IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

UNITED STATES OF AMERICA

MOUZON BASS, III (1)

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INDICTMENT

THE UNITED STATES GRAND JURY CHARGES:

SEALED

Case No.

Judge

FILED

JAN 1 0 2024

Clerk, U.S. District Court

Texas Eastern

General Allegations

At all times material to the facts set forth in this Indictment:

The Defendants, Their Entities, and Their Bank Accounts

1. Defendant Monzon Muzzy Bass, III, was an individual residing in

Highland Park, Texas.

2.

3.

Defe dant B was an individual residing in Allen, Texas.

Defendant was an individual residing in Colorado,

Oklahoma, and California, and was a licensed physician in approximately fifteen states

including Colorado, Oklahoma, and Arkansas.

4. Vivature, Inc. ( Vivature ) was a company that pu ported to provide medical

billing services to a variety of entities, including university health centers, athletic

departments, counseling centers, liigh schools, and international resorts. Vivature was a

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subsidia y of its pare t company, Orchestrate HR, Inc. Bass was the majority owner and

Chief Executive Officer of Vivature, and H was the Executive Vice President of the

company.

5. Varsity Health, Inc. was a business entity registered in Oklahoma. was

a registered agent for the company.

6. Bass, andu N opened and cont olled numerous bank accounts at

Veritex Bank, Titan Bank, and Bank of America, among other financial institutions.

Specifically, the defendants controlled the following accounts, among others:

• On or about June 1, 2012, Bass opened an account at Veritex Bank ending in

1200 ( Veritex 1200 account ), in the name of Vivature, listing Bass as an

authorized signer.

• On or about June 4, 2012, Bass opened an account at Ve itex Bank ending in

1277 ( Veritex 1277 account ), in the name of Vivature, listing Bass as an

authorized signer.

• On or about January 22, 2010, Bass opened an account at Veritex Bank ending

in 1278 (“Veritex 1278 account”), in the name of Orchestrate HR, Inc DBA

Employers Direct Health, listing Bass as an authorized signer.

• On or about August 30, 2017, opened an account at Veritex Bank endin:

in 906 “Veritex 9062 account”), in the name of |

listing as an authorized signer.

• On or about June 6, 1994, opened an account at Bank of America

(previously NationsBank) ending in 9903 (“BOA 9903 account ), listing |

as an authorized signer.

Begiru ing in or around 2019, Vivature s banking relationship with Veritex Bank was

centered at a bank location in the Easte District of Texas, and all Automated Clearing

House (ACH) transfers and the majority of physical check deposits associated with

Indictment

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Vivature, Bass, or gg] were processed through Veritex Bank locations in the Eastern

District of Texas.

7. With respect to he lthcare reimbursements, a servicing provider is the

individual or entity who performed the healthcare service. A place of service is a

healthcare facility where the healthcare service was delivered.

8. A National Provider Identifier ( NPI ) is a unique 10-digit numeric identifier

for covered healthcare providers, created to help send health information electronic lly

safely and efficiently. Covered healthcare providers, health plans, and healthcare

clearinghouses must use NPIs in their administr tive and financial transactions. A

healthcare provider s NPI does not change, even if their name, address, taxonomy, or other

infon ation changes.

COUNT ONE

Violation: 18 U.S.C. § 1349, 1343

(Conspiracy to Commit Wire Fraud)

9. The General Allegations section of this Indictment is realleged and

incorporated by reference as though fully set forth herein.

10. From in or around April 2014 and continuing up through and including the

date of this Indictment, in the Eastern District of Texas and elsewhere, the defendants,

Mouzon Bass, 11 1. and al°ng with others both known and

unknown to the Grand Jury, did knowingly and willfully combine, conspire, confederate,

and agree to violate 18 U.S.C. § 1343, wire fraud, that is to transmit and cause to be

Indictment

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transmitted by means of wire communication in interstate and foreign commerce writings,

signs, signals, pictures, and sounds for the purpose of executing a scheme and artifice to

defraud and for obtaining money and property from private health insurance carriers by

means of false and fraudulent material pretenses, representations, and promises.

Overview of the Athletic Billing Scheme

11. Bass, and others executed a multimillion-dollar scheme to

defraud private insurance companies. Bass nd Q used their company, Vivature, to

submit false claims to private insurance carriers representing that physicians, like co¬

conspirator were providing medical services for injured student-athletes at

universities across the country. In reality, and other physicians did not see or treat

these student-athletes, and in many instances, were physically hundreds of miles away from

where the student-athletes were receiving treatment. The services were actually performed

by athletic trainers employed by the educational institutions athletic departments who,

most times, were specifically excluded from insurance companies’ reimbursement policies.

At the direction of Bass andHHB| Vivature submitted thousands of false claims to the

insurance companies, named and other physicians as the servicing providers, and

used their NPI numbers on the claims paperwork. In exchange for allowing the fraudulent

use of their NPI and credentials, Vivature made regular payments to and other

physicians. In addition, using the fraud proceeds, the defendants transferred the funds to

various accounts, paid each other and co-conspirators salaries and commissions, and

purchased high-dollar luxury items and multi-million-dollar real estate. During the

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scheme, Vivature submitted thousands of fraudulent claims to private insurance carriers,

and and|g || collected over $50 million in paid reimbursements.

Purpose of the Conspiracy

12. It was the general purpose of the conspiracy for Bass, and

their co-conspirators to unlawfully and unjustly enrich themselves by obtaining healthcare

reimbursements from private insurance companies through materially false and fraudulent

pretenses, representations, and promises.

Manner and Means of the Conspiracy

13. The manner and means by which the defendants and their co-conspirators

sought to accomplish the purpose of the conspiracy included, among others, the following:

a. The defendants ar anged with representatives of educational institutions,

including those in the Eastern District of Texas, to provide medical billing

services for injured student-athletes;

b. The defendants and their co-conspirators communicated with each other via

phone, in-person meetings, and emails;

c. The defendants and their co-conspirators opened businesses to conduct the

fraud and opened bank accounts to receive, deposit, and transfer fraudulently

obtained reimbursements;

d. The defendants and their co-conspirators submitted materially false and

fraudulent claims and paper ork to private health insurance providers,

including by falsely stating that and other physicians were the servicing

providers for treatments actually provided by athletic trainers;

e. The defendants, in some instances, used physicians NPI numbers and

credentials on claims paper ork without their knowled e or consent. In otherinstances, the defendants paid certain physicians, like for the fraudulent

use of their NPI number and credentials;

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f. The defendants, using the fraudulently obtained proceeds, paid each other and

co-conspirators salaries and commissions and purchased high-dollar luxury

items, including multimillion-dollar real estate;

g. The defendants caused financial transactions that were processed by Veritex

Bank at locations in the Eastern District of Texas; and

h. The defendants caused transmissions that affected interstate and foreign

commerce by using the financial banking system and causing the claims to be

submitted to insurance companies across the country.

Private Insurance Reimbursements

14. Vivature employees, at the direction of Bass and submitted claims

for treatment provided to injured student-athletes to these student-athletes private health

insurance ea ers, such as Blue Cross Blue Shield, Kaiser Permanente, Cigna and Humana.

Generally, each of these insurance companies reimbursed claims for healthcare services

rendered by qualified servicing provider, which included physicians, hospitals, and

other specified healthcare professionals. However, according to their policies, most

insurance carriers did not cover services provided by athletic trainers or university athletic

departments, nor did they cover telemedicine supervision or treatment of injured student¬

athletes.

Acts in Furtherance of the Conspiracy

The Defendants9 Pitch and Contracts with the Institutio s

15. Bass and marketed Vivature’s medical billing services to athletic

departments at high schools and universities across the country. Bass, and other

sales representatives invited these organizations to use Vivature to help generate revenue

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by billing students private health insurance ea ers, such as Blue Cross Blue Shield

( BCBS ) of Texas, BCBS of Arkansas, Kaiser Permanente, Cigna, and Humana, for

treatment services provided to students. Specifically, Vivature represented that when a

student-athlete was injured in relation to a university sport, the institution s athletic trainer

could record the work they performed for the injury in the athletic training room within

Vivature’s electronic medical record software. Vivature would then use the information in

its software, along with student demographics, insurance data, and other notes related to

the injury, for claims submission to the insurance company. Vivature would then

electronically submit the claim to the insurance company for billing. Insurance companies

would then, after evaluating the submission, pay the claim directly to Vivature, for the

benefit of the institution. Vivature would then share the revenue with institution per the

parties’ contract.

16. Over the course of the scheme, Vivature representatives executed contracts

with multiple institutions, including institutions in the Eastern District of Texas. For

instance:

• On or about December 9, 2014, on behalf of Vivature, entered into an

agreement with LeTourneau University ( LETU ) to provide web-based medical

billing services, insurance verification, and credentialing services. According to the

contract, Vivature agreed to pay LETU 65% of the total insurance collections

received for claims billed for LETU student-athletes. LETU is located in Longview,

Texas, in the Eastern District of Texas.

• On or about July 9, 2014, on behalf of Vivature, entered into an agreement

with Auburn University ( Auburn ) to provide web-based medical billing services,

insurance verification, and credentialing services. According to the contract,

Vivature agreed to pay Auburn 65% of the total insurance collections received for

Indictment

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claims billed for Auburn student-athletes. Aubu is located in Auburn, Alabama.

• On December 3, 2018, HHH on behalf of Vivature, signed a contract with

Arkansas Tech University ( ATU ) to provide web-based medical billing services,

insurance verification, and credentialing services. According to the contract,

Vivature agreed to pay ATU 65% of the total insurance collections received for

claims billed for ATU student-athletes. ATU is located in Russellville, Arkansas.

The Use of Physicians Credentials

17. In some instances, Bass, and representatives of Vivature used

physicians names, NPIs, and credentials on claims paperwork submitted to insurance

companies without the physicians consent or knowledge. Specifically, when appealing

certain claims with private insurance companies, Vivature sent attestation statements to

the insurance companies, purportedly authorized and signed by a physician who was listed

as the servicing provider. In reality, when interviewed by law enforcement, these

physicians confirmed that they had no knowledge of these statements, never signed these

statements, and never authorized the submissions of these statements to insurance

companies during the claims appeal process.

18. In other instances, Bass, and representatives of Vivature agreed to

pay certain physicians for the fraudulent use of the physicians’ NPI and credentials and

executed written agreements with these physicians. For example, in or around August

2017, Bass, on behalf of Vivature, entered into an agreement with under which j

was to provide medical oversight of athletic trainers and related personnel who provide

treatment on or for the benefit of Vivature Clients. In exchange for Scott’s services, Bass

and Vivature agreed to pay $ 10,000 per month.

Indictment

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Examples of Fraudulent Insurance Sub issions

19. Between in or around August 2020 and May 2023, Vivature submitted

thousands of claims to BCBS Arkansas on behalf of Arkansas Tech University ( ATU )

for treatment provided to injured student-athletes.

20. In a 2023 interview with law enforcement agents, ATU s Head Athletic

Trainer with initials B.W confirmed that was assigned to ATU by Vivature and

was supposed to electronically review treatments rendered by ATU athletic trainers.

However, B.W. confirmed that never physically treated any ATU athletes, never

came to ATU s campus, and never spoke with B.W.

21. Yet | was listed as the servicing provider on over $230,000 worth of

claims submitted to BCBS Arkansas on behalf of ATU. Based on the representation that

a physician was the servicing provider, BCBS Arkansas reimbursed over $12,000 for these

claims, which were deposited into Vivature accounts owned and controlled by Bass and

processed at Veritex Bank locations, including those in the Eastern District of Texas.

22. For Scott s role in the conspiracy, over a six-year period, Bass and

transferred at least $1 million to the Veritex 9062 account held in the name o f B.

| D.O. PC. At least $500,000 of these funds were ultimately transferred to a different

personal account controlled by |

23. Vivature s athletic billing scheme, at the direction of Bass andj j also

involved other physicians and extended to universities around the country. In sum, the

Indictment

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defendants fraudulently obtained at least $50 million in paid claims as part of their athletic

billing scheme.

All in violation of 18 U.S.C. § 1349.

Indictment

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COUNT TWO

Violation: 18U.S.C. § 1349, 1347

(Conspiracy to Commit Healthcare

Fraud)

24. The General Allegations section of this Indictment is realleged and

incorporated by reference as though fully set forth herein.

25. From in or around October 2020 and continuing up through and including

January 2022, in the Eastern District of Texas and elsewhere, the defendants, Mouzon

Bass, 111111.] a d j along with others both kno n and unknown

to the Grand Jury, did knowingly and willfully combine, conspire, confederate, and agree

to violate 18 U.S.C. § 1347, healthcare fraud, that is, 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 the Health Resources and Services Administration

( HRSA ), which operated a healthcare benefit program as defined in Title 18, United

States Code, Section 24(b), in connection with the payment of healthcare benefits, items,

and services.

COVID-19 Testing and HRSA Reimbursements

26. Between January 12, 2021, and June 10, 2022, the United States instituted a

federal order that all air passengers airiving from a foreign country to the United States

provide proof of a negative CO VID-19 test or documentation of having recovered from

COVID-19. The order applied to all travelers regardless of citizenship or originating

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location. To encourage Americans to travel abroad during the pandemic, many hotels and

resorts began offering COVID-19 testing to American travelers returning home.

27. Since 1982, the Health Resources and Services Administration ( HRSA )

was a taxpayer-funded federal program dedicated to providing equitable healthcare to the

nation s highest-need communities serving people who are geographically isolated and

economically or medically vulnerable. HRSA programs supported people with low

incomes, people with HIV, pregnant people, children, parents, rural communities,

transplant patients, and other communities in need, as well as the health workforce, health

systems, and facilities that care for them. Through HRSA, the U.S. Department of Health

and Human Services provided claims reimbursement to healthcare providers for testing

uninsured individuals for COVID-19, treating uninsured individuals with a COVID-19

diagnosis, and administering COVID-19 vaccines to uninsured individuals. The program

did not cover or apply to insured individuals, nor did it cover COVID-19-related services

administered outside the country.

Overview of COVID-19 Billing Scheme

28. Beginning in 2021 and during the COVID-19 pandemic, Bass, |

| and others affiliated with Vivature executed a scheme to fraudulently obtain HRSA

government funds earmarked for COVID-19 testing provided to uninsured Americans.

The defendants partnered with inte ational resorts hosting American travelers abroad,

offering to manage the billing and claims process for COVID-19 testing provided to these

American travelers. Then, the defendants submitted thousands of reimbursement claims

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to HRSA for such travelers. In submitting these claims, the defendants represented to the

government that: (1) the travelers were uninsured; and (2) the testing took place at the

medical offices of Scott s company Varsity Health, located in the United States. In reality,

these travelers actually had private insurance, and did not see these patients 

effectively disqualifying the travelers from the HRSA program. In addition to these

American travelers, the defendants also submitted HRSA reimbursement claims for

COVID-19 testing administered to insured students at high schools and universities

contracted by Vivature. Like the travelers, these insured students were ineligible for

reimbursements under HRSA.

29. Using the fraud proceeds, Bass and| paid| for his participation

in the scheme, paid themselves salaries and commissions, and purchased high-dollar luxury

items and real estate. In total, the defendants fraudulently obtained over $20 million from

the HRSA program.

Purpose of the Conspiracy

30. It was the general purpose of the conspiracy for Bass, | and

their co-conspirators to unlawfully and unjustly enrich themselves by obtaining

government funds from HRSA through materially false and fraudulent pretenses,

representations, and promises.

Manner and Means of the Conspirac 

31. The manner and means by which the defendants and their co-conspirators

sought to accomplish the purpose of the conspiracy included, among others, the following:

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a. The defendants and their co-conspirators arranged with representatives of

international resorts and educational institutions to provide COVID-19 billing

services;

b. The defendants and their co-conspirators communicated with each other via

phone, in-person meetings, and emails;

c. The defendants and their co-conspirators opened businesses to conduct the fraud

and opened bank accounts to receive, deposit, and transfer fraudulently obtained

reimbursements;

d. The defendants and their co-conspirators obtained individuals healthcare

information, including personal identifiers and health insurance infonnation,

without their knowledge;

e. The defendants and their co-conspirators knowingly submitted COVID-19 test

reimbursement claims to HRSA for insured individuals, despite knowing HRSA

only covered uninsured populations;

f. The defendants and their co-conspirators included materially false and

fraudulent representations on the HRSA claims, including falsely stating that

I was the servicing provider for COVID-19 testing and that the testing

took place in the United States;

g. The defendants and their co-conspirators paid for his role in the scheme,

including for the fraudulent use of Scott s NPI number and credentials on claims

paperwork;

h. The defendants and their co-conspirators paid the international resorts and the

educational institutions a portion of the reimbursements they received;

i. The defendants, using the fraudulently obtained proceeds, paid each other and

co-conspirators salaries and commissions and purchased high-dollar luxury

items, including multimillion-dollar real estate;

j. The defendants caused financial transactions that were processed by Veritex

Bank at locations in the Eastern District of Texas;

k. The defendants caused wire transmissions that affected interstate and foreign

commerce by using the financial banking system and causing the claims to be

submitted to HRSA.

Indictment

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Acts in Further of the Conspiracy

The Defendants9 Arrangem nts with the International Resorts

32. Between 2021 and 2022, many international resorts provided complimentary

COVID-19 tests for their guests. Vivature offered the resorts insurance billing and claims

services for COVID-19 testing, and in turn, shared revenue received from reimbursement

claims. Vivature entered into agreements with numerous inte ational resorts in the

Caribbean regarding this arrangement. For instance, on or about August 25, 2021, |

on behalf of Vivature, executed a COVID-19 billing contract with Grace Bay Resorts in

the islands of the Turks and Caicos, to pay the resort 60% of the gross collections received,

with Vivature retaining the remaining 40%.

33. Pursuant to the agreement, Vivature employee with initials F.J. emailed the

resort, copying Bass, and MH stating: "I am reaching out to y u n behalf of

Muzzy to inform you that our Medical Director, Dr. will be visiting the Grace Bay

Resort on Thursday, November 11th to see the CO VID testing operations and meet their

team. Dr. will also be visiting other companies in Turks and Caicos who are

currently working with us and have a contract with our company for a brief introduction &

talk more about our services related to COVID [.] 

Fraudulent COVID-19 Reimbursement Claims for C.D. and D.D.

34. In or around October 2021, an individual with initials D.D. and his spouse

C.D. visited the Shore Club Hotel, believed to be a Vivature-contracted resort, in the

Indictment

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islands of Turks and Caicos. At the time, C.D. and D.D. were both insured by BCBS Texas.

Shortly before leaving the resort, on or about November 13, 2021, hotel staff administered

complimentary COVID-19 tests so that C.D. and D.D. could provide documentation upon

their return to the U.S.

35. In an October 2023 interview with law enforcement agents, D.D. confirmed

the following regarding D.D. and C.D. s visit to the Shore Club Hotel: (1) although both

C.D. and D.D. were insured by BCBS Texas at the time of the visit, the hotel never

requested or obtained their insurance information; (2) the COVID-19 tests were

complimentary for guests; (3) C.D. and D.D. never met or interacted with an individual or

physician named and (4) C.D. and D.D. were never advised that their COVID-19

tests would be billed to the United States government or their private insurance.

36. Despite these facts, in or around December 2021, Vivature submitted

reimbursement claims for C.D. and D.D. s COVID-19 tests. For C.D., Vivature submitted

a claim to HRSA, which listed or Scott s entity Varsity Health as the servicing

provider, which included Scott s NPI and noted a place of service as a medical facility

within the United States. Meanwhile, Vivature submitted a separate claim for D.D. to

BCBS Texas, which also listed as the servicing provider. Based on these

representations, HRSA reimbursed Vivature $74.29 and BCBS Texas reimbursed Vivature

approximately $41.38. These payments were deposited in accounts owned and controlled

by Bass.

37. Vivature, at the direction of Bass and submitted similar claims to

Indictment

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HRSA for insured travelers retu ing from other international resorts, as well as for insured

student athletes at high schools and universities othei ise ineligible for HRSA

reimbursements. In most instances, or Scott s company Varsity Health was listed as

the servicing provider. Many of the resulting reimbursement deposits were processed at

Veritex Bank locations in the Easte District of Texas.

38. For Scott s assistance in the scheme, Bass, and Vivature agreed to

pay m 1% of net collections, and ultimately paid|| over $500,000 for his role in

this scheme and others. In exchange for the international resorts cooperation in Vivature s

scheme, Bass and others sent over $6.9 million to these resorts per their contracts.

39. During their scheme, the defendants submitted several thousand individuals

claims to HRSA and fraudulently obtained over $20 million in government funds.

All in violation of 18 U.S.C. § 1349.

Indictment

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COUNT THREE

Violation: 18U.S.C. § 1956(h)

(Conspiracy to Commit Money

Laundering)

40. Paragraphs 1 through 39 of this Indictment are realleged and incorporated by

reference as though fully set forth herein.

41. From in or around 2014 and continuing up through and including the date of

this Indictment, in the Eastern District of Texas and elsewhere, the defendants, Mouzon

Bass, III, and along with others both known and unknown

to the Grand Jury, did knowingly conspire with each other and with other persons known

and unknown to the Grand Jury to violate 18 U.S.C. § 1956 and 1957, to wit:

a. to knowingly conduct and attempt to conduct financial transactions affecting

interstate and foreign commerce, which involved the proceeds of a specified

unlawful activity, that is, wire fraud in violation of 18 U.S.C. § 1343 and

healthcare fraud in violation of 18 U.S.C. § 1347, with the intent to promote

the carrying on the same specified unlawful activity, and that while

conducting and attempting to conduct such financial transactions, knew that

the property involved in the financial transactions represented the proceeds

of some form of unlawful activity, in violation of 18 U.S.C. §

1956(a)(l)(A)(i);

b. to knowingly conduct and attempt to conduct financial transactions affecting

interstate commerce and foreign commerce, which transactions involved the

proceeds of specified unlawful activity, that is, wire fraud in violation of 18

U.S.C. § 1343 and healthcare fraud in violation of 18 U.S.C. § 1347,

knowing that the transactions were designed in whole or in part to conceal

and disguise the nature, location, source, ownership, and control of the

proceeds of specified unlawful activity, and that while conducting and

attempting to conduct such financial transactions, knew that the property

involved in the financial transactions represented the proceeds of some form

of unlawful activity, in violation of 18 U.S.C. § 1956(a)(l)(B)(i); and

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c. to knowingly engage and attempt to engage, in monetary transactions by,

through or to a financial institution, affecting interstate and foreign

commerce, in criminally derived property of a value greater than $10,000,

such property having been derived from a specified unlawful activity, that is,

that is, wire fraud in violation of 18 U.S.C. § 1343 and healthcare fraud in

violation of 18 U.S.C. § 1347, in violation of 18 U.S.C. § 1957.

42. Over the course of the schemes described in Counts One and Two, the

defendants engaged and participated in thousands of financials transactions with the

fraudulently obtained proceeds.

a. Certain transactions with fraudulently obtained proceeds were designed to

promote and encourage the continued participation of co-conspirators in the

scheme. For instance:

• Between 2018 and 2023, Vivature, at the direction of Bass and]

transferred at least $1 million to the Veritex 9062 account in the name of

| D.O. PC.

• Between 2016 and 2023, Wilson s BOA 9903 account received at least

$2.9 million from accounts controlled by Bass, including from the

Veritex 1200 account.

• In 2021 and 2022, Bass and g paid the international resorts at least

$6.9 million for the resorts role in the scheme from the Veritex 1200,

Veritex 1277, and Veritex 1278 accounts.

b. Other transactions with fraudulently obtained proceeds were intended to

disguise and conceal the true nature of the defendants fraudulent conduct.

For example:

• Between 2014 and 2023, the defendants used at least 200 different bank

accounts to set up regular transfers to/from umbrella accounts receiving

income from other sources.

c. Using the fraudulently obtained proceeds, the defendants also engaged in

dozens of personal transactions in excess of $10,000 to fund their lifestyle,

including the following:

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• On or about March 1, 2023, from the Veritex 1200 account, Bass made

an approximately $ 1 million payment toward the purchase of a yacht. On

or about June 1, 2023, from the same account, Bass made another

approximately $2.8 million payment toward the purchase of that same

yacht.

• On or about October 29,2020, from the Veritex 1278 account, Bass made

a payment of approximately $4.09 million on a residential property

located in Highland Park, Texas, valued at over $7 million.

• On or about February 17, 2022, from the Veritex 1277 account, Bass

made a payment of approximately $3.85 million toward the purchase of

a residential property in Mexico valued at over $11 million.

• On or about November 30, 2020, from the BOA 9903 account, 

wire transferred approximately $75,000 to a title company for the

purchase of a lake house located in Afton, Oklahoma valued at

approximately $500,000.

All in violation of 18 U.S.C. § 1956(h).

Indictment

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NOTICE OF INTENT TO SEEK CRIMINAL FORFEITURE

Pursuant to 18 U.S.C. 981(a)(1)(C) and 982(a)(1) and 28 U.S.C. § 2461

1. The allegations contained in Counts 1, 2, and 3 of this Indictment are

realleged and incorporated by reference as though folly set forth herein for the purpose of

alleging forfeiture to the United States of America of certain property in which the

defendant has an interest.

2. Upon conviction of any violation of 18 U.S.C. § 1349, the defendants,

Mouzon Bass, III, and shall forfeit to the United States any

property, real or personal, that constitutes or is derived from proceeds traceable to the

offense(s), pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c). The property,

which is subject to forfeiture, includes but is not limited to, a money judgment, and all

interest and proceeds traceable thereto, representing the proceeds of the offenses, for which

the defendants are jointly and severally personally liable.

3. Upon conviction of any violation of 18 U.S.C. § 1956, the defendants shall

forfeit to the United States any property, real or personal, involved in such offense, or any

property traceable to such property, pursuant to 18 U.S.C. § 982(a)(1), including a money

judgment representing fonds involved in the offense.

4. Pursuant to 21 U.S.C. § 853(p), as incorporated by reference by 18 U.S.C. §

982(b), if any of the forfeitable property, or any portion thereof, as a result of any act or

omission of the defendant:

a. Cannot be located upon the exercise of due diligence;

Indictment

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Case 4:24-cr-00007-ALM-AGD Document 9 Filed 01/10/24 Page 21 of 23 PageID #: 55
b. Has been tr nsferred, or sold to, or deposited with a third party;

c. Has been placed beyond the jurisdiction of the Court;

d. Has been substantially diminished in value; or

e. Has been commingled with other property which cannot be subdivided

without difficulty;

it is the intent of the United States to seek the forfeiture of other property of the defendants

up to the value of the above-described forfeitable properties, including, but not limited to,

any identifiable property in the names of the defendants, pursuant to 21 U.S.C.§ 853(p), as

incorporated by 28 U.S.C. § 2461(c).

5. By virtue of the commission of the offenses alleged in this Indictment, any

and all interest that the defendants have in the above-described property is vested in the

United States and hereby forfeited to the United States pursuant to 18 U.S.C. §

981(a)(1)(C), 18 U.S.C. § 982(a)(1), and 28 U.S.C. § 2461(c).

All pursuant to 18 U.S.C. § 981(a)(1)(C), 18 U.S.C. § 982(a)(1), and 28 U.S.C. §

2461(c) and the procedures set forth at 21 U.S.C. § 853, as made applicable through 18

U.S.C. § 982(b)(1).

A TRUE BILL

DAMIEN M. DIGGS

UNITED STATES ATTORNEY

ANAND VARADARAJAN

Assistant United States Attorney

GRAND JURY FOREPERSON

Date

Indictment

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Case 4:24-cr-00007-ALM-AGD Document 9 Filed 01/10/24 Page 22 of 23 PageID #: 56
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

UNITED STATES OF AMERICA § SEALED

v.

MOUZON BASS, III (1)

a/k/a Muzzy 

§

§

§

§

§

§

§

Case No. 4:24 "7

Judge

JAN 1 0 202 

Clerk U.S, District Court

exas Eastern

NOTICE OF PENALTY

COUNT ONE

Violation: 18 U.S.C. §§ 1349 (Conspiracy to Commit Wire Fraud)

Penalty: Not more than 20 years imprisonment, a fine not to exceed $250,000,

or both; supervised release of not more than 3 years.

Special

Assessment: $100.00

COUNT TWO

Violation: 18 U.S.C. §§ 1349 (Conspiracy to Commit Healthcare Fraud)

Penalty: Not more than 10 years imprisonment, a fine not to exceed $250,000,

or both; supervised release of not more than 3 years.

S ecial

Assessment: $100.00

COUNT THREE

Violation: 18 U.S.C. § 1956(h) (Conspiracy to Commit Money

Laundering)

Penalty: Not more than 20 years imprisonment, a fine not to exceed

$250,000, or both; supervised release of not more than 3 years.

Special

Assessment: $100.00

Notice of Penalty

Case 4:24-cr-00007-ALM-AGD Document 9 Filed 01/10/24 Page 23 of 23 PageID #: 57