K & M La Botica Pharmacy, Incorporated, et al. - Page 27

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          K & M for 1995, but Ahmed failed to produce much of the                     
          information requested in the IDRs.                                          
               Due to Ahmed’s failure to fully comply with the IDRs,                  
          respondent’s agent served approximately 70 administrative                   
          summonses on K & M’s suppliers, banks, and customers.                       
               At the first meeting between respondent’s agent and Ahmed,             
          Ahmed falsely informed respondent’s agent that the pharmacies did           
          not have cash sales and that all of the sales proceeds of K & M             
          were deposited into K & M bank accounts.  When respondent’s agent           
          confronted Ahmed with evidence of cash sales, Ahmed changed his             
          story and admitted that the pharmacies had cash sales.                      
               Ahmed told respondent’s agent that he had made personal                
          loans to K & M, but when respondent’s agent asked Ahmed for                 
          documentation relating to the loans Ahmed told the agent that               
          loan documentation did not exist.  Later, in December of 1997,              
          Ahmed produced purported loan documentation relating to the                 
          alleged loans.                                                              
               Ahmed denied having an ownership interest in CSM, CK, and              
          CL, and in the medical clinics operated under those names.  Ahmed           
          told respondent’s agent that during the years at issue CSM, CK,             
          CL, and the clinics were owned by Elkholy or later by Leslie.               
          Ahmed represented that he acted only as a manager of the clinics            
          on behalf of Elkholy and Leslie.                                            







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