Case 1:15-cr-00227-WS Document 1 Filed 10/29/15 Page 1 of 17 F,LED tN opil,tåor* ocl2 e 20tt DAG IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA UNITED STATES OF AMERICA, * * {< CRrmrurr, No.:15- Cþ¡ARLES R. DIARD, JR. CLERK Dòàà?- UIS USAO Number: 15R00345 * * t Vror,rnoNs: {< CHARLES BURTON RITCHIE ANd I}ENJAMIN ED\ryARD GALECKI * * 18 U.S.C. $ 1349 18 U.S.C. S 1es6(h) l8 u.s.c. $ 371 INDICTMENT At all times relevant to this Indictment: 1. Defendants CHARLES BURTON RITCHIE and BEN.IAMIN GALECKI were the owners and operators of ZIV/ (formerly known as "Zençense"), a Florida-based company, which manufactured and distributecl synthetic drugs. These substances are generally referred to as "spice," "incense," or "potpourri." 2. The terms "spice,"'oincense," and "potpourri," used generically, refer to any number of forms of srnokeable synthetic drugs. 3. In or about December 2}l2,clefendants RITCHIE and GALECKI purported to sell ZIW's product line to Anthony Nottoli, who is not named as a def'endant herein. At that time the successor company became known as ZenBio, however, both defendants GALECKI continued to participate in the operation 2012, IIITCHIE and and receive funds from ZenBio. In October RITCHIE" GALECKf, and others began moving the spice manufacturing operation fi'om Florida to California. In December 2012, ZenBio's call center movecl to Robertsdale, Alabama, in tlie Southern District of Alabarna. Case 1:15-cr-00227-WS Document 1 Filed 10/29/15 Page 2 of 17 4. Crystal Henry, Robert Biggerstaff, and Jim Vail, who are not named as defendants herein, and others were employed by defendants RITCHIE and GALECKI in various capacities at Zencense and ZtrW and continued to work atZenBio. 5. The United States Food and Drug Administration ("FDA") is the agency of the United States responsible for, among other things, enforcing the provisions of the Federal Food, and Cosmetic Act D*g, ("FDCA"), 21 U.S.C. $$ 301 et seq. In enforcing the provisions of the FDCA, the FDA's primary purpose is to protect the public health. The FDA's responsibilities include regulating the manufacturing, labeling, and distribution of drugs shipped or received in interstate commerce. The FDA's responsibilities include preventing drugs that are unapproved for marketing or sale, or which are improperly packaged and labeled, from reaching the marketplace. 6- The FDCA defines a "drug" as- articles (other than food) intended to affect the structure or any function of the body man or other animals. See 21 U.S.C. $ 321(9)(1). of The FDCA defines the term "label" to include "a display of written, printed, or graphic matter upon the immediate container of any article." See 2l U.S.C. $ 321(k). The FDCA defines the term "labeling" as "all labels and other written, printed, or graphic matter (1) upon any article or any of its containers or wrappers, or (2) accompanying such article." See 2l U.S.C. $ 321(m). 7. ZIW's products were sold to the public to be smokeable products. Consequently, they were drugs under the FDCA, subject to the Act's regulation. 2 Case 1:15-cr-00227-WS Document 1 Filed 10/29/15 Page 3 of 17 THE GRAND JURY CHARGES THAT: COUNT ONE The Grand Jury re-alleges and re-incorporates the introductory paragraphs 1 - 7 above as if fully set forth herein. From on or about August I,2012, through and including April 1I,2013, said dates being approximate, in the Southern District of Alabama, and elsewhere, the defendants, CHARLES BURTON RITCHIE and BENJAMIN EDWARD GALECKI, knowingly and intentionally combined, conspired and agreed with each other and with others, known and unknown to the Grand Jury, to commit an offense against the United States, that is: Mail Fraud, in violation of 18 U.S.C. $1341, by devising and intending to devise a scheme to defraud the Food and Drug Administration, to defraud the public, and to obtain money by materially false and fraudulent pretenses and representations, that is false pretenses and representations that the products their company, ZIW, manufactured and distributed were "spice," "incense," and "potpourri" and "not for human consumption" when, in truth and fact, they were synthetic drugs that contained chemicals, known as XLR1 l or 5FUR-l44,that were intended for human consumption as a drug, and for the purpose of executing such scheme and artifice, mailed, and caused to be mailed, and caused their products to be sent or delivered by commercial interstate carrier; including but not limited to: the mailing of chemicals from China to the United States; the delivery of manufactured synthetic drugs from Pensacola, Florida by FedBx, a commercial interstate carrier to Mobile, Alabama, and elsewhere; and the use of commercial interstate carriers to deliver finished product from Florida and from California to head shops, tobacco shops, pipe shops and adult novelty stores in the United States for retail sale, all in violation of Title 18, United States Code, Section 134I. 1 J Case 1:15-cr-00227-WS Document 1 Filed 10/29/15 Page 4 of 17 All in violation of Title 18, United States Code, Section 1349 COUNT TWO The Grand Jury re-alleges and re-incorporates the introductory paragraphs if fully I - 7 above as set forth herein. From on or about August 1,2012, through and including April 11,2013, in the Southern District of Alabama, and elsewhere, defendants, CHARLES BURTON RITCHIE and BENJAMIN EDWARD GALECKI, aided and abetted by others, both known and unknown to the Grand Jury, did knowingly conspire, confederate, and agree with each other and with Crystal Henry and Travis Gross, who are not named as defendants herein, and with others, both known and unknown to the Grand Jury, to commit offenses against the United States, in violation of Title 18, United States Code, Section 1957,to wit: to knowingly engage and attempt to engage, in monetary transactions by, through and to financial institutions, affecting interstate and foreign commerce, in criminally derived property of a value greater than $10,000, that is, among other means and methods, sending and receiving funds through bank accounts by wire transfers, checks and cash deposits, such property having been derived from a specified unlawful activity, that is, mail fraud and wire fraud, in violation of Title 18, United States Code, Section 1341 and 1343. All in violation of Title 18, United States Code, Section 1956(h). COTJNT THREE The Grand Jury re-alleges and re-incorporates the introductory paragraphs 1 - 7 above as if fully set forth herein. 4 Case 1:15-cr-00227-WS Document 1 Filed 10/29/15 Page 5 of 17 From on or about August I,2012, through and including April 1I,2013, said dates being approximate, in the Southern District of Alabama, and elsewhere, defendants CHARLES BURTON RITCHIE and BENJAMIN EDWARD GALECKI, knowingly and intentionally conspired and agreed with each other and with others, known and unknown to the Grand Jury, with the intent to defraud and mislead: (a) (b) to commit offenses against the United States, that is to: 1. in violation of Title 2l,United States Code, Section 331(a) and333(a)(2); 2. Receive and cause the receipt of misbranded drugs in interstate commerce and to deliver and proffer delivery thereof for pay, in violation of Title 21, United States Code, Section 331(c); 3. Do and cause to be done acts with respect to drugs, while such drugs were held for sale after being shipped in interstate coÍrmerce that resulted in such drugs being misbranded, in violation of Title 21, United States Code, Section 331(k); 4. Use and cause to be used the mails in executing a scheme to defraud, in violation of Title 18, United States Code, Section l34l; and Cause the introduction of misbranded drugs into interstate commerce, to defraud the United States and departments and agencies thereof, namely, the Food and Drug Administration, by impairing, impeding, and obstructing by craft, trickery, deceit, and dishonest means, the FDA's lawful and legitimate function of protecting thq health and safety of the American public by enforcing the Food, Drug, and Cosmetic Act, one purpose of which is to ensure that drugs sold for human use are safe and efTective and bear labeling that contains true and accurate information. 5 Case 1:15-cr-00227-WS Document 1 Filed 10/29/15 Page 6 of 17 OeJEcr oF THE CoNspnacy The objects of the conspiracy were the financial gain of the defendants and to defeat the FDA's lawful and legitimate function of protecting the health and safety of the American public. The Food, Drug, and Cosmetic Act Under the FDCA, a drug is deemed to be misbranded if, among other things: a. its labeling is false or misleading in any particular, including material omissions. See 2l U.S.C. $$ 352(a), 321(n). b. unless, in package form, it bears a label containing: (1) the name and place of business of the manufacturer, packer, or distributor, and (2) an accurate statement of the quantity of the contents in terms of weight, measure, or numerical count. See 2l U.S.C. $ 352(b). c. its labeling does not bear adequate directions for use. See 21 U.S.C. $ 352(Ð(l). Unless subject to an exemption not applicable here, a drug must bear adequate directions for use under which a layperson can administer the drug safely for the purposes for which it is intended. See 21 C.F.R. $ 201.5. d. its labeling does not bear such adequate warnings against use in those pathological conditions and by children where its use may be dangerous to health, and against unsafe dosage and methods and duration of administration and application, in such manner and form, as are necessary for the protection of users. See 2I U.S.C. $ 3s2(f)(2). Me¡næn ANr MpeNs Or Tup CoNspn¡cy It was part of the conspiracy that defendants RITCHIE, GALECKI and others set up locations for manufacturing and packaging the synthetic drugs, including but not limited to a warehouse located in Califomia. It was further part of the conspiracy that defendants RITCHIE and GALECKI, and others, both known and unknown to the Grand Jury, would import, and caused to be imported, 6 Case 1:15-cr-00227-WS Document 1 Filed 10/29/15 Page 7 of 17 chemicals from China, to include but not limited to XLRI1, also known as 5FUR-144, to various locations in the United States. It was fuither part of the conspiracy that defendants RITCHIE, GALECKI and others, both known and unknown to the Grand Jury, would manufacture and caused to be manufactured packaged synthetic drugs for purposes of wholesale and retail sales, either directly or indirectly, through ZIW, which were then shipped and sold throughout various states in the United States to include the Southem District of Alabama. It was a further part of the conspiracy that the packaged synthetic drugs were intended for human consumption although they carried a "not for human consumption" label in an attempt to thwart the FDA and law-enforcement regarding the products' status as drugs, with the purpose of avoiding regulations over the drugs and enabling the defendants to continue selling the drugs in exchange for money. It was a further part of the conspiracy that the defendants RITCHIE and GALECKI and their retailers falsely and misleadingly referred to their synthetic drug products as "spice," "incense," "potpourri," and other erroneous names when, in fact, such products were synthetic drugs intended for consumption in order to obtain a physiological effect of a "high." During the course and in furtherance of the conspiracy and scheme, defendants RITCHIE and GALECKI, and others, manufactured synthetic drugs in a manner designed to disguise the presence of chemicals and to avoid law enforcement detection. During the course and in furtherance of the conspiracy and scheme, defendants RITCHIE and GALECKI, and others conducted business through e-mails and text messages. 7 Case 1:15-cr-00227-WS Document 1 Filed 10/29/15 Page 8 of 17 During the course and in furtherance of the conspiracy and scheme, defendants RITCHIE and GALECKI and others used the mails and commercial interstate carriers, such as FedEx, to promote, market, sell, and distribute, the drugs for human consumption. It was part of the conspiracy for defendant GALECKI, to place and receive orders of XLR1 l, also known as 5FUR-144, and cause orders of XLR11 to be placed and received, with various sources of supply, including but not limited to Jason Fox, who is not named as a defendant herein. It was part of the conspiracy that GALECKI, would provide payrnent to and direct that payment be made to Fox, as well as other sources of supply, for the chemical orders. The drugs were misbranded in at least one of the following respects: a) The drugs' labeling did not bear adequate directions for use and did not bear adequate wamings as required by law; b) The drugs had false and misleading labeling in that they were labeled in a manner indicating they were not for human consumption when, in fact, the synthetic drugs were intended for human consumption; the drugs' labeling was false and misleading in at least one particular manner, including but not limited to the following, in violation of Title 21, United States Code, Section 352(a): i. the drugs falsely were labeled in a manner indicating that they were not for human consumption, when in fact such drugs were intended for human consumption; ii. the drugs were sold as "spice," "herbal incense," "pot-pourri," arrd under other false and misleading names when in fact the products 8 Case 1:15-cr-00227-WS Document 1 Filed 10/29/15 Page 9 of 17 were intended for use as drugs for human consumption and to affect the structure or any function of the body; iii. the drugs were packaged with labeling which failed to identif,, accurately the package's contents and intended use; and c) The drugs' packaging did not bear a label containing the name and place of the business, the manufacturer, packer or distributor. Ovpnr Acrs The following overt acts, among others, were committed and caused to be committed in furtherance of the conspiracy during the period of time alleged, August 1,2012 through and including April 11,2013, said dates being approximate. A. Defendants RITCHIE and GALECKI, and other members of the conspiracy, caused the shipment of chemicals to be transported from China with misleading labeling, including manifests or declarations, regarding their contents, in order to avoid detection by the FDA and law enforcement officers, to the United States. B. Defendants RITCHIE and GALECKI, and other members of the conspiracy, caused the packaging of synthetic drugs into foil packets for sale to retailers who then sold the packets to consumers. C. Defendants RITCHIE and GALECKI, and other members of the conspiracy, caused misbranded drugs to be shipped/transported to Amy Lynn located in Dallas, Texas, who then resold the misbranded drugs to consumers. D. Defendants RITCHIE and GALECKI, and other members of the conspiracy, shipped/transported and caused to be shipped/transported misbranded synthetic drugs to various head shops, smoke shops, and other retail establishments who sold drug paraphernalia 9 Case 1:15-cr-00227-WS Document 1 Filed 10/29/15 Page 10 of 17 to a number of states in the United States, to include a location in the Southern District of Alabama, who then sold the misbranded drugs to consumers. E. On or about September 5,2012, defendants RITCHIE and GALECKI, and other members of the conspiracy, shipped or caused to be shipped a package from RITCHIE,ZIW LLC, BURTON Burgess Rd, Pensacola, Florida, bearing tracking number 798900631774, by FedEx to "Kyle," at The Green Beavis, in Mobile, Alabama. F. On or about September 6,2012, defendants RITCHIE and GALECKI, and other members of the conspiracy, shipped or caused to be shipped a kilogram of "AVALANCHE Vanilla Loose Bulk," costing $1,500.00, from Pensacola, Florida, bearing tracking number 798910044367,by FedEx to "Kyle," at The Green Beavis, in Mobile, Alabama. G. On October 10,2012, Anthony Notolli, who is not named as a defendant herein, sent a wire transfer from his Bank of America account ending 5448, in the amount $500,000, to "Attorney H. of A" in Pensacola, Florida. On or about October 25,2012, "Susan" at Ruechem, a chemical supplier in China, e-mailed defendant GALECKI advising him they had20 kilograms in stock for $1,250 per kilogram. I. On or about October 26,2012, defendant GALECKI emailed Brian Xu, a chemical supplier in China, about the purchase of "20" of 5FUR-1 44 and then forwarded a return email from Brian Xu with the wiring instructions relating to this transaction to Anthony Notolli. J. On or about October 30,2012, defendant GALECKI e-mailed Anthony Nottoli about "10" from "Jayson," who is not named as a defendant herein, for $20,000, along with wiring instructions. t0 Case 1:15-cr-00227-WS Document 1 Filed 10/29/15 Page 11 of 17 K. On November 3., 2012, defendant GALECKI sent an email instructing employees as to the order of production for the drugs. L. On or about November 20,2012, defendant RITCHIE caused $121,000 to be wire transferred from his Bank of America account ending in397l to a bank account held by Jason Fox, an XLRll M. broker, who is not named as a defendant herein. On or about December 10,2012, defendant RITCHIE received an incoming wire transfer into his bank account from Amy Lyntt, a company in Dallas, Texas. N. On December 31, 2012, a check, ending in#6494, drawn on "Attorney A's" trust account, made payable to ZIW in the amount of $500,000 was deposited into defendants RITCHIE O. and GALECKI's Gulf Coast Community Bank account ending in4740. On or about January 25,2013, a check in the amount of $466,030 drawn on BioNaturals, Inc., Robertsdale, Alabama, bank account at Wells Fargo ending in 0961, was deposited into RITCHIE's ZIVI Grand Valley Bank account ending 0102. P. On or about February 12,2013, defendant GALECKI deposited a cashier's check in the amount of $100,000 drawn on defendant RITCHIE's Grand Valley Bank account ending in 0102, into defendant GALECKI's Gulf Coast Community Bank Account ending 5754. a. On March 21,2013, defendant GALECKI deposited a cashier's check in the amount of $150,000, drawn on defendant RITCHIE's Zions First National Bank account ending in 5836, into defendant GALECKI's Gulf Coast Community Bank Account ending 2938. 11 Case 1:15-cr-00227-WS Document 1 Filed 10/29/15 Page 12 of 17 R. On or about March 20,2013, Anthony Nottoli and Crystal Henry, who are not named as defendants herein, and defendants GALECKI and RITCHIE met in the San Francisco, Califomia area to discuss the transfer of ZenBio to Henry. S. On or about January 2013, members of the conspiracy shipped and caused to be shipped products, referred to as "Bizarro," each package being misbranded drugs, to a customer in Tennessee, after receiving or causing the receipt of the product in interstate commerce. T. On or about February 2013, members of the conspiracy shipped and caused to be shipped products, referred to as "Bizarro," each package being misbranded drugs, to a customer in Maryland, after receiving or causing the receipt of the product in interstate coÍìmerce. U. On or about February 5,2013, co-conspirator Crystal Henry, who is not named as a defendant herein, sent an email to several individuals, to include co-conspirators Jim Vail and Travis Gross, who are not named as defendants herein, which stated Effective immediately, we need to discontinue to use the Wells Fargo bank account for depositing and wiring money. They have been giving us trouble the last week really investigating our account due to the nature of the large amount of money moving through. The end result is that V/ells Fargo is not welcome to banking with a business in our industry. V. On or about March 2013, members of the conspiracy shipped and caused to be shipped products, referred to as "Bizarro," each package being misbranded drugs, to a customer in Minnesota, after receiving or causing the receipt of the product in interstate commerce. T2 Case 1:15-cr-00227-WS Document 1 Filed 10/29/15 Page 13 of 17 W. On or about April4, 2013, members of the conspiracy caused bulk quantities of misbranded drugs to be shipped from China to the UPS store in Spanish Fort, Alabama, and to be repackaged and shipped to Califomia. All in violation of Title 18, United States Code, Section 371. COUNT FOUR The Grand Jury re-alleges and re-incorporates the introductory paragraphs if fully I - 8 above as set forth herein. From on or about August l,2llz,through and including April ll,2013,said dates being approximate, in the Southern District of Alabama, and elsewhere, the defendants, CHARLES BURTON RITCHIE and BENJAMIN EDWARD GALECKI, knowingly and intentionally combined, conspired and agreed with each other and with others, known and unknown to the Grand Jury, to commit an offense against the United States, that is: Wire Fraud, in violation of 18 U.S.C. $1343, by devising and intending to devise a scheme to defraud the Food and Drug Administration, to defraud the public, and to obtain money by materially false and fraudulent pretenses and representations, that is false pretenses and representations that the products their company, ZIW, manufactured and distributed were "spice," "incense," and "potpourri" and "not for human consumption" when, in truth and fact, they were synthetic drugs that contained chemicals, known as XLRl1 or 5FUR-I44,that were intended for human consumption as a drug. For the purpose of executing such scheme and artifice, RITCHIE and GALECKI used and caused to be used the wires to carry out and attempt to carry out an esscntial part of thc schcmc, including, but not limited to: engaging in electronic communications, such as emails and text messaging; and 13 Case 1:15-cr-00227-WS Document 1 Filed 10/29/15 Page 14 of 17 incoming wire transfers into the BioNaturals Inc., dbaZenBio, bank account ending in 0961 at Wells Fargo Bank in the Southern District of Alabama, all in violation of Title 18, United States Code, Section 1343. All in violation of Title 18, United States Code, Section 1349. Fonrnrrunn Norrcn Couxrs ONB & Foun- 18 U.S.C. I 1349 The allegations of Counts One and Four of this Indictment are hereby realleged and, by this reference, fully incorporated herein for the purpose of alleging forfeiture pursuant to the provisions of Title 18, United States Code, Section 981(a)(l)(C), and Title 28, United States Code, Section 2461(c); Title 18, United States Code, Section 982(a)(8)(A); and Title 18, United States Code, Section 982(aX8XB); Upon conviction of the felony offenses alleged in Count One or Count Four, defendants RITCHIE and GALECKI shall forfeit to the United States of America, any property, real or personal, which constitutes or is derived from proceeds traceable to the offenses alleged in Counts One or Four, including, but not limited to, the following: I. A2OT3LX57O LrxUS, VIN JTJHY7AX4D41IO626 2. 14 Marilyn Court, Park City, Utah 84060 and any and all improvements thereto. 3. 2294SouthBaxter Drive, Heber City, Utah 84032 4. A Money Judgment in the amount of $13,757,416.58 against RITCHIE, based upon the amounts of proceeds he obtained from such offenses. 5. A Money Judgment in the amount of $3,466,000 against GALECKI, based upon the amounts of prooeeds he obtainecl from such offenses. l4 Case 1:15-cr-00227-WS Document 1 Filed 10/29/15 Page 15 of 17 Fonrurrunn Noucn CouNr Two - U.S.C. S 1956(h) The allegations of Count Two of this Indictment are hereby realleged and, by this reference, fully incorporated herein for the purpose of alleging forfeiture pursuant to the provisions of Title 18, United States Code, Section 982(a)(1). Upon conviction of the felony offense alleged in Count Two, defendants RITCHIE and GALECKI shall forfeit to the United States of America, any property, real or personal, involved in such offense, or any property traceable to such property; including, but not limited to, the following: I A2013 LX570 Lexus, VIN JTJHYT AX4D4II0626 2. 14 3. 2294SouthBaxter Drive, Heber City, Utah 84032 4. A Money Judgment in the amount of $13,757,416.58 against RITCHIE, based upon Marilyn Court, Park City, Utah 84060 and any and all improvements thereto. the amounts of proceeds he obtained from such offenses. 5. A Money Judgment in the amount of $3,466,000 against GALECKI, based upon the amounts of proceeds he obtained from such offenses. The allegations contained in Count Three of this lndictment are re-alleged and incorporated by reference for the purpose of alleging forfeiture pursuant to the provisions of Title 18, United States Code, Section 981(a)(1)(C), and Title28, United States Code, Section 2ail@). Upon conviction of the felony offense alleged in Count Three, the defendants RITCHIE and GALECKI, shall forfeit to the United States any property, real or personal, which constitutes, or is derived from proceeds traceable to such offense, including but not limited to: 15 Case 1:15-cr-00227-WS Document 1 Filed 10/29/15 Page 16 of 17 1 A 2013 LX57 0 Lexus, VIN JTJHYT AX4D4I 10626 2. 14 3. 2294SouthBaxter Drive, Heber City, Utah 84032 4. A Money Judgment in the amount of $13,757 ,416.58 against RITCHIE, based Marilyn Court, Park City, Utah 84060 and any and all improvements thereto. upon the amounts of proceeds he obtained from such offenses. 5 A Money Judgment in the amount of $3,466,000 against GALECKI, based upon the amounts of proceeds he obtained from such offenses. SunsrrrurE ASSETS As To All Counrs If any of the property described above as being subject to forfeiture, as a result of any act or omission of the defendants, RITCHIE and GALECKI, (a) cannot be located upon the exercise ofdue diligence; (b) has been transferred or sold to, or deposited (c) has been placed beyond the (d) has been substantially diminished (e) has been commingled with, a third party; jurisdiction of the court; in value; or with other property which cannot be divided without diffi culty; it is the intent of the United States, pursuant to Title Title2l, United 18, United States Code, Section 982(bX1), States Code, Section 853(p), and Rule 32.2(e) Fed. R. Crim. P., to seek forfeiture of any other property of said defendants up to the value of the forfeitable property described above. A TRUE BILL THE GRAND JURY T6 Case 1:15-cr-00227-WS Document 1 Filed 10/29/15 Page 17 of 17 KENYEN R. BROWN TA A By: Davis Assistant U. S. Attorney Criminal Chief /, By: Deborah A. Griffin Assistant U. S. Attorney October 2015 17 Case 1:15-cr-00227-WS Document 1-2 Filed 10/29/15 Page 1 of 1 àl PENALTY PAGE CASE STYLE: DEFENDANTS: USAO NO.: AUSA: UNITED STATES v. CHARLES BURTON RITCHIE, Ct. AI. CHARLES BURTON RITCHIE (All Counts) BENJAMIN EDWARD GALECKI (All Counts) 15R00345 DEBORAH A. GRIFFIN CODE VIOLATIONS: COUNT COUNT COUNT 1: 2: 3: Mln 18 U.S.C. S 1349 (CoNsrrrucy ro Conrnnrr Fnauo) 18 U.S.C. S 1956(h) (CoNsrrnacy ro Covrvrrr MoNnv L.r.uNnnnrNc) 18 U.S.C. $ 371 (CoNSprRACy ro INTRoDUCE, RECEwn, Dnr,rvnR & 4: u.s.c. FORFEITURE NOTICE couNr rB $ ß4eìåT"Ïi:TiÏåiiiTiìì'ire PENALTIES: COUNTS & 4z 20 yrs to life/$250,000 fine/3 yrs SRT/$100 SA COUNT 2: 10 yrs /$250,000 fine/3 COUNT 3: 5 yrs/$250,000 fine/3 yrs SRT/$100 SA yrs SRT/$100 SA FORFEITURE 18 Fraud)