May Indict

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UNITJD STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDA

IM-8OO8I-CR-HURLEY/HO PKINSCASE NO.

18 USG 1 134118 USC 1 134318 USC 1 134918 USC 1 1956 (a)(1)(A)(i)18 USC j 1956 (a)(1)(B)(i)18 USC 1 195718 USC 1 2

18 USC j 981(a)(1)(C)

Fltf9by TM. - D.c.&K FG c

May 8, 2014

NTEMI.X M. kl@leoqte LE A h tl . .$ ol : T. tT.:.0. :F etl. . MG II

UNITED STATES OF AMERICA,

E3llhirl tiff,

V.

JOSEPH SIGNOR ,EPAUL LEW IS SCHUMACK II,LAURA GM NDE-SIGNORE, andCRAIG ALLEN HIPP,

Defendants./

INDICTMENT

The Grand Jury charges that:

GENERAL ALLEGATIONS

At all times relevant to this lndictm ent:

JCS Enterprises, Inc.(hereaqer 'iJCS'') was a Delaware corporation

registered as a foreign comoration in the State of Florida on or about June 23, 2011.

JOSEPH SIGNORE served as the President of JCS. On or about June 29. 2011, JCS

Enterprises, lnc. changed its name to JCS Enterprises Services, Inc. JOG Enterprises,

Inc. (hereafter uJOLA'') was a Florida corporation formed on or about February 25, 2013.

Case 9:14-cr-80081-DTKH Document 45 Entered on FLSD Docket 05/08/2014 Page 1 of 31

JOSEPH SIGNORE and G URA GRANDE-SIGNORE served as the o/cers of JOtA .

2. T.B.T.I., Inc. (hereafter ''TBTl'') was a Florida corporation formed on August 13,

2001 by defendant PAUL LEW IS SCHUMACK, lI. TBTI served as a sales agent for JCS

beginning as early as Novem ber, 2011. PSCS Holdings LLC, was a Florida corporation

formed on or about August 5,2013, by PAUL LEW IS SCHUMACK 11 a manager and

resident agent of the corporation.

3. JCS and its sales team at TBTI marketed and sold virtual concierge machines

(VCMs) to investors throughout the United States, utilizing various salesmen in Florida

and around the country. A VCM is a stand-alone machine with a monitor display that

allows the user to, among other things, view advedisements, purchase products and print

retail coupons. VCMS are viable for any business that wanted to Iet its customers order

products without having to interact with a cashier.

5. LAURA GRANDE-SIGNORE served as the Executive Vice President of JCS.

She Signed checks to investors and vendors, and signed investor contracts on behalf of

JCS.

6. CRAIG ALLEN HIPP served as the President of Manufacturing and Operations

for JCS. He was in charge of manufacturing, and also signed

behalf of JCS.

investor contracts on

TD Bank, BB&T, Bank of America (hereafter d'BOA''), and SunTrust Bank

(hereafter ''SunTrust'') are FDIC insured financial institutions as defined by Title 18, United

States Code, Section 20.

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Count 1

(Conspiracy to Commit Mail Fraud & Wire Fraud, 18 U.S.C. Sec. 1349)

8. Beginning at Ieast as early as June 2011, the exact date being unknown to the

grand jury, through on or about April 7,2014, in Palm Beach County, in the Southern

District of Florida, and elsewhere, the defendants,

JOSEPH SIGNOR ,EPAUL LEW IS SCHUMACK II,

LAURA GRANDE-SIGNORE, andCRAIG ALLEN HIPP,

did willfully, that is, with the intent to further the object of the conspiracy, and knowingly

combine, conspire, confederate, agree and reach a tacit understanding with each other,

and with persons, known and unknown to the grand jury, to commit offenses against the

United States, that is: (a) mail fraud, in violation of Title 18, United States Code, Section

1341,. and (b) wire fraud, in violation of Title 18, United States Code, Section 1343.

OBJECT OF THE CONSPIRACY

9. It was the object of the conspiracy for the defendants and their co-conspirators

to obtain money from investors under false and fraudulent pretenses, representations and

promises by purpoding to sell manufactured VCMS, and to place the VCMS in marketable

Iocations which would earn revenues from advedising and other commercial activities

be returned to investors on a monthlyinstalled on manufactured VCMS, which would

basis.

MANNER AND M EANS OF THE CONSPIRACY

10. The manner and means by which the defendants sought to accomplish the

object of the conspiracy included the following:

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11. From at Ieast as early as June 2011, defendant JOSEPH SIGNORE

marketed VCMS as investments from the olices of JCS in Jupiter, FL. Defendant PAUL

LEW IS SCHUMACK, 11 reached an agreement with JOSEPH SIGNORE in approximately

November 2011 to also market VCMS,and SCHUMACK operated from his residences

Iocated in Highland Beach, a/k/a Boca Raton, and Delray Beach, FL.

12. The defendants sold the VCMS as investments to approximately 1,500

investors nationwide by representing that the investors would own the VCM, that it would

be placed in a prime Iocation and would generate advedising revenues on a monthly

basis.

13. To induce the investors to pay the cost of the VCM , which ranged between

$3,000.00 and $4,500.00, the defendants made one or more of the following false and

fraudulent representations:

a. Investors would purchase an actual VCM unit, typically for $3,500.00, which

would be placed into service somewhere in the United States to be used by

the public and have enough built-in advedising and other revenue to suppod

the payments to investors. Defendants called this the ''passive program .''

b. The defendants claimed that they had Iocations at hotels, restaurants,

hospitals and other public places at which to place the manufactured VCMS

upon which advedising and other commercial activities were placed.

c. The defendants represented that they had companies paying revenues for

the placement of advedising and other revenue generating commercial

activities on the VCMS.

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d. In vidually every sale, investors were promised a guaranteed $300 payment

per month for 36 consecutive months, purpodedly as the investors' share of

the incom ing advedising and commercial revenue stream on the VCM .

e. lnvestors were told their units had been built and then provided the investors

with a fake serial number for each of the units they purchased.

f. Defendants promised to provide maintenance and insurance for the VCM

units at no cost to the investors.

g. Investors were sometimes told that they could purchase a VCM and place it

wherever they chose and receive aII advertising and other revenue their

machine produced. This was referred to by the defendants as the

''aggressive program ,'' but very few, if any, investors chose to take actual

delivery of the VCM and place it into use themselves.

14. To convince the investors that the VCMS were being built and placed at

public Iocations, defendant JOSEPH SIGNORE rented a Iuxury office and warehouse

space in Jupiter, FL in which to display VCMS being built and the operations of the

company for inspection by the investors.

15. To conceal the scheme to defraud and avoid the investors Iearning that no

more than 500 VCMS were placed in Iocations and that revenues from advertising and

other sources were insufficient to pay the monthly agreed upon earnings of $300 for each

VCM, the defendants caused Ponzi payments to be made by using new investor money

received for the sale of VCMS to pay existing prior investors the $300 per month

guaranteed payment per VCM unit. These Ponzi payments were sent out to investors by

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use of the U.S. Mails. Convinced that the VCMS were a good investment, many of the

investors contracted to purchase m ultiple units, with one investor buying hundreds of

units.

16. On occasion, investors requested to know the exact location of the VCM unit

sold to them . Defendants responded by suggesting that they would have to switch from

the 'lpassive program'' (which provided a guaranteed stream of $300 monthly payments)

to the ''aggressive program ,'' and would need to take actual delivery of the unit. Doing

this would involve the investor generating its own sources of revenue, maintenance and

insurance, and foregoing the guaranteed payments.

Although the defendants represented to investors that thousands of VCM

units were already manufactured, shipped and placed at business Iocations to collect

advedising and other commercial revenues, in truth and in fact Iess than approximately

1,000 VCMS were manufactured and no more than 500 VCMS shipped and placed in

Iocations to earn advedising and other commercial activities revenues.

18. Using these materially false and fraudulent pretenses, representations and

promises, and others, the defendants, through JCS and TBTI, sold approximately 26,000

VCMS to approximately 1,500 investors in Florida and throughout the United States,

bringing in over $70,000,000.00 in revenue.

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

Counts 2 - 15

(MaiI Fraud, 18 U.S.C. Secs. 1341 and 2)

19. Paragraphs 1 through 7 of the General Allegations section of this Indictment

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

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20. Beginning at Ieast as early as June 2011, the exact date being unknown to

the grand jury, through on or about April 7, 2014, in Palm Beach County, in the Southern




did knowingly, and with intent to defraud, devise and intend to devise, and participate in a

scheme and artifice to defraud and for obtaining money and propedy by means of

materially false and fraudulent pretenses, representations and promises, knowing that such

pretenses, representations and promises were false and fraudulent when made.

OBJECT OF THE SCHEME AND ARTIFICE

21. lt was the object of the scheme and artifice to defraud for the defendants to

obtain money from investors under false and fraudulent pretenses, representations and

promises by purporting to sell manufactured VCMS, and to place the VCMS in marketable

Iocations which would earn revenues from advedising and other commercial activities

installed on manufactured VCMS, which would be returned to investors on a monthly

basis.

MANNER AND MEANS OF THE SCHEME AND ARTIFICE

22. The Grand Jury re-alleges and incorporates herein by reference paragraphs 10

through 18 of the Manner and Means Section in Count One of the Indictment.

USE OF THE MAILS IN THE EXECUTION OF THE SCHEME

23. On or about the dates set fodh below as to each count, in the Southern

District of Florida and elsewhere, and for the purpose of executing the aforesaid scheme

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and artifice to defraud and for obtaining money and property by means of materially false

and fraudulent pretenses, representations and promises, the defendants charged in each

respective count did knowingly cause to be delivered mail matter by the United States

Postal Service and by private or commercial interstate carrier, by causing payments for

hurported VCM purchases to be sent back to the offices of the defendants, and for Ponzi

payments to be sent to investors, as described below:

COUNT DATE DEFENDANTS MAIL MATTER

2 October 25, 2012 JOSEPH SIGNORE Federal Express packet from

PAUL LEW IS ''MB'' in Virginia to TBTI,SCHUMACK 11 Boca Raton, FL

3 January 31, 2013 JOSEPH SIGNORE Federal Express packet fromPAUL LEW IS ''M B'' in Virginia to TBTI,SCHUMACK 11 Delra Beach, FL

4 February 27, 2013 JOSEPH SIGNORE Federal Express packet fromPAUL LEW IS ''MB'' in Virginia to TBTI,SCHUMACK 11 Delra Beach, FL

5 May 23, 2013 JOSEPH SIGNORE Federal Express packet fromPAUL LEW IS ''JB'' in Louisiana to TBTI,SCHUMACK 11 Boca Raton, FL

6 June 25, 2013 JOSEPH SIGNORE Federal Express packet fromPAUL LEW IS ''MB'' in Virginia to TBTI,SCHUMACK 11 Boca Raton, FL

7 June 27, 2013 JOSEPH SIGNORE Federal Express packet fromPAUL LEW IS 'tJB'' in Louisiana to TBTI,SCHUMACK 11 ''Paul Schumack,'' Boca

Raton, FL8 July 3, 2013 JOSEPH SIGNORE Federal Express packet from

PAUL LEW IS ''JB'' in Louisiana to TBTI,SCHUMACK 11 'dpaul Schumack,'' Boca

Raton, FL9 July 24, 2013 JOSEPH SIGNORE Federal Express packet from

PAUL LEW IS ''JB'' in Louisiana to TBTI,SCHUMACK 11 'dpaul Schumack,'' Boca

Raton, FL10 September 27, 2013 JOSEPH SIGNORE Federal Express packet from

PAUL LEW IS ''AB'' New Jersey to TBTI,SCHUMACK 11 Boca Raton, FL

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COUNT DATE DEFENDANTS MAIL MATTER

11 October 29, 2013 JOSEPH SIGNORE Federal Express packet from

PAUL LEW IS ''MB'' in Virginia to ,Tû'T'L FXW/-SCHUMACK 11 Boca Raton, FL

12 November 15, 2013 JOSEPH SIGNORE Ponzi payment for $7:500

PAU L LEWIS jjjyjot # , q ..U .S. Mail to ''AB''SCHUMACK 11 ï' K.rM'- ''X e y by defendantSCHUMACK, from BocaRaton, FL

13 December 27, 2013 JOSEPH SIGNORE Federal Express packet from

PAUL LEW IS $$MB'' in Virginia to TBTI,SCHUMACK 11 Boca Raton, FL

14 February 15, 2014 JOSEPH SIGNORE Ponzi payments for $1,800LAURA and $3,000 sent via U.S. MailGRANDE-SIGNORE to ''ML'' in Bossier City, LA

from JCS Enterprises, Inc., inJu iter, FL

15 March 28, 2014 JOSEPH SIGNORE Ponzi Payment for $15,.

000LAURA sent via U.S. Mail to ''SX'' inGRANDE-SIGNORE Port St. Lucie, FL from JCSCRAIG HIPP Enterprises, Inc., in Jupiter,

FL

AII in violation of Title 18, United States Code, Sections 1341 and 2.

Counl 16 - 24

(W ire Fraud, 18 U.S.C. Secs. 1343 and 2)

24. Paragraphs 1 through 7 of the General Allegations section of this Indictment

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

25. Beginning at Ieast as early as June 2011, the exact date being unknown to

the grand jury, through on or about April 7, 2014, in Palm Beach County, in the Southern




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did knowingly, with intent to defraud, devise and intend to devise, and padicipate in a

scheme and adifice to defraud and for obtaining money and property by means of

materially false and fraudulent pretenses, representations and promises, knowing that such

pretenses, representations and promises were fajse and fraudulent when m ade.

OBJECT OF THE SCHEME AND ARTIFICE

26. lt was the object of the scheme and adifice to defraud for the defendants to

obtain money from investors under false and fraudulent pretenses, representations and

promises by purpoding to sell manufactured VCMS, and to place the VCMS in marketable

Iocations which would earn revenues from advertising and other commercial activities

installed on manufactured VCMS, which would be returned to investors on a monthly

basis.

MANNER AND M EANS OF THE SCHEME AND ARTIFICE

27. The Grand Jury re-alleges and incorporates herein by reference paragraphs 10

through 18 of the Manner and Means section in Count One of the Indictment

USE OF THE INTERSTATE W IRES IN EXECUTION OF THE SCHEME

28. On or about the dates set forth below as to each count, in the Southern District

of Florida, and elsewhere, and for the purpose of executing the aforesaid scheme and

artifice to defraud and for obtaining money and propedy by means of materially false and

fraudulent pretenses, representations and promises, the defendants charged in each

respective count did knowingly cause to be transmitted by means of wire comm unications

in interstate commerce cedain writings or signals as described below:

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UNT DATE DEFENDANTS INTERSTATE W IREcocouuuNlcAn oN

16 April 22, 2013 JOSEPH SIGNORE Internet communication from

CRAIG HIPP craigo icsenterprise.net inJupiter, FL to investor ''CS'' inFlorida

17 July 25, 2013 JOSEPH SIGNORE Internet communication from

PAUL LEW IS infoa icsenternrise.net inSCHUMACK 11 Jupiter, FL to investor 'IRH'' in

Vir inia

18 September 21, JOSEPH SIGNORE $28,000 wire from 'SPD'' from2013 LAURA Fremont Bank in California to

GRANDE-SIGNORE JCS Enterprises, Inc.'s BB&T

account ending in 5654 inJu iter, FL

19 Septem ber 30, JOSEPH SIGNORE Internet comm unication from2013 PAUL LEW IS defendant SCHUMACK to

SCHUMACK 11 investor ''AB'' in Florida20 September 30, JOSEPH SIGNORE Telefax com munication from

2013 PAUL LEW IS investor ''AA'' in Indiana toSCHUMACK 11 ''Paul Schumack'' in Palm

Beach Count , FL

21 October 28, 2013 JOSEPH SIGNORE $51,000 wire from ''PT'' in,PAUL LEW IS Ohio to TBTI'S BOA accountSCHUMACK 11 ending in 2038 in Deerfield

Beach, FL22 November 23, JOSEPH SIGNORE Telefax communication from

2013 PAUL LEW IS investor '$AA'' in Indiana to

SCHUMACK 11 ''Paul Schumack'' in PalmBeach Count , FL

23 December 26, JOSEPH SIGNORE Telefax communication from2013 PAUL LEW IS investor '$AA'' in Indiana to

SCHUMACK 11 ''Paul Schumack'' in Palm

Beach Count , FL

24 January 7, 2014 JOSEPH SIGNORE $14,000 wire from $'GS'''s lRALAURA SIGNORE Services Trust Co. in California

to JCS Enterprise ,s Inc.'st ending in 1921 ataccoun

Seacoast Bank, in Palm Beach

Count , FL

AIl in violation of Title 18, United States Code, Sections 1343 and 2.

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MONEY LAUNDERING

Count 25(Conspiracy to Commit Money Laundering, 18 U.S.C., Section 1956(h))

29. Paragraphs 1 through 7 of the General Allegations section and paragraphs 10

through 17 of the Manner and Means section in Count One this Indictment are realleged

and incorporated by reference as though fully set fodh herein.

30. Beginning at Ieast as early as June 201 1, the exact date being unknown to the

grand jury, through on or about April 7, 2014, in Palm Beach County, in the Southern


JosEpH SIGNOR ,EpAuu LEwls scHuuAck I L andLAURA GRANDE-SIGNOéE

did knowingly and willfully combine, conspire, confederate and agree with each other and

with others known and unknown to the grand jury to commit offenses against the United

States, that is, money Iaundering, in violation of Title 18, United States Code, Sections

1956 and 1957, as follows:

(a) To conduct and attempt to conduct a financial transaction affecting

interstate and foreign commerce, which financial transaction involved the proceeds of

specified unlawful activity, that is, mail fraud and wire fraud, in violation of Title 18, United

States Code, Sections 1341 and 1343, and with the intent to promote the carrying on of

specified unlawful activity, in violation of Title 18, United States Code, Section

1956(a)(1)(A)(i);

(b) To conduct and attempt to conduct a financial transaction affecting

interstate and foreign com merce, which financial transaction involved the proceeds of

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specified unlaM ul activity, that is, mail fraud and wire fraud, in violation of Title 18, United

States Code, Sections 1341 and 1343, knowing that the transaction was designed in whole

or in part to conceal and disguise the nature, location, source, ownership and control of the

proceeds of the specified unlawful activity, in violation of Title 18, United States Code,

Section 1956(a)(1)(B)(i)', and

(c) To knowingly engage and attempt to engage in monetary transactions in

criminally derived propedy of a value greater than $10,000, which property had been

derived from specified unlawful activity, that is, mail fraud and wire fraud in violation of Title

18, United States Code, Sections 1341 and 1343, in violation of Title 18, United States

Code, Section 1957.

AII in violation of Title 18, United States Code, Section 1956(h).

Count 26

(Promotion Money Laundering, 18 U.S.C. Secs. 1956(a)(1)(A)(i), and (2))

31. Paragraphs 1 through 7 of the General Allegations section of the Indictment

and paragraphs 10 through 18 of the Manner and Means section in Count One of this

Indictment are reallegeà and incorporated by reference as though fully set fodh herein.

32. On or about September 30, 2013, in Palm Beach County, in the Southern

District of Florida and elsewhere, the defendant,

JOSEPH SIGNORE,

did knowingly, with the intent to promote the carrying on of specified unlawful activity,

conduct and attempt to conduct a financial transaction affecting interstate and foreign

commerce, that is paying ''CK'' $49,170.00 drawn on JCS Enterprises account 5654 check

2872 at BB&T, which involved the proceeds of a specified unlawful activity, that is, mail

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fraud and wire fraud in violation of Title 18, United States Code, Sections 1341 and 1343.

AII in violation of Titlel8, United States Code, Sections 1956(a)(1)(A)(i) and 2.

Counl 27 - 30

(Concealment Money Laundering, 18 U.S.C. Secs. 1956(a)(1)(B)(i))

33. Paragraphs 1 through 7 of the General Allegations section of the Indictment

and paragraphs 10 through 18 of the Manner and Means section of Count One of this

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

34. On or about the dates set forth below as to each count, in Palm Beach County,

in the Southern District of Florida and elsewhere, the defendants, as identified below , did

knowingly conduct and attempt to conduct a financial transaction affecting interstate and

foreign commerce, which involved the proceeds of a specified unlawful activity, that is, mail

fraud and wire fraud, in violation of Title 18, United States Code, Sections 1341 and 1343,

knowing that the transaction was designed in whole and in part to conceal and disguise the

nature, Iocation, source, ownership and control of the proceeds of specified unlawful

activity and knowing that the propedy involved in the financial transaction represented the

proceeds of some form of unlawful activity:

COUNT DATE DEFENDANT TRANSACTION

27 September 16, JOSEPH SIGNORE TBTI Inc account (TD Bank2013 PAUL LEW IS 4901)r check 47407 for

SCHUMACK 11 $57,525.00 deposited to JOLA

Enterprises account (Sun Trust3628)

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28 September 30, JOSEPH SIGNORE $110,119.27 wire from JOLA2013 LAURA Enterprises account (SunTrust

GRANDE-SIGNORE 3628) to title company accountat Bank United for purchase of

rell propedy located at 1416164.b Drive Nodh

, Palm Beach

Gardens, FL

29 September 30, JOSEPH SIGNORE $225,000 wire from 'dt-aura2013 LAURA Signore'' account (SunTrust

GRANDE-SIGNORE 2100) to Bank United forpurchase of real prqgertyIocated at 14161 64.n DriveNorth, Palm Beach Gardens,FL

30 October 28, 2013 PAUL LEW IS $ ,1 50 u0 000.00 transfer fromSCHUMACK 11 SCHUMACK'S personal

account (BOA 6721) to PSCSHoldings LLC (BOA 6687)

AII in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and (2).

Counts 31 - 34

(Illegal Money Spending, 18 U.S.C., Section 1957)

35. Paragraphs 1 through 7 of the General Allegations of the lndictment section

and paragraphs 10 through 18 of the Manner and Means section of Count One of this

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

36. On or about the dates set forth as to each count below, in Palm Beach

County in the Southern District of Florida and elsewhere, the defendant indicated in each

count below did knowingly engage and attempt to engage in a m onetary transaction by,

through, or to a financial institution, affecting interstate and foreign commerce, in crim inally

derived propedy of a value greater than $10,000, as described below, such propedy

having been derived from specified unlawful

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activity, to wit: mail fraud (Title 18, United


States Code, Section 1341)*, and wire fraud (Title 18, United States Code, Section 1343).


31 May 20, 2013 JOSEPH $114,040.12 wire from JCS

SIGNORE account (TD Bank 8571) toSouth Florida Title for the

purchpse of real property locatedt 77tn Trail North

, Palm Beacha

Gardens, FL Insurp.m ju s

32 September 19, PAUL LEW IS TBTI Inc. account (TD Bank2013 SCHUMACK 11 4901) check 47408 for $25,000

deposited to PSCS Holdings LLC

account (BOA 6687)33 September 30, JOSEPH $200,000 wire from JCS

2013 SIGNORE Enterprises (BB&T 5654) to titlecom pany account at Bank United

for purchase of real yroperty14161 64tn DriveIocated at

Nodh, Palm Beach Gardens, FL

34 October 2, 2013 JOSEPH $114,613.31 internet paymentSIGNORE from JCS Enterprises account

(BB&T 5654) to AmericanExpress account ending 66003in the name of JCS Enterprises

AII in violation of Title 18, United States Code, Sections 1957 and 2.

FORFEITURE

37. Upon conviction of any of the violations set forth in Counts 1 through 24 of

this lndictment, the defendants JOSEPH SIGNORE, LAURA GRANDE-SIGNORE, and

PAUL LEW IS SCHUMACK, II, shall forfeit to the United States alI propedy, real or

. '

personal, which constitutes or is derived from proceeds traceable to a violation of the

afore-stated offenses, including, but not Iim ited to the following:

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a. A money judgment in the amount of at Ieast $70,000,000, which

represents the proceeds traceable to the violations.

b. the sum that constitutes the gross proceeds the Defendants derived

from the offenses, which sum is alleged to be at Ieast approximately $70,000,000 inUnited States currency.

c. alI principal, deposits, interest, dividends and other amounts credited

to TD Bank account number ending 4901 in the name of T.B.T.I., Inc., signatories

Paul and Christine SCHUMACK

d. aII principal, deposits, interest, dividends and other amounts credited

to BB&T Bank account number ending 5654 in the name JCS Enterprises, Inc.,Joseph and Laura SIGNORE signatories',

e. aII principal, deposits, interest, dividends and other amounts credited

to SunTrust Bank account numbers ending 1272 and 1000142942100 in the name

of Laura SIGNORE.

f. all principal, deposits, interest, dividends and other amounts credited

to Regions Bank account num ber ending 0589 in the name of JOLA Enterprises,

Inc., Joseph and Laura SIGNORE, signatories.

g. aII principal, deposits, interesl, dividends and other amounts creditedto Regions Bank account number ending 0546 in the name of JOLA Enterprises,

Inc., Joseph SIGNORE signatory.

h. aII principal, deposits, interest, dividends and other amounts credited

to Regions Bank account number ending 4372 in the name of Joseph Signore,

Joseph SIGNORE, signatory.

i. aII principal, deposits, interest, dividends and other amounts credited

to Regions Bank safe box (account ending 0150), Joseph and Laura SIGNORE,signatories.

j. Scottrade account number ending 3916 in the name of MY GEE BO,Inc., Joseph and Laura SIGNORE are the signatories.

k. aII principal, deposits, interest, dividends and other amounts credited

to Scottrade account number ending 6374 in the name of JCS Enterprises, lnc.,

Joseph and Laura SIGNORE signatories.

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aII principal, deposits, interest, dividends and other amounts credited

to Seacoast National Bank account number ending 1921 in the name of JCS

Enterprises Services, Inc., Joseph and Laura SIGNORE signatories.

m . aII principal, deposits, interest, dividends and other amounts credited



n. aII principal, deposits, interest, dividends and other amounts credited


Enterprises Services, Inc. ''M'' Account., Joseph SIGNORE signatory.

o. alI principal, deposits, interest, dividends and other amounts credited

to Bank of America account ending 2038 in the name of T.B.T.I., Inc., Paul and

Christine SCHUMACK signatories.

p. AlI that Iot or parcel of land, together with its buildings, appurtenances,i rovements, fixtures, attachments and easements, Iocated at 14161 64* Drivemp

N., Palm Beach Gardens, Palm Beach County, Florida, 33418, and moreparticularly described as:

A parcel of Iand in Section 22, Township 41 South, Range 42East, in Palm Beach County, Florida, and more particularlydescribed as follows:

The East 244 feet of a certain part of the Nodh 235 feet of theSouth 770 feet of said Section 22, with the East Iine of saidcertain part being at right angles to the South Iine of said

Section, and so Iocated that the Northerly projection of saidEast Iine intercepts the North Iine of the South 1250 feet of saidsection at a point 2720 feet East of the intersection of saidNorth Iine with W est section Iine; and with aII indicateddimensions being measured along Iines parallel to the W est

and South lines of Section 22. Subject to and together witheasements of record, including a road easement for ingressand egress over the South 30 feet and East 30 feet thereof.

Parcel ID: 00-42-41-00-000-8140

q. AII that lot or parcel of Iand, together with its buildings,

apgurtenances, improvements, fixtures, attachments and easements, Iocated at'b Trail Nodh Palm Beach Gardens

, FL 33418, as more padicularly described as77 ,follows:

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Propedy Appraisers Parcel Identification (FoIio) Number:00-42-41-16-00-000-7080 Parcel Y-279 A parcel of Iand inSection 16, Township 41 South, Range 42 East, in Palm BeachCounty, Florida, more padicularly described as follows:

The South 248 feet of the Nodh 561 feet of the W est 230 feetof the East 1620 feet of the Southwest Quader of said Section16.

r. All that lot or parcel of land, together with its buildings, appudenances,improvements, fixtures, attachments and easements, Iocated at 7725 NW 39Avenue, Coconut Creek, Broward County, Florida , 33073, and more padicularlydescribed as:

A portion of Section 32, Township 47 South, Range 42 East,

Broward County, Florida, more fully described as follows:

The North 144.40 feet of the South 516.35 feet (as measuredat right angles) of the East 1/2 of Tract 29, Block 83, PALMBEACH FARMS COMPANY PLAT No. 3, as recorded in PlatBook 2, Page 53, of the Public Records of Palm Beach County

,

Florida, said Iands situate, Iying and being in Broward County,

Florida.

38. If any of the property described above, as a result of any act oromission of the defendants:

a. cannot be Iocated upon the exercise of due diligence',

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

has been placed beyond the jurisdiction of the court',

has been substantially diminished in value', or

has been comm ingled with other propedy which cannot be divided

d.

e .

without difficulty;

It is the intent of the United States of America, pursuant to Title 21, United States Code,

Section 853(p), to seek forfeiture of any other property of the defendants up to the value of

the above forfeitable property.

19


AII pursuant to Title 28 United States Code, Section 2461 , Title 18, United States

Code, Section 981(a)(1)(C) and Title 21, United States Code, Section 853.

39. Upon conviction of any of the violations set forth in Counts 25 through 34 of

this Indictment, the defendants JOSEPH SIGNORE, LAURA GRANDE-SIGNORE, and

PAUL LEW IS SCHUMACK 11 shall fo/eit to the United States any property, real or

personal, involved in such offense, or any propedy traceable to such property, including,

but not Iimited to, the following:

a. A money judgment in the amount of at Ieast $70,000,000, which

represents the proceeds traceable to the violations.

b. the sum that constitutes the gross proceeds the Defendants derivedfrom the offenses, which sum is alleged to be at Ieast approximately $70,000,000 inUnited States currency.

aII principal, deposits, interest, dividends and other amounts credited

to TD Bank account number ending 4901 in the name of T.B.T.I., Inc., signatories

Paul and Christine SCHUMACK

d. aIl principal, deposits, interest, dividends and other amounts credited

to BB&T Bank account number ending 5654 in the name JCS Enterprises, Inc.,

Joseph and Laura SIGNORE signatories',

e. aII principal, deposits, interest, dividends and other amounts credited

to SunTrust Bank account numbers ending 1272 and 1000142942100 in the name

of Laura SIGNORE.

f. alI principal, deposits, interest, dividends and other amounts credited

to Regions Bank account number ending 0589 in the name of JOLA Enterprises,

lnc., Joseph and Laura SIGNORE, signatories.

g. aII principal, deposits, interest, dividends and other amounts credited

to Regions Bank account number ending 0546 in the name of JOLA Enterprises,

Inc., Joseph SIGNORE signatory.

20


h. alI principal, deposits, interest, dividends and other amounts credited

to Regions Bank account number ending 4372 in the name of Joseph Signore,

Joseph SIGNORE, signatory.

i. aII principal, deposits, interest, dividends and other amounts credited

to Regions Bank safe box (account ending 0150), Joseph and Laura SIGNORE,signatories.

j. Scottrade account number ending 3916 in the name of MY GEE BO,Inc., Joseph and Laura SIGNORE signatories.

k. aII principal, deposits, interest, dividends and other amounts credited

to Scottrade account number ending 6374 in the name of JCS Enterprises, Inc.,Joseph and Laura SIGNORE signatories.

1. aII principal, deposits, interest, dividends and other amounts credited


Enterprises Services, Inc., Joseph and Laura SIGNORE are the signatories.

m. alI principal, deposits, interest, dividends and other amounts credited



n. aII principal, deposits, interest, dividends and other amounts credited


Enterprises Services, Inc. $'M'' Account., Joseph SIGNORE signatory.

o. aII principal, deposits, interest, dividends and other amounts credited

to Bank of America account ending 2038 in the name of T.B.T.I., Inc., Paul and

Christine SCHUMACK signatories.

p. AII that lot or parcel of Iand, together with its buildings, appurtenances,improvements, fixtures, attachments and easements, located at 14161 64th Drive

N., Palm Beach Gardens, Palm Beach County, Florida, 33418, and moreparticularly described as:

A parcel of Iand in Section 22, Township 41 South, Range 42East, in Palm Beach County, Florida, and more particularlydescribed as follows:

The East 244 feet of a cedain part of the North 235 feet of theSouth 770 feet of said Section 22, with the East Iine of saidcedain part being at right angles to the South Iine of said

21


2

Section, and so Iocated that the Nodherly projection of saidEast Iine intercepts the North line of the South 1250 feet of saidsection at a point 2720 feet East of the intersection of saidNorth Iine with W est section line; and with aII indicateddimensions being measured along Iines parallel to the W est

and South Iines of Section 22. Subject to and together witheasements of record, including a road easement for ingressand egress over the South 30 feet and East 30 feet thereof.

Parcel lD: 00-42-41-00-000-8140

q. AII that lot or parcel of Iand, together with its buildings,

apgudenances, improvements, fixtures, attachments and easements, located atkb Trail Nodh Palm Beach Gardens

, FL 33418 as more particularly described as77 , ,

follows:

Propedy Appraisers Parcel Identification (FoIio) Number:00-42-41-16-00-000-7080 Parcel Y-279 A parcel of Iand inSection 16, Township 41 South, Range 42 East, in Palm BeachCounty, Florida, more padicularly described as follows:

The South 248 feet of the North 561 feet of the W est 230 feetof the East 1620 feet of the Southwest Quader of said Section16.

AII that lot or parcel of Iand, together with its buildings, appurtenances,improvements, fixtures, attachments and easements, Iocated at 7725 NW 39Avenue, Coconut Creek, Broward County, Florida , 33073, and more particularlydescribed as:

A portion of Section 32, Township 47 South, Range 42 East,Broward County, Florida, more fully described as follows:

The North 144.40 feet of the South 516.35 feet (as measuredat right angles) of the East 1/2 of Tract 29, Block 83, PALMBEACH FARMS COMPANY PLAT No. 3, as recorded in PlatBook 2, Page 5 ,3 of the Public Records of Palm Beach County,Florida, said Iands situate, Iying and being in Broward County,Florida.

Pursuant to Title 18, United States Code, Section 982(a)(1).

40. If the propedy described above as being subject to forfeiture, as a result of

any act or omission of the defendants,

22


a.

b.

d.

e.

cannot be located upon the exercise of due diligence',

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

has been placed beyond the jurisdiction of the court;

has been substantially diminished in value; or

has been commingled with other propedy which cannot be divided

without difficulty;

It is the intent of the United States, pursuant to Title 21 , United States Code, Section

853(p), as incorporated by Title 18, United States Code, Section 982(b)(1), to seek

forfeiture of any other property of the defendants up to the value of the above forfeitable

propedy.

A TRUE MILL

FOREPERSON

W IFREDO A. FER ERUNITED STATES AU ORN Y

àTEPHEN CARLTONASSISTANT UNITED STATES AU ORNEY

LLEN L. COHENASSISTANT UNITED STATES AU ORNEY

23


UNITED STATES DISTRICT COURTSOUTHERN DISTRICT O F FLORIDA

UNITED STATES OF AM ERICA

V S.

JOSEPH SIGNORE, et al

Defendants./

Court Division: (stltct one)

CASE NO.

CERTIFICATE OF TRIAL ATTORNEY*

Superseding Case Information:

New Defendantts)Number of New DefendantsTotal number of counts

YES NO

M iami Key W estFTL W PB X FTP

I do hereby certify that:

I have carefully considered the allegations of the indictment, the number of defendants, the number of probablewim esses and the legal complexities of the Indictment/lnformation attached hereto.

I am aware that the information supplied on this statement will be relied upon by the Judges of this Court in settil!gtheir calendars and scheduling criminal trials under the mandate of the Speedy Trial Act

. Title 28 U.S.C. Sectipn3 I 6 1 . !

lï

'

Interpreter: (Yes or No) No iList languagt and/or dialect '!

This case will take 1 5 days for the parties to try.

Please check appropriate category and type of offense listed below:

(Check only one) (Check only one)

0 to 5 days6 to l 0 daysl l to 20 days2 1 to 60 days6 1 days and over

II II I IIVV

.6 Has this case been previously filed in this District Court? (Yes or No) No :lf yes: jJudge: Case No. I(Attach copy of dispositive order !Has a complaint been filed in this matter? (Yes or No) Yes 1

IIf yes: M agistrate Case No. 14-m'-08 1 54 Si nore and Schumack :

Related Miscsllaneous numbers: n aDefendantts) ln federal custody as of 04- 16-20 14 lsignorelDefendantts) in state custody as of n/aRule 20 from the Is lc o

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

PettyM inorM isdem .Felony

X

8.

Does this case originate from a matter pending in the Northern Region of the U.S. Attorney's Office prior toOctober 14, 2003? Yes X No

iID

oes this case originate from a matter pending in the Central Region of the U.S. Attorney's Office prior yoSeptember I , 2007? Yes X No ;

S EP N CA ONASSISTANT UN ITED STATES ATTORNEYAdmin N o. A550001 1

*penalty Sheetts) attached


UNITED STATES DISTRICT COURT

SO UTH ERN DISTRICT OF FLORIDA

PENALTY SHEET

Defendant's Name: JOSEPH SIGNORE

Case No:

Count #: 1

Conspiracv to commit mail/wire fraud

18 USC 1 1349

* M ax-penalty: 20 vears' imprisonment'. $250,000 fine or twice the value of the gross gain by thedefendant or loss by the victims whichever is greater; not more than 3 vears' supervised release.

Counts # 2-1 5:

M ail Fraud

18 USC 5 1341

*M ax. Penalty: 20 years' imprisonment; $250.000 fine or twice the value of the gross gain by thedefendant or loss by the victim. whichever is areater: not more than 3 years' supervised release.

Counts # 16-24:

W ire Fraud

18 USC : 1343

*M ax. Penalty: 20 vears' imprisonments' $250.000 Fine or twice the value of the gross gain by thedefendant or loss bv the victim s whichever is Mreater: not more than 3 years' supervised release.

WRefers only to possible term of incarceration, does not include possible fines, restitution,

special assessm ents, parole terms, or forfeitures that m ay be applicable.


PEN ALTY SHEET

Defendant's Name: JOSEPH SIGNORE

Case No:

Count # 25:

Conspiracy to commit money laundering

18 USC ; 1956413)

*M ax. Penalty: 20 years' imprisonment', $500.000 fine or twice the value of the propertyinvolved in the transactio m whichever is Rreater: not more than 3 vears' supervised release.

-

Counts # 26:

Promotion m oney launderina

1 8 USC 5 1956(a)(1)(A)(i)

*M ax. Penalty: 20 vears' imprisonments' $500.000 fine or twice the value of the propertvinvolved in the transactions whichever is areater's not more than 3 years' supervised release.

Counts # 27-29:

Concealment monev laundering

18 USC 5 1956(ab(1)(Bà(ib

*M ax. Penalty: 20 years' imprisonment'. $500.000 fine or twice the value of the propertvinvolved in the transaction. whichever is greater: not more than 3 years' supervised release.

Counts # 31 , 33 & 34:

Illegal m oney spending

18 USC % 1957

*M ax. Penalty: as to each count of conviction: 10 vears' imprisonment: $250.000 fine or twicethe amount of the crim inallv derived property involved in the transaction. whichever is creater'.

not m ore than 3 years' supervised release.

*Refers only to possible term of incarceration, does not include possible fines, restitution,

special assessm ents, parole term s, or forfeitures that m ay be applicable.


UNITED STATES DISTRICT CO URT

SOUTHERN DISTRICT OF FLORIDA

PENALTY SHEET

Defendant's Name: PAUL LEW IS SCHUM ACK 11

Case No:

Count #: 1

Conspiracy to eommit mail/wire fraud

18 USC 5 1349

* M ax-penalty: 20 years' imprisonment: $250.000 fine or twice the value of the gross gain by the jdefendant or loss bv the victim. whichever is greatere' not more than 3 vears' supervised release and I

itution. irest!;

Counts # 2- 1 3:

M ail Fraud

18 USC 5 1341

*M ax. Penalty: 20 years' imprisonments' $250,000 fine or twice the value of the gross gain by the i' i d release and !defendant or loss by the victim

. whichever is greater; not m ore than 3 years superv se y

restitution. :

Counts # 17, 19-23:

18 USC 5 1343

*M ax. Penalty: 20 years' imprisonment'. $250.000 Fine or twice the value of the gross gain by thedefendant or loss by the victim. whichever is greaters' not more than 3 years' supervised release and

restitution.




PENALTY SHEET

Defendant's Name: PAUL LEW IS SCHUM ACK 11

Case No:

Count # 25:

Conspiracv to commit monev launderinz

18 U5C-179564h)

*M ax. Penalty: 20 years' imprisonment; $500,000 fine or twice the value of the propertvinvolved in the transactions whichever is greater'. not more than 3 years' supervised release.

Counts # 27 & 30:

Concealment money laundering

18 USC 5 1956(a)(l)(B)(i)

*M ax. Penalty: 20 years' imprisonment's $500.000 fine or twice the value of the propertyinvolved in the transactiom whichever is areaters' not more than 3 years' supervised release.

Count # 32:

lllegal money spending

18 USC ; 1957

*M ax. Penalty: as to each count of conviction: 10 years' imprisonments' $250,000 fine or twicethe amount of the criminally derived propeo involved in the transaction. whichever is areater'.not m ore than 3 years' supervised release.

*Refers only to possible term of incarceration, does not include possible fines, restitution.



UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

PENALTY SHEET

Defendant's Name: LAUM GRANDE-SIGNORE

Case No:

Count #: 1

Conspiracv to commit mail/wire fraud

18 USC Q 1349

# M ax.penalty: 20 years' imprisonment's $250.000 fine or twice the value of the aross aain by thedefendant or loss by the victim. whichever is areater'. not more than 3 years' supervised release and

restitution.

Counts # 14-15:

M ail Fraud i!i18 USC 5 1341 i

i*Max. Penalty: 20 years' imprisonment'. $250.000 fine or twice the value of the gross gain by the i

defendant or loss bv the victim. whichever is createrp' not more than 3 vears' supervised release and jrestitution. I

Counts # 18 & 24:

18 USC 5 1343

*M ax. Penalty: 20 years' imprisonment'. $250.000 Fine or twice the value of the gross cain by thedefendant or loss by the victim . whichever is greater; not more than 3 years' supervised release and

restitution.

WRefers only to possible term of incarceration, does not include possible fines, restitution,

special assessm ents, parole terms, or forfeitures that m ay be applicable.


PEN ALTY SHEET

Defendant's Name: LAUM GRANDE-SIGNORE

Case No:

Count # 25:

Conspiracy to commit money laundering

18 USC 9 1956th)

*M ax. Penalty: 20 years' imprisonment'. $500.000 tine or twice the value of the propertvinvolved in the transaction. whichever is greater; not more than 3 years' supervised release.

Count # 28 & 29:

Concealm ent m oney laundering

18 USC : l956(a)(1)(B)(i)

*M ax. Penalty: 20 years' imprisomnent'. $500.000 tine or twice the value of the propertvinvolved in the transaction. whichever is creater: not more than 3 years' supervised release.




UNITED STATES DISTRICT CO URT

SO UTHERN DISTRICT OF FLO RIDA

PENALTY SHEET

Defendant's Name: CRAIG HIPP

Case No:

Count #: 1

Conspiracy to commit mail/wire fraud

l 8 USC : 1349

* M ax.penalty: 20 years' imprisonment; $250.000 tine or twice the value of the aross gain by thedefendant or loss by the victims whichever is greater: not more than 3 vears' supervised release and i

Irestitution. 1'

ji

:Count # 15:

Mail Fraud

18 USC 5 1341

*M ax. Penalty: 20 years' imprisonment; $250,000 fine or twice the value of the gross gain by thedefendant or loss by the victims whichever is areater; not more than 3 years' supervised release and

restitution.

Count # 16:

W ire Fraud

18 USC 5 1343

*M ax. Penalty: 20 years' imprisonment's $250,000 fine or twice the value of the gross cain bv thedefendant or loss bv the victims whichever is greaters' not more than 3 years' supervised release andrestitution.

Wltefers only to possible term of incarceration, does not include possible fines. restitution,special assessments, parole term s, or forfeitures that m ay be applicable

.


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