Stanley J. Zaban and Shirley A. Zaban - Page 11

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                    The second money laundering scheme, which for purposes of the                                 
             1992 plea bargain with the U.S. Attorney's Office could not be                                       
             proven, involved payments to Westco Manufacturing Co. (Westco) in                                    
             California during 1989.  Mr. Zaban paid his friend Roy Burger                                        
             $41,569, and in exchange, Westco, for whom Mr. Burger worked and                                     
             was earning commissions, paid Zaban Enterprises with checks                                          
             totaling $41,569.  Mrs. Zaban was aware of these transactions and                                    
             the deposits of checks from Westco to Zaban Enterprises.  Mrs.                                       
             Zaban believed that these were consulting fees for work performed                                    
             by Mr. Zaban for Westco, but she did not know the nature of the                                      
             work performed by Mr. Zaban.                                                                         
                    3. Bank Fraud                                                                                 
                    In early 1988, petitioners decided to acquire a new home.                                     
             Mrs. Zaban met with Kathryn Gerling, president of Midstate Savings                                   
             and Loan (Midstate), to begin the process of applying for a loan.                                    
             (To a large extent Mrs. Zaban negotiated the terms of the loan with                                  
             Ms. Gerling.)  On February 26, 1988, petitioners submitted an                                        
             application to Midstate for a $101,000 acquisition loan to purchase                                  
             a residential lot in Lutherville, Maryland. The loan application                                     
             listed monthly income of $12,200, assets of $683,293.65, and a net                                   
             worth of $520,325.65.                                                                                
                    On or about August 23, 1988, petitioners submitted an                                         
             application to Midstate for a $528,700 construction loan to build                                    
             their home on the lot in Lutherville, Maryland, pursuant to a                                        





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