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INDICTMENT
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SUP REM EC 0 U R TO F THE S TAT E 0 F NEW Y 0 R K
COUNTYOFKINGS
. J. BORIS SHTEYNGART
DEFENJ)ANT
INJ)ICTMENT NO. 8852/20 1
SUPERSEDING INDICTM T
NO. 9493/2010
DOCKET NO. 2011KN07754
THR PEOPLÉOF THl STATE OF NEW YORK
-AGAINST-
NON-ALIGNEDRACKETS DIVISION
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COUNTS:
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GRAND LARCENY ÍN THE SECOND DEGREE
SCHEME TO DEFRAUD IN THE FI~ST DEGREEATTEMPTED GRAND LARCENY IN THE THIRD DEGREE
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,( COUNT)
(1 COUNT)
,(4 COuNTS)(l COUNT)
GRAND LARCENY IN THE THIRD DEGREE
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CRIMINAL POSSESSION OF A FORGED INST~UMENT IN
THE SECOND DEG~E
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(2 COuNTS)
FORGERY IN THE SECOND DEGREE
. CRIMINAL IMPERSONATION IN THE SECOND uEÚREE
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:(2 COUNTS)
(4 COUNTS)FRAUDULENT PRACTICE ÍN RESPECT TO A STOCK, BOND
AND OTHER SECURITIES
(15 COUNTS)
ATTEMPTED FRAUDULENT PRACTICE IN RESPECT TO A
STOCK, BOND ANO OTHE~SECUlUTIES
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C:¡ S i\ TRUÉ BILL
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(5 COUNTS)
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CHARLES J. HYNl S
DISTmct ATTORNEY
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COUNT 1:
THE GRAND JURY OF THE COUNTY OF KINGS AND THE STATE OF NEWYORK, BY THIS INDICTMENT ACCUSES THE DEFENDANT, BORISSHTEYNGART, OF THE CRIME OF: GRAND LARCENY IN THE SECOND
DEGREE (PENAL LAW §I55.40(l)J AS COMMITTED AS FOLLOWS:
THE DEFENDANT, ON OR ABOUT AND BETWEEN APRIL 15,2010 AND JUNE 1,
2010, IN THE COUNTY OF KINGS AND THE STATE OF
NEW YORK, AS PART
OF AN ONGOING COURSE OF CONDUCT AND PURSUANT TO A COMMONPLAN AND SCHEME, STOLE PROPERTY, NAMELY: UNITED STATES
CURRNCY, VALUED IN EXCESS OF FIFTY THOUSAND DOLLARS ($50,000),
FROM KENNETH ROWAN.
COUNT
2:
THE GRAND JURY OF THE COUNTY OF KINGS AND THE STATE OF NEWYORK, BY THIS INDICTMENT ACCUSES THE DEFENDANT, BORISSHTEYNGART, OF THE CRIME OF: GRAND LARCENY IN THE THIRD DEGREE
(PENAL LAW § I55.35J AS COMMITTED AS FOLLOWS: i
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HE DEFENDANT, ON OR ABOUT AND BETWEENAPRIL I5,¡2qi~ AND JUNE 1,
2010, IN THE COUNTY OF KINGS AND THE STATE OF
NEW YORK, AS PARTOF AN ONGOING COURSE OF CONDUCT AND PURSUANT TO A COMMONPLAN AND SCHEME, STOLE PROPERTY, NAMELY: UNITED STAtES i'
CURRNCY, VALUED IN EXCESS OF THREE THOlfSAND DaLtARS ($3,000),
FROM KENNETH
ROWAN. ' ,
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COUNT 3:
THE GRAND JURY OF THE COUNTY OF KINGS AND THE STATE OF NEWYORK, BY THIS INDICTMENT ACCl)SES THE DEFENDANT, BORISSHTEYNGART, OF THE CRIME OF: CRIMINALIMPERSONATIQN IN THE
SECOND DEGREE (PENAL LAW §I90.25(2)J AS1 ÇOMMITTED AS FOLLOWS:
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THE DEFENDANT, ON OR ABOUT AND BETWEEN APRIL 15,2010 AND JUNE 1,2010, IN THE COUNTY OF KINGS AND THE STATE OF NEW YORK,PRETENDED TO BE A REPRESENTATIVE OF SOME PERSON AND
ORGANIZATION, AND DID AN ACT IN SUCH
PRETENDED Cf\PAÇITY WITH
INTENT TO OBTAIN A BENEFIT OR TO INJURE OR DEFRAUD ANOTHER,NAMEL Y: THE DEFENDANT PRETENDED TO ßE A REPRESENTATIVE OF S.GOLDMAN ADVISORS IN A WRITTEN CORRESPONDENCE SENT TOKENNETH ROWAN, WHILE HAVING THE INTENT TO OBTAIN MONIES FROMKENNETH ROWAN AND TO INJURE AND DEFRAUD KENNETH ROWAN.
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COUNT
4:
THE GRAND JURY OF THE COUNTY OF KINGS AND THE STATE OF NEWYORK, BY THIS INDICTMENT ACCUSES THE DEFENDANT, BORISSHTEYNGART, OF THE CRIME OF: CRIMINAL IMPERSONATION IN THE
SECOND DEGREE (PENAL LAW § 1 90.25(2) J AS COMMITTED AS FOLLOWS:
THE DEFENDANT, ON OR ABOUT AND BETWEEN APRIL 15,2010 AND JUNE 1,
2010, IN THE COUNTY OF KINGS AND THE STATE OF NEW YORK,
PRETENDED TO BE A REPRESENT
A TIVE OF SOME PERSON AND
ORGANIZATION, AND DID AN ACT IN SUCH PRETENDED CAPACITY WITHINTENT TO OBTAIN A BENEFIT OR TO INJURE OR DEFRAUD ANOTHER,NAMEL Y: THE DEFENDANT PRETENDED TO BE A REPRESENTATIVE OF S.
GOLDMAN ADVISORS IN AN ORAL COMMUNICATION WITH KENNETH
ROWAN, WHILE HAVING THE INTENT TO OBTAIN MONIES FROM, AND TO
INJURE AND DEFRAUD KENNETH ROWAN.
COUNT 5:
THE GRAND JURY OF THE COUNTY OF KINGS AND THE STATE OF NEW
YORK, BY THIS INDICTMENT ACCUSES THE
DEFENDANT, BORlS
SHTEYNGART, OF THE CRIME OF: SCHEMETO DEFRAUD IN tHE FIRST
1
EGREE (PENAL LAW §I90.65(I)(B)J AS COMMITTED
AS
FOLLOWS:
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THE DEFENDANT, ON OR ABOUT AND BETWEEN JANUARY 9, 2009 AND
SEPTEMBER 27, 2011, IN THE COUNTY OF KINGS AND THE STATE OF NEW
YORK, ENGAGED IN A SCHEME CONSTITUTING A SYSTEMATIC ONGOINGCOURSE OF CONDUCT WITH INTENT TO DEFRAUD MORE THAN ONE
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PERSON, AND TO OBTAIN PROPERTY FROrv ¥ORE THAN ONE PERSON BY
FALSE OR FRAUDULENT PRETENSES, REPRE:St:NTATIONS .çNDPROMISES,AND SO OBTAINED PROPERTY WITH A VALUE IN EXCESS OF OWE
THOUSAND DOLLARS FROM ONE OR MOiz SUCH PERSONS. I ,
COUNT
6:
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THE GRAND JURY OF THE COUNTY OF KINGS AND THE STATE OF NEW
YORK, BY THIS INDICTMENT ACCUSES THE DEFENDANT, BqRIS.
SHTEYNGART, OF THE CRIME OF: GRAND LARCENY IN THE THIRD DEGREE
(PENAL LAW §I55.35J AS COMMITTED AS F~tLOWS: i':, :
THE DEFENDANT ON OR ABOUT AND BETWEEN APRIL 16,2010 ,AND APRIL
14,2011, IN THE COUNTY OF KINGS AND THEiSTATEOF,NEW YOtRK, AS
PART OF AN ONGOING COURSE OF CONDUCT AND PURSUANT. 0 A
COMMON PLAN AND SCHEME, STOLE PROPERTY, NAMELY: UNITED
STATES CURRNCY, VALUED IN EXCESS OF
THREE THOU~ANI?i DOLLARS
( 3,000) FROM ROBERT THOMPSON. ' ,i I
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