Case ECF No. 1 filed 12/11/18 PagelD.1 Page 1 of 5 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION UNITED STATES OF AMERICA, Plaintiff, Offenses: Count 1: 18 U.S.C. 371 Conspiracy to Defraud the United States - V. D-1 JAYSON ROSETT, D-2 ROBERT ROSETT, D's CAROL ALMERANTL and Judge: Leitman, Matthew MJ: Davis, Stephanie Dawkms D-4 KAREN MILLER, Filed: 12?11-2018At 10:53 AM INFO USA 12mg: Defendants_ FLINT, MICHIGAN INFORMATION THE ACTING PRINCIPAL DEPUTY ASSISTANT ATTORNEY GENERAL CHARGES THAT: At all times relevant to this Information, unless othenrvise indicated: COUNT 1 18 U.S.C. 371 Conspiracy to Defraud the United States 1. Defendant JAYSON ROSETT, a resident of Bloomfield Hills, Michigan, owned and operated ENTITY 2. - Defendant ROBERT ROSETT, a resident of Boca Raton, Florida, owned and operated ENTITY B. 5 Case ECF No. 1 filed 12/11/18 PagelD.2 Page 2 of 5 3. Defendant CAROL ALMERANTI was a resident of Farmington Hills, Michigan. 4. Defendant KAREN MILLER was a resident of St. Clair Shores, Michigan. 5. From at least in or about January of 2012, through in or about April of 2018, in the Eastern District of Michigan and elsewhere, Defendants JAYSON ROSETT, ROBERT ROSETT, CAROL ALMERANTI, and KAREN MILLER, together and with others both known and unknown, did unlawfully, voluntarily, intentionally, and knowingly conspire, combine, confederate, and agree together and with each other to defraud the United States for the purpose Of impeding, impairing, obstructing, and defeating the lawful government functions of the Internal Revenue Service of the Treasury Department in the ascertainment, computation, assessment, and collection of the revenue: to wit, income taxes, in violation of Title 18, United States Code, Section 371. Manner and Means of the 6. To accomplish the object of this conspiracy, Defendants JAYSON ROSETT, ROBERT ROSETT, CAROL ALMERANTI, and KAREN MILLER, together with each other and others known and unknown, used the following manner and means, among others: a. From at least in or about July of 2012, through in or about April of 2018, Defendants JAYSON ROSETT, ROBERT ROSETT, and others paid funds to Defendants CAROL ALMERANTI and KAREN MILLER. b. To conceal from the IRS the receipt of taxable income by Defendants CAROL ALMERANTI and KAREN MILLER, and the expenses incurred by Case ECF No. 1 filed 12/11/18 PageI-D.3 Page 3 of 5 Defendants JAYSON ROSETT and ROBERT ROSETT, Defendants JAYSON. ROSETT and ROBERT ROSETT paid Defendants CAROL ALMERANTI and KAREN MILLER through a series of entities. c. Defendant JAYSON ROSETT, through ENTITY A, sent funds to Defendant ROBERT ROSETT, through ENTITY B. d. Defendants ROBERT ROSETT and CAROL ALMERANTI opened a bank account where they were both signors (?the shared bank account?). 9. From inor about November of 2012, through April of 2018, Defendant ROBERT ROSETT caused ENTITY to disburse funds into the shared bank account he held with Defendant CAROL ALMERANTI. f. Defendants CAROL ALMERANTI and KAREN MILLER withdrew funds from the shared bank account using debit cards at ATM machines. g. Defendants CAROL ALMERANTI and KAREN MILLER failed to report the taxable income received from Defendants JAYSON ROSETT and ROBERT ROSETT on their individual income tax returns. h. Defendants JAYSON ROSETT and ROBERT ROSETT failed to . report the payments made to Defendants CAROL ALMERANTI and KAREN MILLER as expenses on business tax returns filed for ENTITY A and ENTITY B, respectively. Overt Acts 7. In furtherance of the conspiracy, and to accomplish its purposes and objects, at least one of the conspirators committed, or caused to be committed, in the Eastern District of Michigan, the following overt acts, among others: Case ECF No. 1 filed 12/11/18 _PagelD.4 Page 4 of 5 a. On or about November 9, 2012, Defendant ROBERT ROSETT and Defendant CAROL ALMERANTI opened the shared bank account to ensure I Defendants CAROL ALMERANTI and KAREN MILLER could easily receive funds. From in or about November of 2012, through April of 2018, Defendant ROBERT ROSETT caused ENTITY to disburse funds totaling over $375,000 into the joint bank account for withdrawal by Defendants CAROL ALMERANTI and KAREN MILLER. b. On or about December 30, 2013, Defendant CAROL ALMERANTI withdrew approximately $500 of funds from the shared account. c. On or about January 3, 2014, Defendant KAREN MILLER withdrew approximately $500 of funds from the shared account. All in violation of Title 18, United States Code, Section 371. Date: DeCember 11, 2018 STUART M. GOLDBERG Acting Principal Deputy Assistant Attorney General US. Department of Justice Tax Division Mark McDonald MARK MCDONALD WILLIAM GUAPPONE Trial Attorneys US. Department of Justice Tax Division Case ECF No. 1 filed 12/11/18 PageID.5 Page 50f 5 Companion Case information MUST be completed I: Case??amzosos - United States District Court Criminal case Judge. Leitman Matthew Eastern District of Michigan - MJ Davis Stephanie Dawkins Filed: 09-07-2018 At 01:48 PM NOTE: It is the responsibilityof the Assistant U.s. Attorney signing this fermi INFO USA MADIHA (5k) Companion Case Number: This may be a companion case based upon 57.10 Judge Assigned: Yes No Initials: MSM ?:JnnIEm Case Title: USA V- Jayson Rosett, Robert Rosett, Carol Almeranti, Kare: [LlailleDEC 1 1 2013 County where offense occurred Genesee Countv 3 DISTRICT courn~ FLINT, MICHIGAN Check One: lFelony El Misdemeanor Petty -- no prior complaint. __lndictmentlm__lnformation based upon prior complaint [Case number: I -- based upon 57.10 [Complete Superseding section below]. Superseding to Case No: Judge: El Original case was terminated; no additional charges or defendants. Corrects errors; no additional charges or defendants. involves, for plea purposes, different charges or adds counts. Embraces same subject matter but adds the additional defendants or charges below: Defendant name Charges - Prior Com laint ifa licable Please take notice that the below listed Assistant United States Attorney is the attorney of record for the above captioned case. December 11, 2018 Date Mark McDonald Assistant United States Attorney 210 Federal Building 600 Church Street Flint, Michigan 48502 Telephone: (810) 766-5177 Email: mark.s.mcdonald@usdoj.gov Companion cases are matters In which it appears that (1) substantially similar evidence will be offered at trial, (2) the same or related parties are present, and the cases arise out of the same transaction or occurrence. Cases may be companion cases even though one of them may have already been terminated. 031112013