United States v. Charles White, 737 F.3d 1121

White operated Eyes Have Not Seen (EHNS), a mortgage bailout program that induced distressed homeowners to transfer title to investors for a year, promising to pay their mortgage and allow buyback later.
Investors (straw purchasers) were financed via fraudulent mortgage applications prepared by White, inflating assets and falsely claiming intended owner-occupancy to obtain loans.
Ford, as Title Zone closing agent, prepared dual HUD-1s, concealed EHNS fees from lenders, accepted down payments from White, and forged or fabricated checks to trigger fund disbursement.
Helton, a real estate attorney, represented EHNS homeowners at closings, assured documents were in order, and later concealed the transactions in bankruptcy filings to obstruct creditors and trustees.
White, Ford, and Helton were charged in a multi-count superseding indictment with wire fraud; Helton also faced bankruptcy fraud charges; they were tried in 2010 and convicted on multiple counts, with White sentenced to 266 months, Helton to 180 months, and Ford to 48 months.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of Ford’s wire‑fraud conviction	Ford argues wire transfers occurred before her involvement, so she did not participate in a defrauding scheme.	Ford contends lack of causation/participation in the wire portion dispels liability.	Evidence supports Ford as an integral, foreseeable participant; conviction affirmed.
Sufficiency of Helton’s wire‑fraud conviction	Helton asserts lack of intent to defraud; he was merely an attorney present at closings.	Helton contends he did not knowingly participate or deceive lenders.	Jury could reasonably find intent to defraud; conviction affirmed.
Joinder and severance	Joinder of Helton with White and Ford should be severed due to prejudicial evidence about Helton’s bankruptcy fraud unrelated to wire fraud.	Joinder was improper and severance required to avoid prejudice.	Joinder upheld; no abuse of discretion in denying severance.
Helton Brady claim	Exculpatory bankruptcy-file documents were suppressed evidence.	Suppression denied; Brady violation occurred.	No Brady violation; evidence was not suppressed.
Admission and treatment of Government Exhibit 20908	Chart summarizes voluminous EHNS transactions to prove loss and pattern of fraud.	Chart is improper Rule 1006 evidence or unduly prejudicial.	Chart properly admitted under Rule 1006 with appropriate limiting instructions; not reversible error.

Schmuck v. United States, 489 U.S. 705 (U.S. 1989) (wire‑fraud elements; step in the plot not endpoint)
Pereira v. United States, 347 U.S. 1 (U.S. 1954) (foreseeable use of wires in fraud schemes)
Powell, 576 F.3d 482 (7th Cir. 2009) (no requirement that defendant cause wire; intent to defraud can be inferred)
Turner, 551 F.3d 657 (7th Cir. 2008) (wire transfers foreseeability in scheme to defraud)
Gimbel, 830 F.2d 621 (7th Cir. 1987) (courts may apply logic from mail fraud to wire fraud)
Janati, 374 F.3d 263 (4th Cir. 2004) (distinguishes Rule 1006 vs. Rule 611 summaries; pedagogy vs. substantive evidence)
Milkiewicz, 470 F.3d 390 (1st Cir. 2006) (distinction between Rule 1006 and Rule 611 summaries; accuracy requirement)
Johns, 686 F.3d 438 (7th Cir. 2012) (vulnerable victim analysis in mortgage bailout context)
Acosta, 85 F.3d 275 (7th Cir. 1996) (relevance of conduct findings; implicit vs explicit findings)
Wilson, 502 F.3d 718 (7th Cir. 2007) (unanimity requirement in multiple‑schemes instructions)
Mansoori, 304 F.3d 635 (7th Cir. 2002) (acceptable multiple‑schemes instruction in fraud cases)
Davis, 471 F.3d 783 (7th Cir. 2006) (variance and subset of indictment in fraud cases)
Leiskunas, 656 F.3d 732 (7th Cir. 2011) (loss amount calculation review; need for explicit findings)