Ahmed Et Al Superseding Indictment
Ahmed Et Al Superseding Indictment
Ahmed Et Al Superseding Indictment
any one year period, including from at least 2018 through at least 2022, benefits in
Hospital A issued payments to vendors that provided goods and services to the
between in or around December 2017 and March 26, 2021, serving as the hospital’s
Chief Operating Officer (COO) and, between in or around July 2018 and the end of
his employment, as the hospital’s Chief Financial Officer (CFO). As CFO, AHMED
was a senior executive responsible for managing Hospital A's finances, including its
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second in command to the Chief Executive Officer and was responsible for the
hospital's day-to-day operations. AHMED was also the owner and operator of a
AHMED maintained bank accounts at Bank B in his name and the names of entities
he controlled.
and operated multiple medical supply and service entities, including American
maintained bank accounts at Bank A in his name and the names of entities he
controlled.
around March 2022, and continued as an agent of Hospital A until on or about April
approving invoices and bills for payment; submitting requests for vendor payments;
paying invoices and bills; requesting, generating, issuing and printing checks for
payment for goods and services; and processing credit card payments for goods and
services. BERGDAHL maintained bank accounts at Bank C in her name and the
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f. Employee B was employed by Hospital A in its Accounts Payable
who was the owner and operator of Vendor C, an entity registered in Texas.
least in or around May 2022, in the Northern District of Illinois, and elsewhere,
ANOSH AHMED,
SAMEER SUHAIL, and
HEATHER BERGDAHL,
defendants herein, together with others known and unknown to the Grand Jury,
to obtain money and funds owned by and under the custody and control of, Hospital
3. It was part of the scheme that AHMED, SUHAIL, and BERGDAHL (the
“defendants”), for the purpose of obtaining more than approximately $15 million in
and submitted to Hospital A requests for vendor payments, which requests falsely
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and fraudulently, among other things: (1) represented that Hospital A owed each
purported vendor payment for goods and services that Hospital A had in fact not
received, (2) directed those payments to entities controlled by one or more of the
defendants, and (3) caused Hospital A to issue payments consistent with the requests
4. It was further a part of the scheme that, in order to conceal the scheme
and other documents, which contained false information about goods and services
and Individual D, and false information about goods and services purportedly
provided to Hospital A.
5. It was further part of the scheme that SUHAIL and AHMED created
numerous additional names for existing companies (“doing business as” names, or
“DBA” names) that they respectively owned and controlled and added those
additional names to bank accounts that each opened and controlled, knowing that
they would submit, and cause to be submitted, false and fraudulent payment requests
to Hospital A in the names of those companies. SUHAIL and AHMED created these
additional company names to conceal their association with the companies and the
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fraudulently obtained payments that they would receive from Hospital A.
Specifically:
and bank accounts that he owned and controlled, including: Vitality Medical
the name of an existing entity which he controlled, to which he added to the accounts
Promotions Ltd., Illinois Biotech Co., and Midwest Medical Supplies (together, the
6. It was further part of the scheme that AHMED and BERGDAHL caused
“Mideast Contractors,” knowing that they would submit, and cause to be submitted,
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false and fraudulent payment requests to Hospital A in the name of Mideast
Mideast Contractors for the purpose of concealing from Hospital A Individual D’s
association with any requests for payment and invoices submitted to Hospital A for
accounts in the names of two legitimate Hospital A vendors (Vendors A and B) and
registered a sole proprietorship in Texas under the name of each Hospital A Vendor,
knowing that she would submit false and fraudulent payment requests to Hospital A
in the names of those legitimate vendors and thereafter deposit those payments into
bank accounts that she controlled. BERGDAHL opened these bank accounts in the
names of Vendors A and B because she wanted to conceal her association with the
fraudulently obtained proceeds and to make Hospital A believe that those payments
Suhail Payments
2020 and February 2022, SUHAIL and BERGDAHL prepared and submitted to
payments to the Fictitious Suhail Vendors, which requests falsely and fraudulently
represented that each Fictitious Suhail Vendor had provided goods or services to
Hospital A. SUHAIL and BERGDAHL knew at the time that the Fictitious Suhail
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Vendors had not provided any goods or services to Hospital A. As a result of these
Inc.;
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r. approximately $867,574 to Allied Protective Equipment;
9. It was further part of the scheme that, between in or about April 2020
and March 2021, AHMED, SUHAIL, and BERGDAHL prepared and submitted to
knew at the time that the SUHAIL-owned companies identified in the invoices had
not provided Hospital A the goods or services identified in those invoices and were
not entitled to the requested payments. As a result of their submission of these false
BERGDAHL caused Hospital A to transfer more than approximately $3.6 million into
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b. approximately $2.7 million to Shenzhen Medical Supplies.
10. It was further part of the scheme that, in or around April 2021 and in
Medical Supplies, AHMED and BERGDAHL falsely represented that Shenzhen had
auditors. AHMED and BERGDAHL knew at the time that Shenzhen had not
11. It was further part of the scheme, between in or about May 2021 and
approximately $34,000 in credit card charges made for the purchase of four copier
machines and related products from Copier Company A, which requests falsely and
fraudulently represented that BERGDAHL had purchased the copier machines and
related products for the benefit of Hospital A. AHMED, SUHAIL and BERGDAHL
knew at the time that BERGDAHL had in fact purchased the copier machines and
related products for the personal use and benefit of SUHAIL and AHMED and had
company for copiers and related products provided to AHMED and SUHAIL.
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Ahmed Payments
12. It was further part of the scheme that, between on or about June 11,
2021, and November 29, 2021, AHMED and BERGDAHL prepared and submitted to
requests for payments to the Fictitious Ahmed Vendors, which requests falsely and
fraudulently represented that each Fictitious Ahmed Vendor had provided goods and
services to Hospital A. AHMED and BERGDAHL knew at the time that the Fictitious
Ahmed Vendors had not provided any goods or services to Hospital A. As a result of
transfer more than $486,000 into various AHMED-controlled bank accounts, by way
13. It was further part of the scheme that, between on or about August 14,
2020, and on or about December 31, 2021, AHMED and BERGDAHL prepared and
Mideast Contractors. AHMED and BERGDAHL knew at the time that Mideast
Contractors had not provided any goods or services to Hospital A, and instead knew
that Individual D was performing handyman services for AHMED at the Ahmed
Individual D.
Bergdahl Payments
14. It was further part of the scheme that, between in or about October 2020
requests for payments to Vendors A and B, which requests falsely and fraudulently
represented that Hospital A owed each vendor money for goods or services.
BERGDAHL knew at the time that Vendors A and B had not requested and were not
owed the requested amounts and that she intended to keep the requested payments
and B, including:
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Vendor C Payments
15. It was further part of the scheme that, between on or about May 1, 2020,
and on or about March 15, 2021, BERGDAHL prepared and submitted to Hospital A,
Vendor C for services purportedly provided to Hospital A, which requests falsely and
fraudulently represented that Vendor C was owed money for services that Vendor C
already had been paid for. BERGDAHL knew at the time that Hospital A had already
issued payment for the services on which each request was based and that Vendor C
was not entitled to additional payment. As a result of these false and fraudulent
duplicate payments into Individual C-controlled bank and credit accounts, on behalf
of Vendor C.
16. It was further part of the scheme that, to conceal the duplicate payments
namely, monthly payments by way of both Hospital A checks and payments to a credit
17. It was further part of the scheme that, to conceal the duplicate payments
the expenses as incurred under Hospital A’s general business account when
(c) misrepresented the total amount of Hospital A money paid to Vendor C when
questioned about the payments by Hospital A’s general counsel, disclosing only the
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total amount of Hospital A checks issued to Vendor C in 2021 and nothing about the
checks issued in 2020 or the monthly credit card payments made to the company in
18. It was further part of the scheme that, through the submission of the
false and fraudulent vendor payment requests, AHMED, SUHAIL, and BERGDAHL
proceeds from Hospital A into bank accounts that the defendants controlled, which
proceeds the defendants obtained for their personal use and benefit.
19. It was further a part of the scheme that through the submission of false
transfer hospital proceeds into bank accounts controlled by Individuals C and D, and
20. It was further part of the scheme that AHMED, SUHAIL, and
BERGDAHL transferred proceeds of the scheme to each other and to their associates,
including Employee A.
21. It was further part of the scheme that AHMED, SUHAIL, and
concealed, and hidden, the existence and purpose of the scheme and the acts done in
22. On or about the dates set forth below, in the Northern District of Illinois,
Eastern Division, and elsewhere, the defendants, as set forth below, for the purpose
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of executing the above-described scheme, knowingly caused to be transmitted by
signals, listed below, each such writing, sign, and signal constituting a separate
count:
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Count Defendants Date Writing, Sign, and Signal
Five SAMEER October 9, a wire transmission of
SUHAIL 2020 approximately $48,930.20 from
and Bank D to Bank A, processed
HEATHER through servers located outside the
BERGDAHL state of Illinois, which funds
represented the proceeds of a
Hospital A check issued to Unified
Wellness Specialists
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Count Defendants Date Writing, Sign, and Signal
Ten ANOSH AHMED June 15, 2021 a wire transmission of
and approximately $54,888.99 from
HEATHER Bank D to Bank B, processed
BERGDAHL through servers located outside the
state of Illinois, which funds
represented the proceeds of a
Hospital A check issued to
Midwest Medical Supplies USA
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Count Defendants Date Writing, Sign, and Signal
Fourteen HEATHER March 7, a wire transmission of
BERGDAHL 2022 approximately $8,678 from Bank D
to Bank C, processed through
servers located outside the state of
Illinois, which funds represented
the proceeds of a Hospital A check
issued to Vendor A
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COUNTS FIFTEEN THROUGH TWENTY-FOUR
District of Illinois, and elsewhere, the defendants, as set forth below, each being an
authority knowingly converted to the use of a person not the rightful owner, and
intentionally misapplied, property worth at least $5,000 and owned by and under the
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Count Defendants Date Payment
Twenty HEATHER October 9, approximately $48,930.20
BERGDAHL 2020 through a check made payable to
Unified Wellness Specialists
SAMEER SUHAIL,
defendant herein, did knowingly aid and abet the offenses set forth in Counts Fifteen,
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COUNTS TWENTY-FIVE THROUGH THIRTY-FIVE
1. The allegations of paragraphs 1(a), (b), and (d) of Counts One through
HEATHER BERGDAHL,
and otherwise without authority knowingly converted to the use of a person not the
rightful owner, and intentionally misapplied, property worth at least $5,000 and
owned by and under the care, custody and control of Hospital A, namely, payments
separate count:
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Count Date Payment
Thirty August 23, 2021 approximately $29,999.99 through a check for
made payable to Chicago Promotions
ANOSH AHMED,
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COUNTS THIRTY-SIX THROUGH FORTY-ONE
On or about the dates set forth below, in the Northern District of Illinois,
Eastern Division, and elsewhere, the defendants, as set forth below, knowingly
conducted and attempted to conduct the following financial transactions listed below,
namely, the transfer of United States currency from one bank account to another
bank account, in or affecting interstate and foreign commerce, each such financial
knowing that the transaction was designed in whole and in part to conceal and
disguise the nature, location, source, ownership, and control of the proceeds of the
specified unlawful activity, and that while conducting such financial transactions, the
defendant knew that the property involved in the financial transactions represented
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Count Defendant Date Financial Transaction
Thirty-Eight ANOSH June 22, 2021 a transfer of approximately $81,050
AHMED from Gold Oak Capital dba Illinois
Biotech account ending in 1584 at
Bank B to a Gold Oak Capital Account
ending in 8845 at Bank B
Thirty-Nine ANOSH June 23, 2021 a transfer of approximately $151,000
AHMED Gold Oak Capital dba Medlabs
account ending in 2358 at Bank B to
Gold Oak Capital Account ending in
8845 at Bank B
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FORFEITURE ALLEGATION ONE
Sections 666(a)(1)(A) and 1343, and 1956(a)(1)(B)(i), as set forth in this Indictment,
defendants shall forfeit to the United States of America any property which
constitutes and is derived from proceeds traceable to the offense, as provided in Title
18, United States Code, Section 981(a)(1)(C), and any property traceable to such
by a defendant: cannot be located upon the exercise of due diligence, has been
transferred or sold to, or deposited with, a third party, has been placed beyond the
jurisdiction of the Court; has been substantially diminished in value; or has been
commingled with other property which cannot be divided without difficulty, the
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FORFEITURE ALLEGATION TWO
Section 1956(a)(1)(B)(i), as set forth in this Indictment, defendant shall forfeit to the
United States of America any property involved in such offense, and any property
traceable to such property, as provided in Title 18, United States Code, Section
982(a)(1).
by a defendant: cannot be located upon the exercise of due diligence; has been
transferred or sold to, or deposited with, a third party; has been placed beyond the
jurisdiction of the Court; has been substantially diminished in value; or has been
commingled with other property which cannot be divided without difficulty, the
A TRUE BILL:
FOREPERSON
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