IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA, 6p = BEFORE ME, Judge Meu, qg ie v aa __ of the Eleventh Judicial Circuit Court in and for Miami-Dade County Florida, personally came, Financial Crimes Investigator Neptime Dicujuste of the Florida Office of Financial Regulation, after being duly sworn, deposes and says that Anson Jean-Pierre, B/M, DOB: 04/12/1962 and Edy Durosier, B/M, DOB 10/28/1973, in the aforesaid County and State, did unlawfully violate the following Florida Statutes; CHARGES: Anson Jean-Pierre, B/M, DOB: 04/12/1962: ‘+ One (1) count of Racketeering in violation of Fla. Stat, §§895.03.and 910.01. a first degree felony. One (1) count of Money Laundering in the First Degree in violation of Fla Stat. §896.101(5)(C),a first-degree felony © One (1) count of Organized Scheme to Defraud in an amount of $50K or greater, in violation of Fla, Stat, §817.034(4)(a)2, a first-degree felony. © One (1) count of Organized Scheme to Defraud in an amount between $20K and $50K or more, in violation of Fla Stat. §817.034(4)(a)2, a second degree felony, ‘+ Eight (8) counts of Organized Scheme to Defraud in an amount of $20K or less, in violation of Fla Stat. §817.034(4)(A)3 a third-degree felony. © One (1) count of Grand Theft in the Second Degree, in violation of Fla. Stat. §812.014(2)(B), a second-degree felony. ‘© Nineteen (19) counts of Grand Theft in the a third-degree felony. * Nine (9) counts of Engaging in Fraudulent Security Transactions through the Falsification or Concealment of Facts in violation of Fla, Stat. §517.301 (1)(a)2, a third-degree felony. © One (1) count of Engaging in Fraudulent Security Transactions with a value of more than $SOK from Five or More Persons violation of Fla, Stat. §517.302.2, a first-degree felony. Degree, in violation of Fla. Stat. §812.0142)(C), Edy Durosier, B/M, DOB 10/28/1973, ‘© One (1) count of Racketeering in violation of Fla, Stat. §§895.03.and 910.01. a first degree felony, ‘One (1) count of Money Laundering in the First Degree in violation of Fla Stat. §896.101(5(C), a first-degree felony ‘© One (1) count of Organized Scheme to Defraud in an amount of $50K or greater, in violation of Fla, Stat. §817.034(4)(a)2, a first-degree felony. ‘* One (1) count of Organized Scheme to Defraud in an amount between $20K and $50K or more, in violation of Fla, Stat. §817.034(4)(a)2, a second degree felony. ‘+ Eight (8) counts of Organized Scheme to Defraud in an amount of $20K or less, in violation of Fla, Stat. §817.034(4)(A)3 a third-degree felony. ‘+ One (1) count of Grand Theft in the Second Degree, in violation of Fla, Stat. §812.014(2(B), @ second-degree felony. Affiant’s Initials ASA’s Initials /s/ M Judge’s Initials ys 1of 13,‘© Nineteen (19) counts of Grand ‘Theft in the Third Degree, in violation of Fla, Stat. §812.014(2\(C), a third-degree felony. ‘+ Nine (9) counts of Engaging in Fraudulent Security Transactions through the Falsification or Concealment of Facts in violation of Fla, Stat, §517.301 (1}(a)2, a third-degree felony. ‘© One (1) count of Engaging in Fraudulent Security Transactions with a value of mote than $50K, from Five or More Persons violation of Fla, Stat. §517.302.2, a first-degree felony. 1. Your affiant, Neptime Dieujuste, has been employed as a Financial Crimes Investigator with the State of Florida Office of Financial Regulation (hereinafter referred to as “FLOFR”), Bureau of Financial Investigations (hereinafter referred to as “BFT”), for over fifteen (18) years. Your affiant has completed more than fifty (50) investigations and is currently involved in twenty-two (22) on-going investigations. Your affiant has received in-service training by the FLOFR and external training by personnel in the law enforcement profession, which included cours. in financial fraud and conducting financial fraud investigations. As a financial crimes investigator with the FLOFR, your affiant’s duties consist of investigating indi iuals and companies alleged to be in violation of Florida Statutes related to securities, banking, mortgage lending, mortgage fraud, retail installment entities, money services businesses and other areas of the financial services industry. 2. This affidavit is provided for the limited purpose of establishing probable cause in support of an arrest warrant, Your affiant has not included all details of this investigation, but rather has set forth only those facts that are necessary to establish probable cause, ‘The information in this affidavit is based ‘upon your affiant’s personal knowledge as well as information obtained from officers, victims, and from a review of documentation related to the investigation, 3. Youraffiant conducted an investigation of Anson Jean-Pierre (“Jean-Pierre”), manager and president of Brothers Investment Group Intemational, LLC (“Brothers Investment”) and Edy Durosier, manager of Advantage Realty & Investment Group, LLC (“Advantage Realty”) and leader of Brothers Investment’s “Real Estate Group.” Affiant’s Initials £7 ASA’s Initials /s/ MI Judge’s Initialsed” 20f 134. Brothers Investment Group International, LLC was a Florida limited liability company with it principal place of business listed as 1380 NE Miami Gardens Drive, Suite 130, North Miami Beach, FL 33162. Brothers Investment was incorporated in Florida on or about August 22, 2017, by Anson Jean- Pierre. Jean-Pierre was also its registered agent and manager, according to the Florida Department of State, Division of Corporations. 5. Advantage Realty & Investment Group, LLC was a Florida limited liability company with its principal place of business listed as 1314 E Las Olas Blvd, Fort Lauderdale, Florida 33301. Advantage Realty was incorporated in Florida on or about June 27, 2017. Edy Durosier was listed on the Florida Department of State, Division of Corporations as manager of the company. 6 Between August 2017 through at least January 4, 2019, in Miami-Dade and elsewhere, Jean-Pierre and Durosier, acting together, obtained money from investors through the offering of fraudulent investment opportunities. Jean-Pierre and Durosier solicited investments from potential investors in the form of membership interests in Brothers Inv tment, Jean-Pierre and Durosier hosted a series of meetings. during which they represented to potential investors that their money would be used (0 fund a variety of projects. Brothers Investment was divided into ten different “investment groups.” Purported investment opportunities included real estate and agricultural projects in Haiti, as well as purchasing an international bank with a branch office in Florida, Durosier also told potential investors that he had developed a renewable energy device capable of providing solar energy and intemet services in Haiti, Brothers Investment also sold fake “foreign diplomatic classes” for $600. Investors were told that after paying for and completing the course, they would be recognized as highly ranked representatives of Brothers Investment with special privileges when they traveled internationally. Jean-Pierre represented to investors that he was the president of Brothers Investment, He signed documents and correspondence to investors as “president.” Florida Department of State records showed Jean-Pierre as the manager of Brothers Investment. Durosier led the Real Estate Group of Brothers Affiant’s Initials_ @2~ ASA’s Initials /s/ ME Judge’s Initials ag, 3 of 13Investment. Durosier told potential investors in the Real Estate Group that he would use their personal information to apply for credit cards on their behalf and obtain cash advances from the credit cards, ‘That money would then be used as investment money to buy and flip residential properties in Miami-Dade County and elsewhere. 7. Jean-Pierre and Durosier used their claims about their projects and purported business ventures to induce individuals to invest with Brothers Investment, Brothers Investment asked potential investors to pay $3,650 in “seed money” which they told investors would go towards funding the projects and $150 “registration fee” to cover non-project related expenses. Jean-Pierre and Durosier told their potential investors they would be “millionaires” within the next few years because they would share Brothers Investment’s profits from the projects in which they invested and financed. Neither Jean-Pierre nor Duros 1 ever told investors that their money would be used for personal living expenses, hotels, restaurants, vacations in the Caribbean, payments to themselves, payments to Durosier’s other company, Advantage Realty, refunds to other investors who requested their money back, or cash withdrawals. 8. Your affiant obtained copies of banking records and documents belonging to Brothers Investment from Bank of America and TD Bank. Your affiant also obtained bank account records of Advantage Realty from TD Bank. Analyses of these documents between the operative period show that Jean-Pierre and Durosier did not make any investments with funds collected from investors as promised Your affiant’s investigation indicates that Jean Pierre controlled the Brothers Investment bank accounts. Durosier was the only signatory on the Advantage Realty’s account located at TD bank. 9. Your affiant is aware that “a pattern of racketeering activity,” as defined by Pla. Stat §895.02(1}) and Fla, Stat. §895.02(4), Florida’s RICO (Racketeer Influenced and Corrupt Organization), means engaging in at least two incidents of racketeering conduct that have the same or similar intents results, accomplices, victims, or methods of commission or that otherwise are interrelated by distinguishing characteristies and are not isolated incidents. Affiant’s Initials ASA’ Initials /s/ ME Judge’s Initiale4g2e~ 4 0f 1310. Your affiant is aware that an “enterprise” means any individual, sole proprietorship. partnership, corporation, business trust, union chartered under the laws of this state, or other legal entity, or ‘any unchartered union, association, or group of individuals associated in fact although not a legal entity and it includes il cit as well as licit enterprises and governmental, as well as other, entities pursuant to Fla. Stat. §895.02(5). IL. You affiant’s investigation revealed that Brothers Investment qualifies as an “enterprise” within the meaning of Fla, Stat, §895.03(5). Its a legal entity that continuously operated within the State of Florida during all relevant time periods. Your affiant’s investigation shows Brothers Investment that was created and controlled by Jean-Pierre and operated for the purpose of committing organized fraud, grand theft, and money laundering. Your affiant is aware that organized scheme to defraud (Fla, Stat {§817.034(4)(a)1), grand theft (Pla, Stat. §817.034(2\(B)1), any crimes relating to sale of securities and investor protection (Fla. Stat. §517), and money laundering (Fla. Stat, $896.101(5\(©)) are predicate offenses for racketeering under §895.02(8), 12. Your affiant’s investigation has revealed that both Jean-Pierre and Durosier solicited and obtained funds from investors based on false promises and misrepresentations. Both used those funds for purposes unrelated to the purported investment. As previously stated, in addition to having his own busit which received i stor funds without investors’ knowledge (Advantage Realty) Durosier was in charge of Brothers Investment’s Real Estate Group, one of Brothers Investment’s ten “investment groups.” Your affiant reviewed banking records for Brothers Investment’s bank account at Bank of America ending in 9609. Your affiant also reviewed TD Bank records for Brothers Investment ending in 1845, 5168,6158, 6166, 7744, and 9222. Your affiant determined that once investors’ money was deposited into these accounts, the money was used by Jean-Pierre to make payments to Durosiet and Advantage Realty as well as paying personal expenses, including but not limited to, hotels, restaurants, airlines tickets, utilities, and ‘groceries. Jean-Pi re never used investors’ money for its specifically solicited purposes. Affiant’s Initials 42 ASA’s Initials /s/ ME Judge's Initials 44 4 Sof 13unlawful and a 13. Your affiant is aware that pursuant to Fla, Stat. §517.301 (1)(a)2), violation of the provisions of this chapter for a person in connection with the rendering of any investment advice or in connection with the offer, sale, or purchase of any investment or security, including any security exempted under the provisions of §517.051 and including any security sold in a transaction exempted under the provisions of § 517.061, directly or indirectly, to employ any device, scheme, or artifice to defraud; to obtain money or property by means of any untrue statement of a material fact or any omission to state a it of the circumstances under which material fact necessary in order to make the statements made, in the they were made, not misleading. From August 2017 through at least January 4, 2019, Jean-Pierre and Duros + engaged in selling unregistered securities to numerous investors in Miami-Dade County and elsewhere by making fraudulent claims about investment opportunities, projects, and returns. None of the investors who provided money to Brothers Investment had thorough knowledge of the investment instruments or opportunities. 14. In the summer of 2017, Frantz Louissaint (“Louissaint") was introduced to Brothers Investment by Leon George Anglade (“Anglade”). Louissaint told your affiant that he attended a meeting with several members of Brothers Investment, but Jean-Pierre and Durosier did most of the talking and planning. The initial meeting was with approximately twenty-five people at a church on 164th street in Miami, Florida, During the presentation Durosier told potential investors that he was a lawyer, a law Flo professor at St. Thomas University, and had a law firm on 163rd street in North Miami Beacl ‘Your affiant’s investigation has revealed these claims to be false, Durosier also claimed he had an invention that could provide solar power to Haiti; and that it was developed at Florida International University North campus. Jean-Pierre and Durosier told investors, including Louissant, that Brothers Investment was trying to get potential investors to invest $10 per day for 365 days plus a $150 membership fee. Using the $365,000 from that investment as collateral, they would procure a loan from a bank for $3,650,000 and use that money to invest in real estate, agriculture in Haiti, and the solar energy project in Haiti. Jean-Pierre and Durosier Affiant’s Initials @2~ ASA’s Initials /s/ ME Judge's Initialg pg / 60f13told investors that they could buy "shares" of Brothers Investment which would not give them membership status but would be worth six times the purchase price by May 2018. 15. As a result of these statements by Durosier and Jean-Pierre, between approximately September 4, 2017, and January 17, 2018, Louissaint, both himself and on behalf of other family members, provided money to Brothers Investment for investment in the purported projects and purchase of Brothers, Investment stocks. On September 4, 2017, he provided a check for $150.00 to Brothers Investment, On December 21, 2017, Louissaint provided two checks totaling $14,600.00 to Brothers Investment, On January 17, 2018, he provided two checks to Brothers Investment: one for $500.00 and another check for $1,000.00. Your affiant’s review of Brothers Investment’s banking records shows none of the money provided by Louissant’s checks was used by Brothers Investment for investment purposes. Louissaint never obtained any stock certificates from Brothers Investment. 16. Faberna Pierre (“F. Pierre”), her sister Elle Sabrina Pierre (“E. Pierre”), and her father, Jacques F. Pierre ("J. Pierre”), were introduced to Jean-Pierre by, her father’s friend, Scheller Leconte (“Leconte”). Leconte told the Pierre fan ly about Brothers Investment, Jean-Pierre, and provided them Brothers Investment investment plan. According to F. Pierre, she and her family trusted Leconte’s referral to Jean-Pierre and Brothers Investment because she knew Leconte from church, 17. The Pierre family met with Jean-Pierre at an insurance business in Miami, Florida. During the meeting, Jean-Pierre told the Pierre family that any money they invested with Brothers Investment ‘would be invested in several areas, and they would all receive a return of their investment after one year. Jean-Pierre told the Pierre family members that all any money provided to Brothers Investment would go towards actual investment. 18. As a result of Jean Pierre’s pitch, between October 6, 2017, and December 19, 2017, the Pierre family provided money to Brothers Investment for investment purposes. Her father, J. Pierre, provided a check to Brothers Investment in the amount of $150.00 which was deposited into Brothers Affiant’s Initials > —— ASA’s Initials /s/ ME Judge’s Initial i@/ 7of 13Investment Account on October 6, 2017; a check in the amount of $1,000.00, deposited into Brothers Investment Account October 13, 2017; a check in the amount of $1,000.00, deposited into Brothers Investment Account on October 23, 2017; a check in the amount of $1,000.00, deposited into Brothers, Investment Account on November 11, 2017, and a check in the amount of $2,300.00, deposited into Brothers Investment Account on January 2, 2018. None of J. Pierre’s money was used for investment purposes. 19. F. Pierre provided a check to Brothers Investment in the amount of $150.00 which was deposited into Brothers Investment account on October 6, 2017; a check for $1,000.00, deposited into Brothers Investment account on October 13, 2017; and a check for $1,000.00, deposited into Brothers Investment account on December 1, 2017. F, Pierre believed her funds were to be placed into the Real Estate Group for the purposes of investing in real estate, None of F. Pierre’s money was used for investment purposes, 20. _E, Pierre provided a check to Brothers Investment in the amount of $1,000.00 which was deposited into Brothers Investment account on October 19, 2017; a check for $650.00, deposited into Brothers Investment account on October 30, 2017; and a check for $1,000.00, deposited into Brothers Investment account on December 8, 2017; and a check for $1,000.00, deposited into Brothers Investment account on December 19, 2017. B. Pierre was told that her funds were placed into the Real Estate Group for the purposes of investing in real estate. None of E, Pierre’s money was used for investment purposes. 21. Your affiant interviewed Manus Delva (“M. Delva"). M. Delva stated that he learned of Brothers Investment through an acquaintance who invited M. Delva to attend an investor meeting on Miramar Parkway, near 441, Broward County, Florida, in December 2017. Numerous investors attended the meeting, Both Jean-Pierre and Durosier presided over the meeting, They stated that M. Delva and the other attendees had an opportunity fo invest in farm work in Haiti, They stated that Brothers Investment Affiant’s iit _ ASA’s Initials /s see Judge’s Initials yQA/ 8of 13wanted to replicate agricultural techniques of farmers in Israel. M. Delva was told that once the business ‘grows, the investors would be millionaires. 22. After the meeting, M. Delva provided money to Brothers Investment. M. Delva provided a check to Brothers Investment in the amount of $1,500.00 which was deposited into Brothers Investment account on January 2, 2018. He provided a check in the amount of $1,500.00, deposited in Brothers Investment on January 18, 2018. Jean-Pierre told M. Delva he had purchased land in Haiti to grow and export tomatoes and wanted to launch the company soon because he did not want investors thinking he stole the money they had invested with Brothers Investment. M. Delva’s money was not used for investment purposes. 23. After M. Delva’s initial investment, Jean-Pierre approached M. Delva about using M, Delva’s credit to take out personal loans for a new limousine business. Jean-Pierre said the limousine business was to make money for Brothers Investment to do good by the investors. In December 2018, Delva then applied and received two personal loans in approximately $21,500 from Marcus by Goldman Sachs and $39,793.53 from PNC Bank, The lenders deposited the funds into M. Delva’s Bank of America account ending in 6137. On December 13, 2018, M. Delva gave Jean-Pierre a check in the amount of $22,617.00 made out to Brothers Investment for investment purposes. On January 4, 2019, Delva wrote a check to cash for amount of $13,900 to start the new company. Jean-Pierre made monthly payments on the loans for approximately $765 to Delva to remit to the loan companies. Pierre then stopped making payments, ‘on the loans in May 2022 and has not returned M, Delva’s telephone calls 24, Violette Milien (“Milien”) was introduced to Jean-Pierre by her cousin, Paulette Almonor (“Almonor”), Jean-Pierre told Milien her money would be invested different things, including Wall Street investments and Milien would receive a return on her investment after one year. Jean-Pierre also told Milien ‘that members of the investment group would receive a share of the profit from Brothers Investiment’s projects. On December 27, 2017, Milien invested approximately $3,600 for herself and $3,600 for her Affiant’s Initials @2—~ ASA’s Initials /s/ ME Judge's Initials aa 9 of 13,daughter Kimberly Milien, In addition, Milien paid a $150 membership fee for both she and her daughter. On February 8, 2018, Milien paid a $600 fee to participate in a diplomatic group she which was formed for the purpose of traveling to different countries and being regarded with status as a highly ranked representative of the investment group. 25, Milien told your affiant the money she gave Jean-Pierre was for investment purposes only and she did not authorize itto be spent on salaries, personal expenses, or travel. Milien believed her money was placed into the Real Estate Group, headed by Durosier, but she did not make any additional investments. Milien asked Jean-Pierre for a refund. Milien gave Brothers Investment a total of $7,950.00 for investment purposes, To date, she has not received her money back. 26. On February 12, 2018, Luna Marchand (“Marchand”) invested $3,650 with Brothers Inyestment, paid the $150 membership fee and $600 for a diplomatic seminar being offered by Brothers Investment. Marchand also paid $100 to be a member of the Real Estate Group led by Durosier. Jean-Pierre told Marchand that Brothers Investment was going to cr fe a company in Haiti to transport Haitian coffee to Columbia and other countries, which would generate profits to pay investors a return on their investment within a short period of time. Marchand repeatedly asked Jean-Pierre for her money back. On May 5, 2018, Jean-Pierre responded to one of Marchand text messages, stating that the business was still in the works and that Marchand, and the other investors did not understand “business” which is why they wanted their ‘money back. Jean-Pierre asked investors to sign documents that they would not receive their money back ‘once invested. Further, Jean-Pierre told Marchand he would not return her money beeause it was placed somewhere waiting to be used for the investment, Marchand has not received her money back from Jean- Pierre, None of Marchand’s money was used for investment. 27. Your affiant interviewed Preval Floreal (“Floreat”). Floreal is a retired pastor. Floreal Jeamed of Brothers Investment through an acquaintance, Joseph Carno (“Caro”), Floreal stated that Jean- Pierre, Durosier, and nine others ran Brothers Investment. Jean-Pierre and Durosier claimed they planned Affiant’s Initials¢7_ ASA’: Judge's Initials yu J* 10 of 13, Jto raise the standard of living of Haitians in both Miami, Florida and Haiti by investing in agriculture, businesses, real estate, building a Haitian bank, and bringing solar powered generators to Haiti, Durosier told Floreal he would make a lot of money from the investments, On May 17, 2018, Floreal invested $7,000.00, Floreal was placed in the Real Estate Group of Brothers Investment, ran by Durosier. Durosier told Floreal that his money would be used to buy and flip houses in Miami, Plorida, Floreal’s money was never used to buy and flip a house, Additionally, Floreal reported that in addition to the money provided to Brothers Investment Real Estate Group, throughout the time frame he gave Durosier approximately $35K in cash for real estate transactions. To date, Floteal has not received his money back and does own any additional properties 28. Rose L. Delva (“R. Delva”) learned of Brothers Investment through her friend Milien. R. Delva attended a gala organized by Brothers Investment during which Jean-Pierre introduced himself at the president of Brothers Investment and stated that he was in charge of Brothers Investment, Jean-Pierre told investors that Brothers Investment would invest their money in real estate. On December 25, 2017, R. Delva invested a total $3,650.00 with Brothers Investment. In June 2018, R. Delva received a “Certificate of Guarantee” from Jean-Pierre which stated that Brothers Investment would share its revenue and profits with investors. To date, R. Delva has not received any profits from Brothers Investment. R. Delva has been unable to contact Jean-Pierre. 29. Your affiant examined and analyzed Brothers Investment’s TD Bank accounts ending in 9222, 1845, 5168, 6166, 6158. Your Affiant also examined Brothers Investment's Bank of America account ending in 9606. These records show Brothers Investment’s business banking records and for the operative period, Brother Investment collected approximately $694,989 from about myriad investors, including the funds of the aforementioned vietims, You affiant’s investigation has revealed that although there were multiple signatories on the signature card of Brothers Investment accounts, Jean-Pierre controlled and utilized the accounts and their contents. Jean-Pierre spent approximately $150,000.00 of the investor funds Affiant’s Initials g=2—~ ASA’s Initials /s"M1 Judge's Initials (af 11 of 13for personal expenses including not limited to restaurants, hotel charges, vacations in the Caribbean, airline tickets, cash withdrawals and retail purchases. Throughout the operative period, Jean-Pierre also gave Durosier and Advantage Realty approximately $86,302. He provided approximately $21,860.00 to other investors as refunds to quell complaints against Brothers Investment. Jean-Pierre and Durosier did not invest any of the investor funds as promised. On November 17, 2017, Brothers Investmer ‘wired $60,000 to BurgerIM Group USA, Ine, (“BurgerIM”) as a down payment to purchase a burger franchise, BurgerIM returned the $60,000.00 and it was deposited into Brothers Investment’s Bank of America account ending in 9609, on September 6, 2018. None of the investors gave money for investment in a burger franchise Upon depositing the refund check into account ending 9609, Jean-Pierre used it to pay himself approximately $3,000 and make refunds to other investors for approximately $8,500.00. Brothers Investment also paid approximately $200,000.00 in consulting fees for projects. Neither Jean Pierre nor Durosier informed any investors that their investment money would be used for consulting fees. Jean- Pierre did not invest investor funds in a single revenue generating project, but continuously told investors that their money was in the bank when, in fact, he had already spent it. Based on the forgoing, your affiant respectfully requests an arrest warrant be issued for Anson Jean-Pierre, B/M, DOB: 04/12/1962: ‘+ One (1) count of Racketeering in violation of Fla, Stat. §§895.03.and 910.01. a first degree felony, ‘+ One (1) count of Money Laundering in the First Degree in violation of Fla Stat. §896.101(5XC), a first-degree felony ‘+ One (1) count of Organized Scheme to Defraud in an amount of $50K or greater, in violation of Fla, Stat. §817.034(4)(a)2, a first-degree felony '* One (1) count of Organized Scheme to Defraud in an amount between $20K and $S0K or more, in violation of Fla, Stat. §817.034(4)(a)2, a second degree felony. * Eight (8) counts of Organized Scheme to Defraud in an amount of $20K ot less, in violation of Fla. Stat. §817.034(4)(A)3 a third-degree felony. # One (1) count of Grand Theft in the Second Degree, in violation of Fla. Stat. §812.014(2)(B), a second-degree felony. * Nineteen (19) counts of Grand Theft in the Third Degree, in violation of Fla, Stat. §812.014(2)(C), a third-degree felony. * Nine (9) counts of Engaging in Fraudulent Security Transactions through the Fal Concealment of Facts in violation of Fla, Stat. §517,301 (1}(a)2, a third-degree felony. Affiant’s Initials <> ASA’s Initials /s/ Mi Judge's Initial, oA « ication or 12 of 13,© One (1) count of Engaging in Fraudulent Security Transactions with a value of more than $50K from Five or More Persons violation of Fla, Stat, §517.302.2, a first-degree felony, Edy Durosier, B/M, DOB 10/28/1973, © One (1) count of Racketeering in violation of Fla, Stat, §§895.03.and 910.01. a first degree felony. One (1) count of Money Laundering in the First Degree in violation of Fla Stat. §896.101(5(C), a first-degree felony * One (1) count of Organized Scheme to Defraud in an amount of $50K or greater, in violation of Fla, Stat. §817.034(4)(a)2, a first-degree felony. * One (1) count of Organized Scheme to Defraud in an amount between $20K and $50K or more, in violation of Fla. Stat. §817.034(4)(a)2, a second degree felony. ight (8) counts of Organized Scheme to Defraud in an amount of $20K or less, in violation of Fla Stat. §817.034(4)(A)3 a third-degree felony. * One (1) count of Grand Theft in the Second Degree, in violation of Fla, Stat, §812.014(2)(B), a second-degree felony. ‘+ Nineteen (19) counts of Grand Theft in the Third Degree, in violation of Fla, Stat. §812.0142\(C), a third-degree felony. + Nine (9) counts of Engaging in Fraudulent Security Transactions through the Falsification or Concealment of Facts in violation of Fla. Stat. §517.301 (1)(a)2, a third-degree felony. + One (1) count of Engaging in Fraudulent Security Transactions with a value of more than $SOK from Five or More Persons violation of Fla, Stat. §517.302.2, a first-degree felony. Einaricial Crimes Investigator State of Florida Office of Financial Regulation Joh, SWORN TO AND SUBSCRIBED ON THIS“ DAY OF DEG Judge Eleventh Judicial Circuit of Florida Judge’s Initials 4.6-< 13 of 13,