UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

casx xo. > - bog-3t'p ,omqta-/s 18 U.S.C. j 1349

18 U.S.C. j 1343

18 U.S.C. j 1028A(a)(1)

18 U.S.C. j 981(a)(1)(C)

ITNITED STATES OF AM ERICA

VS.

NOEL STM CHAN,

0M V ETAYEM ,

' a/k/a Rom ar Rivera,''

ODM N M ARSH,

YEGISIBET BENLI,

a/k/a fûtzisa Benli,''

YUNIOR PEREZ M IJRO ,

M ICHAEL PARD OS,

a/l#a dtM ario Cruise,''

a/k/a (dGangster M iker''

ANTH ON Y JONAS,

JAVIER ARGV LLES,

a/lda ddCub:,''

M ARLON FOSTER,

DEM AI, CH EEK S, and

DERROL SCAFE,

Defendants.

JNDICTM ENT

The Grand Jury charges that:

GENER AL ALLEG ATIONS

At a1l times relevant to this Indictm ent:

A vehicle title established a person or business as the legal owner of a vehicle. If

there were any lienholders to the vehicle, the vehicle title also listed al1 lienholders.

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State of Florida tag agencies used the Florida Departm ent of Highway Safety and

M otor Vehicles (FLHSM V) database to issue vehicle titles.

W hen a vehicle title was issued, the FLHSM V database autom atically colm ected

with the National M otor Vehicle Title Infonnation System (NM VTIS), the servers for which were

located outside the State of Florida.

4. Under Florida law, a person claiming a: lien for performing labor or services on a

vehicle m ay enforce such lien by sale of the vehicle in accordance with the procedtlres set forth in

section 713.585, Florida Statm es.

In general, there are fotlr requirem ents to comply with the procedlzres set forth in

section 713.585, Florida Statutes'.

a. The claimant (i. e., the lienor) must check officialrecords to locate a11

persons who m ay have an interest in the vellicle;

b. The claim mlt mu'st provide notice by certified m ail, rettu'n receipt requested,

of the lien and proposed sale to the registered owner of the vehicle, to the

custom er as indicated on the order for repair, and to a1l other persons

claim ing an interest in or lien thereon;

c. The claim mlt must publishthe notice in a newspqper circulated in the cotmty

where the vehicle is held; and

d. Imm ediately upon the sale of the vehicle and paym ent in cash of the

ptlrchase price, the lienor shall file with the clerk of the circuit court in the

county where the vehicle is held a verified report of the sale stating a

'descdption of the vehicle sold, including the vehicle identitication number

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 2 of 23
(VlN); the nnme and address of the purchaser; the date of the sale; and the

selling price.

6. Upon receipt of docum ents showing com pliance with section 713.585, Florida

Statutes, State of Flolida tag agencies issued a vehicle title to the ptlrchaser of a vehicle at a liensale.

COUNT 1

Conspiracy to Com m it W ire Fraud

(18 U.S.C. j 1349)

1.

and incop orated by reference as though fully set forth herein.

Paragraphs 1-6 of the General Allegations section of this Indictm ent are re-alleged

From in or arotmd M arch 2017, through in or arotmd April 2019, in Broward,

M iam i-Dade, and Palm Beach Counties, in the Southern District of Florida, and elsewhere, the

defendants,

NOEL STR ACHAN,

OM A R ETAYEM ,

a/k/a dtom ar Rivera,''

ODM N M ARSH,

YEGISIBET BENLI,

a/k/a RLisa Benli,''

Y UNIOR PEREZ M URO,

M ICH AEL PARDO S,

a/lt/a ddM ario Cruise,''

a/k/a SdG angster M ike,''

ANTH ONY JONAS,

JAW ER ARGUELLES,

a/k/a ddcuba ''

M ARI,ON FOSTER,

D EM AI, CH EEK S, and

DERROL SCM 'E,

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

com bine, conspire, and agree with each other and with others known and llnknown to the Grand

Jury, to knowingly and withthe intentto defraud, devise, and intend to devise a schem e and artifice

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 3 of 23
to defraud, and to obtain m oney and property by m eans of m aterially false and fraudlzlent

pretenses, representations, and promises, knowing that such pretenses, representations, and

prom ises were false and fraudulent when m ade, and for the purpose of executing such schem e and

artifice to defraud, did knowingly transm it and cause to be transm itted, by m eans of wire

com munications in interstate and foreign comm erce, certain writings, signs, signals, pictm es, and

solmds, in violation of Title 18, United States Code, Seotion 1343.

PURPOSE OF THE CON SPIRACY

It was the purpose of the conspiraêy for the defendants and their co-conspirators to

tmlawfully enrich themselves and others by, among other things: (1) acquiring vehicles through

various means, including by theft and deception', (2) preparing and submitting false and fraudùlent

title application doeuments to remove the vehiole's iwful ownerts) and lieriholderts) from the

title; and (3) retaining possession of the vehicle for personal use and enjoyment or selling the

vehicle for a profit, or both.

M ANNER AND M EANS O F THE CONSPIM CY

The m anner and m eans by which the defendants and their co-conspirators sought to

accom plish the purpose of this conspiracy included, nm ong other things, the following: '

NOEL STRACHAN and his co-conspirators acquired vehicles through various

means. Some vehicles were stolen. Som e vehicles were purchased by straw buyers. Some vehicles

were rented using fraudulent means of identification and never returned. Som e W hicles were

ptlrchased at a steeply discbunted rate from distressed ow ners w ho fm anced the irlitial ptlrchase of

the vehicle.

NOEL STRACH AN, OM AR ETAYEM , and other co-conspirators altered and

caused to be altered the Vm on some stolen vehicles.

4

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6. NOEL STM CHAN, OM AR ETAYEM , alpd other co-conspirators altered énd

caused to be altered the m ileage on som e vehicles.

7. NOEL STM CHAN, ODAIN M ARSH , YEGISIBET BENLI, Y UM OR

PEREZ M URO, and other co-conspirators entered and caused to be entered som e Vm s into the

FLHSM V database to determ ine if the vehicles were reported as stolen or otherwise had an alert

that would prevent a title transfer from occuqing.

8. NOEL STR ACH AN, YEGISIBET BENLI, and other co-conspirators prepared

and caused to be prepared false and fraudulent title application docum ents. These docllm ents

purported .to establish compliqnce with Florida's mechanics lien enforcement process (codified at

section 713.585, Florida Statutes) by falsely and fraudulently tepresenting, among other things,

that: (a) labor or services were perfonned on a vehicle; (b) the registered owner of the vehicle

failed to pay for the labor or services', (c) a notice of a claim of lien was served on a11 persons or

entities claiming an interest in the vehicle or lien on the vehicle; and (d) the vehicle was sold to

the title applicant at a public sale.

(

9. YEGISIBET BENLI was the office manager at a company irt Broward Cotmty,

Florida that provided courier services to register and title vehicles in Florida.

10. NOEL STRALIIAN, OM AR ETAYEM , ODM N M ARSH, M ICHAEL

PAW OS, ANTJIONY JONAS, JAVIER ARGUELLES, M ARLON FOSTER, DEMAL

CTTEEKS, DERROL SCAFE, and other co-conspirators subm itted and caused to be subm itted

applications for vehicle titles to Y E G ISIBET B ENL I, lm ow ing

docum ents were false and fraudulent.

that the title application

5

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 5 of 23
11. YIX IOR PEREZ MURO was a title clerk at a State of Florida tag agency iocated

in M iam i-Dade County, Florida. YUNIOR PEREZ M URO was authorized to process véhicle

title applications and issue vehicle titles in the State of Florida.

12. YEGISIBET BENLI delivered and caused the delivery of the false and fzaudulent

title application doctlm ents to YUNIO R PEREZ M URO for processing.

1

13. YUNIOR PEREZ M URO issued titles to vehicles, knowing that the title

application docum ents were false and fraudulent, and often incomplete or erroneous under Florida

law. These fraudulently obtained vehicle titles rem oved a11 prior owners and lienholders f'rom the

title or, if the vehicle was stolen, created a new title with a fraudulent Vm for the stolen vehicle.

14. After a fraudulently obtained

OVAR ETAYEM, ODAIN MARSH, MICHAEL PARDOS, ANTHONY JONAS, JAW ER

ARGUENLES, MARLON FOSTER, DEMAL CHEEKS, DERROL'.SCM 'E, and other coconspirators retained possession of the vehicles for personal use, sold the vehicles for a profit, or

both.

vehicle title was issued, NOEL STRACH AN ,

ln som e instances, after a fraudulently obtained vellicl: title was issued, NOEL

STM CH AN, M ICHAEL PARDO S, ANTHONY JO NAS, M ARI,ON FOSTER, and other

co-conspirators also applied for a loan, using the fraudtllently obtained vehicle title as collateral.

16. From in or around M arch 2017, through in or ârotmd April 2019, the defendants

fraudulently obtained titles to over 100 vehicles.

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

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 6 of 23
CO UNTS 2-11

W ire Fraud

(18 U.S.C. j 1343)

Paragraphs 1-6 of the General Allegations section of this Indictment al'e re-alleged

and incorporated by reference as though fully set forth herein.

From in or arotmd M arch 2017, through in or arotmd April 2019, in Broward,

M iami-Dade, and Palm Beach Counties, in the Southez'n District of Florida, and elsewhere, the

defendants, as specified below, did knowingly, and with the intent to defraud, devise, and intend

to devise, a schem e and artifice to defraud, and obtain m oney and property by m eans of m aterially

fqlse and fraudulent pretenses,representations, and prom ises, knowing that the pretenses,

representations, and prom ises were false and fraudulent when m ade, and for the purpose of

executing such schenae and adilce,did knowingly transm it and cause to be transm itted in

interstate and foreign com merce, by means of wire comm tmication, certain m itings, signs, signals,

.

'

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

PURPOSE OF THk SCIIEME AND ARTIFICE

It yvas the purpose of the schenae

accomplices to unlawfully emich themselves and others by, among other things: (1) acquiring

velzicles through various means, including by theft and dçception; (2) preparing and submitting

false and fraudulent title application docllments to remove the vehicle's lawf'ul ownerts) and

lienholderts) from the title; and (3) retaining possession of the vehicle fpr personal use and

alld artifice for the defendants and thçir

enjoyment, selling the vehicle for a profit, or both.

M A NN ER AN D M EA N S O F TH E SC H EM E A N D A R TIFICE

4. Paragraphs 4-16 of the M nnner and M eans Section of Cotmt 1 of this Indictm ent

are re-alleged and incorporated fully herein by reference as a description of the manner and m eans

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 7 of 23
by which the defendants and their co-conspirators sought to accomplish the purpose of the scheme

and artifice.

USE OF TH E W IRES

On or about the dates specified as to each cotmt below, the defendants, as speciûed

in each count below, for the purpose of executing the aforesaid scheme and artifice to defraud and

to obtain m oney and property by means of m aterially false mld âaudulent pretenses,

representations and prom ises, did knowingly transm it and cause to be transm itted in interstate and

foreign comm erce, by m eans of wire com mllnication, certain m 'itings, signs, signals, pictures, and

sounds, as more particularly described in each count below:

Count Approx. Dâte Defendantts) Description of W ire

2 November 6, 2017 NOEL STILACIIAN, Title issued for 2016 Cadillac

M ARI,ON FOSTER, CTS-V IVIN *196165) in

and M inmi-Dade County, Florida,

M ICH AEL PARDO S utilizing NM VTIS servers

located outside the State of

Florida.

3 April 24, 2018 NOEL STRACH AN Title issued for 2013 M ercedes

and 5L550 IVIN *018543) in

DERROL SCAFE M iami-Dade Cotmty, Florida,

utilizing NM VTIS servers

located outside the State of

Florida.

4 July 12, 2018 NOEL STRACH AN Title issued for 2013 M ercedes

and 51-,550 t'Vm *028543) in

ANTH ONY JONAS M iami-Dade County, Florida,

utilidng NM VTIS servers

located outside the State of

Florida.

5 ' August 29, 2018 NOEL STRACHAN Title issued for 2005 Honda

and Accord IVI'N *104606) in

M ARLON FOSTER M iami-Dade Colmty, Florida,

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 8 of 23
utilizing NM VTIS servers

located outside the State of

Florida.

6 October 19, 201.8 NOEL STR ACHAN Title issued for 2016

and Challenger IVIN *193526) in

ODAIN M A RSH M i>mi-Dade Cotmty, Florida,

utilizing NM VTIS servers

located outside the State of

Florida.

7 October 24, 2018 NOEL STRACHAN, Title issued for 2015 BM W i8,

OM AR ETAYEM , IVIN *391648) in M iamiand Dade County, Florida, utilizing

DERROL SCM ?E NM VTIS servers located.

outside the State of Floljda..

8 Octöber 31, 2018 NOEL STR ACHAN, Title issued for 2015 Polaris

YEGISIBET BENYI, Slingshot IVIN * 108843) in

and M inm i-Dade County, Florida,

JAW ER ARG UELLES utilizing NM VTIS qervers

located outside the State of

Florida.

9 'November 27, 2018 NOEL MTITACI-IAN, Title issued for 2016 Polmis

YEGISIBET BENLI, Slingshot IVm *107405) in

and Miami-Dade Cotmtydlorida,

JAW ER ARG UELLES utilizing NM VTIS servers

located outside the State of

Florida.

10 December 10, 2018 NOEL STR ACH AN Title issued for 2012 Cadillac

and Escalade IVIN *235060) in

DEM AI, CTTEEK S M iami-Dade Cotmty, Florida,

utilizing NM VTIS servers

located outside the State of

Florida.

11 Janualy 3, 2019 NOEL STR ACH AN Title issued for 2017 M ercedes

and GLE AM G I'VIN *059653) in

M ICH AEL PARDOS M inm i-Dade County, Florida,

utilizing.N M v-fls servers

located outside the State of

Florida.

9

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 9 of 23
In violation of Title 18, United States Code, Sections 1343 and 2.

COUNTS 12-15

Aggravated Identity Theft

(18 U.S.C. j 1028A(a)(1))

3

On or about the dates specified below, in Broward, M inm i-Dade, and Palm Beach Counties,

in the Southel'n District of Florida, and elsewhere, the defendants, as specified below, dtuing and

in relation to a felony violation of Title 18, United States Code, 'Section 1349, that is, Conspiracy

to Comm it W ire Fraud, as charged in Count 1, did knowingly transfer, possess, and, use, without

lawful authority, the m eans of identification of another person, as specified in each count below :

Count Approx. Date Defendantts) M eans of ldentification

12 N ovember 16, 2017 ' M ICH AF,L PARDOS Nam e, date of birth, and

driver's license nlzmber of

M .C.

13 October 31, 2018 N OEL STRACH AN Nam e and forged signamre

of S.G.

14 October 31, 2018 N OEL STRACH AN Nam e and commission

' 

ntlmber of D.R.

15 . November 27, 2018 N OEL STRACH AN Nam e, date of birth, and

and driver's license number of

Om R ETAYEM G.L.

'!y,

In violation of Title 18, United States Code, Sections 1028A(a)(1) and 2.

FORFEITIJRE ALLEGATIONS

1. The allegations of this Indictm ent aze hereby re-alleged and by this reference fully

incorporated hereih for the purpose of alleging forfeittlre to the United States of Am ericà of cedain

' property in which any of the defendants, NOEL STM CH M , 0M .* ETAYEM , a/k/a Sdo m ar

Rivera,'' ODAIN M ARSH, W GISIBET BENLI, a/k/a (dtzisa Benlir'' Y UM OR PEREZ

M URO, M ICH AEL PARDOS, a/k/a dfM ario Cruiser'' a/k/a RGangster M ike,'' ANTHOW

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 10 of 23
JONAS, JAW ER ARGUELLES, a/k/a (dcuba,'' M ARLON FOSTER, DEM AI, CHEEK S,

and DERROL SCAFE, have an interess.

Upon conviction of a violation of Title 18, United States Code, Sections 1343

and/or 1349, as alleged i.n this Indictm ent, the defendant shall forfeit to the United States any

property, real or personal, which constitutes or is derived from proceeds traceable to such offense,

plzrsuant to Title 18, United States Code, Section 98 1(a)(1)(C).

Al1 pursuant to Title 18, United States Code, Section 981(a)(1)'(C), arld the procedtlres set

forth at Title 21, Ullited States Code, Section 853, as incop orated by Title 28, United States Code,

Section 2461(c).

A TRIJE lLI'-'---- ''x,- .-,- . ', 1 :-.--w ...-.- .. - ..

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FOREP

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JUAN ANT N IO GONZALEZ

UNITED STATES ATTORNEY

'

- arme F.v,% i '--'p

LAU N CE M . M DFEL

ASSISTANT UNITED STATES ATTORNEY

,

/

A DA M M . H APN E

ASSISTANT UNITED STATES ATTORNEY

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 11 of 23
UN ITED STATES DISTRICT C OUR T

SO UTH ERN DISTR IC T OF FLO RIDA

VNITED STATES OF AM ERICA CASE NO.:

CER TIFICA TE O F TR IA L A TTO R N EY *

Superseding Case Inform ation:

New Defendantts) (Yes or No)

N um ber of N ew D efendants

Total fmmber of New Counts

NOEL STM CHAN, et al.,

/

D efendants.

Court Division (select one)

E-I M iami Q Key W est L FTP

E1 F TL L' W P B

1 do hereby certify that:

1. 1 have carefully considered the allegations of the indictm ent, the num ber of defendants, the num ber of probable

witnesses and the legal complexities of the Indictment/lnform ation attached hereto.

1 nm aware that the information supylied on this statement will be relied upon by the Judges of this Court ill setting

their calendars and scheduling crimlnal trials under the mandate of the Speedy Trial Act, Title 28 U.S.C. j3161.

Interpreter: t'Yes or No) NO

List language and/or dialect:

This case will take 10 days for the jarties to try.

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

(Check only one) (Check only one)

I IZI 0 to 5 days E1 Petty

11 Z 6 to 10 days L. M inor

III D 1 1 to 20 days L. . M isdem eanor

IV EIQ 1 to 60 days z. Felony

V Q' 6 1 days and over

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

If yes, Judge Case N o.

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

lf yes, M agistrate Case N o.

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

lf yes, Judge Case N o. .

9. Defendantts) in federal custody as' of

10. Defendantts) in state custody as of

1 1. Rule 20 from the D istrict of

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

l3. Does this case originate from a m atter pending in the N odhern Region of the U .S. A ttorney's Office

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

Does this case originate from a m atter pending in the Central Region of the U .S. Attorney's O ffice

prior to October 3, 2019 (M ag. Judge Jared Strauss? (Yes or NolYes

By:

M . H AP

A ssistant United States A ttorney

FL B ar N o. 112006

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 12 of 23
UNITED STATES DISTRICT COURT

SOUTH ERN DISTRICT OF FLORIDA

PEN A LTY SH EET

D efendant's N am e: N OEL STM CI-IAN

C ase N o:

Cotmt #: 1

Conspiracv to Commit W ire Fraud

18 U .S.C. k 1349

* M ax. Term of Im prisonm ent: 20 years '

* M andatory M in. Term of Imprisonment (if applicable): N/A

* M ax. Supervised R elease: 3 years

* M ax. Fine: $250,000

Cotmts #: 2-11

W ire Fraud

18 U .S.C. i 1343

* M ax. Term of Im prisonm ent: 20 years

* M andatory M in. Term of lmprisonment (if applicable): N/A

* M ax. Supervised R elease: 3 years

* M ax. Fine: $250,000

Colmts #: 13-15

Azcravated Identity Theft

18 U.S.C. k 1028A(a)(1) '

* M ax. Term of Im prisonm ent: 2 years, consecutive to any other sentence

* M an' datory M in. Term of Imprisonment (if applicable):

2 years, consecutive to any other sentence

* M ax. Supervised R elease: 1 year

* M ax. Fine: $250,000 .

WRefers only to possible term of incarceration, supervised release and llnes. It does not include

restitution, special assessm ents, parole term s, or forfeitures that m ay be applicable.

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 13 of 23
IJNITED STATES DISTRICT COURT

SO UTH ERN DISTRICT OF FLORIDA

PENALTY SHEET

D efendant's Nam e: 0M A1). ETAYEM a/k/a çGomar Rivera''

C ase N o:

Cotmt #: 1

Conspiracy to Com mit W ire Fraud

, 18 U.S.C. k 1349

* M ax. Term of Im prisonm ent: 20 yeazs

* M andatory M in. Term of Imprisonment (if applicable): N/A

* M ax. Supervised Release: 3 years

* M ax. Fine: $250,000

Cotmt #: 7

W ire Fraud

18 U.S.C. i 1343

* M ax. Term of Im prisonm ent: 20 years

* M andatory M in. Term of lmprisonment (if applicable): N/A

* M ax. Supervised Release: 3 years

* M ax. Fine: $250,000

Cotmt #: 15

Accravated Identity Theft

18 U.S.C. k 1028A(a)(1) '

* M ax. Term of Im prisonm ent: 2 years, consecutive to any other sentence

* M andatory M in. Term of Imprisonment (if applicable):

2 years, consecutive to any other sentence

* M ax. Supervised Release: 1 year

* M ax. Fine: $250,000

WRefers only to possible term of incarceration, supervised release and flnes. It does not include

restitution, special assessm ents, parole term s, or forfeitures that m ay be applicable.

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 14 of 23
UNITED STATES DISTRICT COURT

SOUTH ERN DISTRICT OF FLORIDA

PENALTY SHEET

Defendant's Nam e: ODAIN M ARSH

C ase N o: - -

Cotmt #: 1

Conspiracy to Commit W ire Fraud

18 U.S.C. j 1349

* M ax. Term of Im prisonm ent: 20 years

* M andatory M in. Term of Imprisonment (if applicable): N/A

* M ax. Supervised R elease: 3 years

* M ax. Fine: $250,000

Count #: 6

W ire Fraud

18 U .S.C. j 1343

* M ax. Term of Im prisonm ent: 20 years

* M andatory M in. Term of Imprisonment (if applicable): N/A

* M ax. Supervised Release: 3 years

* M ax. Fine: $250,000

WRefers only to possible term of incarceration, supervised release and llnes. It does not include

restitution, special assessm ents, parole term s, or forfeitures that m ay be applicable.

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 15 of 23
UNITED STATES DISTRICT COURT

SOUTH ERN DISTRICT OF FLORIDA

PENALTY SHEET

)

D efendant's Nam e: YEGISIBET BENLI aIV a 't isa Benli''

Case No:

Colmt #: 1

Conspiracy to Com mit W ire Fraud '

18 U.S.C. k 1349

* M ax. Term of Im prisonm ent: 20 years

* M andatory M in. Term of Imprisonment (if applicable): N/A

* M ax. Supervised R elease: 3 years

* M ax. Fine: $250,000

Cotmt #: 8 & 9

W ire Fraud

. .w '

18 U.S.C. k 1343 -

* M ax. Term of Im prisonm ent: 20 years

* M andatory M in. Term of lmprisonment (if applicable): N/A

* M ax. Supervised Release: 3 years

* M ax. Fine: $250,000

frRbfers only to possible term of incarceration, supervised release and llnes. It does not include

restitution, special assessm ents, parole term s, or forfeitures that m ay be applicable.

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 16 of 23
UM TED STATES DISTRICT COURT

SOUTH ERN DISTRICT OF FLORIDA

PENALTY SHEET

Defendant's Nam e: Y UNIOR PEREZ M URO

Case No:

Collnt #: 1

Conspiracv to Com mit W ire Fraud

18 U .S.C. j 1349

* M ax. Term of Im prisonm ent: 20 years

* M andatory M in. Term of Imprisonment (if applicable): N/A

* M ax. Supervised Release: 3 years

* M ax. Fine: $250,000

'kRefers only to possible term of incarceration, supervised felease and llnes. It does not include

restitution, special assessm ents, parole term s, or forfeitures that m ay be applicable.

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 17 of 23
IJNITED STATES DISTRICT COURT

SOUTH ERN DISTRICT OF FLORIDA

PENALTY SHZET

Defendant's Nam e: M ICHAEL PARDOS zlkla GçM ario Cruise'' and Gçtllancster M ike''

Case No:

Count #: 1

Cpnspiracy to Commit W ire Fraud

18 U .S.C. k 1349

* M ax. Term of Im prisonm ent: 20 years '

* M andatory M in. Term of Imprisonment (if applicable): N/A

* M ax. Supervised R elease: 3 years

* M ax. Fine: $210,000

Cotmts #: 2 & 11

18 U .S.C. i 1343 .

* M ax. Term of Im prisonm ent: 20 years

* M andatory M in. Term of Imprisonment (if applicable): N/A

* M ax. Supervised Release: 3 years

* M ax. Fine: $250,000

Count #: 12

Azcravated Identity Theft

18 U .S.C. k 1028A(a)(1)

* M ax. Term of Im prisonm ent: 2 years, consecutive to any other sentence

* M andatory M in. Term of lmprisonment (if applicable):

2 years, consecutive to any other sentence

* M ax. Supervised R eliase: 1 year

* M ax. Fine: $250,0041

WRefers only to possible term of incarceration, supervised release and llnes. It'does not include

restitution, special assessm ents, parole term s, or forfeitures that m ay be applicable.

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 18 of 23
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

PEN A LTY SH EET

Defendant's Nam e: ANTHON Y JONAS

C ase N o:

Collnt #: 1

Conspiracy to Comm it W ire Fraud

18 U.S.C. k 1349

* M ax. Term of Im prisonm ent: 20 years

* M andatory M in. Term of Imprisonm ent (if applicable): N/A

* M ax. Supervised Release: 3 years

* M ax. Fine: $250,000

Count #: 4

18 U.S.C. j 1343

* M ax. Term of Im prisonm ent: 20 years

* M andatory M in. Term of Imprisonm ent (if applicable): N/A

* M âx'. Supervised R:lease: 3 years

* M 'ax. Fine: $250,000

RRefers only to possible term of incarceration, supervised release and lines. It does not inclùde

restitution, spécial assessm ents, parole term s, or forfeitures that m ay be applicable.

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 19 of 23
UNITED STATES DISTRICT COIJRT

SOUTH ERN DISTRICT OF FLORIDA

PENALTY SHEET

Defendantfs Nam e: JAVIER ARGUELLES a/k/a Glcuba''

C ase N o:

Collnt #: 1

Conspiracy to Com mit W ire Fraud

.18 U .S.C. k 1349

o ' ' M ax. Term of Imprisonment: 20 yearj

* M andatory M in. Term of Imprisonment (if applicable): N/A

* M ax. Supervised Release: 3 years

* M ax. Fine: $250,000

Counts #: 8-9

W ire Fraud

18 U.S.C. j 1343 ..

* M ax. Term of Im prisonm ent: 20 years

* M andatory M in. Term of Imprisonment (if applicable): N/A

* M ax. Supervised Release: 3 years

* M ax. Fine: $250,000

RRefers only to possible term of incarçeration, supervised release and llnes. It does not include

restitution, special assessm entsr parole term s, or forfeitures that m ay be applicable.

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 20 of 23
UNITED STATES DISTRICT COURT

SO U TH ER N D ISTR ICT O F FL OR ID A

PENALTY SHEET

Defendant's Nam e: ' M ARLON FOSTER

Case No:

Count #: 1

Conspiracv to Comm it W ire Fraud

18 U.S.C. j 1349 .

* M ax. Term of Im prisonm ent: 20 yeàrs

* M andat:ry M in. Term of Imprisonm ent (if applicable): N/A

* M ax. Supervised Release: 3 years

* M ax. Fine: $250,000

Cotmts #: 2 & 5

W ire Fraud

18 U.S.C. i 1343

* M ax. T erm of Im prisonm ent: 20 years

* M andatory M in. Term of Imprisonment (ifapplicable): N/A

* M ax. Supervised Release: 3 years

* M ax. Fine: $250,000

WRefers only to possible term of incarceration, supervised release and llnes. It does not include

restitution, special assessm ents, parole term s, or forfeitures that m ay be applicable.

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 21 of 23
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

PENALTY SHEET

D efendant's Nam e: DEM AL CHEEKS

Case No:

Count #: 1

Conspiracv to Com mit W ire Fraud

18 U .S.C. j 1349

* M ax. Term of lm prisonp ent: 20 years

* M andatory M in. Term of Imprisonment (if applicable): N/A

* M ax. Supervised Releqse: 3 years

* M ax. Fine: $250,000

Cotmt #: 10

W ire Fraud

18 U.S.C. q 1343

* M ax. Term of Im prisonm ent: 20 years

* M andatory M in. Term of Imprisonment (if applicable): N/A

* M ax. Supervised Release: 3 years

* M ax. Fine: $250,000

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

restitution, special assessm ents, parole term s, or forfeitures that m ay be applicable.

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 22 of 23
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

PENALTY SHEET

Defendant's Nam e: DERROL SCAFE

Case NO: '

Colmt #: 1

Conpkacv to Commit W ize Fraud

18 U.S.C. k 1349

* M ax. Term of lm prisonm ent: 20 years

* M andatory M in. Term of Imprisonm ent (if applicable): N/A

* M ax. Supervised R elease: 3 years

* M ax. Fine: $250,000

Count #: 3 & 7

W ire Fraud I

18 U.S.C. j 1343. 

'

* M ax. Term of Im prisonm ent: 20 years .

* M andatory M in. Term of Imprisonm ent (if applicable): N/A

* M ax. Supervised Release: 3 years

* M ax. Fine: $250,000 -

WR efers only to possible term of incarceration, supervised release and llnes. It does not include

restitution, special assessm ents, parole term s, or forfeitures that m ay be applicable.

Case 0:22-cr-60238-DPG Document 1 Entered on FLSD Docket 10/28/2022 Page 23 of 23