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Page 1 of 22 AFFIDAVIT IN SUPPORT OF ARREST WARRANTS ...

AFFIDAVIT IN SUPPORT OF ARREST WARRANTSBefore me, ________________________, a Judge of the Circuit Court of the SeventeenthJudicial Circuit of Florida, personally appeared Detective John Swope, employed by the FloridaDepartment of Financial Services Division of Insurance Fraud, who being duly sworn, deposesand says that he has probable cause to believe and does believe that he has probable cause for thearrest of:1) Johnson CuffyB/M DOB: 12/18/1977277 Vervain Ave. Davenport, Florida 33837(1) Count of Racketeering, in violation of 895.03(3)(1) Count of Conspiracy to Commit Racketeering in violation of 895.03(4)(7) Counts of Grand Theft first degree, in violation of 812.014(2)(a)1(7) Counts of Grand Theft 2nd degree in violation of 812.014(2)(b) more than $20,000 but lessthan $100,000.2) Lillia CuffyB/F DOB: 01/10/19729737 N. Springs Way Coral Springs, Fl. 33076(1) Count Racketeering in violation of 895.03(3)(1) Count Racketeering Conspiracy, in violation of 895.03(4)(1) Count of Grand Theft First Degree over $100,000.00 in violation of 812.014(2)(a)13) Cliff JohnsonB/M DOB: 07/19/1959981 NE 155 ter. N. Miami Beach, Florida 33162(1) Count Racketeering in violation of 895.05(3)(1) Count Racketeering Conspiracy, in violation of 895.03(4)(3) Counts Grand Theft first degree over $100,000.00 in violation of 812.014 (2)(a)1(2) Counts of Grand Theft second degree under $100,000 but over $20,000.00 in violation of812.014(2)(b)Page 1 of 22


4) Joy WilliamsB/F DOB: 04/03/1979901 NE 34 St. Oakland Park, Florida 33334(1) Count of Racketeering in violation of 895.05(3)(1) Count Racketeering Conspiracy, in violation of 895.03(4)(2) Counts of Grand Theft first degree in violation of 812.014(2)(a)1(1) Count Grand Theft second degree in violation of 812.014(2)(b)5) Frumence PaulH/M DOB: 11/06/19461105 NW 5th Ave. Ft. Lauderdale, Florida 33311(1) Count Racketeering in violation of 895.05(3)(1) Count Racketeering Conspiracy in violation of 895.03(4)(2) Count Grand Theft $100,000.00 in violation of 812.014(2)(a)1(3) Counts of Grand Theft second degree in violation of 812.014(2)(b)16) Hans JeantyH/M DOB: 10/21/19812268 SW 195 Ave. Miramar, Florida 33029(1) Count of Racketeering in violation of 895.03(3)(1) Count Racketeering Conspiracy in violation of 895.03(4)(2) Counts Grand Theft more than $20,000 less than $100,000 in violation of 812.014(2)(b)(1)7) Lloyd GeluB/M DOB: 11/14/197520856 NW 21 Street Pembroke pines, Fl. 33029(1) Count of Racketeering in violation of 895.05(3)(1) Count of Conspiracy to Commit Racketeering 895.03(4)(1) Count Grand Theft second degree more than $20,000 in violation of 812.014(2)(b)(1)8) Charles ReynoldsB/M DOB: 07/06/1966Page 2 of 22


229 Pelican Way Del Ray Beach, Florida 33483(1) Count Racketeering in violation of 895.03(3)(2) Count Conspiracy to Commit Racketeering in violation of 895.03(4)(1) Grand Theft $100,000.00 or more in violation of 812.014(2)(a)19) Paula AugustusB/F DOB: 06/25/1963611 NW 69 Way Hollywood, Florida(1) Count Racketeering in violation of 895.03(3)(1) Count Conspiracy to Commit Racketeering in violation of 895.03(4)(2) Counts Grand Theft first degree in violation of 812.014(2)(a)1(1) Count Grand Theft second degree in violation of 812.014(2)(b)1AFFIANT TRAINING AND EXPERIENCEYour affiant, Detective John Swope has been a sworn law enforcement officer in the State ofFlorida for over eleven years. Your affiant has approximately twenty years of combined financialinvestigative experience. Your affiant presently is employed with the Florida Department ofFinancial Services, Division of Insurance Fraud. During the past two years your affiant has beenassigned to investigate cases involving mortgage title fraud which has involved both State andFederal law enforcement authorities. Your affiant has led in the arrest of over thirty-five subjectsand affected the service of numerous search warrants in the State of Florida. . Your affiant’s caseexperience focuses almost entirely on white collar investigations which have been conducted inboth the public as well as corporate sector. Your affiant was employed in the private sector as aSpecial Investigations Unit investigator as well as manager. Your affiant was responsible for theday to day operations of the Special Investigations Unit which worked closely with both State &Federal law enforcement authorities in the southeastern United States. Your affiant was chargedwith the responsibility of investigating complex medical disability claims to determine thepresence of misrepresentation or fraud. As a field investigator and manager your affiantperformed these duties for approximately nine years. In addition your affiant has obtained theindustry designation of Certified Fraud Examiner.INTRODUCTIONOn or about November 2007, your affiant began an investigation into an organized criminalenterprise involving Mortgage Fraud, to include but not limited to, Racketeering, Conspiracy toRacketeer and Grand Theft. Your affiant has reviewed and examined public records of PalmBeach, Broward and Dade Counties, the Secretary of State of Florida, Florida Department ofMotor Vehicles relating to the involved individuals of corporations, vehicle ownership, andPage 3 of 22


property ownership and identified relevant bank records of the individuals and/or companies.Your affiant has also subpoenaed and examined bank records pertaining to loan files.Your affiant has participated in this investigation and has personally interviewed those whoseinformation is set forth herein, and/or have reviewed reports of interviews or other investigativeinformation prepared by others that may appear in this affidavit.As a result of your Affiant’s personal participation in this investigation and/or reports, oral andwritten, your affiant is familiar with the circumstances of the offenses described in theAFFIDAVIT.On the bases of your affiant’s training and experience, you’re Affiant states the facts contained inthis Affidavit. Your Affiant has identified the aforementioned subjects as active participants inan ongoing criminal enterprise used to defraud numerous financial institutions.MORTGAGE TERMS‘Residential mortgage loan’ means a loan to extend credit made to a person, which loan issecured by a deed to secure debt, security deed, mortgage, security interest, deed of trust, orother document representing a security interest or lien upon any interest in one-to-four familyresidential property located in Florida including the renewal or refinancing of any such loan. Asin these listed mortgage loans they are referred to as HELOC which is a home equity line ofcredit. These HELOC loans are secured through the submission of a warranty deed declaringsecurity interest in the collateral property being represented. These warranty deeds are forgedand are submitted to the financial institutions declaring ownership of the property when noneexisted. The equity line of credit is determined based on the amount of equity available in thestated property. Through the embellishment of false & fraudulent appraising the manufacturingof property equity takes place. The financial institution using that appraisal information willassign an approved equity line of credit. Once the line of credit is approved and distributed theHELOC is funded for a short period of time and then becomes delinquent. As a result thefinancial institutions are forced to move against the properties under foreclosure proceedingsonly to find out that the original owners still own the effected property.‘Mortgage lending process’ means the process through which a person seeks or obtains aresidential mortgage loan including, but not limited to, solicitation, application, or origination,negotiation of terms, third party provider services, underwriting, signing and closing, andfunding of the loan. Documents involved in the mortgage lending process include, but are notlimited to, uniform residential loan applications, appraisal reports: HUD-1 settlement statements;supporting personal documentation for loan applications such as W-2 forms, verifications ofincome and employment, bank statements, tax returns, and payroll stubs; and any requireddisclosures.‘Pattern of residential mortgage fraud’ means one or more material misrepresentations, oromissions made during the mortgage lending process that involve to or more residentialproperties., which have the same or similar intents, results, accomplices, victims, or methods ofcommission or otherwise are interrelated by distinguishing characteristics.Page 4 of 22


‘Person’ means a natural person, corporation, company, Limited Liability Company,partnership, trustee, association, or any other entity.‘HUD-1 Settlement Statement means a form used by the settlement agent (also referred to as theclosing agent) to itemize all charges imposed upon the borrower and seller for the real estatetransaction. It gives each party a complete list of their incomingAnd outgoing funds disclosed to the lender. The form is ultimatelySubmitted to the lender by the closing agent prior to funding the loan.‘1003’ means the loan application filled out by the loan officer, employee of the mortgage brokercompany. The application contains the purported personal information, monthly income,employer information, credit history and assets he/she may have. This document is essential inthe loan process for the purpose of qualifying the borrower.GENERAL EXPLANATION OF THE MORTGAGE FRAUD SCHEMEEach mortgage fraud scheme contains some type of “material misstatement, misrepresentation,or omission relied upon by an underwriter or lender to fund, purchase or insure a loan. Thedefendants and their accomplices orchestrated a scheme to locate properties for sale in the SouthFlorida area. Thereafter, the accomplices fraudulently purchase the properties using strawbuyers, and received cash back at closings without the knowledge of the lender.STRAW BUYERS COLLABORATION IN THE SCHEMEA straw buyer is one who purchases property for another to conceal the identity of the realperpetrator. The straw buyer is usually compensated several thousands of dollars for the use ofname and credit information to perform this false purchase. Straw buyers are also used to signdocuments that contain false information. Such as a straw buyer willing to sign the 1103document (loan application) representing an embellished income in order to qualify for the loan.These straw buyers may also falsely represent their intent to occupy the property. If in the loanprocess, the straw buyer falsely represents that the source of the down payment or cash at closingcame from the straw buyer, this will constitute mortgage fraud. At times, defendantsorchestrating the scheme will make payments on the property long enough to sell the property ormake only one or two payments to disguise the fraud. Often, payments are made on theproperties with illicit funds attained from the Mortgage fraud.An example of such a scheme is when co-conspirators pay the owner’s asking price and thenfraudulently embellish the contract price by using two HUD-1 settlement sales contracts. This isperpetrated by conducting simultaneous closings without the lender’s knowledge. This schemeallows the co-conspirators to create the financial illusions of additional equity in the property.This instant equity however is then diverted to an undisclosed third party known as“cash back atclosing” in order for the person or persons to realize these fraudulent fundsDuring the loan approval process, the fraud subject provides the lender with false pay stubs, IRSform W-2s, verification of employment and verification of deposit forms in order to obtain thePage 5 of 22


loan. These fraudsters at times will fraudulently forge purchaser’s signatures, inaccuratelycomplete loan applications and falsify supporting loan documents. These individuals also falsifythe loan applicant’s income, rent payment verification statements, proof of employment andother documents. These documents are shared by these co-conspirators before they are ultimatelyfraudulently submitted to the lender. In addition to the straw buyers, the co-conspirators includecoworkers within the mortgage company and the cooperating title company (closing agent).THE CRIMINAL ENTERPRISEOn September 27, 2007, the victims Cheri and Dan Pulen enter into a real estate sales contractwith Mr. Johnson Cuffy hereinafter referred to as the defendant. Exhibit # 1 The contract thatwas entered into was for the sale of fifty-four separate condominiums at and established price of$ 4, 200,000. The properties were identified as Presidential Golf View Condominiums located inPalm Beach County, Florida.The purpose of this contract was for the defendant to purchase these stated units for the $4,200,000. In addition the defendant was to issue a check for $100,000 to the seller’s escrow agentTran State Title insurance Agency. This check was eventually returned to the seller’s forinsufficient funds. In addition the victim’s had determined that the defendant had obtained forgedwarranty deeds for eleven separate properties of Presidential Golf View Condominiums and thenobtained home equity lines of credit hereinafter referred to as “ HELOC”. These elevenproperties have subsequently been heavily encumbered with the majority of these proceeds ofthese HELOC being diverted to the defendant’s corporate account known as BlueKap Financialor Capital Investment Group.Of the eleven properties that have been compromised two were sold through straw buyers andhave subsequently gone into foreclosure proceedings. The remaining nine properties remainheavily encumbered with high equity lines of credit.On December 18, 2007, your affiant obtained a sworn statement from the registered owner of theinitial eleven properties in question. The victim Ms. Cheri Pulen adamantly claimed that shenever sold the deeds to nine of these properties and that they were in fact forgeries. Theseremaining nine properties that were affected by the invalid deeds all preceded the actual contractdate of September 27, 2007, Exhibits 2 through 12On December 17, 2007, your affiant meets with Attorney Michael Bozdin at his Aventura lawoffices. Mr. Bozdin represents the victim in her sales transactions with the defendant. Mr. Bozdinprovides a sworn recorded statement indicating the following,Mr. Bozdin hereinafter referred to Witness # 1 is contacted by the Palm Beach County TaxRecorders office on November 5, 2007. Witness # 1 is informed that the check the defendantused to pay for the multiple properties being recorded had been returned for insufficient funds.Witness # 1 advised that he had no such knowledge of any sales concerning the victim’sproperty. The witness contacts the victim directly and confirms that the warranty deeds are infact forgeries. The witness then instructs the Palm Beach Recorders Office to fax him thesewarranty deeds for examination. As a result witness # 1 determines that they were in factPage 6 of 22


submitted by the defendant. As a result of this alarming information witness # 1 convinces thedefendant to come into his office in Aventura, Florida in attempt to resolve these issues. Thedefendant agrees to meet with the victim’s attorney and discuss the issues now pending regardingthe sale of the Presidential Golf View Condominiums.Witness #1 does meet with the defendant on November 5, 2007, at his law offices. The defendantadvised witness # 1 that he had in fact forged the warranty deeds in question but did not considerthese actions criminal as he was simply getting a “jumpstart on the financing. The defendantstated that he was eventually going to buy the entire amount of condominiums. Mr. Bozdin wasable to obtain a notarized statement from the defendant admitting to these invalid deeds, Exhibit#13. In addition this affiant submitted a photo lineup consisting of the defendant’s picture withfive additional black and white photographs. Upon reviewing the photo lineup witness # 1 wasable to positively identify the defendant as the party that admitted to the forged warranty deedsas well as the provided sworn statement. Victim/Witness Affidavit signed by witness # 1.Exhibit #14On December 18, 2007, this affiant met with Mr. John Sutton at his South Miami Law Offices.Mr. Sutton hereinafter referred to witness # 2 is legally blind and is assisted by Mr. AdrianAcosta his employee. Mr. Sutton also represents the victim in her criminal complaint against thedefendant. Mr. Sutton indicates that he and his assistant met with the defendant Johnson Cuffyand his sister Lillia Cuffy on Saturday December 8, 2007, at his law office located at 7721 SW62 Ave in South Miami, Florida. Witness # 2 provided a recorded sworn statement in which thedefendants Johnson Cuffy and his sister Lillia Cuffy admitted knowledge of these forgedwarranty deeds. Exhibit #15 Witness # 2 and his assistant advised that Lillia Cuffy and thedefendant Johnson Cuffy admitted to these deeds being forged and that they would be corrected.Lillia Cuffy advised that she would have these deeds for these properties corrected and returnednotarized. Per witness # 2 he confronted Ms. Cuffy regarding the fraudulent lines of credit aswell as the mortgages that were seated based on these deeds. Ms. Cuffy indicated a significantamount of firsthand knowledge concerning these properties, forged deeds and subsequentfinancial transactions regarding them.Upon concluding my sworn statement with witness # 2 I obtained a signed victim/witnessaffidavit from Mr. Acosta. Mr. Acosta was able to positively identify both the defendant and hissister from separate photo line ups. Exhibit #16. It should be noted that prior to the December8th meeting commencing Mr. Acosta had the defendant and his sister submit their driver’slicenses for identification purposes. Both of their licenses were subsequently photo copied.As a result of the defendant’s Johnson & Lillia Cuffy’s action, eleven of the victim’s real estateproperties were fraudulently impacted by mortgages and home equity lines of credit as theft fromthe lending institutions as indicated in the information.These real estate loan closings were conducted by the below listed financial institutions withtheir stated HELOC or mortgage amounts.On Thursday 07/03/08, your affiant obtained a sworn statement from Diane Hildebrand who wasthe notary on the multiple warranty deeds that reflected her name and stamp. Exhibit #17 Ms.Hildebrand reviewed each notarized signature and document. Upon review of these ninePage 7 of 22


warranty deeds Ms. Hildebrand indicated that all were in fact forgeries of her signature andstamp. In addition Ms. Hildebrand indicated that her name had been misspelled multiple times onthese documents. Ms. Hildebrand advised that she was formerly employed as a closing agent forMr. Mike Bozdin for over a ten year period. She stated that all closings were conducted in hisAventura offices and recorded accordingly. Ms. Hildebrand remained adamant that she nevernotarized these closing documents (warranty deeds) and that her signature was in fact forged.1) SunTrust Bank $100,000 Line of CreditLoan# 073031427450Account name: Frumence PaulProperty: 2000 Congress Ave. N Unit K-209West Palm Beach, FloridaRecorded: 11/20/20072) Wachovia Bank HELOC, $87,000Loan # 0729600653Account Name: Frumence PaulProperty: 1950 N. Congress Ave. # 302West Palm Beach, Florida 33401Recorded: 11/15/20073) Wachovia Bank HELOC $110,000Loan # 0729600615Account Name: Frumence PaulProperty: 1821 N. Congress Ave.West Palm Beach, Florida 33401Recorded: 11/15/20074) SunTrust Bank HELOC $110,000Loan# 1071233315Account Name: Ramon Ortiz-PicosProperty: 1820 N. Congress Ave. E-406Palm Beach, FloridaRecorded: 11/15/20075) Wachovia Bank HELOC, $110,000Loan # 4386544410018090Account Name: Ramon Ortiz-PicosProperty: 1750 N. Congress Ave C-102Palm Beach, FloridaRecorded: 11/15/20076) Bank of America HELOC $ 75,000Loan# 1000063897275Account Name: Trumaine PetersProperty: 1900 N. Congress Ave. # H 102Page 8 of 22


West Palm Beach, FloridaRecorded: 10/03/20077) Bank of America HELOC $ 88,000Loan# 68218012381099Account Name: Trumaine PetersRecorded: 10/11/2007Property: 1950 N. Congress Ave. F 409West Palm Beach, Florida 334018) Bank of America HELOC $100,000Loan# 68218012707899Account Name: Michael JimenezProperty: 1720 N. Congress Ave. B-306West Palm Beach, Florida 33401Recorded: 10/03/20079) SunTrust Bank HELOC $240,000Loan # 60708971300012992Acct. Name: Trumaine PetersProperty: 4 Dunbar Rd. Palm Beach, FloridaRecorded: 12/06/200710) Bank of America $217,000 HELOCLoan# 682180119557199Account Name: Kamel AhmedProperty: 15 Dunbar Rd.Palm Beach, Gardens, FloridaRecorded: 11/16/200711) Wachovia Bank $85,600 HELOCLoan# 07296006536Account Name: Hans Jeanty1950 N. Congress Ave. # 302West Palm Beach, Florida 33401Recorded: 11/08/200712) Bank of America HELOC $90,400Loan # 68218012562799Account Name: Hans Jeanty1850 N. Congress Avenue, Apt. F410West Palm Beach, FLRecorded: 10/3/200713) Bank of America HELOC $ 100,000Loan # 68218012585099Page 9 of 22


Account Name: Trumaine Peters4 Dunbar Rd.Palm Beach, Florida 33401Recorded: 10/22/200714) GMAC Mortgage $61,600Loan # 8686450204Account Name: Gregory Giraud1920 N. Congress Ave., # I-102West Palm Beach, Florida 33401Recorded: 12/13/200715) SunTrust Bank $90,000 mortgageLoan# 1000063897275Account Name: Gregory GiraudProperty: 1900 N. Congress Ave. H-102West Palm Beach, FloridaRecorded: 11/16/2007Subpoenas were issued against the account holder Frumence Paul (straw buyer) Wachoviaaccount. A review of the $87,000 home equity line of credit was conducted which revealed thefollowing:Starter check #95 written to Heru Enterprises in the amount of $5,000, it was endorsed bydefendant Cliff Johnson on 11/21/2007.Exhibit #18Starter check # 95 written to defendant Cliff Johnson for $7,000 11/21/07 Exhibit #19Withdrawals slip in the name of defendant Paul Frumence for $10,000 dated 12/03/07 Exhibit#20Withdrawals slip in the amount of $2,661.00 in the name of defendant Paul Frumence dated12/04/07. Exhibit #21Withdrawals slip in the name of defendant Frumence Paul in the amount of $4,600.00 dated12/06/07. Exhibit #22On 11/20/07, defendant Frumence Paul transfers $76,000 to new account # dated 12/24/06.Home Equity Line of Credit Wachovia Bank $87,000.00, closing document. Exhibit #23Statements were obtained by your affiant from the victim Cheri Pulen that she was the rightfulowner of the property used to facilitate this loan. She denies ever selling the property orassigning a representative on her behalf to sell it. As a result of the loan being taken out in thename other than the titleholder the Record of Lien could not be recorded.Page 10 of 22


Loan # 0729600615 filed through Wachovia Bank in the amount of $110,000 in the name ofdefendant Frumence Paul hereinafter referred to as the straw buyer. The funds were in the formof a home equity line of credit. The equity was alleged to have existed in the residence owned bydefendant Frumence Paul located at 1820 N. Congress Ave. in Palm Beach, Florida. The loanapplication was witnessed by defendants John Cuffy and Paula Augusta. The loan document wasnotarized by Paula Augusta # DD474814 on 11/15/07.In March 2007, the straw buyer, defendant Frumence Paul opens savings account with SunTrustBank. At that time Frumence Paul identifies himself as a dishwasher at a local Olive Gardenlocated in Plantation, Florida.On October 30, 2007, a loan request was initiated through SunTrust’s telephone customer servicecenter. The collateral address of 2000 Congress Ave North, Unit K-209, West Palm Beach,Florida was listed. The loan was in the form of a home improvement equity line of credit alsoknown as a “HELOC”.The loan was reviewed and approved and moved into a checking account Frumence Paul openedon 11/26/2007. At the time of the closing defendant Frumence Paul was identified as beingemployed as a dishwasher. When confronted with the information the accountholder indicatedthat this was a second job and that his primary employment was with a company known as“Integral Builders” with a monthly net income of $6,112.34. Integral Builders principal addressis located at 6740 NW 45 court in Lauderhill, Fl. Your affiant contacted the manager at the OliveGarden on May 11, 2008. In addition your affiant has interviewed Frumence Paul’s cousinOminque Paul who is also an Olive Garden employee. Ominque Paul speaks limited English butdid advise your affiant that defendant Frumence Paul has never been employed as a manager of abuilding construction company. Your affiant was also informed by the cousin that defendantFrumence Paul had gotten into trouble with mortgages from Bank of America and SunTrustBank. Your affiant was advised that defendant Frumence Paul has been a full time kitchenemployee. The SunTrust loan has subsequently gone into default. The title holder of thecollateral property is owned by Cheri Pulen of Plantation, Florida. Your affiant has obtained asworn statement from her that she has never sold or relinquished her financial standing of herproperty located at 2000 Congress Ave N. Unit # 209 West Palm Beach, Fl.Subsequent to this loan being issued your affiant examined this account pursuant to a subpoena.A records review determined the following.Check # 99 in the amount of $20,000 withdrawn on 11/26/07 by defendant Frumence Paul.Exhibit #24Heru Enterprises Inc. issued 12/4/07 by defendant Frumence Paul in the amount $72,500.Exhibit #25Defendant Cliff Johnson issued 12/04/07 by defendant Frumence Paul in the amount of$4,600.00. Exhibit #26Page 11 of 22


Heru Enterprises: Your affiant conducted a corporation search through the State of FloridaCorporate Records of Heru Enterprises which determined their principle address to be 34 NW 50Street Miami, Florida. An inspection of this residence on May 15, 2008, revealed it to be in poorstructural condition. The residence was once a single family home which appeared to beseparated into apartments. The residence was currently listed for sale.The corporate officer for Heru Enterprises is identified as defendant Cliff Johnson-Manager. Thecorporation was original formed by Lillia Cuffy the defendant’s sister as of 05/30/2006 through08/1/2007. Mr. Cliff Johnson the defendant became the registered agent of Heru Enterprises until08/31/07.The corporation was amended to reflect Arhi Heru as the new registered agent with defendantCliff Johnson as the Manager. These accounts are designed to receive thousands of dollars ofderived proceeds from ill-gotten Home Equity Lines of Credit transactions. The monies aredeposited into the Heru account and subsequently dispersed back to Bluekap Financial, PGAProperties and Capital Investments.Integral Builders: This corporation was formed by Marc Labidou on or about December 18,1996. The State of Florida corporate records reflect the principal place of business address as6740 NW 45 Court in Lauderhill, Florida. Investigation has determined that on December 7,2007, articles of amendment were filed making the co-defendant Frumence Paul Vice Presidentof Integral Builders with Gary Resil as Chief Executive Officer. The inspection of this propertyconducted on 07/16/08, determined it to be a large single family residence which has been vacantfor an extended period of time. Your affiant spoke with area neighbors who advised that thehouse had been vacant for over the past year and a half. The former owner was a Freddy Labidouwho relocated to Riviera Beach, Florida. Your affiant observed numerous pieces of mail in thename of Integral Builders attention Gary Resil protruding from the mailbox.A search through the Florida Department of Revenue reflects a negative finding of wages forIntegral Builders as a corporation as well as wages for Frumence Paul as an employee or officer.As such the verification of employment of defendant Frumence Paul and the financial statementon his behalf is fraudulent. In addition to the three collateral properties that were portrayed asownership on behalf of Frumence Paul to facilitate the three equity loans.“Grand Theft” is categorized as a specific unlawful activity. As a result of this investigation,once the proceeds were obtained from the lenders these funds were deposited into or funneledthrough one of the personal, corporate or shell company bank accounts listed not limited to, :Capital Investments, BlueKap Financial, Heru Enterprises, DD&J Cleaning Services, Fresh StartCleaning Services, Great Mind Development, ABS Financial Group, Integral Builders, ScientificOptions; Johnson Cuffy, Cliff Johnson, Trumaine Peters, Hans Jeanty, Frumence Paul, GregoryGiraud, Gregory Aimes, Ramon Ortiz-Picos . The defendants involved in the scheme financiallytransacted the cash out of the bank by writing checks to the individuals and/or company listedabove or were compensated financially for their role in these schemes.Your Affiant realizes through investigative findings that the funds involved in these transactionswere derived from Mortgage Fraud. Those defendants in this conspiracy knew that the fundswere derived from illegal activities. These defendants committed this conspiracy acts against thePage 12 of 22


lending institutions in violation of Florida Statute 895.03(3), 895.03(4), 812.014(2)(a)(1) and812.014(2)(b).Frumence Paul LoanSunTrust Loan # 0730314274507601 NW 14th Place Miami, Fl. 33147(COLLATERAL PROPERTY #1)2000 N. Congress Ave. K 209West Palm Beach, FloridaThe FraudOn October 3, 2007, Frumence Paul executes a $100,000 equity line of credit against theproperty located at 2000 N. Congress Ave. K 209 in West Palm Beach, Florida to lenderSunTrust Bank.A HUD-1 settlement statement was presented to defendant Frumence Paul at closing on10/3/2007, in Tamarac, Florida. The closing representative for SunTrust Bank was Aldo De LaNoval. The borrower’s identity was confirmed by review of his immigration card and Floridadriver’s license. Mr. Paul was asked several questions at closing which sparked the closingagent’s suspicion. The borrower indicated that his occupation was that of a dishwasher for theOlive Garden Restaurant. The closing agent confronted the borrower in regards to his applicationstated occupation as a site manager for Integral Builders. The borrower quickly added throughhis translator that his dishwashing job was merely a second job he maintained. According to theclosing agent Mr. Paul identified the interpreter as his son, then changed it to his nephew andthen finally to his contractor, all during the time period it took to close the loan. The closingagent advises your Affiant that the loan closes and he obtains the $100,000 which he transfersover to a small start up checking account. Frumence Paul then authors a check in the name of“Heru Enterprises” in the amount of $72,500.00 on 12/4/07. An additional draft in the amount of$20,000 is made out to Frumence Paul on 11/26/07, for cash. On 11/28/07, Frumence Paul issuesa $10,000 payment in the name of John Connolly and Jose Rodriguez in the amount of$5,000.00. Payments of $4,600 were also made to Cliff Johnson (Heru Enterprises) on 12/4/07.As a result of these transactions SunTrust bank loan #073031427450 has gone into default.On 4/22/08, a subpoena was issued against Heru Enterprises LLC which operated out of BankAtlantic acct. The signature card for the account reflects the name of Cliff Johnson. A review ofthe banks records displayed large sums of funds being made out to Cliff Johnson including the$72,500 made out to Heru Enterprises on 12/04/07. The back of this document is endorsed byCliff Johnson.On 12/06/07 check# 631588 is authored to a corporation known as Foreclosure First Aid in theamount of $8,000.00. State of Florida Division of Corporations revealed it to be operated byCharles Reynolds of 525 NW 52 Ave. in Boca Raton. Your Affiant conducted a corporate searchvia the State of Florida Corporations and determined that subject Charles Reynolds is listed asPage 13 of 22


president of Payment Processing Systems, Inc. located at the principal address of 701 W CypressCreek Road # 200 Ft. Lauderdale, Fl. The registered agent name is Capital Investments located at2255 Glades Rd. # 324A in Boca Raton, Fl. The president of Capital Investments now known asCapital Investments and Associates is Johnson Cuffy also of BlueKap Financial. In addition youraffiant conducted a records search through Sun Tax of the Florida Department of Revenue whichrevealed Charles Reynolds as an employee of Capital Investments earning $2,320.00 in the firstquarter of 2008. Capital Investments principal address is also 701 W Cypress Creek Rd. in Ft.Lauderdale, Fl.(COLLATERAL PROPERTY #2)Frumence Paul Loan1950 N. Congress Ave. # J 302West Palm Beach, FloridaOn 11/15/2007 Frumence Paul executes a Prime Equity Line of Credit through Wachovia Bank.The equity line was authorized in the amount of $87,000.00. The collateral property used to fundthis loan was identified as 1950 N. Congress Ave. J 302 in Palm Beach, Fl. It was determinedthat after the loan closed it was determined that the mortgage could not be recorded as thetitleholder of the property was not that of the borrower. The contract was witnessed andnotarized by Ms. Paula Augustus an employee of John Cuffy and BlueKap Financial as well aswitnessed by John Cuffy himself.On 11/20/2007, a deposit of $76,000.00 was made into Frumence Paul’s new Wachovia account.A distribution of monies was identified as follows;1) Check # 95 made out to Heru Enterprises for $5,000.00 11/21/07. Exhibit #182) Check # 93 made out to defendant Cliff Johnson for $7,000.00 on 11/21/07. Exhibit #193) Wachovia withdrawal slip made out to defendant Frumence Paul for $10,000.00 on11/30/2007, deposited into his SunTrust Account. Exhibit #204) Wire transfer of $52,000.00 sent to SunTrust Bank account on12/03/2007, from Frumence Paul Wachovia account. Exhibit #21(COLLATERAL PROPERTY #3)Frumence Paul Loan1820 N. Congress Ave. E 306West Palm Beach, FloridaOn November 6, 2007, Frumence Paul executes a Prime Equity Line of Credit in the amount of$110,000.00. The collateral property in question was identified as 1820 Congress Ave E 306 inPalm Beach County, Florida. The property was owned by Swan Properties who allegedly soldthis condominium for $138,000.00 on October 3, 2007. This affiant obtained a sworn statementPage 14 of 22


from the owner Ms. Cheri Pulen of Swan Properties. Ms. Pulen advised that the signature on theHUD-1 is not hers and that she still owns the property.Frumence Paul is awarded the $110,000.00 line of credit under Wachovia loan #4386540314254542. These monies are subsequently depleted via cash advances and transferredinto account also with Frumence Paul as the account holder of record. These funds were cashadvanced on 11/20/2007, in the amounts of $76,000.00 and $34,000.00 each. Exhibits # 22 & 23(COLLATERAL PROPERTY # 4)Ramon Ortiz-Pico Loan1820 N. Congress Ave. E 406West Palm Beach, FloridaOn 11/15/2007, a SunTrust Home Equity Loan Line of Credit was established through theinternet in the name of Ramon Ortiz-Pico. The collateral property in question was identified as1820 North Congress Ave, #E406 in West Palm Beach, Florida. The loan amount was approvedand a checking account was opened credited with the $110,000 as of 11/30/2007. SunTrustaccount was assigned. The property in question was allegedly sold on 10/03/2007 by SwanProperties. This affiant obtained a sworn statement from Ms. Cheri Pulen owner of the propertyin question and president of Swan Properties. Ms. Pulen advised that she had not sold thisproperty and that the signature on the HUD-1 properties was not hers.A subpoena was issued for the account information and banking activity which revealed thefollowing;1) Check # 93 issued in the amount of $60,000.00 made out to BlueKap Financial Inc.on 12/3/2007. This business is owned by Lillia and Sylvester Cuffy.Exhibit # 242) Check # 94 issued in the amount of $22,500.00 made out to Heru Enterprises on12/03/2007. Defendant Cliff Johnson is the account holder for Heru.Exhibit # 253) Check # 95 issued in the amount of $7, 500.00 made out to cash on 12/14/2007.Exhibit # 264) Check # 96 made out to cash for $6,000.00 on 2/22/2007.Exhibit # 27SunTrust security was able to freeze the account before all of the assets were transferredresulting in a recovery of $12,001.22. Total loss on this loan was $87,998.78.(COLLATERAL PROPERTY # 5)Ramon Ortiz-Pico Loan1750 N Congress Ave. C 102West Palm Beach, FloridaPage 15 of 22


On 11/15/2007, Ramon Ortiz Pico obtained a Primary Equity Line of Credit fromWachovia Bank in the amount of $110,000.00. The equity line of credit was closed underWachovia account. The collateral property in question was identified as 1750 North CongressAve. C 102 West Palm Beach, Florida. This affiant obtained a sworn statement from theregistered owner of the property Ms. Cheri Pulen of Swan Properties Inc. Ms. Pulen advised thatshe had not sold this property nor had she given authorization on her behalf to sell it.On 12/13/2007, these originated funds were transferred to checking account. On12/14/2007 a wire transfer of $82,500.00 was made to Heru Enterprises.Exhibit # 28. A review of the closing documents revealed that Paula Augustus and John Cuffywere listed as the witnesses for this real estate transaction. Loan is currently foreclosed.(COLLATERAL PROPERTY #6)Trumaine Peters Loan1950 N. Congress Ave. # J102West Palm Beach, FloridaOn 10/03/2007, Bank of America issues a Home Equity Line of Credit to Trumaine Peters underLoan # 658218012584799 in the amount of $75,000.00. The collateral property has beenidentified as 1950 N. Congress Ave J 102 in West Palm Beach, Florida. These granted fundswere transferred into [account] which Trumaine Peters is identified as the account holder ofrecord.On 12/18/2007, your affiant obtains a sworn statement from Ms. Cheri Pulen who is theregistered owner of this property. Ms. Pulen reviewed the closing documents and advised thatshe has never sold this property and that the signature as the seller is not hers. Loan is currentlyforeclosed. This affiant issued a subpoena to Florida Power & Light also known as FP&Lregarding the account number that appears on the utility bill for Trumaine Peters.Exhibit # 29. A records reviewed revealed that Trumaine Peters was not the customer of recordfor this residence. The account was that of Johnson Cuffy while he resided at 743 NE 17th Wayin Ft. Lauderdale, Florida.(COLLATERAL PROPERTY #7)Trumaine Peters Loan1950 N. Congress Ave. # 409West Palm Beach, FloridaOn 10/11/2007, Bank of America issues a Home Equity Line of Credit in the name of TrumainePeters in the amount of $88,000.00 under loan # 68218012681099. The collateral property wasidentified as 1950 N. Congress Ave. J 409 West Palm Beach, Florida. On 10/12/2007 a$25,000.00 transfer is made into Trumaine Peter’s account. On 10/15/2007 a second transfer of$63,000.00 is made into this account. Loan is currently foreclosed.Page 16 of 22


This affiant issued a subpoena to Florida Power & Light also known as FP&L. A records searchrevealed that the account # given to Bank of America in support of this equity line of creditactually was assigned to Johnson Cuffy while he resided at 743 NE 17th Way in Ft. Lauderdale.Florida. Exhibit # 30(COLLATERAL PROPERTY #8)Trumaine Peters Loan4 Dunbar Rd. Palm Beach, FloridaOn 10/3/2007, Bank of America issues a Home Equity Line of Credit under loan #68218012585099 in the name of Trumaine Peters. The total loan amount was $100,000. Thecollateral property has been identified as 4 Dunbar Rd. in Palm Beach, Florida. On 10/12/2007,money transfers of $63,000.00 and $37,000.00 are made into account. This account has beenidentified as Trumaine Peters as the account holder. Loan is currently foreclosed.On 05/20/2008, a subpoena is issued to Florida Power & Light also known as FP&L. A recordssearch of the account number listed on a utility bill submitted to Bank of America was actuallythat of Johnson Cuffy while resided at 743 NE 17th Way in Ft. Lauderdale, Florida. Exhibit # 30(COLLATERAL PROPERTY #9)Trumaine Peters Loan4 Dunbar Rd Palm Beach, FloridaOn 12/06/2007, SunTrust Bank authorized an Equity Line of Credit under loan #60708971300012992 in the amount of $240,000 in the name of Trumaine Peters. The creditbalance was then transferred to account by Trumaine Peters. It should be mentioned thatSunTrust Bank security froze this account with a remaining balance of $80, 865.58.On 05/20/2008, a subpoena was issued to Florida Power & Light regarding the account numberon the utility bill that was received by SunTrust Bank. A records search revealed that this FP&Laccount number was assigned to that of Johnson Cuffy while he resided at 734 NW 17th Way inFt. Lauderdale, Florida. Exhibit # 30A review of this account revealed check disbursements to the following;· $75,000.00 paid to PGA Properties. The former registered agent is Lillia Cuffy. Exhibit#31· A total of $61, 637 paid to Fresh Start Cleaning. JoyWilliams is the account holder. Exhibit #32· $16,700 paid to Companies Inc. Bank of America, Exhibit # 33· $8,950.63 paid to Capital Investments Wachovia Acct. This company is operated byJohnson Cuffy with this account in his name. Exhibit # 34Page 17 of 22


· On 10/12/2007, $188,000.00 was made payable to Gregory Aime. Exhibit # 35(COLLATERAL PROPERTY #10)Kamel Ahmed Loan15 Dunbar Rd. Palm Beach Gardens, FloridaOn 11/16/2007, an application of a $217,000.00 Home Equity Line of Credit short form wasfiled on line with Bank of America. The account name was Kamel Ahmed. The identifiedcollateral property was 15 Dunbar Rd. in Palm Beach Gardens, Florida. The broker’s emailaddress was CUFFYJOHN2004@HOTMAIL.COM . The loan agreement was concluded on09/6, 2007, with $216,776.66 being deposited into Bank of America acct. This affiant had asubpoena issued for this account which revealed it to be in the following names;1) Kenneth Pierre Louis2) Gregory Aime3) Kamal AhmedOn 09/14/2007, $107,000.00 is transferred from this account to the account of Joy Williams’s,acct. Exhibit # 45 At exactly 4:36pm a wire in the amount of $96,000.00 in made to the accountfor Capital Investments Wachovia Bank. Exhibit # 46. On 04/08/08, a subpoena was issued forthe records pertaining to this account. It was determined that this account was in the name ofCapital Investments, LLC located at 4635 NW 26th Ave. in Boca Raton, Florida. The accountapplication displayed Johnson Cuffy as the president. An additional $10,000 was transferred intothis account on 09/28/2007 from DD&J Cleaning Wachovia Bank acct. Exhibit # 36. Asubpoena for this account information was also issued which revealed it to be assigned to JoyWilliams as well.Your Affiant reviewed the bank records for Joy Williams’s Bank of America account during thetime period between 02-10-07 through 3-14-07. Ms. Williams account information reflected abalance of $11.00 on 07/14/07. On 07/14/07, a transfer of $95,000.00 was made into her account.Exhibit #48. On 07/27/07, a second deposit of $34,000.00. On this same date Joy Williamsconducts a wire transfer of $32,000.00 to Wachovia Bank which has been indicated as JohnsonCuffy. On 07/17/07, a transfer of $19,000.00 was deposited into Johnson Cuffy’s Wachoviaaccount. Exhibit # 50A second review of these records from 09/13/07 through 10/15/07, indicated a transfer of$96,000.00 on 09/14/07 to Johnson Cuffy’s account. This account has been identified as CapitalInvestments. Exhibit # 51On 09/28/07, a funds transfer was conducted by Joy Williams from her business accountidentified as DD&J Cleaning Services Inc. This account # shows a transfer of $10,000.00 intoCapital Investment Wachovia Bank account # which Johnson Cuffy.Your Affiant reviewed bank records of Joy Williams’s SunTrust account. A review of JoyWilliams December 2007 revealed that she received $61, 637.07 into her account from TrumainePeters.Page 18 of 22


Exhibit # 52. Subject Joy Williams withdrew a total of $44,700.00 in cash and issued a$10,000.00 draft in the name of Roberto Orozco.Your Affiant conducted a records search through the Florida Department of Corporationsconcerning Fresh Start Cleaning and DD&J Cleaning Services. These corporations indicated aprincipal address of 580 NW 29th Ave in Ft. Lauderdale, Fl. On 04/22/08, your Affiantresponded to this address and determined it to be a residential home in poor condition. Youraffiant spoke with Joy Williams’s cousin Talisa Rolle who advised that Joy Williams had neverlived at this residence with her.I requested that she have Joy contact this Affiant as soon as possible.This affiant received a telephone call from the subject’s mother Tarisa who informed me that shewould have joy Williams contact me. This affiant was contacted by Joy Williams by cellulartelephone. She advised that her cleaning company was not solvent and that she had not derivedany money from it in 2006 and limited income from it in 2007. Ms. Williams did advise that sheused these accounts to deposit numerous checks for her friend named Johnson Cuffy. Williamsstated that she received approximately $2,000.00 per check to deposit into her accounts. Ms.Williams did admit that some of these checks were over $20,000.00. Ms. Williams refused tomeet in person to discuss these transactions.On Tuesday 04/30/08, your Affiant issued a subpoena to Chrysler Financial regarding a vehiclepurchase made by Ms. Joy Williams. A copy of the purchasing file was obtained by this Affiant.A review of the credit application revealed that Joy Williams had formerly been employed byBlueKap Financial earning a monthly stated income of $4,500.00. Exhibit #53. The applicationand loan request was dated 01/19/2007. The vehicle was purchased for approximately $30,000by Joy Williams. Your Affiant obtained a complete copy of the Joy Williams vehicle sale file.The loan file number for this vehicle from Chrysler Financial was 1010847206. On 05/11/2008,a draft was issued under the account of Capital investments & Associates in the amount of$7,000.00. The signature on the account was in the name of John Cuffy. The draft was indicatedto the loan # of 1010847206. The account was under National City Bank in Tamarac, Florida.Exhibit #54COLLATERAL PROPERTY #11HANS JEANTY LOAN1880 N. CONGRESS AVE. F-410WEST PALM BEACH, FloridaOn 10/04/2007, Mr. Hans Jeanty is awarded a $85,600.00 Home Equity Line of Credit fromBank of America (loan# 68218012583399). The collateral property in question has beenidentified as 1880 N. Congress Ave. # F-410 in West Palm Beach, Florida.On 12/18/2007, your affiant interviewed the owner of the property Ms. Cheri Pulen. Your affiantobtained a sworn recorded statement indicating that she had never sold this property and that shewas the actual owner of this property. In addition Ms. Pulen reviewed the signature that wasevident on the warranty deed. Ms. Pulen remained adamant that this was not her signature.Page 19 of 22


On 07/03/2008, your affiant obtained a recorded sworn statement from Ms. Diane Hildebrandwho is listed as the notary on the warranty deed for this impacted property. Ms. Hildebrandremained adamant that she had not signed this document nor had she authorized anyone in heroffice to use her notary.Once Bank of America awarded this loan amount of $85,600.00 it was disbursed into acct # on10/29/2007.COLLATERAL PROPERTY #12HANS JEANTY LOAN1850 N. Congress Ave. #F-410West Palm Beach, FloridaOn 10/03/2007, Mr. Hans Jeanty is awarded a Home Equity Line of Credit in the amount of$90,400.00 from Bank of America. Loan # 68218012562799. The collateral property in questionwas identified as 1850 N. Congress Ave. #F-410 in West Palm Beach, Florida.On 12/18/2007, your affiant obtained a recorded sworn statement from the actual owner Ms.Cheri Pulen that she was the rightful owner of the property and that she had never sold theproperty. The signature on the warranty did was not hers as well as reported in her swornstatement.On 07/03/2008, your affiant obtained a sworn statement from Ms. Diane Hildebrand who islisted as the notary of record in this warranty deed. Ms. Hildebrand indicated that she had notsigned nor notarized this document in question. In addition Ms. Hildebrand made it clear that noone uses her notary stamp but her.As a result of these two forged and fraudulent warranty deeds Bank of America issuedtwo separate lines of credit to Mr. Hans Jeanty totaling $176,000.00. These funded accounts havenot been repaid in full and have subsequently been foreclosed on.A financial review of Hans Jeanty’s accounts revealed the following transactions;1) $15,000.00 transferred to Lloyd Gelu MFG Investments 10/04/2008.Exhibit # 552) $20,000 transferred to Joy Williams account 10/04/2007, DD&J Cleaning Service Exhibit# 563) $7,000.00 to Joy Williams account on 10/16/2007, DD&J Cleaning.Exhibit # 574) $42,000.00 transferred to Lloyd Gelu account on 10/09/2007.Exhibit # 585) $50,000.00 transferred to Jeanty’s account on 10/05/2007.Page 20 of 22


Exhibit # 596) $25,000.00 transferred to Jeanty account ($90,400.00 Heloc).Exhibit # 59COLLATERAL PROPERTY #13GERALD GIRAUD LOAN1920 N. Congress Ave, I 102West Palm Beach, FloridaOn 11/06/2007 Mr. Gregory Giraud is awarded a Home Equity Line of Credit by GMACMortgage in the amount of $61,600.00. Loan # 686450204 was issued by GMAC Mortgage. Thecollateral property was identified as 1920 N. Congress Ave. # I 102 in West Palm Beach,Florida.On 12/18/2007, your affiant obtained a recorded sworn statement from the actual owner of theproperty in question, Ms. Cheri Pulen. Ms. Pulen reviewed the warranty deed in questioned andadvised that she had not signed this document and that she still in fact owned this property.On 07/03/2008, your affiant met with Ms. Diane Hildebrand who is reflected as thenotary of record on the warranty deed. Upon review of this document Ms. Hildebrand advisedthat she did not sign this warranty deed and that her notary stamp appears to be a copy. Thesignature bearing her name is a forgery. Ms. Hildebrand provided a recorded sworn statementreflecting this information. Ms. Hildebrand was formerly employed at Trans-State Titleinsurance located at 3050 Aventura Blvd, Suite 300 Aventura, Florida. Ms. Hildebrandworked for Attorney Marty Bodzin for over a ten year period.On 12/17/2007, your affiant obtained a recorded sworn statement from Mr. Bodzin at hisAventura law office. Mr. Bodzin provided me with a copy of a notarized statement from subjectJohnson Cuffy dated 11/05/2007. In this sworn document signed by Johnson Cuffy it states thatthe warranty deed for this property and many others had been forged. Mr. Cuffy states in hissworn document that both the seller’s and the notary signature had been forged. Mr. Cuffysigned this document as president of Capital Investments & Associates, LLC.As a result of this fraudulent warranty deed the loan was authorize and the funds werereleased. Subsequently this home equity loan has gone into foreclosure.COLLATERAL PROPERTY #14GREGORY GIRAUD LOAN1900 N. Congress Ave. # H 102West Palm Beach, Florida 33401Page 21 of 22


On 09/16/2007, a warranty deed was accepted by SunTrust Bank for the purpose of documentingownership and securing a $90,000.00 home equity line of credit. The document was allegedlysigned by the owner of the collateral property Ms. Cheri Pulen. The collateral property has beenidentified as 1900 N. Congress Ave. #H 102 in West Palm Beach, Florida. The sale price for theproperty was established at $138,000.00 by the seller. As a result of SunTrust accepting thewarranty deed as proof of ownership the $90,000.00 was released. It was when the warranty deedwas attempted to be filed with the recorder’s office in Palm Beach County that it was determinedthat Mr. Gregory Giraud did not have ownership in the collateral property. As a result on06/11/2008, SunTrust charged off a total of $89,635.48.On Monday August 25, 2008, this affiant interviewed Ms. Lisa Frederick who formerly workedfor BlueKap Financial and Capital Investments. Ms. Frederick provided a sworn recordedstatement as to knowledge of the daily activities of both of these former businesses. Ms.Frederick indicated that she was a loan processor and made ten dollars an hour and $500.00 forevery loan she closed. She indicated that John Cuffy was creating false occupational historiesand well as financial documents to support loan applications that were submitted. The witnessindicated that the loans were placed in the names of straw buyers with fraudulent work andfinancial histories. The straw buyers never met with her only John Cuffy. The witness was giventhe information to file with the application. Ms. Frederick claims that during her employment shereceived complaints daily from those customers that had been swindled. The witness recalled allof the HELOC loans taken out against Presidential Golf view Condominiums in West PalmBeach. She stated that each of these loans she had worked on and received the financial historiesof each client from John Cuffy himself. Ms. Frederick was submitted a photo lineup of subjectJohn Cuffy and was able to positively identify him. Exhibit # 60.Based upon the foregoing, your affiant has probable cause to believe that the defendants listedabove have violated numerous Florida Statutes to include, Racketeering, in violation of Fla.Stat. 895.03(3); Racketeering Conspiracy, in violation of Fla. State. 895.03(4); Grand Theft,in violation of Fla. Stat. 812.014; 812.014(2)(a)(1) and 812.014(2)(b).Page 22 of 22

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