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F.# 2017R00060 F J I_ ~ 'I
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STEPHEN KIM, being duly sworn, deposes and says that he is a Special Agent
with the Unjted States Department of Housing and Urban Development Office of Inspector
From on or about and between December 2013 and August 2016, in the Eastern
District ofNew York and elsewhere, the defendants WILLIAM GRELLA and GARY OSBORNE,
together with others, did knowingly falsify, conceal, and cover up by trick, scheme, and device
material facts, and did make materially false, fictitious, and fraudu lent statements and
representations, and did make and use false writings and documents knowing the same to contain
materially false, fictitious, and fraudulent statements and representations, in matters involving
benefits authorized, transported, transmitted, transferred, disbursed, and paid in connection with a
major disaster declaration under section 401 of the Robert T. Stafford Disaster Relief and
Emergency Assistance Act, to wit, the disaster declaration in connection with Superstorm Sandy,
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payment of benefits was in and affected interstate and foreign commerce, and the benefit was
disbursement and payment ofthat benefit, and the benefit was a record , voucher, payment, money,
and thing of value of the Urtited States and a department and agency thereof.
1. The source of my information and the grounds for my belief are as follows: 1 I am
a Special Agent with the U.S. Department of Housing and Urban Development Office of Inspector
General, and I have been personally involved in the investigation of tills matter. I base this
affidavit on that personal observations and interviews, as well as on my conversations with other
law enforcement agents, and my examination of various reports and records. Where the contents
of documents and the actions, statements, and conversations of others are reported herein, they are
THE DEFENDANTS
practices primarily in the Wayne, New Jersey area. He is employed as the Medical Director of
JDT Lincoln Park Resorts and Renaissance, located at 52 I Pine Brook Road, Lincoln Park, NJ
07035. In addjtion, GRELLA was also an owner of Integrated Hospital Medicine, a medjcal
practice, located at 224 Hamburg Turnpike, Suite 4023, Wayne, NJ. From January 2002 through
August 2013, WILLIAM GRELLA was also the President of Vital Medical Forces, another
medical practice located in Saint Claire's Dover Hospital, 400 W. Blackwell Street, Dover, NJ .
1Because the purpose of this complaint is merely to establish probable cause to arrest, I have
not set forth all the facts and circumstances concerning this investigation of which I am
aware.
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he established and operates, Oliver & Adelaide, LLC, a Manhattan-based children's clothing
manufacturer that he directs from their residence, while providing care for their adopted children.
THE RESIDENCES
4. From 2003 through March 2012, WILLIAM GRELLA leased an apartment at 327
W. 30th Street, Apt 4E, New York, NY. GARY OSBORNE, now his spouse, shared that
residence. The men later purchased a cottage on the east end of the North Fork of Suffolk County.
The house is located at I 200 1st Street, New Suffolk, NY I 1956. The house was used as a summer
property, 2 Raymond A venue, Chestnut Ridge, NY, located in Rockland County, NY and gave up
their apartment in Manhattan. That residence is within 30 miles of Dr. GRELLA 's various medical
practices in New Jersey. The couple and their two children moved into the house in May 201 2,
opening utility accounts with Orange and Rockland Utilities. Thereafter they used that address on
all their business and personal tax filings as their declared residence.
fashion and clothing line named after their adopted children: "Clever Oliver & Sweet Adelaide
LLC" d/b/a Oli ver & Adelaide. From that first year of business through the present, OSBORNE
filed taxes for the corporation, declarin g the Rockland County, as the location of the business. 2
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In 2010 both GRELLA and Osborne filed taxes using the New Suffolk address as their
residence, however in all subsequent years 20 I 1 to date, the couple declared the Rockland
County address as their residence on tax filings ..
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7. On or about October 30, 20 12, President Obama declared a major disaster for the
areas in the State ofNew York affected by Hurricane Sandy. This disaster area included Suffolk
8. The declaration made federal funds available to Suffolk County residents through
the U.S. Department of Homeland Security ("DHS") Federal Emergency Management Agency
("FEMA"), the U.S. Small Business Administration, and the New York State's Governor's
Office of Storm Recovery ("GOSR") through their NY Rising Housing Recovery Program for
disaster relief.
10. On or about November 12, 2012, GRELLA submitted an application for FEMA
disaster relief, FEMA Registration Number No. 4 1-1439868. GRELLA claimed in the application
that hi s primary residence was in New Suffolk and was damaged by the di saster resulting in the
11. On or about December 18, 20 12, after initially determining GRELLA was ineli gib le
for rental assistance because of flood insurance coverage, FEMA subsequently approved two
months of rental assistance. The approval was based upon information provided by GRELLA that
12. On or about January 16, 201 3, GRELLA submitted an application for Continued
Rental Assistance to FEMA's National Processing Service Center. The letter contained
GRELLA's signature and address in Rockland County, which fa lsely represented that the New
Suffolk cottage, rather than the Rockland County rental as their primary residence, as follows:
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"Please note our lease began on May l , 2013 because the home in Chestnut Ridge
was intended as a vacation rental, however has become our primary residence since
our home in New Suffolk, NY has become inhab itable United Airlines."
Letter ofDr. GRELLA to FEMA, January 16, 2013.
Included in the subm ission was an email, dated January 20, 20 13 with the image of
a cashed check to the landlord, for rent in the amount of $3,750. A number of prior rent receipts,
dated November 8, 2012, December 5, 2012, and January 2, 2013, were provided to FEMA.
13. Also submitted as part of the FEMA application was a falsified copy of the original
lease for the Rockland County house, that GRELLA and OSBORNE rented the property as of
November 1, 2012, after Superstorm Sandy struck Suffolk County. Based on the information
received, FEMA paid the defendants, at least $4,11 6 in disaster recovery funds to which the
14. In December 2012, GRELLA, signed a SBA Home Loan appl ication certifying
hi s eligibility into the loan program as his primary residence in New Suffolk had been flooded
out.
15. Also submitted as part ofthe SBA application was a copy of the fraudulently
altered lease indicating that GRELLA and OSBORNE had onl y rented the Rockland County
16. In February and March 2013, WILLIAM GRELLA, signed SBA Loan
Authorization and Agreements with the SBA, in the amount of $250,300, for a period of 15 years
at an Interest rate of 1.688%. On or about July I 0, 2013, an initial payment of $ 14,000 was wire-
transferred to GRELLAs and OSBORNE bank account Chase Account 8 17353496. GRELLA
and OSBORNE cancelled the remainder of the loan. Based on the information received, SBA
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paid the defendants, at least $14,000 in disaster recovery funds to which the defendants were not
entitled.
17. On or about June 15, 2016, GRELLA re-applied for a loan in the amount of
$300,000.
18. On or about July 22, 2016, GRELLA was declined by the SBA based on
Ridge, NY and not the damaged property in New Suffolk, NY, as listed on their SBA
application.
19. On or about July 21,2016, WILLIAM GRELLA faxed an appeal letter to the U.S.
Small Business Administration. Included was copies ofthe defendants NYS driver license, and a
20. To assist storm-impacted New Yorkers, the Governor's Office of Storm Recovery
("GOSR") operates the NY Rising Housing Recovery Program to facilitate home repairs,
21. From my training and experience, I have learned the following about the eligibility
into the Single Family Homeowner Program, administered by GOSR, funded by HUD, in
You live in one of the counties designated a disaster area as a result of the named storm:
i. Superstorm Sandy: Nassau, Orange, Putnam, Rockland, Suffolk, Sullivan, Ulster,
and WestchesterHurricane Sandy,
ii. Hurricane Irene: Albany, Clinton, Columbia, Delaware, Dutchess, Essex,
Franklin, Greene, Hamilton, Herkimer, Montgomery, Nassau, Orange, Otsego Putnam,
Rensselaer, Rockland, Saratoga, Schenectady, Schoharie, Suffolk, Sullivan, Ulster,
Warren, Washington, and Westchester
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22. Homeowners who are eligible participants in the NY Rising Housing Recovery
Program and are paying both temporary housing costs, such as rent, and mortgage payments may
be eligible to receive assistance from the Interim Mortgage Assistance ("IMA") Program. The
assistance amount is the monthly mortgage costs (interest, principal, taxes, and escrow), to a
23. On or about January 6, 2014, WILLIAM GRELLA and GARY OSBORNE signed
24. On or about January 6, 2014 WILLIAM GRELLA and GARY OSBORNE signed
25. On or about January 14, 2014 WILLIAM GRELLA and GARY OSBORNE
submitted an Interim Mortgage Assistance Tax Assessment Certification Form, certifying "I/we
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owned the Storm Damaged Property and occupied it, as our primary residence, during one or more
26. On or about January 14, 2014 GRELLA and OSBORNE submitted a certification
regarding Interim Mortgage Assistance, certifying that they are receiving funds for temporary
replacement housing while displaced from the Storm Damaged Property which was my/our
primary residence, and that they are NOT receiving funds for mortgage assistance during the
Period ofEiigibility while displaced from the Storm Damaged Property which was my/our primary
residence.
27. On or about January 14, 2014 GRELLA and OSBORNE submitted an Interim
Mortgage Assistance Data Form, certifying Eligibility of their Storm Damaged Property, and
stating Ken Herndon is the landlord they are renting a home from. The form included a lease citing
submitted an Interim Mortgage Assistance Data Form, including a letter, dated January 24, 2014,
from Ken Herndon, on Et Tu Raymond, LLC letterhead stating "Bill Grella and Gary Osborne
have been renting the house at 2 Raymond Ave., Chestnut Ridge, NY from November 2012 to
present. The rent was initially $3 ,750 per month, and was increased to $3,775 per month in June
20 13." Ken Herndon, at the request of GARY OSBORNE, prepared the letter. OSBORNE
specificall y requested the month of November 20 12 be entered as the start of the rental period in
the letter.
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1200 151 Street in New Suffolk, NY is our primary residence. We have not been
able to live in the home since Superstorm Sandy we are located at a different
address because the property is not safe at this time for our 2 small children we
redirected some of our mail because of distance.
30. Based on information available to it at this time, GOSR calculates that, between
March 13, 2014, and August 15, 20 14, GOSR paid to the defendants, at least $34,734 in Single
Family Homeowner disaster recovery funds, and at least $26,805 in Interim Mortgage Assistance
3 1. In various media interviews the defendant OSBORNE identified their New Suffolk
a. In an interview in the New York Times on June 29,2007, the defendant OSBORNE
"We started looking in the South Fork, because a lot of our friend s are out there," said
Gary Osborne, who designs men's wear and has shared a weekend home in Mattituck
with hi s partner, William Grella, for nearly four years. "It was such a different vibe."
They have since bought a third home, south of Mattituck in New Suffolk. "The whole
reason behind having a second home is to spend qui et time at your home," Mr. Osborne
said, "away from work and social life."
concerning the children's clothing manufacturing that OSBORNE started, Oliver & Adelaide,
LLC, a Manhattan-based business. That article states: "He's hired stay-at-home moms and retirees
on the North Fork of Long Island where he spends weekends ... "
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WHEREFORE, deponent prays that warrants be issued for the arrest of WILLIAM
GRELLA and GARY OSBORNE, the defendants, and that they be arrested.
Stephen Kim
Special Agent
U.S. Department of Housing and Urban
Development, Office of Inspector General
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