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ApprovedBOYD
M.
JOHNSON I11RITA GLAVINDANIEL STEINAssistant United States AttorneysBefore: HONORABLE RONALD L. ELLISUnited States Magistrate JudgeSouthern District of New York
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0463
ALED COMPLAINTUNITED STATES OF AMERICAMARK BRENER,a/k/a "Michael,CECIL SUWAL,a/k/a "Katie,a/k/a "Kate,TEMEKA RACHELLE LEWIS,a/k/a "Rachelle, andTANYA HOLLANDER,a/k/a "Tania Hollander,"Violations of18 U.S.C.
§§
371, 1952,2421, 2422, 1956COUNTY OF OFFENSE:NEW YORKDefendants.SOUTHERN DISTRICT OF NEW YORK, ss.:KENNETH HOSEY, being duly sworn, deposes and says thathe is a Special Agent with the Federal Bureau of Investigation,and charges as follows:COUNT ONE1.' From in or about December 2004 to in or aboutMarch 2008, in the Southern District of New York and elsewhere,MARK BRENER, a/k/a "Michael," CECIL SUWAL, a/k/a "Katie," a/k/a"Kate, TEMEKA RACHELLE LEWIS, a/k/a "Rachelle, and TANYAHOLLANDER, a/k/a "Tania HollanderIN he defendants, and othersknown and unknown, unlawfully, willfully, and knowingly didcombine, conspire, confederate, and agree together and with eachother to violate Sections 1952 (a)
3),
2421, and 2422 (a) of Title18, United States Code.
2. It was a part and an object of the conspiracy thatMARK BRENER, a/k/a "Michael," CECIL SUWAL, a/k/a "Katie," a/k/a"Kate," TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," and TANYAHOLLANDER, a/k/a "Tania Hollandert1I he defendants, and othersknown and unknown, would and did use and cause to be usedfacilities in interstate commerce, to wit, cellular telephonesand e-mail, with intent to promote, manage, establish, and carryon, and to facilitate the promotion, management, establishmentand carrying on of an unlawful activity, to wit, a businessenterprise involving prostitution offenses in violation ofapplicable State law, and thereafter did perform and attempt toperform an act to promote, manage, establish, and carry on and tofacilitate the promotion, management, establishment, and carryingon of said unlawful activity, in violation of Title 18, UnitedStates Code, Section 1952 (a) 3).3. It was a further part and an object of theconspiracy that MARK BRENER, a/k/a "Michael," CECIL SUWAL, a/k/a"Katie," a/k/a "Kate," TEMEKA RACHELLE LEWIS, a/k/a "Rachelle,"and TANYA HOLLANDER, a/k/a "Tania Hollander," the defendants, andothers known and unknown, unlawfully, willfully and knowinglywould and did transport individuals in interstate and foreigncommerce with intent that such individuals engage inprostitution, and in sexual activity for which a person can becharged with a criminal offense, in violation of Title 18, UnitedStates Code, Section 2421.4. It was a further part and an object of theconspiracy that MARK BRENER, a/k/a "Michael," CECIL SUWAL, a/k/a"Katie," a/k/a "Kate," TEMEKA RACHELLE LEWIS, a/k/a "Rachelle,"and TANYA HOLLANDER, a/k/a "Tania Hollander,I1 the defendants, andothers known and unknown, unlawfully, willfully and knowinglywould and did persuade, induce, entice, and coerce individuals totravel in interstate and foreign commerce to engage inprostitution and in sexual activity for which a person can becharged with a criminal offense, in violation of Title 18, UnitedStates Code, Section 2422 (a).Overt Acts
5.
In furtherance of said conspiracy and to effectthe illegal objects thereof, the following overt acts, amongothers, were committed in the Southern District of New York andelsewhere:a. From in or about December 2004 through in orabout March 2008, MARK BRENER, a/k/a 'Michael," and CECIL SUWAL,a/k/a "Katie, a/k/a "Kate, the defendants, controlled a website
located at URL
www.emperorsclubvip.com.
that included photographsof prostitutesf bodies, with their heads hidden, along withhourly rates for different categories of prostitutes;b. From in or about December 2004 through in orabout at least January 2008, MARK BRENER, a/k/a "Michael," andCECIL SUWAL,a/k/a "Katie," a/k/a "Kate," the defendants,received applications from women seeking to work as prostituteswith their prostitution business (hereinafter, the "EmperorsClub") at various e-mail accounts;c. On or about January
9,
2008, MARK BRENER,a/k/a "Michael, CECIL SUWAL, a/k/a "Katie, a/k/a "Kate, andTEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendants, spokeover the telephone about offering the Emperors Club's clients theopportunity to exercise a "buyout clause," which would permitclients to purchase direct access to one of the Emperors Club'sprostitutes without having to contact the agency;
d.
On or about January 15, 2008, TEMEKA RACHELLELEWIS, a/k/a "Rachelle," the defendant, spoke with a client ofthe Emperors Club over the telephone about arranging f0r.aprostitute to come to his room at a hotel in New York, New York;e. On or about January 15, 2008, a prostituteworking with the Emperors Club went to aclient's hotel in New
'
York, New York;f. On or about January 18, 2008, TEMEKA RACHELLELEWIS, a/k/a "Rachelle," the defendant, spoke over the telephonewith a new prostitute working with the Emperors Club who toldLEWIS that she had never "done anything like this before" and wasa "little bit nervous about it";g. On or about January 18, 2008, CECIL SUWAL,a/k/a "Katie," a/k/a "Kate," the defendant, sent an e-mail to apotential prostitute asking her to send photographs of herself toSUWALh. On or about January 22, 2008, TEMEKA RACHELLELEWIS, a/k/a "Rachelle," the defendant, told an Emperors Clubclient that he should not be concerned about sending a wiretransfer to the Emperors Club because the wire would be sent to"QAT Consulting" so it would show up "like as a businesstransaction";
i.
On or about January 24, 2008, a prostituteworking with the Emperors Club went to a hotel in Los Angeles,
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