Case 5:14-cr-40151-DDC Document 1 Filed 12/17/14 Page 1 of 24
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF KANSAS
UNITED STATES OF AMERICA,
)
)
Plaintiff,
)
)
v.
)
)
MAUREEN LONG, d/b/a
)
CAMELOT CANCER CARE, INC., )
)
Defendant.
)
_______________________________)
14-40151-DDC
Case No. ________________
Counts 1-13: 18 U.S.C. §§ 2, 1343
INDICTMENT
The Grand Jury charges:
At all material times:
INTRODUCTION
1.
From in or about 2007, and continuing through the present, in the
District of Kansas and elsewhere, defendant MAUREEN LONG, doing business
as Camelot Cancer Care, Inc., and aided and abetted by others, devised and
executed a scheme to defraud the Food and Drug Administration and individuals
desperately seeking cures for cancer by infusing clients with what she often called
her “secret sauce.” The defendant claimed her infusion treatments contained FDAapproved drugs proven safe and effective as cancer treatments, when they actually
contained non-FDA approved drugs and misbranded drugs. In executing her
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scheme to defraud, defendant MAUREEN LONG used interstate wire
communications, including e-mail communications to and from Kansas residents.
The Defendant and Her Business
2.
Defendant MAUREEN LONG founded and operates Camelot
Cancer Care, Inc. (“Camelot”). On March 29, 2007, Camelot, was incorporated in
the State of Delaware as a “for profit business corporation.”
3.
At one time, Camelot operated out of a commercial property located
at 6804 S. Canton Avenue, Suite 110, in Tulsa, Oklahoma. It then operated out of
defendant MAUREEN LONG’s residence and motels, such as the Fairfield Inn &
Suites. Additionally, clients were sent home to administer the ostensible cancer
treatments themselves.
4.
Camelot advertises its ostensible cancer treatment programs on the
internet at two websites: www.camelotcancercare.com; and
http://camelotcancercare.exdnn.com.
5.
Defendant MAUREEN LONG is not a physician, nurse, or other
licensed medical professional.
6.
Camelot’s staff is primarily comprised of defendant MAUREEN
LONG and members of her family. Defendant’s now-deceased husband
corresponded with clients via e-mail. None of these family members were or are
licensed medical professionals.
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7.
Defendant MAUREEN LONG, through Camelot, hires nurses who
work as independent contractors to provide limited services, such as the insertion
of PICC (Peripherally Inserted Central Catheter) lines.
8.
Defendant MAUREEN LONG, through Camelot, hires physicians
who are not oncologists (cancer specialists). The physicians do not act
independently, but act at the direction of defendant MAUREEN LONG,
performing primarily ministerial tasks, such as writing prescriptions and orders.
One physician lost her license to practice medicine in the State of Oklahoma as a
result of working at Camelot.
The Food Drug and Cosmetic Act
9.
The United States Food and Drug Administration (“FDA”) is the
federal agency responsible for protecting the health and safety of the American
public by ensuring, among other things, that drugs and devices are safe and
effective for their intended uses and have labeling that contain true and accurate
information. FDA carries out its responsibilities by enforcing the Federal Food,
Drug, and Cosmetic Act (“FDCA”) and other pertinent laws and regulations.
10.
The Food Drug and Cosmetic Act defines “label” as: “a display or
written, printed, or graphic matter upon the immediate container of any article.”
See 21 U.S.C. § 321(k).
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11.
The Food Drug and Cosmetic Act defines “labeling” as all labels and
other written, printed, or graphic matter (1) upon any article or any of its
containers or wrappers, or (2) accompanying such article. See 21 U.S.C. §
321(m).
12.
The Food Drug and Cosmetic Act defines a “drug” as an article
intended for use in the diagnosis, cure, mitigation, treatment, or prevention of
disease in man or other animals; an article (other than food) intended to affect the
structure or any function of the body of man or other animals; and an article
intended for use as a component of any such article. See 21 U.S.C. § 321(g)(1)(B),
(C), and (D).
13.
The Food Drug and Cosmetic Act defines a “new drug” as, with limited
exceptions, any drug that is not generally recognized as safe and effective among
experts qualified by scientific training and experience to evaluate the safety and
effectiveness of drugs for use under the conditions prescribed, recommended or
suggested in its labeling. See 21 U.S.C. § 321(p). Unless there is in effect with the
FDA a new drug application (“NDA”) or an abbreviated new drug application
(“ANDA”), a new drug is unapproved and cannot lawfully enter into interstate
commerce. See 21 U.S.C. §§ 355(a); 331(d).
14.
New Drug Applications and Abbreviated New Drug Applications
describe how the product was manufactured, its components, and what was stated
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on the label and in the labeling. As part of the process, FDA must have approved
the manufacturing process, and label and labeling set forth in the application. See
21 U.S.C. § 355(b)(1). The approval process addresses, among other things, the
elements of the distribution, such as the methods used in, and the facilities and
controls used for, the product's manufacturing, processing, and packing; and the
proposed labeling. See 21 U.S.C. § 355(b)(1)(A)-(F). The approval process is
specific to each manufacturer and each product. See 21 C.F.R. § 314.50.
15.
A “prescription drug” under the Food Drug and Cosmetic Act is a drug
that: (i) because of its toxicity and other potential for harmful effects, or the method
of its use, or the collateral measures necessary to its use, was not safe for use
except under the supervision of a practitioner licensed by law to administer such
drug; or (ii) was limited by an application approved by FDA, to use under the
professional supervision of a practitioner licensed by law to administer the
drugs. See 21 U.S.C. § 353(b)(1).
16.
A drug is misbranded if its labeling fails to bear adequate directions
for use. See 21 U.S.C. § 352(f)(1). “Adequate directions for use” means directions
under which a layman can use a drug safely and for the purposes for which it was
intended. See 21 C.F.R. §§ 201.5. By definition, prescription drugs do not have
directions that allowed a layman to use them safely and for the purposes for which
they were intended. See, e.g., 21 U.S.C. § 353(b); 21 C.F.R. § 201.5.
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17.
The Food Drug and Cosmetic Act prohibits causing the introduction or
delivery for introduction into interstate commerce of any “new drug” that lacks
approval. See 21 U.S.C. §§ 331(d) and 355(a).
18.
The Food Drug and Cosmetic Act also prohibits causing the
introduction or delivery for introduction into interstate commerce of any drug that
is misbranded. See 21 U.S.C. § 331(a).
The Scheme to Defraud
19.
For the purpose of luring individuals to pay her money for the
ostensible cancer treatments, defendant MAUREEN LONG, aided and abetted by
her family members, through Camelot’s websites, marketing materials, and e-mail
correspondence with clients, makes false, misleading, and fraudulent statements
about its treatment programs using FDA-approved drugs to treat and cure cancer.
20.
In furtherance of her scheme to defraud, defendant MAUREEN
LONG routinely refers to Camelot as a “clinic”, falsely creating the impression
that she runs an actual, legitimate, medical clinic.
21.
The purpose of defendant’s scheme to defraud is to unlawfully enrich
herself and her family members by manufacturing and distributing drugs that had
not been approved by the FDA, which she called the “Federal Death
Administration.”
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22.
In furtherance of her scheme to defraud, defendant MAUREEN
LONG, through Camelot, communicates by e-mail with clients for the purpose of
providing medical advice. The defendant and her family members routinely give
medical advice to clients regarding medical treatments not determined to be safe
and effective by the FDA or the scientific community.
23.
In furtherance of her scheme to defraud, defendant MAUREEN
LONG, through Camelot’s websites and through e-mails with clients, promotes,
advertises, sells, and distributes in interstate commerce drugs that have not been
approved by the FDA.
24.
In furtherance of her scheme to defraud, defendant MAUREEN
LONG, through Camelot, falsely represents that the drugs used at Camelot are
FDA approved and used by traditional cancer treatment centers.
25.
In furtherance of her scheme to defraud, defendant MAUREEN
LONG, through Camelot, routinely misrepresents and misleads clients regarding
the medical benefits of using her treatments to treat and cure cancer, including
giving clients the false impression that her treatments have been tested in clinical
trials. In truth and in fact, defendant’s treatments are not the product of any proven
clinical trials.
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26.
In furtherance of her scheme to defraud, defendant MAUREEN
LONG, through Camelot, falsely represents that Camelot has a 60% success rate,
resulting in either remission of the cancer or stopping a tumor’s growth.
27.
In furtherance of her scheme to defraud, defendant MAUREEN
LONG, through Camelot, purports to provide “natural, effective alternative cancer
treatment program options.”
28.
In furtherance of her scheme to defraud, defendant MAUREEN
LONG, through Camelot, manufactures and distributes a drug product she called
the “DMSO Protocol”, ostensibly to treat and cure cancer. The DMSO Protocol
purportedly consists of DMSO, Vitamin C, and Vitamin B-17. Defendant
MAUREEN LONG, through Camelot states: “Our primary treatment program
consists of a proprietary blend of pure, pharmaceutical grade, vacuum-distilled
DMSO, high-dose Vitamin C and Vitamin B-17 (also known as Amygdalin or
Laetrile) administered daily over a 20-day period.” But, in truth and in fact, the
DMSO Camelot uses is not pharmaceutical grade and is labeled “not for drug use”
and “do not inject.”
29.
In furtherance of her scheme to defraud, defendant MAUREEN
LONG and Camelot’s employees use IV bags of Lactated Ringer’s and 5%
Dextrose Injection (“Ringer’s solution”). Ringer’s solution is an FDA-approved
prescription drug used for intravenous (“IV”) fluid and electrolyte replacement.
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Defendant MAUREEN LONG and Camelot’s employees would add to the IV
Ringer’s solution, or would claim to add to the IV Ringer’s solution, what the
defendant calls her “secret sauce”, which is purportedly some combination of
DMSO, and Laetrile (also known as Amygdalin or Vitamin B-17). But, forensic
chemical analysis of some seized infusion materials found neither DMSO nor
Laetrile.
DMSO
30.
DMSO is dimethyl sulfoxide. RISMO-50 is a prescription drug
product manufactured by Mylan; its active ingredient is dimethyl sulfoxide. FDA
has approved RISMO-50 for the treatment of bladder disease. In furtherance of her
scheme to defraud, defendant MAUREEN LONG claims that Camelot “was
allowed to administer [DMSO] off-label as a cancer treatment.” But, neither
defendant MAUREEN LONG nor Camelot ever obtained an FDA-approved
prescription drug product that contained DMSO and administered it to her
customers. Instead, the defendant and Camelot obtained unapproved DMSO that
was labeled “not for drug use” and “not for injection.”
31.
In furtherance of her scheme to defraud, defendant MAUREEN
LONG, aided and abetted by her family members, through Camelot, makes the
following false, misleading, and fraudulent statements about DMSO:
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• “There is extensive medical research literature, extending back decades and
covering 1000s of patients, proving the safety of DMSO uses and also its
effectiveness as a cancer treatment.”
• [DMSO] serves as “a gentle but powerful healing substance which is also
very effective and allowed as an off label application in the treatment of
most types of cancers without the toxic effects of other chemo and radiation
methods.”
• “DMSO . . . [cuts] through . . . malignancy like a scythe through a wheat
field.”
• DMSO kills cancer or kills tumors;
• DMSO is a “miracle treatment”;
• “DMSO . . . is a potent cancer killer by itself. . . . Thousands of patients
have received it, going back over 30 years, in many published clinical
trials.”
• “DMSO crosses the blood/brain barrier and reduces brain swelling . . . so
well that even the FDA has finally approved it for treatment of head
trauma.”
Laetrile
32.
Laetrile, also known as Amygdalin or Vitamin B-17, is a substance
derived from the kernels or pits of apricots and other related fruits. Although
Laetrile and Amygdalin are different chemical compounds, their names are
commonly used interchangeably.
33.
Laetrile is a toxic drug, and is not approved for use in the United
States. It has not been demonstrated to be a safe and effective cancer treatment.
Individuals who ingest or who have been injected with Laetrile have been known
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to show symptoms suggestive of cyanide toxicity, or blood cyanide levels
approaching the lethal range, or both. Laetrile is commonly manufactured in
facilities located in Mexico that have not been inspected by the FDA.
34.
Vitamin B-17 is not recognized among experts in the field of nutrition
or nutrition research as a vitamin.
35.
Knowing that it is illegal to obtain and administer Laetrile,
Amygdalin, or Vitamin B-17, and in an effort to avoid government detection,
defendant MAUREEN LONG did not directly procure the Laetrile, Amygdalin, or
Vitamin B-17 from Mexico, but instead had clients procure the Laetrile,
Amygdalin, or Vitamin B-17 from Mexico.
36.
The product procured from Mexico was typically labeled
“Amigdalina.” Amigdalina is an unapproved new drug and a misbranded drug.
37.
In furtherance of her scheme to defraud, defendant MAUREEN
LONG, aided and abetted by her family members, through Camelot, makes the
following false, misleading, and fraudulent statements about Laetrile:
• “[A]ll the major cancer centers infuse [Laetrile].”
• Laetrile is a superior cancer treatment over traditional, medicallyrecognized treatments, such as chemotherapy and radiation;
• Laetrile is absorbed into cancer cells, where it releases cyanide and
kills the cancer cells, while leaving healthy cells unharmed;
• The FDA provides disinformation about Laetrile being an unapproved
drug;
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• The source for the Laetrile used at Camelot is a Mexican drug
manufacturer called CytoPharma, which has good manufacturing
practices and produces some of the highest quality Laetrile on the
market.
38.
In furtherance of the scheme to defraud, Camelot purports to have
experience and success in treating or curing a variety of cancers, including, but not
limited to, the following:
Brain Tumors, including glioblastomas
Breast cancer
Lung cancer
Colon cancer
Prostate cancer
Non-Hodgkin’s Lymphoma
Ovarian cancer
Cervical cancer
Bladder cancer
Renal cell carcinoma
Esophageal cancer
Osteosarcoma
39.
Defendant MAUREEN LONG referred to prospective clients who
contacted Camelot through its websites as “leads.”
40.
The ostensible cancer treatments defendant MAUREEN LONG
provides through Camelot are not covered by insurance. Therefore, defendant
MAUREEN LONG, through Camelot, in furtherance of her scheme to defraud,
charges fees for the ostensible cancer treatment, typically $12-13,000 for the first
round of treatment, $3,600 for each subsequent round of treatment, and $300 per
treatment for the ultraviolet blood irradiation treatments.
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41.
Although Camelot purports to employ licensed physicians, some
prospective clients are not allowed to meet with these physicians prior to agreeing
to and paying for the ostensible cancer treatment. According to defendant
MAUREEN LONG, Camelot’s doctors did not do “auditions” for prospective
clients.
42.
In furtherance of her scheme to defraud, defendant MAUREEN
LONG and Camelot employees instruct clients that they should forego traditional
treatments of radiation and chemotherapy, and participate in her ostensible cancer
treatment program instead.
43.
In furtherance of her scheme to defraud, Camelot employees do not
provide the ostensible cancer treatments in a sterile environment and act in ways
contrary to maintaining sterility, such as not wearing gloves. Consequently, clients
are exposed not only to unapproved new drugs and misbranded drugs, but also to
harmful bacteria and other potential infectious agents.
44.
In furtherance of her scheme to defraud, Camelot’s client records are
sparse and contain little information about the actual drugs infused, the reactions to
the infusions, or the outcomes of the ostensible cancer treatments.
45.
While communicating to her clients about hope, defendant
MAUREEN LONG communicates to her family members about these same
clients in disparaging ways. For example:
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• In speaking about Kansas residents MH & SH, defendant
MAUREEN LONG wrote to a family member: “These people got a
free ride for at least a couple weeks, ducking and dodging payment for
not only free treatment but even free meals and lodging over at the
B&B on us, then gave us a check that they later claimed might not
clear.”
• In speaking about a low income couple from Kansas who needed
financial help to pay for the treatments, defendant MAUREEN
LONG sent an e-mail to her husband, in which she made the
following comment: “Hi, dear, I thought you might enjoy this. I
haven’t sent you the previous emails from this whining couple,
wanting to know if we finance or what sort of funding is available.”
46.
In furtherance of her scheme to defraud, when clients report negative
results from the ostensible cancer treatment, defendant MAUREEN LONG often
chastises the clients, claiming the negative results were because they did not stay
on the treatment long enough. For example:
“If only [MK] had continued right on with his treatments while waiting out
the time for the next PET scan, maybe we could have gotten rid of the big
tumor completely, before it tried to recolonize to new places. . . . If [MK]
had remained on treatment uninterrupted for a total of 3 or even 4 18 day
courses, we might have completely wiped out the cancer by now. All we did
was weaken it by over half . . . but then when treatment was stopped, it went
into survival mode; sending out metastases to recolonize.”
The Kansas Victims
47.
Defendant MAUREEN LONG perpetrated her scheme to defraud on
at least 11 Kansas residents.
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48.
The Kansas residents typically discovered defendant MAUREEN
LONG’s and Camelot’s claims of success in treating and curing cancer on the
internet.
49.
The Kansas residents communicated with defendant MAUREEN
LONG and Camelot employees by telephone and by e-mail.
50.
The Kansas residents traveled to Tulsa to obtain the ostensible cancer
treatments from defendant MAUREEN LONG and Camelot, and brought back the
“DMSO Protocol” to continue treatments in their homes in Kansas, or Camelot
shipped infusion materials to them.
51.
Based on defendant MAUREEN LONG’s false, misleading, and
fraudulent representations, the Kansas residents paid her approximately and at least
$128,000.00 for the ostensible cancer treatments, which were comprised of
unapproved new drugs and misbranded drugs. Specifically, the following Kansas
residents paid the indicated amounts to Camelot:
Name
SA
BGH
PLO
JHH
KMH
JKG
JEH
MH
JA
Kansas Residence
Lenexa
Spring Hill
Hartford
Prairie Village
Spring Hill
Hesston
Ottawa
Mt. Hope
Ottawa
“Treatment” Date
January 2008
April 2008
May 2008
July 2009
August 2011
November 2011
October 2012
March 2013
September 2013
15
Payment
7,500.00
14,650.00
8,500.00
29,190.00
22,800.00
9,400.00
13,125.00
16,815.00
6,500.00
Case 5:14-cr-40151-DDC Document 1 Filed 12/17/14 Page 16 of 24
52.
According to Camelot’s records, the Kansas residents had the
following cancer diagnoses: ovarian cancer, esophageal cancer, rectal and lymph
cancer, non-Hodgkin's lymphoma, cervical cancer, non-small cell lung cancer,
brain tumor, and breast cancer. One Kansas resident, JEH, never had a confirmed
cancer diagnosis, although Camelot purported to treat her for breast cancer.
Another Kansas resident, JA, had an unknown form of cancer. Camelot’s records
listed only “metastatic” for Kansas resident PLO.
53.
On or about May 28, 2007, CK, a resident of Strong City, Kansas,
sent an e-mail to defendant MAUREEN LONG, asking if Camelot had any type
of payment plan. On or about May 30, 2007, CK followed up with another e-mail,
asking if Camelot was listed with any of the Better Business Bureaus, what
Camelot’s success was with lung cancer, and a financial report and status with the
Better Business Bureau. CK asked these questions because they had been asked of
her in seeking funding for her husband’s treatment with Camelot. In furtherance of
her scheme to defraud, defendant MAUREEN LONG sent a lengthy e-mail
response, which stated in part:
“We have had considerable success with lung cancer, particularly non-small
cell lung cancer. . . .
As for the BBB, I . . . refuse to pay their extortion. . . .
We have a great patient survival rate, and our treatment costs about the same
as a big screen television, or half the cost of a new car, or a thousand dollars
less than the cheapest funeral—plus the patient gets to survive;)”
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54.
On or about October 5, 2008, when Kansas resident, DM, the mother
of a two-year-old with cancer asked for references from other clients who could
attribute over two years of cancer survival to DMSO treatment, defendant
MAUREEN LONG, in furtherance of her scheme to defraud, stated in an e-mail
to DM:
“They are out there, sorry, we stay busy constantly and cannot dig out that
info for you. . . . But the only patients I am aware of losing are ones who
were either too badly damaged from prior radiation and standard toxic
chemo or patients who let their anxiety get the best of them, couldn’t stay
with what was clearly working and skipped around the country from clinic
to clinic . . . .”
55.
On or about December 3, 2009, in furtherance of her scheme to
defraud, defendant MAUREEN LONG sent an e-mail to JH, who lived in Prairie
Village, Kansas. In that e-mail, defendant MAUREEN LONG made the following
statements, among others:
“This is not your average, run of the mill holiday greetings from a medical
office. We have news you and other Camelot patients may have been
praying for. We have an ethical duty to inform any among you who could
benefit from a recent important discovery, which could revolutionize cancer
treatment as we know it.
We are constantly researching any means to boost the effectiveness of our
intravenous formula and have come across a botanically derived biochemical
agent; a very potent medicinal herbal extract which is a known cancer killer.
It has been right under the nose of researchers for decades, but for whatever
reason, has been ignored and overlooked. . . .
We finally found one precious overseas source where we could get it, and
made certain that its purity and potency was standardized (by assay; lab
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analysis) meaning the right strength and guaranteed genuine, not counterfeit.
...
This sterile extract from a potent medicinal herb has now been through
foreign research studies and used with varying degrees of success against a
broad spectrum of cancers. . . . With our almost 15 year history in the use of
our formulas, (using DMSO as the carrier solvent and delivery agent),
Camelot has set the Gold Standard for alternative cancer treatment. We
believe this new formula enhancement brings us ever closer to finding the
‘Holy grail’ in the fight against cancer. . . .
[W]e will put our patient survival rates up against those of orthodox
oncology any day. . . .
We feel that our patients who are in trouble deserve to be treated better than
lab rats. . . .
And so we sent for the precious substance and prayed that customs would
not intercept it, and then we got busy in the lab.
WE CANNOT PUBLICLY ANNOUNCE, AND SURE AS HECK
CANNOT PUBLISH . . . . We do not dare announce until we have more
hard evidence for efficacy, and . . . until we have expanded Camelot’s
operations into a satellite clinic in Cancun, Mexico. . . .
Our new high Octane formula, plus the Camelot Arsensal [sic] Against
Cancer (CAAC) of protective and immune-boosting nutritional supplements
now being offered to our patients, works together to provide you with the
greatest fight team against cancer, now and in the future. . . . We know,
because we focus on REAL cancer research! . . .
We can ship treatment supplies out to you within 24 hours of receipt of your
paid order. . . .
The new formula will be priced in 2010 at between $3500-$4,000 for 5
“quad” bags (a 20 day round). . . .
However, until the first of the year, we are offering rounds of the new
formula for $3,000 to our current and past patients, for as long as existing
supplies hold out . . . .
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IMPORTANT INFO ABOUT PAYMENT: We cannot ship supplies until
payments have cleared. Not only is the mail slow, but then our bank places
a ten day hold on all personal checks which are drawn on out of state bank
accounts.
Camelot has discovered a way to get around this problem.
It is now possible to order treatment supplies by either bank account debit or
charged to a credit card, using Paypal. . . . This way, online payment can be
made to Camelot’s email address, which is linked to the Camelot account,
and we can ship our treatment supplies the next business day. . . .
For some of you, this news could be an early Christmas present; a
breakthrough that could make all the difference.”
56.
On or about March 6, 2010, in furtherance of her scheme to defraud,
defendant MAUREEN LONG sent another e-mail to JH, stating, in part:
“I have not personally seen your PET scan, but Belinda has and she did
remark it was not good. . . . We probably bought you some time, but I was
hoping for so much more than that. . . .[W]e have been in private
consultation with a brilliant scientist in Florida. . . Our top R&D person
(Noel) knows him personally and tracked him down to rekindle the
friendship and explore the possibility of sharing his formula. . . . [H]is
formula is very potent and effective, even against advanced stage cancers, all
except for the leukemias. . . . [T]hey will ship us some of their premixed
formula and we will make it available to every patient in need. You will be
the first. . . . [Y]our PET scan was not good – but at least we can give you
hope.”
57.
On or about July 21, 2011, in furtherance of the scheme to defraud,
defendant MAUREEN LONG’s husband sent an e-mail to KH, a resident of
Spring Hill, Kansas, in which he made the following representations:
“[T]he DMSO treatment . . . is very comfortable with no side effects or
discomfort of any kind. It goes into the bone marrow and even crosses the
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blood/brain barrier and destroys brain tumors. . . . Camelot has considerably
more (overall) than a 60% 5 year survival rate. . . .
The treatment at Camelot has been successful in achieving remission (I
hesitate to say cure) for many, if not most of [the cancer patients]. . . . It is
important . . . not to wait, to get the treatment as soon as possible, waiting
and trying ineffective treatments could cost you your life.”
58.
On or about November 7, 2012, in response to Kansas resident JEH’s
complaints of being very sick and vomiting from Camelot’s treatments, defendant
MAUREEN LONG, in furtherance of her scheme to defraud, sent an e-mail to a
family member, making the following statements, in part:
“Find some excuse without causing suspicion to have them discard their
remaining supply that was sent home with her, and mix up fresh replacement
to send out to them. Tell them its [sic] okay for her to be without for up to
three days without losing momentum. This is awkward to say the least, and
we are just going to have to eat the loss. The loss is depending by the hour.
God, it sickens me to think about how much loss this is adding up to. . . . I
suggest you tell them the concentration is too strong for her, to ship it back
(safer for us) or to discard it, and we will ship out replacement bags. This is
so upsetting. Six patients impacted, and what if any complain to Lynn. We
are so screwed. Fix this.”
59.
On or about November 30, 2012, one of defendant MAUREEN
LONG’s family members, in furtherance of the scheme to defraud, wrote to JH
about his mother, JEH, suggesting that she not get a PET scan:
“[I]t is highly recommended that [JEH] go into a 2nd round before doing a
pet. . . . The average patient in her shoes needs a 2nd round as the cancer
needs more DMSO to kill the amount she has. We can ship her a 2nd round
with instructions on how to administer. We want that pet to show no cancer
and we don’t believe we are there yet. A 2nd round is essential on
increasing the changes of wiping out all her cancer.”
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Case 5:14-cr-40151-DDC Document 1 Filed 12/17/14 Page 21 of 24
60.
On or about June 6, 2013, in furtherance of her scheme to defraud,
defendant MAUREEN LONG sent an e-mail to MH and SH in Mt. Hope, Kansas,
that stated, in part:
“We were as disappointed as you were that your PET scan wasn’t showing
improvement yet. But what is there to say, when you know its [sic] going to
take more treatment for there to be any progress against the malignancy, but
the patient can’t afford it and you cannot give it away for free and still meet
payroll and cover bills for supplies? Its [sic] a sad, awkward situation.
Its [sic] not that we don’t want to help you. But we are in enough trouble
already without risking being charged with practicing medicine without a
license, which is a felony.
COUNT 1- 13 -- WIRE FRAUD
61.
The Grand Jury incorporates by reference Paragraphs 1 through 60, as
though fully restated and realleged herein.
62.
From in or about 2007, and continuing through the present, the exact
dates being unknown to the Grand Jury, in the District of Kansas and elsewhere,
defendant
MAUREEN LONG,
doing business as Camelot Cancer Care, Inc., for the purpose of executing the
scheme to defraud the FDA and individuals seeking a cure for cancer, and
attempting to do so, transmitted and caused to be transmitted by means of wire
communication in interstate commerce, namely, from Oklahoma and Florida to
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Case 5:14-cr-40151-DDC Document 1 Filed 12/17/14 Page 22 of 24
Kansas, and from Kansas to Oklahoma, the following writings, signs, signals,
pictures, and sounds:
Count On or about Date
1
March 6, 2010
July 21, 2011
2
3
4
5
6
7
8
9
10
11
12
13
To
JH
KH
November 7, 2012, 12:09 p.m.
November 7, 2012, 1:32 p.m.
November 7, 2012, 4:10 p.m.
November 7, 2012, 5:02 p.m.
March 18, 2013
March 24, 2013
March 27, 2013
April 29, 2013
June 5, 2013
July 6, 2013, 8:26 a.m.
July 6, 2013, 4:59 p.m.
63.
Samantha
JH
JH
JH (by cc)
MH & SH
MH & SH
Maureen Long
Maureen Long
John
MH & SH
MH & SH
From
Maureen Long
Maureen Long’s
husband
JH
Maureen Long
John L.
Maureen Long
Maureen Long
Maureen Long
MH & SH
MH & SH
MH & SH
Maureen Long
Maureen Long
Transmission
e-mail
e-mail
e-mail
e-mail
e-mail
e-mail
e-mail
e-mail
e-mail
e-mail
e-mail
e-mail
e-mail
The foregoing is in violation of Title 18, United States Code, Sections
2 and 1343.
FORFEITURE ALLEGATIONS
64.
Paragraphs 1 through 63 and the allegations of Counts 1through 13
are hereby realleged and incorporated herein by reference for the purposes of
alleging forfeitures pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461.
65.
Upon conviction of one or more of the wire fraud offenses alleged in
Counts 1 through 13 of this Indictment, defendant MAUREEN LONG shall
forfeit to the United States, pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. §
2461, any property, real or personal, that constitutes or is derived, directly or
indirectly, from gross proceeds traceable to the commission of the offenses. The
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Case 5:14-cr-40151-DDC Document 1 Filed 12/17/14 Page 23 of 24
property to be forfeited includes, but is not limited to, a sum of money equal to the
amount of proceeds obtained as a result of the wire fraud offenses set out in Counts
1 through 13.
66.
If any of the above-described forfeitable property, as a result of any
act or omission of the defendant:
(a)
cannot be located upon the exercise of due diligence;
(b)
has been transferred or sold to, or deposited with, a third party;
(c)
has been placed beyond the jurisdiction of the court;
(d)
has been substantially diminished in value; or
(e)
has been commingled with other property which cannot be divided
without difficulty;
it is the intent of the United States, pursuant to 21 U.S.C. § 853(p), to seek
forfeiture of any other property of said defendant up to the value of the forfeitable
property described above.
A TRUE BILL.
Dated: December 17, 2014
s/ Foreperson
FOREPERSON
Tanya J. Treadway #13255
Barry R. Grissom
United States Attorney
District of Kansas
500 State Avenue, Suite 360
Kansas City, KS 66101
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Case 5:14-cr-40151-DDC Document 1 Filed 12/17/14 Page 24 of 24
913-551-6730
913-551-6541 (fax)
[email protected]
Ks. S. Ct. # 10866
(It is requested that trial of the above captioned case be held in Topeka, Kansas.)
24