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ES “ SEALED — [rxSESR © ee INTHE UNITED STATES DISTRICT couRti_ FED Z FOR THE NORTHERN DISTRICT OF TEXAS. DALLAS DIVISION UNITED STATES OF AMERICA § § bee v. lo. - S P-990R 247°? EUGENE J. LOCKHART, JR. (01) § PEBD-ENDERSEAL unsealed WILLIAM RANDOLPH TISDALE, JR. (02) § HUBERT JONES, lil (03) § LENDELL BEACHAM (04) § PATRICIA ORTEGA SUAREZ (05) § SUZETTE SWITZER HINDS (06) § MICHAEL ANTHONY CALDWELL (07) § DONNA LOIS KNEELAND (08) § BRYAN J, MOORMAN (09) § INDICTMENT ‘The Grand Jury Charges: Conspiracy to Commit Bank Fraud and Wire Praud (Violation of 18 U.S.C. § 1349 (18 U.S.C. §§ 1343 and 1344) Atall times material to the indictment: Introduction 1, Countrywide Bank (Countrywide), a division of Treasury Bank, N.A., Dallas, Texas was a financial institution with its principle place of business located in Dallas, Texas. ‘The accounts of Countrywide and Treasury Bank, N.A. were insured by the Federal Deposit Insurance Corporation (FDIC). 2, Long Beach Mortgage Corporation (Loig Beach), 4 division of Washington Mutual Bank, was a financial institution with its principle place of business located in Indictment - Page 1 Orange, California, ‘The accounts of Long Beach and Washington Mutual Bank were insured by the Federal Deposit Insurance Corporation (FDIC). 3, WMC Mortgage Corporation (WMC) was « mortgage lending institution engaged in the business of funding residential loans to qualified borrowers with its principle place of business Jocated in Woodland Hills, California, 4, First Magons Financial Corporation was « mortgage lending institution with its principle place of business located in Tucson, Arizona, and was engaged in the business of funding residential loans to qualified borrowers, 5, Security National Mortgage Corporation was « mortgage lending institution with its prinejple place of business Jocated in Murray, Utah, and was engaged in the business of funding residential loans to qualified borrowers. | 6. Realty Mortgage Corporation was # mortgage lending institution with its | principle place of business located in Flowood, Mississippi, and was engaged in the business of funding residential loans to qualified borrowers. 7. People's Choice Home Loans, Inc, was 2 mortgage lending institution with its principle place of business located in Irvine, California, and was engaged in the | business of funding residential loans to qualified bomowers. | 8. Fieldstone Mortgage Company (Fieldstone) was a mortgage lending institution with its principle place of business located in Columbia, Maryland, and was engaged in the business of funding residential loans to qualified borrowers. 9, An “Escrow Account” was a bank account for holding and disbursing funds to be paid to and on behalf of parties to a transaction, Indictment - Page 2 10, The term “Disbursement” means payments from the Escrow Account in connection with the transaction, Il, The term “Straw Buyer” in real estate transactions was a person who agreed to allow his name, personal identifiers, and credit rating to be used to secure a mortgage for the purchase of real property. The straw buyer did not intend to either pay any closing costs, make all loan payments, or occupy the property. A person was generally paid a fee in return for his agreement to act as a straw buyer. Each straw buyer was considered an investor in the property, and never intended to occupy the property as a primary residence, 12. The term “HUD-1” referred to the uniform settlement statement which should accurately account for all funds involved in a particular real estate closing, The escrow officer certifies on each HUD-I that the document is # true and accurate account of the transaction. Defendants and Related Entities 13, Eugene J. Lockhart was involved in some capacity with one or more real estate entities related to charges alleged in this indictment, to include: America’s"Team'* Mortgage; America’s Team Realty; Americe’s Team Funding Group; Ace Mortgage; Cowboys Realty; Cowboys Mortgage; and KLT Properties, 14, William Randolph Tisdale, Jr. was involved in some capacity with one or more real estate entities related to charges alleged in this indictment, to include: Pinnacle Development and Realty Corporation; Atilla Capital Corporation; and KLT Properties. 15, Hubert Jones, IIT was involved in some capacity with one or more real estate entities related to charges alleged in this indictment, to include: Pinnacle Indictment - Page 3