6cv (03.u^ - wpri.com · councilorbetween 2014 and 2016. 3. in or about january 2013, correia began...

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UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS SEALED UNITED STATES OF AMERICA ) ) V. ) Criminal No. \6cv (03.U^ ) Violations: JASIEL F. CORREIA, II, ) ) Counts One - Nine: Wire Fraud ) (18U.S.C. § 1343) Defendant ) ) Counts Ten - Thirteen: False Tax Returns ) (26 U.S.C. § 7206(1)) ) ) Forfeiture Allegation: ) 18 U.S.C. § 981(a)(1)(C); ) 28 U.S.C. § 2461(c) INDICTMENT General Allegations At all times relevant to this Indictment: 1. SnoOwI was a company conceived and founded by JASIEL F. CORREIA, II ("CORREIA") in late 2012 to develop an "app" designed to connect local businesses with their target consumer market. SnoOwl was incorporated in Delaware in December 2014. 2. CORREIA, 26, is the mayor of Fall River, Massachusetts. CORREIA was first elected in November 2015, and was re-elected by a wide margin to a second two-year term in November 2017. Prior to his election as mayor, CORREIA was a one-term Fall River City Councilor between 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return for equity in the company. To induce their investments, CORREIA represented to the SnoOwl investors that: (i) he was a successful tech entrepreneur who previously sold another app, Findit Networks, for a large profit; (ii) their Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 1 of 20

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Page 1: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTSSEALED

UNITED STATES OF AMERICA )

)V. )

Criminal No. \6cv (03.U^) Violations:

JASIEL F. CORREIA, II, )) Counts One - Nine: Wire Fraud) (18U.S.C. § 1343)

Defendant )) Counts Ten - Thirteen: False Tax Returns) (26 U.S.C. § 7206(1))

)) Forfeiture Allegation:) 18 U.S.C. § 981(a)(1)(C);) 28 U.S.C. § 2461(c)

INDICTMENT

General Allegations

At all times relevant to this Indictment:

1. SnoOwI was a company conceived and founded by JASIEL F. CORREIA, II

("CORREIA") in late 2012 to develop an "app" designed to connect local businesses with their

target consumer market. SnoOwl was incorporated in Delaware in December 2014.

2. CORREIA, 26, is the mayor of Fall River, Massachusetts. CORREIA was first

elected in November 2015, and was re-elected by a wide margin to a second two-year term in

November 2017. Prior to his election as mayor, CORREIA was a one-term Fall River City

Councilor between 2014 and 2016.

3. In or about January 2013, CORREIA began seeking investors who were willing to

provide investment money for SnoOwl in return for equity in the company. To induce their

investments, CORREIA represented to the SnoOwl investors that: (i) he was a successful tech

entrepreneur who previously sold another app, Findit Networks, for a large profit; (ii) their

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 1 of 20

Page 2: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 2 of 20

Page 3: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 3 of 20

Page 4: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 4 of 20

Page 5: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 5 of 20

Page 6: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 6 of 20

Page 7: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 7 of 20

Page 8: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 8 of 20

Page 9: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 9 of 20

Page 10: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 10 of 20

Page 11: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 11 of 20

Page 12: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 12 of 20

Page 13: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 13 of 20

Page 14: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 14 of 20

Page 15: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 15 of 20

Page 16: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 16 of 20

Page 17: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 17 of 20

Page 18: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 18 of 20

Page 19: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 19 of 20

Page 20: 6cv (03.U^ - WPRI.com · Councilorbetween 2014 and 2016. 3. In or about January 2013, CORREIA began seeking investors who were willing to provide investment money for SnoOwl in return

Case 1:18-cr-10364-DPW Document 1 Filed 10/04/18 Page 20 of 20