23. It was a part of DONALD W. WAINWRIGHT'S scheme and artifice to defraud that, in
November and December of2012, when neither DONALD W. WAINWRJGHT, DONALD
W. WAINWRJOHT, JR., nor Valley View Ohio possessed a license to legally buy or
possess deer or conduct hunts, W AINWRlGHT and co-defendant W AINWRJGHT, JR.,
nevertheless purchased White-tailed deer from another Ohio deer preserve and had those deer
transported to Valley View Ohio in order to stock Valley View Ohio with large deer for the
clients ofW AINWRlGHT and WAINWRIGHT, JR., to hunt.
24. On or about December 7, 2012, in the Southern District of Ohio, Defendant DONALD W.
WAINWRJGHT for the purpose of executing the aforesaid scheme and artifice to defraud or
attempting to do so, and for obtaining property by means of false and fraudulent pretenses,
misrepresentations and promises, did knowingly cause to be transmitted, or did aid, abet..
counsel, and procure the commission of the transmission, by witness J.F., an employee of
DONALD W. WAINWRIGHT, by means of wire communication in interstate commerce,
namely, an electronic bank transfer of money, a sum of money in the amount of $26,500.00,
transferred from Lafayette State Bank, account number , in the name ofDon's
Septic and Fill, Inc., located in Mayo, Florida, to a Huntington National Bank branch in
Massillon, Ohio, account number in the name of the proprietor of an Ohio
deer preserve (known to the Grand Jury but not identified herein).
In violation of 18 U.S.C. 1343 and 2.
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Case: 2:14-cr-00044-GCS-EPD Doc #: 1-1 Filed: 03/04/14 Page: 17 of 18 PAGEID #: 58