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Indictment — United States v. Christopher A. Mazzei and Erin V. Mazzei, District of Hawaii (Document 1)

Summary

An indictment filed May 26, 2022 as Document 1 in United States v. Christopher A. Mazzei and Erin V. Mazzei, Case 1:22-cr-00045-JMS, in the U.S. District Court for the District of Hawaii, citing 18 U.S.C. §§ 1343, 1349, 1956(h), and 1957. Count 1 charges conspiracy to commit wire fraud, alleging the defendants submitted PPP loan applications to Bank 1, Bank 2, and Bank 3 with fabricated IRS Form 941 and payroll records while concealing their ownership of other businesses, and obtained approximately $1,365,000.00 in PPP funds. Applications described include one for Better Half Entertainment LLC seeking $92,500 on or about April 10, 2020 and one for Gusto On The Go LLC seeking $562,500 that claimed 27 employees. The forfeiture allegations list seized funds and real property in Kapolei, Hawaii and Arroyo Grande, California.

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

“Indictment — United States v. Christopher A. Mazzei and Erin V. Mazzei, District of Hawaii (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-1-22-cr-00045-dkt-1-36cb20d432/, SHA-256 a5ea263ceeb3cfa1345a518f2685bf0388c5ef477e4c7129ee6ed506570ebd82.

Full text

Case 1:22-cr-00045-JMS Document 1 Filed 05/26/22 Page 1 of 24        PageID #: 1
       ORIGINAL                                          FILED IN THE
                                                  UNITED STATESDISTRICT COURT
                                                     DISTRICT OF HAWAII
  CLARE E . CONNOR S #7936
  United States Attmney                                  MAY 2 6, 2022
  District of Hawaii                                 (            A~
                                                 at_o'cloc k and_min .f_M
                                                  CLERK, U.S. District Court
  GREGG PARIS YATES #8225
  Assistant United States Attorney
  Room 6-100, PJKK Federal Building
  300 Ala Moana Boulevar d
  Honolulu, Hawaii 96850
  Telephone: (808) 541-2850
  E-mail: Gregg.Ya tes@usdo j.gov

  Attorneys for Plaintiff
  UNITED STATES OF AMERIC A


                  IN THE UNITED STATES DISTRIC T COURT

                        FOR THE DISTRIC T OF HAWAH

  UNITED STATES OF AMERIC A,                    )) CR.No.ai z2---0_0045JMS'
                      Plaintiff,           )     INDICTM ENT
                                           )
                     vs.                   )     [18 U.S.C. §§ 1343, 1349,
                                           )     1956(h), and 1957]
  CHRISTO PHER A. MAZZEI , (1)             )
  ERINV. MAZZEI,           (2)             )
                                           )
                      Defendan ts.         )
 _ _ _ _ _ __ __ _                         ).




                                   INDICTM ENT

 The Grand Jury charges:

 II

 II
Case 1:22-cr-00045-JMS Document 1 Filed 05/26/22 Page 2 of 24         PageID #: 2




                                General Allegations

      At all times relevant to this Indictment:

               The Defendants and the Relevant Business Entities

      1.    CHRISTOPHER A. MAZZEI and ERIN V. MAZZEI, the defendants,

have been married since 2008. CHRISTOPHER and ERIN MAZZEI resided in

Arroyo Grande, California.

      2.    BETTER HALF ENTERTAINMENT LLC (BHE) was headquartered

in San Luis Obispo, California and was a film and television production business.

According to its filings with the California Secretary of State, BHE was established

on July 2, 2018, and listed both CHRISTOPHER and ERIN MAZZEI as its only

members or managers.

      3.    BETTER HALF PRODUCTIONS INC. (BHP) was headquartered in

Beverly Hills, California and was a film and television production business. BHP

was established on January 7, 2020, and ERIN MAZZEI was the sole registered

owner of this corporation.

      4.    GUSTO ON THE GO LLC (GOTG) was headquartered in San Luis

Obispo, California and was a catering business. GOTG was established on

January 22, 2013 , and CHRISTOPHER MAZZEI' s mother was the sole registered

owner. The last filing for this corporation occurred on October 28, 2019, and the

corporation was suspended thereafter.
                                          2
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                   Overview of the Paycheck Protection Program

      5.     The United States Small Business Administration (SBA) is an

executive-branch agency of the United States government that provides support to

entrepreneurs and small businesses. The SBA's mission is to maintain and

strengthen the nation's economy by enabling the establishment and viability of

small businesses and by assisting in the economic recovery of communities after

disasters. The SBA enables and provides for loans through banks, credit unions,

and other lenders that have government-backed guarantees. The SBA also

provides direct loans.

      6.     On March 13, 2020, the President of the United States declared that

the Coronavirus Disease 2019 (COVID-19) pandemic was an emergency under

Section 501(b) of the Robert T. Stafford Disaster Relief and Emergency Assistance

Act, 42 U.S.C. 5121-5207. Shortly afterward, on March 27, 2020, the

Coronavirus Aid, Relief, and Economic Security (CARES) Act was enacted 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 up to $349 billion in

forgivable loans to small businesses for job retention and certain other expenses

through a program referred to as the Paycheck Protection Program (PPP). In or



                                         3
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around April 2020, Congress authorized over $300 billion in additional PPP

funding.

        7.   To obtain a PPP loan, a qualifying business must submit a PPP loan

application. The PPP loan application requires the business, through its

authorized representative, to acknowledge the program rules and make ce1iain

affirmative certifications. The business, through its authorized representative,

must state, among other things, its: (a) average monthly payroll expenses; and (b)

number of employees. These figures are used to calculate the amount of money

the business is eligible to receive under the PPP. In addition, businesses applying

for a PPP loan must provide documentation showing their payroll expenses.

        8.   A PPP loan application must be processed by a paiiicipating lender,

such as a financial institution. If a PPP loan application is approved, the

participating lender funds the PPP loan using its own monies, but repayment is

100% 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, is transmitted by the lender to the SBA in the course of processing the

loan.

        9.   PPP loan proceeds may only be used by the business for specific types

of expenses- payroll costs, interest on mmigages, rent, and utilities.


                                          4
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                           Relevant Financial Institutions

      10.    Bank 1 is based in the State of Pennsylvania. Bank 1 was an

approved SBA lender and participated as a lender in the PPP.

      11.    Bank 2 is based in the State of Maine. Bank 2 was an approved SBA

lender and participated as a lender in the PPP.

      12.    Bank 3 is based in the State of Hawaii. Bank 3 is an approved SBA

lender and participated as a lender in the PPP.

      13.    Bank 4 is based in the State of California. CHRISTOPHER and

ERIN MAZZEI were the signatories on a business account at Bank 4 in the name

of BETTER HALF ENTERTAINMENT LLC dba GUSTO ON THE GO

CATERING.

      14.    Bank 5 is based in the State of California. CHRISTOPHER and

ERIN MAZZEI were the signatories on two business accounts at Bank 5, both in

the name of BHP. CHRISTOPHER MAZZEI's mother was also a signatory on

one of the accounts.

      15.    Bank 6 is based in the State of California. CHRISTOPHER and

ERIN MAZZEI were the signatories on a business account at Bank 6 in the name

of BHP.




                                          5
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      16.   Bank 7 is based in the State of California. CHRISTOPHER and

ERIN MAZZEI, along with P.H., were the signatories on a business account at

Bank 7 in the name of a production company, R.B.F.

      17.   Bank 8 is based in the District of Hawaii. CHRISTOPHER and

ERIN MAZZEI were the signatories on a business account at Bank 8 in the name

of MY BETTER HALF ENTERTAINMENT INC.

      18.   Banks 1 through 8 are "financial institutions" as defined in Title 18,

United States Code, Section 20.



                                     Count 1
                        Conspiracy to Commit Wire Fraud
                               (18 u.s.c. § 1349)

      The allegations contained in Paragraphs 1 through 18 of this Indictment are

hereby realleged and incorporated by reference.

                         The Conspiracy and Its Objects

      19.   From a precise date unknown, but by at least in or around April 2020,

and continuing to in or around May 2020, within the District of Hawaii and

elsewhere, CHRISTOPHER A . MAZZEI and ERIN V. MAZZEI, the defendants,

did knowingly combine, conspire, and agree with each other and with other

persons known and unknown to commit an offense against the United States,



                                         6
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namely wire fraud affecting financial institutions, a violation of Title 18, United

States Code, section 1343.

                               Purpose of the Conspiracy

      20.    The purpose of the conspiracy was for CHRISTOPHER and ERIN

MAZZEI to obtain money from the PPP and its participating lenders by submitting

false loan applications and supporting documents. CHRISTOPHER and ERIN

MAZZEI submitted such false loan applications and supporting documents to

Bank 1, Bank 2, and Bank 3, while concealing their ownership interest in multiple

companies and the fact that they were submitting multiple PPP loan applications

based on false payroll expenses. As a result of the scheme, CHRISTOPHER and

ERIN MAZZEI obtained approximately $1,365,000.00 in PPP funds, which they

transferred to their own accounts and used for their personal benefit contrary to

PPP rules.

                       Manner and Means of the Conspiracy

      21.    The manner and means by which CHRISTOPHER and ERIN

MAZZEI sought to accomplish the purpose of the conspiracy included, among

other things, the following:




                                           7
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                              PPP Application to Bank 1

       22.   On or about April 10, 2020, CHRISTOPHER MAZZEI submitted a

PPP loan application, signed by ERIN MAZZEI, to Bank 1 in the name of BHE,

seeking $92,500 in PPP funds. CHRISTOPHER MAZZEI transmitted and caused

to be transmitted the application to Bank 1 by means of interstate wires, namely E-

mail. In the PPP application, ERIN MAZZEI claimed that she held a 100%

ownership interest in BHE, that BHE had 12 employees and an average monthly

payroll of $37,000, and that the loan was for "payroll" and "lease/mortgage

interest."

       23.   Fmthermore, as patt of her application, ERIN MAZZEI ce1tified that:

             a. on February 15, 2020, BHE was in operation and the loan funds

                 would be used to retain workers, maintain payroll or make

                 mortgage interest payments, lease payments and utility payments;

             b. between February 15, 2020 to December 31, 2020, BHE had not

                 and would not receive another PPP loan; and

             c. neither BHE nor any of its owners had any other ownership in a

                 business or common management with any other business.

       24.   In fact, and contrary to the foregoing representations, ERIN MAZZEI

held an ownership interest in another business, BHP, and was purportedly an

officer of that business as well.
                                          8
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      25.   CHRISTOPHER and ERIN MAZZEI also provided Bank 1 with false

records purporting to show the amount of wages paid to BHE' s employees, as

required for PPP loans. In support of the BHE PPP application, CHRISTOPHER

and ERIN MAZZEI provided Internal Revenue Service (IRS) Form 941 records

(Employer's Quarterly Federal Tax Return) for the first and second quarter of

2019, which BHE had purportedly submitted to the IRS. These Form 941 records

described the business name as "BETTER HALF ENTERTAINMENT LLC dba

GUSTO ON THE GO CATERING." The Form 941 records for the first and

second quarter of2019 purpmied to show that BHE paid $111,000 and $114,000 in

wages, respectively, in each of these quarters. Both the IRS Form 941 records

submitted by CHRISTOPHER and ERIN MAZZEI in support ofBHE's PPP loan

application to Bank 1 bore ERIN MAZZEI' s signature and date, as required for a

submission to the IRS.

      26.   In fact, and contrary to the foregoing representations, BHE had not

filed any Fmm 941 records with the IRS, and the records provided to Bank 1 were

fabricated to supp011 BHE' s false claims about employee wages, so as to qualify

for a PPP loan.

      27.    CHRISTOPHER and ERIN MAZZEI further provided Bank 1 with

false payroll records to bolster BHE's loan application. CHRISTOPHER and

ERIN MAZZEI submitted payroll records for "BETTER HALF
                                        9
Case 1:22-cr-00045-JMS Document 1 Filed 05/26/22 Page 10 of 24        PageID #: 10




ENTERTAINMENT LLC dba GUSTO ON THE GO CATERING" that

purportedly showed wages paid for the first and second quarters of 2019 and the

first quai1er of 2020. In fact, and as CHRISTOPER and ERIN MAZZEI knew,

neither BHE nor GOTG had filed employment tax returns, wage rep011s, payroll

tax deposits, or any other records with the California Employment Development

Department, as required by California state law.

      28.   Prior to the loan closing, ERIN MAZZEI signed a Bank 1 form

entitled "Authorization for PPP Loan Disbursement" in which she reaffirmed that

the PPP loan funds would be used solely for business-related payroll, m011gage

interest, lease payments, and utilities, and acknowledged an understanding that the

unauthorized use of funds could carry legal consequences such as "charges of

fraud."

      29.   In reliance on the false representations and documents submitted by

CHRISTOPHER and ERIN MAZZEI, Bank 1 approved a loan for BHE. On or

about April 27, 2020, Bank 1 wired $92,500 to a Bank 4 account ending 8237

(x8237), maintained in the name of BETTER HALF ENTERTAINMENT LLC

dba GUSTO ON THE GO CATERING.




                                        10
Case 1:22-cr-00045-JMS Document 1 Filed 05/26/22 Page 11 of 24        PageID #: 11




                            PPP Application to Bank 2

       30.   On or about April 13, 2020, CHRISTOPHER MAZZEI submitted a

PPP loan application to Bank 2 in the name of GOTG seeking $562,500 in PPP

funds. CHRISTOPHER MAZZEI transmitted and caused to be transmitted the

GOTG PPP application to Bank 2 by means of interstate wires, namely Bank 2' s

internet portal. In the PPP application, CHRISTOPHER MAZZEI claimed that he

held a 100% ownership interest in GOTG, and that GOTG had 27 employees and an

average monthly payroll of $225,000. The sole purpose checked for GOTO's PPP

loan was "payroll."

       31.   CHRISTOPHER MAZZEI certified that (a) GOTG was in operation

on February 15, 2020, (b) that the loan funds would only be used to retain workers,

maintain payroll or make mortgage interest payments, lease payments and utility

payments, and (c) that between February 15, 2020 and December 31 , 2020, GOTG

had not received, and would not receive, another PPP loan.

       32.   On the GOTG PPP application, CHRISTOPHER MAZZEI answered

"no" to the question as to whether the applicant [GOTG] or any owner of the

applicant had any ownership interest in another business or common management

with any other business. In fact, and as he well knew, CHRISTOPHER MAZZEI

was a 50% owner and an officer of BHP.


                                        11
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      33.    CHRISTOPHER MAZZEI also submitted falsified records to Bank 2

to support the GOTG PPP loan application. In support of the GOTG application,

CHRISTOPHER MAZZEI submitted IRS Form 941 records for the first, second,

third and fom1h qua11ers of 2019 that GOTG had purportedly filed with the IRS.

These Form 941 records described the entity's business name as "GUSTO ON

THE GO LLC" and represented that GOTG had paid 2019 quarterly wages of

$848,900, $855,900, $1,404,250, and $300,550, respectively. The IRS Form 941

records submitted by CHRISTOPHER MAZZEI in supp011 ofGOTG's PPP loan

application to Bank 2 bore CHRISTOPHER MAZZEI's signature and date, as

required for filings with the IRS.

      34.    In fact, and contrary to CHRISTOPHER MAZZEI's representations,

GOTG had not filed any F01m 941 records with the IRS for 2019. Instead, the

IRS Form 941 records that CHRISTOPHER MAZZEI submitted to Bank 2 in

supp011 of the GOTG PPP loan application were created for the purpose of

supporting BHE' s false claims about employee wages and thereby to qualify for a

PPP loan.

      35.    CHRISTOPHER MAZZEI also submitted falsified records to Bank 2,

purporting to show payroll paid by "GUSTO ON THE GO LLC" to its employees

for the first and second quarters of2019 and the first quai1er of 2020. In fact, and

as CHRISTOPER MAZZEI then knew, GOTG had not filed employment tax
                                         12
Case 1:22-cr-00045-JMS Document 1 Filed 05/26/22 Page 13 of 24          PageID #: 13




returns, wage reports, payroll tax deposits, or any other records with the California

Employment Development Department, as required by California state law.

Contrary to the payroll records submitted to Bank 2, GOTG's last corporate filing

with the State of California occurred on October 28, 20 19, and the corporation was

suspended from doing business at some point afterward.

      36.    On or about April 26, 2020, CHRISTOPHER MAZZEI signed U.S.

Small Business Administration Loan Form 147, affirming that the information and

documents submitted were true and accurate, and acknowledging that the provision

of false information could result in criminal liability.

      3 7.   In reliance on the false representations and documents, Bank 2

approved the GOTG loan application and on April 27, 2020, wired $562,500 to

Bank 4 account ending 8237 (x8237), maintained in the name of BETTER HALF

ENTERTAINMENT LLC dba GUSTO ON THE GO CATERING.

                              PPP Application to Bank 3

      38.    On or about April 25, 2020, CHRISTOPHER MAZZEI submitted to

Bank 3, which is headquartered in the District of Hawaii, a loan application in the

name of BHP seeking $710,333.333 in PPP funds . CHRISTOPHER MAZZEI

transmitted and caused to be transmitted the BHP PPP application to Bank 3 by

means of interstate wires, namely E-mail.      CHRISTOPHER MAZZEI claimed

that BHP had an average monthly payroll of $284,133.33 and that the loan was for
                                      13
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"payroll." The application also stated that CHRISTOPHER and ERIN MAZZEI

each owned 50% of BHP, and held the titles CEO and President, respectively.

      39.    CHRISTOPHER MAZZEI falsely stated that: (a) BHP was in

operation on February 15, 2020; (b) the loan funds would be used to retain

workers, maintain payroll or make mortgage interest payments, lease payments and

utility payments; and (c) that from February 15, 2020 to December 31, 2020, BHP

had not r·eceived, and would not receive, another PPP loan.

      40.    In fact, and contrary to the foregoing representations, BHP was not

established until January 7, 2020, and did not obtain an Employer Identification

Number (EIN) from the IRS, which was required to operate and pay employment

taxes, until April 9, 2020. To bolster his claims about BHP's operations prior to

February 15, 2020, CHRISTOPHER MAZZEI submitted to Bank 3 the 2019

payroll and IRS employment tax records for a different entity, GOTG.

      41 .   CHRISTOPHER MAZZEI also falsely represented that neither BHP

nor any of its owners had an ownership interest in, or shared common

management, with another business. In fact, and as he well knew,

CHRISTOPHER MAZZEI claimed that he was a 100% owner of GOTG in his

loan application to Bank 2, and CHRISTOPHER MAZZEI and ERIN MAZZEI

jointly managed BHE.


                                        14
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      42.    CHRISTOPHER MAZZEI also submitted falsified records to Bank 3

in supp01t of BHP's loan application. As supp01t for BHP's representations

relating to its wage expenditures, CHRISTOPHER MAZZEI submitted IRS Form

941 records for the first and second quarters of 2019 for "GUSTO ON THE GO

LLC," and for first quaiter of 2020 for "BETTER HALF PRODUCTIONS, INC.

dba GUSTO ON THE GO CATERING." All three IRS Form 941 records

submitted by CHRISTOPHER MAZZEI in support of the Bank 3 PPP loan

application bore CHRISTOPHER MAZZEI' s signatures and dates in 2019 and

2020, as would have been required for filings with the IRS.

      43.    In fact, and contrary to these representations, neither BHP, nor

GOTG, ever filed a Form 941 with the IRS. Instead, the purported IRS filings

submitted by CHRISTOPHER MAZZEI on behalf of BHP to Bank 3 were created

for the sole purpose of supporting BHP's loan application.

      44.    CHRISTOPHER MAZZEI also submitted falsified records to Bank 3,

purporting to show payroll paid by "GUSTO ON THE GO LLC" to its employees

for the first and second qua1ters of 2019 and the first quaiter of 2020. In fact, the

State of California's Employment Development Depaitment has no record of

employment tax retmns, wage rep01ts, payroll tax deposits, or any records,

submitted to it by or regarding BHP.


                                          15
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      45.    In reliance on the false statements and documents, Bank 3 approved

BHP's application and on or about May 11, 2020, mailed cashier's check

#18670465, dated May 7, 2020, in the amount of $710,332, made payable to BHP.

      All in violation of Title 18, United States Code, Section 1349.



                                      Count 2
                                     Wire Fraud
                                 (18 U.S.C. § 1343)

      46.    The allegations contained in Paragraphs 1 through 18, and 38 through

45 of this Indictment are hereby realleged and incorporated by reference.

      47.    From a precise date unknown, but by at least in or around April 2020,

and continuing to in or around May 2020, within the District of Hawaii and

elsewhere, CHRISTOPHER A. MAZZEI and ERIN V. MAZZEI, the defendants,

did knowingly devise and intend to devise a scheme and artifice to defraud, that is

to deceive and cheat, and to obtain money from the PP]? and Bank 3, a financial

institution, by means of materially false and fraudulent pretenses, representations,

and promises, well knowing at the time that such pretenses, representations, and

promises would be and were false when made.

      48.    As part of the scheme to defraud, CHRISTOPHER and ERIN

MAZZEI submitted and caused to be submitted to Bank 3 a PPP loan application

on behalf of BHP well knowing that this loan application attached documents and
                                         16
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contained representations that were false, as described in paragraphs 38-45 of this

Indictment. As a result of the scheme, CHRISTOPHER and ERIN MAZZEI

obtained approximately $710,332 in PPP funds to which they were not entitled,

and which they transferred to their own accounts for their personal benefit.

      49.    On or about April 25, 2020, in the District of Hawaii and elsewhere,

and for the purpose of executing the aforesaid scheme and artifice to defraud, and

attempting to do so, CHRISTOPHER and ERIN MAZZEI did knowingly transmit,

and cause to be transmitted, certain writings, signs, signals, pictures, and sounds in

interstate commerce, namely an E-mail from California to Bank 3, which is located

in the District of Hawaii, that attached a PPP loan application on behalf of BHP.

      All in violation of Title 18, United States Code, Sections 1343 and 2.



                                     Count 3
                           Conspiracy to Launder Money
                               (18 U.S.C. § 1956(h))

      50.    From a precise date unknown, but by on or about May 1, 2020, and

continuing to on or about December 4, 2020, within the District of Hawaii and

elsewhere, CHRISTOPHER A. MAZZEI and ERIN V . MAZZEI, the defendants,

did knowingly combine, conspire, and agree with each other and with other

persons known and unknown to commit money laundering offenses under Title 18,

United States Code, Section 1957, by knowingly engaging and attempting to
                                       17
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engage in monetary transactions, affecting interstate commerce, in criminally

derived property of a value greater than $10,000, with such property having been

derived from specified unlawful activity, namely conspiracy to commit wire fraud

and wire fraud, as charged in Counts 1 and 2 of the Indictment.

        51.     In furtherance of the conspiracy and to effect the objects thereof,

CHRISTOPHER A. MAZZEI and ERIN V. MAZZEI, conducted the following

transactions:

    #            Date        Amount                      Description

    1         05/01/2020 $50,000         Fund transfer by CHRISTOPHER
                                         MAZZEI from Bank 5 acct. no. x0096 to
                                         Bank 5 acct. no. x0 195
    2         05/21/2020 $26,869.13      Check by CHRISTOPHER MAZZEI
                                         from Bank 5 acct. no. x0195 to F.B. for
                                         mortgage payment on Oak Hill Road
                                         Property
    3         05/22/2020 $12,576.59      Check by CHRISTOPHER MAZZEI
                                         from Bank 4 acct. no. x8237 to F.B. for
                                         Home Equity Line of Credit payment on
                                         Oak Hill Road property
    4         07/06/2020 $293 ,000       Cashier's check by CHRISTOPHER
                                         MAZZEI from Bank 6 acct. no. 3230 to
                                         Bank 7 acct. no. x7416
    5         07/06/2020 $500,000        Cashier's check by CHRISTOPHER
                                         MAZZEI from Bank 5 acct. no. x0096 to
                                         Bank 7 acct. no. x7416
    6         11/24/2020 $43,524.06      Purchase of a 2019 Ford Expedition by
                                         ERIN MAZZEI from M.F. by check from
                                         Bank 5 acct. no. x0195 for $21,762.03
                                         and check from Bank 6 acct. no. 3230 for
                                         $21,762.03, signed by CHRISTOPHER
                                         MAZZEI
                                            18
Case 1:22-cr-00045-JMS Document 1 Filed 05/26/22 Page 19 of 24           PageID #: 19




    7         05/23/2020 $75,877.64     Check by ERIN MAZZEI from Bank 5
                                        acct. no. x0195 to S.M.F. for purchase of
                                        2019 Lincoln Navigator
    8         05/31/2020 $50,000        Check by ERIN MAZZEI from Bank 4
                                        acct. no. x8237 to P.F. for purchase of
                                        2020 Lincoln Aviator
    9         12/04/2020 $175,500       Wire transfer by ERIN MAZZEI from
                                        Bank 5 acct. no. x0096 to T.G.E.S., an
                                        entity based in the District of Hawaii, for
                                        down payment on a Koio Drive condo

        All in violation of Title 18, United States Code, Section 1956(h).



                                        Count 4
                                   Money Laundering
                                   (18 U.S.C. § 1957)

        52.    On or about December 4, 2020, within the District of Hawaii and

elsewhere, CHRISTOPHER A. MAZZEI and ERIN V. MAZZEI, the defendants,

did knowingly engage in, and attempt to engage in, a monetary transaction,

affecting interstate commerce, in criminally derived prope1iy of a value greater

than $10,000, namely, CHRISTOPHER and ERIN MAZZEI did transfer and cause

the transfer of $175,000 from Bank 5 acct. no. x0096 to T.G.E.S. in Hawaii, with

such property having been derived from specified unlawful activity, namely

conspiracy to commit wire fraud and wire fraud, charged in Counts 1 and 2 of the

Indictment.

        All in violation of Title 18, United States Code, Sections 1957 and 2.

                                          19
Case 1:22-cr-00045-JMS Document 1 Filed 05/26/22 Page 20 of 24            PageID #: 20




                                First Forfeiture Notice

       1.    The allegations contained in all paragraphs of Counts 1 and 2 of this

Indictment are hereby realleged and incorporated by reference for the purpose of

noticing forfeitures pursuant to Title 18, United States Code, Section 982(a)(2)(A)

and/or Title 18, United States Code, Section 981(a)(l)(C) and Title 28, United

States Code, Section 2461(c).

      2.     The United States hereby gives notice to CHRISTOPHER A.

MAZZEI and ERIN V. MAZZEI, the defendants, that, upon conviction of the

offenses charged in Counts 1 and 2 of the Indictment, the government will seek

forfeiture, in accordance with Title 18, United States Code, Section 982(a)(2)(A)

and/or Title 18, United States Code, Section 981(a)(l)(C) and Title 28, United

States Code, Section 2461 (c ), of any and all property, real or personal, that

constitutes or is derived from proceeds traceable to, or is obtained directly or

indirectly as a result of, the violations of Title 18, United States Code, Sections

1343 and 1349, including but not limited to a sum of money equal to at least

$1,365,332 in United States currency, including:

             a. $45,789.99 seized from Bank 8 acct. no. x8974 on or about May

                24, 2021;

             b. $538,203.61 seized from Bank 7 acct. no. 7416, on or about May

                25,2021;
                                          20
Case 1:22-cr-00045-JMS Document 1 Filed 05/26/22 Page 21 of 24           PageID #: 21




             c. $42,000 seized from P.F., a car dealership in San Luis Obispo,

                California, which represents the proceeds of the sale of a 2019

                Ford Expedition registered to ERIN V. MAZZEI;

             d. the real property located at 92-0143 Koio Drive, Unit M4-3, in

                Kapolei, Hawaii, and designated as Tax Map Key Number (1) 9-1 -

                056-005-0081 , together with all appurtenances and improvements;

                and

             e. the real property located at 1769 Oak Hill Road, in Arroyo Grande,

                California, and designated as Tax ID 044-332-0120, together with

                all appurtenances and improvements.

      3.     If by any act or omission of the defendants, any of the property

subject to forfeiture described in the preceding paragraph herein:

             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

                 divided without difficulty,

the United States of America will be entitled to the forfeiture of substitute property

up to the value of the property described above in the preceding paragraph,
                                         21
Case 1:22-cr-00045-JMS Document 1 Filed 05/26/22 Page 22 of 24           PageID #: 22




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

28, United States Code, Section 2461 (c).

                              Second Forfeiture Notice

      4.     The allegations contained in all paragraphs of Counts 3 and 4 of this

Indictment are hereby realleged and incorporated by reference for the purpose of

noticing forfeitures pursuant to Title 18, United States Code, Section 982.

      5.     The United States hereby gives notice to CHRISTOPHER A.

MAZZEI and ERIN V. MAZZEI, the defendants, that, upon conviction of the

offenses in violation of Title 18, United States Code, Sections 1956(h) and 1957,

charged in Counts 3 and 4 of this Indictment, the government will seek fo_rfeiture,

in accordance with Title 18, United States Code, Section 982(a)( 1), of any and all

property, real or personal, involved in the offenses, and all property traceable to

such property, including but not limited to:

             a. $45,789.99 seized from Bank 8 acct. no. x8974 on or about May

                24,2021 ;

             b. $538,203.61 seized from Bank 7 acct. no. 7416, on or about May

                25, 2021;

             c. $42,000 seized from P.F., a car dealership in San Luis Obispo,

                California, which represents the proceeds of the sale of a 2019

                Ford Expedition registered to ERIN V. MAZZEI;
                                          22
Case 1:22-cr-00045-JMS Document 1 Filed 05/26/22 Page 23 of 24           PageID #: 23




             d. the real property located at 92-0143 Koio Drive, Unit M4-3, in

                Kapolei, Hawaii, and designated as Tax Map Key Number ( 1) 9-1-

                056-005-008 l, together with all appmienances and improvements;

                and

             e. the real prope1iy located at 1769 Oak Hill Road, in Arroyo Grande,

                California, and designated as Tax ID 044-332-0120, together with

                all appurtenances and improvements.

      6.     If by any act or omission of the defendants, any of the property

subject to forfeiture described in the preceding paragraph herein:

             a. cannot be located upon the exercise of due diligence;

             b. has been transferred or sold to, or deposited with, a third paiiy;

             c. has been placed beyond the jurisdiction of the comi;

             d. has been substantially diminished in value; or

             e. has been commingled with other property which cannot be

                 divided without difficulty,

the United States of America will be entitled to the forfeiture of substitute property

up to the value of the property described above in the preceding paragraph,

II

II

II
                                         23
Case 1:22-cr-00045-JMS Document 1 Filed 05/26/22 Page 24 of 24         PageID #: 24




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

18, United States Code, Section 982(b)( 1).

      DATED: May 26, 2022, Honolulu, Hawaii.

                                              A TRUE BILL

                                              Isl Foreperson, Grand Jury
                                              Foreperson, Grand Jury




Assistant United States Attorney




United States v. Christopher A. Mazzei and Erin V. Mazzei
Indictment

Cr. No.   C,jf· 2 2 - .Q OO4 5 ~~s J



                                       24


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