Exhibit D — Sworn affidavit of IRS Special Agent Timothy Nugent:
Victim Statements
8. Clarence Enge
Amy Von Freyman stated that her grandfather, Clarence Enge, who is in his 80s, received letters via the United States mail from companies soliciting his participation in foreign lotteries.
Since 1997, Enge had sent $600-$1200/month to such companies, including to OLD AMSTERDAM and SHAMROCK AGENCY. In order to continue his participation he refinanced his home.
9. Paul Greven
A letter addressed to Greven stating it is an "Official Announcement of Winning Tickets in the 2003 Irish Sweepstake Triple Crown." The letterhead indicated it was from "The Shamrock Agency" and claimed it had been a "Certified Service since 1959." The letter stated: "Millionaires by the score! We have just finished round one of the verification process of the Triple Crown 118 major Jackpot winning tickets. Enclosed is a list of the winning numbers. Congratulations to the jackpot winners.. . ." The letter informed Greven to be patient for "round 2 of the winning verification process" but encouraged him not to "... delay in getting the 'Jump' on next year's Triple Crown millions (order form enclosed)." It also stated that the Triple Crown was unlike any other lottery because players could be sure there is no ". . . 'Inside corruption' or 'secret trick' . . . ." The letter was signed by "Sir William Winfield, Northup Manor, Shannon Ireland."
10. Paul Wood
When interviewed, Paul Wood stated that he had been involved with WORLD EXPERT for about five years. He had played lotteries with them and obtained a form of life insurance from WORLD EXPERT. Woods stated the insurance from WORLD EXPERT FUND was known as the "Gold Reserve Fund." For this he sent $29 per month to the Netherlands to pay for retirement/life insurance. Statements he had received showed that he had approximately $4,000 in his account.
13. In furtherance of the scheme to defraud, the following mailings, among many others, were sent by the companies run by SONNY VLEISIDES and his co-schemers, to victims of the scheme:
Proceeds to describe the fraudulent letters; [ a, b, c, d, e, f, g, h, i, j, k ]
The letters are clearly fraudulent, like some snail mail 419 scam, that no non-senile person should fall for. The exhibits are dating from the years 2002 to 2006.
18. When interviewed, PJ and Michael Swink stated the following:
a. PJ Swink stated that her company, Western Internet, worked for Sonny VLEISIDES. The work PJ Swink did for VLEISIDES included printing as well as stuffing and mailing envelopes. VLEISIDES gave her instructions regarding the preparing, printing, and mailing of lottery solicitations. Western Internet had done this work for VLEISIDES, or his father, "Rex Rogers," since 1993. Since 2000, all of the work PJ Swink had done for VLEiSIDES and "Rex Rogers" had been related to the lottery.
b. PJ Swink was unaware of the exact name of VLEISIDES' company, because it has had multiple names over the years. Based on conversations and other communications with VLEISIDES over the years, she believed "The Shamrock Agency" and "World Expert" were companies related to VLEISIDES. She believed VLEISIDES also used the name "Atlas Informaticos."
Michael Swink stated that VLEISIDES told him that VLEISIDES was a licensed broker for these companies in Europe. PJ Swink and Michael Swink have met VLEISIDES in person.
c. PJ Swink provided a business card with contact information for VLEISIDES. The information on the card said "SONNY VLEISIDES." The address was in Costa Rica. The email address was sonnv[-BAD-OCR-]city.com . However, PJ Swink later identified a further email address for VLEISIDES of
sonnv@atlasinformaticos.com.
20. Henry Walther, who has pled guilty to one count of mail fraud and one count of money laundering and is cooperating with the United States government, stated the following when interviewed:
a. Henry Walther explained that the main people involved in the lottery were Houston, VLEISIDES, and Dennis Emmett. The business started with Houston and Emmett. Houston was the principal behind it. Cloud is Houston's brother or halfbrother, and lives in Amsterdam. About five years ago, Houston and Dennis Emmett got into an argument and split their businesses. Then, Houston and VLEISIDES got into an argument, and VLEISIDES took over the business.
b. For the last five to ten years, Henry Walther has been working as an accountant/banker and attorney for VLEISIDES and Houston, who he also knows as "Rex Vieisides" and "Rex Rogers." Henry Walther explained that VLEISIDES and Houston resided in Costa Rica. Henry Walther explained that Houston and VLEISIDES operated a mail solicitation business involving foreign lotteries and horse racing. Two of the companies they use were The Shamrock Agency and World Expert Fund. Houston and VLEISIDES instructed Henry Walther to open and maintain bank accounts in the United States because the banking system was too slow in Costa Rica.
21. Glenda Emmet, when interviewed, stated the following:
a. Emmett was the owner of Astro Computer, which operated a mail list business. This included maintaining lists and preparing the letters to be mailed out by a mail house.
b. For five or six years, her only customer was Global Search Network, which was run by her ex-husband, Dennis Emmett. Dennis Emmett is now in prison in Costa Rica for murder, but was still issuing instructions to her from prison. Before she worked for Global Search Network, she worked for World Expert Fund. That company was owned by VLEISIDES. Her ex-husband, Dennis Emmett, worked with World Expert Fund for some time in Costa Rica.
Search Warrant Evidence26. On July 6, 2006, several search warrants were executed at addresses in California, Georgia, and Missouri. The searches yielded the following evidence, as well as other information:
a. A computer belonging to co-schemer Scott Walther contained documents and emails involving the scheme. The emails were between VLEISIDES and co-schemer Henry Walther and Scott Walther. Some of the emails were addressed to "Sonny" with an email of
Sonny@atlasinformaticos.com (identified as VLEISIDES' email address by other participants in the scheme, while others were addressed to "Sonny Vleisides" with the same email address. Specific examples of documents and emails are as follows:
i. A word processing document stating:
This is a fraud that has been going on for many years. Millions of dollars have been stolen from people that cannot afford it. The mailings originate from Little Rock, AR-cancelled at 722. The mail then goes to . . . Amsterdam in the Netherlands. From there it is sent by DHL to . . . Costa Rica. Atlas Informaticos to be held for pick up at the DHL office... The master mind behind this scam is James Ray Houston apx. 60 years old. He gained fame in 1974 when he ran for Governor in Nevada.
His accomplice is Sonny Vleisides apx. 30 years old. Both from Kansas City originally .... However, these guys are very slick and try very hard not put their names on anything. A Russian by the name of Mikhstl Larguine has been used as Houston's front man for most of the 10 years plus that Houston has been in Costa Rica. Houston has used many aliases over the years. Rex Rogers was the longest lasting.
ii. An email dated November 1, 2002, from Henry Walther to Sonny at an email address of
sonny@atlasinformaticos.com with a "cc" to Scott Walther, shows a thread of discussion regarding establishing a new bank account and company offshore since accounts were being closed in the United States. At one point Henry Walther asks VLEISIDES "What goals do you want to accomplish by getting the accounts offshore. I think it is to keep the account from being shut down by the US banking system. Any other goals?" VLEISIDES responds saying "The only objective is to have an account with less vulnerability from any US authority. Also depending on how the account works for the Mexican bank-it may be more difficult for the bank to deal with canceling an account that's co-mingled with all their other accounts in the US-because it's all really just one account to them." In an earlier thread, Henry Walther had written: "Dear Sonny: Today Scott set up a new EU American Payment Services account at Union Bank. I will get the information to you tomorrow, but since PJ [Swink, a participant in the scheme, as described above] has Scott's facsimile signature and also the Union Bank has been handling the North American account, it should be easy to set up once she has the account number."
c. At an address in Georgia that was under the control of co-schemer William Cloud through a woman named Mary McRae, relevant evidence including the following was found:
i. Thousands of credit card "Mail Order Forms" that listed names and credit card numbers. On the bottom of many of the forms was "Euro American."
ii. Western Union receipts for money wired by McRae, in Georgia, USA, to "Sonny Velisides" in Costa Rica. The dates and amounts were as follows: August 11, 2004 - $2200, August 5, 2004 - $1200, July 9, 2004 - $3300, July 2, 2004 - $2000, and June 24, 2004 - $2000.
27. SONNY VLEISIDES is a United States citizen born on February 21, 1971, in Las Vegas, Nevada. He is a white male, who is 1.8 meters tali and was last known to weigh approximately 70 kilograms. He has black hair and hazel eyes. He was issued a United States passport, number 701797046, on May 23, 1989, in New Orleans, Louisiana. A photograph of VLEISIDES is attached as Exhibit 1 to my affidavit.
28. Henry Walther has identified the photograph attached as Exhibit 1 to this affidavit as being a photograph of the same SONNY VLEISIDES who ran the fraudulent lottery scheme discussed in this affidavit.
Timothy Nugent, Special Agent
Internal Revenue Service -
Criminal Investigations Division
Subscribed to and sworn before me this 9 day of May, 2007
HONORABLE SUZANNE H. SEGAL
United States Magistrate Judge
The photo attached to the extradition document:
