Maybe read the federal complaint again. It's very

Maybe read the federal complaint again. It's very bad.

Someone was diving in a lot more than trying to deliver a bogus Mexican mask manufacturer/supplier at 28 cents per mask.

Why one would be so desperate to cover for someone just to get his measly investment back is way way way beyond me? Whatever.

https://www.justice.gov/d9/press-releases/att...5276.1.pdf

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12. Co-Conspirator-2 (“CC-2”) has interests in various
business entities, including a company that manufactures heating
products (“CC-2 Company-1”) with locations in New Jersey and
Ireland. Based on my participation in this investigation,
including my review of email correspondence obtained pursuant to
judicially authorized warrants, I am aware that CC-2 was a friend
and business associate of RONALD ROMANO, the defendant, and claimed to have sources of supply of certain PPE, including N95 and N99 respirators.

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a. Beginning in or about February 2020, RONALD ROMANO,
the defendant, and others, including his business associate, CC-1,
and his friend and business associate, CC-2, commenced efforts to
obtain for resale large quantities of PPE, including N95 respirators. As described below, the potential sources of PPE 10 included a Mexico-based company, a “hedge fund” associated with CC-2, a Peruvian-based exporter, and 3M itself.

b. ROMANO and CC-2 discussed, in substance and in part, that they could get rich quick by closing a sale of respirators. On March 9, 2020, ROMANO sent a text message to CC-2,stating in part, “I’m working on a few deals that if I get any of them you might be buying a Ferrari.”

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The Purported Mexico-Sourced Respirators
c. Starting in or about February 2020, ROMANO’s friend and business associate, CC-2, began negotiating with a Mexico based company to purchase, for purposes of resale, face coverings and other PPE, and ROMANO and CC-2 had an ongoing dialogue about obtaining PPE from various sources

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The Purported Hedge Fund
Sourced Respirators
f. On or about March 12, 2020, CC-2 emailed ROMANO,
among others, about a separate purported opportunity to acquire up
to 400 million 3M-brand respirators. CC-2’s email stated, in part,
that one of CC-2’s entities (“CC-2 Company-2”), which had a name
similar to CC-2 Company-1’s name, “has secured the rights to
manufacture . . . with 3M factories 3M N95 NIOSH particulate
respirator Models 1860 and 8210, with a cap amount of *400 million
units worldwide*.” CC-2 offered per-mask prices of $5.20 and $5.50
for 3M models 8210 and 1860, respectively, on orders of at least
5 million.
g. Based on my investigation, CC-2 Company-2, which,
as described below, ROMANO represented to be a “hedge fund,”
appears to be a fictitious entity. Also, based on my review of
records obtained during the course of the investigation and my
conversations with 3M’s representatives, I am aware that 3M never
agreed to manufacture respirators for CC-2 Company-2 and none of
CC2 Company-1, CC-2 Company-2, or CC-2 was authorized to distribute
3M products or solicit purchase orders from prospective customers
on behalf of 3M.

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h. In the days that followed, ROMANO

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(with the
assistance of CC-2) created a document on CC-2 Company-1’s
letterhead stating that Vendor-1 was authorized to sell 3M products
on CC-2 Company-1’s behalf (the “Fictitious Authorization
Letter”)

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. On or about March 15, 2020, ROMANO emailed CC-2 a draft
of the Fictitious Authorization Letter.

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THIS IS HUGE WHEN READING THE COMPLAINT.

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i. The following day, on or about March 16, 2020, CC-2
emailed ROMANO a signed copy of the Fictitious Authorization Letter
on CC-2 Company-1 letterhead. CC-2’s spouse signed as the
“President” of CC-2 Company-1 .

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even though ROMANO was not an authorized 3M distributor and ROMANO knew or had reason to know that CC-2 Company-1 and CC-2 Company-2 had no ability to procure face respirators from 3M.

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Based on my review of emails and text messages between
Broker-1 and the City, and ROMANO and CC-2, I am aware that ROMANO
and Vendor-1 attempted to sell PPE facemasks to the City at prices
marked up between 390% and 1,129% from the manufacturer’s prices.

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Third, the References Document indicated that
Vendor-1 supplied CC-2 and CC-2 Company-1 with 3-ply face
respirators. Based on my participation in this investigation,
including my review of text messages and email correspondence
between ROMANO and CC-2, I believe this representation was false .

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e. On or about April 1, 2020, at approximately 12:05
p.m., ROMANO emailed CC-2 a copy of the References Document, and
wrote in the body of the email, “In case they call on the
reference.”

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WOW!!

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f. Based on my review of records obtained from NYC’s
Office of Citywide Procurement, I am aware that, on or about April
1, 2020, NYC personnel contacted CC-2, whom ROMANO had listed on
the References Document. NYC personnel notes from that call
indicate that CC-2 stated, in substance and in part, “CC-2 has
worked with [Vendor-1] for numerous orders in the past for surgical
masks and medical supplies. CC-2 advised that [Vendor-1] is
straight forward, delivers on time and that product meets
expectations.” For the reasons set forth above, CC-2’s statements
to NYC appear to have been materially false and misleading.

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The kicker to whole scheme

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d. After several days of negotiations with the FDEM, on or about March 29, 2020, Broker-3 submitted a revised formal quote, at the direction of ROMANO, for 3 million N99 facemasks, $1.82 per mask, for a total sale price of $5,460,000. Based on my review of ROMANO’s and CC-2’s emails, I am aware that ROMANO and CC-2 were able to obtain these facemasks from their source-of- supply, the Mexico-based manufacturer, for approximately 28 cents per mask. Thus, ROMANO attempted to sell these three million N99 facemasks at an approximately 500% markup.

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in my opinion

cheers