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

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

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from the owner Ms. Cheri Pulen <strong>of</strong> 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 <strong>of</strong> credit under Wachovia loan #4386540314254542. These monies are subsequently depleted via cash advances and transferredinto account also with Frumence Paul as the account holder <strong>of</strong> record. These funds were cashadvanced on 11/20/2007, in the amounts <strong>of</strong> $76,000.00 and $34,000.00 each. Exhibits # <strong>22</strong> & 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 <strong>of</strong> Credit was established through theinternet in the name <strong>of</strong> 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 <strong>of</strong> 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 <strong>of</strong> the propertyin question and president <strong>of</strong> 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 <strong>of</strong> $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 <strong>of</strong> $<strong>22</strong>,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 <strong>of</strong> $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/<strong>22</strong>/2007.Exhibit # 27SunTrust security was able to freeze the account before all <strong>of</strong> the assets were transferredresulting in a recovery <strong>of</strong> $12,001.<strong>22</strong>. Total loss on this loan was $87,998.78.(COLLATERAL PROPERTY # 5)Ramon Ortiz-Pico Loan1750 N Congress Ave. C 102West Palm Beach, Florida<strong>Page</strong> 15 <strong>of</strong> <strong>22</strong>

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