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FILED by YH D.C. 

Aug 11, 2020 

ANGELA E. NOBLE 

CLERK U.S. DIST. CT. 

UNITED STATES DISTRICT COURT S.D. OFFLA. - MIAMI 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO.: 20-20185-CR-WILLIAMS/TORRES 

18 u.s.c. § 1349 

18 u.s.c. § 1341 

18 u.s.c. § 1343 

18 u.s.c. § 1346 

18 U.S.C. § 1956(h) 

18 U.S.C. § 1956(a)(l)(B)(i) and (ii) 

18 u.s.c. § 1957 

18 u.s.c. § 2 

18 u.s.c. § 371 

26 u.s.c. § 7206(2) 

26 u.s.c. § 7206(1) 

18 U.S.C. § 981(a)(l)(C) 

18 U.S.C. § 982(a)(l) 

21 u.s.c. § 853 

UNITED STATES OF AMERICA 

vs. 

MARIO RENE DE LA TORRE, 

a/k/a "Mario R. Delatorre," 

YUMET DE LA TORRE, and 

JOE LEWIS MCHOMES, 

a/k/a "Joe McHomes," 

_______________ 

Defendants. 

/ 

INFORMATION 

The United States Attorney charges that: 

GENERAL ALLEGATIONS 

At various times material to this Information: 

1. Summit Aerospace, Inc. ("Summit Aerospace") was a Florida corporation, having 

its principal place of business in Miami, Florida. 

2. Al-Raha Group for Technical Services, a/k/a "Al-Raha Group for Technical 

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Services (Inc.)" ("RGTS") was a company having its principal place of business in Riyadh, in the 

Kingdom of Saudi Arabia. 

3. RGTS was the prime contractor to Foreign Military Sales ("FMS") contracts with 

the United States Air Force ("USAF"), for the repair and return of aircraft components and parts 

(the "FMS contracts"). Summit Aerospace served as a subcontractor and repair source for RGTS, 

under the FMS contracts. 

Defendants 

4. Defendant MARIO RENE DE LA TORRE, a/k/a "Mario R. Delatorre," 

("MARIO DE LA TORRE" or "MARIO") was an individual who resided in Miami-Dade 

County. MARIO DE LA TORRE served as the Vice President of Sales and Marketing, and the 

Senior Vice President of Sales and Marketing of Summit Aerospace. 

5. Defendant YUMET DE LA TORRE (or "YUMET") was an individual who 

resided in Miami-Dade County. YUMET DE LA TORRE served as the Controller of Summit 

Aerospace. 

6. Defendant JOE LEWIS MCHOMES, a/k/a "Joe McHomes," ("JOE 

MCHOMES." or "MCHOMES") was an individual who resided in the State of Georgi_a. 

MCHOMES purported to carry on business as a marketing representative for Summit Aerospace 

under the names J-CONN Solutions, J-CONN Management Solutions, and J-CONN. 

Financial Institutions 

7. 50 Shades, Inc., doing business as Kevin's Check Casher, Kevin's Check Cashing, 

and Mr. Kevin's Check Cashing ("Kevin's Check Cashing"), was a Georgia corporation, with its 

principal office and place of business in Macon, Georgia. 

8. Discount Check Casher of Georgia, LLC, doing business as Discount Check Casher 

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of Macon, and Macon Check Casher ("Macon Check Casher"), was a Georgia limited liability 

company, with its principal office in Savannah, Georgia, and a place of business in Macon, 

Georgia. 

9. Kevin's Check Cashing, and Macon Check Casher, carried on business as cashiers 

and redeemers of checks, and similar instruments. Accordingly, Kevin's Check Cashing, and 

Macon Check Casher, were "financial institutions" as defined in Title 31, United States Code, 

Section 5312(a)(2)(K), and Title 18, United States Code, Section 1956( c )(6)(A). 

10. Bank of America, N .A. ("Bank of America"), and Wells Fargo Bank, N .A. ("Wells 

Fargo Bank"), were banks whose deposits were insured by the Federal Deposit Insurance 

Corporation ("FDIC") in accordance with Chapter 16, Title 12, United States Code, and were 

"insured banks" as defined in Title 12, United States Code, Section 1813(h). Accordingly, Bank 

of America, and Wells Fargo Bank, were "financial institutions" as defined in Title 31, United 

States Code, Section 5312(a)(2)(A), and Title 18, United States Code, Section 1956(c)(6)(A). 

Internal Revenue Service 

11. The Internal Revenue Service ("IRS") was an agency of the United States 

Department of Treasury responsible for administering the federal tax laws of the United States and 

collecting taxes owed to the United States. 

COUNT 1 

CONSPIRACY TO COMMIT MAIL FRAUD AND WIRE FRAUD 

(18 u.s.c. § 1349) 

1. Paragraphs 1 to 10 of the General Allegations section of this Information are realleged and fully incorporated herein by reference. 

2. From on or about April 22, 2008, and continuing through in or around October 

2018, the exact dates being unknown to the United States Attorney, in Miami-Dade County, in the 

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Southern District of Florida, and elsewhere, the defendants, 

MARIO RENE DE LA TORRE, 

a/k/a "Mario R. Delatorre," 

YUMET DE LA TORRE, and 

JOE LEWIS MCHOMES, 

did willfully, that is, with the intent to further the objects of the conspiracy, and knowingly 

combine, conspire, confederate, and agree with each other: 

(a) to knowingly, and with the intent to defraud, devise, and intend to devise, a scheme 

and artifice to defraud, including to deprive another, that is Summit Aerospace, of the intangible 

right of the honest services of MARIO DE LA TORRE and YUMET DE LA TORRE, through 

the use of kickbacks and bribes, and the concealment of material information, when the defendants 

foresaw and reasonably should have foreseen that Summit Aerospace might suffer economic harm 

as a result of the scheme, and to obtain money and property by means of materially false and 

fraudulent pretenses, representations, and promises, knowing that the pretenses, representations, 

and promises were false and fraudulent when made, and, for the purpose of executing such scheme 

and artifice, knowingly deposit, and cause to be deposited any matter or thing whatever to be sent 

and delivered by any private and commercial interstate carrier, knowingly cause to be delivered 

by such carrier according to the direction thereon any such matter or thing, and knowingly take 

and receive therefrom any such matter or thing, in violation of Title 18, United States Code, 

Sections 1341 and 1346; and 

(b) to knowingly, and with the intent to defraud, devise, and intend to devise, a scheme 

and artifice to defraud, including to deprive another, that is Summit Aerospace, of the intangible 

right of the honest services of MARIO DE LA TORRE and YUMET DE LA TORRE, through 

the use of kickbacks and bribes, and the concealment of material information, when the defendants 

foresaw and reasonably should have foreseen that Summit Aerospace might suffer economic harm 

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as a result of the scheme, and to obtain money and property by means of materially false and 

fraudulent pretenses, representations, and promises, knowing that the pretenses, representations, 

and promises were false and fraudulent when made, and, for the purpose of executing such scheme 

and artifice, knowingly transmit and cause to be transmitted, by means of wire communications in 

interstate commerce, certain writings, signs, signals, pictures, and sounds, in violation of Title 18, 

United States Code, Sections 1343 and 1346. 

PURPOSE OF THE CONSPIRACY 

3. The purpose of the conspiracy was to unjustly enrich the defendants by inducing 

Summit Aerospace to send money and property to JOE MCHOMES doing business as J-CONN 

Solutions, so that MCHOMES could pay undisclosed kickbacks to MARIO DE LA TORRE, 

for the use and benefit of MARIO and YUMET DE LA TORRE; and to thereby deprive Summit 

Aerospace of the honest services of its employees, MARIO and YUMET DE LA TORRE. 

MANNER AND MEANS OF THE CONSPIRACY 

The manner and means of the conspiracy included, but were not limited to, the following: 

4. MARIO DE LA TORRE and JOE MCHOMES made representations to Summit 

Aerospace that MCHOMES had secured contracts, agreements, and purchase orders for Summit 

Aerospace under ROTS's FMS contracts with the United States Air Force. Typically, the Summit 

Aerospace and ROTS contracts, agreements, and purchase orders required that Summit Aerospace 

repair and return aircraft components and parts that ROTS would ship to Summit Aerospace's 

repair shop in Miami, Florida. 

5. MARIO DE LA TORRE created invoices purportedly issued by J-CONN 

Solutions to Summit Aerospace, for marketing commission fees that MCHOMES had purportedly 

earned by securing repair and return work from ROTS (the "J-CONN Solutions invoices"). In 

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many, if not most instances, MARIO DE LA TORRE determined that the amount of each JCONN Solutions invoice was approximately ten percent of a specific invoice or group of invoices 

that Summit Aerospace presented to RGTS, for repair and return work. Further, MARIO 

determined that each of the J-CONN Solutions invoices was for an amount under $10,000. 

MARIO submitted the J-CONN Solutions invoices to Summit Aerospace for payment. 

6. YUMET DE LA TORRE arranged for Summit Aerospace to pay J-CONN 

Solutions invoices. Among other things, YUMET signed checks payable to J-CONN Solutions, 

drawn on Summit Aerospace's U.S. Century Bank account number ending in 1810, and its Florida 

Community Bank account number ending in 0300 (the "Summit Aerospace checks"). 

7. JOE MCHOMES and MARIO DE LA TORRE used, and caused Summit 

Aerospace to use, wire communications in interstate commerce, including electronic mail, to cause 

and coordinate the creation, submission, and payment of J-CONN Solutions invoices, and the 

delivery of Summit Aerospace checks to MCHOMES's address in Georgia. 

8. The defendants used, and caused Summit Aerospace to use, a private and 

commercial interstate carrier, that is FedEx, to send Summit Aerospace checks from Summit 

Aerospace's office in Miami, Florida, to JOE MCHOMES's address in Georgia. 

9. JOE MCHOMES cashed Summit Aerospace checks at check cashers in Georgia, 

including Kevin's Check Cashing and Macon Check Casher. In most instances, MCHOMES 

structured his cashing of Summit Aerospace checks, so that the check or checks he cashed on one 

day had a total value of less than $10,000. MCHOMES deposited cash proceeds from Summit 

Aerospace checks in MARIO DE LA TORRE's Bank of America account number ending in 

8988 ("account no. 8988"). In most instances, JOE MCHOMES structured his deposits to 

account no. 8988, so that he deposited less than $10,000 in cash on any one day. 

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10. During the period commencing on or about February 16, 2011, and continuing 

through on or about October 26, 2015, JOE MCHOMES deposited approximately $612,662 in 

cash proceeds from Summit Aerospace checks in MARIO DE LA TORRE's account no. 8988. 

These deposits were kickbacks and bribes. The defendants did not disclose to, and concealed from 

Summit Aerospace, the fact that MCHOMES would kickback proceeds from Summit Aerospace 

checks to MARIO DE LA TORRE. 

All in violation of Title 18, United States Code, Section 1349. 

COUNTS 2-6 

Mail Fraud 

(18 u.s.c. § 1341) 

1. Paragraphs 1 to 10 of the General Allegations section of this Information are realleged and fully incorporated herein by reference. 

2. From on or about April 22, 2008, and continuing through in or around October 

2018, the exact dates being unknown to the United States Attorney, in Miami-Dade County, in the 

Southern District of Florida, and elsewhere, the defendants, 

MARIO RENE DE LA TORRE, 

a/k/a "Mario R. Delatorre," 

YUMET DE LA TORRE, and 

JOE LEWIS MCHOMES, 

did knowingly, and with intent to defraud, devise, and intend to devise, a scheme and artifice to 

defraud, including to deprive another, that is Summit Aerospace, of the intangible right of the 

honest services of MARIO DE LA TORRE and YUMET DE LA TORRE, through the use of 

kickbacks and bribes, and the concealment of material information, when the defendants foresaw 

and reasonably should have foreseen that Summit Aerospace might suffer economic harm as a 

result of the scheme, and to obtain money or property by means of materially false and fraudulent 

pretenses, representations, and promises, knowing that the pretenses, representations, and 

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promises were false and fraudulent when made, and, for the purpose of executing such scheme and 

artifice, did knowingly deposit, and cause to be deposited any matter or thing whatever to be sent 

or delivered by any private and commercial interstate carrier, did knowingly cause to be delivered 

by such carrier according to the direction thereon, any such matter or thing, and did knowingly 

take and receive therefrom any such matter or thing. 

PURPOSE OF THE SCHEME AND ARTIFICE 

3. The purpose of the scheme and artifice was to unjustly enrich the defendants by 

inducing Summit Aerospace to send money and property to JOE MCHOMES doing business as 

J-CONN Solutions, so that MCHOMES could pay undisclosed kickbacks to MARIO DE LA 

TORRE, for the use and benefit of MARIO and YUMET DE LA TORRE; and to thereby 

deprive Summit Aerospace of the honest services of its employees, MARIO and YUMET DE 

LATORRE. 

THE SCHEME AND ARTIFICE 

4. Paragraphs 4 to 10 of the Manner and Means section of Count I of this Information 

are re-alleged and fully incorporated herein by reference. 

USE OF PRIVATE AND COMMERCIAL INTERSTATE CARRIER 

5. On or about the dates specified below, in the Southern District of Florida, and 

elsewhere, for the purpose of executing and in furtherance of the aforesaid scheme and artifice, the 

defendants did knowingly deposit, and caused to be deposited, in Miami, Florida, the packages 

specified below, which contained Summit Aerospace checks payable to J-CONN SOLUTIONS, 

to be delivered by private and commercial interstate carrier, that is FedEx, to JOE MCHOMES's 

address in Georgia, did knowingly cause the said packages to be delivered by FedEx according to 

the directions thereon, and did knowingly take and receive from FedEx the said packages: 

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COUNT APPROX. DATES FEDEX PACKAGE SUMMIT AEROSPACE 

OF SHIPMENT TRACKING NUMBER CHECK NUMBERS 

2 8/12-13/2015 7742 6759 5180 057001,057002 

3 10/22-23/2015 7747 9886 7700 060298, 060299, 

060300,060301 

4 2/4-5/2016 7755 7659 6186 061808, 061809, 

061810,061811 

5 2/1-2/2017 7783 2880 6269 066295,066296,066297 

6 5/15-16/2018 7722 3729 1387 072106,072107,072108 

In violation of Title 18, United States Code, Sections 1341, 1346, and 2. 

COUNTS 7-11 

Wire Fraud 

(18 u.s.c. § 1343) 

1. Paragraphs 1 to 10 of the General Allegations section of this Information are realleged and fully incorporated herein by reference. 

2. From on or about April 22, 2008, and continuing through in or around October 

2018, the exact dates being unknown to the United States Attorney, in Miami-Dade County, in the 

Southern District of Florida, and elsewhere, the defendants, 

MARIO RENE DE LA TORRE, 

a/k/a "Mario R. Delatorre," 

YUMET DE LA TORRE, and 

JOE LEWIS MCHOMES, 

did knowingly, and with intent to defraud, devise, and intend to devise, a scheme and artifice to 

defraud, including to deprive another, that is Summit Aerospace, of the intangible right of the 

honest services of MARIO DE LA TORRE and YUMET DE LA TORRE, through the use of 

kickbacks and bribes, and the concealment of material information, when the defendants foresaw 

and reasonably should have foreseen that Summit Aerospace might suffer economic harm as a 

result of the scheme, and to obtain money and property by means of materially false and fraudulent 

pretenses, representations, and promises, knowing that the pretenses, representations, and 

promises were false and fraudulent when made, and, for the purpose of executing such scheme and 

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artifice, did knowingly transmit and cause to be transmitted, by means of wire communications in 

interstate commerce, certain writings, signs, signals, pictures, and sounds. 

PURPOSE OF THE SCHEME AND ARTIFICE 

3. The purpose of the scheme and artifice was to unjustly enrich the defendants by 

inducing Summit Aerospace to send money and property to JOE MCHOMES doing business as 

J-CONN Solutions, so that MCHOMES could pay undisclosed kickbacks to MARIO DE LA 

TORRE, for the use and benefit of MARIO and YUMET DE LA TORRE; and to thereby 

deprive Summit Aerospace of the honest services of its employees, MARIO and YUMET DE 

LATORRE. 

THE SCHEME AND ARTIFICE 

4. Paragraphs 4 to 10 of the Manner and Means section of Count 1 of this Information 

are re-alleged and fully incorporated herein by reference. 

USE OF WIRES 

5. On or about the dates below, in the Southern District of Florida, and elsewhere, for 

the purpose of executing and in furtherance of the aforesaid scheme and artifice, the defendants 

did knowingly transmit and cause to be transmitted, by means of wire communications in interstate 

commerce, certain writings, signs, signals, pictures, and sounds, as specified below: 

COUNT APPROX. DATE DESCRIPTION OF WIRE TRANSMISSION 

OF WIRE 

7 8/12/2015 Email from Summit Aerospace in Miami, Florida, to 

Joe McHomes, in Georgia, regarding JCONN 8/12. 

8 10/22/2015 Email from Mario De La Torre at Summit 

Aerospace in Miami, Florida, to Joe McHomes, in 

Georgia, regarding Increased Repairs. 

9 2/4/2016 Email from Summit Aerospace in Miami, Florida, to 

Joe McHomes, in Georgia, regarding J-CONN 

AWB-2/4. 

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COUNT APPROX. DATE DESCRIPTION OF WIRE TRANSMISSION 

OF WIRE 

10 2/1/2017 Email from Summit Aerospace in Miami, Florida, to 

Joe McHomes, m Georgia, regarding J-CONN 

SOLUTIONS-2/1. 

11 5/15/2018 Email from Summit Aerospace in Miami, Florida, to 

Joe McHomes, in Georgia, regarding JCONN -5/15. 

In violation of Title 18, United States Code, Sections 1343, 1346, and 2. 

COUNT 12 

Conspiracy to Commit Money Laundering Offenses 

(18 U.S.C. § 1956(h)) 

1. Paragraphs 1 to 10 of the General Allegations section of this Information are realleged and fully incorporated herein by reference. 

2. From on or about April 22, 2008, and continuing through in or around October 

2018, the exact dates being unknown to the United States Attorney, in Miami-Dade County, in the 

Southern District of Florida, and elsewhere, the defendants, 

MARIO RENE DE LA TORRE, 

a/k/a "Mario R. Delatorre," 

YUMET DE LA TORRE, and 

JOE LEWIS MCHOMES, 

did knowingly and voluntarily combine, conspire, confederate, and agree with each other and with 

other persons known and unknown to the United States Attorney, to commit certain offenses 

against the United States, in violation of Title 18, United States Code, Sections 1956 and 1957, 

that is: 

(a) to knowingly conduct a financial transaction affecting interstate and foreign 

commerce, and involving the use of a financial institution the activities of which affected interstate 

and foreign commerce, which transaction involved the proceeds of specified unlawful activity, 

knowing that the property involved in the financial transaction represented the proceeds of some 

form of unlawful activity, and knowing that such financial transaction was designed in whole and 

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in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds 

of specified unlawful activity, in violation of Title 18, United States Code, Section 

l 956(a)(l )(B)(i); 

(b) to knowingly conduct a financial transaction affecting interstate and foreign 

commerce, and involving the use of a financial institution the activities of which affected interstate 

and foreign commerce, which transaction involved the proceeds of specified unlawful activity, 

knowing that the property involved in the financial transaction represented the proceeds of some 

form of unlawful activity, and knowing that such financial transaction was designed in whole and 

in part to avoid a transaction reporting requirement under State and Federal law, in violation of 

Title 18, United States Code, Section l 956(a)(l )(B)(ii); and 

( c) to knowingly engage in a monetary transaction affecting interstate commerce, by, 

through, and to a financial institution, in criminally derived property having a value of more than 

$10,000, such property having been derived from a specified unlawful activity, and knowing that 

the property involved in the monetary transaction represented the proceeds of some form of 

unlawful activity, in violation of Title 18, United States Code, Section 1957. 

It is further alleged that the specified unlawful activity is mail fraud, in violation of Title 

18, United States Code, Section 1341, and wire fraud in violation of Title 18, United States Code, 

Section 1343. 

All in violation of Title 18, United States Code, Section l 956(h). 

COUNT 13 

Money Laundering 

(18 u.s.c. § 1957) 

I. Paragraphs I to IO of the General Allegations section of this Information are realleged and fully incorporated herein by reference. 

2. On or about February 5, 2016, in Miami-Dade County, in the Southern District of 

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Florida, and elsewhere, the defendant, 

MARIO RENE DE LA TORRE, 

a/k/a "Mario R. Delatorre," 

did knowingly engage in and attempt to engage in a monetary transaction affecting interstate 

commerce, by, through, and to a financial institution, in criminally derived property having a value 

of more than $10,000, such property having been derived from a specified unlawful activity, and 

knowing that the property involved in the monetary transaction represented the proceeds of some 

form of unlawful activity; in particular: the wire-transfer of approximately $179,017.07 from a 

Wells Fargo Bank account ending in 6796, in Miami-Dade County, to a CNLBank account ending 

in 3817, in Miami-Dade County, for the purchase of 3878 S.W. 152 Court, Miami, Florida 33185. 

It is further alleged that the specified unlawful activity is mail fraud, in violation of Title 

18, United States Code, Section 1341, and wire fraud, in violation of Title 18, United States Code 

Section 1343. 

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

COUNT 14 

Conspiracy to Defraud the United States 

(18 u.s.c. § 371) 

1. Paragraphs 1 to 11 of the General Allegations section of this Information are realleged and fully incorporated herein by reference. 

2. From on as early as on or about May 4, 2012, and continuing through on or about 

July 27, 2016, the exact dates being unknown to the United States Attorney, in Miami-Dade 

County, in the Southern District of Florida, and elsewhere, the defendants, 

MARIO RENE DE LA TORRE, 

a/k/a "Mario R. Delatorre," and 

YUMET DE LA TORRE, 

did unlawfully, voluntarily, intentionally, and knowingly conspire, combine, confederate, and 

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agree with each other to defraud the United States for the purpose of impeding, impairing, 

obstructing, and defeating the lawful governmental functions of the Internal Revenue Service of 

the Treasury Department of the United States in the ascertainment, computation, assessment, and 

collection of the revenue, that is, federal income taxes. 

PURPOSE AND OBJECT OF THE CONSPIRACY 

3. It was the purpose of the conspiracy, among others, for the defendants to unlawfully 

enrich themselves by engaging in a fraudulent scheme to evade the ascertainment, computation, 

assessment, and collection of federal income taxes. 

MANNER AND MEANS OF THE CONSPIRACY 

The manner and means of the conspiracy included, but were not limited to, the following: 

4. MARIO DE LA TORRE created invoices purportedly issued by J-CONN 

Solutions to Summit Aerospace for marketing commission fees that JOE MCHOMES had 

purportedly earned by securing repair and return work from RGTS (the "J-CONN Solutions 

invoices"). In many, if not most instances, MARIO DE LA TORRE determined that the amount 

of each J-CONN Solutions invoice was approximately ten percent of a specific invoice or group 

of invoices that Summit Aerospace presented to RGTS, for repair and return work. Further, 

MARIO determined that each of the J-CONN Solutions invoices was for an amount under 

$10,000. MARIO submitted the ]-CONN Solutions invoices to Summit Aerospace for payment. 

5. YUMET DE LA TORRE arranged for Summit Aerospace to pay J-CONN 

Solutions invoices. Among other things, YUMET signed checks payable to J-CONN Solutions, 

which were drawn on Summit Aerospace's U.S. Century Bank account number ending in 1810, 

and its Florida Community Bank account number ending 0300 (the "Summit Aerospace checks"). 

6. JOE MCHOMES cashed Summit Aerospace checks and deposited a portion of 

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the cash proceeds from the Summit Aerospace checks in MARIO DE LA TORRE's Bank of 

America account number ending in 8988 ("account no. 8988"). In particular, MCHOMES 

deposited approximately the following amounts of cash in MARI O's account no. 8988, in the tax 

years 2011, 2012, 2013, 2014, and 2015: 

Tax Year Approximate Cash Deposits to Account No. 8988 

2011 $68,756 

2012 $136,068 

2013 $132,673 

2014 $124,125 

2015 $151,040 

7. MARIO DE LA TORRE and YUMET DE LA TORRE failed to disclose the 

cash that was deposited in account no. 8988, to the preparer of their federal income tax returns. 

8. MARIO DE LA TORRE and YUMET DE LA TORRE knowingly filed false 

and fraudulent federal income tax returns that did not disclose as income the cash that JOE 

MCHOMES deposited in MARIO's Bank of America account no. 8988. 

OVERT ACTS IN FURTHERANCE OF THE CONSPIRACY 

In furtherance of the conspiracy, at least one of the conspirators committed and caused to 

be committed at least one of the following overt acts, among others, in the Southern District of 

Florida, and elsewhere: 

9. On or about May 4, 2012, MARIO DE LA TORRE and YUMET DE LA 

TORRE filed with the IRS a false joint United States Individual Tax Return, IRS Form 1040, for 

the tax year 2011, which failed to report approximately $68,756 in income. 

10. On or about September 15, 2013, MARIO DE LA TORRE and YUMET DE LA 

TORRE filed with the IRS a false joint United States Individual Tax Return, IRS Form 1040, for 

the tax year 2012, which failed to report approximately $136,068 in income. 

11. On or about April 15, 2014, MARIO DE LA TORRE and YUMET DE LA 

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TORRE signed an IRS Form 8879, e-file Signature Authorization, which authorized their tax 

return preparer to enter or generate their respective PIN s, as their signatures on their 2013 

electronically-filed federal income tax return. 

12. On or about April 15, 2014, MARIO DE LA TORRE and YUMET DE LA 

TORRE filed with the IRS a false joint United States Individual Tax Return, IRS Form 1040, for 

the tax year 2013, which failed to report approximately $132,673 in income. 

13. On or about September 9, 2015, MARIO DE LA TORRE and YUMET DE LA 

TORRE filed with the IRS a false joint United States Individual Tax Return, IRS Form 1040, for 

the tax year 2014, which failed to report approximately $124,125 in income. 

14. On or about October 22, 2015, YUMET DE LA TORRE signed Summit 

Aerospace check numbers 060298, 060299, 060300, and 060301 payable to J-CONN Solutions. 

15. On or about July 27, 2016, MARIO DE LA TORRE and YUMET DE LA 

TORRE filed with the IRS a false joint United States Individual Tax Return, IRS Form 1040, for 

the tax year 2015, which failed to report approximately $151,040 in income. 

All in violation of Title 18, United States Code, Section 371. 

COUNT15 

Aiding and Abetting the Filing of a False Tax Return 

(26 u.s.c. § 7206(2)) 

On or about September 9, 2015, in Miami-Dade County, in the Southern District of Florida, 

and elsewhere, the defendants, 

MARIO RENE DE LA TORRE, 

a/k/a "Mario R. Delatorre," and 

YUMET DE LA TORRE, 

did willfully aid and assist in, and procure, counsel, and advise the preparation and presentation to 

the IRS, of a joint United States Individual Income Tax Return, IRS Form 1040, for the tax year 

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2014, which was false in that it represented on line 22 that the defendants' total joint income was 

$255,256, whereas, as the defendants then and there well knew, their total joint income was 

substantially greater that the reported amount. 

In violation of Title 26, United States Code, Section 7206(2). 

COUNT 16 

Making and Subscribing a False Tax Return 

(26 u.s.c. § 7206(1)) 

On or about July 27, 2016, in Miami-Dade County, in the Southern District of Florida, and 

elsewhere, the defendants, 

MARIO RENE DE LA TORRE, 

a/k/a "Mario R. Delatorre," and 

YUMET DE LA TORRE, 

did willfully make and subscribe a joint United States Individual Income Tax Return, IRS Form 

1040, for the tax year 2015, which was verified by a written declaration that it was made under the 

penalties of perjury, and filed with the IRS, which the defendants did not believe to be true and 

correct as to every material matter, in that line 22 of the tax return reported the defendants' total 

joint income was $239,604, whereas, as the defendants then and there well knew and believed, 

their joint total income was substantially greater than the stated amount. 

In violation of Title 26, United States Code, Section 7206(1). 

FORFEITURE ALLEGATIONS 

(18 U.S.C. § 981(a)(l)(C)) 

(18 U.S.C. § 982(a)(l)) 

(21 u.s.c. § 853) 

1. The allegations of this Information are hereby re-alleged and by this reference fully 

incorporated herein for alleging criminal forfeiture to the United States of America of certain 

property in which the defendants, MARIO RENE DE LA TORRE, a/k/a "Mario R. Delatorre," 

YUMET DE LA TORRE, and JOE LEWIS MCHOMES, a/k/a "Joe McHomes," have an 

17 

Case 1:20-cr-20185-KMW Document 1 Entered on FLSD Docket 08/12/2020 Page 17 of 27
interest. 

2. Upon conviction of a violation of, or a conspiracy to violate, Title 18, United States 

Code, Section 1341 and/or 1343, as alleged in this Information, the defendant so convicted shall 

forfeit to the United States of America, pursuant to Title 18, United States Code, Section 

98l(a)(l)(C), any property, real or personal, which constitutes or is derived from proceeds 

traceable to such violation. 

3. Upon conviction of a violation of Title 18, United States Code, Section 1956 and/or 

1957, as alleged in this Information, the defendant so convicted shall forfeit to the United States 

of America, pursuant to Title 18, United States Code, Section 982(a)(l), any property, real or 

personal, involved in such offense, or any property traceable to such property. 

All pursuant to Title 18, United States Code, Section 982(a)(l), Title 18, United States 

Code, Section 98l(a)(l)(C), as made applicable by Title 28, United States Code, Section 246l(c), 

and the procedures set forth in Title 21, United States Code, Section 853, as made applicable by 

Title 18, United States Code, Section 982(b )(I) and Title 28, United States Code, Section 2461 ( c ). 

E WARD WILLIAMS 

UNITED STATES ATTORNEY 

18 

' Case 1:20-cr-20185-KMW Document 1 Entered on FLSD Docket 08/12/2020 Page 18 of 27
UNITED ST ATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

UNITED STATES OF AMERICA CASE NO. _______________ _ 

v. 

MARIO RENE DE LA TORRE, et al., CERTIFICATE OF TRIAL ATTORNEY* 

Superseding Case Information: 

Defendants. 

Court Division: (Select One) 

✓ Miami Key West 

New defendant(s) Yes 

Number of new defendants 

No 

FTL WPB FTP Total number of counts 

1. I have carefully considered the allegations of the indictment, the number of defendants, the number of 

probable witnesses and the legal complexities of the Indictment/Information attached hereto. 

2. I am aware that the information supplied on this statement will be relied upon by the Judges of this 

Court in setting their calendars and scheduling criminal trials under the mandate of the Speedy Trial 

Act, Title 28 U.S.C. Section 3161. 

3. Interpreter: (Yes or No) No 

List language and/or dialect 

4. This case will take _8_ days for the parties to try. 

5. Please check appropriate category and type of offense listed below: 

(Check only one) (Check only one) 

I 0 to 5 days Petty 

II 6 to 10 days ✓ Minor 

III 11 to 20 days Misdem. 

IV 21 to 60 days Felony ✓ 

V 61 days and over 

6. Has this case previously been filed in this District Court? (Yes or No) 

If yes: Judge Case No. 

No 

(Attach copy of dispositive order) --------------

Has a complaint been filed in this matter? (Yes or No) 

If yes: Magistrate Case No. 

Related miscellaneous numbers: 

Defendant(s) in federal custody as of 

Defendant(s) in state custody as of 

Rule 20 from the District of 

Is this a potential death penalty case? (Yes or No) 

No 

7. Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Office 

prior to August 9, 2013 (Mag. Judge Alicia 0. Valle)? Yes No 1 

8. U.S. Attorney's Office 

*Penalty Sheet(s) attached 

No 1 

NITED STATES ATTORNEY 

Florida Bar No. 125199 

REV 8/13/2018 

Case 1:20-cr-20185-KMW Document 1 Entered on FLSD Docket 08/12/2020 Page 19 of 27
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENAL TY SHEET 

Defendant's Name: MARIO RENE DE LA TORRE 

Case No: -------------------------------

Count#: 1 

Conspiracy to Commit Mail Fraud and Wire Fraud 

Title 18 United States Code Section 1349 

* Max. Penalty: 

Counts #: 2-6 

Mail Fraud 

Twenty (20) years' imprisonment 

Title 18 United States Code Section 1341 

* Max. Penalty: Twenty (20) years' imprisonment as to each count 

Counts#: 7-11 

Wire Fraud 

Title 18, United States Code, Section 1343 

* Max. Penalty: Twenty (20) years' imprisonment as to each count 

Count#: 12 

Conspiracy to Commit Money Laundering Offenses 

Title 18, United States Code, Section 1956(h) 

* Max. Penalty: Twenty (20) years' imprisonment 

Count#: 13 

Money Laundering 

Title 18 United States Code Section 1957 

*Max.Penalty: Ten (10) years' imprisonment 

*Refers only to possible term of incarceration, does not include possible fines, restitution, 

special assessments, parole terms, or forfeitures that may be applicable. 

Case 1:20-cr-20185-KMW Document 1 Entered on FLSD Docket 08/12/2020 Page 20 of 27
Count#: 14 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENAL TY SHEET 

Conspiracy to Defraud the United States 

Title 18 United States Code Section 3 71 

*Max.Penalty: Five (5) years' imprisonment 

Count#: 15 

Aiding and Abetting the Filing of a False Tax Return 

Title 26, United States Code, Section 7206(2) 

*Max.Penalty: Three (3) years' imprisonment 

Count#: 16 

Making and Subscribing a False Tax Return 

Title 26, United States Code, Section 7206(1) 

* Max. Penalty: Three (3) years' imprisonment 

*Refers only to possible term of incarceration, does not include possible fines, restitution, 

special assessments, parole terms, or forfeitures that may be applicable. 

Case 1:20-cr-20185-KMW Document 1 Entered on FLSD Docket 08/12/2020 Page 21 of 27
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENAL TY SHEET 

Defendant's Name: YUMET DE LA TORRE 

Case No: -------------------------------

Count#: 1 

Conspiracy to Commit Mail Fraud and Wire Fraud 

Title 18 United States Code Section 1349 

*Max.Penalty: 

Counts #: 2-6 

Mail Fraud 

Twenty (20) years' imprisonment 

Title 18 United States Code Section 1341 

* Max. Penalty: Twenty (20) years' imprisonment as to each count 

Counts#: 7-11 

Wire Fraud 

Title 18 United States Code Section 1343 

* Max. Penalty: Twenty (20) years' imprisonment as to each count 

Count#: 12 

Conspiracy to Commit Money Laundering Offenses 

Title 18, United States Code, Section l 956(h) 

* Max. Penalty: Twenty (20) years' imprisonment 

Count#: 14 

Conspiracy to Defraud the United States 

Title 18 United States Code Section 3 71 

* Max. Penalty: Five (5) years' imprisonment 

*Refers only to possible term of incarceration, does not include possible fines, restitution, 

special assessments, parole terms, or forfeitures that may be applicable. 

Case 1:20-cr-20185-KMW Document 1 Entered on FLSD Docket 08/12/2020 Page 22 of 27
Count#: 15 

UNITED ST ATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENAL TY SHEET 

Aiding and Abetting the Filing of a False Tax Return 

Title 26, United States Code, Section 7206(2) 

* Max. Penalty: Three (3) years' imprisonment 

Count#: 16 

Making and Subscribing a False Tax Return 

Title 26, United States Code, Section 7206(1) 

*Max.Penalty: Three (3) years' imprisonment 

*Refers only to possible term of incarceration, does not include possible fines, restitution, 

special assessments, parole terms, or forfeitures that may be applicable. 

Case 1:20-cr-20185-KMW Document 1 Entered on FLSD Docket 08/12/2020 Page 23 of 27
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

Defendant's Name: JOE LEWIS MCHOMES 

Case No: ______________________________ _ 

Count#: 1 

Conspiracy to Commit Mail Fraud and Wire Fraud 

Title 18 United States Code Section 1349 

* Max. Penalty: 

Counts #: 2-5 

Mail Fraud 

Twenty (20) years' imprisonment 

Title 18 United States Code Section 1341 

* Max. Penalty: Twenty (20) years' imprisonment as to each count 

Counts#: 7-11 

Wire Fraud 

Title 18 United States Code Section 1343 

*Max.Penalty: Twenty (20) years' imprisonment as to each count 

Count#: 12 

Conspiracy to Commit Money Laundering Offenses 

Title 18, United States Code, Section 1956(h) 

* Max. Penalty: Twenty (20) years' imprisonment 

*Refers only to possible term of incarceration, does not include possible fines, restitution, 

special assessments, parole terms, or forfeitures that may be applicable. 

Case 1:20-cr-20185-KMW Document 1 Entered on FLSD Docket 08/12/2020 Page 24 of 27
AO 455 (Rev. 01/09) Waiver of an Indictment 

UNITED STATES DISTRICT COURT 

United States of America 

V. 

Mario Rene De La Torre, 

Defendant 

for the 

Southern District of Florida 

) 

) 

) 

) 

) 

Case No. 

WANER OF AN INDICTMENT 

I understand that I have been accused of one or more offenses punishable by imprisonment for more than one 

year. I was advised in open court of my rights and the nature of the proposed charges against me. 

After receiving this advice, I waive my right to prosecution by indictment and consent to prosecution by 

information. 

Date: -------~ Defendant's signature 

Signature of defendant's attorney 

Printed name of defendant's attorney 

Judge 's signature 

Judge 'sprinted name and title 

Case 1:20-cr-20185-KMW Document 1 Entered on FLSD Docket 08/12/2020 Page 25 of 27
! 

AO 455 (Rev. 01/09) Waiver ofan Indictment 

UNITED STATES DISTRICT COURT 

United States of America 

V. 

Yumet De La Torre, 

Defendant 

for the 

Southern District of Florida 

) 

) 

) 

) 

) 

Case No. 

WAIVER OF AN INDICTMENT 

I understand that I have been accused of one or more offenses punishable by imprisonment for more than one 

year. I was advised in open court of my rights and the nature of the proposed charges against me. 

After receiving this advice, I waive my right to prosecution by indictment and consent to prosecution by 

information. 

Date: 

Defendant's signature 

Signature of defendant's attorney 

Printed name of defendant's attorney 

Judge's signature 

Judge 'sprinted name and title 

Case 1:20-cr-20185-KMW Document 1 Entered on FLSD Docket 08/12/2020 Page 26 of 27
AO 455 (Rev. 01/09) Waiver ofan Indictment 

UNITED STATES DISTRICT COURT 

United States of America 

V. 

Joe Lewis McHomes, 

Defendant 

for the 

Southern District of Florida 

) 

) 

) 

) 

) 

Case No. 

WAIVER OF AN INDICTMENT 

I understand that I have been accused of one or more offenses punishable by imprisonment for more than one 

year. I was advised in open court of my rights and the nature of the proposed charges against me. 

After receiving this advice, I waive my right to prosecution by indictment and consent to prosecution by 

information. 

Date: -------- Defendant's signature 

Signature of defendant's attorney 

Printed name of defendant's attorney 

Judge's signature 

Judge 'sprinted name and title 

Case 1:20-cr-20185-KMW Document 1 Entered on FLSD Docket 08/12/2020 Page 27 of 27