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Indictment — United States v. Osaretin Eghaghe et al. (Eastern District of Texas, Document 1)

Summary

An Indictment, Document 1, filed 01/18/23 in Case 4:23-cr-00014-SDJ-AGD, United States of America v. Osaretin Eghaghe, a/k/a Biggie, and the other listed defendants, in the United States District Court for the Eastern District of Texas, Sherman Division. Count One charges conspiracy to engage in monetary transactions with criminally derived property, alleging that from in or about July, 2019 through in or about December, 2020 the defendants received fraud proceeds into bank accounts they opened and controlled. It alleges that the combined activity resulted in the laundering of more than $3,500,000 and that the funds came from romance scams, business email compromises, fraud schemes, and unemployment insurance fraud. The indictment then describes the alleged acts of individual defendants, including fraudulent EIDL loan funds and assumed name certificates used to open accounts.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Indictment — United States v. Osaretin Eghaghe et al. (Eastern District of Texas, Document 1).” Original at ecf.txed.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-4-23-cr-00014-dkt-1-e-d-tex-1d05bd6bd7/, SHA-256 25b120032890b491193fe64afd8912690162567989a4656e2bda52d578db436c.

Full text

Case 4:23-cr-00014-SDJ-AGD      Document 1   Filed 01/18/23   Page 1 of 18 PageID #: 1



                                                                          J N 1 8 2023
                           IN THE UNITED STATES DISTRICT COURT       Cterk, i.s, District Court
                                                                          lexas Eastern
                            FOR THE EASTERN DISTRICT OF TEXAS .
                                     SHERMAN DIVISION

   UNITED STATES OF AMERICA §                             S     D
                                             §
   V.                            §                                      014
                                                          Case No. 4:23-CR-
                                             §              Jordan
                                                          Judge
   OSARETIN EGHAGHE, (01) §
   a/k/a                 BIGGIE , §
   E RO OHWOVORIOLE, (02) §
   KENDRICK LAVELL COLLINS, (03) §
   LETISHA ANN STOVER, (04) §
   HONESTY MONEY WEIR, (05) §
   SPENCER LEONARD LEIGH, (06) §
   DANUIELLE FOWLER EDNEY, (07) §
   DIAMOND PLASHETTE EDWARDS, (08) §
   TABITHA LASHAWN DEBERRY, (09) §
   AMOS WILSON, (10) §
   ANDREW DEMARCUS PENNEY, (11) §
   DEMETRICS DEVON BLACK, (12) §
   IARRICK OTISHEY BUCKHANAN, (13) §
   IERICA JAREESE MATTHEWS, (14) §
   JOHN GANTT, (15) §
   LEMAR MARSH WN* COHEN, (16) §
   CHIBUIKE SAMUEL IWUH, (17) §
   CYNTHIA MECHELLE WILSON, (18) §
   DONTRELL LAMON AMIE, (19) §
   ENSLEY LEON NEAL, (20) §
   ERIC JASON VAUGHN, (21) §
   JEF ARI JERWAN RUCKER, (22) §
   JEREMIAH LEE GANTT, (23) §
   JOSHUA MATTHEW BAIIAM, (24) §
   LESLEY ODELL BROWN, (25) §
   MICHAEL ANDRE STUD AW AY, (26) §
   TAMARA DAWN THOMAS, (27) §
   TIMOTHY DWAYNE HOSTON, (28) §
   JAKEVION DESHAWN FREEMAN, (29) §

                                    INDICTMENT

   THE UNITED STATES GRAND JURY CHARGES:



   Indictment - Page 1
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                                           Count One
                                                         Violation: 18U.S.C. § 1956(h)
                                                         (Conspiracy to Engage in
                                                         Monetary Transactions with
                                                          Criminally Derived Property)

           1. From in or about July, 2019, continuing through in or about December,

   2020, the exact dates being unknown to the Grand Jury in the Eastern District of Texas

    and elsewhere, the defendants,


           Osaretin Eghaghe, A/K/A Biggie ,
           Ejiro Ohwovoriole,
           Kendrick Lavell Collins,
           Letisha Ann Stover,
           Honesty Money Weir,
           Spencer Leonard Leigh,
           Danuielle Fo ler Edney,
           Diamond Plashette Ed ards,
           Tabitha Lashawn Deberry,
           Amos Wilson,
           Andrew Demarcus Penney,
           Demetrics Devon Black,
           Jarrick Otishey Buckhanan,
           Jerica Jareese Matthews,
           John Gantt,
           Lemar Marshawn Cohen,
           Chibuike Samuel Iwuh,
           Cynthia Mechelle Wilson,
           Dontrell Lamon Amie,
           Ensley Leon Neal,
           Eric Jason Vaughn,
           Jefari Jerwan Rucker,
           Jeremiah Lee Gantt,
           Joshua Matthew Baham,
           Lesley Odell Brown,
           Michael Andre Studaway,
           Tamara Dawn Thomas,
           Timothy Dwayne Hoston,
           Jakevion Deshawn Freeman,




   Indictment - Page 2
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    did knowingly combine, conspire, and agree with each other and with other persons,

    known and unknown to the Grand Jury, to commit offenses against the United States in

    violation of Title 18, United States Code Section 1956, to wit: to knowingly conduct and

    attempt to conduct financial transactions affecting interstate commerce and foreign

    commerce, which transactions involved the proceeds of specified unlawful activity, that

    is, wire fraud, a violation of 18 U.S.C. § 1343, knowing that the transactions were

    designed in whole and in part to conceal and disguise the nature, location, source,

    ownership, and control of the proceeds of specified unlawful activity, and that while

    conducting and attempting to conduct such financial transactions, knew that the property

   involved in the fin ncial transactions represented the proceeds of some form of unlawful

   activity, in violation of Title 18, United States Code, Section 1956(a)(l)(B)(i) and

    1956(a)(2)(B)(i); while knowing the unlawful purpose of the agreement; and each of

   them joined in the agreement willfully, that is, with the intent to further its unlawful

   pui ose, in violation of Title 18, United States Code, 1956.


                                  Overview of the Conspiracy

           2. The defendants engaged in a conspiracy in which they received funds

   generated by fraud into bank accounts that they opened and controlled. Certain members

   of the conspiracy would direct the opening of accounts, communicate about the accounts,

   and direct the fraud proceeds to certain accounts for deposit. Following receipt of the

   funds the defendants used a variety of methods to transfer, withdraw, move, and use the




   Indictment - Page 3
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   funds for their own purposes and for the purposes of co-conspirators. Over time, the

   defendants combined activity resulted in the laundering of more than $3,500,000.

                                    Purpose of the Conspiracy

           3. It was the general purpose of the conspiracy for the defendants to conceal the

   source of the funds and to promote the carrying on of the fraud activity, all while

   knowing that the transactions were designed in whole or part to conceal and disguise the

   nature, location, source, ownership, and control of the proceeds of the fraud, and further

   to enrich themselves and others with the funds.

                              Manner and Means of the Conspiracy

           4. The manner and means by which the defendants sought to accomplish the

   purpose of the conspiracy included, among others, the following:

               a. The defendants and their co-conspirators communicated with each other by

                   phone, WhatsApp message, in-person meetings;

               b. Some of the defendants and their co-conspirators used code words to

                   communicate related to the conspiracy;

               c. The defendants and their co-conspirators received funds into their accounts

                   generated by a variety of deceptive schemes, including romance scams,

                   business email compromises, fraud schemes, and unemployment insurance

                   fraud;

               d. Certain of the defendants coordinated the receipt of fraud proceeds and

                   directed the proceeds to accounts that other conspirators designated as

                   available to receive fraud funds.



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               e. The defendants would open multiple bank accounts at various financial

                   institutions to receive funds generated by fraud. Some of the defendants

                   would file a document with local gove ment officials falsely representing

                   that they were operating a business under an assumed name, and then

                   would use this document to open a bank account in the name of a business

                   similar to that of an ongoing, legitimate business, so as to cause confusion

                   with the bank and to allow the defendant to deposit or receive funds in the

                   name of the business or to conceal their fraud and money laundering

                    activities;

               f. The defendants received money from fraud victims in various forms,

                   including wire transfers, Automated Clearing House transactions, fund

                   transfers, money orders, cash, and cashier s checks;

               g. The defendants used many financial accounts, oftentimes in a business

                   name or another individual s name, for the purpose of depositing,

                   withdrawing, and transferring victim money;

               h. The defendants and their co-conspirators used fraud victim money for

                   personal expenses;

               i. The defendants and their co-conspirators engaged in banking and financial

                    institution transactions, and caused wire transmissions, that affected

                    interstate and foreign commerce.

           5. Osaretin Eghaghe, a/k/a Biggie, engaged in and furthered the conspiracy

   by: using WhatsApp encrypted communications and messaging application to


   Indictment - Page 5
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    communicate with one or more co-conspirators related to bank accounts that were

    available to be used for money laundering; using WhatsApp to direct one or more

   individuals within the conspiracy to open financial accounts and engage in financial

   transactions constituting money laundering; and discussing and coordinating via

    WhatsApp numerous bank accounts and account-identifying information that could or

   would be used to launder funds.

           6. Ejiro Ohwovoriole engaged in and furthered the conspiracy by: possessing

    stolen identifying information for use in frauds and the money laundering activity;

    communicating with individuals about methods for carrying out the conspiracy; and

   possessing and attempting to destroy evidence of the conspiracy including checks

   belonging to a fraud victim.

           7. Kendrick Lavell Collins engaged in and furthered the money laundering

    conspiracy by: communicating with Osaretin Eghaghe about bank account information,

   numerous bank accounts and account-identifying information that could or would be used

   to launder funds opening bank accounts; receiving fraud funds from Diamond P.

   Edwards payable to Collins business Luxury Kutz; receiving and depositing a check

    comprised of fraud proceeds from Jarrick Otishey Buckhanan; depositing checks from

    Jerica Jareese Matthews comprised of fraudulent loan funds; depositing a cashier s

    check comprised of fraud proceeds from Danuielle Fowler Edney; and withdrawing

    cash, transferring funds to other bank accounts, and spending funds.

           8. Letisha Ann Stover engaged in and furthered the conspiracy by: depositing

    funds derived from a fraud scheme into a bank account Stover controlled; receiving and


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   depositing fraud-sourced funds from Jarrick Otishey Buckhanan; receiving and

   depositing funds from Michael Andre Studaway; receiving and depositing fraudulently

   procured funds from Jerica Jareese Matthews acting under an assumed business name;

   and removing funds from her account by withdrawals, transfers, and spending on

   personal purposes.

            9. Honesty Weir engaged in and furthered the conspiracy by: receiving money

   from fraud victims into a bank account that she controlled, including non-Texas state

   unemployment benefits meant for other individuals; receiving and depositing money

   from Jerica Jareese Matthews and John Gantt into her bank account; receiving

    fraudulent EIDL loan funds from Demetrics Black; withdrawing cash from her account;

    and transferring funds to Letisha Ann Stover and to Kendrick Lavell Collins.

            10. Spencer Leonard Leigh engaged in and furthered the conspiracy by:

    opening a bank account into which funds from a fraudulent EIDL loan received by

   Michael Andre Studaway were deposited; transferring money b check to co¬

    conspirators to Andrew Demarcus Penney and to another account that Lei h controlled;

   transferring funds to Demetrics Black in the form of a check; receiving fraudulent EIDL

    funds into a PayPal account he controlled; and transferring funds from his PayPal account

    to bank accounts he controlled.

            11. Danuielle Fowler Edney engaged in and furthered the conspiracy by:

    opening a bank account and receiving funds that were proceeds of a fraudulent Small

    Business Administration Loan, then withdrawing the funds or transferring them to

    Michael Andre Studaway; receiving a wire transfer in the amount of approximately


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   $60,000 that was comprised of funds received from a romance fraud victim and

   transferring funds by check to Kendrick Lavell Collins.

           12. Diamond Plashette Edwards engaged in and furthered the conspiracy by:

   filing an assumed name certificate with the Tarrant County Clerk, naming UT Logistics

   as the name of a business or professional entity; opening a bank account under the name

   of “Diamond P. Edwards - UT Logistics; filing an assumed name certificate in Denton

   County, Texas; receiving a wire transfer into the account from a victim of a fraud

   scheme; writing a check to John Gantt under the assumed business name (which Gantt

   deposited); transferring funds to Kendrick Lavell Collins in the name of an assumed

   business entity controlled by Collins; and withdrawing funds.

           13. Tabitha Lashawn Deberry engaged in and furthered the conspiracy by:

   depositing a check from Timothy D. Boston under an assumed business name into a

   bank account that she controlled; transferring funds by check to John Gantt (in the name

   Peak Energy Group) and by check to Letisha Ann Stover; and withdrawing funds in

   cash.


           14. Amos Wilson engaged in and furthered the conspiracy by: opening bank

   accounts and receiving and depositing Economic Injur Disaster Loan (“EIDL Loan )

   funds procured by fraud; withdrawing the funds and spending the funds on personal

   expenses; receiving and depositing loan funds procured by fraud and transferring funds to

   Andrew Demarcus Penney and to Cynthia Wilson; receiving and depositing funds

   from an account in the name of a synthesized identity, and thereafter withdrawing funds

   in cash and spending most of the rest.


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          15. Andrew Demarcus Penney engaged in and furthered the conspiracy by:

   receiving and depositing a check from Michael Andre Studa ay acting under a business

   name, then withdrawing cash and spending the funds on personal expenses; depositing a

   check from Amos Wilson, then withdrawing, spending, and transferring the funds;

   writing checks to himself and depositing them into another bank account he controlled;

   receiving multiple electronically-transmitted funds meant for a business not af iliated

   with Penney; writing checks to Demetrics Black; receiving wire transmissions of funds

   arising from a business email compromise; receiving as a deposit a Small Business

   Administration loan obtained by fraud and then withdrawing, transferring, or spending

   the f nds.

          16. Demetrics Black engaged in and furthered the conspiracy by: receiving a

   deposit into his bank account for Small Business Administration loan designated for an

   unaffiliated company, then transferring funds to Honesty Weir and to Black himself,

   which Black deposited in another bank account that he controlled; receiving funds

   transferred from PayPal into his bank account; receiving and depositing checks from

   Andre Penny; receiving a deposit of an automated clearing house electronic transfer

   resulting from a of a business email compromise fraud.

          17. Jarrick Otishey Buckhanan engaged in and furthered the conspiracy by:

   using multiple bank accounts in furtherance of the money laundering conspiracy; opening

   a bank account under an assumed business name and receiving and depositing funds from

   a fraudulent EIDL loan; receiving and depositing stolen checks made out to his assumed

   business name; receiving and depositing funds from a fraud victim also known as a


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                                          10




    money mule, then transferring funds to bank account that he controlled at a separate

   bank; writing a check to Letisha Ann Stover and to himself; receiving and depositing a

   check into an account he controlled under an assumed business name, then withdrawing

   funds and transferring funds to another account he controlled, and withdrawing funds

   from that account.

           18. Jerica Jareese Matthews engaged in the conspiracy by opening bank

   accounts under a d/b/a name and her own name, receiving money secured by fraud, and

   distributing funds to Kendrick Lavell Collins and Lemar M rshawn Cohen (both

   under assumed business names) and to herself by check.

           19. John Gantt engaged in the conspiracy by filing a certificate for an assumed

   business name; opening multiple bank accounts under an assumed business name;

   receiving fraudulently produced funds into those accounts from third parties and from

   Diamond P. Ed ards under an assumed business name; using PayPal to receive Payroll

   Protection Act loan funds and other funds procured by fraud and from Dontrell Amie,

   and by transferring funds to co-conspirators including Demetrics Black and Honesty

   Weir.


           20. Lemar Ma- sh h Cohen engaged in the conspiracy by: filing a certificate

   for an assumed business name in Denton County, Texas; opening a bank account under

   the assumed name; receiving and depositing fraudulently produced funds from co¬

   conspirators including Joshua Baham and Jerica Jareese Matthews; receiving

   fraudulently produced EIDL and PPP loans; and transferring funds by check to Danuielle

   Fowler Edney out of the PPP funds.


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          21. Chibuike hv engaged in the conspiracy by: receiving electronic

   transmissions of funds derived from inte et-based romance fraud; using his bank

   account to receive and deposit funds meant for other entities and individuals as well as

   cash and a check; and withdrawing and spending funds.

          22. Cynthia Wilson engaged in the conspiracy by: opening a bank account

   under an assumed business name and receiving a deposit of a check to her from Amos

   Wilson; and attempting to receive and deposit funds generated from a business email

   compromise scheme.


           23. Dontrel Amie received and deposited into his PayPal account an EIDL loan

   or grant procured by fraud and PPP loans procured by fraud; transferred funds to John

   Gantt and Demetrics Black (under an assumed business name); and transferred funds to

   A ie s own bank account.

           24. Ensley Neal engaged in and furthered the conspiracy by: depositing a check

   derived from a stolen identity scheme as provided by Kendrick Lavell Collins into a

   bank account that Neal controlled; and depositing a check into another bank that Neal

   controlled and then withdrawing funds at the direction of Kendrick Lavell Collins.

           25. Eric Vaughn engaged in and furthered the conspiracy by: opening bank

   accounts under an assumed business name; receiving a check from co-conspirator China

   Woods and thereafter withdrawing funds and transferring funds by check to Lesley

   Brown; and receiving funds for a third parly and transferring them to Kendrick Lavell

   Collins under an assumed business name; receiving a PPP loan intended for someone

   else into his bank account and writing checks to third parties including Ensley Ne l; and


   Indictment - Page 11
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                                          12




   receiving and depositing checks from Jarrick Otishey Buckhanan and Michael Andre

   Studaway, and thereafter withdrawing funds.

           26. Jerfari Rucker engaged in and furthered the conspiracy by: obtaining an

   assumed business name by filing a certificate in Denton County, Texas; opened a bank

   account in the name of the assumed name entity; received and deposited funds into a

   bank account that were generated by a business email compromise fraud scheme; and is

   referenced in WhatsApp communications.

           27. Jeremiah Gantt engaged in and furthered the conspiracy by: filing a

   certificate of assumed name in Denton County, Texas, and then opening a bank account

   under that name; depositing a stolen check into the account; and using another account to

   receive a wire meant for a third party and transferring funds to co-conspirators Kendrick

   Lavell Collins and Letisha Ann Stover.

           28. Joshua Baham engaged in and furthered the conspiracy by: filing a

   certificate of assumed name in Denton County, Texas, and opening bank accounts under

   that name; receiving funds from a business email compromise in an account and

   transferring the funds by check; transferring funds to Lemar Marshawn Cohen; and

   depositing funds generated by fraud and writing checks to Lemar Mar hawn Cohen and

    Luxury Kutz (z.e., Kendrick Lavell Collins).

           29. Lesley O Dell Bro n engaged in and furthered the conspiracy by: opening a

   bank account and depositing checks from Michael Andre Studaway and Eric Vaughn,

   and thereafter spending and withdrawing the funds by check or otherwise.




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          30. Michael Andre Studaway engaged in and furthered the conspiracy by:

   opening a bank account under an assumed business name and receiving funds meant for a

   third party; writing a check to John Gantt under an assumed business name; receiving a

   Small Business Administration loan and transferring most of the funds by check to

   Andrew Demarcus Penney and Spencer Leonard Leigh within a few days; receiving

   and depositing multiple wire transfers from Russia totalling over $300,000 into his bank

   account; transferring money by check to co-conspirators Kendrick Lavell Collins under

   an assumed business name and Eric Vau hn under an assumed business name; and

   transferring funds to himself by withdrawals.

          31. Tamara Thomas engaged in and furthered the conspiracy by: opening a

   bank account under an assumed business name and receiving funds resulting from fraud

   (some of which were returned) along with non-Texas state unemployment insurance

   payments; and transferring funds.

          32. Timothy Boston engaged in and furthered the conspiracy by: filing an

   assumed name certificate in Denton County, Texas; opening bank accounts in his own

   and an assumed business name; receiving deposits of funds from Mexico and Russia;

   writing a check to co-conspirator Tabitha Deberry (under a business name) and

   withdrawing funds; receiving a check from co-conspirator Diamond P. Ed ards and

   withdrawing funds; receiving and depositing a check from co-conspirator Michael

   Andre Studaway and withdrawing cash; and receiving Washington State unemployment

   benefits into his account and withdrawing funds.




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           33. Jakevion Deshawn Freeman engaged in and furthered t e conspiracy by:

   filing an assumed name certificate in Dallas County, Texas; opening multiple bank

   accounts; receiving and deposited funds from business email compromise fraud;

   receiving non-Texas unemployment insurance funds; writing checks on the account to

   transfer funds to others.




           All in violation of 18 U.S.C. § 1956(h).




   Indictment - Page 14
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                                              15




                  NOTICE OF INTENT TO SEEK CRIMINAL FORFEITURE

                                  Pursuant to 18 U.S.C. 982(a)(1)

            1. The allegations contained in paragraphs 1 - 33 of this Indictment are hereby

   realleged and incorporated by reference for the pur ose of alleging forfeitures pursuant to

   Title 18, United States Code, Sections 982(a)(1), as set forth below.

           2. Upon conviction of the offense of Conspiracy to Engage in Monetary

   Transactions with Funds Derived from Specified Unlawful Activity (in violation of 18

   U.S.C. § 1956(h)) alleged in Count One of this Indictment, the defendants herein shall

   forfeit to the United States any property, real or personal, involved in such offense, and

   any property traceable to such property, including, but not limited to, a money judgment,

   representing property, real or personal, involved in the commission of the violation of 18

   U.S.C. § 1956(h), for which the defendants are personally liable.

           Substitute Assets

           3. If any property subject to forfeiture, as a result of any act or omission by any

   of the defendants:

           (a) cannot be located upon the exercise of due diligence;

           (b) has been transferred or sold to, or deposited with a third party;

           (c) has been placed beyond the jurisdiction of the court;

           (d) has been substantially diminished in value; or

           (e) has been commingled with other property which cannot be subdivided

                    without difficulty,




   Indictment -- Page 15
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   the United States of America shall be entitled to forfeiture of substitute property pursuant

   to Title 21, United States Code, Section 853(p), as incorporated by Title 18, United States

   Code, Section 982(b)(1) and Title 28, United States Code, Section 2461(c).

           By virtue of the commission of the offense charged in this Indictment, any and all

   interest defendants have in the above-described property is vested in the United States and

   hereby forfeited to the United States pursuant to 18 U.S.C. § 982(a)(1).




   A TRUE BILL



   GRAND JURY FOREPERSON                                    Date




   BRIT FEATHERSTON
   UNITED STATES ATTORNEY



   THOMAS E. GIBSON                                         Date
   ASSISTANT U.S. ATTORNEY

   BRENT ANDRUS
   ASSISTANT U.S. ATTORNEY




   Indictment - Page 16
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                                             17




                                IN THE UNITED STATES DISTRICT COURT
                                 FOR THE EASTERN DISTRICT OF TEXAS
                                          SHERMAN DIVISION

   UNITED STATES OF AMERICA §                                S' D

                                                 §
   v.                                §                       Case No. 4:23-CR
                                                 §           Judge
   OSARETIN EGHAGHE, (01) §
   a/k/a BIGGIE , §
   E RO OHWOVORIOLE, (02) §
   KENDRICK LAVELL COLLINS, (03) §
   LETISHA ANN STOVER, (04) §
   HONESTY MONEY WEIR, (05) §
   SPENCER LEONARD LEIGH, (06) §
   DANUIELLE FOWLER EDNEY, (07) §
   DIAMOND PLASHETTE EDWARDS, (08) §
   TABITHA LASHAWN DEBERRY, (09) §
   AMOS WILSON, (10) §
   ANDREW DEMARCUS PENNEY, (11) §
   DEMETRICS DEVON BLACK, (12) §
   JARRICK OTISHEY BUCKHANAN, (13) §
   JERICA JAREESE MATTHEWS, (14) §
   JOHN GANTT, (15) §
   LEMAR MASHAWN COHEN, (16) §
   CHIB HIKE SAMUEL IWUH, (17) §
   CYNTHIA MECHELLE WILSON, (18) §
   DONTRELL LAMON AMIE, (19) §
   ENSLEY LEON NEAL, (20) §
   ERIC JASON VAUGHN, (21) §
   JEF ARI JERWAN RUCKER, (22) §
   JEREMIAH LEE GANTT, (23) §
   JOSHUA MATTHEW BAHAM, (24) §
   LESLEY ODELL BROWN, (25) §
   MICHAEL ANDRE STUD AWAY, (26) §
   TAMARA DAWN THOMAS, (27) §
   TIMOTHY DWAYNE HOSTON, (28) §
   JAKEVION DESHAWN FREEMAN, (29) §

                                     NOTICE OF PENALTY




   Notice of Penalty - Page 1
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                                        18




                                      Count One

     Violation:                    18 U.S.C. § 1956(h) (Conspiracy to Engage in
                                   Monetary Transactions with Funds Derived from
                                   Specified Unlawful Activity)

     Penalty:                      Imprisonment for a term not more than 20 years, a
                                   fine not to exceed $500,000.00, or not more than
                                   twice the amount of the property involved in the
                                   transaction, whichever is greater, or both. A term of
                                   supervised release of not more than three years in
                                   addition to such term of imprisonment.

   Special Assessment:             $100.00




   Notice of Penalty - Page 2


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