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CASENO. j 7 . 6 p j a g ;q-NILLIAgs
18UU.S.C.j371
18 /TORRF.
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N
-Qk ...
S.C.j1542
.
18U.S.C.j982(a)(6)
UNITED STATES O F AM ERICA
VS.
VLAD IM IR N EVID O M Y,
VER A M U ZY IQA ,and
D AR IA ER SH O V A ,
D efendants.
/
IND ICTM E NT
COUNT 1
C onspiracy to C om m itan O ffense A gainstthe U nited States
(18U.S.C.j371)
Begilm ing atleastasearly ason oraboutApril28,2014, the exad date being unknow n to
the Grand Jury,and continuing through on or about M ay 6, 2016, in Brow ard County,in the
V LA D IM IR N EV ID O M Y ,
VER A M U ZYK A,and
DA R IA ER SH O VA ,
did knowingly and w illfully com bine,conspire,confederate, and agree w ith each other and w ith
otherpersons know n and unknow n to the G rand Jm y to com m it an offense againstthe United
States,thatis,to w illfully and know ingly m ake a false statem entin an application for a passport
Case 0:17-cr-60137-KMW Document 3 Entered on FLSD Docket 05/31/2017 Page 2 of 16
with theintentto induce and secure the issuanee ofa passportunderthe authority ofthe United
presclibed pursuantto such law s,in violation ofTitle 18,United States Code,Section 1542.
A C TS IN FU R TH ER AN CE O F TH E C O N SPIM C Y
VLA D IM IR NEV IDO M Y falsely and fraudulently represented thathe had personally w itnessed
the non-applying parent sign the D 5-3053 Statem ent of Consent w hen he had not personally
promised to prepare documents and othem ise assistin obtaining a United Statespassportfora
NEV IDO M Y falsely and fraudulently represented that he had personally w itnessed the non-
DA RIA ERSH O V A falsely and fraudulently represented thatshe had personally witnessed the
non-applying parent sign the 175-3053 Statem ent of Consent w hen she had not personally
D A RIA ER SH O V A falsely and fraudulently represented thatshe had personally w itnessed the
non-applying parent sign the D5-3053 Statem ent of Consent w hen she had not personally
NEV IDO M Y inform ing him thatthe non-applyingparentw ould notbepresentw hen the passport
application w as filed for a m inor child,thatthe non-applying parenthad notsigned the consent
form ,and thatVE R A M U ZY IG had prom ised thatthe com pany w ould take care ofthe issue.
N EVIDO M Y infonning him thata non-applying parentwould notbe presentw hen the passport
application w as filed for a m inor child and thatV LA D IM IR NEV ID O M Y w ould need to take
VLA DIM IR N EV ID O M Y falsely and fraudulently represented thathe had personally w itnessed
the non-applying parent sign the 175-3053 Statem ent of C onsent when he had not personally
COUNT 2
M aking a False Statem entin PassportA pplication
(18U.S.C.j 1542)
O n or aboutM ay 28,2014,in Brow ard County,in the Southern D istrict of Florida, and
elsewhere,the defendant,
V LAD IM IR N EV ID O M Y ,
3
Case 0:17-cr-60137-KMW Document 3 Entered on FLSD Docket 05/31/2017 Page 4 of 16
to induce and secure the issuance ofa passportunderthe authority oftheU nited Statesforthe use
of another, contrary to the law s regulating the issuance of passports and the nlles prescribed
pursuant to such law s,in that he represented that he had personally w itnessed a non-applying
wellknew ,he had notpersonally w itnessed a non-applying parentsign the 175-3053 Statem entof
Consent,in violation ofTitle 18,U nited States Code,Sed ions 1542 and 2.
COUNT 3
M aking a False Statem entin PassportA pplication
(18U.S.C.j 1542)
On or about June 3,2014,in Broward County,in the Southern D istrict of Florida, and
elsewhere,the defendant,
V LA D IM IR N EVID O M Y ,
did w illfully and know ingly m ake a false statem entin an application fora passportw ith the intent
to induce and secure the issuance ofapassportunderthe authority ofthe United Statesforthe use
of another, contrary to the law s regulating the issuance of passports and the rules prescribed
pursuant to such law s,in that he represented that he had personally w itnessed a non-applying
parentsign the 175-3053 Statem entofConsent,w hen in truth and in fact, and ashe then and there
C O UN T 4
M aking a False Statem entin PassportA pplication
(18U.S.C.j1542)
On or aboutSeptem ber 24,2014,in Brow ard County,in the Southern D istrictofFlorida,
4
Case 0:17-cr-60137-KMW Document 3 Entered on FLSD Docket 05/31/2017 Page 5 of 16
V LA DIM IR NEV ID O M Y ,
did w illfully and know ingly m ake a false statem entin an application for a passportw ith the intent
to induce and secure the issuance ofa passportunderthe authority ofthe United States forthe use
of another,contrary to the law s regulating the issuance of passports and the rules prescribed
pursuant to such law s, in that he represented that he had personally w itnessed a non-applying
parentsignthe135-3053 StatementofConsent,when in truth and in fact, and ashe then and there
wellknew ,he had notpersonally w itnessed a non-applying parentsign the D 5-3053 Statem entof
CO UN T 5
M aking a False Statem entin PassportA pplication
(18U.S.C.j 1542)
On oraboutOctober29,2014,in Broward County,in theSouthern DistrictofFlorida, and
elsewhere,the defendant,
V LAD IM IR N EV ID O M Y ,
did willfullyand knowingly m akea false statem entin an application forapassportwith theintent
to induce and secure the issuance ofa passportunderthe authority ofthe United Statesforthe use
of another,contrary to the law s regulating the issuance of passports and the rules presclibed
pursuant to such law s,in that he represented that he had personally w itnessed a non-applying
w ellknew ,hehad notpersonally w itnessed a non-applying parentsign the 135-3053 Statem entof
CO U N T 6
M aking a False Statem entin PassportA pplication
(18U.S.C.j1542)
On oraboutJanuary 20,2015,in Brow ard County,in the Southern D istrictofFlorida, and
VLA D IM IR N EV ID O M Y ,
did willfully and know ingly m ake a false statem entin an application fora passportwith the intent
to induce and secure the issuance ofa passportunderthe authority ofthe U nited States forthe use
of another, contrary to the law s regulating the issuance of passports and the rules prescribed
pursuant to such law s,in that he represented that he had personally w itnessed a non-applying
parentsign the 175-3053 Statem entofConsent,w hen in truth and in fact,and as he then and there
wellknew ,he had notpersonally w itnessed a non-applying parentsign the 175-3053 Statem entof
C O UN T 7
M aking a False Statem entin PassportA pplication
(18U.S.C.j 1542)
On oraboutJune 4,2015,in Broward County,in the Southem DistrictofFlorida,and
elsewhere,the defendant,
V LAD IM IR NEV ID O M Y ,
did w illfully and know ingly m ake a false statem entin an application for apassportw ith the intent
to induce and secure the issuance ofapassportunderthe authority ofthe United States forthe use
of another,contrary to the law s regulating the issuance of passports and the rules prescribed
pursuant to such law s,in that he represented that he had personally w itnessed a non-applying
parentsign the 175-3053 Statem entofC onsent,when in truth and in fact, and ashe then and there
Case 0:17-cr-60137-KMW Document 3 Entered on FLSD Docket 05/31/2017 Page 7 of 16
w ellknew ,he had notpersonally w itnessed a non-applying parentsign the D 5-3053 Statem entof
C O U NT 8
M aking a False Statem entin PassportA pplication
(18U.S.C.j 1542)
On oraboutA ugust28,2015,in Brow ard County,in the Southern D istrictofFlorida,and
elsewhere,the defendant,
DA R IA ER SH O VA ,
did willfully and know ingly m ake a false statem entin an application fora passportw ith the intent
of another, contrary to the law s regulating the issuance of passports and the rules prescribed
pursuantto such law s,in thatshe represented thatshe had personally w itnessed a non-applying
parentsign the 135-3053 Statem entofConsent,w hen in trtlth and in fact,and as she then and there
w ellknew ,she had notpersonally witnessed a non-applying parentsign the D 5-3053 Statem ent
C O UN T 9
M aking a False Statem entin PassportA pplication
(18U.S.C.j 1542)
On oraboutSeptem ber21,2015,in Broward County,in the Southem DistrictofFlorida,
D AR IA ER SH O V A ,
did willfully and know ingly m ake a false statem entin an application fora passportw ith the intent
to induce and secure the issuance ofa passportunderthe authority ofthe U nited Statesforthe use
of another, contrary to the law s regulating the issuance of passports and the nzles prescribed
pursuantto such law s,in thatshe represented thatshe had personally witnessed a non-applying
Case 0:17-cr-60137-KMW Document 3 Entered on FLSD Docket 05/31/2017 Page 8 of 16
parentsign the175-3053 Statem entofConsent, when in truth and in fact,and asshe then and there
w ellknew ,she had notpersonally w itnessed a non-applying parent sign the 175-3053 Statem ent
C O U NT 10
M aking a False Statem entin PassportA pplication
(18U.S.C.j1542)
On oraboutSeptem ber2 l,2015,in Brow ard County, in the Southern DistrictofFlorida,
and elsewhere,thedefendant,
DA R IA ER SH O V A ,
did w illfully and know ingly m ake a false statem entin an application for apassportw ith the intent
to induce and secure the issuance ofapassportunderthe authority ofthe U nited States forthe use
of another,contrary to the law s regulating the issuance of passports and the rules prescribed
pursuantto such law s,in thatshe represented thatshe had personally w itnessed a non-applying
parentsignthe 175-3053 Statem entofConsent,when in truth and in fact, and asshe then and there
CO U N T 11
M aking a False Statem entin PassportA pplication
(18U.S.C.j 1542)
O n or aboutN ovem ber 16,2015,in Brow ard County,in the Southern Districtof Florida,
and elsewhere,thedefendant,
DA R IA ER SH O V A ,
did w illfully and know ingly m ake a false statem entin an application for apassportw ith theintent
to induceand secure the issuance ofa passportunderthe authority ofthe United Statesforthe use
of another,contrary to the law s regulating the issuance of passports and the rules presclibed
8
Case 0:17-cr-60137-KMW Document 3 Entered on FLSD Docket 05/31/2017 Page 9 of 16
pursuantto such laws,in thatshe represented thatshe had personally witnessed a non-applying
parentsign the 175-3053 Statem entofConsent,w hen in truth and in fact,and asshe then and there
wellknew ,she had notpersonally witnessed a non-applying parent sign the 135-3053 Statem ent
CO UN T 12
M aking a False Statem entin PassportA pplication
(18U.S.C.j1542)
On orabout Decem ber 15,2015,in Broward County,in the Southern D istrid ofFlorida,
D AR IA ER SH O VA ,
to induce and securethe issuance ofa passportunderthe authority ofthe U nited States fortheuse
of another,contrary to the law s regulating the issuance of passports and the rules prescribed
pursuantto such law s,in thatshe represented thatshe had personally w'itnessed a non-applying
parentsign the 175-3053 Statem entofConsent,when in truth and in fact,and as she then and there
w ellknew ,she had notpersonally w itnessed a non-applying parentsign the 175-3053 Statem ent
C O UN T 13
M aking a False Statem entin PassportA pplication
(18U.S.C.j 1542)
On oraboutFebruary 2,2016,in Brow ard County,in the Southern D istrictofFlorida,and
elsewhere,thedefendantk,
V LA DIM IR N EV ID O M Y and
V ER A M U ZY K A ,
did w illfully and know ingly m ake a false statem entin an application fora passportw ith the intent
to induce and secure the issuance ofa passportunderthe authority ofthe U nited Statesforthe use
9
Case 0:17-cr-60137-KMW Document 3 Entered on FLSD Docket 05/31/2017 Page 10 of 16
of another,contrary to the law s regulating the issuance of passports and the rules prescribed
pursuantto such laws,in thatthe defendantrepresented thathe had personally witnessed a non-
applyingparentsign the 175-3053 Statem entofConsent,when in tnzth and in fact, and ashe then
and there w ell knew ,he had notpersonally w itnessed a non-applying parent sign the 175-3053
CO UN T 14
M aking a False Statem entin PassportA pplication
(18U.S.C.j1542)
On oraboutFebruary 4,2016,inBroward County,in theSouthern DistrictofFlorida, and
VLA D IM IR N EV ID O M Y and
V ER A M U ZY IQA,
did willfully and knowinglym ake afalse statem entin an application forapassportwiththeintent
ofanother,contrary to the laws regulating the issuance of passports and the rules prescribed
pursuantto sueh law s,in thatthe defendantrepresented thathe had personally w itnessed a non-
applying parentsign the 175-3053 StatementofConsent,when in truth and in fad , and ashethen
and there wellknew,he had notpersonally witnessed a non-applying parentsign the 135-3053
Statem entofConsent,in violation ofTitle 18,U nited States Code,Sections 1542 and 2.
C O UN T 15
M aking a False Statem entin PassportApplication
(18U.S.C.j1542)
O n or about M ay 6,2016,in Brow ard County,in the Southem D istrict of Florida, and
elsewhere,the defendant,
D A RIA ERSH O VA ,
10
Case 0:17-cr-60137-KMW Document 3 Entered on FLSD Docket 05/31/2017 Page 11 of 16
D AR IA E RSH O V A,
did w illfully and know ingly m ake a false statem entin an application fora passportwith the intent
to induce and secure the issuance ofa passportunderthe authority ofthe U nited Statesforthe use
of another, contrary to the law s regulating the issuance of passports and the nzles prescribed
pursuant to such law s,in thatshe represented that she had personally w itnessed a non-applying
parentsign the 175-3053 Statem entofConsent,w hen in truth and in fad , and as she then and there
wellknew ,she had notpersonally w itnessed a non-applying parent sign the 175-3053 Statem ent
The allegations of this Indictm ent are re-alleged and by this reference fully
theUnited Statesthefollowing:
b) anyproperty,realOrpersonal,
thatconstitutes,orisdelived from oristraceable to the proceedsobtained
Code,Section982(b)(1).
A TRU E BILL
FoR
-UPERsox
t .
szztk >Jz.(..
BEN JA M W G .GREEN BERG
TIN G UN ITED STA TES A TTO RN EY
JESSICA KA HN O BEN AU F
A SSISTA N T UN ITED STA TES A TTO RN EY
12
UNITED STATES DISTRICT COURT
Case 0:17-cr-60137-KMW Document 3 Entered
SOUTHERN DISTRICTon
OFFLSD
FLORIDocket
DA 05/31/2017 Page 13 of 16
CourtDivision:(Sel
ectOne) New Defendantts)
N Yes No
um berofNew Defendants
Totalnumberofcounts
Mi
FTaLmi w
KeIBWest FTp
Ido hereby cedify that:
Ihave carefull
y considered the allegations ofthe indictmeqt,the num berofdefendants,the num ber
Ofprobable witnesses and the Iegalcom plexitiesofthe Indlctment/lnform ation attached hereto.
2. Iam aware thatth: informati on suppliedoq this jtqtemeqtwillbe relied uponbythe Judgesofthis
Coud in setting thelrcal:ndars and schedullng crlmlnaltrlals underthe m andate ofthe Speedy Trial
Act,Title 28 U.S.C.Sectlon 3161.
Iqterpreter: (YesqrNo) Yes
LIstIanguage and/ordlalect usslan
4. Thi
s case willtake 4-5 daysforthe parties to try.
Please check appropriate category and type ofoffense Iisted below:
(Checkonl
yone) (Checkonl
yone)
I 0 to 5days x Pftty
11 6 to 10 days Mlnor
III 11to 20 days Mlsdem .
IV 21to 60 days Felony x
V 61days and over
6.
If Hasthiscasebeenpreviouslyfiledinthis DistrictCourt? (YesorNo) No
yes:
Judge: Case No.
(Attach copy gfdispositi
ve?rdel)
Hasacomplalntbeenfiled Inthlsmatter? (YesorNo) No
Ifyej:
Maglstrate Case No.
Related Misc:llaneous numbers:
DlfendantisllInf
se
Rule 20 from the
td
at
era
cl
uc
su
to
sd
to
yda
ysao
sfof Is rIc O
--
lsthisa potentialdeathpenaltycase?(YesorNo) No
Dges this case originate from a matterpending in the Northern Region ofthe U.S.Attorney's Office
prlorto October14-,2003:2 Yes x No
JE I H BENAU F
ASSI ANT UNITED STATES ATTORNEY
Florida BarNo.0052716
*penaltySheetts)attached REV4/8/08
Case 0:17-cr-60137-KMW Document 3 Entered on FLSD Docket 05/31/2017 Page 14 of 16
Defendant'sN am e: V LA D IM IR N EV ID OM Y
Case N o:
Count:l
Counts:2-7,13-14
PEN AL TY SH EET
D efendant's N am e: V ER A M U ZY K A
C ase N o:
Count:1
Counts:13,14
PEN AL TY SH E ET
C ase N o:
Count:1
Counts:8-12,15