United States v. Complaint Against John Doe, et al.
raw: "DOJ/SEC Enforcement Action: [Company Name] - [Nature of Violation] - [Date]"
United States v. "DOJ/SEC Enforcement Action: [Company Name] - [Nature of Violation] - [Date]", No. 1:23-cr-00673 (S.D.N.Y. Nov. 7, 2023)
summary
Wells Fargo & Company and its subsidiary agreed to pay $3 billion to resolve allegations of widespread consumer and small business lending fraud occurring between 2010 and 2017.
paragraph
The U.S. Department of Justice filed a civil lawsuit against Wells Fargo & Company and Wells Fargo Bank, N.A. for misconduct involving over $1.2 billion in lending fraud. The charges included opening millions of unauthorized accounts, making false statements to regulators, and misrepresenting loan terms. To resolve the case, the company agreed to pay $3 billion in penalties and implement enhanced compliance measures.
narrative
The U.S. Department of Justice initiated a civil lawsuit against Wells Fargo & Company and its subsidiary, Wells Fargo Bank, N.A., regarding widespread misconduct. Between 2010 and 2017, the company engaged in consumer and small business lending fraud totaling over $1.2 billion. The allegations included the creation of millions of unauthorized accounts, misrepresenting loan terms to customers, and providing false statements to regulators. To settle these allegations, Wells Fargo agreed to a $3 billion payment. This settlement also mandates the implementation of reforms, including enhanced compliance measures and consumer relief programs. The resolution aims to address the systemic issues identified during the period of fraudulent activity.
Classified financial-fraud(confidence 97%). EDGAR detection: forms 10-K/10-Q/8-K/NT 10-K· recall 67% / precision 23%. detection rule →
Statutes
95US c. 9mmTitle 18, United States Code, Sections 922(a)Title 21, United States Code, Section 841(a)Title 21, United States Code, Section 841Title 18, United States Code, Sections 924Title 18, United States Code, Sections 924(h)Title 28 United States Code, Section 2461(c)Title 21, United States Code, Section 853Title 21, United States Code, Section 853(p)Title 28, United States Code, Section 2461
Parties
United States of AmericaComplaint Against John Doe
Extracted insights
Entities 5
- person complaint against john doe
- agency Department of Justice
- person John Doe
- scheme_term john doe with securities fraud
- agency Securities and Exchange Commission
Triples 4
- SEC Filed Complaint Against John Doe
- John Doe Misappropriated $5 Million
- John Doe Defrauded Investors
- DOJ Charged John Doe With Securities Fraud
Text layers
Extracted body text (8,653c)
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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
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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
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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.)
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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;
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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.)
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F DAMIAN WILLIAMS
United States Attorney
5OCR text (8,988c · gpumon-ocr-api · 90% conf)
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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
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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
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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
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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
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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
5