UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON

AT SEATTLE

UNITED STATES OF AMERICA,	)

)	NO.

Plaintiff,	)

)

v.	)	INDICTMENT

)

KEVIN L. LAWRENCE,	)

)

Defendant.	)

_________________________________)

THE GRAND JURY CHARGES THAT:

I.

COUNT 1

(Conspiracy)

From in or about 1995, and continuing thereafter until the present, at Seattle, Bellevue, and Bainbridge Island, at other places within the Western District of Washington, and elsewhere, the defendant, KEVIN L. LAWRENCE, together with other persons known and unknown to the Grand Jury, did unlawfully, willfully, and knowingly combine, conspire, confederate and agree among themselves and each other to commit certain offenses against the United States, as follows:

A.	INTRODUCTION

1.	Health Maintenance Centers, Inc., ("HMC") was incorporated in Washington State on or about May 12, 1995, and was administratively dissolved and reinstated at various times throughout the period from on or about December 6, 1995, through on or about October 30, 2000. At all times material to this Indictment, defendant KEVIN L. LAWRENCE was the founder and principal officer of HMC. Beginning at a time unknown but at least by in or around 1997, Donavon C. Claflin was the Treasurer of HMC and the authorized signer for many of the bank accounts associated with HMC. From in or around September 2000 through in or around January 2002, Kevin McCarthy was the head of HMC's investor relations department. The Articles of Incorporation for HMC provided that the corporate purposes of HMC were "[t]o operate health and exercise clubs, and related facilities" and "[t]o engage in any business, trade or activity which may be conducted lawfully by a corporation organized under the Washington State Business Corporation Act." The Articles of Incorporation for HMC also provided that "[t]his corporation is authorized to issue 10,000 shares of common stock and each share shall have a par value of $1.00." On February 5, 1997, HMC filed Articles of Amendment that provided, among other things, that "[t]his corporation is authorized to issue 15,000,000 shares of common stock and each share shall have a par value of $1.00." On or about December 26, 2001, HMC ceased to exist as a Washington State corporation and merged with a Delaware corporation known as HMC Acquisition Corp., a wholly-
owned subsidiary of Znetix, Inc. Also on or about December 26, 2001, HMC Acquisition Corp. changed its name to Health Maintenance Centers, Inc.

2.	Project X, Inc., was incorporated in the State of Washington on November 3, 1999. On October 3, 2000, Project X filed Articles of Amendment with the Washington State Secretary of State changing its name to Znetix, Inc. On or about September 25, 2001, Znetix, Inc., ceased to exist as a Washington State corporation and merged with a Delaware corporation known as Znetix, Inc.

3.	From in or about 1995 through in or about January 2002, HMC, Project X, and Znetix, and affiliated entities, through various sales agents and at the direction of defendant KEVIN L. LAWRENCE, and other persons known and unknown to the Grand Jury, solicited and received in excess of $60 million from investors. At no time were the offers and sales of securities issued by HMC, Project X, Znetix, and affiliated entities registered with the United States Securities and Exchange Commission, the State of Washington Department of Financial Institutions, Securities Division, or with the securities regulatory authorities in any other state.

4.	On or about April 9, 2001, the State of Washington Department of Financial Institutions, Securities Division, issued a Summary Order to Cease and Desist against HMC and defendant KEVIN L. LAWRENCE. The Cease and Desist Order, among other things, barred defendant KEVIN L. LAWRENCE and HMC (including HMC's employees, officers and directors) from selling securities through fraudulent representations and material omissions, and in violation of the Washington State statutes providing for the registration of securities prior to their offer and sale.

5.	Cascade Pointe LLC was a limited liability company formed in Washington State on or about May 2, 2001. Cascade Pointe of Arizona LLC was a limited liability company formed in Arizona on or about August 8, 2001. Cascade Pointe of Nevis LLC was a limited liability company established in the Carribean nation of Nevis on or about July 26, 2001.1 Clifford G. Baird was the manager of Cascade Pointe from on or about June 22, 2001, through in or around January 2002. From on or about May 2, 2001, through in or around January 2002, defendant KEVIN L. LAWRENCE, along with Kevin McCarthy and other persons known and unknown to the Grand Jury, secretly controlled and directed the activities of Cascade Pointe.

6.	From on or about May 2, 2001, through in or around January 2002, Cascade Pointe, through various sales agents and at the direction of defendant KEVIN L. LAWRENCE and others known and unknown to the Grand Jury, solicited and received in excess of $12 million from investors. At no time were the offers and sales of securities issued by Cascade Pointe and affiliated entities registered with the United States Securities and Exchange Commission, the State of Washington Department of Financial Institutions, Securities Division, or with the securities regulatory authorities in any other state.

B.	OBJECTS OF THE CONSPIRACY

The objects of the conspiracy were as follows:

1.	To unlawfully, knowingly, and willfully, directly and indirectly, by the use of means and instrumentalities of interstate commerce, and of the mails, use and employ, in connection with the purchases and sales of securities, manipulative and deceptive devices and contrivances, by (a) employing devices, schemes, and artifices to defraud; (b) making untrue statements of material facts and omitting to state material facts necessary to make the statements made, in light of the circumstances in which they were made, not misleading; and (c) engaging in acts, practices, and courses of business which operated and would operate as a fraud and deceit upon other persons, in violation of Title 15, United States Code, Sections 78j(b) and 78ff(a), and Title 17, Code of Federal Regulations, Section 240.10b-5;

2.	To knowingly and willfully transmit and cause to be transmitted by wire communication in interstate and foreign commerce writings, signs, signals, pictures, and sounds in furtherance of a scheme and artifice to defraud and for obtaining money and property by means of false and fraudulent pretenses, representations, and promises, in violation of Title 18, United States Code, Section 1343;

3.	To knowingly and willfully use and cause the United States mail and interstate couriers to be used in furtherance and execution of a scheme and artifice to defraud, and a scheme and artifice for obtaining money and property by means of false and fraudulent pretenses, representations and promises, in violation of Title 18, United States Code, Section 1341;

4.	To conduct and attempt to conduct financial transactions affecting interstate commerce involving the proceeds of specified unlawful activities, that is mail fraud, wire fraud, and securities fraud, knowing that the property involved in the financial transactions represented the proceeds of some form of unlawful activity, and knowing that the transactions were 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 specified unlawful activities, in violation of Title 18, United States Code, Section 1956(a)(1)(B)(i);

5.	To transport, transmit, and transfer, and attempt to transport, transmit, and transfer, monetary instruments and funds from places in the United States to and through places outside the United States, and to places in the United States from and through places outside the United States, knowing that the monetary instruments and funds involved in the transportations, transmissions, and transfers represented the proceeds of some form of unlawful activity, and knowing that such transportations, transmissions, and transfers were 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 specified unlawful activities, that is, securities fraud, wire fraud, and mail fraud, in violation of Title 18, United States Code, Section 1956(a)(2)(B)(i); and

6.	To knowingly and willfully engage and attempt to engage in monetary transactions by, through, and to financial institutions, which monetary transactions affected interstate and foreign commerce, in criminally derived property of a value greater than $10,000, such property having been derived from specified unlawful activities, that is, securities fraud, wire fraud, and mail fraud, in violation of Title 18, United States Code, Section 1957.

C.	MANNER AND MEANS OF THE CONSPIRACY

1.	It was a part of the conspiracy and scheme to defraud that defendant KEVIN L. LAWRENCE, and other persons known and unknown to the Grand Jury, knowingly and willfully offered and sold, caused to be offered and sold, and aided and abetted the offer and sale of, securities issued by HMC, Project X, Znetix, Cascade Pointe, and affiliated entities to thousands of investors located in Washington State and other states by means of false and fraudulent statements, representations, promises, and pretenses, including, but not limited to, the false and fraudulent statements that:

a.	investors who purchased the securities of HMC for one dollar per share would receive four shares of Znetix for each share of HMC at the point when Znetix purchased or merged with HMC;

b.	Znetix would imminently engage in an Initial Public Offering ("IPO"), after which Znetix securities could be freely traded on exchanges such as NASDAQ;

c.	Znetix shares would be valued at substantially more than one dollar per share after the IPO;

d.	Znetix had retained prominent investment banking and underwriting firms who were working on the IPO;

e.	Znetix had filed or would very shortly file a registration statement with the United States Securities and Exchange Commission;

f.	HMC and Znetix had developed proprietary medical and fitness software and equipment which would generate substantial revenues;

g.	Znetix had sold or would shortly sell licenses for approximately one million dollars apiece to operate health and fitness clubs throughout the United States;

h.	leading sports and entertainment figures had agreed to purchase or license health and fitness clubs from Znetix;

i.	defendant KEVIN L. LAWRENCE had previously been employed with the firm Morgan Stanley in Japan;

j.	Znetix would receive $500 million from an investor group from China;

k.	Znetix or an affiliate had or was about to obtain a contract with the United States Department of Defense worth millions or even billions of dollars;

l.	defendant KEVIN L. LAWRENCE owned millions of shares in HMC and had to sell a substantial portion of these shares because securities regulators would not allow him to hold a majority interest in both HMC and Znetix;

m.	defendant KEVIN L. LAWRENCE was not receiving any compensation from HMC and Znetix;

n.	funds received from investors in Znetix would be placed in an escrow account and released to Znetix only after Znetix fulfilled the fundraising goals set forth in its private placement memorandum;

o.	Cascade Pointe was a private investment firm under management separate and apart from HMC;

p.	Cascade Pointe was one of the nation's leading private investment firms, and employed investment strategies based on "diversification" and "rock-solid financials";

q.	Cascade Pointe would and had the ability to fund, by means of cash or lines of credit, a "rescission offer" to be made by HMC to its investors, which rescission offer would afford HMC investors the opportunity to choose between a refund of their investments or keeping their investments with HMC in place, and was a final step before the Znetix IPO;

r.	the rescission offer, and therefore the Znetix IPO, was imminent;

s.	Cascade Pointe would operate health and fitness clubs in Arizona and in international locations such as Japan, and would receive tens of millions of dollars of revenue; and

t.	investors who received "units" in Cascade Pointe would receive more than one share of HMC in exchange for each unit, and would later receive four shares of Znetix for each HMC share.

2.	It was a part of the conspiracy and scheme to defraud that in the offer and sale of the securities issued by HMC, Project X, Znetix, Cascade Pointe, and affiliated entities, defendant KEVIN L. LAWRENCE, and other persons known and unknown to the Grand Jury, knowingly and willfully failed to truthfully and accurately disclose in a registration statement, prospectus, private placement memorandum or in any other form material facts, including but not limited to:

a.	the uses to which investors' money would be put, including that investors' money had been and would be used to purchase millions of dollars worth of luxury cars, boats, homes, and other items for the personal use of defendant KEVIN L. LAWRENCE and other persons known and unknown to the Grand Jury,

b.	the financial condition of HMC, Project X, Znetix, Cascade Pointe, and affiliated entities;

c.	the lack of financial controls at HMC, Project X, Znetix, Cascade Pointe, and affiliated entities;

d.	the compensation to be received by defendant KEVIN L. LAWRENCE, and others associated with HMC, Project X, Znetix, Cascade Pointe, and affiliated entities;

e.	that HMC, Project X, Znetix, and Cascade Pointe were under common management and control;

f.	that Znetix could not receive funds under its purported $500 million "debenture contract" with an investment group from China unless Znetix first made $500 million available to that investment group;

g.	that HMC had sold more than its authorized amount of shares.

3.	It was a part of the conspiracy and scheme to defraud that defendant KEVIN L. LAWRENCE, and other persons known and unknown to the Grand Jury, used funds received from investors for personal use, including for purchases of luxury cars, boats, homes, jewelry, and other items, and for other purposes not disclosed to investors.

4.	It was a part of the conspiracy and scheme to defraud that defendant KEVIN L. LAWRENCE, and other persons known and unknown to the Grand Jury, established and used a series of shell companies in Nevada, in the Carribean nation of Nevis, and elsewhere, to promote the scheme and to conceal the ownership and control of funds.

5.	It was a part of the conspiracy and scheme to defraud that defendant KEVIN L. LAWRENCE, and other persons known and unknown to the Grand Jury, used millions of dollars of investor funds to promote the scheme by sponsoring hydroplane and offshore racing boats, the Seattle Mariners major league baseball team and other prominent organizations and events, by hosting lavish parties in Los Angeles and elsewhere, and by paying professional sports stars to wear items imprinted with the Znetix logo.

6.	It was a part of the conspiracy and scheme to defraud that defendant KEVIN L. LAWRENCE, and other persons known and unknown to the Grand Jury, paid employees, consultants, and sales agents of Znetix, Project X, HMC, Cascade Pointe, and affiliated entities outrageously high salaries, commissions, and other compensation, including in the form of cash, homes, and luxury cars, to work, wittingly and unwittingly, in furtherance of the conspiracy and scheme to defraud.

7.	It was a part of the conspiracy and scheme to defraud to mislead and attempt to mislead the State of Washington, the United States Securities and Exchange Commission, and others with regard to the activities of HMC, Project X, Znetix, Cascade Pointe, and those affiliated with them.

8.	It was a part of the conspiracy and scheme to defraud that defendant KEVIN L. LAWRENCE, and other persons known and unknown to the Grand Jury, employed multi-level marketing techniques and various sales agents to offer and sell the securities of HMC, Project X, Znetix, Cascade Pointe and affiliated entities, to over five thousand investors located throughout the United States.

9.	It was a part of the conspiracy and scheme to defraud that defendant KEVIN L. LAWRENCE, and other persons known and unknown to the Grand Jury, lulled and attempted to lull investors, through oral and written communications containing false and misleading statements, into believing that their investments with HMC, Project X, Znetix, Cascade Pointe, and affiliated entities would result in the creation of significant wealth.

D.	OVERT ACTS

In furtherance of the conspiracy, and to promote the objects thereof, defendant KEVIN L. LAWRENCE, and other persons known and unknown to the Grand Jury, committed and caused to be committed, among others, the overt acts described in Counts 2 through 64 of this Indictment, and the following:

1.	On or about August 27, 1997, defendant KEVIN L. LAWRENCE signed check number 1146 in the amount of $25,263.33, drawn on a U.S. Bank account in the name of American HMC LLC, payable to John Green for a 1990 Donzi Black Widow boat.

2.	On or about April 10, 1998, defendant KEVIN L. LAWRENCE signed check number 1661 in the amount of $5,830.34, drawn on a U.S. Bank account in the name of American HMC LLC, payable to "Brothers" for a 1997 Bombardier jet ski watercraft.

3.	On or about April 10, 1998, defendant KEVIN L. LAWRENCE signed check number 1659 in the amount of $7,226.15, drawn on a U.S. Bank account in the name of American HMC LLC, payable to "Brothers" for a 1998 Bombardier jet ski watercraft.

4.	On or about March 26, 1999, defendant KEVIN L. LAWRENCE signed check number 7664 in the amount of $93,337.05, drawn on a U.S. Bank account in the name of Health Maintenance Centers, Inc., payable to Fitzgerald Motor Sports for a 1999 Dodge Viper automobile.

5.	On or about April 12, 1999, defendant KEVIN L. LAWRENCE signed check number 7707 in the amount of $51,648.00, drawn on a U.S. Bank account in the name of Health Maintenance Centers, Inc., payable to Fitzgerald Motor Sports for a 1994 Dodge Viper automobile.

6.	On or about June 6, 1999, defendant KEVIN L. LAWRENCE signed check number 7731 in the amount of $37,435.17, drawn on a U.S. Bank account in the name of Health Maintenance Centers, Inc., payable to Courtesy Ford for a 1999 Ford F350 pickup truck.

7.	On or about August 18, 1999, defendant KEVIN L. LAWRENCE signed check number 7749 in the amount of $108,500, drawn on a U.S. Bank account in the name of Health Maintenance Centers, Inc., payable to John Hennessy for work performed on defendant KEVIN L. LAWRENCE's vehicles.

8.	On or about August 19, 1999, defendant KEVIN L. LAWRENCE signed check number 7793 in the amount of $119,950, drawn on a U.S. Bank account in the name of Health Maintenance Centers, Inc., payable to David Golder for a 1996 Dodge Viper automobile.

9.	On or about February 24, 2000, defendant KEVIN L. LAWRENCE authorized a wire transfer in the amount of $66,000, from a U.S. Bank account in the name of Health Maintenance Centers, Inc., to Roby Autogroup, Inc., for a 1999 Ferrari F355 CV Spider automobile.

10.	On or about March 30, 2000, defendant KEVIN L. LAWRENCE	authorized a wire transfer in the amount of $292,652, from a U.S. Bank account in the name of Health Maintenance Centers, Inc., to National Auto Wholesale for a 2000 Cigarette boat.

11.	On or about June 15, 2000, defendant KEVIN L. LAWRENCE sent a memorandum to "The Qualified Investor" in which he stated:

Znetix, Inc., a Washington corporation, is acquiring HMC, Inc. (d.b.a. Human Performance Centers) with a stock purchase. The valuation of HMC, Inc. has been accepted by the Board of Directors of Znetix, Inc. Znetix, Inc. offers to HMC, Inc. for consideration of its value, four (4) shares of Znetix, Inc. Common Stock, or equivalent, for every one (1) share of HMC, Inc. Common Stock. This conversion is applicable to all shareholders with the date of record from January 1, 1999 through the present.

12.	On or about June 16, 2000, defendant KEVIN L. LAWRENCE countersigned a letter addressed to him from Keith Falls of SPI Silver Pointe Investments LLC ("Silver Pointe"), pursuant to which defendant KEVIN L. LAWRENCE represented that Silver Pointe would be able to exchange 400,000 HMC shares for 1,600,000 shares of Znetix, and that "[i]t will be announced next week that Znetix, Inc. will be offered in an IPO later this year and based on today's market conditions you and your board of advisors expect a low end strike price to be between $12-20 dollars per share."

13.	On or about June 26, 2000, defendant KEVIN L. LAWRENCE caused the purchase of a U.S. Bank cashier's check in the amount of $25,000, payable to Europa for a 2000 Mercedes Benz 500CV automobile.

14.	On or about August 11, 2000, defendant KEVIN L. LAWRENCE authorized a wire transfer in the amount of $325,000, from a U.S. Bank account in the name of Health Maintenance Centers, Inc., to Lake Cumberland Marine for a 1999 Cigarette boat.

15.	On or about September 10, 2000, defendant KEVIN L. LAWRENCE signed check number 8402 in the amount of $135,755, drawn on a U.S. Bank account in the name of Health Maintenance Centers, Inc., dba Kevin Lawrence, Inc., payable to Europa International, Inc., for a 2000 Mercedes Benz 500CV automobile.

16.	On or about September 15, 2000, defendant KEVIN L. LAWRENCE sent a memorandum to Gary Engen, an investor, answering two questions posed by that investor as follows:

The answers to your two general questions are as follows:

1.	What type of escrow account are the Znetix private placement funds held in?

Znetix private placement funds are in the control of the legal firms handling our stock offering. When Znetix receives funds, the checks are photocopied and one is sent to the Stock Transfer Company, Znetix holds one and the original check is controlled by the legal group. When Znetix has finished raising its offering amount, the legal group will file with the SEC in each of the states the funding came from. When this intern [sic] mechanics if [sic] finished, the funds are released to Znetix to be used as described in its private placement memorandum. This process is very strict and allows no gray area. That is why there are three independent entities, which control the access to funds and stock. One is the legal group, one is Znetix and one is the Stock Transfer Company.

2.	What is the likelihood that an action could slow or stop the funds from being released to Znetix?

There is virtually no situation to stop the funds from being released. It is a very closely monitored process and the funds belong to Znetix from the onset. The escrow system is just one step more secure than that of a real estate escrow account and that step being the legal control of the account. However, it is no different than a real estate account when it comes to the release of the funds. the funds belong to the parties involved in the transaction, not the escrow or legal companies, therefore when the documentation is signed, the funds are available.

I allow two weeks or so to give the parties involved time to finish the internal paperwork shuffling that happens in all business transactions. Also, I always assume absenteeism due to sickness and such as well as mail and bank slow downs. Having contingencies built into the time schedule is prudent when dealing with more than one individual. This is why I always give two weeks as a buffer for any working arrangements dealing with escrows or SEC funding assignments.

Conclusion:

I am so secure about the absolute conclusion of the Znetix funds release I will warrant or pledge my entire ownership in Znetix as well as my personal assets against the event happening as I have depicted.

Thank you for your help and call me if you have further questions.

17.	On or about October 18, 2000, defendant KEVIN L. LAWRENCE authorized a wire transfer in the amount of $25,000, from a U.S. Bank account in the name of Health Maintenance Centers, Inc., to Motorcars International, Inc., for a 2001 Lamborghini Diablo automobile.

18.	On or about November 7, 2000, defendant KEVIN L. LAWRENCE authorized check number 3022 in the amount of $100,000, drawn on an account of Project X, Inc., at U.S. Bank, payable to Land Title for property in Poulsbo, Washington.

19.	On or about November 15, 2000, defendant KEVIN L. LAWRENCE authorized check number 3014 in the amount of $100,000, drawn on an account at U.S. Bank, in the name of Project X, Inc., payable to the wife of an individual affiliated with Znetix located in Los Angeles, California.

20.	On or about December 27, 2000, defendant KEVIN L. LAWRENCE caused the purchase of cashier's check number 5021882717 in the amount of $25,000, with funds from a U.S. Bank account in the name of Project X, Inc., payable to Executive Auto Consultants for a 2000 Mercedes G500 automobile.

21.	On or about January 5, 2001, defendant KEVIN L. LAWRENCE authorized a wire transfer in the amount of $90,000, from a U.S. Bank account in the name of Project X, Inc., to a bank account held by Plaza Motor Company for a 2001 Porsche 911 Carrera Cabriolet.

22.	On or about February 9, 2001, defendant KEVIN L. LAWRENCE authorized a wire transfer in the amount of $20,000, from a First Mutual Bank account in the name of Health Maintenance Centers, Inc.- American Integrated Health, to Bank of Hawaii in Honolulu for credit to an account in the name of Title Guaranty Escrow Services.

23.	On or about February 9, 2001, defendant KEVIN L. LAWRENCE authorized an unnumbered counter check in the amount of $12,999.21, drawn on a First Mutual Bank account in the name of Health Maintenance Centers, Inc.- American Integrated Health, payable to Executive Auto Consultants for accessories for a 2000 Mercedes Benz G500 automobile.

24.	On or about February 14, 2001, defendant KEVIN L. LAWRENCE authorized check number 1014 in the amount of $5000, drawn on a First Mutual Bank account in the name of Health Maintenance Centers, Inc.- American Integrated Health, payable to Executive Auto for a 2000 Mercedes Benz G500 automobile.

25.	On or about February 26, 2001, defendant KEVIN L. LAWRENCE authorized a wire transfer in the amount of $85,000, from a First Mutual Bank account in the name of Health Maintenance Centers, Inc.- American Integrated Health, payable to Executive Auto Consultants for a 2000 Mercedes Benz G500 automobile.

26.	On or about March 1, 2001, defendant KEVIN L. LAWRENCE signed check number 5146 in the amount of $80,000, drawn on a Bank of America account in the name of Bainbridge Human Performance Center PLLC, for the purchase of cashier's check number 3410121573, which was used for property in Princeville, Hawaii.

27.	On or about March 23, 2001, defendant KEVIN L. LAWRENCE authorized a wire transfer in the amount of $725,000, from a First Mutual Bank account in the name of Health Maintenance Centers, Inc.- American Integrated Health, to Title Guaranty Escrow Services for property in Princeville, Hawaii.

28.	On or about March 26, 2001, defendant KEVIN L. LAWRENCE authorized a wire transfer in the amount of $90,000, from a First Mutual Bank account in the name of Health Maintenance Centers, Inc.- American Integrated Health, to Hall Pantera, Inc., for a 1972 DeTomaso Pantera automobile.

29.	On or about March 27, 2001, defendant KEVIN L. LAWRENCE authorized a wire transfer in the amount of $600,000, from a First Mutual Bank account in the name of Health Maintenance Centers, Inc.- American Integrated Health, to SkyPrints for a residence for a Znetix fundraiser located in St. Louis, Missouri.

30.	On or about March 27, 2001, defendant KEVIN L. LAWRENCE authorized a wire transfer in the amount of $124,653, from a First Mutual Bank account in the name of Health Maintenance Centers, Inc.-American Integrated Health, to a bank account held by Steve Taub, Inc., for the purchase of a 2001 Porsche 911 Cabriolet for the wife of an individual affiliated with Znetix located in Los Angeles, California.

31.	On or about April 6, 2001, defendant KEVIN L. LAWRENCE authorized a wire transfer in the amount of $174,698.75, from a First Mutual Bank account in the name of Health Maintenance Centers, Inc.- American Integrated Health, to The Bank of Nova Scotia, Nassau, Bahamas, for account number 6077-18 in the name of Graham, Thompson & Co.

32.	On or about April 17, 2001, defendant KEVIN L. LAWRENCE authorized check number 1096 in the amount of $330,000, drawn on a First Mutual Bank account in the name of Health Maintenance Centers, Inc.- American Integrated Health, payable to Lido Jewelry for the purchase of a seven carat diamond ring.

33.	On or about May 2, 2001, defendant KEVIN L. LAWRENCE and other persons known and unknown to the Grand Jury caused the formation of Cascade Pointe LLC as a Washington State limited liability company.

34.	On or about June 26, 2001, defendant KEVIN L. LAWRENCE and Clifford G. Baird signed a "letter of intent" purporting to commit Cascade Pointe to provide $35 million to fund a rescission offer to be made by HMC to investors.

35.	On or about June 26, 2001, Clifford G. Baird sent a letter to Cascade Pointe investors requesting that the investors not "discuss any information relating to Cascade Pointe, HMC, or Znetix with any party whatsoever," and requesting that the investors sign a non-disclosure agreement, which would allow them to receive "a research report regarding Znetix" written by "Sanjoy Bhattaharya [sic], a former analyst with Goldman Sachs & Company."

36.	On or about July 2, 2001, Clifford G. Baird received a letter from Julie S. Mills falsely stating that Palledium Capital Partners, Ltd., of Nevis would provide Cascade Pointe with a $5 million line of credit for an up front fee of $175,000.

37.	On or about July 2, 2001, a wire transfer was authorized in the amount of $250,000, with funds from Bank of America account number 62577507 in the name of Cascade Pointe LLC, to Silverdale State Bank, for account number 04022995 in the name of Bainbridge HPC.

38.	On or about July 5, 2001, persons affiliated with Cascade Pointe known and unknown to the Grand Jury established a web site known as www.cascadepointe.com with content that included the false statements that Cascade Pointe was one of the nation's leading private investment firms and employed investment strategies based on "diversification" and "rock-solid financials."

39.	On or about July 11, 2001, Clifford G. Baird received a letter from Julie S. Mills falsely stating that Rutherford, York & Baxter, Ltd., of Nevis would provide Cascade Pointe with a $10 million line of credit for an up front fee of $200,000.

40.	On or about July 11, 2001, Clifford G. Baird sent a letter to investors stating, among other things, "[p]lease read the enclosed summary and analysis of Znetix as done by a former Goldman Sachs analyst. This should really excite you."

41.	On or about July 12, 2001, Clifford G. Baird sent a letter to investors falsely stating, among other things, that:

a.	the contract between HMC and Cascade Pointe "discloses in excess of $60 million in promissory notes due to HMC, Inc. by other companies";

b.	Cascade Pointe "has been awarded the state of Arizona by Znetix. The anticipated annual revenues will be between $50 million and $100 million within the first five years of operation";

c.	Cascade Pointe "will also be participating in some portion of the international markets of the Znetix rollout";

d.	Cascade Pointe "has secured a $50 million line of credit from several private money groups."

42.	On or about July 12, 2001, Clifford G. Baird received a letter from Julie S. Mills falsely stating that Winfield & Brundidge Investments, Inc., of Nevis would provide Cascade Pointe with a $10 million line of credit for an up front fee of $150,000.

43.	On or about July 12, 2001, Kevin McCarthy sent an e-mail message to Clifford G. Baird and others stating "[h]ere are the lines of credit. I plan to email these to Nevis tonight for them to fax back signed tomorrow and fedex originals. Let me know if you have any changes."

44.	On or about July 16, 2001, Clifford G. Baird received a letter from Kim Singh falsely stating that Hawkins & Holland, Inc., of Nevis would provide Cascade Pointe with a $10 million line of credit for an up front fee of $250,000.

45.	On or about July 16, 2001, Clifford G. Baird sent a letter to investors falsely stating, among other things, that:

a.	"On Friday night last, July 13, I signed the final agreement to acquire HMC, Inc. rescission stock, some assets and some liabilities. This agreement now gives HMC the ability to start its rescission process by providing the funding necessary for HMC to purchase back shares as requested"; and

b.	"With the retaining of a couple of new Fund Managers as consultants, we should be able to finish our $50 million round by the end of the week."

46.	On or about July 16, 2001, Clifford G. Baird received a letter from Julie S. Mills falsely stating that Nurrell Marcos Capital, Ltd., of Nevis would provide Cascade Pointe with a $10 million line of credit for an up front fee of $150,000.

47.	On or about July 20, 2001, defendant KEVIN L. LAWRENCE had a telephone conversation with Kevin McCarthy in which they discussed having the Acting Controller of Cascade Pointe provide false information regarding Cascade Pointe in response to an inquiry by the State of Washington Department of Financial Institutions, Securities Division.

48.	On or about July 21, 2001, Clifford G. Baird sent an e-mail message to investors stating, among other things, that:

a.	"We are now negotiating to participate in a new foreign opportunity. We are entering discussions for the very real possibility of Cascade Pointe participating in the licensing of over 150 health club/fitness centers in Tokyo, Japan. This just continues to increase your future income stream as a founding member"; and

b.	"This past week someone gave me a great metaphor about this journey we have been on. He suggested it was like an Olympic marathon and we have just entered the Olympic stadium - Wow?"

49.	On or about July 24, 2001, Clifford G. Baird sent a letter to investors, stating, among other things, that Cascade Pointe would be moving its "legal venue" to the Carribean nation of Nevis, and that on or around August 15, 2001, Cascade Pointe would be "retaining the services of an investment banker like Bear Stearns or Stifel, Nicolaus to assist us in raising money to build the facilities."

50.	On or about July 27, 2001, a wire transfer was authorized in the amount of $200,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to Wells Fargo Bank, for account number 3515689010, in the name of Health Maintenance Centers, Inc.

51.	On or about July 27, 2001, a wire transfer was authorized in the amount of $26,550, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to SKNA National Bank, for account number 04022995, in the name of Nevis American Trust, for credit to Cascade Pointe of Nevis LLC.

52.	On or about August 2, 2001, a wire transfer was authorized in the amount of $100,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to Wells Fargo Bank, for account number 3515689010, in the name of Health Maintenance Centers, Inc.

53.	On or about August 2, 2001, a wire transfer was authorized in the amount of $100,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to SKNA National Bank, for account number 04022995, in the name of Nevis American Trust, for credit to Lemur Capital, Ltd.

54.	On or about August 3, 2001, a wire transfer was authorized in the amount of $500,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to Wells Fargo Bank, for account number 3515689010, in the name of Health Maintenance Centers, Inc.

55.	On or about August 6, 2001, the Acting Controller of Cascade Pointe sent a letter to Martin Cordell, a securities enforcement attorney with the State of Washington Department of Financial Institutions, Securities Divison, in which the Acting Controller falsely stated, among other things, that Cascade Pointe's organizers became familiar with HMC, Znetix, and affiliates in the following way:

LLC members have been researching opportunities with companies like HMC and Znetix. During their research, they became aware of the problems HMC was experiencing with your department. Cascade Pointe viewed HMC's problem as a potential opportunity. Contact was made with appropriate personnel at HMC to begin discussions, which has led us to where we are today. The purpose of Cascade Pointe is to pursue the acquisition of HMC stock.

56.	On or about August 7, 2001, a wire transfer was authorized in the amount of $300,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to Wells Fargo Bank, for account number 3515689010, in the name of Health Maintenance Centers, Inc.

57.	On or about August 8, 2001, a wire transfer was authorized in the amount of $150,000, from Bank of America account number 62577507, in the name of Cascade Point LLC, to Wells Fargo Bank Nevada N.A., for account number 924927726, in the name of Eceuro RC Corp.

58.	On or about August 9, 2001, defendant KEVIN L. LAWRENCE and Clifford G. Baird executed an "Amended and Restated Stock Purchase Agreement" that purportedly committed Cascade Pointe to provide $55 million to fund a rescission offer to be made by HMC to investors.

59.	On or about August 9, 2001, a wire transfer was authorized in the amount of $50,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to SKNA National Bank, for account number 04022995, in the name of Nevis American Trust for credit to Gibraltar Capital Partners.

60.	On or about August 10, 2001, a wire transfer was authorized in the amount of $200,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to Wells Fargo Bank, for account number 3515689010, in the name of Health Maintenance Centers, Inc.

61.	On or about August 17, 2001, a wire transfer was authorized in the amount of $100,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to Wells Fargo Bank, for account number 3515689010, in the name of Health Maintenance Centers, Inc.

62.	On or about August 17, 2001, a wire transfer was authorized in the amount of $100,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to Wells Fargo Bank, for account number 3515689010, in the name of Health Maintenance Centers, Inc.

63.	On or about August 21, 2001, a wire transfer was authorized in the amount of $375,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to Wells Fargo Bank, for account number 3515689010, in the name of Health Maintenance Centers, Inc.

64.	On or about August 23, 2001, the Acting Controller of Cascade Pointe sent a memorandum to Clifford G. Baird, which Baird distributed to investors, stating among other things, that the Acting Controller had a lengthy telephone conference with defendant KEVIN L. LAWRENCE, who provided the following information:

a.	"HMC filed the Registration Statement with the State of Washington relative to the rescission"; and

b.	"Znetix is proceeding in an expedited manner to file its S-1. The expectation is that it will be completed and filed within the next few weeks."

65.	On or about August 28, 2001, Kevin McCarthy sent an e-mail message to Clifford G. Baird and the Acting Controller of Cascade Pointe stating, among other things, that McCarthy had received messages from defendant KEVIN L. LAWRENCE, and an "action item" based on those messages was to "[t]ry to get $2 to $3 million in this week and another $1 mill minimum next week."

66.	On or about September 5, 2001, a wire transfer was authorized in the amount of $10,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to SKNA National Bank account number 04022995, in the name of Nevis American Trust, for credit to Gibraltar Capital Partners.

67.	On or about September 6, 2001, a wire transfer was authorized in the amount of $200,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to Wells Fargo Bank, for account number 3515689010, in the name of Health Maintenance Centers, Inc.

68.	On or about September 7, 2001, Clifford G. Baird received a letter from J. Michelle Williams falsely stating that Lloyd's & Lloyd's Financial, Ltd., of Nevis would provide Cascade Pointe with a $10 million line of credit for an up front fee of $150,000.

69.	On or about September 14, 2001, defendant KEVIN L. LAWRENCE sent a letter to Znetix shareholders stating that:

I would like you to know that at the time of this printing I have a Debenture Contract for $500M from an investor group from China. The additional funding of foreign money, approximately $500M, will be used primarily for acquisitions, predictive medicine, and technology developments both domestic and international. This contract is to be executed and as details are available we will forward them to you. This process should be coming to a conclusion in the near future.

70.	On or about September, 18, 2001, a wire transfer was authorized in the amount of $25,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to The Bank of Nevis International for account number 574074998241, in the name of Nevis American Trust, for credit to Alliance Advisory Group.

71.	On or about September 18, 2001, a wire transfer was authorized in the amount of $25,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to ABN Amro Bank N.V. for account number 026009580, in the name of Nevis American Trust, for credit to River Johnson Investors.

72.	On or about September 21, 2001, a wire transfer was authorized in the amount of $60,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to ABN Amro Bank for account number 8298685, in the name of Nevis American Trust, for credit to Alliance Advisory Group.

73.	On or about September 21, 2001, a wire transfer was authorized in the amount of $50,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to The Bank of Nevis International for account number 574074998241, in the name of Nevis American Trust, for credit to River Johnson Investors.

74.	On or about September 24, 2001, a wire transfer was authorized in the amount of $40,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to The Bank of Nevis International, for account number 574074998241, in the name of Nevis American Trust, for credit to Alliance Advisory Group.

75.	On or about September 26, 2001, a wire transfer was authorized in the amount of $25,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to The Bank of Nevis International, for account number 574074998241, in the name of Nevis American Trust, for credit to Cascade Pointe of Nevis.

76.	On or about September 27, 2001, a wire transfer was authorized in the amount of $35,000, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to The Bank of Nevis International, for account number 574074998241, in the name of Nevis American Trust, for credit to Cascade Pointe of Nevis.

77.	On or about September 30, 2001, defendant KEVIN L. LAWRENCE signed an agreement with Global Project and Development, Ltd., providing that Znetix would have to make $500 million available to that company in order to receive $500 million.

78.	On or about October 2, 2001, a wire transfer was authorized in the amount of $30,000, with funds from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to The Bank of Nevis International, for account number 574074998241, in the name of Nevis American Trust, for credit to Alliance Advisory Group.

79.	On or about October 2, 2001, a wire transfer was authorized in the amount of $30,000 with funds from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to The Bank of Nevis International, for account number 574074998241, in the name of Nevis American Trust, for credit to River Johnson Investors.

80.	On or about October 10, 2001, defendant KEVIN L. LAWRENCE falsely stated under oath during a deposition taken by the SEC that Znetix or an affiliate had a contract with the Department of Defense.

81.	On or about October 10, 2001, defendant KEVIN L. LAWRENCE falsely stated under oath during a deposition taken by the SEC that he had no relationship with Cascade Pointe.

82.	On or about October 11, 2001, defendant KEVIN L. LAWRENCE falsely stated under oath during a deposition taken by the SEC that he did not know Randy Becker, the manager of Cascade Pointe from on or about May 2, 2001, through on or about June 21, 2001.

83.	On or about October 11, 2001, defendant KEVIN L. LAWRENCE falsely stated under oath during a deposition taken by the SEC that he was anticipating that Znetix would receive $500 million from a Chinese-based investor group, but that he was unaware of the details of the deal.

84.	On or about October 24, 2001, funds in the amount of $100,000 were withdrawn for the purchase of cashier's check number 8590332204, from Bank of America account number 62577507, in the name of Cascade Pointe LLC, made payable to Health Maintenance Centers, and deposited into Wells Fargo Bank, for account number 3515689010, in the name of Health Maintenance Centers, Inc.

85.	On or about October 31, 2001, defendant KEVIN L. LAWRENCE authorized a wire transfer in the amount of $70,904.02, from a Wells Fargo Bank account in the name of Health Maintenance Centers, Inc., dba HPC, to Pacific NW Title for the purchase of property in Poulsbo, Washington.

86.	On or about November 2, 2001, funds in the amount of $125,000 were withdrawn from a bank account controlled by Cascade Pointe for the purchase of cashier's check number 0604963566 payable to HMC.

87.	On or about November 7, 2001, funds in the amount of $50,000 were withdrawn from a bank account controlled by Cascade Pointe for the purchase of cashier's check number 8590333743 payable to HMC.

88.	On or about November 9, 2001, funds in the amount of $100,000 were withdrawn from a bank account controlled by Cascade Pointe for the purchase of cashier's check number 8590333968 payable to HMC.

89.	On or about November 20, 2001, funds in the amount of $140,000 were withdrawn from a bank account controlled by Cascade Pointe for the purchase of cashier's check number 8590335507 payable to HMC.

90.	On or about November 26, 2001, funds in the amount of $125,000 were withdrawn from a bank account controlled by Cascade Pointe for the purchase of cashier's check number 8590336083 payable to HMC.

91.	On or about November 26, 2001, funds in the amount of $100,000 were withdrawn from a bank account controlled by Cascade Pointe for the purchase of cashier's check number 8590335912 payable to HMC.

92.	On or about November 27, 2001, funds in the amount of $50,000 were withdrawn for the purchase of cashier's check number 8590336146 with funds from Bank of America account number 62577507, in the name of Cascade Pointe LLC, and deposited into Wells Fargo Bank, for account number 3515689010, in the name of Health Maintenance Centers, Inc.

93.	On or about December 7, 2001, a wire transfer was authorized in the amount of $50,000, with funds from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to The Bank of Nevis International, for account number 574074998241, in the name of Nevis American Trust, for credit to Lemur Capital, Ltd.

94.	On or about December 17, 2001, Clifford G. Baird sent a facsimile transmission to defendant KEVIN L. LAWRENCE that included a letter from Vanessa Rawlins to defendant KEVIN L. LAWRENCE stating that "Cascade Pointe of Nevis, LLC is anticipating a significant deposit of funds earmarked as an investment in our company. In accordance with our agreement and at your request, we will be immediately transferring said funds to the transitional account of HMC, Inc."

95.	On or about December 19, 2001, a wire transfer was authorized in the amount of $50,000, with funds from Bank of America account number 62577507, in the name of Cascade Pointe LLC, to bank account number 004962707081 in the name of Night Wind Enterprises, Ltd.

96.	On or about January 8, 2002, funds in the amount of $105,000 were withdrawn for the purchase of a cashier's check, from Bank of America account number 62577507, in the name of Cascade Pointe LLC.

97.	On or about January 8, 2002, defendant KEVIN L. LAWRENCE sent by facsimile transmission to Thomas Odegaard, an investor, a letter from Palledium Capital Partners, Ltd., dated December 10, 2001, and a letter from Nurrel Marcos Capital, Ltd., dated December 11, 2001; both such letters falsely stated that the $10 million lines of credit that these Nevis entities would supposedly provide to Cascade Pointe had been "extended."

98.	On or about January 16, 2002, funds in the amount of $50,000 were withdrawn for the purchase of a cashier's check from Bank of America account number 62577507, in the name of Cascade Pointe LLC.

99.	On or about January 18, 2002, funds in the amount of $85,000 were withdrawn for the purchase of a cashier's check, from Bank of America account number 62577507, in the name of Cascade Pointe LLC.

All in violation of Title 18, United States Code, Section 371.

II.

COUNTS 2 through 25

(Securities Fraud)

1.	Sections A, C, and D of Part I of this Indictment are incorporated in this paragraph as if fully set forth herein.

2.	On or about the dates set forth below, at Bellevue, Seattle, and Bainbridge Island, at other places within the Western District of Washington, and elsewhere, the defendant, KEVIN L. LAWRENCE, together with other persons known and unknown to the Grand Jury, unlawfully, knowingly, and willfully, directly and indirectly, by the use of means and instrumentalities of interstate commerce, and of the mails, did use and employ, in connection with the purchases and sales of securities issued to the investors listed below, manipulative and deceptive devices and contrivances in violation of Title 17, Code of Federal Regulations, Section 240.10b-5, by (a) employing devices, schemes, and artifices to defraud; (b) making untrue statements of material facts and omitting to state material facts necessary to make the statements made, in light of the circumstances in which they were made, not misleading; and (c) engaging in acts, practices, and courses of business which operated and would operate as a fraud and deceit upon other persons. Each investment set forth below constitutes a representative sample of the purchase and sale of securities through the use by defendant KEVIN L. LAWRENCE of such manipulative and deceptive devices and contrivances, and a separate count of this Indictment, as follows:

Count	Date	Investor	Investment
2	August 29, 1999	James Grace, Bellevue, WA	Purchase of 5,000 shares in HMC
3	October 7, 1999	Christopher Teem,

Kirkland, WA	Purchase of 10,000 shares in HMC
4	December 7, 1999	Joe Marvelle,

Sequim, WA	Purchase of 10,000 shares in HMC
5	December 7 1999	Michael Hardy,

Sequim, WA	Purchase of 15,000 shares in HMC
6	February 21, 2000	Dana Milkie and Colleen Poole,

Issaquah, WA	Purchase of 20,000 shares in HMC
7	April 18, 2000	Liberty Unlimited Corp. Management, Issaquah, WA	Purchase of 500,000 shares in Project X.
8	May 5, 2000	Liberty Utld. Management Trust Account for Sundance Assoc., Issaquah, WA	Purchase of 80,000 shares in HMC
9	August 10, 2000	David Nahirny,

Houston, TX	Purchase of 25,000 shares in HMC
10	August 23, 2000	Greg Arrellano,

Redwood City, CA	Purchase of 10,000 shares in HMC
11	September 2, 2000	Bill Cassas,

Newport Beach, CA	Purchase of 15,000 shares in HMC
12	September 25, 2000	Bill Cassas, Newport Beach, CA	Purchase of 10,000 shares in HMC
13	November 10, 2000	Gary Engen,

Yakima, WA	Purchase of 12,500 shares in HMC
14	January 12, 2001	First Security Funding, Bellevue, WA	Purchase of 107,000 shares in Znetix
15	February 1, 2001	Paul Einan,

Scottsdale, AZ	Purchase of 10,000 shares in HMC
16	February 1, 2001	Jonathan Greenspahn, Naples, FL	Purchase of 100,000 shares in Znetix
17	February 16, 2001	Hugh Yap,

Marysville, WA	Purchase of 26,200 shares in HMC
18	March 7, 2001	Mark and Kay Meitzer,

Madison, WI	Purchase of 9,000 shares in HMC
19	March 19, 2001	Julene Daniels,

Portland,OR	Purchase of 3,000 shares in HMC
20	April 2, 2001	Michael and Bernadette Etka, Big Bear Lake, CA	Purchase of 14,000 shares in HMC
21	April 9, 2001	Thomas Riccolo, Morris, IL	Purchase of 10,000 shares in Znetix
22	April 13, 2001	Michael Esber,

Phoenix, AZ	Purchase of 22,200 shares in HMC
23	June 14, 2001	Greg Arrellano,

Redwood City, CA	Purchase of 10,000 units of Cascade Pointe
24	August 18, 2001	Keith Falls,

Arlington, TX	Purchase of 100,000 shares of HMC
25	September 4, 2001	Jason Smith, Cape Coral, FL	Purchase of 50,000 units of Cascade Pointe

All in violation of Title 15, United States Code, Sections 78j(b) and 78ff(a),

Title 17, Code of Federal Regulations, Section 240.10b-5, and Title 18, United States Code, Section 2.

III.

COUNTS 26 through 36

(Wire Fraud)

1.	Sections A, C, and D of Part I of this Indictment are incorporated in this paragraph as if fully set forth herein.

2.	On or about the dates set forth below, at Bellevue, Seattle, and Bainbridge Island, at other places within the Western District of Washington, and elsewhere, the defendant, KEVIN L. LAWRENCE, together with other persons known and unknown to the Grand Jury, having devised and intended to devise the above-described scheme and artifice to defraud, and for obtaining money and property by means of false and fraudulent pretenses, representations, and promises, did, for the purpose of executing such scheme or artifice, knowingly and willfully transmit and cause to be transmitted, by wire communication in interstate and foreign commerce, the writings, signs, signals, pictures, and sounds described below, each of which constitutes a representative sample of the use of wire communications in interstate and foreign commerce in furtherance of the scheme and artifice to defraud and a separate count of this Indictment, as follows:

Count	Date	Sender	Sent To	Description of Item
26	August 1, 2000	Tom Trombaugh, Bank One, Coppell, TX	Project X, U.S. Bank, Seattle, WA	Wire transfer of funds in the amount of $1,000,000
27	September 8, 2000	Keith Falls, Wells Fargo Bank, Arlington, TX	HMC, U.S. Bank, Seattle, WA	Wire transfer of funds in the amount of $82,000
28	November 10, 2000	Kenneth Morgante, Pavilion State Bank, Leroy, NY	HMC, U.S. Bank, Bellevue, WA	Wire transfer of funds in the amount of $20,000
29	June 8, 2001	Robert Norton, Wells Fargo Bank, Twin Falls, ID	Cascade Pointe, Bank of America, Bellevue, WA	Wire transfer of funds in the amount of $25,000
30	June 29, 2001	Susanne J. Pederson, Monona, WI	Bainbridge Human Performance, Silverdale State Bank, Silverdale, WA	Wire transfer of funds in the amount of $10,000
31	July 25, 2001	Mark Heffernan, Arlington Heights, IL	Cascade Pointe, Bank of America, Bellevue, WA	Wire transfer of funds in the amount of $20,000
32	July 26, 2001	Keith and Sue Rezin, Standard Bank & Trust, Evergreen Park, IL	Cascade Pointe, Bank of America, Bellevue, WA	Wire transfer of funds in the amount of $50,000
33	July 28, 2001	Nick Singh, Wells Fargo Bank, Aliso Viejo, CA	Cascade Pointe, Bank of America, Bellevue, WA	Wire transfer of funds in the amount of $100,000
34	June 18, 2001	Linda Bossom, Bank One, Joliet, IL	Cascade Pointe, Bank of America, Bellevue, WA	Wire transfer of funds in the amount of $50,000
35	July 31, 2001	Kenn Davin, The Bankers Bank, Norris, TN	Cascade Pointe, Bank of America, Bellevue, WA	Wire transfer of funds in the amount of $110,000
36	January 15, 2002	Michael Esber, Bank of America, Peoria, AZ	Cascade Pointe, Bank of America, Bellevue, WA	Wire transfer of funds in the amount of $10,000

All in violation of Title 18, United States Code, Sections 1343 and 2.

IV.

COUNTS 37 through 50

(Mail Fraud)

1.	Sections A, C, and D of Part I of this Indictment are incorporated here by reference as if fully set forth herein.

2.	On or about the dates set forth below, at Bellevue, Seattle, and Bainbridge Island, at other places within the Western District of Washington, and elsewhere, the defendant, KEVIN L. LAWRENCE, together with other persons known and unknown to the Grand Jury, having devised and intended to devise the above-described scheme and artifice to defraud, and for obtaining money and property by means of false and fraudulent pretenses, representations, and promises, did, for the purpose of executing such scheme and artifice and attempting so to do, knowingly and willfully send and deliver, cause to be sent and delivered, by the United States Postal Service and other private and commercial interstate carriers according to the directions thereon, the items listed below, each of which constitutes a representative sample of the use of the mails in furtherance of the scheme and artifice to defraud and a separate count of this Indictment, as follows:

Count	Date	Sent

From	Sent

To	Description of Item
37	June 29, 1999	Asa

Sarver, Gallatin Gateway, MT	HMC,

Washington	$6,000 check made payable to HMC
38	August 31, 1999	HMC,

Bellevue, WA	Mark Jennings,

Kirkland, WA	Stock certificate in the amount of 4,000 shares in HMC
39	January 18, 2000	Kevin Lawrence, Bainbridge Island, WA	Mark Schuster, Kirkland, WA	Letter regarding HMC transfer of assets to Project X
40	September 9, 2000	HMC,

Redmond, WA	Mark Schuster, Kirkland, WA	Stock certificate in the amount of 4,000 shares in HMC
41	October 2, 2000	HMC, Washington	Salvatore Zambito, Suquamish, WA	Stock certificate in the amount of 14,500 shares in HMC
42	October 6, 2000	HMC, Redmond, WA	Steven

Gerdes, Lynnwood, WA	Stock certificate in the amount of 25,000 shares in HMC
43	October 23 2000	Billy & Sandy Jamison, Colorado	HMC, Washington	$30,000 check made payable to HMC
44	October 31, 2000	Sean Chaflin, Grand Rapids, MI	HMC, Bellevue, WA	$9,000 check made payable to HMC
45	January 31, 2001	Leonard & Gayle Deddo, Santa Cruz, CA	Al Lacson,

Kirkland, WA	$10,000 check made payable to HMC
46	March 26, 2001	Nati Salvidar, Big Springs, TX	Al Lacson, Kirkland, WA	$5,000 check made payable to HMC
47	April 9, 2001	Wayne Franklin, Vancouver, WA	HMC, c/o

Al Lacson, Kirkland, WA	$30,000 check made payable to HMC
48	May 23, 2001	Robert Norton, Twin Falls, ID	Kevin McCarthy, Bellevue, WA	$50,000 check made payable to HMC
49	May 29, 2001	HMC, Bellevue, WA	Colleen James, Portage, WI	HMC Promissory Note in the amount of $25,000
50	July 9, 2001	Jason and Karae Smith, Cape Coral, FL	Cascade Pointe, Washington	$10,000 check made payable to Cascade Pointe

All in violation of Title 18, United States Code, Sections 1341 and 2.

V.

COUNTS 51 through 55

(Money Laundering)

1.	On or about the dates set forth below, within the Western District of Washington, and elsewhere, the defendant, KEVIN L. LAWRENCE, together with other persons known and unknown to the Grand Jury, did knowingly and willfully conduct and attempt to conduct the financial transactions set forth below affecting interstate and foreign commerce, which involved the proceeds of specified unlawful activities, that is, mail fraud, wire fraud, and securities fraud, knowing that such transactions were designed in whole and in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of said specified unlawful activities, and that while conducting and attempting to conduct such financial transactions knew that the property involved in the financial transactions, that is funds and monetary instruments in the amounts set forth below, represented the proceeds of some form of unlawful activity; each transaction identified below constitutes a representative sample of such financial transactions and a separate count of this Indictment, as follows:

Count	Date	Description of Financial Transaction
51	August 10, 2001	Withdrawal of funds in the amount of $50,000 from Wells Fargo Bank account number 3515689010 in Bellevue, Washington, in the name of Health Maintenance Centers, Inc., dba HPC, by check number 11062 payable to Night Wind Enterprises, Ltd.
52	August 10, 2001	Withdrawal of funds in the amount of $50,000 from Wells Fargo Bank account number 3515689010 in Bellevue, Washington, in the name of Health Maintenance Centers, Inc., dba HPC, by check number 11063 payable to Night Wind Enterprises, Ltd.
53	November 27, 2001	Wire transfer of funds in the amount of $150,000 from First Southern Bancorp account number 80063015 in Kentucky, in the name of Lake Cumberland Marine LLC, deposited to Bank of Hawaii account number 1447165 in Hawaii, in the name of Tradewinds Southwest, Inc.
54	December 4, 2001	Wire transfer of funds in the amount of $50,000 from First Southern Bancorp account number 80063015 in Kentucky, in the name of Lake Cumberland Marine LLC, deposited to Bank of Hawaii account number 1447165 in Hawaii, in the name of Tradewinds Southwest, Inc.
55	December 26, 2001	Wire transfer of funds in the amount of $400,000 from Somerset National Bank in Kentucky, deposited to Bank of Hawaii account number 1447165 in Hawaii in the name of Tradewinds Southwest, Inc.

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

VI.

COUNTS 56 through 64

(Engaging in Monetary Transactions with Proceeds of Unlawful Activity)

1.	On or about the dates set forth below, within the Western District of Washington, and elsewhere, the defendant, KEVIN L. LAWRENCE, together with other persons known and unknown to the Grand Jury, did knowingly and willfully engage and attempt to engage in the monetary transactions set forth below by, through, and to the financial institutions identified below, which monetary transactions affected interstate and foreign commerce, in criminally derived property of a value greater than $10,000, such property having been derived from specified unlawful activities, that is mail fraud, wire fraud, and securities fraud; each deposit of funds set forth below constitutes a representative sample of such monetary transactions and a separate count of this Indictment, as follows:

Count	Date	Description of Financial Transaction
56	August 14, 2000	Deposit of cashier's check number 5021882267 in the amount of $88,570, drawn on funds from U.S. Bank account 153500122400, in Bainbridge Island, Washington, in the name of Health Maintenance Centers, Inc., to U.S. Bank account number 153590383896 in the name of National Alliance, Inc., Management Trust Account for Performance Consult.
57	September 1, 2000	Deposit of cashier's check number 5022187023 in the amount of $26,180, drawn on funds from U.S. Bank account 153500122400, in Bainbridge Island, Washington, in the name of Health Maintenance Centers, Inc. to U.S. Bank account number 153590383896 in the name of National Alliance, Inc., Management Trust Account for Performance Consult.
58	February 9, 2001	Deposit of check number 1005 in the amount of $28,880, drawn on First Mutual Bank account number 00724025200, in Bellevue, Washington, in the name of HMC Inc, - American Integrated Health, to U.S. Bank account number 153590383896 in the name of National Alliance, Inc., Management Trust Account for Performance Consult.
59	February 13, 2001	Deposit of check number 1013 in the amount of $64,360, drawn on First Mutual Bank account number 00724025200, in Bellevue, Washington, in the name of HMC Inc, - American Integrated Health, to U.S. Bank account number 153590383896 in the name of National Alliance, Inc., Management Trust for Performance Consult.
60	February 27, 2001	Deposit of check number 1032 in the amount of $22,450, drawn on First Mutual Bank account number 00724025200, in Bellevue, Washington, in the name of HMC Inc, - American Integrated Health, to U.S. Bank account number 153590383896 in the name of National Alliance, Inc., Management Trust Account for Performance Consult.
61	March 8, 2001	Deposit of check number 1047 in the amount of $143,000, drawn on First Mutual Bank account number 00724025200, in Bellevue, Washington, in the name of HMC Inc, - American Integrated Health, to U.S. Bank account number 153590383896 in the name of National Alliance, Inc., Management Trust Account for Performance Consult.
62	March 22, 2001	Deposit of check number 1064 in the amount of $19,650, drawn on First Mutual Bank account number 00724025200, in Bellevue, Washington, in the name of HMC Inc, - American Integrated Health, to U.S. Bank account number 153590383896 in the name of National Alliance, Inc., Management Trust Account for Performance Consult.
63	April 2, 2001	Deposit of check number 1072 in the amount of $119,871.38, drawn on First Mutual Bank account number 00724025200, in Bellevue, Washington, in the name of HMC Inc, - American Integrated Health, to U.S. Bank account number 153590383896 in the name of National Alliance, Inc., Management Trust Account for Performance Consult.
64	April 16, 2001	Deposit of check number 1092 drawn on First Mutual Bank account number 00724025200, in Bellevue, Washington, in the name of HMC Inc, - American Integrated Health, in the amount of $31,066 to U.S. Bank account number 153590383896 in the name of National Alliance, Inc. Management Trust Account for Performance Consult.
All in violation of Title 18, United States Code, Sections 1957 and 2.

VII.

CRIMINAL FORFEITURE ALLEGATIONS

Upon conviction of the offenses charged in Counts 1 through 50 of this Indictment, defendant KEVIN L. LAWRENCE shall forfeit to the United States, pursuant to Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c), any property constituting or derived from proceeds obtained directly or indirectly as a result of the such offense, including but not limited to the following:

1.	One (1) Brequet Type XX Men's Watch, Model No. 4227;

2.	One (1) Rolex Oyster Men's Watch;

3.	One (1) Tag Heuer Men's Watch, Model #WG1120-KO;

4.	Five (5) Swords, more fully described as follows:

a.	one (1) sword with a large lion face guard (larger of the two), maker unknown;

b.	one (1) Jemadar dagger by Jose De Braga;

c.	one (1) sword with a large lion guard (smaller of the two), maker unknown;

d.	one (1) Bektran dagger by Jose DeBraga; and

e.	one (1) Vektran sword by Jose DeBraga;

5.	One (1) 1978 Mako vessel, serial # MRK106070478M25 & EZ Loader trailer, VIN # 1ZE1S428PAN24310;

6.	One (1) 1999 Yamaha Wave Runner jet ski, Serial # YAMA4636C999, and 1999 Shore Land'r trailer, VIN #1MDH1MJ17XA066535;

7.	One (1) 2001 Ferrari F-1 360 Modena Spyder, VIN #ZFFYT53A210123121, or the proceeds from the interlocutory sale of the 2001 Ferrari F-1 360 Modena Spyder;

8.	One (1) 1990 Donzi vessel, Serial # DMRA083L990, and 1991 Trail Rite boat trailer, VIN # 1T0BS10TXMS115882;

9.	One (1) 2000 Mercedes-Benz G-Wagen Brabus Cabriolet, VIN # WDBEG4069Y7121043;

10.	One (1) 2000 AM General Hummer 4 door, VIN # 137ZA843XYE190060;

11.	One (1) 1996 Black AM General Hummer, VIN #137ZA9038TE170751;

12.	One (1) 2001 Ducati 996SPC Motorcycle, VIN # ZDM1SB5T31B010092;

13.	One (1) 2001 Yamaha YFM 600 Grizzly ATV, VIN # JY4AJ02Y31A003778;

14.	One (1) 2001 Yamaha YFM 600 Grizzly ATV, VIN # JY4AJ02Y91A004658;

15.	One (1) 1972 De Tomaso Pantera, VIN # THPNLJ02144; and

16.	One (1) 1983 De Tomaso Pantera, VIN # THPNAR09259.

If any of the above-described forfeitable property, as a result of any act or omission of the defendant:

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(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 jurisdiction of the Court;

(d)	has been substantially diminished in value; or

(e)	has been commingled with other property which cannot be divided without difficulty;

it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title 28, United States Code, Section 2461(c), to seek

forfeiture of any other property of said defendant up to the value of the forfeitable property described above.

A TRUE BILL:

DATED:

FOREPERSON

MARK BARTLETT

Acting United States Attorney

FLOYD SHORT

Assistant United States Attorney

RICHARD E. COHEN

Assistant United States Attorney

YE-TING WOO

Assistant United States Attorney

JEFFREY B. COOPERSMITH

Assistant United States Attorney