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Bianca Keesler

WCC 9:30 a.m. 10:45 a.m.


Part 2 Final Investigative Plan
Jurisdiction Federal
Summary of Facts
Matthew Milkum, our main suspect, has worked for Frankie Short selling
magazine subscriptions over the phone. Milkum keeps a running list of a group of old
women who always place an order. They often forget about ordering magazines and just
mail him a check. Milkum gave them a PO Box he opened in Fordham Road Post Office
in the Bronx. His current boss, Frankie, does not know about his side income. Milkum
has another income.
Milkum has convinced fifteen (15) people to invest $500 each, totaling $7500 so
far, into buying gold. Milkum has promised them 60% returns on their money before
winter. Milkum was dismissed from his job when he went to the office and saw piles of
checks on Frankies desk.
Milkum then enlisted help from his girlfriend, Paris Spacey. Spacey is a head
teller at Campus Savings Bank. Spacey has opened fictitious name accounts along with
lines of credit to the accounts. Spaceys friend at the bank, Josie Flood, helped by
providing supporting documentation and initial deposits for the new accounts by dipping
into other customers accounts.
Spaceys bank manager, Jon Powers, approves the accounts and advances. After
accepting season tickets to the Jets, Powers agreed to approve a new line of credit for
Milkum using his Arizona property as collateral. Milkum recently repurchased the
property from Frankies brother in law. Milkum had originally sold the property to
Frankie but decided to buy it back from Frankies brother in law.

Bianca Keesler
WCC 9:30 a.m. 10:45 a.m.
Part 2 Final Investigative Plan
Spacey has been taking cash advances fro various fictitious accounts so Milkum could
form a series of companies. Milkum promised too good to be true interest rates as a
return on investments. Milkum guarantees these investments through offshore assets.
Milkum has been diverting all investor funds to himself without Spacey knowing. The
transfer of funds is done mainly by small denomination checks, with an exception of on
very large check for $55,000. He has taken some of the investor money and bought a
pizzeria in New Rochelle that his brother Bernie runs. Milkum has also purchased a new
flat screen, round sound stereo system for his car, an I-phone, and a satellite navigator
system. He has also wired some cash into an account in the Channel Islands.
Milkum has promised Spacey that he would give back all the money with interest
once business is rolling. One of the first steps that should be taken in the investigation is
to try to find the auditor Spacey wants to approach and ask to attend the meeting and then
further question her about Milkum.
Suspects

Matthew Milkum he is the main suspect in our investigation, he has committed

multiple offenses.
Paris Spacey the second suspect in our case. She has aided Milkum in most of

his bank transactions.


Jon Powers another suspect because of his acceptance of bribes while working

in a federal institution.
Josie Flood She helped Spacey by providing documentation for the fictitious
accounts by dipping into other customers accounts.

Possible Offenses Committed

18 USC 371 Conspiracy

Bianca Keesler
WCC 9:30 a.m. 10:45 a.m.
Part 2 Final Investigative Plan
o The elements are that two or more individuals conspire to defraud the U.S.
or any agency. Conspiracy is committed once the intent to commit a crime
is completed.
o In this case, Matthew Milkum, Josie Flood, Jon Powers, and Paris Spacey,
committed conspiracy once they intended to commit the other offenses

listed below.
18 USC 1344 Bank Fraud
o The elements of bank bribery are any scheme or attempted scheme to
defraud a federally insured/regulated financial institution.
o In this case, Pairs Spacey committed this when she would withdraw cash
advances from various fictitious accounts so her boyfriend, Milkum could
form multiple companies. By withdrawing from a fraudulent account, she
schemed to defraud a federally regulated financial institution.
o Spacey also committed this offense when she opened fictitious name
accounts along with lines of credit to these accounts. By opening fictitious
accounts, Spacey attempted to defraud her bank, Campus Savings.
o Josie Flood committed this offense by providing supporting
documentation and initial deposits for the accounts, opened by Spacey, by

dipping into other customers accounts.


18 USC 1005 False Entries, Reports and Transactions
o The elements of false entries, reports, and transactions are that the subject
must be officer, director, agent, or employee of a national bank, Federal
Reserve Bank, member bank or federally insured/regulated financial
institution. The subject knowingly makes or causes to be made a false
entry in a financial institutions books, reports, or statements, with intent
to deceive the bank, a bank officer, or a regulatory agency.

Bianca Keesler
WCC 9:30 a.m. 10:45 a.m.
Part 2 Final Investigative Plan
o Paris Spacey committed this offense as well as Jon Powers and Josie
Flood.
o Paris Spacey is a bank employee and knowingly made a false entry by
opening fictitious accounts and credit lines for these accounts.
o Josie Flood is also a bank employee and knowingly made a false entry by
providing documentation for the newly opened accounts by dipping into
other customers accounts.
o Jon Powers is the banks manager and knowingly agreed to approve a new

line of credit, without asking any questions, to Matthew Milkum.


18 USC 656 Bank Embezzlement/Misapplication
o The element of bank embezzlement are that the subject must be an officer,
director, agent, or employee of a national bank, Federal Reserve Bank,
member bank or federally insured/regulated financial institution. The
subject willfully embezzles or misapplies funds entrusted to the bank.
o Spacey committed this offense by taking withdrawals from various
fictitious accounts so Milkum could form a series of companies. Spacey, a
bank employee, took the money that she was entrusted without permission

for her own use to fund her boyfriends personal business ventures.
18 USC 215 Bank Bribery
o The element of bank bribery is an officer, director, agent, or employee,
corruptly solicits or accepts something of value for oneself or another,
intending to be influenced in connection with a transaction of the
institution.
o Jon Powers committed this offense when he took season tickets, from
Spacey, and agreed to approve a new line of credit for Milkum. The season
tickets were the bribe and Powers was influenced by them and allowed a

fraudulent credit line to be approved.


18 USC 1956 Financial Transaction Money Laundering

Bianca Keesler
WCC 9:30 a.m. 10:45 a.m.
Part 2 Final Investigative Plan
o The element of this statute is whoever, knowing that a property involved
in a financial transaction represents the proceeds of some from of unlawful
activity, conducts or attempts to conduct such a financial transaction
which in fact involves the proceeds of a specified unlawful activity.
o Milkum does this by taking the money he gets from investors and storing

it in offshore accounts.
18 USC 1962 Racketeer Influenced & Corrupt Organizations Act (RICO)
o The elements of this statute are an enterprise that takes part in racketeering
activity. It can be either an individual or corporation. The racketeering
activity is a fraudulent activity or collection of an unlawful debt.
o Spacey, Powers, and Flood all committed this offense when they used their
positions at Campus Bank to further their schemes. For RICO there needs
to be a pattern of racketeering activity which can be two state or federal
felonies. Each have committed two offences that have been listed above.

Interviews

Matthew Milkum Interview him on his involvement with Paris Spacey.

Interview him about his magazine job and his dealings in the gold market.
Pairs Spacey Convince her to testify against Milkum and to possible wear a wire

in order to get Milkum to incriminate himself while they are talking.


Jon Powers He could testify to taking a bribe from Spacey in order to give more
credit to Milkum. He could talk about what Spacey does in the bank and give any
information about any recent accounts she has opened.

Possible Questions to Ask

Why did Milkum choose to open the offshore accounts?


How much money is currently in these accounts?
How much is Milkum currently earning?
What are his companies? What do they specialize in?
When was the SAR filed and by whom?

Bianca Keesler
WCC 9:30 a.m. 10:45 a.m.
Part 2 Final Investigative Plan
How much money is taken out of the customer accounts that Josie had access to?
What is Milkums goal?
Sources of Evidence

Gather all financial documents, via subpoena, such as:


o DMV records
o Withdrawal and deposit slips of the fictitious accounts
o Any documentation about the accounts
o Milkums and Spaceys financial records
o Any bank statements regarding the accounts
o Any books or reports about the accounts and credit lines attached to them
form the bank
Check for prior convictions against Milkum, Powers, Spacey, and Flood

Cooperating Witnesses:

Frankie Short He will be a good witness because he can testify to how Milkum
was as a worker. He can also testify he and his girlfriend, Lily, and her family

helped Milkum
Josie Flood She will be a good person to testify against Paris Spacey. She can
also admit to providing supporting documentation for fictitious accounts that
Spacey opened. She can also testify that she did this by dipping into other

customers accounts.
Jim Blank he would be a good witness to question, especially about who he has
not notice anything out of the ordinary with Campus Banks finances. He could
also help explain the technicalities of what both Josie Flood and Paris Spacey are
doing.

One of the biggest flight concerns would be Matthew Milkum. He has proven that he has
the means to flee the country should he need to. He is a big concern because he has the
money that can help him get out of the country. We would be willing to seek the

Bianca Keesler
WCC 9:30 a.m. 10:45 a.m.
Part 2 Final Investigative Plan
cooperation of Paris Spacey in our investigation, one of the main reasons being her close
relationship with Milkum. She knows a great deal of information about Milkum and the
accounts he holds. She is also upset with him so she could be willing to give up more
information to possibly get back at him. Any information she would willingly give would
gain her a lesser sentence for the offenses she is convicted. It will show her cooperation
with our investigation, which we could tell the D.A. and the court.