IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS (KANSAS CITY DOCKET) STATES OF AMERICA, ) ) ) ) ) ) ) )

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1 I'.,. \S UNITED IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS (KANSAS CITY DOCKET STATES OF AMERICA, Plaintiff, v. No. qo B'=>- o \ SCOTT ALAN TUCKER, Defendant. I N D I C T M E N T The Grand Jury charges that: Count 1 That on or about the 28th day of March, 1990, at Overland Park, in the District of Kansas, SCOTT ALAN TUCKER, having devised a scheme or artifice to defraud, or for obtaining money or property by means of false or fraud~lent pretenses, representations, or promises, that is, by representing that he operated a loan brokerage business known as Chase, Morgan, Stearns and Lloyd, which was owned by Chase and Manhattan Bank, Lloyds of London, and J. P. Morgan, and requiring advance fees from clients - in order to obtain either loans or letters of credit from lending institutions, for the purpose of executing such scheme or artifice or attempt~ng so to do, did unlawfully and knowingly cause to be delivered by mail according to the direction thereon, a letter addressed.to Chase, Morgan, Stearns and Lloyd, Building 35, Corporate Woods, Overland Park, Kansas 66210, from Elastomer Seals, Inc., Mario R. Trieste, 5 Ditomas Court 1 Copique, New York 11726, Page 9 EXHIBIT "A"

2 ... ' when, in truth and fact, Chase, Morgan, Stearns and Lloyd was owned by the defendant SCOTT ALAN TUCKER and he did not have access to financing as represented to his clients 1 but made said false representations for the purpose of obtaining money or property, in violation of Title 18, United States Code, Sections 1341 and 2. A TRUE BILL. 0 FOREMAN United States~fney District of Kansas Bond Fixed At: $ : L<:?Jz>. IF[ ' S/ G. T. VAN BEBBER U. SQ DISTRICT JUDGE..._ o/r I -I i (It is requested that trial of the above captioned case be held in Kansas City, Kansas. U.S. DISTRICT COURT DISTHICT OF KANSAS SS! I h'}rebj' certify that ~-.~ for~g::.ing is a true copy d the ori:in:;l on file in t~;i: court a~ caus. 2 Page 10

3 Fl LED P:r i 1 L\.v l J! " f;'l '91 Li ~~i I l IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON UNITED STATES OF AMERICA, v. STEPHEN R. STANARD, aka Stephen Stenard, Steven Osborn, Defendant. NO. CR (RE [18 u.s.c u.s.c. 1956(a (1 (A (i] THE GRAND JURY CHARGES THAT: COUNT 1 A. Scheme To Defraud 1. From in or about November 1989, to in or about June 1990, in the District of Oregon, Stephen R. Stanard, also known as Stephen Stenard and Steven Osborn, defendant herein, together with Scott Tucker, not a defendant herein, devised and intended to devise a scheme and artifice to defraud and to obtain money and property by means of false and fraudulent pretenses, representations and promises, as more particularly set forth below.

4 2. At all times relevant to this indictment, defendant Stephen R. Stanard was the founder and operator of United States Investors Corporation, hereinafter referred to as USIC, S.W. Hall Boulevard, Tigard, Oregon. In his capacity as founder and operator of USIC, defendant Stephen R. Stanard directed, supervised, and controlled the staff and employees of USIC. 3. At all times relevant to this indictment, Scott Tucker, not a defendant herein, operated Chase, Morgan, Stearns & Lloyd, hereinafter referred to as CMSL, Overland Park, Kansas. In his capacity as operator of CMSL, Scott Tucker directed, supervised and controlled the staff and employees of CMSL. 4. Defendant Stephen R. Stanard, and his staff and employees, placed advertisements in the "Money to Lend" sections of various newspapers and financial magazines across the country. These advertisements informed potential borrowers that they could obtain substantial business loans through USIC. These advertisements instructed potential borrowers to call USIC for additional information. 5. It was further a part of the scheme and artifice to defraud that defendant Stephen R. Stanard and his staff spoke directly to those individuals responding to the advertisements by telephone. Defendant Stanard and his staff would thereafter send packages of information to potential borrowers regarding the services USIC had to offer. In the course of these communications, Stanard and his staff represented that USIC was a loan brokerage, which could obtain financing for various business PAGE 2 -

5 ventures, in exchange for the payment of a fee or commission. In order to induce interested borrowers to pay such fees and commissions before receiving any financing, Stanard, Tucker and their staffs made the following false, fictitious and fraudulent promises and representations: a. That USIC had existing relationships with and had previously done business with banks and other investors who would provide financing to clients of USIC; b. That CMSL was an investment banking firm which could obtain financing for clients of USIC; c. That loan requests made by clients of USIC had been submitted to financial institutions by USIC and CMSL; d. That such financial institutions had in fact agreed to lend money to clients of USIC; e. That clients of USIC would actually receive such loans if they first paid various commission and fees to USIC and CMSL; f. That clients would actually receive loans from CMSL. 6. It was further part of the scheme and artifice to defraud that Stanard, Tucker and their staffs would and did conceal from and omit to disclose to potential borrowers certain material facts about themselves, USIC and CMSL that were necessary in order to make the representations and promises not misleading including: a. That neither USIC or CMSL had ever successfully PAGE 3 -

6 obtained financing for any potential borrowers; b. That neither USIC or CMSL would make any attempt to obtain financing for potential borrowers. 7. It was further part of the scheme and artifice to defraud that defendant Stephen R. Stanard and his staff would instruct potential borrowers to wire fees and commission to the USIC bank account at Security Pacific Bank, Tigard Branch, Tigard, Oregon, account # , to mail checks made payable to USIC, or to send these checks to USIC via Federal Express or Airborne Express. B. Use of Wire Communications: On or about January 26, 1990, in the District of Oregon, for the purpose of executing the aforementioned scheme and artifice to defraud and attempting to do so, defendant Stephen R. Stanard, defendant herein, knowingly and willfully transmitted and caused to be transmitted by means of wire communication in interstate commerce, sounds in the form of a telephone call from Stephen R. Stanard, d/b/a u.s. Investors Corporation, ( , to Alvin Ray Petty, ( ; All in violation of Title 18, United States Code, Section COUNTS 2 THROUGH The grand jury realleges each and every allegation contained in paragraphs 1 through 7 of Count 1 of this indictment, and incorporates them as if fully set forth. 2. On or about the dates listed below, in the District of Oregon, defendant Stephen R. Stanard, for the purpose of PAGE 4 -

7 executing the aforementioned scheme and artifice to defraud, and attempting to do so, knowingly and willfully transmitted and caused to be transmitted by means of wire communication in interstate commerce, sounds in the form of telephone conversations, more particularly described as follows: Count From To Date Telephone Telephone To Name ( ( James Monaghan ( ( Elizabeth Guest ( ( Mario Trieste ( ( Peter Tourangeau ( ( David Lee ( ( John Tsimogiannis ( ( Paul Medley ( ( Steven Puthuff ( ( James Ishii All in violation of Title 18, United States Code, Section COUNT The grand jury realleges each and every allegation of paragraphs 1 through 7 of Count 1 of this indictment, and incorporates them as if fully set forth. 2. On or about March 26, 1990, in the District of Oregon, for the purpose of executing the scheme and artifice to defraud and attempting to do so, defendant Stephen R. Stanard knowingly and willingly caused to be transmitted by means of wire communication in interstate commerce, sounds in the form of a Ill PAGE 5 -

8 telephone call to U.S. Investors Corporation, ( , from John N. Mayer, ( ; All in violation of Title 18, United States Code, Section COUNT The grand jury realleges each and every allegation of paragraphs 1 through 7 of Count 1 of this indictment, and incorporates them as if fully set forth. 2. On or about May 29, 1990, in the District of Oregon, for the purpose of executing the scheme and artifice to defraud and attempting to do so, defendant Stephen R. Stanard knowingly and willfully caused to be transmitted by means of wire communication in interstate commerce funds in the amount of $3, from the Visa account of David J. Hickson, at First Interstate Bank, Glendale, Arizona, to the account of Stephen R. Stanard, d/b/a U.S. Investors Corporation, at Security Pacific Bank, Tigard Branch, Tigard, Oregon, account number ; All in violation of Title 18, United States Code, Section COUNT The grand jury realleges each and every allegation of paragraphs 1 through 7 of Count 1 of this indictment, and incorporates them as if fully set forth. 2. On or about May 18, 1990, in the District of Oregon, for the purpose of executing the scheme and artifice to defraud and attempting to do so, defendant Stephen R. Stanard, knowingly and wilfully caused to be transmitted by means of wire communication in interstate commerce funds in the amount of $ from the PAGE 6 -

9 account of Lou Munzi, at Western Suburban Bank, Bloomingdale, Illinois, to the account of Stephen R. Stanard, d/b/a U.S. Investor's Corporation, at Security Pacific Bank, Tigard Branch, Tigard, Oregon, account number ; All in violation of Title 18, United States Code, Section COUNTS 14 THROUGH The grand jury realleges each and every allegation of paragraphs 1 through 7 of Count 1 of this indictment and incorporates them as if fully set forth herein. 2. On or about the dates listed below for each count, within the District of Oregon, the defendant, Stephen R. Stanard, did knowingly and wilfully conduct and attempt to conduct a financial transaction affecting interstate commerce, which in fact involved the proceeds of a specified unlawful activity to wit: payment of a check as described below, with the intent to promote the carrying on of the specified unlawful activity, to wit: wire fraud in violation of Title 18, United States Code, Section 1343, as part of the scheme described herein; All in violation of Title 18, United States Code, Section 1956(a (1 (A (i. Count Date Amount Payee Payment For 14 3/20/90 $ u.s. West Comm. Telephone bill 15 3/27/90 $ Chase, Stearns, Commission & Lloyd 16 4/9/90 $ Chase, Morgan, Commission Stearns & Lloyd PAGE 7 -

10 17 4/19/90 $ Chase, Morgan, Commission Stearns & Lloyd 18 4/20/90 $5oo. oe- Chase, Morgan, Commission Stearns & Lloyd 19 4/26/90 $ Chase, Morgan, Commission Stearns & Lloyd All in violation of Title 18, United States Code, Section 1956 (a (1 (A (i. DATED this J:L_ day of December, A TRUE BILL. Presented by: CHARLES H. TURNER United States Attorney District of Oregon /' l/j -~/J;r /(' Lfd/A~ /f'!, '7 CLAIRE M. FAY Assistant U. S. Attorney PAGE 8

Case 5:09-cr D Document 1 Filed 04/16/09 Page 1 of 8

Case 5:09-cr D Document 1 Filed 04/16/09 Page 1 of 8 DAB UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION UNITED STATES OF AMERICA V. I N D I C T MEN T SCOTT ARTHUR WADDELL The Grand Jury charges that: INTRODUCTION