Case 2:14-cr-00558-SDW Document 57 Filed 04/07/17 Page 1 of 23 PageID: 139
UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY
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 reality television personality who gained fa.me on the television show "The Jersey Shore," 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
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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)