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

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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
Page 1 and 2: AFFIDAVIT IN SUPPORT OF ARREST WARR
Page 3 and 4: 229 Pelican Way Del Ray Beach, Flor
Page 5 and 6: ‘Person’ means a natural person
Page 7 and 8: submitted by the defendant. As a re
Page 9 and 10: West Palm Beach, FloridaRecorded: 1
Page 11: Loan # 0729600615 filed through Wac
Page 15 and 16: from the owner Ms. Cheri Pulen of S
Page 17 and 18: This affiant issued a subpoena to F
Page 19 and 20: Exhibit # 52. Subject Joy Williams
Page 21 and 22: Exhibit # 596) $25,000.00 transferr

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

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