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Home Court filings Joff Stenn Wroy Philossaint case — U.S. District Court, S.D. Fla. Second Superseding Indictment — United States v. Pidlossaint (Dkt. 107, S.D. Fla.)

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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.

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Filed December 15, 2022 in Joff Stenn Wroy Pidlossaint; one of 110 filings from this case.

Record facts

CourtU.S. District Court for the Southern District of Florida
Filed2022-12-15

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“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.

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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

Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 7 of 30




                                      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

Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 8 of 30




                                      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.

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