‘4091 ev. 1182) CRIMINAL COMPLAINT
UNITED STATES DISTRICT COURT CENTRAL DISTR
DOCKETNO,
UNITED STATES OF AMERICA
v.
MICHAEL J. AVENATTI
Complaint for violations of Title 18, United States Code, Sections 1343 and 1344(1)
[NAME OF MAGISTRATE JUDGE UNITED STATES LOCATION
HONORABLE DOUGLAS F. MCCORMICK MAGISTRATE JUDGE | Santa Ana, California
DATEOF OFFENSES PLACE OF OFFENSE, "ADDRESS OF ACCUSED UF KNOWN) 7
Beginning in.or around Orange County and | 10000 Santa Monica Boulevard, Unit 2205,
January 2014 and continuing | Los Angeles County | Los Angeles, California 90067
‘through in or around March
2019
‘COMPLAINANT'S STATEMENT OF FACTS CONSTITUTING THE OFFENSE OR VIOLATION:
(See attached Complaint’s Statement of Facts Constituting the Offense or Violation which is incorporated as part
of this Complaint)
[BASIS OF COMPBAINANTS CHERLGE AGAINST THE ACCUSED:
(See attached Affidavit which is incorporated as part of this Complaint)
[MATERIAL WITNESSES IN RELATION TO Tas CHARGE: N/A
[- SIGNATURE OF COMPLAINANT
Being duly sworn, I declare that the 12
foregoing is true and correct to the best | Remoun Karlous |"
of my knowledge. OFFICIAL TITLE : i
Special Agent, Internal Revenue Service ~ Criminal Investigation
‘Sworn to before me and subscribed in my presence,
SIGNATURE OF MAGISTRATE TUDOR | pate
7 CK
DOUGLAS F. McCORMI March 22, 2019
07 Sag Fela Rus of Cina Proceed 37
AUSAs Julian L. André 213.894.6683 and Brett A. Sagel 714.338.3598 REC: DetentionComplaint’s Statement of Facts
Constituting the Offense or Violation
COUNT ONE
[18 U.S.c. § 1344(1)]
Beginning in or about January 2014, and continuing through
in or about April 2016, in Orange County, within the Central
District of California, and elsewhere, defendant MICHAEL J.
AVENATTI (“AVENATTI”), together with others known and unknown,
knowingly and with intent to defraud, executed and attempted to
execute a scheme to defraud The Peoples Bank as to material
matters.
on or about December 12, 2014, in Orange County, within the
Central District of California, and elsewhere, defendant
AVENATTI, together with others known and unknown, committed and
willfully caused others to commit the following act, which
constituted an execution of, or an attempt to execute, the
fraudulent scheme: (1) wire transfer of approximately $494,500
from The Peoples Bank in Biloxi, Mississippi, to a California
Bank & Trust bank account in the name of Eagan Avenatti LLP in
Irvine, California.COUNT TWO
[18 U.S.C. § 1343]
Beginning as early as in or around December 2017 and
continuing through in or around March 2019, in Los Angeles and
orange Counties, within the Central District of California, and
elsewhere, defendant MICHAEL 3. AVENATTI (“AVENATTI”), knowingly
and with intent to defraud, devised participate in, and executed
a scheme to defraud clients to whom defendant AVENATTI had
agreed to provide legal services, as to material matters, and to
obtain money and property from his legal clients by means of
material false and fraudulent pretenses, representations, and
promises, and the concealment of material facts.
on or about January 5, 2018, in Los Angeles and Orange
counties, within the Central District of California, and
elsewhere, defendant AVENATTI, for the purpose of executing the
above-described scheme to defraud, transmitted or caused the
transmission of the following items by means of wire
communication in interstate and foreign commerce: (1) wire
transfer of approximately $1,600,000 sent from Silicon Valley
Bank through the interstate Fedwire system to defendant
AVENATTI's City National Bank attorney trust account in Los
Angeles, California.