Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 1 of 28 UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA.

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1 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 1 of 28 DJF:JJT:nl UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA UNITED STATES OF AMERICA v. ) ) ) ) Defendant. ) RAYMOND OLIVER KRAFT, JR., INDICTMENT ) CRIMINAL NO. r~\ ~ -C tz-cjs- I ) c RA-m~ COUNTS 1 THROUGH 22,J.) PER_ WIRE FRAUD (Title 18, United States Code, Section 1343) THE GRAND JURY CHARGES: At times material to this Indictment: INTRODUCTION FILED HARRISBURG, PA JUL b,y/ EPlJTYCLERK 1. The defendant, Raymond Oliver Kraft, Jr., was President, manager, and sole owner of WiseKraft Solutions, L.L. C., a financial consulting business located in York, Pennsylvania. On October 31, 2011, Kraft registered WiseKraft Solutions with the Pennsylvania Corporation Bureau. Kraft controlled all aspects of the operation of WiseKraft Solutions, including marketing, financial decisions, and

2 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 2 of 28 client relations. Kraft is not registered as an investment advisor with either the U.S. Securities and Exchange Commission or the Pennsylvania Department of Banking and Securities. 2. On WiseKraft Solutions' website, Kraft marketed WiseKraft Solutions as a financial consulting business that provided clients with financial planning, business management, bill paying, banking services, tax preparation, and estate administration. On the website, Kraft further represented that he was President and Founding Member, a graduate of the University of Baltimore, and that he attended "National Trust School." Kraft represented that he had more than thirty years banking experience, trust administration, estate administration, retirement planning, and financial consulting. According to the website, WiseKraft Solutions "upheld the highest standards in business and security" and that clients could ''trust the friendly professionals at WiseKraft." 3. Kraft marketed WiseKraft Solutions' financial services in several states, including Maryland, Pennsylvania, Delaware, West Virginia, Virginia, and Washington, D.C. The company employed one person,_ an office manager. -2-

3 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 3 of 28 WISEKRAFT CLIENTS AND FINANCIAL PLANNING, MANAGEMENT, AND CONSULTING AGREEMENT 4. As a financial planner, Kraft had access to and handled financial accounts for numerous clients, including the following clients: a. S.C.; is a woman who is more than 68 years old and resides in York County, Pennsylvania; b. L.B. and V.B., are a married couple, both of whom are more than 70 years old and reside in Maryland; c. D.J., is a man who resides in New York; d. S.L., is a woman who is more than 70 years old and resides in York County, Pennsylvania; e. D.B., is a woman who is more than 85 years old and resides in York, Pennsylvania; and f. B.A.P. Irrevocable Trust, is a trust created in the Commonwealth of Pennsylvania for which WiseKraft was the appointed Trustee. 5. Kraft represented to customers, including customers listed in Paragraphs 4a through 4f above, that he would manage their financial accounts and advise them about the financial benefits of -3-

4 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 4 of 28 investments, including investment in private placement notes, certificates of deposits, and real estate. 6. Beginning in or about March 2012, WiseKraft Solutions entered into "Financial Planning, Business Management, and Consulting Agreement" with several clients, including clients S.C., L.B., V.B., S.L., D.B., and D.J. According to the Financial Planning Agreement, WiseKraft Solutions was to provide the client with "financial planning, business management, andlor consulting services as designated by the client on annexed Schedule A." Schedule A stated that WiseKraft Solutions would provide (1) "non-brokerage asset management defined under this agreement as promissory notes, savings bonds, annuities, life insurance policies... "; and (2) "Quick Books, business-related functions, and assistance with tax preparation!reporting." 7. According to Schedule A, WiseKraft Solutions' fee was 1 % of all managed assets. Kraft represented to clients and others that he did not receive a commission for the services rendered by WiseKraft Solutions. -4-

5 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 5 of 28 THE BANK ACCOUNTS USED BY DEFENDANT KRAFT 8. In addition to entering into Financial Planning Agreements with each client, from. in or about March 2012, through in or about July 25, 2014, Kraft opened several Fulton Bank accounts, including WiseKraft Solutions "For Benefit Of'' (FBO) accounts for the following customers: S.C., L.B., V.B., D.J., S.L., and D.B. Kraft also opened a Fulton Bank Account for B.A.P. Trust. 9. The clients did not have an ownership interest or signature authority on any ofthe accounts. Kraft was the sole owner and signatory on all of these accounts except the D.J~.FBO account. Kraft, not his clients, received Fulton Bank statements for each account. In addition to the "For Benefit Of'' accounts, Kraft also opened WiseKraft Solutions operating and payroll accounts with Fulton Bank. 10. In or about April 2015, Fulton Bank questioned Kraft about the legitimacy of certain financial transactions involving the FBO accounts. Kraft represented to Fulton Bank that he owned the FBO accounts and managed the. accounts "For the Benefit Of' 1 the client whose name appeared on the account. -5-

6 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 6 of In or about April 15, 2015, Kraft falsely represented to Fulton Bank that clients did not pay him commissions, but rather Kraft received asset-based fees for rendering financial consultant services to clients. 12. In or about April 15, 2015, Kraft falsely represented to Fulton Bank that he invested client funds in private placement notes secured by property liens and that at least ninety percent of the private placement notes were secured. 13. In or about June 2015, Fulton Bank notified Kraft that Fulton Bank was closing all WiseK.raft Solutions' FBO accounts. 14. In or about June 2015, Fulton Bank sent a letter to several WiseK.raft Solution clients advising them the bank was closing the FBO accounts and suggesting to them that they have an accountant review their accounts. 15. In response to the letters from Fulton Bank to his clients, Kraft sent s to clients stating that Fulton Bank was retaliating against Kraft due to disagreements and that Kraft has always had his clients' interest at heart and that he worked to protect client investments. -6-

7 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 7 of Because Fulton Bankwas closing all WiseK.raft Solutions' accounts, in or about April 2015, Kraft attempted to open WiseK.raft Solutions FBO accounts at York Traditions Bank for the purpose of transferring FBO funds from Fulton Bank to York Traditions Bank. 17. In or about April 2015, York Traditions Bank questioned Kraft about the legitimacy of opening FBO accounts in which the client had no ownership of, but which bore the client's name. In the place of FBO accounts, Kraft opened a WiseK.raft Solutions Reserve Account. with York Traditions Bank. Kraft transferred the client funds from the Fulton Bank FBO accounts to the York Traditions Bank WiseK.raft Solutions Reserve Account. Kraft also opened a WiseK.raft Solutions' operating and payroll account with York Traditions Bank, both of which Kraft used to funnel misappropriated client funds. THE SCHEME 18. From in or about 2011, to in or about February 2018, Kraft devised and intended to devise a sche:r:p.e to defraud clients of WiseKraft Solutions and to obtain money and property by means of false and fraudulent pretenses, representations, and promises and concealment of material facts. -7-

8 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 8 of 28 MANNER AND MEANS It was part of the scheme that: 19. Kraft solicited from clients more than $1,000,000 under false pretenses, did not invest clients' funds as promised, and concealed from clients material facts, such as Kraft's use of clients' funds to pay WiseKraft Solutions operating expenses, Kraft's personal expenses, and clients whom Kraft had previously defrauded. CLIENT S.C. 20. From on or about July 23, 2014, to on or about August 27, 2014, Kraft induced S.C. to transfer $75,000 from S.C.'s Wells Fargo affiliated broker account to the Fulton Bank FBO S. C. Account by falsely representing that the money was going to be used for legitimate investments. 21. From on or about July 23, 201.4, to on or about August 28, 2014, Kraft transferred $66,000 from the FBO S.C. account to the Fulton Bank WiseKraft Solutions operating account and embezzled the $66,000 by making ATM withdrawals, credit card payments, checks payable to Kraft, payments for WiseKraft Solutions' operating expenses, including rent payments. -s-

9 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 9 of On or about December 8, 2014, Kraft induced S.C. to transfer $150,000 from S.C.'s Raymond James brokerage account to the S.C. FBO account by falsely representing that the money was going to be used for legitimate investments. Between on or about December 8, 2014, and January 28, 2015, Kraft embezzled approximately $110,000 of the $150,000 by transferring funds'from the S.C. FBO account to the WiseKraft operating and payroll accounts, and used these S. C. 's funds for his own personal and business purposes. 23. On or about February 10, 2015, Kraft deposited an $80,000 check from D.S. Investor Properties made payable to S.C. into the FBO S.C. account. 24. From on or about February 11, 2015, to on or about March.. 23, 2015, Kraft embezzled $70,000 of the $80,000 by transferring $70,000 from the FBO S.C. account into the WiseKraft Solutions' operating account, and withdrawing these funds for his own personal and business expenses.. CLIENTS L.B. AND V.B. 25. From on or about February 1, 2013, through on or about October 27, 2014, L.B. and V.B. wrote 5 checks totaling $90,000 that -9-

10 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 10 of 28 were deposited into FBO L.B. and V.B. account. In addition, from on or about February 1, 2013, to on or about June 24, 2014, there were 6 transfers from L.B. and v~b.'s First Clearing account totaling $200,000 deposited into the FBO L.B. and V.B. account. Kraft falsely represented that these funds were going to be used for legitimate investments 26. From on or about February 1, 2013, through on or about November 28, 2014, Kraft initiated 18 fund transfers from the FBO L.B. and V.B. account to WiseKraft Solutions operating account No These fund transfers totaled $241,500. On or about January 14, 2014, Kraft wrote a $30,000 check drawn on FBO L.B. and V.B. account and deposited it into the WiseKraft Solutions' operating account. Kraft used these funds to pay himself a commission, WiseKraft Solutions' busine.ss expenses, and personal expenses. 27. Of the $290,000 d~posited into the FBO L.B. and V.B. account, oply approximately $11,000 was used for the benefit of ~.B. and V.B. L.B. and V.B. were unaware of the transfers from the FBO L.B. and V.B. account to the WiseKraft Solutions operating account. L.B. and V.B. were also unaware that Kraft used the transferred funds. - to pay himself a commission, business expenses, and personal expenses. -10-

11 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 11 of 28 CLIENT D.J. 28. From on or about March 4, 2014, to on or about May 2, 2014, there 3 wire transfers made from D.J.'s First Clearing account to the Fulton Bank FBO D.J. account totaling $150,000. From on or about March 14, 2014, to on or about May 14, 2014, Kraft initiated 6 transfers from the FBO D.J. account to Fulton Bank WiseKraft Solutions' operating account No totaling $140, Immediately after the transfers and checks were received in the WiseKraft Solutions operating account, Kraft made numerous transfers to other client accounts. The transfers to other client accounts were in $5, 000 increments. In addition to the transfers to client accounts, Kraft used the funds from the FBO D.J. account for business expenses, ATM withdrawals, and commission checks to Kraft. CLIENTD.B. 30. From on or about April 15, 2013, to on or about February 7, 2014, D.B. gave Kraft 5 checks totaling $175,000 for the purpose of investing. Kraft deposited these checks into the WiseKraft Solutions Operating Account No held at Fulton Bank..These checks funded WiseKraft Solutions' business expenses, payments to other -11-

12 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 12 of 28 clients, payments to Kraft and ATM withdrawals. D.B. was not aware of, and did not authorize Kraft to use her funds for any of these expenses. 31. On or about April 20, 2016, D.B. gave Kraft a check in the amount of $10,000. Kraft deposited this check into the WiseK.raft Solutions Reserve account No held at York Traditions Bank. Unbeknownst to D.B., these checks funded WiseK.raft Solutions' business expenses and repayments to clients Kraft had previously defrauded. 32. On or about October 31, 2016, D.B. gave Kraft a check in the amount of $50,000 with the understanding that Kraft was going to purchase certificates of deposit. Without D.B.'s knowledge and authority, Kraft deposited this check into a DS Investor Properties LLC Account No held at York Traditions Bank. DS Investor Properties LLC is a business owned by Kraft that deals in real estate investments. Kraft was the sole signor on the account. At the time of deposit the DS Investor Properties LLC account was overdrawn. The $50, 000 deposit funded renovations to properties, American Express payments, and $37,326 in payments to Kraft. ' -12-

13 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 13 of 28 CLIENTS.L. 33. On or about August 29, 2016, a check for $120,000 from Merrill Lynch payable to S.L. was deposited into the WiseKraft Solutions Reserve Account No held at York Traditions Bank. Prior to the deposit the WiseKraft Solutions Reserve Account had a balance of $1, From on or about August 29, 2016, to on or about September 21, 2016, Kraft made 5 transfers totaling $63,000 from WiseKraft Solutions' Reserve Account to the WiseKraft Solutions' Operating Account No held at York Traditions Bank. These transfers funded WiseKraft Solutions business expenses, payments to other clients, and payments to Kraft. 35. From on or about August 30, 2016, to on or about September 15, 2016, Kraft wrote 5 checks drawn on WiseKraft Solutions Reserve totaling $57,500. These checks included payments to other clients. CLIENT B.A.P. TRUST 36. B.A.P. died on or about June 15, Kraft was the executor of the B.A.P. Estate. The B.A.P. Trust documents dated -13-

14 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 14 of 28 March 6, 2006, names WiseKraft Solutions LLC as the Primary Trustee. 37. On or about September 30, 2015, the B.A.P. Trust Account No held at York Traditions Bank re~eived a $750,000 deposit resulting from the life insurance payout from Lincoln National Life Insurance Company. On or about November 30, 2015, the B.A.P. Trust Account No received an additional $9, deposit from the Lincoln National Life Insurance Company. 38. From on or about October 19, 2015, to on or about July 22, 2016, Kraft made 8 transfers totaling $115, from the B.A.P. Trust account No to the WiseKraft Solutions Operating account No held at York Traditions Bank. On or about January 26, 2016, Kraft Transferred $50,000 from the B.A.P. Trust account No to the WiseKraft Solutions Reserve account No held at York Traditions Bank. On or about December 29, 2015, Kraft wrote a $100,000 check drawn on the B.A.P. Trust account No and deposited the check in the WiseKraft Solutions Reserve account No These deposits into the WiseKraft Solutions' Operating -14-

15 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 15 of 28 Account and WiseKraft Solutions Reserve Account funded WiseKraft Solutions' business expenses, repayments to clients previously defrauded, and payments to Kraft. CLIENT R.K. TRUST 39. Kraft was the trustee of the R.K. GST Exempt Trust and the R.K. GST Non-Exempt Trust. On or about July 10, 2012, Kraft opened checking accounts for both trusts at Fulton Bank. 40. The Exempt Trust was funded on or about July 24, 2012 with a $82, wire transferred from Wells Fargo. 41. On or about August 23, 2012, Kraft wrote a $50,000 check drawn on the Exempt Trust account to WiseKraft Solutions' operating account. Kraft noted "Prom Nt" on the memo line of the check. Kraft deposited the $50,000 check into the WiseKraft Solutions' operating account No held at Fulton Bank. 42. The $50, 000 deposit funded transfers and checks from WiseKraft Solutions' operating account No , including a $16,000 note to A.W., $7,500 to Kraft's personal account, $8,000 to D.S., $5,000 to Hobbie Stop Multi Shop, $3,000 towards a Kraft credit card. -15-

16 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 16 of 28 payment, $1, to Sleepy 1 s mattres.s store, and $1,085 to Journal Multimedia The Non-Exempt Trust was funded on or about July 25, 2012, with a $37, wire transfer from Wells Fargo and on or about August 17, 2012, with a $58, check from Lakeside Title Company. 44. On or about August 22, 2012, Kraft wrote a $55,000 check drawn on the Non-Exempt Trust account to WiseKraft Solutions. Kraft noted "Prom Nt 11 on the memo line of the check. Kraft deposited the $55,000 check into the WiseKraft Solutions operating account No held at Fulton Bank. 45. On or about August 27, 2012 Kraft Transferred $55,000 from WiseKraft Solutions 1 operating account No... ~21787 to the FBO L.B. and V.B. account. 46. Subsequently, Kraft made transfers and check transactions from the FBO L.B. and V:B. account to WiseKraft Solutions 1 operating account No , including $12,500 on September 14, 2012; $30,000 on October 1, 2012; $10,000 on October 4,

17 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 17 of The three transactions totaling $52,500 from the FBO L.B. and V.B. account to WiseKraft Solutions' operating account No funded the following transfers and checks from WiseKraft Solutions' operating account No... ; : $11,000 to Kraft's personal account, $7,000 to D.S., $15,000 to Hobbie Stop Multi Shop, $11,000 to B.A.P. Trust, and $6,066 to Rittenhouse Square Park, LLC. 48. On or about April 19, 2013, Kraft began making deposits into the R.K. GST Exempt Trust account from the WiseKraft Solutions operating account No From on or about April 19, 2013 through on or about June 19, 2015, Kraft made 22 transfers from WiseKraft Solutions' operating account No to the R.K. Exempt Trust account totaling $102, Kraft initiated the transfers when the Exempt Trust was either overdrawn or close to depletion as a result of Kraft's embezzlement of Trust funds. 49. The source of the funds transfer from the WiseKraft Solutions' operating account No to the R.K. Exempt Trust account were f1:1.nd, in part, from the following accounts: FBO L.B. and V.B., FBO S.C., FBO J.P.B.H., J.D.W. Landscaping, B.A.P. Trust, and L.P.B. Trust. -17-

18 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 18 of 28 CLIENT C.C. 50. In or around January of 2016, Kraft received a check drawn on the bank account of Doyle New York Auctions. The check was C.C.'s proceeds of the sale of a rare piece of furniture. C.C. requested Kraft to invest thefunds for C.C. On or about January 25, 2016, Kraft deposited a $80, check from Doyle New York Auctfoneers into the WiseKraft Solutions LLC Reserve Account No held at York Traditions Bank. This deposit was comingled with an existing balance of $53, and with two other large deposits the next day totaling $150, By on or about July 26, 2016, the WiseKraft Solutions LLC Reserve Account was drawn down to a balance of $1, The transactions that depleted the account consisted of $142, in transfers to the WiseKraft Solutions LLC Operating Account No , $15,000 in transfers to the WiseKraft Solutions LLC Payroll Account No , $81, paid to other WiseKraft Solutions LLC clients, $56,000 in checks to C.C.'s father, $5,000 to C.C.'s spouse and a $5,000 check to Kraft. Client C.C. was not aware of, and did not authorize any of these payments. -18-

19 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 19 of On or about November 6, 2016, Kraft offered to purchase and lease a house for C.C. On or about December 16, 2016, Kraft purchased a property located in Rehoboth Beach, Delaware, with an $80, cashier's check drawn on the WiseKraft Solutions LLC Reserve Account. Kraft listed CCMC LLC as the owner of the property. Kraft registered with the Delaware Corporation bureau on or about December 7, The $80, cashier check Kraft used to purchase the property for C. C. was funded with the proceeds of the sale of a different house that S.C., L.B., V.B., and D.J. invested in. S.C., L.B., V.B, and D.J. were not aware of, and did not authorize the use of their money to purchase a home for C.C. 54. Kraft informed C.C. that the $80, investment from the sale of the rare piece of furniture had been depleted. C.C. asked Kraft for an accounting of the investment transactions. On or about February 20, 2018, Kraft provided C.C. with a document that falsely indicated that $80, 000 of C. C. 's investment had been used to purchase the Rehoboth Beach, Delaware, house that C. C. is renting from Kraft. -19-

20 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 20 of 28 STATUTORY ALLEGATION 55. The allegations contained in Paragraphs 1 through 54 are incorporated here. 56. From in or about 2012, until in or about 2016, in the Middle District of Pennsylvania and elsewhere, the defendant, RAYMOND OLIVER KRAFT, JR., knowingly and willfully devised and intended to devise a scheme and artifice to defraud and to obtain money and property by means of materially false and fraudulent pretenses, representations, and promises, and for the purpose of executing the scheme and artifice to defraud and obtain money and property, and attempting to do so, did on the dates specified below, transmit by means of wire communication in interstate and foreign commerce, certain writings, signs, signals, pictures, and sounds as described in each count below: Count Date Wired From Account Wired To Account Amount 1 12/12/2013 SC First Clearing Credit Acct No. XXXXXX:X:3021 FBO SC Fulton Bank Acct No. XX:XX6644 $10,

21 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 21 of 28 Count Date Wired From Account Wired To Account Amount 2 3/4/ /23/ /27/ /8/2014 SC First Clearing Credit Acct No. XXXXX:XX3021 SC First Clearing Credit Acct No. XXXXXXX:3021 SC First Clearing Credit Acct No. XXXXXXX3021 L VB Wells Fargo Acct No. X:XXX9098 FBO SC Fulton Bank Acct No. XXXX6644 $25, FBO SC Fulton Bank Acct No. XXXX , FBO SC Fulton Bank Acct No. XXXX , FBO SC Fulton Bank Acct No. XXXX , L VB First Clearing 6 2/1/2013 Credit No. XXXX:XXX6151 L VB First Clearing 7 9/3/2013 Credit No. XXXX:XXX6151 L VB First Clearing 8 9/3/2013 Credit No. XXXX:XXX6151 L VB First Clearing 9 1/14/2014 Credit No. XXXX:XXX6151 L VB First Clearing 10 3/4/2014 Credit No. XXXX:XXX6151 L VB First Clearing 11 6/24/2014 Credit No. XXXX:XXX6151 FBO LVB Fulton Bank Acct No. XXXX , FBO L VB Fulton Bank Acct No. XXXX , FBO LVB Fulton Bank Acct No. :XXXX , FBO L VB Fulton Bank Acct No. XXXX , FBO L VB Fulton Bank Acct No. X:XXX , FBO L VB Fulton Bank Acct No. X:XXX , /4/2014 DJ First Clearing Credit No. XXXX:XXX FBO DJ Fulton Bank Acct No. X:XXX ,000.00

22 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 22 of 28 Count Date Wired From Account Wired To Account Amount 13 4/23/2014 DJ First Clearing Credit No. XXXXXXX4981 FBO DJ Fulton Bank Acct No. XXXX5731 $50, /2/2014 DJ First Clearing Credit FBO DJ Fulton Bank No. XXXXXXX4981 Acct No. XXXX , /9/2013 DJ First Clearing Credit No. XXXXXXX4981 FBO DJ Fulton Bank Acct No. XXXX , B.A.P. Trust"York 10/19/2015 Traditions Bank Acct No. XXXX5726 B.A.P. Trust York 10/19/2015 Traditions Bank Acct No. XXXX5726 B.A.P. Trust York 10/19/2015 Traditions Bank Acct No. XXXX5726 B.A.P. Trust York 5/27/2016 Traditions Bank Acct No. XXXX:5726 B.A.P. Trust York 6/14/2016 Traditions Bank Acct No. XXXX:572 6 B.A.P. Trust York 7/22/2016 Traditions Bank Acct No. XXXX:5726 B.AP. Trust York 1/26/2016 Traditions Bank Acct No. XXXX:5726 York Traditions Bank Acct No. XXXX , York Traditions Bank Acct No. XX:XX1833 8, York Traditions Bank Acct No. XX:XX1833 8, York Traditions Bank Acct No.XXXX1833 9, York Traditions Bank Acct No. XXXX1833 7, York Traditions Bank Acct No. XXXX:l833 20, York Traditions Bank Acct No. XXXX: , All iri violation of Title 18, United States Code, Section

23 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 23 of 28 COUNTS 23 THROUGH 26 MAIL FRAUD-PLACED IN AN AUTHORIZED DEPOSITORY FOR DELIVERY BY MAIL (Title 18, United States Code, Section 1341) THE GRAND JURY FURTHER CHARGES: 57. The allegations contained in Paragraphs 1 through 54 of this Indictment are incorporated here. 58. On or about the dates set forth below, in the Middle District of Pennsylvania and elsewhere, for the purp.ose of executing or attempting to execute the above-described scheme and artifice to defraud and deprive, the defendant, RAYMOND OLIVER KRAFT, JR., knowingly and willfully devised and intended to devise a scheme and artifice to defraud, and to obtain money and property by means of materially false and fraudulent pretenses, representations, and promises and for the purpose of executing the scheme and artifice to defraud and to obtain money and property and attempting to do so, did on or about the dates specified below cause to he placed in post offices and authorized depos_itories for mail matter the particular item(s) described in each count below, to be sent and delivered by the Unit~d -23-

24 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 24 of 28 States Postal Service and to be delivered by mail according to the directions thereon, and at the places at which they were directed to be delivered, by the person to whom it was addressed, as more fully set. forth below: Count Date Check Sent From Check Deyosited Into Account Amount WiseKraft Solutions LLC FBO Coastal Equities 23 5/6/2013 LVB Fulton Bank Acct No. $10, Inc. XXXX6653 WiseKraft Solutions LLC FBO Coastal Equities 24 5/6/2013 LVB Fulton Bank Acct No. 5, Inc. XXXX6653 WiseKraft Solutions LLC FBO 25 10/27/2014 LB;VB LVB Fulton Bank Acct No. 15, XXXX6653 WiseKraft Solutions LLC FBO 26 10/27/2014 LB;VB LVB Fulton Bank Acct No. 10, XXXX6653 All in violation of Title 18, United States Code, Section COUNTS 27 THROUGH 58 MONEY LAUNDERING (Title 18, United States Code, Section 1956) THE GRAND JURY FURTHER CHARGES:. 59. Paragraphs 1 through 54 above are incorporated here. -24-

25 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 25 of On or about the dates listed below, in the Middle District of Pennsylvania and elsewhere, the defendant, RAYMOND OLIVER KRAFT, JR., knowing that the property involved in a financial transaction listed below represented proceeds of some form of unlawful activity, conducted and caused to be conducted a financial transaction (1) with the intent to promote the carrying on of the specified unlawful activity; and (2) knowing that the transaction was designed in whole or in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of_ specified unlawful activity, which was wire fraud, in violation of Title 18, United States Code, Section 1343, and each transaction affecting interstate commerce, in that defendant. transferred and caused to be transferred funds from the bank accounts at the financial institutions identified below. Transfer To Transfer From Wise Kraft Count Date WiseKraft Solutions Solutions LLC Amount LLC Account No. Fulton Bank Account No. 27 7/23/2014 SC Fulton Bank Acct No. XX:XX6644 No. XX:XX-Xl 787 $25,

26 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 26 of 28 Transfer To Count Date Transfer From WiseKraft WiseKraft Solutions Solutions LLC LLC Account No. Fulton Bank Amount Account No. 28 8/5/ /15/ /20/ /22/ /25/ /28/ /8/2014 SC Fulton Bank Acct No. XXXX6644 SC Fulton Bank Acct No. XXXX6644 SC Fulton Bank Acct No. XXXX6644 SC Fulton Bank Acct No. XXXX6644 SC Fulton Bank Acct No. XXXX6644 SC Fulton Bank Acct No. XXXX6644 SC Fulton Bank Acct No. XXXX6644 No. XXXX-Xl 787 $10, No. XXXX-Xl 787 5, No. XXXX-Xl 787 3, No. XXXX-X1787 2, No. XXXX-Xl 787 1, No. XXXX-Xl , No. XXXX-X , /8/2014 Acct No. XXXX X1644 No. XXXX-Xl , ' SC Fulton Bank Acct 12/24/2014 No. XXXX-Xl , No. XXXX /2/ /13/ /28/ /11/ /17/2015 SC Fulton Bank Acct No. XXXX6644 SC Fulton Bank Acct No. XXXX6644 SC Fulton Bank Acct No. XXXX6644 SC Fulton Ban,k Acct No. XXXX6644 SC Fulton Bank Acct No. XXXX No. XXXX X , No. XXXX Xl , No. XXXX-X , No. XXXX-Xl , No. XXXX-Xl ,000.00

27 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 27 of 28 Transfer To Transfer From WiseKraft Count Date WiseKraft Solutions Solutions LLC Amount LLC Account No. Fulton Bank Account No. 42 3/23/ /1/ /9/ /3/ /17/ /22/2013 SC Fulton Bank Acct No. XXXX6644 L VB Fulton Bank Acct No. XXXX6653. LVB Fulton Bank Acct No. XXXX6653 L VB Fulton Bank Acct No. XXX:X6653 L VB Fulton Bank Acct No. XXXX6653 L VB Fulton Bank Acct No. XXXX6653 No. XXXX-X1787 $10, No. XXXX-Xl , No. XXXX-X , No. XXXX-X , No. XXXX-X , No. XXXX-Xl , L VB Fulton Bank Acct 1/14/2014 No. XX:XX Check No. XXXX-Xl , i/27/ /4/ /26/ /28/ /14/ /20/2014 LVB Fulton Bank Acct No. XXX:X6653 LVB Fulton Bank Acct No. XXX:X6653 LVB Fulton Bank Acct No. XXX:X6653 L VB Fulton Bank Acct No. XXX:X6653 DJ Fulton BankAcct No. XXXX5731 DJ Fulton Bank Acct No. XXXX5731 No. XXXX-X , No. XXXX-Xl , No. XXXX-Xl , No. XXXX-Xl , No. XXXX-X , No. XXXX-X ,

28 Case 1:18-cr SHR Document 3 Filed 07/25/18 Page 28 of 28 Transfer To Transfer From WiseKraft Count Date WiseKraft Solutions Solutions LLC Amount LLC Account No. Fulton Bank Account No. 55 4/23/ /29/ /2/ /14/2014 DJ Fulton Bank Acct No. XXXX5731 DJ Fulton Bank Acct No. XXX:X5731 DJ Fulton Bank Acct No. XXXX5731 DJ Fulton Bank Acct No. XXXX5731 No. XXX:X-Xl 787 $30, No. XXX:X-Xl , No. XXX:X-Xl , No. XXX:X-Xl , All in violation of Title 18, United States Code, Sections 1956(a)(l) (A)(i) and (B)(i). A TRUE BILL FOREPERSON, GRAND JURY.DAVID J. FREED. UNITED STATES ATTORNEY I By:_, JOSEPH... TERZ ASSISTAN U.S. ATTORNEY '- 1 i~c 1~1[? DATE J -28-