Pandemic Darlings The pandemic economy, in original documents
Home Source documents United States’ Opposition to Defendant’s Motion for Judgment of Acquittal or, in the Alternative, for a New Trial — No. 1:22-CR-00146 (Dkt. 85, D. Md.)

United States’ Opposition to Defendant’s Motion for Judgment of Acquittal or, in the Alternative, for a New Trial — No. 1:22-CR-00146 (Dkt. 85, D. Md.)

Summary

The United States asks the District of Maryland to deny Ron Elfenbein’s motion for judgment of acquittal or a new trial in this opposition, filed September 1, 2023 by the U.S. Attorney’s Office and the Justice Department’s Fraud Section. Elfenbein, an owner and the medical director of Drs ERgent Care, was convicted on August 4, 2023 of all five counts of health care fraud after a three-week jury trial. The government says the insurer of nearly every patient who came to the clinic for a COVID-19 test was also billed for an evaluation and management visit of purportedly 30 or more minutes, while Elfenbein instructed providers that patients should be seen in five minutes or less. It argues that the visits were not Level 4 services, that Elfenbein’s testimony was not credible, and that the exclusion of three defense email exhibits and the voir dire process were proper.

Summary drafted by a model from the document's text below 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

Full text

                      UNITED STATES DISTRICT COURT
                         DISTRICT OF MARYLAND



UNITED STATES OF AMERICA,

 v.                                              CASE NO. 1:22-CR-00146-JKB


RON ELFENBEIN,

                  Defendant.
_____________________________/


UNITED STATES’ OPPOSITION TO DEFENDANT’S MOTION FOR JUDGMENT OF
        ACQUITTAL OR, IN THE ALTERNATIVE, FOR A NEW TRIAL




                                 GLENN S. LEON, CHIEF
                                 CRIMINAL DIVISION, FRAUD SECTION
                                 U.S. DEPARTMENT OF JUSTICE

                                 EREK L. BARRON
                                 UNITED STATES ATTORNEY

                                 Matthew P. Phelps
                                 Assistant United States Attorney

                                 D. Keith Clouser
                                 U.S. Department of Justice
                                 Criminal Division, Fraud Section
                                 1400 New York Avenue, N.W.
                                 Washington, D.C. 20005
                                 david.clouser@usdoj.gov

                                 COUNSEL FOR THE UNITED STATES
                                                   TABLE OF CONTENTS

PROCEDURAL AND FACTUAL BACKGROUND.................................................................... 1

I.        THE COURT SHOULD DENY DEFENDANT’S MOTION FOR JUDGMENT OF
          ACQUITTAL ...................................................................................................................... 2

                     1.         Defense expert, Hugh Hill, MD, told the jury everything it needed
                                to know about whether the Defendant’s providers were providing
                                a Level 4 service. ........................................................................................ 4

                     2.         The code is written in English and the Defendant’s instructions do not
                                meet the definition of a Level 4. ................................................................. 5

                     3.         Expert testimony that is based on inaccurate, vague, and misleading
                                medical records has no value. ..................................................................... 7

                     4.         Hybrid expert witnesses and fact witnesses testified that Dr. Elfenbein’s
                                practitioners were not providing a Level 4 service. .................................... 9

                     5.         Evidence of the defendant’s intent is relevant to falsity. .......................... 12

                     6.         The patients who testified about the charged counts reported brief
                                encounters that were consistent with the Defendant’s instructions and
                                inconsistent with Level 4 visits. ................................................................ 13

II.       THE COURT SHOULD DENY DEFENDANTS MOTION FOR A NEW TRIAL ....... 15

          A.         The Weight of the Evidence Supports the Jury’s Verdict..................................... 15

                     1.         The Testimony Of The Government’s Witnesses Was Credible, And
                                Established The Defendant’s Guilt Beyond A Reasonable Doubt. .......... 16

                     2.         The Defendant’s Testimony Was Not Credible. ....................................... 22

          B.         The Court’s Evidentiary Rulings Were Correct.................................................... 26

                     1.         The Defendant’s Three Proposed Email Exhibits Were
                                Properly Excluded ..................................................................................... 27

                     2.         The Court Properly Admitted The Testimony Of A.H. ............................ 33

          C.         The Court’s Voir Dire Process Did Not Violate Defendant’s Sixth Amendment
                     Rights .................................................................................................................... 38

CONCLUSION ............................................................................................................................. 40




                                                                             ii
                                            INDEX OF EXHIBITS

Exhibit Number             Description
Exhibit 1 ..............   July 17, 2023 Trial Transcript (Day 1)
Exhibit 2 ..............   July 18, 2023 Trial Transcript (Day 2)
Exhibit 3 ..............   July 19, 2023 Trial Transcript (Day 3)
Exhibit 4 ..............   July 20, 2023 Trial Transcript (Day 4)
Exhibit 5 ..............   July 24, 2023 Trial Transcript (Day 5)
Exhibit 6 ..............   July 25, 2023 Trial Transcript (Day 6)
Exhibit 7 ..............   July 26, 2023 Trial Transcript (Day 7)
Exhibit 8 ..............   July 27, 2023 Trial Transcript (Day 8)
Exhibit 9 ..............   July 31, 2023 Trial Transcript (Day 9)
Exhibit 10 ............    August 1, 2023 Trial Transcript (Day 10)
Exhibit 11 ............    August 2, 2023 Trial Transcript (Day 11)
Exhibit 12 ............    Government’s Trial Exhibit 137
Exhibit 13 ............    Excerpt from Government’s Trial Exhibit 402
Exhibit 14 ............    Excerpt from Government’s Trial Exhibit 402
Exhibit 15 ............    Excerpt from Government’s Trial Exhibit 402
Exhibit 16 ............    Excerpt from Government’s Trial Exhibit 402
Exhibit 17 ............    Government’s Trial Exhibit 403
Exhibit 18 ............    Government’s Trial Exhibit 404
Exhibit 19 ............    Government’s Trial Exhibit 407
Exhibit 20 ............    Government’s Trial Exhibit 408
Exhibit 21 ............    Government’s Trial Exhibit 409
Exhibit 22 ............    Government’s Trial Exhibit 410
Exhibit 23 ............    Government’s Trial Exhibit 413
Exhibit 24 ............    Government’s Trial Exhibit 414
Exhibit 25 ............    Government’s Trial Exhibit 415
Exhibit 26 ............    Government’s Trial Exhibit 501
Exhibit 27 ............    Government’s Trial Exhibit 502
Exhibit 28 ............    Government’s Trial Exhibit 601
Exhibit 29 ............    Government’s Trial Exhibit 605
Exhibit 30 ............    Government’s Trial Exhibit 606

                                                       iii
Exhibit Number            Description
Exhibit 31 ............   Government’s Trial Exhibit 607
Exhibit 32 ............   Government’s Trial Exhibit 608
Exhibit 33 ............   Government’s Trial Exhibit 609
Exhibit 34 ............   Government’s Trial Exhibit 614
Exhibit 35 ............   Government’s Trial Exhibit 617
Exhibit 36 ............   Government’s Trial Exhibit 626
Exhibit 37 ............   Government’s Trial Exhibit 628
Exhibit 38 ............   Government’s Trial Exhibit 629
Exhibit 39 ............   Government’s Trial Exhibit 631
Exhibit 40 ............   Government’s Trial Exhibit 635
Exhibit 41 ............   Government’s Trial Exhibit 638
Exhibit 42 ............   Government’s Trial Exhibit 643
Exhibit 43 ............   Government’s Trial Exhibit 644
Exhibit 44 ............   Government’s Trial Exhibit 645
Exhibit 45 ............   Government’s Trial Exhibit 646
Exhibit 46 ............   Government’s Trial Exhibit 647
Exhibit 47 ............   Government’s Trial Exhibit 654
Exhibit 48 ............   Government’s Trial Exhibit 658
Exhibit 49 ............   Government’s Trial Exhibit 938
Exhibit 50 ............   Defendant’s Trial Exhibit 51
Exhibit 51 ............   Defendant’s Trial Exhibit 214
Exhibit 52 ............   Defendant’s Trial Exhibit 219
Exhibit 53 ............   Defendant’s Trial Exhibit 255




                                                         iv
       The United States of America, through undersigned counsel, hereby opposes and responds

to Defendant’s Motion For Judgment Of Acquittal Or, In The Alternative, For A New Trial, ECF

78. For the reasons stated below, the Court should deny Defendant’s motion.

                       PROCEDURAL AND FACTUAL BACKGROUND

       On January 11, 2023, Defendant was charged in a Superseding Indictment with five counts

of execution of a health care fraud scheme, in violation of 18 U.S.C. § 1347. See ECF 29. The

Superseding Indictment alleges that Defendant was an owner and the medical director of Drs

ERgent Care, an urgent care clinic in Maryland that provided drive-through COVID-19 testing. In

addition to billing individuals’ insurance for COVID-19 tests, Defendant required that the COVID-

19 tests and reporting of results be bundled with more lucrative evaluation and management

services that were not provided as represented. That is, the insurance carrier of nearly every patient

who came to Defendant’s clinic for a COVID-19 test was also billed for an evaluation and

management visit of purportedly 30 or more minutes in duration or involving moderate or high

levels of medical decision making. Rather than providing such evaluation and management visits,

Defendant instructed providers that patients were there only to be tested, that the providers were

not there to address complex medical issues, and that patients should be seen in five minutes or

less. Defendant nevertheless instructed the providers to bill for high-level office visits.

       On August 4, 2023, following a three-week jury trial during which the government

presented twelve witnesses and introduced more than 120 exhibits and the defense presented

several witness including the Defendant and additional exhibits, Defendant was convicted of all

five counts of health care fraud. Defendant filed a motion for judgment of acquittal or, in the

alternative, for a new trial on August 18, 2023. See ECF 78.




                                                      1
I.     THE COURT SHOULD DENY                        DEFENDANT’S          MOTION        FOR
       JUDGMENT OF ACQUITTAL

           A. Rule 29 Standard

       Federal Rule of Criminal Procedure 29 permits a defendant to move for a judgment of

acquittal, or renew such motion, after a guilty verdict. Fed. R. Crim. P. 29(c). In evaluating a

Rule 29 motion, a jury’s verdict commands the respect of the reviewing court, United States v.

Siegelman, 640 F.3d 1159, 1164 (11th Cir. 2011) (noting that jurors are asked to sit through “long

days” of testimony and “pore over countless documents to decide what happened”), and their

judgment is entitled to great deference. United States v. Hicks, 368 F.3d 801, 804 (7th Cir. 2004);

United States v. Mercado, 610 F.3d 841, 845 (3d Cir. 2010) (“We apply a particularly deferential

standard when determining if a jury verdict rests on sufficient evidence”). The task of a defendant

who challenges the sufficiency of the evidence is accordingly a daunting one. United States v.

Curtis, 324 F.3d 501, 505 (7th Cir. 2003); United States v. Seawood, 172 F.3d 986, 988 (7th Cir.

1999) (a defendant making a sufficiency of the evidence challenge bears a heavy burden and faces

a nearly insurmountable hurdle”); United States v. Zambrano, 776 F.2d 1091, 1094 (2d Cir. 1985)

(such challenges are “seldom successful”).

       The jury’s verdict must be sustained if there is substantial evidence in the record to support

it. Glasser v. United States, 315 U.S. 60, 80 (1942); United States v. Wilson, 198 F.3d 467, 469

(4th Cir. 1999). In determining whether the evidence in the record is substantial, the court must

view the evidence in the light most favorable to the government, drawing all reasonable inferences

from the evidence in its favor. United States v. Harvey, 532 F.3d 326, 333 (4th Cir. 2008); United

States v. Moye, 454 F.3d 390, 394 (4th Cir. 2006); Hicks, 368 F.3d at 804; United States v.

Tresvant, 677 F.2d 1018, 1021 (4th Cir. 1982) (the government is granted “the benefit of all

reasonable inferences from the facts proven to those sought to be established”). A judgment of


                                                     2
acquittal should be granted only if “there is no interpretation of the evidence that would allow a

reasonable jury to find the defendant guilty . . . .” United States v. Gomez, 165 F.3d 650, 654 (8th

Cir. 1999) (emphasis added); Moye, 454 F.3d at 394 (conviction can be reversed based upon

insufficiency of the evidence only where the government’s failure is clear); United States v. Jones,

735 F.2d 785, 791 (4th Cir. 1984). If any rational trier of fact could have found the essential

elements of the crime beyond a reasonable doubt, then the jury’s verdict must be sustained.

Jackson v. Virginia, 443 U.S. 307, 319 (1979); Tresvant, 677 F.2d at 1021. Where the evidence

supports differing reasonable interpretations, it is the jury’s responsibility to determine which

interpretation to accept. Moye, 454 F.3d at 394; Wilson, 118 F.3d at 234. And in particular, intent

to defraud may be inferred from the totality of the circumstances, and need not be proven by direct

evidence. Harvey, 532 F.3d at 334.

           B. The Government did not need an expert audit to show that Level 4 was
              incorrect.

       The Defendant claims he is entitled to an acquittal because the Government did not offer

expert testimony that the Defendant’s Level 4 billings for the charged patient encounters were

false. Although the Defendant offered his own expert, Michael Miscoe, his opinions were based

on an audit of inaccurate, vague, and misleading medical records that did not accurately reflect the

interactions between patients and providers at Defendant’s clinic. The Government, by contrast,

adduced evidence that the Level 4 billing was false based on what actually occurred during these

patient encounters. As explained below, the Government offered evidence of falsity through the

Defendant’s own instructions, through testimony from the patients, through testimony from the

Defendant’s employees, and through the sheer volume of the Defendant’s mass-testing operation.

In addition, the inaccurate, vague, and misleading nature of the medical records demonstrated that

the Defendant’s providers were not offering a Level 4 service to their patients.

                                                     3
                1.     Defense expert, Hugh Hill, MD, told the jury everything it needed to
                know about whether the Defendant’s providers were providing a Level 4
                service.

        Defense expert, Hugh Hill, MD (“Dr. Hill”), was an emergency room physician at Johns

Hopkins Bayview, and he testified about the level of care and decision-making needed for patients

during the pandemic. Dr. Hill’s testimony showed that the Defendant’s providers could not have

provided a Level 4 service to their patients.

        The trial evidence showed that the Defendant’s providers could see more than 100 hundred

patients in one day. One email from the Defendant stated that two providers saw 350 patients in

one day. Exhibit 41 (Gov’t Trial Ex. 638). Before Dr. Hill testified on Monday, July 31st, defense

witness Steven Carroll testified that he saw as many as 170 patients in one day. Exhibit 9 (7/31/23

Tr.) at 15. Dr. Hill responded in disbelief when he was confronted with these facts. See id. at 106.

Dr. Hill testified as follows:

                Q.      And you’re aware that Dr. Elfenbein’s providers could see
                        in excess of 150 patients in a day?

                A.      I doubt if they were seeing that many personally. I do know
                        that the statistics on this say that a small percentage of
                        providers can see 5o to 60 patients in a day, depending on
                        the circumstances.

                Q.      So you don’t actually believe that they actually – that a single
                        provider actually saw 150 patients in a day?

                A.      I do not.

                Q.      Why not?

                A.      Because it seems like that’s an excessive burden. …

                ...

                Q.      That one nurse practitioner, you would not expect that nurse
                        practitioner to see 150 patients in a day, would you?

                A.      I would not.


                                                       4
               Q.      Okay. Why not?

               A.      Because that’s too many to have time for, even if you’re
                       working, you know, a 24-hour shift.

Id. at 106-07. But the evidence showed that is exactly what Defendant was telling insurance

companies that his providers were doing—conducting moderate complexity, level 4 office visits

on hundreds of patients a day at drive-through COVID-19 testing sites. See, e.g., Exhibit 41 (Gov’t

Trial Ex. 638) (“Our volumes continue to explode. Jimmy and Crystal yesterday s[aw] over 350

people. It was amazing.”), Exhibit 42 (Gov’t Trial Ex. 643) (“EH opened this week and we are

already seeing over 150[.]”). Defendant even offered bonuses to providers who saw more than

100 people in a day. Exhibit 43 (Gov’t Trial Ex. 644) (“Additionally and this is in perpetuity, we

will pay $5/patient for every patient you see over 100.”); Exhibit 44 (Gov’t Trial Ex. 645) (“If you

see more then 100 patients you get 1 hour of paid time to chart. If you see more than 150 patients

you get 1 more hour to chart.”). Dr. Hill’s testimony, without more, shows that the Defendant’s

Level 4 billing scheme was false.

               2.     The code is written in English and the Defendant’s instructions do not
               meet the definition of a Level 4.

       Defense counsel told the jury during closing argument that the jury should not use common

sense to evaluate this case. That is because the Defendant’s billing instructions were not consistent

with a common-sense reading of the CPT Code and its accompanying resources.

       For example, the 2020 CPT code for 99204 required “moderate complexity” decision

making and, “typically,” the visit was expected to last 45 minutes. ECF 78, Ex. 3 (2020 CPT

Manual) at 13. The 2021 CPT code for 99204 required a “moderate level” of medical decision

making. ECF 78, Ex. 4 (2021 CPT Manual) at 19. By contrast, the Defendant told his providers

that “[w]e are not there to solve complex medical issues, etc… Just to test them.” and “we want

them in and out of the tent in under 5 minutes total.” Exhibit 47 (Gov’t Trial Ex. 654). Both the

                                                     5
2020 and 2021 CPT Codes for 99202 (Level 2) required “straightforward” medical decision-

making. See ECF 78, Ex. 3 at 13, Ex. 4 at 18. Dr. Elfenbein told one of his providers, “the patients

are all here for one reason . . . . simple and straightforward-to get tested[.]” Exhibit 45 (Gov’t

Trial Ex. 646).    A common-sense application of the CPT Code to the defendant’s billing

instructions shows that Level 4 billing was false.

       The CPT Coding resources cited by the defense also showed that the defendant’s billing

instructions were false.    Both the Novitas and AMA scoring sheets provide for moderate

complexity decision making when treating an “undiagnosed new problem with uncertain

prognosis.” The example offered in both the Novitas scoring sheet and in the 2021 CPT Code is

“lump in breast.” To justify his coding instructions, Dr. Elfenbein had to equate a healthy,

asymptomatic, vaccinated person who just needed a test for an administrative reason with a patient

who had a lump in their breast. See Exhibit 11 (8/2/23 Tr.) at 126-27. Similarly, Dr. Elfenbein

testified that a patient who had been diagnosed with COVID-19 and needed a test to return to work

had an “undiagnosed new problem.”1 Id. at 171.

       The Defendant’s explanations were not credible. His explanations were pretext for billing

a level 4 when, in fact, the Defendant knew he was churning through patients like a “herd of cattle.”

See Exhibit 48 (Gov’t Trial Ex. 658) (provider stating “I feel there is constant pressure of moving

a herd of cattle through a pass at 60 heads per minute!!”)




1
  The defense further argues that the ICD 10 diagnosis code for exposure to COVID-19 mandated
a finding that a patient had an “undiagnosed new problem.” See ECF 78 at 26-27. This mandate
does not appear anywhere. The only people to suggest such a “mandate” are the defendant and his
expert. As explained in several places herein, the defendant’s theory that every patient who
showed up for testing had an “undiagnosed new problem of uncertain prognosis” was not credible.
                                                     6
               3.    Expert testimony that is based on inaccurate, vague, and misleading
               medical records has no value.

       The evidence showed that the medical records—which were templates created by the

Defendant—were inaccurate, vague, and misleading. Neither the Government nor the Defendant

could not have obtained a reliable expert opinion based on these records, and the jury agreed.

       The trial evidence showed that the medical records were inaccurate. Patient A.H. disagreed

with significant portions of her records. Exhibit 3 (7/19/23 Tr.) at 108-110. Patient W.R.’s record

is an in-person record with a full physical exam even though the visit took place by video and the

“physical exam” consisted of Patient S.T. leaning back in her seat so that Provider Kathy Wrona

could see W.R. on the screen across the car. See Exhibit 19 (Trial Ex. 407)2 at 6-9; Exhibit 5

(7/24/23 Tr.) at 99-102. D.M.’s medical record indicated that she was negative for COVID-19 but

later the record stated she was positive. Exhibit 18 (Trial Ex. 404) at 4-6. The medical records

often stated that a patient was exposed to person with COVID-19 when hand-written registration

documents completed by the patient indicated that they were not exposed.

       The medical records were also vague. Defendant’s templated language for the medical

records contained generic descriptions of patient encounters that did not inform what treatment, if

any, was provided to a particular patient. The Government showed that the same care plan was

used for multiple patients, each of whom had a different presentation. See, e.g., Exhibit 13

(Excerpt from Gov’t Trial Ex. 402) at 5; Exhibit 14 (Excerpt from Gov’t Trial Ex. 402) at 4; Exhibit

15 (Excerpt from Gov’t Trial Ex. 402) at 3; Exhibit 16 (Excerpt from Gov’t Trial Exhibit 402) at

5. Two of the patients were sick, one needed a test to travel, and one needed a test prior to




2
  Although redacted versions of each of the patient records was discussed in open court during
trial, the government has applied additional redactions to these records for purposes of this filing
to remove patient identifying information including full names.
                                                     7
undergoing surgery. Id. Every care plan contained generic phrases like “patient to follow current

CDC guidelines,” “advised patient to monitor AM and PM temps,” “Tylenol prn fever and

bodyaches,” “Full PPE was worn,” “All questions asked and answered.” Id.

       Finally, the medical records were misleading. The Government introduced multiple emails

written by the Defendant where he implored his providers to document “SOMETHING” about

why the patient is there to be tested. See, e.g., Exhibit 29 (Gov’t Trail Ex. 605); Exhibit 31 (Gov’t

Trial Ex. 607); Exhibit 33 (Gov’t Trial Ex. 609). Deborah Needle testified that these emails were

“concerning” because “it implies that we need to find something to document even if it’s not

there.” Exhibit 5 (7/24/23 Tr.) at 143. This is likely why the template was drafted to state that a

patient was exposed to COVID-19 when, in fact, many patients were seen for administrative

reasons such as for work or travel.

       The call-back records are perhaps the best examples of the misleading records. Here is the

medical record related to a phone call that A.H. testified “couldn’t have been more than one

minute”:




Exhibit 17 (Gov’t Ex. 403) at 6; Exhibit 3 (7/19/23 Tr.) at 111. This misleading, vague medical

gibberish becomes even more absurd in light of the repeated usage of this language. Patient S.T.

received one phone call to report the results for her family, but the medical records claim that S.T.


                                                     8
and each of her triplets spoke “at length” with the provider and that “[i]n excess of 32 minutes”

was spent on various issues for each patient. See Exhibit 20 (Gov’t Trial Ex. 408) at 6; Exhibit 21

(Gov’t Trial Ex. 409) at 6; Exhibit 22 (Gov’t Trial Ex. 410) at 12; and Exhibit 23 (Gov’t Trial Ex.

413) at 31.

               4.     Hybrid expert and fact witnesses testified that Dr. Elfenbein’s
               practitioners were not providing a Level 4 service.

       Fact witnesses who possess training and skill beyond that of a lay person, but who are not

otherwise designated as experts, are often considered “hybrid” experts. See, e.g., Adell Plastics,

Inc. v. Mt. Hawley Ins. Co., 2019 WL 2359441, *1 (D. Md. June 4, 2019) (describing hybrid

expert/fact witnesses as giving testimony “arising out of personal observations made in the normal

course of duty.”) (internal quotation marks omitted). Several witnesses with such training and

skill testified at trial, including Cathy Raymond, Courtney Sinagra (as a representative of

CareFirst), Steven Carroll, and Suzanna Silva.

       Cathy Raymond was a Certified Professional Coder who worked for the Defendant from

2017 until she quit in protest in October 2020. See Exhibit 4 (7/20/23 Tr.) at 79, 85. She testified

that she told the Defendant that she was seeing unsupported level 4 and level 5 office visits. See

id. at 84. During cross-examination, the defense highlighted that Raymond did not specifically

address the Defendant’s use of Level 4 billing, but Raymond clarified that while she may not have

used the words “Level 4,” she raised issues with the “pattern” of billing, and that pattern included

Level 4 and Level 5. See Exhibit 5 (7/24/23 Tr.) at 55, 90.

       The Defendant reduces Raymond’s concerns to “documentation” concerns, suggesting that

her concerns were just a matter of paperwork and not a concern about medical decision making.

Raymond’s concerns, however, go to the heart of the Government’s fraud theory. Raymond saw

systemic billing of Level 4 and Level 5 office visits that were not supported by the medical records.


                                                     9
The obvious explanation for her observations was that the Defendant’s providers were each

churning through more than 100 patients per day.

       The Government also called Courtney Sinagra, as a representative of CareFirst Blue

Cross/Blue Shield to testify about two audits of First Call performed by CareFirst. CareFirst’s

second audit was performed by a Certified Professional Coder and a Registered Nurse. See Exhibit

27 (Gov’t Trial Ex. 502) at 2; Exhibit 53 (Def. Trial Ex. 255). Courtney Sinagra was also a

Certified Professional Coder and she testified on behalf of CareFirst that, as to the second audit in

particular, none of the 89 patient records reviewed met the Level 4 billing criteria. Exhibit 6

(7/25/23 Tr.) at 21, 56-57. The medical records reviewed by CareFirst during the second audit

were similar to the medical records for the charged encounters; they contained inaccuracies and

generic care plans that gave no meaningful insight into the care provided to the patient. See, e.g.,

Exhibit 13 (Excerpt from Gov’t Trial Ex. 402) at 5; Exhibit 14 (Excerpt from Gov’t Trial Ex. 402)

at 4; Exhibit 15 (Excerpt from Gov’t Trial Ex. 402) at 3; Exhibit 16 (Excerpt from Gov’t Trial

Exhibit 402) at 5. The jury was entitled to rely on Ms. Sinagra’s testimony and on the CareFirst

audit to conclude that the five charged encounters were false.

       Two providers called by the defense, Steven Carroll and Suzanna Silva, also had billing

training and admitted that using Level 4 for every patient visit was not appropriate. Carroll, for

example, admitted that Defendant’s “in and out of the tent in under 5 minutes” instruction did not

describe a level 4 encounter. Exhibit 9 (7/31/23 Tr.) at 40-41. The Government also cross-

examined Carroll with this own treatment records for a patient who came to First Call regularly to

be tested for work. He testified as follows:

               Q.      And why did the patient come to FirstCall?

               A.      Needs a test for work.

               Q.      How’d you code the office visit?

                                                     10
                 A.     99214.

                 Q.     And is the care plan identical to the last care plan we just
                 saw?

                 A.     Yes.

                 Q.     Do you think that’s a level 4 decision making, Mr. Carroll?

                 A.     No.

                 Q.     This visit should not have been a level 4.

                 A.     No.

Id. at 43.

         Suzanna Silva testified that she received training on medical billing at her previous

employer, and she testified that she—not the defendant—decided how to code her office visits.3

Exhibit 10 (8/1/23 Tr.) at 105-06. She testified that when she saw patients in-person at the FedEx

Field location, she coded the office visit as a level 3: “if the patient circumstance was extremely

straightforward, such as they simple needed a test for travel or work and were having absolutely

no symptoms, I didn’t need to take time consulting with them, helping them with any concerns,

then I might code those as a level 3.” Id. at 110. Ms. Silva added that she “may have billed more

3s at Earleigh Heights given that my exam was more limited.” Id. Defendant, in contrast,

instructed one of his providers that Level 3 was “never” appropriate. Exhibit 39 (Gov’t Trial Ex.

631).

         Fact witnesses also supplied evidence that the billing was false. Deborah Needle, another

provider at First Call, testified that she had some familiarity of medical billing, and that she did

not think it was appropriate to bill all asymptomatic patients as a level 4 and all symptomatic




3
    Silva also joined the practice 18 months after the pandemic began.
                                                     11
patients as a level 5. See Exhibit 5 (7/24/23 Tr.) at 139 (“I didn’t feel that an asymptomatic patient

warranted a level 4.”) Needle also provided key testimony about the Defendant’s billing scheme.

When Needle initially confronted the Defendant and expressed disagreement, he told her to “do

what [she] felt was appropriate.” Id. at 151. Yet, “that same day [Defendant] sends out an e-mail

again with the guidelines of level 4s and 5s.” Id.

         David Turner, the owner and President of BlueFish Medical, also provided evidence that

Dr. Elfenbein’s billings were false. Centennial Medical Group was the management company for

the Defendant’s medical practice and also for a much larger medical practice led by Dr. Rajeev

Dua. Dr. Dua’s practice also provided COVID-19 testing services in Maryland. BlueFish

provided services to both Dr. Dua’s practice and Defendant’s practice, and Turner testified that

Dr. Dua’s E/M coding practices “were more conservative.” Exhibit 3 (7/19/23 Tr.) at 181. The

jury could have relied on this testimony to determine that the five charged patient encounters were

false.

                5.     Evidence of the defendant’s intent is relevant to falsity.

         The jury could also have also determined that the claims for the five charged encounters

were false because the defendant intended to submit false claims. In other words, when evaluating

falsity, the jury was not limited to the four corners of the medical records. The jury could

reasonably infer that the claims were false because the evidence of the Defendant’s intent showed

that he intended to submit false claims. Evidence of the defendant’s intent is more-thoroughly

discussed in the response to the Motion for a New Trial, but the Government showed at trial,

among other things, that: (1) the defendant acted with a financial motive; (2) the defendant’s claim

to have used the Novitas and AMA scoring sheets was uncorroborated by any witness, email, or

document; (3) the Defendant disregarded billing recommendations from his business partner and

his Certified Professional Coder; and (4) when confronted by Cathy Raymond or Deborah Needle
                                                     12
he either told them to bill what they felt was appropriate only to follow up with an email directing

his level 4 billing or her ignored them. See Exhibit 28 (Gov’t Trial Ex. 601) (“there has to be a

way to bill higher level”); Exhibit 11 (8/2/23 Tr.) at 187 (“Q. And we don’t see any e-mails where

you use the phrase ‘new undiagnosed problem with uncertain prognosis’? We haven’t seen any

of those e-mails, have we? . . . A. I don’t think so.”); Exhibit 32 (Gov’t Trial Ex. 608) (“let’s try

it”); Exhibit 5 (7/24/23 Tr.) (Needle testifying that she “felt like [she] was being avoided.”);

Exhibit 4 (7/20/23 Tr.) at 84 (Raymond testifying “After the first time I raised a concern, he

acknowledged my concern and he had backed off . . . However, a couple weeks later, he was back

at it[.]”).

                6.     The patients who testified about the charged counts reported brief
                encounters that were consistent with the Defendant’s instructions and
                inconsistent with Level 4 visits.

         The grand jury charged the Defendant with five separate executions of his scheme, four of

which related to patients who testified at trial. Four of the patients testified at trial, and one of the

patients, S.T., testified about the fifth patient, W.R., who was her father. Each patient had different

circumstances that brought them to First Call, but they all recounted the same perfunctory

encounter that did not rise to a level 4 service.

         A.H. testified that the person who swabbed her nose only asked a few questions but did not

provide any substantive care. See Exhibit 3 (7/19/23 Tr.) at 106. S.T., who was vaccinated and

asymptomatic, testified that the examination and discussion for her and her three children lasted a

combined 10 minutes, even though Defendant’s company billed their insurance company for Level

4 visits for all of them. Exhibit 5 (7/24/23 Tr.) at 99-102. S.T. testified that W.R.’s visit, at which

S.T. was present, lasted less than five minutes and the provider’s exam of W.R. consisted of S.T.

leaning back in the driver’s seat of her car so the provider on the screen could see W.R. in the

passenger seat across the car. Id. at 108-09. D.M., who was vaccinated and asymptomatic,
                                                       13
testified that she spoke to a provider on a screen for about five minutes. See Exhibit 4 (7/20/23

Tr.) at 68-70. J.J., who was experiencing symptoms and had a history of asthma, testified that she

spoke to a provider for 2 minutes. See Exhibit 6 (7/25/23 Tr.) at 6, 12

       Their collective experience mirrored the Defendant’s instructions to his providers to see

patients in under five minutes, that these were “simple and straightforward” encounters, and that

providers were not to solve complex medical issues. See Exhibit 45 (Gov’t Trial Ex. 646); Exhibit

46 (Gov’t Trial Ex. 647). The defendant’s statement that “[p]atients just want to get tested and go

home” was largely correct. See Exhibit 45 (Gov’t Trial Ex. 646). S.T. had three young children

and wanted the convenience of a drive-thru. See Exhibit 5 (7/24/23 Tr.) at 98. J.J. testified that

she did not go to First Call to see a doctor, she went there to get a COVID-19 test. See Exhibit 6

(7/25/23 Tr.) at 20. (“Q. Ms. Jones, were you going to Earleigh Heights to see a doctor? A. No.

Q. What were you going to Earleigh Heights for? A. To get tested for COVID.”)

       The Defendant commonly refers to the medical records as evidence that medical decisions

must have been made by the provider. See, e.g., ECF No. 78 at 22. But the template medical

records, which were vague, misleading, and inaccurate, and which were “100% done for you,” do

not prove that medical decision making was actually rendered by the provider. See Exhibit 48

(Gov’t Trial Ex. 658) (“the template I built for this is 100% done for you. How much simpler can

that get?”) Even Mr. Miscoe admitted that medical decision making is the “cognitive labor a

provider puts into the encounter.” No such cognitive labor was expended by the providers here.

       The Defendant also points to each patient’s “limited recollection” of the encounter. See,

e.g., ECF No. 78 at 21. Their recollections were limited because the encounters were so brief.

Presumably, if the patient had met with an oncologist about a lump in their breast, then they would

have a better memory of it.



                                                    14
       The Defendant also argues that he is entitled to an acquittal as to patient A.H. because A.H.

testified that she never saw a provider, and the Defendant never instructed his providers to test

patients without seeing them. The Defendant implemented a scheme to bill for level 4 office visits

that he knew were not occurring, and that was just has much true for A.H. as it was for any of the

other charged patient encounters. Further, that his providers may have seen a patient so quickly

that the patient did not perceive it as a provider encounter is a foreseeable consequence of the

Defendant’s instructions. See, e.g., Exhibit 35 (Gov’t Trial Ex. 617) (“[E]ntire patient encounter

and chart took 20 seconds”).

II.    THE COURT SHOULD DENY DEFENDANT’S MOTION FOR A NEW
       TRIAL

       The Court should reject the Defendant’s Motion for a New Trial because the weight of the

evidence supports the jury’s verdict, the evidentiary rulings by the Court were consistent with the

law and the facts of the case, and conducting voir dire without public spectators does not violate

the Defendant’s Sixth Amendment right to a public trial. Federal Rule of Criminal Procedure 33

permits a defendant to move for a new trial “if the interest of justice so requires.” Fed. R. Crim.

P. 33(a). For these reasons, the Defendant’s motion should be denied.

       A.      The Weight of the Evidence Supports the Jury’s Verdict

       As explained above, the evidence presented at trial was more than sufficient for a

reasonable juror to conclude the defendant committed each count of conviction. The Fourth

Circuit has explained that to determine whether a new trial is warranted based on the weight of the

evidence, “the court examines the evidence as a whole to determine whether it ‘preponderates

sufficiently heavily against the verdict that a serious miscarriage of justice may have occurred.’”

United States v. Rafiekian, 68 F.4th 177, 189 (4th Cir. 2023). “District courts should grant new

trials based on the weight of the evidence only in ‘rare’ instances.” Rafiekian, 68 F.4th at 186.


                                                    15
“Merely believing that the case could have come out the other way is not enough to warrant a new

trial.” Rafiekian, 68 F.4th at 186. “A district court should grant a new trial based on the weight

of the evidence ‘only when the evidence weighs heavily against the verdict.” United States v.

Saint Louis, 889 F.3d 145, 157 (4th Cir. 2018); United States v. Wilson, 118 F.3d 228, 237 (4th

Cir. 1997) (“[D]istrict court should exercise its discretion to grant a new trial ‘sparingly’”).

Because “’determining witness credibility and weighing conflicting evidence are the responsibility

of the factfinder,’ [] ‘the standard for jettisoning a jury verdict in favor of a new trial’ is

‘demanding.’” Rafiekian, 68 F.4th at 186-87 (quoting United States v. Arrington, 757 F.2d 1484,

1485 (4th Cir. 1985) and United States v. Millender, 970 F.3d 523, 532 (4th Cir. 2020)) (internal

citations and some quotation marks omitted).

       No new trial is warranted here. The evidence presented at trial, taken as a whole,

establishes that Defendant engaged in a scheme to defraud Medicare and other insurers by billing

those insurers for high-level office visits that did not occur as represented for every patient who

came to the Defendant’s clinic for a COVID-19 test. The Defendant decided on the level of office

visit he was going to bill before the patient ever presented for service, without regard to the

patient’s health or reason for testing. This was a one-size-fits-all billing scheme.

       The evidence demonstrates that the claims submitted by Defendant’s company for level 4

office visits for COVID-19 testing patients was false and fraudulent, and that Defendant knew and

intended that these claims were false.

               1.     The Testimony Of The Government’s Witnesses Was Credible, And
               Established The Defendant’s Guilt Beyond A Reasonable Doubt.

       As discussed above in Section I, the Government introduced ample evidence from which

the jury found the Defendant guilty beyond a reasonable doubt. This included testimony from

Defendant’s former employees, testimony from a representative of the third-party billing company


                                                     16
used by Defendant to submit claims, testimony from representatives of Medicare and CareFirst,

and testimony from patients who went to Defendant’s COVID-19 drive-through testing site for

COVID-19 tests. In addition, the government presented documentary evidence, including claims

data, medical records, and e-mails showing the scheme. This evidence demonstrated that the

claims submitted at Defendant’s direction were false, that Defendant knew they were false, and

that Defendant intended to submit false claims to obtain higher reimbursement.

       The evidence presented by the Government was credible and consistent, and strongly

supported the verdict rendered by the jury. In contrast, the Defendant’s testimony was not credible,

and the Defendant’s expert, Michael Miscoe, rendered an opinion that was based on inaccurate

medical records and defies logic. The evidence presented does not “preponderate sufficiently

heavily against the verdict,” and the Defendant’s motion for a new trial should be denied.

                       a)     Defendant Implemented a Scheme To Defraud

       The evidence presented at trial established that Defendant implemented a plan to bill for

Level 4 visits for every COVID-19 test with an additional level 4 visit. Defendant did so by

instructing his providers repeatedly to code all COVID-19 testing patients with additional Level 4

office visits, and creating templated medical records that included the Level 4 codes. In email

after email, starting as early as April 25, 2020, the Defendant instructed his employees that every

asymptomatic COVID-19 testing patient should be billed at level 4. See Exhibit 29 (Gov’t Trial

Ex. 605), Exhibit 30 (Gov’t Trial Ex. 606), Exhibit 31 (Gov’t Trial Ex. 607), Exhibit 34 (Gov’t

Trial Ex. 614), Exhibit 36 (Gov’t Trial Ex. 626), Exhibit 37 (Gov’t Trial Ex. 628), Exhibit 38

(Gov’t Trial Ex. 629), Exhibit 39 (Gov’t Trial Ex. 631), Exhibit 40 (Gov’t Trial Ex. 635), Exhibit

47 (Gov’t Trial Ex. 654); see also Exhibit 5 (7/24/23 Tr.) at 138-39 (Provider Needle testifying

that Defendant instructed her to bill all COVID-19 patients for Level 4 E/M visit). The evidence

also confirmed that Defendant prepared templated medical records and instructed providers to use
                                                    17
the templates. For example, in an email to one of his providers, Defendant stated that “the template

[he] built for this is 100% done for you. How much simpler can that get?” Exhibit 48 (Gov’t Trial

Ex. 658).

        And the employees followed Defendant’s instructions. The Defendant was the medical

director of the clinic. See, e.g., Exhibit 48 (Gov’t Trial Ex. 658) (Defendant’s email stating “I am

medical director and will change the process when I feel it best—that is my prerogative and

responsibility.”). The testimony from the providers confirms that they relied on Defendant’s

instructions, and coded COVID-19 testing patients for an additional level 4 office visit. See, e.g.,

Exhibit 9 (7/31/23 Tr.) at 27 (Provider Carroll testifying that the Defendant instructed him by email

to bill COVID-19 test patients at level 4, and he followed that instruction); Exhibit 7 (7/26/23 Tr.)

at 36 (Provider Wrona testifying that she relied on the emails from Defendant and the templated

CPT coding). The claims data corroborates their testimony. See, e.g., Exhibit 12 (Gov’t Trial Ex.

137) (summary chart showing nearly every COVID-19 test was billed with Level 4 office visit).

Nearly every patient who received a COVID-19 test at Defendant’s clinic was billed on that same

day for a level 4 office visit. Id.

        The evidence also showed that Defendant decided on his scheme to bill every

asymptomatic COVID-19 testing patient for an additional Level 4 office visit early in the pandemic

in order to increase the amount of money he would get from insurers. For example, as early as

March 18, 2020, Defendant’s former biller, Cathy Raymond, suggested using level 1 evaluation

and management coding for COVID-19 testing patients. Exhibit 28 (Gov’t Trial Ex. 601)

(suggesting 99201 code). Defendant responded that “[t]here has to be a way to bill higher level

on these” to increase reimbursement. Id. The Government also introduced several emails in which

Defendant confirmed that reimbursement rates were the motive for billing Level 4 visits. For



                                                     18
example, Defendant repeatedly confirmed that evaluation and management coding was the “bread

and butter” of how they get paid, See, e.g., Exhibit 37 (Gov’t Trial Ex. 628), Exhibit 40 (Gov’t

Trial Ex. 635), and “a 99202 pays way less than a 99204.” Exhibit 40 (Gov’t Trial Ex. 635).

Defendant was telling his providers to raise the level of coding because “[t]he difference in coding

of one level can be over a hundred dollars, so it is not inconsequential.” Exhibit 39 (Gov’t Trial

Ex. 631).

       By instructing his providers to code every COVID-19 testing patient for a level 4 office

visit in addition to the COVID-19 test, Defendant was telling Medicare and other insurers that

every patient was receiving an “office or other outpatient visit for the evaluation and management

of a [new or existing] patient, which requires a medically appropriate history and/or examination

and moderate level of medical decision making.” See ECF 78, Ex. 4 at 19 (2021 CPT Code

Manual) (also introduced as Gov’t Trial Ex. 903).4 As discussed above in Section I, the evidence

presented at trial established that the services being provided at Defendant’s direction were not

moderate complexity office visits.     The Government presented evidence of the E/M code

definition, and what services were being represented by the Level 4 E/M codes. The Government

presented testimony from patients and providers who testified the services provided were not Level

4 E/M visits. The Government presented testimony from CareFirst regarding its audits of

Defendant’s billing, in which multiple certified professional coders concluded the services




4
  In 2020, the guidelines for CPT codes 99204 and 99214 similarly involved medical decision
making of moderate complexity. See ECF 78, Ex. 3 at 13 (2020 CPT Code Manual) (also
introduced as Gov’t Trial Exhibit 902). In the 2020 guidelines, the CPT manual provides “typical”
times—for 99204, “typically, 45 minutes are spent face-to-face with the patient and/or family” and
for 99215, “typically, 25 minutes are spent face-to-face with the patient and/or family.” Id. at 13-
14. The CPT manual states that “[t]he inclusion of time as an explicit factor beginning in CPT
1992 is done to assist in selecting the most appropriate level of E/M services.” Id. at 8.
                                                    19
provided by Defendant’s company were not Level 4 E/M visits. And the Government presented

emails from the Defendant instructing his providers to provide services inconsistent with Level 4

E/M visits. All of this evidence strongly supports the jury’s determination that the claims

submitted by Defendant’s company were false.

                       b)     Defendant’s Acted Knowingly and Willfully

       The evidence showed that Defendant acted knowingly and willfully in pursuing this

scheme to defraud. As discussed above, the evidence presented at trial established that Defendant

was the person who decided what codes to bill, and was telling his providers to bill for moderate

complexity, Level 4 E/M visits. See Exhibit 29 (Gov’t Trial Ex. 605), Exhibit 30 (Gov’t Trial Ex.

606), Exhibit 31 (Gov’t Trial Ex. 607), Exhibit 34 (Gov’t Trial Ex. 614), Exhibit 36 (Gov’t Trial

Ex. 626), Exhibit 37 (Gov’t Trial Ex. 628), Exhibit 38 (Gov’t Trial Ex. 629), Exhibit 39 (Gov’t

Trial Ex. 631), Exhibit 40 (Gov’t Trial Ex. 635), Exhibit 47 (Gov’t Trial Ex. 654); see also Exhibit

5 (7/24/23 Tr.) at 138-39 (Provider Needle testifying that Defendant instructed her to bill all

COVID-19 patients for Level 4 E/M visit). At the same time, Defendant was telling his providers

that they were “not there to solve complex medical issues, etc… Just to test them.” Exhibit 46

(Gov’t Trial Ex. 647). The patient “is there for one reason only-to be tested. Goal is to get them

seen and out quickly (we want them in and out of the tent in under 5 minutes total).” Id. “Speed

here is key.” Exhibit 45 (Gov’t Trial Ex. 646). “The patients are all here for one reason…. simple

and straightforward-to get tested.” Id.

       Multiple employees, including Defendant’s at-the-time certified professional coder, raised

concerns about the level of coding Defendant was instructing providers to use for COVID-19

testing patients. For example, Cathy Raymond was Defendant’s biller, and a certified professional

coder that had worked for Defendant for several years prior to the COVID-19 pandemic. See

Exhibit 4 (7/20/23 Tr.) at 79. Raymond testified that during the pandemic, for the first time,
                                                    20
Defendant was instructing patients on what codes to bill for patients. Id. at 83-84. Raymond

testified that she raised concerns about the coding instructions to Defendant multiple times,

verbally and in writing. Id. at 84. The concern she raised was with the pattern of over-coding she

was seeing—that every COVID-19 testing patient was being billed for level 4 and level 5 office

visits. Exhibit 5 (7/24/23 Tr.) at 20-23, 55 (“The pattern included that level 4, though.”); Id. at 90

(“[T]here was a consistent pattern of level 4s and level 5s being billed but without the appropriate

documentation level to support it.”). Raymond testified that Defendant ignored her concerns, and

continued to instruct providers to bill COVID-19 testing patients for level 4 and level 5 office

visits in addition to COVID-19 tests. See Exhibit 4 (7/20/23 Tr.) 84-86; Exhibit 5 (7/24/23 Tr.) at

11-12. Ultimately, Raymond testified, she reported her concerns to the government and resigned

from her position because “the situation that was going on with the over coding was not a situation

that [she] could stay in.” Exhibit 5 (7/24/23 Tr.) at 11, 16-17.

       Provider Deborah Needle, a nurse practitioner who worked for Defendant’s clinic, testified

that Defendant gave instructions on how to code COVID-19 testing patients, and that his

instruction was to code all COVID-19 testing patients at level 4 at the very least. See id. at 138-

139. Needle did not agree with those instructions. Id. at 139. Needle testified that she raised her

concerns about the coding level with Defendant, and he responded by reiterating his instruction

that all COVID-19 testing patients should be billed for an additional level 4 office visit at a

minimum. Id. at 139-140. Needle testified that Defendant was “never available” to answer her

concerns, and she “felt like [she] was being avoided.” Id. at 146.

       Defendant’s company was audited twice during the scheme. Exhibit 26 (Gov’t Trial Ex.

501), Exhibit 53 (Def. Trial Ex. 255); Exhibit 6 (7/25/23 Tr.) at 28. In both audits, CareFirst

determined that the Defendant’s company was billing for services not provided as represented.



                                                     21
Exhibit 26 (Gov’t Trial Ex. 501), Exhibit 53 (Def. Trial Ex. 255); Exhibit 6 (7/25/23 Tr.) at 33-34,

53-57. These audit results were communicated to the Defendant’s company. See Exhibit 26

(Gov’t Trial Ex. 501), Exhibit 53 (Def. Trial Ex. 255); Exhibit 6 (7/25/23 Tr.) at 33 (first audit

report sent to Defendant’s company address).

       The evidence presented at trial strongly supports the jury’s determination that the

Defendant acted knowingly and willfully.

               2.      The Defendant’s Testimony Was Not Credible.

       Defendant’s contention that every patient encounter in which a patient received a COVID-

19 test at his clinic qualified to be coded at level 4 is not supported by the evidence and is not

credible. Defendant and his expert, Michael Miscoe, testified that every patient encounter

involving a rapid and PCR COVID-19 test automatically qualifies for level 4 coding. Exhibit 10

(8/1/23 Tr.) at 63 (Michael Miscoe testimony: “Q. Your opinion is that every patient who got a

COVID test and got two tests with one reviewed, regardless of status, regardless of diagnosis,

regardless of risk, necessarily involved the second-highest level of medical decision making, right?

A. That’s the way it scores out.”); Exhibit 11 (8/2/23 Tr.) at 182 (Defendant testimony: “Q. Is there

moderate decision making with respect to every patient who walks in the door during the

pandemic? A. According to the chart, yes. Q. So everywhere in this country during the pandemic,

as soon as [the] patient walks in the door, regardless of what they’re there for, because they existed

in society, they at least get that new problem with uncertain prognosis? A. If they’re getting two

tests for COVID and it’s in 2021, yes.”).

       There is not a shred of evidence that corroborates that opinion. In fact, the evidence showed

precisely the opposite. Guidance issued during the pandemic (and on which Defendant and his




                                                     22
expert purported to rely in part)5 made clear that COVID-19 testing in and of itself did not

automatically qualify every encounter as level 4. See, e.g., Exhibit 51 (Def. Trial Ex. 214) (CMS

Transmittal: “Physician’s and NPPs must use CPT code 99211 to bill for a COVID-19 symptom

and exposure assessment and specimen collection provided by clinical staff . . . incident to the

physician’s or NPP’s services.”), Exhibit 52 (Def. Trial Ex. 219) (CMS Interim Final Rule: “For

the duration of the COVID-19 PHE, we are therefore finalizing on an interim basis that when the

services described by CPT code 99211 for a level 1 E/M visit are furnished for the purpose of a

COVID-19 assessment and specimen collection, the code can be billed for both new and

established patients. We believe this policy will support expanded access to COVID-19 testing,

and provide appropriate payment for COVID-19 test-related services furnished by physician and

other practitioners.”) (emphasis added). The contention that every individual who received a

COVID-19 test always qualified for a Level 4 evaluation and management visit does not pass the

smell test. For example, as Defendant’s expert was forced to concede, such an interpretation would

necessarily mean that it would not matter if the provider saw the patient for 20 seconds. See

Exhibit 10 (8/1/23 Tr.) at 33-35 (Defendant’s expert suggesting a 20 second encounter could be

Level 4), 50 (“Q. [] So your opinion that your expressing to the jury today is, if a medical assistant

at a drive-through COVID testing site does a swab, and does a symptom and exposure assessment,

if the provider is on a screen for 20 seconds or 40 seconds just to look at that patient, it all of a




5
  Defendant could not decide whether he did or did not search for relevant CPT code guidance
when he was purportedly determining the coding level. Compare Exhibit 11 (8/2/23 Tr.) at 132
(Defendant Direct Testimony that “there was a new table that was being put out by the American
Medical Association, along with the CPT guidelines” and Defendant “conduct[ed] an analysis”
using that chart) and 136 (Defendant Direct Testimony that he “started to Google other sources”)
with Exhibit 11 (8/2/23 Tr.) at 161-162 (Defendant Cross Testimony that “I looked for a lot of
things. I don’t remember specific looking for the AMA guidelines on coding.”) and 168
(Defendant Cross Testimony that he doesn’t specifically recall guidance from the AMA).
                                                     23
sudden goes from a level 1 visit as instructed by CMS to a moderate complexity office visit, the

second-highest level of office visit[?] A. As soon as the provider gets involved. I mean, that’s

just the way the medical decision making scores. I didn’t write the rules.”).

       Moreover, Defendant’s testimony was directly contradicted by the testimony of other fact

witnesses and was inconsistent with his own emails. For example, Defendant testified that Cathy

Raymond never expressed any concerns with Defendant about coding levels. Exhibit 11 (8/2/23

Tr.) at 49 (“Q. Did she ever express any concerns to you about coding levels? A. No, she did

not.”). In contrast, Ms. Raymond testified that she repeatedly raised concerns about the pattern of

coding at Defendant’s company. Exhibit 4 (7/20/23 Tr.) at 84-86. That “pattern” of coding

included billing COVID-19 testing patients for Level 4 E/M visits. Exhibit 5 (7/24/23 Tr.) at 20-

23, 55 (“The pattern included that level 4, though.”); Id. at 90. Dr. Elfenbein also testified that

Deborah Needle never expressed any concerns with Defendant about his billing instructions.

Exhibit 11 (8/2/23 Tr.) at 161 (“Q. And Deborah Needle expressed the same concern about your

billing instructions, correct? A. She did not. Q. So she did not express concerns with your billing

instructions? A. Not to me, she did not.”). Again, in contrast, Ms. Needle testified that she did

raise her concerns with the Defendant. Exhibit 5 (7/24/23 Tr.) at 139-140 (“Q. Did you ever tell

Dr. Elfenbein that you disagreed with his instructions? A. I told him that I had questions and

concerns, yes. Q. And what exactly did you tell him? A. I told him that I felt like the codes didn’t

– I felt that the level was higher than it should be, and I was looking for some clarification because

I was concerned.”).

       Defendant also testified that he used the AMA’s medical decision making chart and the

Novitas calculator to conclude that every COVID-19 testing patient should be coded with a Level

4 E/M visit. Exhibit 11 (8/2/23 Tr.) at 134-137. But no email or other evidence corroborates



                                                     24
Defendant’s testimony that he looked at this chart at the time. And evidence presented conflicts

with Defendant’s testimony that he used these charts. On cross-examination, Defendant was

confronted with his own email indicating that sometimes Defendant’s company did not perform

two tests—and in those circumstances even under Defendant’s purported calculation he could not

have billed a Level 4 visit. Id. at 171-72; Exhibit 49 (Gov’t Trial Ex. 938). But the claims data

shows that the Defendant did not change the coding in those circumstances. See Exhibit 12 (Gov’t

Trial Ex. 137); Exhibit 8 (7/27/23 Tr.) at 16-19. He did not ever change the coding. That evidence

calls into serious question the veracity of Defendant’s testimony.

       In United States v. Janati, the Fourth Circuit affirmed conviction for health care fraud in

similar circumstances. See 237 F. App’x 843, 847 (4th Cir. 2007). In that case, defendants were

convicted of health care fraud for, among other things, “upcod[ing] office visits, meaning that

when they billed insurers, they represented that an office visit was more involved or complex than

it actually was, justifying a higher billing rate.” Id. at 845. The evidence in that case showed that

the defendants billed virtually all office visits using the highest code, CPT 99215, without regard

to the seriousness of the patient’s problem or the complexity of the visit.” Id. There, the defendant

claimed the coding was too vague to sustain the conviction. Id. The Court rejected the argument

and affirmed conviction, explaining that the evidence “overwhelmingly demonstrates” that the

defendants knowingly used improper coding “if for no other reason that the fact that they altered

their forms to eliminate even the option of billing at a level lower than Code 99214.” Id. at 847.

In addition, the Court noted that the defendants previously billed differently, that they billed every

visit at the highest level, that the government’s expert testified that none of the charges came “even

close” to warranting the billing level, and that the defendants continued to bill falsely “even after




                                                     25
being specifically warned by Medicare officials and other insurers that their billing was improper.”

Id.

       Here, the evidence is even more comprehensive. Although the Government did not present

a hired expert to testify about the CPT codes used, two certified professional coders testified

regarding opinions rendered at the time and communicated to the Defendant that these COVID-19

testing visits did not qualify as level 4 office visits. Providers testified that the services they were

providing were not level 4 office visits. And Defendant caused his company to bill nearly every

patient for level 4 office visits, “without regard to the seriousness of the patient’s problem or the

complexity of the visit.” See Janati, 237 F. App’x at 845. The facts in Janati also did not occur

during a pandemic. In other words, the patients seen by Janati were likely sick. Here, many of

Defendant’s patients were healthy, asymptomatic, and later in 2021, vaccinated.

       The weight of the evidence establishes that the codes submitted by Defendant’s company

at Defendant’s direction were false, that Defendant knew they were false, and that he intended to

defraud Medicare and other insurers. The Defendant’s motion for a new trial should be denied.

       B.      The Court’s Evidentiary Rulings Were Correct

       The Court’s evidentiary rulings on Defendant’s three proposed exhibits and on the

testimony of A.H. were consistent with the evidentiary rules on hearsay, and Defendant’s

arguments should be rejected. Federal Rule of Evidence 801 defines hearsay as a statement that

“(1) the declarant does not make while testifying at the current trial or hearing; and (2) a party

offers in evidence to prove the truth of the matter asserted in the statement.” Fed. R. Evid. 801(c).

Hearsay statements made by a defendant, if offered by that defendant, are inadmissible unless they

fit within a specific hearsay exception. See United States v. Gearheart, --- F. Supp. 3d ---, 2023

WL 4106252 (W.D. Va. June 21, 2023); cf. United States v. Conto, 2022 WL 228845, *1 (4th Cir.

2022) (Rule 106 does not “require the admission of self-serving, exculpatory statements made by
                                                      26
a party which are being sought for admission by that same party.”) (internal quotation marks

omitted). The Rules of Evidence provide an exception to hearsay for statements made by the

Defendant or his agent, if offered against the Defendant. Fed. R. Evid. 801(d)(2).

       In addition, evidentiary rulings are also subject to a harmless error analysis. United States

v. Gordon, 754 F. App’x 171, 177 (4th Cir. 2018) (citing United States v. Medford, 661 F.3d 746,

751 (4th Cir. 2011)). “An ‘error, defect, irregularity, or variance that does not affect substantial

rights must be disregarded.’” Id. (quoting Fed. R. Crim. P. 52(a)). “An error is harmless if it did

not affect the verdict.” Id. Thus, “if the evidence is not merely sufficient, but so powerful,

overwhelming, or cumulative that the error simply could not reasonably be said to have

substantially swayed the jury’s judgment, then the error is not harmful.” Id. (quoting Cooper v.

Taylor, 103 F.3d 366, 370 (4th Cir. 1996)). When applying a harmless error analysis, the Fourth

Circuit has held that “‘[e]vidence erroneously admitted will be deemed harmless if a reviewing

court is able to ‘say, with fair assurance, after pondering all that happened without stripping the

erroneous action from the whole, that the judgment was not substantially swayed by the error.’’”

United States v. Hanna, 353 F. App’x 806, 809 (4th Cir. 2009) (citing United States v. Abu Ali,

528 F.3d 210, 231 (4th Cir. 2008)).

               1.    The Defendant’s Three Proposed Email Exhibits Were Properly
               Excluded.

       Each of the three proposed exhibits Defendant claims should have been admitted are

inadmissible hearsay and were properly excluded.

       Defendant argues that these emails fall within the hearsay exception for statements

regarding a declarant’s state of mind. ECF 78 at 32-33. Federal Rule of Evidence 803(3) provides

an exception to the hearsay rule for “[a] statement of the declarant’s then-existing state of mind

(such as motive, intent, or plan) or emotional, sensory, or physical condition (such as mental


                                                    27
feeling, pain, or bodily health), but not including a statement of memory or belief to prove the fact

remembered or believed unless it relates to the validity or terms of the declarant’s will.” Fed. R.

Evid. 803(3). “Rule 803(3) explicitly excludes hearsay statements about memories offered ‘to

prove the fact remembered.’” United States v. Liu, 654 F. App’x 149, 155 (4th Cir. 2016)

(rejecting argument that statements fit within 803(3) because they would have described state of

mind “hours or days earlier, rather than a ‘then-existing’ state of mind”). “Where state of mind

itself is in issue . . . the court must determine if the declarant’s state of mind at the time of the

declaration is relevant to the declarant’s state of mind at the time at issue.” United States v.

Srivastava, 411 F. App’x 671, 684 (4th Cir. 2011). Of course, even if evidence falls within a

hearsay exception, it must be relevant to be admissible. Fed. R. Evid. 803.

       Defendant’s contention that these three emails were being offered to show Defendant’s

state of mind was properly rejected. First, Defendant initially sought to introduce these emails as

business records. Second, the emails do not speak to Defendant’s state of mind with respect to

any relevant issue. Third, Defendant cannot introduce his own, self-serving hearsay statements.

                       a)      DX77

       Defendant’s proposed exhibit DX77 is an email dated December 18, 2021 (approximately

21 months after the pandemic began, and long after Defendant hatched the scheme) that is a post-

mortem look back on the pandemic. ECF 78, Ex. 9. The Defendant’s contention that the email

reflects Defendant’s motive for billing COVID-19 testing patients for level 4 office visits is wrong.

Nothing in the email addresses billing or coding. Instead, it is a motivational speech to his

employees. Such general character evidence is not admissible under Rule 404(a)(1). Even if the

email could be read to suggest that Defendant’s decision to offer COVID-19 tests to patients at his

mass testing sites was motivated by a desire to help people, that says nothing about the Defendant’s



                                                     28
motive for billing every one of those patients for an additional, Level 4 office visit that was not

performed as represented.

       Moreover, the vast majority of the email has nothing to do with Defendant’s state of mind.

The very first paragraph of the email highlights that: “I know this week and last has been CRAZY.

Volumes are unexpected and obviously unpredictable. I want to first off thank you for all your

hard work under extraordinary and incredibly difficult circumstances. We on the management

side have done and continue to do whatever we can to alleviate provider burden and make it as

easy as possible for everyone.” See ECF 78, Ex. 9. The second paragraph that Defendant

highlights in his motion similarly includes statements of purported fact unrelated to Defendant’s

state of mind: “We opened the doors to Gambrills in 2016. We saw more patients at all our

combined sites this past week alone then we did in the entirety of 2018. Yesterday, not counting

E-visits we saw almost 1,000 people (including E-visits we were well over 1400).” Id. Other

examples abound: “Some of you are new grads and you are being inundated by a tidal wave of

people-many of them sick and many angry and frustrated.” Id. These do not reflect Defendant’s

state of mind.

       Finally, as the Defendant noted in his motion, the Court provided an alternative to DX77—

the Defendant could be asked about his motivations for billing level 4 office visits on the stand.

Defendant’s contention that this email provides “crucial corroboration of [Defendant’s] testimony

about his state of mind at the time” cannot be squared with the fact that Defendant decided to bill

every COVID-19 testing patient for a level 4 office visit in early 2020, and this email is dated

December 2021. The Court’s ruling excluding this exhibit was correct, and Defendant’s motion

should be denied.




                                                    29
                       b)      DX60

       Defendant’s proposed exhibit 60 was properly excluded as irrelevant and inadmissible

hearsay. ECF 78, Ex. 7. It describes a one-off circumstance in February 2021, almost a year after

Defendant determined that every COVID-19 testing patient was to be billed for a level 4 office

visit, in which a patient returned for a re-swab as a result of some undisclosed issue with the PCR

swab.6 That Defendant expressed concern about billing for a second Level 4 E/M visit for the

same patient is not relevant to whether Defendant had intent to defraud with respect to billing for

level 4 office visits in the first instance. There was no allegation that the scheme involved charging

patients for a second Level 4 E/M visit when there was an issue with a previous swab.

       The second portion of the email addresses another one-off situation in which a patient left

the line and did not receive any test or services at all. This is not relevant to the scheme or

Defendant’s state of mind. The Government did not contend that Defendant was billing for

patients who never came to get tested, or that patients who were billed did not receive tests and

briefly see a provider. Instead, the Defendant was charged with billing for services that were not

provided as represented—that is, patients who came for COVID-19 tests were seen briefly by

providers, in a perfunctory manner, and billed for a level 4 office visit. The circumstance described

in the Defendant’s proposed exhibit 60 is irrelevant to the charges in this case.

       Moreover, it contains hearsay statements, both by Defendant and others, that are not subject

to an exception. For example, in the top email in the chain, Defendant says “as of now there is an

EM code of 99204.” ECF 78, Ex. 7. That is an out of court statement that is offered for the truth




6
  Claims data reflects that this patient had an encounter on January 25, 2021, at which she was
charged for a COVID test and a level 4 office visit. This email relates to a return visit this patient
made on January 28, 2021, to get re-swabbed. Thus, the e-mail is not relevant to the decision to
bill every patient who came for a COVID-19 test for an additional level 4 office visit.
                                                     30
about what was included in the billing. Lower in the chain, Defendant again is describing

information purportedly contained in a chart.

       The Court correctly excluded this proposed exhibit.

                      c)      DX66

       Defendant’s proposed exhibit 66 is dated March 13, 2021, addressing circumstances

unrelated to billing COVID-19 testing patients for level 4 office visits. ECF 78, Ex. 8. Instead,

the email addresses whether a provider was allowed to bill for infusion medication and critical

care time when providing infusions. This evidence is irrelevant to the charged criminal scheme.

The defendant offered the email to bolster his character, suggesting that he did not commit fraud

with respect to infusion billing. But that is not an exception to hearsay—nor is it appropriate use

of character evidence. The Defendant is permitted to testify that when he saw issues with coding,

he raised concerns about fraudulent billing, but he may not introduce self-serving hearsay not

subject to any exception.

       Moreover, the email contains self-serving hearsay offered by the defendant that is not

subject to any exception. For example, the email states: “I have spent a lot of time speaking to

billers, coders, Connor, Erin, the state and the feds.” ECF 78, Ex. 8. The Court properly excluded

this document.

                      d)    If the Court improperly excluded the evidence, then the error
                      was harmless.

       Even assuming, arguendo, that the Court improperly excluded Defendants proposed

exhibits DX77, DX60, and DX66, the error was harmless. As discussed above, the evidence

presented at trial of Defendant’s intent was substantial. The exclusion of three emails, two of

which occurred months after the coding decisions were made and the scheme was put into motion

by Defendant, and none of which address the coding decisions at issue in this case, “did not affect


                                                    31
the verdict.” See Gordon, 754 F. App’x at 177. Moreover, Defendant did introduce at trial emails

that covered the same ground. For example, admitted exhibit DX51 covers much of the same

ground as Defendant’s proposed exhibit DX66, but in the context of the COVID-19 testing at issue

in the case rather than with respect to infusions. Compare Exhibit 50 (Def. Trial Ex. 51) (“the MA

can only pull template over AFTER you have made contact with the patient. . . Doing so

beforehand generates too much a possibility of accidental fraudulent billing . . .”) with ECF 78,

Ex. 8 (“I know you are trying to help . . . . but lots of unintended consequences . . . By adding in

the medication (the BAM), that is committing fraud[,] for example.”).             In addition, like

Defendant’s proposed exhibit DX60, DX51 addresses not billing for encounters that did not occur.

Compare Exhibit 50 (Def. Trial Ex. 51) (“Doing so beforehand generates too much a possibility

of accidental fraudulent billing and too much work on the back end to delete all the encounters

that are filled out (and indistinguishable form ones that were actually seen/connected) but not real

encounters.”) with ECF 78, Ex. 7 (“Ok for Sweeney…Andre, delete that encounter please. Please

keep a log of who you see to avoid things like this. Had you accidentally billed that chart it would

be fraudulent billing.”).

       With respect to Defendant’s proposed exhibit DX77, which Defendant asserted was

intended to show that Defendant was “motivated to help patients, not to make money[,]” ECF 78

at 34, other admitted emails contain the same sentiment. See, e.g., Exhibit 31 (Gov’t Trial Ex.

607) (“Hope this finds everyone well. First off, GREAT work everyone. These are tough times

and you guys are rocking it. I am in awe of you guys and the work everyone is doing-truly! We

are the only game in town . . . truly TAKING CARE of people[.]”); Exhibit 41 (Gov’t Trial Ex.

638) (“Our volumes continue to explode. Jimmy and Crystal yesterday s[aw] over 350 people. It

was amazing.”); id. (“Thank you all for your continued dedication and hard work. As always,



                                                    32
ANY questions, let me know. Stay safe and thank you truly for all the hard work and dedication

you bring every day!”).

       The exclusion of Defendant’s proposed exhibits DX77, DX60, and DX66 “could not

reasonably be said to have substantially swayed the jury’s judgment,” and therefore “is not

harmful.’” See Gordon, 754 F. App’x at 177 (quoting Cooper, 103 F.3d at 370). In light of the

extensive evidence of intent, and the fact that other emails were admitted that included similar

language in relevant context, the Court can conclude “with fair assurance, after pondering all that

happened without stripping the erroneous action from the whole, that the judgment was not

substantially swayed by the error.” See Hanna, 353 F. App’x at 809 (internal quotation marks

omitted). The Defendant testified for several hours over two days. There is no reason to believe

that these three emails would have impacted the jury’s assessment of the defendant’s mental state

after hearing him testify.

               2.      The Court Properly Admitted The Testimony Of A.H.

       The Court properly permitted beneficiary witness A.H. to testify regarding her recollection

of a phone call with an individual who she understood to be an agent of the Defendant. Federal

Rule of Evidence 801(d) provides that a statement is not hearsay if “offered against the opposing

party and . . . was made by the party’s agent or employee on a matter within the scope of that

relationship and while it existed[.]”    Fed. R. Evid. 801(d)(2)(D).      Thus, an employee of

Defendant’s company, speaking on a matter within the scope of that employment, is admissible

non-hearsay if offered against the Defendant. See United States v. Poulin, 461 F. App’x 272, 282

(4th Cir. 2012) (citing United States v. Portsmouth Paving Corp., 694 F.2d 312, 321 (4th Cir.

1982) (“This exclusion applies whenever an employee makes a statement ‘about a matter within

the scope of her employment,’ even if she is not authorized to speak on the matter.”).



                                                    33
       First, the testimony about which Defendant objects was not given in the presence of the

jury. See ECF 78 at 41 (citing 7/19/23 Tr. 119:11-120:21 (foundational testimony outside the

presence of the jury)). Defendant objects to the statement “this is how we bill,” which was testified

to by A.H. during foundational testimony outside the presence of the jury. See Exhibit 3 (7/19/23

Tr.) at 119-120. Nevertheless, the government assumes Defendant intended to raise its objection

to the testimony that was before the jury, in which A.H. stated:

               Q. [A.H.] when you spoke to this person on the phone, what did they
               tell you?

               A. They told me that that's just what we do.

Id. at 122. This testimony was properly admitted for the reasons stated by the Court on the record,

and as discussed below. See id. at 121-122.

       During A.H.’s testimony, she testified that in response to receiving a notice from Medicare

about the services billed to Medciare for her COVID-19 test, A.H. called the number on the

explanation for Drs ERgent Care that was listed on her explanation of benefits. A.H. testified that

“[s]omeone answered the phone, and I explained who I was, gave them my name. I told them that

I’d received a summary notice that showed that they had billed and been paid [for] services

provided by Dr. Elfenbein, whom I had never met, had never seen, neither have I seen him nor

anyone else at Drs ERgent Care, and that they have to have made a mistake.” Id. at 115. A.H.

testified about what the individual on the phone said in response, an objection was interposed and

the Court excused the jury. Id. at 116-118. Outside the presence of the jury, additional questioning

was conducted by government counsel to lay foundation for the testimony under Fed. R. Evidence

801(d)(2)(D). A.H. testified:

               Q. [A.H.], who did you call that day?

               A. I called the phone number on the explanation of Medicare
               benefits.

                                                     34
Q. Okay. And did you have an understanding of who you were
speaking with when you had that phone call?

A. It was whoever answered the phone. I don't know who that was.

Q. Did --

A. They gave me a first name, but I don't remember it.

Q. Okay. Could you explain the substance -- do you believe that you
actually were speaking to a person who was affiliated with the
company that rendered you service when you went to get your
COVID test?

A. Yes, because -- would you ask me the question again, please?

Q. Sure. Did anybody on the phone tell you that you had called the
wrong number?

A. No.

Q. Did anybody tell you that you were not actually one of their
patients?

A. No, they did not.

Q. Did whoever you spoke to actually confirm that you were a
patient of theirs?

A. No, they did not.

Q. Okay. Well, then, why do you think -- why do you think you were
talking to somebody about the bill you were disputing?

A. Because the phone number was on the Medicare explanation of
benefits.

Q. Okay. And what did you -- what did that person ultimately tell
you?

A. What they said was, that's just what we do, when I told them that
they had billed me for services that were not furnished and that I had
received the COVID test on the date of the first service for which
they claimed I received.

Q. They said, this is how we bill?

A. This is how we bill, yes.


                                     35
               Q. Okay. And the bill you got was from Drs ERgent Care, at least
               according to the notice?

               A. Well, the explanation of Medicare benefits said it was Drs
               ERgent Care who filed the claim and was paid on behalf of and
               spoke to an individual she understood to be an employee of that
               company.

               Dr. Elfenbein.

               Q. And they didn't say you called the wrong number?

               A. They did not say I called the wrong number.

Id. at 119-121. Defense counsel opted not to ask any voir dire questions of the witness at that

time. Id. at 121. The foundation provided by A.H. was sufficient to establish that the statement

was made by an agent of the defendant for purposes of admissibility. A.H. testified that she called

the number associated with Drs ERgent Care listed on the explanation of benefits and spoke to an

individual who answered the phone. Id. at 119. She testified that the individual did not indicate

that she had the wrong number, or otherwise indicate that she was not speaking with someone

associated with Drs ERgent Care. Id. at 120. A.H. testified that the individual responded

substantively to her inquiry, saying “[t]his is how we bill.” Id. at 20-21. In addition, the

explanation of benefits indicates that services were provided by Drs Ergent Care LLC, and the

provider who purportedly provided the services was the Defendant. Exhibit 24 (Gov’t Trial Ex.

414), Exhibit 25 (Gov’t Trial Ex. 415). Defendant was an owner and the Medical Director of Drs

ERgent Care at the time of the phone call. Exhibit 10 (8/1/23 Tr.) at 119-120 (Defendant testimony

that he was owner and medical director of Drs ERgent Care), Exhibit 2 (7/18/23 Tr.) at 83

(ownership disclosure to Medicare of Drs ERgent Care did not change).

       This evidence is sufficient to establish foundation for admission of the hearsay statement

under Rule 801(d)(2)(D). The Fourth Circuit in Portsmouth affirmed evidentiary rulings under

Rule 801(d)(2)(D) in similar circumstances. 694 F.2d at 321. In that case, the district court

                                                    36
permitted a witness to testify about statements made to him by an individual who answered a phone

at the Defendant’s office. The Fourth Circuit explained: “First, [the witness] testified that he

‘called [the defendant’s] office.’ Not only does this testimony authenticate the occurrence of the

telephone call in accordance with the standard illustrated by Rule 901(b)(6),[] but the testimony

also supports the inference that the one who answered the telephone was [defendant’s] agent. One

would usually and properly assume upon the dialing of a business office phone number that the

person who answers is employed by and has the authority to speak for the business.” Portsmouth

Paving, 694 F.2d at 322. Although Defendant contends that other evidence suggests the number

listed on the explanation of benefits was a fax number, A.H.’s testimony that she called the number

listed for Drs ERgent Care and received an answer supports the finding that she spoke with an

agent of Drs ERgent Care.7 Further, her testimony that the individual on the phone did not indicate

a wrong number had been called, or that she was not a patient of the company, and instead that the

individual substantively responded supports the finding.

         The testimony of A.H. was properly admitted under Federal Rule of Evidence

801(d)(2)(D).     Moreover, in light of the extensive evidence about the coding practices at

Defendant’s company, and specifically the practice of coding and billing patients who receive a

COVID-19 test at Defendant’s company for an additional level 4 office visit—the same code

contained in A.H.’s summary notice—any error in admitting the evidence is harmless. See United

States v. Gordon, 754 F. App’x 171, 177 (4th Cir. 2018) (“An error is harmless if it did not affect

the verdict.”).




7
    Fax machines use phone lines and can have telephone receivers.
                                                    37
       C.     The Court’s Voir Dire Process Did Not Violate Defendant’s Sixth Amendment
       Rights.

       The Court’s voir dire process, which followed the Court’s standard practice, satisfies

constitutional scrutiny. While the Defendant enjoys the right to a public trial under the Sixth

Amendment, which includes voir dire, “[t]he right to an open trial may give way in certain cases

to other rights or interests, such as the defendant’s right to a fair trial or the government’s interest

in inhibiting the disclosure of sensitive information.” Presley v. Georgia, 558 U.S. 209, 213

(2010). Here, the Court’s determination to exclude members of the public from the courtroom

during the individual Q&A portion of juror voir dire does not warrant a new trial.

        “[N]ot every public-trial violation will in fact lead to a fundamentally unfair trial.” Weaver

v. Massachusetts, 582 U.S. 286, 300 (2017). In Weaver, the Supreme Court addressed the question

of whether exclusion of the public during voir dire warranted relief where counsel did not object

to the public-trial violation, Id. at 301-302, and held that “[a]lthough the petitioner’s mother and

her minister were indeed excluded from the courtroom for two days during jury selection,

petitioner’s trial was not conducted in secret or in a remote place. [] The closure was limited to

the jury voir dire; the courtroom remained open during the evidentiary phase of the trial; the

closure decision was apparently made by court officers rather than the judge, there were many

members of the venire who did not become jurors but who did observe the proceedings; and there

was a record made of the proceedings that does not indicate any basis for concern, other than the

closure itself.” Weaver, 582 U.S. at 304.

       The Fourth Circuit similarly has affirmed closure of the courtroom and in camera voir dire

of potential jurors. In In re South Carolina Press Ass’n, the Fourth Circuit explained:

               As we stated in In re Greensboro News Co., 727 F.2d 1320, 1325
               (4th Cir.1984): “A careful and exhaustive voir dire is crucial to
               ensure that these defendants will be tried by an impartial jury which
               will render its verdict on the basis of evidence adduced at trial rather
                                                      38
               than information from the newspapers or television.” In Greensboro
               News, we also concluded that a trial judge’s in camera voir dire of
               potential jurors in a criminal prosecution so as to ensure frank and
               forthcoming responses was not an unusual practice, “nor viewed
               with suspicion.” Id. at 1323.

In re South Carolina Press Ass’n, 946 F.2d 1037, 1041 (4th Cir. 1991); see also Woodson v.

Hutchinson, 52 F. App’x 195, 198-99 (4th Cir. 2002) (rejecting ineffective assistance of counsel

claim for failure to object to closure of courtroom during voir dire, and confirming space

considerations may be proper basis for closure during jury selection process).

       Here, the Court’s closure of the courtroom during voir dire was consistent with those

interests—the closure of the courtroom encouraged “frank and forthcoming responses” from the

jurors about their personal information, education and employment history, as well as medical

histories pertinent to the case. The interest in obtaining frank and honest answers to such inquiry

warranted closure of the courtroom.       See id.; cf. Weaver, 582 U.S. at 298 (“It would be

unconvincing to deem a trial fundamentally unfair just because a judge omitted to announce factual

findings before making an otherwise valid decision to order the courtroom temporarily closed.”).

The Court explained on the record that “[g]enerally speaking, we treat the individual voir dire as

being the equivalent of our former practice of brining the prospective juror to the bench. So all on

the record, but not public. Accordingly, my preference would be to exclude from the courtroom

anyone who is not a direct participant in the trial.” Exhibit 1 (7/17/23 Tr.) at 31. This practice

protects the Defendant’s rights by encouraging the jurors answer candidly to follow-up voir dire

questions posed by the Court and the parties.

       Moreover, as the Defendant concedes in his motion, counsel for the Defendant “agreed that

it was acceptable.” ECF 78 at 44 (citing 7/17/23 Tr. 33:5-9). Nor can Defendant contend that it

did not have time to lodge an objection to the process. See ECF 78 at 44 (“The acquiescence by

defense counsel, after the Court had stated how it would proceed, does not cure this structural
                                                    39
error.”). This process was proposed by the parties in its Joint Proposed Voir Dire filing. ECF 35

at 1 (parties’ jointly proposed prefatory voir dire instruction: “After I have asked all of my

questions, you will leave the Courtroom and wait in the hallway and vestibule areas, just outside

the Courtroom door. Then you will be brought back to the Courtroom, one-by-one, to meet with

me and to review the answers that you have provided on your answer sheet. Once you are back in

the Courtroom, only court staff, the parties, the lawyers, and I will be present. No one else will

hear the answers that you provide.”). The Court adopted the parties’ proposed process, notifying

the parties weeks in advance of trial that it would follow that process. ECF 43-1 (July 6, 2023

Voir Dire Questions Court Intends To Employ At Trial). Defendant’s contention that the process

he jointly proposed, and to which he did not raise any objection, should be rejected.

        Defendant has not shown that the closure of the courtroom during voir dire warrants a new

trial, and his motion should be denied.

                                     CONCLUSION

        For the reasons stated above, the United States respectfully requests that the Court deny

Defendant’s Motion for Judgment of Acquittal or, in the Alternative for a New Trial, ECF 78, in

its entirety.

                                             Respectfully Submitted,

                                             GLENN S. LEON, CHIEF
                                             CRIMINAL DIVISION, FRAUD SECTION
                                             U.S. DEPARTMENT OF JUSTICE

                                             EREK L. BARRON
                                             UNITED STATES ATTORNEY

                                             /s/
                                             Matthew P. Phelps
                                             Assistant United States Attorney

                                             D. Keith Clouser
                                             U.S. Department of Justice
                                                    40
Criminal Division, Fraud Section
1400 New York Avenue, N.W.
Washington, D.C. 20005
david.clouser@usdoj.gov

COUNSEL FOR THE UNITED STATES




     41
                               CERTIFICATE OF SERVICE

       I HEREBY CERTIFY that on September 1, 2023, I electronically filed the foregoing with

the Clerk of the Court by using the CM/ECF system which will send a notice of electronic filing

to all counsel of record.



                                                   By:    /s/ Matthew Phelps




                                                 42


File and source

File
gov.uscourts.mdd.510872.85.0.pdf
Size
638,383 bytes
SHA-256
4547f3073e111e0b7fa51d3f5a0b715d59e52696739fef4d52b09ffdda58d1b1
Our copy
gov.uscourts.mdd.510872.85.0.pdf
Original
archive.org
Back to top