DOJ-OGR-00031526.pdf

--- Page 1 --- **BANK FRAUD** **COUNT II** 12. Paragraphs 1-9 are realleged and incorporated by reference herein. 13. On or about May 7, 1999, in Palm Beach County, in the Southern District of Florida, the defendant knowingly, willfully and with intent to defraud executed a scheme to obtain monies from a financial institution under false and fraudulent pretenses, that is, to obtain a loan from Bank of America in Fairfax, Virginia. In order to execute this scheme the defendant caused Bank of America to fund a mortgage loan to Jose M. Abejon, under false and fraudulent pretenses, that is, a fictitious lease was submitted with the loan application, which fictitious lease was intended to cause the lender to believe that the applicant had more assets than was otherwise true, all in violation of Title 18, United States Code, Section 1344 and 2. **COUNT III** 13. Paragraphs 1-9 are realleged and incorporated by reference herein. 15. On or about March 31, 1999, in Palm Beach County, in the Southern District of Florida, the defendant knowingly, willfully and with intent to defraud executed a scheme **Page 5** **Public Records Request No. 17-295** **07/26/17**