AO 91 (Rev.

08/09) Criminal Complaint

UNITED STATES DISTRICT COURT

for the
Southern District of Florida

United States of America )

v. )
) Case No.
') tfrCI­,5·
/ 1- c:.><- Si7j
ALEC SIMCHUK. ALBERT TAKHALOV. )

SVETLANA COGHLlN, et al.

)
)

CRIMINAL COMPLAINT

I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of February 2010 through present in the county of Miami-Dade in the
Southern District of , the defendant(s) violated:

Code Section Offense Description

Title 18, United States Code, 1349 knowingly conspiring with others to violate Title 18, United States Code,
Section 1343, that is. to knowingly and with intent to defraud, devise, and
intend to devise a scheme and artifice to defraud and to obtain money and
property by means of materially false and fraudulent pretenses,
representations, and promises, knowing that they were false and fraudulent
when made, and knowingly causing to be transmitted by means of wire
communication in interstate and foreign commerce. any writings, signs or
signals. for the purpose of executing the scheme and artifice

This criminal complaint is based on these facts:

SEE ATIACHED AFFIDAVIT

o Continued on the attached sheet.

Alexander V, Tiguy, FBI Special Agent

Printed name and title

Sworn to before me and signed in my presence.

Date: 04/04/2011

City and state: Miami, Florida '_+-_-=::':7""'"",-"""",=w.:..:..:..:n-'---=.U,,-,,.S~.~M=a9istrate JU""d",,9-"Oe_ __

Printed name and ti/le
 AFFIDAVIT IN SUPPORT OF COMPLAINT

I, Alexander V. Tiguy, Special Agent (SA) for the Federal Bureau of Investigation (FBI),

being duly sworn state:

1. I have been a Special Agent (SA) with the FBI since December, 2007. During

this time, I have been assigned to investigations of counterintelligence, counter proliferation,

internet intrusion, organized crime, identity theft, kidnapping, and mortgage fraud. My

educational background is in the field of Finance and Accounting. I worked for approximately

three years in the Finance and Banking field prior to becoming a Special Agent with the FBI. I

am a native Russian speaker currently assigned to the FBI Miami Division. In addition to my

work experience, I have received extensive specialized training in the field of counterintelligence

and computer crime from the FBI and others.

2. This affidavit is in support of a criminal complaint charging Alec SIMCHUK aka

"Alex," Albert TAKHALOV ("TAKHALOV"), Svetlana COGHLAN, Isaac FELDMAN,

Stanislav PAVLENKO, Fady KALDAS, Siavash ZARGARI aka "Sammy," Marina TURCINA,

Julija VINOGRADOV A, Anna KILIMA TOV A, Valeria MATSOV A, Victorija ARTEMJEV A,

Anastassia USAKOVA, Kristina TAKHALOV ("K. TAKHALOV"), Irina DOMKOV A,

Anastassia MIKRUKOVA, and Agnese RUDAKA, with knowingly conspiring together with

others to violate Title 18, United States Code, Section 1343, that is, to knowingly and with intent

to defraud, devise, and intend to devise a scheme and artifice to defraud and to obtain money and

property by means of materially false and fraudulent pretenses, representations, and promises,

knowing that they were false and fraudulent when made, and knowingly causing to be'

transmitted by means of wire communication in interstate and foreign commerce, any writings,
 4. The facts and information contained in this Affidavit are based upon my

knowledge and observations, information received from other experienced federal agents

working on this investigation, information obtained from witnesses, sources and law

enforcement personnel outside my own agency, and information gained from my training and

experience. This affidavit is intended to show only that there is probable cause for the requested

warrant and does not set forth all of my knowledge about this matter.

PROBABLE CAUSE

Overview of the Fraudulent Scheme

5. The Federal Bureau of Investigation is conducting an ongoing investigation into

an international criminal organization committing fraud in South Florida. The organization

operates private night clubs, and uses female coconspirators to lure male victims in order to

fraudulently charge their credit cards exorbitant prices for alcoholic beverages. This is done by

either having the female coconspirators order multiple bottles of wine and champagne without

the victim's knowledge, misleading male victims about the price of alcohol, forging the victim's

signatures on credit card receipts, or processing unauthorized charges on the victim's credit

cards.

6. Based on the investigation to date as set forth in more detail infra, members of the

criminal organization, herein referred to as Organizers, opened clubs in Miami Beach, Florida

with investment capital obtained from other coconspirators, herein referred to as Investors. The

Organizers secured business locations, filed for the appropriate liquor and business licenses, and

acquired merchant accounts and credit card terminals to be used inside the clubs. Conspirators

SIMCHUK, PAVLENKO, TAKHALOV, COGHLAN, KALDAS, ZARGARI, and other

unnamed coconspirators are Organizers and Investors in the criminal organization.

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or "B-Girls," to travel to the United States. The Organizers also rented apartments for B-Girls

during their stay in the United States, and their participation in the fraud. Defendants

SIMCHUK, TAKHALOV, COGHLAN, KALDAS, PAVLENKO, FELDMAN, ZARGARI, and

other unnamed coconspirators are Organizers and Investors in the criminal organization.

6. Some of the B-Girls were trained in Eastern Europe and the Baltic States to

conduct the fraud by working at similar clubs operated by members of the criminal organization.

B-Girls also recruit and train other B-girls overseas to participate in the criminal organization.

7. B-Girls enter the United States through the U.S. Visa Waiver Program (VWP)

with the purpose of working at the criminal organization's clubs. The B-Girls typically obtain

permission to enter the U.S. by submitting an application via the U.S. Department of Homeland

Security Electronic System for Travel Authorization (ESTA), an automated system accessible

through the internet. ESTA is used to determine the eligibility of visitors traveling to the United

States under the VWP. On the application,.B-Girls falsely declare that they are not entering the

United States for any criminal or immoral purpose, nor are they entering the United States to

seek employment.

8. Once in South Florida, B-Girls are employed to participate in the fraud by nightly

"hunting" in pairs for victims at legitimate establishments in Miami Beach. B-Girls usually

work between the hours of 10:00 PM to 5:00 AM. Initially, suitable victims are identified by

their appearance and age. B-Girls' ideal targets are wealthy males, preferrably tourists or

traveling businessmen due to the low probability that they will come back into the club once they

have discovered the money charged to their account. Expensive watches or shoes, amongst other

factors, are used to identify such targets. Defendants TURCINA, VINOGRADOVA,

KILIMATOVA, MATSOVA, ARTMEJEVA, USAKOVA, K. TAKHALOV, DOMKOVA,

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MIKRUROVA, RUDAKA, and other unnamed coconspirators are B-Girls m the criminal

organization.

9. Shortly after the introduction, B-Girls lure the victims back to one of the criminal

organization's clubs. The clubs are not open to the public, and operate solely as a front for the

fraud. B-Girls pretend to be unaffiliated with the establishment and either order, or encourage

the victims to order, multiple bottles of wine and champagne from an experienced B-girl

coconspirator who acts as the bartender/manager. Often times the victims are not told the price

(or in some cases told an incorrect price) of the alcohol. B-Girls then continue to order

numerous bottles of wine and champagne on behalf of the victim (often times without victim's

knowledge), on occasion surreptitiously pouring out drinks and contents of the bottles into

plants, ice buckets, or other receptacles so that more alcohol can be ordered.

10. The managerslbartenders at the criminal enterprise's clubs make sure to obtain a

victim's credit card and driver's license and make copies of the documents on a scanner/printer

located at the criminal organization'S private clubs. On some occasions, they also take photos of

the victims with the B-Girls at the clubs or record the events on surveillance videos. The

coconspirator managers/bartenders then bill the victim an exorbitant amount for the ordered

alcohol, for example, up to $5,000 for bottles of wine or champagne purchased by the

organization for $5 to $100. The coconspirator bar managers and bartenders charge the victims'

credit cards, typically one bottle at a time, to prevent "maxing out" the credit cards. It is

common practice of the bar managers to charge at least one cent difference for each bottle in

order to eliminate the appearance of accidental double charges to the victim's credit card. The

credit card charges are sent by wire in interstate commerce through a credit card processor.

Defendants TURCINA, VINOGRADOVA, KILIMATOV A, and MATSOVA acted as

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managerslbartenders for the criminal organization as well as working as B-Girls on occasion.

TAKHALOV, COGHLAN, KALDAS, and TAKHALOV also acted as managers of the criminal

organization's clubs.

II. The nature of the fraudulent charging of the credit cards perpetrated by the

coconspirators depends on the victim's response to the underlying fraud at the criminal

organization's clubs. Some victims are so intoxicated by the drinks forced upon them by the B­

Girls that they cannot stand and are not competent enough to sign credit card receipts. Those

victims are propped up by the B-Girls long enough to obtain signatures on credit card receipts.

In most cases, the bartender or manager explains to the victim that he agreed to purchase the

alcohol, that the bar has surveillance video of him at the bar ordering the alcohol, and demand

that he pay the bill or the local police will be called and the victim will be arrested. If necessary,

the bar calls for local police officers to arrive on scene at which point the victims pay the bills

under threat of arrest or are arrested. Consistent with Innkeepers Law, Florida Statute 509.151,

which requires patrons disputing their bill to pay the bill, the victims are told by the police

officer that their choices are either to settle the bill and handle the dispute through the credit card

company or get arrested. On occasion coconspirators at the clubs forge signatures on credit card

receipts or run the credit card 'charge through without authorization. B-Girls receive

approximately 20% of the bill to be split amongst the pair of females. Managers, who usually

work in pairs, also typically receive 10% each.

12. When a victim challenges the charge with their credit card company, members of

the criminal organization provide copies of the victim's signed receipts, driver's license, and, on

some occasions, photographs with the B-Girls as proof that the victim was responsible for the

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charges all in order to avoid any charge backs against their merchant account. To date, law

enforcement has identified approximately 88 victims defrauded at these bars.

The Investigation

13. Law enforcement conducted an investigation into the criminal organization and

the ongoing fraud at the clubs operated by the criminal organization. An undercover agent

(UC 1) was able to infiltrate the organization purporting to be a corrupt police officer working

off-duty as bouncer/doorman. UCI is in fact a local police officer. UCI typically worked from

9:00 PM to 5:00 AM the next morning. His duties, as instructed by TURCINA, included

preventing customers who were not accompanied by B-girls from entering the clubs, pretending

not to know the B-Girls by checking their identifications when they were entering the club,

ensuring that victims pay their bills by identifying himself as an officer or contacting the police if

necessary.

14. It was in the interest of the coconspirators, including identitied Organizers and B-

Girls, to confide in and obtain the trust ofUCI because they believed he was corrupt and would

maintain the fayade that B-Girls did not work at the club. He would enforce the Innkeepers Law

which requires patrons disputing their bill to pay the bill. Furthermore, UCI also provided

security for the B-Girls.

15. Since August of 2010, UCI worked for the criminal organization at the various

clubs operated by its members. As part of his duties, UC 1 transported the B-girls from their

residences to the criminal organization's clubs and from the criminal organization clubs to

legitimate bars and clubs in Miami Beach to find victims. UCI witnessed firsthand the operation

of the criminal organization and had numerous conversations with targets of the investigation,

including with defendants who described in detail the fraud, its history and their involvement in

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it. While embedded in the criminal organization, UC1 was provided audio and video recording

devices to record conversations and events at the clubs.

16. Based on the investigation to date, the FBI determined that the criminal

organization operated at least six clubs in Miami Beach: (1) Caviar Bar, located at 643

Washington Avenue, Miami Beach, FL, from approximately February 2010 to May 2010; (2)

Stars Lounge, located at 643 Washington Avenue, Miami Beach, FL, from approximately

August 2010 to October 2010; (3) a room at Club Moreno, located at 1341 Washington Avenue,

Miami Beach, FL, from approximately October 2010 to December 2010; (4) Nowhere Bar,

located at 653 Washington Avenue, Miami Beach, FL, from approximately December 22, 2010

to mid January 2011; (5) Steel Toast, located at 758 Washington Avenue; Miami Beach, FL from

approximately early January to the present; and (6) the Tangia Club located at 841 Washington

Avenue, Miami Beach, FL from approximately January 27,2011 to the present.

Fraud at Caviar Bar

17. Caviar Bar was primarily operated by SIMCHUK and PAVLENKO. A Florida

Limited Liability Company called Rose Entertainment, LLC was incorporated in October 2009.

The listed address .for Rose Entertainment was 643 Washington Avenue, Miami Beach, FL

33139. In February of 2010, the City of Miami Beach issued a liquor license to Rose

Entertainment, LLC in care of PAVLENKO, doing business as Caviar Bar at that location. On

February 22, 2010, PA VLENKO filed incorporation documents for Caviar Bar listing himself as

the owner. On February 23,2010, PAVLENKO signed as owner a certificate of use for alcohol

at Caviar Bar. Additionally, Rose Entertainment LLC opened an account at Wachovia Bank

xxx1474 on March 11, 2010. PAVLENKO was described as the owner of the business. In

addition, PAVLENKO obtained at least one of the merchant accounts for Caviar Bar.

 18. The FBI investigation identified numerous victims of the fraud at Caviar Bar

including:

a) lB., who is from Philadelphia, was defrauded at Caviar Beach for approximately
$43,000. During the evening of March 28, 2010, J.B. was approached at the
Delano Hotel by two females subsequently identified as TURCINA and
KILIMATOV A. lB. drank some wine with the females then was given one shot
of alcohol and became woozy. His fuzzy recollection was of people physically
holding him up at an unknown location and having him sign something three
times. He awoke the next day in his hotel room with an unknown painting and
missing cash and items. J.B. received a voicemail at his hotel room from
TURCINA who said the females inadvertently took his sunglasses. TURCINA
confirmed lB. purchased the painting the previous night but agreed to meet him
to return property they claim was unintentionally taken. The females took him to
the Caviar Bar where he again became woozy after some drinks and found
himself later back in his hotel. J.B. learned a few days later that his American
Express credit card had been charged illegally without his authorization -- five
times on March 28, 2010 for a total of $16,51 7.37 and 7 times on March 29, 2010
for a total of $27,194.88. Each charge was for approximately $2,000-$4,000 and
most were for one bottle of alcohol. 1.B. was also charged $2,480 in one
transaction for a painting. 1.B. disputed the charges with his credit card
company. The company stated that "Stan" (PAVLENKO), at the Caviar Bar, had
provided photographs of 1.B. embracing females inside the Caviar Bar as well as
copies of his driver's license as proof of the validity of the charges. The victim
continues to dispute the charges noting that he does not carry his driver's license
when he goes out and believes it was taken from his hotel room and that he was
drugged by the females.

b) On March 22, 2010, R.M., who is from Minnesota, was at the Delano Hotel bar
when two females, one named "Marina LNU" (believed to be TURCINA),
approached him. The females eventually took him to the Caviar Bar. There,
"Marina" ordered a bottle of champagne. R.M. had one glass. R.M. was provided
a bill of $507.00 and refused to pay. Eventually, he agreed to pay $85.00 for his
glass. The manager made a copy of R.M.'s Amex card and driver's license. R.M.
signed the $85.00 receipt. However, R.M. later discovered that his credit card
was later charged $85 and $507.00. The second charge was not signed nor
authorized by R.M.

19. On numerous occasions, members of the criminal organization, including some of

the Defendants, discussed with UC 1 the fraud which occurred at Caviar Bar under the direction

of SIMCHUK and PAVLENKO. For example:

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 a) On approximately September 28, 2010, COGHLAN told UCI that SIMCHUK's
previous club was run by PAVLENKO.

b) On February 22, 2011, KILIMATOVA met UCI for dinner and told UCI she
used to work at Caviar Bar with PA VLENKO.

c) On March 9, 2011, KILIMATOVA told UCI that she and TURCINA were
involved in defrauding lB. and noted that they even sold lB. a painting from the
wall of the club.

The Continued Fraud at Subsequent Bars

20. The criminal organization ceased operations at Caviar Bar in May of 2010,

largely due to American Express closing its merchant accounts and due to large volume of

charge-backs from victims claiming unauthorized and fraudulent activity on their credit cards.

The criminal organization, however, continued to perpetrate the fraud at other clubs, seizing and

resuming operation as necessary, with the B-Girls relocating from one club to another. In

particular, the fraud continued at Stars Lounge, Club Moreno, Nowhere Bar, Steel Toast, and

Tangia Club, which was opened by K&S Entertainment Inc., which lists ZARGARI as an officer

of the corporation.

21. UCI witnessed the B-Girls participate in the fraud at aforementioned clubs. On

numerous occasions the B-Girls, including some of the defendants, admitted to UC 1 their

involvement in the fraud. For example:

a) On August 23, 2010, TURCINA told UCI that it was difficult to run the business
with only a handful of B-Girls present. She added that the girls were looking for
victims not from Miami.

b) On the evening of September 19,2010, ARTEMJEVA told UCI that she and
another B-Girl made $400 each for one night as a customer bought three bottles of
wine and a bottle of champagne. ARTEMJEVA said she worked for SIMCHUK
for approximately four years and that police raided SIMCHUK's clubs in Estonia.
She also stated that SIMCHUK only brings the best girls from Estonia to Miami.

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 c) On September 28, 20 lo, VINOGRADOVA told UCI that she was mad at
SIMCHUK as even though she had worked for him for years, SIMCHUK still
owes her and TURCINA money from the last time the two were in Miami.

d) On the evening of October 19, 20 I 0, an uncharged B-Girl told UC I that the girls
were afraid to work the Miami clubs because the prices of the bottles are so
significantly increased that it is too obvious. She said that a bottle that would go
for $2,000.00 in a club in Europe will go for $7,000.00 in Miami. She said thcy
were also afraid because there were so many declined credit cards and that Star
Lounge was selling bottles for $300.00 that they were buying at CVS Pharmacy
for $6.00.

e) On October 21, 2010, USAKOVA told UCI that the organization was having
trouble getting new girls into the U.S. and thus SIMCHUK wanted USAKOV A,
DOMKOVA, and MATSOVA to remain in U.S. longer. She stated the girls are
not happy the way SIMCHUK is treating them, but feel they have to stay because
he purchases their return flight tickets and holds them.

f) On November 10,2010, MATSOVA, DOMKOVA, and USAKOVA told UCI

that they plan to work at SIMCHUK's new club in Prague. They also discussed
one of the B-Girls attempting to enter the United States on a visa waiver and was
not admitted because she indicated she was working in the United States.

g) On March 18, 2011, KILIMATOVA informed UCI that she personally recruited
other B-Girls to work at the clubs. She admitted that in the short time the other B­
Girl worked for the criminal organization, she made approximately $4,000. She
added that in this line of business, it is better to only be open for a few months,
then close and switch locations as that is what they would do with clubs overseas,
staying open a maximum of six months. She also admitted that the Tangia Club
was on its final credit card terminal and once it was used up, they would have to
find another location.

h) On March 26,2011, RUDAKA admitted to UCI she used to work for SIMCHUK
at Caviar Bar and taught other B-Girls how to participate in the fraud.
SIMCHUK tried to get her to work at Stars Lounge but she declined but did
eventually agree to work at Tangia Club for the criminal organization.

i) On February 16, 2011, ARTMENJEV A told UC 1 that an unnamed coconspirator

was the one with all the money as he pays for the B-Girls tickets and rents the
club at Steel Toast

22. UC 1 witnessed the Organizers and Investors participate m the fraud. For

example:

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 a) On the evening of August 21, 2010, UC1 heard SIMCHUK tell B-Girls at the
Stars Lounge that whoever made the most money will be granted the privilege of
operating out of Stars Lounge which was a more desirable location than other
clubs.

b) On September 16, 2010, UCI overheard TAKHALOV, FELDMAN, and other

coconspirators talking at Stars Lounge about using Star Lounge's credit card
terminals. TAKHALOV also told FELDMAN that they instructed the girls that
subsequent credit card charges should be a cent less than the prior charge.

c) On September 28, 2010, during an inspection by fire marshals, TAKHALOV

represented himself as the manager or owner of the Stars Lounge.

d) On various occasions, UCI witnessed TAKHALOV installing or fixing credit

card terminals at some ofthe Clubs.

e) On February 2, 2011, UCI overheard TAKHALOV and KALDAS discussing the

Tangia Club and say that they needed more girls, especially girls with more
experience.

f) On February 5, 2011, KALDAS was at Tangia Club when a Victim AW.

provided a Platinum American Express card. UCI overheard KALDAS state that
he wanted to charge additional bottles on the victim's credit card.

g) On February 21, 2011, at one of the clubs, KALDAS was confronted by a victim
of the fraud who claimed the B-Girl worked for club but KALDAS denied it.

h) On March 19, 2011, ZARGARI contacted VCl about a victim who was disputing
his bill at a club and wanted him arrested.

i) On March 26, 2011, ZARGARI took a cell phone from a victim at the club and
later stated that he had done so in order to use it as evidence against the victim
, challenging the charges with his credit card company.

j) On February 20, 2011, UC1 overheard TAKHALOV and ZARGARI at Tangia

Club, laughing about how they give customers shots of vodka to get them drunk
and girls only get water and commenting that K. TAKHALOV must be careful
not to mix it up.

23. VCI also identified and spoke with various Organizers at the clubs. They

described the history of the criminal organization and the fraudulent scheme and admitted their

involvement in the fraud as well as the involvement of other coconspirators. For example:

IJ
 a) On the evening of August 21, 2010, UCI was introduced to SIMCHUK as the
O\\lner of Stars Lounge.

b) On the evening of October 14,2010, TAKHALOV told UCI that he works in the
banking industry and credit card processing industry and that he has the data
processing portion of the organization which processes the credit cards charged at
the bar, a service that no one else in the organization can offer.

c) On the evening of February 19, 2010, TAKHALOV told UCI that the B-girls get
20% of a bill which they split and B-Girls who work as managerslbartenders for
the night, including MATSOVA and KILIMATOVA, get 10%.

d) On the evening of October 12, 2010, TAKHALOV told UCI he loaned

FELDMAN money so he could be a partner at Stars Lounge.

e) On February 18, 2011, COGHLAN told UCI that FELDMAN initially recruited
her to maintain books at Stars Lounge.

f) On September 13,2010, FELDMAN asked UCI ifhe could run checks on the B­
girls to make sure they had no prior history of prostitution. FELDMAN wanted
UC 1 and not the City of Miami Beach to do checks.

g) On September 28, 2010, SIMCHUK, FELDMAN and TAKHALOV urged UCI

to find another officer to work his off nights who was "trustworthy."

h) On February 19,2011, TAKHALOV told UCI that RASNER is a partner in the

club and RASNER is a silent partner in both clubs.

i) On December 20, 2010, COGHLAN told UC1 they intended to reopen business
on Tangia Club with KALDAS and 12 girls and that COGHLAN was going to be
silent partner in new club while here KALDAS and RASNER will operate it.

24. UC I witnessed the coconspirators, including some of the defendants, working at

these clubs and perpetrating the fraud on victims at those clubs. For example:

a) On August 28, 2010, D.P., who is a German national and pern1anent resident of
Chile, was picked up by VINOGRADOV A and another B-Girl, and taken to Stars
Lounge. D.P. purchased a bottle of wine, was charged $151. 72 for the bottle, and
while closing out his tab, was given three shots of vodka. D.P. could not
remember anything after that. He was observed by UC1 falling down. UCI also
witnessed D.P. attempt to leave the club, but PETUHOVA coaxed him back in.
D.P.'s credit card was charged four times for USD $151.72, $706.32, $1,595.76,
and $1,427.02 (a total $3,880.82), charges which he did not authorize and which
left him with $50 left on his card limit.

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 b) On September 25,2010, T.C., who resides in New Jersey, was at the Clevelander
Bar with his friends when two women approached him claiming to be from
Denmark. The females wanted to leave to go to their hotel room but instead took
them to Stars Lounge. No other patrons were there. A waitress, identified by
UC 1 as MATSOV A, placed wine on the table that they had not ordered. The girls
poured drinks and persuaded T.C. to drink some of it. He excused himself, went
to the bathroom, and asked for the check on his return. The bill was for $388.47.
He tried to negotiate a lower price but the waitress refused. T.C. refused to pay
and a uniformed police officer arrived and transported him to Miami Beach Police
department where he was interviewed. T.C. noticed on his credit card account a
pending charge of $388.47 from Stars Lounge. He disputed the charges as
unauthorized.

c) On October 12, 2010, K.W., who lives in Texas, was at the Delano Hotel with
two friends. Two girls approached who claimed they were from Finland. After
encouraging him to drink, the girls took him to Stars Lounge. K.W. felt more
drunk than usual but when he got the bill it was for over $3,000.00. He refused to
sign and the police were called. K. W. was told it was a civil matter and he had to
pay and then could dispute charges later. K.W. ended up in a taxi and is not sure
how he got back to the hotel as he blacked out. Credit cards show charges for
$1,045.09, $1,045.09 and $1,045.08. UCI identified DOMKOVA as one of the
female B-Girls who victimized K. W.

d) On February 11, 2011, B.E. and his roommate J.T. were in Miami Beach on
vacation. That night, at approximately 10:30 PM, B.E. and J.T. were at the
Clevelander Bar where two females later identified by UC 1 as USAKOV A and
MATSOVA took them to the Tangia Club. There, J.E. noticed the bartender who
was later identified as K. TAKHALOV. As soon as the B-Girls ordered
champagne, J.T. inquired regarding the price of the bottle and was told by K.
TAKHALOV it was "799." B.E. clarified that it was "$7.99" several times. K.
TAKHALOV agreed. B.E. then provided his bank card and driver's license.
B.E. agreed to purchase a second bottle then was informed his debit card was
declined as the bill was for $1,097.09. B.E. told K. TAKHALOV that he was told
it was "7.99" and demanded to see the manager. Eventually the manager agreed
to drop the bill to $915.50. At the same time, USAKOVA rubbed B.E.'s back to
console him while MATS OVA told J.T. to just sign the credit card receipt. J.T.
signed the credit card receipt after the conspirators warned that he could be
arrested if he did not.

e) On February 6, 2011, A.W. met two Russian females at Club Mokai in Miami
Beach. Shortly after, the females suggested going to another place they knew,
and walked AW. to the Tangia Club. UCI identified the females as
MIKRUKOVA and USAKOV A AW. remembers leaving the club when it was
light out, and barely remembers getting home. Once awake, A. W. found that he
had two credit card slips in his wallet, for approximately $5,000. His credit card

13

 company later informed him that the club attempted to charge him $16,000 but it
was declined. AW. continues to dispute the charges as unauthorized.

f) On February 14,2011, T.W., met some B-Girls who brought him to Steel Toast.
He noticed that there were no other customers in the club. T W. ordered a beer,
and went to the restroom. Upon his return, the females had a bottle of champagne
that they insisted on him opening for them. T. W. initially refused, stating he did
not drink champagne, but finally agreed. Almost immediately, VINOGRADOVA
told T. W. that he had to pay $700 for the bottle. T W. refused and tried to exit the
establishment. VINOGRADOVA directed the unnamed bouncer to stop T.W.
The bouncer kept TW. from leaving and choked him to the point where T.W.
began to lose consciousness. When police arrived, T. W. provided his credit card
to the bartender as to avoid being arrested. The bar attempted to charge TW.'s
card $1,000 but it was declined. Ultimately the club charged $300, which was the
daily limit on T.W.'s card. T.W. believes he had approximately $1,400 and a cell
phone taken off his person while he was unconscious. UCI responded to the club
and was able to identifY TURCINA working as the bartender and
VINOGRADOV A as the server.

g) On March 19,2011, J.O. was at a hotel bar in Miami Beach. B-Girl RUDAKA
approached him and took him to Tangia Club. J.O. ordered a beer and RUDAKA
ordered a glass of wine. RUDAKA forced the glass of wine in his hand. 1.0. was
charged approximately $374, which included $286 for the bottle of wine. There
was also a charge of $52 for a hookah pipe which was not ordered by anyone.
1.0. disputed the charges stating that he did not order the wine or the hookah
pipes. 1.0. requested the police arrive. UCI arrived. 1.0. eventually signed two
credit card slips and disputed the charges the next morning.

25. Law enforcement agents also posed as victims of the criminal organization. For

example, on the night of October 19, 2010, an undercover agent (UC2) met DOMKOVA and

MATSOV A at the Blue Door bar at the Delano Hotel. DOMKOV A urged DC2 to go to Stars

Lounge. UC2 ordered one bottle, danced with the females and observed the females pour out the

champagne into buckets. Two more bottles were brought although UC2 did not order them.

When it came time for the bill, which totaled $3,135.24 between three receipts, UC2 refused to

pay for the last two bottles. An argument ensued with the server. DOMKOVA told UC2 that he

was acting like a rude, stupid American. UC2 accused both of them of being employees of the

bar. MATSOV A denied it saying she had only been there once. UC2 agreed to pay for one bill

but refused to pay the bill for the unordered bottles. The police were called and UC2 was

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arrested as had been prearranged. His credit card was charged for all three bills. UC2's name

was forged on at least one of the receipts.

26. While working for the criminal organization, UC 1 witnessed B-Girls periodically

getting paid. For example, on one occasion at Stars Lounge, UCI witnessed one uncharged

coconspirator with envelopes for various B-Girls including VINOGRADOV A. The individual

would withdraw an envelope, open it and hand the' money to the B-Girls. The B-Girls then

returned some of the money to her.

27. UCI also obtained pills at some of the criminal organization's clubs. On March

8, 2011, UC 1 told KILIMA TOV A at the Club Tangia that he had a headache and she gave him

some pills from a bottle of Tylenol PM directly next to the register. She warned him that it

would put him to sleep. UC 1 also went to Steel Toast and observed a bottle of natural herbal

sleep aid located next to the register. UC 1 told VINOGRADOV A that he was having difficulties

sleeping and asked if she could give him one of the pills. VINOGRADOV A did and warned

UC I not to take too many because it would knock him out. On March 15, 2011, KILIMA TO VA

provided UCI with capsules believed to be tranquilizers. UCI had been told previously by

coconspirators that KILIMA TOV A has drugged victims in the past.

Bribery in Furtherance of Fraud

28. As noted previously, one of the B-Girls was not permitted to enter the United

States under VWP. The B-Girl, who had submitted an ESTA VWP application, was interviewed

during secondary inspection at the Miami International Airport and admitted that she was

working in the United States.

29. On January 25,2011, TAKHALOV told the UCI that he had five girls scheduled

to fly into the U.S. on January 27, 2011 MATSOVA, DOMKOVA, USAKOVA,

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MIKRUKOVA, and a fifth uncharged B-Girl. TAKHALOV wanted UC 1 to have a U.S.

Immigration and Customs (ICE) Agent assist with getting the aforementioned B-Girls through

customs. TAKHALOV was under impression that UCI had a good relationship with the ICE

Agent. TAKHALOV wanted to make sure that the B-Girls are admitted in the United States as

the criminal organization lost a significant amount of money in the past, when B-Girls were not

admitted into the country.

30. On March 14, 2001, TAKHALOV spoke to UCI and confirmed that he would

provide money to let the B-Girls into the United States. He also stated that two Estonian girls

from MATSOVA's crew and three Latvian girls from KILIMATOV A's crew will be arriving in

a week or so.

31. On March 16,2011, KALDAS spoke with UCI at Tangia Club and discussed the

upcoming payment to the ICE Agent. KALDAS indicated they would provide the money the

following week.

32. On March 22,2011, UCI met TAKHALOV at Tangia Club. Also present in the

club were KALDAS, and ZARGANL UCI told TAKHALOV that the ICE Agent did not want

to personally meet him. During the meeting, TAKHALOV pulled UCI aside, paid him $1,000

and thanked him.

Conclusion

33. Based upon the forgoing facts, I assert that there is probable cause to believe that

Alec SIMCHUK aka "Alex," Albert TAKHALOV ("TAKHALOV"), Svetlana COGHLAN,

Isaac FELDMAN, Stanislav PAVLENKO, Fady KALDAS, Siavash ZARGARI aka "Sammy,"

Marina TURCINA, Julija VINOGRADOVA, Anna KILIMATOVA, Valeria MATSOVA,

Victorija ARTEMJEVA, Anastassia USAKOV A, Kristina T AKHALOV ("K. TAKHALOV"),

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Irina DOMKOVA, Anastassia MIKRUKOV A, and Agnese RUDAKA, within the Southern

District of Florida and elsewhere, committed violations of federal law, namely, Title 18, United

States Code, Section 1349.

Alexander V. Tiguy, Sp . I Agen

Federal Bure Investigation

Sworn to before me this L day of April, 2011

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