K & M La Botica Pharmacy, Incorporated, et al. - Page 14

                                       - 14 -                                         
               On December 19, 1997, at Ahmed’s request and on Ahmed’s                
          behalf, Saghir prepared and filed articles of incorporation for a           
          corporation to be named Madina, Inc. (Madina), to which the                 
          pharmacies nominally were to be transferred.  Darwish was                   
          identified as the sole shareholder of Madina.  Ahmed then caused            
          Saghir to prepare a series of documents reflecting, among other             
          things, a purported transfer of ownership of the pharmacies from            
          Ahmed to Darwish for a total stated purchase price of $170,000,             
          to be reflected by a purported $20,000 cash downpayment from                
          Darwish to Ahmed and by a purported $150,000 promissory note from           
          Darwish to Ahmed.                                                           
               Notwithstanding the contents of the above documents and the            
          purported sale of the pharmacies, Ahmed was the sole owner of the           
          stock of Madina, and Ahmed retained actual control of the                   
          pharmacies.                                                                 
               Sometime in 1997, Ahmed used funds from K & M to open a                
          medical laboratory using the name Apex Medical Lab.  The lab was            
          located near Ahmed’s pharmacies and clinics and derived most of             
          its business from customers and patients of Ahmed’s pharmacies              
          and clinics.                                                                
               To avoid scrutiny by California State health care officials,           
          who were already investigating the other businesses Ahmed                   
          controlled, Ahmed arranged for nominal ownership of the lab to be           
          put into Darwish’s name.                                                    






Page:  Previous  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  Next

Last modified: May 25, 2011