Case 2:14-cr-00558-SDW Document 57 Filed 04/07/17 Page 1 of 23 PageID: 139

UNITED STATES DISTRICT COURT DISTRICT OF

UNITED STATES OF AMERICA

Criminal v. No. 14 558 (SDW) 18 u.s.c. §§ 371, 1519, 2 26 u.s.c. §§ 7206(2) MARC SORRENTINO and & 7201 31 U.S.C. § 5324(a} MICHAEL SORRENTINO, (3) a/k/a "The Situation"

SUPERSEDING INDICTMENT The Grand Jury in and for the District of New Jersey, sitting at Newark, charges:

COUNT 1 (Conspiracy to Defraud the United States) Parties and Entities 1. At all times relevant to this Superseding Indictment:

a. Defendant MARC SORRENTINO was a resident of Mon.mouth County, New Jersey, and received income. b. Defendant MICHAEL SORRENTINO, a/k/a "The Situation," was a resident of Monmouth and Ocean Counties, New Jersey, and was a personality who gained fa.me on the television show "The ," which first appeared on the MTV network in or around December 2009. Defendant MICHAEL SORRENTINO received income.

c. MPS Entertainment, LLC ("MPS") was a limited liability company existing under the laws of the State of New

endorsements endorsements

business, business,

featuring featuring

interest interest appearances appearances

defendants defendants

from from

Sources Sources

SORRENTINO's SORRENTINO's

engaged engaged

defendants defendants

Businesses") Businesses")

percent percent Investments, Investments,

around around

registered registered

capacity. capacity.

SORRENTINO SORRENTINO Jersey Jersey

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a a

variety variety

October October

of of

in in

that that

ownership ownership

in in

defendant defendant

publication publication

h. h.

g. g.

f. f.

MARC MARC

e. e.

d. d.

Income Income

MARC MARC

the the

a a

by by

with with

and and

of of

celebrity celebrity

was was

MPS, MPS,

were were

LLC, LLC,

vodka vodka

MPS, MPS,

Situation Situation

defendant defendant

of of

Situation Situation

Employee Employee

business business

products products

2010. 2010.

SORRENTINO SORRENTINO

MICHAEL MICHAEL

SORRENTINO SORRENTINO

the the

formed formed

sources, sources,

SitNat, SitNat,

additional additional

and and

interest interest

SitNat, SitNat,

MICHAEL MICHAEL

company, company,

State State

of of

GTL GTL

Defendant Defendant

status. status.

#1 #1

SORRENTINO SORRENTINO

of of

in in

such such

an an

MICHAEL MICHAEL Productions, Productions,

Nation, Nation,

and and

Management, Management,

of of

including including and and

was was

the the

or or exploiting exploiting

and/or and/or

SORRENTINO SORRENTINO

autobiography autobiography

in in

ownership ownership

as as

business business

New New

around around

the the

SitNat. SitNat.

MICHAEL MICHAEL

Other Other

employed employed

2 2

vitamins, vitamins,

MICHAEL MICHAEL

SORRENTINO, SORRENTINO,

Inc. Inc.

Jersey Jersey

Other Other

MICHAEL MICHAEL

held held

personal personal

Sorrentino Sorrentino

January January

Inc., Inc.,

defendant defendant

("SitNat") ("SitNat")

entities entities

as as

Inc. Inc.

of of

SORRENTINO SORRENTINO

by by

ownership ownership

Sorrentino Sorrentino

SORRENTINO SORRENTINO

that that

a a

and and

an an

DVDs, DVDs,

SORRENTINO. SORRENTINO.

MPS MPS

superhero, superhero,

Situation Situation

("Other ("Other

online online

a a

2010. 2010.

a a

was was

and and

partnership partnership

in in

established established

comic comic

Businesses, Businesses,

MICHAEL MICHAEL

clothing clothing

was was

television television received received formed formed

a a

interests interests

Businesses Businesses

Sorrentino Sorrentino

clothing clothing

held held

secretarial secretarial

Defendants Defendants

a a

book book Capital Capital

and and

corporation corporation

a a

in in

lines, lines,

100 100

income income

by by

or or

and and

in in

were were

MPS. MPS. MARC MARC

1065 1065

annually annually

Internal Internal

and and

taxpayer taxpayer

Individual Individual

for for

income income

citizen citizen

Taxes Taxes

SORRENTINO. SORRENTINO.

in in

contracted contracted

booking booking

including including

MICHAEL MICHAEL SORRENTINO SORRENTINO

approximately approximately

approximately approximately

defendants defendants jewelry, jewelry,

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cash cash

owing. owing.

a a

("Form ("Form

particular particular

and and

in in

and and

make make

Revenue Revenue

directly directly

reports reports

fees. fees.

SORRENTINO SORRENTINO

k. k.

excess excess

Tax Tax

j. j.

tuxedos, tuxedos,

nightclubs, nightclubs,

Income Income

1065"), 1065"),

i. i.

that that

to to

resident resident

MARC MARC

and and

MPS MPS

The The

Return Return

make make

December December

From From

$8.9 $8.9

Defendants Defendants

Code. Code.

a a

items items

tax tax

of of

file file

was was

SORRENTINO SORRENTINO

to to

Tax Tax

tax tax

substantial substantial

reporting, reporting,

and and

personal personal

the the entered entered

approximately approximately

million million

defendants defendants

year year

of of

Preparation Preparation

established established

Return, Return,

a a

laws laws

including including

bars, bars,

As As

sunglasses. sunglasses.

minimum minimum

the the

2012, 2012,

U.S. U.S.

to to

a a

MARC MARC

of of

United United into into

partnership, partnership,

in in

and and

and and

annually annually

appearances appearances

Return Return

Form Form

among among

defendants defendants

the the

portion portion

gross gross

MARC MARC

SORRENTINO SORRENTINO

3 3

filing filing

MICHAEL MICHAEL

income, income,

liquor liquor

numerous numerous

as as

United United

January January

1040 1040

States States

For For

other other

of of

a a

SORRENTINO SORRENTINO

income. income.

make make

partnership partnership

of of

amount amount

Partnership Partnership

tax tax

stores, stores,

{"Form {"Form

SORRENTINO SORRENTINO

deductions, deductions,

at at

MARC MARC

States States

MPS MPS

the the

who who

contracts contracts

items, items,

2010 2010

and and

and and

years years

various various

was was

booking booking

established established

receives receives

SORRENTINO SORRENTINO

MICHAEL MICHAEL

1040"), 1040"),

file file

through through

and/or and/or

in in

require require

its its

required required

2010 2010

under under

exchange exchange

Income, Income,

earned earned

venues, venues,

a a

for for

and and

ordinary ordinary

fee fee

U.S. U.S.

MICHAEL MICHAEL

through through

wherein wherein

SORRENTINO SORRENTINO

gross gross

MICHAEL MICHAEL

every every

the the

tax tax

and and

be be

by by

to to

Form Form

for for

paid paid

due due

law law

2012, 2012, a a

defendant defendant

business business

net net

net net

Instead, Instead,

income. income. determined determined

Corporation's Corporation's

Corporation, Corporation,

items, items,

to to

Internal Internal

respective respective

defendants defendants

business business

income income

owners owners

partnership partnership

income income

subtracting subtracting

business business business business

ae21-r058SW ouet5 Fld0/71 Page 4 of 23 PageID: 142 Filed 04/07/17 Document 57 Case 2:14-cr-00558-SDW

annually annually

business business

business business

its its

on on

of of

it it

income income

the the

An An

MICHAEL MICHAEL Revenue Revenue

income income

income income

income income

1. 1.

their their

may may

by by

the the

ordinary ordinary

MARC MARC

Forms Forms

S S

make make

income income

owner owner

income income

does does

its its

Form Form

Corporation Corporation

subtracting subtracting

net net

SitNat SitNat

partnership partnership

have have

incurred incurred

SORRENTINO SORRENTINO

incurred incurred

respective respective

as as total total

and and

Code. Code.

SORRENTINO SORRENTINO

1040. 1040.

("net ("net

not not

business business

1120S 1120S

of of

on on

it it

earned earned

business business

reported reported

file file

was was

the the

incur incur

his his

may may

deductions deductions

business business

As As

by by

("Form ("Form

established established

by by

S S

does does

its its

a a

Form Form

have have

are are

during during

income income

an an

SitNat SitNat

and and

Corporation Corporation

Forms Forms

any any

U.S. U.S.

on on

MPS MPS

on on

income income

total total

S S

required required

not not

1120S"), 1120S"),

his his

MICHAEL MICHAEL

1040. 1040.

earned earned

tax tax

the the

income"}. income"}.

Corporation, Corporation,

4 4

was was

Income Income

1040. 1040.

a a

as as

from from

was was

incur incur

Form Form

given given

deductions deductions

liability liability

Form Form

("net ("net

required required

reported reported

as as

Accordingly, Accordingly,

required required

during during

its its

SORRENTINO SORRENTINO

is is

to to

reporting, reporting,

Tax Tax

an an

1040. 1040.

Accordingly, Accordingly,

any any

1065 1065

tax tax

business business

required required

report report

A A

total total

S S

Return Return

tax tax

partnership's partnership's

SitNat SitNat

Corporation Corporation

to to

a a

year. year.

on on

for for

is is

from from

to to

given given

be be

liability liability

income. income. determined determined

the the

such such

any any

be be

on on

income"). income").

among among

for for

any any

reported reported

to to

its its

was was

Instead, Instead,

Form Form

reported reported

their their

any any

tax tax net net

report report net net

ans ans

net net

total total

required required

other other

under under

net net

year. year.

business business

A A

1120S 1120S

business business

for for

net net

by by

by by

such such

the the

An An

by by

any any

the the

is is S S

defendants defendants #1. #1.

for for

and and

2010 2010

elsewhere, elsewhere,

for for

Island, Island,

engaged engaged

"Accounting "Accounting

corporation. corporation.

Form Form

individual individual

required required

on on

income income

Forms Forms

above, above, MICHAEL MICHAEL

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MPS, MPS,

Gregg Gregg

that that

clients. clients.

and and

1099 1099

1040 1040

and and

New New

was was

the the

the the

2011, 2011,

income. income.

SORRENTINO, SORRENTINO,

Mark Mark

to to

p. p.

MARC MARC

is is

o. o.

was was

n. n.

m. m.

or or

assess assess

enable enable

York, York,

required required

Firm"). Firm").

services services

Form Form be be

generally generally

A A

Defendants Defendants

partnership partnership

prepared, prepared,

defendants defendants

employed employed

i. i.

Among Among

Any Any

SORRENTINO SORRENTINO

filed filed

Form Form

1120S 1120S

and and

and and

Coconspirator Coconspirator

the the

income income

1099 1099

other other

The The

to to

in in

of of

with with

was was

compute compute

Internal Internal

not not

for for

by by

be be

addition addition

a a

and and

Accounting Accounting

MARC MARC

MARC MARC

is is

in in

earned earned

certified certified

and and

in in

the the

the the

things, things, reported reported

required required

SitNat, SitNat,

caused caused

an an

the the

the the

SORRENTINO SORRENTINO

MICHAEL MICHAEL

IRS IRS

Accounting Accounting SORRENTINO SORRENTINO any any

Revenue Revenue

informational informational

5 5

#1, #1,

business business

by by

to to

course course

to to

taxes taxes

Forms Forms

and and

to to

net net

on on

public public defendants defendants

Firm Firm

for for

Gregg Gregg

report report

SORRENTINO, SORRENTINO,

be be

their their

the the

Service Service

business business

payments payments

of of

that that

1065, 1065,

had had

and and

prepared, prepared,

and and

Firm. Firm.

of of

Mark, Mark,

accounting accounting

a a

Forms Forms

payments payments

preparing preparing

respective respective

offices offices

MICHAEL MICHAEL

trade trade

may may

MICHAEL MICHAEL

form form

Forms Forms

MARC MARC

("IRS") ("IRS")

For For

charged charged

income income

made made

1040 1040

be be

and and

generally generally

or or

the the

SORRENTINO SORRENTINO

due due

1120S, 1120S,

tax tax

in in

SORRENTINO SORRENTINO

made made

SORRENTINO, SORRENTINO,

firm firm

business. business.

to to

Employee Employee

for for

tax tax

Forms Forms

to to

Forms Forms

described described

Staten Staten

and and

years years

a a

to to

identify identify

returns returns

(the (the

and and

owing owing

an an

1065 1065

1040. 1040.

and and A A

I I

Chase. Chase.

accounts, accounts,

various various

authority authority

SORRENTINO SORRENTINO

accounts accounts

authority authority

various various

SORRENTINO SORRENTINO

accounts accounts

maintained maintained

JPMorgan JPMorgan

bank bank

Bank Bank

SORRENTINO SORRENTINO

preparers preparers

the the and and

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MICHAEL MICHAEL

Form Form

accounts, accounts,

Accounts Accounts

Defendant Defendant

times, times,

times, times,

ending ending

ending ending

Chase Chase

1120S 1120S

including including

over over

t. t.

s. s.

over over

r. r.

q. q.

at at

maintained maintained

maintained maintained

sole sole

and and

SORRENTINO SORRENTINO

the the

The The

SitNat SitNat

MPS MPS

Defendant Defendant

defendant defendant

these these

defendant defendant

these these

Bank, Bank,

MICHAEL MICHAEL including including

for for

ii. ii.

-3078 -3078

signature signature

-9768 -9768

MICHAEL MICHAEL

Accounting Accounting

Other Other

maintained maintained

SitNat, SitNat,

accounts accounts

For For

accounts. accounts.

maintained maintained

accounts. accounts.

N.A. N.A.

signature signature

and and

signature signature

and and

SORRENTINO. SORRENTINO.

engaged engaged

Sorrentino Sorrentino

MICHAEL MICHAEL

tax tax

SORRENTINO SORRENTINO

MARC MARC

MARC MARC

accounts accounts

-0395 -0395

authority authority

-0799 -0799

("Chase"). ("Chase").

and and

year year Firm Firm

ending ending

business business

SORRENTINO SORRENTINO

SORRENTINO SORRENTINO

the the

the the

authority authority

business business

at at

authority authority

at at

SORRENTINO SORRENTINO

to to

2012, 2012,

ending ending

Businesses Businesses

Chase. Chase.

Chase. Chase.

Forms Forms

services services

maintained maintained

-3060, -3060,

over over

prepare prepare

bank bank

Defendant Defendant

defendants defendants

also also

bank bank

also also

these these

-7378 -7378

1040 1040

over over

over over

Defendant Defendant

-7295, -7295,

Defendant Defendant

accounts, accounts,

maintained maintained

of of

the the

maintained maintained

maintained maintained

accounts, accounts,

maintained maintained

for for

signature signature

these these

these these

accounts. accounts.

and and

other other

MICHAEL MICHAEL

Form Form

and and

defendants defendants

MARC MARC

-4910 -4910

MICHAEL MICHAEL

MICHAEL MICHAEL

accounts. accounts.

accounts. accounts.

including including

1065 1065

tax tax

-9910 -9910

personal personal

SORRENTINO SORRENTINO

including including

SORRENTINO SORRENTINO

authority authority

bank bank

signature signature

signature signature

at at

return return

for for

at at

MARC MARC

MPS, MPS,

At At At At

Grand Grand

and and

did did

New New

November November

other other

United United

the the

cash cash

Transaction Transaction

clothing. clothing.

bank bank

to to

and and

various various

SitNat, SitNat,

also also over over

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agree agree

unlawfully, unlawfully,

pay pay

Jersey Jersey

Financial Financial

MICHAEL MICHAEL

2. 2.

Jury, Jury,

exceeding exceeding

accounts accounts

purposes, purposes,

maintained maintained

these these

States States

for for

2013, 2013, bank bank

From From

and and

with with

v. v.

and and

u. u.

including including

personal personal

accounts. accounts.

Reports Reports

SORRENTINO SORRENTINO

the the

accounts accounts

in in

Department Department

Crimes Crimes

Financial Financial

each each

and and

elsewhere, elsewhere,

A A in in

$10,000, $10,000,

voluntarily, voluntarily,

tracking tracking

Other Other

portion portion

or or

signature signature

Monmouth Monmouth

used used

other other

around around

items, items,

("CTRs") ("CTRs")

Enforcement Enforcement

Gregg Gregg

a/k/a a/k/a

described described

Sorrentino Sorrentino

At At

MICHAEL MICHAEL

MARC MARC

the the

continually continually

including including

institutions institutions

of of

income income

of of

and and

defendants defendants

various various

The The

and and

January January

authority authority

Mark, Mark,

monies monies

such such

the the

Treasury, Treasury,

"The "The

intentionally intentionally

SORRENTINO SORRENTINO

for for

others, others,

Conspiracy Conspiracy

Ocean Ocean

SORRENTINO, SORRENTINO,

income income

and and

7 7

as as

above. above.

Situation," Situation,"

Network, Network,

monetary monetary

to to

Businesses Businesses

times, times,

deposits. deposits.

from from

2010 2010

high-end high-end

commingled commingled

assets. assets.

defraud defraud

Counties, Counties,

over over

are are

known known

and and

from from

and and

the the

through through

Defendants Defendants

defendant defendant

required required

these these

are are

a a

transactions transactions

and and

and and

business business

the the

bureau bureau

the the

luxury luxury

was was

CTRs CTRs

used used

knowingly knowingly

monies monies

in in

unknown unknown

operation operation

accounts. accounts.

in in

United United

deposited deposited

the the

are are

to to

or or

MARC MARC

within within

for, for,

vehicles vehicles

MARC MARC

bank bank

file file

among among

District District

around around

filed filed

involving involving

States States

to to

SORRENTINO SORRENTINO

among among

conspire conspire

SORRENTINO SORRENTINO

accounts accounts

of of

the the

Currency Currency

the the

into into

the the

with with

and and

MPS, MPS,

by by

of of the the

Accounting Accounting received received

MARC MARC

for for connection connection

MARC MARC

and and

million million

income income

SORRENTINO SORRENTINO

collection collection

Treasury, Treasury,

constituent constituent

obstruct, obstruct,

assessment, assessment,

Department Department

functions functions impeding, impeding,

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themselves themselves

incomplete incomplete

SORRENTINO SORRENTINO

6. 6.

SORRENTINO SORRENTINO

5. 5.

4. 4.

3. 3.

taxes taxes

in in

as as

It It

It It

It It

The The

Firm Firm

in in

and and

with with

of of

gross gross

impairing, impairing, and and

income income

of of

was was

was was

of of

was was

agency agency

and and

due due

the the

object object

the the

income income

defeat defeat

and and

information information

the the

MICHAEL MICHAEL

and and

and and

further further

the the

and and

further further

part part

Manner Manner

collection collection

and and

income income

ascertainment, ascertainment,

IRS, IRS,

from from

their their

Treasury, Treasury,

MICHAEL MICHAEL

report report

of of

Accounting Accounting

MICHAEL MICHAEL

of of

owing. owing.

of of

taxes. taxes.

the the

obstructing, obstructing,

Object Object

the the

a a

SORRENTINO SORRENTINO

promotional promotional

part part

the the

and and

part part

on on

the the

business business

constituent constituent

lawful lawful

United United to to

and and

which which

SORRENTINO SORRENTINO

conspiracy conspiracy

Means Means

of of

SORRENTINO SORRENTINO

conspiracy conspiracy

of of

in in

of of

of of

the the

Firm's Firm's

records records

income income

the the

the the

the the

the the

8 8

computation, computation,

functions functions

they they

States States IRS IRS

entities. entities.

of of

earned earned

and and

and and

conspiracy conspiracy

ascertainment, ascertainment,

conspiracy conspiracy

Conspiracy Conspiracy

the the

agency agency

all all

preparation preparation

taxes. taxes.

failed failed

did did

was was

provided provided

to to

defeating defeating

that that

business business

Department Department

Conspiracy Conspiracy

approximately approximately

of of

the the

not not

of of

to to

of of

defendants defendants

the the

to to

assessment, assessment,

the the

impede, impede,

Accounting Accounting

declare declare

that that

the the that that

false, false,

pay pay

activities. activities.

cash cash

the the

IRS, IRS,

of of

computation, computation,

United United

of of

defendants defendants

defendants defendants

all all

tax tax

lawful lawful

that that

impair, impair,

a a

the the to to

fraudulent, fraudulent,

MARC MARC

$8.9 $8.9

federal federal

returns returns

Firm Firm

and and

the the

States States

they they in in

MARC MARC

fraudulent fraudulent

filed, filed,

companies companies

SORRENTINO SORRENTINO

evidencing evidencing

SitNat SitNat

Forms Forms

Because Because

from from

MARC MARC

from from

that that

documenting documenting

issued issued

production production

SORRENTINO SORRENTINO

SORRENTINO SORRENTINO

requirements. requirements.

deposits deposits MICHAEL MICHAEL

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SORRENTINO SORRENTINO

9. 9.

one one

production production

SORRENTINO SORRENTINO

shortly shortly

1099, 1099, 8. 8.

7. 7.

with with

and and

IRS IRS

SitNat SitNat

It It

corporation corporation

SORRENTINO SORRENTINO

to to

Prior Prior

and and

It It

Forms Forms

did did

payments. payments.

therefore, therefore,

the the

was was

Forms Forms

be be

companies companies

and and

the the

the the

SitNat SitNat

was was

after after

attempted attempted

paid paid

not not

was was

and and IRS IRS

further further

MICHAEL MICHAEL

production production

to to

companies companies

and/or and/or

1120S 1120S

payments. payments.

further further

1099 1099

report report

in in

established established

SitNat SitNat

MICHAEL MICHAEL

a a

as as to to

structured, structured,

to to

false false

for for

Defendants Defendants

no no or or

for for

MPS, MPS,

to to

income. income.

MICHAEL MICHAEL

part part

SORRENTINO SORRENTINO

to to

another another

around around

Forms Forms

part part

MPS MPS

services services

all all

be be

was was

their their

evade evade

companies companies

and and

It It SORRENTINO SORRENTINO

whereupon whereupon

of of

made made

with with

of of

of of

was was

formed formed

1099 1099

as as

SORRENTINO SORRENTINO

fraudulent fraudulent

the the

October October

and and

do do

9 9

business business

MARC MARC

these these

bank bank

the the

an an

to to

a a

further further

performed performed

directed directed

not not

conspiracy conspiracy

were were

caused caused

copy copy

did did

conspiracy conspiracy

S S

SitNat SitNat

in in

the the

SORRENTINO SORRENTINO

currency currency

filed, filed,

payments payments

require require

Corporation, Corporation,

2010, 2010,

October October

sent sent not not

entities. entities.

production production

sent sent

directed directed

part part

Form Form

to to

that that

instead instead

by by

issue issue

and and

defendants defendants

be be

to to

to to

that that

reporting reporting

the the

of of

1065 1065

defendant defendant

from from

that that

2010, 2010,

payments payments

and and

structured, structured,

the the

the the

caused caused

the the

Forms Forms

issuance issuance

that that

defendants defendants

and and

of of

These These

and and

companies companies

production production

MICHAEL MICHAEL

IRS IRS defendant defendant

IRS IRS

defendants defendants

conspiracy conspiracy

MPS. MPS.

payments payments

payments payments

false false

to to

MARC MARC

1099 1099

MICHAEL MICHAEL

from from

tax tax

be be

of of

cash cash

to to and and

and and

SORRENTINO SORRENTINO

year year

to to

manipulated, manipulated,

defendant defendant

response response

about about

earning earning

file file

MICHAEL MICHAEL

report report

MARC MARC

tax tax

MARC MARC

filed, filed,

underreported underreported

SORRENTINO SORRENTINO

deductions, deductions,

gross gross returns returns

ae21-r058SW ouet5 Fld0/71 Page 10 of 23 PageID: 148 Filed 04/07/17 Document 57 Case 2:14-cr-00558-SDW

MPS MPS

records records

returns returns

2012. 2012.

12. 12.

a a

11. 11.

SORRENTINO SORRENTINO

SORRENTINO SORRENTINO

November November 10. 10.

and and

Form Form

receipts receipts

all all

with with

substantial substantial

SORRENTINO, SORRENTINO,

to to

were were

MARC MARC

It It

It It

manipulated, manipulated,

SitNat SitNat

It It

of of

to to

After After

federal federal and and

1040 1040

were were

books books

the the

was was

disguised disguised

was was

was was

false false

alter alter

the the

SORRENTINO SORRENTINO

net net

6, 6,

MICHAEL MICHAEL

of of

and and

IRS IRS

and and

further further

for for

further further

producing producing

false false

the the

further further

2013, 2013,

income income

and and

business business

the the

Grand Grand

and and

income, income,

and and

and and

MICHAEL MICHAEL

MICHAEL MICHAEL

false false

tax tax

Grand Grand

records records

businesses, businesses, income income

and and

and and

SORRENTINO SORRENTINO

through through

fraudulent fraudulent

Employee Employee

reclassify reclassify

part part

year year

part part

that that

part part

manipulated, manipulated,

Jury Jury

and and

caused caused

fraudulent fraudulent

Jury Jury

the the

income. income.

defendant defendant

SORRENTINO, SORRENTINO,

SORRENTINO SORRENTINO

payments payments

of of

2011. 2011.

of of

defendants defendants

fraudulent fraudulent

on on

of of

subpoenas subpoenas

books books

10 10

on on

subpoenas subpoenas

the the

the the

#1 #1

behalf behalf

the the

to to

and and or or

claimed claimed

in in

taxable taxable

received. received.

conspiracy conspiracy

conspiracy conspiracy

be be

and and

conspiracy conspiracy

about about

MICHAEL MICHAEL

that that

in in

and and

made made

to to

filed, filed,

manipulated, manipulated,

and and

of of

dated dated

MARC MARC

that that

Forms Forms records, records,

Employee Employee

were were

caused caused

fraudulent fraudulent

they they

payments payments

MPS MPS

November November

to to

Employee Employee

SORRENTINO SORRENTINO

SORRENTINO SORRENTINO

they they

and and

October October

defendants defendants

1040 1040

served, served,

and and

understated understated

that that

that, that,

that that

to to

defendant defendant

caused caused

#1, #1,

failed failed

SitNat SitNat

to to

for for

be be

13, 13,

from from

#1. #1.

these these

defendants defendants

business business

despite despite

and/or and/or

8, 8,

defendant defendant

but but

defendants defendants

2013, 2013,

did did

and and

to to

MARC MARC

2013, 2013,

on on

These These

to to

for for

books books

prior prior

the the

MARC MARC

be be

or or

not not

tax tax in in

accounts, accounts,

SORRENTINO SORRENTINO

Cash Cash

New New

commit commit

business business its its

ae21-r058SW ouet5 Fld0/71 Page 11 of 23 PageID: 149 Filed 04/07/17 Document 57 Case 2:14-cr-00558-SDW

14 14

14(p) 14(p)

14(0) 14(0)

14(n) 14(n)

14(m) 14(m)

14 14

14(j) 14(j) 14{k) 14{k)

14(i) 14(i)

14(h) 14(h)

14 14

14{f) 14{f)

14(e) 14(e)

14(c) 14(c) 14 14

14(b) 14(b)

..l..':t ..l..':t

1 1

Jersey Jersey

object, object,

A A

14. 14.

Deposits Deposits

(q) (q)

{l) {l)

13. 13.

(

SORRENTINO SORRENTINO

(d) (d)

I~\ I~\

\ \

g) g)

0. 0.

the the

J J

deductions. deductions.

and and

On On

In In

3/29/2011 3/29/2011

3/28/2011 3/28/2011

3/29/2011 3/29/2011

3/28/2011 3/28/2011

3/28/2011 3/28/2011

3/28/2011 3/28/2011

3/14/2011 3/14/2011

3/14/2011 3/14/2011

3/14/2011 3/14/2011

deposited, deposited,

and and

3/1/2011 3/1/2011

3/1/2011 3/1/2011

following following

1/5/2011 1/5/2011

3/1/2011 3/1/2011

3/1/2011 3/1/2011

1/5/2011 1/5/2011

1/4/2011 1/4/2011

1/4/2011 1/4/2011

defendants defendants

or or

furtherance furtherance

in in

elsewhere: elsewhere:

about about

as as

the the

non-taxable non-taxable

amounts, amounts,

overt overt

and and

Situation Situation

the the

Situation Situation

Situation Situation

Situation Situation

Situation Situation

MARC MARC

Michael Michael

Michael Michael

Michael Michael

Michael Michael

Michael Michael

Michael Michael

Michael Michael

MPS MPS

Situation Situation

Situation Situation

Situation Situation

Situation Situation

of of

dates dates

caused caused

acts, acts,

SORRENTINO SORRENTINO

Entertainment Entertainment

the the

Overt Overt

set set

payments payments

Sorrentino Sorrentino

Sorrentino Sorrentino

Sorrentino Sorrentino

Sorrentino Sorrentino

Sorrentino Sorrentino

Sorrentino Sorrentino

Sorrentino Sorrentino

listed listed

conspiracy conspiracy

Productions Productions

11 11

Productions Productions

Productions Productions

Productions Productions

Productions Productions

among among

to to

forth forth

Acts Acts

Nation Nation

Nation Nation

Nation Nation

Nation Nation

be be

below, below,

deposited, deposited,

others, others,

and and

below: below:

to to

MICHAEL MICHAEL

and and

him him

defendant defendant

4910 4910

7378 7378

3078 3078

7378 7378

3060 3060

4910 4910

3078 3078

3060 3060

4910 4910

9768 9768

7378 7378 4910 4910

3060 3060

3078 3078

3060 3060

3060 3060

3078 3078

in in

in in

and and

cash cash

order order

the the

SORRENTINO SORRENTINO

as as

District District

legitimate legitimate

$ $

$ $

$ $

$ $

$ $

$ $

$ $

$ $

$ $

$ $

$ $

$ $

$ $

$ $

into into

$ $

:;, :;,

$ $

......

MICHAEL MICHAEL

to to

1,100.00 1,100.00

7,000.00 7,000.00

8,000.00 8,000.00

9,900.00 9,900.00 2,100.00 2,100.00

2,000.00 2,000.00

9,987.00 9,987.00

2,000.00 2,000.00

9,500.00 9,500.00

2,000.00 2,000.00

2,000.00 2,000.00

3,500.00 3,500.00

8,880.00 8,880.00

3,500.00 3,500.00

5,000.00 5,000.00

4,500.00 4,500.00

4,500.00

effect effect

the the

did did of of

' '

. .

filed, filed,

Form Form

filed, filed,

Form Form

filed, filed,

MICHAEL MICHAEL

false false Tax Tax

ae21-r058SW ouet5 Fld0/71 Page 12 of 23 PageID: 150 Filed 04/07/17 Document 57 Case 2:14-cr-00558-SDW

14(ff) 14(ff)

14(ee) 14(ee)

14 14

14(cc) 14(cc)

14(bb) 14(bb)

14(aa) 14(aa)

Rumber Rumber

14(z) 14(z)

14 14

14 14

14 14

14 14

14 14

Year Year 14(t) 14(t)

14(s) 14(s)

14(r) 14(r)

Overt Overt

18. 18.

1040 1040

17. 17.

1040 1040

16. 16.

15. 15.

Act Act

(dd) (dd)

and and

(y) (y)

(x) (x)

(w) (w)

(v) (v)

and and

(u) (u)

and and

and and

SORRENTINO SORRENTINO

2010 2010

On On

on on

On On

on on

On On

fraudulent fraudulent

On On

caused caused

caused caused

caused caused

12

12/6/2012 12/6/2012

12/5/2012 12/5/2012

12/5/2012 12/5/2012

12/5/2012 12/5/2012

12/5/2012 12/5/2012

9/21/2011 9/21/2011

9

9

9/21/2011 9/21/2011

8/20/2011 8/20/2011

8/19/2011 8/19/2011

8

8/19/2011 8/19/2011

3/29/2011 3/29/2011

or or

his his

or or /

/ behalf behalf

Depoait Depoait

Date Date

/ or or

or or

/

21/2011 21/2011

21/2011 21/2011

19/2011 19/2011

6/2012 6/2012

about about

about about

about about

about about

behalf behalf

to to

to to

of of

to to

filed, filed,

of of

be be

be be

be be

Form Form

Situation Situation

July July

July July

June June

July July

Employee Employee

Situation Situation

Situation Situation

Situation Situation

Situation Situation

filed, filed,

for for

filed, filed,

filed, filed,

Michael Michael

Michael Michael

MPS MPS

MPS MPS

MPS MPS

Situation Situation

Situation Situation

Situation Situation

Situation Situation

1065 1065

and and

GTL GTL

5, 5,

5, 5,

21, 21,

5, 5,

tax tax

Account Account

Entertainment Entertainment

Entertainment Entertainment

Entertainment Entertainment

2011, 2011,

2011, 2011,

caused caused

2011, 2011,

Management Management

with with

with with

with with

2011, 2011,

on on

Capital Capital

year year

#1 #1

12 12

Sorrentino Sorrentino

Sorrentino Sorrentino

Productions Productions

Productions Productions

Productions Productions

Productions Productions

behalf behalf

for for

Nation Nation

Nation Nation

Nation Nation

Nation Nation

defendant defendant

the the

defendant defendant Name Name

the the

the the

defendants defendants

2010. 2010.

defendant defendant

to to

tax tax

Invst. Invst.

IRS IRS

IRS IRS

IRS IRS

be be

of of

year year

filed, filed,

a a

a a

a a

MPS MPS

MICHAEL MICHAEL

false false

MARC MARC

false false

false false

Account Account

Bnding Bnding NUmber NUmber

MARC MARC

MARC MARC

3078 3078

7378 7378

7295 7295 4910 4910

3060 3060

3078 3078

9910 9910

3078 3078

0395 0395 9768 9768

3060 3060

9768 9768

9768 9768

3060 3060

3060 3060

2010. 2010.

for for

with with

SORRENTINO SORRENTINO

and and

and and

and and

SORRENTINO SORRENTINO

tax tax

SORRENTINO SORRENTINO

SORRENTINO SORRENTINO

Amount Amount

the the

$ $

$ $

$ $

fraudulent fraudulent $ $

$ $

$ $

$ $

$ $

fraudulent fraudulent

$ $

$ $

$ $

$ $

year year

$ $

fraudulent fraudulent

$ $ $1,000.00 $1,000.00

4,178.75 4,178.75

Depoait Depoait

9,000.00 9,000.00

2,161.92 2,161.92

2,161.94 2,161.94

2,161.92 2,161.92

1,513.60 1,513.60

2,000.00 2,000.00

4,393.32 4,393.32

4,724

9,448.10 9,448.10

2,800.00 2,800.00

4,000.00 4,000.00

5,500.00 5,500.00

IRS IRS

80.00 80.00

of of

2010. 2010.

.

a a

and and

00 00 caah caah

SORRENTINO SORRENTINO

Form Form

filed, filed,

with with

for for

SORRENTINO SORRENTINO

and and

connection connection

incomplete incomplete

2013, 2013,

Tax Tax

Form Form

filed, filed,

with with

for for

SORRENTINO SORRENTINO

Tax Tax Form Form

ae21-r058SW ouet5 Fld0/71 Page 13 of 23 PageID: 151 Filed 04/07/17 Document 57 Case 2:14-cr-00558-SDW

tax tax

a a

24. 24. Year Year

1040 1040

23. 23.

tax tax the the

22. 22.

Year Year

21. 21.

1040 1040

20. 20.

the the

19. 19.

Form Form

1040 1040

defendant defendant

and and

and and

year year

year year

IRS IRS

On On

2012 2012

on on

On On

IRS IRS

On On

2011 2011

On On

filed, filed,

on on

caused caused

On On

and and

On On

1120S 1120S

with with

on on

information information

caused caused

and and

or or

his his

or or

2012. 2012.

a a

or or

or or

his his

or or

2011. 2011.

a a

or or

his his

MICHAEL MICHAEL

false false

about about

about about

MICHAEL MICHAEL

false false

about about

MARC MARC

the the

about about

behalf behalf

about about

about about

for for

and and

behalf behalf

to to

behalf behalf

to to

Accounting Accounting

be be

and and

their their

SORRENTINO SORRENTINO

caused caused

September September

be be

April April

and and

September September

July July

August August

SORRENTINO SORRENTINO

February February

and and

for for

filed, filed,

SORRENTINO SORRENTINO

for for

filed, filed,

fraudulent fraudulent

for for

fraudulent fraudulent

business business

records records

15, 15,

tax tax

15, 15,

to to

tax tax

tax tax

23, 23,

with with

Firm's Firm's

be be

2013 2013

with with 13, 13,

year year

2013, 2013,

13 13

26, 26,

13, 13,

provided provided

year year

year year

2012, 2012,

filed, filed,

filed, filed,

filed, filed,

to to

2013, 2013,

the the

Form Form

2013, 2013,

2013, 2013,

entities entities

through through

2012. 2012.

the the

Form Form

2011. 2011.

defendant defendant

preparation preparation

2010. 2010.

the the

defendant defendant

IRS IRS

IRS IRS

1120S 1120S

and and

false, false,

with with

defendant defendant

1120S 1120S

and and

defendants defendants

defendants defendants

Accounting Accounting

a a

on on

a a

caused caused

for for

false false

caused caused

the the

false false

on on

or or

MARC MARC

on on

fraudulent, fraudulent,

tax tax

MARC MARC

behalf behalf

of of

about about

IRS IRS

behalf behalf

MICHAEL MICHAEL

and and

to to

and and

SORRENTINO SORRENTINO

MARC MARC

to to

MARC MARC

year year

a a

Firm Firm

a a

SORRENTINO SORRENTINO

be be

Form Form

be be

fraudulent fraudulent

August August

false false

fraudulent fraudulent

of of

of of

filed, filed,

2012. 2012.

in in

filed, filed,

SitNat SitNat

1065 1065

and and

SitNat SitNat

and and 1, 1,

371. 371.

defendant defendant

legitimate legitimate

causing causing

SitNat SitNat

caused caused November November dated dated fraudulent fraudulent

ae21-r058SW ouet5 Fld0/71 Page 14 of 23 PageID: 152 Filed 04/07/17 Document 57 Case 2:14-cr-00558-SDW

All All

25. 25.

October October

for for

to to

to to

in in

13, 13,

MARC MARC

be be

On On

business business

be be

tax tax

Form Form

violation violation

manipulated manipulated

or or

2013, 2013,

altered altered

8, 8,

SORRENTINO SORRENTINO year year

about about

1040 1040

2013, 2013,

in in

deductions. deductions.

2012 2012

on on

of of

and and

November November

response response

defendant defendant

his his

Title Title

by by

books books

as as

reclassified, reclassified,

altering altering

behalf behalf

non-taxable non-taxable

18, 18,

and and

to to

6, 6,

14 14

MARC MARC

2013, 2013,

federal federal

United United

records records

for for

and and

SORRENTINO SORRENTINO

tax tax

taxable taxable

through through

payments payments

reclassifying, reclassifying,

States States

Grand Grand

on on

year year

behalf behalf

payments payments

Jury Jury

on on

2012. 2012.

Code, Code,

manipulated manipulated

to to

or or

him him

of of

subpoenas subpoenas

about about

Section Section

MPS MPS

and and

and and

to to

and and

as as and and Case 2:14-cr-00558-SDW Document 57 Filed 04/07/17 Page 15 of 23 PageID: 153

(Structuring to Evade Currency Transaction Reports)

1. Paragraph 1 of Count 1 of this Superseding Indictment is hereby realleged and incorporated as if set forth in full herein.

2. On or about the dates set forth below, in the District

of New Jersey and elsewhere, defendant

MICHAEL SORRENTINO, a/k/a "The Situation,"

did knowingly and for the purpose of evading the reporting

requirements of section 5313(a) of Title 31, United States Code, and the regulations promulgated thereunder, structure, assist in structuring, and attempt to structure and assist in structuring,

the following transactions with a domestic financial institution, JPMorgan Chase Bank, N.A., and did so while violating another law

of the United States and as part of a pattern of illegal activity

involving more than $100,000 in a 12-month period:

Account Date of NWl.ber Allount of Caab Depoait Account Bame Bnding Depoait 1/4/2011 Situation Nation 3078 $ 4,500.00 1/4/2011 Situation Productions 3060 $ 4,500.00 1/5/2011 Situation Productions 3060 $ 3,500.00 1/5/2011 Situation Nation 3078 $ 3,500.00

In violation of Title 31, United States Code, Sections

5324(a) (3) and 5324(d); Title 31, Code of Federal Regulations, Sections 103.11, 103.22; and Title 18, United States Code, Section 2.

15

States States

Sections Sections

5324(a) 5324(a)

of of

JPMorgan JPMorgan

the the structuring, structuring,

and and

requirements requirements

did did

of of

hereby hereby

12/6/2012 12/6/2012

12/6/2012 12/6/2012

12/5/2012 12/5/2012

12/5/2012 12/5/2012

12/5/2012 12/5/2012 12/5/2012 12/5/2012

ae21-r058SW ouet5 Fld0/71 Page 16 of 23 PageID: 154 Filed 04/07/17 Document 57 Case 2:14-cr-00558-SDW

Depoait Depoait

D&t D&t

the the

New New

following following

the the

knowingly knowingly

In In

2. 2.

1. 1.

Code, Code,

(3) (3)

United United

of of

violation violation

Jersey Jersey

realleged realleged

regulations regulations

1010.100, 1010.100,

Chase Chase

(Structuring (Structuring

and and

On On

Paragraph Paragraph

Section Section

and and

of of

or or

States: States:

transactions transactions

and and

5324(d); 5324(d);

and and

Situation Situation

Bank, Bank,

Michael Michael

Michael Michael

section section

about about

attempt attempt

Situation Situation

of of

Situation Situation

and and

1010.311, 1010.311,

GTL GTL

for for

elsewhere, elsewhere,

Account._ Account._

promulgated promulgated

2. 2.

Title Title

1 1

N.A., N.A.,

incorporated incorporated

to to

Management Management

the the

the the

of of

a/k/a a/k/a

Title Title

Sorrentino Sorrentino

5313(a) 5313(a)

MICHAEL MICHAEL Sorrentino Sorrentino

Evade Evade

Productions Productions

to to

Count Count

purpose purpose

31, 31,

dates dates

and and

with with

Nation Nation

Nation Nation

structure structure

and and

"The "The

31, 31,

defendant defendant

United United

Currency Currency

COUNT COUNT

did did

16 16

1 1

a a

of of

thereunder, thereunder,

1010.313; 1010.313;

SORRENTINO, SORRENTINO,

set set

Code Code

of of

Situation," Situation,"

domestic domestic

of of

as as

so so

Title Title

forth forth

this this

3 3

evading evading

States States

if if

while while

and and

of of

Transaction Transaction

set set

31, 31,

Federal Federal

Superseding Superseding Account Account

assist assist 11\mber 11\mber

Snding Snding

and and

below, below,

3078 3078

7378 7378

7295 7295 4910 4910

financial financial

3060 3060

3078 3078

violating violating

structure, structure,

Code, Code,

forth forth

United United

the the

Title Title

in in

reporting reporting

Regulations, Regulations,

in in

Sections Sections

in in

AIIIOWlt AIIIOWlt

Reports) Reports)

structuring, structuring,

States States

18, 18,

the the

institution, institution,

$ $ $ $

$ $

$ $ $ $

$1,513.60 $1,513.60

full full

Indictment Indictment

another another

Depoait Depoait

assist assist

4,178.75 4,178.75

2,161.92 2,161.92

9,000.00 9,000.00

2,161.94 2,161.94 2,161.92 2,161.92

United United

District District

of of

herein. herein.

Code, Code,

Caah Caah

law law

in in is is

and and

follows: follows: and and

as as

hereinafter hereinafter

preparation preparation

willfully willfully

tax tax

New New

Count Count hereby hereby

ae21-r058SW ouet5 Fld0/71 Page 17 of 23 PageID: 155 Filed 04/07/17 Document 57 Case 2:14-cr-00558-SDW

4 4

to to

mischaracterized mischaracterized

fraudulently fraudulently

returns returns

Jersey Jersey

2. 2.

1. 1.

material material

Defendant(&) Defendant(&)

realleged realleged

SORRENTINO SORRENTINO

SORRENTINO SORRENTINO

MICHAEL MICHAEL

On On

Paragraph Paragraph

aid aid

(Aiding (Aiding

MARC MARC

and and

specified. specified.

identified identified

and and

or or

& &

and and

matters matters

elsewhere, elsewhere,

about about

presentation presentation

a) a)

and and

in in

assist assist

1 1

underreported underreported

'l'ax 'l'ax

deductions, deductions,

the the

MPS MPS

the the

of of

incorporated incorporated

as as

below below

1065 1065

The The

Count Count

Return Return

Preparation Preparation

in, in,

dates dates

Form Form

herein herein

the the

COUNTS COUNTS

tax tax

for for

and and

to to

defendants defendants

1 1

set set

17 17

Year Year

returns returns

2010 2010

the the

of of

'l'ax 'l'ax

and and

specified specified

procure, procure,

the the

gross gross

as as

- 4

forth forth

this this

Internal Internal

c) c)

of of

taxpayers taxpayers

if if

Approximate Approximate Date Date

12 12

July July

underreported underreported

False False

receipts, receipts, were were

set set

Superseding Superseding

riled riled

2011 2011 below, below,

set set

counsel, counsel,

Return Return

in in

forth forth

5, 5,

Revenue Revenue

false false

forth forth

Tax Tax

that that

and and

in in

b) b) Returns) Returns)

b. b.

a

in in

and and

they they

ralae ralae

calendar calendar

and and below, below,

the the

. .

Indictment Indictment

business business

ordinary ordinary

$501,639 $501,639

Line Line

income income

deductions deductions

other other

Line Line $681,861 $681,861

overstated overstated

Service, Service,

full full

Natter(&) Natter(&)

income income

fraudulent fraudulent

advise advise

District District

falsely falsely

Material Material

22, 22,

20, 20,

did did

herein. herein.

of of

years years

as as

the the

the the

is is

of of of of Count Count

ae21-r058SW ouet5 Fld0/71 Page 18 of 23 PageID: 156 Filed 04/07/17 Document 57 Case 2:14-cr-00558-SDW

9 9

8 8

7 7

6 6

5 5

SORRENTINO SORRENTINO

SORRENTINO SORRENTINO

Defendant<•> Defendant<•>

SORRENTINO SORRENTINO

SORRENTINO SORRENTINO

SORRENTINO SORRENTINO

SORRENTINO SORRENTINO

MICHAEL MICHAEL

MICHAEL MICHAEL

MARC MARC

MARC MARC

MARC MARC

MARC MARC

& &

Sorrentino Sorrentino

Form Form

Form Form

Sorrentino Sorrentino

Situation Situation

Tax Tax

Sorrentino Sorrentino

Form Form

Form Form

Employee Employee

#1 #1

Michael Michael

Nation Nation

Marc Marc

1040 1040

Marc Marc

Form Form

Return Return

1120S 1120S

1040 1040

1040 1040

1040 1040

18 18

2011 2011

2011 2011

2010 2010

2010 2010

Year Year

2010 2010

Tax Tax

August August

Approximate Approximate

Date Date

February February

26, 26,

June June

July July

July July

2012 2012

Filed Filed

2011 2011

2011 2011

2011 2011

2013 2013

Return Return

21, 21,

23, 23,

5, 5,

5, 5,

a. a.

d. d.

c. c.

b. b.

a. a.

a. a.

b. b.

a

b. b.

a. a.

False False

. .

of of

Line Line

business business total total

-$5,714 -$5,714

ordinary ordinary

income income Line Line

Statement Statement

deductions deductions

$2,129,130 $2,129,130 other other

Line Line

gross gross

receipts receipts $3,055,541 $3,055,541

Line Line

of of

Line Line

total total of of

Line Line

partnership partnership

total total

$201,659 $201,659

income income Line Line

of of

-$6,337 -$6,337

Line Line

total total partnership partnership

$299,980 $299,980

income income Line Line

Matter<•> Matter<•>

$64,907 $64,907

16,465 16,465

$218,068 $218,068

22, 22,

21, 21,

19, 19, Material Material

lb, lb,

22, 22,

22, 22,

17, 17,

22, 22,

income income

17, 17,

income income

income income

income income

of of

of of

of of

of of

2 2 of of

' '

• •

' '

.

. .

' '

In In Count Count

ae21-r058SW ouet5 Fld0/71 Page 19 of 23 PageID: 157 Filed 04/07/17 Document 57 Case 2:14-cr-00558-SDW

12 12

11 11

violation violation

10 10

SORRENTINO SORRENTINO

Defendant(•) Defendant(•)

SORRENTINO SORRENTINO

SORRENTINO SORRENTINO

SORRENTINO SORRENTINO

MICHAEL MICHAEL

MICHAEL MICHAEL

MARC MARC

MARC MARC

of of

Title Title

& &

Sorrentino Sorrentino

Sorrentino Sorrentino

Form Form

Tax Tax Form Form

Form Form

26, 26,

Situation Situation

Michael Michael

Nation Nation

Marc Marc

Return Return

United United

1120S 1120S

1040 1040

1040 1040

19 19

2012 2012

2012 2012

States States

Year Year

2012 2012

Tax Tax

Approximate Approximate

Date Date

September September

April April

September September

13, 13,

Code, Code,

13, 13,

riled riled

2013 2013

Return Return

2013 2013

2013 2013

15, 15,

Section Section

b. b.

a. a.

a. a.

b. b.

a. a.

ralae ralae

of of

Line Line

total total

partnership partnership

$108,475 $108,475 corporation corporation

and and income income

Line Line

of of

Line Line

total total

business business

$89,955 $89,955

ordinary ordinary income income

Line Line

gross gross

receipts receipts

Line Line

$450,000 $450,000

7206(2). 7206(2).

Matter<•> Matter<•>

$108,475 $108,475

$10,313 $10,313

S S

Material Material

22, 22,

17, 17,

22, 22,

21, 21,

la, la,

income income

income income

of of

of of of of

cash cash

filed filed

to to

2011, 2011,

owing owing

attempted attempted

2013, 2013,

from from

Internal Internal

of of

before before

foregoing foregoing

tax tax SORRENTINO SORRENTINO hereby hereby

ae21-r058SW ouet5 Fld0/71 Page 20 of 23 PageID: 158 Filed 04/07/17 Document 57 Case 2:14-cr-00558-SDW

conceal conceal

the the

due due

into into

on on

a a

by by

2. 2.

by by

1. 1.

in in

April April

Internal Internal

false false

realleged realleged

or or

and and

committing committing

him him

the the

Revenue Revenue

the the

During During

Paragraph Paragraph

to to

facts facts

his his

about about

received received

owing owing

evade evade

to to

District District

17, 17,

accounts accounts

2011 2011

income, income,

the the

Revenue Revenue

and and

the the

January January

Service, Service,

2012, 2012,

and and

to to

Form Form

and and

1 1

United United

the the

failing failing

taxable taxable

calendar calendar

the the

of of incorporated incorporated

of of

and and

a/k/a a/k/a

among among

defeat defeat

as as

1065 1065

following following

MICHAEL MICHAEL

Service, Service,

Count Count

New New

4, 4,

United United

defendant defendant

required required

in in

States States

2011 2011

(Tax (Tax

to to

income, income,

others, others,

for for

"The "The

Jersey Jersey

year year

the the

a a

COUNT COUNT

1 1

make make

20 20

substantial substantial

SORRENTINO, SORRENTINO,

States States

Situation Situation

of of

Evasion) Evasion)

through through

and and

amounts amounts Situation," Situation,"

affirmative affirmative

of of

2011, 2011,

as as

by by

this this

and and

13 13

an an

upon upon

of of

America, America,

to to

if if

law, law,

income income

of of

filing filing

elsewhere, elsewhere,

pay pay

defendant defendant

set set

Superseding Superseding

on on

which which

set set

America. America.

Nation Nation

to to

income income

or or

the the

forth forth

forth forth

acts acts

for for

any any

tax tax

and and

about about

there there

income income

and and

calendar calendar

proper proper

return return

MICHAEL MICHAEL

in in

causing causing

in in

willfully willfully

tax tax

below: below:

Knowing Knowing

Indictment Indictment

February February

was was

depositing depositing

full full

an an

due due

tax tax

attempt attempt

officer officer

on on

income income

herein. herein.

to to year year

and and

to to

or or

of of

be be

26, 26,

the the

the the is is

\ \

.. ..

' '

. .

. .

and and

2 ( ( 2

2 2

2 2

2 2

2 2

2 2

2 ( ( 2

2 2

2 ( ( 2 2 2

2 2

2(o) 2(o)

2 2

2 2

2 ( ( 2

2 2

2 ( ( 2

2 ( ( 2

2 2

2 2

2 2

2 2

2 2

2 ( ( 2

2 2 2 2

~firmativ• ~firmativ•

(y) (y)

ActNmllber ActNmllber (x) (x)

(w) (w)

(v) (v)

(u) (u)

(s) (s)

(q) (q)

(p) (p)

(n) (n)

(m) (m)

(k) (k)

(h) (h)

z) z)

(g) (g)

( (

(e) (e) (d) (d)

ae21-r058SW ouet5 Fld0/71 Page 21 of 23 PageID: 159 Filed 04/07/17 Document 57 Case 2:14-cr-00558-SDW

(b) (b)

t) t)

r) r) (a) (a)

1) 1)

i) i) j) j)

f) f)

c) c)

Title Title

In In

violation violation

18, 18,

9/21/2011 9/21/2011

9/21/2011 9/21/2011

9/21/2011 9/21/2011 9/21/2011 9/21/2011

8/20/2011 8/20/2011

8/19/2011 8/19/2011

8/19/2011 8/19/2011

8/19/2011 8/19/2011

3/29/2011 3/29/2011

3/29/2011 3/29/2011

3

3/28/2011 3/28/2011

3/28/2011 3/28/2011

3/28/2011 3/28/2011 3/28/2011 3/28/2011

3/14/2011 3/14/2011

3/14/2011 3/14/2011

3/14/2011 3/14/2011

3/1/2011 3/1/2011

3/1/2011 3/1/2011

3/1/2011 3/1/2011

1/5/2011 1/5/2011

3/1/2011 3/1/2011

1/5/2011 1/5/2011

1/4/2011 1/4/2011

1/4/2011 1/4/2011

/2

Depo•it Depo•it United United

Date Date

9

/

2011 2011

of of

of of

States States Title Title

~PS ~PS

Situation Situation

~PS ~PS

Situation Situation Investments Investments

~PS ~PS

Situation Situation

~ichael ~ichael

!Michael !Michael Situation Situation

!Michael !Michael

Situation Situation

Situation Situation

~ichael ~ichael

Situation Situation

Situation Situation

Situation Situation Michael Michael

MPS MPS

Situation Situation Michael Michael

Michael Michael

Situation Situation

Situation Situation

Situation Situation

Situation Situation

Situation Situation

Entertainment Entertainment

Entertainment Entertainment

Entertainment Entertainment

Entertainment Entertainment

26, 26,

Account Account

Code, Code,

Sorrentino Sorrentino

Sorrentino Sorrentino

Sorrentino Sorrentino

Sorrentino Sorrentino

Sorrentino Sorrentino

Sorrentino Sorrentino

Sorrentino Sorrentino

United United

Nation Nation Capital Capital

Nation Nation

Productions Productions

Nation Nation

Productions Productions

Productions Productions

21 21 Nation Nation

Productions Productions

Productions Productions

Nation Nation

Productions Productions

Nation Nation

Productions Productions

Productions Productions

Section Section

Name Name

States States

2. 2.

9910 9910 3078 3078

0395 0395

3060 3060 9768 9768

9768 9768

3060 3060 9768 9768

3060 3060

3078 3078

4910 4910

7378 7378

4910 4910

3060 3060

3078 3078

7378 7378

4910 4910

3060 3060

9768 9768

7378 7378

4910 4910

3060 3060 3078 3078

3060 3060

3060 3060

3078 3078

Code, Code,

Account Account

Bnding Bnding

IJUmber IJUmber

Section Section

$ $

$ $

$ $

$ $

$ $

$ $

$ $

C&•h C&•h

$ $

$ $

$ $

$ $

$ $

$ $

$ $

$ $

$ $

$ $ $ $

$ $

$ $

$ $

$ $

$ $

$ $

$ $ $ $

Amount Amount

2,000.00 2,000.00

4,393.32 4,393.32 4,724.00 4,724.00

9,448.10 9,448.10

2,800.00 2,800.00

4,000.00 4,000.00

1,000.00 1,000.00 5,500.00 5,500.00

1,100.00 1,100.00

7,000.00 7,000.00

8,000.00 8,000.00

9,900.00 9,900.00

9,987.00 9,987.00

9,500.00 9,500.00

2,000

2,000.00 2,000.00

8,880.00 8,880.00

2,100.00 2,100.00

2,000.00 2,000.00

2,000

5,000.00 5,000.00 3,500.00 3,500.00

3,500.00 3,500.00

4,500.00 4,500.00

4,500.00 4,500.00

7201, 7201,

80.00 80.00

Depo•it Depo•it

.

.

00 00

00 00 of of Case 2:14-cr-00558-SDW Document 57 Filed 04/07/17 Page 22 of 23 PageID: 160

14 (Falsification of Records)

1. Paragraph 1 of Count 1 of this Superseding Indictment is hereby realleged and incorporated as if set forth in full herein.

2. On or about November 6, 2013, through on or about

November 13, 2013, in the District of New Jersey and elsewhere, defendant

MARC SORRENTINO did knowingly alter, destroy, mutilate, conceal, cover up, falsify, and make false entries in a record, document, and tangible object with the intent to impede, obstruct, and influence an investigation and the proper administration of a federal grand jury in the District of New Jersey, a matter that the defendant knew was within jurisdiction of a department and agency United States. In violation of Title 18, United States Code, Sections 1519 and 2.

&ILI/ 1 I

Acting United States Attorney

22 CASE NUMBER: 14-558 (SOW) ae21-r058SW ouet5 Fld0/71 Page 23 of PageID: 161 Filed 04/07/17 Document 57 Case 2:14-cr-00558-SDW

United States District Court District of New Jersey

UNJ:TBD STATES OF AMBRXCA

v.

MARC SORRDl'l'J:NO and MICHA.BL SORRDl'l'J:NO, a/k/a The Situation•

SUPBRSBD:I.NG J:NDJ:C'l'NBNT FOR

18 u.s .c . §§ 371, 1519 & 2 26 u.s .c . §§ 7206(2) & 7201 21 u.s .c. § 5324(a) (3)·

A 'l'...-11 'R i 1 1.

WILLIAM E . FITZPATRICK ACTING U . S . ATroRJ.'\/EY

NEWARK I NEW JERSEY

JONATHAN W. ROMANKOW AsSISTANr U . S . ATI'ORNEY 973-645-2740 :J d USA-48AD 8 (Ed. 1/97)