Case 9:18-mj-08431-DLB Document 1 Entered on FLSD Docket 10/15/2018 Page 1 of 11

AO 91(Rev.01X ) EMY- ICamplaint

U NITED STATES D ISTRICT COURT

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Southern DistrictofFlorida
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1,thecomplainu tin thiscase.sute thatthe following istnleto thebestofmy u owledge and belieE
()noraboutthedatets)of Januaw 2015-November2015 illthecotmtyof Palm Beach illthe
Southern Districtof Florida sthedefenfhntts)violated:
CodeSection OgenseDeacrfp/fop
18U.S.C.â1M 3 W irefraud.

Thiscrim innlcomplnintisbased on tkesefacts:

See Attached Amdavit

W Conthmedontheattachedsheet.

Co ain ' signature

Alisha Rhoades,FBISpecialAqent
Printed nameand rirle

Swom tobeforeme and sipzed illm ypresence.

Date: to - Ib- - l.
6 It G vl
aa-- -
Judge'
.
<signature

City alld state: W estPalm Beach,Florida Dave Lee Brannon,U.S.MagistrateJudge

Printednameand lirle
Case 9:18-mj-08431-DLB Document 1 Entered on FLSD Docket 10/15/2018 Page 2 of 11

AFFIDAVIT IN SUPPO RT O F CRIM INAL CO M PLAINT

SCOTT BRADLEY M EYROW ITZ

1,Alisha Rhoades,firstbeing duly sworn,do hereby depose and state as follows:

.

YourAffiantisa SpecialAgent(SA)ofthe United States FederalBureauof

Investigation (FBI),currently assigned to the MiamiDivision,W estPalm Beach Resident
Agency Office.

2. Ihave been em ployed by the FBIforoverfive years,serving as a Special

Agentfornearly three years. Ibegan working forthe FBIin February 2013,serving as

an Accountantforthe FBl Headquaders Finance Division Iocated in W ashington D.C.

Afterapproxim ately three years as an Accountant Ireceived an appointm entto attend

FBINew Agents Class in Q uantico,Virginia where Ibecam e an FBISpecialAgentafter

21 weeks oftraining.

3. As a SpecialAgent of the FBIassigned to a Com plex FinancialCrim es

Squad,Ihave conducted investigations into allegations ofvehicle Ioan fraud,wire fraud,

m ailfraud,securities fraud,bank fraud,identity theft,m oney Iaundering and corporate

fraud. During the course ofthese investigations, Ihave conducted physicaland wire

surveillance,executed search warrants,and reviewed and analyzed conversations and

records ofindi
viduals involved in crim inalactivity.Through m y training,education,and

experience,which also includes debriefing cooperating defendants and witnesses,and

handling confidentialinform ants,lhave becom e fam iliarw ith the m annerin which m any

types ofcrim inalactivities are conducted and proceeds are deri

ved and Iaundered.

4. lsubm itthis affidavi

t in supportofa crim inalcom plaintcharging thatfrom

as earl
y as January 2015 through approxim ately Novem ber2015,in Palm Beach County,

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Case 9:18-mj-08431-DLB Document 1 Entered on FLSD Docket 10/15/2018 Page 3 of 11

in the Southern District of Florida, and elsewhere, Scott Bradley M EYROW ITZ did

know ingly com m itW ire Fraud in violation ofTitle 18,United States Code,Section 1343.

5. Iam fam iliarwith the facts and circum stances ofthe investigation setforth

below through m y personalpadicipation,from discussions with otheragents ofthe FBI,

from m y discussions with witnesses involved in the investigation,and from m y review of

records and repods relating to the investigation. This affidavitis intended to show m erely

thatthere is sufficientprobable cause forthe requested warrant,and does notsetforth

aIIofmy knowledge aboutthis matter.

BACKG RO UND O N THE DIAM O ND

6. Richard Mellen,ownerof M ellen,Inc.is a wholesale dealerof diam onds

andjewelry inthe New YorkCitydiamond district.Mellenspecializes in coloredandother

high-quality diam onds valued atm ore than a m illion dollars.

In2013,Mellen purchased a 4.oscaratflawless heart-shaped blue diam ond

mounted ina ring (''the Diamond'').Mellen purchasedthe Diamondfrom MichaelLippman,

a wholesale diamonddealerin LosAngeles.The purchase pricewas$1.3 million.Mellen
and Lippm an had been doing business togetherforover20 years.

8. ln January 2015, Lippman contacted M ellen and told him Scott B.

MEYROW ITZ,ajewelry dealerin Florida,had a customerforthe Diamond and wanted

to take it''on m em o''or'on consignm ent.''In the Diam ond trade the term s S
'on m em o''or

''on consignm ent''are understood to have the sam e particularm eaning.W hen the dealer

9ives m erchandise to anotherdealer 'on m em o'

'or ''on consignm ent'',the recipient is

custom arily required to sign a docum ent,called a m em orandum ,stating thathe is taking

possession ofthe m erchandise solely to show it,thatthe item rem ains the property ofthe
Case 9:18-mj-08431-DLB Document 1 Entered on FLSD Docket 10/15/2018 Page 4 of 11

owner,and acknowledging thatthe recipienthas no rightto sellorencum berit.A m emo

typically includes a 'stated value''w hich is the am ountthatthe recipientm ustpay to the

ownerin damages ifthe itemts)is Iostorstolen. Ifthe recipientwants to buy the item
afterhe takes iton memo (typically because he believes he has found a customer),he
notifies the ownerofthe goods (known as the 'dmemo holdern).In this case,Lippman
vouched forM EYROW ITZ'S trustwodhiness.

THE M EMO AG REEM ENT

9. M ellen and M EYROW ITZ began having conversations via em ailregarding

the possible sale ofthe diam ond,and on January 23,2015 Mellen sentM EYROW ITZ a

m em orandum forthe Diam ond m ade outto M EYROW ITZ and SSB International,w hich

is M EYROW ITZ'S com pany.The mem o stated thatMellen was sending the Diam ond to

M EYROW ITZ ''only forinspection by prospective purchasers,upon the express condition

thatthe Diam ond shallrem ain propedy ofBen Mellen & Sons,Inc.and has to be returned

on dem and.In itsfulloriginalform .''ltalso stated thatM EYROW ITZ and SSB International

would acquire no rightorauthority to sell,pledge,hypothecate orotherwise dispose of

the Diam ond.The m em o stated thatitcannotbe varied by oralstatem ent,am ong other

instructions.

10. Before the Diam ond wasshipped,M EYROW ITZ had signed the agreem ent.

O n January 23,2015,M ellen shipped the Diam ond via Brinks to the W ells Fargo branch

in Florida where M EYROW ITZ had a safety depositbox. Brinks'records state thatW ells

Fargo received the Diam ond on January 26,2015.

On Decem ber8,2014 M EYROW ITZ contacted David Goldstein,ownerof

Biltm ore Loan and Jewelry,and asked ifG oldstein would Iend a clientofMEYROW ITZ'S

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$1 million for60 to 90 days againsta 4-plus caratflawless blue Diamond. On January

23,2015,M EYROW ITZ told Goldstein thathis clientwould contactGoldstein.

THE PAW NING O F THE DIAM O ND

12. Joseph G utekunstwas a friend ofM EYROW ITZ forover30 years w ho runs

a business nam ed Alleralt. Gutekunst Iives in M inneapolis. M EYROW ITZ recruited

G utekunstto pose as the ownerofthe Diam ond in orderto obtain the Ioanfrom Goldstein

by ''pawningd
' the Diam ond. Beginning on January 23, 2015, G utekunst m ade

representations that he was a client of M EYROW ITZ and began negotiations with

Goldstein to pawn the Diam ond.

13. Between Janual 27, 2015 and February 1, 2015, Goldstein m et with

M EYROW ITZ in Florida to inspectthe Diam ond.During these discussions,M EYROW ITZ

m aintained the false m isrepresentation that G utekunst was the actual owner of the

Diam ond. Afterseeing the Diamond,Goldstein contacted G utekunstand told him he had

seen the stone and had no problem withIoaning him $1m illion.Gutekunstand Goldstein
arranged to m eet at Biltmore's offices Iocated in Arizona to finalize the pawn of the

Diam ond.

14. M EYROW ITZ shipped the Diam ond to Biltm ore in Arizona, via Brinks,

w here itwas received attheir olices on February 2,2015.Afterthe pawn ticketwas

signed,Biltm ore officials noticed thatthe G IA cedification forthe Diam ond was a copy

and notthe original,as itshould have been.

15. The true ow ner of the Diam ond,Richard M ellen, still had the original

Gemologicallnstitute ofAmerica,Inc.(GIA)cedificate forthe Diamond ring.A diamond

cedificate, also known as a diam ond grading report, is issued by an accredited

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independent gemological Iaboratory. In addition to the Diam ond's carat weight and

m easurem ents,a cedificate includes grades forthe Diam ond's cut,colorand clarity,aII

ofwhich have an im pacton the marketvalue ofthe stone.

16. G oldstein sentthe Diam ond to Gutekunst and G utekunstthen sent itto

M EYROW ITZ via FedEx. M EYROW ITZ thensentitto GIA in orderto geta new diam ond

grading repod.GIA received the Diamond in February18,2015.MEYROW ITZ paid$747

ficate orgrading report. On February 23,2015,M EYROW ITZ recei
forthe new cedi ved

the Diam ond back from G IA with the new GIA grading repod. O n that sam e date,

M EYROW ITZ sentthe Diam ond to Goldstein via Brinks.

O n M arch 2,2015,G utekunstpersonally delivered the grading repod,or

cedificate,to Goldstein atBiltm ore's office in Phoenix,Arizona.O n thatday,the Diam ond

was pledged as collateralfora pawn Ioan in G utekunst's nam e. The nextday,M arch 3,

2015, Biltmore wired $1 million to Gutekunst's personalaccount atW ells Fargo in

Minnesota.Upon receiving the wire,Gutekunstwithdrew $955,000 and made a deposit
of$955,000 into MEYROW ITZ'SSSB International's accountatW ells Fargo.
18. O n March 5,2015,M EYROW ITZ purchased a cashier's check at W ells

Fargo and deposited the check into his Scottrade Account,underhis wife's name. After

Gutekunstreceived the $1million from Biltmore,he staded making the m onthly interest
payments to Biltmore for$40,000. MEYROW ITZ supplied the funds forthese interest
payments to Gutekunstto in turn pay Biltm ore between April2015 and October2015.

19. In Novem ber2015,Goldstein offered to buy the Diam ond from G utekunst

for$1.3 million.Goldstein contacted MEYROW ITZ and asked him to convince Gutekunst

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to acceptthe offer.M EYROW ITZ and G oldstein agreed thatM EYROW ITZ would receive

25% ofthe profits from the subsequentre-sale ofthe Diamond.

20. O n Novem ber17,2015,Biltm ore boughtthe Diamond from Gutekunst,with

the understanding that G utekunstwas the true owner of the Diam ond.Biltm ore w ired

$250,000to Gutekunst.The nextday,Gutekunstwired $225,000 to MEYROW ITZ'SSSB

InternationalaccountatTD Bank.

21. O n Septem ber24,2018,M EYROW ITZ was interviewed by SpecialAgents

of the FBI. M EYROW ITZ adm itted his involvem ent in the pawning and sale of the

Diam ond. MEYROW ITZ acknowledged thathe was supposed to keep the ring in a safety

depositbox and was notauthorized to pawn the ring orto sellitoutright.He said thathe

was aware thatthe ring was never supposed to be in the possession of Gutekunst.

M EYROW ITZ acknowledged thathe Iied repeatedly and that he was notauthorized to

receive any assets orpaym entsforthe selling ofthe ring,northe pawning ofthe ring. He

stated thathe gotcaughtup in his Iies and he m ade m istakes.

22. M EYROW ITZ told agents thathe acted alone and said thathe thoughtthat

he would be able to make m oney in the stock m arketand otherdeals and he would be

able to make everyone whole. He was notable to do that.

THE EXECUTIO N O F THE W IRE FRAUD SC HEM E

23. Beginning on M arch 27,2015, Richard Mellen and Scott M EYROW ITZ

exchanged a series ofem ails wherein Mellen was requesting the return ofthe Diamond.

M EYROW ITZ continued to delay and distractM ellen by offering excuses forwhy he had

notreturned the Diamond orsecured a buyerforit.These em ails continued untilatIeast

May 28,2015.

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24. As partschem e to fraudulently acquire and laterto sellthe Diam ond which

he did notown,on April8,2015,M EYROW ITZ caused an emailto be sentvia interstate

wiresfrom Palm Beach Countyto Richard Mellen in New York,NY,wherein M EYROW ITZ

falsely stated thathe would schedule a Brinks pick up ofthe Diam ond:

''Richard. Icalled to find outw hattim e the truck from Brinks would be there
since Ihave to be there physically to sign offand give package to driver. l
called backto reschedule IW illreschedule.And Iwillhave som e paperwork
thatwillbe sentto you to finalize purchase and m ake everyone com fortable.
Scott''

25. As M EYROW ITZ wellknew,atthattim e he did nothave possession ofthe

Diam ond since he had already pawned it,nordid he have any intention ofshipping itback

to Richard Mellen as requested.

CONCLUSIO N

26. Based on the information provided in this affidavit,youraffiantsubm its that

there is probable cause to believe that beginning as early as January 2015 through

approximately Novem ber2015,in Palm Beach County,in the Southern DistrictofFlorida,

and elsewhere,Scott Bradley M EYROW ITZ did know ingly,and with intentto defraud,

devise and intend to devise a schem e and adifice to defraud and to obtain m oney and

propedy from Mellen, lnc. by m eans of m aterially false and fraudulent pretenses,

representationsand prom ises,knowing thatthe pretenses,representations and prom ises

were false and fraudulentwhen m ade,and in orderto execute the schem e to defraud,

did knowingly transm itand cause to be transm itted,by m eans ofw ire com m unication in

interstate and foreign

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Case 9:18-mj-08431-DLB Document 1 Entered on FLSD Docket 10/15/2018 Page 9 of 11

com m erce,cedain writings,signs,signals,pictures and sounds,in violation ofTitle 18,

United States Code,Section 1343.

*'
p 1 -..
.'

SpecialAgent
FederalBureau ofInvestigation

Sworntobefore methis /J- dayofOctober2018 atW estPalm Beach, Florida.

W
DAVE L E BRANNO N
UNITED STATES MAG ISTRATE JUDG E

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Case 9:18-mj-08431-DLB Document 1 Entered on FLSD Docket 10/15/2018 Page 10 of 11

UNITED STATES DISTRICT CO URT

SO UTHERN DISTRICT O F FLORIDA

PENALTY SHEET

Defendant's Nam e: SCO TT BRADLEY M EYROW ITZ

Case No:

Count#:1

W ire Fraud

18 U.S.C.5 1343

*Max.penalty: 20 Years Imprisonment'

,3 Years Supervised Release;$250,000 Fine

ARefersonlyto qossibleterm ofincarceration,doesnotincludepossiblefines,

restitution,speclalassessm ents,parole term s,orforfeitures thatm ay be applicable.
Case 9:18-mj-08431-DLB Document 1 Entered on FLSD Docket 10/15/2018 Page 11 of 11

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 18-8431-DLB

UNITED STATES OF AMERICA

v.

SCOTT BRADLEY MEYROWITZ,

Defendant,
--------------------------~'
CRIMINAL COVER SHEET

1. Did this matter originate from a matter pending in the United States Attorney's
OfficepriortoAugust9,2013(Mag.JudgeAiiciaValle)? _ _ Yes X No

2. Did this matter originate from a matter pending in the Northern Region of the ·
United States Attorney's Office prior to August 8, 2014 (Mag. Judge Shaniek
Maynard)? _ _ Yes X No

Respectfully submitted,

ARIANA FAJARDO ORSHAN

NITED STATES ATTORNEY

BY:
L N E. JO
ASSISTANT U ED STATES ATTORNEY
Florida Bar No. 726885
500 S. Australian Ave, Ste. 400
West Palm Beach, Florida 33401
TEL (561) 820-8711
FAX (561) 820-8777 .
Lauren .Jorgensen@usdoj.gov