Professional Documents
Culture Documents
MKM:AS/MJJ
F.# 2018002164
Defendants.
Neill Fagan, being duly sworn, deposes and states that he is a Special Agent
with the Federal Bureau ofInvestigation, duly appointed according to law and acting as such.
On or about and between November 2,2018 and November 16, 2018, both
dates being approximate and inclusive, within the Eastern District ofNew York and
others, did knowingly and intentionally conspire to obstruct, delay and affect commerce, and
WOOD and others conspired to obtain property, to wit: proceeds of a commercial business in
Brooklyn, New York, Jfrom an individual, with his consent, which consent was to be induced
The source of your deponent's information and the grounds for his belief are
as follows:'
"FBI"), and have been since approximately 2016. I previously served as a police officer and
detective in Florida for approximately eight years. During the course of my career, I have
participated in investigations concerning organized crime and violent crime, among other
SINGER and MARIANNE WOOD,together with Leroy Wilson, extorted a victim (the
"Victim").^ In interviews with the FBI,the Victim stated, in sum and substance and in part,
the following: In early 2018 the Victim sold a business, located in a Victim-owned building
in Coney Island Avenue in Brooklyn, New York (the "Restaurant"). The purchaser ofthis
business was SINGER,whom the Victim has,following that transaction, routinely called at a
telephone number ending in 6508 (the "SINGER Telephone").^ SINGER paid the Victim
'Because the purpose of this Complaint is to set forth only those facts necessary
to establish probable cause to arrest, I have not described all the relevant facts and circumstances
of which 1 am aware. For example,this Complaint refers to and quotes some, but not all,
recorded conversations. Such quotations are based on draft transcriptions, which are set forth in
part and in substance.
^ The Victim has not received any benefits from the FBI or the govemment. The
Victim has proven reliable throughout this investigation, including, as noted throughout the
Affidavit, by corroboration through independent sources of information the Victim has provided
to the FBI. According to a search of databases available to the FBI,the Victim has no
documented criminal history but has reported arrests, which have not led to convictions, are
sealed, and do not pertain to his credibility.
^ Subscriber information for the SINGER Telephone shows that the SINGER
Telephone is subscribed to SINGER in his name.
Case 1:19-cr-00147-LDH Document 1 Filed 12/17/18 Page 3 of 16 PageID #: 31
$60,000 for the Restaurant and agreed to pay monthly rent to the Victim, who continued to
agreement(the "Lease") was executed between an entity controlled by the Victim, and an
entity controlled by SINGER. The Lease provided for the use ofthe retail space occupied
by the Restaurant, in return for $5,200 monthly rent payments to the entity controlled by the
Victim. In order to secure the Lease, SINGER paid the Victim a $15,600.00 security
deposit.
Restaurant, which he renamed. SINGER paid the Victim rent every month until the month
of October 2018.
The Victim responded via text message, to the SINGER Telephone, and agreed to meet with
^ The Victim provided me with the sales contract memorializing the sale ofthe
Restaurant to SINGER. Although the contract provides that it was signed on February 8, 2017,
the Victim informed me that the year is a typographical error, and that the sale occurred in 2018,
not 2017.
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text message to the SINGER Telephone informing SINGER that the Victim was at the
Restaurant. Shortly thereafter, the Victim observed SINGER arriving at the Restaurant in a
gray Ford Explorer(the "Ford Explorer"), which the Victim knew to be SINGER'S vehicle.^
WOOD,and a male, later identified as Leroy Wilson, both then unknown to the Victim.
After parking the Ford Explorer, and in front ofthe Restaurant, SINGER introduced WOOD,
by her first name,to the Victim as SINGER'S business partner. WOOD shook the Victim's
hand but Wilson did not. During the course ofthe ensuing conversation, the Victim heard
separated fi:om SINGER and the Victim, and WOOD began talking to the Victim. During
the course oftheir conversation, WOOD explained in substance and in part that: she was
SINGER'S business partner and she worked for an organization (hereafter "the
Organization") handling all ofSINGER's business relating to the Restaurant. WOOD told
the Victim that the Victim owed the Organization $198,000, which must be paid by the close
ofthe day; she explained the figure by adding the sale price ofthe Restaurant($60,000),to
^ I have reviewed records retrieved from New York State's Department of Motor
Vehicles and leamed that SINGER is the registrant of a 2018 gray Ford Explorer.
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which she retrieved and displayed to the Victim photographs ofthe Victim and the Victim's
spouse and children. WOOD told the Victim, in sum and substance,that she knew the
Victim's family members' names,that it would be in the best interest ofthe Victim and the
Victim's family for the Victim to pay the $198,000, and that she knew how to handle people
like the Victim. The Victim responded, in sum and substance, that the Victim did not have
$198,000 immediately available. WOOD directed the Victim to arrange a payment to her
WOOD a pen. As Wilson retrieved the pen from hisjacket pocket and leaned forward, the
10. Also during the meeting, WOOD provided the Victim with her
telephone number, which ends in 9171 (the"WOOD Telephone"), as the telephone number
at which the Victim had to reach her that day. Information received from the service
provider indicates that the WOOD Telephone is prepaid, with no listed subscriber
information. Based on my training and experience I know that individuals who commit
^ When interviewed by the FBI, SINGER denied that a firearm was used. He
added that when recruiting Wilson for the role of"muscle," Wilson told him he "did not want to
be part of anything illegal," and, according to SINGER,"if there is any true innocent, it's
certainly him [i.e.. Wilson]." SINGER further stated that he believed the Victim committed
"fraud" and that his intention was to convey to the Victim,"give me my money back or we're
going after you to the full extent ofthe law."
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records for the SESIGER Telephone show that the SINGER Telephone was in contact with
the WOOD Second Telephone on November 5, 2018 (the day ofthe meeting between the
Victim, SINGER, WOOD and Wilson). These records further show that the SINGER
Telephone was in contact with the WOOD Second Telephone approximately 30 times in the
months leading to the extortion(between April 24,2018 and November 1, 2018), and
13. Later on November 5, 2018,the Victim reported the threats to the New
York City Police Department, which subsequently alerted the FBI. After the FBI
interviewed the Victim, at the FBI's direction, the Victim called WOOD at the telephone
number she left and arranged for a meeting later the same day, November 5,2018, at a local
diner to discuss payment. During the call, which the FBI recorded, WOOD asked the
Victim,"Do you have my money?" The FBI provided the Victim with a recording device
14. At the prearranged time for the meeting on the same day, FBI agents
conducting surveillance observed a Ford Explorer arrive at the diner and park. The driver of
the Ford Explorer, believed to be SINGER,remained inside the vehicle while two
Case 1:19-cr-00147-LDH Document 1 Filed 12/17/18 Page 7 of 16 PageID #: 35
individuals, believed to be WOOD and Wilson,^ entered the diner. WOOD sat with the
Victim at a booth and Wilson—a large man, wearing all black, including a black leather
jacket^—^sat at the next booth and positioned himself so that he was looking in the direction
ofthe Victim during most ofthe Victim's meeting with WOOD. During the course of
WOOD'S and the Victim's conversation, which was recorded, WOOD explained that
SINGER did not actually own the Restaurant, that she and SINGER worked for the
Organization, and that the Organization required the Victim to buy back the Restaurant:
^ The individuals observed by the FBI near the Ford Explorer matched the
descriptions provided by the Victim. The Victim has informed the FBI that the two individuals
the Victim met at the diner were the same two individuals the Victim had been introduced to
earlier in the day by SINGER.
® New Jersey Department of Motor Vehicles records list Wilson as 6 feet, 1 inch
tall, and weighing over 220 pounds.
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15. Later in the same conversation, WOOD explained that SINGER and
WOOD work for an "organization," but that SINGER could not be forthcoming with the
16. Later in the same conversation, WOOD insisted that the Victim sign a
document that purported to release SINGER from any liability associated with the
Restaurant:
17. Later in the conversation, the Victim inquired about the safety of his family
and referenced the photographs that WOOD showed the Victim earlier in the day:
Victim: Alright.
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WOOD Second Telephone)that is on file with United States Customs and Border Protection.
A comparison ofthe photograph and surveillance footage from the diner where the
I will not be speaking with anyone but you and at the end ofthe
day tomorrow I will have done everything I can and you will be
on your own. This is not a negotiation.
20. The next day, November 9,2018,the Victim met with SINGER at a
cafe in order to discuss the Victim's payment. During the Victim's and SINGER'S
conversation, which was recorded, the Victim inquired as to the safety ofthe Victim's
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November 9,2018,the Victim informed SINGER that the Victim did not have the payment
demanded by WOOD readily available. SINGER,at the Victim's request, agreed to contact
called the Victim from the SINGER Telephone. During the conversation,the Victim asked,
"Is my family going to be in danger after I give you this money?" After SINGER stated that
he was not part ofthe conversation when the Victim's family was threatened by WOOD and
Wilson, SINGER stated,"I would not mess with them that way." Based on the context of
the conversation, I believe that by "them," SINGER meant WOOD and Wilson and/or other
members ofthe Organization. SINGER stated that he "felt really upset" about the threats
and about WOOD and Wilson's demand for "triple damages" from the Victim. Seconds
later, however,SINGER added that he did not care how he got paid: "I don't think it
matters. I think green is green as far as I'm concerned." The Victim continued asking for
assurance from SINGER with regard to the Victim's family, adding,in reference to WOOD
and Wilson,"You have more power on them than me. You're the guy that brought them in.
I mean, not me." SINGER responded,"Of course. Ofcourse." SINGER and the Victim
arranged to meet on November 16,2018 for the Victim to pay $75,000 and to release
23. At this November 16,2018 meeting, while FBI agents were conducting
surveillance, the Victim gave SINGER cash, which the Victim stated was $75,000(but was,
in reality,$10,000). After SINGER accepted the money,the Victim left the Restaurant.
Case 1:19-cr-00147-LDH Document 1 Filed 12/17/18 Page 12 of 16 PageID #: 40
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recovered in the search show them discussing the extortion ofthe Victim.^ For example, on
brief life lesson on business. I appreciate you both." Based on my knowledge ofthe
investigation and training and experience,I believe that Wilson was referring to WOOD'S
possible for you to wear a dark suit but no tie? Maybe a white shirt? And dark sunglasses?"
WILSON replied, proposing that he would wear "All black, I'm thinking. Black button
down shirt. Black suitjacket, black suit pants." Based on my knowledge ofthe
investigation and training and experience, I believe that Wilson was attempting to select
clothing that would make him appear most intimidating,to fit the role of an enforcer for
SINGER, WOOD and their "organization." SINGER responded to this message stating,
"Perfect!"
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had a feeling that [the Victim] was going to be the weasel that he is. Keep me posted."
Based on my knowledge ofthis investigation, I believe that SINGER informed Wilson that
the Victim had not yet provided the money, and Wilson was expressing his view ofthe
Victim. The following day, Wilson followed up with SINGER,asking "Haven't heard from
Hey Roy,I hope this note finds you well. I was wondering if
you might be interested in a 'kind of acting gig. I need a
couple ofguys to escort my associate [i.e.. WOOD]while she
delivers a demand to my landlord. It will be in a pizzeria in
Brooklyn. You would simply have to stand in the background
and appear to be muscle. Suit/sunglasses. He [i.e.. the
Victim] tried to screw me and she isjust setting him straight.
No danger. I would pay you $50 per hour including 2 hours of
drive time with a minimum of$250. The problem is that it has
to be this Monday. Let me know if you are interested ASAP.
Thanks.
After sending this message, SINGER left Wilson his telephone number.
29. Messages between SINGER and WOOD also show that they scripted
messages, SINGER wrote to WOOD,"By the way the other guy whose picture I sent, he is
100% in. He is for Monday." Based on my knowledge ofthe investigation, I believe that
SINGER was referring to Wilson, whom WOOD did not appear to have met prior to the
extortion ofthe Victim. Later, the two shared the following exchanges:
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WOOD: YAY
SINGER: Me too.
30. In these messages, WOOD and SINGER agreed to meet with Wilson
for "20 minutes before you tw[o] get in the car together." SINGER added, about Wilson,
"He is an actor and on Monday his gig is there going to be to look scary and not say a
fucking word. Easy gig for 50 bucks an hour say LOL Fi.e.. laughing out loud]." WOOD
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and SrNGER also discussed how they arrived at the extortionate sum. SINGER wrote:
renovation cost. Average of$7000 a month and losses times 8 V2 months is 60,000."
WOOD responded,"Eve got 75000 by the end ofthis week and you're out ofthe lease.
What do you say?" SINGER responded,"Do you trust it [sic] vdll get the 75,000? How do
we know that?" Based on my knowledge ofthe investigation and training and experience,
these messages show that SINGER and WOOD discussed the probability that they could
residence, pursuant to a search warrant authorized by the Honorable Leda D. Wettre, United
States Magistrate Judge for the District ofNew Jersey. Among the items recovered from
Wilson's residence was a prop black pistol (the same color as described by the Victim), and a
leather jacket that WILSON could be seen wearing on surveillance footage on November 5,
2018.
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Neill Pagan
Special Agoot/
Federal Bureau ofInvestigation