03-031 - Denti-Cal Complaint - Attorney General - State of California

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COUNT 3
On or about or between January 1, 1997 and July 12, 2000, in the County of Los Angeles,
State of California, defendant, Enrique Valer, Julio Javier Romo, Zubin Plasencia, Gabriel
Humberto Rios, Monica Maximiliano, Juan Carlos Avila, Teresa Mendivil, and Carmen
Revelli, committed the crime of HEALTH BENEFITS FRAUD in that said defendants did
commit or aid, abet, solicit, or conspire with others known and unknown, and did knowingly
make or cause to be made false or fraudulent claims for payment of a health care benefit under
the provider number fraudulently obtained and used for one or more dentists, to the Medi-Cal
Dental program, in violation of Penal Code §550(a)(6), a FELONY.
SPECIAL ALLEGATION
LOSS OVER $50,000: Penal Code §12022.6(a)(1)
It is further alleged that in the commission of the felonies charged in Counts 1 through 3
that defendants Enrique Valer, Julio Javier Romo, and Zubin Plasencia, with the intent to
cause so, took, damaged, and destroyed property of a value in excess of Fifty Thousand Dollars
($50,000), within the meaning of Penal Code §12022.6(a)(1).
SPECIAL ALLEGATION
LOSS OVER $150,000: Penal Code §12022.6(a)(2)
It is further alleged that in the commission of the felonies charged in Counts 1 through 3
that defendants Julio Javier Romo, and Zubin Plasencia, with the intent to cause so, took,
damaged, and destroyed property of a value in excess of One Hundred Fifty-Thousand Dollars
($150,000), within the meaning of Penal Code §12022.6(a)(2).
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14.
Felony Complaint - People v. Enrique Valer, et al.