1.media.graytvinc.com/documents/maize+fraud+complaint.pdf · at emprise bank, 10620 west 21st...

UNITED STATES OF AMERICA,

Plaintifi

Defendant No. I :

3103 North Den Hollow Court, Wichita, Kansas,with alI appurtenances, improvements,and attachments thereon;

))))))))))))))))))))))))))

IN THE LTNITED STATES DISTRICT COURTFOR THE DISTRICT OF KANSAS

Civil Case No.

Defendant No. 2:

Contents of Safe Deposit Box #XXX0259 locatedAt Emprise Bank, 10620 West 21st Street, Wichita,Kansas, Styled as Ramon Antonio Mosate and LoriBarvais in the approximate amount of $80,000.00U.S. Cunency;

Delendant No. 3:

Contents ofChecking Account #XXX1954 [ocatedAt Emprise Bank, 10620 West 2l st Street, Wichita,Kansas, styled as Ramon Antonio Mosate, in theAmount of $5,357.36 U.S. Currency.

Delendants.

COMPLAINT FOR FORFEITURE IN REM

Plaintiff, United States of America, by and through Barry R. Grissom, United States

Attomey for the District of Kansas, and Aaron L. Smith, Assistant United States Attorney, brings

this Complaint and alleges as follows in accordance with Supplemental Rule G(2) of the Federal

Rules of Civil Procedure:

NATURE OF THE ACTION

1. This is an in rem forfeiture action brought to forfeit and condemn to the United

States the above-captioned defendants.

1

FILED UNDER S[,AL

Case 6:14-cv-01393-JTM-KGG Document 1 Filed 11/21/14 of 22

JURISDICTION AND VENUE

2, Plaintiff brings this action in rem irt its own right to forfeit and condemn the

defendants pursuantto 18 U.S.C. $$ 981(aX1)(A) and (a)(l)(C), and 28 U.S.C. $ 2461. This

Court has inrem jwisdiction over this action under 28 U.S.C. $$ 1345and 1355.

3. Venue is proper in this district pursuant to 28 U.S.C. $$ 1355 and 1395, because

the acts or omissions giving rise to the forfeiture occurred in this district, andlor defendants are

located within this district.

THE DEFENDANTS IN REM

4. Defendant No. 1 is property located at 3103 North Den Hollow Courl, Sedgwick

County, Wichita, Kansas with all appurtenances, improvements, and attachments thereon, and is

more fully described as follows:

Lot 54, Block 4, Fox Ridge Addition, an Addition to Wichita, SedgwickCounty, Kansas

It has not been seized, and is located in the District of Kansas. The owners of record of

Defendant No. 1 are Ramon and Angie Mosate. It has not been seized.

5. Defendant No. 2 is the contents of Safe Deposit Box #XXXX0259 located at

Emprise Bank, 10620 West 21st Street, Wichita, Kansas 67205, styled as Ramon Antonio and

Lori Barvais in the amount of $80,000.00 United States Currency. Defendant No. 3 is the

contents of checking Account #XXXI954 located at Emprise Bank, 10620 West 21st Street,

Wichita, Kansas, styled as Ramon Antonio Mosate, in the amount of $5,357.36 U.S. Currency.

BASIS FOR FORFEITURE

6. Defendants are subject to forfeiture to the United States pursuant to l8 U.S.C. $$

981(a)(1)(A) and (C), and 28 U.S.C. $ 2461. The United States alleges that these defendants are


subject to forfeiture because they constitute or were derived from proceeds traceable to

violations of 18 U.S.C. $ 371, 18 U.S.C. $ 666, 18 U.S.C. $1343, 18 U.S.C S 1344, 18 U S'C' $

1346 and 1 8 U.S.C. $ 1349, and/or are property involved in money laundering transactions.

FACTS SUPPORTING FORF'EITURE

'7. The facts and circumstances supporting the forfeiture ofthe defendants are

contained in Exhibit A, which is attached hereto and incorporated by reference.

CLAIM FOR RELIEF

8. Plaintiffrepeats and realleges each and every allegation set forth in Paragraphs 1

through 7, above.

g. As a result ofthe foregoing, the defendants are liable to condemnation and to

forfeiture to the United States for its use, in accordance with 18 U.S.C' $$ 981(aX1XA) and (C)'

10. The United States does not request authority from the Court to seize the defendant

real property (Defendant No. 1) at this time. The United States will, as provided by 18 U.S.C. $

985(cX I ):

A. post notice ofthis action and a copy ofthe Complaint on the defendants;

B. serve notice ofthis action on the registered owners ofthe defendants, and any

other person or entity who may claim an interest in the defendants, along with a

copy of this Complaint, and

C. file a lis pendens in the appropriate county records setting out the defendant status

as defendant in this in rem aclion.

WHEREFORE, the plaintiff requests that notice of this action be given to all persons who

reasonably appear to be potential claimants of interests in the defendants; that all ofthe

defendants be forfeited and condemned to the united States of America; that the plaintiffbe

aJ


awarded its costs and disbursements in this action; and, for such other and further reliefas this

Court deems proper and just.

The United States hereby requests that trial ofthe above entitled matter be held in the

City of Wichita, Kansas.

Respectfully submitted,

BARRY R. GRISSOMUnited States Attomey

/s/ Aaron L. SmithAaron L. Snjth#20447Assistant United States Attomey1200 Epic Center, 301 N. MainWichita, Kansas 67202(316) 269-6481aaron.smith3 @usdoi.sov

4


DECLARATION

I, Thomas S. Ensz, am a Special Agent with the Federal Bureau of Investigation. I have

read the contents ofthe foregoing Complaint for Forfeiture, and the exhibit thereto, and the

statements contained therein are true to the best of my knowledge and belieL

I declare under penalty ofperjury that the foregoing is true and correct.rt14

Executed on this{l - day of November.2014.

Thomas S. EnszSpecial AgentFederal Bureau of Investigation

5

4=,4/4-


AFFIDAVIT IN SUPP ORT OF A COMP LAINT FOR FORFEITURE

I, Thomas S. Ensz, being duly swom, depose and state that I have been a Special Agent

of the Federal Bureau of Investigation for fifteen years. Since January of 2008, I have

been assigned to the Kansas City Division, Wichita Resident Agency. Prior to my

assignment in Wichita, I was assigned to the San Antonio Division, Laredo Resident

Agency, and the main field office of the Dallas Division. As a Special Agent, I have

participated in all ofthe normal methods of investigation, including, but not limited to:

the interviews ofwitnesses, the execution ofsearch warrants, and the review ofelectronicrecords. I have participated in numerous investigations concerning violation of Titles 18

and 21 ofthe United States Code throughout my career. I have experience workingfinancial fraud, embezzlement and other white-collar crimes. I am currency engaged inan investigation involving suspected violation of Theft or Bribery Conceming Programs

Receiving Federal Funds, Wire Fraud, Bank Fraud, Theft of Honest Services, and MoneyLaundering.

2. The statements contained in this affidavit are based, in part, on infbrmation provided byother law enforcement personnel and witnesses, information gained through my personal

investigation, and on my experience and training as a Special Agent. This affidavit does

not contain all the information regarding the investigation, but only provides sufficientinformation to support the government's request.

3. This affidavit is in supporl of a Complaint for Forl'eiture for the following property

a. $80,000 in United States Currency located during a search of safe deposit boxnumber 16000259, located within the Emprise Bank Branch at 10620 West 21't

Street, Wichita, Kansas;b. Olficiat Emprise Bank check, check number 5070835981, in the amount of

$5,357.36 seized from account number 9501954, styled in the name ofRamonAntonio Mosate (POD);

c. Real property located at 3103 North Den Hollow Court, Wichita, Kansas 67205-8748, and more particularly described as follows:Lot 54, Block 4, Fox fudge Addition, an Addition to Wichita, Sedgwick County,Kansas.

BACKGROUND

4. According to its website (yaury.usd266.aa!O, the Maize Unified School District 266(USD 266) encompasses approximately 42 square miles and includes ten schools locatedin Maize, Kansas, and in the northwest part of Wichita, Kansas. The USD 266Educational Support Center (ESC) is located at 905 West Academy Avenue, Maize,Kansas 67101. According to records found on the Kansas State Department olEducation(KSDE) website lw'lv.ksde.or , USD 266 had a total enrollment of 7 ,069 students forthe 2013-2014 school year. During the 2013-2014 school year, USD 266 received a totalof $70,639,178.00 in revenues, $1,164,007.00 from Federal sources. During the 2012-2013 school year (the most current summary ofexpenditures found on the KSDEwebsite), USD 266 made a total of $12,215,092.00 in expenditures.

Page I of 17


5. On April 28,2008, a preliminary floor plan for the construction of the ESC was presentedduring a special meeting of the USD 266 Board of Education (BOE). According to theplan, the ESC houses the Technology Services Department, including the office of itsdirector; as well as the Accounts Payable and Business Departments. The ESC alsohouses the computer servers for USD 266.

6. Ramon Mosate is the Director of the Technology Services Department for USD 266.According to the Technology Plan prepared by Ramon Mosate in June of2012, he is"responsible for establishing the future direction oftechnology usage for the USD 266organization." He is also "able to make final decisions about software and hardwarechoices and purchasing." The address listed on Ramon Mosate's current Kansas Driver'sLicense is 3103 North Den Hollow Court, Wichita, Kansas 67205. Vehicles registered toRamon Mosate have been observed in the parking lot ofthe ESC on several occasions,most recently on November 14,2014, and I believe that his office is located there.

7. Angie Mosate is the spouse of Ramon Mosate. She is empioyed as a CurriculumSecretary for USD 266 (according to a directory found on the USD 266 website). The

address listed on Angie Mosate's current Kansas Driver's License is 3103 North DenHollow Court, Wichita, Kansas 67205. Vehicles registered to Angie Mosate have been

observed in the parking lot of the ESC on several occasions, most recently on November5,2014, and I believe that she works there.

8. Based upon a review of the State Govemment Payroll Database found on theKansasOpenGov.org website (www.kansasopengov.org), I believe that Eric Bayena, also

known as Bayena Eric Yenika, was formerly employed by the Kansas Department ofLabor as a Technology Support Consultant III. This beliefis supported by the fact thatmy review ofbank records revealed that Eric Bayena received a bi-weekly direct depositfrom the State ofKansas from April 4,2008, to February 18, 201 l. Based upon a reviewof its publicly-available check registers, I believe that USD 266 paid Eric Bayena as a

vendor ol inlormation technology services from 2007 to 2012. The current whereabouts

of Eric Bayena are unknown.

9. Jared Kelley is a former employee of Vision Communications, Inc. and the current ownerof Vision Communications KS, Inc. He is also the former owner of K2 Resources, LLC.The address listed on his current Kansas Driver's License is 10406 Harvest Lane,Wichita, Kansas 67212.

10. I believe that Jason Kelley is the nephew ofJared Kelley. Based upon a review oltheSedgwick County Payroll Database found on the KansasOpenGov.org website(www.kansasopengov.ors), I believe that Jason Kelley is currently employed as a

Communications Cabling Specialist by Sedgwick County, Kansas. This belief issupported by the fact that my review ofbank records revealed that Jason Kelley continuesto receive a bi-weekly direct deposit from Sedgwick County as ofAugust 29, 2014. He isalso the owner of MLCM, LLC. The address listed on his current Kansas Driver'sLicense is 5710 North Saint Clair Street, Wichita, Kansas 67204.

Page 2 of 17


11. Bobbie Jo Dickson has managed and/or been employed by K2 Resources, LLC, VisionCommunications KS, Inc., and MLCM, LLC. On December 16,2011, Bobbie Jo Dicksonwas married and she subsequently changed her name to Bobbie Jo Hoehner. To remainconsistent, she is described as Bobbie Jo Dickson throughout this affrdavit. The addresslisted on her cunent Georgia Driver's License is 162 Sir Edward Teach Road, Midway,Georgia 3 1320.

12. Based upon a review olaccount opening documents obtained from Emprise Bank, Ibelieve that Christopher Concepcion is currently employed or was formerly employed byBlue Sky Satellite. The address listed on his current Kansas Driver's License is 520South Longbranch Drive, Maize, Kansas 67101. Based upon a review olthe publicly-available check registers ofUSD 266, I believe that USD 266 paid Concepcion as a

vendor of information technology services from 2008 to 201 1.

Eric Bavena and Ramon Mosate's Consniracv to Fraudulentlv Obtain the Funds of USD266

i3. According to publicly-available reports found on the USD 266 website, Eric Bayenareceived a total of$704,138.96 in vendor payments from USD 266 during the time periodofNovember 13,2007, to October 31,2012. Descriptions found in the reports indicatedthat the payments were made to Eric Bayena for technology-related services that heprovided to USD 266. From May 13, 2008, to October 3 1, 2012, $659,958.24 from thesepayments was deposited into Eric Bayena's personal checking account at Bank oftheWest and $17,300.00 was deposited into his personal checking account at Bank ofAmerica. From March 26,2009, to Octobdr 31, 2012, the vendor checks wdtten to EricBayena listed a mailing address of "PO Box 97, Maize, Kansas 67101." This is the same

mailing address listed on the account statements lor Ramon Mosate's Discover Card

credit card, dating back to November 18, 201 1.

14. From January 11,2008, to November 5, 2012, atotal of$304,546.08 in checks was

written from Eric Bayena's accounts to Ramon Mosate, Angie Mosate and one of theirchildren. Many ofthese checks were endorsed by Ramon Mosate and cashed at Bank ofthe West, while the others were deposited into five different bank accounts owned by the

Mosates. From July 14,2008, to January 3l ,2012, a total of $39,125.00 was transferreddirectly tiom Eric Bayena's account at Bank of America to Ramon Mosate and AngieMosate's joint checking account at Bank olAmerica. Additionally, from November 20,

2009, to May 8, 2010, checks in the total amount of $38,500.00 were written from EricBayena's accounts to persons or businesses involved in the construction of the residenceof Ramon and Angie Mosate, located at 3103 North Den Hollow Court, Wichita, Kansas67205.

15. As an example of this activity, a $123,927 .00 check was written to Eric Bayena fromUSD 266 on March 5, 2010. According to the publicly-available USD 266 check register

Page 3 of 17

PROBABLE CAUSE


for that month, the check was written to Eric Bayena for "MES IntemetworkingDevices." The USD 266 check was deposited into Eric Bayena's personal checkingaccount at Bank of the West that same day. From that account, the following checkstotaling $89,000.00 were thereafter written:

In addition to the aboveJisted checks, during the same time period, three checks totaling$25,000.00 were written from Eric Bayena's account to Christopher Concepcion. The

checks were written in the amounts of$9,975.00, $9,950.00, and $5,075.00. Two ofthechecks bore the notations of"Supply Tech" and "Outsourcing Tech." Angie Mosate also

wrote a check to Christopher Concepcion in the amount of $9,518.00 the day after the

third check from Eric Bayena was deposited into his account. Angie Mosate's check toChristopher Concepcion bore the notation of"Loan Payment." All ofthese checks weredeposited into Christopher Concepcion's personal checking account at Emprise Bank andhe thereafter used the money to help fund a $55,318.00 check he wrote to the UnitedStates Treasury. On the check to the United States Treasury, Christopher Concepcionnoted that the payment was for his "2009 form 1040." Aside from a $i00.00 cashwithdrawal, Christopher Concepcion used all of the money from the checks he receivedfrom Eric Bayena and Angie Mosate to fund his check to the United States Treasury. Ibelieve that Christopher Concepcion's use of the money in this manner makes it unlikelythat he was paid by Eric Bayena as a sub-contractor.

16. Based upon my knowledge, training, and experience in fraud and money launderinginvestigations, I believe that Eric Bayena could not have provided the above-describedproducts, "MES Internetworking Devices," to USD 266 lor 59,927.00 (the amountremaining after Eric Bayena's checks to the Mosates, the contractor involved in theconstruction oltheir residence. and Christopher Concepcion). Even if Eric Bayena could

I The name ofthe contractor has been redacted to protect his identity.

Page 4 of l7

Payee Amount Memo03109120t0 [Contractor on Behalf of the

Mosatesl]$3,000.00 "Home Improvement"

03/15t20t0 Ramon Mosate $7,000.00 "Loan Pavment"03/1st20t0 Angie Mosate $8,s00.00

Angie Mosate $9,600.00 "2"0 Pa)rynent on NiceHouse"

03il6t2010 [Contractor on Behalf of theMosates]

$4.000.00 "Acid Concrcte Down"

03fi6t2010 Ramon Mosate $9,700.00 IBlankl03n7t2010 Angie Mosate $8,900.00 "3'd Pa)T nent on Nice

House"0311712010 Angie Mosate $8.000.00 "Final Payment"031t712010 Ramon Mosate $9.300.00 lBlankl03124t2010 Ramon Mosate $8,s00.00 lBlankl03/2412010 Ramon Mosate $4,500.00 IBlankl03/2412010 Ramon Mosate $8,000.00 lBlankl

Date

"Down on Nice House"0311612010


have provided the products for that amount, his invoice to USD 266 would have

represented a mark-up in price ofover 800 percent, which I believe to be well outside ofthe norm for a legitimate small business. Further, approximately 54 percent ofall ofthemoney that Eric Bayena received from USD 266 from November 13,2007, to October31,2012, was paid to the Mosates, their family members, or other persons on theirbehalves. Given this fact, I believe that Eric Bayena and Ramon Mosate had an

agreement by which they woutd split evenly the money Eric Bayena fraudulentlyreceived from USD 266. Accordingly, I believe that most or all of Eric Bayena's invoices

to USD 266 were fraudulent.

Susnected Cash P ments From Christonher Concencion To Ramon Mosate

17. According to publicly-available reports found on the USD 266 website, ChristopherConcepcion received a total of $ $698,626.58 in vendor payments from USD 266 duringthe time period of October 13, 2008, to November 30, 201 1. Descriptions lbund in the

reporls indicated that the payments were made to Christopher Concepcion fortechnology-related services he provided to USD 266.

18. Checks totaling $685,942.58 from these payments were cashed by ChristopherConcepcion at Emprise Bank and $532,135.58 from the checks was deposited into hispersonal checking account. Based upon my review of the deposit and withdrawal recordsofChristopher Concepcion's personal checking account and the various bank accounts ofRamon and Angie Mosate, I have probable cause to believe and do believe thatChristopher Concepcion gave Ramon Mosate at least in $204,402.00 in cash paymentsfrom December 15, 2008, to November 16,2011. As an example of this activity, a$58,400.00 check was written to Christopher Concepcion from USD 266 on August 16,

201 1 . According to the publicly-available USD 266 check register for that month, the

check was wfitten to Christopher Concepcion for "MSMS Wireless Expansion-Mosate."The check was deposited into the personal checking account of him and his spouse at

Emprise Bank the following day. The table below provides a comparison between the

timing of some of the cash withdrawals made from the account and the subsequent cash

deposits made into three of Ramon Mosate's accounts.

Date Time Amount Description Account08/18/201 i 1:56

P,M,$9,000.00 Withdrawal Concepcion Checking

0811912011 4:43P.M.

$9,000.00 Deposit Mosate's Emprise Bank

08il9/201t 2:39P,M

$9,000.00 Withdrawal Concepcion Checking

08122/2011 5:06P.M.

$9.000.00 Deposit Mosate's Bank of America Checking

08t201201]1 l1:59A.M.

$6,000.00 Withdrawal Concepcion Checking

0812112011 ViaATM

$6.000.00 Deposit Mosate's Bank of America Savings

Page 5 of 17


Pavme nts From K2 Resources . LLC. and MLCM. LLC. To Ramon Mosate to Benefit

19. According to the records ofthe Kansas Secretary of State, Vision Communications, Inc.

was incorporated in Kansas on January 4, 1999. Jared Kelley was not listed on the

Articles of Incorporation for Vision Communications, Inc., nor was he listed as an owneron any of its annual reports. However, Jared Kelley was listed as the "Director of IT" ona signature card for a business checking account at Bank of America under the name ofVision Communications, Inc. Jared Kelley had signature authority for the account, alongwith one of the owners of Vision Communications, Inc.

20. On December 10,2009, Bank of America notified one ofthe owners of VisionCommunications, Inc. of its intention not to renew a $250,000.00 line ofcredit. VisionCommunications, Inc. was also notified that it needed to repay all debt associated withthe line of credit by February 21,2010. Documents obtained from Bank of Americarevealed that the bank did not renew the line ofcredit because Vision Communications,Inc. posted a loss in fiscal years 2007 and 2008. Vision Communications, Inc. filed for a

Chapter 7 banlruptcy on May I l, 201 1.

21. According to the records of the Kansas Secretary of State, Vision Communications KS,Inc. was incorporated by Jared Kelley in Kansas on March 10,2010. In each of the

subsequent Annual Reports filed on its behalf, Jared Kelley is listed as the sole officer ofVision Communications KS, Inc. At various times, both Jared Kelley and Bobbie Jo

Dickson have had signature authority lbr the Vision Communications KS, Inc. business

checking account at Emprise Bank.

22. The most recent Annual Report filed with the Kansas Secretary of State listed thebusiness address of Vision Communications KS, Inc., as 1237 South Mead Street,

Wichita, Kansas 67211 (the first Annual Report listed the address olVisionCommunications KS, Inc. as 1525 South Washington Street, Wichita, Kansas 6721 1). OnMay 13, 2014, a sign was observed on the door ol i237 South Mead Street, Wichita,Kansas 67211, indicating that the business had relocated to 1235 South Mead Street.However, materials commonly used in the cabling business, such as large wooden spools,have been periodically observed in the open garage spaces ofboth 1235 and 1237 South

Mead Street. Further, no other business has been observed operating in the office space

with the address of 1237 South Mead Street. Finally, according to a Property RecordCard located on the website of the Sedgwick County Appraiser's Office(www.sedgwickcounty.org/appraiser), both 1235 and 123 7 South Mead Street are

appraised as one property, owned by Hopper Development. Accordingly, it is believedthat the current address of Vision Communications KS, Inc. is 1235 South Mead Street,Wichita, Kansas 6721 1. However, it is also believed that Vision Communications KS,Inc. utilizes the entire building for its operation, including the space with the address of1237 South Mead Street, Wichita, Kansas 6721 1 .

Page 6 of 17

Vision Communications, Inc. and Vision Communications KS, Inc.


23. Based upon a review ofthe publicly-available check registers ofUSD 266, I believe that

USD 266 has paid both Vision Communications, lnc. and Vision Communications KS,

Inc. as vendors of information technology services from 2009 to 2014. VisionCommunications, Inc. received payments from USD 266 from January 12,2009, toDecember 15, 2011. I also believe that USD 266 began paying Vision Communications

KS, Inc. as a vendor of information technology services in 2012 and continues to do so

today.

24. According to the records ofthe Kansas Secretary of State, K2 Resources, LLC, was

organized in Kansas on June 11, 2007. Jared Kelley was the sole owner ofK2 Resources,

LLC, according to the 2007 Annual Report filed on its behalf. At various times, Jared

Kelley, Bobbie Jo Dickson, and another employee ofK2 Resources, LLC, all had

signature authority for the K2 Resources, LLC, business checking account at EmpriseBank. This account was closed on September 21, 2012. At the time the account was

closed, the mailing address for K2 Resources, LLC, was 1237 South Mead Street,

Wichita, Kansas 67211. Based upon a review ofthe publicly-available check registers ofUSD 266, I believe that USD 266 paid K2 Resources, LLC, as a vendor of informationtechnology services from 2007 to 2010.

25. According to the records ofthe Kansas Secretary of State, Upgrade I.T.S., LLC, was

organized in Kansas on February 17,2009. Matthew Joumey was listed as the registeredagent on the Articles of Organization for Upgrade I.T.S., LLC. Additionally, MatthewJoumey and his wife were listed as the owners of Upgrade I.T.S., LLC, on each of theAnnual Reports tlled on its behall.

26. According to the records of the Kansas Secretary of State, MLCM, LLC, was organizedin Kansas on August 23, 2011. In the only Annual Report filed on its behalf, Jason Kelleyis listed as the sole owner of MLCM, LLC. Jason Kelley and Bobbie Jo Dickson bothhave signature authority for the MLCM, LLC, business checking accounts at EmpriseBank and Meritrust Credit Union. The Reinstatement of Limited Liability Company lormfiled on behallolMLCM, LLC, on September 27,2013,listed the address of itsregistered of'fice as 5710 North Saint Clair Street, Wichita, Kansas 67204. Based upon areview ofthe publicly-available check registers ofUSD 266, I betieve that USD 266

began paying MLCM, LLC, as a vendor of infbrmation technology services in 2011 andcontinues to do so today.

28. From April 11, 2008, to September 18, 2009, checks in the total amount of$171,395.00were written to Ramon Mosate f'rom the K2 Resources, LLC, business checking account

Pagc 7 of 17

27. According to publicly-available reports lbund on the USD 266 website, K2 Resources,LLC, received a total of$757,734.19 in vendor payments from USD 266 during the timeperiod ofNovember 28,2007, to September 30, 2010. Descriptions found in the reportsindicated that the payments were made to K2 Resources, LLC, for technology-relatedservices that it provided to USD 266. With the exception of the lirst payment, the timeframe of which is not covered in the records I have reviewed, all ofthese payments weredeposited into the business checking account ofK2 Resources, LLC, at Emprise Bank.


at Emprise Bank. These checks were all signed by Jared Kelley, Bobbie Jo Dickson, or an

employee who worked at K2 Resources, LLC. As an example of this activity, a

$68,235.00 check from USD 266 was deposited into K2 Resources, LLC, checking

account on June 30,2008. According to the publicly-available USD 266 check register

for that month, the check was wdtten to K2 Resources, LLC, for "MHS Cisco Switch

Upgrades." On July 3,2008, an employee ofK2 Resources, LLC, wrote a check to

Ramon Mosate in the amount of $60,235.00. Further, K2 Resources, LLC, received

$96,583.50 in checks from USD 266 during the time period of April, 2008, to November,

2008. During that same time period, K2 Resources, LLC, wrote checks to Ramon Mosate

which totaled 86,535.00.

29. In addition to the checks written to Ramon Mosate from the K2 Resources, LLC,business checking account, the business checking account ofUpgrade I.T.S., LLC, was

used as a conduit by K2 Resources, LLC, to make additional payments to Ramon Mosate.

On March 16,2009, a $63,400.00 check from USD 266 was deposited into the business

checking account ofK2 Resources, LLC. According publicly-available reports found onthe USD 266 website, the check was written to K2 Resources, LLC, for "DistrictLAN/WAN Networking" and "District Technology Routers" (the check was written as

payment for two invoices). One week later, a $44,405.00 check was written from the K2Resources, LLC, business checking account to Upgrade LT.S., LLC. The check was

signed by Jared Kelley, endorsed by Matthew Joumey, and deposited it into the business

checking account ofUpgrade I.T.S., LLC, at Equity Bank. From that account, thelollowing checks totaling $44,405.00 were thereafter written from the Upgrade I.T.S.,LLC, account to Ramon Mosate:

Date Payee Amount Memo03130/2009 Ramon Mosate $9,800.00 [BIank]04104t2009 Ramon Mosatc $9,s00.00 fBlankl04109/2009 Ramon Mosate $8,380.00 lBlankl04il6t2009 Ramon Mosate $7,125.00 IBIank I

04127 t2009 Ramon Mosate $9,600.00 IBlankl

30. Based upon my review olthe deposit and withdrawal records of the K2 Resources, LLC,checking account and the various bank accounts of Ramon and Angie Mosate, I haveprobable cause to believe and do believe that K2 Resources, LLC, also gave RamonMosate at least in $155,740.00 in cash payments from April, 2009, to October, 2010. Asan example of this activity, a$109,922.50 check from USD 266 was deposited into thebusiness checking account ofK2 Resources, LLC, on April 9,2009. According to thepublicly-available USD 266 check register for that month, the check was written to K2Resources, LLC, for "MHS LAN/WAN Equipment." From April 9,2009, to June 10,

2009, Bobbie Jo Dickson made a total ol$101,800.00 in structured cash withdrawalsfrom the account. Six of the withdrawals were made in amounts between $9,000.00 and

$9,900.00 and the remaining withdrawals were made in amounts that exceeded

$4,500.00. From April 17,2009, to June 15, 2009, atotal of$64,290.00 in unexplainedcash was deposited into the bank accounts of the Mosates.

Page 8 of 17


31. According to publicly-available reports found on the USD 266 website, VisionCommunications, Inc. received a totat of $932,302.00 in payments from USD 266

February, 2009, to February, 2010, under purchase order number 00069725. Descriptions

found in the reports indicated that Vision Communications, Inc. received these payments

for "MSES/MSMS LAN/WAN Cabling." Based upon the timing of the payments fromK2 Resources, LLC, to Ramon Mosate, I have probable cause to believe and do believe

that Jared Kelley caused K2 Resources, LLC, to give payments to Ramon Mosate inorder to ensure that Vision Communications, Inc was approved to provide cabling

services under the afbrementioned purchase order number to USD 266.

32. This beliefis further supported by the fact that one of the checks written from K2Resources, LLC, to Ramon Mosate was funded by a check from Vision Communications,

Inc. On0111212009, USD 266 issued an $11,096.00 check to Vision Communications,

Inc. According to publicly-available reports found on the USD 266 website, the check

was written to Vision Communications, Inc. for "lnstall[ing] Cables PWS to CHSM" and

I believe that it was the first payment made to Vision Communications, Inc. by USD 266.

On 0111512009, Jared Ketley signed a $4,200.00 check from Vision Communications,

Inc. to K2 Resources, LLC. Jared Kelley endorsed this check and deposited it into the

checking account olK2 Resources, LLC, on 0112812009. On that same day, Jared Kelleywrote a $3,165.00 check lrom the K2 Resources, LLC, checking account to Ramon

Mosate. Based upon the timing ofthese deposits and checks, I have probable cause tobelieve and do believe that the $3,165.00 paid to Ramon Mosate was a "kickback" fromthe $11,096.00 check that Vision Communications, Inc. received from USD 266.

33. The last check received by K2 Resources, LLC, from USD 266 was deposited into the K2Resources, LLC, checking account on October 1, 2010. The check was issued in the

amount of$23,560.00. According to publicly-available reports found on the USD 266

website, the check was written to K2 Resources, LLC, for "PWS Relocate Projector" and

"ESC Infrastructure-Barvais." From October 2, 2010, to October 12,2010, Bobbie Jo

Dickson made a total of $ 17,600.00 in structured cash withdrawals from the account. The

withdrawals were made in the amounts of $9,000.00, $7,000.00, and $1,600.00. From

October 4, 2010, to October 13,2010, a total of$16,450.00 in unexplained cash was

deposited into the bank accounts ofthe Mosates.

34. On October 13,2010; October 27,2010; and December 16,2010; USD 266 issued

checks related to the installation of surveillance equipment to Vision Communications,

Inc. which totaled $ 106,781.18. According to publicly-available reports found on the

USD 266 website, these were the first checks issued by USD 266 to VisionCommunications, Inc. since the checks issued under purchase order number 00069725.Based upon the timing of the cash payments from K2 Resources, LLC, to Ramon Mosate,

I have probable cause to believe and do believe that Jared Kelley caused K2 Resources,

LLC, to give cash payments to Ramon Mosate in order to ensure that VisionCommunications, Inc. was approved to install a large amount of surveillance equipmentfor USD 266.

Page 9 ol 17


35. On August 24,2011, Bobbie Jo Dickson and Jason Kelley opened a business checkingaccount at Emprise Bank for MLCM, LLC. On 1010412011, a $32,225.22 check lromUSD 266 to Vision Communications, Inc. was deposited into the checking account ofVision Communications KS, Inc. According to publicly-available reports found on the

USD 266 website, the check was written to Vision Communications, Inc. for "MSMSEthemet Module," "ESC Security Camera Install," and "VES Tech Cable Installation."That same day, a$26,595.67 check was written from the Vision Communications KS,Inc. checking account and deposited into the checking account fbr MLCM, LLC. Thiswas the first deposit into the account since the opening deposit on August 24, 2011.

36. From October 4, 2011, to October 13,2011, Bobbie Jo Dickson made a total of$26,500.00 in structured withdrawals from the MLCM, LLC, account. The withdrawalswere made in the amounts of$9,000.00, $9,000.00, $6,000.00, and $2,500.00. From

October 7,2011,to October 13,2011, a total of$22,000.00 in unexplained cash was

deposited into the bank accounts ofthe Mosates.

37. On November 30, 2011, a $19,000.00 check from USD 266 to MLCM, LLC, was

deposited into the checking account of MLCM, LLC. According to publicly-availablereports found on the USD 266 website, the check was written to MLCM, LLC, for "MMSRework Network Closets." On November 30,2011, and December 1, 2001, Bobbie Jo

Dickson made two withdrawals from the account which totaled $13,000.00. On

November 30,2011, and December 5,201l, two deposits ofunexplained cash were made

into the joint checking account ofRamon and Angie Mosate which totaled $11,600.00.

38. From December 9, 201 1, to February 29,2012, USD 266 issued checks totaling

$368,319.75 to Vision Communications KS, Inc. and MLCM, LLC, for services related

to cabling and the installation of surveillance cameras. Based upon the above, I have

probable cause to believe and do believe that MLCM, LLC, was used by VisionCommunications KS, Inc. to give payments to Ramon Mosate in a manner similar to that

for which K2 Resources, LLC, was used. I also believe that the payments given to Ramon

Mosate from MLCM, LLC, benefitted both Vision Communications KS, Inc. and

MLCM, LLC.

39. According to publicly-available reports found on the USD 266 website, MLCM, LLC,has received a total of $1,045,782.35 in vendor payments from USD 266 during the timeperiod ofNovember 30, 2011, to August 26,2014. Descriptions found in the reports

indicated that the payments were made to MLCM, LLC, for technology-related services itprovided to USD 266. A review of the records for the two checking accounts of MLCM,LLC (an additional account was opened by MLCM, LLC, at Meritrust Credit Union),revealed that official checks totaling $ I 13,851 .00 were purchased from the accounts and

made payable to Ramon Mosate, Angie Mosate, or one of their family members. The

review also revealed that $52,600.00 was transferred directly from the MLCM, LLC,business checking account at Emprise Bank to Ramon Mosate's personal checking

account at Emprise Bank from April 26, 2013,to September 4, 2014.

Page 10 ol17


40. Additionally, based upon my review olthe deposit and withdrawal records oftheMLCM, LLC, business checking accounts and the various bank accounts ofRamon andAngie Mosate, I have probable cause to believe and do believe that $208,850.00withdrawn in cash from the MLCM, LLC, business checking accounts from December27,2011, to April 18, 2014, was given to Ramon Mosate.

41. In total, the afbrementioned companies that are all owned, controlled, or utilized by JaredKelley have received a total of $3,489,867.94 in payments f-rom USD 266 fromNovember 28, 2007,1o August 26, 2014. During that same time fiame, these entities havegiven Ramon Mosate, Angie Mosate, and one of their l'amily members multiple paymentsin the form ofchecks, business checks, direct transfers between accounts, and officialchecks.

42. According to records obtained from Emprise Bank, Ramon Mosate formerly leased a safedeposit box, Box Number 219, al the Emprise Bank branch in Maize, Kansas. RamonMosate leased the box with another employee ofthe USD 266 Technology ServicesDepartment, from April 16,2013, to February 19,2014. During the time in which theyleased the box, only Ramon Mosate accessed it (according to logs maintained by EmpriseBank). Prior to closing the lease on the aforementioned box, Ramon Mosate leased

another safe deposit box, Box Number 259, at the Emprise Bank New Market Square

branch, located at 10620 West 21't Street North, Wichita, Kansas 67205. Based upon areview of the records for the bank accounts of the Mosates and the bank accounts ofMLCM, LLC, I have probable cause to believe and do believe that Ramon Mosate was

using the safe deposit boxes he leased to store some of the cash he received from MLCM,LLC. The table below provides a summary of Ramon Mosate's visits to his safe depositboxes in comparison with withdrawals made from the bank accounts of MLCM, LLC. Itshould be noted that I observed no similar cash deposits in the records ofthe Mosates'bank accounts that corresponded with the cash withdrawals from the MLCM, LLC,accounts described below.

Date Time Activity04nst20t3 Unknown S8,000.00 Withdrawal from MLCM, LLC's Account at

Meritrust01n6t20t3 10:49

A.M.Ramon Mosate visited his safe deposit box at Emprise

06/10/2013 Unknown $6,000.00 Withdrawal from MLCM, LLC's Account atEmprise

06111/2013 Unknown $1,500.00 Withdrawal from MLCM, LLC's Account atMeritrust

06t13t2013 4:51 P.M. Ramon Mosate visited his sale deposit box at Emprise

0910312013 Unknown $6,000.00 Withdrawal from MLCM, LLC's Account atEmprise

0910312013 2:00 P.M. Ramon Mosate visited his sale deposit box at Emprise.

9:47 A.M. $3,000.00 Withdrawal from MLCM, LLC's Account at

Page 1l of 17

Ramon Mosate's Use of Safe Derrosit Boxes to Store Cash

03/0412014


Emprise03106t2014 l0:32

A.M.$7,000.00 Withdrawal f'rom MLCM, LLC's Account atEmprise

03t06/2014 5:56 P.M. Ramon Mosate visited his safe deposit box at Emprise

Date Time Activity4:36P.M

Ramon Mosate visited his safe deposit box at Emprise

01t03t20t4 5:07P.M

$10,000.00 Deposit into Ramon Mosate's Account at Emprise

01 /03/2014 Unknown $5,700.00 Deposit into Ramon Mosate's Savings Account, viaATM

0110312014 Unknown $4,000.00 Deposit into Ramon Mosate's Savings Account, viaATM

Ramon Mosate's Use of Fun ds to Purchase Assets and Fund Travel

43. Based upon my review ofthe records for the bank accounts of the persons and companiespreviously referenced in this affidavit, I have probable cause to believe that RamonMosate and Angie Mosate have used the proceeds of the criminal activity previouslydescribed in this affidavit to fund the construction ofthe residence located at 3103 NorthDen Hollow Court, Wichita, Kansas 67205. The table below provides a summary of the

funding ofthe Mosates' purchase of the lot on which the residence is located. The lot was

purchased for $28,770.27 at a closing on April 28, 2009.

Date Range Activity04/09t2009 5109p22.50 USD 266 Check Deposited into K2 Resources, LLC,

Account04t14t2009

0412812009 $28.800.00 in Structured Withdrawals from K2 Resources LLC. Account

04t1712009 -

04t28t2009 $28,500.00 in Structured Deposits into Angie Mosate's Account at

F'ideli Bank

04128t2009 $28,770.27 Withdrawal fiom A ie Mosate's Account at Fideli Bank

The tabte below provides a summary of the funding of the Mosates' payment of eamest

money and their first payment to the construction company that built the Mosates'

The table below provides a summary of one of Ramon Mosate's visits to his safe depositboxes in comparison with deposits made into his checking account at Emprise Bank andthe Mosates' savings account at Bant of America. It should be noted that I observed nocash withdrawals in the records ofthe bank accounts ofany ofthe vendors identified inthis affidavit that corresponded with the cash deposits described below.

01/0312014

Page 12 of 17


residence2 for the construction of the residence f'rom their checking account at Bank olAmerica.

44. The following are further examples of transactions by the Mosates' of improvementsmade to their residence located at 3 103 North Den Hollow Court, Wichita, Kansas:

2 The name ofthe company has been redacted to protect its identity3 The name ofthe company has been redacted to protect its identitya The name ofthe company has been redacted to protect its identity

Page 13 of 17

Date Range Activity03/16t2009 $63,400.00 USD 266 Check Deposited into K2 Resources, LLC, Account03t31t2009 $44,405.00 K2 Resources, LLC, Check Deposited into Upgrade ITS

Account04t03t2009

0412812009

$44,405.00 in Checks from Upgrade ITS Deposited or Cashed and

Depositedinto the Mosates' Accounts at Bank of America

04,L5t2009

06/rv2009

$44,405.00 Deposited into the Mosates' Accounts at Bank of America is

Transferred Between Accounts and Ultimately into the Checking Account

0411412009 $2,000.00 Eamest Money Check Written by the Mosates to thethat built the Mosates' residenceconstruction company

$39,754.56 Check Written by the Mosates to the construction companythat built the Mosates' residence

Date Range Activity09t18t2009 $58,1 18.00 USD 266 check deposited into K2 Resources LLC Emprise

Bank account number XXXX47 42

09t28t2009 $17,727 .60 check from K2 Resources, LLC, to an electronics companwhich paid for electronic equipment located inside the Mosates'residence

tUt2t2009 $47,070.00 USD 266 check deposited into Bayena Yenika's Bank oftheWest account number XXXXX9897

1v2012009 $ 10,000.00 check from Bayena Yenika to a swimming pool company

which is believed to have partially paid for the swimming pool at the

Mosates' residence.

12/1812009 $20,360.00 USD 266 check deposited into Bayena Yenika's Bank oftheWest account number XXXXX9897

12t21-23t2009

$10,000.00 in cash was deposited into Bayena Yenika's Bank olAmericaaccount number XXXXXXXX2981

$10,000.00 check written tiom Bayena Yenika's Bank of Americaaccount number XXXXXXXX2981 and deposited into Ramon and Angie

06t1U2009

$11,000.00 check for cash was written from Bayena Yenika's Bank ofthe West account number XXXXX9897 and cashed


Mosate's Bank of America account number XXXXXXXX2332

$11,547.00 check written from Ramon and Angie Mosate's Bank ofAmerica account number XXXXXXXX2332 to the constructioncompany that built the Mosates' residence

45. The fotlowing are examples of mortgage transactions by the Mosates' for their residence

located at 3103 North Den Hollow Court, Wichita, Kansas:

Date Range Activity12/17-2012010 1211712010 - $14,317.14 USD 266 check deposited into Christopher

Concepcion Emprise Bank account number XXXX9652

12120/2010 - $4,000.00 cash withdrawal from Christopher ConcepcionEmprise Bank account number XXXX9652

12120/2010 - $3,000.00 cash deposit to Ramon Mosate Emprise Bankaccount number XXXI954

1212012010 - $3,232.15 withdrawal made fbr thc mortgage paymentfor 3 103 North Den Hollow Court, Wichita, Kansas

03116-3012011 0311612011 -539,728.67 USD 266 check deposited into VisionCommunications KS, Inc. account number XXXX2280

0312812011 - $7,000.00 cash withdrawal from Vision CommunicationsKS. Inc. account number XXXX2280

0313012011 - S2,000.00 cash deposit to Ramon Mosate Emprise Bankaccount number XXXI954

0313012011 - $2,060.29 withdrawal made tbr the mortgage paymentfor 3i03 North Den Hollow Court, Wichita, Kansas

08/17-19/2011 0811712011 - $58,400.00 USD 266 check deposited into ChristopherConcepcion Emprise Bank account number XXXX9652

0811912011 - $9,000.00 cash deposit to Ramon Mosate Emprise Bankaccount number XXXX1954

081191201I - $7,804.70 withdrawal made for the mortgage paymentfor 3 103 North Den Hollow Coufi, Wichita, Kansas

12il6-22t201.1 1211612011 - $9,960.00 USD 266 check deposited into Bayena YenikaBank of the West account# XXXXX9897

1212012011 - $6,000.00 cash withdrawal from Bayena Yenika Bank ofthe West account# XXXXX9897

Page 14 of 17

I


1212112011 - $6,000.00 deposit to Ramon Mosate Emprise Bankaccount number XXXXl954

12/2212011 - $5,693.78 withdrawal made for the mortgage paymentfor 3103 North Den Hollow Court, Wichita, Kansas

1211612011 - $158,982.77 USD 266 check deposited into MLCM LLCEmprise Bank account number XXXX8107

1212712011 - $6,500.00 cash deposit to Ramon Mosate Emprise Bankaccount number XXXXI 954

12/2712011 - $6,000.00 withdrawal made for the mortgage paymentfor 3 103 North Den Hollow Court, Wichita, Kansas

12/16-271201t

03n6-3012012 03/1612012 - $40,907.48 USD 266 check deposited into MLCM LLCEmprise Bank account number XXXX8l07

03/30/2012 - $8,000.00 cash withdrawal from MLCM LLC EmpriseBank account number XXXX8107

0313012012 - $3,000.00 cash deposit to Ramon Mosate Emprise Bankaccount number XXXX 1954

0313012012 - $2,609.40 withdrawal made for the mortgage paymentfor 3 103 North Den Hollow Court, Wichita, Kansas

Date Time Amount Descriptiorr

02/28t2014 12:12P.M $66,1 37.00 USD 266 check deposit into MLCM, LLC, account

0310312014 10:39A.M.

$ l 7,000.00 Official Check to Ramon Mosate fiom MLCM, LLC,account

Page 15 ol' l7

1212712011- $9,700.00 cash withdrawal from MLCM LLC EmpriseBank account number XXXX8107

Financial Analvsis

46. From February 28,2014, to September 3,2014, atotal of$211,941.80 in checks fromUSD 266 was deposited into MLCM, LLC, checking account at Emprise Bank. FromMarch 3, 2014,to September 11,2014, a total of$44,600.00 was transferred directlyfrom the MLCM, LLC, account to Ramon Mosate's Emprise Bank checking account(Account Number 9501954) and an additional $24,500.00 in Official Checks purchased

from the MLCM, LLC, account was deposited into the account. Additionally, I have

probable cause to believe and do believe that a total of$35,000.00 in cash that was

withdrawn from the MLCM, LLC, account was deposited into Ramon Mosate's account.

The table below provides a summary ofthe activity in both accounts related to these

transactions.


03/0312014 l2:41 P.M $ 17,000.00 Official Check deposit into Ramon Mosate account03t0612014 10:32

A.M.$7.000.00 Cash withdrawal from MLCM, LLC, account

03t06/2014 l7:02 P.M. $2,000.00 Cash deposit into Ramon Mosate account03t13/2014 s2,000.00 Transfer from MLCM, LLC, account to Ramon Mosate

account

04t1s/2014 11:34A.M.

922,020.00 USD 266 check deposit into MLCM, LLC, account

04fi612014 9:55 A.M. $7,000.00 Cash withdrawal from MLCM, LLC, account

041t612014 9:56 A.M. $7,000.00 Cash deposit into Ramon Mosate account

04/1812014 10:10A.M.

$7,000.00 Cash withdrawal from MLCM, LLC, account

0411812014 l5:18 P.M. $s.000.00 Cash deposit into Ramon Mosate account

0412912014 10:57A,M.

$38.350.00 USD 266 check deposit into MLCM, LLC, account

04t2912014 3:53 P.M. $5,500.00 Transfer from MLCM, LLC, account to Ramon Mosateaccount

05/271201.4 3:24P.M. $29.839.80 USD 266 check deposit into MLCM, LLC, account

06t0212014 1l:11A.M.

$s,000.00 Transfer from MLCM, LLC, account to Ramon Mosateaccount

0610612014 9:23 A.M. $5,000.00 Transfer from MLCM, LLC, account to Ramon Mosateaccount

06,1812014 2:58 P.M. $21,614.00 USD 266 check deposit into MLCM, LLC, account

0612012014 9:02 A.M. $6,000.00 Transfer liom MLCM, LLC, account to Ramon Mosateaccount

0612512014 1 1:03A.M.

$4,800.00 Transfer from MLCM, LLC, account to Ramon Mosateaccount

07 /1s12014 10:55A.M.

$ 1 6,600.00 USD 266 check deposit into MLCM, LLC, account

07 t2212014 9:08 A.M $4,000.00 Transfer lrom MLCM, LLC, account to Ramon Mosateaccount

07 t2512014 l0:46A.M.

$2,300.00 Transfer from MLCM, LLC, account to Ramon Mosateaccount

0810612014 8:40 A.M. $6.440.00 Vision Comm. KS check deposit into MLCM, LLC,account

08106t2014 10:50A.M.

$3,000.00

0910312014 10..25

A.M.$38,960.00 USD 266 check deposit into MLCM, LLC, account

09t0412014 11:51

A.M.$7,000.00

09111/2014 9:46 A.M. $7,s00.00 Official Check to Ramon Mosate from MLCM, LLC,account

09/11r2014 Unknown $7.500.00 Official Check deposit to Ramon Mosate accountln

Page 16 ol 17

9:23 A.M.

Transfer from MLCM, LLC, account to Ramon Mosateaccount

Transfer fiom MLCM, LLC, account to Ramon Mosateaccount


47. On November 17 , 2014, United States Magistrate Judge Karen Humphreys issued aseizure warrant to seize the contents of account number XXXX1954 up to approximately$104,000.00 based upon the above information. On November 18,2014, the seizurewarrant was executed, and resulted in the seizure of $5,357.36.

SEARCH WARRANT FOR EMPRISE BANK SAFE,TY DEPOSIT BOX# 259

48. Information was obtained through various sources during the course of the investigationthat Ramon Mosate had rented a safety deposit box from Emprise Bank. A review offinancial records obtained from Emprise Bank revealed that the saf'ety deposit boxassociated with Mosate was box number 259 located at Emprise Bank, 10620 West 21'tStreet North, Wichita, Kansas.

49. On Novemb er 17,2014, United States Magistrate Judge Karen Humphreys issued a

search and seizure warrant for the contents of the safety deposit box.50. On Novemb er 18,2014, the search and seizure warrant was executed for safety deposit

box number 259. Located inside the box were numerous documents associated withRamon Mosate, included his passport, information relating to Banco Popular accountnumber 721868255, and two large envelopes containing approximately $80,000.00 incash.

51. Based on the foregoing, I have probable cause to believe that Ramon Mosate and othersfraudulently obtained funds in excess of $1,000,000.00 from USD 266. Based on theinvestigation, I have probable cause to believe the real property and currency identified inparagraph 2 constitute or were derived from proceeds traceable to violations of 18 U.S.C.

9371; 18 U.S.C. $666;18 U.S.C. $1343; l8 U.S.C. $1344(2); 18 U.S.C. $1346; l8U.S.C.91349; and 18 U.S.C. $1956(aXlXBXi) & (iD, or is property involved inviolations of 18 U.S.C. $1956(a)(1XBXD & (iD.

SA THOMAS S. ENSZFederal Bureau of Investigation

Subscribed to and swom before me this 21th day of November, 2014.

O-]-UJL--Notarv Public

My commission expires

NOTARY PUBLIC - State ot KansaS

PATTI J. KORW IN

l- aLl -3.orf,

My ApPt. Expirest-a* -eor5 Page 17 ol l7

CONCLUSION

.<----1-<
