RPG Complaint 112119
RPG Complaint 112119
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
Beginning on or about January 1,2015, through and including the present date, in the Western District of
New York, THOMAS NARY, ERIC FINNEFROCK and RALPH SWAIN violated Title 18, United States Code,
Sections 1343 and 1349 (Wire Fraud), Title 18, United States Code, Sections 371, 2314 and 2315 (Interstate
Transportation and Sale of Stolen Property), and Title 18, United States Code Section 1956 (Money Laundering);
AND beginning on or about January \,z}l1,through and including the present date, in the Western District of New
York, THOMAS NARYviolated Title 18, United States Code, Section 1957 (Money Laundering); AND on or about
Jlly 22,2018, through and including July 28, 2018, in the Western District ofNew York, ERIC FINNEFROCK and
RALPH SWAIN violated Title 18, United States Code, Section 10284 (Aggravated Identity Theft); said offenses
described as follows:
All defendants did knowingly devise and execute and conspire to devise and execute a scheme or artifice to
defraud or to obtain money or property by materially false and fraudulent representations, with specific intent
to defraud, and in execution of that scheme, used or caused the use of interstate wires, in violation of Title 18,
United States Code, Sections 1343 and 1349; AND
All defendants knowingly ffansported (or caused to be ffansported or conspired to ffansport) in interstate or
foreign commerce goods, wares, and merchandise, the value of which was at least $5,000, that were stolen,
converted, or taken by fraud, all while knowing that such property was stolen, converted, or taken by fraud,
in violation of Title 18, United States Code, Sections 371and 2314; AND
All defendants sold or conspired to sell goods, wares, or merchandise, the value of which was at least $5,000,
that were stolen, converted, or taken and that, after having been stolen, converted, or taken, crossed a
boundary of a state or of the United States, all while knowing that such property had been stolen, converted,
or unlawfully taken, in violation of Title 18, United States Code, Sections 371and2315;AND
All defendants have conducted (or attempted to conduct) financial transactions involving property
constituting the proceeds of specified unlawful activity-specifically wire fraud and the interstate sale and
ffansportation of stolen property-all while knowing that the properfy involved in the financial ffansactions
was the proceeds of some form of unlawful activities and with the intent to promote the carrying on of said
specified unlawful activities, in violation of Title 18, United States Code, Sections 1956; AND
The defendant THOMAS NARY did knowingly engage (or attempt to engage) in monetary transactions in
or affecting interstate cofllmerce, each with a value gteater than $10,000, which transactions occurred in the
United States and involved property derived from a specified unlawfully activity-specifically wire fraud and
the interstate sale and transportation of stolen properfy-allwhile knowing that the properry was derived from
said specified unlawful activities, in violation of Title 18, United States Code, Section 1957; AND
The defendants ERIC FINNEFROCK and RALPH SWAIN did knowingly use a means of identification of
another person during and in relation to the offenses of wire fraud and the interstate transportation and sale
of stolen goods without lawful authority to do so, in violation of Title 18, United States Code, Section 1028A.
MARIANW. PAYSON
City and State: Rochester, New York IINTTED STATES AGTSTRATF,.ITIDGE
Pinted name and title