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UNITED STATES DISTRICT


DISTRICT OF CONNECTI
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UNITED STATES OF AMERICA cASE No. 3:14c Rlll
VIOLATIONS:
(AV/r)
V
GLORVINA CONSTANT 18 U.S.C.
$
371 (Conspiracy)
INFORMATION
The United States Attomey charges:
COTINT ONE
(Violation of 18 U.S.C.
$
371: Conspiracy to Commit Bank Fraud)
1. At all times relevant to this Information the defendant GLORVINA CONSTANT
resided in the State of Connecticut.
2. CONSTANT was not employed by any employer at any time between September
10, 2010, and September 19, 2013.
3. From approximately November 1, 2012, through March 1,2014, in the District of
Connecticut and elsewhere, CONSTANT did unlawfully, knowingly, and intentionally combine,
conspire, confederate, and agree with others, both known and unknown to the United States
Attomey, to devise and intend to devise a scheme and artifice to knowingly execute or attempt to
execute a scheme or artifice to defraud a f,rnancial institution, and to obtain any of the moneys,
funds, credits, assets, securities or other property owned by, or under the custody or control of, a
financial institution, by means of materially false or fraudulent pretenses, representations and
promises, in violation of Title 18, United States Code, Section 1344.
Case 3:14-cr-00197-AWT Document 1 Filed 10/07/14 Page 1 of 4
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4. At all times relevant to this Information, The Milford Bffkwas a financial
institution insured by the Federal Deposit Insurance Corporation. n
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5. During the month of November 2012, CONSTANT held financial accounts with at
least two different financial institutions in her own name (respectively, "Bank 1" and "Bank 3", the
identities of which are known to the United States Attorney).
6. During the month of November 2012, another individual, whose identity is known
to the United States Attorney, held an account at another f,rnancial institution in his or her name
("Bank 2",the identity of which is known to the United States Attorney).
Purpose of the Conspiracy
7. The purpose of the conspiracy was for CONSTANT, with assistance from her
co-conspirator(s), to obtain mortgage loan proceeds from The Milford Bank totaling $390,000 for
a first mortgage loan and $ 13 1,000 for a second mortgage loan, to be secured by real property in
New Haven, Connecticut.
Manner and Means of the Conspiracy
8. The manner and means by which CONSTANT and her co-conspirator(s) sought to
accomplish and did accomplish the objects of the conspiracy included CONSTANT's submission
of: (a) a Uniform Mortgage Loan Application for a $390,000 first mortgage containing materially
false information to The Milford Bank in approximately March 2013; and, (b) a Home Equity
Credit Line and Home Equity Loan Application for a $131,000 second mortgage containing
materially false information to The Milford Bank in approximately September 2013.
Overt Acts
9. In furtherance of the conspiracy and to effect the illegal objects of the conspiracy,
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Case 3:14-cr-00197-AWT Document 1 Filed 10/07/14 Page 2 of 4
the defendant GLORVINA CONSTANT and her co-conspirator(s) committed the following overt
act, among others, in the District of Connecticut and elsewhere:
a. On or about November 29,2012, funds originating from a company known as
Infinistaff, LLC totaling approximately $170,000 were transferred from an account
held in the name of CONSTANT at Bank 1 to an account held by another individual
atBank2.
b. On or about November 29,2012, the same funds consisting of approximately
$170,000 were transferred from the bank account held at Bank 2to anaccount held
in the name of CONSTANT at Bank 3.
c. On or about March 22,2013, CONSTANT prepared a Uniform Mortgage Loan
Application ("Loan Application") seeking approval of a $390,000 mortgage loan to
purchase real property known as 532 Whitney Avenue, New Haven, Connecticut.
d. On or about March 22,2013, CONSTANT submitted the Loan Application to The
Milford Bank containing the following materially false representations:
i. CONSTANT was employed by Infinistaff, LLC as an "Accounting Mgr."
when in truth she was not,
ii. CONSTANT had been employed by Infinistaff, LLC for five years and had
been employed in "this line of work" for nine years when in truth she had
not.
iii. CONSTANT eamed $16,856
per month from employment when in truth
she did not.
iv. CONSTANT owned a bank account with $188,837 on deposit when in fact
Constant knew the majority of the funds on deposit had been transferred
among several bank accounts in approximately November 2012 to disguise
the origin and ownership of the funds.
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Case 3:14-cr-00197-AWT Document 1 Filed 10/07/14 Page 3 of 4
e On or about September 19,2013, CONSTANT submitted a Home Equity Credit
Line and Home Equity Loan Application ("Home Equity Loan Application") to
The Milford Bank in order to obtain a second mortgage loan in the amount of
$131,000 that contained the following materially false information:
i. CONSTANT was employed by Infinistaff, LLC when in truth she
was not.
ii. CONSTANT earned $159,996 in annual income from Infinistaff,
LLC when in truth she did not.
In violation of Title 18, United States Code, Section 371.
UNITED STATES OF AMERICA
DEIRDRE M. DALY
UNITED STATES ATTORNEY
M. NEVINS
ASSISTANT UNITED STATES ATTORNEY
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Case 3:14-cr-00197-AWT Document 1 Filed 10/07/14 Page 4 of 4