K & M La Botica Pharmacy, Incorporated, et al. - Page 10

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          the medical boards.  Ahmed and Elkholy both had lived in the same           
          neighborhood, and both had worked in the same New York City                 
          hospital.                                                                   
               By 1993, Elkholy had obtained a medical degree and a                   
          California medical license.  Ahmed’s wife had obtained a medical            
          degree but apparently was not licensed to practice medicine in              
          California.                                                                 
               To increase prescriptions filled by Ahmed’s pharmacies,                
          Ahmed established a procedure for the medical clinic under which            
          drug prescriptions would not be given directly to patients of the           
          clinic; rather, clinic employees would deliver or would fax drug            
          prescriptions for clinic patients directly to Ahmed’s pharmacies.           
          Ahmed threatened to terminate clinic employees who did not follow           
          this procedure.                                                             
               Also, Ahmed established a policy for his medical clinic that           
          each patient was to receive either an x ray, a lab test, or a               
          shot, and each patient was to be provided a prescription.  These            
          services and prescriptions were provided to each patient of                 
          Ahmed’s clinic regardless of the medical necessity and were                 
          intended to increase revenue for Ahmed’s pharmacies and clinic.             
               On June 13, 1996, Ahmed caused his accountant, one Ahmad               
          Saghir (Saghir), to prepare and to file articles of incorporation           
          for Clinica Santa Maria, Inc. (CSM).  Without Elkholy’s                     
          permission or knowledge, Elkholy was identified as the sole                 






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