New York and New Jersey no-fault insurance laws require a driver's automobile insurance company to pay automobile insurance claims automatically for certain types of motor vehicle accidents, provided the claim is legitimate and is below a particular injury or damages threshold. Pursuant to these requirements, insurance companies will often pay medical service providers directly for the treatment they provide to automobile accident victims, without the need to bill the victims themselves. This process resolves automobile claims without apportioning blame or fault for the accident, thereby avoiding protracted disputes, and the costs associated with an extended investigation of the accident. Mr. Rose and his associates allegedly exploited these procedures by bribing individuals with access to confidential information about motor vehicle accident victims, using this information to contact victims under false pretenses, and steering these victims to seek treatment at medical clinics and legal representation from lawyers who were willing to pay kickbacks for the referrals.

Since at least in or about 2014, Mr. Rose and his alleged co-conspirators allegedly bribed as many as 50 people, whom they called "lead sources," who, at the time they accepted the bribes, were working for federally funded hospitals (the "Hospital Defendants"), the NYPD (the "NYPD Defendants"), and other entities. Mr. Rose paid these lead sources as much as $4,000 per month, and continuously worked to identify new lead sources, largely through word of mouth, and through the extensive corrupt network he established. Lead sources were paid in cash and "off the books." In return, these lead sources unlawfully disclosed protected, confidential information to Mr. Rose and his co-conspirators including victims' names, contact information, and medical information, according to the indictment.

As alleged, after receiving the confidential victim information from the lead sources, Mr. Rose and his associates provided the information to co-conspirators working at Mr. Rose's call center (the "Call Center Defendants") located in Brooklyn, New York. The call center was staffed with 10 to 15 "employees" who contacted the accident victims on a daily basis and steered them to seek medical treatment at clinics and law firms handpicked by Mr. Rose. The Call Center Defendants followed a pre-established "script" during these communications. Among other things, the Call Center Defendants falsely told accident victims that they were calling from an organization affiliated with the New York Department of Transportation, and that their organization had obtained the victims' contact information through a so-called Personal Injury Hotline. The Call Center Defendants also lied that they were calling to protect victims from people who obtain victims' information illegally and mislead victims into seeking treatment with certain providers. In actuality, the true perpetrators of these illegal acts were none other than Mr. Rose and his co-conspirators.

In selecting which motor vehicle accident victims to call, Mr. Rose instructed the Call Center Conspirators to target victims from low-income neighborhoods because, in Mr. Rose's view, these individuals could be more easily brought into the scheme, according to the indictment.

As alleged, from at least in or about 2014 to the present, Mr. Rose and his alleged co-conspirators illegally steered more than 6,000 motor vehicle accident victims to participating clinics and lawyers, who paid kickbacks in return for the referrals. In addition, this figure is a fraction of the number of actual accident victims whose confidential information was unlawfully disclosed as part of the No-Fault Scheme. The Call Center Conspirators successfully induced approximately one in 10 accident victims to seek treatment or representation from participating clinics and lawyers. Thus, the No-Fault Scheme resulted in the improper disclosure of the confidential information of at least 60,000 motor vehicle accident victims. Mr. Rose and co-conspirators further earned, on average, approximately $3,000 per successful referral.

Mr. Rose and the alleged co-conspirators went to elaborate lengths to conceal the No-Fault Scheme from law enforcement. Among other deceptive tactics, the alleged co-conspirators generally referred to one another only by aliases; used "burner" phones with temporary and unidentifiable phone numbers, switched their phone every 60 days; set up numerous fictitious companies; corresponded through encrypted mobile applications; and utilized concealed spreadsheets, which tracked the bribe payments to lead sources, in secret email accounts that co-conspirators could access remotely. The members of the conspiracy also assigned unique code names to each lead source, such as "J1," "P2," and "G6," and used these code names to refer to lead sources during communications rather than using their true names, according to the indictment.

The indictment charged Mr. Rose and the Hospital Defendants with conspiracy to violate the Travel Act, unlawful disclosure of protected health care information, and bribery. Six others, including members of Mr. Rose's family, and the five Call Center Defendants were charged with conspiracy to violate the Travel Act. In addition, the six NYPD Defendants were charged with conspiracy to violate the Travel Act and bribery. The names of the defendants, the charges against them, and other information is set forth below.