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ARNOLD MORRIS, SCOTT MORRIS, and FIBRE-TECH,
INC.
INDICTMENT
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION
UNITED STATES OF AMERICA,
V.
CASE NO. 94-168-Cr-T-23A
ARNOLD MORRIS,
SCOTT MORRIS,
and
FIBRE-TECH, INC.
The Grand Jury charges that:
COUNT ONE
[18 U.8.C. S371]
A. INTRODUCTION
1. At all times material to this Indictment, FIBRE-TECH,
INC. was a corporation doing business in Florida, and
elsewhere as a manufacturer
of fiberglass reinforced products under the trade name
Fibre-Tech. FIBRE-TECH, INC. also sold Fibre-Tech
products to licensed dealers and applicators for use with
swimming pool surfaces. FIBRE-TECH, INC. was
incorporated on or about April 6, 1987.
2. At all time; material to this Indictment, SCOTT MORRIS
and his brother, Andrew Morris, were the owners and
President and Vice-President, respectively, of
FIBRE-TECH, INC.
3. ARNOLD MORRIS is the father of SCOTT MORRIS and Andrew
Morris. At all times material to this Indictment, ARNOLD
MORRIS claimed to act only as a "consultant" to
FIBRE-TECH, INC.
4. At all times material to this Indictment, ARNOLD
MORRIS also did business as Willies Manufacturing, which
sold fiberglass reinforced products to Charm Industries.
Charm Industries, in turn, distributed
said products under the trade name Intra-Seal to licensed
dealers and applicators for use with swimming pool
surfaces. The fiberglass reinforced produce. sold by
ARNOLD MORRIS, doing business as Willies
Manufacturing, were manufactured at facilities owned and
operated by FIBRE-TECH INC.
5. At all times material to this Indictment, Swim
Industries Corporation was a creditor of ARNOLD MORRIS by
virtue of a S1,700,000 judgment entered against ARNOLD
MORRIS in a civil lawsuit in the Circuit Court in and for
Pinellas County, Florida on April 23, 1991.
6. Subsequent to April 23, 1991, ARNOLD MORRIS used the
fictitious name of Charles Glass in order to avoid paying
the judgment against him in favor of Swim Industries
Corporation
7. On or about May 6, 1991, ARNOLD MORRIS caused SCOTT
MORRIS to open a checking account with Republic Bank on
behalf of ARNOLD MORRIS in the name of Willies
Manufacturing in order to conceal monies belonging to
ARNOLD MORRIS from Swim Industries Corporation.
8. On or about August 27, 1991, ARNOLD MORRIS opened a
checking account With First Union Bank in the fictitious
name of Charles Glass in order to conceal monies
belonging to ARNOLD MORRIS from Swim Industries
Corporation.
9. On or about December 17, 1991, ARNOLD MORRIS applied
for and received a State of Florida drivers license
issued in the fictitious name of Charles Glass.
10. On or about December 17, 1991, ARNOLD MORRIS opened a
checking account with First Florida Bank in the
fictitious name of Charles Glass in order to conceal
monies belonging to ARNOLD MORRIS from Swim
Industries Corporation.
11. On or about April 27, 1992, ARNOLD MORRIS caused to
be prepared and filed a voluntary petition under Chapter
11 of the Bankruptcy Code Title 11, United States Code)
in the United States Bankruptcy Court for the Middle
District of Florida, Tampa Division (hereinafter the
Bankruptcy Court).
12. On or about May 21, 1992, ARNOLD MORRIS, using the
fictitious name Charles Glass, opened a checking account
with First Union Bank in the name of Willies
Manufacturing in order to conceal monies belonging to
the bankruptcy estate of ARNOLD MORRIS from his creditors
and the Bankruptcy Court.
13. On or about October 27, 1992, ARNOLD MORRIS, using
the fictitious name Charles Glass, opened a second
checking account with First Union Bank in the fictitious
name of Charles Glass in order to conceal monies
belonging to the bankruptcy estate of Arnold MORRIS from
his creditors and the Bankruptcy Court.
B. THE CONSPIRACY
14. Beginning in or about April, 1992, and continuing
until the date of this Indictment, in the Middle District
of Florida, and elsewhere, the defendants,
ARNOLD MORRIS, SCOTT MORRIS, and FIBRE-TECH, INC.,
did knowingly and willfully combine, conspire,
confederate and agree with each other, and with others
known and unknown to the Grand Jury, to commit the
following offenses against the United States:
a. to knowingly and fraudulently transfer and conceal
monies of ARNOLD MORRIS in contemplation of bankruptcy,
in violation of Title 18, United States Code, Section
152;
b. to knowingly and fraudulently transfer and conceal
monies belonging to the bankruptcy estate of ARNOLD
MORRIS, in violation, of Title 18, United States Code,
Section 152; and
c. to knowingly and fraudulently make and cause to be
made false statements under penalty of perjury and in
relation to the bankruptcy proceedings of ARNOLD MORRIS,
in violation of Title 18 United States Code, Section 152.
C. THE
MANNER AND MEANS BY WHICH
THE CONSPIRACY WAS CARRIED OUT
15. The manner and means by which the conspiracy was
sought to be accomplished included, among other things:
a, ARNOLD MORRIS would and did use checking accounts in
names other than his own to conceal the transfer of
monies in contemplation of bankruptcy;
b. ARNOLD MORRIS would and did cause to be prepared and
filed a voluntary petition under Chapter 11 of the
Bankruptcy Code which contained false statements and
material omissions;
c. ARNOLD MORRIS would and did cause to be prepared and
filed schedules of assets and liabilities under Chapter
11 of the Bankruptcy Code which contained false
statements and material omissions;
d. ARNOLD MORRIS would and did cause to be prepared and
filed amended schedules of assets and liabilities under
Chapter 11 of the Bankruptcy Code which contained false
statements and material omissions;
e. ARNOLD MORRIS would and did cause to by prepared and
filed "Chapter 11 Monthly Reports For
Individual Debtors" which contained false statements
and material omission;
f. ARNOLD MORRIS would and did conceal from the creditors
of ARNOLD MORRIS and the Bankruptcy Court that
FIBRE-TECH, INC. was manufacturing the fiberglass
reinforced products that ARNOLD MORRIS, doing business as
Willies Manufacturing, sold to Charm Industries;
g. ARNOLD MORRIS would and did conceal from the creditors
of ARNOLD MORRIS and the Bankruptcy Court income received
by ARNOLD MORRIS;
h. ARNOLD MORRIS, SCOTT MORRIS, and FIBRE-TECH INC.,
acting through SCOTT MORRIS, would and did transfer and
cause to be transferred monies from FIBRE-TECH, INC. to
ARNOLD MORRIS which would then be deposited in
checking accounts in names other than ARNOLD MORRIS;
i. ARNOLD MORRIS would and did use checking accounts in
names other than his own to conceal monies belonqing to
the bankruptcy estate of ARNOLD MORRIS;
j. ARNOLD MORRIS would and did withdraw and cause to be
withdrawn monies belonging to the bankruptcy estate of
ARNOLD MORRIS from the aforesaid checking accounts and he
would and did transport, transmit and transfer
and cause to but transported, transmitted and transferred
said monies to foreign countries;
k. ARNOLD MORRIS and SCOTT MORRIS would and did purchase
real property in foreign countries and ARNOLD MORRIS
would and did Conceal said property from his creditors
and the Bankruptcy Court; and
1. ARNOLD MORRIS would and did make false statements
under penalty of perjury in and in relation to the
bankruptcy proceedings of ARNOLD MORRIS;
m. SCOTT MORRIS would and did testify falsely under oath
in relation to an arbitration hearing.
D. OVERT ACTS
16. In furtherance of this conspiracy and to effectuate
the objects thereof, the following overt acts, among
others, were committed in the Middle District of Florida,
and elsewhere:
a. On or about April 2, 1992, ARNOLD MORRIS and SCOTT
MORRIS met with an attorney and arranged for the
commencement of bankruptcy proceedings on behalf of
ARNOLD MORRIS;
b. On or about April 2, 1992, ARNOLD MORRIS, in the
presence of SCOTT MORRIS, told an attorney that his only
source of income was a monthly wage paid to him by
FIBRE-TECH, INC.
c. From on or about April 2, 1992, to on or about April
26, 1992, ARNOLD MORRIS made and caused to be made
deposits of monies into checking accounts in the names of
Charles Glass and Willies Manufacturing in the total
approximate amount of S47,529.60;
d. From on or about April 2, 1992, to on or abort April
26, 1992, ARNOLD MORRIS made and caused to be made
withdrawals of monies from checking
accounts in the names of Charles Glass and Willies
Manufacturing in the total approximate amount of
S58,165.07.
e. On or about April 22, 1992, SCOTT MORRIS signed two
checks made payable to Charles Glass;
f. On or about April 27, 1992, ARNOLD MORRIS caused to be
prepared and filed a voluntary petition under Chapter 11
of the Bankruptcy Code in the Bankruptcy Court;
g. From on or about April 27, 1992, to on or about
January 21, 1993, ARNOLD MORRIS made and caused to be
made deposits of monies into checking accounts in the
names of Charles Glass and Willies Manufacturing in the
total approximate amount of $643,984.97;
h. From on or about April 27, 1992, to on or about
January 26, 1993, ARNOLD MORRIS made and caused to be
made withdrawals of monies from checking accounts in the
name of Charles Glass and Willies Manufacturing in the
total approximate amount of $727,177;
i. On or about May 1, 1992, FIBRE-TECH, acting by and
through SCOTT MORRIS, endorsed a check made payable to
FIBRE-TECH, INC. to Willies Manufacturing;
j. 0n or about May 4, 1992, SCOTT MORRIS signed a check
made payable to Charles Glass;
k. On a. about May 8, 1992, SCOTT MORRIS signed two
checks made payable to Charles Glass;
1. On or about May l8, 1992, SCOTT MORRIS signed two
checks made payable to Charles Glass;
m. On or about May 21, 1992, ARNOLD MORRIS, using a
fictitious name, Charles Glass, opened a checking account
with First Union Bank in the name of Willies
Manufacturing;
n. From on or about June 20, 1992, to December 20, 1992,
ARNOLD MORRIS filed and caused to be filed "Chapter
11 Monthly Reports For Individual Debtors";
o. On or about June 25, 1992, ARNOLD MORRIS testified
under oath in relation to the bankruptcy proceeding of
ARNOLD MORRIS;
p. On or about August 28, 1992, ARNOLD MORRIS testified
under oath in relation to the bankruptcy proceeding of
ARNOLD MORRIS;
q, On or about August 13, 1992, FIBRE-TECH, INC., acting
by and through SCOTT MORRIS, endorsed a check payable to
FIBRE-TECH, INC., to Charles Glass; and,
r. On or about November 18, 1992, ARNOLD MORRIS testified
under oath in relation to the bankruptcy proceedings of
ANROLD MORRIS:
s. On or about February 8 and 9, 1993, SCOTT MORRIS
testified under oath in relation to an arbitration
hearing;
All in violation of Title 18,
United States Code, Section 371
COUNT TWO
[18 U.S.C. Sec. 1956(g)]
A. INTRODUCTION
1. The allegations of the Introduction (Section A.) of
Count One are incorporated by reference and realleged as
if fully set forth herein.
B. THE CONSPIRACY
2. Beginning on or about April 27, 1992, and continuing
until the date of this indictment, in the Middle District
of Florida, and elsewhere,
the defendants,
ARNOLD MORRIS, SCOTT MORRIS and
FIBRE-TECH, INC.,
did knowingly and willfully combine, conspire,
confederate and agree together and with each other, and
with others known and unknown to the Grand Jury, to
commit the following offenses against the United States:
To knowingly and willfully conduct a financial
transaction, which transaction involved the proceeds of a
specified unlawful activity, that is, bankruptcy fraud
(18 U.S.C. S 152), knowing that the
transaction was designed in whole or in part to conceal
and disguise the nature, the location, the source, the
ownership and the control of the
proceeds of said specified unlawful activity; then
knowing that the property involved -in said financial
transaction represented the proceeds of some form of
unlawful activity, in violation of 18 U.S.C.
Sec. 1956 (a) (1) (B) (i).
C. THE
MANNER AND MEANS BY WHICH
THE CONSPIRACY WAS CARRIED OUT
3. The allegations of The Manner and Means By Which The
Conspiracy Was Carried Out (Section C) of Count One are
incorporated by reference and realleged as if fully set
forth herein.
D. OVERT ACTS
The allegations of Overt Acts (Section D) of Count One
are incorporated by reference and realleged as if fully
set forth herein.
All in violation of Title 18, United States Code, Section
1956(g).
COUNT THREE
[18 U.S.C. SS 152 and 2]
Beginning on or about April 2, 1992, and continuing until
on or about April 27, 1993, in the Middle District of
Florida, the defendants,
ARNOLD MORRIS, SCOTT MORRIS and FIBRE-TECH, INC.,
aided and abetted by each other, in contemplation of a
case under Title 11, United States Code (Bankruptcy)
relating to ARNOLD MORRIS, and with the intent to defeat
the provisions or Title 11, United States Code,
did knowingly and fraudulently transfer and conceal
property of ARNOLD MORRIS, that is, monies in the
approximate amount of $32,529.60.
In violation of Title 18, United States Code, Sections
152 and 2.
COUNT FOUR
[18
U.S.C. SS 152 and 2]
Beginning on for about April 27, 1992, and continuing
until the date of his Indictment, in the Middle District
of Florida, and elsewhere, the defendants,
ARNOLD MORRIS, SCOTT MORRIS, and FIBRE-TECH, INC.,
aided and abetted by each Other, in relation to the
bankruptcy proceedings of ARNOLD MORRIS, being a case
under Title 11, United States Code (Bankruptcy), styled
In Re Arnold Morris, Case No. 92-572l-8Bl and ancillary
proceedings thereto, pending in the United
States Bankruptcy Court for the Middle District or
Florida, Tampa Division, did knowingly and fraudulently
conceal. and cause to be concealed from creditors,
property of the bankruptcy estate of ARNOLD
MORRIS, that is, monies in the total approximate amount
of $388,809.97.
In violation of Title 18,
United States Code, Section 152 and 2.
COUNT FIVE
[U.S.C. SEC 1521]
On or about April 27, 1992, in the Middle District Of
Florida, the defendants,
ARNOLD MORRIS, SCOTT MORRIS, and FIBRE-TECH, INC.,
in relation to the bankruptcy proceedings of ARNOLD
MORRIS. being a case under Title 11, United States Code
(Bankruptcy), styled In Re ARNOLD MORRIS, Case No.
92-5721-8B1. in the United States Bankruptcy Court for
the Middle District of Florida, Tampa Division, did
knowingly and fraudulently cause to be prepared and filed
a false account, that is, a bankruptcy petition and
accompanying schedules, which were not true and correct
in that:
a. Although no other names were disclosed, in addition to
his true name, ARNOLD MORRIS used the name Charles Glass
during the six (6) years previous to April 27, 1992;
b. Although no other names were disclosed, in addition to
his true name, ARNOLD MORRIS did business as Willies
Manufacturing during the six (6) years prior to April 27,
1992;
c. In addition to the income reported as "gross
monthly wages," ARNOLD MORRIS also received income
from doing business as Willies Manufacturing and from
leasing real property located at 2055 34th Way
North, Largo, Florida: and,
d. Although no checking accounts were disclosed, ARNOLD
MORRIS maintained a checking account with First Union
National Bank in the name of Charles Glass
(#14964000459), a checking account with First Florida
Bank in the name of Charles Glass, (#218044010), and a
checking account with Repute Bank in the name of Willies
Manufacturing, Inc., (#0980712806) .
In violation of Title 18,
United States Code, Section 152.
COUNT SIX
[18 U.S.C. S 152]
On or about June 25, 1992, in the Middle District
of Florida, the defendants,
ARNOLD MORRIS, SCOTT MORRIS, and FIBRE-TECH,
INC., .
in relation to the bankruptcy proceedings of ARNOLD
MORRIS, being a case under Title 11, United States Code
(Bankruptcy), styled In Re Arnold Morris, Case No.
92-5721-8B1, in the United States Bankruptcy Court for
the Middle District of Florida, Tampa Division, did
knowingly and fraudulently cause to be prepared and filed
a false account, that is, amended schedules which were
not true and correct in that:
a. In addition to the income reported as "gross
monthly wages," ARNOLD MORRIS also received income
from doing business as Willies Manufacturing and from
leasing real property located at 2055 34th Way North,
Largo, Florida, and,
b. Although no checking accounts were disclosed, ARNOLD
MORRIS maintained a checking account with First Union
National Bank in the name of Charles Glass
(#l4964000459), a checking account with First Florida
Bank in the name of Charles Glass, (#218044010), a
checking account with Republic Bank in the name of
Willies Manufacturing, Inc., (#0980712806), and a
checking account with First Union National Bank in
the name of Charles Glass (#17448110053).
In violation of Title 18, United
States Code, Section 152.
COUNT SEVEN
[18 U.S.C. S 152]
.
On or about July 23, 1992, in the Middle District of
Florida, the defendants,
ARNOLD MORRIS, SCOTT MORRIS, and FIBRE-TECH, INC.,
in relation to the bankruptcy proceedings of ARNOLD
MORRIS, being a case under Title 11, United States Code
(Bankruptcy) styled In Re Arnold Morris, Case No.
92-5721-8B1, in the United States Bankruptcy Court for
the Middle District of Florida, Tampa Division, did
knowingly and fraudulently make a false oath after being
duly administered an oath and sworn to tell the truth, in
that ARNOLD MORRIS was asked the following
questions and gave the following answers:
Q. Did you -- after the judgment was rendered, did you
have any bank accounts that had any money in them?
A. No. I closed
all my bank accounts. I closed my bank accounts.
Q. You operated
without any bank accounts up from the time of the
judgment until the bankruptcy court filing?
A. Correct.
Whereas, as
ARNOLD MORRIS then and there well knew, said answers made
under oath were false and fraudulent in that ARNOLD
MORRIS in fact maintained bank accounts during the period
from the referenced judgment until the bankruptcy court
filing.
In violation of Title 18, United States Code, Section
2. Q. What
income sources have you had during the bankruptcy
proceeding?
A. Fiber Tech.
Excuse me.
Q. Anybody
else?
A. No.
* * * * *
Q. Do you have
any other source of income besides the money from Fibre
Tech?
A. No.
Q. Have you
opened any bank account in the Caymen Islands or any
other foreign location?
A. No.
Whereas, as ARNOLD MORRIS then and there well knew, said
answers made under oath were false and fraudulent in
that:
1. During the time that he had filed the Chapter } 11
bankruptcy proceeding, he opened bank accounts in
addition to a bank account at Sun Bank;
2. During the bankruptcy proceeding, ARNOLD MORRIS
received income in addition to the income he received
from FIBRE-TECH, INC.; and
3. ARNOLD MORRIS opened and caused to be opened a bank
account in a foreign country.
In violation of Title 18, United States Code, Section 152
COUNT EIGHT
[18 U.S.C. S 152]
On or about November 3,
1992, in the Middle District of Florida, the defendants,
ARNOLD MORRIS, SCOTT MORRIS, and FIBRE-TECH, INC.,
in relation to the bankruptcy proceedings of ARNOLD
MORRIS, being a case under Title 11, United States Code
(Bankruptcy), styled In Re Arnold Morris, Case No.
92-5721-8B1, in the United States Bankruptcy Court for
the Middle District of Florida, Tampa Division, did
knowingly and fraudulently make a false oath after being
duly administered an oath and sworn to tell the truth, in
that ARNOLD MORRIS was asked the following
questions and gave the following answers:
Q. During the time that you filed this Chapter 11, do you
have -- did you open a bank account?
A. Yes, I did.
Q. And where
that is (sic) located?
A. Sun Bank.
* * * * *
Q. Have you
opened any other bank accounts?
A. No.
Q. Have you
deposited all of your income into that bank account?
A. Yes.
* * * * *
Q. Do you have
any other bank accounts besides that bank account?
A. No.
.
COUNT NINE
[18 U.S..C. S 1001]
On or about July 20, 1992, in the
Middle District of Florida, the defendants,
ARNOLD MORRIS, SCOTT MORRIS, and FIBRE-TECH, INC.,
in a matter within the jurisdiction of the United Stares
Bankruptcy Court, an agency of the United States, did
knowingly and willfully make a false and fraudulent
statement as to a material fact, in that ARNOLD MORRIS
signed and submitted a "Chapter 11 Monthly Report
For Individual Debtors" in which he claimed income
or receipts during the period
beginning April 27, 1992, and ending May 31, 1992, in an
amount of five thousand dollars (S5,000), when in truth,
as ARNOLD MORRIS well knew, he had income and receipts
during the period beginning April 27, 1992, and ending
May 31, 1992, in an amount substantially greater than
five thousand dollars ($5,000).
In violation of Title 18, United States Code, Section
1001.
COUNT TEN
[18 U.S.C. S 1001]
On or about July 20, 1992, in
the Middle District Florida, the defendants,
ARNOLD MORRIS, SCOTT MORRIS, and FIBRE-TECH, INC.,
in a matter within the jurisdiction of the United States
Bankruptcy Court, an agency of the United States, did
knowingly and willfully make a false and fraudulent
statement as to a material fact, in that ARNOLD MORRIS
signed and submitted a ''Chapter 11 Monthly Report For
Individual Debtors" in which he claimed income or
receipts during the period
beginning June 1, 1992, and ending June 30, 1992, in an
amount of five thousand dollars ($5,000), when in truth,
as ARNOLD MORRIS well knew, he had income and receipts
during the period beginning June 1, 1992, and
ending June 30, 1992, in an amount substantially greater
than five thousand dollars ($5,000).
In violation of Title 18, United
States Code, section 1001.
COUNT ELEVEN
[18 U.S.C. S 1001]
On or about August 19, 1992, in
the Middle District Florida, the defendants,
ARNOLD MORRIS, SCOTT MORRIS, and FIBRE-TECH, INC.,
in a matter within the jurisdiction of the United States
Bankruptcy Court, an agency of the United States, did
knowingly and willfully make a false and fraudulent
statement as to a material fact, in that ARNOLD MORRIS
signed and submitted a "Chapter 11 Monthly Report
For Individual Debtors" in which he claimed income
or receipts during the period
beginning June 30, 1992,and ending July 30, 1992, in an
amount of five thousand dollars ($5,000), when in truth,
as ARNOLD MORRIS well knew, he had income and
receipts during the period beginning June 30, 1992, and
ending July 30, 1992, in an amount substantially greater
than five thousand dollars
($5,000).
In violation of Title 18, United
States Code, Section 1001.
COUNT TWELVE
[18 U.S.C. S 1001]
On or about September 19, 1992,
in the Middle District of Florida, the defendants,
ARNOLD MORRIS, SCOTT MORRIS, and FIBRE-TECH, INC.,
In a matter within the jurisdiction of the United States
Bankruptcy Court, an agency of the United States, did
knowing and willfully make a false and fraudulent
statement as to a material fact, in that ARNOLD MORRIS
signed and submitted a "Chapter 11 Monthly Report
For Individual Debtors" in which he claimed income
or receipts during the period
beginning August 1, 1992, and ending August 30, 1992, in
an amount of five thousand dollars ($5,000), when in
truth, as ARNOLD MORRIS well knew, he had income and
receipts during the period beginning August,
1992, and ending August 30, 1992, in an amount
substantially greater than five thousand dollars
(S5,000).
In violation of Title 18, United States Code, Section
1001.
COUNT THIRTEEN
[18 U.S.C. S 1001]
On or about October 20, 1992, in
the Middle District of Florida, the defendants,
ARNOLD MORRIS, SCOTT MORRIS, and FIBRE-TECH,
INC.,
in a matter within the jurisdiction of the United States
Bankruptcy Court, an agency of the United States, did
knowing and willfully make a false and fraudulent
statement as to a material fact, in that ARNOLD MORRIS
did sign and submitted a "Chapter 11 Monthly Report
For Individual Debtors" in which he claimed no
income or receipts during the period beginning September
1, 1992, and ending September 30, 1992, when in truth. as
ARNOLD MORRIS well knew, he had substantial income and
receipts during the period beginning September 1, 1992,
and ending September 30, 1992.
In violation of Title 18, United States Code, Section
1001.
COUNT FOURTEEN
[18 U.S.C. S 1001]
On or about November 20, 1992,
in the Middle District of Florida, the defendants,
ARNOLD MORRIS, SCOTT MORRIS, and FIBRE-TECH, INC.,
In a matter within the jurisdiction of the United States
Bankruptcy Court, an agency of the United States, did
knowingly and willfully make false and fraudulent
statement as to a material fact, in that ARNOLD MORRIS
signed and submitted a "Chapter 11 Monthly Report
For Individual Debtors" in which he claimed income
or receipts during the period
beginning October 1, 1992, and ending October 31, 1992,
in an amount of five thousand five hundred fifty dollars
(S5,550), when in truth, as ARNOLD MORRIS well knew, he
had income and receipts during the period
beginning October 1, 1992, and ending October 31, 1992,
in an amount substantially greater than five thousand
five hundred fifty dollars ($5,550).
In violation of Title 18, United
States Code, Section 1001.
COUNT FIFTEEN
[18 U.S.C. S 1001]
On or about December 20, 1992,
in the Middle District of Florida, the defendants,
ARNOLD MORRIS, SCOTT MORRIS, and FIBRE-TECH, INC.,
in a matter within the jurisdiction of the United States
Bankruptcy Court, an agency of the United States, did
knowingly and willfully make a false and fraudulent
statement as to a material fact, in that ARNOLD MORRIS
signed and submitted a "Chapter 11 Monthly Report
For Individual Debtors" in which he claimed income
or receipts during the period
beginning November 1, 1992, and ending November 30, 1992,
in an amount of five thousand dollars ($5,000), when in
truth, as ARNOLD MORRIS well knew, he had income and
receipts during the period beginning November I, 1992,
and ending November 30, ,992, in an amount substantially
greater than five thousand dollars ($5,000).
In violation of Title 18, United
States Code, Section 1001.
C0UNTS SIXTEEN
THROUGH TWENTY-ONE
[l8 U.S.C. SS 1956(a) (1) (B) (i) and
2]
On or about the dates set forth
below, in the Middle District of Florida, the defendants,
ARNOLD MORRIS, SCOTT MORRIS, and FIBRE-TECH, INC.,
aided and abetted by each other, did knowingly and
willfully conduct and cause to be conducted
financial transactions set forth below, affecting
interstate and foreign commerce, which involved the
proceeds of a
specified unlawful activity, that is bankruptcy fraud (18
U.S.C. S 152), knowing that the transactions were
designed in whole or in part to conceal the nature, the
location, the source, the ownership and the
control of the proceeds of said specified unlawful
activity, then knowing that the property involved in said
financial transactions represented the proceeds of some
form of unlawful activity:
COUNT DATE TRANSACTION AMOUNT
BANK
16 5/12/92
DEPOSIT $ 54,832.75 REPUBLIC
BANK
17 5/18/92 DEPOSIT $
47,500 FIRST FLORIDA
18 5/18/92 DEPOSIT
$547,500 FIRST UNION
19 6/22/92 DEPOSIT $
5,337.45 FIRST UNION
20 10/28/92 DEPOSIT $
36,800 FIRST UNION
21 11/30/92 DEPOSIT $
5,985 FIRST UNION.
All in violation of Title 18,
United States Code, Sections 1956(a) (1) (B) (i) and 2.
COUNTS TWENTY-TWO
THROUGH TWENTY-FIVE
[42
U.S.C. Sec. 408a) (7) (b)]
On or about the dates set forth
below, in the Middle District of Florida, the defendant,
ARNOLD MORRIS,
for the purposes set forth below, did knowingly and
willfully and with the intent to deceive, falsely
represent number 102-32-874 to be a Social Security
account number assigned by the Secretary of the United
States Department of Health and Human Services, to
himself when in fact, as ARNOLD MORRIS then and there
well knew such number was not the Social Security account
number assigned by the Secretary of the United States
Department of Health and Human Services to ARNOLD MORRIS:
COUNT DATE
PURPOSE
22 8/27/91 To open checking account (First Union)
23 12/17/91 To obtain Florida driver's license
24 12/17/91 To open checking account (First Florida)
25 10/27/92 To open checking account (First Union)
In violation of Title 42, United
States Code, Sections 408(a) (7) (b).
COUNT TWENTY-SIX
[18 U.S.C. S 1621]
On or about February 9, 1993, in
the Middle Dlstrict of Florida, the defendant,
SCOTT MORRIS,
in relation to the proceedings styled Fibre-Tech, Inc.,
v. Wayne Stringer, et al., American Arbitration
Association Case No. 33 199 00088 92, after being duly
administered an oath and sworn to tell the truth, did
willfully and contrary to such oath give the following
answers to the following questions:
Q. Do you know who Charles Glass is?
A. No.
Q. Was Charles
Glass ever paid any money from
Fibre-Tech?
A. No.
Q. Did your
father ever use Charles Glass as an alias?
A. I have no
idea.
Whereas, as SCOTT MORRIS then and there well knew, said
answers made under oath were false and fraudulent in that
SCOTT MORRIS in fact knew that his father, ARNOLD MORRIS,
had used the alias Charles Glass and
that FIBRE-TECH, INC. had pain money to ARNOLD MORRIS
under the alias of Charles Glass.
In violation of Title 18, United
States Code, Sections 1621.
FORFEITURES
1. The allegations of Counts Two and Sixteen through
Twenty-One of this dictment are realleged and by this
referent and fully incorporated herein for the purpose of
alleging forfeitures to the United States of America
pursuant to the provisions of Title 18, United States
Code, Section 982.
2. As a result of the offenses, alleged in Counts Two and
Sixteen through Twenty One, ARNOLD MORRIS, SCOTT MORRIS
and FIBRE-TECH INC., shall forfeit to the United States
all property real and personal,
involved in the aforestated offenses and all property
traceable to such property, as to which property the said
defendants are jointly and severally liable, including by
not limited to the following property:
a. $ 421,329.60 in United States currency and all
interest and proceeds traceable thereto, in that such sum
in aggregate is property which was involved in the
aforesaid offenses or is traceable to such property, in
violation of Title 18, United States Code, Sections 1956
and 982.
3. If any of the property described above as being
subject to forfeiture, as a result of any act or omission
of the defendants --
(1) cannot be located upon the exercise of due diligence;
(2) has been transferred or sold to, or deposited with, a
third person;
(3) has been placed beyond the jurisdiction of the Court;
(4) has been substantially diminished in value; or
(5) has been commingled with other property which cannot
be subdivided without difficulty;
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 said defendants up to the value of the
above forfeitable property; that is, $421,329.60
including but not limited to the following:
1. Any assets of Fibre-Tech, Inc., including but ~:
limited to any patent rights, trademark rights, real
estate, accounts receivables, or any other thing of value
owned by the aforementioned corporation, its
officers or subsidiaries.
2. Real property located at 3805 Shore Boulevard Oldsmar,
Florida, 34677-5615, more particularly described as
follows:
Lot 11 in block 8 of SECTION NO. 1, WEST OLDSMAR,
according to the Plat thereof, recorded in Plat Book 9,
on page 79, of the Public Records of Pinellas County,
Florida.
3. Real property located at 1800 Driftwood Circle.
Oldsmar, Florida, 34677-2751, more particularly described
as follows:
Lot 145 of HARBOR PALMS, Unit 2 as per plat thereof
recorded in Plat Book 69 Page 27, of the Public Records
of Pinellas County, Florida.
4. Real property located at 8001 Bardmoor Place, Building
K, Unit 202, Largo, Florida 34647-1317, more particularly
described as follows:
CONDOMINIUM PARCEL: UNIT NO. 202-K, FAIRWAY VILLAS AT
BARDMOOR, A CONDOMINIUM according to plat thereof
recorded in Condominium Plat Book 45, Pages 87 through
91, inclusive, and any amendments subsequent thereto, and
being further described in that certain Declaration of C
ondominium in
O.R. Book 5099, Page 1255, and any amendments subsequent
thereto, Public Records of`Pinellas County, Florida.
All in violation of Title 18,
United States Code, section 982.
A TRUE BILL,
___________________________
FOREPERSON
_____________________________
DONNA A. BUCELLA
Acting United States Attorney
_____________________________
DENNIS I. MOORE
Assistant United States Attorney
_____________________________
EDWARD J. PAGE
Assistant United States Attorney
Deputy Managing Assistant
Major Crimes Section
_____________END___________________END_______________
See Also: Order of Arrest for Arnold Morris
Lorenzo Dee Belveal, Author
Copyright © 1997 Lorenzo Dee
Belveal
All Rights Reserved
Guadalajara, Jalisco, MEXICO
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