SEC Charges Eleven in Stock Manipulation Ring

[scion]

15. It was a part of the conspiracy that defendant BROWN and P.D., J.M., J.C. and M.R. along with others known and unknown to the grand jury, sought to conceal and disguise both the co-conspirators' participation in the underlying fraud and the nature, source, ownership, and control of the proceeds obtained through that fraud. They did this in various ways, including laundering the proceeds of the sales of GH3 stock through various co-conspirators' personal and business accounts and converting a sizable portion of the securities fraud proceeds into cash.

Overt Acts

16. In furtherance of the conspiracy, MATTHEW W. BROWN, defendant herein, and P.D., J.M., J.C. and MR., along with others committed and caused to be committed the following overt acts, among others, in the District of Delaware and elsewhere:

a. On or about December 14, 15, and 18, 2006, proceeds from the sales of GH3 shares were sent from J.C.'s brokerage account at Bishop, Rosen to J.C.'s Wells Fargo bank account xxxxxx-8336.

b. On or about December 13, 15, and 19, 2006, proceeds from the sales of GH3 shares were sent via wire transfer from J.C.'s brokerage account at Spartan Securities to J.C.'s Wells Fargo Bank account xxxxxx-8336.

c. On or about December 15, 18 and 19, 2006, approximately $253,000 was sent via wire transfer and check from J.C.'s Wells Fargo Bank account xxxxxx-8336 to a Bank of America account xxxxxx-2508 in the name of Westmark Capital Group, Inc. ("Westmark").

d. On or about December 21, 2006, $60,000 in cash was withdrawn by M.R. from Westmark's Bank of America account xxxxxx-2508.

e. On or about January 8, 2007, $80,000 in cash was withdrawn by M.R. from Westmark's Bank of America account xxxxxx-2508.

f. On or about January 19, 2007, $80,000 in cash was withdrawn by M.R. from Westmark's Bank of America account xxxxxx-2508.

g. In or about January 2007, M.R. delivered to J.M. approximately $220,000 in cash proceeds from the sale of GH3 shares, a portion of which proceeds were ultimately intended for defendant BROWN and P.D.

h. In or about January 2007, D.W. was hired by defendant BROWN and P.D. and D.W. was paid $10,000 to drive approximately $146,000 in cash proceeds from the GH3 deal from California to P.D. in Newark, Delaware.

All in violation of Title 18, United States Code, Section 1956(h).
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Matthew W. Brown: 04/16/2009 3 REDACTED VERSION of 2 Indictment by USA as to Defendant Sealed. (rpg) (rpg). (Entered: 04/22/2009)
Doc 3 OCR extract