united states districf court district of massachusetis … · 18. in this manner, on or about...

UNITED STATES DISTRICf COURT DISTRICT OF MASSACHUSETIS

~ CRIMINAL NO. II ~ J '/' 3J-(UNITED STATES OF AMERICA

) VIOLATIONS: v. )

) 18 U.S.C. § 1343 (Wire Fraud) PETERSON CHERIMOND ) 18 U.S.C. § 1028(a)(7) (Identity Fraud)

and ) 18 U.S.C. § I028A(a)(I) (Aggravated Identity Theft) JUDY BONAS ) 18 U.S.C. § 1957 (Unlawful Monetary Transaction)

Defendants. ) 18 U.S.C. § 2 (Aiding and Abetting) ) 18 U.S.C. §§981, 982,1028 (Forfeiture)

____________ ) 28 U.S.C. §2461 (Forfeiture)

INDICTMENT

The Grand Jury charges that:

GENERAL ALLEGATIONS

At times relevant to this Indictment:

I. Defendant PETERSON CHERIMOND (hereinafter "CHERIMOND") was an

individual who resided in Brockton and Roxbury, Massachusetts.

2. CHERIMOND was employed at Wainwright Bank and Trust Company, located at 63

Franklin Street, Boston, Massachusetts.

3. CHERIMOND was the owner and operator of P & A General Contractors, a

construction company located at 4 Romar Terrace, Roxbury, Massachusetts.

4. Defendant JUDY BONAS (hereinafter "BONAS") was an individual who lived in

New York City, New York.

5. TIle individual identified herein as J.M. is a person known to the Grand Jury.

Case 1:11-cr-10324-GAO Document 9 Filed 09/22/11 of 18

THE MORTGAGE LENDERS

6. New Century Mortgage Corporation ("New Century") was a real estate mortgage

company with a, principal place of business at 18400 Von Karman, Suite 1000, Irvine, California.

7. WMC Mortgage Corporation ("WMC") was a real estate mortgage company with a

principal place of business at 3100 Thorton Avenue, Burbank, California.

8. Novastar Mortgage, Inc. ("Novastar") was a real estate mortgage company with a

principal place of business at 6200 Oak Tree Boulevard, 3'd Floor, Independence, Ohio.

OVERVIEW OF THE SCHEME TO DEFRAUD

9. From in or about September 2006, to in or about November 2006, defendants

CHERIMOND and BONAS, acting in concert with others known and unknown to the Grand Jury,

defrauded the mortgage lenders by means ofmaterial false and fraudulent pretenses, representations

and promises and thereby obtained money, funds, credits, assets, and other property owned by and

under the custody and control ofthe mortgage lenders in connection with the financing ofresidential

real estate purchases located at the following Massachusetts addresses:

a. 22 Arch Street, Brockton, Massachusetts;

b. 115 West Selden Street, Mattapan, Massachusetts; and

c. 29 Lake Street, Halifax, Massachusetts.

10. TIle fraud was executed in the following manner:

a. CHERIMOND and others acting in concert with CHERIMOND identified

residential real estate properties for sale.

b. CHERIMOND recruited BONAS to act as the purported purchaser of the

real estate properties using the stolen personal identifiers of J.M. In

2


recruiting BONAS to impersonate J.M. for the purpose of buying the

properties. CHERIMOND at various times:

i. provided BONAS with a counterfeit California Drivers License in the

name of J.M.• bearing BONAS' photograph, to be used as

identification in connection with the purchase and mortgage loan

financing of the properties;

ii. arranged for the payment offunds to BONAS for her role in the fraud.

c. CHERIMOND and others acting in concert with him caused false and

fraudulent loan applications to be submitted to the mortgage lenders and

approved in the name ofJ.M. to finance the purchase of the properties. The

mortgage loan applications and supporting documents contained material

misrepresentations, including:

I. false representations that J.M. was the buyer for properties;

II. false representations that BONAS was J.M.;

III. false representations that J.M. would occupy the properties as her

"primary" residence; and

iv. on various occasions, false representations regarding J.M.'s

employment, income. assets in the form ofbank account balances and

assets in the form of real estate owned.

d. On various occasions CHERIMOND and others acting in concert with him

caused false Verifications ofRent and false Verifications ofEmployment to

3


be created and submitted to the lenders in support of mortgage loan

applications in the name ofJ.M.

t:. CHERIMOND caused BONAS to attend closings for mortgage loans in the

name ofJ.M., whereby the defendants used the counterfeit California Drivers

License in the name J.M., and whereby BONAS executed mortgage loan

documents and other legal documents in the name of J.M.

f. In this way, CHERIMOND, BONAS, and others acting in concert with them,

caused the mortgage lenders New Century, WMC, and Novastar to fund

mortgage loans through interstate wire transfers to the bank accounts of the

closing attorneys.

I I . The mortgages for the properties involved in the scheme to defraud went into default

and resulted in fi:>reclosure.

THE FRAUDULENT TRANSACTIONS

22 ARCH STREET BROCKTON,~SACHUSETTS

12. On or about July 15,2004, defendant CHERIMOND acquired the residential real

estate property located at 22 Arch Street, Brockton, Massachusetts for the purchase price of

$345,000.

13. In or about September, 2006, defendant CHERIMOND and others acting in

concert with him caused a Purchase and Sale agreement to be prepared in the name of J.M.

representing that J.M. intended to purchase the Arch Street property from him for $425,000.

4


14. In or about September, 2006, defendant CHERIMOND and others acting in

concert with him caused two mortgage loan applications in the name of J.M. to be submitted to

New Century. The loan applications contained the name, date of birth and social security

number of the true J.M. The loan applications contained material false representations,

including: that J.M. was involved in the transaction when in fact the true J.M. was not involved

and had not authorized the use of her identity; that J.M. resided at 602 South Street in Quincy,

Massachusetts; that J.M. was employed at Stajez Center For The Art; that J.M. owned assets held

as balances in two bank accounts totaling $4,500 and other tangible assets aggregating $75,500;

and, that J.M. intended to occupy the Arch Street property as her primary residence. The loan

applications also contained material false representations regarding J .M.'s income.

15. In this manner, in or about September, 2006, defendant CHERIMOND and others

acting in concert with him caused New Century to approve first and second mortgages in the

amounts of $340,000 and $85,000, respectively, for a total loan amount of $425,000.

16. On or about September 29, 2006, defendant CHERIMOND caused defendant

BONAS to travd from New York City to Boston for the purpose of impersonating J .M. and

executing mortgage loan documents in the name of J.M.

17. On or about September 29, 2006, defendants CHERIMOND and BONAS

attended a mortgage loan closing. Defendant BONAS, posing as J.M., presented the counterfeit

California Drivers License that had been provided by defendant CHERIMOND in the name J.M.

to the closing attorney as proof of her identity. Defendants CHERIMOND and BONAS, posing

as J.M., signed false and fraudulent HUD-I Settlement Statements and other legal documents.

5


18. In this manner, on or about September 29, 2006, defendants CHERIMOND and

BONAS caused New Century to transfer $342,345.78 and $84,654.46, totaling $427,000.24, by

interstate wire to the Massachusetts bank account of the closing attorney.

19. On or about September 29, 2006, defendant CHERIMOND paid defendant

BONAS approximately $750.00.

20. [n or about October 2006, defendant CHERIMOND paid defendant BONAS an

additional sum ofapproximately $750.00.

115 WEST SELDEN STREET MATTAPAN, MASSACHUSETTS

21. In or about October 2006, defendant CHERIMOND and others acting in concert

with him created the appearance that J.M. was purchasing the property at 115 West Selden Street

in Mattapan, Massachusetts for $482,000.

22. On or about October 13,2006, defendant CHERIMOND and others acting in

concert with him caused two mortgage loan applications in the name of J.M. to be submitted to

WMC. The loan applications contained the name, date of birth and social security number of the

true J.M. The loan applications contained material false representations, including: that J.M. was

involved in the transaction when in fact the true J.M. was not involved and had not authorized

the use ofher idlmtity; that J.M. resided at 602 South Street in Quincy, Massachusetts; that J.M.

was employed at Premium Care and Stajez Center For The Art; that J.M. owned tangible assets

in real estate valued at $482,000; and, that J.M. intended to occupy the Selden Street property as

her primary residence. The loan applications also contained material false representations

regarding J.M.'s income.

6


23. In this manner, in or about October, 2006, defendant CHERIMOND and others

acting in concert with him caused WMC to approve first and second mortgages in the amounts of

$385,600 and $96,400, respectively, for a total loan amount of$482,000.

24. On or about October 19, 2006, defendant CHERIMOND caused defendant

BONAS to travel from New York City to Boston for the purpose ofimpersonating J.M. and

executing mortgage loan documents in the name of J.M.

25. On or about October 19, 2006, defendants CHERIMOND and BONAS attended a

mortgage loan closing. Defendant BONAS, posing as J.M., presented the counterfeit California

Drivers Licens(~ that had been provided by defendant CHERIMOND in the name J.M. to the

closing attorney as proof of her identity. Defendant BONAS, posing as J.M., signed false and

fraudulent HUD-I Settlement Statements and other legal documents.

26. In that manner, on or about October 19, 2006, defendants CHERIMOND and

BONAS caused WMC to transfer $389,414.27 and $95,579.19, totaling $484,993.46, by

interstate wire to the Massachusetts bank account of the closing attorney.

27. On or about October 19,2006, defendant CHERIMOND paid defendant BONAS

approximately $1,500.00.

29 LAKE STREET HALIFAX, MASSACHUSETTS

28. In or about October 2006, defendant CHERIMOND and others acting in concert

with him created the appearance that J.M. was purchasing the property at 29 Lake Street in

Halifax, Massachusetts for $605,000.

7


29. From on or about September 24, 2006, to on or about October 27, 2006, defendant

CHERIMOND and others acting in concert with him caused two mortgage loan applications in

the name of1.M. to be submitted to Novastar. The loan applications contained the name, date of

birth and social security number of the true 1.M. The loan applications contained material false

representations, including: that 1.M. was involved in the transaction when in fact the true J.M.

was not involved and had not authorized the use of her identity; that 1.M. resided at 602 South

Street in Quincy, Massachusetts; that 1.M. owned tangible assets in real estate valued at

$425,000; and, that 1.M. intended to occupy the Lake Street property as her primary residence.

30. In this manner, in or about October, 2006, defendant CHERIMOND and others

acting in concert with him caused Novastar to approve first and second mortgages in the amounts

of$484,000 and $121,000, respectively, for a total loan amount of $605,000.

31. On or about October 27, 2006, defendant CHERIMOND caused defendant

BONAS to travel from New York City to Boston for the purpose of having defendant BONAS

impersonate J.M. and execute mortgage loan documents in the name of1.M.

32. On or about October 27, 2006, defendant BONAS attended a mortgage loan

closing with an associate of defendant CHERIMOND. Defendant BONAS, posing as 1.M.,

presented the counterfeit California Drivers License that had been provided by defendant

CHERIMOND in the name 1.M. to the closing attorney as proof of her identity. Defendant

BONAS, posing as J.M., signed false and fraudulent HUD-l Settlement Statements and other

legal documents.

8


33. In this manner, on or about October 27,2006, defendants CHERIMOND and

BONAS caused Novastar to transfer $487,200.55 and $120,385.75, totaling $607,586.30, by

interstate wire to the Massachusetts bank: account of the closing attorney.

34. On or about October 27,2006, defendant CHERIMOND caused his associate to

pay defendant BONAS approximately $ 1,500.00.

9


COUNTS ONE through SIX [Wire Fraud - 18 U.S.C. §1343]

35. The Grand Jury re-alleges and incorporates by reference paragraphs I through 34 of

this Indictment and further charges that:

36. On or about the following dates, in the District of Massachusetts and elsewhere,

PETERSON CHERIMOND aud

JUDy BONAS,

defendants hen::in, together with others known and unknown to the Grand Jury, having devised and

intending to devise a scheme and artifice to defraud, and for obtaining money and property by means

ofmaterial falst: and fraudulent pretenses, representations, and promises, did cause writings, signs,

signals, pictures and sounds to be transmitted by means of wire communication in interstate

commerce for the purpose of executing such scheme and artifice, as follows:

Count Date MortaageLen er

and Property

Wire Transaction

I 09/29/06 New Century re: 22 Arch Street,

Brockton, MA

$342,345.78 wire transfer of funds from Deutsche Bank Trust Co. Americas (DBTCO Americas NYC) at New York NY to the 10LTA account of L.B., Sovereign Bank account No.····7962 at Quincy, MA

2 09/29/06 New Century re:

22 Arch Street,

Brockton, MA

$84,654.46 wire transfer of funds from Deutsche Bank Trust Co. Americas (DBTCO Americas NYC) at New York, NY to the 10LTA account of L.B., Sovereign Bank account No.····7962 at Quincy, MA.

3 10119/06 WMC Mortgage

re: 115 West Selden Street, Mattapan, MA

$389,414.27 wire transfer offunds from Bank of New York Mellon (Bk ofNYC) at New York, NY to the 10LTA account ofN.L., The Community Bank account No...• ..4114 at Brockton, MA

10


Count Date Mort5ageLen er

and Property

Wire Transaction

4 1011912006 WMC Mortgage

re:115 West Selden Street,

Mattapan, MA

$95,579.19 wire transfer of funds from Bank of New York Mellon (Bk ofNYC) at New York, NY to the IOLTA account ofN.L., The Community Bank account No.·····4114 at Brockton, MA

5 10/2712006 Novastar re: 29 Lake Street, Halifax, MA

$487,200.55 wire transfer of funds from UBS AG (UBS AG NYC) at New York, NY to the IOLTA account of M.F., Citizens' Bank account No. ···2007 at Andover, MA.

6 10/2712006 Novastar re:

29 Lake Street, Halifax, MA

$ 120,385.75 wire transfer of funds from UBS AG (UBS AG NYC) at New York, NY to the IOLTA account ofM.F., Citizens' Bank account No. ···2007 at Andover, MA.

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

II


COUNTS SEVEN through NINE [Identity Fraud -18 U.S.C. § 1028 (a)(7»)

37. The Grand Jury re-alleges and incorporates by reference paragraphs 1-36 of this

Indictment and further charges that:

38. On or about the following dates, in the District of Massachusetts and elsewhere,

PETERSON CHERIMOND and

JUDY BONAS,

defendants herdn, did knowingly transfer, possess and use, without lawful authority, in and

affecting interstate commerce, means of identification of another person as set forth below, with

the intent to commit and to aid and abet, and in connection with, unlawful activities that

constitute violations of Federal law, to wit: Wire Fmud in violation of 18 U.S.C. §1343, to obtain

things of value aggregating $1,000 or more during a one-year period:

Count Date Means of Identification

7 9/29/2006 Name, date of birth and social security number of I.M

8 10/19/2006 Name, date ofbirth and social security number of I.M

9 10/27/2006 Name, date of birth and social security number of I.M

All in violation of Title 18, United States Code, Sections 1028(a)(7) and 2.

12


COUNT TEN [Aggravated Identity Theft -18 U.S.C. §1028A(a)(I»)

39. The Grand Jury re-alleges and incorporates by reference paragraphs 1 through 36 of

this Indictment, and further charges that:

40. From in or about September, 2006, to in or about October, 2006, in the District of

Massachusetts, and elsewhere,

PETERSON CHERIMOND

defendant herein, did, knowingly transfer, possess and use, without lawful authority, the means

of identification of a person, during and in relation to the commission of violations of 18 U.S.C.

§1343 (Wire Fraud).

All in violation of 18 U.S.C. §1028A(a)(l) and 18 U.S.C. § 2.

13


COUNT ELEVEN [Unlawful Monetary Transaction -18 U.S.c. §1957]

41. The Grand Jury re-alleges and incorporates by reference paragraphs I through 36 of

this Indictment, and further charges that:

42. On or about November 8, 2006, in the District of Massachusetts, and elsewhere,

PETERSON CHERIMOND

defendant herein, did knowingly engage and attempt to engage in a monetary transaction, by, through

or to a fmancial institution, affecting interstate or foreign commerce, in criminally derived property

of a value greater than $10,000, to wit: Check No. 101 in the amount of $ 25,000 drawn on the

account ofM.T. at Crescent Credit Union account No. XXXX8542, payable to Peterson Cherimond,

which funds were derived from a specified unlawful activity, that is, Wire Fraud in connection with

the purchase of 115 West Selden Street in violation of 18 U.S.C. §1343.

All in violation ofTitle 18, United States Code, Sections 1957 and 2.

14


WIRE FRAUD FORFEITURE ALLEGATION [18 U.S.C. § 981(a)(I)(C) aDd 28 U.S.C. § 246I(c»

43. Upon conviction ofone or more ofthe offenses alleged in Counts One through Six of

this Indictment,

PETERSON CHERIMOND aDd

JUDy BONAS,

defendants herein, shall forfeit to the United States, pursuant to 18 U.S.C. § 981(a)(l)(C) and 28

U.S.C. § 246 I(c), any property, real or personal, which constitutes, or is derived from, proceeds

traceable to the commission ofthe offenses.

44. If any of the property described in paragraph 43, above, as a result of any act or

omission of the defendants

a. cannot be located upon the exercise ofdue diligence;

b. has been transferred or sold to, or deposited with, a third party;

c. has been placed beyond the jurisdiction of this Court;

d. has been substantially diminished in value; or

e, has been commingled with other property which cannot be divided without difficulty;

it is the intention of the United States, pursuant to 28 U.S.c. § 2461 (c), incorporating 21 U.S.c. §

853(P), to seek forfeiture of any other property of the defendants up to the value of the property

described in paragraph 42 above.

All pursuant to Title 18, United States Code, Section 981 (a)( 1)(C) and Title 28, United States

Code, Section 2461 (c).

15


IDENTITY THEn FORFEITURE ALLEGAnON (18 U.S.C. § 982(a)(2)(B) and 18 U.S.c. § 1028(b)(S)]

45. Upon conviction ofone or more ofthe offenses alleged in Counts Seven through Nine

of this Indictment,

PETERSON CHERIMOND and

JUDY BONAS,

defendants herein, shall forfeit to the United States, pursuant to 18 U.S.c. § 982(a)(2)(B), any

property constituting, or derived from, proceeds obtained directly or indirectly as a result of the

offenses, and pursuant to 18 U.S.C. § 1028(b)(5), any personal property used or intended to be used

to commit the offenses.


omission of the defendants-

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

b. has been transferred to, sold to, or deposited with a third party;

(;. has been placed beyond the jurisdiction of this Court;


e. has been commingled with other property which cannot be divided without difficulty;

it is the intention of the United States, pursuant to 18 U.S.C. § 982(b)(l), incorporating 21 U.S.C.

§ 853(p), to seek forfeiture of any other property of the defendants up to the value of the property


All pursuant to Title 18, United States Code, Section 982(a)(2)(B) and Title 18, United

States Code, Section 1028(b)(5).

16


MONEY LAUNDERING FORFEITURE ALLEGATION [18 U.S.C. § 982(a)(I»)

47. Upon conviction of the offense alleged in COWlt Eleven of this Indictment,

PETERSON CHERIMOND,

defendant herein, shall forfeit to the United States, pursuant to 18 U.S.C. § 982(a)(I), any property,

real or personal, involved in such offense, or any property traceable to such property.


omission of the defendant-

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

b. has been transferred to, sold to, or deposited with a third party;

c. has been placed beyond the jurisdiction ofthis Court;


e. has been commingled with other property which cannot be divided without difficulty;

it is the intention of the United States, pursuantto 18 U.S.C. § 982(b)(l), incorporating 21 U.S.C.

§ 853(P), to seek forfeiture of any other property of the defendant up to the value ofthe property


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

17


A TRUE BILL

~d:61.~Q~ FOREPERSON OF THE GRAN JURY

VI A. IL As Istant United States Attorney

DISlRICT OF MASSACHUSETTS: September 12.,2011.

Returned into the District Court by the Grand J

CERK.

oJ 'J. ',.31 PM q.~Z,[{

18


----------

""]845 (5/97) - (RevIsed U 8.D.C. MA 3/25(2011)

Crimin~1 Case Cover Sheet U.S. District Court - District of Massacbusetts

Place of Offense: Category No. II Investigating Agency USPIS and IRS

City Quincy Related Case Information:

County Norfolk Superseding Ind.llnf. Case No. Same Defendant New Defendant ---Magistrate Judge Case Number Search Warrant Case Number R 201R 40 from District of

Defendant Information:

Defendant Name Juvenile: DYes 0NoJUDY BONAS

Is this person an attorney and/or a member of any state/federal bar: DYes 0 No

Alias Name

Address (City & Stale) NEW YORK CITY D

Birth date (Yr only): 1956 SSN (last4#): 0000 Sex ~ Race: B Nationality: Trini_d_a_d _

Defense Counsel if known: Stellio Sinnis Address Federal Defender Office

Boston, MA 02210Bar Number

U.S. Attorney Information:

Victor A. Wild 543148AUSA Bar Number if applicable

Interpreter: DYes [(] No List language and/or dialect:

Victims: 0Yes D No )fyes, are there multiple crime victims under) 8 USC§3771(d)(2) DYes [{]No

Matter to be SEALED: DYes 0 No

OWarrant Reque'sted [{] Regular Process D In Custody

Location Status:

Arrest Date

DAlready in Federal Custody as of in

DAlready in State Custody at ---------- []serving Sentence Gwaiting Trial

DOn Pretrial Release: Ordered by: on

Charging Document: DComplaint D Information o Indictment

9Total # of Counts: Dpetty--- DMisdemeanor !ZJFelony

Continue on Page 2 for Entry of U.S.C. Citations

I hereby certify that the case numbers of any prior proceedings b e are accurately set forth above.

Date: September -1-bO'11 Signature of AUSA:

Case 1:11-cr-10324-GAO Document 9-1 Filed 09/22/11 Page 1 of 4

'545 (5m) (Revised U.5.D.C. MA 1217105) Page 2 of2 or Reve""

District Court Case Number (To be filled in by deputy clerk):

JUDY BONAS Name of Defendant

U.S.c. Citations

Index Key/Code Description of Offense Charged Count Numbers

18 USC 1343 Wire Fraud 1- 6 Set 1

18 USC 1028(a)(7) Identity Fraud 7-9Set 2

Set 3

Set 4

Set 5

Set 6

Set 7

Set 8

Set 9

Set 10 _

Set II _

Set 12 _

Set 13 _

Set 14 _

Set 15 _

ADDITIONAL INFORMATION:

cr jS.45-MA2011 wpd - 3/2512011


-----------------

'"'S 45 (5i97) - (Revised US.D.C. MA 3125/2011)

Criminal Case Cover Sheet U.S. District Court - District of Massachusetts

II USPIS and IRS Place of Offense: Category No. Investigating Agency

Related Case Information: City Quincy

County Norfolk Superseding Ind./ Inf. Case No. Same Defendant New Defendant Magistrate Judie Case Number II .... .rMfI~D Search Warrant Case Number R 201R 40 from District of

Defendant Information:

PETERSON CHERIMOND Defendant Name Juvenile: DYes [l] No

Is this person an attorney and/or a member of any state/federal bar: DYes [l] No

Alias Name

Address (City & State) Dorchester, MA .. Birth date (Yronly): 197~ SSN(last4#):2110 Sex_~ Race: Other__ Nationality: UNK

-~--~~-

Defense Counsel ifknown: Arnold Rosenfeld Address Sarrouf Law

2 Oliver Street Bar Number

Boston, MA 02109U.S. Attorney Information:

Victor A. Wild 543148AUSA Bar Number if applicable

Interpreter: DYes [{] No List language and/or dialect:

Victims: [(JYes DNo If yes, are there multiple crime victims under 1& USC§3111(d)(2) DYes [l]No

Matter to be SEALED: DYes [{] No

DWarrant Requested D Regular Process [l] In Custody

Location Status:

Arrest Date September 12, 2011

[(]AJready in Federal Custody as of September 12,2011 in ,,/VI S-;lC1f .:rG!)

DAlready in State Custody at ---------- Derving Sentence 0 waiting Trial

DOn Pretrial Release: Ordered by: on

Charging Document: oComplaint D Information [l] Indictment

11Total # of Counts: DPetty--- DMisdemeanor [{]Felony

Continue on Page 2 for Entry ofU.S.C. Citations

I hereby certify that the case numbers of any prior proceedings befo accurately set fortb above.

September ~ 2011Date: Signature of AUSA:

a


IS 45 (5197) (Revised U S.D.C MA 12/7/05) Page 2 of2 or Reverse

Distric:t Court Case Number (To be filled in by deputy cleric):

Name ofDefendant PETERSON CHERIMOND

U.S.C. Citations

Set 1

Index Key/Code

18 USC 1343 Description of Offense Charged

Wire Fraud Count Numbers

1- 6

Set 2 18 USC 1028(a)(7) Identity Fraud 7-9

Set 3 18 USC 1028A Aggravated Identity Theft 10

Set 4 18 USC 1957 Money Laundering 11

Set 5

Set 6

Set 7

Set 8

Set 9

Set 10 _

Set 11 . _

Set 12 , _

Set 13 _

Set 14 . _

Set 15 • _

ADDITIONAL INFORMATION:

cr js.45-MA20 II wpd - 3/25120 II


united states districf court district of massachusetis … · 18. in this manner, on or about...

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