Free Redacted Document - District Court of Delaware - Delaware

Case 1:06-cr-00125-SLR

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, Plaintiff, v. TERESA M. FLOOD, Defendant. Criminal Action No. 06

SUPERSEDING INDICTMENT
The Grand Jury for the District of Delaware charges that:

COUNT ONE Scheme to Defraud
1.

In or around November 2004, Teresa M. Flood, the defendant, purchased a 2005

~ c u r TL fiom a car dealership in Delaware. In connection with the purchase, the defendant a applied for a car loan through the dealership. 2.

In applying for the loan, Teresa M. Flood, the defendant, submitted false

employment and income information.
3.

Based on the application containing the false information, in or around December

2004, Teresa M. Flood, the defendant, obtained a car loan which she used to purchase the 2005 Acura TL.

Charging Paragraph
4. On or about November 30,2004, in the District of Delaware, having devised and

intending to devise a scheme and artifice to defraud, as described in paragraphs one through three above, incorporated herein by reference, and for the purpose of executing such scheme and

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artifice to defraud, Teresa M. Flood, the defendant, did knowingly transmit or cause to be transmitted by means of wire in interstate commerce a facsimile from The UPS Store in Maryland to the Castle Dealerships in Delaware, all in violation of Title 18, United States Code, Section 1343.
COUNT TWO
Introduction

5,

At all times relevant to this Indictment, Wells Fargo Bank was a federally insured

financial institution, the deposits of which were insured by the Federal Deposit Insurance Corporation or FDIC.
Scheme to Defraud 6.

In or around the Fall of 2005, Wells Fargo Bank sent a credit offer to Genesis

Investors Group at an office complex in Cinnaminson, New Jersey. Genesis Investors Group was a fictitious company that had been set up by G.C., HI. 7. In or around November 2005, G.C., HI, using the name and Social Security

number of J.F. (without the knowledge andlor authorization of J.F.) and the company name Genesis Investors Group, responded to the credit offer by applying for a $30,000 line of credit with Wells Fargo Bank.

8.

Based on the application containing the false identity information, Wells Fargo

Bank approved a $30,000 line of credit for J.F. of Genesis Investors Group at the Cinnaminson, New Jersey address.

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9.

On or about January 17,2006, a $15,000 check was written off the line of credit.

On or about January 18,2006, the $15,000 check was deposited into a bank account in Delaware held solely by Teresa M. Flood, the defendant, in the name Agape Ventures. 10.

On or about January 23,2006, Teresa M. Flood, the defendant, used a portion

of the money that had been deposited into the Agape Ventures bank account to pay the rent for the Cinnarninson, New Jersey office to which the original offer from Wells Fargo Bank had been sent. Within a month, all but a few hundred dollars of the money was withdrawn from Teresa M. Flood's account via ATM withdrawals, checks, and check card purchases.
Charging Paragraph

11.

From in or around November 2005 through in or around February 2006, in the

District of Delaware and elsewhere, G.C., 111, aided and abetted by Teresa M. Flood, the defendant, did knowingly execute and attempt to execute a scheme and artifice to defraud Wells Fargo Bank, a federally insured financial institution, as described more fully in paragraphs 5 through 10 above, incorporated herein by reference, and in execution of the scheme, on or about January 17,2006, a $15,000 check off a Wells Fargo Bank line of credit was deposited into the defendant's bank account, all in violation of Title 18, United States Code, Sections 1344 and 2.
COUNT THREE

12.

From in or around November 2005, through in or around January 2006, in the

State and District of Delaware, G.C., 111, aided and abetted by Teresa M. Flood, the defendant, did knowingly use, without lawful authority, a means of identification of J.F. during and in relation to a violation of the bank fraud statute, 18 U.S.C. 1344, as described in paragraphs 5

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through 10 above, incorporated herein by reference, all in violation of Title 18, United States Code, Sections 1028A and 2. COUNT FOUR

Scheme and Artzjice to Defraud
13.

In or around February 2006, G.C., Ill, using the name "Michael Fuller" and the

Social Security number of J.H., contacted Aggressive Mortgage in Maryland and inquired about obtaining a mortgage for a residential property in Delaware. 14. Sometime later in February 2006, G.C., 1 1 using the name "Michael Fuller" and 1,

the Social Security number of J.H., went to Aggressive Mortgage and filled out a mortgage loan application. In connection with the application, G.C., Ill submitted false identity information and false employment information. 15. Based on the information he had submitted, Aggressive Mortgage pre-qualified

G.C., Ill as "Michael Fuller" with the Social Security number of J.H., for a $399,900 mortgage. 16.

In or around March 2006, Teresa M. Flood, the defendant, called a real estate

agent in Delaware and scheduled a time for herself and for G.C., Ill, using the name "Michael Fuller" and the Social Security number of J.H., to view residential properties. Also in or around March 2006, Teresa M. Flood, the defendant, and G.C., 1 1met with a real estate agent in 1 Delaware, viewed three residential properties that were listed for sale, and chose to purchase one of the properties. 17. On or about March 8,2006, L.R. and G.C., 1 1went to the office of the real estate 1

agent in Delaware. While at the office, G.C., Ill, using the name "Michael Fuller" and the Social Security number of J.H., signed an agreement of sale to purchase a residential property for

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$399,900 and provided a deposit for the property. The check for the deposit was written off an account held solely by Teresa M. Flood, the defendant, in the name T and T Enterprise. 18. During that same meeting, at G.C., ID'S request, Aggressive Mortgage sent via

facsimile to the real estate agent's office a letter stating that G.C., 111, as "Michael Fuller", had been approved for a purchase loan in the amount of $399,900. 19. The seller of the property accepted the offer and took the property off the market.

Charging Paragraph 20.

On or about March 8, 2006, in the State and District of Delaware, having devised

and intending to devise a scheme and artifice to defraud, as described in paragraphs 13 through 19 above, incorporated herein by reference, and for the purpose of executing such scheme and artifice to defraud, G.C., IU, aided and abetted by Teresa M. Flood, the defendant, did knowingly cause a facsimile to be transmitted by means of wire in interstate commerce from the offices of Aggressive Mortgage in Maryland to the offices of ReMAX Metrostar in Delaware, all in violation of Title 18, United States Code, Sections1343 and 2.
COUNT FIVE

21.

From in or around February 2006, through in or around March 2006, in the State

and District of Delaware, G.C., 111, aided and abetted by Teresa M. Flood, thedefendant, did knowingly use, without lawful authority, a means of identification of J.H. during and in relation to a violation of the wire fraud statute, 18 U.S.C. 1343, as described in paragraphs 13 through

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19 above, incorporated herein by reference, all in violation of Title 18, United States Code, Sections 1028A and 2.

A TRUE BEL:

COLM F. CONNOLLY United States Attorney

Foreperson

-,-*,,

BY:

-

Beth Moskow-Schnoll Assistant United States Attorney

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Dated: August 28,2007