DD Support Board and Research Team

[Michael-Goode]

Interestingly it is an IRS investigator who did the investigating.

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT
I, Michael K. Klimczak, being duly sworn, depose and say:
1. I am a Special Agent with Internal Revenue Service, Criminal Investigation
(IRS-CI) and have been so employed for approximately 12 1/2 years. I am currently assigned
to the New York Field Office, Buffalo Post of Duty to investigate crimes within the Western
District of New York. As part of my official duties, I investigation allegations of violations
of Federal criminal law, including statues that prohibit fraud and money laundering.

It looks to me like the irregularity of buying a boat with a business checking account is what triggered the investigation -- otherwise why spend so much time talking about?

33. While visiting the Western District of New York, specifically Lakewood,
New York, from their residence in Texas during the summer of 2011, CUSIMANO and
JESSICA CUSIMANO purchased a 2011 Bennington pontoon boat from Snug Harbor
Marina for $48,564.63. In addition to an $8,000 cash deposit made on the day of the sale,
CUSIMANO paid the remaining balance of $40,564.63 utilizing check no. 1074 drawn on
Wells Fargo Bank, N.A. account no. 8174859929 dated 07/02/2011. This account is in the
name of PREMIRE CONSULTING INC. and CUSIMANO. At the time CUSIMANO
wrote the check, his sole source of income was the pump and dump stock fraud scheme
detailed above.
17
Case 1:14-mj-00069-HKS Document 1 Filed 05/19/14 Page 20 of 21
34. In furtherance of the money laundering scheme, the 2011 Bennington
pontoon boat was registered in JESSICA CUSIMANO’s name, using a recently obtained
New York State driver’s license listing her current residence as 169 Front Street, Lakewood,
NY 14750, which was the address of the lakeside cabin they rented while visiting from
Texas.
35. JESSICA CUSIMANO obtained insurance for the 2011 Bennington Pontoon
boat from Progressive Direct Insurance Company on 07/02/2011, policy number 18884772-
0. On the application for the insurance, JESSICA CUSIMANO listed her maiden name,
JESSICA LOPEZ, and listed her current residence as 169 Front Street, Lakewood, NY
14750, and listed her marital status as “single.”