Approved, ~~~AM~Lf~~J.6~ MICHAEL S
Approved, ~~~AM~lf~~J.6~ MICHAEL S. BOSWORTH Assistant United States Attorneys Before: HONORABLE DEBRA FREEMAN United States Magistrate Judge Southern District of New York 10 ----------------- x SEALED COMPLAINT UNITED STATES OF AMERICA 18 U.S.C. §§ 1001, - v. - 1343 & 1956; 15 U.S.C. §§ 80b-6 & KENNETH STARR, and 80b-17; 26 U.S.C. -ANDREW STEIN, §7206(1) Defendants. COUNTY OF OFFENSE: NEW YORK x SOUTHERN DISTRICT OF NEW YORK, ss.: ROBERT BERANGER, being duly sworn, deposes and says that he is a Special Agent with the Internal Revenue Service Criminal Investigative Division (the "IRS-CID") and charges as follows: COUNT ONE (Wire Fraud Scheme To Obtain Property) 1. From at least in or about January 2008, through and including in or about April 2010, in the Southern District of New York and elsewhere, KENNETH STARR, the defendant, and others known and unknown, unlawfully, willfully, and knowingly, having devised and intending to devise a scheme and artifice to defraud, and for obtaining money and property by means of false and fraudulent pretenses, representations, and promises, did transmit and cause to be transmitted by means of wire, radio, and television communication in interstate and foreign commerce, any writings, signs, signals, pictures, and sounds for the purpose of executing such scheme and artifice, to wit, STARR marketed his services as an accountant and financial adviser to clients, gained control over millions of dollars belonging to his clients, and then misappropriated millions of dollars of his clients' assets for his own personal use, including to purchase himself a new, multi-million dollar residence.
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