b. $24.50 for each pediatric dose of the Pfizer COVID-19 vaccine;
c. $12.25 for each dose of the Modema COVID-19 vaccine; and
d. $7.50 for each dose of the Janssen COVID-19 vaccine.
14. To further provide for the administration of COVID-19 vaccines, the United States
also contracted with companies to print COVID-19 vaccination record cards according to certain
CDC specifications ("COVID-19 Vaccination Record Cards"). The United States required that the
COVID-19 Vaccination Record Cards include a space to record the dates of the first and (where
needed) second vaccine doses, and that the COVID-19 Vaccination Record Cards be distributed
as part of the vaccine ancillary kits sent to each vaccine distribution location.
15. To facilitate the proper administration of the COVID-19 vaccines, the CDC and
HHS also developed rules and protocols for the entities that would administer the vaccines at
locations around the United States ("vaccine distributing entities").
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16. These protocols required all vaccine distributing entities that administered the
COVID-19 vaccines at physical locations to provide a COVID-19 Vaccination Record Card to
each vaccine recipient after they had received their COVID-19 vaccine.
17. To ensure that vaccine distributing entities appropriately administered the COVID-
19 vaccines and appropriately distributed COVID Vaccination Record Cards, the CDC required
such entities to sign a CDC COVID-19 Vaccination Program Provider Agreement before they
could receive COVID-19 vaccines for distribution to the public. Among other things, these CDC
Provider Agreements required vaccine distributing entities to:
a. Administer COVID-19 vaccines in accordance with all requirements and
recommendations of the CDC and the CDC's Advisory Connnittee on
Immunization Practices;
b. Within 24 hours of administering a dose of COVID-19 vaccine, to record the
vaccine recipient's record and to report required information to the relevant
state, local, or territorial public health authority;
c. Not sell or seek reimbursement for any COVID-19 vaccine that the federal
government provided to the organization without cost;
d. Administer the vaccine regardless of the vaccine recipient's ability to pay for
the administration of the vaccine;
e. Conduct its COVID-19 vaccination services in compliance with the CDC's
Guidance for Immunization Services During the COVID-19 Pandemic for safe
delivery of vaccines;
f. Repo1t the number of doses of COVID-19 vaccines that were unused, spoiled,
expired, or wasted as required by the relevant jurisdiction;
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g. Provide a completed COVID-19 vaccination record card to every COVID-19
vaccine recipient; and
h. Administer the COVID-19 vaccines in compliance with all applicable state and
territorial vaccination laws.
18. The CDC included COVID-19 Vaccination Record Cards in each COVID-19
vaccine shipment to a vaccine distributing entity.
COUNTl
18 U.S.C. § 371
(Conspiracy to Defraud the United States)
19. The allegations in paragraphs 1-18 are incorporated by reference and re-alleged as
though fully set forth herein.
20. On or before May 12, 2021, and continuing to at least September 6, 2022, in the
District of Utah and elsewhere,
PLASTIC SURGERY INSTITUTE OF UTAH, INC.,
MICHAEL KIRK MOORE JR.,
KARI DEE BURGOYNE,
KRISTIN JACKSON ANDERSEN, and
SANDRA FLORES,
defendants herein, did unlawfully, voluntarily, intentionally, and knowingly conspire, combine,
confederate, and agree together and with each other and with other individuals both known and
unknown to the Grand Jury, with interdependence among the members of the conspiracy, to
defraud the United States by deceit, craft, trickery, and dishonest means for the purpose of
impeding, impairing, obstructing, and defeating the lawful governmental functions of the CDC in
distributing and administering authorized COVID-19 vaccines and COVID-19 Vaccination
Record Cards through approved vaccine distributing entities.
US. v. Michael Kirk Moore Jr. et al. 6
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Object of the Conspiracy
21. It was the object of the conspiracy for the defendants PLASTIC SURGERY
INSTITUTE, DR. MOORE, BURGOYNE, ANDERSEN, and FLORES, and other individuals to
unlawfully, voluntarily, intentionally, and knowingly defraud the United States of America and an
agency thereof, that is, the Centers for Disease Control and Prevention, by impeding, impairing,
obstructing, and defeating the lawful governmental functions of the CDC in distributing and
administering authorized COVID-19 vaccines and COVID-19 Vaccination Record Cards through
approved vaccine distributing entities.
Manner and Means of the Conspiracy
22. Among the manner and means by which defendants PLASTIC SURGERY
INSTITUTE, DR. MOORE, BURGOYNE, ANDERSEN, and FLORES, and others (the "Co-
Conspirators") sought to accomplish the object and purpose of the conspiracy were the following:
a. In furtherance of the conspiracy and with the intent to benefit PLASTIC
SURGERY INSTITUTE, on or about May 12, 2021, DR. MOORE signed a CDC COVID-19
Vaccination Program Provider Agreement so that he could receive COVID-19 vaccines and
COVID-19 Vaccination Record Cards from the CDC at the Plastic Surgery Institute.
b. In furtherance of the conspiracy, and with the intent to benefit PLASTIC
SURGERY INSTITUTE, on or about May 24, 2021, DR. MOORE and BURGOYNE caused
Surgeon !-another plastic surgeon who worked with DR. MOORE at the time-to also sign the
CDC COVID-19 Vaccination Program Provider Agreement. When Surgeon 1 signed the Provider
Agreement, he believed that the Plastic Surgery Institute intended to administer the vaccine as per
the Provider Agreement.
U.S. v. Michael Kirk Moore Jr. et al. 7
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c. In furtherance of the conspiracy and with the intent to benefit PLASTIC
SURGERY INSTITUTE, between on or about May 24, 2021 and September 23, 2022, DR.
MOORE and BURGOYNE ordered hundreds of doses of COVID-19 vaccines from the CDC,
ostensibly for administration to others at the Plastic Surge1y Institute.
d. In furtherance of the conspiracy, and with the intent to benefit PLASTIC
SURGERY INSTITUTE, on October 15, 2021, DR. MOORE and BURGOYNE and others began
receiving doses of COVID-19 vaccines from the CDC at the Plastic Surgery Institute.
e. In furtherance of the conspiracy, and with the intent to benefit PLASTIC
SURGERY INSTITUTE, on or before October 15, 2021, DR. MOORE, BURGOYNE, and others
began to notify persons seeking to receive a COVID- I 9 Vaccination Record Card without
receiving a vaccine ("Fraudulent Vax Card Seekers") that they could receive fraudulently
completed COVID-19 Vaccination Record Cards from the Plastic Surgery Institute without having
to receive a COVID-19 vaccine.
f. In furtherance of the conspiracy, and with the intent to benefit PLASTIC
SURGERY INSTITUTE, starting on or before November 9, 2021, in exchange for direct cash
payments or directed donations of$50 per person per occurrence, DR. MOORE and BURGOYNE
began to distribute and caused to be distributed COVID-19 Vaccination Record Cards to
Fraudulent Vax Card Seekers who came into the Plastic Surge1y Institute to receive the cards,
without administering a COVID-19 vaccine to them.
g. In furtherance of the conspiracy, and with the intent to benefit PLASTIC
SURGERY INSTITUTE, DR. MOORE an-anged to have BURGOYNE manage the day-to-day
logistics of the scheme. DR. MOORE and BURGOYNE set up a screening mechanism for
Fraudulent Vax Card Seekers. When Fraudulent Vax Card Seekers contacted the Plastic Surgery
U.S. v. Michael Kirk Moore Jr. et al. 8
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Institute, BURGOYNE would refer them to ANDERSEN and tell them they had to go through
her.
h. In furtherance of the conspiracy, ANDERSEN would then screen the
purported Fraudulent Vax Card Seekers by requiring them to provide her with the name of another
Fraudulent Vax Card Seeker who had already received a COVID-19 Vaccination Record Card
from the Plastic Surge1y Institute without actually receiving a COVID-19 vaccine.
1. In furtherance of the conspiracy, once ANDERSEN had successfully
screened the Fraudulent Vax Card Seekers by verifying the name of their refetrnl, she would
provide them a link to Organization l's website. She would require them to make a $50 "donation"
for each person and each appointment to receive a fraudulent entty on a COVID-19 Vaccination
Record Card suggesting that the person had actually been vaccinated. The $50 "donations" were
made to a "charitable organization" linked to Organization 1.
J. In furtherance of the conspiracy, after the Fraudulent Vax Card Seekers
verified they had made their required $50 "donations," ANDERSEN sent them fonns to complete.
k. In furtherance of the conspiracy, after the required forms were completed
and submitted, ANDERSEN directed Fraudulent Vax Card Seekers to schedule an appointtnent to
pick up a COVID-19 Vaccination Record Card from the Plastic Surgery Institute.
I. In furtherance of the conspiracy, and with the intent to benefit PLASTIC
SURGERY INSTITUTE, pursuant to Dr. MOORE's and BURGOYNE's instructions, when the
Fraudulent Vax Card Seekers came to pick up their fraudulent COVID-19 Vaccination Record
Cards, FLORES and other employees at the Plastic Surgery Institute would then fill in and stamp
COVID-19 Vaccination Record Cards to falsely indicate that the Fraudulent Vax Card Seekers
had actually received a dose of a COVID-19 vaccine. Further pursuant to DR. MOORE's and
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BURGOYNE's instructions, FLORES and other employees would then provide the Fraudulent
Vax Card Seekers with the completed COVID-19 Vaccination Record Cards without
administering any COVID-19 vaccine to them.
m. Between on or about October 15, 2021 and at least September 6, 2022, with
the intent to benefit PLASTIC SURGERY INSTITUTE, DR. MOORE, BURGOYNE,
ANDERSEN, FLORES, and others conveyed and sold without authority COVID-19 Vaccination
Record Cards to Fraudulent Vax Card Seekers that were fraudulently completed to falsely reflect
that the Fraudulent Vax Card Seekers had received at least 1937 doses of bona fide COVID-19
vaccines, when, in fact, they had received none.
n. In fi.uiherance of the conspiracy, and with the intent to benefit PLASTIC
SURGERY INSTITUTE, DR. MOORE, BURGOYNE, and FLORES also atTanged, at times, to
administer or have others administer saline shots to minor children at the request of their parents
so that the minor children would think they were actually receiving a COVID-19 vaccine.
o. Between on or about October 15, 2021 and at least September 6, 2022, with
the intent to benefit PLASTIC SURGERY INSTITUTE, defendants DR. MOORE, BURGOYNE,
FLORES, and others uploaded or caused to be uploaded the names of all Fraudulent Vax Card
Seekers who requested it to the Utah Statewide Immunization Information System.
p. In furtherance of the conspiracy, and with the intent to benefit PLASTIC
SURGERY INSTITUTE, DR. MOORE and BURGOYNE continued to atTange to have a total of
approximately 2,200 doses of COVID-19 vaccines delivered to the Plastic Surge1y Institute
without intending to adlninister any of them to the public.
q. In fu1iherance of the conspiracy, and with the intent to benefit PLASTIC
SURGERY INSTITUTE, the Defendants destroyed or caused to be destroyed viable doses of
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COVID-19 vaccines, usually by drawing them from the bottle and then squirting them down the
drain from a syringe.
r. In furtherance of the conspiracy, and with the intent to benefit PLASTIC
SURGERY INSTITUTE, DR. MOORE and BURGOYNE also arranged for BURGOYNE to
upload or cause to be uploaded the names of all purported COVID-19 vaccine recipients who
requested it to the Utah Statewide Immunization Information System. All told, they caused to be
uploaded to this system records purporting to show that the Plastic Surgery Institute had properly
administered at least 193 7 doses of COVID-19 vaccines.
s. Between on or before October 15, 2021 and at least September 6, 2022, with
the intent to benefit PLASTIC SURGERY INSTITUTE, DR. MOORE, BURGOYNE,
ANDERSEN, FLORES, and others improperly converted and disposed of or caused to be disposed
of at least $28,028.50 worth of COVID-19 vaccines, without administering any of those vaccines
to anyone, as follows:
Type ofCOVID-19 Vaccine Number of Doses Cost Per Dose Value of Doses
Janssen 958 $7.50 $7,185
Modema 64 $12.25 $784
Pfizer 524 $20.00($19.50 $10,480
per dose
+ 50-cent diluent
ner dose)
Pfizer Pediatric 391 $24.50 $9,579.50
Total: $28,028.50
Overt Acts to Effect the Object of the Conspiracy
23. In furtherance of the conspiracy and in order to achieve the unlawful objectives and
purposes of their conspiracy, PLASTIC SURGERY INSTITUTE, DR. MOORE, BURGOYNE,
US. v. Michael Kirk Moore Jr. et al. 11
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ANDERSEN, FLORES, and others, aiding and abetting each other, committed or caused to be
committed the following ove1i acts, among others, in the District of Utah and elsewhere:
a. On around May 12 and 24, 2021, defendants DR. MOORE and
BURGOYNE signed or caused to be signed a CDC COVID-19 Vaccination Program Provider
Agreement so that DR. MOORE could receive COVID-19 vaccines and CDC COVID-19
Vaccination Record Cards at the Plastic Surgery Institute.
b. On March 3, 2022, when Undercover Agent 1 called the Plastic Surge1y
Institute to inquire about scheduling a "vaccine appointment," BURGOYNE told Undercover
Agent 1 that "eve1ybody needs to go through Kris [ANDERSEN]" and gave Undercover Agent 1
ANDERSEN's phone number.
c. On March 3, 2022, when Undercover Agent 1 called back a few minutes
later and asked BURGOYNE, "Do I still need to contact Kris [ANDERSEN] for the paperwork if
I just want the card and not the vaccine?" BURGOYNE replied, "Yes."
d. On March 10, 2022, when ANDERSEN was sent a text from Undercover
Agent 1's phone inquiring about getting a vaccine card for a cruise, ANDERSEN asked, "Who
refe1Ted you to the clinic?" and declared that, "We go by refenal basis."
e. On March 14, 2022, ANDERSEN received a text from Undercover Agent
1's phone which provided the name of a refen-al. ANDERSEN verified the referral person had in
fact been in to receive a COVID-19 Vaccination Record Card. ANDERSEN then sent Undercover
Agent 1 a text message instructing Undercover Agent 1 to use Venmo or PayPal to make a $50
donation per appointment per person. ANDERSEN instructed Undercover Agent 1 to put an
"orange" in the memo and send ANDERSEN a screenshot of the receipt with Undercover Agent
U.S. v. Michael Kirk Moore Jr. et al. 12
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1 's "name or pie" on it, and then ANDERSEN would send Undercover Agent 1 the instructions
for the next steps to receive a COVID-19 Vaccination Record Card.
f. On March 16, 2022, ANDERSEN received a text from Undercover Agent
1 's phone indicating that Undercover Agent 1 had paid the $50 donation and included an "orange"
in the memo line according to ANDERSEN's instructions. ANDERSEN then promptly texted
Undercover Agent 1 a link to office forms Undercover Agent 1 needed to complete in order to
schedule an appointment at the Plastic Surgery Institute to obtain a COVID-19 Vaccination Record
Card without receiving a COVID-19 vaccine.
g. On May 20, 2022, ANDERSEN received a text from Undercover Agent 2's
phone, indicating that Undercover Agent 2' s girlfriend had received a vaccine card and that he was
hoping to get one too, and asking if it "still cost $50?"
ANDERSEN replied with a text instructing Undercover Agent 2 to use "signal app"-an enc1ypted
instant messaging system-to communicate with her.
h. On May 31, 2022, when Undercover Agent 2 used Signal App to
communicate with ANDERSEN and identified himself, ANDERSEN asked Undercover Agent 2,
"Who referred you?" ANDERSEN then required Undercover Agent 2 to provide the "full name
for referral of someone[]" who had already "been in" before she provided Undercover Agent 2
with instructions to make a $50 donation per appointment per person through Venmo or PayPal.
ANDERSEN also instructed Undercover Agent 2 to send her a screenshot of the receipt with his
"name or pie" on it, and advised him that she would then send the instructions for the next steps.
i. On June 1, 2022, after Undercover Agent 2 sent ANDERSEN a screenshot
showing that he had made the required $50 donation, ANDERSEN texted him instructions, with a
link to fill out office forms, before Undercover Agent 2 was to call and schedule an appointment
US. v. Michael Kirk Moore Jr. et al. 13
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to retrieve his COVID-19 Vaccination Record Card from the Plastic Surge1y Institute.
ANDERSEN also asked Undercover Agent 2 not to call and ask questions on the clinic number.
J. On June 21, 2022, FLORES completed and distributed to Undercover Agent
2 a COVID-19 Vaccination Record Card indicating that he had received a dose of Pfizer COVID-
19 without administering a vaccine to him and knowing that he had not received a vaccine.
k. On June 21, 2022, when Undercover Agent 2 asked FLORES if his children
could also receive similar COVID-19 Vaccination Record Cards, FLORES wrote on a Post-it note
that "with 18 & younger, we do a saline shot," indicating that minors could receive saline shots
and obtain the cards without receiving a vaccine, and then slipped him the note.
I. On September 23, 2022, BURGOYNE signed a Vaccine Transfer Form on
behalf of PLASTIC SURGERY INSTITUTE, acknowledging that 60 doses of COVID-19
vaccines were received by PLASTIC SURGERY INSTITUTE and that she accepted
accountability for the vaccines.
All in violation of Title 18, United States Code, Section 371.
COUNT2
18 U.S.C. §§ 371 and 641
(Conspiracy to Convert, Sell, Convey, and Dispose of Government Property)
24. The allegations in paragraphs 1-23 are incorporated by reference and re-alleged as
though fully set forth herein.
25. On or before May 12, 2021, and continuing to at least September 23, 2022, in the
District of Utah and elsewhere,
PLASTIC SURGERY INSTITUTE OF UTAH, INC.
MICHAEL KIRK MOORE JR.,
KARI DEE BURGOYNE,
KRISTIN JACKSON ANDERSEN, and
SANDRA FLORES,
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defendants herein, and others did nnlawfully, voluntarily, intentionally, and knowingly conspire,
combine, confederate, and agree together and with each other and with other individuals both
known and unknown to the Grand Jury, with interdependence among the members of the
conspiracy, to commit an offense against the United States, to wit: Conversion and Unauthorized
Sale, Conveyance, and Disposal of Government Property in violation of Title 18, United States
Code, Section 641.
Objects of the Conspiracy
26. The objects of the conspiracy were for the defendants PLASTIC SURGERY
INSTITUTE, DR. MOORE, BURGOYNE, ANDERSEN, and FLORES, and other individuals to
nnlawfully, voluntarily, intentionally, and knowingly commit an offense against the United States
of America and an agency thereof, that is, the Centers for Disease Control and Prevention, by (I)
without authority, disposing of the COVID-19 vaccines that were provided to the Plastic Surgery
Institute pursuant to a CDC COVID-19 Vaccination Program Provider Agreement; (2) converting
COVID-19 Vaccination Record Cards to defendants PLASTIC SURGERY INSTITUTE, DR.
MOORE, BURGOYNE, ANDERSEN, and FLORES' own use and the use of others; and (3)
without authority, selling and conveying the COVID-19 Vaccination Record Cards to others-the
COVID-19 Vaccination Record Cards and COVID-19 vaccines being a thing of value of the
United States and a department or agency thereof, and property made or being made under contract
for the United States and a department or agency thereof, that is, the CDC.
Manner and Means of the Conspiracy
27. The manner and means of the conspiracy are detailed above in paragraph 22 and
are incorporated by reference and re-alleged as though fully set forth herein.
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Overt Acts in Furtherance of the Conspiracy
28. The overt acts that PLASTIC SURGERY INSTITUTE, DR. MOORE,
BURGOYNE, ANDERSEN, FLORES, and others connnitted in furtherance of the conspiracy and
to effect its unlawful objectives and purposes, are detailed above in paragraph 23 and are
incorporated by reference and re-alleged as though fully set forth herein.
All in violation of 18 U.S.C. §§ 371 and 641.
COUNT3
18 U.S.C. §§ 641 and2
(Conversion, Sale, Conveyance, and Disposal of Government Property and Aiding and Abetting)
29. The allegations in paragraphs 1-28 are incorporated by reference and re-alleged as
though fully set forth herein.
30. On or about the dates set forth below, in the District of Utah and elsewhere,
, PLASTIC SURGERY INSTITUTE OF UTAH, INC.,
MICHAEL KIRK MOORE JR.,
KARI DEE BURGOYNE,
KRISTIN JACKSON ANDERSEN, and
SANDRA FLORES,
defendants herein, did embezzle, steal, purloin, and knowingly convett to their use or the use of
another, and without authority, sold, conveyed, and disposed of a thing of value of the United
States or of a department or agency thereof and of property made or being made under contract for
the United States and a department or agency thereof, that is, the Centers for Disease Control and
Prevention, namely approximately 1937 doses ofCOVID-19 vaccines and corresponding COVID-
19 Vaccination Record Cards, with an aggregate value exceeding $1,000, as follows:
Dates Approximate Value of Approximate Value of Total Value
(On or About) COVID-19 Vaccines Vaccination Record Cards of Gov't
Improperly Disposed of Improperly Conveyed Property
November 9, 2021 $28,028.50 $96,850 $124,878.50
to (1937 doses' worth x $50 each)
September 6, 2022
U:S. v. Michael Kirk Moore Jr. et al. 16
Indictment
Case 2:23-cr-00010-HCN Document 1 Filed 01/11/23 PageID.17 Page 17 of 19
31. And did aid, abet, counsel, command, induce and procure the commission of the
offense.
All in violation of Title 18, United States Code, Sections 641 and 2.
NOTICE OF INTENT TO SEEK FORFEITURE
Pursuant to 18 U.S.C. § 981(a)(l)(C), and 28 U.S.C. § 2461, upon conviction of any
offense charged herein in violation of 18 U.S.C. § 371, defendants shall forfeit to the
United States of America, any property, real or personal, that constitutes or is derived,
directly or indirectly, from gross proceeds traceable to the commission of the offense.
The property to be forfeited includes, but is not limited to, the following:
• All remaining doses ofCOVID-19 vaccines in defendants' possession, custody,
or control;
• All remaining COVID-19 Vaccination Record Cards in defendants' possession,
custody, or control;
• A money judgment in the amount of approximately $124,878.50; and
• Substitute property as allowed by 28 U.S.C. § 246l(c) and 21 U.S.C. § 853(p).
Pursuant to 18 U.S.C. § 981(a)(l)(C), and 28 U.S.C. § 2461, upon conviction of any
offense charged herein in violation of 18 U.S.C. §§ 371 and 641, defendants shall forfeit
to the United States of America, any property, real or personal, that constitutes or is
derived, directly or indirectly, from gross proceeds traceable to the commission of the
offense.
US. v. Michael Kirk Moore Jr. et al. 17
Indictment
Case 2:23-cr-00010-HCN Document 1 Filed 01/11/23 PageID.18 Page 18 of 19
The property to be forfeited includes, but is not limited to, the following:
• All remaining doses ofCOVID-19 vaccines in defendants' possession,
custody, or control;
• All remaining COVID-19 Vaccination Record Cards in defendants'
possession, custody, or control;
• A money judgment in the amount of approximately $124,878.50; and
• Substitute property as allowed by 28 U.S.C. § 2461(c) and 21 U.S.C. § 853(p).
Pursuant to 18 U.S.C. § 98l(a)(l)(C), and 28 U.S.C. § 2461, upon conviction of any
offense charged herein in violation of 18 U.S.C. § 641, defendants shall forfeit to the
United States of America, any property, real or personal, that constitutes or is derived,
directly or indirectly, from gross proceeds traceable to the commission of the offense.
The property to be forfeited includes, but is not limited to, the following:
• All remaining doses of COVID-19 vaccines in defendants' possession, custody,
or control;
• All remaining COVID-19 Vaccination Record Cards in defendants'
possession, custody, or control;
I II
Ill
II I
US. v. Michael Kirk Moore Jr. et al. 18
Indictment
Case 2:23-cr-00010-HCN Document 1 Filed 01/11/23 PageID.19 Page 19 of 19
• A money judgment in the amount of approximately $124,878.50; and
• Substitute property as allowed by 28 U.S.C. § 2461(c) and 21 U.S.C. § 853(p).
A TRUE BILL:
FOREPERSON O GRAND JURY
TRINA A. HIGGINS
United States Attorney
~
Todd C. ~
~---
Assistant United States Attorney
US. v. Michael Kirk Moore Jr. et al. 19
Indictment
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