Affidavit in Support of Criminal Complaint
IN THE UNITED STATES DISTRICT COURT MAY l,') 8 (,L,l."',qi:'l FOR THE SOUTHERN DISTRICT OF ILLINOIS CUFFORD J. PROUD US.MAG5TRATEJUOGE SOl.J1lfERN DlSTRlcr OF ILLlNOl" EAST sr. LOU5 OF"fICE '- UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) vs. ) ) NICHOLAS A. SMIRNOW ) a/k/a Nicoloy Smirnow, Alexander Judizcev, ) Nicholas Kachura, and JeffProzorowiczm, ) ) Defendant. ) AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT I, Postal Inspector Jacob M. Gholson, being first duly sworn, hereby depose and state as follows: 1. I am a Postal Inspector with the United States Postal Inspection Service, and have been since March, 2008. I have been working mail fraud cases since July 2008. Overview ofscam 2. As is detailed more fully within, Pathway to Prosperity ("P-2-P") was an internet Ponzi scheme that promised investors worldwide very high returns with little or no risk. P-2-P purported to afford to the average person the opportunity to take advantage ofinvestment vehicles ostensibly available to only the very rich. As represented to investors, by investing with P-2-P, the average investor would supposedly pool his or her money with that ofother investors to "piggyback" on the investment ofP-2-P and its principal, NICHOLAS A. SMIRNOW ("SMIRNOW"). 3. Financial records ofpayment processors utilized by P-2-P to collect investment funds from investors show that approximately 40,000 investors in 120 countries established accounts with P-2-P. Despite the fact that the investment was supposedly "guaranteed," investors lost approximately $70 million as a result ofSMIRNOW'S actions. Smirnow's pathway to prosperity 4. The investigation ofP-2-P began when the Government received a referral from the Illinois Securities Department concerning an elderly Southern District of Illinois resident who had made a substantial investment in P-2-P.
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