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DWC Posts Revised Copy Service Regs for Public Comment

Following a public hearing on July 1 and a review of comments from a previous 15-day public comment period, the Division of Workers’ Compensation (DWC) has made additional revisions to its Copy Service Fee Schedule regulations. Members of the public are invited to present written comments regarding the proposed modifications to dwcrules@dir.ca.gov until 5 p.m. on Saturday, November 8. Proposed revisions include:

1) Reinstating authorizations into the fee schedule to avoid a loophole that would have allowed for billing outside of the schedule. Additionally, authorizations have been defined including stating the specific uses and limitations on the type of information to be disclosed and a specific date after which the provider is no longer authorized to disclose the information.
2) Clarifying the regulations regarding records obtained from the Workers’ Compensation Insurance Rating Bureau (WCIRB) and Employment Development Department (EDD). Claims adjusters will not be liable for subpoenaed records from the WCIRB and EDD when such records can be obtained without a subpoena at lower cost. Twenty dollars is allowed for records from EDD and $30 allowed for records from WCIRB.
3) Replacing the requirement that professional photocopier certificates be attached to each bill with supplying professional photocopier registration numbers.

The public can access WCIRB coverage information for employers for the past five years for free online. For coverage information beyond the past five years, the WCIRB charges $10 per year of coverage requested by way of a Coverage Research Service request. Over the last several years, the WCIRB has seen a marked increase in the number of subpoenas received requesting coverage information for cases before the WCAB. The number jumped from a low of approximately 1,300 in 2010 to a record high of 4,000 in 2013, 90% of which were to determine the identity of the insurer for a specific employer as of a specific date and which is readily available to the public at no cost on the WCIRB’s coverage website. The impact of the cost of these subpoenas on the system is a concern, particularly in view of the comment in Martinez v. Terrazas (2013) 78 Cal. Comp. Cases 444, 447, fn. 3 (Appeals Board en banc) that “in the context of a subpoena to recover costs associated with a subpoena to the WCIRB, the copy service would need to establish the expenses were incurred to prove or disprove a contested claim and that they were reasonable and necessary at the time incurred.” In that case, the parties participated in an agreed medical evaluation before the subpoena was served on the WCIRB requesting coverage information. Consequently, it appeared to the court that the identity of the employer’s insurer had been identified prior to the subpoena for coverage information being requested and was therefore not necessary.

In regards to EDD records, Unemployment Insurance Code section 2111 provides that EDD is only authorized to provide EDD records only if EDD has an existing lien in the WCAB case. If EDD does not have a lien, then no records can be provided, even if EDD receives a subpoena. If EDD has a lien, the records can be obtained for free upon request from the injured worker’s attorney. Attorneys can also request records with an Authorization signed by the injured worker for $15.

Pacific Hospital CEO Sues Plaintiff Attorneys in $50 Million Defamation Case

Michael D. Drobot, Chief Executive Officer of Pacific Hospital of Long Beach, filed a $50 million dollar defamation lawsuit against a group of plaintiff’s attorneys who he alleges have falsely claimed in broadcast comments that he and Pacific Hospital of Long Beach directed surgeons to install “counterfeit” screws in “thousands” of spinal-surgery patients.

The lawsuit, filed in Orange County Superior Court alleges that lawyers Brian Kabatek and Robert Hutchinson and the law firms of Kabateck Brown Kellner, Cotchett Pitre and McCarthy and Knox Ricksen made false claims in press statements “in an effort to disparage Michael D. Drobot and Pacific Hospital of Long Beach’s good name and reputation, and disrupt business operations for their own personal benefit.”

According to his press release Drobot claims “I never envisioned filing a lawsuit against a group of attorneys,,” said Drobot. “But these allegations are malicious and, most importantly, patently false. Not only do they portray me as someone I am not, but they needlessly create incredible anxiety for hundreds of former patients at Pacific Hospital. We did not compromise patient care at PHLB.”

The lawsuit alleges that Kabateck, during a July television interview with Fox 11, made multiple false and defamatory statements about “counterfeit” and “unsterilized” screws used on a patient during two 2010 surgeries. Several weeks later, attorney Hutchinson allegedly made many of the same defamatory remarks in a radio interview on CBS 2. The lawsuit alleges that the lawyers made the remarks as a solicitation for patients to join in their pending lawsuits against Drobot and Healthsmart Pacific, Inc. Among their claims: that Michael D. Drobot bribed government officials with money and prostitutes to sell and install the counterfeit screws into patients.

Drobot blasted the defamatory remarks in his defamation lawsuit, affirming under oath in a verified complaint that he and Pacific Hospital of Long Beach “never purchased or used any non-FDA-approved screws or other related parts made with non-FDA-approved materials for use in PHLB spinal surgeries.”

According to Drobot “Defendants made up the aforementioned false and defamatory statements broadcast on television, radio and Internet out of whole cloth,” the lawsuit alleges. “Ironically, Defendants’ false and defamatory statements likely will cause many PHLB spinal surgery patients to request and possibly undergo wholly unnecessary spinal surgeries simply to determine whether they, too, have received ‘counterfeit’ screws from PHLB.”

In February 2014, Drobot pled guilty to government allegations that he paid kickbacks to surgeons for referring patients to Pacific Hospital of Long Beach. The criminal case did not include allegations of providing counterfeit parts or devices to patients.

Hutchinson, in an interview with the Long Beach Press Telegram said the lawsuit is an attempt to intimidate him and other attorneys named, and to intimidate patients from coming forward in a pending lawsuit against Drobot and the company that previously owned Pacific Hospital. “(Drobot is) an admitted felon,” Hutchinson said. “This raises the issue of how can we defame someone when their own actions have tainted them far worse than any comments. He should know it’s not going to work.” The lawsuit is characteristic of a Strategic Lawsuit Against Public Participation, commonly known as SLAPP, used to try and censor, intimidate or silence critics by hampering them with legal costs until they abandon their criticism, Hutchinson said.

Drobot, 69, of Corona del Mar, was charged by the U.S. Attorney’s Office with orchestrating a conspiracy from 1997 to 2013 in which tens of millions of dollars in illegal kickbacks were paid to doctors, chiropractors, marketers and others who referred patients to the former Pacific Hospital for spinal surgery. Prosecutors said that Drobot also paid $28,000 in bribes to state Sen. Ron Calderon, D-Montebello, to support legislation delaying or limiting changes in workers’ compensation laws that would have directly affected Drobot’s scheme. The hospital submitted more than $500 million in fraudulent bills between 2008 and last year. Much of the total was paid by the California workers’ compensation system, according to the U.S. Attorney’s Office. Drobot pleaded guilty in April to counts of conspiracy and payment of kickbacks for his activities in the scheme, and he faces 10 years in prison when he is sentenced in October 2015.

LA Probation Officer Arrested for Altering RTW Slip

Cynthia Wesley, 46, of Claremont, was arrested by Los Angeles Sheriff’s Deputies on two felony counts of insurance fraud after allegedly altering workers’ compensation documents and illegally collecting $1,036 in disability payments.

“Falsifying documents to receive unearned disability payments is a serious offense,” said Commissioner Dave Jones. “The fact that Wesley was a trusted member of law enforcement adds insult to injury in this case. We will investigate and bring to justice anyone that commits insurance fraud, regardless of where they are employed.”

An investigation by the California Department of Insurance Fraud Division revealed Wesley, a Los Angeles probation officer, filed an altered workers’ compensation return to work slip. Wesley submitted a workers’ compensation form extending her total temporary disability period. The same altered documents were submitted to her supplemental disability insurance company.

Wesley was double dipping and received three months of fraudulent disability benefits from the Los Angeles County Probation Department and her supplemental disability insurance policy. Wesley’s insurer was unaware of the over payment and the altered documentation until notified by department investigators.

If convicted Wesley faces a max sentence of five year, eight months in county jail.

Security Firm With Statewide Government Contracts Fakes Comp Insurance

In sweeping charges alleging public contract fraud, forged real estate deals and identity theft stretching from Alameda to Orange counties, authorities arrested a Black Muslim minister, his mother and five others, saying they ran a wide-ranging scam through a private security firm, known as Black Muslim Temple (BMT) International Security Services, that falsely claimed its guards were retired Navy SEALs and its leader a former FBI agent.

Alameda County District Attorney Nancy O’Malley said the charges involved “not only large-scale bid fraud victimizing local communities and cities and counties around the state, but also real estate fraud, insurance fraud, bankruptcy fraud, income tax evasion and the exploitation of workers by evading workers’ compensation insurance and payroll.” O’Malley said the group led “an organized and sophisticated criminal enterprise conducting an extraordinary variety of fraudulent activities.” The charges, detailed in a 118-page affidavit, allege the firm faked insurance and state license documents and made fanciful claims of expertise it did not possess.

O’Malley’s staff and the state Department of Consumer Affairs began investigating BMT in March.The Port of Oakland that month was in the final stages of agreeing to terms with the company when it terminated negotiations, citing reporting by the San Jose Mercury News on the bogus credentials. The city of Oakland also backed off on a proposal to award the firm part of a contract to guard City Hall. The Housing Authority of the city of Los Angeles rescinded a BMT contract after the investigation by the newspaper.The group sought and at times obtained lucrative contracts with Los Angeles agencies, Alameda County, Vallejo, Oakland, the Port of Oakland and Newport Beach.

Alameda County canceled its contract with the firm back in 2012 after a BMT guard beat up a guard from a rival company on the first day of the county contract to protect a public works building in Hayward. A lawsuit by the injured guard, Robert Chamberlin, helped expose the fraudulent credentials that government procurement officials had failed to vet when awarding the contracts. Upon learning that BMT was still listing it as its insurance carrier, the insurance company in that lawsuit contacted district attorney’s investigators to alert them to the discrepancy. The policy had been canceled in 2009 for non-payment of premiums, according to the complaint..

Those arrested include Black Muslim minister Dahood Sharieff Bey, 42, and his mother, Rory Parker, 63, Basheer Fard Muhammad, 62, Qadirah Najeebah Bey, 39, Jameelah Aasma Muhammad Bey, 39, Billie Latrice Poindexter, 33, and Ira Barnard Dickerson Jr., 53. among those who were arrested. District attorney’s inspector Patrick Johnson requested in an affidavit that the seven defendants be denied bail because he suspects their means of income for years has been fraudulent.

A spokesman for the state Department of Consumer Affairs said it should not be blamed. BMT had fraudulently taken over the security license of a retired Oakland police officer who had moved out of state. “We had no way of knowing the license had essentially been hijacked,” said the spokesman, Russ Heimerich.

DWC Seeks Nominations for Community Service Award

The Division of Workers’ Compensation (DWC) is now accepting nominations for its annual Carrie Nevans community service awards which will be presented at the 22th annual educational conference luncheons in February 2015.

The awards, which began in 2010, were renamed in memory and honor of Carrie Nevans, the acting administrative director, who passed away in 2011. “This award is about recognizing and acknowledging those extraordinary individuals whose efforts, often unsung, do so much to benefit the comp system for the betterment of employees and employers,” said DIR Director Christine Baker. DWC is a division of DIR.

Nominations should be made for those individuals who have made a significant contribution to the betterment of the workers’ compensation community in the highest professional manner. DWC will honor the Southern California recipient in Los Angeles and the Northern California recipient in Oakland during an award ceremony at the educational conference luncheons.

To submit your nominations, please complete the DWC nomination form and send to Wendy So at wso@dir.ca.gov no later than January 5, 2015.

Report Claims Ebola Pandemic Poses Low Risk For Comp Carriers

The primary impact of the Ebola epidemic “crisis” on U.S. property and casualty insurers will be on companies writing workers compensation insurance, according to a new study by the Insurance Information Institute. In a paper written by Dr. Dr. Steven Weisbart, senior Institute vice president and chief economist, said the WC category will likely be most affected because health-care workers could be most directly exposed (as happened in Texas and in several African countries). Other possible effects might be on various liability insurance lines, such as general liability, directors and officers liability and medical malpractice liability, Weisbart said in his paper. Weisbart said that WC would be primarily impacted because it pays for the cost of medical care and lost income for people who become ill in the course of their work, and pays death benefits if they die from a work-related cause.

“As with life insurance, it is unlikely that many workers in the main affected African countries have workers compensation-type coverages,” he said. Citing the latest Swiss Re report, Weisbart said that the level of premiums per capita for all non-life insurance coverages combined (not just WC) in the three most-affected countries “is so low as to not be listed.”

In the United States, by contrast, Weisbart said, WC coverage is nearly universal, but the likelihood of claims is low, assuming that employers and their workers take CDC-recommended precautions. He also notes that, as with life insurance coverage, “reinsurance will help mitigate the financial effect of a surge in claims, which are likely to be very costly in the event of actual work-related infections.” In his report, Weisbart said that, “at this stage,” it is impossible to forecast the precise number of such claims or the amounts of damages that might be sought.

“That said, assuming the Center for Disease Control’s protocols are successfully followed, the number of Ebola cases should be small, thereby limiting the number and likelihood of tort actions that can impact various liability coverages,” Weisbart concluded.

As for the total world impact, Weisbart said that as of Oct. 10, the Ebola virus has infected at least 8,399 people and killed 4,035, according to the World Health Organization. This includes 4,762 confirmed cases, 2,196 probable cases and 1,652 suspected cases. He said that as of Oct. 10, all but four of the cases were in four countries in Africa (Guinea, Liberia, Sierra Leone, and Nigeria). One was in Senegal, one in Spain, and (as of Oct. 12) two in the United States.

There are five known strains of the Ebola virus, Weisbart said in his study. The one causing the illness and deaths noted above is the Zaire strain, which was identified in 1976, he said.Weisbart also said that there is currently no cure and no vaccine for this virus. Treatment is isolation (to prevent spread) and focus on symptoms—mainly dialysis and fluids to prevent dehydration and reduce fever. He also said that the mortality rate of infected people to date is roughly 50 percent.

Orders For Witness “Hits” Adds 10 Counts to 50 Count Fraud Case

A Contra Costa County jail inmate added ten counts to a 50-charge indictment after he allegedly tried to order the killings of witnesses set to testify against him in a workers’ compensation fraud case.

A grand jury voted to indict defendant Charles Waldo with nine counts of solicitation to commit murder and one count of conspiracy to commit murder. The indictment alleges that while serving time in custody at the Martinez Detention Facility, the defendant solicited and conspired with other inmates to arrange the killing of nine different witnesses that were set to testify against him at an upcoming trial. These ten new charges will be added to the fifty charges the defendant currently faces.

The investigation of Mr. Waldo began when the Auto Insurance Fraud Unit of the Contra Costa County District Attorney’s Office received information about a fraudulent auto insurance claim related to an automobile arson. With the assistance of the Contra Costa County Fire Protection District, the investigation expanded and soon involved multiple fraudulent insurance claims related to the arsons and vandalisms of five cars over a five year period. The loss from these fraudulent claims exceeds $100,000.

The investigation also uncovered a series of crimes that occurred at a local business. Mr. Waldo had worked at the business and eventually talked the owner into making him the manager. Once he was in charge of the business it is alleged that Mr. Waldo embezzled over $100,000 from the business and that he stole property from the business, including a $38,000 generator. As the manager, Waldo was able to force out other employees and replace them with his associates. He directed these associates to commit additional crimes while working for the company such as the theft of recyclable metals and the theft of an electrical transformer. He also had his associates help construct a 2000 square foot addition to his Pittsburg, CA home. This work occurred while his associates were being paid by, and supposed to be working for, the victim company.

Investigators from the California Department of Insurance established that Waldo was also committing Workers’ Compensation Insurance fraud and tax code violations. Investigators from the Employment Development Department discovered that Mr. Waldo claimed unemployment insurance benefits for a year after being fired from the victim business. Mr. Waldo claimed these benefits despite the fact that he had secured other employment.

The new allegations came to light when a witness was alerted that a “hit” had been put out on him. The District Attorney’s office promptly started an investigation which led to two witnesses and one document. The document was a hit list that included nine names, the order in which they were to be killed, and suggested methods by which the murders were to occur. The methods included staged car accidents, drug overdoses and robberies that had “gone bad”.

The charges carry a maximum penalty of 25 years to life in jail.

SCIF Obtains Terminating Sanctions in Discovery Dispute With Employer

In 2004, the State Fund issued a workers’ compensation policy to a construction company doing business as L and M Construction. In May 2005, it audited the employer to calculate the final premium due for the policy year resulting in a claim by the SCIF for $497,265.48 premium due under the 2004 policy. SCIF was unsuccessful in obtaining payment, thus it assigned the debt to a collection company that sued the employer to recover.

In July 2007, SCIF propounded its first discovery set, to the employer which included form interrogatories, requests for admission, and requests for production of documents. The interrogatories were form interrogatories approved for use in civil cases. The employer’s response to each of these requests was the same: “Overbroad, overburdensome, vague and ambiguous, irrelevant, seeks information not reasonably calculated to lead to the discovery of admissible evidence.” A meet and confer process resulted in supplemental responses in September 2007. Appellant denied several requests for admission, provided non-committal answers to the rest, and added objections to requests that required admitting dates or verifying documents. This was the beginning of a discovery war between the parties that became quite acrimonious. For example, during one deposition, the employer’s attorney ridiculed the questions and then abruptly ended the deposition.

There were numerous motions by SCIF to enforce discovery. In August 2008, the court denied SCIF’s motion for terminating sanctions, but awarded $3,000 in additional sanctions on the ground that the employer and its counsel willfully violated the court’s order by failing to attend the deposition and produce documents in a timely fashion, by “stonewalling,” and walking out of the deposition. It ordered that all discovery matters be heard by the earlier-appointed discovery referee. Yet the employer “continued to evade identifying specific documents and potential witnesses in support of its denial that it owed any money.” The SCIF again filed discovery motions and requests for terminating sanctions which the referee recommended. The referee found appellant’s discovery responses continued to be dilatory, evasive, lacking a factual basis, and thus violative of the prior order. The trial court granted terminating sanctions. The sanctions were affirmed in the unpublished case of State Compensation Fund v. Notis Enterprises.

Under the Civil Discovery Act (§ 2016.010 et seq.), courts may impose monetary, issue, evidence, terminating, and contempt sanctions for “misuse of the discovery process.” Misuses of the discovery process include: (1) “[f]ailing to respond or to submit to an authorized method of discovery”; (2) “[m]aking, without substantial justification, an unmeritorious objection to discovery”; (3) “[m]aking an evasive response to discovery”; (4) “[d]isobeying a court order to provide discovery”; (5) “[m]aking or opposing, unsuccessfully and without substantial justification, a motion to compel or to limit discovery”; and (6) “[f]ailing to confer in person, by telephone, or by letter with an opposing party or attorney in a reasonable and good faith attempt to resolve informally any dispute concerning discovery . . . .” (§ 2023.010, subds.(d)-(i).) The trial court may impose terminating sanctions, such as striking a party’s pleadings and rendering a judgment by default against the party, for willful violations preceded by a history of abuse, where “the evidence shows that less severe sanctions would not produce compliance with the discovery rules . . . .”

“The record supports the referee’s finding that appellant and its counsel repeatedly violated section 2023.010 by failing to respond to discovery, making unmeritorious objections and evasive responses, disobeying court orders, opposing motions to compel without substantial justification, and failing to confer in good faith. The referee properly considered appellant’s ongoing failure to comply with discovery requests and court orders.”

Although this case was in the Superior Court, the same rules apply before the WCAB. Labor Code section 5710 provides that the deposition of witnesses in workers’ compensation cases are “to be taken in the manner prescribed by law for like depositions in civil actions in the superior courts of this state….” Thus this case is a good overview of the enforcement mechanisms available when a litigant unreasonable interferes with appropriate discovery.

Feds Now Target Executives in Healthcare Fraud Cases

Federal authorities are ramping up efforts to crack down on healthcare fraud, announcing plans to prosecute top executives at hospitals and other organizations involved with fraud – and target other fraudsters as well.

Leslie Caldwell, assistant attorney general for the criminal division at the Department of Justice, said in a recent presentation: “We are stepping up our prosecutions of corporations involved in healthcare fraud. Corporate healthcare fraud cases are a natural fit for us in light of our healthcare fraud expertise and our prosecutions of corporate cases in the financial fraud and foreign bribery arenas. We have numerous ongoing corporate healthcare fraud investigations, and we are determined to bring more.”

Healthcare attorney Peter Zeindenberg, a partner in the Washington officer of the law firm Arent Fox, says that the Justice Department’s warning is aimed at top executives at hospitals and other healthcare organizations where fraudulent activities, ranging from false Medicare billing to illegal kick-backs, are taking place.

For the most part, fraud-related cases against healthcare organizations have often ended up with restitution or settlements, not criminal prosecutions of executives that involve prison time, he says. “Companies have been able to resolve these cases by entering into non-prosecution or deferred prosecution agreements and leave individual executives untouched,” he says. In large part due to public pushback on corporate executives too often getting passes, the Justice Department is sending out signals that it “wants to serve up executives on a silver platter,” for misconduct that includes healthcare fraud, Zeidenberg says. But the attorney says he’s “somewhat dubious” that will actually happen.
OIG Crack Down

In addition to the Justice Department’s efforts, the Department of Health and Human Services’ Office of Inspector General is also stepping up its fraud crackdown activities. OIG often gets involved in criminal cases against owners of small medical companies or clinics – or individual physicians – where false billing and identity fraud is alleged, says Scott Lampert, assistant special agent in charge of the HHS OIG’s New York Regional Office, Office of Investigations. “Cases involving identity theft are a growing problem,” he tells Information Security Media Group. “Medical ID numbers are an ATM card to fraudsters.”

One of the largest “and most blatant” such cases to date was the prosecution and conviction of the owner of a Long Island, N.Y., medical supply company who posed as a clinician when visiting nursing homes. Helene Michel entered nursing homes pretending she was a clinician and stole information from patient charts, submitting more than $7 million in fraudulent Medicare billing using those records, Lampert says. In April 2013, Michel was convicted on charges of healthcare fraud and wrongful disclosure of individually identifiable health information. She was sentenced to 12 years federal prison time and ordered to pay more than $4.4 million in restitution. Her husband and co-conspirator, Etienne Allonce, for the second year in a row tops the HHS OIG’s “most wanted” fugitive list. Joseph Giambalvo, special agent with the HHS OIG’s New York regional office, tells ISMG that Allonce is believed to be in Haiti. “We have an arrest warrant out for him,” he says. The fraud case involving Allonce and Michel “is one of the largest medical identity theft cases we’ve had, and the first prosecution in the Northeast of a HIPAA case for the misuse of personal health information for profit,” Lampert says.

Two Dozen Civil Suits Filed Against Drobot Related Local Hospitals

More than two dozen lawsuits were filed in Los Angeles Superior Court against a former hospital executive and a collection of his business partners that allege the group was behind counterfeit screws and hardware used in spinal surgeries at various Southern California hospitals.The lawsuits claim that unknowing patients underwent spinal surgeries with doctors who benefited financially for using certain hardware – allegedly made at an auto shop in Temecula – and for performing surgery at certain hospitals. The former hospital executive, Michael Drobot, was indicted in February for his role in bribing a state senator to protect the $500 million insurance fraud scheme he was using to bilk the state’s workers compensation fund. Drobot agreed to a plea deal and is cooperating with federal law enforcement.

Also named in the lawsuit are Pacific Hospital of Long Beach, Riverside Community Hospital, Spinal Solutions, Orthopedic Alliance, Crowder Machine and Tool Shop and doctors Jack Akmakjian, Sunny Uppal and Khalid Ahmed. Attorneys told KPCC they have received hundreds of calls from people concerned they may have the fake parts, adding that they are going through each case to figure out if those former patients may have been impacted by the scheme. Drobot’s operation included bribes for doctors and others who referred patients to Drobot’s hospital, used hardware distributed by his partners, and inflated prices for medical hardware. The lawsuits say the victims are “among thousands of spinal fusion surgery patients in Southern California and elsewhere who [have] such counterfeit, non-FDA approved medical devices implanted into their bodies as a consequence of the systematic pattern of fraud and deceit.” According to the lawsuits, Spinal Solutions, a distributor out of Murrieta, was behind the manufacture of the fake screws provided to hospitals and doctors who were also part of the scheme.

Drobot’s attorney, Terree Bowers, said the lawsuits are “scare tactics” and that they are “reprehensible.” He further denies any counterfeit parts were used at Drobot’s hospital. “There is absolutely no indication or evidence that Spinal Solutions … screws were ever used at Pacific Hospital,” he said. “It is false and patients who went to that facility do not have to be alarmed.” Bowers said the federal indictment does not include any accusations regarding fake screws, and he said his own investigation into hospital records do not indicate counterfeit screws were used there. “They are creating fear in patients that have absolutely no reason to afraid,” he said.

Last summer, the State Insurance Commission Fund filed a lawsuit against Drobot and his son under the state’s racketeering laws. It alleges the Drobots created shell companies that supposedly made spinal hardware and billed for it at much higher rates than what it costs.

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