Case 8:13-cv-01601-MSS-TBM Document 1 Filed 06/19/13 Page 19 of 20 PageID 19
account number 100-118-0932, held in the name of "HARC Endowment." 37.
In 2010, deposits totaling $99,010 were transferred from 56 HARC client
accounts at Synovus Bank alone, into the HARC Endowment Fund account. 38.
In 2011, deposits totaling $120,477 were transferred from 56 HARC client
accounts at Synovus Bank alone, into the HARC Endowment Fund account. 39.
In 2012, deposits totaling $69,400 were transferred from 56 HARC client
accounts at Synovus Bank alone, into the HARC Endowment Fund account. 40.
The Endowment Fund account received no deposits other than those
from HARC's clients' personal accounts. As of today's date, there is $87,827 in the HARC "Endowment Fund" account at Synovus Bank.
VI. CONCLUSION 41.
In sum, the evidence indicates that agents of HARC unlawfully
established accounts to which its agents had sole access, in order to obtain its disabled adult clients' Social Security benefits. They then wired the money from HARC's clients' accounts into HARC's Endowment Fund and operating accounts. Although agents of HARC created sham agreements to shroud the siphoning of HARC's clients' funds with an appearance of legality, even had the agreements been legitimate, they would have been insufficient to make HARC a Social Security Administration-approved representative payee entitled to manage its clients' benefits. 42.
Based on the foregoing information, I submit there is probable cause to
believe that the Subject Funds are proceeds of the theft of government property,
understanding the nature and effect of the document at the time of notarization"). 14