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Case 4:13-cr-00055-JAJ-RAW Document 20 Filed 07/02/13 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF IOWA

UNITED STATES OF AMERICA,

Plaintiff,

v.

MICHAEL FRANCIS STEIN

Defendants.

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) CRIMINAL NO. 4:13-CR-55
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) GOVERNMENT'S RULE 12.4
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STATEMENT

The United States of America, by and through its undersigned counsel,

respectfully submits the following disclosure statement as required by Fed. R. Crim. P. 12.4.

1. The following corporation is the victim of the criminal activity charged in the above

case:

Wellmark is an Iowa corporation with its principal place of business located in

Des Moines, Iowa. Wellmark does business under the name Wellmark Blue Cross and Blue

Shield of Iowa. Wellmark is a mutual insurance company that is licensed by the Iowa Division of

Insurance to provide health care benefits to its members. Wellmark is an independent licensee of

the Blue Cross and Blue Shield Association (BCBSA). The BCBSA is a national federation of

38 Blue Cross and Blue Shield companies. Wellmark has no parent corporation and no publicly

held corporation owns 10% or more of their stock.



2. This statement is based on information reasonably believed to be accurate and

presently available to government counsel, upon the exercise of due diligence, and is subject to

Case 4:13-cr-00055-JAJ-RAW Document 20 Filed 07/02/13 Page 2 of 2

being supplemented under Fed. R. Crim. P. 12.4(b)(2).



Respectfully Submitted,

Nicholas A. Klinefeldt
United States Attorney

By: /s/ John S. Courter

John S. Courter
Assistant United States Attorney
U. S. Courthouse Annex, 2nd Floor
110 E. Court Avenue
Des Moines, Iowa 50309
Tel: (515) 473-9300
Fax: (515) 473-9292
Email: [email protected].gov

CERTIFICATE OF SERVICE

I hereby certify that on July 2, 2013, I
electronically filed the foregoing with the
Clerk of Court using the ECF system which
will send notification of such filing to the
attorney(s) of record.

UNITED STATES ATTORNEY

By:

/s/ AUSA John S. Courter