U.S. v. Meghrouni, Shaver and Hoss Ltd., Inc.

UNITED STATES OF AMERICA,

Plaintiff,

v.

MARC MEGHROUNI,
SCOTT D. SHAVER, and
HOSS LIMITED, INC.,
d/b/a PARADISE CASINO,

Defendants.

The United States Attorney charges that:

Beginning in 1995 and continuing through at least Spring 1998, in the Eastern District of Missouri, the Central District of California, the Middle District of Florida, the Northern District of Georgia, the District of Nevada, the Cayman Islands, Antigua, the Netherlands Antilles, the Turks and Caicos Islands, the Republic of Ireland, the Isle of Man, and elsewhere,

the defendants herein, with others known and unknown, did corruptly endeavor to obstruct or impede the due administration of the Internal Revenue Code by the Internal Revenue Service, in particular that agency's exercise of its lawful statutory and regulatory responsibilities in the accurate ascertainment, assessment, and collection of excise taxes and/or of excise tax information, forms and reports pertaining to wagering;

In violation of Title 26, United States Code, Section 7212.

The United States Attorney further charges that:

Beginning in 1995, and continuing through at least Spring 1998, in the Eastern District of Missouri, the Central District of California, the Middle District of Florida, the Northern District of Georgia, the District of Nevada, the Cayman Islands, Antigua, the Netherlands Antilles, the Turks and Caicos Islands, the Republic of Ireland, the Isle of Man, and elsewhere,

the defendants herein, with others known and unknown, as a continuing course of conduct, while engaged in the business of betting and wagering, did as a part of that business knowingly use or cause to be used a wire communication facility, to wit: telephone lines in the United States, to transport in interstate or foreign commerce bets and wagers, and information which assisted in the placing of bets and wagers, on sporting events and sporting contests; each defendant then knowing that the transmissions using the wire communication facility began in one state and ended in another or, more frequently, began in one nation and ended in another; In violation of Title 18, United States Code, Section 1084.

The United States Attorney further charged that:

During or about a time period beginning in approximately November 1995, and continuing through approximately March 1997, in the Eastern District of Missouri, the Central District of California, the Middle District of Florida, the Northern District of Georgia, the District of Nevada, the Cayman Islands, Antigua, the Netherlands Antilles, the Turks and Caicos Islands, the Republic of Ireland, the Isle of Man, and elsewhere,

the defendant herein, did aid and abet, as a continuing course of conduct, a financial transaction involving the purchase of real estate at 2501 Alton Parkway, Irvine, California, and at 922 East Oceanfront, Unit 2, Balboa, California, doing so with money that was proceeds of specified unlawful activity, to wit: recurring violation of Title 18, United States Code, Section 1084 (the Wire Wager Act) , knowing that the money represented the proceeds of some form of unlawful activity, and intending to promote the carrying on of the specified unlawful activity violating Title 18, United States Code, Section 1084 and to engage in conduct violating Title 26, United States Code, Sections 7201 and 7206,

In violation of Title 18, United States Code, section 1956(a) (1) (A) (i) and (ii).

1.The allegations of Count Three of this Information are hereby realleged and incorporated by reference as if here fully set forth for the purpose of alleging forfeiture to the United States pursuant to the provisions of Title 18, United States Code, Section 982.

2. As a result of the offense alleged in Count Three of this Information,

the defendant herein, its officers, directors, employees and agents, including Marc Meghrouni, and Scott D. Shaver, shall forfeit to the United States the following real and personal property involved in and proceeds of the aforesaid offense, or which traceable to property involved in and proceeds of such offense:

A.The real property consisting of:

All the improvement, appurtenant attachments and real property located at assessor's parcel #435-061-15, located in the City of Irvine, County of Orange, State of California, commonly known by the street address of 2501 Alton Parkway, and legally described as assessor' s parcel #435-061-15, and further described as: "Parcel 2, as shown on a parcel map filed in Book 80, pages 19 and 20 of parcel maps in the Office of the County Recorder of said county.

"Except all oil, oil rights, minerals, mineral rights, natural gas, natural gas rights, and other hydrocarbons by whatsoever name known that may be within or under the parcel of land herein above described, together with the perpetual right of drilling, mining, exploring and operating therefor, and storing in and removing the same from said land or any other land, including the right to whipstock or directionally drill and mine from lands other than those herein above described, oil or gas wells, tunnels and shafts into, through or across the subsurface of the land herein above described, and to bottom such whipstocked or directionally drilled wells, tunnels and shafts under and beneath or beyond the exterior limits thereof, and to redrill, retunnel, equip, maintain, repair, deepen and operate any such wells or mines, without, however, the right to drill, mine, store, explore and operate through the surface of the upper 500 feet of the subsurface of the land herein above described, as reserved in the deed from Irvine Industrial Complex, a California Corporation, recorded September 21, 1973 in Book 10910, page 385 of official records.

B. The real property consisting of: A condominium, as defined in Sec-.ion 783 of the California Civil Code, in fee as to Parcel (a) and (b) and an Easement more particularly described as Parcel (c), commonly known as 922 East Oceanfront, Balboa, California 92661, and more particularly described as:

Parcel A:

An undivided 1/2 interest in and to Parcel I of Parcel Map 85-385, in the City of Newport Beach, County of Orange, State of California, as per map recorded in Book 218, pages 9 and 10 of parcel maps, in the Office of the County Recorder of said county.

Except therefrom the following:

(A) Units 1 and 2 as shown and defined upon the Condominium Plan recorded February 23, 1987 as Instrument No. 87-095812, Official Records of said County.

(B) The exclusive right to use of all those areas designated as balconies, patios and garages as shown upon the Condominium plan referred to above.

Parcel B:

Unit 2 as shown upon the condominium plan above referred to.

Parcel C:

The exclusive right to use of those portions of Parcel 1 described in Parcel A above, designated as B-2, P-2 and G-2 as appurtenant to Parcels 1 and B above described.

C. A motor vehicle, to wit: one 1995 Lamborghini Diablo, VIN ZA9D407FXSLA12370.

D. If any of the property described above as being subject to forfeiture

(1) cannot be located upon the exercise of due diligence;

(2) has been transferred, sold to, deposited with or encumbered by a third person;

(3) has been placed beyond the jurisdiction of the Court;

(4) has been substantially diminished in value; and/or

(5) has been commingled with other property which cannot be subdivided without difficulty;

and if said condition (1) - (5) exists as a result of any act or omission of any defendant herein, it is the intent of the United States pursuant to Title 18, United States Code, Section 982(b) (1) to seek forfeiture of any other property of any corporate or individual defendant, named in this information, up to and possibly in excess of the value of the above forfeitable property;

In violation of Title 18, United States Code, Section 982 (a) (1)

MICHAEL W. REAP
United States Attorney

MICHAEL K. FAGAN
Assistant United States Attorney

1114 Market Street, Room 421
St. Louis, Missouri- 63101
(314) 539-6851