Case 3:15-cr-00064-L Document 1 Filed 02/19/15 Page 1 of 5 PageID 1 v-?u - ?nal-133m tuft-{5? IN THE UNITED STATES DISTRICT COURT i FILEQ FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION 2335176919 222g, CLERKLW UNITED STATES OF AMERICA VI Criminal No. JEREMY WIGGAINS - 1 5 0 6 INDICTMENT The Grand Jury charges: Introduction A. Background At all times material to this indictment: 1. The defendant, Jeremy Wiggains, owned and operated Straight Line Automotive Group in Dallas, Texas. 2. SLAG advertised itself as an exotic and high-end pre-owned auto dealer servicing potential customers worldwide via the internet. 3. SLAG maintained a line of credit or ??oor-plan? through State Bank Trust Co., which was an insured depository institution with the FDIC. B. The Purpose of the Scheme and Arti?ce 4. From at least May 3, 2013, and continuing to on or about July 14, 2013, the defendant, Jeremy Wiggains, devised and intended to devise a scheme and arti?ce to defraud State Bank Trust Co. by obtaining money through materially false and fraudulent pretenses and representations. Indictment - Page 1 of4 Case 3:15-cr-00064-L Document 1 Filed 02/19/15 Page 2 of 5 PageID 2 C. The Scheme and Arti?ce to Defraud 5. It was part of the scheme and arti?ce to defraud that Jeremy Wiggains would sell vehicles to Park Place Motors that SLAG had accepted as ?trade-in? during the course of business. However, SLAG would continue to keep the vehicle in inventory, even after depositing Park Place Motors? payment. 6. It was further part of the scheme and arti?ce to defraud that Jeremy Wiggains would have his salespersons market and sell the inventory that he had already sold to Park Place Motors. After ?nding a potential buyer, SLAG would negotiate and sell the vehicles to general public. 7. It was further part of the scheme and arti?ce to defraud that Jeremy Wiggains would obtain ??oor-plan? ?nancing from State Bank Trust Co. for the vehicles SLAG had already sold to. bona ?de third-party purchasers. Essentially, allowing SLAG to get paid for these vehicles three different times: (1) from the sale to Park Place Motors; 7(2) from the sale to a bona ?de third~party purchaser; and (3) from the ??oor?plan? ?nancing. Indictment Page 2 of 4 Case 3:15-cr-00064-L Document 1 Filed 02/19/15 Page 3 of 5 PageID 3 Counts One through Two Bank Fraud (Violation of 18 U.S.C. 1344) The Grand Jury realleges and incorporates by reference the allegations contained in the Introduction to this indictment as if fully set forth. 9. On or about the dates set forth below for each count listed below, in the Dallas Division of the Northern District of Texas, the defendant, Jeremy Wiggains, devised a scheme and arti?ce to defraud the ?nancial institution listed below to obtain moneys, funds, credits, assets, securities, or other property owned by or under the custody or control of the ?nancial institution listed below, by means of materially false or fraudulent pretenses, representations, or promises, as described in each count below: Count Approximate Dates Financial Institution Materially False or Fraudulent Act Jeremy Wiggains ?oor-plans a 2008 Ferrari 430 ending in 4331) for One May 3, 2013 June Sgt: approximately $170,000 with State Bank 20, 2013 FDIC) Trust Co. on June 20, 2013, after having sold this vehicle to B.P. on or about May 13, 2013. Jeremy Wiggains ?oor~plans a 2013 Aston Martin Vantage ending in TWO May 15, 2013 June 7387) for approximately $128,000 with 25, 2013 FDIC) State Bank Trust Co. on June 25, 2013, after having sold this vehicle to HP. on or about May 16, 2013. 10. Allin violation of 18 U.S.C. 1344. Indictment Page 3 of4 Case 3:15-cr-00064-L Document 1 Filed 02/19/15 Page 4 of 5 PageID 4 Forfeiture Notice (18 U.S.C. 982(a)(1)(C) and 28 U.S.C. ?2461(c)) Upon conviction for the offense alleged in Count One and Two of this indictment and pursuant to 18 U.S.C. 982(a)(2), the defendant, Jeremy Wiggains, shall forfeit to the United States of America all property, real or personal, constituting, or derived from, the proceeds traceable to the offense. This property, includes, but is not limited to, the following: 1. The proceeds obtained as a result [of the offense, in the form of a money judgment. A TRUE BILL: FOREMANU JOHN R. PARKER Acting . a 3 to BRIAN D. POE Assistant United States Attorney Northern District of Texas Texas State Bar No. 24056908 1100 Commerce St., Third Floor Dallas, Texas 75242-1699 Telephone: 214.659.8670 Facsimile: 214.659.8803 E-mail: brian.poe@usdoi.gov Indictment Page 4 of4 Case 3:15-cr-00064-L Document 1 Filed 02/19/15 Page 5 of 5 PageID 5 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN TEXAS DALLAS DIVISION THE UNITED STATES OF AMERICA JEREMY WIGGAINS 3~ INDICTMENT 18 U.S.C. 1344 Bank Fraud 18 U.S.C. and 28 U.S.C. 2461(c) Forfeiture Notice 2 Counts A true bill rendered DALLAS 9% FOREPERSON Filed in open court this iday of February, 2015.