UNDER SEAL 01 12) __CRIMINAL COMPLAINT UNITED STATES DISTRICT COURT oCKET NO, UNITED STATES OF AMERICA DZUNG AHN PHAM CENTRAL DISTRICT OF CALIFORNIA | Complaint for violation of Title 21 U.S.C. 841(@)(1), (B,C) NAMEEOF MAGISTRATE JUDGE INITED STATES Paar HONORABLE AUTUMN D. SPAETH MAGISTRAAEGopae_{ Santa Ann, California DATEOF OFFENSE mal OFFENSE ADDIS OF ACCUSED UF KNOW August 4 and 27, 2018 Orange County ‘COMPLAINANT'S STATEMET OF FACTS CONSTITUTING THE OFFENSZOR VIOLATION On or about the following dates, in Orange County, within the Central District of California, and elsewhere, defendant DZUNG AHN PHAM, then a physician licensed to practice medicine in the ‘State of California, while acting and intending to act outside the usual course of professional practice and without a legitimate medical Purpose, knowingly and intentionally prescribed and distributed oxycodone, a Schedule II narcotie drug controlled substance, in the name and date of birth of RC: COUNT DATE, ONE_ August 4, 2018 Gus August 27, 2018 in violajign OF-Fitle 2}, United States Code, Section 84 1(a)(1), (bM INC). si gi as hana sonnei aco Ge atiatlied affidavit which is (Se att LODGED incorporated as part of this Complaint) average RBG TION TO scHaRGrs N/A, SIGNATURE OF COMPLAINANT Being duly sworn, I declare that the foregoing is true and correct to the best ofmy knowledge | LINDSEY M. BELLOMY fs] orica-rmus _ Special Agent, Drug Enforcement Administration ‘Swom to before me and subseribed in my presence, 'JONATURE OF nGistRATE UDOR bat | AUTUMN D. SPAETH ' ‘W'Sse Fede Roles of Criminal Procedure Vand i az 2 & AUSA BSagellb REC: DetentionAFFIDAVIT I, Lindsey Bellomy, being duly sworn, declare and state as follows: I. INrRopucTIoN 1. I ama Special Agent ("SA") with the United States Department of Justice, Drug Enforcement Administration (“DEA”) and have been so employed since December 2010. 1 am currently assigned to the Los Angeles Field Division, Orange County Resident Office (“OCRO”). At OCRO, I am assigned to the Tactical Diversion Squad. During my tenure with DEA, I have received comprehensive, formalized instruction on such topics as drug identification, money laundering techniques, patterns of drug trafficking, complex conspiracies, the exploitation of narcotics traffickers’ telecommunications devices, criminal law, surveillance, and other investigative techniques. I have participated in numerous investigations into the unlawful importation, manufacture, and distribution of controlled Substances, the laundering of narcotics proceeds, and conspiracies associated with narcotics offenses. tn conducting these investigations, 1 have utilized a variety of investigative techniques and resources, including surveillance, confidential source debriefings, telephone toll analysis, and wire communications analysis.2. Through my investigations, my training and experience, and my conversations with other law enforcement personnel, 1 have become familiar with the tactics and methods used by traffickers to smuggle and safeguard pharmaceutical controlled Substances, to distribute and divert pharmaceutical controlled substances, and to collect and launder the proceeds from the sale of controlled substances. Further, I am aware of the tactics and methods employed by pharmaceutical trafficking organizations and individuals to thwart investigation of their illegal activities. 3. Through my investigations, my training and experience, and my conversations with other law enforcement personnel, I and other law enforcement personnel have spoken on numerous occasions with pharmacists, physicians, DIs, Medical Board investigators, patients, and other witnesses having extensive knowledge of pharmaceuticals regarding the methods and practices of individuals trafficking in or diverting pharmaceutical controlled substances. 4. The facts set forth in this affidavit are based upon my personal observations, my training and experience, and information obtained from other agents and witnesses. This affidavit is intended to show merely that there is sufficient Probable cause for the requested warrants and does not purport fe set forth all of my knowledge of or investigation into this