PER 18 U.S.C. 3170 DEFENDANT INFORMA nON RELATIVE TO A CRIMINAL ACTION -IN u.s. DISTRICT COURT BY: 0 INFORMATION Il]INDICTMENT .,...--. Matter Sealed: o Juvenile IZI Other than Juvenile USA vs. o Pre-Indictment Plea o Superseding o Defendant Added Defendant: Samuel Cohen (a/kla Mouli .4(\ o Indictment o Charges/Counts Added o Information l' Name of District Court. andlor JudgeiMagistrate Location (City) AdusR 1 0 UNITED STATES DISTRICT COURT Northern DISTRICT OF California Divisional Office /,...".,>." -'\) '/ . Joseph P. Russoniello ':; f Name and Office of Person Furnishing Information on DU.s.Atty DOther U.S, Agency 0 C' Phone No. (415) 436-7200 Interpreter Required Dialect: l Name of Ass!. Alien U.S. Attorney Jeffrey Finigan Birth IZl Male (if assigned) Date 4/8/1958 0 (if applicable) Female PROCEEDING Name of Complainant Agency, or Person (& Title, if any) IRS & FBI Social Security Number 0 person is awaiting trial in another Federal or State Court (give name of court) DEFENDANT IlJ Warrant o Summons Issue: 0 this person/proceeding transferred from another district per (Circle one) FRCrP 20, 21 or 40. Show District Location Status: Arrest Date or Date Transferred to Federal Custody 0 this Is a reproseculion of charges 0 Currently in Federal Custody previously dismissed which were dismissed on motion of: 0 Currently in State Custody D U.S. Atty 0 Defense SHOW o Writ Required 0 this prosecution relates to a DOCKET NO. 0 Currently on bond pending case involving this same D Fugitive defendant. (Notice of Related Case must still be filed with the 0 Clerk.) MAG. JUDGE prior proceedings or appearance(s) CASE NO. Defense Counsel (if any): before U.S. Magistrate Judge regarding this defendant were DFPD o CJA D RET'D recorded under Place of I San Francisco 0 Appointed on Target Letter countySan Francisco offense o This report amends AO 257 previously submitted OFFENSE CHARGED· U.S.C. CITATION· STATUTORY MAXIMUM PENALTIES· ADDITIONAL INFORMATION OR COMMENTS Total # of Counts 32 Set Title & Section/Offense Level Description of Offense Charged Count(s) (Pettv = 1 I Misdemeanor" 31 Felonv = 4) 1 18 USC Section 1343 Wire Fraud 1 -19 2 18 USC Section 1957 Money Laundering 20- 32 (cts 1 - 19: 20 yrs BOP; $250,000 fine; (cts 20 - 32: 10 yrs BOP; $250,000 fine or twice amount 3 yrs supervised release; of criminally derived property; 3 yrs suprevised release; $100 assessment) $100 assessment)
Mouli Cohen Criminal Indictment dated July 15, 2010
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PER 18 U.S.C. 3170
DEFENDANT INFORMA nON RELATIVE TO A CRIMINAL ACTION -IN u.s. DISTRICT COURT
BY: 0 INFORMATION Il]INDICTMENT .,...--.
Matter Sealed: o Juvenile IZI Other than Juvenile USA vs.
o Pre-Indictment Plea o Superseding o Defendant Added Defendant:
Samuel Cohen (a/kla Mouli Co~) .4(\ o Indictment o Charges/Counts Added '~~.p ~ o Information ".{.f,~ ~ l'
Name of District Court. andlor JudgeiMagistrate Location (City) AdusR 1 0 o§~i~ ~
UNITED STATES DISTRICT COURT Northern DISTRICT OF California Divisional Office
/,...".,>." -'\) '/ -c'~- ~ ,~.,~~\ .
Joseph P. Russoniello -'c:./:'~t1- ':; f Name and Office of Person Furnishing Information on DU.s.Atty DOther U.S, Agency 0 ~O C'
Name of Complainant Agency, or Person (& Title, if any)
IRS & FBI Social Security Number
0 person is awaiting trial in another Federal or State Court (give name of court) DEFENDANT
IlJ Warrant o Summons Issue:
0 this person/proceeding transferred from another district per (Circle one) FRCrP 20, 21 or 40. Show District
Location Status:
Arrest Date or Date Transferred to Federal Custody
0 this Is a reproseculion of charges 0 Currently in Federal Custody previously dismissed which were dismissed on motion of: 0 Currently in State Custody D U.S. Atty 0 Defense
SHOW o Writ Required
0 this prosecution relates to a DOCKET NO. 0 Currently on bond pending case involving this same D Fugitive defendant. (Notice of Related Case must still be filed with the
0 Clerk.)
MAG. JUDGE prior proceedings or appearance(s) CASE NO. Defense Counsel (if any): before U.S. Magistrate Judge regarding this defendant were DFPD o CJA D RET'D recorded under
Place of I San Francisco 0 Appointed on Target Letter
countySan Francisco offense
o This report amends AO 257 previously submitted
OFFENSE CHARGED· U.S.C. CITATION· STATUTORY MAXIMUM PENALTIES· ADDITIONAL INFORMATION OR COMMENTS
Total # of Counts 32
Set Title & Section/Offense Level Description of Offense Charged Count(s) (Pettv = 1 I Misdemeanor" 31 Felonv = 4)
Wells Fargo Bank. account ***-****546 in San Francisco, CA (via New Jersey)
AU in violation of Title 18, United States Code, Section 1343.
COUNTS TWENTY THROUGH THIRTY TWO: (18 U.S.C. § 1957- Engaging in Monetary Transactions in Criminally Derived Property)
13. Paragraphs 1 through 10 and 12, of this Indictment are realleged as iffully set
12 forth herein.
13
14
15
16
17
18
14. On or about the dates set forth below, in the Northern District of California and
elsewhere, the defendant,
SAMUEL COHEN, aIkIa Mouli Cohen,
did knowingly engage in monetary transactions, in and affecting interstate commerce, in
criminally derived property that was of a value greater than $10,000, and that was derived from
19 specified unlawful activity, namely, wire fraud, as follows:
20
21
22
23
24
25
26
27
28
TWENTY 9/15/2005
TWENTY ONE 9/27/2005
INDICTMENT
$600,000 transfer from Wells Fargo Bank account ***-****021 to Wells Fargo Bank account *******646 and derived from specified unlawful activity, namely, wire fraud, as set forth in count]
$600,000 transfer from Wells Fargo Bank account ***-****021 to Wells Fargo Bank account *******646 and derived from specified unlawful activity, namely, wire fraud, as set forth in counts 2 and 3
8
1
2 TWENTY TWO 10/4/2005 $1,200,000 transfer from Wells Fargo Bank
3 account ***-****021 to Wells Fargo Bank account
4 ***-****646 and derived from specified unlawful activity, namely, wire fraud, as set forth in count 4
5
6 TWENTY THREE 10/19/2005 $500,000 transfer from Wells Fargo Bank account ***-****021 to Wells Fargo Bank account ***-
7 ****646 and derived from specified unlawful activity, namely, wire fraud, as set forth in count 5
8
9 TWENTY FOUR 12/5/2005 $500,000 transfer from Wells Fargo Bank account
10 ***-****021 to Wells Fargo Bank account ***-****646 and derived from specified unlawful
11 activity, namely, wire fraud, as set forth in counts 6 and 7
12
13 TWENTY FIVE 12/7/2005 $167,000 transfer from Wells Fargo Bank account
14 ***-****021 to Wells Fargo Bank account ***-****646 and derived from specified unlawful
15 activity, namely, wire fraud, as set forth in counts 8 and 9
16
17 TWENTY SIX 1124/2006 $700,000 transfer from Wells Fargo Bank account
18 ***-****021 to Wells Fargo Bank account ***-****646 and derived from specified unlawful
19 activity, namely, wire fraud, as set forth in count 10
20 TWENTY SEVEN 211/2006 $542,000 transfer from Wells Fargo Bank account
21 ***-****021 to Wells Fargo Bank account ***-
22 ****646 and derived from specified unlawful activity, namely, wire fraud, as set forth in count II
23
24 TWENTY EIGHT 4112/06 $600,000 transfer from Wells Fargo Bank account ***-****021 to Wells Fargo Bank account ***-
25 ****646 and derived from specified unlawful activity, namely, wire fraud, as set forth in counts
26 12 and 13
27
28
INDICTMENT 9
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
TWENTYNINE
TIIIRTY
THIRTY ONE
THIRTY TWO
5/30/2006
7127/2006
8/23/2006
119/2007
$590,000 transfer from Wells Fargo Bank account ***-****021 to Wells Fargo Bank account *******646 and derived from specified unlawful activity, namely, wire fraud, as set forth in count 14
$100,000 transfer from Wells Fargo Bank account ***-****021 to Wells Fargo Bank account *******646 and derived from specified unlawful activity, namely, wire fraud, as set forth in count 15
$300,000 transfer from Wells Fargo Bank account ***-****021 to Wells Fargo Bank accollllt *******646 and derived from specified unlawful activity, namely, wire fraud, as set forth in count 16 and 17
$320,000 transfer from Wells Fargo Bank account ***-****021 to Wells Fargo Bank account *******646 and derived from specified unlawful activity, namely, wire fraud, as set forth in count 18
All in violation of Title 18, United States Code; Section 1957.
18 FORFEITURE ALLEGATION: (18 U.S.C. § 981 (a)(l)(C) and 28 U.S.C. § 2461 (c) -Forfeiture of SUA (wire fraud) proceeds)
19
20 16. The allegations of Counts ONE through NINETEEN of this indictment are
21 realleged and by this reference fully incorporated herein for the purpose of alleging forfeiture
22 pursuant to the provisions of 18 U.S.C. § 981 (a)(I)(C) and 28 U.S.C. § 2461 (c).
23 17. Upon a conviction of any of the offenses alleged in COllllts ONE through
24 NINETEEN, the defendant,
25 SAMUEL COHEN,
26 alk/a Mouli Cohen,
27 shall forfeit to the United States all property, constituting and derived from proceeds traceable to
28 said offenses, including but not limited to the following property:
INDICTMENT 10
1 (a) a money judgment equal to the amount of the proceeds obtained from the
2 offense; and
3 If any of said property, as a result of any actor omission of the defendant-
4
5
6
7
8
(a)
(b)
(c)
(d)
(e)
cannot be located upon the exercise of due diligence;
has been transferred or sold to or deposited with, a third person;
has been placed beyond the jurisdiction of the Court;
has been substantially diminished in value; or
has been commingled with other property which cannot be subdivided
9 without difficulty, any and all interest defendant has in other property shall be vested in the
10 United States and forfeited to the United States pursuant to Title 21, United States Code, Section
11 853(P), as incorporated by Title 28, United States Code, Section 2461 (c) and Rule 32.2 of the
12 Federal Rules of Criminal Procedure.
13 FORFEITURE ALLEGATION: (18 U.S.C. § 982(a)(I) - Forfeiture (money or property involved in money laundering))
14
15
16
17
18
19
20
18. The allegations of Counts TWENTY through THIRTY TWO of this indictment
are realleged and by this reference fully incorporated herein for the purpose of alleging forfeiture
pursuant to the provisions of 18 U.S.C. § 982(a)(I).
19. Upon a conviction of any of the offenses alleged in Counts TWENTY through
THIRTY TWO, the defendant,
SAMUEL COHEN, aJkIa Mouli Cohen,
21 shall forfeit to the United States all property, constituting and derived from money or property
22 involved in money laundering, including but not limited to the following property:
23 (a) a money judgment equal to the amount of the money or property involved
24 in the offense; and
25 If any of said property, as a result of any act or omission of the defendant-
26
27
28
(a)
(b)
(c)
INDICTMENT
cannot be located upon the exercise of due diligence;
has been transferred or sold to or deposited with, a third person;
has been placed beyond the jurisdiction of the Court;
11
1
2
(d)
(e)
has been substantially diminished in value; or
has been commingled with other property which cannot be subdivided
3 without difficulty, any and all interest defendant has in other property shall be vested in the
4 United States and forfeited to the United States pursuant to Title 21, United States Code, Section
5 853(p), as incorporated by Title 28, United States Code, Section 2461(c) and Rule 32.2 of the