Second Superseding Indictment — United States v. Fayne

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Full text

FILED IN OPEN COURT
ORiGINAL
NOV 192020
JAMES N. FlATTEN, Clerk
By;
‘.3’
Deputy Clerk
IN THE UNITED STATES DISTRICT COURT~
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERICA
V.
INDICTMENT NUMBER
MAURICE FAYNE, a k a ARKANSAS Mo
1 :20-CR-228-MHC-JKL
DANIEL ERIC JAY
(SECOND SUPERSEDING)
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
MarkT. Sargent,
did knowingly and willfully combine, conspire, confederate, agree, and have a
tacit understanding with each other and with others known and unknown to the
Grand Jury to devise and intend 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 in violation
ofTitle 18, United States Code, Section 1343.

2.
At all times relevant to this Indictment, Defendant Fayne operated a small,
unprofitable trucking company. He frequently changed the name of the company
and its address in an effort to avoid the IRS and other creditors and to stay one step
ahead of the government agencies that regulated the 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 CONSPIRACY
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 Fayne asked the other Defendants to help him recruit people to
invest in his trucking company. The other Defendants agreed.
(b)
During the course of the conspiracy, the Defendants caused more than 20
people to invest money in Defendant Fayne’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 Match.com and Plenty of Fish (POF.com).
Page 2 of 22

(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 that 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 true.
(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 information would be viewed
online by investors and others who were checking up on his trucking
company.
(g)
Also, the Defendants told investors a variety of lies. For example, the
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
Page 3 of 22

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 in frill, 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.
(j)
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”
information concerning the status of the contract approval process.
Page 4 of 22

(k)
Furthermore, the Defendants sent investors phony text messages from
someone posing as M.B. and someone posing as T.M., a nonexistent
Walmart 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 from discovering the truth about the phony Walmart
deal, the Defendants told investors not to contact Walmart directly. The
Defendants falsely claimed that secrecy was necessary because Walmart
would cancel the contract if it found out that one of its executives had
invested in Defendant Fayne’s trucking 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.”
PageS of 22

•
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
an[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 “flys 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.] is bluffing 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
either.
(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 flirther that illusion, the Defendants
sent investors a fraudulently altered bank record, which overstated the
amount of money in the 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.
Page 6 of 22

(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 trucks 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 trucking company appear legitimate, and to lull investors into a
false sense of security and delay or prevent their 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 oftheir 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 find 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 during 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.
Page 7 of 22

COUNTS 2-4
WWE Fi~un
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/a Arkansas Mo,
Daniel Eric Jay,
Michael D. Sargent and
Mark T. Sargent
aided and abetted by each other and by others known and unknown to the 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 following writings, signs, signals, pictures, and sounds for the
purpose of executing such scheme and artifice:
Count
Date
Description
2
04-23-20
$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 the
name of T.V.
Page 8 of 22

Count
Date
Description
3
04-24-20
$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 B. Jay
4
05-01-20
$25,000 wire transfer from United Community Bank
account #1408, held in the name of Flame Trucking Inc.,
to Bank ofAmerica, N.A., account #285 1, held in the
name of Michael Sargent
All in violation of Title 18, United States Code, Section 1343 and Section 2.
COUNT 5
BANK Fi~uu
8.
From in or about April 2020 through 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 finds 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 Fayne was the sole
owner of a Georgia corporation called Flame Trucking Inc.
Page 9 of 22

10.
United Community Bank participated as a lender in the Paycheck 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-l9 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 conspiracy described in Count 1 of this Indictment. Defendant Jay later said
to Defendant Fayne: “{I]f we can somehow justif~v 100+ drivers on 1099 for Flame
we have something[.j” 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 ofpeople who were
Page 10 of 22

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 FUIC
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 theaccounts of which were insured by the
Federal Deposit Insurance Corporation, in connection with Flame Trucking’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 Trucking’s account at Arvest Bank, when in truth and in
fact—as Defendant Fayne knew—those bank statements were phony, because
Arvest Bank had shut down Flame Trucking’s account in September 2019.
All in violation of Title 18, United States Code, Section 1014 and Section 2.
Page 11 of 22

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 Trucking’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 Trucking’s PPP loan application, Defendant Fayne acknowledged
that he could be prosecuted for fraud if the PPP loan proceeds were
“knowingly 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 jewelry;
•
paying child support; and
•
leasing a Rolls-Royce.
(d)
In or around mid-March 2020, Defendant Fayne contacted one 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
Page 12 of 22

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 about April 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 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
conducted and attempted to conduct a financial transaction affecting interstate
commerce, which involved the proceeds of a specified unlawifil activity, that is
bank fraud, in violation ofTitle 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 the proceeds of specified
unlawful activity, and while conducting and attempting to conduct such financial
Page 13 of 22

transaction knowing that the property involved in the financial transaction
represented the proceeds of some form of unlawfUl activity;
Count
Date
Description
7
04-23-20
Defendant Fayne caused $60,000 in PPP loan proceeds to be
wire transferred from Navy Federal Credit Union, account
#60 82, held in the name of T.V., to Sterling National Bank
account #5233, held in the name of Lucky Star Licensing.
8
04-23~20
Defendant Fayne caused $60,000 in PPP loan proceeds to be
wire transferred from Navy Federal Credit Union, account
#6082, held in the name of T.V., to JPMorgan Chase Bank
account #1572, held in the name of Sonoran HomeWatch LLC.
9
04-24-20
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 of J.S.
10
04-27-20
Defendant Fayne caused J.S. to purchase a $50,000 cashier’s
check payable to the DeSha County (Arkansas) Sheriff’s
Office, to pay restitution owed by Defendant Fayne.
11
04-23-20
Defendant Fayne caused $3 50,000 in PPP loan proceeds to be
wire transferred from United Community Bank account #1408,
held in the name of Flame Trucking Inc., to Wells Fargo Bank,
NA account #0467, held in the name of C.W.
12
04-28-20
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 ofAmerica, New York, NY
account #9593, held in the name of Status Jewelers, to
purchase three pieces of jewelry for Defendant Fayne.
13
04-30-20
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 the name of S.T., to pay child support
owed by Defendant Fayne.
14
04~28-20
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.
Page 14 of 22

Count
Date
Description
15
04-30-20
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 in the name ofMaurice
Fayne.
16
05-01-20
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 #46 12, 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, including 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 Trucking, LLC.
(b)
The next day, on or about April 23, 2020—on behalf of C.R. Wilkins
Trucking, LLC—C.W. signed a contract to purchase eight Kenworth T-680
trucks from TransAm Trucking, for a total of $368,000.
(c)
Also on or about April 23, 2020—on behalfofC.R. Wilkins Trucking,
LLC—C.W. signed a contract to purchase six refrigerated trailers from
Great Dane, LLC, for a total of $189,000.
Page 15 of 22

21.
On or about each date set forth below, 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
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 than $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
Date
Description
17
04-23-20
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 TIME
Bank, N.A. account #6 105, held in the name of TransArn
Trucking Exchange, to purchase eight Kenworth T-680 trucks
for C.R. Wilkins Trucking, LLC.
18
04-23-20
Defendant Fayne caused $189,000 in PPP loan proceeds to be
wire transferred from United Community Bank account
#1408, held in the name of Flame Trucking Inc., to JPMorgan
Chase Bank, NA account #2 162, held in the name of Great
Dane LLC, to purchase six refrigerated trailers for C.R.
Wilkins Trucking, LLC.
19
04-27-20
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.
Page 16 of 22

COUNT 20
AGGRAVATED IDENTITY THEFT
22.
The facts alleged in paragraphs 2 through 5, including all subparts, are
incorporated here.
23.
From in or about October 2018 through in or about July 2019, 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
possessed and used, without lawfhl authority, the means of identification of
another person, namely the name and signature of D.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 in violation of Title 18, United States Code, Section 1028A(a)(1) and Section 2.
Page 17 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 B. Sargent, 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
limited to, the following:
(a)
Money Judgment:
•
A sum of money in 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 11, 2020.
•
$319,113.11 in fUnds seized from United Community Bank account
number XXXXXX1408 held in the name of Flame Trucking Inc.
•
$169,650.90 in funds seized from Wells Fargo Bank account number
XXXXXXO467 held in the name of C.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 in funds seized from United Community Bank account
number XXXXXX2864 held in the name of K.L.
•
$15,195.62 in funds seized from Navy Federal Credit Union account
number XXXXXX1000 held in the name of Maurice Johnson Fayne.
Page 18 of 22

•
$14,169.57 in funds seized from Navy Federal Credit Union account
number XXXXXXO090 held in the name of Maurice Fayne.
•
$9,362.47 in funds seized from United Community Bank account
number XXXXXX2299 held in the name of P.C.
(c)
Vehicles:
•
$136,000.00 in funds used as a down payment on, and in lieu of, a 2019
Rolls-Royce Wraith, VIE SCA665C53KUX87297.
•
2015 Kenworth 1-680 truck, VIE 1XKYDP9X3FJ384332.
•
2015 Kenworth 1-680 truck, VIN IXKYDP9XOFJ384367.
•
2015 Kenworth 1-680 truck, VIE 1XKYDP9X5FJ384364.
•
2015 Kenworth 1-680 truck, VIE 1XKYDP9X5FJ384350.
•
2015 Kenworth T-680 truck, VIE 1XKYDP9X5FJ384347.
•
2015 Kenworth T-680 truck, VIE 1XKYDP9X1FJ384362.
•
2015 Kenworth T-680 truck, VIE 1XKYDP9XXFJ384358.
•
2015 Kenworth T-680 truck, VIE 1XKYDP9XBFJ384343.
•
2015 Great Dane trailer, VIE 1GRAAO62XFW7O35O1.
•
2015 Great Dane trailer, VIE 10RAA0620FW703748.
•
2015 Great Dane trailer, V~IN 10RAA0629FW703750.
•
2015 Great Dane trailer, VIM 10RAA0626FW703754.
•
2015 Great Dane trailer, VIM 1GRAA0621FW703743.
•
2015 Great Dane trailer, ViE 10RAA0621FW703760.
(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.
Page 19 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 Indictment, the Defendant,
Maurice Fayne, a/k/a Arkansas Mo,
shall forfeit to the United States pursuant to Title 18, United States Code, Section
982(a)(1), 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 11,2020.
•
$3 19,113.11 in hinds seized from United Community Bank account
number XXXXXX14O8 held in the name of Flame Trucking Inc.
•
$169,650.90 in hands seized from Wells Fargo Bank account number
XXXXXXO467 held in the name of C.W.
•
$60,000.00 in hinds seized from Sterling National Bank account
number XXXXX5233 held in the name of Lucky Star Licensing.
•
$29,477.91 in hinds seized from United Community Bank account
number XXXXXX2864 held in the name of K.L.
•
$15,195.62 in hinds seized from Navy Federal Credit Union account
number XXXXXX1000 held in the name of Maurice Johnson Fayne.
•
$14,169.57 in funds seized from Navy Federal Credit Union account
number XXXXXXOO9O held in the name of Maurice Payne.
•
$9,362.47 in hinds seized from United Community Bank account
number XXXXXX2299 held in the name of RC.
Page 20 of 22

(c)
Vehicles:
•
$136,000.00 in flinds used as a down payment on, and in lieu ot a 2019
Rolls-Royce Wraith, VIN SCA665C53KUX87297.
•
2015 Kenworth 1-680 truck, VIN 1XKYDP9X3FJ384332.
•
2015 Kenworth 1-680 truck, VIN 1XKYDP9XOFJ384367.
•
2015 Kenworth 1-680 truck, VIM 1XKYDP9X5FJ384364.
•
2015 Kenworth 1-680 truck, VIN 1XKYDP9X5FJ38435O.
•
2015 Kenworth 1-680 truck, VIM 1XKYDP9X5FJ384347.
•
2015 Kenworth 1-680 truck, VIN 1XKYDP9X1FJ3 84362.
•
2015 Kenworth 1-680 truck, VIN 1XKYDP9XXFJ3 84358.
•
2015 Kenworth 1-680 truck, VIM 1XKYDP9XBFJ3 84343.
•
2015 Great Dane trailer, VIN 1GRAAO62XFW7O35O1.
•
2015 Great Dane trailer, VIN 1GRAA0620FW703748.
•
2015 Great Dane trailer, VIN 1GRAA0629FW703750.
•
2015 Great Dane trailer, VIM 1GRAA0626FW703754.
•
2015 Great Dane trailer, VIN 1GRAA0621FW703743.
•
2015 Great Dane trailer, VIN 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 about April 28, 2020 for $3,750.00.
26.
If, as a result of any act or omission ofthe Defendant(s), any property subject to
forfeiture, (a) cannot be located upon the exercise of due diligence; (b) has been
Page 21 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 diminished 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 Defendant(s) up to the value of the
forfeitable property described above.
A
tR,cJz~
BILL
/s6Q
FQ~EPERSON
BYLING J. PAK
UNITED STATES ATTORNEY
~1’& a~s€a
JOHN RUSSELL PHILLIPS
ASSISTANT UNITED STATES ATTORNEY
GEORGIA BAR No. 576335
BERNITA B. MALLOY
ASSISTANT UNITED STATES ATTORNEY
GEORGIA BAR No.718905
?P4cAad f2. &oeun
MICHAEL J. BROWN
ASSISTANT UNITED STATES ATTORNEY
GEORGIA BAR No. 064437
600 U.S. COURTHOUSE
75 TED TURNER DRIVE, SW
ATLANTA, GA 30303
(404) 581-6000
Page 22 of 22

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