United States District Court Western District of Kentucky at Louisville
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UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY AT LOUISVILLE UNITED STATES OF AMERICA INDICTMENT v. NO. _____________________ 18 U.S.C. § 2 JAMESY HAVENS 18 U.S.C. § 981(a)(1)(C) DAVID FARNSWORTH 18 U.S.C. § 982(a)(1) RONALD LOVELL 18 U.S.C. § 982(a)(2) JASEN COON 18 U.S.C. § 1028A(a)(1) DANNY COSLOW 18 U.S.C. § 1028A(c)(5) CHRISTOPHER PEPLINSKI 18 U.S.C. § 1341 18 U.S.C. § 1349 18 U.S.C. § 1956(a)(1)(B)(i) 18 U.S.C. § 1957 28 U.S.C. § 2461 The Grand Jury charges: COUNT 1 (Mail Fraud Conspiracy) 1. In or about and between May 2013, and August 2015, in the Western District of Kentucky, Jefferson County, Kentucky, and elsewhere, the defendants, JAMESY HAVENS, DAVID FARNSWORTH, RONALD LOVELL, JASEN COON, DANNY COSLOW, and CHRISTOPHER PEPLINSKI, and others, known and unknown to the Grand Jury, conspired, confederated and agreed with each other and with others to knowingly execute and attempt to execute a scheme and artifice to defraud, in violation of Title 18, United States Code, Section 1341. The goal of the conspiracy was to obtain money and property from car loan companies and banks by filing car loan applications and stealing the cars and loan proceeds, and subsequently claiming that they did not purchase the cars and apply for the loans, but rather falsely claiming that someone else had stolen their identities, filed the applications, and taken possession of the cars and loan proceeds, without their knowledge and approval. Manner and Means 2. It was part of the conspiracy that JAMESY HAVENS, DAVID FARNSWORTH, RONALD LOVELL, JASEN COON, DANNY COSLOW, and CHRISTOPHER PEPLINSKI, and others, known and unknown to the Grand Jury, opened bank accounts in Louisville, Kentucky, Michigan, and Florida, in the names of nominee companies, designed to appear as legitimate businesses and car dealerships, such as 24/7 Motors, FTD Motors, Auto Advantage Company, Gulf Coast Holdings, VMCD Corp., and VMD Direct Processing. 3. It was further part of the conspiracy that JAMESY HAVENS, RONALD LOVELL, and DANNY COSLOW, used the addresses of UPS Store post office boxes to give the appearance that the businesses, listed in paragraph 2, had actual physical addresses. 4. JAMESY HAVENS, DAVID FARNSWORTH, and others, known and unknown to the Grand Jury, applied for car loans, and initially purchased cars with no intent to repay the loans, kept or transferred the cars to others, and later reported that someone else had stolen their identities, filed the applications, and taken possession of the cars without their knowledge and approval. 5. JAMESY HAVENS, DAVID FARNSWORTH, JASEN COON, and CHRISTOPHER PEPLINSKI later applied for car loans and created and used fraudulent car purchase invoices from businesses listed in paragraph 2 to create the impression that the defendants and others were purchasing cars, when, in fact, no car was actually purchased. 6. JAMESY HAVENS, DAVID FARNSWORTH, RONALD LOVELL, JASEN COON, DANNY COSLOW, and CHRISTOPHER PEPLINSKI, submitted false invoices, and 2 fraudulently obtained car loans for these non-existent sales, and loan proceed checks were subsequently issued to the applicants and car dealerships. 7. JAMESY HAVENS, DAVID FARNSWORTH, RONALD LOVELL, DANNY COSLOW, JASEN COON, and CHRISTOPHER PEPLINSKI conducted financial transactions, by depositing car loan proceeds into the nominee bank accounts listed in paragraph 2, and kept the loan proceeds for their own personal use and the use of other defendants. 8. JAMESY HAVENS, DAVID FARNSWORTH, RONALD LOVELL, and DANNY COSLOW obtained multiple loans for the same car, creating the false impression to the lender that the car had been sold, when in fact the defendants still possessed the car. 9. JAMESY HAVENS, DAVID FARNSWORTH, RONALD LOVELL, and DANNY COSLOW created the false impression that there were no liens on cars, when, in fact, liens had not been released by previous lenders, allowing the defendants to sell the cars using a title that did not reflect any liens. 10. To interfere with and prevent collection efforts by lenders, JAMESY HAVENS, DAVID FARNSWORTH, RONALD LOVELL, JASEN COON, and CHRISTOPHER PEPLINSKI submitted credit disputes to credit reporting agencies, by facsimile and mail, in which they claimed that their identities had been stolen, and that the car loans had been obtained by some unknown third party, when, in fact, the defendants applied for the loans or caused others to apply for loans, and took possession of the cars or the loan proceeds. In violation of Title 18, United States Code, Section 1349. 3 The Grand Jury further charges: COUNT 2 (Aggravated Identity Theft) 11. The allegations contained in paragraphs 1 through 10 are incorporated by reference. 12. On or about December 30, 2014, in the Western District of Kentucky, Jefferson County, Kentucky, the defendant, JAMESY HAVENS, during and in relation to the offense of conspiracy to commit mail fraud, as charged in Count 1, in violation of Title 18, United States Code, Section 1349, knowingly transferred, possessed and used, without lawful authority, a means of identification of A.M., to wit: JAMESY HAVENS submitted a false credit dispute to Equifax Information Service, by United States mail, containing a police report with a fraudulent identity theft claim and A.M.’s name, social security number, and date of birth. In violation of Title 18, United States Code, Sections 1028A(a)(1) and (c)(5) The Grand Jury further charges: COUNTS 3-6 (Laundering of Monetary Instruments) 13. The allegations contained in paragraphs 1 through 12 are incorporated by reference. 14. On or about the dates set forth below, in the Western District of Kentucky, Jefferson County, Kentucky, and elsewhere, the defendants, JAMESY HAVENS, DAVID FARNSWORTH, RONALD LOVELL, JASEN COON, and DANNY COSLOW, and others, known and unknown to the Grand Jury, aiding and abetting each other and others, did knowingly engage and attempt to engage in the following monetary transactions, by through or to a financial institution, affecting interstate and foreign commerce, in criminally derived property of a value greater than $10,000, that is, the deposit, withdrawal, transfer, and exchange of U.S. Currency, 4 funds, and monetary instruments, such property having been derived from a specified unlawful activity, that is, proceeds of a conspiracy to commit mail fraud, as charged in Count 1: COUNT DEFENDANT DATE MONETARY TRANSACTION 3 HAVENS 6/19/2013 PNC Bank loan check to JAMESY HAVENS for $73,675 to purchase 2014 Jeep VIN ****6008 4 HAVENS 6/21/2013 Fifth Third Bank loan check to JAMESY HAVENS for $25,025.44 to purchase a 2011 Dodge Durango 5 HAVENS/FARNSWORTH 10/26/2013 Ford Motor Credit loan check to DAVID FARNSWORTH for $77,0091.71 to purchase a 2014 Ford F350 VIN ****1412 6 FARNSWORTH 10/24/2013 Chrysler Capital loan check to DAVID FARNSWORTH for $54,814.48 to purchase 2014 Jeep VIN ****6871S In violation of Title 18, United States Code, Sections 1957 and 2. The Grand Jury further charges: COUNTS 7-20 (Laundering of Monetary Instruments-Concealment) 15. The allegations contained in paragraphs 1 through 14 are incorporated by reference. 16. On or about the dates set forth below, in the Western District of Kentucky, Jefferson County, Kentucky, and elsewhere, the defendants, JAMESY HAVENS, DAVID FARNSWORTH, RONALD LOVELL, JASEN COON, DANNY COSLOW, and CHRISTOPHER PEPLINSKI, and others, known and unknown to the Grand Jury, aiding and 5 abetting each other and others, did knowingly conduct and attempt to conduct the following financial transactions, affecting interstate and foreign commerce, to wit, deposits of loan proceeds to bank accounts designed to appear as legitimate businesses and car dealerships, knowing that the transaction was designed, in whole and in part, to conceal and disguise the nature, location, source, ownership, and control of the proceeds of a specified unlawful activity, that is, conspiracy to commit mail fraud, as charged in Count 1, and while conducting and attempting to conduct such financial transactions, knew the property involved in each financial transaction represented the proceeds of some form of unlawful activity: COUNT DEFENDANT DATE MONETARY TRANSACTION 7 HAVENS/LOVELL 8/23/2013 Nationwide Bank loan check to R.S. and 24/7 Motors for $30,000 deposited to US Bank #14580929906 for purchase of Dodge Charger VIN # 2CDXCTXCH300472 8 HAVENS/LOVELL 8/28/2013 M&T Bank loan check to R.S. and 24/7 Motors for $30,000 deposited to US Bank #145809299061 for purchase of Dodge Charger VIN # 2CDXCTXCH300472 9 HAVENS/FARNSWORTH 10/21/2013 Digital Federal Credit Union loan to DAVID FARNSWORTH and FTD Motors for $35,250 deposited to Forcht Bank # 10150285 10 HAVENS/PEPLINSKI 11/18/2013 Sagelink Credit Union loan check to CHRISTOPHER PEPLINSKI and FTD Motors for $36,101 deposited to Republic Bank # 57603294 11 HAVENS/PEPLINSKI 12/05/2013 Pentagon Federal Credit Union loan to CHRISTOPHER PEPLINSKI and FTD Motors for $42,000 deposited to Forcht Bank # 10150285 6 12 HAVENS/LOVELL/ 11/22/2013 Tri-Point Credit Union loan PEPLINSKI check to CHRISTOPHER PEPLINSKI and FTD Motors Corp for $44,000 deposited to SYB&T #1798731 13 HAVENS/PEPLINSKI 12/9/2013 Community Financial Credit Union loan check to CHRISTOPHER PEPLINSKI and FTD Motors for $44,000 deposited to Republic Bank # 57603294 14 HAVENS/COON/LOVELL 4/22/2014 USAA loan check to JASEN COON for $49,945.81 deposited to FTD Motors at Forcht Bank #10150285 to purchase a 2014 Jeep VIN ****6008 15 HAVENS/COSLOW 11/10/2014 Alliant Credit Union loan check to J.W. and Auto Advantage Co. for $31,850 deposited to Fifth Third Bank #7973625853 16 HAVENS/COON 5/16/2014 USAA loan to JASEN COON and FTD Motors for $32,462 deposited to Forcht Bank # 10150285 17 HAVENS/COSLOW 7/02/2015 PNC Bank loan check to B.F.