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
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“Indictment — United States v. Christopher A. Mazzei and Erin V. Mazzei, District of Hawaii (Document 1).”
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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
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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
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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
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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
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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.
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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
File and source
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- Our copy
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- Original
- archive.org