U.S. v. Maritza Claudia Fernanda Lorza Ramirez, and James Arley ...

Case 0:12-cr-60091-KMW Document 2 Entered on FLSD Docket 04/20/2012 Page 1 of 11 

UNITED STATES OF AM ERICA 

VS. 

MARITZA LORZA and 

JAMES VELASCO, 

Defendants. 

Sealed 

UNITED STATES DISTRICT COURT ' ' . x, 

SOUTHE RICT e A gh-ykjuuj/jjyjy 

Case No. u: 

18 U.S.C. 

k y,j :. tugyaww yssta 

j 1956(h) &Nt7&7 

18 U.S.C. j 1957 

18 U.S.C. j1956(A)(1)(B)(i) 

FILED by D 

18 U.S.C. j 2 

. 

18 U.S.C. j 982 

The Grand Jury charges that: 

At al times relevant to this lndictment: 

/ 

INDICTM ENT 

GENERAL ALLEGATIONS 

The Defendants and Their Companies 

y, , . j 

AFF l ! 2912 

STEVEN . 

CLERK M LARIMORE 

U S DIST CT 

s. D. of fIA. - M1hM1 

Celebration Home Services, lnc. (scelebration') was a Florida company, incorporated 

on or about October 5, 2005, with its principal place of business in Broward County, in the Southern 

District of Florida. M ARITZA LORZA was the president, treasurer and registered agent of 

Celebration. JAMES VELASCO was the vice-president and secretary of Celebration. LORZA and 

VELASCO controlled Bank of America account no. xxxxxx4036 opened on behalf of Celebration. 

2. 4 Al Your Needs, Inc. (t4 All YourNeeds') was a Florida company, incorporated on 

or about May 5, 2006, with its principal place of business in Broward County, in the Southern District 

of Florida. JAMES VELASCO was the president, treasurer and registered agent of 4 A l YourNeeds.


MARITZA LORZA was the vice-president and secretary of 4 Al1 Your Needs. LORZA and 

VELASCO controled Bank of America account no. xxxxxx2718 opened on behalf of 4 A1l Your 

Needs. 

VPP Staffing lnc. (ç%VPP') was a Florida company, incorporated on or about January 

5, 2007, with its principal place of business in Broward County, in the Southern District of Florida. 

M ARITZA LORZA was the president, treasurer and registered agent of VPP. LORZA and JAMES 

VELASCO controled Bank of America account no. xxxxxxxx5365 opened on behalf of VPP. 

4. 

Work Force lnnovations, Co. CfWork Force') was a Florida company, incorporated on 

or about October 12, 2007, with its principal place of business in Broward County, in the Southern 

District of Florida. MARITZA LORZA was the president, treasurer and registered agent of Work 

Force. JAM ES VELASCO was the vice-president and secretary of Work Force. LORZA and 

VELASCO controlled Bank of Americaaccount no. xxxxxxxx4708 opened on behalf of Work Force. 

1. 

COUNT 1 

Conspiracy to Commit Money Laundering 

(18 U.S.C. 5 1956(h)) 

Paragraphs 1 through 4 of the General A ltgations section of this Indictment are 

realeged and incorporated by reference as if fully set forth herein. 

2. From on or about January 12, 2006, and continuing through on or about December 

18, 2009, in Broward County, in the Southern District of Florida, and elsewhere, the defendants, 

M ARITZA LORZA 

and 


did willfuly, that is, with the intent to further the object of the conspiracy, and knowingly combine, 

conspire, confederate, and agree with each other and with others lcnown and unknown to the Grand 

Jury, to commit the folowing violations:


(a) to knowingly conduct a financial transaction affecting interstate commerce, which 

transaction involved the proceeds of specified unlawful activity, knowing that the property involved 

in the financial transaction represented the proceeds of some fonn of unlawful activity, and knowing 

that such transaction was designed in whole and in part to conceal and disguise the nature, the 

location, the source, the ownership, and the control of the proceeds of specitsed unlawful activity in 

violation of Title 18, United States Code, Section 1956(a)(1)(B)(i); 

(b) to knowingly engage and attempt to engagein a monetary transaction affecting 

interstate commerce, by, through, and to, a financial institution involving criminaly derived property 

of a value greater than $ 10,000, such property having been derived from specitied unlawful activity 

in violation of Title 1 8, United States Code, Section 1957. 

It is further aleged that the specifed unlawfulactivity is health care fraud, in 

violation of Title 18, United States Code, Section 1347. 

A1l in violation of Title 18, United States Code, Section 1956(h). 

COUNTS 2-10 

M oney Laundering 

(18 U.S.C. j 1956(a)(1)(B)(i)) 

Paragraphs 1 through 4 of the General A legations section of this lndictment are 

realleged and incorporated by reference as if fuly set forth herein. 

On or about the dates specified as to each count below, in Broward County, in the 

Southern District of Florida, and elsewhere, the defendants 

MARITZA LORZA 



did knowingly conduct and attempt to conduct a financial transaction affecting interstate commerce,

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l 

l 


. 

which transaction involved the proceeds of specified unlawful activity , knowing that the property . 

involved in the financial transaction represented the proceeds of some form of unlawful activity , and 

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knowing that the transaction was designed in whole and in part to conceal and disguise the nature , the 

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location, the source, the ownership, and the control of the proceeds of specified unlawful activity , as ' 

l Set forth below: t 

. 

.i 

! Count Approximate Description of Finan 

cial j 

) 

Date of Transaction 

Transaction 

r( 

2 05/03/2007 The deposit of approximately $5 

,000 into Bank of : è 

America Account xxxxxx5365 via Check No. 

2271 , drawn on the account of Bou Inc. and made 

ble to VPP Staffing, Inc. 

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Paya , 

, : 

3 05/25/2007 The deposit of approximately $5,500 into Bnnk of ( 

America Account xxxxxx4036 via Check No . 

1712, drawn on the account of Font & Bou Rehab 

' 

y 

t 

Associates, Inc. and made payable to Celebration 

Home Services, Inc. 

4 07/12/2007 The deposit of approximately $6 

,400 into Bank of 

) 

;) 

. ( 

; ( 

America Account xxxxxx5365 via Check No . y 

1817 , drawn on the accotmt of Font & Bou Rehab t 

Associates, Inc. and made payable to VPP è :(. 

Staffing, Inc. 

), ' 5 1 1/28/2007 The deposit of approximately $5,500 into Bank of 

, 

l 


' 

C. 

2059, drawn on the account of Font & Bou Rehab y 

Associates, lnc. and made payable to Celebration ' 

Home Services, ) 

Inc. jy:. 

6 04/02/2008 The deposit of approximately $5,500 into Bank of ; 


2506 drawn on the account of Start Therapy , lnc. 

and made payable to W ork Force Innovations, ; 

Co. : 

4 4. 

. 

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F 

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' 

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li, 

1. 

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Count Approximate Description of Financial 


Transaction 

7 12/29/2008 The deposit of approximately $5,400 into Bank of 


2843, drawn on the accotmt of Font & Bou Rehab 

Associates, lnc. and made payable to Celebration 

Home Services, Inc. 



3503, drawn on the account of Griffon, lnc. and 

made payable to W ork Force lnnovations, Co. 



3617, drawn on the account of Font & Bou Rehab 

Associates, lnc. and made payable to 4 All Your 

Needs, Inc. 



1254, drawn on the account of Bou lnc. and made 

payable to Celebration Home Services, Inc. 

lt is further aleged that the specified unlawful activity is health care fraud, in violation 

of Title 18, United States Code, Section l 347. 

ln violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. 

COUNTS 11-14 

Money Laundering 

(18 U.S.C. j 1957) 

Paragraphs 1 through 4 of the General A legations section of this Indictment are 

realeged and incorporated by reference as if fuly set forth herein 

On or about the dates specified as to each count below, in Broward County, in the 

Southern District of Florida, and elsewhere, the defendants, 

MARITZA LORZA 


JAMES VELASCO,


did knowingly engage and attemptto engage in a monetarytransaction affecting interstate commerce , 

by, through, and to, a financial institution, involving criminaly derived property of a value greater 

than $ 10,000, and such property having been derived from specified unlawful activity . 

Count Approximate Description of M onetary ' 


Transaction 

1 1 05/31/2007 The deposit of approximately $14,595 into Bank of 

America Accotmt xxxxxx2718 via Check No. 

1717, drawn on the account Font & Bou Rehab 

Associates, lnc. and made payable to 4 AIl Your 

Needs. 

12 02/22/2008 The deposit of approximately $1 1,137 into Bank of 



Associates, Inc. and made payable to 4 A I Your 

Needs. 




Associates, Inc. and made payable to 4 AII Your 

Needs. 




Associates, Inc. and made payable to 4 AlI Your 

Needs. 

3. It is further aleged thatthe specified unlawful activity is health care fraud , in violation 

of Title l 8, United States Code, Section 1347. 

ln violation of Title 18, United States Code, Sections 1957 and 2 . 

FORFEITURE 

(18 U.S.C. j 982) 

1. The alegations contained in Counts l through 14 of this lndictment are re-aleged and


incoporated by reference as though fuly set forth herein for the purpose of aleging fodkiture to the 

United States of America of certain property in which the defendants, MARITZA LORZA and 

JAM ES VELASCO, have an interest. 

2. Upon conviction of a violation of, or a conspiracy to violate, Title 18, United States 

Code, Sectionl956 or 1957, as alleged in this lndictment, the defendant so convicted shal forfeit to 

the United States aIl of his or her right, title and interest in any property , real or personal, involved 

in such violation, or in any property traceable to such property , pursuant to Title 18, United States 

Code, Section 982(a)(1). 

3. lf any property described as being subject to forfeittlre in paragraph 2, above, as a 

result of any ad or omission of either or both of the defendants, 

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

(b) has been transferred or sold to or deposited with a third party; 

(c) has been placed beyond the jtuisdiction of the Court; 

(d) has been substantialy diminished in value; or 

(e) has been commingled with other property which cnnnot be subdivided 

without difficulty; it is the intent of the United States to seek forfeiture of any other property of 

either of the defendants up to the value of the above forfeitable property , pursuant to Title 21, United 

States Code, Section 853(p). 

4. The property subject to forfeiture as substitute property, pursuant to Title 21, United 

States Code, Section 853(p), includes, but is not limited to, the folowing: 

Real property known and numbered as 1 134 Areca Way , W eston, Florida 33327, 

together with al appurtenances, immovements and attachments thereon . 

The United States will seek a forfeiture money judgment against the defendants,


jointly and stveraly, as part of any sentence in the folowing nmount: 

$2,800,000 in United States currency, which is a sum of money equal in value to the 

property, real or personal, involved in the violations aleged in this lndidment, and the property 

traceable to such property. 

All pursuant to Title 18, United States Code, Section 982(a)(1) and the procedures set forth 

at Title 2 1 , United States Code, Section 853, as made applicable by Title 18, United States Code, 

Section 982(b)(1). 

L- I > = p/y 

/ 

WIFREDO A. FEIG ER 

UNITED STATES ATTORNEY 

JON . JUE GER 

ASSISTANT UNITED STATES ATTORNEY 

8 

A U BILL

UNITED STATES DISTRICT COURT 

Case 0:12-cr-60091-KMW Document SOUTHERN 2 DISTRICT Entered on OF FLSD FLORIDA Docket 04/20/2012 Page 9 of 11 

UNITED STATES OF AMERICA 

VS. 

MARITM C. LORZA and 

JAMES A. VELASCO, Defendants. I 

Court Division'. (select one) 

Miami Ke West 

v FTu vvlB FTp 

I do hereby certify that: 

2 . 

3. 

4 . 

CASE NO. 

CERTIFICATE OF TRIAL ATTORNEY. 

Superseding Case Information: 

NNew Defendants) Yes No 

umber of New Defendants 

Total number of counts 

l have carefuly considered the alegations Rf the indictm:n t the number Qf defendants, the number of 

probable witnesses and the Iegal complexltles of the Indlctment/lnformatlon attached hereto. 

I am Mware that the information supplied Mn thij qtatement wil be relied upon b ythe 

Ju d ges 

pf this 

Cpurtln setting theirpalendars and schedulng crlmlnaltrlals underthe mandateof the Speed-yTrlal Act, 

Tltle 28 U.S.C. Sectlon 3161. 

Iqterpreter: LIst Ianguage and/or (Yes dlalec 9r Nj 

This case wil take 6 

Ypm 

Spanish 

days for the padies to try. 

5. Please check appropriate category and type of offense Iisted below: 

(Check only one) 

0 to 5 days 

6 to 10 days 

11 to 20 days 

21 to 60 days 

61 days and over 

6. lf Has this case been previously filed in this District Court? (Yes or No) No 

yes: 

Judge: Case No. - - 

(Atach H copy gf dispositive grdeq) 

If as a complalnt been filed In thls mater? (Yes or No) No 

Maglstrate yeq: 

Case No. 

Related Misc:laneous numbers: 

Defendantls) ln federal custody as of 

Defendantls) In state custody as of 

Rule 20 from the District of 

Is this a potential death penalty case? (Yes or No) 

8. 

(Check only one) 

Peë M 

inor 

Misdem. 

Felony 

Does October this caseori inatefrom a matter pending in the Nodhern Region of the U .S. Attorney's Office prior 

to 14, 2J03? Yes Y No 

Does this case originate from a matter pending in the Central Region of the U .S. Attorney's Office prior 

D07? Yes Y No 

to September 1, 2 

JON JUENG 

AS>I ANT U ED STATES ATTORNEY 

Fl orld ar No./coud No. 56108 

*penalty Sheets) atached REV 4/8/08


Defendant's Name: M aritza Lorza 

Case No: 

Count #: 1 

Conspiracy to Commit Monev LaunderinR 

18 U.S.C. $ 1956413) 


SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

* Max. Penalty: Twenty (20) years' imprisonment 

Counts #: 2 - 10 

Money LaunderinR 

18 U.S.C. $ 1956(aX1b(B')(i) 

*Max. Penalty: Twenty (20) years' imprisonment as to each count 

Counts #: 1 1 - 14 

Monev Latmderinz 

18 U.S.C. $ 1957 

*Max. Penalty: Ten (10) years' imprisonment as to each count 

*Refers only to possible term of incarceration, does not include possible fines, restitution, 

special assessments, parole terms, or fodeitures that may be applicable.


Defendant's Name: James Velasco 

Case No: 

Count #: 1 

Conspiracy to Commit Monev Laundering 

18 U.S.C. j 1956(h) 


SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

* Max. Penalty: Twenty (20) years' imprisonment 

Cotmts #: 2 - 10 


18 U.S.C. $ 1956(ab(11(B1(i1 

*Max. Penalty: Twenty (20) years' imprisonment as to each count 

Counts #: 1 1 - 14 


IS U.S.C. q 1957 

*Max. Penalty: Ten (10) years' imprisonment as to each count 

WRefers only to possible term of incarceration, does not include possible fines, restitution , 

special assessments, parole terms, or forfeitures that may be applicable.

U.S. v. Maritza Claudia Fernanda Lorza Ramirez, and James Arley ...

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