The extent of Couri's alleged criminal actions through Plazagal and the fraudulent dealings with the Manufacturers and Traders Trust Company were a tangled web, but [Assistant United States Attorney] Livingston described them in some detail in his letter.

"Certain employees at Plazagal provided information that Couri changed some company financial records in order to inflate the sales figures. One employee was asked to inflate the recorded sales figures by treating unsold items as if they had been sold. Other employees were instructed to create false invoices to correspond with the inflated sales figures. These false sales figures were then incorporated into the monthly accounts receivable reports forwarded to the Manufacturers and Traders Trust Company, whose outstanding loan of $1.8 million to Plazagal had been personally guaranteed by Couri, Livingston's letter stated 'the aggregate overstatement of sales was approximately $600,000,' a figure later reduced to something between 300,000 and 400,000.

In addition the US attorney's office was informed that 'figures for inventory of Plazagal [the shortened term of Plazagal which Livingston uses throughout his letter], which were from time to time submitted to MMT bank were greatly in excess of the actual inventory on hand at Plazagal. The letter went on to describe a number of Plazagal checks issued on overdrawn accounts, check 'kiting' between Plazagal and other Couri owned companies, use of Plazagal's funds by Couri to purchase speculative securities, Couri's warnings and threats to employees about talking to outsiders about Plazagal's operations or its financial status, etc. And finally, Livingston concludes in his letter: "there is information that after the MMT bank began its litigation against Plazagal [which the bank was suing so as to collect on the defaulted loan], Couri took a portion of certain payments received by Plazagal for certain sales, after directing the employees to enter the receipt of the cash on the books of Plaza and to enter the expenditure of the cash as payments to other companies controlled by Couri. Also since the bank began its lawsuit several checks were issued by Plazagal paying for personal expenses of Mr. Couri, including checks to his attorneys in the aggregate amount of approximately 80,000 to 100,000" — Boy Wonder of Wall Street - The Life and Times of Financier Eddie Gilbert, by Richard Whittingham, 2004, Texare, pages 348-349.