2021R00442/LR/SB

UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

UNITED STATES OF AMERICA Hon.

v. Crim. No. 22-

JAMES PATTEN, Count One

PETER COKER, SR., and 18 u.s.c. § 371
PETER COKER, JR. (Securities Fraud Conspiracy)

CountTwo
15 u.s.c. § 78ff
15 U.S.C. § 78j(b)
17 C.F.R. § 240. l0b-5
18 u.s.c. § 2
(Securities Fraud)

Count Three
18 u.s.c. § 371
(Conspiracy to Manipulate
Securities)

Counts Four through Seven

15 U.S.C. § 78i(a)(2)
15 u.s.c. § 78ff
18 u.s.c. § 2
(Manipulation of Securities
Prices)

Counts Eight through Eleven

18 u.s.c. § 1343
18 u.s.c. § 2
(Wire Fraud)

Count Twelve
18 U.S.C. § l 956(a)(l)(B)(i)
(Money Laundering)
 INDICTMENT

The Grand Jury in and for the District of New Jersey, sitting

at Newark, charges as follows:

COUNT ONE
(Conspiracy to Commit Securities Fraud - 18 U.S.C. § 371)

Individuals, Entities, and Definitions

1. At all times relevant to this Indictment:

a. The entity referred to as the "Deli" herein was a delicatessen

located in Paulsboro, New Jersey that was incorporated under the laws of Nevada

in or around 2015. The Deli was closed at certain points during the period of the

Indictment.

b. Hometown International, Inc. ("Hometown International"), a

publicly traded company that utilized the ticker "HWIN," was the umbrella

corporation of which the Deli was a wholly owned subsidiary.

c. E-Waste Corporation ("E-Waste"), incorporated in Florida in

or around 2012, was a publicly traded company that utilized the ticker "EWST."

d. Defendant JAMES PATTEN ("PATTEN") was a resident of

Basking Ridge, New Jersey until in or around August 2017 and then Winston-

Salem, North Carolina. PATTEN previously worked as a stockbroker, but the

Financial Industry Regulatory Authority, Inc. ("FINRA") barred PATTEN acting as

a stockbroker or associating with broker-dealers in or around 2006.

e. Defendant PETER COKER, SR. ("COKER, SR.") was a resident

of Chapel Hill, North Carolina.

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 f. Defendant PETER COKER, JR. ("COKER, JR.") was a resident

of Hong Kong, China.

g. Co-Conspirator-1 was a resident of Greensboro, North

Carolina.

h. Co-Conspirator-2 was a resident of Hong Kong, China.

i. Co-Conspirator-3 was a resident of Raleigh, North Carolina.

j. Co-Conspirator-4 was a resident of Hong Kong, China.

k. Tryon Capital LLC ("Tryon Capital"), a North Carolina limited

liability corporation, was controlled and operated by COKER, SR. and Co-

Conspirator-1. PATTEN was also associated with Tryon Capital.

1. VCH Limited, a Macau, China entity, was believed to be

controlled by COKER, JR.

m. Individual-1 was a resident of Gloucester County, New Jersey.

Individual-1 was one of the founders of the Deli and was initially listed as the

President of Hometown International.

n. Individual-2 was a resident of Salem County, New Jersey.

Individual-2 was one of the founders of the Deli and was initially listed as the

Vice-President of Hometown International.

o. Individual-3 was a resident of Staten Island, New York and

held an investment account at Brokerage Firm-1.

p. Individual-4, an immediate family member of PATTEN'S

romantic partner, was a resident of Gibson, New Jersey and held an investment

account at Brokerage Firm-2.

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 q. Individual-5, an immediate family member of COKER, SR.,

was a resident of Greensboro, North Carolina who held an investment account

at Brokerage Firm -3.

r. Individual-6 was a resident of Glen Ridge, New Jersey.

s. Individual-7 was a resident of Greensboro, North Carolina and

held an investment account at Brokerage Firm-3.

t. Individual-8 was a resident of Greensboro, North Carolina and

held an investment account at Brokerage Firm-3.

u. Individual-9 was a resident of Bahama, North Carolina.

v. The OTC Link Alternative Trading System is an alternative

trading system that contains three tiers of markets, which are largely based on

the quality and quantity of the listed companies' information and disclosures.

"OTC Pink" is the lowest tier, and most speculative of the marketplaces. "OTCQB"

is the middle tier, which requires that listed companies meet certain eligibility

standards. "OTCQX" is the top tier of the three marketplaces and requires that

listed companies meet more stringent eligibility requirements (altogether, the

"OTC Marketplace"). Stocks sold on the OTC Marketplace are particularly

susceptible to manipulative trading and other forms of fraud because, among

other things, they are often thinly traded, and their free-trading shares may be

controlled by a single individual or group of individuals. OTC Marketplace's

primary servers are in New Jersey.

w. "Wash Trades" are purchases and sales of securities that

match each other in price, volume, and time of execution, and involve no change

4
in beneficial ownership. For example, a Wash Trade takes place when Investor A

buys 100 shares of Company A at $5.00 through Broker A while simultaneously

selling 100 shares of Company A at $5.00 through Broker B.

x. "Match Trades" are similar to Wash Trades, but involve a

related third-person or third-party who conducts one side of the trade. For

example, a Match Trade takes place when Investor A buys 100 shares of

Company A at $5.00, while Investor B, who coordinates with Investor A,

simultaneously sells 100 shares of Company A at $5.00.

y. "Coordinated Trading Events" or "CTEs" are trading events,

such as Match Trades and Wash Trades, that are used to create the appearance

that a given stock price rose as a result of genuine market demand for the

manipulated security.

z. A "Reverse Merger" is a transaction through which an existing

public company merges with a private operating company-usually one that is

seeking access to funding in the United States capital markets in order for the

private operating company to be listed on an exchange without conducting an

initial public offering. Typically, the shareholders of the private operating

company exchange their shares for a large majority of the shares of the public

company. While the public company technically "survives" the Reverse Merger,

the private operating company's shareholders gain a controlling interest in the

voting power and outstanding shares of stock. Additionally, the private

company's management typically takes over and replaces the board of directors

and management of the public company.

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 The Conspiracy

2. From in or around 2014 through in or around September 2022, in

Gloucester County, in the District of New Jersey, and elsewhere, the defendants,

JAMES PATTEN,
PETER COKER, SR., and
PETER COKER, JR.,

did willfully and knowingly combine, conspire, confederate and agree with each

other and others, by the use of the means and instrumentalities of interstate

commerce, and of the mails, and of facilities of national securities exchanges, to

use and employ, in connection with the purchase and sale of securities,

manipulative and deceptive devices and contrivances by: (a) employing devices,

schemes, and artifices to defraud; (b) making untrue statements of material facts

and omitting to state material facts necessary in order to make the statements

made, in light of the circumstances under which they were made, not misleading;

and (c) engaging in acts, practices and courses of business which operated and

would operate as a fraud and deceit upon persons, contrary to Title 15, United

States Code, Sections 78j(b) and 78ff, and Title 17, Code of Federal Regulations,

Section 240. l0b-5.

Goal of the Conspiracy

3. The goal of the conspiracy was for PATTEN, COKER, SR., COKER,

JR. and their Co-Conspirators to enrich themselves through a scheme to

manipulate the price of securities through a pattern of coordinated conduct

intended to deceive, and by making and causing to be made fraudulent

pretenses, representations, and promises to brokerage firms, market makers,

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market regulators, and the trading public, injecting inaccurate information into

the marketplace, and creating false impressions of supply and demand for these

securities.

Manner and Means

4. It was part of the conspiracy that:

a. To accomplish the goal of the conspiracy, PATTEN, COKER,

SR., and COKER, JR. targeted two publicly traded companies, the first of which

they caused to be created: (1) Hometown International, and (2) E-Waste. In both

cases, PATTEN capitalized on long-term friendships and preyed on his friends

and associates by presenting the plan as a legitimate business opportunity, as

opposed to a fraudulent scheme. PATTEN, COKER, SR., and COKER, JR. took

significant steps to gain control of the respective entities' management and stock

with the ultimate intention of entering Reverse Mergers that would allow them

to sell shares of each respective entity at a significant profit resulting from

market manipulation.

The Hometown International Scheme

b. In or around 2014, Individual-1 and Individual-2 began the

process of opening a local delicatessen to operate in Paulsboro, New Jersey (i.e.,

the Deli). Individual-1 discussed his interest in opening the Deli with PATTEN, a

long-time friend. PATTEN, who had a background in business and finance,

offered to assist Individual-1 and Individual-2 with opening the Deli and

recommended that Individual-1 and Individual-2 incorporate the Deli. In

addition, while residing in Basking Ridge, New Jersey, PATTEN suggested the

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creation of Hometown International, an umbrella corporation, under which the

Deli would operate as a wholly owned subsidiary. PATTEN explained that

creating Hometown International would allow for easy expansion in the event the

Deli was successful.

c. The Deli opened for business on or about October 14, 2015.

Individual-1 and Individual-2 were responsible for the day-to-day operations of

the Deli. Although Individual-1 was listed as the President, and Individual-2 the

Vice-President of Hometown International, PATTEN acted as an unnamed control

person and handled the majority of corporate-related decisions, issues, and

tasks. Indeed, Individual-1 and Individual-2 were nominal officers-that is,

Individual-1 and Individual-2 had virtually no involvement or practical

responsibilities with respect to the control, operation, and management of

Hometown International.

d. Almost immediately after Hometown International was

formed, PATTEN and his associates began positioning Hometown International

as a vehicle for a Reverse Merger that would yield substantial profit to them.

From in or around July 2014 through in or around June 2015, PATTEN and

COKER, SR. arranged the private sale of Hometown International shares to a

number of individuals and entities that were either related to, or associated with,

PATTEN, COKER, SR., COKER, JR., and/or Co-Conspirator-1, COKER, SR.'s

business associate. These shares were exempt from registration under

Regulation D of the Securities Act, a Securities and Exchange ("SEC") regulation

8
governing private placement exemptions, meanmg they did not have to be

registered with the SEC.

e. In or around October 2019, Hometown International began

publicly selling shares on OTC Pink. Shortly thereafter, PATTEN, COKER, SR.,

and COKER, JR. undertook a calculated scheme to gain control of Hometown

International's shares. In or around December 2019, PATTEN arranged for

COKER, JR. to purchase approximately 2 million shares, constituting

approximately 38% of the outstanding Hometown International stock, from

Individual-1 and Individual-2 for approximately $3,000. In or around February

2020, PATTEN arranged for the sale of an option to COKER, JR. that would allow

him to purchase approximately 1.5 million shares, constituting approximately

28% of the outstanding Hometown International stock, from Individual-2.

Shortly thereafter, COKER, JR. became Hometown International's Chairman of

the Board. In or around March 2020, COKER, JR. exercised the option and

purchased the approximately 1.5 million shares for approximately $500.

f. After gaming control of Hometown International's

management and stock, PATTEN, COKER, SR., and COKER, JR. undertook a

scheme to transfer the shares to nominee entities and family members, friends,

and associates. PATTEN, COKER, SR., and COKER, JR. transferred the shares

for three primary purposes: (1) to give the appearance that there were more

shareholders than there actually were; (2) to facilitate CTEs in order to artificially

inflate the price of Hometown International's stock without alerting brokerage

firms, market makers, market regulators, and the trading public; and (3) to give

9
the appearance of an arm's-length relationship between management and

shareholders.

g. As part of the scheme, in or around March 2020, Hometown

International issued approximately 100,000 shares of common stock to Europa

Capital Investments, LLC ("Europa Capital"), an entity controlled by COKER, SR.

and Co-Conspirator-1. In or around April 2020, PATIEN, COKER, SR., and

COKER, JR. arranged for the approximately 3.5 million Hometown International

shares that COKER, JR. had acquired from Individual-1 and Individual-2 to be

transferred to four nominee entities in Macau, China (including VCH Limited),

all of which were under COKER, JR.'s control, but formally in the names of other

individuals. In or around May 2020, Europa Capital began systematically

"gifting" its approximately 100,000 shares to approximately twenty-one (21)

individuals, most of whom had a relationship with PATIEN, COKER, SR.,

COKER, JR., and/or Co-Conspirator-1.

h. Once PATIEN, COKER, SR., and COKER, JR. had transferred

the majority of the Hometown International shares, they arranged the filing of a

Form S-1 Registration Statement with the SEC in order to register these shares

(the "Form S-1 Application"), thereby enabling the sale of Hometown

International shares on the open market. Despite the fact that the shares were

registered to their friends, family members, associates, and entities under their

control, the Form S-1 Application stated that "[n]one of the Selling Shareholders

nor any of their respective affiliates have held a position or office, or had any

other material relationship with us or any of our predecessors or affiliates." The

10
SEC approved the Form S-1 Application on or about October 15, 2020 (the "S-1

Approval").

1. PATTEN, COKER, SR., and COKER, JR. used the S-1 Approval

and the transfer of shares to their family, friends, and associates to "uplist"

Hometown International from OTC Pink to OTCQB, a more desirable market

within the OTC Marketplace that has a fifty-shareholder requirement. This

elevation was advantageous in that it provided fewer restrictions to trading and

greater visibility for Hometown International. But most notably, this elevation

allowed Hometown International shares to be sold at a price greater than $6.50

per share, the amount at which they were previously capped.

j. The elevation to the OTCQB allowed PATTEN, COKER, SR.,

and COKER, JR. to facilitate their fraudulent scheme. Once PATTEN, COKER,

SR., and COKER, JR. had the ability to trade the shares on the open market

without price restrictions, they systematically engaged and caused others to

engage in a series of contemporaneous transactions designed to artificially

influence the market price of Hometown International's stock based on the false

impression that there was real market interest in the securities through Match

Trades and Wash Trades (i.e., Coordinated Trading Events or CTEs). PATTEN,

COKER, SR., and COKER, JR engaged and caused others to engage in these

CTEs in order to artificially increase the stock price of Hometown International

and ultimately make Hometown International appear attractive to private

companies interested in a Reverse Merger with a publicly traded company, at

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which point PATTEN, COKER, SR., and COKER, JR. would arrange the sale of

HWIN shares at a profit.

k. PATTEN, COKER, SR., and COKER, JR.: (1) engaged other

individuals who they encouraged to participate in certain aspects of the CTEs;

and (2) gained access and control over trading accounts that were rightfully held

by their family members, friends, and associates, and used those accounts to

engage in CTEs. This had the effect of masking PATTEN, COKER, SR., and

COKER, JR. 's participation in and control of the affected entities and accounts.

1. For example, on or about December 15, 2020, COKER, JR., in

an email to PATTEN and COKER, SR., advised that he had engaged Co-

Conspirator-2 to participate in CTEs, stating "[First name and last initial of Co-

Conspirator-2] MY HOTEL GUY SHOULD HAVE HIS ACCOUNT SET UP TO

TRADE HWIN BY THURSDAY LATEST. I WILL PUT YOU GUYS IN TOUCH WITH

[Co-Conspirator-l's first name] TO GET HIS ORDERS SORTED ON A DAILY

BASIS." Shortly thereafter, Co-Conspirator-2 and PATTEN engaged in the

following CTEs:

i. On or about December 15, 2020, Co-Conspirator-2

placed an order to purchase 100 shares of Hometown International

for $11.85 per share. This order was filled by an account that was

registered to Individual-3, an associate of PATTEN, from an IP

Address that resolved to PATTEN'S residence.

ii. On or about January 5, 2021, at approximately 11:13

a.m., Co-Conspirator-2 placed an order to purchase 100 shares of

12
 Hometown International for $13.25 per share. Shortly thereafter, at

approximately 12:49 p.m., this order was filled by an account

registered to Individual-4, an individual related to PATTEN'S

romantic partner, from an IP Address that resolved to PATTEN'S

residence.

111. On or about January 29, 2021, at approximately 11:03

a.m., Co-Conspirator-2 placed an order to purchase 100 shares of

Hometown International for $13.70. Minutes later, at approximately

11:06 a.m., this order was filled by an account registered to

Individual-5, an immediate family member of COKER, SR., from an

IP Address that resolved to PATTEN'S residence.

m. As noted above, PATTEN, COKER, SR., and COKER, JR. also

facilitated CTEs by accessing trading accounts that belonged to their family

members, friends, and associates. For instance:

i. On or about January 19, 2021, the account registered

to Individual-3 placed an order to purchase 200 shares of Hometown

International for $13.99 per share. This order was filled by

Individual-4. Notably, both of these transactions were conducted

from an IP Address that resolved to PATTEN'S residence.

ii. On or about February 4, 2021, at approximately 11:56

a.m., the account registered to Co-Conspirator-2 placed an order to

purchase 100 shares of Hometown International for $13.80 per

share. Approximately twenty minutes later, at approximately 12: 19

13
 p.rn., this order was filled by an account registered to COKER, SR.

Notably, both transactions were conducted from an IP Address that

resolved to PATTEN and COKER, SR.'s place of employment.

iii. On or about February 22, 2021, at approximately 9: 17

a.rn., the account registered to Co-Conspirator-2 placed two orders

to purchase 100 shares of Hometown International for $13.85 per

share from an IP Address associated with COKER, SR.

Approximately two hours later, at 11:21 a.rn., one order was filled

by an account registered to COKER, SR. from an IP Address that

resolved to PATTEN'S residence. Shortly thereafter, at approximately

12:07 p.rn., the second order was filled by an account registered to

Individual-5 from an IP Address that resolved to PATTEN'S

residence.

n. PATTEN monitored the trading of Hometown International

shares and received weekly reports outlining the trading volume. For instance,

on or about February 13, 2021, PATTEN discussed a report with COKER, Sr.,

writing "everyone [is] playing nice. All seems to check out."

o. PATTEN, COKER, SR., and COKER, JR.'s efforts to

manipulate Hometown International's shares had the ultimate impact of

artificially inflating the stock approximately 939%. Indeed, on the first day that

Hometown International was publicly traded, on or about October 25, 2019, the

stock's closing price was approximately $1.25 per share. On or about April 16,

2021, Hometown International's stock closed at approximately $12.99 per share.

14
 p. In addition, in an effort to enrich themselves, over the course

of the scheme, PATTEN, COKER, SR., and COKER, JR. orchestrated the

execution of consulting agreements between Hometown International and Tryon

Capital, controlled by COKER, SR. and Co-Conspirator-1, and VCH Limited, one

of COKER JR. 's nominee entities. Pursuant to these agreements, Hometown

International paid approximately $15,000 per month to COKER, SR. and Co-

Conspirator-1 (through Tryon Capital), and approximately $25,000 a month to

COKER JR. (through VCH Limited) during the period of these consulting

agreements.

q. On March 31, 2022, Hometown International announced that

it had entered into a Reverse Merger with Makamer Holdings, Inc. Hometown

International's application to FINRA for a ticker symbol change remains pending.

PATTEN, COKER, SR., and COKER, JR. have not yet sold shares of Hometown

International for a profit.

The E-Waste Scheme

r. In or around September 2020, PATTEN recruited Individual-

6, another long-time friend, to assist E-Waste, an unsuccessful, yet publicly

traded company, in finding a candidate for a Reverse Merger. Shortly thereafter,

PATTEN arranged for Individual-6 to become Chief Executive Officer of E-Waste,

despite the fact that PATTEN was effectively in control. As with Hometown

International, PATTEN, COKER, SR., and COKER, JR. took actions to control E-

Waste's stock, artificially inflate its stock price through CTEs, and ultimately

market E-Waste in order to execute a Reverse Merger.

15
 s. PATIEN, COKER, SR., and COKER, JR. subsequently

arranged for the transfer of millions of shares of E-Waste stock to a number of

nominee entities, and to themselves personally. For instance, on or about

September 25, 2020, E-Waste sold approximately six-million shares to Global

Equity, an entity controlled by COKER, JR. On the same day, COKER, JR., and

Benchmark Capital, LLC, a company controlled by PATIEN, attained

approximately 475,000 and 250,000 shares of E-Waste, respectively. On or

about October 14, 2020, E-Waste sold approximately 500,000 shares to both

COKER, JR. and Europa Capital-an entity controlled by COKER, SR and Co-

Conspirator-1.

t. After PATIEN, COKER, SR., and COKER, JR. gained control

of E-Waste's shares, PATIEN commenced a series of CTEs intended to artificially

inflate the value of E-Waste's stock. For example:

1. On or about November 19, 2020 at approximately 11:21

a.m., an account registered to Individual-7 placed an order to buy

100 shares of E-Waste for $2.66 per share from an IP Address that

resolved to PATIEN'S residence. Approximately two minutes later,

at approximately 11:23 a.m., the order was filled by an account

registered to Individual-3 from the same IP Address, which, again,

resolved to PATIEN'S residence.

ii. On or about January 22, 2021, an account registered

to Individual-5 placed an order to purchase 200 shares of E-Waste

for $6.49 per share from an IP Address that resolved to PATIEN'S

16
 residence. The order was filled by an account registered to

Individual-3 from the same IP Address, which, again, resolved to

PATTEN'S residence.

111. On or about March 22, 2021, at approximately 2:17

p.m., an account registered to Individual-7 placed an order to

purchase 176 shares of E-Waste for $9.46 per share from an IP

Address that resolved to PATTEN'S residence. Approximately two

minutes later, at 2:19 p.m., the order was filled by an account

registered to Individual-8 from the same IP Address, which, again,

resolved to PATTEN'S residence.

iv. On or about April 9, 2021, at approximately 1:27 p.m.,

an account registered to Individual-7 placed an order to purchase

100 shares of E-Waste for $10.00 per share from an IP Address that

resolved to PATTEN'S residence. Approximately ten minutes later, at

1:37 p.m., the order was filled by an account registered to

Individual-3 from the same IP Address, which, again, resolved to

PATTEN'S residence.

u. PATTEN, COKER, SR., and COKER, JR.'s efforts to

manipulate E-Waste's shares had the ultimate impact of artificially inflating the

stock approximately 19,900%. Indeed, on the first day of HWIN trading, July 6,

2020, EWST's closing price was approximately $0.05 per share. On April 16,

2021, EWST closed at approximately $10.00 per share.

17
 v. In addition-like with Hometown International-in an effort to

enrich themselves, over the course of the scheme, PATTEN and COKER, SR.

orchestrated the execution of consulting agreements between E-Waste and Tryon

Capital, controlled by COKER, SR. and Co-Conspirator-1, and Benchmark

Capital, controlled by PATTEN. Pursuant to these agreements, E-Waste paid

$2,500 per month to COKER, SR. and Co-Conspirator-1 (through Tryon Capital),

and $5,000 a month to PATTEN (through Benchmark Capital) during the period

of these agreements.

w. In or around September 2021, E-Waste merged with EZRaider

Global, Inc. A registration statement has not yet been filed. PATTEN, COKER,

SR., and COKER, JR. have not yet sold their shares of E-Waste for a profit.

Overt Acts

5. In furtherance of the conspiracy and to effect the objects of the

conspiracy, the following overt acts, among others, were committed in the

District of New Jersey and elsewhere.

a. On or about February 20, 2017, PATTEN sent an email to

Individual-1 containing a letter, dated February 21, 2017, purportedly written

by Individual-1, to FINRA in response to an inquiry from FINRA regarding

Hometown International's common stock (the "February 21 Letter"). Individual-

1, who was residing in New Jersey, denied writing the February 21 Letter and

believes that PATTEN wrote the letter in his role as an unnamed control person

of Hometown International. The February 21 Letter appears to have been

18
intended to induce FINRA to approve a portion of Hometown International's

application to be listed on the OTC Marketplace.

b. On or about March 20, 2020, COKER, JR. sent an email to

COKER, SR., indicating that he had received advice from Co-Conspirator-4 to

"PUT MY SHARES INTO A COMPANY NOT IN MY NAME (FINE WITH ME)

BECAUSE WE ARE CLOSE AND IT COULD LOOK STRANGE TO HIS GUYS .. SO

CAN I GIVE YOU A COMPANY NAME TOMORROW WHERE WE CAN PUT THE

SHARES IN MACAO?" Shortly after this email, PATTEN, COKER, JR., and

COKER, SR. transferred approximately 3.5 million Hometown International

shares to a number of nominee entities located in Macao, China (including VCH

Limited).

c. On or about May 10, 2020, PATTEN sent an email to

Individual-9, copying COKER, SR., which contained wire transfer instructions to

pay VCH Limited $25,000 pursuant to one of the consulting agreements

discussed above. The investigation revealed that multiple large wire transfers

were conducted from Hometown International's bank account in New Jersey to

VCH Limited.

d. On or about November 10, 2020, COKER, JR. sent an email

to PATTEN, COKER, SR., Co-Conspirator-4, and others, stating "WE HAVE

SPENT AN ENORMOUS AMOUNT OF TIME CURATING THIS ASSET AND ARE

NOW READY TO TAKE HOMETOWN TO THE NEXT LEVEL (NASDAQ, ETC)."

e. On or about December 15, 2020, COKER, JR. sent an email

to PATTEN and COKER, SR., stating "[First name and last initial of Co-

19
Conspirator-2] MY HOTEL GUY SHOULD HAVE HIS ACCOUNT SET UP TO

TRADE HWIN BY THURSDAY LATEST. I WILL PUT YOU GUYS IN TOUCH WITH

[Co-Conspirator-l's first name] TO GET HIS ORDERS SORTED ON A DAILY

BASIS." COKER, SR. responded to COKER, JR.'s email that he "will keep it light."

As discussed above, Co-Conspirator-2 was an instrumental participant in the

CTEs that led to the artificial inflation of Hometown International's valuation.

f. On or about January 23, 2021, PATTEN sent an email to

COKER, SR. discussing the transfer and trade of a significant volume of shares.

COKER, SR. responded, "I have been looking at all of the others and making sure

I know what is going on. Can you take a copy of [Individual-S's] Fidelity account?"

As discussed, Individual-S's account was used in a number of CTEs involving

both Hometown International and E-Waste, the majority of which were

conducted from IP Addresses that resolved to PATTEN'S residence.

g. On or about February 28, 2021, PATTEN sent an email to

COKER, SR. stating, "[h]ere are the available cash balances: ... [Individual-7's

middle name] $S,902.41 - [abbreviation of Individual-S's first name] $2,980.34

- [Individual-S's first name] $4,790.64 ... " COKER, SR. responded, "[t]hanks

Jim. Is it easy to give me [Individual-S's first name's] holdings - if not please wait

until later as it is not urgent. Thanks." As discussed, Individual-S's trading

accounts were used to engage in multiple CTEs from an IP Address that resolved

to PATTEN.

20
 Conclusion

6. On or about April 16, 2021, a news article exposing Hometown

International and E-Waste's over-inflated market valuations was published.

PATIEN, COKER, JR., and COKER, SR. acknowledged reading the article in

email communications. The negative publicity, which received a significant

amount of attention, came at a point when PATIEN, COKER, SR., and COKER,

JR. were in the middle of the scheme, and had not yet sold their inflated shares.

All in violation of Title 18, United States Code, Section 371.

21
 COUNT TWO
(Securities Fraud - 15 U.S.C. § 78j(b))

7. Paragraphs One, Four, Five, and Six of Count One are re-alleged and

incorporated as if set forth fully herein.

8. From in or around 2014 through in or around September 2022, in

Gloucester County, in the District of New Jersey, and elsewhere, the defendants,

JAMES PATTEN,
PETER COKER, SR., and
PETER COKER, JR.,

knowingly and willfully, directly and indirectly, by the use of the means and

instrumentalities of interstate commerce, the mails, and the facilities of national

securities exchanges, in connection with the purchase and sale of securities, did

use and employ manipulative and deceptive devices and contrivances, and aided

and abetted others known and unknown to the grand jury, and attempted to do

so by: (a) employing devices, schemes, and artifices to defraud; (b) making, and

causing others to make, untrue statements of material facts and omitting to state

material facts necessary in order to make the statements made, in the light of

the circumstances under which they were made, not misleading; and (c) engaging

in acts, practices, and courses of business which operated and would operate as

a fraud and deceit upon persons-that is, PATTEN, COKER, SR., and COKER,

JR. and others engaged in a scheme to manipulate the price of securities through

a pattern of coordinated trading conduct intended to deceive, and by making and

causing to be made fraudulent pretenses, representations, and promises to,

brokerage firms, market makers, market regulators, and the trading public,

22
injecting inaccurate information into the marketplace, and creating the false

impressions of supply and demand for these securities.

In violation of Title 15, United States Code, Sections 78j(b) and 78ff, Title

17, Code of Federal Regulations, Section 240. l0b-5, and Title 18, United States

Code, Section 2.

23
 COUNT THREE
(Conspiracy to Manipulate Securities Prices - 18 U.S.C. § 371)

9. Paragraphs One, Four, Five, and Six of Count One are re-alleged and

incorporated as if set forth fully herein.

10. From in or around 2014 through in or around September 2022, in

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

JAMES PATTEN,
PETER COKER, SR., and
PETER COKER, JR.,

did willfully and knowingly combine, conspire, confederate and agree with each

other and others, to, alone and with one or more other persons, effect a series of

transactions, in securities registered on a national securities exchange, creating

actual or apparent active trading in such security, and raising or depressing the

price of such security, for the purpose of inducing the purchase and sale of such

security by others, contrary to Title 15, United States Code, Sections 78i(a)(2)

and 78ff, and Title 18, United States Code, Section 2.

Goal of the Conspiracy

11. The goal of the conspiracy was for PATTEN, COKER, SR., COKER,

JR., and their Co-Conspirators to unlawfully manipulate the price of the

securities in which they were trading and to profit from their actions.

Overt Acts

12. In furtherance of the conspiracy and to effect the objects of the

conspiracy, the overt acts described in Paragraph 5 of Count One, among others,

were committed in the District of New Jersey and elsewhere.

All in violation of Title 18, United States Code, Section 371.

24
 COUNTS FOUR THROUGH SEVEN
(Manipulation of Securities Prices - 15 U.S.C. §§ 78i(a)(2) and 78ft)

13. Paragraphs One, Four, Five, and Six of Count One are re-alleged and

incorporated as if set forth fully herein.

14. From in or around 2014 through in or around September 2022, in

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

JAMES PATTEN,

willfully, alone and with one or more other persons, effected a series of

transactions, in a security registered on a national securities exchange, creating

actual or apparent active trading in such security, and raising or depressing the

price of such security, for the purpose of inducing the purchase and sale of such

security by others, to wit: the CTE transactions set forth below, each constituting

a separate count of this Indictment:

Count Approximate Date and Time Ticker Brokerage Accounts

Four March 1, 2021 HWIN Individual-3's account

12:00 p.m. at Brokerage Firm-1
Five March 1, 2021 HWIN Individual-4's account
12:01 p.m. at Brokerage Firm-2
Six April9,2021 EWST Individual-Ts account
1:27 p.m. at Brokerage Firm-3
Seven April 9, 2021 EWST Individual-3's account
1:37 p.m. at Brokerage Firm-1

In violation of Title 15, United States Code, Sections 78i(a)(2) and 78ff, and

Title 18, United States Code, Section 2.

25
 COUNTS EIGHT THROUGH ELEVEN
(Wire Fraud - 18 U.S.C. § 1343)

15. Paragraphs One, Four, Five, and Six of Count One are re-alleged and

incorporated as if set forth fully herein.

16. From in or around November 2020 through in or around April 2021,

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

JAMES PATTEN,

did knowingly and intentionally devise a scheme and artifice to defraud investors

and potential investors in Hometown International and E-Waste, and to obtain

money and property from them by means of materially false and fraudulent

pretenses, representations, and promises.

17. The object of this scheme and artifice was to artificially inflate the

stock price of Hometown International and E-Waste through multiple stock

trading transactions, or CTEs, so that PATTEN and others could profit and

unlawfully enrich themselves.

18. On or about the dates set forth below, for the purpose of executing

such scheme and artifice, the defendant, and others, did transmit and cause to

be transmitted, by means of wire communication in interstate and foreign

commerce, writings, signs, signals, pictures, and sounds, as set forth below:

Count Approximate Date Description

Eight March 1, 2021 At approximately 12:00 p.m., an

account registered to Individual-3
placed an order to purchase 100 shares
of Hometown International Stock for
$13.85 per share. This transaction
occurred from an IP Address that

26
 resolved to PATTEN's residence in
Winston-Salem, North Carolina and
involved OTC Market Servers in the
District of New Jersey.
Nine March 1, 2021 At approximately 12:01 p.m., the order
for 100 shares of HWIN stock,
referenced in Count Eight, was filled by
an account registered to Individual-4.
This transaction occurred from an IP
Address that resolved to PATTEN's
residence in Winston-Salem, North
Carolina and involved OTC Market
Servers in the District of New Jersey.
Ten April 9, 2021 At approximately 1:27 p.m., an account
registered to Individual-7 placed an
order to purchase 100 shares of E-
Waste stock for $10.00 per share. This
transaction occurred from an IP Address
that resolved to PATTEN'S residence in
Winston-Salem, North Carolina and
involved OTC Market Servers in the
District of New Jersey.
Eleven April 9, 2021 At approximately 1:37 p.m., the order
for 100 shares of E-Waste stock,
referenced in Count Ten, was filled by
an account registered to Individual-3.
This transaction occurred from an IP
Address that resolved to PATTEN'S
residence in Winston-Salem, North
Carolina and involved OTC Market
Servers in the District of New Jersey.

In violation of Title 18, United States Code, Section 1343 and Section 2.

27
 COUNT TWELVE
(Laundering of Monetary Instruments - 18 U.S.C. § 1956(a)(l)(B)(i))

19. Paragraphs Fifteen through Eighteen of Counts Eight through

Eleven are re-alleged and incorporated as if fully set forth herein.

20. From in or around November 2020 through in or around April 2021,

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

JAMES PATTEN,

knowing that the property involved in certain financial transactions, to wit, the

manipulative purchases and sales of securities through brokerage accounts

belonging to others, as outlined in Counts Eight through Eleven, represented the

proceeds of some form of unlawful activity, would and did conduct and attempt

to conduct such financial transactions, which in fact involved the proceeds of

specified unlawful activity as defined in Title 18, United States Code, Section

l 956(c)(7), to wit, proceeds from wire fraud, knowing that the transactions were

designed in whole or in part to conceal and disguise the nature, location, source,

ownership and control or the proceeds of specified unlawful activity.

In violation of Title 18, United States Code, Section 1956(a)(l)(B)(i) and

Section 2.

28
 FORFEITURE ALLEGATION AS TO COUNTS ONE THROUGH ELEVEN

1. Upon conviction of the offenses charged in Counts One through

Eleven of this Indictment, the defendants,

JAMES PATTEN,
PETER COKER, SR., and
PETER COKER, JR.,

shall forfeit to the United States, pursuant to Title 18, United States Code,

Section 981(a)(l)(C), and Title 28, United States Code, Section 2461(c), all

property, real and personal, that constitutes or is derived from proceeds

traceable to the commission of the offenses charged in Counts One through

Eleven of this Indictment, and all property traceable thereto.

FORFEITURE ALLEGATION AS TO COUNT TWELVE

2. As a result of committing the money laundering offense charged in

Count Twelve of this Indictment, the defendant,

JAMES PATTEN,

shall forfeit to the United States, pursuant to Title 18, United States Code,

Section 982(a)(l), all property, real or personal, involved in such money

laundering offense, and all property traceable to such property.

29
 Substitute Assets Provision

2. If any of the above-described forfeitable property, as a result of any

act or omission of the defendants:

a. cann ot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third person;

c. has been placed beyond the jurisdiction of the Court;

d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be

subdivided without difficulty,

it is the intent to the United States, pursuant to Title 21, United States Code,

Section 853(p), as incorporated by Title 28, United States Code, Section 2461 (c),

to seek forfeiture or any other property of the defendants up to the value of the

above-described forfeitable property.

A TRUE BILL

~ t i - -
PHILIP R. SELLINGER
~
United States Attorney

30
 CASE NUMBER: 22-

United States District Court .

District of New Jersey
UNITED STATES OF AMERICA

v.

JAMES PATTEN,
PETER COKER, SR., &
PETER COKER, JR.

INDICTMENT FOR
15 U.S.C. §§ 78ff, 78j(b) & 78i(a)(2)
17 C.F.R. § 240. l 0b-5
18 U.S.C. § 2
18 U.S.C. § 371
18 u.s.c . § 1343
18 U .S .C. § 1956 (a)(l)(B)(i)

PHILIP R . SELLINGER
UNITED STATES AITORNEY
NEWARK, NEW JERSEY

LAUREN E. R EPOLE
SHAWN P. BARNES
ASSISTANT UNITED STATES AITORNEYS
(973) 645-2848