1 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

Miami Division 

www.flsb.uscourts.gov

In re: 

G&C INVESTMENT CORP., Case No.: 17-20150-LMI 

 Chapter 7 

 Debtor. 

__________________________________/ 

Adv. Case No.: 

MARCIA T. DUNN, Chapter 7 

Trustee of the Bankruptcy Estate 

of G&C INVESTMENT CORP., 

 Plaintiff, 

v. 

AMERICAN EAGLE SERVICES 

GROUP, INC, a District of Columbia 

corporation, AESG CAPITAL, INC., 

a District of Columbia corporation, 

and PAUL MAUCHA, an individual, 

 Defendants. 

__________________________________/ 

COMPLAINT TO AVOID AND RECOVER FRAUDULENT 

TRANSFERS, FRAUD, UNJUST ENRICHMENT AND CONVERSION

 Marcia T. Dunn, as Chapter 7 trustee of the bankruptcy estate of G&C Investment Corp. 

(“Trustee”), sues American Eagle Services Group, Inc. (“AESG”), AESG Capital, Inc. (“AESG 

Cap”), and Paul Maucha (“Mr. Maucha,” and collectively with AESG and AESG Cap, the 

“Defendants”), and alleges as follows: 

I. JURISDICTION AND VENUE 

1. This is an adversary proceeding brought pursuant to Fed. R. Bank. P. 7001, 11 

U.S.C. § 541, 544, 548 and 550, Chapter 726, Fla. Stat., and other applicable law. 

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 1 of 24
2 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363

2. This Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334. 

3. This matter is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(A), (E), (H) and 

(O), and the Trustee consents to the entry of final orders and judgment by the Bankruptcy Court. 

4. Venue is proper before this Court pursuant to 28 U.S.C. §§ 1408 and 1409. 

II. PARTIES 

5. The Trustee is the duly appointed Chapter 7 Trustee of the bankruptcy estate of 

G&C Investment Corp. (the “Debtor”) and brings this action solely in her capacity as trustee. 

6. AESG is a District of Columbia corporation that conducts business in Miami-Dade 

County, Florida. 

7. AESG Cap is a District of Columbia corporation that conducts business in MiamiDade County, Florida. 

8. Mr. Maucha is an individual residing in Washington DC, is over the age of 18, and 

is sui juris. 

III. PROCEDURAL BACKGROUND 

9. On August 10, 2017 (the “Petition Date”), this case was commenced by the filing 

of an involuntary petition for relief under Chapter 7, Title 11 of the United States Bankruptcy Code 

(the “Bankruptcy Case”). 

10. On November 7, 2017, the Court entered its Order for Relief in Involuntary Case

(the “Relief Date”). 

11. On December 20, 2017, the Trustee was appointed as the duly authorized and acting 

Chapter 7 Trustee of the Debtor’s bankruptcy estate. 

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 2 of 24
3 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363

IV. GENERAL BACKGROUND 

A. Mr. Garrido’s Fraud Through the Debtor 

12. As early as 2010, Mr. Jorge Garrido caused the Debtor to raise monies from 

investors to purportedly invest in different ventures – ranging from gem deals, funding start up 

projects, participating in humanitarian platforms, and commodities trading. The common theme 

for all the investments was the false promise of generating large returns in a very short period of 

time, and in exchange the Debtor would earn a relatively small advance fee. 

13. Mr. Garrido was the Debtor’s owner, officer and controlling person. 

14. On October 1, 2018, Mr. Garrido was indicted by the United States of America as 

a result of the fraud he orchestrated through the Debtor (the “Indictment”). 

15. On May 23, 2019, Mr. Garrido pled guilty to a number of his crimes alleged in the 

Indictment, and on August 7, 2019, Mr. Garrido was sentenced to 70 months in federal prison and 

ordered to pay over $5,000,0000 in restitution. Attached as Exhibit A is Mr. Garrido’s Factual 

Proffer admitting to his crimes and his fraud (the “Fraud”). 

B. AESG, AESG CAP, and Mr. Maucha Receive Improper Transfers from the 

Debtor 

16. Prior to the Petition Date, the Debtor transferred $400,000 to AESG (the 

“Transfers”). 

17. Attached as Exhibit B is a schedule of the Transfers. The Trustee reserves the right 

to amend this schedule based on additional information obtained during discovery in this adversary 

proceeding. 

18. The Debtor made the Transfers to AESG pursuant to an “MOU & Working 

Agreement” between AESG Cap and the Debtor, which was entered into on April 16, 2016 (the 

“Agreement”). A copy of the Agreement is attached as Exhibit C. 

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 3 of 24
4 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363

19. Specifically, AESG Cap represented in the Agreement: 

Collectively, the “Representations.”

20. The Debtor relied on the Representations, and as a result, made the Transfers to 

AESG. 

21. The Representations were false, which falsity was known by AESG, AESG Cap, 

and Mr. Maucha. 

22. Mr. Maucha, the owner of AESG and AESG Cap, executed the Agreement. 

23. In exchange for the Transfers, the Debtor never received $4,000,000 from AESG. 

24. On multiple occasions, the Debtor demanded from the Defendants the return of the 

Transfers. 

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 4 of 24
5 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363

25. Despite numerous promises by Mr. Maucha to return the Transfers to the Debtor, 

the Transfers have not been returned and the Defendants have kept the Transfers. 

26. Neither AESG nor AESG Cap provided any consideration to the Debtor in 

exchange for the Transfers. 

27. The Debtor was insolvent at all relevant times by virtue of the fact the Debtor was 

an entity engaged solely in fraudulent activities and was always unprofitable, had no meaningful 

assets other than funds which accompanied an obligation (either debt or equity) equal to or more 

than the funds themselves, and the numerous tort and other claims held by investors defrauded by 

the Debtor, which claims (in pertinent part) preceded the Transfers. 

28. All conditions precedent to the filing of this action have been performed, have 

occurred, or have been waived. 

COUNT I 

Fla. Stat. §§ 726.105(1)(a) and 726.108 

Against AESG 

29. The Trustee reasserts the allegations set forth in paragraphs 1 through 28 as if fully 

set forth herein. 

30. The Debtor made the Transfers to AESG within four years of the Petition Date. 

31. AESG is the initial transferee of the Transfers. 

32. The Debtor made the Transfers to AESG with the actual intent to hinder, delay, or 

defraud the Debtor’s creditors. 

WHEREFORE, the Trustee requests that the Court enter judgment in favor of the Trustee 

and against AESG (i) avoiding the Transfers pursuant to Section 726.105(1)(a), Fla. Stat., and or 

otherwise applicable law; (ii) awarding the Trustee a money judgment in an amount equal to the 

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 5 of 24
6 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363

amount or value of the Transfers, plus interest and costs, pursuant to Section 726.108, Fla. Stat., 

and (iii) granting such other and further relief as this Court shall deem appropriate. 

COUNT II

Fla. Stat. §§ 726.105(1)(b) and 726.108 

Against AESG 

33. The Trustee reasserts the allegations set forth in paragraphs 1 through 28 as if fully 

set forth herein. 

34. The Debtor made the Transfers to AESG within four years of the Petition Date. 

35. AESG is the initial transferee of the Transfers. 

36. The Debtor made the Transfer to AESG without receiving reasonably equivalent 

value in exchange for the Transfers. 

37. At the time of the Transfers, the Debtor was engaged in, or was about to engage in, 

a business or a transaction for which the remaining assets were unreasonably small in relation to 

the business or transaction. 

38. At the time of the Transfers, the Debtor intended to incur or believed that it would 

incur, debts that were beyond its ability to pay as such debts matured. 

39. At the time the Transfers was made, the Debtor had at least one unsecured creditor 

that could have avoided such transfer(s). 

40. By reason of the foregoing, the Transfers to AESG are avoidable and recoverable 

pursuant to Sections 726.105(1)(b) and 726.108, Fla. Stat., and or otherwise applicable law. 

WHEREFORE, the Trustee requests that the Court enter judgment in favor of the Trustee 

against AESG (i) avoiding the Transfers pursuant to Section 726.105(1)(b), Fla. Stat., and or 

otherwise applicable law; (ii) awarding the Trustee a money judgment in an amount equal to the 

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 6 of 24
7 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363

amount or value of the Transfers, plus interest and costs, pursuant to Section 726.108, Fla. Stat., 

and (iii) granting such other and further relief as this Court shall deem appropriate. 

COUNT III 

Fla. Stat. §§ 726.106(1) and 726.108 

Against AESG 

41. The Trustee reasserts the allegations in paragraphs 1 through 28 as if fully set forth 

herein.

42. The Debtor made the Transfers to AESG within four years of the Petition Date. 

43. AESG is the initial transferee of the Transfers. 

44. The Debtor made the Transfers to AESG without receiving reasonably equivalent 

value in exchange for the Transfers. 

45. At the time of the Transfers, the Debtor was insolvent or became insolvent as a 

result of the Transfers.

46. At the time the Transfers was made, the Debtor had at least one unsecured creditor 

that could have avoided such transfer(s).

47. By reason of the foregoing, the Transfers to AESG are avoidable and recoverable 

pursuant to Sections 726.106(1) and 726.108, Fla. Stat., and or otherwise applicable law. 

WHEREFORE, the Trustee requests that the Court enter judgment in favor of the Trustee 

against AESG (i) avoiding the Transfers pursuant to Section 726.106, Fla. Stat., and or otherwise 

applicable law; (ii) awarding the Trustee a money judgment in an amount equal to the amount or 

value of the Transfers, plus interest and costs, pursuant to Section 726.108, Fla. Stat., and (iii) 

granting such other and further relief as this Court shall deem appropriate. 

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 7 of 24
8 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363

COUNT IV 

11 U.S.C. §§ 548(a)(1)(A) and 550 

Against AESG 

48. The Trustee reasserts the allegations set forth in paragraphs 1 through 28 as if fully 

set forth herein. 

49. The Debtor made the Transfers to AESG within two years of the Petition Date. 

50. AESG is the initial transferee of the Transfers. 

51. The Debtor made the Transfers to AESG with the actual intent to hinder, delay, or 

defraud the Debtor’s creditors. 

WHEREFORE, the Trustee requests that the Court enter judgment in favor of the Trustee 

and against AESG (i) avoiding the Transfers pursuant to 11 U.S.C. § 548(a)(1)(A), and or 

otherwise applicable law; (ii) awarding the Trustee a money judgment in an amount equal to the 

amount or value of the Transfers, plus interest and costs, pursuant to Section 11 U.S.C. § 550, and 

(iii) granting such other and further relief as this Court shall deem appropriate. 

COUNT V

11 U.S.C. §§ 548(a)(1)(B) and 550 

Against AESG 

52. The Trustee reasserts the allegations set forth in paragraphs 1 through 28 as if fully 

set forth herein. 

53. The Debtor made the Transfers to AESG within two years of the Petition Date. 

54. AESG is the initial transferee of the Transfers. 

55. The Debtor made the Transfers to AESG without receiving reasonably equivalent 

value in exchange for the Transfers. 

56. At the time of the Transfers, the Debtor was insolvent on the date the Transfers 

were made, or became insolvent as a result of the Transfers. 

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 8 of 24
9 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363

57. At the time of each of the Transfers, the Debtor was engaged in, or was about to 

engage in, a business or a transaction for which any property remaining with the Debtor was an 

unreasonably small capital. 

58. At the time of the Transfers, the Debtor intended to incur or believed that it would 

incur, debts that were beyond its ability to pay as such debts matured. 

59. By reason of the foregoing, the Transfers to AESG are avoidable and recoverable 

pursuant to 11 U.S.C. §§ 548(a)(1)(B) and 550. 

WHEREFORE, the Trustee requests that the Court enter judgment in favor of the Trustee 

and against AESG (i) avoiding the Transfer pursuant to 11 U.S.C. § 548(a)(1)(B), and or otherwise 

applicable law; (ii) awarding the Trustee a money judgment in an amount equal to the amount or 

value of the Transfers, plus interest and costs, pursuant to Section 11 U.S.C. § 550, and (iii) 

granting such other and further relief as this Court shall deem appropriate. 

COUNT VI 

Unjust Enrichment 

Against AESG and Mr. Maucha 

60. The Trustee reasserts the allegations set forth in paragraphs 1 through 28 as if fully 

set forth herein. 

61. The Trustee pleads this count in the alternative to her legal claims. 

62. The Trustee does not have an adequate remedy at law, and therefore, is entitled to 

relief under the equitable doctrine of unjust enrichment. 

63. The Debtor conferred a benefit on AESG by virtue of the Transfers. 

64. AESG had knowledge of the benefit of the Transfers conferred upon them. 

65. AESG voluntarily accepted and retained the benefit of the Transfers conferred upon 

them. 

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 9 of 24
10 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363

66. Under the circumstances, it would be inequitable for AESG to retain the benefit of 

the Transfers conferred upon them. 

WHEREFORE, the Trustee requests that the Court enter judgment in favor of the Trustee 

and against AESG in the amount of the Transfers, plus interest and costs, and granting such other 

and further relief as this Court shall deem appropriate. 

COUNT VII 

FRAUD 

Against AESG, ASEG Cap, and Mr. Maucha 

67. The Trustee reasserts the allegations set forth in paragraphs 1 through 28 as if fully 

set forth herein. 

68. The Debtor made the Transfers to AESG pursuant to the Agreement. 

69. Specifically, Mr. Maucha, through AESG Cap, made the following Representations 

in the Agreement: 

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 10 of 24
11 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363

70. Specifically, Mr. Maucha, through AESG Cap, knowingly misrepresented to the 

Debtor that if the Debtor transferred $400,000 to AESG, then AESG would invest the money in a 

“short-term SBLC monetization opportunity” and within “2/3 business days AESG will pay to the 

account designated by the [Debtor] the sum of $4,000,000, less nominal bank delivery fees.” 

71. The Representations were false, which falsity was known by AESG, AESG Cap, 

and Mr. Maucha, 

72. It was the intent of AESG, AESG Cap, and Mr. Maucha for the Debtor to rely on 

the false Representations. 

73. The Debtor relied on the Representations, and as a result, made the Transfers to 

AESG. 

74. Despite receiving the Transfers from the Debtor, AESG Cap never invested in the 

“short-term SBLC monetization opportunity” 

75. As a result of AESG, AESG Cap, and Mr. Maucha’s fraud, and the Debtor’s 

reasonable reliance thereon, the Debtor has suffered $400,000 in damages. 

WHEREFORE, the Trustee requests that the Court enter judgment in favor of the Trustee 

against AESG, AESG Cap, and Mr. Maucha (i) in the amount of $400,000, plus pre- and postCase 19-01807-LMI Doc 1 Filed 11/05/19 Page 11 of 24
12 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363

judgment interest; and (ii) granting such other and further relief as this Court shall deem 

appropriate. 

COUNT VIII 

Conversion 

Against AESG, ASEG Cap, and Mr. Maucha 

76. The Trustee reasserts the allegations set forth in paragraphs 1 through 28 as if fully 

set forth herein. 

77. The Debtor made the Transfers to AESG pursuant to the Agreement. 

78. Specifically, Mr. Maucha, through AESG Cap, made the following Representations 

in the Agreement: 

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 12 of 24
13 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363

79. Specifically, Mr. Maucha, through AESG Cap, knowingly misrepresented to the 

Debtor that if the Debtor transferred $400,000 to AESG, then AESG would invest the money in a 

“short-term SBLC monetization opportunity” and within “2/3 business days AESG will pay to the 

account designated by the [Debtor] the sum of $4,000,000, less nominal bank delivery fees.” 

80. The Representations were false, which falsity was known by AESG, AESG Cap, 

and Mr. Maucha, 

81. It was the intent of AESG, AESG Cap, and Mr. Maucha for the Debtor to rely on 

the false Representations. 

82. The Debtor relied on the Representations, and as a result, made the Transfers to 

AESG. 

83. Despite receiving the Transfers from the Debtor, AESG Cap never invested in the 

“short-term SBLC monetization opportunity” 

84. As a result of AESG, AESG Cap, and Mr. Maucha’s fraud, and the Debtor’s 

reasonable reliance thereon, the Debtor has suffered $400,000 in damages. 

85. Instead of investing the Transfers in a “short-term SBLC monetization 

opportunity,” AESG, AESG Capital, and Mr. Maucha converted the Transfers for their own use, 

which $400,000 was property of the Debtor. 

86. On numerous occasions, the Debtor informed Mr. Maucha that continued 

possession of the $400,000 was no longer permitted and demanded the return of same. Despite 

Mr. Maucha’s promises to the Debtor to return the $400,000, the money was never returned. 

87. As a result, the Debtor has suffered at least $400,000 in damages. 

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 13 of 24
14 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363

WHEREFORE, the Trustee requests that the Court enter judgment in favor of the Trustee 

and against AESG, AESG Cap, and Mr. Maucha in favor of the Trustee (i) in the amount of 

$400,000, plus pre- and post-judgment interest; and (ii) granting such other and further relief as 

this Court shall deem appropriate. 

Dated: November 5, 2019. 

Respectfully submitted, 

s/ Daniel N. Gonzalez 

Daniel N. Gonzalez, Esquire 

Florida Bar No. 592749 

dgonzalez@melandrussin.com

MELAND RUSSIN & BUDWICK, P.A. 

3200 Southeast Financial Center 

200 South Biscayne Boulevard 

Miami, Florida 33131 

Telephone: (305) 358-6363 

Telecopy: (305) 358-1221 

Attorneys for the Trustee 

 and 

 Michael P. Dunn, Esq. 

Florida Bar No. 100705 

michael.dunn@dunnlawpa.com 

 DUNN LAW, P.A. 

66 West Flagler Street, Suite 400 

Miami, Florida 33130 

Telephone: (786) 433-3866 

Telecopy: (786) 260-0269 

Co-Counsel for Plaintiff, Marcia T. Dunn, 

as Chapter 7 Trustee 

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 14 of 24
EXHIBIT A

Case l:18-cr-20784-CMA Document 31 Entered on FLSD Docket 05/23/2019 Page 1 of 2

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No.: 18-20784-CR-ALTONAGA

, UNITED STATES OF AMERICA,

v.

JORGE GARRIDO,

Defendant.

FACTUAL PROFFER

Had this case proceeded to trial, JORGE GARRIDO and the Government agree that the

Government would have proven the following facts beyond a reasonable doubt. The parties agree

that these facts, which are true, do not include all facts known to the Government and the defendant

relating to the Indictment. The parties agree that these facts are sufficient to prove the guilt ofthe

Defendant as to Count 1 ofthe above-referenced Indictment: • From in or around 2010, through in or around June 2017, in the Southern District ofFlorida

and: elsewhere, the Defendant conspired with Peter Block and others, to defraud certain

individuals. This Defendant and others participated in a scheme to defraud that raised money from

' advance fees, purportedly for, among other things, funding start-up projects, participating in

humanitarian platforms, monetizing bank instruments, and engaging in platform trading. The

victims relied on the Defendant's materially false and fraudulent representations, and then

GARRIDO and others misappropriating these advance fees for the defendant and his co

conspirators' personal use.

This conspiracy occurred by means ofmaterially false and fraudulent pretenses, as well as

material omissions, to knowingly devise a scheme and artifice to defraud and to obtain money and . property through the delivery of certain wire communications, contrary to Title 1 8, United States

Code, Section 1343, and all in violation ofTitle 18, United States Code, Section 1349.

GARRIDO was the president, director and registered agent of G & C Investment Corp.

("G&C"), which was a Florida corporation that purportedly had "relationships with suppliers,

buyers, and sellers of fuel and sugar products" and acted as a commodities trader. G&C claimed

to "have developed close ties with the most important people in the industry."

In or around 2010, GARRIDO approached potential investors and promoted himself as

someone who could generate large sums of money in return for a relatively small advance fee. In

or around 2010, GARRIDO began receiving investor funds via U.S. mail and bank wires, and

depositing their money into bank accounts he controlled. In return for money detained from

investments in advance, GARRIDO promised to generate staggering returns of 15 times, 20 times,

or more of an investor's advance fee. GARRIDO promised to provide returns within a short time

EXHIBIT A

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 15 of 24
Case l:18-cr-20784-CMA Document 31 Entered on FLSD Docket 05/23/2019 Page 2 of 2

frame, typically 30 to 45 banking days. GARRIDO eased investor concerns about the safety and

security of their principal by having investors transfer their money to Block, a co-conspirator

attorney escrow account, where, according to GARRIDO, the funds could not be transferred from

the attorney to GARRIDO before GARRIDO generated returns on the investments. In truth, after

investors wired their money to the account, the attorney took a portion ofthe funds for his own

benefit and wired the rest ofthe advanced fee money to GARRIDO. • GARRIDO also guaranteed the safety ofinvestors' principal by stating that he owned U.S.

Treasury Notes and claimed the notes as collateral. In truth, the U.S. Treasury Notes did not exist.

Furthermore, GARRIDO and his co-conspirators used false and fraudulent emails from a financial

advisor at a financial institution purporting to vouch for the existence of the notes. GARRIDO

also guaranteed the safety ofinvestors' principal by claiming that he held a standby letter ofcredit

from JP Morgan Chase as collateral. In truth, the standby JP Morgan Chase letter ofcredit did not

exist. Furthermore, GARRIDO and his co-conspirators used false and fraudulent financial

documents to investors to vouch for the existence ofthe standby letter of credit.

This Defendant and his co-conspirators made numerous materially false and fraudulent

statements to investors and withheld material facts, including, but not limited to; that banking

instruments provided to investors by GARRIDO, including but not limited to a $30,000,000

"Standby- Letter of Credit" from JP Morgan Chase, were legitimate and authentic banking

instruments; that GARRIDO never had funds to repay investors' principal or returns; that

GARRIDO and his co-conspirators would use nearly all the investor funds for their personal

benefit. .. . i»

Date: fTAy/ 1 / Roger Cruz /

Assistant Uniiei Attorney

Date:

'Samuel Rabin

Attorney fpr-Befendant

Date: V A/ / f By:

Jorge Gam<

DefenaAtir

2

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 16 of 24
Bank Name Account Name Account No. Date Type Check No. Payee Amount

Citibank G&C Investment Corp. 9139693233 04/06/16 Wire N/A American Eagle Services Group Inc. $ (250,000.00)

Citibank G&C Investment Corp. 9139693233 04/11/16 Wire N/A American Eagle Services Group Inc. (150,000.00)

American Eagle Services Group Inc. Total $ (400,000.00)

In re: G&C Investment Corp.

Case No.: 17-20150-LMI

Transfers To American Eagle Services Group Inc.

from April 6, 2016 through April 11, 2016

Page 1 of 1

EXHIBIT B

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 17 of 24
AESG CAPITAL, INC 

A DIVISION OF 

AMERICAN EAGLE SERVICES GROUP, INC 

 New York, NY. 10005 

Phone: (646) 820-3142 | Fax: On Demand 

www.AESGCapital.com 

www.Americaneagleservicesgroup.com

MOU & WORKING AGREEMENT

Private & Confidential

AESG Capital Agreement Code: 

AESG - Jorge Garrido

This Private Funding Agreement dated this 6th Day of April 2016 is made by AESG Capital, 

Inc.

And between the undersigned

Jorge Garrido, CEO / President

G&C Investment Corp

Fax: 858 408 4555

USA Office

1200 Brickell Ave.

18th Floor

Miami, FL 33131

Hereinafter referred to as “PARTICIPANT(S)”

 RECITALS

Whereas, AESG has an existing relationship with a Bank Trade Group which offers a limited 

investment opportunity that requires a total participation fee of $1,000,000. 

Whereas, G & C Investments has $400,000 to invest in a short-term SBLC monetization 

opportunity for a shared interest of proceeds derived from the completion of the 

transaction. 

Whereas, AESG will arrange for the balance of funding that is sufficient to initiate the SBLC 

monetization transaction. 

After receiving the $400,000.00 AESG will procure an SBLC. AESG has the availability of 

such an instrument and will procure the same immediately upon receipt of the funds from 

G&C, and will notify G&C when the SBLC is obtained. 

Asset Management, Commodities, Capital Markets

Page 1 7 of 

DocuSign Envelope ID: DBEEC5D8-16E9-4F32-A5F3-781B620F2482 Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 18 of 24
AESG CAPITAL, INC 

A DIVISION OF 

AMERICAN EAGLE SERVICES GROUP, INC 

 New York, NY. 10005 

Phone: (646) 820-3142 | Fax: On Demand 

www.AESGCapital.com 

www.Americaneagleservicesgroup.com

MOU & WORKING AGREEMENT

Private & Confidential

AESG Capital Agreement Code: 

AESG - Jorge Garrido

Whereas, AESG will secure a $50M SBLC from a top tier bank to be delivered in one 

tranche. 

When the SBLC is obtained AESG will arrange for an investment program to commence with 

in a manner to allow the return to be paid to G&C within 2/3 business days after delivery 

to AESG of the $400,000. 

Within said 2/3 business days AESG will pay to the account designated by G&C below the 

sum of $4,000,000, less nominal bank delivery fees. 

AESG is responsible for all aspects of the transaction other than delivery of the 

$400,000.00 and if any of the process shall fail there shall be a default and AESG will 

immediately return to G&C the $400,000.00. If any of the above timing shall not be met it 

shall be considered a default triggering return of the $400,000.00, whether or not a SBLC 

has been purchased by AESG. 

 

 

NOW THEREFORE, the parties have agreed as follows:

Incorporation of Recitals

The above Recitals are hereby incorporated into this agreement as if first herein 

written.

 

Obligation and Profit Distribution.

G & C Investments shall receive $4,000,000 from the net proceeds derived from the SBLC 

monetization transaction. The payments of $4,000,000 shall be transferred to G & C 

Investments nominated bank account as noted below: 

 

Asset Management, Commodities, Capital Markets

Page 2 7 of 

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AESG CAPITAL, INC 

A DIVISION OF 

AMERICAN EAGLE SERVICES GROUP, INC 

 New York, NY. 10005 

Phone: (646) 820-3142 | Fax: On Demand 

www.AESGCapital.com 

www.Americaneagleservicesgroup.com

MOU & WORKING AGREEMENT

Private & Confidential

AESG Capital Agreement Code: 

AESG - Jorge Garrido

G&C Investments Coordinates for receipt of Net Proceeds - (Total: $4,000,000) 

TRANSACTION PAYMASTER – Banking Account Information & Coordinates

BANK NAME BMO Harris Bank

BANK ADDRESS 500 Half Day Road, Buffalo Grove, IL 60089

BANK OFFICER Sylwia Pacyk

BANK OFFICER TELEPHONE/FAX 847-876-8404

BANK OFFICER E-MAIL ADDRESS Sylwia.pacyk@bmo.com

ABA BANK ROUTING CODE 071025661

SWIFT CODE1 HATRUS-44

ACCOUNT NAME David Feltman d/b/a The Law Office of David Feltman Client 

Funds 2

ACCOUNT HOLDER’S ADDRESS 56 Carlyle Lane, Buffalo Grove, IL 60089

ACCOUNT HOLDER’S TELEPHONE 847-609-4230

ACCOUNT NUMBER 4810126757

PAYMASTYER NAME David Feltman d/b/a The Law Office of David Feltman

PAYMASTER PASSPORT1 USA 479681417

PAYMASTER TELEPHONE//EMAIL 847-609-4230/ feltmanlaw22@gmail.com

Asset Management, Commodities, Capital Markets

Page 3 7 of 

DocuSign Envelope ID: DBEEC5D8-16E9-4F32-A5F3-781B620F2482 Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 20 of 24
AESG CAPITAL, INC 

A DIVISION OF 

AMERICAN EAGLE SERVICES GROUP, INC 

 New York, NY. 10005 

Phone: (646) 820-3142 | Fax: On Demand 

www.AESGCapital.com 

www.Americaneagleservicesgroup.com

MOU & WORKING AGREEMENT

Private & Confidential

AESG Capital Agreement Code: 

AESG - Jorge Garrido

NON-PERFORMANCE/DEFAULT. If for any reason AESG should fail to receive any proceeds 

from the SBLC monetization transaction in the timeframe herein specified, then a default 

of this Agreement shall be deemed to have occurred. In the event of default AESG shall 

return $400,000 to G&C Investments designated bank account within 48 hours of default 

declaration. 

Applicable Law. The terms and provisions of this Agreement shall be interpreted in

accordance with the laws of the United States of America. 

Attorney’s Fees & Costs. Should any litigation arise out o f this agreement, 

each party shall pay its own attorney’s fees and costs but the guilty party shall reimburse 

all expenses of the counter party upon resolution.

Entire Agreement. This Agreement terminates and replaces all prior 

Agreements, either written, oral, or implied, between the parties hereto, and 

constitutes the entire agreement between the parties. 

Amendment. All amendments of this Agreement must be in writing signed by all parties.

Indemnification. Each party agrees to defend, indemnify, and hold the other party

harmless from all claims, demands, and liabilities arising from that party’s actions, 

past, present and future.

Confidentiality. All information obtained by all parties regarding the 

transaction and deal shall be held in strictest confidence, and may not be released 

without the advance written permission of the other party.

Note: Electronic Signatures on this MOU are acceptable and legally binding. 

Agreed to and signed on this 6th day of April, 2016 by:

Asset Management, Commodities, Capital Markets

Page 4 7 of 

DocuSign Envelope ID: DBEEC5D8-16E9-4F32-A5F3-781B620F2482 Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 21 of 24
AESG CAPITAL, INC 

A DIVISION OF 

AMERICAN EAGLE SERVICES GROUP, INC 

 New York, NY. 10005 

Phone: (646) 820-3142 | Fax: On Demand 

www.AESGCapital.com 

www.Americaneagleservicesgroup.com

MOU & WORKING AGREEMENT

Private & Confidential

AESG Capital Agreement Code: 

AESG - Jorge Garrido

ACCEPTED AND AGREED WITHOUT CHANGE:

Date signed:

Name:

Title:

Company:

Telephone No.:

Email address:

Signature:

Asset Management, Commodities, Capital Markets

Page 5 7 of 

DocuSign Envelope ID: DBEEC5D8-16E9-4F32-A5F3-781B620F2482

garrido@gcinvestmentcorp.com

Jorge Gorrido

G&C investment corp

4/6/2016

CEO 

305-803-7272

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 22 of 24
AESG CAPITAL, INC 

A DIVISION OF 

AMERICAN EAGLE SERVICES GROUP, INC 

 New York, NY. 10005 

Phone: (646) 820-3142 | Fax: On Demand 

www.AESGCapital.com 

www.Americaneagleservicesgroup.com

MOU & WORKING AGREEMENT

Private & Confidential

AESG Capital Agreement Code: 

AESG - Jorge Garrido

For AESG Capital:

This agreement constitutes an entire understanding and cannot be modified 

unless agreed to in writing and signed by all parties. This agreement is 

 Date signed:

Signatory’s Name: Paul Maucha 

Title: Principal

Company: AESG Capital Inc.

Telephone No.: 646-820-3142

Email address: paul@aesgcapital.com

Signature:

Asset Management, Commodities, Capital Markets

Page 6 7 of 

DocuSign Envelope ID: DBEEC5D8-16E9-4F32-A5F3-781B620F2482

4/6/2016

Case 19-01807-LMI Doc 1 Filed 11/05/19 Page 23 of 24
AESG CAPITAL, INC 

A DIVISION OF 

AMERICAN EAGLE SERVICES GROUP, INC 

 New York, NY. 10005 

Phone: (646) 820-3142 | Fax: On Demand 

www.AESGCapital.com 

www.Americaneagleservicesgroup.com

MOU & WORKING AGREEMENT

Private & Confidential

AESG Capital Agreement Code: 

AESG - Jorge Garrido

binding on the parties aforementioned, their heirs and assigns and all others succeeding in the interest to any party either directly or indirectly. 

Funds Wiring Instructions:

American Eagle Services Group, Inc.

1231 B. Good Hope Rd. SE.

Washington, DC. 20020

Bank of America

Account # 0022 6004 4370

Routing # 026009593

Swift Code BOFAUS3N

Asset Management, Commodities, Capital Markets

Page 7 7 of 

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