Queens DA: Internet Gambling Press Release & Indictment

Release # 168-2015
DISTRICT ATTORNEY
www.queensda.org
twitter@QueensDABrown
QUEENS COUNTY
125-01 QUEENS BOULEVARD

KEW GARDENS, NEW YORK 11415-1568
718-286-6000
RICHARD A. BROWN
DISTRICT ATTORNEY
FOR IMMEDIATE RELEASE

WEDNESDAY, OCTOBER 28, 2015
CONTACT: QDA (718-286-6315)

FBI (212-384-2100)
U.S. ATTORNEY (718-254-6323)
NYPD (646-610-6700)
SEVENTEEN INDIVIDUALS IN NEW YORK AND TWO WESTERN STATES INDICTED

BY QUEENS COUNTY GRAND JURY IN ILLEGAL $32 MILLION SPORTS BETTING RING
Queens District Attorney Richard A. Brown, joined by Robert L. Capers, the United States Attorney
for the Eastern District of New York, Diego Rodriguez, the Assistant Director-in-Charge of the New York
Field Office of the Federal Bureau of Investigation, and New York City Police Commissioner William J.
Bratton, today announced that a Queens County grand jury has indicted 17 individuals in New York, Nevada
and California on charges of unlawfully operating a highly sophisticated sports gambling enterprise that
stretched westward from Queens County and utilized offshore-based gambling websites. The enterprise,
which is alleged to have annually booked more than $32 million in bets, is also accused of laundering its
criminal proceeds by depositing and withdrawing large sums of cash from various banks throughout the
United States.
The defendants are charged in a 126-count indictment with enterprise corruption a violation of New
York States Organized Crime Control Act as well as money laundering, promoting gambling and
conspiracy. Fourteen of the defendants are in custody, including three local defendants who are awaiting
arraignment in Queens County Supreme Court. Three defendants are still being sought. If convicted, the
defendants each face up to 25 years in prison.
Internet gambling is a multi-billion dollar worldwide industry. It is highly sophisticated and
extremely lucrative handling wagers on a wide variety of sports events, ranging from horse racing, football,
baseball, basketball and hockey to NASCAR, PGA gold and professional tennis, among others, said District
Attorney Brown. Over the last few years working with our federal, state and local law enforcement
colleagues we have taken down a number of these operations and put them out of business. These cases,
I believe, have put a significant dent in illegal gambling nationwide and have saved individuals across the
country millions of dollars in gambling losses.
District Attorney Brown continued, There are some who would argue that Internet gambling is a
victimless crime. I very much disagree. Internet gambling has been compared by some to the crack cocaine
epidemic of the late 80s and early 90s. It is highly addictive and easy to get hooked. It has been said of
Internet gambling that you simply click the mouse and lose your house. Once you start, you cannot stop.
For example, it is estimated that more than ten percent of college students are online gambling, and that
more than one million young people currently are using Internet gambling sites on a monthly basis and that
the number of college students who are gambling online once a week has quadrupled in recent years.
U.S. Attorney Capers said, The arrests and seizures today represent a coordinated effort to address
(MORE)
-2illegal sports wagering over the Internet. With this seizure of millions of dollars from the Cryus Irani
operation, our asset forfeiture unit stands united with our law enforcement partners in rooting out the profits
from illegal sports gambling.
FBI Assistant Director-in-Charge Rodriquez said, This case is a great example of a collaborative
approach by the government to tackle a criminal problem. As alleged, Cyrus Irani ran an extensive offshore
internet gambling ring. The FBI, in coordination with our local partners, have carried out search warrants
and seizures of alleged profits from this online gambling ring.
Commissioner Bratton said, This investigation demonstrates how formidable the NYPDs law
enforcement partnerships are, facilitating the takedown of a cross-country Internet betting ring that stretches
through Nevada and California. The suspects in this case mistakenly believed this scheme would remain
hidden by the anonymity of the Internet and a click of a mouse, but they were wrong. I would like to thank
the NYPD investigators, prosecutors and our law enforcement partners whose hard work resulted in these
arrests and seizures.
District Attorney Brown said that the investigation leading to todays arrests began in February 2014
when the NYPDs Organized Crime Investigation Division, in conjunction with the Queens County District
Attorneys Offices Organized Crime and Rackets Bureau, developed information about a betting ring
operating in Queens County and elsewhere. The investigation included physical surveillance, intelligence
information and court-authorized electronic eavesdropping that intercepted hundreds of hours of
incriminating conversations.
The District Attorney identified the alleged boss of the gambling operation as Cyrus Irani, 37, of
Santa Clarita, California, who is accused of acting as the bookmaker who controlled and oversaw the
entire operation and profited from each criminal pursuit by the other defendants. Clark W. Bruner, 56, of
Downey, California, is alleged to have been Iranis second-in-command and was the administrator over the
accounts, managed the agents and collected the winnings from the agents. Bruners sons, Chris Bruner, 30,
also of Downey, California, and Clark (C.J.) Bruner, 23, of Menifee, California, are alleged to have
answered directly to their father and managed their own accounts, paid winners and collected debts from
losers. Ten other individuals are accused of acting as agents or sub-agents along with two alleged money
collectors and a clerk. (See Addendum for additional details on the defendants).
District Attorney Brown said that, according to the indictment, the defendants conspired to make
money illegally through the operation of unlawful gambling that accepted bets on sporting events. It is
alleged that Irani decided on wager limits, approved new accounts and all money collected eventually
funneled up to him. It is additionally alleged that the gambling operation had more than 2,000 active bettors
and utilized an 800 phone number and the off-shore Internet website www.365Action.com to allow bettors
to wager on both professional and college basketball, football, hockey and baseball. Both the website and
the toll-free number were allegedly connected to wire rooms and the defendants allegedly accepted payments
using credit cards and bank deposits ranging from $5,000 to $270,000. It is alleged that some of the proceeds
were allegedly used to buy memorabilia. For instance, during the course of the investigation, a telephone
call was allegedly intercepted in which several of the defendants discussed getting $10,000 to an individual
who was selling a classic Batman comic book.
In addition to todays arrests, court-authorized search warrants are being executed in California. At
present, more than $3 million has been seized by the FBI from bank account allegedly controlled by Cyrus
Irani pursuant to federal seizure warrants.
(MORE)
-3-
The investigation was conducted by Detective Sean MacDonald and other members of the New York
City Police Departments Organized Crime Investigation Division Headquarters One Team under the
supervision of Lieutenant Christopher Fasano, Captain John Dusanenko and Inspector John Denesopolis and
under the overall supervision of Chief Thomas Purtell of the Organized Crime Control Bureau.
Assisting in the investigation was the Office of the United States Attorney for the Eastern District
of New York specifically, Assistant United States Attorneys Tanya Hill, Deputy Chief of the Asset
Forfeiture Unit, and Laura Mantell, Chief of the Asset Forfeiture Unit.
District Attorney Brown thanked the Nevada Gaming Control Board, the Federal Bureau of
Investigation and the Los Angeles Police Departments Trans-National Organized Crime Unit for their
assistance in the investigation.
Assistant District Attorney Suzanne H. Sullivan, of the District Attorneys Organized Crime and
Rackets Bureau, is prosecuting the case under the supervision of Assistant District Attorneys Gerard A.
Brave, Bureau Chief, and Catherine C. Kane and Mary M. Lowenberg, Deputy Bureau Chief, and the overall
supervision of Executive Assistant District Attorney for Investigations Peter A. Crusco and Deputy
Executive Assistant District Attorney for Investigations Linda M. Cantoni.
It should be noted that an indictment is merely an accusation and that defendants are presumed
innocent until proven guilty.
#
Note to Editors: Press release e-version posted on www.queensda.org.
ADDENDUM
* defendant being sought.
CYRUS IRANI, 37, of 26421 River Rock Way, Santa Clarita, California, is alleged to be the bookmaker
or the boss of the organization. He is charged with enterprise corruption, first-, second-, third- and fourthdegree money laundering, first degree promoting gambling and fourth- and fifth-degree conspiracy.
CLARK W. BRUNER, 56, of 9524 Orizaba Avenue, Downey, California, is alleged to have been a primary
agent or super agent. He is charged enterprise corruption, first-, third- and fourth-degree money laundering,
first-degree promoting gambling and fifth-degree conspiracy.
CLARK (CJ) O. BRUNER, 33, of 28536 River Glen Court, Menifee, California, is alleged to have worked
as a primary agent under Clark W. Bruner. The defendant is charged with enterprise corruption, first- and
fourth-degree money laundering, first-degree promoting gambling and fifth-degree conspiracy.
CHRIS BRUNER, 31, of 8308 Cherokee Drive, Downey, California, is alleged to have been an agent. He
is charged with enterprise corruption, first- and fourth-degree money laundering, first-degree promoting
gambling and fifth-degree conspiracy.
SAUL SALAMI, 45, of 24023 Via Cresta, Santa Clarita, California, is alleged to be an agent. He is charged
with enterprise corruption, first- and fourth-degree money laundering, first-degree promoting gambling, and
fourth- and fifth-degree conspiracy.
(MORE)
-4MICHAEL GALLAGHER, 39, of 4525 Dean Martin Drive, Las Vegas, Nevada, is alleged to have been an
agent. He is charged with enterprise corruption, first- and fourth-degree money laundering, first-degree
promoting gambling and fifth-degree conspiracy.
MICHAEL GALOYAN, 32, of 59 Dean Street, Hicksville, New York, is alleged to have been an agent. He
is charged with enterprise corruption, first- and third-degree money laundering, first-degree promoting
JOHNSON MATHEW, 31, of 11880 Metropolitan Avenue, Kew Gardens, New York, is alleged to have
been an agent. He is charged with enterprise corruption, first-, second- and fourth-degree money laundering,
first-degree promoting gambling and fifth-degree conspiracy.
JIMMY JOSEPH, 31, of 5 Butler Street, Congers, New York, is alleged to have been an agent. The
defendant is charged with enterprise corruption, first-degree promoting gambling and fifth-degree
conspiracy.
THOMAS CORTESE, 49, of 4647 Carpinteria Avenue, Santa Barbara, California, is alleged to have been
an agent. He is charged with enterprise corruption, first- and third-degree money laundering, first-degree
promoting gambling and fifth-degree conspiracy.
CASSONDRA SMITH-LUTTMAN, 32, of 969 Market Street, San Diego, California, is accused of being
an agent. She is charged with enterprise corruption, first-degree promoting gambling and fifth-degree
conspiracy.
JULIO ALVARENGA, 40, of 21051 Kingscrest Drive, Santa Clarita, California, is alleged to have been an
agent. He is charged with enterprise corruption, first-degree promoting gambling and fifth-degree
conspiracy.
*ANDRES ARRIAGA, 41, of 25873 McBean Parkway, Valencia, California, is alleged to have been an
agent. He is charged with enterprise corruption, first- and fourth-degree money laundering, first-degree
promoting gambling, fifth-degree conspiracy and fifth-degree conspiracy.
JEFFREY METELITZ, 54, of 23234 Cuestport Drive, Valencia, California, is alleged to have been an agent.
He is charged with enterprise corruption, first- and fourth-degree money laundering, first-degree promoting
*RICHARD VANDERWYK, 41, of 1050 Electric Avenue, Seal Beach, California, is alleged to have been
the money collector. He is charged with enterprise corruption and first- and fourth-degree promoting
HYUN (DAVID) CHANG, 37, of 4257 East Ocean Boulevard, Long Beach, California, is alleged to have
been the money collector. He is charged with enterprise corruption and first- and fourth-degree promoting
*SALLY MEDINA, 49, of 1008 North 61 Lane, Phoenix, Arizona, is accused of being a clerk. She is
charged with enterprise corruption and first- and fourth-degree money laundering and fifth-degree
conspiracy.
#
I N D I C T M E N T
S U P R E M E
C O U R T O F T H E S T A T E O F
C O U N T Y O F Q U E E N S
N E W
Y O R K
----------------------------------------|
THE PEOPLE OF THE STATE OF NEW YORK
|
|
AGAINST
|
|
|
CYRUS IRANI
| FILED:
DEFENDANT
| INDICTMENT NO. 2037/2015
|
SAUL SALAMA
|
DEFENDANT
|
|
JOHNSON MATHEW
|
DEFENDANT
|
|
SALLY MEDINA-CABELLO
|
DEFENDANT
|
|
RICHARD VANDERWYK
|
DEFENDANT
|
|
JEFFREY METELITZ
|
DEFENDANT
|
|
DAVID CHANG
|
DEFENDANT
|
|
JIMMY JOSEPH
|
DEFENDANT
|
|
JULIO ALVARENGA
|
DEFENDANT
|
|
THOMAS CORTESE
|
DEFENDANT
|
|
ANDRES ARRIAGA
DEFENDANT
|
|
|
MICHAEL GALLAGHER
|
DEFENDANT
|
|
CASSONDRA SMITH-LUTTMAN
|
DEFENDANT
|
|
CLARK W BRUNER
|
DEFENDANT
|
|
CLARK OLIVER BRUNER
|
DEFENDANT
|
|
CHRISTOPHER BRUNER
|
DEFENDANT
|
|
MICHAEL GALOYAN
|
DEFENDANT
|
|
|
|
----------------------------------------PL 460.20-1A
ENTERPRISE CORRUPTION (1)
(IRANI,CYRUS)
(SALAMA,SAUL)
(MATHEW,JOHNSON)
(MEDINA-CABELLO,
SALLY)
(VANDERWYK,RICHARD)
(METELITZ,JEFFREY)
(CHANG,DAVID)
(JOSEPH,JIMMY)
(ALVARENGA,JULIO)
(CORTESE,THOMAS)
(ARRIAGA,ANDRES)
(GALLAGHER,MICHAEL)
(SMITH-LUTTMAN,
CASSONDRA)
(BRUNER,CLARK W)
(BRUNER,CLARK OLIVER)
(BRUNER,CHRISTOPHER)
(GALOYAN,MICHAEL)
PL 470.20-1B-IA MONEY LAUNDERING IN THE
FIRST DEGREE (2)
(IRANI,CYRUS)
(SALAMA,SAUL)
(MATHEW,JOHNSON)
(VANDERWYK,RICHARD)
(METELITZ,JEFFREY)
(CHANG,DAVID)
(CORTESE,THOMAS)
(ARRIAGA,ANDRES)
(GALLAGHER,MICHAEL)
(BRUNER,CLARK W)
(GALOYAN,MICHAEL)

SECOND DEGREE (3)
(IRANI,CYRUS)
(MATHEW,JOHNSON)
PL 105.05-1
CONSPIRACY IN THE FIFTH

DEGREE (4)
(IRANI,CYRUS)
(SALAMA,SAUL)
(MATHEW,JOHNSON)
(MEDINA-CABELLO,
SALLY)
(VANDERWYK,RICHARD)
(METELITZ,JEFFREY)
(CHANG,DAVID)
(JOSEPH,JIMMY)
(ALVARENGA,JULIO)
(CORTESE,THOMAS)
(ARRIAGA,ANDRES)
(GALLAGHER,MICHAEL)
(SMITH-LUTTMAN,
CASSONDRA)
(BRUNER,CLARK W)
(GALOYAN,MICHAEL)
PL 225.10-1
PROMOTING GAMBLING IN THE

FIRST DEGREE
(IRANI,CYRUS)
(MATHEW,JOHNSON)
(5,11-12,14-18,23-24,69)
(MEDINA-CABELLO,
SALLY)
(JOSEPH,JIMMY)

THIRD DEGREE (6)
(IRANI,CYRUS)
(GALOYAN,MICHAEL)
PL 105.05-1
CONSPIRACY IN THE FIFTH

DEGREE (7)
(IRANI,CYRUS)
(GALOYAN,MICHAEL)
PL 470.05-2A-I
MONEY LAUNDERING IN THE

FOURTH DEGREE (8,46)
(IRANI,CYRUS)
(ARRIAGA,ANDRES)
PL 470.05-2A-I

(IRANI,CYRUS)
(METELITZ,JEFFREY)
PL 470.05-2A-I

(IRANI,CYRUS)
(CHANG,DAVID)
PL 470.05-2A-I

FOURTH DEGREE
(13,38,42,45,48,89,115)
(IRANI,CYRUS)
(SALAMA,SAUL)
PL 225.10-1

FIRST DEGREE (19-21,70,72)
(IRANI,CYRUS)
(MEDINA-CABELLO,
SALLY)
(METELITZ,JEFFREY)
PL 225.10-1

FIRST DEGREE (22,71)
(IRANI,CYRUS)
(MATHEW,JOHNSON)
(MEDINA-CABELLO,
SALLY)
(METELITZ,JEFFREY)
(JOSEPH,JIMMY)

THIRD DEGREE (25)
(IRANI,CYRUS)
(CORTESE,THOMAS)
PL 470.05-1A-IIAMONEY LAUNDERING IN THE

FOURTH DEGREE (26-27,73)
(IRANI,CYRUS)
PL 225.10-1
(IRANI,CYRUS)
FIRST DEGREE
(28-32,34-35,90-94,98-100)
(MEDINA-CABELLO,
SALLY)
(BRUNER,CLARK W)
PL 470.05-2A-I

FOURTH DEGREE
(33,51,54,58-59,63,87,101,112)
(IRANI,CYRUS)
(BRUNER,CLARK W)
PL 225.10-1

FIRST DEGREE
(36-37,39-40,43-44)
(IRANI,CYRUS)
(SALAMA,SAUL)
(MATHEW,JOHNSON)
(MEDINA-CABELLO,
SALLY)
(METELITZ,JEFFREY)
(JOSEPH,JIMMY)
(ALVARENGA,JULIO)
(ARRIAGA,ANDRES)
PL 225.10-1

FIRST DEGREE (41)
(IRANI,CYRUS)
(SALAMA,SAUL)
(MATHEW,JOHNSON)
(MEDINA-CABELLO,
SALLY)
(METELITZ,JEFFREY)
(JOSEPH,JIMMY)
PL 470.05-2A-I

FOURTH DEGREE (47)
(IRANI,CYRUS)
(VANDERWYK,RICHARD)
PL 105.10-1
CONSPIRACY IN THE FOURTH

DEGREE (49)
(IRANI,CYRUS)
(SALAMA,SAUL)

SECOND DEGREE (50)
(IRANI,CYRUS)
(SALAMA,SAUL)
PL 225.10-1
(IRANI,CYRUS)
(SALAMA,SAUL)
(MEDINA-CABELLO,
SALLY)
(CORTESE,THOMAS)

FIRST DEGREE (52,103)
PL 225.10-1

FIRST DEGREE
(53,55-56,60,106-109)
(IRANI,CYRUS)
(MEDINA-CABELLO,
SALLY)
(CORTESE,THOMAS)
PL 470.05-2A-I

FOURTH DEGREE (57)
(IRANI,CYRUS)
(MATHEW,JOHNSON)
PL 225.10-1

FIRST DEGREE
(61-62,64,86,88,102,105)
(IRANI,CYRUS)
(MEDINA-CABELLO,
SALLY)
(SMITH-LUTTMAN,
CASSONDRA)
PL 225.10-1

FIRST DEGREE (65-66,68)
(IRANI,CYRUS)
(MEDINA-CABELLO,
SALLY)
(ALVARENGA,JULIO)
(ARRIAGA,ANDRES)
PL 225.10-1

FIRST DEGREE (67)
(IRANI,CYRUS)
(MEDINA-CABELLO,
SALLY)
(ALVARENGA,JULIO)
(ARRIAGA,ANDRES)
(SMITH-LUTTMAN,
CASSONDRA)

SECOND DEGREE (74)
(IRANI,CYRUS)
(CHANG,DAVID)
PL 225.10-1

FIRST DEGREE (75)
(IRANI,CYRUS)
(MEDINA-CABELLO,
SALLY)
(GALLAGHER,MICHAEL)
(GALOYAN,MICHAEL)
PL 225.10-1

FIRST DEGREE (76)
(IRANI,CYRUS)
(SALAMA,SAUL)
(MEDINA-CABELLO,
SALLY)
(METELITZ,JEFFREY)
(CORTESE,THOMAS)
(GALLAGHER,MICHAEL)
(SMITH-LUTTMAN,
CASSONDRA)
(GALOYAN,MICHAEL)
PL 225.10-1

FIRST DEGREE (77)
(IRANI,CYRUS)
(SALAMA,SAUL)
(MATHEW,JOHNSON)
(MEDINA-CABELLO,
SALLY)
(METELITZ,JEFFREY)
(JOSEPH,JIMMY)
(ALVARENGA,JULIO)
(CORTESE,THOMAS)
(ARRIAGA,ANDRES)
(GALLAGHER,MICHAEL)
(SMITH-LUTTMAN,
CASSONDRA)
(BRUNER,CLARK W)
(GALOYAN,MICHAEL)
PL 225.10-1

FIRST DEGREE (78)
(IRANI,CYRUS)
(MATHEW,JOHNSON)
(MEDINA-CABELLO,
SALLY)
(METELITZ,JEFFREY)
(JOSEPH,JIMMY)
(GALLAGHER,MICHAEL)
(BRUNER,CLARK W)
(GALOYAN,MICHAEL)
PL 470.05-2A-I

(IRANI,CYRUS)
(VANDERWYK,RICHARD)
(BRUNER,CLARK W)
PL 225.10-1
(IRANI,CYRUS)
FIRST DEGREE (80)
(MATHEW,JOHNSON)
(MEDINA-CABELLO,
SALLY)
(JOSEPH,JIMMY)
(GALLAGHER,MICHAEL)
(BRUNER,CLARK W)
PL 225.10-1

FIRST DEGREE (81-83)
(IRANI,CYRUS)
(MATHEW,JOHNSON)
(MEDINA-CABELLO,
SALLY)
(JOSEPH,JIMMY)
(GALLAGHER,MICHAEL)
(BRUNER,CLARK W)
(GALOYAN,MICHAEL)
PL 225.10-1

FIRST DEGREE (84)
(IRANI,CYRUS)
(SALAMA,SAUL)
(MATHEW,JOHNSON)
(MEDINA-CABELLO,
SALLY)
(JOSEPH,JIMMY)
(ALVARENGA,JULIO)
(CORTESE,THOMAS)
(ARRIAGA,ANDRES)
(GALLAGHER,MICHAEL)
(BRUNER,CLARK W)
(GALOYAN,MICHAEL)
PL 225.10-1

FIRST DEGREE (85)
(IRANI,CYRUS)
(MATHEW,JOHNSON)
(MEDINA-CABELLO,
SALLY)
(JOSEPH,JIMMY)
(GALLAGHER,MICHAEL)
(SMITH-LUTTMAN,
CASSONDRA)
PL 225.10-1

FIRST DEGREE (95)
(IRANI,CYRUS)
(MEDINA-CABELLO,
SALLY)
(SMITH-LUTTMAN,
CASSONDRA)
(BRUNER,CLARK W)
PL 225.10-1

FIRST DEGREE (96-97)
(IRANI,CYRUS)
(SALAMA,SAUL)
(MEDINA-CABELLO,
SALLY)
(BRUNER,CLARK W)
PL 225.10-1

FIRST DEGREE (104)
(IRANI,CYRUS)
(MEDINA-CABELLO,
SALLY)
(CORTESE,THOMAS)
(SMITH-LUTTMAN,
CASSONDRA)
PL 470.05-2A-I

FOURTH DEGREE (110)
(IRANI,CYRUS)
(VANDERWYK,RICHARD)
(BRUNER,CLARK W)
PL 470.05-2A-I

FOURTH DEGREE (113)
(IRANI,CYRUS)
(GALLAGHER,MICHAEL)
PL 470.05-2A-I

FOURTH DEGREE (114)
(IRANI,CYRUS)
(CHANG,DAVID)
(BRUNER,CLARK W)
PL 225.10-1

FIRST DEGREE
(116,120-121,123,126)
(IRANI,CYRUS)
(SALAMA,SAUL)
(MEDINA-CABELLO,
SALLY)

THIRD DEGREE (117)
(IRANI,CYRUS)
(VANDERWYK,RICHARD)
(BRUNER,CLARK W)
PL 470.05-2A-I

FOURTH DEGREE (118)
(IRANI,CYRUS)
(BRUNER,CLARK W)
PL 470.05-2A-I

FOURTH DEGREE (119)
(IRANI,CYRUS)
(VANDERWYK,RICHARD)
(CHANG,DAVID)
(BRUNER,CLARK W)

THIRD DEGREE (124)
(IRANI,CYRUS)
(CHANG,DAVID)
(BRUNER,CLARK W)
A TRUE BILL
------------------------------FOREMAN
DISTRICT ATTORNEY
FIRST COUNT
ENTERPRISE CORRUPTION
THE GRAND JURY OF THE COUNTY OF QUEENS, BY THIS
INDICTMENT, ACCUSES THE DEFENDANTS, EACH AIDING AND
ACTING IN CONCERT WITH EACH OTHER AND OTHERS KNOWN
AND UNKNOWN TO THE GRAND JURY, OF THE CRIME OF
ENTERPRISE CORRUPTION, IN VIOLATION OF PENAL LAW
SECTION 460.20(1)(A), COMMITTED IN THE COUNTY OF QUEENS
AND ELSEWHERE, AS FOLLOWS:
THE DEFENDANTS, ON OR ABOUT AND BETWEEN JANUARY 3,
2013 AND SEPTEMBER 8, 2015, HAVING KNOWLEDGE OF THE
EXISTENCE OF A CRIMINAL ENTERPRISE, TO WIT: AN ILLEGAL
GAMBLING OPERATION, AND THE NATURE OF ITS ACTIVITIES,
AND BEING EMPLOYED BY AND ASSOCIATED WITH THAT
CRIMINAL ENTERPRISE, INTENTIONALLY CONDUCTED AND
PARTICIPATED IN THE AFFAIRS OF THE CRIMINAL ENTERPRISE
BY PARTICIPATING IN A PATTERN OF CRIMINAL ACTIVITY, AS
FOLLOWS:
THE CRIMINAL ENTERPRISE
THE DEFENDANTS, CYRUS IRANI, SAUL SALAMA, CLARK
W. BRUNER, CLARK O. BRUNER, CHRISTOPHER BRUNER,

CASSONDRA SMITH- LUTTMAN, MICHAEL GALLAGHER, JULIO
ALVARENGA, ANDRES ARRIAGA, JEFFREY METELITZ, THOMAS
CORTESE, JIMMY JOSEPH, JOHNSON MATHEW, MICHAEL
GALOYAN, RICHARD VANDERWYK, DAVID CHANG, AND SALLY
MEDINA-CABELLO,
ALONG WITH OTHER PERSONS KNOWN AND
UNKNOWN, WERE MEMBERS OF AN ENTERPRISE WHICH SHARED

A COMMON PURPOSE OF ENGAGING IN CRIMINAL CONDUCT,
AND WERE ASSOCIATED IN A STRUCTURE THAT WAS DISTINCT
FROM THE PATTERN OF CRIMINAL ACTIVITY, IN THAT EACH
PARTICIPANT HAS A SPECIALIZED ROLE WITHIN THE
GAMBLING OPERATION, AND THAT HAD A CONTINUITY OF
EXISTENCE, STRUCTURE AND CRIMINAL PURPOSE BEYOND THE
SCOPE OF INDIVIDUAL CRIMINAL INCIDENTS.
THE
DEFENDANTS WERE MEMBERS AND ASSOCIATES OF AN

ORGANIZATION THAT OPERATED AN UNLAWFUL SPORTS
GAMBLING ENTERPRISE, AN ORGANIZED CRIMINAL GROUP
THAT CONSTITUTED A CRIMINAL ENTERPRISE AS THAT TERM
IS DEFINED IN PENAL LAW SECTION 460.10 SUBSECTION 3.
THE PURPOSE AND STRUCTURE OF THE CRIMINAL ENTERPRISE
THE COMMON PURPOSE OF THE MEMBERS AND ASSOCIATES OF

THE GAMBLING OPERATION WAS TO ENGAGE IN CRIMINAL
CONDUCT AND TO ACQUIRE MONEY ILLEGALLY THROUGH THE

PROMOTION OF GAMBLING ACTIVITY, INCLUDING WAGERS ON
SPORTS.
THIS GAMBLING ENTERPRISE CONSISTED OF THE
FOLLOWING INDIVIDUALS WHO COORDINATED TOGETHER IN

ORDER TO ACQUIRE MONEY ILLEGALLY THROUGH THE
PROMOTION OF GAMBLING ACTIVITY:
CYRUS IRANI WAS THE BOOKMAKER IN THIS OPERATION.
SAUL SALAMA, CLARK W. BRUNER, CLARK O. BRUNER,
CHRISTOPHER BRUNER, CASSONDRA SMITH-LUTTMAN, MICHAEL
GALLAGHER, JULIO ALVARENGA, ANDRES ARRIAGA, JEFFREY
METELITZ, THOMAS CORTESE, JIMMY JOSEPH, JOHNSON
MATHEW, AND MICHAEL GALOYAN WERE AGENTS IN THIS
ORGANIZATION WHO RECRUITED BETTORS, MAINTAINED
EXISTING BETTORS, COLLECTED GAMBLING LOSSES AND PAID
OUT WINNINGS RESULTING FROM BETS PLACED WITH THE
ENTERPRISE. RICHARD VANDERWYK, AND DAVID CHANG WERE
MONEY COLLECTORS, MONEY DISTRIBUTORS AND BANKS IN
THIS ORGANIZATION WHO COLLECTED AND DISTRIBUTED
MONEY AMONG THE PARTICIPANTS OF THIS ENTERPRISE AND
HELD LARGE SUMS OF CASH FOR THE ADVANCEMENT OF THE
BUSINESS.
SALLY MEDINA-CABELLO WAS THE RECORD KEEPER,
ACCOUNT MANAGER, AND MAINTAINED THE WEBSITE FOR THE

ADVANCEMENT OF THE BUSINESS.
THIS GAMBLING ENTERPRISE CONDUCTED THIS GAMBLING

BUSINESS IN THE FORM OF A SPORTS GAMBLING OPERATION, AS
FOLLOWS:
BETS WERE ACCEPTED BY THIS GAMBLING OPERATION ON
VARIOUS SPORTING EVENTS, INCLUDING PROFESSIONAL AND
COLLEGE BASKETBALL, FOOTBALL, HOCKEY AND BASEBALL,
PRIMARILY THROUGH A TOLL-FREE NUMBER, ACCESSIBLE FROM
TELEPHONES LOCATED IN QUEENS COUNTY AND ELSEWHERE,
AND THROUGH THE INTERNET WEBSITE 365ACTION.COM WHICH
WAS ACCESSIBLE FROM COMPUTERS CONNECTED TO THE
INTERNET IN QUEENS COUNTY AND ELSEWHERE.
THIS INTERNET WEBSITE AND THE TOLL FREE TELEPHONE
NUMBER WERE WIRE ROOMS WHERE WAGERS WERE ACCEPTED
AND GAMBLING ACCOUNTS MAINTAINED.
AT VARIOUS TIMES
RELEVANT TO THIS INDICTMENT LARGE SUMS OF CASH WERE

COLLECTED, TRANSPORTED AND DISTRIBUTED BY MEMBERS OF
THE ENTERPRISE IN ORDER FOR THE CRIMINAL BUSINESS TO
OPERATE AND PROFIT IN QUEENS COUNTY AND ELSEWHERE.
PATTERN OF CRIMINAL ACTIVITY
DURING THE PERIOD OF THESE OFFENSES, AS INDICATED BELOW,
EACH OF THE DEFENDANTS, WITH INTENT TO PARTICIPATE IN
AND ADVANCE THE AFFAIRS OF THE CRIMINAL ENTERPRISE,

ENGAGED IN CONDUCT CONSTITUTING, OR WAS CRIMINALLY
LIABLE FOR, THREE OR MORE OF THE FOLLOWING CRIMINAL
ACTS INCLUDED WITHIN AN ESTABLISHED PATTERN OF
CRIMINAL ACTIVITY:
PATTERN ACT 1
THE DEFENDANTS CYRUS IRANI, SAUL SALAMA, CLARK W.
BRUNER, CLARK O. BRUNER, CHRISTOPHER BRUNER, MICHAEL
GALLAGHER, ANDRES ARRIAGA, JEFFREY METELITZ, THOMAS
CORTESE, JOHNSON MATHEW, MICHAEL GALOYAN, RICHARD
VANDERWYK, AND DAVID CHANG,
ACTING IN CONCERT,
COMMITTED THE CRIME OF MONEY LAUNDERING IN THE FIRST

DEGREE, IN VIOLATION OF PENAL LAW SECTION 470.20
SUBDIVISION ONE, (B) (I) (A) (III), IN THAT ON OR ABOUT JANUARY
3, 2013 THROUGH ON OR ABOUT SEPTEMBER 8, 2015, IN THE
COUNTY OF QUEENS AND ELSEWHERE, THEY, KNOWING THAT
PROPERTY INVOLVED IN ONE OR MORE FINANCIAL
TRANSACTIONS REPRESENTED THE PROCEEDS OF A CLASS A, B,
OR C FELONY, OR OF A CRIME IN ANY OTHER JURISDICTION THAT
IS OR WOULD BE A CLASS A, B, OR C FELONY UNDER THE LAWS
OF THIS STATE, CONDUCTED ONE OR MORE SUCH FINANCIAL
TRANSACTIONS WHICH IN FACT INVOLVED THE PROCEEDS OF
ANY SUCH FELONY WITH INTENT TO PROMOTE THE CARRYING

ON OF SPECIFIED CRIMINAL CONDUCT AND THE TOTAL VALUE
OF THE PROPERTY INVOLVED IN SUCH FINANCIAL
TRANSACTIONS EXCEEDED ONE MILLION DOLLARS.
PATTERN ACT 2
THE DEFENDANTS, CYRUS IRANI AND JOHNSON MATHEW,
ACTING IN CONCERT, COMMITTED THE CRIME OF MONEY
LAUNDERING IN THE SECOND DEGREE IN VIOLATION OF PENAL
LAW SECTION 470.15(1) (B)(I)(A)(III), IN THAT ON OR ABOUT AND
BETWEEN JANUARY 3, 2013 AND JANUARY 27, 2014, IN THE
COUNTY OF QUEENS AND ELSEWHERE, KNOWING THAT THE
TRANSACTIONS REPRESENTED THE PROCEEDS OF SPECIFIED
CRIMINAL CONDUCT, THEY CONDUCTED ONE OR MORE SUCH
FINANCIAL TRANSACTIONS WHICH IN FACT INVOLVED THE
PROCEEDS OF SPECIFIED CRIMINAL CONDUCT WITH INTENT TO
PROMOTE THE CARRYING ON OF SPECIFIED CRIMINAL CONDUCT
AND THE TOTAL VALUE OF THE PROPERTY INVOLVED IN SUCH
TRANSACTIONS EXCEEDS $100,000.
PATTERN ACT 3
THE DEFENDANTS CYRUS IRANI, SAUL SALAMA, CLARK W.
BRUNER, CLARK O. BRUNER, CHRISTOPHER BRUNER,

CASSONDRA SMITH- LUTTMAN, MICHAEL GALLAGHER, JULIO
ALVARENGA, ANDRES ARRIAGA, JEFFREY METELITZ, THOMAS
CORTESE, JIMMY JOSEPH, JOHNSON MATHEW, MICHAEL
GALOYAN, RICHARD VANDERWYK, DAVID CHANG, AND SALLY
MEDINA-CABELLO, COMMITTED THE CRIME OF CONSPIRACY IN
THE FIFTH DEGREE, IN VIOLATION OF PENAL LAW SECTION 105.05
SUBDIVISION ONE, IN THAT ON OR ABOUT JANUARY 3, 2013 AND
BETWEEN SEPTEMBER 8, 2015, IN THE COUNTY OF QUEENS AND
ELSEWHERE, WITH INTENT THAT CONDUCT CONSTITUTING A
FELONY, TO WIT: PROMOTING GAMBLING IN THE FIRST DEGREE
BE PERFORMED, AGREED WITH ONE OR MORE PERSONS TO
ENGAGE IN OR CAUSE THE PERFORMANCE OF SUCH CONDUCT.
OVERT ACTS:
IN FURTHERANCE OF SAID CONSPIRACY AND TO EFFECT THE
OBJECTS THEREOF, AND DURING THE COURSE THEREOF, THE
FOLLOWING OVERT ACTS, AMONG OTHERS, WERE COMMITTED:
ON FEBRUARY 17, 2015, MICHAEL GALOYAN DELIVERED
GAMBLING PROCEEDS FROM INTERNET GAMBLING IN QUEENS
COUNTY.
PATTERN ACT 4
THE DEFENDANTS, CYRUS IRANI, JOHNSON MATHEW, JIMMY

JOSEPH, AND SALLY MEDINA-CABELLO ACTING IN CONCERT,
COMMITTED THE CRIME OF PROMOTING GAMBLING IN THE
FIRST DEGREE, IN VIOLATION OF PENAL LAW SECTION 225.10(1),
IN THAT ON OR ABOUT FEBRUARY 24, 2014, IN THE COUNTY OF
QUEENS AND ELSEWHERE, THEY KNOWINGLY ADVANCED AND
PROFITED FROM UNLAWFUL GAMBLING ACTIVITY BY ENGAGING
IN BOOKMAKING TO THE EXTENT THAT THEY RECEIVED OR
ACCEPTED ON THAT DATE MORE THAN FIVE BETS TOTALING
MORE THAN $5,000.
PATTERN ACT 5
THE DEFENDANTS, CYRUS IRANI AND MICHAEL GALOYAN,
ACTING IN CONCERT, COMMITTED THE CRIME COMMITTED THE
CRIME OF MONEY LAUNDERING COMMITTED THE CRIME OF
MONEY IN THE THIRD DEGREE, IN VIOLATION OF PENAL LAW
SECTION 470.10(1)(B)(I)(A)(III), IN THAT ON OR ABOUT MARCH 5,
2014 AND JUNE 20, 2015, IN THE COUNTY OF QUEENS AND
ELSEWHERE, KNOWING THAT THE PROPERTY INVOLVED ONE OR
MORE FINANCIAL TRANSACTIONS REPRESENTS THE PROCEEDS
OF CRIMINAL CONDUCT, THEY CONDUCTED ONE OR MORE SUCH
PROCEEDS OF SPECIFIED CRIMINAL CONDUCT, WITH INTENT TO

PROMOTE THE CARRYING ON OF CRIMINAL CONDUCT AND THE
TOTAL VALUE OF SUCH PROPERTY INVOLVED IN SUCH
FINANCIAL TRANSACTION OR TRANSACTIONS EXCEEDED $50,000.
PATTERN ACT 6
THE DEFENDANTS, CYRUS IRANI AND MICHAEL GALOYAN,
COMMITTED THE CRIME OF CONSPIRACY IN THE FIFTH DEGREE
IN VIOLATION OF PENAL LAW SECTION 105.05(1), IN THAT, ON OR
ABOUT MARCH 5, 2014 AND JUNE 30, 2014, IN THE COUNTY OF
QUEENS AND ELSEWHERE, WITH INTENT THAT CONDUCT
CONSTITUTING A FELONY, TO WIT: PROMOTING GAMBLING IN
THE FIRST DEGREE BE PERFORMED, AGREED WITH ONE OR MORE
PERSONS TO ENGAGE IN OR CAUSE THE PERFORMANCE OF SUCH
CONDUCT.
OVERT ACTS:
IN FURTHERANCE OF SAID CONSPIRACY AND TO EFFECT THE
OBJECTS THEREOF, AND DURING THE COURSE THEREOF, THE
FOLLOWING OVERT ACTS, AMONG OTHERS, WERE COMMITTED:
ON APRIL 8, 2014, MICHAEL GALOYAN SPOKE TO CYRUS IRANI
FROM QUEENS COUNTY, NEW YORK USING TELEPHONE NUMBER
(718) 721-7513 TO DISCUSS CUSTOMER K604 AND THEN DEPOSITED
$5,000 CASH INTO CYRUS' BANK OF AMERICA ACCOUNT FROM

THE FOREST HILLS, QUEENS BRANCH.
PATTERN ACT 7
THE DEFENDANTS, CYRUS IRANI AND ANDRES ARRIAGA, ACTING
IN CONCERT WITH OTHERS, COMMITTED THE CRIME COMMITTED
THE CRIME OF MONEY LAUNDERING IN THE FOURTH DEGREE, IN
VIOLATION OF PENAL LAW SECTION 470.05(2)(A)(I)(B), IN THAT ON
OR ABOUT MARCH 7, 2014, IN THE COUNTY OF QUEENS AND
ELSEWHERE, KNOWING THAT ONE OR MORE MONETARY
INSTRUMENTS REPRESENTED THE PROCEEDS OF SPECIFIED
CRIMINAL CONDUCT, THEY TRANSPORTED, TRANSMITTED OR
TRANSFERRED ON ONE OR MORE OCCASIONS, MONETARY
INSTRUMENTS WHICH IN FACT REPRESENTED THE PROCEEDS OF
SPECIFIED CRIMINAL CONDUCT, WITH INTENT TO PROMOTE THE
CARRYING ON OF CRIMINAL CONDUCT AND THE VALUE OF SUCH
MONETARY INSTRUMENTS EXCEEDED $10,000.
PATTERN ACT 8
THE DEFENDANTS, CYRUS IRANI AND JEFFREY METELITZ,
CRIME OF MONEY LAUNDERING IN THE FOURTH DEGREE, IN
OR ABOUT MARCH 27, 2014, IN THE COUNTY OF QUEENS AND

PATTERN ACT 9
THE DEFENDANTS, CYRUS IRANI AND DAVID CHANG, ACTING IN
CONCERT, COMMITTED THE CRIME COMMITTED THE CRIME OF
MONEY LAUNDERING IN THE FOURTH DEGREE, IN VIOLATION OF
PENAL LAW SECTION 470.05(2)(A)(I)(B), IN THAT ON OR ABOUT
MARCH 28, 2014, IN THE COUNTY OF QUEENS AND ELSEWHERE,
KNOWING THAT ONE OR MORE MONETARY INSTRUMENTS
REPRESENTED THE PROCEEDS OF SPECIFIED CRIMINAL
CONDUCT, THEY TRANSPORTED, TRANSMITTED OR
PATTERN ACT 10
COMMITTED THE CRIME OF PROMOTING GAMBLING IN THE FIRST
DEGREE, IN VIOLATION OF PENAL LAW SECTION 225.10(1), IN
THAT ON OR ABOUT APRIL 7, 2014, IN THE COUNTY OF QUEENS
AND ELSEWHERE, THEY KNOWINGLY ADVANCED AND PROFITED
FROM UNLAWFUL GAMBLING ACTIVITY BY ENGAGING IN
BOOKMAKING TO THE EXTENT THAT THEY RECEIVED OR
MORE THAN $5,000.
PATTERN ACT 11

MORE THAN $5,000.
PATTERN ACT 12
THE DEFENDANTS, CYRUS IRANI AND SAUL SALAMA, ACTING IN
APRIL 10, 2014, IN THE COUNTY OF QUEENS AND ELSEWHERE,
PATTERN ACT 13

MORE THAN $5,000.
PATTERN ACT 14
MORE THAN $5,000.
PATTERN ACT 15

MORE THAN $5,000.
PATTERN ACT 16
MORE THAN $5,000.
PATTERN ACT 17

MORE THAN $5,000.
PATTERN ACT 18
THE DEFENDANTS, CYRUS IRANI, JEFFREY METELITZ, AND SALLY
MEDINA-CABELLO ACTING IN CONCERT, COMMITTED THE CRIME
OF PROMOTING GAMBLING IN THE FIRST DEGREE, IN VIOLATION
OF PENAL LAW SECTION 225.10(1), IN THAT ON OR ABOUT APRIL
23, 2014, IN THE COUNTY OF QUEENS AND ELSEWHERE, THEY
KNOWINGLY ADVANCED AND PROFITED FROM UNLAWFUL
GAMBLING ACTIVITY BY ENGAGING IN BOOKMAKING TO THE
EXTENT THAT THEY RECEIVED OR ACCEPTED ON THAT DATE
MORE THAN FIVE BETS TOTALING MORE THAN $5,000.
PATTERN ACT 19

PATTERN ACT 20
PATTERN ACT 21

JOSEPH, JEFFREY METELITZ, AND SALLY MEDINA-CABELLO
ACTING IN CONCERT, COMMITTED THE CRIME OF PROMOTING
GAMBLING IN THE FIRST DEGREE, IN VIOLATION OF PENAL LAW
SECTION 225.10(1), IN THAT ON OR ABOUT APRIL 28, 2014, IN THE
COUNTY OF QUEENS AND ELSEWHERE, THEY KNOWINGLY
ADVANCED AND PROFITED FROM UNLAWFUL GAMBLING
ACTIVITY BY ENGAGING IN BOOKMAKING TO THE EXTENT THAT
THEY RECEIVED OR ACCEPTED ON THAT DATE MORE THAN FIVE
BETS TOTALING MORE THAN $5,000.
PATTERN ACT 22
MORE THAN $5,000.
PATTERN ACT 23
THAT ON OR ABOUT MAY 1, 2014, IN THE COUNTY OF QUEENS
MORE THAN $5,000.
PATTERN ACT 24
THE DEFENDANTS, CYRUS IRANI AND THOMAS CORTESE, ACTING
IN CONCERT, COMMITTED THE CRIME COMMITTED THE CRIME OF
MONEY LAUNDERING COMMITTED THE CRIME OF MONEY IN THE
THIRD DEGREE, IN VIOLATION OF PENAL LAW SECTION
470.10(1)(B)(I)(A)(III), IN THAT ON OR ABOUT MAY 2, 2014 AND
JUNE 30, 2015, IN THE COUNTY OF QUEENS AND ELSEWHERE,
KNOWING THAT THE PROPERTY INVOLVED ONE OR MORE
FINANCIAL TRANSACTIONS REPRESENTS THE PROCEEDS OF

PATTERN ACT 25
THE DEFENDANT, CYRUS IRANI, ACTING IN CONCERT WITH
OTHERS, COMMITTED THE CRIME COMMITTED THE CRIME OF
MAY 13, 2014, IN THE COUNTY OF QUEENS AND ELSEWHERE,
PATTERN ACT 26

PENAL LAW SECTION 470.05 (1) (A) (II) (A)(B), IN THAT ON OR
ABOUT MAY 27, 2014, IN THE COUNTY OF QUEENS AND
ELSEWHERE, 1.
KNOWING THAT THE PROPERTY INVOLVED IN
ONE OR MORE FINANCIAL TRANSACTIONS REPRESENTS THE

PROCEEDS OF CRIMINAL CONDUCT:
(A) HE CONDUCTED ONE OR
MORE SUCH FINANCIAL TRANSACTIONS WHICH IN FACT

INVOLVE THE PROCEEDS OF SPECIFIED CRIMINAL CONDUCT: (II)
KNOWING THAT THE TRANSACTION OR TRANSACTIONS IN
WHOLE OR IN PART ARE DESIGNED TO: (A)
CONCEAL OR
DISGUISE THE NATURE, THE LOCATION, THE SOURCE, THE

OWNERSHIP OR THE CONTROL OF THE PROCEEDS OF CRIMINAL
CONDUCT; AND (B) THE TOTAL VALUE OF THE PROPERTY
INVOLVED IN SUCH FINANCIAL TRANSACTION OR
TRANSACTIONS EXCEEDED $5,000.
PATTERN ACT 27
THE DEFENDANTS, CYRUS IRANI, CLARK W. BRUNER, CLARK O.
BRUNER, CHRISTOPHER BRUNER, AND SALLY MEDINA-CABELLO
SECTION 225.10(1), IN THAT ON OR ABOUT SEPTEMBER 21, 2014, IN

THE COUNTY OF QUEENS AND ELSEWHERE, THEY KNOWINGLY
PATTERN ACT 28
PATTERN ACT 29

PATTERN ACT 30
SECTION 225.10(1), IN THAT ON OR ABOUT OCTOBER 4, 2014, IN
PATTERN ACT 31

PATTERN ACT 32
THE DEFENDANTS, CYRUS IRANI, CLARK W. BRUNER, AND CLARK
O. BRUNER, ACTING IN CONCERT, COMMITTED THE CRIME
COMMITTED THE CRIME OF MONEY LAUNDERING IN THE
FOURTH DEGREE, IN VIOLATION OF PENAL LAW SECTION
470.05(2)(A)(I)(B), IN THAT ON OR ABOUT OCTOBER 10, 2014, IN THE
COUNTY OF QUEENS AND ELSEWHERE, KNOWING THAT ONE OR
MORE MONETARY INSTRUMENTS REPRESENTED THE PROCEEDS
OF SPECIFIED CRIMINAL CONDUCT, THEY TRANSPORTED,
TRANSMITTED OR TRANSFERRED ON ONE OR MORE OCCASIONS,
MONETARY INSTRUMENTS WHICH IN FACT REPRESENTED THE
VALUE OF SUCH MONETARY INSTRUMENTS EXCEEDED $10,000.
PATTERN ACT 33
PATTERN ACT 34

PATTERN ACT 35
THE DEFENDANTS, CYRUS IRANI, JIMMY JOSEPH, JOHNSON
MATHEW, JULIO ALVARENGA, ANDRES ARRIAGA, JEFFREY
METELITZ, SAUL SALAMA, AND SALLY MEDINA-CABELLO
PATTERN ACT 36

PATTERN ACT 37
OCTOBER 14, 2014, IN THE COUNTY OF QUEENS AND ELSEWHERE,
PATTERN ACT 38

PATTERN ACT 39

PATTERN ACT 40
MATHEW, JEFFREY METELITZ, SAUL SALAMA, AND SALLY
OF PENAL LAW SECTION 225.10(1), IN THAT ON OR ABOUT
THEY KNOWINGLY ADVANCED AND PROFITED FROM UNLAWFUL
PATTERN ACT 41

PATTERN ACT 42
PATTERN ACT 43

PATTERN ACT 44
NOVEMBER 21, 2014, IN THE COUNTY OF QUEENS AND

PATTERN ACT 45
THE DEFENDANTS, CYRUS IRANI AND ANDRES ARRIAGA, ACTING
IN CONCERT WITH OTHERS, COMMITTED THE CRIME COMMITTED
OR ABOUT NOVEMBER 21, 2014, IN THE COUNTY OF QUEENS AND
PATTERN ACT 46
THE DEFENDANTS, CYRUS IRANI AND RICHARD VANDERWYK,
OR ABOUT NOVEMBER 30, 2014 AND DECEMBER 1, 2014, IN THE

PATTERN ACT 47
CONCERT WITH OTHERS, COMMITTED THE CRIME COMMITTED
OR ABOUT DECEMBER 10, 2014, IN THE COUNTY OF QUEENS AND
PATTERN ACT 48
THE DEFENDANTS, CYRUS IRANI AND SAUL SALAMA,
COMMITTED THE CRIME OF CONSPIRACY IN THE FOURTH
DEGREE IN VIOLATION OF PENAL LAW SECTION 105.10(1), IN THAT
ON OR ABOUT DECEMBER 19, 2014, AND DECEMBER 20, 2014, IN
THE COUNTY OF QUEENS AND ELSEWHERE, WITH INTENT THAT
CONDUCT CONSTITUTING A CLASS C FELONY, TO WIT, MONEY
LAUNDERING IN THE SECOND DEGREE BE PERFORMED, AGREED
WITH ONE OR MORE PERSONS TO ENGAGE IN OR CAUSE THE
PERFORMANCE OF SUCH CONDUCT.
OVERT ACTS:
ON DECEMBER 19, 2014, CYRUS IRANI AND SAUL SALAMA HAD A
CONVERSATION WHEREIN SAUL AGREED TO DELIVER $140,000 IN
CASH TO A MANHATTAN COMIC BOOK COLLECTIBLES STORE.
ON DECEMBER 20, 2014, SAUL SALAMA DELIVERED THE MONEY.
PATTERN ACT 49
CONCERT, COMMITTED THE CRIME OF MONEY LAUNDERING IN
THE SECOND DEGREE IN VIOLATION OF PENAL LAW SECTION
470.15(1)(B)(I)(A)(III), IN THAT ON OR ABOUT DECEMBER 20, 2014,

IN THE COUNTY OF QUEENS AND ELSEWHERE, KNOWING THAT
THE PROPERTY INVOLVED IN ONE OR MORE FINANCIAL
PATTERN ACT 50
470.05(2)(A)(I)(B), IN THAT ON OR ABOUT DECEMBER 29, 2014 AND
DECEMBER 31, 2014, IN THE COUNTY OF QUEENS AND

PATTERN ACT 51
THE DEFENDANTS, CYRUS IRANI, THOMAS CORTESE, SAUL
SALAMA, AND SALLY MEDINA-CABELLO ACTING IN CONCERT,
THAT ON OR ABOUT JANUARY 1, 2015, IN THE COUNTY OF
MORE THAN $5,000.
PATTERN ACT 52
THE DEFENDANTS, CYRUS IRANI, THOMAS CORTESE, AND SALLY
JANUARY 2, 2015, IN THE COUNTY OF QUEENS AND ELSEWHERE,

PATTERN ACT 53
470.05(2)(A)(I)(B), IN THAT ON OR ABOUT JANUARY 2, 2015 IN THE
PATTERN ACT 54

PATTERN ACT 55
PATTERN ACT 56
THE DEFENDANTS, CYRUS IRANI AND JOHNSON MATHEW,

OR ABOUT AND BETWEEN JANUARY 4, 2015 AND JUNE 10, 2015, IN
THE COUNTY OF QUEENS AND ELSEWHERE, KNOWING THAT ONE
OR MORE MONETARY INSTRUMENTS REPRESENTED THE
PROCEEDS OF SPECIFIED CRIMINAL CONDUCT, THEY
TRANSPORTED, TRANSMITTED OR TRANSFERRED ON ONE OR
MORE OCCASIONS, MONETARY INSTRUMENTS WHICH IN FACT
CONDUCT, WITH INTENT TO PROMOTE THE CARRYING ON OF
CRIMINAL CONDUCT AND THE VALUE OF SUCH MONETARY
INSTRUMENTS EXCEEDED $10,000.
PATTERN ACT 57

PATTERN ACT 58
PATTERN ACT 59

PATTERN ACT 60
THE DEFENDANTS, CYRUS IRANI, CASSONDRA SMITH-LUTTMAN,
AND SALLY MEDINA-CABELLO ACTING IN CONCERT, COMMITTED
THE CRIME OF PROMOTING GAMBLING IN THE FIRST DEGREE, IN
VIOLATION OF PENAL LAW SECTION 225.10(1), IN THAT ON OR
ABOUT JANUARY 12, 2015, IN THE COUNTY OF QUEENS AND
ELSEWHERE, THEY KNOWINGLY ADVANCED AND PROFITED
MORE THAN $5,000.
PATTERN ACT 61

MORE THAN $5,000.
PATTERN ACT 62
470.05(2)(A)(I)(B), IN THAT ON OR ABOUT AND BETWEEN JANUARY
16, 2015 AND JANUARY 26, 2015, IN THE COUNTY OF QUEENS AND

PATTERN ACT 63
MORE THAN $5,000.
PATTERN ACT 64
THE DEFENDANTS, CYRUS IRANI, JULIO ALVARENGA, ANDRES
ARRIAGA, AND SALLY MEDINA-CABELLO ACTING IN CONCERT,

MORE THAN $5,000.
PATTERN ACT 65
MORE THAN $5,000.
PATTERN ACT 66
ARRIAGA, CASSONDRA SMITH-LUTTMAN, AND SALLY

PATTERN ACT 67
MORE THAN $5,000.
PATTERN ACT 68
MATHEW AND SALLY MEDINA-CABELLO ACTING IN CONCERT,

MORE THAN $5,000.
PATTERN ACT 69
THE DEFENDANTS, CYRUS IRANI, JEFFREY METELITZ AND SALLY
PATTERN ACT 70
MATHEW, JEFFREY METELITZ, AND SALLY MEDINA-CABELLO

SECTION 225.10(1), IN THAT ON OR ABOUT JANUARY 28, 2015, IN
PATTERN ACT 71
THE DEFENDANTS, CYRUS IRANI, MICHAEL GALOYAN, JEFFREY
METELITZ AND SALLY MEDINA-CABELLO ACTING IN CONCERT,
MORE THAN $5,000.
PATTERN ACT 72

PENAL LAW SECTION 470.05 (1) (A) (II) (A)(B), IN THAT ON OR
ELSEWHERE, 1.
KNOWING THAT THE PROPERTY INVOLVED IN
ONE OR MORE FINANCIAL TRANSACTIONS REPRESENTS THE

PROCEEDS OF CRIMINAL CONDUCT:
(A) HE CONDUCTED ONE OR
MORE SUCH FINANCIAL TRANSACTIONS WHICH IN FACT

INVOLVE THE PROCEEDS OF SPECIFIED CRIMINAL CONDUCT: (II)
KNOWING THAT THE TRANSACTION OR TRANSACTIONS IN
WHOLE OR IN PART ARE DESIGNED TO: (A)
CONCEAL OR
DISGUISE THE NATURE, THE LOCATION, THE SOURCE, THE

OWNERSHIP OR THE CONTROL OF THE PROCEEDS OF CRIMINAL
CONDUCT; AND (B) THE TOTAL VALUE OF THE PROPERTY
INVOLVED IN SUCH FINANCIAL TRANSACTION OR
TRANSACTIONS EXCEEDED $5,000.
PATTERN ACT 73
CONCERT WITH OTHERS, COMMITTED THE CRIME OF MONEY
LAUNDERING IN THE SECOND DEGREE IN VIOLATION OF PENAL
LAW SECTION 470.15(1)(B)(I)(A)(III), IN THAT ON OR ABOUT AND
BETWEEN JANUARY 30, 2015 AND FEBRUARY 2, 2015, IN THE
COUNTY OF QUEENS AND ELSEWHERE, KNOWING THAT THE

PATTERN ACT 74
THE DEFENDANTS, CYRUS IRANI, MICHAEL GALLAGHER,
MICHAEL GALOYAN, AND SALLY MEDINA-CABELLO ACTING IN
CONCERT, COMMITTED THE CRIME OF PROMOTING GAMBLING IN
THE FIRST DEGREE, IN VIOLATION OF PENAL LAW SECTION
225.10(1), IN THAT ON OR ABOUT JANUARY 30, 2015, IN THE
PATTERN ACT 75
THE DEFENDANTS, CYRUS IRANI, THOMAS CORTESE, MICHAEL

GALLAGHER, MICHAEL GALOYAN, SAUL SALAMA, CASSONDRA
SMITH-LUTTMAN, AND SALLY MEDINA-CABELLO ACTING IN
225.10(1), IN THAT ON OR ABOUT JANUARY 31, 2015, IN THE
PATTERN ACT 76
ARRIAGA, CLARK W. BRUNER, CLARK O. BRUNER, CHRISTOPHER
BRUNER, THOMAS CORTESE, MICHAEL GALLAGHER, MICHAEL
GALOYAN, JOHNSON MATHEW, JIMMY JOSEPH, JEFFREY
METELITZ, SAUL SALAMA, CASSONDRA SMITH-LUTTMAN, AND
SALLY MEDINA-CABELLO ACTING IN CONCERT, COMMITTED THE
CRIME OF PROMOTING GAMBLING IN THE FIRST DEGREE, IN
ABOUT FEBRUARY 1, 2015, IN THE COUNTY OF QUEENS AND

MORE THAN $5,000.
PATTERN ACT 77
THE DEFENDANTS, CYRUS IRANI,
BRUNER, CHRISTOPHER BRUNER,
CLARK W. BRUNER, CLARK O.

MICHAEL GALLAGHER, MICHAEL
GALOYAN, JOHNSON MATHEW, JIMMY JOSEPH, JEFFREY

METELITZ, AND SALLY MEDINA-CABELLO ACTING IN CONCERT,
THAT ON OR ABOUT FEBRUARY 2, 2015, IN THE COUNTY OF
MORE THAN $5,000.
PATTERN ACT 78
THE DEFENDANTS, CYRUS IRANI, CLARK W. BRUNER, AND
RICHARD VANDERWYK, ACTING IN CONCERT WITH OTHERS,
COMMITTED THE CRIME COMMITTED THE CRIME OF MONEY

LAUNDERING IN THE FOURTH DEGREE, IN VIOLATION OF PENAL
LAW SECTION 470.05(2)(A)(I)(B), IN THAT ON OR ABOUT
FEBRUARY 2, 2015 AND FEBRUARY 12, 2015, IN THE COUNTY OF
QUEENS AND ELSEWHERE, KNOWING THAT ONE OR MORE
MONETARY INSTRUMENTS REPRESENTED THE PROCEEDS OF
SPECIFIED CRIMINAL CONDUCT, THEY TRANSPORTED,
PATTERN ACT 79
BRUNER, CHRISTOPHER BRUNER, MICHAEL GALLAGHER,
JOHNSON MATHEW, JIMMY JOSEPH, AND SALLY
FEBRUARY 3, 2015, IN THE COUNTY OF QUEENS AND ELSEWHERE,

PATTERN ACT 80
MICHAEL GALOYAN, JOHNSON MATHEW, JIMMY JOSEPH, AND
MORE THAN $5,000.
PATTERN ACT 81

MORE THAN $5,000.
PATTERN ACT 82
MORE THAN $5,000.
PATTERN ACT 83
ARRIAGA, CLARK W. BRUNER, CLARK O. BRUNER, CHRISTOPHER
BRUNER, THOMAS CORTESE, MICHAEL GALLAGHER, MICHAEL
GALOYAN, JOHNSON MATHEW, JIMMY JOSEPH, SAUL SALAMA
MORE THAN $5,000.
PATTERN ACT 84
THE DEFENDANTS, CYRUS IRANI, MICHAEL GALLAGHER,
JOHNSON MATHEW, JIMMY JOSEPH, CASSONDRA
SMITH-LUTTMAN AND SALLY MEDINA-CABELLO ACTING IN
225.10(1), IN THAT ON OR ABOUT FEBRUARY 8, 2015, IN THE

PATTERN ACT 85
THE DEFENDANTS, CYRUS IRANI, CASSONDRA SMITH-LUTTMAN
MORE THAN $5,000.
PATTERN ACT 86
470.05(2)(A)(I)(B), IN THAT ON OR ABOUT FEBRUARY 12, 2015, IN

THE COUNTY OF QUEENS AND ELSEWHERE, KNOWING THAT ONE
OR MORE MONETARY INSTRUMENTS REPRESENTED THE
PROCEEDS OF SPECIFIED CRIMINAL CONDUCT, THEY
PATTERN ACT 87
THE DEFENDANTS, CYRUS IRANI, CASSONDRA SMITH-LUTTMAN
MORE THAN $5,000.
PATTERN ACT 88
FEBRUARY 17, 2015, IN THE COUNTY OF QUEENS AND
PATTERN ACT 89
THE DEFENDANTS, CYRUS IRANI, CLARK O. BRUNER, CLARK W.
BRUNER, CHRISTOPHER BRUNER AND SALLY MEDINA-CABELLO
SECTION 225.10(1), IN THAT ON OR ABOUT FEBRUARY 23, 2015, IN

PATTERN ACT 90
PATTERN ACT 91

PATTERN ACT 92
PATTERN ACT 93

PATTERN ACT 94
BRUNER, CHRISTOPHER BRUNER, CASSONDRA SMITH-LUTTMAN,
ABOUT FEBRUARY 28 2015, IN THE COUNTY OF QUEENS AND
MORE THAN $5,000.
PATTERN ACT 95

BRUNER, CHRISTOPHER BRUNER, SAUL SALAMA, AND SALLY
OF PENAL LAW SECTION 225.10(1), IN THAT ON OR ABOUT MARCH
PATTERN ACT 96
THE DEFENDANTS, CYRUS IRANI, SAUL SALAMA, CLARK O.
BRUNER, CLARK W. BRUNER, CHRISTOPHER BRUNER, AND SALLY
PATTERN ACT 97
SECTION 225.10(1), IN THAT ON OR ABOUT MARCH 3, 2015, IN THE
PATTERN ACT 98
PATTERN ACT 99
PATTERN ACT 100

470.05(2)(A)(I)(B), IN THAT ON OR ABOUT MARCH 10, 2015, IN THE

PATTERN ACT 101

ABOUT MARCH 11, 2015, IN THE COUNTY OF QUEENS AND
MORE THAN $5,000.
PATTERN ACT 102


PATTERN ACT 103

THOMAS CORTESE, AND SALLY MEDINA-CABELLO ACTING IN
225.10(1), IN THAT ON OR ABOUT MARCH 22, 2015, IN THE COUNTY
OF QUEENS AND ELSEWHERE, THEY KNOWINGLY ADVANCED
AND PROFITED FROM UNLAWFUL GAMBLING ACTIVITY BY
ENGAGING IN BOOKMAKING TO THE EXTENT THAT THEY
RECEIVED OR ACCEPTED ON THAT DATE MORE THAN FIVE BETS
TOTALING MORE THAN $5,000.
PATTERN ACT 104


ABOUT MARCH 25, 2015, IN THE COUNTY OF QUEENS AND
MORE THAN $5,000.
PATTERN ACT 105

PATTERN ACT 106


PATTERN ACT 107

PATTERN ACT 108


PATTERN ACT 109

THE DEFENDANTS, CYRUS IRANI, CLARK W. BRUNER,
CHRISTOPHER BRUNER, AND RICHARD VANDERWYK, ACTING IN
APRIL 7, 2015, IN THE COUNTY OF QUEENS AND ELSEWHERE,
PATTERN ACT 110

RICHARD VANDERWYK, ACTING IN CONCERT WITH OTHERS,
LAW SECTION 470.05(2)(A)(I)(B), IN THAT ON OR ABOUT APRIL 17,
2015, IN THE COUNTY OF QUEENS AND ELSEWHERE, KNOWING
THAT ONE OR MORE MONETARY INSTRUMENTS REPRESENTED
THE PROCEEDS OF SPECIFIED CRIMINAL CONDUCT, THEY
PATTERN ACT 111

470.05(2)(A)(I)(B), IN THAT ON OR ABOUT MAY 4, 2015, IN THE

PATTERN ACT 112

THE DEFENDANTS, CYRUS IRANI AND MICHAEL GALLAGHER,
OR ABOUT MAY 15, 2015, IN THE COUNTY OF QUEENS AND
PATTERN ACT 113

THE DEFENDANTS, CYRUS IRANI, CLARK W. BRUNER, AND DAVID
CHANG, ACTING IN CONCERT WITH OTHERS, COMMITTED THE
CRIME COMMITTED THE CRIME OF MONEY LAUNDERING IN THE
470.05(2)(A)(I)(B), IN THAT ON OR ABOUT MAY 29, 2015, IN THE
PATTERN ACT 114

OR ABOUT JUNE 4, 2015, IN THE COUNTY OF QUEENS AND

PATTERN ACT 115

THE DEFENDANTS, CYRUS IRANI, SAUL SALAMA, AND SALLY
OF PENAL LAW SECTION 225.10(1), IN THAT ON OR ABOUT JUNE 28,
2015, IN THE COUNTY OF QUEENS AND ELSEWHERE, THEY
PATTERN ACT 116

RICHARD VANDERWYK, ACTING IN CONCERT, COMMITTED THE
CRIME COMMITTED THE CRIME OF MONEY LAUNDERING

COMMITTED THE CRIME OF MONEY IN THE THIRD DEGREE, IN
VIOLATION OF PENAL LAW SECTION 470.10(1)(B)(I)(A)(III), IN THAT
ON OR ABOUT JUNE 29, 2015, IN THE COUNTY OF QUEENS AND
ELSEWHERE, KNOWING THAT THE PROPERTY INVOLVED ONE OR
MORE FINANCIAL TRANSACTIONS REPRESENTS THE PROCEEDS
OF CRIMINAL CONDUCT, THEY CONDUCTED ONE OR MORE SUCH
PATTERN ACT 117

THE DEFENDANTS, CYRUS IRANI AND CLARK W. BRUNER,
ACTING IN CONCERT WITH OTHERS, COMMITTED THE CRIME
470.05(2)(A)(I)(B), IN THAT ON OR ABOUT JUNE 30, 2015, IN THE

PATTERN ACT 118

THE DEFENDANTS, CYRUS IRANI, CLARK W. BRUNER, RICHARD
VANDERWYK, AND DAVID CHANG, ACTING IN CONCERT,
LAW SECTION 470.05(2)(A)(I)(B), IN THAT ON OR ABOUT JULY 1,
2015, IN THE COUNTY OF QUEENS AND ELSEWHERE, KNOWING
THAT ONE OR MORE MONETARY INSTRUMENTS REPRESENTED
THE PROCEEDS OF SPECIFIED CRIMINAL CONDUCT, THEY
PATTERN ACT 119


OF PENAL LAW SECTION 225.10(1), IN THAT ON OR ABOUT JULY 2,
PATTERN ACT 120

PATTERN ACT 121


OR ABOUT JULY 16, 2015, IN THE COUNTY OF QUEENS AND
PATTERN ACT 122

PATTERN ACT 123

THE DEFENDANTS, CYRUS IRANI, CLARK W. BRUNER, AND DAVID
CHANG, ACTING IN CONCERT, COMMITTED THE CRIME
COMMITTED THE CRIME OF MONEY LAUNDERING COMMITTED
THE CRIME OF MONEY IN THE THIRD DEGREE, IN VIOLATION OF
PENAL LAW SECTION 470.10(1)(B)(I)(A)(III), IN THAT ON OR ABOUT
AUGUST 5, 2015, IN THE COUNTY OF QUEENS AND ELSEWHERE,
KNOWING THAT THE PROPERTY INVOLVED ONE OR MORE
FINANCIAL TRANSACTIONS REPRESENTS THE PROCEEDS OF
PATTERN ACT 124

THE DEFENDANTS, CYRUS IRANI AND JEFFREY METELITZ,
OR ABOUT AUGUST 11, 2015, IN THE COUNTY OF QUEENS AND

PATTERN ACT 125

SEPTEMBER 7, 2015, IN THE COUNTY OF QUEENS AND
MORE THAN $5,000.
SECOND COUNT
THE GRAND JURY OF THE COUNTY OF QUEENS BY THIS INDICTMENT,
ACCUSES THE DEFENDANTS CYRUS IRANI, SAUL SALAMA, JOHNSON MATHEW, RICHARD
VANDERWYK, JEFFREY METELITZ, DAVID CHANG, THOMAS CORTESE, ANDRES
ARRIAGA, MICHAEL GALLAGHER, CLARK W BRUNER, CLARK OLIVER BRUNER,
CHRISTOPHER BRUNER AND MICHAEL GALOYAN OF MONEY LAUNDERING IN THE
FIRST DEGREE COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHERS AND ACTING IN CONCERT WITH
OTHER PERSONS, ON OR ABOUT AND BETWEEN JANUARY 03, 2013 AND SEPTEMBER
08, 2015 IN THE COUNTY OF QUEENS AND ELSEWHERE, KNOWING THAT THE
PROPERTY INVOLVED IN ONE OR MORE FINANCIAL TRANSACTIONS REPRESENTED
THE PROCEEDS OF A CLASS A, B OR C FELONY UNDER THE LAWS OF THIS STATE,
CONDUCTED ONE OR MORE SUCH FINANCIAL TRANSACTIONS, , AS FOLLOWS: THE
EXCHANGE OF ILLEGAL SPORTS GAMBLING PROCEEDS, WHICH IN FACT INVOLVED THE
PROCEEDS OF SPECIFIED CRIMINAL CONDUCT, WHICH IN FACT INVOLVED THE
PROCEEDS OF ANY SUCH FELONY, WITH INTENT TO PROMOTE THE CARRYING ON OF
CRIMINAL CONDUCT, AND THE TOTAL VALUE OF THE PROPERTY INVOLVED IN SUCH
FINANCIAL TRANSACTION OR TRANSACTIONS EXCEEDED ONE MILLION DOLLARS.
THIRD COUNT
ACCUSES THE DEFENDANTS CYRUS IRANI AND JOHNSON MATHEW OF MONEY
LAUNDERING IN THE SECOND DEGREE COMMITTED AS FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHER AND ACTING IN CONCERT
WITH OTHER PERSONS, ON OR ABOUT AND BETWEEN JANUARY 03, 2013 AND JANUARY
THE PROCEEDS OF SPECIFIED CRIMINAL CONDUCT, CONDUCTED ONE OR MORE SUCH
FINANCIAL TRANSACTIONS, AS FOLLOWS: THE EXCHANGE OF ILLEGAL SPORTS
GAMBLING PROCEEDS, WHICH IN FACT INVOLVED THE PROCEEDS OF SPECIFIED
CRIMINAL CONDUCT, WHICH IN FACT INVOLVED THE PROCEEDS OF SPECIFIED
CRIMINAL CONDUCT, WITH INTENT TO PROMOTE THE CARRYING ON OF SPECIFIED
CRIMINAL CONDUCT; AND THE TOTAL VALUE OF THE PROPERTY INVOLVED IN SUCH
FINANCIAL TRANSACTION OR TRANSACTIONS EXCEEDED ONE HUNDRED THOUSAND
DOLLARS.
FOURTH COUNT
ACCUSES THE DEFENDANTS OF CONSPIRACY IN THE FIFTH DEGREE COMMITTED AS
FOLLOWS:
OTHER PERSONS, ON OR ABOUT AND BETWEEN JANUARY 03, 2013 AND SEPTEMBER
08, 2015 IN THE COUNTY OF QUEENS WITH INTENT THAT CONDUCT CONSTITUTING A
FELONY BE PERFORMED, AGREED WITH ONE OR MORE PERSONS TO ENGAGE IN OR
CAUSE THE PERFORMANCE OF SUCH CONDUCT.
AND IN THE FURTHERANCE OF
SAID CONSPIRACY AND IN ORDER TO EFFECT THE OBJECTS THEREOF, THE

FOLLOWING OVERT ACTS, AMONG OTHERS, WERE DONE AND PERFORMED BY CERTAIN
OF THE PARTIES TO SAID CONSPIRACY, NAMELY: ON FEBRUARY 17, 2015, MICHAEL
GALOYAN DELIVERED GAMBLING
PROCEEDS FROM INTERNET GAMBLING IN QUEENS COUNTY.
FIFTH COUNT
ACCUSES THE DEFENDANTS CYRUS IRANI, JOHNSON MATHEW, SALLY MEDINA-CABELLO
AND JIMMY JOSEPH OF PROMOTING GAMBLING IN THE FIRST DEGREE COMMITTED
AS FOLLOWS:
OTHER PERSONS, ON OR ABOUT FEBRUARY 24, 2014 IN THE COUNTY OF QUEENS AND
ELSEWHERE, KNOWINGLY ADVANCED OR PROFITED FROM UNLAWFUL GAMBLING
ACTIVITY BY ENGAGING IN BOOKMAKING TO THE EXTENT THAT THEY RECEIVED OR
ACCEPTED IN ANY ONE DAY MORE THAN FIVE BETS TOTALING MORE THAN FIVE
THOUSAND DOLLARS.
SIXTH COUNT
ACCUSES THE DEFENDANTS CYRUS IRANI AND MICHAEL GALOYAN OF MONEY
LAUNDERING IN THE THIRD DEGREE COMMITTED AS FOLLOWS:
WITH OTHER PERSONS, ON OR ABOUT AND BETWEEN MARCH 05, 2014 AND JUNE
THE PROCEEDS OF CRIMINAL CONDUCT, CONDUCTED ONE OR MORE SUCH FINANCIAL
TRANSACTIONS, AS FOLLOWS: THE EXCHANGE OF ILLEGAL SPORTS GAMBLING
PROCEEDS, WHICH IN FACT INVOLVED THE PROCEEDS OF SPECIFIED CRIMINAL
CONDUCT, WHICH IN FACT INVOLVED THE PROCEEDS OF SPECIFIED CRIMINAL
CONDUCT, WITH INTENT TO PROMOTE THE CARRYING ON OF CRIMINAL CONDUCT, AND
THE TOTAL VALUE OF THE PROPERTY INVOLVED IN SUCH FINANCIAL TRANSACTION
OR TRANSACTIONS EXCEEDED FIFTY THOUSAND DOLLARS.
SEVENTH COUNT
ACCUSES THE DEFENDANTS CYRUS IRANI AND MICHAEL GALOYAN OF CONSPIRACY
IN THE FIFTH DEGREE COMMITTED AS FOLLOWS:
WITH OTHER PERSONS, ON OR ABOUT AND BETWEEN MARCH 05, 2014 AND JUNE
30, 2014 IN THE COUNTY OF QUEENS WITH INTENT THAT CONDUCT CONSTITUTING A
FELONY BE PERFORMED, AGREED WITH ONE OR MORE PERSONS TO ENGAGE IN OR
CAUSE THE PERFORMANCE OF SUCH CONDUCT.
AND IN THE FURTHERANCE OF
SAID CONSPIRACY AND IN ORDER TO EFFECT THE OBJECTS THEREOF, THE

FOLLOWING OVERT ACTS, AMONG OTHERS, WERE DONE AND PERFORMED BY CERTAIN
OF THE PARTIES TO SAID CONSPIRACY, NAMELY: ON APRIL 8, 2014, MICHAEL
GALOYAN SPOKE TO CYRUS IRANI FROM
QUEENS COUNTY, NEW YORK USING TELEPHONE NUMBER (718) 721-7513 TO DISCUSS
CUSTOMER K604 AND THEN DEPOSITED $5,000 CASH INTO CYRUS' BANK OF AMERICA
ACCOUNT FROM THE FOREST HILLS, QUEENS BRANCH.
EIGHTH COUNT
ACCUSES THE DEFENDANTS CYRUS IRANI AND ANDRES ARRIAGA OF MONEY
LAUNDERING IN THE FOURTH DEGREE COMMITTED AS FOLLOWS:
WITH OTHER PERSONS, ON OR ABOUT MARCH 07, 2014 IN THE COUNTY OF QUEENS
AND ELSEWHERE, KNOWING THAT ONE OR MORE MONETARY INSTRUMENTS REPRESENTED
THE PROCEEDS OF CRIMINAL CONDUCT,
TRANSPORTED, TRANSMITTED OR
TRANSFERRED ONE OR MORE OCCASIONS, MONETARY INSTRUMENTS WHICH IN FACT

REPRESENTED THE PROCEEDS OF SPECIFIED CRIMINAL CONDUCT, WITH THE
INTENT TO PROMOTE THE CARRYING ON OF CRIMINAL CONDUCT, AND THE TOTAL
VALUE OF SUCH MONETARY INSTRUMENT OR INSTRUMENTS EXCEEDED TEN THOUSAND
DOLLARS.
NINTH COUNT
ACCUSES THE DEFENDANTS CYRUS IRANI AND JEFFREY METELITZ OF MONEY

DOLLARS.
TENTH COUNT
ACCUSES THE DEFENDANTS CYRUS IRANI AND DAVID CHANG OF MONEY LAUNDERING
IN THE FOURTH DEGREE COMMITTED AS FOLLOWS:

DOLLARS.
ELEVENTH COUNT
AS FOLLOWS:
OTHER PERSONS, ON OR ABOUT APRIL 07, 2014 IN THE COUNTY OF QUEENS AND
THOUSAND DOLLARS.
TWELFTH COUNT
AS FOLLOWS:
THOUSAND DOLLARS.
THIRTEENTH COUNT
ACCUSES THE DEFENDANTS CYRUS IRANI AND SAUL SALAMA OF MONEY LAUNDERING
WITH OTHER PERSONS, ON OR ABOUT APRIL 10, 2014 IN THE COUNTY OF QUEENS

DOLLARS.
FOURTEENTH COUNT
AS FOLLOWS:
THOUSAND DOLLARS.
FIFTEENTH COUNT
AS FOLLOWS:
THOUSAND DOLLARS.
SIXTEENTH COUNT
AS FOLLOWS:
THOUSAND DOLLARS.
SEVENTEENTH COUNT
AS FOLLOWS:
THOUSAND DOLLARS.
EIGHTEENTH COUNT
AS FOLLOWS:
THOUSAND DOLLARS.
NINETEENTH COUNT
ACCUSES THE DEFENDANTS CYRUS IRANI, SALLY MEDINA-CABELLO AND JEFFREY
METELITZ OF PROMOTING GAMBLING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:
THOUSAND DOLLARS.
TWENTIETH COUNT
THOUSAND DOLLARS.
TWENTY FIRST COUNT

THOUSAND DOLLARS.
TWENTY SECOND COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, JOHNSON MATHEW, SALLY MEDINACABELLO, JEFFREY METELITZ AND JIMMY JOSEPH OF PROMOTING GAMBLING IN
THE FIRST DEGREE COMMITTED AS FOLLOWS:
THOUSAND DOLLARS.
TWENTY THIRD COUNT

AS FOLLOWS:
THOUSAND DOLLARS.
TWENTY FOURTH COUNT

AS FOLLOWS:
OTHER PERSONS, ON OR ABOUT MAY 01, 2014 IN THE COUNTY OF QUEENS AND
THOUSAND DOLLARS.
TWENTY FIFTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI AND THOMAS CORTESE OF MONEY
LAUNDERING IN THE THIRD DEGREE COMMITTED AS FOLLOWS:
WITH OTHER PERSONS, ON OR ABOUT AND BETWEEN MAY 02, 2014 AND JUNE 30,
2015 IN THE COUNTY OF QUEENS, KNOWING THAT THE PROPERTY INVOLVED IN
ONE OR MORE FINANCIAL TRANSACTIONS REPRESENTED THE PROCEEDS OF
CRIMINAL CONDUCT, CONDUCTED ONE OR MORE SUCH FINANCIAL TRANSACTIONS,
AS FOLLOWS: THE EXCHANGE OF ILLEGAL SPORTS GAMBLING PROCEEDS, WHICH IN
FACT INVOLVED THE PROCEEDS OF SPECIFIED CRIMINAL CONDUCT, WHICH IN
FACT INVOLVED THE PROCEEDS OF SPECIFIED CRIMINAL CONDUCT, WITH INTENT TO
PROMOTE THE CARRYING ON OF CRIMINAL CONDUCT, AND THE TOTAL VALUE OF
THE PROPERTY INVOLVED IN SUCH FINANCIAL TRANSACTION OR TRANSACTIONS
EXCEEDED FIFTY THOUSAND DOLLARS.
TWENTY SIXTH COUNT

ACCUSES THE DEFENDANT CYRUS IRANI OF MONEY LAUNDERING IN THE FOURTH
DEGREE COMMITTED AS FOLLOWS:
THE DEFENDANT, ON OR ABOUT MAY 13, 2014 IN THE COUNTY OF QUEENS
AND ELSEWHERE, KNOWING THAT THE PROPERTY INVOLVED IN ONE OR MORE
FINANCIAL TRANSACTIONS REPRESENTED THE PROCEEDS OF CRIMINAL CONDUCT,
CONDUCTED ONE OR MORE SUCH FINANCIAL TRANSACTIONS, AS FOLLOWS: THE
PROCEEDS OF CRIMINAL CONDUCT, KNOWING THAT THE TRANSACTION OR
TRANSACTIONS IN WHOLE OR IN PART WERE DESIGNED TO CONCEAL OR DISGUISE
THE NATURE, THE LOCATION, THE SOURCE, THE OWNERSHIP OR THE CONTROL OF
THE PROCEEDS OF CRIMINAL CONDUCT, AND THE TOTAL VALUE OF THE PROPERTY
INVOLVED IN SUCH FINANCIAL TRANSACTION OR TRANSACTIONS EXCEEDED FIVE
THOUSAND DOLLARS.
TWENTY SEVENTH COUNT

THE DEFENDANT, ON OR ABOUT MAY 27, 2014 IN THE COUNTY OF QUEENS
AND ELSEWHERE, KNOWING THAT THE PROPERTY INVOLVED IN ONE OR MORE
FINANCIAL TRANSACTIONS REPRESENTED THE PROCEEDS OF CRIMINAL CONDUCT,
CONDUCTED ONE OR MORE SUCH FINANCIAL TRANSACTIONS, AS FOLLOWS: THE
PROCEEDS OF CRIMINAL CONDUCT, KNOWING THAT THE TRANSACTION OR
TRANSACTIONS IN WHOLE OR IN PART WERE DESIGNED TO CONCEAL OR DISGUISE
THE NATURE, THE LOCATION, THE SOURCE, THE OWNERSHIP OR THE CONTROL OF
THE PROCEEDS OF CRIMINAL CONDUCT, AND THE TOTAL VALUE OF THE PROPERTY
INVOLVED IN SUCH FINANCIAL TRANSACTION OR TRANSACTIONS EXCEEDED FIVE
THOUSAND DOLLARS.
TWENTY EIGHTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, SALLY MEDINA-CABELLO, CLARK W
BRUNER, CLARK OLIVER BRUNER AND CHRISTOPHER BRUNER OF PROMOTING GAMBLING
IN THE FIRST DEGREE COMMITTED AS FOLLOWS:
OTHER PERSONS, ON OR ABOUT SEPTEMBER 21, 2014 IN THE COUNTY OF QUEENS
AND ELSEWHERE, KNOWINGLY ADVANCED OR PROFITED FROM UNLAWFUL GAMBLING
THOUSAND DOLLARS.
TWENTY NINTH COUNT

THOUSAND DOLLARS.
THIRTIETH COUNT
THOUSAND DOLLARS.
THIRTY FIRST COUNT

OTHER PERSONS, ON OR ABOUT OCTOBER 04, 2014 IN THE COUNTY OF QUEENS
THOUSAND DOLLARS.
THIRTY SECOND COUNT

THOUSAND DOLLARS.
THIRTY THIRD COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, CLARK W BRUNER AND CLARK OLIVER
BRUNER OF MONEY LAUNDERING IN THE FOURTH DEGREE COMMITTED AS FOLLOWS:

DOLLARS.
THIRTY FOURTH COUNT

THOUSAND DOLLARS.
THIRTY FIFTH COUNT

THOUSAND DOLLARS.
THIRTY SIXTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, SAUL SALAMA, JOHNSON MATHEW, SALLY
MEDINA-CABELLO, JEFFREY METELITZ, JIMMY JOSEPH, JULIO ALVARENGA AND
ANDRES ARRIAGA OF PROMOTING GAMBLING IN THE FIRST DEGREE COMMITTED AS
FOLLOWS:
THOUSAND DOLLARS.
THIRTY SEVENTH COUNT

FOLLOWS:
THOUSAND DOLLARS.
THIRTY EIGHTH COUNT

WITH OTHER PERSONS, ON OR ABOUT OCTOBER 14, 2014 IN THE COUNTY OF QUEENS

DOLLARS.
THIRTY NINTH COUNT

FOLLOWS:
THOUSAND DOLLARS.
FORTIETH COUNT
FOLLOWS:
THOUSAND DOLLARS.
FORTY FIRST COUNT

MEDINA-CABELLO, JEFFREY METELITZ AND JIMMY JOSEPH OF PROMOTING
GAMBLING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:
THOUSAND DOLLARS.
FORTY SECOND COUNT

WITH OTHER PERSONS, ON OR ABOUT OCTOBER 17, 2014 IN THE COUNTY OF QUEENS

DOLLARS.
FORTY THIRD COUNT

FOLLOWS:
THOUSAND DOLLARS.
FORTY FOURTH COUNT

FOLLOWS:
THOUSAND DOLLARS.
FORTY FIFTH COUNT

WITH OTHER PERSONS, ON OR ABOUT NOVEMBER 21, 2014 IN THE COUNTY OF
QUEENS AND ELSEWHERE, KNOWING THAT ONE OR MORE MONETARY INSTRUMENTS
REPRESENTED THE PROCEEDS OF CRIMINAL CONDUCT,
TRANSPORTED,
TRANSMITTED OR TRANSFERRED ONE OR MORE OCCASIONS, MONETARY INSTRUMENTS

WHICH IN FACT REPRESENTED THE PROCEEDS OF SPECIFIED CRIMINAL CONDUCT,
WITH THE INTENT TO PROMOTE THE CARRYING ON OF CRIMINAL CONDUCT, AND
THE TOTAL VALUE OF SUCH MONETARY INSTRUMENT OR INSTRUMENTS EXCEEDED
TEN THOUSAND DOLLARS.
FORTY SIXTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI AND ANDRES ARRIAGA OF MONEY
WITH OTHER PERSONS, ON OR ABOUT NOVEMBER 21, 2014 IN THE COUNTY OF
TRANSPORTED,

FORTY SEVENTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI AND RICHARD VANDERWYK OF MONEY
WITH OTHER PERSONS, ON OR ABOUT AND BETWEEN NOVEMBER 30, 2014 AND
DECEMBER 01, 2014 IN THE COUNTY OF QUEENS AND ELSEWHERE, KNOWING THAT
ONE OR MORE MONETARY INSTRUMENTS REPRESENTED THE PROCEEDS OF CRIMINAL
CONDUCT,
TRANSPORTED, TRANSMITTED OR TRANSFERRED ONE OR MORE OCCASIONS,
MONETARY INSTRUMENTS WHICH IN FACT REPRESENTED THE PROCEEDS OF SPECIFIED

CRIMINAL CONDUCT, WITH THE INTENT TO PROMOTE THE CARRYING ON OF CRIMINAL
CONDUCT, AND THE TOTAL VALUE OF SUCH MONETARY INSTRUMENT OR
INSTRUMENTS EXCEEDED TEN THOUSAND DOLLARS.
FORTY EIGHTH COUNT

WITH OTHER PERSONS, ON OR ABOUT DECEMBER 10, 2014 IN THE COUNTY OF
TRANSPORTED,

FORTY NINTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI AND SAUL SALAMA OF CONSPIRACY IN
THE FOURTH DEGREE COMMITTED AS FOLLOWS:
WITH OTHER PERSONS, ON OR ABOUT AND BETWEEN DECEMBER 19, 2014 AND
DECEMBER 20, 2014 IN THE COUNTY OF QUEENS, WITH INTENT THAT CONDUCT
CONSTITUTING A CLASS B OR CLASS C FELONY BE PERFORMED, AGREED WITH ONE
OR MORE PERSONS TO ENGAGE IN OR CAUSE THE PERFORMANCE OF SUCH CONDUCT.
AND IN THE FURTHERANCE OF SAID CONSPIRACY AND IN ORDER TO EFFECT THE
OBJECTS THEREOF, THE FOLLOWING OVERT ACTS, AMONG OTHERS, WERE DONE AND
PERFORMED BY CERTAIN OF THE PARTIES TO SAID UNLAWFUL CONSPIRACY, NAMELY:
ON
DECEMBER 19, 2014, CYRUS IRANI AND SAUL SALAMA HAD A
CONVERSATION WHEREIN SAUL AGREED TO DELIVER $140,000 IN
CASH TO A MANHATTAN COMIC BOOK COLLECTIBLES STORE.
ON DECEMBER 20, 2014, SAUL SALAMA DELIVERED THE MONEY.
FIFTIETH COUNT
IN THE SECOND DEGREE COMMITTED AS FOLLOWS:
WITH OTHER PERSONS, ON OR ABOUT DECEMBER 20, 2014 IN THE COUNTY OF
QUEENS AND ELSEWHERE, KNOWING THAT THE PROPERTY INVOLVED IN ONE OR
MORE FINANCIAL TRANSACTIONS REPRESENTED THE PROCEEDS OF SPECIFIED
CRIMINAL CONDUCT, CONDUCTED ONE OR MORE SUCH FINANCIAL TRANSACTIONS,
AS FOLLOWS: THE EXCHANGE OF ILLEGAL SPORTS GAMBLING PROCEEDS, WHICH IN
FACT INVOLVED THE PROCEEDS OF SPECIFIED CRIMINAL CONDUCT, WHICH IN
FACT INVOLVED THE PROCEEDS OF SPECIFIED CRIMINAL CONDUCT, WITH INTENT TO
PROMOTE THE CARRYING ON OF SPECIFIED CRIMINAL CONDUCT; AND THE TOTAL
VALUE OF THE PROPERTY INVOLVED IN SUCH FINANCIAL TRANSACTION OR
TRANSACTIONS EXCEEDED ONE HUNDRED THOUSAND DOLLARS.
FIFTY FIRST COUNT

OTHER PERSONS, ON OR ABOUT AND BETWEEN DECEMBER 29, 2014 AND DECEMBER
31, 2014 IN THE COUNTY OF QUEENS AND ELSEWHERE, KNOWING THAT ONE OR MORE
MONETARY INSTRUMENTS REPRESENTED THE PROCEEDS OF CRIMINAL CONDUCT,
FIFTY SECOND COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, SAUL SALAMA, SALLY MEDINA-CABELLO
AND THOMAS CORTESE OF PROMOTING GAMBLING IN THE FIRST DEGREE COMMITTED
AS FOLLOWS:
OTHER PERSONS, ON OR ABOUT JANUARY 01, 2015 IN THE COUNTY OF QUEENS
THOUSAND DOLLARS.
FIFTY THIRD COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, SALLY MEDINA-CABELLO AND THOMAS
CORTESE OF PROMOTING GAMBLING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:
THOUSAND DOLLARS.
FIFTY FOURTH COUNT


DOLLARS.
FIFTY FIFTH COUNT

THOUSAND DOLLARS.
FIFTY SIXTH COUNT

THOUSAND DOLLARS.
FIFTY SEVENTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI AND JOHNSON MATHEW OF MONEY
WITH OTHER PERSONS, ON OR ABOUT AND BETWEEN JANUARY 04, 2015 AND JUNE
FIFTY EIGHTH COUNT


DOLLARS.
FIFTY NINTH COUNT


DOLLARS.
SIXTIETH COUNT
THOUSAND DOLLARS.
SIXTY FIRST COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, SALLY MEDINA-CABELLO AND CASSONDRA
SMITH-LUTTMAN OF PROMOTING GAMBLING IN THE FIRST DEGREE COMMITTED AS
FOLLOWS:
THOUSAND DOLLARS.
SIXTY SECOND COUNT

FOLLOWS:
THOUSAND DOLLARS.
SIXTY THIRD COUNT

OTHER PERSONS, ON OR ABOUT AND BETWEEN JANUARY 16, 2015 AND JANUARY
SIXTY FOURTH COUNT

FOLLOWS:
THOUSAND DOLLARS.
SIXTY FIFTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, SALLY MEDINA-CABELLO, JULIO
ALVARENGA AND ANDRES ARRIAGA OF PROMOTING GAMBLING IN THE FIRST DEGREE
COMMITTED AS FOLLOWS:
THOUSAND DOLLARS.
SIXTY SIXTH COUNT

THOUSAND DOLLARS.
SIXTY SEVENTH COUNT

ALVARENGA, ANDRES ARRIAGA AND CASSONDRA SMITH-LUTTMAN OF PROMOTING
GAMBLING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:
THOUSAND DOLLARS.
SIXTY EIGHTH COUNT

THOUSAND DOLLARS.
SIXTY NINTH COUNT

AS FOLLOWS:
THOUSAND DOLLARS.
SEVENTIETH COUNT
THOUSAND DOLLARS.
SEVENTY FIRST COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, JOHNSON MATHEW, SALLY MEDINACABELLO, JEFFREY METELITZ AND JIMMY JOSEPH OF PROMOTING GAMBLING IN
THE FIRST DEGREE COMMITTED AS FOLLOWS:
THOUSAND DOLLARS.
SEVENTY SECOND COUNT

THOUSAND DOLLARS.
SEVENTY THIRD COUNT

THE DEFENDANT, ON OR ABOUT JANUARY 29, 2015 IN THE COUNTY OF
QUEENS AND ELSEWHERE, KNOWING THAT THE PROPERTY INVOLVED IN ONE OR
MORE FINANCIAL TRANSACTIONS REPRESENTED THE PROCEEDS OF CRIMINAL
CONDUCT, CONDUCTED ONE OR MORE SUCH FINANCIAL TRANSACTIONS, AS
FOLLOWS: THE EXCHANGE OF ILLEGAL SPORTS GAMBLING PROCEEDS, WHICH IN FACT
INVOLVED THE PROCEEDS OF SPECIFIED CRIMINAL CONDUCT, WHICH IN FACT
INVOLVED THE PROCEEDS OF CRIMINAL CONDUCT, KNOWING THAT THE
TRANSACTION OR TRANSACTIONS IN WHOLE OR IN PART WERE DESIGNED TO CONCEAL
OR DISGUISE THE NATURE, THE LOCATION, THE SOURCE, THE OWNERSHIP OR THE
CONTROL OF THE PROCEEDS OF CRIMINAL CONDUCT, AND THE TOTAL VALUE OF
THE PROPERTY INVOLVED IN SUCH FINANCIAL TRANSACTION OR TRANSACTIONS
EXCEEDED FIVE THOUSAND DOLLARS.
SEVENTY FOURTH COUNT

IN THE SECOND DEGREE COMMITTED AS FOLLOWS:
WITH OTHER PERSONS, ON OR ABOUT AND BETWEEN JANUARY 30, 2015 AND
FEBRUARY 02, 2015 IN THE COUNTY OF QUEENS AND ELSEWHERE, KNOWING THAT
THE PROPERTY INVOLVED IN ONE OR MORE FINANCIAL TRANSACTIONS
REPRESENTED THE PROCEEDS OF SPECIFIED CRIMINAL CONDUCT, CONDUCTED ONE OR
MORE SUCH FINANCIAL TRANSACTIONS, AS FOLLOWS: THE EXCHANGE OF ILLEGAL
SPORTS GAMBLING PROCEEDS, WHICH IN FACT INVOLVED THE PROCEEDS OF
SPECIFIED CRIMINAL CONDUCT, WHICH IN FACT INVOLVED THE PROCEEDS OF
SPECIFIED CRIMINAL CONDUCT, WITH INTENT TO PROMOTE THE CARRYING ON OF
SPECIFIED CRIMINAL CONDUCT; AND THE TOTAL VALUE OF THE PROPERTY INVOLVED
IN SUCH FINANCIAL TRANSACTION OR TRANSACTIONS EXCEEDED ONE HUNDRED
THOUSAND DOLLARS.
SEVENTY FIFTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, SALLY MEDINA-CABELLO, MICHAEL
GALLAGHER AND MICHAEL GALOYAN OF PROMOTING GAMBLING IN THE FIRST
THOUSAND DOLLARS.
SEVENTY SIXTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, SAUL SALAMA, SALLY MEDINA-CABELLO,
JEFFREY METELITZ, THOMAS CORTESE, MICHAEL GALLAGHER, CASSONDRA SMITHLUTTMAN AND MICHAEL GALOYAN OF PROMOTING GAMBLING IN THE FIRST DEGREE
THOUSAND DOLLARS.
SEVENTY SEVENTH COUNT

MEDINA-CABELLO, JEFFREY METELITZ, JIMMY JOSEPH, JULIO ALVARENGA,
THOMAS CORTESE, ANDRES ARRIAGA, MICHAEL GALLAGHER, CASSONDRA SMITHLUTTMAN, CLARK W BRUNER, CLARK OLIVER BRUNER, CHRISTOPHER BRUNER AND
MICHAEL GALOYAN OF PROMOTING GAMBLING IN THE FIRST DEGREE COMMITTED AS
FOLLOWS:
THOUSAND DOLLARS.
SEVENTY EIGHTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, JOHNSON MATHEW, SALLY MEDINACABELLO, JEFFREY METELITZ, JIMMY JOSEPH, MICHAEL GALLAGHER, CLARK W
BRUNER, CLARK OLIVER BRUNER, CHRISTOPHER BRUNER AND MICHAEL GALOYAN OF
PROMOTING GAMBLING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:
THOUSAND DOLLARS.
SEVENTY NINTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, RICHARD VANDERWYK AND CLARK W BRUNER
OF MONEY LAUNDERING IN THE FOURTH DEGREE COMMITTED AS FOLLOWS:
OTHER PERSONS, ON OR ABOUT AND BETWEEN FEBRUARY 02, 2015 AND FEBRUARY
EIGHTIETH COUNT
ACCUSES THE DEFENDANTS CYRUS IRANI, JOHNSON MATHEW, SALLY MEDINACABELLO, JIMMY JOSEPH, MICHAEL GALLAGHER, CLARK W BRUNER, CLARK OLIVER
BRUNER AND CHRISTOPHER BRUNER OF PROMOTING GAMBLING IN THE FIRST
THOUSAND DOLLARS.
EIGHTY FIRST COUNT

BRUNER, CHRISTOPHER BRUNER AND MICHAEL GALOYAN OF PROMOTING GAMBLING
THOUSAND DOLLARS.
EIGHTY SECOND COUNT

THOUSAND DOLLARS.
EIGHTY THIRD COUNT

THOUSAND DOLLARS.
EIGHTY FOURTH COUNT

MEDINA-CABELLO, JIMMY JOSEPH, JULIO ALVARENGA, THOMAS CORTESE, ANDRES
ARRIAGA, MICHAEL GALLAGHER, CLARK W BRUNER, CLARK OLIVER BRUNER,
CHRISTOPHER BRUNER AND MICHAEL GALOYAN OF PROMOTING GAMBLING IN THE
FIRST DEGREE COMMITTED AS FOLLOWS:
THOUSAND DOLLARS.
EIGHTY FIFTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, JOHNSON MATHEW, SALLY MEDINACABELLO, JIMMY JOSEPH, MICHAEL GALLAGHER AND CASSONDRA SMITH-LUTTMAN
OF PROMOTING GAMBLING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:
THOUSAND DOLLARS.
EIGHTY SIXTH COUNT

FOLLOWS:
THOUSAND DOLLARS.
EIGHTY SEVENTH COUNT

ELSEWHERE, KNOWING THAT ONE OR MORE MONETARY INSTRUMENTS REPRESENTED THE
PROCEEDS OF CRIMINAL CONDUCT,
TRANSPORTED, TRANSMITTED OR TRANSFERRED
ONE OR MORE OCCASIONS, MONETARY INSTRUMENTS WHICH IN FACT REPRESENTED

THE PROCEEDS OF SPECIFIED CRIMINAL CONDUCT, WITH THE INTENT TO PROMOTE
THE CARRYING ON OF CRIMINAL CONDUCT, AND THE TOTAL VALUE OF SUCH
MONETARY INSTRUMENT OR INSTRUMENTS EXCEEDED TEN THOUSAND DOLLARS.
EIGHTY EIGHTH COUNT

FOLLOWS:
THOUSAND DOLLARS.
EIGHTY NINTH COUNT

WITH OTHER PERSONS, ON OR ABOUT FEBRUARY 17, 2015 IN THE COUNTY OF
TRANSPORTED,

NINETIETH COUNT
THOUSAND DOLLARS.
NINETY FIRST COUNT

THOUSAND DOLLARS.
NINETY SECOND COUNT

THOUSAND DOLLARS.
NINETY THIRD COUNT

THOUSAND DOLLARS.
NINETY FOURTH COUNT

THOUSAND DOLLARS.
NINETY FIFTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, SALLY MEDINA-CABELLO, CASSONDRA
SMITH-LUTTMAN, CLARK W BRUNER, CLARK OLIVER BRUNER AND CHRISTOPHER
BRUNER OF PROMOTING GAMBLING IN THE FIRST DEGREE COMMITTED AS FOLLOWS:
THOUSAND DOLLARS.
NINETY SIXTH COUNT

CLARK W BRUNER, CLARK OLIVER BRUNER AND CHRISTOPHER BRUNER OF
OTHER PERSONS, ON OR ABOUT MARCH 01, 2015 IN THE COUNTY OF QUEENS AND
THOUSAND DOLLARS.
NINETY SEVENTH COUNT

CLARK W BRUNER, CLARK OLIVER BRUNER AND CHRISTOPHER BRUNER OF
THOUSAND DOLLARS.
NINETY EIGHTH COUNT

THOUSAND DOLLARS.
NINETY NINTH COUNT

THOUSAND DOLLARS.
ONE HUNDREDTH COUNT

THOUSAND DOLLARS.
ONE HUNDRED AND FIRST COUNT


ONE HUNDRED AND SECOND COUNT

FOLLOWS:
THOUSAND DOLLARS.
ONE HUNDRED AND THIRD COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, SAUL SALAMA, SALLY MEDINA-CABELLO
AND THOMAS CORTESE OF PROMOTING GAMBLING IN THE FIRST DEGREE COMMITTED
AS FOLLOWS:
THOUSAND DOLLARS.
ONE HUNDRED AND FOURTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, SALLY MEDINA-CABELLO, THOMAS CORTESE
AND CASSONDRA SMITH-LUTTMAN OF PROMOTING GAMBLING IN THE FIRST DEGREE
THOUSAND DOLLARS.
ONE HUNDRED AND FIFTH COUNT

FOLLOWS:
THOUSAND DOLLARS.
ONE HUNDRED AND SIXTH COUNT

THOUSAND DOLLARS.
ONE HUNDRED AND SEVENTH COUNT

THOUSAND DOLLARS.
ONE HUNDRED AND EIGHTH COUNT

THOUSAND DOLLARS.
ONE HUNDRED AND NINTH COUNT

THOUSAND DOLLARS.
ONE HUNDRED AND TENTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, RICHARD VANDERWYK, CLARK W BRUNER
AND CHRISTOPHER BRUNER OF MONEY LAUNDERING IN THE FOURTH DEGREE

ONE HUNDRED AND ELEVENTH COUNT

OF MONEY LAUNDERING IN THE FOURTH DEGREE COMMITTED AS FOLLOWS:

ONE HUNDRED AND TWELFTH COUNT


ONE HUNDRED AND THIRTEENTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI AND MICHAEL GALLAGHER OF MONEY
WITH OTHER PERSONS, ON OR ABOUT MAY 15, 2015 IN THE COUNTY OF QUEENS AND

ONE HUNDRED AND FOURTEENTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, DAVID CHANG AND CLARK W BRUNER OF
MONEY LAUNDERING IN THE FOURTH DEGREE COMMITTED AS FOLLOWS:

ONE HUNDRED AND FIFTEENTH COUNT

WITH OTHER PERSONS, ON OR ABOUT JUNE 04, 2015 IN THE COUNTY OF QUEENS

DOLLARS.
ONE HUNDRED AND SIXTEENTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, SAUL SALAMA AND SALLY MEDINA-CABELLO
OTHER PERSONS, ON OR ABOUT JUNE 28, 2015 IN THE COUNTY OF QUEENS AND
THOUSAND DOLLARS.
ONE HUNDRED AND SEVENTEENTH COUNT

OF MONEY LAUNDERING IN THE THIRD DEGREE COMMITTED AS FOLLOWS:
OTHER PERSONS, ON OR ABOUT JUNE 29, 2015 IN THE COUNTY OF QUEENS AND
ELSEWHERE, KNOWING THAT THE PROPERTY INVOLVED IN ONE OR MORE FINANCIAL
TRANSACTIONS REPRESENTED THE PROCEEDS OF CRIMINAL CONDUCT, CONDUCTED ONE
OR MORE SUCH FINANCIAL TRANSACTIONS, AS FOLLOWS: THE EXCHANGE OF ILLEGAL
FINANCIAL TRANSACTION OR TRANSACTIONS EXCEEDED FIFTY THOUSAND DOLLARS.
ONE HUNDRED AND EIGHTEENTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI AND CLARK W BRUNER OF MONEY
WITH OTHER PERSONS, ON OR ABOUT JUNE 30, 2015 IN THE COUNTY OF QUEENS

DOLLARS.
ONE HUNDRED AND NINETEENTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, RICHARD VANDERWYK, DAVID CHANG AND
CLARK W BRUNER OF MONEY LAUNDERING IN THE FOURTH DEGREE COMMITTED AS
FOLLOWS:
OTHER PERSONS, ON OR ABOUT JULY 01, 2015 IN THE COUNTY OF QUEENS AND

ONE HUNDRED AND TWENTIETH COUNT

THOUSAND DOLLARS.
ONE HUNDRED AND TWENTY FIRST COUNT

THOUSAND DOLLARS.
ONE HUNDRED AND TWENTY SECOND COUNT

WITH OTHER PERSONS, ON OR ABOUT JULY 16, 2015 IN THE COUNTY OF QUEENS

DOLLARS.
ONE HUNDRED AND TWENTY THIRD COUNT

THOUSAND DOLLARS.
ONE HUNDRED AND TWENTY FOURTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, DAVID CHANG AND CLARK W BRUNER OF
MONEY LAUNDERING IN THE THIRD DEGREE COMMITTED AS FOLLOWS:
OTHER PERSONS, ON OR ABOUT AUGUST 05, 2015 IN THE COUNTY OF QUEENS AND
ELSEWHERE, KNOWING THAT THE PROPERTY INVOLVED IN ONE OR MORE FINANCIAL
TRANSACTIONS REPRESENTED THE PROCEEDS OF CRIMINAL CONDUCT, CONDUCTED ONE
OR MORE SUCH FINANCIAL TRANSACTIONS, AS FOLLOWS: THE EXCHANGE OF ILLEGAL
FINANCIAL TRANSACTION OR TRANSACTIONS EXCEEDED FIFTY THOUSAND DOLLARS.
ONE HUNDRED AND TWENTY FIFTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI AND JEFFREY METELITZ OF MONEY
WITH OTHER PERSONS, ON OR ABOUT AUGUST 11, 2015 IN THE COUNTY OF
TRANSPORTED,

ONE HUNDRED AND TWENTY SIXTH COUNT

ACCUSES THE DEFENDANTS CYRUS IRANI, SAUL SALAMA AND SALLY
MEDINA-CABELLO OF PROMOTING GAMBLING IN THE FIRST DEGREE COMMITTED AS
FOLLOWS:
THE DEFENDANTS, EACH AIDING THE OTHERS AND ACTING IN CONCERT
WITH OTHER PERSONS, ON OR ABOUT SEPTEMBER 07, 2015 IN THE COUNTY OF
QUEENS AND ELSEWHERE, KNOWINGLY ADVANCED OR PROFITED FROM UNLAWFUL
GAMBLING ACTIVITY BY ENGAGING IN BOOKMAKING TO THE EXTENT THAT THEY
RECEIVED OR ACCEPTED IN ANY ONE DAY MORE THAN FIVE BETS TOTALING MORE
THAN FIVE THOUSAND DOLLARS.
RICHARD A. BROWN
DISTRICT ATTORNEY

Queens DA: Internet Gambling Press Release &amp; Indictment

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Queens DA: Internet Gambling Press Release &amp; Indictment

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Release # 168-2015

125-01 QUEENS BOULEVARD

FOR IMMEDIATE RELEASE

CONTACT: QDA (718-286-6315)

SEVENTEEN INDIVIDUALS IN NEW YORK AND TWO WESTERN STATES INDICTED

ENTERPRISE CORRUPTION (1)

PL 470.15-1B-IA MONEY LAUNDERING IN THE

CONSPIRACY IN THE FIFTH

PROMOTING GAMBLING IN THE

PL 470.10-1B-IA MONEY LAUNDERING IN THE

CONSPIRACY IN THE FIFTH

MONEY LAUNDERING IN THE

MONEY LAUNDERING IN THE

MONEY LAUNDERING IN THE

MONEY LAUNDERING IN THE

PROMOTING GAMBLING IN THE

PROMOTING GAMBLING IN THE

PL 470.10-1B-IA MONEY LAUNDERING IN THE

PL 470.05-1A-IIAMONEY LAUNDERING IN THE

PROMOTING GAMBLING IN THE

MONEY LAUNDERING IN THE

PROMOTING GAMBLING IN THE

PROMOTING GAMBLING IN THE

MONEY LAUNDERING IN THE

CONSPIRACY IN THE FOURTH

PL 470.15-1B-IA MONEY LAUNDERING IN THE

PROMOTING GAMBLING IN THE

PROMOTING GAMBLING IN THE

MONEY LAUNDERING IN THE

PROMOTING GAMBLING IN THE

PROMOTING GAMBLING IN THE

PROMOTING GAMBLING IN THE

PL 470.15-1B-IA MONEY LAUNDERING IN THE

PROMOTING GAMBLING IN THE

PROMOTING GAMBLING IN THE

PROMOTING GAMBLING IN THE

PROMOTING GAMBLING IN THE

MONEY LAUNDERING IN THE

PROMOTING GAMBLING IN THE

FIRST DEGREE (80)

PROMOTING GAMBLING IN THE

PROMOTING GAMBLING IN THE

PROMOTING GAMBLING IN THE

PROMOTING GAMBLING IN THE

PROMOTING GAMBLING IN THE

PROMOTING GAMBLING IN THE

MONEY LAUNDERING IN THE

MONEY LAUNDERING IN THE

MONEY LAUNDERING IN THE

PROMOTING GAMBLING IN THE

PL 470.10-1B-IA MONEY LAUNDERING IN THE

MONEY LAUNDERING IN THE

MONEY LAUNDERING IN THE

PL 470.10-1B-IA MONEY LAUNDERING IN THE

W. BRUNER, CLARK O. BRUNER, CHRISTOPHER BRUNER,

ALONG WITH OTHER PERSONS KNOWN AND

UNKNOWN, WERE MEMBERS OF AN ENTERPRISE WHICH SHARED

DEFENDANTS WERE MEMBERS AND ASSOCIATES OF AN

THE COMMON PURPOSE OF THE MEMBERS AND ASSOCIATES OF

CONDUCT AND TO ACQUIRE MONEY ILLEGALLY THROUGH THE

THIS GAMBLING ENTERPRISE CONSISTED OF THE

FOLLOWING INDIVIDUALS WHO COORDINATED TOGETHER IN

SALLY MEDINA-CABELLO WAS THE RECORD KEEPER,

ACCOUNT MANAGER, AND MAINTAINED THE WEBSITE FOR THE

THIS GAMBLING ENTERPRISE CONDUCTED THIS GAMBLING

RELEVANT TO THIS INDICTMENT LARGE SUMS OF CASH WERE

AND ADVANCE THE AFFAIRS OF THE CRIMINAL ENTERPRISE,

Queens DA: Internet Gambling Press Release & Indictment

Queens DA: Internet Gambling Press Release & Indictment