#88 Consumer Comment
AUTHOR: JohnBoschertJeniferHoffmanScam - (USA)
SUBMITTED: Wednesday, October 13, 2010
POSTED: Wednesday, October 13, 2010
Case 5:10-cv-00468-WTH-GRJ Document 1 Filed 09/14/10 Page 1 of 17
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
OCALA DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
FILED
zalo SEP r4 AM fO: 411
v.
REAL PROPERTY, INCLUDING
ANY BUILDINGS, APPURTENANCES,
AND IMPROVEMENTS THEREON,
LOCATED AT 17532 COBBLESTONE
LANE, CLERMONT, FLORIDA,
REAL PROPERTY, INCLUDING
ANY BUILDINGS, APPURTENANCES,
AND IMPROVEMENTS THEREON,
LOCATED AT 13045 HIDDEN BEACH WAY,
CLERMONT, FLORIDA,
Defendants.
Case No. 5:10·cv~ 4lt'f ·0(.- /o~
VERIFIED COMPLAINT FOR FORFEITURE IN REM
Plaintiff United States of America, by and through the undersigned Assistant
United States Attorney, brings this complaint and alleges upon information and belief, in
accordance with Supplemental Rule G(2), Supplemental Rules for Admiralty or
Maritime Claims and Asset Forfeiture Actions, as follows:
NATURE OF THE ACTION
1. This is a civil action in rem to forfeit to the United States, the following real
properties located at 17532 Cobblestone Lane, Clermont, Florida, 34711 and 13045
Hidden Beach Way, Clermont, Florida, 34711 (Defendant Properties), pursuant to 18
U.S.C. § 981 (a)(1)(C), as proceeds traceable to a conspiracy to commit a "specified
unlawful activity," as that term is defined in 18 U.S.C. § 1956(c)(7), specifically wire
Case 5:10-cv-00468-WTH-GRJ Document 1 Filed 09/14/10 Page 2 of 17
fraud offenses. This action is also brought, pursuantto 18 U.S.C. § 981 (a)(1)(A),
against the Defendant Properties because the monetary transactions conducted to
purchase these properties were made in violation of 18 U.S.C. § 1957(a). The offenses
which give rise to this action arise from an investment fraud scheme perpetrated by
Assured Capital Consultants, Jenifer Hoffman, John Boschert, Bryan Zuzga and ottiers
in which investors have been defrauded out of millions of dollars.
JURISDICTION AND VENUE
2. This Court has subject matter jurisdiction over an action commenced by
the United States by virtue of 28 U.S.C. § 1345, and over an action for forfeiture by
virtue of 28 U.S.C. § 1355.
3. This Court has in rem jurisdiction over the Defendant Properties pursuant
to:
a. 28 U.S.C. § 1355(b)(1)(A), because pertinent acts or omissions
giving rise to the forfeiture occurred in the Middle District of Florida; and
b. 28 U.S.C. § 1355(b)(1)(B), because venue properly lies in the
Middle District of Florida pursuant to 28 U.S.C. § 1395.
4. Venue is proper in the District Court for the Middle District of Florida,
pursuant to 28 U.S.C. § 1355(b)(1), because the acts or omissions giving rise to the
forfeiture occurred in this district.
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THE DEFENDANT IN REM
5. The Defendant Properties are described as:
a. 17532 Cobblestone Lane, Clermont, Florida 34711, more
particularly described as:
Lot 30, MAGNOLIA POINTE, according to the plat thereof, as
recorded in Plat Book 40, Pages 1 through 6, inclusive, of the
Public Records of Lake County, Florida; and
b. 13045 Hidden Beach Way, Clermont, Florida 34711, more
partiCUlarly described as:
Lot 72, MAGNOLIA POINTE, according to the plat thereof
recorded in Plat Book 40, Page(s) 1-6, of the Public Records
of Lake County, Florida
and are located in Lake County, Florida. The United States does not request
authority from the Court to seize the real property defendant at this time.
6. As set forth in Supplemental Rule G(3)(a) and 18 U.S.C. § 985(b)(1) and
(c)(1), the United States will:
a. post notice of this action and a copy of the Complaint on the
defendant real properties;
b. serve notice of this action on the defendant real properties
owner(s), and any other person or entity who may claim an interest
in the defendant, along with a copy of this Complaint;
c. file a lis pendens in county records of the defendant real
properties' status as a defendant in this in rem action.
7. The Defendant Properties are subject to forfeiture pursuant to 18 U.S.C. §
981(a)(1)(C), because they constitute proceeds traceable to a conspiracy to commit
"specified unlawful activity," as that term is defined in 18 U.S.C. § 1956(c)(7). A
"specified unlawful activity," as defined in 18 U.S.C. § 1956(c)(7), includes offenses
3
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listed in 18 U.S.C. § 1961(1). Specifically, 18 U.S.C. § 1961(1) includes wire fraud
violations. Lastly, the monetary transactions made to purchase the Defendant
Properties were conducted in violation of 18 U.S.C. § 1957(a) because they involved
monetary transactions conducted with more than $10,000 in criminally derived funds
and, as such, are subject to forfeiture pursuant to 18 U.S.C. § 981(a)(1)(A).
FACTS
8. Specific details of the facts and circumstances supporting the forfeiture
of the defendant real properties are contained in the Affidavit of United States Secret
Service Special Agent Shelley Kolarczyk, which is attached hereto as Exhibit A and fully
incorporated herein by reference.
9. As required by Supp'l Rule G(2)(f), this complaint supports a reasonable
belief that the government will be able to meet its burden of proof at trial. Specifically,
there is probable cause to believe that the Defendant Properties were purchased with
proceeds of the wire fraud offenses detailed in SA Kolarczyk's Affidavit, and therefore,
are subject to forfeiture pursuant to 18 U.S.C. § 981 (a)(1)(C). Additionally, there is
probable cause to believe that the Defendant Properties were involved in violations of
18 U.S.C. § 1957(a), and therefore, are subject to forfeiture pursuant to 18 U.S.C. §
981 (a)(1 )(A).
WHEREFORE, the United States requests that process, in accordance with the
provisions of Supplemental Rule G, be issued against the Defendant Properties to
enforce the forfeiture and that any person or persons having an interest therein be cited
and directed to appear and show cause why it should not be decreed; and that the
4
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Defendant Properties be forfeited to the United States for disposition according to law;
and that the United States have such other and further relief as this case may require.
Respectfully submitted,
A. BRIAN ALBRITION
United States Attorney
By:
icole M. Andrejko
Assistant United States Attorney
Florida Bar No. 0820601
501 West Church St., Suite 300
Orlando, FL 32805
Telephone: (407) 648-7500
Facsimile: (407) 648-7643
E-mail: Nicole.Andrejko@usdoLgov
5
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VERIFICATION
I, Shelley Kolarczyk, hereby verify and declare under penalty of perjury as
provided by 28 U.S.C. § 1746 that I am a Special Agent with the United States Secret
Service, that I have read the foregoing Verified Complaint in rem and know the contents
thereof, and that the matters contained in the Verified Complaint are true and correct to
my own knowledge, except those matters herein stated to be alleged on information
and belief and, as to those matters, I believe them to be true and correct.
The sources of my knowledge and information, and the grounds of my belief are
the official files and records of the United States, information supplied to me by other
law enforcement officers, as well as my investigation of this case and other cases.
Executed this --"L- day of September, 2010.
¥=:~~=v~',Q~,,:::..:...~..... '=---=--
Shelley Kolar k, Special Agent
United States Secret Service
6
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AFFIDAVIT
I, Shelley Kolarczyk, being duly sworn, depose and state as follows:
1. I am a Special Agent (SA) of the United States Secret Service (USSS)
and have been so employed for 8 years. I am currently assigned to the Orlando Field
Office. Among my duties as a SA, I am charged with the investigation of financial
crimes, including check fraud, identity fraud, credit card fraud, bank and wire fraud, and
the manufacturing, possession and passing of counterfeit United States currency.
I have been involved in several investigations involving Ponzi/Pyramid schemes1 that
resulted in the issuance of seizure warrants. As a SA, I have conducted numerous wire
fraud, money laundering and other financial crimes investigations. I have become
intimately familiar with the manner in which criminals communicate by wire (telephone,
internet, fax machine, etc.) in attempts to code their language to disguise the true
meaning of their conversations. Additionally, I have extensive experience in
investigating individuals who attempt to conceal proceeds of illegal acts, such as wire
fraud, including the use of trusts and corporations to disguise the true owner of illicit
funds they control through these entities. I have become knowledgeable about the
methods and means by which money is laundered and the efforts of persons involved in
1 Ponzi schemes promote allegedly lucrative business opportunities, often involving
foreign currency exchange, precious metals trading, or other high return investments.
However, in a Ponzi scheme, there is in fact no underlying profitable business to
support the payments promoters say they will make to the investors. Instead, the
promoters simply use the money obtained from a growing base of latter investors to pay
so-called "profits" to earlier investors. Schemes that depend on growing the base of
new investors to support payments to prior investors are also referred to as pyramids.
Ponzi schemes have evolved with the development of the Internet, but their basic
premise remains the same: later investors' funds are used to pay the earlier investors.
1
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such activities to avoid detection by law enforcement. As a USSS agent, I have utilized
a variety of investigative techniques and resources, including physical and electronic
surveillance, undercover operations. and cooperating sources of information, including
cooperating defendants.
2. This investigation is being conducted jointly by the USSS, the FBI, the IRS
and the State of Florida, Office of Financial Regulation. Information obtained as a result
of the investigative efforts of each agency is being shared with agents from the other
agencies and incorporated into this affidavit. The facts set forth in this affidavit are
based on my own personal knowledge, knowledge obtained from law enforcement
officers. reviews of documents and computer records related to this investigation.
communications with others who have personal knowledge of the events and
circumstances described herein (including participants.) and information gained through
my training and experience and the training and experience of others. Because this
affidavit is being submitted for the limited purpose of establishing probable cause in
support of the civil forfeiture complaint described herein, it does not set forth each and
every fact that I or others have learned during the course of the investigation.
I. Property to be Seized
3. This affidavit is being submitted for the limited purpose of supporting the
civil forfeiture complaint against real properties located at:
a. 17532 Cobblestone Lane, Clermont, Florida, 34711, titled in the name
of Donald and Jenifer Hoffman; and
b. 13045 Hidden Beach Way, Clermont, Florida, 34711, titled in the
name of Bryan and Mersades Zuga.
2
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II. Relevant Individuals/Entity
4. The following individuals/entity are believed to be involved in this scheme:
a. John Boschert (Boschert)
b. Jenifer Hoffman (Hoffman)
c. Bryan Zuzga (Zuzga)
d. Assured Capital Consultants (ACC) - According to the Florida
Department of State, Division of Corporations, ACC was established in
September 2008. Boschert is listed as the Manager and Hoffman was listed as
the Managing Member. State filings indicate that ACC is engaged in "any and all
lawful business." ACC's principal address is listed as 13148 Summerlake Way,
Clermont, Florida.
III. Overview of Scheme
5. Since January 2009, the above-referenced individuals have been
deceiving investors by making claims to them, both via business meetings and phone
conversations, that investments in ACC would yield exceptionally high returns on
investments not achievable anywhere in the legitimate business world. Specifically,
ACC's Joint Venture Revenue Share Agreements (Agreements) indicate that although
ACC does not guarantee minimum monthly returns to investors, investors could earn
monthly returns between 100%-200% on their investments, with any earnings over
100% per month paid directly to ACC.
6. The terms of ACC's agreements indicate that investor funds would be
placed into what ACC described as a "private placement trade platform," which was
being managed by a confidential Trade Platform. Indeed, Boschert and Hoffman told
3
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investors that the specific details of ACC's investments were private or confidential and
could not be shared with them.2 As is typical of most pyramid schemes, investors were
advised verbally that the higher initial investment they made with ACC, the higher
returns they would receive and the quicker they would receive their payouts. Investors
were also advised verbally that their funds would not leave the designated escrow
account. Per the terms of the agreements, at any time upon their request, investors' full
principal investment would be returned to them within 10 business days. ACC offered
investment opportunities ranging between $50,000 to $500,000 with the option for
smaller investors to pool their funds and inv~st as a group, as many individuals did.
7. As part of the investment scheme, Hoffman verbally advised investors that
Bryan Zuzga (Zuzga) was managing investors' payments by serving as the escrow
agent for funds disbursed from Assured Capital Consultant's SunTrust Bank Account
#1000085984168 (ACC"s SunTrust Account). Several investors also reported
conversations with Hoffman and ZUZGA wherein Hoffmana and Zuzga held Zuzga out
to be ACC's lawyer. Initial investigation into Zuzga's background indicates that he does
not hold a license to practice law in either Florida or Ohio, as he represented to several
investors. Zuzga also falsely repre~ented to investors via an Escrow Agreement, he
was the sole signatory on ACC's SunTrust Account.
8. An examination into ACC's SunTrust Account, the account utilized by ACC
to accept investor funds, does not indicate that any legitimate investments were actually
2 On at least one occasion, Boschert advised an investor that he could not disclose how
ACG was investing investor funds because the company ACC was investing with did not
want this information disclosed.
4
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being made on behalf of ACC's investors. Bank analysis reveals that since January
2009, ACC collected over $28 million from various investors, both domestic and
international. Instead of investing funds on behalf of investors, bank records indicate
that Boschert and Hoffman were misappropriating investors' funds for their own
personal benefit. Specifically, these individuals used investors' funds to purchase
vehicles, vessels, buy homes, compensate themselves and send money to accounts
directly under their control. This investigation has revealed that neither Boschert nor
Hoffman have any substantial income other than ACC related money.
IV. ACe is Unlicensed to Operate Its Business
9. I contacted the National Futures Association (NFA) and the Commodities
Futures Trading Commission (CFTC) in order to determine whether ACC holds any type
of investment licenses. A check with both the NFA and CFTC resulted in negative
results for any license or registration for ACC, Boschert or Hoffman. According to the
CFTC, ACC is considered a "pool operator" because it collectively accumulates investor
money for investments. Serving as a pool operator for the purpose of purchasing
commodities without a license or registration is in violation of federal law. Registration
with the CFTC requires companies to produce disclosure documents, yearly
prospectuses and incorporation documents. These are necessary to protect investors
from fraudulent practices by unregulated pool operators.
V. Investor Interview
10. On September 16,2009, I received a call from St. Petersburg, Florida
resident Brian Haas (Haas) who was concerned that he may have been victimized by
an investment scheme operated by ACC. In June 2009, Hass, on behalf of his wholly
5
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owned company, Marketworx Corp., began investing with ACC. Haas learned about
ACC through an acquaintance and was interested in investing his money where he
could receive a high yield on investments. ACC purported in writing to Haas, and other
individuals, that investments were made in private placement platforms. As was the
case with other investors, ACC advised Haas that it was unable to disclose the specific
nature of the investments it would make on his behalf.
11. On June 11, 2009, Marketworx Corp. entered into a contract with ACC.
The terms of the contract indicate that interest, in the amount of 5-25% per week, was
to be paid every ten days once investing began. Moreover, Marketworx had to agree to
pay ACC any earnings earned in excess of 100% per month. If, however, Marketworx
wanted to withdraw its principal, it could do so at any time after it provided ACC with 10
business days notice.
12. Pursuant to the terms of the contract, on June 12,2009, Haas wired
$100,000 to ACC's SunTrust Account for the sole purpose of investing with ACC.
13. Thereafter, on or about July 14, 2009, Hass was verbally informed by
Hoffman that his investment had earned $196,000. With this information, Haas
requested a $50,000 payout from his earnings, which he received on July 22,2009 in
the form of a wire from ACC's SunTrust Account.
14. On July 31,2009, feeling confident in his investment decision, Haas
provided ACC with additional funds for investment. Haas provided SunTrust Official
Check No. 4677029837 made payable to ACC in the amount of $254,000 to add to his
original investment. Bank records reveal this check was deposited into ACC's SunTrust
Account.
6
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15. In the days following his additional investment, Boschert and Hoffman
communicated regularly with Haas regarding his investment. In early August 2009,
Haas began to have problems reaching Boschert and Hoffman and became concerned
about his investment. Accordingly, on August 3,2009, Haas requested the return of his
earnings and entire principal investment. Hoffman initially agreed to return theses funds
to Haas, but then continued to delay and make broken promises to Haas regarding the
return of his funds. On September 26,2009, after several weeks of attempting to obtain
his funds from Hoffman, Haas called the Orlando Secret Service to file a complaint.
16. Additional victims have been identified and have provided similar accounts
of their dealings with ACC to the Orlando Secret Service.
VI. Tracing of Funds Used to Purchase the Defendant Real Properties
17. According to bank records, on September 8,2008, Jenifer Hoffman and
John Boschert opened SunTrust Business Checking Account #1000085984168 held in
the name of Assured Capital Consultants, LLC, at the Clermont branch located at 581
E. Highway 50, Clermont, Florida, 34711. Bank records list Hoffman and Boschert as
the only signatories on the account in their capacity as Managers of ACC's Escrow
Account. As discussed above, ACC directed investors to send their investment funds to
this account.
18. Between January and September 2009, over $28 million was wired or
directly deposited into this account. Based on a review of incoming wires, and
numerous victim interviews conducted by investigators, with the exception of a small
7
Case 5:10-cv-00468-WTH-GRJ Document 1 Filed 09/14/10 Page 14 of 17
portion of funds,3 it is apparent this account was funded almost entirely with funds
received directly from ACC investors. Bank analysis indicates that of the funds
deposited into this account, $19,761,376.25 was returned to investors, $1,906,525 was
wired to ACC's Secondary Account, $1,093,890 was wired to DAH Management,4
$832,250 was wired to or withdrawn by Boschert and/or Hoffman, $382,000 was wired
to Zuzga, $350,000 was wired to Paul Forkner,5 and $150,000 was wired to Banco
General in Panama and there were $446,300 in counter and cash withdrawals.
19. While it appears that the funds in this account were being used to pay
back investor returns (as it typical in most Ponzi/Pyramid schemes), compensate
Boschert, Hoffman and their family members, sent to overseas accounts and used to
purchase assets for the Hoffmans, there is little to no account activity that demonstrates
that the funds were actually being invested as advertised to investors. Indeed, none of
the account's outgoing wires can be directly traced to any legitimate investment.
20. Additionally, investor funds deposited into ACC's SunTrust Account were
used to purchase the Defendant Properties.
3 A portion of funds, $1,412,690, came from ACC SunTrust Account #1000085983079
(ACC's Secondary Account) and two cash deposits totaling $11,500. With the
exception of a few transactions, the vast majority of the funds deposited into ACC's
Secondary Account came from ACC's SunTrust Account. Both of ACC's SunTrust
accounts were closed on or about September 21,2009 for "non-compliance" with
SunTrust Bank's rules and regulations and after the bank received several customer
complaints.
4 DAH Management is an active Florida corporation listing Jenifer Hoffman as the sole
Officer/Director.
5 Paul Forkner is Jenifer Hoffman's father.
S
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A. Purchase of The Hoffmans' Property
21. Records obtained from the Lake County Property Appraiser's Office reveal
that on July 3,2009, Donald and Jenifer Hoffman purchased their residence located at
17532 Cobblestone Lane, Clermont, Florida, 34711 for $1 ,575,000 (Hoffmans'
residence). Attorney Wade Boyette served as the title agent for the closing. The
following is a summary of the funding of the Hoffmans' residence:
a. On June 19,2009, the ACC SunTrust Account received an
incoming wire of $1,850,000 from United Funding.6 The same day
$230,000 was wired from the ACC SunTrust Account to the
BankFirst account of the Boyette Law Offices in Clermont, Florida.
b. On June 29, 2009, the ACC SunTrust Account received an
incoming wire of $500,000 from Harbour Distribution? The same
day $500,000 was wired from the ACC SunTrust Account to the
BankFirst account of the Boyette Law Offices in Clermont, Florida.
c. On June 30, 2009, the ACC SunTrust Account received an
incoming wire of $300,000 from Aishwariya Enterprises.8 The
same day $303,963.96 was wired from the ACC SunTrust Account
to the BankFirst account of the Boyette Law Offices in Clermont,
Florida.
d. On July 2, 2009, the ACC SunTrust Account received an incoming
wire of $400,000 from United Funding. The same day $300,000
was wired from the ACC SunTrust Account to the BankFirst
account of the Boyette Law Offices in Clermont, Florida.
22. Because the Hoffmans' residence was purchased with at least $1,330,000
in wire fraud proceeds, the Hoffmans' residence, up to $1,330,000, is subject to
6 United Funding has been identified as a victim in this case and is currently awaiting
the return of investor funds.
7 Harbour Distribution has been identified as a victim in this case and is currently
awaiting the return of investor funds.
8 Aishwariya Enterprises has been identified as a victim in this case and is currently
awaiting the return of investor funds.
9
Case 5:10-cv-00468-WTH-GRJ Document 1 Filed 09/14/10 Page 16 of 17
forfeiture as proceeds of the wire fraud violations, pursuant to 18 U.S.C. § 981(a)(1)(C).
Additionally, the four wire transfers also violated 18 U.S.C. § 1957(a) because they
involved monetary transactions conducted with more than $10,000 in criminally derived
funds and, as such, the entire property is subject to forfeiture pursuant to 18 U.S.C. §
981(a)(1)(A).
B. Purchase of the Zuzgas' Residence
23. Additionally, investor funds deposited into ACC's SunTrust Account were
used to purchase Zuzga and his spouse, Mersades Zuzga's, residence located at
13045 Hidden Beach Way, Clermont, Florida, 34711 (Zuzgas' residence). Records
obtained from the Lake County Property Appraiser's Office reveal that on July 9,2009,
the Zuzgas' purchased their residence for $385,000. Watson Title Services, Inc. served
as the title agent for the closing.
24. On July 7,2009, Zuzga opened SunTrust Personal Checking Account
#1000096511042 (Zuzga's SunTrust Account) at the Clermont branch at 581 E.
Highway 50, Clermont, Florida, 34711 with a $100 cash deposit. Zuzga has sole
signature authority on this account.
25. On July 17,2009, ACC's SunTrustAccount received a $1,000,000 wire
from International Finance and Trust, LLC.9 On the same day, $382,000 was wired
from ACC's SunTrust Account to Zuzga's SunTrust Account. The same day,
$381,975.65 was withdrawn from Zuzga's SunTrust Account in the form of two official
checks made payable to Watson Title Services, Inc: 1) SunTrust Official Check
9 International Finance and Trust, LLC has been identified as a victim investor in this
case and is currently awaiting the return of investor funds.
10
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#2136867534, dated July 17, 2009, in the amount of $190,987.83; and 2) SunTrust
Official Check #2136867543, dated July 17, 2009, in the amount of $190,987.82.
26. Records obtained from Watson Title Services, Inc. reveal these official
checks were received on July 22,2009 as payment for the balance due for the closing
of the Zugas' residence.
27. Because the Zuzgas' residence was purchased with at'least $381,975.65
in wire fraud proceeds, the Zuzgas' residence, up to $381,975.65 is subject to forfeiture
as proceeds of the wire fraud violations, pursuant to 18 U.S.C. § 981 (a)(1 )(C).
Additionally, the purchase of the Zuzgas' residence with the two cashier's checks also
violated 18 U.S.C. § 1957(a) because it involved two monetary transactions each
conducted with more than $10,000 in criminally derived funds and, as such. the entire
property is subjectto forfeiture pursuant to 18 U.S.C. § 981 (a)(1 )(A).
~ ~vVj </7e--------
Special Age Shelley Kolarczyk
United States Secret Service
State of Florida
County of Orange
Before me. the undersigned authority personally appeared, Special Agent
Shelley Kolarczyk, who having produced her United States Secret Service credentials
as identification and having being duly sworn, deposes and says that the foregoing
Affidavit is true to the best of her knowledge, information and iCi~ Witness my hand
and official seal in the State of Florida. County of Orange this {] tlay of September,
2010.
Public
ission Expires:
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g:(A\: Commission # 00590194
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11
