Case 8:13-cv-01601-MSS-TBM Document 1 Filed 06/19/13 Page 18 of 20 PageID 18
35.
In addition to the fact that the agreements would have been legally
insufficient to allow HARC to become its clients' representative payee (as discussed above), the fact that the funds were used in contravention of the agreements' own commitment to use the funds solely for the beneficiaries' benefit, and the fact that the agreements entirely omitted key terms referenced therein, none of the agreements were completely executed or properly notarized. Pannullo himself-despite being a party to the transaction as CFO of HARC-notarized all but one of the agreements. 2 Agreements were signed by adults who were not mentally capable of understanding their nature or effect.
3
On none of the agreements notarized by Pannullo did Panullo
write the "grantor's" (the HARC client's) name in the space provided for the notary to include it. And none of the agreements had the grantor's initials in the place designated for them at the bottom right of the second and subsequent pages. Based on my training and experience, these agreements appear to represent an attempt to conceal and/or disguise the impropriety of the HARC agents' siphoning of HARC's client's Social Security benefits. Bank Records 36.
Synovus Bank records from 2010 through 2013 reveal that funds were
transferred from the private accounts held in the names of HARC's clients at Synovus Bank, Sun Trust Bank, and the Bank of Tampa, into the HARC-controlled Synovus Bank
2
See Fla. Stats. Ch. 107.17 ("A notary public may not notarize a signature on a document if the notary public has a financial interest in or is a party to the underlying transaction"). 3 The notarizing of signatures of mentally incapacitated clients is contrary to Florida State Statute, Chapter X, Section 117.107 ("A notary public may not notarize a signature on a document if it appears that the person is mentally incapable of
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