STATE OF WYOMING ) ) 55: COUNTY OF NIOBRARA) IN THE DISTRICT COURT EIGHTH JUDICIAL DISTRICT Docket No.: CQ-2D\a tos O THE STATE OF WYOMING VS. Plaintiff, LISA L. MELLOTF YEAR OF BIRTH: 1967 Defendant. FILED IN DISTRICT COURT NIOBRARA COUNTY, WYO. FEB 182016 KAYLA COURTRIGI-IT CLERK OF THE DISTRICT COURT By: AMENDED INFORMATION The State of Wyoming by and through Nathaniel S. Hibben, and in the name and by the authority of the State of Wyoming, informs the Court and gives the Court to understand that: Count 1: Medicaid Fraud > $5,000 A. On or between the 1st day of July, 2013 and the 31st day of August, 2015; D. Did knowingly fail to maintain records in accordance with Medicaid program rules as necessary to disclose fully the nature of the goods, services, for which claims were submitted under the Medicaid program, to wit: did intend to defraud and the medical assistance for which records were not maintained in twenty-five percent or more of the Medicaid claims submitted by MELLOTF in at least a consecutive three month period and the value of the claims is greater than $5,000.00 in violation of W.S. 42-4-11 l(e)(iii), the same being a Felony. (SEE AFFIDAVIT OF PROBABLE CAUSE); Count 2: Medicaid Fraud > $500 A. On or between the 1st day of July, 2011 and the 31st day of July, 2015; is greater than Five Hundred dollars ($500.00), to wit: did unlawthlly make a false statement in providing case management services to client DB, and the value of ($500.00) dollars in violation of W.S. 42-4-111 (a)(b)(i), the same being a Felony. (SEE
U U Count 3: Medicaid Fraud > $500 a material fact in providing Medicaid medical assistance and the value of reimbursement is greater than Five Hundred dollars ($500.00), to wit: did unlawfully make a false statement in providing case management services to client CD, and the value of reimbursement received from Wyoming Medicaid is greater than Five Hundred ($500.00) dollars in violation of W. S. 42-4-111 (a)(b)(i), the same being a Felony. (SEE AFFIDAVIT OF PROBABLE CAUSE); Count 4: Medicaid Fraud > $500 A. On or between the 6th day of May, 2013 and the 31st day of January, 2015; C. LISA L. MELLOn; statement in providing case management services to client VII, and the value of ($500.00) dollars in violation of W.S. 42-4-11 l(a)(b)(i), the same being a Felony. (SEE Count 5: Medicaid Fraud > $500 statement in providing case management services to client DH, and the value of ($500.00) dollars in violation of W.S. 424-11 1(a)(b)(i), the same being a Felony. (SEE Count 6: Medicaid Fraud > $500 A. On or between the 1st day of January, 2011 and the 30th day of June, 2015; C. LISA L. MELLOTT;
U U statement in providing case management services to client JH, and the value of ($500.00) dollars in violation of W.S. 42-4-111 (a)(b)(i), the same being a Felony. (SEE Count 7: Medicaid Fraud > $500 statement in providing case management services to client IP, and the value of ($500.00) dollars in violation of W.S. 42-4-11 1(a)(b)(i), the same being a Felony. (SEE Count 8: Medicaid Fraud > $500 statement in providing case management services to client CP, and the value of ($500.00) dollars in violation of W.S. 42-4-11 1(a)(b)(i), the same being a Felony. (SEE Count 9: Medicaid Fraud> $500 A. On or between the 7th day of May, 2013 and the 31st day of May, 2015;
statement in providing case management services to client JS, and the value of ($500.00) dollars in violation of W.S. 42-4-111 (a)(b)(i), the same being a Felony. (SEE Count 10: Medicaid Fraud> $500 A. On or between the 15th day of September, 2011 and the 31st day of July, 2015; statement in providing case management services to client 1W, and the value of reimbursement received from Wyoming Medicaid is greater than Five hundred ($500.00) dollars in violation of W.S. 42-4-11 l(a)(b)(i), the same being a Felony. (SEE Count 11: Medicaid Fraud> $500 A. On or between the 1st day of January, 2011 and the 31st day of May, 2015; C. LISA L. MELLOn; statement in providing case management services to client NW, and the value of ($500.00) dollars in violation of W.S. 42-4-11 l(a)(b)(i), the same being a Felony. (SEE Count 12: Forgery A. On or between the 8th day of June, 2015; Choice of Service form so that said form purported to be the act of DB, who did not authorize that act, in violation of W.S. 6-3-602(a)(ii)(b), the same being a Felony. (SEE
U Count 13: Forgery A. On or between the 8th day of June, 2015; Responsibility form so that said form purported to be the act of DB, who did not authorize that act, in violation of W.S. 6-3-602(a)(ii)(h), the same being a Felony. (SEE Count 14: Forgery A. On or between the 28 th day of October, 2013; Choice of Service form so that said form purported to be the act of JS, who did not authorize that act, in violation of W.S. 6-3-602(a)(ii)(b), the same being a Felony. (SEE Count 15: Forgery A. On or between the 28th day of October, 2013; Responsibility form so that said form purported to be the act of JS, who did not authorize that act, in violation of W.S. 6-3-602(a)(ii)(b), the same being a Felony. (SEE Against the peace and dignity of the State of Wyoming.
DATED this /7 day of February, 2015. Nathaniel S. Hibben, WSB # 7-4553 Special Prosecutor P0 Box 130 215 East 21 Avenue Torrington, WY 82240 (307) 532-2700 Melissa R. Theriault, WSB # 6-4266 Special Prosecutor Medicaid Fraud Control Unit Senior Assistant Attorney General Wyoming Attorney General's Office 123 Capitol Building Cheyenne, WY 82001-3021 (307) 777-8084
STATE OF WYOMING ) )SS COUNTY OF GOSHEN I, NATHANIEL S HIBBEN, Special Prosecutor of the County of Niobrara, in the State of Wyoming, do solemnly swear that I have read the above and foregoing information by me subscribed, that I know the contents thereof, and that I have been reliably informed and verily believe the facts therein stated to be true. So help me God. NATHANIEL S. HIBBEN Sworn to before me and signed in my presence the do hereby so certify. /' / day of February, 2015, and I My commission expires. OTARY PUBLIC