united states district court southern … abdul hakim muhammad, and kwasi drakes, the defendants,...
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UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF NEW YORK- - - - - - - - - - - - - - - - - -X
UNITED STATES OF AMERICA :
-v.- : SEALED INDICTMENT
BEVERLY MOZER-BROWNE, : 06 Cr.PHILLIP A. BROWNE,SANDFORD BROWNE, : a/k/a “Tyson,”GERRARDA BROWNE, : a/k/a “Gerry,”WILLIANA BROWNE, :JOHN LOFTON, a/k/a “Big John,” :PETER ABSOLAM, a/k/a “Lloyd,” :KEITH MAHASE, ABDUL HAKIM MUHAMMAD, :TIFFANY WAYMAN, NARRISA MOHAMMED, :JAMSHEED JEREMIAH, a/k/a “Jason,” :KHADIGA CLARKE, a/k/a “Kelly,” :LENNARD PRESCOD, a/k/a “Bob,” :MAKEBA ISAROON,RHONDA EATON, :RODERICK CHASSEAU, CAMERON A. LLOYD, :KWASI DRAKES,NARINE JAIRAM, :CHERYLENE RAMDASS, TULSI RAMRUP, :NATASHA HERCULES, ANNEKA RAMPERSAD, :TASLEEM KUDRATH, MERVIN TRANCOSO, :ADRIAN GOURSAHAB, NIGEL DEFOUR, :WENDY HARRISON, and KERRY RAMPERSAD, :
Defendants. :
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COUNT ONE
(Conspiracy to Commit Visa Fraud)
The Grand Jury charges:
Background
1. BEVERLY MOZER-BROWNE, the defendant (“MOZER-
BROWNE”), owned and operated a business called Help Preparers
Professional Services (“HPPS”), located at 106-16 Jamaica Avenue
in Queens, New York.
2. HPPS purported to offer its customers assistance
in a variety of financial and legal matters, but in fact, the
primary business at HPPS was providing permanent residence
documents (“green cards”) by means of fraud.
3. SANDFORD BROWNE, a/k/a “Tyson,” GERRARDA BROWNE,
a/k/a “Gerry,” WILLIANA BROWNE, PETER ABSOLAM, a/k/a “Lloyd,”
KEITH MAHASE, ABDUL HAKIM MUHAMMAD, NARRISA MOHAMMED, JAMSHEED
JEREMIAH, a/k/a “Jason,” KHADIGA CLARKE, a/k/a “Kelly,” LENNARD
PRESCOD, a/k/a “Bob,” RODERICK CHASSEAU, CAMERON A. LLOYD, and
KWASI DRAKES, the defendants, were all employed by HPPS to assist
in its illegal activity.
4. Until in or about December 2005, PHILLIP A.
BROWNE, the defendant (“BROWNE”), MOZER-BROWNE’s brother, was
employed as a District Adjudication Officer by the United States
Citizenship and Immigration Services (“CIS”) (formerly known as
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the “Immigration and Naturalization Service” or “INS”) at 26
Federal Plaza, New York, New York.
5. MOZER-BROWNE and her co-conspirators at HPPS
charged an applicant anywhere from approximately $8,000 to
approximately $16,000 to provide a green card by means of fraud.
A person seeking these services (an “HPPS applicant”) was
typically provided with documentation of marriage to a United
States citizen in one of two ways: Either MOZER-BROWNE and her
co-conspirators would pay a United States citizen to enter into a
sham marriage with the HPPS applicant, or they would produce
phony documentation indicating that a marriage to a United States
citizen had occurred at some time in the past.
6. JOHN LOFTON, a/k/a “Big John,” and RHONDA EATON,
the defendants, helped MOZER-BROWNE and HPPS find United States
citizens willing to enter into sham marriages with HPPS
applicants. TIFFANY WAYMAN and MAKEBA ISAROON, the defendants,
were two United States citizens paid by HPPS to enter into sham
marriages with HPPS applicants. CAMERON A. LLOYD, the defendant,
performed sham marriages for HPPS applicants.
7. Once the HPPS applicant had documentation of a
marriage to a United States citizen, employees at HPPS would
prepare an application package for a green card. The application
usually included fraudulent financial information, such as
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fictitious letters from employers or banks. The application was
then mailed to CIS.
8. Following the submission of the fraudulent
application, the HPPS applicant received an appointment for an
interview at the CIS office at 26 Federal Plaza. BROWNE then
approved the applications submitted by his co-conspirators at
HPPS without requiring the HPPS applicant to appear at CIS for
the interview. BROWNE generated a Form I-181 (“Memorandum of
Creation of Record of Lawful Permanent Residence”) on behalf of
the HPPS applicant, and a green card was issued to the HPPS
applicant.
9. From at least in or about April 2001 through in or
about November 2005, MOZER-BROWNE, BROWNE, and their co-
conspirators provided hundreds of fraudulent green cards to HPPS
applicants, receiving more than one million dollars in proceeds.
Statutory Allegation
10. From at least in or about April 2001 through in or
about November 2005, in the Southern District of New York and
elsewhere, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, SANDFORD
BROWNE, a/k/a “Tyson,” GERRARDA BROWNE, a/k/a “Gerry,” WILLIANA
BROWNE, JOHN LOFTON, a/k/a “Big John,” PETER ABSOLAM, a/k/a
“Lloyd,” KEITH MAHASE, ABDUL HAKIM MUHAMMAD, TIFFANY WAYMAN,
NARRISA MOHAMMED, JAMSHEED JEREMIAH, a/k/a “Jason,” KHADIGA
CLARKE, a/k/a “Kelly,” LENNARD PRESCOD, a/k/a “Bob,” MAKEBA
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ISAROON, RHONDA EATON, RODERICK CHASSEAU, CAMERON A. LLOYD, and
KWASI DRAKES, the defendants, and others known and unknown,
unlawfully, willfully, and knowingly combined, conspired,
confederated, and agreed together and with each other to commit
an offense against the United States, to wit, violations of
Section 1546 of Title 18, United States Code.
11. It was a part and an object of the conspiracy that
BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, SANDFORD BROWNE, a/k/a
“Tyson,” GERRARDA BROWNE, a/k/a “Gerry,” WILLIANA BROWNE, JOHN
LOFTON, a/k/a “Big John,” PETER ABSOLAM, a/k/a “Lloyd,” KEITH
MAHASE, ABDUL HAKIM MUHAMMAD, TIFFANY WAYMAN, NARRISA MOHAMMED,
JAMSHEED JEREMIAH, a/k/a “Jason,” KHADIGA CLARKE, a/k/a “Kelly,”
LENNARD PRESCOD, a/k/a “Bob,” MAKEBA ISAROON, RHONDA EATON,
RODERICK CHASSEAU, CAMERON A. LLOYD, and KWASI DRAKES, the
defendants, and others known and unknown, unlawfully, willfully
and knowingly would and did utter, use, possess, obtain, accept
and receive immigrant and nonimmigrant visas, permits, alien
registration receipt cards, and other documents prescribed by
statute and regulation as evidence of authorized stay and
employment in the United States, knowing them to have been
procured by means of false claims and statements, and to have
been otherwise procured by fraud and unlawfully obtained, in
violation of Title 18, United States Code, Section 1546.
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Overt Acts
12. In furtherance of the conspiracy and to effect the
illegal object thereof, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE,
SANDFORD BROWNE, a/k/a “Tyson,” GERRARDA BROWNE, a/k/a “Gerry,”
WILLIANA BROWNE, JOHN LOFTON, a/k/a “Big John,” PETER ABSOLAM,
a/k/a “Lloyd,” KEITH MAHASE, ABDUL HAKIM MUHAMMAD, TIFFANY
WAYMAN, NARRISA MOHAMMED, JAMSHEED JEREMIAH, a/k/a “Jason,”
KHADIGA CLARKE, a/k/a “Kelly,” LENNARD PRESCOD, a/k/a “Bob,”
MAKEBA ISAROON, RHONDA EATON, RODERICK CHASSEAU, CAMERON A.
LLOYD, and KWASI DRAKES, the defendants, and others known and
unknown, committed the following overt acts, among others, in the
Southern District of New York and elsewhere:
a. In or about April 2001, RODERICK CHASSEAU,
the defendant, submitted a fraudulent green card application to
CIS (then INS).
b. In or about August 2003, JAMSHEED JEREMIAH,
a/k/a “Jason,” the defendant, submitted a fraudulent green card
application to CIS.
c. In or about January 2004, NARRISA MOHAMMED,
the defendant, submitted a fraudulent green card application to
CIS.
d. In or about March 2004, RHONDA EATON, the
defendant, submitted a fraudulent Petition For Alien Relative to
CIS.
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e. On or about May 14, 2004, ABDUL HAKIM
MUHAMMAD, the defendant, deposited approximately $9,000 in cash
proceeds into his checking account at New York Community Bank.
f. In or about May 2004, SANDFORD BROWNE, a/k/a
“Tyson,” the defendant, submitted a fraudulent green card
application to CIS.
g. In or about May 2004, WILLIANA BROWNE, the
defendant, submitted a fraudulent green card application to CIS.
h. In or about June 2004, KHADIGA CLARKE, a/k/a
“Kelly,” the defendant, submitted a fraudulent green card
application to CIS.
i. On or about June 24, 2004, MAKEBA ISAROON,
the defendant, entered into a fraudulent marriage with an HPPS
applicant.
j. On or about August 4, 2004, PHILLIP A. BROWNE
approved SANDFORD BROWNE’s fraudulent application for a green
card at CIS in New York, New York.
k. In or about August 2004, KEITH MAHASE, the
defendant, submitted a fraudulent green card application to CIS.
l. On or about August 30, 2004, KWASI DRAKES,
the defendant, deposited approximately $9,000 in cash into her
checking account at Chase.
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m. In or about September 2004, GERRARDA BROWNE,
a/k/a “Gerry,” the defendant, submitted a fraudulent green card
application to CIS.
n. On or about March 14, 2005, CAMERON A. LLOYD,
the defendant, conducted a sham marriage ceremony for an HPPS
applicant.
o. On or about May 27, 2005, PETER ABSOLAM,
a/k/a “Lloyd,” the defendant, introduced an HPPS applicant for a
fraudulent green card (“Applicant-1”) to MOZER-BROWNE.
p. On or about June 15, 2005, MOZER-BROWNE,
RHONDA EATON, and JOHN LOFTON, a/k/a “Big John,” the defendants,
introduced Applicant-1 to TIFFANY WAYMAN, who was paid to enter
into a sham marriage with Applicant-1.
q. On or about June 15, 2005, TIFFANY WAYMAN
applied for and obtained a license to marry Applicant-1.
r. On or about November 9, 2005, LENNARD
PRESCOD, a/k/a “Bob,” provided fraudulent birth certificates to a
confidential informant in exchange for cash.
(Title 18, United States Code, Sections 371.)
COUNT TWO
(Money Laundering Conspiracy)
The Grand Jury further charges:
13. From at least in or about March 2004, up to and
including at least in or about May 2005, in the Southern District
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of New York and elsewhere, BEVERLY MOZER-BROWNE, PHILLIP A.
BROWNE, ABDUL HAKIM MUHAMMAD, and KWASI DRAKES, the defendants,
and others known and unknown, unlawfully, willfully and knowingly
did combine, conspire, confederate and agree together and with
each other to commit offenses against the United States, to wit,
violations of Title 18, United States Code, Section
1956(a)(1)(B)(i).
14. It was a part and an object of said conspiracy
that BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, ABDUL HAKIM
MUHAMMAD, and KWASI DRAKES, the defendants, and others known and
unknown, in an offense involving and affecting interstate and
foreign commerce, knowing that property involved in certain
financial transactions represented the proceeds of some form of
unlawful activity, unlawfully, willfully, and knowingly would and
did conduct and attempt to conduct financial transactions, which
in fact involved the proceeds of specified unlawful activity, to
wit, visa fraud, knowing that the transactions were designed in
whole and in part to conceal and disguise the nature, location,
source, ownership and control of the proceeds of specified
unlawful activity, in violation of Title 18, United States Code,
Section 1956(a)(1)(B)(i).
Means and Methods of the Conspiracy
15. Among the means and methods employed in conducting
and participating in the conduct of the conspiracy were the
following:
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a. BEVERLY MOZER-BROWNE (“MOZER-BROWNE”) and
PHILLIP A. BROWNE (“BROWNE”), the defendants, and their co-
conspirators made large cash deposits of visa fraud proceeds into
bank accounts at various financial institutions, usually in
amounts smaller than $10,000.
b. In order to conceal the illegal source of the
cash, ABDUL HAKIM MUHAMMAD (“MUHAMMAD”) and KWASI DRAKES
(“DRAKES”), the defendants, made large cash deposits and then
transferred the money into accounts controlled by MOZER-BROWNE or
members of her family, or withdrew the money by writing checks to
MOZER-BROWNE or members of her family.
c. In addition to dividing the cash proceeds
from the visa fraud conspiracy among different bank accounts,
MOZER-BROWNE and her co-conspirators concealed the proceeds by
purchasing a number of properties, including several properties
in Florida, held in various straw purchasers’ names.
Overt Acts
16. In furtherance of said conspiracy and to effect
the illegal object thereof, BEVERLY MOZER-BROWNE, PHILLIP A.
BROWNE, ABDUL HAKIM MUHAMMAD, and KWASI DRAKES, the defendants,
and others known and unknown, committed the following overt acts,
among others, in the Southern District of New York and elsewhere:
a. On or about March 8, 2004, MOZER-BROWNE
deposited approximately $22,400 (including $7,400 in cash) into
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her checking account at a Chase bank branch in New York, New
York.
b. On or about March 15, 2004, MOZER-BROWNE
deposited approximately $7,500 (including $7,000 in cash and a
$500 check made out to “Kwasi Drakes”) into her checking account
at a Chase bank branch in New York, New York.
c. On or about May 14, 2004, MUHAMMAD deposited
approximately $9,000 in cash into his checking account at New
York Community Bank.
d. On or about May 24, 2004, MUHAMMAD deposited
approximately $9,000 into his checking account at New York
Community Bank.
e. On or about June 9, 2004, MOZER-BROWNE
deposited approximately $9,000 in cash into her bank account at
Chase.
f. On or about June 9, 2004, DRAKES deposited
approximately $3,000 into her bank account at Chase.
g. On or about June 10, 2004, DRAKES deposited
approximately $3,900 into her bank account at Chase.
h. On or about June 10, 2004, DRAKES transferred
approximately $4,000 from her account at Chase into MOZER-
BROWNE’s Chase account.
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i. On or about July 1, 2004, MOZER-BROWNE
deposited a check for approximately $27,000 to her checking
account at a Chase bank branch in New York, New York.
j. On or about August 30, 2004, MOZER-BROWNE
deposited approximately $9,000 in cash into her bank account at
Chase.
k. On or about August 30, 2004, DRAKES deposited
approximately $9,000 in cash into her bank account at Chase.
l. On or about August 30, 2004, DRAKES
transferred approximately $9,000 from her account into MOZER-
BROWNE’s Chase account.
m. On or about September 1, 2004, MOZER-BROWNE
deposited approximately $13,000 into her bank account at Chase.
n. On or about September 1, 2004, DRAKES
deposited approximately $4,600 in cash into her account at Chase.
o. On or about September 1, 2004, DRAKES
transferred approximately $4,600 from her account into MOZER-
BROWNE’s Chase account.
p. On or about September 10, 2004, MOZER-BROWNE
deposited approximately $5,000 in cash into her account at Chase.
q. On or about September 10, 2004, DRAKES made
two deposits into her bank account at Chase: one for
approximately $7,000 and one for approximately $5,000.
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r. On or about September 17, 2004, DRAKES
transferred approximately $8,700 from her account into MOZER-
BROWNE’s Chase account.
s. On or about December 2, 2004, MUHAMMAD made
two deposits totaling $9,400 in cash into his account at New York
Community Bank.
t. On or about December 2, 2004, DRAKES
deposited approximately $9,400 in cash into her account at Chase.
u. On or about December 2, 2004, DRAKES wrote a
check for $9,000 from her Chase account made out to a co-
conspirator’s relative (“Relative-1”) with a memo indicating
“gift towards purchase of house.”
v. On or about December 3, 2004, MUHAMMAD wrote
a check for approximately $9,000 from his New York Community Bank
account to Relative-1 with a memo indicating “loan to purchase
house.”
w. On or about December 3, 2004, MOZER-BROWNE
deposited approximately $9,000 in cash into her account at Chase.
x. On or about December 3, 2004, MOZER-BROWNE
wrote a check for approximately $8,500 from her Chase account to
Relative-1 with a memo “gift to son for purchase of property.”
y. On or about December 17, 2004, MOZER-BROWNE
deposited approximately $9,000 into her checking account at
Chase.
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z. On or about December 17, 2004, MOZER-BROWNE
wired approximately $9,000 from her Chase checking account to
“Prominent Title Insurance.”
aa. On or about December 17, 2004, DRAKES
deposited approximately $9,130 in cash into her account at Chase.
bb. On or about December 17, 2004, DRAKES
transferred approximately $9,179.72 from her Chase checking
account to “Prominent Title Insurance.”
cc. On or about December 21, 2004, BROWNE
deposited approximately $9,228.44 into his savings account at
Washington Mutual Bank.
dd. On or about December 21, 2004, BROWNE
withdrew an official check for approximately $9,228.44 from his
savings account at Washington Mutual Bank made out to “Prominent
Title Insurance.”
ee. On or about January 13, 2005, MUHAMMAD
deposited approximately $5,000 in cash into his account at New
York Community Bank.
ff. On or about January 24, 2005, BROWNE
deposited approximately $8,000 in cash into his account at
Washington Mutual Bank.
gg. On or about January 27, 2005, BROWNE
deposited approximately $8,800 in cash into his account at a
Washington Mutual Bank branch in New York, New York.
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hh. On or about January 31, 2005, BROWNE
deposited approximately $5,000 in cash into his account at a
Washington Mutual Bank branch in New York, New York.
ii. On or about February 7, 2005, BROWNE
deposited approximately $9,000 in cash into his account at
Washington Mutual Bank.
jj. On or about February 7, 2005, DRAKES
deposited approximately $8,740 into her account at JPMorgan
Chase.
kk. On or about February 9, 2005, BROWNE
deposited approximately $9,000 in cash into his account at a
Washington Mutual Bank branch in New York, New York.
ll. On or about February 11, 2005, BROWNE
deposited approximately $8,500 in cash into his account at a
Washington Mutual Bank branch in New York, New York.
mm. On or about February 14, 2005, BROWNE
deposited approximately $9,000 in cash into his account at a
Washington Mutual Bank branch in New York, New York.
nn. On or about February 15, 2005, BROWNE
deposited approximately $6,500 in cash into his account at a
Washington Mutual Bank branch in New York, New York.
oo. On or about February 18, 2005, BROWNE
deposited approximately $9,000 in cash into his account at a
Washington Mutual Bank branch in Kissimmee, Florida.
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pp. On or about February 22, 2005, BROWNE
deposited approximately $7,600 in cash into his account at a
Washington Mutual Bank branch in New York, New York.
qq. On or about February 23, 2005, BROWNE
deposited approximately $9,000 in cash into his account at a
Washington Mutual Bank branch in New York, New York.
rr. On or about February 25, 2005, BROWNE
deposited approximately $8,800 in cash into his account at a
Washington Mutual Bank branch in New York, New York.
ss. On or about March 5, 2005, DRAKES wrote a
check to BROWNE from her JPMorgan Chase account for approximately
$8,500.
tt. On or about March 5, 2005, BROWNE deposited a
total of approximately $16,500 into his account at Washington
Mutual Bank.
uu. On or about March 14, 2005, BROWNE deposited
approximately $9,000 into his account at Washington Mutual Bank.
vv. On or about May 5, 2005, MUHAMMAD received a
transfer of approximately $8,500 into his account at New York
Community Bank from the account of Relative-1.
(Title 18, United States Code, Section 1956(h).)
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COUNT THREE
The Grand Jury further charges:
17. In or about October 2004, BEVERLY MOZER-BROWNE,
PHILLIP A. BROWNE, and WENDY HARRISON, the defendants,
unlawfully, willfully and knowingly uttered, used, possessed,
obtained, accepted and received immigrant and nonimmigrant visas,
permits, alien registration receipt cards, and other documents
prescribed by statute and regulation as evidence of authorized
stay and employment in the United States, knowing them to have
been procured by means of false claims and statements, and to
have been otherwise procured by fraud and unlawfully obtained, to
wit, the defendants obtained a green card for WENDY HARRISON by
submitting a forged marriage certificate and fraudulent financial
documents.
(Title 18, United States Code, Sections 1546 and 2.)
COUNT FOUR
The Grand Jury further charges:
18. In or about November 2004, BEVERLY MOZER-BROWNE,
PHILLIP A. BROWNE, and TASLEEM KUDRATH, the defendants,
unlawfully, willfully and knowingly uttered, used, possessed,
obtained, accepted and received immigrant and nonimmigrant visas,
permits, alien registration receipt cards, and other documents
prescribed by statute and regulation as evidence of authorized
stay and employment in the United States, knowing them to have
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been procured by means of false claims and statements, and to
have been otherwise procured by fraud and unlawfully obtained, to
wit, the defendants obtained a green card for TASLEEM KUDRATH by
submitting a forged marriage certificate and fraudulent financial
documents.
(Title 18, United States Code, Sections 1546 and 2.)
COUNT FIVE
The Grand Jury further charges:
19. In or about September 2004, BEVERLY MOZER-BROWNE,
PHILLIP A. BROWNE, and TULSI RAMRUP, the defendants, unlawfully,
willfully and knowingly uttered, used, possessed, obtained,
accepted and received immigrant and nonimmigrant visas, permits,
alien registration receipt cards, and other documents prescribed
by statute and regulation as evidence of authorized stay and
employment in the United States, knowing them to have been
procured by means of false claims and statements, and to have
been otherwise procured by fraud and unlawfully obtained, to wit,
the defendants obtained a green card for TULSI RAMRUP using a
forged marriage certificate and fraudulent financial documents.
(Title 18, United States Code, Sections 1546 and 2.)
COUNT SIX
The Grand Jury further charges:
20. In or about November 2004, BEVERLY MOZER-BROWNE,
PHILLIP A. BROWNE, and CHERYLENE RAMDASS, the defendants,
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unlawfully, willfully and knowingly uttered, used, possessed,
obtained, accepted and received immigrant and nonimmigrant visas,
permits, alien registration receipt cards, and other documents
prescribed by statute and regulation as evidence of authorized
stay and employment in the United States, knowing them to have
been procured by means of false claims and statements, and to
have been otherwise procured by fraud and unlawfully obtained, to
wit, the defendants obtained a green card for CHERYLENE RAMDASS
using a forged marriage certificate and fraudulent financial
documents.
(Title 18, United States Code, Sections 1546 and 2.)
COUNT SEVEN
The Grand Jury further charges:
21. In or about November 2004, BEVERLY MOZER-BROWNE,
PHILLIP A. BROWNE, and ADRIAN GOURSAHAB, the defendants,
unlawfully, willfully and knowingly uttered, used, possessed,
obtained, accepted and received immigrant and nonimmigrant visas,
permits, alien registration receipt cards, and other documents
prescribed by statute and regulation as evidence of authorized
stay and employment in the United States, knowing them to have
been procured by means of false claims and statements, and to
have been otherwise procured by fraud and unlawfully obtained, to
wit, the defendants obtained a green card for ADRIAN GOURSAHAB
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using a forged marriage certificate and fraudulent financial
documents.
(Title 18, United States Code, Sections 1546 and 2.)
COUNT EIGHT
The Grand Jury further charges:
22. In or about October 2004, BEVERLY MOZER-BROWNE,
PHILLIP A. BROWNE, and NIGEL DEFOUR, the defendants, unlawfully,
willfully and knowingly uttered, used, possessed, obtained,
accepted and received immigrant and nonimmigrant visas, permits,
alien registration receipt cards, and other documents prescribed
by statute and regulation as evidence of authorized stay and
employment in the United States, knowing them to have been
procured by means of false claims and statements, and to have
been otherwise procured by fraud and unlawfully obtained, to wit,
the defendants obtained a green card for NIGEL DEFOUR using a
forged marriage certificate and fraudulent financial documents.
(Title 18, United States Code, Sections 1546 and 2.)
COUNT NINE
The Grand Jury further charges:
23. In or about November 2004, BEVERLY MOZER-BROWNE,
PHILLIP A. BROWNE, and KERRY RAMPERSAD, the defendants,
unlawfully, willfully and knowingly uttered, used, possessed,
obtained, accepted and received immigrant and nonimmigrant visas,
permits, alien registration receipt cards, and other documents
21
prescribed by statute and regulation as evidence of authorized
stay and employment in the United States, knowing them to have
been procured by means of false claims and statements, and to
have been otherwise procured by fraud and unlawfully obtained, to
wit, the defendants obtained a green card for KERRY RAMPERSAD
using a forged marriage certificate and fraudulent financial
documents.
(Title 18, United States Code, Sections 1546 and 2.)
COUNT TEN
The Grand Jury further charges:
24. In or about November 2004, BEVERLY MOZER-BROWNE,
PHILLIP A. BROWNE, and MERVIN TRANCOSO, the defendants,
unlawfully, willfully and knowingly uttered, used, possessed,
obtained, accepted and received immigrant and nonimmigrant visas,
permits, alien registration receipt cards, and other documents
prescribed by statute and regulation as evidence of authorized
stay and employment in the United States, knowing them to have
been procured by means of false claims and statements, and to
have been otherwise procured by fraud and unlawfully obtained, to
wit, the defendants obtained a green card for MERVIN TRANCOSO
using a forged marriage certificate and fraudulent financial
documents.
(Title 18, United States Code, Sections 1546 and 2.)
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COUNT ELEVEN
The Grand Jury further charges:
25. In or about March 2005, BEVERLY MOZER-BROWNE,
PHILLIP A. BROWNE, and NARINE JAIRAM, the defendants, unlawfully,
willfully and knowingly uttered, used, possessed, obtained,
accepted and received immigrant and nonimmigrant visas, permits,
alien registration receipt cards, and other documents prescribed
by statute and regulation as evidence of authorized stay and
employment in the United States, knowing them to have been
procured by means of false claims and statements, and to have
been otherwise procured by fraud and unlawfully obtained, to wit,
the defendants obtained a green card for NARINE JAIRAM using a
forged marriage certificate and fraudulent financial documents.
(Title 18, United States Code, Sections 1546 and 2.)
COUNT TWELVE
The Grand Jury further charges:
26. In or about March 2005, BEVERLY MOZER-BROWNE,
PHILLIP A. BROWNE, and NATASHA HERCULES, the defendants,
unlawfully, willfully and knowingly uttered, used, possessed,
obtained, accepted and received immigrant and nonimmigrant visas,
permits, alien registration receipt cards, and other documents
prescribed by statute and regulation as evidence of authorized
stay and employment in the United States, knowing them to have
been procured by means of false claims and statements, and to
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have been otherwise procured by fraud and unlawfully obtained, to
wit, the defendants obtained a green card for NATASHA HERCULES
using a forged marriage certificate and fraudulent financial
documents.
(Title 18, United States Code, Sections 1546 and 2.)
COUNT THIRTEEN
The Grand Jury further charges:
27. In or about March 2005, BEVERLY MOZER-BROWNE,
PHILLIP A. BROWNE, and ANNEKA RAMPERSAD, the defendants,
unlawfully, willfully and knowingly uttered, used, possessed,
obtained, accepted and received immigrant and nonimmigrant visas,
permits, alien registration receipt cards, and other documents
prescribed by statute and regulation as evidence of authorized
stay and employment in the United States, knowing them to have
been procured by means of false claims and statements, and to
have been otherwise procured by fraud and unlawfully obtained, to
wit, the defendants obtained a green card for ANNEKA RAMPERSAD
using a forged marriage certificate and fraudulent financial
documents.
(Title 18, United States Code, Sections 1546 and 2.)
FIRST FORFEITURE ALLEGATION
28. As the result of committing the visa fraud
conspiracy offense in violation of Title 18, United States Code,
Sections 371 and 1546, alleged in Count One of this Indictment,
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BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, SANDFORD BROWNE, a/k/a
“Tyson,” GERRARDA BROWNE, a/k/a “Gerry,” WILLIANA BROWNE, JOHN
LOFTON, a/k/a “Big John,” PETER ABSOLAM, a/k/a “Lloyd,” KEITH
MAHASE, ABDUL HAKIM MUHAMMAD, TIFFANY WAYMAN, NARRISA JEREMIAH,
JAMSHEED JEREMIAH, a/k/a “Jason,” KHADIGA CLARKE, a/k/a “Kelly,”
LENNARD PRESCOD, a/k/a “Bob,” MAKEBA ISAROON, RHONDA EATON,
RODERICK CHASSEAU, CAMERON A. LLOYD, and KWASI DRAKES, the
defendants, shall forfeit to the United States pursuant to Title
18, United States Code, Section 982(a)(6)(A), all property, real
or personal, that constitutes, or is derived from or is traceable
to the proceeds obtained directly or indirectly from the
commission of the offense, and all property, real or personal,
that was used to facilitate, or was intended to be used to
facilitate, the commission of the offense, including but not
limited to the following:
a. A sum of money of at least $1 million in
United States currency, representing the amount of proceeds
obtained as a result of the conspiracy to commit visa fraud, for
which the defendants are jointly and severally liable.
b. All that lot or parcel of land, together with
its buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 951 Nancy Court, Kissimmee, Florida.
c. All that lot or parcel of land, together with
its buildings, appurtenances, improvements, fixtures, attachments
25
and easements, located at 373 Aylesbury Court, Kissimmee,
Florida.
d. All that lot or parcel of land, together with
its buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 4414 Canopy Court, Kissimmee, Florida.
e. All that lot or parcel of land, together with
its buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 4418 Canopy Court, Kissimmee, Florida.
f. All that lot or parcel of land, together with
its buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 4430 Canopy Court, Kissimmee, Florida.
g. All that lot or parcel of land, together with
its buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 267 Magellan Drive, Kissimmee, Florida.
h. All that lot or parcel of land, together with
its buildings, appurtenances, improvements, fixtures, attachments
and easements, located at Lot E-5, Alpine Lake, Pocono Township,
Monroe County, Pennsylvania.
SECOND FORFEITURE ALLEGATION
29. As the result of committing the money laundering
conspiracy offense in violation of Title 18, United States Code,
Section 1956(h), alleged in Count Two of this Indictment, BEVERLY
MOZER-BROWNE, PHILLIP A. BROWNE, ABDUL HAKIM MUHAMMAD, and KWASI
DRAKES, the defendants, shall forfeit to the United States
26
pursuant to Title 18, United States Code, Section 982(a)(1), all
property, real and personal, involved in the money laundering
offense and all property traceable to such property, including
but not limited to the following:
a. A sum of money of at least $1 million in
United States currency, representing the amount of property
involved in the money laundering conspiracy, or traceable to such
property, for which the defendants are jointly and severally
liable.
b. All that lot or parcel of land, together with
its buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 951 Nancy Court, Kissimmee, Florida.
c. All that lot or parcel of land, together with
its buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 373 Aylesbury Court, Kissimmee,
Florida.
d. All that lot or parcel of land, together with
its buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 4414 Canopy Court, Kissimmee, Florida.
e. All that lot or parcel of land, together with
its buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 4418 Canopy Court, Kissimmee, Florida.
27
f. All that lot or parcel of land, together with
its buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 4430 Canopy Court, Kissimmee, Florida.
g. All that lot or parcel of land, together with
its buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 267 Magellan Drive, Kissimmee, Florida.
h. All that lot or parcel of land, together with
its buildings, appurtenances, improvements, fixtures, attachments
and easements, located at Lot E-5, Alpine Lake, Pocono Township,
Monroe County, Pennsylvania.
THIRD FORFEITURE ALLEGATION
30. As the result of committing the visa fraud
offenses in violation of Title 18, United States Code, Sections
1546 and 2, alleged in Counts Three through Thirteen of this
Indictment, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, WENDY
HARRISON, TASLEEM KUDRATH, TULSI RAMRUP, CHERLYENE RAMDASS,
ADRIAN GOURSAHAB, NIGEL DEFOUR, KERRY RAMPERSAD, MERVIN TRANCOSO,
NARINE JAIRAM, NATASHA HERCULES, and ANNEKA RAMPERSAD, the
defendants, shall forfeit to the United States pursuant to Title
18, United States Code, Section 982(a)(6)(A), all property, real
or personal, that constitutes, or is derived from or is traceable
to the proceeds obtained directly or indirectly from the
commission of the offense, and all property, real or personal,
28
that was used to facilitate, or was intended to be used to
facilitate, the commission of the offense.
Substitute Asset Provision
31. If any of the forfeitable property described in
the foregoing Forfeiture Allegations, as a result of any act or
omission of the defendants:
(1) cannot be located upon the exercise of due
diligence;
(2) has been transferred or sold to, or deposited
with, a third person;
(3) has been placed beyond the jurisdiction of the
Court;
(4) has been substantially diminished in value; or
(5) has been commingled with other property which
cannot be subdivided without difficulty;
it is the intent of the United States, pursuant to 18 U.S.C.
§ 982(b), to seek forfeiture of any other property of said
defendants up to the value of the above forfeitable property.
(Title 18, United States Code, Sections 371, 982, 1546 and 1956.)
FOREPERSON MICHAEL J. GARCIA
United States Attorney