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Case 1:19-cr-00147-LDH Document 1 Filed 12/17/18 Page 1 of 16 PageID #: 29

MKM:AS/MJJ
F.# 2018002164

UNITED STATES DISTRICT COURT


EASTERN DISTRICT OF NEW YORK
X

UNITED STATES OF AMERICA COMPLAINT

-against- (18U.S.C. § 1951(a))

DOUGLAS SINGER and 18-M-1223


MARIANNE WOOD,

Defendants.

EASTERN DISTRICT OF NEW YORK,SS:

Neill Fagan, being duly sworn, deposes and states that he is a Special Agent

with the Federal Bureau ofInvestigation, duly appointed according to law and acting as such.

On or about and between November 2,2018 and November 16, 2018, both

dates being approximate and inclusive, within the Eastern District ofNew York and

elsewhere,the defendants DOUGLAS SINGER and MARIANNE WOOD,together with

others, did knowingly and intentionally conspire to obstruct, delay and affect commerce, and

the movement of articles and commodities in commerce, by extortion, in that SINGER,

WOOD and others conspired to obtain property, to wit: proceeds of a commercial business in

Brooklyn, New York, Jfrom an individual, with his consent, which consent was to be induced

by wrongful use ofthreatened force, violence and fear.

(Title 18, United States Code, Section 1951(a))


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The source of your deponent's information and the grounds for his belief are

as follows:'

1. I am a Special Agent with the Federal Bureau ofInvestigation (the

"FBI"), and have been since approximately 2016. I previously served as a police officer and

detective in Florida for approximately eight years. During the course of my career, I have

participated in investigations concerning organized crime and violent crime, among other

offenses. I have also participated in the execution ofsearch warrants.

2. As set forth below, there is probable cause to believe that DOUGLAS

SINGER and MARIANNE WOOD,together with Leroy Wilson, extorted a victim (the

"Victim").^ In interviews with the FBI,the Victim stated, in sum and substance and in part,

the following: In early 2018 the Victim sold a business, located in a Victim-owned building

in Coney Island Avenue in Brooklyn, New York (the "Restaurant"). The purchaser ofthis

business was SINGER,whom the Victim has,following that transaction, routinely called at a

telephone number ending in 6508 (the "SINGER Telephone").^ SINGER paid the Victim

'Because the purpose of this Complaint is to set forth only those facts necessary
to establish probable cause to arrest, I have not described all the relevant facts and circumstances
of which 1 am aware. For example,this Complaint refers to and quotes some, but not all,
recorded conversations. Such quotations are based on draft transcriptions, which are set forth in
part and in substance.

^ The Victim has not received any benefits from the FBI or the govemment. The
Victim has proven reliable throughout this investigation, including, as noted throughout the
Affidavit, by corroboration through independent sources of information the Victim has provided
to the FBI. According to a search of databases available to the FBI,the Victim has no
documented criminal history but has reported arrests, which have not led to convictions, are
sealed, and do not pertain to his credibility.

^ Subscriber information for the SINGER Telephone shows that the SINGER
Telephone is subscribed to SINGER in his name.
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$60,000 for the Restaurant and agreed to pay monthly rent to the Victim, who continued to

own the building/

3. To finalize the deal, on February 14,2018,a commercial lease

agreement(the "Lease") was executed between an entity controlled by the Victim, and an

entity controlled by SINGER. The Lease provided for the use ofthe retail space occupied

by the Restaurant, in return for $5,200 monthly rent payments to the entity controlled by the

Victim. In order to secure the Lease, SINGER paid the Victim a $15,600.00 security

deposit.

4. Later in February 2018, SINGER began to occupy and operate the

Restaurant, which he renamed. SINGER paid the Victim rent every month until the month

of October 2018.

5. On Friday, November 2,2018,the Victim received a text message from

the SINGER Telephone, which provided in relevant part:

I will have rent for you on Monday morning [November 5,


2018]. Is it possible for you to get together with me at 11:30
A.M. at the store on Monday to discuss a couple ofthings?

The Victim responded via text message, to the SINGER Telephone, and agreed to meet with

SINGER at the Restaurant.

^ The Victim provided me with the sales contract memorializing the sale ofthe
Restaurant to SINGER. Although the contract provides that it was signed on February 8, 2017,
the Victim informed me that the year is a typographical error, and that the sale occurred in 2018,
not 2017.
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6. On November 5,2018, at approximately 11:35 A.M.,the Victim sent a

text message to the SINGER Telephone informing SINGER that the Victim was at the

Restaurant. Shortly thereafter, the Victim observed SINGER arriving at the Restaurant in a

gray Ford Explorer(the "Ford Explorer"), which the Victim knew to be SINGER'S vehicle.^

In addition to SINGER,the Ford Explorer was occupied by a female,later identified as

WOOD,and a male, later identified as Leroy Wilson, both then unknown to the Victim.

After parking the Ford Explorer, and in front ofthe Restaurant, SINGER introduced WOOD,

by her first name,to the Victim as SINGER'S business partner. WOOD shook the Victim's

hand but Wilson did not. During the course ofthe ensuing conversation, the Victim heard

WOOD refer to Wilson as "Roy."

7. The four individuals then entered the Restaurant. Inside, Wilson

separated fi:om SINGER and the Victim, and WOOD began talking to the Victim. During

the course oftheir conversation, WOOD explained in substance and in part that: she was

SINGER'S business partner and she worked for an organization (hereafter "the

Organization") handling all ofSINGER's business relating to the Restaurant. WOOD told

the Victim that the Victim owed the Organization $198,000, which must be paid by the close

ofthe day; she explained the figure by adding the sale price ofthe Restaurant($60,000),to

the security deposit($15,600), and to costs for equipment,renovations, and losses

purportedly incurred by SINGER during his operation ofthe Restaurant.

^ I have reviewed records retrieved from New York State's Department of Motor
Vehicles and leamed that SINGER is the registrant of a 2018 gray Ford Explorer.
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8. During their conversation, WOOD produced a yellow envelope from

which she retrieved and displayed to the Victim photographs ofthe Victim and the Victim's

spouse and children. WOOD told the Victim, in sum and substance,that she knew the

Victim's family members' names,that it would be in the best interest ofthe Victim and the

Victim's family for the Victim to pay the $198,000, and that she knew how to handle people

like the Victim. The Victim responded, in sum and substance, that the Victim did not have

$198,000 immediately available. WOOD directed the Victim to arrange a payment to her

by 5:00 p.m. that same day.

9. According to the Victim, during their conversation, Wilson provided

WOOD a pen. As Wilson retrieved the pen from hisjacket pocket and leaned forward, the

Victim noticed a black pistol bolstered on Wilson's right hip.^

10. Also during the meeting, WOOD provided the Victim with her

telephone number, which ends in 9171 (the"WOOD Telephone"), as the telephone number

at which the Victim had to reach her that day. Information received from the service

provider indicates that the WOOD Telephone is prepaid, with no listed subscriber

information. Based on my training and experience I know that individuals who commit

crimes often use prepaid cellular telephones(commonly referred to as "burner phones")for

criminal activity, to avoid detection.

^ When interviewed by the FBI, SINGER denied that a firearm was used. He
added that when recruiting Wilson for the role of"muscle," Wilson told him he "did not want to
be part of anything illegal," and, according to SINGER,"if there is any true innocent, it's
certainly him [i.e.. Wilson]." SINGER further stated that he believed the Victim committed
"fraud" and that his intention was to convey to the Victim,"give me my money back or we're
going after you to the full extent ofthe law."
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11. Subscriber information for a different telephone number, which ends in

1303("WOOD Second Telephone"), shows it to be subscribed to WOOD in her name. Toll

records for the SESIGER Telephone show that the SINGER Telephone was in contact with

the WOOD Second Telephone on November 5, 2018 (the day ofthe meeting between the

Victim, SINGER, WOOD and Wilson). These records further show that the SINGER

Telephone was in contact with the WOOD Second Telephone approximately 30 times in the

months leading to the extortion(between April 24,2018 and November 1, 2018), and

approximately 63 times during part ofthe period ofthe extortion(November 2,2018 to

November 12, 2018).

12. According to the Victim, at the conclusion oftheir meeting, SINGER,

WOOD and Wilson drove away in the Ford Explorer.

13. Later on November 5, 2018,the Victim reported the threats to the New

York City Police Department, which subsequently alerted the FBI. After the FBI

interviewed the Victim, at the FBI's direction, the Victim called WOOD at the telephone

number she left and arranged for a meeting later the same day, November 5,2018, at a local

diner to discuss payment. During the call, which the FBI recorded, WOOD asked the

Victim,"Do you have my money?" The FBI provided the Victim with a recording device

and conducted surveillance ofthe meeting.

14. At the prearranged time for the meeting on the same day, FBI agents

conducting surveillance observed a Ford Explorer arrive at the diner and park. The driver of

the Ford Explorer, believed to be SINGER,remained inside the vehicle while two
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individuals, believed to be WOOD and Wilson,^ entered the diner. WOOD sat with the

Victim at a booth and Wilson—a large man, wearing all black, including a black leather

jacket^—^sat at the next booth and positioned himself so that he was looking in the direction

ofthe Victim during most ofthe Victim's meeting with WOOD. During the course of

WOOD'S and the Victim's conversation, which was recorded, WOOD explained that

SINGER did not actually own the Restaurant, that she and SINGER worked for the

Organization, and that the Organization required the Victim to buy back the Restaurant:

Victim: Why didn't he [SINGER], why didn't he put it up


for sale? He could sell it.

WOOD: It's not to him to put it up for sale. He doesn't


have that kind oftime.

Victim: He is in the real estate business. Why wouldn't he


have that kind oftime?

WOOD: Doug [SINGER]doesn't own that restaurant.

Victim: Oh. He told me he was the owner.

WOOD: That's what he was supposed to tell you. That's


his job. We both work for the same people.
The people who put money into that business.
The people who bought that business, and the
people who now want their money covered.

Victim: So why come to me? Why not sell it?

WOOD: Because they want what they want.

^ The individuals observed by the FBI near the Ford Explorer matched the
descriptions provided by the Victim. The Victim has informed the FBI that the two individuals
the Victim met at the diner were the same two individuals the Victim had been introduced to
earlier in the day by SINGER.

® New Jersey Department of Motor Vehicles records list Wilson as 6 feet, 1 inch
tall, and weighing over 220 pounds.
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15. Later in the same conversation, WOOD explained that SINGER and

WOOD work for an "organization," but that SINGER could not be forthcoming with the

Victim because, WOOD explained:

He[SINGER]is under contract not to say anything. He takes


our money. He opens a business and then he gives us some
money back. That's hisjob. He does it all over the world.
And he's done it for a long time. We have had this problem
once or twice before, and we've gotten our money. So,it's
really about, he has such a soft spot for you. That's the only
reason I'm really still here.

16. Later in the same conversation, WOOD insisted that the Victim sign a

document that purported to release SINGER from any liability associated with the

Restaurant:

WOOD: That's ok. You sign this paper.

Victim: I can't sign anything. I need to have my lawyer


look at it.

WOOD: You have no idea ~

Victim: What do I have no idea about? I want,I want to


do it.

WOOD: No,no. If you want to sign it, sign it now.

Victim: It says that "I,[Victim], releases Douglas Singer


of...[a restaurant company], from all
obligations and relationship to this lease and
establishment, currently known as Brooklyn
what do you mean? He's not surrendering any
lease to me. Why would I sign this?

WOOD: He is surrendering his lease to you.

Victim: No he's not. A surrender lease is a document,


and it says surrender lease on it, agreement on it,
and it has a number on it that I have to give him
back.
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WOOD: Ok. You're really thinking about what you're


doing here right?
***

WOOD: Let me just say this. Ok. If he[SINGER]did


not have such a soft spot for you,I would not
have come here at all.

Victim: I believe you.

WOOD: You know, my associate, and other associates,


would have come about you. And I don't want

Victim: Whatever they want to do they can do.

17. Later in the conversation, the Victim inquired about the safety of his family

and referenced the photographs that WOOD showed the Victim earlier in the day:

WOOD: Ok? As long as it's done at the end ofthe week,


you're done.

Victim: What about my photographs for me and my kids


and my [spouse] and everything else? You told
me about.

WOOD: Those things, I can't even tell you.

Victim: You can't tell me? I want insurance that nothing


will happen to them.

WOOD: As long as we are clear that this is finished by the


end ofthe week,it's a business agreement.

Victim: That's all it is.

WOOD: We have no reason to argue with you about


anything.

Victim: Alright.

WOOD: As long as you keep up your end ofthe bargain,


we keep up our end ofthe bargain. We're done.
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18. I have obtained a passport photograph of WOOD (associated with the

WOOD Second Telephone)that is on file with United States Customs and Border Protection.

A comparison ofthe photograph and surveillance footage from the diner where the

November 5 meeting occurred, as well as my observations ofthe female co-conspirator,

further confirm WOOD'S identity.

19. On November 8,2018,the Victim received a text message from the

WOOD Telephone, stating that:

I will not be speaking with anyone but you and at the end ofthe
day tomorrow I will have done everything I can and you will be
on your own. This is not a negotiation.

20. The next day, November 9,2018,the Victim met with SINGER at a

cafe in order to discuss the Victim's payment. During the Victim's and SINGER'S

conversation, which was recorded, the Victim inquired as to the safety ofthe Victim's

family, and the following exchanges occurred:

Victim: Alright. So, my question is: How is my family


protected? Cause these guys-

SINGER: They will. If we straighten this out. Whatever


you worked out with them. If we straighten this
out. I guarantee you. You will hear from them
one last time and they will say,"You're good."
You'll never hear from us again.
***

Victim: Am I in danger? Once you bring these people


in?

SINGER: Can I tell you that? I'll ask them what-one


thing - people I work with always stick by what
they say. They don't fuck around. They knew
what they say what they mean and so let me see.
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21. During the Victim's and SINGER's conversation on or about

November 9,2018,the Victim informed SINGER that the Victim did not have the payment

demanded by WOOD readily available. SINGER,at the Victim's request, agreed to contact

"them"—^which the Victim understood to mean co-conspirators—and attempt to get them to

"bend" as to the due date ofthe Victim's payment.

22. On or about November 12,2018,the Victim spoke vvith SINGER, who

called the Victim from the SINGER Telephone. During the conversation,the Victim asked,

"Is my family going to be in danger after I give you this money?" After SINGER stated that

he was not part ofthe conversation when the Victim's family was threatened by WOOD and

Wilson, SINGER stated,"I would not mess with them that way." Based on the context of

the conversation, I believe that by "them," SINGER meant WOOD and Wilson and/or other

members ofthe Organization. SINGER stated that he "felt really upset" about the threats

and about WOOD and Wilson's demand for "triple damages" from the Victim. Seconds

later, however,SINGER added that he did not care how he got paid: "I don't think it

matters. I think green is green as far as I'm concerned." The Victim continued asking for

assurance from SINGER with regard to the Victim's family, adding,in reference to WOOD

and Wilson,"You have more power on them than me. You're the guy that brought them in.

I mean, not me." SINGER responded,"Of course. Ofcourse." SINGER and the Victim

arranged to meet on November 16,2018 for the Victim to pay $75,000 and to release

SINGER from the Lease ofthe Restaurant.

23. At this November 16,2018 meeting, while FBI agents were conducting

surveillance, the Victim gave SINGER cash, which the Victim stated was $75,000(but was,

in reality,$10,000). After SINGER accepted the money,the Victim left the Restaurant.
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24. On November 16,2018,the FBI lawfully obtained the SINGER

Telephone and SINGER consented to a search ofthe SINGER Telephone. As detailed

below,the search revealed communications between SINGER and WOOD,as well as

between SINGER and Wilson.

25. Electronic communications between Wilson and SINGER that were

recovered in the search show them discussing the extortion ofthe Victim.^ For example, on

November 5,2018, Wilson wrote a message to SINGER stating,"[WOOD]just gave me a

brief life lesson on business. I appreciate you both." Based on my knowledge ofthe

investigation and training and experience,I believe that Wilson was referring to WOOD'S

efforts to extort the Victim for money.

26. Prior to the November 5 meetings, SINGER wrote to Wilson,"Is it

possible for you to wear a dark suit but no tie? Maybe a white shirt? And dark sunglasses?"

WILSON replied, proposing that he would wear "All black, I'm thinking. Black button

down shirt. Black suitjacket, black suit pants." Based on my knowledge ofthe

investigation and training and experience, I believe that Wilson was attempting to select

clothing that would make him appear most intimidating,to fit the role of an enforcer for

SINGER, WOOD and their "organization." SINGER responded to this message stating,

"Perfect!"

^ Wilson is listed in SINGER'S phone as"ROY," under a telephone number


ending in 6001. Both Experian (in June 2018)and Accurint(unspecified date) attribute the
6001 telephone to Wilson. The messages recovered from SENGER's telephone also indicate
that Wilson was coming from New Jersey, where Wilson resides.
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27. As another example, on November 9,2018, Wilson sent the following

text message,the relevant part of which provided:"Received your VM [i.e.. voicemail]. I

had a feeling that [the Victim] was going to be the weasel that he is. Keep me posted."

Based on my knowledge ofthis investigation, I believe that SINGER informed Wilson that

the Victim had not yet provided the money, and Wilson was expressing his view ofthe

Victim. The following day, Wilson followed up with SINGER,asking "Haven't heard from

you. What's the latest?"

28. A message SINGER sent to Wilson via "Facebook Messenger" on

November 1,2018 shows how SINGER recruited Wilson:

Hey Roy,I hope this note finds you well. I was wondering if
you might be interested in a 'kind of acting gig. I need a
couple ofguys to escort my associate [i.e.. WOOD]while she
delivers a demand to my landlord. It will be in a pizzeria in
Brooklyn. You would simply have to stand in the background
and appear to be muscle. Suit/sunglasses. He [i.e.. the
Victim] tried to screw me and she isjust setting him straight.
No danger. I would pay you $50 per hour including 2 hours of
drive time with a minimum of$250. The problem is that it has
to be this Monday. Let me know if you are interested ASAP.
Thanks.

After sending this message, SINGER left Wilson his telephone number.

29. Messages between SINGER and WOOD also show that they scripted

the planned extortion. For example,in a November 2,2018 exchange, in consecutive

messages, SINGER wrote to WOOD,"By the way the other guy whose picture I sent, he is

100% in. He is for Monday." Based on my knowledge ofthe investigation, I believe that

SINGER was referring to Wilson, whom WOOD did not appear to have met prior to the

extortion ofthe Victim. Later, the two shared the following exchanges:

SINGER: We are confirmed for 11:30 AM at the


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pizzeria with [the Victim].

WOOD: YAY

SINGER: Let the games begin!

WOOD: Oh yeah baby!!


4c Hi ^

SINGER: So regarding Monday, how important is it


to have a super luxury car? I can get a
Mercedes for $150 an hour, but I can get a
Lincoln town car for $35. If you think
it's really important I will get the
Mercedes. I don't want to cheap out.

WOOD: Your call entirely.

SINGER: Towncar works.

WOOD: It's just that ifthings don't work out, not


that I want to think that way,it is a lot of
money that I don't have.
***

SINGER: That's why,in my opinion, stead silence


can be the most intimidating thing there is.
I actually think this might be kind offun.
Is that wrong? LOL [l^,laughing out
loud]!

WOOD: Not at all.

WOOD: I'm looking forward to it.

SINGER: Me too.

30. In these messages, WOOD and SINGER agreed to meet with Wilson

for "20 minutes before you tw[o] get in the car together." SINGER added, about Wilson,

"He is an actor and on Monday his gig is there going to be to look scary and not say a

fucking word. Easy gig for 50 bucks an hour say LOL Fi.e.. laughing out loud]." WOOD
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and SrNGER also discussed how they arrived at the extortionate sum. SINGER wrote:

"60,000 purchase price. $15,600 in security deposit. $23,000 in equipment. $40,000 in

renovation cost. Average of$7000 a month and losses times 8 V2 months is 60,000."

WOOD responded,"Eve got 75000 by the end ofthis week and you're out ofthe lease.

What do you say?" SINGER responded,"Do you trust it [sic] vdll get the 75,000? How do

we know that?" Based on my knowledge ofthe investigation and training and experience,

these messages show that SINGER and WOOD discussed the probability that they could

obtain $75,000 from the Victim.

31. On December 14, 2018,the FBI executed a search warrant on Wilson's

residence, pursuant to a search warrant authorized by the Honorable Leda D. Wettre, United

States Magistrate Judge for the District ofNew Jersey. Among the items recovered from

Wilson's residence was a prop black pistol (the same color as described by the Victim), and a

leather jacket that WILSON could be seen wearing on surveillance footage on November 5,

2018.
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WHEREFORE,your deponent respectfully requests that the defendants

DOUGLAS SINGER and MARIANNE WOOD,be dealt with according to law.

Neill Pagan
Special Agoot/
Federal Bureau ofInvestigation

Sworn to before me this


17th day of December,2018

™ HONORABLE SANKET J. BULSARA


UNITED STATES MAGISTRATE JUDGE
EASTERN DISTRICT OF NEW YORK