supreme court of the state of new york kings county ... · the people of the state of new york ......

SUPREME COURT OF THE STATE OF NEW YORK KINGS COUNTY: CRIMINAL TERM ---------------------------------------------------------------------------------X THE PEOPLE OF THE STATE OF NEW YORK -against-

IND. NO. 3592/2013 BASEL RAMADAN, A.K.A. ABU SALAH SAMER RAMADAN, A.K.A. ABU MAHDY ADELA BUZAHRIEH, A.K.A. ADEL ABU ZAHRIEH YOUSSEFF ODEH, A.K.A. ABU MAHMOUD ISSA SULIEMAN MUFEED ATTAL, A.K.A. ABU SALEEM IZZAT NIMER, A.K.A. NIMER IZZAT, A.K.A. ABU ALI MUNTHER MAHMOUD NABIEL SAAD BADR, A.K.A. ABU NABIL AHMAD ABDELAZIZ, A.K.A. AL JABA'I RIBHI AWAWDEH MOHAMED ABED ALABED AWAWDEH, A.K.A. ABU SAMIR BASSAM TWAM MURAD BISHRAT MOHANNAD SEIF MUAFFAQ ASKAR DEFENDANTS. ---------------------------------------------------------------------------------X

COUNT ONE

ENTERPRISE CORRUPTION

THE GRAND JURY OF KINGS COUNTY, by this Indictment, accuses the

defendants of the crime of ENTERPRISE CORRUPTION, in violation of Penal Law

Section 460.20(1)(a), committed in Kings County and elsewhere as follows:

The defendants, from on or about December 2008, to on or about May 10, 2013,

having knowledge of the existence of a Criminal Enterprise, to wit: the RAMADAN

Untaxed Cigarette Distribution based Money Laundering Enterprise, and the nature of its

2

activities, and being members of or associated with that criminal enterprise by

participating in a pattern of criminal activity, as follows:

THE CRIMINAL ENTERPRISE

At all times relevant to the First Count:

The defendants Basel Ramadan, a.k.a. Abu Salah, Samir Ramadan, a.k.a.

Abu Mahdy, Adela Buzahrieh, a.k.a. Adel Abu Zahrieh, Yousseff Odeh, a.k.a. Abu

Mahmoud, Issa Sulieman, Mufeed Attal, a.k.a. Abu Saleem, Izzat Nimer, a.k.a.

Nimer Izzat, a.k.a. Abu Ali, Munther Mahmoud, Nabiel Saad Badr, a.k.a. Abu

Nabil, Ahmad Abdelaziz, a.k.a. Al Jaba'I, Ribhi Awawdeh, Mohamed Abed Alabed

Awawdeh, a.k.a. Abu Samir, Bassam Twam, Murad Bishrat, Mohannad Seif,

Muaffaq Askar, along with other persons known and unknown, were members and/or

associates of an enterprise called herein the RAMADAN Untaxed Cigarette Distribution

based Money Laundering Enterprise which consisted of a group of persons sharing a

common purpose of engaging in criminal conduct. The RAMADAN Untaxed Cigarette

Distribution based Money Laundering Enterprise had an ascertainable structure that was

distinct from a pattern of criminal activity, and had a continuity of existence, structure

and criminal purpose beyond the scope of individual criminal incidents.

The defendants listed above were members and associates of the RAMADAN

Untaxed Cigarette Distribution based Money Laundering Enterprise - an organized

criminal group which operated an untaxed cigarette trafficking based money laundering

operation in Kings, Bronx and Albany Counties, New York, New Jersey, Delaware, and

Maryland, and elsewhere inside and outside of the United States of America. The

3

RAMADAN Untaxed Cigarette Distribution based Money Laundering Enterprise

constituted a “criminal enterprise" as that term is defined in Penal Law § 460.10 (3).

The defendant Basel Ramadan, a.k.a. Abu Salah was “Boss” of the enterprise,

and the defendants Samer Ramadan, a.k.a. Abu Mahdy, Adela Buzahrieh, a.k.a. Adel

Abu Zahrieh, Yousseff Odeh, a.k.a. Abu Mahmoud, Issa Sulieman, Mufeed Attal,

a.k.a. Abu Saleem, Izzat Nimer, a.k.a. Nimer Izzat, a.k.a. Abu Ali, Munther

Mahmoud, Nabiel Saad Badr, a.k.a. Abu Nabil, Ahmad Abdelaziz, a.k.a. Al Jaba'I,

Ribhi Awawdeh, Mohamed Abed Alabed Awawdeh, a.k.a. Abu Samir, Bassam

Twam, Murad Bishrat, Mohannad Seif, Muaffaq Askar were “employees” and

“associates” of Basel Ramadan, a.k.a. Abu Salah and of the RAMADAN Untaxed

Cigarette Distribution based Money Laundering Enterprise.

THE STRUCTURE AND PURPOSES OF THE CRIMINAL ENTERPRISE

The Criminal Enterprise consisted of a BOSS, Basel Ramadan (a.k.a. Abu Salah,

hereinafter "Ramadan"), who headed the illicit untaxed cigarette distribution based

money laundering operation by acquiring cigarettes for distribution throughout New York

State, storing those cigarettes in Delaware, and by controlling the distribution of

cigarettes to the New York City area without paying New York State tobacco taxes

thereby generating millions of dollars in illicit proceeds for himself and other members of

the enterprise; his TREASURER (and right hand) and younger brother Samer

Ramadan, who assisted Ramadan in all aspects of the operation, but focused on control

and disbursement of the cash generated by the enterprise; several NEW YORK BASED

DISTRIBUTORS; Youssef Odeh, a.k.a. Abu Mahmoud (hereinafter "Odeh”), Issa

Sullieman (hereinafter “Issa”); Ribhi Awawdeh (hereinafter “Ribhi”), Mohamed

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Abed Alabed Awawdeh, a.k.a. Abu Samir (hereinafter “Mohamed Abed”)(collectively

referred to as “the Dibwani” or “The Bronx Guys”); Ahmad Abdelaziz, a.k.a. Al Jaba'I

(hereinafter “Abdelaziz”); Mufeed Attal, a.k.a. Abu Saleem (hereinafter "Attal")

Nimer Izzat, a.k.a. Izzat Nimer, a.k.a., Abu Ali (hereinafter "Nimer"); Munther

Mahmoud (hereinafter "Munther") and Saad Badr Nabiel, a.k.a. Abu Nabil

(hereinafter "Nabiel"), all of whom purchased untaxed cigarettes from Ramadan using

the proceeds that they generated from a prior sale of contraband cigarettes, and then

distributed them within New York City (predominantly in Brooklyn) to NEW YORK

BASED RESELLERS; Bassam Twam (hereinafter "Bassam"), Mohannad Seif

(hereinafter "Seif"), Murad Bishrat (hereinafter "Murad"), Muaffaq Askar

(hereinafter "Askar"), who sold the contraband cigarettes to local cigarette retailers; and

a TRANSPORTER, Adel Abuzarieh (hereinafter “Adel”), regularly transported large

amounts of the cash proceeds generated from the cigarette sales, sometimes over

$100,000 per trip, from New York based distributors back to Ramadan in order to

replenish the cigarette supply, and transported the contraband cigarettes from Ramadan's

Delaware storage facilities back down to the New York based distributors for sale.

Ramadan and Samer Ramadan, purchased cigarettes from at least one wholesaler,

Cooper Booth Wholesale, Inc., using their Virginia businesses as fronts to appear as

though they were purchasing cigarettes for sale in Virginia, thereby paying only the low

Virginia cigarette tax, and thereafter controlled the distribution of the cigarettes

(approximately 20,000 cartons per week) to New York City area without anyone

associated with the enterprise paying New York State tobacco taxes for those cigarettes.

Specifically, Ramadan determined the New York based distributors to whom he would

5

sell cigarettes, the prices the distributors had to pay for cigarettes and the times and

locations at which the distributors would exchange money for cigarettes. Ramadan

dictated that one of the central locations was the operation's storage facility located in

Dagsboro, Delaware. Additionally, Ramadan determined which distributors would use

Adel to transport the money to and cigarettes from the Ramadans. Ramadan also

mandated that the distributors that employ Adel's services pay Adel a fee of

approximately $0.75 per carton of cigarettes that he transported. On average, the

distributors purchased two to four thousand cartons of cigarettes per week (400,000 to

800,000 cigarettes) at a value of between $100,000 and $200,000. Ramadan accepted the

payment for the merchandise distributed in cash, which was generated from the sale of

the previously delivered cigarettes, and kept a running tally of how much each distributor

owed them. Ramadan determined how much "credit" each distributor was permitted

before he required payment. The distributors were paying Ramadan and Samer Ramadan

for merchandise that they had already received using the proceeds from sale of the

untaxed cigarettes. With each transaction, the re-sellers collected money from the

retailers, and then the re-sellers provided that cash to the distributers who either

transported it themselves to the Ramadans in Delaware in exchange for their fresh supply

of contraband cigarettes, or provided it to Adel for transport to the Ramadans, and then

Adel would transport the fresh supply of cigarettes back to the New York based

Distributers. In both scenarios, a percentage of the profits from the sale of the untaxed

cigarettes is being infused back into the RAMADAN Untaxed Cigarette Distribution

based Money Laundering Enterprise.

6

Once the distributors take possession of the merchandise, they distribute it to the

resellers, who in turn sell the untaxed cigarettes to a myriad of bodegas and grocery

stores throughout Brooklyn, Queens, Bronx and Staten Island. One of the resellers,

Mohannad Seif, also resells the untaxed cigarettes to various grocery stores in Capital

District - Albany and Schenectady Counties.

Ramadan and Samer Ramadan also furthered the untaxed cigarette distribution

business by concealing and disguising the true nature of the illicit proceeds of that

business by depositing a portion of the proceeds that the distributors used to pay for the

cigarettes into small local financial institutions in the Ocean City, Maryland area, and

used that money to purchase additional cigarettes for sale from Cooper Booth.

None of the members of the RAMADAN Untaxed Cigarette Distribution based

Money Laundering Enterprise are licensed or registered New York State Cigarette

Stamping Agents or Wholesale Dealers of Cigarettes.

PATTERN OF CRIMINAL ACTIVITY

During the period of this offense, the defendants Basel Ramadan, a.k.a. Abu

Salah, Samer Ramadan, a.k.a. Abu Mahdy, Adela Buzahrieh, a.k.a. Adel Abu Zahrieh,

Yousseff Odeh, a.k.a. Abu Mahmoud, Issa Sulieman, Mufeed Attal, a.k.a. Abu Saleem,

Izzat Nimer, a.k.a. Nimer Izzat, a.k.a. Abu Ali, Munther Mahmoud, Nabiel Saad Badr,

a.k.a. Abu Nabil, Ahmad Abdelaziz, a.k.a. Al Jaba'I, Ribhi Awawdeh, Mohamed Abed

Alabed Awawdeh, a.k.a. Abu Samir, Bassam Twam, Murad Bishrat, Mohannad Seif,

Muaffaq Askar, with intent to participate in and advance the affairs of the criminal

7

enterprise and pursuant to a common scheme and plan, engaged in conduct constituting

or was criminally liable for the following criminal acts included within a pattern of

criminal activity:

PATTERN ACT #1

Defendants Basel Ramadan, a.k.a. Abu Salah, Samer Ramadan, a.k.a. Abu

Mahdy, Adela Buzahrieh, a.k.a. Adel Abu Zahrieh, Yousseff Odeh, a.k.a. Abu

Mahmoud, Issa Sulieman, Ahmad Abdelaziz, a.k.a. Al Jaba'I, Ribhi Awawdeh and

Mohamed Abed Alabed Awawdeh, a.k.a. Abu Samir, each aiding the other and acting

in concert, committed the crime of Attempt to Evade or Defeat Cigarette and Tobacco

Products Tax in violation of N.Y. Tax L. §§ 481(2)(a) & 4 and N.Y. Tax L. §

1814(a)(i), in that on or about and between January 31, 2013 and February 2, 2013, in the

County of Kings, County of Bronx and elsewhere in the State, and in the States of

Delaware, Maryland and New Jersey, they did willfully attempt in any manner to evade

or defeat the taxes imposed pursuant to New York State Tax Law or payment thereof on

ten thousand (10,000) or more cigarettes.

PATTERN ACT #2





in concert, committed the crime of Possession or Transport for the Purpose of Sale, or

Sale or Offering For Sale, of Thirty Thousand or More Cigarettes in Unstamped or

Unlawfully Stamped Packages in violation of N.Y. Tax L. §§ 481(2)(a) & 4 and N.Y.

8

Tax L. § 1814(c)(2), in that on or about and between January 31, 2013 and February 2,

2013, in the County of Kings, County of Bronx and elsewhere in the State, and in the

States of Delaware, Maryland and New Jersey, not being agents licensed by the

Commissioner of the New York State Department of Taxation and Finance, did willfully

possess or transport for the purpose of sale thirty thousand or more cigarettes subject to

the tax imposed pursuant to New York State Law in any unstamped or unlawfully

stamped packages, and/or willfully sold or offered for sale thirty thousand or more

cigarettes in any unstamped or unlawfully stamped packages.

PATTERN ACT #3





in concert, committed the crime of Money Laundering in the Third Degree in violation

of Penal Law § 470.10(2)(b)(i), in that on or about and between January 31, 2013 and

February 2, 2013, in the County of Kings, County of Bronx, and elsewhere in the State of

New York and in the States of Delaware, Maryland and New Jersey, knowing that one or

more monetary instruments, to wit, United States currency, represented the proceeds of

criminal conduct, the defendants transported, transmitted, or transferred, or attempted to

transport, transmit or transfer, on one or more occasions, monetary instruments which in

fact represented the proceeds of specified criminal conduct, to wit, violation of N.Y. Tax

L. §§ 481(2)(a) & 4, N.Y. Tax L. §§ 1814(a)(i) and (c)(2) and Enterprise Corruption,

from a place in any county in this state to or through a place outside that county or to a

9

place in any county in this state from or through a place outside that county, with intent to

promote the carrying on of criminal conduct, and the total value of such monetary

instrument or instruments exceeded fifty thousand dollars.

PATTERN ACT #4





in concert, committed the crime of Money Laundering in the Third Degree in violation

of Penal Law § 470.10(1)(b)(i)(A), in that on or about and between January 31, 2013 and

February 2, 2013, in the County of Kings, County of Bronx, and elsewhere in the State

of New York and in the States of Delaware, Maryland and New Jersey, knowing that the

property involved in one or more financial transactions, to wit, United States currency,

represented the proceeds of criminal conduct, the defendants conducted one or more such

financial transactions which in fact involved the proceeds of specified criminal conduct,

to wit, violation of N.Y. Tax L. §§ 481(2)(a) & 4, N.Y. Tax L. §§ 1814(a)(i) and (c)(2)

and Enterprise Corruption, with intent to promote the carrying on of criminal conduct,

and the total value involved in such financial transaction or transactions exceeded fifty

thousand dollars.

PATTERN ACT #5



Mahmoud, Issa Sulieman, Bassam Twam, Ahmad Abdelaziz, a.k.a. Al Jaba'I, Ribhi

10

Awawdeh, Mohamed Abed Alabed Awawdeh, a.k.a. Abu Samir and Muaffaq

Askar, each aiding the other and acting in concert, committed the crime of Attempt to

Evade or Defeat Cigarette and Tobacco Products Tax in violation of N.Y. Tax L. §§

481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that on or about and between March 12,

2013 and March 14, 2013, in the County of Kings, County of Bronx, and elsewhere in the

State of New York and in the States of Delaware, Maryland and New Jersey, did willfully

attempt in any manner to evade or defeat the taxes imposed pursuant to New York State

Tax Law or payment thereof on ten thousand or more cigarettes.

PATTERN ACT #6





Askar, each aiding the other and acting in concert, committed the crime of Possession or

Transport for the Purpose of Sale, or Sale or Offering For Sale, of Thirty Thousand

or More Cigarettes in Unstamped or Unlawfully Stamped Packages in violation of

N.Y. Tax L. §§ 481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about and

between March 12, 2013 and March 14, 2013, in the County of Kings, County of Bronx,

and elsewhere in the State of New York and in the States of Delaware, Maryland and

New Jersey, not being agents licensed by the Commissioner of the New York State

Department of Taxation and Finance, did willfully possess or transport for the purpose of

sale, thirty thousand or more cigarettes subject to the tax imposed pursuant to New York

State Law in any unstamped or unlawfully stamped packages, and/or willfully sold or

11

offered for sale thirty thousand or more cigarettes in any unstamped or unlawfully

stamped packages.

PATTERN ACT #7





Askar, each aiding the other and acting in concert, committed the crime of Money

Laundering in the Third Degree in violation of Penal Law § 470.10(2)(b)(i), in that on

or about and between March 12, 2013 and March 14, 2013, in the County of Kings,

County of Bronx, and elsewhere in the State of New York and in the States of Delaware,

Maryland and New Jersey, knowing that one or more monetary instruments, to wit,

United States currency, represented the proceeds of criminal conduct, the defendants

transported, transmitted, or transferred, or attempted to transport, transmit or transfer, on

one or more occasions, monetary instruments which in fact represented the proceeds of

specified criminal conduct, to wit, violation of N.Y. Tax L. §§ 481(2)(a) & 4, N.Y. Tax

L. §§ 1814(a)(i) and (c)(2) and Enterprise Corruption, from a place in any county in this

state to or through a place outside that county or to a place in any county in this state

from or through a place outside that county, with intent to promote the carrying on of

criminal conduct, and the total value of such monetary instrument or instruments

exceeded fifty thousand dollars.

12

PATTERN ACT #8





Askar, each aiding the other and acting in concert, committed the crime of Money

Laundering in the Third Degree in violation of Penal Law § 470.10(1)(b)(i)(A), in that

on or about and between March 12, 2013 and March 14, 2013, in the County of Kings,

County of Bronx, and elsewhere in the State of New York and in the States of Delaware,

Maryland and New Jersey, knowing that the property involved in one or more financial

transactions, to wit, United States currency, represented the proceeds of criminal conduct,

the defendants conducted one or more such financial transactions which in fact involved

the proceeds of specified criminal conduct, to wit, violation of N.Y. Tax L. §§ 481(2)(a)

& 4, N.Y. Tax L. §§ 1814(a)(i) and (c)(2) and Enterprise Corruption, with intent to

promote the carrying on of criminal conduct, and the total value involved in such

financial transaction or transactions exceeded fifty thousand dollars.

PATTERN ACT #9


Mahdy, Izzat Nimer, a.k.a. Nimer Izzat, a.k.a. Abu Ali and Mufeed Attal, a.k.a. Abu

Saleem, each aiding the other and acting in concert, committed the crime of Attempt to


481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that on or about March 11, 2013, in the

County of Kings, and elsewhere in the State of New York and in the States of Delaware

13

and Maryland, did willfully attempt in any manner to evade or defeat the taxes imposed

pursuant to New York State Tax Law or payment thereof on ten thousand or more

cigarettes.

PATTERN ACT #10



Saleem, each aiding the other and acting in concert, committed the crime of Possession

or Transport for the Purpose of Sale, or Sale or Offering For Sale, of Thirty

Thousand or More Cigarettes in Unstamped or Unlawfully Stamped Packages in

violation of N.Y. Tax L. §§ 481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or

about March 11, 2013, in the County of Kingsand elsewhere in the State of New York

and in the States of Delaware and Maryland, not being agents licensed by the


possess or transport for the purpose of sale, thirty thousand or more cigarettes subject to




PATTERN ACT #11

Defendants, Basel Ramadan, a.k.a. Abu Salah, Samer Ramadan, a.k.a. Abu


Saleem, each aiding the other and acting in concert, committed the crime of Money

Laundering in the Fourth Degree in violation of Penal Law § 470.05(2)(a)(i), in that

on or about March 11, 2013, in the County of Kings and elsewhere in the State of New

14

York and in the States of Delaware and Maryland, knowing that one or more monetary

instruments, to wit, United States currency, represented the proceeds of criminal conduct,

the defendants transported, transmitted, or transferred, on one or more occasions,

monetary instruments which in fact represented the proceeds of specified criminal

conduct, to wit, violation of N.Y. Tax L. §§ 481(2)(a) & 4, N.Y. Tax L. §§ 1814(a)(i) and

(c)(2) and Enterprise Corruption, with intent to promote the carrying on of criminal

conduct, and the total value of such monetary instrument or instruments exceeded ten

thousand dollars.

PATTERN ACT #12




Laundering in the Fourth Degree in violation of Penal Law § 470.05(1)(a)(i)(A), in

that on or about March 11, 2013, in the County of Kings and elsewhere in the State of

New York and in the States of Delaware and Maryland, knowing that the property, to wit,

United States Currency, involved in one or more financial transactions represented the

proceeds of criminal conduct, the defendants conducted one or more such financial

transactions which in fact involved the proceeds of specified criminal conduct, to wit,

violation of N.Y. Tax L. §§ 481(2)(a) & 4, N.Y. Tax L. §§ 1814(a)(i) and (c)(2) and

Enterprise Corruption, with intent to promote the carrying on of criminal conduct, and the

total value involved in such financial transaction or transactions exceeded five thousand

dollars.

15

PATTERN ACT #13






County of Kings and elsewhere within the State of New York, and in the States of

Delaware and Maryland, did willfully attempt in any manner to evade or defeat the taxes

imposed pursuant to New York State Tax Law or payment thereof on ten thousand or

more cigarettes.

PATTERN ACT #14







about March 3, 2013, in the County of Kings and elsewhere in the State of New York,





16



PATTERN ACT #15





or about March 3, 2013, in the County of Kings and elsewhere within the State of New

York, and in the States of Delaware and Maryland, knowing that one or more monetary


the defendants transported, transmitted, or transferred, or attempted to transport, transmit

or transfer, on one or more occasions, monetary instruments which in fact represented the

proceeds of specified criminal conduct, to wit, violation of N.Y. Tax L. §§ 481(2)(a) & 4,

N.Y. Tax L. §§ 1814(a)(i) and (c)(2) and Enterprise Corruption, from a place in any

county in this state to or through a place outside that county or to a place in any county in

this state from or through a place outside that county, with intent to promote the carrying

on of criminal conduct, and the total value of such monetary instrument or instruments


PATTERN ACT #16




Laundering in the Third Degree in violation of Penal Law § 470.10(1)(b)(i)(A), in

17

that on or about March 3, 2013, in the County of Kings and elsewhere in the State of New

York, and in the States of Delaware and Maryland, knowing that the property, to wit,

United States currency, involved in one or more financial transactions represented the




Enterprise Corruption, as that term is defined under Article 470 of the Penal Law, with

intent to promote the carrying on of criminal conduct, and the total value involved in such


PATTERN ACT #17






County of Kings and elsewhere in the State of New York, and in the States of Delaware

and Maryland, did willfully attempt in any manner to evade or defeat the taxes imposed


cigarettes.

PATTERN ACT #18

Defendants, Basel Ramadan, a.k.a. Abu Salah, Samer Ramadan, a.k.a. Abu



18




about March 12, 2013, in the County of Kings and elsewhere in the State of New York,







PATTERN ACT #19





or about Mach 12, 2013, in the County of Kings and elsewhere in the State of New York,

and in the States of Delaware and Maryland, knowing that one or more monetary







19




PATTERN ACT #20





on or about March 12, 2013, in the County of Kings and elsewhere within the State of

New York, and within the States of Delaware and Maryland, knowing that the property,

to wit, United States currency, involved in one or more financial transactions represented

the proceeds of criminal conduct, the defendants conducted one or more such financial




total value involved in such financial transaction or transactions exceeded fifty thousand

dollars.

PATTERN ACT #21



Mahmoud, Issa Sulieman, Bassam Twam, Ribhi Awawdeh and Mohamed Abed

Alabed Awawdeh, a.k.a. Abu Samir, each aiding the other and acting in concert,

committed the crime of Attempt to Evade or Defeat Cigarette and Tobacco Products

20

Tax in violation of N.Y. Tax L. §§ 481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that

on or about March 27, 2013, in the County of Kings and County of Bronx and elsewhere

within the State of New York, and within the States of Delaware, Maryland and New

Jersey, did willfully attempt in any manner to evade or defeat the taxes imposed pursuant

to New York State Tax Law or payment thereof on ten thousand or more cigarettes.

PATTERN ACT #22





committed the crime of Possession or Transport for the Purpose of Sale, or Sale or

Offering For Sale, of Thirty Thousand or More Cigarettes in Unstamped or


Tax L. § 1814(c)(2), in that on or about March 27, 2013, in the County of Kings, County

of Bronx and elsewhere within the State of New York, and within the States of Delaware,

Maryland and New Jersey, not being agents licensed by the Commissioner of the New

York State Department of Taxation and Finance, did willfully possess or transport for the

purpose of sale, thirty thousand or more cigarettes subject to the tax imposed pursuant to

New York State Law in any unstamped or unlawfully stamped packages, and/or willfully

sold or offered for sale thirty thousand or more cigarettes in any unstamped or unlawfully

stamped packages.

21

PATTERN ACT #23





committed the crime of Money Laundering in the Third Degree in violation of Penal

Law § 470.10(2)(b)(i), in that on or about March 27, 2013, in the County of Kings,

County of Bronx, and elsewhere within the State of New York, and within the States of

Delaware, Maryland and New Jersey, knowing that one or more monetary instruments, to

wit, United States currency, represented the proceeds of criminal conduct, the defendants









PATTERN ACT #24





22


Law § 470.10(1)(b)(i)(A), in that on or about March 27, 2013, in the County of Kings,

County of Bronx and elsewhere within the State of New York, and in the States of

Delaware, Maryland and New Jersey, knowing that the property, to wit, United States

currency, involved in one or more financial transactions represented the proceeds of

criminal conduct, the defendants conducted one or more such financial transactions

which in fact involved the proceeds of specified criminal conduct, to wit, violation of

N.Y. Tax L. §§ 481(2)(a) & 4, N.Y. Tax L. §§ 1814(a)(i) and (c)(2) and Enterprise

Corruption, with intent to promote the carrying on of criminal conduct, and the total

value involved in such financial transaction or transactions exceeded fifty thousand

dollars.

PATTERN ACT #25




Awawdeh and Mohamed Abed Alabed Awawdeh, a.k.a. Abu Samir, each aiding the

other and acting in concert, committed the crime of Attempt to Evade or Defeat

Cigarette and Tobacco Products Tax in violation of N.Y. Tax L. §§ 481(2)(a) & 4 and

N.Y. Tax L. § 1814(a)(i), in that on or about and between March 28, 2013 and March 30,

2013, in the County of Kings, County of Bronx and elsewhere within the State of New

York, and in the States of Delaware, Maryland and New Jersey, did willfully attempt in

any manner to evade or defeat the taxes imposed pursuant to New York State Tax Law or

payment thereof on ten thousand or more cigarettes.

23

PATTERN ACT #26





other and acting in concert, committed the crime of Possession or Transport for the

Purpose of Sale, or Sale or Offering For Sale, of Thirty Thousand or More

Cigarettes in Unstamped or Unlawfully Stamped Packages in violation of N.Y. Tax

L. §§ 481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about and between

March 28 and March 30, 2013, in the County of Kings, County of Bronx and elsewhere

within the State of New York, and in the States of Delaware, Maryland and New Jersey,

not being agents licensed by the Commissioner of the New York State Department of

Taxation and Finance, did willfully possess or transport for the purpose of sale, thirty

thousand or more cigarettes subject to the tax imposed pursuant to New York State Law

in any unstamped or unlawfully stamped packages, and/or willfully sold or offered for

sale thirty thousand or more cigarettes in any unstamped or unlawfully stamped

packages.

PATTERN ACT #27





other and acting in concert, committed the crime of Money Laundering in the Third

24

Degree in violation of Penal Law § 470.10(2)(b)(i), in that on or about and between



knowing that one or more monetary instruments, to wit, United States currency,

represented the proceeds of criminal conduct, the defendants transported, transmitted, or

transferred, or attempted to transport, transmit or transfer, on one or more occasions,



(c)(2) and Enterprise Corruption, from a place in any county in this state to or through a

place outside that county or to a place in any county in this state from or through a place

outside that county, with intent to promote the carrying on of criminal conduct, and the

total value of such monetary instrument or instruments exceeded fifty thousand dollars.

PATTERN ACT #28






Degree in violation of Penal Law § 470.10(1)(b)(i)(A), in that on or about and between



knowing that the property, to wit, United States currency, involved in one or more

financial transactions represented the proceeds of criminal conduct, the defendants

25

conducted one or more such financial transactions which in fact involved the proceeds of


L. §§ 1814(a)(i) and (c)(2) and Enterprise Corruption, with intent to promote the carrying

on of criminal conduct, and the total value involved in such financial transaction or

transactions exceeded fifty thousand dollars.

PATTERN ACT #29


Mahdy, Munther Mahmoud, Bassam Twam, Murad Bishrat and Mohannad Seif,

each aiding the other and acting in concert, committed the crime of Attempt to Evade or

Defeat Cigarette and Tobacco Products Tax in violation of N.Y. Tax L. §§ 481(2)(a)

& 4 and N.Y. Tax L. § 1814(a)(i), in that on or about and between October 21, 2012 and

October 28, 2012, in the County of Kings and elsewhere within the State of New York,

and in the States of Delaware and Maryland, did willfully attempt in any manner to evade


ten thousand or more cigarettes.

PATTERN ACT #30



each aiding the other and acting in concert, committed the crime of Possession or




between October 21, 2012 and October 28, 2012, in the County of Kings and elsewhere

26

within the State of New York, and in the States of Delaware and Maryland, not being

agents licensed by the Commissioner of the New York State Department of Taxation and

Finance, did willfully possess or transport for the purpose of sale, thirty thousand or more

cigarettes subject to the tax imposed pursuant to New York State Law in any unstamped

or unlawfully stamped packages, and/or willfully sold or offered for sale thirty thousand

(30,000) or more cigarettes in any unstamped or unlawfully stamped packages.

PATTERN ACT #31



each aiding the other and acting in concert, committed the crime of Money Laundering

in the Third Degree in violation of Penal Law § 470.10(2)(b)(i), in that on or about and

between October 21, 2012 and October 28, 2012, in the County of Kings and elsewhere

within the State of New York, and in the States of Delaware and Maryland, knowing that

one or more monetary instruments, to wit, United States currency, represented the

proceeds of criminal conduct, the defendants transported, transmitted, or transferred, or

attempted to transport, transmit or transfer, on one or more occasions, monetary

instruments which in fact represented the proceeds of specified criminal conduct, to wit,


Enterprise Corruption, from a place in any county in this state to or through a place

outside that county or to a place in any county in this state from or through a place


total value of such monetary instrument or instruments exceeded fifty thousand dollars.

27

PATTERN ACT #32




in the Third Degree in violation of Penal Law § 470.10(1)(b)(i)(A), in that on or about

and between October 21, 2012 and October 28, 2012, in the County of Kings and

elsewhere within the State of New York, and in the States of Delaware and Maryland,








PATTERN ACT #33


Mahdy, Munther Mahmoud and Nabiel Saad Badr, a.k.a. Abu Nabil, each aiding the




L. §§ 481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about October 31, 2012,

in the County of Kings, not being agents licensed by the Commissioner of the New York

State Department of Taxation and Finance, did willfully possess or transport for the

28




stamped packages.

PATTERN ACT #34





N.Y. Tax L. § 1814(a)(i), in that on or about October 31, 2012, in the County of Kings

and elsewhere within the State of New York, and in the States of Delaware and

Maryland, did willfully attempt in any manner to evade or defeat the taxes imposed


cigarettes.

PATTERN ACT #35






L. §§ 481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about November 1,

2012, in the County of Kings and elsewhere within the State of New York, and in the

States of Delaware and Maryland, not being agents licensed by the Commissioner of the

29

New York State Department of Taxation and Finance, did willfully possess or transport

for the purpose of sale, thirty thousand or more cigarettes subject to the tax imposed

pursuant to New York State Law in any unstamped or unlawfully stamped packages,

and/or willfully sold or offered for sale thirty thousand or more cigarettes in any

unstamped or unlawfully stamped packages.

PATTERN ACT #36





N.Y. Tax L. § 1814(a)(i), in that on or about November 1, 2012, in the County of Kings




cigarettes.

PATTERN ACT #37








30







PATTERN ACT #38









cigarettes.

PATTERN ACT #39







31








PATTERN ACT #40









cigarettes.

PATTERN ACT #41





October 31, 2012 and November 3, 2012, in the County of Kings and elsewhere within

32

the State of New York, and in the States of Delaware and Maryland, knowing that the

property, to wit, United States currency, involved in one or more financial transactions






thousand dollars.

PATTERN ACT #42





October 31, 2012 and November 3, 2012, in the County of Kings and elsewhere within

the State of New York, and in the States of Delaware and Maryland, knowing that one or







place in any county in this state from or through a place outside that county, with intent

33

to promote the carrying on of criminal conduct, and the total value of such monetary


PATTERN ACT #43





N.Y. Tax L. § 1814(a)(i), in that on or about and between November 7, 2012 and

November 8, 2012, in the County of Kings and elsewhere within the State of New York,




PATTERN ACT #44







November 7, 2012 and November 8, 2012, in the County of Kings and elsewhere within

the State of New York, and in the States of Delaware and Maryland, not being agents

licensed by the Commissioner of the New York State Department of Taxation and


34



or more cigarettes in any unstamped or unlawfully stamped packages.

PATTERN ACT #45
















PATTERN ACT #46




35










thousand dollars.

PATTERN ACT #47









cigarettes.

PATTERN ACT #48



36












PATTERN ACT #49



other and acting in concert, committed the crime of Money Laundering in the Second


November 14, 2012 and November 15, 2012, in the County of Kings and elsewhere



proceeds of specified criminal conduct, the defendants transported, transmitted, or




37

(c)(2) and Enterprise Corruption, from a place in any county in this state to or through a


outside that county, with intent to promote the carrying on of specified criminal conduct,

and the total value of such monetary instrument or instruments exceeded one hundred

thousand dollars.

PATTERN ACT #50





November 14, 2012 and November 15, 2012, in the County of Kings and elsewhere


the property, to wit, United States currency, involved in one or more financial

transactions represented the proceeds of specified criminal conduct, the defendants




on of specified criminal conduct, and the total value involved in such financial

transaction or transactions exceeded one hundred thousand dollars.

PATTERN ACT #51




38


N.Y. Tax L. § 1814(a)(i), in that on or about January 19, 2013, in the County of Kings




cigarettes.

PATTERN ACT #52






L. §§ 481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about January 19, 2013,

in the County of Kings and elsewhere within the State of New York, and in the States of

Delaware and Maryland, not being agents licensed by the Commissioner of the New





stamped packages.

PATTERN ACT #53



39







cigarettes.

PATTERN ACT #54













stamped packages.

40

PATTERN ACT #55









cigarettes.

PATTERN ACT #56












41


stamped packages.

PATTERN ACT #57





January 19, 2013 and January 24, 2013, in the County of Kings and elsewhere within the

State of New York, and in the States of Delaware and Maryland, knowing that one or


specified criminal conduct, the defendants transported, transmitted, or transferred, or








thousand dollars.

PATTERN ACT #58




42


January 19, 2013 and January 24, 2013, in the County of Kings and elsewhere within the

State of New York, and in the States of Delaware and Maryland, knowing that the


represented the proceeds of specified criminal conduct, the defendants conducted one or

more such financial transactions which in fact involved the proceeds of specified criminal


(c)(2) and Enterprise Corruption, with intent to promote the carrying on of specified

criminal conduct, and the total value involved in such financial transaction or transactions

exceeded one hundred thousand dollars.

PATTERN ACT #59





N.Y. Tax L. § 1814(a)(i), in that on or about February 12, 2013, in the County of Kings




cigarettes.

PATTERN ACT #60



43




L. §§ 481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about February 12,








PATTERN ACT #61









cigarettes.

44

PATTERN ACT #62














PATTERN ACT #63








45


cigarettes.

PATTERN ACT #64














PATTERN ACT #65





46





cigarettes.

PATTERN ACT #66














PATTERN ACT #67




47






cigarettes.

PATTERN ACT #68














PATTERN ACT #69



48



February 12, 2013 and February 17, 2013, in the County of Kings and elsewhere within











thousand dollars.

PATTERN ACT #70





February 12, 2013 and February 17, 2013, in the County of Kings and elsewhere within




49



(c)(2) and Enterprise Corruption, with intent to promote the carrying on of specified



PATTERN ACT #71





481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that on or about December 4, 2012, in

the County of Kings and elsewhere within the State of New York, and in the States of


imposed pursuant to New York State Tax Law or payment thereof on ten thousand

(10,000) or more cigarettes.

PATTERN ACT #72







about December 4, 2012, in the County of Kings and elsewhere within the State of New

50

York, and in the States of Delaware and Maryland, not being agents licensed by the






PATTERN ACT #73





or about December 4, 2012, in the County of Kings and elsewhere within the State of

New York, and in the States of Delaware and Maryland, knowing that one or more

monetary instruments, to wit, United States currency, represented the proceeds of









51

PATTERN ACT #74





on or about December 4, 2012, in the County of Kings and elsewhere within the State of

New York, and in the States of Delaware and Maryland, knowing that the property, to

wit, United States currency, involved in one or more financial transactions represented






dollars.

PATTERN ACT #75



Saleem, each aiding the other and acting in concert, committed the crime of Criminal

Possession of a Forged Instrument in the First Degree in violation of Penal Law §

170.30, in that on or about December 4, 2012, in the County of Kings and elsewhere

within the State of New York, and in the States of Delaware and Maryland, with

knowledge that it is forged and with intent to defraud, deceive or injure another, the

52

defendants uttered any forged instrument of a kind specified in Penal Law section 170.15,

to wit, New York State tax stamps.

PATTERN ACT #76

Defendants Basel Ramadan, a.k.a. Abu Salah, Adela Buzahrieh, a.k.a. Adel

Abu Zahrieh, Yousseff Odeh, a.k.a. Abu Mahmoud, Mufeed Attal, a.k.a. Abu

Saleem, and Izzat Nimer, a.k.a. Nimer Izzat, a.k.a. Abu Ali, each aiding the other and

acting in concert, committed the crime of Possession or Transport for the Purpose of

Sale, or Sale or Offering For Sale, of Thirty Thousand or More Cigarettes in

Unstamped or Unlawfully Stamped Packages in violation of N.Y. Tax L. §§ 481(2)(a)

& 4 and N.Y. Tax L. § 1814(c)(2), in that on or about November 4, 2012, in the County

of Kings and elsewhere within the State of New York, and in the States of Delaware and

Maryland, not being agents licensed by the Commissioner of the New York State





stamped packages.

PATTERN ACT #77




acting in concert, committed the crime of Attempt to Evade or Defeat Cigarette and

Tobacco Products Tax in violation of N.Y. Tax L. §§ 481(2)(a) & 4 and N.Y. Tax L. §

53

1814(a)(i), in that on or about November 4, 2012, in the County of Kings and elsewhere

within the State of New York, and in the States of Delaware and Maryland, did willfully



PATTERN ACT #78




acting in concert, committed the crime of Money Laundering in the Fourth Degree in

violation of Penal Law § 470.05(2)(a)(i), in that on or about November 4, 2012, in the


Delaware and Maryland, knowing that one or more monetary instrumentsto wit, United

States currency, represented the proceeds of criminal conduct, the defendants transported,

transmitted, or transferred, or attempted to transport, transmit or transfer, on one or more

occasions, monetary instruments which in fact represented the proceeds of specified

criminal conduct, to wit, violation of N.Y. Tax L. §§ 481(2)(a) & 4, N.Y. Tax L. §§

1814(a)(i) and (c)(2) and Enterprise Corruption, with intent to promote the carrying on of


exceeded ten thousand dollars.

PATTERN ACT #79




54


violation of Penal Law § 470.05(1)(a)(i)(A), in that on or about November 4, 2012, in


Delaware and Maryland, knowing that the property, to wit, United States currency,

involved in one or more financial transactions represented the proceeds of criminal

conduct, the defendants conducted one or more such financial transactions which in fact

involved the proceeds of specified criminal conduct, to wit, violation of N.Y. Tax L. §§

481(2)(a) & 4, N.Y. Tax L. §§ 1814(a)(i) and (c)(2) and Enterprise Corruption, with


financial transaction or transactions exceeded five thousand dollars.

PATTERN ACT #80

Defendants Basel Ramadan, a.k.a. Abu Salah, Izzat Nimer, a.k.a. Nimer

Izzat, a.k.a. Abu Ali, Mufeed Attal, a.k.a. Abu Saleem and Murad Bishrat, each

aiding the other and acting in concert, committed the crime of Possession or Transport

for the Purpose of Sale, or Sale or Offering For Sale, of Thirty Thousand or More








55



PATTERN ACT #81



aiding the other and acting in concert, committed the crime of Attempt to Evade or


& 4 and N.Y. Tax L. § 1814(a)(i), in that on or about November 30, 2012, in the County




cigarettes.

PATTERN ACT #82



aiding the other and acting in concert, committed the crime of Money Laundering in the

Fourth Degree in violation of Penal Law § 470.05(2)(a)(i), in that on or about



instruments, to wit, United States currency, represented the proceeds of criminal

conduct, the defendants transported, transmitted, or transferred, or attempted to transport,

transmit or transfer, on one or more occasions, monetary instruments which in fact

represented the proceeds of specified criminal conduct, to wit, violation of N.Y. Tax L.

56

§§ 481(2)(a) & 4, N.Y. Tax L. §§ 1814(a)(i) and (c)(2) and Enterprise Corruption, with

intent to promote the carrying on of criminal conduct, and the total value of such

monetary instrument or instruments exceeded ten thousand dollars.

PATTERN ACT #83



aiding the other and acting in concert, committed the crime of Money Laundering in the

Fourth Degree in violation of Penal Law § 470.05(1)(a)(i)(A), in that on or about


and in the States of Delaware and Maryland, knowing that the property, to wit, United

States currency, involved in one or more financial transactions represented the proceeds

of criminal conduct, the defendants conducted one or more such financial transactions




value involved in such financial transaction or transactions exceeded five thousand

dollars.

PATTERN ACT #84


Mahdy, Adela Buzahrieh, a.k.a. Adel Abu Zahrieh, Izzat Nimer, a.k.a. Nimer Izzat,

a.k.a. Abu Ali, Mufeed Attal, a.k.a. Abu Saleem and Murad Bishrat, each aiding the


57


N.Y. Tax L. § 1814(a)(i), in that on or about and between December 26, 2012 and

December 27, 2012, in the County of Kings and elsewhere within the State of New York,




PATTERN ACT #85








December 26, 2012 and December 27, 2012, in the County of Kings and elsewhere

within the State of New York, and in the States of Delaware and Maryland, not being






58

PATTERN ACT #86
















total value of such monetary instrument or instruments exceeded fifty thousand

dollars.

PATTERN ACT #87





59




the property, to wit, United States currency, involved in one or more financial

transactions represented the proceeds of criminal conduct, the defendants conducted one

or more such financial transactions which in fact involved the proceeds of specified





PATTERN ACT #88


Izzat, a.k.a. Abu Ali and Mufeed Attal, a.k.a. Abu Saleem, each aiding the other and



1814(a)(i), in that on or about February 3, 2013, in the County of Kings and elsewhere




PATTERN ACT #89




60



& 4 and N.Y. Tax L. § 1814(c)(2), in that on or about February 3, 2013, in the County of

Kings and elsewhere within the State of New York, and in the States of Delaware and






stamped packages.

PATTERN ACT #90




violation of Penal Law § 470.05(2)(a)(i), in that on or about February 3, 2013, in the


Delaware and Maryland, knowing that one or more monetary instruments, to wit, United






61



PATTERN ACT #91




violation of Penal Law § 470.05(1)(a)(i)(A), in that on or about February 3, 2013, in the









PATTERN ACT #92





481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that on or about February 5, 2013, in the

County of Kings, did willfully attempt in any manner to evade or defeat the taxes

62


more cigarettes.

PATTERN ACT #93







about February 5, 2013, in the County of Kings and elsewhere within the State of New







PATTERN ACT #94





on or about February 5, 2013, in the County of Kings and elsewhere within the State of


63






with intent to promote the carrying on of criminal conduct, and the total value of such


PATTERN ACT #95





that on or about February 5, 2013, in the County of Kings and elsewhere within the State

of New York, and in the States of Delaware and Maryland, knowing that the property, to







dollars.

64

PATTERN ACT #96





481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that on or abut February 10, 2013, in the




more cigarettes.

PATTERN ACT #97












65



PATTERN ACT #98






New York, and in the States of Delaware, Maryland and New Jersey, knowing that one or








PATTERN ACT #99





that on or about February 10, 2013, in the County of Kings and elsewhere within the


66






and the total value involved in such financial transaction or transactions exceeded five

thousand dollars.

PATTERN ACT #100







1814(a)(i), in that on or about February 11, 2013, in the County of Kings, County of

Bronx and elsewhere within the State of New York, and in the States of Delaware,

Maryland and New Jersey, did willfully attempt in any manner to evade or defeat the

taxes imposed pursuant to New York State Tax Law or payment thereof on ten thousand

or more cigarettes.

PATTERN ACT #101



67






Tax L. § 1814(c)(2), in that on or about February 11, 2013, in the County of Kings,


Delaware, Maryland and New Jersey, not being agents licensed by the Commissioner of

the New York State Department of Taxation and Finance, did willfully possess or

transport for the purpose of sale, thirty thousand or more cigarettes subject to the tax

imposed pursuant to New York State Law in any unstamped or unlawfully stamped

packages, and/or willfully sold or offered for sale thirty thousand or more cigarettes in

any unstamped or unlawfully stamped packages.

PATTERN ACT #102





in concert, committed the crime of Money Laundering in the Second Degree in

violation of Penal Law § 470.15(2)(b)(i), in that on or about February 11, 2013, in the

County of Kings, County of Bronx and elsewhere within the State of New York, and in

the States of Delaware, Maryland and New Jersey, knowing that one or more monetary

instruments, to wit, United States currency, represented the proceeds of specified criminal

68




§§ 481(2)(a) & 4, N.Y. Tax L. §§ 1814(a)(i) and (c)(2) and Enterprise Corruption, from a

place in any county in this state to or through a place outside that county or to a place in

any county in this state from or through a place outside that county, with intent to

promote the carrying on of specified criminal conduct, and the total value of such

monetary instrument or instruments exceeded one hundred thousand dollars.

PATTERN ACT #103






violation of Penal Law § 470.15(1)(b)(i)(A), in that on or about February 11, 2013, in

the County of Kings, County of Bronx and elsewhere within the State of New York, and

in the States of Delaware, Maryland and New Jersey, knowing that the property, to wit,


proceeds of specified criminal conduct, the defendants conducted one or more such



and Enterprise Corruption, with intent to promote the carrying on of specified criminal

69

conduct, and the total value involved in such financial transaction or transactions


PATTERN ACT #104





481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that on or about February 16, 2013, in




more cigarettes.

PATTERN ACT #105











70




PATTERN ACT #106





or about February 16, 2013, in the County of Kings and elsewhere within the State of











PATTERN ACT #107




71










dollars.

PATTERN ACT #108









more cigarettes.

PATTERN ACT #109



72












PATTERN ACT #110












73





PATTERN ACT #111













dollars.

PATTERN ACT #112





74





more cigarettes.

PATTERN ACT #113














PATTERN ACT #114




75













PATTERN ACT #115











76



dollars.

PATTERN ACT #116









more cigarettes.

PATTERN ACT #117










77





PATTERN ACT #118
















PATTERN ACT #119



78











dollars.

PATTERN ACT #120









more cigarettes.

79

PATTERN ACT #121














PATTERN ACT #122









80








PATTERN ACT #123













dollars.

81

PATTERN ACT #124









PATTERN ACT #125






& 4 and N.Y. Tax L. § 1814(c)(2), in that on or about February 24, 2013, in the County







stamped packages.

82

PATTERN ACT #126




violation of Penal Law § 470.05(2)(a)(i), in that on or about February 24, 2013, in the










PATTERN ACT #127




violation of Penal Law § 470.05(1)(a)(i)(A), in that on or about February 24, 2013, in





83





PATTERN ACT #128







Delaware and, Maryland, did willfully attempt in any manner to evade or defeat the taxes


more cigarettes.

PATTERN ACT #129









84






PATTERN ACT #130
















PATTERN ACT #131

85













dollars.

PATTERN ACT #132









more cigarettes.

86

PATTERN ACT #133







about March 2, 2013, in the County of Kings and elsewhere within the State of New







PATTERN ACT #134









87








PATTERN ACT #135













dollars.

PATTERN ACT #136

88









more cigarettes.

PATTERN ACT #137














89

PATTERN ACT #138
















PATTERN ACT #139







90







dollars.

PATTERN ACT #140









more cigarettes.

PATTERN ACT #141






91





possess or transport for the purpose of sale thirty thousand or more cigarettes subject to




PATTERN ACT #142














92

PATTERN ACT #143





that on or about March 14, 2013, in the County of Kings and elsewhere within the State

of New York, and in the States of Delaware and Maryland, knowing that the property, to







dollars.

PATTERN ACT #144









93






PATTERN ACT #145









more cigarettes.

PATTERN ACT #146




or Transport for the Purpose of Sale, or Sale or Offering For Sale, of Ten Thousand


N.Y. Tax L. §§ 481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(1), in that on or about March

15, 2013, in the County of Kings and elsewhere within the State of New York, and in the

94



for the purpose of sale, ten thousand or more cigarettes subject to the tax imposed


and/or willfully sold or offered for sale ten thousand or more cigarettes in any unstamped

or unlawfully stamped packages.

PATTERN ACT #147









more cigarettes.

PATTERN ACT #148







95








PATTERN ACT #149
















96

PATTERN ACT #150













dollars.

PATTERN ACT #151








97


more cigarettes.

PATTERN ACT #152














PATTERN ACT #153







98










PATTERN ACT #154













dollars.

99

PATTERN ACT #155





481(2)(a) 4 and N.Y. Tax L. § 1814(a)(i), in that on or about March 24, 2013, in the




more cigarettes.

PATTERN ACT #156












100



PATTERN ACT #157
















PATTERN ACT #158





101









dollars.

PATTERN ACT #159


Mahdy, Adela Buzahrieh, a.k.a. Adel Abu Zahrieh, Ahmad Abdelaziz, a.k.a. Al

Jaba'I, Ribhi Awawdeh and Mohamed Abed Alabed Awawdeh, a.k.a. Abu Samir,



& 4 and N.Y. Tax L. § 1814(a)(i), in that on or about December 26, 2012, in the County

of Kings, County of Bronx and elsewhere within the State of New York, and in the States

of Delaware, Maryland and New Jersey, did willfully attempt in any manner to evade or

defeat the taxes imposed pursuant to New York State Tax Law or payment thereof on ten

thousand or more cigarettes.

102

PATTERN ACT #160







N.Y. Tax L. §§ 481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about

December 26, 2012, in the County of Kings, County of Bronx and elsewhere within the

State of New York, and in the States of Delaware, Maryland and New Jersey, not being






PATTERN ACT #161





in the Third Degree in violation of Penal Law § 470.10(2)(b)(i), in that on or about


State of New York, and in the States of Delaware, Maryland and New Jersey, knowing

103

that one or more monetary instruments, to wit, United States currency, represented the









dollars.

PATTERN ACT #162








that the property, to wit, United States currency, involved in one or more financial





104



PATTERN ACT #163



Mahmoud, Issa Sulieman, Ribhi Awawdeh, Mohamed Abed Alabed Awawdeh,

a.k.a. Abu Samir and Ahmad Abdelaziz, a.k.a. Al Jaba'I, each aiding the other and



1814(a)(i), in that on or about January 7, 2013, in the County of Kings, County of Bronx

and elsewhere within the State of New York, and in the States of Delaware, Maryland

and New Jersey, did willfully attempt in any manner to evade or defeat the taxes imposed


cigarettes.

PATTERN ACT #164








& 4 and N.Y. Tax L. § 1814(c)(2), in that on or about January 7, 2013, in the County of

105

Kings, County of Bronx and elsewhere within the State of New York, and in the States of







PATTERN ACT #165





acting in concert, committed the crime of Money Laundering in the Third Degree in

violation of Penal Law § 470.10(2)(b)(i), in that on or about January 7, 2013, in the










106



PATTERN ACT #166





acting in concert, committed the crime of Money Laundering in the Third Degree in

violation of Penal Law § 470.10(1)(b)(i)(A), in that on or about January 7, 2013, in the


the States of Delaware, Maryland and New Jersey, knowing that the property, to wit,







dollars.

PATTERN ACT #167


Abu Zahrieh, Ribhi Awawdeh, Mohamed Abed Alabed Awawdeh, a.k.a. Abu Samir

and Ahmad Abdelaziz, a.k.a. Al Jaba'I, each aiding the other and acting in concert,


107


on or about January 9, 2013, in the County of Kings, County of Bronx and elsewhere


did willfully attempt in any manner to evade or defeat the taxes imposed pursuant to New

York State Tax Law or payment thereof on ten thousand or more cigarettes.

PATTERN ACT #168







Tax L. § 1814(c)(2), in that on or about January 9, 2013, in the County of Kings, County

of Bronx and elsewhere within the State of New York, and in the States of Delaware,






stamped packages.

PATTERN ACT #169



108



Law § 470.10(2)(b)(i), in that on or about January 9, 2013, in the County of Kings,












PATTERN ACT #170





Law § 470.10(1)(b)(i)(A), in that on or about January 9, 2013, in the County of Kings,




109






dollars.

PATTERN ACT #171


Mahdy, Adela Buzahrieh, a.k.a. Adel Abu Zahrieh, Ribhi Awawdeh, Mohamed

Abed Alabed Awawdeh, a.k.a. Abu Samir and Ahmad Abdelaziz, a.k.a. Al Jaba'I,



& 4 and N.Y. Tax L. § 1814(a)(i), in that on or about January 27, 2013, in the County

of Kings, County of Bronx and elsewhere within the State of New York, and in the States

of Delaware, Maryland and New Jersey, did willfully attempt in any manner to evade or



PATTERN ACT #172






110


N.Y. Tax L. §§ 481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about January

27, 2013, in the County of Kings, County of Bronx and elsewhere within the State of

New York, and in the States of Delaware, Maryland and New Jersey, not being agents






PATTERN ACT #173





in the Third Degree in violation of Penal Law § 470.10(2)(b)(i) in that on or about

January 27, 2013, in the County of Kings, County of Bronx and elsewhere within the







111





dollars.

PATTERN ACT #174






January 27, 2013, in the County of Kings, County of Bronx and elsewhere within the









PATTERN ACT #175



112









or more cigarettes.

PATTERN ACT #176














113



PATTERN ACT #177


















PATTERN ACT #178



114














PATTERN ACT #179










115


or more cigarettes.

PATTERN ACT #180
















PATTERN ACT #181





116














PATTERN ACT #182










117







PATTERN ACT #183



Mahmoud, Issa Sulieman, Bassam Twam and Muaffaq Askar, each aiding the other

and acting in concert, committed the crime of Attempt to Evade or Defeat Cigarette

and Tobacco Products Tax in violation of N.Y. Tax L. §481(2)(a) & 4 and N.Y. Tax

L. § 1814(a)(i), in that on or about March 16, 2013, in the County of Kings and

elsewhere within the State of New York, and in the States of Delaware and Maryland, did

willfully attempt in any manner to evade or defeat the taxes imposed pursuant to New


PATTERN ACT #184




and acting in concert, committed the crime of Possession or Transport for the Purpose

of Sale, or Sale or Offering For Sale, of Thirty Thousand or More Cigarettes in


118

& 4 and N.Y. Tax L. § 1814(c)(2), in that on or about March 16, 2013, in the County of







stamped packages.

PATTERN ACT #185




and acting in concert, committed the crime of Money Laundering in the Third Degree

in violation of Penal Law § 470.10(2)(b)(i), in that on or about March 16, 2013, in the







1814(a)(i) and (c)(2) and Enterprise Corruption, from a place in any county in this state to

or through a place outside that county or to a place in any county in this state from or

through a place outside that county, with intent to promote the carrying on of criminal

119

conduct, and the total value of such monetary instrument or instruments exceeded fifty

thousand dollars.

PATTERN ACT #186




and acting in concert, committed the crime of Money Laundering in the Third Degree

in violation of Penal Law § 470.10(1)(b)(i)(A), in that on or about March 16, 2013, in









PATTERN ACT #187



Mahmoud, Issa Sulieman, Bassam Twam, Muaffaq Askar and Ahmad Abdelaziz,

a.k.a. Al Jaba'I, each aiding the other and acting in concert, committed the crime of

Attempt to Evade or Defeat Cigarette and Tobacco Products Tax in violation of N.Y.

Tax L. §§ 481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that on or about March 20,

120


States of Delaware and Maryland, did willfully attempt in any manner to evade or defeat

the taxes imposed pursuant to New York State Tax Law or payment thereof on ten


PATTERN ACT #188





Possession or Transport for the Purpose of Sale, or Sale or Offering For Sale, of

Thirty Thousand or More Cigarettes in Unstamped or Unlawfully Stamped

Packages in violation of N.Y. Tax L. §§ 481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in

that on or about March 20, 2013, in the County of Kings and elsewhere within the State

of New York, and in the States of Delaware and Maryland, not being agents licensed by

the Commissioner of the New York State Department of Taxation and Finance, did

willfully possess or transport for the purpose of sale, thirty thousand or more cigarettes

subject to the tax imposed pursuant to New York State Law in any unstamped or

unlawfully stamped packages, and/or willfully sold or offered for sale thirty thousand or

more cigarettes in any unstamped or unlawfully stamped packages.

PATTERN ACT #189




121


Money Laundering in the Second Degree in violation of Penal Law § 470.15(2)(b)(i),

in that on or about March 20, 2013, in the County of Kings and elsewhere within the

State of New York, and in the States of Delaware and Maryland, knowing that one or










thousand dollars.

PATTERN ACT #190





Money Laundering in the Second Degree in violation of Penal Law §

470.15(1)(b)(i)(A), in that on or about March 20, 2013, in the County of Kings and

elsewhere within the State of New York, and in the States of Delaware and Maryland,


122

financial transactions represented the proceeds of specified criminal conduct, the

defendants conducted one or more such financial transactions which in fact involved the


N.Y. Tax L. §§ 1814(a)(i) and (c)(2) and Enterprise Corruption, with intent to promote

the carrying on of specified criminal conduct, and the total value involved in such

financial transaction or transactions exceeded one hundred thousand dollars.

PATTERN ACT #191



Mahmoud, Issa Sulieman and Muaffaq Askar, each aiding the other and acting in

concert, committed the crime of Attempt to Evade or Defeat Cigarette and Tobacco






PATTERN ACT #192




concert, committed the crime of Possession or Transport for the Purpose of Sale, or



123

Tax L. § 1814(c)(2), in that on or about February 13, 2013, in the County of Kings and

elsewhere within the State of New York, and in the States of Delaware and Maryland not

being agents licensed by the Commissioner of the New York State Department of





packages.

PATTERN ACT #193



Mahmoud, Issa Sulieman and Muaffaq Askar, committed the crime of Money











124

PATTERN ACT #194













thousand dollars.

PATTERN ACT #195








125



PATTERN ACT #196







Tax L. § 1814(c)(2), in that on or about February 21, 2013, in the County of Kings and

elsewhere within the State of New York, and in the States of Delaware and Maryland, not






packages.

PATTERN ACT #197






126









PATTERN ACT #198













thousand dollars.

127

PATTERN ACT #199



Mahmoud, Issa Sulieman, Ahmad Abdelaziz, a.k.a. Al Jaba'I, Ribhi Awawdeh,

Mohamed Abed Alabed Awawdeh, a.k.a. Abu Samir, Muaffaq Askar and

Mohannad Seif, each aiding the other and acting in concert, committed the crime of

Attempt to Evade or Defeat Cigarette and Tobacco Products Tax in violation of N.Y.

Tax L. §§ 481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that on or about March 6,


York, and in the States of Delaware, Maryland and New Jersey, did willfully attempt in

any manner to evade or defeat the taxes imposed pursuant to New York State Tax Law or

payment thereof on ten thousand or more cigarettes.

PATTERN ACT #200






Possession or Transport for the Purpose of Sale, or Sale or Offering For Sale, of



that on or about March 6, 2013, in the County of Kings, County of Bronx and elsewhere

128







packages.

PATTERN ACT #201






Money Laundering in the Third Degree in violation of Penal Law § 470.10(2)(b)(i),

in that on or about March 6, 2013, in the County of Kings, County of Bronx and

elsewhere within the State of New York, and in the States of Delaware, Maryland and

New Jersey, knowing that one or more monetary instruments, to wit, United States

currency, represented the proceeds of criminal conduct, the defendants transported,




1814(a)(i) and (c)(2) and Enterprise Corruption, from a place in any county in this state to


129



thousand dollars.

PATTERN ACT #202






Money Laundering in the Third Degree in violation of Penal Law §

470.10(1)(b)(i)(A), in that on or about March 6, 2013, in the County of Kings, County of


Maryland and New Jersey, knowing that the property, to wit, United States currency,







PATTERN ACT #203



Mahmoud, Bassam Twam, Murad Bishrat and Mohannad Seif, each aiding the other

130

and acting in concert, committed the crime of Attempt to Evade or Defeat Cigarette

and Tobacco Products Tax in violation of N.Y. Tax L. §§ 481(2)(a) & 4 and N.Y.

Tax L. § 1814(a)(i), in that on or about September 22, 2012, in the County of Kings and

elsewhere within the State of New York, and in the States of Delaware and Maryland, did



PATTERN ACT #204




and acting in concert, committed the crime of Possession or Transport for the Purpose

of Sale, or Sale or Offering For Sale, of Thirty Thousand or More Cigarettes in


& 4 and N.Y. Tax L. § 1814(c)(2), in that on or about September 22, 2012, in the







stamped packages.

131

PATTERN ACT #205




and acting in concert, committed the crime of Money Laundering in the Fourth Degree

in violation of Penal Law § 470.05(2)(a)(i), in that on or about September 22, 2012, in










PATTERN ACT #206



Mahmoud, Bassam Twam and Murad Bishrat, each aiding the other and acting in

concert, committed the crime of Money Laundering in the Fourth Degree in violation

of Penal Law § 470.05(1)(a)(i)(A), in that on or about September 22, 2012, in the



132







PATTERN ACT #207






1814(a)(i), in that on or about and between September 28, 2012 and September 30, 2012,




more cigarettes.

PATTERN ACT #208






133


Tax L. § 1814(c)(2), in that on or about and between September 28, 2012 and September

30, 2012, in the County of Kings and elsewhere within the State of New York, and in the







PATTERN ACT #209




concert, committed the crime of Money Laundering in the Third Degree in violation of

Penal Law § 470.10(2)(b)(i), in that on or about and between September 28, 2012 and

September 30, 2012, in the County of Kings and elsewhere within the State of New York,








134




PATTERN ACT #210





Penal Law § 470.10(1)(b)(i)(A), in that on or about and between September 28, 2012

and September 30, 2012, in the County of Kings and elsewhere within the State of New

York, and in the States of Delaware and Maryland, knowing that the property, to wit,







dollars.

PATTERN ACT #211





135


1814(a)(i), in that on or about and between October 1, 2012 and October 6, 2012, in the




more cigarettes.

PATTERN ACT #212







Tax L. § 1814(c)(2), in that on or about and between October 1, 2012 and October 6,








136

PATTERN ACT #213





Penal Law § 470.10(2)(b)(i), in that on or about and between October 1, 2012 and












PATTERN ACT #214





137

Penal Law § 470.10(1)(b)(i)(A), in that on or about and between October 1, 2012 and









dollars.

PATTERN ACT #215



Abed Alabed Awawdeh, a.k.a. Abu Samir, Yousseff Odeh, a.k.a. Abu Mahmoud,

Issa Sulieman and Mohannad Seif, each aiding the other and acting in concert,



on or about and between December 21 and December 22, 2012, in the County of Kings,


Delaware, Maryland and New Jersey, did willfully attempt in any manner to evade or



138

PATTERN ACT #216








Tax L. § 1814(c)(2), in that on or about and between December 21, 2012 and December


New York, and in the States of Delaware, Maryland and New Jersey, not being agents






PATTERN ACT #217






139

Law § 470.10(2)(b)(i), in that on or about and between December 21, 2012 and












dollars.

PATTERN ACT #218






Law § 470.10(1)(b)(i)(A), in that on or about and between December 21, 2012 and




140







PATTERN ACT #219



Mahmoud, Issa Sulieman and Mohannad Seif, each aiding the other and acting in



1814(a)(i), in that on or about and between December 29, 2012 and January 3, 2013, in




more cigarettes.

PATTERN ACT #220






141


Tax L. § 1814(c)(2), in that on or about and between December 29, 2012 and January 3,


States of Delaware and Maryland and New Jersey, not being agents licensed by the






PATTERN ACT #221





Penal Law § 470.10(2)(b)(i), in that on or about and between December 29, 2012 and

January 3, 2013, in the County of Kings and elsewhere within the State of New York, and

in the States of Delaware and Maryland, knowing that one or more monetary instruments,

to wit, United States currency, represented the proceeds of criminal conduct, the

defendants transported, transmitted, or transferred, or attempted to transport, transmit or

transfer, on one or more occasions, monetary instruments which in fact represented the




142




PATTERN ACT #222





Penal Law § 470.10(1)(b)(i)(A), in that on or about and between December 29, 2012 and

January 3, 2013, in the County of Kings and elsewhere within the State of New York, and

in the States of Delaware and Maryland, knowing that the property involved in one or

more financial transactions represented the proceeds of criminal conduct, the defendants






PATTERN ACT #223






143

1814(a)(i), in that on or about and between January 13, 2013 and January 14, 2013, in the




more cigarettes.

PATTERN ACT #224







Tax L. § 1814(c)(2), in that on or about and between January 13, 2013 and January 14,








PATTERN ACT #225



144



Penal Law § 470.10(2)(b)(i), in that on or about and between January 13, 2013 and

January 14, 2013, in the County of Kings and elsewhere within the State of New York,

and in the States of Delaware and Marylandy, knowing that one or more monetary

instrument, to wit, United States currency, represented the proceeds of criminal conduct,









PATTERN ACT #226





Penal Law § 470.10(1)(b)(i)(A), in that on or about and between January 13, 2013 and




145






dollars.

PATTERN ACT #227




a.k.a. Abu Samir and Mohannad Seif, each aiding the other and acting in concert,



on or about and between January 22, 2013 and January 24, 2013, in the County of Kings,


Delaware, Maryland and New Jersey, did willfully attempt in any manner to evade or



PATTERN ACT #228





146






York, and in the States of Delaware, Maryland and New Jersey, not being agents licensed

by the Commissioner of the New York State Department of Taxation and Finance, did

willfully possess or transport for the purpose of sale, thirty thousand or more cigarettes


unlawfully stamped packages, and/or willfully sold or offered for sale thirty thousand or

more cigarettes in any unstamped or unlawfully stamped packages.

PATTERN ACT #229






Law § 470.10(2)(b)(i), in that on or about and between January 22, 2013 and January 24,


York, and in the States of Delaware, Maryland and New Jersey, knowing that one or




147







PATTERN ACT #230

Defendants Basel Ramadan, a.k.a. Abu Salah, Samer Ramadan, a.k.a.





Law § 470.10(1)(b)(i)(A), in that on or about and between January 22, 2013 and January


New York, and in the States of Delaware, Maryland and New Jersey, knowing that the







thousand dollars.

148

PATTERN ACT #231






1814(a)(i), in that on or about and between January 26, 2013 and January 30, 2013, in the


the States of Delaware, Maryland and New Jersey, did willfully attempt in any manner to

evade or defeat the taxes imposed pursuant to New York State Tax Law or payment

thereof on ten thousand or more cigarettes.

PATTERN ACT #232












149




PATTERN ACT #233





Penal Law § 470.10(2)(b)(i), in that on or about and between January 26, 2013 and












PATTERN ACT #234



150



Penal Law § 470.10(1)(b)(i)(A), in that on or about and between January 26, 2013 and









dollars.

PATTERN ACT #235



Mahmoud and Mohannad Seif, each aiding the other and acting in concert, committed

the crime of Attempt to Evade or Defeat Cigarette and Tobacco Products Tax in

violation of N.Y. Tax L. §§ 481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that on or

about April 7, 2013, in the County of Kings and elsewhere within the State of New York,




151

PATTERN ACT #236



Mahmoud and Mohannad Seif, each aiding the other and acting in concert, committed

the crime of Possession or Transport for the Purpose of Sale, or Sale or Offering For

Sale, of Thirty Thousand or More Cigarettes in Unstamped or Unlawfully Stamped


that on or about April 7, 2013, in the County of Kings and elsewhere within the State of

New York, and in the States of Delaware and Maryland, not being agents licensed by the






PATTERN ACT #237




a.k.a. Abu Samir, Bassam Twam, Ahmad Abdelaziz, a.k.a. Al Jaba'I and Mohannad

Seif, each aiding the other and acting in concert, committed the crime of Attempt to


481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that on or about and between March 22,

2013 and March 23, 2013, in the County of Kings, County of Bronx and elsewhere within

152

the State of New York, and in the States of Delaware, Maryland and New Jersey, did



PATTERN ACT #238





Seif, each aiding the other and acting in concert, committed the crime of Possession or




between March 22, 2013 and March 23, 2013, between in the County of Kings, County

of Bronx and elsewhere within the State of New York, and in the States of Delaware,






stamped packages.

PATTERN ACT #239



153



Seif, each aiding the other and acting in concert, committed the crime of Money


or about and between March 22, 2013 and March 23, 2013, in the County of Kings,

County of Bronx and elsewhere within the State of New York, and within the States of





specified criminal conduct, to wit, violation of N.Y. Tax L. § 481(2)(a) & 4 and N.Y.

Tax L. §§ 1814(a)(i) and (c)(2) and Enterprise Corruption, from a place in any county in

this state to or through a place outside that county or to a place in any county in this state




PATTERN ACT #240





154

Seif, each aiding the other and acting in concert, committed the crime of Money


on or about and between March 22, 2013 and March 23, 2013, in the County of Kings,

County of Bronx and elsewhere within the State of New York, and within the States of





N.Y. Tax L. § 481(2)(a) & 4 and N.Y. Tax L. §§ 1814 (a)(i) and (c)(2) and Enterprise



dollars.

PATTERN ACT #241

Defendants Basel Ramadan, a.k.a. Abu Salah and Samer Ramadan, a.k.a.

Abu Mahdy, each aiding the other and acting in concert, committed the crime of Money

Laundering in the Second Degree in violation of Penal Law § 470.15(1)(b)(ii)(A), in

that on or about and between September 2011, and December 2012, in the County of

Kings and elsewhere within the State of New York and within the States of Delaware and

Maryland, knowing that the property, to wit, United States currency, involved in one or

more financial transactions represented the proceeds of specified criminal conduct, to wit,

violation of N.Y. Tax L. § 481(2)(a) & 4 and N.Y. Tax L. §§ 1814 (a)(i) and (c)(2) and

Enterprise Corruption, the defendants conducted one or more such financial transactions

which in fact involved the proceeds of specified criminal conduct, knowing that the

155

transaction or transactions in whole or in part are designed to conceal or disguise the

nature, location, the source, the ownership or control of the proceeds of specified criminal



PATTERN ACT #242

Defendants Basel Ramadan, a.k.a. Abu Salah and Samer Ramadan, a.k.a.

Abu Mahdy, each aiding the other and acting in concert, committed the crime of Money

Laundering in the Second Degree in violation of Penal Law § 470.15(1)(b)(i)(A), in

that on or about and between September 2011 and December 2012, in the County of


Maryland, knowing that the property, to wit, United States currency, involved in one or

more financial transactions represented the proceeds of criminal conduct, to wit, violation

of N.Y. Tax L. §§ 481(a)(i) & 4, N.Y. Tax L. §§ 1814 (a)(i) and (c)(2) and Enterprise

Corruption, the defendants conducted one or more such financial transactions which in

fact involved the proceeds of specified criminal conduct with intent to promote the

carrying on of criminal conduct, and the total value involved in such financial transaction

or transactions exceeded one hundred thousand dollars.

PATTERN ACT #243






156


Muaffaq Askar, each aiding the other and acting in concert with each other and others

known and unknown to the Grand Jury, committed the crime of Conspiracy in the fifth

degree in violation of Penal Law Section 105.05(1), committed as follows:

The defendants, from on or about and between September 2011 and May 10,

2013, in Kings County, Bronx County and elsewhere within the State of New York and

the States of Delaware, Maryland and New Jersey, with intent that conduct constituting a

felony be performed, to wit: Attempt to Evade or Defeat Cigarette and Tobacco

Products Tax in violation of N.Y. Tax L. §481(2)(a) & 4 and N.Y. Tax L. §

1814(a)(i), agreed with one or more persons to engage in or cause the performance of

such conduct.

OVERT ACTS

In furtherance of said conspiracy and to effect the objects thereof, and during the

course thereof, the following overt acts, among others, were committed:

On October 23, 2012, Mohannad Seif and Bassam Twam had a telephone

conversation in which Seif told Twam he was counting money for untaxed cigarettes.

On October 23, 2012, Mohannad Seif and Bassam Twam met and Twam gave

Seif bags containing untaxed cigarettes.

On November 3, 2012, Munther Mahmoud and Basel Ramadan, a.k.a. Abu

Salah had a telephone conversation in which Mahmoud discussed the balance of money

he owed to Ramadan for untaxed cigarettes.

On November 3, 2012, Saad Badr, a.k.a. Abu Nabil and Basel Ramadan, a.k.a.

Abu Salah had a telephone conversation in which Badr discussed the money he owed to

157

Ramadan for untaxed cigarettes, and Ramadan confirmed that Badr had just received

over 30,000 untaxed cigarettes.

On December 26, 2012, Mufeed Attal, a.k.a. Abu Saleem, and Izzat Nimer,

a.k.a. Nimer Izzat, a.k.a. Abu Ali, had a telephone conversation in which Nimer

advised Attal that he brought in excess of 30,000 untaxed cigarettes.

On Decemer 26, 2012, Murad Bishrat sent a text message to Mufeed Attal,

a.k.a. Abu Saleem, that read: 118 Marlboro and 344 Newport.

On December 26, 2012, Murad Bishrat had a telephone conversation with

Mufeed Attal, a.k.a. Abu Saleem to confirm Attal received his order for untaxed

cigarettes.

On January 22, 2013, Ribhi Awawdeh and Adela Buzahrieh, a.k.a. Adel Abu

Zahrieh, had a telephone conversation in which Ribhi Awawdeh stated he wanted to

order 1000 cartons of untaxed cigarettes for himself and another 1000 cartons of untaxed

cigarettes for his brother.

On February 1, 2013, Basel Ramadan, a.k.a. Abu Salah and Yousseff Odeh,

a.k.a. Abu Mahmoud, had a telephone conversation in which Odeh ordered in excess of

30,000 untaxed cigarettes from Basel Ramadan.

On February 10, 2013, Ahmad Abdelaziz, a.k.a. Al Jaba'I and Adela

Buzahrieh, a.k.a. Adel Abu Zahrieh had a telephone conversation in which Ahmad

Abdelaziz told Adela Buzahrieh that he wanted to order 1800 cartons of untaxed

cigarettes.

158

On March 6, 2013, Mohamed Abed Alabed Awawdeh and Adela Buzahrieh,

a.k.a. Adel Abu Zahrieh met up and Adel Abu Zahrieh delivered untaxed cigarettes to

Awawdeh.

On March 11, 2013, Samer Ramadan, a.k.a. Abu Mahdy and Izzat Nimer,

a.k.a. Nimer Izzat, a.k.a. Abu Ali had a telephone conversation in which Nimer ordered

in excess of 30,000 untaxed cigarettes from Samer Ramadan.

On March 15, 2013, Muaffaq Askar and Issa Sulieman had a telephone

conversation in which Askar ordered a quantity of untaxed cigarettes from Sulieman.

On March 30, 2013, Basel Ramadan, a.k.a. Abu Salah was present at a storage

facility located at Dagsboro, Delaware.

COUNT TWO

THE GRAND JURY OF THE COUNTY OF KINGS, by this Indictment,

accuses the Defendants Basel Ramadan, a.k.a. Abu Salah, Samer Ramadan, a.k.a.




in concert, of the crime of Attempt to Evade or Defeat Cigarette and Tobacco

Products Tax in violation of N.Y. Tax L. § 481(2)(a) & 4 and N.Y. Tax L. §

1814(a)(i), in that on or about and between January 31 and February 2, 2013, in the




159

COUNT THREE






in concert, of the crime of Possession or Transport for the Purpose of Sale, or Sale or


Unlawfully Stamped Packages in violation of N.Y. Tax L. § 481(2)(a) & 4 and N.Y.

Tax L. § 1814(c)(2), in that on or about and between January 31 and February 2, 2013, in

the County of Kings, not being agents licensed by the Commissioner of the New York


purpose of sale, thirty thousand (30,000) or more cigarettes subject to the tax imposed


and/or willfully sold or offered for sale thirty thousand (30,000) or more cigarettes in any


COUNT FOUR






in concert, of the crime of Money Laundering in the Third Degree in violation of

160

Penal Law § 470.10(2)(b)(i), in that on or about and between January 31 and February 2,

2013, in the County of Kings, knowing that one or more monetary instruments




conduct, as that term is defined in Article 470 of the Penal Law, from a place in any





COUNT FIVE






in concert, of the crime of Money Laundering in the Third Degree in violation of

Penal Law § 470.10(1)(b)(i)(A), in that on or about and between January 31 and

February 2, 2013, in the County of Kings, knowing that the property involved in one or


conducted one or more such financial transactions which in fact involved the

proceeds of specified criminal conduct, as that term is defined under Article 470 of the

161

Penal Law, with intent to promote the carrying on of criminal conduct, and the total value

involved in such financial transaction or transactions exceeded fifty thousand dollars.

COUNT SIX






Askar, each aiding the other and acting in concert, of the crime of Attempt to Evade or

Defeat Cigarette and Tobacco Products Tax in violation of N.Y. Tax L. §481(2)(a) &

4 and N.Y. Tax L. § 1814(a)(i), in that on or about and between March 12 and March

14, 2013, in the County of Kings, did willfully attempt in any manner to evade or defeat


thousand (10,000) or more cigarettes.

COUNT SEVEN






Askar, each aiding the other and acting in concert, of the crime of Possession or



162

N.Y. Tax L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about and

between March 12 and March 14, 2013, in the County of Kings, not being agents licensed


willfully possess or transport for the purpose of sale, thirty thousand (30,000) or more




COUNT EIGHT






Askar, each aiding the other and acting in concert, of the crime of Money Laundering

in the Third Degree in violation of Penal Law § 470.10(2)(b)(i), in that on or about and

between March 12 and March 14, 2013, in the County of Kings, knowing that one or

more monetary instruments represented the proceeds of criminal conduct, the defendants



specified criminal conduct, as that term is defined in Article 470 of the Penal Law, from a


163




COUNT NINE






Askar, each aiding the other and acting in concert, of the crime of Money Laundering


and between March 12 and March 14, 2013, knowing that the property involved in one or



specified criminal conduct, as that term is defined under Article 470 of the Penal Law,

with intent to promote the carrying on of criminal conduct, and the total value involved in

such financial transaction or transactions exceeded fifty thousand dollars.

COUNT TEN



Abu Mahdy, Izzat Nimer, a.k.a. Nimer Izzat, a.k.a. Abu Ali and Mufeed Attal, a.k.a.

Abu Saleem, each aiding the other and acting in concert, of the crime of Attempt to

Evade or Defeat Cigarette and Tobacco Products Tax in violation of N.Y. Tax L.

164

§481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that on or about March 11, 2013, in the




COUNT ELEVEN




Abu Saleem, each aiding the other and acting in concert, of the crime of Possession or



N.Y. Tax L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about March

11, 2013, in the County of Kings, not being agents licensed by the Commissioner of the


for the purpose of sale, thirty thousand (30,000) or more cigarettes subject to the tax


packages, and/or willfully sold or offered for sale thirty thousand (30,000) or more


COUNT TWELVE


accuses the Defendants, Basel Ramadan, a.k.a. Abu Salah, Samer Ramadan, a.k.a.


Abu Saleem, each aiding the other and acting in concert, of the crime of Money

165


on or about March 11, 2013, in the County of Kings, knowing that one or more monetary

instruments represented the proceeds of criminal conduct, the defendants transported,

transmitted, or transferred, on one or more occasions, monetary instruments which in fact

represented the proceeds of specified criminal conduct, as that term is defined in Article

470 of the Penal Law, with intent to promote the carrying on of criminal conduct, and the

total value of such monetary instrument or instruments exceeded ten thousand dollars.

COUNT THIRTEEN






that on or about March 11, 2013, in the County of Kings, knowing that the property



involved the proceeds of specified criminal conduct, as that term is defined under Article



dollars.

166

COUNT FOURTEEN










COUNT FIFTEEN







N.Y. Tax L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about March 3,

2013, in the County of Kings, not being agents licensed by the Commissioner of the New




167



COUNT SIXTEEN






or about March 3, 2013, in the County of Kings, knowing that one or more monetary




criminal conduct, as that term is defined in Article 470 of the Penal Law, from a place in

any county in this state to or through a place outside that county or to a place in any

county in this state from or through a place outside that county, with intent to promote

the carrying on of criminal conduct, and the total value of such monetary instrument or

instruments exceeded fifty thousand dollars.

COUNT SEVENTEEN






168







dollars.

COUNT EIGHTEEN










COUNT NINETEEN


accuses the Defendants, Basel Ramadan, a.k.a. Abu Salah, Samer Ramadan, a.k.a.




169









COUNT TWENTY















170

COUNT TWENTY-ONE






on or about March 12, 2013, in the County of Kings, knowing that the property involved

in one or more financial transactions represented the proceeds of criminal conduct, the





COUNT TWENTY-TWO





Alabed Awawdeh, a.k.a. Abu Samir, each aiding the other and acting in concert, of the

crime of Attempt to Evade or Defeat Cigarette and Tobacco Products Tax in

violation of N.Y. Tax L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that on or

about March 27, 2013, in the County of Kings, did willfully attempt in any manner to

evade or defeat the taxes imposed pursuant to New York State Tax Law or payment

thereof on ten thousand (10,000) or more cigarettes.

171

COUNT TWENTY-THREE






crime of Possession or Transport for the Purpose of Sale, or Sale or Offering For


Packages in violation of N.Y. Tax L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in

that on or about March 27, 2013, in the County of Kings, not being agents licensed by the


possess or transport for the purpose of sale, thirty thousand (30,000) or more cigarettes


unlawfully stamped packages, and/or willfully sold or offered for sale thirty thousand


COUNT TWENTY-FOUR






crime of Money Laundering in the Third Degree in violation of Penal Law §

172

470.10(2)(b)(i), in that on or about March 27, 2013, in the County of Kings, knowing that

one or more monetary instruments represented the proceeds of criminal conduct, the



proceeds of specified criminal conduct, as that term is defined in Article 470 of the Penal

Law, from a place in any county in this state to or through a place outside that county or

to a place in any county in this state from or through a place outside that county, with


monetary instrument or instruments exceeded fifty thousand dollars.

COUNT TWENTY-FIVE







470.10(1)(b)(i)(A), in that on or about March 27, 2013, in the County of Kings, knowing

that the property involved in one or more financial transactions represented the proceeds


which in fact involved the proceeds of specified criminal conduct, as that term is defined

under Article 470 of the Penal Law, with intent to promote the carrying on of criminal

173



COUNT TWENTY-SIX






other and acting in concert, of the crime of Attempt to Evade or Defeat Cigarette and

Tobacco Products Tax in violation of N.Y. Tax L. §481(2)(a) & 4 and N.Y. Tax L. §

1814(a)(i), in that on or about and between March 28 and March 30, 2013, in the County

of Kings, did willfully attempt in any manner to evade or defeat the taxes imposed

pursuant to New York State Tax Law or payment thereof on ten thousand (10,000) or

more cigarettes.

COUNT TWENTY-SEVEN






other and acting in concert, of the crime of Possession or Transport for the Purpose of


Unstamped or Unlawfully Stamped Packages in violation of N.Y. Tax L. §481(2)(a)

174

& 4 and N.Y. Tax L. § 1814(c)(2), in that on or about and between March 28 and

March 30, 2013, in the County of Kings, not being agents licensed by the Commissioner

of the New York State Department of Taxation and Finance, did willfully possess or

transport for the purpose of sale, thirty thousand (30,000) or more cigarettes subject to the

tax imposed pursuant to New York State Law in any unstamped or unlawfully stamped



COUNT TWENTY-EIGHT






other and acting in concert, of the crime of Money Laundering in the Third Degree in

violation of Penal Law § 470.10(2)(b)(i), in that on or about and between March 28 and

March 30, 2013, in the County of Kings, knowing that one or more monetary instruments







175



COUNT TWENTY-NINE






other and acting in concert, of the crime of Money Laundering in the Third Degree in

violation of Penal Law § 470.10(1)(b)(i)(A), in that on or about and between March 28

and March 30, 2013, in the County of Kings, knowing that the property involved in one

or more financial transactions represented the proceeds of criminal conduct, the





COUNT THIRTY



Abu Mahdy, Munther Mahmoud, Bassam Twam, Murad Bishrat and Mohannad

Seif, each aiding the other and acting in concert, of the crime of Attempt to Evade or


176

4 and N.Y. Tax L. § 1814(a)(i), in that on or about and between October 21 and October




COUNT THIRTY-ONE




Seif, each aiding the other and acting in concert, of the crime of Possession or




between October 21 and October 28, 2012, in the County of Kings, not being agents


Finance, did willfully possess or transport for the purpose of sale, thirty thousand

(30,000) or more cigarettes subject to the tax imposed pursuant to New York State Law


sale thirty thousand (30,000) or more cigarettes in any unstamped or unlawfully stamped

packages.

COUNT THIRTY-TWO




177

Seif, each aiding the other and acting in concert, of the crime of Money Laundering in

the Third Degree in violation of Penal Law § 470.10(2)(b)(i), in that on or about and

between October 21 and October 28, 2012, in the County of Kings, knowing that one or









COUNT THIRTY-THREE





the Third Degree in violation of Penal Law § 470.10(1)(b)(i)(A), in that on or about

and between October 21 and October 28, 2012, in the County of Kings, knowing that the

property involved in one or more financial transactions represented the proceeds of




178



COUNT THIRTY-FOUR



Abu Mahdy, Munther Mahmoud and Nabiel Saad Badr, a.k.a. Abu Nabil, each

aiding the other and acting in concert, of the crime of Possession or Transport for the



L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about October 31, 2012,







COUNT THIRTY-FIVE




aiding the other and acting in concert, of the crime of Attempt to Evade or Defeat

Cigarette and Tobacco Products Tax in violation of N.Y. Tax L. §481(2)(a) & 4 and

N.Y. Tax L. § 1814(a)(i), in that on or about October 31, 2012, in the County of Kings,

179


York State Tax Law or payment thereof on ten thousand (10,000) or more cigarettes.

COUNT THIRTY-SIX







L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about November 1, 2012,







COUNT THIRTY-SEVEN






N.Y. Tax L. § 1814(a)(i), in that on or about November 1, 2012, in the County of Kings,

180



COUNT THIRTY-EIGHT














COUNT THIRTY-NINE







181



COUNT FORTY














COUNT FORTY-ONE







182



COUNT FORTY-TWO




aiding the other and acting in concert, of the crime of Money Laundering in the Third


October 31 and November 3, 2012, in the County of Kings, knowing that the property






dollars.

COUNT FORTY-THREE






October 31 and November 3, 2012, in the County of Kings, knowing that one or more

monetary instruments represented the proceeds of criminal conduct, the defendants

183








COUNT FORTY-FOUR






N.Y. Tax L. § 1814(a)(i), in that on or about and between November 7 and November 8,

2012, in the County of Kings, did willfully attempt in any manner to evade or defeat the



COUNT FORTY-FIVE






184


L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about and between

November 7 and November 8, 2012, in the County of Kings, not being agents licensed by

the Commissioner of the New York State Department of Taxation and Finance, did





COUNT FORTY-SIX






November 7 and November 8, 2012, in the County of Kings, knowing that one or more









185

COUNT FORTY-SEVEN






November 7 and November 8, 2012, in the County of Kings, knowing that the property






dollars.

COUNT FORTY-EIGHT






N.Y. Tax L. § 1814(a)(i), in that on or about November 15, 2012, in the County of

Kings, did willfully attempt in any manner to evade or defeat the taxes imposed pursuant

to New York State Tax Law or payment thereof on ten thousand (10,000) or more

cigarettes.

186

COUNT FORTY-NINE







L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about November 15,







COUNT FIFTY




aiding the other and acting in concert, of the crime of Money Laundering in the Second


November 14 and November 15, 2012, in the County of Kings, knowing that one or more

monetary instruments represented the proceeds of specified criminal conduct, the


187





intent to promote the carrying on of specified criminal conduct, and the total value of

such monetary instrument or instruments exceeded one hundred thousand dollars.

COUNT FIFTY-ONE






November 14 and November 15, 2012, in the County of Kings, knowing that the property

involved in one or more financial transactions represented the proceeds of specified



under Article 470 of the Penal Law, with intent to promote the carrying on of specified



COUNT FIFTY-TWO




188



N.Y. Tax L. § 1814(a)(i), in that on or about January 19, 2013, in the County of Kings,



COUNT FIFTY-THREE







L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about January 19, 2013,







COUNT FIFTY-FOUR




189






COUNT FIFTY-FIVE














COUNT FIFTY-SIX




190






COUNT FIFTY-SEVEN














COUNT FIFTY-EIGHT




191



January 19 and January 24, 2013, in the County of Kings, knowing that one or more








instrument or instruments exceeded one hundred thousand dollars.

COUNT FIFTY-NINE






January 19 and January 24, 2013, in the County of Kings, knowing that the property





192



COUNT SIXTY






N.Y. Tax L. § 1814(a)(i), in that on or about February 12, 2013, in the County of Kings,



COUNT SIXTY-ONE







L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about February 12, 2013,




193




COUNT SIXTY-TWO









COUNT SIXTY-THREE



Abu Mahdy, Munther Mahmoud and Nabiel Saad Badr, a.k.a. Abu Nabil , each








194




COUNT SIXTY-FOUR









COUNT SIXTY-FIVE











195




COUNT SIXTY-SIX









COUNT SIXTY-SEVEN











196




COUNT SIXTY-EIGHT









COUNT SIXTY-NINE



Abu Mahdy, Munther Mahmoud and Nabiel Saad Badr, a.k.a. Abu Nabil , each








197




COUNT SEVENTY






February 12 and February 17, 2013, in the County of Kings, knowing that one or more

monetary instruments represented the proceeds of specified criminal conduct, the






intent to promote the carrying on of specified criminal conduct, and the total value of

such monetary instrument or instruments exceeded one hundred thousand dollars.

COUNT SEVENTY-ONE





198


February 12 and February 17, 2013, in the County of Kings, knowing that the property







COUNT SEVENTY-TWO






§481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that on or about December 4, 2012, in

the County of Kings, did willfully attempt in any manner to evade or defeat the taxes



COUNT SEVENTY-THREE





199



N.Y. Tax L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about

December 4, 2012, in the County of Kings, not being agents licensed by the






COUNT SEVENTY-FOUR





Laundering in the Third Degree in violation of Penal Law § 470.10(2)(b)(i), in that

on or about December 4, 2012, in the County of Kings, knowing that one or more







200



COUNT SEVENTY-FIVE






on or about December 4, 2012, in the County of Kings, knowing that the property






dollars.

COUNT SEVENTY-SIX




Abu Saleem, each aiding the other and acting in concert, of the crime of Criminal

Possession of a Forged Instrument in the First Degree in violation of Penal Law §

170.30, in that on or about December 4, 2012, with knowledge that it is forged and with

201

intent to defraud, deceive or injure another, the defendants uttered any forged instrument

of a kind specified in Penal Law section 170.15.

COUNT SEVENTY-SEVEN


accuses the Defendants Basel Ramadan, a.k.a. Abu Salah, Adela Buzahrieh, a.k.a.

Adel Abu Zahrieh, Yousseff Odeh, a.k.a. Abu Mahmoud, Mufeed Attal, a.k.a. Abu


acting in concert, of the crime of Possession or Transport for the Purpose of Sale, or


Unlawfully Stamped Packages in violation of N.Y. Tax L. §481(2)(a) & 4 and N.Y.

Tax L. § 1814(c)(2), in that on or about November 4, 2012, in the County of Kings, not



thousand (30,000) or more cigarettes subject to the tax imposed pursuant to New York


offered for sale thirty thousand (30,000) or more cigarettes in any unstamped or

unlawfully stamped packages.

COUNT SEVENTY-EIGHT





acting in concert, of the crime of Attempt to Evade or Defeat Cigarette and Tobacco

202


1814(a)(i), in that on or about November 4, 2012, in the County of Kings, did willfully


Tax Law or payment thereof on ten thousand (10,000) or more cigarettes.

COUNT SEVENTY-NINE





acting in concert, of the crime of Money Laundering in the Fourth Degree in violation

of Penal Law § 470.05(2)(a)(i), in that on or about November 4, 2012, in the County of

Kings knowing that one or more monetary instruments represented the proceeds of

criminal conduct, the defendants transported, transmitted, or transferred, on one or more


criminal conduct, as that term is defined in Article 470 of the Penal Law, with intent to


instrument or instruments exceeded ten thousand dollars.

COUNT EIGHTY






203

of Penal Law § 470.05(1)(a)(i)(A), in that on or about November 4, 2012, in the County

of Kings, knowing that the property involved in one or more financial transactions



as that term is defined under Article 470 of the Penal Law, with intent to promote the


or transactions exceeded five thousand dollars.

COUNT EIGHTY-ONE


accuses the Defendants Basel Ramadan, a.k.a. Abu Salah, Izzat Nimer, a.k.a. Nimer





L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about November 30,







204

COUNT EIGHTY-TWO






N.Y. Tax L. § 1814(a)(i), in that on or about November 30, 2012, in the County of



cigarettes.

COUNT EIGHTY-THREE




aiding the other and acting in concert, of the crime of Money Laundering in the Fourth

Degree in violation of Penal Law § 470.05(2)(a)(i), in that on or about November 30,





conduct, as that term is defined in Article 470 of the Penal Law, with intent to promote


instruments exceeded ten thousand dollars.

205

COUNT EIGHTY-FOUR




aiding the other and acting in concert, of the crime of Money Laundering in the Fourth

Degree in violation of Penal Law § 470.05(1)(a)(i)(A), in that on or about November 30,

2012, in the County of Kings, knowing that the property involved in one or more





such financial transaction or transactions exceeded five thousand dollars.

COUNT EIGHTY-FIVE



Abu Mahdy, Adela Buzahrieh, a.k.a. Adel Abu Zahrieh, Izzat Nimer, a.k.a. Nimer




N.Y. Tax L. § 1814(a)(i), in that on or about and between December 26 and December




206

COUNT EIGHTY-SIX








L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about and between

December 26 and December 27, 2012, in the County of Kings, not being agents licensed






COUNT EIGHTY-SEVEN







December 26 and December 27, 2012, in the County of Kings, knowing that one or more

207









COUNT EIGHTY-EIGHT







December 26 and December 27, 2012, in the County of Kings, knowing that the property






dollars.

208

COUNT EIGHTY-NINE






1814(a)(i), in that on or about February 3, 2013, in the County of Kings, did willfully



COUNT NINETY







Tax L. § 1814(c)(2), in that on or about February 3, 2013, in the County of Kings, not







209

COUNT NINETY-ONE





of Penal Law § 470.05(2)(a)(i), in that on or about February 3, 2013, in the County of

Kings, knowing that one or more monetary instruments represented the proceeds of






COUNT NINETY-TWO





of Penal Law § 470.05(1)(a)(i)(A), in that on or about February 3, 2013, in the County of

Kings, knowing that the property involved in one or more financial transactions




210



COUNT NINETY-THREE






§481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that on or about February 5, 2013, in




COUNT NINETY-FOUR







N.Y. Tax L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about February



211





COUNT NINETY-FIVE






on or about February 5, 2013, in the County of Kings, knowing that one or more


transported, transmitted, or transferred, on one or more occasions, monetary instruments

which in fact represented the proceeds of specified criminal conduct, as that term is

defined in Article 470 of the Penal Law, with intent to promote the carrying on of



COUNT NINETY-SIX






212

that on or about February 5, 2013, in the County of Kings, knowing that the property






dollars.

COUNT NINETY-SEVEN






§481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that on or abut February 10, 2013, in




COUNT NINETY-EIGHT






213









COUNT NINETY-NINE






on or about February 10, 2013, in the County of Kings, knowing that one or more


transported, transmitted, or transferred, on one or more occasions, monetary instruments

which in fact represented the proceeds of specified criminal conduct, as that term is

defined in Article 470 of the Penal Law, with intent to promote the carrying on of



COUNT ONE HUNDRED

214






that on or about February 10, 2013, in the County of Kings, knowing that the property






dollars.

COUNT ONE HUNDRED-ONE









215



COUNT ONE HUNDRED-TWO
















COUNT ONE HUNDRED-THREE





216


in concert, of the crime of Money Laundering in the Second Degree in violation of

Penal Law § 470.15(2)(b)(i), in that on or about February 11, 2013, in the County of




instruments which in fact represented the proceeds of specified criminal conduct, as that

term is defined in Article 470 of the Penal Law, from a place in any county in this state to


through a place outside that county, with intent to promote the carrying on of specified



COUNT ONE HUNDRED-FOUR







Penal Law § 470.15(1)(b)(i)(A), in that on or about February 11, 2013, in the County of




217

conduct, as that term is defined under Article 470 of the Penal Law, with intent to

promote the carrying on of specified criminal conduct, and the total value involved in

such financial transaction or transactions exceeded one hundred thousand dollars.

COUNT ONE HUNDRED-FIVE










COUNT ONE HUNDRED-SIX










218





COUNT ONE HUNDRED-SEVEN






or about February 16, 2013, in the County of Kings, knowing that one or more monetary









COUNT ONE HUNDRED-EIGHT




219



on or about February 16, 2013, in the County of Kings, knowing that the property






dollars.

COUNT ONE HUNDRED-NINE










COUNT ONE HUNDRED-TEN




220











COUNT ONE HUNDRED-ELEVEN













221



COUNT ONE HUNDRED-TWELVE












dollars.

COUNT ONE HUNDRED-THIRTEEN







222




COUNT ONE HUNDRED-FOURTEEN














COUNT ONE HUNDRED-FIFTEEN






223










COUNT ONE HUNDRED-SIXTEEN












dollars.

224

COUNT ONE HUNDRED-SEVENTEEN










COUNT ONE HUNDRED-EIGHTEEN












225



COUNT ONE HUNDRED-NINETEEN















COUNT ONE HUNDRED TWENTY






226







dollars.

COUNT ONE HUNDRED TWENTY-ONE










COUNT ONE HUNDRED TWENTY-TWO






227









COUNT ONE HUNDRED TWENTY-THREE













228



COUNT ONE HUNDRED TWENTY-FOUR












dollars.

COUNT ONE HUNDRED TWENTY-FIVE







229



COUNT ONE HUNDRED TWENTY-SIX














COUNT ONE HUNDRED TWENTY-SEVEN





of Penal Law § 470.05(2)(a)(i), in that on or about February 24, 2013, in the County of


230






COUNT ONE HUNDRED TWENTY-EIGHT





of Penal Law § 470.05(1)(a)(i)(A), in that on or about February 24, 2013, in the County

of Kings, knowing that the property involved in one or more financial transactions






COUNT ONE HUNDRED TWENTY-NINE






231





COUNT ONE HUNDRED THIRTY














COUNT ONE HUNDRED THIRTY-ONE





232











COUNT ONE HUNDRED THIRTY-TWO












dollars.

233

COUNT ONE HUNDRED THIRTY-THREE










COUNT ONE HUNDRED THIRTY-FOUR












234



COUNT ONE HUNDRED THIRTY-FIVE















COUNT ONE HUNDRED THIRTY-SIX






235

on or about March 2, 2013, in the County of Kings, knowing that the property involved in

one or more financial transactions represented the proceeds of criminal conduct, the





COUNT ONE HUNDRED THIRTY-SEVEN










COUNT ONE HUNDRED THIRTY-EIGHT







236








COUNT ONE HUNDRED THIRTY-NINE















237

COUNT ONE HUNDRED FORTY






on or about March 2, 2013, in the County of Kings, knowing that the property involved in

one or more financial transactions represented the proceeds of criminal conduct, the





COUNT ONE HUNDRED FORTY-ONE










238

COUNT ONE HUNDRED FORTY-TWO














COUNT ONE HUNDRED FORTY-THREE









239




COUNT ONE HUNDRED FORTY-FOUR












dollars.

COUNT ONE HUNDRED FORTY-FIVE







240








COUNT ONE HUNDRED FORTY-SIX










COUNT ONE HUNDRED FORTY-SEVEN





Transport for the Purpose of Sale, or Sale or Offering For Sale, of Ten Thousand or

241

More Cigarettes in Unstamped or Unlawfully Stamped Packages in violation of N.Y.

Tax L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(1), in that on or about March 15,



purpose of sale, ten thousand (10,000) or more cigarettes subject to the tax imposed


and/or willfully sold or offered for sale ten thousand (10,000) or more cigarettes in any


COUNT ONE HUNDRED FORTY-EIGHT










COUNT ONE HUNDRED FORTY-NINE





242










COUNT ONE HUNDRED FIFTY













243



COUNT ONE HUNDRED FIFTY-ONE












COUNT ONE HUNDRED FIFTY-TWO








244



COUNT ONE HUNDRED FIFTY-THREE














COUNT ONE HUNDRED FIFTY-FOUR







245









COUNT ONE HUNDRED FIFTY-FIVE












COUNT ONE HUNDRED FIFTY-SIX



246








COUNT ONE HUNDRED FIFTY-SEVEN














247

COUNT ONE HUNDRED FIFTY-EIGHT















COUNT ONE HUNDRED FIFTY-NINE








248





COUNT ONE HUNDRED SIXTY



Abu Mahdy, Adela Buzahrieh, a.k.a. Adel Abu Zahrieh, Ahmad Abdelaziz, a.k.a. Al


each aiding the other and acting in concert, of the crime of Attempt to Evade or Defeat


N.Y. Tax L. § 1814(a)(i), in that on or about December 26, 2012, in the County of Kings,



COUNT ONE HUNDRED SIXTY-ONE





each aiding the other and acting in concert, of the crime of Possession or Transport for

the Purpose of Sale, or Sale or Offering For Sale, of Thirty Thousand or More


L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or about December 26,

249







COUNT ONE HUNDRED SIXTY-TWO





each aiding the other and acting in concert, of the crime of Money Laundering in the

Third Degree in violation of Penal Law § 470.10(2)(b)(i), in that on or about December

26, 2012, in the County of Kings, knowing that one or more monetary instruments









250

COUNT ONE HUNDRED SIXTY-THREE






Third Degree in violation of Penal Law § 470.10(1)(b)(i)(A), in that on or about

December 26, 2012, in the County of Kings, knowing that the property involved in one or






COUNT ONE HUNDRED SIXTY-FOUR








1814(a)(i), in that on or about January 7, 2013, in the County of Kings, did willfully

251



COUNT ONE HUNDRED SIXTY-FIVE









Tax L. § 1814(c)(2), in that on or about January 7, 2013, in the County of Kings, not







COUNT ONE HUNDRED SIXTY-SIX





252


acting in concert, of the crime of Money Laundering in the Third Degree in violation

of Penal Law § 470.10(2)(b)(i), in that on or about January 7, 2013, in the County of




fact represented the proceeds of specified criminal conduct, as that term is defined in

Article 470 of the Penal Law, from a place in any county in this state to or through a




dollars.

COUNT ONE HUNDRED SIXTY-SEVEN






acting in concert, of the crime of Money Laundering in the Third Degree in violation

of Penal Law § 470.10(1)(b)(i)(A), in that on or about January 7, 2013, in the County of




253



or transactions exceeded fifty thousand dollars.

COUNT ONE HUNDRED SIXTY-EIGHT



Adel Abu Zahrieh, Ribhi Awawdeh, Mohamed Abed Alabed Awawdeh, a.k.a. Abu

Samir and Ahmad Abdelaziz, a.k.a. Al Jaba'I, each aiding the other and acting in

concert, of the crime of Attempt to Evade or Defeat Cigarette and Tobacco Products

Tax in violation of N.Y. Tax L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that

on or about January 9, 2013, in the County of Kings, did willfully attempt in any manner

to evade or defeat the taxes imposed pursuant to New York State Tax Law or payment

thereof on ten thousand (10,000) or more cigarettes.

COUNT ONE HUNDRED SIXTY-NINE





concert, of the crime of Possession or Transport for the Purpose of Sale, or Sale or



Tax L. § 1814(c)(2), in that on or about January 9, 2013, in the County of Kings, not


254






COUNT ONE HUNDRED SEVENTY





concert, of the crime of Money Laundering in the Third Degree in violation of Penal

Law § 470.10(2)(b)(i), in that on or about January 9, 2013, in the County of Kings,

knowing that one or more monetary instruments represented the proceeds of criminal




470 of the Penal Law, from a place in any county in this state to or through a place




dollars.

255

COUNT ONE HUNDRED SEVENTY-ONE






Law § 470.10(1)(b)(i)(A), in that on or about January 9, 2013, in the County of Kings,

knowing that the property involved in one or more financial transactions represented the


transactions which in fact involved the proceeds of specified criminal conduct, as that

term is defined under Article 470 of the Penal Law, with intent to promote the carrying



COUNT ONE HUNDRED SEVENTY-TWO



Abu Mahdy, Adela Buzahrieh, a.k.a. Adel Abu Zahrieh, Ribhi Awawdeh, Mohamed


each aiding the other and acting in concert, of the crime of Attempt to Evade or Defeat





256

COUNT ONE HUNDRED SEVENTY-THREE





each aiding the other and acting in concert, of the crime of Possession or Transport for

the Purpose of Sale, or Sale or Offering For Sale, of Thirty Thousand or More









COUNT ONE HUNDRED SEVENTY-FOUR






Third Degree in violation of Penal Law § 470.10(2)(b)(i) in that on or about January 27,


257









COUNT ONE HUNDRED SEVENTY-FIVE






Third Degree in violation of Penal Law § 470.10(1)(b)(i)(A), in that on or about

January 27, 2013, in the County of Kings, knowing that the property involved in one or






258

COUNT ONE HUNDRED SEVENTY-SIX











COUNT ONE HUNDRED SEVENTY-SEVEN












259





COUNT ONE HUNDRED SEVENTY-EIGHT

















260

COUNT ONE HUNDRED SEVENTY-NINE














COUNT ONE HUNDRED EIGHTY









261



COUNT ONE HUNDRED EIGHTY-ONE
















COUNT ONE HUNDRED EIGHTY-TWO





262













COUNT ONE HUNDRED EIGHTY-THREE











263




COUNT ONE HUNDRED EIGHTY-FOUR





and acting in concert, of the crime of Attempt to Evade or Defeat Cigarette and


1814(a)(i), in that on or about March 16, 2013, in the County of Kings, did willfully



COUNT ONE HUNDRED EIGHTY-FIVE





and acting in concert, of the crime of Possession or Transport for the Purpose of Sale,

or Sale or Offering For Sale, of Thirty Thousand or More Cigarettes in Unstamped

or Unlawfully Stamped Packages in violation of N.Y. Tax L. §481(2)(a) & 4 and

N.Y. Tax L. § 1814(c)(2), in that on or about March 16, 2013, in the County of Kings,


264






COUNT ONE HUNDRED EIGHTY-SIX





and acting in concert, of the crime of Money Laundering in the Third Degree in

violation of Penal Law § 470.10(2)(b)(i), in that on or about March 16, 2013, in the

County of Kings, knowing that one or more monetary instruments represented the








thousand dollars.

265

COUNT ONE HUNDRED EIGHTY-SEVEN





and acting in concert, of the crime of Money Laundering in the Third Degree in

violation of Penal Law § 470.10(1)(b)(i)(A), in that on or about March 16, 2013, in the

County of Kings, knowing that the property involved in one or more financial



criminal conduct, as that term is defined under Article 470 of the Penal Law, with intent

to promote the carrying on of criminal conduct, and the total value involved in such


COUNT ONE HUNDRED EIGHTY-EIGHT





a.k.a. Al Jaba'I, each aiding the other and acting in concert, of the crime of Attempt to




266



COUNT ONE HUNDRED EIGHTY-NINE





a.k.a. Al Jaba'I, each aiding the other and acting in concert, of the crime of Possession



violation of N.Y. Tax L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or

about March 20, 2013, in the County of Kings, not being agents licensed by the






COUNT ONE HUNDRED NINETY





a.k.a. Al Jaba'I, each aiding the other and acting in concert, of the crime of Money

267

Laundering in the Second Degree in violation of Penal Law § 470.15(2)(b)(i), in that


instruments represented the proceeds of specified criminal conduct, the defendants








COUNT ONE HUNDRED NINETY-ONE





a.k.a. Al Jaba'I, each aiding the other and acting in concert, of the crime of Money







268



COUNT ONE HUNDRED NINETY-TWO







on or about February 13, 2013, in the County of Kings, did willfully attempt in any

manner to evade or defeat the taxes imposed pursuant to New York State Tax Law or

payment thereof on ten thousand (10,000) or more cigarettes.

COUNT ONE HUNDRED NINETY-THREE











269





COUNT ONE HUNDRED NINETY-FOUR




Mahmoud, Issa Sulieman and Muaffaq Askar, of the crime of Money Laundering in

the Fourth Degree in violation of Penal Law § 470.05(2)(a)(i), in that on or about

February 13, 2013, in the County of Kings, knowing that one or more monetary






COUNT ONE HUNDRED NINETY-FIVE





the Fourth Degree in violation of Penal Law § 470.05(1)(a)(i)(A), in that on or about


270






COUNT ONE HUNDRED NINETY-SIX







on or about February 21, 2013, in the County of Kings, did willfully attempt in any

manner to evade or defeat the taxes imposed pursuant to New York State Tax Law or

payment thereof on ten thousand (10,000) or more cigarettes.

COUNT ONE HUNDRED NINETY-SEVEN








271








COUNT ONE HUNDRED NINETY-EIGHT





the Fourth Degree in violation of Penal Law § 470.05(2)(a)(i), in that on or about

February 21, 2013, in the County of Kings, knowing that one or more monetary






COUNT ONE HUNDRED NINETY-NINE




272


the Fourth Degree in violation of Penal Law § 470.05(1)(a)(i)(A), in that on or about







COUNT TWO HUNDRED






Mohannad Seif, each aiding the other and acting in concert, of the crime of Attempt to

Evade or Defeat Cigarette and Tobacco Products Tax in violation of N.Y. Tax L. §





COUNT TWO HUNDRED-ONE



273




Mohannad Seif, each aiding the other and acting in concert, of the crime of Possession



violation of N.Y. Tax L. § 481(2)(a) & 4 and N.Y. Tax L. § 1814(c)(2), in that on or

about March 6, 2013, in the County of Kings, not being agents licensed by the






COUNT TWO HUNDRED-TWO






Mohannad Seif, each aiding the other and acting in concert, of the crime of Money

Laundering in the Third Degree in violation of Penal Law § 470.10(2)(b)(i), in that



274








COUNT TWO HUNDRED-THREE






Mohannad Seif, each aiding the other and acting in concert, of the crime of Money








dollars.

275

COUNT TWO HUNDRED-FOUR





and acting in concert, of the crime of Attempt to Evade or Defeat Cigarette and


1814(a)(i), in that on or about September 22, 2012, in the County of Kings, did willfully



COUNT TWO HUNDRED-FIVE





and acting in concert, of the crime of Possession or Transport for the Purpose of Sale,

or Sale or Offering For Sale, of Thirty Thousand or More Cigarettes in Unstamped

or Unlawfully Stamped Packages in violation of N.Y. Tax L. §481(2)(a) & 4 and

N.Y. Tax L. § 1814(c)(2), in that on or about September 22, 2012, in the County of

Kings, not being agents licensed by the Commissioner of the New York State Department

of Taxation and Finance, did willfully possess or transport for the purpose of sale, thirty


276




COUNT TWO HUNDRED-SIX





and acting in concert, of the crime of Money Laundering in the Fourth Degree in

violation of Penal Law § 470.05(2)(a)(i), in that on or about September 22, 2012, in the


proceeds of criminal conduct, the defendants transported, transmitted, or transferred, on


specified criminal conduct, as that term is defined in Article 470 of the Penal Law, with



COUNT TWO HUNDRED-SEVEN





and acting in concert, of the crime of Money Laundering in the Fourth Degree in

violation of Penal Law § 470.05(1)(a)(i)(A), in that on or about September 22, 2012, in

277

the County of Kings, knowing that the property involved in one or more financial






COUNT TWO HUNDRED-EIGHT







on or about and between September 28 and September 30, 2012, in the County of Kings,



COUNT TWO HUNDRED-NINE







278


Tax L. § 1814(c)(2), in that on or about and between September 28 and September 30,







COUNT TWO HUNDRED-TEN






Law § 470.10(2)(b)(i), in that on or about and between September 28 and September 30,








279



COUNT TWO HUNDRED-ELEVEN






Law § 470.10(1)(b)(i)(A), in that on or about and between September 28 and September

30, 2012, in the County of Kings, knowing that the property involved in one or more






COUNT TWO HUNDRED-TWELVE







on or about and between October 1 and October 6, 2012, in the County of Kings, did

280



COUNT TWO HUNDRED-THIRTEEN








Tax L. § 1814(c)(2), in that on or about and between October 1 and October 6, 2012, in







COUNT TWO HUNDRED-FOURTEEN






281

Law § 470.10(2)(b)(i), in that on or about and between October 1 and October 6, 2012, in

the County of Kings, knowing that one or more monetary instruments represented the








thousand dollars.

COUNT TWO HUNDRED-FIFTEEN






Law § 470.10(1)(b)(i)(A), in that on or about and between October 1 and October 6,







282

COUNT TWO HUNDRED-SIXTEEN





Issa Sulieman and Mohannad Seif, each aiding the other and acting in concert, of the

crime of Attempt to Evade or Defeat Cigarette and Tobacco Products Tax in


about and between December 21 and December 22, 2012, in the County of Kings, did



COUNT TWO HUNDRED-SEVENTEEN






crime of Possession or Transport for the Purpose of Sale, or Sale or Offering For



that on or about and between December 21 and December 22, 2012, in the County of

Kings, not being agents licensed by the Commissioner of the New York State Department

of Taxation and Finance, did willfully possess or transport for the purpose of sale, thirty

283





COUNT TWO HUNDRED-EIGHTEEN







470.10(2)(b)(i), in that on or about and between December 21 and December 22, 2012, in

the County of Kings, knowing that one or more monetary instruments represented the








thousand dollars.

284

COUNT TWO HUNDRED-NINETEEN







470.10(1)(b)(i)(A), in that on or about and between December 21 and December 22,







COUNT TWO HUNDRED-TWENTY







on or about and between December 29, 2012 and January 3, 2013, in the County of


285


cigarettes.

COUNT TWO HUNDRED TWENTY-ONE








Tax L. § 1814(c)(2), in that on or about and between December 29, 2012 and January 3,







COUNT TWO HUNDRED TWENTY-TWO






286

Law § 470.10(2)(b)(i), in that on or about and between December 29, 2012 and January

3, 2013, in the County of Kings, knowing that one or more monetary instruments









COUNT TWO-HUNDRED TWENTY-THREE






Law § 470.10(1)(b)(i)(A), in that on or about and between December 29, 2012 and

January 3, 2013, in the County of Kings, knowing that the property involved in one or






287

COUNT TWO HUNDRED TWENTY-FOUR







on or about and between January 13 and January 14, 2013, in the County of Kings, did



COUNT TWO HUNDRED TWENTY-FIVE








Tax L. § 1814(c)(2), in that on or about and between January 13 and January 14, 2013, in





288



COUNT TWO HUNDRED TWENTY-SIX






Law § 470.10(2)(b)(i), in that on or about and between January 13 and January 14, 2013,

in the County of Kings, knowing that one or more monetary instruments represented the








thousand dollars.

COUNT TWO HUNDRED TWENTY-SEVEN





289


Law § 470.10(1)(b)(i)(A), in that on or about and between January 13 and January 14,







COUNT TWO HUNDRED TWENTY-EIGHT





a.k.a. Abu Samir and Mohannad Seif, each aiding the other and acting in concert, of

the crime of Attempt to Evade or Defeat Cigarette and Tobacco Products Tax in


about and between January 22 and January 24, 2013, in the County of Kings, did



COUNT TWO HUNDRED TWENTY-NINE




290



the crime of Possession or Transport for the Purpose of Sale, or Sale or Offering For



that on or about and between January 22 and January 24, 2013, in the County of Kings,







COUNT TWO HUNDRED THIRTY






the crime of Money Laundering in the Third Degree in violation of Penal Law §

470.10(2)(b)(i), in that on or about and between January 22 and January 24, 2013, in the




291






thousand dollars.

COUNT TWO HUNDRED THIRTY-ONE






the crime of Money Laundering in the Third Degree in violation of Penal Law §

470.10(1)(b)(i)(A), in that on or about and between January 22 and January 24, 2013, in

the County of Kings, knowing that the property involved in one or more financial






COUNT TWO HUNDRED THIRTY-TWO



292





on or about and between January 26 and January 30, 2013, in the County of Kings, did



COUNT TWO-HUNDRED THIRTY-THREE








Tax L. § 1814(c)(2), in that on or about and between January 26 and January 30, 2013, in







COUNT TWO HUNDRED THIRTY-FOUR

293






Law § 470.10(2)(b)(i), in that on or about and between January 26 and January 30, 2013,

in the County of Kings, knowing that one or more monetary instruments represented the








thousand dollars.

COUNT TWO HUNDRED THIRTY-FIVE






Law § 470.10(1)(b)(i)(A), in that on or about and between January 26 and January 30,

294







COUNT TWO HUNDRED THIRTY-SIX




Mahmoud and Mohannad Seif, each aiding the other and acting in concert, of the crime

of Attempt to Evade or Defeat Cigarette and Tobacco Products Tax in violation of

N.Y. Tax L. §481(2)(a) & 4 and N.Y. Tax L. § 1814(a)(i), in that on or about April 7,

2013, in the County of Kings, did willfully attempt in any manner to evade or defeat the



COUNT TWO HUNDRED THIRTY-SEVEN




Mahmoud and Mohannad Seif, each aiding the other and acting in concert, of the crime

of Possession or Transport for the Purpose of Sale, or Sale or Offering For Sale, of


295


that on or about April 7, 2013, in the County of Kings, not being agents licensed by the






COUNT TWO HUNDRED THIRTY-EIGHT






Seif, each aiding the other and acting in concert, of the crime of Attempt to Evade or


4 and N.Y. Tax L. § 1814(a)(i), in that on or about and between March 22 and March




COUNT TWO HUNDRED THIRTY-NINE




296



Seif, each aiding the other and acting in concert, of the crime of Possession or




between March 22 and March 23, 2013, between in the County of Kings, not being


Finance, did willfully possess or transport for the purpose of sale, thirty thousand

(30,000) or more cigarettes subject to the tax imposed pursuant to New York State Law


sale thirty thousand (30,000) or more cigarettes in any unstamped or unlawfully stamped

packages.

COUNT TWO HUNDRED FORTY







the Third Degree in violation of Penal Law § 470.10(2)(b)(i), in that on or about and

between March 22 and March 23, 2013, in the County of Kings, knowing that one or


297








COUNT TWO HUNDRED FORTY-ONE







the Third Degree in violation of Penal Law § 470.10(1)(b)(i)(A), in that on or about

and between March 22 and March 23, 2013, in the County of Kings, knowing that the

property involved in one or more financial transactions represented the proceeds of






298

COUNT TWO HUNDRED FORTY-TWO


accuses the Defendants Basel Ramadan, a.k.a. Abu Salah and Samer Ramadan,

a.k.a. Abu Mahdy, each aiding the other and acting in concert, of the crime of Money

Laundering in the Second Degree in violation of Penal Law § 470.15(1)(b)(ii)(A), in





conduct, as that term is defined under Article 470 of the Penal Law, knowing that the

transaction or transactions in whole or in part are designed to conceal or disguise the

nature, location, the source, the ownership or control of the proceeds of specified criminal

conduct, as that term is defined under Article 470 of the Penal Law, and the total value

involved in such financial transaction or transactions exceeded one hundred thousand

dollars.

COUNT TWO HUNDRED FORTY-THREE


accuses the Defendants Basel Ramadan, a.k.a. Abu Salah and Samer Ramadan,

a.k.a. Abu Mahdy, each aiding the other and acting in concert, of the crime of Money





299





COUNT TWO HUNDRED FORTY-FOUR








Muaffaq Askar, each aiding the other and acting in concert with each other and others

known and unknown to the Grand Jury, committed the crime of Conspiracy in the fifth

degree in violation of Penal Law Section 105.05(1), committed as follows:

The defendants, from on or about and between September 2011 and May 10,

2013, in Kings County, Bronx County and elsewhere within the State of New York and

the States of Delaware, Maryland and New Jersey, with intent that conduct constituting a

felony be performed, to wit: Attempt to Evade or Defeat Cigarette and Tobacco


1814(a)(i), agreed with one or more persons to engage in or cause the performance of

such conduct.

300

PREAMBLE

During the course of the above-described conspiracy it was the goal of its

members to promote and profit from the Ramadan untaxed cigarette distribution-based

money laundering enterprise (hereinafter "the business"). Basel Ramadan and his brother

Samer (collectively referred to as "the Ramadans") supplied their co-conspirators with

hundreds of thousands of dollars worth of untaxed cigarettes for unauthorized resale and

distribution in New York City, predominantly in Brooklyn, and elsewhere. The

Ramadans directed the untaxed cigarette trafficking operation from the Ocean City,

Maryland area, and employed distributors in the New York City area, consisting of

Youssef Odeh, a.k.a. Abu Mahmoud (hereinafter "Odeh”), Issa Sullieman (hereinafter

“Issa”); Ribhi Awawdeh (hereinafter “Ribhi”), Mohamed Abed Alabed Awawdeh,

a.k.a. Abu Samir (hereinafter “Mohamed Abed”)(collectively these two are referred to

as “the Dibwani” or “The Bronx Guys”); Ahmad Abdelaziz, a.k.a. Al Jaba'I (hereinafter

“Abdelaziz”); Mufeed Attal, a.k.a. Abu Saleem (hereinafter "Attal") Nimer Izzat,

a.k.a. Izzat Nimer, a.k.a., Abu Ali (hereinafter "Nimer"); Munther Mahmoud

(hereinafter "Munther") and Saad Badr Nabiel, a.k.a. Abu Nabil (hereinafter

"Nabiel"), all of whom purchased untaxed cigarettes from the Ramadans. In turn, the

distributors sold the untaxed cigaretted within New York City (predominantly in

Brooklyn) to selected resellers Bassam Twam (hereinafter "Bassam"), Mohannad Seif

(hereinafter "Seif"), Murad Bishrat (hereinafter "Murad"), and Muaffaq Askar

(hereinafter "Askar"), who would resell the untaxed cigarettes to consumers. Adel

Abuzarieh (hereinafter “Adel”) transported the cash proceeds from the cigarette sales,

sometimes over $100,000 per trip, from the New York City-based distributors back to the

301

Ramadans and transported the untaxed cigarettes from the Ramadans to the New York

based distributors for sale.

It was the common criminal purpose of the conspiracy to profit from the business

by generating large amounts of cash profits and to launder illicit proceeds in order to

promote and carrying on evading and defeating New York State's Cigarette and Tobacco

Products Tax and to conceal and disguise the nature and origin of the illicit proceeds,

thereby allowing the business to continue its operations and reap the financial benefits of

the criminal conduct without detection by law enforcement. The defendants

accomplished this goal by reinvesting some of the millions dollars of money generated

from the sale and distribution of untaxed cigarettes to further expand and generate

additional profits from their illegal business.

OVERT ACTS

In furtherance of said conspiracy and to effect the objects thereof, and during the

course thereof, the following overt acts, among others, were committed:

On October 23, 2012, Mohannad Seif and Bassam Twam had a telephone

conversation in which Seif told Twam he was counting money for untaxed cigarettes.

On October 23, 2012, Mohannad Seif and Bassam Twam met and Twam gave

Seif bags containing untaxed cigarettes.

On November 3, 2012, Munther Mahmoud and Basel Ramadan, a.k.a. Abu

Salah had a telephone conversation in which Mahmoud discussed the balance of money

he owed to Ramadan for untaxed cigarettes.

On November 3, 2012, Saad Badr, a.k.a. Abu Nabil and Basel Ramadan, a.k.a.

Abu Salah had a telephone conversation in which Badr discussed the money he owed to

302

Ramadan for untaxed cigarettes, and Ramadan confirmed that Badr had just received

over 30,000 untaxed cigarettes.

On December 26, 2012, Mufeed Attal, a.k.a. Abu Saleem, and Izzat Nimer,

a.k.a. Nimer Izzat, a.k.a. Abu Ali, had a telephone conversation in which Nimer

advised Attal that he brought in excess of 30,000 untaxed cigarettes.

On Decemer 26, 2012, Murad Bishrat sent a text message to Mufeed Attal,

a.k.a. Abu Saleem, that read: 118 Marlboro and 344 Newport.

On December 26, 2012, Murad Bishrat had a telephone conversation with

Mufeed Attal, a.k.a. Abu Saleem to confirm Attal received his order for untaxed

cigarettes.

On January 22, 2013, Ribhi Awawdeh and Adela Buzahrieh, a.k.a. Adel Abu

Zahrieh, had a telephone conversation in which Ribhi Awawdeh stated he wanted to

order 1000 cartons of untaxed cigarettes for himself and another 1000 cartons of untaxed

cigarettes for his brother.

On February 1, 2013, Basel Ramadan, a.k.a. Abu Salah and Yousseff Odeh,

a.k.a. Abu Mahmoud, had a telephone conversation in which Odeh ordered in excess of

30,000 untaxed cigarettes from Basel Ramadan.

On February 10, 2013, Ahmad Abdelaziz, a.k.a. Al Jaba'I and Adela

Buzahrieh, a.k.a. Adel Abu Zahrieh had a telephone conversation in which Ahmad

Abdelaziz told Adela Buzahrieh that he wanted to order 1800 cartons of untaxed

cigarettes.

303

On March 6, 2013, Mohamed Abed Alabed Awawdeh and Adela Buzahrieh,

a.k.a. Adel Abu Zahrieh met up and Adel Abu Zahrieh delivered untaxed cigarettes to

Awawdeh.

On March 11, 2013, Samer Ramadan, a.k.a. Abu Mahdy and Izzat Nimer,

a.k.a. Nimer Izzat, a.k.a. Abu Ali had a telephone conversation in which Nimer ordered

in excess of 30,000 untaxed cigarettes from Samer Ramadan.

On March 15, 2013, Muaffaq Askar and Issa Sulieman had a telephone

conversation in which Askar ordered a quantity of untaxed cigarettes from Sulieman.

On March 30, 2013, Basel Ramadan, a.k.a. Abu Salah was present at a storage

facility located at Dagsboro, Delaware.

PERI ALYSE KADANOFF Deputy Attorney General Organized Crime Task Force By ________________________________ JONATHAN R. SENNETT

Assistant Deputy Attorney General A TRUE BILL _____________________________ GRAND JURY FOREPERSON Dated: May 13, 2013

supreme court of the state of new york kings county ... · the people of the state of new york ......

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