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transaction to one or more of the escrow accounts set up at the direction of Larry Sangaree and controlled by DONALD JAKE GANBLE or to Ronald Allan Cohen, an attorney from Coolidge, Georgia, who, at Larry Sangaree's direction, DONALD JAKE GAMBLE later designated as his substitute. After the funds vere receivad, the victims vere routinely informed by the individuals described in paragraph C that they had breached one or more of these conditions of the agreement and thus, their funds had been forfeited.

F.

Southeastern Financial Acceptance Corporation

(SEPAC) was a corporation formed by DONALD JAKE GAMBLE and operated by him initially to collect outstanding and delinquent account receivables of other companies. SEFAC vould also be utilized to receive money and funds derived from the result of specified criminal activity set forth in this information and defined in Title 18, United States Code, Section 1956 (c) (7). SEFAC was co-located and its activities were conducted from the law office of DONALD JAKE GAMBLE.

G. Larry Glynn Sangaree utilized the services of DONALD JAKE GAMBLE in order to promote and conduct his multimillion dollar, international in scope, vire and mail fraud advance fee swindle scheme.

These services utilized by Larry Glynn sangaree and his

associates included:

1. To act as the "escrow agent" for the purpose of receiving hundreds of thousands of dollars each

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2.

3.

4.

from dozens of individuals and businessmen, bereinafter "victims," throughout the United states and internationally who ware in need of venture capital funds for a variety of purposes; To open, establish and utilize attorney escrow accounts with banks, both domestic and foreign, to recciva, transmit and launder the funds received from the victims;

To assist in the formation of an off-shore bank known as the Caribbean American Bank (CAB), St. John's Island, Antigua, for the purpose of promoting and conducting the activities of the scheme.

DONALD JAKE GAMBLE would and did serve as a director and general counsel for CAB and would and did establish or caused to be established escrow and other accounts vherein CAB would be utilized to receive the funds derived from the scheme as well as to promote the scheme itself; To assist in the formation of foreign off-shore corporations in Antigua for use by other members of the scheme, that is, DONALD JAKE GAMBLE would wire transfer funds received from the victims to an account which he had established for and on behalf of CAB at American International Bank (AIB), an Antiguan bank, which in turn had

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established accounts with American and Canadian

banks.

II. On or about November 16, 1994, in the Middle District of Tennessee, and elsewhere, DONALD JAKE GAMBLE knowingly and willfully engaged and attempted to engage in a monetary transaction, affecting interstate commerce, in criminally derived property of a value greater than $10,000 which was derived from a specified unlawful activity, that is, the scheme and artifice to defraud individuals and businessmen of money, as set forth in paragraph I, in that DONALD JAKE GAMBLE engaged in a monetary transaction, that is the wire transfer of $169,900 from an account which CAB maintained with American International Bank, Antigua, through an account at Bank of America, New York, for final credit to an account at Bank of Roane County, Kingston,

Donald Ray Gamble a/k/a Donald Jake Gamble is a resident of Kingston, Tennessee, and has his law office in Crossville, Tennessee, where, among other things, he has engaged in the general practice of law. He was born in 1942, and graduated from the YMCA Night Lav School, now the Nashville School of Lav in 1977.

In 1987, Hr. Gamble, along with another individual, formed the Southeastern Financial Acceptance Corporation (SEPAC) to purchase the account receivables of Cumberland Loan and Thrift which was in bankruptcy. SEFAC is co-located at Gamble's lav office and its primary legitimate source of income comes from the collection of delinquent accounts of various companies and businesses located in the Cumberland Plateau region of Tennessee. In 1993, Gamble vas introduced to Lawrence Glynn Sangaree a/k/a Larry Sangaree and Frank Dzwonkowski by a third party who in the past had had dealings with both Gamble and Sangaree.

Larry Sangaree and Frank Devonkovski are both residents of Florida and vere initially represented to Gamble as being legitimate businessman who wanted to establish an offshore bank in Antigua, West Indies. In truth and in fact, Larry Sangaree was

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convicted in Florida of first degree murder in 1970, and although sentenced to life imprisonment, was released from prison in the late 80's and remained on supervision until 1995. Sangarea bas no known and confirmed legitimate source of income or employment although he has asserted to Gamble that he owns some shrimp boats that are titled in the names of third parties. Frank Dzwonkovski also is a convicted felon having been convicted in federal court for the possession of a controlled substance and conspiracy to distribute came in the Southern District (Miami Division) of Florida in the 1980's. He likewise has no known legitimate source of employment and his income is believed to be derived solely from the funds received from the fraudulent scheme set forth in the information. The information regarding Sangarea's and Dzwonkowski's criminal past was not something which Gambla knew from the outset of his association with these men, but was learned over the course of his association with them.

to,

Dzwonkowski informed Gamble that he had contacts vith the prime minister of Antigua who would assist in chartering the bank. In mid 1993, Gamble accompanied Sangaree and Dzvonkovski on a chartered flight to Antigua where they were met by members of the prime minister's family. According to Gamble, no bank was formed during this visit due to the fact that the prime minister's familywould not allow a bank to be formed unless they received an ownership interest and vere paid a large sum of money, that is, a bribe to do so. Sangaree and Davonkowski refused to pay the bribe and the men left the island.