Case: 4:18-cv-01005 Doc.

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Exhibit C
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EXPRESS SCRIPTS®

April 12, 2017

Sent via FedEx

CZ Services, Inc. dba Carezone Pharmacy

860 Harbour Way S, Ste E
Richmond, CA 94802

Re: Notice of Breach and Cease and Desist I CZ Services, Inc. dba Carezone Pharmacy,
NCPDP 5654137 ("Provider")

Dear Provider,

In accordance with the Express Scripts Network Provider Manual and Section ml of the Express
Scripts, Inc. Pharmacy Provider Agreement (collectively, the "Agreement"), this letter constitutes notice by
Express Scripts, Inc. ("Express Scripts") of Provider's breach of the Agreement.

This violates

Based on recent review of Provider's claim activity, Express Scripts has determined that Provider is
primarily operating a mail order business in breach of the Agreement and contrary to the representations
and warranties made by Provider to Express Scripts during the credentialing process. Provider submitted
a credentialing application to Express Scripts in May 2015. In signing this application, Provider "certified
that each answer on the Provider Certification (including attachments) is true and correct" . Specifically,
Provider specified that 99% of its business is Open Door Retail/Community. In fact, Jennifer Thomashow
confirmed that fact in a letter dated May 18, 2015 stating "Pharmacy will only mail 1% of prescriptions.
Most if not all will be picked up" and again on June 1, 2015, stating 'Please be sure your records indicate
only 1% mail order". In reviewing claims submitted by Provider, it is clear that nearly 99% of Provider's
business is mail order. Upon review of this information, it is clear that the information submitted by
Provider was materially misleading and inaccurate.

1 Pursuant to the Network Provider Manual Glossary, -

Confidential Information

Express Scripts, Inc. One Express Way St. Louis, MO 63121 (888)571 -8182
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In addition, it appears that Provider has improperly shipped prescriptions into states where Provider is not
licensed in direct violation of the Agreement. Specifically, Provider shipped prescriptions into the following
states for which Express Scripts cannot locate a valid Board of Pharmacy non-resident license as follows:

1_ New York
2, Virginia
3. Tennessee
4 . Georgia
5. Maryland

As participate in Express Scripts network(s),

Based on the foregoing, Express Scripts hereby demands that Provider: {i) cease and desist
mailing into all non-resident states; (ii) provide Express Scripts with a copy of a valid non-resident
license in the aforementioned states or reverse all submitted claims shipped to those states, and
any other states where Provider is not licensed, or was unlicensed; and (iii) refrain from any
conduct that constitutes a breach of your obligation as a participating Provider in the Express
Scripts retail network(s) under the Agreement.

Further, Express Scripts requires Provider to submit a written corrective action plan that
specifically details how Provider will remedy the breaches set forth in this letter.

Provider must comply with the demands set forth above and confirm such compliance in writing no later
than May 3, 2017. In the event Provider fails to remedy the breaches identified in this letter and comply
with Express Scripts' requests, Express Scripts may immediately terminate Provider's participation in
Express Scripts' provider network in accordance with the Agreement. See Sections . and • of the
Provider Agreement.

Please retain a copy of this letter as Provider's official notice of breach. Should you have any questions
regarding tt1is notification, please contact pharmacvproviderterm@express-scripts com.

Regards,

Provider Compliance

Conf idential Info rmat ion

Express Scripts, Inc. One Express Way St. Louis, MO 63121 (888)571 -8182