WES^®
NOV T. 0.2019 UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF LOUISIANA
MONROE DIVISION
UNITED STATES OF AMERICA * CRIMINAL NO.A
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VERSUS **
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DONNIE LAING, JR. *
3:19-cr-00364Judge DoughtyMagistrate Judge Hayes
INDICTMENT
THE GRAND JURY CHARGES:
COUNTS 1-9Wire Fraud
18 U.S.C. § 1343
At all times material to this Indictment:
1. The defendant, DONNIE LAING, JR., was a resident of the Western
District of Louisiana.
2. A Ponzi scheme is a financial fraud whereby an operator induces
investments from individuals (the Ponzi Investors") by promising high investment
returns with little or no risk of loss. In a Ponzi scheme, new investor proceeds are
fraudulently converted to an operator s own personal use and benefit and used to pay
fabricated returns to previous investors, under the guise that such monies represent
1
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legitimate returns on investment. A Ponzi scheme cultivates an illusion that
legitimate profit-making business opportunities exist, thereby inducing further
investment.
3. The Ponzi Investors lived and conducted business primarily in
Northeast Louisiana.
4. Capital Energy Investments (Capital), was a Louisiana limited
liability company, formed on or about February 10, 2017, with a registered address
of 1109 Jules Broussard Road, Breaux Bridge, Louisiana, whose sole member and
registered agent was the defendant, DONNIE LAING, JR.
5. Capital held a business account with Iberia Bank, a regional bank
headquartered in Lafayette, Louisiana and operating in multiple states throughout
the southeast United States.
THE SCHEME AND ARTIFICE TO DEFRAUD
6. Beginning on or before April 16, 2018, and continuing through on or
after November 1, 2018, in the Western District of Louisiana and elsewhere, the
defendant, DONNIE LAING, JR,, did knowingly and unlawfully devise and intend to
devise a scheme and artifice to defraud and to obtain money from multiple investors
by means of false and fraudulent pretenses, representations, and promises. For the
purposes of executing and attempting to execute the scheme and artifice to defraud,
the defendant, DONNIE LAING, JR., aided and abetted by "Individual A" and other
persons both known and unknown to the Grand Jury, did knowingly utilize and cause
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others to utilize interstate wire communication facilities, including bank-to-bank
wire transfers, to send and receive monies representing the proceeds of the scheme
to defraud in violation of 18 U.S.C. § 1343. The scheme and artifice to defraud was
as follows:
7. It was part of the scheme and artifice to defraud that the defendant,
DONNIE LAING, JR., formed a business relationship with "Individual A", an
associate living in northeast Louisiana, who was well-known in the City of Monroe
and throughout northeast Louisiana due to his former position as a United States
Congressman.
8. It was further part of the scheme and artifice to defraud that the
defendant, DONNIE LAING, JR., enlisted the assistance of "Individual A", to solicit
money from the Ponzi Investors to, among other things, invest in Capitals purported
purchase of oil and gas equipment for use in "tracking wells.
9. It was further part of the scheme and artifice to defraud that, in
soliciting these monies, DONNIE LAING, JR. falsely and fraudulently represented
to the Ponzi Investors that he had contracts and relationships with oil and gas
companies that would allow Capital to earn high rates of return by purchasing oil
and gas equipment and then leasing such equipment to oil and gas companies
engaged in oil and gas exploration activities.
10. It was further part of the scheme and artifice to defraud that the
defendant, DONNIE LAING, JR., did not invest any of the money transferred to him
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by the Ponzi Investors into the promised investments. Instead, DONNIE LAING,
JR., used the Ponzi Investors' money for his own purposes.
11. It was further part of the scheme and artifice to defraud that in
executing and attempting to execute this scheme, the defendant, DONNIE LAING,
JR., created and distributed to the Ponzi Investors false and fraudulent proposals,
contracts, and other documents to induce the Ponzi Investors to remit funds to him.
12. It was further part of the scheme and artifice to defraud that the
defendant, DONNIE LAING, JR., provided certain Ponzi Investors with monetary
payments ("lulling payments") that he fraudulently represented were returns on
investment from their alleged investments; knowing instead that these payments
were actually investment monies provided by other Ponzi Investors. In this manner,
DONNIE LAING, JR., funneled new investor funds to previous investors under the
guise of legitimate profits and returns, thereby inducing further investment.
13. It was further part of the scheme and artifice to defraud that the
defendant, DONNIE LAING, JR., wrongfully obtained a cumulative amount in excess
of $1 million from the Ponzi Investors.
14. It was further part of the scheme and artifice to defraud that in
executing and attempting to execute this scheme, the defendant, DONNIE LAING,
JR., utilized and caused others to utilize interstate wire communication facilities,
including email and inter-bank wire transfers as means of communicating with
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Individual A and the victims of the offense, and to send and receive monies
representing the proceeds of the scheme to defraud.
THE CHARGES
14. On or about the dates listed below, in the Western District of Louisiana
and elsewhere, the defendant, DONNIE LAING, JR., having devised and intending
to devise a scheme and artifice to defraud and to obtain money as described above by
means of false and fraudulent pretenses, representations, and promises, and for the
purposes of executing and attempting to execute the above described scheme and
artifice to defraud, did knowingly utilize and cause others to utilize interstate wire
communication facilities, including inter-bank wire transfers and other means, to
send and receive monies representing the proceeds of the scheme to defraud, each
transmission constituting a separate count:
COUNT DATE
April 25, 2018
June 1, 2018
June 7, 2018
DESCRIPTION
Interstate wire transfer of $175,000 fromPonzi Investor to a Capital account at IberiaBank.
Interstate wire transfer of $135,265.50 fromPonzi Investor to a Capital account at IberiaBank.
Interstate wire transfer of $135,265.50 fromPonzi Investor to a Capital account at IberiaBank.
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6
9
June 19, 2018
Sept. 10, 2018
Sept. 12, 2018
Sept. 14, 2018
Sept. 19, 2018
Interstate wire transfer of $325,000 fromPonzi Investor to a Capital account at IberiaBank.
Interstate wire transfer of $100,000 fromPonzi Investor to a Capital account at IberiaBank.
Interstate wire transfer of $130,000 fromPonzi Investor to a Capital account at IberiaBank.
Interstate wire transfer of $70,000 from PonziInvestor to a Capital account at Iberia Bank.
Interstate wire transfer of $100,000 fromPonzi Investor to a Capital account at IberiaBank.
Interstate wire transfer of $45,000 from PonziInvestor to a Capital account at Iberia Bank.
Oct. 19, 2018
all in violation of Title 18, United States Code, Section 1343. [18 U.S.C. § 1343].
A TRUE BILL:
FOREPERSON: FEDERAL GRAND JURY
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