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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

UNITED STATES OF AMERICA

No. 15-cr-20351

v.

Hon. Victoria A. Roberts

D-1 SHAHID TAHIR,

Defendant.

________________________________/

AMENDED DISCOVERY NOTICE

1. The attorney for the government knows that the defendant made

a. relevant written or recorded statements (including grand jury 

testimony) and/or

b. relevant oral statements made in response to interrogation, whether 

before or after arrest, by a person then known to the defendant to be a 

government agent, whether or not the statement is included in a 

written record, as follows:

Date Agent/Agency Type Not Applicable __ 

09/11/2012 Brian Fairweather, FBI

Gary Francis, FBI

FD-302a

Multiple dates FBI and HHS-OIG Recorded statements made 

during interactions with 

confidential sources

2. The attorney for the government knows that defendant has a prior criminal 

record:

NO X YES 

3. The following books, papers, documents, photographs and tangible objects 

are within the possession, custody or control of the government and are 

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intended to be used as evidence in chief at trial, are known to the 

government to be material to the preparation of the defense, or were 

obtained from or belong to the defendant: 

• Documents and billing data provided by Medicare;

• Bank records;

• Travel records;

• Items seized during the execution of search warrants at the 

following locations:

o At Home Network, Inc., 20282 and 20284 Middlebelt 

Road, Livonia, Michigan

o Waseem Alam, M.D., P.C., 43344 Woodward Avenue, 

Bloomfield Hills, Michigan

o Woodward Urgent Care PLLC, 43344 Woodward 

Avenue, Bloomfield Hills, Michigan

o 3840 Manchester Court, Bloomfield Hills, Michigan

o 92 Millstone Drive, Troy, Michigan

o 6701 Stonebridge Court, West Bloomfield, Michigan

o Hatem M. Ataya, M.D., P.C., 971 Baldwin Street, 

Lapeer, Michigan

o Hatem M. Ataya, M.D., P.C., 3400 Fleckenstein Drive, 

Flint, Michigan

o Hatem M. Ataya, M.D., P.C., 3390 North State Road, 

Davison, Michigan

o Hatem M. Ataya, M.D., P.C., 5097 Miller Road, Flint, 

Michigan

o 2591 South Shore Drive, Flushing, Michigan

o 3390 North State Road, Suite C, Davison, Michigan

o Storage room within 3390 North State Road, Davison, 

Michigan

o Black Mercedes Benz sedan with Michigan license plate 

number CJZ2104

o gotherapy@yahoo.com

o nasima.ahmed0@gmail.com

o shahidtahir@comcast.net

o House Calls Physicians, PLLC, 6842 Park Avenue, Allen 

Park, Michigan

o Advanced Medical Billing Professionals, LLC, 6842 

Park Avenue, Suite 3, Allen Park, Michigan

o Home Physician Services, P.C., 17520 West 12 Mile 

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Road, Suites 109 and 111

including patient files, patient charts, and other medical records, 

payroll information, personal financial documents, checks, 

miscellaneous business information binders, employee 

verification files, corporate documents, activity logs, faxes, 

contact lists, prescriptions and prescription records, business 

records, employee files, correspondence, invoices, electronic 

media and storage devices, accounting records, billing records, 

and other miscellaneous items and documents;

• Photographs of premises taken during execution of search 

warrants.

4. Results or reports of the following physical or mental examinations, or 

scientific tests or experiments, are within the possession, custody or control 

of the government, and are either intended to be used as evidence in chief at 

trial or are known to the government to be material to the preparation of the 

defense: N/A

5. The government intends to introduce at trial testimony from one or more 

experts in the following areas of expertise: N/A at this time

6. The government may introduce evidence obtained from execution of the 

following search warrants:

Date(s) Address/Location Docket Number(s)

06/16/2015 At Home Network, Inc., 20282 

and 20284 Middlebelt Road, 

Livonia, Michigan

15-mc-50783-D

06/16/2015 Waseem Alam, M.D., P.C., 

43344 Woodward Avenue, 

Bloomfield Hills, Michigan

15-mc-50783-E

06/16/2015 Woodward Urgent Care PLLC, 

43344 Woodward Avenue, 

Bloomfield Hills, Michigan

15-mc-50783-F

06/16/2015 3840 Manchester Court, 

Bloomfield Hills, Michigan

15-mc-50783-G

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06/16/2015 92 Millstone Drive, Troy, 

Michigan

15-mc-50783-H

06/16/2015 6701 Stonebridge Court, West 

Bloomfield, Michigan

15-mc-50783-I

06/02/2015 Hatem M. Ataya, M.D., P.C., 971 

Baldwin Street, Lapeer, Michigan

15-mc-50777

06/02/2015 Hatem M. Ataya, M.D., P.C., 

3400 Fleckenstein Drive, Flint, 

Michigan

15-mc-50777-A

06/02/2015 Hatem M. Ataya, M.D., P.C., 

3390 North State Road, Davison, 

Michigan

15-mc-50777-B

06/02/2015 Hatem M. Ataya, M.D., P.C., 

5097 Miller Road, Flint, 

Michigan

15-mc-50777-C

06/02/2015 2591 South Shore Drive, 

Flushing, Michigan

15-mc-50777-D

06/02/2015 3390 North State Road, Suite C, 

Davison, Michigan

15-mc-50783

06/02/2015 Storage room within 3390 North 

State Road, Davison, Michigan

15-mc-50783-A

06/02/2015 Black Mercedes Benz sedan with 

Michigan license plate number 

CJZ2104

15-mc-50783-B

01/16/2015 Waseem Alam, M.D., P.C., 

43344 Woodward Avenue, 

Bloomfield Hills, Michigan

14-mc-51592-C

11/20/2014 gotherapy@yahoo.com 14-mc-51592

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11/20/2014 nasima.ahmed0@gmail.com 14-mc-51592-A

11/20/2014 shahidtahir@comcast.net 14-mc-51592-B

09/20/2012 House Calls Physicians, PLLC, 

6842 Park Avenue, Allen Park, 

Michigan

12-mc-51300-B

09/20/2012 Advanced Medical Billing 

Professionals, LLC, 6842 Park 

Avenue, Suite 3, Allen Park, 

Michigan

12-mc-51300-D

09/11/2012 Home Physician Services, P.C., 

17520 West 12 Mile Road, Suites 

109 and 111, Southfield, 

Michigan

12-mc-50403-B

7. The government may introduce evidence obtained through wiretaps or other 

electronic surveillance:

Type: (wiretap, bug, etc.) Docket Number(s) Not Applicable __

Consensual recordings on N/A

multiple dates 

8. The government intends to offer evidence under Rule 404(b), Fed. R. Evid.

Yes __ No__ Unsure X 

9. The attorney for the government is aware of the obligations imposed by

Brady v. Maryland, 373 U.S. 83 (1963), and its progeny and will comply 

with their obligation to provide defense counsel with exculpatory evidence 

that is material to either guilt or to punishment in time for effective use at 

trial.

If the government discovers additional information of the type described in 

Paragraphs One through Nine, it will advise defense counsel in writing.

Upon specific request of the defendant, the government will make available 

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for inspection or copying the items described in Paragraphs One, Three, and Four; 

will furnish the record referred to in Paragraph Two; will provide a summary 

(which will include the witnesses’ qualifications, opinions, and the bases and 

reasons for the opinions) of the anticipated testimony described in Paragraph Five;

and will provide notice of the general nature of the evidence referred to in 

Paragraph Eight. The government’s compliance with any specific request will 

trigger the defendant’s duty to provide the reciprocal discovery denoted in Fed. R. 

Crim. P. 16(b)(1)(A)-(C). If the defendant makes a general request for discovery 

the government will construe it as a request for each item described in Fed. R. 

Crim. P. 16(a)(1)(A)-(E). The government’s compliance with the defendant’s 

general request will trigger the defendant’s duty to provide reciprocal discovery of 

each item specified in Fed. R. Crim. P. 16(b)(1)(A)-(C).

Barbara L. McQuade

United States Attorney

s/Matthew C. Thuesen

Matthew C. Thuesen 

Trial Attorney

U.S. Department of Justice

Criminal Division, Fraud Section

1400 New York Ave., N.W.

Bond Building, Fourth Floor

Washington, D.C. 20005

Phone: 202-679-4187

Dated: June 25, 2015 E-Mail: matthew.thuesen@usdoj.gov

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CERTIFICATE OF SERVICE

I hereby certify that, on June 25, 2015, I electronically filed the foregoing 

document with the Clerk of the Court using the CM/ECF, which will send 

notification of such filing to the following:

Harold Z. Gurewitz

Gurewitz & Raben, PLC

333 W. Fort Street Suite 1400

Detroit, MI 48226

Counsel for Defendant Shahid Tahir

 

s/Matthew C. Thuesen

Matthew C. Thuesen 

Trial Attorney

U.S. Department of Justice

Criminal Division, Fraud Section

1400 New York Ave., N.W.

Bond Building, Fourth Floor

Washington, D.C. 20005

Phone: 202-679-4187

E-Mail: matthew.thuesen@usdoj.gov

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