Island Child Indictment

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I N D I C T M E N T

S U P R E M E C O U R T O F T H E S T A T E O F N E W Y O R KC O U N T Y O F Q U E E N S

----------------------------------------- | THE PEOPLE OF THE STATE OF NEW YORK | | AGAINST | | | IRA KURMEN | FILED: DEFENDANT | INDICTMENT NO. 378/2014 NYSID# 05553150K | | ROY HOFFMAN | DEFENDANT | | DANIEL LANIADO | DEFENDANT | | SAMUEL HILLER | DEFENDANT | NYSID# 01139431N | | | |-----------------------------------------

PL 155.42 GRAND LARCENY IN THE FIRST (IRA KURMEN) DEGREE (1) (ROY HOFFMAN) (SAMUEL HILLER)

PL 175.35 OFFERING A FALSE INSTRUMENT (IRA KURMEN) FOR FILING IN THE FIRST (ROY HOFFMAN) DEGREE (2-3) (SAMUEL HILLER)

PL 155.40-1 GRAND LARCENY IN THE SECOND (IRA KURMEN) DEGREE (4) (SAMUEL HILLER)

PL 175.10 FALSIFYING BUSINESS RECORDS (IRA KURMEN)

IN THE FIRST DEGREE (5-16) (SAMUEL HILLER)

PL 175.35 OFFERING A FALSE INSTRUMENT (IRA KURMEN) FOR FILING IN THE FIRST (SAMUEL HILLER) DEGREE (17-28)

PL 155.42 GRAND LARCENY IN THE FIRST (DANIEL LANIADO) DEGREE (29)

PL 190.80-1 IDENTITY THEFT IN THE FIRST (DANIEL LANIADO) DEGREE (30,33,36)

PL 190.80-2 IDENTITY THEFT IN THE FIRST (DANIEL LANIADO) DEGREE (31,34,37)

PL 190.80-3 IDENTITY THEFT IN THE FIRST (DANIEL LANIADO) DEGREE (32,35,38)

PL 155.35-1 GRAND LARCENY IN THE THIRD (ROY HOFFMAN) DEGREE (39)

PL 155.35-1 GRAND LARCENY IN THE THIRD (IRA KURMEN) DEGREE (40)

PL 155.35-1 GRAND LARCENY IN THE THIRD (SAMUEL HILLER) DEGREE (41)

PL 155.35-1 GRAND LARCENY IN THE THIRD (DANIEL LANIADO) DEGREE (42)

A TRUE BILL

------------------------------- DISTRICT ATTORNEY FOREMAN

FIRST COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN, ROY HOFFMAN AND SAMUEL HILLER OF

GRAND LARCENY IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHERS, ON OR ABOUT AND BETWEEN

NOVEMBER 30, 2005 AND DECEMBER 30, 2012 IN THE COUNTY OF QUEENS, STOLE

PROPERTY HAVING AN AGGREGATE VALUE EXCEEDING ONE MILLION DOLLARS, TO

WIT: UNITED STATES CURRENCY FROM THE STATE OF NEW YORK.

SECOND COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN, ROY HOFFMAN AND SAMUEL HILLER OF

OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE COMMITTED AS

FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHERS, ON OR ABOUT MAY 17,

2010 IN THE COUNTY OF QUEENS, KNOWING THAT A WRITTEN INSTRUMENT

CONTAINED A FALSE STATEMENT OR FALSE INFORMATION, AND WITH INTENT TO

DEFRAUD THE STATE OR ANY POLITICAL SUBDIVISION THEREOF, OFFERED OR

PRESENTED THE SAME TO A PUBLIC OFFICE OR PUBLIC SERVANT KNOWING OR

BELIEVING THAT IT WOULD BE FILED WITH, REGISTERED OR RECORDED IN, OR

OTHERWISE BECOME A PART OF THE RECORDS OF SUCH PUBLIC OFFICE OR PUBLIC

SERVANT.

THIRD COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN, ROY HOFFMAN AND SAMUEL HILLER OF

OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE COMMITTED AS

FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHERS, ON OR ABOUT MARCH 01,

2011 IN THE COUNTY OF QUEENS, KNOWING THAT A WRITTEN INSTRUMENT

CONTAINED A FALSE STATEMENT OR FALSE INFORMATION, AND WITH INTENT TO

DEFRAUD THE STATE OR ANY POLITICAL SUBDIVISION THEREOF, OFFERED OR

PRESENTED THE SAME TO A PUBLIC OFFICE OR PUBLIC SERVANT KNOWING OR

BELIEVING THAT IT WOULD BE FILED WITH, REGISTERED OR RECORDED IN, OR

OTHERWISE BECOME A PART OF THE RECORDS OF SUCH PUBLIC OFFICE OR PUBLIC

SERVANT.

FOURTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF GRAND LARCENY

IN THE SECOND DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT AND BETWEEN

JULY 01, 2009 AND JUNE 30, 2010 IN THE COUNTY OF QUEENS, STOLE

PROPERTY HAVING AN AGGREGATE VALUE EXCEEDING FIFTY THOUSAND DOLLARS,

TO WIT: UNITED STATES CURRENCY FROM THE NEW YORK CITY DEPARTMENT OF

EDUCATION.

FIFTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF FALSIFYING

BUSINESS RECORDS IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT JULY 24,

2009 IN THE COUNTY OF QUEENS, WITH THE INTENT TO DEFRAUD, MADE OR CAUSED

A FALSE ENTRY IN THE BUSINESS RECORDS OF AN ENTERPRISE, AND THEIR INTENT

TO DEFRAUD INCLUDED AN INTENT TO COMMIT ANOTHER CRIME OR CONCEAL THE

COMMISSION THEREOF.

SIXTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF FALSIFYING

BUSINESS RECORDS IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER

10, 2009 IN THE COUNTY OF QUEENS, WITH THE INTENT TO DEFRAUD, MADE OR

CAUSED A FALSE ENTRY IN THE BUSINESS RECORDS OF AN ENTERPRISE, AND THEIR

INTENT TO DEFRAUD INCLUDED AN INTENT TO COMMIT ANOTHER CRIME OR

CONCEAL THE COMMISSION THEREOF.

SEVENTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF FALSIFYING

BUSINESS RECORDS IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT OCTOBER 07,

2009 IN THE COUNTY OF QUEENS, WITH THE INTENT TO DEFRAUD, MADE OR CAUSED

A FALSE ENTRY IN THE BUSINESS RECORDS OF AN ENTERPRISE, AND THEIR INTENT

TO DEFRAUD INCLUDED AN INTENT TO COMMIT ANOTHER CRIME OR CONCEAL THE

COMMISSION THEREOF.

EIGHTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF FALSIFYING

BUSINESS RECORDS IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT NOVEMBER 10,

2009 IN THE COUNTY OF QUEENS, WITH THE INTENT TO DEFRAUD, MADE OR CAUSED

A FALSE ENTRY IN THE BUSINESS RECORDS OF AN ENTERPRISE, AND THEIR INTENT

TO DEFRAUD INCLUDED AN INTENT TO COMMIT ANOTHER CRIME OR CONCEAL THE

COMMISSION THEREOF.

NINTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF FALSIFYING

BUSINESS RECORDS IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT DECEMBER 01,

2009 IN THE COUNTY OF QUEENS, WITH THE INTENT TO DEFRAUD, MADE OR CAUSED

A FALSE ENTRY IN THE BUSINESS RECORDS OF AN ENTERPRISE, AND THEIR INTENT

TO DEFRAUD INCLUDED AN INTENT TO COMMIT ANOTHER CRIME OR CONCEAL THE

COMMISSION THEREOF.

TENTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF FALSIFYING

BUSINESS RECORDS IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT JANUARY 07,

2010 IN THE COUNTY OF QUEENS, WITH THE INTENT TO DEFRAUD, MADE OR CAUSED

A FALSE ENTRY IN THE BUSINESS RECORDS OF AN ENTERPRISE, AND THEIR INTENT

TO DEFRAUD INCLUDED AN INTENT TO COMMIT ANOTHER CRIME OR CONCEAL THE

COMMISSION THEREOF.

ELEVENTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF FALSIFYING

BUSINESS RECORDS IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT FEBRUARY 09,

2010 IN THE COUNTY OF QUEENS, WITH THE INTENT TO DEFRAUD, MADE OR CAUSED

A FALSE ENTRY IN THE BUSINESS RECORDS OF AN ENTERPRISE, AND THEIR INTENT

TO DEFRAUD INCLUDED AN INTENT TO COMMIT ANOTHER CRIME OR CONCEAL THE

COMMISSION THEREOF.

TWELFTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF FALSIFYING

BUSINESS RECORDS IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT MARCH 10, 2010

IN THE COUNTY OF QUEENS, WITH THE INTENT TO DEFRAUD, MADE OR CAUSED A

FALSE ENTRY IN THE BUSINESS RECORDS OF AN ENTERPRISE, AND THEIR INTENT

TO DEFRAUD INCLUDED AN INTENT TO COMMIT ANOTHER CRIME OR CONCEAL THE

COMMISSION THEREOF.

THIRTEENTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF FALSIFYING

BUSINESS RECORDS IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT APRIL 09, 2010

IN THE COUNTY OF QUEENS, WITH THE INTENT TO DEFRAUD, MADE OR CAUSED A

FALSE ENTRY IN THE BUSINESS RECORDS OF AN ENTERPRISE, AND THEIR INTENT

TO DEFRAUD INCLUDED AN INTENT TO COMMIT ANOTHER CRIME OR CONCEAL THE

COMMISSION THEREOF.

FOURTEENTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF FALSIFYING

BUSINESS RECORDS IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT APRIL 20, 2010

IN THE COUNTY OF QUEENS, WITH THE INTENT TO DEFRAUD, MADE OR CAUSED A

FALSE ENTRY IN THE BUSINESS RECORDS OF AN ENTERPRISE, AND THEIR INTENT

TO DEFRAUD INCLUDED AN INTENT TO COMMIT ANOTHER CRIME OR CONCEAL THE

COMMISSION THEREOF.

FIFTEENTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF FALSIFYING

BUSINESS RECORDS IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT JUNE 09,

2010 IN THE COUNTY OF QUEENS, WITH THE INTENT TO DEFRAUD, MADE OR CAUSED

A FALSE ENTRY IN THE BUSINESS RECORDS OF AN ENTERPRISE, AND THEIR INTENT

TO DEFRAUD INCLUDED AN INTENT TO COMMIT ANOTHER CRIME OR CONCEAL THE

COMMISSION THEREOF.

SIXTEENTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF FALSIFYING

BUSINESS RECORDS IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT AUGUST 27,

2010 IN THE COUNTY OF QUEENS, WITH THE INTENT TO DEFRAUD, MADE OR CAUSED

A FALSE ENTRY IN THE BUSINESS RECORDS OF AN ENTERPRISE, AND THEIR INTENT

TO DEFRAUD INCLUDED AN INTENT TO COMMIT ANOTHER CRIME OR CONCEAL THE

COMMISSION THEREOF.

SEVENTEENTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF OFFERING A

FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT JULY 24,

2009 IN THE COUNTY OF QUEENS, KNOWING THAT A WRITTEN INSTRUMENT

CONTAINED A FALSE STATEMENT OR FALSE INFORMATION, AND WITH INTENT TO

DEFRAUD THE STATE OR ANY POLITICAL SUBDIVISION THEREOF, OFFERED OR

PRESENTED THE SAME TO A PUBLIC OFFICE OR PUBLIC SERVANT KNOWING OR

BELIEVING THAT IT WOULD BE FILED WITH, REGISTERED OR RECORDED IN, OR

OTHERWISE BECOME A PART OF THE RECORDS OF SUCH PUBLIC OFFICE OR PUBLIC

SERVANT.

EIGHTEENTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF OFFERING A

FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT SEPTEMBER

10, 2009 IN THE COUNTY OF QUEENS, KNOWING THAT A WRITTEN INSTRUMENT

CONTAINED A FALSE STATEMENT OR FALSE INFORMATION, AND WITH INTENT TO

DEFRAUD THE STATE OR ANY POLITICAL SUBDIVISION THEREOF, OFFERED OR

PRESENTED THE SAME TO A PUBLIC OFFICE OR PUBLIC SERVANT KNOWING OR

BELIEVING THAT IT WOULD BE FILED WITH, REGISTERED OR RECORDED IN, OR

OTHERWISE BECOME A PART OF THE RECORDS OF SUCH PUBLIC OFFICE OR PUBLIC

SERVANT.

NINETEENTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF OFFERING A

FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT OCTOBER 07,

2009 IN THE COUNTY OF QUEENS, KNOWING THAT A WRITTEN INSTRUMENT

CONTAINED A FALSE STATEMENT OR FALSE INFORMATION, AND WITH INTENT TO

DEFRAUD THE STATE OR ANY POLITICAL SUBDIVISION THEREOF, OFFERED OR

PRESENTED THE SAME TO A PUBLIC OFFICE OR PUBLIC SERVANT KNOWING OR

BELIEVING THAT IT WOULD BE FILED WITH, REGISTERED OR RECORDED IN, OR

OTHERWISE BECOME A PART OF THE RECORDS OF SUCH PUBLIC OFFICE OR PUBLIC

SERVANT.

TWENTIETH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF OFFERING A

FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT NOVEMBER 10,

2009 IN THE COUNTY OF QUEENS, KNOWING THAT A WRITTEN INSTRUMENT

CONTAINED A FALSE STATEMENT OR FALSE INFORMATION, AND WITH INTENT TO

DEFRAUD THE STATE OR ANY POLITICAL SUBDIVISION THEREOF, OFFERED OR

PRESENTED THE SAME TO A PUBLIC OFFICE OR PUBLIC SERVANT KNOWING OR

BELIEVING THAT IT WOULD BE FILED WITH, REGISTERED OR RECORDED IN, OR

OTHERWISE BECOME A PART OF THE RECORDS OF SUCH PUBLIC OFFICE OR PUBLIC

SERVANT.

TWENTY FIRST COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF OFFERING A

FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT DECEMBER 01,

2009 IN THE COUNTY OF QUEENS, KNOWING THAT A WRITTEN INSTRUMENT

CONTAINED A FALSE STATEMENT OR FALSE INFORMATION, AND WITH INTENT TO

DEFRAUD THE STATE OR ANY POLITICAL SUBDIVISION THEREOF, OFFERED OR

PRESENTED THE SAME TO A PUBLIC OFFICE OR PUBLIC SERVANT KNOWING OR

BELIEVING THAT IT WOULD BE FILED WITH, REGISTERED OR RECORDED IN, OR

OTHERWISE BECOME A PART OF THE RECORDS OF SUCH PUBLIC OFFICE OR PUBLIC

SERVANT.

TWENTY SECOND COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF OFFERING A

FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT JANUARY 07,

2010 IN THE COUNTY OF QUEENS, KNOWING THAT A WRITTEN INSTRUMENT

CONTAINED A FALSE STATEMENT OR FALSE INFORMATION, AND WITH INTENT TO

DEFRAUD THE STATE OR ANY POLITICAL SUBDIVISION THEREOF, OFFERED OR

PRESENTED THE SAME TO A PUBLIC OFFICE OR PUBLIC SERVANT KNOWING OR

BELIEVING THAT IT WOULD BE FILED WITH, REGISTERED OR RECORDED IN, OR

OTHERWISE BECOME A PART OF THE RECORDS OF SUCH PUBLIC OFFICE OR PUBLIC

SERVANT.

TWENTY THIRD COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF OFFERING A

FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT FEBRUARY 09,

2010 IN THE COUNTY OF QUEENS, KNOWING THAT A WRITTEN INSTRUMENT

CONTAINED A FALSE STATEMENT OR FALSE INFORMATION, AND WITH INTENT TO

DEFRAUD THE STATE OR ANY POLITICAL SUBDIVISION THEREOF, OFFERED OR

PRESENTED THE SAME TO A PUBLIC OFFICE OR PUBLIC SERVANT KNOWING OR

BELIEVING THAT IT WOULD BE FILED WITH, REGISTERED OR RECORDED IN, OR

OTHERWISE BECOME A PART OF THE RECORDS OF SUCH PUBLIC OFFICE OR PUBLIC

SERVANT.

TWENTY FOURTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF OFFERING A

FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT MARCH 10, 2010

IN THE COUNTY OF QUEENS, KNOWING THAT A WRITTEN INSTRUMENT CONTAINED A

FALSE STATEMENT OR FALSE INFORMATION, AND WITH INTENT TO DEFRAUD THE

STATE OR ANY POLITICAL SUBDIVISION THEREOF, OFFERED OR PRESENTED THE

SAME TO A PUBLIC OFFICE OR PUBLIC SERVANT KNOWING OR BELIEVING THAT IT

WOULD BE FILED WITH, REGISTERED OR RECORDED IN, OR OTHERWISE BECOME A

PART OF THE RECORDS OF SUCH PUBLIC OFFICE OR PUBLIC SERVANT.

TWENTY FIFTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF OFFERING A

FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT APRIL 09, 2010

IN THE COUNTY OF QUEENS, KNOWING THAT A WRITTEN INSTRUMENT CONTAINED A

FALSE STATEMENT OR FALSE INFORMATION, AND WITH INTENT TO DEFRAUD THE

STATE OR ANY POLITICAL SUBDIVISION THEREOF, OFFERED OR PRESENTED THE

SAME TO A PUBLIC OFFICE OR PUBLIC SERVANT KNOWING OR BELIEVING THAT IT

WOULD BE FILED WITH, REGISTERED OR RECORDED IN, OR OTHERWISE BECOME A

PART OF THE RECORDS OF SUCH PUBLIC OFFICE OR PUBLIC SERVANT.

TWENTY SIXTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF OFFERING A

FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT APRIL 20, 2010

IN THE COUNTY OF QUEENS, KNOWING THAT A WRITTEN INSTRUMENT CONTAINED A

FALSE STATEMENT OR FALSE INFORMATION, AND WITH INTENT TO DEFRAUD THE

STATE OR ANY POLITICAL SUBDIVISION THEREOF, OFFERED OR PRESENTED THE

SAME TO A PUBLIC OFFICE OR PUBLIC SERVANT KNOWING OR BELIEVING THAT IT

WOULD BE FILED WITH, REGISTERED OR RECORDED IN, OR OTHERWISE BECOME A

PART OF THE RECORDS OF SUCH PUBLIC OFFICE OR PUBLIC SERVANT.

TWENTY SEVENTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF OFFERING A

FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT JUNE 09,

2010 IN THE COUNTY OF QUEENS, KNOWING THAT A WRITTEN INSTRUMENT

CONTAINED A FALSE STATEMENT OR FALSE INFORMATION, AND WITH INTENT TO

DEFRAUD THE STATE OR ANY POLITICAL SUBDIVISION THEREOF, OFFERED OR

PRESENTED THE SAME TO A PUBLIC OFFICE OR PUBLIC SERVANT KNOWING OR

BELIEVING THAT IT WOULD BE FILED WITH, REGISTERED OR RECORDED IN, OR

OTHERWISE BECOME A PART OF THE RECORDS OF SUCH PUBLIC OFFICE OR PUBLIC

SERVANT.

TWENTY EIGHTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANTS IRA KURMEN AND SAMUEL HILLER OF OFFERING A

FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANTS, EACH AIDING THE OTHER, ON OR ABOUT AUGUST 27,

2010 IN THE COUNTY OF QUEENS, KNOWING THAT A WRITTEN INSTRUMENT

CONTAINED A FALSE STATEMENT OR FALSE INFORMATION, AND WITH INTENT TO

DEFRAUD THE STATE OR ANY POLITICAL SUBDIVISION THEREOF, OFFERED OR

PRESENTED THE SAME TO A PUBLIC OFFICE OR PUBLIC SERVANT KNOWING OR

BELIEVING THAT IT WOULD BE FILED WITH, REGISTERED OR RECORDED IN, OR

OTHERWISE BECOME A PART OF THE RECORDS OF SUCH PUBLIC OFFICE OR PUBLIC

SERVANT.

TWENTY NINTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANT DANIEL LANIADO OF GRAND LARCENY IN THE FIRST

DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANT, ACTING IN CONCERT WITH OTHER PERSONS, ON OR

ABOUT AND BETWEEN MARCH 11, 2006 AND JULY 01, 2012 IN THE COUNTY OF

QUEENS, STOLE PROPERTY HAVING AN AGGREGATE VALUE EXCEEDING ONE MILLION

DOLLARS, TO WIT: UNITED STATES CURRENCY FROM THE STATE OF NEW YORK.

THIRTIETH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANT DANIEL LANIADO OF IDENTITY THEFT IN THE FIRST

DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANT, ACTING IN CONCERT WITH OTHER PERSONS, ON OR

ABOUT AND BETWEEN JULY 31, 2009 AND MAY 01, 2011 IN THE COUNTY OF

QUEENS, KNOWINGLY AND WITH INTENT TO DEFRAUD, ASSUMED THE IDENTITY OF

NISELLY BONILLA BY PRESENTING HIMSELF AS NISELLY BONILLA OR BY ACTING AS

NISELLY BONILLA OR BY USING PERSONAL IDENTIFYING INFORMATION OF

NISELLY BONILLA AND THEREBY OBTAINED GOODS, MONEY, PROPERTY OR

SERVICES OR USED CREDIT IN THE NAME OF NISELLY BONILLA IN AN AGGREGATE

AMOUNT THAT EXCEEDED TWO THOUSAND DOLLARS.

THIRTY FIRST COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANT DANIEL LANIADO OF IDENTITY THEFT IN THE FIRST

DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANT, ACTING IN CONCERT WITH OTHER PERSONS, ON OR

ABOUT AND BETWEEN JULY 31, 2009 AND MAY 01, 2011 IN THE COUNTY OF

QUEENS, KNOWINGLY AND WITH INTENT TO DEFRAUD, ASSUMED THE IDENTITY OF

NISELLY BONILLA BY PRESENTING HIMSELF AS NISELLY BONILLA OR BY ACTING AS

NISELLY BONILLA OR BY USING PERSONAL IDENTIFYING INFORMATION OF

NISELLY BONILLA AND THEREBY CAUSED FINANCIAL LOSS TO SUCH PERSON OR

ANOTHER PERSON OR PERSONS IN AN AGGREGATE AMOUNT THAT EXCEEDED TWO

THOUSAND DOLLARS.

THIRTY SECOND COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANT DANIEL LANIADO OF IDENTITY THEFT IN THE FIRST

DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANT, ACTING IN CONCERT WITH OTHER PERSONS, ON OR

ABOUT AND BETWEEN JULY 31, 2009 AND MAY 01, 2011 IN THE COUNTY OF

QUEENS, KNOWINGLY AND WITH INTENT TO DEFRAUD, ASSUMED THE IDENTITY OF

NISELLY BONILLA BY PRESENTING HIMSELF AS NISELLY BONILLA OR BY ACTING AS

NISELLY BONILLA OR BY USING PERSONAL IDENTIFYING INFORMATION OF

NISELLY BONILLA AND THEREBY COMMITTED OR ATTEMPTED TO COMMIT A CLASS D

FELONY OR HIGHER LEVEL CRIME OR ACTED AS AN ACCESSORY IN THE

COMMISSION OF A CLASS D OR HIGHER LEVEL FELONY.

THIRTY THIRD COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANT DANIEL LANIADO OF IDENTITY THEFT IN THE FIRST

DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANT, ACTING IN CONCERT WITH OTHER PERSONS, ON OR

ABOUT AND BETWEEN MAY 31, 2011 AND MARCH 31, 2012 IN THE COUNTY OF

QUEENS, KNOWINGLY AND WITH INTENT TO DEFRAUD, ASSUMED THE IDENTITY OF

DOUBLE PLAY TOYS INC., A BUSINESS ENTITY, BY PRESENTING HIMSELF AS

DOUBLE PLAY TOYS INC., A BUSINESS ENTITY, OR BY ACTING AS DOUBLE PLAY

TOYS INC., A BUSINESS ENTITY, OR BY USING PERSONAL IDENTIFYING

INFORMATION OF DOUBLE PLAY TOYS INC., A BUSINESS ENTITY, AND THEREBY

OBTAINED GOODS, MONEY, PROPERTY OR SERVICES OR USED CREDIT IN THE NAME

OF DOUBLE PLAY TOYS INC., A BUSINESS ENTITY, IN AN AGGREGATE AMOUNT THAT

EXCEEDED TWO THOUSAND DOLLARS.

THIRTY FOURTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANT DANIEL LANIADO OF IDENTITY THEFT IN THE FIRST

DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANT, ACTING IN CONCERT WITH OTHER PERSONS, ON OR

ABOUT AND BETWEEN MAY 31, 2011 AND MARCH 31, 2012 IN THE COUNTY OF

QUEENS, KNOWINGLY AND WITH INTENT TO DEFRAUD, ASSUMED THE IDENTITY OF

DOUBLE PLAY TOYS INC., A BUSINESS ENTITY, BY PRESENTING HIMSELF AS

DOUBLE PLAY TOYS INC., A BUSINESS ENTITY, OR BY ACTING AS DOUBLE PLAY

TOYS INC., A BUSINESS ENTITY, OR BY USING PERSONAL IDENTIFYING

INFORMATION OF DOUBLE PLAY TOYS INC., A BUSINESS ENTITY, AND THEREBY

CAUSED FINANCIAL LOSS TO SUCH PERSON OR ANOTHER PERSON OR PERSONS IN

AN AGGREGATE AMOUNT THAT EXCEEDED TWO THOUSAND DOLLARS.

THIRTY FIFTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANT DANIEL LANIADO OF IDENTITY THEFT IN THE FIRST

DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANT, ACTING IN CONCERT WITH OTHER PERSONS, ON OR

ABOUT AND BETWEEN MAY 31, 2011 AND MARCH 31, 2012 IN THE COUNTY OF

QUEENS, KNOWINGLY AND WITH INTENT TO DEFRAUD, ASSUMED THE IDENTITY OF

DOUBLE PLAY TOYS INC., A BUSINESS ENTITY, BY PRESENTING HIMSELF AS

DOUBLE PLAY TOYS INC., A BUSINESS ENTITY, OR BY ACTING AS DOUBLE PLAY

TOYS INC., A BUSINESS ENTITY, OR BY USING PERSONAL IDENTIFYING

INFORMATION OF DOUBLE PLAY TOYS INC., A BUSINESS ENTITY, AND THEREBY

COMMITTED OR ATTEMPTED TO COMMIT A CLASS D FELONY OR HIGHER LEVEL

CRIME OR ACTED AS AN ACCESSORY IN THE COMMISSION OF A CLASS D OR

HIGHER LEVEL FELONY.

THIRTY SIXTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANT DANIEL LANIADO OF IDENTITY THEFT IN THE FIRST

DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANT, ACTING IN CONCERT WITH OTHER PERSONS, ON OR

ABOUT AND BETWEEN JUNE 12, 2011 AND NOVEMBER 18, 2011 IN THE COUNTY OF

QUEENS, KNOWINGLY AND WITH INTENT TO DEFRAUD, ASSUMED THE IDENTITY OF

NLM, A BUSINESS ENTITY, BY PRESENTING HIMSELF AS NLM, A BUSINESS ENTITY,

OR BY ACTING AS NLM, A BUSINESS ENTITY, OR BY USING PERSONAL IDENTIFYING

INFORMATION OF NLM, A BUSINESS ENTITY, AND THEREBY OBTAINED GOODS,

MONEY, PROPERTY OR SERVICES OR USED CREDIT IN THE NAME OF NLM, A

BUSINESS ENTITY, IN AN AGGREGATE AMOUNT THAT EXCEEDED TWO THOUSAND

DOLLARS.

THIRTY SEVENTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANT DANIEL LANIADO OF IDENTITY THEFT IN THE FIRST

DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANT, ACTING IN CONCERT WITH OTHER PERSONS, ON OR

ABOUT AND BETWEEN JUNE 12, 2011 AND NOVEMBER 18, 2011 IN THE COUNTY OF

QUEENS, KNOWINGLY AND WITH INTENT TO DEFRAUD, ASSUMED THE IDENTITY OF

NLM, A BUSINESS ENTITY, BY PRESENTING HIMSELF AS NLM, A BUSINESS ENTITY,

OR BY ACTING AS NLM, A BUSINESS ENTITY, OR BY USING PERSONAL IDENTIFYING

INFORMATION OF NLM, A BUSINESS ENTITY, AND THEREBY CAUSED FINANCIAL LOSS

TO SUCH PERSON OR ANOTHER PERSON OR PERSONS IN AN AGGREGATE AMOUNT

THAT EXCEEDED TWO THOUSAND DOLLARS.

THIRTY EIGHTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANT DANIEL LANIADO OF IDENTITY THEFT IN THE FIRST

DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANT, ACTING IN CONCERT WITH OTHER PERSONS, ON OR

ABOUT AND BETWEEN JUNE 12, 2011 AND NOVEMBER 18, 2011 IN THE COUNTY OF

QUEENS, KNOWINGLY AND WITH INTENT TO DEFRAUD, ASSUMED THE IDENTITY OF

NLM, A BUSINESS ENTITY, BY PRESENTING HIMSELF AS NLM, A BUSINESS ENTITY,

OR BY ACTING AS NLM, A BUSINESS ENTITY, OR BY USING PERSONAL IDENTIFYING

INFORMATION OF NLM, A BUSINESS ENTITY, AND THEREBY COMMITTED OR

ATTEMPTED TO COMMIT A CLASS D FELONY OR HIGHER LEVEL CRIME OR ACTED AS

AN ACCESSORY IN THE COMMISSION OF A CLASS D OR HIGHER LEVEL FELONY.

THIRTY NINTH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANT ROY HOFFMAN OF GRAND LARCENY IN THE THIRD

DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANT, ACTING IN CONCERT WITH OTHER PERSONS, ON OR

ABOUT AUGUST 18, 2009 IN THE COUNTY OF QUEENS, STOLE PROPERTY HAVING

AN AGGREGATE VALUE OF MORE THAN THREE THOUSAND DOLLARS, TO WIT: UNITED

STATES CURRENCY FROM THE STATE OF NEW YORK.

FORTIETH COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANT IRA KURMEN OF GRAND LARCENY IN THE THIRD DEGREE

COMMITTED AS FOLLOWS:

THE DEFENDANT, ACTING IN CONCERT WITH OTHER PERSONS, ON OR

ABOUT SEPTEMBER 30, 2009 IN THE COUNTY OF QUEENS, STOLE PROPERTY

HAVING AN AGGREGATE VALUE OF MORE THAN THREE THOUSAND DOLLARS, TO WIT:

UNITED STATES CURRENCY FROM THE STATE OF NEW YORK.

FORTY FIRST COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANT SAMUEL HILLER OF GRAND LARCENY IN THE THIRD

DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANT, ACTING IN CONCERT WITH OTHER PERSONS, ON OR

ABOUT JUNE 30, 2010 IN THE COUNTY OF QUEENS, STOLE PROPERTY HAVING AN

AGGREGATE VALUE OF MORE THAN THREE THOUSAND DOLLARS, TO WIT: UNITED

STATES CURRENCY FROM THE STATE OF NEW YORK.

FORTY SECOND COUNT

THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,

ACCUSES THE DEFENDANT DANIEL LANIADO OF GRAND LARCENY IN THE THIRD

DEGREE COMMITTED AS FOLLOWS:

THE DEFENDANT, ACTING IN CONCERT WITH OTHER PERSONS, ON OR ABOUT

MAY 05, 2011 IN THE COUNTY OF QUEENS, STOLE PROPERTY HAVING AN

AGGREGATE VALUE OF MORE THAN THREE THOUSAND DOLLARS, TO WIT: UNITED

STATES CURRENCY FROM THE STATE OF NEW YORK.

RICHARD A. BROWN DISTRICT ATTORNEY