Complaint for Forfeiture — 3018 Kingfisher Point, Chuluota, FL (No. 6:20-cv-02306, M.D. Fla.)

Summary

A verified complaint for forfeiture in rem filed by the United States against real property in Chuluota, Florida, Case No. 6:20-cv-02306-PGB-EJK, in the U.S. District Court for the Middle District of Florida, filed December 17, 2020 as Document 1. The government seeks civil forfeiture, alleging the property was bought with proceeds of wire fraud under 18 U.S.C. § 1343 and involved in money laundering under 18 U.S.C. § 1957. Facts provided by an IRS special agent state that a PPP loan was obtained through Fountainhead SBF, LLC for Magnifi.Co, Inc. on an application claiming average monthly payroll of $2,880,000, supported by 441 Form W-2s, of which 16 had duplicate Social Security numbers, 130 had numbers never issued and 150 had numbers issued to someone other than the person listed. It states that loan proceeds went toward the $3,499,000 property purchased in July 2020.

Summary drafted by a model from the text of the original file linked on this page 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

Cite this document

“Complaint for Forfeiture — 3018 Kingfisher Point, Chuluota, FL (No. 6:20-cv-02306, M.D. Fla.).” Original at www.justice.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/complaint-no-6-20-cv-02306-dkt-1-m-d-fla-af3e533f13/, SHA-256 608fc2cfa89b14e38f88f79dd29c29eded4673daed81b725d56f8911fe1ddae4.

Full text

Case 6:20-cv-02306-PGB-EJK Document 1 Filed 12/17/20 Page 1 of 22 PageID 1
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UNITED STATES OF AMERICA

Plaintiff,
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V. Case No. 6:20-cv- i1:)~· v~

REAL PROPERTY LOCATED AT
3018 KINGFISHER POINT,
CHULUOTA, FL 32766,

Defendant.

VERIFIED COMPLAINT FOR FORFEITURE IN REM

In accordance with Rule G(2) of the Supplemental Rules for Admiralty

or Maritime Claims and Asset Forfeiture Actions, Plaintiff the United States

of America brings this complaint and alleges upon information and belief as

follows:

NATURE OF THE ACTION

1. This is a civil action in rem to forfeit to the United States,

pursuant to 18 U.S.C. §§ 981(a)(l)(A), (a)(l)(C), and Rule G(2), the real

property, attachments thereto, and appurtenances thereon, located at 3018

Kingfisher Point, Chuluota, FL 32766 (the Defendant Property) because the

property was purchased with proceeds traceable to wire fraud, in violation of

18 U.S.C. § 1343, and involved in money laundering transactions, in violation
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of 18 U.S.C. § 1957. The Defendant Property is thus property constituting or

derived from proceeds traceable to a violation of an offense constituting

"specified unlawful activity" (as defined in section 1956(c)(7) of Title 18), and

property involved in money laundering offenses, and subject to civil forfeiture

to the United States pursuant to 18 U.S.C. §§ 981(a)(l)(A) and (a)(l)(C).

JURISDICTION AND VENUE

2. This Court has subject matter jurisdiction over an action

commenced by the United States by virtue of 28 U.S.C. § 1345 and over an

action for forfeiture by virtue of 28 U.S.C. § 1355.

3. Venue properly lies in the Middle District of Florida pursuant to

28 U.S.C. § 1395 because the Defendant Property is in the district. 28 U.S.C.

§ 1395(b).

4. This Court has in rem jurisdiction over the Defendant Property

pursuant to 28 U.S.C. § 1355(b)(l)(B), because venue properly lies in the

Middle District of Florida pursuant to 28 U.S.C. § 1395.

5. Pursuant to Rule G(3)(a) of the Supplemental Rules for

Admiralty or Maritime Claims and Asset Forfeiture Actions, and 18 U.S.C.

§ 985(c)(2), a notice of this forfeiture, as well as a copy of the complaint will be

posted on the real property and served on the owners of the real property.

Thereafter, neither the issuance of a warrant in rem nor any other action will

2
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be necessary for the Court to exercise in rem jurisdiction over the property. 18

U.S.C. § 985(c)(3).

THE DEFENDANT IN REM

6. The Defendant Property is the real property, attachments thereto,

and appurtenances thereon, located at 3018 Kingfisher Point, Chuluota, FL

32766.

BASIS FOR FORFEITURE

7. Pursuant to 18 U.S.C. § 1343, it is unlawful to "devise[] ... any

scheme or artifice to defraud," or to "obtain[] money or property ... by means

of false or fraudulent pretenses, representations, or promises," if the person

"transmits or causes to be transmitted by means of wire ... communication in

interstate or foreign commerce any writings ... or sounds ... for the purpose

of executing such scheme or artifice." Id.

8. Pursuant to 18 U.S.C. § 1957(a), it is unlawful to knowingly

engage or attempt to engage in a monetary transaction with proceeds of a

specified unlawful activity in an amount greater than $10,000 by, through, or

to a financial institution. Id.

9. The Defendant Property was purchased with proceeds of a wire

fraud scheme that operated in violation of 18 U.S.C. § 1343, as set forth

further below. Because the Defendant Property was purchased with proceeds

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of a violation of 18 U.S.C. § 1343, it is subject to forfeiture pursuant to 18

U.S.C. § 98l{a)(l)(C), which authorizes the United States to civilly forfeit any

property that constitutes or is derived from proceeds traceable to a "specified

unlawful activity," as defined in 18 U.S.C.§ 1956(c)(7). "Specified unlawful

activity," is defined in 18 U.S.C. § 1956(c)(7) to include offenses listed in 18

U.S.C. § 1961(1), which includes wire fraud in violation of 18 U.S.C. § 1343.

10. Additionally, the monetary transactions made to purchase the

Defendant Property were conducted in violation of 18 U.S.C. § 1957(a)

because they were knowingly conducted with more than $10,000 in funds

derived from specified unlawful activity (specifically, wire fraud offenses),

and, as such, the Defendant Property is subject to civil forfeiture pursuant to

18 U.S.C. § 98l{a){l)(A).

11. As required by Rule G(2)(t), the facts set forth herein support a

reasonable belief that the government will be able to meet its burden of proof

at trial. Specifically, they support a reasonable belief that the government will

be able to show by a preponderance of the evidence that the Defendant

Property was purchased with proceeds of wire fraud and involved in money

laundering transactions.

FACTS

12. Specific details of the facts and circumstances supporting the

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forfeiture of the Defendant Property have been provided by Internal Revenue

Service (IRS) Special Agent Jacob Stafford, who states as follows:

I. Overview of the Cares Act

13. The CARES Act is a federal law enacted on March 29, 2020,

designed to provide emergency financial assistance to the millions of

Americans who are suffering the economic effects caused by the COVID-19

pandemic. One source of relief provided by the CARES Act was the

authorization of up to $349 billion in SBA-guaranteed forgivable loans to

small businesses through the Paycheck Protection Program (PPP). In April

2020, Congress authorized over $300 billion in additional PPP funding.

14. The PPP allows qualifying small-businesses and other

organizations to receive loans with a maturity of two years and an interest rate

of one percent. PPP loan proceeds must be used by businesses on payroll

costs, interest on mortgages, rent, and utilities. The PPP allows the interest

and principal to be forgiven if businesses spend the proceeds on these expenses

within eight weeks of receipt and use at least 75 percent of the forgiven

amount for payroll.

15. As will be explained more fully below, Don Cistemino, on behalf

ofMagnifi.Co, Inc. applied for a PPP loan through Fountainhead SBF, LLC.

In so doing, Fountainhead was supplied with false documents/ information for

5
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Magnifi.Co, Inc. in order to obtain the loan, and then Cistemino used the loan

proceeds on purchases unrelated to the operation of his business, including the

purchase of the Defendant Property.

II. Relevant Participants

16. Cistemino and Lori Quasky are the titled owners of the

Defendant Property. Prior to purchasing the Defendant Property in July 2020,

Cistemino was a resident of Manatee County in the Middle District of

Florida.

17. Magnifico was incorporated in the state of New York on or

about May 12, 2014, with its business address listed in Rye, New York.

Cistemino is the founder and registered agent ofMagnifi.Co. Magnifi.Co's

Linkedln page provides the company overview as: "Software, Consulting,

Marketing, IT, Tech, Apps, Graphics, Websites, Content, PR, Social, Talent,

Literary, Professional and Personal Services, and more" and lists its web

address as htt_p://magnifico.media. However, the webpage is not functional

and has no further information about the company.

18. Fountainhead is a national, non-bank, direct commercial lender

that specializes in helping owners of small to midsize businesses finance their

growth and create wealth through their SBA 504, SBA 7(a) and low LTV

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conventional loan programs. Fountainhead is incorporated in Florida with its

business address located in Seminole County, Florida.

19. Radius Bank is an FDIC insured on1ine bank headquartered in

. Boston, Massachusetts.

20. Lori Quasky is also a titled owner of the Defendant Property.

According to documents provided in support of the fraudulent PPP loan and

Magnifi.Co's Linkedln page, Quasky is the V.P. of marketing for Magnifico.

21. Law enforcement believes that Quasky and Cisternino are

involved in a romantic relationship. Prior to purchasing the $3,499,000

Defendant Property together, the two resided together in an apartment in

Bradenton, FL. However, in August 2019, their landlord sought to evict them

for failing to pay August's rent in the amount of $2,565.26 in an action filed in

County Court in Manatee County. The matter was quickly resolved by

stipulation of the parties after the two were able to obtain the necessary rent

payment. 1

m. The Scheme to Defraud
22. On or about April 12, 2020, Cisternino opened bank account

1
According to a document filed by Quasky and Cisternino in that action,
they were behind on their rent because a couple of their clients did not timely
pay them for "freelance work" they had performed for their clients.

7
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ending in 7809 at Radius Bank in the name of MagnifiCo. Cisternino held sole

signatory authority on the bank account.

23. On or about May 5, 2020, documents were submitted to

Fountainhead seeking a PPP loan under the CARES Act on behalf of

Magnifico. Multiple documents were submitted in support of the loan

application including, but not limited to, a Form 2483 Paycheck Protection

Program Borrower Application Form, a 2019 Form 1120 for Magnifico, a

2019 profit and loss statement for Magnifico, 441 2019 Form W-2s for alleged

employees ofMagnifiCo, and four 2019 Form 941 Employers Quarterly

Federal Tax Returns for Magnifico.

24. The Form 2483 claimed the average monthly payroll for

Magnifico was $2,880,000, and that the loan was being sought to assist with

payroll, lease/mortgage interest, utilities, re-hiring, new hires, and upgrading

platform. Indeed, Cisternino initialed the Form 2483 certifying, among other

things, 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, as reported on Form(s) 1099-MISC, and that the loan proceeds

would be used to retain workers and maintain payroll or make mortgage

interest payments, lease payments, and utility payments, as specified under the

Paycheck Protection Program Rule.

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A. Inconsistencies in Information Provided by Magnifico to
Fountainhead for the PPP Loan

25. The first inconsistency in the information provided to

Fountainhead were the 441 Form W-2s submitted to Fountainhead contained

two Form W-2s in the names of S.A.W. and I.M. with incomplete Social

Security numbers; 16 Form W-2s contained duplicate Social Security numbers

(only eight unique Social Security numbers were used to create 16 Form W-

2s); 130 Form W-2s contained Social Security numbers that were never issued

to an individual (this number does not include the two incomplete Social

Security numbers); and 150 Form W-2s contained Social Security numbers

issued to an individual other than the person listed on the Form W-2. 2

26. Second, the information provided to Fountainhead about

Magnifi.Co's Employer Identification Number (EIN) was inconsistent. The

Form 2483 reported Magnifi.Co's EIN to be 46-5656635, but the Form SS-4,

Form 941s, Form 1120 and Form W-2s provided in the loan file reported

Magnifi.Co's EIN as 46-5656035.

2 It was noted that the Form W-2 for Quask:y is contained in this group as the
first digit of Quask:y' s Social Security number is "0," but the Social Security
number on the Form W-2 submitted to Fountainhead is a "l." The Social
Security number listed for Quask:y belongs to M.C.B. The remaining digits on
the Form W-2 submitted for Quaksy to Fountainhead match Quasky's Social
Security number.

9
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27. Third, the documents provided to Fountainhead included

inconsistencies in the total amount of wages for Magnifico. Specifically, the

Form 941s and Form 1120 both reported total wages of$37,440,000.

However, the aggregate amount of wages from the 441 Form W-2s totaled

$37,435,000. The amount of wages listed on these forms should have all been

the same.

28. Fourth, the documents provided to Fountainhead also included

inconsistencies in MagnifiCo's Federal Income Tax Withholdings (FITW).

Specifically, the Form 941s contained a total of $2,246,409.00 in FITW, but

the 441 Forms W-2s totaled $2,246,438.00 in FITW. Again, these amounts

should all be the same.

29. Fifth, the 2019 profit and loss statement submitted to

Fountainhead contained basic math errors.

30. Sixth, the 441 Form W-2s submitted to Fountainhead contained

six Form W-2s with incorrect calculations for Social Security Tax

Withholdings and Medicare Tax Withholdings. Specifically, Social Security

Tax Withholdings are calculated by multiplying the wage amount by 6.2%

and Medicare Tax Withholdings are calculated by multiplying the wage

amount by 1.45%. 3 However, in this case, the six Form W-2s used variable

3
This is the portion to be paid by the employee and reflected on the Form
Case 6:20-cv-02306-PGB-EJK Document 1 Filed 12/17/20 Page 11 of 22 PageID 11

calculations to determine the Social Security Tax Withholdings and Medicare

Tax Withholdings. In my experience this is an extremely odd occurrence since

the rest of the Form W-2s have the correct calculations, including some Form

W-2s reporting the same wage amounts. Further, these figures are normally

automatically calculated and for the numbers to be correct on most, but

incorrect on others, shows the Form W-2 appears to have been engineered to

apply for the PPP loan and not generated in the normal course of business.

31. There were also 158 Form W-2s with Social Security numbers

that were issued to the individual listed on the Form W-2. However, three of

'those individuals were deceased; two died in 2018 and the third died on

March 7, 2019.

32. Additionally, the 441 Form W-2s submitted to Fountainhead

reported the following exact wage amounts and FITW:

Count
Wages 65,000.00 1
FITW 3,118.00 1
Wages 70,000.00 1
FITW 6,726.50 1
Wages 75,000.00 23
FITW 2,156.00 22
FITW 3,668.00 1

W-2. If the employee earns over $200,000 there is an additional .09% paid by
the employee, but this does not factor into this scenario as all employees
earned under $95,000.

11
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Wages 80,000.00 86
FITW 2,756.00 84
FITW 4,414.00 2
Wages 85,000.00 223
FITW 3,356.00 108
FITW 3,859.96 1
FITW 6,330.50 16
FITW 6,380.00 14
FITW 6,884.00 8
FITW 7,254.50 16
FITW 8,178.50 15
FITW 9,102.50 15
FITW 10,026.50 18
FITW 10,950.50 12
Wages 90,000.00 86
FITW 3,956.00 16
FITW 4,460.00 11
FITW 4,556.00 2
FITW 4,964.00 3
FITW 5,468.00 5
FITW 5,564.00 1
FITW 5,582.50 4
FITW 6,476.00 3
FITW 6,505.50 1
FITW 6,506.50 4
FITW 6,979.96 4
FITW 7,430.28 8
FITW 7,484.00 3
FITW 8,354.32 4
FITW 8,354.50 5
FITW 9,278.50 5
FITW 10,202.40 1
FITW 10,202.50 4
FITW 11,126.50 2
Wages 95,000.00 19
FITW 2,756.00 1

12
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FITW 4,556.00 17
FITW 5,564.00 1
Wages 97,500.00 2
FITW 4,556.00 1
FITW 7,460.28 1

The above FITW calculations appear to be false/ fictitious based not only on

the fact of repeat exact amounts, but also whole dollar amounts (i.e., there are

a large portion of the above figures ending in .00, which is not a common

occurrence at such a high rate for whole dollar amounts). Moreover,

Cisternino claimed that 108 employees made exactly $85,000 in salary, and all

had the exact same tax situation to generate $3,356 in FITW. However,

FITW is calculated based on multiple factors such as total wages, filing

status,4 and number of exemptions, 5 so it would be highly unusual for that

many people to have identical amounts ofFITW. Further, the total FITW for

all 441 Form W-2s was $2,246.438.00, which, when evenly divided by quarter,

comes to $562,109.50. The total amount ofFITW on the Form W-2s has the

appearance of being a predetermined number with the goal of being evenly

divisible by four so that it creates a simple calculation for the 941 Forms

4
For example, single or married filing separately, married filing joint, or head
of household.
5
For example, the number of dependents an individual can claim along with
additional withholdings depending on an individual's tax situation or the
individuals combined tax situation with a spouse.

13
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submitted to Fountainhead, 6 and not an honest calculation by a business

calculating a tax liability.

33. Based on all the above inconsistencies contained in the 2019

Form 1120, 2019 profit and loss statement, 441 2019 Form W-2s for alleged

employees ofMagnifi.Co, and four 2019 Form 941 Employers Quarterly

Federal Tax Returns, it is believed these documents are false/fictitious and

were submitted in order to obtain a PPP loan for Magnifico that the company

was not entitled too.

IV. The Funding of the Fraudulently Obtained PPP Loan

34. On or about May 27, 2020, Magnifi.Co's PPP loan was approved

by Fountainhead in the amount of$7,210,000. The following day, the funds

were wired into Magnifi.Co's Radius Bank account ending in 7809 from

Fountainhead's account ending in 5588 at Capital One N.A. 7 Prior to this

deposit, the account balance was $89 .44.

35. After the funding of the loan, the following notable purchases

were made using the funds in the Radius Bank account ending in 7809:

6
As noted above, this figure does not match the total of FITW listed in the
combined Form 941s, but it appears as a planned amount.
7
Capital One N .A. utilizes servers in either Virginia or Oregon to handle the
sending of wire payments, and Radius Bank utilizes servers in Florida to
receive wire transfers.

14
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• Check 0001, dated May 30, 2020, for $89,413.71 made payable
to Alex Karras Lincoln with "Don Cistemino Lincoln
Navigator" 8 in the memo line;

• Check 0005, dated June 9, 2020, for $1,440,000.00 made payable
to Victor A. Cisternino with "Repayment of Loan" in the memo
line·
'
• Check 0008, dated June 22, 2020, for $251,436.21 made payable
to Mercedes-Benz ofSarasota; 9

• Check 0009, dated June 25, 2020, for $48,477.26 made payable
to Chase Auto Finance with "Maserati Payoff: Acct #
0011070037" in the memo line;

• June 26, 2020 wire transfer for $40,903.80 to Relin, Goldstein
and Crane LLP; 10

• Check 0010, dated June 28,2020, for $7,122.31 made payable to
ABBA Fund with "Lori Ann Quasky-Final Payment" in the
memo line;

• June 29, 2020 wire transfer for $90,600.00 to Godaddy.com;

• Check 0011, dated June 30, 2020, for $7,473.38 made payable to
Nissan Motor Acceptance Corporation with "Payoff for Nissan
for Lori Ann Quasky" in the memo line;

8
According to records from the Driver and Information Database (DAVID),
this vehicle was registered to Cistemino, but no longer has a valid registration.
9
According to records from DAVID, Cistemino had a Mercedes Benz S650X
(which has a base MSRP of$202,550) registered in his name, but no longer
has a valid registration.
10
Relin, Goldstein, and Crane LLP represented Cistemino in a matter filed by
American Express Centurion Bank in the New York Supreme Court. A final
judgement was entered for American Express on or about June 21, 2020.

15
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• Check 0013, dated July 8, 2020, for $3,000.00 made payable to
Rex Moving with "Deposit-Move" in the memo line;

• Check 0015, dated July 9, 2020, for $5,555.97 made payable to
Gale V[illegible] with "Bradenton->Chuluota" in the memo line;

• August 10, 2020 wire transfer for $54,031.63 to Godaddy.com,
with the wire detail noting "purchase of Domain iagent.com;"
and

• August 18, 2020 wire transfer for $121,000.00 to Godaddy.com,
with the wire detail noting "Purchase of domain
Magnifico.com."

36. Of interest, there were no checks written to any of the individuals

listed on the Form W-2s supplied by Cisternino. There were no direct

payments to any payroll companies, rent or utilities. A limited amount of

funds were spent on what appear to be possible business purposes·, including a

check made payable to Colin Broderic Supermoon Productions for

$327,692.30, an international wire to MKlStudios LTD for $75,000.00, and

debit purchases at Toptal.com totaling $21,117.80. 11

A. Purchase of the Defendant Property

37. On or about June 29, 2020, Cisternino wired $200,000 of the

PPP fraud proceeds in the Radius Bank account ending in 7809 to Premiere

11
Toptal.com is a website to hire freelance talent for projects. There were an
additional $16,579.25 in debit purchases attempted at Toptal.com, but the
account was over drafted and the debits were rejected.

16
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Title Insurance Co., LLC notating a deposit for the Defendant Property in the

description detail of the wire transfer. 12

38. On or about July 6, 2020, Cistemino wired $3,104,000 of the

PPP fraud proceeds in the Radius Bank account ending in 7809 to Premiere

Title Insurance Co., LLC notating "Balance of Purchase Price for 3018

KINGFISHER PT CHULUOTA FL 32766 for DON CISTERNINO, CEO

MAGNIFICO INC."

39. Public records indicate that on or about July 7, 2020, Cistemino

and Quasky purchased the Defendant Property for $3,499,000, and no

mortgage was filed against the property. 13 The Defendant Property sits on

twelve plus acres, and is approximately 12,579 square feet with seven

bedrooms, 11 bathrooms, a four car garage, theater room, "resort style" pool

and spa area, tennis courts, and a 5 stall horse barn. Below are pictures of the

Defendant Property:

12
Excluding fraud proceeds, the only other deposits into the account over
$100 during the relevant time frame were from interest payments and debit
card reward payments.
13
At this time, law enforcement is not sure where the remaining $195,000
came from for the full payment towards the purchase of the Defendant
Property.

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CONCLUSION
40. As required by Supplemental Rule G(2)(f), the facts set forth

herein support a reasonable belief that the government will be able to meet its

burden of proof at trial. Specifically, probable cause exists to believe that the

Defendant Property was purchased with proceeds of a wire fraud scheme that

operated in violation of 18 U.S.C. § 1343, and property involved in money

laundering offenses, and is therefore subject to forfeiture pursuant to 18 U.S.C.

§§ 981(a)(l)(A) and (a)(l)(C).

Dated: December l7 , 2020 Respectfully Submitted,

MARIA CHAP A LOPEZ
United States Attorney

By: £)~ n.urf 11n
~ ND~
Assistant United States Attorney
Florida Bar Number 0820601
400 W. Washington Street,
Suite 3100
Orlando, Florida 32801
(407) 648-7500-telephone
(407) 648-7643 - facsimile
Email:
nicole. andrejko@usdoj.gov

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Case 6:20-cv-02306-PGB-EJK Document 1 Filed 12/17/20 Page 22 of 22 PageID 22

VERIFICATION

I, Jacob Stafford, hereby verify and declare under penalty of perjury,
I

that I am a Special Agent ¥th the Internal Revenue Service, and pursuant

to 28 U .S.C. § 1746: (1) I have read the foregoing Verified Complaint for
I
Forfeiture in Rem and know the contents thereof; and (2) that the matters
! .

contained in the Verified qomplaint are true to my own knowledge and

belief.

The sources of my ~owledge and information and the grounds of

my belief are the official files
I
and records of the Internal Revenue Service,·

as well as my investigation iof this case together with other law
i

enforcement agents. I hereby verify and declare under penalty of perjury

that the foregoing is true ~d correct.
j ,_-,11
Executed this ...J...L day of December, 2020.
I

Special Agent
Internal Revenue Service

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