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United States v. Kareem Memon — Information (S.D. Fla., Dkt. 1)

Summary

A Rule 20 transfer packet entered on the docket January 11, 2024 as Document 1 in Case 0:24-cr-60004-RS in the Southern District of Florida, transferring United States v. Kareem Memon from the District of New Jersey, Criminal No. 24-17 (MEF). It contains Memon's consent to transfer the case for plea and sentence under Fed. R. Crim. P. 20, the New Jersey docket for Case 2:24-cr-00017-MEF-1, and the clerk's transmittal letter dated January 10, 2024. The enclosed information charges conspiracy to commit health care fraud under 18 U.S.C. § 1349 in Count 1 and conspiracy to violate the Federal Anti-Kickback Statute under 18 U.S.C. § 371 in Count 2, alleging that from in or around 2017 through in or around 2020 Memon's companies were paid kickbacks for completed doctor's orders for durable medical equipment billed to Medicare.

Summary drafted by a model from the text of the original file linked on this page and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“United States v. Kareem Memon — Information (S.D. Fla., Dkt. 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/rule-20-transfer-packet-incl-no-0-24-cr-60004-dkt-1-s-d-fla-f941b9bba6/, SHA-256 bf666ddf5ab4b443d7b3948b572e8275ceb9c687e3493fab75b21389745fe922.

Full text

Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 1 of 21

                                                                      MP

                                                              Jan 11, 2024

                                                                         Miami



                                                   (MEF)


                                                      24-17


                                            SDFL Case # 24-cr-60004 Smith/Augustin-Birch
       Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 2 of 21
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                                         U.S. District Court
                             District of New Jersey [LIVE] (Newark)
                      CRIMINAL DOCKET FOR CASE #: 2:24-cr-00017-MEF-1


Case title: USA v. MEMON                                                Date Filed: 01/10/2024

Assigned to: Judge Michael E. Farbiarz

Defendant (1)
KAREEM MEMON                                              represented by BRIAN SILBER
                                                                         916 SOUTH ANDREWS AVENUE
                                                                         FORT LAUDERDALE,, FL 33316
                                                                         1954-462-3636
                                                                         LEAD ATTORNEY
                                                                         ATTORNEY TO BE NOTICED
                                                                         Designation: CJA Appointment

Pending Counts                                                          Disposition
None

Highest Offense Level (Opening)
None

Terminated Counts                                                       Disposition
18-1349 CONSPIRACY TO COMMIT
HEALTH CARE FRAUD (dof- from 2017-
2020)
(1)
18:371 CONSPIRACY TO VIOLATE THE
FEDERAL ANTI-KICKBACK STATUTE
(dof- from 2017-2020)
(2)

Highest Offense Level (Terminated)
Felony

Complaints                                                              Disposition
None



Plaintiff
USA                                                       represented by MATTHEW SPECHT
                                                                         DOJ-USAO
                                                                         DISTRICT OF NEW JERSEY
     Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 3 of 21
                                                                      970 BROAD STREET
                                                                      ROOM 700
                                                                      NEWARK, NJ 07102
                                                                      973-353-6061
                                                                      Email: matthew.specht@usdoj.gov
                                                                      LEAD ATTORNEY
                                                                      ATTORNEY TO BE NOTICED
                                                                      Designation: Assistant US Attorney

Date Filed   # Docket Text
01/10/2024   1 CONSENT TO TRANSFER JURISDICTION (Rule 20) to SOUTHERN DISTRICT OF
               FLORIDA by KAREEM MEMON. (JB, ) (Main Document 1 replaced on 1/10/2024) (JB, ).
               (Additional attachment(s) added on 1/10/2024: # 1 Information) (JB, ). (Additional attachment(s)
               added on 1/10/2024: # 3 Cover sheet) (JB, ). Modified on 1/10/2024 (mfr). (Entered: 01/10/2024)
01/10/2024      Notice of Allocation and Assignment setting plea agreement hearing as to KAREEM MEMON for
                2/20/2024 at 02:00 PM before Judge Michael E. Farbiarz. (JB, ) Modified on 1/10/2024 (JB, ).
                (Entered: 01/10/2024)
01/10/2024      Notice of Allocation and Assignment setting plea agreement hearing as to KAREEM MEMON for
                2/6/2024 at 02:00 PM before Judge Michael E. Farbiarz. (JB, ) (Entered: 01/10/2024)
01/10/2024      Please disregard the setting of plea hearing as to KAREEM MEMON this case is a Rule 20
                Transfer out to Southern District of Florida: (mfr) (Entered: 01/10/2024)
01/10/2024   2 INFORMATION as to KAREEM MEMON (1) count(s) 1, 2. (JB, ) (Entered: 01/10/2024)
01/10/2024   3 Transmittal Letter re: 1 Rule 20 - Transfer Out to the District of Southern Florida. (JB, ) (Entered:
               01/10/2024)
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 4 of 21


                       UNITED STATES DISTRICT COURT
                                 DISTRICT OF NEW JERSEY
                                  OFFICE OF THE CLERK                              CAMDEN OFFICE
                              M. L. KING JR. FEDERAL BLDG. & U.S. COURTHOUSE       ONE JOHN F. GERRY PLAZA
                                         50 WALNUT STREET, P.O. BOX 419            FOURTH & COOPER STREETS
                                              NEWARK, NJ 07101-0419                CAMDEN, NJ 08101
                                               (973) 645-3730
                                                                                   TRENTON OFFICE
                                                                                   402 EAST STATE STREET
   Melissa E. Rhoads                                                               ROOM 2020
        Clerk                                                                      TRENTON, NJ 08608

                                                                                   REPLY TO:


January 10, 2024




           Re: U.S.A. v- KAREEM MEMONOur
           Docket No. 24-cr17 (MEF)



 Dear Clerk:

         A Consent to Transfer Case pursuant to Rule 20 of the Federal Rules of Criminal
 Procedure has been filed with this District in the above-captioned case. This District considers
 the electronic record to be the original pursuant to Federal Rules of Criminal Procedure 49(d),
 Local Civil Rule 5.2 and paragraph 7 of the Court’s Electronic Case Filing Policies and
 Procedures. The original records of this Court can be obtained by accessing CM/ECF through
 PACER. Certified copies of any document not available through PACER are enclosed. Kindly
 acknowledge receipt on the duplicate of this letter, which is provided for your convenience.

                                        Sincerely,

                                        MELISSA E. RHOADS, Clerk


                                        By: JACKELINE BARCO
                                                   Deputy Clerk




 RECEIPT ACKNOWLEDGED BY:
 DATE:
 YOUR DOCKET NUMBER:                                                           .



                                                                                   DNJ-Crim-001(Rev. 09/06)
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 5 of 21



                       Instructions for Retrieving Electronic Case Files


 1. Access the CM/ECF website for the District of New Jersey at https://ecf.njd.uscourts.gov

 2. Click on:   Link to Electronic Filing System (Live)

 3. At the ECF/PACER Login Screen, enter your Court’s PACER Login and Password

 4. On the CM/ECF toolbar, choose:

        •       Reports
        •       Docket Sheet
        •       Enter Case Number in the following format: [06-1234]
        •       Run Report

                <      To view a document from the docket sheet, click on the blue “underlined”
                       document number;

                <      To download, click on File, Save a Copy and save to your specific
                       directory;

                <      If the document does not have an underlined document number, it is
                       either:

                       •      A text only entry and no document is attached, or
                       •      An entry made prior to electronic case filing and the original is
                              enclosed, or
                       •      The document included an attachment too large for the electronic
                              case filing system and is enclosed.

 If you have any questions, our ECF help-desk telephone numbers are as follows:

        <       Camden - 866-726-0726 or 856-757-5285
        <       Newark - 866-208-1405 or 973-645-5924
        <       Trenton - 866-848-6059 or 609-989-2004
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 6 of 21



 MHS/2023R00813


                           UNITED STATES DISTRICT COURT
                              DISTRICT OF NEW JERSEY

  UNITED STATES OF AMERICA                      :       Hon. (MEF)
                                                :
                   v.                           :       Criminal No. 24-17
                                                :
  KAREEM MEMON                                  :       18 U.S.C. § 1349 18
                                                :       U.S.C. § 371

                                   INFORMATION

        The defendant having waived in open court prosecution by Indictment, the

 Attorney for the United States for the District of New Jersey, acting under

 authority conferred by 28 U.S.C. § 515, charges:

                                        COUNT 1
                        (Conspiracy to Commit Health Care Fraud)

        1.        Unless otherwise indicated, at all times relevant to this Information:

                            Relevant Individuals and Entities

                  a.     The defendant, KAREEM MEMON (“MEMON”), was a resident

 of Florida who owned, operated, and/or had a financial or controlling interest in

 entities (the “MEMON Supply Companies”) through which he and his coconspirators

 generated information and documents amounting to a guarantee that durable

 medical equipment (“DME”) would be reimbursed by Medicare, referred to herein as

 a “completed doctor’s order.” As that term was used during MEMON’s scheme, a

 completed “doctor’s order” (“DO”) was comprised of a prospective patient’s name,

 contact information, insurance information, and a doctor’s order or prescription for a
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 7 of 21




 DME orthotic brace, such as a knee, ankle, back, wrist, or shoulder brace for that

 particular patient.

                 b.    Aaron Williamsky (“WILLIAMSKY”) and Nadia Levit (“LEVIT”),

 coconspirators not charged herein, were residents of New Jersey who owned,

 operated, and/or had a financial or controlling interest in several DME supply

 companies (the “WILLIAMSKY/LEVIT DME Companies”), which primarily supplied

 DME to Medicare beneficiaries. The WILLIAMSKY/LEVIT DME Companies were

 enrolled with Medicare as suppliers of DME, and therefore, were authorized to bill

 Medicare for the supplying of orthotic braces. Pursuant to the requirements described

 above, the WILLIAMSKY/LEVIT DME Companies were also responsible for

 acknowledging that any claims made to Medicare complied with the relevant laws,

 regulations, and program instructions.

                 c.    Charles Burruss (“BURRUSS”) and Armani Adams (“ADAMS”),

 coconspirators not charged herein, were residents of California who owned, operated,

 and/or had a financial or controlling interest in several DME supply companies (the

 “BURRUSS/ADAMS DME Companies”), which primarily supplied DME to Medicare

 beneficiaries. The BURRUSS/ADAMS DME Companies were enrolled with Medicare

 as suppliers of DME, and therefore, were authorized to bill Medicare for the supplying

 of   orthotic    braces.   Pursuant   to   the   requirements   described   above,   the

 BURRUSS/ADAMS DME Companies were also responsible for acknowledging that

 any claims made to Medicare complied with the relevant laws, regulations, and

 program instructions. The WILLIAMSKY/LEVIT DME Companies and the



                                              2
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 8 of 21




 BURRUSS/ADAMS DME Companies will be referred to collectively as the “Subject

 DME Companies.”

              d.    As   described   more       fully   below,   MEMON   entered   into

 arrangements with WILLIAMSKY, LEVIT, BURRUSS, ADAMS, and others whereby

 the Subject DME Companies paid kickbacks and bribes to the MEMON Supply

 Companies in exchange for the MEMON Supply Companies providing them with

 completed DOs for DME, which the Subject DME Companies would thereafter bill to

 and be reimbursed by Medicare and other health care benefit programs, without

 regard for medical necessity.

                     Background on the Medicare Program

              e.    Medicare was a federally funded program established to provide

 medical insurance benefits for individuals aged 65 and older and certain disabled

 individuals who qualified under the Social Security Act. Individuals who receive

 benefits under Medicare were referred to as “Medicare beneficiaries.”

              f.    Medicare was administered by the Center for Medicare and

 Medicaid Services (“CMS”), a federal agency under the United States Department of

 Health and Human Services.

              g.    Medicare was divided into four parts, which helped cover specific

 services: Part A (hospital insurance), Part B (medical insurance), Part C (Medicare

 Advantage), and Part D (prescription drug coverage).




                                            3
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 9 of 21




              h.     Medicare Part B covered non-institutional care that included

 physician services and supplies, such as DME that were needed to diagnose or treat

 medical conditions and that met accepted standards of medical practice.

              i.     Medicare was a “health care benefit program,” as defined by 18

 U.S.C. § 24(b), and a “Federal health care program,” as defined by 42 U.S.C. § 1320a-

 7b(f), that affected commerce.

              j.     In order for a supplier of DME services to bill Medicare Part B,

 that supplier had to enroll with Medicare as a Durable Medical Equipment,

 Prosthetics, Orthotics, and Supplies (“DMEPOS”) supplier by completing a Form

 CMS-855S.

              k.     As provided in the Form CMS-855S, to enroll as a DMEPOS

 supplier, every DMEPOS supplier had to meet certain standards to obtain and retain

 billing privileges to Medicare, such as, but not limited to, the following: (i) provide

 complete and accurate information on the Form CMS-855S, with any changes to the

 information on the form reported within 30 days; (ii) disclose persons and

 organizations with ownership interests or managing control; (iii) abide by applicable

 Medicare laws, regulations and program instructions, such as, but not limited to, the

 Federal Anti-Kickback Statute (“AKS”) (42 U.S.C. § 1320a-7b(b)); (iv) acknowledge

 that the payment of a claim by Medicare was conditioned upon the claim and the

 underlying transaction complying with such laws, regulations and program

 instructions; and (v) refrain from knowingly presenting or causing to be presented a




                                           4
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 10 of 21




 false or fraudulent claim for payment by Medicare and submitting claims with

 deliberate ignorance or reckless disregard of their truth or falsity.

                                       TRICARE

              l.     TRICARE was a health care program of the U.S. Department of

 Defense (“DoD”) Military Health System that provided coverage for DoD beneficiaries

 worldwide, including active-duty service members, National Guard and Reserve

 members, retirees, their families, and survivors. The Defense Health Agency, an

 agency of the DoD, was the military entity responsible for overseeing and

 administering the TRICARE program.

              m.     TRICARE was a “health care benefit program,” as defined by 18

 U.S.C. § 24(b), and a “Federal health care program,” as defined by 42 U.S.C. § 1320a-

 7b(f), that affected commerce.

                                      CHAMPVA

              n.     The Civilian Health and Medical Program of the Department of

 Veterans Affairs (“CHAMPVA”) was a federal health care benefit program within the

 Department of Veterans Affairs (“VA”). CHAMPVA was a comprehensive health care

 program in which the VA shared the cost of covered health care services and supplies

 with eligible beneficiaries. The eligible categories for CHAMPVA beneficiaries were

 the spouses or children of veterans who had been rated permanently and totally

 disabled for a service-connected disability and the surviving spouse or child of a

 veteran who died from a VA-rated service-connected disability.




                                            5
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 11 of 21




              o.     In general, the CHAMPVA program covered most health care

 services and supplies that were medically and psychologically necessary. CHAMPVA

 was always the secondary payer to Medicare and reimbursed beneficiaries for costs

 that Medicare did not cover. Health care claims had to have first been sent to

 Medicare for processing. Medicare electronically forwarded claims to CHAMPVA

 after Medicare had processed them.

              p.     CHAMPVA was a “health care benefit program,” as defined by 18

 U.S.C. § 24(b), and a “Federal health care program,” as defined by 42 U.S.C. § 1320a-

 7b(f), that affected commerce.

                                     Telemedicine

              q.     Telemedicine allowed health care providers to evaluate, diagnose,

 and treat patients remotely—without the need for an in-person visit—by using

 telecommunications technology, such as the internet or telephone, to interact with a

 patient.

              r.     Medicare deemed telemedicine an appropriate means to provide

 certain health care related services (“telehealth services”) to beneficiaries, including,

 among other services, consultations, and office visits, only when certain requirements

 were met. These requirements included, among others, that: (i) the beneficiary was

 located in a rural area (outside a metropolitan area or in a rural health professional

 shortage area); (ii) the services were delivered via an interactive audio and video

 telecommunications system; and (iii) the beneficiary was at a licensed provider’s




                                            6
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 12 of 21




 office or a specified medical facility—not at a beneficiary’s home—during the

 telehealth service furnished by a remote provider.

              s.     Telehealth services could be covered by and reimbursable under

 Medicare, but only if telemedicine was generally appropriate, as outlined above, and

 only if the services were both ordered by a licensed provider and were reasonable and

 medically necessary to diagnose and treat a covered illness or condition.

                                   The Conspiracy

       2.     From in or around 2017 through in or around 2020, in the District of

 New Jersey, and elsewhere, defendant

                                 KAREEM MEMON

 did knowingly and intentionally conspire and agree with others to knowingly and

 willfully execute a scheme and artifice to defraud a health care benefit program and

 to obtain, by means of false and fraudulent pretenses, representations, and promises,

 money owned by, and under the custody and control of, a health care benefit program,

 as defined by 18 U.S.C. § 24(b), namely, Medicare, in connection with the delivery of

 and payment for health care benefits, items, and services, contrary to Title 18, United

 States Code, Section 1347.

                               Goal of the Conspiracy

       3.     The goal of the conspiracy was for MEMON and others to obtain money

 by submitting or causing the submission of false and fraudulent claims to Medicare

 and other federal and private health care benefit programs.




                                           7
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 13 of 21




                                 Manner and Means

       4.     The manner and means by which MEMON and others sought to

 accomplish the object of the conspiracy included, among other things, the following:

              a.     From in or around February 2015 through in or around April

 2019, WILLIAMSKY, LEVIT, BURRUSS, ADAMS and others began purchasing and

 establishing DME companies, including the Subject DME Companies, in New Jersey,

 New York, and elsewhere to fraudulently bill health care benefit programs, including

 Medicare, for various orthotic braces.

              b.     Through the Subject DME Companies, and/or other billing

 companies, WILLIAMSKY, LEVIT, BURRUSS, ADAMS, and others submitted

 and/or caused the submission of false or fraudulent claims to Medicare and other

 federal and private health care benefit programs for orthotic braces that were: (i) not

 medically necessary; (ii) never requested by a Medicare beneficiary; (iii) never

 received by a Medicare beneficiary; and/or (iv) provided based on a DO procured

 through the payment of kickbacks and bribes.

              c.     From in or around 2017 through in or around 2020, the Subject

 DME Companies entered into kickback agreements with a number of individuals and

 entities who were able to generate completed DOs (the “DME Suppliers”). The Subject

 DME Companies paid the DME Suppliers, including MEMON, kickbacks ranging

 from approximately $125 to $450 for each completed DO.

              d.     MEMON and others sold completed DOs from the MEMON

 Supply Companies to the Subject DME Companies, and others, located in New Jersey



                                           8
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 14 of 21




 and elsewhere.

              e.    In general, the DME Suppliers obtained completed DOs for DME

 for beneficiaries located in the United States and elsewhere through the use of

 marketing call centers and telemedicine companies with whom they had

 relationships.

              f.    To conceal the payment of kickbacks, the Subject DME

 Companies entered into sham “Marketing, Business Process Outsourcing and Call

 Center” agreements (“Marketing Agreements”) with the DME Suppliers. On paper,

 the Marketing Agreements called for the DME Suppliers to provide “raw leads”

 generated from various advertising campaigns for orthotic braces to the Subject DME

 Companies. According to the agreements, these raw leads were to consist only of

 information of individuals responding to the advertisements indicating an interest in

 orthotic braces. In reality, the DME Suppliers provided WILLIAMSKY, LEVIT,

 BURRUSS, ADAMS, and others affiliated with their DME Companies with

 completed DOs and not “raw leads.”

              g.    Once the Subject DME Companies received the completed DOs

 from the DME Suppliers, they arranged for the shipping of the ordered orthotic

 brace(s) to the beneficiary and electronically submitted and/or caused the electronic




                                          9
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 15 of 21




 submission of a claim to Medicare and other federal and private health care benefit

 programs for payment.

             h.     Based on the submission of these claims, the Subject DME

 Companies received from Medicare and other federal and private health care benefit

 programs payments that they were not entitled to receive.

             i.     As a result of MEMON’s participation in the health care fraud

 kickback scheme, from in or around 2017 through in or around 2020, MEMON and

 his coconspirators caused a loss to Medicare of approximately $11,384,001.

       In violation of Title 18, United States Code, Section 1349.




                                          10
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 16 of 21




                                    COUNT 2
            (Conspiracy to Violate the Federal Anti-Kickback Statute)

       1.        The allegations in Paragraphs 1 and 3 through 5 of Count 1 are re-

 alleged here.

       2.        From in or around February 2017 through in or around 2020, in the

 District of New Jersey, and elsewhere, defendant

                                  KAREEM MEMON

 did knowingly and intentionally conspire and agree with others to commit an offense

 against the United States, that is, to knowingly and willfully solicit and receive

 remuneration, directly and indirectly, overtly and covertly, in cash and in kind, that

 is, kickbacks and bribes, from any person in return for purchasing, ordering, and

 arranging for, and recommending purchasing and ordering, any good, item, and

 service, namely, durable medical equipment, for which payment may be made in

 whole and in part under a Federal health care program, as defined by 18 U.S.C. §

 24(b), namely, Medicare, TRICARE, and CHAMPVA, contrary to Title 42, United

 States Code, Section 1320a-7b(b)(1)(B).

                                Goal of the Conspiracy

       3.        The goal of the conspiracy was for MEMON and his coconspirators to

 unlawfully enrich themselves by soliciting and receiving kickbacks and bribes for the

 referral of Medicare beneficiaries for DME to the Subject DME Companies and

 others, for which the DME companies billed to and obtained payments from Medicare

 and other federal health care benefit programs.




                                           11
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 17 of 21




                                 Manner and Means

       4.     The manner and means by which MEMON and others sought to

 accomplish the object of the conspiracy included, among other things, the following:

              a.    As described in Paragraphs 3 through 5 of Count 1, MEMON

 entered into kickback arrangements with WILLIAMSKY, LEVIT, BURRUSS,

 ADAMS, and others. Pursuant to those arrangements, MEMON and his

 coconspirators solicited and received kickbacks for each DO for DME provided to the

 Subject DME Companies. To conceal the payment of kickbacks, the Subject DME

 Companies entered into sham Marketing Agreements with MEMON and others.

              b.     As a result of MEMON’s participation in the health care fraud

 and kickback scheme, from in or around 2017 through in or around 2020, MEMON

 and his coconspirators caused a loss to Medicare and other federal health care benefit

 programs of at least approximately $11,384,001.

              c.    From in or around February 2017 through in or around 2020,

 MEMON, through the MEMON Supply Companies) received kickbacks of

 approximately $1,486,261.78 for completed DOs provided pursuant to the conspiracy.

                                     Overt Acts

       5.     In furtherance of the conspiracy and to effect its object, MEMON and

 others committed or caused the commission of the following overt acts in the District

 of New Jersey and elsewhere:

              a.    On or about April 9, 2018, WILLIAMSKY and LEVIT, based in

 New Jersey, caused a WILLIAMSKY/LEVIT holding company based in New Jersey



                                          12
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 18 of 21




 to provide MEMON kickbacks of approximately $36,000 in exchange for completed

 DOs for DME.

             b.     On or about April 10, 2018, WILLIAMSKY and LEVIT, based in

 New Jersey, caused a WILLIAMSKY/LEVIT holding company based in New Jersey

 to provide MEMON kickbacks of approximately $36,000 in exchange for completed

 DOs for DME.

       In violation of Title 18, United States Code, Section 371.




                                          13
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 19 of 21




                           FORFEITURE ALLEGATIONS

       1.     Upon conviction of the offenses alleged in Counts 1 and 2 of this

 Information, defendant KAREEM MEMON shall forfeit to the United States,

 pursuant to 18 U.S.C. § 982(a)(7), all property, real or personal, that constitutes or is

 derived, directly and indirectly, from gross proceeds traceable to the commission of

 the federal health care offenses (as defined by 18 U.S.C. § 24(a)) alleged in this

 Information, which was approximately $1,486.261.78.

                          SUBSTITUTE ASSETS PROVISION
                        (Applicable to All Forfeiture Allegations)

       2.      If any of the above-described forfeitable property, as a result of any act

 or omission of the defendant:

              (a)    cannot be located upon the exercise of due diligence;

              (b)    has been transferred or sold to, or deposited with, a third person;

              (c)    has been placed beyond the jurisdiction of the Court;

              (d)    has been substantially diminished in value; or

              (e)    has been commingled with other property which cannot be

                     subdivided without difficulty;




                                            14
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 20 of 21




 the United States shall be entitled to forfeiture of substitute property, pursuant to 21

 U.S.C. § 853(p), as incorporated by 18 U.S.C. § 982(b).




                                                __________________________
                                                VIKAS KHANNA
                                                Attorney for the United States,
                                                Acting Under Authority Conferred
                                                By 28 U.S.C. § 515




                                           15
Case 0:24-cr-60004-RS Document 1 Entered on FLSD Docket 01/11/2024 Page 21 of 21




                           CASE NUMBER: 24-17(MEF)
                    ═════════════════════════════════
                   United States District Court
                     District of New Jersey
                    ═════════════════════════════════
                     UNITED STATES OF AMERICA

                                      v.

                             KAREEM MEMON

                    ═════════════════════════════════
                        INFORMATION FOR
                                18 U.S.C. § 1349
                                 18 U.S.C. § 371

                    ═════════════════════════════════
                                VIKAS KHANNA
                       ATTORNEY FOR THE UNITED STATES
                      ACTING UNDER AUTHORITY CONFERRED
                              BY 28 U.S.C. § 515
                             NEWARK, NEW JERSEY
                    ═════════════════════════════════
                              MATTHEW SPECHT
                           ASSISTANT U.S. ATTORNEY
                            NEWARK, NEW JERSEY
                                (973) 353-6061
                    ═════════════════════════════════


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