United States v. LARISA MEDZON, Southern District of New York (June 19, 2013) — Information
raw: No Actionable Content Provided
No Actionable Content Provided (S.D.N.Y. June 19, 2013)
summary
Larisa Medzon is charged with structuring over $200,000 in withdrawals to evade Bank Secrecy Act reporting requirements, facing forfeiture of approximately $8.5 million in assets.
paragraph
Larisa Medzon is charged with structuring cash withdrawals of $500 or less between June 2006 and December 2010 to evade federal reporting requirements under 31 U.S.C. § 5324. The government alleges she withdrew more than $200,000 derived from the CityTime project in increments designed to avoid triggering Currency Transaction Reports. Consequently, the U.S. seeks forfeiture of approximately $8.5 million in funds held in accounts across multiple banks and entities linked to Medzon and her associates.
narrative
Larisa Medzon is charged in a Superseding Information with violating the Bank Secrecy Act by structuring financial transactions to evade reporting requirements. From June 2006 to December 2010, Medzon withdrew more than $200,000 derived from the CityTime project in increments of $500 or less from multiple domestic financial institutions. This conduct was intended to cause these institutions to fail to file the required Currency Transaction Reports mandated by 31 U.S.C. § 5313(a). The government alleges these actions constitute a violation of 31 U.S.C. § 5324(a)(1) and (a)(3). As a result, the United States seeks the forfeiture of approximately $8.5 million in assets pursuant to 31 U.S.C. § 5317(c)(1). The forfeiture list includes funds held in accounts at Astoria Federal Savings Bank, Bank of America, Capital One, and JPMorgan Chase. These accounts are held in the names of Medzon, her family members, and related entities such as MAS Solutions Inc. and Front Line Consulting Corp. The assets represent the proceeds of the alleged structuring offenses.
Classified unclassified. No EDGAR filing fingerprint (criminal/DOJ-side scheme). detection rule →
Statutes
31 U.S.C. § 5317(c)21 U.S.C. § 853(p)31 U.S.C. § 5324Title 31, United States Code, Section 5313(a)Title 31, United States Code, Sections 5324(a)Title 31, United States Code, Section 5317Title 21, United States Code, Section 853
Parties
United States of AmericaLARISA MEDZON
Keywords
medzon larisalarisa informationmedzonlarisainformation
Extracted insights
Dollar amounts 48
- $1.51M $1,513,409 $1M–$10M
- $1.06M $1,058,593 $1M–$10M
- $831K $831,053 $100K–$1M
- $807K $807,389 $100K–$1M
- $792K $792,422 $100K–$1M
- $746K $746,417 $100K–$1M
- $680K $680,266 $100K–$1M
- $664K $663,875 $100K–$1M
- $540K $540,483 $100K–$1M
- $494K $494,141 $100K–$1M
- $419K $419,498 $100K–$1M
- $398K $397,545 $100K–$1M
Entities 1
- person LARISA MEDZON
Text layers
Extracted body text (13,976c)
--- page 1 --- UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - x UNITED STATES OF AMERICA : SUPERSEDING - v. - : INFORMATION LARISA MEDZON, : S3 11 Cr. 121 (GBD) Defendant. : - - - - - - - - - - - - - - x COUNT ONE The United States Attorney charges: 1. From at least in or about June 2006 up to and including in or about December 2010, in the Southern District of New York and elsewhere, LARISA MEDZON, the defendant, knowingly and for the purpose of evading the reporting requirements of Title 31, United States Code, Section 5313(a) and the regulations promulgated thereunder, caused and attempted to cause a domestic financial institution to fail to file a report required under section 5313(a) of Title 31, and any regulation prescribed thereunder, and structured, and assisted in structuring, transactions with one and more domestic financial institutions, to wit, MEDZON withdrew more than $200,000 derived from the CityTime project from accounts at multiple financial institutions in increments of $500 or less in order to evade the reporting requirements of Title 31, United States Code, Section 5313(a) and the regulations promulgated thereunder. (Title 31, United States Code, Sections 5324(a)(1) and (a)(3)). --- page 2 --- FORFEITURE ALLEGATION 2. As a result of committing the offense alleged in Count One of this Information, LARISA MEDZON, the defendant, shall forfeit to the United States, pursuant to 31 U.S.C. § 5317(c)(1), all right, title and interest 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 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; --- page 3 --- - 3 --- page 4 --- - 4--- page 5 --- y. Approximately $6,389.60 in United States currency formerly on deposit in account number 006619428, held in the name of 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 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 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; -5- --- page 6 --- 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 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; ll. 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 --- page 7 --- 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 number 486040479, 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; -7- --- page 8 --- -8- --- page 9 --- -9---- page 10 --- Minor, Svetlana Mazer, Custodian, U.T.M.A., at Sovereign Bank; sss. Approximately $397,545 in United States currency formerly on deposit in account number 0971122725, held in the name of MS Advantage Group LLC, at Sovereign Bank; ttt. Approximately $10,012.03 in United States currency formerly on deposit in account number 3580520520, held in the name of MS Advantage Group LLC, at Sovereign Bank; uuu. Approximately $419,498.80 in United States currency formerly on deposit in account number 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; -10- --- page 11 --- -11- --- page 12 --- mmmm. Approximately $233,194 in United States currency formerly on deposit in account number 2000038347089, held in the name of MS Advantage Group LLC, at Wells Fargo; nnnnn. Approximately $205,350 in United States currency seized on or about December 16, 2010 from Safe Deposit Box No. 411 at Chase, Munsey Park, 2111 Northern Blvd., Manhasset, New York 11030; ooooo. Approximately $178,900 in United States currency seized on or about December 16, 2010 from Safe Deposit Box No. 1862 at Citibank, 1075 Northern Blvd., Roslyn, New York 11576; ppppp. Approximately $200,000 in United States currency seized on or about December 16, 2010 from Safe Deposit Box No. 2108-958 at Sovereign Bank, 1420 Northern Blvd., Manhasset, New York 11030; qqqqq. Approximately $280,200 in United States currency seized on or about December 16, 2010 from Safe Deposit Box No. 499 at TD Bank, 10836 Queens Blvd., Forest Hills, New York 11375; rrrrr. Approximately $155,100 in United States currency seized on or about January 11, 2011 from Safe Deposit Box No. 741-4 at Citibank, 1110 Northern Blvd., Manhasset, New York 11030; sssss. $182,000 in United States currency representing the substitute res for the real property and appurtenances, with all improvements and attachments thereon, located at 66-20/66-26 Laurel Hill Blvd., Woodside, New York 11377; ttttt. The real property and appurtenances, with all improvements and attachments thereon, located at 59 Harrow Lane, Manhasset, New York 11030; --- page 13 --- uuuu. The real property and appurtenances, with all improvements and attachments thereon, located at 97 Dorchester Drive, Manhasset, New York 11030; and vvvv. The real property and appurtenances, with all improvements and attachments thereon, located at 10 West End Avenue, Unit 24A, New York, New York 10023. --- page 14 --- 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 31 U.S.C. § 5317(c)(1) and 21 U.S.C. § 853(p), to seek forfeiture of any other property of the defendant up to the value of the above forfeitable property. (Title 31, United States Code, Section 5317, and Title 21, United States Code, Section 853.) Preet Bharara United States Attorney --- page 15 --- UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA V. LARISA MEDZON, Defendant. SUPERSEDING INFORMATION S3 11 Cr. 121 (GBD) (31 U.S.C. § 5324) PREET BHARARA United States Attorney.
OCR text (13,976c · none · 60% conf)
--- page 1 --- UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - x UNITED STATES OF AMERICA : SUPERSEDING - v. - : INFORMATION LARISA MEDZON, : S3 11 Cr. 121 (GBD) Defendant. : - - - - - - - - - - - - - - x COUNT ONE The United States Attorney charges: 1. From at least in or about June 2006 up to and including in or about December 2010, in the Southern District of New York and elsewhere, LARISA MEDZON, the defendant, knowingly and for the purpose of evading the reporting requirements of Title 31, United States Code, Section 5313(a) and the regulations promulgated thereunder, caused and attempted to cause a domestic financial institution to fail to file a report required under section 5313(a) of Title 31, and any regulation prescribed thereunder, and structured, and assisted in structuring, transactions with one and more domestic financial institutions, to wit, MEDZON withdrew more than $200,000 derived from the CityTime project from accounts at multiple financial institutions in increments of $500 or less in order to evade the reporting requirements of Title 31, United States Code, Section 5313(a) and the regulations promulgated thereunder. (Title 31, United States Code, Sections 5324(a)(1) and (a)(3)). --- page 2 --- FORFEITURE ALLEGATION 2. As a result of committing the offense alleged in Count One of this Information, LARISA MEDZON, the defendant, shall forfeit to the United States, pursuant to 31 U.S.C. § 5317(c)(1), all right, title and interest 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 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; --- page 3 --- - 3 --- page 4 --- - 4--- page 5 --- y. Approximately $6,389.60 in United States currency formerly on deposit in account number 006619428, held in the name of 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 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 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; -5- --- page 6 --- 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 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; ll. 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 --- page 7 --- 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 number 486040479, 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; -7- --- page 8 --- -8- --- page 9 --- -9---- page 10 --- Minor, Svetlana Mazer, Custodian, U.T.M.A., at Sovereign Bank; sss. Approximately $397,545 in United States currency formerly on deposit in account number 0971122725, held in the name of MS Advantage Group LLC, at Sovereign Bank; ttt. Approximately $10,012.03 in United States currency formerly on deposit in account number 3580520520, held in the name of MS Advantage Group LLC, at Sovereign Bank; uuu. Approximately $419,498.80 in United States currency formerly on deposit in account number 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; -10- --- page 11 --- -11- --- page 12 --- mmmm. Approximately $233,194 in United States currency formerly on deposit in account number 2000038347089, held in the name of MS Advantage Group LLC, at Wells Fargo; nnnnn. Approximately $205,350 in United States currency seized on or about December 16, 2010 from Safe Deposit Box No. 411 at Chase, Munsey Park, 2111 Northern Blvd., Manhasset, New York 11030; ooooo. Approximately $178,900 in United States currency seized on or about December 16, 2010 from Safe Deposit Box No. 1862 at Citibank, 1075 Northern Blvd., Roslyn, New York 11576; ppppp. Approximately $200,000 in United States currency seized on or about December 16, 2010 from Safe Deposit Box No. 2108-958 at Sovereign Bank, 1420 Northern Blvd., Manhasset, New York 11030; qqqqq. Approximately $280,200 in United States currency seized on or about December 16, 2010 from Safe Deposit Box No. 499 at TD Bank, 10836 Queens Blvd., Forest Hills, New York 11375; rrrrr. Approximately $155,100 in United States currency seized on or about January 11, 2011 from Safe Deposit Box No. 741-4 at Citibank, 1110 Northern Blvd., Manhasset, New York 11030; sssss. $182,000 in United States currency representing the substitute res for the real property and appurtenances, with all improvements and attachments thereon, located at 66-20/66-26 Laurel Hill Blvd., Woodside, New York 11377; ttttt. The real property and appurtenances, with all improvements and attachments thereon, located at 59 Harrow Lane, Manhasset, New York 11030; --- page 13 --- uuuu. The real property and appurtenances, with all improvements and attachments thereon, located at 97 Dorchester Drive, Manhasset, New York 11030; and vvvv. The real property and appurtenances, with all improvements and attachments thereon, located at 10 West End Avenue, Unit 24A, New York, New York 10023. --- page 14 --- 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 31 U.S.C. § 5317(c)(1) and 21 U.S.C. § 853(p), to seek forfeiture of any other property of the defendant up to the value of the above forfeitable property. (Title 31, United States Code, Section 5317, and Title 21, United States Code, Section 853.) Preet Bharara United States Attorney --- page 15 --- UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA V. LARISA MEDZON, Defendant. SUPERSEDING INFORMATION S3 11 Cr. 121 (GBD) (31 U.S.C. § 5324) PREET BHARARA United States Attorney.