StubHub Indictment

download StubHub Indictment

of 67

Transcript of StubHub Indictment

  • 8/12/2019 StubHub Indictment

    1/67

    NOTICE OF IMMIGRATION CONSEQUENCES

    If you are not a United States citizen, a plea of guilty to any offense, a conviction by trial verdict, or a youthful

    offender adjudication subjects you to a risk that adverse consequences will be imposed on you by the United Statesimmigration authorities, including, but not limited to, removal from the United States, exclusion from admission to theUnited States, and/or denial of naturalization. Because the immigration consequences applicable in your particular

    case may depend on factors such as your current immigration status, your length of residence in the United States, and

    your previous criminal history, you should consult with your attorney for advice specific to your circumstances.

    The following are designated as deportable offenses under 8 U.S.C. 1227(a)(2), and any non-citizen

    convicted of such an offense (within the meaning of 8 U.S.C. 1101[a][48]) shall, upon order of the AttorneyGeneral, be removed (8 U.S.C. 1227[a]), regardless of whether the offense is a felony, a misdemeanor, or any other

    offense under State law:

    any controlled substance or marihuana offense (other than a first offense involvingpossession for ones own use of 30 grams or less of marihuana);

    any offense involving a firearm, any domestic violence offense or violation of an order of

    protection, any stalking offense or crime of child abuse, and failure to register as a sex offender;

    any offense designated an aggravated felony under 8 U.S.C. 1101(a)(43), including, butnot limited to: murder; rape; any controlled substance or firearm trafficking offense; bail jumping;

    burglary, robbery, receipt of stolen property, or any other theft-related offense or crime of violencefor which a sentence of one year or more is imposed; or any offense involving money laundering ofmore than $10,000 or fraud, deceit or tax evasion in which the loss to the victim(s) is more than

    $10,000; and

    many other offenses described in 8 U.S.C. 1227(a)(2).

    In addition, if the offense constitutes an aggravated felony, or if you are not a lawful permanent resident of

    the United States (or have not been such for at least five years with at least seven years continuous residency) and the

    offense is any deportable offense, there will be additional consequences, including, but not limited to, your ineligibilityfor discretionary cancellation of removal by the Attorney General.

  • 8/12/2019 StubHub Indictment

    2/67

    NOTIFICACIN SOBRE CONSECUENCIAS INMIGRATORIAS

    Si usted no es ciudadano de los Estados Unidos, una declaracin de culpabilidad por cualquier

    ofensa, un veredicto condenatorio mediante un juicio o una declaracin como ofensor juvenil lo har sujetoal riesgo de que las autoridades inmigratorias de los Estados Unidos le impongan consecuencias adversas,

    que incluyen, sin que estas se limiten a, su expulsin de Los Estados Unidos, exclusin de ser admitido a los

    Estados Unidos, y/o el rechazo de su solicitud para la ciudadana o naturalizacin. Debido a que las

    consecuencias de inmigracin aplicables a su caso en particular pueden depender de factores como su

    estado de inmigracin actual, el tiempo que lleva viviendo en los Estados Unidos y sus antecedentes

    penales, usted debe consultar a su abogado para asesora especfica a sus circunstancias.

    Las siguientes ofensas han sido clasificadas como aquellas que implican deportacin de acuerdo a laley 8 U.S.C. 1227(a)(2), y cualquiera que no sea ciudadano y sea condenado por tal ofensa (como lodefine la ley 8 U.S.C. 1101[a][48]) deber, bajo ordenes del Procurador General, ser expulsado de los

    Estados Unidos (8 U.S.C. 1227[a]), sin importar si la ofensa es un delito mayor, un delito menor, o

    cualquier otra ofensa segn las leyes estatales:

    cualquier ofensa por sustancias reguladas o marihuana (excepto la primera ofensa

    relacionada con posesin de 30 gramos de marihuana o menos para uso propio);

    cualquier ofensa que incluya un arma de fuego, cualquier ofensa por violencia

    domstica o violacin de una orden de proteccin, cualquier ofensa por acechar o delito

    por maltrato de menores, e incumplimiento a registrarse como ofensor sexual;

    cualquier ofensa clasificada como un delito con agravante de acuerdo a la ley 8

    U.S.C. 1101(a)(43), incluyendo, y sin que estas se limiten a: homicidio; violacin

    sexual; cualquier ofensa por trfico de sustancias reguladas o de armas de fuego; huir

    estando bajo fianza, entrar sin autorizacin en propiedad ajena con la intencin de cometer

    un crimen, robo, recepcin de propiedad robada, o cualquier otra ofensa relacionada conrobo o un delito de violencia por el cual se haya impuesto una condena de un ao o ms; o

    cualquier ofensa relacionada con el lavado de dinero por ms de $10,000 o un fraude,

    t f i d i t l l did d l ( ) ti ( ) d

  • 8/12/2019 StubHub Indictment

    3/67

    /

    8 U.S.C. 1227(a)(2)

    ( 8

    U.S.C. 1101 [a][48] )

    (8 U.S.C. 1227 [a])

    30

    8 U.S.C. 1101 (a)(43)

    $10,000

    $10,000

    8 U.S.C. 1227 (a)(2) (

  • 8/12/2019 StubHub Indictment

    4/67

    SUPREME COURT OF THE STATE OF NEW YORK

    COUNTY OF NEW YORK

    THE PEOPLE OF THE STATE OF NEW YORK

    -against-

    Vadim Polyakov,

    Daniel Petryszyn,

    Laurence Brinkmeyer,Bryan Caputo,

    Sergei Kirin,

    Nikolay Matveychuk,

    Defendants.

    THE GRAND JURY OF THE COUNTY OF NEW YORK, by this indictment, accuses the

    defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of MONEY

    LAUNDERING IN THE FIRST DEGREE, in violation of Penal Law 470.20(1)(b)(ii)(A)(iii),

    committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

  • 8/12/2019 StubHub Indictment

    5/67

  • 8/12/2019 StubHub Indictment

    6/67

    FOURTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov and Daniel Petryszyn of the crime of CRIMINAL POSSESSION OF STOLEN

    PROPERTY IN THE FOURTH DEGREE, in violation of Penal Law 165.45(1), committed as

    follows:

    The defendants Vadim Polyakov and Daniel Petryszyn, in the County of New York and

    elsewhere, on or about April 8, 2013, with intent to benefit themselves, and a person other than an

    owner thereof and to impede the recovery by an owner thereof, knowingly possessed stolen property

    owned by StubHub LLC, and the value of the property exceeded one thousand dollars.

    FIFTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov and Daniel Petryszyn, of the crime of CRIMINAL POSSESSION OF STOLEN

    PROPERTY IN THE THIRD DEGREE, in violation of Penal Law 165.50 committed as

  • 8/12/2019 StubHub Indictment

    7/67

    SIXTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov and Daniel Petryszyn of the crime of CRIMINAL POSSESSION OF STOLEN

    PROPERTY IN THE FOURTH DEGREE, in violation of Penal Law 165.45(1), committed as

    follows:

    The defendants Vadim Polyakov and Daniel Petryszyn, in the County of New York and

    elsewhere, on or about April 24, 2013, with intent to benefit themselves, and a person other than an

    owner thereof and to impede the recovery by an owner thereof, knowingly possessed stolen property

    owned by StubHub LLC, and the value of the property exceeded one thousand dollars.

    SEVENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

  • 8/12/2019 StubHub Indictment

    8/67

    EIGHTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer, and Bryan Caputo of the crime of

    CRIMINAL POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation

    of Penal Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer, and Bryan

    Caputo, in the County of New York and elsewhere, on or about April 26, 2013, with intent to

    benefit themselves, and a person other than an owner thereof and to impede the recovery by an

    owner thereof, knowingly possessed stolen property owned by StubHub LLC, and the value of the

    property exceeded three thousand dollars.

    NINTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer, and Bryan Caputo of the crime of

    CRIMINAL POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation

  • 8/12/2019 StubHub Indictment

    9/67

    TENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer, and Bryan Caputo of the crime of

    CRIMINAL POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation

    of Penal Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer, and Bryan

    Caputo, in the County of New York and elsewhere, on or about May 12, 2013, with intent to benefit

    themselves, and a person other than an owner thereof and to impede the recovery by an owner

    thereof, knowingly possessed stolen property owned by StubHub LLC, and the value of the property

    exceeded three thousand dollars.

    ELEVENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer, and Bryan Caputo of the crime of

  • 8/12/2019 StubHub Indictment

    10/67

    TWELFTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer, and Bryan Caputo of the crime of

    CRIMINAL POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation

    of Penal Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer, and Bryan

    Caputo, in the County of New York and elsewhere, on or about May 16, 2013, with intent to benefit

    themselves, and a person other than an owner thereof and to impede the recovery by an owner

    thereof, knowingly possessed stolen property owned by StubHub LLC, and the value of the property

    exceeded three thousand dollars.

    THIRTEENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov and Daniel Petryszyn of the crime of CRIMINAL POSSESSION OF STOLEN

  • 8/12/2019 StubHub Indictment

    11/67

    FOURTEENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer in the County

    of New York and elsewhere, on or about June 12, 2013, with intent to benefit themselves, and a

    person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded three

    thousand dollars.

    FIFTEENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

  • 8/12/2019 StubHub Indictment

    12/67

    SIXTEENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE FOURTH DEGREE, in violation of Penal

    Law 165.45(1), committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about July 14, 2013, with intent to benefit themselves, and a

    person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded one

    thousand dollars.

    SEVENTEENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

  • 8/12/2019 StubHub Indictment

    13/67

    EIGHTEENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about July 19, 2013, with intent to benefit themselves, and a

    person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded three

    thousand dollars.

    NINETEENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

  • 8/12/2019 StubHub Indictment

    14/67

    TWENTIETH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about July 30, 2013, with intent to benefit themselves, and a

    person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded three

    thousand dollars.

    TWENTY-FIRST COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

  • 8/12/2019 StubHub Indictment

    15/67

    TWENTY-SECOND COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about August 6, 2013, with intent to benefit themselves, and a

    person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded three

    thousand dollars.

    TWENTY-THIRD COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

  • 8/12/2019 StubHub Indictment

    16/67

    TWENTY-FOURTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about August 14, 2013, with intent to benefit themselves, and a

    person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded three

    thousand dollars.

    TWENTY-FIFTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE FOURTH DEGREE, in violation of Penal

  • 8/12/2019 StubHub Indictment

    17/67

  • 8/12/2019 StubHub Indictment

    18/67

    TWENTY-EIGHTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about September 4, 2013, with intent to benefit themselves, and a

    person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded three

    thousand dollars.

    TWENTY-NINTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

  • 8/12/2019 StubHub Indictment

    19/67

    THIRTIETH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about September 8, 2013, with intent to benefit themselves, and a

    person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded three

    thousand dollars.

    THIRTY-FIRST COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

  • 8/12/2019 StubHub Indictment

    20/67

    THIRTY-SECOND COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about September 20, 2013, with intent to benefit themselves, and

    a person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded three

    thousand dollars.

    THIRTY-THIRD COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE FOURTH DEGREE, in violation of Penal

  • 8/12/2019 StubHub Indictment

    21/67

    THIRTY-FOURTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about September 22, 2013, with intent to benefit themselves, and

    a person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded three

    thousand dollars.

    THIRTY-FIFTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

  • 8/12/2019 StubHub Indictment

    22/67

    THIRTY-SIXTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about September 30, 2013, with intent to benefit themselves, and

    a person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded three

    thousand dollars.

    THIRTY-SEVENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

  • 8/12/2019 StubHub Indictment

    23/67

    THIRTY-EIGHTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE FOURTH DEGREE, in violation of Penal

    Law 165.45(1), committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about October 4, 2013, with intent to benefit themselves, and a

    person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded one

    thousand dollars.

    THIRTY-NINTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov and Daniel Petryszyn of the crime of CRIMINAL POSSESSION OF STOLEN

  • 8/12/2019 StubHub Indictment

    24/67

    FORTIETH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about October 13, 2013, with intent to benefit themselves, and a

    person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded three

    thousand dollars.

    FORTY-FIRST COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov and Daniel Petryszyn of the crime of CRIMINAL POSSESSION OF STOLEN

    PROPERTY IN THE THIRD DEGREE, in violation of Penal Law 165.50, committed as

  • 8/12/2019 StubHub Indictment

    25/67

    FORTY-SECOND COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about November 24, 2013, with intent to benefit themselves, and

    a person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded three

    thousand dollars.

    FORTY-THIRD COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

  • 8/12/2019 StubHub Indictment

    26/67

    FORTY-FOURTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about December 4, 2013, with intent to benefit themselves, and a

    person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded three

    thousand dollars.

    FORTY-FIFTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

  • 8/12/2019 StubHub Indictment

    27/67

  • 8/12/2019 StubHub Indictment

    28/67

    FORTY-EIGHTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about December 11, 2013, with intent to benefit themselves, and

    a person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded three

    thousand dollars.

    FORTY-NINTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

  • 8/12/2019 StubHub Indictment

    29/67

    FIFTIETH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about December 16, 2013, with intent to benefit themselves, and

    a person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded three

    thousand dollars.

    FIFTY-FIRST COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

  • 8/12/2019 StubHub Indictment

    30/67

    FIFTY-SECOND COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov and Daniel Petryszyn of the crime of CRIMINAL POSSESSION OF STOLEN

    PROPERTY IN THE THIRD DEGREE, in violation of Penal Law 165.50, committed as

    follows:

    The defendants Vadim Polyakov and Daniel Petryszyn, in the County of New York and

    elsewhere, on or about December 29, 2013, with intent to benefit themselves, and a person other

    than an owner thereof and to impede the recovery by an owner thereof, knowingly possessed stolen

    property owned by StubHub LLC, and the value of the property exceeded three thousand dollars.

    FIFTY-THIRD COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov and Daniel Petryszyn of the crime of CRIMINAL POSSESSION OF STOLEN

    PROPERTY IN THE THIRD DEGREE, in violation of Penal Law 165.50, committed as

    follows:

  • 8/12/2019 StubHub Indictment

    31/67

    FIFTY-FOURTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about January 8, 2014, with intent to benefit themselves, and a

    person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded three

    thousand dollars.

    FIFTY-FIFTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

  • 8/12/2019 StubHub Indictment

    32/67

    FIFTY-SIXTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants

    Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer of the crime of CRIMINAL

    POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, in violation of Penal

    Law 165.50, committed as follows:

    The defendants Vadim Polyakov, Daniel Petryszyn, and Laurence Brinkmeyer, in the County

    of New York and elsewhere, on or about January 12, 2014, with intent to benefit themselves, and a

    person other than an owner thereof and to impede the recovery by an owner thereof, knowingly

    possessed stolen property owned by StubHub LLC, and the value of the property exceeded three

    thousand dollars.

    FIFTY-SEVENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

  • 8/12/2019 StubHub Indictment

    33/67

    FIFTY-EIGHTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

    April 19, 2013, with intent to benefit himself and a person other than an owner thereof and to

    impede the recovery by an owner thereof, knowingly possessed stolen property owned by a second

    individual known to the Grand Jury and the property consisted of a second credit card ending 8480.

    FIFTY-NINTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

    April 23, 2013, with intent to benefit himself and a person other than an owner thereof and to

  • 8/12/2019 StubHub Indictment

    34/67

    SIXTIETH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

    April 23, 2013, with intent to benefit himself and a person other than an owner thereof and to

    impede the recovery by an owner thereof, knowingly possessed stolen property owned by a fourth

    individual known to the Grand Jury and the property consisted of a fourth credit card ending 7168.

    SIXTY-FIRST COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May

    4, 2013, with intent to benefit himself and a person other than an owner thereof and to impede the

  • 8/12/2019 StubHub Indictment

    35/67

    SIXTY-SECOND COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May

    7, 2013, with intent to benefit himself and a person other than an owner thereof and to impede the

    recovery by an owner thereof, knowingly possessed stolen property owned by a sixth individual

    known to the Grand Jury and the property consisted of a sixth credit card ending 9030.

    SIXTY-THIRD COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May

    8, 2013, with intent to benefit himself and a person other than an owner thereof and to impede the

  • 8/12/2019 StubHub Indictment

    36/67

    SIXTY-FOURTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May

    12, 2013, with intent to benefit himself and a person other than an owner thereof and to impede the

    recovery by an owner thereof, knowingly possessed stolen property owned by a eighth individual

    known to the Grand Jury and the property consisted of an eighth credit card ending 6945.

    SIXTY-FIFTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May

    15, 2013, with intent to benefit himself and a person other than an owner thereof and to impede the

  • 8/12/2019 StubHub Indictment

    37/67

    SIXTY-SIXTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May

    15, 2013, with intent to benefit himself and a person other than an owner thereof and to impede the

    recovery by an owner thereof, knowingly possessed stolen property owned by a tenth individual

    known to the Grand Jury and the property consisted of a tenth credit card ending 5224.

    SIXTY-SEVENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about June

    1, 2013, with intent to benefit himself and a person other than an owner thereof and to impede the

  • 8/12/2019 StubHub Indictment

    38/67

    SIXTY-EIGHTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about July

    15, 2013, with intent to benefit himself and a person other than an owner thereof and to impede the

    recovery by an owner thereof, knowingly possessed stolen property owned by a twelfth individual

    known to the Grand Jury and the property consisted of a twelfth credit card ending 7698.

    SIXTY-NINTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

    August 11, 2013, with intent to benefit himself and a person other than an owner thereof and to

  • 8/12/2019 StubHub Indictment

    39/67

    SEVENTIETH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

    August 11, 2013, with intent to benefit himself and a person other than an owner thereof and to

    impede the recovery by an owner thereof, knowingly possessed stolen property owned by a

    fourteenth individual known to the Grand Jury and the property consisted of a fourteenth credit card

    ending 6842.

    SEVENTY-FIRST COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

  • 8/12/2019 StubHub Indictment

    40/67

    SEVENTY-SECOND COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

    September 5, 2013, with intent to benefit himself and a person other than an owner thereof and to

    impede the recovery by an owner thereof, knowingly possessed stolen property owned by a sixteenth

    individual known to the Grand Jury and the property consisted of a sixteenth credit card ending

    6228.

    SEVENTY-THIRD COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

  • 8/12/2019 StubHub Indictment

    41/67

    SEVENTY-FOURTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

    September 5, 2013, with intent to benefit himself and a person other than an owner thereof and to

    impede the recovery by an owner thereof, knowingly possessed stolen property owned by an

    eighteenth individual known to the Grand Jury and the property consisted of an eighteenth credit

    card ending 5952.

    SEVENTY-FIFTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

  • 8/12/2019 StubHub Indictment

    42/67

  • 8/12/2019 StubHub Indictment

    43/67

  • 8/12/2019 StubHub Indictment

    44/67

    EIGHTIETH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

    September 20, 2013, with intent to benefit himself and a person other than an owner thereof and to

    impede the recovery by an owner thereof, knowingly possessed stolen property owned by a twenty-

    fourth individual known to the Grand Jury and the property consisted of a twenty-fourth credit card

    ending 9004.

    EIGHTY-FIRST COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of CRIMINAL POSSESSION OF STOLEN PROPERTY IN

    THE FOURTH DEGREE, in violation of Penal Law 165.45(2), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

  • 8/12/2019 StubHub Indictment

    45/67

  • 8/12/2019 StubHub Indictment

    46/67

    EIGHTY-FOURTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

    April 18, 2013, knowingly and with intent to defraud assumed the identity of another person by

    presenting himself as that other person, and by acting as that other person, and by using personal

    identifying information of that other person and thereby obtained goods and property, and used

    credit in the name of such other person in an aggregate amount that exceeded five hundred dollars.

    EIGHTY-FIFTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

  • 8/12/2019 StubHub Indictment

    47/67

  • 8/12/2019 StubHub Indictment

    48/67

    EIGHTY-EIGHTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May

    4, 2013, knowingly and with intent to defraud assumed the identity of a fifth person by presenting

    himself as that other person, and by acting as that other person, and by using personal identifying

    information of that other person and thereby obtained goods and property, and used credit in the

    name of such other person in an aggregate amount that exceeded five hundred dollars.

    EIGHTY-NINTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May

  • 8/12/2019 StubHub Indictment

    49/67

    NINETIETH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May

    8, 2013, knowingly and with intent to defraud assumed the identity of a seventh person by

    presenting himself as that other person, and by acting as that other person, and by using personal

    identifying information of that other person and thereby obtained goods and property, and used

    credit in the name of such other person in an aggregate amount that exceeded five hundred dollars.

    NINETY-FIRST COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May

  • 8/12/2019 StubHub Indictment

    50/67

    NINETY-SECOND COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May

    15, 2013, knowingly and with intent to defraud assumed the identity of a ninth person by presenting

    himself as that other person, and by acting as that other person, and by using personal identifying

    information of that other person and thereby obtained goods and property, and used credit in the

    name of such other person in an aggregate amount that exceeded five hundred dollars.

    NINETY-THIRD COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about May

  • 8/12/2019 StubHub Indictment

    51/67

    NINETY-FOURTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about June

    1, 2013, knowingly and with intent to defraud assumed the identity of a eleventh person by

    presenting himself as that other person, and by acting as that other person, and by using personal

    identifying information of that other person and thereby obtained goods and property, and used

    credit in the name of such other person in an aggregate amount that exceeded five hundred dollars.

    NINETY-FIFTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about July

  • 8/12/2019 StubHub Indictment

    52/67

    NINETY-SIXTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

    August 11, 2013, knowingly and with intent to defraud assumed the identity of a thirteenth person

    by presenting himself as that other person, and by acting as that other person, and by using personal

    identifying information of that other person and thereby obtained goods and property, and used

    credit in the name of such other person in an aggregate amount that exceeded five hundred dollars.

    NINETY-SEVENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

  • 8/12/2019 StubHub Indictment

    53/67

    NINETY-EIGHTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

    September 4, 2013, knowingly and with intent to defraud assumed the identity of a fifteenth person

    by presenting himself as that other person, and by acting as that other person, and by using personal

    identifying information of that other person and thereby obtained goods and property, and used

    credit in the name of such other person in an aggregate amount that exceeded five hundred dollars.

    NINETY-NINTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

  • 8/12/2019 StubHub Indictment

    54/67

    ONE HUNDREDTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

    September 5, 2013, knowingly and with intent to defraud assumed the identity of a seventeenth

    person by presenting himself as that other person, and by acting as that other person, and by using

    personal identifying information of that other person and thereby obtained goods and property, and

    used credit in the name of such other person in an aggregate amount that exceeded five hundred

    dollars.

    ONE HUNDRED AND FIRST COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

  • 8/12/2019 StubHub Indictment

    55/67

    ONE HUNDRED AND SECOND COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

    September 7, 2013, knowingly and with intent to defraud assumed the identity of a nineteenth

    person by presenting himself as that other person, and by acting as that other person, and by using

    personal identifying information of that other person and thereby obtained goods and property, and

    used credit in the name of such other person in an aggregate amount that exceeded five hundred

    dollars.

    ONE HUNDRED AND THIRD COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

  • 8/12/2019 StubHub Indictment

    56/67

    ONE HUNDRED AND FOURTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

    September 8, 2013, knowingly and with intent to defraud assumed the identity of a twenty-first

    person by presenting himself as that other person, and by acting as that other person, and by using

    personal identifying information of that other person and thereby obtained goods and property, and

    used credit in the name of such other person in an aggregate amount that exceeded five hundred

    dollars.

    ONE HUNDRED AND FIFTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

  • 8/12/2019 StubHub Indictment

    57/67

    ONE HUNDRED AND SIXTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

    September 9, 2013, knowingly and with intent to defraud assumed the identity of a twenty-third

    person by presenting himself as that other person, and by acting as that other person, and by using

    personal identifying information of that other person and thereby obtained goods and property, and

    used credit in the name of such other person in an aggregate amount that exceeded five hundred

    dollars.

    ONE HUNDRED AND SEVENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

  • 8/12/2019 StubHub Indictment

    58/67

    ONE HUNDRED AND EIGHTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

    December 2, 2013, knowingly and with intent to defraud assumed the identity of a twenty-fifth

    person by presenting himself as that other person, and by acting as that other person, and by using

    personal identifying information of that other person and thereby obtained goods and property, and

    used credit in the name of such other person in an aggregate amount that exceeded five hundred

    dollars.

    ONE HUNDRED AND NINTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

  • 8/12/2019 StubHub Indictment

    59/67

    ONE HUNDRED AND TENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Vadim Polyakov of the crime of IDENTITY THEFT IN THE SECOND DEGREE, in violation

    of Penal Law 190.79(1), committed as follows:

    The defendant Vadim Polyakov, in the County of New York and elsewhere, on or about

    December 13, 2013, knowingly and with intent to defraud assumed the identity of a twenty-seventh

    person by presenting himself as that other person, and by acting as that other person, and by using

    personal identifying information of that other person and thereby obtained goods and property, and

    used credit in the name of such other person in an aggregate amount that exceeded five hundred

    dollars.

    ONE HUNDRED AND ELEVENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Nikolay Matveychuk of the crime of GRAND LARCENY IN THE FOURTH DEGREE, in

    violation of Penal Law 155.30(1), committed as follows:

  • 8/12/2019 StubHub Indictment

    60/67

    ONE HUNDRED AND TWELFTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Nikolay Matveychuk of the crime of MONEY LAUNDERING IN THE 4TH DEGREE, in

    violation of Penal Law 470.05(1)(a)(ii)(A)(b), committed as follows:

    The defendant Nikolay Matveychuk, in the County of New York and elsewhere, during the

    period from on or about April 26, 2013 to on or about October 14, 2013, knowing that the property

    involved in one or more financial transactions represented the proceeds of criminal conduct,

    conducted one or more such financial transactions which in fact involved the proceeds of specified

    criminal conduct, knowing that the transaction or transactions in whole or in part were designed to

    conceal and disguise the nature, the location, the source, the ownership, and control of the proceeds

    of criminal conduct and the total value of the property involved in such financial transaction or

    transactions exceeded five thousand dollars.

  • 8/12/2019 StubHub Indictment

    61/67

    ONE HUNDRED AND THIRTEENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Bryan Caputo of the crime of MONEY LAUNDERING IN THE 4TH DEGREE, in violation of

    Penal Law 470.05(1)(a)(ii)(A)(b), committed as follows:

    The defendant Bryan Caputo, in the County of New York and elsewhere, during the period

    from on or about April 26, 2013 to on or about May 21, 2013, knowing that the property involved in

    one or more financial transactions represented the proceeds of criminal conduct, conducted one or

    more such financial transactions which in fact involved the proceeds of specified criminal conduct,

    knowing that the transaction or transactions in whole or in part were designed to conceal and

    disguise the nature, the location, the source, the ownership, and control of the proceeds of criminal

    conduct and the total value of the property involved in such financial transaction or transactions

    exceeded five thousand dollars.

  • 8/12/2019 StubHub Indictment

    62/67

    ONE HUNDRED AND FOURTEENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Nikolay Matveychuk of the crime of UNLAWFUL POSSESSION OF PERSONAL

    IDENTIFICATION INFORMATION IN THE THIRD DEGREE, in violation of Penal Law

    190.81, committed as follows:

    The defendant Nikolay Matveychuk, in the County of New York and elsewhere, on or about

    September 4, 2013, knowingly possessed a person's financial services account number and code,

    savings account number and code, checking account number and code, credit card account number

    and code, debit card number and code, personal identification number, mother's maiden name,

    computer system password, and electronic signature, knowing such information was intended to be

    used in furtherance of the commission of a crime defined in the Penal Law.

  • 8/12/2019 StubHub Indictment

    63/67

    ONE HUNDRED AND FIFTEENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Nikolay Matveychuk of the crime of UNLAWFUL POSSESSION OF PERSONAL

    IDENTIFICATION INFORMATION IN THE THIRD DEGREE, in violation of Penal Law

    190.81, committed as follows:

    The defendant Nikolay Matveychuk, in the County of New York and elsewhere, on or about

    September 7, 2013, knowingly possessed a person's financial services account number and code,

    savings account number and code, checking account number and code, credit card account number

    and code, debit card number and code, personal identification number, mother's maiden name,

    computer system password, and electronic signature, knowing such information was intended to be

    used in furtherance of the commission of a crime defined in the Penal Law.

  • 8/12/2019 StubHub Indictment

    64/67

    ONE HUNDRED AND SIXTEENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Nikolay Matveychuk of the crime of UNLAWFUL POSSESSION OF PERSONAL

    IDENTIFICATION INFORMATION IN THE THIRD DEGREE, in violation of Penal Law

    190.81, committed as follows:

    The defendant Nikolay Matveychuk, in the County of New York and elsewhere, on or about

    September 7, 2013, knowingly possessed a person's financial services account number and code,

    savings account number and code, checking account number and code, credit card account number

    and code, debit card number and code, personal identification number, mother's maiden name,

    computer system password, and electronic signature, knowing such information was intended to be

    used in furtherance of the commission of a crime defined in the Penal Law.

  • 8/12/2019 StubHub Indictment

    65/67

    ONE HUNDRED AND SEVENTEENTH COUNT:

    AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant

    Sergei Kirin of the crime of MONEY LAUNDERING IN THE SECOND DEGREE, in violation

    of Penal Law 470.15(1)(b)(ii)(A)(iii), committed as follows:

    The defendant Sergei Kirin, in the County of New York and elsewhere, during the period

    from on or about August 21, 2013 to on or about March 4, 2014, knowing that the property involved

    in one or more financial transactions represented the proceeds of specified criminal conduct, he or

    she conducts one or more financial transactions which in fact involved the proceeds of specified

    criminal conduct, knowing that the transaction or transactions in whole or in part were designed to

    conceal and disguise the nature, the location, the source, the ownership, and control of the proceeds

    of specified criminal conduct and the total value of the property involved in such financial

    transaction or transactions exceeded one hundred thousand dollars.

    CYRUS R. VANCE, JR.

    District Attorney

    GJ # 10 Case # 3A

  • 8/12/2019 StubHub Indictment

    66/67

    Filed: NA for all Defendants

    No.

    THE PEOPLE OF THE STATE OF NEW YORK

    -against-

    Vadim Polyakov, Daniel Petryszyn, Laurence Brinkmeyer,

    Bryan Caputo, Nikolay Matveychuk, Sergei Kirin,

    Defendants.

    INDICTMENT

    MONEY LAUNDERING IN THE FIRST DEGREE, P.L. 470.20(1)(b)(ii)(A)(iii) - DEF. V. Polyakov, D. Petryszyn, L. Brinkmeyer

    GRAND LARCENY IN THE FIRST DEGREE, P.L. 155.42 - DEF. V. Polyakov

    CRIMINAL POSSESSION OF STOLEN PROPERTY IN THE SECOND DEGREE, P.L. 165.52 - DEF. V. Polyakov, D. Petryszyn,CRIMINAL POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE, P.L. 165.50 - DEF. V. Polyakov, 46 Cts, D. Petryszyn, 46 Cts, L. Brinkmeyer,

    40 Cts, B. Caputo, 5 Cts

    CRIMINAL POSSESSION OF STOLEN PROPERTY IN THE FOURTH DEGREE, P.L. 165.45(1) - DEF. V. Polyakov, 7 Cts, D. Petryszyn, 7 Cts, L.

    Brinkmeyer, 4 Cts

    CRIMINAL POSSESSION OF STOLEN PROPERTY IN THE FOURTH DEGREE, P.L. 165.45(2) - DEF. V. Polyakov, 27 Cts

    IDENTITY THEFT IN THE SECOND DEGREE, P.L. 190.79(1) - DEF. V. Polyakov, 27 Cts

    GRAND LARCENY IN THE FOURTH DEGREE, P.L. 155.30(1) - DEF. N. Matveychuk

    MONEY LAUNDERING IN THE FOURTH DEGREE, P.L. 470.05(1)(a)(ii)(A)(b) - DEF. N. Matveychuk

    MONEY LAUNDERING IN THE FOURTH DEGREE, P.L. 470.05(1)(a)(ii)(A)(b) - DEF. B. Caputo

    UNLAWFUL POSSESSION OF PERSONAL IDENTIFICATION INFORMATION IN THE THIRD DEGREE, P.L. 190.81 - DEF. N. Matveychuk, 3 CtsMONEY LAUNDERING - 2ND CONCEAL OWNERSHIP, P.L. 470.15(1)(b)(ii)(A) - DEF. S. Kirin

    CYRUS R. VANCE, JR., District Attorney

    A True Bill

    N. David Neeman

    Cybercrime and Identity Theft Bureau Foreman

    ADJOURNED TO PART _______ ON ________

  • 8/12/2019 StubHub Indictment

    67/67

    67