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scion

11/22/10 2:11 PM

#11844 RE: scion #11843

11/22/2010 16 INDICTMENT as to Isreal Owen Hawkins, Jr (1) count(s) 1, 2, 3, 4, 5-6, Teresa Brown (2) count(s) 1, 2, 7-12, Johnny Heurung (3) count(s) 1, 13-14, Clarence D Moore (4) count(s) 1. (Attachments: # 1 Criminal Cover Sheet Dft 1, # 2 Criminal Cover Sheet Dft 2, # 3 Criminal Cover Sheet Dft 3, # 4 Criminal Cover Sheet Dft 4) (Beard, Melanie) (Entered: 11/22/2010)

Doc 16 PDF file
http://viewer.zoho.com/docs/qEbjW0

Document Number: 16 40 pages 179 kb

Attachment Description
1 Criminal Cover Sheet Dft 1 1 page 47 kb
2 Criminal Cover Sheet Dft 2 1 page 46 kb
3 Criminal Cover Sheet Dft 3 1 page 46 kb
4 Criminal Cover Sheet Dft 4 1 page 46 kb


COUNT ONE: CONSPIRACY
All Defendants
18 U.S.C. § 371
NMT: 5 Years Imprisonment
NMT: $250,000 Fine
NMT: 3 Years Supervised Release
Class D Felony

COUNT TWO: SECURITIES FRAUD
Defendants Brown and Hawkins
15 U.S.C. § 77q and 18 U.S.C. § 2
NMT: 5 Years Imprisonment
NMT: $250,000 Fine
NMT: 3 Years Supervised Release
Class D Felony

COUNT THREE: AGGRAVATED CURRENCY
STRUCTURING
Defendant Hawkins
31 U.S.C. §§ 5324(a) & (d)(2); & 18 U.S.C. § 2
NMT 10 Years Imprisonment
NMT $500,000 Fine
NMT 3 Years Supervised Release
Class C Felony

COUNT FOUR: MONEY LAUNDERING
Defendant Hawkins
18 U.S.C. §§ 1957 and 2
NMT 10 Years Imprisonment
NMT $250,000 Fine
NMT 3 years Supervised Release
Class C Felony

COUNTS FIVE THROUGH FOURTEEN:
WIRE FRAUD
Defendant Brown: 18 U.S.C. §§ 1343 and 2
Defendants Hawkins and Heurung: 18 U.S.C. § 1343
NMT: 20 Years Imprisonment
NMT: $250,000 Fine
NMT: 3 Years Supervised Release
Class C Felony

$100 Mandatory Special Assessment per Count
Forfeiture Allegation
28 U.S.C. § 2461(c) and 21 U.S.C. § 853
Order of Restitution

scion

11/22/10 2:42 PM

#11845 RE: scion #11843

11/16/2010 14 LETTER from Isreal Owen Hawkins -requesting for new counsel and to modify bond (Attachments: # 1 resigned as CEO) (Gicinto, JoRita) [4:10-mj-00171-SWH] (Entered: 11/16/2010)

Doc 14 PDF file
http://viewer.zoho.com/docs/kXick

Doc 14-1 PDF file
http://viewer.zoho.com/docs/hXlri

scion

11/25/10 12:11 PM

#11850 RE: scion #11843

Pacer update 24 Nov 10 USA v Hawkins CRIMINAL COMPLAINT Case Number: 4:10-cr-00332-ODS All Defendants

Date Filed # Docket Text

11/24/2010 23 NOTICE OF HEARING as to Teresa Brown. This is the official notice for this hearing. Initial Appearance and Arraignment set for 12/8/2010 01:30 PM in Courtroom 6E, Kansas City (SWH) before Magistrate Judge Sarah W. Hays. Signed on 11/24/2010 by Magistrate Judge Sarah W. Hays.This is a TEXT ONLY ENTRY. No document is attached.(Gicinto, JoRita) (Entered: 11/24/2010)

11/24/2010 22 AMENDED NOTICE OF HEARING as to Isreal Owen Hawkins, Jr. This is the official notice for this hearing. Show Cause Hearing reset for 12/6/2010 02:30 PM in Courtroom 6E, Kansas City (SWH) before Magistrate Judge Sarah W. Hays. Per the request of defense counsel. Signed on 11/24/2010 by Magistrate Judge Sarah W. Hays.This is a TEXT ONLY ENTRY. No document is attached.(Gicinto, JoRita) (Entered: 11/24/2010)

11/23/2010 21 DISCOVERY ORDER as to Isreal Owen Hawkins, Jr, Teresa Brown, Johnny Heurung, Clarence D Moore. Signed on 11/23/2010 by Magistrate Judge Sarah W. Hays.(Gicinto, JoRita) (Entered: 11/23/2010)

11/22/2010 20 ORDER SETTING SCHEDULING CONFERENCE as to Isreal Owen Hawkins, Jr. Scheduling Conference set for 12/16/2010 11:30 AM in Courtroom 6E, Kansas City (SWH) before Magistrate Judge Sarah W. Hays., Show Cause Hearing set for 11/29/2010 02:30 PM in Courtroom 6E, Kansas City (SWH) before Magistrate Judge Sarah W. Hays. Signed on 11/22/10 by Magistrate Judge Sarah W. Hays.(Carr, Lori) (Entered: 11/22/2010)

11/22/2010 19 Minute Entry for proceedings held before Magistrate Judge Sarah W. Hays: INITIAL APPEARANCE, ARRAIGNMENT, and BOND HEARING as to Isreal Owen Hawkins Jr (1) Count 1,2,3,4,5-6 held on 11/22/2010. Defendant charged in Count(s) 1-6 of a 14 Count indictment. Defendant waived reading of the indictment. Defendant was informed of the maximum punishment for each applicable count of theindictment. Defendant entered a plea of not guilty to each count of the indictment applicable to him/her. On 10/27/10, the court entered an order appointing the federal public defenders office. The defendant was to provide a complete list of income and assets to Pretrial Services and also to defense counsel. Mr. Moss was to complete and file, under seal, a financial affidavit incorporating defendants income and assets. To date, such filing as not beenmade. Mr. Moss indicated he will do so within the week. The court takes up the defendants request for new counsel, ex parte, and out of the presence of the government and the public. The court denies defendants request. Mr. Moss will remain as court-appointed counsel. Court summarizes the Pretrial Services violation report dated 11/19/10. Government presents argument and orally moves for pretrial detention. Defense counsel requests a continuance of this hearing as he has not had adequate time to prepare. The Government then provides defendant with a copy of the audiotape of the telephone call referenced inthe violation report. The Court grants defendants oral motion and continues the hearing until Monday, November 29, 2010 at 2:30 p.m in Courtroom 6E before Magistrate Judge Hays. Based on the information before the Court, the Court revokes defendants bond and remands defendant to the custody of the U.S. Marshal pending outcome of the show cause hearing. Case ordered set for trial on the joint criminal jury trial docket which commences January 10, 2011.Scheduling Conference set for 12/16/2010 11:30 AM in Courtroom 6E, Kansas City (SWH) before Magistrate Judge Sarah W. Hays., Show Cause Hearing set for 11/29/2010 02:30 PM in Courtroom 6E, Kansas City (SWH) before Magistrate Judge Sarah W. Hays. To order a transcript of this hearing please contact Lori Carr, 816-512-5064. (Carr, Lori) (Entered: 11/22/2010)

11/22/2010 18 ORDER REFERRING CASE to Magistrate Judge Hays as to Isreal Owen Hawkins, Jr, Teresa Brown, Johnny Heurung, Clarence D Moore. Signed on 11/22/10 by District Judge Ortrie D. Smith.(Beard, Melanie) (Entered: 11/22/2010)



U.S. District Court
Western District of Missouri (Kansas City)
CRIMINAL DOCKET FOR CASE #: 4:10-cr-00332-ODS All Defendants

Case title: USA v. Hawkins et al

Magistrate judge case number: 4:10-mj-00171-SWH

Date Filed: 11/22/2010

Assigned to: District Judge Ortrie D. Smith
Referred to: Magistrate Judge Sarah W. Hays

4:10-cr-00332-ODS USA v. Hawkins et al
4:10-cr-00332-ODS-1 Isreal Owen Hawkins, Jr
4:10-cr-00332-ODS-2 Teresa Brown
4:10-cr-00332-ODS-3 Johnny Heurung
4:10-cr-00332-ODS-4 Clarence D Moore

Defendant (1)
Isreal Owen Hawkins, Jr

represented by FPD
Federal Public Defender
818 Grand Boulevard
Suite 300
Kansas City, MO 64106
(816) 471-8282
Email: ray_conrad@fd.org
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: Public Defender or Community Defender Appointment

Stephen C Moss
Federal Public Defender's Office
818 Grand Ave
Ste 300
Kansas City, MO 64106
816-471-8282
Fax: 816-471-8008
Email: steve_moss@fd.org
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: Public Defender or Community Defender Appointment

Pending Counts
CONSPIRACY
(1)
SECURITIES FRAUD
(2)
AGGRAVATED CURRENCY STRUCTURING
(3)
MONEY LAUNDERING
(4)
WIRE FRAUD
(5-6)

Highest Offense Level (Opening)
Felony

Complaints

Defendant willfully and knowingly used the means and instruments of transportation and communication in interstate commerce and of the mails to sell, offer to sell, and to aid and abet the sale of a security, as defined in Title 15 of the USC, as to which no registration statement was in effect or filed, and further knew that no registration statement was in effect for the offers and sales of the security at the time of the offers for sale and sales; in violation of Title 15, USC, Sections 77e(a), 77e(c), 77x and Title 18, USC, Section 2; and for the purpose of evading the reporting requirements of Title 31 USC, Sections 5313 (a) and 5325 and any regulation prescribed under any such section, the reporting or recordkeeping requirements imposed by any order issued under Title 31, USC, Section 5326, and the recordkeeping requirements imposed by any regulation prescribed under section 21 of the Federal Deposit Insurance Act or section 123 of Public Law 91508, as part of a pattern of illegal activity involving more than $100,000 in a 12-month period, knowingly and willfully structured and assisted in structuring, and attempted to structure and assist in structuring, and caused and aided and abetted the structuring, of transactions with one or more domestic financial institutions in Kansas City, Western District of Missouri, with all monies originating from a $180,000 March 16, 2010 wire transfer from J.P. Morgan Chase account in violation of Title 31, USC, Sections 5324(a)(3) and (d)(2), and Title 18, USC, Section 2.

Defendant (2)
Teresa Brown

Pending Counts

CONSPIRACY
(1)
SECURITIES FRAUD
(2)
WIRE FRAUD
(7-12)

Highest Offense Level (Opening)
Felony

Defendant (3)
Johnny Heurung

Pending Counts

CONSPIRACY
(1)
WIRE FRAUD
(13-14)

Highest Offense Level (Opening)
Felony

Defendant (4)
Clarence D Moore

Pending Counts

CONSPIRACY
(1)

Highest Offense Level (Opening)
Felony


https://ecf.mowd.uscourts.gov/cgi-bin/iquery.pl