UNITED STATES OF AMERICA,

HEARTLAND DENTAL CARE, INC.,

Case No.
,
APR 11 12008
CLERK OFTHE
DISTRICTCcgJ:
DISTRICTOF ILLINOIS
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IN THE UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF ILLINOIS
AT SPRINGFIELD
Plaintiff,
Defendant.
v.
COMPLAINT
The United States of America, on behalf of the Drug Enforcement Administration of the
United States Department of Justice ("DEA"), for its complaint against the defendant states the
following:
Jurisdiction and Venue
1. This is a civil action for penalties under the Comprehensive Drug Abuse
Prevention and Control Act of 1970 ("The Act"), Title 21, United States Code, Section 801, et
seq., and the regulations promulgated thereunder.
2. The jurisdiction of this Court is based upon Title 28, United States Code, Sections
1345 and 1355, and Title 21, United States Code, Section 842(c)(1).
3. Venue is proper in the Central District of Illinois pursuant to Title 28, United
States Code, Sections 1391(c) and 1395(a).
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E-FILED
Friday, 11 April, 2008 02:58:10 PM
Clerk, U.S. District Court, ILCD
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Parties
4. The plaintiff is the United States of America, on behalf of the United States Drug
Enforcement Administration ("DEA"). The DEA is an agency within the United States
Department of Justice responsible for enforcing the provisions of the Act.
5. The defendant is Heartland Dental Care, Inc. ("Heartland"). Heartland is a
Delaware corporation in good standing located at 1200 Network Centre Dr., Effingham, Illinois.
Heartland manages dental practices throughout the state of Illinois and elsewhere. Heartland
Dental Care, Inc., which was not incorporated until 2006, is the successor entity to Dental Health
Resources, LLC, Dental Health Resources, Inc. and Heartland Dental Development, Inc.
(collectively "DHR entities"). The DHR entities managed the dental practices, entities, dentists
and employees whose conduct is described below. Richard E. Workman, D.M.D. is the
President and Chief Executive Officer for Heartland.
Regulatory Scheme
6. The Act and regulations thereunder require that every person who distributes or
dispenses any controlled substance shall obtain annually a registration issued by the Attorney
General.
7. It is unlawful for any person to distribute or dispense a controlled substance in
violation of the Act, including through the use of a registration number issued to another person.
8. Dentists working for Heartland are, and are required to be if that dentist elects to
distribute or dispense any controlled substance, registered with the Attorney General of the
United States under the Act, and have been assigned various registration numbers by the DEA.
9. As a result of DEA inspections and review conducted from 2003 until 2007, DEA
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uncovered numerous instances of misuse of DEA registration numbers assigned to the various
dentists working for Heartland.
Factual Background
10. Beginning in at least August, 1999, Heartland employed dentists for its affiliated
dental offices.
11. Many of the newly hired dentists were not registered with DEA and therefore did
not possess a DEA registration number as required by the Act.
12. Without regard for the Act, unregistered dentists employed by Heartland used the
DEA registration number of other Heartland dentists to issue prescriptions for controlled
substances in violation of the Act.
13. Heartland management was aware of and facilitated the improper use by
unregistered dentists of DEA registration numbers assigned to other Heartland dentists.
COUNT I
(Issuance of Prescriptions by Unregistered Practitioners)
14. Plaintiff incorporates by reference the allegations of paragraphs 1 13 of this
complaint as if fully set forth herein.
15. In violation of21 U.S.c. 842(a)(1) and 21 C.F.R. 1306.03, on a number of
instances beginning in at least August, 1999 and continuing until on or about December 31,
2005, Heartland dentists issued prescriptions without registering with the Attorney General ofthe
United States under the Act and without previously obtaining an assigned registration number
from the DEA.
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Count II
(False Statements on Prescriptions)
16. Plaintiff incorporates by reference the allegations of paragraphs 1 - 13 of this
complaint as if fully set forth herein.
17. In violation of21 U.S.C. 842(a)(l) and 21 C.F.R. 1306.05, on a number of
instances beginning in at least August, 1999 and continuing until on or about December 31,
2005, Heartland dentists issued prescriptions for controlled substances misrepresenting the name,
address, and registration number of the issuing practitioner, in that the issuing dentist used the
name and registration number of another Heartland dentist.
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s/Eric I. Long
Relief Requested
WHEREFORE, the plaintiff, the United States of America, respectfully prays that this
Court grant the following relief:
1. Enter an order directing Heartland to pay a civil penalty for its past violations of
the Act;
2, Enjoin Heartland from any all further violations of the Act and its implementing
regulations for a period of five (5) years from the date ofjudgment herein;
3. Award plaintiff the costs of this suit; and
4. Award all other relief as it deems just and proper.
Respectfully submitted,
RODGER A. HEATON
UNITED STATES ATTORNEY
Eric I. Long
Assistant United States Attorney
Office of the United States Attorney
318 S. Sixth Street
Springfield, Illinois 62701
Telephone: 217/492-4450
Eric.long@usdoj.gov
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