Court filing
Second Superseding Indictment — United States v. Pidlossaint (Dkt. 107, S.D. Fla.)
Summary
A second superseding indictment in United States v. Joff Stenn Wroy Philossaint, Mariel Tollinchi, Regine Marie Rene, Brianna Monique Gayle, Maurice Shazier and Robenson Lauvince, in the U.S. District Court for the Southern District of Florida, entered December 15, 2022 in Case 9:22-cr-80144-RS as Document 107. It describes the Paycheck Protection Program, including loans to sole proprietorships applied for online through lender platforms, as background to its charges. The statutes cited include conspiracy (18 U.S.C. § 1349), money laundering conspiracy (18 U.S.C. § 1956(h)), wire fraud (18 U.S.C. § 1343), aggravated identity theft and 18 U.S.C. § 1425(a). It runs 30 pages.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Filed December 15, 2022 in Joff Stenn Wroy Pidlossaint; one of 110 filings from this case.
Record facts
| Court | U.S. District Court for the Southern District of Florida |
|---|---|
| Filed | 2022-12-15 |
Cite this document
“Second Superseding Indictment — United States v. Pidlossaint (Dkt. 107, S.D. Fla.).”
U.S. District Court for the Southern District of Florida, No. 9:22-cr-80144, Doc. 107, filed 2022-12-15. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/us-v-joff-stenn-wroy-philossaint/2022-12-15-second-superseding-indictment-dkt-107/
, SHA-256 38c9d740d097a7d304789bb1e1e7ff6ffafcbdae01ce7f0b8092c53088f1e091.Full text
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 1 of 30
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. ---=22=--....;:;:C=R=----8=0=1--=-44.;:_-=SMI=T=H/MA==-=Y.;;..;N=ARD=""'"{s"""')"""{s.,_)_ __
18 u.s.c. § 1349
18 U.S.C. § 1956(h)
18 U.S.C. § 1425(a)
18 u.s.c. § 1343
18 U.S.C. § 1028A(a)(l)
18 U.S.C. § 1956(a)(l)(B)(i)
18 U.S.C. § 1956(a)(2)(B)(i)
18 u.s.c. § 1957
18 U.S.C. § 982(a)
UNITED STATES OF AMERICA
vs.
JOFF STENN WROY PIDLOSSAINT,
MARIEL TOLLINCHI,
REGINE MARIE RENE, DEC 15 2022
BRIANNA MONIQUE GAYLE, ANGELA E. NOBLE
CLERK U.S . DIST. CT.
MAURICE SHAZIER, and S.D. OF FLA . - W.P.8.
ROBENSON LAUVINCE,
Defendants.
- - - - - - - - - - - - - - -I
SECOND SUPERSEDING INDICTMENT
The Grand Jury charges that:
GENERAL ALLEGATIONS
At all times material to this Second Superseding Indictment:
The Paycheck Protection Program
1. The Coronavirus A id , Relief, and Economic Security ("CARES") Act was a federal
law enacted in or around March 2020 and designed to provide emergency financial assistance to
the millions of Americans who were suffering the economic effects caused by the COVID-19
pandemic. One source of relief provided by the CARES Act was the authorization of forgivable
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 2 of 30
loans to small businesses for job retention and certain other expenses, through a program referred
to as the Paycheck Protection Program ("PPP").
2. The types of businesses eligible for a loan included sole proprietorships. In order to
obtain a PPP loan, a qualifying business (through its authorized representative or the sole
proprietor) signed and submitted a PPP loan application (Small Business Administration ("SBA")
Form 2483) online through the lender's application platform. In order to be eligible to obtain the
PPP loan, the PPP loan application required the business (through its authorized representative or
the sole proprietor) to acknowledge the program rules and make certain affirmative certifications.
The certifications included an attestation that the business was in operation on February 15, 2020,
and had employees for whom it paid salaries and payroll taxes, or paid independent contractors,
or was a sole proprietorship with no employees. In the PPP loan application, the small business
(through its authorized representative or the sole proprietor) was required to provide, among other
things, its average monthly payroll expenses and number of employees. In addition, businesses
applying for the PPP loan were required to provide documentation confirming their payroll
expenses. Typically, businesses supplied documents showing the amount of payroll taxes reported
to the Internal Revenue Service ("IRS"). The sole proprietorship had to report and document the
business ' income and expenses, as typically reported to the IRS on Fo1m 1040, Schedule C. These
figures and documentation were used to calculate the amount of money the small business was
eligible to receive under the PPP. Sole proprietorships were eligible to receive a maximum PPP
loan of up to $20,833 to cover lost income.
3. A PPP loan application was processed by a participating lender. The SBA delegated
authority to third-party lenders to underwrite and approve the loans. If a PPP loan app lication was
approved, the participating lender funded the PPP loan using its own monies, which were 100%
2
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 3 of 30
guaranteed by the SBA. Data from the application, including information about the borrower, the
total amount of the loan, and the listed number of employees, was transmitted electronically by
the lender to the SBA in the course of processing the loan.
4. PPP loan proceeds were required to be used by the business on certain permissible
expenses - payroll costs, interest on mortgages, rent, and utilities. The PPP allowed the interest
and principal on the PPP loan to be entirely forgiven if the business spent the loan proceeds on
these expense items within a designated period of time and used a defined portion of the PPP loan
proceeds on payroll expenses.
The Economic Injury Disaster Loan Program
5. Before the COVID-19 pandemic, SBA' s Economic Injury Disaster Loan ("EIDL")
program provided low-interest financing to small businesses, renters, and homeowners in regions
affected by declared disasters.
6. The CARES Act also authorized the SBA to provide EIDL assistance to eligible
small businesses experiencing "substantial economic injury" (substantial financial disruptions)
due to the COVID-19 pandemic. In order to obtain a COVID-19 EIDL, a qualifying business was
required to submit electronically an EIDL application to the SBA and provide information about
its operations, such as the number of employees, gross revenues, and the cost of goods sold for the
12-month period preceding January 31 , 2020. The applicant was also required to certify under
penalty of perjury that all of the information in the EIDL application was true and correct to the
best of the applicant' s knowledge. Before receiving a loan, a borrower was required to sign a Loan
Authorization and Agreement. Pursuant to that agreement, it was a condition of the loan that the
borrower would use the loan solely as working capital to alleviate economic injury caused by a
disaster occurring in January 2020 and continuing thereafter.
3
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 4 of 30
7. EIDL applications were subm itted directly to, and processed by, the SBA, with
support from a government contractor. EIDL funds were issued directly from the United States
Treasury.
8. In addition, the CARES Act authorized the SBA to issue advances of up to $10,000
to small businesses within three days of applying for an EIDL. The amount of the advance was
determined by the number of employees the applicant certified having at the small business. The
advances did not have to be repaid.
9. SBA' s email and loan application servers were located outside the State of Florida,
so wire communications between banks and the SBA and between EIDL applicants located within
Florida and the SBA necessarily traveled in interstate commerce.
The Defendants, Businesses, and Lenders
10. Defendant JOFF STENN WROY PHILOSSAINT was a resident of Broward and
Miami-Dade Counties, in the Southern District of Florida.
11. Defendant MARIEL TOLLINCHI was a resident of Broward County, m the
Southern District of Florida.
12. Defendant REGINE MARIE RENE was a resident of Palm Beach County, in the
Southern District of Florida.
13 . Defendant BRIANNA MONIQUE GAYLE was a resident of Palm Beach and
Miami-Dade Counties, in the Southern District of Florida.
14. Defendant MAURICE SHAZIER was a resident of St. Lucie County, in the Southern
District of Florida.
15. Defendant ROB ENSON LAUVINCE was a resident of Broward County, in the
Southern District of Florida.
4
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 5 of 30
16. Co-conspirator David Andre Johnson was a resident of Broward County, in the
Southern District of Florida.
17. Defendant JOFF STENN WROY PHILOSSAINT was the principal and registered
agent of Royal Elite Trans, LLC ("ROY AL ELITE"), Elite International Financial Group, a/k/a
Elite International Venture Capital ("EIVC"), and One Solution Group LLC ("ONE
SOLUTION"), purported businesses located in Broward County, in the Southern District of
Florida.
18. Defendant MARIEL TOLLINCHI was the Treasurer of the Cinda Foundation Inc.
("CINDA"), and her family members were the principals and registered agents of CINDA, Ferro ' s
Entertainment and Production LLC ("FERRO'S"), and D.F. d/b/a "Perfect Landscaping"
("PERFECT LANDSCAPING"), purported businesses located in Broward County, in the
Southern District of Florida. TOLLINCHI was also the principal of Tollinchi Law P.A.
("TOLLINCHI LAW"), a law firm located in Broward County, in the Southern District of Florida.
19. Defendant JOFF STENN WROY PHILOSSAINT was the president and registered
agent of Dad Money Investment Group, LLC ("DAD MONEY"), a purported business located in
Broward County, in the Southern District of Florida.
20. Defendant REGINE MARIE RENE was the principal and registered agent of Unfold
Perception, LLC (" UNFOLD"), a purported business located in Palm Beach County, in the
Southern District of Florida.
21. Defendant BRIANNA MONIQUE GAYLE was an employee of EIVC and
purportedly owned a sole proprietorship in her name located in Palm Beach County, in the
Southern District of Florida.
5
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 6 of 30
22. Defendant MAURICE SHAZIER was the principal and registered agent of Sunrise
City Construction Development LLC (" SUNRJSE CITY") and JREAM Vision T.V. LLC
("JREAM"), purported businesses located in St. Lucie County, in the Southern District of Florida.
23. Defendant ROBENSON LAUVINCE was the principal and the registered agent of
Clear Shot Entertainment LLC ("CLEAR SHOT"), a purported business located in Broward
County, in the Southern District of Florida.
24. Co-conspirator David Andre Johnson was the principal and registered agent of
D.D.Z. Family Enterprises L.L.C. ("DDZ"), a purported business located in Broward County, in
the Southern District of Florida.
25. Lender #1 was headquartered in New Jersey and was an approved SBA lender for
PPP loans.
26. Lender #2 was headquartered in Delaware and was an approved SBA lender for PPP
loans.
27. Lender #3 was headquartered in Utah and was an approved SBA lender for PPP
loans.
COUNT 1
(Conspiracy to Commit Wire Fraud: 18 U.S.C. § 1349)
Paragraphs 1 through 27 of the General Allegations Section of this Second Superseding
Indictment are re-alleged and incorporated by reference as though fully set forth herein.
From in or around April 2020, continuing through on or about August 7, 2022 , the exact
dates being unknown to the Grand Jury, in Palm Beach, St. Lucie, Broward, and Miami-Dade
Counties, in the Southern District of Florida, and elsewhere, the defendants,
6
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MARIEL TOLLINCHI,
REGINE MARIE RENE,
BRIANNA MONIQUE GAYLE,
MAURICE SHAZIER, and
ROBENSON LAUVINCE,
and Joff Stenn Wroy Philossaint did wi llfully, that is, with the intent to further the object of the
conspiracy, and knowingly combine, conspire, co nfederate, and agree w ith each other and with
persons known and unknown to the Grand Jury, to knowingly, and w ith the intent to defraud,
devise, and intend to devise, a scheme and artifice to defraud, and to obtain money and property
by means of materially false and fraudulent pretenses, representations, and promises, knowing that
the pretenses, representations, and promises were fal se and fraudulent when made, and, for the
purpose of executing such scheme and artifice, did transmit and cause to be transmitted, by means
of wire communications in interstate and foreign commerce, certain writings, signs, signals,
pictures, and sounds, in vio lation of Title 18, United States Code, Section 1343.
OBJECT OF THE CONSPIRACY AND THE SCHEME AND ARTIFICE
It was the object of the conspiracy and of the scheme and artifice for the Defendants and
their co-conspirators to unlawfully enrich them selves by, among other things: (1) creating false
and fraudulent documents, including payroll records and tax documents ; (2) subm itting and
causing the submission of fa lse and fraudulent app lications for loans and loan agreements made
avai lable through the SBA to provide relief for the economic effects caused by the COVlD-19
pandemic, including EIDL and PPP loans; (3) offering, paying, and receiving kickbacks in return
for causing the submi ssion of false and fraudulent loan app lications; (4) diverting fraud proceeds
for the Defendants ' and co-conspirators' personal use and benefit, the use and benefit of others,
and to further the conspiracy and the scheme and artifice; and (5) subm itting and causing the
submission of false and fraudulent applications for forgiveness of the received loans.
7
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MANNER AND MEANS
The manner and means by w hich the defendants and their co-conspirators sought to
accomplish the object of the conspiracy and the scheme and artifice included, among others, the
following:
(a) Joff Stenn Wroy Philossaint and BRIANNA MONIQUE GAYLE created
and caused the creation of false and fraudulent tax documents for business entities owned and
controlled by themselves, MARIEL TOLLINCHI, REGINE MARIE RENE, MAURICE
SHAZIER, ROBENSON LAUVINCE, David Andre Johnson, and others known and unknown to
the Grand Jury, for the purpose of applying for PPP and EIDL loans.
(b) Joff Stenn Wroy Philossaint, MARIEL TOLLINCHI, REGINE MARIE
RENE, BRIANNA MONIQUE GAYLE, MAURICE SHAZIER, ROBENSON LA UV INCE,
David Andre Johnson , and others known and unknown to the Grand Jury submitted and caused
the submission of false and fraudulent PPP and EIDL loan appl ications and loan agreements.
(c) The PPP and EIDL loan applications and agreements submitted, or caused
to be submitted, by Joff Stenn Wroy Philossaint, MARIEL TOLLINCHI, REGINE MARIE
RENE, BRIANNA MONIQUE GAYLE, MAURICE SHAZIER, ROBENSON LAUVINCE,
David Andre Johnson, and others known and unknown to the Grand Jury included false and
fraudulent tax documents and made false and fraudulent representations about the borrowing
entities ' number of employees, amount of monthly payro ll , gross income, cost of goods sold, and
the purposes for which the loans would be used.
(d) Joff Stenn Wroy Philossaint and BRIANNA MONIQUE GAYLE created
and caused the creation of false and fraudulent payroll accounts with a payroll processing service
for business entities owned and controlled by them selves, MARIEL TOLLINCHI, REGINE
8
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 9 of 30
MARIE RENE, MAURICE SHAZIER, ROBENSON LAUVINCE, David Andre Johnson, and
others known and unknown to the Grand Jury, for the purpose of applying for PPP loans and PPP
loan forgiveness.
(e) Having obtained PPP loans for those entities, Joff Stenn Wray Philossaint,
MARIEL TOLLINCHI, REGINE MARIE RENE, BRIANNA MONIQUE GAYLE, MAURICE
SHAZIER, ROBENSON LAUVINCE, David Andre Johnson, and others known and unknown to
the Grand Jury caused the electronic wire transfer of a portion of the loan proceeds to a payroll
processing service to make it appear that the proceeds were being used for legitimate payro ll
expenses.
(f) Having obtained PPP and EIDL loans for their business entities, Joff Stenn
Wray Philossaint caused MARIEL TOLLINCHI, REGINE MARIE RENE, BRIANNA
MONIQUE GAYLE, MAURICE SHAZIER, ROBENSON LAUVINCE, David Andre Johnson ,
and others known and unknown to the Grand Jury to pay kickbacks of approximately 10% of the
loans ' values to Joff Stenn Wray Philossaint via checks and wire transfers that were often disguised
to appear to be legitimate business expenses.
(g) Joff Stenn Wray Philossaint, MARIEL TOLLINCHI, REGINE MARIE
RENE, BRIANNA MONIQUE GAYLE, MAURICE SHAZIER, ROBENSON LAUVINCE,
David Andre Johnson, and others known and unknown to the Grand Jury submitted and caused
the submission of false and fraudulent applications for PPP loan forgiveness for these business
entities.
(h) As a result of the false and fraudulent representations that Joff Stenn Wray
Philossaint, MARIEL TOLLINCHI, REGINE MARIE RENE, BRIANNA MONIQUE GAYLE,
MAURICE SHAZIER, ROBENSON LAUVINCE, David Andre Johnson, and others known and
9
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 10 of 30
unknown to the Grand Jury made in the PPP and EIDL loan applications submitted as part of this
scheme, financial institutions and the SBA disbursed loan proceeds to the Defendants and their co-
conspirators in the amount of approximately $8 .1 million .
All in violation of Title 18, United States Code, Section 1349.
COUNT2
(Conspiracy to Commit Money Laundering: 18 U.S.C. § 1956(h))
From in or around April 2020, continuing through on or about August 7, 2022, the exact
dates being unknown to the Grand Jury, in Palm Beach, St. Lucie, Broward , and Miami-Dade
Counties, in the Southern District of Florida, and elsewhere, the defendants,
MARIEL TOLLINCHI,
REGINE MARIE RENE,
BRIANNA MONIQUE GAYLE,
MAURICE SHAZIER, and
ROBENSON LAUVINCE,
and Joff Stenn Wray Philossaint did knowingly and voluntarily combine, conspire, confederate,
and agree with each other, and with persons known and unknown to the Grand Jury, to knowingly
conduct, and attempt to conduct, a financial transaction affecting interstate and foreign commerce
involving the proceeds of specified unlawful activity, knowing that the property involved in the
transaction represented the proceeds of some form of unlawful activity, and 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 said specified unlawful activity, in violation of 18 U.S.C.
§ 1956(a)(l)(B)(i).
It is further alleged that the specified unlawful activity is wire fraud , in violation of 18
U.S.C. § 1343.
All in violation of Title 18, United States Code, Section 1956(h).
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 11 of 30
COUNT3
(Conspiracy to Commit Money Laundering: 18 U.S.C. § 1956(h))
From in or around April 2020, continuing through on or about August 7, 2022, the exact
dates being unknown to the Grand Jury, in Palm Beach, St. Lucie, Broward, and Miami-Dade
Counties, in the Southern District of Florida, and elsewhere, the defendant,
MARIEL TOLLINCHI,
and Joff Stenn Wroy Philossaint did knowingly and voluntarily combine, conspire, confederate,
and agree with each other and with persons known and unknown to the Grand Jury, to:
(a) knowingly transmit and transfer monetary instruments and funds, from a
place inside the United States to and through a place outside the United States, knowing that the
monetary instruments and funds involved in such transmission and transfer represented the
proceeds of some form of unlawful activity, and knowing that such transmission and transfer 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, in violation of 18 U.S.C. § l 956(a)(2)(B)(i);
and
(b) knowingly engage in a monetary transaction by, through, and to a financial
institution, affecting interstate and foreign commerce, in criminally derived property of a value
greater than $10,000 that is derived from specified unlawful activity, in violation of 18 U.S.C.
§ 1957.
It is further alleged that the specified unlawful activity is wire fraud , in vio lation of 18
U.S.C. § 1343.
All in violation of Title 18, United States Code, Section 1956(h).
11
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 12 of 30
COUNT4
(Obtaining Citizenship by Fraud: 18 U.S.C. § 1425(a))
Paragraphs 1 through 9 of the General Allegations Section of this Superseding Indictment
are re-alleged and incorporated by reference as though fully set forth herein.
Beginning at least as early as December 15 , 2020, and continuing through on or about
February 9, 2021 , in Broward and Miami-Dade Counties, in the Southern District of Florida, and
elsewhere, the defendant,
JOFF STENN WROY PHILOSSAINT,
did knowingly procure and attempt to procure, contrary to law, naturalization as a United States
citizen for himself, to wit, the defendant obtained and attempted to obtain naturalization by falsely
swearing to a statement in his written Form N-400 (Application for Naturalization), his
naturalization interview, and his written Form N-455 (Notice of Naturalization Oath Ceremony),
that:
(a) he had not knowingly committed, assisted in committing, or attempted to
commit, a crime or offense for which he had not been arrested, when in truth and in fact, as the
defendant then and there well knew, he had committed the offenses of wire fraud conspiracy, and
money laundering conspiracy, as charged in Counts 1 through 3 of this Second Superseding
Indictment; and
(b) he had not made any misrepresentation to obtain any public benefit in the
United States, when in truth and in fact, as the defendant then and there well knew, he had
misrepresented businesses, their earnings, and their employee workforces in an effort to obtain
multiple loans and advances, and forgivene ss of those loans and advances pursuant to the United
States ' Paycheck Protection Program and the Economic Injury Disaster Loan Program.
All in violation of Title 18 , United States Code, Section 1425(a).
12
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 13 of 30
COUNTS 5-25
(Wire Fraud: 18 U.S.C. § 1343)
The General Allegations Section of this Second Superseding Indictment is re-alleged and
incorporated by reference as though fully set forth herein.
From in or around April 2020, continuing through on or about August 7, 2022, the exact
dates being unknown to the Grand Jury, in Palm Beach, St. Lucie, Broward, and Miami-Dade
Counties, in the Southern District of F lorida, and elsewhere, the defendants,
MARIEL TOLLINCHI,
REGI E MARIE RENE,
BRIANNA MONIQUE GAYLE,
MAURICE SHAZIER, and
ROBENSON LAUVINCE,
did knowingly, and with the intent to defraud, devise, and intend to devise, a scheme and artifice
to defraud, and to obtain money and property by means of materially fa lse and fraudulent
pretenses, representations, and promises, knowing that the pretenses, representations, and
promises were false and fraudulent when made, and, for the purpose of executing such scheme and
artifice, did transmit and cause to be transmitted, by means of wire communications in interstate
and foreign commerce, certain writings, signs, signals, pictures, and sounds, in violation of Title
18, United States Code, Section 1343.
OBJECT OF THE SCHEME AND ARTIFICE
The section of Count 1 of this Second Superseding Indictment entitled "Object of the
Conspiracy and the Scheme and Artifice" is realleged and incorporated by reference as though
fully set forth herein to describe the object of the scheme and artifice.
13
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 14 of 30
THE SCHEME AND ARTIFICE
The section of Count 1 of this Second Superseding Indictment entitled "Manner and
Means" is realleged and incorporated by reference as though fully set forth herein to describe the
manner and means of the scheme and artifice.
USE OF WIRES
On or about the dates specified as to each count below, in Palm Beach , St. Lucie, Broward,
and Miami-Dade Counties, in the Southern District of Florida, and elsewhere, the specified
defendants, for the purpose of executing and in furtherance of the aforesaid scheme and artifice to
defraud, and to obtain money and property by means of materially false and fraudulent pretenses,
representations, and promises, knowing that the pretenses, representations, and promises were
false and fraudulent when made, did knowingly transmit and cause to be transmitted, by means of
wire communications in interstate and foreign commerce, certain writings, signs, signals, pictures,
and sounds, as described below:
Count Date Defendants Interstate Wire
5 6/ 15/2020 ROBENSON Electronic submission of PPP loan application
LAUVINCE to Lender #3 on behalf of CLEAR SHOT
6 6/18/2020 REGINE MARIE E lectronic submi ssion of PPP loan application
RENE to Lender #3 on behalf of UNFOLD
7 7/8/2020 ROBENSON Electronic transmission of loan agreement,
LAUVINCE note, and related documents to SBA on behalf
of CLEAR SHOT
8 7/ 13/2020 MARIEL Electronic submi ssion of EIDL application to
TOLLINCHI SBA on behalf of PERFECT
LANDSCAPING
9 7/ 16/2020 MAURICE E lectronic submission of EIDL application to
SHAZIER SBA on behalf of SUNRISE CITY
10 7/21/2020 MARIEL E lectronic submission of EIDL application to
TOLLINCHI SBA on behalf ofFERRO ' S
11 7/31 /2020 MAURICE E lectronic submi ssion of EIDL app lication to
SHAZIER SBA on behalf of JREAM
14
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 15 of 30
Count Date Defendants Interstate Wire
12 8/2/2020 REGINE MARIE Electronic submission ofEIDL app lication to
RENE SBA on behalf of UNFOLD
13 8/5/2020 MAURICE Electronic transmission of loan agreement,
SHAZIER note, and related documents to SBA on behalf
of SUNRISE CITY
14 2/12/202 1 MAURICE Electronic submission of PPP loan application
SHAZIER to Lender #1 on behalf of SUNRISE CITY
15 2/12/2021 MAURICE Electronic submission of PPP loan application
SHAZIER to Lender # 1 on behalf of JREAM
16 2/14/202 1 BRIANNA Electronic submission of PPP loan application
MONIQUE to Lender #2 on behalf of BRIANNA
GAYLE MONIQUE GAYLE
17 2/14/202 1 ROBENSON Electronic transmission of loan agreement,
LAUVINCE note, and related documents to Lender #2 on
behalf of CLEAR SHOT
18 2/15/202 1 MARIEL E lectronic submission of PPP loan application
TOLLINCHI to Lender #2 on behalf of CINDA
19 2/22/202 1 REGINE MARIE Electronic submission of PPP loan application
RENE to Lender #3 on behalf of UNFOLD
20 4/19/202 1 MARIEL Electronic transmission of documents to a
TOLLINCHI payroll processing service to open a payroll
account on behalf of CINDA
21 5/5/2021 MAURICE E lectronic submission of PPP loan application
SHAZIER to Lender # 1 on behalf of SUNRISE CITY
22 5/5/202 1 MAURICE Electronic submission of PPP loan application
SHAZIER to Lender # 1 on behalf of JREAM
23 5/6/202 1 REGINE MARIE Electronic transmission of documents to a
RENE and payroll processing service to open a payroll
BRIANNA account on behalf of UNFOLD.
MONIQUE
GAYLE
24 6/11/202 1 MARIEL Electronic transmission of Form 4506-T
TOLLINCHI (Di saster Request for Transcript of Tax
Return) to SBA on behalf of PERFECT
LANDSCAPING
25 6/11/2021 MARIEL Electronic transmission of Form 4506-T
TOLLINCHI (Disaster Request for Transcript of Tax
Return) to SBA on behalfofFERRO ' S
15
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 16 of 30
COUNT26
(Aggravated Identity Theft: 18 U.S.C. § 1028A(a)(l))
On or about April 19, 202 1, in Broward County, in the Southern Di strict of Florida, and
elsewhere, th e defendant,
MARIEL TOLLINCHI,
during and in re lat ion to fe lony violations of T itle 18, U nited States Code, Section 1349, that is,
conspiracy to commit w ire fraud, as charged in Co unt 1 of this Second Superseding Indictment,
and of Ti tl e 18, United States Code, Section 1343 , th at is, w ire fraud, as charged in Count 20 of
this Second Superseding Indictment, did know ing ly transfer, possess, and use, without lawfu l
authority, the means of identification of another person, that is, the name, date of bi rth, and Social
Security num ber ofN .T., in violation of T itle 18, United States Code, Sections 1028A(a)(l ) and 2.
COUNTS 27- 33
(Money Laundering: 18 U.S.C. § 1956(a)(l)(B)(i))
The General A llegations Section of thi s Second Superseding Indictment is re-alleged and
incorporated by reference as though fu lly set forth herein .
On or about the dates set fo rth in each Count below, in Broward and M iami-Dade Counties,
in the Southern Di strict of Florida, and elsewhere, the defendants,
MARIEL TOLLINCHI,
REGINE MARIE RENE,
BRIANNA MONIQUE GAYLE,
MAURICE SHAZIER, and
ROBENSON LAUVINCE
did knowingly condu ct and attempt to condu ct a fina ncial transacti on affecting interstate and
fore ign commerce invo lving the proceeds of spec ified unlawful activity, know ing that the property
invo lved in the transactio n represented the proceed s of some form of unlawful acti vity, and
knowing th at the transaction was designed, in whole and in part, to conceal and di sguise the nature,
16
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 17 of 30
location, source, ownership, and control of the proceeds of said specified unlawful activity, as
more spec ifically described below:
Count Date Defendant Financial Transaction
27 6/18/2020 ROBENSON Deposit of check number 1097 in the amount of
LAUVINCE approximately $18,270, drawn on CLEAR
SHOT's account ending in 5325 at Well s Fargo
Bank, with a notation of "account setup", into
ROY AL ELITE's account ending in 0080 at
Bank of America.
28 3/12/21 REGINE MARIE Deposit of check number 101 9 in the amount of
RENE approximately $5 ,597, drawn on UNFOLD's
account ending in 8839 at Wells Fargo Bank,
with a notation of "accounting," into EIVC ' s
account ending in 4241 at Synovus Bank.
29 3/25/2021 BRIANNA Deposit of check number 171 in the amount of
MONIQUE approximately $3994, drawn on BRIANNA
GAYLE MONIQUE GA YLE' s account ending in 7876
at Navy Federal Credit Un ion, into DAD
MONEY' s acco unt ending in 4266 at Synovus
Bank.
30 4/15/202 1 MARIEL Deposit of check number 1062 in the amount of
TOLLINCHI approximately $7,500, drawn on CINDA's
account ending in 6917 at Popular Bank, with a
notation of "Legal Services," into TOLLINCHI
LA W' s account ending in 6299 at Chase Bank.
31 4/28/2021 MARIEL Deposit of check number 1067 in the amount of
TOLLINCHI approximately $3 ,500, drawn on CINDA ' s
account end ing in 6917 at Popular Bank, with a
notation of "Legal Services," into TOLLINCHI
LA W' s account ending in 6299 at Chase Bank.
32 5/17/2021 MAURICE Deposit of check number 1017 in the amount of
SHAZIER approximately $10,000, drawn on SUNRISE
CITY's account ending in 7117 at Bank of
America, with a notation of "advertisement,"
into EIVC ' s account ending in 4241 at Synovus
Bank.
33 5/ 18/202 1 MAURICE Electronic wire transfer of approximately
SHAZIER $7.300 from JREAM' s account ending in 0316
at Wells Fargo Bank, with a notation of
"advertisement commission," into EIVC ' s
account ending in 6361 at Synovus Bank.
17
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 18 of 30
It is further alleged that the specifi ed unlawful activity was wire fra ud, in v iolati on of Title
18, United States Code, Secti on 1343.
In violation of Title 18, United States Code, Sections l 956(a)(l )(B)(i) and 2.
COUNTS 34-35
(International Money Laundering: 18 U.S.C. § 1956(a)(2)(B)(i))
The General A llegati ons Section of thi s Second Superseding Indictment is re-all eged and
incorporated by reference as though full y set forth herein .
On or about the dates set forth in each Count be low, in Broward County, in the Southern
District of Florida, and elsewhere, the defendant,
MARIEL TOLLINCID,
did knowingly transmit and transfer and attempt to transmit and transfer monetary instruments and
fund s from a place inside the United States to and through a place outside the United States,
knowing that the monetary instruments and fund s invo lved in such transmission and transfer
represented the proceeds of some form of unlawful activity, and knowing that such transmission
and transfer was des igned in whole and in part to conceal and disguise the nature, locati on, source,
ownership, and control of the proceeds of specified unlawful activity, as more specifically
described below:
Count Date Description of Financial Transaction
34 1/6/2022 Electron ic wire transfer of approximately $26,371 fro m TOLLINCHI
LA W' s account ending in 1969 at Chase Bank to an acco unt in the
Dominican Republic.
35 1/25/2022 Electronic wire transfe r of approximately $200,000 fro m TOLLINCHI
LA W's account ending in 1969 at Chase Bank to an acco unt in the
Dominican Republic.
It is fu rther alleged th at the specifie d unl awful activity was wire fraud, in violation of Title
18, Uni ted States Code, Section 1343.
18
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 19 of 30
In violation of Title 18, United States Code, Sections l 956(a)(2)(B)(i) and 2.
COUNTS 36-37
(Engaging in a Transaction in Criminally Derived Property: 18 U.S.C. § 1957)
On or about the dates set forth in each Count below, in Broward County, in the Southern
District of Florida, and elsewhere, the defendants,
MARIEL TOLLINCHI and
ROBENSON LAUVINCE,
did knowingly engage in and attempt to engage in a monetary transaction affecting interstate
commerce, by, through, and to a financial institution, in criminally derived property of a value
greater than $10,000, as more specifically described below, such property having been derived
from a specified unlawful activity, and knowing that the property involved in the financial
transaction represented the proceeds of some form of unlawful activity.
It is further alleged that the specified unlawful activity was wire fraud, in violation of Title
18, United States Code, Section 1343 .
Count Date Defendant Financial Transaction
36 6/18/2020 ROBENSON Deposit of check number 1097 in the amount of
LAUVINCE approximately $18,270, drawn on CLEAR
SHOT's account ending in 5325 at Wells Fargo
Bank, w ith a notation of "account setup", into
ROYAL ELITE's account ending in 0080 at
Bank of America.
37 7/27/2020 MARIEL Electronic wire trartsfer of approximately
TOLLINCHI $70,800 from D.F. ' s account ending in 3145 at
Popular Bank to TOLLINCHI LA W ' s account
ending in 6299 at Chase Bank
In violation of Title 18, United States Code, Sections 1957 and 2.
FORFEITURE ALLEGATIONS
1. The allegations of this Superseding Indictment are hereby re-alleged and by this
reference fully incorporated herein for the purpose of alleging forfeiture to the United States of
19
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 20 of 30
America of certain property in which the defendants, MARIEL TOLLINCID, REGINE MARIE
RENE, BRIANNA MONIQUE GAYLE, MAURICE SHAZIER, and ROBENSON LAUVINCE
have an interest.
2. Upon conviction of a violation of Title 18, United States Code, Section 1349 or
1343 , as alleged in this Second Superseding Indictment, the defendant shall forfeit to the United
States any property constituting, or derived from, proceeds obtained, directly or indirectly, as the
res ult of such offense, pursuant to Title 18, United States Code, Section 982(a)(2)(A).
3. Upon conviction of a violation of Title 18, United States Code, Section 1956(h),
1956(a)(l)(B)(i), 1956(a)(2)(B)(i), or 1957, as alleged in this Second Superseding Indictment, the
defendant shall forfeit to the United States any property, real or personal, invol ved in such offense,
and any property traceable to such property, pursuant to T itle 18, United States Code, Section
982(a)(l).
4. Upon conviction of a violation of Title 18, United States Code, Section 1425, as
alleged in thi s Second Superseding Indictment, the defendant shall forfe it to the United States,
pursuant to Title 18, United States Code, Section 982(a)(6),
(i) any conveyance, including any vessel, vehicle, or aircraft used in the
commission of the offense; and
(ii) any property real or personal-
(!) that constitutes, or is derived from or is traceable to the proceeds
obtained directly or indirectly from the commission of the offense; or
(II) that is used to facilitate, or is intended to be used to fac ilitate, the
commission of the offense.
20
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 21 of 30
All pursuant to Title 18, United States Code, Sections 982(a)(l) and 982(a)(2)(A), and the
procedures set forth at Title 21 , United States Code, Section 853 , as incorporated by Title 18,
United States Code, Sections 982(6 )(1 ).
A TRUE BILL.
FOREPERSON
IO GONZALEZ
ATES ATTORNEY
/AM- O.sl-u..-
MARC OSBORNE
ASSISTANT UNITED STATES ATTORNEY
21
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 22 of 30
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
UNITED STATES OF AMERICA CASE N0.:22-CR-80144-SMITH/MA YNARD(s)(s) .
v.
CERTIFICATE OF TRIAL ATTORNEY*
JOFF S. W. PIIlLOSSAINT, et al.
- - - - - - - - - - - - - -I Superseding Case Information:
Defendants.
Court Division (select one) New Defendant( s) (Yes or No) Yes
□ Miami □ Key West □ FTP Number of New Defendants 1
□ FTL IZ] WPB Total number of New Counts 33
I do hereby certify that:
1. I have carefully considered the allegations of the indictment, the number of defendants, the number of probable
witnesses and the legal complexities of the Indictment/Information attached hereto.
2. I am aware that the information supplied on this statement will be relied upon by the Judges of this Court in setting
their calendars and scheduling criminal trials under the mandate of the Speedy Trial Act, Title 28 U.S.C. §3161 .
3. Interpreter: (Yes or No) No
List language and/or dialect:
4. This case will take 15 days for the parties to try.
5. Please check appropriate category and type of offense listed below:
(Check only one) (Check only one)
I □ 0 to 5 days □ Petty
II □ 6 to 10 days □ Minor
III Eil 11 to 20 days □ Misdemeanor
IV Dl 21 to 60 days GI Felony
V □ 61 days and over
6. Has this case been previously filed in this District Court? (Yes or No) Yes
If yes, Judge Smith Case No. 22-Cr-80144
7. Has a complaint been filed in this matter? (Yes or No) Yes
If yes, Magistrate Case No. 22-8336, 22-8337, 22-8357, 22-8579
8. Does this case relate to a previously filed matter in this District Court? (Yes or No) No
If yes, Judge Case No .
9. Defendant(s) in federal custody as of
10. Defendant(s) in state custody as of
11. Rule 20 from the District of
12. Is this a potential death penalty case? (Yes or No) No
13. Does this case originate from a matter pending in the Northern Region of the U.S. Attorney's Office
prior to August 8, 2014 (Mag. Judge Shaniek Maynard? (Yes or No) No
14. Does this case originate from a matter pending in the Central Region of the U.S. Attorney' s Office
prior to October 3, 2019 (Mag. Judge Jared Strauss? (Yes or No)No
By:
MARC OSBORNE
Assistant United States Attorney
Court ID No. A550796
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 23 of 30
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Name: JO FF STENN W ROY PHILOSSAINT
Case No: 22 -CR-801 44-SMITH/MAYNARD(s) (s)
Count #4:
Acquiring Naturalized U.S. Citizenship through Fraud
Title 18, United States Code, Section 1425(a)
* Max. Term oflmprisonment: 10 years
* Max.Supervised Release: 3 years
* Max. Fine: $250,000
*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms , or forfeitures that may be applicable.
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 24 of 30
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Name: MARIEL TOLLINCID
Case No: 22-CR-80 144-SMITH/MA YNARD(s)(s)
Count # 1:
Conspiracy to Commit Wire Fraud
Title 18, Un ited States Code, Section 1349
* Max. Term oflmprisonment: 20 years
*Max.Supervised Release: 3 years
* Max. Fine: $250,000 or twice gross loss or gross gain
Count #2:
Conspiracy to Commit Money Laundering
Title 18, United States Code, Section 1956(h)
*Max.Term of Imprisonment: 20 years
*Max.Supervised Release: 3 years
* Max. Fine: $500,000 or twice amount laundered
Count #3:
Conspiracy to Commit Money Laundering
Title 18, United States Code, Section 1956(h)
* Max. Term oflmprisonment: 20 years
* Max.Supervised Release: 3 years
* Max. Fine: $500,000 or twice amount laundered
Counts #8, 10, 18, 20, 24, 25:
Wire Fraud
Title 18 United States Code Section 1343
* Max. Term oflmprisonment: 20 years
*Max.Supervised Release: 3 yea rs
* Max. Fine: $250,000 or twice gross loss or gain
*Refers only to possible term of incarceration, supervised release and fines. It does not
include restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 25 of 30
Count #26:
Aggravated identity theft
Title 18, United States Code, Section 1028A
* Min. & Max. Term oflmprisonment: 2 years consecutive to any other term of
imprisonment imposed on the person under any other provision of law
* Max.Supervised Release: 3 years
* Max. Fine: $250,000
Counts #3 0-31:
Money Laundering
Title 18, United States Code, Section 1956(a)(l)(B)(i)
* Max. Term oflmprisonment: 20 years
*Max.Supervised Release: 3 years
* Max. Fine: $500,000 or twice amount laundered
Counts #34-35 :
International Money Laundering
Title 18, United States Code, Section l 956(a)(2)(B)(i)
* Max. Term oflmprisonment: 20 years
* Max. Supervised Release: 3 years
* Max. Fine: $500,000 or twice amount laundered
Count #37:
Engaging in a Transaction in Criminally Derived Property
Title 18 United States Code Section 1957
*Max.Term oflmprisonment: 10 years
*Max.Supervised Release: 3 years
* Max. Fine: $250,000 or twice value of derived property
*Refers only to possible term of incarceration, supervised release and fines. It does not
include restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 26 of 30
UNITED ST ATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Name: REGINE MARIE RENE
Case No: 22-CR-80144-SMITH/MAYNARD(s) (s)
Count # 1:
Conspiracy to Commit Wire Fraud
Title 18 United States Code Section 1349
* Max.Term of Imprisonment: 20 years
* Max.Supervised Release: 3 years
* Max. Fine: $250,000 or twice gross loss or gross gain
Count #2 :
Conspiracy to Commit Money Laundering
Title 18. United States Code, Section 1956 (h)
* Max.Term of Imprisonment: 20 years
* Max. Supervised Release: 3 years
* Max.Fine: $500,000 or twice amount laundered
Counts #6, 12, 19, 23:
Wire Fraud
Title 18 United States Code Section 1343
* Max. Term of Imprisonment: 20 years
* Max.Supervised Release: 3 years
* Max.Fine: $250,000 or twice gross loss or gain
Count #28:
Money Laundering
Title 18, United States Code, Section 1956(a)(l)(B)(i)
* Max. Term of Imprisonment: 20 years
* Max.Supervised Release: 3 years
* Max. Fine: $500,000 or twice amount laundered
*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 27 of 30
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Name : BRIANNA MONIQUE GAYLE
Case No : 22 -CR-80144-SMITH/MAYNARD(s) (s)
Count #1:
Conspiracy to Commit Wire Fraud
Title 18, United States Code, Section 1349
* Max.Term of Imprisonment: 20 years
* Max. Supervised Release: 3 years
* Max. Fine: $250,000 or twice gross loss or gross gain
Count #2:
Conspiracy to Commit Money Laundering
Title 18, United States Code, Section 1956 (h)
* Max.Term oflmprisonment: 20 years
* Max.Supervised Release: 3 years
* Max. Fine: $500,000 or twice amount laundered
Counts # 16 , 23:
Wire Fraud
Title 18 United States Code Section 1343
* Max. Term of Imprisonment: 20 years
* Max. Supervised Release: 3 years
* Max. Fine: $250,000 or twice gross loss or gain
Count #29:
Money Laundering
Title 18, United States Code, Section 195 6(a)(l)(B)(i)
* Max. Term of Imprisonment: 20 years
* Max.Supervised Release: 3 years
* Max. Fine: $500,000 or twice amount laundered
*Refers only to possible term of incarceration, supervised release and fines. It does not
include restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 28 of 30
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Name: MAURICE SHAZIER
Case No: 22-CR-80 144-SMITH/MA YNARD (s) (s)
Count #1:
Conspiracy to Commit Wire Fraud
Title 18, United States Code, Section 1349
* Max.Term of Imprisonment: 20 years
* Max. Supervised Release: 3 years
* Max. Fine: $250,000 or twice gross loss or gross gain
Count #2:
Conspiracy to Commit Money Laundering
Title 18, United States Code, Section 1956(h)
* Max.Term of Imprisonment: 20 years
* Max.Supervised Release: 3 years
* Max. Fine: $500,000 or twice amount laundered
Counts #9, 11 , 13-15 , 21, 22:
Wire Fraud
Title 18 United States Code Section 1343
* Max.Term of Imprisonment: 20 years
* Max.Supervised Release : 3 years
* Max. Fine: $250,000 or twice gross loss or gross gain
Counts #32-33:
Money Laundering
Title 18, United States Code, Section 1956 (a)( l)(B)(i)
* Max.Term of Imprisonment: 20 years
* Max. Supervised Release: 3 years
* Max. Fine: $500,000 or twice amount laundered
*Refers only to possible term of incarceration, supervised release and fines . It does not include
restitution , special assessments, parole terms, or forfeitures that may be applicable.
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 29 of 30
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Name: ROBENSON LAUVINCE
Case No: 22-CR-80144-SMITH/MAYNARD(s) (s)
Count #1:
Conspiracy to Commit Wire Fraud
Title 18 United States Code Section 1349
* Max. Term oflmprisonment: 20 years
* Max.Supervised Release: 3 years
* Max. Fine: $250,000 or twice gross loss or gross gain
Count #2:
Conspiracy to Commit Money Laundering
Title 18, United States Code, Section 1956 (h)
* Max.Term of Imprisonment: 20 years
* Max. Supervised Release: 3 years
* Max. Fine: $500,000 or twice amount laundered
Counts #5, 7, 17:
Wire Fraud
Title 18 United States Code Section 1343
* Max.Term of Imprisonment: 20 years
* Max. Supervised Release: 3 years
* Max. Fine: $250,000 or twice gross loss or gain
Count #27:
Money Laundering
Title 18, United States Code, Section 19 56 (a) (1 )(B )(i)
* Max.Term of Imprisonment: 20 years
* Max.Supervised Release: 3 years
* Max. Fine: $500,000 or twice amount laundered
*Refers only to possible term of incarceration, supervised release and fines. It does not
include restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 30 of 30
Count #36:
Engaging in a Transaction in Criminally Derived Property
Title 18 United States Code Section 1957
* Max. Term of Imprisonment: 10 years
* Max.Supervised Release: 3 years
* Max. Fine: $250,000 or twice amount of criminally derived property
*Refers only to possible term of incarceration, supervised release and fines. It does not
include restitution, special assessments, parole terms, or forfeitures that may be applicable.File and source
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