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Government Action:
The following describes a pending government action that has been formally brought by a government agency but has not yet been resolved. We are providing a summary of the government's allegations, which have not yet been proven.
As of February 20, 2020, Case -50-2020-CF-001618-AXXX-MB;
The State of Florida (State), 15th Judicial Circuit - Palm Beach County:
The State charged ROBERT JEAN SIMEONE in a 6 count indictment, to wit:
1) ORGANIZED SCHEME TO DEFRAUD' ($50,000 OR MORE)
2) MONEY LAUNDERING
3) MONEY LAUNDERING
4) GRAND THEFT
5) GRAND THEFT
6) GRAND THEFT
COUNT 1: ROBERT JEAN SIMEONE From on or about March 16, 2015 and continuing through on or about October 29, 2018, in the County of Palm Beach and State of Florida, did engage in a scheme to defraud constituting a systematic, ongoing course of conduct with intent to defraud one or more persons, or with intent to obtain property from one or more persons by false or fraudulent pretenses, representations, or promises or willful misrepresentations of a future act and did obtain property 'from one or more of such persons in an aggregate value of $50,000 or more, Florida Statute 817.034(4)(a)1. (1 DEG FEL)
COUNT 2: ROBERT JEAN SIMEONE From on or about February 2, 2016 and continuing through on or about November 6, 2017, in the County of Palm Beach and State of Florida, did with financial transactions exceeding $300 but less than $20,000 in any 12- month period, and knowing that the property involved in a financial transaction represents the proceeds of some form of unlawful activity, to wit: THEFT conducted or attempt to conduct such a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the
carrying on of specified unlawful activity; or knowing that the transaction is designed in whole or in part to conceal or disguise the nature, the location, the source, the ownership, or the control of the proceeds of specified unlawful activity, contrary to Florida Statute 896.101(3) and (5)(a). (3 DEG FEL)
COUNT 3: ROBERT JEAN SIMEONE From on or about November 6, 2017 and continuing through on or about November 6, 2018, in the County of Palm Beach and State of Florida, did with financial transactions exceeding $300 but less than $20,000 in any 12- month period, and knowing that the property involved in a financial transaction represents the proceeds of somet form of unlawful activity, to wit: THEFT conducted or attempt to conduct such a financial trahsaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity; or knowing that the transaction is designed in whole or in part to conceal or disguise the nature, the location, the source, the ownership, or the control of the proceeds of specified unlawful activity, contrary to Florida Statute 896.101(3) and (5)(a). (3
DEG FEL)
COUNT 4: ROBERT JEAN SIMEONE on or about September 2018, in the County of Palm Beach and State of Florida, did knowingly obtain or use, or endeavor to obtain or use US CURRENCY of a value of $10,000 or more but less than $20,000, which was the property of CONNELLY FAMILY FOUNDATION and/or CORRY CONNELLY, or any other person not the defendant(s), with the intent to permanently or temporarily' deprive the CONNELLY FAMILY FOUNDATION and/or CORRY CONNELLY or any other person not the defendant(s) of the property or benefit therefrom or to approprite the property to the use of ROBERT JEAN SIMEONE or to the use of any person not entitled thereto, contrary to Florida Statute 812.014(1)
and (2)(c). (3 DEG FEL)
COUNT 5: ROBERT JEAN SIMEONE on or about July 2, 2015, in the County of Palm Beach and State of Florida, did knowingly obtain or use, or endeavor to obtain or use US CURRENCY of a value of $300.00 or more, whichwas the property of TREASURE COAST NAM KNIGHTS MOTORCYCLE CLUB, or any other person not the defendant(s), with the intent to permanently or temporarily deprive the TREASURE COAST NAM KNIGHTS MOTORCYCLE CLUB or any other person not the defendant(s) of the property or benefit therefrom or to appropriate the property to the use of ROBERT JEAN SIMEONE or to the use of any person not entitled thereto, contrary to Florida Statute 812.014(1) and (2)(c). (3 DEG FEL)
COUNT 6: ROBERT JEAN SIMEONE From on or about March 27, 2015 and continuing through on or about December 17, 2018, in the County of Palm Beach and State of Florida, did knowingly obtain or use, or endeavor to obtain or use US CURRENCY of a value of $10,000 or more but less than $20,000, which was the property of EUGENE MERKERT 1996 CHARITABLE FOUNDATION and/or TUYET MERKERT and/or TUYET THI PAYNE MERKERT TRUST and/or TUYET MERKERT, or any other person not the defendant(s), with the intent to permanently or temporarily deprive the EUGENE MERKERT 1996 CHARITABLE FOUNDATION and/or TUYET MERKERT and/or TUYET THI PAYNE MERKERT TRUST and/or TUYET MERKERT or any other person not the defendant(s) of the property or benefit therefrom or to appropriate the property to the use of ROBERT JEAN SIMEONE or to the use of any person not entitled thereto, contrary to Florida Statute 812.014(1) and (2)(c). (3 DEG FEL
Related court documents and information may be found on the website of the Palm Beach Clerk of Court at https://applications.mypalmbeachclerk.com/eCaseView/search.aspx
For further information please contact:
Office of the State Attorney
401 N Dixie Hwy, West Palm Beach, FL 33401
West Palm Beach, FL 33401
(561) 355-7100
http://www.sa15.state.fl.us/stateattorney
As of February 20, 2020, Case -50-2020-CF-001618-AXXX-MB;
The State of Florida (State), 15th Judicial Circuit - Palm Beach County:
The State charged ROBERT JEAN SIMEONE in a 6 count indictment, to wit:
1) ORGANIZED SCHEME TO DEFRAUD' ($50,000 OR MORE)
2) MONEY LAUNDERING
3) MONEY LAUNDERING
4) GRAND THEFT
5) GRAND THEFT
6) GRAND THEFT
COUNT 1: ROBERT JEAN SIMEONE From on or about March 16, 2015 and continuing through on or about October 29, 2018, in the County of Palm Beach and State of Florida, did engage in a scheme to defraud constituting a systematic, ongoing course of conduct with intent to defraud one or more persons, or with intent to obtain property from one or more persons by false or fraudulent pretenses, representations, or promises or willful misrepresentations of a future act and did obtain property 'from one or more of such persons in an aggregate value of $50,000 or more, Florida Statute 817.034(4)(a)1. (1 DEG FEL)
COUNT 2: ROBERT JEAN SIMEONE From on or about February 2, 2016 and continuing through on or about November 6, 2017, in the County of Palm Beach and State of Florida, did with financial transactions exceeding $300 but less than $20,000 in any 12- month period, and knowing that the property involved in a financial transaction represents the proceeds of some form of unlawful activity, to wit: THEFT conducted or attempt to conduct such a financial transaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the
carrying on of specified unlawful activity; or knowing that the transaction is designed in whole or in part to conceal or disguise the nature, the location, the source, the ownership, or the control of the proceeds of specified unlawful activity, contrary to Florida Statute 896.101(3) and (5)(a). (3 DEG FEL)
COUNT 3: ROBERT JEAN SIMEONE From on or about November 6, 2017 and continuing through on or about November 6, 2018, in the County of Palm Beach and State of Florida, did with financial transactions exceeding $300 but less than $20,000 in any 12- month period, and knowing that the property involved in a financial transaction represents the proceeds of somet form of unlawful activity, to wit: THEFT conducted or attempt to conduct such a financial trahsaction which in fact involves the proceeds of specified unlawful activity with the intent to promote the carrying on of specified unlawful activity; or knowing that the transaction is designed in whole or in part to conceal or disguise the nature, the location, the source, the ownership, or the control of the proceeds of specified unlawful activity, contrary to Florida Statute 896.101(3) and (5)(a). (3
DEG FEL)
COUNT 4: ROBERT JEAN SIMEONE on or about September 2018, in the County of Palm Beach and State of Florida, did knowingly obtain or use, or endeavor to obtain or use US CURRENCY of a value of $10,000 or more but less than $20,000, which was the property of CONNELLY FAMILY FOUNDATION and/or CORRY CONNELLY, or any other person not the defendant(s), with the intent to permanently or temporarily' deprive the CONNELLY FAMILY FOUNDATION and/or CORRY CONNELLY or any other person not the defendant(s) of the property or benefit therefrom or to approprite the property to the use of ROBERT JEAN SIMEONE or to the use of any person not entitled thereto, contrary to Florida Statute 812.014(1)
and (2)(c). (3 DEG FEL)
COUNT 5: ROBERT JEAN SIMEONE on or about July 2, 2015, in the County of Palm Beach and State of Florida, did knowingly obtain or use, or endeavor to obtain or use US CURRENCY of a value of $300.00 or more, whichwas the property of TREASURE COAST NAM KNIGHTS MOTORCYCLE CLUB, or any other person not the defendant(s), with the intent to permanently or temporarily deprive the TREASURE COAST NAM KNIGHTS MOTORCYCLE CLUB or any other person not the defendant(s) of the property or benefit therefrom or to appropriate the property to the use of ROBERT JEAN SIMEONE or to the use of any person not entitled thereto, contrary to Florida Statute 812.014(1) and (2)(c). (3 DEG FEL)
COUNT 6: ROBERT JEAN SIMEONE From on or about March 27, 2015 and continuing through on or about December 17, 2018, in the County of Palm Beach and State of Florida, did knowingly obtain or use, or endeavor to obtain or use US CURRENCY of a value of $10,000 or more but less than $20,000, which was the property of EUGENE MERKERT 1996 CHARITABLE FOUNDATION and/or TUYET MERKERT and/or TUYET THI PAYNE MERKERT TRUST and/or TUYET MERKERT, or any other person not the defendant(s), with the intent to permanently or temporarily deprive the EUGENE MERKERT 1996 CHARITABLE FOUNDATION and/or TUYET MERKERT and/or TUYET THI PAYNE MERKERT TRUST and/or TUYET MERKERT or any other person not the defendant(s) of the property or benefit therefrom or to appropriate the property to the use of ROBERT JEAN SIMEONE or to the use of any person not entitled thereto, contrary to Florida Statute 812.014(1) and (2)(c). (3 DEG FEL
Related court documents and information may be found on the website of the Palm Beach Clerk of Court at https://applications.mypalmbeachclerk.com/eCaseView/search.aspx
For further information please contact:
Office of the State Attorney
401 N Dixie Hwy, West Palm Beach, FL 33401
West Palm Beach, FL 33401
(561) 355-7100
http://www.sa15.state.fl.us/stateattorney
Government Action:
The following describes a pending government action that has been formally brought by a government agency but has not yet been resolved. We are providing a summary of the government's allegations, which have not yet been proven.
As of November 28, 2019, 50-2018-CF-010771-CXXX-MB;
The State of Florida (State), 15th Judicial Circuit - Palm Beach County:
The State charged ROBERT JEAN SIMEONE in a 25 count indictment, to wit:
Counts 29-52 PATIENT BROKERING
Count 53 CONSPIRACT TO COMMIT PATIENT BROKERING
COUNT 29: ROBERT JEAN SIMEONE on or about May 31, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 30: ROBERT JEAN SIMEONE on or about June 16, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patrod4e,to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4): (3 DEG FEL)
COUNT 31: ROBERT JEAN SIMEONE on or about July 1, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE. THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 32: ROBERT JEAN SIMEONE on or about July 15, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817,505(1)(a) and (4). (3 DEG FEL)
COUNT 33: ROBERT JEAN SIMEONE on or about July 29, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 34: ROBERT JEAN SIMEONE on or about August 4, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 35: ROBERT JEAN SIMEONE on or about August 12, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickbaCk, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 36: ROBERT JEAN SIMEONE on or about August 19, 2016,,in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a)atkr(4). (3 DEG FEL)
COUNT 37: ROBERT JEAN SIMEONE on or about August 26, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 38: ROBERT JEAN SIMEONE on or about September 9, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the, referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4), (3 DEG FEL)
COUNT 39: ROBERT JEAN SIMEONE on or about September 20, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER' LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 40: ROBERT JEAN SIMEONE on or about September 23, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 41: ROBERT JEAN SIMEONE on or about October 3, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or
bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT
CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL) ,
COUNT 42: ROBERT JEAN SIMEONE on or about October 7, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 43: ROBERT JEAN SIMEONE on or about October 21, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients/or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a)'and (4). (3 DEG FEL)
COUNT 44: ROBERT JEAN SIMEONE on or about October 27, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS', INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida gtatute 817,505(1)(a) and (4). (3 DEG FEL)
COUNT 45: ROBERT JEAN SIMEONE on or about November 4, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 46: ROBERT JEAN SIMEONE on or about November 18, 2018, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 47: ROBERT JEAN SIMEONE on or about November 21, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
Case No. 2018CF010771AMB
CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 48: ROBERT JEAN SIMEONE on or about December 1, 2016, in the County Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE,., CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback", or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 49: ROBERT JEAN SIMEONE on or about December 15, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 50: ROBERT JEAN SIMEONE on or about December 20, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC 'a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute'817.505(1)(a) and (4). (3 DEG FEL)
COUNT 51: ROBERT JEAN SIMEONE on or about December 29, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 52: ROBERT JEAN SIMEONE on or about December 30, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 53: ROBERT JEAN SIMEONE between April 1, 2016 and December 30, 2016, in the County of Palm Beach and State of Florida, did unlawfully agree, conspire, combine or confederate with another person or persons including but not limited to JENNIFER SWANSON to commit PATIENT BROKERING, a felony, and did unlawfully offer or pay PURE
THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC, a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC contrary to Florida Statute 817.505(1)(a) and (4) and 777.04(3). (3 DEG FEL)
Related court documents and information may be found on the website of the Palm Beach Clerk of Court at https://applications.mypalmbeachclerk.com/eCaseView/search.aspx
For further information please contact:
Office of the State Attorney
401 N Dixie Hwy, West Palm Beach, FL 33401
West Palm Beach, FL 33401
(561) 355-7100
http://www.sa15.state.fl.us/stateattorney
As of November 28, 2019, 50-2018-CF-010771-CXXX-MB;
The State of Florida (State), 15th Judicial Circuit - Palm Beach County:
The State charged ROBERT JEAN SIMEONE in a 25 count indictment, to wit:
Counts 29-52 PATIENT BROKERING
Count 53 CONSPIRACT TO COMMIT PATIENT BROKERING
COUNT 29: ROBERT JEAN SIMEONE on or about May 31, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 30: ROBERT JEAN SIMEONE on or about June 16, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patrod4e,to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4): (3 DEG FEL)
COUNT 31: ROBERT JEAN SIMEONE on or about July 1, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE. THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 32: ROBERT JEAN SIMEONE on or about July 15, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817,505(1)(a) and (4). (3 DEG FEL)
COUNT 33: ROBERT JEAN SIMEONE on or about July 29, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 34: ROBERT JEAN SIMEONE on or about August 4, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 35: ROBERT JEAN SIMEONE on or about August 12, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickbaCk, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 36: ROBERT JEAN SIMEONE on or about August 19, 2016,,in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a)atkr(4). (3 DEG FEL)
COUNT 37: ROBERT JEAN SIMEONE on or about August 26, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 38: ROBERT JEAN SIMEONE on or about September 9, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the, referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4), (3 DEG FEL)
COUNT 39: ROBERT JEAN SIMEONE on or about September 20, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER' LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 40: ROBERT JEAN SIMEONE on or about September 23, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 41: ROBERT JEAN SIMEONE on or about October 3, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or
bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT
CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL) ,
COUNT 42: ROBERT JEAN SIMEONE on or about October 7, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 43: ROBERT JEAN SIMEONE on or about October 21, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients/or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a)'and (4). (3 DEG FEL)
COUNT 44: ROBERT JEAN SIMEONE on or about October 27, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS', INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida gtatute 817,505(1)(a) and (4). (3 DEG FEL)
COUNT 45: ROBERT JEAN SIMEONE on or about November 4, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 46: ROBERT JEAN SIMEONE on or about November 18, 2018, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 47: ROBERT JEAN SIMEONE on or about November 21, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
Case No. 2018CF010771AMB
CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 48: ROBERT JEAN SIMEONE on or about December 1, 2016, in the County Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE,., CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback", or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 49: ROBERT JEAN SIMEONE on or about December 15, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 50: ROBERT JEAN SIMEONE on or about December 20, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC 'a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute'817.505(1)(a) and (4). (3 DEG FEL)
COUNT 51: ROBERT JEAN SIMEONE on or about December 29, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 52: ROBERT JEAN SIMEONE on or about December 30, 2016, in the County of Palm Beach and State of Florida, did unlawfully offer or pay PURE THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC, contrary to Florida Statute 817.505(1)(a) and (4). (3 DEG FEL)
COUNT 53: ROBERT JEAN SIMEONE between April 1, 2016 and December 30, 2016, in the County of Palm Beach and State of Florida, did unlawfully agree, conspire, combine or confederate with another person or persons including but not limited to JENNIFER SWANSON to commit PATIENT BROKERING, a felony, and did unlawfully offer or pay PURE
THOUGHTS AT TURTLE CREEK, INC AND/OR PURE THOUGHTS, INC, a commission, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of patients or patronage to EPIPHANY'S TREATMENT CENTER LLC contrary to Florida Statute 817.505(1)(a) and (4) and 777.04(3). (3 DEG FEL)
Related court documents and information may be found on the website of the Palm Beach Clerk of Court at https://applications.mypalmbeachclerk.com/eCaseView/search.aspx
For further information please contact:
Office of the State Attorney
401 N Dixie Hwy, West Palm Beach, FL 33401
West Palm Beach, FL 33401
(561) 355-7100
http://www.sa15.state.fl.us/stateattorney
At-a-glance
Related Categories
Business Details
- Location of This Business
- 5674 Sandbirch Way, Lake Worth, FL 33463-7204
- BBB File Opened:
- 2/26/2020
- Business Incorporated:
- 1/31/2011 in FL, USA
- Type of Entity:
- Corporation
- Contact Information
Principal
- Mr. Bobby Simeone, President
Other Contacts
- Ms. Vivian Simeone, Vice President
- Mr. James Suarez, Treasurer
- Additional Contact Information
Website Addresses
Industry Tip
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Customer Complaints
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