also SKS Constructors, Inc. v. Drinkwine, 458 F. Supp. 2d 68, 78
(E.D.N.Y. 2006) (when alleging use of the mail and wires, "the pleader need only allege
that the mail ... included allegations that defendants made misrepresentations by submitting annual
payroll statements certifying inaccurate information): SKS Constructors. 458 F. Supp. 2d at 76-78 (credit card charges and
checks
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01358951.pdf