In the United States District Court for the Northern District of Georgia Atlanta Division

COUNTS ONE THROUGH THIRTEEN
(Wire Fraud)

1. Beginning on a date unknown, but at least by in or about February 2004, and continuing until in or about February 2010, in the Northern District of Georgia and elsewhere l the defendant, POUL THORSEN 1 aided and abetted by others known and unknown to the Grand Jury, did knowingly devise and intend to devise a scheme and artifice to defraud, and to obtain money and property by means of materially false and fraudulent pretenses, representations, and promises, and by omission of material facts, well knowing and having reason to know that said pretenses, representations, and promises were and would be false and fraudulent when made and caused to be made and that said omissions were and would be material.