Joe Meli was a businessman who bought and sold tickets directly from show producers, concert promoters and talent agencies and only ran afoul of the law because he falsified some documents and kept poor accounting records, an attorney for the convicted former CEO of Advanced Entertainment is arguing in hopes of securing a light sentence. In October, Meli pled guilty to one count of wire fraud after a lengthy investigation by the FBI amid accusations Meli was operating a Ponzi scheme.

On Wednesday (March 14), Meli’s attorney Daniel J. Fetterman filed a sentencing memorandum with U.S. District Court Judge Kimbra Wood, claiming his client was not a criminal but a real businessman who had direct dealings with executives throughout the live entertainment industry. Promoters and agents would directly sell him concert and show tickets, often at double face value, which Meli would then attempt to flip on the secondary market. By presenting a series of heavily-redacted emails and lengthy text message exchanges, attorneys for Meli paint a picture of a high-volume ticket broker bragging about deals with big-time promoters and ultimately falling on the wrong side of the law because of several misrepresentations. Yes, he concocted phony agreements to lure in investors, his lawyers claim, but Meli also had real relationships with show promoters, agents and artist managers.

Fetterman, who works for the law firm of Marc E. Kasowitz, President Donald Trump’s longtime attorney representing him in the Russia investigations, is asking U.S. District Court Judge Kimbra Wood to sentence Meli to two years in prison, a considerably lighter sentence than the four-and-a-half year sentence suggested by the U.S. Probation Office and the eight years he faces under federal sentencing guidelines. Fetterman is also asking a judge to consider allowing Meli to serve out part of his term on house arrest, saying he has a job offer at the Friends of Island Academy, a non-profit that supports young people serving time in New York City jails.

Was Meli really a player in the live music space, or was the whole gambit one complex lie to trick investors into handing over cash? In an attempt to portray Meli as a legitimate businessman, Fetterman filed hundreds of pages of redacted emails and text messages that trace back to the formation of Bulldog Entertainment, a “bespoke” concert series that charged a premium for intimate concerts by “Prince, Billy Joel, Dave Matthews, Tom Petty, and James Taylor,” according to the sentencing document, which says he sold the company in 2007 to Warner Music Group.

Fetterman said Meli founded a legitimate ticket business called Advanced Entertainment in 2011 “to arrange for the purchase of large blocks of premium tickets directly from venues, promoters, and artists’ managers,” tapping into “Joe’s relationships in the industry” which “provided Joe and his investors with access to tickets that other ticket brokers could not provide.”

Much like a hedge fund, Meli would use money from multiple investors to buy up tickets, sell them at a markup and then disperse the profits to his backers. One investor told Fetterman “‘spend a week with [Joe] and you will understand all of this,” because Meli’s “success was built on these hard-earned relationships,” and “the greatest engine of these relationships was Joe himself.”

Fetterman even produced a heavily-redacted August 14, 2017 contract between Meli and an unnamed individual who promised to sell Meli tickets to Metallica’s 2017 stadium tour, promising as many as 250,000 tickets priced at 1.5 times face value for $46.9 million. In the agreement, the seller claims to have a direct relationship with the band, and Meli agrees to wire $1.1 million to the seller as a deposit, although ultimately the deal fell apart for reasons not explained, according to Fetterman. That’s followed by a similar letter on Jan. 13, 2017 which notifies Meli “we have all the tickets ironed out (66,000) for the stadium shows this summer and we will have them listed” for sale.

Who is this person offering to sell Meli Metallica tickets, and why did the agreement collapse? According to a Jan. 12, 2017 $1 million funding agreement between Meli and a private investor, Meli claimed to have an agreement with “Ride the Lightening LLC,” which he said was the “entity through which the band popularly known as the Metallica has and does currently conduct business, including arranging concert tours.” But Amplify could find no record of this company and the word ‘Lightning’ is spelled wrong.

One possibility — the document is another fake. After all, the government said Meli showed investors several phony agreements with the producers of Broadway hit musical Hamilton to win their trust. But Fetterman argues the Metallica document is not a fake and said Meli really did have connections in the entertainment industry but kept many of his investors in the dark about how he was spending their money, not to deceive them but because “had he disclosed the true sources of tickets to his investors, they could have cut Joe out of the transactions entirely.”

Emails and text messages produced in discovery showed “Joe was negotiating daily with the heads of live event companies, artists’ managers, and others to obtain the tickets he said he’d obtained,” Fetterman writes. “While he did not always obtain those tickets from the sources identified in the false letter agreements, Joe usually was able to obtain the tickets.”

Meli’s other problem was cash — namely, having too much of it, forcing Meli to constantly seek out methods for converting paper money into wireable funds. There’s an email dated Nov. 17, 2016 that shows Meli trying to convert “cash proceeds from the sale of Hamilton tickets” into bankable assets. In another email dated June 15, 2016, Meli is approached by a client asking for a disbursement from his Hamilton investment to finance a vacation.

“I have collected money and have them converting it from cash to wirable capital,” Meli responds. “I am trying to get it out as I too could use some liquidity.”

Ultimately it was this abundance of cash coupled with poor accounting that caused Meli’s downfall, his attorney argued, because brokers he bought and sold tickets from demanded to be paid with cash while investors sought to be paid with wireable funds.

“When the time came to repay an investor with a wire transfer, Joe used the wired funds he received from later investors. All the time, however, cash transactions were occurring in parallel to buy and sell tickets to live events,” Fetterman writes. “Given the context of the business, that the Government saw investor funds arrive in Joe’s bank account, and then be immediately wired out to other investors was not proof that Joe was operating a ‘fictitious business.’ Rather, it was evidence that Joe ran a highly unconventional business that typically was conducted using cash transactions.”

Prior to he arrest, Meli was said to be finalizing a deal with DTI, a consolidation firm that operates like a hedge fund for ticket brokers.

“By August, Joe had struck a deal, merging Joe’s business gathering tickets to be sold on the secondary market with DTI’s broker management tool,” Fetterman writes. “The vision behind this merger was profound — it would have allowed Joe to provide forward financing to promoters, venues, artists, and their managers by buying premium tickets in advance, and then selling those tickets directly to fans at premium prices without having to deal with the network of brokers, and their demands to conduct business in cash.”

Meli claims he helped orchestrate the October 2016 investment into DTI by private equity firms CVC and New Amsterdam Growth Capital and was briefly appointed as co-CEO of DTI, supplying the company directly with inventory.

“As is clear from the correspondence, Joe’s goal was to purchase premium tickets directly from these promoters to post those tickets for sale directly on the DTI platform without having to engage in cash transactions with ticket brokers,” Fetterman writes.”He would no longer struggle to convert the cash proceeds of his business into wire- able funds. By the end of 2016, as the DTI transaction began to get off the ground, Joe believed he was on the verge of a dramatic success, the ultimate reward for his many years of hard work. That all came crashing to a halt with his arrest on January 27, 2017.”

Meli was originally charged with five counts of fraud, but saw four of the charges dropped after attorneys alleged he was illegally lured out of his lawyers’ office by a government informant. Meli later pled guilty to one charge of wire fraud. He is set to be sentenced on March 27.