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over the CEA account at the Mineola branch of Citibank, account
No. 23429344.
In March or April 1986, Lieter and Levine became aware of
financial irregularities at CEA. Checks were missing, and
petitioner failed to provide satisfactory documentation of his
activities. They responded by revoking his independent authority
over the CEA bank account: henceforth petitioner would not be
permitted to write checks on the account without the signature of
one of the other three signatories. CEA began to receive
complaints from individuals claiming that they had invested in
second mortgages through petitioner's solicitations yet had not
received interest payments or mortgage documentation. In most
cases Lieter and Levine were unable to locate any records of the
alleged transactions. In late May or early June 1986,
petitioner's relationship with CEA and East Coast Abstracts was
terminated.
Mildred Lawrence (Lawrence) was one of the numerous
individuals who believed they had invested in second mortgages
through CEA. Petitioner and his wife were close friends of the
Lawrences. Shortly before his work for CEA began, petitioner
informed Lawrence of the investment opportunities he would be
handling and offered to select some safe mortgages for her.
Between April and July 1986, she gave him three checks payable to
CEA in the aggregate amount of $65,000. Petitioner represented
to her that each of the checks would be used to acquire an
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