in the supreme court of florida case number …myfloridalegal.com/indictmentcarlowetal.pdf · state...
Post on 19-May-2018
215 Views
Preview:
TRANSCRIPT
1
IN THE SUPREME COURT OF FLORIDACASE NUMBER SC02-2645
STATE OF FLORIDA, SEVENTEENTH STATEWIDE JURYGRAND JURY INDICTMENT NO. 1
Plaintiff, vs. BROWARD CO. CASE NO.
MICHAEL CARLOW, (A) OSWP CASE NO.: 2002-0052FLLCANDACE CARLOW, (B)THOMAS ATKINS, JR., (C)MARILYN ATKINS, (D)HENRY GARCIA, (E)FABIAN DIAZ, (F)JOEL DE LA OSA, (G) DAVID EBANKS, (H) a/k/a Julius TaylorJOSE L. BENITEZ, (I)DARIEL TABARES, (J) MICHAEL E. BURMAN, (K)LAZARO VILARCHAO, (L)IVAN VILARCHAO, (M)JOSEPH VILLANUEVA, (N)ARTURO GODINEZ, (O)TOM MARTINO, (P)JULIO CESAR CRUZ, (Q) a/k/a Ricardo Garcia,GISELA GONZALEZ, (R)
Defendants._________________________________/
INDICTMENT FOR:
COUNT 1: COUNT 2:Racketeering (F1) Conspiracy to Commit Racketeering (F1)F.S. 895.02(4) F.S. 895.03(4)Defendants A-Q Defendants A-Q
2
COUNT 3: COUNT 4:Organized Scheme to Defraud (F1) Grand Theft (F1)F.S. 817.034(4)(a)1 F.S. 812.014(1), (b), (2)(a)1Defendants A-R Defendants A & F
COUNT 5: COUNT 6:Dealing In Stolen Property (F2) Sale or Delivery of a Controlled Substance (F3)F.S. 812.019(1) F.S. 893.13(1)(a)(2) and 893.03(3)(f)Defendants A & F Defendant A
COUNTS 7-12, 15, 19: COUNT 13:Possession with Intent to Sale and Delivery of a Controlled Substance Sell Legend Drugs (F3) F.S. 893.13(1)(a)(2) and 893.03(3)(f) (F3)F.S. 499.03(1) Defendant ADefendant A
COUNTS 14 COUNTS 16 & 17:Possession with Intent to Purchase or Receipt of a Legend Sell Legend Drugs (F3) Drug from Unauthorized Person (F3)F.S. 499.03(1) F.S. 499.005(14)Defendants A, C, E, G, Defendant A
COUNT 18 COUNT 20:Possession with Intent to Possession with Intent to Sell Legend Drugs Sell Legend Drugs (F3) F.S. 499.03(1) (F3)F.S. 499.03(1) Defendants A & J Defendant H
COUNTS 21-26 COUNTS 27-32:Possession with Intent to Purchase or Receipt of a Legend Drug Sell Legend Drugs (F3) from Unauthorized Person (F3)F.S. 499.03(1) F.S. 499.005(14)Defendants L, M, N Defendant P
3
IN THE NAME AND BY THE AUTHORITY OF THE STATE OF FLORIDA
COUNT 1Racketeering
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that beginning on or about April 5, 2001, and continuing through and including on, or about,
July 1, 2003, in the Ninth, Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial Circuits of
Florida, to wit: Orange, Miami-Dade, Palm Beach, Broward, and Martin Counties, Florida, as part
of a related transaction occurring in two or more judicial circuits, the defendants, MICHAEL
CARLOW, CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY
GARCIA, FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE
L. BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO,
IVAN VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia, and others known and unknown to the GRAND
JURY, while employed by or associated with an enterprise, as defined in section 895.02(3), Florida
Statutes, to wit: BTC Wholesale, Inc., a Florida corporation; G&K Pharma, LLC.; a Maryland
corporation; Complete Wholesale, Inc.; a Maryland corporation; Accucare, LLC, a Florida
corporation; JB Pharmaceuticals, Inc., a Texas corporation; and Pormis Wholesale Distributors,
Inc., a Texas corporation; acting together with a group of individuals, associated in fact, although
not a legal entity, to wit: Michael Carlow, Candace Carlow, Thomas Atkins, Jr., Marilyn Atkins,
Henry Garcia, Fabian Diaz, Joel De La Osa, David Ebanks, Jose L. Benitez, Dariel Tabares, Michael
4
E. Burman, Lazaro Vilarchao, Ivan Vilarchao, Joseph Villanueva, Pamela Walter, Mark Novosel,
Arturo Godiñez, Mark Siegel, and Tom Martino, and, in furtherance of which enterprise, said
persons did unlawfully, willfully and knowingly conduct or participate in the affairs of said
enterprise, directly or indirectly, through a continuous pattern of racketeering activity as defined by
section 895.02(4), Florida Statutes, by committing crimes chargeable by Indictment under Title 18,
United States Code, Sections 1341, 1343, and Chapter 812, Florida Statutes, and by engaging in at
least two of the following incidents of racketeering activity which had similar intents, results,
accomplices, victims or methods of commission, or were otherwise related by distinguishing
characteristics, and were not isolated incidents, including, but not limited to:
Predicate 1A:Grand Theft
Beginning on or about January 16, 2002, and continuing through, and including, January 20,
2002, in Miami-Dade and Broward Counties, Florida, MICHAEL CARLOW and FABIAN DIAZ
did knowingly and unlawfully obtain or use, or endeavored to obtain or use, legend drugs as defined
in section 499.003(19), Florida Statutes, said property being the property of another, to wit: Bio-Med
Plus, Inc., a Florida corporation, of a value of $100,000 or more, with the intent to either temporarily
or permanently appropriate the property to their own use or to the use of another person not entitled
thereto, contrary to section 812.014(1),(b),(2)(a)1, Florida Statutes.
5
Predicate 1BDealing in Stolen Property
On or about January 20, 2002, in Miami-Dade and Broward Counties, Florida, MICHAEL
CARLOW and FABIAN DIAZ did knowingly and unlawfully traffic in or endeavor to traffic in
property to wit: legend drugs, as defined in section 499.003(19), Florida Statutes, that they knew or
should have known were stolen, contrary to section 812.019(1), Florida Statutes.
Predicate 2Mail Fraud
On or about August 31, 2001, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so, cause
to be delivered by mail, according to the direction thereon, a certain letter from the Florida
6
Department of Health, Tallahassee, Florida, to Optia Medical, Las Vegas, Nevada, contrary to 18
U.S.C. §1341.
Predicate 3Mail Fraud
On or about January 3, 2002, in Miami-Dade County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs, when in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so, cause
to be delivered by mail, according to the direction thereon, a certain letter from Lane C. Reedman,
El Paso, Texas, to Fabian Diaz, c/o Oasis Management, Miami, Florida, contrary to 18 U.S.C.§1341.
7
Predicate 4Mail Fraud
On or about June 21, 2002, in Miami-Dade County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were at different times either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so, cause
to be delivered by mail, according to the direction thereon, a certain letter from David Ebanks, a/k/a
Julius Taylor, Miami, Florida, to Lori Barrera, Corpus Christi, Texas, contrary to 18 U.S.C. §1341.
Predicate 5Mail Fraud
On April 5, 2001, in Broward County, Florida, MICHAEL CARLOW, CANDACE
CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA, FABIAN
DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L. BENITEZ,
8
DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ having devised a scheme to defraud prescription drug consumers residing
inside and outside the state of Florida by selling into the wholesale prescription drug market what
was purported to be pure, genuine and unadulterated prescription drugs when, in fact, the said
prescription drugs were, at different times, either counterfeit, relabeled, stolen, illegally purchased
from Medicaid recipients, illegally purchased from unlicensed persons, illegally imported into the
United States, stored in unlicensed facilities, or sold with false, fraudulent or forged documentation,
did, for the purpose of executing such scheme or attempting to do so, deposit or cause to be
deposited, a package to be sent or delivered by a private or commercial interstate carrier, to wit:
Federal Express, from AmeRx, Inc., Oakland Park, Florida, to Albers Medical, Inc., Kansas City,
Missouri, contrary to 18 U.S.C. §1341.
Predicate 6Mail Fraud
On September 11, 2002, in Palm Beach County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
9
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so,
deposit or cause to be deposited, a package to be sent or delivered by a private or commercial
interstate carrier, to wit: United Parcel Service (UPS), from Accucare, Boynton Beach, Florida, to
Albers Medical, Kansas City, Missouri, contrary to 18 U.S.C.§1341.
Predicate 7Mail Fraud
On October 22, 2002, in Palm Beach County, Florida, MICHAEL CARLOW, CANDACE
CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA, FABIAN
DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L. BENITEZ,
DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs, were at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
10
or forged documentation, did, for the purpose of executing such scheme or attempting to do so,
deposit or cause to be deposited, a package to be sent or delivered by a private or commercial
interstate carrier to wit: United Parcel Service (UPS), from Four Points Wholesale, Boynton Beach,
Florida, to Albers Medical, Kansas City, Missouri, contrary to 18 U.S.C.§1341.
Predicate 8Mail Fraud
On November 11, 2002, in Palm Beach County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so,
deposit or cause to be deposited, a package to be sent or delivered by a private or commercial
interstate carrier, to wit: United Parcel Service (UPS), from Four Points Wholesale, Boynton Beach,
Florida, to Albers Medical, Kansas City, Missouri, contrary to 18 U.S.C. §1341.
11
Predicate 9Mail Fraud
On December 18, 2002, in Palm Beach County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so,
deposit or cause to be deposited, a package to be sent or delivered by a private or commercial
interstate carrier, to wit: United Parcel Service (UPS), from G & K Pharma, Boynton Beach, Florida,
to Albers Medical, Kansas City, Missouri, contrary to 18 U.S.C. §1341.
Predicate 10Mail Fraud
On March 27, 2003, in Miami-Dade County, Florida, MICHAEL CARLOW, CANDACE
CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA, FABIAN
12
DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L. BENITEZ,
DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so,
deposit or cause to be deposited, a package to be sent or delivered by a private or commercial
interstate carrier, to wit: United Parcel Service (UPS), from David Ebanks, a/k/a Julius Taylor,
Miami, Florida, to Albers Medical, Inc., Kansas City, Missouri, contrary to 18 U.S.C.§1341.
Predicate 11Mail Fraud
On May 19, 2003, in Broward County, Florida, MICHAEL CARLOW, CANDACE
CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA, FABIAN
DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L. BENITEZ,
DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
13
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so,
deposit or cause to be deposited, a package to be sent or delivered by a private or commercial
interstate carrier, to wit: United Parcel Service (UPS), from G & K Pharma, Miami, Florida, to
Pormis Wholesale & Distribution, Laredo, Texas, contrary to 18 U.S.C.§1341.
Predicate 12 Mail Fraud
On or about February 14, 2003, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
14
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so,
cause to be delivered by private or commercial interstate carrier, to wit: United Parcel Service
(UPS), according to the direction thereon a certain package from Albers Medical, Kansas City,
Missouri, to Medcom Pharmaceutical Wholesale Drugs, Jensen Beach, Florida, contrary to 18 U.S.C.
§1341.
Predicate 13Mail Fraud
On or about October 29, 2002, in Miami-Dade County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, for the purpose of executing such scheme or attempting to do so, did cause
to be delivered by private or commercial interstate carrier to wit: Federal Express according to the
15
direction thereon a certain letter from David Ebanks, a/k/a Julius Taylor, in Miami, Florida, to
Chavey Real Estate, Corpus Christi, Texas, contrary to 18 U.S.C.§1341.
Predicate 14Wire Fraud
On or about February 5, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a facsimile transmission (fax) from Lori Marvel
in Wanatah, Indiana, to Michael Carlow in Weston, Florida, contrary to 18 U.S.C. §1343.
16
Predicate 15Wire Fraud
On or about June 27, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia, having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$1,482,102.62 from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
17
Predicate 16Wire Fraud
On or about July 3, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia, having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$750,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens
National Bank in Seiverville, Tennessee, to account number 30333145805 in the name of GD
Medical at Ocean Bank in Miami, Florida, contrary to 18 U.S.C. §1343.
18
Predicate 17Wire Fraud
On or about July 3, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia, having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$510,500.43 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens
National Bank in Seiverville, Tennessee, to account number 3200052822 in the name of Medical
Dynamics at Citibank in Miami, Florida, contrary to 18 U.S.C. §1343.
19
Predicate 18Wire Fraud
On or about July 10, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia, having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$1,000,000.00 from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
20
Predicate 19Wire Fraud
On or about July 17, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$677,600.00 from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
21
Predicate 20Wire Fraud
On or about July 31, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate or foreign
commerce, writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount
of $900,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens
National Bank in Seiverville, Tennessee, to account number 7061-0 in the name of Serra Morena
Import Export at Banco do Brazil in Brazil, South America, contrary to 18 U.S.C. §1343.
22
Predicate 21Wire Fraud
On or about September 9, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia, having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$900,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens
National Bank in Seiverville, Tennessee, to account number 9660148926 in the name of Lighthouse
Capital Inv at Union Planters Bank in Coral Gables, Florida, contrary to 18 U.S.C. §1343.
23
Predicate 22Wire Fraud
On or about September 10, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$41,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens National
Bank in Seiverville, Tennessee, to account number 3892010831 in the name of Tina Investments at
Washington Mutual Bank in Miami, Florida, contrary to 18 U.S.C. §1343.
24
Predicate 23Wire Fraud
On or about November 18, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$1,398,079.65 from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
25
Predicate 24Wire Fraud
On or about November 26, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$900,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens
National Bank in Seiverville, Tennessee, to account number 9660148926 in the name of Lighthouse
Capital Inv at Union Planters in Coral Gables, Florida, contrary to 18 U.S.C. §1343.
26
Predicate 25Wire Fraud
On or about November 27, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$1,382,321.15 from account 003937132789 in the name of G&K Pharma, LLC, at the Bank of
America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc. at
Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
27
Predicate 26Wire Fraud
On or about December 9, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$1,248,606.00 from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
28
Predicate 27Wire Fraud
On or about December 11, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$1,368,835.00 from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
29
Predicate 28Wire Fraud
On or about December 12, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$900,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens
National Bank in Seiverville, Tennessee, to account number 9660148926 in the name of Lighthouse
Capital Inv at Union Planters Bank in Coral Gables, Florida, contrary to 18 U.S.C. §1343.
30
Predicate 29Wire Fraud
On or about December 16, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate or foreign
commerce, writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount
of $511,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens
National Bank in Seiverville, Tennessee, to account number 2000192288149 in the name of
Proteknika do Brazil at Banco Bilbao Vizcaya, in Argentina, South America, contrary to 18 U.S.C.
§1343.
31
Predicate 30Wire Fraud
On or about December 23, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$2,117,757.00 from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
32
Predicate 31Wire Fraud
On or about December 30, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$896,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens
National Bank in Seiverville, Tennessee, to account number 9660148926 in the name of Lighthouse
Capital Inv at Union Planters Bank in Coral Gables, Florida, contrary to 18 U.S.C. §1343.
33
Predicate 32Wire Fraud
On or about January 9, 2003, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$2,038,452.00, from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.,
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
34
Predicate 33Wire Fraud
On or about February 4, 2003, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$1,293,542.00, from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.,
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
35
Predicate 34Wire Fraud
On or about January 10, 2003, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate or foreign
commerce, writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount
of $900,000.00, from account number 00-93207 in the name of Pharma Medical, Inc., at Citizens
National Bank in Seiverville, Tennessee, to account number 2000192001258 in the name of
Comercializadora E & I at Multicredit Bank Panama, in Panama, Central America, contrary to 18
U.S.C. §1343.
36
Predicate 35Sale or Delivery of a Controlled Substance
Beginning on or about January 20, 2002, in Broward County, Florida, MICHAEL
CARLOW, did knowingly and unlawfully sell or deliver, or possess with intent to sell or deliver,
a controlled substance, to wit: Dronabinol (synthetic THC), in violation of sections 893.13(1)(a)(2)
and 893.03(3)(f), Florida Statutes.
Predicate 36Possession with Intent to Sell or Deliver a Controlled Substance
Beginning on or about February 15, 2002, in the Seventeenth Judicial Circuit, to wit:
Broward County, Florida, MICHAEL CARLOW, did knowingly and unlawfully possess, with
intent to sell or deliver, a controlled substance, to wit: Phentermine Hydrochloride, in violation of
sections 893.13(1)(a)(2) and 893.03(3)(f), Florida Statutes.
All in violation of section 895.03(3), Florida Statutes.
COUNT 2Conspiracy to Commit Racketeering
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that beginning on or about April 5, 2001, and continuing through and including July 1, 2003,
37
in the Ninth, Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial Circuits of Florida, to wit:
Orange, Miami-Dade, Palm Beach, Broward and Martin Counties, Florida, as part of a related
transaction, the Defendants, MICHAEL CARLOW, CANDACE CARLOW, THOMAS
ATKINS, JR., MARILYN ATKINS, HENRY GARCIA, FABIAN DIAZ, JOEL DE LA OSA,
DAVID EBANKS, JOSE L. BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN,
LAZARO VILARCHAO, IVAN VILARCHAO, JOSEPH VILLANUEVA, ARTURO
GODIÑEZ, TOM MARTINO, and JULIO CESAR CRUZ, a/k/a Ricardo Garcia, did
unlawfully and knowingly combine, conspire, confederate and agree each with the other and others
known and unknown to violate the laws of Florida, to-wit: section 895.03(3), Florida Statutes,
prohibiting racketeering, thereby committing crimes chargeable by indictment or information under
Chapter 812, Florida Statutes, and Title 18, United States Code, Sections 1341 and 1343, by
engaging in two or more predicate incidents which would have similar intents, results, accomplices,
victims or methods of commission, or would otherwise be related by distinguishing characteristics
and would not be isolated incidents, or by otherwise participating in the affairs of the enterprise with
the knowledge and intent that other members of the conspiracy would engage in at least two
incidents of racketeering activity. As part of said conspiracy, the above-named defendants were
employed by, or associated with, an enterprise consisting of BTC Wholesale, Inc., a Florida
corporation; G&K Pharma, LLC., a Maryland corporation; Complete Wholesale, Inc., a Maryland
corporation; Accucare, LLC, a Florida corporation; JB Pharmaceuticals, Inc., a Texas corporation;
and Pormis Wholesale Distributors, Inc., a Texas corporation; acting together with a group of
individuals, associated in fact, although not a legal entity, to wit: Michael Carlow, Candace Carlow,
Thomas Atkins, Jr., Marilyn Atkins, Henry Garcia, Fabian Diaz, Joel De La Osa, David Ebanks, Jose
38
L. Benitez, Dariel Tabares, Michael E. Burman, Lazaro Vilarchao, Ivan Vilarchao, Joseph
Villanueva, Pamela Walter, Mark Novosel, Arturo Godiñez, Mark Siegel, and Tom Martino, and
one or more members of the conspiracy did engage or intend to engage in at least two of the
following incidents:
Predicate 1A:Grand Theft
Beginning on or about January 16, 2002, and continuing through, and including, January 20,
2002, in Miami-Dade and Broward Counties, Florida, MICHAEL CARLOW and FABIAN DIAZ
did knowingly and unlawfully obtain or use, or endeavored to obtain or use, legend drugs as defined
in section 499.003(19), Florida Statutes, said property being the property of another, to wit: Bio-Med
Plus, Inc., a Florida corporation, of a value of $100,000 or more, with the intent to either temporarily
or permanently appropriate the property to their own use or to the use of another person not entitled
thereto, contrary to section 812.014(1),(b),(2)(a)1, Florida Statutes.
Predicate 1BDealing in Stolen Property
On or about January 20, 2002, in Miami-Dade and Broward Counties, Florida, MICHAEL
CARLOW and FABIAN DIAZ did knowingly and unlawfully traffic in or endeavor to traffic in
property to wit: legend drugs, as defined in section 499.003(19), Florida Statutes, that they knew or
should have known were stolen, contrary to section 812.019(1), Florida Statutes.
39
Predicate 2Mail Fraud
On or about August 31, 2001, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so, cause
to be delivered by mail, according to the direction thereon, a certain letter from the Florida
Department of Health, Tallahassee, Florida, to Optia Medical, Las Vegas, Nevada, contrary to 18
U.S.C. §1341.
40
Predicate 3Mail Fraud
On or about January 3, 2002, in Miami-Dade County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs, when in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so, cause
to be delivered by mail, according to the direction thereon, a certain letter from Lane C. Reedman,
El Paso, Texas, to Fabian Diaz, c/o Oasis Management, Miami, Florida, contrary to 18 U.S.C.§1341.
Predicate 4Mail Fraud
On or about June 21, 2002, in Miami-Dade County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
41
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were at different times either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so, cause
to be delivered by mail, according to the direction thereon, a certain letter from David Ebanks, a/k/a
Julius Taylor, Miami, Florida, to Lori Barrera, Corpus Christi, Texas, contrary to 18 U.S.C. §1341.
Predicate 5Mail Fraud
On April 5, 2001, in Broward County, Florida, MICHAEL CARLOW, CANDACE
CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA, FABIAN
DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L. BENITEZ,
DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ having devised a scheme to defraud prescription drug consumers residing
inside and outside the state of Florida by selling into the wholesale prescription drug market what
42
was purported to be pure, genuine and unadulterated prescription drugs when, in fact, the said
prescription drugs were, at different times, either counterfeit, relabeled, stolen, illegally purchased
from Medicaid recipients, illegally purchased from unlicensed persons, illegally imported into the
United States, stored in unlicensed facilities, or sold with false, fraudulent or forged documentation,
did, for the purpose of executing such scheme or attempting to do so, deposit or cause to be
deposited, a package to be sent or delivered by a private or commercial interstate carrier, to wit:
Federal Express, from AmeRx, Inc., Oakland Park, Florida, to Albers Medical, Inc., Kansas City,
Missouri, contrary to 18 U.S.C. §1341.
Predicate 6Mail Fraud
On September 11, 2002, in Palm Beach County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
43
or forged documentation, did, for the purpose of executing such scheme or attempting to do so,
deposit or cause to be deposited, a package to be sent or delivered by a private or commercial
interstate carrier, to wit: United Parcel Service (UPS), from Accucare, Boynton Beach, Florida, to
Albers Medical, Kansas City, Missouri, contrary to 18 U.S.C.§1341.
Predicate 7Mail Fraud
On October 22, 2002, in Palm Beach County, Florida, MICHAEL CARLOW, CANDACE
CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA, FABIAN
DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L. BENITEZ,
DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs, were at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so,
deposit or cause to be deposited, a package to be sent or delivered by a private or commercial
interstate carrier to wit: United Parcel Service (UPS), from Four Points Wholesale, Boynton Beach,
Florida, to Albers Medical, Kansas City, Missouri, contrary to 18 U.S.C.§1341.
44
Predicate 8Mail Fraud
On November 11, 2002, in Palm Beach County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so,
deposit or cause to be deposited, a package to be sent or delivered by a private or commercial
interstate carrier, to wit: United Parcel Service (UPS), from Four Points Wholesale, Boynton Beach,
Florida, to Albers Medical, Kansas City, Missouri, contrary to 18 U.S.C. §1341.
Predicate 9Mail Fraud
On December 18, 2002, in Palm Beach County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
45
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so,
deposit or cause to be deposited, a package to be sent or delivered by a private or commercial
interstate carrier, to wit: United Parcel Service (UPS), from G & K Pharma, Boynton Beach, Florida,
to Albers Medical, Kansas City, Missouri, contrary to 18 U.S.C. §1341.
Predicate 10Mail Fraud
On March 27, 2003, in Miami-Dade County, Florida, MICHAEL CARLOW, CANDACE
CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA, FABIAN
DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L. BENITEZ,
DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
46
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so,
deposit or cause to be deposited, a package to be sent or delivered by a private or commercial
interstate carrier, to wit: United Parcel Service (UPS), from David Ebanks, a/k/a Julius Taylor,
Miami, Florida, to Albers Medical, Inc., Kansas City, Missouri, contrary to 18 U.S.C.§1341.
Predicate 11Mail Fraud
On May 19, 2003, in Broward County, Florida, MICHAEL CARLOW, CANDACE
CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA, FABIAN
DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L. BENITEZ,
DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
47
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so,
deposit or cause to be deposited, a package to be sent or delivered by a private or commercial
interstate carrier, to wit: United Parcel Service (UPS), from G & K Pharma, Miami, Florida, to
Pormis Wholesale & Distribution, Laredo, Texas, contrary to 18 U.S.C.§1341.
Predicate 12 Mail Fraud
On or about February 14, 2003, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, did, for the purpose of executing such scheme or attempting to do so,
cause to be delivered by private or commercial interstate carrier, to wit: United Parcel Service
(UPS), according to the direction thereon a certain package from Albers Medical, Kansas City,
48
Missouri, to Medcom Pharmaceutical Wholesale Drugs, Jensen Beach, Florida, contrary to 18 U.S.C.
§1341.
Predicate 13Mail Fraud
On or about October 29, 2002, in Miami-Dade County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be pure, genuine and unadulterated prescription
drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,
stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,
illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent
or forged documentation, for the purpose of executing such scheme or attempting to do so, did cause
to be delivered by private or commercial interstate carrier to wit: Federal Express according to the
direction thereon a certain letter from David Ebanks, a/k/a Julius Taylor, in Miami, Florida, to
Chavey Real Estate, Corpus Christi, Texas, contrary to 18 U.S.C.§1341.
49
Predicate 14Wire Fraud
On or about February 5, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a facsimile transmission (fax) from Lori Marvel
in Wanatah, Indiana, to Michael Carlow in Weston, Florida, contrary to 18 U.S.C. §1343.
50
Predicate 15Wire Fraud
On or about June 27, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia, having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$1,482,102.62 from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
51
Predicate 16Wire Fraud
On or about July 3, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia, having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$750,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens
National Bank in Seiverville, Tennessee, to account number 30333145805 in the name of GD
Medical at Ocean Bank in Miami, Florida, contrary to 18 U.S.C. §1343.
52
Predicate 17Wire Fraud
On or about July 3, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia, having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$510,500.43 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens
National Bank in Seiverville, Tennessee, to account number 3200052822 in the name of Medical
Dynamics at Citibank in Miami, Florida, contrary to 18 U.S.C. §1343.
53
Predicate 18Wire Fraud
On or about July 10, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia, having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$1,000,000.00 from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
54
Predicate 19Wire Fraud
On or about July 17, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$677,600.00 from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
55
Predicate 20Wire Fraud
On or about July 31, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate or foreign
commerce, writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount
of $900,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens
National Bank in Seiverville, Tennessee, to account number 7061-0 in the name of Serra Morena
Import Export at Banco do Brazil in Brazil, South America, contrary to 18 U.S.C. §1343.
56
Predicate 21Wire Fraud
On or about September 9, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia, having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$900,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens
National Bank in Seiverville, Tennessee, to account number 9660148926 in the name of Lighthouse
Capital Inv at Union Planters Bank in Coral Gables, Florida, contrary to 18 U.S.C. §1343.
57
Predicate 22Wire Fraud
On or about September 10, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$41,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens National
Bank in Seiverville, Tennessee, to account number 3892010831 in the name of Tina Investments at
Washington Mutual Bank in Miami, Florida, contrary to 18 U.S.C. §1343.
58
Predicate 23Wire Fraud
On or about November 18, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$1,398,079.65 from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
59
Predicate 24Wire Fraud
On or about November 26, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$900,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens
National Bank in Seiverville, Tennessee, to account number 9660148926 in the name of Lighthouse
Capital Inv at Union Planters in Coral Gables, Florida, contrary to 18 U.S.C. §1343.
60
Predicate 25Wire Fraud
On or about November 27, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$1,382,321.15 from account 003937132789 in the name of G&K Pharma, LLC, at the Bank of
America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc. at
Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
61
Predicate 26Wire Fraud
On or about December 9, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$1,248,606.00 from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
62
Predicate 27Wire Fraud
On or about December 11, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$1,368,835.00 from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
63
Predicate 28Wire Fraud
On or about December 12, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$900,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens
National Bank in Seiverville, Tennessee, to account number 9660148926 in the name of Lighthouse
Capital Inv at Union Planters Bank in Coral Gables, Florida, contrary to 18 U.S.C. §1343.
64
Predicate 29Wire Fraud
On or about December 16, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate or foreign
commerce, writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount
of $511,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens
National Bank in Seiverville, Tennessee, to account number 2000192288149 in the name of
Proteknika do Brazil at Banco Bilbao Vizcaya, in Argentina, South America, contrary to 18 U.S.C.
§1343.
65
Predicate 30Wire Fraud
On or about December 23, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$2,117,757.00 from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
66
Predicate 31Wire Fraud
On or about December 30, 2002, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$896,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens
National Bank in Seiverville, Tennessee, to account number 9660148926 in the name of Lighthouse
Capital Inv at Union Planters Bank in Coral Gables, Florida, contrary to 18 U.S.C. §1343.
67
Predicate 32Wire Fraud
On or about January 9, 2003, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$2,038,452.00, from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.,
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
68
Predicate 33Wire Fraud
On or about February 4, 2003, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,
writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of
$1,293,542.00, from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank
of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.,
at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.
69
Predicate 34Wire Fraud
On or about January 10, 2003, in Broward County, Florida, MICHAEL CARLOW,
CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,
FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.
BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and
JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription
drug consumers residing inside and outside the state of Florida by selling into the wholesale
prescription drug market what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold
with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or
attempting to do so, transmit or caused to be transmitted by means of wire in interstate or foreign
commerce, writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount
of $900,000.00, from account number 00-93207 in the name of Pharma Medical, Inc., at Citizens
National Bank in Seiverville, Tennessee, to account number 2000192001258 in the name of
Comercializadora E & I at Multicredit Bank Panama, in Panama, Central America, contrary to 18
U.S.C. §1343.
70
Predicate 35Sale or Delivery of a Controlled Substance
Beginning on or about January 20, 2002, in Broward County, Florida, MICHAEL
CARLOW, did knowingly and unlawfully sell or deliver, or possess with intent to sell or deliver,
a controlled substance, to wit: Dronabinol (synthetic THC), in violation of sections 893.13(1)(a)(2)
and 893.03(3)(f), Florida Statutes.
Predicate 36Possession with Intent to Sell or Deliver a Controlled Substance
Beginning on or about February 15, 2002, in the Seventeenth Judicial Circuit, to wit:
Broward County, Florida, MICHAEL CARLOW, did knowingly and unlawfully possess, with
intent to sell or deliver, a controlled substance, to wit: Phentermine Hydrochloride, in violation of
sections 893.13(1)(a)(2) and 893.03(3)(f), Florida Statutes.
All in violation of section 895.03(4), Florida Statutes.
COUNT 3Organized Scheme to Defraud
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that beginning on or about April 5, 2001, and continuing through July 1, 2003, in the Ninth,
71
Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade,
Palm Beach, Broward and Martin Counties, Florida, as part of a related transaction occurring in, or
in connection with, an organized criminal conspiracy affecting two or more judicial circuits of
Florida, the Defendants, MICHAEL CARLOW, CANDACE CARLOW, THOMAS ATKINS,
JR., MARILYN ATKINS, HENRY GARCIA, FABIAN DIAZ, JOEL DE LA OSA, DAVID
EBANKS, JOSE L. BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO
VILARCHAO, IVAN VILARCHAO, JOSEPH VILLANUEVA, JULIO CESAR CRUZ, a/k/a
Ricardo Garcia, GISELA GONZALEZ, ARTURO GODIÑEZ, and TOM MARTINO did
knowingly engage in a scheme to defraud prescription drug users residing inside and outside the
State of Florida, through a systematic and ongoing course of conduct, by selling into the prescription
drug wholesale market, what was purported to be genuine, unadulterated and legitimately acquired
prescription drugs when, in fact, the said prescription drugs were, at different times, either
counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from
unlicensed persons, illegally imported into the United States, stored in unlicensed facilities or sold
with false, fraudulent or forged documentation. It was the intent and purpose of the various members
of the scheme to hide or disguise their true source of the prescription drugs they sold by engaging
in sham transactions, providing false documentation of the sales history of the prescription drugs and
placing straw men on the corporate papers of drug wholesale companies inside and outside the State
of Florida, and as a result of this scheme to defraud, the defendants did thereby obtain property with
an aggregate value of $50,000 or more, contrary to section 817.034(4)(a)1, Florida Statutes.
72
COUNT 4Grand Theft
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that beginning on or about January 16, 2002, and continuing through and including January
20, 2002, in the Eleventh and Seventeenth Judicial Circuits of Florida, to-wit: Miami-Dade and
Broward Counties, Florida, as part of a related transaction occurring in, or in connection with, an
organized criminal conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth,
Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade,
Palm Beach, Broward and Martin Counties, Florida, MICHAEL CARLOW and FABIAN DIAZ,
did knowingly and unlawfully obtain or use, or endeavored to obtain or use, legend drugs as defined
in section 499.003(19), Florida Statutes, said property being the property of another, to wit: Bio-Med
Plus, Inc., a Florida corporation, of a value of $100,000 or more, with the intent to either temporarily
or permanently appropriate the property to their own use or to the use of another person not entitled
thereto, contrary to section 812.014(1),(b),(2)(a)1, Florida Statutes.
COUNT 5Dealing in Stolen Property
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that beginning on or about January 20, 2002, in the Eleventh and Seventeenth Judicial
Circuits of Florida, to-wit: Miami-Dade and Broward Counties, Florida, as part of a related
73
transaction occurring in, or in connection with, an organized criminal conspiracy affecting two or
more judicial circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and Nineteenth
Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward and Martin Counties, Florida,
MICHAEL CARLOW and FABIAN DIAZ, did knowingly and unlawfully traffic in property, to
wit: legend drugs as defined in section 499.003(19), Florida Statutes that they knew, or should have
known, were stolen, contrary to section 812.019(1), Florida Statutes.
COUNT 6Sale or Delivery of a Controlled Substance
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that beginning on or about January 20, 2002, in the Seventeenth Judicial Circuit, to wit:
Broward County, Florida, the Defendant, as part of a related transaction occurring in, or in
connection with, an organized criminal conspiracy affecting two or more judicial circuits of Florida,
to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange,
Miami-Dade, Palm Beach, Broward and Martin Counties, Florida, MICHAEL CARLOW, did
knowingly and unlawfully sell or deliver, or possess with intent to sell or deliver a controlled
substance, to wit: Dronabinol (synthetic THC), in violation of sections 893.13(1)(a)(2) and
893.03(3)(f), Florida Statutes.
74
COUNT 7Possession with Intent to Sell Legend Drugs
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about April 5, 2001, in the Seventeenth Judicial Circuit, to wit: Broward County,
Florida, in connection with an organized criminal conspiracy affecting two or more judicial circuits,
to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange,
Miami-Dade, Palm Beach, Broward and Martin Counties, Florida, the Defendant, MICHAEL
CARLOW, did knowingly and unlawfully possess with intent to sell, dispense or deliver a legend
drug as defined in section 499.003(19), Florida Statutes, to wit: Gamimune (immune globulin
intravenous), contrary to section 499.03(1), Florida Statutes.
COUNT 8Possession with Intent to Sell Legend Drugs
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about January 16, 2002, and continuing through and including January 20, 2002
in the Ninth, Eleventh, Fifteenth and Seventeenth Judicial Circuits, to wit: Orange, Miami-Dade,
Palm Beach and Broward Counties, Florida, as part of a related transaction occurring in, or in
connection with, an organized criminal conspiracy affecting two or more judicial circuits of Florida,
to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange,
Miami-Dade, Palm Beach, Broward and Martin Counties, Florida, MICHAEL CARLOW, did
75
knowingly and unlawfully possess with intent to sell, dispense or deliver a legend drug as defined
in section 499.003(19), Florida Statutes, to wit: Novoseven (coagulation factor VIIa), Hyprho-D
(immune globulin intravenous), Immune Globulin, Gamimune (immune globulin intravenous),
Gammagard (immune globulin intravenous), Iveegam (immune globulin intravenous-human),
contrary to section 499.03(1), Florida Statutes.
COUNT 9Possession with Intent to Sell Legend Drugs
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about February 15, 2002, in the Ninth, Eleventh, Fifteenth and Seventeenth Judicial
Circuits, to wit: Orange, Miami-Dade, Palm Beach and Broward Counties, Florida, as part of a
related transaction occurring in, or in connection with, an organized criminal conspiracy affecting
two or more judicial circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and
Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward and Martin
Counties, Florida, MICHAEL CARLOW, did knowingly and unlawfully possess with intent to sell,
dispense or deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit:
Doxyclycline, contrary to section 499.03(1), Florida Statutes.
76
COUNT 10Possession with Intent to Sell Legend Drugs
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about February 15, 2002, in the Ninth, Eleventh, Fifteenth and Seventeenth Judicial
Circuits, to wit: Orange, Miami-Dade, Palm Beach and Broward Counties, Florida, as part of a
related transaction occurring in, or in connection with, an organized criminal conspiracy affecting
two or more judicial circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and
Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward and Martin
Counties, Florida, MICHAEL CARLOW, did knowingly and unlawfully possess with intent to sell,
dispense or deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit: Lactated
Ringer’s Injection Solution, contrary to section 499.03(1), Florida Statutes.
COUNT 11Possession with Intent to Sell Legend Drugs
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about February 15, 2002, in the Ninth, Eleventh, Fifteenth and Seventeenth Judicial
Circuits, to wit: Orange, Miami-Dade, Palm Beach and Broward Counties, Florida, as part of a
related transaction occurring in, or in connection with, an organized criminal conspiracy affecting
two or more judicial circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and
77
Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward and Martin
Counties, Florida, MICHAEL CARLOW, did knowingly and unlawfully possess with intent to sell,
dispense or deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit:
Novocain (xylocaine hydrochloride), contrary to section 499.03(1), Florida Statutes.
COUNT12Possession with Intent to Sell Legend Drugs
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about February 15, 2002, in the Ninth, Eleventh, Fifteenth and Seventeenth Judicial
Circuits, to wit: Orange, Miami-Dade, Palm Beach and Broward Counties, Florida, as part of a
related transaction occurring in, or in connection with, an organized criminal conspiracy affecting
two or more judicial circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and
Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward and Martin
Counties, Florida, MICHAEL CARLOW, did knowingly and unlawfully possess with intent to sell,
dispense or deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit:
Phentermine Hydrochloride, contrary to section 499.03(1), Florida Statutes.
78
COUNT 13Sale or Delivery of a Controlled Substance
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that beginning on or about February 15, 2002, in the Seventeenth Judicial Circuit, to wit:
Broward County, Florida, as part of a related transaction occurring in, or in connection with, an
organized criminal conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth,
Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade,
Palm Beach, Broward and Martin Counties, Florida, the Defendant, MICHAEL CARLOW, did
knowingly and unlawfully sell or deliver, or possess with intent to sell or deliver a controlled
substance, to wit: Phentermine Hydrochloride in violation of sections 893.13(1)(a)(2) and
893.03(3)(f), Florida Statutes.
COUNT 14Possession with Intent to Sell Legend Drugs
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about October 1, 2002 in the Fifteenth and Seventeenth Judicial Circuits, to wit:
Palm Beach and Broward Counties, Florida, as part of a related transaction occurring in, or in
connection with, an organized criminal conspiracy affecting two or more judicial circuits of Florida,
to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange,
Miami-Dade, Palm Beach, Broward and Martin Counties, Florida, the Defendants, HENRY
79
GARCIA, JOEL DE LA OSA, MICHAEL CARLOW, THOMAS ATKINS, JR., did knowingly
and unlawfully possess with intent to sell, dispense or deliver a legend drug as defined in section
499.003(19), Florida Statutes, to wit: Procrit (epoetin alfa), 40,000 units per ML, contrary to section
499.03(1), Florida Statutes.
COUNT 15Possession with Intent to Sell Legend Drugs
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about January 27, 2003, through and including February 6, 2003, in the
Seventeenth Judicial Circuit, to wit: Broward County, Florida, as part of a related transaction
occurring in, or in connection with, an organized criminal conspiracy affecting two or more judicial
circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial
Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward and Martin Counties, Florida, the
Defendant, MICHAEL CARLOW, did knowingly and unlawfully possess with intent to sell,
dispense or deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit: Zyprexa
(olanzapine), contrary to section 499.03(1), Florida Statutes.
80
COUNT 16Purchase or Receipt of a Legend Drug
from Unauthorized Person
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about February 6, 2002, in the Ninth, Eleventh, Fifteenth and Seventeenth Judicial
Circuits, to wit: Osceola, Miami-Dade, Palm Beach and Broward Counties, Florida, as part of a
related transaction occurring in, or in connection with, an organized criminal conspiracy affecting
two or more judicial circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and
Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward and Martin
Counties, Florida, the Defendant, MICHAEL CARLOW, did knowingly and unlawfully purchase
or receive a legend drug, to wit: Viracept (nelfinavir), Crixivan (indinavir sulfate), Combivir
(lamivudine/zidovudine), Trizivir (abacavir sulfate/lamivudine/zidovudine) , Diflucan (fluconazole),
Sustiva (efavirenz), Retrovir (zidovudine), Viramune (nevirapine), Viread (tenofovir disoproxil
fumarate), Epivir (lamivudine), Videx (didanosine), Ziagen (abacavir), from a person, to wit: Jose
L. Benitez, not authorized under Chapter 499, Florida Statutes, to distribute legend drugs, contrary
to section 499.005(14), Florida Statutes.
81
COUNT 17Purchase or Receipt of a Legend Drug
from Unauthorized Person
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about February 13, 2002, in the Ninth, Eleventh, Fifteenth and Seventeenth Judicial
Circuits, to wit: Osceola, Miami-Dade, Palm Beach and Broward Counties, Florida, as part of a
related transaction occurring in, or in connection with, an organized criminal conspiracy affecting
two or more judicial circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and
Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward and Martin
Counties, Florida, the Defendant, MICHAEL CARLOW, did knowingly and unlawfully purchase
or receive a legend drug, to wit: Viracept (nelfinavir), Crixivan (indinavir sulfate), Combivir
(lamivudine/zidovudine), Trizivir (abacavir sulfate/lamivudine/zidovudine) , Diflucan (fluconazole),
Sustiva (efavirenz), Viramune (nevirapine), Epivir (lamivudine), Videx (didanosine), Ziagen
(abacavir) from a person, to wit: Jose L. Benitez, not authorized under Chapter 499, Florida Statutes,
to distribute legend drugs, contrary to section 499.005(14), Florida Statutes.
COUNT 18Possession with Intent to Sell Legend Drugs
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that between or about January 24, 2003 and February 24, 2003, in the Seventeenth Judicial
82
Circuit, to wit: Broward County, Florida, as part of a related transaction occurring in, or in
connection with, an organized criminal conspiracy affecting two or more judicial circuits of Florida,
to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange,
Miami-Dade, Palm Beach, Broward and Martin Counties, Florida, the Defendant, DAVID
EBANKS, a/k/a Julius Taylor, did knowingly and unlawfully possess with intent to sell, dispense
or deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit: Diflucan
(fluconazole) contrary to section 499.03(1), Florida Statutes.
COUNT 19Possession with Intent to Sell Legend Drugs
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about April 11, 2003, in the Seventeenth and Nineteenth Judicial Circuits, to wit:
Broward and Martin Counties, Florida, as part of a related transaction occurring in, or in connection
wit, an organized criminal conspiracy affecting two or more judicial circuits of Florida, to wit: the
Ninth, Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-
Dade, Palm Beach, Broward and Martin Counties, Florida, the Defendant, MICHAEL CARLOW,
did knowingly and unlawfully possess with intent to sell, dispense or deliver a legend drug as defined
in section 499.003(19), Florida Statutes, to wit: Celebrex (celecoxib) and Lipitor (atorvastatin)
contrary to section 499.03(1), Florida Statutes.
83
COUNT 20Possession with Intent to Sell Legend Drugs
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about May 20, 2003, in the Eleventh and Seventeenth Judicial Circuits, to wit:
Miami-Dade and Broward Counties, Florida, as part of a related transaction occurring in, or in
connection with, an organized criminal conspiracy affecting two or more judicial circuits of Florida,
to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange,
Miami-Dade, Palm Beach, Broward and Martin Counties, Florida, the Defendants, DARIEL
TABARES and MICHAEL CARLOW, did knowingly and unlawfully possess with intent to sell,
dispense or deliver a legend drug as defined in section 499.003(19), Florida Statutes, contrary to
section 499.03(1), Florida Statutes.
COUNT 21Possession with Intent to Sell Legend Drugs
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about January 24, 2002, in the Seventeenth Judicial Circuit, to wit: Broward
County, Florida, as part of a related transaction occurring in, or in connection with, an organized
criminal conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth, Eleventh,
Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach,
Broward and Martin Counties, Florida, the Defendants, LAZARO VILARCHAO, IVAN
84
VILARCHAO, JOSEPH VILLANUEVA, did knowingly and unlawfully possess with intent to
sell, dispense or deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit:
Epogen (epoetin alfa) contrary to section 499.03(1), Florida Statutes.
COUNT 22Possession with Intent to Sell Legend Drugs
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about February 28, 2002, in the Seventeenth Judicial Circuit, to wit: Broward
County, Florida,as part of a related transaction occurring in, or in connection with, an organized
criminal conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth, Eleventh,
Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach,
Broward and Martin Counties, Florida, the Defendants, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, did knowingly and unlawfully possess with intent to
sell, dispense or deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit:
Procrit (epoetin alfa) contrary to section 499.03(1), Florida Statutes.
COUNT 23Possession with Intent to Sell Legend Drugs
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about March 5, 2002, in the Seventeenth Judicial Circuit, to wit: Broward County,
85
Florida, as part of a related transaction occurring in, or in connection with, an organized criminal
conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth,
Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward
and Martin Counties, Florida, the Defendants, LAZARO VILARCHAO, IVAN VILARCHAO,
JOSEPH VILLANUEVA, did knowingly and unlawfully possess with intent to sell, dispense or
deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit: Epogen (epoetin
alfa) contrary to section 499.03(1), Florida Statutes.
COUNT 24Possession with Intent to Sell Legend Drugs
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about March 11, 2002, in the Seventeenth Judicial Circuit, to wit: Broward
County, Florida, as part of a related transaction occurring in, or in connection with, an organized
criminal conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth, Eleventh,
Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach,
Broward and Martin Counties, Florida, the Defendants, LAZARO VILARCHAO, IVAN
VILARCHAO, JOSEPH VILLANUEVA, did knowingly and unlawfully possess with intent to
sell, dispense or deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit:
Epogen (epoetin alfa) contrary to section 499.03(1), Florida Statutes.
86
COUNT 25Possession with Intent to Sell Legend Drugs
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about March 18,2002, in the Seventeenth Judicial Circuit, to wit: Broward County,
Florida, as part of a related transaction occurring in, or in connection with, an organized criminal
conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth,
Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward
and Martin Counties, Florida, the Defendants, LAZARO VILARCHAO, IVAN VILARCHAO,
JOSEPH VILLANUEVA, did knowingly and unlawfully possess with intent to sell, dispense or
deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit: Procrit (epoetin alfa)
contrary to section 499.03(1), Florida Statutes.
COUNT 26Possession with Intent to Sell Legend Drugs
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about March 20, 2002, in the Seventeenth Judicial Circuit, to wit: Broward
County, Florida, as part of a related transaction occurring in, or in connection with, an organized
criminal conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth, Eleventh,
Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach,
Broward and Martin Counties, Florida, the Defendants, LAZARO VILARCHAO, IVAN
87
VILARCHAO, JOSEPH VILLANUEVA, did knowingly and unlawfully possess with intent to
sell, dispense or deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit:
Panglobulin (immune globulin intravenous) contrary to section 499.03(1), Florida Statutes.
COUNT 27Purchase or Receipt of a Legend Drug
from Unauthorized Person
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about January 24, 2002, in the Seventeenth Judicial Circuit, to wit: Broward
County, Florida, as part of a related transaction occurring in, or in connection with, an organized
criminal conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth, Eleventh,
Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach,
Broward and Martin Counties, Florida, the Defendant, TOM MARTINO, did knowingly and
unlawfully purchase or receive a legend drug, to wit: Epogen (epoetin alfa) from a person, to wit:
Mark Novosel, not authorized under Chapter 499, Florida Statutes, to distribute legend drugs,
contrary to section 499.005(14), Florida Statutes.
88
COUNT 28Purchase or Receipt of a Legend Drug
from Unauthorized Person
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about February 28, 2002, in the Seventeenth Judicial Circuit, to wit: Broward
County, Florida, as part of a related transaction occurring in, or in connection with, an organized
criminal conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth, Eleventh,
Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach,
Broward and Martin Counties, Florida, the Defendant, TOM MARTINO, did knowingly and
unlawfully purchase or receive a legend drug, to wit: Procrit (epoetin alfa) from a person, to wit:
Mark Novosel, not authorized under Chapter 499, Florida Statutes, to distribute legend drugs,
contrary to section 499.005(14), Florida Statutes.
COUNT 29Purchase or Receipt of a Legend Drug
from Unauthorized Person
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about March 5, 2002, in the Seventeenth Judicial Circuit, to wit: Broward County,
Florida, as part of a related transaction occurring in, or in connection with, an organized criminal
conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth,
Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward
89
and Martin Counties, Florida, the Defendant, TOM MARTINO, did knowingly and unlawfully
purchase or receive a legend drug, to wit: Epogen (epoetin alfa) from a person, to wit: Mark Novosel,
not authorized under Chapter 499, Florida Statutes, to distribute legend drugs, contrary to section
499.005(14), Florida Statutes.
COUNT 30Purchase or Receipt of a Legend Drug
from Unauthorized Person
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about March 11, 2002, in the Seventeenth Judicial Circuit, to wit: Broward County,
Florida, as part of a related transaction occurring in, or in connection with, an organized criminal
conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth,
Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward
and Martin Counties, Florida, the Defendant, TOM MARTINO, did knowingly and unlawfully
purchase or receive a legend drug, to wit: Epogen (epoetin alfa) from a person, to wit: Mark Novosel,
not authorized under Chapter 499, Florida Statutes, to distribute legend drugs, contrary to section
499.005(14), Florida Statutes.
90
COUNT 31Purchase or Receipt of a Legend Drug
from Unauthorized Person
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about March 18, 2002, in the Seventeenth Judicial Circuit, to wit: Broward County,
Florida, as part of a related transaction occurring in, or in connection with, an organized criminal
conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth,
Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward
and Martin Counties, Florida, the Defendant, TOM MARTINO, did knowingly and unlawfully
purchase or receive a legend drug, to wit: Procrit (epoetin alfa) from a person, to wit: Mark Novosel,
not authorized under Chapter 499, Florida Statutes, to distribute legend drugs, contrary to section
499.005(14), Florida Statutes.
COUNT 32Purchase or Receipt of a Legend Drug
from Unauthorized Person
The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly
called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and
charge that on or about March 20, 2002, in the Seventeenth Judicial Circuit, to wit: Broward County,
Florida, as part of a related transaction occurring in, or in connection with, an organized criminal
conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth,
Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward
91
and Martin Counties, Florida, the Defendant, TOM MARTINO, did knowingly and unlawfully
purchase or receive a legend drug, to wit: Panglobulin (immune globulin intavenous) from a person,
to wit: Mark Novosel, not authorized under Chapter 499, Florida Statutes, to distribute legend drugs,
contrary to section 499.005(14), Florida Statutes.
ALL OF SAID OFFENSES BEING AGAINST THE PEACE AND DIGNITY OF THESTATE OF FLORIDA.
JAMES ROSSForepersonSeventeenth Statewide Grand Jury of Florida
___________________Date
I, OSCAR GELPI, Assistant Legal Adviser, Seventeenth Statewide Grand Jury, and AssistantStatewide Prosecutor for the State of Florida, hereby certify that I, as such Prosecuting Officer andas authorized and required by law have advised the Grand Jury which returned this Indictment this day of July, 2003.
OSCAR GELPIAssistant Legal Adviser to theSeventeenth Statewide Grand JuryFlorida Bar Number 382345110 Southeast 6th Street, Suite 1400Ft. Lauderdale, Florida 33301(954)712-4950
92
I, ROBERT PENEZIC, Assistant Legal Adviser, Seventeenth Statewide Grand Jury, andAssistant Statewide Prosecutor for the State of Florida, hereby certify that I, as such ProsecutingOfficer and as authorized and required by law have advised the Grand Jury which returned thisIndictment this day of July, 2003.
ROBERT PENEZICAssistant Legal Adviser to theSeventeenth Statewide Grand JuryFlorida Bar Number 0064319110 Southeast 6th Street, Suite 1400Ft. Lauderdale, Florida 33301(954)712-4950
The foregoing Indictment was returned before me in open court this day of July,2003, and further, it is hereby sealed as to each defendant until their arrest, at which time it shall beunsealed (as to that defendant) without necessity of further Order of this Court. I hereby certify andorder the transfer of this Indictment to Miami-Dade County, Florida, pursuant to Florida Statute905.34.
HONORABLE DALE ROSSPresiding JudgeSeventeenth Statewide Grand Jury
Filed in the Circuit Court of the Eleventh Judicial Circuit, Miami-Dade County, Florida, this day of , 2003.
Clerk of the Circuit CourtDeputy Clerk
93
Defendant Biographical Information
MICHAEL CARLOWDOB: 10/16/1952SSN: 263-04-6925Last Known Address: 3465 Windmill Ranch Road
Weston, FL 33331
CANDACE CARLOWDOB: 05/20/1971SSN: 197-66-9195Last Known Address: 3465 Windmill Ranch Road
Weston, FL 33331
THOMAS ATKINS, JR.DOB: 01/02/1967SSN: 205-62-3592Last Known Address: 1544 Regal Court
Kissimmee, FL 34744
MARILYN ATKINSDOB: 07/01/1945SSN: 205-36-5133Last Known Address: 7137 Lake Island Drive
Lake Worth, FL 33467-7953
HENRY GARCIADOB: 07/10/1966SSN: 590-05-5383Last Known Address: 15444 S.W. 50th Terrace
Miami, FL
FABIAN DIAZDOB: 06/29/1947SSN: 262-92-8339Last Known Address: 9021 S.W. 113th Circle Place
Miami, FL 33176
JOEL DE LA OSADOB: 01/06/1969SSN: 594-02-5711Last Known Address: 13535 NW 9th Lane
Miami, FL 33182
94
DAVID EBANKSDOB: 07/02/1959SSN: 265-55-0361Last Known Address: 830 NE 144th Street
North Miami, FL 33161
JOSE L. BENITEZDOB: 11/06/1953SSN: 266-95-5677Last Known Address: 32070 SW 196th Avenue
Homestead, FL 33030-6404
DARIEL TABARESDOB: 11/21/1977SSN: 595-43-3905Last Known Address: 11970 SW 191st Terrace
Miami, FL 33177
MICHAEL E. BURMANDOB: 02/23/1968SSN: 267-73-2581Last Known Address: 6590 W. Rogers Circle, #6
Boca Raton, Fl 33487
LAZARO VILARCHAODOB: 12/17/1966SSN: 261-87-7455Last Known Address: 3210 SW 190th Avenue
Miramar, FL 33029
IVAN VILARCHAODOB: 11/27/1973SSN: 262-73-5718Last Known Address: 15319 Lock Isle Drive
Miami Lakes, FL 33014
JOSEPH VILLANUEVADOB: 02/06/1973SSN: 595-48-0872Last Known Address: 19230 NW 67th Court
Hialeah, FL 33015-2476
ARTURO GODINEZ
95
DOB: 01/07/1959 (F3)SSN: 262-47-7822Last Known Address: 16500 NW 84th Avenue
Hialeah, FL 33016
TOM MARTINODOB: 02/13/1971SSN: 066-70-3523Last Known Address: 504 Schulmann Drive
Las Vegas, NV 89146
JULIO CESAR CRUZDOB: 11/08/1962SSN: 267-85-8057Last Known Address: 4182 W. 6th Avenue
Miami, FL 33127
GISELA GONZALEZDOB: 01/29/1965SSN: 261-85-6308Last Known Address: 643 W. 64th Drive
Hialeah, FL 33012-6572
top related