UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. ---=22=--....;:;:C=R=----8=0=1--=-44.;:_-=SMI=T=H/MA==-=Y.;;..;N=ARD=""'"{s"""')"""{s.,_) __ _ 

UNITED STATES OF AMERICA 

vs. 

18 u.s.c. § 1349 

18 U.S.C. § 1956(h) 

18 U.S.C. § 1425(a) 

18 u.s.c. § 1343 

18 U.S.C. § 1028A(a)(l) 

18 U.S.C. § 1956(a)(l)(B)(i) 

18 U.S.C. § 1956(a)(2)(B)(i) 

18 u.s.c. § 1957 

18 U.S.C. § 982(a) 

JOFF STENN WROY PIDLOSSAINT, 

MARIEL TOLLINCHI, 

REGINE MARIE RENE, 

BRIANNA MONIQUE GAYLE, 

MAURICE SHAZIER, and 

ROBENSON LAUVINCE, 

Defendants. 

I ---------------

DEC 1 5 2022 

ANGELA E. NOBLE 

CLERK U.S. DIST. CT. 

S.D. OF FLA. - W.P.8. 

SECOND SUPERSEDING INDICTMENT 

The Grand Jury charges that: 

GENERAL ALLEGATIONS 

At all times material to this Second Superseding Indictment: 

The Paycheck Protection Program 

1. The Coronavirus Aid, Relief, and Economic Security ("CARES") Act was a federal 

law enacted in or around March 2020 and designed to provide emergency financial assistance to 

the millions of Americans who were suffering the economic effects caused by the COVID-19 

pandemic. One source of relief provided by the CARES Act was the authorization of forgivable 

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loans to small businesses for job retention and certain other expenses, through a program referred 

to as the Paycheck Protection Program ("PPP"). 

2. The types of businesses eligible for a loan included sole proprietorships. In order to 

obtain a PPP loan, a qualifying business (through its authorized representative or the sole 

proprietor) signed and submitted a PPP loan application (Small Business Administration ("SBA") 

Form 2483) online through the lender's application platform. In order to be eligible to obtain the 

PPP loan, the PPP loan application required the business (through its authorized representative or 

the sole proprietor) to acknowledge the program rules and make certain affirmative certifications. 

The certifications included an attestation that the business was in operation on February 15, 2020, 

and had employees for whom it paid salaries and payroll taxes, or paid independent contractors, 

or was a sole proprietorship with no employees. In the PPP loan application, the small business 

(through its authorized representative or the sole proprietor) was required to provide, among other 

things, its average monthly payroll expenses and number of employees. In addition, businesses 

applying for the PPP loan were required to provide documentation confirming their payroll 

expenses. Typically, businesses supplied documents showing the amount of payroll taxes reported 

to the Internal Revenue Service ("IRS"). The sole proprietorship had to report and document the 

business' income and expenses, as typically reported to the IRS on Fo1m 1040, Schedule C. These 

figures and documentation were used to calculate the amount of money the small business was 

eligible to receive under the PPP. Sole proprietorships were eligible to receive a maximum PPP 

loan of up to $20,833 to cover lost income. 

3. A PPP loan application was processed by a participating lender. The SBA delegated 

authority to third-party lenders to underwrite and approve the loans. If a PPP loan application was 

approved, the participating lender funded the PPP loan using its own monies, which were 100% 

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guaranteed by the SBA. Data from the application, including information about the borrower, the 

total amount of the loan, and the listed number of employees, was transmitted electronically by 

the lender to the SBA in the course of processing the loan. 

4. PPP loan proceeds were required to be used by the business on certain permissible 

expenses - payroll costs, interest on mortgages, rent, and utilities. The PPP allowed the interest 

and principal on the PPP loan to be entirely forgiven if the business spent the loan proceeds on 

these expense items within a designated period of time and used a defined portion of the PPP loan 

proceeds on payroll expenses. 

The Economic Injury Disaster Loan Program 

5. Before the COVID-19 pandemic, SBA's Economic Injury Disaster Loan ("EIDL") 

program provided low-interest financing to small businesses, renters, and homeowners in regions 

affected by declared disasters. 

6. The CARES Act also authorized the SBA to provide EIDL assistance to eligible 

small businesses experiencing "substantial economic injury" (substantial financial disruptions) 

due to the COVID-19 pandemic. In order to obtain a COVID-19 EIDL, a qualifying business was 

required to submit electronically an EIDL application to the SBA and provide information about 

its operations, such as the number of employees, gross revenues, and the cost of goods sold for the 

12-month period preceding January 31 , 2020. The applicant was also required to certify under 

penalty of perjury that all of the information in the EIDL application was true and correct to the 

best of the applicant's knowledge. Before receiving a loan, a borrower was required to sign a Loan 

Authorization and Agreement. Pursuant to that agreement, it was a condition of the loan that the 

borrower would use the loan solely as working capital to alleviate economic injury caused by a 

disaster occurring in January 2020 and continuing thereafter. 

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7. EIDL applications were submitted directly to, and processed by, the SBA, with 

support from a government contractor. EIDL funds were issued directly from the United States 

Treasury. 

8. In addition, the CARES Act authorized the SBA to issue advances of up to $10,000 

to small businesses within three days of applying for an EIDL. The amount of the advance was 

determined by the number of employees the applicant certified having at the small business. The 

advances did not have to be repaid. 

9. SBA's email and loan application servers were located outside the State of Florida, 

so wire communications between banks and the SBA and between EIDL applicants located within 

Florida and the SBA necessarily traveled in interstate commerce. 

The Defendants, Businesses, and Lenders 

10. Defendant JOFF STENN WROY PHILOSSAINT was a resident of Broward and 

Miami-Dade Counties, in the Southern District of Florida. 

11. Defendant MARIEL TOLLINCHI was a resident of Broward County, m the 

Southern District of Florida. 

12. Defendant REGINE MARIE RENE was a resident of Palm Beach County, in the 

Southern District of Florida. 

13 . Defendant BRIANNA MONIQUE GAYLE was a resident of Palm Beach and 

Miami-Dade Counties, in the Southern District of Florida. 

14. Defendant MAURICE SHAZIER was a resident of St. Lucie County, in the Southern 

District of Florida. 

15. Defendant ROBENSON LAUVINCE was a resident of Broward County, in the 

Southern District of Florida. 

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16. Co-conspirator David Andre Johnson was a resident of Broward County, in the 

Southern District of Florida. 

17. Defendant JOFF STENN WROY PHILOSSAINT was the principal and registered 

agent of Royal Elite Trans, LLC ("ROY AL ELITE"), Elite International Financial Group, a/k/a 

Elite International Venture Capital ("EIVC"), and One Solution Group LLC ("ONE 

SOLUTION"), purported businesses located in Broward County, in the Southern District of 

Florida. 

18. Defendant MARIEL TOLLINCHI was the Treasurer of the Cinda Foundation Inc. 

("CINDA"), and her family members were the principals and registered agents of CINDA, Ferro's 

Entertainment and Production LLC ("FERRO'S"), and D.F. d/b/a "Perfect Landscaping" 

("PERFECT LANDSCAPING"), purported businesses located in Broward County, in the 

Southern District of Florida. TOLLINCHI was also the principal of Tollinchi Law P.A. 

("TOLLINCHI LAW"), a law firm located in Broward County, in the Southern District of Florida. 

19. Defendant JOFF STENN WROY PHILOSSAINT was the president and registered 

agent of Dad Money Investment Group, LLC ("DAD MONEY"), a purported business located in 

Broward County, in the Southern District of Florida. 

20. Defendant REGINE MARIE RENE was the principal and registered agent of Unfold 

Perception, LLC ("UNFOLD"), a purported business located in Palm Beach County, in the 

Southern District of Florida. 

21. Defendant BRIANNA MONIQUE GAYLE was an employee of EIVC and 

purportedly owned a sole proprietorship in her name located in Palm Beach County, in the 

Southern District of Florida. 

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22. Defendant MAURICE SHAZIER was the principal and registered agent of Sunrise 

City Construction Development LLC ("SUNRJSE CITY") and JREAM Vision T.V. LLC 

("JREAM"), purported businesses located in St. Lucie County, in the Southern District of Florida. 

23. Defendant ROBENSON LAUVINCE was the principal and the registered agent of 

Clear Shot Entertainment LLC ("CLEAR SHOT"), a purported business located in Broward 

County, in the Southern District of Florida. 

24. Co-conspirator David Andre Johnson was the principal and registered agent of 

D.D.Z. Family Enterprises L.L.C. ("DDZ"), a purported business located in Broward County, in 

the Southern District of Florida. 

25. Lender #1 was headquartered in New Jersey and was an approved SBA lender for 

PPP loans. 

26. Lender #2 was headquartered in Delaware and was an approved SBA lender for PPP 

loans. 

27. Lender #3 was headquartered in Utah and was an approved SBA lender for PPP 

loans. 

COUNT 1 

(Conspiracy to Commit Wire Fraud: 18 U.S.C. § 1349) 

Paragraphs 1 through 27 of the General Allegations Section of this Second Superseding 

Indictment are re-alleged and incorporated by reference as though fully set forth herein. 

From in or around April 2020, continuing through on or about August 7, 2022, the exact 

dates being unknown to the Grand Jury, in Palm Beach, St. Lucie, Broward, and Miami-Dade 

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

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MARIEL TOLLINCHI, 

REGINE MARIE RENE, 

BRIANNA MONIQUE GAYLE, 

MAURICE SHAZIER, and 

ROBENSON LAUVINCE, 

and Joff Stenn Wroy Philossaint did wi llfully, that is, with the intent to further the object of the 

conspiracy, and knowingly combine, conspire, confederate, and agree with each other and with 

persons known and unknown to the Grand Jury, to knowingly, and with the intent to defraud, 

devise, and intend to devise, a scheme and artifice to defraud, 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, did transmit and cause to be transmitted, by means 

of wire communications in interstate and foreign commerce, certain writings, signs, signals, 

pictures, and sounds, in violation of Title 18, United States Code, Section 1343. 

OBJECT OF THE CONSPIRACY AND THE SCHEME AND ARTIFICE 

It was the object of the conspiracy and of the scheme and artifice for the Defendants and 

their co-conspirators to unlawfully enrich themselves by, among other things: (1) creating false 

and fraudulent documents, including payroll records and tax documents; (2) subm itting and 

causing the submission of fa lse and fraudulent applications for loans and loan agreements made 

avai lable through the SBA to provide relief for the economic effects caused by the COVlD-19 

pandemic, including EIDL and PPP loans; (3) offering, paying, and receiving kickbacks in return 

for causing the submission of false and fraudulent loan app lications; (4) diverting fraud proceeds 

for the Defendants' and co-conspirators' personal use and benefit, the use and benefit of others, 

and to further the conspiracy and the scheme and artifice; and (5) submitting and causing the 

submission of false and fraudulent applications for forgiveness of the received loans. 

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MANNER AND MEANS 

The manner and means by which the defendants and their co-conspirators sought to 

accomplish the object of the conspiracy and the scheme and artifice included, among others, the 

following: 

(a) Joff Stenn Wroy Philossaint and BRIANNA MONIQUE GAYLE created 

and caused the creation of false and fraudulent tax documents for business entities owned and 

controlled by themselves, MARIEL TOLLINCHI, REGINE MARIE RENE, MAURICE 

SHAZIER, ROBENSON LAUVINCE, David Andre Johnson, and others known and unknown to 

the Grand Jury, for the purpose of applying for PPP and EIDL loans. 

(b) Joff Stenn Wroy Philossaint, MARIEL TOLLINCHI, REGINE MARIE 

RENE, BRIANNA MONIQUE GAYLE, MAURICE SHAZIER, ROBENSON LA UV INCE, 

David Andre Johnson, and others known and unknown to the Grand Jury submitted and caused 

the submission of false and fraudulent PPP and EIDL loan appl ications and loan agreements. 

(c) The PPP and EIDL loan applications and agreements submitted, or caused 

to be submitted, by Joff Stenn Wroy Philossaint, MARIEL TOLLINCHI, REGINE MARIE 

RENE, BRIANNA MONIQUE GAYLE, MAURICE SHAZIER, ROBENSON LAUVINCE, 

David Andre Johnson, and others known and unknown to the Grand Jury included false and 

fraudulent tax documents and made false and fraudulent representations about the borrowing 

entities' number of employees, amount of monthly payroll, gross income, cost of goods sold, and 

the purposes for which the loans would be used. 

(d) Joff Stenn Wroy Philossaint and BRIANNA MONIQUE GAYLE created 

and caused the creation of false and fraudulent payroll accounts with a payroll processing service 

for business entities owned and controlled by themselves, MARIEL TOLLINCHI, REGINE 

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MARIE RENE, MAURICE SHAZIER, ROBENSON LAUVINCE, David Andre Johnson, and 

others known and unknown to the Grand Jury, for the purpose of applying for PPP loans and PPP 

loan forgiveness. 

(e) Having obtained PPP loans for those entities, Joff Stenn Wray Philossaint, 

MARIEL TOLLINCHI, REGINE MARIE RENE, BRIANNA MONIQUE GAYLE, MAURICE 

SHAZIER, ROBENSON LAUVINCE, David Andre Johnson, and others known and unknown to 

the Grand Jury caused the electronic wire transfer of a portion of the loan proceeds to a payroll 

processing service to make it appear that the proceeds were being used for legitimate payroll 

expenses. 

(f) Having obtained PPP and EIDL loans for their business entities, Joff Stenn 

Wray Philossaint caused MARIEL TOLLINCHI, REGINE MARIE RENE, BRIANNA 

MONIQUE GAYLE, MAURICE SHAZIER, ROBENSON LAUVINCE, David Andre Johnson, 

and others known and unknown to the Grand Jury to pay kickbacks of approximately 10% of the 

loans' values to Joff Stenn Wray Philossaint via checks and wire transfers that were often disguised 

to appear to be legitimate business expenses. 

(g) Joff Stenn Wray Philossaint, MARIEL TOLLINCHI, REGINE MARIE 

RENE, BRIANNA MONIQUE GAYLE, MAURICE SHAZIER, ROBENSON LAUVINCE, 

David Andre Johnson, and others known and unknown to the Grand Jury submitted and caused 

the submission of false and fraudulent applications for PPP loan forgiveness for these business 

entities. 

(h) As a result of the false and fraudulent representations that Joff Stenn Wray 

Philossaint, MARIEL TOLLINCHI, REGINE MARIE RENE, BRIANNA MONIQUE GAYLE, 

MAURICE SHAZIER, ROBENSON LAUVINCE, David Andre Johnson, and others known and 

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unknown to the Grand Jury made in the PPP and EIDL loan applications submitted as part of this 

scheme, financial institutions and the SBA disbursed loan proceeds to the Defendants and their coconspirators in the amount of approximately $8.1 million. 

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

COUNT2 

(Conspiracy to Commit Money Laundering: 18 U.S.C. § 1956(h)) 

From in or around April 2020, continuing through on or about August 7, 2022, the exact 

dates being unknown to the Grand Jury, in Palm Beach, St. Lucie, Broward, and Miami-Dade 

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

MARIEL TOLLINCHI, 

REGINE MARIE RENE, 

BRIANNA MONIQUE GAYLE, 

MAURICE SHAZIER, and 

ROBENSON LAUVINCE, 

and Joff Stenn Wray Philossaint did knowingly and voluntarily combine, conspire, confederate, 

and agree with each other, and with persons known and unknown to the Grand Jury, to knowingly 

conduct, and attempt to conduct, a financial transaction affecting interstate and foreign commerce 

involving the proceeds of specified unlawful activity, knowing that the property involved in the 

transaction represented the proceeds of some form of unlawful activity, 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, in violation of 18 U.S.C. 

§ 1956(a)(l)(B)(i). 

It is further alleged that the specified unlawful activity is wire fraud, in violation of 18 

U.S.C. § 1343. 

All in violation of Title 18, United States Code, Section 1956(h). 

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COUNT3 

(Conspiracy to Commit Money Laundering: 18 U.S.C. § 1956(h)) 

From in or around April 2020, continuing through on or about August 7, 2022, the exact 

dates being unknown to the Grand Jury, in Palm Beach, St. Lucie, Broward, and Miami-Dade 

Counties, in the Southern District of Florida, and elsewhere, the defendant, 

MARIEL TOLLINCHI, 

and Joff Stenn Wroy Philossaint did knowingly and voluntarily combine, conspire, confederate, 

and agree with each other and with persons known and unknown to the Grand Jury, to: 

(a) knowingly transmit and transfer monetary instruments and funds, from a 

place inside the United States to and through a place outside the United States, knowing that the 

monetary instruments and funds involved in such transmission and transfer represented the 

proceeds of some form of unlawful activity, and knowing that such transmission and transfer was 

designed in whole and in part to conceal and disguise the nature, location, source, ownership, and 

control of the proceeds of specified unlawful activity, in violation of 18 U.S.C. § l 956(a)(2)(B)(i); 

and 

(b) knowingly engage in a monetary transaction by, through, and to a financial 

institution, affecting interstate and foreign commerce, in criminally derived property of a value 

greater than $10,000 that is derived from specified unlawful activity, in violation of 18 U.S.C. 

§ 1957. 

It is further alleged that the specified unlawful activity is wire fraud , in violation of 18 

U.S.C. § 1343. 

All in violation of Title 18, United States Code, Section 1956(h). 

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COUNT4 

(Obtaining Citizenship by Fraud: 18 U.S.C. § 1425(a)) 

Paragraphs 1 through 9 of the General Allegations Section of this Superseding Indictment 

are re-alleged and incorporated by reference as though fully set forth herein. 

Beginning at least as early as December 15, 2020, and continuing through on or about 

February 9, 2021 , in Broward and Miami-Dade Counties, in the Southern District of Florida, and 

elsewhere, the defendant, 

JOFF STENN WROY PHILOSSAINT, 

did knowingly procure and attempt to procure, contrary to law, naturalization as a United States 

citizen for himself, to wit, the defendant obtained and attempted to obtain naturalization by falsely 

swearing to a statement in his written Form N-400 (Application for Naturalization), his 

naturalization interview, and his written Form N-455 (Notice of Naturalization Oath Ceremony), 

that: 

(a) he had not knowingly committed, assisted in committing, or attempted to 

commit, a crime or offense for which he had not been arrested, when in truth and in fact, as the 

defendant then and there well knew, he had committed the offenses of wire fraud conspiracy, and 

money laundering conspiracy, as charged in Counts 1 through 3 of this Second Superseding 

Indictment; and 

(b) he had not made any misrepresentation to obtain any public benefit in the 

United States, when in truth and in fact, as the defendant then and there well knew, he had 

misrepresented businesses, their earnings, and their employee workforces in an effort to obtain 

multiple loans and advances, and forgiveness of those loans and advances pursuant to the United 

States' Paycheck Protection Program and the Economic Injury Disaster Loan Program. 

All in violation of Title 18, United States Code, Section 1425(a). 

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COUNTS 5-25 

(Wire Fraud: 18 U.S.C. § 1343) 

The General Allegations Section of this Second Superseding Indictment is re-alleged and 

incorporated by reference as though fully set forth herein. 

From in or around April 2020, continuing through on or about August 7, 2022, the exact 

dates being unknown to the Grand Jury, in Palm Beach, St. Lucie, Broward, and Miami-Dade 

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

MARIEL TOLLINCHI, 

REGI E MARIE RENE, 

BRIANNA MONIQUE GAYLE, 

MAURICE SHAZIER, and 

ROBENSON LAUVINCE, 

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

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

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

18, United States Code, Section 1343. 

OBJECT OF THE SCHEME AND ARTIFICE 

The section of Count 1 of this Second Superseding Indictment entitled "Object of the 

Conspiracy and the Scheme and Artifice" is realleged and incorporated by reference as though 

fully set forth herein to describe the object of the scheme and artifice. 

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THE SCHEME AND ARTIFICE 

The section of Count 1 of this Second Superseding Indictment entitled "Manner and 

Means" is realleged and incorporated by reference as though fully set forth herein to describe the 

manner and means of the scheme and artifice. 

USE OF WIRES 

On or about the dates specified as to each count below, in Palm Beach, St. Lucie, Broward, 

and Miami-Dade Counties, in the Southern District of Florida, and elsewhere, the specified 

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

defraud, 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, did knowingly transmit and cause to be transmitted, by means of 

wire communications in interstate and foreign commerce, certain writings, signs, signals, pictures, 

and sounds, as described below: 

Count Date Defendants Interstate Wire 

5 6/ 15/2020 ROBENSON Electronic submission of PPP loan application 

LAUVINCE to Lender #3 on behalf of CLEAR SHOT 

6 6/18/2020 REGINE MARIE Electronic submission of PPP loan application 

RENE to Lender #3 on behalf of UNFOLD 

7 7/8/2020 ROBENSON Electronic transmission of loan agreement, 

LAUVINCE note, and related documents to SBA on behalf 

of CLEAR SHOT 

8 7/ 13/2020 MARIEL Electronic submission of EIDL application to 

TOLLINCHI SBA on behalf of PERFECT 

LANDSCAPING 

9 7/ 16/2020 MAURICE Electronic submission of EIDL application to 

SHAZIER SBA on behalf of SUNRISE CITY 

10 7/21/2020 MARIEL Electronic submission of EIDL application to 

TOLLINCHI SBA on behalf ofFERRO' S 

11 7/31 /2020 MAURICE Electronic submission of EIDL app lication to 

SHAZIER SBA on behalf of JREAM 

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Count Date Defendants Interstate Wire 

12 8/2/2020 REGINE MARIE Electronic submission ofEIDL application to 

RENE SBA on behalf of UNFOLD 

13 8/5/2020 MAURICE Electronic transmission of loan agreement, 

SHAZIER note, and related documents to SBA on behalf 

of SUNRISE CITY 

14 2/12/202 1 MAURICE Electronic submission of PPP loan application 

SHAZIER to Lender #1 on behalf of SUNRISE CITY 

15 2/12/2021 MAURICE Electronic submission of PPP loan application 

SHAZIER to Lender # 1 on behalf of JREAM 

16 2/14/202 1 BRIANNA Electronic submission of PPP loan application 

MONIQUE to Lender #2 on behalf of BRIANNA 

GAYLE MONIQUE GAYLE 

17 2/14/2021 ROBENSON Electronic transmission of loan agreement, 

LAUVINCE note, and related documents to Lender #2 on 

behalf of CLEAR SHOT 

18 2/15/202 1 MARIEL Electronic submission of PPP loan application 

TOLLINCHI to Lender #2 on behalf of CINDA 

19 2/22/202 1 REGINE MARIE Electronic submission of PPP loan application 

RENE to Lender #3 on behalf of UNFOLD 

20 4/19/202 1 MARIEL Electronic transmission of documents to a 

TOLLINCHI payroll processing service to open a payroll 

account on behalf of CINDA 

21 5/5/2021 MAURICE Electronic submission of PPP loan application 

SHAZIER to Lender # 1 on behalf of SUNRISE CITY 

22 5/5/202 1 MAURICE Electronic submission of PPP loan application 

SHAZIER to Lender # 1 on behalf of JREAM 

23 5/6/202 1 REGINE MARIE Electronic transmission of documents to a 

RENE and payroll processing service to open a payroll 

BRIANNA account on behalf of UNFOLD. 

MONIQUE 

GAYLE 

24 6/11/202 1 MARIEL Electronic transmission of Form 4506-T 

TOLLINCHI (Disaster Request for Transcript of Tax 

Return) to SBA on behalf of PERFECT 

LANDSCAPING 

25 6/11/2021 MARIEL Electronic transmission of Form 4506-T 

TOLLINCHI (Disaster Request for Transcript of Tax 

Return) to SBA on behalfofFERRO' S 

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COUNT26 

(Aggravated Identity Theft: 18 U.S.C. § 1028A(a)(l)) 

On or about April 19, 2021, in Broward County, in the Southern District of Florida, and 

elsewhere, the defendant, 

MARIEL TOLLINCHI, 

during and in re lation to felony violations of Title 18, United States Code, Section 1349, that is, 

conspiracy to commit wire fraud, as charged in Count 1 of this Second Superseding Indictment, 

and of Titl e 18, United States Code, Section 1343, that is, wire fraud, as charged in Count 20 of 

this Second Superseding Indictment, did knowingly transfer, possess, and use, without lawful 

authority, the means of identification of another person, that is, the name, date of birth, and Social 

Security number ofN.T., in violation of Title 18, United States Code, Sections 1028A(a)(l) and 2. 

COUNTS 27- 33 

(Money Laundering: 18 U.S.C. § 1956(a)(l)(B)(i)) 

The General Allegations Section of this Second Superseding Indictment is re-alleged and 

incorporated by reference as though fu lly set forth herein . 

On or about the dates set forth in each Count below, in Broward and Miami-Dade Counties, 

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

MARIEL TOLLINCHI, 

REGINE MARIE RENE, 

BRIANNA MONIQUE GAYLE, 

MAURICE SHAZIER, and 

ROBENSON LAUVINCE 

did knowingly conduct and attempt to conduct a financial transaction affecting interstate and 

fore ign commerce involving the proceeds of spec ified unlawful activity, knowing that the property 

involved in the transaction represented the proceeds of some form of unlawful activity, and 

knowing that the transaction was designed, in whole and in part, to conceal and disguise the nature, 

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location, source, ownership, and control of the proceeds of said specified unlawful activity, as 

more specifically described below: 

Count Date Defendant Financial Transaction 

27 6/18/2020 ROBENSON Deposit of check number 1097 in the amount of 

LAUVINCE approximately $18,270, drawn on CLEAR 

SHOT's account ending in 5325 at Wells Fargo 

Bank, with a notation of "account setup", into 

ROY AL ELITE's account ending in 0080 at 

Bank of America. 

28 3/12/21 REGINE MARIE Deposit of check number 101 9 in the amount of 

RENE approximately $5,597, drawn on UNFOLD's 

account ending in 8839 at Wells Fargo Bank, 

with a notation of "accounting," into EIVC's 

account ending in 4241 at Synovus Bank. 

29 3/25/2021 BRIANNA Deposit of check number 171 in the amount of 

MONIQUE approximately $3994, drawn on BRIANNA 

GAYLE MONIQUE GA YLE's account ending in 7876 

at Navy Federal Credit Union, into DAD 

MONEY's account ending in 4266 at Synovus 

Bank. 

30 4/15/202 1 MARIEL Deposit of check number 1062 in the amount of 

TOLLINCHI approximately $7,500, drawn on CINDA's 

account ending in 6917 at Popular Bank, with a 

notation of "Legal Services," into TOLLINCHI 

LA W's account ending in 6299 at Chase Bank. 

31 4/28/2021 MARIEL Deposit of check number 1067 in the amount of 

TOLLINCHI approximately $3,500, drawn on CINDA's 

account ending in 6917 at Popular Bank, with a 

notation of "Legal Services," into TOLLINCHI 

LA W's account ending in 6299 at Chase Bank. 

32 5/17/2021 MAURICE Deposit of check number 1017 in the amount of 

SHAZIER approximately $10,000, drawn on SUNRISE 

CITY's account ending in 7117 at Bank of 

America, with a notation of "advertisement," 

into EIVC's account ending in 4241 at Synovus 

Bank. 

33 5/18/202 1 MAURICE Electronic wire transfer of approximately 

SHAZIER $7.300 from JREAM's account ending in 0316 

at Wells Fargo Bank, with a notation of 

"advertisement commission," into EIVC's 

account ending in 6361 at Synovus Bank. 

17 

Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 17 of 30
It is further alleged that the specifi ed unlawful activity was wire fraud, in violation of Title 

18, United States Code, Section 1343. 

In violation of Title 18, United States Code, Sections l 956(a)(l)(B)(i) and 2. 

COUNTS 34-35 

(International Money Laundering: 18 U.S.C. § 1956(a)(2)(B)(i)) 

The General Allegations Section of this Second Superseding Indictment is re-alleged and 

incorporated by reference as though fully set forth herein . 

On or about the dates set forth in each Count be low, in Broward County, in the Southern 

District of Florida, and elsewhere, the defendant, 

MARIEL TOLLINCID, 

did knowingly transmit and transfer and attempt to transmit and transfer monetary instruments and 

funds from a place inside the United States to and through a place outside the United States, 

knowing that the monetary instruments and fund s involved in such transmission and transfer 

represented the proceeds of some form of unlawful activity, and knowing that such transmission 

and transfer was designed in whole and in part to conceal and disguise the nature, location, source, 

ownership, and control of the proceeds of specified unlawful activity, as more specifically 

described below: 

Count Date Description of Financial Transaction 

34 1/6/2022 Electronic wire transfer of approximately $26,371 from TOLLINCHI 

LA W's account ending in 1969 at Chase Bank to an account in the 

Dominican Republic. 

35 1/25/2022 Electronic wire transfer of approximately $200,000 from TOLLINCHI 

LA W's account ending in 1969 at Chase Bank to an account in the 

Dominican Republic. 

It is fu rther alleged that the specified unl awful activity was wire fraud, in violation of Title 

18, United States Code, Section 1343. 

18 

Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 18 of 30
In violation of Title 18, United States Code, Sections l 956(a)(2)(B)(i) and 2. 

COUNTS 36-37 

(Engaging in a Transaction in Criminally Derived Property: 18 U.S.C. § 1957) 

On or about the dates set forth in each Count below, in Broward County, in the Southern 

District of Florida, and elsewhere, the defendants, 

MARIEL TOLLINCHI and 

ROBENSON LAUVINCE, 

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 of a value 

greater than $10,000, as more specifically described below, such property having been derived 

from a specified unlawful activity, and knowing that the property involved in the financial 

transaction represented the proceeds of some form of unlawful activity. 

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

18, United States Code, Section 1343. 

Count Date Defendant Financial Transaction 

36 6/18/2020 ROBENSON Deposit of check number 1097 in the amount of 

LAUVINCE approximately $18,270, drawn on CLEAR 

SHOT's account ending in 5325 at Wells Fargo 

Bank, with a notation of "account setup", into 

ROYAL ELITE's account ending in 0080 at 

Bank of America. 

37 7/27/2020 MARIEL Electronic wire trartsfer of approximately 

TOLLINCHI $70,800 from D.F. 's account ending in 3145 at 

Popular Bank to TOLLINCHI LA W's account 

ending in 6299 at Chase Bank 

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

FORFEITURE ALLEGATIONS 

1. The allegations of this Superseding Indictment are hereby re-alleged and by this 

reference fully incorporated herein for the purpose of alleging forfeiture to the United States of 

19 

Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 19 of 30
America of certain property in which the defendants, MARIEL TOLLINCID, REGINE MARIE 

RENE, BRIANNA MONIQUE GAYLE, MAURICE SHAZIER, and ROBENSON LAUVINCE 

have an interest. 

2. Upon conviction of a violation of Title 18, United States Code, Section 1349 or 

1343, as alleged in this Second Superseding Indictment, the defendant shall forfeit to the United 

States any property constituting, or derived from, proceeds obtained, directly or indirectly, as the 

result of such offense, pursuant to Title 18, United States Code, Section 982(a)(2)(A). 

3. Upon conviction of a violation of Title 18, United States Code, Section 1956(h), 

1956(a)(l)(B)(i), 1956(a)(2)(B)(i), or 1957, as alleged in this Second Superseding Indictment, the 

defendant shall forfeit to the United States any property, real or personal, involved in such offense, 

and any property traceable to such property, pursuant to Title 18, United States Code, Section 

982(a)(l). 

4. Upon conviction of a violation of Title 18, United States Code, Section 1425, as 

alleged in this Second Superseding Indictment, the defendant shall forfe it to the United States, 

pursuant to Title 18, United States Code, Section 982(a)(6), 

(i) any conveyance, including any vessel, vehicle, or aircraft used in the 

commission of the offense; and 

(ii) any property real or personal-

(!) that constitutes, or is derived from or is traceable to the proceeds 

obtained directly or indirectly from the commission of the offense; or 

(II) that is used to facilitate, or is intended to be used to fac ilitate, the 

commission of the offense. 

20 

Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 20 of 30
All pursuant to Title 18, United States Code, Sections 982(a)(l) and 982(a)(2)(A), and the 

procedures set forth at Title 21 , United States Code, Section 853, as incorporated by Title 18, 

United States Code, Sections 982(6 )(1 ). 

IO GONZALEZ 

ATES ATTORNEY 

/AM- O.sl-u..-

MARC OSBORNE 

ASSISTANT UNITED STATES ATTORNEY 

A TRUE BILL. 

FOREPERSON 

21 

Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 21 of 30
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

UNITED STATES OF AMERICA CASE N0.:22-CR-80144-SMITH/MA YNARD(s)(s) . 

v. 

CERTIFICATE OF TRIAL ATTORNEY* 

JOFF S. W. PIIlLOSSAINT, et al. 

I -------------- Defendants. 

Court Division (select one) 

□ Miami □ Key West □ FTP 

□ FTL IZ] WPB 

I do hereby certify that: 

Superseding Case Information: 

New Defendant( s) (Yes or No) Yes 

Number of New Defendants 1 

Total number of New Counts 33 

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. §3161 . 

3. Interpreter: (Yes or No) No 

List language and/or dialect: 

4. This case will take 15 days for the parties to try. 

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

(Check only one) 

I □ 0 to 5 days 

II □ 6 to 10 days 

III Eil 11 to 20 days 

IV Dl 21 to 60 days 

V 61 days and over 

(Check only one) 

□ Petty 

□ Minor 

□ Misdemeanor 

GI Felony 

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

If yes, Judge Smith Case No. 22-Cr-80144 

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

If yes, Magistrate Case No. 22-8336, 22-8337, 22-8357, 22-8579 

8. Does this case relate to a previously filed matter in this District Court? (Yes or No) No 

If yes, Judge Case No. 

9. Defendant(s) in federal custody as of 

10. Defendant(s) in state custody as of 

11. Rule 20 from the District of 

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

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

prior to August 8, 2014 (Mag. Judge Shaniek Maynard? (Yes or No) No 

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

prior to October 3, 2019 (Mag. Judge Jared Strauss? (Yes or No)No 

By: 

MARC OSBORNE 

Assistant United States Attorney 

Court ID No. A550796 

Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 22 of 30
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

Defendant's Name: JOFF STENN WROY PHILOSSAINT 

Case No: 22-CR-801 44-SMITH/MAYNARD(s) (s) 

Count #4: 

Acquiring Naturalized U.S. Citizenship through Fraud 

Title 18, United States Code, Section 1425(a) 

* Max. Term oflmprisonment: 10 years 

* Max.Supervised Release: 3 years 

* Max. Fine: $250,000 

*Refers only to possible term of incarceration, supervised release and fines. It does not include 

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

Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 23 of 30
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

Defendant's Name: MARIEL TOLLINCID 

Case No: 22-CR-80 144-SMITH/MA YNARD(s)(s) 

Count # 1: 

Conspiracy to Commit Wire Fraud 

Title 18, Un ited States Code, Section 1349 

* Max. Term oflmprisonment: 20 years 

*Max.Supervised Release: 3 years 

* Max. Fine: $250,000 or twice gross loss or gross gain 

Count #2: 

Conspiracy to Commit Money Laundering 

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

*Max.Term of Imprisonment: 20 years 

*Max.Supervised Release: 3 years 

* Max. Fine: $500,000 or twice amount laundered 

Count #3: 

Conspiracy to Commit Money Laundering 

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

* Max. Term oflmprisonment: 20 years 

* Max.Supervised Release: 3 years 

* Max. Fine: $500,000 or twice amount laundered 

Counts #8, 10, 18, 20, 24, 25: 

Wire Fraud 

Title 18 United States Code Section 1343 

* Max. Term oflmprisonment: 20 years 

*Max.Supervised Release: 3 years 

* Max. Fine: $250,000 or twice gross loss or gain 

*Refers only to possible term of incarceration, supervised release and fines. It does not 

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

Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 24 of 30
Count #26: 

Aggravated identity theft 

Title 18, United States Code, Section 1028A 

* Min. & Max. Term oflmprisonment: 2 years consecutive to any other term of 

imprisonment imposed on the person under any other provision of law 

* Max.Supervised Release: 3 years 

* Max. Fine: $250,000 

Counts #30-31: 

Money Laundering 

Title 18, United States Code, Section 1956(a)(l)(B)(i) 

* Max. Term oflmprisonment: 20 years 

*Max.Supervised Release: 3 years 

* Max. Fine: $500,000 or twice amount laundered 

Counts #34-35 : 

International Money Laundering 

Title 18, United States Code, Section l 956(a)(2)(B)(i) 

* Max. Term oflmprisonment: 20 years 

* Max. Supervised Release: 3 years 

* Max. Fine: $500,000 or twice amount laundered 

Count #37: 

Engaging in a Transaction in Criminally Derived Property 

Title 18 United States Code Section 1957 

*Max.Term oflmprisonment: 10 years 

*Max.Supervised Release: 3 years 

* Max. Fine: $250,000 or twice value of derived property 

*Refers only to possible term of incarceration, supervised release and fines. It does not 

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

Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 25 of 30
UNITED ST ATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

Defendant's Name: REGINE MARIE RENE 

Case No: 22-CR-80144-SMITH/MAYNARD(s) (s) 

Count #1: 

Conspiracy to Commit Wire Fraud 

Title 18 United States Code Section 1349 

* Max.Term of Imprisonment: 20 years 

* Max.Supervised Release: 3 years 

* Max. Fine: $250,000 or twice gross loss or gross gain 

Count #2: 

Conspiracy to Commit Money Laundering 

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

* Max.Term of Imprisonment: 20 years 

* Max. Supervised Release: 3 years 

* Max.Fine: $500,000 or twice amount laundered 

Counts #6, 12, 19, 23: 

Wire Fraud 

Title 18 United States Code Section 1343 

* Max. Term of Imprisonment: 20 years 

* Max.Supervised Release: 3 years 

* Max.Fine: $250,000 or twice gross loss or gain 

Count #28: 

Money Laundering 

Title 18, United States Code, Section 1956(a)(l)(B)(i) 

* Max. Term of Imprisonment: 20 years 

* Max.Supervised Release: 3 years 

* Max. Fine: $500,000 or twice amount laundered 

*Refers only to possible term of incarceration, supervised release and fines. It does not include 

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

Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 26 of 30
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

Defendant's Name : BRIANNA MONIQUE GAYLE 

Case No: 22-CR-80144-SMITH/MAYNARD(s) (s) 

Count #1: 

Conspiracy to Commit Wire Fraud 

Title 18, United States Code, Section 1349 

* Max.Term of Imprisonment: 20 years 

* Max. Supervised Release: 3 years 

* Max. Fine: $250,000 or twice gross loss or gross gain 

Count #2: 

Conspiracy to Commit Money Laundering 

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

* Max.Term oflmprisonment: 20 years 

* Max.Supervised Release: 3 years 

* Max. Fine: $500,000 or twice amount laundered 

Counts #16, 23: 

Wire Fraud 

Title 18 United States Code Section 1343 

* Max. Term of Imprisonment: 20 years 

* Max. Supervised Release: 3 years 

* Max. Fine: $250,000 or twice gross loss or gain 

Count #29: 

Money Laundering 

Title 18, United States Code, Section 1956(a)(l)(B)(i) 

* Max. Term of Imprisonment: 20 years 

* Max.Supervised Release: 3 years 

* Max. Fine: $500,000 or twice amount laundered 

*Refers only to possible term of incarceration, supervised release and fines. It does not 

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

Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 27 of 30
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

Defendant's Name: MAURICE SHAZIER 

Case No: 22-CR-80 144-SMITH/MA YNARD (s) (s) 

Count #1: 

Conspiracy to Commit Wire Fraud 

Title 18, United States Code, Section 1349 

* Max.Term of Imprisonment: 20 years 

* Max. Supervised Release: 3 years 

* Max. Fine: $250,000 or twice gross loss or gross gain 

Count #2: 

Conspiracy to Commit Money Laundering 

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

* Max.Term of Imprisonment: 20 years 

* Max.Supervised Release: 3 years 

* Max. Fine: $500,000 or twice amount laundered 

Counts #9, 11 , 13-15, 21, 22: 

Wire Fraud 

Title 18 United States Code Section 1343 

* Max.Term of Imprisonment: 20 years 

* Max.Supervised Release: 3 years 

* Max. Fine: $250,000 or twice gross loss or gross gain 

Counts #32-33: 

Money Laundering 

Title 18, United States Code, Section 1956 (a)(l)(B)(i) 

* Max.Term of Imprisonment: 20 years 

* Max. Supervised Release: 3 years 

* Max. Fine: $500,000 or twice amount laundered 

*Refers only to possible term of incarceration, supervised release and fines. It does not include 

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

Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 28 of 30
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

Defendant's Name: ROBENSON LAUVINCE 

Case No: 22-CR-80144-SMITH/MAYNARD(s) (s) 

Count #1: 

Conspiracy to Commit Wire Fraud 

Title 18 United States Code Section 1349 

* Max. Term oflmprisonment: 20 years 

* Max.Supervised Release: 3 years 

* Max. Fine: $250,000 or twice gross loss or gross gain 

Count #2: 

Conspiracy to Commit Money Laundering 

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

* Max.Term of Imprisonment: 20 years 

* Max. Supervised Release: 3 years 

* Max. Fine: $500,000 or twice amount laundered 

Counts #5, 7, 17: 

Wire Fraud 

Title 18 United States Code Section 1343 

* Max.Term of Imprisonment: 20 years 

* Max. Supervised Release: 3 years 

* Max. Fine: $250,000 or twice gross loss or gain 

Count #27: 

Money Laundering 

Title 18, United States Code, Section 19 5 6 ( a) (1 )(B )(i) 

* Max.Term of Imprisonment: 20 years 

* Max.Supervised Release: 3 years 

* Max. Fine: $500,000 or twice amount laundered 

*Refers only to possible term of incarceration, supervised release and fines. It does not 

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

Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 29 of 30
Count #36: 

Engaging in a Transaction in Criminally Derived Property 

Title 18 United States Code Section 1957 

* Max. Term of Imprisonment: 10 years 

* Max.Supervised Release: 3 years 

* Max. Fine: $250,000 or twice amount of criminally derived property 

*Refers only to possible term of incarceration, supervised release and fines. It does not 

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

Case 9:22-cr-80144-RS Document 107 Entered on FLSD Docket 12/15/2022 Page 30 of 30