FLORENCE T. NAKAKUNI United states Attorney District of Hawaii LESLIE E. OSBORNE, JR Chief, Fraud & Financial CLARE CONNORS Assistant U.S. Attorney Room 6-100, PJXK Federal 300 Ala Moana Blvd., Box Honolulu, Hawaii 96850 ‘Telephone (808) 541- Facsimile: (808) 541- Email: Attorneys for Plaintiff UNITED STATES OF AMERICA Clare [email protected] SEALED #2286 BY ORDER OF THE COURT #3070 Crimes section #7936 fates oisTRICT COURT nuTE9 STATES DISTRICT C Bullding UNTSpisrRICT OF HAWAI 2850 2958 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF e R10 - 00527 SOM UNITED STATES OF AMERICA ) CR. NO. ) Plaintiff, ) INDICTMENT ) v. ) Count 2 18 U.S.C. § 371 ) Counts 2-45: 1a U.S.C. § 1343 ESTRELLITA "ESTHER" (01) ) Counts 46-56: 18 U.S.C. § 1014 GARO MIGUEL, ) JENNIFER GARIN MIGUEL, (02) ) ST: A True Copy YOLIE CASTILLO TIBURCTO, (03) ) “SUE BECTIA VINAH CERIALES MORALES, (04) ) Clack. nnd States District GERALDINE GARIN MIGUEL (05) ) pf Yea LUKELA, TERESITA "TESSIE" (06) ) FAELDONEA SORINO, ) MARY ANN LAPENIA, (07) STEPHEN ELMER CALLO, (08) FELICIDAD "FELICIA" (08) TABALBAG CORPUZ, ) ALBERT LONOIKAUAKINI JOY, (10) ) Defendants ) See ee ee) INDICTMENTThe Grand Jury charges that: INTRODUCTION 1. At all times relevant to this Indictment and as set forth herein: a. ESTRELLITA "ESTHER" GARO MIGUEL ("ESTHER MIGUEL") was the owner and principal broker of Easy Mortgage Corporation ("Easy Mortgage"), as well as a real estate agent in the State of Hawaii. b. JENNIFER GARIN MIGUEL ("JENNIFER MIGUEL") was a loan officer at Easy Mortgage, the president of Unlimited Mortgage Services, and a real estate agent in the State of Hawaii. ¢. YOLIE CASTILLO TIBURCIO ("TIBURCIO") was a loan officer at Easy Mortgage. d. VINAH CERIALES MORALES ("MORALES") and GERALDINE GARIN MIGUEL LUKELA ("GERALDINE MIGUEL") were loan officers at Easy Mortgage and real estate agents in the State of Hawaii. ©. TERESITA "TESSIE" FAELDONEA SORINO ("SORINO") was a loan officer and processor at Easy Mortgage £. MARY ANN LAPENIA ("LAPENIA") was a real estate agent in the State of Hawaii and owner of R and M Rentals. g. STEPHEN ELMER CALLO ("CALLO") was the president of Accufast Mortgage and the owner of Stephen Callo CPA, Inc.| FELICIDAD "FELICIA" TABALBAG CORPUZ ("CORPUZ") applied for and obtained fraudulent mortgage loans for residential properties. i. ALBERT LONOIKAUAKINI Joy ("Joy") was the owner and operator of Hawaii Real Estate Professionals, as well as a mortgage solicitor and the owner of a property management business. counr 1 (Conspiracy to Commit Wire Fraud and False Statements on Loan Applications) The Grand Jury further charges that 2. From a precise earlier date unknown to the Grand Jury, but by in or about September 2003, and continuing until the date of this Indictment, in the District of Hawaii and elsewhere, defendants: ESTRELLITA "ESTHER" GARO MIGUEL JENNIFER GARIN MIGUEL YOLIE CASTILLO TIBURCIO VINAH CERIALES MORALES GERALDINE GARIN MIGUEL LUKELA TERESITA "TESSIE" FAELDONEA SORINO MARY ANN LAPENTA STEPHEN ELMER CALLO FELICIDAD "FELICIA" TABALBAG CORPUZ ALBERT LONOIKAUAKINI JOY Gid knowingly and willfully conspire with each other and with others, both known and unknown to the Grand Jury, to commit offenses against the United States, that is:a. knowingly to devise, and intending to devise, a scheme and artifice to defraud and to obtain money from lenders and others by means of materially false and fraudulent pretenses, representations and promises, as well as omissions of material facts, and for the purpose of executing said scheme and artifice, and attempting to do so, to cause certain items to be transmitted, in interstate commerce, by means of wire communications, certain signs, signals and sounds, in violation of Title 18, United states Code, Section 1343, and b. knowingly to make material false statements and reports for the purpose of influencing the actions of a financial institution in connection with loan applications, in violation of Title 18, United states Code, Section 1014. MANNER AND MEANS OF THE CONSPIRACY 3. The purpose of the conspiracy was to defraud lending institutions and others by preparing documents that contained materially false representations. It was part of the manner and means of the conspiracy that: ESTHER MIGUEL, JENNIFER MIGUEL, TIBURCIO, LAPENIA, JOY, and others, both known and unknown to the Grand Jury, recruited individuals, including CORPUZ, to sign loan applications containing false representations and false supporting documentation.b. ESTHER MIGUEL, JENNIFER MIGUEL, TIBURCIO, MORALES GERALDINE MIGUEL, SORINO and others, in their capacities as loan officers, made or caused to be made false representations on behalf of the mortgage loan applicants and, in so doing submitted materially false and fraudulent loan applications to lending institutions. ¢. ESTHER MIGUEL, SORINO, and others prepared the materially false loan applications by cutting and pasting documents, including bank statements, before submitting them to lending institutions. d. LAPENIA prepared and signed rental verification documents containing false information e. ALLO, in his capacity as a certified public accountant, prepared and signed letters containing false information concerning the employment of the loan applicants. £. When underwriters for the lending institutions attempted to verify the representations made in the loan applications, ESTHER MIGUEL, CALLO, and others subverted these efforts by asserting that the false representations were true. g. In reliance on the false statements in the loan applications, lenders transferred funds from their bank accounts in other states to the bank accounts of escrow companies in the State of Hawaii responsible for the closing of the fraudulent real estate transactionsh. ESTHER MIGUEL, JOY, and others directed the distribution of, and caused to be distributed, the loan proceeds to the participants of the scheme, as well as collected their standard transaction fees. commissions, and costs associated with the transactions. OVERT_ACTS 4, In furtherance of the conspiracy and to achieve the objects thereof, the conspirators committed, and caused to be committed, overt acts in the District of Hawaii and elsewhere. a. These overt acts include, but are not limited to, the followin: (1) On or about September 18, 2003, TIBURCIO and CORPUZ signed ‘a loan application containing false information related to the purchase by CORPUZ of a property located at 94-353 Apowale Street. (2) On or about September 18, 2003, LAPENIA signed a verification of rent form containing false information related to the purchase by CORPUZ of a property located at 94-353 Apowale Street. (3) On or about February 4, 2004, ESTHER MIGUEL signed a loan application containing false information related to the purchase by R.R. of a property located at 4018 Salt Lake Boulevard.(4) On or about June 7, 2004, TIBURCIO and CORPUZ signed a loan application containing false information related to the purchase by CORPUZ of a property located at 98-796 Leialii Street. (5) On or about June 24, 2004, TIBURCIO signed a loan application containing false information related to the purchase by R.R. of a property located at 1207 Ukana Street. (6) On or about July 20, 2004, ESTHER MIGUEL signed a standard Deposit Receipt Offer and Acceptance form related to the purchase by J.B. and A.B. of a property located at 91-1191 Hanaloa Street. (7) On or about August 31, 2004, TIBURCIO signed a loan application containing false information related to the purchase by J.B. and A.B. of a property located at 91-1191 analoa Street. (8) On or about January 16, 2005, ESTHER MIGUEL signed a standard Deposit Receipt Offer and Acceptance form related to the purchase by F.B. and Z.B. of a property located at 99-640 Halawa Drive. (9) On or about February 15, 2005, GERALDINE MIGUEL and TIBURCIO signed a loan application containing false information related to a residential property located at 1503 Piikea Street.(10) On or about February 18, 2005, TIBURCIO signed a loan application containing false information related to the purchase by F.B. and Z.B. of a residential property located at 99-640 Halawa Drive. (11) On or about March 28, 2005, ESTHER MIGUEL signed a loan application containing false information related to the purchase by R.R. of a property located at 364 Awini Place. (12) On or about April 20, 2005, JoY signed a standard Deposit Receipt Offer and Acceptance form related to the purchase by W.J. of a property located at 1322 Olino street (13) on or about April 22, 2005, CALLO signed a letter falsely certifying G.S.'s ownership of a company from which he earned income, which was submitted with a loan application related to the purchase by G.S. of a property located at 91-1191 Hanaloa Street. (14) on or about April 26, 2005, TIBURCIO signed a loan application containing false information related to the purchase by G.S. of a property located at 91-1191 Hanaloa Street (15) On or about dune 6, 2005, TIBURCIO signed a loan application containing false information related to the purchase by W.J. of a property located at 1322 Olino Street(16) On or about July 8, 2005, Joy and JENNIFER MIGUEL signed a standard Deposit Receipt Offer and Accegtance form related to the purchase by L.R. of a property located at 1477 Kanikani Place (17) On or about July 15, 2005, TIBURCIO signed a loan application containing false information related to the purchase by L.R. of a property located at 1477 Kanikani Place (18) On or about July 18, 2005, ESTHER MIGUEL signed a loan application containing false information the purchase by F.B. and Z.B. of a property located at Place. (19) On or about July 18, 2005, LAPENIA verification of rent form containing false information the purchase by F.B. and Z.B. of a property located at Place. (20) On or about July 29, 2005, MORALES signed-a loan application containing false information related to 1303 Wawe signed a related to 1303 Wawe and SORINO related to the purchase by MORALES of a property located at 98-797 Ainanui Loop (21) On or about August 14, 2005, LAPENIA signed a verification of rent form containing false information related to the purchase by L.R. of a property located at 1477 Kanikani Place.(22) On or about September 28, 2005, ESTHER MIGUEL signed a standard Deposit Receipt Offer and Acceptance form related to the purchase by J.D. of a property located at 94-967 Lumihoahu Street. (23) On or about December 9, 2005, LAPENIA signed a verification of rent form containing false information related to the purchase by L.A. of a property located at 91-822 Lawalu Place (24) On or about December 28, 2005, JENNIFER MIGUEL signed a loan application containing false information related to the purchase by J.D. of a property located at 94-967 Lumihoahu Street. (28) On or about January 7, 2006, JOY signed a standard Deposit Receipt Offer and Acceptance form related to the purchase by L.A. of a property located at 91-822 Lawalu Place. (26) On or about February 14, 2006, BSTHER MIGUEL signed a loan application containing false information related to the purchase by L.A. of a property located at 91-822 Lawalu Place. (27) On or about March 13, 2006, ESTHER MIGUEL signed a loan application containing false information related to the purchase by F.B. and Z.B. of a property located at 4158 Keaka Drive. 10(28) On or about March 16, 2006, JENNIFER MIGUEL signed a loan application containing false information related to the purchase by M.B. of a property located at 91-1039 Hamoula Street. (29) On or about March 19, 2006, LAPENIA signed a verification of rent form containing false information related to the purchases by J.V. of properties located at 94-266 Kahuanani Street and 1503 Piikea Street. (30) On or about April 25, 2006, TIBURCIO signed a loan application containing false information related to the purchase by J.V. of a property located at 94-266 Kahuanani Street. (31) On or about April 27, 2006, CALLO signed a letter falsely certifying that A.D.P. was self-employed, which was submitted with a loan application related to the purchase by R.P. and A.D.P. of a property located at 715 Puuhale Road. (32) On or about April 27, 2006, CALLO signed a loan application containing false information related to the refinance of a property located at 92-1236 Hookeha Street. (33) on or about May 8, 2006, ESTHER MIGUEL signed a loan application containing false information related to the purchase by R.P. and A.D.P. of a property located at 715 Puuhale Road. 12(34) On or about May 8, 2006, ESTHER MIGUEL signed a loan application containing false information related to the refinance by R.R. of a property located at 4018 Salt Lake Boulevard. (35) On or about May 17, 2006, TIBURCIO signed a loan application containing false information related to the purchase by E.V. of a property located at 1557 Molehu Drive. (36) On or about June 1, 2006, CALLO signed a letter containing false information about the employment of E.V., which was submitted with a loan application related to the purchase by E.V. of a property located at 1557 Molehu Drive. (37) On or about July 8, 2006, JENNIFER MIGUEL signed a loan application containing false information related to the purchase by M.L. of a property located at 1030 Long Lane. (38) On or about July 17, 2006, ESTHER MIGUEL signed a loan application containing false information related to the purchase by F.B. and Z.B. of a property located at 94-394 Honowai Street. (39) on or about July 17, 2006, ESTHER MIGUEL signed a standard Deposit Receipt offer and Acceptance form related to the purchase by R.L. of a property located at 94-967 Lumihoahu street. 12(40) On or about August 11, 2006, ESTHER MIGUEL signed a loan application containing false information related to the purchase by R.R. of a property located at 94-877 Lumiiki Street. (41) On or about August 19, 2006, JENNIFER MIGUEL signed a loan application containing false information related to the purchase by J.D. of a property located at 94-862 Lumihoahu Street. (42) on or about August 28, 2006, JENNIFER MIGUEL and LAPENIA signed a loan application containing false information related to the purchase by LAPENIA of a property located at 1477 Kanikani Place. (43) On or about September 11, 2006, JENNIFER MIGUEL signed a loan application containing false information related to the purchase by J.B. and A.B. of a property located at 94-386 Honowai Street. (44) On or about September 13, 2006, MORALES signed a standard Deposit Receipt Offer and Acceptance form related to the purchase by E.C. of a property located at 811 Kainoa Place (45) On or about September 20, 2006, JENNIFER MIGUEL signed a loan application containing false information xelated to the purchase by R.L. of a property located at 94-967 Lumihoahu. 13(46) On or about September 23, 2006, LAPENIA signed a verification of rent form containing false information, which was submitted with a loan application for the purchase by E.C. of a property located at 811 Kainoa Place (47) On or about September 26, 2006, JENNIFER MIGUEL signed a loan application containing false information for the purchase by E.C. of a property located at 811 Kainoa Place. (48) On or about October 7, 2006, ESTHER MIGUEL and LAPENIA signed a standard Deposit Receipt Offer and Acceptance form related to the purchase by L.R. of a property located at 1303 Wawe Place. (49) On or about October 26, 2006, SORINO signed a loan application containing false information related to the purchase by F.B. and Z.B. of a property located at 1333 Wanaka Street. (50) On or about December 18, 2006, CALLO signed a letter falsely certifying that L.R. was self-employed, which was submitted with a loan application related to the purchase by L.R. of a property located at 1303 Wawe Place (51) On or about January 9, 2007, LAPENIA signed a verification of rent form containing false information, which was submitted witn a loan application related to the purchase by J.D. of a property located at 1919 Beckley Street 14(52) On or about January 17, 2007, ESTHER MIGUEL signed a loan application containing false information related to the purchase by J.D. of a property located at 1919 Beckley Street. (53) On or about January 24, 2007, CALLO signed a letter containing false information about T.N.'s employment, which was submitted with a loan application related to the purchase by T.N. of a property located at 94-353 Apowale Street. (54) On or about July 12, 2007, CALLO signed a letter containing false information about L.N. and T.N.'s employment, which was submitted with a loan application related to a property located at 94-451 Honowai Street. (55) On or about February 8, 2008, GERALDINE MIGUEL and SORINO signed a loan application containing false information related to the purchase by GERALDINE MIGUEL of a property located at 98-796 Leialii Street. All in violation of Title 18, United States Code, Section 371. 2-45 (Wire Fraud) The Grand Jury further charges: SCHEME AND ARTIFICE TO DEFRAUD From a specific time unknown, but by in or about September 2003 and continuing thereafter until the date of this Indictment, in the District of Hawaii and elsewhere, defendant: 15ESTRELLITA "ESTHER" GARO MIGUEL, JENNIFER GARIN MIGUEL YOLIE CASTILLO TIBURCIO GERALDINE GARIN MIGUEL LUKELA TERESITA "TESSIE" FAELDONEA SORINO MARY ANN LAPENIA STEPHEN ELMER CALLO ALBERT LONOIKAUAKINI JOY along with others both known and unknown to the Grand Jury knowingly devised and intended to devise a scheme and artifice to defraud, and a scheme and artifice for obtaining money from lenders and others by means of material false and fraudulent pretenses, representations, and promises, as well as by omissions of material facts. 2. The Grand Jury hereby incorporates by reference paragraphs 1 through 4 of Count 1, as if set forth herein in their entirety WIRE COMMUNICATIONS 3. On or about the dates listed below, within the District of Hawaii and elsewhere, for the purpose of carrying out and attempting to carry out the aforesaid scheme and artifice to defraud, the defendants identified below did knowingly transmit and cause to be transmitted in interstate commerce writings signs, ané signals by means of wire communications, with each such transmission constituting a separate count of the Indictment: 16coun DEFENDANT (S) CHARGED DATE OF DESCRIPTION OF WIRE WIRE COMMUNICATION ESTHER MIGUEL 2/10/2004 |Wire re: 4018 Salt Lake Boulevard from Countrywide Home Loans, Inc.'s account in New York to Security Title Corporation's account in Hawaii in the amount of $389,328.10 ESTHER MIGUEL 2/10/2004 |Wire re: 4018 Salt Lake Boulevard from Countrywide Home Loans, Inc.'s account in New York to Security Title Corporation's account in Hawaii in the amount of $73,807.60 TIBURCIO 7/2/2004 |Wire re: 1207 Ukana Street from Fremont Investment and Loan's account in California to Old Republic Title & Escrow of Hawaii, LTD.'s account in Hawaii in the amount of $286,289.17. ESTHER MIGUEL TIBURCIO GERALDINE MIGUEL 2/23/2005 |Wire re: 1503 Piikea Street from Countrywide Home Loans Inc.'s account in New York to Old Republic Title & Escrow of Hawaii, LTD.'s account in Hawaii in the amount of $705,119.42 ESTHER MIGUEL 3/31/2005 |Wire re: 364 Awini Place from Countrywide Home Loans, Inc.'s account in New York to Old Republic Title & Escrow of Hawaii, LTD.'s account in Hawaii in the amount of $680,703.66. TIBURCIO CALLO 8/2/2005 |Wire re: 91-1191 Hanaloa Street from Countrywide Home Loans, Inc.'s account in New York to Old Republic Title & Escrow of Hawaii LID.'s account in Hawaii in the amount of $304,256.74 17counr | DEFENDaNT(s) | DATE OF DESCRIPTION OF. WIRE CHARGED WIRE COMMUNICATION a TIBURCIO 5/2/2005 |Wire re: 91-1191 Hanaloa Street from Countrywide Home CALLO Loans, Inc.'s account in New York to Old Republic Title & Escrow of Hawaii LTD.'s account in Hawaii in the amount of $75,724.68 9 ESTHER 8/17/2005 |Wire re: 1477 Kanikani Place MIGUEL from People's Choice Home Loan, Inc.'s account in New JENNIFER York to Island Title MIGUEL Corporation's account in Hawaii in the amount of TIBURCIO $349,851.60 LAPENIA gov 10 ESTHER 8/17/2005 |Wire re: 1477 Kanikani Place MIGUEL from People's Choice Home Loan, Inc.'s account in New JENNIFER York to Island Title MIGUEL Corporation's account in Hawaii in the amount of TIBURCIO $87,094.20 LAPENIA Jor 1 ESTHER 12/30/2005 |Wire re: 94-967 Lumihoahu MIGUEL Street from Fremont Investment and Loan's account in JENNIFER California to Fidelity MIGUEL National Title Insurance Company's account in Hawaii in the amount of $535,407.98 18counr | DEFENDawr(s) | DATE OF DESCRIPTION OF WIRE CHARGED WIRE COMMUNICATION 12 ESTHER 2/16/2006 |Wire re: 91-822 Lawalu Place MIGUEL from New Century Mortgage's account in New York to Old LAPENIA Republic Title & Escrow of Hawaii, UTD.'s account in gov Hawaii in the amount of $330,219.44 13 ESTHER 2/16/2006 |Wire re: 91-822 Lawalu Place MIGUEL from New Century Mortgage's account in New York to Old LAPENIA Republic Title & Escrow of Hawaii, LTD.'s account in gov Hawaii in the amount of $82,332.55 14 ESTHER 3/10/2006 |wire re: 1503 Piikea Street MIGUEL from Fremont Investrient and Loan's account in California TIBURCIO to Old Republic Title & Escrow of Hawaii, LTD.'s account in LAPENIA Hawaii in the amount of $674,480.26 15 ESTHER 3/10/2006 | Wire re: 1503 Piikea Street MIGUEL from Fremont Investment and Loan's account in California TIBURCIO to Old Republic Title & Escrow of Hawaii, LTD.'s account in LAPENIA Hawaii in the amount of $168,545.78 16 ESTHER 3/22/2006 |Wire re: 4158 Keaka Drive from MIGUEL ResMAE Mortgage Corporation's account in New York to Old JENNIFER Republic Title & Escrow of MIGUEL Hawaii LTD.'s account in Hawaii in the amount of $545,801.08 19COUNT | DEFENDANT(S) | DATE OF DESCRIPTION OF WIRE CHARGED WIRE COMMUNICATION 17 ESTHER 3/22/2006 | Wire re: 4158 Keaka Drive from MIGUEL ResMAE Mortgage Corporation's account in New York to Old JENNIFER Republic Title & Escrow of MIGUEL Hawaii LTD.'s account in Hawaii in the amount of $136,218.36 18 JENNIFER | 3/23/2006 |Wire re: 91-1039 Hamoula MIGUEL Street from Fremont Investment and Loan's account in California to Old Republic Title & Escrow of Hawaii LTD.'s account in Hawaii in the amount of $491,705.12 19 TIBURCIO 5/9/2006 |Wire re: 94-266 Kahuanani Street from WMC Mortgage LAPENIA Corporation's account in New York to Old Republic Title & Escrow of Hawaii LID.'s account in Hawaii in the amount of $543,304.37 20 TIBURCIO 5/9/2006 |Wire re: 94-266 Kahuanani Street from WMC Mortgage LAPENIA Corporation's account in New York to Old Republic Title & Escrow of Hawaii LID.'s account in Hawaii in the amount of $134,281.40 21 ESTHER 3/15/2006 | Wire re: 715 Puuhale Road from MIGUEL Accredited Home Lenders Inc.'s account in New York to CALLO Old Republic Title & Escrow of Hawaii LTD.'s account in Hawaii in the amount of $562,433.86 22 ESTHER 5/15/2006 |Wire re: 715 Puuhale Road from MIGUEL Accredited Home Lenders, Inc.'s account in New York to ALLO Old Republic Title & Escrow of Hawaii LID.'s account in Hawaii in the amount of $140,675.03 20A DEFENDANT. CHARGED DATE OF WIRE DESCRIPTION OF WIRE COMMUNICATION ESTHER MIGUEL 5/19/2006 Wire re: 4018 Salt Lake Boulevard from Fremont Investment and Loan's account in California to Old Republic Title & Escrow of Hawaii, LTD.'s account in Hawaii in the amount of $746,689.35 24 TIBURCIO CALLO 6/6/2006 Wire re: 1557 Molehu Drive from People's Choice Home Loan, Inc.'s account in New York to Old Republic Title & Escrow of Hawaii, LTD.'s account in Hawaii in the amount of $631,538.65 25 TIBURCIO CALLO 6/6/2006 Wire re: 1557 Molehu Drive from People's Choice Home Loan, Inc.'s account in New York to Old Republic Title & Escrow of Hawaii, LTD.'s account in Hawaii in the amount of $157,746.65 26 CALLO 6/19/2006 Wire re: 92-1236 Hookeha Street from Argent Mortgage Company LLC's account in New York to Fidelity National Title Insurance Company's account in Hawaii in the amount of $553,301.60 27 ESTHER MIGUEL, JENNIFER MIGUEL, 7/17/2006 Wire re: 1030 Long Lane from People's Choice Home Loan, Inc.'s account California to Old Republic Title & Escrow of Hawaii, LTD.'s account in Hawaii in the amount of $660,618.15 28 ESTHER MIGUEL 7/26/2006 Wire re: 94-394 Honowai Street from Accredited Home Lenders, Inc.'s account in Oregon to Old Republic Title & Escrow of Hawaii LTD.'s account in Hawaii in the amount of $591,657.46 22coun | DEFENDANT(S) | DATE OF DESCRIPTION OF WIRE CHARGED WIRE COMMUNICATION 29 ESTHER 7/26/2006 |Wire re: 94-394 Honowai Street MIGUEL from Accredited Home Lenders, Inc.'s account in Oregon to Old Republic Title & Escrow of Hawaii LTD.'s account in Hawaii in the amount of 135,451.08 30 ESTHER 8/23/2006 |Wire re: 94-877 Lumiiki Street MIGUEL from People's Choice Home Loan, Inc.'s account in New York to Old Republic Title & Escrow of Hawaii LTD.'s account in Hawaii in the amount of $625,346.77 31 ESTHER 8/29/2006 |Wire re: 94-862 Lumihoanu MIGUEL Street from People's Choice Home Loan, Inc.'s account in JENNIFER California to Island Title MIGUEL Corporation's account in Hawaii in the amount of $484,450.59 32 JENNIFER | 8/31/2006 |Wire re: 1477 Kanikani Place MIGUEL from ResMAE Mortgage Corporation's account in New LAPENIA York to Old Republic Title & Escrow of Hawaii LTD.'s account in Hawaii in the amount of $503,838.99. 33 ESTHER 9/21/2006 |Wire re: 94-386 Honowai Street MIGUEL from ResMAE Mortgage Corporation's account in New JENNIFER York to Old Republic Title & MIGUEL Escrow of Hawaii, LTD.'s account in Hawaii in the amount of $437,332.06 34 ESTHER 9/21/2006 |Wire re: 94-386 Honowai Street MIGUEL from ResMAE Mortgage Corporation's account in New JENNIFER York to Old Republic Title & MIGUEL Escrow of Hawaii, LTD.'s account in Hawaii in the amount of $109,117.59 22counr | DEFENDANT (Ss) | DATE OF DESCRIPTION OF WIRE CHARGED WIRE ‘COMMUNICATION 35 ESTHER 9/29/2006 |Wire re: 94-967 Lumihoahu MIGUEL Street from People's Choice Home Loan, Inc.'s account in JENNIFER New York to Old Republic Title MIGUEL & Escrow of Hawaii, LTD.'s account in Hawaii in the amount of $642,540.30 36 ESTHER 9/29/2006 |Wire re: 94-967 Lumihoahu MIGUEL Street from People's Choice Home Loan, Inc.'s account in JENNIFER, New York to Old Republic Title MIGUEL & Escrow of Hawaii, LTD.'s account in Hawaii in the amount of $160,396.46 37 geNNIFER | 11/3/2006 |Wire re: 1333 Wanaka Street MIGUEL from Fremont Investment & Loan's account in California SORINO to Old Republic Title & Escrow of Hawaii, LTD.'s account in Hawaii in the amount of $771,313.52 38 JENNIFER | 11/3/2006 |Wire re: 1333 Wanaka Street MIGUEL from Fremont Investment & Loan's account in California SORINO to Old Republic Title & Escrow of Hawaii, LTD.'s account in Hawaii in the amount of $193,821.38 39 ESTHER 12/21/2006 | Wire re: 1303 Wawe Place from MIGUEL People's Choice Home Loan, Inc.'s account in New York to JENNIFER Old Republic Title & Escrow of MIGUEL Hawaii, LTD.'s account in Hawaii in the amount of LAPENIA $557,447 CALLO 23count | DEFENDANT(s) | DATE OF DESCRIPTION OF WIRE CHARGED WIRE COMMUNICATION 40 ESTHER 12/21/2006 | Wire re: 1303 Wawe Place from MIGUEL People's Choice Home Loan Inc.'s account in New York to JENNIFER Old Republic Title & Escrow of MIGUEL Hawaii, LTD.'s account in Hawaii in the amount of LAPENIA, $138,955.60 CALLO 41 CALLO 1/25/2007 |Wire re: 94-353 Apowale Street from Impac Funding Corporation, dba Impac Lending Group's account in New York to Old Republic Title & Escrow of Hawaii, LTD.'s account in Hawaii in the amount of $700,962.73 42 CALLO 1/25/2007 |Wire re: 94-353 Apowale Street from Impac Funding Corporation, dba Impac Lending Group's account in New York to Old Republic Title & Escrow of Hawaii, LTD.'s account in Hawaii in the amount of $175,559.27. 43 ESTHER 1/26/2007 |Wire re: 1919 Beckley Street MIGUEL from Fremont Investment and Loan's account in California JENNIFER to Old Republic Title & Escrow MIGUEL of Hawaii, LTD.'s account in Hawaii in the amount of LAPENIA $361,569.84 44 ALLO 7/20/2007 |Wire re: 94-451 Honowai Street from Impac Funding Corporation, dba Impac Lending Group's account in New York to Old Republic Title & Escrow of Hawaii, LTD.'s account in Hawaii in the amount of $589,740.46 24counr | perENpanr (s. DATE OF DESCRIPTION OF WIRE CHARGED MIRE, “COMMUNICATION 45 ESTHER 2/14/2008 |Wire re: 98-796 Leialii Street MIGUEL from Washington Mutual Bank's account in California to Old SORINO Republic Title & Escrow of Hawaii, LTD.'s account in GERALDINE Hawaii in the amount of MIGUEL $621,242.41 All in violation of Title 18, United states Code, Sections 1343 and 2. counr_46 (False Statement on a Loan Application) The Grand Jury further charges: on or about February 4, 2004, in the District of Hawaii, defendant ESTRELLITA "ESTHER" GARO MIGUEL did knowingly make and cause to be made material false statements for the purpose of influencing the action of Countrywide Home Loans, Inc., an institution whose accounts were insured by the Federal Deposit Insurance Corporation, in connection with a Uniform Residential Loan Application, Form 1003, related to a property located at 4018 Salt Lake Boulevard for an individual identified by initials R.R., which included but was not limited to the materially false representation that R.R. earned $7,850 per month, when in truth and in fact, as the defendant well knew, R.R. did not earn $7,850 per month. All in violation of Title 18, United States Code, Section 1014 25counr 47 (False Statement on a Loan Application) The Grand Jury further charges: On or about June 24, 2004, in the District of Hawaii, defendant YOLIE CASTILLO TIBURCIO did knowingly make and cause to be made material false statements for the purpose of influencing the action of Fremont Investment and Loan, an institution whose accounts were insured by the Federal Deposit Insurance Corporation, in connection with a Uniform Residential Loan Application, Form 1003, for an individual identified by initials R.R., which included but was not limited to the materially false representations that R.R. intended to reside in a property located at 1207 Ukana Street, and that R.R. earned $5,300 per month, when in truth and in fact, as the defendant well knew, R.R. did not intend to occupy the property and did not earn $5,300 per month. All in violation of Title 18, United states Code, Section 1014. cOuNT 48 (False Statement on @ Loan Application) The Grand Jury further charges: On or about February 15, 2005, in the District of Hawaii, defendants GERALDINE GARIN MIGUEL LUKELA and YOLIE CASTILLO TIBURCIO did knowingly make and cause to be made material false statements for the purpose of influencing the 26action of Countrywide Home Loans, Inc., an institution whose accounts were insured by the Federal Deposit Insurance Corporation, in connection with a Uniform Residential Loan Application, Form 1003, for GERALDINE MIGUEL, which included but was not limited to the materially false representation that GERALDINE MIGUEL intended to reside in a property located at 1503 Piikea as a primary residence, when in truth and in fact, as the defendants well knew, GERALDINE MIGUEL did not intend to occupy the property. All in violation of Title 18, United States Code Section 1014. counr 49 (False Statement on a Loan Application! The Grand Jury further charges: On or about March 28, 2005, in the District of Hawaii defendant ESTRELLITA "ESTHER" GARO MIGUEL did knowingly make and cause to be made material false statements for the purpose of influencing the action of Countrywide Home Loans, Inc., an institution whose accounts were insured by the Federal Deposit Insurance Corporation, in connection with a Uniform Residential Loan Application, Form 1003, for an individual identified by initials R.R., which included but was not limited to the materially false representations that R.R. intended to reside in a property located at 364 Awini Place, and that R.R. earned $25,488.22 per month, when in truth and in fact, as the defendant 27well knew, R.R. did not intend to occupy the property and did not earn $25,488.22 per month. All in violation of Title 18, United states Code, Section 1014. counr_50 (False Statement on a Loan Application) The Grand Jury further charge: On or about April 26, 2005, in the District of Hawaii, defendants YOLIE CASTILLO TIBURCIO and STEPHEN ELMER CALLO did knowingly make and cause to be made material false statements for the purpose of influencing the action of Countrywide Home Loans, Inc., an institution whose accounts were insured by the Federal Deposit Insurance Corporation, in connection with a Uniform Residential Loan Application, Form 1003, for an individual identified by initials G.S, which included but was not limited to the materially false representations that G.9. intended to reside in a property located at 91-1191 Hanaloa Street, that G.S. earned $7,500 per month, and that G.S. owned a company from which $3,500 in monthly income was earned, when in truth and in fact, as the defendants well knew, G.S. did not intend to occupy the property, did not earn $7,500 per month, and did not earn $3,500 from a company G.S. owned. All in violation of Title 18, United States Code, Section 1014 28couNT 51 (False Statement on a Loan Application’ The Grand Jury further charges: On or about December 28, 2005, in the District of Hawaii, defendant JENNIFER GARIN MIGUEL did knowingly make and cause to be made material false statements for the purpose of influencing the action of Fremont Investment and Loan, an institution whose accounts were insured by the Federal Deposit Insurance Corporation, in connection with a Uniform Residential Loan Application, Form 1003, for an individual identified by initials J.D., which included but was not limited to the materially false representations that J.D. intended to reside in a property located at 94-967 Lumihoahu Street, and that 3.D. earned $10,500 per month, when in truth and in fact, as the defendant well knew, J.D. did not intend to occupy the property and did not earn $10,500 per month All in violation of Title 18, United States Code section 1014. count _52 (False Statement on a Loan Application The Grand Jury further charges: On or about March 16, 2006, in the District of Hawaii defendant JENNIFER GARIN MIGUEL did knowingly make and cause to be made material false statements for the purpose of influencing the action of Fremont Investment and Loan, an institution whose 29accounts were insured by the Federal Deposit Insurance Corporation, in connection with a Uniform Residential Loan Application, Form 1003, for an individual identified by initials M.B., which included but was not limited to the materially false representations that M.B. intended to reside in a property located at 91-1039 Hamoula Street, and that M.B. earned $8,300 per month, when in truth and in fact, as the defendant well knew, M.B. did not intend to occupy the property and did not earn $8,300 per month. All in violation of Title 18, United states Code, Section 1014. counr 53 (False Statement on a Loan Application) The Grand dury further charges: On or about May 9, 2006, in the District of Hawaii, defendant ESTRELLITA "ESTHER" GARO MIGUEL did knowingly make and cause to be made material false statements for the purpose of influencing the action of Fremont Investment and Loan, an institution whose accounts were insured by the Federal Deposit Insurance Corporation, in connection with a Uniform Residential Loan Application, Form 1003, for an individual identified by initials R.R., which included but was not limited to the materially false representations that R.R. intended to reside in the property located at 4018 Salt Lake Boulevard, and that R.R. earned $23,000 per month, when in truth and in fact, as the 30defendant well knew, R.R. did not intend to occupy the property and did not earn $23,000 per month All in violation of Title 18, United States Code Section 1014. COUNT 54 (False Statement on a Loan Application The Grand Jury further charges On or about October 26, 2006, in the District of Hawaii, defendant TERESITA "TESSTE" FAELDONEA SORINO did knowingly make and cause to be made material false statements for the purpose of influencing the action of Fremont Investment and Loan, an institution whose accounts were insured by the Federal Deposit Insurance Corporation, in connection with a Uniform Residential Loan Application, Form 1003, related to a property located at 1333 Wanaka Street for individuals identified by initials as F.B. and Z.B., which included but was not limited to the materially false representation that F.B. and Z.B. earned $18,500 per wonth, when in truth and in fact, as the defendant well knew, F.B. and 2.B, did not earn $18,500 per month All in violation of Title 18, United states Code, section 1014. COUNT 55 (False Statement on a Loan Application) The Grand Jury further charges: 31on or about January 17, 2007, in the District of Hawaii, defendant ESTRELLITA "ESTHER" GARO MIGUEL did knowingly make and cause to be made material false statements for the purpose of influencing the action of Fremont Investment and Loan, an institution whose accounts were insured by the Federal Deposit Insurance Corporation, in connection with a Uniform Residential Loan Application, Form 1003, related to a property located at 1919 Beckley Street for an individual identified by initials J.D., which included but was not limited to the materially false representation that J.D. earned $7,500 per month, when in truth and in fact, as the defendant well knew, J.D. did not earn $7,500 per month All in violation of Title 18, United States code Section 1014. counrs 56 (False Statement on a Loan Application The Grand Jury further charges On or about February 8, 2008, in the District of Hawaii, defendants GERALDINE GARIN MIGUEL LUKELA and TERESITA "“TESSIE" PAELDONEA SORINO did knowingly make and cause to be made material false statements for the purpose of influencing the action of Washington Mutual Bank, FA, an institution whose accounts were insured by the Federal Deposit Insurance Corporation, in connection with a Uniform Residential Loan Application, Form 1003, related to a property located at 98-796 32Leialii Street for GERALDINE MIGUEL, which included but not limited to the materially false representation that GERALDINE MIGUEL earned $12,000 per month, when in truth and in fact, as the defendants well knew, GERALDINE MIGUEL did not earn $12,000 per month. All in violation of Title 18, United states Code, Section 1014. A TRUE BILL. DATED: August 4, 2010, at Honolulu, Hawaii s/ Foreverson FOREPERSON FLORENCE T. NAKAKUNI United States Attorney District of Hawaii LESLIS) E, OSBORNE, JR. Chief, Fraud & Financial Crimés iORS, Assistant U.S. mney 33