RETURETA & WASSEM, P.L.L.C.

Sierralta & Asociados

Attorneys at Law Abogados

300 New Jersey Avenue, NW ~ Suite 900 Centro Comercial Bello Campo, Local 73 Nivel
Washington, D.C. 20001 Boulevard Caracas, 1063, Miranda - Venezuela
www.returetawassem.com 5805 Blue Lagoon Dr., Ste. 200
Miami, Florida 33126 - USA

February 24, 2022

The Honorable Merrick Garland,

Attorney General
U.S. Department of Justice
Washington, D.C. 20004
950 Pennsylvania Avenue, NW
Washington, D.C. 20530

Dear Attorney General Garland,

We refer the business entity “Intense Live” and its founding member, operating
officers, and agents to the United States Department of Justice for criminal
investigation and possible prosecution. This referral document and the supporting
exhibits included herein detail conduct on the part of Intense Live and the individuals
referenced that in our legal opinion may constitute a conspiracy to fraudulently
induce individuals to invest in a business entity that was nothing more than a
“pyramid scheme.” Our investigation has learned of numerous individuals in the
United States, Central America and South America that have been victimized by
Intense Live, who have suffered losses totaling into the millions of U.S. dollars. As a
result of our investigation, we respectfully submit this referral and supporting
documentation to the United States Department of Justice.

Background
Beginning in 2019, the law firms of Retureta & Wassem, PLLC of Washington,
D.C. (hereinafter “Retureta & Wassem”) and/or Sierralta & Asociados, based in the

Retureta & Wassem, P.L.L.C. Sierralta & Asociados

Washington, D.C. Venezuela
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Republic of Venezuela, were approached by numerous individuals from the United

States and several Central and South American countries (hereinafter
“Complainants”) who voiced complaints about a business entity known as “Intense
Live” (hereinafter “Intense Live”).
Each of the Complainants alleged Intense Live committed a fraud upon them.
Specifically, they alleged they were approached by individuals extolling the wealth
they would easily earn by investing in Intense Live and its business model. In
reliance upon those representations, the Complainants paid money to Intense Live
expecting the promised lucrative return on their investments. Unfortunately, the
Complainants suffered great monetary losses instead.
The victimized Complainants requested the assistance of Retureta & Wassem
and Sierralta & Asociados, which conducted an initial investigation of the facts and
Intense Live and concluded a valid factual basis existed for further investigation of
Intense Live, its business practices, its founder and its operating officer(s) for
violations of the laws of the United States.

Intense Live Business Model – Formation – Founder & Officers/Employees

Intense Live presented itself to each of the Complainants as a “ride-sharing”
business seeking investors to fund fleets of vehicles for use in the ride-sharing market
currently dominated by the commonly known ride-sharing platforms “Uber” and
“Lyft.” The concept appeared to be that investors would invest to build a fleet of
vehicles to be used for the benefit of those investors, who would have the profits
returned to them and be paid commissions to recruit other investors. Intense Live
employees and/or agents assured the Complainants they would receive a very
lucrative return with little investment and described a rolling influx of new investors.
The statements by Intense Live, its employees and/or agents plainly describe a classic
pyramid scheme on their face.
Intense Live registered as a limited liability company with the State of Florida
in October of 2019 as “Intense Live Company, L.L.C.” See Exhibit – Florida LLC

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Organizational Documents. According to its organizational documents, Intense Live

purportedly had a business address in Orlando, Florida and a registered agent in
Kissimmee, Florida. See Exhibit – Florida LLC Organizational Documents. Two
individuals were identified as its founding members:

1) Manuelito M. “Maxi” Santos Bispo

(listed as “AMBR;”1) and,
2) Julio Cesar J. Mota Lisboa
(listed as Manager and Registered Agent).

See Exhibit – Florida LLC Organizational Documents.

Intense Live filed annual reports, as required, with the State of Florida in 2020
and 2021. See Exhibits – 2020 Annual Report and 2021 Annual Report. According
to those Annual Reports, the two individuals listed above continued in their roles
with Intense Live in 2020 and 2021 and the individual described above remained as
Intense Live’s registered agent. Later in 2021, however, Intense Live filed an
Amended Annual Report wherein it changed its registered agent to “Larson
Accounting Group” in Orlando, Florida. See Exhibit – 2021 Amended Annual Report.
No other amendments were made to its previously filed 2021 report.
Two months following it filed its amended annual report in 2021, Intense Live
was unceremoniously dissolved. “Articles of Dissolution” filed with the State of
Florida in August of 2021, reflect Manuelito M. “Maxi” Santos Bispo was designated
as the “person appointed to wind up [Intense Live’s] activities and affairs.” See
Exhibit – 2021 Articles of Dissolution. Mr. Santos Bispo executed those Articles of
Dissolution, affirming that any false information provided therein would constitute a
third-degree felony pursuant to Florida Criminal Statute section 817.155. Exhibit –
2021 Articles of Dissolution.
In the Articles of Dissolution Mr. Santos Bispo represented to the State of

1 The State of Florida employs the term “AMBR” to refer to an owner of a limited liability
company and/or an individual authorized to act on its behalf.
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Florida that “[t]he business [Intense Live] is not operating.” Id. That statement was
patently false. According to numerous Complainants, at the same time Intense Live
was filing to dissolve its LLC in Florida, it was continuing to entice and defraud
individuals in the United States, as well as in Central and South America.
In addition to the individuals listed above (Messrs. Santos Bispo and Mota
Lisboa), our investigation has identified a third individual who the Complainants
describe as an employee, and possibly an officer, of Intense Live named Armin
Velázquez. Information provided by the Complainants during interviews indicates
that Mr. Velázquez acted as a publicist and salesperson for Intense Live.

Intense Live Scheme & Conspiracy

At the heart of the business practices driving Intense Live were
representations that new participants would recoup their original investments and
earn large profits by inducing two or more prospects to make the same investment as
they had made. Intense Live failed to tell prospective participants, however, that this
business model was mathematically impossible for everyone to profit as promised
because some participants would inevitably drop out and others would withdraw
their money after recouping their original investments. As with any pyramid scheme,
Intense Live used money collected from new investors to pay earlier investors.
Unfortunately, the Complainants who paid Intense Live were not, in fact, investors.
They were victims who fell prey to a veneer of legitimacy supported by glamorous
videos and flashy flyers, and were induced thereby to recruit further victims with the
hope of large profits arising from recruitment commissions.
It is the professional opinion of Retureta & Wassem and Sierralta &
Asociados, based upon numerous interviews with individuals complaining of fraud,
that Intense Live knowingly combined, conspired, and agreed to commit an offense
against the United States, namely, wire fraud, beginning sometime in 2019 and
continuing through 2021 in federal districts of the United States, as well as
internationally. Retureta & Wassem and Sierralta & Asociados are further of the

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opinion that the manner and scope of the Intense Live conspiracy constituted a crowd
funding pyramid scheme.
According to the Complainants, Intense Live used interstate and
international wire communications to repeatedly contact them with promises of easy
and lucrative returns. Yet, the Complainants have instead lost the money they
provided to Intense Live, which has not provided any explanation.

Potential Violations of U.S. Laws

It is the professional opinion of Retureta & Wassem and Sierralta & Asociados
that the actions of Intense Live constitute a conspiracy to commit wire fraud as set
forth in Title 18, Sections 1349 and 1343 of the U.S. Code. Based upon information
provided by the Complainants, Intense Live was a Florida business entity consisting
of two or more individuals who agreed and devised a scheme to intentionally defraud
and victimize the Complainants. As such, it was reasonably foreseeable interstate
wire communications would be used by Intense Live, its employees and/or agents to
facilitate that fraudulent scheme in the United States, as well as other countries.
Moreover, according to the Complainants, Intense Live utilized U.S. financial
institutions to facilitate its scheme. For example, Intense Live offered use of a
MasterCard credit card to its investors to for them to use to invest with Intense Live
and withdraw money from their investments. In addition, the Complainants report
that as investors they were to have access to vehicles that would be delivered to
numerous countries to work with an international trucking system, and that they
would be able to use those vehicles to generate income.
Based upon our investigation, it is the professional opinion of Retureta &
Wassem and Sierralta & Asociados that Intense Live, its employees, officers and/or
agents unlawfully enriched themselves by: 1) inducing investors to invest in Intense
Live through materially false and fraudulent pretenses, representations, promises,
and omissions; 2) generated revenue and earned money through commissions and
funds based on the volume of investors who invested in Intense Live; and, 3)

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concealed the nature of the conspiracy. Based upon the information provided, Intense
Live was nothing more than a fraud and its promises of lucrative earnings, use of
vehicles, prizes and travel as rewards for soliciting new investors were nothing more
than a glitzy pyramid scheme. The complaints presented to Retureta & Wassem and
Sierralta & Asociados support the conclusion that a criminal investigation is
warranted.

Remedies: Restitution/Forfeiture & Victim Notification

Retureta & Wassem and Sierralta & Asociados are prepared to provide the
U.S. Department of Justice with the names of thousands of victims seeking relief from
the fraud committed upon them by Intense Live. Its is the sincerest hope of the
Complainants that with the reach of the U.S. Department of Justice and the results
of any investigation that may follow, justice will be served and they may receive
restitution for their injuries. 18 U.S.C. § 3663A. In addition, it is the hope of the
Complainants that any penalties that may be held against Intense Live would forfeit
to the United States as property constituting, or derived from, proceeds obtained
directly or indirectly, as a result of any illegal conduct. See 18 U.S.C. § 982(a)(2)(A)
and 28 U.S.C. § 2461(c).
Furthermore, the Complainants hope and request pursuant to 18 U.S.C. §
3771(d)(2), that notification procedures be authorized and implemented to identify
the extraordinary number of victims that may have fallen prey to Intense Live and
its business practices.

Conclusion
Therefore, based upon the information presented herein, as well as the
supporting exhibits provided, Retureta & Wassem and Sierralta & Asociados
respectfully refer the business entity “Intense Live” and its founding member,
operating officers, employees, and agents to the United States Department of Justice
for criminal investigation of their business practices and complaints by U.S. citizens

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and individuals from Central and South America. We are prepared to provide further
documentation and victim information at your request. We look forward to hearing
from you and your representatives quickly.

Respectfully submitted,

RETURETA & WASSEM, PL.L.C.

By: Manuel J. Retureta, Esq.

SIERRALTA & ASOCIADOS,

By: Carlos J. Jimenez V.

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