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Case 9:13-cr-80143-KLR Document 29 Entered on FLSD Docket 07/09/2013 Page 1 of 12

U N ITE D STA TES D ISTR ICT C O U R T
SO U TH E RN D IST R IC T O F FLO R ID A

13-80143-C R -RY S K A M P/H O P K IN S

C ase No.

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18 U.S.C. j 371
18 U.S.C. j 641
18 U.S.C. j 1028A(a)(1)
18 U.S.C. j 510(a)(1)
18 U.S.C. j 287
18 U.S.C. j 981

UN ITED STA TES O F A M ERIC A

VS.

G ET O D O RLIZIER and
JO U R M EL TH O M A S,

Defendants.

/

IN D IC TM ENT

'l'he Grand Jury charges that:

G EN EM L AL LEG A T IO N

At all tim es relevant to this indictm ent, a third party tax refund check w as a check

written by a financial institution to a taxpayer at or near the tim e the taxpayer filed his or her tax

return. n e check was written for the am ount of the taxpayer's tax refund, reduced by a

processing fee and, in som e cases, the return preparer's prepr ation fee, w hich was redirected by

the issuing financial institution diredly to the preparer. The financial institution in turn rectived

the am ount of the tax refund from the United States Treasury. U pon authorization from the

issuing fnancial institution, return preparers had the ability to issue third party tax reftm d checks

directly to their clients.

Case 9:13-cr-80143-KLR Document 29 Entered on FLSD Docket 07/09/2013 Page 2 of 12

Conspiracy to Steal, R eceive, and R etain M oney and Things of Value of the U nited States

and to Forge Endorsem ents on and C ash Treasury C hecks

CO UN T 1

18 U.S.C. j 371

The G eneral A llegation section of this indictm ent is realleged and incorporated by

reference as if fully set forth herein.

2.

Beginning at least as early as April 24, 2013, the exact date being llnknow n to the

Grand Jury, and continuing through on or about June 5, 2013, in Palm Beach County, in the

Southern D istrict of Florida, and elsew here, the defendants,

G ETO D O R LIZIE R and
JO U R M EL TH O M A S,

did know ingly and w illfully com bine, conspire, confederate, and agree w ith each other and

persons know n and unknow n to the G rand Jury to com m it offenses against the U nited States, that

a.

to steal, purloin, and know ingly convert to their own use and the use of others

m oney and things of value of the United States and of a departm ent and agency thereof, the

aggregate value of which exceeded $1,000, in violation of Title 18, United States Code, Section

641,

b.

to receive and retain things of value of the United States and of a departm ent and

agency thereof, the aggregate value of which exceeded $ 1,000, with the intent to convert them to

their ow n use and gain, know ing the checks to have been stolen, purloined, and converted, in

violation of Title 18, U nited States Code, Section 641,

to falsely m ake and forge endorsem ents on United States Treasury checks, in

violation of Title 18, United States Code, Section 510(a)(1), and

d.

to pass, utter, and publish United States Treasury checks, bearing falsely m ade

and forged endorsem ents, the aggregate face value of which exceeded $1,000, in violation of

2

Case 9:13-cr-80143-KLR Document 29 Entered on FLSD Docket 07/09/2013 Page 3 of 12

Title 18, United States Code, Section 510(a)(2).

Purpose of the C onspiracy

lt w as the purpose of the conspiracy for the defendants and their co-conspirators

to unjustly enrich themselves by cashing fraudulently obtained United States Treasury checks

and third party tax refund checks.

M anner and M eans of the Conspiracy

4.

The conspirators obtained United States Treasury checks and third party tax

refund checks in the nnm es of other people to w hich they w ere not entitled, including through the

filing of fraudulent Federal tax returns in the nam es of other people, w ithout those people's

know ledge or consent.

5.

The conspirators forged the payees' signatures as endorsem ents on the checks.

6.

The conspirators created fraudulent Florida driver's licenses in the nam es of the

payees on the checks.

The conspirators sought to cash the checks using the services of a cooperating

individual and undercover FBI agents, w hom the conspirators believed w ould pay the

conspirators a portion of the proceeds of the offense.

O vert A cts

In f'urtherance of the conspiracy,

and to

accomplish its objects and pumose, the

conspirators com m itted and caused to be com m itted, in the Southern D istrict of Florida, the

follow ing overt acts, am ong others:

8.

On or about A pril 30, 2013, JO U R M EL TH O M A S, during a telephone

conversation with an undercover FBI agent, told the agent that T H O M A S wanted the agent to

cash tax refund checks.

Case 9:13-cr-80143-KLR Document 29 Entered on FLSD Docket 07/09/2013 Page 4 of 12

9.

O n or about M ay 2, 2013, G ETO DO RL IZIER and JO U RM EL TH O M A S,

during a m eeting w ith two undercover FBl agents, told the agents that they w anted the agents to

cash tax refund checks.

1 0.

O n or about M ay 7, 2013, JO UR M EL TH O M A S accepted from an undercover

FBI agent identifying inform ation of tw o pum orted individuals and agreed to file fraudulent tax

returns on behalf of these pup orted individuals and to share the refunds obtained from these

retum s w ith the agent.

On or about M ay 7, 2013, JO U R M EL TH O M A S gave an undercover FB I agent

four United States Treasury checks with an aggregate value of approximately $1 1,880, three

third party tax refund checks with an aggregate value of approxim ately $1,412, and copies of

purported Florida driver's licenses for the payees on six of the checks.

On or about M ay 7, 2013, JO UR M EL TH O M A S forged endorsem ents on the

backs of the three third party tax reftm d checks described in the previous pr agraph in the nam es

of the payees on those checks.

13. On or about M ay 9, 2013, JO U R M EL TH O M A S gave an undercover FB1 agent

a third party tax refund check with a value of approximately $1,366.05 and a copy of a purported

Florida driver's license for the payee on one of the U nited States Treasury checks described in

paragraph 1 1.

On or about M ay 10, 2013, JO UR M EL TH O M AS gave an undercover FBI

agent a copy of a purported Florida driver's license for the payee on the third party tax reftm d

checks described in paragraph 13.

4

Case 9:13-cr-80143-KLR Document 29 Entered on FLSD Docket 07/09/2013 Page 5 of 12

On or about M ay 13, 2013, G ET O D O RLIZIER subm itted a false and

fraudulent tax return to the United States D epartm ent of the Treasury, in the nam e of and using

the social security num ber of one of the purported individuals described in paragraph 10.

16. On or about M ay 15, 2013, G ETO D O RI,IZIER gave tw o undercover FBl

agents seven U nited States Treasury checks. Six of those checks had an aggregate value of

approximately $37,746. The seventh check was originally issued with a value of approximately

$ 1,366 and subsequently altered such that its purported value was approxim ately $38,866.

DO RIaIZIER also gave the agents copies of purported Florida driver's licenses in the nam es of

the payees on tsve of the United States Treasury checks, including the altered check.

17.

On or about M ay 17, 2013, G ETO D O R IUIZIER gave tw o undercover FBl

agents nine United States Treasury checks with an aggregate value of approxim ately $9,610 and

one third party tax refund check with a value of approximately $5,746 and a copy of a purported

Florida driver's license and a purported social security card in the nnm e of the payee on the third

party tax refund check.

18. On or about M ay 17, 2013, after tw o undercover FB l agents retum ed the checks

and copies of purported licenses described in paragraph 16 to G E TO DO R LIZIER ,

DO R I,IZIER forged and caused conspirators to forge endorsem ents on the backs of six of the

checks described in paragraph 16 and the checks described in paragraph 17 and caused other

conspirators to sign the copies of the purported licenses described in paragraph 16.

O n or about M ay 20, 2013, G ET O D O R LIZIER gave an undercover FBI agent

copies of purported Florida driver's licenses in the nam es of the payees on eight of the U nited

States Treasury checks described in paragraph 17.

A ll in violation of Title 18, U nited States Code, Section 371 .

Case 9:13-cr-80143-KLR Document 29 Entered on FLSD Docket 07/09/2013 Page 6 of 12

R eceipt and R etention of T hings of V alue of the United States

C O U N TS 2-6

18 U.S.C. j 641

Begirm ing no earlier than the approxim ate dates of issue indicated as to each count

below , the exact dates being unknow n to the G rand Jury, and continuing through on ox about the

dates of distribution indicated below , in Palm Beach County, in the Southem D istrict of Florida,

and elsewhere, the defendants,

G ETO D O R LIZIER and
JO U RM EL TH O M A S,

did know ingly receive and retain things of value of the U nited States, that is, the indicated

United States Treasury checks, the aggregate value of which exceeded $ 1,000, with the intent to

convert them to their own use and gain, know ing the checks to have been stolen, purloined, and

converted.

Count D ate Check lssued

2
3
4
5
6

Au ust 6, 2012

D ate Check
Distributed
Check N um ber
M ay 7, 2013 315860364913
M a 15, 2013 315861894148
M a 15, 2013 315864864746
M a 17, 2013 315837927359
December 31, 2012 M ay 17, 2013 315842491773

A ril 19, 2013
A ril 24, 2013
M a 2, 2013

A pproxim ate

Value
$4,835
$8,827
$12,560
$1,575
$482

ln violation of Title 18, United States Codes Sections 641 and 2.

C O U N TS 7-9

A ggravated Identity Theft
18 U.S.C. j 1028A(a)(1)

On or about the dates indicated as to each count below , in Palm Beach County, in the

Southern D istrict of Florida, and elsew here, the defendants,

G ETO D O R LIZIER and
JO U RM E L TH O M A S,

during and in relation to felony violations, that is, receipt and retention of things of value of the

U nited States, as charged in the indicated predicate counts, did know ingly possess and use,

6

Case 9:13-cr-80143-KLR Document 29 Entered on FLSD Docket 07/09/2013 Page 7 of 12

w ithout law ful authority, m eans of identitk ation of other persons, that is, the nam es of the

indicated persons, printed on copies of pum orted Florida driver's licenses.

Count

D ate

lnitials of person

Predicate Count

7
8
9

M a 7, 2013
M a 15, 2013
M ay 15, 2013

LL
Cl
W A

2
3
4

ln violation of Title 18, United States Code, Sections 1028A(a)(1) and 2

CO UN T 10

Forging E ndorsem ents on Treasury C hecks

18 U.S.C. j 510(a)(1)

On or about M ay 17, 2013, in Palm Beach County, in the Southern D istrict of Florida,

and elsew here, the defendants,

G ETO D O R LIZIER and
JO U R M EL TH O M A S,

did know ingly and falsely m ake and forge endorsem ents on the fifteen indicated United States

Treasury checks, the aggregate value of which exceeded $1,000, with intent to defraud.

Check N um ber Approxinnate

N ote

315861894148
315865420148
315858274296

315861172251
315863341926
315864864746
315155335145
315840290553
315842177207
315837927359
315842491773
315842177259
315838363575
315837938393
205937458279

V alue

$8,827
$810

$38,866 originally issued with a value of approxinaately
$1,366 and subse uentl altered

$1,030
$4,551
$12,560
$430
$1,451
$1,685
$1,575
$482
$870
$1,274
$1,489
$352

Case 9:13-cr-80143-KLR Document 29 Entered on FLSD Docket 07/09/2013 Page 8 of 12

ln violation of Title 18, United States Code, Sections 510(a)(1) and 2

C O U N T 11

False, Fictitious and Fraudulent C laim

18 U.S.C. j 287

On or about January 17, 2012, in Palm Beach County, in the Southern D istrict of Florida,

and elsew here, the defendant,

G ET O D O R LIZIER ,

did m ake and present to a departm ent and agency of the United States, that is, the D epartm ent of

the Treasury, a claim upon and against the U nited States and said departm ent and agency, that is,

a tax return in the name of J.H ., assigned DLN 30221417587452, seeking a refund of $2,242,

know ing sueh claim to be false, fctitious, and fraudulent, in violation of Title 18, U nited States

Code, Sections 287 and 2.

C O U NT 12

False, Fictitious and Fraudulent C laim

18 U.S.C. j 287

On or about M ay 13, 2013, in Palm Beach County, in the Southem D istrict of Florida,

and elsew here, the defendants,

G ETO D O R LIZIER and
JO U R M EL TH O M A S,

did m ake and present to a departm ent and agency of the U nited States, that is, the D epartm ent of

the Treasury, a claim upon and against the U nited States and said departm ent and agency, that is,

a tax return in the nam e of the fictitious individual D avid J. K elley, assigned D LN

30221533053133, seeking a refund of $1,675, knowing such claim to be false, tictitious, and

fraudulent, in violation of Title 18, United States Code, Sections 287 and 2.

8

Case 9:13-cr-80143-KLR Document 29 Entered on FLSD Docket 07/09/2013 Page 9 of 12

C R IM IN A L FO RFEITU R E

The allegations of Counts 1 tllrough 6 and 10 of this Indictm ent are re-alleged and

by this refexence fully incom orated herein for the purpose of alleging forfeiture to the U nited

States of Am erica of certain property in w hich the defendant has an interest.

Upon conviction of any of the offenses alleged in Counts 1 through 6 or 10 of this

lndictm ent, the defendants, G E TO D O RLIZIER and JO U R M EL TH O M A S, shall forfeit to

the United States, ptlrsuant to Title 18, United States Code, Section 981(a)(1)(C), any property

constituting, or derived from , any proceeds that the defendant obtained, directly or indirectly, as

the result of such violation.

The property subject to forfeiture includes, but is not limited to the sum of

$29,800, which constitutes the gross proceeds the defendant derived from the offenses alleged in

this Indictment, which sum may be sought as a money judgment.

A11 pursuant to the provisions of Title 18, United States Code, Section 981(a)(l)(C), as

made applicable by Title 28, United States Cpde, Section 246l(c); and the procedures set forth at

Title 21, U nited States Code, Section 853.

A TRUE BILL

FO RE R SON

/

W IFREDO A. FERRER
UN ITED STATES ATTO RN EY

/>

M AR C OSBORN E
A SSISTAN T U N ITED STA TES ATTO RN EY

9

Case 9:13-cr-80143-KLR Document 29 Entered on FLSD Docket 07/09/2013 Page 10 of 12

UNITED STATES DISTRICT COURT
SO UTHERN DISTRICT OF FLORIDA

UNITED STATES OF AMERICA

CASE NO.

l 3 -gotNa-ce-m s- /e - 'c

VS.

GETO DORLIZIER and
JOURM EL THOMAS

CERTIFICATE O F TRIA L ATTO RN EY*

Defendant.

I

Supeo eding Case Inform ation:

Court Division: (select One)

Ke W est

M iam i
FTL
x w)B
l do hereby certify that:

FTP

New Defendantls.l
Num ber of New Defendants
Total number of counts

Yes

No X

I have carefully considered the allegations W the indictm:n t the number qf defendants, the number of
P
robable witnesses and the legal complexlties of the lndlctment/lnform atlon attached hereto.

2 .

I am Mware that the inform ation supplied Pn thi? jtaterpent will be relied upon by the Ju gd es 9f this
Cpurt In setting their galendars and schedullng crlmlnal trlals underthe mandate of the SpeedyTrlal Act,
Tltle 28 U.S.C. Sectlon 3161.

Iqterpreter: (Yes Qr Nj Nn
LIst Ianguage and/or dlalec
8-7
This case will take

days for the padies to try.

5.

Please check appropriate category and type of offense Iisted below:

(Check only one)

0 to 5 days
6 to 10 days
11 to 20 days
21 to 60 days
61 days and over

(Check only one)

Petty
MlnorM

lsdem .

Felony

Has this case been previously filed in this District Court? (Yes or No)

Kln

6.
If yes:
Judge:
LAttach copy Qf dispositive ?rdeç)
H
lf
M

as a complalnt been filed In thls matter?
yep:
aglstrate Case No.

Related Misc:llaneous numbers:
Defendantts) ln federal custody as of
Defendantts) In state custody as of
Rule 20 from the

Case No.

(Yes or No)

YpK

13-8277-JM1-1

District of

ls this a potential death penalty case? (Yes or No)

Doesthiscaseor gi inatefrom a matter pending in the Northern Region of the U.S. Attorney's Office prior
to October 14, 2

Yes X

G03?

No

8.

Does this case orininate from a matter pending in the Central Region of the U.S. Attorney's Office prior
to Septem ber 1, 2

Yes X

D07?

No

*penalty Sheetts) attached

REV 4/8/08

MARC OSBORNE
AS>ISTANT UNITED STATES ATTORNEY
Fl

orlda Bar No./coud No. A5500796

Case 9:13-cr-80143-KLR Document 29 Entered on FLSD Docket 07/09/2013 Page 11 of 12

U NITED STAT ES D IST RIC T C O U R T
SO U TH ERN D ISTR ICT O F FL O R ID A

PEN A LTY SH EET

D efendant's N am e: GETO DO RLIZIER
Case No: l B e N tv. B e' C# - O SO RP/

&S

Count #: 1

Conspiracv to Steal. Receive. and Retain M oney and Thin. as of V-alue of the United States and to
Force Endorsem ents on and Cash Treasury Checks

Title 18. U nited States Code. Section 371

* M ax.penalty: 5 Years' incarceration, $250,000 fine, 3 years' supervised release, restitution
Counts #: 2-6

Receipt and Retention of Things of Value of the U nited States

Title 18. United States Code. Section 641

# M axppenalty: 10 Years' incarceration, $250,000 fine, 3 years' supervised release, restitution
Counts #: 7-9

Accravated Identity Theft

Title 18. United States Code. Section 1028A(a)(1b

* M ax.penalty: 2 years' m andatory incarceration consecutive to a11 other offenses, $250,000

fine, 1 year's supervised release

Cotm t #: 10

Forzing Endorsem ents on Treasury Checks

Title 18. United States Code. Section 510(a)(1)

* M ax.penalty: 10 Years' incarceration, $250,000 tine, 3 years' supervised release, restitution
Count #: 1 1-12

False. Fictitious and Fraudulent Claim

Title 18. U nited States Code. Section 287

* M axvpenalty: 5 Years' incarceration, $250,000 fine, 3 years' supervised release, restitution

Case 9:13-cr-80143-KLR Document 29 Entered on FLSD Docket 07/09/2013 Page 12 of 12

U NITED STA TES DISTR IC T C O U R T
SO UTH ERN D ISTR ICT O F FLO R IDA

PEN A LTY SH EET

D efendant's Nam e: JOURMEL THOMAS
case No: l % -11 l @ B r f - S

:/

'<

Count #: 1

Conspiracy to Steal. Receive. and R etain M oney and Things of V alue of the United States and to
Forge Endorsem ents on and Cash Treasury Checks

Title 18. U nited States Code. Section 371

* M ax.penalty: 5 Years' incarceration, $250,000 fine, 3 years' supervised release, restitution
Counts #: 2-6

Receipt and Retention of Things of Value of the U nited States

Title 18. United States Code. Section 641

# M ax.penalty: 10 Years' incarceration, $250,000 fine, 3 years' supervised release, restitution
Counts #: 7-9

Aqgravated Identity Theft

Title 18. United States Code. Sedion 1028A(a)(11

# M ax.penalty: 2 years' m andatory incarceration consecutive to all other offeses, $250,000

fine, 1 year's supervised release

Count #: 10

Forging Endorsem ents on Treasury Checks

Title 1 8. U nited States Code. Section- -slotaltl)

* M axvpenalty: 10 Years' incarceration, $250,000 fine, 3 years' supervised release, restitution
Count #: 12

False- Fictitious and Fraudulent C laim

Title 18. U nited States Code. Section 287

# M ax.penalty: 5 Years' incarceration, $250,000 fine, 3 years' supervised release, restitution