Criminal Complaint — United States v. Maurice Fayne (Dkt. 158, N.D. Ga. No. 1:20-cr-00228)

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U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00228-MHC-JKL · Doc. 158 · 2021-02-08 · Docket on CourtListener

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Case 1:20-cr-00228-MHC-JKL     Document 158     Filed 02/08/21     Page 1 of 24

AO 83 (12/85) Summons in a Criminal Case
FILED IN CHAMRFDC
UNITED STATES DISTlUCT COURT
NORTHERN DISTRICT OF GEORGIA
JAN 13.
UNITED STATES OF AMERICA,
vs.
MARKT.SARGENT
43 COUNmY RIDGE ROAD
MELISSA, TEXAS 75454
YOU ARE HEREBY SUMMONED to appear before
date and time set forth below.
U.S.MAlSTSTRATE JUDGE'
N.D.GEORGIA
SUMMONS IN A CRIMINAL CASE
CASE NO. 1:20-CR-228-MHC-JKL
the United States District Court at the place,
PLACE: U.S. Courthouse
Richard B. Russell Building -
Room # 1860
75 Ted Turner Drive, SW
Atlanta, Georgia 30303-3309
BEFORE: Honorable Linda T. Walker
United States Magistrate Judge
DATE AND January 27,2021
TIME: 10:00 am
To answer a(n)
S Indictment
D Vijslation Notice
D Probation Violation Petition
D Information D Complaint
Charging you with a violation of Title 18, United States Code, Secjtion(s) 1349
Brief description of the offense: Attempt and Conspiracy to Cdmmit Fraud
AUSA: Russell Phillips
Counsel for Defendant: Mark Campbell
PLEASE CONTACT PRETRIAL SERVICES IMMEDIATELY UPON RECEIPT OF TfflS SUMMONS.
OFFICE HOURS ARE FROM 8;30 AM TO 5:00 PM, MONDAt THROUGH FRIDAY.
TELEPHONE (404) 215-1900.
January 5,2021
Ji<\MES N. HATTEN
CILERK OF COURT
By:
Deputy fclerk
1 t^~2^5< ^
z
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ORiGiNAL
Case l:20-cr-00228-MHC-JKL Document 96 Filed 11/19/20. Page 1 of 22
FILED IN OPEN COURT
U.S.D.C. - Atlanta ;
NOV \ 9 2020 I
'•(
JAMES N, HATTEN, Clerk
' Deputy Cierk
m THE UNITED STATES DISTRICT COURT—~~~'
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
INDICTMENT NUMBER
1:20-CR-228-MHC-JICL
(SECOND SUPERSEDING)
UNITED STATES OF AMERICA
V.
MAURICE FAYNE, a/k/a ARKANSAS Mo
DANIEL ERIC JAY
MICHAEL D. SARGENT
MARK T. SARGENT
THE GRAND JURY CHARGES THAT:
COUNT 1
CONSPIRACY TO COMMIT WIRE FRAUD
1. From in or about. March 2013 through in or about May 2020, in the Northern
District of Georgia and elsewhere, the Defendants,
Maurice Fayne, a/k/a Arkansas Mo,
Daniel Eric Jay,
Michael D. Sargent, and
Mark T. Sargent,
did knowmgly and willfully combine, conspire, confederate, agree, and have a
tacit understa.ndmg with each other and with others known and unknown to the
Grand Jury to devise and intend to devise a scheme and artifice to de&aud
investors in Defendant Fayne's trucking company, and for obtaining money .from
those investors by means of materially false and fi-audulent pretenses,
representations, and promises, and by the omission of material facts, in violation
of Title 18, United States Code, Section 1343.
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2. At all times relevant to this Indictment, Defendant Fayne operated a small,
unprofitable trucking company. He frequently changed fhe name of the company
and its address in an effort to avoid the IRS and other creditors and to stay one step
ahead offiie government agencies that regulated fhe trucking industry.
3. A mutual friend named D.B. introduced Defendant Fayne to the other Defendants
when they all lived in Texas. Defendant Fayne later moved to Georgia, and
Defendant Jay moved to Pennsylvania. Defendants Michael D. Sargent and Mark
T. Sargent—who are twins—remained in Texas.
OBJECT OF THE CONSPffiACY
4. The object of the conspiracy was for the Defendants to pay their own debts and
expenses by taking money from others under false pretenses.
MANNER AND MEANS
5. To accomplish the unlawful object of the conspiracy:
(a) Defendant Payne asked the other Defendants to help him recruit people to
invest in his trucking company. The other Defendants agreed.
(b) During fhe course of the conspiracy, the Defendants caused more than 20
people to invest money in Defendant Payae's trucking company. The
Defendants targeted their own friends and family members. The Sargent
brothers also targeted women that they met through online dating sites,
such as Matoh-com and Plenty of Fish (POF.com).
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(c) The Defendants took money from investors by cash, check, electronic
payment, credit card, debit card, and wire transfer.
(d) The Defendants fraudulently led investors to believe tiiat Defendant
Fayne's trucking company was capable of generating enormous profits for
investors when, as the Defendants knew and had reason to know, that was
not tme.
(e) The Defendants also misled investors by providing them with fraudulent
documents.
(f) In addition. Defendant Fayne provided and caused others to provide false
and misleading information to various government agencies—including the
Arkansas Secretary of State, the United States Department of
Transportation, and the Federal Motor Carrier Safety Administration—
knowing and having reason to know that the mformation would be viewed
online by investors and others who were checkmg up on his tmcking
company.
(g) Also, the Defendants told investors a variety ofHes. For example, fhe
Defendants fraudulently overstated the number of trucks and drivers that
Defendant Fayne's trucking company actually had.
(h) The Defendants also falsely told investors that Defendant Fayne's trucking
company was on the verge of obtaining a multi-million-dollar contract with
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Walmart. Defendant Jay and the Sargent brothers claimed to be Defendant
Fayne's partners in the alleged deal.
(i) . The Defendants falsely claimed that Walmart -was ready to sign the contract
as soon as Defendant Fayne's trucking company paid a particular bill—a
bill that, in truth, did not exist. The Defendants asked investors for money
to pay the fictional bill and promised to repay the investors ia full, with a
generous amount of interest, as soon as the contract was signed. Within a
short time after that, the Defendants would go back to the investors and ask
for money to pay another nonexistent bill, which the Defendants would
falsely say had to be paid to prevent the alleged deal from falling apart. The
investors would usually find a way to come up with the additional money
because they were afraid of losing everything they had invested up to that
point. That cycle repeated itself—time after time after time—until the
investors either ran out of money or simply refused to turn over any more
money because they finally realized that they had been conned.
0) The Defendants falsely claimed that a senior Walmart executive named
M.B. had invested a large amount of his own money in Defendant Fayne's
trucking company and was helping the Defendants secure the contract. The
Defendants even pretended that M.B. was providing them with "insider"
infomiation concerning the status of the contract approval process.
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(k) Furthermore, the Defendants sent investors phony text messages from
someone posing as M.B. and someone posing as T.M., a nonexistent
Wah-nart insider. In addition, Defendant Fayne disguised his voice and
posed as M.B. and T.M. in phone conversations with investors.
(1) M.B. is, in fact, a real person and really was a senior executive at Walmart.
But neither M.B. nor any other Walmart executive ever invested in
Defendant Fayne's trucking company. And the Defendants never even
talked to the M.B. who worked at Walmart.
(m) To prevent investors fi-om discovering the truth about the phony Walmart
deal, the Defendants told investors not to contact Wahnart directly. The
Defendants falsely claimed that secrecy was necessary because Wahnart
would cancel the contract if it found out that one of its executives had
invested m Defendant Fayne's tmckiag company.
(n) During the course of the conspiracy, the Defendants acknowledged that
they were participating in an illegal scheme to defraud investors. For
example:
• On or about November 6,2017, Defendant Jay told Defendant Mike
Sargent that an investor was "questioning whether he'll get payback
because the deal doesn't seem real."
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• On or about June 20,2018, Defendant Mark Sargent told D.B., "There
is NO Walmart.. . Same scam every few days.... Just steel [sic] more
aa[d] more money. It's conspiracy, Money laundering. Wire fraud.!!!!
God know what else the feds are going to charge all of us with.!!!!
Because there is no Walmart deal.!!!!"
• Also on or about June 20,2018, Defendant Mark Sargent sent a text
message to Defendant Mike Sargent, attaching a screenshot of a bank
record showing that Defendant Fayne had used investor money to pay
personal his expenses. In that same text message. Defendant Mark
Sargent also told his brother that Defendant Fayne "fly s everywhere on
the money you steel" [sic]. Defendant Mike Sargent responded, "Yes I
saw it."
• On or about February 13,2019, Defendant Jay told Defendant Fayne, "I
don't know if [investor L.W.j is blufimg but I don't think we need
attorneys calling" Walmart's legal department.
(o) Not all investors were told that the company offering the contract was
Walmart. Some were told that it was Amazon or UPS. But Defendant
Fayne's trucking company did not have a contract with Amazon or UPS
eitiher.
(p) The Defendants falsely told investors that one of Defendant Fayne's bank
accounts had millions of dollars in it, and they falsely claimed that the IRS
had temporarily frozen the account. To further that illusion, the Defendants
sent investors a fraudulently altered bank record, which overstated the
amount of money in fhe account. The Defendants then convinced investors
to pay expenses related to Defendant Fayne's trucking company, promising
them that they would be repaid with interest as soon as the account was
unfrozen.
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(q) Defendant Fayne falsely told investor B.A. that Defendant Mike Sargent
had purchased 40 trucks for Defendant Fayne's trucking company.
(r) The Defendants falsely promised other investors that their investment
proceeds would be used to purchase new teucks for Defendant Fayne's
trucking company and that they would receive a steady income stream from
the profits generated by those trucks. In an attempt to make Defendant
Fayne's truckiag company appear legitimate, and to lull investors into a
false sense of security and delay or prevent fheir complaints to law
enforcement, the Defendants paid "make-believe" profits to a few of these
investors—using the investors' own money.
(s) But most investors never received any of their investment proceeds back,
much less the huge profits that they were promised.
(t) Instead, the Defendants used most of the investors' money to pay their own
personal debts and expenses and to fund a lifestyle for themselves that they
otherwise could not have afforded. Defendant Fayne—the organizer and
leader of the fraudulent scheme—kept the majority of the fraud proceeds
for himself. And durmg the course of the conspiracy. Defendant Fayne
transferred more than $5 million to the Choctaw Casino and Resort to cover
his personal gambling and entertainment expenses.
All in violation of Title 18, United States Code, Section 1349.
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COUNTS 2-4
WmE FRAUD
6. The facts alleged in paragraphs 2 through 5, including all subparts, are
incorporated here.
7. On or about each of the dates set forth below, in the Northern District of Georgia
and elsewhere, the Defendants,
Maurice Fayne, a/k/aArkansas Mo,
Daniel Eric Jay,
Michael D. Sargent, and
MarkT.Sargent,
aided and abetted by each other and by others known and unknown to fhe Grand
Jury, having devised and intending to devise a scheme and artifice to defraud
investors in Defendant Fayne's trucking company, and for obtaining money from
those investors by means of materially false and fraudulent pretenses,
representations, and promises, and by the omission of material facts, transmitted
and caused to be transmitted by means of wire communication in interstate
commerce, the followmg writings, signs, signals, pictures, and sounds for the
purpose of executing such scheme and artifice:
Count
2
Date
04-23-20
Description
$175,000 wire transfer from United Community Bank
account #1408, held in the name of Flame Trucking Inc.,
to Navy Federal Credit Union account #6082, held in tiie
name ofT.V.
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Count
3
4
Date
04-24-20
05-01-20
Description
$30,000 wire transfer from United Community Bank
account #1408, held in the name of Flame Trucking Inc.,
to JPMorgan Chase Bank, NA account #0180, held in the
name of Daniel E. Jay
$25,000 wire transfer from United Community Bank
account #1408, held in the name of Flame Trucking Inc.;
to Bank of America, N.A., account #2851, held in the
name of Michael Sargent
All in violation of Title 18, United States Code, Section 1343 and Section 2.
COUNTS
BANK FRAUD
8. From in or about Apnl 2020 tb-ough in or about May 2020, in the Northern
District of Georgia and elsewhere, the Defendants,
Maurice Fayne, a/k/a Arkansas Mo, and
Daniel Eric Jay,
aided and abetted by each other and by others known and unknown to the Grand
Jury, participated in a scheme and artifice to defraud United Community Bank, a
financial institution as defined in Title 18, United States Code, Section 20, and to
obtain moneys and funds owned by and under the custody and control of United
Community Bank, by means of materially false and fraudulent pretenses,
representations, and promises, and by the omission of material facts ("the bank
fraud scheme").
9. At all times material to the bank fraud scheme, Defendant Payne was tfae sole
owner of a Georgia corporation called Flame Trucking Inc.
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10. United Community Bank participated as a lender in the Pay check Protection
Program (PPP); a loan program created by the United States Small Business
Administration to help small businesses pay payroll costs, including benefits;
interest on mortgages; rent; and utilities during the COVID-19 pandemic.
11. On or about March 29, 2020, Defendant Jay suggested to Defendant Fayne that
Defendant Fayne obtain a PPP loan under false pretenses and use the loan
proceeds for an illegal purpose, namely, to make payments related to the wire
fraud couspiracy described in Count 1 of this Indicttneat. Defendant Jay later said
to Defendant Fayne: "[I]fwe can somehow justify 100+ drivers on 1099 for Flame
we have somethmg[.]" Defendant Jay then helped Defendant Fayne create
fraudulent documents to support a PPP loan application.
12. On or about April 15, 2020, for the purpose of executing and attempting to execute
the bank fraud scheme, Defendant Fayne signed and submitted to United
Community Bank a PPP loan application in the name of Flame Trucking Inc.,
which requested a loan in the amount of $3,725,500, and which falsely represented
that Flame Trucking Inc. had 107 employees and an average monthly payroll of
$1,490,200.
13. After the loan was funded. Defendant Jay admitted to E.B. that he had falsified
bank statements to help Defendant Fayne get the loan. Defendant Jay also
admitted to E.B. that he had made up a list of fake names of people who were
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allegedly employed by Flame Trucking Inc., and that Defendant Fayne had
submitted that list to United Community Bank in connection with the loan.
All in violation of Title 18, United States Code, Section 1344 and Section 2.
COUNT 6
FALSE STATEMENT TO A FINANCIAL INSTITUTION INSURED BY THE FDIC
14. The facts alleged in paragraphs 9 and 10 are incorporated here.
15. On or about April 24, 2020, in the Northern District of Georgia and elsewhere, the
Defendant,
Maurice Fayne, a/k/a Arkansas Mo,
aided and abetted by others known and unknown to the Grand Jury, knowingly
made a false statement for the purpose of influencing the action of United
Community Bank, an institution the accounts of which were insured by the
Federal Deposit Insurance Corporation, in connection with Flame Tracking's PPP
loan application, when he sent an email to United Community Bank, attaching
what he represented to be October, November, and December 2019 bank
statements for Flame Tracking's account at Arvest Bank, when in truth and in
fact—as Defendant Fayne knew—those bank statements were phony, because
Aryest Bank had shut down Flame Trucking's account in September 2019.
All m violation of Title 18, United States Code, Section 1014 and Section 2.
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COUNTS 7-16
CONCEALMENT MONEY LAUNDERING
16. The facts alleged in paragraphs 2 through 5, including all subparts, are
incorporated here.
17. It is also relevant to the Indictment that:
(a) In Flame Tmcking's PPP loan application. Defendant Fayne certified that
the loan proceeds would be used to "retain workers and maintain payroll or
make mortgage interest payments, lease payments, and utility payments, as
specified under the Paycheck Protection Program Rule."
(b) In. Flame Tmcking's PPP loan application, Defendant Payne acknowledged
that he could be prosecuted for fraud if the PPP loan proceeds were
"kQowingly used for unauthorized purposes."
(c) Defendant Fayne knowingly used the PPP loan proceeds for unauthorized
purposes, including the following:
• making payments related to the wire fraud conspiracy described in
Count 1 of this Indictment;
• paying restitution;
• purchasing j eweliy;
• paying child support; and
• leasing a Rolls-Royce.
(d) In or around mid-March 2020, Defendant Fayne contacted oue of the
recruiters involved in the wire fraud conspiracy, T.V., and stated that he was
in the process of obtaining a PPP loan. Defendant Fayne stated that he
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planned to use some of the PPP loan proceeds to make payments related to
the wire fraud conspiracy.
(e) On or about April 22,2020, United Community Bank transferred the PPP
loan proceeds to United Community Bank account #1408, held in the name
of Flame Trucking and controlled by Defendant Fayne.
(f) On or aboutApril 23, 2020, Defendant Fayne wire transferred $175,000 in
PPP loan proceeds to T.V., as described in Count 2 of this Indictment, and
Defendant Fayne instructed T.V. to use that money to conduct certain
financial transactions on his behalf, including those described in. Counts 7
and 8 of this Indictment.
18. On or about each date set forth below, in the Norfchem Disb-ict of Georgia and
elsewhere, the Defendant,
Maurice Fayne, a/k/a Arkansas Mo,
aided and abetted by others known and unknown to the Grand Jury, knowingly
conducted and attempted to conduct a financial transaction affecting interstate
commerce, which involved the proceeds of a specified unlawful activity, that is
bank fraud, in violation of Title 18, United States Code, Section 1344, knowing
that the transaction was designed in whole and in part to conceal and disguise, the
nature, location, source, ownership, and control of tiie proceeds of specified
unlawful activity, and white conducting and attempting to conduct such financial
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transaction knowing that the property involved in the financial transaction
represented the proceeds of some form of unlawful activity:
Count
7
8
9
10
11
12
13
14
Date
04-23-20
04-23-20
04-24-20
04-27-20
04-23-20
04-28-20
04-30-20
04-28-20
Description
Defendant Payne caused $60,000 m PPP loan proceeds to be
wire transferred from Navy Federal Credit Union, account
#6082, held in the name ofT.V., to Sterling National Bank
account #5233, held in the name of Lucky Star Licensing.
Defendant Fayne caused $60,000 in PPP loan proceeds to be
wire transferred from Navy Federal Credit Union, account
#6082, held in the name ofT.V., to JPMorgan Chase Bank
account #1572, held in the name ofSonoran HomeWatch LLC.
Defendant Fayne caused $75,000 in PPP loan proceeds to be
wire transferred from United Community Bank account #1408,
held in the name of Flame Trucking Inc., to Regions Bank
account #5081, held in the name ofJ.S.
Defendant Fayne caused J.S. to purchase a $50,000 cashier's
check payable to the DeSha County (Arkansas) Sheriff's
Of5ce, to pay restitution owed by Defendant Fayne.
Defendant Fayne caused $350,000 in PPP loan proceeds to be
wire transferred from United Community Bank account #1408,
held m the name of Flame Trucking Inc., to Wells Fargo Bank,
NA account #0467, held in the name ofC.W.
Defendant Fayne caused $84,000 in PPP loan proceeds to be
wire transferred from Wells Fargo Bank, NA account #0467,
held in the name of C.W., to Bank of America, New York, NY
account #9593, held m the name of Status Jewelers, to
purchase three pieces of jewelry for Defendant Fayne.
Defendant Fayne caused $40,000 in PPP loan proceeds to be
wire transferred from Wells Fargo Bank, NA account #0467,
held in the name of C.W., to Arkansas Federal Credit Union
account #5028, held in fhe name of S.T., to pay child support
owed by Defendant Fayne.
Defendant Fayne caused $90,000 in PPP loan proceeds to be
wire transferred from United Community Bank account #1408,
held in the name of Flame Trucking Inc., to Navy Federal
Credit Union account #0090, held in the name of Maurice
Fayne.
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Count
15
16
Date
04-30-20
05-01-20
Description
Defendant Fayne caused $142,000 in PPP loan proceeds to be
wire transferred from United Community Bank account #1408,
held in the name of Flame Trucking Inc., to Navy Federal
Credit Union account #0090, held m the name of Maurice
Payne.
Defendant Fayne caused $136,000 in PPP loan proceeds to be
wire transferred from Navy Federal Credit Union account
#0090, held in the name of Maurice Fayne, to M & T Bank
account #4612, held in the name of Luxury Lease Company, as
a down payment on the lease of a 2019 Rolls-Royce Wraith,
VIN SCA665C53KUX87297.
All in violation of Title 18, United States Code, Section 1956(a)(l)(B)(i) and Section 2.
COUNTS 17-19
TRANSACTIONAL MONEY LAUNDERING
19. The facts alleged in paragraphs 2 through 5, includiag all subparts, are
incorporated here.
20. It is also relevant to the Indictment that:
(a) On or about April 22,2020, C.W. created an Arkansas limited liability
company called C.R. Wilkins Tmcldng, LLC.
(b) The next day, on or about April 23, 2020—on behalf of C.R. WiUdns
Trucking, LLC—C.W. signed a contract to purchase eight Kenworth T-680
trucks fi-om TransAm Tmcking, for a total of $368,000.
(c) Also on or about April 23, 2020—on behalf of C.R. Wilkins Trucking,
LLC—C.W. signed a contract to purchase six refrigerated trailers from
Great Dane, LLC, for a total of $ 189,000.
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21. On or about each date set forth below, in the Northern District of Georgia and
elsewhere, the Defendant,
JVIaurice Fayne, a/k/a Arkansas Mo,
aided and abetted by others known and unknown to the Grand Jury, knowingly
engaged in, attempted to engage in, and caused others to engage in a monetary
transaction by, through, and to a financial institution, affecting interstate
commerce, knowing that such transaction involved criminally derived property of
a value greater fhan $10,000, such property having been derived from a specified
unlawful activity, that is, bank fraud, in violation of Title 18, United States Code,
Section 1344:
Count
17
18
19
Date
04-23-20
04-23-20
04-27-20
Description __
Defendant Fayne caused $368,000 in PPP loan proceeds to be
wire transferred from United Community Bank account
#1408, held in the name of Flame Trucking Inc., to UMB
Bank, N.A. account #6105, held in the name ofTransAm
Trucking Exchange, to purchase eight Kenworth T-680 trucks
for C.R. Wffldns Trucking, LLC.
Defendant Fayne caused $189,000 in PPP loan proceeds to be
wire transferred from United Community Bank account
#1408, held m the name of Flame Trucking Inc., to JPMorgan
Chase Bank, NA account #2162, held iti the name of Great
Dane LLC, to purchase six refrigerated trailers for C.R.
Wilkins Trucking, LLC.
Defendant Fayne withdrew $65,000 in cash from United
Community Bank account #1408, held in the name of Flame
Trucking Inc.
All in violation of Title 18, United States Code, Section 1957 and Section 2.
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COUNT 20
AGGRAVATED IDENTITY THEFT
22. The facts alleged m paragraphs 2 through 5, including all subparts, are
incorporated here.
23. From in or about October 2018 through in or about July 2019, in fhe Northern
District of Georgia and elsewhere, the Defendant,
IVEaurice Fayne, a/k/a Arkansas Mo^
aided and abetted by others known and unknown to the Grand Jury, knowingly
possessed and used, without lawful authority, the means of identification of
another person, namely the name and signature ofD.P., during and in relation to a
felony violation of Title 18, United States Code, Section 1349, as alleged in Count
1 of this Indictment.
All m violation of Title 18, United States Code, Section 1028A(a)(l) and Section 2.
Page 17 of 22
Case 1:20-cr-00228-MHC-JKL     Document 158     Filed 02/08/21     Page 19 of 24

Case l:20-cr-00228-MHC-JKL Document 96 Filed 11/19/20 Page 18 of 22
FORFEITURE PROVISION
24. Upon conviction of one or more of the offenses alleged in Counts 1 through 6 of
this Indictment, the Defendants,
Maurice Fayne, a/k/a Arkansas Mo,
Daniel Eric Jay,
Michael D. Sargenf, and
MarkT.Sargent,
shall forfeit to the United States, pursuant to Title 18, United States Code, Section
982(a)(2), any property, real or personal, constituting or derived from proceeds
obtained, directly or indirectly, as a result of the violation, including, but not
lunited to, the following:
(a) Money Judgment:
• A sum of money m United States currency representing the amount of
proceeds obtained as a result of each offense, or conspiracy to commit
such offense, for which each Defendant is convicted.
(b) Currency and Bank Funds:
• $79,482.00 in United States Currency seized on May 1 1,2020.
• $319,113.11 in funds seized from United Community Bank account
number XXXXXXI408 held in the name of Flame Trucking Inc.
• $169,650.90 in funds seized from Wells Fargo Bank account number
XXXXXX0467 held in the name of C.W.
• $60,000.00 in funds seized from Sterling National Bank account
number XXXXX5233 held m the name of Lucky Star Licensing.
• $29,477.91 in funds seized from United Community Bank account
number XXXXXX2864 held in the name ofK.L.
• $15,195.62 in funds seized from Navy Federal Credit Union account
number XXXXXX1000 held in the name of Maurice Johnson Fayne.
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Case l:20-cr-00228-MHC-JKL Document 96 Filed 11/19/20 Page 19 of 22
• $14,169.57 in funds seized from Navy Federal Credit Union account
number XXXXXX0090 held in the name of Maurice Fayne.
• $9,362.47 m funds seized from United Community Bank account
number XXXXXX2299 held in the name ofP.C.
(c) Vehicles:
• $136,000.00 in fimds used as a down payment on, and iu lieu of, a 2019
RolIs-Royce Wraifh, VIN SCA665C53KUX87297.
• 2015 Kenworffa T-680 tmck, VIN 1XKYDP9X3PJ3 84332.
• 2015 Kenworth T-680 truck, VIN IXKYDP9XOFJ384367.
• 2015 Keaworth T-680 truck, VIN IXKYDP9X5FJ384364.
• 2015 Kenworth T-680 tmck, VIN 1XKYDP9X5PJ384350.
• 2015 Kenworth T-680 truck, VIN 1XKYDP9X5FJ384347.
• 2015 Kenworth T-680 truck, VIN 1XKYDP9X1FJ384362.
• 2015 Kenworth T-680 truck, VIN 1XKYDP9XXFJ384358.
• 2015 Kenworth T-680 truck, VIN 1XKYDP9XBFJ384343.
• 2015 Great Dane trailer, VIN 1GRAA062XFW70350L
• 2015 Great Dane trailer, VW 1 GRAA0620FW703748.
• 2015 Great Dane trailer, VW 1 GRAA0629FW703750.
• 2015 Great Dane trailer, VIN 1 GRAA0626FW703754.
• 2015 Great Dane trailer, VIN 1GRAA0621FW703743.
• 2015 Great Dane trailer, VIN 1GRAA0621FW703760.
(d) Personal Properly:
• One custom-made 18 kt Rolex 41 mm Presidential watch, serial number
5636S3S8, with diamonds, purchased on or about April 28,2020 for
$52,000.00.
• One 10 kt custom-made Cuban bracelet with 34.75 carats of diamonds,
purchased on or about April 28, 2020 for $24,500.00.
Page 19 of 22
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Case l:20-cr-00228-MHC-JKL Document 96 Filed 11/19/20 Page 20 of 22
• One 14 kt custom-made ring with 5.73 carats of diamonds, purchased on
or about April 28, 2020 for $3,750.00.
25. Upon conviction of one or more of the offenses alleged in Counts 7 through 19 of
this ladictment, the Defendant,
JVIaurice Fayne, a/k/aArkansas M'o,
shall forfeit to the United States pursuant to Titie 18, United States Code, Section
982(a)(l), all property real or personal, involved in such offenses and all property
traceable to such offenses, including but not limited to the following:
(a) Money Judgment:
• A sum of money in U. S. currency representing the value of the property
involved in the offenses for which the Defendant is convicted.
(b) Currency and Bank Funds :
• $79,482.00 in United States Currency seized on May 1 1,2020.
• $319,113.llm funds seized from United Community Bank account
number XXXXXX1408 held m the name of Flame Trucking Inc.
• $169,650.90 in fimds seized from Wells Fargo Bank account number
XXXXXX0467 held in the name ofC.W.
• $60,000.00 in funds seized from Sterling National Bank account
number XXXXX5233 held in the name of Lucky Star Licensing.
• $29,477.91 m funds seized from United Community Bank account
number XXXXXX2864 held m the name ofK.L.
• $15,195.62 in funds seized from Navy Federal Credit Union account
number XXXXXX1000 held in the name ofMaunce Johnson Fayne.
• $ 14,169.57 ia funds seized from Navy Federal Credit Union account
number XXXXXX0090 held in the name of Maurice Payne.
• $9,362.47 in fands seized from United Community Bank account
number XXXXXX2299 held in the name ofP.C.
Page 20 of 22
Case 1:20-cr-00228-MHC-JKL     Document 158     Filed 02/08/21     Page 22 of 24

Case l:20-cr-00228-MHC-JKL Document 96 Filed 11/19/20 Page 21 of 22
(c) Vehicles:
• $136,000.00 m funds used as a- down payment on, and in lieu of, a 2019
• Rolls-Royce Wraith, VDST SCA665C53KUX87297.
• 2015 Kenworth T-680 truck, VIN 1XKYDP9X3PJ3 84332.
• 2015 Kenworth T-680 truck, VIN 1XKYDP9XOFJ384367.
• 2015 Kenworth T-680 truck, VIN 1XKYDP9X5FJ384364.
• 2015 Kenworth T-680 truck, VDST 1XKYDP9X5FJ384350.
• 2015 Kenworth T-680 truck, VIN 1XKYDP9X5FJ3 84347.
• 2015 Kenworth T-680 truck, VIN 1XKYDP9X1FJ3 843 62.
• 2015 Kenworth T-680 truck, VIN 1XKYDP9XXFJ384358.
• 2015 Kenworth T-680 truck, VIN 1XKYDP9XBFJ3 84343.
• 2015 Great Dane trailer, VIN 1GRAA062XFW703501.
• 2015 Great Dane trailer, VIN 1GRAA0620FW703748.
• 2015 Great Dane trailer, VIN 1GRAA0629FW703750.
• 2015 Great Dane trailer, VIN 1GRAA0626FW703754.
• 2015 Great Dane trailer, VIN 1GRAA0621FW703743.
• 2015 Great Dane trailer, VEST 1GRAA0621FW703760.
(d) Personal Property:
• One custom-made 18 kt Rolex 41mm Presidential watch, serial number
5636S3S8, with diamonds, purchased on or about April 28, 2020 for
$52,000.00.
• One 10 kt custom-made Cuban bracelet with 34.75 carats of diamonds,
purchased on or about April 28, 2020 for $24,500.00.
• One 14 kt custom-made ring with 5.73 carats of diamonds, purchased on
or aboutApri! 28,2020 for $3,750.00.
26. If, as a result of any act or omission of the Defendant(s), any property subject to
forfeiture, (a) cannot be located upon the exercise of due diligence; (b) has been
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Case 1:20-cr-00228-MHC-JKL     Document 158     Filed 02/08/21     Page 23 of 24

Case l:20-cr-00228-MHC-JKL Document 96 Filed 11/19/20 Page 22 of 22
transferred or sold to, or deposited with, a third person; (c) has been placed beyond
the jurisdiction of the Court; (d) has been substantially dimmished in value; or (e)
has been commingled with other property which cannot be subdivided without
difficulty, the United States intends, pursuant to Title 21, United States Code,
Section 853(p), as incorporated by Title 18, United States Code, Section 982(b), to
seek forfeiture of any other property of the Defendants) up to the value of the
forfeitable property described above.
A 't^^ ^. _. BILL
^
^ ^^
FQ^PERSON
BYUNG J. PAK
UNITED STATES ATTORNEY
^w^ ^{^te? P&t&Ufis.
JOHN RUSSELL PHILLIPS
ASSISTANT UNITED STATES ATTORNEY
GEORGIA BAR No. 576335
^ew^'S. ffta^
BERNITA B. MALLOY
ASSISTANT UNITED STATES ATTORNEY
GEORGIA BAR No. 71 8905
'Wite^d^. 'SIMM
MICHAEL J. BROWN
ASSISTANT UNITED STATES ATTORNEY
GEORGIA BAR No. 064437
600 U.S. COURTHOUSE
75 TED TURNER DRIVE, SW
ATLANTA, GAS 03 03
(404)581-6000
Page 22 of 22
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