Professional Documents
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2006 To 2007 Predicate FACTS EVE Gusty Cicero MF Overlap Research
2006 To 2007 Predicate FACTS EVE Gusty Cicero MF Overlap Research
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Uncle Pete will always and forever be the uncle who fixed the
TV, took us to Kennywood on the rainy day Aunt
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Component(s):
USAO - Pennsylvania, Western
AA i justice.gov
Department of Justice
U.S. Attorney's Office
U=tJ;if;.
Western District of Pennsylvania
United States District Judge David Cercone imposed the sentence on Peter Cicero, 41.
The sentence also included a restitution order of approximately $3.6 million.
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-- AIIOnGeorgia
In May 2020, Agard submitted a fraudulent PPP
loan application for his business, Wild Stylz
Entertainment, LLC, to a financial institution. In
support of the application, Agard submitted
fraudulent supporting documents that made
numerous false and misleading statements
about Wild Stylz's number of employees and
payroll expenses. The financial institution
approved and funded a loan of over $395,000.
Agard disseminated the fraudulently obtained
funds to other members of the conspiracy to
conceal the true nature of their fraudulently
obtained funds. On May 27, 2020, Agard made
$200,000 counter withdrawal at a bank branch.
On May 28, 2020, Agard withdrew $50,000 in
cash and made a $96,000 counter withdrawal.
In June 2020, Duhart, Smith, and Lewis
requested that Hunt provide Duhart, Smith, and
Lewis with bank accounts in which to deposit
fraudulently obtained PPP funds. Hunt had
l lviously participated in drug trafficking and
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The indictment alleges that Agard also utilized
his business, Wild Stylz, to launder the proceeds
of other fraud schemes. In October of 2019,
Lewis recruited Duffield to participate in a fraud
scheme. As part of the scheme, Duffield allowed
Agard to transfer $378,000 of fraud proceeds
from the Wild Stylz business account to be
deposited into Duffield's business account in
return for a portion of the proceeds. After the
proceeds were deposited, Roosevelt Hunt (who
has pied guilty to related charges), Latourneau,
and Keane withdrew the funds from Duffield's
account by depositing checks totaling $200,000
at a casino. After gambling for less than two
hours, Hunt, Keane, and Latourneau cashed out
from the casino and left with approximately
$198,750 in cash. Lewis met with Hunt to
retrieve the cash which had been withdrawn
from Duffield's account. Lewis delivered a portion
of the cash he picked up from Hunt to Duhart.
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11/23/1988: Multiple sequential property transactions occur al of which were recorded as if there
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were one transaction reflected in one instrument. See Allegheny County US Land Records, Name
Search, results " Imperial House Condominium Assn. Inc." reflecting the following entry as recorded:
12/01/08 Mortgage, 14th Ward (sans property address( for 0.0 consideration at MB Vol.
· -462 (6 pgs.). These entries are deliberately false. First recorded papers begin at p. 460 not
21
In a lette r, Stanley Arnhcim wrote before he died in 1988, he explained that the trust, loyalty, and respect that the
partners had for each other led to the company's success. t Stanley Amhcim mcl Navy veteran Paul Neely. That
chance encounter led to the 1946 establishment of the commercial real estate brokerage firm of Amhcim & Neely Co.
Sec Tribune Review archives, h1tps://11rchivc.triblivc.com/ncws/clmncc-mccting-lcd-10-rcal-cs1111c-panncrship/
24 Brophie was an original straw purchase and conspirator in the fraudulent sales and purchases of apartments.
:, Maryland resident Brophie allegedly sell, unit 208 in consideouion ofS70k by inden1urc deed 10 Imperial House Condominium Assoc.. Inc. (no
rttord or chis en1i1y in Pa biz records b«ausc the Indenture was rttorded in Maryland on . Stt DE Book Vol. 7919, p, 179-1111.
462 and there are 7 pages not six. These entire deals were structured and recorded to conceal
criminal misconduct as described herein and elsewhere. See Exh. Carve Out Unit 208 and
recorded Instruments. The following conve yances are alleged to have occurred based on the
recorded Instruments as follows:26
mortgage is in favor of community savings Association 6319 Butler St. for the amount
of $56,000 due and payable unknown December I. 2003 for unit 208 and together
with \a .664904% and divided interest in the common clements appurtenant thereto
the condominium project known as Imperial house. and at as shown as defined in the
declaration plan as recorded in the recorder's office of Allegheny County plan book
volume I08. pages 126 to 39, and as amended by plan recorded in plan book volume
110 page 190 and in lhe D declaration of condominium bei ng recorded in volume 6 134
pagi; 337 and tugi;thcr. .. Said unit 208 and .6690% undivided intt.:ri;~t in thi; cummun
clements granted thcre10
Second, at MB Vol. 10069-462, is a one-page Mortgage Rider executed by IMCA, Inc., Herbert R.
Miller and another individual as secretary and references a non-existent property as follows: 208
Munhall Road, Pittsburgh PA 15217 NOT 5600 Munhall Road, Unit 208. conveying interest in the
"Condominium Proj ect" known as "Imperial House." This record constitutes evidence of mortgage
and deed fraud because it refers and describes a non-existe nt Condominium Project at 208 Munhall
Road NOT 5600 Munhall, Unit 208
Third, al MB Vol 10069-463-465 are seemingly, conflated, excerpts of versions of different Freddie/;
Fannie Uni form Instrument, namely, Form 3 170 and 1685, styled as a 1-4 Family Rider" and -
Assignment of Rents. See MB Vol. 10069-462-465. These pages described and referenced the interest
conveyed to Bank as specific to the nonexistent "Condominium Project at 208 Munhall Road." and the
instrument was executed a Herbert R. Miller in front of Community Saving Bank, counsel: Michael
allegedly notarized the instruments. Id. at 465. " See entire 1999 supra for satisfaction
aa n
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ly Rider is mandatory for all Mortj?a_2;es secured by 2-4-unit properties and originated using
ic Mac/Freddie Mac Uniform Instruments. Sec e.j?., Exhibit 4 Cfrcddicmoc com) viewed Mar.
25. Typically, a 1-4 Family Rider - any residential property of I to 4 units that is rented out (i.e., investment
property). Ir the vacation home is also rented for more weeks than is allowed (there's a margin allowed, don't
rememher hnw m:1nv week~ 1h:11 i~\. o r :1hem:11ivelv - if 1hc hnrrnwer tlne~n'I livt!: in rhe vac:11inn hnme: fnr 1he
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-- single family Freddie/Fannie Single Family Uniform Inslrumenl, Form 3140 v. 12.83,
containing.
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mortgage is in favor of community savings Association 6319 Butler S1. for the amount
of $56,000 due and payable unknown December I, 2003 for unil 208 and together
with \a .664904% and divided interest in the common clcmcnls appurtenant thereto
the condominium project known as Imperial house, and at as s hown as defined in the
dec laration plan as recorded in the recorder's office o f Allegheny County p lan book
volume I 08, pages 126 to 39, and as amended by plan recorded in p lan book volume
11 0 page 190 and in the D declaration of condominium being recorded in volume 6 134
page 337 and together ... Said unit 208 and .66900/o undivided interest in 1hc common
clements granted 1hcrc10
Second, at MB Vol. 10069-462, is a one-page Mortgage Rider execute d by IMCA, Inc., Herbert R.
Miller and another indiv idual as secretary a nd references a non-existent pro perty as follows: 208
Munhall Road, Pillsburgh PA 152 17 NOT 5600 Munhall Road, Unil 208. conveying inleresl in the
..Condominium Project" known as .. Imperial Ho use." This record c onstitutes evidence of mortgage
and deed fraud because ii refers and describes a non-exis1en1 Condominium Project al 208 Munhall
Road NOT 5600 Munhall, Unit 208
Third, at MB Vol 10069-463-465 are seemingly, conflated, excerpts of versions of different Freddie/;
Fannie Uniform lnslrumenl, namely, Form 3 170 and 1685, styled as a 1-4 Family Rider 27 and -
Assignment of Rents. See MB Vol. 10069-462-465. These pages described and referenced lhe inleresl
conveyed to Ba nk as specific to the nonexistent " Condominium Project at 208 Munhall Road ." and the
instrument was executed a Herbert R. Miller in front of Community Saving Bank, counsel: Michael
Georgalas, w ho allegedly notarized the instruments. Id. at 465. 28 See e ntire 1999 supra for satisfaction
?7Use of the 1-4 Family Rider is mandatory for al l Mort~a~es secured by 2-4-unit properties and originated using
the single-family Fannie Mac/Freddie Mac Uniform Instruments. Sec e.~.• Exhibit 4 (frcddicmac com) vie wed Mar.
25, Typically, a 1-4 Family Rider = any residential property of I to 4 units that is rented out (i.e., investment
propeny). If the vacation home is also rented for more weeks than is allowed (there's a margin a llowed, don't
remember how many weeks that is), o r alternatively - if the borrower doesn't live in the vacation home for the
required minimum number of weeks, it's going to fall under this category.
" Moreover, based on public records regarding a standard Form 3 170 strongly suggests thal the
conspirators co nflaled al leas! two different Fannie/;Freddie Uniform Instrument Forms 10 conceal 1ha1 ( I)
thal lhe units conslilute unregistered securities for rent being held for investment purposes, (2) lo conceal
the facl 1ha1 Bank was trying 10 make up ils losses on the original inveslmenl by a scheme 10 evade lhe
of mortgage fraudulent ly recorded as related 10 a different enlily, supra, Section 1999 and MB 10356-
344, searchable and discoverable under lhe name, "Imperial Associates" -- lhe long defunct joinl
partnership.
• Michael De lla Vecchio lhcn- recorder recorded at volume book 79 19 page 18 2 has no LJ r by or
ichacl Gcor~c Gowers cert ifying that precise residence of the 2n ntee Is
avin2s Associallon 43 19 Butler SI., Pittsburgh PA" 1~201 witnessed on
cc n , 1988 but recorded o n December I
cc '-'\ rophic ..Deed''
10 INHC assoc. inc) recorded in Pe nnsylva nia as assigned to
a,
cd wi1h Brophic sale Deed BK Vol. 1212,_~. 182, 178-8 1.
• 3:42PM. Pennsylvania Recorde r records BA NKS security interes t in the e ntirety of unit 20 8
inaccurately described as 208 imperia l h ouses a s if it were the entire development 1101 jus1 a unit
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