May caused fraudulent "private offering memorandums," "subscription agreements," and "investment recaps" for the LLCs to be drafted and distributed to potential investors. The offering memorandums fraudulently stated that E-M Management Co. had entered into agreements with various hotel corporations, including Hilton Hotels, Sheraton Hotels, Hyatt Hotels, and MGM Grand Hotels, to "provide all of the telecommunication services to the hotel properties" and to "install new equipment where needed, to purchase existing equipment where practicable and to cut over the services from present providers," and fraudulently promised investors that the funds raised "will be used solely for the purpose of purchasing telephone, high speed internet, low speed internet, [and] DVD equipment." The offering memorandums "guaranteed a minimum monthly income" to each investment LLC.
Read more:
