RB:MMS:TKF. #2011R02156UNITED STATES DISTRICT COURTEASTERN DISTRICT OF NEW YORK- - - - - - - - - - - - - - - - - X UNITED STATES OF AMERICACOMPLAINT- against- (18 U.S.C. § 1343)JIMMY MENG,Defendant.- - - - - - - - - - - - - - - - - XEASTERN DISTRICT OF NEW YORK, SS:AMY M. HIRINA, being duly sworn, deposes and says thatshe is a Special Agent with the Federal Bureau of Investigation(“FBI”), duly appointed according to law and acting as such.Upon information and belief, there is probable cause tobelieve that in or about and between December 2011 and July 2012,both dates being approximate and inclusive, within the EasternDistrict of New York and elsewhere, the defendant JIMMY MENG,having devised a scheme and artifice to defraud, and to obtainmoney and property by means of materially false and fraudulentpretenses, representations and promises, did knowingly andintentionally transmit and cause to be transmitted by means ofwire communication in interstate commerce, writings, signs,
signals, pictures and sounds for the purpose of executing suchscheme and artifice.(Title 18, United States Code, Section 1343).The source of your deponent’s information and thegrounds for her belief are as follows:1.I have been a Special Agent with the FBI forapproximately seven years. The facts set forth in this affidavitare based on interviews with a cooperating witness (the “CW”),consensual recordings, information obtained from the review ofdocuments, and information obtained from others in lawenforcement who participated in the investigation detailed below.2.Because the purpose of this complaint is to setforth only those facts necessary to establish probable cause, Ihave not described all of the relevant facts and circumstances ofwhich I am aware. In addition, when I rely on statements made byothers, such statements are set forth in part and in substanceunless otherwise indicated.Background3.The CW was indicted by the New York CountyDistrict Attorney’s Office (“Manhattan DA”) in approximately June2011 for tax offenses.
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The CW is cooperating with the federal government in hopes
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of receiving a benefit in his/her pending state case. On July2
4.The CW informed the FBI that following hisindictment:(a) The CW told his/her friends that the ManhattanDA had offered the CW a plea agreement whereby the CW wouldreceive a sentence of two to six years and that the Manhattan DAdid not want to negotiate with the CW’s lawyer for a lessersentence. The CW’s friends recommended that s/he speak to thedefendant JIMMY MENG, a former Queens assemblyman and owner of alumber yard in Flushing, Queens, about helping the CW obtain alower plea offer from the Manhattan DA.(b)On or about December 8, 2011, the CW calledMENG to discuss the CW’s case and MENG asked the CW to fax himthe index number of the CW’s indictment.(c)On or about December 9, 2011, the CW met MENGat MENG’s lumber yard to discuss how the CW could get a betterplea offer from the Manhattan DA. MENG told the CW that MENGneeded approximately two weeks to find out more about the CW’scase.20, 2012, the CW pled guilty in this district, pursuant to acooperation agreement, to an information charging bank fraud inviolation of Title 18, United States Code, Section 1344. The CWalso intends to plead guilty to the CW’s pending tax charges inNew York County.3
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