RAIN OR SHINE: Join Bronx Dems Chairman Marcos Crespo for Our Annual BBQ

  The annual Bronx Democratic County Committee Softball game may have been rained out, but as you see in the photo above the rain did not stop the Annual BDCC Barbecue. There was more than just hot dogs and hamburgers this year as there were about a dozen different main dishes, and as many side dishes to be had. A huge fruit platter, and an almost endless variety of desert cookies and mini muffins were all on hand. An abundance of different refreshments were also in the house. 

Above - The early group photo of the elected officials that were on hand.

Below - Former 80th A.D. Male District Leader Marcos Sierra (L.) with future (?) Councilman Brian Meadows. Mr. Meadows boss Andy King will be term limited out of office in 2021.

Above - The latter group photo with the second wave of elected officials.

Below - We were glad to see our good friend Assemblyman Jose Rivera, and had a nice lively three way conversation with Assemblyman Rivera and Assemblyman Jeffrey Dinowitz.

The rain may have cancelled the annual BDCC Softball game,  but it could not damper the spirit of those who attended this years BDCC Barbecue. 

Street Renaming For Will Madonna Does Not Go As Planned

  It didn't go as planned for the Street Renaming of the corner of Morris Park and Bogart Avenues to 'Wil Madonna Way'. The family, the elected officials, and close friends were there, but the official street sign did not arrive in time for the ceremony. Councilman Mark Gjonaj said in his most apologetic way, but also a humorous way that Wil must still be here in spirit because this is something he might have done. Councilman Gjonaj and others who spoke gave revealing thoughts of how William (Wil) Madonna touched their lives, with Gjonaj sadly remembering all the many things that Wil did for him. Assemblywoman Nathalia Fernandez said that Will taught her many things while he always said after wards that she had done a good job in the assignment she was given. She had to stop at one point, while she wiped away the tears, but almost everyone was teary eyed. Assemblyman Michael Benedetto, Wil's sister, his son , and others spoke of all the good things that William Madonna had done for the community and his friends, not wanting anything really in return. 

Above - Assemblywoman Nathalia Fernandez speaks as tears are coming to her eyes, as next to her is a somber Councilman Mark Gjonaj.

Below - Wil's good friend Sonny Vitaj told a few stories of the great times with Wil.

Above - Wil's sister spoke of how committed he was to his community.

Below - Wil's sons echoed the comment their aunt made about Wil's devotion to his friends and community.

As the official  street sign  did not arrive on  time for the  ceremony, a dignified temporary sign was put up until the official street sign 'Wil Madonna Way' arrives in a few days.

Bronx Man Convicted In White Plains Federal Court In Connection With Fatal Carjackings Of Two Livery Cab Drivers

  Geoffrey S. Berman, the United States Attorney for the Southern District of New York, announced that TYRONE FELDER, a/k/a “Man Man,” was found guilty of participating in the fatal carjackings of two livery cab drivers: Maodo Kane, who was killed in the Bronx on August 5, 2014, and Aboubacar Bah, who was killed in the Bronx on August 12, 2014.  FELDER was also found guilty of participating in two armed robberies in Yonkers on August 5, 2014, as well as firearms offenses related to the carjackings and the robberies.  The jury convicted FELDER yesterday on all nine counts of the Indictment following a two-week trial before U.S. District Judge Vincent L. Briccetti.

U.S. Attorney Geoffrey S. Berman said:  “Tyrone Felder’s days of reckless and deadly violence are over.  This unanimous verdict means that Felder will spend the rest of his life in prison, but it will not bring back the two men that Felder murdered.”

According to the allegations contained in the Indictment and the evidence presented in court during the trial:

On August 5, 2014, FELDER participated in the armed carjacking of Maodo Kane.  During the course of the carjacking, FELDER shot and killed Mr. Kane in the vicinity of Hunter Avenue, in the Bronx.  FELDER then used the stolen car to participate in two gunpoint robberies of businesses in Yonkers.  Subsequently, on August 12, 2014, FELDER participated in the carjacking of Aboubacar Bah.  During the course of the carjacking, FELDER shot and killed Mr. Bah in the vicinity of Bryant Avenue, in the Bronx.

FELDER, 29, was found guilty of two counts of carjacking resulting in death, two counts of robbery, four counts of firearms possession, and one count of conspiracy to commit robbery.  FELDER faces a maximum potential sentence of life in prison and a mandatory minimum sentence of 100 years in prison, which must run consecutively to any other term of imprisonment imposed.  FELDER is scheduled to be sentenced by Judge Briccetti on January 18, 2019.

FELDER’s co-defendants, Kareem Martin, a/k/a “Jamal Walker,” Takiem Ewing, a/k/a “Mulla,” and Tommy Smalls, a/k/a “Tommy Guns,” previously pled guilty to participating in the fatal carjackings described above. 

Mr. Berman praised the outstanding investigative work of the New York City Police Department, the City of Yonkers Police Department, and the Federal Bureau of Investigation’s Westchester County Safe Streets Task Force.

New York Attorney Pleads Guilty To Tax Fraud Related To Multimillion-Dollar Embezzlement From Deceased Client’s Estate

  Geoffrey S. Berman, the United States Attorney for the Southern District of New York, and Richard E. Zuckerman, the Principal Deputy Assistant Attorney General for the Tax Division of the Department of Justice, announced that STEVEN M. ETKIND, a New York-licensed attorney and a Certified Public Accountant, pled guilty today to conspiracy to defraud the United States and tax evasion arising from a scheme to embezzle millions of dollars from a deceased client’s estate.  ETKIND pled guilty before United States District Judge John G. Koeltl.

Manhattan U.S. Attorney Berman said:  “As he admitted in court today, Steven Etkind violated the law, the canons of his profession, and the trust of his client by stealing more than $3.5 million from the client’s estate.  Etkind now awaits sentencing for his crimes.”

Principal DAAG Zuckerman said:  “The fiduciary duty that a lawyer owes to a client is paramount to the practice of law.  The Justice Department will prosecute and seek just punishment against any attorney who victimizes their clients for their own personal gain.”

According to the allegations contained in the Indictment to which ETKIND pled guilty and statements made in court:

ETKIND was a partner at a New York law firm and served as head of the law firm’s Tax, Trusts, and Estates practice group.  ETKIND performed legal work for a successful entrepreneur client who, prior to his death in 2008, named ETKIND as co-executor of his $35 million estate.

The client’s will directed the creation of two charitable trust private foundations, funded with assets from the client’s estate, for the sole purpose of donating to 501(c)(3) charitable organizations, including those aimed at assisting Jewish-sponsored organizations.  ETKIND was named co-trustee of these trusts. 

Beginning in 2009, ETKIND and his co-conspirator set up a phony charitable organization, the United Jewish Education Foundation (“UJEF”), and used it to steal more than $3.5 million from these charitable trusts.  As part of the conspiracy, ETKIND directed that donations from the trusts be first made to legitimate Jewish charitable organizations in order to give the disbursements the appearance of legitimate donations.  ETKIND and his co-conspirator then redirected the funds to accounts of UJEF, the phony charity that his co-conspirator controlled. 

ETKIND subsequently directed his co-conspirator to write checks, totaling $327,500, to a bank account in the name of JE Capital Holding Corp., a nominee corporate entity that ETKIND controlled exclusively.  ETKIND further directed more than $3 million to be used in 2010 to purchase a 6,300 square-foot home with a swimming pool in Southampton, New York.  The Southampton property was purchased for the use and enjoyment of ETKIND and his family.  ETKIND later transferred title of the property to JE Trust, a nominee trust he controlled. 

To conceal his embezzlement, ETKIND filed, and caused to be filed, fraudulent personal, corporate, and charitable trust returns with the Internal Revenue Service (“IRS”).  During the course of a subsequent audit of UJEF by the IRS Tax Exempt & Government Entities Division, ETKIND and his co-conspirator made several false and misleading statements, including about the true ownership of the Southampton Property.          

ETKIND, 56, of New York, New York, pled guilty to one count of conspiracy to defraud the United States and one count of tax evasion, each of which carries a maximum sentence of five years in prison.  As part of the plea agreement, ETKIND agreed to pay restitution in the amount of $1,208,245 to the IRS, which represents the additional tax due and owing as a result of ETKIND’s filing of false individual income tax returns for the 2009 and 2010 calendar years.  Sentencing is scheduled for January 18, 2019, before Judge Koeltl.

The maximum potential sentences are prescribed by Congress and are provided here for informational purposes only, as any sentencing of the defendant will be determined by Judge Koeltl.

Mr. Berman and Mr. Zuckerman praised the outstanding efforts by special agents of IRS Criminal Investigation.  Mr. Berman also thanked the U.S. Department of Justice’s Tax Division and the IRS’s Tax Exempt & Government Entities Division for their assistance in the investigation. 

Additional information about the Tax Division and its enforcement efforts may be found on the division’s website, https://www.justice.gov/tax.

Former World Boxing Champion Sentenced In Manhattan Federal Court To 10 Years In Prison

Avtandil Khurtsidze Previously Convicted at Trial of Racketeering Conspiracy and Fraud in Connection with his Role as an Enforcer for the Shulaya Enterprise

  Geoffrey S. Berman, the United States Attorney for the Southern District of New York, announced that AVTANDIL KHURTSIDZE, a former world boxing champion and the chief enforcer for Razhden Shulaya, was sentenced to 10 years in prison by United States District Judge Katherine B. Forrest, following KHURTSIDZE’s conviction in June on charges of racketeering and fraud conspiracy.   

Manhattan U.S. Attorney Geoffrey S. Berman said:  “Avtandil Khurtsidze, a former middleweight boxing champion and heavyweight enforcer for the Shulaya Enterprise – a massive ‘elite’ criminal enterprise of the former Soviet Union – was convicted of intimidating and punishing associates of the organization.  Thanks to our dedicated law enforcement partners around the globe, Khurtzide’s reign of extortion and violence has been halted, as he is now sentenced to 10 years in federal prison.”

According to the Indictments filed in Manhattan federal court, previous court filings, and statements made at public court proceedings:

The Shulaya Enterprise was an organized criminal group operating under the direction and protection of Razhden Shulaya, a/k/a “Brother,” a/k/a “Roma,” a “vor v zakone” or “vor,” which are Russian phrases translated roughly as “Thief-in-Law” or “Thief,” and which refer to an order of elite criminals from the former Soviet Union who receive tribute from other criminals, offer protection, and use their recognized status as vor to adjudicate disputes among lower-level criminals.  As a vor, Shulaya had substantial influence in the criminal underworld and offered assistance to and protection of the members and associates of the Shulaya Enterprise.  Those members and associates, and Shulaya himself, engaged in widespread criminal activities, including acts of violence, extortion, the operation of illegal gambling businesses, fraud on various casinos, identity theft, credit card frauds, trafficking in large quantities of stolen goods, money laundering through a fraudulently established vodka import-export company, payment of bribes to local law enforcement officers, and the operation of a Brooklyn-based brothel.

The Shulaya Enterprise operated through groups of individuals, often with overlapping members or associates, dedicated to particular criminal tasks.  While many of these crews were based in New York City, the Shulaya Enterprise had operations in various locations throughout the United States (including in New Jersey, Pennsylvania, Florida, and Nevada) and abroad.  Most members and associates of the Shulaya Enterprise were born in the former Soviet Union and many maintained substantial ties to Georgia, Ukraine, and the Russian Federation, including regular travel to those countries, communication with associates in those countries, and the transfer of criminal proceeds to individuals in those countries.

AVTANDIL KHURTSIDZE, formerly a middleweight boxing champion, acted as Shulaya’s chief enforcer and, as such, engaged in multiple acts of extortion and violence.  KHURTSIDZE was captured on video twice assaulting others in service of the Shulaya Enterprise, participated in recorded acts of extortion of gambling debts, and planned additional acts of violence with Shulaya targeting associates of the Shulaya Enterprise whom KHURTSIDZE and Shulaya perceived as having disrespected Shulaya’s status as a vor.

KHURTSIDZE also participated in a scheme to defraud casinos by targeting particular models of electronic slot machines using a complicated algorithm designed to predict the behavior of those machines.  Shulaya and other members of the Enterprise obtained the technology used to commit that fraud through violence, including through the 2014 kidnapping of a software engineer in Las Vegas.  KHURTSIDZE, working at Shulaya’s direction, then assisted in refining that technology by training lower-level members of the Shulaya Enterprise to execute this casino scam using smartphones and software developed by the Shulaya Enterprise.

Following a two-week trial before the Honorable Katherine B. Forrest, KHURTSIDZE was found guilty of one count of racketeering conspiracy and one count of wire fraud conspiracy.      

In addition to the prison term, KHURTSIDZE, 38, of Kutaisi, Republic of Georgia, was sentenced to two years of supervised release

Mr. Berman praised the outstanding work of the Federal Bureau of Investigation and its Eurasian Organized Crime Squad, as well as U.S. Customs and Border Protection, and the New York City Police Department for their investigative efforts and ongoing support and assistance with the case.

Gary Hirst Sentenced To 8 Years In Prison For Defrauding Tribal Entity And Pension Funds Of Tens Of Millions Of Dollars

  Robert Khuzami, Attorney for the United States, Acting Under Authority Conferred by 28 U.S.C. § 515, announced that GARY HIRST was sentenced today by U.S. District Judge Ronnie Abrams to 8 years imprisonment for defrauding a Native American tribal entity and numerous pension fund investors of tens of millions of dollars in connection with the issuance of bonds by the tribal entity.  HIRST pled guilty May 15, 2018, to conspiracy to commit securities fraud, securities fraud, investment adviser fraud, and conspiracy to commit investment adviser fraud before U.S. Magistrate Judge Barbara Moses. 

Attorney for the United States Robert Khuzami said:  “This complex and brazen securities fraud scheme lined the pockets of Gary Hirst and his co-defendants but left the Native American tribal entity, the Wakpamni Lake Community Corporation $60 million in debt.  Hirst, who is already in prison for a separate securities scheme prosecuted by this Office, now faces additional time behind bars for this criminal conspiracy.”

According to the allegations contained in the Indictment filed against HIRST and statements made in related court filings and proceedings, including the trial of co-defendants John Galanis, Devon Archer, and Bevan Cooney:

From March 2014 through April 2016, HIRST, Jason Galanis, John Galanis, Devon Archer, Bevan Cooney, Michelle Morton, and Hugh Dunkerley, engaged in a fraudulent scheme to misappropriate the proceeds of bonds issued by the Wakpamni Lake Community Corporation (“WLCC”), a Native American tribal entity (the “Tribal Bonds”), and to use funds in the accounts of clients of asset management firms controlled by HIRST, Morton, and others to purchase the Tribal Bonds, which the clients were then unable to redeem or sell because the bonds were illiquid and lacked a ready secondary market.

The WLCC was convinced to issue the Tribal Bonds through false and fraudulent representations by John Galanis.  Simultaneously, Jason Galanis, with the backing of Archer and Cooney, worked to acquire Hughes Capital Management (“Hughes”), a registered investment adviser.  HIRST and Morton were installed as Hughes’s chief investment officer and chief executive officer, respectively.  Within weeks of taking control of Hughes, HIRST and Morton placed the entire $28 million first series of Tribal Bonds with Hughes clients but failed to disclose material facts about the Tribal Bonds, including that the Tribal Bonds fell outside the investment parameters set forth in the investment advisory contracts of certain Hughes clients.  Indeed, HIRST himself signed the trade tickets to purchase the bonds after other employees of Hughes refused to do so.  In addition, Hughes’s clients were not told about substantial conflicts of interest with respect to the issuance and placement of the Tribal Bonds before the Tribal Bonds were purchased on these clients’ behalf. 

The defendants and their co-conspirators then misappropriated the proceeds of the first Tribal Bond issuance.  Specifically, although the Tribal Bonds were supposed to be invested in an annuity, the proceeds were deposited into an account opened by HIRST and over which both HIRST and Dunkerley had signatory authority.  HIRST and Dunkerley, at the direction of Jason Galanis, then transferred significant amounts of the bond proceeds from that account to support the defendants’ business and personal interests.  Jason Galanis, for example, used a portion of the proceeds of the first Tribal Bond issuance to finance the purchase of a $10 million luxury apartment in Tribeca.  John Galanis, similarly, secretly received $2.35 million in proceeds of the first bond issuance, which he spent on a variety of personal expenses and luxury items, including cars, jewelry, and hotel expenses. 

In addition, after John Galanis induced the WLCC to issue a second round of Tribal Bonds, Archer and Cooney used $20 million of bond proceeds from the first issuance to buy the entirety of the second issuance.  As a result of the use of recycled proceeds to purchase additional issuances of Tribal Bonds, the face amount of Tribal Bonds outstanding increased and the amount of interest payable by the WLCC increased, but the actual bond proceeds available for investment on behalf of the WLCC did not increase.  The bonds purchased by Archer and Cooney were then used to meet net capital requirements at two broker dealers in which Archer and Cooney had interests.  Cooney also obtained a $1.2 million loan based on his purported ownership of the bonds, which he subsequently failed to repay.  In addition, millions of dollars in bond proceeds from the bond issuances were used to finance the acquisition of companies that the defendants and their co-conspirators acquired as part of a strategy to build a financial conglomerate.

In the spring of 2015, John Galanis induced the WLCC to issue an additional $16 million worth of Tribal Bonds.  Simultaneously, Jason Galanis, Archer, and others – in consultation with HIRST – purchased a second investment adviser, Atlantic Asset Management (“Atlantic”), and installed Morton as the chief executive officer.  Within days of obtaining control of Atlantic, Morton placed the entirety of the $16 million Tribal Bond with an Atlantic client, without the client’s consent and without disclosing the fact that the Tribal Bonds were outside the client’s investment parameters and that numerous conflicts of interest existed.  The proceeds of the $16 million issuance were again not invested in an annuity as promised, but instead were diverted, among other things, to finance the defendants’ acquisition of another company in furtherance of their plan to build a financial conglomerate and to make payments to one of the broker dealers in which Archer and Cooney had interests.  HIRST also directed that significant portions of the bond proceeds be funneled through other secret accounts and used to purchase significant portions of a technology stock’s IPO – which was itself secretly controlled by several of the defendants.

In addition to the prison term, GARY HIRST, 66, was sentenced to 3 years of supervised release.  HIRST was also ordered to forfeit $1.3 million and to make restitution in the amount of $43,785,176.

Jason Galanis, who pled guilty to conspiracy to commit securities fraud, securities fraud, and investment adviser fraud, was sentenced to a term of 173 months in prison on August 11, 2017.  Michelle Morton, who pled guilty to conspiracy to commit securities fraud and investment adviser fraud, is scheduled to be sentenced on November 30, 2018.  John Galanis, who was convicted at trial of conspiracy to commit securities fraud and securities fraud, is scheduled to be sentenced on November 2, 2018.  Devon Archer and Bevan Cooney, who were convicted at trial of conspiracy to commit securities fraud and securities fraud, are scheduled to be sentenced on November 9, 2018.  Hugh Dunkerley, who pled guilty to conspiracy to commit securities fraud, two counts of securities fraud, bankruptcy fraud, and falsification of records with the intent to obstruct a government investigation, is scheduled to be sentenced on March 8, 2019.

This conviction represents HIRST’s second conviction in this District in a little more than a year.  On August 3, 2017, following his conviction at trial, HIRST was sentenced by U.S. District Judge P. Kevin Castel to 78 months in prison in connection with his participation in a scheme to manipulate the market for Gerova Financial Group, Ltd., a publicly traded company listed on the New York Stock Exchange, and to defraud the shareholders of that company. 

Mr. Khuzami praised the work of the U.S. Postal Inspection Service and the Federal Bureau of Investigation, and thanked the Securities and Exchange Commission.

Sex Trafficker Pleads Guilty In Manhattan Federal Court To Victimizing Minor Girls And Adult Women For Nearly Two Decades

  Geoffrey S. Berman, the United States Attorney for the Southern District of New York, announced that GREVY GERARD PIERRE-LOUIS, a/k/a “Cadillac Slim,” a/k/a “Caddy,” pled guilty yesterday before Chief United States District Judge Colleen McMahon to conspiracy to commit sex trafficking and conspiracy to transport minors interstate for the purpose of prostitution. 

Manhattan U.S. Attorney Geoffrey S. Berman said:  “The defendant spent most of his adult life profiting from his victimization of girls and women through extreme physical and psychological abuse.  All the while, he bragged about being a pimp and a player.  Thanks to the extraordinary work of the FBI, the defendant’s so-called game is now over, and he will face the consequences of his actions.  We can only hope that the defendant’s guilty plea brings some measure of justice for the survivors of his vicious crimes.”

According to the Indictment, Superseding Information, publicly-filed documents, and statements made in court:

Starting in or about 1998 and continuing through 2016, PIERRE-LOUIS compelled his victims to engage in prostitution through extreme violence, psychological and verbal abuse, coercion, and threats of violence to them and their family members.  PIERRE-LOUIS victimized girls and women in numerous states, all for his own profit. 

PIERRE-LOUIS, 46, of Queens, New York, was arrested on August 17, 2016, and has been in federal custody since.  PIERRE-LOUIS pled guilty to one count of conspiracy to commit sex trafficking, which carries a maximum sentence of life in prison; and one count of conspiracy to transport minors interstate for the purpose of prostitution, which carries a mandatory minimum sentence of ten years in prison, and a maximum sentence of life in prison.  The maximum potential sentences are prescribed by Congress and are provided here for informational purposes only, as any sentencing of the defendant will be determined by the judge.

PIERRE-LOUIS is scheduled to be sentenced by Judge McMahon on December 12, 2018.

Mr. Berman praised the outstanding investigative work of the FBI.  Mr. Berman also thanked the New York City Police Department, the U.S. Attorney’s Office for the Southern District of Florida, the Miami Field Office of the FBI, the United States Secret Service, the City of Miami Police Department, the Miami Beach Police Department, and the Miramar Police Department for their cooperation throughout the investigation. 

A.G. Underwood Announces Clergy Abuse Hotline – Part Of Investigation Into Sexual Abuse Of Children Within NY Dioceses Of Catholic Church

Victims and Anyone with Information are Encouraged to Call Hotline at 1-800-771-7755 or File Complaint Online at ag.ny.gov/ClergyAbuse

AG Launched Civil Investigation into How Catholic Church Reviewed and Potentially Covered Up Sexual Abuse; AG Also Seeking to Partner with District Attorneys on Viable Criminal Prosecutions

AG Reiterates Call for State Legislature to Pass Child Victims Act

  New York Attorney General Barbara D. Underwood announced a clergy abuse hotline and online complaint form through which victims and anyone with information can provide information – part of the Attorney General’s ongoing investigation into sexual abuse of children within the New York dioceses of the Catholic Church.

Victims and anyone with information about abuse can call the hotline at 1-800-771-7755 or file a complaint online at ag.ny.gov/ClergyAbuse. An investigator will review all allegations; the Attorney General and our law enforcement partners will seek to protect victims’ and witnesses’ identities.

The Attorney General’s Charities Bureau has launched a civil investigation into how the dioceses and other church entities – which are non-profit institutions – reviewed and potentially covered up allegations of extensive sexual abuse of minors.

As announced last month, the Attorney General’s Criminal Division is also seeking to partner with District Attorneys – who are the only entities that currently have the power to convene grand juries to investigate these matters – to investigate and, if warranted, prosecute any individuals who have committed criminal offenses that fall within the applicable statutes of limitations.

“The Pennsylvania grand jury report shined a light on incredibly disturbing and depraved acts by Catholic clergy, assisted by a culture of secrecy and cover ups in the dioceses. Victims in New York deserve to be heard as well – and we are going to do everything in our power to bring them the justice they deserve,” said Attorney General Underwood. “I urge all victims and anyone else with information to contact our hotline. And make no mistake: the only way that justice can fully and truly be served is for the legislature to finally pass the Child Victims Act.”

It is important to note that many cases of abuse may not be prosecutable given New York’s statutes of limitations. The Attorney General has repeatedly urged the legislature to pass the Child Victims Act, which would allow all victims to file civil suits until age 50 and seek criminal charges until age 28. Under current law, victims only have until age 23 to file civil cases or seek criminal charges for most types of child sexual abuse; some of the most serious child sex crimes have no time limit on the bringing of criminal charges, but only for conduct that occurred in 2001 or later.  

However, the Attorney General encourages any victim of sexual abuse by Catholic clergy to participate in this investigation, even if they believe that their information may be outside the statute of limitations for a court case. All victim information will be helpful to understanding and reforming the institutional approach of the Church, regardless of whether an individual case can be prosecuted.

“I continue to encourage District Attorneys in all counties to work with the Attorney General’s Office to investigate allegations of sexual abuse in the Catholic Diocese. Past victims and current victims deserve to have their complaints aggressively investigated and those who have committed these horrific crimes must be held accountable,” said District Attorneys Association of New York President, Albany County District Attorney David Soares. “DAASNY is ready to collaborate with the Attorney General’s office to investigate complaints from victims and witnesses.”