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Nahum compl1

Nahum compl1

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Published by SHIFrankel
2 N.J. Mayors, Several Rabbis Arrested: Feds arrest mayors of 2 NJ cities, lawmaker in broad corruption
2 N.J. Mayors, Several Rabbis Arrested: Feds arrest mayors of 2 NJ cities, lawmaker in broad corruption

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Published by: SHIFrankel on Jul 23, 2009
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07/23/2009

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UNITED STATES DISTRICT COURTDISTRICT OF NEW JERSEY
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UNITED STATES OF AMERICA:
CRIMINAL COMPLAINT
v. :EDMOND NAHUM :Mag. No. 09-3611I, Robert J. Cooke, being duly sworn, state that the following is true and correct to thebest of my knowledge and belief.From in or about June 2007 to in or about December 2008, in Monmouth County, in theDistrict of New Jersey, and elsewhere, defendant EDMOND NAHUM did:
knowingly and willfully conspire with others to conduct and attempt to conduct financialtransactions involving property represented to be the proceeds of specified unlawful activity,specifically, bankruptcy fraud, bank fraud and trafficking in counterfeit goods, with the intent toconceal and disguise the nature, location, source, ownership, and control of the property believedto be proceeds of specified unlawful activity, contrary to Title 18, United States Code, Section1956(a)(3).
 In violation of Title 18, United States Code, Section 1956(h).I further state that I am a Special Agent with the Federal Bureau of Investigation, and that thiscomplaint is based on the following facts:SEE ATTACHMENT Acontinued on the attached page and made a part hereof._______________________________Robert J. Cooke, Special AgentFederal Bureau of InvestigationSworn to before me and subscribed in my presence,July , 2009, at Newark, New JerseyH
ONORABLE
M
ADELINE
C
OX
A
RLEO
________________________________U
NITED
S
TATES
M
AGISTRATE
J
UDGE
Signature of Judicial Officer
 
1
Attachment AI, Robert J. Cooke, a Special Agent with the Federal Bureauof Investigation (“FBI”), following an investigation anddiscussions with other law enforcement officers, am aware of thefollowing facts. Because this Attachment A is submitted for thelimited purpose of establishing probable cause, I have notincluded herein the details of every aspect of thisinvestigation. Nor have I recounted every conversation involvingthe defendant. All conversations referred to in this attachmentwere recorded and are related in substance and in part.1. Defendant Edmond Nahum was the principal rabbi of DealSynagogue, a synagogue located in Deal, New Jersey (hereinafter,“defendant NAHUM”). Defendant NAHUM operated several charitabletax-exempt organizations in conjunction with his synagogue,including one called Deal Kupot and another called Ahabat HaimVehesed. A check with the New Jersey Department of Banking andInsurance and the New York State Department of Banking hasrevealed that defendant NAHUM does not hold a license to transmitor remit money.2. Coconspirator Saul Kassin, a resident of Brooklyn, NewYork,
 
was the Chief Rabbi of Sharee Zion, a synagogue located onOcean Parkway in Brooklyn, New York (hereinafter, “CoconspiratorKassin”).
 
Coconspirator Kassin operated several charitable tax-exempt organizations in conjunction with his synagogue, includingone called, for purposes of this Complaint, “CoconspiratorKassin’s Charitable Organization”. A check with the New JerseyDepartment of Banking and Insurance and the New York StateDepartment of Banking has revealed that Coconspirator Kassin doesnot hold a license to transmit or remit money.3.There was an individual named Eliahu Ben Haim, a/k/a“Eli Ben Haim,” who resided in Elberon, New Jersey, and was theprincipal rabbi of Congregation Ohel Yaacob, a synagogue locatedin Deal (hereinafter, “Ben Haim”). Ben Haim operated severalcharitable tax-exempt organizations in conjunction with hissynagogue, including one called Congregation Ohel Eliahu(hereinafter, “COE”) and another called Friends of Yachave Da’at.A check with the New Jersey Department of Banking and Insuranceand the New York State Department of Banking has revealed thatBen Haim does not hold a license to transmit or remit money.4. At all times relevant to this Complaint, there was acooperating witness (the “CW”) who had been charged in a federalcriminal complaint with bank fraud in or about May 2006.Pursuant to the FBI’s investigation and under its direction, the
 
2
CW from time to time represented that the CW purportedly wasengaged in illegal businesses and schemes including bank fraud,trafficking in counterfeit goods and concealing assets and moniesin connection with bankruptcy proceedings.5. On or about June 15, 2007, defendant NAHUM met with theCW in defendant NAHUM’s office
 
in Deal. During the ensuingconversation, the CW told defendant NAHUM that “I have a checkfor you” from a “guy who owes me money from a while ago - tenthousand.” The CW indicated that the CW wished to make the checkout to Deal Kupot, the charitable organization administered bydefendant NAHUM. The CW made this suggestion with theexpectation that defendant NAHUM would give the CW cash inexchange, thereby hiding assets from the CW’s ongoing bankruptcyproceedings. In response, defendant NAHUM suggested that the CWwrite the check out to another “tax exempt” organization, AhabatHaim Vehesed, which defendant NAHUM had recently created. As theconversation continued, defendant NAHUM indicated that he passedmoney through the Coconspirator Kassin’s Charitable Organization,and described the flow of money between their charitable accountsin the following terms: “of course, back and forth, of course.”When the CW remarked that this was an effective “way to get ridof money,” defendant NAHUM replied “exactly.” Defendant NAHUMdiscussed another individual who had run money through hischaritable organization, Deal Kupot. Defendant NAHUM remarked,however, that this individual’s desire to run $200,000 throughDeal Kupot might draw attention from the Government, and that hewould not allow this individual to cycle that much money throughthis account.6. On or about June 20, 2007, defendant NAHUM met with theCW in defendant NAHUM's
 
office in Deal. During this meeting,defendant NAHUM accepted two bank checks from the CW, each in theamount of $10,000. The first bank check was made payable to DealSynagogue Kupot, defendant NAHUM’s charitable organization. Thesecond bank check was made payable to Coconspirator Kassin’sCharitable Organization. In exchange, the CW asked defendantNAHUM to provide a check made out to a specific corporation thatthe CW described as a “company nobody knows about,” and a checkmade out to COE, the charitable organization operated by BenHaim. The CW indicated that the funds from the checks that theCW was providing represented monies that the CW was owed byanother individual, and that this individual wished to launderthe money through a charitable organization account. The CW alsoinformed defendant NAHUM that “the guy gave it to me because hewants a write off, like everybody else.” Later in theconversation, defendant NAHUM described how he put checks throughCoconspirator Kassin’s Charitable Organization, and would receive

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