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Replies to post #69984 on DD Support Board and Research Team
Michael-Goode
06/12/14 3:20 PM
#69986 RE: Michael-Goode #69984
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.
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.”