UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

BROWARD DIVISION

CASE NO.: 0:20-cv-61403

UNITED STATES OF AMERICA,

Plaintiff,

 vs.

ROSCELLY SKLAVOUNOS,

Defendant.

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UNITED STATES OF AMERICA’S COMPLAINT FOR

PERMANENT INJUNCTION

Plaintiff, the United States of America (“United States”), through its undersigned 

counsel, hereby sues Defendant Roscelly Sklavounos (“Defendant”) and alleges as follows:

INTRODUCTION

1. Starting as early as 2018 and continuing to the present, Defendant has assisted and 

facilitated a predatory mail and wire fraud scheme that primarily victimizes senior citizens of the 

United States. Participants in the scheme contact potential victims, falsely claim that those 

victims have won the lottery, and thereby induce the victims to transmit money to Defendant to 

account for taxes and fees purportedly associated with victims’ falsely promised lottery 

winnings. 

2. The United States seeks to prevent continuing and substantial injury to victims of

this fraudulent scheme by bringing this action for a permanent injunction and other equitable 

relief under 18 U.S.C. § 1345 to enjoin the ongoing commission of mail fraud and wire fraud in 

violation of 18 U.S.C. §§ 1341 and 1343.

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JURISDICTION AND VENUE

3. The Court has subject matter jurisdiction over this action under 18 U.S.C. § 1345 

and 28 U.S.C. §§ 1331 and 1345.

4. Venue is proper in this district under 28 U.S.C. § 1391(b)(1).

PARTIES

5. Plaintiff is the United States.

6. Defendant is a resident of Deerfield Beach, Florida. Defendant engaged, and 

continues to engage, in the conduct described in this Complaint from within the Southern District 

of Florida.

FRAUDULENT SCHEME

7. Since at least as early as December 2018, Defendant has assisted and facilitated a 

fraud scheme by accepting victim payments and providing participants of the scheme with access 

to those payments.

8. Operators of the fraud scheme engage in a lottery scam. Callers associated with 

the fraud scheme contact victims, who often are senior citizens, and falsely claim that the victims

have won the lottery. Typically, the callers then tell the victim that he or she needs to wire or 

otherwise transmit money to pay for fees and/or taxes allegedly associated with winning the 

lottery. These claims are false and fraudulent, as the members of the scheme know the victim 

has not won the lottery and that there is no need for the victim to wire fees and/or taxes 

associated with winning the lottery. 

9. Since at least December 2018, victims have been harmed by the fraudulent 

scheme facilitated by Defendant. Defendant plays a critical role in the scheme by receiving 

victim payments by mail, and then forwarding payments to individuals in Jamaica engaged in the 

scheme. 

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10. On or about February 26, 2019, Defendant voluntarily agreed to and signed a 

Consent Order to Cease and Desist her participation in the fraudulent lottery scheme pursuant to 

39 U.S.C. § 3005. Despite agreeing to this order, Defendant continues to assist and facilitate the 

fraud scheme. In May 2020, Defendant was the intended recipient of four packages sent to her 

via U.S. mail from elderly lottery scam victims. One victim, a 74 year-old woman from 

Oklahoma, sent a $1,000 money order to the defendant on May 31, 2020. Another parcel that

contained a $499 money order was sent to the Defendant by a 69 year-old woman from 

Pennsylvania, who sent the money after being told she won a prize. 

DEFENDANT’S KNOWLEDGE OF FRAUD

11. Upon information and belief, the United States alleges that Defendant has 

knowledge that her conduct facilitates a mail and wire fraud scheme.

HARM TO VICTIMS

12. Victims suffer financial losses from the mail and wire fraud scheme facilitated by 

Defendant. 

13. The scheme disproportionately affects elderly victims.

14. Absent injunctive relief by this Court, Defendant’s conduct will continue to cause 

injury to victims.

COUNT I

(18 U.S.C. § 1345 – Injunctive Relief)

15. The United States re-alleges and incorporates by reference Paragraphs 1 through 

14 of this Complaint as though fully set forth herein.

16. By reason of the conduct described herein, Defendant violated, is violating, and is 

about to violate 18 U.S.C. §§ 1341 and 1343 by facilitating a scheme and artifice to defraud and

obtain money or property by means of false or fraudulent representations with the intent to 

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defraud, and, in so doing, use the United States mails and interstate or foreign wire 

communications.

17. Upon a showing that Defendant is committing or about to commit mail or wire 

fraud, the United States is entitled, under 18 U.S.C. § 1345, to seek a permanent injunction 

restraining all future fraudulent conduct and to any other action that this Court deems just and 

proper to prevent a continuing and substantial injury to victims.

18. As a result of the foregoing, the Court should enjoin Defendant’s conduct under

18 U.S.C. § 1345.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff, United States of America, requests of the Court the following 

relief:

A. That the Court issue a permanent injunction, pursuant to 18 U.S.C. § 1345, 

ordering that Defendant is restrained from engaging, participating, or assisting in any lottery

scam or money transmitting business; and

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B. That the Court order such other and further relief as the Court shall deem just and 

proper.

DATED: July 13, 2020 Respectfully Submitted,

GUSTAV W. EYLER

Director

Consumer Protection Branch

RICHARD GOLDBERG

Senior Counsel for Complex Litigation

Consumer Protection Branch

By: LINDA I. MARKS

 Linda I. Marks

 Senior Litigation Counsel 

 Consumer Protection Branch

 United States Department of Justice

 P.O. Box 386

 Washington, D.C. 20044

 Tel.: 202-307-0060

 Email: linda.marks@usdoj.gov

Counsel for United States of America

ARIANA FAJARDO ORSHAN

UNITED STATES ATTORNEY

By: JAMES A. WEINKLE

James A. Weinkle

Assistant United States Attorney

Florida Bar No. 0710891

United States Attorney’s Office

Southern District of Florida

99 N.E. 4th Street, Suite 300

Miami, Florida 33132

Tel.: 305-961-9290

Email: James.Weinkle@usdoj.gov

Counsel for United States of America

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