AG James, NY Strike Force Take Down Long Island Gun Trafficking Ring

Individuals Illegally Sold 32 Firearms, Including Assault Weapons, High-Capacity Ammunition Feeding Devices, and More Than One Thousand Rounds of Ammunition

 New York Attorney General Letitia James and the New York Strike Force today announced a 125-count indictment, charging four individuals for their roles in a gun trafficking operation that illegally sold 32 firearms on Long Island. The indictment — unsealed in Suffolk County Court today — charges Scotbert Green, James McNulty, Harold Lamm, and Carl Singer with trafficking numerous assault weapons, semiautomatic pistols, revolvers, high-capacity ammunition feeding devices, and more than one thousand rounds of ammunition.

“Illegal guns have no place in our homes or on our streets,” said Attorney General James. “These individuals put all of our communities at risk by allegedly trafficking dozens of guns, including assault weapons, from other states into New York. Our streets are a little safer tonight because of this investigation and I thank the New York Strike Force for their invaluable partnership.”

Some of the assault weapons, semiautomatic pistols, revolvers, high-capacity ammunition feeding devices, and more than one thousand rounds of ammunition recovered through this gun trafficking operation.

 Some of the assault weapons, semiautomatic pistols, revolvers, high-capacity ammunition feeding devices, and more than one thousand rounds of ammunition recovered through this gun trafficking operation.

Today’s take down was the result of a joint investigation between the Attorney General’s Organized Crime Task Force (OCTF) and the New York Strike Force — a crime-fighting unit comprising federal, state, and local law enforcement agencies, supported by the Organized Crime Drug Enforcement Task Force and the New York/New Jersey High Intensity Drug Trafficking Area.

The investigation — dubbed “Operation Silence of the Lamm” after one of the defendants — included the use of physical surveillance, electronic surveillance, and undercover operations. During the course of the recorded transactions, the defendants repeatedly referenced their ability to obtain guns from other states and bring them into New York to be sold. The four defendants were charged with Criminal Sale of a Firearm, Criminal Possession of a Weapon, and Conspiracy for their participation in the illegal gun trafficking operation. 

According to the indictment, Scotbert Green acted as a broker between his firearms suppliers, James McNulty and Carl Singer, and sold firearms and ammunition to undercover officers on nine occasions between January 28, 2019 and June 26, 2019. Similarly, McNulty obtained firearms from his supplier, Harold Lamm, and sold numerous firearms and ammunition to undercover officers on five occasions between April 4, 2019 and October 24, 2019. 

In a separate 28-count indictment, McNulty is also charged with selling an additional seven firearms, including an assault weapon, four high-capacity ammunition feeding devices, and ammunition to an undercover officer on January 27, 2020.

The investigation resulted in the recovery of the following firearms and ammunition from the defendants:

Seven 9-millimeter semiautomatic pistols
Seven .45 caliber semiautomatic pistols
Four .40 caliber semiautomatic pistols
Four .380 caliber semiautomatic pistols
Two .32 caliber semiautomatic pistols
Two .38 caliber revolvers
One .410-gauge revolver
One .44 magnum revolver
One .44 special caliber revolver
One .9-millimeter semiautomatic rifle (assault weapon)
One 9-millimeter semiautomatic pistol (assault weapon)
One .455 caliber revolver – inoperable
One .357 caliber revolver
One 12-gauge shotgun – not chargeable
1,063 rounds of ammunition
18 high-capacity ammunition feeding devices

The 125-count indictment — unsealed today in Suffolk County Court — charged the four individuals with 12 crimes, including Criminal Sale of a Firearm in the Second Degree, Criminal Possession of a Weapon in the Second Degree, and Conspiracy in the Fourth Degree, among other charges. Green, McNulty, and Lamm were also charged with Criminal Sale of a Firearm in the First Degree, a Class B violent felony. If convicted, Green, McNulty, and Lamm face a maximum of 25 years in prison, and Singer faces a maximum of 15 years in prison.

The separate 28-count indictment against McNulty — also unsealed today — charged McNulty with Criminal Sale of a Firearm in the Second Degree, Criminal Possession of a Weapon in the Second Degree, among other charges. If convicted on this indictment, McNulty faces an additional maximum of 15 years in prison.  

Those charged in today’s indictment include:

SCOTBERT GREEN, 63, of Brentwood, New York;
JAMES MCNULTY, 33, of Deer Park, New York;
HAROLD LAMM, 36, of Deer Park, New York;
CARL SINGER, 89, of Islandia, New York;

"Gun traffickers invade our communities by putting weapons in the wrong hands for the wrong reasons," said DEA Special Agent in Charge Ray Donovan. "By seizing 32 illegal guns from the streets of Long Island, we are making our communities safer from gun-related crime and violence. I applaud the men and women whose diligent work led to these arrests and seizures.”

“The four suspects who were running this illegal gun trafficking operation had absolutely no regard for the potential damage that could have been inflicted if these firearms ended up in the wrong hands,” said State Police Superintendent Keith M. Corlett. “I commend our members and all our partners for their outstanding work on this case. Taking these firearms off the streets prevented future crimes and may have saved lives.”

“I would like to thank Attorney General James and the NY Strike Force for bringing down this gun trafficking ring and seizing dozens of guns that were destined for communities here on Long Island,” said Suffolk County Executive Steve Bellone. “This investigation sends a strong message about our unrelenting commitment to reducing firearm violence in Suffolk County and keeping illegal weapons off of our streets.”

“When law enforcement investigates criminals who are illegally selling firearms, they are putting themselves in harm’s way in order to prevent these weapons from ending up in the wrong hands,” said Suffolk County District Attorney Timothy Sini. “Illegal gun trafficking — particularly the illegal sale of assault weapons — can have deadly consequences, which is why every time an illegal trafficking operation is shut down, it has potentially saved lives. I thank Attorney General James, the New York Strike Force and all of the partnering agencies involved in this investigation for their vigilance in targeting gun traffickers and continuing to keep Suffolk County safe.”

“The number of firearms, to include automatic weapons, that were seized during this operation is a clear representation of the potential violence that the alleged gun traffickers were ready to contribute to,” said Peter C. Fitzhugh, Special Agent in Charge of HSI New York. “HSI, along with its law enforcement partners, prioritize the safety of our citizens and will aggressively pursue investigations into those who are willing to supply dangerous weapons contrary to the law.”

The Office of the Attorney General wishes to thank the members of the New York Strike Force for their partnership in this investigation, including the New York Division of the Drug Enforcement Administration (DEA); the New York State Police; the New York City Police Department; Immigration and Customs Enforcement – Homeland Security Investigations; the U.S. Internal Revenue Service Criminal Investigation Division; the Bureau of Alcohol, Tobacco, Firearms and Explosives; the U.S. Customs and Border Protection; the U.S. Secret Service; the U.S. Marshals Service, the New York National Guard; the Clarkstown Police Department; the U.S. Coast Guard; the Port Washington Police Department; and the New York State Department of Corrections and Community Supervision.

The Office of the Attorney General also wishes to thank the Suffolk County Police Department, the Suffolk County District Attorney’s Office, and members of the DEA’s New York Drug Enforcement Task Force for their valuable participation and assistance in this investigation.

The joint investigation with the Drug Enforcement Administration’s New York Field Division Organized Crime Drug Enforcement Strike Force was directed by OCTF Investigators Bradley Rutty and Andrew Scala, the U.S. Army National Guard Counterdrug Task Force, and Supervising Investigator Paul Grzegorski, under the supervision of OCTF Assistant Chief John Sullivan and Deputy Chief Christopher Vasta. The Attorney General’s Investigations Division is led by Chief Oliver Pu-Folkes. .

The charges against the defendants are merely accusations and the defendants are presumed innocent unless and until proven guilty.

Additional photos of firearms and ammunition recovered:

BRONX WOMAN SENTENCED FOR STEALING OVER $100,000 IN HRA AND SNAP BENEFITS

Defendant Pleaded Guilty to Falsifying Business Records; Must Pay Back Thousands to City of New York

 Bronx District Attorney Darcel D. Clark today announced that a Bronx woman has been sentenced for stealing over $100,000 in Human Resources Administration (HRA) benefits and Supplemental Nutrition Assistance Program (SNAP) benefits. 

 District Attorney Clark said, “Throughout the years the defendant illegally collected funds, her husband was working for the New York City Fire Department and the New York City Department of Sanitation. The defendant also failed to disclose that she was working at Domino’s Pizza. She stole money that is meant to help those in the most vulnerable situations.” 

 District Attorney Clark said the defendant, Eleana Marrero, 32, of Westchester Avenue, Bronx, N.Y., was sentenced today to five years’ probation, was ordered to pay back $30,000 in restitution and received a $86,963 judgement order of restitution by Bronx Supreme Court Justice Linda Poust-Lopez. Marrero pleaded guilty to first-degree Falsifying Business Records on December 18, 2019. 

 According to the investigation, between May 2014 and May 2017, the defendant lied about her income in City of New York HRA and SNAP benefit applications and recertifications. In the paperwork, Marrero did not disclose her husband’s income, who was a City of New York employee for the FDNY and the NYC Department of Sanitation. The defendant also lied about her income by failing to disclose in applications that she was employed by Domino’s Pizza. Marrero stole $39,590.43 in welfare cash assistance, $22,736 in SNAP benefits and $54, 636.74 in Medicaid benefits, totaling $116,963.17 in stolen funds.

 District Attorney Clark also thanked Investigator Nyah Paul of the New York State Office of the Welfare Inspector General.

Statement from Senator Rivera on the Composition of the Medicaid Redesign Team II

 "I continue to be greatly concerned about the recommendations the Medicaid Redesign Team II will be making given that there are serious gaps in the representation of the membership and the unrealistic timeline outlined by the administration. While the team that was announced today includes respected members of the health care industry, it leaves key players and sectors that are a critical to our health care delivery system out of the decision making process, most notably safety net providers, like NYC Health +Hospitals and Federally Qualified Health Centers, actual medical providers, pharmacists, and consumer representatives. The goal of Medicaid is to provide health care to New Yorkers who can´t afford to pay for it. You would think that it would be critical to include those providing a significant part of that care in a conversation on how to redesign the program."

State Senator Gustavo Rivera is the Chair of the State Senate Health Committee.

STATE OF THE CITY 2020: MAYOR DE BLASIO AND CHANCELLOR CARRANZA ANNOUNCE ACCELERATED EXPANSION OF 3-K FOR ALL

City will now serve 26,000 three-year-olds across all five boroughs in 2020-21 school year

 As part of the Mayor’s 2020 State of the City address, Mayor de Blasio and Schools Chancellor Richard A. Carranza are announcing that 3-K is expanding to Districts 1 (Chinatown, East Village, Lower East Side) and 14 (Greenpoint, Williamsburg) in the Fall, bringing the total number of Districts to 16, spanning every borough across the City. In the Fall of 2020, 3-K will also expand to Districts 12 (Central Bronx) and 29 (Cambria Heights, Hollis, Laurelton, Queens Village, Springfield Gardens, St. Albans) as announced in 2018. 3-K and Pre-K applications open today.

Through this expansion, 3-K for All will serve 26,000 children citywide for the 2020-21 school year. This includes all 3-year-old children served citywide in Head Start and Child Care programs, which transferred from ACS to management by the DOE this summer to create a single early childhood system for families.

"Every family should be able to give their child the world, and expanding 3-K will help us set even more of our students on the path to success,” said Mayor Bill de Blasio. “3-K and Pre-K for All are unlocking the potential of every child and creating more opportunity for families.” 

"I'm so excited to make 3-K bigger and better than ever this fall, serving a total of 16 districts and up to 26,000 three year olds. We know that the City's youngest learners and their families benefit tremendously from getting in the classroom earlier, and I thank Mayor de Blasio for his leadership and support in growing early childhood education each year,” said Chancellor Richard A. Caranza.

3-K for All is the nation’s most ambitious effort to provide universal, free, full-day, high-quality early childhood education for every three-year-old child, and builds on the success of Pre-K for All. Research has found every dollar invested in high-quality early education saves taxpayers as much as $13 in the long-term.

These districts were selected based on need and space availability, and builds on the Mayor’s commitment to early childhood education. Each year, the City has outpaced its planned growth—originally, 3-K was expanding to only 8 districts by Fall 2020.

With this increased commitment, the full schedule for 3-K expansion is: 

·    2017-18: District 7 (South Bronx) and District 23 (Brownsville)

·   2018-19: District 4 (East Harlem), District 5 (Harlem), District 16 (Bedford-Stuyvesant), and District 27 (Broad Channel, Howard Beach, Ozone Park, Rockaways)

·   2019-20: District 6 (Washington Heights and Inwood), District 8 (Country Club, Pelham Bay, Throgs Neck, Castle Hill, Soundview, Hunts Point), District 9 (Grand Concourse, Highbridge, Morrisania), District 19 (East New York), District 31 (Staten Island), and District 32 (Bushwick)

·   2020-21: District 1 (Chinatown, East Village, Lower East Side), District 12 (Central Bronx), District 14 (Greenpoint, Williamsburg), and District 29 (Cambria Heights, Hollis, Laurelton, Queens Village, Springfield Gardens, St. Albans)

The application for 3-K opens today, Wednesday February 5, and will remain open until Friday, April 24. Families in these new districts will be notified as new program options are added to the application, and they will be able to update their application at any time before submitting. Families can find programs and apply online at MySchools.nyc. Families can also apply over the phone at 718-935-2009, or in person at a Family Welcome Center. The online application is available in ten languages, and families can submit an application over the phone or in person in over 200 languages. All New York City families with children born in 2016 can apply for pre-K, and all families with children born in 2017 can apply for 3-K in the 2020-21 school year.

3-K and pre-K enrollment specialists – experts on sites across each neighborhood – will also be available to help families throughout the process as they find a program that best fits their child’s needs. 

Pre-K for All and 3-K for All are part of the Mayor and Chancellor’s Equity and Excellence for All agenda, which is building a pathway to success in college and careers for all students. 3-K for All and Pre-K for All are strengthening foundational skills and instruction earlier; Universal Literacy is working towards ensuring every student is reading on grade level by the end of 2nd grade; and Algebra for All is improving elementary- and middle-school math instruction and ensuring that all 8th graders have access to algebra. Equity and Excellence for All is also offering students more challenging, hands-on, college and career-aligned coursework – Computer Science for All brings 21st-century computer science instruction to every school, and AP for All is giving all high school students access to at least five Advanced Placement courses. Along the way, they are giving students and families additional support through College Access for All, Single Shepherd, and investment in Community Schools. Efforts to create more diverse and inclusive classrooms, outlined in the 2017 New York City school diversity plan and through diversity pilots taking root in eight districts, are central to this pathway.

News From Congressman Eliot Engel

Engel Leads New York City Delegation to Protect Public Health Preparedness Program

 Congressman Eliot L. Engel led the entire New York City Congressional Delegation on a letter to the Assistant Secretary for Preparedness and Response (ASPR) about changes to the Hospital Preparedness Program (HPP), which could affect the City’s ability to respond to public health threats.

“Having a robust public health infrastructure is critical to protecting the City from 21^st century health threats,” said Rep. Engel. “The Hospital Preparedness Program provides crucial resources to support these efforts. Any changes to program need to account for the complex and unique threats that urban centers like New York City face.”

“The Assistant Secretary for Preparedness and Response must explain what methodology led to a cut to New York City’s Hospital Preparedness Program funding,” said New York City Health Commissioner Dr. Oxiris Barbot. “Coordination between public health departments and the health care system is critical for public health emergency response. As we are learning from the current coronavirus outbreak, the only way to prevent another outbreak is to maintain vigilance—and if you start cutting the budget, the cost down the road will be even greater. We look forward to working with Representative Engel and the New York City delegation on this important issue.”

HPP is the only source of federal funding for helping health care systems prepare and respond to complex health threats, including natural and man-made incidents. In 2019, ASPR proposed changes to HPP’s grant formula which could eliminate nearly 5% of the City’s HPP dollars, affecting local hospitals such as Montefiore Hospital-Wakefield Campus. This letter seeks additional information about ASPR’s changes to HPP.

Congressman Engel has been a long-time proponent of HPP. On June 4, 2019, he supported passage of the Pandemic and All-Hazards Preparedness and Advancing Innovation Act, which was signed into law and provides $385 million annually for HPP over the next five years. Engel is a member of the House Energy and Commerce Committee’s Health Subcommittee.

ENGEL STATEMENT ON THE END OF SENATE REPUBLICANS’ SHAM TRIAL

Representative Eliot L. Engel, Chairman of the House Committee on Foreign Affairs, today made the following statement:

“There’s no such thing as an acquittal when you don’t have a real trial. The Senate’s sham process was nothing more than an extension of the President’s coverup. Today’s vote was the ultimate demonstration that the Party of Lincoln has become the Party of Trump, and that for Republican lawmakers—with one courageous exception—there’s no duty or oath higher than showing loyalty to this President.

“The evidence is overwhelming that the President deserved to be impeached and removed. His abuse of power was blatant. His obstruction of a legitimate congressional inquiry was unprecedented; not even Richard Nixon went so far. There can be no justification for his actions. Those who voted not to remove him acted out of sheer partisanship and did damage to the institutions that underpin our democracy.

“Despite the Senate Republicans’ near total abdication of their responsibility, the House will not go along with the notion that this President is above the law. The Foreign Affairs Committee will push ahead with our oversight efforts to hold this administration accountable and to demonstrate to the American people that some of us in Washington still believe in the Constitution and the rule of law.”

Partnerships for Parks - Bronx News Blast-February

Partnerships for Parks is turning 25 this year!

Since 1995, PfP has been working side-by-side with communities across New York City to sustain parks through greening, beautifying, and programming. Join us to celebrate our 25th anniversary and envision the future at one of our upcoming events. The schedule will be available shortly on our website. Please sign up for our newsletter, and follow us on Facebook, Instagram, and Twitter for updates. Share your own photos with us using the hashtag #wearepfp.

NEW YORK CITY REPORTS SECOND AND THIRD PERSON UNDER INVESTIGATION FOR NOVEL CORONAVIRUS

A second and third person in New York City met the criteria to have samples sent to the Centers for Disease Control and Prevention (CDC)

Both individuals, who are currently hospitalized, had recently been in mainland China

The Health Department is educating health care providers and community members about the coronavirus outbreak as the situation evolves

 Two additional people in New York City have been identified for testing for the novel coronavirus. Both individuals, who are over 60-years-old, had recently been in mainland China and presented with fever and cough or shortness of breath without another common cause, like influenza and other cold viruses, identified on testing. The first individual has been hospitalized at Flushing Hospital Medical Center. The second is hospitalized a New York-Presbyterian Queens. Both are in stable condition. Testing to determine whether these are confirmed cases of the novel coronavirus will take a minimum of 36-48 hours and depends on CDC testing capacity. 

“With the best public health system in the world, New York City stands ready to respond to any confirmed cases of the coronavirus,” said Mayor Bill de Blasio. “I urge all New Yorkers to remain vigilant, and if you or anyone you know matches the criteria and have recently traveled to the affected areas of China, please see a medical professional.”

“We are continuing to work closely with our partners at the CDC, State and federal government as the coronavirus situation evolves,” said Health Commissioner Dr. Oxiris Barbot. “If you have traveled to the area affected by the outbreak in the last 14 days and feel unwell, call your doctor or visit a clinic, and you will be cared for. Also, practice everyday precautions like you would during flu season—wash your hands frequently, and cover your mouth and nose when you sneeze. We remain grateful to all New Yorkers for their cooperation.”

There are now eight confirmed cases in the United States and over 14,000 worldwide. At least 300 people have died. The first person under investigation for the novel coronavirus in New York City remains at Bellevue Hospital and in stable condition. The Health Department has not received results of the CDC test, and will share information about the test as soon as the results are provided.

Cases under investigation should not be presumed as likely to be confirmed. As of Friday, January 31—the latest available national numbers from CDC on cases under investigation—only six of the 120 specimens tested were identified as novel coronavirus.

The novel (new) coronavirus is a strain of coronavirus that has not been previously detected in humans. This novel coronavirus can lead to symptoms of fever, cough or shortness of breath. While some infections have resulted in severe illness, and even death, others have presented with milder symptoms and been discharged from care. 

The Health Department is continuing to monitor the evolving worldwide situation daily, including the latest data on transmissions, incubation, new cases, and guidance. The Department has distributed educational materials so that people have the facts about how to protect themselves and their families, what to do if they feel unwell and have a travel history to affected areas, and other important information about this disease. The Health Department has conducted outreach and is providing guidance to local community-based organizations and health care providers serving our communities to inform them of the necessary precautions they need to take if someone with symptoms of coronavirus visits them.

For those who feel sick with fever, cough, or difficulty breathing, and traveled to Hubei province China—or been in contact with a confirmed case novel coronavirus—within 14 days of symptom onset, the CDC recommends:

Seek medical care right away. Before going to a doctor’s office or emergency room, call ahead and tell them about recent travel and symptoms.

Avoid contact with others.

Do not travel while sick.

Cover mouth and nose with a tissue or your sleeve (not hands) when coughing or sneezing.

Wash hands often with soap and water for at least 20 seconds. Use an alcohol-based hand sanitizer if soap and water are not available.

For more information about the coronavirus, visit the Heath Department website at nyc.gov/health.

Iranian National Charged With Bank Fraud And Lying To Federal Agents In Connection With A Scheme To Use The U.S. Financial System To Send More Than $115 Million To Iranian Individuals And Entities

  Geoffrey S. Berman, United States Attorney for the Southern District of New York, John C. Demers, Assistant Attorney General for National Security, Cyrus R. Vance Jr., New York County District Attorney, and William F. Sweeney Jr., Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of Investigation (“FBI”), announced today that BAHRAM KARIMI was charged with conspiring to commit bank fraud, bank fraud, and making false statements in connection with his involvement in a joint project initiated by the Governments of Iran and Venezuela in which more than $115 million was illegally funneled through the U.S. financial system for the benefit of various Iranian individuals and entities.  The case is assigned to U.S. District Judge Alison J. Nathan. 

Manhattan U.S. Attorney Geoffrey S. Berman said:  “As alleged, Bahram Karimi knowingly and willfully facilitated the circumventing of sanctions against Iran, and then lied about it to FBI agents.  Karimi allegedly enabled the concealed transfer through U.S. banks of more than $100 million from a Venezuelan state-owned company to an Iranian construction firm, and when questioned, told the agents he didn’t know that was prohibited by the sanctions.”

FBI Assistant Director William F. Sweeney Jr. said:  “At the end of the day, these charges reflect the use of our financial system to generate U.S. dollars for Iranians and Iranian entities.  That’s why our government has robust sanctions in place against Iran and Iranian entities who seek to use the U.S. banking system for their own benefit.”

As alleged in the Superseding Indictment and statements made in court filings and proceedings[[1]]:

In August 2004, the Governments of Iran and Venezuela entered into a Cooperation Framework Agreement, whereby they agreed to cooperate in certain areas of common interest.  The following year, both governments supplemented the Cooperation Framework Agreement by entering into a Memorandum of Understanding regarding an infrastructure project in Venezuela (the “Project”), which was to involve the construction of thousands of housing units in Venezuela. 

The Project was led by Stratus Group, an Iranian conglomerate with international business operations in the construction, banking, and oil industries.  In December 2006, Stratus Group incorporated a company, which was then known as the Iranian International Housing Corporation (“IIHC”), in Tehran.  IIHC was responsible for construction for the Project.  Thereafter, IIHC entered into a contract with a subsidiary of a Venezuelan state-owned energy company (the “VE Company”), which called for IIHC to build approximately 7,000 housing units in Venezuela in exchange for approximately $475,734,000.  Stratus Group created the Venezuela Project Executive Committee to oversee the execution of the Project.  KARIMI was a member of the committee and was responsible for managing the Project in Venezuela.

In connection with his role on the Project, KARIMI worked with others to defraud U.S. banks by concealing the role of Iranian parties in U.S. dollar payments sent through the U.S. banking system.  Specifically, between April 2011 and November 2013, the VE Company made approximately 15 payments to IIHC through two front companies, which were created to conceal the Iranian nexus to the payments, in violation of U.S. economic sanctions.  These 15 payments totaled approximately $115 million. 

In January 2020, KARIMI was interviewed by, among other people, two FBI agents.  During that interview, KARIMI falsely stated that, during the course of the Project, he believed that international sanctions against Iran did not apply to Iranian companies or persons.

KARIMI, 53, of Canada, is charged with (1) conspiring to commit bank fraud, which carries a maximum sentence of 30 years in prison; (2) bank fraud, which carries a maximum sentence of 30 years in prison; and (3) making false statements, which carries a maximum sentence of five years in prison.  The maximum potential sentences in this case are prescribed by Congress and are provided here for informational purposes only, as any sentencing of the defendant will be determined by the judge.

Mr. Berman and Mr. Demers praised the outstanding investigative efforts of the New York County District Attorney’s Office and the FBI.  Mr. Berman also thanked the New York County District Attorney’s Office for their ongoing assistance in this investigation.

The charges contained in the Superseding Indictment are merely allegations, and the defendant is presumed innocent unless and until proven guilty.

[1] As the introductory phrase signifies, the entirety of the text of the Superseding Indictment and the description of the Superseding Indictment and statements and filings in court set forth herein, constitute only allegations, and every fact described herein should be treated as an allegation as to the defendant charged in the Superseding Indictment.