Does Cocaine Come With That Lexus?
The Not So Charmed World of Charm City Motors
The courtroom was emptying out and tears lingered on Steven Ray Custis' cheek as he contemplated the biggest break of his life. The heavyset 34-year-old, known to hundreds of Baltimore teenagers as "Pop," had just been spared prison time despite his role in a five-year drug conspiracy from the late 1990s involving Charm City Motors, a used-car dealership on Reisterstown Road. "Let's go home, Big Boy," a family member said at the May 23 federal court sentencing, as Custis gathered himself and walked out a free man.
Custis pleaded guilty in January to conspiracy to distribute cocaine and marijuana in a scheme that lasted from 1997 to 2002. In 2000, police nabbed an associate of his in Texas carrying 3.2 kilograms of coke in a hidden compartment inside a car that had come right off Charm City's lot. Along with company president Harrington Campbell, who after a conviction in April on drug and fraud charges has yet to be sentenced, Custis moved dope for years using Charm City Motors as a conduit. Custis is also coach of the Charm City Buccaneers, a Pop Warner football team once sponsored by Charm City Motors, and he co-founded a youth baseball league named after a famous Negro League star.
In sparing Custis, U.S. District Judge Catherine Blake accepted his explanation that he had walked away from the drug game after the 2000 Texas bust and devoted his life to mentoring kids and renovating slum housing for the benefit of recovering addicts. While his family members watched and held their breath, Custis apologized to Blake for selling drugs in the community where he claimed to be a legitimate leader. "I did wrong and tried to make up for it," Custis sobbed, as he described a humble journey of redemption that went unchallenged by the federal prosecutor.
For weeks since that day in court, after initially agreeing to an interview, he avoided talking about his renaissance, emerging shortly before press time for this story with answers to at least some questions about his past. It is clear, however, that before his redemption, Custis worked with Campbell and others to use Charm City Motors to exploit a poorly regulated industry that is known among law enforcers as a pipeline for drug traffickers to move dope and launder money with little chance of getting caught.
A typical scam--one that Charm City Motors engaged in, according to court testimony--involves using drug cash to buy cars and issuing fake loan documentation associated with the purchase. When law-enforcement officers seize the vehicles, which often happens, the car dealer tries to repossess the car with a phony lien. The express purpose of such a scam, according to veteran law enforcers who have seen it executed to perfection, is to facilitate drug trafficking and money laundering by keeping cars and money moving through the underground economy.
According to local, state, and federal law enforcers, there's only so much the government can do to prevent it. "After a while, it's like being a doctor," says veteran Assistant State's Attorney Rudolph Drayton, who handles on average more than 300 drug-related forfeitures per year. "You see similar patterns of illness, and it's just a matter of how the illness was contracted."
In the mid-1990s, Custis and Campbell, members of Northwestern High School's class of 1992, saw an opportunity to exploit such gaps in the system. In 1995, Charm City Motors opened for business, incorporated in the name of Campbell's sister, Collette. Though Campbell had no criminal record at the time, for Custis, who says he joined the company in 1997, it was not his first foray into Baltimore's shadow economy. Like many young men, he had an unfortunate early childhood. His father was incarcerated, and his mother was a heroin user who died from an overdose when he was 18, so he was raised by his grandmother. He witnessed family members who abused drugs and was convicted in a drug-related conspiracy in 1992.
Nevertheless, Custis showed initiative. In the early 1990s, before going into business with Campbell, he began rehabbing slum houses and selling them to working people for reasonable prices. At Charm City Motors, the two started slowly by specializing in low-budget used cars in the rough Park Heights neighborhood, on a stretch of Reisterstown Road that includes numerous auto repair shops and dealerships.
On a recent weekday, that commercial stretch was still thriving. No one answered the door at Charm City Motors, however, which is housed in an attractive red and yellow building with fresh paint and stucco. A Buick Riviera, a Toyota Camry and a Pacifica sat unattended on the lot. Neighboring auto shops were open for business at the corner of Reisterstown Road and Shirley Avenue, in front of the Malcolm X Youth Center. A colorful mural adorns the side of Charm City Motors, behind which sits the Towanda Recreation Center, where a group of boys idled by the woods beyond the outfield of a baseball diamond, and two city Department of Recreation and Parks employees sat in a truck in a nearby cul-de-sac under a Kurt Schmoke drug free school zone sign.
Employees at the neighboring businesses were eerily silent in response to questions about Custis, Campbell, and Charm City Motors. Harrington Campbell declined to comment for this story.
Drug dealers need to wash tons of cash through legitimate businesses before they can spend it. To counter money laundering, the federal government requires all cash transactions involving $10,000 or more to be reported to the Internal Revenue Service. Auto liens are but one way drug dealers skirt that law. Here's how it works:
A used-car dealer has a luxury car for sale for $20,000, and a drug dealer buys the car with $15,000 in dirty cash. The car dealer creates documentation of a bogus car loan and records a phony lien in its own name for $5,000. The car dealer also records a trade-in of a vehicle worth $10,000 without actually accepting a trade-in. The effect is that the car dealer avoids having to report a $15,000 cash payment to the IRS. Then, when the drug dealer gets caught and authorities seize the car, the car dealer repossesses the vehicle using the phony lien as a hook. Sometimes the car dealer records a trade-in to account for the full purchase value, using a ghost vehicle identification number, which has the same effect as keeping a cash transaction off paper. A drug dealer often will send a friend, lover, or family member to buy the car as a straw purchaser, so the documentation is in someone else's name.
Charm City Motors is one of 301 used-car dealers in Baltimore City, according to the Maryland Motor Vehicle Administration (MVA), which issues dealer licenses and enforces the state's vehicle code. But despite a background-check requirement that gives the MVA authority to deny a license to anyone convicted of a serious crime, the MVA has no specific policy regarding the denial of licenses to convicted drug dealers, according to MVA special projects manager Andy Srebroski. Once a used-car dealer is in business, Srebroski says, the majority of MVA's 35 investigators spend 98 percent of their time responding to consumer complaints--about 3,000 per year--or site-inspection requests by prospective dealers. "We would love to be proactive, but we have a small number of people who are required to react to consumer complaints first. And consumers will complain about anything."
Srebroski says the MVA has occasion to work with law enforcement on cases of auto theft, fraud, and special investigations related to drug trafficking, but usually in a reactive manner. So if a used-car dealer is selling drugs or systematically recording fake liens and selling cars to drug dealers, the MVA might be the last to find out. The same goes for straw purchasers, he says. "We go by what's on paper. Unless it starts on paper, we're not going to look at it."
A typical eyebrow raiser, according to Drayton and other law enforcers, is the sale of used cars at inflated prices with high interest rates to people who have little or no legitimate income and poor credit. However, that may describe any number of low-income folks, and even when a drug trafficker buys a used car and gets caught dealing drugs, there's no guarantee the car dealer had any idea whom he was selling to.
Law enforcers in Baltimore also may notice certain car dealers extending loans without going through a third-party lending company and then recording liens on the cars they sell. When those same companies assert liens on seized late-model luxury cars favored by drug dealers, such as Lexuses, BMWs, Mercedes, or Cadillacs, that's a tip-off that illicit activity may be taking place.
The problem is that such information is culled from a revolving door of cars that pass through asset-forfeiture divisions of law-enforcement agencies, based on day-to-day activities of police who mostly are interested in capturing criminals and taking drugs off the street. Last year, Baltimore City seized more than 400 vehicles that were involved in drug trafficking. "We don't have a set routine," says Sgt. John Taylor of Baltimore Police Department's Violent Crime Impact Division, when asked if the city has a task force or protocol for targeting criminals in the used-car business. "It's a case-by-case basis."
What's more, Maryland's vehicle-forfeiture laws are drafted in a way that makes it easy for lien holders to get forfeited cars back in their possession--a loophole so big that drug dealers and corrupt auto dealers can drive a truck through it.
According to court records, Custis and Campbell began dealing drugs in 1997. In time the two began selling late-model luxury cars purchased wholesale at auto auctions in Pennsylvania. The cars were sold at high retail prices with steep interest rates. Wire transfers intercepted by federal investigators showed that Custis and Campbell had also begun buying drugs from a major Los Angeles drug trafficker named Jerome Bruce, who had a Mexican connection named Cesar Aragon. The California connection was supplemented by a connection in Texas, and in 2000, Custis and unnamed co-conspirators recruited a man named Norman Edmond to drive to Texas in a car purchased at Charm City Motors that contained a secret compartment for storing drugs. Once in Texas, Edmond was to meet Campbell, who had flown down from Baltimore.
At his sentencing in May, Custis contended that his involvement with drugs ended that same year, after Edmond was arrested leaving the Houston area with 3.2 kilos of cocaine that Campbell had placed in the compartment of the car bound for Baltimore. Custis, who provided cash for a lawyer to defend Edmond against charges in Texas, said that the incident, coupled with the birth of his daughter, set him on a straight and narrow path.
At Campbell's trial in April, the testimony of Edmond, Bruce, and a third convicted drug dealer named Reginald Jones established that Campbell was buying drugs wholesale and selling retail, just like with his cars. The used-car business provided not just a business front, but also an opportunity to work different financial scams. The jury heard how Jones would pay cash for a vehicle--with drug money--and also buy cocaine from Campbell while he was at it. Then, according to Jones, Campbell would issue phony loan documentation and take out a bogus lien on the car so that, in case it was seized and forfeited by the government, Charm City Motors could claim the loan was in default and get the car back to be resold or traded. Court records indicate that since 2002--two years after Custis left the company and claims to have gone straight--Charm City placed liens on at least eight cars, including a 1997 Mercedes Benz E 420, a 1995 Chevrolet Tahoe, and a 1997 Acura that were later seized by the police. In most cases, after asserting their liens, Charm City abandoned efforts to get the cars back when authorities asked for more documentation.
Court records further show that Charm City operated in a violent criminal milieu. A list of customers who bought cars from Charm City that were seized from 1999 to 2005 includes convicted drug traffickers and a rapist. A 2007 federal indictment out of Philadelphia alleging a murderous, multimillion-dollar drug conspiracy known as the "Phillips Cocaine Organization" shows that members of that group, led by Maurice Phillips, bought cars from Charm City as well. One former employee whose wages were garnished in 2001, Shannon Starke, has state drug convictions from 1996 and 2003. In 2002, Starke also was charged and later convicted in federal court on wire fraud for his part in a complex nationwide conspiracy to obtain cash from finance companies through business leases for nonexistent computer equipment. He received probation.
Charm City was not the only questionable car dealer that found a home at Reisterstown Road and Shirley Avenue. A dealership named Platinum Motors was located at 4016 Reisterstown Road, on the same lot as Charm City. Founded in 2000 by Damon Young, who was convicted of drug trafficking in 1998, Platinum Motors also catered to--and hired--criminals.
Since 2002, according to court records, at least 16 customers bought cars at Platinum Motors--including several Lexuses, a Lincoln Mark VIII, and a Cadillac--that later were seized by the authorities in drug-related cases. Platinum had liens on all of them. One employee had a violent drug history.
In 2007, Young took over Select Autohaus on York Road in Cockeysville, which was founded in 2005 by Calvin Newsome Jr., who was convicted in 1997 on federal drug charges and sentenced to 70 months in prison. Select Autohaus appealed to a similar clientele. In January 2006, one customer had three of his cars forfeited on the same day: a 1999 Oldsmobile, a 2003 BMW 320i, and a 2000 Cadillac DeVille.
A visit to Select Autohaus indicated that a new dealer, Hunt Valley Auto, is now in business at that location. "We have nothing to do with those people," an employee at Hunt Valley Auto says, when asked about Young and his associates. State records indicate that Platinum Motors was located at 5115 Pimlico Road, across from the racetrack, until 2005. The manager of a two-bay repair shop called Small's Garage at that address confirms that Platinum Motors, and Young, who once dealt used cars off a back lot, are long gone. On a recent visit to Small's, an upside-down Platinum Motors sign was leaning against the fence to the lot. "All sorts of people are looking for that guy," the manager says. "He still owes us money for rent." Efforts to reach Damon Young were unsuccessful.
In retrospect, it's a wonder Steven Custis was able to get out of the drug life. According to statements he made at his sentencing, at first he had to borrow money from a relative who borrowed against his own credit card. "I was broke when I left the game in 2000," he told Judge Blake. In an interview shortly before press time, after avoiding questions for weeks, Custis says, "You have to understand Charm City Motors was eight years ago for me. People who I'm doing business with now don't know about my past life." Custis further insists Charm City used his name after he broke ties with the company in 2000, and that he never had any involvement with Damon Young and Platinum Motors.
Custis' story leaves room for clarification that he admits he is hesitant to provide. "I don't want my words twisted, or it to seem like my situation is being thrown in the judge's face," he says.
In the mid-1990s, as he and Campbell were getting Charm City Motors off the ground, Custis approached a woman named Betty Hawkins, who was organizing a youth baseball organization in the name of famous Negro League star Leon Day, a Baltimore native who died shortly before his induction to the Hall of Fame in 1995. In a recent interview with City Paper, Hawkins, a friend of Day's widow Geraldine, says Custis wanted to help with the league and that Charm City Motors also wished to sponsor a Pop Warner football team, the Charm City Buccaneers. Those endeavors led to the establishment of the Leon Day Foundation in 2001, which lists Custis as treasurer. "We formed an organization and became a 501(c)(3)," Hawkins says, "so we could save at-risk kids" in the Franklintown Road area of Southwest Baltimore.
Custis also is the incorporator of a real-estate company called Metropolitan Baltimore Developers Inc. (MBD), which he founded in 2001. Though MBD and the Leon Day Foundation are not related entities, Custis is the link between the two; both forfeited their corporate charters at the same time in 2003 and revived them at the same time in '06. And though Custis told a federal judge in May that he left the drug game in 2000, the sole director of MBD beginning in late 2001 was Raeshio Rice, a leader of the Rice Organization, a violent drug-trafficking conspiracy in Northwest Baltimore that dates to the mid-1990s ("Wired," Mobtown Beat, March 2, 2005). The Rice Organization was known for transporting large amounts of cocaine and heroin across the United States--and laundering assets through real estate. In 2007, after pleading guilty to racketeering and conspiracy to distribute narcotics, Rice was sentenced to 27 years in federal prison.
"What does that have to do with me?" Custis protests, when asked about his business ties to the convicted racketeer. "If I had anything to do with that, I'd be in prison now, too, right?"
Steven Custis' brother Gregory (known as "Peanut") was also involved in the city's drug trade. In the late 1990s, while Custis and Campbell were dealing drugs, selling used cars, and sponsoring the Charm City Buccaneers, Peanut had his own Pop Warner football team. He was deep into the drug trade when, in 2003, police arrested him with large quantities of crack and several guns--one block from his brother Steven Custis' business at 2824 W. Cold Spring Lane. In 2006, Peanut was sentenced to five years in federal prison, with credit for time served since his arrest in 2003.
A recent visit to 2824 W. Cold Spring shows that it is a family residence, practically within eyeshot of the block where Peanut sold crack. "I don't know what my brother or the next person was doing," Steven Custis says. "He's a wonderful coach. As long as anyone is down here working with the kids, I don't care what they're doing in other areas of their life."
Pop Warner officials with the Metropolitan Baltimore Football Conference did not return calls and e-mails for comment.
Harrington Campbell and Steven Custis went their separate ways around 2000, when Custis resigned from Charm City Motors. Neither was prosecuted for their drug-related crimes until 2007. But whereas Custis pleaded guilty, accepted responsibility, and, in the words of his attorney William Purpura, "admitted his culpability and that of others," Campbell kept silent and went to trial. That trial, earlier this year, exposed another layer of criminality to the used-car business--one that could result in a lengthy prison sentence for Campbell.
Though state and local authorities could see an eyebrow-raising pattern of vehicle seizures involving Charm City customers, the company only came under federal scrutiny because of illegal drug transactions. Once the feds looked closer at the company's financial records, investigators also noticed that, from at least March 1999 to November 2003, Campbell was structuring bank transactions--that is, concealing assets by depositing amounts less than $10,000, the threshold for reporting cash transactions to the IRS. (Custis denies any involvement with the structuring offenses, though bank records show his name on at least one transaction, on March 27, 2001.)
Compared to money laundering, which is taking dirty money and running it through a business or bank to remove the taint of illegality, structuring is a more common crime that is committed as a means to conceal other illegal activity or to avoid tax consequences. (Former New York Gov. Eliot Spitzer was snagged in a prostitution sting earlier this year after bankers reported to the IRS that he was structuring financial transactions to conceal his withdrawal of large sums of cash.)
The critical mistake for Campbell is that, rather than spreading his deposits to various banks in increments below $10,000, he used five different branches of the same bank, which was easily detected by IRS investigators. A review of evidence from the trial shows that Campbell was depositing money in $8,000 and $9,000 increments that consisted of dozens of money orders usually in the amount of $500, purchased in the name of Campbell or one of his associates, and paid to Charm City Motors. Asked what kind of car dealer transacts business by money orders in such a manner, Campbell's lawyer John Hassett says, "I do not know the answer to that question. But he declared all of his income to the IRS."
Hassett declines to comment on whether Campbell simply was trying to avoid reporting vehicle transactions that shed light on his clientele. He has asked for a new trial and got an extension for Campbell's sentencing. A hearing date has been set for Aug. 6. He argues that if Custis got no time for his role in a drug conspiracy, the judge should not throw the book at Campbell. He finds it troubling that the top investigator for the IRS and convicted drug traffickers testified against his client as if the drug dealing was directly tied to the structuring. "It's fascinating when the [federal] government puts thugs on the stand, then brings in the guys with the suits and documents. It shows the power the government has when it puts someone in its sights."
Despite the various crimes and suspicious players and activity associated with Charm City Motors, it is the rare case of a used-car dealer getting caught. Yet the industry has a long history of ups and downs that raise questions about why the government has not committed more resources to policing it in a proactive manner.
In the early 1980s, when cocaine use was exploding in Baltimore and most major U.S. cities, the State's Attorney's Office was aggressively taking drug dealers' cars off the street, according to Rudy Drayton, who has been head of the office's asset forfeiture section for more than a decade. The city continues to be more active than other jurisdictions, he says, pointing to more than 400 vehicles seized each of the last two years, up from 300 in 2005. But the game has gotten more sophisticated, and state laws make it easier for drug dealers.
Whereas in the 1980s prosecutors could not help noticing that drug dealers were showing up at car dealerships with bags of money for their flashy cars, over time they deployed more subtle tactics. "It was always easy for drug dealers to use cars for money-laundering purposes," Drayton says. But in the old days, at least when authorities could see past a straw purchase, for instance, they could seize and forfeit a vehicle and slow down the drug traffickers, he says.
Around 1988, however, at the height of the drug war, Maryland amended its laws to allow lien holders to regain possession of a seized vehicle almost immediately, simply by filing an affidavit that the car loan was in default and they needed to repossess the car. The law also made it virtually impossible to invalidate a lien held by a car dealer who had sold a vehicle to a drug trafficker unless authorities could prove actual knowledge on the part of the car dealer that drug money was a part of the transaction. Likewise, straw purchasers could not be prosecuted without evidence of actual knowledge that their name went on a vehicle title to facilitate a drug dealer's activities. Known as the "innocent owner defense," the law allows drug dealers to exploit their friends, family, and so-called loved ones by not disclosing their purposes for obtaining a vehicle in someone else's name.
The law change was a boon for unscrupulous used-car dealers. MVA regulations allow a used-car dealer to issue loans on the premises without having to go through a third-party lender, which is why such dealers have signs that say bad credit no credit we finance and guaranteed credit approval. So once a car dealer gets paid cash and records a phony loan and a bogus lien, it's easy to swear out an affidavit saying the loan is in default after the car has been seized. According to Drayton, once the affidavit is submitted, the government has to give the car to the lien holder, "no ifs, ands, or buts."
Another feature of the lien scam is the purchase of cars at auctions in Maryland, Delaware, and Pennsylvania. When a customer comes to a used-car dealer and doesn't see what he or she wants on the lot, the car dealer can go to an auction to purchase the desired vehicle at a wholesale price, then sell the vehicle to the customer at a marked-up retail price. When the customer is a drug dealer with a large amount of disposable cash that he or she needs to conceal anyway, price is hardly the issue.
The auction dealers sell on consignment, so the used-car dealer can buy multiple vehicles on a line of credit, return to Baltimore, and sell a bunch of cars at a significant profit, for cash, then proceed with the fake loan/phony lien scam. With a 30-day time period to pay off the line of credit, the used-car dealer has cash earning interest in the bank and the ability to get the same car back and resell it in the future, in the event law enforcement breaks the revolving cycle of cars, cash, and drugs. Even then, the interruption in business is temporary.
"We see it happen all the time," says Drayton, who has processed more than 3,000 forfeitures in the last decade, but who says 95 percent of what he sees is the result of police just doing their jobs. Yet the city State's Attorney's Office--like the MVA and the Baltimore Police Department--cannot point to an investigative branch that targets patterns such as car dealers holding a large number of liens on late-model luxury cars and recording loans with exorbitant interest rates to customers with no reportable income. "Why would a small used-car dealership want to float all that paper?" Drayton asks.
Matters just got worse in November 2007: The Maryland Court of Special Appeals struck down the Baltimore State's Attorney's efforts to force lien holders to go before a judge to determine if their liens are valid. This further hampers prosecutors' efforts to pierce the veil of legitimacy. "We don't have the legal tools to go after this activity," Drayton says.
In response to City Paper's inquiries, Margaret Burns, a spokeswoman for Baltimore State's Attorney Patricia Jessamy, says the office intends to address a legislative solution in the near future. "There is substantial need for legislative action," Burns writes in an e-mail. Baltimore Police Commissioner Frederick Bealefeld would not confirm any similar intentions.
Overall, veteran law enforcers say, the legal and regulatory deck is stacked in favor of drug dealers who, with each arrest and seizure, get wiser to the limits of the law and flaws in the bureaucracy.
At the local level, where day-to-day observations of law enforcers can be most useful, police are frustrated by the shell game of finding documentation to prove a criminal conspiracy. "We can look into car dealers," a veteran Baltimore police officer says. "But when we get out there they might not have any records, or they might say their receipts are in a shoe box at their other store. We can't always review how people are paying for cars."
State regulators are similarly hamstrung. While the MVA can investigate shoddy record keeping of car dealers suspected of facilitating the drug trade, MVA authority is limited to compliance and administrative fines, which is no match for a criminal conspiracy.
In addition, Maryland's money-laundering statute is narrow in that it prevents authorities from going after money that criminals use for legal services. And limited resources are already an issue for state and local law enforcers. Thus, the most promising opportunities to broaden investigations go to the federal government. Asked about how the feds investigate drug-money laundering in the auto-sales business, a veteran assistant U.S. Attorney laughs and says: "Maybe you should ask the U.S. Attorney if he has ever thought about establishing a task force." A spokesperson for Maryland U.S. Attorney Rod Rosenstein says the office does not specifically target such activity. Rosenstein could not point to any such recent prosecutions other than Charm City Motors.
"It's ridiculous," is a common refrain from law enforcers at numerous agencies who were interviewed by City Paper about how Maryland law applies to used-car dealers. "We had a used-car lot that we knew was dirty," a veteran drug task force officer says. "But by the time we combed through the paperwork and dealt with all the people who had claims on the vehicles we had seized, we ended up with like five cars. It was a pain in the ass."
No one will ever be able to say for sure how sophisticated Charm City Motors was with its used-car business. The case against Custis and Campbell in federal court arose from routine dope investigations, while Campbell's structuring offenses were amateurish and easily detected, once authorities bothered to look. And though Charm City had liens on a number of seized cars, and allegedly employed the fake-lien ruse to reel those cars back in, it also abandoned those efforts when questioned.
But for every Charm City Motors, law enforcers can only suspect others who might be dirtier, a little more slick, and thus not likely to get caught. Plus, used cars are still a way for a regular business owner to make a buck. Not everyone deserves investigators crawling all over their lot because they are selling used cars to a low-income clientele.
Next door to Charm City Motors recently, the new tenant where Platinum Motors used to be, Deandre Wiggins has just opened his own business, Five Star Motors, after working for other companies for more than a decade. "I was wondering why I never met [Campbell]," Wiggins says, in response to questions about his absentee landlord and the seemingly defunct Charm City Motors. "But a lot of car dealers have folded because of the economy."
Wiggins says that, with the energy crunch, the business climate for used cars is not ideal, but he observes, "People buy cars because they need them, not because they want them." As far as car dealers go, he says, it's important to have your cars and financing in order, because otherwise, when tough times hit, you'll be in trouble. That is why he uses third-party lenders, he says, so he isn't floating loans to people who have poor credit and little income. The added benefit for Wiggins is he won't likely be a magnet for questionable customers. When asked if he's ever been approached by customers who want to pay in large sums of cash, or who are suggesting they act as investors so he can go to the car auction and bring back a number of flashy cars, he says, "If someone approaches me with some sort of investment proposal, I prefer to get the lawyers involved, and to get it in writing."
That's another good sign that Wiggins, and others like him, will not attract unwanted attention from law enforcers, either. Not that any such attention would lead to a focused or proactive enforcement effort, according to those who do the enforcing.
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