?Case Document 1 Entered on FLSD Docket 10/03/2008 Page 4 of 26

Helio Castroneves?s Agreements With Coimex

11. On or about March 15, 1999, HELIO CASTRONEVES entered into a one-year
sponsorship contract (the ?1999 Coimex deal?) with Coimex. The written contract for the 1999
Coimex deal stated that Coimex would pay HELIO CASTRONEVES a total of $2,000,000 for his
services.

12. On or about April 28, 2000, HELIO CASTRONEVES entered into a one-year
sponsorship contract (the ?2000 Coimex deal?) with Coimex. The written contract for the 2000
Coimex deal stated that Coimex would pay HELIO CASTRONEVES a total of $2,000,000 for his
services.

13. On or about April 4, 2001, HELIO CASTRONEVES entered into a one?year
sponsorship contract (the ?2001 Coimex deal?) with Coimex. The written contract for the 2001
Coimex deal stated that Coimex would pay HELIO CASTRONEVES a total of $2,000,000 for his
services.

Helio Castroneves?s Agreements With Penske

14. On or about November 5, 1999, HELIO CASTRONEVES agreed to join Penske
as a race car driver.

1 5. ALAN R. MILLER negotiated the deal with Penske on HELIO 
behalf. ALAN R. MILLER drafted the contracts that memorialized the deal. Under the contracts,
HELIO compensation from Penske was divided between a ?Driver
Agreement? and a ?Licensing Agreement.?

16. The Driver Agreement was between CNR and Penske. Pursuant to the Driver

Agreement, CNR was to receive compensation of $1,000,000 for the combined years 2000, 2001,

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Case Document 1 Entered on FLSD Docket 10/03/2008 Page 5 of 26

and 2002. That sum was payable in thirty-six (36) installments of $27,777.78. On or about
November 5, 1999, Penske and CNR executed the Driver Agreement. HELIO CASTRONEVES
signed the Driver Agreement on behalf of CNR.

17. The Licensing Agreement was between Seven Promotions and Penske. Pursuant to
the Licensing Agreement, Seven Promotions was to receive compensation of $5,000,000 for the
combined years 2000, 2001, and 2002. That sum was payable in thirty?six (3 6) installments
of $138,888.89. On or about November 5, 1999, Penske and SevenPromotions executed the
Licensing Agreement. HELIO CASTRONEVES signed the Licensing Agreement on behalf of
Seven Promotions.

neurone
Conspiracy to Defraud the United States
(18 U.S.C. 371)
1. Paragraphs 1 through 17 of the General Allegations section of this Indictment are
realleged and incorporated by reference herein.
2. From on or about March 2, 1999, and continuing through at least on or about February
6, 2004, in Miami-Dade County, in the Southern District of Florida, and elsewhere, the defendants,
HELIO CASTRONEVES,
a/k/a ?Helio Castro-Neves,?
a/k/a ?Helio Alves de Castro Neves,?
KATIUCIA CASTRONEVES,
a/k/a ?Katiucia Castro-Neves,?
a/k/a ?Katiucia Alves de Castro Neves,? and
ALAN R. MILLER,
did unlawfully, willfully, and knowingly combine, conspire, confederate and agree with each other

and with others, known and unknown to the Grand Jury, to defraud the United States for the purpose

of impeding, impairing, obstructing, and defeating the lawful governmental functions of the Internal

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