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BOYD M. JOHNSON I11
RITA GLAVIN
DANIEL STEIN
Assistant United States Attorneys
Before: HONORABLE RONALD L. ELLIS
United States Magistrate Judge
Southern District of New York
- - - - - - - - - - - - - - - - - -X $MAG 0463 ALED COMPLAINT
UNITED STATES OF AMERICA
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
COUNTY OF OFFENSE:
NEW YORK 8
Defendants.
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 HollanderIN 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.
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 Hollandert1I 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 sexua| 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,I1 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 sexua| 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
located at URL
http://www.emperorsclubvip.com.
that included photographs
of prostitutesf 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 f0r.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,
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 exbended
prostitution date with a client to cost $25,000 or more.
rn. 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 H~llander,t~he 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;
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 H~llander,t~h e 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;
v. 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.)
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 uqe 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.";
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.
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.
-7-
KENNETH HOSEY
Special Agent
Federal Bureau of Investigation
Sworn to before me this
6 day of March, 2008.
SOUTHERN DISTRICT OF NEX YORK
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK mAcrFl) - - - - - - - - - - - - - - - - - -X
IN THE MATTER OF THE APPLICATION SEALED
OF THE UNITED STATES OF AMERICA AFFIDAVIT IN SUPPORT
OF, APPLICATION FOR
FOR ARREST WARRANTS, SEARCH ARREST WARRANTS,
SEARCH WARRANTS, AND
WARRANTS, AND SEI ZURE WARRANTS SEIZURE WARRANTS
- - - - - - - - - - - - - - - - - -X
STATE OF NEW YORK 1
COUNTY OF NEW YORK : SS.:
SOUTHERN DISTRICT OF NEW YORK )
KENNETH HOSEY, being duly sworn, deposes and says:
I. INTRODUCTION
1. I have been a Special Agent with the Federal
Bureau of Investigation ("FBI" ) for approximately twelve years.
During that period, I have participated in investigations
involving surveillance, undercover transactions, the introduction
of undercover agents, debriefings of informants, and reviews of '
recorded conversations and documents. I have also participated
in numerous arrests.
2. I make this Affidavit in support of the following
applications:
a. An application for warrants to arrest
MICHAEL BRENER, a/k/a "Mi~hael,.'C~E CIL 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;
b. An application for warrants to search the
following premises:
1 Because this location is in the District of New Jersey,
I will be requesting the search warrant from a United States
Magistrate Judge for the District of New Jersey.
c. An application for seizure warrants for the
following:
b - d(in) iAll funds
(ii)
3. I have been involved in the investigation of this
case. This Affidavit is based upon, among other things, my
personal participation in this investigation, my conversations
with other law enforcement officers who have participated in this
investigation, my review of court-authorized wire and electronic
communications and e-mails recovered from search warrants, my
review of bank records and other documents, and my participation
in physical surveillance. Because this Affidavit is being
submitted for the limited purpose of establishing probable cause,
it does not include all of the facts that I have learned during
this investigation. Where I report statements made by others,
those statements are reported in substance and in part.
4. As explained in more detail below, there is
probable cause to believe that the defendants are organizers and
managers of a criminal organization engaged in illegal
prostitution and money-laundering activities throughout the
United States and Europe.
2 Because this location is in Brooklyn, New York, I will
be requesting the search warrant from a United States Magistrate
Judge in the Eastern District of New York.
11. THE EMPERORS CLUB'S PROSTITUTION CRIMES
A. Overview
5. In or about October 2007, the FBI and the United
States Internal Revenue Service-Criminal Investigative Division
("IRS-CID") began an investigation focusing on an organization
suspected of conducting prostitution and money-laundering crimes
in the United States and Europe. Through the investigation, the
FBI and IRS have determined that MARK BRENER, a/k/a 'Michael,"
CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," TEMEKA RACHELI+E LEWIS,
a/k/a "Rachelle," and TANYA HOLLANDER, a/k/a "Tania Hollander,"
the defendants, organized, managed, and operated the Emperors
Club VIP ("Emperors Club"), an international criminal
organization engaged in illegal prostitution and money-laundering
activities. BRENER, SUWAL, LEWIS, and HOLLANDER used the
Emperors Club to arrange for prostitution activity between
wealthy male clients and more than 50 prostitutes in, among other
places, New York, New York; Washington, D.C.; Los Angeles,
California; Miami, F10rida;~ London, England; and Paris, France.
The defendants charged the Emperors Club's clients fees ranging
from $1,000 to more than $5,500 per hour for prostitution
services.
6. Through the Emperors Club, 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, received more than $1 million
in illicit proceeds from their international prostitution
business. BRENER, SUWAL, LEWIS, and HOLLANDER accepted payment
3 At all times relevant to this Affidavit, New York State
law made it a crime when a person "engages or agrees or offers to
engage in sexua| conduct with another person in return for a
fee." NY CLS Penal § 230.00. Similarly, District of Colombia
law made it a crime for "any person to engage in prostitution or
to solicit for prostitution," which is defined as "a sexua| act
or contact with another person in return for giving or receiving
a fee," D.C. Code § 22-2701; California law made it a crime for a
person to "pay money or other valuable thing for, any person for
the purpose of prostitution," which is defined to include 'any
lewd act between persons for money or other consideration,"
California Penal Code §§ 266(e), 647; and Florida law made it a
crime to commit or solicit prostitution, which is defined as "the
giving or receiving of the body for sexua| activity for hire,"
Florida Statutes § 796.07.
from their clients in the form of cash, American Express charges,
wire transfers, and money orders. To conceal the nature of the
Emperors Club prostitution business, MARK BRENER, a/k/a
"Michael, " and CECIL SUWAL, a/k/a "Katie, " a/k/a "Kate, " the
defendants, received prostitution proceeds in United States bank
accounts in the names of front companies, including QAT
Consulting Group, Inc. and QAT International, Inc.
7. As demonstrated below, the evidence obtained
during this investigation includes, among other things,
statements of a confidential source who worked with the Emperors
Club; statements of an undercover officer; more than 5,000
telephone calls and text messages intercepted pursuant to courtauthorized
wiretaps; more than 6,000 e-mails recovered pursuant
to court-authorized search warrants; bank records; travel and
hotel records; and physical surveillance.
8. The evidence has established that the four
defendants played different roles with respect to the criminal
activities of the Emperors Club:
a. MARK BRENER, a/k/a "Michael," the defendant,
was the leader of the Emperors Club. BRENER had the ultimate
decision-making authority over the Emperors Club. BRENER
recruited prospective prostitutes, determined how to market the
Emperors Club's prostitutes to clients, and resolved problems
that arose with the Emperors Club's clients and prostitutes.
b. CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the
defendant, was the day-to-day organizer of the Emperors Club's
operations. SUWAL controlled the Emperors Club bank accounts,
supervised the Emperors Club's booking agents, and received
applications from the Emperors Club's prospective prostitutes.
c. TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," and
TANYA HOLLANDER, a/k/a "Tania Hollander," the defendants, were
booking agents for the Emperors Club. LEWIS and HOLLANDER took
requests over the telephone from the Emperors Club's clients for
prostitution services, coordinated over the telephone with the
Emperors Club's prostitutes to carry out acts of prostitution,
and referred issues relating to payment for prostitution services
to CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant.
B. The CS
9. I have spoken with another law enforcement officer
who has been involved in the investigation of a number of
prostitution businesses in the New York City area. The law
enforcement officer informed me that in the end of 2006 he spoke
with a confidential source (the "CS") who had worked as a
prostitute in New York City. The CS was immunized from
prosecution as a result of her cooperation with law enforcement.
In addition, the law enforcement officer with whom I spoke
confirmed that the CS had provided information that was reliable
and corroborated by independent evidence. The CS told the law
enforcement officer that during 2006 she worked for the Emperors
Club as a prostitute.
10. In an effort to further corroborate the
information provided by the CS, I have reviewed bank records for
a b a n kacc ount- in the name of QAT
Consulting Group, Inc. (the "First QAT Account"). According to
the bank records, in 2006, the CS in fact received a check for
more than $1,000 from the First QAT Account. As discussed in
further detail below, the defendants have directed clients of the
Emperors Club to make payments for prostitution services to the
and also to a second bank account a tbank
Facicr -osAQutn t in the name of QAT International, Inc. (the
"Second QAT Account" ) .
C. The Undercover
11. In the course of this investigation, I have worked
with an agent acting in an undercover capacity (the
"Undercover"). The Undercover posed as a potential client of the
Emperors Club prostitution business, and made arrangements over
the telephone with TEMEKA RACHELLE LEWIS, a/k/a "Rachelle, " the
defendant, for an appointment with an Emperors Club prostitute.
He then coordinated over e-mail with CECIL SUWAL, a/k/a 'Katie,"
a/k/a "Kate," the defendant, to make a deposit of more than
$1,000 towards the appointment in the Second QAT Account.
12. The Undercover initially went on the Internet and
accessed a website located at URL
http://www.emperorsclubvip.com.
(the
"Website"). The Website included photographs of Emperors Club
prostitutes' bodies, with their faces hidden, along with hourly
rates for different categories of prostitutes. The Website
ranked the prostitutes using a ranking system from one to seven
diamonds, and charged hourly rates according to the assigned
ranking. For example, according to the Website, the Emperors
Club charged $1,000 per hour for a three-diamond prostitute, and
$3,100 per hour for a seven-diamond prostitute. The Website
offered the Emperors Club's most valued clients 'membership" in
the 'Icon Club," a status which allowed the clients to access
restricted areas of the Website and permitted them to schedule
appointments for illegal prostitution services with the most
highly-ranked prostitutes whose fees started at $5,500 per hour.
According to the Website, in certain circumstances, the Emperors
Club also offered its clients the opportunity to exercise a "buyout
clause," which permitted them to purchase direct access to
one of the Emperors Club's prostitutes without having to contact
the agency. The Website listed (212) 812-2114 (the "2114
Number") as one of the numbers for clients to use to contact the
Emperors Club.
13. On or about October 20, 2007, at approximately
9 :30 p.m., the Undercover placed a call to the 2114 Number, which
I have determined from toll records was forwarded to a cellular
telephone assigned call number 6 5 8 7(th e "6587
Number"). The call was answered by TEMEKA RACHELLE LEWIS, a/k/a
"Rachelle," the defendant.' During the conversation, the
Undercover and LEWIS discussed an appointment the Undercover
wanted to arrange for October 25, 2007. The Undercover explained
that he was hoping to have a "good night" for himself. LEWIS
asked the Undercover which particular woman he wanted to see, to
which the Undercover responded that all the women on the Website
were 'beautiful." The Undercover requested an appointment with
"Helena" - one of the women depicted on the Website - but LEWIS
told him that "Helena" was "based in London." The Undercover
then asked for an appointment with "Drew," to which LEWIS
4 As discussed below, I have determined that telephone
calls placed to the 2114 Number were typically forwarded to
various cellular telephones used by 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.
5 My belief that the person using the 6587 Number in this
and other calls summarized above was LEWIS is based on the
following: First, an IRS-CID agent working on this case has
reviewed bank records for the First QAT Account for the period
December 10, 2004, through January 2008. The IRS-CID agent has
determined that during this time period approximately $53,473.00
worth of checks were written from the First QAT Account to
"Rachelle Lewis," a portion of which were negotiated through an
account at in According
to records obtained fr current address for the 4
account is 0
On February 28, 2008,
th LEWIS, who identified
herself as "Tameka Lewis," and saw her enter- --- at - . Second, during calls intercepted over the 6587
-consistently identified herself over the telephone
as either "Rachelle" or 'Temeka."
responded that "Drew" was based in New York, but had very limited
availability. The Undercover stated that he was looking for
someone who was "physically very attractive" and had a "fun
per~onality."~L EWIS stated that, based on the women the
Undercover had identified, it sounded like the Undercover was not
necessarily interested in "that model look," but maybe someone "a
little curvier than a model." After the Undercover agreed, LEWIS
said that "Drew" was a 'great choice." If "Drew" was not
available, LEWIS said she would recommend "Raquel," whom she
described as a "brunette" who was "beautiful . . . All-American .
. . very clean, . . . very fresh." She explained that "Raquel"
and "Drew" had "similar body types," though 'Raquel" was
"probably a little bit bustier on top." LEWIS told the
Undercover that for "Drew" there was a "two-hour, introductory
rate" of $2,000, and that "Raquel's" hourly rate was $1,500 for
the first two hours, with a discount to $1,200 for the third
hour. The conversation ended with the Undercover asking LEWIS
for a follow-up call to confirm the arrangements, which LEWIS
promised to do. LEWIS further stated that she could be reached
at either the "212 number" (believed to be a reference to the
2114 Number) or the "347 number" (believed to be a reference to
the 6587 Number), and that the Undercover could always reach her
directly at the "347 number. "
14. On or about October 22, 2007, at approximately
2:33 p.m., the Undercover received a call from TEMEKA RACHELLE '
LEWIS, a/k/a "Rachelle," the defendant. During the call, LEWIS
and the Undercover confirmed an appointment for the Undercover to
meet "Raquel." LEWIS told the Undercover that he would have to
meet 'Raquel" at a "private location just . . . for the beginning
of the appointment . . . where she would collect the fee," and
suggested that they meet at 'a hotel or a private home." The
Undercover asked if there was another way he could handle the
payment of the fee, and LEWIS responded that he could either "pay
cash," use his American Express card, or pay by wire transfer.
The Undercover expressed a preference for a wire transfer, and
LEWIS told him she would send him the necessary information,
asking if she could send it to him by text message.
15. On or about October 22, 2007, at approximately
3:24 p.m., the Undercover called the 2114 Number, which was
The Undercover also stated that, in the long term, he
wanted to discuss "other things" with LEWIS, such as, hiring a
group of women to entertain his clients. LEWIS said that
"certainly could be arranged," and that 'our models are the types
of women who can handle themselves well in any situation."
forwarded to another cellular telephone, and spoke to TEMEKA
RACHELLE LEWIS, a/k/a "Rachelle," the defendant. During the
call, LEWIS stated that she had spoken to "the office," and that
they preferred to send him the wire transfer information by email.
The Undercover provided LEWIS with his e-mail address.
16. The Undercover subsequently received an e-mail
from an e-mail address identified as
"reservations@emperorsclubvip.com." The e-mail provided the
Undercover with instructions for paying his fee by wire transfer
and was signed by "Katie," which I believe to be an alias used by
CECIL SUWAL, the defendant. In the e-mail, "Katie" identified
the Second QAT Account as the bank account where the Undercover
should send his wire transfer. The Undercover later wire
transferred more than $1,000 to the Second QAT Account .7
17. On or about November 29, 2007, at approximately
3:47 p.m., the Undercover called TEMEKA RACHELLE LEWIS, a/k/a
"Rachelle," the defendant, on the 6587 Number. During the call,
the Undercover asked to reschedule his appointment with "Raquel."
LEWIS told the Undercover that "Raquel" had moved back to Los
Angeles, California. The Undercover then asked if "Raquel" would
travel back from California to New York to be with him. LEWIS
stated that "Raquel" would travel, but it would have to be a
lengthy appointment. LEWIS told the Undercover that she would
have to check with "Raquel" about her availability. During a
later call on November 29, 2007, over the 6587 Number, LEWIS
confirmed to the Undercover that Raquel would travel to New
Jersey for an appointment with the Undercover.
D. The Interce~ted Communications And Seized E-Mails
18. Based in part on the information provided by the
CS and the Undercover, described above, on or about January 8,
2008, the Honorable Charles S. Haight, United States District
Judge for the Southern District of Nel~ York, authorized the
interception of telephone calls and text messages over the 6587
Number. On or about February 7, 2008, authorization expired, but
was renewed on or about February 11, 2008, by the Honorable
Gerard E. Lynch. On or about January 23, 2008, based in part on
7 The Undercover later told TEMEKA RACHELLE LEWIS, a/k/a
"Rachelle," the defendant, that he had to reschedule his October
25, 2007, appointment. As discussed above, the FBI relied on the
Undercover's recorded conversations with LEWIS, among other
evidence, to support an application for court authorization to
wiretap the 6587 Number.
communications intercepted over the 6587 Number, the Honorable
Leonard B. Sand, United States District Judge for the Southern
District of New York, authorized the interception of telephone
calls and text messages over the cellular telephone assigned call
number 3 3 9 0(th e "3390 Number") , which was used by
CECIL SUWAL, a/k/a "Katie, " a/k/a "Kate," and MARK BRENER, a/k/a
"Michael," the defendants, to operate the Emperors Club and to
make strategic decisions regarding its prostitution and moneylaundering
activities. On or about February 21, 2008, the
Honorable Lawrence M. McKenna, United States District Judge for
the Southern District of New York, re-authorized the interception
of telephone calls and text messages over the 3390 Number. To
date, the FBI has intercepted more than 5,000 telephone'calls and
text messages over the 6587 Number and the 3390 Number.
19. On or about January 25, 2008, based on wiretap
interceptions and other evidence developed during the
investigation, the FBI obtained a search warrant from the
Honorable Gabriel W. Gorenstein, United States Magistrate Judge
for the Southern District of New York, for the content of the email
account entitled "emperorsclubvipny@yahoo.com" (the
"Emperors Club E-Mail Account"), which was used primarily by MARK
BRENER, a/k/a "Michael," and CECIL SUWAL, a/k/a "Katie," a/k/a
"Kate," the defendants, to recruit new prostitutes for the
Emperors Club. As a result of the search warrant, the FBI
obtained more than 6,000 e-mails relating to the Emperors Club's
operations.
20. The intercepted telephone calls and text messages,
combined with the recovered e-mails, demonstrate 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, collectively
managed the prostitution activities of the Emperors Club. These
intercepted wire and electronic communications also confirmed
that the defendants were, among other things: (1) making various
strategic decisions regarding the Emperors Club's criminal
operations; (2) using cellular telephones and e-mail to promote
prostitution in the United States and Europe; and (3) conspiring
with certain clients to transport prostitutes interstate for the
purposes of' prostitution.
1. The Emperors Club' s Operational Issues
21. During a number of intercepted telephone calls the
text messages, and recovered e-mails, the defendants discussed
various strategic issues relating to the Emperors Club. These
issues included relationships with the Emperors Club's clients,
the recruitment, marketing, and advertising of Emperors Club's
prostitutes, hourly rates and other payment issues, and problems
that arose with the Emperors Club's prostitutes and clients. A
number of these intercepted telephone calls and text messages and
recovered e-mails are summarized below.
The 'Buy-Out" Option
22. On January 10, 2008, at approximately 8:44 p.m.,'
MARK BRENER, a/k/a "Michael," the defendantlg using the 3390
Number, called TEMEKA RACHELLE LEWIS, a/k/a. "Rachelle," the
defendant, at the 6587 Number. During the call, BRENER and LEWIS
discussed a business arrangement, which they referred to as a
'buy-out," by which a client of the Emperors Club could "buy out"
a prostitute, and thereby arrange appointments with her without
having to go through the Emperors Club. At one p.oint in the
conversation, BRENER handed the telephone to CECIL SUWAL, a/k/a
8 All times are Eastern Standard Time unless otherwise
indicated.
9 My belief that the person using the 3390 Number in this
and other calls summarized above, and using the telephone
assigned call number -0937 (the '0937 Number") in other
calls summarized above, was BRENER is based on, among other
things, the following: First, the 3390 Number and the 0937
Number are both subscribed to CECIL SUWAL, a/k/a "Katie," a/k/a
"Kate," the defendant, at
that the account of MARK HKENER also is reaistered to BRENER at
intercepted calls over the 3390 Number and the 0937 Number, an
individLa1 referred to as "Michael" discussed traveling with
SUWAL to meet with other co-conspirators. Other FBI agents then
observed BRENER with SUWAL on.surveillance meeting with other coconspirators.
Moreover, after a series of intercepted calls
involving "Michael" and SUWAL, on January 28, 2008, I observed
individuals resembling BRENER and SUWAL inside their-
-minivan near the vicinity of Grand Central Terminal in
Manhattan. Also, a New York City Police Department Officer, at
the FBI's request, identified the man driving the Honda Odyssey
as BRENER. As a result, I believe that the "Michael" speaking
over the 3390 Number and the 0937 Number during the course of the
wiretaps was BRENER.
"Katie, " a/k/a "Kate, " the defendant, lo who continued discussing
the same subject with LEWIS; in particular, SUWAL and LEWIS
discussed a specific client who had expressed interest in such an
arrangement, and the fact that they needed to find out how much
such an arrangement was worth for that client. SUWAL indicated
that during a conversation the day before they had disregarded
this client's potential for the "buy out." SUWAL then stated:
"[Oln second thought . . . why would we completely disregard him.
[I] f . . . maybe a good deal could come of it , . . . maybe it
would come more [money] than . . . what we're currently seeing
and receiving from him. So . . . when he calls asking for
'Raquel' [believed to be the alias of a prostitute], he wants to
see her again, again, again, . . . you can always say, 'YOU know,
you may be interested in privately dating her which is when . . .
you contact her directly . . . and not necessarily going through
the agency.'" (Call 865C).
b. Advertisinq
23. On January 12, 2008, at approximately 8:59 p.m.,
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, using the
6587 Number, called MARK BRENER, a/k/a 'MichaellN the defendant,
at the 0937 Number. During the call, BRENER and LEWIS discussed
the Emperors Club's prostitution operations in Los Angeles,
California. LEWIS told BRENER: "I don't know if, if you're gonna
lo My belief that the person using the 3390 Number in this
and other calls summarized above, and using the 0937 Number in
other calls summarized above, was SUWAL is based on, among other
things, the following: First, the 3390 Number and the 0937
Number are subscribed in the name "Cecil Suwal." Second, on
January 17, 2008, there were calls between the 3390 Number and
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle, " the defendant, on the
6587 Number, regarding meeting in New Jersey. Around the time of
these calls, other FBI agents and I were following the-
-inivan and observed both MARK BRENER, a/k/a "Michael,"
the defendant. and a female I believed to be SUWAL inside.
Another FBI agent then observed LEWIS enter the
with SUWAL and BRENER. Another FBI agent
license photograph of SUWAL with the person who was inside the
a n dbelieve d that the person was SUWAL. Third,
during February 2008, the FBI intercepted calls over the 3390
Number during which the speaker said that she and "Michael,"
believed to be a reference to BRENER, were traveling to London.
From law enforcement records, I have determined that during
February 2008 SUWAL and BRENER in fact traveled to London under
their true names.
be advertising but . . . it's just been really, really slow in LA
. . . We have a lot of girls there now . . . we need calls."
BRENER said that he understood, and thanked LEWIS. (Call 1507R).
Recruitment Of Prostitutes
24. On January 18, 2008, CECIL SUWAL, a/k/a "Katie,"
a/k/a "Kate," the defendant, sent an e-mail from the Emperors
Club E-Mail Account to a potential prostitute. In the e-mail,
SUWAL stated: 'It was a pleasure meeting you last night. If you
are having trouble emailing the pictures perhaps we can just meet
up, take them and then return them to you the next day after we
scan them into the computer. You can also feel free to email any
that are 'email-ablet now. . . ."
25. On January 24, 2008, CECIL SUWAL, a/k/a "Katie,"
a/k/a "Kate," the defendant, received an e-mail at the Emperors
Club E-Mail Account from a potential prostitute. In the e-mail,
the potential prostitute wrote:
Hi, I have just spoke to a friend of mine who done
[sic] her first job for you . . . Unfortunately I
wasn't very happy to find out that its only 500 ph +
over 50% commission fees . . . I was aware of 50% but
didn't know the price was 500 . . . This is a kind of
money I make very easily in photoshoots and the reason
I wanted to join your site to make an extra money . . .
The other think [sic] I was little bit shock and
confuse that she had a sex with him twice in an hour
and without her [sic] taking her out for dinner before.
. So I am very sorry I don't think this is my kind of
thing. I was told by your assistant in London this is
more like a dating agency than an escort. But to
provide sex for £500 an hour, I just thing [sic] this
is not a price I would ever consider of doing it for. .
d. Marketinq
26. On January 19, 2008, MARK BRENER, a/k/a "Michael,"
the defendant, using the 0937 Number, called TEMEKA RACHELLE
LEWIS, a/k/a "Rachelle," the defendant, at the 6587 Number.
During the call, BRENER asked LEWIS if his "intervention" was
needed regarding the unavailability of a girl for an Emperors
Club client in Miami, Florida. LEWIS told BRENER no, and listed
three prostitutes who were working in Miami. BRENER commented
that one of the prostitutes "looks like [a] butcher in my
opinion," and told LEWIS that he was not sure if LEWIS could
"market this girl." BRENER and LEWIS then discussed the other
two Miami-based prostitutes. BRENER asked LEWIS if the Miami
client sounded like a rich person, and BRENER indicated that he
was thinking of offering the client "membership." BRENER
commented : " [I] f he' s rich guy . . . we send or fly somebody .to
them, right?'' BRENER and LEWIS then discussed coaching another
prostitute, and LEWIS suggested that "Katie," a reference to
CECIL SUWAL, a/k/a "Katie, " a/k/a "Kate, " ,the defendant, should
call her. LEWIS stated that she doubted that the prostitute they
were discussing would ever be an "Icon" model. (Call 2344R) .
27. On February 11, 2008, at approximately 12,:53 p.m.,
CECIL SUWAL, a/k/a "Katie, " a/k/a "Kate, " the defendant, using
the 3390 Number, sent a text message to TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, at the 6587 Number, stating:
" [Cl hrissy is at $2100/hr." (Call 3582C) . LEWIS responded: "New
pix or same ones?" (Call 3585C). SUWAL stated: "Same ones . . .
she'll have new ones soon but so far the ones she 1st gave are
the best. " (Call 3588C) . LEWIS responded: ’Ok." (Call 3598C) .
SUWAL, using the 3390 Number, sent another text message to LEWIS
at the 6587 Number, stating: " [S] omeone asked what her 3 day rate
was. I told him about 50,000 & that emilys was about 35,000 in
case he calls." (Call 3594C) . LEWIS replied: "Ok. " (Call
3598C).
e. Availability Of Prostitutes
28. On January 18, 2008, at approximately 5:41 p.m.,
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, using the
6587 Number, received a call from a new pro~ti~utweo rking with
the Emperors Club. LEWIS and the new prostitute discussed an
upcoming date that LEWIS had scheduled for her in Los Angeles,
California. The new prostitute told LEWIS that she had talked to
'Katie,,, a reference to CECIL SUWAL, a/k/a "Katie," a/k/a "Kate,"
the defendant, but she had never done anything like this before
and was a little bit nervous about it. LEWIS said that she would
let the client know that this was her first appointment, and
indicated that "Katie" could best answer how to handle oneself on
an appointment. The new prostitute was concerned because she
wanted to be more anonymous, and did not want to be pictured on
the Website in part because of her family background. LEWIS told
the new prostitute that it was in her interest to have pictures
on the Website, and commented: "There are some pictures where I
think that even if you knew who the person was, you couldn't
really identify [them]." LEWIS suggested that when "Katie"
cropped the pictures, she should tell "Katie" that she did not
want anything above the chin. The new prostitute and LEWIS
discussed the possibility of the new prostitute becoming an
"Icon" model with Emperors Club. (Call 2207R).
29. At approximately 5 : 5 1 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, received
a call from CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the
defendant, using t h e 0937 Number. During the call, LEWIS
referred to the conversation she had earlier with the new
prostitute. LEWIS stated that she did not know why the new
prostitute was even considered because she was "clueless" and
"looking . . . to be on Icon portfolio. SWAL stated: " [W] e
don' t even know if we can charge 1200 [let alone] 5000 ." SWAL
suggested that LEWIS emphasize to the client that it was the new
prostitute's first date. (Call 2212R) .
30. At approximately 7:05 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, received
a call from an Emperors Club client based in Los Angeles,
California. LEWIS and the client discussed an appointment
between the client and the new prostitute, whom LEWIS referred to
as "Felana.,, LEWIS claimed that she was waiting to hear back
from "Felana," but cautioned the client that this would be her
first appointment. The client responded: "Sounds great to me."
LEWIS stated: "What your expectations are might not be fulfilled
just because it's just her very first appointment ever." The
client said that he would "take [his] chances." LEWIS described
another prostitute whom the Emperors Club marketed as "Samantha"
to the client, stating that she was a professional model, 5 feet
9 inches tall, 115 pounds, and in her early 20s. The client
stated that if "Felana" was unavailable, he would see "Samantha"
later in the week. (Call 2226R).
31. On or about January 24, 2008, CECIL SWAL, a/k/a
"Katie," a/k/a "Kate," the defendant, sent an e-mail from the
Emperors Club E-Mail Account to TEMEKA RACHELLE LEWIS, a/k/a
u~achelle", the defendant, at the e-mail address
I N 1The subjec t line for this e-mail was
"Most Updated Version!", and SUWAL attached a list of the aliases
used by- more than 50 prostitutes, including those designated as
vIcons," working with the Emperors Club in, among other places,
New York, New York; Los Angeles, California; Miami, Florida;
11 MY belief that LEWIS was us
inf ormatTon another Taw enf orcement o
bank. when LEWIS o~ened her account a
ing the e-ma
fact that,
ff icer obtai
t -bank,
il address
according to
ned from HSBC
she provided
s as part of her contact
London, England; and Paris, France.
32. On or about January 30, 2008, at approximately
9:55 p.m., TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the
defendant, using the 6587 Number, called MARK BRENER, a/k/a
"Michael, " and CECIL SUWAL, a/k/a "Katie, " a/k/a "Kate, " the
defendants, at the 0937 Number, to discuss problems with one of
the Emperors Club's prostitutes in Los Angeles. During the call,
LEWIS explained to BRENER that the prostitute missed an
appointment, and had left a "crazy text" for her last night.
LEWIS told BRENER that he might not want to send the prostitute
out any more. BRENER and LEWIS discussed the possibility that
the prostitute was on drugs. SUWAL, speaking in the background,
commented that there was an "elephant standing in the living
room" with respect to the prostitute's actions. BRENER agreed
that LEWIS could not do business with the prostitute the way she
was acting. LEWIS commented that it seemed that 'a lot of these
girls deteriorate to this point." (Call 4554R).
33. On January 30, 2008, at approximately 1:46 p.m.,
CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant, using
the 3390 Number, sent a text message to TANYA HOLLANDER, a/k/a
"Tania Hollander", l2 the defendant, at the cellular telephone
assigned call number -1627 (the "1627 Numbert1). In the
text message, SWAL told HOLLANDER: "[Client] would like to meet
someone in nyc feb lEt O 6pm. Pls call him O [Client's number] .&
(Call 849C) . Later that day, at approximately 7 :24 p.m., SWAL,
using the 3390 Number, sent HOLLANDER another text message at the
1627 Number. In the text message, SUWAL told HOLLANDER: "Pls
send madison & trina in ny if possible. They're new & in order
to absorb them we have to give them some work." (Call 885C).
Approximately five minutes later, at approximately 7:29 p.m.,
HOLLANDER responded by sending a text message from the 1627
Number to SUWAL at the 3390 Number, stating: 'Of course." (Call
l2 My belief that HOLLANDER was the person using the 1627
Number in this and other intercepted calls and text messages
summarized above is based on the following: First, during
intercepted* calls over the 1627 Number, HOLLANDER consistently is
referred to as 'Tanya." Second, on January 28, 2008, after a
series of intercepted calls over the 1627 Number where the
"Tanya" on the telephone agreed to meet with CECIL SWAL, a/k/a
'Katie," a/k/a "Kate," and MARC BRENER, a/k/a "Michael," the
defendants, another asent and I observed a woman we believed to
be HOLLANDER in the vicinity of the -minivan with
SUWAL and BRENER inside. Finally, c ecks SWAL has written from
the First QAT Account have been made out to "Tanya Hollander."
3 4 . On February 1 0 , 2008, at approximately 6 : 2 6 p.m.,
CECIL SUWAL, a/k/a "Katie, " a/k/a "Kate, " the defendant, using
the 3390 Number, called TANYA HOLLANDER, a/k/a "Tania Hollander,"
the defendant, at the 1627 Number. During the c a l l , SUWAL asked
HOLLANDER i f she was ever able to reach the Emperors Club c l i e n t
who "Madison" saw. HOLLANDER said that she called two times, but
he never called back. SUWAL stated that he was a new c l i e n t , and
she stayed for just 40 minutes. SUWAL continued: "We're
thinking that t h e r e ' s a chance that the reason she stayed 40
minutes 'cause we just found out the other day that she has
children and she went t o pick them up from school immediately
afterwards . . . I don't know i f . . . she i n t e n t i o n a l l y cut it
short . . . to pick up her children . . . but, as a general rule,
the g i r l s who have children tend t o have . . . a l i t t l e more
baggage going on." HOLLANDER stated that she did not know who
"Madison" checked i n with, but HOLLANDER told h e r several t i m e s
t o c a l l HOLLANDER once a t the room and then that HOLLANDER would
c a l l her a t the end of the hour. HOLLANDER s a i d t h a t she was
f i n a l l y about to reach her, and found out l a t e r t h a t she had
l e f t . SUWAL indicated t h a t it was a problem i f she was "cutting
it short." (Call 3537C).
f . Hourly Rates
35. On January 25, 2008, a t approximately 12:49 p.m.,
MARK BRENER, a/k/a "Michael," and CECIL SUWAL, a/k/a "Katie,"
a/k/a "Kate," the defendants, using the 3390 Number, called a
p r o s t i t u t e using the name "Sophie" a t a number i n London,
England. During the c a l l , SUWAL told "Sophie" that she had
received "Sophie's" e-mail i n which "Sophie" s t a t e d t h a t she was
not comfortable with the 2ayment she had received. SUWAL t o l d
'Sophie" that they would t r y to r a i s e "Sophief sf, 'rate.
"Sophie" stated t h a t she could not speak openly because she was
i n a 'public area," but asked what kind of "charges do the other
g i r l s charge?" SUWAL indicated that the r a t e s ranged from 500
[British pounds] t o "very high rates." SWAL t o l d "Sophie" that
someone named "Michael," a reference to BRENER was there t o speak
with her. SUWAL put BRENER on the telephone with "Sophie."
BRENER told "SophieN that t h e i r goal in r e c r u i t i n g people was t o
bring them to the point where they could join "Icon models."
BRENER continued t h a t it was "much more pleasant for us t o s p l i t
$5,000 than $1,200 o r whatever." SUWAL got back on the
telephone. "Sophie" told SUWAL that she thought t h a t i n t i m e she
could join "Icon," and SUWAL told "Sophieff that they would r a i s e
her r a t e . (Call 329C) .
36. On or about February 4, 2008, at approximately
11:05 a.m., TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the
defendant, using the 6587 Number, received a call from CECIL
SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant, using the 3390
Number. During the call, SUWAL and LEWIS discussed the fact that
some of the Emperors Club prostitutes were not properly taking
imprints of the clients' American Express cards. SUWAL told
LEWIS to ask the prostitutes to fax the imprints, or if that did
not work to scan them and e-mail the imprints, and then send the
originals in the event of a dispute with the clients about the
charge, or if American Express inquired. MARK BRENER, a/k/a
"Michael," the defendant, commented in the background that he
thought one of the prostitutes ignored him when he told her how
to fill out the credit card slips. SUWAL complained about a fax
of a credit card slip she received from a prostitute, and stated:
'[Ilf American Express were to ask to see that, as a legitimate
business, you can't even deliver something like that." (Call
6538R).
2. The Emperors Club's Domestic Prostitution
Operations
37. During a number of intercepted telephone calls and
text messages, the defendants made arrangements for acts of
prostitution in the United States, including in, among other
cities, New York, New York; Los Angeles, California; and Miami,
Florida. A number of these telephone calls and text messages are
summarized below.
a. New York, New York
i. January 12 and 13, 2008
38. On January 12, 2008, at approximately 4:59 p.m.,
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, using the
6587 Number, spoke over the telephone with an Emperors Club
client ('Client-1") . During the call, LEWIS told Client-1 that a
prostitute the Emperors Club marketed using the alias "Kristen"
was available at 9:00 p.m. the following day. Client-1 said
fine. LEWIS stated that "Kristen" was new so she did not have
images up, and that her hourly rate was $1,000. Client-1 told
LEWIS that he would be staying at a hotel downtown. LEWIS told
Client-1 to let her know his room number after he checked in.
(Call 1467R) .
39. On January 13, 2008, at approximately 3:29 p.m.,
Client-1 called TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the
defendant, at the 6587 Number. Client-1 told LEWIS that he had
checked in at the hotel, and that his room number was 2006.
LEWIS confirmed the location of the hotel, and told Client-1 that
everything was set for 9 p.m. (Call 1556R).
40. On January 13, 2008, at approximately 8:59 p.m.,
"Kristen" sent a text message to TEMEKA RACHELLE LEWIS, a/k/a
"Rachelle," the defendant, at the 6587 Number. In the text
message, "Kristen" stated: "I am going to be late. It is pouring
rain, and I couldn't find my little pocket book with all my
slips! This is a cash appt, so I hope this is not a problem. .
." (Call 1593R). Approximately two minutes later, LEWIS, using
the 6587 Number, sent "Kristen" a text message, stating: "Ok.
It's a cash appt. Will let client know ur running late. R."
(Call 1597R). Immediately thereafter, LEWIS, using the 6587
Number, called the hotel, and was connected to room 2006. LEWIS
then spoke with Client-1, and told him that "Kristen" was running
a little late due to rain and traffic. LEWIS stated that
"Kristen" would be there by 9:15 p.m. (Call 1598).
41. At approximately 9:15 p.m., "Kristen" called
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, at the
6587 Number. "Kristen" told LEWIS that she was there, and that
everything was okay. LEWIS told "Kristen1' that she would called
her in an hour. (Call 1608R). At approximately 10:17 p.m.,
LEWIS, using the 6587 Number, sent "Kristent1 a text message,
stating: "It's been an hr. Pls call." (Call 1612R).
Approximately one minute later, at approximately 10:18 p.m.,
"Kristen" sent a text message to LEWIS at the 6587 Number,
stating: "I am walking out now. Xo." (Call 1613R) .
ii. January 15, 2008
42. On January 15, 2008, at approximately 7:38 p.m.,
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, using the
6587 Number, received a call from an Emperors Club client
("Client-2"). During the call, Client-2 said that he was looking
for a girl tonight at 11 p.m. at a hotel in New York, New York.
Client-2 told LEWIS that he has used the service before. LEWIS
told client12 that she believed that a prostitute who the
Emperors Club marketed using the name "Emily" was available, and
also discussed two other Emperors Club prostitutes with Client-2.
LEWIS told Client-2 that she would make some calls and get back
to him. (Call 1809R) .
43. At approximately 8:04 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, spoke
with "Emily." During the call, LEWIS offered "Emily" two
appointments: the first for one hour with a client who had used
the service before, liked model types, and was easy; the second
for multiple hours with a client who was a "partier." "Emily1'
said she had a casting this week, so the one-hour appointment
would be best. (Call 1840R) .
44. Approximately two minutes later, at 8:08 p.m.,
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, using the
6587 Number, received a call from Client-2. LEWIS confirmed that
"Emily" would be available at 11 p.m. LEWIS described "Emily" as
a professional model, 23 years old, with strawberry blonde hair
and fair skin, 5 feet 9 inches tall, and 116 pounds, with an
hourly rate of $1,500. Client-2 said he was in room number 1916.
(1843R).
45. At approximately 8:42 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, sent a
text message to CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the
defendant, at the 3390 Number. In the text message, LEWIS listed
the three appointments she was working on, including the 11 p.m.
appointment between Client -2 and "Emily. " (1876R) .
46. At approximately 10:53 p.m., TEMEKA RACHELLE
LEWIS, a/k/a "Rachelle," the defendant, using the 6587 Number,
received a call from "Emily." During the call, "Emily" stated
that she was "there" (believed to be a reference to the fact that
she had arrived at the appointment with Client-2). (Call 1918R).
b. Los Anqeles, California
i. Januarv 22-24, 2008
47. On January 22, 2008, at approximately 11:28 a.m.,
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, using the
6587 Number, received a call from an Bmperors Club client
("Client-3") . During the call, LEWIS told Client-3 that a
prostitute that the Emperors Club marketed using the name
"Samantha" would be available on Thursday [January 24, 20081 at
3:30 p.m. Client-3 said that he would make hotel arrangements.
Client-3 indicated that he would pick a hotel on the west side of
Los Angeles so that it was convenient for him. LEWIS told
Client-3 that because of a "new policy," the Emperors Club would
require a 55% deposit for his date with "Samantha." Based on
other calls intercepted in this case, I believe that the reason
LEWIS asked Client-3 for a 55% deposit was because the Emperors
Club was having problems collecting money from "Samantha," who
they believed might be abusing drugs. Client-3 stated: "What?"
LEWIS explained that " [t] he office would just e-mail you the
financial details so that you could either do a wire transter or
. . . a direct deposit." Client-3 responded: "A wire transfer
from my bank?,, LEWIS said yes, or a direct deposit intobank.
Client-3 asked whether direct deposit meant going to the
bank himself, and LEWIS confirmed that it did. LEWIS said that
most clients did wire transfers, and Client-3 stated: "I don't
really like either one . . . ah . . . and,to whom does it get
paid?" LEWIS stated: 'It's to QAT Consulting, so it's a
consulting firm . . . I mean it shows up like as a business
transaction." Client-3 told LEWIS that it was getting harder and
harder to do business with 'them' [a reference to the Emperor's
Club]." (Call 2690R).
48. On January 22, 2008, at approximately 12:04 p.m.,
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, using the
6587 Number, sent a text message to CECIL SUWAL, a/k/a "Kat?e,"
a/k/a "Kate," the defendant, at the 3390 Number. In the text
message, LEWIS told SUWAL: "Pls send [Client-31 the info needed
to make 55% deposit. His e-mail is [Client-3's e-mail address]."
(Call 2698R) . Later that day, at approximately 4 :30 p.m., LEWIS,
using the 6587 Number, received a call from Client-3. During the
call, Client-3 stated that he did the wire transfer for "$1500."
Client-3 told LEWIS that the appointment would be at a particular
hotel in Santa Monica, [California] , at 3 :30 p.m. (Pacific
StandardTirne ("P.S.T.")). L E W I S t o l d C l i e n t - 3 t h a t s h e h a d '
confirmed everything with "SamanthaI1'a nd told Client-3 to
provide his room number when he checked in. Client-3 asked
whether he could pay the difference to "Samantha" if he wanted to
extend, and LEWIS said he could. (Call 2761R).
49. On January 24, 2008, at approximately 6:06 p.m.,
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, using the
6587 Number, received a call from Client-3. During the call,
Client-3 told LEWIS that he was in room 506, and described where
the elevators were. Client-3 said that he should be ready at
3:30 p.m. P.S.T. (Call 3426R).
50. At approximately 6:38 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, called
"Samantha."' LEWIS told "Samantha" that she had a problem with
her telephone earlier, "Samanthal1 said she was driving there now.
(Call 3485R). One minute later, at approximately 6:39 p.m.,
LEWIS, using the 6587 Number, called Client-3, and told him that
"Samantha" would be there in five to ten minutes. (Call 3486R).
51. At approximately 6:56 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, received
a call from "Samantha," who told LEWIS that she was there. LEWIS
said it was room 506, and told her where the elevators were.
(Call 3489R). Approximately three minutes later, at
approximately 6:59 p.m., LEWIS, using the 6587 Number, called
"Samantha." LEWIS told her: "I forgot to tell you, you're
'Samantha.'" "Samantha" said okay, and that she had just walked
in and "everything's great." (Call 3497R).
52. Approximately two hours later, at approximately
8:59 p.m., TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the
defendant, using the 6587 Number, called Client-3. LEWIS asked
Client-3 how his meeting was, and Client-3 said it was great.
Client-3 and LEWIS then discussed a new prostitute on the
Website. (3527R) .
ii. January 26-27, 2008
53. On January 26, 2008, at approximately 8:05 p.m.,
TEMEKA RACHELLE LEWIS, a/k/a 'Rachelle," the defendant,, using the
6587 Number, received a call from an Emperors Club client
("Client-4") in Los Angeles, California. During the call,
Client-4 said that he was staying in Los Angeles, and wanted to
know if there was anyone available on short notice for 9:30 p.m.
(P.S.T.) that evening. LEWIS and Client-4 discussed various
Emperors Club prostitutes as possibilities. (Call 3915R).
54. At approximately 9:41 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, called
Client-4. LEWIS told Client-4 that "Raquel" was not available,
but that "Chrissy" would be. LEWIS said that "Chrissy" was new
to the agency, had four stars, and a rate of $1,200 per hour.
Client-4 said perfect. LEWIS told Client-4 she would try to make
the appointment for 9:00 or 9:30 p.m. (Call 3931R). At
approximately 9 : 5 2 p.m., LEWIS, using the 6587 Number, sent a
text message to "Chrissy" on her cellular telephone. In the text
message, she stated: ' [Client-4's name] , [Hotel] Beverly Hills .
. . Room 467 9:30pm lhr. 1380 credit Client may extend." (Call
3934R) .
55. On January 27, 2008, at approximately 12:05 a.m.,
TEMEKA RACHELLE LEWIS, a/k/a 'Rachelle," the defendant, using the 1
6587 Number, received a call from Client-4. Client-4 said that
he just got back to the hotel room and pulled up the Website.
Client-4 asked: "Who are we looking at?" LEWIS said it was
'Chrissy," and explained that she had misquoted "Chrissyls" rate
at $1,200 per hour because she was actually five diamonds which
meant a rate of $1,500 per hour. Client-4 and LEWIS negotiated
the rate for "Chrissy," and ultimately agreed that Client-4 would
pay $305 in cash and charge $1,300 on his credit card. (Call
3947R). At approximately 12:14 a.m., LEWIS, using the 6587
Number, sent a text message to "Chrissy," stating: "305 cash 1300
credit." (Call 3954R).
56. On January 27, 2008, at approximately 1:40 a.m.,
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, using the
6587 Number, called Client-4. LEWIS asked Client-4 how the
appointment was. Client-4 said "two A+s in a row. . . I don1 t know
where you get these young ladies . . ." Client-4 asked if there
was any "traceability," and added that he could "get it 'past my
accountant and auditor as a business expense but you sometimes
hear of these agencies getting busted, you know, that's my really
only concern, that's why I don't call more often." LEWIS
responded: 'I would say no . . . the tax ID for the business is
QAT Consulting." Client-4 asked if that was a real company, and
LEWIS replied: 'It is . . . it exists . . . there are real
offices in New York City." Client-4 stated: "That' s how they
usually come after you . . . fake company." LEWIS replied:
"Exactly, just as long as you pay your taxes, you're fine."
(Call 3969R) .
c. Miami, Florida
57. On February 2, 2008, at approximately 11:45 a.m.,
TANYA HOLLANDER, a/k/a "Tania Hollandert1,t he defendant, using
the 1627 Number, called TEMEKA RACHELLE LEWIS, a/k/a "Rachelle,"
the defendant, at the 6587 Number. During the call, LEWIS asked
HOLLANRER if she had problems booking in New York and Miami
because there were no people to send out. HOLLANDER said that in
Miami, yes, they do not have enough variety down there. LEWIS
complained about the fact that there were not enough people
available in Mlami, and commented that it did not make sense to
advertise in Miami if there were not enough people to come out.
HOLLANDER said that she totally agreed with LEWIS. (Call 6125R).
58. A few minutes later, at approximately 11:48 a.m.,
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, using the
6587 Number; called MARK BRENER, a/k/a "Michael," the defendant,
at the 0937 Number. During the call, LEWIS told BRENER that she
had a client who used the service in New York who wanted to see
multiple girls for multiple hours in Miami. LEWIS suggested
tonight, and that the client wanted three girls, possibly four,
for four hours each. LEWIS indicated that she only had two
girls, and might lose the entire appointment. BRENER agreed that
it was frustrating, and suggested sending someone from New York.
LEWIS said that it was too late - she had checked the flights and
they were either sold out or the one way fare was too expensive.
(Call 6127R) .
59. At approximately 1:48 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, sent a
text message to a prostitute who the Emperors Club marketed using
the name "Dorine. " In the text message, LEWIS told "Dorine" :
"Waiting 4 client 2 confirm. Client has used service in NY
before & booked 4 multiple hrs. Appt may start after 6pm. Will
let u know when I speak 2 client. R." (Call 6157R) . One minute
later, at approximately 1:49 p.m., 'Dorine" sent LEWIS a text
message at the 6587 Number, stating "Thx." (Call 6161R) .
60. At approximately 4:37 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle,'" the defendant, using the 6587 Number, called an
Emperors Club client ("Client-5") in Miami, Florida. During the
call, Client-5 said that he wanted "both of them" (believed to be
a reference to two Emperors Club prostitutes) for 6:00,p.m.
Client-5 said that one would pay cash, and the other would use a
credit card. Client-5 confirmed with LEWIS that the cost would
be "1000" per hour and four hours for "36" (believed to be a
reference to $3,600). Client-5 confirmed with LEWIS that the
girls Itlike to have fun," and then provided the address for the
appointment to LEWIS. (Call 6197R).
61. At approximately 4:58 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, called
"Dorine." LEWIS told "Dorine" that she would be meeting with two
clients, and that another model would be joining her. LEWIS said
that the "client" (believed to be a reference to Client-5) had
used the service in New York, and that the last time he saw
someone for many, many hours. LEWIS and "Dorine" then discussed
the amount of money and credit card charges "Dorine" should
receive from Client-5. (Call 6212R). At approximately 5:12
p.m., LEWIS, using the 6587 Number, sent a text message to
'Dorine," stating: "The other model's name is Michelle. Pls go
inside house together. If client pays cash its 1000/hr OR 3600/4
hrs. If client pays credit its 1150/hr OR 4140/4hrs." (Call
6218R). Approximately one minute later, at approximately 5:13
p.m., LEWIS, using the 6587 Number, sent a text message to
"Michelle," stating: "The other model's name is Dorine. Pls go
inside house together. If client pays cash its 1000/hr OR 3600/4
hrs. If client pays credit its 1150/hr OR 4140/4 hrs." (Call
6221) .
62. At approximately 6:16 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, received
a call from "Dorlne." During the call, "Dorine" stated that
"they" (believed to be a reference to "Dorine" and "Michelle")
were there, and were going in. LEWIS told "Dorine" to call back
after they collected. (Call 6250R). At approximately 6 : 3 8 p.m.,
LEWIS, using the 6587 Number, called Client-5. During the call,
Client-5 complimented the girls, and confirmed the cost for four
hours would be $3,600. LEWIS confirmed that the cost would be
$3,600 if paying in cash and $4,140 if paying by credit card.
Client-5 passed the telephone to "Dorine." LEWIS told 'Dorine"
that they had to collect $3,600 in cash and $4,140 on credit.
(Call 6258R) . At approximately 7: 05 p.m., LEWIS, using 'the 6587
Number, received a call from "Dorine," who told LEWIS that
"they're very nice ... just ... sitting by the pool ... not doing
anything, just talking so far." (Call 6279R) . Approximately two
hours later, at approximately 9: 13 p.m., LEWIS, using the 6587
Number, called "Michelle," who told LEWIS that the clients were
asleep, and discussed the amount of money that "Michelle" and
"Dorine" had been paid. (Call 6325R) .
3. The Emperors Club's International Prostitution
Operat ions
63. During a number of intercepted telephone calls and
text messages, and recovered e-mails, the defendants made ,
arrangements for acts of prostitution in various locations in
Europe. Several of these intercepted telephone calls and text
messages and recovered e-mails are summarized below.
a. London, Enqland
i. January 12, 2008
64. On January 12, 2008, at approximately 9:00 a.m.,
TEMEKA RACHELLE LEWIS, a/k/a 'Rachells," the defendant, using the
6587 Number, called a prostitute based in London, England, who
the Emperors Club marketed under the name "A~trid.~'D uring the
call, "Astrid" told LEWIS that she was there with the client
("Client-6"). LEWIS asked to speak with Client-6. LEWIS told
Client-6 that they had not yet received his deposit. Client-6
said that he would give everything to "Astrid." LEWIS told
Client-6 that when the deposit arrived, he could use it for his
next appointment. "Astrid" got back on the telephone, and LEWIS
told her that Client-6 was going to give her 500 pounds, and that
LEWIS would call her in an hour. (Call 1301R) .
65. At approximately 10:04 a.m., TEMEKA RACHELLE
LEWIS, a/k/a "Rachelle," the defendant, using the 6587 Number,
retrieved a message from [Astrid], who stated that she was
leaving Client-6 and everything was fine. LEWIS then received an
incoming call from Client-6. LEWIS asked Client-6 how it went,
and he said that she was very nice. Client-6 stated, however,
that next time he wanted to see someone else. Client-6 told
LEWIS that he would give her a call next week. (Call 1342R).
ii. January 24, 2008
66. On or about January 24, 2008, CECIL SUWAL, a/k/a
''Katie," a/k/a "Kate," the defendant, sent an e-mail to an
Emperors Club prostitute. In the e-mail, SUWAL asked the
prostitute if she would be available on February 11, 2008, for a
prostitution appointment in Europe with a client to cost $25,000
or more.
b. Vienna, Austria
67. On February 11, 2008, at approximately 12:22 p.m.,
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, received
an incoming call from an Emperors Club client ("Client-7") based
in Europe. Client-7 told LEWIS that he just landed in Vienna,
and was on his way to the hotel. Client-7 indicated that he
would call back with his room number. (Call 3578C). At
approximately 12:53 p.m., Client-7 called LEWIS and told her that
he was in room 511. (Call 3580C) .
68. At approximately 1:02 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, sent a
text message to CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the
defendant, at the 3390 Number. In the text message, LEWIS
stated: "How long is 'Aveline's' appt?l1 (Call 3602C). In
response, SUWAL sent a text message to LEWIS, stating: "[Client-
71 has enough credit that they can take their time this evening
and tomorrow morning. She . . . doesn't necessarily have to race
out @ 9am." (Call 3605C) .
4. The Emperors Club's Interstate Transportation Of
Prostitutes
69. During a number of intercepted telephone calls and
text messages, 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, made arrangements with clients to
transport Emperors Club prostitutes interstate for purposes of
prostitution. A number of the intercepted telephone calls and
text messages relating to the interstate transportation are
summarized below.
a. February 15, 2008, Interstate Transportation
From California To Las Veqas, Nevada
70. On February 7, 2008, at approximately 12:13 a.m.,
TANYA HOLLANDER, a/k/a "Tania Hollander," 'the defendant, using
the 1627 Number, sent a text message to CECIL SUWAL, a/k/a
"Katie," a/k/a "Kate," the defendant, from the 3390 Number. In
the text message, HOLLANDER wrote: '[An Emperors Club client
("Client-an)] would like to fly falana out to las vegas ,on fri.
do you thnk that is an ok first appt for her?" (Call 2081C).
71. On February 11, 2008, at approximately 9:28 p.m.,
CECIL SUWAL, a/k/a 'Katie," a/k/a "Kate," the defendant, using
the 3390 Number, received a call from a representative of Client-
8. During the call, the representative, who said he was calling
on behalf of Client-8, asked if "Felana" would be available for
Friday night. .SUWAL informed the representative that Client-8
would have to pay a deposit to the Emperors Club to secure
"Falana's" transportation to Las Vegas. SUWAL and the
representative discussed Client-8 sending a wire transfer to pay
for the deposit. (Call 3692C) .
72. Notwithstanding the foregoing calls, on February
12, 2008, at 9:58 p.m., TEMEKA RACHELLE LEWIS, a/k/a "Rachelle,"
the defendant, using the 6587 Number, spoke with Client-8's
representative. LEWIS told the representative that "Falana"
would not be available for the appointment with Client-8. (Call
9550R).
b. February 13, 2008, Interstate Transportation
From New York To Washinqton, D.C.
73. On February 11, 2008, at approximately 10:53 p.m.,
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, using the
6587 Number, sent a text message to CECIL SUWAL, a/k/a "Katie,"
a/k/a "Kate," the defendant, at the 3390 Number. In the text
message, LEWIS wrote: 'Pls let me know if [Client-9's] 'package'
(believed to be a reference to a deposit of money sent by mail)
arrives 2mrw. Appt wd b on Wed." (Call 3728C). SUWAL sent a
text message back to LEWIS, stating: 'K." (Call 3731C).
74. On February 12, 2008, at approximately 2:37 p.m.,
TEMEKA RACHELLE LEWIS, a/k/a 'Rachelle," the defendant, using the
6587 Number, called a prostitute who the Emperors Club marketed
using the name "Kristen." During the call, LEWIS left a message
for "Kristen" that the "deposit" had not arrived today, but that
they should be able to do the trip if the deposit arrived
tomorrow. (Call 9324R) . At approximately 4 : 03 p.m. , LEWIS
received a call from "Kristen." During the call, "Kristen" said
that she had heard the message, and that was fine. LEWIS and
"Kristen" then discussed the time that "Kristen" would take the
train from New York to Washington, D.C. LEWIS told "Kristen"
that there was a 5:39 p.m. train that arrived at 9:00 p.m., and
that "Kristen" would be taking the train out of Penn Station.
LEWIS confirmed that Client-9 would be paying for everything -
train tickets, cab fare from the hotel and back, mini bar or room
service, travel time, and hotel. LEWIS said that they would ..
probably not know until 3 p.m. if the deposit arrived because
Client-9 would not do traditional wire transferring. (Call
9362) .
75. At approximately 8:12 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, received
a call from Client-9. During the call, LEWIS told Client-9 that
the "package" did not arrive today. LEWIS asked Client-9 if
there was a return address on the envelope, and Client-9 said no.
LEWIS asked: "You had QAT . . .," and Client-9 said: "Yup, same
as in the past, no question about it." LEWIS asked Client-9 what
time he was interested in having the appointment tomorrow.
Client-9 told her 9:00 p.m. or 10:OO p.m. LEWIS told Client-9 to
call her back in five minutes. (Call 9460R) .
76. At approximately 8:14 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, called
MARK BRENER, a/k/a "Michael," the defendant, at the 0937 Number.
During the call, LEWIS told BRENER that Client-9 had just called
about an appointment for tomorrow, and that he had around $400 or
$500 credit. SUWAL said that she did not feel comfortable saying
that Client-9 had a $400 credit when she did not know that for a
fact. SUWAL and BRENER talked in the background about whether
Client-9 could proceed with the appointment without his deposit
having arrived. (Call 9462R). At approximately 8:23 p.m., LEWIS
called Client-9, and told him that the 'office" said he could not
proceed with the appointment with his available credit. After
discussing ways to resolve the situation, LEWIS and Client-9 I
agreed to speak the following day. (Call 9467R) .
77. On February 12, 2008, at approximately 9:22 p.m.,
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, using the
6587 Number, sent a text message to ''Kristen." In the text
message, LEWIS wrote: 'If D.C. appt. happens u will need 2 leave
NYC @ 4:45pm. Is that possible?" (Call 9515R). "Kristen" wrote
back: "Yes." (Call 9516R) .
78. At approximately 3 : 2 0 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, received
a call from Client-9. During the call, LEWIS told Client-9 that
they were still trying to determine if his deposit had arrived.
Client-9 told LEWIS that he had made a re'servation at the hotel,
and had paid for it in his name. Client-9 said that there would
be a key waiting for her, and told LEWIS that what he had on
account with her covered the "transportation" (believed to be a
reference to the cost of the trainfare for "Kristen" from New
York to Washington, D.C.). LEWIS said that she would try to make
it work. (Call 9636R). At approximately 3:24 p.m., LEWIS, using
the 6587 Number, called CECIL SUWAL, a/k/a "Katie," a/k/a "Kate,"
the defendant, at the 3390 Number. LEWIS explained to SUWAL what
Client-9 had proposed. SUWAL told LEWIS she would call her back.
(Call 9642R) . At approximately 3 : 53 p.m., MARK BRENER, a/k/a
"Michael," the defendant, using the 0937 Number, called LEWIS at
the 6587 Number. BRENER and LEWIS discussed the problem about
Client-9's deposit. (Call 9654R). At approximately 4:18 p.m.,
SUWAL, using the 3390 Number, sent a text message to LEWIS at the
6587 Number, stating: "[Plackage arrived. Pls be sure he rsvp
hotel." (Call 9659R) .
79. At approximately 4:21 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle, " the defendant, using the 6587 Number, called
"Kri~ten.~Du ring the call, LEWIS told "Kristen" that the
package had arrived, and that "theyu (believed to be a reference
to MARK BRENER, a/k/a "Michael," and CECIL SUWAL, a/k/a "Katie,"
a/k/a "Kate," the defendants) just got the mail. LEWIS told
"Kristen" to get to Penn Station and call her when she picked up
her tickets. (Call 9661R) . At approximately 4 :48 p.m., LEWIS
sent a text message to "Kristen," stating: "TRAIN INFO Departing
from Penn St. Arriving 8 Union St. Washington, DC NYC to DC Train
129 Dep. 5:39pm Arr. 9pm." (Call 9G79R). At approximately
4:54 p.m., LEWIS sent another text message to "KristenItts tating:
"TRAIN INFO Return trip DC to NYC Train 84 Dep. 2/14 8:35pm Arr.
ll:57am." (Call 9683R).
80. At approximately 4:58 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, received
an incoming call from Client-9. During the call, LEWIS told
Client-9 that his package arrived today, and Client-9 said good.
LEWIS asked Client-9 what time he was expecting to have the
appointment. Client-9 told LEWIS maybe 10:OO p.m. or so, and
asked who it was. LEWIS said it was "Kristen," and Client-9 said
"great, okay, wonderful ." LEWIS told Client-9 that she would
give him a final price later, and asked Client-9 whether he could
give "Kristen" "extra funds" at this appointment in order to
avoid payment issues in the future. Client-9 said maybe, and
that he would see if he could do that. LEWIS explained that the
agency did not want a model accepting funds for a future
appointment, but that she was going to make an exception that way
a deposit could be made so that he would have a credit, and they
would not have to "go through this" next time. Client-9 said
perfect, and that he would call her regarding the room number.
(Call 9686R) .
81. At approximately 7:51 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, received
a call from Client-9. During the call, LEWIS told Client-9 that
the balance was around ,"2611 (believed to be a reference to
$2,600), but she would give him an exact number later. LEWIS
asked if when "Kristen" went to pick up the key she would have to
give a name or would she be able to say that she was one of
Client-9's guests for whom he left an envelope. ~EW1~'and
Client-9 discussed how to arrange for "Kristen" to get the key to
her hotel room. LEWIS said that she would prefer if "Kristen"
did not have to give a name. Client-9 said that he was trying to
'think this through." Client-9 repeated that his balance was
'2600," and stated that maybe he would give "her," a reference to
"Kristen," '3600" and have a thousand on balance. LEWIS
suggested making it "1500fl more. Client-9 said that would make
it "4100," and said that he would look for a bank and see about
it. Client-9 told LEWIS to let him go down and take care of
this, and suggested that maybe he could put it [the hotel key] in
an envelope with the concierge. (Call 9725R).
82. At approximately 8:47 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, received
a call from Client-9. During the call, Client-9 told LEWIS to
tell "Kristen" to go to the hotel and go to room 871. Client-9
told LEWIS that the door would be open. Client-9 told LEWIS that
there would be a key in the room, but the door would be ajar.
LEWIS asked if the hotel staff might pass by the door and close
it, and Client-9 said no it was okay. Client-9 explained that
the door would not be visibly open, but if someone pushed it, the 4
door would open. LEWIS told Client-9 that his balance was
$2,721.41, and that if he wanted to do an additional "150OU or
even "2000" it would be better. Client-9 said that he did not
know if he could get to a machine to do that, but he would see.
LEWIS said that 'Kristen" would go directly to room ,871. Client-
9 asked LEWIS to remind- him what 'Kristen" looked like, and LEWIS
said that she was an American, petite, very pretty brunette, 5
feet 5 inches, and 105 pounds. Client-9 said that she should go
straight to 871, and if for any reason it did not work out, she
should call LEWIS. (Call 9731) .
83. At approximately 9 : 3 2 p.m., TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant, using the 6587 Number, received
a call from "Kristen." During the call, '"Kristen" said that she
was in the room. LEWIS told "Kristen" that she would call her
back when she knew when Client-9 would be there. (Call 9734R).
84. At approximately 9:36 p.m., TEMEKA RACHELLE LEWIS,
a/k/a 'Rachelle," the defendant, using the 6587 Number, received
a call from "Kristen." During the call, LEWIS told "Kristen"
that "he," a reference to Client-9, was at the hotel. "Kristen"
told LEWIS that she just talked to him. 'Kristen" said that
Client-9 was coming'to her. LEWIS told "Kristen" that Client-9
should be giving her "extra," and that the extra should be
deposited into- LEWIS told "Kristen" to text her when he
arrived and LEWIS would start the four hours then, and also to
let her know if he left early. (Call 9741R).
85. On February 14, 2008, at approximately 12:02 a.m.,
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, received
a call from "Kristen." During the call, "Kristen" told LEWIS ,
that "he," a reference to Client-9, had left. LEWIS asked
"Kristen" what time he got there, and "Kristen" said "15 after .
. . maybe 10." LEWIS asked "Kristen" how she thought the
appointment went, and "Kristen" said that she thought it went
very well. LEWIS asked "Kristen" how much she collected, and
'Kristen" said $4,300. "Kristen" said that she liked him, and
that she did not think he was difficult. "Kristen" stated: 'I
don't think he's difficult. I mean it's just kind of like . . .
whatever. . . I'm here for a purpose. I know what my purpose is.
I am not a . . . m*o*o*n, you know what I mean. So maybe that's
why girls maybe think they're difficult . . . . " "Kristen"
continued: "That's what it is, because you're here for a
[purpose]. Let's not get it twisted - I know what I do, you
know." LEWIS responded: "You look at it very uniquely, because .
. . no one .ever says it that way." LEWIS continued that from
what she had been told "he" (believed to be a reference to
Client-9) "would ask you to do things that, like, you might not
think were safe - you know - I mean that . . . very basic things.
. . . "Kristen" responded: "I have a way of dealing with that .
. . I'd be like listen dude, you really want the sex? . . . You
know what I mean." Near the end of the call, LEWIS and "Kristen"
discussed "Kristen's" departure via Amtrak, the room that Client9
had provided for "Kristen," and "Kristen's" share of the cash
that Client-9 had provided to her. (Call 9750R).
c. March 4, 2008, Interstate Transportation From
California to Chicaqo, Illinois
86. During February 2008, the FBI intercepted a series
of telephone calls and text messages over the 6587 Number
regarding an Emperors Club client ("Client-10") who requested a
date in Chicago, Illinois, on March 4, 2008. As discussed below,
in order to accommodate Client-10's request, TEMEKA RACHELLE
LEWIS, a/k/a "Rachelle," the defendant, informed Client-10 that
he would have to pay the costs of transportation for the
prostitute from California to Chicago.
87. On February 22, 2008, at approximately 7:48 p.m.,
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle, " the defendant, using the
6587 Number, spoke with Client-10. During the call, LEWIS and
Client-10 discussed the possibility of a prostitute the Emperors
Club marketed under the name "Chrissy" traveling to ch=cago for a
date with Client-10 on March 4, 2008. LEWIS informed Client-10
that he would be responsible for the airfare for "Chrissy" to
Chicago, and discussed additional expenses he would owe related
to the travel. (Call 11503R) .
88. On February 29, 2009, at approximately 1:41 p.m.,
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, using the
6587 Number, sent a text message to CECIL SUWAL, a/k/a "Katie,"
a/k/a "Kate," the defendant, at the 3390 Number. In the text
message, LEWIS stated: "CHRISSY'S FLIGHT INFO orbitz.com LAX to
OIHare United 110 Dep. 3/4 10:05 a.m. Arr. 4:05pm OtHare to
LaGuardia. United 692 Dep. 3/5 8:45pm Arr. ll:45pm $482.98."
(Call 13817R) .
THE EMPERORS CLUBt S MONEY LAUNDERING CRIMES
89. As discussed above, MARK BRENER, a/k/a "Michael,"
and CECIL SUWAL, a/k/a "Katie, " a/k/a "Kate, " the defendants,
have laundered the proceeds of the Emperors Club prostitution
business primarily through two bank accounts in the names of "QAT
Consulting Group, Inc. " (the "First QAT Account") and "QAT
International, Inc . " (the "Second QAT Ac~ount) ~(~c ollectively,
the "QAT Accounts"). As discussed below, from in or about
December 2004 through at -least in or about January 2008, I
believe that BRENER and SUWAL have used the QAT Accounts to
launder more than $1 million in proceeds from the Emperors Club
prostitution business.
90. Based on my review of bank records and my review
of documents prepared by the IRS-CID agents involved in this
investigation, I have determined that CECIL SUWAL, a/k/a "Katie,"
a/k/a "Kate," the defendant, opened the First QAT Account on or
about December 10, 2004. In the account opening documents, SUWAL
claimed that QAT Consulting Group, Inc., was an active company
with an address of
and a mailing address of
4 'According to the N ew York Department of
State website, however, QAT was an inactive corporation, and its
current entity name was "Protech Consultants, Inc . Protech
Consultants, however, was also listed as an inactive company by
the New York Department of State. Moreover, other agents
involved in this investigation have determined that the 0
faddress was merely the address for a mail -
receiving and forwarding service.
91. Based on my review of bank records and my review
of documents prepared by IRS-CID agents, I have also determined
that CECIL SUWAL, a/k/a "Katie.," a/k/a "Kate," the defendant,
opened the Second QAT Account on or about November 30, 2006. In
the account opening documents, SUWAL claimed that she was the
President of "QAT International, Inc.," and provided 1040 Avenue
of the Americas as the address for the business.
92. I have reviewed account activity for the QAT
Accounts. Based on my review, I have determined that from in or
about December 2004 to at least in or about January 2008 Emperors
Club clients have sent more than $1 million in payments for
prostitution services to the QAT Accounts. Emperors Club clients
have sent these payments primarily in the form of American
Express credits and wire transfers from both inside and outside
the United States.
93. From my review of bank records and my review of
documents prepared by IRS-CID agents, I have also determined that
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 $lOO,OtOO in checks to cash from the QAT Accounts. During
the same time period, SUWAL wrote more than $39,000 in checks
from the QAT Accounts to Protech Consultants. I have spoken with
an IRS-CID agent who determined from his review of bank records
that from in or about September 2003 through in or about October
2006, MARK BRENER, a/k/a "Michael," the defendant, controlled an
account in the name of Protech Consultants at -
94. I have also determined from my discussions with
IRS-CID agents who have analyzed the bank records in this case
that from in or about November 2005 to in or about January 2008,
CECIL SWAL, a/k/a "Katie," a/k/a "Kate," the defendant, wrote
approximately $53,473.00 in checks from the QAT Accounts to
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant. From in
or about July 2007 to in or about January 2008, SUWAL wrote
approximately $4,870 in checks from the QAT Accounts to TANYA
HOLLANDER, a/k/a ItTania Hollander," the defendant. SUWAL also
wrote approximately $22,616.00 in checks from the QAT Accounts to
herself. In addition, from in or about December 2004 to in or
about January 2008, SUWAL sent more than $400,000 in checks and
wire transfers from the QAT Accounts to more than 50 Emperors
Club prostitutes in the United States and Europe.
95. Based on the foregoing, I believe that MARK
BRENER, a/k/a "Michael," and CECIL SUWAL, a/k/a "Katie," a/k/a
"Kate," the defendants, have used and are using the QAT Accounts
to commit money-laundering crimes. Specifically, I believe that
BRENER and SUWAL have used and are using the QAT ~ccounts to
promote the Emperors Club's prostitution business and to conceal
the illicit nature of the proceeds of its illegal activities.
IV. THE APPLICATION FOR ARREST WARRANTS
96. Based on the foregoing, the Government requests
that arrest warrants be issued for 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, so.that they may be arrested and detained or
bailed, as the case may be.-
V. THE APPLICATION FOR SEARCH WARRANTS
A. Th I-ef Premises
97. For the reasons discussed below, I submit there
is probable cause to believe that there is presently located at
f a one-bedroom apartment with affixed to the
door and located o nB- tfhe atJ 4-
apartment building at - m (the 1, evidence, fruits, and
instrumentalities of violations of the federal prostitution and
money-laundering offenses alleged herein. More specifically, as
set forth below, based on (1) records for the First QAT Account,
(2) surveillance at m ,( 3 ) e-mail records
and Internet service provider records, and (4) intercepted wire
communications, I submit that there is probable cause to believe
that CECIL SUIdAL, a/k/a "Katie," a/k/a "Kate, " and MARK BRENER,
a/k/a "Michael," the defendan tsb, l-ive at the
that SUWAL and BRENER operate the Emperors cluTis prostitution
business out of 4 and that records
(electronic and otherwise) and other evidence pertaininq- to that
prostitution busin esus- a4re a t
1. Payments From The F i r s t QAT Account For The
98. A s set forth above, I have reviewed bank records
for the F i r s t QAT Account, for which CECIL SUWAL, a/k/a "Katie,"
a/k/a "Kate," the defendant, is a signatory. For the years 2005,
2006, 2007, and 2008, there were numerous checks written from
that account t --o-- - totaling more than $30,000. The checks were written on almost a monthly basis to
Notations on these checks include
l1Brenerl1 and, account
-- heck I have reviewed
from b -thI e( QAT Account to -I!
was dated January 1, 2008, and it also contains the notation
- -- .-- I have not seen any apartment number other than
-d on the checks from the First QAT Account to
99. On February 26, 2008, an FBI agent called
which is a number l i s t e d for
e agent spoke to an individual, -- -. -
who conf i r i e d that
-
is a property
management company,
property man
2008, a law
door.
100. Within the past three weeks, another law
enforcement officer has reviewed the Internet websi t e for - at internet address The
E t a i n s sa mple floor ploartments on the
line in that building. The floor plans show that -apartments
are one-bedroom apartments that consist of a kitchen, living room
and dining area, a bedroom, a bathroom, and a terrace.
2 . January 17, 2008, Surveillance Of BRENER And SUWAL
101. On January 17, 2008, based on intercepted
cornrnunications over the 6587 Number, law enforcement agents
learned that MARK BRENER, a/k/a "Michael," and TEMEKA RACHELLE
LEWIS, a/k/a "Rachelle," the defendants, planned to meet that
day. Specifically, on January 16, 2008, at approximately 8:31
p.m., BRENER called LEWIS at the 6587 Number. During the call,
BRENER and LEWIS discussed meeting the next day, January 17,
2008. BRENER suggested meeting LEWIS in Fort Lee, New Jersey,
after BRENER finished a morning meeting in Manhattan. (Call
1956R). On January 17, 2008, at approximately 11:12 a.m., BRENER
called LEWIS at the 6587 Number and left a voice mail message
asking LEWIS when they should meet, and BRENER told LEWIS to call
him or send a message to "Katie," a reference to CECIL SUWAL,
a/k/a "Katie," a/k/a "Kate," the defendant, because BRENER1s
telephone was having difficulty taking messages. (Call 1976R).
102. That same day, at approximately 11:34 a.m.,
TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the defendant, using the
6587 Number, sent a text message to the CECIL SUWAL, a/k/a
"Katie," a/k/a "Kate," the defendant, stating that the "cashn was
"$2320 ." (Call 1978R) . Based on my participation in this
investigation, I believe that these text messages referred to
payments for illegal prostitution activities, and that MARK
BRENER, a/k/a "Michael," the defendant, SUWAL and LEWIS were ,
planning to meet that day to discuss the financial activities of
the Emperors Club and payments related to work for that illegal
business.
103. Based on these intercepted communications on
January 16 and 17, 2008, I and other agents conducted
surveillance in the vicinity of m. At
approximately 12:45 p.m. on JanuFry 17, 2008, another FBI agent
observed individuals who I believe to be MARK BRENER, a/k/a
"Michael," and CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the
defendants, enter a with V - '
, which was parked in
the parking lot at the- Premises. BRENER got into the
driver's seat and SUWAL got into the front passenger seat, and
they drove away. I have reviewed New York State Department of
Motor Vehicle records for the . These records
reflect that the
- andmi to QAT Consulting
Group, 1 n c . a -
104. Other FBI agents and I followed the 0
into the parking lot of a strip mall located in Fort Lee,
New Jersey. At approximately 12:57 p.m., CECIL SUWAL, a/k/a
"Katie," a/k/a "Kate," the defendant, using the 3390 Number, sent
a text message to TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," the
defendant, stating : "We are here. " Approximately one minute
later, LEWIS sent a text message to SUWAL, stating: "B there 2
min."
105. At approximately 1:00 p.m., another FBI agent
observed a woman, whom I believe to be TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," the defendant,') approach and then enter the
and t h ethe lef t the mall parking
lot and parked on a street corner ne a-ar branch
location. At approxims-tely 1 : 23 p.m. , after parking the 0 in front of a --branch, an FBI agent
observed SUWAL get out of the Honda Odyssey and enter thet-
branch location. At approximately 1: 35 p.m., an FBI
agent observed SUWAL speak with a bank teller inside the branch
and conduct a transaction. At approximately 1:55 p.m., theleft
the area. At approximately 2:15 p.m., FBI agents
parked back in the parking lot for the
106. I have reviewed bank records for the First QAT
Account, which reflect that on January 17, 2008, at approximately
1:33 p.m., CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the
defendant, cashed a $1,400 check .drawn on the First QAT Account
at ad-bbranch. The time of this banking
transaction coincides with the timing of when an FBI agent
observed SUWAL inside of thee-branch in Fort Lee
on January 17, 2008. Moreover, SUWAL wrote a $790 check on the
First QAT Account to TEMEKA RACHELLE LEWIS, a/k/a -"~achelle,"th e
defendant, that same day - January 17, 2008 - and LEWIS
negotiated that check on January 17, 2008, at anlocation
in Brooklyn, New York. Based on the foregoing, I
believe that the meeting between SUWAL, BRENER, and LEWIS in the
&-bin Fort Lee on January 17, 2008, was to discuss
activities related to their illegal prostitution businesses, and
to engage in financial transactions with proceeds from that
prostitution business.
3. The Computer At b
l3 I believe the woman I saw was LEWIS based on, among
other things, her similarity to a driver's license photograph for
LEWIS issued out of the State of Virginia.
107. As set forth above and below, the Emperors Club
utilizes the e-mail address "emperorsclubvipny@yahoo.com."
(previously defined as the "Emperors Club E-Mail Account") . For
example, on January 24, 2008, at approximately 1:46 p.m., TEMEKA
RACHELLE LEWIS, a/k/a ..'Rachelle," the defendant, using the 6587
Number, left a voice mail message for a woman using the name
"Sophia," whom I believe to have been a London-based prostitute
working with the Emperors Club. In the message, LEWIS asked
'Sophia" to "send and e-mail as soon as possible to
emperorsclubvipny@yahoo.com," and, after repeating this e-mail
address, LEWIS explained that 'it may just be easier if we speak
over the phone. But if you can't call . . . please try,to send
an e-mail, to let me know your availability for tonight."
108. On or about January 25, 2008, I obtained login
records for the Emperors Club E-Mail Account. These records
reflect that, between December 10, 2007, and January 24, 2008,
the Emperors Club E-Mail Account was accessed more than 100 times
from a computer with the Internet protocol ('IP") Address14
( hAccording to records obtained from Time Warner
Cable, this IP adres(-b was used more than a dozen
times - including numerous of the dates and times when this IP
address accessed the Emperors Club E-Mail - during January of
2008 by an account subscribed to b y 4 ! ! b at
(the address for the
109. Moreover, pursuant to a court-authorized search
warrant for the Emperors Club E-Mail Account, I have reviewed
numerous e-mails for that account which were sent from a
computer with IP address-nd which relate to the
illegal prostitution business run by CECIL SUWAL, a/k/a "Katie,"
a/k/a "Kate," and MARK BRENER, a/k/a 'Michael," the defendants.
Accordingly, I believe that SUWAL and BRENER have used and are
l4 An internet protocol, or IP, address is a unique
numerical address assigned to a particular computer that is
connected to the Internet during a given session. An IP Address
is a series,of four numbers each in the range 0-255, separated
by periods e . . , . Every computer attached to the
Internet must be assigned an IP address so that Internet traffic
sent from and directed to that computer may be directed properly
from its source to its destination. An IP address acts much like
a home or business street address: it enables computers
connected to the Internet to properly route traffic to each
other.
using a computer located inside t h e ' - ?to
conduct the criminal activities of the Emperors Club.
4. Intercepred Communications ~nda-
110. Interceptions of wire and electronic
communications over the 3390 Number used by CECIL SUWAL, a/k/a
"Katie," a/k/a "Kate," the defendant, provide further evidence
that SUWAL conducts her illegal activities bo-u1t of
-and maintains records related to those illegal
activities at -- - - . . For example:
a. On February 11, 2008, at approximately 1:57
p.m., CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant,
called a prostitute known as "Chrissy" and told her that her
appointment with a customer in San Francisco had been confirmed.
During this call, "Chrissy" told SUWAL that she had emailed SUWAL
some pictures last night, and SUWAL confirmed that she had
received those pictures but that SUWAL preferred the cbrrent
pictures of 'Chrissy" on the Website. SUWAL also noted that they
had changed her rate to $2100 per hour. (Call 3620C). Given
that law enforcement agents began conducting surveillance at-
--- - -- - - that day, and that these agents saw SUWAL
-RENER, a/k/a "Michael, the defendant, leave the
-
parking garage at that location at 3:40 p.m., I believe that
during this telephon e' c-al(lt SaUWAL was
I further believe that SUWAL received the'e-mail referenced
during this call at a computer located a t j r - b. On February 13, 2008, at approximately 10:54
a.m., CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant,
sent a text message to a prostitute, possibly known as "Alyssa,"
and asked her to "Pls fax cc slip from last night." (3936C). At
approximately 11:59 a.m., SUWAL sent another text message to the
same prostitute stating: "[Jlust received fax. Perfect thanks."
(3945C). Based on my knowledge of this investigation, I believe
that during this text message exchange, SWAL wanted "Alyssa" to
fax her a client's credit card slip from a recent appointment.
Moreover, given that FBI agents began conducting surveillance at
on that day at approximately 1:55 p.m.,
and saw SUWAL leave the-with BRENER at approximately
2:00 p.m., I believe that SUWAL received that fi_-a=tax
- ..- - -prior to surveillance that day.
B. sesimerpT.-fhe
111. I submlt there is probable cause to believe that
there is presently located at at b
-- - -- I w h i c e d i n ! n s t o n e
apartment building, on the
the only apartment that oc Ievid)ence, fruits, and in,strumkntalities o f violations
of the federal prostitution and money-laundering offenses alleged
herein. More specifically, as set forth below, based on (1) bank
account records, (2) surveillance of the
and (3) intercepted wire communications, t that there is
~robable cause to believe that TEMEKA RACHELLE LEWIS. a/k/a
:~achelle, " the defen dLan-tf,e hltives at
that LEWIS conducts illegal activities relating to the Emperors
Club out of the , and that records
(electronic and A i d e n c eper taining to those
i llegbal a-ctivIities are at the
112. Another law enforcement official has reviewed
records from-which reflect that TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle, " the defendant, maintains an account withand
that, as of February 2008, LEWIS'S bank mailing address
was changed to the a .As a result, LEWIS
current1 receives her- stateme nbts- aft the
Moreover, records from the First QAT Account show
that, since January 1, 2008, LEWIS has received at least three
checks drawn on that account. and that those checks were
negotiated at a nibcation i .n'1-
2. Surveillanceo f- fLtE~WIS -
Premises
113. On January 31, 2008, at approximately 8:30 a.m.,
another law enforcement officer observed TEMEKA RACHELLE LEWIS,
a/k/a 'Rachelle, " the defendant, exit the building at I-
The officer identified LEWIS based
on her driver's license photograph issued out of the 0
I-This was .the same p hotograph used to identify LEWIS
when she met with CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," and
MARK BRENER, a/k/a "Michael," the defendants, on January 17,
2008, in Fort Lee, New Jersey.
114. On February 28, 2008, at approximately 2:50 p.m.,
another law enforcement officer went to conduct surveillance at
At approximately 2 : 5 5
p.m., the officer spoke with TAMEKA RACHELLE LEWIS, a/k/a
"Rachelle," the defendant. She confirmed that she lived in the
building, pointed at the window of the f
and indicated that she lived there. At approximately 3 : 0 0 p.m.,
the officer saw LEWIS , B-eaenhtter and
noticed that this was the only apartment on that floor There
was no markin g 1on1 t1he- d1oor to the other
than an ADT security sticker.
115. On February 28, 2008, at approximately 3:12 p.m.,
TEMEKA RACHELLE LEWIS, a/k/a uRachelle," the defendant, used the
6587 Number to call CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the
defendant. During the call, SUWAL told LEWIS that the "phones
are transferred to you." SUWAL also provided LEWIS with
prostitution booking updates, including the date and time of at
least two prostitution appointments with different customers.
(Call 13581R). Based on the timing of this call, and the timing
of the officer's observation of LEWIS ent
I believe that LEWIS was at the
when she took this call to receive specific information about
prostitution booking appointments.
3 . Intercepted Wire Communications And The - Premises
:$qr?, -* 3)
116. Based upon intercepted wire communications over
the 6587 Number, I believe TEMEKA RACHELLE LEWIS, a/k/a
"Rachelle , " the defendant, worked from her home when she handled
prostitution bookings for the Emperors Club. I therefore believe
that records and evidence concernin-g these illegal activities are
at the a ! .For exam ple, on February 5, 2008,
at approximately 10 :21 p.m., LEWIS, using the 6587 d umber, spoke
with MARK BRENER, a/k/a "Michael," the defendant, about their
concerns as to whether the telephone number on the Website was
working. LEWIS told BRENER that she did not get any calls
yesterday, and, if she had any calls early in the day, those
calls related to "prebookings." LEWIS noted that one client had
called and was able to '..get through," but LEWIS did not know what
number he called. BRENER said that the telephone company was
attempting to fix the problem, and that his purpose in calling 1
LEWIS was to say that only the '917" number was working and not
to wait to call regarding prebookings. BRENER asked LEWIS during
this call if she had an Internet computer at home or if she went
to an Internet cafe. LEWIS responded that she had a computer at
home, but that she sometimes had to go to a cafe because of
difficulties in accessing attachments. (Call 6873R). Given
LEWIS'S comment about havinq a computer at her home, I believe
that LEWIS work
in conducting t he illegal business of th<~mperors Club.
117. Furthermore, in communications intercepted over
the 6587 Number and the 3390 Number, TEMEKA RACHELLE LEWIS, a/k/a
"Rachelle," the defendant, has indicated that some of the records
she maintains regarding the Emperors Club!s activities include
notes on the prostitutes1 physical appearances, credit card
information from prostitution clients, hourly rates for the
prostitutes, booking sheets relating to prostitution
appointments, and contact information for clients.
118. For example, on February 7, 2008, at
approximately 6:30 p.m., TEMEKA RACHELLE LEWIS, a/k/a "Rachelle,"
the defendant, spoke with CECIL SUWAL, a/k/a 'Katie," a/k/a
"Kate," the defendant, about how much money a prostitute the
Emperors 'Club marketed using the name "Alyssa" had collected from
a client. SUWAL indicated that she was unsure if LEWIS would
still have the "bookers sheet" for that appointment, and LEWIS
responded that she had "the piece of paper I wrote it on," and
that the amount "was 1200 cash and 2070 credit card." (Call
3175C). Given SUWAL1s comment about a "bookers sheet" and
LEWIS'S comment about still having the document on which she
wrote the amount, I believe that LEWIS maintains prostitution
booking records at the Clinton Road Premises.
C. The & Premises
119. I submit there is probable cause to believe that
there is presently located at the home a t l f l
(the b) , evidence,
fruits, -and instr-urnentaliti& of violations of the federal
prostitution and money-laundering offenses alleged herein. More
specifically, based on (1) bank records and (2) wire
communications, I believe that TANYA HOLLANDER, a/k/a "Tania
Hollander," the defendant ,b -lIiehvtes at
that HOLLANDER conducts activities related to the Emperor's Club
illegal prostitution business out of the f ,
and that records (electronic and otherwise) and other evidence
pertaining to that illegal prostitution business are at the
-
1. Bank Records And he- - . Premises
120. Law enforcement agents have reviewed bank records
for an account TANYA HOLLANDER, a/k/a I1Tania Hollander," the
defendant, maintains at t h e m &
a m .Those records, which cover* the period from
2007 and to February 2008, reflect that HOLLANDER receives her
banking mail at the l . Moreover, in
connection with this bank account, HOLLANDER submitted a copy of
her New York State Driver's License, which contained a photograph
that I used to identify HOLLANDER on January 28, 2008.
121. Law enforcement agents have reviewed records
showing that TANYA HOLLANDER, a/k/a "Tania Hollander, the
defendant, received numerous checks drawn on the First QAT
Account during 2007, and at least three of those checks were
deposited into the ~ 0 ~ L A N ~ ~ ~ ' s ~ a cbectwoeeun Oncto ber and
December of 2007. Furthermore, HOLLANDER received at least two
checks in 2008 drawn on the First QAT Account that were
negotiated at a b a n klo cation inm-b
- -
2. Wire Communications And The Premises
122. Based on intercepted wire communications, as well
as cell site information obtained from the 1627 Number used by
TANYA HOLLANDER, a/k/a I1Tania Hollander," the defendant, to
conduct the illegal activities of the Emperors Club, I believe
that HOLLANDER conducts those illegal activities out of the
that she maintains records relating to
such activities at t h e f For e xample:
a. On February 7, 2008, at approximately 8:55
p.m., CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant,
sent a text message to TANYA HOLLANDER, a/k/a "Tania Hollander,"
the defendant, at the 1627 Number, stating: "Hi tania. If
possible, pls do not send pamela on a travel date w/ a new
client. Pls refer to the sheet in the bookers manual that
addresses Itravel date models." (Call 3236C). Given this
reference to a "sheet" in a "bookers manual," I believe that
HOLLANDER maintains a record with procedures for booking
prostitutes at the q f b .
b. On February 10, 2008, at approximately 6:26
p.m., CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendant,
called TANYA HOLLANDER, a/k/a I1Tania Hollander," the defendant,
at the 1627 Number. During the call, SUWAL provided HOLLANDER
with numerous prostitution booking updates. SUWAL also gave
HOLLANDER specific information about at least six separate
prostitution bookings in various cities - New York, Washington,
D.C., Los Angeles, and Miami, - with different clients, on
different dates, and with different prostitutes. (Call 3537R).
Given the specificity and quantity of the information HOLLANDER
received during this call - which included client names, city
information, various times and dates for prostitution
appointments, hotel information, telephone numbers, prostitute
availability for the appointments, and prostitute rate
information - I believe that HOLLANDER must have recorded this
information onto paper or electronic media in order to handle
calls concerning this prostitution meetings over the next several
days. Furthermore, during this call, SUWAL and HOLLANDER
discussed how to market a specific prostitute known as "Dorine,"
and HOLLANDER told SUWAL: "I have the write up on Dorine."
Based on this call, I believe that HOLLANDER maintains records
about 'Dorine" and other Emperors Club prostitutes at the - VI. APPLICATION FOR SEIZURE WARRANTS
A. The OAT Accounts
123. As discussed above, MARK BRENER, a/k/a "Michael,"
and CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendants,
have used the QAT Accounts to received more than $1 million in
proceeds from the Emperors Club illegal prostitution business.
BRENER and SUWAL also have used the QAT Accounts to make payments
of illicit proceeds to themselves, to TEMEKA RACHELLE LEWIS,
a/k/a "Rachelle," and TANYA HOLLANDER, a/k/a "Tania Hollander,"
the defendants, and to Emperors Club prostitutes. As a result, I
submit that there is probable cause to believe that the QAT
Accounts contain the proceeds of illegal activity and have been
used and are being used by BRENER and SUWAL to conduct their
money-laundering crimes.
B. The LEWIS Account and The HOLLANDER Account
124. As discussed above, based on my discussions with
IRS-CID agents, I have determined that between in or about
November 2005 and January 2008, CECIL SUWAL, a/k/a "Katie," a/k/a
"Kate," the defendant, wrote approximately $53,473.00 worth of
checks from the First QAT Account to TEMEKA RACHELLE LEWIS, a/k/a
"Rachelle," the defendant, a portion of which were ultimately
deposited into account number in the name of
Temeka R. Lewis (the "LEWIS Account") . oreover, during past
twelve months most of the money deposited into the LEWIS Account,
besides cash, appears to have come from the First QAT Account.
Based on my reviewed of intercepted wire communications, I have
determined that individuals working with the Emperors Club often
receive payments in cash. Also, during that same period there is
.. no indication that the LEWIS Account received money from any
employment activity other than LEWIS'S work for Emperors Club.
From in or about July 2007 through July 2008, SUWAL wrote
approximately $4,870.00 in checks from the First QAT Atcount to
TANYA HOLLANDER, a/k/a "Tania Hollander, the defendant,
0$4,700.00 o,fi nw htihce h nwaemree ofd eTpoasniitae Rd .i Hnotlol aancdecr o(tuhe n"HtOLnL uAmNbDeErR
Accountt1.)
125. I submit that there is probable cause to believe
that the -has been used by MARK BRENER, a/k/a
"Michael," and CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the
defendants, to conduct their federal prostitution and moneylaundering
crimes. As set forth above, on January 17, 2008, law
enforcement agents observed SUWAL and BRENER use the
to both conduct banking activity and meet w i t h m
LEWIS, a/k/a "Rachelle, " the defendant, in connection
with the illegal prostitution business.
126. In addition to this meeting, on January 28, 2008,
law enforcement agents surveiled MARK BRENER, a/k/a "Michael,"
and CECIL SUWAL, a/k/a "Katie," a/k/a "Kate," the defendants, use
the to meet with TANYA HOLLANDER, a/k/a "Tania
Hol efendant, in connection with the illegal
prostitution activities. Specifically, on January 28, 2008, after
series of intercepted communications relating in part to the
amount of money HOLLANDER was to receive from BRENER and SUWAL,
the three defendants met in person in the vicinity of Grand
Central Terminal in New York, New York. I personally observed
individuals who matched the descri~tion of BRENER and SWAL A.
i n-si-dfe the during
this surveillance.
Statutory Authoritv For Seizure Warrants
127. The statutory provisions pursuant to which the
QAT Bank Accounts, the LEWIS Account, the HOLLANDER Account, and
the - are subject to seizure and forfeiture are as
follows :
a. Title 18, United States Code, Section
981 (a) (1) (A) subjects to forfeiture I' [a] ny property, real or
personal, involved in a transaction cr attempted transaction in
violation of . . . section 1956 . . . of this title [relating to
money laundering], or any property traceable to such property."
b. Title 18, United States Code, Section
981 (a) (1) (C) subjects to forfeiture: "Any property, real or
personal, which constitutes or is derived from proceeds traceable
to . . . any offense constituting 'specific unlawful activity'
(as defined in section 1956(c) (7) of this title), or a conspiracy
to commit such offense."
c. Title 18, United States Code, Section 1956
provides, in pertinent part, that
(a)(l) Whoever, knowing that the property
involved in a financial transaction
represents the proceeds of some form of
unlawful activity, conducts or attempts to '
conduct such a financial transaction which in
fact involves the proceeds of specified
unlawful activity--
(A)(i) with the intent to promote the
carrying on of specified unlawful activity;
or
(B) knowing that the transaction is
designed in whole or in part--
(i) to conceal or disguise the nature, the
location, the source, the ownership, or the
control of the proceeds of specified unlawful
activity;
shall be guilty of a crime.
d. "Specified unlawful activitynt is defined in
18 U.S.C. § 1956(c)(7), and includes any offense listed under 18
U.S.C. 5 1961(1). Section 1961(1), in turn, lists as offenses 18
U.S.C. §§ 1952, 2421, and 2422.
e. Title 18 U.S.C. § 984 provides ina
forfeiture action in which the property is funds deposited in an
account in a financial institution, that
(A) it s h a l l not be necessary for the Government
to identify the specific property involved in the
offense that is the basis for t h e f o r f e i t u r e ; and
(B) it shall not be a defense that the property
involved in such an offense has been removed and
replaced by identical property.
f . In addition, "any identical property found i n
the same place or account as the property involved in the offense
that is the basis for the forfeiture shall be subject to
forfeiture" except that [n] o action . . . to f o r f e i t property
not traceable directly to the offense that is the basis for the
forfeiture may be commenced more than 1 year from the date of the
offense .
g. Title 18, United States Code, Section
981 (b) (2) provides that the Secretary of Treasury may seize
property subject t o forfeiture under 18 U.S.C. § 981(a) (1) when
the Secretary "has obtained a warrant for such seizure pursuant
to the Federal Rules of Criminal Procedure."
128. 'Based on the foregoing, there is probable cause
to believe that the QAT Accounts, the LEWIS Account, the
HOLLANDER Account, and thed-constitute property tha,t
was involved in transactions in violation of 18 U.S.C. § 1956, or
property traceable to such property, in that the defendant funds
represent the proceeds of the use of f a c i l i t i e s in i n t e r s t a t e
commerce with the intent to promote unlawful prostitution
activity, the i n t e r s t a t e tr.ansportation of individuals for
purposes of prostitution, and the persuasion of individuals to
travel in i n t e r s t a t e commerce to engage in prostitution, in
violation of 18 U.S.C. §§ 1952, 2421, and 2422, which were
attempted to be transferred and were transferred with the intent
to promote the carrying on of the i l l e g a l prostitution business
and in order to conceal the nature, location, source and
ownership of the proceeds of such business. In addition, there
is probable cause t o believe that the QAT Accounts, the SUWAL
Account, the LEWIS Account, and the HOLLANDER Account are subject
to forfeiture to the United States of America pursuant to 18
U.S.C. 5 981 (a) (1) (C) as these accounts contain proceeds
constituting and derived from violations of 18 U.S.C. §§ 1952,
2421, and 2422, and proceeds traceable to such violations.
V I I . CONCLUSION
129. Based on the foregoing, I respectfully request
that the arrest warrants and seizure warrants specified above be
issued, and that a search w a!r-rdaenhtt for
be issued, and that the individuals arrested be imprisoned or
bailed as the case may be.
KENNETH HOSEY
Special Agent
Federal Bureau of Investigation
Sworn to before me this
SOUTHERN DISTRICT OF NEW YORK
RONALD L. ELL6
United States hn~nistrateJ udge
Southern District of New York
Transcript of Gov. Eliot Spitzer's remarks after being linked to prostitution ring
Monday, March 10th 2008, 3:14 PM
"Good afternoon.
"For the past nine years, eight years as attorney general, and one as governor, I have tried to uphold a vision of progressive politics that would rebuild New York and create opportunity for all. We sought to bring real change to New York and that will continue.
"Today I want to briefly address a private matter. I have acted in a way that violates my obligations to my family and violates my, or any, sense of right and wrong. I apologize first and most importantly to my family. I apologize to the public, whom I promised better.
"I do not believe that politics in the long run is about individuals. It is about ideas, the public good, and doing what is best for the state of New York. But I have disappointed and failed to live up to the standard I expected of myself. I must now dedicate some time to regain the trust of my family.
"I will not be taking questions. Thank you very much. I will report back to you in short order. Thank you very much."
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