UNITED STATES DISTRICT COURT
FILED: June 13, 2008
THE UNITED STATES CHARGES:
At all times relevant to this Information:
1. The defendant Frank Granizo was the President of a freight forwarder ("FF-1").
2. FF-1 is an entity organized and existing under the laws of Florida with its principal place of business in Pompano Beach, Florida. FF-1 is a licensed freight forwarder.
DESCRIPTION OF THE OFFENSE
3. Beginning at least as early as May 2001 until at least as late as January 2005, the exact dates being unknown to the United States, the defendant and an executive of a manufacturing company ("Company A") located in West Sayville, New York, willfully devised a scheme to commit wire fraud by depriving Company A of the honest services of the executive and allowing the executive to obtain money by means of materially false or fraudulent pretenses with regard to the procurement of freight forwarding services within the United States in violation of Title 18 U.S.C. §§ 1343 and 1346.
4. The executive and the defendant willfully devised a scheme to defraud in which the defendant agreed, in a series of meetings and telephone calls, to pay the executive monies. In exchange, the executive agreed to select FF-1 to provide freight forwarding services for Company A. In execution of this scheme, the defendant paid the executive approximately $28,000 in seventeen installments, which were made by wire transfer from the defendant in Florida to the executive's personal bank account in New York. In so doing, the defendant willfully entered into a scheme to defraud. The scheme to defraud deprived Company A of the honest services of its executive and permitted the executive to obtain monies by means of materially false or fraudulent pretenses. It was further part of the scheme and artifice that the defendant submitted invoices to Company A that incorporated the amount of the payments made to the executive without disclosing to Company A that such payments were made.
USE OF WIRES
5. As part of the scheme, and for the purpose of executing the scheme to defraud, beginning at least as early as May 2001 until at least as late as January 2005, the defendant, situated in Florida, made seventeen wire transfers of money into the defendant's bank account in New York. In addition, the defendant, situated in Florida, made numerous telephone calls to the executive, situated in New York, to arrange for the transfer of this money and the procurement of freight forwarding services.
JURISDICTION AND VENUE
6. The scheme charged in this Information was devised and carried out, in part, in the Eastern District of New York, within five years preceding the filing of this Information.
(Title 18, United States Code, Sections 1343 and 1346)