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-v. - Violation of
18 U.S.C. §§ 1344 and 2
HASSAN NEMAZEE,
COUNTY OF OFFENSE:
Defendant. NEW YORK
COUNT ONE
THE DEFENDANT
SUMMARY
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on many of the documents at issue, NEMAZEE falsely gave as the
address and telephone numbers of various financial institutions
purportedly vouching for his financial strength an address and
telephone number that 'was in fact controlled by NEMAZEE, so that
in the event anyone at Citibank made an effort to confirm the
existence of the assets reflected on the fraudulent documents
submitted by NEMAZEE, they would in fact be contacting a
telephone number assigned to NEMAZEE himself, and not any
financial institution.
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d. The written agreements from December 2006
also provided that NEMAZEE would maintain at all times a net
worth of not less than $250 million.
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b. On or about August 7, 2009, a reI)resentative
of Citibank contacted NEMAZEE by telephone in order t:o verify
assets held by NEMAZEE. The Citibank representative informed
NEMAZEE that a repre'sentative of Ci tibank was going t:o contact
Pershing LLC to verify assets held by NEMAZEE. NEMA2~EE
responded, in substance and in part, that Citibank sl:10uld not do
so and that NEMAZEE would rather payoff the balance of his loan
from Citibank.
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August 17 Letter as an affiliate of The Bank of New y10rk Mellon.
The August 17 Letter purportedly verifies, in substance and in
part, that the Pledged Account contains:
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Representative on the August 17 Letter is a forgery and was not
signed by the Second Pershing LLC Representative. The Second
Pershing LLC Representative denied signing the August 17 Letter.
Indeed the Second Pershing LLC Representative was on vacation
l
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a. The Business engages in, among other things,
the business of providing telephone answering service, mail
receipt service, and conference rooms. As advertised on its
Internet website, the Business can provide "[a]n exclusive
telephone number answered in your company name" and "575 Madison
Avenue as your mailing address." Based on my training and
experience, these services are sometimes referred to as providing
clients with a "virtual office."
-8-
drawn off an account maintained by Nemazee Capital, payable to
the Business representing the monthly payments to the Business
for maintaining the "Pershing LLC" virtual office.
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c. NEMAZEE provided the August 17 Letter to
Citibank.
N BARKER
AGENT
BUREAU OF INVESTIGATION
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c. NEMAZEE provided the August l7 Letter to
Citibank.
INVESTIGATION
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