Operation Reveal The Deal Exhibits

STATE OF FLORIDA COUNTY OF SEMINOLE SEIZURE AFFIDAVIT Your affiant, Captain James Sammy Gibson being duly sworn
states the following: 1. Your Affiant is a duly sworn deputy sheriff with the Seminole County Sheriff's
Office and has been duly sworn since 1980. During your affiants 33 year career in law enforcement, he has authored, reviewed, supervised, and/or participated in several thousand investigations, several thousand search warrants both state and federal, thousands of arrests, and the seizure of millions of dollars in illegal assets. Your affiant through his
investigations has been responsible for the successful prosecution and/or supervised the successful prosecution of defendants in both state and federal court for violations of R.I.C.O. and R.I.C.O. Conspiracy in violation of Florida State Statute 895 et. seq. and Title 18 United State Code 1961. Your affiant has also been certified as an expert witness in U.S. District Court, Middle District of Florida, Orlando Division, in wire- tap and drug investigations. Your affiant has also been certified as an expert witness in the Circuit Court for the 18th Judicial Circuit in and for Seminole County, Florida in the aerial detection of marijuana and the visual identification of marijuana. 2. This investigation is being conducted by the Seminole County Sheriffs Office
(SCSO), Volusia County Sheriffs Office (VCSO), Florida Department of Law Enforcement (FDLE), Internal Revenue Service (IRS),United States Secret Service, and Jacksonville Sheriffs Office (JSO). Your affiant has personally participated in this investigation and is thoroughly familiar with the information contained in this affidavit either through personal investigation or through discussions with other law enforcement personnel assigned to this
investigation. The following information is derived from your affiants review of documents and financial records related to this investigation, your affiants personal observations, as well as the review of reports of, and discussions with, other investigators, state and federal, who have personal knowledge of the matters covered in this investigation. All the facts set forth below are true and correct to the best of your affiants knowledge. This information set forth herein is not intended to be exhaustive, or to include all relevant information known to investigators but to establish probable cause. 3. Because this affidavit is being submitted for the limited purposes of establishing
probable cause, your affiant has not included every detail of every aspect of the investigation for this affidavit. Rather, it only includes the information necessary to prove that probable cause exists for the issuance of seizure warrants and Lis Pendens for the contents of the below-described accounts and/or property, which are the proceeds of violations of Florida State Statute 849. Et. Seq. (Illegal Gambling) and 895.03 (R.I.C.O.) and/or were involved in or are traceable to Florida State Statute 896. Et. Seq. (Money Laundering) violations and such assets are therefore subject to forfeiture pursuant to Florida State Statute 895.05(3) and 932.702. I. 4. Legal Basis for Seizure This affidavit is made in support of application for seizure warrants and Lis
Pendens for the contents of the financial accounts listed in Attachment 1 of this Seizure Affidavit, the personal property listed in Attachments 2 and the real property listed in Attachment 3 of this Seizure Affidavit. As set forth in this Seizure Affidavit and the Master Affidavit, there is probable cause to believe that the contents of the financial accounts listed in Attachment 1 of this affidavit and the personal property listed in Attachments 2 and the real
property listed in Attachment 3 of this affidavit constitute property involved in or traceable to Gambling violations, R.I.C.O. violations, and Money Laundering by members of the AVOTW Enterprise as described in your affiants Master Affidavit. 5. The Courts authority to order forfeiture of property for violations of F.S. 849 Et.
Seq., F.S. 895 Et. Seq., and 896 Et. Seq. is found within F.S. 895.05(3) and F.S. 932.702. Florida Statute 932.702 provides for the forfeiture of any property, real or personal, which constitutes or is derived from proceeds from any offense constituting specified unlawful activity as defined in F.S. 896.101, or conspiracy to commit such offenses. A specified unlawful activity as defined in 896.101 includes offenses listed in F.S. 895.02. Specifically, F.S. 895.02 includes as an offense, any act which is chargeable under F.S. 849 Et. Seq. and/or F.S. 896 Et. Seq. II. Overview 6. Your affiant has submitted a Master Affidavit in this investigation that sets forth
information obtained and learned during the course of the investigation about the gambling and money laundering operation and the racketeering activities involving members of the AVOTW Enterprise. Your affiants Master Affidavit is hereby re-alleged and incorporated herein by reference. The Master Affidavit fully sets forth the factual basis to support a
probable cause determination that members of the AVOTW Enterprise are engaging in racketeering activities to include: illegal use of gaming devices, conducting illegal lotteries, keeping and/or maintaining gambling houses, then laundering the proceeds through the bank accounts listed in this affidavit. 7. Allied Veterans of the World Inc. and Affiliates and members of the AVOTW
Enterprise currently operate approximately forty-nine (49) Gambling Centers which allegedly
sell internet time and offer free sweepstakes with the purchase of internet time. However, as explained more fully in your affiants Master Affidavit, these entities are actually engaged in the operation of illegal gambling businesses, in violation of F.S. 849. Et. Seq and F.S. 895.03. As a result, between 2007 and present, the AVOTW Enterprise to include Allied Veterans Management Group (Allied Management), AVOTW Affiliates, and it co-conspirators have deposited over $300 million dollars in gambling proceeds into their bank accounts. III. 8. Basis for Seizure of Affiliate Bank Accounts From on or about 2007 through on or about April 30, 2012, each gambling
center that used the Allied Veterans name was numbered (i.e., Allied Veterans Affiliate 31, Allied Veterans Affiliate 32, etc.). As a corporate entity, Allied Veterans has no role in the day-to-day operation or management of any of the Gambling Centers. Instead, each
gambling center that uses the Allied Veterans name is operated by members of the AVOTW Enterprise that own for-profit corporations. On or about April 30, 2012 to present the AVOTW gambling centers have changed their names from the AVOTW Affiliates to new, for-profit entity names in an effort to further conceal and disguise the illegal enterprise. 9. From on or about 2007 through on or about April 30, 2012, each gambling
center Affiliate location had a separate bank account located at Bank of America. Instead of the accounts being held in the name of the for- profit corporation that is actually operating the gambling center, each of them was opened using the name of the Affiliate from which the proceeds were deposited in order to further disguise the fact that a for profit corporation was actually operating that gambling center. Former National Commander Johnny Duncan is the sole signatory on all or most all of these bank accounts. As discussed in your affiants Master Affidavit, the Affiliates appear to do nothing more than serve as a conduit to distribute
the proceeds from the Gambling Centers to those involved in the illegal gambling operation. The Affiliate bank accounts subject to forfeiture are as follows: Chart 1: Affiliate Bank Accounts Bank Name Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America
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Account #
Account Name Affiliate 31 Affiliate 32 Affiliate 34 Affiliate 35 Affiliate 36 Affiliate 37 Affiliate 38 Affiliate 39 Affiliate 40 Affiliate 41 Affiliate 42 Affiliate 43 Affiliate 44 Affiliate 45 Affiliate 46 Affiliate 47 Affiliate 49 Affiliate 50
Address on Account PO Box 160939, Boiling Springs, SC, 29316-0016 814 N Nova RD Apt 1529 Daytona Beach, FL 32117-4616 PO Box 160939, Boiling Springs, SC, 29316-0016 PO Box 160939, Boiling Springs, SC, 29316-0016 PO Box 160939, Boiling Springs, SC, 29316-0016 PO Box 160939, Boiling Springs, SC, 29316-0016 PO Box 160939, Boiling Springs, SC, 29316-0016 PO Box 160939, Boiling Springs, SC, 29316-0016 PO Box 160939, Boiling Springs, SC, 29316-0016 PO Box 160939, Boiling Springs, SC, 29316-0016 PO Box 160939, Boiling Springs, SC, 29316-0016 PO Box 160939, Boiling Springs, SC, 29316-0016 PO Box 160939, Boiling Springs, SC, 29316-0016 PO Box 160939, Boiling Springs, SC, 29316-0016 PO Box 160939, Boiling Springs, SC, 29316-0016 PO Box 160939, Boiling Springs, SC, 29316-0016 PO Box 160939, Boiling Springs, SC, 29316-0016 PO Box 160939, Boiling Springs, SC, 29316-0016
Signors on Account Johnny Duncan Johnny Duncan Johnny E Duncan, Linda A Duncan Johnny E Duncan, Linda A Duncan Johnny E Duncan, Linda A Duncan Johnny E Duncan, Linda A Duncan Johnny E Duncan, Linda A Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny E Duncan, Linda A Duncan Johnny E Duncan, Linda A Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan
Bank Name Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America
Account #
Account Name Affiliate 51 Affiliate 52 Affiliate 53 Affiliate 54 Affiliate 55 Affiliate 56 Affiliate 57 Affiliate 58 Affiliate 59 Affiliate 60 Affiliate 61 Affiliate 63 Affiliate 65 Affiliate 67 Affiliate 68 Affiliate 70 Affiliate 71 Affiliate 72 Affiliate 74 Affiliate 76 Affiliate 77
Address on Account 415 N Grove ST, Eustis, FL 32726-3427 7269 Forest Oaks Blvd, Spring Hill, FL 34606-2330 7130 W Tennessee Street, Tallahassee, FL 32304-9324 401 Barton Blvd, Rockledge, FL 32955-2709 PO Box 160939, Boiling Springs, SC, 29316-0016 PO Box 160939, Boiling Springs, SC, 29316-0016 PO Box 160939, Boiling Springs, SC 16093 6450 N Wickham RD STE 100, Melbourne, FL 32940-2036 PO Box 160939, Boiling Springs, SC, 29316-0016 1150 Malabar Rd SE Ste 101, Palm Bay, FL 32907-3239 50 Plaza DR STE 201, Palm Coast, FL 32137 PO Box 160939, Boiling Springs, SC, 29316-0016 933 14th LN, Vero Beach, FL 32960-4736 PO Box 160939, Boiling Springs, SC, 29316-0016 231 Koolabrew Dr NW, Calabash, NC 28467-1937 501 N Beneva Rd Ste 500, Sarasota, FL 34232-1313 266 Blanding Blvd STE 1, Orange Park, FL 32073-3343 4158 NW 13th ST, Gainesville, FL 32609-1864 944 State Road 436, Casselberry, FL 32707-5633 13920 Palm Beach BLVD, Fort Myers, FL 33905-2138 PO Box 160939, Boiling Springs, SC, 29316-0016
Signors on Account Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny E Duncan, Linda A Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny E Duncan, Linda A Duncan Johnny Duncan Johnny Duncan Johnny E Duncan, Linda A Duncan Johnny Duncan Johnny E Duncan, Linda A Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan
Bank Name Bank of America Bank of America Bank of America Bank of America Bank of America
Account #
Account Name Affiliate 78 Affiliate 79 Affiliate 81 Affiliate 85 Affiliate 86
Address on Account 1965 State Road 16, Saint Augustine, FL 32084-0811 PO Box 160939, Boiling Springs, SC, 29316-0016 185 Carter Road, Palatka, FL 32177-8625 PO Box 180938, Boiling Springs, SC 29316 PO Box 160939, Boiling Springs, SC, 29316-0016
Signors on Account Johnny Duncan Johnny Duncan, Linda Duncan Johnny E Duncan, Linda A Duncan Johnny Duncan Johnny Duncan, Linda Duncan
10.
From on or about 2007 through on or about April 30, 2012, for each Affiliate,
the proceeds of the gambling operation were collected every day and deposited into each Affiliates bank account. An analysis of the amount of gambling proceeds withdrawn from the Affiliates accounts per the ERG documents previously described in the Master Affidavit is listed below. It should be noted that the withdrawals represent only 90% of the total amount of illegal proceeds that were deposited into the accounts from the date the respective account was opened through January 5, 2012.
Chart 2: Gambling Proceeds Withdrawn from Affiliate Accounts

Sum of Amount Year Receiving Accoun 2008 TOTAL DEBIT FROM AFFILIATE $ 52,888,846.34 7 31 $ 2,247,394.90 32 $ 1,697,806.53 33 $ 6,309,086.19 34 $ 3,709,139.43 35 $ 3,092,382.03 36 $ 1,280,691.61 37 $ 2,360,015.02 38 $ 3,724,491.53 39 $ 1,309,257.39 40 $ 1,606,062.03 41 $ 3,233,692.54 42 $ 3,487,724.02 43 $ 3,733,120.76 44 $ 1,089,042.52 45 $ 1,000,339.75 46 $ 8,802.70 47 $ 489,839.37 48 $ 190,381.50 49 $ 1,742,778.08 50 51 $ 3,578,563.66 52 $ 3,029,995.00 53 54 $ 2,100,255.34 55 $ 11,451.79 56 $ 1,187,162.37 57 58 $ 78,548.28 59 $ 586,603.89 60 61 62 $ 4,218.11 63 65 66 67 68 70 71 72 74 76 77 78 79 80 81 83 84 85 86 87 90 Grand Total $ 52,888,846.34 7 2009 $ 70,964,167.57 $ 2,506,253.81 $ 2,299,507.13 $ 5,420,561.68 $ 3,850,665.74 $ 3,540,759.55 $ 2,298,226.72 $ 2,572,904.34 $ 3,706,897.75 $ 1,428,240.26 $ 1,252,964.63 $ 3,007,226.22 $ 1,792,654.83 $ 4,401,540.98 $ 2,784,347.46 $ 1,645,871.55 $ 323,182.09 $ 310.15 $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ 1,290,898.10 782,029.46 3,484,942.32 3,400,290.59 1,949,749.24 1,055,757.27 2,243,904.76 110,820.54 1,155,588.97 2,615,424.66 613,927.91 667,703.20 81,478.71 370,063.52 2,759,284.11 2,853,791.66 1,142,852.59 303,395.24 1,071,642.67 178,507.16 2010 $ 89,824,624.05 $ 2,578,908.34 $ 2,383,637.30 $ 4,612,937.68 $ 4,004,027.92 $ 4,012,765.78 $ 2,348,139.77 $ 2,308,104.60 $ 4,223,698.39 $ 1,610,449.38 $ 1,238,897.11 $ 3,055,031.05 $ 542,061.85 $ 5,216,226.64 $ 2,922,248.20 $ 2,097,457.50 $ 699,384.60 $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ 2011 $ 1 3,916,010.00 $ 3,157,961.10 $ 2,537,498.59 $ $ $ $ $ $ $ $ $ $ $ $ $ $ 4,271,049.11 3,951,835.35 2,542,377.04 2,200,648.88 4,165,381.00 2,001,097.45 1,294,909.51 3,135,752.11 1,055,531.60 4,449,452.82 2,964,481.95 1,854,109.23 871,276.03 98,942.07 1,209,063.12 1,922,076.17 3,389,284.05 993,175.08 2,089,901.38 1,489,824.35 2,177,588.58 20,302.41 1,687,849.26 2,584,362.74 1,473,165.22 1,433,662.66 147,261.19 1,194,242.87 5,040,207.09 4,372,925.20 381,095.71 2,529,340.69 3,087,937.67 3,752,386.05 540,954.18 201,502.88 2012 $ 2,991,083.09 $ 65,765.00 $ 54,855.92 $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ 88,649.97 89,674.37 56,807.06 49,115.07 93,613.74 44,578.46 32,216.22 62,783.33 25,325.65 101,294.93 54,702.29 54,278.63 12,159.92 6,935.76 30,928.39 43,332.00 84,974.84 29,707.01 44,388.70 40,434.88 54,638.34 6,657.09 44,724.50 59,573.60 36,818.40 31,553.29 10,898.48 34,331.38 119,793.37 104,474.38 2,998.67 73,407.17 74,038.70 83,043.44 8,251.33 5,966.13 33,497.02 29,753.92 4,852.49 5,289.25 Grand Total $ 89,584,731.05 $ 10,556,283.15 $ 8,973,305.47 $ 16,342,585.55 $ 15,923,532.17 $ 14,687,417.08 $ 8,526,242.20 $ 9,490,787.91 $ 15,914,082.41 $ 6,393,622.94 $ 5,425,049.50 $ 12,494,485.25 $ 6,903,297.95 $ 17,901,636.13 $ 9,814,822.42 $ 6,652,056.66 $ 1,914,805.34 $ 596,027.35 $ 190,381.50 $ 4,124,471.02 $ 3,381,629.05 $ 9,091,250.35 $ 13,527,341.08 $ 1,022,882.09 $ 8,192,576.46 $ 3,991,843.08 $ 7,996,064.20 $ 137,780.04 $ 4,523,827.72 $ 8,943,946.05 $ 2,967,226.36 $ 3,410,809.69 $ 85,696.82 $ 158,159.67 $ 2,421,997.61 $ 2,759,284.11 $ 13,470,695.44 $ 9,160,504.61 $ 1,133,011.22 $ 2,602,747.86 $ 7,318,276.66 $ 7,081,700.70 $ 1,250,732.67 $ 207,469.01 $ 203,396.21 $ 448,351.38 $ 281,453.78 $ 759,666.93 $ 26,806.91 $ 34,681.64 $ 43,223.88 $ 107,536.96 $ 11,785.23 $ 5,483.58 $ 89,584,731.05
1,090,794.84 1,359,608.08 $ 62,336.20 $ 3,622,796.60 $ $ 2,008,281.80 $ 1,394,374.79 $ 2,332,770.15 $ $ 1,557,116.71 $ 3,097,981.16 $ 843,314.83 $ 1,277,890.54 $ 823,359.84 5,456,903.32 3,540,252.44 445,521.60 3,084,657.62 3,246,271.21 523,020.00 203,396.21 $ $ $ $ $ $ $ $ $ $
$ 70,964,167.57
$ 89,824,624.05
$ 414,854.36 $ 281,453.78 $ 729,913.01 $ 26,806.91 $ 34,681.64 $ 38,371.39 102,247.71 $ $ 11,785.23 $ 5,483.58 $ 1 3,916,010.00
$ 2,991,083.09
*The 2012 column reflects transactions on Jan. 5, 2012 only
11.
An analysis of the bank records associated with each Affiliate Account indicates
that the only funds that have been deposited into the above-referenced accounts are the funds that were collected each day from each Affiliates gambling operation. No other funds, other than those funds obtained as a result of illegal gambling, have been deposited into these accounts except for the initial account opening deposit(s). Accordingly, all of the funds contained within these accounts represent the proceeds obtained from an illegal gambling business, in violation of F.S. 849 Et. Seq. and F.S. 895.03. Therefore, all of the funds in the above-referenced accounts are subject to forfeiture pursuant to F.S. 895.05(3) and F.S. 932.702. 12. As previously stated, on or about April 30, 2012, AVOTW allegedly sold the
gambling centers to non-affiliated corporations. It has been determined that after the alleged sale of the Affiliates, the AVOTW Enterprise quit making deposits into the Affiliate bank accounts and began making daily deposits into newly named bank accounts or bank accounts in the name of existing for-profit corporations. Although the AVOTW Enterprise quit using the Affiliate bank accounts to transfer their illegal proceeds, they continue to transfer the illegal proceeds in virtually the same manner. A financial analysis of bank records from August 1, 2012 through September 30, 2012 shows that the gambling centers still pay Allied Veterans Management Group Inc. and I.I.T. on a weekly basis. The analysis shows that some of the gambling centers still utilize ERG to transfer illegal proceeds on a weekly basis and other gambling centers transfer the proceeds electronically or write checks to Allied Veterans Management Group Inc. and I.I.T. on a weekly basis.
13.
The following chart reflects the deposits made to Allied Veterans Management
account from the accounts that replaced the Affiliate accounts. The financial analysis and chart is for the time frame of August 2012 through September 2012. Chart 3: Amount Transferred into Allied Veterans Management Account 2012 September 2012 (Electronic Deposits) Electronic Deposits From Allied Veterans 31 Allied Veterans 35 Allied Veterans 36 Allied Veterans 50 Allied Veterans 58 Allied Veterans 60 Allied Veterans 65 Allied Veterans 75 Business Center Capital City Internet Seaside Internet Location 34 Account (Deposits in name of Elite 34) Coastal Games Account (Deposits in name of Elite 35) Coastal Games Account (Deposits in name of Elite 36 Bearcon Management Account (Deposits in name of Elite 37) M&S Management Account (Deposits in name of Elite 38) Seaside Internet Location 43 Account (Deposits in name of Elite 43) B&M Leasing & Management Account (Deposits in name of Elite 44) (Deposits in name of Elite 55) Seaside Internet - Marion Account (Deposits in name of Elite 57) Seaside Internet Marion Account (Deposits in name of Elite 63 Seaside Internet Location 68 Account (Deposits in name of Elite 68) Free Entry Clay County Account (Deposits in name of Elite 71)
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August
Sum of Amount $ 25,167.58 $ 29,114.89 $ 15,745.00 $ 6,848.82 $ 20,624.63 $ 15,297.84 $ 9,085.40 $ 1,270.97 $ 8,889.07 $ 8,760.52 $ $ $ $ $ $ $ $ $ $ $ $ 21,982.09 2,130.37 220.59 12,326.96 22,581.32 24,690.23 19,188.47 11,036.69 1,605.56 1,673.46 27,351.92 22,066.91
Electronic Deposits From Seaside Internet Putnam Account (Deposits in name of Elite 81) Gainesville Internet Gulf Internet J&R Business Center Lake City Internet Live Oak Internet Tparker Management Grand Total 14.
Sum of Amount $ $ $ $ $ $ $ $ 7,138.23 17,499.42 7,514.18 1,703.35 13,409.02 7,126.45 779.58 362,829.52
Your affiant believes the funds in the above listed accounts are the daily
proceeds of the illegal gambling centers. Accordingly, all of the funds contained within these accounts represent the proceeds obtained from an illegal gambling business, in violation of F.S. 849 Et. Seq. and F.S. 895.03. Therefore, all of the funds in the above-referenced accounts are subject to forfeiture pursuant to F.S. 895.05(3) and F.S. 932.702. IV. 15. Basis for Seizure of Allied Veterans Accounts to include I.I.T. Accounts From on or about 2007 through on or about April 30, 2012, the bank and
financial records show that every seven (7) days, the gambling proceeds deposited into the Affiliates Bank of America Accounts were automatically transferred by wire through a Payroll Company, Employers Resource Group (ERG), as follows: Allied Management Group Inc. which is a for-profit corporation receives approximately 10% (prior to April 2009, Allied Veterans received approximately 9.75% ); International Internet Technologies (ITT) receives approximately 22%; The for-profit corporation that operates the gambling center receives approximately 66%;
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16.
Between 2007 and March 2012, this gambling operation has generated over
$300 million in illicit gambling proceeds of which over $68 million has been paid to IIT (for the licensing fee and use of the software in the slot machines) and over $30 million has been paid to Allied Veterans and Allied Management for hosting the gambling locations.
ALLIED VETERANS MANAGEMENT GROUP INC 17. Bank of America checking account # held in the name of Allied
Veterans Management Group Inc. was opened in March 2009. Johnny Duncan and Linda Duncan are listed as the signors on the account. 18. As previously discussed, Allied Veterans Management Group is a for-profit
corporation which receives approximately 10% of gambling proceeds from every AVOTW gambling center location every week. Between March 2009 and March 2012 over $24.3
million dollars was deposited into Allied Managements Bank account and at least $22 million appears to be from gambling proceeds. 19. From March 1, 2009 through December 31, 2009 at least $6.4 million was At least $5.7 million appears to be
deposited into Bank of America checking account
gambling proceeds directly from the Allied Veterans Affiliates. At Least $5.7 million from Affiliate gambling centers Over $500,000 returned from Mathis & Murphy PA Over $150,000 consisted of IRS Refunds, Affiliate Management Fees (each Affiliate gambling center pays $2,000 per year), and other miscellaneous checks.
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20.
From January 1, 2010 through December 31, 2010 at least $8.6 million was . At least $8.3 million appears to be
gambling proceeds directly from the Allied Veterans Affiliates. At Least $8.3 million from Affiliates Over $200,000 consisted of IRS Refunds, Affiliate Management Fees (each Affiliate pays $2,000 per year), and other miscellaneous checks. 21. From January 1, 2011 through December 31, 2011 at least $9.3 million was At least $8.1 million appears to be
gambling proceeds directly from the Allied Veterans Affiliates. At Least $8.1 million from Affiliates Over $550,000 is cash deposits (unknown source) $326,272.88 Wire in from Elite Title and Escrow Services Re: Refinance Home Apply Funds to Ln for Jerry W & Carolyn Bass At Over $200,000 consisted of IRS Refunds, Affiliate Management Fees (each Affiliate pays $2,000 per year), and other miscellaneous checks. 22. From January 1, 2012 through March 31, 2012 at least $2.7 million was . At least $2.5 million appears to be
gambling proceeds directly from the Allied Veterans Affiliates. 23. At Least $2.7 million from Affiliates Over $200,000 of unknown deposits Between June 1st, 2011 and March 31st, 2012, at least $8,713,587.57 was Of that amount, $7,768,337.36 came directly from Allied
deposited into this account.
Veterans Affiliates Bank of America accounts which, as discussed above, were funded with
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gambling proceeds. million dollars. 24.
On March 31, 2012 the balance in the account was $2,519,987.65
Between August 1, 2012 and September 30, 2012, at least $362,829.52 was
deposited into this account from gambling center bank accounts, previously described, that replaced the Affiliate bank accounts. Your affiant believes that all these funds are the daily illegal proceeds generated by the AVOTW Enterprise gambling centers. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the violations, pursuant to F.S. 895.05(3) and F.S. 932.702.
ALLIED VETERANS OF THE WORLD INC. HEADQUARTERS 25. Bank of America checking account held in the name of Allied
Veterans of the World Inc & Affiliate Headquarters was opened prior to October 2007. John Michael Hessong and Johnny Duncan are listed as the signors on the account. Prior to March 2009, Allied Veterans of the World and Affiliates received approximately 9.75% of gambling proceeds from every Affiliate location (split between a SunTrust Account-now closed and the Bank of America Account). Between October 2007 and December 2011 over $11 million dollars was deposited into Allied Veterans of the World Inc. and Affiliates Headquarters bank account and at least $7 million appears to be from the gambling: 26. From January 1, 2008 through December 31, 2008 at least $4.1 million was . At least $2.7 million appears to be
gambling proceeds directly from the Allied Veterans Affiliates. Over $2.7 million from Affiliates.
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Over $900,000 transferred from SunTrust, Allied Veterans of the World Inc. and Affiliates Advisory Account which also received gambling proceeds from each affiliate.
$220,000 from Mathis & Murphy PA for raffle proceeds. Over $150,000 was the redemption of a Certificate of Deposit. Over $100,000 consisted of IRS Refunds, Affiliate Management Fees (each Affiliate pays $2,000 per year), and other miscellaneous checks.
27.
From January 1, 2009 through December 31, 2009 at least $3.4 million was At least $725,000 appears to be
gambling proceeds directly from the Allied Veterans Affiliates. Over $725,000 from Affiliates. Over $2.5 million transferred from Bank of America, Acct #8705, Allied Veterans Management which also received gambling proceeds from each affiliate discussed above. Over $140,000 consisted of Refunds, Affiliate Management Fees (each Affiliate pays $2,000 per year), and other miscellaneous checks. 28. From January 1, 2010 through December 31, 2010 at least $1.5 million was . At least $1.5 million appears to be
gambling proceeds directly from the Allied Veterans Affiliates. Over $1.5 million transferred from Bank of America, Acct # Allied
Veterans Management which also received gambling proceeds from each affiliate discussed above.
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Over $70,000 consisted of Tax Refunds, Affiliate Management Fees (each Affiliate pays $2,000 per year), and other miscellaneous checks.
29.
From January 1, 2011 through December 31, 2011 at least $1.7 million was . At least $1.7 million appears to be
gambling proceeds directly from the Allied Veterans Affiliates. Over $1.7 million transferred from Bank of America, Acct # Allied
Veterans Management which also received gambling proceeds from each affiliate discussed above. Over $40,000 consisted of Tax Refunds, Affiliate Management Fees (each Affiliate pays $2,000 per year), and other miscellaneous checks. 30. Between June 1, 2011 and December 31, 2011, at least $1,129,359.27 was Of that amount, $1,110,000.00 came directly from Allied
deposited into this account.
Veterans Management Bank of America account which, as discussed above, was funded with gambling proceeds. 31. As of December 31, 2011 the balance in the account was approximately
$39,000. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702.
INTERNATIONAL INTERNET TECHNOLOGIES (I.I.T.) Flow of Criminal Proceeds into IIT bank accounts 32. Chase and Kristin Burns laundered the funds of the illegal gambling operation
by using a series of layered transactions, commingled illegal gambling proceeds with other
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moneys, and used a Professional Employer Organization to help accomplish these transactions. 33. As stated in your affiants Master Affidavit, a portion of the proceeds of the
AVOTW Enterprise gambling operation proceeds are transferred into IITs Bank of America account on a weekly basis. From 2007 through on or about April 30, 2012, all of the
proceeds were transferred via ACH through the bank account of Employers Resource Group at International Bank of Commerce from each affiliate. Employers Resource Group (ERG) is a payroll service or a Professional Employer Organization (PEO) which offers payroll, employee benefits, human resource administration, Section 125 Cafeteria Plan and 401(k) retirement plans. 34. A review of the bank accounts of all the affiliates does not show the identity of
the receiving bank or the receiving company. The transactions are conducted in such a manner that ERG is not identified on the Affiliates bank accounts, instead the statement shows Allied Veterans (the affiliate #) payroll. The transfers conceal the receiver of the funds i.e. IIT. Anyone looking at the affiliates bank accounts would not be able to identify the accounts where the money is being transferred or if the transfer was split and transferred to different accounts, only the fact that it was transferred out of the account. To further conceal the nature of the funds, each affiliate bank account only shows four weekly transfers and these transfers do not show that IIT is receiving approximately 22% of the funds. 35. As previously stated, on or about April 30, 2012 AVOTW allegedly sold the
gambling centers to non-affiliated corporations. It has been determined that the AVOTW Enterprise quit making deposits into the Affiliate bank accounts and began making daily deposits into newly named bank accounts. Although the AVOTW Enterprise quit using the
17
Affiliate bank accounts to transfer their illegal proceeds, they continue to transfer the illegal proceeds in virtually the same manner. A financial analysis of bank records from August 1, 2012 through September 30, 2012 shows that the gambling centers still pay I.I.T. on a weekly basis. The analysis shows that some of the gambling centers still utilize ERG to transfer illegal proceeds on a weekly basis and other gambling centers write checks to I.I.T. on a weekly basis. The amount of proceeds transferred to I.I.T. from the newly named AVOTW Enterprise gambling center bank accounts from August 2012 through September 2012 is $3,524,721.34. 36. Along with the AVOTW funds, IIT provides it software to other gambling centers
throughout the country and each of these gambling centers also deposit the gambling proceeds into this same Bank of America account. Your affiant has not done an analysis or any investigation into the other non-AVOTW gambling centers located outside the State of Florida but these funds may also be gambling proceeds. Once the gambling proceeds are deposited into the Bank of America account, the funds are immediately commingled with the other proceeds from the other states. Chase and/or Kristin Burns through IIT have
commingled the funds and therefore concealed the nature and the source of the funds. 37. To further conceal the nature and the source of the funds after the funds were
commingled, Chase and/or Kristin Burns through IIT would then transfer the commingled funds to other bank accounts that he/she controlled. Chase and/or Kristin Burns transferred the proceeds to other accounts he/she controlled including: IIT account at Midfirst Bank Chase Burns DBA CB Farms/Family Cattle LLC at Midfirst Bank, Chase Burns Trustee for the Chase Burns Trust Account at Midfirst Bank
18
38.
Chase Burns DBA OK Coin/Burns Family Land Co. LLC at Midfirst Bank Prestige Gaming LLC at Midfirst Bank Chase and/or Kristin Burns used the accounts above to conduct a series of
convoluted transactions with the commingled proceeds. The funds are transferred between accounts but eventually end up in Burns personal account titled Chase Burns TTEE FBO Chase Burns Trust U/A/D . It would be impossible for your affiant to identify the
specific gambling proceeds (as it relates to Allied Veterans) that have been deposited into IITs account at Bank of America and then laundered through Burns accounts because of the weekly commingling of the gambling proceeds and the layering of the transactions after receipt of the funds. INTERNATIONAL INTERNET TECHNOLOGIES (I.I.T.) 39. Bank of America checking account held in the name of
International Internet Technologies LLC was opened in May 2007. Chase Burns and Kristin Burns are listed as the signors on the account. The account was opened in Oklahoma. The contact address for this account is P.O. Box 130, Anadarko, Oklahoma 73005. As stated above, approximately 22% of what is deposited into the AVOTW Affiliates accounts at Bank of America is transferred to ITT each week. Specifically, that money is wire transferred by the Employers Resource Group to this account. Between January 2008 and March 2012, IIT has received over $68.6 million into this account from the AVOTW Enterprise gambling operation. IIT also received funds from North Carolina and South Carolina Internet Cafes (which some of these are being operated by the same members of the AVOTW Enterprise previously mentioned in your affiants Master Affidavit) and other states which totaled approximately $98.4 million through March 2012.
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40.
From January 1, 2008 through December 31, 2008 over $22.3 million was Approximately $11.4
million appears to be gambling proceeds directly from the Allied Veterans Affiliates and approximately $10.8 million from Gambling Centers located outside the State of Florida, some of which are run by the persons who operate the AVOTW gambling center locations in Florida. $11.4 million was directly from the Affiliates of the gambling operation. $1 million dollars consisted of proceeds of North Carolina based Gambling Centers. These two Gambling Centers are Cyber World-owned by Anthony Parker and Cyberlynk owned by Reggie Medlinboth of these individuals run AVOTW Gambling Centers in Florida. $9.8 million dollars consist of proceeds from other North Carolina based Gambling Centers not included in this investigation. 41. From January 1, 2009 through December 31, 2009 over $35 million was Approximately $15.7
million appears to be gambling proceeds directly from the AVOTW gambling centers. $15.7 million was directly from the Affiliates of the gambling operation. $1.9 million dollars consisted of proceeds of North Carolina based Gambling Centers. These three Gambling Centers are Cyber World-owned by Anthony Parker and Cyberlynk owned by Reggie Medlin, and Fannco Inc owned by John Fanninthese three individuals run AVOTW Gambling Centers in Florida. $17.4 million dollars consist of proceeds from other North Carolina based Gambling Centers not included in this investigation.
20
42.
From January 1, 2010 through December 31, 2010 over $48 million was At least $18.3 million
appears to be gambling proceeds directly from the AVOTW gambling centers. $18.3 million was directly from the Affiliates of the gambling operation. $2.2 million dollars consisted of proceeds of North Carolina based Gambling Centers. These three Gambling Centers are Cyber World-owned by Anthony Parker and Cyberlynk owned by Reggie Medlin, and Fannco Inc owned by John Fanninthese three individuals run AVOTW Gambling Centers in Florida. $27.7 million dollars consist of proceeds from other North Carolina based Gambling Centers not included in this investigation. 43. From January 1, 2011 through December 31, 2011 over $47.3 million was At least $17.5 million
appears to be gambling proceeds directly from the AVOTW gambling centers. $17.5 million was directly from the Affiliates of the gambling operation. $2.4 million dollars consisted of proceeds of North Carolina based Gambling Centers. These three Gambling Centers are Cyber World-owned by Anthony Parker and Cyberlynk owned by Reggie Medlin, and Fannco Inc owned by John Fanninthese three individuals run AVOTW Gambling Centers in Florida. $26.9 million dollars consist of proceeds from other North Carolina based Gambling Centers not included in this investigation. 44. From January 1, 2012 through March 31, 2012 over $14.5 million was At least $5.4 million
appears to be gambling proceeds directly from the AVOTW gambling centers.
21
Over $5.4 million was directly from the Affiliates of the gambling operation. Over $570,000 consisted of proceeds of North Carolina based Gambling Centers. These three Gambling Centers are Cyber World-owned by Anthony Parker and Cyberlynk owned by Reggie Medlin, and Fannco Inc owned by John Fanninthese three individuals run AVOTW Gambling Centers in Florida.
$8.3 million dollars consist of proceeds from other North Carolina based Gambling Centers not included in this investigation.
45. 46.
As of March 31, 2012, the balance in this account was $3,201,481.61. From August 1, 2012 through on or about September 30, 2012, $6,985,910.78 At least $3,524,721.34 appears to be
was deposited into the aforementioned account.
gambling proceeds directly from AVOTW gambling centers. The below chart indicates the aforementioned deposits: Chart 4: I.I.T. Account Deposits August 2012 September 2012
Grand Total $ 94,779.40 $ 110,844.37 $ 64,340.66 $ 37,349.09 $ 63,118.23 $ 44,554.19 $ 32,716.08 $ 269.71 $ $ $ $ $ $ $ $ 114,800.91 48,791.58 49,944.88 51,308.74 3,359.50 79,826.48 218,099.03 6,835.50
Deposited From Allied 31 Allied 35 Allied 36 Allied 50 Allied 58 Allied 60 Allied 65 Allied 75 AVMG Incorporated Operating BOA 898035758966 B.B.S Management Group BOA 898011602395 Business Center CCS Management Group BOA Comptrac, Inc BOA Cyberlynk BOA Cyberworld Wells Fargo Datahub, Inc BOA 22
Deposited From Davis Internet BOA Digitrac, Inc. BOA Elite 34 Elite 37 Elite 38 Elite 43 Elite 44 Elite 55 Elite 57 Elite 63 Elite 68 Elite 71 Elite 81 Fannco Inc BB&T Gainesville Internet Game Advice, Inc BOA Ginlin, LLC Wells Fargo Gulf Internet Infovice, Inc BOA INH Management BOA Intelitek, Inc BOA Invovice, Inc BOA Lake City Internet Live Oak Internet Media Advice BOA Reginald Medlin T. Parker Management Grand Total
Grand Total $ 2,800.07 $ 325,729.01 $ 155,410.94 $ 72,934.66 $ 159,075.15 $ 155,724.81 $ 107,367.07 $ 64,306.42 $ 2,648.07 $ 4,471.41 $ 173,510.85 $ 138,158.15 $ 38,211.03 $ 130,500.38 $ 95,588.53 $ 160,899.79 $ 160,390.79 $ 28,658.28 $ 57,474.19 $ 63,497.06 $ 54,171.18 $ 31,239.66 $ 79,286.17 $ 38,145.18 $ 187,319.77 $ 15,988.52 $ 275.85 $ 3,524,721.34
Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. INTERNATIONAL INTERNET TECHNOLOGIES (I.I.T.) 47. Midfirst Bank checking account held in the name of International
Internet Technologies LLC was opened prior to 2008. Chase Burns and Kristin Burns are
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listed as the signors on the account.
The account was opened in Oklahoma. The contact
address for this account is P.O. Box 130, Anadarko, Oklahoma 73005-0130. The Midfirst account is used by Chase and/or Kristin Burns to move gambling proceeds to other accounts that he/she controls. This account has been used by Chase and/or Kristin Burns as a
savings account for IIT. After Chase and/or Kristin Burns has amassed a large amount of funds in the Bank of America Account discussed above, he/she transfers large Once the commingled funds are
amounts of commingled proceeds into this account.
deposited into this account, they are moved again to additional accounts controlled by Chase and/or Kristin Burns, which moves the funds further away from the source. This account has received over $65 million from Bank of America Account 48. From October 1, 2008 through December 31, 2008 over $5 million was (the records prior to October
deposited into Midfirst Bank checking account
2008 were not available). At least $5 million dollars was transferred from Bank of America checking account to this account.
Three deposits for $5 million dollars from IIT account at Bank of America, Account
49.
One miscellaneous deposit for $2,072.87 From January 1, 2009 through December 31, 2009 over $27 million was $22.6 million dollars was
deposited into Midfirst Bank checking account transferred from Bank of America checking account
Fifteen Deposits totaling over $22.6 million dollars from IIT, Bank of America account
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Additional $3.9 million in deposits from previously purchase Certificates of Deposits
$250,000 from Chase Burns Trustee for Chase Burns Trust Account , Account
50.
Over $507,000 from Scenic Mountain Amusements Over $92,000 from SteelCreek Business Center Over $75,000 from the gambling center Over $56,000 from Cyber Express LTD Miscellaneous other deposits totaling over $180,000 From January 1, 2010 through December 31, 2010 over $23.9 million was . $23.4 million dollars was
Seven deposits totaling $23.4 million dollars Bank of America account
51.
Over $169,000 from SteelCreek Business Center Over $209,000 from the gambling center Over $109,000 from Cyber Express Limited Miscellaneous other deposits totaling over $75,000 From January 1, 2011 through December 31, 2011 over $15.4 million was $14.6 million dollars was
Four deposits totaling $14.6 million Bank of America account $30,000 from Ginlin LLC (a for-profit corporation operating AVOTW Affiliates)
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52.
Over $28,000 from the Internet Business Center Over $11,000 from Prestige Gaming LLC (Burns controlled corporation) Over $7,000 from Burns Family Cattle Miscellaneous other deposits totaling over $21,000 From January 1, 2012 through February 28, 2012 over $150,000 was deposited
into Midfirst Bank checking account 53. As of February 28, 2012, the balance in this account was $1,123,699.29.
Because this account was used to launder the proceed of the commingling of the funds which concealed the nature and source of the gambling proceeds, the proceeds are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702
FOR-PROFIT CORPORATION ACCOUNTS 54. As discussed in your affiants Master Affidavit, from 2007 through on or about
April 30, 2012, each AVOTW Affiliate was a separate for- profit entity operated by a for-profit corporation owned by members of the AVOTW Enterprise that ran the day to day operations of the business. All of the for-profit corporations operate in the same manner. Each
AVOTW Affiliate had the Affiliate number on the outside of the building and provided the location with Allied Veterans pictures, donation letters and various signs to dupe the public into believing the location was run by Allied Veterans. On or about April 30, 2012, the Affiliate locations removed their AVOTW signs, pictures, and other propaganda items in an attempt to imply that the Affiliate locations had been sold. The for-profit corporations are responsible for purchasing the computers and software from IIT to set up the location. Each for-profit
26
corporation receives an IIT training manual as part of the set up process. Each for-profit corporation staffs the location with employees, who wear Allied Veterans shirts, and all the employees are instructed on what terms to use (ie sweepstakes not gambling, sweepstakes entries not bets, etc) with the customers. 55. Allied Veterans of the World and Affiliates and Allied Veterans Management
Group Inc., and all the AVOTW Affiliate gambling centers have deposited over $300 million dollars of illicit gambling proceeds into their bank accounts for the years 2007 through present. From April 2012 through September 30, 2012 the AVOTW Affiliate locations under their new business names, Allied Veterans Management Group Inc., and I.I.T. have continued to deposit and launder millions of dollars of illicit gambling proceeds through their bank accounts. The corporations listed below have been operating each of the AVOTW locations and have deposited approximately 66% of the illicit proceeds into their bank accounts and further transferred these funds to their personal accounts that will be discussed later in this affidavit. In addition, there are for-profit corporations owned by members of the AVOTW Enterprise that receive gambling proceeds indirectly from the AVOTW Affiliate gambling centers through the for-profit corporations that operate the gambling centers. These for-profit corporations utilized to further conceal and disguise the nature of the proceeds are also listed below in this affidavit. 56. An analysis of the bank records associated with each for-profit account
indicates that the majority of the funds that have been deposited into the above-referenced accounts are the funds that are transferred each week directly or indirectly from each Affiliates gambling operation. All other funds not obtained as a result of illegal gambling have been analyzed and the analysis reveals that small amounts of proceeds have been
27
deposited into some of these accounts and therefore commingled with the gambling proceeds. Accordingly, the funds contained within in these accounts represent the proceeds obtained from an illegal gambling business, in violation of F.S. 849 Et. Seq. and F.S. 895.03. Because these accounts received deposits directly and/or indirectly from gambling proceeds, the funds in these accounts are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. 57. In addition to the for-profit corporations that receive funds directly from the
Affiliate gambling centers, there are for-profit corporations that are also listed below that receive funds indirectly from the Affiliate gambling centers. Accordingly, the funds contained within in these accounts represent the proceeds obtained from an illegal gambling business, in violation of F.S. 849 Et. Seq. and F.S. 895.03. Because these accounts received deposits directly and/or indirectly from gambling proceeds, the funds in these accounts are also subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. ALL PRO TAX AND ACCOUNTING 58. The Palmetto Bank account was opened on April 7, 2009 in the
name ALL-PRO TAX AND ACCOUNTING, at a branch located in Boiling Springs, South Carolina. Johnny Duncan and Scott Pruitt are listed as the signor on the account. The contact address for this account is listed as P.O. Box 160272, Boiling Springs, SC., 29316. 59. As previously stated, Duncan has been laundering the proceeds of the
gambling operation through this company since its inception. Duncan is also using this company to pay his wife, Linda Duncan over $100,000 per year. All Pro Tax and Accounting
28
is being used by Duncan and Pruitt to launder gambling proceeds and this money is being deposited and/or transferred through Palmetto Bank, Acct #051129183. 60. Between April 7, 2009 and March 31, 2012, a total of approximately
$1,354,554.82 was deposited into this account. Of that amount, $1,236,171.67 came directly from Allied Veterans Management Group Bank of America account which receives its funds directly from Allied Veterans Affiliate Bank of America accounts as discussed above, that were funded solely with gambling proceeds. 61. As of March 31, 2012, this account had a balance of $55,296.06.
AUTOMATED X-100 SERVICES 62. Bank of America Business Economy Checking account was
opened on or about April 5, 2001 in the name of AUTOMATED X-100 SERVICES, INC. with Johnny E. Duncan listed as the President and sole signor on the account. On January 19, 2010 bank records indicate that Linda Duncan was added to the account as Vice President and authorized signor. The contact addresses for the account are listed as Duncans
residence, 240 Oldmaster Ct., Boiling Springs, SC 29316 and P.O. Box 160939, Boiling Springs, SC, 29316-0016. 63. Between January 2009 and December 2010, a total of $1,881,921.22 was
deposited into this account, at least $1,880,823.22 of which appears to be proceeds of gambling: $100,000.00 was deposited from Allied Veterans Management Group, Inc. (Bank of America account ending in ) which received illegal proceeds
directly or indirectly from AVOTW and/or the Affiliates.
29
$52,500.00 was deposited from All-Pro Tax and Accounting, LLC. (The Palmetto Bank account which received illegal proceeds directly or
indirectly from AVOTW and/or the Affiliates. $1,596,883.22 was deposited from Allied Veterans of the World, Inc. & Affiliate Headquarters / Allied Veterans of the World & Affiliate (Bank of America account ending in which received illegal proceeds directly or indirectly
from AVOTW and/or the Affiliates. $120,000.00 was deposited from Johnny E. Duncan and or Linda A Duncan (Bank of America personal account ending in ) which received illegal
proceeds directly or indirectly from AVOTW and/or the Affiliates. $10,000.00 was deposited from Mathis & Murphy P.A. Trust Account (The Jacksonville Bank account ending in ) which received illegal proceeds
directly or indirectly from AVOTW and/or the Affiliates. $700.00 was deposited from Moses Ramos and/or Elizabeth Ramos (Bank of America account ending in ).
$740.00 was deposited from Pier Point South (BBVA Compass Bank) which is where several condominium residential properties were purchased with illegal proceeds directly or indirectly derived from AVOTW and/or the Affiliates.
64.
Between January 2011 and March 2012, a total of $832,267.34 was deposited
into this account, at least $802,354.67 of which appears to be proceeds of gambling: $588,000.00 was deposited from Allied Veterans of the World & Affiliate (Bank of America) which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates.
30
$214,354.67 was deposited from Johnny E. Duncan and or Linda A Duncan (Bank of America personal accounts) which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates.
65.
As of March 31, 2012 this account had a balance of $122,532.88. Because this
account received deposits of at least $2,683,177.89 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. AVMG INCORPORATED OPERATING 66. Bank of America account in the name of AVMG
INCORPORATED lists Michael Davis as the signor on the account. This for-profit corporation and bank account replaced the gambling centers previously identified as Affiliates 39 and 40 and the bank accounts identified as Affiliate 39 and Affiliate 40. 67. Between April 2012 and January 2013, $2,883,454.95 was deposited into this
account which your affiant believes is the daily proceeds of the gambling centers previously identified as Affiliates 39 and 40. The gambling proceeds are then laundered and transferred to other AVOTW Enterprise bank accounts including AVMG INCORPORATED bank accounts ending in 68. and and MSG Business Center account ending in
As of January 2013, the balance in this account is $10,483.49. Because this
account was utilized to launder illegal gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702.
31
AVMG INCORPORATED HOLDING 69. Bank of America account in the name of AVMG
INCORPORATED lists Michael Davis as the signor on the account. 70. Between April 2012 and January 2013, $121,117.63 was deposited into this which receives the daily proceeds
account from AVMG Incorporated account ending in of gambling centers Affiliate 39 and Affiliate 40. 71.
account was utilized to launder illegal gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. AVMG INCORPORATED ESCROW & TAXES 72. Bank of America account in the name of AVMG
INCORPORATED lists Michael Davis as the signor on the account. 73. Between April 2012 and January 2013, $121,192.24 was deposited into this which receives the daily proceeds
account from AVMG Incorporated account ending in of gambling centers Affiliate 39 and Affiliate 40. 74.
account was utilized to launder illegal gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. B&C GAMING DBA 75. Bank of America Business Advantage Checking account was
opened on June 13, 2005 in the name of CONRAD H ROWE DBA B & C GAMING at the
32
Harbour Place Branch in Jacksonville, Florida. Conrad Rowe, Earline V Hart, Shannon Gahagan and Michael C Nisbet are listed as the signors on the account. The contact address for this account is listed as 8513 Gracious Pine Avenue, Las Vegas, NV 89143-4609. 76. Between January 2008 and December 2008, $1,593,681.86 was deposited
directly from AVOTW Affiliate 37 Bank of America account which, as discussed above, was funded solely with gambling proceeds. 77. Between January 2009 and December 2010, a total of $2,864,500.57 was
deposited into this account, of which at least $2,617,987.03 was deposited directly from AVOTW Affiliate 37 Bank of America account which, as discussed above, was funded solely with gambling proceeds. 78. Between January 1, 2011 and March 31, 2012, a total of $95,795.38 was
deposited into this account, of which at least $70,766.29 appears to be proceeds of gambling: $15,766.29 was deposited from Bearcon Management, LLC Bank of America account ending in , which received illegal proceeds from Affiliate 37.
$53,000.00 was deposited from Bearcon Management, LLC Bank of America account ending in 37. which indirectly received illegal proceeds from Affiliate
$2,000.00 was deposited from Conrad Rowes Bank of America account ending in , which received illegal proceeds indirectly from AVOTW Affiliate 37.
79.
As of March 31, 2012, this account had a balance of $2,484.41. Because this
account received deposits of at least $4,282,435.18 in gambling proceeds, the funds in this
33
account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. B&M LEASING & MANAGEMENT, LLC. 80. Bank of America Business Advantage Checking account was
opened on September 27, 2007 in the name B&M LEASING & MANAGEMENT LLC., at a branch located at University Pointe, Jacksonville, Florida. Mazen Salloum, Terri LeClaire, and Conrad Rowe are listed as the signor on the account. The contact address for this account is listed as 3814 University Blvd., W, Jacksonville, Florida, 32217-2202.92. 81. Between September 27, 2007 and March 31, 2012, a total of approximately
$12,492,193.98 was deposited into this account, of which at least $7,257,073.65 was deposited directly from AVOTW Affiliate 44 Bank of America Account which, as discussed above, was funded solely with gambling proceeds. As of March 31, 2012, this account had a balance of $51,015.67. 82. deposits. Between April 2012 and January 2013, this account received $1,910,908.88 in The bank records show that the deposits came from payroll Elite 44
approximately every seven (7) days which your affiant believes is a portion of the daily proceeds of gambling center Affiliate 44. 83. Between April 2012 and January 2013, $19,549.60 was deposited into this
account that came directly from SEASIDE INTERNET, LLCs Bank of America account ending in 2707, which receives illegal proceeds from gambling centers. 84. As of January 2013, the balance in this account is $86,028.41. Because this
account received deposits of gambling proceeds the funds in this account are subject to
34
forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. B&M LEASING & MANAGEMENT, LLC 85. Bank of America Business Economy Checking account was
opened on May 18, 2010 in the name of B&M LEASING & MANAGEMENT ATM ACCOUNT at the University Pointe Branch in Jacksonville, Florida. Mazen Salloum and Terri LeClaire are listed as the signors on the account. The contact address for this account is listed as 3814 University Blvd W, Jacksonville, FL 32217-2202. 86. Between May 18, 2010 and March 31, 2012, a total of approximately
$680,929.00 was deposited into this account of which at least $15,842.00 was deposited from B&M Leasing & Management Bank of America account ending in illegal proceeds from AVOTW Affiliate 44. 87. As of March 31, 2012, this account had a balance of $10,905.00. Because this which received
account received deposits of gambling proceeds the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. 88. Between April 2012 and January 2013, this account received $45,444.00 in
deposits that came from Delta Leasing & Management LLC. Delta Leasing & Management LLC is a for-profit corporation owned by AVOTW Enterprise co-conspirators. This for-profit corporation provides the ATM machines to the gambling centers which the customers utilize to obtain money to gamble. The for-profit corporation charges a surcharge for the
customers use of the ATM machine. Your affiant believes a portion of those proceeds are then deposited into this account which you affiant believes are illegal proceeds.
35
89.
account received deposits of gambling proceeds the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. B & M LEASING & MANAGEMENT, LLC 90. Bank of America account in the name of B&M LEASING &
MANAGEMENT, LLC LOCATION 44 ACCOUNT lists Mazen Salloum, Brad Skidmore, Terri LeClaire, and Rebecca Stevens as signors on the account. Your affiant believes this account replaced the bank account previously identified as Affiliate 44. 91. Between April 2012 and January 2013, this account received $2,462,078.26 in
deposits which your affiant believes are the daily proceeds of gambling center previously identified as Affiliate 44. This account is then utilized to transfer proceeds to other AVOTW Enterprise bank accounts. 92. As of January 2013, the balance in this account is $16,510.56. Because this
account received deposits of gambling proceeds the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. B&M LEASING & MANAGEMENT, LLC 93. Bank of America account in the name of B&M LEASING &
MANAGEMENT, LLC SAINT AUGUSTINE STORE #55 lists Conrad Rowe, Mazen Salloum, Salim Salloum, and Kenneth Nisbet as signors on the account. 94. deposits. Between April 2012 and January 2013, this account received $1,173,000.28 in The bank records show that the deposits came from payroll Elite 55
36
approximately every seven (7) days which your affiant believes is a portion of the daily proceeds of gambling center Affiliate 55. 95. As of January 2013, the balance in this account is $45,722.14. Because this
account received deposits of gambling proceeds the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. B & M LEASING & MANAGEMENT, LLC SPECIAL FUNDS ACCOUNT 96. Bank of America account in the name of B&M LEASING &
MANAGEMENT, LLC, SPECIAL FUNDS ACCOUNT lists Mazen Salloum, Brad Skidmore, Terri LeClaire, and Rebecca Stevens as signors on the account. 97. Between April 2012 and January 2013, this account received $227,454.67 in
deposits. The bank records show that the deposits came from Elite 44 and Elite 55 approximately every seven (7) days which your affiant believes is a portion of the daily proceeds of gambling centers Affiliate 44 and Affiliate 55. 98. As of January 2013, the balance in this account is $19,444.72. Because this
account received deposits of gambling proceeds the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. B.B.S. MANAGEMENT GROUP INC. 99. Bank of America Business Advantage Checking account was
opened on October 17, 2008 in the name B.B.S. MANAGEMENT GROUP INC., at a branch located at Volusia County, Florida. Bennie J. Prince, Peggy A. Prince and Cynthia Weaver
37
are listed as the signors on the account. The contact address for this account is listed as 809 Riviera Bella Drive, DeBary, Florida, 32713-5434 100. Between February 17, 2009 and March 31, 2012, a total of approximately
$2,642,266.06 was deposited into this account which came directly from AVOTW Affiliate 61 Bank of America account which, as discussed above, was funded solely with gambling proceeds. 101. As of March 31, 2012, this account had a balance of $85,954.27. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. BASS CONSULTING & E BAY SALES 102. Southeastern Bank Business Checking account was opened on
or about September 26, 2007, in the name of JERRY BASS DBA BASS CONSULTING & EBAY SALES with Jerry W. Bass as the Sole Owner/Signor. On November 19, 2008, Carolyn Gail Bass was added to the account as an authorized signor. The contact addresses for the account are listed as Basss residence 2826 Waterview Circle, Jacksonville, FL 32226, 542390 U.S. Hwy 1, Callahan, FL 32011-6493 and 542830 U.S. Hwy 1, Callahan, FL 320116645. 103. Between September 2007 and February 2012, approximately $735,911.73 was
deposited into this account, at least $544,948.97 of which appears to be proceeds of gambling violations:
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$9,000.00 was deposited from Allied Veterans Management Group, Inc. (Bank of America) which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates.
$80,500.00 was deposited from Allied Veterans of the World, Inc. & Affiliate Headquarters (Bank of America) which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates.
$75,000.00 was deposited from Bearcon Management, LLC. (Bank of America) which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates.
$121,948.97 was deposited from Conrad Rowe DBA B&C Gaming (Bank of America) which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates.
$32,000.00 was deposited from M&S Management Services, LLC (Bank of America) which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates.
$9,000.00 was deposited from Michael W. Ryles and/or Janice S. Ryles (Bank of America) which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates.
$9,000.00 was deposited from MNL Investments, Inc. (SunTrust Bank) which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates.
$10,000.00 was deposited from Seaside Internet, LLC (Bank of America) which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates.
39
$169,000.00 was deposited from Tamara L. Gross DBA Goodtimes Caf (Bank of America) which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates.
$29,500.00 was deposited from Three of Us Property Management, LLC (Bank of America) which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates.
104.
As of February 29, 2012 this account had a balance of $45,182.95. Because
this account received deposits of at least $677,126.83 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. BEARCON MANAGEMENT, LLC 105. Bank of America Business Economy Checking account was
opened on January 31, 2012 in the name BEARCON MANAGEMENT, LLC.at the Churchland Banking Branch located in Chesapeake, VA. Shannon D Gahagan and Conrad Rowe are listed as the signors on the account. The contact address for this account is listed as 3077 Stratford Ct., Chesapeake, VA. 106. Between January 31, 2012 and April 30, 2012, a total of approximately
$505,109.69 was deposited into this account. Of that amount, $423,506.94 came directly from AVOTW Affiliate 37 Bank of America account, as discussed above, was funded solely with gambling proceeds. As of April 30, 2012, this account had a balance of $176,317.39. 107. Between April 2012 and January 2013, $1,309,310.56 was deposited into this
account which your affiant believes is a portion of the daily proceeds of the gambling center
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previously identified as Affiliate 37.
The bank records show that the deposits into this
account reflect payroll deposit from Elite 37. 108. As of January 2013 the balance in this account is $148,914.77. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. BEARCON MANAGEMENT, LLC 109. Bank of America account in the name of BEARCON
MANAGEMENT LLC. is receiving direct deposits from BOA account number ending in in the name of BEARCON MANAGEMENT, previously described, that is receiving illegal proceeds from gambling center Affiliate 37. The signors on the account are Conrad Rowe, Shannon Gahagan, and Kenneth M. Nisbet. 110. Between April 2012 and January 2013, $566,515.04 was deposited into this previously described. As of January
account which came from account ending in
2013, the balance in this account is $20,082.02. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. BEARCON MANAGEMENT, LLC 111. Bank of America account in the name of BEARCON
MANAGEMENT LLC. lists Conrad Rowe and Shannon Gahagan as signors on the account. 112. Between April 2012 and January 2013, $75,431.52 was deposited into this
account which your affiant believes is a portion of the daily proceeds of the gambling center previously identified as Affiliate 37. The bank records show that the deposits into this
41
account reflect payroll deposit from Elite 37.
As of January 2013 the balance in this account
is $12,917.30. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. BEARCON MANAGEMENT, LLC 113. Bank of America Business Advantage Checking account was
opened on February 23, 2009 in the name of BEARCON MANAGEMENT LLC at the Harbour Place Branch in Jacksonville, Florida. Conrad H Rowe, Mazen G Salloum and Shannon D Gahagan are listed as the signors on the account. The contact address for this account is listed as 3077 Stratford Court, Chesapeake, VA 23321-5825. 114. Between February 1, 2009 and March 31, 2012, a total of $1,939,845.33 was
deposited into this account of which at least $1,775,933.67 appears to be proceeds of gambling: $385,000.00 was deposited from Bearcon Management Bank of America account ending in 37. $711,024.16 was deposited from B&M Leasing & Management Bank of America account ending in Affiliate 44. $1,250.00 was deposited from B&M Leasing& Managements ATM Account Bank of America account ending in indirectly from AVOTW Affiliate 44. that received illegal proceeds which received illegal proceeds from AVOTW , which received illegal proceeds from AVOTW Affiliate
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$675,000.00 was deposited from B&M Leasing and Management St Augustine Store # 55, Bank of America account number ending in illegal proceeds from AVOTW Affiliate 55. that received
$2,000.00 was deposited from Mazen Salloums Wachovia account ending in , which indirectly received illegal proceeds from AVOTW Affiliates 34, 37, 38, 43, 44, 57, 68, 71, and 81.
$1,659.51 was deposited from Seaside Internet Marion Bank of America account ending in , which received illegal proceeds from AVOTW Affiliate
63. As of March 31, 2012, this account had a balance of $632,362.23. 115. Between April 2012 and January 2013, this account received deposits in the
amount of $735,473.99 which came from B & M Leasing bank accounts which received illegal proceeds from gambling centers previously described. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. BEARCON MANAGEMENT, LLC 78. Bank of America account in the name of BEARCON
MANAGEMENT LLC. lists Conrad Rowe and Shannon Gahagan as signors on the account. This for-profit corporation and bank account replaced the gambling center previously identified as Affiliate 37 and the bank account identified as Affiliate 37. 79. Between April 2012 and January 2013, $1,728,528.76 was deposited into this
account which your affiant believes is the daily proceeds of the gambling center previously identified as Affiliate 37. The gambling proceeds are then laundered and transferred to other
43
AVOTW Enterprise accounts on a weekly basis including Allied Veterans Management Group Inc. and I.I.T. 80. As of January 2013, the balance in this account is $13,075.79. Because this
account was utilized to launder illegal gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. BETTER GAMES DISTRIBUTING CO., INC. 116. Horry County State Bank, Easy Business Checking Account was
opened on or about March 28th, 2011 in the name of BETTER GAMES DISTRIBUTING CO., INC. The account was opened at an unknown branch in the state of South Carolina.
Michael W Graham, Joseph S. Harrington, and Elaine M. Harrington are listed as the signors/owners of the account. The contact address for this account is listed as 103 N. Main St. Tabor City, NC 28463-1617. 117. Between March 2011 and February 2012, $1,698,869.81 was deposited into
this account, of which at least $941,125.00 appears to be proceeds of gambling: $458,020.00 was deposited from Gainesville Internet Services, LLCs Bank accounts which received direct and indirect illegal proceeds. o $15,000.00 was deposited from Gainesville Internet Services, LLCs Bank of America account ending in proceeds from AVOTW Affiliate 72. o $443,020.00 was deposited from Gainesville Internet Services, LLC unknown account. which received illegal
44
$342,968.00 was deposited from Lake City Internet Services, LLCs Bank accounts which received direct and indirect illegal proceeds. o $35,000.00 was deposited from Lake City Internet Services, LLCs Bank of America account ending in proceeds from AVOTW Affiliate 56. o $307,968.00 was deposited from Lake City Internet Services, LLC unknown account. which received illegal
$60,137.00 was deposited from Live Oak Internet Services, LLCs unknown account.
$80,000.00 was deposited from International Internet Technologies Bank of America account ending in AVOTW Affiliates. which received illegal proceeds from all
NOTE: $300,000.00 of the total deposit amount listed below was the result of a business loan granted to Better Games Distributing Co., Inc. by Horry County State Bank.
118.
As of February, 2012 this account had a balance of $77,987.78. Because this
account received deposits of at least $941,125.00 in gambling proceeds, the funds in this account are subject to forfeiture as the proceeds of gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. BETTER GAMES DISTRIBUTING CO., INC. 119. Horry County State Bank, Money Market Advantage Account
was opened on or about February 4th, 2010 in the name of BETTER GAMES DISTRIBUTING CO., INC. L C LEASE ACCT.. The account was opened at an unknown
45
branch in the state of South Carolina. Michael W Graham and Joseph S. Harrington are listed as the signors/owners of the account. The contact address for this account is listed as 103 N. Main St. Tabor City, NC 28463. 120. Between January 2011 and February 2012, a total of approximately $99,567.34
was deposited into this account, of which $45,000.00 was deposited from Better Games Distributing Company Inc. Horry County State Bank account ending in illegal proceeds from AVOTW Affiliates 56 and 72. 121. As of February, 2012 this account had a balance of $73,378.25. Because this which received
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as the proceeds of gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. BEYER PRODUCTIONS LLC 122. Citizens Bank business green checking account# was opened on
or about August 28, 2006 in the name of BEYER PRODUCTIONS LLC, at a branch located in Jamison, Pennsylvania. Anthony V. Beyer is listed as the signor on the account. The contact address for this account is listed as 18925. 123. Between January 2011 and March 2012, a total of approximately Redbud Lane, Furlong, Pennsylvania,
$2,733,267.84 was deposited into this account. Of that amount, $2,724,867.84 came directly from I.I.T. bank accounts. A total of $2,339,067.84 came directly from I.I.T. Bank of America account# and $385,800.00 came directly from I.I.T. MidFirst account# which received its funds directly and/or indirectly from AVOTW Affiliate Bank of America accounts which, as discussed above, were funded solely with gambling proceeds.
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124.
As of March 31, 2012 this account had an ending balance of $97,444.34.
Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. BEYER PRODUCTIONS LLC 125. Citizens Bank business partners checking III account# was
opened on March 7, 2012 in the name of BEYER PRODUCTIONS LLC, at a branch located in Pennsylvania. Anthony V. Beyer is listed as the signor on the account. The contact address for this account is listed as 2111 Redbud Lane, Furlong, Pennsylvania 18925 126. Between March 7, 2012 and March 31, 2012, a total of approximately
$36,400.00 was deposited into this account that came directly from I.I.T. Bank of America account# which received its funds directly and/or indirectly from AVOTW
Affiliate Bank of America accounts which, as discussed above, were funded solely with gambling proceeds. 127. As of March 31, 2012 this account had an ending balance of $36,400.00.
Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. BEYER PRODUCTIONS LLC 128. Citizens Bank business performance money market account# was
opened on March 7, 2012 in the name of BEYER PRODUCTIONS LLC, at a branch located in Pennsylvania. Anthony V. Beyer is listed as the signor on the account. The contact address for this account is listed as 2111 Redbud Lane, Furlong, Pennsylvania 18925.
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129.
Between March 7, 2012 and March 31, 2012, a total of approximately
$177,248.26 was deposited into this account that came directly from I.I.T. Bank of America account# which received its funds directly and/or indirectly from AVOTW
Affiliate Bank of America accounts which, as discussed above, were funded solely with gambling proceeds. 130. As of March 31, 2012 this account had an ending balance of $150,337.59.
Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. BLUE WATER INTERNET TECHNOLOGY, LLC 131. Bank of America account in the name of BLUE WATER
INTERNET TECHNOLOGY, LLC lists Tony Parker & Leslie Collins as the signors on the account. This for-profit corporation and bank account replaced the gambling center
previously identified as Affiliate 75 and now identified as the Palms Business Center and the bank account identified as Affiliate 75. 132. Between April 2012 and January 2013, $304,225.44 was deposited into this
account which your affiant believes a portion of the proceeds came from The Palms Business Center. This account also transferred proceeds to other BLUE WANTER INTERNET
TECHNOLOGY BOA accounts indicating 75 Allied Veteran Payroll. 133. As of January 2013, this account had a balance of $12,546.23. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702.
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BLUE WATER INTERNET TECHNOLOGY, LLC, PAYROLL ACCOUNT 134. Bank of America account in the name of BLUE WATER
INTERNET TECHNOLOGY, LLC, PAYROLL ACCOUNT lists Tony Parker & Leslie Collins as the signors on the account. This for-profit corporation bank account receives proceeds from BLUE WATER INTERNET TECHNOLOGY, LLC BOA account ending in 5454, previously described. 135. Between April 2012 and January 2013, $90,808.51 was deposited into this
account from BLUE WATER INTERNET TECHNOLOGY, LLC BOA account ending in previously described. As of January 2013, this account has a balance of $2,263.10. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. BLUE WATER INTERNET TECHNOLOGY, LLC, OPERATING ACCOUNT 136. Bank of America account in the name of BLUE WATER
INTERNET TECHNOLOGY, LLC, OPERATING ACCOUNT lists Tony Parker & Leslie Collins as the signors on the account. This for-profit corporation bank account receives proceeds from BLUE WATER INTERNET TECHNOLOGY, LLC BOA account ending in previously described. 137. Between April 2012 and January 2013, $2,950.00 was deposited into this
account from BLUE WATER INTERNET TECHNOLOGY, LLC BOA account ending in previously described. As of January 2013, this account has a balance of $59.17. Because this account received deposits of gambling proceeds, the funds in this account are subject to
49
forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. BLUE WATER INTERNET TECHNOLOGY SPECIAL FUNDS ACCOUNT 138. Bank of America account in the name of BLUE WATER
INTERNET TECHNOLOGY SPECIAL FUNDS ACCOUNT lists Tony Parker & Leslie Collins as the signors on the account. This for-profit corporation and bank account receives proceeds from BLUE WATER INTERNET TECHNOLOGY, LLC BOA account ending in previously described and BLUE WATER INTERNET TECHNOLOGY, LLC PAYROLL BOA account ending in 6071, previously described. 139. Between April 2012 and January 2013, $5,356.00 was deposited into this
account from the aforementioned BLUE WATER INTERNET TECHNOLOGY BOA accounts. As of January 2013, this account has a balance of $2,263.10. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. BLUE WATERS TECHNOLOGIES 140. Bank of America Business Advantage Checking account# was
opened on September 29, 2008 in the name of BLUE WATERS TECHNOLOGIES, at a branch located in Volusia County, Florida. Tony Parker, Cary Hardee, and Leslie L. Collins are listed as the signors on the account. The contact address for this account is listed as 31 Sundunes Circle, Ponce Inlet, Florida, 32127-7053. 141. Between November 11, 2008 and March 31, 2012, a total of approximately
$8,282,982.30 was deposited into this account from AVOTW Affiliates 50, 58, and 60s Bank of America accounts, which, as discussed above, was funded solely with gambling proceeds.
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142.
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. BLUE WATERS TECHNOLOGIES 143. Bank of America Business Economy Checking account# was
opened on December 21, 2009 in the name of BLUE WATERS TECHNOLOGIES, at a branch located in Volusia County, Florida. Tony J. Parker and Leslie Collins are listed as the signors on the account. The contact address for this account is listed as 3300 S. Atlantic Avenue, Daytona Beach Shores, Fl., 32118-6309. 144. Between January 1, 2011 and March 31, 2012, a total of approximately
$987,768.24 was deposited into this account. Of that amount, $987,468.24 was deposited from Blue Waters Technologies Bank of America account ending in illegal proceeds from AVOTW Affiliates 50, 58, and 60. 145. As of March 31, 2012 this account had a balance of $7,691.88. Because this which received
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. BLUE WATERS TECHNOLOGIES 146. Bank of America Business Economy Checking account# was
opened on September 29, 2008 in the name of BLUE WATERS TECHNOLOGIES. Tony Parker and Leslie L. Collins are listed as the signors on the account. The contact address for this account is listed as 31 Sundunes Circle, Ponce Inlet, Florida, 32127-7053.
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147.
Between January 1, 2009 and November 30, 2010, a total of approximately
$406,666.89 was deposited into this account. Of that amount, $386,566.89 was deposited from Blue Waters Technologies Bank of America account ending in illegal proceeds from AVOTW Affiliates 50, 58, and 60. 148. Between January 1, 2011 and March 31, 2012, $411,670.33 was deposited into , which received
this account. Of that amount, $411,190.65 was deposited from Blue Waters Technologies Bank of America account ending in Affiliates 50, 58, and 60. 149. As of March 31, 2012 this account had a balance of $5,779.07. Because this which received illegal proceeds from AVOTW
account received deposits of at least $797,757.54 in gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. BLUE WATERS TECHNOLOGIES, LLC, SPECIAL FUNDS ACCOUNT 150. Bank of America account in the name of BLUE WATERS
TECHNOLOGIES, LLC, SPECIAL FUNDS ACCOUNT lists Tony Parker & Leslie Collins as the signors on the account. 151. Between April 2012 and January 2013, $162,953.17 was deposited into this
account. The bank records reflect the deposits came from 58 Allied Veterans-Payroll-Blue Water, 60 Allied Veterans-Payroll-Blue Water, and 50 Allied Veterans-Payroll-Blue Water. Your affiant believes these deposits came from BOA accounts that receive daily proceeds of gambling centers 50, 58, and 60. 152. As of January 2013, the balance in this account is $16,212.56. Because this
account received deposits of gambling proceeds, the funds in this account are subject to
52
forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. BURNS FAMILY CATTLE LLC 153. Midfirst Bank checking account # held in the name of CHASE
BURNS D/B/A BURNS FAMILY CATTLE LLC was opened on April 2007. Chase Burns and Kristin Burns are listed as the signors on the account. The account was opened in
Oklahoma. The contact address listed for this account is P.O. Box 130, Anadarko, Oklahoma 73005-0130. 154. From January 1, 2009 through December 31, 2009 over $19 million was Over $14.7 million dollars was or Midfirst account
deposited into Midfirst Bank checking account transferred from Bank of America checking account (both discussed above).
Six deposits totaling over $12.8 million from IIT account at Midfirst, account #
One Deposit of $1.9 million from IIT account at Bank of America Account Ten deposits totaling over $3 million from Chase Burns POD Account at Midfirst Account (discussed below).
Over $940,000 from an unknown account at International Bank of Commerce. Over $450,000 from another IIT account (additional account at Anadarko Bank and Trust).
Over $200,000 from PITX Internet LLC (Burns company that was raided by law enforcement discussed in Master Affidavit).
Over $185,000 of miscellaneous deposits.
53
155.
From January 1, 2010 through December 31, 2010 over $730,000 was Over $59,000 dollars was or Midfirst account discussed
(which are both discussed above) or Midfirst account below.
Two deposits totaling $57,000 from Chase Burns Trustee for the Chase Burns Trust Account at Midfirst account (discussed below)
156.
One Deposit of $2,000 from IITs account at Bank of America Account Unknown deposits over $620,000 from International Bank of Commerce. Over $60,000 of miscellaneous deposits. From January 1, 2011 through December 31, 2011 over $297,000 was Over $289,000 was
deposited into Midfirst Bank checking account transferred from Midfirst account # discussed below.
Twelve deposits totaling $289,000 from Chase Burns Trustee for the Chase Burns Trust Account at Midfirst account (discussed below).
One deposit over $8,000 which was a cashiers check from Anadarko Bank & Trust Company.
157.
From January 1, 2012 through February 28, 2012 $110,000 was deposited into All $110,000 was transferred from Midfirst
Midfirst Bank checking account account 158. discussed below.
As of February 29, 2012, the balance in this account was $9,848.83. Because
this account was used to launder the proceed of the commingling of the funds which concealed the nature and source of the gambling proceeds, the proceeds are subject to
54
forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702 BURNS FAMILY LAND CO., LLC 159. MidFirst Bank Free Business Checking account titled CHASE
BURNS-BURNS FAMILY LAND CO., LLC (formally CHASE BURNS DBA OK COIN), was opened on or about April 25, 2003. New Account Information documents dated April 25, 2003 identifies the Account Title as Chase Burns DBA Cb Farms (a Sole Proprietorship with Chase BURNS listed as the account Owner). The documents list both the business address and the personal addresses for Chase Burns as 111 NW 2nd St., Apt. 134, Anadarko, Oklahoma 73005-2801. On December 29, 2006 a Resolution of Sole Proprietorship On
replacement document was signed adding Kristin BURNS as an Authorized Agent.
November 23, 2010, New Account replacement documents retitle the account as Chase Burns-Burns Family Land Co., LLC with Chase Burns listed as the Manager and Kristin P. Burns listed as an Authorized Signor. The documents identify the business address as P.O. Box 130, Anadarko, Oklahoma 73005-2637 and the addresses for Chase and Kristin P. BURNS as 106 E. Kansas Ave., Anadarko, Oklahoma 73005-2637. Between January 2007 and February 2012, approximately $4,021,281.32 was deposited into this account, at least $2,312,154.92 of which appears to be proceeds of gambling violations: $1,503,974.79 was deposited in a series of cash transactions between January 2007 and February 2012. The cash transactions analyzed in this account are consistent with those which have mirrored transactions at AVOTW and/or the Affiliates. These transactions are also indicative of cash intensive business
55
operations such as coin (cash) operated gaming/gambling devices, kiosks, and/or vending machines. $30,700.00 was deposited between January 01, 2010 and December 31, 2010 from the Brad D. Skidmore (Crescent Bank account ) which
received illegal proceeds directly and/or indirectly from AVOTW and/or the Affiliates. $313,956.19 was deposited between January 01, 2007 and February 29, 2012 from the Chase Burns Trustee for the Chase Burns Trust (MidFirst Bank account ) which received illegal proceeds directly and/or indirectly
from AVOTW and/or the Affiliates. $1,485.00 was deposited between January 01, 2007 and December 31, 2007 by way of a Money Gram/Money Order with IIT (International Internet Technologies, LLC) as the Remitter. IIT received illegal proceeds directly and/or indirectly from AVOTW and/or the Affiliates. $415,038.94 was deposited between January 01, 2009 and December 31, 2009 from International Internet Technologies, LLC (Bank of America account , which received illegal proceeds directly and/or indirectly from AVOTW and/or the Affiliates. $47,000.00 was deposited between January 01, 2011 and December 31, 2011, from Burns Family Cattle, LLC (MidFirst Bank account which
received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates. 160. As of February 29, 2012 this account held a balance of $2,610.43. Because
this account received deposits of at least $2,312,154.92 in gambling proceeds, the funds are
56
subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. BUSINESS CENTER UNLIMITED, INC 161. Bank of America Business Economy Checking account# was
opened on October 7, 2010 in the name BUSINESS CENTER UNLIMITED, at a branch located in Tallahassee, Florida. Reginald P. Medlin and John P. Medlin are listed as the signors on the account. The contact address for this account is listed as 7130 W. Tennessee Street, Tallahassee, Fl., 32304-9324. 162. Between January 20, 2011 and March 31, 2012, a total of approximately
$1,001,426.47 was deposited into this account that came directly from AVOTW Affiliate 53 Bank of America account which, as discussed above, was funded solely with gambling. 163. As of March 31, 2012, this account had a balance of $12,948.60. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. CAPITAL CITY INTERNET CENTER, INC. 164. Bank of America Business Economy Checking account was
opened on May 4, 2011 in the name CAPITAL CITY INTERNET CENTER, INC., at a branch located in Tallahassee, Florida. Reginald P. Medlin and John Fannin are listed as the
signors on the account. The contact address for this account is listed as 3030 S. Monroe Street, Suite 5B, Tallahassee, Florida, 32301-6961. 165. Between May 4, 2011 and March 31, 2012, a total of approximately
$649,233.58 was deposited into this account that came directly from AVOTW Affiliate 79
57
Bank of America account which, as discussed above, was funded solely with gambling proceeds. 166. As of March 31, 2012, this account had a balance of $15,821.41. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. CCS MANAGEMENT GROUP INC., HOLLY HILL LOCATION ACCOUNT 167. Bank of America account in the name of CCS MANAGEMENT
GROUP lists Brandon S Weaver and Bennie James Prince as the signors on the account. This for-profit corporation and bank account replaced the gambling center previously identified as Affiliate 32 and the bank account identified as Affiliate 32. 168. Your affiant believes that the daily proceeds of the gambling center previously
identified as Affiliate 32 are being deposited into this account. The gambling proceeds are then laundered and transferred to other AVOTW Enterprise accounts on a weekly basis including Allied Veterans Management Group Inc. and I.I.T. 169. Between April 2012 and January 2013, approximately $1,552,754.03 was
deposited into this account that your affiant believes is the daily proceeds from gambling center identified as Affiliate 32. 170. As of January 2013, the balance in this account is $124,480.94. Because this
account was utilized to launder gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702.
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CCS MANAGEMENT GROUP INC., HOLLY HILL SAVINGS ACCOUNT 171. Bank of America account in the name of CCS MANAGEMENT
GROUP INC., HOLLY HILL SAVINGS ACCOUNT lists Brandon S Weaver and Bennie James Prince as the signors on the account. 172. Between April 2012 and January 2013, $50,770.14 was deposited into this
account from BOA account identified as CCS MANAGEMENT GROUP INC., HOLLY HILL LOCATION ACCOUNT, previously described, that receives daily proceeds from gambling center Affiliate 32. 173. As of January 2013, this account has a balance of $22,919.99. Because this
account was utilized to launder gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. COASTAL GAMES LLC, DBA HOT SPOT, LESLIE L. COLLINS 174. Bank of America Business Economy Checking account was
opened on July 19, 2007 in the name COASTAL GAMES LLC, DBA HOT SPOT, LESLIE L. COLLINS, at a branch located in Volusia County, Florida. Leslie Collins, Tony Parker, and Cary Hardee are listed as the signors on the account. The contact address for this account is listed as P.O. Box 290820, Port Orange, Fl., 32129-0820. 175. Between January 1, 2008 and March 31, 2012, a total of approximately
$19,613,785.37 was deposited into this account that came directly from AVOTW Affiliates 35, 36, and 49 Bank of America accounts which, as discussed above, were funded solely with gambling proceeds. As of March 31, 2012, this account had a balance of $208,833.72.
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176.
Between April 2012 and January 2013, $4,754,736.17 was deposited into this
account that your affiant believes is the daily proceeds of gambling centers previously identified as Affiliate 35 and Affiliate 36. This account is then utilized to transfer the proceeds to other AVOTW Enterprise bank accounts. 177. As of January 2013, this account has a balance of $155,895.39. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. COASTAL GAMES LLC, PAYROLL ACCOUNT 178. Bank of America Business Economy Checking account# was
opened on December 21, 2009 in the name of COASTAL GAMES LLC, PAYROLL ACCOUNT at a branch located in Volusia County, Florida. Tony J. Parker and Leslie Collins are listed as the signors on the account. The contact address for this account is listed as P.O. Box 290820, Port Orange, Fl., 32129-0820. 179. Between December 21, 2009 and November 30, 2010, a total of approximately
$1,367,914.85 was deposited into this account that came directly from Coastal Games Bank of America account ending in , which received its funds directly from AVOTW Affiliates
35, 36, and 49 Bank of America accounts which, as discussed above, were funded solely with gambling proceeds. 180. Between January 1, 2011 and March 31, 2012, a total of approximately
$1,980,096.25 was deposited into this account that came directly from Coastal Games Bank of America account ending in which received its funds directly from Allied Veterans
Affiliate 35, 36, and 49s Bank of America accounts which, as discussed above, were funded
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solely with gambling proceeds. $39,727.91. 181.
As of March 31, 2012 this account had a balance of
account that came directly from Coastal Games Bank of America account ending in described above that receives direct deposits from gambling centers. As of January 2013, this account has a balance of $59,026.35. Because this account received deposits of
gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. COASTAL GAMES SPECIAL FUNDS ACCOUNT 182. Bank of America account in the name of COASTAL GAMES
SPECIAL FUNDS ACCOUNT lists Tony Parker & Leslie Collins as the signors on the account. 183. Between April 2012 and January 2013, this account received $200,245.72 from , described above that receives
Coastal Games Bank of America account ending in
direct deposits from gambling centers. As of January 2013, the balance in this account is $18,558.02. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. COMPTRAC, INC. 184. Bank of America account in the name of COMPTRAC, INC.
lists Aamir Waheed and Donald Powell as the signors on the account. Your affiant believes the financial records show that this for-profit corporation and bank account is being utilized to launder illegal proceeds from AVOTW gambling centers.
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185.
Your affiant believes that the daily proceeds of the gambling center previously The gambling proceeds are
identified as Affiliate 91 are being deposited into this account.
then laundered and transferred to other AVOTW Enterprise accounts on a weekly basis including Allied Veterans Management Group Inc. and I.I.T. 186. Between April 2012 and January 2013, $343,246.10 was deposited into this
account that your affiant believes is the daily proceeds of the gambling center identified as Affiliate 91. As of January 2013, the balance in this account is $25,954.21. 187. Between August 1, 2012 and September 30, 2012, $2,116.36 was transferred
to Allied Veterans Management Group Inc. account and $3,359.50 was transferred to I.I.T. account. This banking activity is consistent with the illegal banking previously described. Because this account was utilized to launder gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. DAVIS INTERNET MANAGEMENT CO 188. Bank of America Business Economy Checking account was
opened since at least July 2010 in the name of DAVIS INTERNET MANAGEMENT CO at an unknown branch. Michael S. Davis, Jonathan T. Shave and Diane M. Davis are listed as the signors on the account. The contact address for this account is listed as 107 Hogan Coweta Road, Hogansville, GA 30230-2852. 189. Between July 7, 2010 and March 31, 2012, a total of approximately
$1,114,331.25 was deposited into this account directly from AVOTW Affiliate 46 Bank of America account which, as discussed above, was funded solely with gambling proceeds. 190. As of April 30, 2012, this account had a balance of $51,973.13.
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191.
account that your affiant believes is the daily proceeds of the gambling center previously identified as Affiliate 46. As of January 2013, the balance in this account is $17,253.23. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. DAVIS INTERNET MANAGEMENT CO. 192. Bank of America account in the name of DAVIS INTERNET
MANAGEMENT CO. lists Michael Davis as the signor on the account. 193. Between April 2012 and January 2013, $339,480.74 was deposited into this in the name of Davis Internet Management Co.,
account from BOA account ending in
described above. As previously stated, Davis Internet Management Co. account ending in receives daily proceeds from gambling center Affiliate 46. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. DEVELOPCO, INC 194. Regions Bank Lifegreen Checking for Business account was
opened on January 11, 2010 in the name of DEVELOPCO INC. Regions bank advised signature cards were not on file for this account. The contact address for this account is 2295 S Hiawassee Road Ste. 214, Orlando, FL 32835-8747. 195. Between January 11, 2010 and April 10, 2012, $1,442,551.36 was deposited
into this account, of which at least $882,000.00 appears to be proceeds of gambling:
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$624,250.00 was deposited from Tariq and Sadia Waheeds Bank of America account ending in , which indirectly received illegal proceeds from AVOTW
Affiliates 59, 66, 67, 74 and 77. $187,800.00 was deposited from Aamir Waheeds Bank of America account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 41, 51, 54, 59, 66, 67, 74 and 78. $5,000.00 was deposited from Tariq Waheeds Region Bank account ending in , which indirectly received illegal proceeds from AVOTW Affiliates 59, 66, 67, 74 and 77. $8,950.00 was deposited from Tariq Waheeds Region Bank account ending in , which indirectly received illegal proceeds from AVOTW Affiliates 59, 66, 67, 74 and 77. $56,000.00 was deposited from Realvice, Inc Fifth Third Bank account ending in , which indirectly received illegal proceeds from AVOTW Affiliates 41,
51, 54, 59, 66, 67, 74 and 78. 196. As of April 10, 2012, this account had an ending balance of $294,312.58.
Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. DIGITRAC INC. 197. Bank of America Business Advantage Checking account# was
opened on November 25, 2008 in the name DIGITRAC INC., at a branch located in Volusia
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County, Florida. Aamir Waheed is listed as the signor on the account. The contact address for this account is listed as 301 N. Pine Meadow Drive Suite E, Debary, Florida, 32713-2605. 198. Between January 2008 and March 31, 2012, a total of approximately
$17,946,217.85 was deposited into this account that came directly from AVOTW Affiliates 66, 67, 74, and 77s Bank of America accounts which, as discussed above, were funded solely with gambling proceeds. 199. As of March 31, 2012, this account had a balance of $157,543.73. Because
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. DMD BUSINESS MANAGEMENT, INC 200. Bank of America Business Economy Checking account was
opened on November 25, 2011 in the name of DMD BUSINESS MANAGEMENT, INC at the Eight Street Banking Center. Diane Davis and Michael S Davis are listed as the signors on the account. The contact address for this account is 107 Hogan Coweta Road, Hogansville, GA 30230-2852. 201. Between November 25, 2011 and April 30, 2012, a total of approximately
$40,599.00 was deposited into this account, of which $28,000.00 appears to be proceeds of gambling: $28,000.00 was deposited from Davis Internet Management Co Bank of America account ending in Affiliate 46. , which received illegal proceeds from AVOTW
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202.
As of April 30, 2012, this account had an ending balance of $4,195.99.
Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. ENZYME CONSULTANTS, LLC. 203. Bank of America Business Economy Checking account was
opened on May 28, 2009 in the name ENZYME CONSULTANTS, LLC. at a branch located in Jacksonville, Florida. Nelson Cuba and Robert B. Freitas are listed as the signor on the account. The contact address for this account is listed as P.O. Box 1101, Jacksonville, Florida, 32201-1101 that has been utilized by the FOP since March 6, 2011. 204. Between September 4, 2009 and March 31, 2012, a total of approximately
$618,500.00 was deposited into this account from Seaside Internet Bank of America account which received deposits from AVOTW Affiliates 34, 43, 44, 57, and 68 which as discussed above, were funded solely with gambling proceeds. As of March 31, 2012, this account had a balance of 4,817.03. 205. Between April 2012 and January 2013, $145,900.00 was deposited into this that receives funds from illegal
account from Seaside Internet BOA account ending in
gambling centers. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. FREE ENTRY CLAY COUNTY LLC., OPERATING ACCOUNT 206. Bank of America Business Economy Checking account was
opened on November 15, 2010 in the name FREE ENTRY CLAY COUNTY LLC.,
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OPERATING ACCOUNT at a branch located in Jacksonville, Florida.
Mazen Salloum,
Bradley D. Skidmore, and Stephanie Bennett are listed as the signors on the account. The contact address for this account is listed as 266 Blanding Blvd Ste 1, Orange Park, FL 32073-3343. 207. Between February 16, 2011 and March 31, 2012, a total of approximately
$2,443,595.68 was deposited into this account that came directly from AVOTW Affiliate 71 Bank of America account which, as discussed above, was funded solely with gambling proceeds. As of March 31, 2012, this account had a balance of $15,524.94. 208. Between April 2012 and January 2013, $2,124,385.54 was deposited into this
account. The bank records show the deposits came from payroll Allied Veterans 71. Your affiant believes these funds were transferred from FREE ENTRY CLAY COUNTY BOA account ending in 209. .
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. FREE ENTRY CLAY COUNTY LLC. LOCATION 71 ACCOUNT 210. Bank of America account in the name of FREE ENTRY CLAY
COUNTY LLC., LOCATION 71 ACCOUNT lists Brad Skidmore, Rebecca Stevens, Mazen Salloum, and Terri LeClaire as signors on the account.. This for-profit corporation and bank account replaced the gambling center previously identified as Affiliate 71 and the bank account identified as Affiliate 71.
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211.
Between April 2012 and January 2013, $2,977,910.65 has been deposited into
this account which your affiant believes is the daily proceeds from the gambling center identified as Affiliate 71. The gambling proceeds are then laundered and transferred to other AVOTW Enterprise accounts on a weekly basis including Allied Veterans Management Group Inc. and I.I.T. 212. As of January 2013, the balance in this account is $22,991.20. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. FREE ENTRY CLAY COUNTY LLC. SPECIAL FUND ACCOUNT 213. Bank of America account in the name of FREE ENTRY CLAY The signors on this account are Mazen
COUNTY LLC. SPECIAL FUNDS ACCOUNT.
Salloum, Brad Skidmore, Rebecca Stevens, and Terri LeClaire. This for-profit corporation and bank account is being utilized in conjunction with the previously mentioned FREE ENTRY CLAY COUNTY LLC. bank accounts to receive and launder proceeds generated from the gambling center previously known as Affiliate 71. 214. Between April 2012 and January 2013, $131,980.93 has been deposited into
this account. The bank records reflect the deposits were made from payroll Elite 71. Your affiant believes the funds were transferred from FREE ENTRY CLAY COUNTY BOA account ending in 215. As of January 2013, the balance in this account is $13,978.04. Because this
account was utilized to launder illegal gambling proceeds, the funds in this account are
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subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. GAINESVILLE INTERNET SERVICES, LLC, OPERATING ACCOUNT 216. Bank of America Business Economy Checking account was
opened on February 26, 2010 in the name GAINESVILLE INTERNET SERVICES, LLC, OPERATING ACCOUNT, at a branch in Columbia County, Florida. Michael Graham, Joey Harrington, and Elaine Harrington are listed as the signor on the account. The contact
address for this account is listed as 103 N. Main Street, Tabor City, NC. 28463-1617. 217. Between March 1, 2010 and March 31, 2012, a total of approximately
$4,572,332.16 was deposited into this account that came directly from AVOTW Affiliate 72 Bank of America account which, as discussed above, was funded solely with gambling proceeds. 218. As of March 31, 2012, this account had a balance of $16,471.24. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. GAME ADVICE, INC. 219. Bank of America Business Advantage Checking account was
opened on September 14, 2007 in the name GAME ADVICE, INC., at a branch located Merritt Island, Brevard County, Florida. Brandon Weaver and Aamir Waheed are listed as the signor on the account. The contact address for this account is listed as 301 N. Pine Meadow Drive, Suite E, Debary, Florida, 32713-2374.
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220.
Between January 1, 2008 and March 31, 2012, a total of approximately
$14,893,823.29 was deposited into this account that came directly from AVOTW Affiliates 41 and 54 Bank of America accounts which, as discussed above, were funded solely with gambling proceeds. 221. As of March 31, 2012, this account had a balance of $107,596.17. Because
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. GINLIN, LLC 222. Bank of America Business Advantage Checking account was
opened on February 26, 2010 in the name GINLIN, LLC, at a branch located at Weeki Wachee, Florida. Anthony Alascia and Genevieve DiGiovanni are listed as the signors on the account. The contact address for this account is listed as 7269 Forest Oaks Blvd, Spring Hill, FL 34606-2330. 223. Between March 9, 2010 and March 31, 2012, a total of approximately
$7,007,230.03 was deposited into this account that came directly from AVOTW Affiliates 45, 52, and 70 Bank of America accounts which, as discussed above, were funded solely with gambling proceeds. 224. As of March 31, 2012, this account had a balance of $52,552.89. Because this
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GINLIN, LLC PAYROLL ACCOUNT 225. Bank of America Business Economy Checking account was
opened on February 26, 2010 in the name GINLIN, LLC PAYROLL ACCT at a branch located at Weeki Wachee, Florida. Anthony Alascia is listed as the signor on the account. The contact address for this account is listed as 7269 Forest Oaks Blvd, Spring Hill, FL 34606-2330. 226. Between March 9, 2010 and March 31, 2012, a total of approximately
$360,750.00 was deposited into this account that came directly from AVOTW Affiliates 45, 52, and 70 Bank of America accounts which, as discussed above, were funded solely with gambling proceeds. 227. Between March 9, 2010 and March 31, 2012, a total of approximately
$212,136.43 was deposited into this account from GINLIN, LLC Bank of America account ending in which received illegal proceeds from AVOTW Affiliates 45, 52, and 70 which,
as discussed above, were funded solely with gambling proceeds. 228. As of March 31, 2012, this account had a balance of $3,993.05. Because this
account received deposits of at least $572,886.43 in gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. GINLIN, LLC 229. Wells Fargo Bank account in the name of GINLIN, LLC. This for-
profit corporation and bank account is believed to have replaced the gambling centers previously identified as Affiliate 45, 52, 70 and 76 and the bank accounts identified as Affiliate 45, 52, 70 and 76.
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230.
Your affiant believes that the daily proceeds of the gambling centers previously
identified as Affiliates 45, 52, 70 and 76 are being deposited into this account. The gambling proceeds are then laundered and transferred to other AVOTW Enterprise accounts on a weekly basis including Allied Veterans Management Group Inc. and I.I.T. 231. From August 1, 2012 through September 30, 2012, $27,301.56 was transferred
to Allied Veterans Management Group Inc. account and $160,390.79 was transferred to I.I.T. account. This banking activity is consistent with the illegal banking previously described. Because this account was utilized to launder gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. GIVE IT AWAY FOUNDATION 232. MidFirst Bank Free Business Checking account was opened on
or about December 22, 2011 in the name of Give It Away Foundation (a not for profit corporation) with Chase Burns listed as the Manager and Kristin P. Burns as an Authorized Signor. Account documents identify the business address for Give It Away Foundation as P.O. Box 130, Anadarko, Oklahoma 73005. The contact address listed for both Chase Burns and Kristin P. Burns is 106 E. Kansas Avenue, Anadarko, Oklahoma 73005-2637. 233. Between December 22, 2011 and February 29, 2012, approximately
$2,000,000.00 was deposited into this account, at least $2,000,000.00 of which appears to be proceeds of gambling violations: $2,000,000.00 was deposited from the Chase Burns Trustee for the Chase Burns Trust (MidFirst Bank account ) which received illegal
proceeds directly or indirectly from AVOTW and/or the Affiliates.
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234.
As of February 29, 2012 this account held a balance of $999,964.19. Because
this account received deposits of at least $2,000,000.00 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. GRANT PARK, LLC 235. Bank of America Business Economy Checking account was
opened on January 26, 2010 in the name GRANT PARK LLC., at a branch located in Volusia County, Florida. Tony J. Parker, Leslie Collins and Cary Hardee are listed as the signors on the account. The contact address for this account is listed as P.O. Box 290820, Port Orange, Florida, 32129-0820. 236. Between February 9, 2010 and March 31, 2012, a total of approximately
$4,562,001.51 was deposited into this account that came directly from AVOTW Affiliate 31 Bank of America account which, as discussed above, was funded solely with gambling proceeds. As of March 31, 2012, this account had a balance of $333,004.38. 237. Between April 2012 and January 2013, $2,515,761.83 was deposited into this
account that your affiant believes is the daily proceeds from the gambling center identified as Affiliate 31. This account is then being utilized to transfer illegal funds to other AVOTW Enterprise bank accounts. 238. As of January 2013, this account has a balance of $305,749.76. Because this
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GRANT PARK, LLC, PAYROLL ACCOUNT 239. Bank of America Business Economy Checking account# was
opened on January 26, 2010 in the name of GRANT PARK, LLC, PAYROLL ACCOUNT, at a branch located in Volusia County, Florida. Tony J. Parker and Leslie Collins are listed as the signor on the account. The contact address for this account is listed as P.O. Box 290820, Port Orange, Fl., 32129-0820. 240. Between January 26, 2010 and March 31, 2012, a total of approximately
$695,173.49 was deposited into this account that came directly from GRANT PARK, LLC Bank of America account ending in , which received its funds directly from AVOTW
Affiliate 31 Bank of America account which, as discussed above, were funded solely with gambling proceeds. As of March 31, 2012 this account had a balance of $3,680.36. 241. Between April 2012 and January 2013, $403,055.72 was deposited into this , which receives
account from GRANT PARK, LLC Bank of America account ending in
its funds directly from the gambling center identified as Affiliate 31. As of January 2013, this account has a balance of $7,747.26. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. GRANT PARK, LLC 242. Bank of America Business Interest Maximizer account was
opened on April 28, 2010 in the name of GRANT PARK, LLC at the Westport banking center located in Port Orange, Florida. Tony J. Parker, Leslie Collins and Cary Hardee are listed as the signors on the account. The contact address for this account is listed as 1050 US Highway 27 Ste. 20, Clermont, FL 34714-7522.
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243.
Between April 28, 2010 and March 31, 2012, $29,381.29 was deposited into
this account, of which approximately $29,381.29 appears to be proceeds of gambling: $29,178.90 was deposited from GRANT PARK, LLC Bank of America account ending in which received illegal proceeds from AVOTW Affiliate 31.
$202.39 was deposited from interest earned from the money deposited from GRANT PARK, LLC Bank of America account ending in
244.
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. GRANT PARK SPECIAL FUNDS ACCOUNT LLC 245. Bank of America account in the name of GRANT PARK
SPECIAL FUNDS ACCOUNT LLC lists Tony Parker & Leslie Collins as the signors on the account. 246. Between April 2012 and January 2013, $107,385.15 was deposited into this
account. The deposits indicate they came from 31 Allied Veterans payroll. Your affiant believes these deposits were made via ERG. As of January 2013, the balance in this
account is $10,929.22. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702.
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GRANT PARK, LLC OPERATING ACCOUNT 247. Bank of America account in the name of GRANT PARK LLC,
OPERATING ACCOUNT lists Tony Parker, Leslie Collins, Cary Hardee, and Sharon Stackpole as the signors on the account. 248. account. Between April 2012 and January 2013, $63,000.00 was deposited into this
The records show the deposits were money transfers from Grant Park BOA that received the daily gambling proceeds from Affiliate 31.
account ending in 249.
As of January 2013 this account had a balance of $2,597.76. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. GULF INTERNET SERVICES LLC 250. Bank of America Business Economy Checking account was
opened on July 28, 2011 in the name GULF INTERNET SERVICES LLC., at a branch located Columbia County, Florida. Michael Graham, Joseph Harrington, and Elaine
Harrington are listed as the signors on the account. The contact address for this account is listed as 103 N. Main Street, Tabor City, NC.,28463-1617. 251. Between September 14, 2011 and March 31, 2012, a total of approximately
$427,561.73 was deposited into this account that came directly from AVOTW Affiliates 47 and 85 Bank of America accounts which, as discussed above, were funded solely with gambling proceeds. 252. As of March 31, 2012, this account had a balance of $66,053.08. Because this
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forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. HORRY TECHNOLOGIES, LLC 253. Bank of America Business Advantage account was opened on
December 4, 2008 in the name HORRY TECHNOLOGIES LLC., at a branch located in Volusia County, Florida. Tony J. Parker, Leslie Collins, Cary Hardee, and George Sloane III are listed as the signors on the account. The contact address for this account is listed as 31 Sundunes Circle, Ponce Inlet, Florida, 32127-7053. 254. Between February 24, 2009 and March 31, 2012, a total of approximately
$1,886,303.09 was deposited into this account that came directly from AVOTW Affiliate 65 Bank of America account which, as discussed above, was funded solely with gambling proceeds. 255. Between April 2012 and January 2013, $1,085,873.33 was deposited into this
account which your affiant believes are the daily proceeds from gambling center Affiliate 65. This account is then utilized to transfer proceeds to other AVOTW Enterprise bank accounts. 256. As of January 2013, this account has a balance of $31,538.60. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. HORRY TECHNOLOGIES, LLC OPERATING ACCOUNT 257. Bank of America Business Economy Checking account was
opened on December 4, 2008 in the name of HORRY TECHNOLOGIES, LLC OPERATING ACCOUNT at the South Nova Road banking center in Port Orange, Florida. Tony J. Parker,
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Leslie Collins, Cary G. Hardee and Stephanie Weeks are listed as the signors on the account. The contact address for this account is 31 Sundunes Circle, Ponce Inlet, FL 321277053. 258. Between February 2009 and November 30, 2010, $90,800.00 was deposited
into this account that came directly from HORRY TECHNOLOGIES, LLC account ending in which received illegal proceeds from AVOTW Affiliate 65 which, as discussed above, was funded solely with gambling proceeds. 259. $79,800.00 Between January 1, 2011 and March 31, 2012, a total of approximately was deposited into this account that came directly from HORRY
TECHNOLOGIES, LLC account ending in
, which received illegal proceeds from
AVOTW Affiliate 65 which, as discussed above, was funded solely with gambling proceeds. 260. Between April 2012 and January 2013, $41,000.00 was deposited into this previously
account from HORRY TECHNOLOGIES, LLC BOA account ending in described that receives daily proceeds from gambling center Affiliate 65. 261.
As of January 2013, this account has a balance of $3,237.75. Because this
account received deposits of at least $170,600.00 in gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. HORRY TECHNOLOGIES, LLC PAYROLL ACCOUNT 262. Bank of America account in the name of HORRY
TECHNOLOGIES LLC., PAYROLL ACCOUNT lists Tony Parker, Cary Hardee, & Leslie Collins as the signors on the account. This for-profit corporation and bank account receives deposits identified as coming from Allied Veterans 65.
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263.
Between April 2012 and January 2013, $175,377.78 was deposited into this
account that came from BOA account identified as HORRY TECHNOLOGIES, LLC ending in 0617, previously described which your affiant believes is a portion of the daily proceeds from gambling center Affiliate 65. 264. As of January 2013, this account has a balance of $6,999.99. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. HORRY TECHNOLOGIES LLC SPECIAL FUNDS ACCOUNT 265. Bank of America account in the name of HORRY
TECHNOLOGIES SPECIAL FUNDS ACCOUNT lists Tony Parker & Leslie Collins as the signors on the account. This for-profit corporation and bank account receives deposits identified as coming from Allied Veterans 65. 266. Between April 2012 and January 2013, $39,110.87 was deposited into this
account that came from Allied Veterans 65 which your affiant believes is a portion of the daily proceeds from gambling center Affiliate 65. 267. As of January 2013, this account has a balance of $5,700.78. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. INFOHUB INC. 268. Bank of America Business Economy Checking account was
opened on August 4, 2011 in the name INFOHUB INC. at a branch located Volusia County,
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Florida. Aamir Waheed is listed as the signor on the account. The contact address for this account is listed as 301 N. Pine Meadow Drive OFC, Debary, Florida, 32713-2376. 269. Between August 17, 2011 and March 31, 2012, a total of approximately
$188,824.97 was deposited into this account that came directly from AVOTW Affiliates 86 and 91 Bank of America accounts which, as discussed above, were funded solely with gambling proceeds. 270. As of March 31, 2012, this account had a balance of $29,082.85. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. INFOVICE INC. 271. Bank of America Business Advantage Checking account was
opened on August 1, 2008 in the name INFOVICE INC. at a branch located in Volusia County, Florida. Aamir Waheed is listed as the signor on the account. The contact address for this account is listed as 3299 S. Babcock Street, Melbourne, Florida, 32901-6926. 272. Between September 23, 2008 and March 31, 2012, a total of approximately
$6,569,680.56 was deposited into this account that came directly from AVOTW Affiliates 59 Bank of America account which, as discussed above, was funded solely with gambling proceeds. 273. As of March 31, 2012, this account had a balance of $48,289.19. Because this
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I.N.H. MANAGEMENT CO. 274. Bank of America Business Economy Checking account was
opened on February 8, 2008 in the name I.N.H. MANAGEMENT CO. at a branch located in Volusia County, Florida. Bennie Prince, Shaheen Mosavi, Peggy Prince, and Cynthia
Weaver are listed as the signors on the account. The contact address for this account is listed as 809 Riviera Bella Drive, Debary, Florida, 32713-5434. 275. Between April 15, 2008 and March 31, 2012, a total of approximately
$6,566,964.11 was deposited into this account that came directly from Allied Veterans Affiliate 32s Bank of America accounts which, as discussed above, was funded solely with gambling proceeds. 276. As of March 31, 2012, this account had a balance of $71,638.77. Because
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. INTELITEK INC. 277. Bank of America Business Advantage Checking account was
opened on September 17, 2010 in the name INTELITEK INC. at a branch located in Volusia County, Florida. Aamir Waheed and Cheri S. Black are listed as the signors on the account. The contact address for this account is listed as 301 N. Pine Meadow Drive Suite E, Debary, Florida, 32713-2374. 278. Between December 22, 2010 and March 31, 2012, a total of approximately
$1,731,868.49 was deposited into this account that came directly from AVOTW Affiliate 51
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Bank of America accounts which, as discussed above, were funded solely with gambling proceeds. 279. As of March 31, 2012, this account had a balance of $34,424.06. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. J&R BUSINESS CENTER INC. 280. Bank of America account in the name of J&R BUSINESS
CENTER Inc. lists Reginald Medlin as the signor on the account. Your affiant believes the financial records show that this for-profit corporation is receiving the daily illegal proceeds from the gambling center identified as J & R Business Center. 281. Between April 2012 and January 2013, $360,712.67 was deposited into this
account which your affiant believes was in whole or part, the illegal proceeds of the aforementioned gambling center. 282. As of January 2013, this account had a balance of $2,189.47. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. J & R BUSINESS CENTER INC. 283. Bank of America account in the name of J&R BUSINESS
CENTER Inc. lists Reginald Medlin as the signor on the account. This account received funds in the amount of $1,546.00 that was transferred from J & R Business Center BOA
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account ending in center. 284.
previously described, that received illegal proceeds from a gambling
As of January 2013, the balance in this account is $399.20. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. JACKSONVILLE F.O.P. FOUNDATION INC. 285. Bank of America Business Economy Checking account was
opened on August 12, 2008 in the name JACKSONVILLE F.O.P. FOUNDATION INC at a branch located in, Jacksonville, Florida. Nelson Cuba is listed as the signor on the account. The contact address for this account is listed as 5530 Beach Blvd., Jacksonville, Florida, 32207-5161. 286. Between December 9, 2008 and March 31, 2012, a total of $515,900.60 was
deposited into this account that came directly from AVOTW Affiliate 46 Bank of America account which, as discussed above, was funded solely with gambling proceeds. 287. As of March 31, 2012, this account had a balance of $85,116.07. Because this
account received deposits of gambling proceeds the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. JACKSONVILLE FRATERNAL ORDER OF POLICE 288. account On or about February 18, 2005, Nelson Cuba opened BBVA Compass Bank titled JACKSONVILLE FRATERNAL ORDER OF
number
POLICE. The authorized signors on the account were Nelson Cuba as President, Robert
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Freitas as Vice President, David Kilcrease as Treasurer, D. Rene Angers as Office Administrator, and Shelley Lindsey as Office Assistant. 289. A review of Bank of America account number Jacksonville
FOP Foundation, Inc., previously described, revealed that a total of six (6) withdrawal transactions were conducted since the account was opened (08/12/08). All the withdrawals were checks written by Nelson Cuba from the Bank of America Jacksonville FOP Foundation, Inc. account (account number Each check was made payable
to the Jacksonville FOP Foundation and was subsequently deposited into BBVA Compass Bank account number , titled FOP Foundation. The six (6) checks totaled
$420,000.00. A synopsis of check withdrawal activity from the Bank of America Jacksonville FOP Foundation, Inc. account (account number is included below:
DATE
CHECK NUMBER
AMOUNT
WRITTEN BY
PAYABLE TO
09/24/09 12/30/09 06/14/10 10/15/10 03/16/11 09/30/11
991 992 993 994 995 996
$50,000.00 $50,000.00 $90,000.00 $50,000.00 $90,000.00 $90,000.00
Nelson Cuba Nelson Cuba Nelson Cuba Nelson Cuba Nelson Cuba Nelson Cuba
FOP Foundation FOP Foundation FOP Foundation FOP Foundation FOP Foundation FOP Foundation
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290.
Because this account received deposits totaling $420,000.00 of gambling
proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. JM LAND INVESTMENTS, LLC 291. Horry County State Bank Free Business Checking account was
opened on March 5, 2010 in the name of JM LAND INVESTMENTS, LLC in Loris, South Carolina. Michael W. Graham and Joseph S. Harrington are listed as the signors on the account. The contact address for this account is 103 N Main Street, Tabor City, NC 28463. 292. Between January 1, 2011 and February 29, 2012, a total of approximately
$33,600.00 was deposited from LIVE OAK INTERNET SERVICES, LLC Bank of America account ending in which received illegal proceeds from AVOTW Affiliate 42 which, as
discussed above, was funded solely with gambling proceeds. 293. As of February 29, 2012 this account had a balance of $24,072.51. Because
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. LAKE CITY INTERNET SERVICES, LLC OPERATING ACCOUNT 294. Bank of America Business Advantage Checking account was
opened on March 2, 2010 in the name LAKE CITY INTERNET SERVICES, LLC. OPERATING ACCOUNT at a branch located in Columbia County, Florida. Michael
Graham, Joey Harrington, and Elaine Harrington are listed as the signor on the account. The contact address for this account is listed as 103 N. Main Street, Tabor City, NC., 284631617.
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295.
Between March 2010 and March 31, 2012, a total of approximately
$3,289,103.96 was deposited into this account that came directly from AVOTW Affiliate 56 Bank of America account which, as discussed above, was funded solely with gambling proceeds. 296. As of March 31, 2012, this account had a balance of $118,743.95. Because
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. LIVE OAK INTERNET SERVICES LLC. OPERATING ACCOUNT 297. Bank of America Business Advantage Checking account was
opened on February 26, 2010 in the name LIVE OAK INTERNET SERVICES LLC. OPERATING ACCOUNT, at a branch located in Columbia County, Florida. Michael
Graham, Joey Harrington, and Elaine Harrington are listed as the signors on the account. The contact address for this account is listed as 103 N. Main Street, Tabor City, NC.,284631617. 298. Between April 7, 2010 and March 31, 2012, a total of approximately
$1,354,526.89 was deposited into this account that came directly from AVOTW Affiliate 42 Bank of America account which, as discussed above, was funded solely with gambling proceeds. 299. As of March 31, 2012, this account had a balance of $44,874.08. Because
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702.
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M & S MANAGMENT SERVICES, LLC 300. Bank of America Business Advantage Checking account was
opened on June 7, 2011 in the name M & S MANAGMENT SERVICES, LLC, at a branch located in Jacksonville, Florida. Salim Saloum, Zaher Salloum, and Samer Saloum are listed as the signors on the account. The contact address for this account is listed as 1440 Dunn Avenue Suite 5, Jacksonville, Florida, 32218-4894. 301. Between June 29, 2011 and March 31, 2012, a total of approximately
$2,269,055.91 was deposited into this account that came directly from AVOTW Affiliate 38 Bank of America account which, as discussed above, was funded solely with gambling proceeds. 302. As of March 31, 2012, this account had a balance of $61,241.46. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. M & S MANAGEMENT SEVICES LLC, LOCATION 38 ACCOUNT 303. Bank of America account in the name of M & S
MANAGEMENT SERVICES LLC., LOCATION 38 ACCOUNT. The signors on this account are Mazen Salloum, Brad Skidmore, Rebecca Stevens, and Terri LeClaire. This for-profit corporation and bank account is believed to have replaced the gambling center previously identified as Affiliate 38 and the bank account identified as Affiliate 38. 304. Between April 2012 and January 2013, $3,465,969.88 was deposited into this
account which your affiant believes is the daily proceeds from the gambling center identified as Affiliate 38. The gambling proceeds are then laundered and transferred to other AVOTW
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Enterprise accounts on a weekly basis including Allied Veterans Management Group Inc. and I.I.T. 305. As of January 2013, the balance in this account is $47,698.16. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. M & S MANAGEMENT SERVICES LLC. SPECIAL FUNDS ACCOUNT 306. Bank of America account in the name of M & S
MANAGEMENT SERVICES LLC. SPECIAL FUNDS ACCOUNT. The signors on this account
are listed as Mazen Salloum, Brad Skidmore, Rebecca Skidmore, and Terri LeClaire.
307.
Between April 2012 and January 2013, $153,678.33 has been deposited into
this account from M & S MANAGEMENT SERVICES LLC. LOCATION 38 BOA account ending 38. 308. As of January 2013, this account has a balance of $14,281.70. Because this that received the daily proceeds of the gambling center identified as Affiliate
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. MATHIS & MURPHY, P.A. 309. Kelly Mathis and Mathis & Murphy P.A. are being paid illegal proceeds from
Allied Veterans Management, I.I.T., the for-profit corporations that are operating the day to day operations of the gambling centers, and co-conspirators. The monies are being
deposited into two (2) separate accounts on behalf of Mathis and Mathis & Murphy P.A., a
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Trust account and an Operating account.
Mathis was the attorney of record in the
Pinellas County prosecution of James Michael Hill previously described in this affidavit whereas Hill pled nolo-contendre to 12 counts of coin-operated devices (slot machines). Mathis knows or should have known that the machines being operated by the AVOTW Affiliates are illegal slot machines. In addition, Mathis is the registered agent for the AVOTW Affiliates, Allied Veterans Management Group, and all or most all of the for-profit corporations owned by co-conspirators who are conducting the day to day operation of the AVOTW gambling centers. The following is a representative chart of some of the monies paid to Mathis and Mathis & Murphy P.A. by the illegal AVOTW Enterprise and its co-conspirators. 310. The following two (2) charts represent deposits made into an account identified for the law firm of Mathis & Murphy. The deposits include
as a Trust account
deposits made from AVOTW Enterprise co-conspirators and businesses owned by members of the AVOTW Enterprise. The first chart is from the time period of February 2007-May 2011, and the second chart is from the time period of June 2011 - February 2012.
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Chart 5: Mathis & Murphy Trust Account
Deposits 2007-2011
Grand Total $2,000,000.00 $920,000.00 $17,599.87 $5,000.00 $427,900.00 $2,660.00 $4,800.00 $1,200.00 $4,796.07 $9,582.38 $31,016.66 $22,000.00 $1,002.02 $200.00 $10,794.50 $2,120.56 $2,955.68 $33,721.58 $200,000.00 $2,000.00 $500.00 $100.00 $196,341.64 $1,330.00 $1,500.00 $3,000.00 $3,902,120.96
Sum of Amount Year Source of Deposit 2007 2008 2009 2010 2011 Allied Veterans Management Group $400,000.00 $600,000.00 $1,000,000.00 Allied Veterans of the World Inc and Affiliates Advisory Account $20,000.00 $550,000.00 $350,000.00 Better Games Distributing Co, Inc $2,500.00 $1,621.05 $4,281.96 $9,139.36 $57.50 Blue Water Gaming Technology $5,000.00 Cash Mgmt Trsfr Cr from 22756 $16,500.00 $11,400.00 $400,000.00 Changiz Rokh $2,660.00 Charles Bartlett $4,800.00 Coastal Games LLC $1,200.00 Davis Internet Management Co LLC $296.07 $3,000.00 $1,500.00 INH Management Co $9,582.38 International Internet Technologies $13,850.00 $17,166.66 Jerry Bass $22,000.00 JM Land Investments, LLC $1,002.02 Kelly B. Mathis $200.00 Kelly B. Mathis PA $10,794.50 Law Offices of Kelly B. Mathis $2,120.56 Live Oak Internet Services, LLC $2,955.68 Mathis & Murphy PA - Acct #22756 $7,507.54 $12,464.08 $13,449.96 $300.00 Mathis & Murphy PA - Acct #300004521 $200,000.00 Mathis & Murphy Tranfer 264.14 AV Aff 43 $2,000.00 Mathis & Murphy Transfer 203.01 Seaside Internet General $500.00 Mathis & Murphy Transfer 22756 $100.00 Mathis and Murphy - Acct #3000019537 $196,341.64 Media Advice $1,330.00 Pitx Internet LLC $1,500.00 Reggie Medlin $3,000.00 Grand Total $69,762.60 $795,693.43 $779,427.99 $1,253,679.44 $1,003,557.50
Chart 6: Mathis & Murphy Trust Account
Deposits 2011-2012
Sum of Amount Year Source of Deposit 2011 2012 Grand Total Allied Veterans Management Group, Inc $1,000,000.00 $250,000.00 $1,250,000.00 Better Games Distributing Co, Inc $17,344.05 $17,344.05 Cash $8,000.00 $1,500.00 $9,500.00 Seaside Internet, LLC $9,000.00 $9,000.00 Mathis & Murphy Operating Account $13,430.29 $13,430.29 Grand Total $1,047,774.34 $251,500.00 $1,299,274.34
311.
The following two (2) charts represent deposits made into an account identified for the law firm of Mathis & Murphy. The deposits include
as an account
deposits made from AVOTW Enterprise co-conspirators and businesses owned by members
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of the AVOTW Enterprise. The first chart is from the time period of February 2007-May 2011, and the second chart is from the time period of June 2011 - February 2012. Chart 7: Mathis & Murphy Account Source of Deposit Aamir Waheed - Personal Account Allied Veterans of the World Inc and Affiliate Headquarters Allied Veterans of the World Inc and Affiliates Advisory Acct ATM4U, LLC Automated X-100 Services AVA Business Offices LLC B&M Leasing & Management, LLC BBS Management Group Bearcon Management, LLC Bennie or Peggy Prince - Personal Account Better Games Distributing Co, Inc Blue Quarry Internet, LLC Blue Water Gaming Technology, Inc Blue Water Internet Technology LLC Blue Waters Technologies, LLC Business Center Unlimited Inc Cary Hardee - Personal Account Chase Burns DBA CB Farms Chase Burns DBA OK Coin Deposits 2007-2011 Sum of Amount $6,355.08 $13,834.33 $75,734.57 $4,033.28 $83,203.13 $35,329.90 $13,101.33 $1,605.27 $7,456.87 $13,574.73 $8,652.14 $4,970.16 $14,000.00 $11,963.49 $30,874.23 $5,000.00 $606.00 $865.49 $342.34
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Source of Deposit Coastal Games LLC Coastal Games LLC DBA Hot Spot Conrad H. Rowe - Personal Account Conrad H. Rowe DBA B&C Gaming Cyber Corp Cyber World LLC Cyberlynk Unlimited LLC Davis Internet Management Co LLC Digitrac Inc Dodge City Games, LLC Flaming Flamingo Gainesville Internet Services, LLC Game Advice, Inc GINLIN, LLC Grant Park, LLC Horry Technologies, LLC Infovice, Inc INH Management Co Intelitek, Inc International Internet Technologies, LLC Internet Management Co, LLC Jack and Linda Medlin - Personal Account
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Sum of Amount $21,236.05 $29,430.19 $7,311.57 $2,805.85 $1,661.01 $10,455.69 $3,931.17 $11,316.25 $29,052.56 $15,400.00 $1,000.00 $16,305.08 $5,219.39 $16,787.76 $5,448.64 $16,435.75 $6,506.13 $4,911.71 $3,068.75 $717,681.58 $282.62 $2,795.00
Source of Deposit JDJ Cyber Centers, LLC JDJ Service Centers, LLC JM Land Investments, LLC Kelly B. Mathis - Personal Account Kelly B. Mathis PA Lake City Internet Services, LLC Law Offices of Kelly B. Mathis Live Oak Internet Services LLC Media Advice, Inc Michael Ryles/Dodge City Games Michael S. Davis - Personal Account Michael W. Graham - Personal Account MSG Business Centers, Inc PITX Internet, LLC R&P Business Center, LLC Reggie Paul Medlin - Personal Account Seaside Gaming Seaside Internet LLC Sky Internet, LLC Sky Technologies, LLC Tamara L. Gross DBA Goodtimes Caf Teamwork Management, LLC
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Sum of Amount $1,470.98 $3,112.08 $3,000.00 $1,445.00 $1,621.69 $5,352.30 $7,500.00 $1,581.45 $7,062.85 $11,965.36 $4,562.65 $1,175.00 $18,439.64 $11,160.48 $6,683.23 $3,291.78 $10,648.28 $129,758.70 $5,083.95 $10,760.15 $8,860.14 $2,194.05
Source of Deposit TLC Games Tony J. Parker - Personal Account Tony Parker & Leonard Lucas - Personal Account X-900 Services, LLC Grand Total
Sum of Amount $2,500.00 $161.32 $2,200.00 $1,659.25 $1,523,795.42
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Chart 8: Mathis & Murphy Account

Source of Deposit ATM4U, LLC Automated X-100 Services, Inc B&M Leasing & Management LLC Bearcon Management, LLC Better Games Distributing Co, Inc Blue Quarry Internet, LLC Blue Rose Inc Blue Water Internet Technology LLC Blue Water T echnologies, LLC Business Center Unlimited Capital City Internet Center Inc Coastal Games DBA Hot Spot Datahub, Inc Davis Internet Management CO Digitrac Inc DMD Business Management I nc Free Entry Clay County, LLC Gainesville Internet Services, LLC Ginlin, LLC Grant Park, LLC Gulf Internet Services, LLC Horry T echnologies, LLC Intelitek, Inc International Internet Technologies, Inc JM Land Investments, LLC Kelly B. Mathis Lake City Internet Services, LLC Leslie Collins Live Oak Internet Services, LLC M&S Management Services, LLC Mathis and Murphy, PA Mathis and Murphy, Trust Account Media Advice, Inc Megjon, Inc Michael W. Graham MSG Business Centers, Inc R&P Business Center, LLC Seaside Internet - Marion, LLC Seaside Internet, LLC Sky Internet, LLC Sky Technologies, LLC Sunset Bay Business Center, LLC Grand Total
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Deposits 2011-2012
Sum of Amount $370.44 $67,864.66 $7,366.42 $2,888.76 $6,503.42 $923.63 $50.94 $4,312.67 $71.69 $4,000.00 $3,100.00 $2,347.60 $11,384.15 $1,719.02 $8,993.37 $1,602.80 $449.24 $8,098.55 $4,638.48 $669.55 $591.48 $3,475.48 $637.25 $55,803.25 $325.00 $2,000.00 $4,874.10 $277.13 $61.61 $82.50 $200,000.00 $1,246,356.78 $506.69 $1,016.07 $796.50 $410.64 $6,378.17 $1,614.08 $22,624.67 $1,226.14 $437.44 $15,972.47 $1,702,822.84
312.
Because these accounts received deposits of gambling proceeds, the funds in
these accounts are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. MEDIA ADVICE INC. 313. Bank of America Business Advantage Checking account was
opened on June 12, 2007 in the name MEDIA ADVICE INC., at a branch located in Volusia County, Florida. Aamir Waheed is listed as the signor on the account. The contact address for this account is listed as 301 N. Pine Meadow Drive Suite E, Debary, Florida, 32713-2374. 314. Between January 1, 2008 and March 31, 2012, a total of approximately
$11,076,332.08 was deposited into this account that came directly from AVOTW Affiliate 33 & 78 Bank of America accounts which, as discussed above, were funded solely with gambling proceeds. 315. As of March 31, 2012, this account had a balance of $119,543.28. Because
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. MEGJON, INC 316. Bank of America Business Economy Checking account was
opened on June 18, 2009 in the name MEGJON, LLC at a branch located at Spring Hill, Florida. Anthony Alascia is listed as the signor on the account. The contact address for this account is listed as 7466 Jonquil Pl, Weeki Wachee, FL 34607-2024. 317. Between June 23, 2009 and March 31, 2012, a total of approximately
$969,219.56 was deposited into the account that came directly from AVOTW Affiliate 76
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Bank of America account which, as discussed above, is funded solely with gambling proceeds. 318. As of March 31, 2012, this account had a balance of $3,943.08. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. MJ ENTERPRISES, LLC 319. Bank of America Business Economy Checking account was
opened on December 17, 2007 in the name MJ Enterprises, LLC, at a branch located in Sumter, SC. Michael Ryles and Janis S Jayroe are listed as the signors on the account. The contact address for this account is listed as 1355 Clearview Drive, Manning, SC 29102. 320. Between January 1, 2008 and March 31, 2012, a total of approximately
$2,219,000.00 was deposited into this account that came directly from SEASIDE INTERNET, LLCs Bank of America account ending in which received illegal proceeds from
AVOTW Affiliates 34, 43, 44, 57 and 68 Bank of America accounts which, as discussed above, were funded solely with gambling proceeds. 321. Between April 2012 and January 2013, $932,000.00 was deposited into this
account that came directly from SEASIDE INTERNET, LLCs Bank of America account ending in which receives it funds directly from gambling centers. Because this account
received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702.
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MNL INVESTMENTS, INC 322. Wells Fargo Business Performance Savings account # was
opened on July 14, 2008 in the name of MNL Investments, Inc. Mazen Salloum, Samer Saloum, Zaher Salloum, and Salim Saloum are listed as the signors on the account. The contact address for this account is listed as 3959 Spring Glen Rd., Jacksonville, FL 322077167. It is unknown at this time where and/or which banking branch center location the account was opened. It should be noted that the account was previously a Wachovia Bank Small Business High Performance account, with the same account number. The account was transferred to Wells Fargo Bank on or about June 11, 2011. 323. Between January 1, 2011 and February 29, 2012, $1,515,048.95 was
deposited into this account, of which at least $1,394,050.00 appears to be proceeds of the gambling violations: $502,100.00 was deposited from SEASIDE INTERNET, LLCs Bank of America account ending in 34, 43, 44, 57 and 68. $319,900.00 was deposited from FREE ENTRY CLAY COUNTY, LLCs Bank of America account ending in Affiliate 71. $183,750.00 was deposited from B&M LEASING MANAGEMENT, LLCs Bank of America account ending in Affiliate 44. that received illegal proceeds from AVOTW that received illegal proceeds from AVOTW that received illegal proceeds from AVOTW Affiliates
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$3,200.00 was deposited from B&M LEASING MANAGEMENT, LLCs Bank of America account number ending in AVOTW Affiliate 44. that received illegal proceeds from
$205,500.00 was deposited from B&M LEASING AND MANAGEMENT ST AUGUSTINE STORE #55 Bank of America account ending in received illegal proceeds from AVOTW Affiliate 55. that
$153,000.00 was deposited from TAMARA GROSS DBA GOODTIMES CAFES Bank of America account ending in AVOTW Affiliate 38. that received illegal proceeds from
$16,500.00 was deposited from SEASIDE INTERNET-PUTNAM, LLCs Bank of America account number ending in AVOTW Affiliate 81. that received illegal proceeds from
$10,100.00 was deposited from SEASIDE INTERNET-MARION Bank of America account ending in Affiliate 63. , which received illegal proceeds from AVOTW
324.
account that came directly from SEASIDE INTERNET, LLCs Bank of America account ending in which receives funds directly from gambling centers. Because this account
received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. MNL INVESTMENTS, INC 325. SunTrust Primary Business Checking account # was opened Mazen Salloum, Samer
on December 4, 2006 in the name of MNL Investments, Inc.
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Saloum, Zaher Salloum, and Salim Saloum are listed as the on the account. The contact address for this account is listed as 3959 Spring Glen Rd., Jacksonville, FL 32207-7167. It is unknown at this time where and/or which banking branch center location the account was opened. 326. Between December 31, 2010 and February 29, 2012, $264,369.16 was
deposited into this account, of which at least $244,050.00 appears to be proceeds of the gambling violations: $88,000.00 was deposited from B&M LEASING AND MANAGEMENT ST AUGUSTINE STORE # 55, Bank of America account ending in received illegal proceeds from AVOTW Affiliate 55. $64,800.00 was deposited from SEASIDE INTERNET, LLCs Bank of America account ending in 34, 43, 44, 57 and 68. $67,500.00 was deposited from FREE ENTRY CLAY COUNTY, LLCs Bank of America account ending in Affiliate 71. $19,750.00 was deposited from B&M LEASING MANAGEMENT, LLCs Bank of America account ending in Affiliate 44. $4,000.00 was deposited from SEASIDE INTERNET-PUTNAM, LLCs Bank of America account ending in Affiliate 81. that received illegal proceeds from AVOTW that received illegal proceeds from AVOTW hat received illegal proceeds from AVOTW that received illegal proceeds from AVOTW Affiliates that
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327.
this account received deposits of gambling proceeds the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. MNL INVESTMENTS, INC 328. SunTrust Business Money Market account # was opened on
February 8, 2008 in the name of MNL Investments, Inc. Mazen Salloum, Samer Saloum, Zaher Salloum, and Salim Saloum are listed as the signors on the account. The contact address for this account is listed as PO Box 48222, Jacksonville, FL 32247. It is unknown at this time where and/or which banking branch center location the account was opened. 329. Between January 31, 2011 and February 29, 2012, $330,415.13 was deposited
into this account, at least $326,200.00 of which appears to be proceeds of the gambling violations. $150,000.00 was deposited from TAMARA GROSS DBA GOODTIMES CAFES Bank of America account ending in AVOTW Affiliate 38. $55,000.00 was deposited from M&S MANAGEMENT SERVICES, LLCs Bank of America account ending in Affiliate 38. $47,500.00 was deposited from FREE ENTRY CLAY COUNTY, LLCs Bank of America account ending in Affiliate 71. that received illegal proceeds from AVOTW hat received illegal proceeds from AVOTW that received illegal proceeds from
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$46,200.00 was deposited from SEASIDE INTERNET, LLCs Bank of America account ending in 34, 43, 44, 57 and 68. that received illegal proceeds from AVOTW Affiliates
$23,500.00 was deposited from B&M LEASING MANAGEMENT, LLCs Bank of America account ending in Affiliate 44. that received illegal proceeds from AVOTW
$4,000.00 was deposited from SEASIDE INTERNET-PUTNAM, LLCs Bank of America account ending in Affiliate 81. hat received illegal proceeds from AVOTW
330.
As of February 29, 2012 this account had a balance of $195,945.21.
Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. MSG BUSINESS CENTERS, INC. 331. Bank of America Business Advantage Checking account was
opened on June 8, 2007 in the name MSG BUSINESS CENTERS, INC., at a branch located at Normandy, Jacksonville, Florida. Michael Davis, Gary Davis, Diane Davis, and Sammy Keeble are listed as the signors on the account. The contact address for this account is listed as 107 Hogan Coweta Road, Hogansville, GA., 30230-2852. 332. Between January 1, 2008 and March 31, 2012, a total of approximately
$8,994,892.01 was deposited into this account that came directly from AVOTW Affiliates 39, 40, and 68 Bank of America accounts which, as discussed above, were funded solely with gambling proceeds.
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333.
As of March 31, 2012, this account had a balance of $243,813.31. Because
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. PRESTIGE GAMING, LLC 334. MidFirst Free Business Checking account was opened on
September 4, 2008 in the name of PRESTIGE GAMING LLC. Chase Burns and Kristin P. Burns are listed as the signors on the account. The contact address for this account is P.O. Box 130, Anadarko, OK 73005. 335. Between September 1, 2008 and February 29, 2012, $7,484,086.56 was
deposited into this account, of which $2,553,000.00 appears to be proceeds of gambling: $750,000.00 was deposited from Chase Burns POD Titanium Money Market Savings MidFirst account ending in proceeds from all AVOTW Affiliates. $1,440,000.00 was deposited from International Internet Technologies, LLC Bank of America Account ending in proceeds from all AVOTW Affiliates. $363,000.00 was deposited from O.K. Coin/Burns Family Land Co., LLC MidFirst account ending in all AVOTW Affiliates. 336. As of February 29, 2012 this account had a balance of $706,915.16. Because which indirectly received illegal proceeds from , which directly received illegal , which indirectly received illegal
this account received deposits of gambling proceeds, the funds in this account are subject to
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forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. QUINCY BUSINESS CENTER INC. 337. Bank of America account in the name of QUINCY BUSINESS
CENTER INC. with the signor on the account being Reginald P. Medlin. Your affiant believes this account is receiving the deposits of the illegal proceeds from the gambling center identified as Quincy Business Center. 338. Between October 2012 and January 2013, $234,690.94 was deposited into this
account. Bank records indicate that $121,178.00 was deposited in cash, $60,000.00 was deposited from a BOA account in the name of Cyberlynk, LLC and $40,000.00 was deposited from a BB&T account in the name of FANNCO INC. The Cyberlynk, LLC account and FANNCO INC. account are under the control of co-conspirators Reginald Medlin and John Fannin. The remaining funds your affiant believes came from the proceeds of the gambling center previously described as Quincy Business Center Inc. 339. As of January 2013, the balance in this account is $1,889.62. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. QUINCY BUSINESS CENTER INC. 340. Bank of America account in the name of QUINCY BUSINESS
CENTER INC. with the signor on the account being Reginald P. Medlin. Your affiant believes this account is receiving the deposits of the illegal proceeds from the gambling center identified as Quincy Business Center.
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341.
Between April 2012 and January 2013, $1,537.00 was deposited into this which receives it funds
account from Quincy Business Center BOA account ending in
from the gambling center identified as Quincy Business Center, previously described. 342. As of January 2013, the balance in this account is $1,175.83. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. REALTRACK INC 343. Fifth Third Bank Business Basics Checking account was opened
on or about at least July 14, 2008 in the name of REALTRACK INC. Cheri S. Black and Aamir Waheed are listed as the signors on the account. The contact address for this account is 301 N Pine Meadow Drive Ste. E, Debary, FL 32713-2374. 344. Between July 14, 2008 and February 29, 2012, $2,303,256.64 was deposited
into this account, of which $1,594,000.00 appears to be proceeds of gambling: $1,026,000.00 was deposited from Aamir Waheeds Bank of America account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 41, 51, 54, 59, 66, 67, 74 and 78. $80,000.00 was deposited from Aamir Waheeds Fifth Third Bank account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 41, 51, 54, 59, 66, 67, 74 and 78. $488,000.00 was deposited from Infovices Bank of America Account ending in , which received illegal proceeds from AVOTW Affiliate 59.
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345.
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. REALVICE INC. 346. Fifth Third Bank Business Basics Checking account was opened
on March 18, 2009 in the name of REALVICE INC. Aamir Waheed and Tariq Waheed are listed as the signors on the account. The contact address for this account is 301 N Pine Meadow Drive Ste. E, Debary, FL 32713-2374. 347. Between March 18, 2009 and September 30, 2011, $2,590,521.00 was
deposited into this account, of which at least $1,528,498.93 appears to be proceeds of gambling: $726,000.00 was deposited from Aamir Waheeds Bank of America account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 41, 51, 54, 59, 66, 67, 74, 77 and 78. $250,000.00 was deposited from Aamir Waheeds Regions Bank account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 41, 51, 54, 59, 66, 67, 74, 77 and 78. $200,000.00 was deposited from Aamir Waheeds Fifth Third Bank account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 41, 51, 54, 59, 66, 67, 74, 77 and 78.
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$50,000.00 was deposited from Aamir Waheeds Fifth Third Bank account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 41, 51, 54, 59, 66, 67, 74, 77 and 78. $85,000 was deposited from Realtrack Incs Fifth Third Bank account ending in which indirectly received illegal proceeds from AVOTW Affiliates 41, 51, 54, 59, 66, 67, 74, 77 and 78. $217,498.93 was deposited from Tariq & Sadia Waheeds Bank of America account ending in , which indirectly received illegal proceeds from AVOTW
Affiliates 59, 66, 67, 74 and 77. 348. As of September 30, 2011 this account had a balance of $5,617.81. Because
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. REALVICE INC DBA METRO ONE STOP (CAR WASH ACC) 349. Regions Advantage Business Checking account was opened on
May 19, 2010 in the name of REALVICE INC DBA METRO ONE STOP (CAR WASH ACC) at the Kings Ridge Branch in Clermont, Florida. Aamir Waheed and Tariq Waheed are listed as the signors on the account. The contact address for this account is 7490 W Colonial Drive, Orlando, FL 32818-6779. 350. Between May 19, 2010 and April 10, 2012, $135,934.63 was deposited into this
account, of which at least $27,500.00 appears to be proceeds of gambling:
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$20,000.00 was deposited from Aamir Waheeds Bank of America account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 41, 51, 54, 59, 66, 67, 74, 77 and 78. $7,500.00 was deposited from Realvice Inc DBA Metro One Stop Store Accounts Regions account ending in which indirectly received illegal
proceeds from AVOTW Affiliates 41, 51, 54, 59, 66, 67, 74, 77 and 78. 351. As of April 10, 2012 this account had a balance of $10,558.77. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. REALVICE INC DBA METRO ONE STOP (GAS ACC) 352. Regions Advantage Business Checking account was opened on
May 19, 2010 in the name of REALVICE INC DBA METRO ONE STOP (GAS ACC) at the Kings Ridge Branch in Clermont, Florida. Aamir Waheed and Tariq Waheed are listed as the signors on the account. The contact address for this account is 7490 W Colonial Drive, Orlando, FL 32818-6779. 353. Between May 19, 2010 and April 10, 2012, $1,010,853.71 was deposited into
this account, of which at least $60,214.34 appears to be proceeds of gambling: $25,000.00 was deposited from Aamir Waheeds Bank of America account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 41, 51, 54, 59, 66, 67, 74, 77 and 78.
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$19,228.74 was deposited from Realvice Inc DBA Metro One Stop Store Accounts Regions account ending in which indirectly received illegal
proceeds from AVOTW Affiliates 41, 51, 54, 59, 66, 67, 74, 77 and 78. $13,000.00 was deposited from Realvice Inc DBA Metro One Stop (Car Wash Acc) Regions account ending in which indirectly received illegal proceeds
from AVOTW Affiliates 41, 51, 54, 59, 66, 67, 74, 77 and 78. $2,985.60 was deposited from Digitracs Bank of America account ending in which received illegal proceeds from AVOTW Affiliates 66, 67, 74 and 77. 354. As of April 10, 2012 this account had a balance of $80,704.50. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. REALVICE INC DBA METRO ONE STOP (LUBE EXPRESS ACC) 355. Regions Advantage Business Checking account was opened on
May 19, 2010 in the name of REALVICE INC DBA METRO ONE STOP (LUBE EXPRESS ACC) at the Kings Ridge Branch in Clermont, Florida. Aamir Waheed and Tariq Waheed are listed as the signors on the account. The contact address for this account is 7490 W Colonial Drive, Orlando, FL 32818-6779. 356. Between May 19, 2010 and April 10, 2012, $109,160.55 was deposited into this
account, of which at least $32,700.00 appears to be proceeds of gambling: $20,000.00 was deposited from Tariq & Sadia Waheeds Bank of America account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 59, 66, 67, 74 and 77.
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$8,000.00 was deposited from Realvice Inc DBA Metro One Stop (Store Acc) Regions account ending in which indirectly received illegal proceeds from
AVOTW Affiliates 41, 51, 54, 59, 66, 67, 74, 77 and 78. $4,700.00 was deposited from Realvice Inc DBA Metro One Stop (Car Wash Acc) Regions account ending in which indirectly received illegal proceeds
from AVOTW Affiliates 41, 51, 54, 59, 66, 67, 74, 77 and 78. 357. As of April 10, 2012 this account had a balance of $6,389.89. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. REALVICE INC DBA METRO ONE STOP (STORE ACC) 358. Regions Advantage Business Checking account was opened on
April 27, 2010 in the name of REALVICE INC DBA METRO ONE STOP (STORE ACC) at the Kings Ridge Branch in Clermont, Florida. Aamir Waheed and Tariq Waheed are listed as the signors on the account. The contact address for this account is 7490 W Colonial Drive, Orlando, FL 32818-6779. 359. Between April 27, 2010 and April 10, 2012, $1,081,953.51 was deposited into
this account, of which at least $226,378.20 appears to be proceeds of gambling: $85,000.00 was deposited from Tariq & Sadia Waheeds Bank of America account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 59, 66, 67, 74 and 77.
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$25,000.00 was deposited from Aamir Waheeds Bank of America account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 41, 51, 54, 59, 66, 67, 74, 77 and 78. $17,578.20 was deposited from Digitracs Bank of America account ending in which received illegal proceeds from AVOTW Affiliates 66, 67, 74 and 77. $35,900.00 was deposited from Realvice Inc DBA Metro One Stop (Gas Acc) Regions account ending in which indirectly received illegal proceeds from
AVOTW Affiliates 41, 51, 54, 59, 66, 67, 74, 77 and 78. $57,000.00 was deposited from Realvice Inc DBA Metro One Stop (Car Wash Acc) Regions account ending in , which indirectly received illegal proceeds
from AVOTW Affiliates 41, 51, 54, 59, 66, 67, 74, 77 and 78. $5,900.00 was deposited from Realvice Inc DBA Metro One Stop (Lube Express Acc) Regions account ending in which indirectly received illegal
proceeds from AVOTW Affiliates 41, 51, 54, 59, 66, 67, 74, 77 and 78. 360. As of April 10, 2012 this account had a balance of $22,858.27. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. SEASIDE GAMING INC. 361. Bank of America Business Economy Checking account was
opened on January 28, 2005 in the name SEASIDE GAMING INC., at a branch located North Myrtle Beach, South Carolina. Brad D. Skidmore, Tracey Skidmore, and Rebecca Stevens
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are listed as the signors on the account. The contact address for this account is listed as 231 Koolabrew Drive, NW Suite A, Calabash, NC.,28467-1937. 362. Between January 1, 2007 and March 31, 2012, a total of approximately
$119,722.60 was deposited into this account, which appears to be proceeds of gambling: $51,976.66 was deposited from SEASIDE INTERNET Bank of America account ending in 44, 57 and 68. $41,146.50 was deposited from FREE ENTRY CLAY COUNTY Bank of America account ending in 1 Affiliate 71. $23,993.69 from B & M LEASING & MANAGEMENT Bank of America account ending in 55. $2,559.40 from SEASIDE INTERNET-MARION Bank of America account ending in 63. $46.35 from SEASIDE INTERNET-PUTNAM Bank of America account ending in 363. which received illegal proceeds from AVOTW Affiliate 81. which received illegal proceeds from AVOTW Affiliates 57 and , which received illegal proceeds from AVOTW Affiliates 44 and which received illegal proceeds from AVOTW , which received illegal proceeds from AVOTW Affiliates 34, 43,
As of March 31, 2012, this account had a balance of $47,786.57. Because this
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SEASIDE GAMING, INC. 364. Crescent Bank Totally Free Business Checking account # was
opened on July 13, 2004 in the name of Seaside Gaming, Inc. Bradley Skidmore and Tracey Skidmore are listed as the signors on the account. The contact address for this account is listed as 231 Koolabrew Dr., Calabash, NC 28467. It is unknown at this time where and/or which banking branch center location the account was opened. 365. Between January 1, 2011 and February 29, 2012, $1,063,599.13 was
deposited into this account, at least $645,035.05 of which appears to be proceeds of the gambling violations: $269,008.73 was deposited from SEASIDE TECHNOLOGIES, LLCs Crescent Bank account ending in which received illegal proceeds indirectly from
but not limited to AVOTW Affiliates 34, 43, 44, 57, and 68. $215,608.52 was deposited from SEASIDE INTERNET, LLCs Bank of America account ending in 34, 43, 44, 57 and 68. $94,328.32 was deposited from BETTER GAMES, LLCs Horry County Bank account ending in Affiliates 42 and 56. $40,000.00 was deposited from SEASIDE GAMING, Bank of America account ending in which received illegal proceeds indirectly from AVOTW which received illegal proceeds indirectly from AVOTW which received illegal proceeds from AVOTW Affiliates
Affiliates 34, 43, 44, 55, 57, 63, 68, 71 and 81.
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$24,638.87 was deposited from SEASIDE INTERNET-MARION, LLCs Bank of America account ending in Affiliate 63. which received illegal proceeds from AVOTW
$357.05 was deposited from FREE ENTRY CLAY COUNTY Bank of America account ending in 71. which received illegal proceeds from AVOTW Affiliate
$1,093.56 was deposited from SEASIDE INTERNET-MARION Bank of America account ending in 63. which received illegal proceeds from AVOTW Affiliate
366.
account that came directly from SEASIDE INTERNET, LLCs Bank of America account ending in , which receives funds directly from gambling centers. Because this account
received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. SEASIDE INTERNET, LLC 367. Bank of America Business Economy Checking account was
opened on May 24, 2007 in the name SEASIDE INTERNET, LLC., at a branch located on Normandy Blvd., Jacksonville, Florida. Brad D. Skidmore, Michael W. Ryles, Tracey
Skidmore, Rebecca Stevens, Jann Ryles, Mazen Salloum and Terri L. LeClaire are listed as the signors on the account. The contact address for this account is listed as 231 Koolabrew Drive, NW, Calabash, NC., 28467-1937. 368. Between January 1, 2008 and March 31, 2012, a total of approximately
$31,275,897.57 was deposited into this account that came directly from AVOTW Affiliates 34,
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43, 44, 57 and 68 Bank of America accounts which, as discussed above, were funded solely with gambling proceeds. As of March 31, 2012, this account had a balance of $80,021.07. 369. Between April 2012 and January 2013, $9,245,395.49 was deposited into this
account. The bank records reflect ACH payroll deposits from gambling centers identified as Affiliates 34, 43, and 68. During this same time frame, $8,924,393.36 was withdrawn from this account. The records indicate a portion of these withdrawals and/or debits went to pay AVOTW Enterprise co-conspirators. As of January 2013, the balance in this account is $401,023.20. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. SEASIDE INTERNET LLC., LOCATION 34 ACCOUNT 370. Bank of America account in the name of SEASIDE
INTERNET, LLC. LOCATION 34 ACCOUNT lists Brad Skidmore, Michael Ryles, Rebecca Stevens, Mazen Salloum, and Terri LeClaire as signors on the account. This for-profit corporation and bank account is believed to have replaced the gambling center previously identified as Affiliate 34 and the bank account identified as Affiliate 34. 371. Between April 2012 and January 2013, $3,436,409.94 was deposited into this
account which your affiant believes is the daily proceeds of the gambling center previously identified as Affiliate 34. The gambling proceeds are then laundered and transferred to other AVOTW Enterprise accounts on a weekly basis including Allied Veterans Management Group Inc. and I.I.T. which is listed in the above charts. As of January 2013 the balance in this account is $36,199.49. This banking activity is consistent with the illegal banking previously described. Because this account received deposits of gambling proceeds, the
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funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. SEASIDE INTERNET LLC., LOCATION 43 ACCOUNT 372. Bank of America account in the name of SEASIDE
INTERNET, LOCATION 43 ACCOUNT lists Brad Skidmore, Michael Ryles, Rebecca Stevens, Mazen Salloum, and Terri LeClaire as signors on the account. This for-profit corporation and bank account is believed to have replaced the gambling center previously identified as Affiliate 43 and the bank account identified as Affiliate 43. 373. Between April 2012 and January 2013, $3,568,937.39 was deposited into this
account which your affiant believes is the daily proceeds of the gambling center previously identified as Affiliate 43. The gambling proceeds are then laundered and transferred to other AVOTW Enterprise accounts on a weekly basis including Allied Veterans Management Group Inc. and I.I.T. which is listed in the above charts. As of January 2013 the balance in this account is $33,983.35. This banking activity is consistent with the illegal banking previously described. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. SEASIDE INTERNET LLC., LOCATION 68 ACCOUNT 374. Bank of America account n the name of SEASIDE
INTERNET, LLC., LOCATION 68 ACCOUNT lists Brad Skidmore, Michael Ryles, Rebecca Stevens, Mazen Salloum, and Terri LeClaire as signors on the account. This for-profit corporation and bank account is believed to have replaced the gambling center previously identified as Affiliate 68 and the bank account identified as Affiliate 68.
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375.
account which your affiant believes is the daily proceeds of the gambling center previously identified as Affiliate 43. The gambling proceeds are then laundered and transferred to other AVOTW Enterprise accounts on a weekly basis including Allied Veterans Management Group Inc. and I.I.T. which is listed in the above charts. As of January 2013 the balance in this account is $21,466.35. This banking activity is consistent with the illegal banking previously described. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. SEASIDE INTERNET-MARION, LLC., LOCATION 57 ACCOUNT 376. Bank of America account in the name of SEASIDE INTERNET
MARION, LLC., LOCATION 57 ACCOUNT lists Brad Skidmore, Rebecca Stevens, Mazen Salloum, and Terri LeClaire as signors on the account. This for-profit corporation and bank account is believed to have replaced the gambling center previously identified as Affiliate 57 and the bank account identified as Affiliate 57. 377. Between April 2012 and January 2013, $220,393.73 was deposited into this
account which your affiant believes is the daily proceeds of the gambling center previously identified as Affiliate 57. The gambling proceeds are then laundered and transferred to other AVOTW Enterprise accounts on a weekly basis including Allied Veterans Management Group Inc. and I.I.T. which is listed in the above charts. This banking activity is consistent with the illegal banking previously described. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702.
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SEASIDE INTERNET-MARION LLC., LOCATION 63 ACCOUNT 378. Bank of America account in the name of SEASIDE INTERNET
MARION LLC., LOCATION 63 ACCOUNT lists Brad Skidmore, Rebecca Stevens, Mazen Salloum, and Terri LeClaire as signors on the account. This for-profit corporation and bank account is believed to have replaced the gambling center previously identified as Affiliate 63 and the bank account identified as Affiliate 63. 379. Between April 2012 and January 2013, $275,109.48 was deposited into this
account which your affiant believes is the daily proceeds of the gambling center previously identified as Affiliate 63. The gambling proceeds are then laundered and transferred to other AVOTW Enterprise accounts on a weekly basis including Allied Veterans Management Group Inc. and I.I.T. which is listed in the above charts. This banking activity is consistent with the illegal banking previously described. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. SEASIDE INTERNET MARION-SPECIAL FUND ACCOUNT 380. Bank of America account in the name of SEASIDE INTERNET
MARION- SPECIAL FUND ACCOUNT lists Brad Skidmore, Rebecca Stevens, Mazen Salloum, and Terri LeClaire as signors on the account. This for-profit corporation and bank account is believed to receive weekly distributions of illegal proceeds from SEASIDE INTERNET MARION accounts that have replaced the gambling centers previously identified as Affiliate 63 and Affiliate 57. 381. Between April 2012 and January 2013, $18,147.29 was deposited into this
account via automatic deposits that occurred every seven (7) days. The records indicate the
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deposits were payroll deposits from gambling centers identified as Affiliates 57 and 63. This banking activity is consistent with the illegal banking previously described. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. SEASIDE INTERNET-MARION, LLC 382. Bank of America account in the name of SEASIDE INTERNET
MARION, LLC. lists Mazen Salloum, Cedric Fuller, and Marisa Banks as signors on the account. This for-profit corporation and bank account is believed to receive weekly distributions of illegal proceeds from SEASIDE INTERNET MARION accounts that have replaced the gambling centers previously identified as Affiliate 63 and Affiliate 57. 383. Between April 2012 and January 2013, $674,201.65 was deposited into this
account via automatic deposits that occurred every seven (7) days. The records indicate the deposits were payroll deposits from gambling centers identified as Affiliates 57 and 63. This banking activity is consistent with the illegal banking previously described. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. SEASIDE INTERNET-PUTNAM, LLC 384. Bank of America Business Advantage Checking account was
opened on May 10, 2011 in the name SEASIDE INTERNET-PUTNAM, LLC., at a branch located in, Jacksonville, Florida. Bradley D. Skidmore, Mazen G. Salloum, and Jill Renee
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Russo are listed as the signors on the account. The contact address for this account is listed as 185 Carter Road, Palatka, Florida, 32177-8625. 385. Between June 1, 2011 and March 31, 2012, a total of approximately
$646,277.20 was deposited into this account that came directly from AVOTW Affiliate 81 Bank of America account which, as discussed above, was funded solely with gambling proceeds. 386. As of March 31, 2012, this account had a balance of $26,482.38. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. SEASIDE INTERNET-PUTNAM LLC., LOCATION 81 ACCOUNT 387. Bank of America account in the name of SEASIDE
INTERNET-PUTNAM LLC., LOCATION 81 ACCOUNT lists Brad Skidmore, Rebecca Stevens, Mazen Salloum, and Terri LeClaire as signors on the account. This for-profit corporation and bank account is believed to have replaced the gambling center previously identified as Affiliate 81 and the bank account identified as Affiliate 81. 388. Between April 2012 and January 2013, $960,790.57 was deposited into this
account which your affiant believes is the daily proceeds of the gambling center previously identified as Affiliate 81. Your affiant believes that the daily proceeds of the gambling center previously identified as Affiliate 81 are being deposited into this account. The gambling proceeds are then laundered and transferred to other AVOTW Enterprise accounts on a weekly basis including Allied Veterans Management Group Inc. and I.I.T. which is listed in the above charts. This banking activity is consistent with the illegal banking previously
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described. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. SEASIDE INTERNET PUTNAM- SPECIAL FUNDS ACCOUNT 389. Bank of America account in the name of SEASIDE
INTERNET-PUTNAM LLC SPECIAL FUNDS ACCOUNT lists Brad Skidmore, Rebecca Stevens, Mazen Salloum, and Terri LeClaire as signors on the account. This for-profit corporation and bank account is believed to receive weekly distributions of illegal proceeds from SEASIDE INTERNET PUTNAM accounts that replaced the gambling center previously identified as Affiliate 81. 390. Between April 2012 and January 2013, $35,022.32 was deposited into this
account via automatic deposits that occurred every seven (7) days. The records indicate the deposits were payroll deposits from gambling center identified as Affiliate 81. This banking activity is consistent with the illegal banking previously described. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. SEASIDE TECHNOLOGIES, INC 391. Crescent Bank Totally Free Business Checking account was
opened on August 27, 2007 in the name of Seaside Technologies, Inc. Bradley Skidmore, Tracey Skidmore, and Rebecca Stevens are listed as the signors on the account. The contact address for this account is listed as 231 Koolabrew Dr., Calabash, NC 28467. It is unknown at this time where and/or which banking branch center location the account was opened.
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392.
Between January 31, 2011 and January 31, 2012, a total of approximately
$1,128,000.00 was deposited into this account that came directly from Seaside Internet, LLCs Bank of America account ending in which received illegal proceeds from
AVOTW Affiliates 34, 43, 44, 57, and 68 Bank of America accounts which, as discussed above, were funded solely with gambling proceeds. As of January 31, 2012 this account had a balance of $642,263.94. 393. Between April 2012 and January 2013, $976,000.00 was deposited into this
account that came directly from Seaside Internet, LLCs Bank of America account ending in which receives illegal proceeds from gambling centers. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. TN YACHT CHARTERS, LLC 394. MidFirst Free Business Checking account was opened on May 9,
2011 in the name of TN YACHT CHARTERS LLC. Kristin P. Burns and Chase Burns are listed as the signors on the account. The contact address for this account is P.O. Box 130, Anadarko, OK 73005. 395. Between May 9, 2011 and April 30, 2012, $593,079.36 was deposited into this
account, of which $574,247.00 appears to be proceeds of gambling: $574,274.00 was deposited from Chase Burns POD Titanium Money Market Savings MidFirst account ending in proceeds from all Affiliates. 396. As of April 30, 2012 this account had a balance of $14,781.32. Because this , which indirectly received illegal
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forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. TN YACHT CHARTERS, LLC 397. Bank of America account number is believed to be titled and/or
held in the name of TN Yacht Charters, LLC and owned by Chase Burns and/or Kristin Burns. The account was identified during this investigation while analyzing several business and personal accounts owned and managed by Chase Burns and/or Kristin Burns. As of this writing, financial records for Bank of America account number requested but not yet received and/or analyzed. have been
However, the following financial
transactions have been identified through other Burns related accounts. 398. Between January 1, 2011 and the present, approximately $180,000.00 was
deposited into this account, at least $180,000.00 of which appears to be proceeds of gambling violations: $130,000.00 was deposited between January 1, 2011 and February 29, 2012 from the Chase Burns Trustee for the Chase Burns Trust (MidFirst Bank account ) which received illegal proceeds directly and/or indirectly
from AVOTW and/or the Affiliates. $50,000.00 was deposited between May 9, 2011 and April 30, 2012 from TN Yacht Charters, LLC (MidFirst Bank account ) which received
illegal proceeds directly and/or indirectly from AVOTW and/or the Affiliates. 399. As of this writing, the accounts current balance is unknown however; because
this account did receive deposits of at least $180,000.00 in gambling proceeds, the funds are
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subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. TPARKER MANAGEMENT LLC 400. Bank of America account in the name of TPARKER
MANAGEMENT lists Tony Parker & Leslie Collins as the signors on the account. Your affiant believes the financial records show that this for-profit corporation and bank account is being utilized to launder illegal proceeds from AVOTW gambling centers. 401. Between September 2012 and January 2013, there was a total of $255,818.56
deposited into this account in cash. Your affiant believes that the daily proceeds of gambling centers are being deposited into this account. Due to the fact that AVOTW gambling centers changed their names, your affiant is unable to identify the exact gambling center that the proceeds are coming from, however, the manner in which the proceeds are being laundered through this account is consistent with all previous money laundering activity. The gambling proceeds are then laundered and transferred to other AVOTW Enterprise accounts on a weekly basis including Allied Veterans Management Group Inc. and I.I.T. 402. As of January 2013, this account has a balance of $124,555.86. This banking
activity is consistent with the illegal banking previously described. Because this account was utilized to launder gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. TPARKER MANAGEMENT LLC 403. Bank of America account in the name of TPARKER
MANAGEMENT lists Tony Parker & Leslie Collins as the signors on the account. Your affiant
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believes the financial records show that this for-profit corporation and bank account is being utilized to launder illegal proceeds from AVOTW gambling centers. 404. Between September 2012 and January 2013, $13,461.37 was deposited into
this account from BOA account in the name of TPARKER MANAGEMENT LLC. ending in previously described, which your affiant believes is receiving proceeds from gambling centers. 405. As of January 2013, this account has a balance of $5,986.40. Because this
account was utilized to launder gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702.
INDIVIDUALS THAT OWN/OPERATE FOR-PROFIT CORPORATION ACCOUNTS 406. The disposition of the illicit proceeds from the Affiliate bank accounts to the for-
profit corporation accounts and other for-profit corporation accounts owned by members of the AVOTW Enterprise is explained above. The members of the AVOTW Enterprise who own the for-profit corporations further transfer the illicit proceeds to their personal bank accounts or other accounts that they control. These illicit funds originated from the illegal gambling operation as previously described in your affiants Master Affidavit. 407. Your affiant has bank records of the below listed individuals and has conducted
or had others conduct a financial analysis of these bank records to trace the illicit funds. Your affiant has not detailed every transaction due to the complexity and scope of the investigation but has the records available for the courts review.
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408.
All other funds not obtained as a result of illegal gambling have been analyzed
and the analysis reveals that small amounts have been deposited into these accounts and therefore commingled with the gambling proceeds. Accordingly, the funds contained within these accounts represent the proceeds obtained from an illegal gambling operation, in violation of F.S. 849. Et. Seq. Because these accounts received deposits of gambling
proceeds, the funds in these accounts are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702.
PERSONAL ACCOUNTS OF MEMBERS OF AVOTW ENTERPRISE: Alascia, Anthony 409. Bank of America regular checking account# was opened on or
about February 27, 2006 in the name of Anthony W. Alascia. This account was opened at the Forest Oaks Banking Center located in Spring Hill, Florida. Alascia is listed as the signor on the account. The contact address for this account is listed as Alascias residence, 7466 Jonquil Pl, Weeki Wachee, FL 34607-2024. 410. Between December 18, 2010 and March 16, 2012, $612,844.18 was deposited
into this account, at least $192,343.99 of which appears to be proceeds of the gambling violations: $125,143.99 was deposited from Eight (8) Anthony Alascia Bank of America related accounts that received illegal proceeds indirectly from but not limited to AVOTW Affiliates 45, 52, 70 and 76. $1,000.00 was deposited from Funtasia Sweeps Bank of America account that received illegal proceeds indirectly from AVOTW Affiliates 45, 52, 70 and 76.
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$61,200.00 was deposited from GINLIN LLC Bank of America account that received illegal proceeds from Affiliates 45, 52, and 70.
$5,000.00 was deposited from JAC Sweeps Bank of America accounts that received illegal proceeds from Affiliate 70.
411.
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Alascia, Anthony 412. Bank of America custom savings account# was opened on or
about February 27, 2006 in the name of Anthony W. Alascia. This account was opened at the Forest Oaks Banking Center located in Spring Hill, Florida. Alascia is listed as the signor on the account. The contact address for this account is listed as Alascias residence, 7466 Jonquil Pl, Weeki Wachee, FL 34607-2024. 413. Between December 18, 2010 and March 16, 2012, $163,555.52 was deposited
into this account, at least $144,036.55 of which appears to be proceeds of the gambling violations: $76,936.82 was deposited from Anthony Alascia Bank of America account ending in which received illegal proceeds indirectly from AVOTW
Affiliates 45, 52, 70 and 76. $67,100.00 was deposited from JAC Sweeps Bank of America account ending in which received illegal proceeds from AVOTW Affiliate 70.
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414.
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Bartlett, Charles 415. Wachovia Crown Classic Banking account # was opened on
or about least May 14, 2007 in the name of Charles P. Bartlett. Charles P. Bartlett is the signor on the account. The contact address for this account is listed as 13630 Jennita Drive, Port Richey, FL 34667. 416. Between December 29, 2010 and February 29, 2012, $967,192.56 was
deposited into this account, at least $50,000.00 of which appears to be proceeds of the gambling violations: $50,000.00 was deposited from GINLIN, LLC Bank of America account ending in and ADP account that received illegal proceeds from Affiliates 45, 52,
70 and 76. 417. As of February 9, 2012 this account had a balance of $22,317.54. Because
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Beyer, Anthony 418. Citizens Bank account # was opened on or about August 2006 in
the name of Anthony V. Beyer. Beyer is listed as the signor on the account. The contact address for this account is listed as 2111 Redbud Lane, Furlong, Pa., 18925.
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419.
Between January 2011 and March 2012, $532,932.01 was deposited into this
account, at least $477,000.00 of which appears to be proceeds of the gambling violations: $477,000.00 was deposited from Beyer Production Citizens Bank account ending in previously described, which received its funds directly and/or
indirectly from gambling proceeds. 420. As of April 4, 2012 this account had an ending balance of $61,657.36.
Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Beyer, Anthony 421. Citizens Bank account was opened since at least January 3,
2012 in the name of Anthony V. Beyer. Beyer is listed as the signor on the account. The contact address for this account is listed as 2111 Redbud Lane, Furlong, Pa., 18925. 422. Between January 2012 and March 2012, $100,000.00 in cash was deposited
into this account; your affiant believes the proceeds were derived from gambling violations. 423. As of March 2012, this account had an ending balance of $100,221.47.
Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Black (Waheed), Cheri 424. Regions Bank Lifegreen preferred checking account# was opened
on November 9, 2005 in the name of Cheri S Black. Cheri Black is listed as the signor on the
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account. The contact address for this account is listed as Blacks residence, 11120 Bridge House Rd, Windermere, FL 34786-5404. 425. Between January 1, 2011 and March 31, 2012, $167,591.17 was deposited into
this account, at least $153,888.85 of which appears to be proceeds of the gambling violations: $22,972.40 was deposited from Digitrac, Inc. Bank of America account ending in which received illegal proceeds directly from AVOTW Affiliates 66, 67,
74, and 77. $11,954.50 was deposited from Infovice, Inc. Bank of America account ending in which received illegal proceeds directly from AVOTW Affiliate 59.
$76,377.15 was deposited from Intelitek, Inc. Bank of America account ending in which received illegal proceeds directly from Affiliate 51.
$42,584.80 was deposited from Media Advice, Inc. Bank of America account ending in which received illegal proceeds from AVOTW Affiliate 78.
426.
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Black, Daniel 427. Regions Bank Lifegreen checking account# was opened on
January 18, 2008 in the names of Daniel L Black, Karie Anne Black. This account was opened at the Elm St Branch in Shelbyville, Tennessee. Daniel & Karie Black are listed as
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the signors on the account.
The contact address for this account is listed as Blacks
residence, 555 Woodford Dr, Debary, FL 32713-2133. 428. Between December 6, 2010 and April 6, 2012, $498,586.31 was deposited into
this account, at least $454,815.88 of which appears to be proceeds of the gambling violations: $253,178.75 was deposited from Digitrac, Inc. Bank of America account ending in 77. $201,637.13 was deposited from Infovice, Inc. Bank of America account ending in 6 429. which received illegal proceeds from AVOTW Affiliate 59. which received illegal proceeds from AVOTW Affiliates 66, 67, 74 and
As of April 6, 2012 this account had a balance of $5,912.01. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Burns, Chase 430. Midfirst Bank checking account held in the name of Chase Burns
POD Trust Account was opened on or about January 2006. Chase Burns and Kristin Burns are listed as the signors on the account and the account was opened in Oklahoma. 431. Chase and/or Kristin Burns transfer large amounts of commingled proceeds
into this account. Once the commingled funds are deposited into this account, the funds are moved again to additional accounts controlled by Chase and Kristin Burns, which moves the funds further away from the source. At times, they move funds from this account to other
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Burns controlled accounts and they transfer the funds back to this account. This account has received over $90 million in deposits. 432. From January 1, 2008 through December 31, 2008 over $7 million was Over $4.9 million dollars was (discussed above) and
deposited into Midfirst Bank checking account transferred from Bank of America checking account over $1 million was transferred from Midfirst Bank Account
Ten deposits totaling $4.9 million from IIT account at Bank of American Account #
Three deposits over $540,000 from Bank of America, Account PITX Internet LLC (for-profit corporation that ran an AVOTW Affiliate owned by Burns discussed in Master Affidavit).
One deposit of $1,077,476.77 from Chase Burns and Kristin Burns POD Titanium Money Market Account at Midfirst Bank, Account (account discussed below also owned by Chase Burns).
Two deposits over $230,000 from Anadarko Bank (appears to be from Burns related accounts).
433.
Over $275,000 of miscellaneous deposits. From January 1, 2009 through December 31, 2009 over $10 million was Of these deposits, $6.75 (discussed above) and
deposited into Midfirst Bank checking account million dollars was transferred from Midfirst account
over $800,000 was transferred from Bank of America Bank Account Four deposits totaling $6.75 million from IITs account Midfirst account .
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One deposit for $800,000 from IITs account at Bank of America account
One deposit for $1,803,800.48 from Chase Burns POD Titanium Money Market Account at Midfirst bank account now closed.
One deposit for $200,000 from Chase Burns BDA CB Farms/Burns Family Cattle LLC at Midfirst bank account # (discussed above). from Bank of America, Account
Two
deposits
totaling
$620,000
PITX Internet LLC (for-profit corporation that ran an AVOTW Affiliate owned by Burns discussed in Master Affidavit). 434. Over $350,000 in miscellaneous deposits. From January 1, 2010 through December 31, 2010 over $49 million was Of these deposits, $30.8 discussed above) and
deposited into Midfirst Bank checking account million dollars was transferred from Midfirst account $13 million was transferred from Bank of America Bank Account
Seven deposits totaling over $30.8 million from Midfirst account # Four deposits for $13 million from Bank of America account Two deposits for over $2.5 million from Certificates of Deposits. One deposit for $1,107,500 from Midfirst bank account Gaming LLC (a Burns controlled corporation). Prestige
One deposit for $56,150.03 from Bank of America, Account Teamwork Management LLC (for-profit corporation that ran an AVOTW Affiliate owned by Burns discussed in Master Affidavit).
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Sixteen deposits for over $1.9 million from JP Morgan Chase from Wheeler Rentals and Mobile Home Sales LLC described as loan payments.
435.
Over $180,000 in miscellaneous deposits. From January 1, 2011 through December 31, 2011 over $34 million was . Of these deposits, $9.5 million (discussed above) and $18.4
deposited into Midfirst Bank checking account dollars was transferred from Midfirst account million was transferred from Bank of America Bank Account
Three deposits totaling $9.5 million from Midfirst account Five deposits for $18.4 million from Bank of America account Two deposits for over $1.5 million from Certificates of Deposits. Nineteen deposits for over $2.5 million from JP Morgan Chase and First American Bank from Wheeler Rentals and Mobile Home Sales LLC described as loan payments.
One deposit for $441,727.35 from First American Bank from Triple K Investments.
436.
Over $1.3 million in miscellaneous deposits. From January 1, 2012 through December 31, 2012 over $6.3 million was Of these deposits, $6 million
deposited into Midfirst Bank checking account was transferred from Bank of America Bank Account 437.
One deposit for $6 million from Bank of America account Over $300,000 in miscellaneous deposits. As of February 28, 2012, the balance in this account was $7,451,954.30.
Because this account was used to launder the proceed of the commingling of the funds
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which concealed the nature and source of the gambling proceeds, the proceeds are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Burns, Chase 438. Principal Life Insurance Company / Principal Financial Group account (contract)
was opened on or about January 8, 2004, with the name of Chase E. Burns as Contract Owner and Annuitant. The Beneficiary Designations are Kristin Burns as Primary Designation (Owner/Spouse) and Tammie McDonald as Contingent Designation
(Owner/Mother). The contact address for the account is P.O. Box 130, Anadarko, Oklahoma 73005-0130. 439. Between January 8, 2004 and January 13, 2012, approximately $357,875.55 in
premium payments were deposited into this account, at least $189,000.00 of which appears to be proceeds of gambling violations: $94,000.00 was deposited from International Internet Technologies, LLC (Bank of America) which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates. $95,000.00 was deposited from Chase Burns DBA OK Coin / Burns Family Land Co., LLC (MidFirst Bank) which received illegal proceeds directly or indirectly from International Internet Technologies LLC, AVOTW and/or the Affiliates. 440. As of January 13, 2012 this account had a balance of $422,824.05. Because
this account received deposits of at least $189,000.00 in gambling proceeds, the funds are
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subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Burns, Chase 441. Morgan Stanley Smith Barney Smith Barney Reserved Client Financial titled Chase Burns TTEE FBO Chase
Management Account number
Burns Trust U/A/D 08-20-2010 Non-Advisory Account was opened on or about August 5, 2008, with Chase Burns as the Account Owner. The current Account Owners are listed as Chase M. Burns and the Chase Burns Trust. The contact addresses listed for the account are P.O. Box 130, Anadarko, Oklahoma 73005-0130 and 34107 County Street 2580, Ft. Cobb, Oklahoma 73038. 442. Between August 5, 2008 and December 31, 2011, approximately
$49,750,000.00 was deposited into this account, at least $49,750,000.00 of which appears to be proceeds of gambling violations: $7,000,000.00 was deposited from August 2008 through December 2008 from the following accounts; $3,000,000.00 from Chase Burns Trustee for the Chase Burns Trust (MidFirst Bank account ), $3,000,000.00 from Chase
Burns-Kristin P. Burns POD Titanium Money Market Account (MidFirst Bank account , and $1,000,000.00 from International Internet
Technologies, LLC (Bank of America account
), all of which
received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates. $6,750,000.00 was deposited from January 2009 through December 2009 from Burns Family Cattle, LLC (MidFirst Bank account ) which received
illegal proceeds directly or indirectly from AVOTW and/or the Affiliates.
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$27,000,000.00 was deposited from January 2010 through December 2010 from Chase Burns Trustee for the Chase Burns Trust (MidFirst Bank account ) which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates.
$9,000,000.00 was deposited during from January 2011 through December 2011 from International Internet Technologies, LLC (Bank of America account ) and International Internet Technologies, LLC (MidFirst Bank account ) which received illegal proceeds directly or indirectly from
AVOTW and/or the Affiliates. Additional deposits were received throughout the aforementioned time frame from other Chase Burns held Morgan Stanley Smith Barney and Citigroup Global Markets Inc. accounts. It should be noted that the additional accounts were opened utilizing funds and investment returns directly from Once the new investment accounts were funded, money would periodically be transferred, withdrawn, re-deposited, and/or swept between the investment accounts and The total amount of all
deposits (funding and revolving) that entered and/or passed through during the August 2008 through December 2011 time frame was approximately $71,547,915.98. 443. As of December 31, 2011 this account held a balance of $43,165,291.32 Because this account received deposits of at least
(includes investment return/loss).
$49,750,000.00 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702.
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Burns, Chase 444. Morgan Stanley Smith Barney Smith Barney Reserved Client account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Western Asset Gov/Corp Bonds, was opened on or about August 5, 2008, with Chase Burns as the Account Owner. The current Account Owners are listed as Chase M. Burns and the Chase Burns Trust. The contact addresses listed for the account are P.O. Box 130,
Anadarko, Oklahoma 73005-0130 and 34107 County Street 2580, Ft. Cobb, Oklahoma 73038. 445. Between August 5, 2008 and December 31, 2011, approximately
$1,000,000.00 was deposited into this account, at least $1,000,000.00 of which appears to be proceeds of gambling violations: $1,000,000.00 was deposited from August 2008 through December 2008 from Smith Barney Reserved Client Financial Management Account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-202010 Non-Advisory Account, all of which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates. 446. As of December 31, 2011 this account held a balance of $1,222,034.41 Because this account received deposits of at least
$1,000,000.00 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Burns, Chase 447. Morgan Stanley Smith Barney Smith Barney Reserved Client account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010
138
TRAK, was opened on or about August 5, 2008, with Chase Burns as the Account Owner. The current Account Owners are listed as Chase M. Burns and the Chase Burns Trust. The contact addresses listed for the account are P.O. Box 130, Anadarko, Oklahoma 730050130 and 34107 County Street 2580, Ft. Cobb, Oklahoma 73038. 448. Between August 8, 2008 and December 31, 2011, approximately
$3,501,761.35 was deposited into this account, at least $3,500,000.00 of which appears to be proceeds of gambling violations: $3,500,000.00 was deposited from August 2008 through December 2011 from Smith Barney Reserved Client Financial Management Account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-202010 Non-Advisory Account, all of which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates. $1,761.35 was deposited as Consulting and Advisory Services from 12/05/11 to 12/31/11. 449. As of December 31, 2011 this account held a balance of $0.00 (includes
investment return/loss). Although a zero ($0.00) balance is reflected, the historical financial analysis of the account indicates that funds will ultimately be re-deposited, transferred, and/or swept back into the account throughout the year. Because this account received deposits of at least $1,000,000.00 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Burns, Chase 450. Morgan Stanley Smith Barney Smith Barney Reserved Client account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010
139
Jennison Large Cap Growth, was opened on or about March 25, 2010, with Chase Burns as the Account Owner. The current Account Owners are listed as Chase M. Burns and the Chase Burns Trust. The contact addresses listed for the account are P.O. Box 130,
Anadarko, Oklahoma 73005 and 34107 County Street 2580, Ft. Cobb, Oklahoma 73038. 451. Between March 25, 2010 and December 31, 2011, approximately
$2,001,288.28 was deposited into this account, at least $2,000,000.00 of which appears to be proceeds of gambling violations: $2,000,000.00 was deposited from March 2010 through December 2011 from Smith Barney Reserved Client Financial Management Account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-202010 Non-Advisory Account, all of which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates. $1,288.28 was deposited as Consulting and Advisory Services from 12/05/11 to 12/31/11. 452. As of December 31, 2011 this account held a balance of $0.00 (includes
140
Cambiar Investors Large Value, was opened on or about March 25, 2010, with Chase Burns as the Account Owner. The current Account Owners are listed as Chase M. Burns and the Chase Burns Trust. The contact addresses listed for the account are P.O. Box 130,
141
Clearbridge Multi-Cap Growth, was opened on or about March 25, 2010, with Chase Burns as the Account Owner. The current Account Owners are listed as Chase M. Burns and the Chase Burns Trust. The contact addresses listed for the account are P.O. Box 130,
investment return/loss). Although a zero ($0.00) balance is reflected, the historical financial analysis of the account indicates that funds will ultimately be re-deposited, transferred, and/or swept back into the account throughout the year. Because this account received deposits of at least $2,000,000.00 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Burns, Chase 459. Morgan Stanley Smith Barney Smith Barney Reserved Client Financial titled Chase Burns TTEE FBO Chase
Management account number
142
Burns Trust U/A/D 08-20-2010 NFJ Dividend Value, was opened on or about June 29, 2011, 2010, with Chase Burns as the Account Owner. The current Account Owners are listed as Chase M. Burns and the Chase Burns Trust. The contact addresses listed for the account are P.O. Box 130, Anadarko, Oklahoma 73005 and 34107 County Street 2580, Ft. Cobb, Oklahoma 73038. 460. Between June 29, 2011 and December 31, 2011, approximately $500,899.50
was deposited into this account, at least $500,000.00 of which appears to be proceeds of gambling violations: $500,000.00 was deposited from June 2011 through December 2011 from Smith Barney Reserved Client Financial Management Account number itled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-202010 Non-Advisory Account, all of which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates. $899.50 was deposited as Consulting and Advisory Services from 12/06/11 to 12/31/11. 461. As of December 31, 2011 this account held a balance of $255.60 (includes Although a $255.60 balance is reflected, the historical financial
investment return/loss).
analysis of the account indicates that funds will ultimately be re-deposited, transferred, and/or swept back into the account throughout the year. Because this account received deposits of at least $500,000.00 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702.
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Burns, Chase 462. Morgan Stanley Smith Barney Smith Barney Reserved Client account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Cubic Asset Mgmt SM/MID Value, was opened on or about March 25, 2010, with Chase Burns as the Account Owner. The current Account Owners are listed as Chase M. Burns and the Chase Burns Trust. The contact addresses listed for the account are P.O. Box 130, Anadarko, Oklahoma 73005 and 34107 County Street 2580, Ft. Cobb, Oklahoma 73038. 463. Between March 25, 2010 and December 31, 2011, approximately
$1,251,571.48 was deposited into this account, at least $1,251,233.48 of which appears to be proceeds of gambling violations: $1,251,223.48 was deposited from March 2010 through December 2011 from Smith Barney Reserved Client Financial Management Account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-202010 Non-Advisory Account, all of which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates. $348.10 was deposited as Consulting and Advisory Services from 12/05/11 to 12/31/11. 464. As of December 31, 2011 this account held a balance of $0.00 (includes
investment return/loss). Although a zero ($0.00) balance is reflected, the historical financial analysis of the account indicates that funds will ultimately be re-deposited, transferred, and/or swept back into the account throughout the year. Because this account received deposits of at least $1,251,223.48 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702.
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Burns, Chase 465. Morgan Stanley Smith Barney Smith Barney Reserved Client account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Syndicate, was opened on or about March 25, 2010, with Chase Burns as the Account Owner. The current Account Owners are listed as Chase M. Burns and the Chase Burns Trust. The contact addresses listed for the account are P.O. Box 130, Anadarko, Oklahoma 73005 and 34107 County Street 2580, Ft. Cobb, Oklahoma 73038. 466. Between March 25, 2010 and December 31, 2011, approximately
$1,010,500.00 was deposited into this account, at least $1,010,500.00 of which appears to be proceeds of gambling violations: $1,010,500.00 was deposited from March 2010 through December 2011 from Smith Barney Reserved Client Financial Management Account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-202010 Non-Advisory Account, all of which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates. 467. As of December 31, 2011 this account held a balance of $15,321.00 (includes
investment return/loss). Although a $15,321.00 balance is reflected, the historical financial analysis of the account indicates that funds will ultimately be re-deposited, transferred, and/or swept back into the account throughout the year. Because this account received deposits of at least $1,010,500.00 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702.
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Burns, Chase 468. Morgan Stanley Smith Barney Smith Barney Reserved Client Financial titled Chase Burns TTEE FBO Chase
Burns Trust U/A/D 08-20-2010 Miller/Howard Income Equity, was opened on or about November 16, 2010, with Chase Burns as the Account Owner. The current Account Owners are listed as Chase M. Burns and the Chase Burns Trust. The contact addresses listed for the account are P.O. Box 130, Anadarko, Oklahoma 73005 and 34107 County Street 2580, Ft. Cobb, Oklahoma 73038. 469. Between November 16, 2010 and December 31, 2011, approximately
$2,500,827.70 was deposited into this account, at least $2,500,000.00 of which appears to be proceeds of gambling violations: $2,500,000.00 was deposited from November 2010 through December 2011 from Smith Barney Reserved Client Financial Management Account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D Non-Advisory Account, all of which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates. $827.70 was deposited as Consulting and Advisory Services from 12/12/11 to 12/31/11. 470. As of December 31, 2011 this account held a balance of $1,103,554.73 Although a $1,103,554.73 balance is reflected, the
historical financial analysis of the account indicates that funds will ultimately be re-deposited, transferred, and/or swept back into the account throughout the year. Because this account received deposits of at least $2,500,000.00 in gambling proceeds, the funds are subject to
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forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Burns, Chase 471. Morgan Stanley Smith Barney Smith Barney Reserved Client account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D Eaton Vance Intermediate Muni, was opened on or about August 5, 2008, with Chase Burns as the Account Owner. The current Account Owners are listed as Chase M. Burns and the Chase Burns Trust. The contact addresses listed for the account are P.O. Box 130,
Anadarko, Oklahoma 73005 and 34107 County Street 2580, Ft. Cobb, Oklahoma 73038. 472. Between August 5, 2008 and December 31, 2011, approximately
$3,500,000.00 was deposited into this account, at least $3,500,000.00 of which appears to be proceeds of gambling violations: $3,500,000.00 was deposited from August 2008 through December 2011 from Smith Barney Reserved Client Financial Management Account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D Advisory Account, all of which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates. 473. As of December 31, 2011 this account held a balance of $4,041,769.42 Because this account received deposits of at least
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Burns, Chase 474. Morgan Stanley Smith Barney Smith Barney Reserved Client account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Western Asset Current Mkt Muni, was opened on or about August 5, 2008, with Chase Burns as the Account Owner. The current Account Owners are listed as Chase M. Burns and the Chase Burns Trust. The contact addresses listed for the account are P.O. Box 130,
Anadarko, Oklahoma 73005 and 34107 County Street 2580, Ft. Cobb, Oklahoma 73038. 475. Between August 5, 2008 and December 31, 2011, approximately
$3,200,174.04 was deposited into this account, at least $3,200,000.00 of which appears to be proceeds of gambling violations: $3,200,000.00 was deposited from August 2008 through December 2011 from Smith Barney Reserved Client Financial Management Account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-202010 Non-Advisory Account, all of which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates. $174.04 was deposited as Consulting and Advisory Services from 10/14/09 to 03/31/09. 476. As of December 31, 2011 this account held a balance of $3,389,627.95 Because this account received deposits of at least
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Burns, Chase 477. Morgan Stanley Smith Barney Smith Barney Reserved Client account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Brandes Emerging Markets, was opened on or about March 25, 2010, with Chase Burns as the Account Owner. The current Account Owners are listed as Chase M. Burns and the Chase Burns Trust. The contact addresses listed for the account are P.O. Box 130,
$2,000,359.97 was deposited into this account, at least $2,000,000.00 of which appears to be proceeds of gambling violations: $2,000,000.00 was deposited from March 2010 through December 2011 from Smith Barney Reserved Client Financial Management Account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-202010 Non-Advisory Account, all of which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates. $359.97 was deposited as Consulting and Advisory Services from 12/19/11 to 12/31/11 including other miscellaneous deposit descriptions. 479. As of December 31, 2011 this account held a balance of $0.00 (includes
investment return/loss). Although a zero ($0.00) balance is reflected, the historical financial analysis of the account indicates that funds will ultimately be re-deposited, transferred, and/or swept back into the account throughout the year. It should be noted that a Brandes
Investment Partners LP Notice of Termination dated December 5, 2011, is contained within the accounts financial records. Because this account received deposits of at least
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$2,000,000.00 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Burns, Chase 480. Morgan Stanley Smith Barney Smith Barney Reserved Client Financial titled Chase Burns TTEE FBO Chase
Burns Trust U/A/D 08-20-2010 Santa Barbara Dividend Growth, was opened on or about February 8, 2011, with Chase Burns as the Account Owner. The current Account Owners are listed as Chase M. Burns and the Chase Burns Trust. The contact addresses listed for the account are P.O. Box 130, Anadarko, Oklahoma 73005 and 34107 County Street 2580, Ft. Cobb, Oklahoma 73038. 481. Between February 8, 2011 and December 31, 2011, approximately
$1,500,825.18 was deposited into this account, at least $1,500,000.00 of which appears to be proceeds of gambling violations: $1,500,000.00 was deposited from November 2010 through December 2011 from Smith Barney Reserved Client Financial Management Account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Non-Advisory Account, all of which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates. $825.18 was deposited as Consulting and Advisory Services from 12/06/11 to 12/31/11. 482. As of December 31, 2011 this account held a balance of $0.00 (includes
investment return/loss). Although a zero ($0.00) balance is reflected, the historical financial analysis of the account indicates that funds will ultimately be re-deposited, transferred, and/or
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swept back into the account throughout the year. Because this account received deposits of at least $1,500,000.00 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Burns, Chase 483. Morgan Stanley Smith Barney Smith Barney Reserved Client Financial titled Chase Burns TTEE FBO Chase
Burns Trust U/A/D 08-20-2010 Clearbridge Dividend Strategy, was opened on or about May 6, 2011, with Chase Burns as the Account Owner. The current Account Owners are listed as Chase M. Burns and the Chase Burns Trust. The contact addresses listed for the account are P.O. Box 130, Anadarko, Oklahoma 73005 and 34107 County Street 2580, Ft. Cobb, Oklahoma 73038. 484. Between May 6, 2011 and December 31, 2011, approximately $1,006,399.80
was deposited into this account, at least $1,000,000.00 of which appears to be proceeds of gambling violations: $1,000,000.00 was deposited from May 2011 through December 2011 from Smith Barney Reserved Client Financial Management Account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-202010 Non-Advisory Account, all of which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates. $6,399.80 was deposited as Consulting and Advisory Services from 05/11/11 to 09/30/11 and Consulting and Advisory Services from 12/05/11 to 12/31/11. 485. As of December 31, 2011 this account held a balance of $0.00 (includes
investment return/loss). Although a zero ($0.00) balance is reflected, the historical financial
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analysis of the account indicates that funds will ultimately be re-deposited, transferred, and/or swept back into the account throughout the year. Because this account received deposits of at least $1,000,000.00 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Burns, Chase 486. Morgan Stanley Smith Barney Smith Barney Reserved Client account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 NFJ International Equity, was opened on or about March 25, 2010, with Chase Burns as the Account Owner. The current Account Owners are listed as Chase M. Burns and the Chase Burns Trust. The contact addresses listed for the account are P.O. Box 130, Anadarko, Oklahoma 73005 and 34107 County Street 2580, Ft. Cobb, Oklahoma 73038. 487. Between March 25, 2010 and December 31, 2011, approximately
$1,250,727.22 was deposited into this account, at least $1,250,000.00 of which appears to be proceeds of gambling violations: $1,250,000.00 was deposited from March 2010 through December 2011 from Smith Barney Reserved Client Financial Management Account number titled Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-202010 Non-Advisory Account, all of which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates. $727.22 was deposited as Consulting and Advisory Services from 12/06/11 to 12/31/11. 488. As of December 31, 2011 this account held a balance of $0.00 (includes
investment return/loss). Although a zero ($0.00) balance is reflected, the historical financial
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analysis of the account indicates that funds will ultimately be re-deposited, transferred, and/or swept back into the account throughout the year. Because this account received deposits of at least $1,250,000.00 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Burns, Chase 489. Morgan Stanley Smith Barney Citigroup Global Markets Inc. (CGMI) titled Chase Burns CGM SEP IRA
Individual Retirement Account number
Custodian U/P/O I.I.T. TRAK, was opened on or about December 9, 2010, with Chase E. Burns as the Account Owner/Participant. Account documents identify the Simplified
Employee Pension (SEP) Plan IRA employer for Chase E. Burns as International Internet Technologies, LLC with the employer addresses listed as 106 E. Kansas Ave, Anadarko, Oklahoma 73005 and P.O. Box 130, Anadarko, Oklahoma 73005. The contact addresses listed for Kristin Burns are P.O. Box 130, Anadarko, Oklahoma 73005 and 34107 County Street 2580, Ft. Cobb, Oklahoma 73038. 490. Between December 9, 2010 and December 31, 2011, approximately
$49,000.00 was deposited into this account, at least $49,000.00 of which appears to be proceeds of gambling violations: $49,000.00 was deposited from December 2010 through December 2011 and described as Deposit Received at 00604 Oklahoma City Employer Contribution Curr Yr. Any and/or all proceeds/contributions deposited from or on behalf of International Internet Technologies, LLC are illegal proceeds derived directly or indirectly from AVOTW Enterprise and/or the Affiliates.
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491.
As of December 31, 2011 this account held a balance of $46,745.55 (includes
investment return/loss). Because this account received deposits of at least $49,000.00 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Burns, Chase 492. Scottrade, Inc. (Scottrade) Brokerage Account number (11)
titled Chase Burns TTEE Chase Burns Trust U/A DTD 08/20/2010, was opened on or about June 30, 2011 with Chase Burns and the Chase Burns Trust, LLC as the listed Applicant/Grantor/Trust(Trustor)/Owner and Kristin Burns listed as the Successor Trustee. The contract address listed for the account is 106 E. Kansas Avenue, Anadarko, Oklahoma 73005-2637. 493. Between June 30, 2011 and January 31, 2012, approximately $2,260,373.25
was deposited into this account, at least $2,260,373.25 of which appears to be proceeds of gambling violations: Between January 01, 2011 and December 31, 2011, approximately 221,851 shares valued at $2,238,616.04 was deposited/transferred into the account as a stock adjustment from Scottrade Brokerage Account number (13) titled Chase Burns. Account number MidFirst Bank account number was fully funded by itled Chase Burns Trustee for the
Chase Burns Trust, which received $3,000,000.00 in deposits from illegal proceeds directly and/or indirectly from the AVOTW Enterprise and/or the Affiliates.
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$20,884.60 was deposited/transferred into the account between January 1, 2011 and December 31, 2011, as a balance transfer from Scottrade Brokerage Account number number (13) titled Chase Burns. Account
was fully funded by MidFirst Bank account number titled Chase Burns Trustee for the Chase Burns Trust, which
received $3,000,000.00 in deposits from illegal proceeds directly and/or indirectly from the AVOTW Enterprise and/or the Affiliates. $872.61 was deposited/transferred into the account between January 1, 2011 and December 31, 2011, as a balance transfer from Scottrade Brokerage Account number (13) titled Chase Burns. Account number
was fully funded by MidFirst Bank account number titled Chase Burns Trustee for the Chase Burns Trust, which received $3,000,000.00 in deposits from illegal proceeds directly and/or indirectly from the AVOTW Enterprise and/or the Affiliates. 494. As of January 31, 2012 this account held a balance of $1,345,215.90 (includes
investment return/loss). Because this account received deposits of at least $2,260,373.25 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Burns, Chase 495. Scottrade, Inc. (Scottrade) Brokerage Account number (13)
titled Chase Burns, was opened on or about June 30, 2011 with Chase Burns as the listed Applicant/Owner. The contact address listed for this account is P.O. Box 130, Anadarko, Oklahoma 73005-0130.
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96.
Between January 1, 2007 and July 31, 2011, approximately $3,000,000.00 was
deposited into this account, at least $3,000,000.00 of which appears to be proceeds of gambling violations: $1,000,000.00 was deposited into the between January 01, 2008 and December 31, 2008, from MidFirst Bank account number titled
Chase Burns Trustee for the Chase Burns Trust, which received illegal proceeds directly and/or indirectly from the AVOTW Enterprise and/or the Affiliates. $1,000,000.00 was deposited into the between January 01, 2010 and December 31, 2010, from MidFirst Bank account number titled
Chase Burns Trustee for the Chase Burns Trust, which received illegal proceeds directly and/or indirectly from the AVOTW Enterprise and/or the Affiliates. $1,000,000.00 was deposited into the between January 01, 2011 and July 31, 2011, from MidFirst Bank account number titled Chase Burns
Trustee for the Chase Burns Trust, which received illegal proceeds directly and/or indirectly from the AVOTW Enterprise and/or the Affiliates. 497. As of July 31, 2011, this account held a zero ($0.00) balance (includes
investment return/loss). Because this account received deposits of at least $3,000,000.00 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702.
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Burns, Chase 498. JPMorgan Chase Bank, N.A. account number appears to be
held by Goldman Sachs & Co., N.Y. under the Hedge Fund investment account titles of Sophrosyne Technology Partners, L.P, Sophrosyne Technology Partners, LP Acct. Sophrosyne Malthusian Partners LP A/C Malthusian Partners LP A/C and Sophrosyne
). The Hedge Fund investment accounts were
partially funded by wire transfers directly from the Chase Burns Trustee for the Chase Burns Trust (MidFirst Bank account number ). It should be noted that a Hedge Fund
is a pooled investment account by several investors with a minimum investment requirement of each. The financial institution and indicated account number receiving the funds may be a corresponding bank and/or account only and not the actual financial institution and/or account where the investment is held. As of this writing, only wire transfer records from JPMorgan Chase Bank, N.A. account number Originator account(s) have been analyzed. transactions (deposits) were identified. 499. Between May 2, 2011 and April 2, 2012 approximately $6,000,000.00 was and the Chase Burns
During the analysis the following financial
deposited into this account, at least $6,000,000.00 of which appears to be proceeds of gambling violations: $1,000,000.00 wire transfer indicates (OBI: for further payment to Sophrosyne Technology Partners, LP Acct. Bank Trust Account ), Originator Chase Burns MidFirst on 05/02/2011, (Beneficiary) Credit Party:
Goldman Sachs & Co., N.Y. Transferred/deposited funds originated from the Chase Burns Trustee for the Chase Burns Trust (MidFirst
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Bank account number
which received illegal proceeds directly
and/or indirectly from the AVOTW Enterprise and/or the Affiliates. $1,000,000.00 wire transfer indicates (OBI: for further payment to Sophrosyne Technology Partners, L.P), Originator Chase Burns MidFirst Bank Trust Account on 06/29/2011, (Beneficiary) Credit Party:
Goldman Sachs & Co., N.Y. Transferred/deposited funds originated from the Chase Burns Trustee for the Chase Burns Trust (MidFirst Bank account number 1 which received illegal proceeds directly
and/or indirectly from the AVOTW Enterprise and/or the Affiliates. $1,000,000.00 wire transfer indicates (Bank to Bank Info: /BNF/Further Payable to Sophrosyne Malthusian Partners LP A/C Burns MidFirst Bank Trust Account Originator Chase on 04/02/2012, Credit Party:
Goldman Sachs & Co., N.Y. Transferred/deposited funds originated from the Chase Burns Trustee for the Chase Burns Trust (MidFirst Bank account number which received illegal proceeds directly
and/or indirectly from the AVOTW Enterprise and/or the Affiliates. $3,000,000.00 wire transfer indicates (Bank to Bank Info: /BNF/Further Payable to Sophrosyne Malthusian Partners LP A/C Burns MidFirst Bank Trust Account 1 , Originator Chase on 04/02/2012, Credit Party:
Goldman Sachs & Co., N.Y. Transferred/deposited funds originated from the Chase Burns Trustee for the Chase Burns Trust (MidFirst Bank account number which received illegal proceeds directly
and/or indirectly from the AVOTW Enterprise and/or the Affiliates.
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500.
As of this writing, the accounts current balance is unknown. However, because
this account (pooled investment) did receive deposits of at least $6,000,000.00 in gambling proceeds, the value of the funds transferred into the account from the Chase Burns Trustee for the Chase Burns Trust are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Burns, Chase 501. JPMorgan Chase Bank, N.A. account number appears to
hold the Hedge Fund investment account titled Sophrosyne Technology Partners, Ltd (Sophrosyne Capital, LLC, c/o Sophrosyne Technology Partners). The Hedge Fund
investment account was partially funded by wire transfers directly from Give It Away Foundation, a Chase Burns and Kristin Burns Not-For-Profit-Corporation, utilizing MidFirst Bank account number It should be noted that a Hedge Fund is a pooled
investment account by several investors with a minimum investment requirement of each. The financial institution and indicated account number receiving the funds may be a corresponding bank and/or account only and not the actual financial institution and/or account where the investment is held. As of this writing, only wire transfer records from JPMorgan Chase Bank, N.A. account number Foundation MidFirst Bank account number the Give It Away , and other Chase Burns and Kristin
Burns Originator account(s) have been analyzed. During the analysis the following financial transactions (deposits) were identified. 502. On December 26, 2011 approximately $1,000,000.00 was deposited into this
account, at least $1,000,000.00 of which appears to be proceeds of gambling violations:
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$1,000,000.00 wire transfer indicates (OBI: Beneficiary Name-Sophrosyne Technology Partners, Ltd), Originator: Give It Away Foundation MidFirst Bank Account on Sophrosyne 12/28/2011, Technology (Beneficiary) Partners, Credit Ltd. Party: Funds
transferred/deposited from the Give It Away Foundation (MidFirst Bank account ) to the investment originated from the Chase Burns Trustee for the Chase Burns Trust (MidFirst Bank account number ) which
received illegal proceeds directly and/or indirectly from the AVOTW Enterprise and/or the Affiliates. 503. As of this writing, the accounts current balance is unknown. However, because
this account (pooled investment) did receive deposits of at least $1,000,000.00 in gambling proceeds, the value of the funds transferred into the account from the Give It Away Foundation are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Burns, Kristin & Chase 504. MidFirst Bank account number titled Kristin P. Burns and Chase
Burns Signature Checking was opened on or about January 17, 2006, with Kristin PORTER as the Account Owner and a contact address of 811 Tottingham Rd., Anadarko, Oklahoma 73005-5810. Account Information documents reveal that a MidFirst Bank Safe Deposit Box Lease Agreement (Box number 304) was entered into and signed by Kristin Porter (Burns) on January 17, 2006. New Account Information replacement documents dated August 18, 2006 retitle the account as the Kristin P. Burns Individual Signature Checking account with Kristin P. BURNS as the account owner. Though no further New Account Information
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replacement documents were provided by MidFirst Bank, it should be noted that from January 2007 through March 2011, the account monthly statements titled the account the Kristin P. BURNS and Chase BURNS Signature Checking account. In addition, check
images indicate that checks written on the account since January 4, 2007, have been titled Chase E. or Kristin P. Burns utilizing the addresses of either 111 NW 2nd St., Apt. 134, Anadarko, Oklahoma 73005-2801 or P.O. Box 130, Anadarko, Oklahoma 73005. 505. Between January 2007 and March 2012, approximately $990,601.46 was
deposited into this account, at least $937,184.55 of which appears to be proceeds of gambling violations: $608,659.36 was deposited between January 2007 through March 2012 from MidFirst Bank account number titled Chase Burns and Kristin P.
Burns Titanium Money Market Savings account (closed August 2009), of which received illegal proceeds directly and/or indirectly from AVOTW and/or the Affiliates. It should be noted that account received approximately titled
$700,000.00 in deposits from MidFirst Bank account number
Chase Burns Trustee for the Chase Burns Trust (described within this affidavit), which also received illegal proceeds derived directly and/or indirectly from the AVOTW Enterprise and/or the Affiliates. $76,837.63 was deposited between January 2007 through March 2012 from MidFirst Bank account number titled Burns Family Cattle, LLC
(previously titled Chase Burns DBA CB Farms)(described within this affidavit), which received illegal proceeds directly and/or indirectly from AVOTW and/or the Affiliates.
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$39,632.41 was deposited between January 2007 through March 2012 from MidFirst Bank account number titled Burns Family Land Co., LLC
(previously titled Chase Burns DBA OK Coin)(described within this affidavit), which received illegal proceeds directly and/or indirectly from AVOTW and/or the Affiliates. $100,371.15 was deposited between January 2007 through March 2012 from the following International Internet Technologies LLC accounts; $99,924.91 from Bank of America account (described within this affidavit) , both of
and $446.24 from Anadarko Bank & Trust Company account
which received illegal proceeds directly and/or indirectly from AVOTW and/or the Affiliates. $62,812.00 was deposited between January 2007 through March 2012 from MidFirst Bank account number titled Chase Burns Trustee for the
Chase Burns Trust (described within this affidavit), which received illegal proceeds directly and/or indirectly from AVOTW and/or the Affiliates. $48,872.00 was deposited between January 2007 through March 2012 from JPMorgan Chase Bank, N.A. Chase Workplace Checking account number titled Kristin P. Burns, which received illegal proceeds directly and/or indirectly from the AVOTW Enterprise and/or the Affiliates. 506. As of March 24, 2012 this account held a balance of $6,260.63. Because this
account received deposits of at least $937,184.55 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702.
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Burns, Kristin 507. MidFirst Bank account number titled Kristin P. Burns (Payable on
Death) Titanium Money Market Savings was opened on or about January 17, 2006. Recent account documents identify Kristin P. BURNS as the account Owner and Chase Burns as the POD Beneficiary and Authorized Signor. The contact address listed for the account is P.O. Box 130, Anadarko, Oklahoma, 73005-0130. The contact address listed for Kristin P. Burns and Chase Burns is 106 E. Kansas Ave, Anadarko, Oklahoma, 73005-2637. 508. Between January 2007 and February 2012, approximately $540,788.14 was
deposited into this account, at least $498,591.54 of which appears to be proceeds of gambling violations: $480,209.30 was deposited between January 2007 through March 2012 from the following accounts; $475,065.00 from JPMorgan Chase Bank, N.A. Chase Workplace Checking account number and $5,144.30 from MidFirst Bank account number itled Kristin P. Burns (closed) titled
Kristin P. Burns (Payable On death), both of which received illegal proceeds directly and/or indirectly from the AVOTW Enterprise and/or the Affiliates. $2,072.24 was deposited between January 2007 through February 2012 from MidFirst Bank account number titled Burns Family Land Co., LLC
(previously titled Chase Burns DBA OK Coin)(described within this affidavit), which received illegal proceeds directly and/or indirectly from AVOTW and/or the Affiliates. $5,348.00 was deposited between January 2007 through February 2012 from Bank of America account number titled International Internet
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Technologies, LLC (described within this affidavit), which received illegal proceeds directly and/or indirectly from AVOTW and/or the Affiliates. $9,562.00 was deposited between January 2007 through February 2012 from Bank of the West account number whose account owner appears
as Kristin Porter (Burns)(as indicated on check images), which received illegal proceeds directly and/or indirectly from AVOTW and/or the Affiliates. $400.00 was deposited between January 2007 through February 2012 from MidFirst Bank account number titled Kristin P. Burns and Chase
Burns Signature Checking (described within this affidavit), which received illegal proceeds directly and/or indirectly from AVOTW and/or the Affiliates. $1,000.00 was deposited between January 2007 through February 2012 from MidFirst Bank account number titled (described within
this affidavit), which received illegal proceeds directly and/or indirectly from AVOTW and/or the Affiliates. 509. As of February 29, 2012 this account held a balance of $554,076.95. Because
this account received deposits of at least $498,591.54 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Burns, Kristin 510. Morgan Stanley Smith Barney Citigroup Global Markets Inc. (CGMI) titled Kristin P. Burns CGM SEP
Individual Retirement Account number
IRA Custodian U/P/O I.I.T. TRAK, was opened on or about December 9, 2010, with Kristin P. Burns as the Account Owner/Participant. Account documents identify the Simplified
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Employee Pension (SEP) Plan IRA employer for Kristin P. Burns as International Internet Technologies, LLC with the employer addresses listed as 106 E. Kansas Ave, Anadarko, Oklahoma 73005 and P.O. Box 130, Anadarko, Oklahoma 73005. The contact addresses listed for Kristin P. Burns are P.O. Box 130, Anadarko, Oklahoma 73005 and 34107 County Street 2580, Ft. Cobb, Oklahoma 73038. 511. Between December 9, 2010 and December 31, 2011, approximately
$98,000.00 was deposited into this account, at least $98,000.00 of which appears to be proceeds of gambling violations: $98,000.00 was deposited from December 2010 through December 2011 and described as Deposit Received at 00604 Oklahoma City Employer Contribution Curr Yr. Any and/or all proceeds/contributions deposited from or on behalf of International Internet Technologies, LLC are illegal proceeds derived directly or indirectly from AVOTW Enterprise and/or the Affiliates. 512. As of December 31, 2011 this account held a balance of $95,746.37 (includes
investment return/loss). Because this account received deposits of at least $98,000.00 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Burns, Kristin 513. JPMorgan Chase Bank, N.A., Chase Workplace Checking account number was originally was opened with BankOne on or about October 10, 2000 and titled Kristin A. Porter (Basic One Checking). The account opening signature card identified Kristin A. Porter as the sole signor with a consumer address of 61 Lexington Ln, Hilton Head, South Carolina 29928. Current monthly statements identify the account title as
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the Kristin P. Burns (Chase Workplace Checking) with a contact address of P.O. Box 130, Anadarko, Oklahoma 73005-130. 514. Between December 22, 2009 and May 21, 2012, approximately $496,570.24
was deposited into this account, at least $476,138.33 of which appears to be proceeds of gambling violations: $476,138.33 was deposited between December 22, 2009 and May 21, 2012, from International Internet Technologies, LLC which received illegal proceeds directly or indirectly from AVOTW and/or the Affiliates. Of these deposits, all were identified on the monthly statements as International IN Payroll PPD ID: . As of this writing, the bank of origin for the deposits is unknown. It is also unknown as to whether the deposits were transferred directly and/or indirectly through a correspondent bank and/or account held by a Professional Employer Organization (PEO) as contracted by International Internet Technologies, LLC and/or the AVOTW Enterprise. 515. As of May 21, 2012 this account held a balance of $72,603.21. Because this
account received deposits of at least $498,591.54 in gambling proceeds, the funds are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 932.702. Collins, Leslie 516. Wachovia Bank regular checking account # was opened on or
about December 18, 2010 in the name of Leslie L. Collins. Collins is listed as the signor on the account. The contact address for this account is listed as Collins residence, 31
Sundunes Circle, Ponce Inlet, FL 32127.
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517.
Between December 10, 2010 and February 24, 2012, $183,438.34 was
deposited into this account, at least $164,838.34 of which appears to be proceeds of the gambling violations: $53,584.41 was deposited from (2) Blue Waters Technologies, Inc. Bank of America accounts ending in and which received illegal proceeds
from AVOTW Affiliates 50, 58 and 60. $100,588.05 was deposited from Coastal Games, LLC Bank of America account ending in 35, 36, and 49. $9,165.88 was deposited from Coastal Games, LLC DBA Hot Spot Bank of America account ending in Affiliates 35, 36, and 49. $800.00 was deposited from Stephanie Weeks/Brent Weeks Regions account ending in which indirectly received illegal proceeds from AVOTW , which received illegal proceeds from AVOTW which received illegal proceeds from AVOTW Affiliates
Affiliates 50, 58, 60. $700.00 was deposited from Anthony Parker Wells Fargo account ending in , which indirectly received illegal proceeds. 518. As of February 9, 2012 this account had a balance of $16,357.54. Because
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Collins, Leslie 519. Wachovia Bank regular checking account # was opened on or
about December 22, 2010 in the name of Leslie L. Collins. Collins is listed as the signor on the account. The contact address for this account is listed as Collins residence, 31
Sundunes Circle, Ponce Inlet, FL 32127. 520. Between December 22, 2010 and February 21, 2012, $68,088.64 was
deposited into this account, at least $65,052.00 of which appears to be proceeds of the gambling violations: $65,052.00 was deposited from Leslie Collins Wachovia account ending in , which indirectly received illegal proceeds. 521. As of February 21, 2012 this account had a balance of $68,639.13. Because
this account received deposits of gambling proceeds, the funds in this account up are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Cuba, Nelson 522. VyStar Credit Union primary savings account# and VyStar Credit
Union checking account#
was opened on or about August 2007 in the name of
Nelson D. Cuba. Cuba is listed as the sole signor on the accounts. The contact address listed on the accounts is 523. As previously stated in your affiants Master Affidavit, NELSON CUBA is an
authorized signor on a shell corporation account in the name of Enzyme Consultants that receives and/or received gambling proceeds from Seaside Internet, previously described. An analysis of a VyStar Credit Union savings account and checking account in the name of
168
Nelson Cuba indicates that CUBA deposited cash into the aforementioned accounts after withdrawals were made from the Enzyme Consultants account. reflects the financial transactions: Chart 9: VyStar Credit Union Account 7010 Analysis
Date 9/15/2009 10/13/2009 11/4/2009 11/4/2009 11/24/2009 1/6/2010 1/20/2010 7/13/2010 11/23/2010 Amount $2,500.00 $3,000.00 $2,000.00 $2,000.00 $1,000.00 $1,500.00 $2,000.00 $3,000.00 $2,600.00 Type

The below listed chart
Account - Savings - Savings Checking - Savings Checking Checking
Location

Address

Enzyme withdrawal
Comparison
9/15/2009 $9,000.00 10/13/2009 $9,000.00 11/3/2009 $6,000.00 11/3/2009 $6,000.00 11/23/2009 $6,000.00 1/5/2010 $6,000.00 1/19/2010 $8,400.00 7/12/2010 $8,400.00 11/16/2010 $5,400.00
cash deposit
branch
cash deposit
branch ATM ATM ATM ATM
1802 Kernan Blvd 686 Commerce Center 7802 Atlantic Blvd 686 Commerce Center 686 Commerce Center 6014 Merrill Road 6014 Merrill Road 6014 Merrill Road
cash deposit cash deposit cash deposit cash deposit cash deposit cash deposit cash deposit cash deposit
Checking Checking
11/23/2010 11/29/2010 12/6/2010 1/7/2011 1/8/2011 1/13/2011
$200.00 $1,900.00 $1,000.00 $4,900.00 $6,000.00 $5,500.00
Checking Checking Checking Checking Checking Checking
ATM ATM ATM ATM branch ATM
11/16/2010(2)
$5,400.00(2)
11/29/2010 $2,000.00 12/6/2010 $3,200.00 1/3/2011 $3,400.00 1/3/2011(2) $3,400.00(2) 1/10/2011 $5,000.00
686 Commerce Center
169
Date 1/29/2011
Amount $900.00
Type cash deposit cash deposit cash deposit cash deposit cash deposit cash deposit cash deposit cash deposit cash deposit cash deposit cash deposit cash deposit cash deposit cash deposit cash deposit cash deposit
Account
Location ATM
Address 686 Commerce Center 686 Commerce Center 5184 Norwood Ave 686 Commerce Center 686 Commerce Center
Enzyme withdrawal
Comparison
Checking
1/24/2011 $6,600.00
1/29/2011
$100.00
Checking
ATM
1/24/2011(2) $6,600.00(2)
2/1/2011
$2,000.00
Checking
ATM
1/31/2011 $5,200.00
2/10/2011
$2,500.00
Checking
ATM
2/8/2011 $5,200.00
2/15/2011 2/22/2011 4/13/2011 4/22/2011 6/2/2011 6/23/2011 7/8/2011
$750.00 $5,000.00 $4,000.00 $6,000.00 $7,000.00 $1,800.00 $2,000.00
Checking Checking Checking Checking Checking Checking Checking
ATM branch ATM branch ATM ATM ATM
2/14/2011 $7,600.00 2/14/2011(2) $7,600.00(2) 4/12/2011 $5,600.00 4/19/2011 $5,600.00 5/31/2011 $5,000.00 6/20/2011 $5,600.00 7/6/2011 $5,400.00
686 Commerce Center
686 Commerce Center 6014 Merrill Road 686 Commerce Center 686 Commerce Center 686 Commerce Center 7802 Atlantic Blvd 7802 Atlantic Blvd 7802 Atlantic Blvd
7/27/2011
$2,200.00
Checking Checking Checking Checking Checking
ATM
7/20/2011 $4,400.00
9/9/2011 10/12/2011 10/21/2011 11/8/2011
$2,000.00 $2,300.00 $2,000.00 $1,850.00
ATM ATM ATM ATM
9/6/2011 $3,800.00 10/11/2011 $4,800.00 10/19/2011 $5,000.00 11/7/2011 $3,600.00
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Date 1/5/2012 2/13/2012 3/12/2012
Amount $700.00 $1,800.00 $2,300.00
Type cash deposit cash deposit cash deposit cash deposit cash deposit
Account Checking Checking Checking Checking Checking
Location ATM ATM ATM
Address 6014 Merrill Road 7802 Atlantic Blvd 686 Commerce Center 686 Commerce Center
Enzyme withdrawal
Comparison
12/28/2011 $4,600.00

3/18/2012 3/28/2012
$2,000.00 $4,100.00 $92,400.00
ATM branch
524.
Your affiant believes because these two (2) accounts received deposits of
gambling proceeds, the funds in these accounts are subject to forfeiture as the proceeds of gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Cucciniello, John & Nikki 525. Bank of America interest checking account # was opened on or
about September 13, 2007 in the name of John Cucciniello and Nikki Cucciniello. John and Nikki Cucciniello are listed as the signors on the account. The contact address for this account is listed as John and Nikki Cucciniellos residence, 5195 Montford Circle, Spring Hill, FL 34606-1547. 526. Between December 15, 2010 and March 13, 2012, $402,918.45 was deposited
into this account, at least $146,309.98 of which appears to be proceeds of the gambling violations: $145,186.80 was deposited from GINLIN, LLC Bank of America account ending in and ADP account, which received illegal proceeds from AVOTW
Affiliates 45, 52, 70 and 76.

171
$1,000.00 was deposited from John Cucciniello/DBA Funtasia Sweeps Bank of America account ending in , which indirectly received illegal proceeds. which
$123.18 was deposited from Felonies, LLC ADP account ending in indirectly received illegal proceeds.
527.
As of February 9, 2012 this account had a balance of $9,369.11. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as the proceeds of gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Cucciniello, John 528. Bank of America regular checking account # was opened on or
about March 19, 2008 in the name of John Cucciniello. John Cucciniello is listed as the signor on the account. The contact address for this account is listed as Cucciniellos
residence, 5195 Montford Circle, Spring Hill, FL 34606-1547. 529. Between December 15, 2010 and March 13, 2012, $158,278.53 was deposited
into this account, at least $75,700.00 of which appears to be proceeds of the gambling violations: $15,500 was deposited from John & Nikki Cucciniello Bank of America account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 45, 52, 70 and 76. $59,800.00 was deposited from John & Nikki Cucciniello Bank of America account ending in , which indirectly received illegal proceeds.
$400.00 was deposited from John Cucciniello/DBA Funtasia Sweeps Bank of America account ending in , which indirectly received illegal proceeds.
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530.
As of February 9, 2012 this account had a balance of $432.97. Because this
account received deposits of gambling proceeds the funds in this account are subject to forfeiture as the proceeds of gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Cucciniello, John 531. Bank of America Money market savings account # was opened
on or about least December 21, 2010 in the name of John Cucciniello. John Cucciniello is listed as the signor on the account. The contact address for this account is listed as
Cucciniellos residence, 5195 Montford Circle, Spring Hill, FL 34606-1547. 532. Between December 15, 2010 and March 13, 2012, $65,265.19 was deposited
into this account, at least $60,000.00 of which appears to be proceeds of the gambling violations: $60,000.00 was deposited from John & Nikki Cucciniello Bank of America account ending in , which indirectly received illegal proceeds from AVOTW
Affiliates 45, 52, 70 and 76. 533. As of February 9, 2012 this account had a balance of $11,042.66. Because
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as the proceeds of gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Davis, Michael, Davis, Gary & Davis, Diane 534. Bank of America interest checking account# was opened since
at least April 21, 2000 in the name of Diane M Davis or Gary W Davis, Michael S Davis. This account was opened at the College Park Banking Center in Georgia. Diane M Davis, Gary
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W Davis, and Michael Davis are listed as the signors on the account. The contact address for this account is listed as 107 Hogan Coweta Rd, Hogansville, GA 30230-2852. 535. Between December 28, 2010 and March 26, 2012, $145,358.08 was deposited
into this account, at least $82,026.30 of which appears to be proceeds of the gambling violations: $4,832.63 was deposited from Davis Internet Managements Bank accounts which received direct and indirect illegal proceeds. o $4,000.00 was deposited from Davis Internet Managements Bank of America account ending in from AVOTW Affiliate 46. o $832.63 was deposited from Davis Internet Management unknown account. $77,193.67 was deposited from MSG Business Centers, Inc. Bank accounts which received direct and indirect illegal proceeds. o $3,000.00 was deposited from MSG Business Centers, Inc. Bank of America account ending in which received illegal proceeds which received illegal proceeds
from AVOTW Affiliates 39, 40 and 68. o $74,193.67 was deposited from MSG Business Centers, Inc. unknown account. 536. As of March 26, 2012 this account had a balance of $25,465.92. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S.S 932.702.
174
Davis, Michael, Davis, Gary & Davis, Diane 537. Bank of America money market savings account# was opened
on or about April 21, 2000 in the name of Diane M Davis or Gary W Davis, Michael S Davis. This account was opened at the East Point Banking Center in East Point, Georgia. Diane M Davis, Gary W Davis and Michael Davis are listed as the signors on the account. The contact address for this account is listed as 107 Hogan Coweta Rd, Hogansville, GA 302302852. 538. Between December 28, 2010 and March 26, 2012, $25,017.50 was deposited
into this account, at least $18,000.00 of which appears to be proceeds of the gambling and $17.50 from interest accrued: $18,000.00 was deposited from Davis Internet Management Bank of America account ending in 46. 539. As of March 26, 2012 this account had a balance of $27,364.88. Because this , which received illegal proceeds from AVOTW Affiliate
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Davis, Michael, Davis, Gary & Davis, Diane 540. Bank of America interest checking account# was opened since
November 25, 2011 in the name of Michael S Davis, Diane M Davis, Gary Wayne Davis. This account was opened at the Eighth Street Banking Center in Fernandina Beach, Florida. Michael Davis, Diane Davis and Gary Davis are listed as the signors on the account. The
175
contact address for this account is listed as 107 Hogan Coweta Rd, Hogansville, GA 302302852. 541. Between December 28, 2010 and March 26, 2012, $145,734.48 was deposited
into this account, at least $74,031.40 of which appears to be proceeds of the gambling violations: $15,000.00 was deposited from Allied Veterans of the World & Affiliate Bank of America account ending in AVOTW Affiliates. $12,506.40 was deposited from Three (3) Diane Davis, Gary Davis & Michael Davis related accounts ending in and which indirectly which received illegal proceeds from all
received proceeds indirectly from AVOTW Affiliates 39, 40, 46 and 68. $46,525.00 was deposited from MSG Business Centers, Inc. Bank of America account, which received illegal proceeds from AVOTW Affiliates 39, 40 and 68. 542. As of March 26, 2012 this account had a balance of $5,912.44. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Davis, Michael & Davis, Diane 543. Bank of America money market savings account was opened
on or about April 23, 2004 in the name of Diane Davis, Michael S Davis. This account was opening at the East Point Banking Center in East Point, Georgia. Diane Davis is listed as the signor on the account. The contact address for this account is listed as 107 Hogan Coweta Rd, Hogansville, GA 30230-2852.
176
544.
Between December 28, 2010 and March 26, 2012, $12,699.55 was deposited
into this account, at least $12,697.99 of which appears to be proceeds of the gambling and $1.56 from interest accrued: $1,500.00 was deposited from Davis Internet Management Bank of America account ending in 46. $697.99 was deposited from Mathis & Murphy, PA Jacksonville Bank account ending in which received illegal proceeds from all AVOTW Affiliates. which received illegal proceeds from AVOTW Affiliate
$10,500.00 was deposited from MSG Business Centers, Inc. Bank of America account ending in 39, 40 and 68. which received illegal proceeds from AVOTW Affiliates
545.
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Davis, Michael 546. Wells Fargo essential checking account# was opened on or
about December 8, 2010 in the name of Michael Davis. It is unknown which banking center this account was opened at. Michael Davis is listed as the signor on the account. The contact address for this account is listed as 7633 Royal Crest Dr, Jacksonville, FL 322562321.
177
547.
Between December 8, 2010 and February 8, 2012, $111,682.94 was deposited
into this account, at least $97,280.94 of which appears to be proceeds of the gambling violations: $23,256.44 was deposited from Davis Internet Managements Bank accounts which received direct and indirect illegal proceeds. o $9,500.00 was deposited from Davis Internet Managements Bank of America account ending in from AVOTW Affiliate 46. o $13,756.44 was deposited from Davis Internet Management unknown account. $71,724.50 was deposited from MSG Business Centers, Inc. Bank accounts which received direct and indirect illegal proceeds. o $16,000.00 was deposited from MSG Business Centers, Inc. Bank of America account ending in which received illegal proceeds which received illegal proceeds
from AVOTW Affiliates 39, 40 and 68. o $55,724.50 was deposited from MSG Business Centers, Inc. unknown account. $800.00 was deposited from Diane & Gary Davis Bank of America account ending in 40, 46 and 68. $1,500.00 was deposited from Michael Davis Bank of America account ending in , which indirectly received illegal proceeds from AVOTW Affiliates 49, which indirectly received illegal proceeds AVOTW Affiliates 49,
40, 46 and 68.
178
548.
As of February 8, 2012 this account had a balance of $1,760.88. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Duncan, Johnny & Linda 549. Bank of America interest checking account# was opened on or
about April 23, 2009 in the name of Johnny E Duncan, Linda A Duncan. This account was opened at the Duncan Banking Center in Duncan, South Carolina. Johnny & Linda Duncan are listed as the signors on the account. The contact address for this account is listed as PO Box 160939, Boiling Springs, SC 29316-0016. 550. Between December 28, 2010 and March 26, 2012, $1,012,628.56 was
deposited into this account, at least $878,966.28 of which appears to be proceeds of the gambling violations: $668,966.28 was deposited from Allied Veterans Management Group, Inc. Bank of America account ending in all AVOTW Affiliates. $70,000.00 was deposited from All-Pro Tax and Accounting LLC Palmetto Bank account ending in AVOTW Affiliates. $100,000.00 was deposited from Automated X-100 Services Bank of America account ending in AVOTW Affiliates. which indirectly received illegal proceeds from all which indirectly received illegal proceeds from all which received illegal proceeds from
179
$40,000.00 was deposited from Johnny & Linda Duncan Bank of America account ending in AVOTW Affiliates. which indirectly received illegal proceeds from all
551.
As of March 26, 2012 this account had a balance of $308,470.49. Because
this account received deposits of gambling proceeds the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Duncan, Johnny & Linda 552. Bank of America interest checking account# was opened on or
about January 14, 2007 in the name of Linda A Duncan, Johnny E Duncan. This account was opened at the Pinewood Banking Center in Spartanburg, South Carolina. Johnny & Linda Duncan are listed as the signors on the account. The contact address for this account is listed as Duncans residence, 240 Oldmaster Ct, Boiling Springs, SC 29316-5659. 553. Between December 10, 2010 and March 8, 2012, $172,173.22 was deposited
into this account, at least $147,387.52 of which appears to be proceeds of the gambling violations: $79,299.97 was deposited from Allied Veterans Management Group, Inc. Bank of America account ending in AVOTW Affiliates. $50,000.00 was deposited from All-Pro Tax and Accounting LLC Palmetto Bank account ending in AVOTW Affiliates. which indirectly received illegal proceeds from all , which received illegal proceeds from all
180
$15,014.12 was deposited from Automated X-100 Services Bank of America account ending in AVOTW Affiliates. which indirectly received illegal proceeds from all
$3,073.43 was deposited from Johnny & Linda Duncan Bank of America account ending in AVOTW Affiliates. which indirectly received illegal proceeds from all
554.
account received deposits of gambling proceeds the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Duncan, Johnny & Linda 555. Bank of America regular checking account# was opened on or
about December 10, 2010 in the name of Johnny E Duncan, Linda A Duncan R-Account. Johnny & Linda Duncan are listed as the signors on the account. The contact address for this account is listed as Duncans residence, 240 Oldmaster Ct, Boiling Springs, SC 293165659. 556. Between December 10, 2010 and March 8, 2012, $194,049.60 was deposited
into this account, at least $48,500.00 of which appears to be proceeds of the gambling violations: $48,000.00 was deposited from All-Pro Tax and Accounting LLC Palmetto Bank account ending in AVOTW Affiliates. which indirectly received illegal proceeds from all
181
$500.00 was deposited from Johnny & Linda Duncan Bank of America account ending in Affiliates. which indirectly received illegal proceeds from all AVOTW
557.
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Graham, Michael W. & Graham, Kelly E. H. 558. Horry County State Bank, Easy Internet Checking Account # was
opened on March 19th, 2007 in the name of Michael W. Graham payable on death to Kelly E. H. Graham as beneficiary. Michael Graham is listed as the authorized signor on the account. The contact address for this account is listed as 249 Carriage Lake Dr. Little River, SC 29566. 559. Between January, 2011 and February, 2012, $233,303.43 was deposited into
this account, of which at least $222,341.61 appears to be proceeds of the gambling violations: $57,470.54 was deposited from Gainesville Internet Services, LLC Bank of America accounts which received direct and indirect illegal proceeds. $153,244.53 was deposited from Lake City Internet Services, LLC Bank of America unknown account which received direct and indirect illegal proceeds. $1,626.54 was deposited from Live Oak Internet Services, LLC Bank of America unknown account which received direct and indirect illegal proceeds.
182
$10,000.00 was deposited via a transfer from Michael Grahams Horry County State Bank, Money Market Account ( proceeds; ) which also receives illegal
560.
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Graham, Michael W. & Graham, Kelly E. H. 561. Horry County State Bank, Horry Money Market Account # was
opened on March 19th, 2007 in the name of Michael W. Graham payable on death to Kelly E. H. Graham as beneficiary. Michael Graham is listed as the authorized signor on the account. The contact address for this account is listed as 249 Carriage Lake Dr. Little River, SC 29566. 562. Between January, 2011 and February, 2012, $58,834.78 was deposited into
this account, of which at least $21,951.06 appears to be proceeds of the gambling violations: $1,887.06 was deposited from Better Games Distributing Co., Inc. Horry County State Bank accounts which received direct and indirect illegal proceeds; $375.00 was deposited from Gainesville Internet Services, LLC Bank of America accounts which received direct and indirect illegal proceeds; $5,178.00 was deposited from Gulf Internet Services, LLC accounts which received direct and indirect illegal proceeds.
183
o $100.00 was deposited from Gulf Internet Services, LLC Bank of America account ending in from AVOTW Affiliates 47 and 85. o $5,078.00 was deposited from Gulf Internet Services, LLC unknown account. $375.00 was deposited from Lake City Internet Services, LLC Bank of America accounts which received direct and indirect illegal proceeds; $14,136.00 was deposited from Live Oak Internet Services, LLC accounts which received direct and indirect illegal proceeds. o $375.00 was deposited from Live Oak Internet Services, LLC Bank of America account ending in from AVOTW Affiliate 42. o $13,761.00 was deposited from Live Oak Internet Services, LLC unknown account. $10,000.00 (not included in the above figures) was electronically transferred from a Horry County State Bank account owned by Michael Graham. 563. As of February, 2012 this account had a balance of $17,375.73. Because this which received illegal proceeds which received illegal proceeds
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Hardee, Cary 564. Wachovia crown banking checking account# was opened on
or about December 25, 2010 in the name of Cary Hardee. Hardee is listed as the signor on
184
the account. The contact address for this account is listed as PO Box 2286, Tybee Island, GA 31328-2286. 565. Between December 25, 2010 and February 27, 2012, $1,986,322.94 was
deposited into this account, at least $1,403,028.64 of which appears to be proceeds of the gambling violations $215,931.69 was deposited from Two (2) Blue Waters Technologies Bank of America accounts ending in and which received illegal proceeds
directly or indirectly from AVOTW Affiliates 50, 58 and 60; $364,185.53 was deposited from Coastal Games Bank of America account ending in and 49. $383,500.00 was deposited from Coastal Games DBA Hot Spot Bank of America account ending in Affiliates 35, 36 and 49. $280,411.42 was deposited from Two (2) Grant Park Bank of America accounts ending in and which received illegal proceeds directly or indirectly , which received illegal proceeds from AVOTW which received illegal proceeds from AVOTW Affiliates 35, 36
from AVOTW Affiliate 31. $119,000.00 was deposited from Horry Technologies Bank of America account ending in which received illegal proceeds from AVOTW Affiliate 65.
$40,000.00 was deposited from MNL Investments, Inc Wachovia account ending in which received illegal proceeds directly or indirectly from but
not limited to Affiliates 34, 38, 43, 44, 55, 57, 63, 68, 71, and 81.
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566.
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Harrington, Joseph S & Harrington, Elaine M 567. Horry County State Bank, Money Markey Advantage Account #
was opened on March 20th, 2007 in the name of Joseph and Elaine Harrington. Joseph and Elaine Harrington are listed as the authorized signors on the account. The contact address for this account is listed as 867 Loop Cir. Longs, SC 29568. 568. Between January, 2011 and February, 2012, $693,844.81 was deposited into
this account, of which at least $533,528.70 appears to be proceeds of the gambling violations: $2,624.27 was deposited from Two (2) Better Games Distributing Co., Inc. Horry County State Bank accounts ending in and , which indirectly
received illegal proceeds from but not limited to AVOTW Affiliates 56 and 72. $252,361.30 was deposited from Gainesville Internet Services, LLC Bank of America accounts which received direct and indirect illegal proceeds. $9,731.04 was deposited from Gulf Internet Services, LLC Bank of America accounts which received direct and indirect illegal proceeds. $186,928.01 was deposited from Lake City Internet Services, LLC Bank of America accounts which received direct and indirect illegal proceeds. $81,884.08 was deposited from Live Oak Internet Services, LLC Bank of America accounts which received direct and indirect illegal proceeds.
186
569.
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Harrington, Joseph S & Harrington, Elaine M 570. Horry County State Bank, Easy Interest Checking Account # was
opened on March 20th, 2007 in the name of Joseph and Elaine Harrington. Joseph and Elaine Harrington are listed as the authorized signors on the account. The contact address for this account is listed as 867 Loop Cir. Longs, SC 29568. 571. Between January, 2011 and February, 2012, $140,477.04 was deposited into
this account, of which at least $41,688.11 appears to be proceeds of gambling violations: $1,500.00 was deposited from Better Games Distributing Co., Inc. Horry County State Bank account ending in , which indirectly received illegal
proceeds from but not limited to AVOTW Affiliates 56 and 72. $40,188.11 was deposited from Joseph and Elaine Harrington Horry County State Bank account ending in which indirectly received illegal proceeds
from but not limited to AVOTW Affiliates 56 and 72. 572. As of February, 2012 this account had a balance of $9,173.80. Because this
187
Lucas, Leonard Account 573. First Citizens Bank Relationship Checking account was opened
on April 9, 2002 in the name of Leonard D. Lucas. Leonard D. Lucas is the authorized signor for the account. The contact address for this account is 2190 Airport Road, Lancaster, SC 29720-3913. 574. Between December 4, 2010 and March 26, 2012, $729,145.98 was deposited
into this account, at least $398,501.53 which appears to be proceeds of the gambling violations: $171,001.53 was deposited from Coastal Games, LLC Bank of America account ending in 35, 36 and 49. $227,500.00 was deposited from Coastal Games LLC DBA Hot Spot Bank of America account ending in Affiliates 35, 36 and 49. 575. As March 5, 2012 this account had an ending balance of $702,106.93. Because which received illegal proceeds from AVOTW which received illegal proceeds from AVOTW Affiliates
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Medlin, Reginald 576. Bank of America account is an account in the name of
REGGIE PAUL MEDLIN POD MARION CHRISTOPHER MEDLIN with a contact address for this account of 3749 Ivy Green Trail, Tallahassee, Florida, 32311-3624.
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577.
Between April 2012 and January 2013, $33,566.78 was direct deposited into
this account from J & R Business Center BOA account, $2,855.64 was direct deposited into this account from Quincy Business Center BOA account, and $1,427.82 was direct deposited into this account from Business Center Unlimited BOA account. The aforementioned bank accounts receive illegal proceeds from gambling center locations previously described. 578. As of January 2013, this account has a balance of $122,566.87. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Medlin, Reginald 579. Bank of America account is an account in the name of
REGGIE PAUL MEDLIN POD MARION CHRISTOPHER MEDLIN with a contact address for this account of 3749 Ivy Green Trail, Tallahassee, Florida, 32311-3624. 580. Between April 2012 and January 2013, $32,138.96 was direct deposited into
this account from Business Center Unlimited BOA account and $33,566.78 was direct deposited into this account from Capital City Internet BOA account. The aforementioned bank accounts receive illegal proceeds from gambling center locations previously described. 581. As of January 2013, this account has a balance of $48,803.21. Because this
189
Parker, Anthony 582. Wells Fargo Crown Banking account was opened on August
10, 2007 in the name of Tony J. Parker. Tony J. Parker is the authorized signor for the account. The contact address for this account is 31 Sundunes Circle, Ponce Inlet, FL 321277053. 583. Between December 22, 2010 and December 20, 2011, $1,239,127.75 was
deposited into this account, at least $1,037,203.19 which appears to be proceeds of the gambling violations: $48,323.81 was deposited from two Blue Waters Technologies, LLC Bank of America accounts ending in and which directly or indirectly received
illegal proceeds from AVOTW Affiliates 50, 58 and 60. $291,957.13 was deposited from Coastal Games, LLC Bank of America account ending in and 49. $208,500.00 was deposited from Coastal Games LLC DBA Hot Spot Bank of America account ending in Affiliates 35, 36 and 49. $356,400.00 was deposited from Tony J. Parker Wells Fargo account ending in , which indirectly received illegal proceeds from AVOTW Affiliates 31, 35, 36, 49, 50, 58 and 60. $73,522.25 was deposited from two Grant Park, LLC Bank of America accounts ending in and which directly or indirectly received illegal proceeds , which received illegal proceeds from AVOTW which received illegal proceeds from Affiliates 35, 36
from AVOTW Affiliate 31.
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$58,500.00 was deposited from Horry Technologies, LLC Bank of America account ending in 65. , which received illegal proceeds from AVOTW Affiliate
584.
As of December 20, 2011 this account had an ending balance of $31,843.73.
Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Parker, Anthony 585. Wells Fargo Preferred Rate Savings account was opened on
or about February 11, 2008 in the name of Tony J. Parker. Tony J. Parker is the authorized signor for the account. The contact address for this account is 31 Sundunes Circle, Ponce Inlet, FL 32127-7053. 586. Between February 11, 2008 and December 20, 2011, $1,087,721.27 was
deposited into this account, at least $854,562.52 which appears to be proceeds of the gambling violations: $176,834.92 was deposited from two Blue Waters Technologies, LLC Bank of America accounts ending in and which directly or indirectly received
illegal proceeds from AVOTW Affiliates 50, 58 and 60. $123,000.00 was deposited from Coastal Games, LLC Bank of America account ending in 35, 36 and 49. which received illegal proceeds from AVOTW Affiliates
191
$152,252.60 was deposited from two Grant Park, LLC Bank of America accounts ending in and which directly or indirectly received illegal
proceeds from AVOTW Affiliate 31. $402,475.00 was deposited from Tony J. Parker Wells Fargo account ending in , which indirectly received illegal proceeds from AVOTW Affiliates 31, 35, 36, 49, 50, 58, 60 and 65. 587. As of December 20, 2011 this account had an ending balance of $81,860.28.
Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Prince, Bennie & Peggy 588. Bank of America regular checking account# was opened on or
about December 21, 2010 in the name of Bennie J Prince, Peggy A Prince ITF Cynthia Weaver, ITF Lori Barnett. This account was opened at the Debary Banking Center in The
Debary, Florida. Bennie & Peggy Prince are listed as the signors on the account. contact address for this account is 809 Riviera Bella Drive, Debary, FL 32713-5434. 589.
into this account, at least $229,318.00 of which appears to be proceeds of the gambling violations $49,500.00 was deposited from B.B.S. Management Group Bank of America account ending in 61. , which received illegal proceeds from AVOTW Affiliate
192
$179,818.00 was deposited from INH Management Co Bank of America account ending in 32. which received illegal proceeds from AVOTW Affiliate
590.
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Prince, Bennie & Peggy 591. Bank of America money market savings account# was opened
on December 29, 2011 in the name of Peggy A Prince, Bennie J Prince ITF Cynthia Weaver, ITF Lori Barnett. Bennie & Peggy Prince are listed as the signors on the account. The contact address for this account is 809 Riviera Bella Dr, Debary, FL 32713-5434. 592. Between December 29, 2011 and March 16, 2012, $250,000.00 was deposited
into this account, at least $250,000.00 of which appears to be proceeds of the gambling violations and $215.93 of interest accrued: $250,000.00 was deposited from Bennie & Peggy Princes Bank of America account ending in Affiliates 32 and 61. 593. $215.93 of interest accrued from deposit. As of March 16, 2012 this account had a balance of $250,215.93. Because this , which indirectly received illegal proceeds from AVOTW
193
Rokh, Changiz & Haghighi, Maryam B. 594. SunTrust Bank regular checking account # was opened on
October 23, 2008 in the name of Changiz Rokh or Maryam B. Haghighi. Rokh and Haghighi are listed as the signors on the account. The contact address for this account is listed as Rokh and Haghighis residence, 96 Rosehill Cresent Ct, Debary, FL 32713. 595. Between December 30, 2010 and February 7, 2012, $650,006.72 was
deposited into this account, at least $168,507.00 of which appears to be proceeds of the gambling violations: $164,797.00 was deposited from B.B.S. Management Group, Inc Bank of America account ending in Affiliate 61. $3,710.00 was deposited from Cynthia Weaver & Bennie Prince Bank of America account ending in which indirectly received illegal proceeds from , which received illegal proceeds from AVOTW
AVOTW Affiliates 32, 41, 54, 61 and 78. 596. As of April 7, 2012 this account had a balance of $30,896.52. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Rokh, Changiz & Haghighi, Maryam B. 597. Fifth Third Account savings account was opened on August 4,
2011 in the name of Changiz Rokh or Maryam B. Haghighi. Rokh and Haghighi are listed as the signor on the account. The contact address for this account is listed as Rokh and
Haghighis residence, 96 Rosehill Cresent Ct, Debary, FL 32713.
194
598.
Between August 5, 2011 and February 27, 2012, $248,452.97 was deposited
into this account, at least $197,876.00 of which appears to be proceeds of the gambling violations: $25,160.00 was deposited from B.B.S. Management Group, Inc Bank of America account ending in Affiliate 61. $170,000.00 was deposited from a Changiz Rokh SunTrust account ending in 8039, which indirectly received illegal proceeds from AVOTW Affiliate 61. $2,716.00 was deposited from Cynthia Weaver & Bennie Prince Bank of America account ending in which indirectly received illegal proceeds from , which received illegal proceeds from AVOTW
AVOTW Affiliates 32, 41, 54, 61 and 78. 599. As of February 27, 2012 this account had a balance of $222,173.98. Because
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Rokh, Changiz &Haghighi, Maryam B. 600. SunTrust regular checking account was opened on Rokh and
November 20, 2008 in the name of Changiz Rokh or Maryam B. Haghighi.
Haghighi are listed as the signors on the account. The contact address for this account is listed as Rokh and Haghighis residence, 96 Rosehill Cresent Ct, Debary, FL 32713. 601. Between December 30, 2010 and February 27, 2012, $165,648.63 was
deposited into this account, at least $51,657.00 of which appears to be proceeds of the gambling violations:
195
$48,960.00 was deposited from B.B.S. Management Group, Inc Bank of America account ending in Affiliate 61. which received illegal proceeds from AVOTW
$1,653.00 was deposited from Cynthia Weaver & Bennie Prince Bank of America account ending in Affiliates 32, 41, 54, 61 and 78. which indirectly received illegal proceeds from
$1,044.00 was deposited from Bennie Prince Bank of America account ending in and 61. which indirectly received illegal proceeds from AVOTW Affiliates 32
602.
this account received deposits of gambling proceeds the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Rowe, Conrad H 603. Bank of America Regular checking account# was opened on
December 1, 2003 in the name of Conrad H Rowe. The account was opened in the North Jacksonville Banking Center in Jacksonville, FL. Conrad Rowe is listed as the signor/owner on the account. The contact address for this account is listed as 8513 Gracious Pine Ave., Las Vegas, NV 89143-4609. 604. Between December 15, 2010 and March 13, 2012, $220,419.79 was deposited
into this account, at least $25,200.00 of which appears to be proceeds of the gambling violations:
196
$25,200.00 was deposited from Bearcon Management, LLCs Bank of America account ending in Affiliate 37. , which indirectly received illegal proceeds from AVOTW
605.
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as the proceeds of gambling violations pursuant to F.S. 895.05(3) and F.S. 932.702. Rubino, Richard 606. Bank of America adv. tiered interest checking account# was
opened since at least June 10, 2009 in the name of Richard J Rubino ITF Patricia A Rubino. This account was opened at the Four Towns Banking Center in Orange City, Florida. Richard Rubino is listed as the signor on the account. The contact address for this account is listed as Rubinos residence, 1534 Grace Lake Cir, Longwood, FL 32750-2836. 607. Between December 28, 2010 and March 26, 2012, $775,063.90 was deposited
into this account, at least $692,868.63 of which appears to be proceeds of the gambling violations: $175,218.63 was deposited from Richard Rubino Bank of America account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 66, 67, 74 and 77. $517,650.00 was deposited from Digitrac, Inc Bank of America account ending in 77. which received illegal proceeds from AVOTW Affiliates 66, 67, 74 and
197
608.
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Rubino, Richard 609. Wells Fargo essential checking account# was opened on or Richard
about January 22, 2011 in the name of Patricia Ann Rubino, Richard Rubino.
Rubino and Patricia Ann Rubino (McDowell) are listed as the signors on the account. The contact address for this account is listed as Rubinos residence, 1534 Grace Lake Cir, Longwood, FL 32750-2836. 610. Between January 22, 2011 and February 29, 2012, $196,768.43 was deposited
into this account, at least $181,280.43 of which appears to be proceeds of the gambling violations: $38,016.43 was deposited from Richard Rubino Bank of America account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 66, 67, 74 and 77. $143,264.00 was deposited from Digitrac, Inc Bank of America account ending in 77. 611. As of February 29, 2012 this account had a balance of $4,453.07. Because which received illegal proceeds from AVOTW Affiliates 66, 67, 74 and
198
Rubino, Richard 612. Wells Fargo essential checking account# was opened on or
about December 21, 2010 in the name of Richard Rubino, Patricia Ann Rubino. Richard Rubino and Patricia Ann Rubino (McDowell) are listed as the signors on the account. The contact address for this account is listed as Rubinos residence, 1534 Grace Lake Cir, Longwood, FL 32750-2836. 613. Between December 21, 2010 and February 29, 2012, $18,140.09 was
deposited into this account, at least $8,404.65 of which appears to be proceeds of the gambling violations: $8,404.65 was deposited from Richard Rubino Bank of America account ending in which indirectly received illegal proceeds from AVOTW Affiliates 66,
67, 74 and 77. 614. As of February 29, 2012 this account had a balance of $26,403.31. Because
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Ryles, Michael & Ryles, Janis 615. Bank of America Platinum Money Market Savings account#
was opened on January 9, 2012 in the name of Janis S Ryles. Janis S Ryles is listed as the signor/owner on the account; however, Michael W Ryles name appears on the monthly statements as well as Janis R Ryles name. The contact address for this account is listed as 302 Haynsworth St., Sumter, SC 29150-4006. The account appeared to have been opened at the Bank of America Broad Street Banking Center located in South Carolina.
199
616.
Between January 9, 2012 and March 7, 2012, $10,001.05 was deposited into
this account, at least $10,000.00 of which appears to be proceeds of the gambling violations: $10,000.00 was electronically transferred and/or deposited from Michael Ryles Bank of America account ending in which received illegal proceeds
indirectly from but not limited to AVOTW Affiliates 34, 37, 43, 44, 57, 68, 71, and 81. 617. The remaining $1.05 was deposited from interest accrued. As of March 7, 2012 this account had a balance of $9,000.88. Because this
account received deposits of in gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Ryles, Michael & Ryles, Janis 618. Bank of America Interest Checking account# has been opened
on or about August 4, 2010, in the name of Michael W. Ryles, Janis S. Ryles. Michael W. Ryles and Janis S Ryles are listed as the signors/owners on the account. The account appeared to have been opened at the University Pointe banking branch center in Jacksonville, FL. The contact address for this account is listed as 1103 Cedar Bay Road, Jacksonville, FL 32218-4938. The previous contact address for this account was 1355 Clearview Drive, Manning, SC 29102-8438. 619. Between December 11, 2010 and March 9, 2012, $3,644,349.57 was deposited
into this account, at least $2,983,910.45 of which appears to be proceeds of the gambling violations:
200
$2,491,360.45 was deposited from Seaside Internet, LLCs Bank of America account ending in 34, 43, 44, 57, and 68. which received illegal proceeds from AVOTW Affiliates
$456,600.00 was deposited from Free Entry Clay County, LLCs Bank of America account ending in Affiliate 71. , which received illegal proceeds from AVOTW
$35,225.00 was deposited from Seaside Internet-Putnam, LLCs Bank of America account ending in Affiliate 81. , which received illegal proceeds from AVOTW
$725.00 was deposited from Bearcon Management, LLCs Bank of America account ending in 37. , which received illegal proceeds from AVOTW Affiliate
620.
As of March 9, 2012 this account had a balance of $655,756.16. Between April 2012 and January 2013, $1,530,160.00 was deposited into this that receives funds directly
account from the Seaside Internet BOA account ending in from gambling centers.
Because this account received deposits of gambling proceeds, the
funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Ryles, Michael 621. Edward Jones account was opened on March 18, 2008 in the
name of Michael Ryles. Michael Ryles is listed as the owner on the account. It is unknown at this time where and/or which Banking Branch location the account was opened. The current contact address for this account is listed as 1103 Cedar Bay, FL 32259-4409.
201
622.
Between January 2011 and March 30, 2012, $387,972.26 was deposited into
this account from cash, insured bank deposits, money market funds, stocks, and bonds; of which at least $250,271.45 appears to be proceeds of the gambling violations, and was deposited into the account between the March 11, 2011 and October 31, 2011 time period: $250,271.45 was deposited from Michael Ryles Bank of America bank account ending in which indirectly received illegal proceeds from but not limited to
AVOTW Affiliates 34, 37, 43, 44, 57, 68, 71, and 81. 623. As of March 30, 2012 this account had a current value of $299,066.46.
Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Ryles, Michael 624. Edward D Jones & Co Custodian MJM Enterprises FBO Michael Ryles SEPwas opened on December 28, 2009 in the name of MJM Michael Ryles is listed as the Account Holder on the
IRA account #
Enterprises and Michael Ryles.
account, and Janis Ryles as the Primary Beneficiary. The current contact address for this account is listed as 1355 Clearview Drive, Manning, SC 29102-8438. 625. Between January 2011 and March 30, 2012, $99,187.39 was deposited and/or
earned on the account from cash, insured bank deposits, money market funds, and mutual funds; of which at least $54,137.60 appears to be proceeds of the gambling and was deposited into the account on or about December 28, 2011.
202
$54,137.60 was deposited from MJ Enterprises, LLCs Bank of America account ending in which indirectly received illegal proceeds from but not
limited to AVOTW Affiliates 34, 43, 44. 626. As of March 30, 2012 this account had a current value of $217,178.40.
Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Ryles, Michael 627. Wells Fargo High Yield Savings account# was opened on April
1, 2011 in the name of Michael W. Ryles and Janis S Ryles aka Janis S Jayroe. It should be noted that Wells Fargo was previously Wachovia Bank, and said account was documented previously as an Enhanced Rate Savings account with Wachovia Bank. Bank records indicated that as of June 8, 2011, the account was changed to a Wells Fargo Bank High Yield Savings account. Michael W Ryles is listed as the signor/owner on the account, along with Janis S Ryles. The contact address for this account is listed as 1103 Cedar Bay Rd., Jacksonville, FL 32218-4938. It is unknown at this time where and/or what banking branch location the account was opened. 628. Between April 2011 and February 7, 2012, $308,897.67 was deposited into this
account, at least $308,261.00 of which appears to be proceeds of the gambling violations and $636.67 from interest accrued: $58,261.00 was deposited from MNL Investments, Wachovia Bank account ending in which received illegal proceeds from but not limited to AVOTW
Affiliates 34, 38, 43, 44, 55, 57, 68, 71 and 81.
203
$250,000.00 was deposited from Michael Ryles Bank of America account ending in which indirectly received illegal proceeds from but not limited to
AVOTW Affiliates 34, 37, 43, 44, 57, 68, 71, and 81. 629. The remaining $636.67 was interest accrued from these deposits. As of February 7, 2012 this account had a balance of $308,897.67. Because
this account received deposits of at least $100,000.00 in gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Ryles, Michael 630. Bank of Clarendon Platinum checking account# was opened on
August 3, 2006 in the name of Michael W. Ryles and Janis S Ryles in Manning, South Carolina. Michael W Ryles is listed as the signor/owner on the account, along with Janis S Ryles. The contact address for this account is listed as 1355 Clearview Drive, Manning, SC 29102-8438. 631. Between August 3, 2006 and February 13, 2012, $720,901.21 was deposited
into this account, at least $574,039.26 of which appears to be proceeds of the gambling violations: $639.86 was deposited from B&M Leasing & Management Bank of America account ending in 44. $17,000.00 was deposited from Janis & Michael Ryles Safe Federal Credit Union account ending in which indirectly received illegal proceeds from which received illegal proceeds from AVOTW Affiliate
AVOTW Affiliates 34, 43, and 44.
204
AVOTW Affiliates 34, 37, 43, 44, 57, 68, 71, and 81. $58,000.00 was deposited from Seaside Internet, LLCs Bank of America account ending in , which received illegal proceeds directly from AVOTW
Affiliates 34, 43, and 68. $36,756.54 was deposited from MJ Enterprises, LLCs Bank of America account ending in which indirectly received illegal proceeds from but not
limited to AVOTW Affiliates 34, 43, 44. $29,143.00 was deposited from MNL Investments, LLCs Wells Fargo Bank account ending in that received illegal proceeds indirectly from but not
limited to AVOTW Affiliates 34, 38, 43, 44, 55, 57, 68, 71, and 81. 632. As of February 13, 2012 this account had a balance of $236,044.79. Because
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Ryles, Michael 633. Safe Federal Credit Union Account Prime Share was opened
on September 22, 2008 in the name of Michael W. Ryles and Janis S Ryles. Janis S Jayroe is listed as the account owner of the account with a member number of and Michael
W Ryles is listed as a joint owner. The contact address listed for Janis S Jayroe is PO Box 352, Manning, SC 29102, and for Michael W Ryles is 1355 Clearview Drive, Manning, SC
205
29102. It is unknown at this time where and/or which banking branch location account was opened at. 634. Between September 2008 and January 31, 2012, $256,247.40 was deposited
into this account, of which at least $115,652.15 appears to be proceeds of the gambling violations: $100,000.00 deposited from Michael Ryles Bank of America account ending in which indirectly received illegal proceeds from but not limited to AVOTW Affiliates 34, 43, and 44. $15,652.15 deposited from MJ Enterprises Bank of America account ending in which indirectly received illegal proceeds from but not limited to AVOTW Affiliates 34, 43, 44. 635. As of January 31, 2012 this account had a balance of $190,394.49. Because
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Ryles, Michael W 636. Wells Fargo Crown Bank checking account# was opened from
at least July 7, 2010 in the name of Michael W. Ryles. Exact opened date is unknown at this time. According to bank records, it appeared that Janis S Ryles aka Janis Jayroe was added to the account on or about April 1, 2011. The current contact address for this account is
listed as 1103 Cedar Bay Rd., Jacksonville, FL 32218. It should be noted that Wells Fargo was previously known as Wachovia Bank. It is unknown at this time where and/or which banking branch location account number was opened at.
206
637.
Between December 7, 2010 and February 7, 2012, $234,012.00 was deposited
into this account, at least $156,000.00 of which appears to be proceeds of the gambling violations: $150,000.00 was deposited from Michael Ryles Bank of America account ending in which indirectly received illegal proceeds from but not limited to
AVOTW Affiliates 34, 37, 44, 57, 68, 71, and 81. $6,000.00 was deposited from Jerry Bass DBA Bass Consulting & e-Bay Sales Southeastern Bank account ending in proceeds from AVOTW Affiliates. 638. As of February 7, 2012 this account had a balance of $34,075.79. Because this which indirectly received illegal
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Ryles, Michael 639. Safe Federal Credit Union checking account was
opened on September 22, 2008 in the name of Michael W Ryles and Janis S Jayroe. Janis S Jayroe is listed as the account owner of the account with a member number of and Michael W Ryles is listed as a joint owner. The contact address for Janis S Jayroe is listed as PO Box 352, Manning, SC 29102, and is listed for Michael W Ryles as 1355 Clearview Drive, Manning, SC 29102. It is unknown at this time where and/or which banking branch location was opened at. 640. Between September 2008 and January 31, 2012, $34,734.58 was deposited
into this account, of which at least $30,000.00 was deposited from Michael W Ryles and Janis
207
S Jayroes Safe Federal Credit Union account Suffix 0.
An analysis of Safe Federal Credit
Union account Suffix 0 revealed that it had indirectly received illegal proceeds from AVOTW Affiliates 34, 43, and 44. 641. As of January 31, 2012 this account had a balance of $5,230.73. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Salloum, Mazen 642. Wells Fargo Crown Banking checking account# was opened
on December 5, 2006 in the name of Mazen Salloum. Mazen Salloum is listed as the signor/owner on the account. The contact address for this account is listed as 4599 Ecton Lane E., Jacksonville, FL 32246-1892. It should be noted that this account was previously a Wachovia Bank account number, which was transferred to Wells Fargo Bank on or about June 11, 2011. It is unknown at this time where and/or what banking branch location account was opened at. 643. Between December 11, 2010 and February 13, 2012, $229,098.55 was
deposited into this account, at least $143,973.70 of which appears to be proceeds of the gambling violations: $73,500.00 was deposited from M&S Management Services, LLC Bank of America account ending in Affiliate 38. , which received illegal proceeds from AVOTW
208
$21,000.00 was deposited from Tamara L Gross DBA Goodtimes Caf, LLC Bank of America account ending in AVOTW Affiliate 38. which received illegal proceeds from
$13,354.66 was deposited from Free Entry Clay County Bank of America account ending in 71. which received illegal proceeds from AVOTW Affiliate
$10,000.00 was deposited from MNL Investments SunTrust account ending in , which indirectly received illegal proceeds from AVOTW Affiliates 38, 71, 34, 43, 44, 57, and 68.
$10,000.00 was deposited from MNL Investments Wachovia account ending in which received illegal proceeds directly or indirectly from but not limited to Affiliates 34, 38, 43, 44, 55, 57, 63, 68, 71, and 81.
$6,000.00 was deposited from Michael Ryles Wachovia account ending in which indirectly received illegal proceeds from but not limited to AVOTW Affiliates 34, 37, 44, 57, 68, 71, and 81.
AVOTW Affiliates 34, 37, 43, 44, 57, 68, 71, and 81. $2,000.00 was deposited from Bearcon Management, LLC Bank of America account ending in , which received illegal proceeds from Affiliate 37.
$1,500.00 was deposited from Seaside Internet-Marion Bank of America account ending in 63. , which received illegal proceeds from AVOTW Affiliate
209
$1,300.00 was deposited from Michael Davis Wachovia account ending in which indirectly received illegal proceeds AVOTW Affiliates 49, 40, 46 and 68.
$319.04 was deposited from B&M Leasing & Management Bank of America account ending in 44. which received illegal proceeds from AVOTW Affiliate
644.
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Salloum, Zaher and Nancy B 645. Bank of America Money Market Savings account # has been
opened since or from at least March 5, 2010 in the name of Zaher Salloum and Nancy B Salloum. Both are listed as the signors/owners on the account. The account was opened at the Julington Creek Branch location center, located in Jacksonville, FL. The current contact address for this account is listed as 304 Sweetbrier Branch Lane, Jacksonville, FL 322594409. The account had a previous contact address of 1124 Ashmore Drive, Jacksonville, FL 32259-8983. 646. Between December 18, 2010 and March 16, 2012, $102,341.78 was deposited
into this account, at least $59,000.00 of which appears to be proceeds of the gambling violations:
210
$32,000.00 was deposited from Tamara L Gross DBA Goodtimes Caf, LLC Bank of America account ending in AVOTW Affiliate 38. which received illegal proceeds from
$20,000.00 was deposited from MNL Investments, Inc. SunTrust Bank account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 38, 71, 34, 43, 44, 57, and 68. $7,000.00 was deposited from M&S Management Services, LLCs Bank of America account ending in Affiliate 38. 647. As of March 16, 2012 this account had a balance of $15,519.32. Because this which received illegal proceeds from AVOTW
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Salloum, Zaher & Nancy B 648. SunTrust Premium Money Market account # was opened on
December 5, 2006 in the name of Zaher Salloum. On May 9, 2008, Nancy B. Salloum was added to the account as a signor. The contact address for this account is listed as 1124 Ashmore Dr., Jacksonville, FL 32259-8983. It is unknown at this time where and/or what banking branch location account was opened at. 649. Between January 2011 and February 7, 2012, $389,140.98 was deposited into
this account, at least $319,000.00 of which appears to be proceeds of the gambling violations:
211
$22,500.00 was deposited from Tamara L Gross DBA Goodtime Caf, LLCs Bank of America account ending in AVOTW Affiliate 38. which received illegal proceeds from
$156,500.00 was deposited from M&S Management Services, Inc. Bank of America account ending in Affiliate 38. , which received illegal proceeds from AVOTW
$140,000.00 was deposited from Zaher & Nancy Salloum Bank of America account ending in , which indirectly received illegal proceeds from AVOTW
Affiliates 38, 71, 34, 43, 44, 57, and 68. 650. As of February 7, 2012 this account had a balance of $66,184.61. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Saloum, Salim & Gross, Tamara 651. Vystar regular checking account# records indicated that on or about
November 5, 2001 Salim Saloum was added as a joint account member, which entitled him to full services of the credit union and made the account a joint account with right of survivorship. According to Vystars Record Processor Trista Williams the account had been opened prior to November 5, 2001, with Tamara L Gross as the sole signor, however due to subpoena request limitations the specific opening date of the account was not provided at this time. The contact address for this account is listed as 3670 Reedpond Drive, Jacksonville, FL 32223-4812. It is unknown at this time where and/or which banking center location account was opened at.
212
652.
Between January 2011 and February 29, 2012, $92,175.02 was deposited into
this account, at least $29,000.00 of which appears to be proceeds of the gambling violations.
$8,000.00 was deposited from M&S Management Services, Incs Bank of

America account ending in Affiliate 38. hat received illegal proceeds from AVOTW
$11,000.00 was deposited from Tamara L Gross DBA Goodtimes Caf Bank of
America account ending in Affiliate 38. , which received illegal proceeds from AVOTW
$10,000.00 was deposited from MNL Investments SunTrust account ending in

, which indirectly received illegal proceeds from AVOTW Affiliates 38, 71, 34, 43, 44, 57, and 68. 653. As of February 29, 2012 this account had a balance of $22,919.65. Because
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Saloum, Samer 654. Everbank Yield Pledge Checking Account# bank records received
for the period of December 31, 2010 through February 29, 2012 indicate Samer G. Saloum as the owner of the account. Bank records for said time period also indicate 10411 Scott Mill Rd., Jacksonville, FL 32257 as the contact address on the account. It is unknown at this time the open date of the account, and/or which banking branch location account was opened at.
213
655.
Between December 31, 2010 and February 29, 2012, $493,730.15 was
deposited into this account, at least $257,004.27 of which appears to be proceeds of the gambling. $157,375.86 was deposited from M&S Management Services, Inc Bank of America account ending in Affiliate 38. $34,528.41 was deposited from Tamara L Gross DBA Goodtimes Caf Bank of America account ending in Affiliate 38. $30,000.00 was deposited from Zaher and Nancy Salloum SunTrust Bank account ending in Affiliate 38. $10,000.00 was deposited from B&M Leasing and Management, LLC Bank of America account ending in Affiliate 44. $10,000.00 was deposited from MNL Investments, Inc. SunTrust Bank account ending in which indirectly received illegal proceeds from AVOTW , which received illegal proceeds from AVOTW , which indirectly received illegal proceeds from AVOTW , which received illegal proceeds from AVOTW , which received illegal proceeds from AVOTW
Affiliates 38, 71, 34, 43, 44, 57, and 68. $8,600.00 was deposited from Seaside Internet, LLC Bank of America account ending in and 68. , which received illegal proceeds from AVOTW Affiliates 34, 43,
214
$6,500.00 was deposited from B&M Leasing and Management St Augustine Store # 55 Bank of America account ending in proceeds from AVOTW Affiliate 55. , which received illegal
656.
this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. 657. It should be further noted that a total of $160,000.00 was withdrawn from this
account and appeared to have been deposited into a Wells Fargo account number during the 2011 time period. The funds in this Wells Fargo account number ending in are also subject to forfeiture as proceeds of the gambling violations,
pursuant to F.S. 895.05(3) and F.S. 932.702. The owner as well as the open date of said account is unknown at this time. Saloum, Samer 658. Everbank Yield Pledge Money Market Account# bank records
received for the period of December 31, 2010 through February 29, 2012 indicate Samer G. Saloum as the owner of the account. Bank records for said time period also indicate 10411 Scott Mill Rd., Jacksonville, FL 32257 as the contact address on the account. It is unknown at this time the open date of the account, and/or which banking branch location account was opened at. 659. Between December 31, 2010 and February 29, 2012, $70,614.09 was
deposited into this account, at least $69,725.00 of which appears to be proceeds of the gambling.
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$69,725.00 was deposited from Samer Saloums Everbank account ending in , which indirectly received illegal proceeds from AVOTW Affiliates 34, 38, 43, 44, 55, 57, 68, and 71.
660.
this account received deposits of at least $69,725.00 in gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Skidmore, Bradley & Skidmore, Tracey 661. Crescent Bank High Interest Checking Account # was opened on
January 7, 2011 in the name of Brad D Skidmore, Tracey B Skidmore, and Rebecca Stevens. All three are listed as account owners. The account appeared to have been opened in South Carolina. The contact address for this account is listed as 817 Tillson Rd., N. Myrtle Beach, SC 29582. 662. Between December 21, 2010 and February 17, 2012, $1,466,810.67 was
deposited into this account, at least $1,374,170.76 of which appears to be proceeds of the gambling violations. (It should be noted that an additional $54,748.75 was electronically transferred and/or deposited from an unknown Seaside Technologies, Inc. account): $1,048,900.00 was deposited from Seaside Internet, LLCs Bank of America account ending in 34, 43, 44, 57, and 68. $274,100.00 was deposited from Free Entry Clay County, LLCs Bank of America account ending in Affiliate 71. which received illegal proceeds from AVOTW which received illegal proceeds from AVOTW Affiliates
216
$30,817.48 was deposited from Seaside Gaming, LLCs Crescent Bank account ending in , which indirectly received illegal proceeds from but not
limited to AVOTW Affiliates 34, 44, 57, 68, and 71. $20,353.28 was deposited from Seaside Technologies Crescent Bank account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 34, 43, 44, 57, and 68. 663. As of February 17, 2012 this account had a balance of $910,813.28. Between April 2012 and January 2013, $1,191,660.00 was deposited into this that receives funds directly from
gambling centers. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Skidmore, Bradley & Skidmore, Tracey 664. Bank of America Interest checking account# was opened from
at least March 12, 2003 in the name of Bradley D Skidmore. The account was opened at the Walzem/Windcrest Banking branch location, located in San Antonio, TX. On or about January 28, 2011, Tracey B Skidmore was added to the account as a joint member with right of survivorship. The current contact address for this account is listed as 231 Koolabrew Drive NW, Calabash, NC 28467-1937. It should be noted that at one point Rebecca Stevens also appeared to have been a signor on the account, her name however was removed from the account as of January 26, 2011. Also the account appeared to have had a previous contact address, 817 Tillson Rd., North Myrtle Beach, SC 29582-2847, which was changed on or about January 26, 2011 to the current contact address.
217
665.
into this account, at least $324,846.30 of which appears to be proceeds of the gambling violations: $135,000.00 was deposited from Free Entry Clay County, LLCs Bank of America account ending in Affiliate 71. $36,000.00 was deposited from Michael Janis Ryles Bank of America account ending in , which indirectly received illegal proceeds from but not limited to , which received illegal proceeds from AVOTW
AVOTW Affiliates 34, 37, 43, 44, 57, 68, 71, and 81. $29,446.30 was deposited from Seaside Gaming, Inc. Bank of America account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 34, 43, 44, 57, 63, 68, and 81. $24,500.00 was deposited from Seaside Internet-Putnam, LLC Bank of America account ending in Affiliate 81. $83,200.00 was deposited from Seaside Internet, LLC Bank of America account ending in 34, 43, 44, 57, and 68. $6,000.00 was deposited from MNL Investments, Inc Wachovia account ending in which received illegal proceeds directly or indirectly from but not which received illegal proceeds from AVOTW Affiliates , which received illegal proceeds from AVOTW
limited to Affiliates 34, 38, 43, 44, 55, 57, 63, 68, 71, and 81.
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$6,000.00 was deposited from B&M Leasing and Management, LLC Bank of America account ending in Affiliate 44. , which received illegal proceeds from AVOTW
$4,700.00 was deposited from B&M Leasing and Management, LLC ATM Account Bank of America ending in proceeds from AVOTW Affiliate 44. which indirectly received illegal
666.
As of March 26, 2012 this account had an ending balance of $675,450.88. Between April 2012 and January 2013, $5,000.00 was deposited into this that receives funds directly from
gambling centers. Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Skidmore, Brad 667. BB&T account # Your affiant has not received bank records as
of the time of the submission of this affidavit, therefore, the account signor is unknown. 668. Between April 2012 and January 2013, Brad Skidmore received seventeen (17)
checks totaling $363,900.00 written from Seaside Internet, LLC BOA account ending in previously described. The proceeds were then deposited into BB&T bank account
Because this account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702.
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Waheed, Aamir 669. Bank of America interest checking account# was opened since
at least December 7, 2006 in the name of Aamir Waheed, Cheri S Black. This account was opened at the Debary Banking Center located in Debary, Florida. Aamir Waheed and Cheri S Black are listed as the signors on the account. The contact address for this account is listed as Waheed & Blacks residence, 11120 Bridge House Rd, Windermere, FL 34786-5404. 670. Between January 7, 2008 and January 24, 2012, a total of approximately
$17,490,997.96 was deposited into this which appears to be proceeds of the gambling violations: $5,623,859.40 was deposited from Digitrac, Inc. Bank of America account ending in 74 and 77. $3,818,084.56 was deposited from Game Advice, Inc. Bank of America account ending in 54. $1,792,533.75 was deposited from Infovice, Inc. Bank of America account ending in which received illegal proceeds from AVOTW Affiliate 59. which received illegal proceeds from AVOTW Affiliates 41 and which received illegal proceeds from AVOTW Affiliates 66, 67,
$374,244.50 was deposited from Intelitek Bank of America account ending in which received illegal proceeds from AVOTW Affiliate 51.
$5,882,275.75 was deposited from Media Advice Bank of America account ending in which received illegal proceeds from AVOTW Affiliate 78.
671.
As of January 6, 2012 this account had a balance of $1,284,041.67. Because
this account received deposits of gambling proceeds, the funds in this account are subject to
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forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Waheed, Aamir & Black (Waheed), Cheri 672. Fifth Third Bank Relationship Savings account was opened since
at least October 31, 2008 in the name of Aamir Waheed or Cheri S Black. Aamir Waheed and Cheri S. Black are listed as the signors on the account. The contact address for this account is 11120 Bridge House Road, Windermere, FL 34786-5404. 673. Between October 31, 2008 and September 28, 2011, a total of $458,004.59
was deposited into this account, at least $352,000.00 of which appears to be proceeds of the gambling violations: $200,000.00 was deposited from Aamir Waheeds Bank of America account ending in which indirectly received illegal proceeds from Affiliates 41, 51,
54, 59, 66, 67, 74 and 78. $142,000.00 was deposited from Intelitek Bank of America account that received illegal proceeds from Affiliate 51. $10,000.00 was deposited from Infovice, Inc. Bank of America account that received illegal proceeds from Affiliate 59. 674. As of September 28, 2011 this account had a balance of $13,265.88. Because
221
Waheed, Tariq & Sadia 675. Bank of America Business Regular Checking account was
opened since at least January 18, 2006 in the name of Tariq Waheed, Sadia Waheed. This account was opened at the Four Corners Banking Center in Clermont, Florida. Tariq and Sadia Waheed are listed as the signors on the account. The contact address for this account is listed as 15348 Harvest Blvd, Clermont, FL 34714-6183. 676. Between January 6, 2011 and March 1, 2012, a total of $1,684,442.09 was
deposited into this account. Of this amount, $1,579,916.50 appears to be proceeds of the gambling violations: $1,275,145.75 was deposited from Digitrac, Inc. Bank of America account ending in 74 and 77. $304,770.75 was deposited from Infovice, Inc Bank of America account ending in 677. which received illegal proceeds from AVOTW Affiliate 59. which received illegal proceeds from AVOTW Affiliates 66, 67,
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Waheed, Tariq 678. Regions Lifegreen Preferred Checking Private Banking account
was opened on May 13, 1999 in the name of Tariq Waheed. This account was opened at the branch in Casselberry, Florida. Tariq Waheed is listed as the signor on the account. The contact address for this account is listed as 15348 Harvest Blvd, Clermont, FL 34714-6183.
222
679.
Between December 28, 2010 and March 26, 2012, a total of $106,355.15 was
deposited into this account. Of this amount, $10,100.00 appears to be proceeds of the gambling violations: $10,100.00 was deposited from Tariq and Sadia Waheed Bank of America account ending in which indirectly received illegal proceeds from
Affiliates 59, 66, 67, 74 and 77. 680. As of March 26, 2012 this account had a balance of $3,325.08. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Weaver, Brandon 681. Bank of America interest checking account# was opened since
at least September 30, 2009 in the name of Brandon S Weaver ITF Hannah Weaver and Isabella Weaver. This account was opened at the Debary Banking Center in Debary, Florida. Brandon Weaver is listed as the signor on the account. The contact address for this account is listed as Weavers residence, 809 Riviera Bella Dr, Debary, FL 32713-5434. 682. Between December 24, 2010 and March 22, 2012, $350,640.73 was deposited
into this account, at least $319,523.14 of which appears to be proceeds of the gambling violations: $31,000.00 was deposited from a cashiers check from Bennie Prince Bank of America account ending in AVOTW Affiliates 32 and 61. which indirectly received illegal proceeds from
223
$288,523.14 was deposited from Cynthia Weaver & Bennie Prince Bank of America account ending in which indirectly received illegal proceeds from
AVOTW Affiliates 32, 41, 54, 61 and 78. 683. As of March 22, 2012 this account had a balance of $3,888.27. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Weaver, Cynthia & Prince, Bennie 684. Bank of America interest checking account# was opened since
at least September 30, 2009 in the name of Cynthia Weaver, Bennie J Prince ITF Hannah Weaver and Isabella Weaver. This account was opened at the Debary Banking Center in Debary, Florida. Cynthia Weaver and Bennie J Prince are listed as the signors on the account. The contact address for this account is listed as Weavers residence, 809 Riviera Bella Dr, Debary, FL 32713-5434. 685. Between December 23, 2010 and March 21, 2012, $3,083,343.73 was
deposited into this account, at least $2,629,023.45 of which appears to be proceeds of the gambling violations: $125,400.00 was deposited from B.B.S. Management Group Bank of America A account ending in Affiliate 61. $978,513.70 was deposited from Game Advice Inc Bank of America account ending in 54. which received illegal proceeds from AVOTW Affiliates 41 and which received illegal proceeds from AVOTW
224
$23,096.75 was deposited from INH Management Co Bank of America account ending in which received illegal proceeds from AVOTW Affiliate 32.
$1,502,013.00 was deposited from Media Advice, Inc. Bank of America account ending in which received illegal proceeds from AVOTW Affiliate 78.
686.
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Weaver, Cynthia 687. Bank of America wealth management money market savings account# was opened since at least September 30, 2009 in the name of Cynthia Weaver ITF Hannah Weaver and Isabella Weaver. This account was opened at the Debary Banking Center in Debary, Florida. Cynthia Weaver is listed as the signor on the account. The contact address for this account is listed as Weavers residence, 809 Riviera Bella Dr, Debary, FL 32713-5434. 688. Between December 30, 2010 and March 28, 2012, $51,110.32 was deposited
into this account, at least $50,000.00 of which appears to be proceeds of the gambling violations and $1,110.32 from interest accrued: $50,000.00 was deposited from Cynthia Weaver & Bennie Prince Bank of America account ending in which indirectly received illegal proceeds from
AVOTW Affiliates 32, 41, 54, 61 and 78. $1,110.32 interest accrued from deposit.
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689.
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Weaver, Cynthia 690. Bank of America wealth management money market savings account# was opened since at least May 28, 2009 in the name of Cynthia Weaver. Weaver is listed as the signor on the account. This account was opened at the Debary Banking Center in Debary, Florida. The contact address for this account is listed as Weavers residence, 809 Riviera Bella Dr, Debary, FL 32713-5434. 691. Between December 15, 2010 and March 13, 2012, $50,580.58 was deposited
into this account, at least $50,442.79 of which appears to be proceeds of the gambling violations and $137.79 from interest accrued: $50,442.79 was deposited from Cynthia Weaver & Bennie Prince Bank of America account ending in which indirectly received illegal proceeds from
AVOTW Affiliates 32, 41, 54, 61 and 78. 692. $137.79 interest accrued from deposits. As of March 13, 2012 this account had a balance of $50,988.32. Because this
226
Weaver, Cynthia 693. Bank of America my access checking account# was opened
since at least September 30, 2009 in the name of Cynthia Weaver ITF Hannah Weaver and Isabella Weaver (Bills Account). This account was opened at the Debary Banking Center in Debary, Florida. Cynthia Weaver is listed as the signor on the account. The contact address for this account is listed as Weavers residence, 809 Riviera Bella Dr, Debary, FL 327135434. 694. Between December 24, 2010 and March 22, 2012, $65,386.00 was deposited
into this account, at least $65,100.00 of which appears to be proceeds of the gambling violations: $65,100.00 was deposited from Cynthia Weaver & Bennie Prince Bank of America account ending in which indirectly received illegal proceeds from
AVOTW Affiliates 32, 41, 54, 61 and 78. 695. As of March 22, 2012 this account had a balance of $10,432.52. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Weeks, Stephanie & Brent 696. Regions Bank Lifegreen preferred checking account# was opened
since at least July 10, 2009 in the name of Stephanie M Weeks or Brent D Weeks POD Isaac W Wiebe. Stephanie and Brent Weeks are listed as the signors on the account. The contact address for this account is listed as 5061 Somerville Dr, Rockledge, FL 32955-6719.
227
697.
into this account, at least $171,583.27 of which appears to be proceeds of the gambling violations: $164,083.27 was deposited from Three (3) Blue Waters Technologies, LLC Bank of America accounts ending in and which directly or
indirectly received illegal proceeds from AVOTW Affiliates 50, 58 and 60. $7,500.00 was deposited from Stephanie & Brent Weeks Regions account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 50, 58 and 60. 698. As of March 20, 2012 this account had a balance of $2,134.64. Because this
account received deposits of gambling proceeds, the funds in this account are subject to forfeiture as proceeds of the gambling violations, pursuant to F.S. 895.05(3) and F.S. 932.702. Weeks, Stephanie & Brent 699. Regions Bank Lifegreen savings account# was opened since at
least January 11, 2011 in the name of Stephanie M Weeks or Brent D Weeks POD Isaac W Wiebe. Stephanie and Brent Weeks are listed as the signors on the account. The contact address for this account is listed as 5061 Somerville Dr, Rockledge, FL 32955-6719. 700. Between January 1, 2011 and March 31, 2012, $27,515.00 was deposited into
this account, at least $27,283.00 of which appears to be proceeds of the gambling violations: $27,283.00 was deposited from Stephanie & Brent Weeks Regions account ending in which indirectly received illegal proceeds from AVOTW
Affiliates 50, 58 and 60.
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701.
CONCLUSION OF BANK ACCOUNTS 702. As set forth above, there is probable cause to believe that funds deposited into
the above named accounts, described and discussed herein and marked as Attachment 1 of this affidavit which is attached and incorporated herein, constitute proceeds of the long term illegal activities of members of the AVOTW Enterprise and others There is probable cause to believe that funds located in bank accounts controlled by members of the AVOTW Enterprise and others, are proceeds of the long term gambling operation and derived from the use of the illegal slot machines, conducting illegal lotteries, keeping gambling houses, and RICO all in violation of F.S. 849 Et. Seq and F.S. 895.Et. Seq. Members of the AVOTW Enterprise and others conducted numerous financial transactions with the proceeds of the illegal gambling and moved the funds between various accounts to continue to carry out the illegal gambling operation and to disguise the source of these funds. The funds described in this affidavit are properties that were involved in a transaction or attempted transaction, in violation of F.S. 896.101 and/or F.S. 896.102 or property traceable to such property, and therefore are subject to forfeiture by F.S. 895.05(3) and F.S. 932.702.
229
VEHICLES, VESSELS, and REAL PROPERTY: 703. Your affiant believes the probable cause in your affiants Master Affidavit and
this Seizure Affidavit has established that members of the AVOTW Enterprise have obtained substantial amounts of income derived from their illegal gambling operation and racketeering activities. All of those persons or entities which seizures are being sought, have no other sources of income other than the illegal gambling and racketeering activities described in the Master Affidavit and this Seizure Affidavit or if they have other sources of income, their proceeds have been commingled with illegal proceeds. Your affiant believes there is
probable cause to physically seize vehicles and vessels described and listed in Attachment 2 of this affidavit which is incorporated herein pursuant to F.S. 932.702 and F.S. 895.05(3) and file Lis Pendens pursuant to F.S. 932.702 and F.S. 895.07(5)(a) on properties described and listed in Attachment 3 of this affidavit which is incorporated herein that are owned by or under the control of members of the AVOTW Enterprise on the grounds that they are proceeds of, or acquired from proceeds of, an unlawful activity as described in your affiants Master Affidavit and this Seizure Affidavit. Your affiant has evidence that will show that the
properties described in Attachment 2 and Attachment 3 of this Seizure Affidavit were purchased directly or indirectly with illegal proceeds or were purchased during the time frame of the racketeering activity and criminal violations whereas your affiant believes the funds would have been proceeds of the illegal activities of the AVOTW Enterprise. Your affiant advises this court that there are additional properties that were purchased with illegal proceeds by members of the AVOTW Enterprise, they are not included on Attachment 3 due to the properties having a Homestead Exemption thus not subject to forfeiture or being located outside the State of Florida.
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SEIZURE AFFIDAVIT - ATTACHMENT 1 BANK ACCOUNT SEIZURE LIST Bank Name Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Account # Type Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Account Owner Affiliate # 31 Affiliate # 32 Affiliate # 34 Affiliate # 35 Affiliate # 36 Affiliate # 37 Affiliate # 38 Affiliate # 39 Affiliate # 40 Affiliate # 41 Affiliate # 42 Affiliate # 43 Affiliate # 44 Affiliate # 45 Affiliate # 46 Affiliate # 47 Affiliate # 49 Affiliate # 50 Affiliate # 51 Affiliate # 52 Affiliate # 53 Affiliate # 54 Affiliate # 55 Affiliate # 56 Affiliate # 57 Affiliate # 58 Affiliate # 59 Account Name Affiliate # 31 (Allied Veteran Inc Affiliate 31) Affiliate # 32 (Allied Veterans of the World Aff 32) Affiliate # 34 (Allied Veterans of the World Inc" Aff 3) Affiliate # 35 (Allied Veterans of the World Aff 35) Affiliate # 36 (Allied Veterans, Affiliate 36) Affiliate # 37 (Allied Veterans Inc, Affiliate 37) Affiliate # 38 (Allied Veterans Inc, Affiliate 38) Affiliate # 39 (Allied Veterans of the World Aff39) Affiliate # 40 (Allied Veterans of the World Aff40) Affiliate # 41 (Allied Veterans of the World Inc Aff 41 Johnny E Duncan) Affiliate # 42 (Allied Veterans of the World Aff 42) Affiliate # 43 (Allied Veterans of the World Inc Aff 43) Affiliate # 44 (Allied Veterans of the World Inc Aff 44) Affiliate # 45 (Allied Veterans of the World, Inc Aff 45) Affiliate # 46 (Allied Veterans of the World Inc Aff 46) Affiliate # 47 (Allied Veterans of the World Inc Aff 47) Affiliate # 49 (Allied Veterans of the World Inc Aff 49) Affiliate # 50 (Allied Veterans of the World Inc Aff 50) Affiliate # 51 (Allied Veterans of the World Inc Aff 51) Affiliate # 52 (Allied Veterans of the World Inc Aff 52) Affiliate # 53 (Allied Veterans of the World Inc Aff 53) Affiliate # 54 (Allied Veterans Inc Affiliate 54 Johnny E Duncan) Affiliate # 55 (Allied Veterans of the World Inc Aff 55) Account Address PO Box 160939, Boiling Springs, SC, 293160016 814 N Nova RD Apt 1529 Daytona Beach, FL 32117-4616 PO Box 160939, Boiling Springs, SC, 293160016 PO Box 160939, Boiling Springs, SC, 293160016 PO Box 160939, Boiling Springs, SC, 293160016 PO Box 160939, Boiling Springs, SC, 293160016 PO Box 160939, Boiling Springs, SC, 293160016 PO Box 160939, Boiling Springs, SC, 293160016 PO Box 160939, Boiling Springs, SC, 293160016 PO Box 160939, Boiling Springs, SC, 293160016 PO Box 160939, Boiling Springs, SC, 293160016 PO Box 160939, Boiling Springs, SC, 293160016 PO Box 160939, Boiling Springs, SC, 293160016 PO Box 160939, Boiling Springs, SC, 293160016 PO Box 160939, Boiling Springs, SC, 293160016 PO Box 160939, Boiling Springs, SC, 293160016 PO Box 160939, Boiling Springs, SC, 293160016 PO Box 160939, Boiling Springs, SC, 293160016 415 N Grove ST, Eustis, FL 32726-3427 7269 Forest Oaks Blvd, Spring Hill, FL 346062330 7130 W Tennessee Street, Tallahassee, FL 32304-9324 401 Barton Blvd, Rockledge, FL 32955-2709 Signors on Account Johnny Duncan Johnny Duncan Johnny E Duncan, Linda A Duncan Johnny E Duncan, Linda A Duncan Johnny E Duncan, Linda A Duncan Johnny E Duncan, Linda A Duncan Johnny E Duncan, Linda A Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny E Duncan, Linda A Duncan Johnny E Duncan, Linda A Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny E Duncan, Linda A Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan
PO Box 160939, Boiling Springs, SC, 293160016 PO Box 160939, Boiling Springs, SC, 29316Affiliate # 56 (Allied Veterans of the World Aff 56) 0016 Affiliate # 57 (Allied Veterans of the World Inc Aff 57) PO Box 160939, Boiling Springs, SC 16093 6450 N Wickham RD STE 100, Melbourne, FL Affiliate # 58 (Allied Veterans of the World Inc Aff 58) 32940-2036 PO Box 160939, Boiling Springs, SC, 29316Affiliate # 59 (Allied Veterans of the World Inc Aff 59) 0016
SEIZURE AFFIDAVIT - ATTACHMENT 1 BANK ACCOUNT SEIZURE LIST Bank Name Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Palmetto Bank Bank of America Bank of America Bank of America Bank of America Bank of America Account # Type Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Affiliate Corporation Corporation Corporation Corporation Corporation Corporation Corporation Corporation Account Owner Affiliate # 60 Affiliate # 61 Affiliate # 63 Affiliate # 65 Affiliate # 67 Affiliate # 68 Affiliate # 70 Affiliate # 71 Affiliate # 72 Affiliate # 74 Affiliate # 76 Affiliate # 77 Affiliate # 78 Affiliate # 79 Account Name Affiliate # 60 (Allied Veterans of the World Inc Aff 60) Affiliate # 61 (Allied Veterans of the World Inc Aff 61) Affiliate # 63 (Allied Veterans of the World Inc Aff 63) Affiliate # 65 (Allied Veterans of the World Aff 65) Affiliate # 67 (Allied Veterans of the World Inc Aff 67) Affiliate # 68 (Allied Veterans of the World Aff 68) Affiliate # 70 (Allied Veterans of the World Aff 70) Affiliate # 71 (Allied Veterans of the World Inc Aff 71) Affiliate # 72 (Allied Veterans of the World Inc Aff 72) Affiliate # 74 (Allied Veterans of the World Inc & Aff Affiliate # 74) Affiliate # 76 (Allied Veterans of the World Inc Aff 76) Affiliate # 77 (Allied Veterans of the World Aff 77) Affiliate # 78 (Allied Veterans of the Wolrd Inc Aff 78) Affiliate # 79 (Allied Veterans of the World Inc Aff 79) Account Address 1150 Malabar Rd SE Ste 101, Palm Bay, FL 32907-3239 50 Plaza DR STE 201, Palm Coast, FL 32137 PO Box 160939, Boiling Springs, SC, 293160016 933 14th LN, Vero Beach, FL 32960-4736 PO Box 160939, Boiling Springs, SC, 293160016 231 Koolabrew Dr NW, Calabash, NC 284671937 501 N Beneva Rd Ste 500, Sarasota, FL 342321313 266 Blanding Blvd STE 1, Orange Park, FL 32073-3343 4158 NW 13th ST, Gainesville, FL 32609-1864 944 State Road 436, Casselberry, FL 327075633 13920 Palm Beach BLVD, Fort Myers, FL 33905-2138 PO Box 160939, Boiling Springs, SC, 293160016 1965 State Road 16, Saint Augustine, FL 320840811 PO Box 160939, Boiling Springs, SC, 293160016 Signors on Account Johnny Duncan Johnny Duncan Johnny E Duncan, Linda A Duncan Johnny Duncan Johnny Duncan Johnny E Duncan, Linda A Duncan Johnny Duncan Johnny E Duncan, Linda A Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan Johnny Duncan
Bank of America Bank of America
Corporation Corporation
Johnny Duncan, Linda Duncan Johnny E Duncan, Affiliate # 81 Affiliate # 81 (Allied Veterans of the World Inc Aff 81) 185 Carter Road, Palatka, FL 32177-8625 Linda A Duncan Affiliate # 85 Affiliate # 85 (Allied Veterans of the World Inc Aff 85) PO Box 180938, Boiling Springs, SC 29316 Johnny Duncan PO Box 160939, Boiling Springs, SC, 29316Johnny Duncan, Affiliate # 86 Affiliate # 86 (Allied Veterans of the World Inc Aff 86) 0016 Linda Duncan Allied Veterans Johnny Duncan, Allied Veterans Management Group Inc PO Box 160939, Boiling Springs, SC, 29316 Management Group Inc Linda Duncan Allied Veterans of the Allied Veterans of the World Inc. & Affiliates Johnny Duncan, 231 Koolabrew Dr NW, Calabash, NC 28467 World Inc. Headquarters John M. Hessong All-Pro Tax and Johnny Duncan, All-Pro Tax & Accounting LLC P.O. Box 160272, Boiling Springs, SC 29316 Accounting Scott Pruitt Automated X-100 P.O. Box 160939, Boiling Springs, SC 29316- Johnny E Duncan, Automated X-100 Services, Inc Services, Inc 00169 Linda Duncan AVMG Incorporated AVMG Incorporated Operating 7633 Royal Crest Dr, Jacksonville, FL 32256 Michael Davis AVMG Incorporated AVMG Incorporated Holding 7633 Royal Crest Dr, Jacksonville, FL 32256 Michael Davis AVMG Incorporated AVMG Incorporated Escrow & Taxes 7633 Royal Crest Dr, Jacksonville, FL 32256 Michael Davis Conrad Rowe, Earline V Hart, B&C Gaming Conrad H Rowe DBA B & C Gaming 8513 Gracious Pine Ave., Las Vegas,NV 89143 Shannon Gahagan, Michael C Nisbet Terri LeClaire, B&M Leasing & 3814 University Blvd., W, Jacksonville, FL B&M Leasing & Management, LLC Conrad Rowe, Management, LLC 32217-2202 Mazen Salloum B&M Leasing & 3814 University Blvd., W, Jacksonville, FL Mazen Salloum, B&M Leasing & Management, LLC ATM Account Management, LLC 32217-2202 Terri LeClaire
SEIZURE AFFIDAVIT - ATTACHMENT 1 BANK ACCOUNT SEIZURE LIST Bank Name Account # Type Account Owner B&M Leasing & Management, LLC Signors on Account Conrad Rowe, Mazen Salloum, B&M Leasing & Management LLC Saint Augustine 3959 Spring Glen Rd, Jacksonville, FL 32207 Salim Salloum, Store #55 Kenneth Nisbet Mazen Salloum, B&M Leasing & Management, LLC "Special Funds Terri Leclaire, Brad 3814 W University Blvd, Jacksonville, FL 32217 Account" Skidmore, Rebecca Stevens Mazen Salloum, B&M Leasing & Management LLC "Location 44 Terri Leclaire, Brad 3814 W University Blvd, Jacksonville, FL 32217 Account" Skidmore, Rebecca Stevens Bennie J Prince, B.B.S. Management Group, Inc. 809 Riviera Bella Dr, Debary, FL 32713-5434 Cynthia Weaver, Peggy A Prince Jerry W Bass, Jerry Bass DBA Bass Consulting & E-Bay Sales 542390 US Highway 1, Callahan, FL 32011 Carolyn Gail Bass Conrad Rowe and Bearcon Management, LLC 3077 Stratford Ct., Chesapeake, VA Shannon Gahagan Conrad Rowe, 3077 Stratford Ct., Chesapeake, VA 23321Bearcon Management, LLC Mazen Salloum, 5825 Shannon Gahagan 3077 Stratford Ct, Chesapeake, VA 23321Shannon Gahagan, Bearcon Management LLC 5825 Conrad Rowe Conrad H Rowe, 3077 Stratford Ct, Chesapeake, VA 23321Bearcon Management, LLC Shannon Gahagan, 5825 Kenneth M Nisbet 3077 Stratford Ct, Chesapeake, VA 23321Shannon Gahagan, Bearcon Management, LLC 5825 Conrad Rowe Michael Graham, Better Games Distributing Co., Inc. 103 N. Main St. Tabor City, NC 28463 Joseph Harrington, Elaine Harrington Michael Graham, Better Games Distributing Co., Inc. "L C Lease Acct" 103 N. Main St. Tabor City, NC 28463 Joseph Harrington Beyer Productions LLC 2111 Redbud Lane, Furlong, PA 18925 Anthony V Beyer Beyer Productions LLC 2111 Redbud Lane, Furlong, PA 18925 Anthony V Beyer Beyer Productions LLC 2111 Redbud Lane, Furlong, PA 18925 Anthony V Beyer Blue Water Internet Technology LLC Special Funds 8793 Tamiami Trl E Ste 207, Naples, FL 34113- Tony Parker, Leslie Acct 3338 Collins Tony Parker, Leslie Blue Water Internet Technology LLC PO Box 290187, Port Orange, FL 32129-0187 Collins Tony Parker, Leslie Blue Water Internet Technology LLC Payroll Account PO Box 290187, Port Orange, FL 32129-0187 Collins Blue Water Internet Technology, LLC Operating Tony Parker, Leslie PO Box 290187, Port Orange, FL 32129-0187 Account Collins Tony Parker, Leslie Blue Waters Technologies Special Funds Acct PO Box 290187, Port Orange, FL 32129-0187 Collins Tony Parker, Cary 31 Sundunes Circle, Ponce Inlet, FL 32127Blue Waters Technologies Hardee, Leslie L 7053 Collins 3300 S. Atlantic Avenue, Daytona Beach Tony J. Parker, Blue Waters Technologies Shores, FL 32218-6309 Leslie Collins Account Name Account Address
Bank of America
Corporation
Bank of America
Corporation
B&M Leasing & Management, LLC
Bank of America
Corporation
B&M Leasing & Management, LLC B.B.S. Management Group, Inc.
Bank of America Southeastern Bank of America Bank of America Bank of America Bank of America Bank of America Horry County State Bank Horry County State Bank Citizens Bank Citizens Bank Citizens Bank Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America
Corporation Corporation
Bass Consulting & EBay Sales Bearcon Management, Corporation LLC Corporation Corporation Corporation Bearcon Management, LLC Bearcon Management, LLC Bearcon Management, LLC Bearcon Management, LLC Better Games Distributing Co., Inc. Better Games Distributing Co., Inc. Beyer Productions LLC Beyer Productions LLC Beyer Productions LLC Blue Water Internet Technology Blue Water Internet Technology Blue Water Internet Technology Blue Water Internet Technology Blue Waters Technologies Blue Waters Technologies Blue Waters Technologies
Corporation Corporation Corporation Corporation Corporation Corporation Corporation Corporation Corporation Corporation Corporation Corporation Corporation
SEIZURE AFFIDAVIT - ATTACHMENT 1 BANK ACCOUNT SEIZURE LIST Bank Name Bank of America MidFirst Bank MidFirst Bank Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Regions Bank Bank of America Bank of America Bank of America Account # Type Corporation Corporation Corporation Corporation Corporation Corporation Corporation Account Owner Blue Waters Technologies Burns Familiy Cattle, LLC Burns Family Land Co., LLC Business Center Unlimited, Inc. Capital City Internet Center, Inc. CCS Management Group CCS Management Group Account Name Blue Waters Technologies Burns Family Cattle, LLC Chase Burns Burns Family Land Co., LLC or OK Coin Business Center Unlimited, Inc. Capital City Internet Center, Inc. CCS Management Group Inc. (Holly Hill Location Acct) CCS Management Group Inc. (Holly Hill Savings Accnt) Coastal Games LLC Special Funds Acct Coastal Games LLC, DBA Hot Spot, Leslie L Collins Coastal Games LLC, Payroll Account Comptrac, Inc. Davis Internet Management Davis Internet Management Co. Developco, Inc. Account Address 31 Sundunes Circle, Ponce Inlet, FL 321277053 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730052637 7130 W Tennessee Street, Tallahassee, FL 32304-9324 3030 S. Monroe Street, Suite 5B, Tallahassee, FL 32301-6961 809 Riviera Bella Dr, Debary, FL 32713-5434 809 Riviera Bella Dr, Debary, FL 32713-5434 PO Box 290187, Port Orange, FL 32129-0187 PO Box 290820, Port Orange, FL 32129-0820 PO Box 290820, Port Orange, FL 32129-0820 301 N Pine Meadow Drive Ste. E, Debary, FL 32713-2374 107 Hogan Coweta Rd, Hogansville, GA 302302852 107 Hogan Coweta Rd, Hogansville, GA Signors on Account Tony Parker, Leslie L Collins Chase Burns, Kristin Burns Chase Burns, Kristin Burns Reginald P Medlin, John P Fannin Reginald P Medlin, John Fannin Brandon S Weaver, Bennie James Prince Brandon S Weaver, Bennie J Prince Tony Parker, Leslie Collins Leslie Collins, Tony Parker, Cary Hardee Tony J Parker, Leslie Collins Aamir Waheed, Donald Powell Michael S. Davis, Jonathan T. Shave, Diane M. Davis Michael Davis
Corporation Coastal Games, LLC Corporation Coastal Games, LLC Corporation Coastal Games, LLC Corporation Corporation Corporation Corporation Corporation Corporation Corporation Comptrac, Inc. Davis Internet Management Davis Internet Management Developco, Inc.
Bank of America
Corporation
Bank of America
Corporation
Bank of America
Corporation
Bank of America
Corporation
2295 S Hiawassee Road Ste. 214, Orlando, FL no signature card 32835-8747 on file 301 N. Pine Meadow Drive Suite E, Debary, FL Digitrac Inc. Digitrac Inc. Aamir Waheed 32713-2605 107 Hogan Coweta Rd, Hogansville, GA 30230DMD Business Diane Davis, DMD Business Management, Inc Management, Inc 2852 Michael S Davis Enzyme Consultants, Nelson Cuba, Enzyme Consultants, LLC PO Box 1101, Jacksonville, FL 32201-1101 LLC Robert B Freitas Mazen Salloum, Free Entry Clay County 266 Blanding Blvd STE 1, Orange Park, FL Bradley D Free Entry Clay County LLC., Operating Account LLC 32073-3343 Skidmore, Stephanie Bennett Brad Skidmore, Free Entry Clay County Rebecca Stevens, Free Entry Clay County LLC "Location 71 Account" 231 Koolabrew Dr NW, Calabash, NC 28467 LLC Mazen Salloum, Terri LeClaire Brad Skidmore, Free Entry Clay County Free Entry Clay County LLC "Special Funds Rebecca Stevens, 231 Koolabrew Dr NW, Calabash, NC 28467 LLC Account" Mazen Salloum, Terri LeClaire Michael Graham, Gainesville Internet Gainesville Internet Services, LLC,"Operating 103 N. Main St. Tabor City, NC 28463-1617 Joey Harrington, Services, LLC" Account" Elaine Harrington
SEIZURE AFFIDAVIT - ATTACHMENT 1 BANK ACCOUNT SEIZURE LIST Bank Name Bank of America Wells Fargo/ Wachovia Bank Bank of America Bank of America MidFirst Bank Bank of America Bank of America Account # Type Corporation Corporation Corporation Corporation Corporation Corporation Corporation Account Owner Game Advice, Inc. Ginlin, LLC Ginlin, LLC Ginlin, LLC Give It Away Foundation Grant Park Grant Park, LLC Account Name Game Advice, Inc. Ginlin, LLC Ginlin, LLC Ginlin, LLC Payroll Acct Give It Away Foundation Grant Park LLC Special Funds Account Grant Park, LLC Account Address 301 N. Pine Meadow Drive Suite E, Debary, FL 32713-2605 Unknown 7269 Forest Oaks Blvd, Spring Hill, FL 346062330 7269 Forest Oaks Blvd, Spring Hill, FL 346062330 P.O. Box 130, Anadarko, Oklahoma 730050130 PO Box 290187, Port Orange, FL 32129-0187 PO Box 290820, Port Orange, FL 32129-0820 1050 US Highway 27 Ste. 20, Clermont, FL 34714-7522 PO Box 290820, Port Orange, FL 32129-0820 103 N. Main St. Tabor City, NC 28463-1617 PO Box 290187, Port Orange, FL 32129-0187 31 Sundunes Circle, Ponce Inlet, FL 321277053 Signors on Account Brandon Weaver, Aamir Waheed Unknown Anthony Alascia, Genevieve DiGiovanni Anthony Alascia Chase Burns, Kristin Burns Tony Parker, Leslie Collins Tony Parker, Leslie Collins, Cary Hardee Tony J. Parker, Leslie Collins, Cary Hardee Tony J Parker, Leslie Collins Michael Graham, Joseph Harrington, Elaine Harrington Tony Parker, Leslie Collins Tony J Parker, Leslie Collins, Cary Hardee, George Sloane III Tony J. Parker, Leslie Collins, Cary Hardee, Stephanie Weeks Tony Parker, Leslie Collins, Cary Hardee Bennie Prince, Shaheen Mosavi, Peggy Prince, Cynthia Weaver Aamir Waheed Aamir Waheed Aamir Waheed, Cheri S Black Chase Burns, Kristin Burns Chase Burns, Kristin Burns
Bank of America Bank of America Bank of America Bank of America
Corporation Corporation Corporation Corporation
Grant Park, LLC Grant Park, LLC Gulf Internet Services LLC Horry Technologies, LLC Horry Technologies, LLC
Grant Park, LLC Grant Park, LLC, Payroll Account Gulf Internet Services LLC Horry Technologies LLC Special Funds Account
Bank of America
Corporation
Horry Technologies, LLC
Bank of America
Corporation
Horry Technologies, LLC Horry Technologies, LLC
Horry Technologies, LLC Operating Account
31 Sundunes Circle, Ponce Inlet, FL 321277053
Bank of America
Corporation
Horry Technologies, LLC Payroll Account
31 Sundunes Cir, Ponce Inlet, FL 32127
Bank of America
Corporation I.N.H. Management Co.
I.N.H. Management Co.
809 Riviera Bella Dr, Debary, FL 32713-5434 301 N. Pine Meadow Drive OFC, Debary, FL 32713-2376 3299 S. Babcock Street, Melbourne, FL 329016926 301 N. Pine Meadow Drive Suite E, Debary, FL 32713-2605 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130
Bank of America Bank of America Bank of America Bank of America MidFirst Bank
Corporation Corporation Corporation Corporation Corporation
Infohub, Inc. Infovice Inc. Intelitek Inc. International Internet Technologies, LLC International Internet Technologies, LLC
Infohub, Inc. Infovice Inc. Intelitek Inc. International Internet Technologies, LLC International Internet Technologies, LLC
SEIZURE AFFIDAVIT - ATTACHMENT 1 BANK ACCOUNT SEIZURE LIST Bank Name Bank of America Bank of America Bank of America Account # Type Corporation Account Owner Account Name J&R Business Center Inc J&R Business Center Inc Jacksonville F.O.P. Foundation Inc Account Address PO Box 97, Little River, SC 29566 18 McCallister Rd, Crawfordville, FL 32327 5530 Beach Blvd., Jackonville, FL 32207-5161 Signors on Account Reginald Medlin Reginald Medlin Nelson Cuba Nelson Cuba, Robert Freitas, David Kilcrease, D. Rene Angers, Shelley Lindsey Michael W. Graham, Joseph S. Harrington Michael Graham, Joey Harrington, Elaine Harrington Michael Graham, Joey Harrington, Elaine Harrington Salim Saloum, Zaher Salloum, Samer Saloum Brad Skidmore, Rebecca Stevens, Mazen Salloum, Terri LeClaire Brad Skidmore, Rebecca Stevens, Mazen Salloum, Terri LeClaire Donna A. Mathis, Kelly B. Mathis, James T. Murphy, Jill F. Bechtold, Kelly B. Mathis, James T. Murphy, The Florida Bar Foundation, Jill F. Bechtold Aamir Waheed Anthony Alascia Michael Ryles, Janis S Jayroe Mazen Salloum,Samer Saloum,Zaher Salloum, Salim Saloum
J&R Business Center Inc J&R Business Center Corporation Inc Corporation Jacksonville F.O.P.
BBVA Compass Bank
Corporation
Jacksonville F.O.P.
Jacksonville Fraternal Order of Police
5530 Beach Blvd., Jackonville, FL 32207
Horry County State Bank Bank of America
Corporation
JM Land Investments LLC Lake City Internet Services, LLC Live Oak Internet Services, LLC M&S Management Services, LLC M&S Management Services, LLC
JM Land Investments LLC Lake City Internet Services, LLC., "Operating Account" Live Oak Internet Services LLC "Operating Account"
103 N Main Street, Tabor City, NC 28463
Corporation
103 N. Main St. Tabor City, NC 28463-1617
Bank of America
Corporation
103 N. Main St. Tabor City, NC 28463-1617 1440 Dunn Avenue Suite 5, Jacksonville, FL 32218-4894
Bank of America
Corporation
M & S Management Services, LLC
Bank of America
Corporation
M&S Management Services, LLC "Location 38 Account"
3814 University Blvd, Jacksonville, FL 32217
Bank of America
Corporation
M&S Management Services, LLC
M&S Management Services, LLC "Special Funds Account"
3814 University Blvd, Jacksonville, FL 32217
The Jacksonville Bank
Corporation Mathis & Murphy, P.A.
Mathis & Murphy, P.A.
1200 Riverplace Blvd Suite 902, Jacksonville, FL 32207
The Jacksonville Bank
Corporation Mathis & Murphy, P.A.
Mathis & Murphy, P.A. "Trust" Account
1200 Riverplace Blvd Suite 902, Jacksonville, FL 32207 301 N. Pine Meadow Drive Suite E, Debary, FL 32713-2605 7466 Jonquil Pl, Weeki Wachee, FL 346072024 1355 Clearview Dr., Manning,SC 29102
Bank of America Bank of America Bank of America
Corporation Corporation Corporation
Media Advice Inc. MegJon, LLC MJ Enterprises, LLC
Media Advice Inc. MegJon, LLC MJ Enterprises, LLC
Suntrust Bank
Corporation MNL Investments, Inc
MNL Investments, Inc
3959 Spring Glen Rd., Jacksonville,FL 322077167
SEIZURE AFFIDAVIT - ATTACHMENT 1 BANK ACCOUNT SEIZURE LIST Bank Name Account # Type Signors on Account Mazen Salloum,Samer MNL Investments, Inc MNL Investments, Inc PO Box 48222, Jacksonville, FL 32247 Saloum,Zaher Salloum, Salim Saloum Mazen Salloum,Samer 3959 Spring Glen Rd., Jacksonville,FL 32207MNL Investments, Inc MNL Investments, Inc Saloum,Zaher 7167 Salloum, Salim Saloum Michael Davis, Gary MSG Business 107 Hogan Coweta Rd, Hogansville, GA 30230MSG Business Centers, Inc. Davis, Diane Davis, Centers, Inc. 2852 Sammy Keeble Chase Burns, Prestige Gaming, LLC Prestige Gaming, LLC P.O. Box 130, Anadarko, Oklahoma 73005 Kristin Burns Quincy Business 1315 E LaFayette St, Ste C RMB, Tallahassee, Quincy Business Center Inc Reginald P Medlin Center FL 32301 Quincy Business 1315 E LaFayette St, Ste C RMB, Tallahassee, Quincy Business Center Inc Reginald P Medlin Center FL 32301 301 N Pine Meadow Drive Ste. E, Debary, FL Cheri S. Black, Realtrack Inc Realtrack Inc 32713-2374 Aamir Waheed 301 N Pine Meadow Drive Ste. E, Debary, FL Aamir Waheed, Realvice Inc Realvice Inc 32713-2374 Tariq Waheed 7490 W Colonial Drive, Orlando, FL 32818Aamir Waheed, Realvice Inc Realvice, Inc DBA Metro One Stop (Car Wash Acc) 6779 Tariq Waheed 7490 W Colonial Drive, Orlando, FL 32818Aamir Waheed, Realvice Inc Realvice, Inc DBA Metro One Stop (Gas Acc) 6779 Tariq Waheed Realvice, Inc DBA Metro One Stop (Lube Express 7490 W Colonial Drive, Orlando, FL 32818Aamir Waheed, Realvice Inc Acc) 6779 Tariq Waheed 7490 W Colonial Drive, Orlando, FL 32818Aamir Waheed, Realvice Inc Realvice, Inc DBA Metro One Stop (Store Acc) 6779 Tariq Waheed Brad D Skidmore, 231 Koolabrew Drive, NW Suite A, Calabash, Seaside Gaming, Inc Seaside Gaming, Inc Tracey Skidmore, NC 28467-1937 Rebecca Stevens Bradley Skidmore Seaside Gaming, Inc Seaside Gaming, Inc 231 Koolabrew Drive NW Calabash, NC 28467 and Tracey Skidmore Mazen G Salloum, Seaside Internet Seaside Internet - Marion, LLC 1033 NE 14th St, Ocala, FL 34470-5452 Cedric D Fuller, Marions, LLC Marisa N Banks Brad Skidmore, Seaside Internet Rebecca Stevens, Seaside Internet-Marion, LLC "Location 57 Account" 231 Koolabrew Dr NW, Calabash, NC 28467 Marions, LLC Mazen Salloum, Terri LeClaire Brad Skidmore, Seaside Internet Rebecca Stevens, Seaside Internet-Marion, LLC "Location 63 Account" 231 Koolabrew Dr NW, Calabash, NC 28467 Marions, LLC Mazen Salloum, Terri LeClaire Brad Skidmore, Seaside Internet Seaside Internet - Marion, LLC "Special Funds Rebecca Stevens, 231 Koolabrew Dr NW, Calabash, NC 28467 Mazen Salloum, Marions, LLC Account" Terri LeClaire Account Owner Account Name Account Address
Suntrust Bank
Corporation
Wells Fargo/ Wachovia Bank
Corporation
Bank of America MidFirst Bank Bank of America Bank of America Fifth Third Fifth Third Regions Bank Regions Bank Regions Bank Regions Bank Bank of America
Corporation Corporation Corporation Corporation Corporation Corporation Corporation Corporation Corporation Corporation Corporation
Crescent Bank
Corporation
Bank of America
Corporation
Bank of America
Corporation
Bank of America
Corporation
Bank of America
Corporation
SEIZURE AFFIDAVIT - ATTACHMENT 1 BANK ACCOUNT SEIZURE LIST Bank Name Account # Type Account Owner Seaside Internet Putnam, LLC Signors on Account Brad Skidmore, Rebecca Stevens, Seaside Internet-Putnam, LLC "Location 81 Account" 231 Koolabrew Dr NW, Calabash, NC 28467 Mazen Salloum, Terri LeClaire Brad Skidmore, Seaside Internt - Putnam, LLC "Special Funds Rebecca Stevens, 231 Koolabrew Dr NW, Calabash, NC 28467 Account" Mazen Salloum, Terri LeClaire Bradley D Skidmore, Mazen G Seaside Internet - Putnam, LLC 185 Carter Road, Palatka, FL 32177-8625 Salloum, Jill Renee Russo Michael Ryles, Brad D Skidmore, Tracey Skidmore, Rebecca 231 Koolabrew Drive NW Calabash, NC 28467Seaside Internet, LLC Stevens, Jann 1937 Ryles, Mazen Salloum, Terri L. LeClaire Brad Skidmore, Michael W Ryles, Seaside Internet, LLC Location 43 Account 231 Koolabrew Dr NW, Calabash, NC 28467 Rebecca Stevens, Mazen Salloum, Terri L LeClaire Brad Skidmore, Michael W Ryles, Seaside Internet, LLC Location 34 Account 231 Koolabrew Dr NW, Calabash, NC 28467 Rebecca Stevens, Mazen Salloum, Terri L LeClaire Brad Skidmore, Michael W Ryles, Seaside Internet, LLC Location 68 Account 231 Koolabrew Dr NW, Calabash, NC 28467 Rebecca Stevens, Mazen Salloum, Terri L LeClaire Bradley Skidmore,Tracey Seaside Technologies, Inc 231 Koolabrew Drive NW Calabash, NC 28467 Skidmore, Rebecca Stevens TN Yacht Charters, LLC Unknown Unknown Chase Burns, TN Yacht Charters, LLC P.O. Box 130, Anadarko, Oklahoma 73005 Kristin Burns 4470 Eastport Park Way, Port Orange, FL Tony Parker, Leslie Tparker Management LLC 32127-6044 Collins 4470 Eastport Park Way, Port Orange, FL Tony Parker, Leslie Tparker Management LLC 32127-6044 Collins 7466 Jonquil Pl, Weeki Wachee, FL 34607Anthony W Alascia Anthony Alascia 2024 7466 Jonquil Pl, Weeki Wachee, FL 34607Anthony W Alascia Anthony Alascia 2024 Account Name Account Address Charles P Bartlett Anthony V Beyer 13630 Jennita Drive, Port Richey, FL 34667 2111 Redbud Lane, Furlong, PA 18925 Charles P Bartlett Anthony V Beyer
Bank of America
Corporation
Bank of America
Corporation
Seaside Internet Putnam, LLC
Bank of America
Corporation
Seaside Internet Putnam, LLC
Bank of America
Corporation Seaside Internet, LLC
Bank of America
Bank of America
Bank of America
Crescent Bank Bank of America MidFirst Bank Bank of America Bank of America Bank of America Bank of America Wells Fargo/ Wachovia Bank Citizens Bank
Corporation Corporation Corporation
Seaside Technologies, Inc TN Yacht Charters, TN Yacht Charters, LLC
Corporation Tparker Management Corporation Tparker Management Personal Personal Personal Personal Alascia, Anthony Alascia, Anthony Bartlett, Charles Beyer, Anthony
SEIZURE AFFIDAVIT - ATTACHMENT 1 BANK ACCOUNT SEIZURE LIST Bank Name Citizens Bank Regions Bank Regions Bank Principal Life Insurance Company/ Principal Financial Group Scottrade Morgan Stanley Smith Barney MidFirst Bank Scottrade Morgan Stanley Smith Barney Morgan Stanley Smith Barney Morgan Stanley Smith Barney Morgan Stanley Smith Barney Morgan Stanley Smith Barney Morgan Stanley Smith Barney Morgan Stanley Smith Barney Morgan Stanley Smith Barney Morgan Stanley Smith Barney Morgan Stanley Smith Barney Morgan Stanley Smith Barney Morgan Stanley Smith Barney Morgan Stanley Smith Barney Morgan Stanley Smith Barney Morgan Stanley Smith Barney Morgan Stanley Smith Barney JP Morgan Chase Bank JP Morgan Chase Bank Account # Type Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Account Owner Beyer, Anthony Black, Cheri Black, Daniel Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Burns, Chase Account Name Anthony V Beyer Cheri S Black Daniel L Black, Karie Anne Black Chase Burns Chase Burns Chase Burns CGM SEP IRA Custodian U/P/O I.I.T. TRAK Chase Burns Trustee for the Chase Burns Trust Chase Burns TTEE Chase Burns Trust U/A DTD 08/20/2010 Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Brandes Emerging Markets Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Cambiar Investors Large Value Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Clearbridge Dividend Strategy Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Clearbridge Multi-Cap Growth Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Cubic Asset Mgmt SM/MID Value Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Eaton Vance Intermediate Muni Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Jennison Large Cap Growth Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Miller/Howard Income Equity Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 NFJ Dividend Value Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 NFJ International Equity Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Non-Advisory Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Santa Barbara Dividend Growth Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Syndicate Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 TRAK Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Western Asset Current Mkt Muni Chase Burns TTEE FBO Chase Burns Trust U/A/D 08-20-2010 Western Asset Gov/Corp Bonds Goldman Sachs & Co., N.Y. (Chase Burns Hedge Fund Investment) Sophrosyne Technology Partners LTD (Chase Burns Hedge Fund Investment) Account Address 2111 Redbud Lane, Furlong, PA 18925 11120 Bridge House Rd, Windermere, FL 34786-5404 555 Woodford Dr, Debary, FL 32713-2133 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 73005P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 106 E. Kansas Ave, Anadarko, Oklahoma 73005-2637 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 Unknown Unknown Signors on Account Anthony V Beyer Cheri Black Daniel Black, Karie Black Chase E Burns, Kristin Burns, Tammie McDonald Chase Burns Chase Burns Chase Burns, Kristin Burns Chase Burns Chase Burns Chase Burns Chase Burns Chase Burns Chase Burns Chase Burns Chase Burns Chase Burns Chase Burns Chase Burns Chase Burns Chase Burns Chase Burns Chase Burns Chase Burns Chase Burns Unknown Unknown
SEIZURE AFFIDAVIT - ATTACHMENT 1 BANK ACCOUNT SEIZURE LIST Bank Name JP Morgan Chase Bank MidFirst Bank Morgan Stanley Smith Barney MidFirst Bank Wells Fargo/ Wachovia Bank Wells Fargo/ Wachovia Bank Vystar Credit Union Vystar Credit Union Bank of America Bank of America Bank of America Wells Fargo/ Wachovia Bank Bank of America Bank of America Account # Type Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Account Owner Burns, Kristin Burns, Kristin Burns, Kristin Burns, Kristin & Burns, Chase Collins, Leslie Collins, Leslie Cuba, Nelson Cuba, Nelson Cucciniello, John Cucciniello, John Cucciniello, John & Cucciniello, Nikki Davis, Michael Davis, Michael & Davis, Diane Davis, Michael, Davis, Gary & Davis, Diane Account Name Kristin Burns Kristin P. Burns Kristin P. Burns CGM SEP IRA Custodian U/P/O I.I.T. TRAK Kristin P. Burns Chase Burns Leslie L Collins Leslie L Collins Nelson D. Cuba Nelson D. Cuba John Cucciniello John Cucciniello John Cucciniello, Nikki Cucciniello Michael Davis Diane Davis, Michael S Davis Diane M Davis or Gary W Davis, Michael S Davis 5195 Montford Circle, Spring Hill, FL 346061547 5195 Montford Circle, Spring Hill, FL 346061547 5195 Montford Circle, Spring Hill, FL 346061547 7633 Royal Crest Dr, Jacksonville, FL 322562321 107 Hogan Coweta Rd, Hogansville, GA 302302852 107 Hogan Coweta Rd, Hogansville, GA 302302852 Account Address P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 P.O. Box 130, Anadarko, Oklahoma 730050130 31 Sundunes Circle, Ponce Inlet, FL 32127 31 Sundunes Circle, Ponce Inlet, FL 321277053 Signors on Account Kristin A. Porter (Burns) Chase Burns, Kristin Burns Kristin Burns Kristin Burns Leslie L Collins Leslie L Collins Nelson D. Cuba Nelson D. Cuba John Cucciniello John Cucciniello John Cucciniello, Nikki Cucciniello Michael Davis Diane Davis
Bank of America
Personal
Bank of America Bank of America Bank of America Bank of America Horry County State Bank Horry County State Bank Wells Fargo/ Wachovia Bank Horry County State Bank Horry County State Bank First Citizens
Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal
Diane M Davis, Gary W Davis, Michael Davis Diane M Davis, Davis, Michael, Davis, 107 Hogan Coweta Rd, Hogansville, GA 30230Diane M Davis or Gary W Davis, Michael S Davis Gary W Davis, Gary & Davis, Diane 2852 Michael Davis Michael Davis, Davis, Michael, Davis, 107 Hogan Coweta Rd, Hogansville, GA 30230Michael S Davis, Diane M Davis, Gary Wayne Davis Diane Davis, Gary Gary & Davis, Diane 2852 Davis Duncan, Johnny & 240 Oldmaster Ct, Boiling Springs, SC 29316Johnny Duncan, Johnny E Duncan, Linda A Duncan Duncan, Linda 5659 Linda Duncan Duncan, Johnny & PO Box 160939, Boiling Springs, SC 29316Johnny Duncan, Johnny E Duncan, Linda A Duncan Linda Duncan Duncan, Linda 0016 Duncan, Johnny & 240 Oldmaster Ct, Boiling Springs, SC 29316Johnny Duncan, Johnny E Duncan, Linda A Duncan R-Account Duncan, Linda 5659 Linda Duncan Graham, Michael & Michael W. Graham POD Kelly E Graham 249 Carriage Lake Dr. Little River, SC 29566 Michael Graham Graham, Kelly Graham, Michael & Michael W. Graham POD Kelly E Graham 249 Carriage Lake Dr. Little River, SC 29566 Michael Graham Graham, Kelly Hardee, Cary Harrington, Joseph & Harrington, Elaine Harrington, Joseph & Harrington, Elaine Lucas, Leonard Cary Hardee Joseph & Elaine Harrington Joseph & Elaine Harrington Leonard D Lucas PO Box 2286, Tybee Island, GA 31328-2286 867 Loop Cir. Longs, SC 29568 867 Loop Cir. Longs, SC 29568 2190 Airport Road, Lancaster, SC 29720-3913 Cary Hardee Joseph & Elaine Harrington Joseph & Elaine Harrington Leonard D. Lucas
SEIZURE AFFIDAVIT - ATTACHMENT 1 BANK ACCOUNT SEIZURE LIST Bank Name Bank of America Bank of America Wells Fargo/ Wachovia Bank Wells Fargo/ Wachovia Bank Bank of America Bank of America Fifth Third Suntrust Bank Suntrust Bank Bank of America Wells Fargo/ Wachovia Bank Bank of America Wells Fargo/ Wachovia Bank Bank of America Edward Jones Edward Jones Wells Fargo/ Wachovia Bank Safe Federal Credit Union Bank of America Bank of Clarendon Safe Federal Credit Union Wells Fargo/ Wachovia Bank Wells Fargo/ Wachovia Bank Bank of America Suntrust Bank Vystar Credit Union Everbank 9 Account # Type Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Account Owner Medlin, Reginald Medlin, Reginald Parker, Anthony Parker, Anthony Prince, Bennie & Prince, Peggy Prince, Bennie & Prince, Peggy Rokh, Changiz & Haghighi, Maryam B Rokh, Changiz & Haghighi, Maryam B Rokh, Changiz & Haghighi, Maryam B Rowe, Conrad Rubino, Richard Rubino, Richard Rubino, Richard Ryles, Janis Ryles, Michael Ryles, Michael Ryles, Michael Ryles, Michael & Ryles, Janis Ryles, Michael & Ryles, Janis Ryles, Michael & Ryles, Janis Ryles, Michael & Ryles, Janis Ryles, Michael & Ryles, Janis Salloum, Mazen Salloum, Zaher & Salloum, Nancy Salloum, Zaher & Salloum, Nancy Saloum, Salim & Gross, Tamara Saloum, Samer Account Name Reginald P Medlin POD Marion Christopher Medlin Reginald P Medlin POD Marion Christopher Medlin Tony J Parker Tony J Parker Bennie J Prince, Peggy A Prince ITF Cynthia Weaver, ITF Lori Barnett Peggy A Prince, Bennie J Prince ITF Cynthia Weaver, ITF Lori Barnett Changiz Rokh, Maryam B Haghighi Changiz Rokh, Maryam B Haghighi Changiz Rokh, Maryam B Haghighi Conrad Rowe Patricia Ann Rubino, Richard Rubino Richard J Rubino ITF Patricia A Rubino Richard Rubino, Patricia Ann Rubino Janis Ryles Michael Ryles Michael Ryles Michael Ryles Michael Ryles and Janis Jayroe Michael Ryles and Janis Ryles Michael Ryles and Janis Ryles Michael Ryles and Janis Ryles Michael Ryles and Janis Ryles Mazen Salloum Zaher Salloum and Nancy Salloum Zaher Salloum and Nancy Salloum Salim Saloum and Tamara L Gross Samer G Saloum Account Address 3749 Ivy Green Trl, Tallahassee, FL 32311 3749 Ivy Green Trl, Tallahassee, FL 32311 31 Sundunes Circle, Ponce Inlet, FL 321277053 31 Sundunes Circle, Ponce Inlet, FL 321277053 Signors on Account Reginald P Medlin Reginald P Medlin Tony J Parker Tony J Parker
Bennie Prince, 809 Riviera Bella Dr, Debary, FL 32713-5434 Peggy Prince Bennie Prince, 809 Riviera Bella Dr, Debary, FL 32713-5434 Peggy Prince Changiz Rokh, 96 Rosehill Cresent Ct, Debary, FL 32713 Maryam B Haghighi Changiz Rokh, 96 Rosehill Cresent Ct, Debary, FL 32713 Maryam B Haghighi Changiz Rokh, 96 Rosehill Cresent Ct, Debary, FL 32713 Maryam B Haghighi 8513 Gracious Pine Ave., Las Vegas,NV 89143 Conrad Rowe Richard Rubino, 1534 Grace Lake Cir, Longwood, FL 32750Patricia Ann Rubino 2836 (McDowell) 1534 Grace Lake Cir, Longwood, FL 32750Richard Rubino 2836 Richard Rubino, 1534 Grace Lake Cir, Longwood, FL 32750Patricia Ann Rubino 2836 (McDowell) 302 Haynsworth St,Sumter,SC 29150 Janis Ryles 1103 Cedar Bay, FL 32259 Michael Ryles Michael Ryles, 1355 Clearview Dr., Manning,SC 29102 Janis Ryles Michael Ryles and 1103 Cedar Bay, FL 32259 Janis Ryles Michael Ryles and 1355 Clearview Dr., Manning,SC 29102 Janis Jayroe Michael Ryles and 1103 Cedar Bay Rd, Jacksonville, FL 32218 Janis Ryles Michael Ryles and 1355 Clearview Dr., Manning,SC 29102 Janis Ryles Michael Ryles and 1355 Clearview Dr., Manning,SC 29102 Janis Ryles Michael Ryles and 1103 Cedar Bay Rd, Jacksonville, FL 32218 Janis Ryles 4599 Ecton Lane E, Jacksonville, Fl 32246 304 Sweetbrier Branch Ln, Jacksonville, FL 32259 1124 Ashmore Dr., Jacksonville, Fl 32259 3670 Reedpond Dr., Jacksonville Fl 10411 Scott Mill Rd, Jacksonville, FL 322576256 Mazen Salloum Zaher Salloum and Nancy Salloum Zaher Salloum and Nancy Salloum Salim Saloum and Tamara L Gross Samer Saloum
SEIZURE AFFIDAVIT - ATTACHMENT 1 BANK ACCOUNT SEIZURE LIST Bank Name Everbank BB&T Bank of America Account # Type Personal Personal Personal Account Owner Saloum, Samer Skidmore, Bradley Skidmore, Bradley Skidmore, Bradley & Skidmore, Tracey Waheed, Aamir & Black, Cheri Waheed, Aamir & Black, Cheri Waheed, Tariq Waheed, Tariq & Waheed, Sadia Weaver, Brandon Weaver, Cynthia Weaver, Cynthia Weaver, Cynthia Weaver, Cynthia Weeks, Stephanie & Weeks, Brent Weeks, Stephanie & Weeks, Brent Account Name Samer G Saloum Brad Skidmore Bradley Skidmore Account Address 10411 Scott Mill Rd, Jacksonville, FL 322576256 Unknown 231 Koolabrew Drive NW Calabash, NC 28467 Signors on Account Samer Saloum Unknown Bradley Skidmore and Tracey Skidmore Brad Skimore, Tracey Skidmore, Rebecca Stevens Aamir Waheed, Cheri S Black Aamir Waheed, Cheri S Black Tariq Waheed Tariq Waheed & Sadia Waheed
Crescent Bank Bank of America Fifth Third Regions Bank Bank of America Bank of America Bank of America Bank of America Bank of America Bank of America Regions Bank Regions Bank 0113578332
Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal Personal
Brad Skimore, Tracey Skidmore, Rebecca Stevens Aamir Waheed, Cheri S Black Aamir Waheed, Cheri S Black Tariq Waheed Tariq Waheed, Sadia Waheed
817 Tillson Rd., Myrtle Beach, SC 29582 11120 Bridge House Rd, Windermere, FL 34786-5404 11120 Bridge House Rd, Windermere, FL 34786-5404 15348 Harvest Blvd, Clermont, FL 34714-6183 15348 Harvest Blvd, Clermont, FL 34714-6183
Brandon S Weaver ITF Hannah Weaver and Isabella 809 Riviera Bella Dr, Debary, FL 32713-5434 Brandon Weaver Weaver Cynthia Weaver 809 Riviera Bella Dr, Debary, FL 32713-5434 Cynthia Weaver Cynthia Weaver ITF Hannah Weaver and Isabella 809 Riviera Bella Dr, Debary, FL 32713-5434 Cynthia Weaver Weaver Cynthia Weaver ITF Hannah Weaver and Isabella 809 Riviera Bella Dr, Debary, FL 32713-5434 Cynthia Weaver Weaver (Bills Account) Cynthia Weaver, Bennie J Prince ITF Hannah Cynthia Weaver, 809 Riviera Bella Dr, Debary, FL 32713-5434 Weaver and Isabella Weaver Bennie J Prince Stephanie M Weeks or Brent D Weeks POD Isaac W Stephanie Weeks, 5061 Somerville Dr, Rockledge, FL 32955-6719 Wiebe Brent Weeks Stephanie M Weeks or Brent D Weeks POD Isaac W Stephanie Weeks, 5061 Somerville Dr, Rockledge, FL 32955-6719 Wiebe Brent Weeks
SEIZURE AFFIDAVIT - ATTACHMENT 2 VEHICLE/VESSEL SEIZURE LIST Registered Owner Alascia, Anthony Bartlett, Charles Bartlett, Charles Bartlett, Charles Bartlett, Charles Bass, Jerry Bass, Jerry Black, Charles Lee Black, Charles Lee Chase Burns Revocable Trust Coastal Games, LLC Cucciniello, John Cucciniello, John Cucciniello, John Duncan, Johnny Duncan, Johnny & Linda Duncan, Johnny Ernest Duncan, Linda Ann Hardee, Cary Hessong, John Michael Hessong, John Michael Hessong, John Michael International Internet Technologies International Internet Technologies International Internet Technologies International Internet Technologies International Internet Technologies, LLC International Internet Technologies, LLC Jones Dabbs, Chassidy Parker, Anthony Parker, Anthony Parker, Anthony Parker, Anthony Parker, Anthony Parker, Anthony Parker, Anthony Parker, Anthony Parker, Anthony Parker, Anthony Parker, Anthony Parker, Anthony Parker, Anthony Parker, Anthony Parker, Anthony & Collins, Leslie Prince, Bennie Prince, Bennie Prince, Peggy Rokh, Changiz Rokh, Changiz Rowe, Conrad Year 2011 1996 1996 1993 2004 2008 2000 2001 2003 2006 2004 2009 2010 2012 2008 2011 2013 2013 2006 2001 1971 2011 2010 2004 2003 2008 2010 2012 2006 2001 2000 2003 2004 1995 2001 2006 2006 2004 1995 2004 2001 2000 2013 2010 2008 2012 2006 2004 2006 2003 Color Gray Make Maserati Vessel Vessel Chevrolet Dodge Cadillac 24.00' Godfrey Marine Company Mitsubishi Procraft Spartan Dodge Harley Davidson 11.00' Bombardier Recreational 19.00' Stingray Boat Company Lexus Cadillac Lexus Lexus BMW Dodge Chevrolet Honda Dodge Pontiac Pontiac Chevrolet Dodge Dodge Ford BMW Harley Davidson Hummer Jaguar Porsche 20.00' Hydra-Sports Inc 10.00' Bombardier Recreational 10.00' Bombardier Recreational 12.00' Zodiac of North America 22.00' Wellcraft Marine Corp 10.00' Bombardier Recreational Sea Ray A-1 Vehicle Trailer Big Tex Trailer Co. BMW Chevrolet GMC Nissan BMW Toyota BMW Model Granturismo S Jetski Jetski Corvette Ram 1500 Escalade Vessel Eclipse GT Vessel Motorhome G2500 Van VRSCF Vessel Open Motorboat RX350 STS 4S ES RX350 750IL Ram 1500 Pickup CR-V SE Caravan SXT Montana Montana Uplander Grand Caravan Grand Caravan Expedition XLT 740IL FLSTF H2 X-Type 3.0 AWD 911 Carrera2/4 Vessel Vessel Vessel Vessel Vessel Vessel Vessel Vehicle Trailer Tilt Tandem 750LI Silverado 3500 Terrain Altima 745LI Sequoia Z4 Convertible State FL FL FL FL FL FL FL FL FL OK FL FL FL FL SC SC SC SC SC FL FL FL OK OK OK OK FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL NV None Tag VIN/Hull # ZAM45KMA8B0060270 ZZN031331596 ZZN210431596 1G1YY23P7P5102997 1D7HA18D94J200281 1GYEC63868R119433 GDY3544EA000 4A3AC54H91E156144 MGL15578J203 4VZAT1C986C055281 1GCGG25V641133548 1HD1HPH109K801353 YDV10669A010 PNYUS9FXD212 JTJGK31U280012476 1G6DX6ED8B0132165 JTHBK1GG7D2010416 2T2ZK1BA5DC092985 WBAHN835X6DT27899 1B7HC13Y01J542681 CE141B609376 5J6RE3H47BL015219 2D4RN5D11AR486434 1GMDX03E74D211503 1GMDX03E93D159547 1GNDV23168D145333 2D4RN4DE6AR418661 2C4RDGCG8CR122922 1FMPU15566LA77245 WBAGH83491DP20294 1HD1BMY15YY028990 5GRGN23U73H108856 SAJEA51C24WD79745 WP0CA2999SS340455 HSXXC262K001 YDV37848D606 YDV36630C606 XDC079BRA404 WELDDD071495 ZZN50047E404 SERY0744F001 455AC16274S000411 16VCX1825D3E63820 WBAKB8C51ACY64013 1GCJK33618F172904 2GKFLXE51C6315579 1N4BL11DX6C191589 WBAGL63444DP70799 5TDZT38A56S270487 Address 7466 Jonquil PL, Spring Hill, FL 34607 13630 Jennita Dr, Hudson, FL 34667 13630 Jennita Dr, Hudson, FL 34667 13630 Jennita Dr, Hudson, FL 34667 13630 Jennita Dr, Hudson, FL 34667 6718 Oakwood Dr, Jacksonville, FL 32211 6718 Oakwood Dr, Jacksonville, FL 32211 555 Woodford Dr, Debary, FL 32713 555 Woodford Dr, Debary, FL 32713 PO Box 130 Anadarko, OK 73005 PO Box 290187 Port Orange, FL 32129 5195 Montford Circle, Spring Hill, FL 34606 5195 Montford Circle, Spring Hill, FL 34606 5195 Montford Circle, Spring Hill, FL 34606 240 OldMaster Ct, Boiling Springs, SC 29316 240 OldMaster Ct, Boiling Springs, SC 29316 240 OldMaster Ct, Boiling Springs, SC 29316 240 OldMaster Ct, Boiling Springs, SC 29316 3570 Red Bluff Rd, Loris, SC 29569 241881 County Rd 121, Hilllard, FL 32046 241881 County Rd 121, Hilllard, FL 32046 241881 County Rd 121, Hilllard, FL 32046 PO Box 130 Anadarko, OK 73005 PO Box 130 Anadarko, OK 73005 PO Box 130 Anadarko, OK 73005 PO Box 130 Anadarko, OK 73005 4325 S Peninsula Drive, Ponce Inlet, FL 32127 4325 S Peninsula Drive, Ponce Inlet, FL 32127 4616 Four Lakes Rd, Melbourne, FL 32940 31 Sundunes Circle, Ponce Inlet, FL 32127
Red Black Gold Silver
White Black
Green White Red
Blue White Silver White Burgundy /Maroon Gray Gray Blue
Black White Red Red White Silver Black
31 Sundunes Circle, Ponce Inlet, FL 32127 31 Sundunes Circle, Ponce Inlet, FL 32127 31 Sundunes Circle, Ponce Inlet, FL 32127 31 Sundunes Circle, Ponce Inlet, FL 32127 31 Sundunes Circle, Ponce Inlet, FL 32127 31 Sundunes Circle, Ponce Inlet, FL 32127 31 Sundunes Circle, Ponce Inlet, FL 32127 31 Sundunes Circle, Ponce Inlet, FL 32127 31 Sundunes Circle, Ponce Inlet, FL 32127 31 Sundunes Circle, Ponce Inlet, FL 32127 31 Sundunes Circle, Ponce Inlet, FL 32127 31 Sundunes Circle, Ponce Inlet, FL 32127 31 Sundunes Circle, Ponce Inlet, FL 32127 31 Sundunes Circle, Ponce Inlet, FL 32127 809 Riviera Bella, Debary FL 32713 809 Riviera Bella, Debary FL 32713 809 Riviera Bella, Debary FL 32713 96 Rosehill Crescent Ct, Debary, FL 32713 96 Rosehill Crescent Ct, Debary, FL 32713 8513 Gracious Pine Ave Las Vegas, NV 4USBT53483LU01319 89143
SEIZURE AFFIDAVIT - ATTACHMENT 2 VEHICLE/VESSEL SEIZURE LIST Registered Owner Rowe, Conrad Rubino, Richard Rubino, Richard Ryles, Janis S Ryles, Michael Ryles, Michael Ryles, Michael Year 2008 1994 1999 2010 2000 1997 2002 Color Silver White Red Gray White White Black Make Chevrolet Ford Porsche Toyota Honda Vessel Chevrolet Cadillac 30.00' Welcraft Marine Corp Blue White Black White Gray Blue Chevrolet Chevrolet GMC Cadillac Chevrolet Toyota Westport Shipyard Black Black Black White Black Red Black Silver White Brown Black Mercedes-Benz Porsche Ferrari BMW Ferrari Chevrolet Jaguar 10.00' Yamaha Motor Corp USA Chevrolet Chevrolet Audi 31.00' Sea Ray Boats Inc 22.00' Chaparral Boats Inc 10.00' Yamaha Motor Corp USA Model Trailblazer Mustang Cobra 911 Carrera2/4 Highlander Odyssey EX Jetski Avalanche K1500 Escalade ESV Vessel Tahoe C1500 Suburban LTZ Denali Escalade Avalanche Corolla Yacht C300 911 Turbo F430 Spider Convertible X3 Xdrive 30I California Monte Carlo SS XJ l Supercharged Jetski G1500 Cargo Van Tahoe C1500 Q7 Prestige Cabin Motorboat Vessel Jetski State FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL FL None None Tag VIN/Hull # 1GNDS13S282219922 1FALP42D0RF198496 WP0AA2996XS625399 5TDYK3EH3AS023090 2HKRL1860YH564050 KAW53354L697 3GNEK13T42G123205 1GYS4KEF2CR106899 WELHHB17C606 1GNFC13058R207419 1GNUKKE32AR258275 1GKEK13R5XR910561 1GYS4EEJ8BR195690 3GNEC12078G170158 2T1BU4EE9DC971857 WPS07718D406 WDDGF54X19F204517 WP0AD29977S785671 ZFFEW59A470154249 WBXPC93439WJ25578 ZFF65LJA0A0174464 2G1WX12KXY9245053 SAJWA2GE2BMV03398 YAMA3867C010 1GBFG15T541219734 1GNFC13J47R186604 WA1VMAFE9DD006908 SERT7749K506 FGB80174G708 YAMA2134D010 Address 8513 Gracious Pine Ave Las Vegas, NV 89143 1534 Grace Lake Circle, Longwood, FL 32750 1534 Grace Lake Circle, Longwood, FL 32750 1355 Clearview Dr, Mannding, SC 291020000 1103 Cedar Bay Rd, Jacksonville, FL 1103 Cedar Bay Rd, Jacksonville, FL 1103 Cedar Bay Rd, Jacksonville, FL 1440 Dunn Ave Ste 5, Jacksonville, FL 32218 1440 Dunn Ave Ste 5, Jacksonville, FL 32218 3670 Reedpond Dr N, Jacksonville, Fl 32223 10411 Scott Mill Rd Jacksonville, FL 32257 10411 Scott Mill Rd Jacksonville, FL 32257 10411 Scott Mill Rd Jacksonville, FL 32257 231 Koolabrew Drive NW, Calabash, NC 28467 4470 Eastport Parkway, Port Orange FL 32127 201 Plaza Real Suite 140, Boca Raton, FL 33432 11120 Bridge House Rd, Windermere, FL 34786 11120 Bridge House Rd, Windermere, FL 34786 11120 Bridge House Rd, Windermere, FL 34786 11120 Bridge House Rd, Windermere, FL 34786 11120 Bridge House Rd Windermere, FL 34786 15348 Harvet Blvd, Clermont, FL 34714 15348 Harvet Blvd, Clermont, FL 34714 809 Riviera Bella, Debary FL 32713 809 Riviera Bella, Debary FL 32713 809 Riviera Bella, Debary FL 32713 809 Riviera Bella, Debary FL 32713 809 Riviera Bella, Debary FL 32713 809 Riviera Bella, Debary FL 32713 809 Riviera Bella, Debary FL 32713
Salloum, Mazen & M&S Management Services LLC 2012 Saloum, Mazen Saloum, Salim Saloum, Samer Saloum, Samer Saloum, Samer & Salloum, Zaher Skidmore, Brad T. Parker Management LLC True North Yacht Charter LLC Waheed, Aamir Waheed, Aamir Waheed, Aamir & Black, Cheri Waheed, Aamir & Shaham Waheed, Aamir & Waheed, Cheri Black Waheed, Tariq Waheed, Tariq Weaver, Brandon Weaver, Brandon & Cynthia Weaver, Cynthia Weaver, Cynthia Weaver, Cynthia Weaver, Cynthia Weaver, Cynthia 2006 2008 2010 1999 2011 2008 2013 2006 2009 2007 2007 2009 2010 2000 2011 2010 2004 2007 2013 2006 2008 2010
SEIZURE AFFIDAVIT - ATTACHMENT 3 REAL PROPERTY SEIZURE LIST Owner(s) Alascia, Anthony Alascia, Anthony Alascia, Anthony Alascia, Anthony & Susan Allied Veterans Center Inc Allied Veterans of the World Inc Allied Veterans of the World Inc & Affiliates Post #5 Inc Allied Veterans Property Management LLC Allied Veterans Property Management LLC Allied Veterans Property Management LLC Automated X-100 Services Inc Automated X-100 Services Inc Automated X-100 Services Inc Automated X-100 Services Inc Bass, Jerry W & Carolyn G Black, Christopher & Prince, Peggy A Developco Inc Developco Inc Developco Inc Developco Inc Developco Inc Developco Inc Developco Inc Developco Inc Developco Inc Developco Inc Developco Inc Developco Inc Developco Inc Developco Inc Developco Inc Developco Inc Developco Inc Developco Inc Hardee, Cary G Hessong, John M MNL Investments Inc MNL Investments Inc MNL Investments Inc MNL Investments Inc MNL Investments Inc County State Hernando FL Hernando FL Hernando FL Hernando FL Duval FL Duval FL Nassau FL Duval FL Duval FL Duval FL St Johns FL St Johns FL St Johns FL St Johns FL Duval FL Volusia FL Duval FL Flagler FL Orange FL Orange FL Orange FL Orange FL Orange FL Orange FL Orange FL Orange FL Orange FL Orange FL Orange FL Orange FL Orange FL Orange FL Orange FL Polk FL Volusia FL Nassau FL Duval FL Duval FL Duval FL Duval FL Duval FL 1 Address 7215 Clearwater Dr. Spring Hill, FL 2115 Founder Rd. Spring Hill, FL 5493 Pinehurst Dr. Spring Hill, FL 3272 Bluestone Ave. Spring Hill, FL 8130 Dandy Ave. Jacksonville, FL 2723 Hubbard St. Jacksonville, FL 542834 US HWY 1 Callahan, FL 1061 Cahoon Rd. Jacksonville, FL 2826 Water View Cir. Jacksonville, FL 3120 W 19th St. Jacksonville, FL 390 A1A Beach Blvd. #56 Saint Augustine, FL 390 A1A Beach Blvd. #61 Saint Augustine, FL 390 A1A Beach Blvd. #64 Saint Augustine, FL 1965 State Rd. 16 Saint Augustine, FL 6718 Oakwood Dr. Jacksonville, FL 2071 S Old Mill Dr. Deltona, FL 10166 Hunters Chase Ct. Jacksonville, FL 37 Cimmaron Dr. Palm Coast, FL 7721 Ficquette Rd. Windermere, FL 1980 Erving Cir. Unit #103 Ocoee, FL 6029 Westgate Dr. Unit #736 Orlando, FL 3337 Soho St. Unit #104 Orlando, FL 2295 S Hiawassee Rd. Unit #213 Orlando, FL 2295 S Hiawassee Rd. Unit #214 Orlando, FL 8112 Poinciana Blvd. Unit #1211 Orlando, FL 5524 Metrowest Blvd. Unit #10-112 12414 Baleria Cv Unit #112 Orlando, FL 12204 Wild Iris Way Unit #108 Orlando, FL 5206 Curry Ford Rd. Unit #114 Orlando, FL 1942 Conway Rd. Unit #5 Orlando, FL 9021 Lee Vista Blvd. Unit #1708 Orlando, FL 8925 Lee Vista Blvd. Unit #2707 Orlando, FL 13812 Magnolia Glen Cir. Orlando, FL 141 Melissa Pl. Davenport, FL 4803 S Atlantic Ave. Ponce Inlet, FL 241877 CR 121 Hilliard, FL 3620 Mimosa Dr. Jacksonville, FL 3531 Loretto Rd. Jacksonville, FL 4059 Piper Dr. Jacksonville, FL 5235 Hickson Rd. Jacksonville, FL 4228 Englewood Ave. Jacksonville, FL Parcel ID R32 323 17 5060 0259 0030 R32 323 17 5210 1428 0040 R32 323 17 5010 0001 0030 R32 323 17 5140 0916 0120 144495-0000 044705-0000 51-2N-25-0000-0016-0000 008690-0000 106167-0176 048729-0000 163011-0560 163011-0610 163011-0640 087620-0000 144894-0000 30-18-31-09-39-0030 002651-0675 07-11-31-7014-00040-0010 27-23-27-0000-00-020 21-22-28-0827-11-103 36-22-28-2857-07-360 01-23-28-3287-48-104 02-23-28-6124-00-213 02-23-28-6124-00-214 35-24-28-4356-01-211 06-23-29-6603-10-112 29-24-29-8824-01-112 29-24-29-8824-18-108 04-23-30-3265-00-114 05-23-30-5625-42-005 24-23-30-1256-01-708 24-23-30-1256-02-707 26-22-31-8996-00-720 27-27-08-727498-013010 30-16-34-00-02-0070 14-4N-23-0000-0016-0220 127583-0000 158101-0000 153771-0000 (changed) 135169-9018 127932-0000
SEIZURE AFFIDAVIT - ATTACHMENT 3 REAL PROPERTY SEIZURE LIST Owner(s) Prince, Bennie & Peggy A Prince, Bennie & Weaver, Cynthia Prince, Bennie & Weaver, Cynthia Prince, Peggy & Bennie James Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc County State Address Volusia FL 120 Elissar Dr. Debary, FL Volusia FL 809 Riviera Bella Way. Debary, FL Volusia FL 108 Elissar Dr. Debary, FL Volusia FL 110 Verde Way. Debary, FL Brevard FL 3299 S Babcock St. Melbourne, FL Charlotte FL 2421 Shreve St. #111, 112, 115, Punta Gurda, FL Escambia FL 154 Ethel Wingate Dr. #901 Pensacola, FL Lake FL Bella Collina Sub Lot 83 Lake FL Bella Collina Sub Lot 73 Lake FL Bell Collina Subdivision Lot 14 Lee FL 4528 E Riverside Dr. Fort Myers, FL Lee FL 4105 Residence Dr. #703 Fort Myers, FL Lee FL 2503 5th St. SW Lehigh Acres, FL Lee FL 5012 Baron St. Lehigh Acres, FL Lee FL 8362 Bamboo Rd. Fort Myers, FL Lee FL 1020 Diplomat Pkwy W. Cape Coral, FL Okaloosa FL 1040 Hwy 98 E. unit 1601 Destin, FL Orange FL Maguire Rd. Windermere, FL Polk FL 1206 Wahneta Court, Kissimmee (Lot 23 Remove) Polk FL 1209 James Lane, Poinciana, FL Polk FL 1238 James Lane, Poinciana, FL Polk FL 139 Athabasca Drive, Poinciana, FL Polk FL 179 Athabasca Drive, Poinciana, FL Polk FL 1952 Michigan Court, Kissimmee, FL Polk FL 2403 Rio Grande Valley Court, Poinciana, FL Polk FL 420 Athabasca Drive, Poinciana, FL Polk FL 696 James Court, Poinciana, FL Polk FL 818 Gila Way, Poinciana, FL Polk FL 824 Gila Way, Poinciana, FL Polk FL Rio Grande Ct Lot 14 Poinciana, FL Polk FL 438 Vernon Ct Poinciana, FL Polk FL 406 Caribbean Ct Poinciana, FL Polk FL 396 Aster Ct Poinciana, FL Polk FL 350 Elderberry Ct Poinciana, FL Polk FL 322 Gardenia Ct Poinciana, FL Polk FL 344 Gardenia Ct Poinciana, FL Polk FL 341 Hibiscus Dr Poinciana, FL Polk FL 324 Hibiscus Dr Poinciana, FL Polk FL Hibiscus Pl Lot 22 Poinciana, FL Polk FL 214 Hyacinth Ct Poinciana, FL Polk FL Fig Ct Lot 27 Poinciana, FL 2 Parcel ID 31-18-30-07-00-0560 31-18-30-09-00-1870 31-18-30-07-02-0500 31-18-30-09-00-1240 28-37-10-00-00501.0 412318127008 233S311104901001 12-22-26-050000008300 12-22-26-050000007300 12-22-26-050000001400 04-44-25-07-000M0.0070 36-44-24-P4-01907.0703 36-44-26-11-00107.002 21-44-26-05-00015.0180 16-46-25-07-00103.0720 03-44-23-C2-02884.0190 00-2S-22-4555-0000-1601 05-23-28-0000-00-017 28-27-33-934460-459230 28-28-15-935360-046150 28-28-15-935360-047070 28-28-15-935360-002300 28-28-15-935360-005040 28-28-03-934760-009020 28-28-15-935360-113120 28-28-15-935360-015040 28-28-15-935360-053100 28-28-15-935360-050040 28-28-15-935360-050050 28-27-33-934460-359140 28-27-33-934460-473040 28-27-33-934460-479150 28-28-10-935240-792130 28-28-10-935240-800230 28-28-10-935240-804110 28-28-10-935240-804270 28-28-10-935240-805380 28-28-10-935240-807180 28-28-10-935240-808220 28-28-10-935240-812080 28-28-10-935240-817270
SEIZURE AFFIDAVIT - ATTACHMENT 3 REAL PROPERTY SEIZURE LIST Owner(s) Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc County State Address Polk FL Lily LN Lot 15 Poinciana, FL Polk FL 219 Maple Dr Poinciana, FL Polk FL 1 Orchid Ln Poinciana, FL Polk FL 56 Orchid Ln Poinciana, FL Polk FL 64 Orchid Ln Poinciana, FL Polk FL 114 Violet Ct Poinciana, FL Polk FL 117 Violet Ct Poinciana, FL Polk FL 363 Hibiscus Dr Poinciana, FL Polk FL 107 Athabasca Dr Haines City, FL Polk FL Churchill Ct Lot 20 Haines City, FL Polk FL James Dr Lot 1 Haines City, FL Polk FL Gila Way Lot 15 Haines City, FL Polk FL Gila Dr Lot 23 Haines City, FL Polk FL James Ct Lot 6 Haines City, FL Polk FL James Ct Lot 4 Haines City, FL Polk FL James Ct Lot 7 Haines City, FL Polk FL 718 Colville PL Poinciana, FL Polk FL 926 Cumberland Dr Poinciana, FL Polk FL 2202 Pecos Ct Poinciana, FL Polk FL 1121 Platte Ln N Poinciana, FL Polk FL 1015 Sabine PL Poinciana, FL Volusia FL 521 Doverton Ln. Debary, FL Volusia FL 1931 Lavina St. Deltona, FL Walton FL Lot 22 Blk A Frangista Beach 3rd Addition Walton FL 127 Grayton Village Rd. Santa Rosa Beach, FL Walton FL Lot 8 Blk A Frangista Beach 3rd Addition PB 17 Walton FL Lot 17 Blk 23 Town of Santa Rosa PB 2 Walton FL 231 Somerset Bridge Rd #1408 Santa Rosa Beach Walton FL 231 Somerset Bridge Rd #1409 Santa Rosa Beach Charlotte FL 1450 Blanot Drive, Punta Gorda, FL Charlotte FL 1454 Blanot Drive, Punta Gorda, FL Charlotte FL 1458 Blanot Drive, Punta Gorda, FL Charlotte FL 1462 Blanot Drive, Punta Gorda, FL Charlotte FL 1466 Blanot Drive, Punta Gorda, FL Charlotte FL 1469 Madrono Drive, Punta Gorda, FL Charlotte FL 1470 Madrono Drive, Punta Gorda, FL Charlotte FL 1473 Madrono Drive, Punta Gorda, FL Charlotte FL 1474 Madrono Drive, Punta Gorda, FL Charlotte FL 1477 Madrono Drive, Punta Gorda, FL Charlotte FL 1478 Madrono Drive, Punta Gorda, FL Charlotte FL 1481 Madrono Drive,Punta Gorda, FL 3 Parcel ID 28-28-10-935240-838150 28-28-10-935240-841210 28-28-10-935240-847220 28-28-10-935240-849080 28-28-10-935240-849090 28-28-10-935240-858030 28-28-10-935240-859020 28-28-10-935240-861090 28-28-15-935360-002220 28-28-15-935360-041200 28-28-15-935360-044010 28-28-15-935360-051150 28-28-15-935360-052230 28-28-15-935360-053060 28-28-15-935360-054040 28-28-15-935360-054070 28-28-15-935360-077040 28-28-15-935360-080070 28-28-15-935360-109010 28-28-15-935360-125040 28-28-15-935360-127030 22-18-30-13-00-0400 30-18-31-13-08-0120 29-2S-21-42060-00A-0220 08-3S-19-25180-000-0241 29-2S-21-42060-00A-0080 22-2S-20-33120-023-0170 14-3S-19-25600-000-1408 14-3S-19-25600-000-1409 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001
SEIZURE AFFIDAVIT - ATTACHMENT 3 REAL PROPERTY SEIZURE LIST Owner(s) Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc Realtrack Inc & Harbco Development LLC Realtrack Inc & Harbco Development LLC Realvice Inc Realvice Inc Rowe, Conrad County State Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Charlotte FL Orange FL Orange FL Orange FL Orange FL Duval FL 4 Address 1482 Madrono Drive, Punta Gorda, FL 1485 Higdon Court, Punta Gorda, FL 1485 Madrono Drive, Punta Gorda, FL 1486 Higdon Court, Punta Gorda, FL 1486 Madrono Drive, Punta Gorda, FL 1489 Higdon Court, Punta Gorda, FL 1490 Higdon Court, Punta Gorda, FL 1493 Higdon Court, Punta Gorda, FL 1494 Higdon Court, Punta Gorda, FL 1497 Higdon Court, Punta Gorda, FL 1498 Higdon Court, Punta Gorda, FL 1501 Higdon Court, Punta Gorda, FL 1501 Tabby Court, Punta Gorda, FL 1502 Higdon Court, Punta Gorda, FL 1502 Tabby Court, Punta Gorda, FL 1505 Tabby Court, Punta Gorda, FL 1506 Tabby Court, Punta Gorda, FL 1509 Tabby Court, Punta Gorda, FL 1510 Tabby Court, Punta Gorda, FL 1513 Palsgrave Drive, Punta Gorda, FL 1513 Tabby Court, Punta Gorda, FL 1514 Tabby Court, Punta Gorda, FL 1517 Palsgrave Drive, Punta Gorda, FL 1517 Tabby Court, Punta Gorda, FL 1518 Tabby Court, Punta Gorda, FL 1521 Palsgrave Drive, Punta Gorda, FL 1525 Palsgrave Drive, Punta Gorda, FL 1529 Palsgrave Drive, Punta Gorda, FL 27218 Solomon Drive, Punta Gorda, FL 27234 Solomon Drive, Putna Gorda, FL 27250 Solomon Drive, Punta Gorda, FL 27266 Solomon Drive, Punta Gorda, FL 27282 Solomon Drive, Punta Gorda, FL 27298 Solomon Drive, Punta Gorda, FL 27312 Solomon Drive, Punta Gorda, FL 27328 Solomon Drive, Punta Gorda, FL 315 N Hampton Ave. Orlando, FL 10615 E Colonial Dr. Orlando, FL 7490 W Colonial Dr. Orlando, FL 2813 S Hiawassee Rd. Unit 103 Orlando, FL 1154 Mayport Landing Dr. Jacksonville, FL Parcel ID 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 402310386001 30-22-30-3314-00-070 17-22-31-8826-00-030 26-22-28-2138-00-010 02-23-28-3518-00-103 168441-0170
SEIZURE AFFIDAVIT - ATTACHMENT 3 REAL PROPERTY SEIZURE LIST Owner(s) Rowe, Conrad Rowe, Conrad Rowe, Conrad Rowe, Conrad Brian & Rowe, Conrad Harold & Gahagan, Shannon Rowe, Conrad H Waheed, Aamir Waheed, Aamir & Black, Cheri S Waheed, Aamir & Tariq County Duval Duval Duval Duval Duval Volusia Volusia Orange State FL FL FL FL FL FL FL FL Address 1216 Songbird Ln. Atlantic Beach, FL 1212 Songbird Ln. Atlantic Beach, FL 2926 Songbird Ln. Atlantic Beach, FL 791 Assisi Ln. #1006 Atlantic Beach, FL 1232 Mayport Landing Dr. Jacksonviile, FL 314 Alexandra Woods Dr. Debary, FL 571 Marina Point Dr. Daytona Beach, FL 1820 Anzle Ave. Winter Park, FL Parcel ID 168441-1154 168441-1156 168441-1180 169385-1136 168441-0136 26-18-30-08-03-0080 39-15-33-0D-01-5710 05-22-30-8504-06-121
ATTORNEYS
'.:.'f, ,
.,
AT LAW
;j
KELLYB:MATHis,
krnathi's@mathislaw:net
'ESQUIRE
,,1200 RIVERPLACE BLVD., SUITE 902 "< JACKSONviLLE 32207 '

. .' ' !.- .'~' -.,r.
,
FL
LAURIE M. LEE, ESQUIRE

lI~e@mathislaw.net
-: .. \
JAMES T. MURPHY, ESQUIRE

,jrnurphy@rnathislaw.net
TELEPHONE: FACSIMILE:
904/396-5500 904/396-5560
GUS A. MARTINEZ, ESQUIRE

grnartinez@rnathislaw.net
JILL F. BECHTOLD, ESQUIRE

j bechtold@rnathislaw.net
www.mathislaw.net
JASON R. HAWKINS, ESQUIRE

jhawkins@rnathislaw.net
ADAM F. REGAR, ESQUIRE

aregar@rnathislaw.net
February 24, 20lO
BRANDON S. RICHARDSON, ESQUIRE

brichardson@mathislaw.net
Brad-Skidmore Seaside Internet, LLC 231 Koolabrew Drive Calabash, NC 28467 RE: Dear Brad: New Policy for Affiliates # 34, #38, #43, #68
.-
.. ~:
The Affiliate locations of Allied Veterans <hci\i~.b~t.:;n experiencing an increasing number of complaints from landlords. The problems that have been complained of appear to be common among most Affiliates. Because this issuehasserious' consequences, there are some new policies outlined below. ' ,-, " , The most common complaint from landlords is that Allied Veterans is a nuisance to the other tenants. They complain about loitering, excessive trash around the premises, and numerous police reports from the Allied Veterans locations. There are also complaints about parking and crimes committed in the parking lots. These issues seem to be compounded when there are transient people in the area. Unfortunately, Allied Veterans' reputation statewide is affected by these kinds of problems. As always, Allied Veterans requires that all of its locations are clean and respectable businesses in the community. When a landlord has complaints about a location within the community, it affects our reputation in the community. After discussions with Johnny, Jerry and Kelly, the following is a plan of action for ALL locations to deal with present landlord problems and deter any future landlord problems: 1. Security. Hire security guards to be present during all operating hours from dusk until dawn. I Some locations, depending on the circumstances, may be required to hire security guards for longer periods of time.
Exceptions will be considered on a case-by-case basis and at the sole discretion of Allied Veterans.
February 24,2010 Page 2 If possible, use off-duty police officers. They are expensive and may be cost-prohibitive in some areas; however, their effectiveness is exceptional. It may be possible to use offduty police officers only during peak hours to limit the cost and use security guards from a company for the remainder of the open hours. Most of the contractors for Allied Veterans already use a security company. Please make sure the guards assigned to your location are effective in policing the area. Some security guards are more interested in socializing than confronting people. If you find that one of 'your security guards is not effective in controlling some of the problems, do not hesitate to. ask the security _company to send a replacement guard. The security guards are our front line in protecting ourselves against some of these problems and they need to be effective. The areas to be patrolled by the security guards will be determined by your lease and your landlord. Some of the locations will have security only inside the premises, while some of the locations are required to patrol the immediately surrounding areas outside of the premises. If you have questions about what areas to patrol, please give me a call and we can discuss your options. Your security company should be well informed about the responsibilities of its guards. Please communicate directly with the security company about your expectations and requirements for the guards assigned to your location. There should be no question that the security guard is under the "control" of the security company and is not your employee. 2. Trash. Hire employee(s) to be a "clean-up" crew to clean up the common areas surrounding the location every day. Empty the trash cans in front of the location, clean up the parking lot areas where your customers park, and sweep up the cigarette butts on the sidewalks. Trash seems to be a common complaint among landlords. Even though most of the locations pay Common Area Maintenance fees for the upkeep of the common areas, which includes trash removal, landlords are complaining that there is excessive trash and littering around our locations. Chip bags and bottles/cups are littering parking lots, etc. Common area trash cans are overflowing. Cigarette butts are littering walkways and parking lots. Even though it is technically the landlord's responsibility to maintain these common areas and keep them clean, we should make an extra effort to lessen the burden we are placing on landlords in this regard. Most businesses do not produce that amount of trash in the common areas. In an effort to maintain or create a good relationship with our landlords, and to promote our own image, we need to do our part to help keep the area clean and looking respectable.
--
February 24, 2010 Page 3 3. Smoking Areas. Designate a smoking area for your customers, and if possible, place signs stating "Designated Smoking Area" to show why people are congregating in that area. Provide a receptacle for cigarette butts in the smoking area. All smokers should be directed to the one designated area instead of allowing them to spread out among many areas. This will reduce the amount of people seen as "loitering" around our locations. A designated smoking area should be chosen with your neighboring tenants in mind. Please try to minimize the effect of our smokers on their businesses. If possible, make a designated smoking area on the side' of the building or in the back, away from other tenant visibility, and not directly in front of the location. It may even be possible to erect a gazebo or benches in an area (preferably designated by your landlord) for your smoking customers. The security guards would then be responsible for directing smokers to that location. Please stress to your security guards that smokers MUST be directed to the designated smoking areas, otherwise they appear to be loitering. 4. Loitering. Please do not tolerate people standing outside in front of the location. The security guards should also be respolli~~e for enforcing this rule. The most common complaint from landlords is about the number of people loitering in front of our businesses. This is the single most important factor in how the community views our business activities. People driving by or visiting neighboring businesses form their opinions of Allied Veterans based on what they see from the outside. If they see loitering of any kind, it reflects poorly on Allied Veterans. In addition to our reputation, loitering affects how safe people perceive our locations to be. If people would otherwise visit our location, but they are discouraged from doing so because of the people loitering out front, or they are afraid our location is not safe, you lose business. This problem is made worse if the loiterers are vocal in any way; comments, shouts, whistles, and catcalls can discourage customers and cause the public to perceive Allied Veterans as a "rough" place to visit. Your security guards need to make loitering one of their primary concerns. 5. Calling the Police. This is a difficult issue to address for many reasons. While there are certainly times when it is necessary to call law enforcement, "excessive" police calls to our locations can be held against Allied Veterans. There have been landlords who have used the number of police calls to our locations to show that we are a "nuisance" and a problem for our neighboring tenants. In many leases, it also states that we cannot conduct business that harms the reputation of the Shopping Center. Some landlords have taken the stance that repeated police reports of calls to the location harm the reputation of the Shopping Center.
February 24,2010 Page 4 Hopefully, the use of security guards during all open business hours can eliminate some of the need to call law enforcement for issues such as vagrants, trespassers, loitering and minor confrontations. Having said that, law enforcement officers should always be called for any situation that is serious and could pose a threat to the safety of our employees or customers. Please implement these new policies to be effective immediately. In addition, please notify me if you receive any notices or complaints from your landlord(s) and we can try to remedy the situation before it becomes a major issue. If you experience any difficulties or have any questions about these new policies, please do not hesitate to call. Sincere Regards,
~VV\.~
'-------LMLIbec Laurie M. Lee
REFER ALL QUESTIONS ABOUT ALLIED VETERANS OR HOW WE OPERATE FROM THE NEWS MEDIA INQUIZATIVE CUSTOMERS (IN PERSON OR BY PHONE) TO
1-904-396-5500
KELLY MATHIS OR LAURIE LEE
SILLC 68
QUIZ
NAME: ________________ DATE: ________________
1. What Product do we sell? How much does it cost? ________________________________________________ 2. What is the MAIN promotion customers get when they purchase internet time? ________________________________________________ 3. Does a customer have to purchase internet time to participate in our FREE promotion? ________________________________________________ 4. Name 2 of the other promotions we conduct here at Normandy #34. ________________________________________________ 5. In your own words write how you explain to a new customer what we do here. (This is very IMPORTANT) __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________
__________________________________________________ __________________________________________________ 6. If you have a customer ask to cash out their card at the front register, what is the correct response? ________________________________________________ 7. If you are working on the floor and overhear a customer talking to another customer saying they are betting $1.00, what should you do? ________________________________________________ ________________________________________________ 8. IF a customer is continually asking you the same question over and over again using negative words what do you do? ________________________________________________ ________________________________________________ 9. What are the correct words to use when a customer uses a negative word? Betting ______________________________ Gamble ______________________________ Cash Out ______________________________ 10. When do you NOT need to see proper ID at the front register? ______________________________________________
11.
When a NEW customer comes in, who should take the customer to the machine and explain the rules and operation of the sweepstakes? _______________________________________________ What are the cash management procedures? Do you know where to find a copy of these procedures if asked by the inspector? _______________________________________________ _______________________________________________ What are the necessary pieces of information needed to fill out a 1099? When does a 1099 need to be filled out? _______________________________________________ _______________________________________________ _______________________________________________ What requires redemptions to be placed on the winners list? _______________________________________________ What do you need to properly document the winners list redemption? _______________________________________________ If you are working as the BOX person and at the end of your shift your box is short, what are you supposed to do before you leave? _______________________________________________
12.
13.
14.
15.
16.
17. 18. 19.
What is the proper procedure for shift change on box? _______________________________________________ Should you leave big bills visible in your register? _______________________________________________ Do you like your job? (BE HONEST!) WHY/WHY NOT? _______________________________________________ _______________________________________________ _______________________________________________ _______________________________________________ _______________________________________________ _______________________________________________ _______________________________________________ _______________________________________________ _______________________________________________ _______________________________________________ _______________________________________________ _______________________________________________ _______________________________________________ _______________________________________________
19. Do you feel that there are things you could bring to the table to improve this location? __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________
__________________________________________________ __________________________________________________ __________________________________________________
20. What do you feel as a management team that Karen and I could do to improve this location? (BE HONEST!) __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________ __________________________________________________
STATE OF SOUTH CAROLINA COUNTY OF SUMTER
CASE NO. 2012-CV-43-10103773 IN THE MAGISTRATE'S COURT
SOUTH CAROLINA LAW ENFORCEMENT DIVISION, PLAINTIFF, VS. ORDER
RECfIVc.U
IJ SUMMARY .,OUHT 115 N. HARVI,~ .r. SUMTER COUi'HY SJUfH CAROLIN\
PALMETIO INTERNET CENTER AND JANICE RYLES, DEFENDANTS.
DAHla TIME
;~O IL3~
On July 12, 2012, in accordance with S.c. Code Ann. 12-21-2710 and 12-21-2712, seventy-two [72] computer hard drives and monitors, along with various other pieces of equipment, were seized by
the South Carolina Law Enforcement
Division and the Sumter County Sheriff's Office from the Palmetto On that date, this court
Internet Center located at 5664 Broad Street in Sumter, South Carolina. examined-the
machines and issued an order finding that the machines violated S.c. Code Ann. 12-21of the machines.
2710 and authorizing the seizure and destruction
The Defendants requested a post-seizure hearing, which was held on August 31, 2012. Attorneys Jared Q. Libet and Adam L. Whitsett appeared on behalf of the Plaintiff. with the South Carolina Attorney General's Office
Attorneys William Ceth Land, Reginald Lloyd and Kelly Mathes of
Jacksonville, Florida appeared on behalf of the Defendants.
At a post-seizure hearing, the burden of proof is on the owner of the machines to show why the seized property should not be forfeited S.c. 516, 719 S.E.2d 665 (2011). and destroyed.
Union County Sheriffs Office v. Henderson, 395
The sole issue before the court is whether the seized machines are contraband per se subject to seizure and destruction under s.c. Code Ann. 12-21-2710. Defendants argue that the machines seized
in this case are not contraband per se because (1) there is no slot on the machines in which is deposited a coin or thing of value; and (2) the machines are not gambling devices but are computers on which customers may purchase internet access with an accompanying promotional sweepstakes feature. under South
disagree and find that the machines are contraband per se, subjection to destruction Carolina law.
BACKGROUND/FACTS
Defendant contends that she is in the internet sales business, with the addition of printer, fax, and copy services, as well as the sale of office supplies such as paper, staples, pens and pencils. The business sells internet access time at the rate of twenty cents per minute. When a customer arrives for
the first time, he or she must fill out a New Customer Entry Form giving his name, address, and other contact information. In addition, the customer must acknowledge, among other things, "I understand
that I am not gambling," and "I understand that the sweepstakes entries are selected from a fixed pool of total entries at the time the internet access time is purchased. Entries that have been drawn prior to After
mine are no longer available at the time my entries are drawn and may limit the prizes available."
filling out the form, customers are given a PIN number to access their account at the computer terminal. Customers may purchase internet time from the cashier or may insert bills into a bill acceptor at a kiosk built into the wall.
When the customer purchases internet time, he or she is also given "credits" which he or she may use to "bet" on an assortment of thirty different casino-themed video games, including poker and
keno. When customers "win" they accumulate more credits which they may use to continue playing the games or which they may redeem for cash. The higher the bet, the higher the potential prize value. The
time in which the customer plays the games is not deducted from the internet time purchased.
According to Defendant's expert witness, the difference between these games and a traditional slot machine is that a traditional whether slot machine contains a random number generator which determines In Defendant's games, the outcome of each "hand" played is preoutcome in a pleasing way. Each level "wins." Furthermore, the outcome
or not the participant wins.
determined.
The video screen merely reflects the predetermined pool of predetermined
for each themed game uses an independent completely
relies on chance, and is in no way affected by the player's skill. If the player chooses, he may
reveal his sweepstakes entries using an "instant reveal" which would appear on the screen as a spreadsheet and would instantly reveal if any of his entries were winners.
LAW/ANALYSIS
Section 12-21-2710 prohibits several different
categories of gaming machines, stating:
It is unlawful for any person to keep on his premises or operate or permit to be kept on his premises or operated within this State any vending or slot machine, or any video game machine with a free play feature operated by a slot in which is deposited a coin or thing of value, or other device operated by a slot in which is deposited a coin or thing of value for the play of poker, blackjack, keno, lotto, bingo, or craps, or any machine or device licensed pursuant to section 12-21-2710 and used for gambling or any punch board, pull board, or other device pertaining to games of chance of whatever name or kind, including those machines, boards or other devices that display different pictures, words, or symbols, at different plays or different numbers, whether in words or figures or, which deposit tokens or coins at regular intervals or in varying numbers to the player or in the machine, but the provisions of this section do not extend to coin-operated nonpayout pin tables, in-line pin games, or to automatic as to give a certain weighing, measuring, musical, and vending machines which are constructed
uniform and fair return for each coin deposited and in which there is no element of chance. (emphasis added). It is undisputed that the machines at issue are not licensed pursuant to 12-21-2710.
Defendant first contends that the machines are not contraband per se because they do not have on each individual computer a physical slot in which to deposit a coin or thing of value. I find that the statute does not require the slot to be physically present on each computer. The seventy-two computer
monitors and hard-drives were all connected to a common server, and a customer could deposit money into a bill acceptor on the wall, or pay money directly to a cashier to receive credits at any of the computer terminals. I find that the point of sale register and bill acceptor are a direct extension of the machine and need not be physically present on each computer monitor to be in violation of the statute. The fact that the bill acceptor is mounted on the wall separate from the computer terminal is not dispositive. Both the bill acceptor and cash register are digitally or electronically connected to the
computer terminal.
Moreover, the fact that the machine is a standard computer monitor and hard drive rather than a traditional freestanding video poker machine does not remove the machines from the purview of 2112-2170. The South Carolina Supreme Court rejected a similar argument in State v. 192 Coin-Operated Video Game Machines, 338 S.c. 176, 525 S.E.2d 872 (2000). In that case, which involved traditional video poker machines, the Defendant argued that at the time the statute was enacted, slot machines were readily identifiable. However, "with the advent of the computer, a video game machine is simply a
box containing a computer which can be configured to playa variety of games, from poker to pac-man." Therefore, Defendant argued, the machine itself should not be considered illegal. The Supreme Court rejected this argument, and held the machines themselves were contraband per se, even when only held in storage.
Defendant next contends that the machines are not gambling devices, but are a means to access the internet, with an incidental sweepstakes feature to promote their internet sales business. I disagree. The real draw to the internet cafe appears to be the video games with a cash payout, rather
than the internet sales. In fact, wireless internet access is available for free at the McDonalds located in the same shopping plaza with Defendant's business. Internet access is also free at computer terminals logs of actual customers of
at the public libraries in Sumter. The State presented the computer Defendant's
business. Those records show many customers who spent enough funds in the machines to
accumulate more hours of internet access than they could use in a week. One customer left the business with 8.9 days of accumulated internet access (if used 24 hours per day, 7 days per week). internet access. These factors support the State's
Another customer purchased 20 days of continuous contention
that the real product for sale is video gambling.
Defendant also contends that the machines are not gambling devices within the meaning of 12-21-2710 because they are predetermined sweepstakes entries rather than traditional video poker
machines containing a random number generator.
The computer software loaded on the Defendant's
machines creates a finite number of sweepstakes entries. Within that universe of entries, the software designates particular entries as winning entries and assigns a cash value to each winning entry. The software then shuffles the universe of entries so that the winning entries are randomly distributed. When a customer purchases internet time or wins credits, his entries are already predetermined winners or losers. He may then play the casino-themed not effected by the player's skill. as
games to reveal those entries. The outcome is
It is important
to note that to the participant
or customer, the video games simulate the The player can
experience of traditional
video poker machines that contain random number generators.
choose to bet fewer or greater credits, each hand is revealed as a winner or loser, the player can accumulate credits with each winning hand, and the player may either redeem those credits for cash or use the credits to continue playing. traditional However, while the experience for the player is exactly the same as winning entries occur with the
video poker, there is no guarantee that the predetermined
same statistical degree of probability
as randomly generated numbers.
Moreover,
once the winning
entries have been paid out, they are no longer available to the next customer since there is a finite pool of winning entries. The next customer has no way of knowing whether or how many of the win ning entries have already paid out.
I find that the machines at issue here are similar to the phone card dispensers in Sunlight Prepaid Phonecard Co., Inc. v. State, 360 S.c. 49,600 S.E.2d 61 (2004). In Sunlight, a computer determined which game piece attached to which phone card would be a winner. randomly
The phone card roll before the
was then placed inside a dispenser.
As in this case, the winning cards were predetermined
customer "played" the machine and the prize was revealed in a gambling-themed
video screen. The
trial court found both the phone cards themselves and the phone card dispensers were illegal gambling devices, and the Supreme Court affirmed.
CONCLUSION
Based upon the foregoing, 2710, and are therefore
I find that the machines are in violation
of s.c. Code Ann. 12-21issued by
subject to destruction
pursuant to the previous Order of Destruction
this court on July 16, 2012.
AND IT IS SO ORDERED.
~~
Kristi F. Curtis, Chief Magistrate for Sumter County
October 5,2012
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Date Filed: 08/01/2012
IN THE UNITED STATES COURT OF APPEALS United States Court of Appeals FOR THE FIFTH CIRCUIT Fifth Circuit
FILED
August 1, 2012
No. 11-40265
Lyle W. Cayce Clerk
UNITED STATES OF AMERICA, PlaintiffAppellee v. DANIEL PATRICK DAVIS; PHILLIP DELL CLARK, DefendantsAppellants
Appeals from the United States District Court for the Eastern District of Texas
Before REAVLEY, PRADO, and OWEN, Circuit Judges. EDWARD C. PRADO, Circuit Judge: DefendantsAppellants Daniel Patrick Davis and Phillip Dell Clark were convicted of illegal gambling, conspiring to commit illegal gambling, and money laundering for their roles in a sweepstakes promotion at three Internet cafs in Texas. They challenge their convictions on a variety of grounds, but contend principally that there is insufficient evidence to support their convictions and that the district court erred in refusing to allow them to present a mistake-oflaw defense. The Government concedes that there is insufficient evidence to support their convictions for money laundering, which we now reverse; we affirm their other convictions.
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No. 11-40265 I. FACTUAL AND PROCEDURAL BACKGROUND A. The Statutory Framework Davis and Clark were charged with violating and conspiring to violate 18 U.S.C. 1955. Section 1955 makes it a federal crime to conduct, finance, manage, supervise, direct, or own all or part of an illegal gambling business, defined as a gambling business which (1) violates the law of the state in which it is conducted, (2) involves five or more persons who conduct, manage, supervise, direct, or own all or part of such business, and (3) continuously operates for a period of more than thirty days or has a gross revenue of $2,000 or more on any single day. The defendants concede the second two elements; the crux of their appeal is that the first element is not satisfied because their conduct did not violate Texas state law. The superseding indictment alleges that Davis and Clark operated electronic gambling devices in violation of three1 Texas state laws: gambling promotion, keeping a gambling place, and possessing a gambling device, equipment or paraphernalia. Tex. Penal Code Ann. 47.03, 47.04, 47.06. As relevant to the conduct involved here, a person is guilty of gambling promotion if the Government proves that he intentionally or knowingly operates or participates in the earnings of a gambling place or for gain, sets up or promotes any lottery or sells or offers to sell or knowingly possesses for transfer, or transfers any card, stub, ticket, check, or other device designed to serve as evidence of participation in any lottery. Id. 47.03(a)(1), (5). A person is guilty of keeping a gambling place if the Government proves that he uses or permits another to use as a gambling place any real estate, building, room, tent, vehicle, boat, or other property whatsoever owned by him or under his control, or rents
A fourth Texas state law is also listed on the indictmentcommunicating gambling information. Tex. Penal Code Ann. 47.05. The facts of this case do not support that crime and it was not charged to the jury.
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No. 11-40265 or lets any such property with a view or expectation that it be so used. Id. 47.04(a). A gambling place is any real estate, building, room, tent, vehicle, boat, or other property whatsoever, one of the uses of which is . . . the conducting of a lottery or the playing of gambling devices. Id. 47.01(3). A person is guilty of possession of gambling device, equipment, or paraphernalia if, with the intent to further gambling, he knowingly owns, manufactures, transfers, or possesses any gambling device that he knows is designed for gambling purposes or any equipment that he knows is designed as a subassembly or essential part of a gambling device or if, with the intent to further gambling, the person knowingly owns, manufactures, transfers commercially, or possesses gambling paraphernalia. Id. 47.06(a), (c). To obtain a conviction under any one of those Texas statutes, the Government would have to prove either that a gambling device or a lottery was involved. A gambling device is any electronic, electromechanical, or
mechanical contrivance . . . that for a consideration affords the player an opportunity to obtain anything of value, the award of which is determined solely or partially by chance, even though accompanied by some skill, whether or not the prize is automatically paid by the contrivance. Id. 47.01(4) (emphasis added). A lottery requires: (a) A prize or prizes[;] (b) the award or distribution of the prize or prizes by chance; [and] (c) the payment either directly or indirectly by the participants of a consideration for the right or privilege of participating. Brice v. State, 242 S.W.2d 433, 434 (Tex. Crim. App. 1951) (internal quotation marks omitted) (emphasis added). Therefore, in order to convict Davis or Clark the Government had to prove the existence of some consideration exchanged for the privilege of playing the sweepstakes. The sole issue in each of the defendants insufficiency challenges is whether such consideration was proved.
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No. 11-40265 B. The Sweepstakes Mechanics In addition to providing Internet access and word processing, faxing, and copying services, each of the three Internet cafs involved in this casethe Dolphin in Port Arthur, Texas; the Double Click in Henderson, Texas; and the Nederland in Nederland, Texasoffered a sweepstakes promotion that allowed customers to win cash prizes. The sweepstakes ran on computer software that, at the outset, created a finite number of entries. Within that universe of entries, the software designated particular entries as winning entries, and assigned a cash value to each winning entry. The software then shuffled the universe of entries so that the winning entries were randomly distributed. There were three ways for sweepstakes participants to acquire entries. First, by purchasing Internet time at one of the cafs; each dollar of Internet time purchased came with 100 entries. Second, by requesting entries in person at the caf, up to 100 entries a day. Or third, by requesting entries by mail, also up to 100 entries a day.2 After obtaining entries, participants could choose among three ways to find out if their entries were winners; the method chosen did not affect whether a particular entry was a winner or a loser because, as noted earlier, whether it was a winner or a loser was predetermined by the computer software. First, participants could ask the clerk who sold them Internet time to instantly reveal whether any of their entries were winners and if so, what their total winnings were. Second, participants could swipe at a computer terminal the card issued by the cafs that electronically stored Internet time and entries, and then choose reveal or quick win on the screen. That option would, like the instant reveal, immediately tell the participant whether or not the entries were winners, and if so, for how much.
Although it was undisputed that entries could be requested by mail, the posters advertising free entries by mail did not include a mailing address.
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No. 11-40265 Third, participants could reveal whether their entries were winners by playing a variety of casino-like games available on each computer terminal. For example, one game available looked like a video slot machine. Clicking reveal caused the reels to rotate and stop, revealing whether or not the played entries were winners, and for how much. Each time reveal was clicked, twenty-five entries were played. Winnings were displayed on the screen, and the participant could cash out those winnings in two ways. The participant could go to a clerk and receive cash, or the participant could use the winnings to purchase more Internet time at a computer terminal. The purchase of Internet time, as before, came with entries100 for each dollar of Internet time. Playing the entries on the computer terminals did not reduce the amount of Internet time available to the participant. After playing the sweepstakes on the computer terminals, participants received a receipt listing any winnings from their entries and Net Time. Nick Farley, an expert called by the defendants co-defendant Cecil Stephens, testified that he believe[d] the number following Net Time was the amount of Internet time remaining. One receipt entered into evidence listed Net Time, 356,397; another listed Net Time, 356,400. When asked if that was the number of minutes of Internet time remaining on that customers account, Farley responded Probably, yes. C. Police Investigations 1. The Dolphin Because of complaints that people had been gambling and losing large sums of money at the Dolphin, Port Arthur Police Officers Shawn Perron and Chris Billiot, while undercover, visited the Dolphin. The Dolphins windows were tinted and a sign outside the buildingwhich was part of a stripcenteradvertised the business as Dolphin Internet. Upon entering, Perron saw several tables containing five or six computers each, a main counter, an area with food, and another room containing about fifteen computers. He observed 5
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No. 11-40265 several people at the computers playing what appeared to be eight-liner or electronic slot machine games. Nobody in the Dolphin was using the computers to do anything but play the sweepstakes. Perron was asked for his
identification, signed some sort of a ledger or a membership type ledger, and was given a card with a magnetic strip. He purchased $20 of Internet time and won $37 playing the sweepstakes. He went back to the Dolphin later that day, purchased $40 of Internet time, and won $117 playing the sweepstakes. A month later he visited again, purchasing $40 of Internet time and winning $233. He made a fourth visit about two months after his third, purchased $20 of Internet time, and won $15 playing the sweepstakes. Billiot testified3 that when he visited the Dolphin, he was issued a card that he took to a machine that worked like a reverse ATM machine in which he put money, swiped his card, and sat down to play the sweepstakes. He stated that in his recollection, when you go into the sweepstakes to a game, it converts those minutes into a cash value to where you can play these different type machines . . . like slot machines. Unlike Perron, Billiot did not win anything while playing the sweepstakes. Billiot testified that in his recollection, once he had used up all of his entries, he could not go back to surf the Internet. He admitted during cross-examination, however, that he did not ask a Dolphin
Davis and Clark argue that some of the testimony by uniformed police officers was prejudicial because the officers made conclusions of law by referring to the computers in the defendants cafs as gambling devices. The district court cautioned the jury three timesonce before the start of trial, once during a police officers testimony, and once during its chargethat calling a device a gambling device is not itself evidence that the machine is in fact a gambling device, and that [t]he government must prove to your satisfaction that the activity is gambling or that the equipment possessed is a gambling device by credible evidence about and beyond the characterization of the activity or equipment by simply calling it a particular name. The repeated cautionary instructions by the district court rendered harmless any improper opinion testimony offered by the police officers. See United States v. Gutierrez-Farias, 294 F.3d 657, 663 (5th Cir. 2002).
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No. 11-40265 clerk for assistance, and it was possible that all of his Internet time was still available. 2. The Nederland Based on information that an illegal gambling business was being conducted at the Nederland, Nederland Police Department Officer Casey Maxwell visited the Nederland while undercover. Like the Dolphin, the
Nederland was located in a strip-mall. Upon entering, Maxwell was asked to sign a piece of paper stating that he was not gambling, he was buying Internet time and playing a sweepstakes. He was handed a credit card looking card which was loaded with $5 free because it was his first visit, led to one of the computer terminals, offered free food, and shown how to access the sweepstakes games. There were about twelve other people sitting at computers, all playing the sweepstakes. Maxwell bought $40 of Internet time, played the sweepstakes, and did not win any money. After using all of his entries, he testified that he couldnt do anything else on the computer, but when asked if he had tried, he said, No. Maxwell visited the Nederland again about a week later. He noticed signs saying Win Cash Prizes and All of Your Favorite Games. Maxwell purchased $40 of Internet time from an ATM-like terminal and played the sweepstakes without success. He purchased another $40 of Internet time and this time won about $640. Maxwell stated that as he played the sweepstakes and won, the entries displayed on the screen continuously went down, and the money he won was displayed in a different box on the screen. He approached a clerk to cash out and was told that because he won more than $500 he had to give the clerk his drivers license and social security numbers to file with the IRS. Maxwell asked if he could continue to play his winnings, was told yes, played the winnings down to $599, then cashed out and received $599 in cash.
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No. 11-40265 3. The Double Click There was no testimony by police officers regarding their investigation into the Double Click. Delores Ridens, the manager of the Double Click, testified as a cooperating witness. She estimated that Double Click customers actually used a little less than $100 worth of Internet time each week. That amount was dwarfed by the $27,770 in Internet time sales during a representative week. D. Charges and Trial After these investigations by local police, a federal grand jury indicted the defendants, along with five others,4 in a nine-count superseding indictment. Davis and Clark were each charged with one count of conspiring to conduct, finance, manage, supervise and direct an illegal gambling business, said illegal gambling business involving the operation of electronic gambling devices in violation of 18 U.S.C. 371 and 1955. In addition to that conspiracy charge, Davis was charged with three counts of illegal gambling in violation of 18 U.S.C. 1955 and two counts of money laundering in violation of 18 U.S.C. 1957. Clark was charged with two counts of illegal gambling and two counts of money laundering. Throughout the trial, Davis and Clark each maintained that they were entitled to present a mistake-of-law affirmative defense. After holding a
hearing, at which both defendants testified, the district court denied the defendants request in a oral order read into the record. At the end of the Governments case, Davis and Clark each moved for a judgment of acquittal. The district court denied those motions. Davis testified,
The others charged in the superseding indictment were: Cecil Stephens, a part owner of the Double Click, who was tried with Davis and Clark but is not part of this appeal; Virginia Slaughter, manager of the Dolphin, who testified as a cooperating witness; Amirali Azim Sumar, a part owner of the Nederland, who testified as a cooperating witness; Mukhtiar Khuwaja, Sumars brother-in-law and a clerk at the Nederland; and Delores Gail Ridens, the Double Clicks manager, who testified as a cooperating witness.
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No. 11-40265 called a witness on his behalf, and elicited testimony from Nick Farley, the expert called by his co-defendant Cecil Stephens, in an attempt to bolster Farleys credibility. Clark did not testify or call any witnesses, but he questioned Davis, elicited favorable testimony from Farley, and referred to Farleys testimony during summation. Neither Davis nor Clark renewed his motion for judgment of acquittal at the close of all the evidence. The jury returned a verdict, finding each defendant guilty on multiple counts. Davis was convicted of conspiracy to commit illegal gambling, two counts of illegal gambling, and two counts of money laundering. Clark was convicted of conspiracy to commit illegal gambling, two counts of illegal gambling, and two counts of money laundering. Davis was sentenced to a year and a day of imprisonment, which was below the applicable Guidelines range of 1824 months. Clark was sentenced to two years of probation, which was also below the applicable Guidelines range of 2430 months. The defendants timely appealed, invoking our jurisdiction under 28 U.S.C. 1291. II. DISCUSSION As stated previously, Davis and Clark principally contend that there is insufficient evidence to sustain their convictions for illegal gambling (and conspiracy to commit illegal gambling) because their conduct did not violate Texas state law. Further, the defendants argue that the district court erred in refusing to allow them to put on a mistake-of-law defense. A. Sufficiency of the Evidence5 1. Standard of Review We review properly preserved claims that a defendant was convicted on insufficient evidence with substantial deference to the jury verdict, asking only
As an initial matter, the Government concedes that the evidence was insufficient to support the defendants money laundering convictions, and agrees that those convictions must be reversed. We therefore reverse these convictions.
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No. 11-40265 whether a rational jury could have found each essential element of the offense beyond a reasonable doubt. United States v. Delgado, 672 F.3d 320, 330 (5th Cir. 2012) (en banc) (internal quotation marks omitted). However, where a defendant moves for a judgment of acquittal at the end of the Governments case but, after presenting evidence, fails to renew that motion, the defendant has forfeited his insufficiency challenge and our review is for a manifest miscarriage of justice.6 United States v. Salazar, 542 F.3d 139, 142 (5th Cir. 2008). Because Davis failed to renew his motion for a judgment of acquittal after he testified, we review his insufficiency claim for a manifest miscarriage of justice. A manifest miscarriage of justice exists only if the record is devoid of evidence pointing to guilt, or because the evidence on a key element of the offense is so tenuous that a conviction would be shocking. United States v. McDowell, 498 F.3d 308, 312 (5th Cir. 2007) (internal quotation marks and ellipses omitted). We consider the evidence in the light most favorable to the government, giving the government the benefit of all reasonable inferences and credibility choices. Id. (internal quotation marks omitted). The proper standard of review for Clarks claim is a closer question. Clark did not testify or call any witnesses, but he questioned Davis and elicited favorable testimony from Farley, which he referred to during closing arguments. Had Clark not questioned Davis or elicited testimony from Farley, he would not have needed to renew his motion for a judgment of acquittal at the end of all the evidence merely because his co-defendant testified. United States v. Arias-Diaz, 497 F.2d 165, 16869 (5th Cir. 1974). If we were to determine that Clark functionally presented evidence by questioning Davis and Farley, he too would
We have recently explained that forfeited insufficiency claims are reviewed, like other forfeited claims, by employing the usual four-prong plain error test. United States v. Delgado, 672 F.3d 320, 33031 (5th Cir. 2012) (en banc). [T]he manifest miscarriage of justice formulation is itself a reasonable restatement of the four-prong test. Id. at 332 n.9.
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No. 11-40265 have forfeited his insufficiency claim by failing to renew his motion for a judgment of acquittal at the end of all the evidence. We need not reach this question because we would affirm Clarks convictions under either the manifest miscarriage of justice standard or the more lenient standard we apply to preserved insufficiency claims. 2. Analysis As noted above, both Daviss and Clarks insufficiency challenges turn on whether or not there was evidence that sweepstakes participants exchanged some consideration for the privilege of playing the sweepstakes. The defendants argue that consideration in this context means paying money in exchange for playing. They maintain that the record does not contain any evidence that sweepstakes participants did, or even could, pay to play the sweepstakes. Participants either received a limited number of sweepstakes entries each day without purchasing Internet time, or received entries free with the purchase of Internet timesuch Internet time, the Government concedes, was sold at fair market value.7 The defendants are correct that consideration exists if sweepstakes participants must pay money for the privilege of playing or if participants who pay have better chances of winning than non-paying participants. In Cole v. State, for example, the Texas Court of Criminal Appeals affirmed the conviction of a theater owner who randomly picked a name from a pool of names that did
Davis argues that the district court erred by excluding his expert, Thomas Fricke, who he claims would have testified that the Internet time sold at the cafs had real value and was sold at the market rate. As the Government concedes, there was testimony at trial supporting the fact that the cafs sold Internet time at competitive prices. The district court excluded Fricke because his testimony amounted to his opinion that the operation conducted by Defendants resembled others in the national gaming industry which was irrelevant to the inquiry of whether this operation complied with Texas law. We cannot say that the district court abused its discretion, MCI Commcns Servs., Inc. v. Hagan, 641 F.3d 112, 118 (5th Cir. 2011), in excluding Frickes largely irrelevant testimony, especially where the single fact Davis argues Fricke would have told the jury was not contested by the Government.
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No. 11-40265 not require payment to enter, but the theater owner limited the amount of time in which the winner could claim her prize to such an extent that, in all practicality, the only people who could win were those paying customers in the theater. 112 S.W.2d 725, 72727, 730 (Tex. Crim. App. 1937). The court in Brice v. State distinguished Cole in overturning the conviction of a store owner who gave away prizes during the three-day opening of his store by randomly drawing a registration card out of the thousands submitted in person each day by participants who were not required to buy anything or pay money. 242 S.W.2d 433, 434 (Tex. Crim. App. 1951). The Brice court reasoned: [I]n the absence of any character of favoritism shown to customers, the [gambling statute] is not violated under a plan whereby a merchant awards a prize or prizes by chance to a registrant without requiring any registrant to be a customer or to purchase merchandise or to do other than to register without charge at the store, though the donor may receive a benefit from the drawing in the way of advertising. Id. A more recent case with facts similar to those in this case also informs the scope of consideration. Jesters store contained machines that, when a dollar was inserted, dispensed a three minute pre-paid telephone card and displayed 100 credits. Jester v. State, 64 S.W.3d 553, 55455 (Tex. App.Texarkana 2001, no pet.). The credits could be used to play a game on the machines through which it was possible to win more credits, which in turn were redeemable for gift certificates. Id. at 555. It was also possible to play for free (to a limit of 100 credits a day) by mailing a request form, receiving a certificate in the mail, and showing the certificate to the clerk at the store. Id. Jester argued that the scheme did not constitute a lottery, but was instead a legal sweepstakes because consideration was lackingthe customers either put in a dollar and received a phone card or played for free. Id. at 55657.
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No. 11-40265 The court stated that consideration regarding lotteries should be measured by the same rule as in contracts, id. at 557, and determined on the facts presented that a reasonable jury could have found the presence of consideration beyond a reasonable doubt, id. at 558. The court explained that its decision turned on whether the sweepstakes was intended to promote the sale of telephone cards or whether the telephone cards were there as an attempt to legitimize an illegal gambling device. Id. Driving the courts finding that the telephone cards were an attempt to legitimize an illegal gambling device, and that therefore the consideration requirement was satisfied, were the following facts: the telephone cards cost much more per minute than the market cost of telephone time; there was testimony that the telephone cards did not work; there was evidence that players did not value the telephone cards, and that some players did not know they even were telephone cards; there was testimony that the employees were aware that the customers did not value the telephone cards; there were no signs on the outside of the building advertising or indicating that telephone cards were sold at the store; and no employee tried to sell customers on the telephone cards. Id. The court concluded: The evidence in this case was legally sufficient for the jury to infer that the main purpose and function of the machines, and the business, was to induce people to play the game, agreeing to gain or lose something of value at least partially by chance, and not to promote telephone cards; that it was Jesters intent to structure the business to entice players to exchange money for chances to play, which they did; and that the telephone cards were not the primary subject of the transaction, but mere subterfuge. Although testimony was provided regarding the redemption of the free games and the telephone card minutes, as well as the higher market price for smaller denominated telephone cards and Jesters intention to promote the telephone cards, the jurys determination was not so contrary to the overwhelming weight of the evidence as
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No. 11-40265 to be clearly wrong and unjust, and therefore, the evidence was factually sufficient as well. Id. at 55859. As the Jester courts reasoning shows, the consideration element in the Texas gambling statutes can be fulfilled without an explicit exchange of money for the opportunity to participate in a sweepstakes. We therefore reject the defendants argument that consideration is limited to the exchange of money for the privilege of participating.8 Here, as in Jester, there is legally sufficient evidence from which a reasonable fact-finder could infer that the sale of Internet time at the defendants cafs was an attempt to legitimize an illegal lottery. Customers receipts indicating over 300,000 minutes of Internet time remaining were evidence that the customers did not value the Internet time they had purchased. Further evidence that customers did not value their Internet time was the investigating police officers uniform testimony that during each of their visits to a caf, all of the people there were only engaged in playing the sweepstakes not accessing the Internet or using any of the other services provided. In addition to the customers apparent disregard for the value of Internet time, there was evidence which casts doubt upon the defendants claim that they intended to be legitimate, full-service Internet, faxing, copying, and wordprocessing vendors. For example, the manager of the Nederland testified that Davis said that he was not worried about the roughly $400 every two months in revenue from services other than Internet time and simply told the manager
We similarly reject Daviss argument that the district court erred by giving an instruction on consideration that was too broad. Davis asked for an instruction stating that: Consideration means the payment of money for a chance to win a prize. Restricting consideration only to money conflicts with Jesters broader conception of consideration; therefore, the district court did not abuse its discretion by rejecting Daviss proffered instruction. See United States v. Wright, 634 F.3d 770, 775 (5th Cir. 2011). We also reject Daviss argument that the district court erred in rejecting his proffered instruction on sweepstakes because his proffered instruction did not apply to the facts of this case, where the prizes were less than $50,000. See Tex. Bus. & Com. Code Ann. 622.051(a), 622.052(a).
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No. 11-40265 to keep it. The defendants focus on income from the sale of Internet time to the exclusion of income derived from other services offered by the cafs could reasonably raise the inference that the defendants offered the other services merely as an attempt to make it appear that their sale of Internet time was part of a full-service business, instead of a mechanism for legitimizing unlawful activity. Further evidence that the defendants true purpose for the cafs was to create a place where people would be comfortable staying for a long time, purchasing Internet time and playing the sweepstakes, was the casino-like atmosphere at the cafs, complete with tinted windows and free food and drink. Finally, it is reasonable to infer that Daviss and Clarks purpose for the cafs was to legitimize illegal gambling from the fact that caf customers were required to sign a form stating that they were not gambling upon entering at least one of the cafs; legitimate businesses ordinarily do not require such formalities. Reviewing all facts and inferences in the light most favorable to the jurys verdict, we conclude similarly to the Jester court that the main purpose and function of Daviss and Clarks Internet cafs was to induce people to play the sweepstakes, and that the Internet time sold by the cafsalbeit at fair market valuewas not the primary subject of the transaction, but instead mere subterfuge.9 We therefore determine a reasonable trier of fact could conclude that consideration was established beyond a reasonable doubt, and affirm
Clark argues, as part of his insufficiency challenge, that the Government failed to prove the mens rea required in each of his two illegal gambling convictions. In Long v. State, 236 S.W.3d 220, 225 (Tex. App.Tyler 2007, pet. refd), the court held that to be guilty under the Texas gambling laws, a defendant must intentionally or knowingly operate or participate in the earnings of a gambling place. Proof of a culpable mental state almost invariably depends upon circumstantial evidence. Id. There is sufficient circumstantial evidence that Clark intentionally participated in the earnings of the cafs: he was the signatory on the account at Bank of America for the Spring Creek Cattle Company, which held money from the Dolphin and the Nederland, he signed payroll checks for the Double Click, and he signed the lease for the Dolphins building.
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No. 11-40265 Daviss and Clarks convictions for illegal gambling and conspiring to commit illegal gambling. B. Mistake-of-Law Defense The defendants maintained throughout the proceedings below that they were entitled to raise a mistake-of-law affirmative defense. The district court held a hearing on this issue and issued a thorough oral ruling preventing the defendants from raising the defense. Whether a defendant should have been allowed to present an affirmative defense is a legal issue that we review de novo. United States v. Sariles, 645 F.3d 315, 317 (5th Cir. 2011). In general, under both federal and Texas state law, ignorance of the law is not a defense. See, e.g., Ratzlaf v. United States, 510 U.S. 135, 149 (1994); Tex. Penal Code Ann. 8.03(a) (It is no defense to prosecution that the actor was ignorant of the provisions of any law after the law has taken effect.). Under federal law, a mistake-of-law defense may be allowed only where the crime charged is a specific intent crime. Cf. United States v. Whaley, 577 F.3d 254, 262 n.6 (5th Cir. 2009); see also United States v. Schultz, 333 F.3d 393, 41011 (2d Cir. 2003). As correctly noted by the district court in its oral ruling, 18 U.S.C. 1955 is not a specific intent crime, see United States v. Hawes, 529 F.2d 472, 481 (5th Cir. 1976), nor do the underlying Texas gambling laws require specific intent, see Legere v. State, 82 S.W.3d 105, 109 (Tex. App.San Antonio 2002, pet. refd). As for the conspiracy charge, [t]he government must prove the same degree of criminal intent as is necessary for proof of the underlying substantive offense. United States v. Dadi, 235 F.3d 945, 950 (5th Cir. 2000). Because neither 18 U.S.C. 1955 nor the relevant Texas gambling laws require specific intent, the conspiracy charged here also does not require specific intent. Consequently, a federal mistake-of-law defense is unavailable to the defendants.
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No. 11-40265 Davis and Clark argue that in this sort of hybrid prosecution, where federal law borrows state substantive law, defendants should be able to raise a mistake-of-law defense that is rooted in state law. Texas allows an affirmative defense where: the actor reasonably believed the conduct charged did not constitute a crime and that he acted in reasonable reliance upon: (1) an official statement of the law contained in a written order or grant of permission by an administrative agency charged by law with responsibility for interpreting the law in question; or (2) a written interpretation of the law contained in an opinion of a court of record or made by a public official charged by law with responsibility for interpreting the law in question. Tex. Penal Code Ann. 8.03(b)(1)(2). The Government argues that this defense should not be available to the defendants, who were prosecuted for violating federal law, not state law. Even assuming that the defendants were entitled to present their Texas state-law mistake-of-law defense, we find that the district court was correct to reject it.10 Davis claims to have reasonably relied upon a variety of official statements of the law and written interpretations of the law. Clark claims to have relied upon a single judicial opinion. First, Davis claims to have read five or six Texas Attorney General (AG) opinions, and to have relied upon three.11 We agree with the district court that Daviss reliance on those AG opinions was not reasonable because, as noted by the district court, he ignored more recent
In a somewhat analogous case, we rejected defendants argument that they may raise in a federal prosecution an affirmative defense rooted in state law. See Sariles, 645 F.3d 315, 318 n.2 ([E]ntrapment by estoppel requires a defendant charged with a federal crime to show the actual authority of a government official to render the advice about federal law.); see also United States v. Ormsby, 252 F.3d 844, 851 (6th Cir. 2001) (holding that a defendant in a 1955 case cannot rely on official statements by state officials in pressing an entrapment by estoppel defense because state officials have no authority to interpret federal law).
11 10
There is no record of which opinions he read and did not rely upon.
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No. 11-40265 and more factually analogous opinions that would support a conclusion that his conduct was illegal. Next, Davis claims that he relied upon three cases: G2, Inc. v. Midwest Gaming, Inc., 485 F. Supp. 2d 757 (W.D. Tex. 2007); Brice; and In re $1,189.51 U.S. Currency, No. 2009-01-160A (107th Dist. Ct., Cameron County, Tex. Apr 24, 2009). The Texas mistake-of-law defense was not created to allow a criminal defendant to rely upon old interpretive opinions, opinions that conflict with others, or on overruled opinions. Green v. State, 829 S.W.2d 222, 223 (Tex. Crim. App. 1992) (en banc) (internal quotation marks omitted). Daviss reliance on G2 was not reasonable because its discussion of the gambling statutes followed immediately after the court had determined that it lacked jurisdiction. G2, 485 F. Supp. 2d at 766. Clark only claims to have relied upon G2; for the same reason as for Davis, Clarks reliance on G2 was not reasonable. Daviss reliance on Brice was not reasonable because the language in it that is most helpful to Davis conflicts with language in Jestera much more recent decision. Finally, Daviss reliance on In re $1,189.51 was not reasonable because the court there did not actually rule on the schemes illegality, as the parties had stipulated to its illegality for the purpose of civil forfeiture. We further agree with the district court that Daviss claimed reliance on the texts of the Texas Sweepstakes Act, Tex. Bus. & Com. Code Ann. 622.001 et seq., and the Texas Gambling Act, Tex. Penal Code Ann. 47.01 et seq., was not reasonable because the texts of statutes are not an official statement of the law . . . by an administrative agency charged with responsibility for interpreting the law or a written interpretation of the law as required by 8.03(b). Lastly, we agree with the district court that Daviss claimed reliance on a letter opinion by the Texas Alcoholic Beverage Commission regarding a different sweepstakes was not reasonable because it was not factually analogous to the facts here. We therefore conclude that the district court did not err in preventing Davis and Clark from putting on a mistake-of-law defense because they did not 18
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No. 11-40265 reasonably rely on any official statements or written interpretations as required by 8.03(b). VI. CONCLUSION For the foregoing reasons, we affirm Daviss and Clarks convictions for illegal gambling and conspiracy to commit illegal gambling; reverse Daviss and Clarks convictions for money laundering; and remand to the district court for resentencing and a forfeiture redetermination. AFFIRMED in part; REVERSED in part; and REMANDED.
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STATE OF FLORIDA COUNTY OF SEMINOLE SEIZURE AFFIDAVIT Your affiant, Captain James Sammy Gibson being duly sworn

Account Name Affiliate 78 Affiliate 79 Affiliate 81 Affiliate 85 Affiliate 86

Chart 2: Gambling Proceeds Withdrawn from Affiliate Accounts

*The 2012 column reflects transactions on Jan. 5, 2012 only

deposited into Bank of America checking account

deposited into Bank of America checking account

deposited into Bank of America checking account

deposited into Bank of America checking account

deposited into this account.

gambling proceeds. million dollars. 24.

On March 31, 2012 the balance in the account was $2,519,987.65

deposited into Bank of America checking account

deposited into Bank of America checking account

deposited into Bank of America checking account

deposited into Bank of America checking account

deposited into this account.

deposited into Bank of America checking account

deposited into Bank of America checking account

deposited into Bank of America checking account

deposited into Bank of America checking account

deposited into Bank of America checking account

appears to be gambling proceeds directly from the AVOTW gambling centers.

was deposited into the aforementioned account.

listed as the signors on the account.

The account was opened in Oklahoma. The contact

amounts of commingled proceeds into this account.

deposited into Midfirst Bank checking account

Additional $3.9 million in deposits from previously purchase Certificates of Deposits

Seven deposits totaling $23.4 million dollars Bank of America account

directly or indirectly from AVOTW and/or the Affiliates.

As of January 2013, the balance in this account is $10,483.49. Because this

As of January 2013, the balance in this account is $14,503.03. Because this

As of January 2013, the balance in this account is $4,064.36. Because this

As of January 2013, the balance in this account is $6,084.00. Because this

As of February 29, 2012 this account had a balance of $45,182.95. Because

previously identified as Affiliate 37.

The bank records show that the deposits into this

account which came from account ending in

account reflect payroll deposit from Elite 37.

As of January 2013 the balance in this account

As of February, 2012 this account had a balance of $77,987.78. Because this

As of March 31, 2012 this account had an ending balance of $97,444.34.

Between March 7, 2012 and March 31, 2012, a total of approximately

Between January 1, 2009 and November 30, 2010, a total of approximately

Over $185,000 of miscellaneous deposits.

(which are both discussed above) or Midfirst account below.

Midfirst Bank checking account account 158. discussed below.

replacement document was signed adding Kristin BURNS as an Authorized Agent.

solely with gambling proceeds. $39,727.91. 181.

As of March 31, 2012 this account had a balance of

Coastal Games Bank of America account ending in

identified as Affiliate 91 are being deposited into this account.

account from BOA account ending in

into this account, of which at least $882,000.00 appears to be proceeds of gambling:

As of April 30, 2012, this account had an ending balance of $4,195.99.

account from Seaside Internet BOA account ending in

OPERATING ACCOUNT at a branch located in Jacksonville, Florida.

As of January 2013, the balance in this account is $98,519.32. Because this

COUNTY LLC. SPECIAL FUNDS ACCOUNT.

Between January 1, 2008 and March 31, 2012, a total of approximately

proceeds directly or indirectly from AVOTW and/or the Affiliates.

As of February 29, 2012 this account held a balance of $999,964.19. Because

account from GRANT PARK, LLC Bank of America account ending in