United States District Court

Central District of California

UNITED STATES OF AMERICA,
Plaintiff,
v.
Crest Recovery LLC, Truvida Recovery, Healing Path Detox LLC, Saigon National Bank, Anaheim Chamber of Commerce, AAA, B&D Automotive, The Irvine Company, OC Superior Court, AT&T, Ralphs, CVS, Walgreens, Marina Inn, Orange County Harbor Businesses, Orange County Rescue Mission, Hurtt Clinic, and associated individuals,
Defendants.

Case No.: [123456]

COMPLAINT FOR CIVIL FORFEITURE IN REM

INTRODUCTION

  1. This is a civil action in rem to forfeit property involved in violations of federal statutes concerning racketeering, money laundering, and health care fraud, including but not limited to 18 U.S.C. § 1962 (RICO), 18 U.S.C. § 981 (Civil Forfeiture), and 18 U.S.C. § 1956 (Money Laundering). The properties listed herein are subject to forfeiture pursuant to federal law as they constitute proceeds or instrumentalities of illegal activity.

JURISDICTION AND VENUE

  1. This Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1345 and 28 U.S.C. § 1355, which provide jurisdiction over actions commenced by the United States and for civil forfeiture actions.
  2. Venue is proper in this district pursuant to 28 U.S.C. § 1391(b) and 28 U.S.C. § 1395, as the defendants and the properties are located within this judicial district, and the acts giving rise to the forfeiture occurred in this district.

THE DEFENDANTS

  1. The defendants in this action are various entities and properties involved in a coordinated network of illegal racketeering and money laundering activities. The defendants include:
    • Crest Recovery LLC, Truvida Recovery, Healing Path Detox LLC (Healthcare and Recovery Centers involved in fraudulent billing schemes),
    • Saigon National Bank (Financial institution facilitating money laundering),
    • Anaheim Chamber of Commerce (Participated in illegal real estate schemes),
    • AAA, B&D Automotive, The Irvine Company (Involved in real estate and insurance fraud),
    • Various retail chains, including AT&T, Ralphs, CVS, Walgreens, which have been implicated in laundering money through point-of-sale and service transactions,
    • The Marina Inn and Orange County Harbor Businesses (Utilized for hospitality-related laundering operations),
    • Orange County Rescue Mission and Hurtt Clinic (Non-profit entities used to defraud insurance programs).

FACTUAL BACKGROUND

  1. The United States Government, through an extensive investigation conducted by the United States Secret Service and a joint task force that includes the Orange County Sheriff's Department, Tustin Police Department, Santa Ana Police Department, and Irvine Police Department, has uncovered a multi-faceted scheme involving racketeering and laundering of criminal proceeds derived from fraudulent medical billing and kickback schemes.

  2. Defendants Crest Recovery LLC, Truvida Recovery, and Healing Path Detox LLC engaged in fraudulent billing practices, submitting false claims to insurance providers in connection with addiction treatment and recovery services. These actions generated millions of dollars in illicit profits, which were subsequently laundered through Saigon National Bank and reinvested in real estate holdings operated by The Irvine Company.

  3. Saigon National Bank facilitated the movement of these funds through offshore accounts and shell companies, further obscuring the origins of the illicit funds. Large portions of these funds were used to purchase properties in the Anaheim and Orange County regions, including assets connected to the Anaheim Chamber of Commerce, AAA, and B&D Automotive.

  4. Retail chains, including AT&T, Ralphs, CVS, and Walgreens, were used as intermediaries to launder funds through fraudulent transactions disguised as legitimate sales and services.

  5. The Orange County Rescue Mission and Hurtt Clinic were also implicated in this scheme, exploiting vulnerable populations and defrauding health care programs through fraudulent claims and illegal kickbacks.

ASSETS SUBJECT TO FORFEITURE

  1. The assets listed below are subject to forfeiture pursuant to 18 U.S.C. § 981(a)(1)(A) and (a)(1)(C) as proceeds of racketeering and money laundering:
  • Real estate properties located in Anaheim, Irvine, and other areas within Orange County that were purchased or maintained using laundered funds.
  • Bank accounts held by Saigon National Bank and affiliated entities.
  • Vehicles and other personal property used as instruments to facilitate money laundering.
  • Business assets associated with Crest Recovery LLC, Truvida Recovery, and Healing Path Detox LLC.
  • Additional property and assets held by the Anaheim Chamber of Commerce, AAA, and B&D Automotive.

CAUSES OF ACTION

COUNT I: FORFEITURE OF PROPERTY USED IN VIOLATION OF RICO (18 U.S.C. § 1962)

  1. The United States alleges that the defendants participated in a pattern of racketeering activities as defined by 18 U.S.C. § 1961 and are subject to forfeiture under 18 U.S.C. § 1962.

COUNT II: FORFEITURE OF PROPERTY INVOLVED IN MONEY LAUNDERING (18 U.S.C. § 1956)

  1. The defendants' property was used in and derived from unlawful money laundering activities in violation of 18 U.S.C. § 1956 and is subject to forfeiture.

COUNT III: FORFEITURE OF PROCEEDS OF HEALTH CARE FRAUD (18 U.S.C. § 1347)

  1. The assets in question are the proceeds of health care fraud in violation of 18 U.S.C. § 1347, and therefore subject to forfeiture under 18 U.S.C. § 981(a)(1)(C).

PRAYER FOR RELIEF

WHEREFORE, the United States requests that this Court:

  1. Enter a judgment of forfeiture against the defendants and all properties described herein.
  2. Order the immediate seizure of the assets, accounts, and properties subject to forfeiture.
  3. Issue a restraining order to prevent the sale or transfer of the properties subject to forfeiture.
  4. Grant any additional relief that the Court deems just and proper.

DATED: [Insert Date]
Respectfully submitted,
United States Attorney for the Central District of California
[Attorney Name], Assistant United States Attorney

Next Steps:

  1. Filing with the Court: This document should be filed in the U.S. District Court for the Central District of California.
  2. Service of Process: Defendants must be served with the complaint following federal rules.
  3. Attach Exhibits: Supporting documents and affidavits (e.g., bank records, property deeds, and communications) should be attached as exhibits.

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