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(Id. ¶ 21.)

State Farm alleges that counterclaim-defendants conducted their insurance fraud scheme

as follows: Counterclaim defendants would solicit individuals who were involved in motor

vehicle accidents. (Id. ¶¶ 16-17.) Those who chose to treat at Allied were “placed on a

standardized and predetermined treatment plan[,]” which included “physical therapy and/or

chiropractic treatment, electromyography (EMG) and nerve conduction testing, orthopedic

consultation and/or other testing . . . .” (Id. ¶ 19.) The treatment plan was not implemented for

the benefit of the patient, but rather “for the financial benefit of Counterclaim Defendants and/or

other entities and/or individuals and/or to support past and future treatment and services and/or to

support uninsured, underinsured and liability claims brought by individuals who treated at Allied

. . . .” (Id.) Counterclaim-defendants did not provide many of the procedures for which they

sought reimbursement and certain procedures counterclaim defendants did provide were not

medically necessary. (Id.) State Farm cites seventeen bills submitted by counterclaim-

defendants that sought reimbursement for treatment that Allied did not, in fact, provide to

patients. (Id.) State Farm also cites four examples where counterclaim-defendants provided

medical treatment that was inconsistent with the patients’ injuries. (Id. ¶ 25.) In addition to

Allied’s own provision of unnecessary treatment, counterclaim-defendants also referred patients

to other healthcare providers to receive unnecessary treatment and medical tests. (Id. ¶¶ 21-22.)

To obtain reimbursement from State Farm, counterclaim-defendants prepared, or had

other Allied employees prepare, “fraudulent, misleading, and/or inaccurate . . . medical reports,

bills and/or other documents . . . .” (Id. ¶ 24; see id. ¶ 11.) Counterclaim-defendants obtained

reimbursement by using “current procedural terminology” codes in their billing forms to classify


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