SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS THE PEOPLE OF THE YORK -against- LUIS SOTO, ABRAHAM MERTZ, A/K/A AVI MERTZ, PEOPLE’S STATEMENT OF BARRY RICE, JR., A/K/A BARRY CORBETT, | FACTS STANLEY HALL, STEVEN CRAWFORD, Indictment No. 516/2015 JOEL RUBIN, i SHEA SIGAL, ARON STUHL, and FRANK CAMPASANO, Defendants. INTRODUCTION 1. Taman Assistant District Attorney in the New York County District Attorney's Office. I have been cross designated as a Special Assistant District Attomey in the Kings County District Attorney's Office for the purpose of the above-captioned matter. 2. The People respectfully submit this letter to assist the Court in making appropriate bail determinations for the nine defendants charged in the above-captioned indictment, who are expected to appear before the Court for arraignment on February 10, 2015 and February 11, 2015. ‘This submission summarizes the evidence with regard to defendants Barry Rice, Jr., a/k/a Barry Corbett (“RICE ), Luis Soto (“SOTO”), Stanley Hall HALL”), and Steven Crawford (“CRAWFORD”), all of whom are city employees working, for the New York Cit Department of Housing Preservation and Development (“HPD”).‘The remaining defendants, Shea Sigal (“SIGAL”), Joel Rubin (“RUBIN”), Aron Stuhl (STUHL”), Abraham Mertz, a/k/a Avi Mertz (“MERTZ”), and Frank Campasano (‘CAMPASANO”), are the property owners and managers who bribed these City employces. 3. As desctibed below, cell phones used by RICE and SOTO were the targets of court-authorized eavesdropping.t BACKGROUND OF HPD 4. HPD isa New York City agency with city-wide jurisdiction. Included in HPD’s mission is ensuring the preservation of affordable, high-quality, and safe housing in the City’s five boroughs through the enforcement of the New York City Housing Maintenance Code (“Housing Code”), which sets forth the City’s housing quality standards. To that end, HPD’s Division of Code Finforcement employs housing inspectors, such as RICE, SOTO, and CRAWFORD, for the purpose of inspecting certain residential buildings in the city 10 determine if violations of the Housing Code have occurred. ‘The residential properties cacompassed within HPD’s jurisdiction include multiple family dwellings comprised of three or mote residential units or private dwellings which have been rented to tenants and in which neither the owner nor the owner's immediate family resides. 5. HPD’s Housing Inspectors are frequently summoned to a particular apartment building or residence after a tenant has called 311 to lodge a complaint or complaints about his living conditions. Such complaints can run the gamut of the Housing Code, including, but * Vatious Associate Justices of the New York State Supreme Cour, Appellate Division, Second Department, supervised this wiretap investigation into RICE, SOTO, and others.not limited to, a lack of heat or hot water, pests such as mice and roaches, water leaks, mold, and/or peeling paint. 6 After receiving a tenant’s complaint, HPD sends a Housing Inspector t0 examine the complaint and verify whether one or more violations of the Housing Code, in fact, exist. If so, the Housing Inspector issues the appropriate violation(s). As is relevant to this Indictment, after Housing Code violations are issued, the onus shifts to the building owner to resolve the violations at issue (Le., by fixing the heat, calling an exterminator or plumber, and painting, as necessary). ‘The building owner can then request a “re-i ;pection” of the issued violations by filling out paperwork and paying a fee to HPD. This prompts HPD to send a Housing Inspector back to the property to re-inspect the violations issued by the original Inspector, to determine whether the owner properly complied with, or fixed, the violations. HPD is legally required to conduct a requested re-inspection within 45 days during ‘warmer months and within 90 days during colder months. 7. fan Inspector conducting a re-inspection determines that a violation has been fixed, or complied with, then the violation is effectively dismissed after a supervisor approves the Inspector's finding. Alternatively, if an Inspector conducting a re-inspection determines that a violation has not been fixed, then the violation remains in effect, requiting the building owner to request another re-inspection after again attempting to fix the violation. Information conceming the type and number of violations issued and findings by Housing Inspectors and their supervisors is maintained in an internal HPD computer system known as the Borough Office Support System (“BOSS”).8. Asdesctibed in more detail below, one bribery scheme alleged in the Indictment concerns RICE’s dismissal of violations during a re-inspection of a building in which RUBIN had an interest in exchange for a bribe, as well as RICE and CRAWFORD’s agreement to dismiss violations at another of RUBIN’s buildings in exchange for a separate bribe. RICE also performed an advance inspection of one of STUHL?s properties in exchange for a bribe, with the intention of conducting a later, “official,” re-inspection of the property during which RICE would dismiss all HPD violations issued upon it. Finally, RICE, acting together with HALL, agreed to dismiss violations at a property in which SIGAL had an interest and to advise SIGAL concerning fines imposed on that property in exchange for a bribe. 9. In addition to issuing violations, HPD also has the authority to issue vacate orders if a given residential building is deemed uninhabitable. Vacate orders are issued far more rarely than violations and ordinarily cannot be issued without multiple layers of internal approval. Upon issuing a valid vacate order, HPD gives the tenants in the affected building notice of the order; the tenants then have approximately 72 hours to leave the premises. HPD also provides support services to assist the tenants in finding new housing. If the condition(s) that led to the vacate order are fixed, the tenants can return to the building. As described below, one bribery scheme alleged in the Indictment concems fake HPD vacate orders. Specifically, in exchange for bribes from MERTZ and CAMPASANO, RICE, acting together with SOTO, told tenants of ewo different buildings to leave their homes under the guise of the enforcement of a valid vacate otdet, when none actually existed.‘THE RICE/RUBIN/CRAWFORD SCHEME 10. RUBIN is one of the property managers who bribed RIC to dismiss HPD violations on one property and bribed RICE, acting together with CRAWFORD, when they agreed to dismiss violations from two other properties. Based on this conduct, the Grand Jury voted the following charges: two counts of Bribery in the Third Degree (P-L. § 200.00) (RUBIN); one count of Bribe Receiving in the Third Degree (P.L. § 200.10) (RICE only); and one count of Bribe Receiving in the Third Degtee (P-L. § 200.10) (RICE and CRAWFORD, acting in concert), 11. Between September 4, 2014 and October 20, 2014, RUBIN paid over $300 in bribes to RICE to have RICE dismiss HPD violations at 1406 Putnam Avenue in the Bushwick neighborhood of Brooklyn. Wiretapped calls show that RICE and RUBIN conspired to schedule the re-inspection at 1406 Putnam Avenue on a date and at a time when RICE was working and, therefore, would be available to conduct the re-inspection, 12, ‘Thereafter, and in exchange for the bribe from RUBIN, RICE visited 1406 Putnam Avenue in advance of the scheduled re-inspection, and, using his training and experience as an HPD Housing Inspector, advised RUBIN as to whether the violations had been properly fixed or required additional work, which RICE determined they did. Intercepted communications between RICE. and RUBIN demonstrated that RICE then coordinated with RUBIN’s repairman to ensure that the violations had been complied with, meaning that RICE could dismiss the violations at the later, official re-inspection without fear that his bribery scheme would be revealed. In a wiretapped call on September 19, 2014, RICE explained to RUBIN that he would wear his official HPD uniform when he accompaniedRUBIN’s repairman to the building and that he expected a bribe payment to do so. Specifically, RICE stated, “Listen, um, when I do something of this nature right, and T have to put this monkey suit on, there’s a number that’s attached to that.” He continued, “{[]£1 go there with, with your repairman you know and dress that up, my numbers have to be taken care of, because I’m taking a chance and tisk and uh T know what I’m doing but um, we just have to be careful.” RUBIN replied, “I know that.” (RICE CELL PHONE, Conversation 4377) RICE continued on this theme in another wiretapped call on September 23, 2014, stating with zegard to meeting RUBIN’s repairman, “I have to come in the suit, you know that.” RUBIN replied, “ What do you mean, in the suit?” RICE answered, “What do I wear every day? Ihave to come there that way, that’s the only way I'm gonna gain access.” (RICE CELL PHONE, Conversation 4912) 13. Indeed, in a later call, RICE made clear to RUBIN that he expected to be paid for each and every action he took in furtherance of their bribery scheme. In a wiretapped call on September 28, 2014, RICE explained to RUBIN, “[W]hatever task I do, I expect to get paid then and there.” RUBIN replied, “It’s fine, as long, as long, all the violations gonna be down, that’s fine.” (RICE CELL PHONE, Conversation 5553) 14. BOSS records show that, on October 3, 2014, RICE, along with his HPD partner, conducted the re-inspection at 1406 Putnam Avenue. RICE dismissed all 20 HPD violations that had been issued at the building ‘The types of violations dismissed included, but were not limited to: Fwo of the violations involved lead paint, and RICE marked those violations as being in “defect letter” status rather than, as “complied with.” According to HPD procedure, lead paint violations cannot be deemed as having been fixed, or “complied with,” by a Housing Inspector such as RICE. Rather, ifn inspector believes based upon his inspection that 2 6+ Exposed electric witing in the cellar of the building; + The presence of mice in an apartment in the building; and + A.water leak in the ceiling of a bathroom ia an apartment. 15. Following the dismissal of the violations, RICE and RUBIN had several text message exchanges during which RUBIN expressed that RICE had done a “good job.” (RICE CELL PHONE, Conversation 6645.) When RUBIN then delayed in paying RICE his bribe, RICE expressed frustration, writing in a text message, “U should have told me it would b a week later after task is done ....” (RICE CELL PHONE, Conversation 7434) Wiretapped communications show that RICE and RUBIN met on October 20, 2014, presumably so that RUBIN could pay RICE the agreed bribe. RUBIN left RICE waiting, which caused RICE to send a text message to RUBIN, stating that he was “risking [his] job” by waiting for RUBIN while on duty working for HPD. (RICE CELL PHONE, Conversation 7934) 16. _Bribery-related conversations between RICE and RUBIN continued and also involved CRAWFORD, another HPD Inspector based in Brooklyn. Between November 12, 2014 and December 17, 2014, RICE, CRAWFORD, and RUBIN agreed that RUBIN would pay RICE and CRAWFORD for their advice concerning the dismissal of violations at two properties and the ultimate dismissal of those violations. The addresses of the properties were 1317 Union Street and 666 Park Place, both in the Crown Heights neighborhood of Brooklyn. 17. In November and December 2014, RICE had a series of conversations with RUBIN, as well as with RUBIN’s employee, a person known only by the first name “Jay.” lead paint violation has been fixed, he masks those violations as being in “defect lets” status, meaning thatthe violation haas been fixed but that additional paperwork concerning lead testing is needed before the violation can be fully dismissed 7‘These conversations made clear that RUBIN and Jay tried, but failed, to schedule re- inspections at 1317 Union Street and 666 Park Place during a date and time when RICE was available to personally conduct the re-inspections. As a result, RICE spoke to CRAWFORD about assisting him with re-inspections. RICE and CRAWFORD agreed that they would “split this money down the middle.” (RICE CELL PHONE, Conversation 13644.) RICE then conveyed to Jay that his “friend” who works in the “daytime” could handle the re- inspections at the two properties and further assured Jay that there would be “no problems, same situation, no extra money, same money.” (RICE CELL PHONE, Conversation 13718) 18. Ina later conversation on December 9, 2014, Jay informed RICE that he had scheduled the re-inspection for 1317 Union Street for two days later, December 11, 2014. He scheduled the re-inspection for 666 Park Place for December 29, 2014. RICE called RUBIN, complaining that Jay had not given him enough advance notice for the re-inspection at 1317 Union Street, stating, “I gotta check this stuff and make sure this shit is done tight, Joel. I have to, man, We gotta be careful with this thing” (RICE CELL PHONE, Conversation 14033.) In essence, RICE told RUBIN that he had to view the violations at 1317 Union Street in advance of the scheduled se-inspection to ensure that the violations could be dismissed without drawing too much attention from his supervisors or others at HPD. RUBIN refused to allow RICE to inspect the violations in advance, stating in substance that it was too hard to coordinate. 19. Ultimately, neither RICE nor CRAWFORD performed the re-inspection at 1317 Union Street or 666 Park Place, no doubt because they deemed the tisk of dismissing violations at these properties without having the opportunity of an advance inspection 100tisky to be worthwhile. ‘The evidence nevertheless meets the elements of bribery and bribe receiving because RUBIN agreed to pay RICE and CRAWFORD jin exchange for the inspectors’ advice and actions concerning violations at 1317 Union Street and 666 Park Place. Nothing more is required. ‘THE RICE/STUHL SCHEME 20. Aron Stuhl, a/k/a Ari Stuhl (“STUHIL”) is one of the property managers who agreed to pay RICE to dismiss violations on one of STUHL!s properties, 1122 Willoughby “Avenue in the Bushwick neighborhood of Brooklyn. Based on this conduct, the Grand Jury voted the following charges: one count of Bribery in the Third Degree (P-L. § 200.00) (STUHL); and one count of Bribe Receiving in the Thied Degree (P.L. § 200.10) (RICE). 21. RICE and STUHL’s conversations concerning 1122 Willoughby Avenue took place between October 21, 2014 and January 6, 2015. An examination of just a few of these phone calls demonstrates the explicit bribery-related nature of the conversations. For ‘example, January 5, 2015, STUHL asked, “I wanna take off all violation, what could we do?” RICE responded that he could meet STUHL at STUHL’s building the following day and instructed STUHL that his “charge is $300.” For that price, RICE would “look over everything and, um, tell you, uh, what needs to be done” (RICE CELL PHONE, Conversation 17940.) The next day, January 6, 2015, at approximately 9:44 a.m., RICE and STUHL discussed meeting at 1122 Willoughby Avenue, presumably so that RICE could perform an advance inspection of the property as discussed. (RICE CELL PHONE, Conversation 18113.) At approximately 12:32 p.m., RICE called STUHL, asking STUHL to “come out now” because RICE could not stay “outside in (his) uniform” waiting. (RICECELL PHON' Conversation 18154.) In addition to their blatant bribery-related conversations, the fact that RICE wanted to avoid being seen in his HPD uniform when meeting with STUHL is another piece of evidence demonstrating both his knowledge and his intent that he was participating in a bribery scheme. Later that day, RICE and STUHL spoke again. STUHL asked when he should schedule the re-inspection, and RICE told him to do so in the afternoon, when RICE works, which would allow RICE to dismiss the HPD violations at 1122 Willoughby Avenue. (RICE CELL PHONE, Conversation 18211.) THE RICE/HALL/SIGAL SCHE} 22. Shea Sigal (“SIGAL”) is one of the property managers that bribed RICE in exchange for RICE’s agreement and assistance, along with that of HALL, an Associate Housing Inspector with supervisory authority, to dismiss violations from 32 Kossuth Place in the Bushwick neighborhood of Brooklyn. Based on this conduct, the Grand Jury voted the following charges: one count of Bribery in the Third Degree (P.L. § 200.00) SIGAL); and one count of Bribe Receiving in the Thisd Degree (P-L. § 200.10) (RICE, acting in concert with HALL). 23. The scheme involving RICE, HALL, and SIGAL took place between December 1, 2014 and December 15, 2014. In a wiretapped phone call between RICE and HALL on December 1, 2014, RICE told HALL that he (RICE) had “somethin’ brand new” involving 32 Ke ssuth Place. (RICE CELL PHONE, Conversation 12544.) RICE continued to describe a situation where a certain individual, later identified as SIGAL, had taken ownership of an “emp vacant lot” where a building had been “torn down.” SIGAL’s problem was that the property had incurred “$270,000 worth of fines” as well as “violations,” 10and SIG. L needed assistance in clearing them, HALL advised that he would obtain a copy of the building’s demolition order with the intention of having “the violations all dismissed based on the demo order.” RICE promised that HALL would be paid for his conduct, stating that he would “get something from them, and I'ma break you off, homie.” In a subsequent conversation on December 2, 2014, HALL advised RICE that SIGAL would have to appear before the New York City Environmental Control Board (“ECB”) to have the fines on the property reduced. (RICE CELL PHONE, Conversation 12667.) 24. Later on December 2, 2014, RICE called SIGAL and discussed the payment of bribes from SIGAL in exchange for action and advice from RICE and HALL. RICE explained that he wanted to meet with SIGAL to give him “paperwork” related to 32 Kossuth Place. He instructed SIGAL to bring “five” with “nwo zeros,” ic., $500, to the meeting so that the “people in front of the computer,” ie. HALL, could be paid. (RICE CELL PHONE, Conversation 12717.) In text messages sent on December 4, 2014, RICE made clear that SIGAL should bring “500 4 computer folks n 100 4 me,” for a total of $600 in bribe money. (RICE CELL PHONE, Conversations 13097, 13098) 25. RICEand SIGAL met on Monday, December 8, 2014, no doubt so that SIGAL, could give RICE the bribe payment in exchange for the promised paperwork and advice. A DOT surveillance team covered this meeting and observed RICE and SIGAL in a coffee shop discussing paperwork. SIGAL was then observed entering a nearby deli. Surveillance footage showed SIGAL using the ATM machine, after which time he rejoined RICE. After meeting with SIGAL, RICE called HALL stating, “Got you.” (RICE CELL PHONE, Conversation u13708) RICE arranged to meet HALL the following day, presumably to pay HALL for his part in this scheme. 26. RICE, HALL, and SIGAL continued to have bribery-related conversation. On. December 14, 2014, RICE spoke to SIGAL concerning a meeting the following day to provide SIGAL with additional paperwork and to further discuss the removal of violations and fines at 32 Kossuth Place. RICE instructed SIGAL, “[NJow tomorrow moming you have the balance of 3,000 for me.” SIGAL replied, “Okay.” (RICE CELL PHONE, Conversation 14745.) On the next day, December 15, 2014, RICE met with HALL concerning the paperwork at issue. SIGAL then sent a text message to RICE, stating, “I will meet u at 930 with the money,” making it explicit that their meeting was bribery-related. RICE then spoke with HALL, assuring HALL that he was atranging to meet SIGAL “to grab that bread,” referring to the $3,000 bribe payment. (RICE CELL PHONE, Conversation 14907.) RICE also instructed HALL that RICE would put HALL on the phone with SIGAL so that HALL could directly advise SIGAL concerning violations and fines on 32 Kossuth Place. 27. RICE and SIGAL did, in fact, mect later on December 14%, and, during that meeting, RICE put HALL on the phone with SIGAL. With respect to any HPD violations issued on 32 Kossuth Place, HALL assured SIGAL, “HPD is gone already, you have zero HPD violations.” He added that with respect to the fines pending before ECB, that HALL, acting together with RICE, would assist SIGAL in finding an expeditor who would resolve the outstanding fines. After his meeting with SIGAL, RICE called HALL, stating, “[I]he ‘eagle has landed,” suggesting that he had been paid $3,000 by SIGAL. (RICE CELL PHONE, Conversation 14975.) RICE and HALL arranged to meet. ‘Thereafter, SIGAL called RICE, 12inquiring again about HPD violations on 32 Kossuth Place. RICE responded that no HPD violations existed for the address because “we just got rid of them,” confirming the purpose of SIGAL’s bribe payments to RICE and HALL. THE RICE, yYTO/MERT: (HEME 28. In addition to dismissing HPD violations, the wiretap evidence uncovered a separate scheme in which RICE and others accepted bribes to force, or attempt to force, tenants of certain buildings to leave the buildings under the supposed authority of an HPD vacate order, which, in reality, did not exist. For example, between July 30, 2014 and July 31, 2014, RICE, working together with SOTO, another HPD inspector, ordered certain tenants of 1249 Jefferson Avenue in the Bushwick neighborhood of Brooklyn to leave their homes. “They did so for no valid purpose and only in exchange for a bribe from MERTZ, a property owner. Based on this conduct, the Grand Juty voted the following charges: one count of Bribery in the Third Degree (P.L. § 200.00) (MERTZ); and one count of Bribe Receiving in the Third Degree (P.L. § 200.10) (RICE and SOTO, acting in concert) 29. On July 30, 2014, MERTZ spoke with SOTO and, referring to “Jefferson,” stated that a tenant did not “wanna go out” (SECOND SOTO CELL PHONE, Conversation 6540.) MERTZ, asked, “What is the option?” SOTO replied, “I’m gonna send my ftiend over there. I’m gona send RICE over there.” Later that day, MERTZ and SOTO A New York County Grand Jury separately charged SOTO with the following crimes: one count of Bribe Receiving in the Second Degiee (PL. § 200.03); 10 counts of Bribe Receiving in the Third Degree (P.L. § 200.10); 25 counts of ‘Tampering with Public Records in the Fiest Degree (PL. § 175.25); and 23 counts of Falsifying Business Records in the First Degree (PLL. § 175.10). The New York County Grand Jury also charged MERTZ with the following crimes: one count of Bribery in the Second Degree (PL. § 200.03); three counts of Bribery in the Third Degree (PLL. § 200.00); 13, counts of Tampering with Public Records in the First Degree (PL. § 175.25); and 13 counts of Falsifying Business Records inthe First Degree (PL. § 175.10) 13spoke again. MERTZ made clear that the address of the property at issue was “1249 Jefferson Avenue.” Referring to RICE, SOTO stated, “[The guy that I wanna send over, we have to pay him.” MERTZ asked, “But it’s gonna be a real vacate?” SOTO responded, “No.” (SECOND SOTO CELL PHONE, Conversation 6593.) 30. SOTO and RIC als spoke on July 30, 2014. RICE stated, “1279, all taken care of.” After SOTO made clear that the correct address was 1249 Jefferson Avenue, RICE said, “I talked to the wrong fucking people then.” He added, “got to go back, Now I got to go to 1249.” (SECOND SOTO CELL PHONE, Conversation 6687.) A surveillance team then observed RICE meeting with MERTZ in the vicinity of 1249 Jefferson Avenue. ‘Thereafter, RICE called SOTO, stating, “[IJhe deed is done. Talked to the police, told them that the property had been, um, vacated by HPD, no one is supposed to be in here, they're trespassing ....”. Despite RICE’s representations to the tenants of 1249 Jefferson Avenue, HPD’s records show that no valid vacate order existed for 1249 Jefferson Avenue at any point in 2014. RICE and SOTO then discussed meeting, no doubt so that SOTO could pay RICE the bribe he had earned by telling tenants of 1249 Jefferson Avenue to vacate their homes. THE RI yT :ANO SCHEME 31. ‘The wiretaps, coupled with phone records, uncovered a similar scheme involving the bascless removal of tenants from a building by RICE, SOTO, and CAMPASANO, the owner of the building, located at 159 Suydam Street in the Bushwick neighborhood of Brooklyn. Based on this conduct, the Grand Jury voted the following charges: one count of Bribery in the Third Degtee (P.L. § 200.00) (CAMPASANO); and one 14count of Bribe Receiving in the Third Degree (P-L. § 200.10) (RICE and SOTO, acting in concert) 32. Between October 20, 2014 and December 17, 2014, CAMPASANO, Bl and SOTO had numerous phone contacts and communications concerning the removal of tenants from the apartment building at 159 Suydam Street based on a supposedly valid vacate order for the building that did not actually exist. On October 20, 2014, CAMPASANO stated to SOTO during an intercepted call, “I wanna get that fucking guy out Luis.” (GECOND SOTO CELL PHONE, Conversation 12476.) On October 25, 2014, SOTO sent a text message to CAMPASANO teading, “I talked to the [sic] my boy he said he’s going to be there this week. .His name is RICE.” (SECOND SOTO CELL PHONE, Conversation 12667.) 33. On December 10, 2014, SOTO spoke to RICE, explaining that SOTO’s “friend” had “a vacate for two rooms. And they told him to vacate, but the tenants don’t wanna leave.” RICE responded, “Can you tell them next week I could get by there?” (RICE CELL PHONE, Conversation 14138.) SOTO and RICE spoke again on December 14, 2014, SOTO made clear that the building at issue was located at 159 Suydam Street. HPD’s records, however, show that no vacate order existed for 159 Suydam Street at any point in 2014. During this same conversation, RICE stated, “I need five on that.” SOTO asked, “Five hundred?” He then s id, “That’s what I’m giving you.” SOTO later continued, “I charged him $700. Two for me, five for you, okay?” (RICE CELL PHONE, Conversation 14746.) 34. On December 15, 2014, SOTO sent a text message to RICE, reading, “Yo he is there when ever you are ready. .call me when u done ...u can yell at the landlord make it look good.” (RICE ZLL PHONE, Conversation 14997.) Importantly, HPD records show 15that the “landlord,” or owner, of the building at 159 Suydam Street is CAMPASANO. In. response to SOTO’s text message, RICE responded, “On my way now got U.” (RICE CELL, PHONE, Conversation 14999.) 35. Later on December 15, RICE and SOTO spoke concerning 159 Suydam Street. RICE said, “Yeah, all done... Every apartment, I screamed on the mother fuckers... “You gotta be out in seventy-two hours, you not out, the marshal is coming, he’s coming with NYPD, your furniture will be outside, and you will be handcuffed and escorted off the premises.”” SOTO stated, “Good deal,” and asked, “[Y]ou need money today,” confirming that SOTO and RICE were being paid for their part in forcing tenants of 159 Suydam Street to leave the building under the guise of an HPD vacate order. 36. In addition to the October 20, 2015 conversation in which CAMPASANO. stated to SOTO, “I wanna get that fucking guy out Luis,” and the fact that CAMPASANO is the owner of 159 Suydam Street, phone records further evidence CAMPASANO’s role in bribing SOTO, who acted together with RICE, to kick tenants out of 159 Suydam Street. For example, on December 10, 2014, after SOTO told RICE about a “friend” that wanted to “vacate” certain tenants from his building, SOTO’s next call was to CAMPASANO. On. December 14, 2014, after SOTO told RICE that SOTO was charging a third person $700 which would be split between SOTO and RICE for kicking tenants out of 159 Suydam Street, SOTO again called CAMPASANO. On December 15, 2014, after SOTO sent a text message to RICE stating that a third person “is there” and that RICE could “yell at the landlord” to “make it look good,” and RICE responded that he was “on [his] way” to the building, CAMPASANO called SOTO. Indeed, in the five-day period between December 10, 2014 16and December 15, 2014, phone records demonstrate that SOTO and CAMPASANO were in contact at least 14 times. In between those contacts, SOTO communicated with RICE about removing tenants from CAMPASANO’’s building in exchange for a payment. CONCLUSION 37. ‘The HPD inspectors in this case betrayed their duty to the City and the City’s residents in exchange for bribes. ‘The remaining defendants disregarded the safety and comfort of their tenants by bribing city inspectors to bypass HPD’s established system for inspections and removing violations, and to vacate certain tenants from their homes without the proper authority to do so. The wiretap, documentary, and testimonial evidence in this case is strong, and the People are confident that the defendants’ guilt will be proven beyond a reasonable doubt. Dated: February 10, 2015 New York, New York Respectfully Submitted, Kenneth P. ‘Thompson District Attorney, Kings County Special Assistant District Attorney cc All Counsel 7