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Redacted Complaint Against Emperors Club VIP

Redacted Complaint Against Emperors Club VIP

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Published by Linden Row
Redacted text of Federal Complaint/Affidavit against Owners of the Emporers Club VIP
Redacted text of Federal Complaint/Affidavit against Owners of the Emporers Club VIP

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Published by: Linden Row on Mar 11, 2008
Copyright:Attribution Non-commercial

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09/28/2012

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Redacted complaint against Emperors Club VIP. Read more onThe Linden Row 
UNITED STATES OF AMERICAViolations of 18 U.S.C. §§ 371, 1952,2421, 2422, 1956MARK BRENER,a/k/a "Michael, " COUNTY OF OFFENSE:CECIL SUWAL, NEW YORK8a/k/a "Katie, "a/k/a "Kate, "TEMEKA RACHELLE LEWIS,a/k/a "Rachelle, "andTANYA HOLLANDER,a/k/a "Tania Hollander,"Defendants.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 the defendants, and othersknown and unknown, unlawfully, willfully, and knowingly didcombine, conspire, confederate, and agree together and with each
 
other 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 the 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 of applicable 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 Acts5. 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

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