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Home Source documents Indictment — United States of America v. Arthur Spitzer, Mendel Deutsch

Indictment — United States of America v. Arthur Spitzer, Mendel Deutsch

Summary

An indictment returned by the Grand Jury for the District of New Jersey, sitting in Camden, against Arthur Spitzer, Mendel Deutsch and Joshua Feldberger, citing 18 U.S.C. § 1349, § 1344, § 1343, § 1014, § 1957(a) and § 2. Its introduction alleges that during 2019 and 2020 Spitzer obtained more than $20,000,000 in mortgage loans on New Jersey and Brooklyn, New York properties he did not own, using fraudulent documents. It further alleges that in 2020 and 2021 Spitzer and Deutsch obtained millions of dollars in government loans meant for small businesses distressed by the COVID-19 pandemic through applications with false statements. The indictment alleges that Spitzer obtained loans of $1,200,000 on each of two properties, for a total of $2,400,000.

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Full text

2021R00609IDAF
                     UNITED STATES DISTRICT COURT
                        DISTRICT OF NEW JERSEY

 UNITED STATES OF AMERICA                     Hon.

     v.

ARTHUR SPITZER,                               18 U.S. C. § 1349
MENDEL DEUTSCH, and                           18 u.s.c. § 1344
JOSHUA FELDBERGER                             18 u.s.c. § 1343
                                              18 U.S. C. § 1028A(a)(l)
                                              18 u.s.c. § 1014
                                              18 U.S.C. § 1957(a)
                                              18 u.s.c. § 2

                              INDICTMENT

      The Grand Jury in and for the District of New Jersey, sitting in

Camden, charges:

                              INTRODUCTION

      1.    During 2019 and 2020, defendant ARTHUR SPITZER orchestrated a

scheme to defraud property owners and mortgage lenders by obtaining mortgage

loans for real estate properties that SPITZER did not own. Defendant SPITZER

identified real estate properties in New Jersey and Brooklyn, New York that had

either no mortgages or mortgages in amounts significantly lower than the

property's market value. Working at times without co-conspirators charged in this

Indictment, and at other times with defendants MENDEL DEUTSCH and JOSHUA

FELDBERGER, defendant SPITZER obtained more than $20,000,000 in mortgage

loans by using fraudulent documents purportedly showing that he-or entities he

controlled-had the authority to apply for mortgage loans. The mortgage loan

proceeds were disbursed to bank accounts controlled by defendant SPITZER or were
used to otherwise benefit defendant SPITZER, such as to pay off defendant

SPITZER's debts. Defendant SPITZER then caused the mortgage loans to default

by not making the required payments, leaving the true property owners subject to

foreclosure and eviction.

        2.   Further, in 2020 and 2021, defendants ARTHUR SPITZER and

MENDEL DEUTSCH fraudulently obtained millions of dollars of government loans

that were intended for small businesses distressed by the COVID-19 pandemic by

submitting loan applications that included false statements about the applicant

companies' number of employees, revenues, cost of goods sold, or lost rents.

                                     COUNT 1
                                    (Wh-e Fraud)
                                     (56th St1·eet)

                                    Background

        1.   At all times relevant to this Indictment:

                                 Mortgage Lending

             a.     Mortgage loans were loans made by banks and other financial

institutions to borrowers: (a) in connection with the purchase of real estate; or (b) in

connection with the refinancing of real estate. Mortgage loans were secured by the

real estate property such that if the borrower defaulted on the loan, the lender

would have the ability to seek foreclosure of the real estate property securing the

loan.

             b.     A mortgage loan borrower typically applied for a mortgage loan

through a mortgage lender or a mortgage originator. If a borrower applied directly

with a mortgage lender, the borrower would p1·ovide documentation directly to the

                                           2
mortgage lender and the mortgage lender would directly fund the loan. If a

borrower applied with a mortgage originator, sometimes the mortgage originator

would make the initial loan to the borrower and then sell the loan to a mortgage

lender after a short period of time. Other times, the mortgage originator would

obtain and verify the relevant information for a mortgage lender, and then the

mortgage lender would issue the mortgage loan directly to the borrower. The

information submitted by a borrower was material to the mortgage lender's decision

whether or not to extend a mortgage loan.

            c.     A mortgage loan typically was closed by a settlement agent. The

settlement agent was responsible for receiving monetary instruments and funds

provided by the borrower and mortgage funds from the lender to the title company's

escrow account, and, when authorized by the parties to the transaction and the

lender, for disbursing those funds from the escrow account to various individuals

and entities, as detailed on the U.S. Department of Housing and Urban

Development Settlement Statement (hereinafter "HUD-1 Settlement Statement").

The HUD~l Settlement Statement detailed the actual disbursement of monies,

including mortgage fund loans, to the proper entities and/or individuals. The HUD-

1 Settlement Statement was required to accurately disclose the receipt and

disbursement of all monies involved in a real estate transaction, including whether

any monies were being used to pay off existing loans. The borrower and a

representative of the title company typically signed the HUD~ 1 Settlement

Statement affirming that it was true and accurate.



                                         3
                             Individuals and Entities

              d.    Defendant ARTHUR SPITZER was a resident of Toms River,

New Jersey.

              e,    Bank-1 was a "financial institution" within the meaning of Title

18, United States Code, Section 20.

              f.   BSD Realty Holdings, Inc. was a New Jersey company controlled

by defendant SPITZER. BSD Realty Holdings, Inc. had a bank account at Bank-1,

whose signatory was defendant SPITZER.

              g,   Mortgage Lender-I was a mortgage lender with its principal

place of business in California and therefore was a "financial institution" within the

meaning of Title 18, United States Code, Section 20. Mortgage Lender-1 made

mortgage loans directly to borrowers and also had relationships with mortgage

originators, who made mortgage loans to the borrowers under guidelines provided

by Mortgage Lender-I, which loans were then transferred to Mortgage Lender-I.

              h.    Mortgage Originator-1 was a New Jersey mortgage originator

that originated loans for Mortgage Lender-!. Mortgage Originator-1 also made

loans to defendant SPITZER that were not secured by real estate.

              i.   Settlement Company-1 was a title and real estate settlement

company located in Howell, New Jersey.

              J.   The Fedwire Funds Service ("Fedwire") was a real-time gross

settlement system that enabled participants to transfer funds from one financial

institution to another financial institution. Every Fedwire funds transfer involved



                                          4
an exchange of electronic communications between Federal Reserve facilities in

New Jersey and Texas.

                             The Scheme to Defraud

        2.   In or about August 2019, in Ocean County in the District of New

Jersey, Kings County in the Eastern District of New York, and elsewhere,

defendant

                                AR THUR SPITZER

did knowingly and intentionally devise and intend to devise a scheme and artifice to

defraud, ~nd aid and abet the scheme and artifice to defraud Individual-I and

Mortgage Lender-1, and to obtain money and property by means of materially false

and fraudulent pretenses, representations, and promises, which scheme and artifice

was in substance as set forth below.

                               Object of the Scheme

        3.   The object of the scheme was for defendant ARTHUR SPITZER to

financially enrich himself and satisfy outstanding debts by fraudulently obtaining

mortgage loans secured by real estate properties that he did not have authority to

use as collateral for the mortgage loans.

                        Manner and Means of the Scheme

        4.   It was part of the scheme that, prior to 2000, Individual-1 purchased

two residential buildings located on 56 th Street in Brooldyn, New York (the "56tb

Street Properties"). There were no mortgage loans on the 56 th Street Properties in

2019.



                                            5
      5.     It was further part of the scheme that in or around August 2019,

defendant SPITZER created an entity (the "56 th Street LLC") of which defendant

SPITZER was the sole member.

      6.     It was further part of the scheme that in or around August 2019,

defendant SPITZER caused to be prepared deeds purportedly transferring

ownership of the 56th Street Properties from Individual-1 to the 56t-h Street LLCs.

These deeds were prepared without Individual-l's understanding or authorization.

      7.     It was further part of the scheme that in or around August 2019>

defendant SPITZER, acting on behalf of the 56 th Street LLC, applied for and

obtained loans of $1,200,000 on each of the two 56th Street Properties (for a total of

$2,400,000) through Mortgage Originator-I and Mortgage Lender-1. The mortgage

loans were secured by the 56th Street Properties. Settlement Company-1 was the

settlement agent for the mortgage transaction. Settlement Company-1 employees

were located in New Jersey when they worked on the 56th Street transaction.

      8.     It was further part of the scheme that Mortgage Lender-1 wired the

mortgage p1·oceeds to Settlement Company-rs escrow account as follows:



8/27/2019         $1,191,611.65       Interstate wire, sent through the Fedwire
                                      system, from Mortgage Lender-l's bank
                                      account to Settlement Company-l's escrow
                                      account, representing the proceeds of the
                                      mortgage loan for the first of the 56 th Street
                                      Pro erties.




                                           6
 8/27/2019                               $1,191,611.65   Interstate wire, sent through the Fedwil'e
                                                         system, from Mortgage Lender-l's bank
                                                         account to Settlement Company-l's escrow
                                                         account, representing the proceeds of the
                                                         mortgage loan for the second of the 56th Street
                                                         Properties.

              9.             It was further part of the scheme that Settlement Company-1 wired

approximately $1,900,000 of the 56 th Street mortgage loan proceeds from its escrow

account to a bank account at Bank-1 in the name of BSD Realty Holdings, Inc.,

which was controlled by defendant SPITZER as follows:
                                                                                                                            ::;_-:


                                          ~~I!il?t-fr
                                                                                                                                           •.·.

·:/\.~_p#~iitr1~tft
: ;;: :: :·::-,Dat~f:, : :~:-. ~·> :.:
                                                                        '.ne_scHi,#oµ • · •-· .
                                                                                      :._:.-,.,.:__=:·-··_._--.-.. -.·-.·
                                                                                                                                            :::

                                                                                       •\,,.
                                                                                                                                     ·.:

 8/28/2019                               $850,250.00     Interstate wire, sent through the Fedwire
                                                         system, from Settlement Company-l's escrow
                                                         account to the BSD Realty Holdings, Inc. bank
                                                         account.
 8/28/2019                               $8,193.11       Interstate wire, sent through the Fedwire
                                                         system, from Settlement Company-l's escrow
                                                         account to the BSD Realty Holdings, Inc. bank
                                                         account.
 8/28/2019                               $20,391.11      Interstate wire, sent through the Fedwire
                                                         system, from Settlement Company-l's escrow
                                                         account to the BSD Realty Holdings, Inc. bank
                                                         account.
 8/28/2019                               $529,625.00     Interstate wire, sent through the Fedwire
                                                         system, from Settlement Company-l's escrow
                                                         account to the BSD Realty Holdings, Inc. bank
                                                         account.
 8/28/2019                               $529,625.00     Interstate wire, sent through the Fedwire
                                                         system, from Settlement Company- l's escrow
                                                         account to the BSD Realty Holdings, Inc. bank
                                                         account.

              10.            It was furthe1· part of the scheme that Settlement Company-1 wired

more than $300,000 of the 56 th Street mortgage loan proceeds to Mortgage

Originator- I to satisfy outstanding debts previously incurred by defendant

SPITZER as follows:
                                                             7
 4ppj;~jµ11.ate ./ :";: )1\:ppr,p~~ate .. ·•.
  · · .:·'bate,. · , • • • • • Amount •• ••
 8/28/2019           $253,000                   Interstate wire, sent through the Fedwire
                                                system, from Settlement Company-l's
                                                escrow account to the Mortgage Originator-
                                                1 bank. account.
 8/28/2019           $60,000                    Interstate wire, sent through the Fedwire
                                                system, from Settlement Company-l's
                                                escrow account to the Mortgage Originator-
                                                1 bank account.

       11.    It was further part of the scheme that Individual-! was not aware of

defendant SPITZER's actions with respect to the preparation of the deeds

purporting to transfer ownership of the properties to an entity controlled by

defendant SPITZER, and Individual-! did not authorize defendant SPITZER to

obtain mortgage loans secured by the 56th Street Properties.

       12.    It was further part of the scheme that Mortgage Lender-! would not

have funded these mortgage loans had it known that Individual-I did not authorize

the transfer of the 56 th Street Properties to an entity controlled by defendant

SPITZER and did not authorize defendant SPITZER to obtain mortgage loans

secured by the 56th Street Properties.

       13.    It was further part of the scheme that defendant SPITZER caused the

56th Street mortgage loans to default by failing to make the required payments.

                         Execution of the Scheme to Defraud

       14.    For the purpose of executing and attempting to execute the scheme

and artifice to defraud, in Ocean County in the District of New Jersey, Kings

County in the Eastern District of New York, and elsewhere, defendant

                                     ARTHUR SPITZER


                                                 8
did knowingly transmit and cause to be transmitted by means of wire communication

in interstate and foreign commerce, certain writings, signs, signals, pictures, and

sounds; including a Fedwire funds transfer on or about August 28, 2019 from the

bank account o:f Settlement Company-I, through processing facilities in New Jersey

and Texas, to the bank account of BSD Realty Holdings Inc.

      In violation of Title 18, United States Code, Sections 1843 and 2.




                                          9
                                      COUNT 2
                                     (Wire Fraud)
                                  (Division Avenue)

       1.     Paragraph 1 of Count 1 of the Indictment is incorporated as if set forth

in full herein.

                                    Background

       2.     At all times relevant to this Indictment:

              a.    Individual-2 was a resident of Brooklyn, New York. Individual-

2 owned and resided in an apartment in a building located on Division Avenue in

Brooklyn, New York (the "Division Avenue Property").

                                     The Scheme

       a.     In or about August 2019, in Ocean County in the District of New

Jersey, Kings County in the Eastern District of New York, and elsewhere,

defendant

                                ARTHUR SPITZER

did knowingly and intentionally devise and execute a scheme and artifice to defraud

Individual-2 and Mortgage Lender-1, and to obtain money and property by means of

materially false and fraudulent pretenses, representations, and promises, which

scheme and artifice was in substance as set forth below.

                               Object of the Scheme

       4.     The object of the scheme was for defendant AR'l'HUR SPITZER to

financially enrich himself and satisfy outstanding debts by fraudulently obtaining a

mortgage loan secured by a real estate property that he did not have authority to

use as collateral for t~e mortgage loan.
                                           10
                       Manner and Means of the Scheme

      5.    It was part of the scheme that Individual-2 purchased the Division

Avenue Property in or about 2001. There was no mortgage loan on the Division

Avenue Property in 2019.

      6.    It was further part of the sch~me that in or ·around September 2019,

defendant SPITZER created an entity (the "Division Avenue LLC,,) of which

defendant SPITZER was the sole member.

      7.    It was further part of the scheme that in or around September 2019,

defendant SPITZER caused Individual-2 to sign a deed transferring ownership of

the Division Avenue Property from Individual-2 to the Division Avenue LLC.

      8.    It was further part of the scheme that in or around September 2019,

defendant SPITZER, through the Division Avenue LLC, applied for and obtained a

$997,500 mortgage loan from Mortgage Lender-I that was secured by the Division

Avenue Property. Settlement Company-1 served as settlement agent for the

Division Avenue mortgage transaction. Settlement Company-1 employees were

located in New Jersey when they worked on the Division Avenue mortgage

transaction and the mortgage was notarized by a Settlement Company-I employee

in New Jersey.

      9.    It was further part of the scheme that on or about September 27, 2020,

Mortgage Lender-1 wired the mortgage proceeds via interstate wire, through the

Fedwil'e system, to Settlement Company- l's escrow account.

      10.   It was further part of the scheme that Settlement Company-! wired

approximately $500,000 of the Division Avenue mortgage loan from its escrow
                                        11
account to a bank account at Bank-1 in the name of BSD Realty Holdings, Inc.,

which was controlled by defendant SPITZER, as set forth in the following table:

 .A.ppr9~im~te..   :Approximate
 </::<:Date:>·:.    .';.;·~ount
 9/27/2019         $400,000.00       Interstate wire, sent tlu·ough the Fedwire
                                     system, from Settlement Company-l's escrow
                                     account to the BSD Realty Holdings, Inc. bank
                                     account.
 9/27/2019         $100,000.00       Interstate wire, sent tlu·ough the Fedwire
                                     system, from Settlement Company.. l's escrow
                                     account to the BSD Realty Holdings, Inc. bank
                                     account.

      11.    It was further part of the scheme that Settlement Company-! applied

approximately $420,500 of the Division Avenue proceeds towards defendant

SPITZER's purchase of another real estate property.

      12.    It was further part of the scheme that Individual-2 did not authorize

defendant SPITZER to obtain a $997,500 mortgage loan sectu·ed by the Division

Avenue Property.

      13.    It was further part of the scheme that Mortgage Lender-1 would not

have funded this mortgage loan had it known that Individual-2 did not authorize

defendant SPITZER to obtain a $997,500 mortgage loan secured by the Division

Avenue Property.

      14.    It was further part of the scheme that defendant SPITZER caused the

Division Avenue mortgage loan to default by not making the required payments.




                                         12
                      Execution of the Scheme to Defraud

      15.    For the purpose of executing and attempting to execute the scheme

and artifice to defraud, in Ocean County in the District of New Jersey, Kings

County in the Eastern District of New York, and elsewhere, defendant

                               ARTHUR SPITZER

did knowingly transmit and cause to be transmitted by means of wire communication

in juterstate and foreign commerce, certain writings, signs, signals, pictures, and

sounds, including a Fedwire funds transfer on or about September 27, 2019 from the

bank account of Settlement Company-1, through processing facilities in New Jersey

and Texas, to the bank account of BSD Realty Holdings Inc.

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




                                         13
                                    COUNTS
                                  (Wire Fraud)
                         (ISM Holdings - Company-1 loan)

       1.     Parag1•aph 1 of Count 1 of the Indictment is incorporated as if set forth

in full herein.

       2.     At all times relevant to the Inclictment:

              a.    ISM Holdings LLC was a New Jersey company.

              b.    The "ISM Properties" were a set of 15 residential buildings

located in Sicklerville, New Jersey, Newark, New Jersey, and Irvington, New

Jersey.

              c.    Company-1 was a New Jersey company owned by Individual-3.

                              The Scheme to Defraud

       3.     In or about December 2019, in Camden, Essex, and Ocean Counties in

the District of New Jersey, and elsewhere, defendant

                                   ARrrHUR SPITZER

did knowingly and intentionally devise and execute a scheme and artifice to defraud

Individual"4, and to obtain money and property by means of materially false and

fraudulent pretenses, representations, and promises, which scheme and artifice was

in substance as set forth below.

                                Object of the Scheme

       4.     The object of the scheme was for defendant ARTHUR SPITZER to

financially em·ich himself and satisfy outstanding debts by fraudulently obtaining a

mortgage loan secured by real estate properties that he did not have authority to

use as collateral for the mortgage loan.
                                           14
                       Manner and Means of the Scheme

      5.    It was part of the scheme that in or around March 2019, ISM Holdings

LLC purchased the ISM Properties. The purchase price of approximately

$3,900,000 was comprised of approximately $875,000 from Ind.ividual-4 and

approximately $3,100,000 in mortgage loans.

      6.    It was further part of the scheme that the operating agreement for

ISM Holdings LLC provided that the only members of ISM Holdings LLC were

Individual-4 and Individual-5. Under the te1·ms of the operating agreement,

Individual-4's consent was needed before any member could assign his membership

interest and before obtaining any mortgage loan secured by the ISM Properties.

      7.    It was further part of the scheme that in or around December 2019,

defendant SPITZER, purportedly acting as managing member of ISM Holdings

LLC, obtained a mortgage loan of approximately $400,000 from Individual-3,

secured by the ISM Properti_es. Documents reflecting a $400,000 mortgage loan

between Company- I and ISM Holdings LLC were notarized and recorded by a

Settlement Company-1 employee in New Jersey.

      8.    It was further pa1't of the scheme that on or about December 26, 2019,

Settlement Company-1 deposited into its escrow account a check in the approximate

amount of $388,000 with the notation "loan spitzer." Settlement Company-! then

wired approximately $365,000 of the loan proceeds from its escrow account to a

bank account in the name of BSD Realty Holdings, Inc., which was controlled by

defendant SPITZER as follows:



                                        15
      t!lt~f   8
                                                  .




                    Appr<>x.i.intite                  nes~rip#on
AP~                  ··Amou11t·•·                                                      .




 12/26/2019        $42,938.79          Interstate wire, sent through the Fedwil'e
                                       system, from Settlement Company-l's escrow
                                       account to the BSD Realty Holdings, Inc. bank
                                       account.
 12/26/2019        $57,350.04          Interstate wire, sent through the Fedwire
                                       system, from Settlement Company-l's escrow
                                       account to the BSD Realty Holdings, Inc, bank
                                       account.
 12/27/2019        $265,000.00         Interstate wire, sent tlll'ough the Fedwire
                                       system, from Settlement Company-l's escrow
                                       account to the BSD Realty Holdings, Inc. bank
                                       account.

      9.      It was further part of the scheme that Individual-4 was not aware of

defendant SPITZER's actions and did not authorize defendant SPITZER to obtain a

mortgage secured by the ISM Properties.

      10.     It was further part of the scheme that Company-1 would not have

funded this mortgage loan had it known that Individual-4's authorization was

required for ISM Holdings to obtain a mortgage loan and that Individual-4 did not

know about or authorize defendant Spitzer to obtain this mortgage loan.

                      Execution of the Scheme to Defraud

      11.     For the pm·pose of executing and attempting to execute the scheme

and artifice to defraud, in Camden, Essex, and Ocean Counties in the District of

New Jersey, and elsewhere, defendant

                                 ARTHUR SPITZER

did knowingly transmit and cause to be transmitted by means of wire communication

in interstate and fo1·eign commerce, certain writings, signs, signals, pictures, and

sounds, including a Fedwire funds transfer on or about December 27, 2019 from the


                                          16
bank account of Settlement Company- I, through processing facilities in New Jersey

and Texas, to the bank account of BSD Realty Holdings Inc.

      In violation of Title 18, United States Code, Sections 1843 and 2.




                                         17
                                    COUNT4
                                   (Wire Fraud)
                             (ISM Holding·s - Refinance)

       1.     Paragraph 1 of Count 1 of the Indictment, paragraph 2 of Count 2 of

the Indictment, and paragraphs 1 thwugh 10 of Count 3 of the Indictment are

incorporated as if set fm·th in full herein.

       2.    At all times relevant to the Indictment:

              a.    Mortgage Originator-2 was a mortgage originator that

originated loans for Mortgage Lender-1.

             b.      Settlement Company-2 was a title and real estate settlement

company located in Lakewood, New Jersey.

                               The Scheme to Defraud

      3.     In 01' about February 2020, in Camden, Essex, and Ocean Counties in

the District of New Jersey, and elsewhere, defendant

                                 ARTHUR SPITZER

did knowingly and intentionally devise and execute a scheme and artifice to defraud

Individual~4 and Mortgage Lender-1, and to obtain money and property by means of

materially false and fraudulent pretenses, representations, and promises, which

scheme and artifice was in substance as set forth below.

                                Object of the Scheme

      4.     The object of the scheme was for defendant ARTHUR SPITZER to

financially enrich himself and satisfy outstanding debts by fraudulently obtaining

mortgage loans secured by real estate properties that he did not have authority to

use as collateral for the mortgage loans.
                                               18
                       Maun er and Mea11s of the Scheme

      5.    It was part of the scheme that defendant SPITZER, using Individual-

2's name, applied for mortgage loans secured by the ISM Properties.

      6.    It was further part of the scheme that defendant SPITZER used a fake

document purporting to assign Individual-4's and Individual-5's membership in ISM

Holdings LLC to Individual-2 and defendant SPITZER. The document purporting

to transfer membership to Individual-2 and defendant SPITZER contained the

forged signature of one of the actual LLC members, Individual-4.

      7,    It was further part of the scheme that in or around February 2020,

defendant SPITZER caused Individual-2 to sign documents enabling ISM Holdings

LLC to obtain mortgage loans totaling approximately $4,000,000 through mortgage

originator Mortgage Originator~2 and Mortgage Lender-1. These mortgage loans

were secured by the ISM Properties. At the time he signed these documents,

Individual-2 was not aware of the nature of the documents or that he was signing

documents to obtain a mortgage loan on a property that neither he nor defendant

SPITZER legitimately owned.

      8.    It was further part of the scheme that Settlement Company-2 served

as settlement agent for these mortgage loans. Settlement Company-2 employees

we1·e located in New Jersey when they worked on the ISM Holdings transaction.

      9.    It was further part of the scheme that, after paying off the existing

mortgage loans on the ISM Properties, Settlement Company-2 wired approximately

$370,000 of the mortgage loan proceeds from its escrow account to a bank account



                                        19
at Bank-1 in the name of BSD Realty Holdings, Inc., which was controlled by

defendant SPITZER as follows:
                                                                                                    ..
 APP+<>X.}~ate Appr~x•~~te •.                                         De~m:iption                 .     ·. . .
                                                                                                         '        _'




 ·: .···:<_. . iJ'a'te. ·::·>•:.-- • •. ,:=:.·
                        ·.··:· .. : • . A m ' , , '

                                               ount   ..
                                                      ••.           .•••.. •...... -· .. ··.·.-.::· ...
                                                                                   ·,·:                  . ·.· ..
                                                                                                             '•




 2/25/2020                           $200,000.00    Interstate wire, sent tlU'ough the Fedwire
                                                    system, from Settlement Company-2's escrow
                                                    account to the BSD Realty Holdings, Inc. bank
                                                    account.
 2/26/2020                           $20,000.00     Interstate wire, sent thmugh the Fedwire
                                                    system, from Settlement Company-2's escrow
                                                    account to the BSD Realty Holdings, Inc. bank
                                                    account.
 2/26/2020                           $50,000.00     Interstate wire, sent through the Fedwfre
                                                    system, from Settlement Company-2's escrow
                                                    account to the BSD Realty Holdings, Inc. bank
                                                    account.
 2/27/2020                           $100,000.00    Interstate wire, sent through the Fedwire
                                                    system, from Settlement Company-2's escrow
                                                    account to the BSD Realty Holdings, Inc. bank
                                                    account.

        10.      It was further part of the scheme that Individual-4 did not actually

transfer membership of ISM Holdings LLC to defendant SPITZER and Individual-2,

and was not aware of, and did not authorize defendant SPITZER to obtain,

mortgage loans secured by the ISM Properties.

        11.      It was further part of the scheme that Mortgage Lende1·- l would not

have funded these mortgage loans had it known that Individual-4's signature on the

purported assigmnent was forged and that Individual-4 did not authorize defendant

SPITZER to obtain mortgage loans secured by the ISM Pl'Operties.

        12.      It was further part of the scheme that defendant SPITZER caused the

ISM Properties mortgage loans to default by not making the requhed payments.




                                                            20
                     Execution of the Scheme to Defraud

      13.   For the purpose of executing and attempting to execute the scheme

and artifice to defraud, in Camden, Essex, and Ocean Counties in the District of

New Jersey, and elsewhere, defendant

                               ARTHUR SPITZER

did knowingly transmit and cause to be transmitted by means of wire communication

in interstate and foreign commerce, certain writings, signs, signals, pictures, and

sounds, including a Fedwire funds transfer on or about February 25, 2020, from the

bank account of Settlement Company-2, through processing facilities in New Jersey

and Texas, to the bank account of BSD Realty Holdings Inc.

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




                                         21
                                    COUNT 5
                            (Aggravated Identity Theft)
                                 (ISM Properties)

       1.    Paragraph 1 of Count 1 of the Indictment, paragraphs 1 through 11 of

Count 3 of the Indictment, and paragraphs 1 through 13 of Count 4 of the

Indictment are incorporated as if set forth in full herein.

      2.     In or about February 2020, in Camden, Essex, and Ocean Counties in

the District of New Jersey, and elsewhere, defendant

                                ARTHUR SPITZER

did knowingly transfer, possess, and use, without lawful authority, a means of

identification of another person, that is, the name and signature of Individual-4,

during and in relation to a felony violation of provisions contained in Chapter 63 of

Title 18, namely, wire fraud, contrary to 18 U.S.C. § 1343 as charged in Count 4 of

this Indictment, knowing that the means of identification belonged to said other

person.

      In violation of Title 18, United States Code, Sections 1028A(a)(l) and 2.




                                           22
                                    COUNT 6
                   (Conspiracy to Commit Wire and Bank Fraud)
                              (Malcolm, X Properties)

       1.     Paragraph 1 of Count 1 of the Indictment is incorporated as if set forth

in full herein.

       2.     At all times relevant to this Indictment:

              a.     Defendant MENDEL DEUTSCH was a resident of Toms River,

New Jersey.

              b.    Defendant JOSHUA FELDBERGER was a resident of

Lakewood, New Jersey. Defendant JOSHUA FELDBERGER owned Settlement

Company-2, a title and real estate settlement company located in Lakewood, New

Jersey.

              c.    306 Malcolm NY LLC was a New York entity controlled by

defendant DEUTSCH (the "DEUTSCH LLC0).

              d.    The "Malcolm X Properties" were three mixed-use commercial

and residential buildings located on Malcolm X Boulevard in Brooldyn, New York.

              e.    Bank-2 was engaged in the business of making mortgage loans

and therefore was a "financial institution" within the meaning of Title 18, United

States Code, Section 20.

              f.    Bank-3 was a "financial institution» within the meaning of Title

18, United States Code, Section 20.

              g.    Deutsche Equity LLC was a New York company controlled by

defendant DEUTSCH. Deutsche Equity LLC had a bank account at Bank-3, whose

sole signatory was defendant DEUTSCH.
                                          23
             h.    Company-2 was a New York limited liability company.

             i.    Individual-6 was a resident of New York.

                                 The Conspiracy

      3.    From in or about November 2019 through in or about July 2020, in

Ocean County in the District of New Jersey, and elsewhere, defendants

                  ARTHUR SPITZER, MENDEL DEUTSCH,
                      aud JOSHUA FELDBERGER

did knowingly and intentionally conspire to commit certain offenses, namely:

   a. To devise a scheme and artifice to defraud Company-2 and Bank-2, and to
      obtain money and property by means of materially false and fraudulent
      pretenses, representations, and promises, and, for the purpose of executing
      and attempting to execute such scheme and artifice to defraud, did transmit
      and cause to be transmitted by means of wire communications in interstate
      and foreign commerce, certain writings, signs, signals, pictures, and sounds,
      contrary to Title 18, United States Code, Section 1343; and

   b. To execute and attempt to execute a scheme and artifice to defraud a
      financial institution, Bank-2, and to obtain moneys, funds, credits, assets,
      securities, and other property owned by, and under the custody and control
      of, Bank-2, by means of materially false and fraudulent pretenses,
      representations, and promises, contrary to Title 18, United States Code,
      Section 1344.

                            Object of the Conspiracy

      4.    The object of the conspiracy was for defendants ARTHUR SPITZER,

MENDEL DEUTSCH, and JOSHUA FELDBERGER to financially enrich

themselves and satisfy outstanding debts by fraudulently obtaining a $4,500,000

mortgage loan from Bank-2 that was secm~ed by the Malcolm X Properties.

                     Manner and Means of the Conspiracy

      5.    It was part of the conspiracy that in or around July 2019, 306A

Malcolm X Blvd LLC, 306 Malcolm X Blvd LLC, and 308 Malcolm X Blvd LLC (the
                                         24
"Malcolm X Blvd LLCs,,), purchased the Malcolm X Properties. No mortgage loan

was obtained in connection with the purchase.

      6.     It was further part of the conspiracy that the operating agreements for

the Malcolm X Blvd LLCs provided that the sole member of each entity was

CompanyN2. The operating agreements further pmvided that Individual-6 was an

authorized signatory who was authorized only to execute documents in connection

with the July 2019 purchase of the Malcolm X Prope1'ties.

      7.    It was further part of the conspfracy that between in or about

November 2019 and in or about March 2020, defendants ARTHUR SPITZER and

MENDEL DEUTSCH engaged in discussions with representatives of the Malcolm X

Blvd LLCs about purchasing the Malcolm X Properties from the Malcolm X Blvd

LLCs. These discussions did not result in any agreement to sell the Malcolm X

Properties to defendants SPITZER and DEUTSCH.

      8.    It was further part of the conspiracy that notwithstanding the lack of

agreement to sell the Malcohn X Properties to defendants SPITZER and

DEUTSCH, defendants SPITZER and DEUTSCH worked with defendant JOSHUA

FELDBERGER to devise and execute a scheme to obtain a mortgage loan secured

by the Malcolm X Properties by making it appear to Bank-2 as if defendant

SPITZER actually owned the Malcolm X Properties and that defendant SPITZER

had agreed to sell the Malcolm X Properties to an entity controlled by defendant

DEUTSCH (the DEUTSCH LLC).




                                         25
      9.       It was furthe1· part of the conspiracy that defendant MENDEL

DEUTSCH, through the DEUTSCH LLC, applied for a mortgage loan from BankN2

in connection with his purported purchase of the Malcolm X Properties.

      10.      It was further part of the conspiracy that defendants SPITZER and

DEUTSCH engaged Settlement Company-2 to be the title and settlement company

for the transaction conveying the Malcolm X Properties to the DEUTSCH LLC and

in which defendant DEUTSCH obtained a mortgage loan from Bank-2. Defendant

FELDBERGER oversaw Settlement Company-2's activities in connection with this

transaction. Defendant FELDBERGER and other Settlement Company-2

employees were located in New Jersey when they worked on the Malcolm X

transaction.

      11.      It was further part of the conspiracy that defendants SPITZER and

DEUTSCH made or caused to be made material misrepresentations to Bank-2 in

connection with defendant DEUTSCH's application for a mortgage loan secured by

the Malcolm X Properties. For example, between in or about January 2020 and in

or about June 2020, defendant FELDBERGER created and caused to be created

letters stating that defendant DEUTSCH already had deposited sizable funds into

Settlement Company-2's escrow account to be used towards the purchase of real

estate properties. Defendants SPITZER and DEUTSCH caused these letters to be

sent to Bank-2 to support defendant DEUTSCH's application for a mortgage loan

secured by the Malcolm X Properties. In fact, defendant DEUTSCH had not

deposited the stated funds into Settlement Company-2's escrow account.



                                          26
       12.   It was further part of the conspiracy that in or about June 2020,

defendant SPITZER signed documents on behalf of the Malcolm X Blvd LLCs to

obtain a sho1·t-term loan of more than $1,000,000. The loan documents were signed

by defendant SPITZER on behalf of the Malcolm X Blvd LLCs even though

defendant SPITZER was not a member of the Malcolm X Blvd LLCs and had no

authority to borrow money on behalf of the Malcolm X Blvd LLCs. The short-term

loan documents were notarized by defendant FELDBERGER.

      13.    It was further part of the conspiracy that defendants SPITZER,

DEUTSCH, and FELDBERGER caused to be created, and used, documents

containing the forged signature of Individual-6 to facilitate the transaction:

             a. On or about June 11, 2020, defendant DEUTSCH emailed a "time

                of essence" letter to his mortgage broker, which was then forwarded

                to Bank-2. The "time of essence" letter stated that the seller of the

                Malcolm X Properties was ready to close the sale of the Malcolm X

                Properties to defendant DEUTSCH. The "time of essence" letter

                was purportedly signed by Individual-6 but was not actually signed

                by Individual-6.

             b. The defendants used a document, dated August 2019, purportedly

                assigning membership in the Malcolm X Blvd LLCs from

                Individual-6 to defendant SPITZER (the "Fake Assignment"). The

                Fake Assignment made it appear as if defendant SPITZER owned

                the Malcolm X Properties and therefore could "sell'' the Malcolm X

                Properties to defendant DEUTSCH. The Fake Assignment was not
                                          27
                actually signed by Individual-6 and was created not in August

                2019, but rather, on a date after the Malcolm X transaction already

                had closed.

      14.    It was further part of the conspiracy that according to the HUD-1

Settlement Statement, the purchase price for the purported sale of the Malcolm X

Properties from defendant SPITZER to defendant DEUTSCH was $6,000,000, the

amount of the loan from Bank-2 was $4,500,000, and defendant DEUTSCH was

required to bring approximately $2,300,000 to the closing.

      15.   It was further part of the conspiracy that on or about June 25, 2020,

defendant FELDBERGER caused a Settlement Company-2 employee to falsely state

in an email sent to a representative of Bank-2 that defendant DEUTSCH already

had provided the required funds to Settlement Company-2. Bank-2 then wired the

loan proceeds of approximately $4,061,368.47 to Settlement Company-2 on or about

June 25, 2020. In fact, Settlement Company-2 had not received the required funds

from defendant DEUTSCH on June 25, 2020.

      16.   It was further part of the conspiracy that after Settlement Company-2

received the mortgage proceeds from Bank-2, the defendants engaged in a series of

monetary transactions that had the effect of allowing defendants SPITZER and

DEUTSCH to purchase the Malcolm X Properties and obtain the Bank-2 mortgage

loan without using any of their own money, as set forth below:

             a. On or about June 26, 2020, defendant FELD BERGER wired

                approximately $1,000,000 of the Bank-2 mortgage proceeds to

                defendant SPITZER's company, BSD Realty Holdings, Inc. These

                                         28
              funds were then wired from BSD Realty Holdings, Inc. to defendant

              DEUTSCH's company, Deutsche Equity, which then sent them by

              wire and check back to Settlement Company-2 as a portion of

              defendant DEUTSCH's approximately $2,300,000 down payment

              for the same transaction for which the mortgage loan was being

              obtained. Specifically, defendants SPITZER, DEUTSCH, and

              FELDBERGER engaged in the following monetary transactions:

                                        ;_-,_'.:;:/\ -:-:i:,, ;;p~~Pr\p._;_}~,-?~-\,;/ .,/ .• · ·,:-_ ·,.: .:::).\.-: .
                                                                                                    '.   ·. ·.', -.... ~...... ::_ ~_:_: :--::,> :··.




6/26/2020        $800,000 and     Interstate wire, sent through the Fedwire
                 $200,000         system, from Settlement Company-2's escrow
                                  account at Bank-I to defendant SPITZER!s
                                  BSD Realty Holdings bank account at Bank-
                                  1.
7/2/2020         $500,000,        Interstate wire, sent through the Fedwire
                 $300,000, and    system, from defendant SPITZER's BSD
                 $200,000         Realty Holdings bank account at Bank-1 to
                                  defendant DEUTSCH's Deutsche Equity
                                  bank account at Bank-3.
7/2/2020         $300,000 and     Interstate wire, sent through the Fedwire
                 $200,000         system, from defendant DEUTSCH's
                                  Deutsche Equity bank account at Bank-3 to
                                  Settlement Company-2's escrow account at
                                  Bank-1.
7/2/2020         $411,348,80      Check from defendant DEUTSCH's Deutsche
                                  Equity bank account at Bank-3, signed by
                                  defendant DEUTSCH, and deposited into
                                  Settlement Company-2's escrow account at
                                  Bank-1.

            b. On or about July 2, 2020, defendants SPITZER and DEUTSCH

              caused Individual-7 to wire the balance of defendant DEUTSCH's

              down payment-approximately $1,400,000-to Settlement

               Company-2. On or about July 2, 2020, defendant FELDBERGER


                                      29
                 wired a portion of the Bank-2 mortgage proceeds to BSD Realty

                 Holdings, Inc. Defendant SPITZER subsequently used these

                 mortgage proceeds to repay Individual-7. Specifically, defendants

                 SPITZER, DEUTSCH, and FELDBERGER engaged in the

                 following monetary transactions:



 7/2/2020          $1,400,000       Interstate wire, sent through the Fedwire
                                    system, from Individual-7's bank account at
                                    Bank-3 to Settlement Company-2's escrow
                                    account at Bank-1.
 7/2/2020          $1,000,000 and Interstate wires, sent through the Fedwire
                   $1,250,000       system, from Settlement Cmnpany-2's escrow
                                    account at Bank-I to defendant SPITZER's
                                    BSD Realt Holdin s bank account atBank-1.
 7/3/2020;         $250,000;        Interstate wires, sent through the Fedwire
 7/6/2020;         $500,000;        system, from defendant SPITZER's BSD
 7/24/2020;        $50,000; $75,000 Realty Holdings bank account at Bank-1 to
 7/28/2020                          Individual-7's bank account at Bank-3.

      17.     It was further part of the conspiracy that the proceeds of the Bank-2

mortgage loan were disbursed for the benefit of defendants SPITZER, DEUTSCH,

and FELD BERGER. As described abov~, a significant portion of the Bank-2

mortgage proceeds were used to fund defendant DEUTSCH's down payment.

Approximately $100,000 of the proceeds were disbursed to a relative of defendant

FELDBERGER to repay a loan he had made to defendant SPI'fZER. Most of the

remaining loan proceeds were disbursed to BSD Realty Holdings Inc. and used for

defendant SPITZER's benefit.

      18.     It was further part of the conspiracy that defendants SPITZER,

DEUTSCH and FELDBERGER signed the HUD-1 Settlement Statement for the


                                          30
Malcolm X transaction even though it did not disclose the material facts that more

than $1,000,000 of the funds were being disbursed to pay off the short-term loan,

that defendant DEUTSCH did not actually provide the required funds to close the

transaction on the closing date, and that defendant SPITZER did not actually own

the Malcolm X Properties. Bank-2 would not have approved and funded this

mortgage loan had it known these facts.

      19.   It was further part of the conspiracy that defendants SPITZER and

DEUTSCH caused the Bank-2 mortgage loan to default by failing to make the

required payments.

      In violation of Title 18, United States Code, Section 1349.




                                          31
                                     COUNT7
                                   (Bank F1·aud)
                               (Malcolm X Properties)

       1.    Paragraph 1 of Count 1 of the Indictment and paragraphs 1 tlu-ough 19

of Count 6 of the Indictment are incorporated as if set forth in full herein.

      2.     From in or about November 2019 through in or about July 2020, in

Ocean County in the District of New Jersey, and elsewhere, defendants

                   ARTHUR SPITZER, MENDEL DEUTSCH,
                       and JOSHUA FELDBERGER

did knowingly and intentionally execute and attempt to execute a scheme and

artifice to defraud a financial institution, Bank-2, and to obtain moneys, funds,

credits, assets, securities, and other property owned by, and under the custody and

control of, Bank-2, by means of materially false and fraudulent pretenses,

representations, and promises, namely by causing Bank-2 to transmit

approximately $4,061,368.47 to Settlement Company-2 on or about June 25, 2020.

      In violation of Title 18, United States Code, Sections 1344 and 2.




                                           32
                                      COUNTS
                                    (Wire Fraud)
                               (Malcolm X Properties)

      1.     Paragraph 1 of Count 1 of the Indictment and paragraphs 1 through 19

of Count 6 of the Indictment are incorporated as if set forth in full herein.

      2.     From in or about November 2019 through in or about July 2020, in

Ocean County in the District of New Jersey, and elsewhere, defendants

                   ARTHUR SPITZER, MENDEL DEUTSCH,
                       and JOSHUA FELDBERGER

did knowingly and intentionally devise and intend to devise a scheme and artifice to

defraud, and aid and abet the scheme and artifice to defraud Company-2 and Bank-

2, and to obtain money and property by means of materially false and fraudulent

pretenses, representations, and promises, and, for purposes of executing and

attempting to execute such scheme and artifice to defraud, did knowingly and

intentionally transmit and cause to be transmitted by means of wire

communications in interstate and foreign commerce certain writings, signs, signals,

pictures, and sounds, including a Fedwh-e funds transfer on or about June 25, 2020,

from Bank-2, through processing facilities in New Jersey and Texas, to the bank

account of Settlement Company-2.

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




                                          33
                                    COUNT9
                            (Aggravated Identity Theft)
                              (Malcolm X Properties)

      1.     Paragraph 1 of Count 1 of the Indictment and paragraphs 1 through 19

of Count 6 of the Indictment are incorporated as if set forth in full herein.

      2.     From in or about June 2020 through in or about July 2020, in Ocean

County in the District of New Jersey, and elsewhere, defendants

                   ARTHUR SPITZER, MENDEL DEUTSCH,
                       and JOSHUA FELDBERGER

did knowingly transfer, possess, and use, without lawful authority, means of

identification of another person, that is, the name and signature of Individual"6,

during an in relation to felony violations of provisions contained in Chapter 63 of

Title 18, namely, bank and wire fraud conspiracy, bank fraud, and wire fraud,

contrary to 18 U.S.C. §§ 1343, 1344, and 1349, as charged in Counts 6, 7, and 8 of

this Indictment, knowing that the means of identification belonged to said other

person.

      In violation of Title 18, United States Code, Sections 1028A(a)(l) and 2.




                                           34
                                    COUNT 10
                                 (False Statement)
                               (Malcolm, X Prope1'ties)

      1.     Paragraph 1 of Count 1 of the Indictment and paragraphs 1 through 19

of Count 6 of the Indictment are incorporated as if set forth in full herein.

      2.     In or about June 2020, in Ocean County in the District of New Jersey,

and elsewhere, defendants

                   ARTHUR SPITZER, MENDEL DEUTSCH,
                       and JOSHUA FELDBERGER

did knowingly make and cause to be made a false statement and report for the

purpose of influencing Bank-2, an institution the accounts of which were insured by

the Federal Deposit Insurance Corporation; namely, the defendants signed and

caused to be submitted to Bank-2, in connection with a $4,500,000 mortgage loan

from Bank-2 related to a purported transfer of the Malcolm X Properties, a HUD-1

Settlement Statement that (a) omitted the fact that a portion of the mortgage loan

proceeds were being used to pay off an existing loan; (b) falsely stated that

defendant DEUTSCH had provided approximately $2,300,000 of bis own, non-

mortgage loan funds at closing; and (c) falsely implied that defendant SPITZER was

authorized to sell the Malcolm X Properties.

      In violation of Title 18, United States Code, Sections 1014 and 2.




                                          35
                                     COUNT 11
                                    (Wire Fraud)
                                  (Conipany-3 loan)

       1.    Paragraph 1 of Count 1 of the Indictment and paragraphs 1 tln"ough 19

of Count 6 of the Indictment are incorporated as if set forth in full herein.

      2.     At all times relevant to this Indictment:

             a.     Individual-8 was a resident of Brooklyn, New York. Individual-

8 owned and resided in a building located on Bedford Avenue in Brooklyn, New

York (the "Bedford Avenue Property>').

             b.     The Bedford Avenue Property was owned by a limited liability

company (the "Bedford Avenue LLC"). The managing members of the Bedford

Avenue LLC were Individual-8 and Individual-B's spouse.

             c.     Company-3 was a Florida company.

             d.     Settlement Company-3 was a title and real estate settlement

company located in Brooklyn, New York.

                                    The Scheme

      3.     From in or about August 2020 through in or about September 2020, in

Kings County in the Eastern District of New York, the District of New Jersey, and

elsewhere, defendant

                                ARTHUR SPITZER

did knowingly and intentionally devise and execute a scheme and artifice to defraud

Company-2, Company-8, and Individual-8, and to obtain money and property by

means of materially false and fraudulent pretenses, representations, and promises,

which scheme and artifice was in substance as set forth below.
                                          36
                               Object of the Scheme

      4.     The object of the scheme was for defendant ARTHUR SPITZER to

financially en.rich himself and satisfy outstanding debts by fraudulently obtaining a

mortgage loan secured by real estate prope1◄ties that he did not have authority to

use as collateral for the mortgage loan.

                       Manner and Means of the Scheme

      5.     It was part of the scheme that in or about July 2020, a representative

of Company-2 learned that the Malcolm X Properties had been conveyed to

defendant DEUTSCH without authorization and that the unauthorized Bank-2

mortgage loan had been obtained. In or about August 2020, defendant DEUTSCH

assigned his interest in the DEUTSCH LLC to Company-2.

      6.     It was further part of the scheme that in or about September 2020,

defendant SPITZER, purportedly acting as an authorized signatory of the

DEUTSCH LLC and the Bedford Avenue LLC, obtained a loan of approximately

$1,000,000 from Company-3 that was secured by the Malcolm X Properties and the

Bedford Avenue Property.

      7.     It was further part of the scheme that Settlement Company-3 served

as settlement agent for the Company-3 mortgage transaction. On or about

Septemqer 29, 2020, approximately $940,000 was wired in interstate commerce

using the Fedwfre system, from a bank account controlled by Company-3 to

Settlement Company-B's escrow account.

      8.     It was further part of the scheme that the Company~3 loan proceeds

were disbursed by inte1·state wires, sent through the Fedwire system, for defendant
                                           37
SPITZER's benefit or to satisfy defendant SPITZER's outstanding debts. None of

the mortgage proceeds were disbursed to Individual-8 or Company-2.

       9.     It was further part of the scheme that defendant SPITZER was not a

member of the DEUTSCH LLC or the Bedford Avenue LLC, and neither Individual-

s nor Company-2 authorized defendant SPITZER to obtain a mortgage loan secured
by the Malcolm X Properties and the Bedford Avenue Property.

      10.     It was further part of the scheme that Company-3 would not have

funded this mortgage loans had it lmown that Individual-8 and Company-2 did not

authorize defendant SPITZER to obtain a mortgage loan secured by these

properties.

      11.     It was further part of the scheme that defendant SPITZER caused the

Company-3 mortgage loan to default by not making the requh-ed payments.

                      Execution of the Scheme to Defraud

      12.     For the purpose of executing and attempting to execute the scheme

and artifice to defraud, in Ocean County in the District of New Je1·sey, IGngs

County in the Eastern District of New York, and elsewhere, defendant

                               ARTHUR SPITZER

did knowingly transmit and cause to be transmitted by means of wire communication

in interstate and foreign commerce, certain writings, signs, signals, pictures, and

sounds, including a Fedwire funds transfer on or about September 29, 2020 from the

bank account of Company-3, through processing facilities in New Jersey and Texas,

to the bank account of Settlement Company-3.

      In violation of Title 18, United States Code, Sections 1343 and 2.
                                         38
                              COUNTS 12-19
            (Money Laundering by Transacting in Criminal Proceeds)
                   (Fraudulent mortgage proceeds - Spitzer)

       1.     Counts 1 through 11 of the Indictment are incorporated as if set forth

in full herein.

       2.     At all times relevant to this Indictment:

              a.    Company-4 was a New York limited liability company.

              b.    Company-5 was a New Jersey limited liability company.

              c.    Bank-4 was a "financial institution" within the meaning of Title

18, United States Code, Section 20.

       3.     On or about the dates set forth in the table below, in the District of

New Jersey and elsewhere, the defendant,

                                ARTHUR SPITZER,

did knowingly engage and attempt to engage in moneta1·y transactions by, through,

and to a financial institution, affecting interstate and foreign commerce, in

criminally derived property of a value greater than $10,000, as set forth in the table

below, such property having been derived from a specified unlawful activity, that is,

wire fraud in violation of Title 18, United States Code, Section 1343, bank fraud in

violation of Title 18, United States Code, Section 1344, and bank and wire fraud

conspiracy in violation of Title 18, United States Code, Section 1349, each monetary

transaction constituting a separate count:

:·.pount\ A:i>#fo:x:i~te
              >::nate:
 12         8/29/2019       $50,000.00 interstate wire, sent through the Fedwire
                            system, consisting of proceeds from the 56th Street
                            mort a e loan char ed in Count 1 of the Indictment

                                           39
                  from defendant SPITZER's BSD Realty Holdings bank
                  account at Bank-1 to defendant DEUTSCH's Deutsche
                  Equity bank account at Bank-3.
13   8/29/2019    $201,000.00 interstate wire, sent through the Fedwire
                  system, consisting of proceeds from the 56 th Street
                  mortgage loan charged in Count 1 of the Indictment,
                  from defendant SPITZER's BSD Realty Holdings bank
                  account at Bank-1 to a bank account controlled by
                  Individual-7 at Bank-3.
14   9/27/2019    $300,000.00 interstate wire, sent through the Fedwire
                  system, consisting of proceeds from the Division
                  Avenue mortgage loan charged in Count 2 of the
                  Indictment, from defendant SPITZER's BSD Realty
                  Holdings bank account at Bank-1 to a bank account in
                  the name of Company-4 at Bank-3.
15   12/27/2019   $130,000.00 interstate wire, sent through the Fedwire
                  system, consisting of proceeds from the ISM Holdings
                  LLC mortgage loan charged in Count 3 of the
                  Indictment, from defendant SPITZER's BSD Realty
                  Holdings bank account at Bank-1 to a bank account in
                  the name of Company-5 at Bank-1.
16   2/25/2020    $45,500.00 interstate wire, sent through the Fedwire
                  system, consisting of proceeds from the ISM Holdings
                  LLC mortgage loan charged in Count 4 of the
                  Indictment, from defendant SPITZER's BSD Realty
                  Holdings bank account at Bank-1 to a bank account in
                  the name of Company-5 at Bank-1.
17   2/27/2020    $100,000.00 interstate wire, sent through the Fedwire
                  system, consisting of proceeds from the ISM Holdings
                  LLC mortgage loan charged in Count 4 of the
                  Indictment, from defendant SPITZER's BSD Realty
                  Holdings bank account at Bank-1 to defendant
                  DEUTSCH's Deutsche Equity bank account at Bank-3.
18   7/2/2020     $100,000.00 interstate wire, sent through the Fedwire
                  system, consisting of proceeds from the Malcolm X
                  Properties mortgage loan charged in Counts 6-10 of the
                  Indictment, from defendant SPITZER's BSD Realty
                  Holdings bank account at Bank-1 to the Company-I
                  bank account at Bank-4.




                               40
19       7/6/2020         $100,000.00 interstate wire, sent through the Fedwire
                          system, consisting of proceeds from the Malcolm X
                          Properties mortgage loan charged in Counts 6-10 of the
                          Indictment, from defendant SPITZER's BSD Realty
                          Holdings bank account at Bank-1 to the Company-1
                          bank account at Bank-4.

     In violation of Title 18, United States Code, Sections 1957(a) and 2.




                                        41
                                     COUNTS 20-21
                                      (Wire Fraud)
                                  (EIDL loans - Spitzer)
       1.     Pa1·agraphs 1 through 13 of Count 1 of the Indictment are incorporated

as if set forth in full herein.

       2.     At all times relevant to the Indictii10nt:

              a.     Bank-5 was a "financial institution" within the meaning of Title

18, United States Code, Section 20.

              b.     The U.S. Small Business Administration ("SBA") was an

independent agency of the federal government created to aid, counsel, assist, and

protect the interests of small business concerns, preserve free competitive

enterprise, and maintain and strengthen the overall economy of the United States.

              c.     The EIDL program was an SBA program that provided low-

interest :financing to small businesses, renters, and homeowners in 1·egions affected

by declared disasters.

              d.     The Coronavirus Aid, Relief, and Economic Security ("CARES")

Act was a federal law enacted in 01· about March 2020 and was designed to provide

emergency financial assistance to millions of Americans suffering economic effects

caused by the COVID-19 pandemic.

              e.     The CARES Act authorized the SBA to provide EID Ls of up to

$2 million to eligible small businesses that were experiencing substantial financial

disruption due to the COVID-19 pandemic.

              f.     To obtain an EIDL, a qualifying business was required to submit

an application to the SBA and provide information about its operations, such as the

                                            42
number of employees, gross 1·evenues for the 12-month period preceding the

disaster, and cost of goods sold in the 12-month period preceding the disaster. In

addition, the business entity must have been in operation on February 1, 2020.

             g.     The amount of the EIDL was determined based, in part, on the

information provided by the applicant regarding the revenue, employees, and cost of

goods of the business. The SBA directly issued any funds disbursed under an EIDL

to the applicant business. A business was permitted to use EIDL funds for payroll

expenses, sick leave, production costs, and business obligations such as debts, rent,

and mortgage payments.

                                    The Scheme

      3.     From in or about June 2020 through at least as late as November

2020, defendant SPITZER devised and intended to devise a scheme to defraud the

SBA, and to obtain fede1·al COVID-19 emergency relief monies by means of

materially false and fraudulent pretenses, representations and promises.

                               Object of the Scheme

      4.     The object of the scheme was for defendant SPITZER to financially

enrich himself by obtaining EIDL loans that were intended for small businesses

distressed by the COVID-19 pandemic, through the submission of fraudulent loan

applications to the SBA that included false statements about the applicant

companies' gross revenues, cost of goods sold, and lost rents.

                       Manner and Means of the Scheme

      5.     It was part of the scheme that defendant SPITZER submitted and

caused to be submitted approximately two dozen EIDL loan applications. The loan
                                          43
applications contained materially false and fraudulent information about one or

more of the following data points: the company's number of employees, gross

revenues, cost of goods sold, and lost rents due to the COVID-19 pandemic.

      6.    It was further part of the scheme that based on the materially false

information, the SBA approved approximately 15 EIDL loans.

      7.    It was further part of the scheme that some of the EIDL applications

or loan agreements were electronically signed and submitted to the SBA from New

Jersey.

      8.    It was further part of the scheme that after approving the EIDLs, the

SBA disbursed the loan proceeds into bank accounts maintained by defendant

SPITZER. Many of the EIDL loans that the SBA approved based on loan

applications that defendant SPITZER caused to be submitted were funded via

Automated Clearing House (ACH) payments sent from the SBA's facility in a state

other than New Jersey, through a facility in New Jersey, to bank accounts

controlled by defendant SPITZER.

      9.    It was further part of the scheme that as a result of his fraudulent

applications, defendant SPITZER unlawfully obtained more than.$1,500,000 in

federal COVID~19 emergency relief money.

      56th Street LLC EIDL Loan

      10.   It was further part of the scheme that on or about August 9, 2020,

defendant SPITZER applied for an EIDL loan on behalf of the 56th Street LLC. The

56th Street EIDL application stated that the 56 th Street LLC had 8 employees, gross




                                        44
revenues of $749,875 for the 12 months prior to the disaster, and lost rents due to

the disaster of $690,120.

      11.    It was further part of the scheme that the information defendant

SPITZER caused to be provided to the SBA on the 56th Street EIDL application was

false and fraudulent. The 56 th Street LLC was a ·company formed by defendant

SPITZER in or around August 2019 to hold the 56th Street Properties and to apply

for unauthorized mortgages secured by the 56th Street Properties. The 56 th Street

LLC did not have any employees, had no revenue (apart from the fraudulent

mortgage proceeds), and no rents were ever paid to the 56 th Street LLC. The 56 th

Street LLC bank account at Bank-5 was not opened until July 23, 2020, shortly

before defendant SPITZER applied for the EIDL loan.

      12.    It was further part of the scheme that in or around November 2020,

based on the fraudulent application, SBA approved the 56 th Street EIDL loan in the

amount of $150,000.

      13.    It was flll'ther part of the scheme that in or around November 2020, in

Jersey City, New Jersey, defendant SPITZER electronically signed, or caused to be

electronically signed, a Loan Authorization and Agreement on behalf <;>f the 56 th

Street LLC certifying that "[a]ll representations in the Borrower's Loan application

(including all supplementary submissions) are true, correct and complete and are

offered to induce SBA to make this Loan. 11

      14.    It was further part of the scheme that in or around November 2020,

the SBA disbursed approximately $149,900 into a Bank"5 account in the name of

the 56th Street LLC, which was controlled by defendant SPITZER.

                                          45
      138 Nobility LLC EIDL Loan

      15.    It was further part of the scheme that on or about August 17, 2020,

defendant SPITZER applied for an EIDL loan on behalf of 138 Nobility LLC. The

138 Nobility LLC EIDL application stated that 138 Nobility LLC had 3 employees,

gross revenues of $185,500 for the 12 months prior to the disaster, and lost rents

due to the disaster of $163,200.

      16.    It was further part of the scheme that the information that defendant

SPITZER caused to be provided to the SBA on the 138 Nobility LLC EIDL

application was false and fraudulent. 138 Nobility LLC was a company formed by

defendant SPITZER in or around August 2019 to hold a single-family residence in

Toms River, New Je1·sey. 138 Nobility LLC did not have any employees, had no

revenue, and no rents were ever paid to 138 Nobility LLC. The 138 Nobility LLC

bank account at Bank-5 was not opened until July 23, 2020, shortly before applying

for the EIDL loan.

      17.    It was further part of the scheme that in or around November 2020,

based on the fraudulent application, SBA approved the 138 Nobility LLC EIDL loan

in the amount of $150,000.

      18.    It was further part of the scheme that in or around November 2020, in

Jersey City, New Jersey, defendant SPITZER electronically signed, or caused to be

electronically signed, a Loan Authorization and Agreement on behalf 0£ 138 Nobility

LLC certifying that "[a]ll representations in the Borrower's Loan application

(including all supplementary submissions) are true, correct and complete and are

offered to induce SBA to make this Loan."
                                         46
      19.     It was further part of the scheme that in or around November 2020,

the SBA disbursed approximately $149,900 into a Bank-5 account in the name of

138 Nobility LLC, which was controlled by defendant SPITZER.

                             Execution of the Scheme

      20.     On or about the dates set forth below, in the District of New Jersey

and elsewhere, defendant,

                                 ARTHUR SPITZER,

for the purpose of executing the scheme described above, transmitted and caused to

be transmitted by means of wire communications in interstate commerce the

writings, signs, and signals described below for each count, each transmission

constituting a separate count:



 20         11/10/2020      An electronic transfer of approximately $149,900 from
                            the SBA to a Bank-5 account in the name of the 56th
                            Street LLC that traveled through the States of New
                            Jersey and Maine.
 21         11/10/2020      An electronic transfer of approximately $149,900 from
                            the SBA to a Bank-5 account in the name of 138
                            Nobility LLC that t1·aveled through the States of New
                            Jersey and Maine.

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




                                          47
                                 COUNTS 22-26
               (Money Laundering by Transacting in C1·iminal Proceeds)
                                     (EIDL loans - Spitzer)
       1.        Paragraphs 1 through 13 of Count 1 of the Indictment and paragraphs

1 through 20 of Counts 20-21 of the Indictment are incorporated as if set forth in

full herein.

       2.        On or about the dates set forth in the table below, in the District of

New Jersey and elsewhere, defendant,

                                     ARTHUR SPITZER,

did knowingly engage and attempt to engage in monetary transactions by, tlu-ough,

and to a financial institution, affecting interstate and foreign commerce, in

criminally derived property of a value greater than $10,000, as set forth in the table

below, such property having been derived from a specified unlawful activity, that is,

wire fraud in violation of Title 18, United States Code, Section 1343, each monetary

transaction constituting a separate count:

 :Count:                                DesQriptio11           of:M9µet11:ry.:Traiis~ctip:n.:::·
       :,·.·
               1-Pfi)°tfri~tll;          .,.·.· .... ·.....
                                                   ,•-      .. .. .. ··
                                                         ·•-·•   -.·,   ,·..  .. . ..
                                                                             ··,',,,'   •'','·: .
                                                                                                .. ·,•   ·••'',   •,_·   _   .. ·.•.·:.·,---.•-···..




 22            11/12/2020         An electronic transfer of approximately $100,000 of the
                                  proceeds from the 56th Street LLC EIDL loan from the
                                  Bank-5 account in the name of the 56th Street LLC to a
                                  Bank-5 account in the name of defendant SPITZER and
                                  defendant SPITZER's spouse.
 23            11/12/2020         An electronic transfer of approximately $45,000 of the
                                  proceeds from the 56 th Street LLC EIDL loan from the
                                  Bank-6 account in the name of the 56 th Street LLC to a
                                  Bank-5 account in the name of ZTS Exuress Inc.
 24            11/12/2020         An electronic transfer of approximately $100,000 of the
                                  proceeds from the 138 Nobility LLC EIDL loan from the
                                  Bank-5 account in the name of 138 Nobility LLC to a
                                  Bank-5 account in the name ofZTS Exoress Inc.
 25            11/12/2020         An electronic transfer of approximately $25,000 of the
                                  proceeds from the 138 Nobilitv LLC EIDL loan from the
                                                48
                          Bank-5 account in the name of 138 Nobility LLC to a
                          Bank-5 account in the name of ZTS Exl)ress Inc.
26       11/12/2020       An electronic transfer of approximately $20,000 of the
                          proceeds from the 138 Nobility LLC EIDL loan from the
                          Bank-5 account in the name of 138 Nobility LLC to a
                          Bank-5 account in the name of ZTS Exnress Inc.

     In violation of Title 18, United States Code, Sections 1957(a) and 2.




                                        49
                                     COUNTS 27-28
                                      (Wire Fraud)
                                  (EIDL loans - Dezttsch)

       1.     Paragraphs 1 and 2 of Counts 20M21 of the Indictment are incorporated

as if set forth in full herein.

                                       The Scheme

       2.     From in or about June 2020 through at least as late as November

2020, defendant DEUTSCH devised and intended to devise a scheme to defraud the

SBA, and to obtain federal COVID-19 emergency relief monies by means of

materially false and fraudulent pretenses, representations and promises.

                                  Object of the Scheme

       3.     The object of the scheme was for defendant DEUTSCH to financially

enrich himself by obtaining EIDL loans that were intended for small businesses

distressed by the COVID-19 pandemic, through the submission of fraudulent loan

ap}llications to the SBA that included false statements about the applicant

companies' gross revenues, cost of goods sold, and lost rents.

                          Manner and Means of the Scheme

       4.     It was part of the scheme that defendant DEUTSCH submitted and

caused to be submitted more than one dozen EIDL loan applications. The loan

applications contained materially false and fraudulent information about one or

more of the following data points: the company,s number of employees, gross

revenues, cost of goods sold, and lost rents due to the COVID-19 pandemic.




                                            50
      5.       It was further part of the scheme that based on the materially false

information, the SBA approved approximately 15 EIDL loans for defendant

DEUTSCH's companies.

      6.       It was further part of the scheme that after approving the EID Ls, the

SBA disbursed the loan proceeds into bank accounts maintained by defendant

DEUTSCH.

      7.       It was further part of the scheme that as a result of the fraudulent

applications, defendant DEUTSCH unlawfully obtained more than $1,800,000 in

federal COVID-19 emergency relief money.

      Blanche Street LLC EIDL Loan

      8.       It was fwther part of the scheme that on or about September 2, 2020,

defendant DEUTSCH applied for an EIDL loan on behalf of 1500 West Blancke

Street LLC. The 1500 West Blancke-Stre_et LLC EIDL application falsely stated

that 1500 West Blancke Street LLC had gross revenues of $378,000 for the 12

months prior to the disaster, and cost of goods sold of $65,000 for the 12 months

prior to the disaster. The actual revenue and cost of goods sold for 1500 West

Blancke Street LLC was significantly lower than the amounts stated on the EIDL

application.

      9.       It was further part of the scheme that in or around September 2020,

based on the fraudulent application, SBA approved the 1500 Blancke Street LLC

EIDL loan in the amount of $150,000.




                                           51
       10.   It was further part of the scheme that in or around September 2020,

the SBA disbursed approximately $149,900 into a Bank-3 account in the name of

1500 West Blancke Street LLC, which w~s controlled by defendant DEUTSCH.

       53 7 Kniclierboclier Enterprises LLC EIDL Loan

       11.   It was further part of the scheme that on or about September 3, 2020,

defendant DEUTSCH applied for an EIDL loan on behalf of 537 Knickerbocker

Enterprises LLC. The 537 Knickerbocker Enterprises LLC EIDL application falsely

stated that 537 Knickerbocker Enterprises LLC had gross revenues of $460,500 for

the 12 months prior to the disaster, and cost of goods sold of $118,000 for the 12

months p1·ior to the disaster.   The actual income for 537 Knickerbocker LLC was·

significantly lower than stated on the EIDL application.

      12.    It was further part of the scheme that in or amund November 2020,

based on the fraudulent application, SBA approved the 537 Knickerbocker

Enterprises LLC EIDL loan in the amount of $150,000.

      13.    It was further part of the scheme that in or around November 2020,

the SBA disbursed approximately $149,900 into a Bank-3 account in the name of

537 Knickerbocker Enterprises LLC, which was controlled by defendant DEUTSCH.

                             Execution of the Scheme

      14.    On or about the dates set forth below, in the District of New Jersey

and elsewhere, the defendant,

                                 MENDEL DEUTSCH,

for the purpose of executing the scheme described above, transmitted and caused to



                                          52
be transmitted by means of wire communications in interstate commerce the

writings, signs, and signals described below for each count, each transmission

constituting a separate count:



 27       9/4/2020         An electronic transfer of approximately $149,900 from
                           the SBA to a Bank-3 account in the name of 1500 West
                           Blancke Street LLC that traveled through the States of
                           New Jerse and New York.
 28       11/23/2020       An electronic transfer of approximately $149,900 from
                           the SBA to a Bank-3 account in the name of 537
                           Knickerbocker Enterprises LLC that traveled through
                           the States of New Jerse and New York.

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




                                         53
                             COUNTS 29-80
           (Money Laundering by Transacting in Criminal Proceeds)
                          (EIDL loans - DeU,tsch)

      1.     Paragraph 2 of Count 6 of the Indictment and paragraphs 1 through 14

of Counts 27-28 of the Indictment are incorporated as if set forth in full herein.

      2.     On or about the dates set forth in the t~ble below, in the District of

New Jersey and elsewhere, defendant,

                                          MENDEL DEUTSCH,

did knowingly engage and attempt to engage in monetary transactions by, through,

and to a financial institution, affecting interstate and foreign commerce, in

criminally derived property of a value greater than $10,000, as set forth in the table

below, such property having been derived from a specified unlawful activity, that is,

wire fraud in violation of Title 18, United States Code, Section 1343, each monetary

transaction constituting a separate count:
                                      .

·;::o.o.itnf· A.pp1:9*§#t~                                                                          :•_ . . ··•-:·
                                           . Descri:pti~11of M911et~:r:y/J):at1s~pti<>11 '. :~: :\.:· :::\·  .•
           ·· ··Date:,-:-.·.     ·.
                                                                                                     • .. ·.·-·.·,•




 29        9/4/2020            An electronic transfer of approximately $149,900,
                               representing the proceeds from the 1500 West Blancke
                               Street LLC EIDL loan from the Bank-3 account in the
                               name of 1500 West Blancke Street LLC to a Bank~3
                               account in the name of Deutsche Equity LLC.
 30        11/23/2020          An electronic transfer of approximately $149,900,
                               representing the proceeds from the 537 Knickerbocker
                               Enterprises LLC EIDL loan from the Bank-3 account in
                               the name of 537 Knickerbocker Enterprises LLC to a
                               Bank-3 account in the name of Deutsche Equity LLC.

      In violation of Title 18, United States Code, Sections 1957(a) and 2.




                                                    54
                   FORFEITURE ALLEGATION AS TO COUNTS
                          1-4, 8, 11, 20-21, and 27-28

       1.    The allegations contained in Counts 1-4, 8, 11, 20-21, and 27-28 of this

Indictment are he1·eby realleged and incorporated by reference for the purpose of

alleging forfeiture pursuant to Title 18, United States Code, Section 981(a)(l)(C)

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

      2.     As a result of committing the offenses charged in Counts 1-4, 8, 11, 20-

21, and 27-28 of this Indictment, the defendants charged in each such count shall

forfeit to the United States, pursuant to Title 18, United States Code, Section

981(a}(l)(C) and Title 28, United States Code, Section 246l(c), any property, real or

personal, said defendant obtained that constitutes or is derived from proceeds

traceable to the each of the offenses alleged in Counts 1-4, 8, 11, 20-21, and 27-28 of

this Indictment.

                   FORFEITURE ALLEGATION AS TO COUNT 6

      1.     The allegations contained in Count 6 of this Indictment are hereby

realleged and incorporated by reference for the purpose of alleging forfeiture

pursuant to Title 18, United States Code, Sections 981(a)(l)(C) and 982(a)(2)(A),

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

      2.     As a result of committing the conspiracy offense charged in Count 6 of

this Indictment, the defendants charged shall forfeit to the United States, pursuant

to Title 18, United States Code, Sections 98l(a)(l)(C) and 982(a)(2)(A), and Title 28,

United States Code, Section 246l(c), any property, real or personal, said defendant




                                          55
obtained that constitutes or is derived from proceeds traceable to the offense

charged in Count 6 of this Indictment.

            FORFEITURE ALLEGATION AS TO COUNTS 7 and 10
       1.    The allegations contained in Counts 7 and 10 of this Indictment are

hereby realleged and incorporated by reference for the purpose of alleging forfeiture

ptu·suant to Title 18, United States Code, Section 982(a)(2)(A).

      2.     As a result of committing one or both of the offenses charged in Counts

7 and 10 of this Indictment, the defendants charged in each such count shall forfeit

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

any property, real or personal, constituting, or derived from, said defendant

obtained directly or indirectly as a result of the each such offense.

    FORFEITURE ALLEGATION AS TO COUNTS 12-19, 22-26, and 29-80

      1.     The allegations contained in Counts 12-19, 22-26, and 29-30 of this

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

alleging forfeiture pursuant to Title 18, United States Code, Section 982(a)(l).

      2.      As a result of committing one or more of the money laundering

offenses charged in Counts 12-19, 22-26, and 29-30 of this Indictment, the

defendants charged in each such count shall forfeit to the United States, pursuant

to Title 18, United States Code, Section 982(a)(l), all property, real or personal,

involved in each such offense, and all property traceable to such property.

                        SUBSTITUTE ASSET PROVISION

      1.     If any of the property described above, as a result of any act or

omission of the respective defendant:

                                           56
          a. cannot be located upon the exercise of due diligence;

          b. has been transferred to 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;

it is the intent of the United States, pursuant to Title 21 United States Code,

Section 853(p), as incorporated by Title 18 United States Code, Section 982(a)(l)

and Title 28 United States Code, Section 2461(c), to seek forfeiture of any other

property of such defendants up to the value of the forfeitable pl'Operty described

above.

                                               A TRUE.BILL



                                            C--:FOREPERSON



United States Attorney




                                          57
 CASE NUMBER: _ _ _ __

 United States District Court
   District of New Jersey

UNITED STATES OF AMERICA
              v.

      ARTHUR SPITZER
     .MENDEL DEUTSCH
   JOSHUA FELDBERGER

     INDICTMENT FOR
       18 U.S. C. § 1349
       18 u.s.c. § 1344
       18 u.s.c. § 1343
    18 U.S.C. § 1028A(a)(l)
       18 u.s.c. § 1014
      18 U.S.C. § 1957(a)
         18 u.s.c. § 2




      PHILIP R. SELLINGER
   UNITED STATES ATTORNEY
FOR THE DISTRICT OF NEW JERSEY

     DANIELA. FRIEDMAN
   AsSISTANT U.S. A'ITORNEY
     CAMDEN, NEW JERSEY
        (856) 757-5026


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