Case 2:21-cv-10046 Document 1 Filed 12/31/21 Page 1 of 11 Page ID #:1
`
`
`PRENOVOST, NORMANDIN, DAWE & ROCHA
`A Professional Corporation
`KAREL ROCHA, SBN 212413
`krocha@pnbd.com
`JASON MEYER, SBN 299032
`jmeyer@pnbd.com
`2122 North Broadway, Suite 200
`Santa Ana, California 92706-2614
`Phone No.:
`(714) 547-2444
`Fax No.:
`(714) 835-2889
`
`Attorneys for NATIONAL UNION FIRE
`INSURANCE COMPANY OF
`PITTSBURGH, PA.
`
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
`
` Case No.
`
`COMPLAINT FOR MONETARY
`DAMAGES
`
`Plaintiff,
`
`NATIONAL UNION FIRE
`INSURANCE COMPANY OF
`PITTSBURGH, PA., as assignee and
`subrogee of Universal Health Services,
`Inc. and Palmdale Regional Medical
`Center,
`
`
`v.
`
`SCOTT FINSTEIN, an individual;
`RICHARD YANIK, individually and
`dba RM POWER and/or MEKR
`ADVANCE SERVICES; THOMAS
`MATHIS, individually and dba PBS
`FIRE PROTECTION SERVICES
`and/or PATRIOT BUILDING
`SERVICES; and DOES 1-20,
`
`Defendants.
`
`
`
`
`Plaintiff, National Union Fire Insurance Company of Pittsburgh, Pa., by and
`through its undersigned counsel, files this Complaint against Defendants, Scott
`Finstein (“Finstein”) an individual, Richard Yanik, individually and dba RM Power
`and/or MEKR Advance Services (“Yanik”), Thomas Mathis, individually and dba
`PBS Fire Protection Services and/or Patriot Building Services (“Mathis”), and DOES
`1-20, and in support thereof avers the following:
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`9477.0019 / 02351984.1
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`
`
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`COMPLAINT FOR MONETARY DAMAGES
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`Case 2:21-cv-10046 Document 1 Filed 12/31/21 Page 2 of 11 Page ID #:2
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`
`THE PARTIES
`1.
`Plaintiff, National Union Fire Insurance Company of Pittsburgh, Pa.
`(“National Union”) is a Pennsylvania insurance corporation formed and existing in
`accordance with the laws of the Commonwealth of Pennsylvania, with a principal
`place of business located at 1271 Ave of the Americas, Floor 37, New York, NY
`10020-1304.
`2.
`Defendant, Scott Finstein, is an individual who resides at 19601 Rose
`Ave., Tehachapi, CA 93561.
`3.
`Defendant, Richard Yanik is an individual who resides at 39434 Basalt
`Ct., Palmdale, CA 93551.
`4. Mr. Yanik does business or has done business as RM Power and MEKR
`Advance Services.
`5.
`Defendant, Thomas Mathis is an individual who resides at 8675 Brook
`Glen Ln., Huntersville, NC 28078.
`6. Mr. Mathis does business or has done business as PBS Fire Protection
`and Patriot Building Services.
`7.
`Defendants, DOES 1-20 are individual persons and/or corporations,
`limited liability companies and/or other business entities of form currently unknown
`to Plaintiff despite reasonable investigation.
`JURISDICTION AND VENUE
`8.
`This Court has subject matter jurisdiction over the claims in this
`Complaint pursuant to 28 U.S.C. § 1332, because National Union does not share state
`citizenship with any of the identifiable Defendants and the amount in controversy,
`exclusive of interest and costs, exceeds $75,000.
`9.
`This court has personal jurisdiction over Finstein and Yanik, because
`they reside in the state of California.
`10. This court has personal jurisdiction over Mathis because his actions,
`which give rise to National Union’s claims, occurred in the state of California.
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`9477.0019 / 02351984.1
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`2
`COMPLAINT FOR MONETARY DAMAGES
`
`TEL (714) 547-2444 • FAX (714) 835-2889
`
`SANTA ANA, CALIFORNIA 92706-2614
`2122 NORTH BROADWAY, SUITE 200
`
`A Professional Corporation
`
`PRENOVOST, NORMANDIN, DAWE & ROCHA
`
`

`

`Case 2:21-cv-10046 Document 1 Filed 12/31/21 Page 3 of 11 Page ID #:3
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`11. Venue is proper in this District pursuant 28 U.S.C. §§1391(b)(1) because
`Yanik resides in this District, and a substantial part of the events giving rise to this
`action occurred in this District.
`FACTUAL ALLEGATIONS
`12. Upon information and belief, Plaintiff alleges as follows:
`13. Palmdale Regional Medical Center (“Palmdale”) is an acute care facility
`located in Palmdale, California. Palmdale is a wholly owned subsidiary of Universal
`Health Services, Inc. (“Universal Health”).
`14. During the period of 2008 to 2019, Finstein was employed as the
`Director of Plant Operations at Palmdale.
`15.
`In his position as Director of Plant Operations, Finstein was responsible
`for coordinating and overseeing the construction and maintenance work performed at
`Palmdale, including work performed by outside vendors.
`16. Finstein also was responsible for reviewing invoices submitted by
`vendors and issuing authorizations for Palmdale to pay such invoices.
`17. From 2008 to 2019, Finstein engaged in a scheme with the other
`Defendants whereby he approved invoices that resulted in payments to the other
`Defendants despite knowing that such individuals and/or their business entities did
`not perform the services or provide the products to Palmdale listed on the invoices.
`A. RM Power’s Fraudulent Invoices.
`18. On behalf of Palmdale, Finstein retained a vendor identified as “RM
`Power” to perform services for Palmdale.
`19. RM Power is and was the business alias of Defendant Richard Yanik.
`20. At all relevant times, Finstein and Yanik were personal friends.
`21. From 2009 through 2018, Yanik, under the alias RM Power, provided
`invoices to Palmdale for various services that he represented had been performed and
`had benefited Palmdale, including but not exclusively carpentry, storm drain clean-
`outs, electrical work, and valve replacements.
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`9477.0019 / 02351984.1
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`3
`COMPLAINT FOR MONETARY DAMAGES
`
`TEL (714) 547-2444 • FAX (714) 835-2889
`
`SANTA ANA, CALIFORNIA 92706-2614
`2122 NORTH BROADWAY, SUITE 200
`
`A Professional Corporation
`
`PRENOVOST, NORMANDIN, DAWE & ROCHA
`
`

`

`Case 2:21-cv-10046 Document 1 Filed 12/31/21 Page 4 of 11 Page ID #:4
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`22. Neither Yanik nor anyone on his behalf performed the services that were
`described in RM Power’s invoices.
`23. Finstein knew that Yanik did not perform the services that were
`described in RM Power’s invoices.
`24. Nevertheless, Finstein approved the invoices and authorized Palmdale to
`pay RM Power’s invoices, despite knowing that the invoices contained false
`information and that the services had not been provided.
`25. Upon receiving Finstein’s approval of the invoices, Palmdale paid RM
`Power (and, therefore, Yanik) for the amounts stated on the invoices.
`26. As a result, Palmdale improperly paid $66,816.33 to Yanik for services
`that RM Power and Yanik did not perform and Palmdale never received.
`B. MEKR Advance Systems’ Fraudulent Invoices.
`27. On behalf of Palmdale, Finstein retained a vendor identified as “MEKR
`Advance Systems” to perform services for Palmdale.
`28. MEKR Advance Systems also was the business alias of Yanik.
`29. From 2011 through 2018, Yanik, under the alias of MEKR Advance
`Systems, provided invoices to Palmdale for various services that he represented had
`been performed and had benefited Palmdale including coil cleaning, cooling tower
`cleaning, infrared inspections, automatic transfer switch maintenance, filter changes,
`line isolation testing, compressor replacement, master alarm replacement, fire pump
`replacement, and valve replacements.
`30. Neither Yanik nor anyone on his behalf performed the services that were
`described in MEKR Advance Systems’ invoices.
`31. Finstein knew that Yanik did not perform the services that were
`described in MEKR Advance Systems’ invoices.
`32. Nevertheless, Finstein approved the invoices and authorized Palmdale to
`pay MEKR Advance Systems’ invoices, despite knowing that the invoices contained
`false information and that the services had not been provided.
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`9477.0019 / 02351984.1
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`
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`4
`COMPLAINT FOR MONETARY DAMAGES
`
`TEL (714) 547-2444 • FAX (714) 835-2889
`
`SANTA ANA, CALIFORNIA 92706-2614
`2122 NORTH BROADWAY, SUITE 200
`
`A Professional Corporation
`
`PRENOVOST, NORMANDIN, DAWE & ROCHA
`
`

`

`Case 2:21-cv-10046 Document 1 Filed 12/31/21 Page 5 of 11 Page ID #:5
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`33. Upon receiving Finstein’s authorization, Palmdale paid MEKR Advance
`Systems (and, therefore, Yanik) for the amounts stated on the invoices.
`34. As a result, Palmdale improperly paid $187,097.74 to Yanik for services
`that MEKR Advance Systems and Yanik did not perform and Palmdale never
`received.
`Patriot Building Services’ Fraudulent Invoices.
`C.
`35. On behalf of Palmdale, Finstein retained a vendor identified as “Patriot
`Building Services” to perform services and to provide products to Palmdale.
`36. Patriot Building Services is and was the business alias of Mathis.
`37. From 2011 through 2018, Mathis, under the alias of Patriot Building
`Services, provided invoices to Palmdale for various products, supplies and services
`that he represented had been performed and had benefited Palmdale, including but not
`exclusively line isolation testing, condensate for steam boilers, return line treatment,
`oxygen scavengers, degreaser, and hand cleaner.
`38. Neither Mathis nor anyone on his behalf performed the services or
`provided the products that were described in Patriot Building Services’ invoices.
`39. Finstein knew that Mathis did not perform the services that were
`described in Patriot Building Services’ invoices.
`40. Nevertheless, Finstein approved the invoices and authorized for
`Palmdale to pay Patriot Building Supplies’ invoices, despite knowing that the invoices
`contained false information and the products, supplies and services had not been
`provided.
`41. Upon receiving Finstein’s authorization, Palmdale paid Patriot Building
`Services (and, therefore, Mathis) for the amounts stated on the invoices.
`42. As a result, Palmdale improperly paid $147,573.09 to Mathis for
`products, supplies and services that Patriot Building Services and Mathis did not
`provide or perform and products that Palmdale never received.
`/ / /
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`9477.0019 / 02351984.1
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`5
`COMPLAINT FOR MONETARY DAMAGES
`
`TEL (714) 547-2444 • FAX (714) 835-2889
`
`SANTA ANA, CALIFORNIA 92706-2614
`2122 NORTH BROADWAY, SUITE 200
`
`A Professional Corporation
`
`PRENOVOST, NORMANDIN, DAWE & ROCHA
`
`

`

`Case 2:21-cv-10046 Document 1 Filed 12/31/21 Page 6 of 11 Page ID #:6
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`PBS Fire Protection Services’ Fraudulent Invoices.
`D.
`43. On behalf of Palmdale, Finstein retained a vendor identified as “PBS Fire
`Protection Services” to perform services for Palmdale.
`44. PBS Fire Protection Services also was the business alias of Mathis.
`45. From 2011 through 2018, Mathis, under the alias of PBS Fire Protection
`Services, provided invoices to Palmdale for various services that he represented had
`been performed and had benefited Palmdale including but not exclusively monthly
`testing of the fire alarm system, line isolation testing, telescoping replacement, ground
`fault repair, and valve and pump replacements.
`46. Neither Mathis nor anyone on his behalf performed the services that were
`described in PBS Fire Protection Services’ invoices.
`47. Finstein knew that Mathis did not perform the services that were
`described in PBS Fire Protection Services’ invoices.
`48. Nevertheless, Finstein approved the invoices and authorized Palmdale to
`pay PBS Fire Protection Services’ invoices, despite knowing that the invoices
`contained false information and that the services had not been provided.
`49. Upon receiving Finstein’s authorization, Palmdale paid PBS Fire
`Protection Services (and, therefore, Mathis) for the amounts stated on the invoices.
`50. As a result, Palmdale improperly paid $262,455.00 to Mathis for services
`that PBS Fire Protection Services and Mathis did not perform, and Palmdale never
`received.
`E. DOES 1-20
`51. Persons and companies currently unknown to National Union despite
`due diligence (identified as DOES 1-20) assisted, aided, abetted, and otherwise
`participated in the fraudulent activities identified above.
`52. Plaintiff alleges that upon and information and belief, discovery will
`provide the identities of such persons and companies.
`/ / /
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`9477.0019 / 02351984.1
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`6
`COMPLAINT FOR MONETARY DAMAGES
`
`TEL (714) 547-2444 • FAX (714) 835-2889
`
`SANTA ANA, CALIFORNIA 92706-2614
`2122 NORTH BROADWAY, SUITE 200
`
`A Professional Corporation
`
`PRENOVOST, NORMANDIN, DAWE & ROCHA
`
`

`

`Case 2:21-cv-10046 Document 1 Filed 12/31/21 Page 7 of 11 Page ID #:7
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`Palmdale’s Discovery of the Scheme and Its Investigation.
`F.
`53. On January 3, 2019, Finstein approved Invoice No. 20910 from RM
`Power, allegedly pertaining to electrical services in the amount of $10,149.66.
`54. Later that day, Finstein stated to a co-worker that he would request that
`RM Power reduce the amount of the invoice to an amount less than $10,000.00 so
`that it would not raise any concerns or questions from Palmdale’s management.
`55. As a result of the conversation with the co-worker, Palmdale initiated an
`investigation into the invoices and determined that RM Power never rendered such
`services to Palmdale.
`56. On January 4, 2019, Finstein resubmitted the invoice for payment, but
`this time in the amount of $9,749.64.
`57. Palmdale thereafter broadened its investigation to analyze all vendors
`retained by Finstein and all invoices approved by Finstein.
`58. On January 12, 2019, Finstein notified Palmdale that he resigned from
`his employment with Palmdale.
`59. On January 24, 2019, Palmdale retained Crowe LLP (“Crowe”) to
`perform a forensic investigation into the vendors and invoicing handled by Finstein.
`60. Crowe’s investigation determined that Finstein authorized the payment
`of invoices for services that he knew were not performed and for products that he
`knew Palmdale never received.
`61. Crowe’s investigation produced information demonstrating that Yanik,
`Mathis, and others submitted false invoices to Palmdale that Finstein approved, and
`that Palmdale paid.
`62. Crowe’s investigation concluded that Palmdale suffered a loss in the
`total amount of $663,942.16 because of the false invoicing scheme.
`63. Palmdale paid Crowe $105,544.03 for Crowe’s services, further
`contributing to Palmdale’s loss.
`/ / /
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`9477.0019 / 02351984.1
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`7
`COMPLAINT FOR MONETARY DAMAGES
`
`TEL (714) 547-2444 • FAX (714) 835-2889
`
`SANTA ANA, CALIFORNIA 92706-2614
`2122 NORTH BROADWAY, SUITE 200
`
`A Professional Corporation
`
`PRENOVOST, NORMANDIN, DAWE & ROCHA
`
`

`

`Case 2:21-cv-10046 Document 1 Filed 12/31/21 Page 8 of 11 Page ID #:8
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`Palmdale’s Claim to National Union.
`G.
`64. National Union issued a policy of insurance (the “Policy”) to Universal
`Health and its subsidiaries, including Palmdale, in which National Union agreed to
`insure Universal Health and its subsidiaries for losses sustained due to employee
`dishonesty.
`65. Pursuant to the Policy, National Union indemnified Universal Health for
`the losses that Palmdale sustained because of the false invoicing scheme perpetrated
`by Finstein, Yanik, Mathis and others.
`66. Accordingly, National Union has become subrogated to Universal
`Health and Palmdale.
`67. Additionally, Universal Health executed an agreement on behalf of itself
`and Palmdale, assigning to National Union all of the rights claims, and causes of
`action that they had against Finstein, Yanik, Mathis and any others who may have
`participated in or benefited from the scheme.
`COUNT ONE - FRAUD
`(Finstein Only)
`68. By approving invoices for services that had not been performed and
`products that had not been provided, Finstein misrepresented facts to Palmdale.
`69. Finstein intended for Palmdale to rely on his approvals so that Palmdale
`would pay the fraudulent invoices.
`70. Palmdale justifiably relied on Finstein’s approvals.
`71. As a direct and proximate result, Palmdale suffered damages in the
`principal amount of $769,486.19.
`COUNT TWO - FRAUD
`(Yanik, Mathis, DOES 1-20)
`72. Yanik, Mathis, and DOES 1-20 misrepresented facts to Palmdale by
`submitting invoices to Palmdale that listed services or products that never were
`provided to Palmdale.
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`9477.0019 / 02351984.1
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`8
`COMPLAINT FOR MONETARY DAMAGES
`
`TEL (714) 547-2444 • FAX (714) 835-2889
`
`SANTA ANA, CALIFORNIA 92706-2614
`2122 NORTH BROADWAY, SUITE 200
`
`A Professional Corporation
`
`PRENOVOST, NORMANDIN, DAWE & ROCHA
`
`

`

`Case 2:21-cv-10046 Document 1 Filed 12/31/21 Page 9 of 11 Page ID #:9
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`73. Yanik, Mathis, and DOES 1-20 created and submitted the invoices
`knowing that the listed services or products never were provided to Palmdale.
`74. Yanik, Mathis, and DOES 1-20 intended to induce Palmdale to rely on
`the false invoices so that Palmdale would pay the invoices.
`75. Palmdale justifiably relied on the representations in the invoices and paid
`the invoices.
`76. As a direct and proximate result, Palmdale suffered damages in the
`principal amount of $769,486.19.
`COUNT THREE – CONVERSION
`(All Defendants)
`77. Palmdale owned and rightfully possessed its funds, totaling the specific
`and identifiable sum of $663,942.16.
`78. Defendants wrongfully exercised dominion over Palmdale’s funds by
`submitting false invoices and causing the funds to be placed in the possession of the
`Defendants.
`79. Defendants’ actions caused Palmdale’s funds to be wrongfully removed
`from Palmdale’s possession and inconsistent with Palmdale’s rights therein.
`80. As a direct and proximate result, Palmdale suffered damages in the
`principal amount of $769,486.19.
`COUNT FOUR – BREACH OF THE DUTY OF LOYALTY
`(Finstein Only)
`81. As an employee of Palmdale, Finstein owed Palmdale a duty of loyalty.
`82. Finstein repeatedly and systematically breached his duty of loyalty to
`Palmdale by authorizing the payment of invoices, despite knowing that such invoices
`listed services and products that never were provided to Palmdale.
`83. As a direct and proximate result, Palmdale suffered damages in the
`principal amount of $769,486.19.
`/ / /
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`9477.0019 / 02351984.1
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`9
`COMPLAINT FOR MONETARY DAMAGES
`
`TEL (714) 547-2444 • FAX (714) 835-2889
`
`SANTA ANA, CALIFORNIA 92706-2614
`2122 NORTH BROADWAY, SUITE 200
`
`A Professional Corporation
`
`PRENOVOST, NORMANDIN, DAWE & ROCHA
`
`

`

`Case 2:21-cv-10046 Document 1 Filed 12/31/21 Page 10 of 11 Page ID #:10
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`COUNT FIVE – CONSPIRACY TO BREACH THE
`DUTY OF LOYALTY
`(All Defendants)
`84. The Defendants entered into an agreement whereby they would submit
`false invoices, Finstein would approve the invoices for payment despite knowing that
`the services and/or products were not provided, and the Defendants would obtain
`payments from Palmdale.
`85. The Defendants knew that by creating, submitting, and approving the
`invoices, Finstein would breach his duty of loyalty to his employer.
`86. Nevertheless, the Defendants combined and assisted Finstein in such
`repeated and systematic breaches which resulted in improper benefits to Defendants.
`87. As a direct and proximate result of the agreement(s), Palmdale suffered
`damages in the principal amount of $769,486.19.
`COUNT SIX – CONSPIRACRY TO COMMIT FRAUD
`(All Defendants)
`88. The Defendants entered into an agreement whereby they would submit
`false invoices, Finstein would approve the invoices for payment despite knowing that
`services and/or products were not provided, and the Defendants would obtain
`payments from Palmdale.
`89. All Defendants knew that by creating, submitting, and approving the
`invoices, they were committing fraud.
`90. Nevertheless, all Defendants combined and acted in furtherance to
`commit fraud, to the detriment of Palmdale.
`91. As a direct and proximate result of the agreement(s), Palmdale suffered
`damages in the principal amount of $769,486.19.
`PRAYER FOR RELIEF
`WHEREFORE, Plaintiff, National Union Fire Insurance Company of
`Pittsburgh, Pa., as assignee and subrogee of Universal Health Services, Inc. and
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`9477.0019 / 02351984.1
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`10
`COMPLAINT FOR MONETARY DAMAGES
`
`TEL (714) 547-2444 • FAX (714) 835-2889
`
`SANTA ANA, CALIFORNIA 92706-2614
`2122 NORTH BROADWAY, SUITE 200
`
`A Professional Corporation
`
`PRENOVOST, NORMANDIN, DAWE & ROCHA
`
`

`

`Case 2:21-cv-10046 Document 1 Filed 12/31/21 Page 11 of 11 Page ID #:11
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`Palmdale Regional Medical Center, prays for relief against Defendants, Scott
`Finstein, Richard Yanik dba RM Power and/or MEKR Advance Services, and
`Thomas Mathis dba PBS Fire Protection Services and/or Patriot Building Services,
`DOES 1-20, jointly and severally, as follows:
`1.
`Compensatory damages in an amount no less than $769,486.19, trebled
`in the amount of $2,308,458.57, according to proof;
`2.
`Punitive damages due to Defendants’ wanton, willful, fraudulent, and
`malicious conduct;
`3.
`Costs of suit incurred herein;
`4.
`Reasonable and necessary attorneys’ fees; and
`5.
`Any such other relief as the Court deems just and proper.
`PRENOVOST, NORMANDIN, DAWE &
`DATED: December 31, 2021
`ROCHA
`A Professional Corporation
`
`By:
`
`/s/ Karel Rocha
`KAREL ROCHA
`JASON MEYER
`Attorneys for NATIONAL UNION FIRE
`INSURANCE COMPANY OF
`PITTSBURGH, PA.
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`TEL (714) 547-2444 • FAX (714) 835-2889
`
`SANTA ANA, CALIFORNIA 92706-2614
`2122 NORTH BROADWAY, SUITE 200
`
`A Professional Corporation
`
`PRENOVOST, NORMANDIN, DAWE & ROCHA
`
`
`
`
`
`
`
`
`
`9477.0019 / 02351984.1
`
`
`
`11
`COMPLAINT FOR MONETARY DAMAGES
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`