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‘4091 ev. 1182) CRIMINAL COMPLAINT UNITED STATES DISTRICT COURT CENTRAL DISTR DOCKETNO, UNITED STATES OF AMERICA v. MICHAEL J. AVENATTI Complaint for violations of Title 18, United States Code, Sections 1343 and 1344(1) [NAME OF MAGISTRATE JUDGE UNITED STATES LOCATION HONORABLE DOUGLAS F. MCCORMICK MAGISTRATE JUDGE | Santa Ana, California DATEOF OFFENSES PLACE OF OFFENSE, "ADDRESS OF ACCUSED UF KNOWN) 7 Beginning in.or around Orange County and | 10000 Santa Monica Boulevard, Unit 2205, January 2014 and continuing | Los Angeles County | Los Angeles, California 90067 ‘through in or around March 2019 ‘COMPLAINANT'S STATEMENT OF FACTS CONSTITUTING THE OFFENSE OR VIOLATION: (See attached Complaint’s Statement of Facts Constituting the Offense or Violation which is incorporated as part of this Complaint) [BASIS OF COMPBAINANTS CHERLGE AGAINST THE ACCUSED: (See attached Affidavit which is incorporated as part of this Complaint) [MATERIAL WITNESSES IN RELATION TO Tas CHARGE: N/A [- SIGNATURE OF COMPLAINANT Being duly sworn, I declare that the 12 foregoing is true and correct to the best | Remoun Karlous |" of my knowledge. OFFICIAL TITLE : i Special Agent, Internal Revenue Service ~ Criminal Investigation ‘Sworn to before me and subscribed in my presence, SIGNATURE OF MAGISTRATE TUDOR | pate 7 CK DOUGLAS F. McCORMI March 22, 2019 07 Sag Fela Rus of Cina Proceed 37 AUSAs Julian L. André 213.894.6683 and Brett A. Sagel 714.338.3598 REC: Detention Complaint’s Statement of Facts Constituting the Offense or Violation COUNT ONE [18 U.S.c. § 1344(1)] Beginning in or about January 2014, and continuing through in or about April 2016, in Orange County, within the Central District of California, and elsewhere, defendant MICHAEL J. AVENATTI (“AVENATTI”), together with others known and unknown, knowingly and with intent to defraud, executed and attempted to execute a scheme to defraud The Peoples Bank as to material matters. on or about December 12, 2014, in Orange County, within the Central District of California, and elsewhere, defendant AVENATTI, together with others known and unknown, committed and willfully caused others to commit the following act, which constituted an execution of, or an attempt to execute, the fraudulent scheme: (1) wire transfer of approximately $494,500 from The Peoples Bank in Biloxi, Mississippi, to a California Bank & Trust bank account in the name of Eagan Avenatti LLP in Irvine, California. COUNT TWO [18 U.S.C. § 1343] Beginning as early as in or around December 2017 and continuing through in or around March 2019, in Los Angeles and orange Counties, within the Central District of California, and elsewhere, defendant MICHAEL 3. AVENATTI (“AVENATTI”), knowingly and with intent to defraud, devised participate in, and executed a scheme to defraud clients to whom defendant AVENATTI had agreed to provide legal services, as to material matters, and to obtain money and property from his legal clients by means of material false and fraudulent pretenses, representations, and promises, and the concealment of material facts. on or about January 5, 2018, in Los Angeles and Orange counties, within the Central District of California, and elsewhere, defendant AVENATTI, for the purpose of executing the above-described scheme to defraud, transmitted or caused the transmission of the following items by means of wire communication in interstate and foreign commerce: (1) wire transfer of approximately $1,600,000 sent from Silicon Valley Bank through the interstate Fedwire system to defendant AVENATTI's City National Bank attorney trust account in Los Angeles, California.