Superseding Indictment — United States v. Aaron J. Rossi, No. 22-CR-10012 (Dkt. 29, C.D. Ill.)

Summary

A grand jury in the Central District of Illinois returned a superseding indictment charging Aaron J. Rossi with six counts of mail fraud and three counts of making and subscribing a false tax return. The indictment says Rossi, office manager at Central Illinois Orthopedic Surgery in Bloomington, earned a medical degree from a medical school in Barbados but was not licensed to practice medicine in Illinois, and portrayed himself as a physician. From at least December 2014 until March 2018, Rossi allegedly used the practice's credit cards and funds for personal purchases, including a home audio-visual system and the lease of a private jet, defrauding the practice and its two owners of more than $1,000,000. The mail fraud counts rest on Amazon orders such as a carpet cleaner and a Sony 49-Inch 4K Ultra HD Smart LED TV, and the tax counts on returns for 2015, 2016 and 2017.

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:22-cr- - -JEH #29 P 1ofs

Thursday, 07 July, 2022 09:15:36 AM
Clerk, U.S. District Court, ILCD

IN THE UNITED STATES DISTRICT COURT : ; L = ail
CENTRAL DISTRICT OF ILLINOIS JUL 06 2022

PEORIA DIVISION
CLERK OF THE COURT
U.S. DISTRICT COURT

UNITED STATES OF AMERICA, _ ) CENTRAL DISTRICT OF ILLINOIS
)
Plaintiff, )
)
VS. ) Case No. 22-CR-10012
)
AARON J. ROSSI, ) 18 U.S.C. § 1341
) 26 U.S.C. § 7206(1)
Defendant. )

SUPERSEDING INDICTMENT

The Grand Jury charges:

COUNTS 1 - 6
(Mail Fraud)

Background

At all times material to this Indictment:

1. Central Illinois Orthopedic Surgery (“CIOS”), located in
Bloomington, Illinois, provided surgical orthopedic services, physical therapy,
and sports medicine services.

2. CIOS was owned by two licenséd physicians, identified herein as
Victim A and Victim B.

3. In approximately 2008, Defendant AARON J. ROSSI (“ROSSI”)

worked as an extern at CIOS.
1:22-cr-10012-SLD-JEH #29 Page2of8

4. In or around July 2012, ROSSI earned a medical degree from a medical
school in Barbados.

5. After obtaining the medical degree, ROSSI did not complete either a
medical residency or fellowship. As a result, ROSSI was not eligible to be licensed
as a physician in the State of Illinois.

6. In or around late 2012, ROSSI was hired by CIOS to assist with
administrative duties. Shortly thereafter, ROSSI became the CIOS office manager.
Over time, ROSSI assumed greater administrative responsibilities at CIOS,
including responsibilities involving CIOS finances, financial accounts, and credit
cards.

7. ROSSI also worked as a “surgical assistant” at CIOS. As a surgical
assistant, ROSSI could only work under the direct supervision of a licensed
physician.

8. On or about March 15, 2018, ROSSI was terminated by CIOS.
1:22-cr-10012-SLD-JEH #29 Page3of8

Scheme to Defraud

9. Beginning at least as early as December 2014 and continuing until in
or about March 2018, in McLean County, Illinois, in the Central District of Illinois,
and elsewhere,

AARON J. ROSSI,
defendant herein, did knowingly engage and attempt to engage in a scheme and
artifice to defraud CIOS, Victim A, Victim B, and others and to obtain money and
property by means of materially false and fraudulent pretenses, representations,
and promises.

10. It was a part of the scheme that ROSSI portrayed himself as a
physician and allowed others to falsely believe that he was a physician licensed to
practice medicine. In truth and fact, as he well knew, ROSSI was not licensed to
practice medicine in the State of Illinois and had been directed by the State of
Illinois Department of Professional Regulation to cease and desist from making
that false representation.

11. ‘It was further a part of the scheme that ROSSI abused his role and
administrative responsibilities at CIOS for his personal benefit and gain.

12. ‘It was further a part of the scheme that ROSSI moved the CIOS bank
account from Commerce Bank to Chase Bank and changed the accountants CIOS

used.
1:22-cr-10012-SLD-JEH #29 Page4of8

13. ‘It was further a part of the scheme that, unbeknownst to Victim A and
Victim B, ROSSI used CIOS credit cards and funds for his personal use and benefit.
This included the purchase of an audio-visual system for his home, the lease of a
private jet, car repairs, various personal items, and payments made on his personal
credit card.

14. ‘It was further a part of the scheme that ROSSI made and caused to be
made false and misleading entries into the books and records of CIOS to conceal
the true nature of ROSSI’s purchases and expenditures.

15. Asa result of the scheme and artifice to defraud, AARON J. ROSSI
defrauded CIOS, Victim A, Victim B, and others of more than $1,000,000.

Mailings

16. Onor about the below-listed dates, in McLean County, in the Central

District of Illinois and elsewhere,

AARON J. ROSSI,
Defendant herein, for the purpose of executing and attempting to execute the
above-described scheme and artifice to defraud, did knowingly order products
from Amazon, an online retailer, and caused those below described products to be
delivered by mail and by private commercial interstate carrier, according to the

directions thereon, to his residence in McLean County, Illinois:
1:22-cr-10012-SLD-JEH #29 Page5of8

Count Date | Means Mailing

1 7/12/17 UPS Folding Propellers Black Drone Kit
Remote

2 7/12/2017 USPS | Nike Squadra Short Sleeve Training
Top

3 7/13/2017 USPS Collapsible Quadcopter with Remote

4 8/20/2017 USPS Bissell ProHeat Full-Size Carpet Cleaner

5 8/20/2017 UPS Dyson V8 Animal Cordless Stick

6 12/14/2017 UPS Sony 49-Inch 4K Ultra HD Smart LED
TV

All in violation of Title 18, United States Code, Section 1341.
1:22-cr-10012-SLD-JEH #29 Page6éof8

COUNT 7
(Making and Subscribing a False Tax Return)

17. The grand jury realleges and incorporates by reference paragraphs 1-
15 as paragraph 17 as if fully set forth herein.

18. On or about April 15, 2016, in the Central District of Illinois and
elsewhere,

AARON J. ROSSL

defendant herein, a resident of Bloomington, Illinois, did willfully make and
subscribe and caused to be filed with the IRS, a joint U.S. Individual Income Tax
Return, Form 1040, for calendar year 2015 which was verified by a written
declaration that it was made under the penalties of perjury and which he did not
believe to be true and correct as to every material matter, that Form 1040, which
was prepared and signed in the Central District of Illinois and was filed with the
Internal Revenue Service, reported taxable income of $324,836, whereas as he then
and there knew, he received income in addition to the amount stated in the return.

In violation of Title 26, United States Code, Section 7206(1).
1:22-cr-10012-SLD-JEH #29 Page/7of8

COUNT 8
(Making and Subscribing a False Tax Return)

19. ‘The grand jury realleges and incorporates by reference paragraphs 1-
15 as paragraph 19 as if fully set forth herein.

20. On or about May 22, 2017, in the Central District of Illinois and
elsewhere,

AARON J. ROSSL

defendant herein, a resident of Bloomington, Illinois, did willfully make and
subscribe and caused to be filed with the IRS, a single U.S. Individual Income Tax
Return, Form 1040, for calendar year 2016 which was verified by a written
declaration that it was made under the penalties of perjury and which he did not
believe to be true and correct as to every material matter, that Form 1040, which
was prepared and signed, and he caused to be signed, in the Central District of
[linois and was filed with the Internal Revenue Service, reported taxable income
of $500,341, whereas as he then and there knew, he received income in addition to
the amount stated in the return.

In violation of Title 26, United States Code, Section 7206(1).
1:22-cr-10012-SLD-JEH #29 Page8of8

COUNT 9
(Making and Subscribing a False Tax Return)

21. The grand jury realleges and incorporates by reference paragraphs 1-
15 as paragraph 21 as if fully set forth herein.

22. On or about July 30, 2018, in the Central District of Illinois and
elsewhere,

AARON J. ROSSI,

defendant herein, a resident of Bloomington, Illinois, did willfully make and
subscribe and caused to be filed with the IRS, a joint U.S. Individual Income Tax
Return, Form 1040, for calendar year 2017 which was verified by a written
declaration that it was made under the penalties of perjury and which he did not
believe to be true and correct as to every material matter, that Form 1040, which
was prepared and signed, and he caused to be signed, in the Central District of
Illinois and was filed with the Internal Revenue Service, reported taxable income
of $472,180, whereas as he then and there knew, he received income in addition to
the amount stated in the return.

In violation of Title 26, United States Code, Section 7206(1).

A TRUE BILL.
aN kes!
s/Gregory Harris s/Fore person
"GREGORY K. HARRIS FOREPERSON
United States Attorney

Kgl/Dfm

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