CASE Document 70 Filed 12/20/17 Page 1 of 21

UNITED STATES DISTRICT COURT

DISTRICT OF MINNESOTA
UNITED STATES OF AMERICA, Criminal No. 17?64 

Plaintiff, FIRST SUPERSEDING
INDICTMENT
V. 
18 U.S.C. 1341
EDWARD S. ADAMS, 18 U.S.C. 1343
18 U.S.C. 2
Defendant. 26 U.S.C. 7206(1)

THE UNITED STATES GRAND IURY CHARGES THAT:
OVERVIEW

1. From at least in or about 2006 through at least in or about March 2013,
Defendant EDWARD S. ADAMS engaged in a scheme and arti?ce to defraud investors
in Apollo Diamond, Inc. (?Apollo Diamond?) and Apollo Diamond Gemstone Corporation
(?Apollo Gemstone?) (collectively, ?Apollo?) by misrepresenting that the investors?
money would be used to fund those companies? operations. Instead, ADAMS deposited
the investors? funds in accounts controlled by ADAMS and subsequently misappropriated
and embezzled millions of dollars for his personal use and bene?t. When these companies
were on the brink of insolvency, and in order to prevent his theft from being discovered,
ADAMS again duped the investors, convincing them to convert their shares of stock in
Apollo Diamond and Apollo Gemstone into shares of stock in a new company, Scio
Diamond Technology Corporation, which, unbeknownst to investors, ADAMS secretly
controlled. This transaction further enriched ADAMS, even as it lulled investors into

believing that their previous investments retained value.

 

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US. v. EDWARD S. ADAMS Criminal No. 17?64 

2. From in or around 2006 through in or around 2013, ADAMS stole over $4.38
million from Apollo Diamond and Apollo Gemstone investors by transferring investment
funds from Apollo and Scio accounts that he controlled to his own personal accounts for
his own use. During this same time period, ADAMS also paid his own law ?rm over
$2.54 million out of Apollo and Scio accounts that he controlled, even though his law ?rm
had already been paid $1.59 million by Apollo out of the company?s operating accounts.

GENERAL ALLEGATIONS

At all times relevant to this indictment:

Relevant Entities and Individuals

3. Apollo Diamond and Apollo Diamond Gemstone Corporation were both
Delaware corporations with their principal places of business in Massachusetts. Apollo?s
core business was the creation of laboratory?grown diamonds and diamond materials.
While Apollo Gemstone was purportedly a privately held subsidiary of Apollo Diamond,
the leadership, operations, and capital of the two entities were commingled, and they
effectively operated as a single corporate entity.

4. Defendant EDWARD S. ADAMS, a resident of Minneapolis, Minnesota,
was an attorney, licensed by the State of Minnesota, and a professor at the University of
Minnesota School of Law. ADAMS held various titles at Apollo Diamond and Apollo
Gemstone, including, at various times, Chief Financial Of?cer, Secretary, Executive Vice
President, and General Counsel of Apollo Diamond, and Chief Financial Of?cer, President,
Executive Vice President, Secretary, and member of the Board of Directors of Apollo

Gemstone.

 

 

 

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U.S. v. EDWARD S. ADAMS Criminal No. 17-64 

5. Adams Monahan LLP (formerly Adams, Monahan Sankovitz)
was a law ?rm, located in Minneapolis, Minnesota, of which ADAMS was
one of the two named partners. The vast majority of revenue came from work
that AMLLP purportedly performed for Apollo.

6. Scio Diamond Technology Corporation (?Scio?) was a publicly traded
corporation that came into existence in 2011 as the result of a transaction that ADAMS
designed and structured, purportedly to acquire the assets of Apollo.

7. ?Apollo Employee was the founder of Apollo Diamond, was a member
of the Board of Directors of both Apollo Diamond and Apollo Gemstone, and, at various
times, served as the Chairman, President, and Chief Executive Of?cer of Apollo Diamond
and the Chairman and Chief Technology Of?cer of Apollo Gemstone. Apollo Employee
A was also the father-in?law of ADAMS.

8. ?Apollo Employee had various roles at Apollo, including, at various
times, as a member of the Board of Directors and Chief Executive Of?cer and President of
Apollo Diamond, and Chief Executive Of?cer and President of Apollo Gemstone. Apollo
Employee was also the brother?in-law of ADAMS.

9. .Z. was an individual employed in the ?nancial services industry who
assisted Apollo in its fundraising efforts. .2. was responsible for raising millions of dollars
of investment money for Apollo. Due to ongoing and substantial material
misrepresentations and material omissions that ADAMS made to .Z., as well as material
omissions, ADAMS caused .Z. unknowingly to convey false and misleading information

to investors and potential investors in Apollo.

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US. v. EDWARD S. ADAMS Criminal No. 17-64 

THE SCHEME To DEFRAUD

10. In or around approximately 2003, at the direction of ADAMS, Apollo
retained Equity Securities, Inc., a ?nancial services ?rm located in Minneapolis,
Minnesota, of which ADAMS was a Principal at the time, to provide investment banking
services and to raise money for Apollo. Equity Securities was successful in raising over
$25 million for Apollo, for which Equity Securities received a commission of
approximately $3?4 million.

11. Subsequent to these fundraising efforts, ADAMS became increasingly
involved with Apollo, ?rst as outside legal counsel to the company and later in various
managerial positions with Apollo. Due to his familial relationship with Apollo Employee
A and Apollo Employee B, and the trust placed in him by these individuals, ADAMS
handled the ongoing fundraising efforts, with little or no oversight from Apollo Employee
A, Apollo Employee B, or anyone else at Apollo.

12. While Apollo Diamond and Apollo Gemstone each purported to have a
Board of Directors, and Apollo Employee A and Apollo Employee were nominal
members of these Boards, neither Board played an active role in overseeing the ?nancial
affairs of Apollo Diamond and Apollo Gemstone, and decisions relating to ?nancial
matters were routinely entrusted to ADAMS.

13. Taking advantage of the trust placed in him by Apollo Employee A and

Apollo Employee and the lack of oversight of his actions, as detailed below, ADAMS

created multiple bank accounts that purported to be accounts related to, and for the bene?t

 

 

 

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US. v. EDWARD S. ADAMS Criminal No. 17-64 

of, Apollo Diamond and Apollo Gemstone, and thereafter deposited investment money
intended for Apollo Diamond and Apollo Gemstone into these accounts.

14. ADAMS then transferred millions of dollars of Apollo investment funds
from these accounts into personal bank accounts controlled by ADAMS and the bank
account for his law ?rm, AMLLP. While AMLLP did perform services for Apollo,
ADAMS unilaterally determined how much Apollo would pay AMLLP, ADAMS himself
signed most of the checks for payments to AMLLP, and Apollo?s books and records did
not reflect most of the payments that ADAMS caused to be paid to AMLLP.

15. Throughout the course of this fraud scheme, and as set forth below, ADAMS
embezzled millions of dollars from Apollo and its investors for his own personal use and
benefit.

Investment Holdings?

16. In or around August 2006, ADAMS opened a bank account at Venture Bank
in Golden Valley, Minnesota, in the name of RL Investment Holdings, LLC 
Investments?). ADAMS was the sole signatory on this account, and bank statements for
this account were mailed to ADAMS at his law ?rm?s business address.

17. ADAMS, directly and indirectly through .2. and others, represented to
investors that they could invest and purchase shares in Apollo Diamond by making checks
payable to Investments.? ADAMS, or other individuals at AMLLP acting at his
direction, issued stock certi?cates representing shares in Apollo Diamond to investors who
wrote checks to RL Investments. ADAMS, directly or indirectly through .2. and others,

represented that the investments would be used for Apollo Diamond?s operations,

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US. v. EDWARD S. ADAMS Criminal No. 17?64 

including working capital, ?mding additional diamond growing equipment, and research
and development.

18. In some instances, ADAMS, directly and indirectly through J.Z. and others,
lied to investors about the source of the shares that investors would be purchasing, thereby
concealing the fact that ADAMS was diverting much of this money to himself.

19. From in or around August 2006 through in or around June 2008, relying on
these representations, individuals or entities who believed that they were investing in
Apollo Diamond wrote checks to RL Investments totaling approximately $2,400,000.
ADAMS deposited these funds into the RL Investments account.

20. Instead of transferring these funds to Apollo Diamond for use to further the
company?s operations, ADAMS surreptitiously diverted over $1.2 million of these
investors? funds to other bank accounts controlled by ADAMS and then spent the money
for his own use and enjoyment. ADAMS transferred an additional $101,500 to his law
firm?s bank account.

21. ADAMS distributed the remainder of the Apollo Diamond investors? funds
from the RL Investments account to various individuals as determined by ADAMS,
including over $500,000 to L.Z., a friend and former business partner of ADAMS.

22. ADAMS used none of the approximately $2.4 million that he deposited in
the RL Investments account for Apollo?s operations, in breach of his promise to the

investors to use their funds for that exclusive purpose.

 

 

 

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US. v. EDWARD S. ADAMS Criminal No. 17-64 

Investments?

23. In or around February 2007, ADAMS opened a bank account at Venture
Bank in Golden Valley, Minnesota, in the name of DL Investments, LLC 
Investments?). ADAMS was the sole signatory on this account, and bank statements for
this account were mailed to home address in Minneapolis, Minnesota.

24. ADAMS, directly and indirectly through .2. and others, represented to
investors that they could invest and purchase shares in Apollo Diamond by making checks
payable to Investments.? ADAMS, or other individuals at AMLLP acting at his
direction, issued stock certi?cates representing shares in Apollo Diamond to investors who
wrote checks to DL Investments. ADAMS, directly or indirectly through J.Z. and others,
represented that the investments would be used for Apollo Diamond?s operations,
including working capital, funding additional diamond growing equipment, and research
and development.

25. In some instances, ADAMS, directly and indirectly through .2. and others,
lied to investors about the source of the shares that investors would be purchasing, thereby
concealing the fact that ADAMS was diverting much of this money to himself.

26. From in or around March 2007 through in or around November 2007, relying
on these representations, individuals or entities who believed that they were investing in
Apollo Diamond wrote checks to DL Investments totaling approximately $1,720,000.
ADAMS deposited these funds into the DL Investments account at Venture Bank.

27. Instead of transferring these funds to Apollo Diamond for use to further the

company?s operations, ADAMS surreptitiously diverted over $857,000 of these investors?

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US. v. EDWARD S. ADAMS Criminal No. 17?64 

funds to other bank accounts controlled by ADAMS and then spent the money for his own
use and enjoyment. ADAMS transferred the remaining approximately $859,000 to his
friend and former business partner DZ.

28. ADAMS used none of the approximately $1.72 million that he deposited in
the DL Investments account for Apollo?s operations, in breach of his promise to the
investors to use their funds for that exclusive purpose.

Apollo Diamond and Apollo Gemstone Accounts Opened and Controlled by Adams

29. In or around 2007, ADAMS opened a bank account at Venture Bank in
Golden Valley, Minnesota, in the name of Apollo Diamond, as well as two bank accounts
in the name of Apollo Gemstone, one at Venture Bank and one at the First National Bank
of Waseca. ADAMS was the sole signatory on these accounts. Bank statements for the
Apollo Diamond account were mailed to home address in Minneapolis,
Minnesota, and bank statements for the Apollo Gemstone accounts were mailed to his law
?rm?s business address.

30. Although these accounts bore the names ?Apollo Diamond? and ?Apollo
Diamond Gemstone Corporation,? the accounts were not authorized by Apollo Diamond,
Apollo Gemstone, Apollo Employee A, or Apollo Employee B, and the activity in these
accounts was solely directed by, and visible to, ADAMS.

31. ADAMS solicited investments for Apollo Diamond and Apollo Gemstone
and represented, directly and indirectly, that the investments would be used for the
operations of Apollo Diamond and Apollo Gemstone, including working capital, funding

additional diamond growing equipment, and research and development. ADAMS

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US. v. EDWARD S. ADAMS Criminal No. 17-64 

deposited investors? funds intended for Apollo Diamond and Apollo Gemstone into the
Apollo Diamond and Apollo Gemstone accounts at Venture Bank and First Bank of
Waseca, and ADAMS, or other individuals at AMLLP acting at his direction, issued stock
certi?cates in Apollo Diamond or Apollo Gemstone to the investors.

32. ADAMS diverted large portions of these investors? funds for his own
personal use and bene?t without the knowledge and consent of Apollo Diamond, Apollo
Gemstone, Apollo Employee A, and Apollo Employee B, and without disclosing this
material fact to investors in Apollo Diamond and Apollo Gemstone.

33. ADAMS transferred over $938,000 to personal bank accounts controlled by
ADAMS and also transferred over $1,176,000 to the bank account for law ?rm,
from which he received distributions.

Investments?

34. In or around July 2009, ADAMS opened a bank account at Venture Bank in
Golden Valley, Minnesota, in the name of ADR Investments, LLC Investments?).
ADAMS was the sole signatory on this account, and bank statements for this account were
mailed to ADAMS at his law ?rm?s business address in Minneapolis, Minnesota.

35. Unlike the RL Investments and DL Investments accounts, Apollo Employee
A was aware of the existence of this account. ADAMS represented to Apollo Employee
A that certain ?warrants? owned by Apollo would be sold to fund this account and that the
proceeds would be used to pay outstanding bills of Apollo.

36. ADAMS, directly and indirectly through .2. and others, represented to

investors that they could invest and purchase shares in Apollo Diamond by making checks

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US. v. EDWARD S. ADAMS Criminal No. 17-64 

payable to Investments.? ADAMS, or other individuals at AMLLP acting at his
direction, issued stock certi?cates representing shares in Apollo Diamond to investors who
wrote checks to ADR Investments. ADAMS, directly or indirectly through J.Z. and others,
represented that the investments would be used for Apollo Diamond?s operations,
including working capital, funding additional diamond growing equipment, and research
and development

37. In some instances, ADAMS, directly and indirectly through .Z. and others,
lied to investors about the source of the shares that investors would be purchasing, thereby
concealing the fact that ADAMS was diverting much of this money to himself.

38. From in or around July 2009 through in or around March 2010, individuals
who believed that they were investing in Apollo Diamond wrote checks to ADR
Investments totaling approximately $2,710,000. ADAMS deposited these funds in the
ADR Investments account at Venture Bank.

39. ADAMS misappropriated and embezzled over $427,000 of these investment
funds for his own personal use and bene?t, transferring these funds into his personal bank
account. ADAMS also distributed over $125,000 to his law partner, M.M., and distributed
$50,000 to L.Z. ADAMS failed to disclose to investors that their investment funds would
be used for the personal use and bene?t of ADAMS and others selected by ADAMS.

40. Although ADAMS falsely represented to investors that their investments in
Apollo Diamond made via ADR Investments would be used to fund Apollo Diamond and
its operations, ADAMS continued diverting investors? funds to his personal account even

when Apollo Diamond was in dire need of capital to maintain its core operations. For

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US. v. EDWARD S. ADAMS Criminal No. 17?64 

example, in January 2010, L.L., an Apollo Diamond employee who handled various
accounting responsibilities, requested access to $15,000 of these ?inds to meet Apollo?s
basic operations. ADAMS falsely stated that no money was available. On the same day,
ADAMS transferred $100,000 from the ADR Investments account to his personal account
at Wells Fargo.

The Scio Diamond Technologr Corp. Lulling Scheme

41. Beginning around mid?2008, Apollo suffered severe ?nancial problems and
could not timely meet its ?nancial obligations. Apollo?s problems were caused and
compounded by embezzlement from Apollo, described above. By late 2010,
Apollo had become irretrievably insolvent and teetered on the brink of bankruptcy.

42. Expecting that bankruptcy would trigger litigation by shareholders of Apollo
Diamond and Apollo Gemstone, and fearful that such litigation would uncover 
embezzlement from Apollo, ADAMS devised a means of appeasing the shareholders, and
extending and continuing the scheme, by allowing the shareholders to convert their now
worthless investments in Apollo Diamond or Apollo Gemstone into investments in a new
entity.

43. Speci?cally, in March 2011, ADAMS and his law partner, M.M., created a
privately held company called Scio Diamond Technology Corporation (?Private Scio?).
ADAMS and M.M. incorporated Private Scio as a Nevada corporation on March 1, 2011.
ADAMS and M.M. were the sole shareholders, issuing themselves each 2,000,000 shares
of common stock of Private Scio. ADAMS and M.M. also named themselves as the only

two members of the board of directors of Private Scio.

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US. v. EDWARD S. ADAMS Criminal No. 17?64 

44. On March 11, 2011, ADAMS sent letters to Apollo Diamond and Apollo
Gemstone shareholders, informing them that the companies? fundraising and ?nancing
efforts had been unsuccessful and that the companies? ability to continue as going concerns
was in doubt. The letters noti?ed the shareholders that Apollo Diamond and Apollo
Gemstone had entered into asset purchase agreements with Private Scio, whereby Private
Scio would acquire the assets of Apollo Diamond for $2,000,000 and the assets of Apollo
Gemstone for $10,000.

45. To induce Apollo Diamond and Apollo Gemstone shareholders to approve
the transaction, ADAMS and M.M. structured the transaction so that Apollo Diamond and
Apollo Gemstone shareholders would be permitted (1) to sell back all of their shares in
Apollo Diamond and Apollo Gemstone for a penny, and (2) to purchase the same number
of shares in Private Scio for a penny. In other words, the shareholders, without expending
additional money, would receive the same number of shares in the new entity, Private Scio,
that they had held in Apollo Diamond and Apollo Gemstone.

46. ADAMS and M.M. concealed from Apollo shareholders that they
themselves had founded Private Scio and that they alone were the sole shareholders and
board members of Private Scio. Moreover, they intentionally misled Apollo shareholders
into believing that Private Scio was willing and able to pay the asset purchase price, when,
in fact, Private Scio was not yet capitalized and did not have the money necessary to
complete the asset purchase.

47. To insulate himself from potential litigation that would potentially uncover

his embezzlement from Apollo, ADAMS required all Apollo shareholders who wanted to

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US. v. EDWARD S. ADAMS Criminal No. 17?64 

participate in the share exchange and acquire shares in Private Scio to sign a covenant not
to sue, and to release any potential claims against Apollo Diamond, Apollo Gemstone, and
its of?cers, directors, advisors, and agents, including ADAMS. If an Apollo Diamond or
Apollo Gemstone shareholder was not willing to sign the agreement containing this release,
the shareholder was not permitted to complete the share exchange and receive shares in
Private Scio.

48. On or about April 18, 2011, at a shareholder meeting and by way of the
submission of proxies, shareholders of Apollo Diamond and Apollo Gemstone, in reliance
on misstatements and material omissions, approved the Private Scio transaction.

49. intention to lull the Apollo investors and avoid, or at least delay,
shareholder litigation that he feared would uncover his past theft and embezzlement was
made clear by his own description of the Scio transaction in a September 2011 email to
Apollo Employee A:

We were broke facing potential massive litigation from
disgruntled shareholders and I pulled a rabbit out of the hat 
for the last time by the way because if this does not work I am
spending my valuable time on something else.

50. Beginning in or around April 2011, the Apollo Diamond and Apollo
Gemstone shareholders sent their shares in Apollo Diamond or Apollo Gemstone to
AMLLP, along with the required Stock Repurchase Agreements through which investors
forfeited the right to sue Apollo and its of?cers, directors, advisors, and agents, including

ADAMS. ADAMS sent those shareholders checks for a penny per share of the stock that

each investor previously held. The process was not completed until in or around July 2012.

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US. v. EDWARD S. ADAMS Criminal No. 17?64 

51. From in or around April through in or around July 201 1, ADAMS and M.M.
solicited investments in Private Scio in an effort to raise the $2,010,000 that Private Scio
promised to pay to complete the asset purchase. Because ADAMS and M.M. could not
raise enough money, ADAMS had to devise another way to lull the former Apollo
Diamond and Apollo Gemstone investors, stave off inevitable litigation, and prevent the
detection of his ongoing fraud scheme.

52. Speci?cally, ADAMS arranged another transaction where Private Scio
would be acquired by a publicly traded shell entity, called Krossbow Holding Corporation,
and then would become a publicly traded company, also called Scio Diamond Technology
Corporation (?Public Scio?), which ADAMS could then use to raise the money necessary
to complete the Apollo asset purchase. The transaction occurred on August 5, 2011, and
was publicly announced on August 11, 2011.

53. Beyond accomplishing his goal of lulling the former Apollo Diamond and
Apollo Gemstone investors and preventing the detection of his earlier fraud, ADAMS saw
another opportunity to personally profit from this transaction. ADAMS structured the
transaction so that he and M.M. received (including shares granted to their spouses) at no
cost 4,100,000 shares each in Public Scio, and both also acquired another 1,000,000 shares
at a substantially reduced price. The former Apollo Diamond and Apollo Gemstone
shareholders received nothing as a result of this transaction.

54. On August 31, 201 1, Public Scio, of which ADAMS now beneficially owned
over 5 million shares, announced that it had agreed to acquire the assets of Apollo Diamond

for the sum of $2,000,000. The former Apollo Diamond shareholders had no opportunity

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US. v. EDWARD S. ADAMS Criminal No. 17-64 

to approve or reject this transaction. Instead, at the direction and upon the advice of
ADAMS, Apollo Employee A approved and signed the asset purchase agreement on behalf
of Apollo Diamond.

55. To fund the purchase of assets from Apollo Diamond, ADAMS solicited,
directly and indirectly, new investors in Public Scio, at a price of $0.70 per share. ADAMS
failed to disclose to these new investors that former Apollo Diamond and Apollo Gemstone
shareholders had been promised the right to buy millions of shares of Public Scio at a penny
a share.

56. After raising enough money from new investments in Public Scio, ADAMS,
through a series of transactions, caused Public Scio to pay the $2,000,000 purchase price
for Apollo Diamond?s assets, much of which he took for himself. ADAMS transferred
over $800,000 into his personal accounts and transferred an additional $550,000 to the
bank account for law ?rm.

57. As noted above, in April 2011, the former Apollo Gemstone shareholders
had agreed to sell the assets of Apollo Gemstone for $10,000. In June 2012, however,
ADAMS unilaterally increased the purchase price to $100,000, falsely representing to
Public Scio?s management that Apollo Gemstone?s sole remaining shareholder, Apollo
Employee A, had demanded an increase in the price. In or around January 2013, Public
Scio paid $100,000 to Apollo Gemstone, which ADAMS deposited in the Apollo
Gemstone account at Venture Bank that ADAMS controlled. Of this money, ADAMS

distributed $33,000 to himself, and $33,000 each to Apollo Employee A and Apollo

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US. v. EDWARD S. ADAMS Criminal No. 17-64 

Employee B. In or around April 2013, ADAMS closed the Apollo Gemstone account at
Venture Bank, transferring the remaining $1,271.75 to his personal account.

58. While the lulling scheme implemented by ADAMS began in 2011 when
Apollo Diamond and Apollo Gemstone shareholders began redeeming their Apollo
Diamond and/or Apollo Gemstone shares for a penny a share, the process was not
completed until these shareholders purchased shares in Public Scio at a penny a share by
sending checks and signed subscription agreements and received stock certi?cates
representing their shares owned in Public Scio. This process took place from in or around
June 2012 through in or around March 2013.

59. By completing this transaction that ADAMS had designed and implemented,
the former Apollo Diamond and Apollo Gemstone shareholders now held shares in a
publicly traded, operating company, which appeared to them as a better option than
retaining shares in entities that they were informed were on the verge of insolvency.
plan succeeded, and he was able to avoid ?potential massive litigation from
disgruntled shareholders? and prevent investors from discovering that he had stolen
millions of dollars of Apollo investors? money, all while lining his pockets with additional

money from new investors in Public Scio.

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