BFF
STATE OF NEW YORK
COUNTY COURT: COUNTY OF WESTCHESTER
THE PEOPLE OF THE STATE OF NEW YORK
-against- INDICTMENT NO.
09-0961
DOREEN SWENSON,
HERBERT “PHIL” HALL,
MILDRED DIDIO,
DAVID REBACK,
EILEEN POTASH,
FRANK CORIGLIANO,
AMERIGO DIPIETRO, and
WILMA SHKRELI (aka WILMA GECAY)
Defendants.
COUNT 1 PL. 155.40 01 CF2 PL
THE GRAND JURY OF THE COUNTY OF WESTCHESTER, by this Indictment, accuses the
defendants, DOREEN SWENSON, HERBERT “PHIL” HALL, MILDRED DIDIO, DAVID REBACK,
EILEEN POTASH, AMERIGO DIPIETRO, and WILMA SHKRELI (aka WILMA GECAY), of the
crime of GRAND LARCENY IN THE SECOND DEGREE, in violation of Penal Law Section 155.40(1),
committed as follows:
The defendants, being aided and abetted by and acting in concert with each other, and others, in the
County of Westchester and State of New York, on or about December 30, 2004, did steal property
from the Argent Mortgage Company with a value in excess of fifty thousand dollars ($50,000.00).
COUNT 2 PL. 155.40 01 CF2 PL
THE GRAND JURY OF THE COUNTY OF WESTCHESTER, by this Indictment, accuses the
defendants, DOREEN SWENSON, HERBERT “PHIL” HALL, MILDRED DIDIO, DAVID REBACK,
FRANK CORIGLIANO, AMERIGO DIPIETRO; and WILMA SHKRELI (aka WILMA GECAY)
of the crime of GRAND LARCENY IN THE SECOND DEGREE, in violation of Penal Law Section
155.40(1), committed as follows:
The defendants, being aided and abetted by and acting in concert with each other, and with
others, in the County of Westchester and State of New York, on or about June 10, 2005, did steal
property from Fremont Investment and Loan with a value in excess of fifty thousand dollars
($50,000.00).
COUNT 3 PL. 155.40 01 CF2 PL
THE GRAND JURY OF THE COUNTY OF WESTCHESTER, by this Indictment, accuses the
defendants, DOREEN SWENSON, HERBERT “PHIL” HALL, MILDRED DIDIO, DAVID REBACK,
FRANK CORIGLIANO, AMERIGO DIPIETRO; and WILMA SHKRELI (aka WILMA GECAY)
of the crime of GRAND LARCENY IN THE SECOND DEGREE, in violation of Penal Law Section
155.40(1), committed as follows:
The defendants, being aided and abetted by and acting in concert with each other, and with
others, in the County of Westchester and State of New York, on or about March 6, 2006, did steal
property from the Argent Mortgage Company with a value in excess off fifty thousand dollars
($50,000.00).
COUNT 4 PL. 155.40 01 CF2 PL
THE GRAND JURY OF THE COUNTY OF WESTCHESTER, by this Indictment, accuses the
defendants, DOREEN SWENSON, HERBERT “PHIL” HALL, MILDRED DIDIO, DAVID REBACK,
and WILMA SHKRELI (aka WILMA GECAY) of the crime of GRAND LARCENY IN THE SECOND
DEGREE, in violation of Penal Law Section 155.40(1), committed as follows:
The defendants, being aided and abetted by and acting in concert with each other, and with
others, in the County of Westchester and State of New York, on or about January 24, 2007, did steal
property from Fremont Investment and Loan with a value in excess of fifty thousand dollars
($50,000.00).
COUNT 5 PL 190.65 01 EF1 PL
THE GRAND JURY OF THE COUNTY OF WESTCHESTER, by this Indictment, accuses the
defendants, DOREEN SWENSON, HERBERT “PHIL” HALL, MILDRED DIDIO, DAVID REBACK,
EILEEN POTASH, FRANK CORIGLIANO, AMERIGO DIPIETRO, and WILMA SHKRELI (aka
WILMA GECAY), of the crime of SCHEME TO DEFRAUD IN THE FIRST DEGREE, in violation of
Penal Law Section 190.65 (1) (b), committed as follows:
The defendants, being aided and abetted by and acting in concert with each other, and with
others, in the County of Westchester and State of New York, on or about and between March 1, 2004 and
January 31, 2007, did engage in a scheme constituting a systematic ongoing course of conduct with
intent to defraud more than one person and to obtain property from more than one person by false
and fraudulent pretenses, representations and promises, and did obtain property with a value in
excess of one thousand dollars ($1,000.00) from one and more such persons.
COUNT 6 PL 105.10 01 EF1 PL
THE GRAND JURY OF THE COUNTY OF WESTCHESTER, by this Indictment, accuses the
defendants, DOREEN SWENSON, HERBERT “PHIL” HALL, MILDRED DIDIO, DAVID
REBACK, EILEEN POTASH, FRANK CORIGLIANO, AMERIGO DIPIETRO, and WILMA
SHKRELI (aka WILMA GECAY), of the crime of CONSPIRACY IN THE FOURTH DEGREE, in
violation of Penal Law Section 105.10 (1), committed as follows:
The defendants, being aided and abetted by and acting in concert with each other, and with others,
in the County of Westchester and State of New York, on or about and between March 1, 2004 and January 31,
2007, with intent that conduct constituting the class C felony of Grand Larceny in the Second Degree, in
violation of Penal Law Section 155.40 (1), be performed, he or she agreed with one or more persons
to engage in and cause the performance of such conduct; and in the course of and in furtherance of such
agreement, the following overt acts were committed and caused to be committed:
1) Defendants, DOREEN SWENSON and HERBERT “PHIL” HALL, in the County of
Westchester and State of New York, on or about December 30, 2004 induced Mayritta and
Thomas Jessamy to transfer the deed to their property located at 15 Greendale Avenue, Mount
Vernon, New York to a purported “investor” named Robert Ballard.
2) Defendants, DOREEN SWENSON, HERBERT “PHIL” HALL, MILDRED DIDIO,
DAVID REBACK, and EILEEN POTASH, in the County of Westchester and State of New
York, on or about December 30, 2004, participated in the closing of a fraudulent real estate
transaction in connection with property located at 15 Greendale Avenue, Mount Vernon, New
York.
3) Defendants, DOREEN SWENSON, HERBERT “PHIL” HALL, MILDRED DIDIO,
DAVID REBACK, EILEEN POTASH, AMERIGO DIPIETRO, and WILMA SHKRELI (aka
WILMA GECAY), in the County of Westchester and State of New York, on or about December
30, 2004, being aided and abetted by and acting in concert with each other, and with others,
committed the crime of Grand Larceny in the Second Degree, a class C felony, in violation of
Penal Law Section 155.40 (1) by stealing property consisting of United States currency with a
value in excess of fifty thousand dollars ($50,000.00) from the Argent Mortgage Company.
4) Defendants, DOREEN SWENSON, HERBERT “PHIL” HALL, MILDRED DIDIO,
DAVID REBACK, FRANK CORIGLIANO, and AMERIGO DIPIETRO, in the County of
Westchester and State of New York, on or about June 10, 2005, participated in the closing of a
fraudulent real estate transaction in connection with property located at 105 Chestnut Street,
Cortlandt Manor, New York.
5) Defendants, DOREEN SWENSON, HERBERT “PHIL” HALL, MILDRED DIDIO,
DAVID REBACK, EILEEN POTASH, FRANK CORIGLIANO, AMERIGO DIPIETRO, and
WILMA SHKRELI (aka WILMA GECAY) in the County of Westchester and State of New
York, on or about June 10, 2005, being aided and abetted by and acting in concert with each
other, and with others, committed the crime of Grand Larceny in the Second Degree, a class C
felony, in violation of Penal Law Section 155.40 (1) by stealing property consisting of United
States currency with a value in excess of fifty thousand dollars ($50,000.00) from Fremont
Investment and Loan.
6) Defendants, DOREEN SWENSON and HERBERT “PHIL” HALL in the County of
Westchester and State of New York, on or about March 6, 2006 induced Andrea Miller to
transfer the deed to her property located at 2186 White Birch Drive, Yorktown Heights New
York to a purported “investor” named Wilma Shkreli.
7) Defendants, DOREEN SWENSON, HERBERT “PHIL” HALL, MILDRED DIDIO,
DAVID REBACK, FRANK CORIGLIANO, AMERIGO DIPIETRO, and WILMA SHKRELI
(aka WILMA GECAY) in the County of Westchester and State of New York, on or about March
6, 2006, participated in the closing of a fraudulent real estate transaction in connection with
property located at 2186 White Birch Drive, Yorktown Heights New York.
8) Defendants, DOREEN SWENSON, HERBERT “PHIL” HALL, MILDRED DIDIO,
DAVID REBACK, FRANK CORIGLIANO, AMERIGO DIPIETRO, and WILMA SHKRELI
(aka WILMA GECAY) in the County of Westchester and State of New York, on or about March
6, 2006, being aided and abetted by and acting in concert with each other, and with others,
committed the crime of Grand Larceny in the Second Degree, a class C felony, in violation of
Penal Law Section 155.40 (1) by stealing property consisting of United States currency with a
value in excess of fifty thousand dollars ($50,000.00) from the Argent Mortgage Company.
9) Defendants, DOREEN SWENSON and HERBERT “PHIL” HALL in the County of
Westchester and State of New York, on or about January 24, 2007 induced Michelle Viehl to
transfer the deed to her property located at 47 High Street, Croton-On-Hudson, New York to
purported “investors” named Grisa and Sefadin Becaj.
10) Defendants, DOREEN SWENSON, HERBERT “PHIL” HALL, MILDRED DIDIO, and
DAVID REBACK, in the County of Westchester and State of New York, on or about January
24, 2007 participated in the closing of a fraudulent real estate transaction in connection with
property located at 47 High Street, Croton-On-Hudson, New York.
11) Defendants, DOREEN SWENSON, HERBERT “PHIL” HALL, MILDRED DIDIO,
DAVID REBACK, and WILMA SHKRELI (aka WILMA GECAY) in the County of
Westchester and State of New York, on or about January 24, 2007, being aided and abetted by
and acting in concert with each other, and with others, committed the crime of Grand Larceny in
the Second Degree, a class C felony, in violation of Penal Law Section 155.40 (1) by stealing
property consisting of United States currency with a value in excess of fifty thousand dollars
($50,000.00) from Fremont Investment and Loan.
All contrary to the form of the statute in such case made and provided and against the peace
and dignity of the People of the State of New York.
/s/ JANET DiFIORE
JANET DiFIORE
District Attorney of Westchester County
10) Defendants, DOREEN SWENSON, HERBERT “PHIL” HALL, MILDRED DIDIO, and
DAVID REBACK, in the County of Westchester and State of New York, on or about January
24, 2007 participated in the closing of a fraudulent real estate transaction in connection with
property located at 47 High Street, Croton-On-Hudson, New York.
11) Defendants, DOREEN SWENSON, HERBERT “PHIL” HALL, MILDRED DIDIO,
DAVID REBACK, and WILMA SHKRELI (aka WILMA GECAY) in the County of
Westchester and State of New York, on or about January 24, 2007, being aided and abetted by
and acting in concert with each other, and with others, committed the crime of Grand Larceny in
the Second Degree, a class C felony, in violation of Penal Law Section 155.40 (1) by stealing
property consisting of United States currency with a value in excess of fifty thousand dollars
($50,000.00) from Fremont Investment and Loan.
All contrary to the form of the statute in such case made and provided and against the peace
and dignity of the People of the State of New York.
____________________________________
JANET DiFIORE
District Attorney of Westchester County
PEOPLE v. DOREEN SWENSON, HERBERT “PHIL” HALL, ...ET AL
INDICTMENT 09-0961
NOTICE TO DEFENDANT OF INTENTION TO OFFER EVIDENCE
PURSUANT TO SECTION 710.30 CPL
Please take notice, that the District Attorney intends to offer at trial evidence of a statement made by
the defendant DOREEN SWENSON to a public servant which statement, if involuntarily made,
would render the evidence thereof suppressible upon motion pursuant to Subdivision 3 of Section
710.20 CPL.
An oral, recorded statement made on or about June 16, 2009 at or about and between 11:00 a.m.
and 4:00 p.m. at the Westchester County District Attorney’s Office, City of White Plains, County of
Westchester, State of New York to members of the Westchester County District Attorney’s Office and
the New York State Banking Department.
In substance, the defendant stated and explained how she, and others, participated in inducing
multiple financially distressed homeowners to transfer the title of their homes to third party “investors”
in order to obtain residential mortgage loans in the names of such third party “investors.” In
connection with one such transaction, the defendant specifically admitted that her name and
signature were affixed to a fictitious lease agreement which was submitted in support a fraudulent
residential mortgage loan application. The defendant confirmed that she, through “The Doran
Group,” was compensated for her participation in these transactions.
Janet DiFiore
DISTRICT ATTORNEY
WESTCHESTER COUNTY COURTHOUSE
111 Dr. Martin Luther King Jr. Blvd
White Plains, NY 10601
PEOPLE v. DOREEN SWENSON, HERBERT “PHIL” HALL, ...ET AL
INDICTMENT 09-0961
NOTICE TO DEFENDANT OF INTENTION TO OFFER EVIDENCE
PURSUANT TO SECTION 710.30 CPL
Please take notice, that the District Attorney intends to offer at trial evidence of a statement made by
the defendant HERBERT “PHIL” HALL to a public servant which statement, if involuntarily
made, would render the evidence thereof suppressible upon motion pursuant to Subdivision 3 of
Section 710.20 CPL.
An oral, recorded statement made on or about June 16, 2009 at or about and between 11:00 a.m.
and 4:00 p.m. at the Westchester County District Attorney’s Office, City of White Plains, County of
Westchester, State of New York to members of the Westchester County District Attorney’s Office and
the New York State Banking Department.
In substance, the defendant stated and explained how he, and others, participated in inducing
multiple financially distressed homeowners to transfer the title of their homes to third party “investors”
in order to obtain residential mortgage loans in the names of such third party “investors.” In
connection with one such transaction, the defendant specifically admitted that he created and forged
multiple fictitious lease agreements which were submitted in support a fraudulent residential
mortgage loan application. The defendant confirmed that he, through “The Doran Group,” was
compensated for his participation in these transactions. The defendant stated that he was aware they
were in trouble and that he would plea guilty to avoid going to jail.
Janet DiFiore
DISTRICT ATTORNEY
WESTCHESTER COUNTY COURTHOUSE
111 Dr. Martin Luther King Jr. Blvd
White Plains, NY 10601
PEOPLE v. DOREEN SWENSON, HERBERT “PHIL” HALL, ...ET AL
INDICTMENT 09-0961
NOTICE TO DEFENDANT OF INTENTION TO OFFER EVIDENCE
PURSUANT TO SECTION 710.30 CPL
Please take notice, that the District Attorney intends to offer at trial evidence of a statement made by
the defendant DOREEN SWENSON to a public servant or an agent thereof, which statement, if
involuntarily made, would render the evidence thereof suppressible upon motion pursuant to
Subdivision 3 of Section 710.20 CPL.
An oral, recorded statement made on or about May 15, 2009, in County of Westchester, State of New
York to a member of the Westchester County District Attorney’s Office or an agent thereof:
In substance, the defendant advised another individual not to provide investigators with documents
relating to a real estate transaction. The defendant further stated that investigators were “on a fishing
expedition to try to find out that we have done something wrong or David (Reback) has done
something wrong or you have done something wrong...” The defendant further stated “...they’re
lumping all of this together as if we’re some horrific people that took these people’s houses and did it
intentionally and did it as predatory lending without down payments, without this, without that and,
umm, it is not a wise idea for you to go in there. I’m just telling you.” Further, the defendant admitted
she was in a worse position in many ways than the aforementioned other individual.
Janet DiFiore
DISTRICT ATTORNEY
WESTCHESTER COUNTY COURTHOUSE
111 Dr. Martin Luther King Jr. Blvd
White Plains, NY 10601
PEOPLE v. DOREEN SWENSON, HERBERT “PHIL” HALL, ...ET AL
INDICTMENT 09-0961
NOTICE TO DEFENDANT OF INTENTION TO OFFER EVIDENCE
PURSUANT TO SECTION 710.30 CPL
Please take notice, that the District Attorney intends to offer at trial evidence of a statement made by
the defendant DOREEN SWENSON to a public servant or an agent thereof, which statement, if
involuntarily made, would render the evidence thereof suppressible upon motion pursuant to
Subdivision 3 of Section 710.20 CPL.
An oral, recorded statement made on or about May 14, 2009, in the County of Westchester, State of
New York to a member of the Westchester County District Attorney’s Office or an agent thereof.
In substance, the defendant stated that she was aware that the Westchester County District
Attorney’s Office was conducting a criminal investigation into real estate transactions in which she,
Doreen Swenson, took part in. The defendant initially advised another individual not to discuss such
real estate transactions with investigators and instead the defendant told the aforementioned other
individual to tell investigators that an attorney had recommended that said individual not discuss the
transactions with them.
Janet DiFiore
DISTRICT ATTORNEY
WESTCHESTER COUNTY COURTHOUSE
111 Dr. Martin Luther King Jr. Blvd
White Plains, NY 10601
PEOPLE v. DOREEN SWENSON, HERBERT “PHIL” HALL, ...ET AL
INDICTMENT 09-0961
NOTICE TO DEFENDANT OF INTENTION TO OFFER EVIDENCE
PURSUANT TO SECTION 710.30 CPL
Please take notice, that the District Attorney intends to offer at trial evidence of a statement made by
the defendant FRANK CORIGLIANO to a public servant which statement, if involuntarily made,
would render the evidence thereof suppressible upon motion pursuant to Subdivision 3 of Section
710.20 CPL.
An oral statement made on or about June 15, 2009 at or about 2:00 p.m. at 174 Brushy Hill Road,
Newtown, Connecticut to members of the Westchester County District Attorney’s Office and the New
York State Banking Department.
In substance, the defendant stated that he was aware of the “Miller case” and invited investigators
into his residence to speak with him. The defendant stated and explained how he participated in the
real estate closing between Andrea Miller and Wilma Shkreli and was paid between $1,000 and
$1,500 for his participation. The defendant stated that the closing between Andrea Miller and Wilma
Shkreli took place in the Briarcliff Manor office of Amerigo and Frank DiPietro. The defendant stated
that although he does not normally participate in closings involving Amerigo and Frank DiPietro due
to problems with the manner in which they conduct their transactions, the defendant admitted that he
had personally taken part in closings for Amerigo and Frank DiPietro, including representing Amerigo
DiPietro in the purchase of 105 Chestnut Street from Noemi Carbonell-Saleh. The defendant further
indicated that he participated in other, additional, closings with Doreen Swenson, Mildred Didio, David
Reback and Eileen Potash.
Janet DiFiore
DISTRICT ATTORNEY
WESTCHESTER COUNTY COURTHOUSE
111 Dr. Martin Luther King Jr. Blvd
White Plains, NY 10601
PEOPLE v. DOREEN SWENSON, HERBERT “PHIL” HALL, ...ET AL
INDICTMENT 09-0961
NOTICE TO DEFENDANT OF INTENTION TO OFFER EVIDENCE
PURSUANT TO SECTION 710.30 CPL
Please take notice, that the District Attorney intends to offer at trial evidence of a statement made by
the defendant WILMA SHKRELI to a public servant which statement, if involuntarily made, would
render the evidence thereof suppressible upon motion pursuant to Subdivision 3 of Section 710.20
CPL.
An oral statement made on or about March 30, 2009 at or about 2:30 p.m. at 141 North State Street,
Briarcliff Manor, NY to members of the Westchester County District Attorney’s Office and the New
York State Banking Department.
In substance, the defendant stated that she was an employee of Interstate Monetary Concepts
located at 141 North State Street, Briarcliff Manor, NY. The defendant initially claimed she had no
knowledge of the whereabouts of Novastar Home Mortgage, but later admitted that she once worked
for a Novastar Home Mortgage branch at the same 141 North State Street, Briarcliff Manor, NY. The
defendant indicated that the Novastar Home Mortgage branch at that location had since gone out of
business. The defendant stated that she is currently an employee of Frank DiPietro, that her job is to
answer the phone and that she is only trying to make a living.
Janet DiFiore
DISTRICT ATTORNEY
WESTCHESTER COUNTY COURTHOUSE
111 Dr. Martin Luther King Jr. Blvd
White Plains, NY 10601
DISTRICT ATTORNEY’S DEMAND FOR DISCOVERY AND INSPECTION
PLEASE TAKE NOTICE, that pursuant to the provisions of Article 240 of the Criminal Procedure Law,
the District Attorney hereby demands that the defendant disclose and make available for inspection,
photographing, copying or testing any and all written reports and documents, or portions thereof, concerning
all physical and mental examinations, and scientific tests, experiments and comparisons, made by or at the
request or direction of the defendant, if the said defendant intends to introduce such reports or documents at
trial, or if the said defendant has filed or will file a notice of intent to proffer psychiatric evidence and such
reports or documents relate thereto, or if such reports or documents were made by a person, other than the
defendant, whom the defendant intends to call as a witness at trial.
IT IS FURTHER DEMANDED, that the defendant disclose and make available for inspection, photographing, copying or testing
any and all photographs, drawings, tapes, or other electronic recordings which the defendant intends to introduce at trial.
IT IS FURTHER DEMANDED, that compliance with the requests for discovery and inspection contained in this “DEMAND
FOR DISCOVERY AND INSPECTION” take place within fifteen (15) days of the arraignment herein, at a place to be mutually
agreed upon by the District Attorney and counsel for the defendant.
DISTRICT ATTORNEY’S DEMAND FOR BILL OF PARTICULARS
PLEASE TAKE NOTICE, that if the defendant herein intends to offer, for any purpose whatsoever, testimony which may tend to
establish presence elsewhere than at the scene of the crime at the time of its commission, you are hereby required within eight (8) days after
the service of this demand upon you, to server upon me, the undersigned, District Attorney of the County of Westchester, and file a Bill of
Particulars which shall set forth in detail the place or places where the defendant claims to have been, together with the names, residential
addresses and place of employment and addresses thereof of the witnesses upon whom defendant intends to rely to establish defendant’s
presence elsewhere than at the scene of the crime at the time of its commission,
Unless you serve and file such Bill of Particulars, in the event that such testimony is sought to be interposed by you upon the trial for
any purpose whatever, or in the event that a witness not mentioned in such Bill of Particulars is called by you to give such testimony, a
motion will be made to exclude the testimony of such witness.
The District Attorney will furnish you with the name and address of any alibi-rebuttal witness(es) intended to be called by the
People to testify.
Very truly yours,
JANET DiFIORE
District Attorney
of Westchester County
111 Dr. Martin Luther King Jr.Blvd.
White Plains, New York 10601
(914) 995-3481
Indictment # 09-0961
WESTCHESTER COUNTY
COUNTY COURT
THE PEOPLE OF THE
STATE OF NEW YORK
against
DOREEN SWENSON
HERBERT “PHIL” HALL
MILDRED DIDIO
DAVID REBACK
EILEEN POTASH
FRANK CORIGLIANO
AMERIGO DIPIETRO and
WILMA SHKRELI (aka WILMA GECAY)
Defendants
______________________________________________
JANET DiFIORE
District Attorney
A TRUE BILL
with
NOTICE(S)
The below signature directs the District Attorney to file this Instrument with the Impanelling Court
________ _________________________________
Foreperson of Grand Jury
_______________ _________________
Acting Foreperson of Grand Jury
Charges: Grand Larceny 2º (4 Counts)
Scheme to Defraud 1º (1 Count)
Conspiracy 4º (1 Count)
Indictment # 09-0961
WESTCHESTER COUNTY
COUNTY COURT
THE PEOPLE OF THE
STATE OF NEW YORK
against
DOREEN SWENSON
HERBERT “PHIL” HALL
MILDRED DIDIO
DAVID REBACK
EILEEN POTASH
FRANK CORIGLIANO
AMERIGO DIPIETRO and
WILMA SHKRELI (aka WILMA GECAY)
Defendants
______________________________________________
JANET DiFIORE
District Attorney
A TRUE BILL
with
NOTICE(S)
The below signature directs the District Attorney to file this Instrument with the Impanelling Court
________ _________________________________
Foreperson of Grand Jury
_______________ _________________
Acting Foreperson of Grand Jury
Charges: Grand Larceny 2º (4 Counts)
Scheme to Defraud 1º (1 Count)
Conspiracy 4º (1 Count)
Indictment # 09-0961
WESTCHESTER COUNTY
COUNTY COURT
THE PEOPLE OF THE
STATE OF NEW YORK
against
DOREEN SWENSON
HERBERT “PHIL” HALL
MILDRED DIDIO
DAVID REBACK
EILEEN POTASH
FRANK CORIGLIANO
AMERIGO DIPIETRO and
WILMA SHKRELI (aka WILMA GECAY)
Defendants
/s/ JANET DiFIORE
JANET DiFIORE
District Attorney
A TRUE BILL
with
NOTICE(S)
The below signature directs the District Attorney to file this Instrument with the Impanelling Court
/s/ LAWRENCE BERNSTEIN
Foreperson of Grand Jury
/s/ FRANCINE HANEY
Acting Foreperson of Grand Jury
Charges: Grand Larceny 2º (4 Counts)
Scheme to Defraud 1º (1 Count)
Conspiracy 4º (1 Count)