William Boyland Ryan Hermon Amended Complaint

RB:CP/LXN
F.#2011R02117
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
- -x
UNITED STATES OF AMERICA
-against-
WILLIAM F. BOYLAND I JR. and
RYAN HERMON I
Defendants.
- - -X
THE GRAND JURY CHARGES:
I N D I C T MEN T
Cr. No.
(T. 18
1
U.S.C. I 371
1
666 (a) (1) (B) I
981(a)(1)(C)/ 1343
1
1346
1
1349, 1951(a) I
2 and 3551 et seq.; T. 211
U.S.C. I 853 (p); T. 28 1
U.S.C. I 2461(c))
ij\fJNES, J.
INTRODUCTION TO ALL COUNTS.
u ~ t J \ . J
At all times relevant to this Indictment I
otherwise indicated:
The Defendants and Other Individuals
1. In or about and between March 2003 and December
2011
1
the defendant WILLIAM F. BOYLAND I JR. served as a member of
the New York State Assembly (the "Assemblyll) representing the
55th Assembly district
l
located in Brooklyn
l
New York. The
Assembly was a subdivision of the legislative branch of the New
York State government which received in excess of $10
1
000 each
calendar year under federal programs involving grants I contracts I
subsidies I loans I guarantees I insurance and other forms of
federal assistance.
Case 1:11-cr-00850-SLT Document 9 Filed 12/23/11 Page 1 of 27 PageID #: 92
.. ).
,.
2. In or about and between 2008 and December 2011,
RYAN HERMON was employed by the Assembly and served as BOYLAND's
chief of staff.
3. In or about and between 2010 and 2011, a carnival
promoter (the "Promoter"), who was cooperating with federal law
enforcement, and whose identity is known to the Grand Jury, held
himself out to BOYLAND and HERMON as an active carnival promoter
interested in scouting locations and setting up carnivals in
Brooklyn, New York.
4. In or about and between 2010 and 2011, an
undercover Special Agent ("UC1") of the Federal Bureau of
Investigation ("FBI"), whose identity is known to the Grand Jury,
held himself out to BOYLAND and HERMON as an entrepreneur from
Philadelphia, Pennsylvania who was (i) in the import-export
business, (ii) interested in aiding the Promoter's carnival
business, and (iii) seeking opportunities to invest in real
estate in Brooklyn, New York. UC1 provided his cellular
telephone number, which was assigned a Pennsylvania-based area
code, to BOYLAND and HERMON.
5. In or about 2011, another undercover special Agent
("UC2") of the FBI, whose identity is known to the Grand Jury,
held himself out to BOYLAND and HERMON as an entrepreneur with
business interests in Florida, who was a business associate of
UC1 and was seeking opportunities to invest in real estate in
2
....
"
"-
)
Brooklyn, New York. UC2 provided his cellular telephone number,
which was assigned a Florida-based area code, to BOYLAND.
The Traveling Carnival Business
6. Traveling carnival businesses that seek to operate
carnivals in New York City must obtain permissions, permits and
licenses from various local government agencies. For example,
the Department of Consumer Affairs ("DCA") must issue a
"Temporary Use Device License" in order for a carnival to operate
rides. DCA often requires letters of support from the local
community board and elected officials who represent the district
within which the carnival is to be held. In addition, the New
York City Department of Buildings must inspect and approve a
-carnival before it can begin operating.
7. Carnival operators in New York City frequently
seek to have community-based non-profit organizations listed as
sponsors for their shows. The carnivals themselves generally
generate more than $5,000 in receipts.
8. A carnival promoter is an individual who helps
secure locations, permissions and permits for traveling carnival
businesses.
The Criminal Schemes
9. In or about and between August 2010 and August
2011, the defendants WILLIAM F. BOYLAND, JR. and RYAN HERMON,
together with others, corruptly solicited in excess of $250,000
3
-
-
in bribes and accepted thousands of dollars in cash and other
forms of payment in exchange for taking official actions and
exerting official influence as specific opportunities arose on
behalf of the Promoter, UCI and UC2. BOYLAND and HERMON
solicited and accepted bribes in connection with (i) the
purported interest of the Promoter and UCI inholding carnivals
in BOYLAND's district, and (ii) the purported interest of UC1 and
UC2 in investing in real estate development projects in BOYLAND's
district.
I. The Carnival Scheme
together with others, engaged in a scheme to solicit bribes from
the Promoter and UC1 in exchange for BOYLAND's assistance in
securing the necessary permits and support to allow the Promoter
to hold carnivals in BOYLAND's district (the "Carnival Scheme").
11. It was part of the Carnival Scheme that starting
in or about August 2010, BOYLAND met with the Promoter and UCI on
multiple occasions in New York City and discussed the desire of
the Promoter and UCI to hold carnivals in BOYLAND's district. In
those meetings, BOYLAND requested payments for assisting the
Promoter and UCI. BOYLAND also discussed various ways in which
payments made to him could be disguised to hide their true
purpose.
4
-..
-
12. As a result of these meetings, BOYLAND directed
his staff to assist the Promoter and UC1. BOYLAND represented to
the Promoter and UCl that he and his staff (i) engaged in
discussions'witb 'governmental agencies to assist the Promoter in
obtaining carnival-related leases and permits, (ii) arranged for
a non-profit organization to sponsor the Promoter's carnivals,
and (iii) took steps to ensure that the Promoter would receive
letters of support from BOYLAND that he needed to operate
carnivals in BOYLAND's district. In return, UCl paid several
thousand dollars by check and money orders that were deposited
into BOYLAND's campaign bank account.
13. In or about February 2011, the defendant RYAN
HERMON itlfomedUC1-that-she had been assigned by BOYLAND to the
"team" dealing with UCl and the Promoter's carnivals. In
addition to her efforts in connection with the Carnival Scheme,
HERMON also solicited bribes for herself from the Promoter and
UCl in exchange for her continuing assistance in securing the
necessary permits, licenses and support to allow the Promoter to
hold carnivals in BOYLAND's district (the "Hermon Carnival
Scheme") .
14. It was part of the Carnival Scheme and the Hermon
Carnival Scheme that HERMON met with the Promoter and UCl on
multiple occasions in New York City. During these meetings,
HERMON asked the Promoter and uel what assistance they needed
5
;
from BOYLAND's office in order to hold carnivals in his district
and sought to be paid for her efforts on their behalf. In
return, UC1 paid HERMON approximately two thousand dollars in
cash. Ultimately, HERMON provided the Promoter and UC1 with,
among other things, letters written on BOYLAND's official
letterhead that expressed BOYLAND's support for the Promoter and
for the carnivals that the Promoter purported to promote. HERMON
also showed the Promoter and UC1 a location in BOYLAND's district
for a proposed carnival.
15. In or about March 2011, HERMON expressed to UC1
that the process of arranging to hold carnivals in BOYLAND's
district had become much better for the Promoter and UC1 since
she became involved. HERMON stated that she was sharing the
bribes she received in connection with the HERMON Carnival Scheme
with other staffers in BOYLAND's office, and that this had
resulted in better service for UC1. An except of their
conversation on that topic follows:
HERMON:
UC1:
HERMON:
You know to be honest with you. I appreciate
your . generosity. I'm actually sharing
with the staff in (laughing) the office . . .
Ehm hm.
--the staff, when I come in and say well
[UC1] needs this, dah dah dah did dah.
They're jumping 'cause they know, like I'm,
they're gonna get something or they got
something.
UC1: Oh good. Ok. Good, good.
6
HERMON:
And that's not saying that should always be
the incentive but, be honest with you,
they're just like, everyone just wanna make
sure these deals get closed and, and they do
happen and work in your favor.
II. The Real Estate Scheme
16. In or about and between November 2010 and August
together with others, engaged in a scheme to solicit bribes from
UC1 and UC2 in exchange for BOYLAND's official assistance to UC1
and UC2 with real estate development projects in BOYLAND's
district (the "Real Estate Scheme"). It was part of the Real
Estate Scheme that BOYLAND and HERMON exchanged telephone calls,
text messages and emails with UC1, when BOYLAND and HERMON were
located in the Eastern' District of New York, -andUC1 was located
in the State of Pennsylvania.
17. It was also part of the Real Estate Scheme that on
March 11, 2011, BOYLAND met with UC1 and UC2 about their interest
in real estate development projects in his district, highlighting
one project in particular in which "state money" for financing
was available. Shortly thereafter, BOYLAND and HERMON solicited
money from UC1, purportedly to pay for lawyers representing
BOYLAND on federal criminal charges that had recently been filed
in New York, New York. In exchange for the money, UC1 and UC2
would receive BOYLAND's official action and influence as specific
7
opportunities arose in support of UCI and UC2's real estate
development businesses.
18. On or about March 25, 2011, UCI met with BOYLAND
at hfs district office in Brooklyn, New York. BOYLAND agreed
that in exchange for money, BOYLAND would assist UCI and UC2 in
obtaining New YorkState grant monies to help finance the real
estate development projects in his district. In return, UCI paid
BOYLAND $7,000 in cash.
19. Approximately one week later, BOYLAND showed UCI
and UC2 locations in his district that he suggested would be
suitable for development projects. BOYLAND emphasized that all
the properties he was showing UCI and UC2 were in BOYLAND's
district,' which "we-have control over." BOYLAND further stated,
"Everything we've seen I'm in control of. You know, I'm the
politician. I'm the guy who can make that move over on this end,
so we know the folks that can pull the sort of triggers we're
looking for."
20. On or about April 29, 2011, in a hotel suite in
Atlantic City, New Jersey, BOYLAND solicited $250,000 from UC1
and UC2 in exchange for BOYLAND's official action and influence
as specific opportunities arose in connection with the purchase
and development of a former hospital in BOYLAND's district
("Hospital A"), the identity of which is known to the Grand Jury.
Specifically, BOYLAND proposed a scheme which called for UC1 and
8
UC2 to purchase Hospital A for $8 million and resell it to a
non-profit organization that BOYLAND purported to control ("Non-
Profit A"), the identity of which is known to the Grand Jury, for
$15 millie-h.
21. During this meeting, BOYLAND demonstrated his
awareness of the criminal nature of the plan by explaining to UCI
and UC2 that he did not want to talk on the telephone about these
activities and that he preferred in-person meetings. He stated,
"I stopped talking on the phone awhile ago . . . I'm just saying
there is no real conversation that you can have that, you know,
especially with what we're talking about." BOYLAND further made
clear that he needed to conceal his involvement in the proposed
proj ect. BOYLAND stated, "I got a middle guy by the way . .. .-I
gotta stay clean . . . I got a bag man . . ."
22. HERMON, knowing that the Hospital A deal was
conditioned on UCI and UC2 paying a $250,000 bribe to BOYLAND,
took action in furtherance of the scheme. For example, HERMON
advised UCI that the hospital deal was "doable" and claimed that
she had been "on the phone with a state representative hearing
about their enthusiasm about the project." HERMON also told UCI
that BOYLAND "definitely has state support."
23. On or about June 7, 2011, in a hotel room in New
York, New York, BOYLAND reiterated that he wanted UCI and UC2 to
pay him $250,000 in exchange for the Hospital A project. When
9
UC2 instead offered to pay BOYLAND $5,000 for introductions to
other government officials who would be involved in the project,
BOYLAND rejected the suggestion, stating that the people whom he
could introduce to UC1 and UC2 were worth more $5,000: m -
not talking about $5,000 folks. I'm talking about ... people
that can actually get these projects done
1/
BOYLAND
further stated that he had been effective in getting projects
like this done in the past.
COUNT ONE
(Extortion Conspiracy -- Real Estate Scheme)
24. The allegations contained in paragraphs 1 through
23 are realleged and incorporated as if set forth fully in this
paragraph.
2011, both dates being approximate and inclusive, within the
Eastern District of New York and elsewhere, the defendants
WILLIAM F. BOYLAND, JR. and RYAN HERMON, together with others,
did knowingly and intentionally conspire to obstruct, delay and
affect commerce, and the movement of articles and commodities in
commerce, by extortion, in that the defendants and others agreed
to obtain property, to wit: cash and other forms of payment
relating to the Real Estate Scheme, from UC1 and UC2, with their
10
consent, which consent was to be induced under color of official
right, to wit: BOYLAND's position as a member of the Assembly.
(Title 18, United States Code, Sections 1951(a) and
COUNT TWO
(Attempted Extortion -- Real Estate Scheme)
paragraph.
did knowingly and intentionally attempt to obstruct, delay and
commerce, by extortion, in that the defendants and others
obtained and attempted to obtain property, to wit: cash and other
forms of payment relating to the Real Estate Scheme, from UC1 and
UC2, with their consent, which consent was to be induced under
color of official right, to wit: BOYLAND's position as a member
of the Assembly.
3551 et seq.)
11
COUNT THREE
(Bribery and Travel Act Conspiracy -- Real Estate Scheme)
23 are realleged and incorporated as if set forth f ~ l l y in this
paragraph.
WILLIAM F. BOYLAND, JR. and RYAN HERMON, together with others:
(a) being agents of the Assembly, an agency of the New
York State government which received benefits in excess of
$10,000 under one or more Federal programs involving grants,
contracts, subsidies, loans, guarantees, insurance and other
forms of Federal assistance in one or more one-year periods, did
knowingly and wilfully conspire to corruptly solicit and demand
for the benefit of BOYLAND, and accept and agree to accept, one
or more things of value, to wit: cash and other forms of payment
relating to the Real Estate Scheme, from one or more persons, to
wit: UC1 and UC2, intending to be influenced and rewarded in
connection with business and one or more transactions and series
of transactions of the Assembly, involving things of value of
$5,000 or more, contrary to Title 18, United States Code, Section
6 6 6 (a) (1) (B) i and
(b) did knowingly and wilfully conspire to travel in
interstate commerce and use the mail and facilities in interstate
12
commerce, with intent to promote, manage, establish, carryon and
facilitate the promotion, management, establishment and carrying
on of unlawful activity, to wit: receiving bribes relating to the
Real Estate Scheme, in violation of New York Penal Law Sections
200.10 and 20.00, and thereafter to perform acts to promote,
manage, establish, carryon and facilitate the promotion,
management, establishment and carrying on of such unlawful
activity, contrary to Title 18, United States Code, Section
1952 (a) (3) .
30. In furtherance of the conspiracy and to effect its
objects, within the Eastern District of New York and elsewhere,
the defendants WILLIAM F. BOYLAND, JR. and RYAN HERMON committed
and caused to be committed, among ohhers, the following:
OVERT ACTS
a. On March II, 2011, BOYLAND met with UC1 and
UC2 in New York, New York.
b. On March 19, 2011, BOYLAND engaged in a
telephone conversation with UC1.
c. On March 22, 2011, HERMON engaged in a
d. On March 23, 2011, BOYLAND engaged in a
e. On March 25, 2011, BOYLAND met with UC1 in
Brooklyn, New York.
13
f. On April I, 2011, BOYLAND met with UC1 and
UC2 in Brooklyn, New York.
g. On April 29, 2011, BOYLAND met with UC1 and
- UC2-in Atlantic City, New Jersey.
h. On May 9, 2011, HERMON met with UC1 in New
York, New York.
i. On May 24, 2011, HERMON engaged in a
j. On May 27, 2011, BOYLAND, HERMON and another
individual met with UC2 in Brooklyn, New York.
k. On June 7, 2011, HERMON met with UC1 and the
Promoter in Brooklyn, New York.
1. On June 7, 2011, BOYLAND met with UC1 and UC2
in New York, New York.
m. On June 7, 2011, BOYLAND sent a text message
to UC1.
(Title 18, United States Code, Sections 371 and 3551 et
seq. )
COUNT FOUR
(Bribery -- Real Estate Scheme)
paragraph.
14
being agents of the Assembly, an agency of the New York State
government which received benefits in excess of $iO,OOb under one
or more Federal programs involving grants, contracts, subsidies,
loans, guarantees, insurance and other forms of Federal
assistance in one or more one-year periods, did knowingly,
intentionally and corruptly solicit and demand for the benefit of
BOYLAND, and accept and agree to accept, one or more things of
value, to wit: cash and other forms of payment relating to the
Real Estate Scheme, from one or more persons, to wit: UC1 and
UC2, intending to be influenced and rewarded in connection with
business andone or more transactions and series of transactions
of the Assembly involving things of value of $5,000 or more.
(Title 18, United States Code, Sections 666(a) (1) (B), 2
and 3551 et seq.)
COUNT FIVE
(Honest Services Fraud Conspiracy Real Estate Scheme)
paragraph.
15
did knowingly and intentionally conspire to devise a scheme and
artifice to defraud and deprive the citizens of the State of New
York and the Assembly of their intangible right to the honest
services of BOYLAND and HERMON through bribery, kickbacks and the
concealment of material information, to wit: the Real Estate
Scheme, and for the purpose of executing such scheme and
artifice, to transmit and cause to be transmitted, by means of
wire communication in interstate commerce, writings, signs,
signals, pictures and sounds, contrary to Title 18, United States
Code, Sections 1343 and 1346.
(Title 18, United States Code, Sections 1349 and 3551
COUNTS SIX THROUGH FIFTEEN
(Honest Services Fraud -- Real Estate Scheme)
23 are realleged and incorporated as if fully set forth in this
paragraph.
did knowingly and intentionally devise a scheme and artifice to
defraud and deprive the citizens of the State of New York and the
Assembly of their intangible right to the honest services of
16
".
BOYLAND and HERMON through bribery, kickbacks and the concealment
of material information, to wit: the Real Estate Scheme.
37. On or about the dates listed below, for the
purpose of executing such scheme and artifice, the defendants
transmitted and caused to be transmitted by means of wire
communication in interstate commerce, writings, signs, signals,
pictures and sounds, as identified below:
COUNT
SIX
SEVEN
EIGHT
NINE
TEN
ELEVEN
TWELVE
THIRTEEN
APPROXIMATE INTERSTATE WIRE TRANSMISSION
DATE
10/29/10 Telephone conversation between BOYLAND
and UC1 who was using out-of-state
telephone number
telephone number
telephone number
2/23/11 Voicemail message from HERMON for UC1
on UC1's out-of-state telephone number
2/24/11 Telephone conversation between HERMON
telephone number
3/18/11 Text message from BOYLAND to UC1 on
UC1's out-of-state telephone number
telephone number
3/22/11 Telephone conversation between HERMON
telephone number
17
FOURTEEN
FIFTEEN
3/23/11
5/24/11
Telephone conversation between BOYLAND
telephone number
Telephone conversation between HERMON
telephone number
(Title 18, United States Code, Sections 1343, 1346, 2
and 3551 et seg.)
COUNT SIXTEEN
(Extortion Conspiracy -- Carnival Scheme)
paragraph.
did knowingly and intentionally conspire to obstruct, delay and
commerce, by extortion, in that the defendants and others agreed
to obtain property, to wit: cash and other forms of payment
relating to the Carnival Scheme, from the Promoter and UC1, with
their consent, which consent was to be induced under color of
official right, to wit: BOYLAND's position as a member of the
Assembly.
3551 et seg.)
18
COUNT SEVENTEEN
(Bribery Conspiracy -- Carnival Scheme)
paragraph.
WILLIAMF. BOYLAND, JR. and RYAN HERMON, together with others,
government which received benefits in excess of $10,000 under one
assistance in one or more one-year periods, did knowingly and
wilfully conspire to corruptly solicit and demand for the benefit
of BOYLAND, and accept and agree to accept one or more things of
Carnival Scheme, from one or more persons, to wit: the Promoter
and UC1, intending to be influenced and rewarded in connection
with business and one or more transactions and series of
transactions of the Assembly, involving things of value of $5,000
or more, contrary to Title 18, United States Code, Section
666 (a) (1) (B) .
42. In furtherance of the conspiracy and to effect its
objects, within the Eastern District of New York and elsewhere,
19
the defendants WILLIAM F. BOYLAND, JR. and RYAN HERMON committed
and caused to be committed, among others, the following:
OVERT ACTS
a. On August 16, 2010, BOYLAND engaged in a
telephone conversation with the Promoter.
b. On August 20, 2010, BOYLAND engaged in a
telephone conversation with the Promoter.
c. On August 26, 2010, BOYLAND met with the
Promoter and UC1 in Brooklyn, New York.
d. On October 8, 2010, BOYLAND met with the
Promoter and UC1 in Brooklyn, New York.
e. On October 18, 2010, HERMON sent an email to
UC1.
f. On October 19, 2010, BOYLAND sent an email to
UC1.
g. On October 28, 2010, BOYLAND met with UC1.
h. On October 29, 2010, BOYLAND engaged in a
i. On November 3, 2010, BOYLAND met with UC1 and
the Promoter in Brooklyn, New York.
j. On November 10, 2010, BOYLAND engaged in a
k. On January 17, 2011, BOYLAND engaged in a
20
1. On or about January 28, 2011, BOYLAND met
with UC1 in New York, New York.
m. On February 23, 2011, HERMON left a voicemail
message for UC1.
n. On February 24, 2011, HERMON engaged in a
o. On February 24, 2011, HERMON met with the
Promoter in New York, New York.
p. On February 27, 2011, HERMON met with UC1 in
New York, New York.
q. On February 27, 2011, HERMON sent a text
message to UC1.
r. On March 8, 2011, HERMON provided the
Promoter with letters on BOYLAND's official letterhead.
(Title 18, united States Code, Sections 371 and 3551 et
seq. )
COUNT EIGHTEEN
(Attempted Extortion -- Carnival Scheme)
paragraph.
21
did knowingly and intentionally attempt to obstruct, delay and
commerce, by extortion, and attempt to do so, in that the
defendants and others obtained and attempted to obtain property,
to wit: cash and other forms of payment relating to the Carnival
Scheme, from the Promoter and UC1, with their consent, which
consent was to be induced under color of official right, to wit:
BOYLAND's position as a member of the Assembly.
(Title 18, United States Code, Sections 1951(a), 2 and
3551 et seg.)
COUNT NINETEEN
(Bribery -- Carnival Scheme)
paragraph.
government which received benefits in excess of $10,000 under one
assistance in one or more one-year periods, did knowingly,
intentionally and corruptly solicit and demand for the benefit of
22
BOYLAND, and accept and agree to accept, one or more things of
Carnival Scheme, from one or more persons, to wit: the Promoter
~ and UC1, intending to be influenced and rewarded in connection
with business and one or more transactions and series of
transactions of the Assembly involving things of value of $5,000
or more.
and 3551 et seg.)
COUNT TWENTY
(Attempted Extortion -- Hermon Carnival Scheme)
paragraph.
48. In or about and between February 2011 and March
Eastern District of New York and elsewhere, the defendant RYAN
HERMON, together with others, did knowingly and intentionally
attempt to obstruct, delay and affect commerce, and the movement
of articles and commodities in commerce, by extortion, and
attempt to do so, in that the defendant and others obtained and
attempted to obtain property, to wit: cash and other forms of
payment relating to the Hermon Carnival Scheme, from the Promoter
and UC1, with their consent, which consent was to be induced
23
,
under color of official right, to wit: HERMON's position as
BOYLAND's chief of staff.
(Title 18, united States Code, Sections 1951(a) and
3551 et seq.)
COUNT TWENTY-ONE
(Bribery -- Hermon Carnival Scheme)
paragraph.
50. In or about and between February 2011 and March
Eastern District of New York and elsewhere, the defendant RYAN
HERMON, together with others, being an agent of the Assembly, an
agency of the New York State government which received benefits
in excess of $10,000 under one or more Federal programs involving
grants, contracts, subsidies, loans, guarantees, insurance and
other forms of Federal assistance in one or more one-year
periods, did knowingly, intentionally and corruptly solicit and
demand for the benefit of HERMON, and accept and agree to accept,
one or more things of value, to wit: cash and other forms of
payment relating to the Hermon Carnival Scheme, from one or more
persons, to wit: the Promoter and UC1, intending to be influenced
and rewarded in connection with business and one or more
24
transactions and series of transactions of the Assembly involving
things of value of $5,000 or more.
and 3551 et seg.)
CRIMINAL FORFEITURE ALLEGATION
51. The United States hereby gives notice to the
defendants that, upon their conviction of any of the offenses
charged in Counts One through Twenty-One, the government will
seek forfeiture, in accordance with Title 18, United States Code,
Section 981(a) (1) (C) and Title 28, United States Code, Section
2461(c), of any property constituting or derived from proceeds
obtained directly or indirectly as a result of such offenses.
52. If any of the above-described forfeitable
property, as a result of any act or omission of the defendants:
a. cannot be located upon the exercise of due
diligence;
b. has been transferred or sold to, or deposited
with, a third party;
c. has been placed beyond the jurisdiction of
the court;
d. has been substantially diminished in value;
or
e. has been commingled with other property which
cannot be divided without difficulty;
25
it is the intent of the United states, pursuant to Title 21,
United States Code, Section 853(p), as incorporated by Title 28,
United States Code, Section 2461(c), to seek forfeiture of any
other property of the defendants up to the value of the
forfeitable property described in this forfeiture allegation.
(Title 28, United States Code, Section 2461(c) i Title
18, United States Code, Section 981(a) (1) (C) i Title 21, United
States Code, Section 853(p))
('-j)r{Jt/bv ~ . ( ~
I ( ~
LORETTA E. LYNCH
UNITED STATES ATTORNEY
A TRUE BILL
26
" F.#20 lIR02 11 7
;. FORM DBD-34
, - ~
JUN. 85
..
No.
UNITED STATES DISTRICT COURT
EASTERN District of NEW YORK
CRIMINAL DIVISION
THE UNITED STATES OF AMERICA
vs.
William F Boyland, Jr. and Ryan Hermon
Defendants.
INDICTMENT
T 18, USc., 371, 666(a)(1)(B), 981(a)(l)(C), 1343, 1346, 1349, 1951 (a),
2 and 3551 et seq.; T 21, USc., 853(P); T 28, USc., 2461(c))
- ~ ~ : : ~ - - - - - - - - - - - - - - - ~ ~ o o -
Filed in open court this _________________ day.
of ____________ A.D. 20 ____ _
Clerk
Bail, $
---------
Lan Nguyen, Assistant U.S. Attorney (718-254-6162)
I
F.#2011R02117
I N F O ~ T ~ ~ E T
UNITED STATES ~ CJRJ.
850
1. Title of Case: United States v. William F. Boyland, Jr. and Ryan Hermon
2.
3.
4.
Related Magistrate Docket Number(s):M-11-1163, M-11-1183,
None ()
Arrest Date: 11/29/11 (Boyland), 12/1/11 (Hermon)
Nature of offense(s): ~ Felony
o Misdemeanor
5. Related Cases - Title and Docket No(s). (Pursuant to Rule 50.3 of the
Local E.D.N.Y. Division of Business Rules):
6. Projected Length of Trial: Less than 6 weeks (X)
More than 6 weeks ()
7. County in which crime was allegedly committed: Brooklyn
,OWNES, J.
GO,-M.J.
(Pursuant to Rule 50.1(d) of the Local E.D.N.Y. Division of Business Rules)
8. Has this indictment/information been ordered sealed? () Yes (X)No
( ) Yes (X) No
9. Have arrest warrants been ordered?
By:
Rev. 3/22/01
LORETTA E. LYNCH
UNITED STATES ATTORNEY
;;;;;---:;;>-,----
Lan Nguyen
Assistant U.S. Attorney
718-254-6162
Case 1:11-cr-00850-SLT Document 9-1 Filed 12/23/11 Page 1 of 1 PageID #: 119

William Boyland Ryan Hermon Amended Complaint

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