Declaration_of_j_christopher_racich__with_exhibits_in_support_of_motion_for_order_addressing_articles_directed_at_defendants_and_defendants_counselMotionCal. Super. - 2nd Dist.June 30, 2016Electronically FILED by os bherir Court of California, County of Los Angeles on 06/09/2020 05:55 PM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Boyadzhyan,Deputy Clerk 10 11 12 13 14 L5 16 17 18 19 20 21 22 23 24 25 26 27 28 MANATT, PHELPS & PHILLIPS, LLP GREGORY N. PIMSTONE (Bar No. 150203) Email: gpimstone@manatt.com JOHN M. LEBLANC (Bar No. 155842) Email: jleblanc@manatt.com ILEANA M. HERNANDEZ (Bar No. 198906) Email: ihernandez@manatt.com 2049 Century Park East, Suite 1700 Los Angeles, CA 90067 Telephone: (310) 312-4000 Facsimile: (310) 312-4224 MANATT, PHELPS & PHILLIPS, LLP KENNETH B. JULIAN (Bar No. 149840) Email: kjulian@manatt.com 695 Town Center Drive, 14th Floor Costa Mesa, CA 92626-1924 Telephone: (714) 371-2500 Facsimile: (714) 371-2550 Attorneys for Defendants HEALTH NET, INC.; HEALTH NET OF CALIFORNIA, INC.; and MANAGED HEALTH NETWORK, INC.; and Defendant and Cross-Complainant HEALTH NET LIFE INSURANCE COMPANY SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES DUAL DIAGNOSIS TREATMENT CENTER, INC, et al., Plaintiffs, VS. HEALTH NET, INC,, et al., Defendants. HEALTH NET LIFE INSURANCE COMPANY, Cross-Complainant, Vs. TONMOY SHARMA, et al., Cross-Defendants. Case No. LC104357 Hon. Virginia Keeny, Dept. W [Van Nuys Courthouse East] DECLARATION OF J. CHRISTOPHER RACICH — WITH EXHIBITS IN SUPPORT OF MOTION FOR ORDER ADDRESSING ARTICLES DIRECTED AT DEFENDANTS AND DEFENDANTS’ COUNSEL Date/Time: June 22, 2020 at 10:00 a.m. Dept.: W Compl. Filed: June 30, 2016 Am. Compl. Filed: October 25, 2016 2nd Am. Compl. Filed: April 9, 2019 Cross-Compl. Filed: February 14, 2017 Am. Cross-Compl. Filed: January 22, 2019 Trial Date: January 25, 2021 DECLARATION OF J. CHRISTOPHER RACICH 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, J. Christopher Racich, declare as follows: L BACKGROUND I. I am the President of Vestigant LLC. Vestigant is a technology and computer forensic consulting firm that assists clients with fact-finding in litigation, regulatory reviews, and business decisions. I founded Vestigant in 2009 and since that time, Vestigant has been retained to provide expertise on hundreds of cases involving computer forensic and e-discovery issues. 2. Vestigant was engaged by Health Net Life Insurance Company to review eight internet postings (designed to look like news articles) that recently appeared online relating to the above-referenced case. A The following is within my personal knowledge and if called as a witness I could testify competently thereto. II. SUMMARY OF CONCLUSIONS 4. I have reviewed the eight internet postings in question, identified below and attached hereto. Based upon the content of these postings and the underlying metadata/links contained on the relevant websites, I have concluded that these postings were done by one individual, who created multiple postings designed to look like news articles by different authors. Based on my review and the research I have done, I have determined the following: (a) The eight articles are posted on six different websites. The six different websites are connected. Each of these six websites has identical contact information (same Chicago address; same phone number), indicating that the same individual is behind all six websites. (b) The individual behind all six websites appears to be a computer consultant who lives in Pune, Maharashtra, India, according to a LinkedIn profile that he has posted online. This individual is identified in the domain name registration information for “newsheadline.us,” which is a website that published one of the eight articles. Based on his LinkedIn profile, he has worked as a computer programmer in India and in Chicago. 2 DECLARATION OF J. CHRISTOPHER RACICH 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 (c) (d) (e) ® The “authors” who purportedly wrote the articles appear to be fictitious. I researched the names of the authors who purportedly wrote the articles and concluded that the authors appear to be fictitious and designed to disguise the identity of the real person who wrote the articles. As described more fully below: 1) Many of the “author” bios appear to be plagiarized from the bios of real people, some of whom have been dead for decades. i1) Other of the author names and bios appear to be fictitious, as evidenced by the fact that the same bios are recycled from other websites controlled by the same individual, under different “author” names. ii) At least some of the “author” bio photographs posted on the websites appear to be stolen from online bios of real people, including professors and attorneys. Each article contain links to copies of a Complaint filed by Dual Diagnosis Treatment Center against these lawyers—although the different copies of the Complaint linked in the eight articles are all hosted by the same account. This leads me to conclude that the same individual wrote all eight articles, despite the different fictitious author names on the articles and the different websites on which they are hosted. Four of the articles have pictures of Manatt lawyers with commentary written on the photographs. This commentary is written in identical font, formatting and color scheme, indicating that these four photographs were edited/defaced by the Same person. The eight articles in question appear in Google and other internet searches, and display prominently when searches are conducted for the individuals or entities involved in this case. For example, if one runs a search in Google News for terms related to the above-captioned case (as a juror might do), such as “Health Net Sovereign fraud” or “Manatt Health Net,” some of the eight articles in question are 3 DECLARATION OF J. CHRISTOPHER RACICH 10 11 12 13 14 L5 16 17 18 19 20 21 22 23 24 25 26 27 28 in the top ten search results. This indicates to me that these articles have a potential to affect the above-captioned case. (2) The timeline of the publication of the articles indicates that they were written by one individual. Dual Diagnosis Treatment Center filed its RICO complaint against Health Net and lawyers for Health Net on May 5, 2020. Shortly thereafter, articles promoting the complaint and attacking the lawyers for Health Net began to appear. Timeline: 0) vi) Vii) viii) 1X) May 5, 2020 — Dual Diagnosis Treatment Center filed its federal RICO complaint against the Health Net lawyers and Health Net. May 18, 2020 — the first article appeared. See Exhibit 6. May 18, 2002 — the second article appeared. See Exhibit 7. May 18, 2020 — the third article appeared. See Exhibit 8. May 20, 2020 — the fourth article appeared. See Exhibit 3. May 20, 2020 — the fifth article appeared. See Exhibit 4. May 20, 2020 — the sixth article appeared. See Exhibit 5. May 21, 2020 — the seventh article appeared. See Exhibit 2. May 26, 2020 — the eighth article appeared. See Exhibit 9. III. QUALIFICATIONS 3. I am a 1993 graduate of Cornell University where I received my Bachelor of Arts degree in Biology. I later attended law school at the Washington College of Law at American University, graduating with a Juris Doctor in 1997. I have been practicing in the field of computer forensics since 1997. 6. I have taken numerous courses and attended multiple seminars in the field of computer forensics over the past 22 years. I have taught computer forensics courses at the High 4 DECLARATION OF J. CHRISTOPHER RACICH 10 11 12 13 14 L5 16 17 18 19 20 21 22 23 24 25 26 27 28 Tech Crimes Investigation Association (HTCIA). I am also an adjunct Professor of Law at the Washington College of Law at American University where I have taught a course concerning electronic discovery. 7s As a result of my work, teaching, and experience, I have expertise in the forensic protocols I utilized in working on this project, including finding and examining website metadata and domain name registration information. 8. During my career in the computer forensics field, I have provided testimony as an expert in computer forensics in numerous courts, including the International Trade Commission; the United States District Court for the Eastern District of Virginia; the United States District Court for the Southern District of Florida; the United States District Court for the Southern District of Texas; the Superior Court for the District of Columbia; the Missouri Circuit Court; the Supreme Court of the State of New York, County of New York; the Larimer County District Court in Colorado; and the Pennsylvania Court of Common Pleas. I have also provided expert deposition testimony in the area of computer forensics in connection with numerous civil claims, and also have testified as an expert witness before the National Labor Relations Board. I have been qualified at least 40 times as an expert in computer forensics in a court of law or arbitration proceeding. A true and correct copy of my Curriculum Vitae which further shows my experience in the field of computer forensics is attached as Exhibit 1. IV. THE EIGHT ARTICLES 0. Vestigant reviewed the eight articles identified below. These articles are attached as Exhibits 2 through 9. All of these articles recently appeared on the internet relating to the above-referenced case: (a) Exhibit 2: “Greg Pimstone has Manatt in serious trouble,” posted on the internet at http://www.ustimesnow.com/greg-pimstone-has-manatt-in-serious-trouble/. Most of the articles on this site appear to be posted in connection with publicity campaigns, because for the most part the articles posted here promote or attack a person or product. 5 DECLARATION OF J. CHRISTOPHER RACICH EA N ~ N O N W n 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 23 26 27 28 (b) (©) (d) J a - Partner at Manatt!|Phelps & Phillips 3 Exhibit 3: “John LeBlanc of Manatt accused of Conspiracy in billion dollar lawsuit,” posted on the internet at https://www.timebulletin.com/john-leblanc-of- manatt-accused-of-conspiracy-in-billion-dollar-lawsuit/. Most of the articles on this site appear to be posted in connection with publicity campaigns, because for the most part the articles posted here promote or attack a person or product. 5 - Partner at Manatt, Phelp &|Phillips — N Exhibit 4: “Kenneth Julian of Manatt sued for Fraud & Conspiracy,” posted on the internet at https://www.openthenews.com/kenneth-julian-of-manatt-sued- for-fraud-conspiracy/. Most of the articles on this site appear to be posted in connection with publicity campaigns, because for the most part the articles posted here promote or attack a person or product. Partner at Manatt{Phelp & Phillips \Y Exhibit 5: “Ileana Hernandez of Manatt sued for Conspiracy & Slander,” posted on the internet at https://www.globestats.com/ileana-hernandez-of-manatt- 6 DECLARATION OF J. CHRISTOPHER RACICH EA N ~ N O N W n 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 23 26 27 28 (e) () sued-for-conspiracy-slander/. Most of the articles on this site appear to be posted in connection with publicity campaigns, because for the most part the articles posted here promote or attack a person or product. bg | RE ne [ Partner at Manatt¥Phelp & Phillips Exhibit 6: “Manatt Lawyers sued for Racketeering Conspiracy,” posted on the internet at https://www.newsheadline.us/manatt-lawyers-sued-for-racketeering- conspiracy/. Most of the articles on this site appear to be posted in connection with publicity campaigns, because for the most part the articles posted here promote or attack a person or product. ek SAyy, Exhibit 7: “Liann Gohari of Health Net faces Conspiracy lawsuit,” posted on the internet at https://www.allnewsbuzz.com/liann-gohari-of-health-net-faces- conspiracy-lawsuit/. Most of the articles on this site appear to be posted in connection with publicity campaigns, because for the most part the articles posted here promote or attack a person or product. 7 DECLARATION OF J. CHRISTOPHER RACICH EA N ~ N O N W n 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 23 26 27 28 (2) (h) The Lawbreaker Lady Lawyer Exhibit 8: “Michael Neidorff Faces Financial Fraud Lawsuit Again,” posted on the internet at https:/www.ustimesnow.com/michael-neidorff-faces-financial- fraud-lawsuit-again/. Most of the articles on this site appear to be posted in connection with publicity campaigns, because for the most part the articles posted here promote or attack a person or product. Michael F Neidorff CEO, Centene Corporation Exhibit 9: “Managed Health Network faces Racketeering lawsuit,” posted on the internet at https:/www.allnewsbuzz.com/managed-health-network-faces- racketeering-lawsuit/. Most of the articles on this site appear to be posted in connection with publicity campaigns, because for the most part the articles posted here promote or attack a person or product. DECLARATION OF J. CHRISTOPHER RACICH 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 V. WEBSITE ANALYSIS A. Website Contact Information is Identical 10. The “Contact Us” webpage associated with the eight articles in question is the same: — Office Address US Times News 445 E Ohio Street, Unit 2708 Chicago, IL 60611 Contact No.: +1 (773) 654-0355 Email:info@ustimesnow.com 11. This common address leads me to conclude that a common person or entity is running these various websites that publish “for hire” articles either attacking a person or product, or promoting a person or product. These websites are listed as being run out of an apartment in Chicago, although based on the domain name registration information for one of the six websites, “newsheadline.us,” and a LinkedIn profile associated with that individual, the individual behind the websites currently lives in Pune, Maharashtra, India, and has worked as a computer programmer in India and in Chicago. 12. In addition, the telephone number for each of these websites is the same: 773-654- 0355. When I called this phone number, it led to an anonymous wireless carrier voicemail box, rather than an identified business. 13. The bylines (the name of the purported author of the article) for each of the articles is different, but, as described above, based on my research I have concluded that each of the bylines are fictitious, in an attempt to disguise the true author of the eight articles. 14. The nature of these eight articles; the consistent pattern throughout of biased statements against HealthNet and its lawyers; and the attempts to obscure the true identity of the individual or entity behind the articles, leads me to conclude that these eight articles are part of a “for hire” public relations campaign that is designed to harm the individuals targeted by the articles 9 DECLARATION OF J. CHRISTOPHER RACICH 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 or shape public perception against those individuals or companies, such as the public perception that would be relevant to the above-captioned case set for trial in this court in January 2021. B. Some of the author bios appear to be plagiarized from the bios of real people, some of whom have been dead for decades. For example: 15. The article regarding Managed Health Network (see Exhibit 9) is purportedly written by “Josh Donohue.” The bio for Josh Donohue states: “Josh was taught at home by his 21, and began his own career as an engraver. After his wedding, he taught his wife how to read and write, as well as teaching her engraving skills. He is not only engraver but also an author of news articles. He writes latest news and published it on allnewsbuzz.com as a free lance author.” See https://www.allnewsbuzz.com/managed-health-network-faces-racketeering-lawsuit/. 16. This bio appears to be plagiarized from an online bio for poet William Blake (1757-1827) from the website www.biblio.com. Mr. Blake’s online bio is listed as: “William Blake is one of the most famous English poets, painters, and print-makers of the Romantic Age. Blake was taught at home by his father, and learned engraving and an appreciation for classical Greek art as created by Raphael, Michelangelo, and Diirer. He completed his schooling with Henry Par, and a long apprenticeship with Basire, who taught him a love for the Gothic cathedrals of London. He was on his own by age 21, and began his own career as an engraver. Blake and his wife Catherine were wed in 1782 at age 25. He taught his wife how to read and write, as well as teaching her engraving skills.” See https://www.biblio.com/william-blake/author/6001. 17. Similarly, the article regarding John LeBlanc is purportedly written by “Dan Zinman.” (See Exhibit 3.) The bio for Dan Zinman states: “Dan Zinman started his career as an science and scientific discovery. He did this through writing books, essays, and articles. He is contributing by writing news articles for timebulletin.com.” 18. This bio appears to be plagiarized from an online bio for famous astronomer Carl Sagan (1934-1996) from the website www.biblio.com. An online bio of Carl Sagan describes him as: “Carl Sagan was a Pulitzer and Hugo award-winning author of books about science for the layman. He started his career as an astronomer and college professor and quickly 10 DECLARATION OF J. CHRISTOPHER RACICH 10 10 11 12 13 14 L5 16 17 18 19 20 21 22 23 24 25 26 27 28 through writing books, essays and articles, as well as appearing on television series and talk shows. He has often been called the most famous American scientist.” https://www.biblio.com/carl- sagan/author/13416 19. The article regarding Liann Gohari is purportedly written by “Ida Taylor.” (See Exhibit 7.) The bio for Ida Taylor states: “Ida Taylor is a celebrity chef, author, travel documentarian, and elevision personality who focused on international cuisine and culture. She wrote both fiction and historical nonfiction the culinary mysteries. She also wrote news articles on allnewsbuzz.com as a free lance author.” 20. This bio appears plagiarized from an online bio for famous chef Anthony Bourdain (1956-2018) from the website www.penguinrandomhouse.com. An online bio for Anthony Bourdain describes him as: “Anthony Bourdain was an American celebrity chef, author, travel documentarian, and televis on personality who starred in programs focusing on the exploration of international culture, cuisine, and the human condition.” https://www.penguinrandomhouse.com/authors/2876/anthony-bourdain. 21. The bios for other “authors” on the websites controlled by this individual also appear to be plagiarized. For example, author, the bio of purported “Time Bulletin” author “Pamela Greenberg” (“a science fiction and fantasy writer, game designer, and poet”) appears to plagiarize from the wikipedia page of author John M. Ford (“a science fiction and fantasy writer, game designer, and poet”). See https://www.timebulletin.com/team/pamela-greenberg/ and https://en.wikipedia.org/wiki/John M. F rd. C. The author names and bios appear to be fictitious. Many of the author bios are recycled on different websites affiliated with the same individual, under different “author” names. For example: 22. The article referring to Ileana Hernandez is purportedly written by “Laurie Patnick.” (See Exhibit 5.) The bio for Laurie Patnick is: “Laurie is a news author, critic and mountaineer. which she approaches many topics. Laurie’s broad understanding of these topics has made her an expert on many topics and now she shares her knowledge with the world through globestats.com.” 11 DECLARATION OF J. CHRISTOPHER RACICH 11 10 11 12 13 14 L5 16 17 18 19 20 21 22 23 24 25 26 27 28 23. I researched that phrasing and found with a bio for a different person, supposedly writing for a different publication, linked to the same Chicago address affiliated with the eight articles. Author: “Blaire Butcher,” who is described as: “Blaire Butcher is a news author, critic and base from which to approach many topics. Because of that she has lots of things are ready to publish latest articles on currently working news website which is precisejournal.com.” See http://www.precisejournal.com/author/blaire. 24. I researched that phrasing and found with a bio for a different person, supposedly writing for a different publication, linked to the same Chicago address affiliated with the eight articles: Author: Andrew Roxburgh is described as “a news author, critic and mountaineer. His to approach many topics. Because of that he has lots of knowledge related to sci/tech. He is always ready to publish latest articles on currently working news website which is ustimesnow.com,” which is a website that hosts the articles referring to Greg Pimstone (see Exhibit 2) and Michael Neidorff (see Exhibit 8). See http://www.ustimesnow.com/author/andrew/. 25. The article referring to John LeBlanc is purportedly written by “Dan Zinman.” (See Exhibit 3.) Dan Zinman’s bio states: “Dan Zinman started his career as an astronomer and college news articles for timebulletin.com.” 26. I researched that phrasing and found with a bio for a different person, supposedly writing for a different publication, linked to the same Chicago address affiliated with the eight articles: Author: Henry Allen. Mr. Allen’s bio is: “Henry Allen started his career as an astronomer writing news articles for entrepreneuryak.com.” See http://www.entrepreneuryak.com/our-team. 27. The bios for other “authors” on the websites controlled by this individual also appear to be fictitious and recycled across more than one “author.” For example, author “Natalia Forrest,” who writes for “StatsGlobe,” has the identical bio as author “Ingrid Hudson,” who writes for “All 9% 6 News Buzz.” Both are “a singer/songwriter and guitarist” “fantasy author” “noted for her 12 DECLARATION OF J. CHRISTOPHER RACICH 12 EA N ~ N O N W n 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 23 26 27 28 distinctive style.” See https://www.statsglobe.com/team/natalia-forrest/ and https://www.allnewsbuzz.com/team/ingrid-hudson/. D. In some cases, the “author” bio photograph posted on the websites appear to be taken from online bios of another person. 28. The photo of “Ida Taylor,” the purported author of the article on allnewsbuzz.com referring to Liann Gohari (see Exhibit 7) (www.allnewsbuzz.com/team/ida-taylor), appears to be of Dr. Florence Ida Hsu, a Yale Medical School professor. 29. In order to determine this, I ran a search for the image found on the website www.allnewsbuzz.com/team/ida-taylor and utilized the Google Image Search function that identifies identical or significantly similar images that have been indexed by Google. The following shows other sites that have identical or significantly similar images: ADOUTUS ~~ Lonactus L r Aum 1erms of Service 2 KSS Business Health Tech Science Ida Taylor Editor Ida Taylor is a celebrity chef, author, travel documentarian, and television personality who focused on international cuisine and culture. She wrote both fiction and historical nonfiction the culinary mysteries. She also wrote news articles on allnewsbuzz.com as a free lance author. « Tel: +1 (773) 654-0355 + Location: 445 E Ohio Street, Unit 2708 Chicago, IL 60611 « Email: ida.t@allnewsbuzz.com * URL: https:/alinewsbuzz.com/author/idal 13 DECLARATION OF J. CHRISTOPHER RACICH 13 EA N ~ N O N W n 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 23 26 27 28 © c Google #& google.com/search?tbs=sbi%3AAMhZZivniWhOBbEpUy9Fh21WdFP1uMJAIq_1Qg0640VLICh-O4MUAIOLWFFBheTfIVVNImKkdJHLIvCQBWo8SG IB) rttos..exto2409 ay Q Pages that include matching images medicine.yale.edu > profile > ida_hsu 975 x 1218 - F. Ida Hsu, MD, is an allergist and immunologist who treats a wide range of conditions and illnesses, including asthma, allergic rhinitis, food allergies, drug medicine.yale.edu > intmed » raci » profile » ida_hsu ~ Florence Ida Hsu, MD < Rheumatology, Allergy & Immunology 975 x 1218 - F. Ida Hsu, MD, is an allergist and immunologist who treats a wide range & of conditions and illnesses, including asthma, allergic rhinitis, food allergies, drug 3 medicine.yale.edu » intmed » raci » profile » ida_hsu ~ Florence Ida Hsu, MD < Rheumatology, Allergy & Immunology 454 x 630 - F. Ida Hsu, MD, is an allergist and immunologist who treats a wide range of conditions and illnesses, including asthma, allergic rhinitis, food allergies, drug doctor.webmd.com> ...» CT» North Haven ~ Dr. Florence Ida Hsu, MD - WebMD Physician Directory 150 x 150 - Florence Hsu is a practicing Allergy & Immunology doctor in North Haven, os < ts 4 medicine.yale.edu > intmed » raci » profile » ida_hsu ~ Florence Ida Hsu, MD < Rheumatology, Allergy & Immunology 454 x 630 - F. Ida Hsu, MD, is an allergist and immunologist who treats a wide range of conditions and illnesses, including asthma, allergic rhinitis, food allergies, drug Goooogle > 1234 Next 30. As shown below, the photo of “Ida Taylor,” the purported author of the article on allnewsbuzz.com referring to Liann Gohari, appears to be of Dr. Florence Ida Hsu, a Yale Medical School professor. See https://medicine.yale.edu/profile/ida_hsu/, which is pictured below: 14 DECLARATION OF J. CHRISTOPHER RACICH 14 n ~ N O N W n 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 23 26 27 28 @ Florence Ia Hsu, MD < Yale Scr Xo « C # medicineyale.edu/profilefida hsu/ Yale scHOOL OF MEDICINE LL St) Education Research Patient Care £2 Diversity A-Z Index Florence Ida Hsu, MD Assistant Professor of Clinical Medicine; Training Program Director - Allergy & Immunology] Internal Medicine oa) rN YEHin>& Contact Information : Biography Biograph! Florence Ida Hsu, MD erik ; : ) : Ida Hsu, MD, is an allergist and immunologist who treat Research & Publications of conditions and illnesses, including asthma, allergic r Appt 203.287.6200 I . i . . Clinic ° allergies, drug hypersensitivity and hives with unknowr Fav 203.2876101 vs = wun mer mw 31. images. This is not the only author on www.allnewsbuzz.com that appears to be using stolen The photo of “Julie McElroy,” who is listed as the editor for the website www.allnewsbuzz.com (https://www.allnewsbuzz.com/team/julie-mcelroy/) appears to be of Julie Dalzell, a lawyer who worked at SquareOne law firm: 32. The photo of “Julie McElroy” from https://www.allnewsbuzz.com/team/julie- mcelroy/ is below: 15 DECLARATION OF J. CHRISTOPHER RACICH 15 EA N ~ N O N W n 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 23 26 27 28 IN Julie McElroy - All News Buzz ~~ X + « C #@ allnewsbuzz.com/team/julie-mcelroy Qa %* OF » 0 : About us Contact Us Our Authors Terms of Service Privacy Policy Rss Business Health Tech Science Julie McElroy She is been cited by many big names «+ Location: 445 E 90, IL 606 « Email: Julie Z « URL: https //alinewsbuzz com/author/julie 33. This photo appears to have been extracted from the following website: https://www.squareonelaw.com/news/employment/experienced-teesside-employment-lawyer- joins-square-one-law/. The full image on the law firm’s website (below) shows the logo of the SquareOne Law firm in the background of Ms. Delzell. The law firm’s logo can be partially seen in the image found on allnewsbuzz.com (above). 16 DECLARATION OF J. CHRISTOPHER RACICH 16 EA N ~ N O N W n 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 23 26 27 28 r Q SQUAREONELAVWV = 2% OH 0191 250 8500 enquiries@squareonelaw.com [4 de] 203 R13 le 3 SECTORS («183 NEWS Ll CONTACT US NEWS < Backto News Pr Experienced Teesside employment lawyer joins Share this pen Square One law aono Employment, News - ~ Square One Law has announced the arrival of senior associate, Julie Dalzell, who joins the firm’s employment team. Julie's arrival coincides with the team achieving tremendous turnover growth of 45 percent and the recent opening of the firm's office in Tees Valley, where she will be based 34. Other purported “authors” on other websites that link to the same Chicago address also use stolen photos of real people. For example, the photo of “Henry Allen,” who shares a bio similar to that of Dan Zinman (the author of the article relating to John LeBlanc), appears to be a lawyer in Denver named Henry Baskerville. Compare see http://www.entrepreneuryak.com/our- team, with https://www.fortislawpartners.com/henry-baskerville. 35. The photo of “Harper Smith” appears to be Abigail Harper, a Michigan State University professor. Compare see http://www.entrepreneuryak.com/our-team, with https://www.canr.msu.edu/people/abigail harper. 36. The photo for author “James Mason” appears to be an employee at Gatix E- Solutions, a consulting firm in Florida. Compare see http://www.entrepreneuryak.com/our-team, with https://www.linkedin.com/in/sam-s-22212b41. 37. The photo of “Andrew Roxburgh” appears to be of South African cricket player David Bedingham. Compare located at http:/www.mintherald.com/our-team/, with https://www.espncricinfo.com/southafrica/content/player/498585.html. 17 DECLARATION OF J. CHRISTOPHER RACICH 17 E. The Photographs of the Lawyers Involved in the Above-Referenced Case Have Comments that are Identical in Font and Color 38. The following photographs were found in four of the eight articles. Based upon review of these photographs and the photographs of the associated lawyers on the firm website (www.manatt.com), the original photograph have been extracted from the firm website. All photographs have text that has been added to them, and all have near identical formatting. This includes the same font, the same or similar text and the same color scheme (yellow/white/red). 2 jo CELL CEU EL ER CIE EAGT Partner at Manatt{Phelp & Phillips Partner at Manatt¥Phelp & Phillips 39. Despite the fact that these four photographs (and the accompanying articles) were posted on four different websites, I have concluded that the manipulation of these photographs is the work of one individual as opposed to four separate authors of separate articles. F. Each of the Eight Articles Link to a Separate Copy of the May 5 Complaint that Plaintiffs in the Above-Referenced Case Filed Against Health Net and the Manatt lawyers. That complaint is copied on the Website Scribd.com, however all copies were uploaded by the same account 40. In the body of each of the eight articles, there is a link beginning with “bit.ly” that takes the reader to the website www.scribd.com. Scribd.com is a website that is designed to host documents, including PDF files. 18 DECLARATION OF J. CHRISTOPHER RACICH 18 EA N ~ N O N W n 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 23 26 27 28 41. The links point to seven PDF files (one of the PDFs is used in two separate articles). All seven of the PDF files are copies of the May 5, 2020 complaint in Dual Diagnosis Treatment Center, Inc. et al. v. Health Net, Inc. et al. (C.D. Cal. Case No. 20-cv-04112), each with a different file name (as follows): (a) (b) (c) (d) (e) () (2) Racketeering & Conspiracy Case Against John LeBlanc Racketeering & Conspiracy Case Against Lawyers of Manatt Phelps & Phillips Racketeering & Conspiracy Case Against Kenneth Julian Racketeering & Conspiracy Case Against Liann Gohari Racketeering & Conspiracy Case Against Ileana Hernandez Racketeering & Conspiracy Case Against Michael Neidorff Racketeering & Conspiracy Case Against Centene Corporation Below is a screen shot of the upload account for the user “Investigative Journalist.” ree \ 2 Uploads by Inves... John LeBlanc | In... Lawyers of Mana... Kenneth Julian | IL. Liann Gohari | Ins... lleana Hernandez... Michael Neidorff... Centene Corpora... - € SCRIBD | search | Q | @uoss @eo~ [signin || goin | ww Q 2 a ly wi w = scrioa.com [0] wu Uploads by Investigative Journalist ll LL LL ld ll Racketeering & Racketeering & Racketeering & Racketeering & Racketeering & Conspiracy Case... Conspiracy Case... Conspiracy Case... Conspiracy Case... Conspiracy Case... 2 Investigative Jo. 2 Investigative Jo. : Jo : Jo.. : igative Jo, PDF =a Racketeering & Racketeering & Conspiracy Case... Conspiracy Case... 2 Investigative Jo. 2 Investigative Jo. 19 DECLARATION OF J. CHRISTOPHER RACICH 19 10 11 12 13 14 L5 16 17 18 19 20 21 22 23 24 25 26 27 28 42. All copies of the complaint are associated with the same user account, meaning this user is the person who uploaded all the documents. This additional factor makes it nearly certain that the same person is behind all of the articles, despite the various pseudonyms used. 43. All copies of the complaints are identical with the exception of the name of the file. 44. These facts further show that all eight articles were written by and/or are connected with the same author, despite the different websites and different bylines used. Moreover, the fact that all eight articles link to the same complaint filed by Dual Diagnosis Treatment Centers on May 5, 2020, which is just shortly before the articles appeared, leads me to conclude that all of the articles are related. G. The Eight Articles Have High Results when Searching on Search Engines such as Google News 45. While the eight articles are hosted on six separate websites that currently do not appear to experience a significant amount of traffic, when one runs searches in search engines such as Google News such as “Health Net Sovereign Fraud,” “Fraud Case Manatt,” “Manatt Health Net” and “Centene Manatt” at least one or more articles from the eight are returned in the top ten articles. This is indicative that effort has been made to use “Search Engine Optimization” tools to push the articles into a higher ranking on Google and other search engines. “Search Engine Optimization” involves techniques used by computer consultants to enhance the number of views of articles on the internet. I conclude based on this that the articles have been designed to be seen as much publicity as possible. 46. This means that anyone researching the above-referenced case pending in this Court will find some, if not all, of these articles—but they would not know that all of them have been authored by one person or organization. H. The Eight Articles Are Written by Fake Authors, Designed to Mislead the True Source of the Articles 47. As described extensively above, the articles at issue were written by fake “bylines,” which are designed to mislead readers as to the true source of the articles. The bylines are 20 DECLARATION OF J. CHRISTOPHER RACICH 20 10 11 12 13 14 L5 16 17 18 19 20 21 22 23 24 25 26 27 28 demonstrably either (a) fake and recycled, used multiple times on different websites under different names, all controlled by the same individual, and/or (b) plagiarized from the bios of famous people. 48. Based on this information and the other factors described above, I conclude that these articles and websites are designed to mislead readers as to the true authors of the articles and the true nature of the websites that host the articles. VI. CONCLUSION 49. Based upon the review of the websites and underlying information associated with the eight articles in question, I have concluded that all eight articles were authored by one person who is trying to hide the fact that all of the articles were authored by a single source. Based on my research, and as described above, I have concluded that these articles appear to be part of a campaign to publicly attack the defendants and lawyers in the above-referenced case, and this is being done in a way that obscures the identity of the attacker and is designed to harm the lawyers and their clients in the above-referenced case. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on June 9" day of 2020 in Vienna, Virginia. . . A fro Vos, J: Cfristophef Racich President, Vestigant, LLC 21 DECLARATION OF J. CHRISTOPHER RACICH 21 Exhibit 1 22 oo 0 00 1 1 0 VESTIGANT Curriculum Vitae J. Christopher Racich, Vestigant, LLC, President Name: J. Christopher Racich Telephone: 202 905-2170 Email: racich@vestigant.com PROFESSIONAL EXPERIENCE Sept. 2009 — Present: Vestigant, LLC — President Create and operate computer forensics/E-Discovery Consulting business Lead, work and testify in all manner of Computer Forensics/E-Discovery cases Gather and investigation of data for a variety of civil and criminal matters. Matters include fraud, embezzlement, sexual harassment, intellectual property theft violation of non-compete clauses, child pornography, and computer, network, and PBX/voice mail hacking Aug. 2010 — Present: American University, Washington College of Law — Adjunct Professor Teaching “Litigation in the Digital Age: E-discovery and Electronically Stored Information Law” Sept. 2010 — Present: American University Washington College of Law — Adjunct Professor Dec. 2008 to Sept. 2009: First Advantage — Senior Regional Practice Leader and Counsel 2006 to 2008: First Advantage — Senior VP and Counsel 2004 to 2006: First Advantage CoreFacts — Managing Director and Counsel 2001 to 2004: CoreFacts — Managing Director and Counsel Head computer forensics practice Lead numerous large scale electronic discovery consulting projects and act as lead consulting expert Lead work and testify in all manner of Computer Forensics/E-Discovery cases 1997 to 2001: Kroll Associates — Director, High Tech Investigation, Mid-Atlantic Region Develop and lead the firm’s Mid-Atlantic high tech investigation practice from Kroll’s Washington, DC office Manage numerous investigations and computer forensic engagements for the firm Testify as a computer forensic expert 23 Ex 1 TESTIMONY In The Matter of: Certain Foodservice Equipment and Components Thereof Investigation No. 337-TA-1166 Testimony given in Deposition, US International Trade Commission, Retained by Illinois Tool Works, Inc. Florida Digestive Health Specialists, LLP v. Neff Case No. 2019 CA 5839 NC Testimony Given in Hearing, retained by Florida Digestive Health Specialists, LLP CACI, Inc. —- FEDERAL v. Bao-Tran X. (“CJ”) Ngo Case No. 01-18-0001-0633 Testimony given in Arbitration, American Arbitration Association, retained by CACI, Inc. - FEDERAL Panera, LLC v. Jim Dobson, et al, Case No. 2019-0111-MTZ Testimony given in Deposition, Court of Chancery of the State of Delaware, Retained by Panera, LLC Mathey Dearman, Inc. v. H&M Pipe Beveling Machine Co., et al, Case no. 18-cv-250-GKF-JFJ Testimony given in Hearing, Federal District Court, NDOK, Retained by Mathey Dearman, Inc. MRP UP Partners, LLC, et al. v. Raymond Rahbar, Jr., et al, Case No. 2017-00817 Testimony given in Hearing, Fairfax County Circuit Court, Retained by MRP UP Partners, LLC MRP UP Partners, LLC, et al. v. Raymond Rahbar, Jr., et al, Case No. 2017-00817 Testimony given in Deposition, Fairfax County Circuit Court, Retained by MRP UP Partners, LLC Integrated Global Services, Inc. v. Michael Mayo Case No. 3:17-cv-00563 Testimony given in Hearing, Federal District Court, EDV A, Retained by Integrated Global Services, Inc. 24 2 Ex 1 U.S. ex rel. Lyle Beauchamp, et al. v. Academi Training Center, Inc. Civil Action No. 1:11-cv-371 Testimony given in Deposition, Federal District Court, EDV A, Retained by Academi Training Center, Inc. Kathryn McGregor Gaietto, et al. v. Jacqueline Lewis, et al. Case No. 2015 CA 004971B Testimony given in Deposition, Superior Court of District of Columbia, Retained by Jacqueline Lewis Netlogic Solutions, Inc. v. Micore Solutions, Inc. Case No. 94260 Testimony given in Hearing, Loudon County Circuit Court, Retained by Micore Solutions, Inc. Liebherr Mining & Construction v. Detroit Heavy Truck Engineer, et al. CL1100114F-15 Testimony given in Hearing, Newport News Circuit Court, Retained by Liebherr Mining & Construction Ratner Companies, LC v. Bobby Brown and Regis Corporation Civil Action No. 2015-13150 Testimony given in Deposition, Fairfax County Circuit Court, VA, Retained by Ratner Companies, LC In the Matter Of: Certain Stainless Steel Products, Certain Process for Manufacturing or Relating to Same and Certain Products Containing Same Investigation No. 337-TA-933 Testimony given in Deposition, US International Trade Commission, Retained by Valbruna Stainless, Inc. Lynn M. Johnson v. BAE Systems, Inc., et al. Civil Action No. 1:11-cv-02172-RLW Testimony given in Hearing, US District Court for the District of Columbia, Retained by BAE Systems, Inc. Headfirst Baseball, LLC, et al., v. Robert Elwood and Stacey Elwood C.A. No. 1:13-cv-00536-RBW Testimony given in Deposition, US District Court for the District of Columbia, Retained by Headfirst Baseball, LLC Chevron Corp. and Texaco Petroleum Co. v. The Republic of Ecuador Track 2 Arbitration under the UNCITRAL Arbitration Rules Testimony given at UNCITRAL Arbitration, Retained by The Republic of Ecuador Taylor Allegyer vs. Melanie Allegyer 25 3 Ex 1 Case No. CL 2014-4514 Testimony given at Hearing, Fairfax County Circuit Court, VA, Retained by Taylor Allegyer. HMS Holdings Corp., et al., v. Sean Curtin, et al. Index No. A00754/2014 Testimony given at Evidentiary Hearing, Supreme Court New York, Retained by HMS Holdings, Corp. James Swan v. BB&T Securities, LLC FINRA Arbitration No. 13-01078 Testimony given at FINRA Arbitration, Retained by BB&T Securities, LLC HMS Holdings Corp., et al., v. Public Consulting Group, Inc., et al Cause No. DC-14-0947 Testimony given in TI Hearing, Dallas County District Court, TX, Retained by HMS Holdings, Corp. HMS Holdings Corp., et al., v. Public Consulting Group, Inc., et al Cause No. DC-14-0947 Testimony given in Deposition, Dallas County District Court, TX, Retained by HMS Holdings, Corp. Taylor Allegyer vs. Melanie Allegyer Case No. CL 2014-4514 Testimony given at Hearing, Fairfax County Circuit Court, VA, Retained by Taylor Allegyer American International Biotechnology, LLC v. Breedlove Case No. 3:14-cv-229 Testimony given at Hearing, Federal District Court EDV A, Retained by American International Biotechnology, LLC Janae Haaland vs. Christopher Marraro Case No. CL 2014-289 Testimony given at Deposition, Fairfax County Circuit Court, VA, Retained by Janae Haaland ManTech International Corp. v. Analex Corp., et al. Case No. 2011-9058 Testimony given at Trial, Fairfax County Circuit Court, VA, Retained by ManTech International Corp. US Foods, Inc., v. Michael Noble & Phillip Roszak AAA Case No. 13 166 01022 13 Testimony given in AAA Hearing, Retained by US Foods, Inc. 26 4 Ex 1 Wise Recycling, LLC v. Gary Taylor, et al. Case No. 12-CVS-2139 Testimony given in Deposition Superior Court of North Carolina, Johnston County, Retained by Wise Recycling, LLC Tullett Prebon, PLC, et al. v. BGC Partners, Inc. Civil Action No. HUD-L-3796-11 Testimony given in Deposition, Superior Court of New Jersey, Hudson County, Retained by John DelVecchio and Peter Ozzimo Random Ventures, Inc., et al. v. Advanced Armament Corp, LLC, et al. Civil Action 1:12-CV-06792-KBF Testimony given at Trial, Federal District Court SDNY, Retained by Advanced Armament Corp, LLC Professional Massage Training Center, Inc. v. Accreditation Alliance of Career Schools and Colleges Civil Action No. 1:12-CV-00911-LO-IDD Testimony given at Evidentiary Hearing, Federal District Court EDV A, Retained by Professional Massage Training Center, Inc. Jennifer J. Taylor v. Republic Services, Inc., et al. Civil Action No. 1:12-CV-523 Testimony given at Evidentiary Hearing, Federal District Court EDV A, Retained by Republic Services, Inc. Tech Systems, Inc. v. Lovelen Pyles, et al. Case No. 1:12-CV-374-GBL-JFA Testimony given at Trial, Federal District Court EDVA, Retained by Tech Systems, Inc. Motors Liquidation Company GUC Trust, v. Appaloosa Investment Ltd. Partnership I, et al. Case No. 09-50026, Case No. 12-09802 Testimony given at Trial, SDNY Bankruptcy Court, Retained by Elliott Management Corporation, Fortress Investment Group LLC and Morgan Stanley & Co. International PLC Confidential Arbitration Testimony given in Confidential Arbitration. Counsel: Christopher Manning, Williams & Connolly, LLP ManTech International Corp. v. Analex Corp., et al. Case No. 2011-9058 Testimony given in Deposition, Fairfax County Circuit Court, VA, Retained by ManTech International Corp. 27 5 Ex 1 Motors Liquidation Company GUC Trust, v. Appaloosa Investment Ltd. Partnership I, et al. Case No. 09-50026, Case No. 12-09802 Testimony given in Deposition, SDNY Bankruptcy Court, Retained by Elliott Management Corporation, Fortress Investment Group LLC and Morgan Stanley & Co. International PLC Tristi Ann Boone v. Dinh Tran Quang Nguyen Case No. CL00069833-00 Testimony given at Hearing, Loudon County Circuit Court, VA, Retained by Tristi Boone Aon Risk Services Northeast, Inc. And Aon Corp. v. M. Cusack and Alliant Insurance Services, Inc. Index No. 651673/2011 Testimony given in Preliminary Injunction Hearing, Supreme Court of the State of New York, Retained by Alliant Insurance Services, Inc. DynCorp International, LLC v. Jane T. Flowers, et al. Case No. CL2011-8117 Testimony given in Deposition, Fairfax County Circuit Court, VA, Retained by DynCorp, International, LLC ManTech International Corp. v. Barry Greenberg, et al. Case No. 2008-5845 Testimony given in trial, Fairfax County Circuit Court, VA, Retained by ManTech International Corp. Energy EIAC Capital Itd and Sanibel Intertrade Corp. v. Maxim Group, LLC Index No. 650180/2010 Testimony given in hearing, Supreme Court of the State of New York, Retained by Energy EIAC Capital Ltd. ManTech International Corp. v. Barry Greenberg, et al. Case No. 2008-5845 Testimony given in Deposition, Fairfax County Circuit Court, VA, Retained by ManTech International Corp. Lumber Liquidators, Inc. v. Kevin H. Sullivan Case No. 11 166 00490 10 Testimony given in American Arbitration Association Arbitration, Retained by Lumber Liquidators, Inc. 28 6 Ex 1 James River Management Co., Inc., et al v. Michael P. Kehoe, et al. Civil Action No. 3:09CV387-REP Testimony given in hearing, Federal District Court EDV A, Retained by James River Management, Inc. Leor Exploration & Production, LLC et al., v. Guma Aguiar Case No. 09-60136-CV-PAS; Case No. 09-60683-CV-PAS Testimony given in Evidentiary Hearing, SDFL, Retained by Guma Aguiar James River Management Co., Inc., et al v. Michael P. Kehoe, et al. Civil Action No. 3:09CV387-REP Testimony given in Deposition, Federal District Court EDV A, Retained by James River Management, Inc. Applied Materials, inc., v. Advanced Micro-Fabrication Equipment, Inc. China, et. al. Case No. C07-05248 Testimony given in Deposition, NDCA, San Jose Division, Retained by Applied Materials John B. Mazur v. TRG Holdings LL.C., et al. Civil Action No. 08 CA 000809 Testimony given in Evidentiary Hearing, Superior Court of the District of Columbia, Retained by John B. Mazur John B. Mazur v. TRG Holdings LL.C., et al. Civil Action No. 08 CA 000809 Testimony given in Deposition, Superior Court of the DC, Retained by John B. Mazur Sterling Merchandising, Inc. v. Nestlé, S.A. et al. Civil No. 06-1015 (SEC) Testimony given in Deposition, District Court, Puerto Rico. Retained by Nestlé, S.A. Interbake Foods, LLC v. Bakery, Confectionery, Tobacco Workers and Gran Millers International Union (BCTGM), Local 68 NLRB Case #5CA-33158, 5CA-33300, 5CA-34261 Testimony given in Trial, National Labor Relations Board, Region 5. Retained by Interbake Foods, LLC. David W. Howard v. Lumber Liquidators, Inc. JAMS Arbitration Ref. No. 1410004567 Testimony given in JAMS Arbitration. Retained by Lumber Liquidators, Inc. 29 7 Ex 1 Bi-State Development Agency of the Missouri-Illinois Metropolitan District v. Cross County Collaborative Joint Venture, et. al. Case #04CC-003335 Testimony given in Trial, Circuit Court, St. Louis, MO. Retained by: Bi-State Development Agency of the Missouri-Illinois Metropolitan District Jerry I. Treppel v. Biovail Corporation, Eugene N. Melnyk, Kenneth C. Cancellara, Michael S. Sitrick and Sitrick and Company, Inc. Case 03 Civ. 3002 Testimony given in 30(b)(6) Deposition, SDNY. Retained by Biovail Corporation American Civil Liberties Union, et al, v. Alberto Gonzales Case #98-CV-5591 Testimony given in Deposition, Federal District Court, EDPA. Retained by American Civil Liberties Union DAG Petroleum Suppliers, LLC v. BP p.l.c. and BP Products North America, Inc. Case #1:05-CV-1323 Testimony given in Deposition, Federal District Court EDVA. Retained by DAG Petroleum Suppliers, LLC IECS, LLC v. Abdallah Walid El Kabbani Case #1:06CV90 Testimony given in Hearing, Federal District Court, EDV A. Retained by IECS, LLC United States v. Daniel Bayly, et al. Case #4:04CR00363-1 Testimony given in Trial, Federal District Court, SDTX. Retained by US Government Hach Company v. Michelle Haubrich Case #04CV1639 Testimony given in Hearing, Larimer County District Court, CO. Retained by Hach Company Scott & Stringfellow v. Jefferies Group, Inc Testimony and Evidence given in Hearings, NASD-DR Arbitration, and in Henrico, VA, Circuit Court. Retained by Scott & Stringfellow Walton Street v. Ocwen Asset Investment Corp. Case # 1999L006116 Evidence given in Deposition, Cook, IL, Circuit Court. Retained by Ocwen Asset Investment Corp. 30 8 Ex 1 Henry N. Camferdam, Jr. et al. v. Ernst & Young International, Inc., et al. Case #1:02CV10100 Testimony given in Hearing, Federal District Court, SDNY. Retained by Ernst & Young International, Inc., et al. DMG Securities v. Bashion, Cruz Case #03-06845 Testimony given in Hearing, NASD-DR Arbitration. Retained by DMG Securities CERTIFICATION AND TRAINING Certified Computer Examiner (CCE) Member New York Bar Association, 1998 — present Member Washington, DC Bar, 1999 — present Member Virginia Bar Association, 2004 —2009 Member HTCIA HTCIA Computer Forensic Certification HTCIA Instructor Encase Intermediate Certification National Consortium for Justice Information and Statistics (SEARCH) Computer Forensic Certification HTCIA/RCFG GMU Computer Forensic Certification Kroll Computer Forensics Certification Co-Chair, ABA Sub-committee on Electronic Evidence 1999 — 2004 Private Investigator, Virginia 2002 - 2016 Private Detective, Washington, DC 1997 — 2001 EDUCATION Washington College of Law, 1997 ID Cornell University, 1993 Bachelor of Arts, Biology Ex 1 31 Exhibit 2 32 Aboutus Our Team Terms of Service Privacy Policy Contact us (3 [e115] Health Lifestyle Sports Sci/Tech Home > Lifestyle > Greg Pimstone Has Manatt In Serious Trouble Greg Pimstone has Manatt in serious trouble A timesnow 6 Moy21,2020 D0 in Linkedin Greg Pimstone, the leader of the law firm Manatt, Phelps & Phillips’ healthcare litigation practice, has literally led the firm into a scandal that is no less than a potential reputational landmine. With a billion dollar lawsuit filed in the US District Courts in LA naming three top lawyers in the LA office of the firm as racketeers, conspirators and slanderers, the firm's management is understandably mad at Greg Pimstone, the one person whom the three allegedly rogue lawyers were directly reporting to. Greg Pimsotne, who likes himself to be referred to as one of the leading healthcare litigators in the country, seems to have had some very serious lapses of judgement in the way he allowed his team to work on helping Manatt’s client Health Net deal with its outstanding claims issue, which has now snowballed into a major controversy. As is already widely known, Sovereign Health Group, a mental healthcare service provider that was operational in Los Angeles till 2018 has filed a billion dollar lawsuit against Health Net, its Deputy General Counsel, Liann Gohari, and its parent company Centene Corporation and its CEO, Michael Neidorff, for conspiring with the three Manatt lawyers, viz. lleana Hernandez, John Leblanc and Kenneth Julian, and two other entities, namely Optum Services Inc. and Managed Health Network Inc. As per the allegations in the case document available here — https: /bit.ly/3ccANw2 - the rogue Manatt Lawyers, who actually work under Greg Pimstone, willingly participated in a malicious campaign with Centene & Health Net and others to drive it out of business. The malicious campaign against Sovereign was hatched and executed by the alleged conspirators to ensure that e The truth about the failing financial health of Health Net remained under wraps, https://www.ustimesnow.com/greg-pimstone-has-manatt-in-serious-trouble/ Page 1 Printed May 30, 2020 Ex 2 « Health Net's acquisition by Centene could materialise « The pending claims amount of over $300 million and taxes that Health Net was supposed to pay could be booked as profit by Centene, thus pushing its share price even higher in the stock market * Centene's CEO Michael Neidorff could take home millions in cash and stock as his compensation and performance bonus « And finally, Michael Neidorff could sell $20 million worth of his stock while in possession of all the above information that he hid from Centene's investors and stakeholders The above sequence of events clearly hint towards a major corporate scandal and white collar crime that will attract federal investigation. Manatt management knows that they have a huge crisis at their hands to deal with immediately. If Greg Pimstone is absolutely clean and had no inkling of what these rogue lawyers were exactly up to, then it is obvious that Manatt’s management has an inept man on the job who is absolutely unfit to run its Los Angeles office. And if, whatever transpired was in Greg Pimstone's knowledge and with his approval, and it was he who kept his bosses at Manatt in dark about the gravity of the situation, then he is as crooked as his team members and only luckier that his name hasn't been included in the said lawsuit. However, his luck may run out sooner than he thinks possible. The ball, for now, is in the court of Manatt’s management. It goes without saying that whatever they do or not do to right the wrongs that their team members have committed will decide the future of their reputation and practice. © Greg Pimstone © Manatt © Phelps & Phillips Timesnow ? CLOUTNEWS.COM Wo «= Brian Young Introducing New and Clout News leading the Competition Peppy Tunes to Music Industry z because of Maximum Celebrity 2 Sophio Heard 8 May 30,2020 D0 Interview: Nuski Baby Exposure 2 Isabel Tuer 6 May 30,2020 0 2 Isabel Turner 6 May 30,2020 PO https://www.ustimesnow.com/greg-pimstone-has-manatt-in-serious-trouble/ Page 2 Printed May 30, 2020 Ex 2 34 VICTORIA 'OLLECTION a Why keeping in the kitchen is essential Industry actors like Pablo Al-Kaalik see during the COVID-19 Crisis California back on track dominating the Competition 2 Jasonlaing B May 30,2020 DP Cake nar WY kor o 2 Isabel Turner EB May 30,2020 [3¢ tobyjakewright, 14 years old and LEAVE A REPLY Your email address will not be published. Required fields are marked * Comment Name * Email * Website Save my name, email, and website in this browser for the next time | comment. SS TTT Cream Magazine by https://www.ustimesnow.com/greg-pimstone-has-manatt-in-serious-trouble/ Page 3 Printed May 30, 2020 Ex 2 35 Exhibit 3 36 Home Aboutus Contact Authors Privacypolicy Termsofservice Contributeus Time BPulletim Home Lifestyle Sports Technology Television HOMEPAGE / BUSINESS / JOHN LEBLANC OF MANATT ACCUSED OF CONSPIRACY IN BILLION DOLLAR LAWSUIT John LeBlanc of Manatt accused of Conspiracy in billion dollar lawsuit Dan Zinman May 20,2020 Spread the love 0 © 0 ~ QO O06 LATEST NEWS CONTINUE» 5 A ———— © May 30,2020 1 Click ‘Continue’ Clout News insights and entertainment portal will take 2 Get Browser Extension gel Sl over the internet by the end of the year a Start Watching © May 30,2020 vw Breaking the shackles to become a successful model, influencer and entrepreneur: tvS. live Martina Vismara 2 = = : = © May 30,2020 John M. Leblanc, a partner in the law firm Manatt, Phelps & Phillips, and a co-chair of the firm's national Stylish Large-Cup SwimweS * Check these top searches to find large-cup swimwear. healthcare litigation practice in the Los Angeles office, has been accused of wilful participation in a racketeering conspiracy and malicious slander. John Leblanc has been named as one of the many defendants in a billion dollar lawsuit filed in the US District Courts. Swimwear Sales The allegations on John Leblanc and other defendants have been made by Sovereign Health Group, one of the leading mental health care service providers based in Los Angeles that had to close down its operations due to Project ECHO Sets to Host 16th the alleged conspiracy. The full complaint against John Leblanc and his alleged co-conspirators is available here - . ~ Annual High School https://bit.ly/2TnNj4t Entrepreneurs’ Business Plan Pommcniitlan https://www.timebulletin.com/john-leblanc-of-manatt-accused-of-conspiracy-in-billion-dollar-lawsuit/ Page 1 Printed May 30, 2020 Ex 3 Lawyer John Leblanc and all other defendants apparently targeted Sovereign to stop its relentless pursuit of unpaid claims that were due on his firm's prized client, Health Net. John LeBlanc, along with his fellow lawyers from Manatt, helped Health Net devise a fraudulent scheme to advance a variety of false accusations against Sovereign so as to deny its valid claims in January 2016. As part of the scheme, John Leblanc and his co-conspirators ensured that hundreds of Sovereign's claims were kept unpaid in the guise of an “audit”, which were later denied on one pretext or the other. Over a period of just a few months, there was an exponential increase in the number of claims that Health Net refused to pay. Px Stop Using Toilet Paper This “DIY” bathroom upgrade is saving Americans thousands on Toilet Paper. ( ; Clear Rear Health Net was eventually acquired by Centene Corporation in March 2016, and Centene joined the scheme and did everything to keep the failing financial health of Health Net and its pending claims a secret. Centene’s CEO Michael Neidorff lied to the company’s investors, shareholders, media and even in the SEC filings and did not disclose Health Net problems to save the acquisition which would otherwise have been stopped by its investors. John Leblanc and all his co-conspirators did everything to keep Health Net's financial problems under wraps by attacking Sovereign and its CEO without evidence of any wrongdoing. They lied to the FBI and somehow convinced them to investigate Sovereign's operations through a physical search of its premises, which destroyed Sovereign's hard earned and well deserved reputation as one of the leading mental health care service providers based in Los Angeles. The conspiracy and the unabated attacks on its reputation caused immense harm to Sovereign's business. John Leblanc and his co-conspirators also managed to generate a lot of negative media coverage against Sovereign and it finally closed down its business in 2018. Sovereign has come back with a watertight lawsuit and a demand for a jury trial against all the conspirators including John Leblanc and is asking for over a billion dollars as damages. The result of this interesting case will definitely be a well earned warning to future lawyers! Stop Using Toilet Paper This “DIY” bathroom upgrade is saving Americans thousands on Toilet Paper. ( I Clear Rear [0 Share J Tweet 0 Share [0 Share 0 Share Tagged: John LeBlanc Manatt Phelps & Phillips Sovereign Health Group You must be logged in to post a comment. Dan Zinman Dan Zinman started his career as an astronomer and college professor and quickly expanded into popularizing the understanding of science and scientific discovery. He did this through writing books, essays, and articles. 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We ep provide news articles with diverse range of KE information and focus on the latest trends in the diols . Clout News insights and Ras market... entertainment portal will take over the internet by the end of La Television © May 30,2020 Entertainment REY Uncategorized © Copyright 2019 Time Bulletin. Theme by Imon Themes https://www.timebulletin.com/john-leblanc-of-manatt-accused-of-conspiracy-in-billion-dollar-la Page3 Printed May 30, 2020 Ex 3 Exhibit 4 40 About Us Contact Us Privacy Policy Our Authors A RSS The Open News # Home Business Education Environment Politics Technology Entertainment Press enter to search Q Kenneth Julian of Manatt sued for Fraud & Conspiracy -s May 20, 2020 by Lisa Miller ONLY $9.98 Partner at Manatt!Phelp & Phillips [ stop now | BX www.onnrons.com Recent Posts Reckless Driving Charge? The music industry is evolving and Brian Young is the Catalyst Rated as Top 100 National Trial Lawyers, Super Lawyers, & a Top Attorney by 3rd parties. kgofirm.com 053) In a billion dollars lawsuit filed by a mental health care services provider, Sovereign Health Group, in the US District Courts, Kenneth B. Julian, an attorney and a partner at the Orange County office of Manatt, Phelps & Phillips, has been named as a conspirator and slanderer who helped design and implement one of the biggest corporate frauds in California that's yet to be investigated. The full complaint against Kenneth Julian and his alleged co-conspirators can be accessed here — hitps //bit ly 2LcS5nKl Know more about shipping cars to Germany Kendall Joshua aka KJTheRevolution is Changing How Her Fans Look at the English Language Tuesday Knight's "FYS" Passes 200K The allegations assume immense significance considering that immediately prior to becoming a partner at Manatt, Kenneth Julian was a Streams deputy chief in the Orange County office of the U.S. attomey for the Central District of California. A classic defender of law going rogue is the kind of story that no one in the legal fraternity can ignore As per the complaint, Health Net hired Manatt in January 2016 to collaborate on a strategy regarding the outstanding claims by out-of-network Meet the Nexigen Tech Entrepreneur substance abuse providers that included Sovereign. Kenneth Julian, along with his coworkers, is alleged to have designed a fraudulent scheme to falsely accuse Sovereign and other providers so as to help Health Net wriggle out of their valid claims. Parmarth Mori making his home town Wadhwan Surendranagar Proud L d This fraudulent scheme designed by Kenneth Julian and his team mates enabled Health Net to designate even the valid claims for an “audit” and later refuse to pay the claims. All this while, there were talks of an impending acquisition of Health Net by Centene Corporation, which Categories finally happened in March 2016 0 With this acquisition, Centene Corporation also became a part of the elaborate scheme hatched by Kenneth Julian with other lawyers of his » Business firm. Centene was not a mere spectator as its CEO Michael Neidorff made every affort to hide the truth about the financial problems of Health Net. Ken Julian and his team ended up assisting him in hiding pending claims and various lawsuits of Health Net * Education https://www.openthenews.com/kenneth-julian-of-manatt-sued-for-fraud-conspiracy/ Page 1 Printed May 30, 2020 Ex 4 Michael Neidorff even lied in the SEC filings and later in many media interviews about Health Net and its outstanding liabilities that ran into + Entertainment millions of dollars. This amount was claimed as profit of the company in its annual filings and Michael Neidorff got millions in cash and stocks E » Environment as his compensation. He later sold about $20 million worth of his shares while in possession of critical undisclosed information, thus being a liable for an insider trading investigation + Guest Posts However, the dogged pursuit of its valid claims worth millions of dollars on Health Net made Sovereign a soft target that needed to be silenced It was Kenneth Julian who came up with the idea of attacking Sovereign with vanous false accusations so that an enquiry into its operations by a federal agency becomes imminent + Politics » Healthcare To make this apparent falsehood stick, Kenneth Julian and others accused in the lawsuit, participated in making false representations to » Sports vanous lawmakers and federal agencies against Sovereign +» Technology Determined to have criminal proceedings initiated against Sovereign, Kenneth Julian, on behalf of all Defendants, created a PowerPoint presentation in which patently false accusations were made against Sovereign without an iota of evidence * Uncategorized Through this malicious presentation, Kenneth Julian suggested “targets” for criminal investigation, misrepresented the contents of vanous interviews; and suggested legal theories for criminal prosecution. This presentation was made to Kenneth Julian's former colleagues at the FBI and the U.S. Attorney in Orange County to convince them that Sovereign needed to be investigated What Kenneth Julian specifically omitted in this presentation was the fact that Sovereign had already sued Health Net to recover its unpaid claims. Kenneth Julian knew that this fact would blow the lid off the whole charade that he and his colleagues were playing Eventually, Kenneth Julian was able to convince some FBI officials with his lies and had them initiate an inquiry into Sovereign's operations Kenneth Julian and his colleagues went a step ahead and broke the story of FBI's search at Sovereign's premises to the media so as to tamish Sovereign's reputation, which led to its closure in 2018 Now, Sovereign is back with a fresh lawsuit against everyone who conspired against its legitimate operations. It remains to be seen how Kenneth Julian and his colleagues now feel, considering that their lies are all about to come undone and the fire has reached their own doorsteps! Px Stop Using Toilet Paper This “DIY” bathroom upgrade is saving Americans thousands on Toilet Paper. (C Clear Rear Open > Filed in: Business Tags: Kenneth Julian, Manatt, Phelps & Phillips Lisa Miller Contact Author Share This Post Get Updates fing RELATED POSTS newsletter code INSURANCE LEAD HQ Know more about shipping cars ~~ Meet the Nextgen Tech Internet Insurance Lead E 9 causes why your improvement to Germany Entrepreneur Parmarth Mori Providers Get the Boot! 2s check isn't here: Dead closures, making his home town g structure issues, more Wadhwan Surendranagar Proud © Copyright 2020 The Open News https://www.openthenews.com/kenneth-julian-of-manatt-sued-for-fraud-conspiracy/ Page 2 Printed May 30, 2020 Ex 4 Exhibit 5 43 ABOUT US [ele 17 Non AUTHORS PRIVACY POLICY GlobeStats HOME SPORTS HEALTH TRAVEL (W[ 23 gl Ileana Hernandez of Manatt sued for Conspiracy & Slander El = Spread the love BX HOODIE EE 4 Blood Pressure Medicines To Avoid Learn more $9.98 For Excellent Breathability www.onnrons.com lleana Hernandez, an att ar acc f rack provider, Sovereign Health Group. The lawsuit, wh in the US District Courts has named five indi CATEGORIES defendants. The full complaint against lleana Hernandez can be accessed at this URL > cm The charges made against the defen Hea and slander among others. The Hernandez knowingly participatec Lifesty Sport Trav LATEST POST : ; 44 https://www.globestats.com/ileana-hernandez-of-manatt-sued-for-conspiracy-slander/ Page 1 Printed May 30, 2020 Ex 5 The defendants, including lawyer lleana Hernandez, were successful in their conspiracy and were able to drive Sovereign Health Group out of business in 2018. They are said to have caused irreparable reputational harm to Sovereign by spreading lies and rumours Beximco becomes World's first about its business and professional practices without any evidence. company to manufacture generic Remdesivir The defendants, including lawyer Illeana Hernandez, are also said to have planned and Exclusive: Zoom intends to turn out solid made false representations to federal agencies against Sovereign. They were successful in misleading some FBI officials through their. This resulted in the FBI initiating an encryption for paying investigation against Sovereign and conducting a physical search of its premises. do clients This one incident proved to be the most harmful for Sovereign as it literally drove all its pA Meet Rising Next-Gen patients away and ruined its reputation. What is remarkable about this whole charade is tech Entrepreneur that the FBI didn't find anything remotely incriminating against Sovereign in its <3 Parmarth Mori showing investigation new ways to IT sector Ahmedabad Gujarat However, the negative media coverage against Sovereign managed by the defendants © Todays Doodiecelbinies was extremely detrimental and proved to be the proverbial last nail. As a result of the web 3 Margaret Lin Xavier (Lin of lies spun by the defendants including lawyer Illeana Hernandez, Sovereign's reputation 4 Ju Srivisarnvaja) was so tarnished that it had to close down its business in 2018. Arizona sues Google over This has become the basis of Sovereign's demand for a jury trial against all the defendants cases it unlawfully including lleana Hernandez and an amount of $1.125 billion as compensation for damages. — followed area of Android ® clients Official Trump Approval Survey x Do You Stand with President Trump? Take the Official Trump Campaign Poll... Bangoood P X TOPICS < DONTMISS IT UP NEXT » The new sensation of the music industry PBE Coronavirus ‘doesn't spread effectively’ by Pluto is blooming high contacting surfaces or articles, CDC currently says. Be that as it may, it despite everything ‘might be conceivable’. LAURIE PATNICK Laurie Patnick is a news author, critic and mountaineer. Her educational background in family science and journalism has given her a broad base from which she approaches many topics. Laurie's broad understanding of these topics has made her an expert on many topics and now she shares her knowledge with the world through globestats.com. YOU MIGHT ALSO LIKE https://www.globestats.com/ileana-hernandez-of-manatt-sued-for-conspiracy-slander/ Page 2 Printed May 30, 2020 Ex 5 Exclusive: Zoom intends to turn out solid encryption for . paying clients 4 i i )| Spread the love Oily oricoEmoo - A “ 3 : A Spread the love Video conferen i ) Ié€ ta Yat Weekly Trump Approval Poir” Only Three More Hours to Tell Us Whether You Approve of President Trump and His Policies Donald J. Trump Action Meet Rising Next-Gen tech Entrepreneur Parmarth Mori showing new ways to IT sector Ahmedabad Gujarat Spread the love pa — < Spread the love Fear is familiar with the unknown For an entrepreneur, they understand the risk of business and every Arizona sues Google over cases it unlawfully followed area of Android clients Spread the love jf — < one of numerous lawfu winds up in Arizona ey General Mark Brnovich has recorded : ; 46 https://www.globestats.com/ileana-hernandez-of-manatt-sued-for-conspiracy-slander/ Page 3 Printed May 30, 2020 Ex 5 Plus Size Newchic American Airlines strategy 30% decrease of the board, managerial staff Spread the love HE CERE LE 2 Spread the love American Airlines hopes to diminish the board and managerial employments by 30%. The aircraft is additionally offering. Bad Credit Auto Financing Spread the love EI < Spread the love Bad credit can be next to impossible to correct when you need to buy something to correct. 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Brands change Paris Fashion Week runway timetable to maintain a strategic distance from yellow vests protesters Spread the love [WG ]in[P]i LIBRA Spread the love You may state that fluorescent yellow is this present season's colour in France... As Paris men's Fashion. POST COMMENT COMMENT NAME * EMAIL" WEBSITE POST COMMENT https://www.globestats.com/ileana-hernandez-of-manatt-sued-for-conspiracy-slander/ Page 5 Printed May 30, 2020 Ex 5 MOST VIEWED Together 118,473 streams Streams Totals for this song Stackin Up Entertainment & Uneekint of Sony Music Collaboration © 3 MONTHS AGO © 42976 VIEWS Global Stats is an extensive repository of the latest curated news from various industries such as health, sports, travel and lifestyle across the globe. We provides news, latest stories, and events that shape the trends of the market Make Detection in Bakersfield, Seg v © SMONTHS AGO © 36839 VIEWS Globe Stats, 445 E Ohio Street, Unit 2708 Chicago, IL 60611 +] (773) 654-0355 info@globestats.com Sean Borg and Lady Victoria Hervey Spotted in West Hollywood © 10 MONTHS AGO © 14934 VIEWS CATEGORIES Business Health Lifestyle Sports licVEl Uncategorized Palm Beach County School Board Member Karen Brill Announces Acceptance into the 2019 Leadership Florida Education Class © 7 MONTHS AGO © 14001 VIEWS GET GLOBE STATS NEWS IN GOOGLE NEWS APP Install Google News on Android or iOS, and then access our edition through the app by Clicking https:/bit.ly/2De3jxg GloheStats = Copyright 2019 Globe Stats - All Rights Reserve https://www.globestats.com/ileana-hernandez-of-manatt-sued-for-conspiracy-slander/ Printed May 30, 2020 Exhibit 6 50 ABOUT US CONTACT EDITORS PRIVACY POLICY TERMS OF SERVICE NEWS HEADLINE HEALTH + LIFE-CULTURE + TECHNOLOGY + USNEWS Manatt Lawyers sued for Racketeering Conspiracy » » Manatt Lawyers sued for Racketeering Conspiracy RECENT POSTS in philanthropy - Koushik Sengupta TVs » Quick Tips to Social Media Growth By Steve “Capo” Newland » 6 delightful, solid, plant-based snacks to assist of energy you through quarantine » How The Lots Of Protein You'll Receive From Vegan Protein Sources Manatt Lawyers sued for Racketeering CATEGORIES Conspiracy Bm Health On by in ®, ® Life-Culture In an ironic state of affairs, three senior lawyers of Manatt, Phelps & Phillips, have been named as co-conspirators in a $1.1B lawsuit filed in the US District courts = Technology These three lawyers, Ileana M. Hernandez, Kenneth B. Julian and John M. LeBlanc, are said to have willingly participated in, and helped execute a conspiracy to drive a ® Uncategorized legitimate and mental healthcare services provider, Sovereign Health Group, out of business in 2018. Please follow the link, https./bitly/3ccANw2, to access the complaint document against Manatt Lawyers and their alleged accomplices BB US News These allegedly rogue lawyers of Manatt maliciously targeted Sovereign Health Group's CEO, Dr. Tonmoy Sharma, through a series of false statements made to various lawmakers and federal agencies including the FBI without even a shred of evidence https://www.newsheadline.us/manatt-lawyers-sued-for-racketeering-conspiracy/ Printed May 30, 2020 » Not just in photography but also interests » Realme declares its first smartwatch and Page 1 Ex 6 51 On its website, Manatt claims to be a multidisciplinary. integrated national professional services firm known for quality and an extraordinary commitment to clients. With the serious charges made against Manatt's lawyers in the, it seems that the firm, or at least some of its lawyers, have taken its commitment to clients a bit too seriously and do not think twice before stepping out of the line and engaging in unlawful activities. The three allegedly crooked lawyers of Manatt hatched up and executed a conspiracy on the behest of their client, Michael Neidorff, CEO of Centene Corporation, so as to help him bury his various actions and inactions as the chief executive of one of the largest insurance companies in the America. The conspiracy, wherein Manatt Lawyers were willing and active participants, was aimed at stopping Sovereign in its attempt to recover millions of dollars that Health Net, a subsidiary of Centene Corporation, owed to Sovereign. Centene, in its statutory filings for 2016 had apparently not disclosed outstanding claims on Health Net worth hundreds of million dollars, which were being pursued by Sovereign and several other healthcare providers. Accepting the financial liability and its consequences will have proven a definite roadblock in the acquisition of Health Net by Centene in 2016. In effect, Manatt Lawyers apparently helped Michael Neidorff hide about 300 Million Dollars worth liability from the company's balance sheet. This conspiracy enabled Centene's CEO Michael Neidorff and its Board of Directors to sign off Health Net's acquisition and book huge profits by the company , a portion of which they claimed as their own personal compensation in cash and stocks. This makes Manatt lawyers accomplices in insider trading of over $20M of shares that Michael Neidorff sold later on. In the opinion of some industry experts, if the allegations in the lawsuit prove to be true, it will not only be the biggest blot on a law firm of the stature of Manatt, Phelps & Phillips, but will also look bad on the legal profession as a whole and that would be a real shame. Joel Woodley Joel Woodley is a freelance journalist, bringing you interesting health fiction, tales of discovery and critical story at everything from deadly diseases. Joel earned BA in English from texas college and she is currently based in USA. she are contributing to the newsletter for newsheadline.us. Joel Woodley Joel Woodley is a freelance journalist, bringing you interesting health fiction, tales of discovery and critical story at everything from deadly diseases. Joel earned BA in English from texas college and she is currently based in USA. she are contributing to the newsletter for newsheadline.us. https://www.newsheadline.us/manatt-lawyers-sued-for-racketeering-conspiracy/ Page 2 Printed May 30, 2020 Ex 6 Previous Article Next Article The Clout Dealer You Didn't Know About, but How The Lots Of Protein You'll Receive From Certainly, Want on Your Team Vegan Protein Sources Leave a Reply Your email address will not be published. Required fields are marked * Comment Name * Email * Website Save my name, email, and website in this browser for the next time | comment. CATEGORIES LJ EE) LJ eT TT ® Technology 8 Uncategorized 8 US News f FACEBOOK RECENT POSTS » Not just in photography but also interests in philanthropy - Koushik Sengupta » Realme declares its first smartwatch and Wa » Quick Tips to Social Media Growth By Steve “Capo” Newland *» 6 delightful, solid, plant-based snacks to assist of energy you through quarantine *» How The Lots Of Protein You'll Receive From Vegan Protein Sources © Copyright 2019 News Head Line - All Rights Reserved. WordPress Theme : By Sparkle Themes 53 https://www.newsheadline.us/manatt-lawyers-sued-for-racketeering-conspiracy/ Page 3 Printed May 30, 2020 Ex 6 Exhibit 7 54 About us Contact Us Our Authors Terms of Service Privacy Policy ALL NEWS BUZZ Business Health Tech Science MRSS & Home» Liann Gohari of Health Net faces Conspiracy lawsuit n May 18, 2020 by ida Taylor | 0 Comments The Lawbreaker Lady Lawyer Liann Gohari, the Vice President and Deputy General Counsel at Health Net Inc., a subsidiary of Centene Corporation has been named as a co-conspirator in a $1.1B lawsuit filed by a mental health care services provider, Sovereign Health Group. The lawsuit claims that Liann Gohari willingly participated and unlawfully acted in the planning and execution of a malicious conspiracy to drive Sovereign Health Group out of business in 2018 by causing irreparable damage to its reputation with the help of several other accomplices who have also been named in the lawsuit. The full complaint is available here ~ https:/bit.ly/2WHIw15 The lawsuit says that in January 2016, Health Net hired a law firm to collaborate on a strategy regarding the outstanding claims by out-of- network substance abuse providers including Sovereign Health Group. In furtherance of the plan, Liann Gohari, along with the lawyers from the company’s law firm devised a fraudulent scheme to make false accusations against Sovereign and other out-of-network substance abuse providers. As a part of the scheme, Health Net instituted a special investigation unit (“SIU”) to conduct an “audit” of Sovereign and other substance use disorder treatment centers in California as a pretext for refusing to pay claims. The lawsuit claims that Sovereign and other providers were placed on an SIU “watchlist.” All claims from providers on the “watchlist” were asked to be re-routed through this SIU audit unit, which led to an exponential increase in the number of claims that Health Net refused to pay. Centene Corporation acquired Health Net in March 2016 and became a part of the elaborate scheme hatched by Liann Gohari with the lawyers of the company's law firm. Itis alleged that Gohari drafted a boilerplate form letter to more than 1,000 treatment centers designed to hide the blanket policy of refusing to pay certain claims and the policy of indiscriminately rerouting claims to SIU. Gohari caused the letter to bear the signature of Health Net's Director of SIU, Matthew Ciganek, without Mr. Ciganek’s prior knowledge. The Ciganek letter imposed unlawful and onerous burdens on providers regarding claim submission, requesting extensive and unusual amounts of documentation in a short time frame making it literally impossible for timely submissions. The letter also stated that Health Net was suspending payment on claims previously submitted and that Health Net was investigating alleged fraudulent practices. Later on, Liann Gohari and others accused in the lawsuit, participated in making false representations to various lawmakers and federal agencies against Sovereign. They managed to convince some officials and have Sovereign investigated by the FBI through their web of lies so as to tamish Sovereign's reputation leading to its closure in 2018. Filed in: Business Tags: Conspiracy lawsuit, Health Net, Liann Gohari Ida Taylor Ida Taylor is a celebrity chef, author, travel documentarian, and television personality who focused on intemational cuisine and culture. She wrote both fiction and historical nonfiction the culinary mysteries. She also wrote news articles on alinewsbuzz.com as a free lance author. The First Place in UAE Desert Quad Race is for Banbouk Yamaha Team Puff Pass live at Boudoir Dubai Sustainable Power Source Divi Banbouk Music released his first track Massachusetts Adds 1,500 Workers to sion Mars Express Catches Picture of a Frosty Hole on the Surface of Mars More Than 3,000 Patients Potentially = Exposed to HIV, Hepatitis Categories + Business » Entertainment + Health » Science » Sports » Tech » Uncategorized https://www.allnewsbuzz.com/liann-gohari-of-health-net-faces-conspiracy-lawsuit/ Printed May 30, 2020 Page 1 ExT Share This Post Get Updates newsletter code vflin& RELATED POSTS Expect additionally stunning Taken care of finds new test for Managed Health Network faces financial information in the the economy: Workers who Racketeering lawsuit week ahead with the joblessness would prefer not to return to rate set to approach 20% their occupations Post Comment What is Cuzzi Gang, and why does Steve “Capo” Newland have all the buzz in Las Vegas? Comment fleoas Email * Website Post Comment D Copynght 2019 All News Buzz https://www.allnewsbuzz.com/liann-gohari-of-health-net-faces-conspiracy-lawsuit/ Printed May 30, 2020 Page 2 ExT Exhibit 8 57 About us Our Team Terms of Service Privacy Policy Contact us (e112 eli] Lifestyle Sella SlelA[a)] Home > Sci/Tech > Michael Neidorff Faces Financial Fraud Lawsuit Again Michael Neidorff faces Financial Fraud lawsuit again A Andrew Roxburgh © May 18,2020 P0 Michael F Neidorff CEO, Centene Corporation 0 SHARES EE < [I REEL) Centene Corporation. CEO, Michael Neidorff, has been named in a new lawsuit filed in the US District courts. If the racketeering conspiracy allegations are proved, Michael Neidorff may also have to face charges of playing a financial fraud of extraordinary proportions on the shareholders and investors of Centene Corporation. He could very well be charged for insider trading to the tune of several million dollars while deliberately failing to discharge his fiduciary duties by not making public and deliberately hiding relevant facts about acquisition of its subsidiary, Health Net, and even lying to the federal agencies including US SEC and the FBI. The current suit filed by the lawyers of a Los Angeles based mental healthcare services provider, Sovereign Health Group, accuses Michael Neidorff and its associates to have conspired to deliberately drive it out of business in 2018. The detailed complaint can be accessed here https: /bit.ly/3dQtsD5 The conspirators are said to have made several apparently false statements, with no supporting evidence, to various federal agencies against the Sovereign Health Group so as to destroy its reputation and drive it out of business. The reason for the conspiracy was to bury Sovereign's valid claims worth millions that were wrongfully denied by Health Net and for which both entities were entangled in a lawsuit. Sovereign's earlier lawsuit against Health Net had literally blown the lid off the lies told by Centene's officials including Michael Neidorff in the company's statutory filings about the financial health and liabilities of Health Net at the time of its acquisition. As per the new lawsuit Michael Neidorff and his co-conspirators aimed to keep Health Net deal away from scrutiny and keep its true financial liabilities and losses hidden from Centene’s investors and shareholders. : ; j . i : : 58 http://www .ustimesnow.com/michael-neidorff-faces-financial-fraud-lawsuit-again/ Page 1 Printed May 30, 2020 Ex 8 Centene's CEO Michael Neidorff lied to the company's Board of Directors and shareholders and signed off false statements in the company's statutory filings. He even lied about Centene and Health Net's financial health in the media and did not talk about Health Net's pending claims and about 300 Million Dollars liability from their balance sheet to save Centene Corporation's share prices from falling in the stock market. Later, Michael Neidorff went on to sell over $20M of his shares while he was very much in the know of this non-public information. To safeguard himself from the apparent consequences of this financial fraud, Michael Neidorff is said to have been one of the perpetrators of a conspiracy against Sovereign so that it could be stopped from pursuing its valid claims. (SNe as Corporation © Financial Fraud Lawsuit © Michael Neidorff Andrew Roxburgh Andrew Roxburgh is a news author, critic and mountaineer. His educational background in family science and journalism has given him a broad base from which to approach many topics. Because of that he has lots of knowledge related to sci/tech. He is always ready to publish latest articles on currently working news website which is ustimesnow.com. You would now be able to add nostalgic application symbols to your iPhone A SophiaHeard © May 26,2020 B0 Father & Son Duo Creates Best New Dice Game? A Isabel Turner EB May 16,2020 BO Vivo's has a giant gimbal-style camera lens on next flagship 2 Sophia Heard B May 20,2020 PO http://www .ustimesnow.com/michael-neidorff-faces-financial-fraud-lawsuit-again/ Page. 2 Printed May 30, 2020 Ex 8 EET . TET TTT da JOT VE. ~— Ace peak Investment Launch Virtual Phone Number service for as low as Kanishk Gupta — Startup under Radar USD 2 per month & Vincent Austin B May 12,2020 P0 Laing B May 13,2020 B0 What Inspires Elevator Studio's VP Of Biz Dev To Work Each Day 2 A Jason Laing BE May 16,2020 [B0 LEAVE A REPLY Your email address will not be published. Required fields are marked * Comment Name * Email * Website Save my name, email, and website in this browser for the next time | comment. ale eT TTT Cream Magazine by http://www .ustimesnow.com/michael-neidorff-faces-financial-fraud-lawsuit-again/ Page 3 Printed May 30, 2020 Ex 8 Exhibit 9 61 About us Contact Us Our Authors Terms of Service Privacy Policy MRSS ALL NEWS BUZZ Business Health Tech Science https://www.allnewsbuzz.com/managed-health-network-faces-racketeering-lawsuit/ Home » The First Place in UAE Desert Quad Race is for Banbouk Yamaha Team Managed Health Network faces Racketeering lawsuit Banbouk Music released his first track Puff Pass live at Boudoir Dubai Massachusetts Adds 1,500 Workers to Sustainable Power Source Division Mars Express Catches Picture of a Frosty Hole on the Surface of Mars More Than 3,000 Patients Potentially = Exposed to HIV, Hepatitis Categories Business Entertainment Health Science Sports In a $1.1 billion lawsuit filed in the US District Courts, Managed Health Network Inc., a subsidiary of Health Net LLC, which in tum is a subsidiary of Centene Corporation, has been accused of racketeering activities and criminal conspiracy aimed at driving a legitimate mental Tech health services provider, Sovereign Healthcare Group, out of business in the year 2018. Uncategorized The Health Net company, Managed Health Network is a Delaware corporation with its principal place of business at 11931 Foundation Place. Building D, Rancho Cordova, California 95670. Managed Health Network offers managed behavioral healthcare, employee assistance programs, organizational development and wellness programs, and non-medical counseling services. According to the complaint filed and available at this URL (https:/bit.ly/3bgs8Yw), Managed Health Network is said to have participated in an elaborate scheme hatched by the senior officials of Health Net and Centene including its CEO, Michael Neidorff, and the lawyers from Health Net's law firm, Manatt, Phelps & Phillips, to destroy the reputation and business of Sovereign, which unwittingly acted as a whistieblower and brought forth $300 million worth of claims unpaid and due to Sovereign and several other out-of-network providers Michael Neidorff specifically failed to mention that there were outstanding claims of hundreds of million dollars on its subsidiary Health Net and deliberately hid about 300 million dollar liability from the company’s balance sheet including unpaid claims of Sovereign which stood at a sum of about $55 million at that time. If Managed Health Network was privy to all this information then it will be considered to have willingly participated in a white collar crime of extraordinary proportions It is alleged that Centene did not disclose this critical information at the time of acquisition of Health Net in 2016 and therefore lied in its SEC filings and kept its investors in the dark about the reality. Centene's CEO, Michael Neidorff repeatedly lied about the financial health of Health Net in several media interviews to ensure that Centene’s share prices kept rising. If Managed Health Network willingly participated in this scheme then it will be liable for its role in one of the biggest corporate frauds in recent times As per the complaint, Health Net was engaged in a scheme to enrich itself by backtracking on its insurance promises and denying payment to its out-of-network mental healthcare providers even for the treatment of patients that it had earlier approved. When Centene took over Health Net, it joined this scheme and made it even more elaborate with the help of lawyers from Manatt and others accused in the case The accused, including Managed Health Network, seemingly created a “denial vortex” to be able to deny valid claims of out-of-networks mental healthcare service providers including Sovereign on one pretext or the other. Sovereign's business was seriously affected when Health Net kep denying its valid claims without regard to goveming law and slowly the amount that it owed to Sovereign rose to a massive $55 million receivable for the provider. Printed May 30, 2020 Ex 9 Page 1 62 When this happened, Sovereign filed a case against Health Net in June 2016. In essence, Sovereign became a whistleblower as the outstanding amount was till then not disclosed or logged in Health Net's books of accounts. This led to a downfall in Centene's share price in the stock market and its valuation came down by about $1 billion. This really shook up the perpetrators of the alleged white collar crime and they took its evil scheme to a whole new nefarious level. To get back at Sovereign, the accused including Managed Health Network, then started to spread malicious falsehoods and rumours about Sovereign's operations so as to destroy its reputation and business. They made several false claims and accusations against Sovereign and got the FBI to initiate an investigation against Sovereign. On the moming of June 13, 2017, based on their false reports, more than 100 armed officers from the FBI and other departments of health and human services executed search warrants on Sovereign. Despite having permission to only recover billing paperwork, vulnerable mental health patients at Sovereign's facilities and its employees were harassed for hours by the FBI team. Sovereign's patients and employees were all physically searched, interrogated, and their cell phones were confiscated, none of which was allowed in the search warrant. It is obvious that the FBI was also lied to by the defendants including Managed Health Network in Sovereign's case and will have to answer to the federal agency sooner or later regarding its role in this charade. This incident attracted a lot of bad press for Sovereign and as a result, hundreds of its mentally vulnerable patients discontinued their treatment at Sovereign forcing it to close all facilities by July 2018. Sovereign has now come back with its new suit against Managed Health Network and other defendants in its case and is demanding for a jury trial and damages to the tune of $1.125 billion. Filed in: Business Tags: Health Net LLC, Managed Health Network, Michael Neidorff, Racketeering lawsuit, Sovereign Healthcare Group Josh Donohue Josh was taught at home by his father, and leamed engraving and an appreciation for classical Greek art. He was on his own by age 21, and began his own career as an engraver. After his wedding, he taught his wife how to read and write, as well as teaching her engraving skills. He is not only engraver but also an author of news articles. He writes latest news and published it on allnewsbuzz.com as a free lance author. Share This Post Get Updates 9 f g fe a newsletter code RELATED POSTS |! Expect additionally stunning Taken care of finds new test for What is Cuzzi Gang, and why i Hassett says joblessness rate could financial information in the the economy: Workers who does Steve “Capo” Newland have i > be ‘north of 20%’ in May with week ahead with the joblessness would prefer not to return to all the buzz in Las Vegas? . Ste conceivable twofold digits in rate set to approach 20% their occupations November Post Comment Comment Name * Email * Website Post Comment © Copyright 2019 All News Buzz https://www.allnewsbuzz.com/managed-health-network-faces-racketeering-lawsuit/ Page 2 Printed May 30, 2020 Ex 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 x7 28 MANATT, PHELPS & PHILLIPS, LLP ATTORNEYS AT LAW LOS ANGELES PROOF OF SERVICE I, Judy Feingold, declare as follows: I am employed in Los Angeles County, Los Angeles, California. I am over the age of eighteen years and not a party to this action. My business address is MANATT, PHELPS & PHILLIPS, LLP, 2049 Century Park East, Suite 1700, Los Angeles, California 90067. On June 9, 2020, I served the within: DECLARATION OF J. CHRISTOPHER RACICH — WITH EXHIBITS IN SUPPORT OF MOTION FOR ORDER ADDRESSING ARTICLES DIRECTED AT DEFENDANTS AND DEFENDANTS’ COUNSEL on the interested parties in this action addressed as follows: Joshua M. Robbins GREENBERG GROSS LLP 650 Town Center Drive, Suite 1700 Costa Mesa, CA 92626 Phone: 949-383-2800 Fax: 949-383-2801 Email: jrobbins@ggtriallaw.com Lisa S. Kantor J. David Oswalt Timothy J. Rozelle Sarah Demers KANTOR & KANTOR, LLP 19839 Nordhoff Street Northridge, CA 91324 Phone: 818-886-2525 Fax: 818-350-2801 Email: lkantor@kantorlaw.net Email: doswalt@kantorlaw.net Email: trozelle@kantorlaw.net Email: sdemers@kantorlaw.net Michael J. FitzGerald Eric P. Francisconi Fitzgerald Yap Kreditor LLP 2 Park Plaza, Suite 850 Irvine, CA 92614 Phone: 949-788-8900 Fax: 949-788-8980 Email: mfitzgerald@ftyklaw.com efrancisconi@fyklaw.com Attorneys for Plaintiffs and Cross-Defendants DUAL DIAGNOSIS TREATMENT CENTER, INC., ET AL. Attorneys for Plaintiffs and Cross-Defendants DUAL DIAGNOSIS TREATMENT CENTER, INC., ET AL. Attorneys for Cross-Defendants MAHYAR MOHASES AND CRMW, INC. 326401292.1 PROOF OF SERVICE 64 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 x7 28 M Penta LLB ATTORNEYS AT LAW LOS ANGELES Steven C. Dawson Anita Rosenthal Dawson & Rosenthal, P.C. 25 Schnebly Hill Road Sedona, AZ 86336 Phone: 928-282-3111 Email: sdawson@dawsonandrosenthal.com arosenthal@dawsonandrosenthal.com Sander R. Dawson Dawson & Rosenthal, P.C. 402 West Broadway, Suite 2100 San Diego, CA 92101-8510 Phone 619-354-1652 Fax: 928-282-3126 Email: sander@dawsonandrosenthal.com Attorneys for Plaintiffs and Cross- Defendants, DUAL DIAGNOSIS TREATMENT CENTER, INC., ET AL. Attorneys for Plaintiffs and Cross- Defendants, DUAL DIAGNOSIS TREATMENT CENTER, INC., ET AL. (BY ELECTRONIC MAIL PER MUTUAL AGREEMENT) By transmitting such document(s) electronically from my e-mail address, jfeingold@manatt.com at Manatt, Phelps & Phillips, LLP, Los Angeles, California, to the person(s) at the electronic mail addresses listed above. The transmission was reported as complete and without error. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed on June 9, 2020, at Granada Hills, California. Judy Feingold “Judy Feingold 326401292.1 PROOF OF SERVICE 65
