BEF/MWS: USAO 2006R00025 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND UNITED STATES OF AMERICA * * v. * CRIMINAL NO. __________________ * PATRICIA OMONDI * (Interstate Transportation of Property a/k/a Patricia Sanfo, * Obtained by Fraud, 18 U.S.C. § 2314; a/k/a Patricia O’Mundy, and * Money Laundering, 18 U.S.C. § 1957; BOUREIMA SANFO * Aiding and Abetting, 18 U.S.C. § 2; a/k/a Abraham Sanfo * Obstruction of Justice, 18 U.S.C. a/k/a Ibraham Sanfo, * § 1503; Forfeiture, 21 U.S.C. § 853, * 28 U.S.C. § 2461(c), 18 U.S.C. Defendants * § 981(a)(1)(C)) * ******* INDICTMENT COUNTS ONE THROUGH NINE The Grand Jury for the District of Maryland charges that: At all times relevant to this indictment. 1. Defendant PATRICIA OMONDI, a/k/a Patricia Sanfo, a/k/a Patricia O’Mundy (“OMONDI”) was the president of Raycha Homes, also known as Construction Consulting and Management (“CCM”), a residential home builder located at 1529 Old Bridge Road, Suite 7, Woodbridge, Virginia. 2. Defendant BOUREIMA SANFO, a/k/a Abraham Sanfo, a/k/a Ibraham Sanfo (“SANFO”) was as a loan officer for Raycha Homes and Allstate Mortgage and was married to OMONDI. The Scheme to Defraud 3. From in or about November 2004 to in or about December 2005, in the District of Maryland and elsewhere, the defendants, PATRICIA OMONDI, a/k/a Patricia Sanfo, a/k/a Patricia O’Mundy, and BOUREIMA SANFO, a/k/a Abraham Sanfo, a/k/a Ibraham Sanfo, did knowingly and willfully devise and intend to devise a scheme and artifice to defraud and to obtain money and property by means of materially false and fraudulent pretenses, representations and promises (“the scheme to defraud”). 4. As a part of the scheme to defraud, OMONDI and SANFO met with individuals and promised to build homes for them on the lots of their choice. 5. As a further part of the scheme to defraud, OMONDI and SANFO drove individuals to view several parcels of land, purported to permit the buyer to select a lot for construction of his house. 6. As a further part of the scheme to defraud, OMONDI and SANFO caused individuals to select lots in Prince George’s County, Maryland for construction of houses. 7. As a further part of the scheme to defraud, OMONDI and SANFO gave individuals false, fictitious and fraudulent letters on the letterhead of a mortgage company falsely representing that the individuals had been pre-approved for mortgages. 8. As a further part of the scheme to defraud, OMONDI and SANFO falsely advised individuals that CCM had obtained permits to begin construction of their houses. 9. As a further part of the scheme to defraud, OMONDI and SANFO provided individuals with copies of the specifications, sketches and design drawings of houses. 2 10. As a further part of the scheme to defraud, OMONDI and SANFO caused individuals to enter into a contract with CCM for the construction and purchase of a house and to agree to a down payment schedule. 11. As a further part of the scheme to defraud, OMONDI and SANFO caused individuals to make monthly payments towards the down payment for the construction and purchase of new houses. 12. As a further part of the scheme to defraud, OMONDI and SANFO obtained more than $200,000 in payments from individuals who contracted with CCM to build a house as a result of defendants’ false, fictitious and fraudulent pretenses, representations and promises. Executing the Scheme to Defraud 13. On or about the dates set forth below, in the District of Maryland and elsewhere, the defendants, PATRICIA OMONDI, a/k/a Patricia Sanfo, a/k/a Patricia O’Mundy, and BOUREIMA SANFO, a/k/a Abraham Sanfo, a/k/a Ibraham Sanfo, did cause to be transported, transmitted and transferred in interstate commerce from Maryland to Virginia securities and money of the value of $5,000 or more, knowing the same to have been taken by fraud, in the amounts listed below: 3 Count Date Amount Person(s) Money Obtained From February 22, 2005 $5,000 S.K. March 17, 2005 $5,000 S.K. March 30, 2005 $5,000 S.K. April 7, 2005 $5,000 M.D. and N.D. April 8, 2005 $5,000 M.D. and N.D. April 11, 2005 $5,000 M.D. and N.D. May 23, 2005 $14,000 M.M.D.; D.N. and R.M. June 29, 2005 $112,700 T.C.; B.F.; M.M.D.; D.N. and R.M. August 22, 2005 $15,500 M.M.D.; E.T. 18 U.S.C. § 2314 18 U.S.C. § 2 4 COUNTS TEN THROUGH TWELVE The Grand Jury for the District of Maryland further charges that: 1. Paragraphs 1 through 12 of Counts One through Nine are incorporated here. 2. On or about the dates set forth below, in the District of Maryland and elsewhere, the defendants, PATRICIA OMONDI, a/k/a Patricia Sanfo, a/k/a Patricia O’Mundy, and BOUREIMA SANFO, a/k/a Abraham Sanfo, a/k/a Ibraham Sanfo, knowingly engaged and attempted to engage in monetary transactions in and affecting interstate commerce in criminally derived property that was of a value greater than $10,000 and was derived from specified unlawful activity (to wit, interstate transportation of property obtained by fraud in violation of Title 18, United States Code, Section 2314, as described in Counts One through Nine of the Indictment) at Provident Bank, a financial institution, in that they conducted the transactions described below: Count Date Description of Transaction 10 May 23, 2005 $14,000 deposit at Provident Bank branch located in Woodbridge, Virginia 11 June 29, 2005 $112,700 deposit at Provident Bank branch located in Woodbridge, Virginia 12 August 22, 2005 $15,500 deposit at Provident Bank branch located in Woodbridge, Virginia 18 U.S.C. § 1957(a) 18 U.S.C. § 2 5 COUNT THIRTEEN The Grand Jury for the District of Maryland further charges that: 1. In or about October 2006, a grand jury of the United States District Court for the District of Maryland, sitting in Greenbelt, Maryland, was conducting an investigation to determine, among other things, whether the defendants had committed violations of the federal criminal statutes relating to interstate transportation of property obtained by fraud, 18 U.S.C. § 2314, and money laundering, 18 U.S.C. § 1957, in connection with several contracts for the construction of houses in Prince George’s County, Maryland. 2. It was material to the grand jury’s investigation to determine whether OMONDI and SANFO had caused any studies to be conducted in 2005 in order to determine the feasibility of constructing houses on the lots chosen by individuals for the construction of their houses. 3. On or about October 20, 2006, in the District of Maryland, the defendants, PATRICIA OMONDI, a/k/a Patricia Sanfo, a/k/a Patricia O’Mundy, and BOUREIMA SANFO, a/k/a Abraham Sanfo, a/k/a Ibraham Sanfo, did corruptly influence, obstruct and impede and endeavor to influence, obstruct and impede the due administration of justice, to wit, the above-referenced grand jury investigation into whether they had engaged in fraud when they had entered into several contracts for the construction of houses in Prince George’s County, Maryland, (a) by providing a feasibility study for a lot located on Princess Garden Parkway that purported to have been completed on June 31, 2005, when in fact such feasibility study was done in September 2006; and (b) by providing a feasibility study for a lot located on Magnolia Avenue, Lanham, Maryland that purported to have been completed on 6 August 30, 2005, when in fact such feasibility study was done in September 2006. 18 U.S.C. § 1503(a) 18 U.S.C. § 2 7 FORFEITURE ALLEGATION 1. As a result of the offenses alleged in Counts One through Nine of this Indictment, the defendants, PATRICIA OMONDI, a/k/a Patricia Sanfo, a/k/a Patricia O’Mundy, and BOUREIMA SANFO, a/k/a Abraham Sanfo, a/k/a Ibraham Sanfo, shall forfeit to the United States all property, real and personal, involved in the offenses and all property traceable to such property, as to which property each defendant is jointly and severally liable, including but not limited to: a. $202,435.00 in United States currency and all interest and proceeds traceable thereto, in that such sum in aggregate is property which was involved in the aforementioned offenses or is property traceable to such property, in violation of Title 18, United States Code, Sections 2314 and 1957, and Title 21, United States Code, Section 853. 2. If any of the property described above in 2(a) in the preceding paragraph as being subject to forfeiture, as a result of any act or omission of any defendant - a. cannot be located upon the exercise of due diligence; b. has been transferred or sold to, or deposited with, a third person; c. has been placed beyond the jurisdiction of the Court; d. has been substantially diminished in value; or, e. has been commingled with other property which cannot be divided without difficulty; it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to seek 8 forfeiture of any other property of said defendant up to the value of the forfeitable property, that is, $202,435.00. 28 U.S.C. § 2461(c) 18 U.S.C. § 981(a)(1)(C) 21 U.S.C. § 853 ROD J. ROSENSTEIN UNITED STATES ATTORNEY A TRUE BILL: FOREPERSON DATE: April 25, 2007 9