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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION
UNITED STATES OF AMERICA )
v. ) Civil Case No.
$115,800.00 IN U.S. CURRENCY )
FUNDS SEIZED FROM SOUTH )
GEORGIA BANK ACCOUNT )
ENDING IN 0378, ET AL. )
VERIFIED COMPLAINT FOR FORFEITURE IN REM
COMES NOW the United States of America, (the “United States” or the “Government”), by and through David H. Estes, United States Attorney for the Southern District of Georgia, and J. Bishop Ravenel, Assistant United States Attorney, and brings this Verified Complaint for Civil Forfeiture In Rem, with the following allegations:
NATURE OF THE ACTION
1. In Rem civil forfeiture is permissible under Rule G of the Supplemental Rules
for Admiralty or Maritime Claims and Asset Forfeiture Actions. 2. The Defendants In
Rem are subject to forfeiture to the United States pursuant to 18 U.S.C. § 981(a)(1)(A)
and (a)(1)(C) on the grounds that the Defendant Property, as defined later herein, is
proceeds traceable to and/or derived from theft and unlawful conversion of government
property and conspiracy in violation of 18 U.S.C. §§ 641 and 371, respectively, and
wire fraud and conspiracy to commit wire fraud in violation of 18 U.S.C. §§ 1343 and
1349, respectively; and property involved in money laundering and conspiracy to commit money laundering in violation of 18U.S.C. §§ 1956 and 1957.
THE DEFENDANTS IN REM
It is a law that these accounts can be seized indefinably pending adjudication
3. Collectively, the Defendants In Rem (hereinafter, collectively the “Defendant
Property”) represent the following assets:
a. (“Account 1”);$115,800.00 in funds from Bank Acc # 200378 held in the name ofHouse of Prayer Christian Churches of America, Inc. Phebe Ruth Denis Foundation,at South Georgia Bank, Hinesville, Georgia (22-FBI-006352) which was seized from House of Prayer Christian Churches of America, Inc. on July 22,2022 at Phebe Ruth Denis Foundation, South Georgia Bank, located in Hinesville, GA
b. (“Account 2”); $21,263.24 in funds from Bank Acct# 9063052757 held in the name of House of Prayer Christian Churches of America, Inc. at First Citizens Bank and Trust, Raleigh, North Carolina (22-FBI-005637) which was seized from House of Prayer Christian Churches of America, Inc. on July 22, 2022 at First Citizens Bank and Trust, located in Savannah, GA
c. (“Account 3”);$6,715.85 in funds from Bank Acct # 9063052888 held in the name of House of Prayer Christian Churches of America, Inc. Killeen Seminary at FirstCitizens Bank and Trust, Raleigh, North Carolina (22-FBI-005638) which was seized from House of Prayer Christian Churches of America, Inc. on July 22, 2022 at First Citizens Bank and Trust, located in Savannah, GA
d. (“Account 4”); $3,168.33 in funds from Bank Acct# 9063052837 held in the name of House of Prayer Christian Churches of America, Inc. Tacoma Seminary at First Citizens Bank and Trust, Raleigh, North Carolina (22-FBI-005639) which was seized from House of Prayer Christian Churches of America, Inc. on July 22, 2022 at First Citizens Bank and Trust, located in Savannah, GA
e. (“Account 5”); $578.84 in funds from Bank Acct# 9063052896 held in the name of House of Prayer Christian Churches of America, Inc. Fayetteville Seminary at First Citizens Bank of Trust, Raleigh, North Carolina 22-FBI-005787) which was seized from House of Prayer Christian Churches of America, Inc. on July 22, 2022 at First Citizens Bank and Trust, located in Savannah, GA
f. (“Account 6”).$2,665.53 in funds from Bank Acct# 200360 held in the name of House of Prayer Christian Churches of America, Inc. Escrow Account, at South Georgia Bank, Hinesville, Georgia (22-FBI-006350) which was seized from House of Prayer Christian Churches of America, Inc. on July 22, 2022 at Escrow Account, South Georgia Bank, located in Hinesville, GA
The Defendant Property was seized on or about July 22, 2022, from accounts held by
South Georgia Bank and First Citizens Bank and Trust as the result of federal seizure
warrants authorized on or about July 21, 2022 in the Southern District of Georgia.
JURISDICTION AND VENUE
4. The United States brings this action In Rem in its own right to forfeit the
Defendant Property.
5. This Court has jurisdiction over an action commenced by the United States
pursuant to 28 U.S.C. § 1345.
6. The Court has jurisdiction over an action for forfeiture pursuant to 28 U.S.C. §
1355(a).
7. The Court has In Rem jurisdiction over the Defendant Property pursuant to
28 U.S.C. § 1355(b).
8. Venue is proper in this district pursuant to 28 U.S.C. § 1355(b)(1) because
acts and/or omissions giving rise to the forfeiture of the Defendant Property occurred
in this district.
FACTS AND BASIS OF FORFEITURE Overview of Investigation
9. This forfeiture action stems from the seizure of the Defendant Property
which was determined to be proceeds traceable to and/or derived from wire fraud, and
which was also related to the violations of other federal laws, currently under
investigation by the Federal Bureau of Investigation (“FBI”) and United States
Department of Veteran’s Affairs – Office of the Inspector General (“VA-OIG”).
10. Particularly, the Defendant Property is forfeitable to the United States, as
proceeds traceable to and derived from theft and unlawful conversion of government
property, conspiracy to commit theft and unlawful conversion of government property,
wire fraud, and wire fraud conspiracy; and property involved in money laundering and
money laundering conspiracy, relating to a scheme to defraud the United States of money and its military veterans of monetary educational benefits.
11. The House of Prayer Bible Seminary (“HOPBS”), their employees and
agents, and others aiding and abetting and aided and abetted by HOPBS (collectively
referred to as “HOPBS”), and its parent organization, House of Prayer Christian
Churches of America, Inc. (“HOPCC”), their employees and agents, and others aiding
and abetting and aided and abetted by HOPCC (collectively referred to as “HOPCC”)
committed crimes, in violation of 18 U.S.C. §§ 371, 641, 1343, 1349, 1956, and 1957,
which caused the Defendant Property to be forfeitable to the United States.
12. HOPBS has operated and may continue to operate locations in the Southern District of Georgia, including in Liberty and Richmond Counties.
13. HOPCC is the parent organization of HOPBS.
14. HOPBS and HOPCC have received money, including the Defendant
Property, through this criminal scheme.
Background on VA Educational Benefits
How it is supposed to work
15. Under Title 38, United States Code, Chapter 33 (“Post-9/11 GI Bill”), the
United States provides educational assistance by paying for tuition, housing costs, and
other educational costs and fees for veterans of the United States Armed Forces and
other eligible persons that meet certain qualifications (hereinafter both classes of
persons are referred to as “veterans”). See 38 U.S.C. § 3311.
16. The Post-9/11 GI Bill and its related regulations provide educational
assistance to veterans and is administered by the Department of Veterans Affairs
(“VA”).
17. On October 1, 2011, the VA implemented a significant change in the
eligibility for receipt of Post-9/11 GI Bill benefits. Effective that day, VA began paying
Post-9/11 GI Bill benefits to individuals pursuing non-institute of higher learning
(non-IHL), non-degree programs, to include non-college degree (NCD) schools or
programs. These benefits are commonly referred to as “Chapter 33 benefits.”
18. For individuals receiving Chapter 33 benefits, the VA pays the tuition and fee
payment directly to the school on the enrolled veteran’s behalf. The VA covers the net
costs for in-state tuition and fees or the annual maximum for the academic year,
whichever is less for a NCD school. See 38 U.S.C. § 3313(g)(3). In addition to the
tuition and fee payments, the VA also provides monthly housing allowance benefits to
veterans who are enrolled in the NCD program on more than a half-time basis. Id. In
addition, veterans enrolled in courses in a NCD program at a non-IHL school receive a
lump-sum amount for books, supplies, equipment, and other educational costs in an
amount equal to $83 for each month (prorated based on the veteran’s VA benefit level).
Id.
19. To be eligible for benefits specifically under the Post-9/11 GI Bill, a course of
education must be approved “by the State approving agency (SAA) for the State where
the educational institution is located,” subject to limited exceptions. 38 U.S.C. §
3672(a). In the state of Georgia, the SAA is the Georgia Department of Veterans Service (“GDVS”). If an approved NCD school offers a course under a
contract from a third party, the contractor must obtain its own VA approval from the
SAA. See 38 U.S.C. § 3680A(f)(2).
20. The Georgia Nonpublic Postsecondary Education Commission (“GNPEC”)
also exercises oversight authority regarding educational programs, including the
program being run by HOPCC and HOPBS, and relates its findings to GDVS and,
ultimately, to the VA.
21. Non-accredited institutions seeking approval from the SAA are evaluated in
several areas to ensure that quality education is provided to veterans. For a school to
obtain approval to offer a non-accredited course, the SAA must find upon investigation
that the educational experience and qualifications of the school’s instructors are
adequate and that the instructors are of good reputation and character. 38 C.F.R. §
21.4254(c)(3), (c)(12). As a result, the school must disclose this information to the SAA
during the approval process. See 38 C.F.R. § 21.4254(c)(3), (c)(12). In practice, this is
normally accomplished by the inclusion of a faculty section in the school’s course
catalog that is submitted to the VA for approval, which includes the name of the
instructors and a short biography.
22. Once the school’s course of education has been approved, tuition
assistance under the Post-9/11 GI Bill is paid directly to the school providing the course
in the amount allowable under the statute. See 38 C.F.R. § 21.9680(a)(1). The VA will
not pay educational assistance to NCD schools for courses offered by distance
learning, See 38 C.F.R. § 21.4267, except for the time period from March 1, 2020,
through December 21, 2021 due to COVID-19 and Public Laws 116-128 and 116-140.
Before assistance is paid out under the Post-9/11 GI Bill, however, the school must first
certify the individual’s enrollment in the approved program. See 38 C.F.R. §
21.9680(b)(1). Other benefits, including the housing allowance, funds for books and
supplies, and other educational costs, are paid directly to the veteran. See 38 C.F.R. §
23. The VA will not approve the enrollment of any veteran or other eligible
person in any course for any period during which more than 85% of the students
enrolled in the course are having all or part of their tuition, fees, or other charges paid
to or for them by the school or the VA. See 38 C.F.R. § 21.4201(a). That is, at least
15% of students must not be receiving VA educational assistance. Failure to adhere to
this requirement, which is commonly referred to as the “85-15 rule,” may result in the
facility’s future enrollments being suspended from receipt of VA educational assistance.
24. Each school that receives VA tuition assistance funds must designate a
School Certifying Official who is responsible for the certification of beneficiaries of VA
education benefits. A school may designate more than one School Certifying Official.
An individual in a position of authority at the school must complete VA Form 22-8794,
Designation of Certifying Official(s), in order to designate a School Certifying Official.
School Certifying Officials are required to submit initial enrollment documents for
veterans within 30 days of the beginning of the term, keep the VA informed of the
enrollment status of veterans, maintain current knowledge of the VA rules and benefits, maintain records of veteran and non-veteran students
(student or enrollee not using VA education benefits to pay for their program program),
and make all records available for inspection at any time by the VA or the SAA.
25. VA-ONCE is a web-based system, with servers based in Pennsylvania, that
allows School Certifying Officials to create and transfer enrollment information directly
to a VA Regional Office for processing. The VA-ONCE system requires the School
Certifying Official to provide a username and password to access the system and
transmit data to the VA. Each School Certifying Official has a unique username and
password which allows him or her access to the system. Transactions originating
or terminating outside the state of Pennsylvania with VA-ONCE cause interstate and/or
foreign wires to occur. Additional interstate and/or foreign wires initiated from locations
outside of Georgia also occur as a result of payments made by the VA for the
educational benefits described herein.
26. School Certifying Officials must complete VA Form 22-1999, VA Enrollment
Certification, for each veteran who will receive VA tuition assistance funds. Using this
form, School Certifying Officials certify the course in which the veteran is being
enrolled, the start and end dates of the enrollment period, the number of hours per
week the veteran will attend class, and the cost of tuition for the course. The School
Certifying Official is responsible for notifying the VA of any changes in the information
the official has certified. In addition, as of January 1, 2018, if the student graduates
from the program, the School Certifying Official must document this graduation on VA Form 22-1999b, Notice of Change in Student Status.
See Public Law 114-315 § 404 (effective January 1, 2018).
27. The School Certifying Official has the option of completing either a hard copy
VA Form 22-1999 or the electronic version of the form available through the VA ONCE
system. The hard copy form requires the School Certifying Official to provide his or her
signature, while the electronic form requires the School Certifying Official to sign
electronically. The date of the electronic signature and the date the document is
electronically received by the VA are recorded on the enrollment certification document.
By signing a VA Form 22-1999, either by hand or electronically, a School Certifying
Official certifies that the veteran’s course or courses are “generally acceptable to meet
requirements for the student’s educational, professional, or vocational objective,” and
that all the “85-15 ratio requirements have been satisfied.”
28. The educational facility is responsible for ensuring that veterans receiving VA
tuition assistance does not make up more than 85% of their student population. The VA
does not track the number of non-veteran students, rather it relies solely on the
representations made by the School Certifying Official on the Statement of Assurance
of Compliance with 85 Percent Enrollment Ratios form, VA Forms 22-1999, and during
VA compliance surveys, which are typically conducted on an annual basis. These
representations are material to the VA, because a school that did not comply with the
rules would be ineligible to receive funds under the program. HOPBS Relationship to VA Education Benefits and Payments
29. HOPBS initially obtained approval to receive VA education assistance
benefits by representing to the VA, among other things, that it was providing courses to
veterans and other eligible persons that were taught by HOPBS instructors at HOPBS
facilities.
30. HOPBS represented to the VA that those facilities were located in Hinesville
and Hephzibah, GA, within the Southern District of Georgia, and also in Fayetteville,
NC, Killeen, TX, and Tacoma, WA.
31. Upon each veteran’s enrollment, a HOPBS School Certifying Official certified
to the VA by way of VA Forms 22-1999 that each veteran was receiving the allotted
hours of instruction consistent with the course for which the veteran had been
approved.
32. HOPBS then received direct tuition payments from the VA under the
Post-9/11 GI Bill.
33. According to documents provided by HOPBS to the SAA and subsequently
the VA, HOPCC operates HOPBS.
34. Between January 2013 and February 2022, approximately 304 veterans
were enrolled in courses at HOPBS.
35. VA enrollment certification records, certified by HOPBS School Certifying
Officials, reflected that a majority of veterans were enrolled as full-time students at
HOPBS requiring at least 18 hours of in-person attendance per week.
36. From January 2013 to January 2022, VA paid veteran students enrolled at
HOPBS under various VA education benefit programs approximately $15,952,721 in
the form of tuition, housing allowances, and stipends.
37. VA records indicate that from January 2013 to February 2022, VA issued
tuition payments to HOPBS totaling approximately $6,916,303 for 210 veterans
enrolled at HOPBS under the Post-9/11 GI Bill program and various other
VA-sponsored educational benefits programs.
38. HOPBS financial records and VA records reflect that from 2013 to 2016 the
tuition payments from the VA to HOPBS for students receiving Post-9/11 GI Bill benefits
grew substantially.
39. From 2013 through 2022, HOPBS received the following monies from the VA
in payments regarding the Post-9/11 GI Bill benefits:
a. For the calendar year 2013, the VA paid approximately $75,360 in
Post-9/11 GI Bill benefits to HOPBS;
b. For the calendar year 2014, the VA paid approximately $442,355 in
Post-9/11 GI Bill benefits to HOPBS;
c. For the calendar year 2015, the VA paid approximately $1,076,967 in
Post-9/11 GI Bill benefits to HOPBS;
d. For the calendar year 2016, the VA paid approximately$1,146,165 in
Post-9/11 GI Bill benefits to HOPBS;
e. For the calendar year 2017, the VA paid approximately $1,120,492 in
Post-9/11 GI Bill benefits to HOPBS;
f. For the calendar year 2018, the VA paid approximately $973,751 in
Post-9/11 GI Bill benefits to HOPBS;
g. For the calendar year 2019, the VA paid approximately $919,921 in
Post-9/11 GI Bill benefits to HOPBS;
h. For the calendar year 2020, the VA paid approximately $677,262 in
Post-9/11 GI Bill benefits to HOPBS;
i. For the calendar year 2021, the VA paid approximately $407,799 in
Post-9/11 GI Bill benefits to HOPBS; and
j. In January 2022, the VA paid HOPBS approximately $76,231 in
Post-9/11 GI Bill benefits to HOPBS.
Overview of Fraud by HOPBS and HOPCC
Who Did It Who is Responsible. Head Of HOPCC Seminary Marcus Labat
I'm not a crook!
Press to Play!
Yes your 100% right you did earn it. Everything you get. You deserve it.
Remember It is Recorded You did it your way Rony.
40. During the course of this ongoing investigation, agents with the FBI and
VA-OIG gathered evidence through interviewing witnesses, including but not
necessarily limited to former students and employees of HOPBS, reviewing VA records,
reviewing records from financial institutions, considering unsolicited complaints to the
VA submitted through a VA online complaint system against HOPBS, and through other measures.
41. Through the investigation, the FBI and VA OIG determined HOPBS made
numerous false statements to the VA in order to establish HOPBS as an educational
institution recognized by the VA and in order to secure regular payments from the VA
under the Post-9/11 GI Bill program for educational services.
42. Those education services were not performed to the standard required by
the VA.
43. HOPBS made the following materially false and fraudulent statements and
representations, knowing then and there that such statements and representations
were false, including through interstate wire communications, to the VA regarding the
Post-9/11 GI Bill program, including but not limited to:
a. overstating and otherwise misrepresenting the number of hours of
instruction performed by HOPBS;
b. misrepresenting the qualifications of faculty members of HOPBS;
c.misrepresenting the facility locations of students enrolled at HOPBS;
d. misrepresenting the facility locations of faculty members of HOPBS;
e. misrepresenting the time periods over which faculty members worked
for HOPBS;
f. misrepresenting the courses taught by faculty members;
g. misrepresenting the courses available to students of HOPBS;
h.misrepresenting the manner of instruction provided by HOPBS; i.misrepresenting the quality of instruction provided by HOPBS;
j.misrepresenting the schedules of students of HOPBS;
k. misrepresenting the nature of the HOPBS education program, including
the requirements to successfully complete the program
l. misrepresenting the true content of courses, including by renaming old
courses to appear as new courses;
m. falsifying attendance rosters for courses, including by falsely and fraudulent stating that certain students attended the courses when in fact they did not;
n. falsifying financial records of payments by students to HOPBS;
o. falsifying information and records bearing upon HOPBS’s compliance with the “85/15
Rule”;
p. falsifying graduation and completion records of students of HOPBS;
q. falsifying course catalogs, including by providing false and misleading information
regarding course names, content, and hours of instruction.
44. Had HOPBS related truthful and accurate information, rather that the materially false statements and/or omissions in the preceding paragraph and subparagraphs, HOPBS would not have been certified to receive Post-9/11 GI Bill program benefits and would not have received money from the VA.
45. HOPBS made the following materially false and fraudulent statements and representations, knowing then and there that such statements and representations were false, to the GNPEC, the Georgia entity overseeing postsecondary educational entities, which in turn resulted in false and fraudulent statements submitted by GNPEC to GDVS, the Georgia SAA, and ultimately to the VA, including through interstate wire communications, including but not limited to:
a. claiming HOPBS received no federal funds in applying for a religious
exemption to GDVS oversight of its Hinesville, GA, educational program, within the
Southern District of Georgia, in or about December 2011;
b. omitting that HOPBS ran a location in Hephzibah, within the Southern
District of Georgia, in applying for the religious exemption to GNPEC in or about
December 2011; and
c. claiming HOPBS received no federal funds in applying for renewals of
its religious exemption to GNPEC oversight of its educational program, in or about
December 2015, March 2017, December 2017, and January 2020.
46. Had HOPBS related truthful and accurate information, rather that the
materially false statements and/or omissions in the preceding paragraph and sub
paragraphs, HOPBS would not have been authorized to operate in the state of Georgia
and, as a result, would not have been certified to receive Post-9/11 GI Bill program
benefits and would not have received money from the VA.
47. In addition, through interviews and the review of unsolicited complaints to the
VA submitted through a VA online complaint system regarding HOPBS, the FBI and
VA-OIG obtained the following information regarding HOPCC and HOPBS, including
but not limited to:
a. HOPCC established locations in close proximity to military bases in order to target military service members and veterans;
b. HOPCC targeted military service members and veterans, seeking to
exploit them and deprive them of their benefits, including but not necessarily limited to
housing benefits as service members and educational benefits as veterans;
c. HOPCC used various psychological efforts, including public shaming,
financial coercion, and control of minute aspects of the military members and veterans’
lives in order to control and exploit them economically;
d. HOPCC members were directed to enroll in HOPBS and to use their
Post-9/11 GI Bill benefits to pay for HOPBS and cause direct payments to HOPBS and
HOPCC.
e. HOPBS directed students at HOPBS to falsify educational records,
including attendance rosters, hours of instruction, and additional paperwork;
f. HOPBS students were not provided with a pathway towards successful completion of the program and had their course plans changed without their input and consent;
g. HOPBS denied and/or delayed providing students with documentation
regarding their education, including transcripts and evidence of course and program
completion;
h. HOPBS misled students regarding the content of courses and the
program, the students’ freedom to choose courses, grading system, and qualifications
of instructions, among other misrepresentations and false statements;
i. HOPBS failed to provide grades to students and rarely tested them; and
j. HOPBS falsified student records, including course attendance records
and graduation records.
Defendant Property Nexus to Wire Fraud and Money Laundering
48. VA records indicate that from October 2020 to June 2022, VA issued tuition payments to the Accounts 2, 3, 4, and 5 totaling approximately $513,751 for veterans enrolled at HOPCC under the Post-9/11 GI Bill program.
49. HOPCC is the account owner for Accounts 2, 3, 4, and 5, and has been the account holder during the time period payments were received from the VA for payments under the Post-9/11 GI Bill program.
50. Accounts 1 and 6 were controlled by HOPBS and HOPCC during the time
period payments were received by HOPBS and HOPCC from the VA for payments
under the Post-9/11 GI Bill program.
51. In total, during the time period over which HOPBS and HOPCC received
money from the VA for payments under the Post-9/11 GI Bill program, HOPBS and
HOPCC controlled 80 or more bank accounts at 20 or more financial institutions;
routinely opened and closed accounts; and frequently transferred and deposited VA
funds to and from multiple HOPBS and HOPCC controlled bank accounts.
52. HOPBS and HOPCC controlled and used even more bank accounts, which
have not been associated at this point in the investigation with monies received from
the VA.
53. Many of the transactions appeared to have no business purpose and served
the effect of distancing the bank accounts and funds from the initial receipt of
the payments from the VA and concealing the VA as the initial source of that money as
well as the nature of the money.
54. During the time period over which HOPCC and HOPBS received Post 9/11
GI Bill program funds from the VA, Accounts 1 through 6 were involved in monetary
transactions involving more than $10,000, which constituted or was derived from
proceeds traceable to violations of 18 U.S.C. §§ 371, 641, 1343, and 1349, including:
a. Account 1 transferring over $10,000 on approximately 13 occasions to
other HOPCC and/or HOPBS accounts, and conducting deposits of over $10,000 on
approximately 8 occasions;
b. Account 2 transferring over $10,000 on approximately 11 occasions to
other HOPCC and/or HOPBS accounts, and conducting deposits of over $10,000 on
approximately 16 occasions from other HOPCC and/or HOPBS accounts;
c. Account 3 transferring over $10,000 on approximately one occasion to
another HOPCC and/or HOPBS account;
d. Account 4 transferring over $10,000 on approximately eight occasions
to other HOPCC and/or HOPBS accounts;
e. Account 5 transferring over $10,000 on approximately two occasions
to other HOPCC and/or HOPBS accounts, and conducting a deposit of over $10,000
on approximately one occasion from another HOPCC and/or HOPBS account; and
f. Account 6 transferring over $10,000 on approximately five occasions to other HOPCC and/or HOPBS accounts, and conducting deposits of over $10,000 on approximately two occasions from other HOPCC and/or HOPBS accounts.
55. The VA paid approximately $208,320 during the time period of 2020 through
2022 into Account 2 under the Post-9/11 GI Bill program.
56. The VA paid approximately $60,457 during the time period of 2020 through 2022 into Account 3 under the Post-9/11 GI Bill program.
57. The VA paid approximately $152,500 during the time period of 2020 through 2022 into Account 4 under the Post-9/11 GI Bill program.
58. The VA paid approximately $92,474 during the time period of 2020
through 2022 into Account 5 under the Post-9/11 GI Bill program.
59. The VA also paid approximately $4.7 million under the Post-9/11 GI Bill program into bank accounts controlled by HOPCC and/or HOPBS between March 2015 and October 2020, which accounts are listed as Subject Accounts 1, 2, 3, and 4 below.
60. The VA paid approximately $821,990 between March 2015 and August 2019
under the Post-9/11 GI Bill program into a Chase Bank account ending in 8352
(“Subject Account 1”).
61. The VA paid approximately $2,704,872 between April 2015 and June 2020
under the Post-9/11 GI Bill program into a Suntrust/Truist account ending in 0040
(“Subject Account 2”).
62. The VA paid approximately $927,247 between April 2015 and October 2020
under the Post-9/11 GI Bill program into a Bank of America account ending in 0803
(“Subject Account 3”).
63. The VA paid approximately $248,972 between June 2016 and July 2017
under the Post-9/11 GI Bill program into a Bank of America account ending in 4594
(“Subject Account 4”).
64. Subject Accounts 1, 2, and 3 also transferred $767,903 in money traceable
to VA payments under the Post-9/11 GI Bill program to a Wells Fargo Bank account
ending in 2120 (“Subject Account 5”), which was controlled by another entity.
65. Subject Account 5 transferred $96,000, via a check, in July 2020, to
Account 1, which monies were traceable to payments from the VA under the Post 9/11
GI Bill program.
66. Subject Accounts 1 through 5 were used to conceal and funnel the monies
received from the VA to additional bank accounts controlled by HOPCC and/or
HOPBS.
67. Account 6 was also used to conceal the monies received from the VA and
received approximately $59,829 from Subject Accounts 1 through 4 traceable to
monies from the VA to Subject Accounts 1 through 4 under the Post 9/11 GI Bill
program.
68. Account 1 was also used to conceal the monies received from the VA and
received approximately $96,000 from Subject Account 5 traceable to monies from the
VA to Subject Account 5 under the Post 9/11 GI Bill program.
69. Through numerous materially false and fraudulent statements and
omissions, including but not necessarily limited to those set forth in the above
paragraphs, HOPBS and HOPCC defrauded the United States of money and its
veterans of monetary educational benefits, including the Defendant Property, which
includes proceeds and/or property traceable to proceeds of theft and unlawful
conversion of government property, conspiracy to commit theft and unlawful conversion
of government property, wire fraud, and wire fraud conspiracy; and is property involving
in money laundering and money laundering conspiracy.
70. Accounts 1 through 6 as well as Subject Accounts 1 through 5 contain and
constitute property that was involved in money laundering offenses, including
conspiracy to commit money laundering, in violation of 18 U.S.C. §§ 1956 and 1957.
71. Accounts 1 through 6 as well as Subject Accounts 1 through 5 contain and
constitute property that was proceeds traceable to and/or derived from theft and
unlawful conversion of government property, conspiracy to commit theft and unlawful
conversion of government property, wire fraud, and conspiracy to commit wire fraud, in
violation of 18 U.S.C. §§ 371, 641, 1343, and 1349.
72. By the foregoing and other acts, the Defendant Property is subject to
forfeiture to the United States pursuant to 18 U.S.C. §§ 981(a)(1)(A) and 981(a)(1)(C)
on the grounds that the Defendant Property is proceeds traceable to and/or derived
from violations of 18 U.S.C. §§ 371, 641, 1343, and 1349; and property involved in
violations of 18 U.S.C. §§ 1956 and 1957.
CLAIMS FOR RELIEF
First Claim for Relief(Forfeiture Pursuant to 18 U.S.C. § 981(a)(1)(C))
73. The United States incorporates by reference the allegations contained in
paragraphs 1 through 72 above as if set forth fully herein.
74. The Defendant Property is property that constitutes and/or is derived from
proceeds traceable to violations of 18 U.S.C. §§ 371, 641, 1343, and 1349.
75. TheDefendant Property is therefore subject to forfeiture pursuant to 18 U.S.C. §
981(a)(1)(C).
Second Claim for Relief (Forfeiture Pursuant to 18 U.S.C. § 981(a)(1)(A))
76. The United States incorporates by reference the allegations contained in
paragraphs 1 through 72 above as if set forth fully herein.
77. The Defendant Property is property that is involved in and/or traceable to
transactions or attempted transactions of a value greater than $10,000 in property
derived from specified unlawful activity, including but not limited to violations of 18
U.S.C. §§ 371, 641, 1343, and 1349, in violation of 18 U.S.C. § 1957.
78. The Defendant Property is therefore subject to forfeiture pursuant to 18
U.S.C. § 981(a)(1)(A).
Third Claim for Relief (Forfeiture Pursuant to 18 U.S.C. § 981(a)(1)(A))
79. The United States incorporates by reference the allegations contained in
paragraphs 1 through 72 above as if set forth fully herein.
80. The Defendant Property is property that is involved in, and/or is traceable
to transactions or attempted transactions designed in whole or in part to conceal or
disguise the nature, location, source, ownership, or control of the proceeds of specified
unlawful activity, including but not limited to violations of 18 U.S.C. §§ 371, 641, 1343,
and 1349, in violation of 18 U.S.C. § 1956(a)(1)(B)(i).
81. The Defendant Property is therefore subject to forfeiture pursuant to 18
U.S.C. § 981(a)(1)(A).
Fourth Claim for Relief (Forfeiture Pursuant to 18 U.S.C. § 981(a)(1)(A))
82. The United States incorporates by reference the allegations contained in
paragraphs 1 through 72 above as if set forth fully herein.
83. The Defendant Property is property involved in a conspiracy to commit
violations of 18 U.S.C. § 1956(a)(1)(B)(i) and § 1957, in violation of 18 U.S.C. §
1956(h).
84. The Defendant Property is therefore subject to forfeiture pursuant to 18
U.S.C. § 981(a)(1)(A).
CONCLUSION
85. WHEREFORE, the United States of America prays that:
a. Process of a Warrant for Arrest and Notice In Rem be issued for the
arrest of the Defendant Property;
b. The Defendant Property be forfeited and condemned to the use and
benefit of the United States;
c. The United States be awarded its costs and disbursements in this action and for
such other and further relief as this Court deems just and proper;
and d. That due notice be given to all parties to appear and show cause why the forfeiture of the Defendant
Property should not be decreed.
The Key Take aways
Another Entity is Rony Denis
Phebe Ruth Denis Fund did have three transactions to 3 separate children in the amount $500 Total over the last ten years
In comparison Denis had 3 checks a week being deposited into his accounts for $10,000
Denis has a laptop and he thinks its set up to where he is invincible to everyone VPN Ghost no recommendo
One of the Seminary faculty told a couple students that they will be receiving Certificates. Rony thinks he is going to be able to print them off in 2023 and that majestically or through the multiverse they will just appear out of the ether and save Him. The printshop is not going to bail you out of this. Who do you got running the printshop now a days. Ezra can print all the diplomas you want to postpartum but do you realize in the end that is not going to help IT is only a Matter of Time Mr. Back Date Himself. You can Date it back to the beginning of the Cosmos where your Delusions think you come from Mr. Ancient of Days / Hog Wash. But Truth is and doesn't need to be altered photoshopped and forged.