John Eckerd Federal Criminal Complaint 45t66

Case 2:18-mj-03556-MF Document 1 Filed 03/08/18 Page 1 of 8 PageID: 1

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

UNITED STATES OF AMERICA v.

:

Hon. Mark Falk

:

Mag. No. 18-

(MF)

JOHN ECKERD CRIMINAL COMPLAINT

I, James Muller, being duly sworn, state the following is trut. arid cor;i. to the best of my knowledge and belief: SEE ATTACHMENT A I further state that I am a Special Agent with the Federal Bureau of Investigation and that this complaint is based on the following facts: SEE ATTACHMENT B continued on the attached pages and made a part hereof.

James Muller, Special Agent Federal Bureau of Investigation *Agent Muller attested this Affidavit by telephone pursuant to FR 4.1(b)(2)(A) Sworn to telephonically pursuant to FR 4. 1(b)(2)(A) on the

March 8, 2018 Date

at

Esse.y, New Jer Co t St

or Judge Name and Title of Judicial Officer

Signature of Judicial Officer

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ATTACHMENT A COUNT ONE

(Conspiracy to Commit Money Laundering) From in or around September 2017 through in or around March 2018, in the District of New Jersey, and elsewhere, the defendant, JOHN ECKERD,

did knowingly and intentionally conspire and agree with others to commit an offense against the United States, to wit: With the intent to conceal and disguise the nature, location, source, ownership, or control of property believed to be the proceeds of specified unlawful activity, that is, narcotics trafficking, did knowingly conduct and attempted to conduct financial transactions involving property represented by a law enforcement officer to be the proceeds of specified unlawful activity, that is, narcotics trafficking, contrary to Title 18, United States Code, Section 1956(a)(3)(B). THE OBJECT OF THE CONSPIRACY

It was the object of the conspiracy that JOHN ECKERD and Co Conspirator-i would conduct financial transactions for their own pecuniary gain knowing that money used in those financial transactions was purported to be proceeds of narcotics trafficking. MANNER AND MEANS

It was part of the conspiracy that on numerous occasions between September 2017 and March 2018, JOHN ECKERD and Co-Conspirator-i engaged in phone calls with each other and others to discuss laundering money believed to be derived from the distribution of narcotics. It was further part of the conspiracy that, on at least three occasions between October 2017 and March 2018, JOHN ECKERD and Co-Conspirator-i met with and undercover law enforcement officer (“UCE- 1”) in the District of New Jersey and elsewhere to discuss the laundering of money, including the various methods that could be used by JOHN ECKERD and Co-Conspirator-i to conceal or disguise the nature, location, source, ownership, or control of property purported to be narcotics proceeds by a law enforcement officer.

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OVERT ACTS In furtherance of the conspiracy and to effect the illegal object thereof, the following acts, among others, were committed in the District of New Jersey and elsewhere: On at least two occasions between January 201$ and February 2018, JOHN ECKERD and Co-Conspirator-i received United States currency from UCE-1, as set forth in the chart below, and in exchange, JOHN ECKERD and Co-Conspirator-i wired money to UCE- l’s bank or provided UCE- 1 with a check, less an amount which JOHN ECKERD and Co-Conspirator-i retained as a fee for conducting the financial transaction. Date of Transaction

Amount Laundered

1/18/18

$100,000

2/23/ 18

$100,000

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

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COUNTS TWO Through THREE

(Money Laundering) On or about each of the dates set forth below, in the District of New Jersey and elsewhere, the defendant, JOHN ECKERD,

With the intent to conceal or disguise the nature, location, source, ownership, or control of property believed to be the proceeds of specified unlawful activity, that is, narcotics trafficking, did knowingly conduct or attempt to conduct financial transactions involving property represented by a law enforcement officer to be the proceeds of specified unlawful activity, that is, narcotics trafficking: Count

Date of Transaction

Amount Laundered

2

1/18/13

$100,000

3

2/23/18

$100,000

In violation of Title 18, United States Code, Section 1956(a)(3)(B).

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ATTACHMENT B

I, James Muller, am an agent with the Federal Bureau of Investigation (“FBI”). I am fully familiar with the facts set forth herein based on my own investigation, my conversations with other law enforcement officers, and my review of reports, documents, and items of evidence. Where statements of others are related herein, they are related in substance and part. Because this complaint is being submitted for a limited purpose, I have not set forth each and every fact that I know concerning this investigation. Where I assert that an event took place on a particular date, I am asserting that it took place on or about the date alleged. 1.

2.

At all times relevant to this Complaint: a.

Defendant JOHN ECKERD was a resident of the State of Texas.

b.

Co-Conspirator-i (“CC- 1”) was a resident of Union County, New Jersey.

c.

The “Development Project” is a high-end underground residential housing project in the area of Dallas, Texas. It is being marketed as a five star playground with DEFCON 1 preparedness (referring to the status of alert/level of readiness for imminent nuclear war) and consists of fortified shelters built to withstand catastrophic events from viral epidemics to nuclear war.

d.

CC-i used a limited liability company that, in reality, was a shell company (“Shell Company- 1”) to launder purported illicit money. Shell Company-i was located in Union County, New Jersey.

e.

UCE- 1 was an undercover FBI agent.

f.

UCE-2 was an undercover FBI agent.

On or about September 1, 2017, UCE-1 was introduced to CC-i, during an audio-recorded meeting, at a location in Cape May County, New Jersey. At that time, CC-i understood that UCE- 1 was a former narcotics trafficker who allegedly had large sums of cash from past illegal narcotics activity that UCE- 1 needed to launder. Later that evening, CC-i accepted $iO,000 in cash from UCE-i and in return, CC-i wrote out a check for $9,400 and handed it to UCE- 1. 4

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3.

On or about September 21, 2017, CC-i, UCE-1 and others met at a location in Atlantic County, New Jersey. During this audio-recorded meeting, CC-i discussed laundering UCE-i’s money through an associate in Dallas, Texas named JOHN ECKERD who was able to launder illicit proceeds through his Development Project. Later that afternoon, CC-i accepted $40,000 in cash from UCE-1 and in return, cc-i handed over two checks totaling $36,000.

4.

On or about October 5, 2017, CC-i, ECKERD, UCE-i and others met at a location in Atlantic County. During this audio-recorded meeting, UCE- 1 and CC-i had a conversation about UCE- l’s alleged past narcotics trafficking, the laundering of UCE-i’s supposed narcotics proceeds through the Development Project, and the laundering of Colombian drug money. That same evening, UCE- 1, ECKERD and CC-i had a separate conversation during which they discussed numerous topics related to laundering money. During the conversation, UCE- 1 made it known to both CC-i and ECKERD that the money to be laundered was from Colombians, thereby indicating that his cash was from narcotics trafficking. Later that same evening, UCE-i handed CC-i $50,000 in cash. CC-i later wrote a check in the amount of $45,000 and handed it to UCE-1.

5.

Between on or about October 16, 2017 and November 13, 2017, UCE- 1 provided CC-i with cash in amounts ranging between $35,000 and $60,000 on at least four occasions. During that same time period, CC-i made at least four cash deposits into Shell Company- l’s bank at bank locations in Union County.

6.

On or about December 13, 2017, CC-i, UCE-i, and others met at a location in Atlantic County. During the audio-recorded meeting, CC-i provided UCE-i with two checks totaling $40,500 in exchange for $45,000 in cash. CC-i asked UCE-1 if UCE-i had spoken to “the people down below yet,” referring to the people “in Florida,” which UCE- 1 understood was a reference to the supposed Colombian drug traffickers who would be laundering money through the Development Project.

7.

Two days later, on or about December 15, 2017, CC-i deposited $9,000 in cash into Shell Company-i’s bank at a bank in Union County.

8.

On or about January 18, 2018, CC-i, UCE-1, UCE-2 and others met During the audio-recorded at a location in Atlantic County. conversation, CC-i accepted $100,000 in cash from UCE-i. CC-i advised UCE- 1 that instead of receiving a check, the money, less a

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fee, would be wired back to UCE-1 by ECKERD. 9.

On or about January 24, 2018, law enforcement intercepted a phone call between CC-i and ECKERD. During the lawfully recorded conversation, ECKERD told CC-i that he would be getting a commitment for the $100,000 from “an air conditioning guy” to whom ECKERD described the transaction as a “quick flip.” (Conspirator-i and ECKERD were discussing the January 18, 2018 money laundering transaction.)

10.

On or about January 31, 2018, during a lawfully recorded call, CC 1 and ECKERD discussed the logistics of wiring money related to the January 18th $100,000 money laundering transaction between UCE-i, CC-i and ECKERD.

ii.

On or about February 1, 2018, during a lawfully recorded call, ECKERD asked CC-i if he transferred the money to UCE- 1. ECKERD told CC-i that the money wired for UCE- 1 was sent from ECKERD’s bank . CC-i advised ECKERD that he was short on cash for an real estate closing, and CC-i was going to ask UCE- 1 if CC- i could borrow a portion of the laundered funds from UCE- 1 for the real estate closing.

12.

Between on or about February 1, 2018 and February 10, 2018, three wire transfers in the amounts of $50,000, $25,000 and $20,000 were received in UCE-i’s undercover bank . The wire transfers originated from bank s associated with Shell Company-i.

13.

On or about February 12, 2018, during a lawfully recorded call, ECKERD and CC-i discussed conducting another $100,000 money laundering transaction with UCE- 1, which was supposed to take place in Texas. During the conversation, ECKERD warned CC-i that the drive between Houston and Dallas was a “corridor” and they discussed taking a “prop job.” (ECKERD was advising CC 1 that a small plane might be better to conceal their illegal activities from law enforcement rather than driving the closely monitored highway route between Houston and Dallas where law enforcement may stop a car and seize the cash.)

14.

On or about February 22, 20i8, ECKERD, CC-i, UCE-i, UCE-2 and others met at a location in Texas. During a lawfully recorded conversation, UCE- 1 explained to ECKERD that the cash supplied by UCE- i and the supposed Colombian drug traffickers was 6

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derived from illicit narcotics activity. UCE- 1 stated that UCE- 1 and the Colombians would both initially launder $1 million in narcotics proceeds through the Development Project and, alter a few months, the Colombians would “bump it up to two million a month.” ECKERD responded, “Right.” 15.

On or about February 23, 2018, CC-i, EcKERD, and UCE-i met at a location in Texas. UCE- 1 had a backpack containing $100,000 in purported narcotics proceeds. During this audio and video-recorded meeting, UCE- 1 told ECKERD that UCE- 1 and CC 1 had opened up the backpack and noticed that the bundles of cash from the supposed Colombian drug traffickers contained some twenty-dollar bills. CC-i noted that it would be easier to transport cash in higher denominations, and, ECKERD also noted, “That’s a lot of conversion.” UCE- 1 later accepted from UCE- 1 $100,000 in cash contained inside the backpack. In exchange, ECKERD provided a check in the amount of $90,000.

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