2023-11-09 DOJ SDNY complaint 354 KB 8,653 chars

United States v. ISAAC BRIGGS III; and DERRICK HODGE, No. 1:23-cr-00673, Southern District of New York (Nov. 9, 2023) — Complaint

raw: United States v. ISAAC BRIGGS III and

United States v. ISAAC BRIGGS III and, No. 1:23-cr-00673 (S.D.N.Y. Nov. 9, 2023)

Caption
UNITED STATES OF AMERICA v. ISAAC BRIGGS III and DERRICK HODGE
summary

Derrick Hodge and Isaac Briggs III face charges of conspiracy to commit wire fraud, money laundering, and aggravated identity theft for a $7 million investment scheme.

paragraph

The defendants allegedly orchestrated a fraudulent scheme through Heritage Integrity Investment Trust (HIIT) between August 2020 and November 2023. They are charged with conspiracy to commit wire fraud, money laundering, and aggravated identity theft involving approximately $7 million in investor funds. The complaint alleges the defendants used false promises regarding trading programs and misappropriated funds for personal luxury expenses.

narrative

Derrick Hodge and Isaac Briggs III have been charged in a sealed criminal complaint in the Southern District of New York for a multi-year investment fraud scheme. Operating through Heritage Integrity Investment Trust (HIIT) from August 2020 to November 2023, the defendants allegedly defrauded investors of approximately $7 million. The scheme involved making false promises of high returns from non-existent trading programs and misrepresenting funds as being held in zero-coupon bonds. The defendants are charged with conspiracy to commit wire fraud, wire fraud, conspiracy to commit money laundering, and aggravated identity theft. While approximately $5.2 million was returned to some victims, roughly $1.5 million remains unreturned and was allegedly diverted for personal luxury expenses. Additionally, the complaint alleges that Briggs III used his father's identity to open brokerage accounts to facilitate the fraudulent operations.

Enriched metadata

Scheme
financial-fraud (95%)
Court
Southern District of New York
Case No.
1:23-cr-00673
Outcome
pleaded · 2004-06-10
Victim loss
$7,000,000
Classified financial-fraud(confidence 95%). EDGAR detection: forms 10-K/10-Q/8-K/NT 10-K· recall 67% / precision 23%. detection rule →
Statutes
Title 18, United States Code, Section 1343Title 18, United States Code, Section 1349Title 18, United States Code, Sections 1956(a)Title 18, United States Code, Section 1957(f)Title 18, United States Code, Section 1957(a)Title 18, United States Code, Section 1956(h)Title 18, United States Code, Section 1028A(c)Title 18, United States Code, Sections 1028A(a)
Parties
United States of AmericaISAAC BRIGGS IIIDERRICK HODGE
Keywords
hiitbriggsvictim-iiiisaac briggsbrokerage accounthiit brokeragebankaccountbrokeragehodgeaboutinvestor fundsfundsinvestor

Extracted insights

Entities 8
  • person conspiracy period
  • person daniel onove ii
  • person derrick hodge
  • person isaac briggs iii
  • scheme_term money laundering
  • agency special agent with fbi
  • person william c. kinder
  • scheme_term wire fraud
Triples 14
  • Derrick Hodge conspired to commit Wire Fraud
  • Isaac Briggs III conspired to commit Wire Fraud
  • Derrick Hodge engaged in scheme to obtain Investor Funds Through False Statements
  • Isaac Briggs III engaged in scheme to obtain Investor Funds Through False Statements
  • Derrick Hodge conspired to commit Money Laundering
  • Isaac Briggs III conspired to commit Money Laundering
  • Derrick Hodge transmitted Interstate Emails, Telephone Calls, Wire Transfers
  • Isaac Briggs III transmitted Interstate Emails, Telephone Calls, Wire Transfers
  • William C. Kinder is AUSA
  • Daniel Onove II is Special Agent with FBI
  • Conspiracy Period occurred from August 2020 Through November 2023
  • Violations include 18 U.S.C. §§ 1343, 1349, 1956(h), 1028A, and 2
  • Case filed in Southern District of New York
  • Case Number is 23 MAG 7107
Text layers
Extracted body text (8,653c)
--- page 1 ---

'
    UNITED STATES DISTRICT COURT
    SOUTHERN DISTRICT OF NEW YORK

     UNITED STATES OF AMERICA                             INDICTMENT

                           V.                             23 Cr.

     JYSHUN TROWER,
            a/k/a "JD," and
     STIVEN ARTURO MARTINEZ NIN,

                                Defendants.
                                                       23 CR1M 673
                                              COUNT ONE
                                      (Unlicensed Firearms Dealing)

           The Grand Jury charges:

           1.      From at least in or about June 5, 2023, through at least in or about September 29,

    2023 , in the Southern District of New York and elsewhere, JYSHUN TROWER, the defendant,

    not being a licensed importer, licensed manufacturer, or licensed dealer of firearms within the

    meaning of Chapter 44, Title 18, United States Code, willfully engaged in the business of dealing

    in firearms, and in the course of such business shipped, transported, and received a firearm in

    interstate and foreign commerce, and aided and abetted the same, to wit, TROWER illegally sold

    firearms in Manhattan, New York.

                      (Title 18, United States Code, Sections 922(a)(l)(A) and 2.)

                                           COUNT TWO
                      (Interstate Transportation and Distribution of Firearms)

           The Grand Jury further charges:

           2.     From at least on or about June 5, 2023, through at least in or about September 29,

    2023 , in the Southern District of New York and elsewhere, JYSHUN TROWER, the defendant,

    not being a licensed importer, licensed manufacturer, licensed dealer, or licensed collector of

--- page 2 ---

'
    firearms within the meaning of Chapter 44, Title 18, United States Code, willfully transferred,

    sold, traded, gave, transported, and delivered a firearm to another individual, said person not being

    a licensed importer, licensed manufacturer, licensed dealer, or licensed collector of firearms within

    the meaning of Chapter 44, Title 18, United States Code, and knowing and with reasonable cause

    to believe that said person was not then residing in Virginia, the State in which the defendant was

    then residing, to wit, TROWER resided in Virginia and traveled to Manhattan, New York, where

    he sold firearms.

                         (Title 18, United States Code, Sections 922(a)(5) and 2.)

                                           COUNT THREE
                                  (Conspiracy to Distribute Narcotics)

           The Grand Jury further charges:

           3.       From at least on or about November 16, 2023 , through on or about December 14,

    2023, in the Southern District of New York and elsewhere, JYSHUN TROWER and STIVEN

    ARTURO MARTINEZ NIN, the defendants, and others known and unknown, intentionally and

    knowingly combined, conspired, confederated, and agreed together and with each other to violate

    the narcotics laws of the United States.

           4.       It was a part and an object of the conspiracy that JYSHUN TROWER and STIVEN

    ARTURO MARTINEZ NIN, the defendants, and others known and unknown, would and did

    distribute and possess with intent to distribute a controlled substance, in violation of Title 21,

    United States Code, Section 841(a)(l).

           5.       The controlled substance that JYSHUN TROWER and STIVEN ARTURO

    MARTINEZ NIN, the defendants, conspired to distribute and possess with intent to distribute was:

    (i) 400 grams and more of mixtures and substances containing a detectable amount of fentanyl,

    and (ii) 100 grams and more of mixtures and substances containing a detectable amount of para-

                                                      2

--- page 3 ---

fluorofentanyl , a fentanyl analogue, m violation of Title 21, United States Code, Section

841 (b )(1 )(A).

              (Title 21 , United States Code, Sections 846, 841(a)(l), and 841(b)(l)(A).)

                                            COUNT FOUR
                                            (Firearms Use)

        The Grand Jury further charges:

        6.         On or about December 14, 2023 , in the Southern District of New York and

elsewhere, JYSHUN TROWER, the defendant, during and in relation to a drug trafficking crime

for which he may be prosecuted in a court of the United States, namely, the drug trafficking crime

charged in Count Three of this Indictment, knowingly used and carried a firearm, and in

furtherance of such crime, possessed a firearm, and aided and abetted the use, carrying, and

possession of a firearm.

                     (Title 18, United States Code, Sections 924( c)(1 )(A)(i) and 2.)

                                      COUNT FIVE
      (Attempted Transfer of a Firearm for use in a Felony or Drug Trafficking Crime)

        The Grand Jury further charges:

        7.         On or about December 14, 2023, in the Southern District of New York and

elsewhere, JYSHUN TROWER, the defendant, knowingly transferred a firearm, and attempted to

do the same, knowing and with reasonable cause to believe that the fuearm would be used to

commit a felony and a drug trafficking crime, to wit, JYSHUN TROWER sold and attempted to

sell numerous firearms, including with large capacity magazines, along with fentanyl, to a

purchaser in the Manhattan, New York.

                         (Title 18, United States Code, Sections 924(h) and 2.)

                                                     3

--- page 4 ---

                                 FORFEITURE ALLEGATION

       8.       As a result of committing the offense alleged in Counts One, Two, Four, and Five

of this Indictment, JYSHUN TROWER, the defendant, shall forfeit to the United States, pursuant

to Title 18, United States Code, Section 924( d)(l) and Title 28 United States Code, Section

2461(c), any and all firearms and ammunition involved in or used in or intended to be used in said

offense, including but not limited to:

                a.     45 caliber rifle, serial number 4506575

                b.     9mm Glock pistol, serial number AZWl 95US

                c.     9mm Smith & Wesson pistol, serial number PJN5949

                d.     9mm Smith & Wesson pistol, serial number HXJ7545

                e.     9mm Taurus pistol, serial number TNI88096

       9.       As a result of committing the offense alleged in Count Three of this Indictment,

JYSHUN TROWER and STIVEN ARTURO MARTINEZ NIN, the defendant, shall forfeit to the

United States, pursuant to Title 21, United States Code, Section 853, any and all property

constituting, or derived from, any proceeds obtained, directly or indirectly, as a result of said

offense and any and all property used, or intended to be used, in any manner or part, to commit, or

to facilitate the commission of, said offense, including but not limited to a sum of money in United

States currency representing the amount of proceeds traceable to the commission of said offense.

                                    Substitute Assets Provision

        10.     If any of the above-described forfeitable property, as a result of any act or omission

of the defendant:

                a.     cannot be located upon the exercise of due diligence;

                                                  4

--- page 5 ---

               b.      has been transferred or sold to, or deposited with, a third person;

               c.     has been placed beyond the jurisdiction of the Court;

               d.     has been substantially diminished in value; or

               e.     has been commingled with other property which cannot be subdivided

               without difficulty;

it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p) and

Title 28, United States Code, Section 2461(c), to seek forfeiture of any other property of the

defendant up to the value of the above forfeitable property.

                           (Title 18, United States Code, Section 924;
                          Title 21, United States Code, Section 853; and
                           Title 28, United States Code, Section 2461.)

                                                                  ~®            LJ'Jlia/Y0._
       F                                                       DAMIAN WILLIAMS
                                                               United States Attorney

                                                 5
OCR text (8,988c · gpumon-ocr-api · 90% conf)
--- page 1 ---

Case 1:23-cr-00673-DLC Document 7 Filed 12/19/23 Page 1 of 5


'
    UNITED STATES DISTRICT COURT
    SOUTHERN DISTRICT OF NEW YORK

     UNITED STATES OF AMERICA                             INDICTMENT

                           V.                             23 Cr.

     JYSHUN TROWER,
            a/k/a "JD," and
     STIVEN ARTURO MARTINEZ NIN,

                                Defendants.
                                                       23 CR1M 673
                                              COUNT ONE
                                      (Unlicensed Firearms Dealing)

           The Grand Jury charges:

           1.      From at least in or about June 5, 2023, through at least in or about September 29,

    2023 , in the Southern District of New York and elsewhere, JYSHUN TROWER, the defendant,

    not being a licensed importer, licensed manufacturer, or licensed dealer of firearms within the

    meaning of Chapter 44, Title 18, United States Code, willfully engaged in the business of dealing

    in firearms, and in the course of such business shipped, transported, and received a firearm in

    interstate and foreign commerce, and aided and abetted the same, to wit, TROWER illegally sold

    firearms in Manhattan, New York.

                      (Title 18, United States Code, Sections 922(a)(l)(A) and 2.)

                                           COUNT TWO
                      (Interstate Transportation and Distribution of Firearms)

           The Grand Jury further charges:

           2.     From at least on or about June 5, 2023, through at least in or about September 29,

    2023 , in the Southern District of New York and elsewhere, JYSHUN TROWER, the defendant,

    not being a licensed importer, licensed manufacturer, licensed dealer, or licensed collector of

--- page 2 ---

Case 1:23-cr-00673-DLC Document 7 Filed 12/19/23 Page 2 of 5


'
    firearms within the meaning of Chapter 44, Title 18, United States Code, willfully transferred,

    sold, traded, gave, transported, and delivered a firearm to another individual, said person not being

    a licensed importer, licensed manufacturer, licensed dealer, or licensed collector of firearms within

    the meaning of Chapter 44, Title 18, United States Code, and knowing and with reasonable cause

    to believe that said person was not then residing in Virginia, the State in which the defendant was

    then residing, to wit, TROWER resided in Virginia and traveled to Manhattan, New York, where

    he sold firearms.

                         (Title 18, United States Code, Sections 922(a)(5) and 2.)

                                           COUNT THREE
                                  (Conspiracy to Distribute Narcotics)

           The Grand Jury further charges:

           3.       From at least on or about November 16, 2023 , through on or about December 14,

    2023, in the Southern District of New York and elsewhere, JYSHUN TROWER and STIVEN

    ARTURO MARTINEZ NIN, the defendants, and others known and unknown, intentionally and

    knowingly combined, conspired, confederated, and agreed together and with each other to violate

    the narcotics laws of the United States.

           4.       It was a part and an object of the conspiracy that JYSHUN TROWER and STIVEN

    ARTURO MARTINEZ NIN, the defendants, and others known and unknown, would and did

    distribute and possess with intent to distribute a controlled substance, in violation of Title 21,

    United States Code, Section 841(a)(l).

           5.       The controlled substance that JYSHUN TROWER and STIVEN ARTURO

    MARTINEZ NIN, the defendants, conspired to distribute and possess with intent to distribute was:

    (i) 400 grams and more of mixtures and substances containing a detectable amount of fentanyl,

    and (ii) 100 grams and more of mixtures and substances containing a detectable amount of para-



                                                      2

--- page 3 ---

Case 1:23-cr-00673-DLC Document 7 Filed 12/19/23 Page 3 of 5




fluorofentanyl , a fentanyl analogue, m violation of Title 21, United States Code, Section

841 (b )(1 )(A).


              (Title 21 , United States Code, Sections 846, 841(a)(l), and 841(b)(l)(A).)

                                            COUNT FOUR
                                            (Firearms Use)

        The Grand Jury further charges:

        6.         On or about December 14, 2023 , in the Southern District of New York and

elsewhere, JYSHUN TROWER, the defendant, during and in relation to a drug trafficking crime

for which he may be prosecuted in a court of the United States, namely, the drug trafficking crime

charged in Count Three of this Indictment, knowingly used and carried a firearm, and in

furtherance of such crime, possessed a firearm, and aided and abetted the use, carrying, and

possession of a firearm.


                     (Title 18, United States Code, Sections 924( c)(1 )(A)(i) and 2.)


                                      COUNT FIVE
      (Attempted Transfer of a Firearm for use in a Felony or Drug Trafficking Crime)

        The Grand Jury further charges:

        7.         On or about December 14, 2023, in the Southern District of New York and

elsewhere, JYSHUN TROWER, the defendant, knowingly transferred a firearm, and attempted to

do the same, knowing and with reasonable cause to believe that the fuearm would be used to

commit a felony and a drug trafficking crime, to wit, JYSHUN TROWER sold and attempted to

sell numerous firearms, including with large capacity magazines, along with fentanyl, to a

purchaser in the Manhattan, New York.

                         (Title 18, United States Code, Sections 924(h) and 2.)



                                                     3

--- page 4 ---

Case 1:23-cr-00673-DLC Document 7 Filed 12/19/23 Page 4 of 5




                                 FORFEITURE ALLEGATION

       8.       As a result of committing the offense alleged in Counts One, Two, Four, and Five

of this Indictment, JYSHUN TROWER, the defendant, shall forfeit to the United States, pursuant

to Title 18, United States Code, Section 924( d)(l) and Title 28 United States Code, Section

2461(c), any and all firearms and ammunition involved in or used in or intended to be used in said

offense, including but not limited to:

                a.     45 caliber rifle, serial number 4506575

                b.     9mm Glock pistol, serial number AZWl 95US

                c.     9mm Smith & Wesson pistol, serial number PJN5949

                d.     9mm Smith & Wesson pistol, serial number HXJ7545

                e.     9mm Taurus pistol, serial number TNI88096

       9.       As a result of committing the offense alleged in Count Three of this Indictment,

JYSHUN TROWER and STIVEN ARTURO MARTINEZ NIN, the defendant, shall forfeit to the

United States, pursuant to Title 21, United States Code, Section 853, any and all property

constituting, or derived from, any proceeds obtained, directly or indirectly, as a result of said

offense and any and all property used, or intended to be used, in any manner or part, to commit, or

to facilitate the commission of, said offense, including but not limited to a sum of money in United

States currency representing the amount of proceeds traceable to the commission of said offense.

                                    Substitute Assets Provision

        10.     If any of the above-described forfeitable property, as a result of any act or omission

of the defendant:

                a.     cannot be located upon the exercise of due diligence;




                                                  4

--- page 5 ---

Case 1:23-cr-00673-DLC Document 7 Filed 12/19/23 Page 5 of 5




               b.      has been transferred or sold to, or deposited with, a third person;

               c.     has been placed beyond the jurisdiction of the Court;

               d.     has been substantially diminished in value; or

               e.     has been commingled with other property which cannot be subdivided

               without difficulty;

it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p) and

Title 28, United States Code, Section 2461(c), to seek forfeiture of any other property of the

defendant up to the value of the above forfeitable property.

                           (Title 18, United States Code, Section 924;
                          Title 21, United States Code, Section 853; and
                           Title 28, United States Code, Section 2461.)


                                                                  ~®            LJ'Jlia/Y0._
       F                                                       DAMIAN WILLIAMS
                                                               United States Attorney




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