UNITED STATES DISTRICT COURT SOUTHERN … ABDUL HAKIM MUHAMMAD, and KWASI DRAKES, the defendants, and others known and unknown, unlawfully, willfully and knowingly did combine, conspire,

UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF NEW YORK- - - - - - - - - - - - - - - - - -X

UNITED STATES OF AMERICA :

-v.- : SEALED INDICTMENT

BEVERLY MOZER-BROWNE, : 06 Cr.PHILLIP A. BROWNE,SANDFORD BROWNE, : a/k/a “Tyson,”GERRARDA BROWNE, : a/k/a “Gerry,”WILLIANA BROWNE, :JOHN LOFTON, a/k/a “Big John,” :PETER ABSOLAM, a/k/a “Lloyd,” :KEITH MAHASE, ABDUL HAKIM MUHAMMAD, :TIFFANY WAYMAN, NARRISA MOHAMMED, :JAMSHEED JEREMIAH, a/k/a “Jason,” :KHADIGA CLARKE, a/k/a “Kelly,” :LENNARD PRESCOD, a/k/a “Bob,” :MAKEBA ISAROON,RHONDA EATON, :RODERICK CHASSEAU, CAMERON A. LLOYD, :KWASI DRAKES,NARINE JAIRAM, :CHERYLENE RAMDASS, TULSI RAMRUP, :NATASHA HERCULES, ANNEKA RAMPERSAD, :TASLEEM KUDRATH, MERVIN TRANCOSO, :ADRIAN GOURSAHAB, NIGEL DEFOUR, :WENDY HARRISON, and KERRY RAMPERSAD, :

Defendants. :

- - - - - - - - - - - - - - - - - -X

2

COUNT ONE

(Conspiracy to Commit Visa Fraud)

The Grand Jury charges:

Background

1. BEVERLY MOZER-BROWNE, the defendant (“MOZER-

BROWNE”), owned and operated a business called Help Preparers

Professional Services (“HPPS”), located at 106-16 Jamaica Avenue

in Queens, New York.

2. HPPS purported to offer its customers assistance

in a variety of financial and legal matters, but in fact, the

primary business at HPPS was providing permanent residence

documents (“green cards”) by means of fraud.

3. SANDFORD BROWNE, a/k/a “Tyson,” GERRARDA BROWNE,

a/k/a “Gerry,” WILLIANA BROWNE, PETER ABSOLAM, a/k/a “Lloyd,”

KEITH MAHASE, ABDUL HAKIM MUHAMMAD, NARRISA MOHAMMED, JAMSHEED

JEREMIAH, a/k/a “Jason,” KHADIGA CLARKE, a/k/a “Kelly,” LENNARD

PRESCOD, a/k/a “Bob,” RODERICK CHASSEAU, CAMERON A. LLOYD, and

KWASI DRAKES, the defendants, were all employed by HPPS to assist

in its illegal activity.

4. Until in or about December 2005, PHILLIP A.

BROWNE, the defendant (“BROWNE”), MOZER-BROWNE’s brother, was

employed as a District Adjudication Officer by the United States

Citizenship and Immigration Services (“CIS”) (formerly known as

3

the “Immigration and Naturalization Service” or “INS”) at 26

Federal Plaza, New York, New York.

5. MOZER-BROWNE and her co-conspirators at HPPS

charged an applicant anywhere from approximately $8,000 to

approximately $16,000 to provide a green card by means of fraud.

A person seeking these services (an “HPPS applicant”) was

typically provided with documentation of marriage to a United

States citizen in one of two ways: Either MOZER-BROWNE and her

co-conspirators would pay a United States citizen to enter into a

sham marriage with the HPPS applicant, or they would produce

phony documentation indicating that a marriage to a United States

citizen had occurred at some time in the past.

6. JOHN LOFTON, a/k/a “Big John,” and RHONDA EATON,

the defendants, helped MOZER-BROWNE and HPPS find United States

citizens willing to enter into sham marriages with HPPS

applicants. TIFFANY WAYMAN and MAKEBA ISAROON, the defendants,

were two United States citizens paid by HPPS to enter into sham

marriages with HPPS applicants. CAMERON A. LLOYD, the defendant,

performed sham marriages for HPPS applicants.

7. Once the HPPS applicant had documentation of a

marriage to a United States citizen, employees at HPPS would

prepare an application package for a green card. The application

usually included fraudulent financial information, such as

4

fictitious letters from employers or banks. The application was

then mailed to CIS.

8. Following the submission of the fraudulent

application, the HPPS applicant received an appointment for an

interview at the CIS office at 26 Federal Plaza. BROWNE then

approved the applications submitted by his co-conspirators at

HPPS without requiring the HPPS applicant to appear at CIS for

the interview. BROWNE generated a Form I-181 (“Memorandum of

Creation of Record of Lawful Permanent Residence”) on behalf of

the HPPS applicant, and a green card was issued to the HPPS

applicant.

9. From at least in or about April 2001 through in or

about November 2005, MOZER-BROWNE, BROWNE, and their co-

conspirators provided hundreds of fraudulent green cards to HPPS

applicants, receiving more than one million dollars in proceeds.

Statutory Allegation

10. From at least in or about April 2001 through in or

about November 2005, in the Southern District of New York and

elsewhere, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, SANDFORD

BROWNE, a/k/a “Tyson,” GERRARDA BROWNE, a/k/a “Gerry,” WILLIANA

BROWNE, JOHN LOFTON, a/k/a “Big John,” PETER ABSOLAM, a/k/a

“Lloyd,” KEITH MAHASE, ABDUL HAKIM MUHAMMAD, TIFFANY WAYMAN,

NARRISA MOHAMMED, JAMSHEED JEREMIAH, a/k/a “Jason,” KHADIGA

CLARKE, a/k/a “Kelly,” LENNARD PRESCOD, a/k/a “Bob,” MAKEBA

5

ISAROON, RHONDA EATON, RODERICK CHASSEAU, CAMERON A. LLOYD, and

KWASI DRAKES, the defendants, and others known and unknown,

unlawfully, willfully, and knowingly combined, conspired,

confederated, and agreed together and with each other to commit

an offense against the United States, to wit, violations of

Section 1546 of Title 18, United States Code.

11. It was a part and an object of the conspiracy that

BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, SANDFORD BROWNE, a/k/a

“Tyson,” GERRARDA BROWNE, a/k/a “Gerry,” WILLIANA BROWNE, JOHN

LOFTON, a/k/a “Big John,” PETER ABSOLAM, a/k/a “Lloyd,” KEITH

MAHASE, ABDUL HAKIM MUHAMMAD, TIFFANY WAYMAN, NARRISA MOHAMMED,

JAMSHEED JEREMIAH, a/k/a “Jason,” KHADIGA CLARKE, a/k/a “Kelly,”

LENNARD PRESCOD, a/k/a “Bob,” MAKEBA ISAROON, RHONDA EATON,

RODERICK CHASSEAU, CAMERON A. LLOYD, and KWASI DRAKES, the

defendants, and others known and unknown, unlawfully, willfully

and knowingly would and did utter, use, possess, obtain, accept

and receive immigrant and nonimmigrant visas, permits, alien

registration receipt cards, and other documents prescribed by

statute and regulation as evidence of authorized stay and

employment in the United States, knowing them to have been

procured by means of false claims and statements, and to have

been otherwise procured by fraud and unlawfully obtained, in

violation of Title 18, United States Code, Section 1546.

6

Overt Acts

12. In furtherance of the conspiracy and to effect the

illegal object thereof, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE,

SANDFORD BROWNE, a/k/a “Tyson,” GERRARDA BROWNE, a/k/a “Gerry,”

WILLIANA BROWNE, JOHN LOFTON, a/k/a “Big John,” PETER ABSOLAM,

a/k/a “Lloyd,” KEITH MAHASE, ABDUL HAKIM MUHAMMAD, TIFFANY

WAYMAN, NARRISA MOHAMMED, JAMSHEED JEREMIAH, a/k/a “Jason,”

KHADIGA CLARKE, a/k/a “Kelly,” LENNARD PRESCOD, a/k/a “Bob,”

MAKEBA ISAROON, RHONDA EATON, RODERICK CHASSEAU, CAMERON A.

LLOYD, and KWASI DRAKES, the defendants, and others known and

unknown, committed the following overt acts, among others, in the

Southern District of New York and elsewhere:

a. In or about April 2001, RODERICK CHASSEAU,

the defendant, submitted a fraudulent green card application to

CIS (then INS).

b. In or about August 2003, JAMSHEED JEREMIAH,

a/k/a “Jason,” the defendant, submitted a fraudulent green card

application to CIS.

c. In or about January 2004, NARRISA MOHAMMED,

the defendant, submitted a fraudulent green card application to

CIS.

d. In or about March 2004, RHONDA EATON, the

defendant, submitted a fraudulent Petition For Alien Relative to

CIS.

7

e. On or about May 14, 2004, ABDUL HAKIM

MUHAMMAD, the defendant, deposited approximately $9,000 in cash

proceeds into his checking account at New York Community Bank.

f. In or about May 2004, SANDFORD BROWNE, a/k/a

“Tyson,” the defendant, submitted a fraudulent green card

application to CIS.

g. In or about May 2004, WILLIANA BROWNE, the

defendant, submitted a fraudulent green card application to CIS.

h. In or about June 2004, KHADIGA CLARKE, a/k/a

“Kelly,” the defendant, submitted a fraudulent green card

application to CIS.

i. On or about June 24, 2004, MAKEBA ISAROON,

the defendant, entered into a fraudulent marriage with an HPPS

applicant.

j. On or about August 4, 2004, PHILLIP A. BROWNE

approved SANDFORD BROWNE’s fraudulent application for a green

card at CIS in New York, New York.

k. In or about August 2004, KEITH MAHASE, the

defendant, submitted a fraudulent green card application to CIS.

l. On or about August 30, 2004, KWASI DRAKES,

the defendant, deposited approximately $9,000 in cash into her

checking account at Chase.

8

m. In or about September 2004, GERRARDA BROWNE,

a/k/a “Gerry,” the defendant, submitted a fraudulent green card

application to CIS.

n. On or about March 14, 2005, CAMERON A. LLOYD,

the defendant, conducted a sham marriage ceremony for an HPPS

applicant.

o. On or about May 27, 2005, PETER ABSOLAM,

a/k/a “Lloyd,” the defendant, introduced an HPPS applicant for a

fraudulent green card (“Applicant-1”) to MOZER-BROWNE.

p. On or about June 15, 2005, MOZER-BROWNE,

RHONDA EATON, and JOHN LOFTON, a/k/a “Big John,” the defendants,

introduced Applicant-1 to TIFFANY WAYMAN, who was paid to enter

into a sham marriage with Applicant-1.

q. On or about June 15, 2005, TIFFANY WAYMAN

applied for and obtained a license to marry Applicant-1.

r. On or about November 9, 2005, LENNARD

PRESCOD, a/k/a “Bob,” provided fraudulent birth certificates to a

confidential informant in exchange for cash.

(Title 18, United States Code, Sections 371.)

COUNT TWO

(Money Laundering Conspiracy)

The Grand Jury further charges:

13. From at least in or about March 2004, up to and

including at least in or about May 2005, in the Southern District

9

of New York and elsewhere, BEVERLY MOZER-BROWNE, PHILLIP A.

BROWNE, ABDUL HAKIM MUHAMMAD, and KWASI DRAKES, the defendants,

and others known and unknown, unlawfully, willfully and knowingly

did combine, conspire, confederate and agree together and with

each other to commit offenses against the United States, to wit,

violations of Title 18, United States Code, Section

1956(a)(1)(B)(i).

14. It was a part and an object of said conspiracy

that BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, ABDUL HAKIM

MUHAMMAD, and KWASI DRAKES, the defendants, and others known and

unknown, in an offense involving and affecting interstate and

foreign commerce, knowing that property involved in certain

financial transactions represented the proceeds of some form of

unlawful activity, unlawfully, willfully, and knowingly would and

did conduct and attempt to conduct financial transactions, which

in fact involved the proceeds of specified unlawful activity, to

wit, visa fraud, knowing that the transactions were designed in

whole and in part to conceal and disguise the nature, location,

source, ownership and control of the proceeds of specified

unlawful activity, in violation of Title 18, United States Code,

Section 1956(a)(1)(B)(i).

Means and Methods of the Conspiracy

15. Among the means and methods employed in conducting

and participating in the conduct of the conspiracy were the

following:

10

a. BEVERLY MOZER-BROWNE (“MOZER-BROWNE”) and

PHILLIP A. BROWNE (“BROWNE”), the defendants, and their co-

conspirators made large cash deposits of visa fraud proceeds into

bank accounts at various financial institutions, usually in

amounts smaller than $10,000.

b. In order to conceal the illegal source of the

cash, ABDUL HAKIM MUHAMMAD (“MUHAMMAD”) and KWASI DRAKES

(“DRAKES”), the defendants, made large cash deposits and then

transferred the money into accounts controlled by MOZER-BROWNE or

members of her family, or withdrew the money by writing checks to

MOZER-BROWNE or members of her family.

c. In addition to dividing the cash proceeds

from the visa fraud conspiracy among different bank accounts,

MOZER-BROWNE and her co-conspirators concealed the proceeds by

purchasing a number of properties, including several properties

in Florida, held in various straw purchasers’ names.

Overt Acts

16. In furtherance of said conspiracy and to effect

the illegal object thereof, BEVERLY MOZER-BROWNE, PHILLIP A.

BROWNE, ABDUL HAKIM MUHAMMAD, and KWASI DRAKES, the defendants,

and others known and unknown, committed the following overt acts,

among others, in the Southern District of New York and elsewhere:

a. On or about March 8, 2004, MOZER-BROWNE

deposited approximately $22,400 (including $7,400 in cash) into

11

her checking account at a Chase bank branch in New York, New

York.

b. On or about March 15, 2004, MOZER-BROWNE

deposited approximately $7,500 (including $7,000 in cash and a

$500 check made out to “Kwasi Drakes”) into her checking account

at a Chase bank branch in New York, New York.

c. On or about May 14, 2004, MUHAMMAD deposited

approximately $9,000 in cash into his checking account at New

York Community Bank.

d. On or about May 24, 2004, MUHAMMAD deposited

approximately $9,000 into his checking account at New York

Community Bank.

e. On or about June 9, 2004, MOZER-BROWNE

deposited approximately $9,000 in cash into her bank account at

Chase.

f. On or about June 9, 2004, DRAKES deposited

approximately $3,000 into her bank account at Chase.

g. On or about June 10, 2004, DRAKES deposited

approximately $3,900 into her bank account at Chase.

h. On or about June 10, 2004, DRAKES transferred

approximately $4,000 from her account at Chase into MOZER-

BROWNE’s Chase account.

12

i. On or about July 1, 2004, MOZER-BROWNE

deposited a check for approximately $27,000 to her checking

account at a Chase bank branch in New York, New York.

j. On or about August 30, 2004, MOZER-BROWNE

deposited approximately $9,000 in cash into her bank account at

Chase.

k. On or about August 30, 2004, DRAKES deposited

approximately $9,000 in cash into her bank account at Chase.

l. On or about August 30, 2004, DRAKES

transferred approximately $9,000 from her account into MOZER-


m. On or about September 1, 2004, MOZER-BROWNE

deposited approximately $13,000 into her bank account at Chase.

n. On or about September 1, 2004, DRAKES

deposited approximately $4,600 in cash into her account at Chase.

o. On or about September 1, 2004, DRAKES



p. On or about September 10, 2004, MOZER-BROWNE


q. On or about September 10, 2004, DRAKES made

two deposits into her bank account at Chase: one for

approximately $7,000 and one for approximately $5,000.

13

r. On or about September 17, 2004, DRAKES



s. On or about December 2, 2004, MUHAMMAD made

two deposits totaling $9,400 in cash into his account at New York

Community Bank.

t. On or about December 2, 2004, DRAKES


u. On or about December 2, 2004, DRAKES wrote a

check for $9,000 from her Chase account made out to a co-

conspirator’s relative (“Relative-1”) with a memo indicating

“gift towards purchase of house.”

v. On or about December 3, 2004, MUHAMMAD wrote

a check for approximately $9,000 from his New York Community Bank

account to Relative-1 with a memo indicating “loan to purchase

house.”

w. On or about December 3, 2004, MOZER-BROWNE


x. On or about December 3, 2004, MOZER-BROWNE

wrote a check for approximately $8,500 from her Chase account to

Relative-1 with a memo “gift to son for purchase of property.”

y. On or about December 17, 2004, MOZER-BROWNE

deposited approximately $9,000 into her checking account at

Chase.

14

z. On or about December 17, 2004, MOZER-BROWNE

wired approximately $9,000 from her Chase checking account to

“Prominent Title Insurance.”

aa. On or about December 17, 2004, DRAKES


bb. On or about December 17, 2004, DRAKES

transferred approximately $9,179.72 from her Chase checking

account to “Prominent Title Insurance.”

cc. On or about December 21, 2004, BROWNE

deposited approximately $9,228.44 into his savings account at

Washington Mutual Bank.

dd. On or about December 21, 2004, BROWNE

withdrew an official check for approximately $9,228.44 from his

savings account at Washington Mutual Bank made out to “Prominent

Title Insurance.”

ee. On or about January 13, 2005, MUHAMMAD

deposited approximately $5,000 in cash into his account at New

York Community Bank.

ff. On or about January 24, 2005, BROWNE

deposited approximately $8,000 in cash into his account at


gg. On or about January 27, 2005, BROWNE

deposited approximately $8,800 in cash into his account at a

Washington Mutual Bank branch in New York, New York.

15

hh. On or about January 31, 2005, BROWNE



ii. On or about February 7, 2005, BROWNE

deposited approximately $9,000 in cash into his account at


jj. On or about February 7, 2005, DRAKES

deposited approximately $8,740 into her account at JPMorgan

Chase.

kk. On or about February 9, 2005, BROWNE



ll. On or about February 11, 2005, BROWNE



mm. On or about February 14, 2005, BROWNE



nn. On or about February 15, 2005, BROWNE



oo. On or about February 18, 2005, BROWNE


Washington Mutual Bank branch in Kissimmee, Florida.

16

pp. On or about February 22, 2005, BROWNE



qq. On or about February 23, 2005, BROWNE



rr. On or about February 25, 2005, BROWNE



ss. On or about March 5, 2005, DRAKES wrote a

check to BROWNE from her JPMorgan Chase account for approximately

$8,500.

tt. On or about March 5, 2005, BROWNE deposited a

total of approximately $16,500 into his account at Washington

Mutual Bank.

uu. On or about March 14, 2005, BROWNE deposited

approximately $9,000 into his account at Washington Mutual Bank.

vv. On or about May 5, 2005, MUHAMMAD received a

transfer of approximately $8,500 into his account at New York

Community Bank from the account of Relative-1.

(Title 18, United States Code, Section 1956(h).)

17

COUNT THREE


17. In or about October 2004, BEVERLY MOZER-BROWNE,

PHILLIP A. BROWNE, and WENDY HARRISON, the defendants,

unlawfully, willfully and knowingly uttered, used, possessed,

obtained, accepted and received immigrant and nonimmigrant visas,

permits, alien registration receipt cards, and other documents

prescribed by statute and regulation as evidence of authorized

stay and employment in the United States, knowing them to have

been procured by means of false claims and statements, and to

have been otherwise procured by fraud and unlawfully obtained, to

wit, the defendants obtained a green card for WENDY HARRISON by

submitting a forged marriage certificate and fraudulent financial

documents.

(Title 18, United States Code, Sections 1546 and 2.)

COUNT FOUR


18. In or about November 2004, BEVERLY MOZER-BROWNE,

PHILLIP A. BROWNE, and TASLEEM KUDRATH, the defendants,






18



wit, the defendants obtained a green card for TASLEEM KUDRATH by

submitting a forged marriage certificate and fraudulent financial

documents.


COUNT FIVE


19. In or about September 2004, BEVERLY MOZER-BROWNE,

PHILLIP A. BROWNE, and TULSI RAMRUP, the defendants, unlawfully,

willfully and knowingly uttered, used, possessed, obtained,

accepted and received immigrant and nonimmigrant visas, permits,

alien registration receipt cards, and other documents prescribed

by statute and regulation as evidence of authorized stay and



been otherwise procured by fraud and unlawfully obtained, to wit,

the defendants obtained a green card for TULSI RAMRUP using a

forged marriage certificate and fraudulent financial documents.


COUNT SIX



PHILLIP A. BROWNE, and CHERYLENE RAMDASS, the defendants,

19








wit, the defendants obtained a green card for CHERYLENE RAMDASS

using a forged marriage certificate and fraudulent financial

documents.


COUNT SEVEN



PHILLIP A. BROWNE, and ADRIAN GOURSAHAB, the defendants,








wit, the defendants obtained a green card for ADRIAN GOURSAHAB

20


documents.


COUNT EIGHT


22. In or about October 2004, BEVERLY MOZER-BROWNE,

PHILLIP A. BROWNE, and NIGEL DEFOUR, the defendants, unlawfully,








the defendants obtained a green card for NIGEL DEFOUR using a



COUNT NINE



PHILLIP A. BROWNE, and KERRY RAMPERSAD, the defendants,




21





wit, the defendants obtained a green card for KERRY RAMPERSAD


documents.


COUNT TEN



PHILLIP A. BROWNE, and MERVIN TRANCOSO, the defendants,








wit, the defendants obtained a green card for MERVIN TRANCOSO


documents.


22

COUNT ELEVEN


25. In or about March 2005, BEVERLY MOZER-BROWNE,

PHILLIP A. BROWNE, and NARINE JAIRAM, the defendants, unlawfully,








the defendants obtained a green card for NARINE JAIRAM using a



COUNT TWELVE



PHILLIP A. BROWNE, and NATASHA HERCULES, the defendants,







23


wit, the defendants obtained a green card for NATASHA HERCULES


documents.


COUNT THIRTEEN



PHILLIP A. BROWNE, and ANNEKA RAMPERSAD, the defendants,








wit, the defendants obtained a green card for ANNEKA RAMPERSAD


documents.


FIRST FORFEITURE ALLEGATION

28. As the result of committing the visa fraud

conspiracy offense in violation of Title 18, United States Code,

Sections 371 and 1546, alleged in Count One of this Indictment,

24

BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, SANDFORD BROWNE, a/k/a

“Tyson,” GERRARDA BROWNE, a/k/a “Gerry,” WILLIANA BROWNE, JOHN

LOFTON, a/k/a “Big John,” PETER ABSOLAM, a/k/a “Lloyd,” KEITH

MAHASE, ABDUL HAKIM MUHAMMAD, TIFFANY WAYMAN, NARRISA JEREMIAH,

JAMSHEED JEREMIAH, a/k/a “Jason,” KHADIGA CLARKE, a/k/a “Kelly,”

LENNARD PRESCOD, a/k/a “Bob,” MAKEBA ISAROON, RHONDA EATON,

RODERICK CHASSEAU, CAMERON A. LLOYD, and KWASI DRAKES, the

defendants, shall forfeit to the United States pursuant to Title

18, United States Code, Section 982(a)(6)(A), all property, real

or personal, that constitutes, or is derived from or is traceable

to the proceeds obtained directly or indirectly from the

commission of the offense, and all property, real or personal,

that was used to facilitate, or was intended to be used to

facilitate, the commission of the offense, including but not

limited to the following:

a. A sum of money of at least $1 million in

United States currency, representing the amount of proceeds

obtained as a result of the conspiracy to commit visa fraud, for

which the defendants are jointly and severally liable.

b. All that lot or parcel of land, together with

its buildings, appurtenances, improvements, fixtures, attachments

and easements, located at 951 Nancy Court, Kissimmee, Florida.

c. All that lot or parcel of land, together with


25

and easements, located at 373 Aylesbury Court, Kissimmee,

Florida.

d. All that lot or parcel of land, together with


and easements, located at 4414 Canopy Court, Kissimmee, Florida.

e. All that lot or parcel of land, together with



f. All that lot or parcel of land, together with



g. All that lot or parcel of land, together with


and easements, located at 267 Magellan Drive, Kissimmee, Florida.

h. All that lot or parcel of land, together with


and easements, located at Lot E-5, Alpine Lake, Pocono Township,

Monroe County, Pennsylvania.

SECOND FORFEITURE ALLEGATION

29. As the result of committing the money laundering

conspiracy offense in violation of Title 18, United States Code,

Section 1956(h), alleged in Count Two of this Indictment, BEVERLY

MOZER-BROWNE, PHILLIP A. BROWNE, ABDUL HAKIM MUHAMMAD, and KWASI

DRAKES, the defendants, shall forfeit to the United States

26

pursuant to Title 18, United States Code, Section 982(a)(1), all

property, real and personal, involved in the money laundering

offense and all property traceable to such property, including

but not limited to the following:

a. A sum of money of at least $1 million in

United States currency, representing the amount of property

involved in the money laundering conspiracy, or traceable to such

property, for which the defendants are jointly and severally

liable.

b. All that lot or parcel of land, together with


and easements, located at 951 Nancy Court, Kissimmee, Florida.

c. All that lot or parcel of land, together with


and easements, located at 373 Aylesbury Court, Kissimmee,

Florida.

d. All that lot or parcel of land, together with



e. All that lot or parcel of land, together with



27

f. All that lot or parcel of land, together with



g. All that lot or parcel of land, together with


and easements, located at 267 Magellan Drive, Kissimmee, Florida.

h. All that lot or parcel of land, together with


and easements, located at Lot E-5, Alpine Lake, Pocono Township,

Monroe County, Pennsylvania.

THIRD FORFEITURE ALLEGATION

30. As the result of committing the visa fraud

offenses in violation of Title 18, United States Code, Sections

1546 and 2, alleged in Counts Three through Thirteen of this

Indictment, BEVERLY MOZER-BROWNE, PHILLIP A. BROWNE, WENDY

HARRISON, TASLEEM KUDRATH, TULSI RAMRUP, CHERLYENE RAMDASS,

ADRIAN GOURSAHAB, NIGEL DEFOUR, KERRY RAMPERSAD, MERVIN TRANCOSO,

NARINE JAIRAM, NATASHA HERCULES, and ANNEKA RAMPERSAD, the

defendants, shall forfeit to the United States pursuant to Title

18, United States Code, Section 982(a)(6)(A), all property, real

or personal, that constitutes, or is derived from or is traceable

to the proceeds obtained directly or indirectly from the

commission of the offense, and all property, real or personal,

28

that was used to facilitate, or was intended to be used to

facilitate, the commission of the offense.

Substitute Asset Provision

31. If any of the forfeitable property described in

the foregoing Forfeiture Allegations, as a result of any act or

omission of the defendants:

(1) cannot be located upon the exercise of due

diligence;

(2) has been transferred or sold to, or deposited

with, a third person;

(3) has been placed beyond the jurisdiction of the

Court;

(4) has been substantially diminished in value; or

(5) has been commingled with other property which

cannot be subdivided without difficulty;

it is the intent of the United States, pursuant to 18 U.S.C.

§ 982(b), to seek forfeiture of any other property of said

defendants up to the value of the above forfeitable property.

(Title 18, United States Code, Sections 371, 982, 1546 and 1956.)

FOREPERSON MICHAEL J. GARCIA

United States Attorney

Documents

UNITED STATES DISTRICT COURT SOUTHERN … ABDUL HAKIM MUHAMMAD, and KWASI DRAKES, the defendants, and others known and unknown, unlawfully, willfully and knowingly did combine, conspire,