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State v Cole - Complaint v9 for Posting

State v Cole - Complaint v9 for Posting

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Published by: Columbia Daily Tribune on Sep 18, 2012
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09/18/2012

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IN THE CIRCUIT COURT OF RANDOLPH COUNTY, MISSOURI
STATE OF MISSOURI, )Plaintiff ))) Case No.v. ))BRUCE A. COLE, )Defendant. )
FELONY COMPLAINT
COME NOW the Prosecuting Attorney of Randolph County and the Attorney General for the State of Missouri, Special Prosecutor for RandolphCounty, and state the following:COUNT ICharge Code: 1501899.0The Prosecuting Attorney of Randolph County and the AttorneyGeneral for the State of Missouri, upon information and belief, charge thatthe defendant, in violation of Section 570.030, RSMo, committed the class Bfelony of stealing by deceit, punishable upon conviction under Section558.011, RSMo, in that on or between July 17, 2010, and July 30, 2010, in theCounty of Randolph, State of Missouri, acting alone or in concert withanother, the defendant appropriated money of a value of at least twenty-fivethousand dollars, which property was in the charge of Greg Hodge, director of finance for the City of Moberly, and Alissa Roston, acting treasurer forMamtek U.S., and defendant appropriated such property from Greg Hodgeand Alissa Roston and with the purpose to deprive them thereof by deceit inthat the defendant represented to Greg Hodge and Alissa Roston that the
money was to be paid to Ramwell for goods or services for Mamtek U.S.’s
Moberly plant, which representations were false and known to be false by thedefendant, and Greg Hodge and Alissa Roston relied on the representationsand were thereby induced to part with such property.Range of punishment: 5 - 15 years imprisonment
 
 
COUNT IICharge Code: 1930099.0The Prosecuting Attorney of Randolph County and the AttorneyGeneral for the State of Missouri, upon information and belief, charge thatthe defendant, in violation of § 409.5-501, RSMo Cum. Supp. 2009, committedthe felony of criminal securities fraud, punishable upon conviction under§ 409.5-508, RSMo Cum. Supp. 2009, in that on or between January 1, 2010,and August 1, 2012, in the County of Randolph, State of Missouri, thedefendant, Bruce A. Cole, willfully, directly or indirectly, and in connectionwith the offer, sale, or purchase of securities, to wit: municipal bonds issuedby the Industrial Development Authority of the City of Moberly, employed,with intent to defraud, a device, scheme, or artifice to defraud in that hearranged to submit to Mamtek U.S. an invoice for engineering services under
the defendant’s business name of “Ramwell,” with the intent to immediately
direct Mamtek U.S. to use the funds for other purposes, including the
payment of $700,000 to the defendant’s wife for the defendant’s personal use
and benefit.Range of punishment: up to 10 years imprisonment; up to $1 million fineCOUNT IIICharge code: 1930099.0The Prosecuting Attorney of Randolph County and the AttorneyGeneral for the State of Missouri, upon information and belief, charge thatthe defendant, in violation of § 409.5-501, RSMo Cum. Supp. 2009, committedthe felony of criminal securities fraud, punishable upon conviction under§ 409.5-508, RSMo Cum. Supp. 2009, in that on or between July 19, 2010,and July 27, 2010, in the County of Randolph, State of Missouri, thedefendant, Bruce A. Cole, willfully, directly or indirectly, and in connectionwith the offer, sale, or purchase of securities, to wit: municipal bonds issuedby the Industrial Development Authority of the City of Moberly, made anuntrue statement of a material fact, in that defendant represented to theissuer of the bonds tha
t Mamtek’s unique manufacturing processes neither
require nor produce any hazardous substances to manage during production,
which was false in that Mamtek’s manufacturing processes called for the use
of either triphosgene or thionyl chloride, both of which are hazardouschemicals.
 
 
OR, IN THE ALTERNATIVE,The Prosecuting Attorney of Randolph County and the AttorneyGeneral for the State of Missouri, upon information and belief, charge thatthe defendant, in violation of § 409.5-501, RSMo Cum. Supp. 2009, committedthe felony of criminal securities fraud, punishable upon conviction under§ 409.5-508, RSMo Cum. Supp. 2009, in that on or between July 19, 2010,and July 27, 2010, in the County of Randolph, State of Missouri, thedefendant, Bruce A. Cole, willfully, directly or indirectly, and in connectionwith the offer, sale, or purchase of securities, to wit: municipal bonds issuedby the Industrial Development Authority of the City of Moberly, omitted tostate a material fact necessary to make the statements made, in light of thecircumstances under which they were made, not misleading, in that
defendant represented to the issuer of the bonds that Mamtek’s unique
manufacturing processes neither require nor produce any hazardoussubstances to manage during production, omitting the fact that triphosgene
and thionyl chloride, chemicals included in Mamtek’s processes, are both
hazardous chemicals.Range of punishment: up to 10 years imprisonment; up to $1 million fineCOUNT IVCharge Code: 1930099.0The Prosecuting Attorney of Randolph County and the AttorneyGeneral for the State of Missouri, upon information and belief, charge thatthe defendant, in violation of § 409.5-501, RSMo Cum. Supp. 2009, committedthe felony of criminal securities fraud, punishable upon conviction under§ 409.5-508, RSMo Cum. Supp. 2009, in that on or between July 19, 2010,and July 27, 2010, in the County of Randolph, State of Missouri, thedefendant, Bruce A. Cole, willfully, directly or indirectly, and in connectionwith the offer, sale, or purchase of securities, to wit: municipal bonds issuedby the Industrial Development Authority of the City of Moberly, omitted tostate a material fact necessary to make the statements made, in light of thecircumstances under which they were made, not misleading, in thatdefendant represented to the issuer of the bonds that Mamtek operates afully-functional sucralose production facility in Fujian Province, China,omitting
the fact that Mamtek’s sucralose
-production facility in Fujian

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