Approved: JOANNA C. HENDON
Assistant United States Attorney
BefQre ; HONORABLE KEVIN NATHANIEL FOX
United States Magistrate Judge
Southern Dietrict of New York
SEALED COMPLAINT
UNITED STATES OF AMERICA, : Violation of
25 U.S.C. BB 7Bj
V. 78ff; 17
240.1Ob; and
IRA MONAS, 18 U.S.C. 8
:
Defendant. :
'--'-~---'--""-----"-----------x COUNTY OF OFFENSE:
NEW YORK COUNTY AND
ELSEWHERE
SOUTHERN DISTRICT OF NEW YORK, 6s.:
John B. Keelan IIZ, being duly rwomd deposes and
(Fraud In Connection With
The Sale of Securities of United Postal Servic#,
1. From in or about August 1999 up to and including
the present, in the Southern District of New York and
IRA MONAS, the defendant, unlawfully, wilfully, and
the use of the means and instrumentalities of interstate
commerce, the mails, and facilities of national
exchanges, directly and indirectly did use and employ,
manipulative and deceptive devices and contrivances,
of Title 17, Code of Federal Regulations, § 240.10b-5,
employing devices, schemes, and artifice6 to defraud,
untrue statements of material fact and omitting to
facts necessary in order to make the statements
the circurwtances under which they were made, not misleading,
(3) engaging in acts, practices, and courses of business which
operated and would operate as a fraud and deceit upall other
persons in connection with the purchase and sale of securities,
to Wit, MONAS caused registered representatives and
solicit public cuetomers to purchase securities in
oversubscribed initial public offering (ItIPO") of United
Service, Inc., when in fact MONAS knew that he had no accuse to
such securities and instead used the customers'
personal and business debts.
(Title 15, United States Code, Sections 7Bj(b) and 78ff;
Title 17, Code of Federal Regulations, Section,
SNIPPETS:
SOUTHERN DISTRICT OF NEW YORK,
I and other agents of the FBI executed the search warrant.
United States Code, Section 2.
slips and customer account statements
copies of batik records of Milan Capital;
that statement is among many statements made by others and is stated only in substance and in
MONAS, the defendant.
obtain shares in the three IPOs from two of the lead undarwriters
bank account at a branch of Marine Midland Bank, which is now known as HSBC Bank USA, in
as of October 12, 1999, the balance in the HSBC aeoount was
October 29, 1999, after Milan Capital had begun to receive
securities.
that he wag "away" as a result of health problems,
Pittsburgh office of AC Financial.
Michael Lamhut discussed the fact that the Mercedes Benz was
WHEREFORE, deponent prays that a warrant be iseued for the
Sworn to before me this 14th
UNITED STATES MGISTRATE JUDGE
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