-v.- : SEALED INDICTMENT

Transcription

1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X UNITED STATES OF AMERICA : -v.- : SEALED INDICTMENT BEVERLY MOZER-BROWNE, : 06 Cr. PHILLIP A. BROWNE, SANDFORD BROWNE, : a/k/a Tyson, GERRARDA BROWNE, : a/k/a Gerry, WILLIANA BROWNE, : JOHN LOFTON, a/k/a Big John, : PETER ABSOLAM, a/k/a Lloyd, : KEITH MAHASE, ABDUL HAKIM MUHAMMAD, : TIFFANY WAYMAN, NARRISA MOHAMMED, : JAMSHEED JEREMIAH, a/k/a Jason, : KHADIGA CLARKE, a/k/a Kelly, : LENNARD PRESCOD, a/k/a Bob, : MAKEBA ISAROON, RHONDA EATON, : RODERICK CHASSEAU, CAMERON A. LLOYD, : KWASI DRAKES, NARINE JAIRAM, : CHERYLENE RAMDASS, TULSI RAMRUP, : NATASHA HERCULES, ANNEKA RAMPERSAD, : TASLEEM KUDRATH, MERVIN TRANCOSO, : ADRIAN GOURSAHAB, NIGEL DEFOUR, : WENDY HARRISON, and KERRY RAMPERSAD, : Defendants. : X

2 COUNT ONE (Conspiracy to Commit Visa Fraud) The Grand Jury charges: Background 1. BEVERLY MOZER-BROWNE, the defendant ( MOZER- BROWNE ), owned and operated a business called Help Preparers Professional Services ( HPPS ), located at Jamaica Avenue in Queens, New York. 2. HPPS purported to offer its customers assistance in a variety of financial and legal matters, but in fact, the primary business at HPPS was providing permanent residence documents ( green cards ) by means of fraud. 3. SANDFORD BROWNE, a/k/a Tyson, GERRARDA BROWNE, a/k/a Gerry, WILLIANA BROWNE, PETER ABSOLAM, a/k/a Lloyd, KEITH MAHASE, ABDUL HAKIM MUHAMMAD, NARRISA MOHAMMED, JAMSHEED JEREMIAH, a/k/a Jason, KHADIGA CLARKE, a/k/a Kelly, LENNARD PRESCOD, a/k/a Bob, RODERICK CHASSEAU, CAMERON A. LLOYD, and KWASI DRAKES, the defendants, were all employed by HPPS to assist in its illegal activity. 4. Until in or about December 2005, PHILLIP A. BROWNE, the defendant ( BROWNE ), MOZER-BROWNE s brother, was employed as a District Adjudication Officer by the United States Citizenship and Immigration Services ( CIS ) (formerly known as 2

3 the Immigration and Naturalization Service or INS ) at 26 Federal Plaza, New York, New York. 5. MOZER-BROWNE and her co-conspirators at HPPS charged an applicant anywhere from approximately $8,000 to approximately $16,000 to provide a green card by means of fraud. A person seeking these services (an HPPS applicant ) was typically provided with documentation of marriage to a United States citizen in one of two ways: Either MOZER-BROWNE and her co-conspirators would pay a United States citizen to enter into a sham marriage with the HPPS applicant, or they would produce phony documentation indicating that a marriage to a United States citizen had occurred at some time in the past. 6. JOHN LOFTON, a/k/a Big John, and RHONDA EATON, the defendants, helped MOZER-BROWNE and HPPS find United States citizens willing to enter into sham marriages with HPPS applicants. TIFFANY WAYMAN and MAKEBA ISAROON, the defendants, were two United States citizens paid by HPPS to enter into sham marriages with HPPS applicants. CAMERON A. LLOYD, the defendant, performed sham marriages for HPPS applicants. 7. Once the HPPS applicant had documentation of a marriage to a United States citizen, employees at HPPS would prepare an application package for a green card. The application usually included fraudulent financial information, such as 3

4 fictitious letters from employers or banks. The application was then mailed to CIS. 8. Following the submission of the fraudulent application, the HPPS applicant received an appointment for an interview at the CIS office at 26 Federal Plaza. BROWNE then approved the applications submitted by his co-conspirators at HPPS without requiring the HPPS applicant to appear at CIS for the interview. BROWNE generated a Form I-181 ( Memorandum of Creation of Record of Lawful Permanent Residence ) on behalf of the HPPS applicant, and a green card was issued to the HPPS applicant. 9. From at least in or about April 2001 through in or about November 2005, MOZER-BROWNE, BROWNE, and their coconspirators provided hundreds of fraudulent green cards to HPPS applicants, receiving more than one million dollars in proceeds. Statutory Allegation 10. From at least in or about April 2001 through in or about November 2005, in the Southern District of New York and elsewhere, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, SANDFORD BROWNE, a/k/a Tyson, GERRARDA BROWNE, a/k/a Gerry, WILLIANA BROWNE, JOHN LOFTON, a/k/a Big John, PETER ABSOLAM, a/k/a Lloyd, KEITH MAHASE, ABDUL HAKIM MUHAMMAD, TIFFANY WAYMAN, NARRISA MOHAMMED, JAMSHEED JEREMIAH, a/k/a Jason, KHADIGA CLARKE, a/k/a Kelly, LENNARD PRESCOD, a/k/a Bob, MAKEBA 4

5 ISAROON, RHONDA EATON, RODERICK CHASSEAU, CAMERON A. LLOYD, and KWASI DRAKES, the defendants, and others known and unknown, unlawfully, willfully, and knowingly combined, conspired, confederated, and agreed together and with each other to commit an offense against the United States, to wit, violations of Section 1546 of Title 18, United States Code. 11. It was a part and an object of the conspiracy that BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, SANDFORD BROWNE, a/k/a Tyson, GERRARDA BROWNE, a/k/a Gerry, WILLIANA BROWNE, JOHN LOFTON, a/k/a Big John, PETER ABSOLAM, a/k/a Lloyd, KEITH MAHASE, ABDUL HAKIM MUHAMMAD, TIFFANY WAYMAN, NARRISA MOHAMMED, JAMSHEED JEREMIAH, a/k/a Jason, KHADIGA CLARKE, a/k/a Kelly, LENNARD PRESCOD, a/k/a Bob, MAKEBA ISAROON, RHONDA EATON, RODERICK CHASSEAU, CAMERON A. LLOYD, and KWASI DRAKES, the defendants, and others known and unknown, unlawfully, willfully and knowingly would and did utter, use, possess, obtain, accept and receive immigrant and nonimmigrant visas, permits, alien registration receipt cards, and other documents prescribed by statute and regulation as evidence of authorized stay and employment in the United States, knowing them to have been procured by means of false claims and statements, and to have been otherwise procured by fraud and unlawfully obtained, in violation of Title 18, United States Code, Section

6 Overt Acts 12. In furtherance of the conspiracy and to effect the illegal object thereof, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, SANDFORD BROWNE, a/k/a Tyson, GERRARDA BROWNE, a/k/a Gerry, WILLIANA BROWNE, JOHN LOFTON, a/k/a Big John, PETER ABSOLAM, a/k/a Lloyd, KEITH MAHASE, ABDUL HAKIM MUHAMMAD, TIFFANY WAYMAN, NARRISA MOHAMMED, JAMSHEED JEREMIAH, a/k/a Jason, KHADIGA CLARKE, a/k/a Kelly, LENNARD PRESCOD, a/k/a Bob, MAKEBA ISAROON, RHONDA EATON, RODERICK CHASSEAU, CAMERON A. LLOYD, and KWASI DRAKES, the defendants, and others known and unknown, committed the following overt acts, among others, in the Southern District of New York and elsewhere: a. In or about April 2001, RODERICK CHASSEAU, the defendant, submitted a fraudulent green card application to CIS (then INS). b. In or about August 2003, JAMSHEED JEREMIAH, a/k/a Jason, the defendant, submitted a fraudulent green card application to CIS. c. In or about January 2004, NARRISA MOHAMMED, the defendant, submitted a fraudulent green card application to CIS. d. In or about March 2004, RHONDA EATON, the defendant, submitted a fraudulent Petition For Alien Relative to CIS. 6

7 e. On or about May 14, 2004, ABDUL HAKIM MUHAMMAD, the defendant, deposited approximately $9,000 in cash proceeds into his checking account at New York Community Bank. f. In or about May 2004, SANDFORD BROWNE, a/k/a Tyson, the defendant, submitted a fraudulent green card application to CIS. g. In or about May 2004, WILLIANA BROWNE, the defendant, submitted a fraudulent green card application to CIS. h. In or about June 2004, KHADIGA CLARKE, a/k/a Kelly, the defendant, submitted a fraudulent green card application to CIS. i. On or about June 24, 2004, MAKEBA ISAROON, the defendant, entered into a fraudulent marriage with an HPPS applicant. j. On or about August 4, 2004, PHILLIP A. BROWNE approved SANDFORD BROWNE s fraudulent application for a green card at CIS in New York, New York. k. In or about August 2004, KEITH MAHASE, the defendant, submitted a fraudulent green card application to CIS. l. On or about August 30, 2004, KWASI DRAKES, the defendant, deposited approximately $9,000 in cash into her checking account at Chase. 7

8 m. In or about September 2004, GERRARDA BROWNE, a/k/a Gerry, the defendant, submitted a fraudulent green card application to CIS. n. On or about March 14, 2005, CAMERON A. LLOYD, the defendant, conducted a sham marriage ceremony for an HPPS applicant. o. On or about May 27, 2005, PETER ABSOLAM, a/k/a Lloyd, the defendant, introduced an HPPS applicant for a fraudulent green card ( Applicant-1 ) to MOZER-BROWNE. p. On or about June 15, 2005, MOZER-BROWNE, RHONDA EATON, and JOHN LOFTON, a/k/a Big John, the defendants, introduced Applicant-1 to TIFFANY WAYMAN, who was paid to enter into a sham marriage with Applicant-1. q. On or about June 15, 2005, TIFFANY WAYMAN applied for and obtained a license to marry Applicant-1. r. On or about November 9, 2005, LENNARD PRESCOD, a/k/a Bob, provided fraudulent birth certificates to a confidential informant in exchange for cash. (Title 18, United States Code, Sections 371.) COUNT TWO (Money Laundering Conspiracy) The Grand Jury further charges: 13. From at least in or about March 2004, up to and including at least in or about May 2005, in the Southern District 8

9 of New York and elsewhere, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, ABDUL HAKIM MUHAMMAD, and KWASI DRAKES, the defendants, and others known and unknown, unlawfully, willfully and knowingly did combine, conspire, confederate and agree together and with each other to commit offenses against the United States, to wit, violations of Title 18, United States Code, Section 1956(a)(1)(B)(i). 14. It was a part and an object of said conspiracy that BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, ABDUL HAKIM MUHAMMAD, and KWASI DRAKES, the defendants, and others known and unknown, in an offense involving and affecting interstate and foreign commerce, knowing that property involved in certain financial transactions represented the proceeds of some form of unlawful activity, unlawfully, willfully, and knowingly would and did conduct and attempt to conduct financial transactions, which in fact involved the proceeds of specified unlawful activity, to wit, visa fraud, knowing that the transactions were designed in whole and in part to conceal and disguise the nature, location, source, ownership and control of the proceeds of specified unlawful activity, in violation of Title 18, United States Code, Section 1956(a)(1)(B)(i). Means and Methods of the Conspiracy 15. Among the means and methods employed in conducting and participating in the conduct of the conspiracy were the following: 9

10 a. BEVERLY MOZER-BROWNE ( MOZER-BROWNE ) and PHILLIP A. BROWNE ( BROWNE ), the defendants, and their coconspirators made large cash deposits of visa fraud proceeds into bank accounts at various financial institutions, usually in amounts smaller than $10,000. b. In order to conceal the illegal source of the cash, ABDUL HAKIM MUHAMMAD ( MUHAMMAD ) and KWASI DRAKES ( DRAKES ), the defendants, made large cash deposits and then transferred the money into accounts controlled by MOZER-BROWNE or members of her family, or withdrew the money by writing checks to MOZER-BROWNE or members of her family. c. In addition to dividing the cash proceeds from the visa fraud conspiracy among different bank accounts, MOZER-BROWNE and her co-conspirators concealed the proceeds by purchasing a number of properties, including several properties in Florida, held in various straw purchasers names. Overt Acts 16. In furtherance of said conspiracy and to effect the illegal object thereof, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, ABDUL HAKIM MUHAMMAD, and KWASI DRAKES, the defendants, and others known and unknown, committed the following overt acts, among others, in the Southern District of New York and elsewhere: a. On or about March 8, 2004, MOZER-BROWNE deposited approximately $22,400 (including $7,400 in cash) into 10

11 her checking account at a Chase bank branch in New York, New York. b. On or about March 15, 2004, MOZER-BROWNE deposited approximately $7,500 (including $7,000 in cash and a $500 check made out to Kwasi Drakes ) into her checking account at a Chase bank branch in New York, New York. c. On or about May 14, 2004, MUHAMMAD deposited approximately $9,000 in cash into his checking account at New York Community Bank. d. On or about May 24, 2004, MUHAMMAD deposited approximately $9,000 into his checking account at New York Community Bank. e. On or about June 9, 2004, MOZER-BROWNE deposited approximately $9,000 in cash into her bank account at Chase. f. On or about June 9, 2004, DRAKES deposited approximately $3,000 into her bank account at Chase. g. On or about June 10, 2004, DRAKES deposited approximately $3,900 into her bank account at Chase. h. On or about June 10, 2004, DRAKES transferred approximately $4,000 from her account at Chase into MOZER- BROWNE s Chase account. 11

12 i. On or about July 1, 2004, MOZER-BROWNE deposited a check for approximately $27,000 to her checking account at a Chase bank branch in New York, New York. j. On or about August 30, 2004, MOZER-BROWNE deposited approximately $9,000 in cash into her bank account at Chase. k. On or about August 30, 2004, DRAKES deposited approximately $9,000 in cash into her bank account at Chase. l. On or about August 30, 2004, DRAKES transferred approximately $9,000 from her account into MOZER- BROWNE s Chase account. m. On or about September 1, 2004, MOZER-BROWNE deposited approximately $13,000 into her bank account at Chase. n. On or about September 1, 2004, DRAKES deposited approximately $4,600 in cash into her account at Chase. o. On or about September 1, 2004, DRAKES transferred approximately $4,600 from her account into MOZER- BROWNE s Chase account. p. On or about September 10, 2004, MOZER-BROWNE deposited approximately $5,000 in cash into her account at Chase. q. On or about September 10, 2004, DRAKES made two deposits into her bank account at Chase: one for approximately $7,000 and one for approximately $5,

13 r. On or about September 17, 2004, DRAKES transferred approximately $8,700 from her account into MOZER- BROWNE s Chase account. s. On or about December 2, 2004, MUHAMMAD made two deposits totaling $9,400 in cash into his account at New York Community Bank. t. On or about December 2, 2004, DRAKES deposited approximately $9,400 in cash into her account at Chase. u. On or about December 2, 2004, DRAKES wrote a check for $9,000 from her Chase account made out to a coconspirator s relative ( Relative-1 ) with a memo indicating gift towards purchase of house. v. On or about December 3, 2004, MUHAMMAD wrote a check for approximately $9,000 from his New York Community Bank account to Relative-1 with a memo indicating loan to purchase house. w. On or about December 3, 2004, MOZER-BROWNE deposited approximately $9,000 in cash into her account at Chase. x. On or about December 3, 2004, MOZER-BROWNE wrote a check for approximately $8,500 from her Chase account to Relative-1 with a memo gift to son for purchase of property. y. On or about December 17, 2004, MOZER-BROWNE deposited approximately $9,000 into her checking account at Chase. 13

14 z. On or about December 17, 2004, MOZER-BROWNE wired approximately $9,000 from her Chase checking account to Prominent Title Insurance. aa. On or about December 17, 2004, DRAKES deposited approximately $9,130 in cash into her account at Chase. bb. On or about December 17, 2004, DRAKES transferred approximately $9, from her Chase checking account to Prominent Title Insurance. cc. On or about December 21, 2004, BROWNE deposited approximately $9, into his savings account at Washington Mutual Bank. dd. On or about December 21, 2004, BROWNE withdrew an official check for approximately $9, from his savings account at Washington Mutual Bank made out to Prominent Title Insurance. ee. On or about January 13, 2005, MUHAMMAD deposited approximately $5,000 in cash into his account at New York Community Bank. ff. On or about January 24, 2005, BROWNE deposited approximately $8,000 in cash into his account at Washington Mutual Bank. gg. On or about January 27, 2005, BROWNE deposited approximately $8,800 in cash into his account at a Washington Mutual Bank branch in New York, New York. 14

15 hh. On or about January 31, 2005, BROWNE deposited approximately $5,000 in cash into his account at a Washington Mutual Bank branch in New York, New York. ii. On or about February 7, 2005, BROWNE deposited approximately $9,000 in cash into his account at Washington Mutual Bank. jj. On or about February 7, 2005, DRAKES deposited approximately $8,740 into her account at JPMorgan Chase. kk. On or about February 9, 2005, BROWNE deposited approximately $9,000 in cash into his account at a Washington Mutual Bank branch in New York, New York. ll. On or about February 11, 2005, BROWNE deposited approximately $8,500 in cash into his account at a Washington Mutual Bank branch in New York, New York. mm. On or about February 14, 2005, BROWNE deposited approximately $9,000 in cash into his account at a Washington Mutual Bank branch in New York, New York. nn. On or about February 15, 2005, BROWNE deposited approximately $6,500 in cash into his account at a Washington Mutual Bank branch in New York, New York. oo. On or about February 18, 2005, BROWNE deposited approximately $9,000 in cash into his account at a Washington Mutual Bank branch in Kissimmee, Florida. 15

16 pp. On or about February 22, 2005, BROWNE deposited approximately $7,600 in cash into his account at a Washington Mutual Bank branch in New York, New York. qq. On or about February 23, 2005, BROWNE deposited approximately $9,000 in cash into his account at a Washington Mutual Bank branch in New York, New York. rr. On or about February 25, 2005, BROWNE deposited approximately $8,800 in cash into his account at a Washington Mutual Bank branch in New York, New York. ss. On or about March 5, 2005, DRAKES wrote a check to BROWNE from her JPMorgan Chase account for approximately $8,500. tt. On or about March 5, 2005, BROWNE deposited a total of approximately $16,500 into his account at Washington Mutual Bank. uu. On or about March 14, 2005, BROWNE deposited approximately $9,000 into his account at Washington Mutual Bank. vv. On or about May 5, 2005, MUHAMMAD received a transfer of approximately $8,500 into his account at New York Community Bank from the account of Relative-1. (Title 18, United States Code, Section 1956(h).) 16

17 COUNT THREE The Grand Jury further charges: 17. In or about October 2004, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, and WENDY HARRISON, the defendants, unlawfully, willfully and knowingly uttered, used, possessed, obtained, accepted and received immigrant and nonimmigrant visas, permits, alien registration receipt cards, and other documents prescribed by statute and regulation as evidence of authorized stay and employment in the United States, knowing them to have been procured by means of false claims and statements, and to have been otherwise procured by fraud and unlawfully obtained, to wit, the defendants obtained a green card for WENDY HARRISON by submitting a forged marriage certificate and fraudulent financial documents. (Title 18, United States Code, Sections 1546 and 2.) COUNT FOUR The Grand Jury further charges: 18. In or about November 2004, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, and TASLEEM KUDRATH, the defendants, unlawfully, willfully and knowingly uttered, used, possessed, obtained, accepted and received immigrant and nonimmigrant visas, permits, alien registration receipt cards, and other documents prescribed by statute and regulation as evidence of authorized stay and employment in the United States, knowing them to have 17

18 been procured by means of false claims and statements, and to have been otherwise procured by fraud and unlawfully obtained, to wit, the defendants obtained a green card for TASLEEM KUDRATH by submitting a forged marriage certificate and fraudulent financial documents. (Title 18, United States Code, Sections 1546 and 2.) COUNT FIVE The Grand Jury further charges: 19. In or about September 2004, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, and TULSI RAMRUP, the defendants, unlawfully, willfully and knowingly uttered, used, possessed, obtained, accepted and received immigrant and nonimmigrant visas, permits, alien registration receipt cards, and other documents prescribed by statute and regulation as evidence of authorized stay and employment in the United States, knowing them to have been procured by means of false claims and statements, and to have been otherwise procured by fraud and unlawfully obtained, to wit, the defendants obtained a green card for TULSI RAMRUP using a forged marriage certificate and fraudulent financial documents. (Title 18, United States Code, Sections 1546 and 2.) COUNT SIX The Grand Jury further charges: 20. In or about November 2004, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, and CHERYLENE RAMDASS, the defendants, 18

19 unlawfully, willfully and knowingly uttered, used, possessed, obtained, accepted and received immigrant and nonimmigrant visas, permits, alien registration receipt cards, and other documents prescribed by statute and regulation as evidence of authorized stay and employment in the United States, knowing them to have been procured by means of false claims and statements, and to have been otherwise procured by fraud and unlawfully obtained, to wit, the defendants obtained a green card for CHERYLENE RAMDASS using a forged marriage certificate and fraudulent financial documents. (Title 18, United States Code, Sections 1546 and 2.) COUNT SEVEN The Grand Jury further charges: 21. In or about November 2004, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, and ADRIAN GOURSAHAB, the defendants, unlawfully, willfully and knowingly uttered, used, possessed, obtained, accepted and received immigrant and nonimmigrant visas, permits, alien registration receipt cards, and other documents prescribed by statute and regulation as evidence of authorized stay and employment in the United States, knowing them to have been procured by means of false claims and statements, and to have been otherwise procured by fraud and unlawfully obtained, to wit, the defendants obtained a green card for ADRIAN GOURSAHAB 19

20 using a forged marriage certificate and fraudulent financial documents. (Title 18, United States Code, Sections 1546 and 2.) COUNT EIGHT The Grand Jury further charges: 22. In or about October 2004, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, and NIGEL DEFOUR, the defendants, unlawfully, willfully and knowingly uttered, used, possessed, obtained, accepted and received immigrant and nonimmigrant visas, permits, alien registration receipt cards, and other documents prescribed by statute and regulation as evidence of authorized stay and employment in the United States, knowing them to have been procured by means of false claims and statements, and to have been otherwise procured by fraud and unlawfully obtained, to wit, the defendants obtained a green card for NIGEL DEFOUR using a forged marriage certificate and fraudulent financial documents. (Title 18, United States Code, Sections 1546 and 2.) COUNT NINE The Grand Jury further charges: 23. In or about November 2004, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, and KERRY RAMPERSAD, the defendants, unlawfully, willfully and knowingly uttered, used, possessed, obtained, accepted and received immigrant and nonimmigrant visas, permits, alien registration receipt cards, and other documents 20

21 prescribed by statute and regulation as evidence of authorized stay and employment in the United States, knowing them to have been procured by means of false claims and statements, and to have been otherwise procured by fraud and unlawfully obtained, to wit, the defendants obtained a green card for KERRY RAMPERSAD using a forged marriage certificate and fraudulent financial documents. (Title 18, United States Code, Sections 1546 and 2.) COUNT TEN The Grand Jury further charges: 24. In or about November 2004, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, and MERVIN TRANCOSO, the defendants, unlawfully, willfully and knowingly uttered, used, possessed, obtained, accepted and received immigrant and nonimmigrant visas, permits, alien registration receipt cards, and other documents prescribed by statute and regulation as evidence of authorized stay and employment in the United States, knowing them to have been procured by means of false claims and statements, and to have been otherwise procured by fraud and unlawfully obtained, to wit, the defendants obtained a green card for MERVIN TRANCOSO using a forged marriage certificate and fraudulent financial documents. (Title 18, United States Code, Sections 1546 and 2.) 21

22 COUNT ELEVEN The Grand Jury further charges: 25. In or about March 2005, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, and NARINE JAIRAM, the defendants, unlawfully, willfully and knowingly uttered, used, possessed, obtained, accepted and received immigrant and nonimmigrant visas, permits, alien registration receipt cards, and other documents prescribed by statute and regulation as evidence of authorized stay and employment in the United States, knowing them to have been procured by means of false claims and statements, and to have been otherwise procured by fraud and unlawfully obtained, to wit, the defendants obtained a green card for NARINE JAIRAM using a forged marriage certificate and fraudulent financial documents. (Title 18, United States Code, Sections 1546 and 2.) COUNT TWELVE The Grand Jury further charges: 26. In or about March 2005, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, and NATASHA HERCULES, the defendants, unlawfully, willfully and knowingly uttered, used, possessed, obtained, accepted and received immigrant and nonimmigrant visas, permits, alien registration receipt cards, and other documents prescribed by statute and regulation as evidence of authorized stay and employment in the United States, knowing them to have been procured by means of false claims and statements, and to 22

23 have been otherwise procured by fraud and unlawfully obtained, to wit, the defendants obtained a green card for NATASHA HERCULES using a forged marriage certificate and fraudulent financial documents. (Title 18, United States Code, Sections 1546 and 2.) COUNT THIRTEEN The Grand Jury further charges: 27. In or about March 2005, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, and ANNEKA RAMPERSAD, the defendants, unlawfully, willfully and knowingly uttered, used, possessed, obtained, accepted and received immigrant and nonimmigrant visas, permits, alien registration receipt cards, and other documents prescribed by statute and regulation as evidence of authorized stay and employment in the United States, knowing them to have been procured by means of false claims and statements, and to have been otherwise procured by fraud and unlawfully obtained, to wit, the defendants obtained a green card for ANNEKA RAMPERSAD using a forged marriage certificate and fraudulent financial documents. (Title 18, United States Code, Sections 1546 and 2.) FIRST FORFEITURE ALLEGATION 28. As the result of committing the visa fraud conspiracy offense in violation of Title 18, United States Code, Sections 371 and 1546, alleged in Count One of this Indictment, 23

24 BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, SANDFORD BROWNE, a/k/a Tyson, GERRARDA BROWNE, a/k/a Gerry, WILLIANA BROWNE, JOHN LOFTON, a/k/a Big John, PETER ABSOLAM, a/k/a Lloyd, KEITH MAHASE, ABDUL HAKIM MUHAMMAD, TIFFANY WAYMAN, NARRISA JEREMIAH, JAMSHEED JEREMIAH, a/k/a Jason, KHADIGA CLARKE, a/k/a Kelly, LENNARD PRESCOD, a/k/a Bob, MAKEBA ISAROON, RHONDA EATON, RODERICK CHASSEAU, CAMERON A. LLOYD, and KWASI DRAKES, the defendants, shall forfeit to the United States pursuant to Title 18, United States Code, Section 982(a)(6)(A), all property, real or personal, that constitutes, or is derived from or is traceable to the proceeds obtained directly or indirectly from the commission of the offense, and all property, real or personal, that was used to facilitate, or was intended to be used to facilitate, the commission of the offense, including but not limited to the following: a. A sum of money of at least $1 million in United States currency, representing the amount of proceeds obtained as a result of the conspiracy to commit visa fraud, for which the defendants are jointly and severally liable. b. All that lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 951 Nancy Court, Kissimmee, Florida. c. All that lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments 24

25 and easements, located at 373 Aylesbury Court, Kissimmee, Florida. d. All that lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 4414 Canopy Court, Kissimmee, Florida. e. All that lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 4418 Canopy Court, Kissimmee, Florida. f. All that lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 4430 Canopy Court, Kissimmee, Florida. g. All that lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 267 Magellan Drive, Kissimmee, Florida. h. All that lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at Lot E-5, Alpine Lake, Pocono Township, Monroe County, Pennsylvania. SECOND FORFEITURE ALLEGATION 29. As the result of committing the money laundering conspiracy offense in violation of Title 18, United States Code, Section 1956(h), alleged in Count Two of this Indictment, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, ABDUL HAKIM MUHAMMAD, and KWASI DRAKES, the defendants, shall forfeit to the United States 25

26 pursuant to Title 18, United States Code, Section 982(a)(1), all property, real and personal, involved in the money laundering offense and all property traceable to such property, including but not limited to the following: a. A sum of money of at least $1 million in United States currency, representing the amount of property involved in the money laundering conspiracy, or traceable to such property, for which the defendants are jointly and severally liable. b. All that lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 951 Nancy Court, Kissimmee, Florida. c. All that lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 373 Aylesbury Court, Kissimmee, Florida. d. All that lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 4414 Canopy Court, Kissimmee, Florida. e. All that lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 4418 Canopy Court, Kissimmee, Florida. 26

27 f. All that lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 4430 Canopy Court, Kissimmee, Florida. g. All that lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 267 Magellan Drive, Kissimmee, Florida. h. All that lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at Lot E-5, Alpine Lake, Pocono Township, Monroe County, Pennsylvania. THIRD FORFEITURE ALLEGATION 30. As the result of committing the visa fraud offenses in violation of Title 18, United States Code, Sections 1546 and 2, alleged in Counts Three through Thirteen of this Indictment, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, WENDY HARRISON, TASLEEM KUDRATH, TULSI RAMRUP, CHERLYENE RAMDASS, ADRIAN GOURSAHAB, NIGEL DEFOUR, KERRY RAMPERSAD, MERVIN TRANCOSO, NARINE JAIRAM, NATASHA HERCULES, and ANNEKA RAMPERSAD, the defendants, shall forfeit to the United States pursuant to Title 18, United States Code, Section 982(a)(6)(A), all property, real or personal, that constitutes, or is derived from or is traceable to the proceeds obtained directly or indirectly from the commission of the offense, and all property, real or personal, 27

28 that was used to facilitate, or was intended to be used to facilitate, the commission of the offense. Substitute Asset Provision 31. If any of the forfeitable property described in the foregoing Forfeiture Allegations, as a result of any act or omission of the defendants: (1) cannot be located upon the exercise of due diligence; (2) has been transferred or sold to, or deposited with, a third person; (3) has been placed beyond the jurisdiction of the Court; (4) has been substantially diminished in value; or (5) has been commingled with other property which cannot be subdivided without difficulty; it is the intent of the United States, pursuant to 18 U.S.C. 982(b), to seek forfeiture of any other property of said defendants up to the value of the above forfeitable property. (Title 18, United States Code, Sections 371, 982, 1546 and 1956.) FOREPERSON MICHAEL J. GARCIA United States Attorney 28