IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA UNITED STATES OF AMERICA, : CRIMINAL NUMBER Plaintiff : VIO: 15 USC 1703(a)(2)(a) vs. 15 USC 1703(a)(2)(b) : 15 USC 1703(a)(2)(c) JACK HALPERIN 15 USC 1717 PHILIP COHEN, : 18 USC 1341 Defendants : 18 USC 2 I N D I C T M E N T THE GRAND JURY CHARGES: INTRODUCTION 1. At all times material and pertinent to this Indictment, High Vista, Inc. was a Pennsylvania corporation, having been incorporated on November 18, 1970, maintaining business offices at 9 West 57th Street, New York, New York and in Hazleton, Luzerne County, Pennsylvania. 2. At all times material and pertinent to this Indictment, High Vista, Inc. was a developer as then de- fined in Title 15 United States Code, Section 1701(4), and currenlly defined in Section 1701(5), and was engaged in and caused others to be engaged in the sale and offering for sale of lots in a 3,856-acre subdivision known as Valley of Lakes located in Schuylkill and Luzerne Counties in the Middle District of Pennsylvania. 3. At all times material and pertinent to this Indictment, the Valley of Lakes subdivision contained 4,717 proposed lots for sale, of which 1,345 lots were subdivided and offered for sale to prospective purchasers. _____________1 4. At all times material and pertinent to this Indictment, the Valley of Lakes was a subdivision as de- fined in Title 15 United States Code, Section 1701(3) in that it was comprised of land which was divided and pro- posed to be divided into 50 or more lots for tiie purpose of sale as a part of a common promotional plan. 5. At all times material and pertinent to this Indictment, Jack Halperin was the President, Chairman of the Board of Directors and stockholder of High Vista, Inc. and its related subsidiary corporation, to wit, American Urban Science Foundation, Inc., Oneida Water Company, Eagle Rock Ski & Golf Club, Inc., and Big Valley Utility Company; and at all times relevant hereto was directly responsible for the management of High Vista, Inc. and its affiliate corporations, including but not limited to; the formulation and implementation of a promotional plan for the sale of lots at the Valley of Lakes, the approval of sales liter- ature and methods used by salesman and other employees of High Vista, Inc.; obtaining financing for the subdivision; and obtaining approval of federal, state and local registr- ations which would permit High Vista, Inc. to subdivide, develop and sell the subdivision known as Valley of Lakes. 6. At all times material and pertinent to this indictment, and from on or about February 5, 1975 until on or about March 7, 1977, Philip Cohen was a Vice President and Director of High Vista, Inc. and a real estate broker licensed in the State of New York, acting as the broker of - 2 - record for the Valley of Lakes subdivision. During this period PHILIP COHEN was responsible for the management of said corporation, his duties including but not limited to, approval of sales literature and selling methods used by salesmen; filing of federal, state and local registrations and permits required by law to be filed by the subdivider in order to obtain approval to engage in sales within Valley of Lakes. 7. On or about August 4, 1969, American Urban Science Foundation, Inc. was incorporated in the State of Delaware for the purpose, among others, for providing pro- motional marketing for the sale of lots at Valley of Lakes. 8. On or about June 19, 1893, Oneida Water Company was incorporated in the Commonwealth of Pennsyl- vania for the purpose of providing a central water system for the public of the Township of East Union, County of Schuylkill and other adjacent communities. 9. On or about a date unknown, High Vista, Inc. purchased Oneida Water Company for the purpose of con- structing and maintaining central water facilities for the Valley of Lakes subdivision. 10. On or about May 29, 1973, Big Valley Utility Corporation was incorporated in the Commonwealth of Pennsyl- vania for the purpose of constructing and maintaining a central sewage system for the Valley of Lakes subdivision. 11. On or about October 20, 1972, Eagle Rock Ski & Golf Club, Inc. was incorporated in the Commonwealth of - 3 - Pennsylvania for the purpose of providing skiing and golf- ing facilities for the public and for lot owners in the Valley of Lakes subdivision. 12. On or about February 5, 1975, Jack Halperin entered into a memorandum of agreement with Philip Seltzer, Nathan Seltzer, and William Seltzer, known as the Seltzer organization, for the purchase of High Vista, Inc., and the Valley of Lakes subdivision. 13. On or about July 3, 1975, Jack Halperin en- tered into a formal stock purchase agreement with Louis Schiava, Philip Seltzer, Nathan Seltzer, and William Seltzer for the purchase of High Vista, Inc., American Urban Science Foundation, Inc., Oneida Water Company, Eagle Rock Ski & Golf Club, Inc. and Big Valley Utility Company. 14. At all times material and pertinent to this indictment, the office of Interstate Land Sales, United States Department of Housing and Urban Development was an agency of the United States of America and was responsible for, among other things, the registration and regulation of the sale and offering and advertising for sale by develop- ers of rural property located in subdivisions as fully described in the Interstate Land Sales full disclosure act of 1968, Title 15 United States Code, Section 1701, et seq. 15. At all times material and pertinent to this Indictment, the New York Department of State, Office of - 4 - Land Sales, was a duly authorized agency of the State of New York and was responsible for the registration and enforcement of land sales activities, including out of state developments advertising lots for sale to residents of the State of New York. 16. At all times material and pertinent to this Indictment, American Bank and Trust Company, Reading, Pennsylvania, was a duly authorized lending institution involved in all aspects of banking activities. 17. At all tims material and pertinent to this Indictment, the Hazleton National Bank, Hazleton, Pennsyl- vania, was a duly authorized lending institution involved in all aspects of banking activities. 18. At all times material and pertinent to this Indictment, the New Jersey Bank, West Patterson, New Jersey, was a duly authorized lending institution actively engaged in all aspects of the banking industry. 19. At all Limes material and pertinent to this Indictment, the First Valley Bank, Bethlehem, Pennsylvania, was a duly authorized lending institution, having been in- volved in all aspects of the banking industry. 20. At all times material and pertinent to this Indictment, the Perth Amboy National Bank of New Jersey was a duly authorized lending institution involved in all aspects of the banking industry. 21. At all times material and pertinent to this Indictment, the Unity Savings Association, Chicago, Illinois, was a duly authorized lending institution, involved in all aspects related to the conduct of business by savings assoc- - 5 - iations in the State of Illinois. 22. On or about February 10, 1976, JACK HALPERIN and PHILIP COHEN caused to be filed with the Office of Interstate Land Sales, United States Department of Housing and Urban Development, a series of amended property reports and financial statements purporting to contain all avail- able material facts and other pertinent information con- cerning High Vista, Inc. and the Valley of Lakes subdivision. 23. Commencing on or about September 10, 1975, JACK HALPERIN and PHILIP COHEN on behalf of High Vista, Inc. did file with the Office of Land Sales, New York Department of State, offering statements purporting to contain all available material facts and other pertinent information to accurately represent the construction schedule, maintenance of escrow accounts and the financial condition of High Vista, Inc. and the Valley of Lakes subdivision. 24. At all times material and pertinent to this Indictment, JACK HALPERIN and PHILIP COHEN caused High Vista, Inc. to distribute to lending institutions, and cer- tain prospective purchasers of property in the Valley of Lakes subdivision, Office of Land Sales, New York Department of State and United States Department of Housing and Urban Development, property reports and financial statements pur- porting to contain all current material facts and information and financial data to accurately represent the construction schedule of amenities, and maintenance of escrow accounts at Valley of Lakes and the financial condition of High Vista, Inc. - 6 - 25. At all times material and pertinent to this Indictment, Jack Halperin did obtain from various lending institutions loans that were purportedly to be used to provide funding to complete construction of exist- ing and proposed facilities and amenities in the Valley of Lakes subdivision. INTRODUCTION TO COUNTS I THROUGH XIII The allegations set forth in paragraphs 1 through 25 of the section of this Indictment entitled Introduction are incorporated herein by reference as though fully set forth within the below stated counts. On or about February 5, 1975, and continuing to on or about December 1, 1978, in Luzerne County, within the Middle District of Pennsylvania, and elsewhere within the jurisdiction of this Court, the Defendants: JACK HALPERIN and PHILIP COHEN acting as agents, officers and employees of High Vista, Inc. did knowingly and willfully make use of and did cause High Vista, Inc. to make use of the means and instruments of transportation and communications in interstate commerce and of the United States; and of the mails: a. To employ a device, scheme and artifice to defraud in selling and offering to sell lots in violation of Section 1703(a)(2)(A), Title 15 United States Code; and b. To obtain money and property by means of material misrepresentations with respect to information per- tinent to the lots and subdivision, upon which purchasers re- lied, in violation of Section 1703(a)(2)(B), Title 15 United States Code; and - 7 - c. To engage in a transaction, practice and course of business which operated as a fraud and deceit upon purchasers, in violation of Section 1703(a)(2)(C), Title 15 United States Code. (1) It was a further part of the device, scheme and artifice to defraud and the transaction, prac- tice and course of business operating as a fraud, that JACK HALPERIN and PHILIP COHEN offered to sell and caused High Vista, Inc. to offer to sell to prospective purchasers, lots in the Valley of Lakes subdivision and induced said purchasers of lots in said subdivision to purchase said lots by means of false and fraudulent representations and promises, which representations and promises the Defendants knew were false and fraudulent, at the time they were made. (2) it was a further part of the device, scheme and artifice to defraud and the transaction, prac- tice and course of business operating as a fraud, that JACK HALPERIN and PHILIP COHEN made untrue statements of material facts and omitted to state material facts required to be stated in property reports and amended property re- ports filed with the United States Department of Housing and Urban Development and property reports filed with the New York Department of State, Office of Land Sales, for the Valley of Lakes subdivision and provided to prospective pur- chasers of lots at the Valley of Lakes subdivision, to wit: (a) That all deposits and payments made with respect to the purchased lots in the Valley of Lakes subdivision were placed - 8 - in escrow accounts and remained under the control of the Pennsylvania real estate broker of record until the deed was recorded and that the deed would be delivered to the purchaser after it was recorded, when in truth and in fact not all the deposits and paymnts made by prospective purchasers were placed in escrow and under the control of the Pennsylvania broker of record; (b) That Lake Algonquin, a proposed 80-acre lake, complete with dams, would be completed no later than January 1, 1980, when in truth and in fact, no said lake or dams have been completed. (c) That completion of said proposed Lake Algonquin was assured by construction contract entered into between the developer and Central Penn Industries, Inc., Hazleton, Pennsylvania, when in truth and in fact, there was no such construction contract in existence at the time of said representation; (d) That a nine-hole golf course and/or eighteen-hole golf course, complete with all fairways and greens, would be completed on or before December 31, 1978, when in truth and in fact, said golf course, fairways and greens has not been completed. - 9 - (e) That central sewer service with central Sewage disposal plant, lift station, treatment plant, and pumps and sewer lines would be extended by the developer to all lots located in Sections A, B, C, CW, D, H, 1, IC, J, JA, JB, of the Valley of Lakes subdivision, by January 1, 1978, when in truth and in fact, said central sewer ser- vice system was partially complete and not extended to the above referenced section lots. (f) That central water facilities with all necessary wells, tanks, pumps, and water lines would be installed by the developer by January 1, 1978, to supply all lots located in Sections A, B, C, CW, D, H, 1, IC, J, JA, and JB, of the Valley of Lakes subdivision, with adequate water, when in truth and in fact, only a portion of said water system has been installed to the above referenced sections; (g) That all roads and cul-de-sacs providing access and use of the lots located in Sections A, B, C, CW, D, H, I, IC, J, JA, and JB of the Valley of Lakes subdivision, would be paved by January 1, 1978, to service all of the lots located in the subdivision, when in truth and in fact, roads and cul-de- sacs have not been paved to date; - 10 - (h) That all completed and existing amenities would be maintained by the devel- oper; when in truth and in fact, the amen- ities have deteriorated as a result of the developers' failure to maintain them. (i) That all monies paid by property owners for general maintenance of the roads, lakes, and other amenities in Valley of Lakes would be used for the general maintenance of the amenities, when in truth and in fact, JACK HALPERIN and PHILIP COHEN, diverted said funds for other purposes; (j) That a special escrow account, meeting the requirements of the Department of State, Office of Land Sales of the State of New York be maintained to insure completion of the proposed and incomplete amenities, to wit: Lake Algonquin, golf course, central water system, central sewage system; paving of roads and cul-de-sacs; and that $2,500.00 from each lot sold in the Valley of Lakes subdivision would be deposited in escrow with Hazleton National Bank, Escrow Agent, to insure completion of the aforesaid amenities, when in truth and in fact the aforesaid escrow account was not properly maintained by the developer and $2,500.00 from all lot sales in - 11 - the subdivision were not deposited in escrow with the escrow agent. (3) It was a further part of the device, scheme and artifice to defraud that JACK HALPERIN and PHILIP COHEN knowingly and willfully caused to be furnished to prospective lot purchasers United States Department of Housing and Urban Development property reports that were not current and in effect, in order to induce the said lot purchasers to buy lots within the Valley of Lakes subdivision. COUNTS I THROUGH XIII The allegations set forth in paragraphs 1 through 25 of the section of this Indictment entitled Introduction and the allegations contained in the introduction to Counts I through XIII inclusive are incorporated herein by ref- erence as though fully set forth within these Counts. On or about the dates set forth in the Counts below at Luzerne County, Pennsylvania, within the Middle Dis- trict of Pennsylvania, and within the jurisdiction of this Court, JACK HALPERIN and PHILIP COHEN did knowingly and willfully sell the lots set forth in the Counts below to the persons identified in each Count and did employ the device, scheme and artifice to defraud as heretofore alleged and did obtain money and property by means of said material misrepresentations with respect to information pertinent to such lot and subdivision upon which the persons named in the Counts below relied, and did further engage in the transaction, practice and course of business which operated and would operate as a fraud and deceit upon - 12 - the persons named in the Counts below; and in furtherance thereof, did make use of means and instruments of transpor- tation and communication in interstate commerce, and of the United States mails. COUNT DATE LOT NUMBER NAME I May 24, 1976 JA-25 Douglas B. Levy II August 31, 1975 D-109 John MasLropietro III December 21, 1975 JA-205 Nicholas Cartabona IV August 24, 1975 D-120 Eustachio Locantore V August 24, 1975 CW-73 Ralph TrombetLa VI September 1, 1976 A-11 Edmund J. Succa VII January 11, 1976 J-64 Charles Kilby VIII December 6. 1975 JA-202 George Frick, III IX July 14, 1976 JA-192 Liz Mammone X May 29, 1976 JA-244 Joseph F. Natale XI October 12, 1975 JA-144 Charles Barrall XII September 14, 1975 D-132 Michael Neglia XIII June 30, 1976 JA-243 Louis Taffetani In violation of 15 United States Code, Section 1703(a)(2)(A)(B)(C), 15 United States Code, Section 1717 and 18 United States Code, Section 2. INTRODUCTION TO COUNTS XIV THROUGH XXXIII 1. The allegations set forth in paragraphsl through 25 of the Indictment entitled Introduction are incorporated herein by reference as though fully set forth within each of the immediately following counts. - 13 - 2. Commencing on or about February 5, 1975, and continuing through the present, the Defendants, JACK HALPERIN and PHILIP COHEN did knowingly and willfully de- vise a scheme and artifice to defraud lot owners and pro- spective lot owners, state and federal regulatory agencies, and lending institutions, in a development identified as Valley of Lakes through false and fraudulent pretenses, representations and promises. The false and fraudulent pretenses, representations and promises contained in Counts I through XIII on pages 7 through 13 of this Indictment are incorporated herein by reference as though fully set forth herein. 3. Commncing on or about February 5, 1975, and continuing until on or about December of 1978, JACK HALPERIN and PHILIP COHEN did make representations to lot owners, prospective lot owners, and lending institutions, as hereinafter stated, that proceeds from lot sales, loans, and financing obtained by High Vista, Inc., would be util- ized for the completion of existing and proposed amenities in the Valley of Lakes; when in truth and in fact, the said JACK HALPERIN and PHILIP COHEN, knew that said rep- resentations were false and fraudulent when made. 4. It was a further part of the scheme and artifice to defraud that an or about June 3, 1975, the Defendants, JACK HALPERIN and PHILIP COHEN, borrowed from the Amerrican Bank and Trust Company, Reading, Pennsylvania, $500,000.00 to be used for completion of all amenities, working capital and the improvement of the Valley of Lakes development, when in truth and in fact only a portion of said funds were used for those purposes. - 14 - 5. It was a further part of the scheme and arti- fice to defraud that on or about October 1, 1975, the Defend- ants, JACK HALPERIN and PHILIP COHEN, borrowed from the Hazleton National Bank the sum of $820,000.00 for the purpose of completing all amenities, working capital and the improve- ment of the Valley of Lakes subdivision, when in truth and in fact, only a portion of said funds were used for those purposes. 6. It was a further part of the scheme and arti- fice to defraud that on or about September 10, 1975, the Defendants, JACK HALPERIN and PHILIP COHIN, caused to be filed with the New York Department of State, Office of Land Sales Registration, offering statements containing mislead- ing and untrue statements of material facts as heretofore alleged in Counts I through XIII of this indictment, the purpose of said filing was to obtain permission from the New York Department of State to advertise within the State of New York lots situate in the Valley of Lakes subdivision. 7. It was a further part of the scheme and arti- fice to defraud that on or about September 30, 1975, the Defendants, JACK HALPERIN and PHILIP COHEN, entered into an escrow agreement with the Hazleton National Bank wherein $2,500.00 from each lot sold would be deposited to provide funds for the completion of all of the heretofore mentioned amenities in the Valley of Lakes subdivision, knowing that said escrow agreement would not be properly maintained and that funds to be deposited in said escrow account from lot sales would not be deposited, said funds being diverted for purposes other than completion of amenities. - 15 - 8. It was further a part of the scheme and arti- fice to defraud that on or about October 20, 1975, the Defendants, JACK HALPERIN and PHILIP COHEN caused to be borrowed from the American Bank and Trust Company, Reading, Pennsylvania, $400,000.00 for the purpose of using a por- tion of these funds to construct all of the amenities, work- ing capital and for the general improvement of the Valley of Lakes subdivision, when in truth and in fact, only a portion of said funds were used for those purposes. 9. It was further part of the scheme and artifice to defraud that on or about January 15, 1976, March 15, 1976, and April 15, 1976, Defendant JACK HALPERIN caused High Vista, Inc. to issue notes to American Bank and Trust Company for funds disbursed for loans and checks issued by American Bank and Trust Company totalling $670,000.00. 10. It was further part of the scheme and artifice to defraud that on or about September 8, 1976, Defendant JACK HALPERIN caused Hazleton National Bank to issue a note to him in the amount of $102,358.00 to acknowledge a debt in that amount which resulted from the issuance of checks drawn on the High Vista, Inc. checking accounts wherein no funds were available to cover said checks. 11. It was further part of the scheme and artifice to defraud that on or about May 24, 1977, Defendant JACK HALPERIN caused Hazleton National Bank to loan $60,000.00 to High Vista, Inc. for the purpose of providing working capital and for completing amenities and recreational facil- - 16 - ities within Valley of Lakes, when in truth and in fact only a portion of said funds was used for those purposes. 12. It was a further part of the scheme and artifice to defraud that on or about October 24, 1977, November 17, 1977, December 14, 1977, and February 15, 1978, Defendant JACK HALPERIN falsely and fraudulently in- duced Unity Savings Association, Chicago, Illinois, to disburse loans totalling $2,600,000.00 to American Urban Science Foundation, for the purpose of using a portion of these funds to complete the heretofore mentioned amenities of the Valley of Lakes subdivision, when the said JACK HALPERIN knew that the funds would not be applied for that purpose. 13. It was a further part of the scheme and artifice to defraud that the Defendants, JACK HALPERIN and PHILIP COHEN,, caused property reports that were not current or in effect at the time to be issued to pur- chasers of the lots in Valley of Lakes development. Said property reports contained untrue and misleading state- ments concerning the completion schedules of proposed amenities and failed to state material facts and pertinent information concerning the current financial status of High Vista, Inc. and its affiliate corporations. 14. It was a further part of the scheme and artifice to defraud that on or about June 21, 1977, August 5, 1975, June 23, 1976, and in the Fall of 1977, the Defendants JACK HALPERIN and PHILIP COHEN caused to be - 17 - mailed lulling letters to purchasers containing material misrepresentations as to the financial status and ongoing construction schedule for the completion of proposed amen- ities. Said letters designed to induce lot purchasers to continue to make payments for the purchase of their lot, to purchase further lots and to refrain from seeking legal redress. 15. It was a further part of the scheme and artifice to defraud that Defendants,JACK HALPERIN and PHILIP COHEN, induced lot owners to mail down payment and monthly financing payment checks to High Vista, Inc., in Hazleton, Pennsylvania. 16. It was a further part of the scheme and artifice to defraud that the Defendant, JACK HALPERIN, caused to be filed with the Office of Land Sales Registration, United States Department of Housing and Urban Development, amended property reports for the years 1977 and 1978, in order to induce the heretofore stated banking and lending institutions to make additional loans to High Vista, Inc. for the completion of the amenities within the subdivision and initiate the implementation of further lot sales, when in truth and in fact, no lots were sold in the subdivision after October, 1976, when the Defendant knew that completion of the amenities would not be financially feasible or prob- able in the Valley of Lakes subdivision. - 18 - COUNT XIV All the allegations contained in paragraphs 1 through 16 of the Introduction to Counts XIV through XXXIII are realleged and incorporated herein by reference as though each allegation was set forth herein at length. On or about November 2,, 1975, the Defendants, JACK HALPERIN and PHILIP COHEN willfully and knowingly and for the purpose of executing the aforesaid scheme and artifice to defraud, and attempted to do so, did cause to be delivered by mail according to the direction thereon a letter addressed to High Vista, Inc., P.O. Box 577, Hazleton, Penna. 18201, from David W. Schneck, 2203 Turk Road, Doylestown, Penna. 18901, con- taining his check number 36, dated November 2. 1975, in the amount of $133.04, payable to High Vista,, Inc. In violation of Title 18 United States Code, Section 1341, and 18 United States Code, Section 2. COUNTS XV THROUGH XXXIII The allegations contained in paragraphs I through 16 of the introduction to Counts XIV through XXXIII are realleged and incorporated herein by reference as though each allegation was set forth herein at length. On or about the dates set forth in the Counts below at Hazleton, Pennsylvania, within the Middle District of Pennsylvania, within the jurisdiction of this Court, JACK HALPI&RIN and PHILIP COHEN having devised a scheme and - 19 - artifice to defraud and to obtain money and property by means of false and fraudulent pretenses representations and promises and for the purpose of executing such scheme and artifice and attempting to do so, caused the in- dividuals identified by the Count below to place into a post office,an authorized depository for mail matter, a letter and matter addressed to the addressees given to be sent and delivered by the United States Postal Service according to the direction thereon in the Middle District of Pemsylvania. - 20 - COUNT DATE SENDER ADDRESSEE DOCUMENT AMOUNT XV October 14, 1975 John Mastropietro High Vista, Inc. Check $123.82 XVI November 15, 1975 John Mastropietro High Vista, Inc. Check $123.82 XVII February 7, 1976 Nicholas J. Cartabona High Vista, Inc. Money $350.00 Order XVIII March 1, 1976 Nicholas J. Cartabona High Vista, Inc. Money $350.00 Order XIX October 10, 1975 Eustachio Locantore High Vista, Inc. Check $131.73 XX November 5, 1975 Eustachio Locantore High Vista, Inc. Check $131.73 XXI October 13, 1975 Ralph Trombetta High Vista, Inc. Check $131.73 XXII November 10, 1975 Alex Pacyna High Vista, Inc. Check $170.25 XXIII August 2, 1975 Robert Eberhardt High Vista, Inc. Check $117.24 XXIV February 20, 1976 Francis Kelly High Vista, Inc. Check $138.31 XXV October 14, 1975 John T. Klajn High Vista, Inc. Check $123.82 XXVI August 5, 1975 Joseph Luciana High Vista, Inc. Check $148.99 XXVII November 23, 1975 Tony Rouse High Vista, Inc. Check $590.00 XXVIII April 21, 1976 Joseph Pirraglia High Vista, Inc. Check $1,090.00 XXIX July 15, 1976 Liz Mammone High Vista, Inc. Check $3,900.00 XXX June 1, 1976 Joseph Natale High Vista, Inc. Check $790.00 XXXI May 17, 1976 Salvatore Barbera High Vista, Inc. Check $900.00 XXXII October 20, 1975 Michael Neglia High Vista, Inc. Check $ 88.26 XXXIII January 24, 1976 Margaret Black High Vista, Inc. Check $500.00 - 21 - PLEAS NOW, this 4th day of August, 1980, the within named defendant, JACK HALPERIN, having been arraigned in open Court, hereby pleads Not guilty to the within Indictment. /s/ All in violation of 18 United States Code, Section 1341 and 18 United States Code, Section 2. A TRUE BILL /s/ FOREMAN 7/25/80 Date /s/ CARLON M. O'MALLEY, JR. United States Attorney - 22 -
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