Case 1:15-cr-00178-AJT Document 74 Filed 10/14/15 Page 1 of 6 PageID# 489

IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES OF AMERICA
v.
HAROLD BAILEY GALLISON II,
a/k/a B.J. GALLISON,
a/k/a Bart Williams,
MICHAEL J. RANDLES,
ANN MARIE HISKEY,
ROGER G. COLEMAN,
CARL H. KRUSE, SR.,
CARL H. KRUSE, JR.,
FRANK J. ZANGARA,
MARK S. DRESNER, and
CHARLES S. MOELLER,
Defendants.

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No. 1:15cr178
Honorable Anthony J. Trenga

UNITED STATES MOTION TO PROVIDE NOTICE TO VICTIMS BY

PUBLICATION

The United States of America, through the undersigned counsel, respectfully requests an
order authorizing it to provide notice to potential victims by publication, in compliance with the
Justice for All Act, 18 U.S.C. 3771. Specifically, the United States seeks the Courts approval
for complying with this law by posting a notice in The Wall Street Journal and by posting
information relevant to the notification of victims on the Department of Justices website. Prior
to filing this motion, the United States provided a draft to counsel for all defendants who have
entered an appearance in this case. Counsel for defendants Hiskey, Coleman, Zangara, and
Moeller indicate that their clients do not object to the motion, while counsel for defendants
Gallison and Dresner did not indicate a position on the motion.

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ARGUMENT
The Justice for All Act (Act) provides certain rights to victims in federal criminal
proceedings. 18 U.S.C. 3771. Among the rights provided for in the Act is the right of victims
to reasonable, accurate, and timely notice of public court proceedings. 18 U.S.C. 3771(a).
The Act further provides that agencies of the United States shall make their best efforts to see
that crime victims are notified of, and accorded, the rights described in subsection (a). 18
U.S.C. 3771(c)(1). The Act defines a crime victim as a person directly and proximately
harmed as a result of the commission of a federal offense. 18 U.S.C. 3771(e). Additionally,
the Act provides that in cases with multiple crime victims where personal notification is
impracticable, the Court shall fashion a reasonable procedure to give effect to [the Act] that
does not unduly complicate or prolong the proceedings. 18 U.S.C. 3771(d)(2).
In this case, any individual or entity who legitimately bought, sold, or held Warrior Girl
Corp. (WRGL) or Everock Inc. (EVRN) stock during or after the alleged fraud is a potential
victim. As a result of information obtained from trading records for these two securities, the
United States thus far has identified approximately 5,400 potential shareholders who either
bought, sold, or held EVRN, and approximately 4,500 potential shareholders who either bought,
sold, or held WRGL stock during the relevant time period, for a total of approximately 9,900
potential victims that have been identified thus far in connection with this case. There may also
be additional shareholders who have not yet been identified as potential victims. Furthermore,
due to the amount of time that has elapsed between the fraudulent scheme and indictment, the
United States does not have current contact information for victims that have been identified.
Requiring the government to identify, locate, and provide personal notification to the large
number of potential victims in this case would significantly prolong and complicate court

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proceedings. Accordingly, the United States respectfully requests that this Court issue an order
permitting compliance with the Act by placing a notification for one day in The Wall Street
Journal, and by posting information relevant to the notification of victims on the website for the
United States Department of Justice on an ongoing basis throughout the court proceedings.
The United States intends to submit a notice in the legal notices section of The Wall
Street Journal to read in substance as follows:
Attention purchasers of Warrior Girl Corp. (WRGL) and/or Everock, Inc.
(EVRN) stock between September 2008 and March 2014:
Charges have been filed against Harold Bailey Gallison II, a/k/a B.J.
Gallison, a/k/a Bart Williams; Anna Hiskey; Michael Randles; Roger
Coleman; Carl Kruse Sr.; Carl Kruse Jr.; Frank Zangara; Mark Dresner;
and Charles Moeller in the United States District Court for the Eastern
District of Virginia. The indictment was filed on June 24, 2015 and
charges the defendants for their alleged involvement in an international
stock manipulation and money laundering scheme involving Warrior Girl
Corp. and Everock, Inc. The stocks were traded on the over-the-counter
market under the ticker symbols WRGL and EVRN. The alleged
scheme was designed to artificially inflate stock prices and volume
through promotional activities. Defendants then allegedly sold the shares
at inflated prices and laundered the proceeds through offshore accounts.
The scheme was facilitated through an offshore brokerage and money
laundering platform located in Costa Rica that went by various names
including: Sandias Azucaradas, Moneyline Brokers, and Trinity Asset
Services.
The indictment charges Gallison, Hiskey, Kruse Sr., and Kruse Jr. with
one count of conspiracy to commit wire fraud and one count of securities
fraud in connection with a pump-and-dump scheme involving Warrior
Girl, Corp. Gallison, Hiskey, Zangara, Moeller, and Dresner are charged
with one count of conspiracy to commit wire fraud and one count of
securities fraud in connection with a pump-and-dump scheme involving
Everock, Inc. Additionally, Gallison, Hiskey, Coleman, and Randles are
charged with conspiracy to commit money laundering. At this time, there
has been no finding of guilt with respect to any of the defendants, and they
are presumed innocent until and unless proven guilty beyond a reasonable
doubt. The case is scheduled for trial on January 25, 2016, before United
States District Court Judge Anthony J. Trenga in the United States District
Court for the Eastern District of Virginia, Alexandra Division, case
number 1:15cr178.
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If you believe that you were a victim of these crimes, and you wish to
receive notice of future developments in the cases, to submit written
information concerning the impact these crimes have had on you to assist
the court in determining defendants sentences, should they be convicted,
and any possible restitution, or to attend any hearings, please contact the
Victim/Witness Coordinator at the United States Department of Justice,
Criminal Division, Fraud Section at telephone number 1-888-549-3945 or
go to the Case Updates section on the Criminal Divisions Victim Witness
webpage at: http://www.usdoj.gov/criminal/vns/index.html.

Similar methods of compliance have been adopted in other securities, mail, and wire
fraud cases where a large or unknown number of potential victims made notification by mail
impracticable or unduly burdensome. See, e.g. United States v. Freedman, No. 5:08CR335,
2009 WL 3784961, at *1 (N.D. Ohio Nov. 10, 2009) (publishing a notice in three weekly
national publications was reasonable because the scheme was estimated to have affected 19,000
victims and they had not been fully identified and located); United States v. Saltsman, No. 07CR-641(NGG), 2007 WL 4232985, at *1-*2 (E.D.N.Y. Nov. 27, 2007) (publishing a notice
directing potential securities fraud victims to the United States Attorneys Office website or
Department of Justice website is reasonable when there are a large number of potential victims).

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CONCLUSION
The large number of potential crime victims makes it impracticable for the United States
to provide reasonable, accurate, and timely notice of court proceedings to each victim of
alleged offenses by direct mailing or other forms of individualized notice. 18 U.S.C.
3771(a)(2). Accordingly, the United States asks the Court to find that individualized notice is
impracticable and that the proposed notice procedure, through publication in The Wall Street
Journal and on the Department of Justices website, and is a reasonable procedure that
satisfies Section 3771.

Respectfully submitted,
Dana J. Boente
United States Attorney
By:

/s/

Kosta S. Stojilkovic
Assistant United States Attorney
United States Attorneys Office
2100 Jamieson Avenue
Alexandria, Virginia 22314
Phone: (703) 299-3700
Fax: (703) 299-3981
Email: kosta.stojilkovic@usdoj.gov
N. Nathan Dimock
Special Assistant United States Attorney
United States Attorneys Office
Senior Trial Attorney
United States Department of Justice
Criminal Division, Fraud Section
1400 New York Avenue, NW
Washington, DC 20530
Office Phone: 202-514-0095
Mobile Phone: 202-355-5655
Fax: 202-514-6118
Email: Nathan.Dimock@usdoj.gov
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CERTIFICATE OF SERVICE
I hereby certify that on October 14, 2015 I will file the foregoing pleading with the Clerk
of the Court, who will then send a notification of such filing (NEF) to all counsel of record.

/s/
_
Kosta S. Stojilkovic
Counsel for the United States
United States Attorneys Office
2100 Jamieson Avenue
Alexandria, Virginia 22314