U.S. v. Shorter

Record supported jury’s guilty verdict on Medicaid fraud charges arising out of defendant’s submission of invoices for medical transportation services that did not occur at all or for services during transportation of patients that did not occur, where govt. presented witnesses who stated that certain services did not occur during their transportation by defendant's company or that they did not use said company's services at times asserted in invoices. Fact that defendant claimed that there was no direct evidence that as owner of said transportation company, she personally submitted fraudulent invoices did not require different result, where other circumstantial evidence indicated that defendant either used identities of third-parties when submitting said invoices or directed/trained others to do so on behalf of her company. Ct. further rejected defendant’s claim that instant indictment, which used only initials to identify third-parties whose names were used when submitting fraudulent invoices, provided defendant with inadequate notice of charged offenses, since record showed that defendant was aware of actual identity of said third-parties at time of trial.