Case 2:18-mj-03556-MF Document 1 Filed 03/08/18 Page 1 of 8 PageID: 1

UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

UNITED STATES OF AMERICA : Hon. Mark Falk

v. : Mag. No. 18- (MF)

JOHN ECKERD
CRIMINAL COMPLAINT

I, James Muller, being duly sworn, state the following is trut. arid cor;i.
to the best of my knowledge and belief:

SEE ATTACHMENT A

I further state that I am a Special Agent with the Federal Bureau of

Investigation and that this complaint is based on the following facts:

SEE ATTACHMENT B

continued on the attached pages and made a part hereof.

James Muller, Special Agent

Federal Bureau of Investigation

*Agent Muller attested this Affidavit

by telephone pursuant to
FRCP 4.1(b)(2)(A)

Sworn to telephonically pursuant to FRCP 4. 1(b)(2)(A) on the

March 8, 2018 at Esse.y, New Jer

Date Co t St

or
Judge
Name and Title of Judicial Officer Signature of Judicial Officer
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ATTACHMENT A

COUNT ONE
(Conspiracy to Commit Money Laundering)

From in or around September 2017 through in or around March 2018, in

the District of New Jersey, and elsewhere, the defendant,

JOHN ECKERD,

did knowingly and intentionally conspire and agree with others to commit an
offense against the United States, to wit:

With the intent to conceal and disguise the nature, location, source,
ownership, or control of property believed to be the proceeds of specified
unlawful activity, that is, narcotics trafficking, did knowingly conduct and
attempted to conduct financial transactions involving property represented by a
law enforcement officer to be the proceeds of specified unlawful activity, that is,
narcotics trafficking, contrary to Title 18, United States Code, Section
1956(a)(3)(B).

THE OBJECT OF THE CONSPIRACY

It was the object of the conspiracy that JOHN ECKERD and Co

Conspirator-i would conduct financial transactions for their own pecuniary gain
knowing that money used in those financial transactions was purported to be
proceeds of narcotics trafficking.

MANNER AND MEANS

It was part of the conspiracy that on numerous occasions between

September 2017 and March 2018, JOHN ECKERD and Co-Conspirator-i
engaged in phone calls with each other and others to discuss laundering
money believed to be derived from the distribution of narcotics.

It was further part of the conspiracy that, on at least three occasions

between October 2017 and March 2018, JOHN ECKERD and Co-Conspirator-i
met with and undercover law enforcement officer (“UCE- 1”) in the District of
New Jersey and elsewhere to discuss the laundering of money, including the
various methods that could be used by JOHN ECKERD and Co-Conspirator-i
to conceal or disguise the nature, location, source, ownership, or control of
property purported to be narcotics proceeds by a law enforcement officer.

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OVERT ACTS

In furtherance of the conspiracy and to effect the illegal object thereof,

the following acts, among others, were committed in the District of New Jersey
and elsewhere:

On at least two occasions between January 201$ and February 2018,

JOHN ECKERD and Co-Conspirator-i received United States currency from
UCE-1, as set forth in the chart below, and in exchange, JOHN ECKERD and
Co-Conspirator-i wired money to UCE- l’s bank account or provided UCE- 1
with a check, less an amount which JOHN ECKERD and Co-Conspirator-i
retained as a fee for conducting the financial transaction.

Date of
Amount Laundered
Transaction

1/18/18 $100,000

2/23/ 18 $100,000

All in violation of Title 18, United States Code, Section 1956(h).

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COUNTS TWO Through THREE

(Money Laundering)

On or about each of the dates set forth below, in the District of New
Jersey and elsewhere, the defendant,

JOHN ECKERD,

With the intent to conceal or disguise the nature, location, source, ownership,
or control of property believed to be the proceeds of specified unlawful activity,
that is, narcotics trafficking, did knowingly conduct or attempt to conduct
financial transactions involving property represented by a law enforcement
officer to be the proceeds of specified unlawful activity, that is, narcotics
trafficking:

Count Date of Amount Laundered

Transaction

2 1/18/13 $100,000

3 2/23/18 $100,000

In violation of Title 18, United States Code, Section 1956(a)(3)(B).

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ATTACHMENT B

I, James Muller, am an agent with the Federal Bureau of Investigation

(“FBI”). I am fully familiar with the facts set forth herein based on my own
investigation, my conversations with other law enforcement officers, and my
review of reports, documents, and items of evidence. Where statements of others
are related herein, they are related in substance and part. Because this
complaint is being submitted for a limited purpose, I have not set forth each and
every fact that I know concerning this investigation. Where I assert that an event
took place on a particular date, I am asserting that it took place on or about the
date alleged.

1. At all times relevant to this Complaint:

a. Defendant JOHN ECKERD was a resident of the State of

Texas.

b. Co-Conspirator-i (“CC- 1”) was a resident of Union County,

New Jersey.

c. The “Development Project” is a high-end underground

residential housing project in the area of Dallas, Texas. It is
being marketed as a five star playground with DEFCON 1
preparedness (referring to the status of alert/level of readiness
for imminent nuclear war) and consists of fortified shelters
built to withstand catastrophic events from viral epidemics to
nuclear war.

d. CC-i used a limited liability company that, in reality, was a

shell company (“Shell Company- 1”) to launder purported illicit
money. Shell Company-i was located in Union County, New
Jersey.

e. UCE- 1 was an undercover FBI agent.

f. UCE-2 was an undercover FBI agent.

2. On or about September 1, 2017, UCE-1 was introduced to CC-i,

during an audio-recorded meeting, at a location in Cape May
County, New Jersey. At that time, CC-i understood that UCE- 1
was a former narcotics trafficker who allegedly had large sums of
cash from past illegal narcotics activity that UCE- 1 needed to
launder. Later that evening, CC-i accepted $iO,000 in cash from
UCE-i and in return, CC-i wrote out a check for $9,400 and
handed it to UCE- 1.

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3. On or about September 21, 2017, CC-i, UCE-1 and others met at a

location in Atlantic County, New Jersey. During this audio-recorded
meeting, CC-i discussed laundering UCE-i’s money through an
associate in Dallas, Texas named JOHN ECKERD who was able to
launder illicit proceeds through his Development Project. Later that
afternoon, CC-i accepted $40,000 in cash from UCE-1 and in
return, cc-i handed over two checks totaling $36,000.

4. On or about October 5, 2017, CC-i, ECKERD, UCE-i and others

met at a location in Atlantic County. During this audio-recorded
meeting, UCE- 1 and CC-i had a conversation about UCE- l’s alleged
past narcotics trafficking, the laundering of UCE-i’s supposed
narcotics proceeds through the Development Project, and the
laundering of Colombian drug money. That same evening, UCE- 1,
ECKERD and CC-i had a separate conversation during which they
discussed numerous topics related to laundering money. During
the conversation, UCE- 1 made it known to both CC-i and ECKERD
that the money to be laundered was from Colombians, thereby
indicating that his cash was from narcotics trafficking. Later that
same evening, UCE-i handed CC-i $50,000 in cash. CC-i later
wrote a check in the amount of $45,000 and handed it to UCE-1.

5. Between on or about October 16, 2017 and November 13, 2017,

UCE- 1 provided CC-i with cash in amounts ranging between
$35,000 and $60,000 on at least four occasions. During that same
time period, CC-i made at least four cash deposits into Shell
Company- l’s bank account at bank locations in Union County.

6. On or about December 13, 2017, CC-i, UCE-i, and others met at a

location in Atlantic County. During the audio-recorded meeting,
CC-i provided UCE-i with two checks totaling $40,500 in exchange
for $45,000 in cash. CC-i asked UCE-1 if UCE-i had spoken to
“the people down below yet,” referring to the people “in Florida,”
which UCE- 1 understood was a reference to the supposed
Colombian drug traffickers who would be laundering money through
the Development Project.

7. Two days later, on or about December 15, 2017, CC-i deposited

$9,000 in cash into Shell Company-i’s bank account at a bank in
Union County.

8. On or about January 18, 2018, CC-i, UCE-1, UCE-2 and others met
at a location in Atlantic County. During the audio-recorded
conversation, CC-i accepted $100,000 in cash from UCE-i. CC-i
advised UCE- 1 that instead of receiving a check, the money, less a

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fee, would be wired back to UCE-1 by ECKERD.

9. On or about January 24, 2018, law enforcement intercepted a

phone call between CC-i and ECKERD. During the lawfully
recorded conversation, ECKERD told CC-i that he would be
getting a commitment for the $100,000 from “an air conditioning
guy” to whom ECKERD described the transaction as a “quick flip.”
(Conspirator-i and ECKERD were discussing the January 18,
2018 money laundering transaction.)

10. On or about January 31, 2018, during a lawfully recorded call, CC

1 and ECKERD discussed the logistics of wiring money related to
the January 18th $100,000 money laundering transaction between
UCE-i, CC-i and ECKERD.

ii. On or about February 1, 2018, during a lawfully recorded call,

ECKERD asked CC-i if he transferred the money to UCE- 1.
ECKERD told CC-i that the money wired for UCE- 1 was sent from
ECKERD’s bank account. CC-i advised ECKERD that he was
short on cash for an upcoming real estate closing, and CC-i was
going to ask UCE- 1 if CC- i could borrow a portion of the
laundered funds from UCE- 1 for the real estate closing.

12. Between on or about February 1, 2018 and February 10, 2018,

three wire transfers in the amounts of $50,000, $25,000 and
$20,000 were received in UCE-i’s undercover bank account. The
wire transfers originated from bank accounts associated with Shell
Company-i.

13. On or about February 12, 2018, during a lawfully recorded call,

ECKERD and CC-i discussed conducting another $100,000
money laundering transaction with UCE- 1, which was supposed to
take place in Texas. During the conversation, ECKERD warned
CC-i that the drive between Houston and Dallas was a “corridor”
and they discussed taking a “prop job.” (ECKERD was advising CC
1 that a small plane might be better to conceal their illegal
activities from law enforcement rather than driving the closely
monitored highway route between Houston and Dallas where law
enforcement may stop a car and seize the cash.)

14. On or about February 22, 20i8, ECKERD, CC-i, UCE-i, UCE-2

and others met at a location in Texas. During a lawfully recorded
conversation, UCE- 1 explained to ECKERD that the cash supplied
by UCE- i and the supposed Colombian drug traffickers was

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derived from illicit narcotics activity. UCE- 1 stated that UCE- 1

and the Colombians would both initially launder $1 million in
narcotics proceeds through the Development Project and, alter a
few months, the Colombians would “bump it up to two million a
month.” ECKERD responded, “Right.”

15. On or about February 23, 2018, CC-i, EcKERD, and UCE-i met
at a location in Texas. UCE- 1 had a backpack containing
$100,000 in purported narcotics proceeds. During this audio and
video-recorded meeting, UCE- 1 told ECKERD that UCE- 1 and CC
1 had opened up the backpack and noticed that the bundles of
cash from the supposed Colombian drug traffickers contained
some twenty-dollar bills. CC-i noted that it would be easier to
transport cash in higher denominations, and, ECKERD also noted,
“That’s a lot of conversion.” UCE- 1 later accepted from UCE- 1
$100,000 in cash contained inside the backpack. In exchange,
ECKERD provided a check in the amount of $90,000.