A General Complaint was filed to the Office of Professional Responsibility OPR regarding the misconduct by federal prosecutors in the i2G Infinity Two Global Case which included 40 pages of documentation to prove the allegations as follows:
The supplemental documents arriving by mail highlight governmental misconduct, which constitutes disbarrable and criminal offenses that have led to wrongful convictions and imprisonments.
The case involves “U.S. v. Maike.” The case number is NO. 4:17CR-00012-JHM
The acts of prosecutorial misconduct include:
- Direct and Repeated Lies to the Court about statements refuted by their witness aimed to discredit exonerating data that disproved their case
- Fraud upon the Court with Knowing presentation of False Evidence
- Manipulating Evidence- “filtering out” 28 million dollars of commissions paid to alleged victims- to dramatically inflate loss representations used as the primary evidence at trial
- Presenting False Data in 101i, 101j, and 101d to misrepresent the I2G Gains/Losses of 16 trial witnesses and many non-witnesses.
- Suborning perjury through the misrepresentation of i2G Gains/Loss data spreadsheets with four key witnesses and 12 distributor witnesses
- Knowingly Presenting 2 years of data AFTER I2G was closed belonging to a separate company Xtg1- as I2G Data through 101b, 101a, 101G, 101G1, 101i, 101d, 101f
- Failure to correct known false statements of 4 key witnesses on known false Gain/Loss representation regarding 101i, 101F, 101j summary charts exhibit 230 232 and other data misrepresentations
- Brady, Giglio and Jenks violations
- Misrepresentation of the law, Using personal opinion, facts not in evidence in closing argument
These misconduct allegations are definitively supported by data evidence, an affidavit from the data provider, testimony from government witnesses, government discovery, and trial testimony, which substantiate each allegation.
This complaint targets Western Kentucky Assistant District Attorney Madison Sewell, Marissa Ford, and Appeal Attorney Tyler Lee. Madison Sewell is based in the Bowling Green Office in Western Kentucky, while Marissa Ford is retired from the same office. Tyler Lee was appointed as the government’s appeal attorney and has continued to present known false data and perjured testimony as evidence in her appeal filing.
Evidence suggests misconduct by FBI Agent McClelland, who misrepresented Infinity Two Global in an affidavit submitted to the court to obtain a lis pendens related to the civil forfeiture of $3 million worth of land and several hundred thousand dollars in cash. He also provided false information to the grand jury regarding the defendant’s relationships and the circumstances surrounding Infinity Two Global to secure an indictment.
FBI Agent Sauber, who succeeded Agent McClelland presented the same false evidence regarding I2G’s gains and losses, among other inaccuracies. He later acknowledged these discrepancies during the Maike sentencing.
Agent McClelland presented false summary charts 230 and 232, which failed to disclose 28 million dollars in earned commission by i2G distributors including the “source” of the gross purchases he misrepresented as losses.
Assistant District Attorney Madison Sewell orchestrated fraud on the court by manipulating exculpatory commission data one week before the trial to create seven false spreadsheet representations of I2G, which “filtered out” 28 million dollars of commission gains by “alleged victims” which were used as the source of the product purchases. Sewell lied to the court about alleged statements by his witness, Reynolds, regarding the reliability of the exculpatory evidence he “filtered”. His lies aimed to discredit evidence that contradicted his case. Sewell possessed this exculpatory data of ALL i2G transactions (7240) five years before the trial proving that $38 million was paid in commissions to i2G distributors (alleged victims) rather than the $7.5 million he presented to the jury through the manipulated data of 101i.
The newly ordered 101 falsely represented All I2G gains and losses by excluding $28 million in paid commissions to the alleged victims. It also failed to deduct millions of dollars from other transactions that never took place, including $800,000 in waived auto-ships, $600,000 in refunds, and millions of dollars in “gifted packages.” The data manipulation resulted in a false loss representation of up to $32 million greater than what was presented to the jury. In short, Sewell presented victim loss amounts that didn’t exist. There were no truthful representations of emperor purchaser losses in 101i.
The misrepresented loss data was presented as “loss evidence” alongside 16 witnesses and non-witnesses. The intentional presentation of 101i as a truthful representation of i2G Gains and Losses amounted to a deliberate act of subornation of perjury with these witnesses. Four key witnesses—two FBI agents, one government expert, and the data provider—made false statements regarding i2G Gains/Loss representations in 101i and other data. Sewell failed to correct any of these false statements, as required by the Napue decision.
This indictment stemmed from a Kansas lands seizure operation. False affidavits misrepresented a multi-level marketing (MLM) company as an investment, which resulted in a lis pendens being placed on a $3 million tract of land purchased by Raw Ventures, and the confiscation of hundreds of thousands of dollars in cash found in Richard Maike’s home and safety deposit boxes. The affidavit failed to identify i2g as a multi-level company or the alleged victims as distributor product purchasers. The motion for lis pendens was filed on January 14, 2015. After 2.5 years of attempting to resolve the land issue through civil means, the government intensified its efforts to acquire the Raw Ventures land by filing a criminal indictment in 2017. This indictment included four top-earning MLM distributors and allegedly named two owners.
Infinity Two Global operated as a multi-level company from August 2014 until December 31, 2014. The first indictment was filed on June 14, 2017. A superseding indictment followed on July 11, 2018, and a third superseding indictment was filed on July 11, 2019.
Initially, plea cooperation probation deals were offered to Hosseinipour and Anzalone. In May 2022, Anzalone accepted the plea cooperation deal. Hosseinipour did not and was tried alongside the owners, Maike and Barnes.
The trial, which took place in July 2022, resulted in the convictions of three individuals—Richard Maike, Doyce Barnes, and Faraday Hosseinipour—for conspiracy to commit mail fraud and conspiracy to commit securities fraud. However, the convictions were only achieved by Assistant District Madison Sewell and Marissa Ford by fraud upon the court through the manipulation of truthful exculpatory data to presenting false evidence of losses presented through 16 trial witnesses and non-witnesses. They also presented two years of data from a separate company which occurred AFTER i2G was closed. As a result of this misconduct, four individuals have been imprisoned, and the government has not taken any steps to rectify the false data or false statements presented during the trial.
The case is under appeal; however, the issues of prosecutorial misconduct have not been fully addressed. I am providing a detailed summary of the assistant district attorney’s actions to outline the far-reaching extent of the fraud.
All relevant documents, testimony, and data that support these allegations can be emailed or posted online. Verifying the false data is straightforward, as the data provided by its source confirms the commission figures. The provider has submitted an affidavit stating that the 101i data used at trial was “filtered” and false. Key commission data totaling $28 million was “filtered out” by request of Madison Sewell one week before the trial.
The truthful commission data contradicts what was presented to the jury. The government depicted I2G as a pyramid scheme with a 96% loss rate; however, the data reveals a different story, showing much higher-than-average earnings for a multi-level company in its first 18 months of operation. Government Exhibit 7240 and the “Total Commissions” data pulled by Reynolds after the trial show $40 million in product sales, with over $38 million paid out in distributor commissions. The government significantly exaggerated the I2G losses in 101i, represented as Total I2G Gains and Losses. This false data adversely affected the testimonies of 16 witnesses. The total gains represented in 101i to the jury indicated only $7.5 million in distributor gains as compared to the actual gains of over 38 million dollars.
Post-trial communication with the data provider and a review of the exculpatory data that the government sought to discredit reveal serious prosecutorial misconduct by Madison Sewell in collaboration with Marissa Ford. Furthermore, the appeal attorney, Tyler Lee, participated in this misconduct by presenting the known false data as the basis for her appeal arguments.
Attached is Detailed Explanation and Proof of the Prosecutorial Misconduct in the I2G Infinity Two Global Case