United States v. ISAAC BRIGGS III; and DERRICK HODGE, Southern District of New York (Nov. 9, 2023) — Complaint

AUSA: William C. Kinder 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
v. 
ISAAC BRIGGS III and 
DERRICK HODGE, 
Defendants. 
      SEALED COMPLAINT 
      Violations of 18 U.S.C. §§ 1343, 1349, 
      1956(h), 1028A, and 2. 
      COUNTY OF OFFENSE: 
      NEW YORK 
SOUTHERN DISTRICT OF NEW YORK, ss.: 
DANIEL ONOVE II, being duly sworn, deposes and says that he is a Special Agent with 
the Federal Bureau of Investigation (“FBI”),  and charges as follows: 
COUNT ONE 
(Conspiracy to Commit Wire Fraud) 
1.From at least in or about August 2020 through at least in or about November 2023,
in the Southern District of New York and elsewhere, DERRICK HODGE and ISAAC BRIGGS 
III, the defendants, and others known and unknown, willfully and knowingly combined, conspired, 
confederated, and agreed together and with each other to commit wire fraud, in violation of Title 
18, United States Code, Section 1343. 
2.It was a part and an object of the conspiracy that DERRICK HODGE and ISAAC
BRIGGS  III,  the  defendants,  and  others  known  and  unknown,  knowingly  having  devised  and 
intending  to  devise  a  scheme  and  artifice  to  defraud,  and  for  obtaining  money  and  property  by 
means  of  false  and  fraudulent  pretenses,  representations,  and  promises,  would  and  did  transmit 
and cause to be transmitted by means of wire, radio, and television communication in interstate 
and foreign commerce, writings, signs, signals, pictures, and sounds for the purpose of executing 
such  scheme  and  artifice,  in  violation  of  Title  18,  United  States  Code,  Section  1343,  to  wit, 
HODGE  and  BRIGGS  III agreed  to  make  and  caused  to  be  made false  statements to victim 
investors to fraudulently obtain investor  funds, and  in  connection  therewith  and  in  furtherance 
thereof,  HODGE  and  BRIGGS  III  transmitted  and  caused  to  be  transmitted  interstate  emails, 
telephone calls, wire transfers of funds, and other electronic communications. 
(Title 18, United States Code, Section 1349.) 
COUNT TWO 
(Wire Fraud) 
3.From at least in or about August 2020 through at least in or about November 2023,
in the Southern District of New York and elsewhere, DERRICK HODGE and ISAAC BRIGGS 
III,  the  defendants,  knowingly  having  devised  and  intending  to  devise  a  scheme  and  artifice  to 
23 MAG 7107

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defraud,  and  for  obtaining  money  and  property  by  means  of  false  and  fraudulent  pretenses, 
representations, and promises, transmitted and caused to be transmitted by means of wire, radio, 
and  television  communication  in  interstate  and  foreign  commerce,  writings,  signs,  signals, 
pictures,  and  sounds,  for  the  purpose  of  executing  such  scheme  and  artifice,  which  affected  a 
financial institution, to wit, HODGE and BRIGGS III engaged in a scheme to make and caused to 
be  made false  statements to victim  investors to fraudulently obtain investor  funds, and  in 
connection therewith and in furtherance thereof, HODGE and BRIGGS III transmitted and caused 
to  be  transmitted  interstate  emails,  telephone  calls,  wire  transfers  of  funds,  and  other  electronic 
communications. 
 
(Title 18, United States Code, Sections 1343 and 2.) 
 
COUNT THREE 
(Conspiracy to Commit Money Laundering) 
 
4. From at least in or about August 2020 through at least in or about November 2023, 
in the Southern District of New York and elsewhere, DERRICK HODGE and ISAAC BRIGGS 
III, the defendants, and others known and unknown, willfully and knowingly combined, conspired, 
confederated, and agreed together and with each other to commit money laundering, in violation 
of Title 18, United States Code, Sections 1956(a)(1)(B)(i), and to engage in monetary transactions 
in property derived from specified unlawful activity, in violation of United States Code, Section 
1957.   
 
5. It was a part and an object of the conspiracy that DERRICK HODGE and ISAAC 
BRIGGS III, the defendants, and others known and unknown, knowing that the property involved 
in a financial transaction represented the proceeds of some form of unlawful activity, would and 
did  conduct  and  attempt  to  conduct  such  a  financial  transaction,  which  transaction  affected 
interstate and foreign commerce and involved the use of a financial institution which was engaged 
in, and the activities of which affected, interstate and foreign commerce, and which in fact involved 
the proceeds of specified unlawful activity, to wit, the wire fraud violation charged in Count Two 
of this Complaint, knowing that the transaction was designed in whole and in part to conceal and 
disguise  the  nature,  the  location,  the  source,  the  ownership,  and  the  control  of  the  proceeds  of 
specified unlawful activity, in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i).  
 
6. It was further a part and an object of the conspiracy that DERRICK HODGE and 
ISAAC BRIGGS III, the defendants, and others known and unknown, within the United States, 
would and did knowingly engage and attempt to engage in a monetary transaction, as defined in 
Title 18, United States Code, Section 1957(f)(1), in criminally derived property of a value greater 
than  $10,000  that  was  derived  from  specified  unlawful  activity,  to wit,  the  wire  fraud violation 
charged in  Count  Two  of  this  Complaint, in violation  of  Title  18,  United  States  Code,  Section 
1957(a). 
 
(Title 18, United States Code, Section 1956(h)) 
 

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COUNT FOUR 
(Aggravated Identity Theft) 
7.From at least in or about October 2020 through at least in or about November 2023,
in  the  Southern  District  of  New  York  and  elsewhere, ISAAC  BRIGGS  III,  the  defendant, 
knowingly transferred, possessed, and used, without lawful authority, a means of identification of 
another person, during and in relation to a felony violation enumerated in Title 18, United States 
Code,  Section  1028A(c),  to  wit, BRIGGS  III used  and  transferred  the  name,  date  of  birth,  and 
driver license number of another person during and in relation to the conspiracy to commit wire 
fraud and wire fraud violations charged in Counts One and Two of this Complaint. 
(Title 18, United States Code, Sections 1028A(a)(1), 1028A(b), and 2.) 
The bases for my knowledge and for the foregoing charges are, in part, as follows: 
8.I  am  a  Special  Agent  with  the  FBI.   I  have  been  personally  involved  in  the
investigation  of  this  matter,  and  I  base  this  affidavit  on  that  experience,  on  my  examination  of 
various  reports  and  records,  and  on  my  conversations  with  witnesses.    Because  this  affidavit  is 
being submitted for the limited purpose of demonstrating probable cause, it does not include all 
the facts I have learned during the course of my investigation.  Where the contents of documents 
and the actions, statements, and conversations of others are reported herein, they are reported in 
substance and in part, except where otherwise indicated. 
9.Based on my participation in this investigation, my conversations with witnesses
and  victims,  law  enforcement  records,  bank  records,  investment  documents,  and  other  records 
obtained  during  this  investigation,  I  have  learned  the  following  about  an  investor  fraud  scheme 
perpetrated by DERRICK HODGE and ISAAC BRIGGS III, the defendants.    
Heritage Integrity Investment Trust 
10.Based on my review of records from the Montana Secretary of State, I know that
Heritage Integrity Investment Trust (“HIIT”) is a domestic business trust organized under the laws 
of Montana.  HIIT was registered with the Montana Secretary of State on or about June 20, 2017 
and was assigned corporation number D1047652.   
11.Montana state records indicate that “Derrick Hodge” and “Isaac Briggs” are HIIT’s
directors.  Montana Secretary of State records further indicate that HIIT’s principal address is 295 
Madison  Avenue,  12th  Floor,  New  York,  New  York,  10017;  its  mailing  address  is  2227  US-1, 
229, North Brunswick, New Jersey, 08902.   
HIIT Opens a Brokerage Account to Receive Investor Funds 
12.Based  on  my  review  of  bank  records,  I  know  that  in  or  about  October  2020,  an
individual  identifying  himself  as  “Isaac  Briggs,  Jr.”  contacted  a  particular  brokerage  firm 
(“Brokerage Firm-1”) by  telephone to  set  up  a  brokerage  account  in  the  name  of  HIIT,  for  the 
purpose  of  trading  certain  financial  instruments,  including  bonds,  options,  stocks,  and  margin.  
Brokerage Firm-1 opened the account (the “HIIT Brokerage Account”). 

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a.HIIT Brokerage Account records identify “Isaac Briggs Jr.” and DERRICK
HODGE, the defendant, as managing trustees of HIIT.  
b.HIIT Brokerage Account documents identify “Phoenix Global Investments,
LLC” as a beneficiary of the account.  Based on my review of bank records, I have learned that 
HODGE is an officer of Phoenix Global Investments. 
c.HIIT  Brokerage  Account  documents  identify ISAAC  BRIGGS  III,  the
defendant, as a “trusted contact” associated with the account.  
d.Based  on interviews  with  witnesses  and my  review  of  bank  records,
including  call  recordings  and  documents,  I  know  that Brokerage  Firm-1  opened  the  HIIT 
Brokerage  Account  after  the  individual  identifying  himself  as  “Isaac  Briggs,  Jr.”  submitted 
application materials, including a New Jersey driver’s license for “Isaac Briggs, Jr.”  However, as 
described further below, I believe that the individual who contacted Brokerage Firm-1 to open the 
HIIT Brokerage Account was not Isaac Briggs Jr., but instead his son, ISAAC BRIGGS III, the 
defendant. 
HIIT Receives Investor Funds 
13.Based  on  my  review  of  bank  records,  I  know  that  soon  after opening the  HIIT
Brokerage Account at Brokerage Firm-1,HIIT began to receive investor funds from the victims of 
the  HIIT  fraud  scheme.   To  complete  their investments,  HIIT  investors wired their investment 
funds to an account managed by Brokerage Firm-1 located in New York, New York, which were 
then pooled into the HIIT Brokerage Account. 
a.On or about October 23, 2020, the HIIT Brokerage Account received a wire
payment of approximately $1,000,000 from an investor (“Victim-1”). 
b.On or about October 26, 2020, the HIIT Brokerage Account received a wire
payment of approximately $1,000,000 from a second investor (“Victim-2”). 
c.On or about October 26, 2020, the HIIT Brokerage Account received a wire
payment of approximately $1,100,000 from a third investor (“Victim-3”). 
d.In  or  about  December  2020,  the  HIIT  Brokerage  Account  received  wire
payments totaling approximately $999,669 from a fourth investor (“Victim-4”). 
14.Based  on  my  review  of  bank  records,  I  have  learned  that  from  approximately
November  2020  to  January  2021,  additional  victims  of  the  HIIT  investor  fraud  scheme  wired 
investment funds to a different account—a business bank account controlled by HIIT (“HIIT Bank 
Account-1”)—and that those funds were then transferred to the HIIT Brokerage Account.   
a.On  or  about  August  14,  2020,  HIIT  Bank  Account-1  was  opened  at  a
particular  financial  institution  (“Bank-1”).    The  signatories  for  HIIT  Bank  Account-1  were 
“Tyshun N Gourdine” and ISAAC BRIGGS III, the defendant. 

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b. On  or  about  November  17,  2020,  HIIT  Bank  Account-1  received  a  wire 
payment of approximately $950,000 from a fifth investor (“Victim-5”).   
 
c. On  or  about  January  12,  2021,  HIIT  Bank  Account-1  received  a  wire 
payment of approximately $1,000,000 from a sixth investor (“Victim-6”). 
 
d. On  or  about  January  19,  2021,  HIIT  Bank  Account-1  received  a  wire 
payment of approximately $1,000,000 from a seventh investor (“Victim-7”). 
 
e. Between   approximately   November   18,   2020   and   January   22,   2021, 
approximately  $2,915,000  was  transferred  from  HIIT  Bank  Account-1  to  the  HIIT  Brokerage 
Account, constituting the approximate amount of funds invested with HIIT by Victim-5, Victim-
6, and Victim-7. 
 
15. Based on my review of bank records, I have learned that a total of approximately 
$7 million was invested with HIIT by its victims.  No funds other than the investments of Victim-
1,  Victim-2,  Victim-3, Victim-4,  Victim-5,  Victim-6,  and  Victim-7  were  used  to  fund  the  HIIT 
Brokerage Account. 
 
HIIT Made False Promises to Induce its Victims’ Investments 
 
16. Based on interviews of victims and witnesses and my review of documents obtained 
in this investigation, I have learned that the victims of the HIIT investor fraud scheme invested in 
HIIT  after  individuals  associated  with  HIIT,  including ISAAC BRIGGS  III  and DERRICK 
HODGE, the defendants, made various misrepresentations about HIIT’s trading program and its 
use of investor funds.  For example: 
 
a. Victim-2   invested   $1   million   with   HIIT   for   what   he was   told   by 
representatives of HIIT, including HODGE and BRIGGS III, was a “small cap” private placement 
trade  program  designed  to  buy  and  resell  mortgages  to  banks  for  a  profit.    Victim-2  made  the 
investment to provide financial security for his children, two of whom have significant disabilities.  
Representatives of HIIT, including HODGE and BRIGGS III, communicated with Victim-2 about 
the investment by telephone and email.   
 
i. In late 2020, after making his $1 million investment, Victim-2 was 
told by BRIGGS III that HIIT could not participate in the small cap trading program because it 
had  fallen  short  of  its  funding  goal.    Victim-2 knew BRIGGS III to go by the first name “Eli.”  
BRIGGS  III  indicated  to  Victim-2  that  HIIT might be  able to  begin  participating in  the  trading 
program by early 2021.   
 
ii. Victim-2  demanded  the  return  of  his  investment  in  or  about 
February  2021,  when  HIIT  had  still  not  begun  the  trading  program.    In  or  about  June  2021, 
BRIGGS III assured Victim-2 that his money would be returned.   
 
iii. In or about February 2022, HODGE returned $300,000 to Victim-2 
by wire payment, representing a portion of his $1 million investment.  HIIT has not returned the 
remainder  of  Victim-2’s investment, nor made any disbursements to Victim-2  of  investment 
profits. 

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b. Victim-5   invested   $950,000   with   HIIT   for   what   he   was   told by 
representatives  of  HIIT,  including  HODGE  and  BRIGGS  III, was a “small cap program” that 
would last 40 weeks and provide a return of five times the initial investment.  Representatives of 
HIIT, including HODGE and BRIGGS III, communicated with Victim-5 by telephone, email, and 
text message.   
 
i. Victim-5  understood  that  HODGE  and  BRIGGS  III  were  the 
facilitators of the small cap program.  Victim-5 knew BRIGGS III to go by the first name “Eli.”  
HODGE and BRIGGS III promised Victim-5 that the first investor payment would be made four 
weeks after Victim-5 made the initial investment, but no such payment was made to Victim-5.   
 
ii. From  late  2020  through  2021,  in  response  to  Victim-5’s inquiries 
about  the  status  of  his  investment  and  the  HIIT  trading  program,  HODGE  and  BRIGGS  III 
repeatedly told Victim-5 that the commencement of the small cap trading program was delayed 
due to various external factors.   
 
iii. In  or  about  July  2021,  Victim-5  demanded  the  return  of  his 
investment.    In  or  about  January  2022,  HODGE  returned  approximately  $20,035  of  Victim-5’s 
investment,  in  a wire payment from  an  account controlled  by Phoenix  Global  Investments (the 
“Phoenix Bank Account”) at a particular financial institution (“Bank-2”).  HIIT has not returned 
the remainder of Victim-5’s investment, nor made any disbursements to Victim-5 of investment 
profits.   
 
c. Victim-6  invested  $1  million  with  HIIT  after  HIIT  represented  that  its 
investment program would provide participants with a guaranteed rate of return of 100%.   
 
i. Victim-6 understood that HIIT would use investor funds in a “small 
cap” trading program with multiple stages.  First, HIIT would pool investor funds for ten days to 
generate  profits.    After  the  initial  ten-day  period,  HIIT  would  return  each  investor’s  initial 
investment.  Next, the profits generated in the ten-day period would be used for a 40-week trading 
program to generate additional profits, which would be distributed to investors.  
 
ii. By mid-February 2021, well over ten business days after Victim-6 
had made its investment, HIIT had still not returned Victim-6’s initial investment.  On or about 
February 15, 2021, Victim-6 demanded the return of its initial investment.  On or about March 15, 
2021, HIIT informed Victim-6 that it could not return the investment because Brokerage Firm-1 
would not release the funds.   
 
iii. On or about June 29, 2021, Victim-6 filed a lawsuit against HIIT, 
alleging  that  HIIT  had  fraudulently  misused  Victim-6’s investment funds.  As a result of the 
lawsuit,  HIIT  agreed  to  return  the  investments  of  Victim-1,  Victim-3,  Victim-4,  Victim-6,  and 
Victim-7.  The lawsuit did not result in the return of investments to Victim-2 or Victim-5.   
 
17. Statements  in  the  HIIT  investment  contract  documents  are  consistent  with  the 
victim  accounts  of  promises  made  by  HIIT, DERRICK HODGE,  and ISAAC BRIGGS  III,  the 
defendants.    For  example,  an  investment  contract  document dated  July  24,  2020  and titled 
“Unanimous  Memorandum  of  Understanding  Joint  Participation,  Project  Funding  &  Asset 

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Management Agreement,” entered into by Victim-2 and HODGE (on behalf of HIIT), made the 
following representations: 
a.The  purpose  of  Victim-2’s $1 million investment was for it to be pooled
with other investor funds “to create profits for the benefit of the [investors] through certain trading 
transactions  to  include  buying  and  selling Debenture  Instruments,  Medium  Term  Notes,  Bank 
Guarantees, and similar financial obligations.” 
b.The investment program would commence with a “10 banking day bullet”
period, after which “LTV times $1,000,000 . . . times five (5) times leverage bullet equals gross 
proceeds  {gp},  that  will  be  held  for  the  benefit  of  [Victim-2] and rolled into” the investment 
program’s second phase.  In the second phase, Victim-2’s “gross proceeds” would be “placed in 
40-week  trade  program  that  will  have  the  initial  amount  from [Victim-2’s investment] plus the
amount  from  [the  10-day bullet period], known as the net proceeds {np}.”  The second phase
would result in “100% yield of (np) per week gross before deductions . . . to be disbursed after
each active week of the program.”
c.HIIT “will not, for any reason, invade, deplete, move or transfer any of the
funds” invested by Victim-2 with HIIT. 
d.HIIT will “[r]elease” Victim-2’s $1 million investment back to Victim-2
“without any liens and encumbrances after 12 (twelve) month term is complete.” 
18.Investors were also asked to execute an additional investment contract document
titled a “Pledge Agreement.”  A Pledge Agreement dated September 30, 2020 and entered into by 
Victim-5 and DERRICK HODGE, the defendant (on behalf of HIIT), stated that HIIT “agreed to 
utilize”  Victim-5’s  investment  funds  (the  “Pledged  Collateral”)  for  “commercial  activity 
transactions”; that Victim-5’s “Pledged Collateral secures commercial activity transactions of 
[HIIT]”; and that the Pledge Agreement would terminate “[u]pon [p]ayment in [f]ull to [Victim-
5],” at which point HIIT “shall return” Victim-5’s investment funds to Victim-5. 
19.Similar representations were made in HIIT’s investment contract documents with
other victims. 
BRIGGS III Impersonated His Father to Open the HIIT Brokerage Account 
20.For the following reasons, I believe that the individual who contacted Brokerage
Firm-1 to open the HIIT Brokerage Account was not Isaac Briggs Jr., but instead his son, ISAAC 
BRIGGS III, the defendant: 
a.Based  on  my review  of  bank and  phone records,  I  know  that  the  phone
number used by the individual who identified himself as “Isaac Briggs Jr.” in his communications 
with Brokerage Firm-1 was subscribed to in the name of “Isaac Briggs.”  Phone records indicate 
that the same phone number (the “Briggs Number”) is associated with a New York limited liability 
company named PrimeSource Equity Solutions, LLC.  Corporate records for PrimeSource Equity 
Solutions, in turn, indicate that the entity’s sole officer is “Eli Briggs III.”   

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b. Multiple victims of the HIIT fraud scheme identified “Eli Briggs” as their 
primary point of contact at HIIT.  Based on the records described above identifying “Eli Briggs 
III” as the user of the Briggs Number, I believe that BRIGGS III goes by the alias “Eli” and that 
BRIGGS III was, in fact, the primary point of contact for the HIIT fraud victims.   
 
c. Law  enforcement  databases  indicate  that the  Briggs  Number is  a  phone 
number for ISAAC BRIGGS III. 
 
d. As  described  in  further  detail below,  “Isaac  Briggs III”  is  listed  as  a 
signatory  on two bank  accounts—identified herein as  HIIT Bank Account-1 and a  second  bank 
account in the name of and controlled by HIIT (“HIIT Bank Account-2”)—which received investor 
funds from the HIIT Brokerage Account.  Based on my review of bank records, and as described 
further  below,  I  know  that  those  funds  were  ultimately  disbursed  for  personal  expenses  of 
DERRICK HODGE, and BRIGGS III, the defendants.   
 
e. In addition to identifying “Isaac Briggs III” as the signatory, records from 
HIIT  Bank  Account-1  identify the  Briggs  Number—the  same  phone  used  to  contact  Brokerage 
Firm-1 to set up the HIIT Brokerage Account—as the account contact number. 
 
f. Based  on  my  review  of  criminal  history  records,  I  know  that  on  or  about 
June  10,  2004,  BRIGGS  III  pleaded  guilty  in  New  Jersey  state  court  for  his  participation  in  a 
money laundering offense, in violation of New Jersey Stat. Ann. § 2C:2-6 (liability for the conduct 
of another), a crime for which he was sentenced to ten years’ imprisonment.  Based on my training 
and experience, I know that brokerage firms like Brokerage Firm-1 conduct Know Your Customer 
(“KYC”) due diligence and typically do not permit convicted felons to open brokerage accounts 
where they would manage funds on behalf of investors.  For this reason, I believe that BRIGGS 
III had an incentive to use the identity of his father, Isaac Briggs Jr., to set up the HIIT Brokerage 
Account and communicate with Brokerage Firm-1. 
 
BRIGGS III and HODGE Misappropriated Victim Investments for Personal Use 
 
21. Based on my review of bank records and interviews with witnesses associated with 
Brokerage Firm-1, I have learned that HIIT, ISAAC BRIGGS III, and DERRICK HODGE, the 
defendants, did not fulfill their promises to investors.  Instead, they failed to conduct any trading 
of investor funds, used investor funds for personal expenses, and depleted the investor funds in the 
HIIT Brokerage Account, contrary to investment contracts into which they entered with investors 
and statements they made to investors. 
 
22. Based  on  interviews  with  witnesses  associated  with  Brokerage  Firm-1,  I  have 
learned that Brokerage  Firm-1 maintains a  policy that its brokerage  accounts cannot  be  used  as 
deposit-only accounts; they must be used for purposes of trading.  Shortly after the HIIT Brokerage 
Account  was  opened,  it  was  flagged  for  review  by  Brokerage  Firm-1  due  to  a lack  of  trading 
activity.  On or about November 4, 2020, and again on or about July 7, 2022, Brokerage Firm-1 
warned HIIT that it must commence trading activity.  Despite these warnings, HIIT did not start 
trading.    As  of  about  September  25,  2023,  no  trading  activity  had  ever  occurred  in  the  HIIT 
Brokerage Account.  
 

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23.Based  on  my  review  of  bank  records,  I  have  learned  that  instead  of  engaging  in
trading activity to generate profits for the benefit of investors, ISAAC BRIGGS III and DERRICK 
HODGE misappropriated investor funds from the HIIT Brokerage Account by transferring such 
funds through intermediary accounts to the Phoenix Bank Account, and then disbursing hundreds 
of thousands of dollars from the Phoenix Bank Account to themselves.  The bank records obtained 
in the course of this investigation show that: 
a.From   approximately   November   5,   2020   through   July   19,   2021,
approximately  $410,250 in investor funds from the  HIIT  Brokerage Account  was transferred to 
HIIT  Bank  Account-1.    Then,  from  approximately  November  18,  2020  through  July  21,  2021, 
approximately $302,000 was transferred from HIIT Bank Account-1 to the Phoenix Bank Account.  
b.From   approximately   December   8,   2021   through   July   27,   2023,
approximately $1,379,700 in investor funds from the HIIT Brokerage Account was transferred to 
HIIT  Bank  Account-2  at  a  particular  financial  institution  (“Bank-3”).    From  approximately 
December 9, 2021 through July 19, 2022, approximately $1,163,000, was transferred from HIIT 
Bank Account-2 to the Phoenix Bank Account.  
c.From  approximately  November  18,  2020  through  December  30,  2022,
hundreds  of  thousands  of  dollars  were  disbursed  from  the  Phoenix  Bank  Account  for  personal 
expenses of HODGE and BRIGGS III, including direct payments to their personal accounts, and 
payments used for travel, entertainment, food, and other expenses.  The flow of funds reflected in 
bank  records  obtained  during  this  investigation  shows that  the  disbursements  made  from  the 
Phoenix Bank Account for the personal expenses of HODGE and BRIGGS III were HIIT investor 
funds. 
i.On or about January 28, 2021, a transfer of approximately $200,000
of investor funds was made from the HIIT Brokerage Account to HIIT Bank Account-1.  The next 
day,  on  or  about  January  29,  2021,  a  transfer  of approximately  $195,000  was  made  from  HIIT 
Bank  Account-1  to  the  Phoenix  Bank  Account.    Three  days  after  that,  on  or  about  February  1, 
2021, a transfer of approximately $95,000 was made to a personal bank account of BRIGGS III.  
Just over two weeks later, BRIGGS III made a $20,000 purchase at a particular car dealership in 
New Jersey. 
ii.In  the  days  and  weeks  following  the  transfer  of  approximately
$195,000  from  HIIT  Bank  Account-1  to  the  Phoenix  Bank  Account,  other  disbursements  were 
made  from  the  Phoenix  Bank  Account  for  personal  expenses,  including  transfers  totaling 
approximately $12,257 to a personal account of HODGE, approximately $26,016 in payments on 
peer-to-peer  transaction  platforms  such  as  Cash  App,  Venmo,  and  PayPal,  and  approximately 
$13,796 in payments for retail purchases.  For example, on February 7, 2022, just over one week 
after  the  transfer  of  $195,000  to  the  Phoenix  Bank  Account  from  HIIT  Bank  Account-1,  the 
Phoenix  Bank  Account  was  used  to  make  a  $2,557.30  purchase  from  the  Gucci  luxury  fashion 
company.  
iii.On or about July 13, 2022, a transfer of approximately $600,000 of
investor funds was made from the HIIT Brokerage Account to HIIT Bank Account-2.  Two days 
later, on or about July 15, 2022, a transfer of approximately $500,000 was made from HIIT Bank 
Account-2 to the Phoenix Bank Account.  In the days and weeks that followed, nearly $300,000 

10 
 
of  disbursements  were  made  from  the  Phoenix  Bank  Account  for  personal  expenses.    These 
disbursements  included  payments  of  approximately  $60,155  for  entertainment  purchases,  and 
checks totaling approximately $122,500 written out to HODGE. 
 
iv. Based  on my review of bank  records,  I  know that  as of July 2023 
the HIIT Brokerage Account, which was funded entirely with investor funds, had been completely 
depleted.  Approximately $5,225,000 was returned to Victim-1, Victim-3, Victim-4, Victim-6, and 
Victim-7 from  the  HIIT  Brokerage Account  as  part  of  the  settlement  of the  lawsuit initiated  by 
Victim-6.  Separately, as described above, HODGE returned approximately $20,035 to Victim-5 
and  approximately  $300,000  to  Victim-2.    Approximately $1,504,634  of  investor  funds—
representing the unreturned investments of Victim-2 and Victim-5—has been misappropriated by 
HODGE and BRIGGS III. 
 
BRIGGS III and HODGE Continued to Make False Statements to Conceal Their Fraud 
 
24. Based  on  my  review  of  bank  records  and  public  records,  I  know  that ISAAC 
BRIGGS  III  and DERRICK HODGE,  the  defendants,  have  continued  to  make  false  statements 
regarding their trading program and use of investor funds, even after complaints by HIIT’s victims. 
 
a. On or about November 17, 2022, Victim-5 filed a lawsuit in the Supreme 
Court  for  the  State  of  New  York  against  HIIT,  HODGE,  BRIGGS  III,  and  others,  seeking  the 
return of his investment.  The lawsuit remains pending. 
 
b. In connection with that lawsuit, HODGE and BRIGGS III submitted sworn 
affidavits containing false statements about their use of investor funds.  For example: 
 
i. On or about March 28, 2023, BRIGGS III stated in an affidavit that 
HIIT  had  “invested  [Victim-5’s]  money  in  Ruwack  2016  zero  coupon  bonds,”  which  were 
mistakenly restricted from trading, and that HIIT was attempting to “lift the restriction” so that it 
could  begin  its  trading  program.    Similarly, on  or  about  March  28,  2023,  HODGE  stated  in  an 
affidavit that HIIT “invested [Victim-5’s] funds in Ruwack 2016 zero coupon bonds.” 
 
ii. On  or  about  June  6,  2023,  BRIGGS  III  stated  in  an  affidavit  that 
“[a]ll $7 million of HIIT’s capitalization was invested, in November 2020, in Ruwack zero coupon 
bonds,” which HIIT still intends to trade; that those bonds have “a face value of $11 million, with 
a maturity date of March 2026”; and that HIIT “purchased an insurance wrap” for those bonds, 
“so that the $11 million payout is absolutely guaranteed.”  BRIGGS III further stated that “[w]e 
have not diverted any funds into our own pockets.” 
 
iii. Based on my review of bank records, I know that these statements 
by  BRIGGS  III and  HODGE are  false.    The  bank  records  obtained  in  the  course  of  this 
investigation show that HIIT made no payments using investor money for Ruwack zero coupon 
bonds or an insurance policy for those bonds; to the contrary, as described above, the bank records 
show that BRIGGS III  and  HODGE returned approximately $5,225,000 to  five  of  their victims 
and that they misappropriated the remaining investor funds, including the funds of Victim-5, for 
personal use.   
 
 

11 
WHEREFORE, I respectfully request that a warrant be issued for the arrests of DERRICK 
HODGE and  ISAAC BRIGGS III, the  defendants, and that they be arrested, and  imprisoned  or 
bailed, as the case may be. 
______________________________ 
Daniel Onove II 
Special Agent 
Federal Bureau of Investigation 
Sworn to me through the transmission of  
this Complaint by reliable electronic  
means (telephone), this 
6th day of November, 2023. 
___________________________________ 
THE HONORABLE SARAH L. CAVE
United States Magistrate Judge 
Southern District of New York 
/s Daniel Onove II (By Court with Authorization)