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USA v. Staley Case No. 4:14-cr-00153
Below is an excerpt of the indictment From (USA v. Staley Case No. 4:14-cr-00153):
B. SCHEME TO DEFRAUD
3. From at least approximately February 2008 through March 2010, in the Eastern District of Missouri, the defendant JAMES STALEY, knowingly devised and intended to devise a scheme and artifice to defraud and to obtain money from investors through the United States by means of false and fraudulent pretenses, representations, and promises, to wit: the defendant knowingly made material false and fraudulent representations and promises to prospective investors/lenders to lure them into investing with B&B’s Premium Financing Company, and in connection therewith, caused the use of interstate wires.
4. As a result of the aforesaid scheme and artifice to defraud, defendant JAMES STALEY defrauded approximately eleven investors/lenders by causing them to invest in over $3.4 million with B&B Premium Financing Company resulting in JAMES STALEY receiving commissions totaling over $570,000.
C. WAYS AND MEANS
5. B&B Premium Financing Company required the lender/investor to invest in the insurance policy for a fixed period of time. This fixed period of time varied from 18 months to 2 years. During this period of time, JAMES STALEY represented to clients of Wealth Financial International that B&B Premium Financing Company would sell the bundled insurance policies on the open market with guaranteed returns. However, in truth and fact, JAMES STALEY well knew that the lender/investor rate of return was based upon the selling of the policies on the open market.
JAMES STALEY was well aware that if B&B Premium Financing Company was unable to secure a buyer for the bundled insurance policies that his clients would lose all their monies invested in the Premium Financing product sold by B&B.
6. In order to induce potential lender/investors to invest in B&B’s premium Financing Company, defendant JAMES STALEY made a number of materially false and fraudulent statements, representations, and promises as more fully set forth below, including, but not limited to:
a. That the investment was safe, secure, and risk free:
b. That the lender/investors were guaranteed a high rate of return;
c. That Staley was well informed about the safety of the investment as well as facts being represented to investors;
d. That Staley was personally invested in the Premium Financing product sold by B&B;
e. That Staley’s family members were invested in the Premium Financing products sold by B&B.
f. That B&B Premium Financing Company had numerous potential buyers that were “lining up to purchase the product”;
g. That Warren Buffet and Time Warner were investing in similar products as the Premium Financing product sold by B&B.
7. During some part of the scheme but no later than the summer of 2009, JAMES STALEY became aware of the fact that B&B Premium Financing Company did not have buyers for the bundled insurance policies. JAMES STALEY was well aware that without buyers, the investors/lenders/ would lose all the money they contributed to the financing of the bundled insurance policies. However, JAMES STALEY continued to lure investors/ lenders into contributing funds for the purchase of these policies and continued to receive commissions for each investor/lender that provided funds.