Case 2:19-cr-00712-PBT Document 5 Filed 11/19/20 Page 1 of 24

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA : CRIMINAL NO. 19-712

v. : DATE FILED: _____________

JEFFREY D. MARTIN : VIOLATIONS:

18 U.S.C. § 1349 (conspiracy to commit
: securities fraud – 1 count)
18 U.S.C. § 1348 (securities fraud – 3
: counts)
18 U.S.C. § 371 (conspiracy to commit
: securities fraud and wire fraud – 1 count)
15 U.S.C. §§ 78j(b) & 78ff and 17 C.F.R.
: § 240.10b–5 (securities fraud – 2 counts)
18 U.S.C. § 1343 (wire fraud – 5 counts)
: 18 U.S.C. § 2 (aiding and abetting)
Notice of forfeiture

SUPERSEDING INDICTMENT

COUNT ONE

THE GRAND JURY CHARGES THAT:

At all times material to this Superseding Indictment:

Relevant Individuals and Entities

1. First Power and Light LLC (“FPL”) was a Delaware limited liability

company with its principal place of business in Bridgeport, Pennsylvania. FPL was formed in

approximately July 2012. Person #1 was the nominal president of FPL. FPL was a solar

installation and sales company. In or about April 2015, FPL changed its name to Volt Solar

LLC, incorporated in Maryland with an address maintained in Bridgeport, Pennsylvania.

2. First Power and Light Inc. (“FPL Inc.”) was incorporated in the State of

Florida on or about July 1, 2013. FPL Inc. had an office in Bridgeport, Pennsylvania. Person #1
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was the nominal president of FPL Inc. Unlike FPL, FPL Inc. was a solar power company in

name only, with no active business or contracts.

3. Person #2 exercised control over FPL and FPL Inc.

4. Person #3 was a stock promoter. Person #3, who was not a licensed

Financial Industry Regulatory Authority (“FINRA”) investment broker, promoted penny stock

companies using various business names under his control, including Quantum Financial

Investments (“QFI”), in which Person #3 was a co-owner.

5. Person #4 was a co-owner of QFI, who worked at QFI in Glen Cove, New

York, promoting stocks. Person #4 was not a licensed FINRA investment broker.

6. Neoterra Enterprises, LLC (“Neoterra”) was a New York limited liability

company with its principal place of business in Woodstock, New Jersey. Neoterra was formed in

2010. Person #3 was the principal of Neoterra. Neoterra had no known legitimate business

purpose.

7. J.E. Consulting Corp. (“J.E. Consulting”) was a New York corporation

with its principal place of business in Thornwood, New York. J.E. Consulting was formed in

2012. Person #4 was the principal of J.E. Consulting. J.E. Consulting had no known legitimate

business purpose.

8. Person #5 and Person #6 together owned and operated Program Funding

Advisors LLC (“PFA”), a Delaware limited liability company with its principal place of business

in Old Brookville, New York. PFA was formed in approximately January 2012. Person #7,

Person #5’s wife, was the president of PFA. PFA was in the business of advising businesses on

how to promote stock.

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9. Mainstream Entertainment, Inc. (“MSEI”) was a Florida corporation with

its principal place of business in Orlando, Florida. MSEI is now known as Volt Solar Systems,

Inc. MSEI was owned by defendant JEFFREY D. MARTIN’s son, Person #8.

The Federal Securities Laws and SEC Rules and Regulations

10. Initially, the shares of MSEI were “restricted” pursuant to statute and rules

and regulations promulgated by the Securities and Exchange Commission (“SEC”). The SEC

was an independent agency of the United States government charged by law with preserving

honest and efficient markets in securities. The federal securities laws, regulations, and rules were

designed to ensure that the financial information of publicly traded companies was accurately

recorded and disclosed to the investing public.

11. The MSEI shares were restricted in the sense that they could not be resold

in the public market. Restricted securities are, generally, securities acquired in unregistered,

private sales. If one wishes to sell restricted securities to the public, certain conditions must,

generally, be met, including having current information about the issuing company available to

the public. In order to have the restriction removed, Person #2 enlisted the services of Person #9,

a lawyer, who agreed to issue a false opinion letter to the effect that certain conditions had been

satisfied for the removal of the restriction.

The Conspiracy

12. From at least in or about April 2012, through at least in or about May

2014, in the Eastern District of Pennsylvania and elsewhere, defendant

JEFFREY D. MARTIN

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together with Person #2, Person #3, Person #4, Person #5, Person #6, Person #10, Person #11,

Person #12, and others known and unknown to the grand jury, conspired to commit offenses

against the United States, namely, securities fraud, that is, to knowingly and intentionally

execute a scheme and artifice (a) to defraud any person in connection with any security of

Mainstream Entertainment, Inc., n/k/a Volt Solar Systems, Inc., an issuer with a class of

securities registered under Section 12 of the Securities Exchange Act of 1934 (15 U.S.C. § 78l)

and that was required to file reports under Section 15(d) of the Securities Exchange Act of 1934

(15 U.S.C. § 78o(d)), and (b) to obtain, by means of materially false and fraudulent pretenses,

representations, and promises, any money and property in connection with the purchase and sale

of any security of Mainstream Entertainment, Inc., n/k/a Volt Solar Systems, Inc., an issuer with

a class of securities registered under Section 12 of the Securities Exchange Act of 1934 (15

U.S.C. § 78l) and that was required to file reports under Section 15(d) of the Securities Exchange

Act of 1934 (15 U.S.C. § 78o(d)), in violation of Title 18, United States Code, Section 1348.

Purposes of the Conspiracy

13. The purposes of the conspiracy were to: (a) defraud the investors; (b)

fraudulently obtain investor monies and pay and receive undisclosed commissions; (c) artificially

inflate the value of MSEI securities; and (d) enrich the schemers.

Manner and Means

It was part of the conspiracy that:

14. In or about 2012, Person #10 introduced Person #2 to defendant JEFFREY

D. MARTIN. Defendant MARTIN was interested in selling MSEI. On or about September 20,

2012, FPL executed a stock purchase agreement, whereby it became the majority shareholder of

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MSEI for $50,000. Related to this transaction, Person #2 also received 50 million shares of

MSEI.

15. Thereafter, Person #2 distributed the 50 million shares of MSEI. Among

other things, Person #2 distributed 35 million shares to his girlfriend, Person #13, so that he

could maintain control over the company. Person #2 also distributed 7.5 million shares to Person

#10 and Person #10’s two sons, Person #11 and Person #12. The remaining 7.5 million shares

were distributed by Person #2 to his associates and to employees of his companies, including

Person #14 and Person #15.

16. The conspirators directed the drafting of and drafted false and fraudulent

press releases and other communications relating to MSEI and its parent company, FPL, for the

purpose of convincing the investing public that FPL and MSEI had more business and were more

valuable than they, in fact, were, and to inflate the price of the stock of MSEI. In addition, the

conspirators created and disseminated false and fraudulent press releases and prepared and

disseminated a Form 8-K securities disclosure filed with the SEC on or about February 8, 2013,

all as part of the conspiracy to fraudulently inflate the price of the common stock of MSEI.

17. The conspirators used manipulative stock trading techniques to

fraudulently inflate the price of MSEI stock.

18. The conspirators used stock promoters, and non-arms-length trading with

related parties, to create the illusion of volume, in order to inflate the stock price and to sell their

own shares at inflated prices.

19. The conspirators ensured that any time they wanted to sell free trading

shares on the open market, there would be available buyers.

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20. Person #5 and Person #6, as well as their company, PFA, fraudulently

promoted MSEI stock. Person #5 and Person #6, in turn, directed Person #3 and Person #4 to

operate what is known as a “boiler room,” in which, among other things, Person #3, Person #4,

and other co-conspirators, known and unknown to the grand jury, cold-called potential investors,

for the purpose of getting them to buy shares of MSEI. Among other things, Person #5 and

Person #6 paid Person #3 and Person #4 undisclosed commissions for selling shares of MSEI,

which Person #3 and Person #4 directed to be paid to QFI, Neoterra, and J.E. Consulting.

21. The boiler room promoters touted MSEI using high pressure sales tactics

and misrepresentations about the value of MSEI and its stock.

22. The boiler room promoters did not disclose the commissions paid to them

by other conspirators on the sale of MSEI stock to investors on the open market.

23. To conceal the payment of undisclosed commissions, conspirators

commonly directed the transfer of such money to PFA to avoid the appearance of a direct

payment from other conspirators to Person #3 and Person #4.

24. Conspirators received shares, both restricted and free-trading, of MSEI

stock to compensate conspirators for participating in the scheme.

25. The conspirators planned to obtain and obtained money by inflating the

volume of trading in and the price of MSEI stock through misleading marketing and stock

manipulation, and by preventing the SEC from detecting the scheme or taking regulatory

enforcement action against them.

26. Defendant JEFFREY D. MARTIN received approximately $989,362 in

illicit proceeds from the sale of MSEI stock. Defendant MARTIN, or entities controlled by

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defendant MARTIN, sent wire transfers of approximately $685,608 to PFA, which was

controlled by Person #5 and Person #6.

27. Person #2 paid kickbacks related to transactions in MSEI stock of

approximately $843,007 to PFA, which was controlled by Person #5 and Person #6.

All in violation of Title 18, United States Code, Section 1349.

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COUNT TWO

THE GRAND JURY FURTHER CHARGES THAT:

1. Paragraphs 1–11 and 14–27 of Count One of this Superseding Indictment

are realleged and incorporated by reference as though fully set forth herein.

2. From at least in or about April 2012, through at least in or about May

2014, in the Eastern District of Pennsylvania and elsewhere, defendant

JEFFREY D. MARTIN

knowingly and intentionally executed a scheme and artifice (a) to defraud any person in

connection with any security of Mainstream Entertainment, Inc., n/k/a Volt Solar Systems, Inc.,

an issuer with a class of securities registered under Section 12 of the Securities Exchange Act of

1934 (15 U.S.C. § 78l) and that was required to file reports under Section 15(d) of the Securities

Exchange Act of 1934 (15 U.S.C. § 78o(d)), and (b) to obtain, by means of materially false and

fraudulent pretenses, representations, and promises, any money and property in connection with

the purchase and sale of any security of Mainstream Entertainment, Inc., n/k/a Volt Solar

Systems, Inc., an issuer with a class of securities registered under Section 12 of the Securities

Exchange Act of 1934 (15 U.S.C. § 78l) and that was required to file reports under Section 15(d)

of the Securities Exchange Act of 1934 (15 U.S.C. § 78o(d)).

All in violation of Title 18, United States Code, Sections 1348 and 2.

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COUNT THREE

THE GRAND JURY FURTHER CHARGES THAT:

Relevant Individuals and Entities

1. Defendant JEFFREY D. MARTIN and his co-conspirators communicated

false and fraudulent information about penny stocks, and engaged in manipulative trading of

those penny stocks, for the purpose of fraudulently inflating the stock prices and reaping illicit

gains, all to the detriment of the investing public.

2. Resort Savers, Inc. (“Resort Savers”) was a Nevada corporation with

reported business locations in the State of Washington and the People’s Republic of China.

Resort Savers’s common stock was a penny stock quoted on the OTC Link (previously known as

the “Pink Sheets”) operated by OTC Markets Group, Inc., under the ticker symbol “RSSV.”

Resort Savers was an issuer with a class of securities registered under Section 12 of the Securities

Exchange Act of 1934 (“Exchange Act”), 15 U.S.C. § 78l.

3. Axiom Corp. (“Axiom”) was a Nevada corporation with reported business

locations in the State of Florida and Hong Kong. Axiom’s common stock was a penny stock

quoted on the OTC Link (previously known as the “Pink Sheets”) operated by OTC Markets

Group, Inc., under the ticker symbol “AIOM.”

4. Virtual Medical International, Inc. (“Virtual Medical”) was a Nevada

corporation with a reported business location in the State of California. Virtual Medical’s

common stock was a penny stock quoted on the OTC Link (previously known as the “Pink

Sheets”) operated by OTC Markets Group, Inc., under the ticker symbol “QEBR.”

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5. Union Bridge Holdings Ltd. (“Union Bridge”) was a Nevada corporation

with a reported business location in Hong Kong. Union Bridge’s common stock was a penny

stock quoted on the OTC Link (previously known as the “Pink Sheets”) operated by OTC

Markets Group, Inc., under the ticker symbol “UGHL.” Union Bridge was an issuer with a class

of securities registered under Section 12 of the Exchange Act, 15 U.S.C. § 78l.

6. The SEC was an independent agency of the United States government

charged by law with preserving honest and efficient markets in securities. The federal securities

laws, regulations, and rules were designed to ensure that the financial information of publicly

traded companies was accurately recorded and disclosed to the investing public.

The Conspiracy

7. From at least in or about October 2015, through at least in or about

December 2019, in the Eastern District of Pennsylvania, the Eastern District of New York, and

elsewhere, defendant

JEFFREY D. MARTIN

together and with Co-Conspirator 1 (“CC-1”), Co-Conspirator 2 (“CC-2”), and Co-Conspirator 3

(“CC-3”), each of whom is known to the grand jury, and with others known and unknown to the

grand jury, conspired to commit offenses against the United States, namely:

a. securities fraud, that is, to knowingly and intentionally execute a

scheme and artifice (i) to defraud any person in connection with any

security of an issuer with a class of securities registered under Section

12 of the Exchange Act (15 U.S.C. § 78l) and that was required to file

reports under Section 15(d) of the Exchange Act (15 U.S.C. § 78o(d)),

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and (ii) to obtain, by means of materially false and fraudulent

pretenses, representations, and promises, any money and property in

connection with the purchase and sale of any security of an issuer with

a class of securities registered under Section 12 of the Exchange Act

(15 U.S.C. § 78l) and that was required to file reports under Section

15(d) of the Exchange Act (15 U.S.C. § 78o(d)), in violation of Title

18, United States Code, Section 1348;

b. securities fraud, that is, unlawfully, willfully, and knowingly, directly

and indirectly, by use of the means and instrumentalities of interstate

commerce and the mails, and the facilities of national securities

exchanges, to use and employ manipulative and deceptive devices and

contrivances by: (i) employing devices, schemes, and artifices to

defraud; (ii) making untrue statements of material facts and omitting to

state material facts necessary in order to make the statements made, in

light of the circumstances under which they were made, not

misleading; and (iii) engaging in acts, practices, and courses of

business which operated and would operate as a fraud and deceit upon

any person, in connection with the purchase and sale of securities, in

violation of Title 15, United States Code, Sections 78j(b) and 78ff, and

Title 17, Code of Federal Regulations, Section 240.10b–5; and

c. wire fraud, that is, knowingly and with the intent to defraud, to devise,

and to intend to devise, a scheme and artifice to defraud, and to obtain

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money and property by means of materially false and fraudulent

pretenses, representations, and promises, and to transmit and cause to

be transmitted certain wire communications in interstate and foreign

commerce, for the purpose of executing the scheme and artifice, in

violation of Title 18, United States Code, Section 1343.

Purposes of the Conspiracy

8. The purposes of the conspiracy were to: (a) defraud the investors; (b)

fraudulently obtain investor monies and pay and receive undisclosed commissions; (c) artificially

inflate the value of the securities of Resort Savers, Axiom, Virtual Medical, and Union Bridge;

and (d) enrich the members of the conspiracy.

Manner and Means

It was part of the conspiracy that:

9. In or about October 2015, CC-1 and CC-2 recruited CC-3 to promote, and

to fraudulently sell to investors and prospective investors, the securities of penny stock

companies. Generally, a penny stock is a security issued by a very small company that trades at

less than $5 per share. CC-3 created Global Research, LLC (“Global Research”) as an entity

through which his and his co-conspirators’ fraudulent activities would be conducted.

10. Defendant JEFFREY D. MARTIN, CC-1, CC-2, and CC-3 agreed with

one another and with persons known and unknown to the grand jury to manipulate—or to “pump

and dump”—the common stock of Resort Savers, Axiom, Virtual Medical, and Union Bridge

(together, the “Manipulated Companies”).

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11. The co-conspirators acquired control of the Manipulated Companies and

their respective stock.

12. The co-conspirators artificially inflated the market price of, and demand

for, the stock of the Manipulated Companies by creating false and misleading information about

the Manipulated Companies and their respective securities to be released to the public and to

investors and prospective investors in the Manipulated Companies and by manipulative trading

of the shares of the Manipulated Companies.

13. CC-3 telephoned investors and prospective investors in the Manipulated

Companies, to convince them to buy stock in the Manipulated Companies. CC-3 made

fraudulent and material misstatements about the Manipulated Companies and their respective

securities in order to convince the investors and prospective investors that the Manipulated

Companies and their stock were more valuable than they, in fact, were and to induce the

investors and prospective investors to buy the stock.

14. The co-conspirators coordinated stock sales with stock promotions,

including widespread e-mail distributions, or “e-mail blasts.” By coordinating stock promotions

and stock sales, the co-conspirators were able to increase the price and volume of stock sales by

creating the false appearance to investors that there was market interest in the stock being

manipulated when, in fact, there was little or no interest in the stock.

15. The co-conspirators engaged in manipulative and deceptive securities

transactions, including pre-arranged sales and purchases of stock between or among themselves

or other individuals under their control, referred to as “coordinated trading,” in order to create

the false appearance of an active and liquid market in the stocks being traded and to artificially

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drive up the share price and trading volume. Among other things, stock purchases made by

investors and prospective investors contacted by CC-3 were coordinated with stock sales,

through communications between or among defendant JEFFREY D. MARTIN, CC-1, and CC-2.

16. The co-conspirators sold stock in the Manipulated Companies, often in a

coordinated manner, during and after the promotions in order to maximize profits.

17. The co-conspirators used various accounts, entities, and nominees in order

to attempt to prevent the SEC or other regulators from being able to determine the identity of

persons receiving the proceeds of the stock manipulations.

18. The co-conspirators used wires and facilities of interstate and foreign

commerce in furtherance of the scheme.

Overt Acts

In furtherance of the conspiracy and to accomplish its objects, defendant

JEFFREY D. MARTIN, CC-1, CC-2, and CC-3, and others known and unknown to the grand

jury, committed the following overt acts, among others, in the Eastern District of Pennsylvania,

the Eastern District of New York, and elsewhere:

1. On or about September 12, 2016, CC-3 sent an e-mail message to K.J.

attaching a Global Research newsletter discussing Global Research’s “top recommendations” for

stock, including Resort Savers.

2. On or about October 20, 2016, defendant JEFFREY D. MARTIN sold

45,655 shares of Axiom common stock through a brokerage account titled in the name of an

entity controlled by defendant MARTIN.

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3. On or about October 21, 2016, and after K.J. purchased 41,500 shares of

Axiom common stock, CC-3 made a telephone call to K.J. to verify that K.J. had bought the

shares.

4. On or about October 25, 2016, defendant JEFFREY D. MARTIN received

proceeds from a settled trade of Axiom common stock, in the amount of $153,807, deposited into

a bank account titled in the name of an entity that defendant MARTIN controlled.

5. On or about October 28, 2016, defendant JEFFREY D. MARTIN

transferred by wire $66,970 to a bank account titled in the name of an entity controlled by CC-1

and CC-2.

6. On or about October 28, 2016, an entity controlled by CC-1 and CC-2

transferred by wire $12,500 to a bank account titled in the name of Global Research.

All in violation of Title 18, United States Code, Section 371.

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COUNT FOUR

THE GRAND JURY FURTHER CHARGES THAT:

1. Paragraphs 1–2, 6, and 9–18 of Count Three of this Superseding

Indictment are re-alleged and incorporated by reference as though fully set forth herein.

2. From at least in or about October 2015, through at least in or about

December 2019, in the Eastern District of Pennsylvania and elsewhere, defendant

JEFFREY D. MARTIN

knowingly and intentionally executed a scheme and artifice (a) to defraud any person in

connection with any security of Resort Savers, Inc., an issuer with a class of securities registered

under Section 12 of the Securities Exchange Act of 1934 (15 U.S.C. § 78l) and that was required

to file reports under Section 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. § 78o(d)),

and (b) to obtain, by means of materially false and fraudulent pretenses, representations, and

promises, any money and property in connection with the purchase and sale of any security of

Resort Savers, Inc., an issuer with a class of securities registered under Section 12 of the

Securities Exchange Act of 1934 (15 U.S.C. § 78l) and that was required to file reports under

Section 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. § 78o(d)).

All in violation of Title 18, United States Code, Sections 1348 and 2.

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COUNT FIVE

THE GRAND JURY FURTHER CHARGES THAT:

1. Paragraphs 1, 3, 6, and 9–18 and the Overt Acts of Count Three of this

Superseding Indictment are re-alleged and incorporated by reference as though fully set forth

herein.

2. From at least in or about December 2015, through at least in or about June

2017, in the Eastern District of Pennsylvania and elsewhere, defendant

JEFFREY D. MARTIN

did unlawfully, willfully, and knowingly, directly and indirectly, by use of the means and

instrumentalities of interstate commerce, and the facilities of national securities exchanges, use

and employ manipulative and deceptive devices and contrivances, in violation of Title 17, Code

of Federal Regulations, Section 240.10b–5, by: (a) employing devices, schemes and artifices to

defraud; (b) making untrue statements of material facts and omitting to state material facts

necessary in order to make the statements made, in the light of the circumstances under which

they were made, not misleading; and (c) engaging in acts, practices and courses of business

which operated and would operate as a fraud and deceit upon any person, in connection with the

purchase and sale of a security of Axiom Corp.

All in violation of Title 15, United States Code, Sections 78j(b) and 78ff, and

Title 17, Code of Federal Regulations, Section 240.10b–5, and Title 18, United States Code,

Section 2.

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COUNT SIX

THE GRAND JURY FURTHER CHARGES THAT:

1. Paragraphs 1, 4, 6, and 9–18 of Count Three of this Superseding

Indictment are re-alleged and incorporated by reference as though fully set forth herein.

2. From at least in or about August 2017, through at least in or about

December 2019, in the Eastern District of New York and elsewhere, defendant

JEFFREY D. MARTIN

did unlawfully, willfully, and knowingly, directly and indirectly, by use of the means and

instrumentalities of interstate commerce, and the facilities of national securities exchanges, use

and employ manipulative and deceptive devices and contrivances, in violation of Title 17, Code

of Federal Regulations, Section 240.10b–5, by: (a) employing devices, schemes and artifices to

defraud; (b) making untrue statements of material facts and omitting to state material facts

necessary in order to make the statements made, in the light of the circumstances under which

they were made, not misleading; and (c) engaging in acts, practices and courses of business

which operated and would operate as a fraud and deceit upon any person, in connection with the

purchase and sale of a security of Virtual Medical International, Inc.

All in violation of Title 15, United States Code, Sections 78j(b) and 78ff, and

Title 17, Code of Federal Regulations, Section 240.10b–5, and Title 18, United States Code,

Section 2.

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COUNT SEVEN

THE GRAND JURY FURTHER CHARGES THAT:

1. Paragraphs 1, 5–6, and 9–18 of Count Three of this Superseding

Indictment are re-alleged and incorporated by reference as though fully set forth herein.

2. From at least in or about January 2017, through at least in or about

December 2019, in the Eastern District of New York and elsewhere, defendant

JEFFREY D. MARTIN

knowingly and intentionally executed a scheme and artifice (a) to defraud any person in

connection with any security of Union Bridge Holdings Ltd., an issuer with a class of securities

registered under Section 12 of the Securities Exchange Act of 1934 (15 U.S.C. § 78l) and that

was required to file reports under Section 15(d) of the Securities Exchange Act of 1934 (15

U.S.C. § 78o(d)), and (b) to obtain, by means of materially false and fraudulent pretenses,

representations, and promises, any money and property in connection with the purchase and sale

of any security of Union Bridge Holdings Ltd., an issuer with a class of securities registered

under Section 12 of the Securities Exchange Act of 1934 (15 U.S.C. § 78l) and that was required

to file reports under Section 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. § 78o(d)).

All in violation of Title 18, United States Code, Sections 1348 and 2.

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COUNTS EIGHT THROUGH TWELVE

THE GRAND JURY FURTHER CHARGES THAT:

1. Paragraphs 1–6 and the Overt Acts of Count Three of this Superseding

Indictment are re-alleged and incorporated by reference as though fully set forth herein.

The Scheme

2. From at least in or about October 2015, through at least in or about

December 2019, defendant

JEFFREY D. MARTIN

devised and intended to devise a scheme to defraud investors in Resort Savers, Inc., Axiom

Corp., Virtual Medical International, Inc., and Union Bridge Holdings Ltd., and to obtain money

and property by means of false and fraudulent pretenses, representations, and promises.

Manner and Means

3. The United States re-alleges and incorporates by reference Paragraphs 9

through 18 of Count Three of this Superseding Indictment as a description of the manner and

means of the scheme.

The Wire

4. On or about each of the dates set forth below, in the Eastern District of

Pennsylvania, the Eastern District of New York, Middle District of Florida, and elsewhere,

defendant

JEFFREY D. MARTIN

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for the purpose of executing the scheme described above caused to be transmitted by means of

wire communication in interstate and foreign commerce the signals and sounds set forth below,

each transmission constituting a separate count:

COUNT DATE DESCRIPTION VENUE

EIGHT October 20, an interstate electronic securities Eastern District of

2016 transaction (for the purchase of Pennsylvania
41,250 shares of Axiom Corp.
common stock) from K.J. (in the
State of Texas) to a broker-dealer
(in the Eastern District of
Pennsylvania)
NINE October 28, a wire transfer from account of Middle District of
2016 Forbes Investment LLLP to Florida
account of Program Funding
Advisors LLC in the amount of
$66,970
TEN November 8, an interstate electronic securities Eastern District of
2016 transaction (for the purchase of Pennsylvania
7,000 shares of Axiom Corp.
common stock) from K.J. (in the
State of Texas) to a broker-dealer
(in the Eastern District of
Pennsylvania)
ELEVEN January 21, an international text Eastern District of New
2019 communication from defendant York
JEFFREY D. MARTIN to CC-1
discussing Resort Savers and
Union Bridge and their respective
securities
TWELVE October 29, an international text Eastern District of New
2019 communication from defendant York
JEFFREY D. MARTIN to CC-1
discussing Union Bridge and its
securities and avoiding anti–
money laundering review by
banks

All in violation of Title 18, United States Code, Section 1343.

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NOTICE OF FORFEITURE

THE GRAND JURY FURTHER CHARGES THAT:

1. As a result of the violations of Title 18, United States Code, Sections 371,

1343, 1348, and 1349 and Title 15, United States Code, Section 78ff, defendant

JEFFREY D. MARTIN

shall forfeit to the United States of America any property that constitutes, or is derived from,

proceeds traceable to the commission of such offenses, including, but not limited to, the sum of

at least $10,993,971.30.

2. If any of the property subject to forfeiture, as a result of any act or

omission of the defendant:

(a) cannot be located upon the exercise of due diligence;

(b) has been transferred or sold to, or deposited with, a third party;

(c) has been placed beyond the jurisdiction of the Court;

(d) has been substantially diminished in value; or

(e) has been commingled with other property which cannot be divided

without difficulty;

it is the intent of the United States, pursuant to Title 28, United States Code, Section 2461(c),

incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any other

property of the defendant up to the value of the property subject to forfeiture.

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