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UNITED STATES DISTRICT COURT FOR TH~Y',~ DISTRICT OF PUERTO RICO 2012 [1] CARLOS DANIEL CUEV AS-DIAZ, (Counts 1-3, 6-7, 9-11, 16,26,29,36-37,40) [2] MIGUEL ANGEL ECHEGARAYGONZALEZ, (Counts 1-5, 8-9, 12, 17,20,25,28-29,31-32, 35,38) [3] LEE A. ARCIA-CENTENO, (Counts 1,3,6-7,10-11) [4] CARLOS LUIS CUEV AS-DIAZ, (Counts 2, 27, 39) [5] GERMANIA GIL-GIL, (Counts 4, 9, 21, 30, 33-34, 41-43) [6] INMERTAJ. PEREZ-ECHEVARRIA, AKA "MARIA PEREZ," (Counts 5,13-14,23) [7] JORGE PAUL GONZALEZGONZALEZ, (Counts 4-5, 32, 35) [8] SONIA E. DIAZ-RODRIGUEZ, (Counts 42, 44) [9] PEDRO ARCHILLA-COLON, (Counts 2-6,8-10,43) [10] OLGA M. DIAZ-MEDINA, (Count 2) [11] GABRIEL OLIVER-VAZQUEZ, (Count 3) [12] OSCAR PIl~A-FUENTES, (Count 4) [13] PATRICIA PERDOMO-REGALADO, (Count 5) [14 ] NORMAN G. OJEDA-MARRERO, (Count 6) [15] MARLENI DE LA CRUZ-ULLOA, (Counts 7, 15) [16] FEDERICO RIVAS-ROSARIO, (Counts 8,18-19,45) [17] CARLOS XAVIER ORTIZ-OLIVERA, (Count 9) [18] JONATHAN E. RIVERA-SANTANA, (Count 10) [19] NOLIN E. CUMBA-RODRIGUEZ, (Counts 9, 22, 24) [20] WANDA RODRIGUEZ-COLON, (Count 9) Defendants. INDICTMENT FILED UNDER SEAL CRIMINAL Violations: NO. 12-

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(COUNT ONE) Title 18, United States Code, §§ 1014,371 (COUNTS TWO THROUGH TEN) Title 18, United States Code, §§ 1014,2 (COUNT ELEVEN) Title 18, United States Code, §§ 1028A, 2 (COUNTS TWELVE THROUGH TWENTY-FOUR) Title 18, United States Code, §§ 1956(a)(1)(A)(i), (a)(1)(B)(i), and 2. (COUNTS TWENTY-FIVE THROUGH FORTY-FIVE) Title 18, United States Code, §§ 1957,2 (FORTY-FIVE Forfeiture COUNTS)

Allegation

INDICTMENT THE GRAND JURY CHARGES:

BACKGROUND and GENERAL ALLEGATIONS At all times material to this indictment: 1. A "Mortgage" is a legal instrument which describes and establishes encumbrances on real

property to secure the payment of a debt. 2. A "Mortgage Loan" can be generally described as a loan evidenced by a deed that creates

a lien over real property wherein the conditions and form of payment are established. 3. A "Mortgage Lending Institution" is generally defined to include an institution whose

principal business is to originate, finance, close, sell, andlor service real property mortgage loans. 4. A "Closing" or "Settlement" in a real property transaction is generally defined as the documents are

final transaction between the buyer and seller, whereby the conveyancing concluded and the money and property transferred. 5. The Federal Housing Administration

("FHA") was an Office of the United States

Department of Housing and Urban Development ("HUD"), a United States Government agency, which provided mortgage insurance to approved commercial lending institutions to enable low and moderate income home buyers to obtain mortgage loans to purchase homes. By offering FHA-insured loans, HUD assisted potential home buyers in obtaining mortgages at more

favorable terms than those otherwise commercially available. 6. To be eligible to receive an FHA insured loan, home buyers were required to establish

that their incomes were sufficient to meet the mortgage payments. HUD required that the lenders making the loans verify the home buyers' employment for the two most recent years. These . verifications could be accomplished by having the home buyers' employer's complete and sign "Verification of Employment" forms. HUD also required the buyers to provide copies of their
2

most recent paystubs, and in some cases, bank account statements and copies of their income tax returns and related documents such as W-2 forms (wage and tax statement) or the equivalent. 7. To be eligible to receive an FHA insured loan, home buyers were also generally required

to make a minimum equity investment in their homes based on the purchase price of the home. Home buyers were permitted to use gifts from relatives, employers, unions, charitable

organizations, or governmental agencies to meet this equity investment. Home buyers were not, however, permitted to meet the equity requirement with gifts from persons or entities with an interest in the sale of the home, such as the sellers of the homes. Home buyers and sellers were both required to certify at closing that the home buyer had not received any undisclosed payments for the closing costs and/or down payments on the property to be purchased. 8. Under FHA's Direct Endorsement Authority program, the lender determined whether the

home buyer was eligible for an FHA insured loan. If the lender determined that the buyer was eligible, the lender then submitted to HOD for final approval of FHA insurance eligibility the application and all documentation supporting the lender's decision to approve the loan, including the Verification of Employment forms, the home buyer's most recent paystubs, and documents establishing the home buyer's investment of a fixed percentage of the purchase price of the property, among other documents. 9. EMI EQUITY ("LATIN MORTGAGE ("EQUITY and MORTGAGE"), EXPRESS LATIN AMERICAN MORTGAGE

FINANCIAL

AMERICAN")

SOLUTION

CORPORATION ("EXPRESS SOLUTION") were mortgage lending institutions located in San Juan, Puerto Rico, authorized Endorsement Authority Program. to issue FHA insured mortgage loans under the Direct

As part of the mortgage loan approval process, EQUITY

MORTGAGE, LATIN AMERICAN, and EXPRESS SOLUTION required borrowers to submit

3

copies of the documentation required by HUD for the approval and processing of FHA-insured loans. 10. A "Straw Buyer" is an individual whose personal profile is used to serve as a cover,

usually for a fraudulent transaction. They were sometimes also referred to as a "nominee borrower" or "straw borrower." A Straw Buyer is chosen for his or her ability to qualify for the However, most of the times the Straw Buyer did

loan with or without legitimate documentation.

not qualify for the mortgage with his or her actual income and employment history, did not intend to occupy the property as a primary residence, and/or was not eligible for a specific loan program such as the FHA insured loans. THE DEFENDANTS 11. Defendant [1] CARLOS DANIEL CUEVAS-DIAZ was an individual engaged in the

business of purchasing and selling real properties and at times he operated under the name TERRANOSTRA GROUP. At times he recruited straw buyers for transactions included herein. 12. Defendant

[2] MIGUEL ANGEL ECHEGARAY-GONZALEZ was an individual

engaged in the business of purchasing and selling real properties and at times acted as an assistant real property appraiser. At times he recruited straw buyers for transactions included herein. 13. Defendant

[8] SONIA E. DIAZ-RODRIGUEZ was the mother of [1] CARLOS

DANIEL CUEVAS-DIAZ and [4] CARLOS LUIS CUEVAS-DIAZ, and at times performed
monetary transactions related to the purchase and sale of real properties. 14. Defendant [9] PEDRO ARCHILLA-COLON at times assisted in the creation of the

false supporting documents submitted in conjunction with the loan applications. 15. Defendants [4] CARLOS LUIS CUEVAS-DIAZ, [5] GERMANIA GIL-GIL, [10]

OLGA M. DIAZ-MEDINA, [11] GABRIEL OLIVER-VAZQUEZ, [12] OSCAR PINA4

FUENTES,

[13]

PATRICIA

PERDOMO-REGALADO,

[14]

NORMAN

OJEDA-

MARRERO, and [17] CARLOS XAVIER ORTIZ-OLIVERA

entered into real property sales

agreements as either seller or straw buyer and applied and/or obtained FHA insured mortgage loans at EQUITY MORTGAGE. 16. Defendant [16] FEDERICO RIVAS-ROSARIO entered into a real property sales

agreement, and applied and obtained an FHA insured mortgage loan at EXPRESS SOLUTION. 17. Defendants [15] MARLENI DE LA CRUZ-ULLOA and [18] JONATHAN RIVERA-

SANTANA entered into a real property sales agreement and obtained an FHA insured mortgage loan at LATIN AMERICAN. 18. Defendant [6] INMERTA J. PEREZ-ECHEVARRIA, also known as "MARIA and served

PEREZ," conducted business under the name of JD SERVICIOS PROFESIONALES as an intermediary in real estate transactions. 19. Defendant [3] LEE A. ARCIA-CENTENO

was a loan officer, first employed by

EQUITY MORTGAGE and later by LATIN AMERICAN, who participated in the mortgage loan origination, processing and/or approval process in connection to FHA insured mortgage loans. 20. Defendant [7] JORGE PAUL GONZALEZ-GONZALEZ was an attorney and notary

public who at times authorized and notarized Deeds of Sale and/or Powers of Attorney in the real property transactions and provided the moneys for the closing costs in real property transactions. 21. Defendant [19] NOLIN E. CUMBA-RODRIGUEZ at times performed monetary

transactions related to the purchase and sale of real properties. 22. Defendant [20] WANDA RODRIGUEZ-COLON at times served as an intermediary in

real estate transactions.

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COUNT ONE Title 18, United States Code, Section 371 & 1014 (Conspiracy to Make False Statements in Loan Applications)

Beginning on a date unknown but no later than in or about December 2008, up to and including in or about April 2010, in the District of Puerto Rico and elsewhere within the jurisdiction of this Court, [1] CARLOS D. CUEVAS-DIAZ, [2] MIGUEL ANGEL ECHEGARAY-GONZALEZ, [3] LEE A. ARCIA-CENTENO, the defendants herein, did knowingly and willfully combine, conspire and agree with each other, and with diverse other persons known and unknown to the Grand Jury, to knowingly make false statements or cause false statements to be made to EQUITY MORTGAGE, LATIN AND

AMERICAN, and EXPRESS SOLUTION for the purpose of influencing the action of the FHA to insure the following mortgage loans:

Date December 9,2008 EQUITY

Lender

Loan # #12330 (FHA Case # 501-7712124-703) 12338 (FHA Case # 501-7731911-703)

Borrower OLGA M. DIAZMEDINA GABRIEL OLIVERVAZQUEZ

Loan Amount $258,550.00

MORTGAGE January 26, 2009 EQUITY MORTGAGE

$95,400.00

February 27, 2009

EQUITY MORTGAGE

05-1368 (FHA Case # 501-7751591-703) 12343 (FHA Case # 501-7734369-702)

OSCAR PIl~AFUENTES PATRICIO PERDOMOREGALADO

$205,214.00

March 18,2009

EQUITY MORTGAGE

$191,350.00

June 3, 2009

EQUITY

12478 (FHA Case #
6

NORMANG.

$103,050.00

MORTGAGE

501-7860166-703)

OJEDAMARRERO

September 25, 2009

LATIN AMERICAN

2009-1184-1 (FHA Case # 501-7920139703)

MARLENIDE LA CRUZULLOA JONATHAN RIVERASANTANA FEDERICO RIVASROSARIO

$132,554.00

December 29, 2009

LATIN AMERICAN

2009-1248-1 (FHA Case # 501-7909501703)

$78,551.00

April 23, 2010

EXPRESS SOLUTION

10-2072 (FHA Case # 501-8032605-703)

$181,649.00

April 30, 2010

EQUITY MORTGAGE

# 12696 (FHA Case #
501-8037342-702)

CARLOS XAVIER ORTIZOLIVERAS

$170,735.00

Object of the Conspiracy The object of the conspiracy was to obtain monetary gain through commissions and or revenues related to real property and/or loan transactions, including undisclosed payments from third parties and false or fraudulent liens, debts, or claims allegedly owed. Manner and Means The manner and means by which the defendants and co-conspirators would accomplish and further the object of the conspiracy, among others, included the following: 1. It was part of the manner and means of the conspiracy that the defendants and their co-

conspirators would recruit straw buyers who at times receive monetary compensation for their participation of the offense. 2. It was further part of the manner and means of the conspiracy that the defendants and

their co-conspirators would assist the straw buyers under the sales contract to apply for FHA insured mortgage loans at various mortgage lenders, to finance the purchase of these properties.
7

3.

It was a part of the manner and means of the unlawful conspiracy that the defendants and

their co-conspirators knowingly submitted and caused to be submitted false and fraudulent information to the mortgage lenders to fraudulently procure mortgage financing for the real property transactions. purchaser's: This false and fraudulent information included, among other things, the

occupation and place of employment, income, time at employment, assets, and

intent to occupy the property. 4. It was a part of the manner and means of the unlawful conspiracy that the defendants and would distribute the illegally obtained proceeds of the real property

their co-conspirators

transactions amongst themselves. Overt Acts in Furtherance of the Conspiracy

In furtherance of the conspiracy and in order to effect its objects, the Defendants, and others known and unknown to the Grand Jury, committed and caused to be committed at least one of the below enumerated over acts, among others, in the District of Puerto Rico and elsewhere: A. 5. EQUITY MORTGAGE LOAN #12330 (FHA Case # 501-7712124-703) DANIEL CUEVAS-DIAZ recruited [10]

Prior to November 20, 2008, [1] CARLOS to act as a straw buyer.

OLGA M. DIAZ-MEDINA 6.

On or about November 20, 2008 and December 9, 2008, and in between, [10] OLGA M. applied for FHA-insured mortgage loan #12330 in the amount of

DIAZ-MEDINA

$258,550.00 for the purchase of a property located at 6-A Ausubo Fajardo,

Street, Las Gaviotas,

P.R. 00738, by falsely stating in the initial and final Uniform Residential Loan

Applications that she was employed at EI Faro Boat Park and that her monthly income was $6,600.00.

8

7.

On or about November 20, 2008,

[3] LEE A. ARCIA-CENTENO

signed the initial

Uniform Residential Loan Application for loan #12330 indicating that he had interviewed [ 10] OLGA M. DIAZ-MEDINA 8. to take her application. ANGEL

In or about November 2008 up to in or about December 2008, [2] MIGUEL

ECHEGARAY-GONZALEZ

caused materially false information to be submitted in connection mortgage loan #12330 applied for by [10] OLGA the false supporting documents which further

with the loan application for FHA-insured M. DIAZ-MEDINA in that he procured

misrepresented her financial eligibility to obtain this loan. B. 9. EQUITY MORTGAGE loan # 12338 (FHA Case # 501-7731911-703) DANIEL CUEVAS-DIAZ recruited [11]

Prior to December 11, 2008, [1] CARLOS

GABRIEL OLIVER-VAZQUEZ 10.

to act as a straw buyer.

On or about December 11,2008, and on or about January 20,2009, and in between, [11] OLIVER- VAZQUEZ applied for FHA-insured mortgage loan #12338 in the

GABRIEL

amount of $95,400.00 for the purchase of a property located at 202 Laurel Street, Fajardo Gardens, Fajardo, P.R. 00738, by falsely stating in the Uniform Residential Loan Application that he was employed at Terrazas Caribe and that his monthly income was $3,000.00. 11. On or about December 11, 2008, [3] LEE A. ARCIA-CENTENO signed the initial

Uniform Residential Loan Application for loan #12338 indicating that he had interviewed [11] GABRIEL OLIVER-VAZQUEZ 12. to take his loan application. ANGEL

In or about December 2008 up to in or about January 2009, [2] MIGUEL

ECHEGARA Y-GONZALEZ with the loan application GABRIEL

caused materially false information to be submitted in connection mortgage loan #12338 applied for by [11]

for FHA-insured

OLIVER- VAZQUEZ

in that he procured the false supporting documents which

further misrepresented his financial eligibility to obtain this loan.

9

13.

On or about January 26, 2009,

EQUITY MORTGAGE paid [2] MIGUEL ANGEL

ECHEGARAY-GONZALEZ

the amount of $31,350.00 in the form of check number #105019, account, to satisfy the balance due on a promissory note

drawn from EQUITY MORTGAGE's

dated September 11,2008, signed between the seller of said property and [2] MIGUEL ANGEL ECHEGARA Y-GONZALEZ. C. 14. EQUITY MORTGAGE loan #05-1368 (FHA Case #501-7751591-703) In or about December 2008 up to in or about February 2009, [5] GERMANIA GIL-

GIL paid approximately

$3,000.00 to [12] OSCAR PIl~A-FUENTES for agreeing to serve as

straw buyer in a real property transaction involving the sale of her property located at 977 Sola Street, Tras Talleres, San Juan, P.R. 00907. 15. In or about December 2008 [2] MIGUEL ANGEL ECHEGARAY-GONZALEZ met

[12] OSCAR PIl~A-FUENTES at 977 Sola Street, Tras Talleres, San Juan, P.R. 00907, through [5] GERMANIA GIL-GIL. 16. On or about January 21, 2009, and on or about February 27, 2009, and in between, [12 ]

OSCAR PIl~A-FUENTES applied for FHA-insured mortgage loan #05-1368 in the amount of $205,214.00 for the purchase of a property located at 977 Sola Street, Tras Talleres, San Juan, P.R. 00907, by falsely stating in the Uniform Residential Loan Application that he was employed at Caribbean Diesel Technologies and that his monthly income was $4,763.92. 17. In or about February 2009, [2] MIGUEL ANGEL ECHEGARAY-GONZALEZ

caused materially false information to be submitted in loan applications in connection with FHA-insured mortgage loan #05-1368 applied for by [12] OSCAR PINA-FUENTES in that he procured the false supporting documents which further misrepresented his financial eligibility to obtain this loan.

10

D. 18.

EQUITY MORTGAGE

loan #12343 (FHA Case #501-7734369-702)

On or about December 22, 2008, and on or about March 12, 2009, and in between, [2] ANGEL ECHEGARAY-GONZALEZ assisted [13] PATRICIA mortgage PERDOMO-

MIGUEL

REGALADO

in her application for FHA-insured

loan #12343 in the amount of

$191,350.00 for the purchase of a property located at #709 8th Street, Buena Vista Community, San Juan, P.R. 00915, for which she falsely stated in the final Uniform Residential Loan Application that she was employed by JD Servicios Profesionales and that her monthly income was $3,500.00. 19. In or about December 2008 up to in or about March 2009, [2] MIGUEL ANGEL

ECHEGARAY-GONZALEZ

caused materially false information to be submitted in loan mortgage loan #12343 applied for by [13]

applications in connection with FHA-insured PATRICIA PERDOMO-REGALADO

in that he procured the false supporting documents

which further misrepresented her financial eligibility to obtain this loan. E. 20. EQUITY MORTGAGE loan #12478 (FHA Case #501-7860166-703) G.

On or about April 22, 2009, and June 3, 2009, and in between, [14] NORMAN applied for FHA-insured mortgage

OJEDA-MARRERO

loan #12478 in the amount of

$103,050.00 for the purchase of a property located at #104 Bartolome de Las Casas Street, Villa Palmeras, San Juan, P.R. 00915, by falsely stating in the final Uniform Residential Loan Application that his monthly income as a hair stylist at "STYLUS AND CUT" was $2,310.00. 21. In or about April 2009, and in or about June 2009, and in between, [3] LEE A. ARCIAassisted in the initial loan request, processing, and closing for FHA-insured

CENTENO

mortgage loan #12478. 22. In or about April 2009, and in or about June 2009, and in between, [1] CARLOS caused materially false information to be submitted in connection

DANIEL CUEVAS-DIAZ

11

with the loan application for FHA-insured mortgage loan #12478 applied in that he in that he procured the false supporting documents which further misrepresented his financial eligibility to obtain this loan. 23. On or about June 3, 2009, [1] CARLOS DANIEL CUEVAS-DIAZ caused someone

known to the Grand Jury with initials M.L.N., to impersonate the real owner of the property being sold to [14] NORMAN G. OJEDA-MARRERO. 24. On or about June 3, 2009, during said closing, [1] CARLOS DANIEL CUEVAS-DIAZ

presented a false promissory note payable to him in the amount of $60,000.00, the balance due of which was paid to him by EQUITY MORTGAGE in the form of a check. F. 25. LATIN AMERICAN loan #2009-1184-1 (FHA Case #501-7920139-703) On or about August 11, 2009, [3] LEE ARCIA-CENTENO signed the initial Uniform

Residential Loan Application for FHA-insured mortgage loan #2009-1184-1, indicating that he interviewed [15] MARLENI DE LA CRUZ-ULLOA to take her loan application. 26. On or about August 8, 2009, [1] CARLOS DANIEL DIAZ-CUEVAS made a cash

deposit of $6,500.00 in a Banco Popular bank account belonging to [15] MARLENI DE LA CRUZ-ULLOA. 27. On or about September 25,2009, [15] MARLENI DE LA CRUZ-ULLOA applied for

FHA-insured mortgage loan #2009-1184-1 in the amount of $132,554.00 for the purchase of a property located at 714 Aristides Chavier Street, Villa Prades,San Juan, P.R. 00924, by falsely stating in the final Uniform Residential Loan Application that her monthly income at Productos Induveca was $2,583.00. 28. On or about September 12, 2009, [3] LEE ARCIA-CENTENO requested that [15]

MARLENI DE LA CRUZ-ULLOA give him a check for $2,000.00 payable to "cash."

12

G. 29.

EXPRESS SOLUTION loan #10-2072 (FHA Case #501-8032605-703) On or about March 2, 2010, and April 23, 2010, and in between, [16] FEDERICO applied for FHA-insured mortgage loan #10-2072 in the amount of

RIVAS-ROSARIO

$181,646.00 for the purchase of a property located at 503 12thSt., Barrio Obrero, San Juan, P.R. 00915, by falsely stating in the final Uniform Residential Loan Application that his monthly income at Nephesh Recycling, Co., Inc. was $4,564.00. 30. In or about March 2010, and April 2010, and in between, [2] MIGUEL ANGEL caused materially false information to be submitted in loan

ECHEGARA Y-GONZALEZ

applications in connection with FHA-insured mortgage loan #10-2072 applied for by [16] FEDERICO RIVAS-ROSARIO in that he procured the false supporting documents which

further misrepresented his financial eligibility to obtain this loan. H. 31. EQUITY MORTGAGE loan #12696 (FHA Case # 501-8037342-702) Prior to October 27,2009, [1] CARLOS DANIEL CUEVAS-DIAZ and [2] MIGUEL recruited [17] CARLOS XAVIER ORTIZ-

ANGEL

ECHEGARAY-GONZALEZ

OLIVERA to act as a straw buyer. 32. On or about October 27, 2009, and April 30, 2010, and in between [17] CARLOS applied for FHA-insured mortgage loan #12696 in the amount

XAVIER ORTIZ-OLIVERA

of $170,735.00 for the purchase of a property located at JC10, 145th St. Jardines de Country Club, Carolina, P.R. 00983, by falsely stating in the final Uniform Residential Loan Application that his monthly income at Perfect Cut was $3,302.00. 33. In or about October 2009, and April 2010, and in between, [2] MIGUEL ANGEL caused materially false information to be submitted in loan 12696 (FHA Case # 501-8037342-702applied

ECHEGARA Y-GONZALEZ

applications in connection with mortgage loan

13

for by [17] CARLOS XAVIER ORTIZ-OLIVERA

in that he procured the false supporting

documents which further misrepresented his financial eligibility to obtain this loan. I. 34. LATIN AMERICAN loan #2009-1248-1 (FHA Case # 501-7909501-703) Prior to December 16, 2009, [1] CARLOS RIVERA-SANTANA DANIEL CUEVAS-DIAZ recruited [18]

JONATHAN 35.

to act as a straw buyer. RIVERA-SANTANA applied for

On or about December 16, 2009, [18] JONATHAN

FHA-insured

mortgage loan #2009-1248-1 in the amount of $78,551.00 for the purchase of a

property located at Urb. Country Club, 242nd Street, JWD-l, Carolina, P.R. by falsely stating in the Uniform Residential Loan Application that he was employed at Centennial and that his monthly income was $2,500.00. 36. On or about December 16,2009, [3] LEE A. ARCIA-CENTENO signed the Uniform

Residential Loan Application for loan #2009-1248-1 indicating that he had interviewed [18] JONATHAN 37. RIVERA-SANTANA to take his loan application. caused materially

In or about December 2009, [1] CARLOS DANIEL CUEVAS-DIAZ

false information to be submitted in connection with the loan application for FHA-insured mortgage loan #2009-1248-1 applied for [18] JONATHAN RIVERA-SANTANA in that he

procured the false supporting documents which further misrepresented his financial eligibility to obtain this loan. All in violation of Title 18, United States Code, Section 371 and 1014.

14

COUNT TWO Title 18, United States Code, Section 1014 & 2 (False Statements in Loan Applications) On or about November 20, 2008, and December 9, 2008, and in between, in the District of Puerto Rico and elsewhere within the jurisdiction of this Court, [1] CARLOS DANIEL CUEVAS-DIAZ, [2] MIGUEL ANGEL ECHEGARA Y-GONZALEZ, [4] CARLOS LUIS CUEV AS-DIAZ, [9] PEDRO ARCHILLA-COLON, [10] OLGA M. DIAZ-MEDINA, the defendants herein and others known and unknown to the Grand Jury, aiding and abetting each other, knowingly made or cause to be made, material false statements to EQUITY MORTGAGE for the purpose of influencing the action of the FHA, in connection with a loan AND

application to obtain FHA-insured mortgage loan number 12330 (FHA Case # 501-7712124703) in the amount of $258,550.00 for the purchase of a property located at 6-A Ausubo Street, Las Gaviotas, Fajardo, P.R. 00738. The false statements include, but are not limited to the

following: (i) in both the initial and final Uniform Residential Loan Applications for this loan that [10] OLGA M. DIAZ-MEDINA's monthly income as Administrator of EI Faro Boat Park

was $6,600.00, when in truth and in fact, as the defendants well knew, such statement was false, in that [10] OLGA M. DIAZ-MEDINA's did not earn this income and did not occupy said

position; (ii) in the final Uniform Residential Loan Applications for this loan that [10] OLGA M. DIAZ-MEDINA's had a bank account at Scotiabank ending in 4590 with a balance of

$17,237.12, when in truth and in fact, as the defendants well knew, said bank account did not contain that balance on that date; (iii) in the final Uniform Residential Loan Application for this loan that [10] OLGA M. DIAZ-MEDINA had provided a $5,000.00 check in earnest deposit

when in truth and in fact, as the defendants well knew, he did not provide said deposit because the check was false; (iv) in the HUD-l that [10] OLGA M. DIAZ-MEDINA had provided the

closing costs in the amount of $13,853.00, when in truth and in fact, as the defendants well knew, [9] PEDRO ARCHILLA-COLON provided the closing costs; and (v) in the occupancy would use the property for which she was

statement, that [10] OLGA M. DIAZ-MEDINA

seeking financing as her principal residence, when in truth and in fact, as defendants well knew, [8] SONIA DIAZ-RODRIGUEZ would reside in the property. The defendants also supplied 15

false' and fraudulent paystubs, bank account statements, and income tax withholding statements. All in violation of Title 18, United States Code, Sections 1014 and 2.

COUNT THREE Title 18, United States Code, Section 1014 & 2 (False Statements in Loan Applications) On or about December 11,2008, and January 26,2009, and in between, in the District of Puerto Rico and elsewhere within the jurisdiction of this Court, [1] CARLOS DANIEL CUEVAS-DIAZ, [2] MIGUEL ANGEL ECHEGARAY-GONZALEZ, [3] LEE A. ARCIA-CENTENO, [9] PEDRO ARCHILLA-COLON, AND

[11] GABRIEL OLIVER-VAZQUEZ, the defendants herein and others known and unknown to the Grand Jury, aiding and abetting each other, knowingly made or cause to be made, material false statements to EQUITY MORTGAGE for the purpose of influencing the action of the FHA, in connection with a loan

application to obtain FHA-insured mortgage loan number 12338 (FHA Case # 501-7731911703) in the amount of $95,400.00 for the purchase of a property located at 202 Laurel Street, Fajardo Gardens, Fajardo, P.R. 00738. The false statements include, but are not limited to the following: (i) in both the initial and final Uniform Residential Loan Applications for this loan that [11] GABRIEL OLIVER-VAZQUEZ's income was $3,000.00 from Terrazas Caribe,

when in truth and in fact, as the defendants well knew, such statements were false, in that [11] GABRIEL OLIVER- VAZQUEZ neither earned this income nor work at Terrazas Caribe; (ii)

in the final Uniform Residential Loan Applications for this loan that [11] GABRIEL OLIVERVAZQUEZ had a bank account at Banco Popular de Puerto Rico ending in 8770 with a balance of $10,430.00, when in truth and in fact, as the defendants well knew, said bank account did not contain that balance on that date; (iii) in the final Uniform Residential Loan Application for this loan that [11] GABRIEL OLIVER-VAZQUEZ had provided a $2,000.00 check in earnest

deposit when in truth and in fact, as the defendants well knew, he did not provide said deposit because the check was false; and (iv) in the occupancy statement, that [11] GABRIEL OLIVER- VAZQUEZ would use the property for which he was seeking financing as his

principal residence, when in truth and in fact, as defendants well knew, [11] GABRIEL 16

OLIVER- VAZQUEZ would not reside in the property. The defendants also supplied false and fraudulent paystubs, bank account statements, and income tax withholding statements. All in violation of Title 18, United States Code, Sections 1014 and 2.

COUNT FOUR
Title 18, United States Code, Section 1014 & 2 (False Statements in Loan Applications) On or about January 21, 2009, and February 27, 2009, and in between, in the District of Puerto Rico and elsewhere within the jurisdiction of this Court, [2] MIGUEL ANGEL ECHEGARA Y-GONZALEZ, [5] GERMANIA GIL-GIL, [7] JORGE PAUL GONZALEZ-GONZALEZ, [9] PEDRO ARCHILLA-COLON, AND

[12] OSCAR PIl~A-FUENTES, the defendants herein and others known and unknown to the Grand Jury, aiding and abetting each other, did knowingly made or cause to be made, material false statements to EQUITY MORTGAGE for the purpose of influencing the action of the FHA, in connection with a loan application to obtain FHA-insured mortgage loan number 05-1368 (FHA Case # 501-7751591703) in the amount of $205,214.00 for the purchase of a property located at 977 Sola Street, Tras Talleres, San Juan, P.R. 00907. The false statements include, but are not limited to the following: (i) in both the initial and the final Uniform Residential Loan Applications for this loan that [12] OSCAR PIl~A-FUENTES's income from Caribbean Diesel Technologies was $4,763.92 when in truth and in fact, as the defendants well knew, such statement was false, in that [12] OSCAR PINA-FUENTES did not earn this income and did not work at Caribbean Diesel Technologies; (ii) in both the initial and the final Uniform Residential Loan Applications for this loan that [12] OSCAR PINA-FUENTES had a bank account at RG Premier Bank ending in 0037 with a

balance of $14,549.00, when in truth and in fact, as the defendants well knew, said bank account did not exist; (iii) in the final Uniform Residential Loan Application for this loan that [12] OSCAR PINA-FUENTES had provided a $5,000.00 check in earnest deposit when in truth and in fact, as the defendants well knew, he did not provide said deposit because the check was false; (iv) in the HUD-l that [12] OSCAR PINA-FUENTES had provided the closing costs in the

amount of $12,000.00, when in truth and in fact, as the defendants well knew, [7] JORGE 17

PAUL

GONZALEZ-GONZALEZ

provided the closing costs; and (v) in the occupancy would use the property for which he was seeking

statement, that [12] OSCAR PIl~A-FUENTES

financing as his principal residence, when in truth and in fact, as defendants well knew, [12] OSCAR PINA-FUENTES would not reside in the property and defendant [5] GERMANIA

GIL-GIL intended to continue to reside in the property and rent other units within the property for income. The defendants also supplied false and fraudulent paystubs, bank account statements, and income tax withholding statements. All in violation of Title 18, United States Code, Sections 1014 and 2.

COUNT FIVE Title 18, United States Code, Section 1014 & 2 (False Statements in Loan Applications)

On or about December 22,2008, and March 18, 2009, and in between, in the District of Puerto Rico and elsewhere within the jurisdiction of this Court, [2] MIGUEL ANGEL ECHEGARAY-GONZALEZ, [6] INMERTA J. PEREZ-ECHEVARRIA, [7] JORGE PAUL GONZALEZ-GONZALEZ, [9] PEDRO ARHCILLA-COLON, [13] PATRICIA AND

PERDOMO-REGALADO,

the defendants herein and others known and unknown to the Grand Jury, aiding and abetting each other, knowingly made or cause to be made, material false statements to EQUITY MORTGAGE for the purpose of influencing the action of the FHA, in connection with a loan

application to obtain FHA-insured mortgage loan number 12343 (FHA Case # 501-7734369702) in the amount of $191,350.00 for the purchase of a property located at 709 8th Street, Buena Vista Community, San Juan, P.R. 00915. The false statements include, but are not limited to the following: (i) in the initial Uniform Residential Loan Application for this loan that [13] PATRICIA Profesionales PERDOMO-REGALADO's monthly income from her employment JD Servicios

was $3,000.00, when in truth and in fact, as the defendants well knew, such PERDOMO-REGALADO neither worked at JD

statement was false, in that [13] PATRICIA

Servicios Profesionales nor earned said income; (ii) in the final Uniform Residential Loan Application for this loan that [13] PATRICIA PERDOMO-REGALADO's monthly income

from her employment with JD Servicios Profesionales was $3,500.00, when in truth and in fact, 18

as the defendants well knew, such statement was false, in that [13] PATRICIA REGALADO

PERDOMO-

neither worked at JD Servicios Profesionales nor earned said income; (iii) in the PERDOMO-

final Uniform Residential Loan Application for this loan that [13] PATRICIA REGALADO

had a bank account at Oriental Bank ending in 8150 with a balance of$17,736.00,

when in truth and in fact, as the defendants well knew, said bank account did not exist; (iv) in the HUD-l that [13] PATRICIA PERDOMO-REGALADO had provided the closing costs in the

amount of $12,770.00, when in truth and in fact, as the defendants well knew, [7] JORGE PAUL GONZALEZ-GONZALEZ provided the closing costs; and (v) in the occupancy PERDOMO-REGALADO would use the property for which

statement, that [13] PATRICIA

she was seeking financing as her principal residence, when in truth and in fact, as defendants well knew, [13] PATRICIA defendant [6] INMERTA PERDOMO-REGALADO J. PEREZ-ECHEVARRIA would not reside in the property and intended to exercise control over the

property and rent the property for income. The defendants also supplied false and fraudulent paychecks, paystubs, bank account statements, and income tax withholding statements. All in violation of Title 18, United States Code, Sections 1014 and 2.

COUNT SIX Title 18, United States Code, Section 1014 & 2 (False Statements in Loan Applications) On or about April 22, 2009, and June 3, 2009, and in between, in the District of Puerto Rico and elsewhere within the jurisdiction of this Court, [1] CARLOS DANIEL CUEVAS-DIAZ, [3] LEE ARCIA-CENTENO, [9] PEDRO ARCHILLA-COLON, AND

[14] NORMAN G. OJEDA-MARRERO, the defendants herein and others known and unknown to the Grand Jury, aiding and abetting each other, knowingly made or cause to be made, material false statements to EQUITY MORTGAGE for the purpose of influencing the action of the FHA, in connection with a loan

application to obtain FHA-insured mortgage loan number 12478 (FHA Case # 501-7860166703) in the amount of $103,050.00 for the purchase of a property located at 104 Bartolome de Las Casas, Villa Palmeras, San Juan, P.R. 00915. The false statements include, but are not limited to the following: (i) in the initial Uniform Residential Loan Application for this loan that
19

[14] NORMAN G. OJEDA-MARRERO

had worked for Stylus and Cut for a period of two

years and four months and was generating a monthly employment income of $2,300.00, when in truth and in fact, as the defendants well knew, such statement was false, in that [14] NORMAN G. OJEDA-MARRERO had only been working at Style and Cuts for less than eight months

and did not earn said income; (ii) in the final Uniform Residential Loan Application for this loan that [14] NORMAN G. OJEDA-MARRERO had worked for Stylus and Cut for a period of

two years and five months and was generating a monthly employment income of $2,310.00, when in truth and in fact, as the defendants well knew, such statement was false, in that [14] NORMAN G. OJEDA-MARRERO had only been working at Style and Cuts for less than ten did not

months and did not earn said income; in that [14] NORMAN G. OJEDA-MARRERO

earn this amount income; (iii) in the final Uniform Residential Loan Application for this loan that [14] NORMAN G. OJEDA-MARRERO had provided a $1,000.00 check in earnest

deposit when in truth and in fact, as the defendants well knew, he did not provide said deposit because the check was false; (iv) in the final Uniform Residential Loan Application for this loan that [14] NORMAN G. OJEDA-MARRERO had a bank account in First Bank ending with

3606 with a balance of $4,657.00, when in truth and in fact, as the defendants well knew, said bank account did not exist; (v) in the HUD-l, that W.C.P. was the seller of the property, when in truth and in fact, as the defendants well knew, a person known to the Grand Jury impersonated W.c.P. The defendants also supplied false and fraudulent bank account statements, informative returns of income subject to withholding, and income tax returns. All in violation of Title 18, United States Code, Sections 1014 and 2.

COUNT SEVEN
Title 18, United States Code, Section 1014 & 2 (False Statements in Loan Applications) On or about August 11,2009, and September 25,2009, and in between, in the District of Puerto Rico and elsewhere within the jurisdiction of this Court, [1] CARLOS DANIEL CUEVAS-DIAZ, [3] LEE ARCIA-CENTENO, AND [15] MARLENI DE LA CRUZ-ULLOA, the defendants herein and others known and unknown to the Grand Jury, aiding and abetting each other, knowingly made or cause to be made, material false statements to LATIN
20

AMERICAN FINANCIAL for the purpose of influencing the action of the FHA, in connection with a loan application to obtain FHA-insured mortgage loan number 2009-1184-1 (FHA Case # 501-7920139-703) in the amount of $132,554.00 for the purchase of a property located at 714

Aristides Chavier St., Villa Prades, San Juan, P.R. 00924. The false statements include, but are not limited to the following: (i) in both the initial and final Uniform Residential Loan

Applications for this loan that [15] MARLENI DE LA CRUZ-ULLOA's monthly income from her employment with PRODUCTOS INDUVECA was $2,583.00, when in truth and in fact, as the defendants well knew, such statement were false, in that [15] MARLENI DE LA CRUZULLOA did not earn this amount; (ii) in the initial Uniform Residential Loan Application for this loan that [15] MARLENI DE LA CRUZ-ULLOA had a bank account at Banco Popular de Puerto Rico ending in 2170 with a balance of $4,655.24, when in truth and in fact, as the defendants well knew, said bank account did not contain that balance on that date; and (iii) in the HUD-1 that [15] MARLENI DE LA CRUZ-ULLOA had provided the closing costs in the amount of $5,531.42, when in truth and in fact, as the defendants well knew, [1] CARLOS DANIEL CUEV AS-DIAZ provided part of the closing costs. The defendants also supplied

false and fraudulent paystubs, bank account statements, and income tax withholding statements. All in violation of Title 18, United States Code, Sections 1014 and 2.

COUNT EIGHT Title 18, United States Code, Section 1014 & 2 (False Statements in Loan Applications) On or about March 2,2010, and April 23, 2010, and in between, in the District of Puerto Rico and elsewhere within the jurisdiction of this Court, [2] MIGUEL ANGEL ECHEGARAY-GONZALEZ, [9] PEDRO ARCHILLA-COLON, AND

[16] FEDERICO RIVAS-ROSARIO, the defendants herein and others known and unknown to the Grand Jury, aiding and abetting each other, knowingly made or cause to be made, material false statements to EXPRESS SOLUTIONS for the purpose of influencing the action of the FHA, in connection with a loan application to obtain FHA-insured mortgage loan number 10-2072 (FHA Case # 501-8032605703) in the amount of $181,646.00 for the purchase of a property located at 503
12th

St., Barrio

Obrero, San Juan, P.R. 0091. The false statements include, but are not limited to the following: 21

(i) in the initial Uniform Residential Loan Application for this loan that [16] FEDERICO RIVAS-ROSARIO's monthly income from his employment with Nephesh Recycling Co., Inc.

was $3,734.00, when in truth and in fact, as the defendants well knew, such statement was false, in that [16] FEDERICO RIVAS-ROSARIO neither worked at Nephesh Recycling Co., Inc. nor earned said income; (ii) in the final Uniform Residential Loan Application for this loan that [16] FEDERICO RIV AS-ROSARIO's monthly income from his employment with Nephesh

Recycling Co., Inc. was $4,564.00, when in truth and in fact, as the defendants well knew, such statement was false, in that [16] FEDERICO RIVAS-ROSARIO Recycling neither worked at Nephesh

Co., Inc. nor earned said income; (iii) in the final Uniform Residential Loan had provided a $5,000.00

Application for this loan that [16] FEDERICO RIVAS-ROSARIO

check in earnest deposit when in truth and in fact, as the defendants well knew, he did not provide said deposit because the check was false; (iv) in the final Uniform Residential Loan Application for this loan that [16] FEDERICO RIVAS-ROSARIO had a bank account at RG

Premier Bank ending in 0123 with a balance of $7,084.00, when in truth and in fact, as the defendants well knew, said bank account did not contain that balance on that date; and (v) in the HUD-1 that [16] FEDERICO RIVAS-ROSARIO had provided the closing costs in the amount of $3,460.80, when in truth and in fact, as the defendants well knew, [2] MIGUEL ANGEL ECHEGARAY-GONZALEZ provided the closing costs. The defendants also supplied false

and fraudulent paystubs, bank account statements, and income tax withholding statements. All in violation of Title 18, United States Code, Sections 1014 and 2.

COUNT NINE Title 18, United States Code, Section 1014 & 2 (False Statements in Loan Applications) On or about October 27, 2009, and April 30, 2010, and in between, in the District of Puerto Rico and elsewhere within the jurisdiction of this Court, [1] CARLOS DANIEL CUEVAS-DIAZ, [2] MIGUEL ANGEL ECHEGARAY-GONZALEZ, [5] GERMANIA GIL-GIL, [9] PEDRO ARCHILLA-COLON, [17] CARLOS XAVIER ORTIZ-OLIVERA, [19] NOLIN E. CUMBA-RODRIGUEZ, 22 AND

[20] WANDA RODRIGUEZ-COLON, the defendants herein and others known and unknown to the Grand Jury, aiding and abetting each other, knowingly made or cause to be made, material false statements to EQUITY MORTGAGE for the purpose of influencing the action of the FHA, in connection with a loan

application to obtain FHA-insured mortgage loan number 12696 (FHA Case # 501-8037342702) in the amount of $170,735.00 for the purchase of a property located at JC10, 145th St. Jardines de Country Club, Carolina, P.R. 00983. The false statements include, but are not limited to the following: (i) in the initial Uniform Residential Loan Application for this loan that [17] CARLOS XAVIER ORTIZ-OLIVERA's monthly income from his employment with Perfect

Cut was $3,250.00, when in truth and in fact, as the defendants well knew, such statement was false, in that [17] CARLOS XAVIER ORTIZ-OLIVERA neither worked at Perfect Cut nor

earned said income; (ii) in the final Uniform Residential Loan Application for this loan that [17] CARLOS XAVIER ORTIZ-OLIVERA's monthly income from his employment with Perfect

Cut was $3,302.00, when in truth and in fact, as the defendants well knew, such statement was false, in that [17] CARLOS XAVIER ORTIZ-OLIVERA neither worked at Perfect Cut nor

earned said income; (iii) in the final Uniform Residential Loan Application for this loan that [17] CARLOS XAVIER ORTIZ-OLIVERA had provided a $3,000.00 check in earnest deposit he did not provide said deposit because

when in truth and in fact, as the defendants wellknew,

the check was false; (iv) in the final Uniform Residential Loan Application for this loan that [17] CARLOS XAVIER ORTIZ-OLIVERA had a bank account at Doral Bank ending in 1512 with

a balance of$7,051.00, when in truth and in fact, as the defendants well knew, said bank account did not exist; (v) in the HUD-1 that [17] CARLOS XAVIER ORTIZ-OLIVERA had provided

the closing costs in the amount of $2,772.55, when in truth and in fact, as the defendants well knew, [2] MIGUEL ANGEL ECHEGARAY-GONZALEZ provided the closing costs; and would use

(vi) in the occupancy statement, that [17] CARLOS XAVIER ORTIZ-OLIVERA

the property for which he was seeking financing as his principal residence, when in truth and in fact, as defendants well knew, [17] CARLOS XAVIER ORTIZ-OLIVERA the property and instead defendants [20] WANDA RODRIGUEZ-COLON E. CUMBA-RODRIGUEZ would not reside in and [19] NOLIN

intended to rent the property for income. The defendants also

supplied false and fraudulent pay checks, bank account statements, and income tax withholding statements. All in violation of Title 18, United States Code, Sections 1014 and 2.

23

COUNT TEN Title 18, United States Code, Section 1014 & 2 (False Statements in Loan Applications) On or about December 16,2009, and December 29,2009, and in between, in the District of Puerto Rico and elsewhere within the jurisdiction of this Court, [1] CARLOS DANIEL CUEVAS-DIAZo [3] LEE A. ARCIA-CENTENO . [9] PEDRO ARCHILLA-COLON, . AND

[18] JONATHAN RIVERA-SANTANA, the defendants herein, and others known and unknown to the Grand Jury, aiding and abetting each other, knowingly AMERICAN made or cause to be made, material false statements to LATIN for the purpose of influencing the action of the FHA, in connection

FINANCIAL

with a loan application to obtain FHA-insured mortgage loan number 2009-1248-1 (FHA Case # 501-7909501-703) in the amount of $78,551.00 for the purchase of a property located at Urb. Country Club, 242nd Street, JWD-l, Carolina, P.R. 00984. The false statements include, but are not limited to the following: (i) in the Uniform Residential Loan Application for this loan that [18] JONATHAN RIVERA-SANTANA had worked for Centennial for the past three years

generating an employment monthly income of $2,500.00, when in truth and in fact, as the defendants well knew, such statements were false, in that [18] JONATHAN RIVERA-

SANTANA had worked for Caribbean Temporary Services assigned to Centennial for less than three months and did not generate said income; (ii) in the Uniform Residential Loan Application for this loan that [18] JONATHAN RIVERA-SANTANA had provided a $1,000.00 check in

earnest deposit when in truth and in fact, as the defendants well knew, he did not provide said deposit because the check was false; (iii) in the Uniform Residential Loan Application for this loan that that [18] JONATHAN RIVERA-SANTANA had a bank account in Banco Popular de

Puerto Rico ending with 3115 with a balance of $4,000, when in truth and in fact, as the defendants well knew, said bank account did not exist; and (iv) in the HUD-l JONATHAN RIVERA-SANTANA that [18]

had provided the closing costs in the amount of $3,019.71,

when in truth and in fact, as the defendants well knew, [1] CARLOS DANIEL CUEV AS-DIAZ provided the closing costs. The defendants also supplied false and fraudulent paystubs and bank account statements as supporting documents to secure the FHA-insured loan. All in violation of Title 18, United States Code, Sections 1014 and 2.
24

COUNT ELEVEN Title 18, United States Code, Sections 1028A and 2 (Aggravated Identity Theft) On or about June 3, 2009, in the District of Puerto Rico and elsewhere within the jurisdiction of this Court, [1] CARLOS DANIEL CUEV AS-DIAZ [3] LEE A. ARCIA-CENTENO the defendants herein, and others known and unknown to the Grand Jury, aiding and abetting each other did knowingly possess and use without lawful authority, the means of identification of another person, to wit, the name and date of birth of an individual known as W.c.P., during and in relation to a violation of Title 18 United States Code, Section 1014. Specifically, the

defendants aided and abetted M.L.N., someone known to the Grand Jury, to falsely represent himself as being the individual known W.C.P., when in truth and in fact, as the defendants well knew, he was not that individual and did not have authorization to act on his behalf, for the purpose of obtaining an FHA-insured mortgage loan from EQUITY MORTGAGE in the amount of$103,050.00, in violation of Title 18, United States Code, Sections 1028A and 2.

COUNTS TWELVE THROUGH TWENTY-FOUR Title 18, United States Code, Sections 1956(a)(1)(A)(i), 1956(a)(1)(B)(i), and 2

(Laundering of monetary instruments to promote and to conceal the carrying on of a specified unlawful activity) On or about May 2009, and continuing to on or about September 2010, in the District of Puerto Rico, and within the jurisdiction of this Court, [1] CARLOS DANIEL CUEVAS-DIAZ, [2] MIGUEL ANGEL ECHEGARAY-GONZALEZ, [5] GERMANIA GIL-GIL, [6] INMERTA J. PEREZ-ECHEVARRIA, [15] MARLENI DE LA CRUZ-ULLOA, [16] FEDERICO RIVAS-ROSARIO, AND· [19] NOLIN E. CUMBA-RODRIGUEZ, the defendants herein, aiding and abetting each other, did knowingly conduct and attempt to conduct the following financial transactions affecting interstate and foreign commerce, which 25

involved the proceeds of specified unlawful activity, that is, false statements in loan and credit applications, in violation of Title 18, United States Code, Section 1014, with the intent to promote the carrying on of said specified unlawful activity --as evidenced in the transactions below-- and knowing that the transaction was designed in whole and in part to conceal and disguise, the nature, location, source, ownership, and control of the proceeds of said specified unlawful activity and that while conducting and attempting to conduct such financial

transactions,

the defendants knew that the property involved in the financial transactions,

represented the proceeds of some form of unlawful activity.

COUNT
12

DEFENDANTS
MIGUEL ANGEL ECHEGARAYGONZALEZ INMERTA J. PEREZECHEVARRIA INMERTA J. PEREZECHEVARRIA

DATE
May 16, 2009

TRANSACTION
Payment of monthly payment, in the amount of$1,437.99 for loan # 12343. Payment of monthly payment, in the amount of$1,437.99 for loan # 12343. Payment of monthly payment in the amount of$1,704.56 for loan # 12343. Purchase of manager's check in the amount of $5,531.42, for closing cost of loan # 20091184-1. Purchase of manager's check in the amount of $3,019.71, for closing cost ofloan # 12481. Purchase of manager's check in the amount of $3,460.80, for closing cost ofloan # 102072. Payment of monthly payment in the amount of $14,447.12 with manager's check for loan # 12343. to Payment of $2,000.00 PEREZINMERTA J. ECHEVARRIA from loan # 102072.
26

13

August 16, 2009

14

November 5, 2009

15

MARLENI DE LA CRUZ-ULLOA

September 25, 2009

16

CARLOS D. CUEVASDIAZ MIGUEL ANGEL ECHEGARAYGONZALEZ FEDERICO RIV AS ROSARIO

December 29,2009

17

April 23, 2010

18

April 23, 2010

19

FEDERICO RIV AS ROSARIO AND INMERTA J. PEREZECHEVARRIA

April 26, 2010

20

MIGUEL ANGEL ECHEGARAYGONZALEZ GERMANI A GIL-GIL

April 30, 2010

Purchase of manager's check in the amount of $2,772.55 for closing cost of loan # 12696. Payment of monthly payment in the amount of $12,105.00 manager's check- for loan # 051368. Payment of monthly payment in the amount of$I,185.86 for loan # 12696. Payment of monthly payment in the amount of $4,500.00 for loan # 12343. Payment of monthly payment in the amount of$1,233.29 for loan # 12696.

21

May 3, 2010

22

NOLIN E. CUMBARODRIGUEZ

August 16,2010

23

INMERTA 1. PEREZECHEVARRIA NOLIN E. CUMBARODRIGUEZ

September 02,2010

24

September 17, 2010

All in violation (a)(1)(B)(i), and 2.

of Title 18, United States Code, Sections

1956(a)(1)(A)(i),

and

COUNTS TWENTY-FIVE THROUGH FORTY-FIVE Title 18, United States Code, Sections 1957 and 2 (Engaging in Monetary Transactions in Property Derived from Specified Unlawful Activity) From in or about December 2008, and continuing up to in our about May 2010, in the District of Puerto Rico, and within the jurisdiction of this Court, [1] CARLOS DANIEL CUEV AS-DIAZ, [2] MIGUEL ANGEL ECHEGARAY-GONZALEZ, [4] CARLOS LUIS CUEV AS-DIAZ, [5] GERMANIA GIL-GIL, [7] JORGE PAUL GONZALEZ-GONZALEZ, [8] SONIA DIAZ-RODRIGUEZ, [9] PEDRO ARCHILLA-COLON, AND [16] FEDERICO RIVAS-ROSARIO,

27

the defendants herein, aiding and abetting each other, did knowingly engage and attempt to engage in the following monetary transactions by, through or to a financial institution, affecting interstate or foreign commerce, all of which originated from criminally derived property of a value greater than $10,000, that is the transfer and payment of U.S. currency having been derived from a specified unlawful activity, that is, false statements in a loan and credit application, in violation of Title 18, United States Code, Section 1014:

COUNT

DEFENDANT MIGUEL ANGEL ECHEGARA YGONZALEZ CARLOS DANIEL CUEV ASDIAZ CARLOS LUIS CUEVAS-DIAZ MIGUEL ANGEL ECHEGARAYGONZALEZ MIGUEL ANGEL ECHEGARAYGONZALEZ AND CARLOS DANIEL CUEV AS-DIAZ GERMANIA GIL-GIL MIGUEL ANGEL ECHEGARA YGONZALEZ JORGE PAUL GONZALEZGONZALEZ AND MIGUEL ANGEL ECHEGARAYGONZALEZ GERMANIA GIL-GIL GERMANIA GIL-GIL JORGE PAUL GONZALEZGONZALEZ AND MIGUEL ANGEL ECHEGARAYGONZALEZ CARLOS DANIEL CUEVASDIAZ CARLOS DANIEL CUEVASDIAZ MIGUEL ANGEL ECHEGARA Y-

DATE December 10, 2008 December 12,2008 December 28, 2008 January 26,2009

MONETARY TRANSACTION $15,000.00 $17,000.00 $27,000.00 $15,000.00

25 26 27 28 29

January 27,2009 February 28, 2009 February 28, 2009

$16,342.00 $25,000.00 $26,000.00

30 31 32

March 2, 2009

$12,000.00

33 34 35

March 2, 2009 March 2, 2009

$13,060.72 $15,923.28

March 18, 2009

$12,770.57

36 37 38

June 9, 2009 June 9, 2009 July 16, 2009
28

$30,000.00 $20,000.00 $10,800

GONZALEZ

39 40 41 42 43 44 45

CARLOS LUIS CUEVAS-DIAZ CARLOS DANIEL CUEV ASDIAZ GERMANIA GIL-GIL SONIA DIAZ-RODRIGUEZ AND GERMANIA GIL-GIL GERMANIA GIL-GIL AND PEDRO ARCHILLA-COLON SONIA DIAZ-RODRIGUEZ FEDERICO RIV AS-ROSARIO

October 1,2009 October 1,2009 May 3, 2010 May 3, 2010 May 3, 2010 May 10,2010 May 13,2010

$35,000.00 $25,000.00 $30,000.00 $30,000.00 $73,991.03 $15,325.54 $15,000.00

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

29

Title 18, United States Code, Section 982 (Forfeiture a. Allegation)

The allegations contained herein in Counts Twelve through Forty-five of this Indictment

are hereby realleged and incorporated by reference for the purpose of alleging forfeitures pursuant to the provisions of Title 18, United States Code, Section 982(a)(I) b. Pursuant to Title 18, United States Code, Section 982(a)(1), should defendants [1] [2] MIGUEL [5] GERMANIA ANGEL ECHEGARAY-GONZALEZ, GIL-GIL, [6] INMERTA J. PEREZDIAZ[15] be

CARLOS DANIEL CUEVAS-DIAZ, [4] CARLOS LUIS CUEVAS-DIAZ, ECHEVARRIA, RODRIGUEZ, MARLENI [7] JORGE

PAUL

GONZALEZ-GONZALEZ, [16] FEDERICO

[8] SONIA RIVAS-ROSARIO,

[9] PEDRO ARCHILA-COLON,

DE LA CRUZ-ULLOA,

AND [19] NOLIN

E. CUMBA-RODRIGUEZ,

convicted of one or more of the offenses set forth in Counts Twelve through Forty-five of this Indictment, the defendants shall forfeit to the United States of America pursuant to Title 18 United States Code, Section 982(a)(I), any property, real or personal, involved in such offense,

and any property traceable to such property. The property to be forfeited includes, but is not limited to, the following:. A money judgment of $535,048.89 in U.S. Currency. c. If any of the property described above, as a result of any act or omission of the defendants: a. cannot be located upon the exercise of due diligence; b. has been transferred or sold to, or deposited with, a third party; c. has been placed beyond the jurisdiction of the court; d. has been substantially diminished in value; or e. has been commingled with other property which cannot be divided without difficulty, the United States of America shall be entitled to forfeiture of substitute property pursuant to Title 21, United States Code, Section 853(P), as incorporated by Title 18, United States Code, Section 982(b)(1) and Title 28, United States Code, Section 2461(c).

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All in accordance with Title 18, United States Code, Section 982(a)(1) and Rule 32.2(a) of the Federal Rules of Criminal Procedure.

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TRUE BILL

ROSA EMILIA RODRIGUEZ-VELEZ St

derson ss nt United States Attorney Deputy Chief, White Collar Unit

Mariana E. Bauza- monte Assistant United States Attorney

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