2013-06-19 DOJ SDNY information 15,500 chars

United States v. SVETLANA MAZER, Southern District of New York (June 19, 2013) — Information

raw: Civil Penalty Action Against XYZ Corporation for Securities Law Violations

Civil Penalty Action Against XYZ Corporation for Securities Law Violations (S.D.N.Y. June 19, 2013)

Caption
United States v. SVETLANA MAZER
Exhibit of Three Defendants Plead Guilty In Manhattan Federal Court To Charges Related To Their Roles In The CityTime Fraud Scheme
Source PDF JSON
summary

Svetlana Mazer attempted to obstruct a federal grand jury by failing to disclose her interest in shell companies linked to the CityTime project, resulting in a forfeiture of over $10 million in assets.

paragraph

Svetlana Mazer is charged with attempting to obstruct a federal grand jury proceeding by failing to disclose her interest in shell companies tied to the CityTime project. The government seeks forfeiture of approximately $10.255 million in assets held in accounts at JPMorgan Chase, Bank of America, Capital One, and other institutions. The case involves multiple shell companies and trusts, with specific accounts totaling over $10 million in value.

narrative

Svetlana Mazer is charged with attempting to obstruct a federal grand jury proceeding by failing to disclose her interest in shell companies linked to the CityTime project. The indictment, filed as S4 11 Cr. 121 (GBD), alleges that she submitted false responses to a VINDEX questionnaire, which was part of a proceeding before a Federal grand jury in the Southern District of New York. The government is seeking forfeiture of over $10 million in assets held in accounts at JPMorgan Chase, Bank of America, Capital One, and other financial institutions. These assets include approximately $680,266 in MAS Solutions Inc. accounts, $792,422 in Front Line Consulting Corp. accounts, and $746,417 in SJM Services Inc. accounts, among others. The forfeiture includes over 30 accounts held under various names, including those of her companies, trusts, and associates such as Mark Mazer and Larisa Medzon. The case was brought by United States Attorney Preet Bharara and involves a superseding information updating the original indictment. The charges are based on 18 U.S.C. § 1512, which prohibits obstructing justice, and the forfeiture is under 18 U.S.C. § 981 and 28 U.S.C. § 2461.

Enriched metadata

Scheme
unclassified (95%)
Court
Southern District of New York
Victim loss
$1,551,936
Classified unclassified(confidence 95%). No EDGAR filing fingerprint (criminal/DOJ-side scheme). detection rule →
Statutes
18 U.S.C. § 981(a)28 U.S.C. § 246118 U.S.C. § 98121 U.S.C. § 853(p)18 U.S.C. § 1512Title 18, United States Code, Section 1512(c)Title 21, United States Code, Section 853
Parties
United States of AmericaSvetlana Mazer
Keywords
mazer svetlanasvetlana informationmazersvetlanainformation

Extracted insights

Dollar amounts 50
  • $1.55M $1,551,936 $1M–$10M
  • $1.06M $1,058,593 $1M–$10M
  • $950K $949,826 $100K–$1M
  • $910K $910,227 $100K–$1M
  • $831K $831,053 $100K–$1M
  • $807K $807,389 $100K–$1M
  • $792K $792,422 $100K–$1M
  • $746K $746,417 $100K–$1M
  • $685K $685,251 $100K–$1M
  • $680K $680,266 $100K–$1M
  • $664K $663,875 $100K–$1M
  • $540K $540,483 $100K–$1M
Entities 1
  • person SVETLANA MAZER
PDF
Civil Penalty Action Against XYZ Corporation for Securities Law Violations · Source
Text layers
Extracted body text (15,500c) 
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA : SUPERSEDING INFORMATION

SVETLANA MAZER, : S4 11 Cr. 121 (GBD)

Defendant. : x

COUNT ONE

The United States Attorney charges:

1. In or about June 2010, in the Southern District of New York and elsewhere, SVETLANA MAZER, the defendant, did knowingly, intentionally and corruptly attempt to obstruct, influence and impede an official proceeding, to wit, a proceeding before a Federal grand jury in the Southern District of New York, by submitting Vendor Information Exchange System ("VINDEX") questionnaire responses to the City of New York that deliberately failed to disclose her interest in shell companies that received millions of dollars derived from the "CityTime" project.

(Title 18, United States Code, Section 1512(c)(2)).

FORFEITURE ALLEGATION

2. As a result of committing the offense alleged in Count One of this Information, SVETLANA MAZER, the defendant, shall forfeit to the United States, pursuant to 18 U.S.C. § 981(a)(1)(c) and 28 U.S.C. § 2461, all right, title and interest

--- page 2 ---

of herself and any entities she controls to the following funds, accounts and properties:

a. Approximately $680,266 in United States currency formerly on deposit in account number 8310823106, held in the name of MAS Solutions Inc., at Astoria Federal Savings Bank;

b. Approximately $792,422 in United States currency formerly on deposit in account number 8310823093, held in the name of Front Line Consulting Corp., at Astoria Federal Savings Bank;

c. Approximately $746,417 in United States currency formerly on deposit in account number 483023745998, held in the name of SJM Services Inc., at Bank of America;

d. Approximately $540,483.18 in United States currency formerly on deposit in account number 483006909751, held in the name of MS Advantage Group LLC, at Bank of America;

e. Approximately $348,730 in United States currency formerly on deposit in account number 7047355456, held in the name of MS Advantage Group LLC, at Capital One;

f. Approximately $140,918.95 in United States currency formerly on deposit in account number 5800168351, held in the name of MS Advantage Group LLC, at Capital One;

g. Approximately $1,058,593.70 in United States currency formerly on deposit in account number 3084010713, held in the name of MAS Solutions Inc, at Capital One;

h. Approximately $201,413.83 in United States currency formerly on deposit in account number 445001417365, held in the name of Svetlana Mazer as Custodian for Alexander Mazer under the N.Y.U.T.M.A., at JPMorgan Chase Bank;

i. Approximately $65,419.67 in United States currency formerly on deposit in account number

-2-

--- page 3 ---

10611000801, held in the name of Mark Mazer ITF Svetlana Mazer, at JPMorgan Chase Bank;

j. Approximately $210,265.79 in United States currency formerly on deposit in account number 2730264393, held in the name of Mark Mazer as Custodian for Michael Mazer under the N.Y.U.T.M.A., at JPMorgan Chase Bank;

k. Approximately $2,898 in United States currency formerly on deposit in account number 753521327, held in the name of Svetlana Mazer Trust 2005 Leonid Gorelik TTE or Mark Mazer TTE, at JPMorgan Chase Bank;

l. Approximately $4,965.25 in United States currency formerly on deposit in account number 893007682, held in the name of Susan Mazer or Mark Mazer, at JPMorgan Chase Bank;

m. Approximately $253,266.29 in United States currency formerly on deposit in account number 2956974956, held in the name of Susan Mazer or Mark Mazer, at JPMorgan Chase Bank;

n. Approximately $21,117.33 in United States currency formerly on deposit in account number 445609492401, held in the name of Svetlana Mazer as Custodian under the N.Y.U.T.M.A. for Alexander Mazer, at JPMorgan Chase Bank;

o. Approximately $66,812.70 in United States currency formerly on deposit in account number 445609491601, held in the name of Svetlana Mazer as Custodian under N.Y.U.T.M.A. for Michael Mazer, at JPMorgan Chase Bank;

p. Approximately $14,903.30 in United States currency formerly on deposit in account number 445609490801, held in the name of Svetlana Mazer as Custodian under the N.Y.U.T.M.A. for Susan Mazer, at JPMorgan Chase Bank;

q. Approximately $164,224.63 in United States currency formerly on deposit in account number 445001163401, held in the name of Svetlana Mazer, at JPMorgan Chase Bank;

-3---- page 4 ---

r. Approximately $58,768.34 in United States currency formerly on deposit in account number 445001163465, held in the name of Svetlana Mazer, at JPMorgan Chase Bank;

s. Approximately $70,000 in United States currency formerly on deposit in account number 937009958065, held in the name of Anna Makovetskaya and Yuiry Makovetskiy, at JPMorgan Chase Bank;

t. Approximately $949,826.79 in United States currency formerly on deposit in account number 151128566965, held in the name of SJM Services, Inc., at JPMorgan Chase Bank;

u. Approximately $227,096.39 in United States currency formerly on deposit in account number 445501101265, held in the name of MS Properties LLC, at JPMorgan Chase Bank;

v. Approximately $910,227.39 in United States currency formerly on deposit in account number 3152815195, held in the name of MAS Solutions, Inc., at JPMorgan Chase Bank;

w. Approximately $1,551,936.38 in United States currency formerly on deposit in account number 445501011665, held in the name of MAS Solutions, Inc., at JPMorgan Chase Bank;

x. Approximately $259,957.82 in United States currency formerly on deposit in account number 006606695, held in the name of Larisa Medzon or Ilya Medzon, at JPMorgan Chase Bank;

y. Approximately $6,389.60 in United States currency formerly on deposit in account number 006619428, held in the name of Larisa Medzon or Ilya Medzon, at JPMorgan Chase Bank;

z. Approximately $304,003.44 in United States currency formerly on deposit in account number 441005778265, held in the name of Ilya Medzon, at JPMorgan Chase Bank;

aa. Approximately $4,491.68 in United States currency formerly on deposit in account number

--- page 5 ---

441011340665, held in the name of Ilya Medzon, at JPMorgan Chase Bank;

bb. Approximately $831,053.06 in United States currency formerly on deposit in account number 756832192, held in the name of Front Line Consulting Corp., at JPMorgan Chase Bank;

cc. Approximately $192,175.62 in United States currency formerly on deposit in account number 4826941498, held in the name of Svetlana Mazer Custodian Michael Mazer Donee, at JPMorgan Chase Bank;

dd. Approximately $18,502.19 in United States currency formerly on deposit in account number 4826941480, held in the name of Svetlana Mazer Custodian Susan J. Mazer Donee, at JPMorgan Chase Bank;

ee. Approximately $3,570 in United States currency formerly on deposit in account number 753521376, held in the name of Mark Mazer Trust 2005 Leonid Gorelik TTE or Svetlana Mazer TTE, at JPMorgan Chase Bank;

ff. Approximately $2,529.94 in United States currency formerly on deposit in account number 006606679, held in the name of Larisa Mazer or Mark Mazer, at JPMorgan Chase Bank;

gg. Approximately $6,154.69 in United States currency formerly on deposit in account number 006619371, held in the name of Larisa Mazer or Mark Mazer, at JPMorgan Chase Bank;

hh. Approximately $5,797.25 in United States currency formerly on deposit in account number 10609923265, held in the name of Mark Mazer, at JPMorgan Chase Bank;

ii. Approximately $1,457.97 in United States currency formerly on deposit in account number 112258301, held in the name of Svetlana Mazer or Mark Mazer, at JPMorgan Chase Bank;

jj. Approximately $223,552.85 in United States currency formerly on deposit in account number

--- page 6 ---

112345328, held in the name of Svetlana Mazer or Mark Mazer, at JPMorgan Chase Bank;

kk. Approximately $228,000 in United States currency formerly on deposit in account number 9340226293, held in the name of Larisa Medzon, at JPMorgan Chase Bank;

11. Approximately $663,875.51 in United States currency formerly on deposit in account number 3152815294, held in the name of Front Line Consulting Corp., at JPMorgan Chase Bank;

mm. Any and all funds on deposit in account number 3110071086, held in the name of MS Development Services Corp., at JPMorgan Chase Bank;

nn. Approximately $297,312.21 in United States currency formerly on deposit in account number 58385994, held in the name of SJM Services, Inc., at Citibank;

oo. Approximately $494,141.42 in United States currency formerly on deposit in account number 9932333666, held in the name of SJM Services, Inc., at Citibank;

pp. Approximately $301,053.45 in United States currency formerly on deposit in account number 9941951976, held in the name of MS Development Services Corp., at Citibank;

qq. Approximately $250,523.93 in United States currency formerly on deposit in account number 27362730, held in the name of Svetlana Mazer ACF Alexander Mazer under the N.Y.U.T.M.A., at Citibank;

rr. Any and all funds on deposit in account number 16289822, held in the name of Larisa Medzon, at Citibank;

ss. Any and all funds on deposit in account number 0071215088873, held in the name of Mark Mazer as Custodian for Michael Mazer, at Dreyfus;

tt. Approximately $91,729.16 in United States currency formerly on deposit in account number486040479, held in the name of Fidelity Management Trust Co. - Trustee - Front Line Consulting Corp. - Fidelity Self-Employed 401 (k) for the Benefit of Larisa Medzon - Plan Administrator, at Fidelity Investments;

uu. Approximately $127,245.29 in United States currency formerly on deposit in account number 486247367, held in the name of Fidelity Management Trust Co. - Trustee - SJM Services Inc. - Fidelity Self-Employed 401 (k) for the Benefit of Larisa Medzon - Plan Administrator, at Fidelity Investments;

vv. Approximately $807,389.90 in United States currency formerly on deposit in account number Z71-925713, held in the name of Larisa Medzon and Ilya Medzon with Rights of Survivorship, at Fidelity Investments;

ww. Any and all funds on deposit in account number 481930253, held in the name of Fidelity Management Trust Co. - Trustee - MS Creative Technologies Inc. - Money Purchase Keogh for the Benefit of Mark Mazer - Svetlana Mazer - Plan Administrator, at Fidelity Investments;

xx. Any and all funds on deposit in account number 485806307, held in the name of Fidelity Management Trust Co. - Trustee - MS Creative Technologies Inc. - Fidelity Self-Employed 401 (k) for the Benefit of Mark Mazer - Plan Administrator, at Fidelity Investments;

yy. Any and all funds on deposit in account number Z85251682, held in the name of MS Advantage Group LLC, at Fidelity Investments;

zz. Any and all funds on deposit in account number X02923435, held in the name of Svetlana Mazer, at Fidelity Investments;

aaa. Any and all funds on deposit in account number 485806315, held in the name of Fidelity Management Trust Co. - Trustee - MS Development Services Corp. - Fidelity Self-Employed 401 (k) for the Benefit of Svetlana Mazer - Plan Administrator, at Fidelity Investments;

-7-

--- page 8 ---

bbb. Any and all funds on deposit in account number 486108588, held in the name of Fidelity Management Trust Co. - Trustee - MS Development Services Corp. - Money Purchase Keogh for the Benefit of Svetlana Mazer - Plan Administrator, at Fidelity Investments;

ccc. Approximately $291,000 in United States currency formerly on deposit in account number 1484005461, held in the name of Larisa Medzon, at Flushing Savings Bank;

ddd. Approximately $100,643.81 in United States currency formerly on deposit in account number 136659152, held in the name of Svetlana Mazer and Mark Mazer, at HSBC Bank;

eee. Approximately $4,290.46 in United States currency formerly on deposit in account number 136734863, held in the name of Svetlana Mazer and Mark Mazer, at HSBC Bank;

fff. Approximately $161,192.74 in United States currency formerly on deposit in account number 136721893, held in the name of MS Development Services Corp., at HSBC Bank;

ggg. Approximately $685,251.28 in United States currency formerly on deposit in account number 136721907, held in the name of MS Advantage Group LLC, at HSBC Bank;

hhh. Approximately $822,936.60 in United States currency formerly on deposit in account number 136724728, held in the name of MAS Solutions, Inc., at HSBC Bank;

iii. Approximately $718,095.22 in United States currency formerly on deposit in account number 136724736, held in the name of Front Line Consulting Corp., at HSBC Bank;

jjj. Approximately $198,470.67 in United States currency formerly on deposit in account number 691019819, held in the name of MS Creative Technologies Inc., at HSBC Bank;

-8-

--- page 9 ---

-9-

--- page 10 ---

788657322, held in the name of Anna Makovetskaya, at TD Ameritrade;

vvv. Any and all funds on deposit in account number 787-453364, held in the name of Svetlana Mazer, at TD Ameritrade;

www. Any and all funds on deposit in account number 883-549297, held in the name of Mark Mazer, at TD Ameritrade;

xxx. Approximately $1,513,409.16 in United States currency formerly on deposit in account number 883-564890, held in the name of Mark Mazer and Svetlana Mazer JT TEN, at TD Ameritrade;

yyy. Any and all funds on deposit in account number 883-588599, held in the name of Mark Mazer Roth IRA for MS Creative Tech., at TD Ameritrade;

zzz. Any and all funds on deposit in account number 883-589685, held in the name of Svetlana Mazer Roth IRA for MS Creative Tech., at TD Ameritrade;

aaaa. Any and all funds on deposit in account number 883-594076, held in the name of Svetlana Mazer Rollover Roth IRA for MS Creative Tech., at TD Ameritrade;

bbbb. Any and all funds on deposit in account number 885-971584, held in the name of Svetlana Mazer and Susan Mazer Joint, at TD Ameritrade;

cccc. Any and all funds on deposit in account number 885-971595, held in the name of Svetlana Mazer and Alexander Mazer Joint, at TD Ameritrade;

dddd. Any and all funds on deposit in account number 885-971598, held in the name of Svetlana Mazer and Michael Mazer Joint, at TD Ameritrade;

eeee. $244,254.46 in United States currency on deposit in account number 883-564076, held in the name of Larisa Medzon and Ilya Medzon, at TD Ameritrade;

-10-

--- page 11 ---

-11-

--- page 12 ---

-12-

--- page 13 ---

Substitute Asset Provision

3. If any of the above-described forfeitable property, as a result of any act or omission of the defendant:

(1) cannot be located upon the exercise of due diligence;

(2) has been transferred or sold to, or deposited with, a third person;

(3) has been placed beyond the jurisdiction of the Court;

(4) has been substantially diminished in value; or

(5) has been commingled with other property which cannot be subdivided without difficulty;

it is the intent of the United States, pursuant to 18 U.S.C. § 981, 21 U.S.C. § 853(p), and 28 U.S.C. § 2461, to seek forfeiture of any other property of the defendant up to the value of the above forfeitable property.

(Title 18, United States Code, Section 981; Title 21, United States Code, Section 853; and Title 28, United States Code, Section 2461.)

PREET BHARARA United States AttorneyUNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA v. SVETLANA MAZER, Defendant.
SUPERSEDING INFORMATION
S4 11 Cr. 121 (GBD)
(18 U.S.C. § 1512)
PREET BHARARA
United States Attorney.
OCR text (15,500c · none · 60% conf) 
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA : SUPERSEDING INFORMATION

SVETLANA MAZER, : S4 11 Cr. 121 (GBD)

Defendant. : x

COUNT ONE

The United States Attorney charges:

1. In or about June 2010, in the Southern District of New York and elsewhere, SVETLANA MAZER, the defendant, did knowingly, intentionally and corruptly attempt to obstruct, influence and impede an official proceeding, to wit, a proceeding before a Federal grand jury in the Southern District of New York, by submitting Vendor Information Exchange System ("VINDEX") questionnaire responses to the City of New York that deliberately failed to disclose her interest in shell companies that received millions of dollars derived from the "CityTime" project.

(Title 18, United States Code, Section 1512(c)(2)).

FORFEITURE ALLEGATION

2. As a result of committing the offense alleged in Count One of this Information, SVETLANA MAZER, the defendant, shall forfeit to the United States, pursuant to 18 U.S.C. § 981(a)(1)(c) and 28 U.S.C. § 2461, all right, title and interest

--- page 2 ---

of herself and any entities she controls to the following funds, accounts and properties:

a. Approximately $680,266 in United States currency formerly on deposit in account number 8310823106, held in the name of MAS Solutions Inc., at Astoria Federal Savings Bank;

b. Approximately $792,422 in United States currency formerly on deposit in account number 8310823093, held in the name of Front Line Consulting Corp., at Astoria Federal Savings Bank;

c. Approximately $746,417 in United States currency formerly on deposit in account number 483023745998, held in the name of SJM Services Inc., at Bank of America;

d. Approximately $540,483.18 in United States currency formerly on deposit in account number 483006909751, held in the name of MS Advantage Group LLC, at Bank of America;

e. Approximately $348,730 in United States currency formerly on deposit in account number 7047355456, held in the name of MS Advantage Group LLC, at Capital One;

f. Approximately $140,918.95 in United States currency formerly on deposit in account number 5800168351, held in the name of MS Advantage Group LLC, at Capital One;

g. Approximately $1,058,593.70 in United States currency formerly on deposit in account number 3084010713, held in the name of MAS Solutions Inc, at Capital One;

h. Approximately $201,413.83 in United States currency formerly on deposit in account number 445001417365, held in the name of Svetlana Mazer as Custodian for Alexander Mazer under the N.Y.U.T.M.A., at JPMorgan Chase Bank;

i. Approximately $65,419.67 in United States currency formerly on deposit in account number

-2-

--- page 3 ---

10611000801, held in the name of Mark Mazer ITF Svetlana Mazer, at JPMorgan Chase Bank;

j. Approximately $210,265.79 in United States currency formerly on deposit in account number 2730264393, held in the name of Mark Mazer as Custodian for Michael Mazer under the N.Y.U.T.M.A., at JPMorgan Chase Bank;

k. Approximately $2,898 in United States currency formerly on deposit in account number 753521327, held in the name of Svetlana Mazer Trust 2005 Leonid Gorelik TTE or Mark Mazer TTE, at JPMorgan Chase Bank;

l. Approximately $4,965.25 in United States currency formerly on deposit in account number 893007682, held in the name of Susan Mazer or Mark Mazer, at JPMorgan Chase Bank;

m. Approximately $253,266.29 in United States currency formerly on deposit in account number 2956974956, held in the name of Susan Mazer or Mark Mazer, at JPMorgan Chase Bank;

n. Approximately $21,117.33 in United States currency formerly on deposit in account number 445609492401, held in the name of Svetlana Mazer as Custodian under the N.Y.U.T.M.A. for Alexander Mazer, at JPMorgan Chase Bank;

o. Approximately $66,812.70 in United States currency formerly on deposit in account number 445609491601, held in the name of Svetlana Mazer as Custodian under N.Y.U.T.M.A. for Michael Mazer, at JPMorgan Chase Bank;

p. Approximately $14,903.30 in United States currency formerly on deposit in account number 445609490801, held in the name of Svetlana Mazer as Custodian under the N.Y.U.T.M.A. for Susan Mazer, at JPMorgan Chase Bank;

q. Approximately $164,224.63 in United States currency formerly on deposit in account number 445001163401, held in the name of Svetlana Mazer, at JPMorgan Chase Bank;

-3---- page 4 ---

r. Approximately $58,768.34 in United States currency formerly on deposit in account number 445001163465, held in the name of Svetlana Mazer, at JPMorgan Chase Bank;

s. Approximately $70,000 in United States currency formerly on deposit in account number 937009958065, held in the name of Anna Makovetskaya and Yuiry Makovetskiy, at JPMorgan Chase Bank;

t. Approximately $949,826.79 in United States currency formerly on deposit in account number 151128566965, held in the name of SJM Services, Inc., at JPMorgan Chase Bank;

u. Approximately $227,096.39 in United States currency formerly on deposit in account number 445501101265, held in the name of MS Properties LLC, at JPMorgan Chase Bank;

v. Approximately $910,227.39 in United States currency formerly on deposit in account number 3152815195, held in the name of MAS Solutions, Inc., at JPMorgan Chase Bank;

w. Approximately $1,551,936.38 in United States currency formerly on deposit in account number 445501011665, held in the name of MAS Solutions, Inc., at JPMorgan Chase Bank;

x. Approximately $259,957.82 in United States currency formerly on deposit in account number 006606695, held in the name of Larisa Medzon or Ilya Medzon, at JPMorgan Chase Bank;

y. Approximately $6,389.60 in United States currency formerly on deposit in account number 006619428, held in the name of Larisa Medzon or Ilya Medzon, at JPMorgan Chase Bank;

z. Approximately $304,003.44 in United States currency formerly on deposit in account number 441005778265, held in the name of Ilya Medzon, at JPMorgan Chase Bank;

aa. Approximately $4,491.68 in United States currency formerly on deposit in account number

--- page 5 ---

441011340665, held in the name of Ilya Medzon, at JPMorgan Chase Bank;

bb. Approximately $831,053.06 in United States currency formerly on deposit in account number 756832192, held in the name of Front Line Consulting Corp., at JPMorgan Chase Bank;

cc. Approximately $192,175.62 in United States currency formerly on deposit in account number 4826941498, held in the name of Svetlana Mazer Custodian Michael Mazer Donee, at JPMorgan Chase Bank;

dd. Approximately $18,502.19 in United States currency formerly on deposit in account number 4826941480, held in the name of Svetlana Mazer Custodian Susan J. Mazer Donee, at JPMorgan Chase Bank;

ee. Approximately $3,570 in United States currency formerly on deposit in account number 753521376, held in the name of Mark Mazer Trust 2005 Leonid Gorelik TTE or Svetlana Mazer TTE, at JPMorgan Chase Bank;

ff. Approximately $2,529.94 in United States currency formerly on deposit in account number 006606679, held in the name of Larisa Mazer or Mark Mazer, at JPMorgan Chase Bank;

gg. Approximately $6,154.69 in United States currency formerly on deposit in account number 006619371, held in the name of Larisa Mazer or Mark Mazer, at JPMorgan Chase Bank;

hh. Approximately $5,797.25 in United States currency formerly on deposit in account number 10609923265, held in the name of Mark Mazer, at JPMorgan Chase Bank;

ii. Approximately $1,457.97 in United States currency formerly on deposit in account number 112258301, held in the name of Svetlana Mazer or Mark Mazer, at JPMorgan Chase Bank;

jj. Approximately $223,552.85 in United States currency formerly on deposit in account number

--- page 6 ---

112345328, held in the name of Svetlana Mazer or Mark Mazer, at JPMorgan Chase Bank;

kk. Approximately $228,000 in United States currency formerly on deposit in account number 9340226293, held in the name of Larisa Medzon, at JPMorgan Chase Bank;

11. Approximately $663,875.51 in United States currency formerly on deposit in account number 3152815294, held in the name of Front Line Consulting Corp., at JPMorgan Chase Bank;

mm. Any and all funds on deposit in account number 3110071086, held in the name of MS Development Services Corp., at JPMorgan Chase Bank;

nn. Approximately $297,312.21 in United States currency formerly on deposit in account number 58385994, held in the name of SJM Services, Inc., at Citibank;

oo. Approximately $494,141.42 in United States currency formerly on deposit in account number 9932333666, held in the name of SJM Services, Inc., at Citibank;

pp. Approximately $301,053.45 in United States currency formerly on deposit in account number 9941951976, held in the name of MS Development Services Corp., at Citibank;

qq. Approximately $250,523.93 in United States currency formerly on deposit in account number 27362730, held in the name of Svetlana Mazer ACF Alexander Mazer under the N.Y.U.T.M.A., at Citibank;

rr. Any and all funds on deposit in account number 16289822, held in the name of Larisa Medzon, at Citibank;

ss. Any and all funds on deposit in account number 0071215088873, held in the name of Mark Mazer as Custodian for Michael Mazer, at Dreyfus;

tt. Approximately $91,729.16 in United States currency formerly on deposit in account number486040479, held in the name of Fidelity Management Trust Co. - Trustee - Front Line Consulting Corp. - Fidelity Self-Employed 401 (k) for the Benefit of Larisa Medzon - Plan Administrator, at Fidelity Investments;

uu. Approximately $127,245.29 in United States currency formerly on deposit in account number 486247367, held in the name of Fidelity Management Trust Co. - Trustee - SJM Services Inc. - Fidelity Self-Employed 401 (k) for the Benefit of Larisa Medzon - Plan Administrator, at Fidelity Investments;

vv. Approximately $807,389.90 in United States currency formerly on deposit in account number Z71-925713, held in the name of Larisa Medzon and Ilya Medzon with Rights of Survivorship, at Fidelity Investments;

ww. Any and all funds on deposit in account number 481930253, held in the name of Fidelity Management Trust Co. - Trustee - MS Creative Technologies Inc. - Money Purchase Keogh for the Benefit of Mark Mazer - Svetlana Mazer - Plan Administrator, at Fidelity Investments;

xx. Any and all funds on deposit in account number 485806307, held in the name of Fidelity Management Trust Co. - Trustee - MS Creative Technologies Inc. - Fidelity Self-Employed 401 (k) for the Benefit of Mark Mazer - Plan Administrator, at Fidelity Investments;

yy. Any and all funds on deposit in account number Z85251682, held in the name of MS Advantage Group LLC, at Fidelity Investments;

zz. Any and all funds on deposit in account number X02923435, held in the name of Svetlana Mazer, at Fidelity Investments;

aaa. Any and all funds on deposit in account number 485806315, held in the name of Fidelity Management Trust Co. - Trustee - MS Development Services Corp. - Fidelity Self-Employed 401 (k) for the Benefit of Svetlana Mazer - Plan Administrator, at Fidelity Investments;

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bbb. Any and all funds on deposit in account number 486108588, held in the name of Fidelity Management Trust Co. - Trustee - MS Development Services Corp. - Money Purchase Keogh for the Benefit of Svetlana Mazer - Plan Administrator, at Fidelity Investments;

ccc. Approximately $291,000 in United States currency formerly on deposit in account number 1484005461, held in the name of Larisa Medzon, at Flushing Savings Bank;

ddd. Approximately $100,643.81 in United States currency formerly on deposit in account number 136659152, held in the name of Svetlana Mazer and Mark Mazer, at HSBC Bank;

eee. Approximately $4,290.46 in United States currency formerly on deposit in account number 136734863, held in the name of Svetlana Mazer and Mark Mazer, at HSBC Bank;

fff. Approximately $161,192.74 in United States currency formerly on deposit in account number 136721893, held in the name of MS Development Services Corp., at HSBC Bank;

ggg. Approximately $685,251.28 in United States currency formerly on deposit in account number 136721907, held in the name of MS Advantage Group LLC, at HSBC Bank;

hhh. Approximately $822,936.60 in United States currency formerly on deposit in account number 136724728, held in the name of MAS Solutions, Inc., at HSBC Bank;

iii. Approximately $718,095.22 in United States currency formerly on deposit in account number 136724736, held in the name of Front Line Consulting Corp., at HSBC Bank;

jjj. Approximately $198,470.67 in United States currency formerly on deposit in account number 691019819, held in the name of MS Creative Technologies Inc., at HSBC Bank;

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788657322, held in the name of Anna Makovetskaya, at TD Ameritrade;

vvv. Any and all funds on deposit in account number 787-453364, held in the name of Svetlana Mazer, at TD Ameritrade;

www. Any and all funds on deposit in account number 883-549297, held in the name of Mark Mazer, at TD Ameritrade;

xxx. Approximately $1,513,409.16 in United States currency formerly on deposit in account number 883-564890, held in the name of Mark Mazer and Svetlana Mazer JT TEN, at TD Ameritrade;

yyy. Any and all funds on deposit in account number 883-588599, held in the name of Mark Mazer Roth IRA for MS Creative Tech., at TD Ameritrade;

zzz. Any and all funds on deposit in account number 883-589685, held in the name of Svetlana Mazer Roth IRA for MS Creative Tech., at TD Ameritrade;

aaaa. Any and all funds on deposit in account number 883-594076, held in the name of Svetlana Mazer Rollover Roth IRA for MS Creative Tech., at TD Ameritrade;

bbbb. Any and all funds on deposit in account number 885-971584, held in the name of Svetlana Mazer and Susan Mazer Joint, at TD Ameritrade;

cccc. Any and all funds on deposit in account number 885-971595, held in the name of Svetlana Mazer and Alexander Mazer Joint, at TD Ameritrade;

dddd. Any and all funds on deposit in account number 885-971598, held in the name of Svetlana Mazer and Michael Mazer Joint, at TD Ameritrade;

eeee. $244,254.46 in United States currency on deposit in account number 883-564076, held in the name of Larisa Medzon and Ilya Medzon, at TD Ameritrade;

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Substitute Asset Provision

3. If any of the above-described forfeitable property, as a result of any act or omission of the defendant:

(1) cannot be located upon the exercise of due diligence;

(2) has been transferred or sold to, or deposited with, a third person;

(3) has been placed beyond the jurisdiction of the Court;

(4) has been substantially diminished in value; or

(5) has been commingled with other property which cannot be subdivided without difficulty;

it is the intent of the United States, pursuant to 18 U.S.C. § 981, 21 U.S.C. § 853(p), and 28 U.S.C. § 2461, to seek forfeiture of any other property of the defendant up to the value of the above forfeitable property.

(Title 18, United States Code, Section 981; Title 21, United States Code, Section 853; and Title 28, United States Code, Section 2461.)

PREET BHARARA United States AttorneyUNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA v. SVETLANA MAZER, Defendant.
SUPERSEDING INFORMATION
S4 11 Cr. 121 (GBD)
(18 U.S.C. § 1512)
PREET BHARARA
United States Attorney.