Approved: Approved: BOYD M. JOHNSON III RITA GLAVIN DANIEL STEIN Assistant United States Attorneys Before: HONORABLE RONALD L. ELLIS United States Magistrate Judge Southern District of New York UNITED STATES OF AMERICA 08 MAG 0463 SEALED COMPLAINT
MARK BRENER,:
a/k/a "Michael,"
CECIL SUWAL,:
a/k/a "Katie,"
a/k/a "Kate,":
TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," and:
TANYA HOLLANDER,
a/k/a "Tania Hollander,":
Violations of 18 U.S.C. §§ 371, 1952, 2421, 2422, 1956 Defendants. : COUNTY OF OFFENSE: NEW YORK· SOUTHERN DISTRICT OF NEW YORK, ss.: KENNETH HOSEY, being duly sworn, deposes and says that he is a Special Agent with the Federal Bureau of Investigation, and charges as follows: COUNT ONE 1. From in or about December 2004 to in or about March 2008, in the Southern District of New York and elsewhere, MARK BRENER, a/k/a "Michael," CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," and TANYA HOLLANDER, a/k/a "Tania Hollander," the defendants, and others known and unknown, unlawfully, willfully, and knowingly did combine, conspire, confederate, and agree together and with each other to violate Sections 1952(a)(3), 2421, and 2422(a) of Title 18, United States Code. EFTA00190254 2. It was a part and an object of the conspiracy that MARK BRENER, a/k/a "Michael," CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," and TANYA HOLLANDER, a/k/a "Tania Hollander," the defendants, and others known and unknown, would and did use and cause to be used facilities in interstate commerce, to wit, cellular telephones and e-mail, with intent to promote, manage, establish, and carry on, and to facilitate the promotion, management, establishment and carrying on of an unlawful activity, to wit, a business enterprise involving prostitution offenses in violation of applicable State law, and thereafter did perform and attempt to perform an act to promote, manage, establish, and carry on and to facilitate the promotion, management, establishment, and carrying on of said unlawful activity, in violation of Title 18, United States Code, Section 1952(a)(3). 3. It was a further part and an object of the conspiracy that MARK BRENER, a/k/a "Michael," CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," and TANYA HOLLANDER, a/k/a "Tania Hollander," the defendants, and others known and unknown, unlawfully, willfully and knowingly would and did transport individuals in interstate and foreign commerce with intent that such individuals engage in prostitution, and in sexual activity for which a person can be charged with a criminal offense, in violation of Title 18, United States Code, Section 2421. 4. It was a further part and an object of the conspiracy that MARK BRENER, a/k/a "Michael," CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," and TANYA HOLLANDER, a/k/a "Tania Hollander," the defendants, and others known and unknown, unlawfully, willfully and knowingly would and did persuade, induce, entice, and coerce individuals to travel in interstate and foreign commerce to engage in prostitution and in sexual activity for which a person can be charged with a criminal offense, in violation of Title 18, United States Code, Section 2422(a). ## Overt Acts 5. In furtherance of said conspiracy and to effect the illegal objects thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: a. From in or about December 2004 through in or about March 2008, MARK BRENER, a/k/a "Michael," and CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendants, controlled a website 2 EFTA00190255 located at URL www.emperorsclubvip.com. that included photographs of prostitutes' bodies, with their heads hidden, along with hourly rates for different categories of prostitutes; b. From in or about December 2004 through in or about at least January 2008, MARK BRENER, a/k/a "Michael," and CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendants, received applications from women seeking to work as prostitutes with their prostitution business (hereinafter, the "Emperors Club") at various e-mail accounts; c. On or about January 9, 2008, MARK BRENER, a/k/a "Michael," CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," and TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendants, spoke over the telephone about offering the Emperors Club's clients the opportunity to exercise a "buyout clause," which would permit clients to purchase direct access to one of the Emperors Club's prostitutes without having to contact the agency; d. On or about January 15, 2008, TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, spoke with a client of the Emperors Club over the telephone about arranging for a prostitute to come to his room at a hotel in New York, New York; e. On or about January 15, 2008, a prostitute working with the Emperors Club went to a client's hotel in New York, New York; f. On or about January 18, 2008, TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, spoke over the telephone with a new prostitute working with the Emperors Club who told LEWIS that she had never "done anything like this before" and was a "little bit nervous about it"; g. On or about January 18, 2008, CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant, sent an e-mail to a potential prostitute asking her to send photographs of herself to SUWAL; h. On or about January 22, 2008, TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, told an Emperors Club client that he should not be concerned about sending a wire transfer to the Emperors Club because the wire would be sent to "QAT Consulting" so it would show up "like as a business transaction"; i. On or about January 24, 2008, a prostitute working with the Emperors Club went to a hotel in Los Angeles, 3 EFTA00190256 California; j. On or about January 24, 2008, CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant, received an e-mail from a potential prostitute declining to work for the Emperors Club in part because her friend had to have sex with a client "twice in an hour"; k. On or about January 24, 2008, CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant, sent an e-mail to TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, attaching a list of the aliases used by more than 50 prostitutes working with the Emperors Club in, among other places, New York, New York; Los Angeles, California; Miami, Florida; London, England; and Paris, France; 1. On or about January 24, 2008, CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant, sent an e-mail to a prostitute working with the Emperors Club and asked if she would be available on February 11, 2008, in Europe for an extended prostitution date with a client to cost $25,000 or more. m. On or about January 26, 2008, TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, spoke with a client of the Emperors Club over the telephone about arranging for a prostitute to come to his room at a hotel in Los Angeles, California; n. On or about January 27, 2008, a prostitute working with the Emperors Club went to a client's hotel in Los Angeles, California; o. On or about January 27, 2008, TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, spoke with an Emperors Club client over the telephone who asked LEWIS whether the QAT consulting company could be traced because he had heard of agencies like the Emperors Club getting "busted"; p. On or about January 28, 2008, MARK BRENER, a/k/a "Michael," CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," and TANYA HOLLANDER, a/k/a "Tania Hollander," the defendants, met in the vicinity of Grand Central Terminal in New York, New York; q. On or about January 28, 2008, TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, spoke with an Emperors Club client over the telephone about arranging for a prostitute to travel from New York to Washington, D.C., to his hotel; 4 EFTA00190257 r. On or about January 30, 2008, MARK BRENER, a/k/a "Michael," CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," and TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendants, spoke over the telephone regarding problems with one of the Emperors Club's prostitutes who they believed might be abusing drugs; s. On or about January 30, 2008, CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant, sent TANYA HOLLANDER, a/k/a "Tania Hollander," the defendant, a text message over the telephone asking HOLLANDER to contact an Emperors Club client to arrange an appointment with an Emperors Club prostitute in New York on February 1, 2008; t. On or about January 30, 2008, CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant, sent TANYA HOLLANDER, a/k/a "Tania Hollander," the defendant, a text message over the telephone asking HOLLANDER to send two particular prostitutes on dates with Emperors Club clients in New York if possible, and HOLLANDER agreed; u. On or about January 31, 2008, TANYA HOLLANDER, a/k/a "Tania Hollander," the defendant, sent CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant, a text message over the telephone informing SUWAL that she had scheduled a date for an Emperors Club client with an Emperors Club prostitute in Europe; On or about February 7, 2008, CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," and TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendants, spoke over the telephone about the fact that an Emperors Club client had complained that one of their prostitutes was "more sex than sexy"; w. On or about February 11, 2008, CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," and TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendants, communicated via text message about the fact that the three-day rates for two of the Emperors Club prostitutes were $50,000 and $35,000, respectively; x. On or about February 12, 2008, TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, spoke with an Emperors Club client over the telephone about arranging for a prostitute to travel from New York to Washington, D.C.; and y. On or about February 13, 2008, an Emperors Club prostitute traveled from New York, New York, to a hotel in Washington, D.C. (Title 18, United States Code, Section 371.) 5 EFTA00190258 COUNT_TWO 6. From in or about December 2004, up through and including in or about March 2008, in the Southern District of New York and elsewhere, MARK BRENER, a/k/a "Michael," and CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendants, and others known and unknown, unlawfully, willfully, and knowingly combined, conspired, confederated, and agreed together and with each other to commit an offense against the United States, to wit, to violate Title 18, United States Code, Section 1956. 7. It was a part and an object of the conspiracy that MARK BRENER, a/k/a "Michael," and CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendants, and others known and unknown, in an offense involving and affecting interstate and foreign commerce, knowing that the property involved in certain financial transactions represented the proceeds of some form of unlawful activity, unlawfully, willfully, and knowingly would and did conduct such financial transactions, which in fact involved the proceeds of specified unlawful activity, to wit, the use of facilities in interstate commerce with the intent to promote, manage, establish, and carry on, and to facilitate the promotion, management, establishment, and carrying on of an unlawful activity, to wit, a business involving prostitution offenses in violation of applicable State law, in violation of Title 18, United States Code, Section 1952(a)(3); interstate transportation of individuals to engage in prostitution, in violation of Title 18, United States Code, Section 2421; and persuasion of individuals to travel in interstate and foreign commerce to engage in prostitution, in violation of Title 18, United States Code, Section 2422(a), (a) with the intent to promote the carrying on of specified unlawful activity, and (b) knowing that the transactions were designed in whole and in part to conceal and disguise the nature, the location, the source, the ownership, and the control of the proceeds of specified unlawful activity, in violation of Title 18, United States Code, Sections 1956(a)(1)(A)(i) and 1956(a)(1)(B)(i). ## Overt Acts 8. In furtherance of the conspiracy and to effect the illegal objects thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: a. In or about December 10, 2004, CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant, opened a bank account in the name of "QAT Consulting Group, Inc."; 6 EFTA00190259 b. In or about November 30, 2006, CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant, opened a bank account in the name of "QAT International, Inc."; c. From in or about December 2004 to in or about January 2008, MARK BRENER, a/k/a "Michael," and CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendants, received more than $1 million in proceeds from the Emperors Club prostitution business in bank accounts in the names of "QAT Consulting Group, Inc.," and "QAT International, Inc."; d. From in or about December 2004 to in or about January 2008, CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant, wrote more than $100,000 in checks to cash from bank accounts in the names of "QAT Consulting Group, Inc.," and "QAT International, Inc."; e. From in or about December 2004 to in or about January 2008, CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant, wrote more than $39,000 in checks to Protech Consultants, a company whose bank account MARK BRENER, a/k/a "Michael," the defendant, controlled; and f. From in or about December 2004 to in or about January 2008, CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant, wrote checks and sent wire transfers totaling more than $400,000 from bank accounts in the name of "QAT Consulting Group, Inc.," and "QAT International, Inc.," to more than 50 prostitutes working with the Emperors Club in the United States and Europe. ## (Title 18, United States Code, Section 1956(h).) 9. The bases for my knowledge and for the foregoing charges are, in part, set forth in the attached Affidavit of Kenneth Hosey in support of the Application for Arrest Warrants, Search Warrants, and Seizure Warrants, which is incorporated by reference herein. 7 EFTA00190260 WHEREFORE, deponent prays that warrants be issued for the arrests of the above-named defendants so that they may be imprisoned or bailed, as the case may be. KENNETH HOSEY Special Agent Federal Bureau of Investigation Sworn to before me this day of March, 2008. UNITED STATES MAGISTRATE JUDGE SOUTHERN DISTRICT OF NEW YORK 8