attention away from the first payment - which is the only payment you will see but he doesn't know that." Additionally, the document states "FOR YOUR INFORMATION the 2nd and 3rd payments will never come. You all are in it for the first payment.

However, you act like you are after all 3 payments."

Further, the same document also states "What all the clients refuse to see, just plain do not understand is that in Section 3 the Syndication Agreement demands that the Payment Guarantee be COLLATERALIZED. That means it must be cash backed or no bank will issue it. It is the clients responsibility to do that. However, you do not call any attention to that UNTIL you have been paid. Period. No exceptions." Later on, the document also makes another comment about the "client" by stating "He is right where you want him. He is desperate."

On March 21, 1997, Peter BARNUM was interviewed at the Main Post Office in Gainesville, Florida by Postal Inspectors Lou Keith and John Sternberg. During the course of this interview, BARNUM was shown documents which indicated that he was a "facilitator" for the group which included SANGAREE. BARNUM advised the inspectors that he had been involved in this for approximately two years and that he believed that it was legal. Mr. BARNUM also advised the Postal Inspectors that the 1996 Jeep Cherokee seized at the SANGAREE residence belongs to BARLOW ENTERPRISES. BARNUM also told the inspectors that he and his wife, Maxine, were "BARLOW ENTERPRISES."

On August 6, 1997, a federal grand jury in Tallahassee, Florida, indicted Larry SANGAREE, AKA Mitchell PORTER, Terri SANGAREE, Peter Albert BARNUM, AKA Dennis MCGREGOR, and Maxine BARNUM, AKA Maxine WOLF, on money laundering conspiracy charges arising out of the operation of the fraudulent venture capital scheme. Further, Count II of this indictment provides for the criminal forfeiture of certain real property including a parcel purchased by the BARNUM's in the name of

BARLOW ENTERPRISES LTD located on Northeast County Road 1474 in Alachua County, Florida. This indictment was sealed by order of the court at that time.

According to information provided to your affiant by IRS-CID S/A Mary Clark, S/A Clark and another IRS-CID agent went to the previously identified Gainesville, Florida residence of Peter and Maxine BARNUM located at 5325 SW 77th Terrace on August 6, 1997, for the purpose of conducting an interview concerning income tax issues. At that time, S/A Clark was informed by the individuals occupying the residence that the BARNUM's had sold the residence and moved. S/A Clark and the other agent subsequently went to the property located at 23507 East County Road 1474 in Alachua County, Florida. At this location, S/A Clark advised that she knocked on the door and was met by Peter BARNUM and Maxine BARNUM. S/A Clark also advised that she observed several vehicles parked at this location including a white GMC pickup truck, a green GMC Jimmy, and an older blue Jeep. Your affiant is aware through Florida registration records that the white GMC pickup truck is registered to Peter BARNUM, the green GMC Jimmy is registered to Maxine BARNUM, and the older blue Jeep is registered to BARLOW ENTERPRISES LTD. S/A Clark advised your affiant that Pete BARNUM told her that he had consulted an attorney and did not wish to talk to the agents. At this point, S/A Clark indicated that she and the other agent left the property.

On August 14, 1997, your affiant traveled to the BARNUM residence located at 23507 East County Road 1474 in Alachua County, Florida for the purpose of serving a federal arrest warrant on Maxine Marie BARNUM. Your affiant was assisted by other law enforcement officers including a uniformed Alachua County Deputy Sheriff who was operating a marked Sheriff's Department vehicle. When agents arrived at the residence, Maxine BARNUM was observed looking out of a window adjacent to the garage door. At the time of her observation out this window, the Alachua County Sheriff's vehicle was parked in plain view within twenty-five feet of this window. Your affiant then went to the front door of the residence, knocked several times, and announced that agents had a warrant for Maxine BARNUM's arrest. Over a period of

several minutes, no response was received from BARNUM. Subsequently, your affiant, who was standing on the other side of the entrance door, heard what appeared to be the sound of the action of a pump shotgun being operated. Officers then retreated and directed BARNUM to drop her weapon and exit the residence. Subsequently, BARNUM was observed to open the door with a pistol grip shotgun in her hand. BARNUM was again directed to drop the weapon. BARNUM then went back inside the residence for a short period and reappeared at the doorway without the weapon being visible. Agents then took BARNUM into custody.

Your affiant and other officers then entered the residence and briefly looked inside each room to determine if Terri SANGAREE or other persons who might present a threat were present. During this protective sweep, your affiant observed a computer installation, file cabinet, fax machine, and a large number of files located in the garage area. The files observed by your affiant were similar to other files recovered from the BARNUM's vehicle during the February search of the SANGAREE residence. Subsequently, your affiant secured the residence and directed supporting agents to maintain this condition until directed otherwise.

Based on the foregoing facts and circumstances, your affiant believes that Larry SANGAREE, Terri SANGAREE, Peter Albert BARNUM, Maxine BARNUM, and others are involved in the continuing perpetration of a sophisticated venture capital scheme which is designed specifically to ensure that prospective "clients" can not comply with the contracts and other documents, thereby forfeiting to the violators the required “upfront" fee or fees. The violators also make extensive use of offshore corporations, principally in Antigua, W. I., to shield themselves from investigation and lend credibility to their assertion that they have access to funds from unidentified offshore investors. Additionally, fees received from victims are, at the direction of the violators, transferred offshore through AMERICAN INTERNATIONAL BANK accounts in Canada, Switzerland, Germany, and elsewhere, ultimately ending up in the CARIBBEAN AMERICAN BANK in St. Johns, Antigua. As indicated in previous paragraphs, funds

have already been traced from victims to AMERICAN INTERNATIONAL BANK correspondent accounts in the U.S. and CARIBBEAN AMERICAN BANK Accounts in Antigua, W.I. These funds have also been traced as they are returned to the violators to purchase a variety of assets, including the residences of Larry SANGAREE in both Alachua and Franklin counties, a residence for Donald Jake GAMBLE, as well as BMW and Lexus automobiles for GAMBLE.

The group of violators makes extensive use of a variety of documents, including contracts, escrow agreements, wire transfer coordinates, underwriting agreements, and other written instruments to accomplish their "transactions." This observation is supported by your affiant's review of documents from a number of violators, records obtained during the search warrant executed on SANGAREE's residence, and those instruments recovered from Jessica MAUN. This review by your affiant indicates that the group makes extensive use of facsimile machines for the transmittal of these and other internal documents. Further, computer files found during the search of SANGAREE's residence and BARNUM's vehicle, coupled with instructions found in documents obtained from Jessica MAUN, indicates that the group also makes extensive use of computers, both laptops and other systems, to generate and store these documents. The seizure of a secure fax machine, secure telephone system, three (3) computers, a satellite telephone communications system, and numerous documents from the residence and office of SANGAREE support this indication.

Based on the above and the observation on August 14, 1997, during the arrest of Maxine BARNUM, there exists, in your affiant's opinion, probable cause to believe that Larry SANGAREE, Terri SANGAREE, Peter Albert BARNUM, Maxine BARNUM, and their associates have been involved in violations of Title 18, United States Code, Section 1343 (Fraud by Wire), Title 18 United States Code, Section 1956 (Money Laundering), and Conspiracy to violate the above. Additionally, your affiant believes that there is probable cause to believe that certain documentary evidence, further described in Exhibit B, of these violations will be found in a search of the residence of

believe that on the person of or on the premises known as (name, description and/or location)

who has reason to

concealed a certain person or property, namely (describe the person or property)

See Above Description

I am satisfied that the affidavit(s) and any recorded testimony establish probable cause to believe that the person or property so described is now concealed on the person or premises above-described and establish grounds for the issuance of this warrant.

YOU ARE HEREBY COMMANDED to search on or before

9 May 1998

(not to exceed 10 days) the person cr place named above for the person or property specified, serving this warrant and making the search (in the daytime--6:00 A.M. to 10:00 P.M.) (at any time in the day ornightest find

reasonable cauce has been established) and if the person or property be found there to seize same, leaving a copy of this warrant and receipt for the person or property taken, and prepare a written inventory of the person or property seized and promptly return this warrant to the undersigned