Case 1:04-cv-02322-GEL Document 222 Filed 11/05/2007
9. On or about April 13, 2006, Richard Altomare purchased an 11.02 ct emerald-cut
diamond from Les Bijoux LLC in Boca Raton, Florida for approximately $500,000. (Item 20 of
the Seized Property listed above in paragraph 7.) Richard Altomare paid Les Bijoux for the
diamond with wire transfers from the bank account of Universal Express, Inc. in the following
amounts: on April 13, 2006 a wire for $325,000, on April 26, 2006 two wires for $30,000 and
$40,000, on June 5, 2006 a wire for $33,900, on July 27, 2006 a wire for $30,000 and on August
21, 2006 a wire for $50,000. Richard Altomare misappropriated these funds from Universal
Express, Inc. to pay for this diamond. In the annual report for Universal Express that Mr.
Altomare signed on March 27, 2007, he did not list any of the payments to Les Bijoux as part of
his annual compensation. See the Summary Compensation Table at page 41 of 49 in the
Company’s annual report on Form 10-K for the year ending June 30, 2006, which is attached as
Exhibit H. The only compensation that Mr. Altomare identified for 2006 in Exhibit H is his cash
salary of $650,000, which was paid to him in bi-weekly payroll checks.
10. On or about January 26, 2007, Richard Altomare purchased from Les Bijoux a
7.00 ct radiant cut fancy yellow SI1 diamond ring set in platinum for $85,000 (Item 21 of the
Seized Property listed above in paragraph 7), a Jaeger LeCoultre Atmos Clock for $40,000,1 and
a FP Journe Chronometre Souverain platinum watch for $20,000 (Item 14 of the Seized Property
listed above in paragraph 7). Richard Altomare made partial payment for these items in three
wire transfers of funds from the bank account of Universal Express in the following amounts:
$20,000 and $40,000 on January 26, 2007, and $20,000 on May 16, 2007. As of approximately
September, 2007, Altomare owed Les Bijoux $65,000 for these three items. Richard Altomare
misappropriated the funds from Universal Express, Inc. to pay for these three items. In the
annual report on Form 10-K for the year ending June 30, 2006, which was filed on March 26,
2007, Altomare represented that he was currently employed under an employment contract that
provides an annual base salary of $650,000. See Exhibit H at page 42 of 49.
