UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Case No. ________ _ 

18 u.s.c. § 1347 

UNITED STATES OF AMERICA, 

18 U.S.C. § 1035(a)(2) 

18 u.s.c. § 2 

18 U.S.C. § 982(a)(7) 

FILED BY ___ D.C. v. 

LAUREN ROSECAN, 

Defendant. 

I ------- ----

INFORMATION 

The United States Attorney charges that: 

GENERAL ALLEGATIONS 

At all times material to this Information: 

Medicare Program 

JUN 2 6 2020 

ANGELA E. NOBLE 

CLERK U.S. DIST. CT. 

S.D. OF FLA. - W.P.B. 

1. The Medicare program ("Medicare") is a federal health care program providing 

benefits to persons who are over the age of sixty-five or disabled. 

2. Medicare is a "health care benefit program," as defined by Title 18, United States 

Code, Section 24(b). Individuals who receive benefits under Medicare are referred to as Medicare 

"beneficiaries." 

3. "Part B" of the Medicare program is a medical insurance plan that pays Medicare 

providers and suppliers, with the exception of inpatient healthcare facilities, directly for covered 

goods and services. 

20-cr-80052-Ruiz/Reinhart SP

Case 9:20-cr-80052-RAR Document 1 Entered on FLSD Docket 06/26/2020 Page 1 of 16
4. "Part C" of the Medicare program allows Medicare beneficiaries to receive covered 

benefits through private health insurance companies, rather than directly through Medicare itself. 

These health care benefit programs follow the Medicare rules and regulations in determining 

coverage and payment for medical services rendered to beneficiaries. 

5. In addition to Medicare Part B and Part C health care plans, benefi ciaries may also 

obtain "supplemental" plans from private health insurance companies, which cover the 

beneficiaries' co-pay obligations under Medicare. All of these plans follow Medicare rul es and 

regulations as well. 

6. Medicare is administered by the United States Department of Health and Human 

Services ("HHS") through its agency, the Centers for Medicare and Medicaid Services ("CMS"). 

CMS contracts with regional fiscal intermediaries, also known as Medicare administrative 

contractors ("MACs"), to receive, adjudicate, and pay Medicare claims submitted by Medicare 

providers. First Coast Service Options, Inc. ("First Coast") serves as the MAC in the State of 

Florida. 

7. Medical clinics or doctors who seek to be reimbursed for medical services provided 

to Medicare beneficiaries must first apply for and receive a Medicare "provider number." In 

signing a provider agreement, the provider agrees to abide by the Medicare laws, regulations, and 

program instructions. Among these obligations is the requirement that the provider submit claims 

only for reasonable and necessary medical services. In submitting a claim, the provider must set 

forth, among other things, the beneficiary's name and Medicare number, the services provided, the 

diagnosis justifying the services, the date the services were provided, the cost of the services, and 

the name and provider number of the physician or other health care provider who ordered the 

services. 

2 

Case 9:20-cr-80052-RAR Document 1 Entered on FLSD Docket 06/26/2020 Page 2 of 16
8. To aid in the processing and adj udication of cla ims, Medicare providers are 

required to use standardized codes to describe the pertinent diagnoses and the procedures for which 

payment is being sought. With respect to diagnoses, providers ar e required to use the codes 

established in the International Classification of Diseases Manual ("ICD Codes"). ICD Codes 

relevant to this Information, include, but are not limited to, the following: 1906, C6930, C693 1 

and C6932, all related to a diagnosis of a malignant neoplasm of the choroid, i.e. choroidal 

melanoma; and 2240 and 2246, related to diagnosis of a benign neoplasm, i.e. a nevus. 

9. The Health Care Financing Administration Common Procedmal Coding System 

("HCPCS") is the coding system used by Medicare to identify every task, service, or procedure a 

medical practitioner may provide to a patient, including medical, surgical, and diagnostic services. 

The HCPCS is based upon the Physicians' Current Procedural Terminology code book ("CPT 

Code") developed by the American Medical Association. On their claims for payment, medical 

providers state the HCPCS/CPT Codes (hereinafter referred to as "CPT Codes") that identify the 

types of services for which Medicare is being charged. These codes are used to determine 

reimbursement. For any claim to be payable, the procedure performed must be reasonable and 

necessary for the particular diagnosis. In other words, the diagnosis, as reflected in the ICD code, 

must support the medical necessity of the particular procedure performed. CPT Codes, their 

Medicare definitions and common descriptions relevant to this Info1mation include, but are not 

limited to, the following: 

CPT Code Medicare Definition Common DescriQtion 

67210 Laser destruction of retinal growth, 1 or Focal laser photocoagulation 

more sessions of retina 

67220 Destruction of vascular growth between Focal laser photocoagulation 

retina and the sclera, 1 or more sessions of choroid 

67228 Laser destruction of leaking retinal Pan Retinal Photocoagulation 

blood vessels, 1 or more sessions ("PRP") of retina 

76510 Ultrasound of eye tissue and structures A and B-Scan 

3 

Case 9:20-cr-80052-RAR Document 1 Entered on FLSD Docket 06/26/2020 Page 3 of 16
CPT Code Medicare Definition Common Descri~tion 

76512 Ultrasound of eye disease, growth or B-Scan 

structure 

10. In addition to the basic CPT Codes, there are a number of "modifiers" that are twodigit or two-letter supplements that provide additional information about the procedure. For 

example, in ophthalmology, the provider must specify the eye upon which a procedure has been 

performed. For some procedures, the modifier "50" is used to indicate that the procedure was 

bilateral, i.e., performed on both eyes. For other procedures, the suffix RT or LT is used to indicate 

that the procedure was performed on the right eye or left eye, respectively. 

11. Under the laws that regulate the Medicare program, no payment may be made for 

any expenses incurred for items or services that are not reasonable and necessary for the diagnosis 

or treatment of illness or injury. In general, Medicare makes the physician the "gatekeeper" for 

determining when medical testing and treatment are medically reasonable and necessary. To 

receive reimbursement, providers are obligated to follow all Medicare rules and regulations. 

12. Medicare permits claims to be submitted electronically. To do so, a provider must 

enroll in electronic billing through the MAC. By submitting an enrollment fonn, a provider agrees 

that all claims wil l be accurate, complete, and truthful. Further, the provider's unique identification 

number affixed to a claim constitutes a lawful electronic signature verifying that the services are 

medically reasonable and necessary and were performed as billed. In order to timely process the 

many millions of claims generated annually in the Medicare program, Medicare relies upon the 

honesty and integrity of providers who certify the validity of their claims. 

4 

Case 9:20-cr-80052-RAR Document 1 Entered on FLSD Docket 06/26/2020 Page 4 of 16
The Defendant 

13. The defendant, LAUREN ROSECAN, operated medical clinics under the name 

The Retina Institute of Florida ("RIF"). The defendant had several office locations in Palm Beach, 

Martin, and Port St. Lucie Counties in the Southern District of Florida. 

14. The defendant was an ophthalmologist and retina specialist licensed to practice 

medicine in the State of Florida. As a retina specialist, the defendant treated conditions and 

diseases of the retina. At al l times material to this Information, the defendant was the only licensed 

physician practicing at RIF. 

15. The defendant was an approved Medicare service provider. A substantial portion 

of his client base was composed of elderly patients who were Medicare beneficiaries. 

CHOROIDAL MELANOMA 

16. Choroidal melanoma (hereinafter referred to as "CM") is a malignant cancer or 

tumor of the eye originating in the choroid, which is a vascular layer of tissue located behind the 

retina. CM is a very rare form of cancer, being diagnosed in approximately five persons per million 

per year in the United States. There are highly trained ophthalmologists, known as ocular 

oncologists, who specialize in cancers of the eye. 

17. There are several treatment options for CM, ranging from observation (for small 

tumors), to radiation (mediwn-sized tumors), to enucleation or removal of the eye. The most 

successful treatment in the past decade has been radiation, which, for small and medium-sized 

tumors, has had a non recun ence rate of approximately 95%. 

18. Laser treatments have also been used to treat small CM tumors, the most common 

being transpupillary thermotherapy ("TTT"). TTT involves the use of a diode laser to slowly heat 

the tumor, thus killing the cancer cells. 

5 

Case 9:20-cr-80052-RAR Document 1 Entered on FLSD Docket 06/26/2020 Page 5 of 16
19. Focal laser photocoagulation ("focal laser") consists of shining a high-intensity 

laser light beam into the eye under magnification in order to burn, or cauterize, actively leaking 

blood vessels. Focal laser has also been used in the past to treat CM, but has largely been 

abandoned in favor of more successful treatments, in particular, radiation. 

20. Pan retinal photocoagulation ("PRP") is a laser treatment used to treat people who 

have developed new abnormal blood vessels at the back of the eye in the retina, generally in 

patients with diabetic retinopathy. lt is not a recognized treatment for CM. In PRP the laser is 

applied in a scatter pattern over a wide area of the retina. Medicare reimburses a doctor for the 

performance of PRP at a higher rate than that of foca l laser. 

CHOROIDAL EVUS 

2 1. A choroidal nevus is a benign lesion or growth located in the back of the eye. It is 

sometimes referred to as an eye freckle and is relatively common in Caucasians, occurring in about 

5-8% of that population. A nevus can generally be differentiated from a melanoma based on its 

size (1 mm or less in thickness), color, and other distinguishing features. It has no effect on vision, 

and no treatment of a nevus is medically indicated. 

DIAGNOSTIC TESTING 

22. Ultrasonography (A-scans and B-scans) is an essential tool in the diagnosis and 

treatment of CM. Ultrasonography is a diagnostic imaging procedure that uses sound waves to 

capture images of the inside and back of the eye. In addition to being used to assess the internal 

structure of the eye when the physician's view into the eye is otherwise obscured, an ultrasound 

may also be used to measure the height and refl ectivity of tumors in the back of the eye. 

Consequently, ultrasound is used to capture and document the presence and size of a CM. 

6 

Case 9:20-cr-80052-RAR Document 1 Entered on FLSD Docket 06/26/2020 Page 6 of 16
23. Fundus photography is routinely utilized by ophthalmologists for diagnosis and 

documentation of a variety ofretinal diseases and conditions. The interior of the eye, known as the 

fundus, may be photographed with a specialized camera that is attached to a low-power microscope. 

A fund us photograph captures the same view of the retina as would be seen by a doctor upon visual 

examination of the eye through a magnifi cation device called an ophthalmoscope. Fundus 

photographs may be taken in color or without color. The photographs that are not in color are 

referred to as "red free" photographs. Fundus photography is used to capture and document the 

presence of an abnormality such as CM. 

24. Fluorescein angiography (FA) and indocyanine green angiography (" ICG") also 

capture abnormalities in the retina and choroid. These tests begin with the intravenous 

administration of certain dyes into a vein in the patient's arm, following which pictures are taken 

of the retina and choroid through special fi lters on the fu ndus camera. F As and ICGs are used to 

capture and document the presence of an abno1mality such as CM. 

COUNTS 1-14 

Health Care Fraud 

(18 USC § 1347) 

25. Paragraphs 1 through 24 of the General Allegations section of this Information are 

real leged and incorporated by reference as though fully set forth herein. 

26. Beginning at least as early as 201 2, the exact date being unknown, and continuing 

at least to and through December 3 1, 2015, in Palm Beach, Martin, and St. Lucie Counties, in the 

Southern District of Florida, and elsewhere, the defendant, 

LAUREN ROSECAN, 

in connection with the delivery of and payment for health care benefits, items, and services, did 

knowingly and willfully execute, and attempt to execute, a scheme and artifice to defraud Medicare 

and other health care benefit programs affecting commerce, as defined by Title 18, United States 

7 

Case 9:20-cr-80052-RAR Document 1 Entered on FLSD Docket 06/26/2020 Page 7 of 16
Code, Section 24(b ), and to obtain, by means of materially false and fraudulent pretenses, 

representations, and promises, money and property owned by and under the custody and control 

of Medicare and other health care benefit programs. 

Purpose and Object of the Scheme and Artifice 

27. It was the purpose and object of the scheme and ai1ifice for the defendant, 

LAUREN ROSECAN, to unlawfully enrich himself by, among other things, falsely diagnosing 

patients with choroidal melanoma ("CM"); perfo1ming medically unreasonable and unnecessary 

diagnostic tests and procedures; making false entries in patients' medical charts; and submitting 

claims to Medicare and other health care benefit programs based upon said false diagnoses, 

treatments and entries in patient medical charts. 

The Scheme and Artifice 

28. The manner and means by which the defendant sought to accomplish the purpose 

and object of the scheme and artifice to defraud included, among other things, the following: 

a) The defendant would fa lsely diagnose a substantial number of his Medicare patients 

with CM, either upon the initial patient visit, or in a subsequent visit. In many instances, the 

defendant would diagnose the condition bilaterally, that is, in both of the patient's eyes. In other 

instances, the defendant would diagnose the condition in both husband and wife of a married 

couple. 

b) The defendant would take ultrasounds (A and B-Scans) of patients' eyes and would 

then place markers on the images, purportedly to measure mid to large sized tumors, when, in fact, 

no such tumors were present. 

c) The defendant would perform laser treatments on said patients, primarily pan 

retinal photocoagulation, which has never been a recognized treatment for CM. 

8 

Case 9:20-cr-80052-RAR Document 1 Entered on FLSD Docket 06/26/2020 Page 8 of 16
d) The defendant would not refer said patients to an ocular oncologist or even another 

ophthalmologist in order to provide a second opinion. To the contrary, the defendant actively 

discouraged patients from obtaining a second opinion. 

e) The defendant would cause patients to return to his clinic on a regular basis for 

followup visits, which, in some instances, involved repeated laser photocoagulation sessions. 

f) The defendant would cause patient fi les to contain false information, including false 

diagnoses, measurements, drawings, and diagrams. 

g) The defendant would cause the submission of claims to Medicare for exams, 

diagnostic tests, and laser treatments based upon the false diagnoses and medically unnecessary 

and medically unreasonable treatments for CM. 

Execution of the Scheme and Artifice 

29. In execution of the scheme and artifi ce to defraud, in Palm Beach, Martin, and St. 

Lucie Counties, in the Southern District of Florida, and elsewhere, the defendant, 

LAUREN ROSECAN, 

in connection with the delivery of and payment for health care benefits, items, and services, did 

knowingly and willfully execute, and attempt to execute, the above-described scheme and artifice 

to defraud a health care benefit program affecting commerce, as defined in Title 18, United States 

Code, Section 24(b), and to obtain, by means of materially false and fraudulent pretenses, 

representations, and promises, money and property owned by, and under the custody and control 

of, said health care benefit program, in that the defendant did submit and cause the submission of 

claims to Medicare under diagnostic code 1906 ( choroidal melanoma) for the below-listed patients, 

among others, on or about the dates as further descri bed below: 

9 

Case 9:20-cr-80052-RAR Document 1 Entered on FLSD Docket 06/26/2020 Page 9 of 16
COUNT PATIENT DATE OF DATE OF PROCEDURE CODE AND DESCRIPTIO AMOUNT 

SERVICE CLAIM BILLED 

I Benjamin F. 4/ 14/15 4/20/ 15 67228- Destruction of leaking retina l blood $1,930 

RT vessels [PRP] 

2 Benjamin F. 4/2 1/ 15 4/22/ 15 67228- Destruction of leaking retinal blood $ 1,930 

LT vessels [PRP] 

3 Dorothy R. 4/ 15/15 4/20/ 15 67228- Destruction of leaki ng retina l blood $1,930 

RT vessels [PRP] 

4 Dorothy R. 4/ 17/15 4/22/ 15 67228- Destruction of leaking retinal blood $ 1,930 

RT vessels [PRP] 

5 Barbara F. 4/ 13/15 4/20/1 5 67228- Destruction of leaking retina l blood $1,930 

RT vessels [PRP] 

6 Anna P. 5/4/15 5/5/ 15 67228- Destruction of leaking retina l blood $1,930 

LT vessels [PRP] 

7 Anna P. 5/ 18/ 15 5/ 19/15 67228- Destruction of leaking retinal blood $ 1,930 

RT vessels [PRP] 

8 Richard L. 6/5/15 6/9/ 15 67228- Destruction of leaking retinal blood $1,930 

LT vessels [PRP] 

9 Richard L. 6/1 2/15 6/22/ 15 67228- Destruction of leaking reti nal blood $ 1,930 

RT vessels [PRP] 

IO Thelma F. 6/ 11/15 6/12/15 67228- Destruction of leaking retinal blood $1,930 

RT vessels [PRP] 

11 WilmaM. 8/1 7/ 15 8/20/ 15 67228- Destruction of leaking retinal blood $ 1,930 

LT vessels [PRP] 

12 WilmaM. 8/ 19/1 5 8/24/ 15 67228- Destruction of leaking retina l blood $1 ,930 

RT vessels [PRP] 

13 Fred M. 8/1 7/15 8/20/15 67228- Destruction of leaking retinal blood $1 ,930 

RT vessels [PRP] 

14 Fred M. 8/19/1 5 8/24/ 15 67228- Destruction of leaking retinal blood $1 ,930 

LT vesse ls [PRP] 

All in violation of Title 18, United States Code, Sections 1347 and 2. 

10 

Case 9:20-cr-80052-RAR Document 1 Entered on FLSD Docket 06/26/2020 Page 10 of 16
COUNTS 15-22 

False Statements Relating to Health Care 

(18 U.S.C. §§ 1035(a)(2) and 2) 

30. Paragraphs 1 through 24 of the General All egations section of this Information are 

realleged and incorporated by reference as though fully set forth herein. 

31. On or about the dates set forth below as to each count, in Palm Beach, Martin, and 

St. Lucie Counties, in the Southern District of Florida, the defendant, 

LAUREN ROSECAN, 

in a matter involving a health care benefit program, to wit, Medicare, did knowingly and willfully 

make and use a materially false writing and document knowing the same to contain a materially 

false, fictitious, and fraudulent statement and entry, in connection with the delivery of and payment 

for health care benefits, items, and services, in that the defendant would make and cause to be 

made false entries into the charts of Medicare patients, that is, false measurements of purported 

choroidal melanoma, as well as false diagnoses and fictitious retinal drawings, as fu11her set forth 

below: 

Count Patient Date of Service 

15 Benjamin F. 4/ 14/ 15 

16 Dorothy R. 4/15/15 

17 Barbara F. 4/13/15 

18 Anna P. 5/4/15 

19 Richard L. 6/5/15 

20 Thelma F. 6/1 1/15 

21 WilmaM. 8/17/15 

22 Fred M. 8/17/15 

All in violation of Title 18, United States Code, Sections 1035(a)(2) and 2. 

11 

Case 9:20-cr-80052-RAR Document 1 Entered on FLSD Docket 06/26/2020 Page 11 of 16
FORFEITURE ALLEGATIONS 

1. The allegations of this Information are hereby re-alleged and by this reference fully 

incorporated herein for the purpose of all eging forfeiture to the United States of America of certain 

property in which the defendant, LAUREN ROSECAN, has an interest. 

2. Upon conviction of a violation of Title 18, United States Code, Sections 1035(a)(2) 

or 1347, as alleged in this Information, the defendant shall forfeit to the United States all property, 

real or personal, that constitutes or is derived, directly or indirectly, from gross proceeds traceable 

to the commission of such offense, pursuant to Title 18, United States Code, Section 982(a)(7). 

All pursuant to Title 18, United States Code § 982(a)(7), and the procedures set forth in 

Title 21, United States Code, Section 853, as incorporated by Title 18, United States Code, Section 

982(b)(l). 

• XANDRA CHASE 

ARIAN ~~JA RDO ORSHAN 

UNITED STATES ATTORNEY 

ASSIST ANT UNITED ST A TES ATTORNEY 

12 

Case 9:20-cr-80052-RAR Document 1 Entered on FLSD Docket 06/26/2020 Page 12 of 16
U ITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

U JTED STATES OF AM ERICA CASE NO. _ ______________ _ _ 

v. 

CERTIFICATE OF TRIAL ATTORNEY* 

L AUREN ROSECAN, Superseding Case Information: 

Defendant. 

Court Division: (Select One) 

Miami Key West 

FTL I WPB FTP 

New defendant(s) Yes 

Number of new defendants 

Total number of counts 

No 

1. I have carefully considered the a llegations of the indictment, the number of defendants, the number of 

probable witnesses and the legal complexities of the Ind ictment/Information attached hereto. 

2. I am aware that the information supplied on this stateme nt will be relied upon by the Judges of this 

Court in setting their calendars and scheduling c riminal trials under the mandate of the Speedy Tri al 

Act, Title 28 U.S.C. Section 3161. 

3. Interpreter: (Yes or No) 

List language and/or dialect 

No 

4. This case wi ll take _2Q_ days for the parties to try. 

5. Please check appropriate category and type of offense listed below: 

(Check only one) (Check only one) 

I 0 to 5 days Petty 

ll 6 to IO days Minor 

111 11 to 20 days ✓ Misdem. 

IV 21 to 60 days Felony ✓ 

V 61 days and over 

6. Has this case previously been filed in this District Court? (Yes or No) No 

If yes: Judge Case No. - ------------- (Attach copy of dispositive order) 

Has a complaint been filed in this matter? (Yes or No) 

If yes: Magistrate Case No. 

Related miscellaneous numbers: 

Defendant(s) in federal custody as of 

Defendant(s) in state custody as of 

Rule 20 from the District of 

Is this a potential death penalty case? (Yes or No) 

No 

7. Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Office 

prior to August 9, 2013 (Mag. Judge Alicia 0. Valle)? Yes No ' 

8. Does this case orig inate from a matter pending in the Northern Region of the U.S. Attorney's Office 

prior to August 8, 2014 (Mag. Judge Shaniek Maynard)? Yes No 1 

9. Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Office 

prior to October 3, 20 19 (Mag. Judge Jared Strauss)? Yes No_,_ 

*Penalty Sheet(s) attached 

h~/i~ 

ASSIBTANT IT.ED STATES ATTORNEY 

ROGER STEFlN 

REV 6/5/2020 

20-cr-80052-Ruiz/Reinhart

Case 9:20-cr-80052-RAR Document 1 Entered on FLSD Docket 06/26/2020 Page 13 of 16
U ITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

Defendant's Name: LAUREN ROSECAN 

Case No: --- ----- ------

Count #: 1-14 

Health Care Fraud 

Title 18 United States Code Section 134 7 

* Max. Penalty: 10 years' imprisonment; 3 years' supervised release; fine of $250,000 or twice 

the gross gain or loss resulting from the offense, whichever is greater; and restitution 

Counts #: 15-22 

False Statements Relating to Health Care 

Title 18, United States Code, Sections 1035(a)(2) and 2) 

* Max.Penalty: 5 years' imprisonment; 3 years' supervised release; and fine of $250,000 or 

twice the gross gain or loss resulting from the offense, whichever is greater; and restitution 

*Refers only to possible term of incarceration, does not include possible fines, restitution, 

special assessments, parole terms, or forfeitures that may be applicable. 

20-cr-80052-Ruiz/Reinhart

Case 9:20-cr-80052-RAR Document 1 Entered on FLSD Docket 06/26/2020 Page 14 of 16
AO 455(Rev. 0 1/09) Waiver of an Indictment 

UNITED STATES D ISTRJCT COURT 

United States of America 

V. 

LAUREN ROSECAN 

Defendant 

for the 

Southern District of Florida 

) 

) 

) 

) 

) 

Case No. 

WAIVER OF AN INDICTMENT 

I understand that I have been accused of one or more offenses punishable by imprisonment for more than one 

year. T was advised in open court of my rights and the nature of the proposed charges against me. 

After receiving this advice, I waive my right to prosecution by indictment and consent to prosecution by 

information. 

Date: -------- Defendant 's signature 

Signature of defendant 's a/lorney 

Dennis Urbano, Esq. 

Printed name of defendant's a//orney 

Judge's signature 

Judge ·sprinted name and title 

20-cr-80052-Ruiz/Reinhart

Case 9:20-cr-80052-RAR Document 1 Entered on FLSD Docket 06/26/2020 Page 15 of 16
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NUMBER: ----------

BOND RECOMME DATION 

DEFENDANT: LAUREN ROSECAN 

$50,000 Personal Surety 

(Personal Surety) (Corporate Surety) (Cash) (Pre-Trial Detention) 

By: 

~ H.STEFIN 

Last Known Address: __________ _ 

What Fac ility: 

Agent(s): Special Agent Wende Bardfelcb 

(FBl) (SECRET SERVICE) (DEA) (lRS) (ICE) (OTHER) 

FBI 

20-cr-80052-Ruiz/Reinhart

Case 9:20-cr-80052-RAR Document 1 Entered on FLSD Docket 06/26/2020 Page 16 of 16