On Feb. 7, 2012, just over a year after Hotton filed for bankruptcy protection in federal court on Long island, the "Rebecca" partnership made an agreement with TM Consulting, a company he controlled, said the complaint. He'd raise money for the show for a fee of $7,500, plus 8 percent of any funds over $250,000, according to the complaint.

The producers paid Hotton the $7,500 plus "expense reimbursements," according to the complaint, amounting to about $18,000 in March and April.

He wrote in e-mails to the producers that he was successful.

"I have soft circles on $3.18 million," he wrote in one cryptic e-mail cited in the complaint.

On about March 5, Producer-1 e-mailed Hotton to say that he was meeting with a large investor who'd committed the Broadhurst and that he needed "everything with me regarding the capitalization target" at the meeting. That was likely to have been the top executives of Shubert.

Unnamed Producer

That month, Hotton provided the unnamed producer with signed agreements from four investors to buy stakes in "Rebecca," according to the complaint. They were "Paul Abrams," "Roger Thomas," "Julian Spencer" and "Walter Timmons." In April, Hotton sent Producer-1 a list of e-mail contact details for them, which contradicted contact information for them supplied weeks before, the complaint said.

Prosecutors said that Web sites associated with the investors Hotton supplied were almost identical to one another and featured photographs of the same office building, albeit from different angles. Both were created through web.com within the past year and registered by Hotton, according to the complaint.

In late April, Hotton demanded an advance against his 8 percent commission reflecting costs for treating "Abrams" to a safari, the complaint said. It was then that Producer-1 sent an e-mail address he had for "Abrams" introducing himself and inviting him to a "Rebecca" event for group sales agents.

Safari Hunt