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Manafort Ny Indictment
Manafort Ny Indictment
-against-
Defendant.
THE GRAND JURY OF THE COUNTY OF NEW YORK, by this indictment, accuses the
The defendant, in the County of New York and elsewhere, during the period from on or
about December 22, 2015 to on or about March 7, 2016, knowingly and with intent to defraud,
presented, caused to be presented, and prepared with knowledge and belief that it would be used in
applying for, underwriting and closing a residential mortgage loan, a written statement which
contained materially false information concerning a fact material thereto; and concealed, for the
purpose of misleading, information concerning a fact material thereto and thereby received
proceeds and any other funds in the aggregate in excess of one million dollars.
SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
about October 19, 2016 to on or about November 18, 2016, knowingly and with intent to defraud,
presented, caused to be presented, and prepared with knowledge and belief that it would be used in
applying for, underwriting and closing a residential mortgage loan, a written statement which
contained materially false information concerning a fact material thereto; and concealed, for the
purpose of misleading, information concerning a fact material thereto and thereby received
proceeds and any other funds in the aggregate in excess of one million dollars.
THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
The defendant, in the County of New York and elsewhere, during the period from on or
about November 1, 2016 to on or about January 17, 2017, knowingly and with intent to defraud,
presented, caused to be presented, and prepared with knowledge and belief that it would be used in
applying for, underwriting and closing a residential mortgage loan, a written statement which
contained materially false information concerning a fact material thereto; and concealed, for the
purpose of misleading, information concerning a fact material thereto and thereby received
proceeds and any other funds in the aggregate in excess of one million dollars.
FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
committed as follows:
The defendant, in the County of New York and elsewhere, during the period from on or
about December 22, 2015 to on or about August 18, 2016, knowingly and with intent to defraud,
presented, caused to be presented, and prepared with knowledge and belief that it would be used in
applying for, underwriting and closing a residential mortgage loan, a written statement which
contained materially false information concerning a fact material thereto; and concealed, for the
purpose of misleading, information concerning a fact material thereto and thereby attempted to
receive proceeds and any other funds in the aggregate in excess of one million dollars.
FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
The defendant, in the County of New York and elsewhere, during the period from on or
about December 22, 2015 to on or about August 18, 2016, with intent that conduct constituting a
class B felony, to wit, Residential Mortgage Fraud in the First Degree, be performed, agreed with
one and more persons to engage in and cause the performance of such conduct.
OVERT ACTS
In furtherance of said conspiracy, during the period from on or about December 22, 2015 to
on or about August 18, 2016, the following overt acts, among others, were committed by a
1) On or about January 26, 2016, the defendant stated by email to Individual #1, in part and in
substance, “The appraiser for Howard St is calling to make an appointment to view the
condo. Could you please call [Individual #2] to arrange a time for him to access the
apartment. Remember, he believes that you and [Individual #3] are living there.”
2) On or about February 2, 2016, the defendant sent a document, named “Use of Cash
3) On or about February 24, 2016, Individual #6 stated to Individual #5 in New York County,
in part and in substance, that defendant was no longer moving forward with a mortgage and
they would provide Individual #5 updated insurance binders confirming there were no
4) On or about February 24, 2016, the defendant stated by email to Individual #4 in New York
County, in part and in substance, “Both issues were resolved today. [Individual #6] has
informed [Individual #5] and will be forwarding her the appropriate documentation from the
5) On or about March 4, 2016, the defendant signed a document, entitled “Uniform Residential
Loan Application.”
6) On or about May 1, 2016, the defendant stated by email to Individual #6, in part and in
substance, “I need [Individual #7] to do the letter requested below in red. Can you draft it
SIXTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
The defendant, in the County of New York and elsewhere, during the period from in or
around July 2016 to on or about October 19, 2016, with intent that conduct constituting a class B
felony, to wit, Residential Mortgage Fraud in the First Degree, be performed, agreed with one and
OVERT ACTS
In furtherance of said conspiracy, during the period from in or around July 2016 to on or
about October 19, 2016, the following overt acts, among others, were committed by a coconspirator
1) On a date during the period from in or around July 2016 to on or about August 15, 2016,
defendant asked Individual #6 in New York County to sign a letter stating, in part and in
substance, “Thank you for allowing me to use the AMEX Business Plum card to purchase
2) On or about August 15, 2016, the defendant sent a document, named “Amex Plum Note
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
The defendant, in the County of New York and elsewhere, during the period from on or
about October 21, 2016 to on or about November 18, 2016, with intent that conduct constituting a
class B felony, to wit, Residential Mortgage Fraud in the First Degree, be performed, agreed with
one and more persons to engage in and cause the performance of such conduct.
OVERT ACTS
In furtherance of said conspiracy, during the period from on or about October 21, 2016 to on
or about November 18, 2016, the following overt acts, among others, were committed by a
1) On or about October 21, 2016, the defendant sent a document, named “DMP P&L 9-31-16
2) On or about October 28, 2016, the defendant electronically signed a document, entitled
EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
with intent to defraud, made and caused a false entry in the business records of an enterprise, to wit,
Lender #1, and defendant’s intent to defraud included an intent to commit another crime and to aid
NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
The defendant, in the County of New York and elsewhere, on or about March 4, 2016, with
intent to defraud, made and caused a false entry in the business records of an enterprise, to wit,
Lender #1, and defendant’s intent to defraud included an intent to commit another crime and to aid
TENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
The defendant, in the County of New York and elsewhere, on or about March 4, 2016, with
intent to defraud, made and caused a false entry in the business records of an enterprise, to wit,
Lender #1, and defendant’s intent to defraud included an intent to commit another crime and to aid
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
The defendant, in the County of New York and elsewhere, on a date during the period from
on or about March 11, 2016 to on or about May 2, 2016, with intent to defraud, made and caused a
false entry in the business records of an enterprise, to wit, Lender #1, and defendant’s intent to
defraud included an intent to commit another crime and to aid and conceal the commission thereof.
TWELFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
The defendant, in the County of New York and elsewhere, on or about October 6, 2016,
with intent to defraud, made and caused a false entry in the business records of an enterprise, to wit,
Lender #2, and defendant’s intent to defraud included an intent to commit another crime and to aid
THIRTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
with intent to defraud, made and caused a false entry in the business records of an enterprise, to wit,
Lender #2, and defendant’s intent to defraud included an intent to commit another crime and to aid
FOURTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
The defendant, in the County of New York and elsewhere, on or about November 11, 2016,
with intent to defraud, made and caused a false entry in the business records of an enterprise, to wit,
Lender #2, and defendant’s intent to defraud included an intent to commit another crime and to aid
FIFTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
The defendant, in the County of New York and elsewhere, on or about January 5, 2017, with
intent to defraud, made and caused a false entry in the business records of an enterprise, to wit,
Lender #2, and defendant’s intent to defraud included an intent to commit another crime and to aid
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
of the crime of SCHEME TO DEFRAUD IN THE FIRST DEGREE, in violation of Penal Law
The defendant, in the County of New York and elsewhere, during the period from on or
about December 22, 2015 to on or about January 17, 2017, engaged in a scheme constituting a
systematic ongoing course of conduct with intent to defraud more than one person and to obtain
property from more than one person by false and fraudulent pretenses, representations and
promises, and so obtained property with a value in excess of one thousand dollars from one and
No.
-against-
Defendant.
INDICTMENT
A True Bill
Peirce R. Moser
Sean C. Pippen
James H. Graham
Lisa M. White
Major Economic Crimes Bureau Foreman