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Case 1:19-cr-00056-SOM Document 1 Filed 04/19/19 Page 2 of 7 PageID #: 2
Wire Fraud
(18 u.s.c. § 1343)
INTRODUCTORY ALLEGATIONS
Hana Nursery beginning on or about 2004 and continuing until her termination on
had access to Ki-Hana's Bank of Hawaii commercial bank account, business credit
activity, including all credits and debits were to be logged. As the bookkeeper for
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Case 1:19-cr-00056-SOM Document 1 Filed 04/19/19 Page 3 of 7 PageID #: 3
THE SCHEME
material facts.
PASCUA-SUYAT would fraudulently alter, mask and falsely represent the nature
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Case 1:19-cr-00056-SOM Document 1 Filed 04/19/19 Page 4 of 7 PageID #: 4
truth, such funds were not required or used for the stated business expenses, but
were in fact used by PASCUA-SUYAT to: (1) pay her American Express Card
and the American Express card of her husband, S.S.; (2) pay multiple Capital One
credit cards in both her name and S.S. 's name; and (3) make mortgage payments
on her personal mortgage with Seterus Inc., a loan servicing company. Due to
Hana' s business records, PASCUA-SUYAT was able to secret her scheme to steal,
convert and purloin the funds of Ki-Hana without detection for at least 8 years.
used, stole and wrongfully converted the funds of Ki-Hana Nursery to make
authorized user, on 291 occasions. Over the span of her scheme, PASCUA-
purpose.
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·- Case 1:19-cr-00056-SOM Document 1 Filed 04/19/19 Page 5 of 7 PageID #: 5
stole and wrongfully converted the funds of Ki-Hana Nursery to make payments
on her and S.S.'s personal Capital One credit cards on 112 occasions. Over the
stole and wrongfully converted the funds of Ki-Hana Nursery to pay the mortgage
WIRE COMMUNICATIONS
4. On or about each of the dates set forth below, within the District of
described below:
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Case 1:19-cr-00056-SOM Document 1 Filed 04/19/19 Page 6 of 7 PageID #: 6
DATE DESCRIPTION
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Case 1:19-cr-00056-SOM Document 1 Filed 04/19/19 Page 7 of 7 PageID #: 7
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United State A omey
District of Hawaii
KENNETH M. SORENSON
Assistant U.S. Attorney