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DEPARTMENT OF THE TREASURY Request for Transfer of Property SeizedlForfeited by a Treasury Agency
(For Use By Domestic Lo:w Enforcemmt Agencies Only)
MIllersville MD 21108
CoDtact PersoD: Lt.~. &xw1 Ca!pt:roller's Cftice Telepbone N....ber: (410) 222-8656
m. AMd~~'__~~~_~~~~-_________________
Property Description:
S ~()~y PA/2)te:'/<.. t>/Vve A.N.f1h')~.s ~Z>
v. Contribution (If any answer to A ibru E is yes, provide details in Part VI) Yes No
Page 2
VI. Additional space for detailed answers (Indicate Part to which flIf.nre,(s) tzpply)
The Anne Arundel County Police Department is a participating member of the Immigration 8..-r1d Cust..oms
Enforcement (ICE) 'Document Benefit Fraud Task Force'. The Anne Arundel County Police Department has one
fuU-time investigator (TFO: Mendoza # 1358) assigned to this Task Force Group. Based on the resUlts of a recent
investigation, the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the seimre.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
infonnation that Annapolis Painting Services, located in Annapolis, MD, was employing undocumented workers.
The information suggested that the owner of the company pays these workers by check:, deducts 1/3 of their gross
pay~ and tells the undorumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays the undocumented
workers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Services, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wife, Rebecca Bontempo, are
laundering proceeds from the employment on undocumented workers through the business account to pay various
assets, to include real estate, vehicles and investment accounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to facilitate the ittegal activity.
DNo
va Cer1iftcadon8:
A. The reqaester certif"aes that the above iaformatioo is true and accurate, that tbe property transferred will be used for
die law eaforcaaent ptII'pOIe stated. and dIat aU IIIGIIfa lue"ed po........ to tIds ft'48eIt trill be depe:Itted ud
@ III' OS
Signature I TiJJe DIII.e
&Ie
Address: _ _ _ _ _ _-Al_~AR-
_ _ _ _ _O~fAC_[ OF ~AW
Telephone Number: (410) 2660 KIVA ROAD. 4111 FLOOR
2008PVVOOOOO2801
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18, 2008, TFO Mendoza assisted in serving subpoenas to BGE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at multiples
locations in Annapolis to include the main business and the owner's residence. On February 4, 2008, TFO Mendoza
conducted nume.rOllS hours of undercover su.-..eiUance and conducted a trathc stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 200S to June 2S, 200S, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted numerous bo~ of
undercover surveillance on Suspect: Roberto Bontempo~s residence, and business and other residences owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search warrant executions scheduled for June 30, 200S. ICE
Agents subsequent1y obtained Federal Search and Seizure Warrants for the following locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
['he Anne Arundel County Police Department also provided fifty (50) police officers and detectives to assist with the
ocecution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
,rrestees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 houses and 11 vehicles.
Date: 07 108 I 2008
Treasury Agency: _ICE
_ _ _ _ __
Case Number: BA02POO7BAOO14
DEPARTMENT OF THE TREASURY Request for Transfer of Property SeizedlForfeited by a TreaRlry Agency
(For Use By Domestic Lew Enforcement AgencIes Only)
I.
FP&F Number: 2008130300011801 • AD .us:ets tnmsferred IIIIW be used for tlae law euforc-.ematt
purpose stated ill the ~
Seizure Number: 2008SZ00674990J
Seizure Date: 6 / 30 /2008 • ))radfine for lUbmiJlion of this reque:R iJ Ibty (60) day.
feIIewiD& the 1Idzure.
SAIC Office: Baltimore
--~~------------
• The ~ag ape)' will be respoasibIe for rdmboJ'1ling _
Case Type: AdoptioIL-. Joint---X-
the 1'reaJary Ageaq its COlts and lila,
be retpOOJible for
Discontiauance - rUnbuniDI the Traatry ~ tbaft.
(rhukOnt'!)
Millersville MD 21108
Contact Penon:Lt. ~/W. Jra.n Qnptroller's Cffice Telephone Number: (410) 222-8656
ro F 92-22.46 07/93 23
DEPARTMENT OF THE TREASURY Seizure Number. 2OOSS7.A)O()74990 I
Page 2
The Anne Arundel County Police Department is a participatil'.g member of the Immignuion and Customs
Enforcement (ICE) <Document Benefrt Fraud Task Force' . The Anne Arundel County Police Department has one
full-time investigator (TFO: Mendoza # 1358) assigned to this Task Force Group. Based on the results of a recent
investigation, the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the seizure ofSl,43 1.51 in US. Currency.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
information that Annapolis Painting Services, located in Annapolis. MD, was employing undocumented workers.
The infonnation suggested that the owner oftbe company pays these workers by check, deducts 113 of their gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays the undoaJmeoted
workers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo. owner of the Annapolis Painting Services, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wife, Rebea;a Bontempo, are
laundering proceeds from the employment on undocumented workers through the business account to pay various
assets, to include rea! estate, vehicles and investment accounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to facilitate the illegal activity.
ONo
vn. CertificatioDs:
A. TIae rq..... cadfies . . . die -.we iIIfenn.adaa a .... ad IIttIInfe, daattlle pnrpaty ~ wit be . . . for
the law enlorcemeat parpose stated, and daat aD IbOIIies receiYed punuant to dais reqam wiD be deposited ad
Sf
B. As legal couueI, I have reviewed dais Reqoat 4~ of Preperty S e. i z e d I FOrfeited by a Treuary Ageacy aDd I
ca1if'y that dae COBtact penonldeatified in p~')t;... the authority Co aa:ept Jeizedlfo~ pnperty aad is the -
ofIidaJ Co wIIom traBlfer dom-- ab aadllir IIIOBey IIIoIdd be deltoN. (LI.pl COIIII8I!l cedijictItioII U lUll ~for
,.-",,,,,,,P'" IIlW ~)
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January IS, 2008, TFO Mendoza assisted in serving subpoenas to BGE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveilJance at multiples
locations in Annapolis to include the main business and the owner's residence. On February 4; 2008, TFO Mendoza
conducted numerous hours of undercover surveillance and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008) TFO Mendoza conducted numerous hours of undercover swveiJIance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted numerous hours of
undercover surveillance on Suspect: Roberto Bontempo's residence, and business and other residences owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search warrant executions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
fhe Anne Arundel County Police Department also provided fifty (50) police officers and detectives to assist with the
",ecution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
lITestees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 houses and II vehicles.
Date: 07 /08/ 2008
Treasury Agency: ICE
-------
Case Number: BA02POO7BAOO14
DEPARTMENT OF THE TREASURY Request for Transfer of Property SeizedlForfeited by a Treasury Agency
(For Use By Domestic Law Enforcement Agencies Only)
Millersville MD 21108
m. Aud~.~.____~~~~c~e~~~~~£.~w~cwY~____________
Property Daeripdoa:
s /~. r79. &77
v. Contribution (If any answer to A thm E ii yes, provide details in Part VI) Yes No
A. Did your agency originate the information leading to the seizure? o
B. Were any other assets seized under state law? o
C. Were extraordinary expenses incurred? o
D. Did your agency supply any unique or indispensable assistance? o
E. Are there any assets located in foreign countries associated witb this case? o
F. How many bours were expended? 4SO Hours ~
D F 92-22.46 07193 23
DEPARTMENT OF mE TREASURY Seizure Number: 2008SZ007008001
Page 2
VL AdditionaJ Ipatt for detailed answenJ (Indicute Part to wltidt answer(s) apply)
The Anne Arundel County Police Department is a participating member of the IIp-migration and Customs
Enforcemeni (iCE) ·Document Benefit Fraud Task Force'. The Anne Arundel County Police Department has one
fulJ-time investigator ([FO: Mendoza # 1358) assigned to this Task Force Group. Based on the results of a recent
investigation, the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the seizure of Sl 9,979.07 in U.S. Currency.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
information that Annapolis Painting Services, located in Annapolis, MD, was employing undocumented workers.
The infonnation suggested that the owner of the company pays these workers by check, deducts II3 of their gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays the undocumented
workers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Services, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wife, Rebecca Bontempo, are
laundering proceeds from the employment on undocumented workers through the business account to pay various
assets, to include real estate, vehicles and investment accounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to facilitate the illegal activity.
(If more space is reqllired, lISe II $II!JXII'fIIe sIu!.et ofpaper and aJtach.) Attacbmeat: ONo
VIL Certificatioo.s:
A The requester certifies that the above iDformaDon is true ad amante, fltat the property Cranlferred will be tued for
the law enforcement purpose stated, ad that aD IDOIIies received punaaat to tbis request wID be depoIited ad
attOIUIted for CODJiJteDt witII applkable Federal, State, aDd local"",
reguIatioaJ aad 0""'"
TIle reqvester agrees to
report on the adPaI UJe of eqaitably trauferred property upGD request. TIle requesta" aadentaDds that if it is IlUbIe
to pay the aecessary fees .... apeases at the time of traDsfer, the utet will be sold aDd tile maDmam pen:eat of Bet
lale proceedJ wiD be awarded in lieu of the auet.
Siguture I Tttle
B. As IepI """'.... I hare . . . . - tIIis Request f.l~PrupeI'ty SdzedII10rfdted I>y • Treotury Aaeary ..... I
certify that tbecontad penon ldeotified In pari~ tile authority to accept lleizedlforfeited property ad is the .
official to whom tnwfer documents and/or money mould be delivered. (Leglll colUfSl!l certijieotUm i& not ,et[uiredfor
Fed6aJ 1Igt!IICies)
Address:
----+fl~++_H~~~--------~.
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18, 2008, TFO Mendoza assisted in serving subpoenas to BGE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at multiples
locations in Annapolis to include the main business and the owner's residence. On February 4, 2008, TFO Mendoza
conducted numerous hours of undercover surveiHance and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted numerous hours of
undercover surveillance on Suspect: Roberto Bontempo's residence, and business and other residences owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search warrant executions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
he Anne Arundel County Police Department also provided fifty (50) police officers and detectives to assist with the
I(ecution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
Testees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 houses and II vehicles.
Date: 07 108 I 2008
Treasury Agency: ICE
-------
Case Number: BA02P007BA0014
DEPARTMENT OF THE TREASURY Request for Transfer of Property Seized/Forfeited by a Treasury Agency
(For Use By Domestic Law Enforcement Agencies Only)
For Treasury Agency Use Only (Fu!" .4ddi!iona! !n/ormatiu;; - See In:'Jiruc:tionsj.
I.
FP&F Number: 2008130390001301 • All assets transferred must be used for the law enforcement
purpose stated in the request.
Seizure Number: 2008PW000003301
Seizure Date: 6 / 30 /2008 • Deadline for submission of this request is sixty (60) days
following the seizure.
SAle Office: Baltimore
---------------------- • The requesting agency will be responsible for reimbursing
Case Type: Adoptioll- Joint---X...
the Treasury Agency its costs and may be responsible for
Discontinuance - - reimbursing the Treasury Agency share.
(rhprk Onp)
•
II. Requesting Agency Name: Anne Arundel County Police Department
Millersville MD 21108
Contact Person:Lt. If.dge/W. J:ra..n 0:nptr011er:'s Office Telepbone Number: (410) 222-8656
Contribution (If any answer to A thru E is yes, provide details in Part VI) Yes No
Page 2
VI. Additional space for detailed answers (Indicate Part to which answer(j) apply)
The Anne Arundel County Police Department is a participating member of the Immigration and Customs
Enforcement (ICE) 'Document Benefit Fraud Task Force' . The Anne Arundel County Police Department has one
full-time investigator (TFO : Mendoza # 1358) assigned to this Task Force Group. Based on the results of a recent
investigation, the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the seizure.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
information that Annapolis Painting Services, located in Annapolis, MD, was employing undocumented workers.
The information suggested that the owner of the company pays these workers by check, deducts 113 of their gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays the undocumented
workers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Services, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wife, Rebecca Bontempo, are
laundering proceeds from the employment on undocumented workers through the business account to pay various
assets, to include real estate, vehicles and investment accounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to facilitate the illegal activity.
(I/more space is required, use a separate sheet o/paper and attach.) Attachment: ~Yes DNo
VII. Certifications:
A. The requester certifies that the above information is true and accurate, that the property transferred will be used for
the law enforcement purpose stated, and that all monies received pursuant to this request will be deposited and
accounted for consistent with applicable Federal, State, and local law, regulations and orders. The requester agrees to
report on the actual use of equitably transferred property upon request. The requester understands that if it is unable
to pay the necessary fees and expenses at the time of transfer, the asset will be sold and the maximum percent of net
sale proceeds will be awarded In lieu of the asset.
~~~~~__~~(~~ri~/~_O(_
Add",", U DateANN£ ARIRI1.
-------ROff~C : V. . ,Y
Telephone Number: (4]0) 26SCiiiVA ROAD, 4D1 fLOOR
------------------------~2~4~~~~~~~~RU~
2008PVV000003301
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18,2008, TFO Mendoza assisted in serving subpoenas to BGE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at IIluliiples
locations in Annapolis to include the main business and the owner's residence. On February 4,2008, TFO Mendoza
conducted numerous hours of undercover surveillance and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted numerous hours of
undercover surveillance on Suspect: Roberto Bontempo's residence, and business and other residences owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search warrant executions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
'"
Annapolis Painting Services - 2561 Housley Road, Annapolis, MD 2140 I
'"
1007 Carrs Road Annapolis, MD 21403
'"31 Arbor Hill Road, Annapolis, MD 21403
'"7 Arbor Hill Road, Annapolis, MD 21403
'"2044 Parker Drive, Annapolis, MD 2140 I
* 402 Harbor Drive, Annapolis, MD 21403
'" 3 Rosecrest Drive, Annapolis, MD 21403
'" 10 16 Bay Ridge Drive, Annapolis, MD 21403
* 34 Pleasant Street, Annapolis, MD 21403
* 30 Pleasant Street, Annapolis, MD 21403
'" 25 Bancroft Avenue, Annapolis, MD 21403
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
The Anne Arundel County Police Department also provided fifty (50) police officers and detectives to assist with the
execution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
arrestees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of IS houses and 11 vehicles.
Date: 07 /08 / 2008
Treasury Agency: ICE
-------
Case Number: BA02P007BAOOl4
DEPARTMENT OF THE TREASURY Request for Transfer of Property SeizedfForfeited by a Treasu ry Agency
(For Use By Domestic Law Enforcement Agencies Only)
Millersville MD 21108
Office
Contact Person: ht. -:Hodge/W. Brown Canptroller' Welephone Number: (410) 222-8656
v. Contribution (If any answer to A thru E is yes, provide details in Part VI) Yes No
Page 2
VI. Additional space for detailed answers (Indicate Part 10 which answer(s) apply)
The Anne Arundel County Police Department is a participating member of the Immi gration and Customs
Enforcemem (iCE) 'Document Benefit Fraud Task Force' . The Anne Arundel County Police Department has one
full-time investigator (TFO: Mendoza # 1358) assigned to this Task Force Group. Based on the results of a recent
investigation, the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the seizure.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
infonnation that Annapolis Painting Services, located in Annapolis, MD, was employing undocumented workers.
The infonnation suggested that the owner of the company pays these workers by check, deducts 1/3 of their gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays the undocumented
workers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Services, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wife, Rebecca Bontempo, are
laundering proceeds from the employment on undocumented workers through the business account to pay various
assets, to include real estate, vehicles and investment accounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to facilitate the illegal activity.
(lfmore space is required, use a separate sheet o/paper and attach.) Attachment: r¢..ves ONo
VII. Certifications:
A. The requester certifies that the above information is true and accurate, that the property transferred will be used for
the law enforcement purpose stated, and that all monies received pursuant to this request will be deposited and
accounted for consistent with applicable Federal, State, and local law, regulations and orders. The requester agrees to
report on the actual use of equitably transferred property upon request. The requester understands that if it is unable
to pay the necessary fees and expenses at the time of transfer, the asset will be' sold and the maximum percent of net
sale proceeds will be awarded in lieu of the asset.
15'
B. As legal counsel, I have reviewed this Request fo~ran'f: of Property SeizedlForfeited by a Treasury Agency and I
certify that the contact person identified in Part has the authority to accept seized/forfeited property and is the _
official to whom transfer documents and/or. mo ey should be delivered. (Legal counsel certification is not required for
f', ralla rcement agencies)
, (0, A-UJI~~-=-r.4-=-/t-4-Lih_b_'/
U Date
Address:
------------------------------~-
'ANNE ARONOR COIIIIT
OfRCr V 'i ' ~~ :M
)------=-:2660 R~~iA ROAD, 4111 R8
TelePhon--eN-um-be-r:-(41-0
24
2008PVV000003201
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18,2008, TFO Mendoza assisted in serving subpoenas to BGE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at Iflultipies
locations in Annapolis to include the main business and the owner's residence. On February 4, 2008, TFO Mendoza
conducted numerous hours of undercover surveillance and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted numerous hours of
undercover surveillance on Suspect: Roberto Bontempo's residence, and business and other residences owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detaiJed
operational information pertaining to the anticipated search warrant executions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
'he Anne Arundel County Police Department also provided fifty (50) police officers and detectives to assist with the
~ecution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
Testees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 houses and 11 vehicles.
(Attachment VI.)
Date: 07 /08 / 20()S
Trea.wry Agency: ICE
--------
Case Number: BA02POO7BAOO14
DEPARTMENT OJ.' THE ]'REASURY Request for Transfer of Property SeizedfForfcited by a Treasm-y Agency
(POT 1l~ Ill' f)mnf1!Vfic '~aw Enfnrcemenf Agencies Only)
Millersville MD 21108
Contact Person: Lt. H:rlge/W. fccw:l G:nptroller' 5 Office Telephone Number: (410) 222-8656
m. Aud~~:____~~~~_~_~~_________________
Property Description:
$ ,~ C LA'" S" r AlIJrJAPDLI ~ tiD Request Type
v. Contribution (If any answer to A tbru E IS yes, provide details in Part VI) Yes No
Page 2
VL Additional space for detailed answers (Indicate Pari 10 .vhich ant,we,.(s) apply)
The Anne Arundel County Police Department is a participating member of the Immigration and Customs
Enforcement (ICE) 'Vocument Benefit Fraud Task Force' . The Anne Arundel County Police Department has one
full-time investigator (TFO: Mendoza # 1358) assigned to this Task Force Group_ Based on the results ofa recent
investigation, the Anne Arundel County Police Department is requesting a percentage of the nel proceeds resulting
from the seizure.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after recei ving
information that Annapolis Painting Services, located in Annapolis, MD, was employing undocumented workers.
The information suggested that the owner of the company pays these workers by check, deducts 1/3 of their gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays the undocumented
workers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Services, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wife, Rebe.cca Bontempo, are
laundering proceeds from tbe employment on undocumented workers through the business account to pay various
assets, to include real estate, vehicles and investment accounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to facilitate the illegal activity.
ONo
VIL Certiftadioos:
A. The requester ceJ1ifies that the above information is true and attUrate, tliat the property ~erred will be used for
tbe law eafon:eaaetit purpose stated, add that aD IIlOIbts received .,.......... &0 thit request will be deposited Ud
aCCOUIIted for oonsi8talt with applicable Federal. State, ud local law, regulatielu ami ~ 'I1le ~ agrees to
report OR the actual use of equitably transferred property upon request. Tke requester UBderstands that if it is UBable
to pay the necessary fees and expetHe8 at the time or tnmsfer, the tiIIef wiD be sold aDd «be maximum perceM of ~
sale proceeds wiD be awarded in lieu of the asset.
9 III I Of)
Signature I Title Date
B. ~::~=:'~==~~~£~=::.::."!~-r!!::=~:dl
offtcial to whom trausfer documents andler money should be delivered. (Legal cmutSel cerli.ftcOtion is "ot ,equiredfor
Fi al 'OI'Ceme1II tlgencies)
111
2008PVVOOO003701
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18, 2008, TFO Mendoza assisted in serving subpoenas to BGE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at multiples
locations in Annapolis to include the main business and the owner's residence. On February 4, 2008, TFO Mendoza
conducted numerous hours of undercover surveiHance and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted numerous hours of
undercover surveillance on Suspect: Roberto Bontempo's residence, and business and other residences owned by
Bontempo (Annapolis. Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertairung to the anticipated search warrant executions scheduled for June 30, 2008_ ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
The Anne Arundel County Police Department also provided fifty (50) police officers and detectives to assist with the
execution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
arrestees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 houses and 11 vehicles.
Date: 07 108 I 200S __
Treasury Agency: ICE
-------
Case Number: BA02POO7BAOO14
DF~PARTMENT OF THE l'REASURY Request for Transfer of Property Seizedf.iI'orfeited by a TreaSttry A!.>coq
(For Use By Domestic Law Enforcement Agencies Only)
Millersville MD 21108
m. Aud~~:____~~~_~_~
__________________ o Other assets in this case. (AI/d list).
Property Description:
S 96 CL.A'I .5,..... •~"t1IVA&l-1 ~ HI> Request Type .
fJ-. Item ~uhIP~8
IV. Spedfic Inteoded Law Enfon:ement Uses:
o Salaries ~Purcbase &f Equipment 0 Other (please Explain): _________________
o Purduue of Vehicles 0 Place Into Official Use
(If other than Calm)
-
v. C&ntributi&n (If any answer to A thru E is yes. provide details iD Part VI) Yes No
Page 2
VI. Additional spa«: rOt' detaik:d 8liswers (lndiUlte Part lb which amwer(lrj applyj
The Anne Arundel County Police Department is a participating member of the Immigration and Customs
Enforcement (ICE) 'Document Benefit Fraud Task Force' . The Anne Arundel County Police Department has one
full-time investigator (TFO: Mendoza # 1358) assigned to this Task Force Group, Based on the results of a recent
investigation, the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the seizure.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
information that Annapolis Painting Services, located in Annapolis, MD, was employing undocumented workers.
The information suggested that the owner of the company pays these workers by check, deducts 1/3 of their gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays the undocumented
workers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Services, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wife, Rebecca Bontempo, are
laundering proceeds from the employment on undocumented workers through the business account to pay various
assets, to include real estate, vehicles and investment accounts, which are proceeds from the iUegal activity: with
eight properties, and eleven vehicles being used to facilitate the illegal activity.
ONo
va Certifkatioos:
A. The requester certifIeS that the above iBfonnation is tnIe and aa:urate, tlult the property tranBferred will be used for
tbe law emon:emeot purpoee lUted, and that aD morne. ftCeived pu.nuaDt to dais request will k deposited and
aecoontecl for amtisteat with applicable Federal, State, _1ocaI1aw~ ~Iations aad onkn. 1k ~ agra:s to
repBrt 011 the actual use of equitably traBsferred property upon request. 1"he requester uRdentaods that if it is unable
to pay tile aeceaary fra aad expt.atea at the time of tnmsfer, the and will be BOld and the muimum perceIlt ef net
sale procu!ds wiD be awarded in lieu of the asset.
Signature I Title
~
B. As legal ~ I bave reviewed tbis Request~~er of Property SdzedIForfdted by • TreMory Agency and I
certify that the eontact penon ideIlfified in Part haB tile authority to auept.lldzecllforfdted property and il1he ·
offICial to whom transfer docomftlts aod/or y should be delivered. (Legal counsel ceitift.Ct1lion is twl requiredfor
F~orcemerrI tlgt!llcies)
Since being assigned to the Task Force Group on January 8, 2008, TFO Mend07A has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18,2008, TFO Mendoza assisted in serving subpoenas to BGE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at multiples
locations in Annapolis to include the main business and the owner's residence. On February 4,2008, TFO Mendoza
conducted fiumefOuS hours of undercover surveiHance and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegaJ workers. TFO Mendoza conducted numerous hours of
undercover surveillance on Suspect: Roberto Bontempo's residence, and business and other residences owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search warrant executions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
The Anne Arundel County Police Department also provided fifty (50) police officers and detectives to assist with the
execution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
arrestees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 houses and 11 vehicJes.
Date: ~I 108 / 2008
Trea."ury Agency: ICE
-------
Case Number: BA02POO7BAOO14
DEPARTMENT OF' THE TREASURY Reqoc-st fur Transfer of Property SeizedlForfeited by a Treasury Agency
(For Use By Domestic Law Enforcement Agencies Onl}')
Millersville MD 21108
o Item S.CatlhlP~
IV. Specific JiateIlded Law Enfon:emeat Uses:
o Salaries ~PurchaseofEquipment 0 Other (Please Explain): _ _ _ _ _ _ _ _ _ __
o Purcbase ofVebicIes 0 Place Into Official Use
(If other than Ca.m)
v. Contribution (If any answer to A tbru E is yes, provide detans in Part VI) Yes No
Page 2
VI. Additional flpace (or detailed ll.U!lwer1§ (lnJieale Part to wlricJr CUlt.Wf!I'(Sj app{v)
The Anne Arundel County Police Department is a participating member of the Immigration and Customs
Enforcement (ICE) 'Document Benefit Fraud Task Force' . The Anne Arundel County Police Department has one
full-time investigator (fFO: Mendoza # 1358) assigned to this Task Force Group. Based on the results of a recent
investigation, the Anne Arundel County P01ice Department is requesting a percentage of the net proceeds resulting
from the seizure.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
information that Annapolis Painting Services, located in Annapolis, MD, was employing undocumented workers.
The information suggested that the owner of the company pays these workers by check, deducts 1/3 of their gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays the undocumented
workers straight time regardless of the hours or days of the week the work was J)eTformed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Services, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wife, Rebecca Bontempo, are
laundering proceeds from the employment on undocumented workers through the business account to pay various
assets, to include real estate, vehicles and investment accounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to facilitate the illegal activity.
DNo
VIL Ccrtificatiou:
A. The requester ttrti.f'1eS tbat the above information is true and accurate, that the property tradsf~ will be used for
tile law eaforcedaellt pu.rpose Rated, and tIlat aD JDODies received pw1IIIlaat te tbis ft4Ut.It will he depoeke4 aIl4
8CtOU.Dted for COIlSiBteIlt 'tfith applieable Federal, Sfate,aad local law, RgIIIatieIu anti orden. The mpteIter agrea to
report 011 the actual ute or equitably transferred property upon request. The requester o.aderstands Chat if it is uoable
to pay the aeceaa.ry fees aDd apaues at the Ume of tnmsfer, the asset will be teId ad tile IIlUimIlDl peReDt of set
sale proaeds will be awarded in lieu of the asset.
Signature I Tille
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18,2008, TFO Mendoza assisted in serving subpoenas to BGE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at multiples
locations in Annapolis to include the main business and the owner's residence. On February 4, 2008, TFO tviendoza
conducted numerous hours of undercover surveillance and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
iUegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted oomerOU8 hour.s of
undercover surveillance on Suspect: Roberto Bontempo's residence, and business and other residences owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search warrant executions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
The Anne Arundel County Police Department also provided fifty (50) police officers and detectives to assist with the
execution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
flrrestees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of IS houses and 11 vehicles.
Date: 07 /os/ 2008
Treasury Agency: ICE
------
Case Number. BA02POO7BAOO14
J)EPARTMENT 01" THE TREASURY Request for Transfer of Property Seized/I!'orfeited by a Treasury Agenc),
(For Use BJ' Domestic Low Enforcement Agencies Only)
I.
FP&F Number: 2008130390000701 • All assets transferred must be used for the law oof~mt
purpose stated in the request.
Seizure Number: 2008PWOOO002901
Seizure Date: 6 / 30 /200S • Deadline for mbminion of WI request is sixty (60) days
following the seizure.
SAle Office: Baltimore
~~~--------------
• The requMing agency wiD be rapeasible for reimbuning
Case Type: AdoptroD-- Jomt--x-' the Treasury Agedcy its (osts and may be responsible for
Discontinuance - - reimbursing the Treasury Ageuey mare.
fr.herl£ One)
Millersville MO 21108
HI.
Property Description:
S ~..l #1112.&12 l)I? AIIIJJAA?uS, N b
-
v. Contributi&n (If any answer to A thru E is yes, provide details in Part VI) Yes No
Page 2
VL Additional space for detailed answers (Indicate Part to which answer(s) apply)
The Anne Arundel County Police Department is a participating member of the Immigration and Custow£
Enforcement (ICE) 'Duwrnent Benefit Fraud Task Force' . The Anne Arundel County Police Department has one
full-time investigator (fFO: Mendoza # 1358) assigned to this Task Force Group. Based on the results of a recent
investigation., the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the seizure.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
information that Annapolis Painting Services., located in Annapolis, MD, was employing undocumented workers.
The information suggested that the owner of the company pays these workers by check, deducts 1/3 of their gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays the undocumented
workers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Services, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wife, Rebecca Bontempo, are
laundering proceeds from the employment on undocumented workers through the business account to pay various
assets, to include real estate, vehicles and investment accounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to facilitate the illegal activity.
DNo
VB.. Certification,:
A. The reqaester certif"ti tbat the above iBformation is tnIe and accurate, that the property trauferred will be u8ed for
the Iaweafon:aDeat pu.tpOIe Itated. and fbat aD monies meived punuaat to this request will be ckpoIited aad
attOOIlfN for CtHlsmeat with applicable Ji'~ State, aad local law, ftCIIIatiou ami onIen. 1k requester agfta to
report 00 tJte actual use of equitably transferred property upon reqoegt The requester Il8derstmds that if it is unable
to pay Gte DeCeIIaJ'7 fees and eqenses at tile time ef fnDIfer, iJJe auet will be IOId aad tile IIlUiamm percent of Bet
sale proceeds will be awarded in IiaI or the asset
Addr~:
--------------------------~~
_ _ _ _--::---:OFflC[ OF lAW
Telephone Number: (4tO) 2660 RlVA ROAD. 4111 FlOOR
24
AlllltIfU II ... in Aile
2008PVV000002901
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18,2008, TFO Mendoza assisted in serving subpoenas to BGE and other banks in the Annapolis area in
reference to this case.
On Ianuary 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at multiples
locations in Annapolis to include the main business and the owner's residence. On February 4, 2008, TFO Mendoza
conducted numerous hours of undercover surveillance and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO MendOZA conducted numerous hours of
undercover surveillance on Suspect: Roberto Bontempo's residence, and business and other residences owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search warrant executions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
The Anne Arundel County Police Department also provided fifty (50) police officers and detectives to assist with the
execution of the search and seizure warrants in Annapolis. TFO MendoZA assisted with the interview of the
arrestees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 houses and 11 vehicles.
Date: 07 /08 / 2008
Treasury Agency: ICE
-------
Case Nomber: BAOZPOO7BAOO14
DEPARTMENT OF THE TREASURY Request for Transfer of Property SeizedlForfeited by a Treasury Agency
(For Use By J>ommic Lt1w En/orcemml A.gendes OJlly)
Addr~s; __________~84~~~V,~~===.M~~=_==a~y______________________________________
Millersville MD 21108
Contact PenoD:Lt. ~/W• .Ikcwl O:npt::roller's Office TelepboDe Number: (410) 112-1656
m.
Property De8uiptioR:
$ L()o Z C A ~,e.s A l> ArlN8 Po('" S M 1)
v. Contribution (If any answer to A thru E is yes, provide details iD Part VI) Yes No
Page 1
VL Additional space for detailed aDS'WeR (bIdic8te PIII1 to JtiUdt answer($) 1IJ1PIy)
The Anne Arundel County Police Department is a participating member of the Immigration and Customs
Enforcement (leB) "Document Benefrt Fraud Task Force'. The Anne Arundel County Police Department bas one
fuB-time investigator (TFO: Mendoza # 1358) assigned to this Task Force Group. Based on the results of a recent
investigation, the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the seizure.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
information that Annapolis Painting Services, located in Annapolis, MD. was employing undocumented workers.
The information SI.g.gested that the owner of the company pays these worlren by check, deducts 113 of their gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does DOt pay overtime and pays the undocumented
worlrers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Secvk.es, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wif~ Rebecca Bontempo, are
laundering proceeds from the employment on undocumented work:ess through the business KCOUDt to pay various
assets, to include reaJ estate, vehicles and investment a.coounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being UBed to facilitate the illegal activity.
vn. Certific......~
A. TIae mplf'lW cr.rdIies dIat die aIMwe mter.aI.ioa II true aad ~ tIaat dae ,reperlJ tnmII'enwI will be lid for
tile law ~ ptII'pfJIIe stated, .... dut ....... rectiYed panuaat fe tbiJ,..at wit a.e ~ aad
ace 1 .tedfor,...;.... wida .......'eJ'edenI,StMe, ....... Iaw~ ................... -'ftlfIM'*' lllftitlte
e I ,, lo-e
Sip. .re I 'IiIk DtIte
R M ..... - . I _ _ IlUJ~~oI~_b7.
urdfy ftIat dteCMtact penon Weadified ia Part it,.die ......
'Ifttiary , , - " " " I
acup ~,.....my ad . . .
ofticlaI to whom traasfer 4IeeamettU adler y tlteultiite deIiYer'ed. {U!gtIl CtJIImI!l ~ ;. ruJt retpIiNJ/01'
F. ~
S'r'L.
I
Addras:_ _ _ _ _~OFACE
~ '+ (0. 141M
• '-a
OF tAW
can
- - - - - 2 8 6 0 RlVA ROAD, 4111 noon
ANNAPOLIS, MD 21401
Te.IephoDe Number: (.ftO)
2008PVVOOOOO2701
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18,2008, TFO Mendoza assisted in serving subpoenas to BGE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at multiples
locations in Annapolis to include the main business and the owner's residence. On February 4, 2008, TFO Mendoza
conducted numerous hours of undercover surveiHance and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
iIIegalJy at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numecous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted numerous hours of
undercover surveillance on Suspect: Roberto Bootempo's residence, and business and other resideoca owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search warrant eXecutions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
On June 30. 2008. TFO Mendoza assisted with the execution of the Federal Search and Seimre Warrants.
fhe Anne Arundel County Police Department also provided fifty (SO) police officers and detectives to assist with the
",ecution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
UTestees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of is houses and II vehicles.
Date: 07 108 I 2008
Treuury Agency: _IC_E_ _ _ __
Case Number: BAOlPOO7BAOO14
L
FP&F Number: 2008130390000301 • All aadJ fralferred ..... be ued for die law eIIf~
puI'p9Ie IItated ill dae reqaat.
Seizure Number: 2OOSPWOOOOOJI01
Seizure Date: 6 / 30 / lOO3 -DeMline for MIInuiiIieo of tId.1"CqlIeR islixty (6&) day.
feJItftriJI& the seIzuR.
sAle Oft"1U: BaIdmIw'e
~~~~-------
• The ~.iag qt:IJCY will be I"eIp8IIIiItIe for ftiaIItu.nbtg _
Cue Type: ~ Jobrt-.:L
.awa
die TraJIIJ'Y A.t!J:acy its COJtJ .... may be 0IUibIe for
DiKontiauance - - .......niD& the TIftIUJ' Aaaq tIwe.
(CJu.tr.Ic IhtP.j
ll. Requesting Agenq Name: Anne Arundel County Po6ce Department
Addnu: __________~M~~~~~ere=r~aa=s~Hghw=*~a~y_______________________________________
Millersville MD 21108
Contact Penon. Lt• ~. fta..n CbJptro11er's Cffice Telephone Number: (410) 222-8656
n.
Prepeny DesaipIioD::
S :2 S 8&t1C~oFr A 11'£ AzwvAJ'!'OtlS #.2>
,. -
Contribution (If any answer to A thru E is yes, pnmde details in Part VI) Yes No
DEPARTMENT OF THE TREASURY Ikquest for Tramfer or Property SeizedlForfeUed by a Treuu.ry A,gency
(For Use By Domestic Low Enforcement AgencJes tOt4')
I.
FP&F Number: 2008130390000201 • All auetJ tntlllIf'erred matt be UfJed for tile law aaforeenaent
purpose Ifated ill dae reqaest.
Seizure NlIIDber: 200JPWOOOOO26Ql
Seizure Date: 6 / 30 / lOO8 • DeHliDefor IIIbmiuiOD ofdlis ftqIIeIt is IiDy (60) day.
r.IIswIDc die Idzure.
sAle OfI'ke: 8ahimore
----------------- • TIle ~ a,p.cy will be ~ fer ftiIUoniag
Cue Type: ~ Joiat-x"
tIae TraJllry At!/f:rIq itt ~ aU 1lla1 be rapoasibIe tor
DiBamtiauance - - - ....bal'liDl the Tmmny Agmq IItaft..
(CIu!r.k~J
Addnss: __________84=~=~Y,=d=~==M=~~==a~y~_____________________________________
MfIlersvHIe MD 21108
m.
PrcJperty Dacripdoa:
s 3/ AR,&>/l #/LL A..!> AN#APoLJ S ;VD
v. Contribution (If any answer to A thru E Is yes, provide details in Part VI) Yes No
ro F 92-22.46 07193 23
DEPARTMENT OF THE TREASURY Seizure Number. 2008PWOOOOO260 I
Page 2
VL MditiooaIlpace for detailed mswus (11UIiaIJe Part to KIdch tBISWl!T(S) 1IJ1PI:y)
The Anne Arundel County Police Department is a participating member of the Immigration l!nd Customs
Enfurcement (iCE) <Document Benefit Fraud Task: Force'. The Anne Arundel County Police Department has one
full-time investigator (TFO: Mendoza # 1358) assigned to this Task Force Group. Based on the results of a recent
investigation, the Anne Arundel County Police Department is requesting a percentage of the net proceeds resuhing
from the seizure.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
infonnation that Annapolis Painting Services, located in Annapolis, MD, was employing undocumented workers.
The information suggested that the owner of the company pays these worlrers by clteck, deducts 113 of their gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays the undocumented
workers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner ofthe Annapolis Painting Selvices, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wife, Rebecca Bontempo, are
laundering proceeds from the employment on undorumented workers through the business account to pay various
assets, to include rea! estate. vehicles and investment accounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to facilitate the illegal activity.
ONo
VB. Certificadeas:
,.......t
A. '1'he re.p"""" ca1ifitA dial die 8INwe iafonutiaa is tI'IIe ad attiUate, .... file pnpertJ tI~ willie . . . fer
the law eafort.alltat parpote stated, and tIaat aD BIODies receIwed to tIIb reqant wiD k depoIHed ad
.............. for NMtJj. . . . with applieable Federal. State, aad 1ocaI_, ......atjgM .......... ne mpc:*r a&IUI to
report .. die . . . . Ide III apdtabIy tl'Ulferreat ptopcsty .... reqaat. TIIe".- *' 1IIIdent.... dull if it is-..Me
to pay the ...........ry lea ad ~ at die dille ........., the aIId will k ........ die . . . . . . . percad of JId
ale prot.ftlIb willie . . . . . . ill IieII of die aaet.
~! tL ("r;-
.:guture I Title
+-f.u.-e <ii /C e I , Ii O~
DtIIL
Dt1te
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18,2008, TFO Mendoza assisted in serving subpoenas to BOE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at mUltiples
locations in Annapolis to include the main business and the owner's residence. On February 4, 2008, TFO Mendoza
conducted numerous hours of undercover surveiUance and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted numerous hours of
undercover SllfVeillance on Suspect: Roberto Bontempo's residence, and business and other residences owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search warrant exerutions scheduled for June 30, 2008. ICE
Agents subsequently ofJtained Federal Search and Seizure Warrants for the following locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
The Anne Arundel County Police Department also provided fifty (50) police officers and detectives to assist with the
execution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
mestees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 houses and II vehicles.
Date: 07 /OS I 200S
Treamry Ageacy: lei:
--.------
Case Number: BA01POO7BAOO14
DEPARTMENT OF THE TREASUKY Request for TraDIfer of Property Seizedlli'orfeited by a Tl'UlUry Apcy
(For Use By 1Jomestic /..,aw EnfOl'cemDII AgencIes O;dy)
I.
FP&F NUJDber: 200Sl305OOOO4301 • AD useD ......ermt __ he UIe4 for tile law emo~
parpote Rated ia dle ~
Seizure N.mber: lOOBSZOO6166701
Seizure Date: (1 / 30 /2008 • DeadIiDe fer IUbmiuioD of tIIis requeR is Ibty (. .) day.
~ die seizure.
sAle 0tT1U:--~~-----------
BaIDmore
• The ft4D"'Chtg .agacy will be reJp1I81ibIe fer reiJaIJunidg
CateType: AdoptJon-- Joiat'-x'
tIte TreaIu:ry A.f!.eacy its COJb IBd ...,. be IftPOIdibie for
Discoutiau.ance - - reimbaniDg the Trenary Apq IIaare.
(n.erJc 0",-)
Millersville MD 21108
Congn Person:Lt. ~/W. &x.w1 h:nptro1ler's <ffice Telephoue Number. (410) 2l2-8656
Asset ~,-:_-=U_S_c,,=-=LJ...t.ae-:.,z._l!;;;...N~r.--AYr...--_ _ __
frope.rty Darripaiea:
S ~963
, .. o0
Cootdbution (If any answer to A thru E is yes, provide details in Part VI) Yes No
-22.46 07193
DEPARTMENT OF THE TREASURY Seizu.re Number. 2OOBSZ0067"701
Page 2
VL AcldiDoaalllPatt fOT t'kUiJed armrtn (hu/iaIIe PIUt Jq wIIic6 1IIf8HIf!7'($) apply)
The Anne ArundeJ County Police Department is a participating member of the Immigration and Customs
Enforcement (ICE) 4DoaJment Benefit Fraud Task Force'. The Anne Arundel County Police Department bas one
full-time investigator (TFO: Mendoza # 1358) assigned to this Task Force Group. Based on the results of a recent
investigat~ the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the seizure ofS4,963.00 in U.S. Currency.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
information that Annapolis Painting Services, loalted in Annapolis, MD, was employing undOQJmented workers.
The information suggested that the ownet" of the company pays these worker's by ~ deducts 113 of their gross
pay. and tells the undoaunented workers that the deductions are fur taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays the undocumented
workers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Services, is
employing 35 undorumented workers and harboring these aliens at residences owned by him. A financial review of
the businessfpersooal bank accounts indicate that Roberto Bontempo and his wife~ Rebecca Bontempo, are
laundering proceeds from the employment on undocwnented workers through the business account to pay various
assets, to include real estate, vehicles and investment accounts, whicb are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to fucilitate the illegal activity.
ONo
VIL CertifiatioDB:
A. 11te reqaata" £eidfies dull die tIIJoft ~ is trw: ad ....~ dW . . pnperty.. #atatdlJe IIsaI for
die law ~.,....,a.e Itated, ad tIaat .. BIOIIieI recdftd paraaat eo tIdJ,.at wIIlte ~ ad
1UGa.1ed fer eGBIi. ._1ridl appIieUIe J'aIeraI, SUCe, 8Id1ocal1aw, .............. enIers. 1k ........ a&fta to
report _
to pay * * .... IIJe., ,....
IIft)tJIUry fI:a ... apmM'S at * ,....t, .....
IM, .. 4ti led re.,r& TIle .... *'
nt'znta t dial Ilia is IIIlabk
dale effnlllfer, die IIIId will k ....... die .ad _ peI'UIIt" lid
ale prea:aIId lie . . . . . itt . . fIId1e ....
Ln~- Sipabaft I
f-r: ~~,,) eJ'1 iif3
DtIte
:n:-
B. As legal eewud, lliave reviewed tItJI Reqaat fO;;~Pnperty SdzedIIi'0rfdte4 . , • TreaIury Atpq I
• ......it, .. &Capt.wJzedlferfciW propeI'ty &ad .. *
&ad
.
cerdfy Cbt a.e ceatact pcftOD kWtified ia ....;}l~
.mdaI ................ _ . . . .tJ...,.~
Fe4eNI hIw 0I'CtIW1It ~
....... 1te "taa. (LtpI C8IIIIMl~ irlllJlretpUredfor
Adtfnw!-_ _ _
~.COfJNJYCE OF lAW
---....O~FA......
- - -_____2iooo--VW68~ORlVA ROAD, 4rR ruiOll
Telephone Number: (410_)_ _ _..... ANNAP
......... OUS, MD 21401
'L
· -U
2008S~76670J
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18,2008, TFO Mendoza assisted in serving subpoenas to BGE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at multiples
locations in Annapolis to include the main business and the owner's residence. On February 4,2008, TFO Mendoza
conducted numerous hours of undercover S-wveillailce and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these swveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted numerous hours of
undercover surveillance on Suspect: Roberto Bontempo', residence, and business and other residences owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search wammt executions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
The Anne Arundel County Police Department also provided fifty (SO) police officers and detectives to assist with the
execution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
mestees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 houses and 11 vehicles.
Date: 07 /OS/ 2008
Treasury Agency: ICE
------
Case Number: BA02POO7BAOO14
Addr~: _________=~==~~~ft=N=a=D=s~~~==M~____________________________________
Millersville MD 21108
m Aud~.~:~U_S
__~C~V~C~~~-N~c~t~____________
Property Deaaiption:
$ ~f~2. 7'/
o Item
IV. Specific Iafende41..4nr Eaf'on:ement Uses:
o Salaries ~Purdtase ofEqaipmeat 0 Other (Please Explain): _ _ _ _ _ _ _ __
o Purdwe of Vehicles 0 Place Into Official Use
(If other titan Cosh)
v. Contribution (If any answer to A tbru E is yes t provide details in Part VI) Yes No
1D F 92-22.46 07193 23
DEPARTMENT OF mE TREASURY Seizure Number. 2008SZ006756001
Page 2
VL Additional space for detailed answers (IndiaJte Pm to which tDlSWt!r(s) 1IJIPIy)
The Anne Arundel County Police Department is a participating member of the Immigration and Customs
Enfoccemern (ILe.) <Document Benefit Fraud Task Force' _ The Anne Arundel County Police Department has one
full-time investigator (fFO: Mendoza # 1358) assigned to this Task Force Group_ Based on tbe results of a. recent
investigation, the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the seizure of $4,942. 79 in U.S. Currency_
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
information that Annapolis Painting Setvices, located in Annapolis. MD, was employing undocumented w()rkers.
The infonnation suggested that the owner of the company pays these workers by check, deducts 113 of their gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays tbe undocumented
workers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Services, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wife, Rebecca Bontempo, are
laundering proceeds from the employment on undocumented workers through the business account to pay various
assets, to include real estate, vehicles and investment accounts, which are proceeds 6-om the illegal activity: witb
eight properties, and eleven vehicles being used to facilitate tbe illegal activity.
~Yes DNo
VB. CertificadooJ:
A. TIre l'aIiN'ldft c:eadfiol dIat die ~ iafenutiaa is tnIe aad ~ daat die pnperty ~ wiIIlJe . . . for
the law eafort.aDellt po.rpoIIe Jtated, and tIaat II IBOIIies received punuut to dIb ftqIIeSt will be depMited ad
8CtOIIated for c:omi__ wida appIicahIe FecIenI, State, .... 1ocaI1aw, regaladoes .... orden. The ~ agrees to
nport_ die adllalille el apIitabIy traalfaled pnpa1y 1IfIOII ....... 'T'k req_" - *..... dtat if it it IIIUIItIe
to pay die aecaary fees ad espaue8 at tile fhae of tnuIIfer, . . auet will be.ald ... tile ___IUD percat".a
tale ~wi111Je awarded ia IiaI of die asa.
~~ 6-r· ~ . €) ~/11/0&
Signature I Tille
2008SZ006756001
Since being assigned to the Task Force Group on January 8,2008, TFO Mendoza bas assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18, 2008, TFO Mendoza assisted in serving subpoenas to BGE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at multiples
locations in Annapolis to include the main business and the owner's residence. On February 4, 2008, TFO Mendoza
conducted numerous hours of undercover surveiHance and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal bistories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted numerous hours of
undercover surveillance on Suspect: Roberto Bontempo's residence, and business and other residences owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search warrant executions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
The Anne Arundel County Police Department also provided fifty (SO) police officers and detectives to assist with the
execution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
atreStees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 hou.ses and II vehicles.
, .
Date: 07 /08 / 200S
Treasury Agency: _IC_E
_ _ _ __
Case Number. BA02POO7BAOO14
DEPARTMENT OF THE TREASURY KeqUeM for Tramfer of Property SeizedlFo~eited by a TreaAlry Agency
(For Use By Domestic Law Enforcement Agencies o"ly)
I.
FP&F Number: 20081J0390003201 • AD auets transferred 8IlMt be aued for tile law enforeemmt
parpmre Itated in tile request.
Seizure Number: 2008SZ0Q6164501
Seizure Date: 6 / 30 /2008 • Deadline fer _mission of 1bb ~ is sixty (00) days
following tile seizure..
SAIC Otrke:~~~~---------
Baltimore
• The requestiag ageacy will be resp8IIIibIe for reimIHlniDg
Case Type: Adoption Joint --X... tile Treuary AfPKY its ~ and lila,
be I'eIpOMibIe (or
Discontinuance - - rdmbunblg the Tl'UJUry AFOCY Ibare.
(r.ituk Ond
Millersville MD 21108
v. Contribution (If any answer to A tbru E is yes, provide details in Part VI) Yes No
Page 2
VL Additional space ror detailed 2IlSWen (lruliade Part to lJItich IUISWI!1'(s) apply)
The Anne Arundel County Police Department is a participating member of the Immigration and Customs
Enforcement (ICE) ~Document Benefit Fraud Task Force', The Anne Arundel County Police Department has one
full-time investigator (TFO: Mendoza # 1358) assigned to this Task Force Group. Based on the results of a recent
investigation, the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the seizure.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
information that Annapolis Painting Services, located in Annapolis, MD, was employing undocumented workers.
The information suggested that the owner of the company pays these workers by check, deducts 113 of their gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays the undorumeoted
workers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Selvioes, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wife, Rebecca Bontempo, are
laundering proceeds from the employment on undocumented workers through the business account to pay various
assets, to include real estate, vehicles and investment accounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to facilitate the illegal activity.
®Va ONo
VB. Certifk.tioo.s:
A. 'The n"qIIeSfer ca M'a da8t die aINwe iafonaadoa is tnIe .... MOIrak, dIat tile property II aasfu led will lie ..at for
tile law eaforcemeat parpoIe stated, .ad tIIat ......... rec:eived JMlI'IIdIli to tIUs ...,..... wi) be depoIited ad
accounted for con...... wIda appkahIe Ji'ederaI, State, ad local law, ......atiou ad orden. n.e reqaerter agRa to
report . . die adIIaI . . ~. .ably tr'DIfa-ml propel., ..,.D
aquest. 'l"IIe ~*'
to pay Ute aeceaary feea ... apelllel at tbe tilDe "D"aalfeJ', die aaet will be .... ad die ••
_'u .....
-am tIaat irit is 8DabIe
pen::eat ef lid
ale proceeds willie awarded ia lea of tile aaet.
SignaaIn I Tille
B. AJIegaJ COUDSel, I bal'e reviewed dIU Request for Tnasfer of Pnperty SeizedIIlorfeited It, a Treamry Agatcy aad I
certify that the contact perIOD idtaflfied ia Part DIw tile autIaority to aca:pt ~ property .... is tbe
ofticiaI to whom tnwfer tIocu:m.eatsllJ1dlor aaoaey ........ be ddiYered. fUgal ctIIIII6el CD'IijicJItitm is 1ItIl,..,ue4IDr
Ii tJgeIICia)
_ _ _ _---=2-=-=66u~~
'i mvA RUAD, 4TH FLOOR
Telepbone Number: (410 ) ANNAPOUS, MD 21401
2008SZ006764501
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18,2008, TFO Mendoza assisted in serving subpoenas to BGE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at multiples
locations in Annapolis to include tbe main business and the owner's residence. On February 4, 2008, TFO Mendoza
conducted numerous hours of undercover surveillance and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent IDlmerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted numerous hour:s of
undercover surveillance on Suspect: Roberto Bontempo's residence, and business and other residences owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search warrant executions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
The Anne Arundel County Police Department also provided fifty (SO) police officers and detectives to assist with thtf
execution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
mestees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 houses and 11 vehicles.
Date: 07 108 I 2008
TreaJUry Agency: _ICE
_ _ _ __
Case Number: BA02POO7BAOO14
MiNersville MD 21108
Contact Penon: Lt: HxWfW. fu::w1 Ca1ptro1ler's Cffice Telephone Number: (410) 222-8656
v. Contribution (If any answer to A thru E is yes, provide detaUs in Part VI) Yes No
ro F 92-22..46 07193 23
DEPARTMENT OF mE TREASURY Seizure Number: 200SSZ006764601
, Page 2
VI. AdditioMIspace for debiJed uswen (1n4U:tde Part to wlticb IIn8WD'(s) opp/;p)
The Anne Arundel County Police Department is a participating member of the Immigration and Custorr.s
Enforcemeni (ICE) 'Dowment Benefit Fraud Task Force'. The Anne Arundel County Police Department has one
full-time investigator (TFO: Mendoza # 1358) assigned to this Task Force Group. Based on the results of a recent
investigation, the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the seizure.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
information that Annapolis Painting Services, located in Annapolis, MD, was employing undocumented workers.
The information suggested that the owner of the company pays these workers by check, deducts 113 oftbeir gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays the undocumented
workers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Services, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the businesslpersooal bank accounts indicate that Roberto Bontempo and his wife. Rebecca Bontempo, are
laundering proceeds from the employment on undocumented workers through the business account to pay various
assets, to include real estate, vehicles and investment accounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to facilitate the illegal activity.
ONo
A. TIle RqPater UI tifits dial tile ~ Wormadoa is fnIe ad attal'1de, duIt die propert, ~ wII be DIed lor
the law eafOrtalalt JHII'P08e stated, ad Chat aU IIIOIIies aw.eMd panaaat to tIlb nqaat wiD lie depotdted and
acxouDted for COP....... wida appIkabIe FedenI, saa.e, .... loeaIlaw, ............... onkn. TIle ft4Ue*r apia to
ri._
report . . dIe.aut . . of,...u.Nr ........ft'ftd PI. ." .... mpaat. 1'k reqarster ............ dtat ilit .. ..aIe
to pay die aec:eJllry lea .... apeaaes at tile time of tnuIIfer, . . ..aid wII be ....... die ••
ale pneeedJ willie awarded ia lea of die aMd.
penat fllilet
~reG;-+kabF)
~
B. As legal cou.ueI, IIt.ve reviewed tJUs Request
certify that $e coatact penon ideadfied in
Ire ~er
Part,
of Pnperty &*edIJi'orfeite4 by • 1'reaJbry Agency od I
~
aotherity to accept lIdzedIferfeited preperty aad iI tIte _
oftidaI to whom tnDIfer up" ab adlor moaey ....d be ddifned. (Lt!glll COIIIf6el ~ ;. lUll t"el/1IireJ/01'
p; ~ I4w "I/f!Ifdes)
Ad4re8s:
--------------------------~
'"
2008SZ006764601
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18,2008, TFO Mendoza assisted in serving subpoenas to BGE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at multiples
locations in Annapolis to include the main business and the owner's residence. On February 4,2008, TFO Mendoza
conducted numerous hours of ondercover surveiiiance and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted numerous hours of
undercover surveillance on Suspect: Roberto Bontempo's residence, and business and other residences owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search warrant executions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the fonowing locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
The Anne Arundel County Police Department also provided fifty (50) police officers and detectives to assist with the
execution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
arrestees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 houses and II vehicles.
Date: 07 /08 / 2008
Treasury Agency: ICE
--------
Case Number: BA02P007BAOOI4
For Treasury Agency Use Only (Far ~4!ld!!i!Jn.!!! In/ermation = See Instruct/utuj.
I.
FP&F Number: 2008130390003001 • All assets transferred must be used for the law enforcement
purpose stated in the request.
Seizure Number: 2008SZ006764201
Seizure Date: 6 / 30 /2008 • Deadline for submission of this request is sixty (60) days
following the seizure.
SAle Office: Baltimore
------------------- • The requesting agency will be responsible for reimbursing
Case Type: Adoptioll- Joint----X-
the Treasury Agency its costs and may be responsible for
Discontinuance - - reimbursing the Treasury Agency share.
(rhprk (}np)
Millersville MD 21108
III. Asset Requested :....___"'.Jt.liiS...H.:.w:.I .,:,C=L<Io6:"S:::::.-__________ o Other assets in this case. (Attach list).
Property Description:
$ ex GM C VAN S "+ M' S C Request Type
L~ Item \'!(cashlProceed:
IV. Specific Intended Law Enforcement Uses:
o Salaries 0 Purchase of Equipment o Other (please Explain): _ _ _ _ _ _ _ _ _ _ __
o Purchase of Vehicles 0 Place Into Official Use
(If other than Cash)
v. Contribution (If any answer to A thm E is-yes, provide details in Part VI) Yes No
Page 2
VI. Additional space for detailed answers (Indicate Part to which answer(s) app{}~
The AlU1e Arundel County Police Department is a participating member of the Immigration and Customs
Enforcement (ICE) ' Documeill Bcndit Fraud Task Force' . The Anne Arundel County Police Department has one
full-time investigator (TFO: Mendoza # 1358) assigned to this Task Force Group. Based on the results of a recent
investigation, the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the seizure.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
information that Annapolis PaInting Services, located in Annapolis, MD, was employing undocumented workers.
The information suggested that the owner of the company pays these workers by check, deducts 1/3 of their gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive thejr
green cards. The information also indicated that the owner does not pay overtime and pays the undocumented
workers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Services, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wife, Rebecca Bontempo, are
laundering proceeds from the employment on undocumented workers through the business account to pay various
assets, to include real estate, vehicles and investment accounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to facilitate the illegal activity.
. (lfmore space is required, use a separate sheet o/paper and attach.) Attachment: IJK(ves DNo
VII. Certifications:
A. Tbe requester certifies that the above information is true and accurate, that the property transferred will be used for
the law enforcement purpose stated, and that all monies received pursuant to this request will be deposited and
accounted for consistent with applicable Federal, State, and local law, regulations and orders. The requester agrees to
report on the actual use of equitably transferred property upon request. The requester understands that if it is unable
to pay the necessary fees and expenses at the time of transfer, the asset will be sold and the maximum percent of net
sale proceeds will be awarded in lieu of the asset.
if'
8. As legal counsel, I have reviewed this Request for;r~of Property SeizedlForfeited by a Treasury Agency and I
certify that the contact person Identified in par~as the authority to accept seized/forfeited property and is the
offici I to whom transfer documents and/oJ money should be delivered. (Legal counsel certiflcatwn is not required/or
Fed r Iia ment agencies)
BIll
Address: _ _ _ _ _ _ ---viOFnCE fiF i'W
-----......v26S0 ruVA ROAD, 4111 FLOII
-----<ANtWOUS, II 214011 ,
Telephone Number: (410_)_ _ _ _ _ _ _
24
2008SZ006764201
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18,2008, TFO Mendoza assisted in serving subpoenas to 8GE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at multiples
locations in Annapolis to include the main business and the owner's residence. On February 4, 2008, TFO Mendoza
conducted numeiOUS hours of undercover survt:iliance and conducted a traffic stop at WhICh time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted numerous hours of
undercover surveillance on Suspect: Roberto Bontempo' s residence, and business and other residences owned- by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search warrant executions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
fhe Anne Arundel County Police Department also provided fifty (50) police officers and detectives to assist with the
~xecution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
rrrestees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 houses and 11 vehicles.
Date: J~7 /08 / 200S
TrcasUl'y ,,{genq: ICE
-------
Case Number: BA02POO7BAOO14
DEPARTMENT OF THE TREASURY Request for Transfer of Property SeizedfForfeited by a Treasury Agenq
(FI»' 1!~e Ill' /)ome!llic lAW Enfnrcement Agencies Only)
I.
FP&F Number: 2008130390001901 • AU assets transferred must be WIetf for the law enforcement
purpose stated in the request.
Seizure Number: 2008PWOOO00380J
Seizure Date: 6 / 30 /2008 • Deadline (or IUbmiSJion of this request is sixty (60) da~'8
following the seizure.
SAle OfTKe: Baltimon!
Case Type: ------~-------------
AdoptiOD-- Joint----X-
• The requestiAg ageacy wiD be responsible ror reimbursing
the Treasury Agency its com and may be n!SpOnsible for
Discontinuance - - reimbursing the Treasury Agency share.
Millersville MD 21108
Contact Person: Lt. ~/W. Ihw1 Ccnptroller's Office Telepbone Number: (410) 222-8656
In.
Property Description:
$ 30 PLeASANT :5 r "tJAlAPOU~
-
v. Contribution (If any answer to A tbru E is yes, provide details in Part VI) Yes No
Vi. Additional 1ipac.e for detailed aD..'<Wcrs (Indicnte Part to which answer(s) apply)
Th~Anne Amndd County Poliee T>epartment is a ~rticipating member of the fmmigration "nct t.nstoms
Enfo rcement (ICE) 'Document Benefit Fraud Task Force'. The Anne Arundel County Police Department has one
fi,ll-time investigator (TFO' Mendon. # 115R) assigned to this Task For,.e Group Rased on the re-~~ufts of R re\.ent
investigation, the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the sei7ure
In Ianuary 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
information that APn~DOlis Painting Servic.e8, loc.ated in Annapolis. MD, was employin~ undocumented workers
The information suggested that the owner of the company pays these workers by check, deducts 1/3 of their gross
pay, and tells the undocumented workers that the deductions are for ta.xes which will be due after they roc.eive their
green cards. The information also indicated that the owner does not pay overtime and pays the undocumented
workers straight time ~ardless of the OOUrsOf days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Services, is
employing 35 undocumented workers and harborin~ these aliens 8t residenc.es owned by him _A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wife, Rebecca Bontempo, are
launderin~ proc.eeds from tbe employment on undocumented workers through the business 8c.('.onnt to pay V3rion~
assets, to include real estate, vehicles and investment accounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to facilitate the illegal activity-
DNo
VJL CertiIicatioos:
A. The requester certifies that the above information ill true and aa:urate, that the property transferred will be used for
the law eafortellledt ptu'pOIe stated, ud that aD IBOIlies received punaut to dais request wII be deposited aaad
~('tllIJr.tl'd
.- . _- . - rnnadl>nf
- - - fnT -- - -" . with
-. . AnnHrAhL>
' -rr ... .. - Jl'.....
dl'l"'AI.
- . . .' ~tAf", aDd..
- -. --- r.- wallaa-.
- - _. -- - -/ ....--IAfUMac
' 0' . • . -
$lad BrdPrc.
- • . .- - - - --
TIw- "","IIU"dI'T
. .• . - - - -
aCJn'l"C
--0
tn
--- - .
report on the actual use of equitably transferred property upon request. 1be requ.ater undentaRds that if it is uoable
tn r ".' till'
. - nAY . - - - - - - " .' ~
IW'II'I'C&AI"V - - _ arut - ¥ . .- - - At
. . .. I'nu>nG:l't: flu.. tlnw
-- _. . - of
- frAftd
. .. .. ..
- l"'.f flu>
'
IIltvt
_ . - _ .•
_ ••
..nt Iw EnId Alt" t .... _anmam £
' .•• - - •. _. "
Rl'l"N'nt
•. - -
-
c4 at't
. -
• • •..
SinGe being assigned to the Task Foree Group on January 8, 2008, TFO Mendon! has ass!5ted (ICE) Speeia!
Agents by providing investigative resources and operational assistance during the course ofthis investigation. On
Jnnn~r.:
~
! P, 20()~ ITO ~1endo7A'1 :l:::5ii~~ in ~ervlnQ
'-'
~llhno.."11n~
J
to RGF nnn othf':f h;mk~ in the A nn:1nnli~ :1rf'::} in
1
On J;;;;u;;.y 21, 20m~ TF(} ~fefid()7~ (:(trlflucted numerotlS hours of 'lnderGover sfJrvelii~nc(' at multiple",
locations in Annapolis to include the main business and the owner's residence. On February 4, 2008, TFO Mendoza
t'-ondllcte.d nume.r()lIS hours of Ilndef"(."A)ver surveilhmce ami ('A)nductoo a traffic stop at which rime an undocumented
employee who worked for Annapolis Painting services was arrested
From Febmary 12, 2008 to June 28. 2008. TFO Mendoza c.onducted numerous hours of underc.over surveillance
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
ilI~any at the Annapolis Paintin~ servic.es TFO Mendoz~ also used the Anne Anmdel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in referenCe to
the vehides and registration plates used by the iIl~1 workers TFO Mendoza c.onducted mlmerOHS hours of
undercover surveillance on Suspect: Roberto Bontempo's residence, and business and other residences owned by
Bontempo (Annapolis. Maryland) This underc.over surveillance. was c.onducted to provide ICE with detaile.d
operational information pertaining to the anticipated search warrant executions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
On J'lne 30, 2008, TFO Mendoza assisted with the execution of the Fe.dera1 Se.arch and Seizure Warrants
The Anne Arundel County Police Department also provided fifty (50) police officers and detectives to assist with the
execution of the se.arch and seizure warrants Ln Annapolis TFO Mendoz~ assisted with the interview of the
arrestees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 houses and 11 vehicles.
Date: 07 /08 / 2008
Treasury Agency: ICE
-------
Case Number: BA02P007BAOOl4
DEPARTMENT OF THE TREASURY Request for Transfer of Property SeizedlForfeited by a Treasury Agency
(For Use By Domestic Law Enforcement Agencies Only)
For Treasury Agency Use Only (For . 4.dtli!iaf:a! In/ormatio" - See Ift5trur.:iiunl).
I.
FP&F Number: 2008130390002801 • All assets transferred must be used for the law enforcement
purpose stated in the request.
Seizure Number: 2008PW000003901
Seizure Date: 6 /30 /2008 • Deadline for submission of this request is sixty (60) days
following the seizure.
SAle Office: Baltimore
----------------------- • The requesting agency will be responsible for reimbursing
Case Type: Adoption- Joint-X-
the Treasury Agency its costs and may be responsible for
Discontinuance ----- reimbursing the Treasury Agency share.
rrhprk Onp)
Millersville MD 21108
Cootact Perso0:.I.t. ~IW. lk!:Kl Q;n:ptroller's Wi.ce Telephone Number: (410) 222-8656
v. Contribution (If any answer to A th ru E is-yes, provide details in Part VI) Yes No
Page 2
VI. Additional space for detailed answers (Indicate Part to which answer(s) apply)
The Anne Arundel County Police Department is a participating member of the Immigration and Customs
Enforcement (ICE) 'Document Benefit Fraud Task Force'. The Anne Arundel County Police Department has one
full-time investigator (TFO: Mendoza # 1358) assigned to this Task Force Group. Based on the results of a recent
investigation, the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the seizure.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
information that Annapolis Painting Services, located in Annapolis, MD, was employing undocumented workers.
The information suggested that the owner of the company pays these workers by check, deducts 1/3 of their gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays the undocumented
workers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Services, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wife, Rebecca Bontempo, are
laundering proceeds from the employment on undocumented workers through the business account to pay various
assets, to include real estate, vehicles and investment accounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to facilitate the illegal activity.
(lfmore space is required, use a separate sheet o/paper and attach.) Attachment: ~Yes DNo
VII. Certifications:
A. The requester certifies that the above information is true and accurate, that the property transferred will be used for
the law enforcement purpose stated, and that all monies received pursuant to this request will be deposited and
accounted for consistent with applicable Federal, State, and local law, regulations and orders. The requester agrees to
report on the actual use of equitably transferred property upon request. The requester understands that if it is unable
to pay the necessary fees and expenses at the time oftransfer, the asset will be sold and the maximum percent of net
sale proceeds will be awarded in lieu of the asset.
B. As legal counsel, I have reviewed this Request f: r ~fer of Property SeizedlForfeited by a Treasury Agency and I
certify that the contact person identified in Part '~I:I;~e authority to accept seized/forfeited property and is the
official to who transfer documents and/or mo ey should be delivered. (Legal counsel certification is not required/or
Fede Iia flo
24
2008PVV000003901
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (lCE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18,2008, TFO Mendoza assisted in serving subpoenas to BGE and other banks in the Annapolis area in
reference to this case.
On JanlJary 23, 2008 TFO Mendoza conducted numerous hours of undercover surveiliance at multIples
locations in Annapolis to include the main business and the owner's residence. On February 4,2008, TFO Mendoza
conducted numerous hours of undercover surveillance and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted numerous hours of
undercover surveillance on Suspect: Roberto Bontempo's residence, and business and other residences owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search warrant executions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
rhe Anne Arundel County Police Department also provided fifty (50) police officers and detectives to assist with the
:xecution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
rrestees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 houses and 11 vehicles.
Date: 07 /08 / 2008
Treasury Agency: ICE
-------
Case Number: BA02P007BAOOl4
IJEPARTMENT OF THE TREASURY Request for Transfer of Property Seized/Forfeited by a Treasury Agency
(For Use By Domestic Law Enforcement Agencies Only)
For Treasury Agency IJse Only (Fa;" r1dditional In/vi/natioii - See instructionsj.
I.
FP&F Number: 2008130390002901 • All assets transferred must be used for the law enforcement
purpose stated in the request.
Seizure Number: 2008PW00004001
Seizure Date: 6 / 30 /2008 • Deadline for submission of this request is sixty (60) days
following the seizure.
SAle Office: Baltimore
--~~~------------
• The requesting agency will be responsible for reimbursing
Case Type: Adoptioll- Joint--X-
the Treasury Agency its costs and may be responsible for
Discontinuance - - reimbursing the Treasury Agency share.
rrhprk Om"
Millersville MD 21108
Contact Person: It.,. li::c\;!.e!W. &cw1 Cbrptrol1.er-'s CfficeTelephone Number: (410) 222-8656
v. Contribution (If any answer to A thru E is-yes, provide details in Part VI) Yes No
Page 2
VI. Additional space for detailed answers (Indicate Part to which answer(s) apply)
The Alme Arundel County Police Department is a participating member of the Immigration and Customs
Enforcement (iCE) 'Document Benefit Fraud Task Force'. The Anne Arundel County Police Department has one
full-time investigator (TFO : Mendoza # 1358) assigned to this Task Force Group. Based on the results of a recent
investigation, the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the seizure.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
information that Annapolis Painting Services, located in Annapolis, MD, was employing undocumented workers.
The infonnation suggested that the owner of the company pays these workers by check, deducts 1/3 of their gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays the undocumented
workers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Services, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the businesslpersonal bank accounts indicate that Roberto Bontempo and his wife, Rebecca Bontempo, are
laundering proceeds from the employment on undocumented workers through the business account to pay various
assets, to include real estate, vehicles and investment accounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to facilitate the illegal activity.
(lfmore space Is required, use a separate sheet o/paper and attach.) Attachment: ~Yes ONo
VII. Certifications:
A. The requester certifies that the above information is true and accurate, that the property transferred will be used for
the law enforcement purpose stated, and that all monies received pursuant to this request will be deposited and
accounted for consistent with applicable Federal, State, and local law, regulations and orders. The requester agrees to
report on the actual use of equitably transferred property upon request. The requester understands that if it is unable
to pay the necessary fees and expenses at the time of transfer, the asset will be sold and the maximum percent of net
sale IJroceeds will be awarded in lieu of the asset
.- ~ COIR1
Address:
- - - - - l r f f·~·C'( H ~.14 f
' · ". .
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18,2008, TFO Mendoza assisted in serving subpoenas to BGE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at Ulultipks
locations in Annapolis to include the main business and the owner's residence. On February 4, 2008, TFO Mendoza
conducted numerous hours of undercover surveillance and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted numerous hoqrs of
undercover surveillance on Suspect: Roberto Bontempo's residence, and business and other residences owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search warrant executions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
rhe Anne Arundel County Police Department also provided fifty (50) police officers and detectives to assist with the
~xecution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
lrrestees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 houses and 11 vehicles.
Date: J!2 /08 / 2008
Treasury Agency: ICE
-------
Case Number: BA02P007BAOOl4
DEPARTMENT OF THE TREASURY Request for Transfer of Property SeizedlForfeited by a Treasu ry Agency
(For Use By Domestic Law Enforcement Agencies Only)
For Treasury Agency Use Only (Far Addition::! In/armatior; - See instructions).
I.
FP&F Number: 2008130390001501 • All assets transferred must be used for the law enforcement
purpose stated in the request.
Seizure Number: 2008PW000003501
Seizure Date: 6 /30 /2008 • Deadline for submission of this request is sixty (60) days
following the seizure.
SAIC Office: Baltimore
------------------- • The requesting agency will be responsible for reimbursing
Case Type: Adoptioll- JOint--X...
the Treasury Agency its costs and may be responsible for
Discontinuance - - reimbursing the Treasury Agency share.
rrhprknnp)
Millersville MD 21108
III. __c________________
Asset Requested :.....___---'#.~_p_,.., o Other assets in this case. (Attach list).
Property Description:
$ G70 Ct7"N172AL A tit 4btp &/lb.5v.N"I' Ltc .#0 Request Type
; : Item ~aShlProceeds
IV. Specific Intended Law Enforcement Uses:
o Salaries I&l. Purchase of Equipment 0 Other (please Explain): _ _ _ _ _ _ _ _ _ _ _ __
o Purchase of Vehicles 0 Place Into Official Use
(If other than Cash)
f. Contribution (If any answer to A thru E is yes, provide details in Part VI) Yes No
o F 92-22.46 07/93 23
DEPARTMENT OF THE TREASURY Seizure Number: 2008P\V000003501
Page 2
VI. Additional space for detailed answers (Indicate Part to which answer(s) apply)
The Anne Arundel County Police Department is a participating member of the Immigration and Customs
Enforcement (ICE) 'Document Benefit Fraud Task Force'. The Anne Arundel County Police Department has one
full-time investigator (TFO: Mendoza # 1358) assigned to this Task Force Group. Based on the results of a recent
investigation, the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the seizure.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
information that Annapolis Painting Services, located in Annapolis, MD, was employing undocumented workers.
The information suggested that the owner of the company pays these workers by check, deducts 113 of their gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays the undocumented
workers straight time regardless of the hours or days of the week the work was performed.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Services, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wife, Rebecca Bontempo, are
laundering proceeds from the employment on undocumented workers through the business account to pay various
assets, to include real estate, vehicles and investment accounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to facilitate the illegal activity.
(lfmore space is required, use a separate sheet o/paper and attach.) Attachment: rJ..ves ONo
VII. Certifications:
",. The requester certifies that the above information is true and accurate, that the property transferred will be used for
the law enforcement purpose stated, and tbat all monies received pursuant to this request will be deposited and
accounted for consistent with applicable Federal, State, and local law, regulations and orders. The requester agrees to
report on tbe actual use of equitably transferred property upon request. The requester understands that if it Is unable
to pay the necessary fees and expenses at tbe time of transfer, the asset will be sold and the maximum percent of net
sale proceeds will be awarded in lieu of the asset.
8. As kgal counsel, I have ,..iewed this Request ~ (~r. of Prop,rty S,izedlForfeited by a Tr...ury Agency and I
certify that tbe contact person identified in party!as the authority to accept seized/forfeited property and is the
official to whom transfer documents and/or money should be delivered. (Legal counsel certification is not reqUired/or
Federall nforcement agencies)
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18,2008, TFO Mendoza assisted in serving subpoenas to BOE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at muItipies
locations in Annapolis to include the main business and the owner's residence. On February 4, 2008, TFO Mendoza
conducted numerous hours of undercover surveillance and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at the Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assist in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted numerous hours of
undercover surveillance on Suspect: Roberto Bontempo's residence, and business and other residences owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search warrant executions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
~he Anne Arundel County Police Department also provided fifty (50) police officers and detectives to assist with the
xecution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
rrestees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 houses and II vehicles.
i :;
\ Date: 07 /08 / 2008
Treasury Agency: ICE
-------
Case Number: 8A02P007BAOOl4
DEPARTMENT OF THE TREASURY Request for Transfer of Property SeizedfForfeited by a Treasu ry Agency
(For Use By Domestic Law Enforcement Agencies Only)
For Treasury Aj!ency Use Only (For ~4ddi!i!!!lal Information - See Instructions).
I.
FP&F Number: 2008130390001401 • All assets transferred must be used for tbe law enforcement
purpose stated in the request.
Seizure Number: 2008PW000003401
Seizure Date: 6 / 30 /2008 • Deadline for submission of this request is sixty (60) days
following the seizure.
SAl C Office: Baltimore
~~~~--------------
• The requesting agency will be responsible for reimbursing
Case Type: AdoptioD- Joint-X-
the Treasury Agency its costs and may be responsible for
Discontinuance - - - - reimbursing the Treasury Agency share.
rrhprk ()np)
Millersville MD 21108
Contribution (If any answer to A thru E isyes, provide details in Part VI) Yes No
Page 2
VI. Additional space for detailed answers (Indicate ParI to which answer(s) apply)
The Anne Arundel County Police Department is a participating member of the Tmmigration and Customs
Enforcement (ICE) 'Document Benefit Fraud Task Force' . The Anne Arundel County Police Department has one
full-time investigator (TFO: Mendoza # 1358) assigned to this Task Force Group. Based on the results of a recent
investigation, the Anne Arundel County Police Department is requesting a percentage of the net proceeds resulting
from the seizure.
In January 2007, (ICE) Special Agents from the SAC Baltimore initiated an investigation after receiving
information that Annapolis Painting Services, located in Annapolis, MD, was employing undocumented workers.
The information suggested that the owner of the company pays these workers by check, deducts 1/3 of their gross
pay, and tells the undocumented workers that the deductions are for taxes which will be due after they receive their
green cards. The information also indicated that the owner does not pay overtime and pays the undocumented
workers straight time regardless of the hours or days of the week the work was perfonned.
Investigative findings indicate that Roberto Bontempo, owner of the Annapolis Painting Services, is
employing 35 undocumented workers and harboring these aliens at residences owned by him. A financial review of
the business/personal bank accounts indicate that Roberto Bontempo and his wife, Rebecca Bontempo, are
laundering proceeds from the employment on undocumented workers through the business account to pay various
assets, to include real estate, vehicles and investment accounts, which are proceeds from the illegal activity: with
eight properties, and eleven vehicles being used to facilitate the illegal activity.
(lfmore space Is required, use a separate sheet of paper and attach.) Attachment: ~Yes ONo
VII. Certifications:
A. The requester certifies that the above information is true and accurate, that the property transferred will be used for
the law enforcement purpose stated, and that all monies received pursuant to this request will be deposited and
accounted for consistent with applicable Federal, State, and local law, regulations and orders. Tbe requester agrees to
report on the actual use of equitably transferred property upon request. The requester understands that if it is unable
to pay the necessary fees and expenses at the time of transfer, the asset will be sold and tbe maximum percent of Det
sale proceeds will be awarded in lieu of the asset.
B. As legal eoun,e~
certify that the contact person identified in
~~fer
pa';'!l~~e
I bave reviewed this Request of Property SeUedlForleited hy a Treasury Ageney and I
authority to accept seized/forfeited property and is the
official to whom transfer documents and/or_money should be delivered. (Legal counsel certification is not requiredfoT
Fe rail iforcement agencies)
Since being assigned to the Task Force Group on January 8, 2008, TFO Mendoza has assisted (ICE) Special
Agents by providing investigative resources and operational assistance during the course of this investigation. On
January 18, 2008, TFO Mendoza assisted in serving subpoenas to BGE and other banks in the Annapolis area in
reference to this case.
On January 23, 2008 TFO Mendoza conducted numerous hours of undercover surveillance at multiples
locations in Annapolis to include the main business and the owner's residence. On February 4, 2008, TFO Mendoza
conducted numerous hours of undercover surveillance and conducted a traffic stop at which time an undocumented
employee who worked for Annapolis Painting services was arrested.
From February 12, 2008 to June 28, 2008, TFO Mendoza conducted numerous hours of undercover surveillance.
During these surveillances, TFO Mendoza was able to obtain information in reference to the employees that worked
illegally at ~e Annapolis Painting services. TFO Mendoza also used the Anne Arundel County databases to assis! in
identifications and criminal histories. TFO Mendoza spent numerous hours compiling information in reference to
the vehicles and registration plates used by the illegal workers. TFO Mendoza conducted numerous hours of
undercover surveillance on Suspect: Roberto Bontempo's residence, and business and other residences owned by
Bontempo (Annapolis, Maryland). This undercover surveillance was conducted to provide ICE with detailed
operational information pertaining to the anticipated search warrant executions scheduled for June 30, 2008. ICE
Agents subsequently obtained Federal Search and Seizure Warrants for the following locations:
On June 30, 2008, TFO Mendoza assisted with the execution of the Federal Search and Seizure Warrants.
he Anne Arundel County Police Department also provided fifty (50) police officers and detectives to assist with the
:ecution of the search and seizure warrants in Annapolis. TFO Mendoza assisted with the interview of the
restees and the booking process.
The Federal Search Warrant and Seizure resulted of the seizure of 15 houses and 11 vehicles.