in the supreme court of florida case number …myfloridalegal.com/indictmentcarlowetal.pdf · state...

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IN THE SUPREME COURT OF FLORIDACASE NUMBER SC02-2645

STATE OF FLORIDA, SEVENTEENTH STATEWIDE JURYGRAND JURY INDICTMENT NO. 1

Plaintiff, vs. BROWARD CO. CASE NO.

MICHAEL CARLOW, (A) OSWP CASE NO.: 2002-0052FLLCANDACE CARLOW, (B)THOMAS ATKINS, JR., (C)MARILYN ATKINS, (D)HENRY GARCIA, (E)FABIAN DIAZ, (F)JOEL DE LA OSA, (G) DAVID EBANKS, (H) a/k/a Julius TaylorJOSE L. BENITEZ, (I)DARIEL TABARES, (J) MICHAEL E. BURMAN, (K)LAZARO VILARCHAO, (L)IVAN VILARCHAO, (M)JOSEPH VILLANUEVA, (N)ARTURO GODINEZ, (O)TOM MARTINO, (P)JULIO CESAR CRUZ, (Q) a/k/a Ricardo Garcia,GISELA GONZALEZ, (R)

Defendants._________________________________/

INDICTMENT FOR:

COUNT 1: COUNT 2:Racketeering (F1) Conspiracy to Commit Racketeering (F1)F.S. 895.02(4) F.S. 895.03(4)Defendants A-Q Defendants A-Q

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COUNT 3: COUNT 4:Organized Scheme to Defraud (F1) Grand Theft (F1)F.S. 817.034(4)(a)1 F.S. 812.014(1), (b), (2)(a)1Defendants A-R Defendants A & F

COUNT 5: COUNT 6:Dealing In Stolen Property (F2) Sale or Delivery of a Controlled Substance (F3)F.S. 812.019(1) F.S. 893.13(1)(a)(2) and 893.03(3)(f)Defendants A & F Defendant A

COUNTS 7-12, 15, 19: COUNT 13:Possession with Intent to Sale and Delivery of a Controlled Substance Sell Legend Drugs (F3) F.S. 893.13(1)(a)(2) and 893.03(3)(f) (F3)F.S. 499.03(1) Defendant ADefendant A

COUNTS 14 COUNTS 16 & 17:Possession with Intent to Purchase or Receipt of a Legend Sell Legend Drugs (F3) Drug from Unauthorized Person (F3)F.S. 499.03(1) F.S. 499.005(14)Defendants A, C, E, G, Defendant A

COUNT 18 COUNT 20:Possession with Intent to Possession with Intent to Sell Legend Drugs Sell Legend Drugs (F3) F.S. 499.03(1) (F3)F.S. 499.03(1) Defendants A & J Defendant H

COUNTS 21-26 COUNTS 27-32:Possession with Intent to Purchase or Receipt of a Legend Drug Sell Legend Drugs (F3) from Unauthorized Person (F3)F.S. 499.03(1) F.S. 499.005(14)Defendants L, M, N Defendant P

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IN THE NAME AND BY THE AUTHORITY OF THE STATE OF FLORIDA

COUNT 1Racketeering

The GRAND JURORS of the Seventeenth Statewide Grand Jury for the State of Florida, duly

called, impaneled and sworn to inquire and true presentment make, upon their oaths, do present and

charge that beginning on or about April 5, 2001, and continuing through and including on, or about,

July 1, 2003, in the Ninth, Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial Circuits of

Florida, to wit: Orange, Miami-Dade, Palm Beach, Broward, and Martin Counties, Florida, as part

of a related transaction occurring in two or more judicial circuits, the defendants, MICHAEL

CARLOW, CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY

GARCIA, FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE

L. BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO,

IVAN VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and

JULIO CESAR CRUZ, a/k/a Ricardo Garcia, and others known and unknown to the GRAND

JURY, while employed by or associated with an enterprise, as defined in section 895.02(3), Florida

Statutes, to wit: BTC Wholesale, Inc., a Florida corporation; G&K Pharma, LLC.; a Maryland

corporation; Complete Wholesale, Inc.; a Maryland corporation; Accucare, LLC, a Florida

corporation; JB Pharmaceuticals, Inc., a Texas corporation; and Pormis Wholesale Distributors,

Inc., a Texas corporation; acting together with a group of individuals, associated in fact, although

not a legal entity, to wit: Michael Carlow, Candace Carlow, Thomas Atkins, Jr., Marilyn Atkins,

Henry Garcia, Fabian Diaz, Joel De La Osa, David Ebanks, Jose L. Benitez, Dariel Tabares, Michael

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E. Burman, Lazaro Vilarchao, Ivan Vilarchao, Joseph Villanueva, Pamela Walter, Mark Novosel,

Arturo Godiñez, Mark Siegel, and Tom Martino, and, in furtherance of which enterprise, said

persons did unlawfully, willfully and knowingly conduct or participate in the affairs of said

enterprise, directly or indirectly, through a continuous pattern of racketeering activity as defined by

section 895.02(4), Florida Statutes, by committing crimes chargeable by Indictment under Title 18,

United States Code, Sections 1341, 1343, and Chapter 812, Florida Statutes, and by engaging in at

least two of the following incidents of racketeering activity which had similar intents, results,

accomplices, victims or methods of commission, or were otherwise related by distinguishing

characteristics, and were not isolated incidents, including, but not limited to:

Predicate 1A:Grand Theft

Beginning on or about January 16, 2002, and continuing through, and including, January 20,

2002, in Miami-Dade and Broward Counties, Florida, MICHAEL CARLOW and FABIAN DIAZ

did knowingly and unlawfully obtain or use, or endeavored to obtain or use, legend drugs as defined

in section 499.003(19), Florida Statutes, said property being the property of another, to wit: Bio-Med

Plus, Inc., a Florida corporation, of a value of $100,000 or more, with the intent to either temporarily

or permanently appropriate the property to their own use or to the use of another person not entitled

thereto, contrary to section 812.014(1),(b),(2)(a)1, Florida Statutes.

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Predicate 1BDealing in Stolen Property

On or about January 20, 2002, in Miami-Dade and Broward Counties, Florida, MICHAEL

CARLOW and FABIAN DIAZ did knowingly and unlawfully traffic in or endeavor to traffic in

property to wit: legend drugs, as defined in section 499.003(19), Florida Statutes, that they knew or

should have known were stolen, contrary to section 812.019(1), Florida Statutes.

Predicate 2Mail Fraud

On or about August 31, 2001, in Broward County, Florida, MICHAEL CARLOW,

CANDACE CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA,

FABIAN DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L.

BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN

VILARCHAO, JOSEPH VILLANUEVA, ARTURO GODIÑEZ, TOM MARTINO, and

JULIO CESAR CRUZ, a/k/a Ricardo Garcia having devised a scheme to defraud prescription

drug consumers residing inside and outside the state of Florida by selling into the wholesale

prescription drug market what was purported to be pure, genuine and unadulterated prescription

drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,

stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons,

illegally imported into the United States, stored in unlicensed facilities, or sold with false, fraudulent

or forged documentation, did, for the purpose of executing such scheme or attempting to do so, cause

to be delivered by mail, according to the direction thereon, a certain letter from the Florida

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Department of Health, Tallahassee, Florida, to Optia Medical, Las Vegas, Nevada, contrary to 18

U.S.C. §1341.


On or about January 3, 2002, in Miami-Dade County, Florida, MICHAEL CARLOW,








drugs, when in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,




to be delivered by mail, according to the direction thereon, a certain letter from Lane C. Reedman,

El Paso, Texas, to Fabian Diaz, c/o Oasis Management, Miami, Florida, contrary to 18 U.S.C.§1341.

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On or about June 21, 2002, in Miami-Dade County, Florida, MICHAEL CARLOW,








drugs when, in fact, the said prescription drugs were at different times either counterfeit, relabeled,




to be delivered by mail, according to the direction thereon, a certain letter from David Ebanks, a/k/a

Julius Taylor, Miami, Florida, to Lori Barrera, Corpus Christi, Texas, contrary to 18 U.S.C. §1341.


On April 5, 2001, in Broward County, Florida, MICHAEL CARLOW, CANDACE

CARLOW, THOMAS ATKINS, JR., MARILYN ATKINS, HENRY GARCIA, FABIAN

DIAZ, JOEL DE LA OSA, DAVID EBANKS, a/k/a Julius Taylor, JOSE L. BENITEZ,

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DARIEL TABARES, MICHAEL E. BURMAN, LAZARO VILARCHAO, IVAN


JULIO CESAR CRUZ having devised a scheme to defraud prescription drug consumers residing

inside and outside the state of Florida by selling into the wholesale prescription drug market what

was purported to be pure, genuine and unadulterated prescription drugs when, in fact, the said

prescription drugs were, at different times, either counterfeit, relabeled, stolen, illegally purchased

from Medicaid recipients, illegally purchased from unlicensed persons, illegally imported into the

United States, stored in unlicensed facilities, or sold with false, fraudulent or forged documentation,

did, for the purpose of executing such scheme or attempting to do so, deposit or cause to be

deposited, a package to be sent or delivered by a private or commercial interstate carrier, to wit:

Federal Express, from AmeRx, Inc., Oakland Park, Florida, to Albers Medical, Inc., Kansas City,

Missouri, contrary to 18 U.S.C. §1341.


On September 11, 2002, in Palm Beach County, Florida, MICHAEL CARLOW,







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or forged documentation, did, for the purpose of executing such scheme or attempting to do so,

deposit or cause to be deposited, a package to be sent or delivered by a private or commercial

interstate carrier, to wit: United Parcel Service (UPS), from Accucare, Boynton Beach, Florida, to

Albers Medical, Kansas City, Missouri, contrary to 18 U.S.C.§1341.


On October 22, 2002, in Palm Beach County, Florida, MICHAEL CARLOW, CANDACE








drugs when, in fact, the said prescription drugs, were at different times, either counterfeit, relabeled,



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interstate carrier to wit: United Parcel Service (UPS), from Four Points Wholesale, Boynton Beach,

Florida, to Albers Medical, Kansas City, Missouri, contrary to 18 U.S.C.§1341.


On November 11, 2002, in Palm Beach County, Florida, MICHAEL CARLOW,













interstate carrier, to wit: United Parcel Service (UPS), from Four Points Wholesale, Boynton Beach,

Florida, to Albers Medical, Kansas City, Missouri, contrary to 18 U.S.C. §1341.

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On December 18, 2002, in Palm Beach County, Florida, MICHAEL CARLOW,













interstate carrier, to wit: United Parcel Service (UPS), from G & K Pharma, Boynton Beach, Florida,

to Albers Medical, Kansas City, Missouri, contrary to 18 U.S.C. §1341.


On March 27, 2003, in Miami-Dade County, Florida, MICHAEL CARLOW, CANDACE


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interstate carrier, to wit: United Parcel Service (UPS), from David Ebanks, a/k/a Julius Taylor,

Miami, Florida, to Albers Medical, Inc., Kansas City, Missouri, contrary to 18 U.S.C.§1341.


On May 19, 2003, in Broward County, Florida, MICHAEL CARLOW, CANDACE






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interstate carrier, to wit: United Parcel Service (UPS), from G & K Pharma, Miami, Florida, to

Pormis Wholesale & Distribution, Laredo, Texas, contrary to 18 U.S.C.§1341.

Predicate 12 Mail Fraud

On or about February 14, 2003, in Broward County, Florida, MICHAEL CARLOW,










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cause to be delivered by private or commercial interstate carrier, to wit: United Parcel Service

(UPS), according to the direction thereon a certain package from Albers Medical, Kansas City,

Missouri, to Medcom Pharmaceutical Wholesale Drugs, Jensen Beach, Florida, contrary to 18 U.S.C.

§1341.


On or about October 29, 2002, in Miami-Dade County, Florida, MICHAEL CARLOW,











or forged documentation, for the purpose of executing such scheme or attempting to do so, did cause

to be delivered by private or commercial interstate carrier to wit: Federal Express according to the

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direction thereon a certain letter from David Ebanks, a/k/a Julius Taylor, in Miami, Florida, to

Chavey Real Estate, Corpus Christi, Texas, contrary to 18 U.S.C.§1341.

Predicate 14Wire Fraud








prescription drug market what was purported to be genuine, unadulterated and legitimately acquired

prescription drugs when, in fact, the said prescription drugs were, at different times, either

counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from

unlicensed persons, illegally imported into the United States, stored in unlicensed facilities, or sold

with false, fraudulent or forged documentation, did, for the purpose of executing such scheme or

attempting to do so, transmit or caused to be transmitted by means of wire in interstate commerce,

writings, signs, signals, pictures or sounds, to wit: a facsimile transmission (fax) from Lori Marvel

in Wanatah, Indiana, to Michael Carlow in Weston, Florida, contrary to 18 U.S.C. §1343.

16


On or about June 27, 2002, in Broward County, Florida, MICHAEL CARLOW,





JULIO CESAR CRUZ, a/k/a Ricardo Garcia, having devised a scheme to defraud prescription








writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount of

$1,482,102.62 from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank

of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.

at Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.

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On or about July 3, 2002, in Broward County, Florida, MICHAEL CARLOW,














$750,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens

National Bank in Seiverville, Tennessee, to account number 30333145805 in the name of GD

Medical at Ocean Bank in Miami, Florida, contrary to 18 U.S.C. §1343.

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National Bank in Seiverville, Tennessee, to account number 3200052822 in the name of Medical

Dynamics at Citibank in Miami, Florida, contrary to 18 U.S.C. §1343.

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$677,600.00 from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank



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prescription drugs when, in fact, the said prescription drugs were, at different times either




attempting to do so, transmit or caused to be transmitted by means of wire in interstate or foreign

commerce, writings, signs, signals, pictures or sounds, to wit: a wire transfer of funds in the amount

of $900,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens

National Bank in Seiverville, Tennessee, to account number 7061-0 in the name of Serra Morena

Import Export at Banco do Brazil in Brazil, South America, contrary to 18 U.S.C. §1343.

22


On or about September 9, 2002, in Broward County, Florida, MICHAEL CARLOW,











with false, fraudulent or forged documentation, did for the purpose of executing such scheme or




National Bank in Seiverville, Tennessee, to account number 9660148926 in the name of Lighthouse

Capital Inv at Union Planters Bank in Coral Gables, Florida, contrary to 18 U.S.C. §1343.

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$41,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens National

Bank in Seiverville, Tennessee, to account number 3892010831 in the name of Tina Investments at

Washington Mutual Bank in Miami, Florida, contrary to 18 U.S.C. §1343.

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On or about November 18, 2002, in Broward County, Florida, MICHAEL CARLOW,

















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Capital Inv at Union Planters in Coral Gables, Florida, contrary to 18 U.S.C. §1343.

26
















$1,382,321.15 from account 003937132789 in the name of G&K Pharma, LLC, at the Bank of

America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc. at

Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.

27


On or about December 9, 2002, in Broward County, Florida, MICHAEL CARLOW,

















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29



















30

















National Bank in Seiverville, Tennessee, to account number 2000192288149 in the name of

Proteknika do Brazil at Banco Bilbao Vizcaya, in Argentina, South America, contrary to 18 U.S.C.

§1343.

31



















32



















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On or about January 9, 2003, in Broward County, Florida, MICHAEL CARLOW,














$2,038,452.00, from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank

of America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc.,


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of $900,000.00, from account number 00-93207 in the name of Pharma Medical, Inc., at Citizens


Comercializadora E & I at Multicredit Bank Panama, in Panama, Central America, contrary to 18

U.S.C. §1343.

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Predicate 35Sale or Delivery of a Controlled Substance

Beginning on or about January 20, 2002, in Broward County, Florida, MICHAEL

CARLOW, did knowingly and unlawfully sell or deliver, or possess with intent to sell or deliver,

a controlled substance, to wit: Dronabinol (synthetic THC), in violation of sections 893.13(1)(a)(2)

and 893.03(3)(f), Florida Statutes.

Predicate 36Possession with Intent to Sell or Deliver a Controlled Substance

Beginning on or about February 15, 2002, in the Seventeenth Judicial Circuit, to wit:

Broward County, Florida, MICHAEL CARLOW, did knowingly and unlawfully possess, with

intent to sell or deliver, a controlled substance, to wit: Phentermine Hydrochloride, in violation of

sections 893.13(1)(a)(2) and 893.03(3)(f), Florida Statutes.

All in violation of section 895.03(3), Florida Statutes.

COUNT 2Conspiracy to Commit Racketeering



charge that beginning on or about April 5, 2001, and continuing through and including July 1, 2003,

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in the Ninth, Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial Circuits of Florida, to wit:

Orange, Miami-Dade, Palm Beach, Broward and Martin Counties, Florida, as part of a related

transaction, the Defendants, MICHAEL CARLOW, CANDACE CARLOW, THOMAS

ATKINS, JR., MARILYN ATKINS, HENRY GARCIA, FABIAN DIAZ, JOEL DE LA OSA,

DAVID EBANKS, JOSE L. BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN,

LAZARO VILARCHAO, IVAN VILARCHAO, JOSEPH VILLANUEVA, ARTURO

GODIÑEZ, TOM MARTINO, and JULIO CESAR CRUZ, a/k/a Ricardo Garcia, did

unlawfully and knowingly combine, conspire, confederate and agree each with the other and others

known and unknown to violate the laws of Florida, to-wit: section 895.03(3), Florida Statutes,

prohibiting racketeering, thereby committing crimes chargeable by indictment or information under

Chapter 812, Florida Statutes, and Title 18, United States Code, Sections 1341 and 1343, by

engaging in two or more predicate incidents which would have similar intents, results, accomplices,

victims or methods of commission, or would otherwise be related by distinguishing characteristics

and would not be isolated incidents, or by otherwise participating in the affairs of the enterprise with

the knowledge and intent that other members of the conspiracy would engage in at least two

incidents of racketeering activity. As part of said conspiracy, the above-named defendants were

employed by, or associated with, an enterprise consisting of BTC Wholesale, Inc., a Florida

corporation; G&K Pharma, LLC., a Maryland corporation; Complete Wholesale, Inc., a Maryland

corporation; Accucare, LLC, a Florida corporation; JB Pharmaceuticals, Inc., a Texas corporation;

and Pormis Wholesale Distributors, Inc., a Texas corporation; acting together with a group of

individuals, associated in fact, although not a legal entity, to wit: Michael Carlow, Candace Carlow,

Thomas Atkins, Jr., Marilyn Atkins, Henry Garcia, Fabian Diaz, Joel De La Osa, David Ebanks, Jose

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L. Benitez, Dariel Tabares, Michael E. Burman, Lazaro Vilarchao, Ivan Vilarchao, Joseph

Villanueva, Pamela Walter, Mark Novosel, Arturo Godiñez, Mark Siegel, and Tom Martino, and

one or more members of the conspiracy did engage or intend to engage in at least two of the

following incidents:

Predicate 1A:Grand Theft

Beginning on or about January 16, 2002, and continuing through, and including, January 20,

2002, in Miami-Dade and Broward Counties, Florida, MICHAEL CARLOW and FABIAN DIAZ






Predicate 1BDealing in Stolen Property

On or about January 20, 2002, in Miami-Dade and Broward Counties, Florida, MICHAEL

CARLOW and FABIAN DIAZ did knowingly and unlawfully traffic in or endeavor to traffic in

property to wit: legend drugs, as defined in section 499.003(19), Florida Statutes, that they knew or

should have known were stolen, contrary to section 812.019(1), Florida Statutes.

39


On or about August 31, 2001, in Broward County, Florida, MICHAEL CARLOW,












to be delivered by mail, according to the direction thereon, a certain letter from the Florida

Department of Health, Tallahassee, Florida, to Optia Medical, Las Vegas, Nevada, contrary to 18

U.S.C. §1341.

40


On or about January 3, 2002, in Miami-Dade County, Florida, MICHAEL CARLOW,








drugs, when in fact, the said prescription drugs were, at different times, either counterfeit, relabeled,




to be delivered by mail, according to the direction thereon, a certain letter from Lane C. Reedman,

El Paso, Texas, to Fabian Diaz, c/o Oasis Management, Miami, Florida, contrary to 18 U.S.C.§1341.


On or about June 21, 2002, in Miami-Dade County, Florida, MICHAEL CARLOW,


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drugs when, in fact, the said prescription drugs were at different times either counterfeit, relabeled,




to be delivered by mail, according to the direction thereon, a certain letter from David Ebanks, a/k/a

Julius Taylor, Miami, Florida, to Lori Barrera, Corpus Christi, Texas, contrary to 18 U.S.C. §1341.


On April 5, 2001, in Broward County, Florida, MICHAEL CARLOW, CANDACE





JULIO CESAR CRUZ having devised a scheme to defraud prescription drug consumers residing

inside and outside the state of Florida by selling into the wholesale prescription drug market what

42

was purported to be pure, genuine and unadulterated prescription drugs when, in fact, the said

prescription drugs were, at different times, either counterfeit, relabeled, stolen, illegally purchased

from Medicaid recipients, illegally purchased from unlicensed persons, illegally imported into the

United States, stored in unlicensed facilities, or sold with false, fraudulent or forged documentation,

did, for the purpose of executing such scheme or attempting to do so, deposit or cause to be

deposited, a package to be sent or delivered by a private or commercial interstate carrier, to wit:

Federal Express, from AmeRx, Inc., Oakland Park, Florida, to Albers Medical, Inc., Kansas City,

Missouri, contrary to 18 U.S.C. §1341.


On September 11, 2002, in Palm Beach County, Florida, MICHAEL CARLOW,











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interstate carrier, to wit: United Parcel Service (UPS), from Accucare, Boynton Beach, Florida, to

Albers Medical, Kansas City, Missouri, contrary to 18 U.S.C.§1341.


On October 22, 2002, in Palm Beach County, Florida, MICHAEL CARLOW, CANDACE








drugs when, in fact, the said prescription drugs, were at different times, either counterfeit, relabeled,





interstate carrier to wit: United Parcel Service (UPS), from Four Points Wholesale, Boynton Beach,

Florida, to Albers Medical, Kansas City, Missouri, contrary to 18 U.S.C.§1341.

44


On November 11, 2002, in Palm Beach County, Florida, MICHAEL CARLOW,













interstate carrier, to wit: United Parcel Service (UPS), from Four Points Wholesale, Boynton Beach,

Florida, to Albers Medical, Kansas City, Missouri, contrary to 18 U.S.C. §1341.


On December 18, 2002, in Palm Beach County, Florida, MICHAEL CARLOW,


45












interstate carrier, to wit: United Parcel Service (UPS), from G & K Pharma, Boynton Beach, Florida,

to Albers Medical, Kansas City, Missouri, contrary to 18 U.S.C. §1341.


On March 27, 2003, in Miami-Dade County, Florida, MICHAEL CARLOW, CANDACE






46








interstate carrier, to wit: United Parcel Service (UPS), from David Ebanks, a/k/a Julius Taylor,

Miami, Florida, to Albers Medical, Inc., Kansas City, Missouri, contrary to 18 U.S.C.§1341.


On May 19, 2003, in Broward County, Florida, MICHAEL CARLOW, CANDACE










47




interstate carrier, to wit: United Parcel Service (UPS), from G & K Pharma, Miami, Florida, to

Pormis Wholesale & Distribution, Laredo, Texas, contrary to 18 U.S.C.§1341.

Predicate 12 Mail Fraud













cause to be delivered by private or commercial interstate carrier, to wit: United Parcel Service

(UPS), according to the direction thereon a certain package from Albers Medical, Kansas City,

48

Missouri, to Medcom Pharmaceutical Wholesale Drugs, Jensen Beach, Florida, contrary to 18 U.S.C.

§1341.


On or about October 29, 2002, in Miami-Dade County, Florida, MICHAEL CARLOW,











or forged documentation, for the purpose of executing such scheme or attempting to do so, did cause

to be delivered by private or commercial interstate carrier to wit: Federal Express according to the

direction thereon a certain letter from David Ebanks, a/k/a Julius Taylor, in Miami, Florida, to

Chavey Real Estate, Corpus Christi, Texas, contrary to 18 U.S.C.§1341.

49















writings, signs, signals, pictures or sounds, to wit: a facsimile transmission (fax) from Lori Marvel

in Wanatah, Indiana, to Michael Carlow in Weston, Florida, contrary to 18 U.S.C. §1343.

50


On or about June 27, 2002, in Broward County, Florida, MICHAEL CARLOW,

















51

















National Bank in Seiverville, Tennessee, to account number 30333145805 in the name of GD

Medical at Ocean Bank in Miami, Florida, contrary to 18 U.S.C. §1343.

52

















National Bank in Seiverville, Tennessee, to account number 3200052822 in the name of Medical

Dynamics at Citibank in Miami, Florida, contrary to 18 U.S.C. §1343.

53



















54
















$677,600.00 from account number 003937132789 in the name of G&K Pharma, LLC, at the Bank



55










prescription drugs when, in fact, the said prescription drugs were, at different times either







National Bank in Seiverville, Tennessee, to account number 7061-0 in the name of Serra Morena

Import Export at Banco do Brazil in Brazil, South America, contrary to 18 U.S.C. §1343.

56













with false, fraudulent or forged documentation, did for the purpose of executing such scheme or






57
















$41,000.00 from account number 00-93207 in the name of Pharma Medical, Inc. at Citizens National

Bank in Seiverville, Tennessee, to account number 3892010831 in the name of Tina Investments at

Washington Mutual Bank in Miami, Florida, contrary to 18 U.S.C. §1343.

58



















59


















Capital Inv at Union Planters in Coral Gables, Florida, contrary to 18 U.S.C. §1343.

60
















$1,382,321.15 from account 003937132789 in the name of G&K Pharma, LLC, at the Bank of

America in Laurel, Maryland, to account number 00-93207 in the name of Pharma Medical, Inc. at

Citizens National Bank in Seiverville, Tennessee, contrary to 18 U.S.C. §1343.

61



















62



















63



















64


















Proteknika do Brazil at Banco Bilbao Vizcaya, in Argentina, South America, contrary to 18 U.S.C.

§1343.

65



















66



















67



















68



















69
















of $900,000.00, from account number 00-93207 in the name of Pharma Medical, Inc., at Citizens


Comercializadora E & I at Multicredit Bank Panama, in Panama, Central America, contrary to 18

U.S.C. §1343.

70

Predicate 35Sale or Delivery of a Controlled Substance

Beginning on or about January 20, 2002, in Broward County, Florida, MICHAEL

CARLOW, did knowingly and unlawfully sell or deliver, or possess with intent to sell or deliver,

a controlled substance, to wit: Dronabinol (synthetic THC), in violation of sections 893.13(1)(a)(2)

and 893.03(3)(f), Florida Statutes.

Predicate 36Possession with Intent to Sell or Deliver a Controlled Substance

Beginning on or about February 15, 2002, in the Seventeenth Judicial Circuit, to wit:

Broward County, Florida, MICHAEL CARLOW, did knowingly and unlawfully possess, with

intent to sell or deliver, a controlled substance, to wit: Phentermine Hydrochloride, in violation of

sections 893.13(1)(a)(2) and 893.03(3)(f), Florida Statutes.

All in violation of section 895.03(4), Florida Statutes.

COUNT 3Organized Scheme to Defraud



charge that beginning on or about April 5, 2001, and continuing through July 1, 2003, in the Ninth,

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Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade,

Palm Beach, Broward and Martin Counties, Florida, as part of a related transaction occurring in, or

in connection with, an organized criminal conspiracy affecting two or more judicial circuits of

Florida, the Defendants, MICHAEL CARLOW, CANDACE CARLOW, THOMAS ATKINS,

JR., MARILYN ATKINS, HENRY GARCIA, FABIAN DIAZ, JOEL DE LA OSA, DAVID

EBANKS, JOSE L. BENITEZ, DARIEL TABARES, MICHAEL E. BURMAN, LAZARO

VILARCHAO, IVAN VILARCHAO, JOSEPH VILLANUEVA, JULIO CESAR CRUZ, a/k/a

Ricardo Garcia, GISELA GONZALEZ, ARTURO GODIÑEZ, and TOM MARTINO did

knowingly engage in a scheme to defraud prescription drug users residing inside and outside the

State of Florida, through a systematic and ongoing course of conduct, by selling into the prescription

drug wholesale market, what was purported to be genuine, unadulterated and legitimately acquired



unlicensed persons, illegally imported into the United States, stored in unlicensed facilities or sold

with false, fraudulent or forged documentation. It was the intent and purpose of the various members

of the scheme to hide or disguise their true source of the prescription drugs they sold by engaging

in sham transactions, providing false documentation of the sales history of the prescription drugs and

placing straw men on the corporate papers of drug wholesale companies inside and outside the State

of Florida, and as a result of this scheme to defraud, the defendants did thereby obtain property with

an aggregate value of $50,000 or more, contrary to section 817.034(4)(a)1, Florida Statutes.

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COUNT 4Grand Theft



charge that beginning on or about January 16, 2002, and continuing through and including January

20, 2002, in the Eleventh and Seventeenth Judicial Circuits of Florida, to-wit: Miami-Dade and

Broward Counties, Florida, as part of a related transaction occurring in, or in connection with, an

organized criminal conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth,


Palm Beach, Broward and Martin Counties, Florida, MICHAEL CARLOW and FABIAN DIAZ,






COUNT 5Dealing in Stolen Property



charge that beginning on or about January 20, 2002, in the Eleventh and Seventeenth Judicial

Circuits of Florida, to-wit: Miami-Dade and Broward Counties, Florida, as part of a related

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transaction occurring in, or in connection with, an organized criminal conspiracy affecting two or

more judicial circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and Nineteenth

Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward and Martin Counties, Florida,

MICHAEL CARLOW and FABIAN DIAZ, did knowingly and unlawfully traffic in property, to

wit: legend drugs as defined in section 499.003(19), Florida Statutes that they knew, or should have

known, were stolen, contrary to section 812.019(1), Florida Statutes.

COUNT 6Sale or Delivery of a Controlled Substance



charge that beginning on or about January 20, 2002, in the Seventeenth Judicial Circuit, to wit:

Broward County, Florida, the Defendant, as part of a related transaction occurring in, or in

connection with, an organized criminal conspiracy affecting two or more judicial circuits of Florida,

to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange,

Miami-Dade, Palm Beach, Broward and Martin Counties, Florida, MICHAEL CARLOW, did

knowingly and unlawfully sell or deliver, or possess with intent to sell or deliver a controlled

substance, to wit: Dronabinol (synthetic THC), in violation of sections 893.13(1)(a)(2) and

893.03(3)(f), Florida Statutes.

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COUNT 7Possession with Intent to Sell Legend Drugs



charge that on or about April 5, 2001, in the Seventeenth Judicial Circuit, to wit: Broward County,

Florida, in connection with an organized criminal conspiracy affecting two or more judicial circuits,


Miami-Dade, Palm Beach, Broward and Martin Counties, Florida, the Defendant, MICHAEL

CARLOW, did knowingly and unlawfully possess with intent to sell, dispense or deliver a legend

drug as defined in section 499.003(19), Florida Statutes, to wit: Gamimune (immune globulin

intravenous), contrary to section 499.03(1), Florida Statutes.




charge that on or about January 16, 2002, and continuing through and including January 20, 2002

in the Ninth, Eleventh, Fifteenth and Seventeenth Judicial Circuits, to wit: Orange, Miami-Dade,

Palm Beach and Broward Counties, Florida, as part of a related transaction occurring in, or in



Miami-Dade, Palm Beach, Broward and Martin Counties, Florida, MICHAEL CARLOW, did

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knowingly and unlawfully possess with intent to sell, dispense or deliver a legend drug as defined

in section 499.003(19), Florida Statutes, to wit: Novoseven (coagulation factor VIIa), Hyprho-D

(immune globulin intravenous), Immune Globulin, Gamimune (immune globulin intravenous),

Gammagard (immune globulin intravenous), Iveegam (immune globulin intravenous-human),

contrary to section 499.03(1), Florida Statutes.




charge that on or about February 15, 2002, in the Ninth, Eleventh, Fifteenth and Seventeenth Judicial

Circuits, to wit: Orange, Miami-Dade, Palm Beach and Broward Counties, Florida, as part of a

related transaction occurring in, or in connection with, an organized criminal conspiracy affecting

two or more judicial circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and

Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward and Martin

Counties, Florida, MICHAEL CARLOW, did knowingly and unlawfully possess with intent to sell,

dispense or deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit:

Doxyclycline, contrary to section 499.03(1), Florida Statutes.

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dispense or deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit: Lactated

Ringer’s Injection Solution, contrary to section 499.03(1), Florida Statutes.








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Novocain (xylocaine hydrochloride), contrary to section 499.03(1), Florida Statutes.

COUNT12Possession with Intent to Sell Legend Drugs










Phentermine Hydrochloride, contrary to section 499.03(1), Florida Statutes.

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COUNT 13Sale or Delivery of a Controlled Substance



charge that beginning on or about February 15, 2002, in the Seventeenth Judicial Circuit, to wit:

Broward County, Florida, as part of a related transaction occurring in, or in connection with, an

organized criminal conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth,


Palm Beach, Broward and Martin Counties, Florida, the Defendant, MICHAEL CARLOW, did

knowingly and unlawfully sell or deliver, or possess with intent to sell or deliver a controlled

substance, to wit: Phentermine Hydrochloride in violation of sections 893.13(1)(a)(2) and

893.03(3)(f), Florida Statutes.




charge that on or about October 1, 2002 in the Fifteenth and Seventeenth Judicial Circuits, to wit:

Palm Beach and Broward Counties, Florida, as part of a related transaction occurring in, or in



Miami-Dade, Palm Beach, Broward and Martin Counties, Florida, the Defendants, HENRY

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GARCIA, JOEL DE LA OSA, MICHAEL CARLOW, THOMAS ATKINS, JR., did knowingly

and unlawfully possess with intent to sell, dispense or deliver a legend drug as defined in section

499.003(19), Florida Statutes, to wit: Procrit (epoetin alfa), 40,000 units per ML, contrary to section

499.03(1), Florida Statutes.




charge that on or about January 27, 2003, through and including February 6, 2003, in the

Seventeenth Judicial Circuit, to wit: Broward County, Florida, as part of a related transaction

occurring in, or in connection with, an organized criminal conspiracy affecting two or more judicial

circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial

Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward and Martin Counties, Florida, the

Defendant, MICHAEL CARLOW, did knowingly and unlawfully possess with intent to sell,

dispense or deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit: Zyprexa

(olanzapine), contrary to section 499.03(1), Florida Statutes.

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COUNT 16Purchase or Receipt of a Legend Drug

from Unauthorized Person




Circuits, to wit: Osceola, Miami-Dade, Palm Beach and Broward Counties, Florida, as part of a




Counties, Florida, the Defendant, MICHAEL CARLOW, did knowingly and unlawfully purchase

or receive a legend drug, to wit: Viracept (nelfinavir), Crixivan (indinavir sulfate), Combivir

(lamivudine/zidovudine), Trizivir (abacavir sulfate/lamivudine/zidovudine) , Diflucan (fluconazole),

Sustiva (efavirenz), Retrovir (zidovudine), Viramune (nevirapine), Viread (tenofovir disoproxil

fumarate), Epivir (lamivudine), Videx (didanosine), Ziagen (abacavir), from a person, to wit: Jose

L. Benitez, not authorized under Chapter 499, Florida Statutes, to distribute legend drugs, contrary

to section 499.005(14), Florida Statutes.

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Circuits, to wit: Osceola, Miami-Dade, Palm Beach and Broward Counties, Florida, as part of a




Counties, Florida, the Defendant, MICHAEL CARLOW, did knowingly and unlawfully purchase

or receive a legend drug, to wit: Viracept (nelfinavir), Crixivan (indinavir sulfate), Combivir

(lamivudine/zidovudine), Trizivir (abacavir sulfate/lamivudine/zidovudine) , Diflucan (fluconazole),

Sustiva (efavirenz), Viramune (nevirapine), Epivir (lamivudine), Videx (didanosine), Ziagen

(abacavir) from a person, to wit: Jose L. Benitez, not authorized under Chapter 499, Florida Statutes,

to distribute legend drugs, contrary to section 499.005(14), Florida Statutes.




charge that between or about January 24, 2003 and February 24, 2003, in the Seventeenth Judicial

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Circuit, to wit: Broward County, Florida, as part of a related transaction occurring in, or in



Miami-Dade, Palm Beach, Broward and Martin Counties, Florida, the Defendant, DAVID

EBANKS, a/k/a Julius Taylor, did knowingly and unlawfully possess with intent to sell, dispense

or deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit: Diflucan

(fluconazole) contrary to section 499.03(1), Florida Statutes.




charge that on or about April 11, 2003, in the Seventeenth and Nineteenth Judicial Circuits, to wit:

Broward and Martin Counties, Florida, as part of a related transaction occurring in, or in connection

wit, an organized criminal conspiracy affecting two or more judicial circuits of Florida, to wit: the

Ninth, Eleventh, Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-

Dade, Palm Beach, Broward and Martin Counties, Florida, the Defendant, MICHAEL CARLOW,

did knowingly and unlawfully possess with intent to sell, dispense or deliver a legend drug as defined

in section 499.003(19), Florida Statutes, to wit: Celebrex (celecoxib) and Lipitor (atorvastatin)


83




charge that on or about May 20, 2003, in the Eleventh and Seventeenth Judicial Circuits, to wit:

Miami-Dade and Broward Counties, Florida, as part of a related transaction occurring in, or in



Miami-Dade, Palm Beach, Broward and Martin Counties, Florida, the Defendants, DARIEL

TABARES and MICHAEL CARLOW, did knowingly and unlawfully possess with intent to sell,

dispense or deliver a legend drug as defined in section 499.003(19), Florida Statutes, contrary to

section 499.03(1), Florida Statutes.




charge that on or about January 24, 2002, in the Seventeenth Judicial Circuit, to wit: Broward

County, Florida, as part of a related transaction occurring in, or in connection with, an organized

criminal conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth, Eleventh,

Fifteenth, Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach,

Broward and Martin Counties, Florida, the Defendants, LAZARO VILARCHAO, IVAN

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VILARCHAO, JOSEPH VILLANUEVA, did knowingly and unlawfully possess with intent to

sell, dispense or deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit:

Epogen (epoetin alfa) contrary to section 499.03(1), Florida Statutes.




charge that on or about February 28, 2002, in the Seventeenth Judicial Circuit, to wit: Broward

County, Florida,as part of a related transaction occurring in, or in connection with, an organized






Procrit (epoetin alfa) contrary to section 499.03(1), Florida Statutes.




charge that on or about March 5, 2002, in the Seventeenth Judicial Circuit, to wit: Broward County,

85

Florida, as part of a related transaction occurring in, or in connection with, an organized criminal

conspiracy affecting two or more judicial circuits of Florida, to wit: the Ninth, Eleventh, Fifteenth,

Seventeenth and Nineteenth Judicial Circuits, to wit: Orange, Miami-Dade, Palm Beach, Broward

and Martin Counties, Florida, the Defendants, LAZARO VILARCHAO, IVAN VILARCHAO,

JOSEPH VILLANUEVA, did knowingly and unlawfully possess with intent to sell, dispense or

deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit: Epogen (epoetin

alfa) contrary to section 499.03(1), Florida Statutes.




charge that on or about March 11, 2002, in the Seventeenth Judicial Circuit, to wit: Broward







Epogen (epoetin alfa) contrary to section 499.03(1), Florida Statutes.

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charge that on or about March 18,2002, in the Seventeenth Judicial Circuit, to wit: Broward County,




and Martin Counties, Florida, the Defendants, LAZARO VILARCHAO, IVAN VILARCHAO,

JOSEPH VILLANUEVA, did knowingly and unlawfully possess with intent to sell, dispense or

deliver a legend drug as defined in section 499.003(19), Florida Statutes, to wit: Procrit (epoetin alfa)





charge that on or about March 20, 2002, in the Seventeenth Judicial Circuit, to wit: Broward





87



Panglobulin (immune globulin intravenous) contrary to section 499.03(1), Florida Statutes.





charge that on or about January 24, 2002, in the Seventeenth Judicial Circuit, to wit: Broward




Broward and Martin Counties, Florida, the Defendant, TOM MARTINO, did knowingly and

unlawfully purchase or receive a legend drug, to wit: Epogen (epoetin alfa) from a person, to wit:

Mark Novosel, not authorized under Chapter 499, Florida Statutes, to distribute legend drugs,


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charge that on or about February 28, 2002, in the Seventeenth Judicial Circuit, to wit: Broward




Broward and Martin Counties, Florida, the Defendant, TOM MARTINO, did knowingly and

unlawfully purchase or receive a legend drug, to wit: Procrit (epoetin alfa) from a person, to wit:

Mark Novosel, not authorized under Chapter 499, Florida Statutes, to distribute legend drugs,










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and Martin Counties, Florida, the Defendant, TOM MARTINO, did knowingly and unlawfully

purchase or receive a legend drug, to wit: Epogen (epoetin alfa) from a person, to wit: Mark Novosel,

not authorized under Chapter 499, Florida Statutes, to distribute legend drugs, contrary to section











purchase or receive a legend drug, to wit: Epogen (epoetin alfa) from a person, to wit: Mark Novosel,



90










purchase or receive a legend drug, to wit: Procrit (epoetin alfa) from a person, to wit: Mark Novosel,











91


purchase or receive a legend drug, to wit: Panglobulin (immune globulin intavenous) from a person,

to wit: Mark Novosel, not authorized under Chapter 499, Florida Statutes, to distribute legend drugs,


ALL OF SAID OFFENSES BEING AGAINST THE PEACE AND DIGNITY OF THESTATE OF FLORIDA.

JAMES ROSSForepersonSeventeenth Statewide Grand Jury of Florida

___________________Date

I, OSCAR GELPI, Assistant Legal Adviser, Seventeenth Statewide Grand Jury, and AssistantStatewide Prosecutor for the State of Florida, hereby certify that I, as such Prosecuting Officer andas authorized and required by law have advised the Grand Jury which returned this Indictment this day of July, 2003.

OSCAR GELPIAssistant Legal Adviser to theSeventeenth Statewide Grand JuryFlorida Bar Number 382345110 Southeast 6th Street, Suite 1400Ft. Lauderdale, Florida 33301(954)712-4950

92

I, ROBERT PENEZIC, Assistant Legal Adviser, Seventeenth Statewide Grand Jury, andAssistant Statewide Prosecutor for the State of Florida, hereby certify that I, as such ProsecutingOfficer and as authorized and required by law have advised the Grand Jury which returned thisIndictment this day of July, 2003.

ROBERT PENEZICAssistant Legal Adviser to theSeventeenth Statewide Grand JuryFlorida Bar Number 0064319110 Southeast 6th Street, Suite 1400Ft. Lauderdale, Florida 33301(954)712-4950

The foregoing Indictment was returned before me in open court this day of July,2003, and further, it is hereby sealed as to each defendant until their arrest, at which time it shall beunsealed (as to that defendant) without necessity of further Order of this Court. I hereby certify andorder the transfer of this Indictment to Miami-Dade County, Florida, pursuant to Florida Statute905.34.

HONORABLE DALE ROSSPresiding JudgeSeventeenth Statewide Grand Jury

Filed in the Circuit Court of the Eleventh Judicial Circuit, Miami-Dade County, Florida, this day of , 2003.

Clerk of the Circuit CourtDeputy Clerk

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Defendant Biographical Information

MICHAEL CARLOWDOB: 10/16/1952SSN: 263-04-6925Last Known Address: 3465 Windmill Ranch Road

Weston, FL 33331

CANDACE CARLOWDOB: 05/20/1971SSN: 197-66-9195Last Known Address: 3465 Windmill Ranch Road

Weston, FL 33331

THOMAS ATKINS, JR.DOB: 01/02/1967SSN: 205-62-3592Last Known Address: 1544 Regal Court

Kissimmee, FL 34744

MARILYN ATKINSDOB: 07/01/1945SSN: 205-36-5133Last Known Address: 7137 Lake Island Drive

Lake Worth, FL 33467-7953

HENRY GARCIADOB: 07/10/1966SSN: 590-05-5383Last Known Address: 15444 S.W. 50th Terrace

Miami, FL

FABIAN DIAZDOB: 06/29/1947SSN: 262-92-8339Last Known Address: 9021 S.W. 113th Circle Place

Miami, FL 33176

JOEL DE LA OSADOB: 01/06/1969SSN: 594-02-5711Last Known Address: 13535 NW 9th Lane

Miami, FL 33182

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DAVID EBANKSDOB: 07/02/1959SSN: 265-55-0361Last Known Address: 830 NE 144th Street

North Miami, FL 33161

JOSE L. BENITEZDOB: 11/06/1953SSN: 266-95-5677Last Known Address: 32070 SW 196th Avenue

Homestead, FL 33030-6404

DARIEL TABARESDOB: 11/21/1977SSN: 595-43-3905Last Known Address: 11970 SW 191st Terrace

Miami, FL 33177

MICHAEL E. BURMANDOB: 02/23/1968SSN: 267-73-2581Last Known Address: 6590 W. Rogers Circle, #6

Boca Raton, Fl 33487

LAZARO VILARCHAODOB: 12/17/1966SSN: 261-87-7455Last Known Address: 3210 SW 190th Avenue

Miramar, FL 33029

IVAN VILARCHAODOB: 11/27/1973SSN: 262-73-5718Last Known Address: 15319 Lock Isle Drive

Miami Lakes, FL 33014

JOSEPH VILLANUEVADOB: 02/06/1973SSN: 595-48-0872Last Known Address: 19230 NW 67th Court

Hialeah, FL 33015-2476

ARTURO GODINEZ

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DOB: 01/07/1959 (F3)SSN: 262-47-7822Last Known Address: 16500 NW 84th Avenue

Hialeah, FL 33016

TOM MARTINODOB: 02/13/1971SSN: 066-70-3523Last Known Address: 504 Schulmann Drive

Las Vegas, NV 89146

JULIO CESAR CRUZDOB: 11/08/1962SSN: 267-85-8057Last Known Address: 4182 W. 6th Avenue

Miami, FL 33127

GISELA GONZALEZDOB: 01/29/1965SSN: 261-85-6308Last Known Address: 643 W. 64th Drive

Hialeah, FL 33012-6572

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