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Home Source documents Application for Leave to File Under Seal; Complaint and Affidavit in Support of Arrest Warrant — Jonathan Cannon and Julie Dotton (E.D.N.Y. No. 24-mj-00342)

Application for Leave to File Under Seal; Complaint and Affidavit in Support of Arrest Warrant — Jonathan Cannon and Julie Dotton (E.D.N.Y. No. 24-mj-00342)

Summary

This filing pairs a May 1, 2024 application by the U.S. Attorney's Office, EDNY, for leave to file under seal, citing an ongoing criminal investigation, with a complaint and affidavit in support of arrest warrants for Jonathan Cannon and Julie Dotton in Case No. 24-MJ-342, charging wire fraud under 18 U.S.C. § 1343. FBI Special Agent Amanda Gildea alleges that between March 2020 and October 2020 the two defrauded a Canadian company that was an official provider of PPE to two Canadian provinces. According to the affidavit, Dotton's KRP Holdings agreed on April 14, 2020 to sell about 12 million face masks for about $8.2 million, and the funds went from the company to an attorney serving as a purported escrow agent and then to an SBM Holdings account controlled by Cannon, which sent $2.75 million to NEDC. The affidavit says the company never received PPE and has recovered only $250,000.

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TO: Clerk’s Office
     UNITED STATES DISTRICT COURT
     EASTERN DISTRICT OF NEW YORK
________________________________________

     APPLICATION FOR LEAVE
   TO FILE DOCUMENT UNDER SEAL

                                                                                           A) If pursuant to a prior Court Order:
********************************                                                           Docket Number of Case in Which Entered:___________________
                                                                                           Judge/Magistrate Judge:__________________________________
United States
                                                                                           Date Entered:___________________________________________
                 -v.-                                 24-MJ- 342
            -v.-                                      _____________________
Jonathan Cannon and Julie Dotton                      Docket Number

********************************
                                                                                           B) If a new application, the statute, regulation, or other legal basis that
SUBMITTED BY: Plaintiff____ Defendant____ DOJ ✔
                                              ____                                         authorizes filing under seal
       John O. Enright
Name:__________________________________________
Firm Name:______________________________________
            U.S. Attorney's Office, EDNY                                                   Ongoing criminal investigation.
                                                                                           __________________________________________________________
Address:_________________________________________
           271 Cadman Plaza   East                                                         __________________________________________________________
________________________________________________
           Brooklyn, NY   11201
Phone Number:___________________________________
               718-254-6203                                                                ORDERED SEALED AND PLACED IN THE CLERK’S OFFICE,
E-Mail Address:___________________________________
                 john.enright@usdoj.gov                                                    AND MAY NOT BE UNSEALED UNLESS ORDERED BY
                                                                                           THE COURT.
INDICATE UPON THE PUBLIC DOCKET SHEET: YES               NO ✔ __
If yes, state description of document to be entered on docket sheet:                       DATED: Central Islip                     , NEW YORK
                                                                                                   5/1/24
__________________________________________________                                         _________________________________________________________

__________________________________________________                                         U.S. MAGISTRATE JUDGE

                                                                                           RECEIVED IN CLERK’S OFFICE___________________________
                                                                                                                            DATE
MANDATORY CERTIFICATION OF SERVICE:
A.) ___ A copy of this application either has been or will be promptly served upon all parties to this action, B.) ___ Service is excused by 31 U.S.C. 3730(b), or by
the following other statute or regulation:______; or C.) ✔
                                                        ____This is a criminal document submitted, and flight public safety, or security are significant concerns.
(Check one)

                           May 1, 2024
                           __________________                  ______________________________
                              DATE                                      SIGNATURE
HDM/DGR:JOE/AT
F. #2022R00468

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
---------------------------X                            TO BE FILED UNDER SEAL

UNITED STATES OF AMERICA                                COMPL AINT AND
                                                        AFFIDAVIT IN SUPP ORT
           - against -                                  OF AR R E ST WARR ANT

JONATHAN CANNON and                                     (18 U.S.C. §§ 1343, 2 and 3551 et seq.)
JULIE DOTTON,
                                                        Case No. 24-MJ-342
                         Defendants.

---------------------------X

EASTERN DISTRICT OF NEW YORK, SS:

               Amanda Gildea, being duly sworn, deposes and states that she is a Special Agent

with the Federal Bureau of Investigation (“FBI”), duly appointed according to law and acting as

such.

               In or about and between March 2020 and October 2020, both dates being

approximate and inclusive, within the Eastern District of New York and elsewhere, the

defendants JONATHAN CANNON and JULIE DOTTON, together with others, did knowingly

and intentionally devise a scheme or artifice to defraud a company, whose identity is known to

your deponent, in order to obtain money or property from it by means of one or more materially

false and fraudulent pretenses, representations and promises, and for the purpose of executing

such scheme and artifice, did transmit or cause to be transmitted, by means of wire

communication in interstate and foreign commerce, writings, signs, signals, pictures and sounds.

               (Title 18, United States Code, Sections 1343, 2 and 3551 et seq.)
                                                                                                   2

                The source of your deponent’s information and the grounds for her belief are as

follows:1

                1.      I am a Special Agent with the FBI and have been involved in the

investigation of numerous cases involving financial crimes, including securities fraud,

commodities fraud, wire fraud, mail fraud and money laundering. I am familiar with the facts

and circumstances set forth below from my participation in the investigation; my review of the

investigative file, including the defendant’s criminal history record; my review of documents

obtained in the course of the investigation, including emails obtained pursuant to judicially

authorized search warrants; and from my review of reports of other law enforcement officers and

regulatory agencies.

                            Background, Relevant Individuals and Entities

                2.      The defendant JONATHAN CANNON resides in Miller Place, New

York, in the Eastern District of New York. CANNON purports to work in various capacities in

the real estate industry.

                3.      The defendant JULIE DOTTON resides in Orchard Park, New York.

DOTTON was the chief executive officer of Applied Sciences Group, Inc., a private company

that publicly claimed to “provide[] technically superior software engineering solutions for

applications involving research, industrial and manufacturing environments, design-oriented

engineering services, technical project management and training.”

                4.      SBM Holdings LLC (“SBM Holdings”) is a limited liability company

organized under the laws of the state of Wyoming in March 2017 with a principal place of


1
        Because the purpose of this Complaint is to set forth only those facts necessary to
establish probable cause to arrest, I have not described all the relevant facts and circumstances of
which I am aware.
                                                                                                     3

address in Wyoming. SBM Holdings is a nominal entity owned and controlled by the defendant

JONATHAN CANNON.

               5.      New England Development Corp. (“NEDC”) is a corporation organized

under the laws of the state of Vermont in November 2006 with a principal place of address in

Miller Place, New York, in the Eastern District of New York. NEDC purports to be a real estate

development business. The defendant JONATHAN CANNON is the president, vice president

and secretary of NEDC.

               6.      KRP Holdings, LLC (“KRP Holdings”) is a limited liability company

organized under the laws of the state of New York in January 2011 with a principal place of

address in Erie County, New York. KRP Holdings is a nominal entity owned and controlled by

the defendant JULIE DOTTON.

               7.      Based on my participation in the investigation to date, I have learned that

in or about and between March 2020 and October 2020, the defendants JONATHAN CANNON

and JULIE DOTTON executed a scheme to defraud a Canadian company (“Company-1”), an

entity whose identity is known to me, that was an official provider of personal protective

equipment (“PPE”) to two Canadian provinces during the COVID-19 pandemic.

                                     The Fraudulent Scheme

               8.      On or about March 31, 2020, the defendant JONATHAN CANNON

forwarded an email from the defendant JULIE DOTTON to Attorney-1, an individual whose

identity is known to me. CANNON informed Attorney-1, in substance, that he was working

with DOTTON, that he had given DOTTON an escrow agreement and that DOTTON “will pay

you direct for your services, she is good for it.” CANNON also stated that he was expecting

“part of the funs [sic] are going to me” for an unspecified “other transaction.”
                                                                                               4

              9.      In or about early April 2020, a representative of Company-1, an individual

whose identity is known to me, communicated with the defendant JULIE DOTTON, who

represented to the Company-1 representative that she had contacts with Supplier-1, an entity

whose identity is known to me, and could quickly and reliably procure PPE, including face

masks. DOTTON offered to serve as the intermediary between Supplier-1 and Company-1.

              10.     On or about April 14, 2020, KRP Holdings, a nominal business entity

controlled by the defendant JULIE DOTTON, entered into an agreement with Company-1 to sell

Company-1 approximately 12 million face masks for approximately $8.2 million.

              11.     On or about April 15, 2020, Company-1 wired $8.2 million to Attorney-1,

who was serving as a purported escrow agent for the defendant JULIE DOTTON and with whom

the defendant JONATHAN CANNON had previously communicated with on March 31, 2020.

              12.     Bank records reflect that, after Attorney-1 received the funds from

Company-1, rather than use the funds to purchase PPE from Supplier-1 on Company-1’s behalf

as agreed, the defendant JULIE DOTTON, together with the defendant JONATHAN CANNON

and others, caused Attorney-1 to wire the funds to a bank account in the name of SBM Holdings,

an entity owned and controlled by CANNON.

              13.     On or about April 16, 2020, the defendant JONATHAN CANNON

emailed the defendant JULIE DOTTON, among other things, a “Corporate Resolution”

document for SBM Holdings and wiring instructions for a bank account in the name of SBM

Holdings. The Corporate Resolution claimed that SBM Holdings, whose only director was

CANNON, had held a Board meeting that same day and issued the Corporate Resolution. The

Corporate Resolution purportedly resolved the following:
                                                                                                 5

                       a.     SBM Holdings was “to join with KRP Holdings LLC and Julie

Dotton . . . in her Medical Supply business. All funds moved to this account from KRP

Holdings LLC and Julie Dotton will be directed by KRP Holdings LLC and Julie Dotton. Any

and ALL fees payable to SBM Holdings, LLC will be discussed and directed as payment from

Julie Dotton.”

                       b.     The Corporate Resolution further resolved that “Jonathan Cannon

will need to sign authorizing ANY movement of funds from the [bank account in the name of

SBM Holdings] in which the invested funds will be held.”

                       c.     Finally, the Corporate Resolution resolved that “these funds are the

property of KRP Holdings LLC and are being used solely for the purposes to expedite business

in the Medical Supply business that Julie Dotton has. The funds will be directed to be paid at

the Sole discretion of Julie Dotton and KRP Holdings LLC.”

                       d.     The Corporate Resolution was signed by the defendant

JONATHAN CANNON on behalf of SBM Holdings and the defendant JULIE DOTTON on

behalf of KRP Holdings.

                 14.   The Corporate Resolution’s purported resolutions were, as defendant

JONATHAN CANNON knew, false and misleading, as CANNON distributed the monies

received in the SBM Holdings account to third parties for purposes other than in connection with

any medical supply business as demonstrated below.

                 15.   In an email attaching the Corporate Resolution, the defendant

JONATHAN CANNON told the defendant JULIE DOTTON, “as discussed [Attorney-1] will

have to physically go to bank, so you should instruct him soon, maybe he will go on his Lunch

break.”
                                                                                             6

              16.    On or about April 17, 2020, funds obtained from Company-1 were

received by the bank account in the name of SBM Holdings. CANNON then caused the funds

from the account in the name of SBM Holdings to be further disbursed to bank accounts

controlled by the defendants JULIE DOTTON and JONATHAN CANNON and other third

parties, including confederates of CANNON and DOTTON. Among other wire transfers,

CANNON caused $2.75 million in the account in the name of SBM Holdings to be wired to a

bank account in the name of NEDC controlled by CANNON.

              17.    Over the course of the next several months, the defendant JONATHAN

CANNON disbursed the $2.75 million in the NEDC Account to various third parties, including

CANNON’s family members.

              18.    In addition, on or about April 22, 2020, the defendant JULIE DOTTON

emailed the defendant JONATHAN CANNON and asked him to execute a series of personal

wire transfers of almost $700,000 from the account in the name of SBM Holdings to, among

others, certain of DOTTON’s creditors. CANNON caused these wire transfers to be made from

the account in the name of SBM Holdings within two days.
                                                                                                      7

               19.     According to records made publicly available in private litigation between

Company-1, on the one hand, and the defendants JONATHAN CANNON and JULIE DOTTON

and others, on the other hand, Company-1 never received PPE from CANNON, DOTTON or

their respective entities and, in fact, has recovered only $250,000 of the $8.2 million it wired to

Attorney-1 as described above.

               WHEREFORE, your deponent respectfully requests that the defendants

JONATHAN CANNON and JULIE DOTTON be dealt with according to law.



                                              Amanda Gildea
                                              Special Agent, Federal Bureau of Investigation

Sworn to before me by telephone on this
 1st day of May, 2024
____


____________________________________________
THE HONORABLE STEVEN L. TISCIONE
UNITED STATES MAGISTRATE JUDGE
EASTERN DISTRICT OF NEW YORK


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