capital and amounting to several million dollars on most deals. This guarantee was to be produced within five to seven days on most transactions and was required prior to any funds being provided to the client. If the client could not produce the required guarantee within the stated time frame, the initiation fee would be forfeited.

Initially, prospective clients would be screened and referred by members of the group identified as "brokers". These "brokers" were responsible for obtaining proof that the prospective client had the ability to pay the initial fee prior to introducing them to anyone else in the group. This verification was done by requiring the client to produce a photocopy of a

cashier's check in the amount of the fee. The broker would then contact the bank to ensure that

the check was genuine. At this point, the client would be introduced to the next level of the group, identified as “syndicators." These individuals were responsible for communicating with the client directly and "closing" the transaction. Syndicators, after coordination with the group's management and attorneys, provided the contracts, correspondence, and conducted actual negotiations with clients.

After an initial review of documents, the syndicator advised the client that, in order to proceed, the initial fee must be transferred to a designated "escrow account". Once the funds are transferred, the syndicator then provides the client with documents which purport to verify that investors have "blocked" the funds necessary to finance the client's transaction and are awaiting the required payment guarantee to proceed. During this process, the client is also introduced to two additional segments of the organization identified as "facilitators" and "underwriters". "Facilitators" are identified to clients as business entities which will assist the client in

obtaining the required payment guarantee from a financial institution in exchange for an additional fee. One of the group's intemal memorandums seized during the execution of a search

warrant on the residence of Lawrence Sangaree specifically identifies how a facilitator should discuss the payment guarantee with the client when it states "The payment guarantee must be collateralized, that means it must be cash backed or no bank will issue it. But you do not call any attention to that until you have been paid. Period. No exceptions."

Another item contained in the group's contract involves a requirement that the client obtain the services of an "underwriter". This individual, also a group member, is ostensibly responsible for packaging the client's transaction and arranging for the sale of offshore stock in order to guarantee the repayment of the original capital within one year. As part of the original deal, clients were issued "preliminary pre-commitments" by individuals acting in the underwriter

role for another additional fee.

In reality, the group did not have access to the capital required to fund any of these transactions and the group's operations were specifically designed to go through the process in order to forfeit the original fee, which was then split up between members of the group according to an agreed upon schedule. In addition, many times the funds were not held in the escrow account until the client technically "defaulted", but were disbursed to members of the group when it was delivered. No clients ever received any funds.

Initially, Larry Sangaree began work with this group as a “broker” for Harry Alonso. In this capacity, Sangaree was responsible for making initial contacts with potential clients and introducing them to Alonso once they were qualified. During this period, Alonso utilized another form of financial transaction known as "financial guarantee bonds" as well as capital syndication. These transactions, although somewhat different in nature, still involved the payment of initial fees which were forfeited. Alonso introduced Sangaree to Les Mersky and

Jerrell Breslin.

Subsequently, Sangaree moved on to become a broker for another member of the group identified as Joseph Bremont, who also worked with Mersky and Breslin. The funds which allegedly backed the transactions conducted by the group during this time were represented by Miami attorney Jerrell Breslin. Breslin utilized a relationship with the president of Guardian Bank and Trust in the Cayman Islands, John Mathewson, to provide potential clients with verifications that millions of dollars existed to cover these deals.

In 1993, Jerrell Breslin elected to "retire" as the group's attorney due to the large number of complaints which had been generated by the business. Breslin was subsequently replaced by Tennessee attorney, Donald Jake Gamble. Gamble had been introduced to the group by Ed Neal and operated a company identified as Southeastern Financial Acceptance Corporation (SFAC). Gamble and SFAC's assets, which included a fraudulent Japanese yen bond, were utilized as the financial backing for transactions which were conducted by the group for a period of time.

Because of a number of factors, a decision was made by the group to attempt to establish

an offshore bank in a tax haven or bank secrecy country to be utilized in the organization's transactions. At that time, Antigua was selected because of group member Frank Dzwonkowski's relationship with government officials and bankers in that country.

After a series of discussions, the intial owners of the bank were to be Larry Sangaree, Ed Neal, Joe Bremont, Frank Dzwonkowski, and Donald Jake Gamble. Discussions and negotiations with the goverment of Antigua continued from August of 1993 until September of 1994 when the Caribbean American Bank was chartered. Stock in this bank was represented by two holding companies, Rharte Ltd. (Larry Sangaree) and BSS Capital Ltd. (Jake Gamble). Bremont, Neal, and Dzwonkowski were not included at the time of chartering.

After Gamble became the group's attorney, Sangaree moved from the job of broker and took over the role of "field operations manager". In this capacity, Larry Sangaree ensured that procedures were followed, documents were processed properly and that payments were made to organization members in accordance with agreements. The majority of this business including contracts, wire transfer requests, banking, and correspondence was handled via fax from Gainesville, Florida, to various locations throughout the United States, Antigua, and other countries. Sangaree also utilized the alias or "desk name" of Mitchell Porter during any required communications with actual or potential clients.

Eventually, Gamble also began receiving a large number of complaints from clients who had lost their money and desired to take a less public role in the group. Consequently, Larry Sangaree suggested Ronald A. Cohen as a replacement. In September, 1995, Cohen, Sangaree, and Dzwonkowski traveled to Antigua where they met with Donald Jake Gamble to handle the transition to operations by Cohen. Subsequently, the day-to-day communications with clients and members of the group were handled by Cohen and his secretary, Kathy Spurling. Gamble continued to represent the Caribbean American Bank and it's alleged investors who ostensibly had funds sufficient to back transactions negotiated by the group. Larry Sangaree continued to function as field operations manager until his arrest in February of 1997.

Throughout the period of his involvement with the group, Larry Sangaree participated

in at least 50 transactions in which clients lost funds. The total funds involved in these transactions is estimated, through analysis of records, to be at least $5,950,000.00. Normally, proceeds associated with these transactions were wire transferred to the Caribbean American Bank in St. Johns, Antigua, W.I. where they were subsequently deposited in Antiguan corporate bank accounts operated by the various members of the organization. These individuals,

including Larry Sangaree then directed via fax that their funds be wire transferred back into the United States to purchase assets including real estate, vehicles, vessels, and other items.

Specific transfers directed by Larry Sangaree include an August 10, 1994, $20,000.00 transfer from Antigua to a Merrill Lynch Investment Account at the Mellon Bank of Pittsburgh, Pennsylvania; a August 10, 1994, $15,000.00 transfer from Antigua to his wife, Terri Sangaree; a December 12, 1994, $10,000.00 transfer from Antigua to co-defendant Maxine Wolf (Barnum) at the Florida Credit Union in Gainesville, Florida; a December 14, 1994, $260,436.00 transfer from Antigua to Gainesville, Florida, for the purchase of real estate in Alachua County, Florida; and a March 18, 1995, $300,000.00 transfer from Antigua to Collins Realty, St. George Island, Florida, for the purchase of real estate in Franklin County, Florida. Each of these transfers involved funds which had been obtained from clients in the above described transactions.