Case 9:18-cr-80216-DMM Document 21 Entered on FLSD Docket 12/13/2018 Page 1 of 9

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLO RIDA

Case No. I8-8OZI6-CR-M IDDLEBROO KS/BRANNO N

UNITED STATES O F AM ERICA,

VS.

SCOTT B.MEYROW ITZ,

Defendant.

PLEA AGREEM ENT

The United StatesofAmerica and ScottB.Meyrowitz (hereinafterreferred to as

thedefendant)enterinto thefollowing agreement:

The defendantagrees to plead guilty to Count1 of the lnform ation,which

charges him with wire fraud,in violation ofTitle 18,United States Code,Section 1343.

2. The United States and the defendantstipulate and agree thatthe attached

FactuafBasis is a true and accurate description of the relevant offense conductand

accordingly constitutes the defendant's relevant conduct under Section 1B1.3 of the

Sentencing G uidelines.
3. The defendantis aware thatthe sentence willbe im posed by the Courtafter

considering the FederalSentencing Guidelines and Policy Statements (hereinafter

Sentencing Guidelines). The defendantacknowledges and understandsthatthe Court
will com pute an advisory sentence under the Sentencing Guidelines and that the

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applicable guidelines willbe determined by the Courtrelying in parton the results ofa

Pre-sentence Investigation by the Courts probation office, which investigation will

comm ence afterthe guilty plea has been entered. The defendantis also aware that,

under certain circum stances, the Court m ay depart from the advisory sentencing

guideline rangethatithascomputed,and mayraise orlowerthatadvisorysentence under

the Sentencing Guidelines. The defendantis furtheraware and understands thatthe

Court is required to consider the advisory guideline range determined under the

Sentencing Guidelines,butis notbound to im pose thatsentence'

,the Courtis perm itted

to tailorthe ultim ate sentence in lightofotherstatutory concerns,and such sentence m ay

be eitherm ore severe orIess severe than the Sentencing G uidelines advisory sentence.

Knowing these facts,the defendantunderstands and acknowledgqs thatthe Courthas

the authority to im pose any sentence up to the statutory m axim um authorized by law for

the offenses identified in paragraph 1 and thatthe defendantm ay notw ithdraw the plea

solely as a resultofthe sentence imposed.

The defendantalso understands and acknowledges that the Court may

im pose a m axim um penalty of up to 20 years im prisonm ent. In addition to any term of

imprisonm ent,the Courtmay im pose a term ofsupervised release ofupto 3 years and a

fine ofup to $250,000,and is required to orderrestitution.

5. The defendantfurtherunderstands and acknowledges that,in addition to any

sentence imposed under paragraph 4 ofthis agreement,a specialassessment in the

amount of $100 willbe imposed on the defendant. The defendant agrees that any
specialassessm entim posed shallbe paid atthe tim e ofsentencing.

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6. The Office ofthe United States Attorney forthe Southern DistrictofFlorida

(hereinafterOffice)reservesthe rightto inform the Courtand the probation office ofaII

facts pertinentto the sentencing process,including alIrelevantinformation concerning

the offenses comm itted,whethercharged ornot,aswellasconcerningthe defendantand

the defendant's background. Subjectonly to the express terms ofany agreed-upon

sentencing recom mendationscontained in this agreement,thisOffice furtherreservesthe

rightto make any recom m endation as to the quality and quantity ofpunishm ent.

The United States agrees that itwillrecom mend atsentencing thatthe

Coud reduce by two Ievels the sentencing guideline Ievelapplicable to the defendant's

offense,pursuantto Section 3E1.1(a)ofthe Sentencing Guidelines,based upon the

defendant's recognition and a#irmative and tim elyacceptance ofpersonalresponsibili
ty.

Ifatthe time ofsentencing the defendant'soffense levelisdetermined to be 16 orgreater,

the governm entwillm ake a motion requesting an additionalone Ieveldecrease pursuant

toSection3E1.1(b)oftheSentencingGuidelines,statingthatthe defendanthasassisted
authorities in the investigation orprosecution ofhis own m isconductby tim ely notifying

authori
ties ofhis intention to entera plea ofguilty,thereby permitting the governmentto
avoid preparing fortrialand perm i
tting the governmentand the Courtto allocate their

resources efficiently. The United States,however,willnotbe required to m ake this

motion and these recommendations i

fthe defendant:(1)failsorrefusesto make afull,
accurate and com plete disclosure to the probation office of the circumstances

surroundingtherelevantoffenseconduct'
,(2)isfoundtohavemisrepresentedfactstothe
governmentpriorto entering into this plea agreement'
,or(3)commits any misconduct
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afterentering into this plea agreem ent,including butnotIim ited to comm itting a state or

federal offense, violating any term of release, or making false statements or

m isrepresentations to any governm entalentity orofficial.

8. The United States and defendant agree that,although not binding on the

probationofficeortheCourt,theywilljointlyrecommendthattheCourtmakethefollowing
findings and conclusions asto the sentence to be im posed:
a. Base Offense Level: That the base offense Ievelis 7,pursuant to

Section2B1.1(a)(1)ofthe Sentencing Guidelines,

'
b. Value of the Loss: That the relevant am ount of actual, probable Or

intended loss resulting from the offense is $1.3 million,which is m ore than $550,000 but
less than $1.5 million, resulting in an 14-level enhancem ent, pursuant to Section

2B1.1(b)(1)(I)and 1B1.3ofthe SentencingGuidelines'

,
Restitution: That the defendant acknowledges and agrees to pay

restitution in an amountto be determ ined by the Court,payable through the Clerk ofthe

Courtto the victims Iisted in a separate ListofFraud Victims.

d. Voluntarv Surrender: That the parties will recomm end that the

defendantbe perm itted to voluntarilysurrenderathisdesignated facility in 60 days,rather

than be remanded atthe time ofsentencing.

9. Otherthan the specificagreementscontained in paragraph 8,the parties agree
thatboth sides retain the rightto m ake specific sentencing recom m endations pursuantto

statute and the Sentencing Guidelines. The defendantspecifically reserves the rightto
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advocate for a dow nw ard variance in his sentence pursuant to Title 18,United States

Code,Section 3553.

10. The defendant i

s aw are thatthe sentence has not yet been determ ined by

the Court. The defendantalso is aware thatany estim ate ofthe probable sentencing

range orsentence thatthe defendantmay receive,whetherthatestim ate com es from the

defendant's attorney,the government, or the probation olice, is a prediction, not a

prom ise,and is notbinding on the government,the probation office orthe Court. The

defendantunderstands furtherthatany recomm endation thatthe governm entm akes to

the Courtas to sentencing,whether pursuant to this agreement or otherwise,is not

binding on the Courtand the Courtm ay disregard the recom m endation in its entirety.
The defendant understands and acknowledges, as previously acknowledged in

paragraph 3 above,thatthe defendant may notwithdraw the defendant's guilty plea

based upon the Court's decision notto accepta sentencing recom m endation made by

the defendant,the government,orarecommendationjointlymade by boththedefendant

and the governm ent.

This agreem entand understanding between the United States and the

defendantisthe entire agreem entbetween the United Statesand the defendant.

There are no otheragreements,prom ises,representations,orunderstandings unless

Case 9:18-cr-80216-DMM Document 21 Entered on FLSD Docket 12/13/2018 Page 6 of 9

contained in a letterfrom the United States Attorney's Office executed by alIpartiesand

counselpriorto the change ofplea.

ARIANA FAJARDO O RSHAN

UNITED STATES ATTO RNEY

Dat
e: 7,,./s
,a
By:
/

LAUREN E.JORGENSEN
ASSIST T UNITE STATES ATTORNEY

Date: lc/.
37,
# I
ROBERT ADLER,ESQ .
ATTO RNEY FOR DEFENDANT

oate:t2 3 lo I: Y
scoTT B.M EYROw ITz,Eso.
ATTO RNEY FoR DEFENDANT

lhave read and carefully reviewed every partofthis Agreem entwith my attorney,and l
voluntarily agree to its term s. No one hasthreatened orcoerced m e in anyway into
entering into this A greem ent.

oate:ï)- ! zolz = #
SCOTT B.MEYROW ITZ
DEFENDA NT

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UNITED STATES v.SCOTT B.M EYROW ITZ

FACTUAL PROFFER IN SUPPORT OF G UILTY PLEA
DefendantSCOTT B.MEYROW ITZ adm its thatthe governmentcould prove the
following facts beyond a reasonable doubt,through adm issible evidence and testimony,
ifthis case had proceeded to trial.
THE M EM O AGREEMENT
AtaIlrelevant times,SCOU BRADLEY MEYROW ITZ was a resident of Palm
Beach County,and owned and operated SSB lnternationalin Florida.
On January23,2015,defendantMEYROW ITZ signed a memorandum witha New
York City diamond wholesaler(the ''Owner''),in which MEYROW ITZ agreed to take
temporary possession of a 4.05 carat flawless heart-shaped blue diamond (the
uDiamond'')forthepurposeoffindingabuyerinFlorida.TheOwnerisawholesaledealer
ofdiamonds and jewelry thatspecializes in colored and otherhigh-quali
ty diamonds
valuedatmorethan amilliondollarswho had previouslypurchasedthe Diamondfor$1.3
rnillion.
M EYROW ITZ was notauthorized to sell,paWn,ortake any otheraction with the
Diam ond,otherthan to identify a buyerand pass the inform ation on to the O w ner.The
mem orandum stated thatthe Ownerwas sending the Diam ond to MEYROW ITZ ''onlyfor
inspection by prospective purchasers,upon the expresscondition thatthe Diam ond shall
remain propedy of'the Ownér.Italso stated thatM EYROW ITZ and SSB International
would acquire no rightorauthority to sell,pledge,hypothecate orotherwise dispose of
the Diamond.The m em ostated thatitcould notbevaried by oralstatement,among other
instructions.Pursuantto the m em orandum agreem ent,the Ownershipped the Diamond
to M EYROW ITZ via Brinks GlobalServices.
THE PAW NING AND SALE OF THE DIAMO ND
M EYROW ITZ recruited a friend who Iived in Minneapolis known as 'J.G.,''to pose
as the ownerofthe Diamond in orderto obtain a Ioan from a Scottsdale,Arizona,pawn
shop thatspecialized inhighendjewelry.
Between January 27,2015 and February 2,2015,MEYROW ITZ met with the
ownerofthe pawn shop in Florida and afterinspection ofthe Diam ond,the pawn shop
agreed to Ioan J.G.$1 million and arranged to meetJ.G.atthe pawn shop's offices
Iocated in Arizona to finalize the pawn ofthe Diamond.
After the pawn ticketwas signed,the pawn shop noticed thatthe Gem ological
Institute ofAmerica,Inc.(GIA) certification forthe Diamond was a copy and notthe
original,as itshould have been. MEYROW ITZ obtained a new G lA certificate forthe
Diam ond ring ata costof$747,as proofofthe authenticity and value ofthe Diamond.ln
addition to a diamond's caratweightand m easurements,a cedi
ficate includes gradesfor
Case 9:18-cr-80216-DMM Document 21 Entered on FLSD Docket 12/13/2018 Page 8 of 9

the diamond's cut,colorand clarity,allofwhich have an impacton the marketvalue of

the stone.
Once the new G IA certificate was in place,M EYROW ITZ directed J.G.to pledge
the Diamond as collateralfora pawn Ioan in J.G .'s name. On March 3,2015,the pawn
shop wired $1 million to J.G.'S personal account at W ells Fargo in Minnesota.
MEYROW ITZ directedJ.G.towi thdraw $955,000 ofthe $1millionand deposititintothe
accountofSSB International,M EYROW ITZ'S company.
InNovember2015,the pawnshop agreed to buy theDiamond from J.G.for$1.3
million and to pay M EYROW ITZ 25% ofthe profits from any subsequentre-sale ofthe
Diam ond. To com plete the sale,the pawn shop ownerwired $250,000 to J.G. At
MEYROW ITZ'S direction,J.G .then wired $225,000 to the SSB lnternationalaccount,
controlled by M EYROW ITZ.
During the course ofthe schem e,MEYROW ITZ responded to inquiries from the
Ownerregarding the status ofthe Diam ond by making a series offalse claim s,including
thata buyerhad been found butm ore time was necessary,thatthere was no buyerand
the Diamond would be on itsway to the Ownershortly,and thatshipping the Diamond
had failed forvarious reasons.
THE EXECUTION OF THE W IRE FRAUD SCHEM E
On April8,2015,MEYROW ITZ caused an emailto be sentvia interstate wires
from Palm Beach County to the Ownerin New York,NY,wherein M EYROW ITZ falsely
stated thathe would schedule a Brinks pick up ofthe Diamond:
lcalled to find outw hattim e the truck from Brinks w ould be
there since lhave to be there physically to sign offand give
package to driver. I called back to reschedule l W ill
reschedule. And Iw illhave som e paperwork thatw illbe sent
to you to finalize purchase and m ake everyone comfortable.
Scott
However,as MEYROW I TZ wellknew,atthattim e he did nothave possession of
the Diamond since he had already pawned it,nordid he have any intention ofshipping it
backto the Owneras requested.
On Septem ber24,2018,M EYROW ITZ was interviewed by SpecialAgents ofthe
FederalBureau oflnvestigation.M EYROW ITZ admitted his involvem entin the pawning
and sale ofthe Diamond. MEYROW ITZ acknowledged thathe was supposed to keep
the ringin a safety depositbox and wasnotauthorized to pawnthering orto sellitoutright.
He said thathe was aware thatthe ring was neversupposed to be in the possession of
J.G .MEYROW ITZ acknowledged thathe Iied repeatedly and thathe was notauthorlzed
to receive any assets orpaymentsforthe selling ofthe ring,northe pawning ofthe ring.
He stated thathe gotcaughtup in his Iies and he m ade m istakes.

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M EYROW ITZ explained to the agentsthathe acted alone and said thathe thought
thathe would be able to make money in the stock marketand otherdeals and he would
be able to make everyone whole. He did not.

RELEVANT CO NDUCT
The relevant amount of actual, probabde or intended loss resulting from the
executionoftheschemeto defraud is$1.3million.

ARIANA FAJARDO ORSHAN

UNITED STATES AU ORNEY

Date: / J By:
UREN E.JORG ENSEN
ASSIST UNITED ATES AU ORNEY

Date: Ii ()1-
3
ROBERT ADLER,ESQ.
AU ORNEY FO R DEFENDANT

Dat
e:jk/r),
t
yo(/ SCOU>BM EYROW
.
V ITZ
AU ORNEY FOR DEF DANT

lhave read and carefullyreviewed everypartofthis FactualProfferwith my attorney,and

Ivoluntarily agree to its terms, No one has threatened orcoerced me in any way into
signing this FactualProffer.

Date: k )0l-.
b /
c TT B.MEYROW ITZ
DEFENDANT