UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. ----=2=-2--'C=R"""-...;;;..80=1:;..;4;...:.4"""-S=M=I=T=H/M==A=Y=N;..;.A=RDa=..,,.;(s;;..,.) ___ _ 

18 u.s.c. § 1349 

18 U.S.C. § 1956(h) 

18 U.S.C. § 1425(a) 

18 U.S.C. § 982(a) 

UNITED STATES OF AMERICA 

vs. 

JOFF STENN WROY PHILOSSAINT, 

MARIEL TOLLINCHI, 

REGINE MARIE RENE, 

BRIANNA MONIQUE GAYLE, 

and MAURICE SHAZIER, 

Defendants. 

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

SUPERSEDING INDICTMENT 

The Grand Jury charges that: 

GENERAL ALLEGATIONS 

At all times material to this Superseding Indi ctment: 

The Paycheck Protection Program 

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

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

the millions of Americans who were sufferi ng the economic effects caused by the COVID-1 9 

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

TM Oct 20, 2022 West Palm Beach

Case 9:22-cr-80144-RS Document 58 Entered on FLSD Docket 10/20/2022 Page 1 of 19
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 sol e proprietorships. In order to 

obtain a PPP loan, a qua) ify ing business (through its authorized representative or the sole 

proprietor) signed and submitted a PPP loan appli cation (Small Business Administrati on ("SBA") 

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

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

the sole propri etor) to acknowledge the program rul es and make certa in affirmative certifications. 

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

and had employees for whom it paid sal ari es 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 prov ide documentation confirming their payroll 

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

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

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

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

eligible to rece ive 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 de legated 

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

approved, the parti cipating lender fund ed the PPP loan using its own monies, whi ch were l 00% 

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guaranteed by the SBA. Data from the app lication, 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 payro ll 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 qualify ing business was 

requ ired to submit electronically an EIDL application to the SBA and provide information abo ut 

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 perj ury that all of the information in the EIDL application was true and correct to the 

best of the applicant's knowledge. 

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

support from a government contractor. EJDL fund s were issued directly from the United States 

Treasury. 

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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 app li cant certifi ed hav ing at the small business. The 

advances did not have to be repaid. 

9. SBA' s emai I 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, Lenders, and Banks 

I 0. Defendant JOFF STENN WROY PHILOSSAINT was a resident of Broward and 

Miami-Dade Counti es, in the Southern District of Florida. 

11 . Defendant MARIEL TOLLINCHI was a resident of Broward County, 111 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. Co-conspirator David Andre Johnson was a resident of Broward County, in the 

Southern District of F lorida. 

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

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

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

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

Florida. 

17. Defendant MARlEL 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 F lorida. TOLLINCHI was a lso the principal of Tol linchi Law P.A. 

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

18. Defendant JOFF STENN WROY PHILOSSAINT was the president and 

TOLLINCHI LAW was the registered agent of Dad Money Investment Group, LLC ("DAD 

MONEY"), a purported business located in Broward County, in the Southern District of F lorida. 

19. Defendant REGINE MARJE RENE was the principal and registered agent of Unfo ld 

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

Southern District of Florida. 

20. 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. 

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

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

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

22. 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. 

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

PPP loans. 

24. Lender #2 was headq uartered in De laware and was an approved SBA lender for PPP 

loans. 

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

loans. 

COUNTl 

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

Paragraphs 1 through 25 of the General A ll egations Section of this 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 e lsewhere, the defendants, 

JOFF STENN WROY PIIlLOSSAINT, 

MARIEL TOLLI CHI, 

REGINE MARIE RENE, 

BRIANNA MONIQUE GAYLE, 

and 

MAURICE SHAZIER, 

did willfully, that is, w ith 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 fa lse 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 

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interstate and fore ign commerce, certain wri tings, signs, signals, pictu res, 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 artifi ce for the Defendants and 

their co-conspirators to unlawfull y enrich themselves by, among other things: (1) creating fa lse 

and fraudulent documents, including payroll record s and tax documents; (2) submitting and 

causing the submission of fa lse and fraudulent applications for loans made avail able through the 

SBA to prov ide relief for the economic effects caused by the COVlD-19 pandemic, including 

ETDL and PPP loans; (3) offering, paying, and receiving kickbacks in return fo r causing the 

submission of fa lse and fraudulent loan applications; ( 4) di verting fraud proceeds fo r the 

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

further the conspiracy; and (5) submitting and causing the submission of fa lse and fraudul ent 

appli cations for forgiveness of the received loans. 

MANNER AND MEANS 

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

accomplish the obj ect of the conspiracy and the scheme and artifi ce included, among others, the 

fo llowing: 

(a) JOFF STENN WROY PHTLOSSAINT and BRIANNA MONIQUE 

GAYLE created and caused the creation of fa lse and fraudulent tax documents for business entities 

owned and contro lled by themselves, MARIEL TOLLINCHI, REGINE MARJE RENE, 

MAURICE SHAZIER, Dav id Andre Johnson, and others known and unknown to the Grand Jury, 

for the purpose of applying fo r PPP and EIDL loans. 

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(b) JOFF STENN WROY PHILOSSAINT, MARIEL TOLLINCHI, REGINE 

MARIE RENE, BRIANNA MONIQUE GAYLE, MAURICE SHAZIER, Dav id Andre Johnson, 

and others known and unknown to the Grand Jury submitted and caused the submission of fa lse 

and fraudulent PPP and EIDL loan applicati ons for these business entities. 

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

by JOFF STENN WROY PHILOSSAINT, MARIEL TOLLINCHI, REGINE MARIE RENE, 

BRlANNA MONIQUE GAYLE, Maurice Shazier, Dav id Andre Johnson, and others known and 

unknown to the Grand Jury included fa lse and fraudulent tax documents and fa lsely and 

fraudul ently represented the borrowing entiti es' number of employees, amount of month ly payroll , 

gross income, and cost of goods sold. 

(d) JOFF STENN WROY PHILOSSAINT and BRIANNA MONIQUE 

GAYLE created and caused the creation of false and fraudulent payro ll accounts with a payro ll 

processing serv ice for business entiti es owned and controll ed by themselves, MARIEL 

TOLLINCHI, REGINE MARIE RENE, MAURICE SHAZIER, David Andre Johnson, and others 

known and unknown to the Grand Jury, fo r the purpose of applying fo r PPP and EIDL loans and 

PPP loan forg iveness. 

(e) Having obtained PPP and EIDL loans for those entities, JOFF STENN 

WROY PHILOSSAINT, MARIEL TOLLINCHI, REGINE MARIE RENE, BRIANNA 

MONIQUE GAYLE, MAURICE SHAZIER, Dav id Andre Johnson, and others known and 

unknown to the Grand Jury caused the electroni c wire transfer of a po11ion of the loan proceeds to 

a payro ll processing serv ice to make it appear that the proceeds were being used for legitimate 

payro ll expenses. 

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(f) Having obtained PPP and EJDL loans for their business entities, JOFF 

STENN WROY PHJLOSSAINT caused MARIEL TOLLINCHI, REGINE MARIE RENE, 

BRIANNA MONIQUE GAYLE, MAURICE SHAZIER, David Andre Johnson, and others known 

and unknown to the Grand Jury to pay kickbacks of approximate ly 10% of the loans' values to 

JOFF STENN WROY PHILOSSAINT via checks and wire transfers that were often disguised to 

appear to be legitimate business expenses. 

(g) JOFF STENN WROY PHTLOSSAINT, MARIEL TOLLINCHI, REGINE 

MARIE RENE, BRIANNA MONIQUE GAYLE, MAURICE SHAZIER, 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 forgive ness for these business entities. 

(h) As a result of the false and fraudulent representations that JOFF STENN 

WROY PHILOSSAINT, MARTEL TOLLINCHI, REGINE MARIE RENE, BRIANNA 

MO IQUE GAYLE, MAURICE SHAZIER, David Andre Johnson, and others known and 

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 approximate ly $8. 1 million. 

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

COUNT2 

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

From in or arou nd 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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JOFF STENN WROY PIDLOSSAINT, 

MARIEL TOLLINCHI, 

REGINE MARIE RENE, 

BRIANNA MONIQUE GAYLE, 

and 

MAURICE SHAZIER, 

did knowingly and vo luntari ly combine, conspire, confederate, and agree with each other and w ith 

persons known and unknown to the Grand Jury, to knowi ngly conduct, and attempt to conduct, a 

fin anc ial transaction affecting interstate and fore ign commerce involving the proceeds of spec ified 

unl awfu l activity, knowing that the property invo lved 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 spec ifi ed unlawfu l activity, in violation of 18 U.S.C. § 1956(a)(l)(B)(i). 

It is further a lleged that the spec ifi ed unlawful activity is wire fraud , in violation of 18 

U.S.C. § 1343. 

All in vio latio n of Titl e 18, United States Code, Section 1956(h). 

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 be ing unkn own to the Grand Jury, in Palm Beach, St. Lucie, Broward, and Miami-Dade 

Counties, in the Southern District of Florida, and e lsewhere, the defendants, 

JOFF STENN WROY PIDLOSSAINT 

and 

MARIEL TOLLINCHI, 

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

persons known and unknown to the Grand Jury, to: 

Case 9:22-cr-80144-RS Document 58 Entered on FLSD Docket 10/20/2022 Page 10 of 19
(a) knowingly transmit and transfer monetary instruments and funds, from a 

pl ace 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 unlawfu l activity, in vio lation of 18 U .S.C. § 1956(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 crimina lly derived property of a value 

greater than $ 10,000 that is derived from spec ifi ed unl awfu l activity, in violation of 18 U.S.C. § 

1957. 

It is further a lleged that the specified unlawfu l activity is wire fraud, in violation of 18 

U.S.C. § 1343. 

A ll in violation of Title 18, Un ited States Code, Section I 956(h). 

COUNT4 

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

Paragraphs I through 9 of the General A ll egations Section of this Superseding Indictment 

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

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

February 9, 202 1, in Broward and Miami-Dade Cou nti es, in the Southern District of Florida, and 

e lsewhere, the defendant, 

JOFF STENN WROY PIIlLOSSAINT, 

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

citizen fo r himse lf, to wit, the defendant obta ined and attempted to obtain naturalization by fa lsely 

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

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

that: 

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

commit, a crime or offense fo r 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 th rough 3 of this Superseding Indictment; 

and 

(b) he had not made any misrepresentation to obta in any publi c benefit in the 

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

misrepresented busi nesses, their earnings, and the ir employee workforces in an effort to obta in 

multip le loans and advances, and forg iveness of those loans and advances pursuant to the United 

States' Paycheck Protection Program and the Economic Inj ury D isaster Loan Program. 

All in violati on of T itl e 18, United States Code, Secti on 1425(a). 

FORFEITURE ALLEGATIONS 

I . The allegations of this Superseding Indictment are hereby re-alleged and by th is 

reference fully incorporated herein for the purpose of a ll eging forfe iture to the United States of 

America of certain property in which the defendants, JOFF STENN WROY PIIlLOSSAINT, 

MARIEL TOLLIN CID, REGINE MARIE RENE, BRIANNA MONIQUE GAYLE, and 

MAURICE SHAZIER, have an interest. 

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

alleged in this 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 l 956(h), as 

alleged in this Superseding Indictment, the defendant shall forfeit to the United States any 

property, real or personal, in volved in such offense, and any property traceabl e to such property, 

pursuant to Titl e 18, Un ited States Code, Section 982(a)(l ). 

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 

UNITE ST A TES ATTORNEY 

0K()~ 

A. MARIE VILLAFANA 

ASSISTANT UNITED STATES ATTORNEY 

A TRUE BILL. 

/'"\ 

FOREPERSON 

13 

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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

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

v. 

JOFF S. W. PHJLOSSATNT, MARJ EL 

TOLLINCHI, BRJANNA M. GAYLE, 

CERTIFICATE OF TRIAL ATTORNEY* 

REGTNE M. RENE, & MAURJCE SHAZLER, / Superseding Case Information: 

Defendants. 

Court Division (select one) 

□ Miami □ Key West FTP 

New Defendant(s) (Yes or No) Yes 

Number of New D efendants 1 

□ FTL El WPB Total number of New Counts 0 

I do hereby certify that: 

I . l 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. §3 161. 

3. Interpreter: (Yes or No) No 

List language and/or dialect: 

4. This case will take 20 days for the parties to try. 

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

(Check only one) 

l D Oto 5 days 

II D 6 to 10 days 

III El 11 to 20 days 

1 V D 21 to 60 days 

V D 61 days and over 

(Check on ly one) 

□ Petty 

D Minor 

□ Misdemeanor 

El Felony 

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

If yes, Judge Smi th Case No. 22-Cr-80144 

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

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

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 federa l custody as of 8/7/2022 (Philossaint) 

l 0. Defendant( s) in state custody as of 

l J. Rule 20 from the District of 

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

13. Does this case origi nate from a matter pending in the No1ihe rn Region of the U.S. Attorney's Office 

prior to A ugust 8, 20 14 (Mag. Judge Shani ek Maynard? (Yes or No) No 

14. Does this case orig inate from a matte r pending in the Central Region of the U.S. Attorney's Office 

prior to October 3, 201 9 (Mag. Judge Jared Strauss? (Yes or No) No 

By: 

A. MARIE VTLLAF ANA 

Assistant United States Attorney 

FLA Bar No. 0018255 

Case 9:22-cr-80144-RS Document 58 Entered on FLSD Docket 10/20/2022 Page 14 of 19
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

Defendant's Name: JOFF STENN WROY PHILOSSAINT 

Case No: 22-CR-80144-SMITH/MA YNARD(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 

Counts #2-3 : 

Money Laundering Conspiracy 

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

* Max. Term oflmprisonment: 20 years 

* Max.Supervised Release: 3 years 

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

Count #4: 

Acquiring Naturalized U.S. Citizenship through Fraud 

Title 18, United States Code, Section l 425(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 58 Entered on FLSD Docket 10/20/2022 Page 15 of 19
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENAL TY SHEET 

Defendant's Name: MARIEL TOLLINCHI 

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

Count # l: 

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 

Counts #2-3: 

Money Laundering Conspiracy 

Title 18, Un ited States Code, Section 1956(h) 

* Max. Term oflmprisonment: 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 58 Entered on FLSD Docket 10/20/2022 Page 16 of 19
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENAL TY SHEET 

Defendant's Name: REGINE MARIE RENE 

Case No: 22-CR-80144-SMITH/MA YNARD(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: 

Money Laundering Consp iracy 

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 

*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 58 Entered on FLSD Docket 10/20/2022 Page 17 of 19
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

Defendant's Name: BRIANNA MONIQUE GAYLE 

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

Count #1: 

Conspiracy to Commit Wire Fraud 

Title l 8 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: 

Money Launderin g Conspiracy 

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

*Max.Term oflmprisonment: 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 58 Entered on FLSD Docket 10/20/2022 Page 18 of 19
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENAL TY SHEET 

Defendant's Name: MAURICE SHAZIER 

Case No: 22-CR-80144-SMITH/MA YNARD(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: 

Money Laundering Conspiracy 

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 

*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 58 Entered on FLSD Docket 10/20/2022 Page 19 of 19