USA v. Curry et al

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WO
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA
United States of America,
Plaintiff,
v.
(1) Alexis Daneen Curry; and
(2) Thvoughn Lynden Curry,
Defendants.
No. CR-23-01293-PHX-GMS
FINDINGS OF FACT AND
CONCLUSIONS OF LAW
Pursuant to Federal Rule of Criminal Procedure 23(c), the Court hereby makes its
findings of fact and its conclusions of law in the above-captioned case.
FINDINGS OF FACT
1. The Court held a four-day bench trial in the above-captioned matter, beginning on
February 3, 2026, and concluding on February 10, 2026.
2. The Government has established the identity of the first-listed Defendant as being
Alexis Daneen Curry.
3. The Government has established the identity of the second-listed Defendant as being
Thvoughn Lynden Curry.
4. The grand jury returned a superseding 26 count indictment on August 6, 2024
(Doc. 54), charging Defendants each with:
(a) One count of Conspiracy (Count 1), in violation of 18 U.S.C. § 1349, for
conspiring to commit Wire Fraud (18 U.S.C. § 1343) and Health Care
Fraud (18 U.S.C. § 1347);
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(b) One count of Wire Fraud (Count 2), in violation of 18 U.S.C. §§ 1343
and 2;
(c) Twelve counts of Health Care Fraud (Counts 3-14), in violation of 18
U.S.C. §§ 1347 and 2; and
(d) Twelve counts of Transactional Money Laundering (Counts 15-26), in
violation of 18 U.S.C. §§ 1957 and 2.
5. At the outset of the first day of trial, the Government moved to dismiss Counts 3-5, 7,
9, 11-15, 18-19, and 21. The Court did so without prejudice.
A. The Arizona Health Care Cost Containment System (“AHCCCS”)
i. Background
6. The Arizona Health Care Cost Containment System (“AHCCCS”) is Arizona’s
Medicaid agency that provides healthcare services for low-income individuals.
AHCCCS is primarily funded by the federal government but also receives funding from
the State of Arizona. The agency offers a range of services spanning medical, vision,
hearing, and behavioral health.
7. Individuals registered with AHCCCS are typically referred to as “members.” Members
qualify for AHCCCS services based on their income level.
8. Behavioral health services under AHCCCS are available to those with either a mental
health diagnosis or substance abuse diagnosis.
9. Behavioral health services covered under AHCCCS are generally provided at three
different types of facilities:
(a) The first, outpatient treatment facilities, involve the lowest level of care
where services are generally provided only for a few hours at a time.
(b) The second, behavioral health residential facilities (“BHRFs”), are 24-
hour living facilities for individuals who need constant supervision and
cannot live independently. At a BHRF, members live in the residence
(also referred to as a “house”). BHRFs are managed by AHCCCS-
approved providers. The providers receive a per diem of ~$300 a day for
each member, reimbursed by AHCCCS, to provide the members at the
house with housing, oversight, and behavioral health services.
(c) The third, inpatient treatment facilities (such as a detox facility, subacute
facility, or inpatient hospital), provide the highest level of care where a
patient is admitted overnight.
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10. To receive reimbursement from AHCCCS for providing outpatient services, a provider
must first be licensed with the Arizona Department of Health Services (“AZDHS”) to
provide such services. The outpatient services provider must also have a National
Provider Identification Number (“NPI”)—a unique identification number for healthcare
providers issued by the federal Centers for Medicare and Medicaid Services (“CMS”).
11. To register with AHCCCS, providers submit an application package with information
regarding (but not limited to): (i) the type of services provided; (ii) primary practice
facility location; (iii) the owners, operators, and managing employees (along with dates
of birth and social security numbers); (iv) hours of operation; (v) AZDHS licensure;
(vi) a W-9 form containing their Employer Identification Number (EIN); (vii) NPI; and
(viii) background information regarding any “adverse actions” (negative legal action,
such as felony convictions, pending indictments, etc.) taken against the provider’s
owners, agents, managing employees, and key personnel.
12. AHCCCS vets the providers’ individual owners to protect the safety and well-being of
its members. AHCCCS may deny or delay an application if information—such as a
prior criminal history—comes to light during the vetting process.
13. Moreover, when a provider represents to AHCCCS that it will provide services for a
set number of hours, the provider is expected to only bill within that range of hours. If
a provider changes its hours of operation, it must inform AHCCCS of the change.
ii. Fee-for-Service (“FFS”) Billing
14. AHCCCS providers generally have two ways of receiving payment for services
rendered to members:
(a) First, providers can receive payment from managed care organization
(“MCO”) health plans (such as Blue Cross Blue Shield, Aetna, etc.). The
majority of AHCCCS members are covered by an MCO plan.
(b) Second, providers can also receive payment directly from AHCCCS
when treating fee-for-service (“FFS”) program members. Under the
American Indian Health Program (“AIHP”)—a subprogram of AHCCCS
which covers members that are Native American or Alaskan Native—
providers are directly paid for services rendered upon billing.
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15. Providers who treat FFS members submit their claims for payment through a billing
portal on the AHCCCS website. When submitting claims, providers submit the range
of dates that the services were rendered, codes reflecting the type and setting of the
service provided (“CPT codes”), and the total amount of reimbursement sought, among
other items. (See, e.g., Pl.’s Ex. 2).
16. Claims submitted on the AHCCCS billing portal are sent to CMS and travel through
the AHCCCS “mainframe server.” Prior to 2017, the AHCCCS mainframe was located
in Phoenix, Arizona. As of February 6, 2026, the mainframe is located in Boulder,
Colorado. No testimony was offered describing where the mainframe was located
between 2017 to February 2026.
17. Certain services are billed in 15-minute increments, called “units.” For example, if a
provider billed a certain service for 4 units, that means that a patient was treated for 1
hour of a particular service, indicated via Current Procedural Terminology (“CPT”)
code. These CPT codes include, as relevant here (Pl.’s Ex. 2, “OVERVIEW” tab):
CPT Code Description of Service Rendered
H0004 Behavioral health counseling and therapy
H2014 Skills training and development
H2027 Psychoeducational service
T1016 Case management (administrative add-on function to provide
services separate from therapy)
18. The CPT codes beginning with an “H” are considered “face-to-face” codes—meaning
that services were provided while the member was with the provider. T1016, on the
other hand, need not occur face-to-face; instead, case management can occur
simultaneously with face-to-face service (i.e., a member can receive service by a
medical professional for an hour, during which a case manager can independently work
on that member’s case management).
19. Providers indicate “modifiers” for certain services. Two of these modifiers, as relevant
here, are:
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(a) “HQ”: a group service (two or more individuals) is being provided.
Failure to include this modifier indicates that the patient was treated
individually. This modifier is commonly seen with CPT code H0004
(behavioral health counseling and therapy).
(b) “HN”: the service provided is by an individual with a bachelor’s degree.
This modifier is commonly seen with T1016 (case management).
20. Providers also indicate the place of service (“POS”). As relevant here:
(a) “11”: the service was provided in an office.
(b) “12”: the service was provided in a home.
21. Providers indicate their provider type (“PT) as well. As relevant here, “77” refers to
outpatient services.
22. Taking the four items together—CPT code, modifiers, POS, and PT—AHCCCS sets
the appropriate FFS fee schedule for any given number of units billed. For example,
an outpatient service provider that provides 120 units (30 hours) of H0004(HQ)(11)
services (behavioral health counseling, in a group setting, in an office) to one member
could bill and receive payment of $1,312.80 in February 2021. (See, e.g., Pl.’s Ex. 2).
B. 1 Family Clinic, LLC (“1FC”)
i. 1FC’s Formation and Bank Accounts
23. On July 13, 2020, Articles of Organization for a limited liability company, 1 Family
Clinic, LLC (“1FC”), were submitted with the Arizona Corporation Commission.
Defendant Thvoughn Curry was listed as 1FC’s statutory agent, principal, organizer,
and authorized agent. The “character of business” of 1FC was listed as “Health Care
and Social Assistance.” (Pl.’s Ex. 21).
24. On October 6, 2020, Articles of Amendment for 1FC were submitted with the Arizona
Corporation Commission. The amendment added Defendant Alexis Curry as a
manager for 1FC. The amendment was signed by Alexis Curry. (Pl.’s Ex. 22).
25. Defendants together opened four bank accounts, each with the name “1 FAMILY
CLINIC LLC,” with Bank of America (“BofA”):
(a) On November 24, 2020, Defendants opened a business checking account
ending in 7401 (“BofA x7401”). The signature card, signed by both
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Defendants, reflected that 1FC is a partnership, had an EIN ending in
8563, with Thvoughn Curry and Alexis Curry listed as the managers.
(Pl.’s Ex. 74; Pl.’s Ex. 70; Pl.’s Ex. 78).
(b) On October 21, 2020, Defendants opened a business savings account
ending in 8149 (“BofA x8149”). The signature card, signed by both
Defendants, reflected that 1FC is a partnership, had an EIN ending in
8563, with Thvoughn Curry and Alexis Curry listed as the managers.
(Pl.’s Ex. 74; Pl.’s Ex. 71; Pl.’s Ex. 79).
(c) On October 21, 2020, Defendants opened a business checking account
ending in 8136 (“BofA x8136”). The signature card, signed by both
Defendants, reflected that 1FC is a partnership, had an EIN ending in
8563, with Thvoughn Curry and Alexis Curry listed as the managers.
(Pl.’s Ex. 74; Pl.’s Ex. 72; Pl.’s Ex. 80).
(d) On November 2, 2021, Defendants opened a business checking account
ending in 6094 (“BofA x6094”). (Pl.’s Ex. 74; Pl.’s Ex. 81).
ii. 1FC’s AHCCCS Application
26. On November 25, 2020, Alexis Curry, on behalf of 1FC, submitted an application
packet with AHCCCS to enroll as an AHCCCS provider.
27. 1FC’s AHCCCS application made several representations (Pl.’s Ex. 1 at 5-141):
(a) It listed 1FC’s NPI as 1023626090;
(b) It indicated that 1FC was registering as a facility/agency organization that
would provide behavioral health services at an outpatient clinic;
(c) It listed the primary practice location as 1550 E McKellips Road, Suite
110, Mesa, Arizona 85203, and did not list any other practice locations;
(d) It stated that the primary practice location’s hours would be from 8:00
a.m. to 4:00 pm from Monday to Friday; 9:00 a.m. to 2:00 p.m. on
Saturday; and closed on Sunday (totaling 45 hours a week);
(e) It indicated that 1FC was licensed by AZDHS, as of November 19, 2020,
to provide outpatient services (license number: OTC10508);
(f) It stated that Alexis Curry had a 100% ownership interest in and was the
only managing employee of 1FC, and it listed her email address as
1familyclinic@gmail.com; and
(g) It represented that for all individuals and entities with an ownership or
1 Exhibit pincites refer to the bates number of the exhibit, found at the lower right
corner of the page. For example, the pincite to “CURRY_000012”—found in Plaintiff’s
Exhibit 1—would be (Pl.’s Ex. 1 at 12).
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control interest in 1FC, and for all agents, managing employees, and key
personnel of 1FC, that there were no convictions or any pending
proceedings (such as an indictment, pending plea, or investigation) that
could result in any sanction, conviction, or action taken against the
individual or entity.
28. The application packet appended a W-9 Form, which is a Request for Taxpayer
Identification Number and Certification. In the W-9, signed by Alexis Curry, the
Employee Identification Number (“EIN”) for 1FC ended in 8563. (Pl.’s Ex. 1 at 42).
This EIN was listed on the bottom of each page of the application packet. (Id. at 2-40).
29. The application packet also appended a copy of the certification and transmittal form
received from AZDHS. The form identified that 1FC was only licensed to provide
outpatient treatment center/counseling services. (Pl.’s Ex. 1 at 45).
30. The application packet contained a Provider Participation Agreement (“PPA”), which
is a contract between the provider and AHCCCS. (Pl.’s Ex. 1 at 16-20). The PPA lays
out the various policies, procedures, and guidelines that a provider must follow to
become an AHCCCS provider with the Medicaid system. The PPA incorporates by
reference all AHCCCS guidelines, policies, and manuals (e.g., Pl’s Exs. 14-18),
including but not limited to the AHCCCS Medical Policy Manual (Pl.’s Ex. 13),
AHCCCS Fee-For-Service Manual (Pl.’s Ex. 19), AHCCCS Claims Clues, and
Reporting Guides.
31. The PPA lists certain requirements for providers to follow (Pl.’s Ex. 1 at 16-20):
(a) The provider agrees to maintain all records relating to performance of the
PPA in compliance with all specifications for record-keeping established
by AHCCCS, and to maintain all records in such detail as to reflect each
service provided and all other costs and expenses of whatever nature for
which payment is made to the provider;
(b) The provider must comply with all federal, state, and local laws and rules
governing or otherwise related to the performance of duties under the
PPA;
(c) The provider agrees to provide services, bill for services, accept payment,
and otherwise follow all AHCCCS policies;
(d) The provider warrants that it has the ability, authority, skill, expertise,
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and capacity to perform and provide the services governed by the PPA;
(e) The provider must ensure that its electronic health records (“EHR”)
system is developed to accurately record, maintain, and reflect all original
entries; and
(f) AHCCCS will suspend any payments to the provider pending an
investigation of a “credible allegation of fraud” against the provider.
32. Alexis Curry signed the PPA on November 25, 2020, under penalty of law that the
information she provided on the form was true, accurate, and complete to the best of
her knowledge. (Pl.’s Ex. 1 at 20).
33. At the time that Alexis Curry submitted 1FC’s AHCCCS application, there was an
outstanding arrest warrant—issued in October 2018 for two state felony charges
involving the fraudulent use of fictitious personal identification and obtaining a vehicle
with intent to defraud—for Thvoughn Curry in Florida. (Pl.’s Ex. 25).
iii. 1FC’s Operations
34. As represented on its AHCCCS application, 1FC only operated out of its primary
practice location: a nine-room office space in Harris Park Professional Plaza, located
at 1550 East McKellips Road, Suite 110, Mesa, Arizona 85203. (Pl.’s Exs. 1, 39).
35. 1FC publicly advertised the hours of business provided in its AHCCCS application.
(Pl.’s Ex. 1 at 7; Pl.’s Ex. 37 at 141805).
36. As of April 2021, 1FC maintained the following “Daily Activities Schedule,” consisting
of 4 hours and 40 minutes of activities (Pl.’s Ex. 36 at 141779; Pl.’s Ex. 37 at 141808):
9:45 a.m. – 10:00 a.m. Morning Meditation
10:00 a.m. – 10:15 a.m. Review Period
10:15 a.m. – 11:15 a.m. First Lesson
11:15 a.m. – 11:30 a.m. 15 min. Break
11:30 a.m. – 12:30 p.m. Second Lesson
12:30 p.m. – 1:45 p.m. Lunch Break
1:50 p.m. – 3:00 p.m. Third Lesson
3:00 p.m. – 4:00 p.m. Group Activity
4:00 p.m. – 4:30 p.m. Break until Transportation Arrives
37. Thvoughn Curry went to 1FC’s primary practice location at least twice a month to drop
off checks. Daniel Brown, a 1FC employee, testified that he understood Thvoughn
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Curry to be the owner of 1FC. Clients at 1FC referred to Thvoughn Curry as “Mr. T.”
Alexis Curry was also seen at 1FC’s office and was understood to be an owner of 1FC.
Alexis Curry and Thvoughn Curry drove several different vehicles when visiting 1FC’s
office, including a Dodge Hellcat, Dodge Charger, a BMW, and a large truck.
38. As described by Daniel Brown, who was employed by 1FC from December 2022 to
June 2023, anywhere between “25 to 30 plus” clients were present at 1FC’s office in
Mesa on a typical day. 1FC’s clients would be transported from “houses” to the office.
39. There were at least five “houses”:
(a) In Mesa, Arizona, there were two women’s houses and one men’s house.
Each of the houses in Mesa housed between 8-12 individuals at a time.
(b) In the Phoenix/Glendale area, there was one men’s house and one
women’s house. There were, at most, 4 individuals living in the men’s
house and, at most, 6 individuals living in the women’s house in
Phoenix/Glendale at a time.
40. Daniel Brown described a typical day at 1FC between December 2022 and June 2023:
(a) The 1FC office was open Monday through Friday. Saturdays were for
special events, and no business took place on Sundays.
(b) Brown typically arrived at 1FC’s office at around 7:00 a.m., got the keys
to one of 1FC’s company vehicles, and then drove to the houses to pick
up clients. 1FC had at least four company vehicles, three of which Brown
was able to remember: one large Mercedes that could carry up to 20
people; one Mercedes minivan; and one Dodge minivan.
(c) Brown taught “classes” at 1FC’s office in a group setting with the clients.
Brown held only a high school diploma and had received no other formal
training to provide such services. Class started between 8:30 a.m. and
9:00 a.m., Monday through Friday. Every client picked up from a house
attended the group classes for the day. Classes took place in one assigned
room at the 1FC office. (Pl.’s Ex. 39, Room 6).
(d) In these group classes, Brown hosted discussions with the clients,
allowing every person to speak and “say fully whatever it is they wanted
to say.” Brown offered advice to help clients out from time to time. He
also assigned and reviewed homework, went over the “word of the day,”
solved crossword puzzles, and watched movies with the clients during the
classes.
(e) At noon, the clients took an hour-long lunch break. Afterwards, clients
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did “work sheets” related to different lessons planned by Brown. After
the work sheets were completed, Brown took the clients to a nearby park
before taking them back to their houses between 4:00 p.m. and 5:00 p.m.
(f) On Friday, clients only attended class for half of the day. After class,
clients were taken out for certain activities, such as going to get a haircut
or getting one’s nails done.
(g) On Saturday, clients were picked up between 10:00 a.m. and 11:00 a.m.
They were often taken to go see a movie and then get dinner afterwards.
(h) No activities took place on Sunday.
41. During Brown’s time at 1FC, the company employed a total of three case managers,
but only two worked at 1FC at the same time. Case managers assisted clients with
receiving social services, setting up doctor’s appointments, and finding visitation times
with family members. Additionally, there was a counselor employed named
“Wayman.” On occasion, when Brown led group classes, Wayman would meet one-
on-one with no more than three clients in a day if they wanted to speak with him.
Wayman would see each client for 30-60 minutes on average. There were no other
individual counseling sessions provided at 1FC other than those led by Wayman.
Wayman also did not host any counseling sessions at the clients’ houses.
42. Of the nine rooms in 1FC’s office, only two were used to provide client services. Brown
led the group classes in room 6, and Wayman’s individual sessions occurred in room 3.
The case managers worked in room 4. Rooms 8 and 9 were offices for 1FC employees.
Children stayed and played in room 5 during the day. Room 1 was for the receptionist;
room 2 was the kitchen; and room 7 was the restroom. (Pl.’s Ex. 39).
43. Once clients were back at the houses for the evening, they typically did their homework,
ate dinner, and watched movies. Clients generally cooked for themselves; they received
funds for food from Alexis Curry and Thvoughn Curry or relied on nutrition assistance
programs to purchase groceries.
44. 1FC relied on its employees to manage the houses in the evenings (except for Sundays).
Brown would spend one to two evenings a week at one of the houses. On those nights,
Brown would eat dinner with the clients, watch movies with them, and upload his
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written notes from the day onto 1FC’s EHR software, ICANotes. Brown did not lead
any group classes at the houses in the evenings. Brown would usually depart the house
by 10:00 p.m.
45. 1FC employees oversaw the houses for security. Brown testified that there were
cameras in every room of the houses, and that these cameras were monitored by Alexis
Curry, Thvoughn Curry, and other 1FC employees. Brown was occasionally called to
manage issues at the houses, such as clients drinking alcohol. When responding to such
calls, Brown first went to the 1FC office, clocked in, got the keys to a company vehicle,
and then drove to the house.
iv. 1FC’s Total AHCCCS Billing
46. 1FC began submitting billing claims to AHCCCS in February 2021. Each claim
consisted of a unique claim number, the AHCCCS identification number of the member
receiving services, the beginning and end dates of service, and the total amount sought
in reimbursement for all itemized services over the dates of service. AHCCCS then
could approve or deny each claim, in full or in part. (Pl.’s Ex. 4).
47. From February 17, 2021, to April 7, 2023, 1FC submitted 2,137 claims to AHCCCS.
All but four of these claims were identified as being submitted by Alexis Curry.
Thvoughn Curry was not listed as having submitted any claims. (Pl.’s Ex. 4). The
2,137 claims represented a total of 13,646 itemized services (or claim lines). For every
itemized service submitted, 1FC represented that it was providing outpatient services.
(Pl.’s Ex. 2, “ALL SERVICES” tab).
48. In total, 1FC sought $12,776,465.75 from AHCCCS in billing reimbursement from
February 2021 to April 2023. (Pl.’s Ex. 4). AHCCCS ultimately paid 1FC
$12,360,053.46 for services claimed to have been rendered. (Pl.’s Ex. 66 at 141935).
C. AHCCCS’s Investigation into 1FC Based on a “Credible Allegation of Fraud”
49. At some point in 2021, AHCCCS received a referral indicating a “credible allegation
of fraud” against 1FC. Loretta Lizarraga, an AHCCCS employee, led the investigation.
50. Lizarraga compared the AHCCCS application submitted by Alexis Curry in November
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2020 with the 1FC’s Articles of Organization, effective as of July 2020 and amended
in October 2020. Lizarraga noticed an inconsistency: 1FC’s AHCCCS application
listed Alexis Curry as its sole owner, while its Articles of Organization listed Thvoughn
Curry as the statutory agent, principal, organizer, and authorized agent, with Alexis
Curry later added as a manager.
51. AHCCCS’s Program Integrity Team (“PIT Team”) then pulled all itemized services
billed by 1FC. (Pl.’s Ex. 2 (the “BRHF-ALL”)). When reviewing the data, Lizarraga
noticed certain red flags that supported a credible allegation of fraud.
52. Lizarraga next created a random sample of the BHRF-ALL. From that random sample,
she requested the medical records from 1FC that corresponded with the itemized
services. In her review of the medical records, Lizarraga noticed missing signatures,
dates, and progress notes, among other items.
53. 1FC was suspended by AHCCCS in April 2023—thus halting all reimbursement
payments. 1FC appealed the suspension. The suspension was upheld by the agency.
i. Count 6: Allegation of Health Care Fraud, Patient M.B.
54. From May 9 to May 15, 2022—a seven-day period—1FC sought a total of $6,255.60
in reimbursement from AHCCCS for services provided to patient M.B. (AHCCCS ID
ending in 4195). 1FC was paid the full $6,255.60. 1FC billed the following itemized
services (Pl.’s Ex. 10; Pl.’s Ex. 2):
CPT Modifier POS Units Hours Billed Paid
H0004 HQ 11 100 25 $1,094.00 $1,094.00
H0004 HQ 12 56 14 $612.64 $612.64
H2014 11 48 12 $953.76 $953.76
H2027 12 72 18 $1,459.44 $1,459.44
T1016 HN 11 40 10 $766.80 $766.80
T1016 HN 12 48 12 $1,368.96 $1,368.96
55. Though 1FC had previously represented to AHCCCS that it was only open for 45 hours
during a seven-day period, 1FC’s billings for patient M.B. from May 9 to May 15, 2022,
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totaled 69 hours of in-person service and 22 hours of case management.
56. From May 9 to May 15, 2022, 1FC submitted claims on behalf of 19 members:
(a) Over that period, 1FC billed a total of 2176 units, or 544 hours, of
individualized face-to-face service (denoted by CPT code H0004, H2014,
or H2027, without the HQ group modifier).
(b) 868 of the units, or 217 hours, were purportedly provided in an office
setting. 1308 of the units, or 327 hours, were purportedly provided in a
home setting.
(c) Thus, on average, 1FC claimed that it provided over 77 hours of
individualized counseling per day over the period (including Saturday
and Sunday): 31 hours per day in the office, and 46.7 hours per day at
home.
(See Pl.’s Ex. 2, “ALL SERVICES” tab).2
57. Additionally, over the same period, 1FC billed a total of 1596 units, or 399 hours, of
case management (denoted by CPT code T1016).
(a) 724 of the units, or 181 hours, were purportedly done in the office. 872
of the units, or 218 hours, were purportedly done at home.
(b) Thus, on average, 1FC claimed that it performed 57 hours of case
management per day over the period (including Saturday and Sunday):
25.9 hours per day in the office, and 31.1 hours per day at home.
(See Pl.’s Ex. 2, “ALL SERVICES” tab).
ii. Count 8: Allegation of Health Care Fraud, Patient F.C.
58. From January 20 to January 25, 2023—a six-day period—1FC sought a total of
$5,476.56 in reimbursement from AHCCCS for services provided to patient F.C.
(AHCCCS ID ending in 4599). 1FC was ultimately paid $5,406.48. 1FC billed the
following itemized services (Pl.’s Ex. 11 at 140489; Pl.’s Ex. 2):
//
//
//
2 To find the number of individualized face-to-face service hours, the Court filtered
the data by (1) the beginning and end dates of service to be between 5/9/22 and 5/15/22;
(2) the CPT codes to be either H0004, H2014, and H2027; and (3) blank modifiers. Unless
otherwise stated, the Court followed this same method when filtering for case management
service (by CPT code T1016, with modifier HN) and for other date ranges, as seen below.
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CPT Modifier POS Units Hours Billed Paid
H0004 11 4 1 $182.08 $112.00
H0004 HQ 11 80 20 $896.80 $896.80
H0004 HQ 12 48 12 $538.08 $538.08
H2014 11 40 10 $814.80 $814.80
H2027 12 60 15 $1,246.80 $1,246.80
T1016 HN 11 32 8 $628.80 $628.80
T1016 HN 12 40 10 $1,169.20 $1,169.20
59. Though 1FC had previously represented to AHCCCS that it was only open for 37 hours
during the six-day period in question, 1FC’s billings for patient F.C. from January 20
to January 25, 2023, totaled 58 hours of in-person service and 18 hours of case
management.
60. From January 20 to January 25, 2023, 1FC submitted claims on behalf of 15 members:
(a) Over that period, 1FC billed a total of 552 units, or 138 hours, of
individualized face-to-face service (denoted by CPT code H0004, H2014,
or H2027, without the HQ group modifier).
(b) 252 of the units, or 63 hours, were purportedly provided in an office
setting. 300 of the units, or 75 hours, were purportedly provided in a
home setting.
(c) Thus, on average, 1FC claimed that it provided 23 hours of individualized
counseling per day over the period (including Saturday and Sunday):
10.5 hours per day in the office, and 12.5 hours per day at home.
(See Pl.’s Ex. 2, “ALL SERVICES” tab).
61. Additionally, over the same period, 1FC billed a total of 404 units, or 101 hours, of case
management (denoted by CPT code T1016).
(a) 204 of the units, or 51 hours, were purportedly done in the office. 200 of
the units, or 50 hours, were purportedly done at home.
(b) Thus, on average, 1FC claimed that it performed over 16 hours of case
management per day over the period (including Saturday and Sunday):
8.5 hours per day in the office, and 8.3 hours per day at home.
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(See Pl.’s Ex. 2, “ALL SERVICES” tab).3
iii. Count 10: Allegation of Health Care Fraud, Patient A.D.
62. From August 2 to August 7, 2022—a six-day period—1FC sought a total of $10,549.78
in reimbursement from AHCCCS for services provided to patient A.D. (AHCCCS ID
ending in 1704). 1FC was ultimately paid $7,028.28. AHCCCS approved the
following itemized services (Pl.’s Ex. 12; Pl.’s Ex. 2):
CPT Modifier POS Units Hours Billed Paid
H0004 11 4 1 $109.28 $109.28
H0004 HQ 11 80 20 $875.25 $875.20
H0004 HQ 12 48 12 $525.12 $525.12
H0004 HQ 11 80 20 $875.25 $612.64
H0004 HQ 12 48 12 $525.12 $0.00
H2014 11 40 10 $794.80 $794.80
H2027 12 60 15 $1,216.20 $1,216.20
T1016 HN 11 32 8 $613.44 $613.44
T1016 HN 12 40 10 $1,140.80 $1,140.80
T1016 HN 12 40 10 $1,140.80 $1,140.80
63. Additionally, AHCCCS denied the following itemized services (Pl.’s Ex. 12):
CPT Modifier POS Units Hours Billed Paid
H0004 11 4 1 $109.28 $0.00
H2014 11 40 10 $794.80 $0.00
H2027 12 60 15 $1,216.20 $0.00
T1016 HN 11 32 8 $613.44 $0.00
64. Though 1FC had previously represented to AHCCCS that it was only open for 37 hours
during the six-day period in question, 1FC’s approved billings for patient A.D. from
3 Furthermore, when widening the dataset by one day to capture a full week period,
from January 20 to January 26, 2023, 1FC submitted claims for 37 members. Over that
period, 1FC billed 3576 units, or 894 hours, for individualized counseling services—
averaging 127.7 hours per day over seven days. It also billed 2580 units, or 645 hours, of
case management—averaging 92.1 hours per day over seven days. (Pl.’s Ex. 2).
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August 2 to August 7, 2022, totaled 90 hours of in-person service and 28 hours of case
management. And when counting hours from the denied claims, 1FC submitted total
billings for 116 hours of in-person service and 36 hours of case management over the
six-day period for patient A.D.
65. From August 2 to August 7, 2022, 1FC submitted claims on behalf of 3 members:
(a) Over that period, 1FC billed a total of 316 units, or 79 hours, of
individualized face-to-face service (denoted by CPT code H0004, H2014,
or H2027, without the HQ group modifier).
(b) 136 of the units, or 34 hours, were purportedly provided in an office
setting. 180 of the units, or 45 hours, were purportedly provided in a
home setting.
(c) Thus, on average, 1FC claimed that it provided over 13 hours of
individualized counseling per day over the period (including Saturday
and Sunday): 5.7 hours per day in the office, and 7.5 hours per day at
home.
(See Pl.’s Ex. 2, “ALL SERVICES” tab).
66. Additionally, over the same period, 1FC billed a total of 220 units, or 55 hours, of case
management (denoted by CPT code T1016).
(a) 100 of the units, or 25 hours, were purportedly done in the office. 120 of
the units, or 30 hours, were purportedly done at home.
(b) Thus, on average, 1FC claimed that it performed over 9 hours of case
management per day over the period (including Saturday and Sunday):
4.2 hours per day in the office, and 5 hours per day at home.
(See Pl.’s Ex. 2, “ALL SERVICES” tab).4
D. Text Message Communications Between Alexis Curry and Thvoughn Curry
67. A number of text message communications between Alexis Curry and Thvoughn Curry
from August 2020 to January 2023 were admitted into evidence at trial. (Pl.’s Ex. 36).5
4 Furthermore, when widening the dataset by one day to capture a full week period,
from August 1 to August 7, 2022, 1FC submitted claims for 15 members. Over that period,
1FC billed 1616 units, or 404 hours, for individualized counseling services—averaging
57.7 hours per day over seven days. It also billed 1196 units, or 299 hours, of case
management—averaging 42.7 hours per day over seven days. (Pl.’s Ex. 2).
5 Texts from Thvoughn Curry were sent from a phone number ending in 6947, and
texts from Alexis Curry were sent from a phone number ending in 3352. (Pl.’s Ex. 34;
Pl.’s Ex. 35).
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68. On August 27, 2020, Defendants discussed how long warrants last (Pl.’s Ex. 36 at
141767-68):
Thvoughn Curry: Warrants last for 4 years right?
. . .
Asking cause we 2 yrs in
It will drop off soon
Alexis Curry: Yes
. . .
Thvoughn Curry: But I had looked it up yesterday and they say warrants
last 4 yrs
Maybe you can do your research or we can ask the
lawyer when I call him for your sister
Alexis Curry: Ok it’s going on 3 years right baby
Yes
Thvoughn Curry: I think this year made 3
We found out when we 1st moved here
So 2 and a half years
Alexis Curry: Yes in 2018
Thvoughn Curry: Just have to look up how they last
69. On November 14, 2020, Defendants exchanged messages regarding the business hours
of 1FC (8:00 a.m. to 4:00 p.m. from Monday-Friday, 9:00 a.m. to 2:00 p.m. on
Saturday, and closed on Sunday). (Pl.’s Ex. 36 at 141770-71).
70. On January 23, 2021, Alexis Curry asked Thvoughn Curry for her AHCCCS password
and username. Thvoughn Curry sent the details. Alexis Curry replied with a screenshot
of an image showing that her AHCCCS application for 1FC was currently in-review.
(Pl.’s Ex. 36 at 141772).
71. On February 10, 2021, Alexis Curry asked for the bank account information to deposit
AHCCCS checks. Thvoughn Curry responded with a screenshot from Bank of
America’s website that contained the account information. The account number in the
screenshot matched that of the BofA x7401 account number. (Pl.’s Ex. 36 at 141774).
72. On April 21, 2021, Defendants exchanged a series of messages discussing 1FC’s
payroll, revenue from AHCCCS billing, the need for more clients, and getting billing
to $6,500/week/client (Pl.’s Ex. 36 at 141776-78):
Thvoughn Curry: Did you see our payroll?
17k
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Alexis Curry: Thank you baby yes my usual please
Thvoughn Curry: I ain’t even pay Tracey yet []
Alexis Curry: Wtf are you serious bookie? . . .
Thvoughn Curry: Very serious
Alexis Curry: Damn that took a chunk of our money
Thvoughn Curry: So from that calculation we looking at 40k-50k a month
in payroll
Alexis Curry: Good lord
Thvoughn Curry: That’s not business expenses or anything.
Alexis Curry: We need more clients ASAP
Thvoughn Curry: Yes.
We at 200k a month right now and a little over if we can
get this billing consistent love.
50-60k a week times 4
Then payroll won’t be a problem
We have to pay for the best right now so we can last
Alexis Curry: That’s good do they have that spread sheet for me to do
billing tomorrow?
Thvoughn Curry: We can make [$312,000] every month baby if you can
get billing to 6500 a week per client.
I will ask right now.
Alexis Curry: Ok bookie
Thvoughn Curry: And if I’m not mistaken I believe that’s where we at
We do a lot.
We have to capture everything
73. On April 26, 2021, Alexis Curry sent five billing codes: H2027; H2014; T1016;
H0004(HQ); and H0004(individual). (Pl.’s Ex. 36 at 141780). On April 29, 2021,
Thvoughn Curry asked Alexis Curry whether she was using those codes when doing
AHCCCS billing (Id. at 141781):
Thvoughn Curry: I have a quick question.
H2027
H2014
T1016
H0004(HQ)
H0004(individual)
Is these all the codes your using for billing love?
Alexis Curry: Yes babe
Why what happened??
Thvoughn Curry: Making sure everything right for you love. That’s all
74. On May 27, 2021, Defendants exchanged a series of texts discussing the need to get a
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third house, establish another office, hire more staff, purchase two more vans, and
ultimately increase billing to 80 clients per week to pull in over $1.9 million in
reimbursement from AHCCCS (Pl.’s Ex. 36 at 141782-86):
Alexis Curry: All claims were approved baby through Ahcccs
$77,971.91
They approved [client’s] back bill
Thvoughn Curry: F*** yeah
We rich b****
. . .
Next week billing for sure going to be 100k when we get
the house
. . .
Alexis Curry: We’ll be at 18 clients right?
Or 19?
Thvoughn Curry: 25
That’s why we need the 3rd house
. . .
We have 14 now currently
Alexis Curry: That’s 152,095
We need another office definitely and more staff
. . .
Thvoughn Curry: 2 more vans
1 more transit
1 more caravan
Can buy both when we cashing a 100k plus check.
Alexis Curry: Yes fr fr we need a big big office and a big ass house 6
bedrooms
Thvoughn Curry: Facts
We need the transit van now though.
The 1st one is to overfilled currently now
We’ll get that when we get the 77k check
. . .
This week billing is going to be fact
. . .
40 clients
We not stopping until we get that
And 40 kids
960 a month
Alexis Curry: This week billing will be 85,173
. . .
80 clients a week child that $486,704 a week
$1,946,816 a month . . .
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Thvoughn Curry: Now you can hire a company to do billing
80 clients that’s a lot or I’ll help you.
Just have to teach me
75. On June 3, 9, and 14 in 2021, Defendants continued to discuss AHCCCS billing and
depositing checks. (Pl.’s Ex. 36 at 141787-92). Alexis Curry asked Thvoughn Curry
for information regarding the 1FC’s clients for billing purposes (Id. at 141792):
Alexis Curry: How many clients had a full week last week?
. . .
I need how many new clients came in last week their
intake date and if their insurance was changed the date it
was changed and their diagnosis codes. I also need a list
of any clients that left last week and their date they left.
76. On October 8, 2021, Alexis Curry shared with Thvoughn Curry the website link to view
1FC’s check payments from AHCCCS every Friday. (Pl.’s Ex. 36 at 141794).
77. On June 14, 2022, Thvoughn Curry asked Alexis Curry if she “want[ed] to do the
formula for last week billing,” reminding her that 1FC “didn’t open up for Monday.”
(Pl.’s Ex. 36 at 141795 (emphasis added)). On June 17, 2022, Thvoughn Curry asked
Alexis Curry to “resend the modifications” that she “did the other day” so that he could
“start billing.” (Id. at 141796 (emphasis added)). Alexis Curry then sent a text
containing the following billing formula to determine the number of units to bill for
services rendered to one client over four weekdays and the weekend (June 7, 2022—a
Tuesday—through June 12, 2022—a Sunday) (id.):
CPT Modifier POS Units Billed (Four Weekdays + Weekend)
H0004 HQ 11 80
H0004 HQ 12 48
H2014 11 40
H2027 12 60
T1016 HN 11 32
T1016 HN 12 40
This formula was identical to a billing formula sent by Alexis Curry on March 18, 2022,
for another period covering four weekdays and the weekend (March 8, 2022—a
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Tuesday—through March 13, 2022—a Sunday). (See Pl.’s Ex. 38).
78. On August 31, 2022, Alexis Curry informed Thvoughn Curry that she could “knock out
billing later” once he sends her “the client census of who all to bill for.” (Pl.’s Ex. 36
at 141797).
79. On October 13, 2022, Thvoughn Curry discussed the need to “fix the billing,” stating
that “[w]e need half a mill a week.” (Pl.’s Ex. 36 at 141798). He also asked Alexis
Curry whether she wanted to go on vacation for a month with a $50,000 budget. (Id. at
141799).
80. On October 14, 2022, Thvoughn Curry sent a screenshot with a list of 39 pending claims
submitted to AHCCCS. He told Alexis Curry that “[i]f all them claims get approved,”
they would receive $200,000 in reimbursement. (Pl.’s Ex. 36 at 141800-01; Pl.’s Ex.
37 at 141812).
81. On January 13, 2023, Thvoughn Curry stated that was “[d]oing billing right [n]ow” and
sent a picture with the following three items visible: (1) his computer screen, which
displayed the AHCCCS website used by providers to input claims for itemized services;
(2) an iPhone screenshot of a billing formula over an unspecified time period; and (3)
a list of clients with personally identifying information, such as their AHCCCS IDs,
diagnosis codes, and the dates they began receiving services. (Pl.’s Ex. 36 at 141802;
Pl.’s Ex. 37 at 141813). The computer screen showed that Thvoughn Curry was logged
into Alexis Curry’s AHCCCS account and it displayed an IP address. (Pl.’s Ex. 68 at
141871). Additionally, Thvoughn Curry had input the following number of units for
four itemized services from January 6, 2023 (Friday) to January 12, 2023 (Thursday)
into the AHCCCS billing portal (id. at 141873):
CPT Modifier POS Units Billed
(Five Weekdays + Weekend)
H0004 HQ 11 100
H0004 HQ 12 56
H2014 11 48
H2027 12 72
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82. On January 20, 2023, Alexis Curry sent images containing the billing formula for a
client for services rendered over two weekdays and the formula for services rendered
over three weekdays (Pl.’s Ex. 36 at 141803-04; Pl.’s Ex. 37 at 141815, 141818):
CPT Modifier POS Units Billed
(Two Weekdays)
Units Billed
(Three Weekdays)
H0004 HQ 11 40 60
H0004 HQ 12 16 24
H2014 11 16 24
H2027 12 24 36
T1016 HN 11 16 24
T1016 HN 12 16 24
E. 1FC’s Billing Formula
i. Analysis of Billings From 12/20/2021 to 12/26/2021
83. On January 10, 2022, 1FC received a payment of $77,170.34 from AHCCCS. The
payment was deposited in the BofA x7401 account, which was under 1FC’s name and
had both Defendants listed on the signature card. (Pl.’s Ex. 67 at 141820-21; Pl.’s Ex.
4; Pl.’s Ex. 5).
84. The $77,170.34 payment from AHCCCS was reimbursement for claims submitted by
Alexis Curry for 12 members for services rendered from December 18 to December 26,
2021. (Pl.’s Ex. 67 at 141822; Pl.’s Ex. 4). Of those 12 claims, 11 of the members
were billed for services from December 20 to December 26, 2021 (one full week of
services). The other one member was billed from December 18 to December 26, 2021
(one full week plus one weekend). (Id.).
85. For the common period of billing for all 12 members over December 20, 2021, to
December 26, 2021, Alexis Curry submitted identical itemized services for each
member—billing $6,364.88 per member over the full week. (Pl.’s Ex. 67 at 141822;
Pl.’s Ex. 4).6
6 For the one member that was also billed for receiving services on December 18,
2021 (Saturday), Alexis Curry submitted claims for additional reimbursement of $791.78,
thus totaling $7,156.66 for that member specifically, and $77,170.34 for all 12 members.
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86. The itemized services billed for each of the 12 members from December 20 to
December 26, 2021, were:
Date Range: 12/20/2021 – 12/26/2021 (the “5 Weekdays + Weekend” Formula)
CPT Modifier POS Units Amount Billed
H0004 11 4 $109.28
H0004 HQ 11 100 $1,094.00
H0004 HQ 12 56 $612.64
H2014 11 48 $953.76
H2027 12 72 $1,459.44
T1016 HN 11 40 $766.80
T1016 HN 12 48 $1,368.96
(Pl.’s Ex. 67 at 141824-25). This common billing pattern is referred to as the “5 Days
+ Weekend Formula” throughout this Order.
87. Though 1FC had previously represented to AHCCCS that it was only open for 45 hours
during a seven-day period, 1FC’s billings for each member from December 20 to
December 26, 2021, totaled 70 hours of in-person service and 22 hours of case
management. (Pl.’s Ex. 67 at 141831).
ii. Matching the “5 Days + Weekend Formula” from Defendants’ Text
Messages
88. AHCCCS investigators were able to match the “5 Days + Weekend Formula,” as seen
in 1FC’s billings, with text messages sent between the Defendants. As identified from
these messages, 1FC used the following billing formulas for a client for services
rendered over (a) two weekdays; (b) three weekdays; and (c) four weekdays plus the
weekend:7
//
//
//
7 The text messages did not indicate any number of units when billing H0004(11) by
itself without the HQ modifier.
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Units Billed
Billing Code 2 Weekdays 3 Weekdays 4 Weekdays +
Weekend
H0004(11)
H0004(HQ)(11) 40 60 80
H0004(HQ)(12) 16 24 48
H2014(11) 16 24 40
H2027(12) 24 36 60
T1016(HN)(11) 16 24 32
T1016(HN)(12) 16 24 40
89. Based on the billing formula for two weekdays and the billing formula for three
weekdays, the following pattern is extrapolated for services rendered over any given
number of weekdays:
Units Billed
Billing Code 1
Weekday
2
Weekdays
3
Weekdays
4
Weekdays
5
Weekdays
H0004(11)
H0004(HQ)(11) 20 40 60 80 100
H0004(HQ)(12) 8 16 24 32 40
H2014(11) 8 16 24 32 40
H2027(12) 12 24 36 48 60
T1016(HN)(11) 8 16 24 32 40
T1016(HN)(12) 8 16 24 32 40
(Pl.’s Ex. 68 at 141846-48).
90. Next, based on the billing formula for four weekdays (as derived above) and the billing
formula for four weekdays plus the weekend (as seen in the Defendants’ text messages),
the “Weekend Formula” is derived:
//
//
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Units Billed
Billing Code 4 Weekdays “Weekend
Formula”
4 Weekdays +
Weekend
H0004(11)
H0004(HQ)(11) 80 +0 80
H0004(HQ)(12) 32 +16 48
H2014(11) 32 +8 40
H2027(12) 48 +12 60
T1016(HN)(11) 32 +0 32
T1016(HN)(12) 32 +8 40
(Pl.’s Ex. 68 at 141850). The “Weekend Formula” can then be appended to any of the
weekday formulas to derive a modified formula as necessary (for example, if a client
was billed from Thursday to Sunday, 1FC would use the two-weekday formula and add
the Weekend Formula to reach the modified unit totals).
91. From there, the billing formula used by 1FC for any given number of days is derived:
Units Billed
Billing Code 1 Day 2 Days 3 Days 4 Days 5 Days 5 Days +
Weekend
H0004(11)
H0004(HQ)(11) 20 40 60 80 100 100
H0004(HQ)(12) 8 16 24 32 40 56
H2014(11) 8 16 24 32 40 48
H2027(12) 12 24 36 48 60 72
T1016(HN)(11) 8 16 24 32 40 40
T1016(HN)(12) 8 16 24 32 40 48
(Pl.’s Ex. 68 at 141851). This billing pattern matches the “5 Days + Weekend Formula”
that 1FC followed when submitting identical itemized services for each of the 12
members from December 20 to December 26, 2021 (with the exception of H0004(11),
which was not seen in the text messages).
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iii. Confirming the Formula Empirically
92. The “5 Days + Weekend Formula” was seen throughout 1FC’s submission of itemized
services to AHCCCS. For example, in the week of December 30, 2022 (a Friday), to
January 5, 2023 (a Thursday), 1FC submitted claims for 16 members. Of those 16
members, 1FC submitted claims for the full week (5 days plus weekend) for 14
members. Each of these 14 members were billed in accordance with the 5 Days +
Weekend Formula.8 (Pl.’s Ex. 68 at 141857-59).
93. Similarly, in the week of January 6, 2023 (a Friday), to January 12, 2023 (a Thursday),
1FC submitted claims for 15 members. Of those 15 members, 1FC submitted claims
for the full week (5 days plus weekend) for 13 members in accordance with the 5 Days
+ Weekend Formula.9 (Pl.’s Ex. 68 at 141872-78).
94. From January 3, 2022, through January 5, 2023 (a 368-day period), 1FC submitted
approved claims for 67 different members for services rendered over 7-day periods (any
instance where the beginning and end dates of service spanned five weekdays plus the
weekend). 1FC billed a total of 4,705 itemized services for those members during that
time span. For those approved services, whenever 1FC billed for a certain code, it billed
the number of units corresponding with the 5 Days + Weekend Formula at the following
rates:
//
//
//
//
//
8 The other two members were billed for two weekdays plus the weekend. Each
member was billed either exactly or partially in the corresponding formula for two
weekdays plus the weekend. (Pl.’s Ex. 68 at 141859-63).
9 One of the members was billed for one weekday exactly in the corresponding
formula for one day. The other member was billed for five weekdays plus the weekend in
a manner corresponding the with 5 Days + Weekend Formula, but 56 additional units of
H0004(HQ)(12) and 48 additional units of T1016(HN)(12) were billed—a double-billing
accident done in accordance with the “5 Days + Weekend Formula.” (Pl.’s Ex. 68 at
141874-76).
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Time Period: 01/03/22–01/05/23
Dataset: Approved Itemized Services for 7-Day Service Claims
Billing Code
Units Billed
(Corresponding with 5 Days +
Weekend Formula)
Frequency at which
Number of Units was Billed
H0004(11) 4 100.00%
H0004(HQ)(11) 100 99.82%
H0004(HQ)(12) 56 96.77%
H2014(11) 48 96.69%
H2027(12) 72 91.98%
T1016(HN)(11) 40 99.89%
T1016(HN)(12) 48 96.70%
(Pl.’s Ex. 68 at 141833-42). For example, the table above demonstrates that whenever
1FC submitted an itemized claim for H0004(11), it billed 4 units for that service every
single time.
iv. Overall Summary Statistics of 1FC’s AHCCCS Billing
95. From February 2021 through March 2023, 1FC submitted claims for 178 members
when using a combination of the three face-to-face service codes (H0004, H2014, and
H2027) and the one case management code (T1016). Over this period, on average, 1FC
billed 9.6 hours of face-to-face services for each member per day billed, and 2.7 hours
of case management services for each member per day billed—culminating in an
average of 12.3 hours of service for each member per day billed.10 (Pl.’s Ex. 68 at
141879-85).
96. Over this 50-month period, there were nine members who were purported to have
received services for more than 365 days (ranging from 383 days to 615 days), for an
average of 13.1 hours of services per day billed—netting 1FC $3.78 million from
AHCCCS from these nine members alone. (Pl.’s Ex. 68 at 141885).
10 These calculations give 1FC the benefit of the doubt and assume that services were
rendered on Sundays—even though 1FC represented to AHCCCS that it was closed on
Sunday.
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97. 1FC’s case management billing was extremely high. For example:
(a) In the week of December 30, 2022, to January 5, 2023, 1FC billed a total
of 328 hours of case management (T1016) across 16 members.
(b) From May 9 to May 15, 2022, it billed a total of 399 hours of case
management across 19 members.
(c) From August 1 to August 7, 2022, it billed a total of 299 hours of case
management across 15 members.
To accomplish that amount of case management, 1FC would have needed to hire at
least five case managers working at or more than 60 hours per week.
F. Money Laundering (Counts 16-17, 20, 22-26)
98. From March 2, 2021, to March 23, 2022, AHCCCS deposited a total of $6,105,447.44
in 1FC’s BofA x7401 account. (Pl.’s Ex. 76 at 141922-24). This dollar amount
matched AHCCCS’s records of 1FC claims submitted and approved from February 24,
2021, through March 23, 2022. (Pl.’s Ex. 75 at 141918-21; Pl.’s Ex. 77).
99. From March 2, 2021, to March 25, 2022, the BofA x7401 account had a total of
$6,389,037.95 in inflows. 95.56% of those inflows consisted of payments from
AHCCCS ($6,105,447.44, as described above). 3.03% of those inflows ($193,489.27)
consisted of transfers from three other 1FC accounts: BofA x8136, BofA x8149, and
BofA x6094. A significant source of funding for these three accounts comprised of
deposits from the BofA x7401 account itself. (Pl.’s Exs. 79-81). The remaining 1.41%
of inflows ($90,101.24) consisted of a combination of returned items, cash, and other
miscellaneous transactions. (Pl.’s Ex. 91).
100. From March 1, 2021, to March 25, 2022, the total balance of the BofA x7401
account rose from $0.16 to $172,025.97. (Pl.’s Ex. 90).
i. Count 20: Land Rover of North Scottsdale
101. On May 12, 2021, 1FC filled out a withdrawal slip of $54,000.00 from the BofA
x7401 account. From that withdrawal, 1FC purchased a cashier’s check of $54,000.00,
payable to Land Rover of North Scottsdale. (Pl.’s Ex. 92 at 62980, 62982).
102. Thvoughn Curry used the cashier’s check to finance the purchase of a 2021 Land
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Rover Range Rover vehicle from Jaguar Land Rover North Scottsdale. (Pl.’s Ex. 92 at
5363).
ii. Count 22: Courtesy CDJR
103. On October 13, 2021, 1FC filled out a withdrawal slip of $34,500.00 from the BofA
x7401 account. From that withdrawal, 1FC purchased a cashier’s check of $32,000.00,
payable to Courtesy CDJR. (Pl.’s Ex. 93 at 63199, 63202).
104. Alexis Curry used the cashier’s check to finance the purchase of a 2021 Ram 1500
vehicle from Courtesy CDJR of Superstition Springs. (Pl.’s Ex. 93 at 4612; Pl.’s Ex.
51 at 4627, 4646-4648).
iii. Count 23: Earnhardt Buick GMC
105. On January 24, 2022, 1FC filled out a withdrawal slip of $126,542.72 from the BofA
x7401 account. From that withdrawal, 1FC purchased a cashier’s check of
$126,542.72, payable to Earnhardt Buick GMC. (Pl.’s Ex. 94 at 62877, 62879).
iv. Count 24: Mercedez Benz of Gilbert
106. On February 5, 2022, 1FC filled out a withdrawal slip of $116,000.00 from the BofA
x7401 account. From that withdrawal, 1FC purchased a cashier’s check of
$116,000.00, payable to Mercedes Benz of Gilbert. (Pl.’s Ex. 95 at 62889, 62891).
107. The 1 Family Clinic Business Trust used the cashier’s check to finance the purchase
of a 2022 Mercedes LT GLE 43 C4 vehicle from Mercedez Benz of Gilbert. A copy of
Thvoughn Curry’s driver’s license was submitted as a part of the vehicle purchase
agreement. (Pl.’s Ex. 95 at 5561-62).
v. Count 25: Pioneer Title
108. On February 18, 2022, 1FC filled out a withdrawal slip of $10,665.10 from the BofA
x7401 account. From that withdrawal, 1FC purchased a cashier’s check of $10,665.10,
payable to Pioneer Title. (Pl.’s Ex. 96).
vi. Count 26: Scottsdale Ferrari/Maserati
109. On March 16, 2022, 1FC filled out a withdrawal slip of $298,243.92 from the BofA
x7401 account. From that withdrawal, 1FC purchased a cashier’s check of
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$298,243.92, payable to Scottsdale Ferrari/Maserati. (Pl.’s Ex. 97 at 62906, 62908).
110. D.A.T. Auto Group LLC used the cashier’s check to finance the purchase of a 2019
Lamborghini Urus vehicle from Scottsdale Ferrari. Thvoughn Curry signed the vehicle
purchase agreement. (Pl.’s Ex. 97 at 129456-57). Thvoughn Curry was the sole
statutory agent, member, manager, and organizer of D.A.T. Auto Group LLC. (Pl.’s
Ex. 23).
vii. Count 16: CDJR Superstition Springs
111. On March 16, 2022, 1FC filled out a withdrawal slip of $91,923.29 from the BofA
x7401 account. From that withdrawal, 1FC purchased a cashier’s check of $91,923.29,
payable to CDJR of Superstition Springs. (Pl.’s Ex. 98 at 62909, 62911).
112. Curry’s Enterprise LLC used the cashier’s check to finance the purchase of a 2022
Ram 1500 vehicle from Courtesy CDJR of Superstition Springs. Thvoughn Curry
signed the vehicle purchase agreement. (Pl.’s Ex. 98 at 4767). Thvoughn Curry was
the sole statutory agent and organizer of Curry’s Enterprise LLC. Both Alexis Curry
and Thvoughn Curry were managers of Curry’s Enterprise LLC. (Pl.’s Ex. 24).
viii. Count 17: WFG Title
113. On March 25, 2022, 1FC filled out a withdrawal slip of $314,094.12 from the BofA
x7401 account. From that withdrawal, 1FC purchased a cashier’s check of
$303,912.60, payable to WFG Title. (Pl.’s Ex. 99 at 62919, 62925).
114. D.A.T. Auto Group LLC used the cashier’s check to finance the purchase of real
estate, located at 630 N Windsor, Mesa, Arizona 85213. (Pl.’s Ex. 99 at 123599-600).
CONCLUSIONS OF LAW
A. Conspiracy (18 U.S.C. § 1349)
i. Count 1: Conspiracy to commit wire fraud and healthcare fraud
1. The Government alleges that Defendants entered a conspiracy to commit healthcare
fraud and wire fraud from July 2020 through December 2023. The Government has
met its burden beyond a reasonable doubt in establishing that Defendants conspired to
commit healthcare fraud.
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2. First, the Government has proven, beyond a reasonable doubt, that there was an
agreement between Thvoughn Curry and Alexis Curry to commit healthcare fraud, in
violation of 18 U.S.C. § 1347, beginning in July 2020 and continuing through
December 2023. See 18 U.S.C. § 1349; Ninth Circuit Manual of Model Criminal Jury
Instructions § 11.1 (2022 ed., updated June 2024).
3. There was a plan between the Defendants to defraud AHCCCS, a healthcare benefit
program. The plan started at the time of 1FC’s formation in July 2020. (Pl.’s Ex. 21).
It continued when Defendants in November 2020 submitted a false application to
AHCCCS to conceal Thvoughn Curry’s involvement in 1FC. The AHCCCS
application asked, for any individual with an ownership interest in 1FC, whether there
were any “pending proceedings, such as but not limited to an indictment, pending plea,
or investigation, that could result in any sanction, conviction, or action.” (Pl.’s Ex. 1
at 14 (emphasis added)). Defendants knew that Thvoughn Curry had an arrest warrant
from Florida—issued in October 2018—stemming from state felony fraud charges.
(Pl.’s Ex. 25). In August 2020, prior to submitting the application, Defendants
discussed how long warrants lasted and noted that the arrest warrant in question was
issued in 2018. (Pl.’s Ex. 36 at 141767-68). Defendants thus were aware that
Thvoughn Curry’s active arrest warrant posed a problem for the approval of 1FC’s
AHCCCS application.
4. To avoid this problem, Defendants conspired to submit a false application to AHCCCS.
In October 2020, Alexis Curry submitted documentation with the Arizona Corporation
Commission adding herself as a manager for 1FC. (Pl.’s Ex. 22). Alexis Curry then
omitted any mention of Thvoughn Curry’s name throughout 1FC’s AHCCCS
application. (See generally Pl.’s Ex. 1). Alexis Curry falsely represented in the
application that she was the 100% owner of 1FC. (Id. at 12). She then falsely
represented that there were no pending proceedings, such as an investigation, against
any individuals with ownership interest in 1FC that could result in any sanction,
conviction, or action (id. at 14)—even though Thvoughn Curry was an owner of 1FC
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and had an active arrest warrant at the time the application was submitted.
5. These false representations were material—they had the tendency to influence
AHCCCS to part with money. Julie Culton, an employee in AHCCCS’s Office of
Inspector General, testified that an entity seeking to become an AHCCCS provider
needed to be properly vetted by AHCCCS before securing approval. Had AHCCCS
known about Thvoughn Curry’s involvement in 1FC, AHCCCS likely would have
delayed its decision on the application and elevated it to a second-level review, which
could have resulted in the denial of 1FC’s application.
6. Upon the approval of 1FC’s application to provide outpatient services, Defendants next
formed an agreement to fraudulently bill AHCCCS for purported services. As
demonstrated by their text messages (see Pl.’s Ex. 36 at 141776-78, 141780, 141787-
92, 141795, 141797-98, 141802-04), both Defendants submitted claims to AHCCCS
for reimbursement, sharing the username and password for Alexis Curry’s 1FC
AHCCCS account. (Pl.’s Ex. 36 at 141772). All but four of the claims submitted to
AHCCCS from February 2021 to April 2023 were submitted through this account.
(Pl.’s Ex. 4).
7. Defendants’ text messages further demonstrate that Defendants agreed to submit
billings in accord with a predetermined formula—the “5 Days + Weekend Formula”—
which allowed for modifications depending on the number of days that a client
purportedly received services. The formula did not reflect services actually provided.
(See Pl.’s Ex. 36 at 141780-81, 141795-96, 141802-04; see also Pl.’s Ex. 38).
8. Defendants’ billing formula was pervasive throughout 1FC’s billing submissions.
From January 3, 2022, to January 5, 2023, 1FC used a set number of units for each CPT
code, billing that set number for all or nearly all instances of that code for 7-day period
claims:
//
//
//
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Time Period: 01/03/22–01/05/23
Dataset: Itemized Services for Approved 7-Day Service Claims
Billing Code
Units Billed
(Corresponding with 5 Days +
Weekend Formula)
Frequency at which
Number of Units was Billed
H0004(11) 4 100.00%
H0004(HQ)(11) 100 99.82%
H0004(HQ)(12) 56 96.77%
H2014(11) 48 96.69%
H2027(12) 72 91.98%
T1016(HN)(11) 40 99.89%
T1016(HN)(12) 48 96.70%
(Pl.’s Ex. 68 at 141833-42). From February 2021 through March 2023, 1FC’s average
daily billing was 12.3 hours of service per member, including 9.6 hours of face-to-face
treatment (through a mix of in-office and at-home services) and 2.7 hours of case
management. (Pl.’s Ex. 68 at 141879-85).
9. The formula and average billing hours were not in accordance with the hours of
operation that 1FC represented in its AHCCCS application. There, it stated that its
primary practice location—the only physical office space used by 1FC—would be open
from 8:00 a.m. to 4:00 pm from Monday to Friday; 9:00 a.m. to 2:00 p.m. on Saturday;
and closed on Sunday (totaling 45 hours a week). (Pl.’s Ex. 1 at 7). 1FC also
advertised, on a flyer shared by Defendants via text messages, that it had those same
hours of business. (Pl.’s Ex. 37 at 141805). Moreover, 1FC’s “Daily Activities
Schedule” (also circulated between Defendants in their text messages) indicated that
only a total of 4 hours and 40 minutes of group activities or lessons were planned at the
primary practice facility each day. (Id. at 141808). Yet under the 5 Days + Weekend
Formula, 1FC billed as if a member received 69 or 70 hours of services per week
(depending on if 1FC used the H0004(11) code). On any given week, based on the
formula, a member was expected to receive:
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(a) 39 hours of group services and 30-31 hours of individualized counseling.
(b) 37-38 hours of services in the office and 32 hours of services at home.
10. Loretta Lizarraga, an investigator with AHCCCS, testified that an AHCCCS-approved
provider is expected to bill for services according to its designated provider type (here,
outpatient services) and for hours in accordance with the hours of operation submitted
to AHCCCS. But here, 1FC did not inform AHCCCS that it would be providing
additional hours of service outside of its primary practice location—another material
omission in 1FC’s AHCCCS application.
11. The number of hours billed by 1FC per patient was not typical of those seen at an
outpatient facility, which generally only provide a low number of hours of care per date
of service, in contrast with a BHRF or an inpatient treatment facility. These high
billings resulted in a large windfall for 1FC. When following the 5 Days + Weekend
formula, 1FC expected to receive ~$6,300 from AHCCCS for each patient every week.
(See, e.g., Pl.’s Ex. 10). Yet if 1FC was licensed to operate as a BHRF, where its clients
would receive constant supervision, 24 hours a day, it would have only received
~$2,100 from AHCCCS for each patient every week to provide housing, oversight, and
behavioral health services—a third of the amount it was billing for as an outpatient
provider.
12. Nor were the hours submitted in accordance with what occurred at 1FC’s office and
houses.
(a) Daniel Brown, an employee of 1FC from December 2022 to June 2023,
testified that only he provided group lessons at the facility, in general
accordance with the hours listed on the Daily Activities Schedule.
Brown held only a high school diploma and had received no other formal
training to provide such services. His lessons generally consisted of
group discussions, doing crossword puzzles and worksheets, and
watching movies. Brown did not lead any group sessions at the clients’
houses.
(b) Additionally, there was only one individual, Wayman, at 1FC’s primary
practice facility who provided one-on-one client services for usually no
more than three clients a day, for 30-60 minutes per session. Wayman
did not host any individual counseling sessions at the clients’ houses.
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Moreover, there was only one room at 1FC’s primary practice location
where individualized counseling sessions were offered (Pl.’s Ex. 39,
Room 3), making it utterly impossible that 1FC would be able to offer 30
to 31 hours of individualized counseling per week for each member.
(c) Furthermore, there were only two case managers working at 1FC’s
primary practice facility at the same time—far shy of the five case
managers needed, each working more than 60 hours a week, to meet the
number of case management hours that 1FC billed for certain weeks.
13. Second, the Government has proven, beyond a reasonable doubt, that each Defendant
knowingly and willfully participated in the conspiracy to further its object of healthcare
fraud. See 18 U.S.C. §§ 1347, 1349; Ninth Circuit Manual of Model Criminal Jury
Instructions § 11.1 (2022 ed., updated June 2024).
14. Defendants knowingly participated in the conspiracy. An act is done knowingly if the
defendant is aware of the act and does not act through ignorance, mistake, or accident.
Ninth Circuit Manual of Model Criminal Jury Instructions § 4.8 (2022 ed., updated
Sept. 2022). As described above, Defendants shared details of the 1FC AHCCCS login
credentials, devised the formula for billing submissions, and submitted claims to
AHCCCS. They jointly opened four bank accounts under 1FC’s name to receive
payment from AHCCCS. (Pl.’s Exs. 70, 74, 78-81).
15. As further evidenced by their text messages, Defendants were motivated to participate
in the conspiracy in order to fund their luxury lifestyle. From the beginning of March
2021 to the end of March 2022, the total balance on Defendants’ BofA x7401 account
rose from $0.16 to $172,025.97. (Pl.’s Ex. 90). Defendants discussed the need to get
“more clients ASAP” to reach a goal of $312,000 in AHCCCS payments every month.
(Pl.’s Ex. 36 at 141776-78). That goal continued to increase as the Defendants began
billing for more clients. (Id. at 141798 (“We need half a mill a week”); id. at 141782-
86 (“80 clients a week child that $486,704 a week”)). They mentioned a month-long
vacation with a $50,000 budget. (Id. at 141799). 1FC ultimately received over $12
million from AHCCCS for services that were purportedly rendered. (Pl.’s Ex. 66 at
141935). It billed, on average, more than $67,000 for each member that it purportedly
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treated. (Pl.’s Ex. 68). With the proceeds of their conspiracy, Defendants were able to
purchase real estate and luxury vehicles (see Pl.’s Exs. 92-99), including a ~$300,000
2019 Lamborghini Urus (Pl.’s Ex. 97).
16. Additionally, Defendants willfully participated in the conspiracy. In the healthcare
fraud context, a “willful” act is one undertaken with a “bad purpose” with knowledge
that the conduct was, in a general sense, unlawful. See United States v. Awad, 551
F.3d 930, 939 (9th Cir. 2009) (quoting Bryan v. United States, 524 U.S. 184, 191-92
(1998)); 18 U.S.C. § 1347(b); (see also Doc. 128 at 3). The Government need not prove
that the defendant had “actual knowledge” of the federal healthcare fraud statute or had
the “specific intent to commit a violation” of the statute. 18 U.S.C. § 1347(b). Willful
intent “can be inferred from efforts to conceal the unlawful activity, from
misrepresentations, from proof of knowledge, and from profits.” United States v.
Dearing, 504 F.3d 897, 901 (9th Cir. 2007) (quoting United States v. Davis, 490 F.3d
541, 549 (6th Cir. 2007)).
17. Defendants’ actions were undertaken with a bad purpose with knowledge that the
conduct was generally unlawful. As described above, Defendants were aware that
Thvoughn Curry’s active arrest warrant could hinder the approval of their AHCCCS
application—so they concealed him from the application altogether. In the Provider
Participation Agreement (PPA), signed by Alexis Curry, 1FC acknowledged that it
would comply with all federal, state, and local laws and rules governing the
performance of its duties as an outpatient provider. (Pl.’s Ex. 1 at 16-20). 1FC
warranted that it had the ability, authority, skill, expertise, and capacity to perform and
provide outpatient services; agreed to bill for services provided; and acknowledged that
AHCCCS would suspend any payments to 1FC pending an investigation of a “credible
allegation of fraud.” Defendants were thus aware that the submission of claims to
AHCCCS for services not actually rendered was generally impermissible under the law.
18. Finally, Defendants acted with the intent to defraud that is, the intent to deceive and
cheat. Intent to defraud may be proven through reckless indifference to the truth or
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falsity of statements. Dearing, 504 F.3d at 903. By billing in accordance with a
predetermined billing formula, Defendants demonstrated a reckless indifference to the
truth or falsity of their claim submissions. Defendants were focused on obtaining as
many clients as possible at 1FC to increase their total payments from AHCCCS. (Pl.’s
Ex. 36 at 141776-78, 141782-86). Defendants took advantage of the American Indian
Health Program (AIHP), which used fee-for-service billing, to receive direct payments
from AHCCCS. The presence of clients at the 1FC houses maintained the air of
legitimacy around 1FC’s operations. Defendants incentivized 1FC’s clients to remain
at the houses by taking them to outings, watching movies with them, and covering their
shelter costs. By housing its clients, Defendants believed that 1FC would be able to
claim that it was providing group outpatient services at home, in accordance with
Defendants’ billing formula, even though no such services were rendered at the houses.
19. Defendants thus are GUILTY on Count 1 of the superseding indictment.11
B. Wire Fraud (18 U.S.C. § 1343)
ii. Count 2: $77,170.34 wire transfer from AHCCCS to Defendants on 1/10/2022
20. The Government alleges that Defendants committed wire fraud by causing AHCCCS
to wire $77,170.34 to Defendants’ BofA x7401 account on January 10, 2022, based on
claims for services rendered between December 18 and December 26, 2021. But the
Government has failed to prove that the Defendants used an interstate wire
communication to carry out an essential part of their scheme. See 18 U.S.C. § 1343;
Ninth Circuit Manual of Model Criminal Jury Instructions § 15.35 (2022 ed., updated
11 Defendants submit that the Court must also find that one of the members of the
conspiracy performed at least one overt act for the purpose of carrying out the conspiracy.
(Doc. 127 at 2). The Government has proved the commission of at least one overt for each
Defendant beyond a reasonable doubt. Both Defendants committed several overt acts,
including creating the 1FC entity (Thvoughn Curry), submitting the AHCCCS application
(Alexis Curry), opening the four 1FC Bank of America accounts to receive AHCCCS
deposits (Alexis Curry and Thvoughn Curry), and billing AHCCCS for purported
outpatient services (Alexis Curry and Thvoughn Curry). Regardless, a conspiracy charge
brought under 18 U.S.C. § 1349 does not require the Government to prove an overt act.
See 18 U.S.C. § 1349; Whitfield v. United States, 543 U.S. 209, 213-14 (2005); see also
United States v. Roy, 783 F.3d 418, 420 (2d Cir. 2015) (adopting the finding of “many
other Circuits” that a § 1349 conviction “does not require proof of an overt act” (citing
string of cases)).
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Sept. 2025).
21. The Government introduced testimony that the AHCCCS mainframe server—through
which all provider billing claims travel—was located in Arizona in 2017 and is located
in Colorado in 2026. But it offered no other evidence or testimony as to the location of
the server in the interim.
22. The claims corresponding with the $77,170.34 wire transfer from AHCCCS to the
BofA x7401 account were submitted by Defendants sometime between December 26,
2021, and January 10, 2022. With no evidence of the server’s location during this brief
period, the Government has not provided sufficient evidence to support a conviction of
wire fraud.
23. Defendants thus are NOT GUILTY on Count 2 of the superseding indictment.
C. Health Care Fraud (18 U.S.C. § 1347)
iii. Count 6: Billing of $6,255.60 related to patient M.B. on 5/20/2022
24. First, Defendants knowingly and willfully executed a scheme to defraud AHCCCS by
means of materially false or fraudulent pretenses, representations, or promises. See 18
U.S.C. § 1347; Ninth Circuit Manual of Model Criminal Jury Instructions § 15.42 (2022
ed.). The general scheme utilized by Defendants is described above in the conspiracy
count section. From May 9 to May 15, 2022 (five weekdays plus the weekend),
Defendants submitted a claim of $6,255.60 for patient M.B., following the exact pattern
of the 5 Days + Weekend Formula for the CPT codes billed. 1FC represented that it
had provided patient M.B. with 69 hours of face-to-face treatment and 22 hours of case
management during this single week. Further, 1FC’s primary practice location was
purportedly open for only 45 hours that week. (Pl.’s Ex. 10; Pl.’s Ex. 2). 1FC’s claim
for patient M.B. was a materially false statement that had the natural tendency to
influence AHCCCS to part with money, as it gave AHCCCS the impression that 1FC
was providing legitimate outpatient services to patient M.B. over the period in question.
25. Second, Defendants acted with the intent to defraud. Defendants’ intent to defraud,
generally, is described above in the conspiracy count section. Defendants demonstrated
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a reckless indifference to truth or falsity of their claim submission for patient M.B. by
following the 5 Days + Weekend formula. Moreover, 1FC frequently submitted claims
on behalf of patient M.B.—from February 2021 to March 2023, 1FC billed for 455 days
of service purportedly provided to M.B., for over 13 hours of service per day, netting
1FC a total $420,177.36 in reimbursements for this one patient alone.
26. Additionally, Defendants’ intent to defraud is further evidenced by their total billings
for the week of May 9 to May 15, 2022. During that week, 1FC billed a total of 544
hours of individualized counseling (77+ hours/day, including the weekend) and 399
hours of case management (57 hours/day, including the weekend) across 19 members—
figures that, on their face, are not credible and demonstrate a reckless indifference to
truth or falsity of the submissions. (See Pl.’s Ex. 2, “ALL SERVICES” tab). For
example, 1FC would have needed 9 counselors and 6 case managers, each working
more than 60 hours per week, to meet those billing numbers. But based on the size and
configuration of 1FC’s office, 1FC would not have been able to fit all these employees
in its office space. (See Pl.’s Ex. 39 (Room 3 was for the individual counselor and room
4 was for the case managers)).
27. Third, AHCCCS is a healthcare benefit program. AHCCCS is Arizona’s federally
funded Medicaid agency. The purpose of AHCCCS is to administer healthcare services
to low-income residents of Arizona.
28. Fourth, the scheme in question was executed in connection with payment of $6,255.60
for the purported 91 hours of healthcare services provided to patient M.B. from May 9
to May 15, 2022. (Pl.’s Ex. 10; Pl.’s Ex. 2).
29. Defendants thus are GUILTY on Count 6 of the superseding indictment.
iv. Count 8: Billing of $5,476.56 related to patient F.C. on 1/27/2023
30. First, Defendants knowingly and willfully executed a scheme to defraud AHCCCS by
means of materially false or fraudulent pretenses, representations, or promises. The
general scheme utilized by Defendants is described above in the conspiracy count
section. From January 20 to January 25, 2023 (four weekdays plus the weekend),
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Defendants submitted a claim of $5,476.56 for patient F.C., following a modified
version of the 5 Days + Weekend Formula for the CPT codes billed. Defendants
discussed this modified version of the formula—for 4 weekdays plus the weekend—
via text messages. (Pl.’s Ex. 36 at 141795-96; Pl.’s Ex. 38). 1FC represented that it
had provided patient F.C. with 58 hours of face-to-face treatment and 18 hours of case
management over the six-day period. Further, 1FC’s primary practice location was
purportedly open for only 37 hours over that time. (Pl.’s Ex. 11; Pl.’s Ex. 2). 1FC’s
claim for patient F.C. was a materially false statement that had the natural tendency to
influence AHCCCS to part with money, as it gave AHCCCS the impression that 1FC
was providing legitimate outpatient services to patient F.C.
31. Second, Defendants acted with the intent to defraud. Defendants’ intent to defraud,
generally, is described above in the conspiracy count section. Defendants demonstrated
a reckless indifference to truth or falsity of their claim submission for patient F.C. by
following the modified formula.
32. Additionally, Defendants’ intent to defraud is further evidenced by their total billings
for the six-day period of January 20 to January 25, 2023. During that time, 1FC billed
138 hours of individualized counseling (23 hours/day, including the weekend) for 15
members—figures that, on their face, are not credible and demonstrate a reckless
indifference to truth or falsity of the submissions. (See Pl.’s Ex. 2, “ALL SERVICES”
tab). Daniel Brown testified that, from at least December 2022 to June 2023, only one
individual—Wayman—provided individualized counseling at the office, for at most 3
hours a day. Brown also testified that Wayman did not, nor did anyone else, provide
individualized counseling at the houses. Thus, Defendants’ individual counseling
billing would not have been possible to achieve if only Wayman was offering such
services.
33. Third, AHCCCS is a healthcare benefit program. AHCCCS is Arizona’s federally
funded Medicaid agency. The purpose of AHCCCS is to administer healthcare services
to low-income residents of Arizona.
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34. Fourth, the scheme in question was executed in connection with payment of $5,406.48
for the purported 76 hours of healthcare services provided to patient F.C. from January
20 to January 25, 2023. (Pl.’s Ex. 11; Pl.’s Ex. 2).
35. Defendants thus are GUILTY on Count 8 of the superseding indictment.
v. Count 10: Billing of $10,549.78 related to patient A.D. on 8/12/2022
36. First, Defendants knowingly and willfully executed a scheme to defraud AHCCCS by
means of materially false or fraudulent pretenses, representations, or promises. The
general scheme utilized by Defendants is described above in the conspiracy count
section. From August 2 to August 7, 2022 (four weekdays plus the weekend),
Defendants submitted a claim of $10,549.78 for patient A.D., following a modified
version of the 5 Days + Weekend Formula for the CPT codes billed. Defendants
discussed this modified version of the formula—for 4 weekdays plus the weekend—
via text messages. (Pl.’s Ex. 36 at 141795-96; Pl.’s Ex. 38). However, 1FC double
billed the CPT codes for patient A.D. under the formula over the period in question.
1FC represented that it had provided patient A.D. with 116 hours of face-to-face
treatment and 36 hours of case management over the six-day period (AHCCCS only
approved 90 hours of face-to-face treatment and 28 hours of case management).
Further, 1FC’s primary practice location was purportedly open for only 37 hours over
that time. (Pl.’s Ex. 12; Pl.’s Ex. 2). 1FC’s claim for patient A.D. was a materially
false statement that had the natural tendency to influence AHCCCS to part with money,
as it gave AHCCCS the impression that 1FC was providing legitimate outpatient
services to patient A.D.
37. Second, Defendants acted with the intent to defraud. Defendants’ intent to defraud,
generally, is described above in the conspiracy count section. Defendants demonstrated
a reckless indifference to truth or falsity of their claim submission for patient A.D. by
following the modified formula. Defendants’ reckless indifference is further
highlighted by their double-billing error, demonstrating that they were focused on rote
memorization of the billing formula, rather than billing for actual services provided.
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38. Third, AHCCCS is a healthcare benefit program. AHCCCS is Arizona’s federally
funded Medicaid agency. The purpose of AHCCCS is to administer healthcare services
to low-income residents of Arizona.
39. Fourth, the scheme in question was executed in connection with payment of $7,028.28
for the purported and approved 118 hours of healthcare services provided to patient
A.D. from August 2 to August 7, 2022. (Pl.’s Ex. 12; Pl.’s Ex. 2).
40. Defendants thus are GUILTY on Count 10 of the superseding indictment.
D. Transactional Money Laundering (18 U.S.C. § 1957)
vi. Count 20: Withdrawal of $54,000.00 to purchase cashier’s check on 5/12/2021
41. First, on May 12, 2021, Defendants knowingly engaged in a monetary transaction by
withdrawing $54,000.00 from 1FC’s BofA x7401, on which both Alexis Curry and
Thvoughn Curry were signers, and purchasing a cashier’s check of $54,000.00. (Pl.’s
Ex. 74; Pl.’s Ex. 70; Pl.’s Ex. 78). Both the withdrawal and the cashier’s check were
under 1FC’s name. (Pl.’s Ex. 92). See 18 U.S.C. § 1957; Ninth Circuit Manual of
Model Criminal Jury Instructions § 18.7 (2022 ed., updated Sept. 2025).
42. Second, Defendants knew that the transaction involved criminally derived property.
Both Thvoughn Curry and Alexis Curry were aware that AHCCCS was depositing
checks in BofA x7401 and that such proceeds were derived from billings submitted to
AHCCCS as a part of Defendants’ conspiracy to commit healthcare fraud. Defendants
shared the account details with each other (Pl.’s Ex. 36 at 141774); discussed receiving
checks in connection with their AHCCCS billing (id. at 141787-92); and sent the
website link to view their check payments from AHCCCS every Friday (id. at 141794).
43. Third, the cashier’s check of $54,000.00 had a value greater than $10,000.00.
44. Fourth, the funds comprising the $54,000.00 cashier’s check were derived from
Defendants’ conspiracy to commit healthcare fraud.12 The transaction—on May 12,
12 For a money laundering conviction under 18 U.S.C. § 1957, the property must have,
in fact, been derived from a “specified unlawful activity.” A defendant’s conviction on
conspiracy to commit healthcare fraud, alone, is a sufficient specified unlawful activity for
a criminal money laundering violation. Conspiracy to commit healthcare fraud, 18 U.S.C.
§ 1349, is considered a “Federal health care offense” and falls under the definition for a
“specified unlawful activity” under the criminal money laundering statute. See 18 U.S.C.
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2021—took place within the conspiracy’s timeline of July 2020 to December 2023.
The $54,000.00 in funds were all withdrawn from BofA x7401. From 3/2/21 to
3/25/22, that account received a total of $6,389,037.95 in inflows, of which
$6,105,447.44—or 95.56%—were direct reimbursements to 1FC from AHCCCS.
Thus, more than $10,000.00 of the $54,000.00 was criminally derived.
45. Fifth, the transaction occurred in the United States. The cashier’s check was purchased
in Arizona. (Pl.’s Ex. 92).
46. Defendants are thus GUILTY on Count 20 of the superseding indictment.
vii. Count 22: Withdrawal of $32,000.00 to purchase cashier’s check on 10/13/2021
47. First, on October 13, 2021, Defendants knowingly engaged in a monetary transaction
by withdrawing $34,500.00 from 1FC’s BofA x7401, on which both Alexis Curry and
Thvoughn Curry were signers, and purchasing a cashier’s check of $32,000.00. (Pl.’s
Ex. 74; Pl.’s Ex. 70; Pl.’s Ex. 78). Both the withdrawal and the cashier’s check were
under 1FC’s name. (Pl.’s Ex. 93).
48. Second, Defendants knew that the transaction involved criminally derived property.
Both Thvoughn Curry and Alexis Curry were aware that AHCCCS was depositing
checks in BofA x7401 and that such proceeds were derived from billings submitted to
AHCCCS as a part of Defendants’ conspiracy to commit healthcare fraud. Defendants
shared the account details with each other (Pl.’s Ex. 36 at 141774); discussed receiving
checks in connection with their AHCCCS billing (id. at 141787-92); and sent the
website link to view their check payments from AHCCCS every Friday (id. at 141794).
49. Third, the cashier’s check of $32,000.00 had a value greater than $10,000.00.
50. Fourth, the funds comprising the $32,000.00 cashier’s check were derived from
Defendants’ conspiracy to commit healthcare fraud. The transaction—on October 13,
2021—took place within the conspiracy’s timeline of July 2020 to December 2023.
The $32,000.00 in funds were all withdrawn from BofA x7401. From 3/2/21 to
3/25/22, that account received a total of $6,389,037.95 in inflows, of which
§ 1957(f)(3); id. § 1956(c)(7)(F); id. § 24(a)(1).
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$6,105,447.44—or 95.56%—were direct reimbursements to 1FC from AHCCCS .
Thus, more than $10,000.00 of the $32,000.00 was criminally derived.
51. Fifth, the transaction occurred in the United States. The cashier’s check was purchased
in Arizona. (Pl.’s Ex. 93).
52. Defendants are thus GUILTY on Count 22 of the superseding indictment.
viii. Count 23: Withdrawal of $126,542.72 to purchase cashier’s check on 1/24/2022
53. First, on January 24, 2022, Defendants knowingly engaged in a monetary transaction
by withdrawing $126,542.72 from 1FC’s BofA x7401, on which both Alexis Curry and
Thvoughn Curry were signers, and purchasing a cashier’s check of $126,542.72. (Pl.’s
Ex. 74; Pl.’s Ex. 70; Pl.’s Ex. 78). Both the withdrawal and the cashier’s check were
under 1FC’s name. (Pl.’s Ex. 94).
54. Second, Defendants knew that the transaction involved criminally derived property.
Both Thvoughn Curry and Alexis Curry were aware that AHCCCS was depositing
checks in BofA x7401 and that such proceeds were derived from billings submitted to
AHCCCS as a part of Defendants’ conspiracy to commit healthcare fraud. Defendants
shared the account details with each other (Pl.’s Ex. 36 at 141774); discussed receiving
checks in connection with their AHCCCS billing (id. at 141787-92); and sent the
website link to view their check payments from AHCCCS every Friday (id. at 141794).
55. Third, the cashier’s check of $126,542.72 had a value greater than $10,000.00.
56. Fourth, the funds comprising the $126,542.72 cashier’s check were derived from
Defendants’ conspiracy to commit healthcare fraud. The transaction—on January 24,
2022—took place within the conspiracy’s timeline of July 2020 to December 2023.
The $32,000.00 in funds were all withdrawn from the BofA x7401 account. From
3/2/21 to 3/25/22, that account received a total of $6,389,037.95 in inflows, of which
$6,105,447.44—or 95.56%—were direct reimbursements to 1FC from AHCCCS.
Thus, more than $10,000.00 of the $126,542.72 was criminally derived.
57. Fifth, the transaction occurred in the United States. The cashier’s check was purchased
in Arizona. (Pl.’s Ex. 94).
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58. Defendants are thus GUILTY on Count 23 of the superseding indictment.
ix. Count 24: Withdrawal of $116,000.00 to purchase cashier’s check on 2/5/2022
59. First, on February 5, 2022, Defendants knowingly engaged in a monetary transaction
by withdrawing $116,000.00 from 1FC’s BofA x7401, on which both Alexis Curry and
Thvoughn Curry were signers, and purchasing a cashier’s check of $116,000.00. (Pl.’s
Ex. 74; Pl.’s Ex. 70; Pl.’s Ex. 78). Both the withdrawal and the cashier’s check were
under 1FC’s name. (Pl.’s Ex. 95).
60. Second, Defendants knew that the transaction involved criminally derived property.
Both Thvoughn Curry and Alexis Curry were aware that AHCCCS was depositing
checks in BofA x7401 and that such proceeds were derived from billings submitted to
AHCCCS as a part of Defendants’ conspiracy to commit healthcare fraud. Defendants
shared the account details with each other (Pl.’s Ex. 36 at 141774); discussed receiving
checks in connection with their AHCCCS billing (id. at 141787-92); and sent the
website link to view their check payments from AHCCCS every Friday (id. at 141794).
61. Third, the cashier’s check of $116,000.00 had a value greater than $10,000.00.
62. Fourth, the funds comprising the $116,000.00 cashier’s check were derived from
Defendants’ conspiracy to commit healthcare fraud. The transaction—on February 5,
2022—took place within the conspiracy’s timeline of July 2020 to December 2023.
The $116,000.00 in funds were all withdrawn from BofA x7401. From 3/2/21 to
3/25/22, that account received a total of $6,389,037.95 in inflows, of which
$6,105,447.44—or 95.56%—were direct reimbursements to 1FC from AHCCCS.
Thus, more than $10,000.00 of the $116,000.00 was criminally derived.
63. Fifth, the transaction occurred in the United States. The cashier’s check was purchased
in Arizona. (Pl.’s Ex. 95).
64. Defendants are thus GUILTY on Count 24 of the superseding indictment.
x. Count 25: Withdrawal of $10,665.10 to purchase cashier’s check on 2/18/2022
65. First, on February 18, 2022, Defendants knowingly engaged in a monetary transaction
by withdrawing $10,665.10 from 1FC’s BofA x7401, on which both Alexis Curry and
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Thvoughn Curry were signers, and purchasing a cashier’s check of $10,665.10. (Pl.’s
Ex. 74; Pl.’s Ex. 70; Pl.’s Ex. 78). Both the withdrawal and the cashier’s check were
under 1FC’s name. (Pl.’s Ex. 96).
66. Second, Defendants knew that the transaction involved criminally derived property.
Both Thvoughn Curry and Alexis Curry were aware that AHCCCS was depositing
checks in BofA x7401 and that such proceeds were derived from billings submitted to
AHCCCS as a part of Defendants’ conspiracy to commit healthcare fraud. Defendants
shared the account details with each other (Pl.’s Ex. 36 at 141774); discussed receiving
checks in connection with their AHCCCS billing (id. at 141787-92); and sent the
website link to view their check payments from AHCCCS every Friday (id. at 141794).
67. Third, the cashier’s check of $10,665.10 had a value greater than $10,000.00.
68. Fourth, the funds comprising the $10,665.10 cashier’s check were derived from
Defendants’ conspiracy to commit healthcare fraud. The transaction—on February 18,
2022—took place within the conspiracy’s timeline of July 2020 to December 2023.
The $10,665.10 in funds were all withdrawn from BofA x7401. From 3/2/21 to
3/25/22, that account received a total of $6,389,037.95 in inflows, of which
$6,105,447.44—or 95.56%—were direct reimbursements to 1FC from AHCCCS.
Thus, more than $10,000.00 of the $10,665.10 was criminally derived.
69. Fifth, the transaction occurred in the United States. The cashier’s check was purchased
in Arizona. (Pl.’s Ex. 96).
70. Defendants are thus GUILTY on Count 25 of the superseding indictment.
xi. Count 26: Withdrawal of $298,243.92 to purchase cashier’s check on 3/16/2022
71. First, on March 16, 2022, Defendants knowingly engaged in a monetary transaction by
withdrawing $298,243.92 from 1FC’s BofA x7401, on which both Alexis Curry and
Thvoughn Curry were signers, and purchasing a cashier’s check of $298,243.92. (Pl.’s
Ex. 74; Pl.’s Ex. 70; Pl.’s Ex. 78). Both the withdrawal and the cashier’s check were
under 1FC’s name. (Pl.’s Ex. 97).
72. Second, Defendants knew that the transaction involved criminally derived property.
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Both Thvoughn Curry and Alexis Curry were aware that AHCCCS was depositing
checks in BofA x7401 and that such proceeds were derived from billings submitted to
AHCCCS as a part of Defendants’ conspiracy to commit healthcare fraud. Defendants
shared the account details with each other (Pl.’s Ex. 36 at 141774); discussed receiving
checks in connection with their AHCCCS billing (id. at 141787-92); and sent the
website link to view their check payments from AHCCCS every Friday (id. at 141794).
73. Third, the cashier’s check of $298,243.92 had a value greater than $10,000.00.
74. Fourth, the funds comprising the $298,243.92 cashier’s check were derived from
Defendants’ conspiracy to commit healthcare fraud. The transaction—on March 16,
2022—took place within the conspiracy’s timeline of July 2020 to December 2023.
The $298,243.92 in funds were all withdrawn from BofA x7401. From 3/2/21 to
3/25/22, that account received a total of $6,389,037.95 in inflows, of which
$6,105,447.44—or 95.56%—were direct reimbursements to 1FC from AHCCCS.
Thus, more than $10,000.00 of the $298,243.92 was criminally derived.
75. Fifth, the transaction occurred in the United States. The cashier’s check was purchased
in Arizona. (Pl.’s Ex. 97).
76. Defendants are thus GUILTY on Count 26 of the superseding indictment.
xii. Count 16: Withdrawal of $91,923.29 to purchase cashier’s check on 3/21/2022
77. First, on March 21, 2022, Defendants knowingly engaged in a monetary transaction by
withdrawing $91,923.29 from 1FC’s BofA x7401, on which both Alexis Curry and
Thvoughn Curry were signers, and purchasing a cashier’s check of $91,923.29. (Pl.’s
Ex. 74; Pl.’s Ex. 70; Pl.’s Ex. 78). Both the withdrawal and the cashier’s check were
under 1FC’s name. (Pl.’s Ex. 98).
78. Second, Defendants knew that the transaction involved criminally derived property.
Both Thvoughn Curry and Alexis Curry were aware that AHCCCS was depositing
checks in BofA x7401 and that such proceeds were derived from billings submitted to
AHCCCS as a part of Defendants’ conspiracy to commit healthcare fraud. Defendants
shared the account details with each other (Pl.’s Ex. 36 at 141774); discussed receiving
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checks in connection with their AHCCCS billing (id. at 141787-92); and sent the
website link to view their check payments from AHCCCS every Friday (id. at 141794).
79. Third, the cashier’s check of $91,923.29 had a value greater than $10,000.00.
80. Fourth, the funds comprising the $91,923.29 cashier’s check were derived from
Defendants’ conspiracy to commit healthcare fraud. The transaction—on March 21,
2022—took place within the conspiracy’s timeline of July 2020 to December 2023.
The $91,923.29 in funds were all withdrawn from BofA x7401. From 3/2/21 to
3/25/22, that account received a total of $6,389,037.95 in inflows, of which
$6,105,447.44—or 95.56%—were direct reimbursements to 1FC from AHCCCS.
Thus, more than $10,000.00 of the $91,923.29 was criminally derived.
81. Fifth, the transaction occurred in the United States. The cashier’s check was purchased
in Arizona. (Pl.’s Ex. 98).
82. Defendants are thus GUILTY on Count 16 of the superseding indictment.
xiii. Count 17: Withdrawal of $303,912.60 to purchase cashier’s check on 3/25/2022
83. First, on March 25, 2022, Defendants knowingly engaged in a monetary transaction by
withdrawing $314,094.12 from 1FC’s BofA x7401, on which both Alexis Curry and
Thvoughn Curry were signers, and purchasing a cashier’s check of $303,912.60. (Pl.’s
Ex. 74; Pl.’s Ex. 70; Pl.’s Ex. 78). Both the withdrawal and the cashier’s check were
under 1FC’s name. (Pl.’s Ex. 99).
84. Second, Defendants knew that the transaction involved criminally derived property.
Both Thvoughn Curry and Alexis Curry were aware that AHCCCS was depositing
checks in BofA x7401 and that such proceeds were derived from billings submitted to
AHCCCS as a part of Defendants’ conspiracy to commit healthcare fraud. Defendants
shared the account details with each other (Pl.’s Ex. 36 at 141774); discussed receiving
checks in connection with their AHCCCS billing (id. at 141787-92); and sent the
website link to view their check payments from AHCCCS every Friday (id. at 141794).
85. Third, the cashier’s check of $303,912.60 had a value greater than $10,000.00.
86. Fourth, the funds comprising the $303,912.60 cashier’s check were derived from
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Defendants’ conspiracy to commit healthcare fraud. The transaction—on March 25,
2022—took place within the conspiracy’s timeline of July 2020 to December 2023.
The $303,912.60 in funds were all withdrawn from BofA x7401. From 3/2/21 to
3/25/22, that account received a total of $6,389,037.95 in inflows, of which
$6,105,447.44—or 95.56%—were direct reimbursements to 1FC from AHCCCS.
Thus, more than $10,000.00 of the $303,912.60 was criminally derived.
87. Fifth, the transaction occurred in the United States. The cashier’s check was purchased
in Arizona. (Pl.’s Ex. 99).
88. Defendants are thus GUILTY on Count 17 of the superseding indictment.
E. Co-Schemer and Aiding-and-Abetting Liability
89. For each of the healthcare fraud counts (6, 8, 10) and money laundering counts (16-17,
20, 22-26), Defendants are liable as either principals, co-schemers, or as aiders and
abettors.
90. The Government has proven beyond a reasonable doubt that each of the healthcare
fraud offenses were those that Defendants could have reasonably foreseen as necessary
and natural consequences of their scheme to commit healthcare fraud. Ninth Circuit
Model Criminal Jury Instruction § 15.33 (2022 ed.); United States v. Martinez, 921 F.3d
452, 472 (5th Cir. 2019) (acknowledging co-schemer liability for healthcare fraud);
United States v. Merino, 846 F. App’x 494, 496 (9th Cir. 2021) (unpublished) (same)
(citing Pinkerton v. United States, 328 U.S. 640 (1946)).
91. The Government has also proven beyond a reasonable doubt that Defendants aided and
abetted each other during the commission of each of the healthcare fraud offenses and
money laundering offenses. Both Defendants took affirmative acts in furtherance of
each offense—such as setting up bank accounts, submitting the AHCCCS application,
withdrawing funds to purchase the cashier’s checks, and billing claims on the AHCCCS
website—with the intent of facilitating the offense’s commission. Rosemond v. United
States, 572 U.S. 65, 71-73 (2014); 18 U.S.C. § 2.
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CONCLUSION
For the reasons stated above, the Court finds that Defendant Alexis Daneen Curry
and Defendant Thvoughn Lynden Curry are guilty of the following counts alleged in the
superseding indictment:
Count Charge Defendant Verdict
1 Conspiracy
(18 U.S.C. § 1349)
Alexis Curry GUILTY
Thvoughn Curry GUILTY
2 Wire Fraud
(18 U.S.C. §§ 1343, 2)
Alexis Curry NOT GUILTY
Thvoughn Curry NOT GUILTY
6 Health Care Fraud
(18 U.S.C. §§ 1347, 2)
Alexis Curry GUILTY
Thvoughn Curry GUILTY
8 Health Care Fraud
(18 U.S.C. §§ 1347, 2)
Alexis Curry GUILTY
Thvoughn Curry GUILTY
10 Health Care Fraud
(18 U.S.C. §§ 1347, 2)
Alexis Curry GUILTY
Thvoughn Curry GUILTY
16 Money Laundering
(18 U.S.C. §§ 1957, 2)
Alexis Curry GUILTY
Thvoughn Curry GUILTY
17 Money Laundering
(18 U.S.C. §§ 1957, 2)
Alexis Curry GUILTY
Thvoughn Curry GUILTY
20 Money Laundering
(18 U.S.C. §§ 1957, 2)
Alexis Curry GUILTY
Thvoughn Curry GUILTY
22 Money Laundering
(18 U.S.C. §§ 1957, 2)
Alexis Curry GUILTY
Thvoughn Curry GUILTY
23 Money Laundering
(18 U.S.C. §§ 1957, 2)
Alexis Curry GUILTY
Thvoughn Curry GUILTY
24 Money Laundering
(18 U.S.C. §§ 1957, 2)
Alexis Curry GUILTY
Thvoughn Curry GUILTY
25 Money Laundering
(18 U.S.C. §§ 1957, 2)
Alexis Curry GUILTY
Thvoughn Curry GUILTY
26 Money Laundering
(18 U.S.C. §§ 1957, 2)
Alexis Curry GUILTY
Thvoughn Curry GUILTY
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Dated this 20th day of February, 2026.
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