EXCERPT; A. The First Purchase of Ingen Stock and Resulting Kickbacks 18. On May 1, 2009, Ingen and Benefits and Pension Group entered
into a subscription agreement where the pension fund agreed to purchase approximately 13.3 million restricted shares of Ingen common stock for $20,000.
19. Five days later, the FBI wired $20,000 from an FBI-controlled bank account to Ingen’s bank account. Then, on May 7, 2009, Ingen issued approximately 13.3 million restricted shares of Ingen common stock to the pension fund.
20. With the stock purchase concluded, Sand, through Ingen, moved on to paying out the kickbacks to reward the bogus purchase.
On May 6, 2009, Great Lakes sent an invoice for consulting services to Ingen in the amount of $6,333.27 (approximately 30% of the stock purchase price).
The next day Ingen wired the money to Great Lakes. Great Lakes never provided any actual consulting services to Ingen.
On May 11, 2009, Ingen also issued five million shares of Ingen common stock to the cooperating witness.
B. The Second Purchase of Ingen Stock and Resulting Kickbacks 21. After successfully completing the first kickback scheme,
Sand wanted to repeat the manipulation.
Therefore, on May 28, 2009, the same parties entered into a second subscription agreement providing for the pension fund to purchase
approximately 6.7 million restricted shares of Ingen common stock for $20,000. On the same day,
Ingen issued approximately 6.7 million restricted shares of Ingen common stock to the pension fund.
On June 3, 2009, the FBI wired $20,000 from an FBI-controlled account to Ingen’s bank account.