Case 1:18-cr-00509-GBD Document 791 Filed 06/11/19 Page 1 of 6
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
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`X
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`UNITED STATES OF AMERICA
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`- V.
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`-
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`SUPERSEDING INFORMATION
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`AZIZA JALOLOVA,
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`SB 18 Cr. 509
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`(GBD)
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`Defendant.
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`X
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`COUNT ONE
`(Conspiracy to Commit Wire Fraud)
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`The United States Attorney charges:
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`1.
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`From at least in or about November 2016, up to and
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`including in or about July 2018, in the Southern District of New
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`York and elsewhere, AZIZA JALOLOVA, the defendant, and others known
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`and unknown, willfully and knowingly, did combine, conspire,
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`confederate, and agree together and with each other to commit wire
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`fraud, in violation of Title 18, United States Code, Section 1343.
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`2.
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`It was a part and object of the conspiracy that AZIZA
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`JALOLOVA,
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`the defendant, and others known and unknown, willfully
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`and knowingly, having devised and intending to devise a scheme and
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`artifice to defraud and for obtaining money and property by means
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`of false and fraudulent pretenses, representations, and promises,
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`would and did transmit and cause to be transmitted by means of wire,
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`radio, and
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`television communication
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`in interstate and foreign
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`commerce, writings, signs, signals, pictures, and sounds for the
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`Case 1:18-cr-00509-GBD Document 791 Filed 06/11/19 Page 2 of 6
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`purpose of executing such scheme and artifice, in violation of Title
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`18, United States Code, Section 1343.
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`(Title 18, United States Code, Section 1349.)
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`COUNT TWO
`{Wire Fraud)
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`The United States Attorney further charges:
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`3.
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`From at least in or about November 2016, up to and
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`including in or about July 2018, in the Southern District of New
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`York and elsewhere, AZIZA JALOLOVA,
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`the defendant, willfully and
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`knowingly, having devised and intending to devise a scheme and
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`artifice to defraud, and for obtaining money and property by means
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`of false and fraudulent pretenses, representations, and promises,
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`did transmit and cause to be transmitted by means of wire, radio,
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`and television communication in interstate and foreign commerce,
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`writings, signs, signals, pictures, and sounds, for the purpose of
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`executing
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`such
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`scheme and artifice,
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`to wit,
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`the defendant
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`participated in a scheme to induce buyers to make wire payments
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`for the purported purchase of automobiles, boats, and machinery
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`falsely advertised on
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`the internet and to misappropriate
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`the
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`buyers' payments, and in connection therewith and in furtherance
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`thereof,
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`transmitted and caused
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`to be
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`transmitted interstate
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`electronic mail, telephone calls, and wire transfers of funds.
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`(Title 18, United States Code, Sections 1343 and 2. )
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`2
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`Case 1:18-cr-00509-GBD Document 791 Filed 06/11/19 Page 3 of 6
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`COUNT THREE
`(Conspiracy to Commit Money Laundering)
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`The United States Attorney further charges:
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`4.
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`From at least in or about November 2016, up to and
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`including in or about July 2018, in .the Southern District of New
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`York and elsewhere, AZIZA JALOLOVA, the defendant, and others known
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`and unknown, knowingly did combine, conspire, confederate, and
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`agree together and with each other to violate the money laundering
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`laws of the United States.
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`5.
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`It was a part and an object of the conspiracy that AZIZA
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`JALOLOVA, the defendant, and others known and unknown, in an offense
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`involving and affecting interstate and foreign commerce, knowing
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`that the property involved in a financial transaction represented
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`the proceeds of some
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`form of unlawful activity, would and did
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`conduct and attempt to conduct such a financial transaction which
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`in fact involved the proceeds of specified unlawful activity as
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`defined in 18 U.S.C. § 1956 (c) (7) (A) & (B), to wit, the proceeds of
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`the wire fraud conspiracy and wire fraud, in violation of 18 U.S.C.
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`§§ 1343 and 1349, as charged
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`in Counts One and Two of
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`this
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`Information, knowing that the transaction was designed in whole and
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`in part to conceal and disguise the nature,
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`the location,
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`the
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`source, the ownership, and the control of the proceeds of specified
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`3
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`unlawful activity, in violation of Title 18, United States Code,
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`Section 1956 (a) (1) (B) (i)
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`(Title 18 , United States Code, Section 1956(h) .)
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`FORFEITURE ALLEGATION
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`6.
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`As a resulting of committing the offenses alleged in Counts
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`One and Two of this Information, AZIZA JALOLOVA, the defendant, shall
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`forfeit to the United States, pursuant to Title 18, United States
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`Code, Section 98l(a) (1) (C) and Title 28, United States Code, Section
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`2461(c), any and all property, real and personal, that constitutes
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`or is derived from proceeds traceable to the commission of said
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`offense, including but not limited to a sum of money in United States
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`currency representing
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`the amount of proceeds
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`traceable
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`to
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`the
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`commission of said offense.
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`7.
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`As a result of committing the offenses alleged in Count
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`Three of this Information, AZIZA JALOLOVA,
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`the defendant, shall
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`forfeit to the United States, pursuant to Title 18, United States
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`Code, Section 982 (a) (1), any and all property, real and personal,
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`involved in said offense, or any property traceable to such property,
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`including but not limited to a sum of money in United States currency
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`representing the amount of property involved in said offense.
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`SUBSTITUTE ASSET PROVISION
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`8.
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`If any of the above-described forfeitable property, as a
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`result of any act or omission of the defendant:
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`a.
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`cannot be located upon the exercise of due
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`4
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`Case 1:18-cr-00509-GBD Document 791 Filed 06/11/19 Page 5 of 6
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`diligence;
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`b.
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`has been transferred or sold to, or deposited with,
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`a third party;
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`c.
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`has been placed beyond the jurisdiction of the
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`court;
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`d .
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`has been substantially diminished in value; or
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`e.
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`has been commingled with other property which
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`cannot be divided without difficulty;
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`it is the intent of the United States, pursuant to Title 21,
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`United States Code, Section 853(p) and Title 28, United States
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`Code, Section 2461(c), to seek forfeiture of any other property of
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`the defendant up to the value of the forfeitable property
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`described above.
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`(Title 18, United States Code, Sections 981, 982; Title 21,
`United States Code, Section 853; and Title 28, United States
`Code, Section 2461.)
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`GEOFFREY S . BERMAN RbM
`United States Attorney
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`5
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`Case 1:18-cr-00509-GBD Document 791 Filed 06/11/19 Page 6 of 6
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`Form No. USA-33s-274 (Ed. 9-25 - 58)
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
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`UNITED STATES OF AMERICA
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`v.
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`AZIZA JALOLOVA,
`
`Defendant.
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`SUPERSEDING INFORMATION
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`S 8 18 Cr. 509 (GBD)
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`(18 u. s .c. §§ 1349, 1343, 1956).
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`GEOFFREY S . BERMAN
`Un i ted States Attorney
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