Indictment Conspiracy #1

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
THE PEOPLE OF THE STATE OF NEW YORK
-against-
OPHELIA ALLEYNE, a/k/a “PHILLY,” INDICTMENT

MARCUS ARTIS, a/k/a “BLING,”
JAMARA BENNETT, a/k/a “KILLZ,”
SHANAYA BETHEA, a/k/a “NAYA,”
ALI BILAL, a/k/a “ACKII,”
ISAAC BILAL, a/k/a “I.B.,”
RAHIM BILAL, a/k/a “MARLO,” a/k/a
“STARLO,”
SHAHEED BILAL, a/k/a “SHA,”
GIL EINHORN,
TRASHAWN FRAILS, a/k/a “SPOT,”
DARNELL GIBBS, a/k/a “BUTTER LUV,”
ANTHONY HARPER, a/k/a “ANT,”
TSAIQUAN IRBY-BACON,
TETEE MORRISON,
ASHLEY PENNICOTT,
SHADU WAGNER and
JAQUAN WRIGHT,
Defendants.
THE GRAND JURY OF THE COUNTY OF NEW YORK, by this indictment,
accuses the defendants OPHELIA ALLEYNE, a/k/a “PHILLY,” MARCUS ARTIS, a/k/a
“BLING,” JAMARA BENNETT, a/k/a “KILLZ,” SHANAYA BETHEA, a/k/a
“NAYA,” ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” RAHIM BILAL,
a/k/a “MARLO,” a/k/a “STARLO,” SHAHEED BILAL, a/k/a “SHA,” GIL EINHORN,
TRASHAWN FRAILS, a/k/a “SPOT,” DARNELL GIBBS, a/k/a “BUTTER LUV,”
ANTHONY HARPER, a/k/a “ANT,” TSAIQUAN IRBY-BACON, TETEE
MORRISON, ASHLEY PENNICOTT, SHADU WAGNER and JAQUAN WRIGHT of
the crime of CONSPIRACY IN THE FOURTH DEGREE, in violation of Penal Law
§105.10(1), committed as follows:
The defendants, in the County of New York, during the period from in or about
May of 2009 to in or about December of 2010, with intent that conduct constituting the
crime of GRAND LARCENY IN THE SECOND DEGREE be performed, said crime
being a Class “C” felony, agreed with each other and with others to engage in and to
cause the performance of such conduct.
During the period of this conspiracy, the defendants engaged in conduct
constituting the crimes of identity theft, forgery, criminal possession of forged
instruments and larceny, designed to enrich themselves and their associates while
avoiding detection by law enforcement. Defendants engaged in larcenies by obtaining
personal identifying information, such as names, credit card account numbers and credit
card data, of other individuals (hereinafter “identity theft victims”), and then used such
information to create counterfeit credit cards. The defendants then used the counterfeit
credit cards to purchase goods for their own use and resale.
Between in or about May of 2009 to in or about May of 2010, it was part of said
conspiracy for defendants SHAHEED BILAL, a/k/a “SHA,” ALI BILAL, a/k/a “ACKII,”
ISAAC BILAL, a/k/a “I.B.,” RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO,”
DARNELL GIBBS, a/k/a “BUTTER LUV,” and ANTHONY HARPER, a/k/a “ANT” to
obtain personal identifying information, including stolen credit card account numbers,
belonging to identity theft victims. It was further part of said conspiracy for defendants
SHAHEED BILAL, a/k/a “SHA,” ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a
“I.B.,” RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO,” DARNELL GIBBS, a/k/a
“BUTTER LUV,” and ANTHONY HARPER, a/k/a “ANT,” to use email accounts to
store and share said stolen credit card information. Specifically, it was part of said
conspiracy for defendant SHAHEED BILAL, a/k/a “SHA,” to use the email account
“oversea2bk@yahoo.com” to receive, send, and store stolen credit card information. It
was further part of said conspiracy for defendants ALI BILAL, a/k/a “ACKII,” ISAAC
BILAL, a/k/a “I.B.,” and RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO,” to use the
email account “splashin64@yahoo.com” to receive, send and store stolen credit card
information.
It was further part of this conspiracy for defendants SHAHEED BILAL, a/k/a
“SHA,” ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” and RAHIM BILAL,
a/k/a “MARLO,” a/k/a “STARLO,” to create forged credit cards using the stolen credit
card account numbers. It was further part of said conspiracy for defendants SHAHEED
BILAL, a/k/a “SHA,” ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” and
RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO,” to provide forged credit cards to
defendants MARCUS ARTIS, a/k/a “BLING,” JAMARA BENNETT, a/k/a “KILLZ,”
SHANAYA BETHEA, a/k/a “NAYA,” DARNELL GIBBS, a/k/a “BUTTER LUV,”
ANTHONY HARPER, a/k/a “ANT,” TRASHAWN FRAILS, a/k/a “SPOT,” JAQUAN
WRIGHT, and others known and unknown to the Grand Jury, frequently to arrange their
transportation, and to send them to locations in New York County and elsewhere to
purchase goods, such as laptop computers, iPods, iPhones, other electronic devices, gift
cards, and clothing products.
Beginning in or about May of 2010, defendant SHAHEED BILAL, a/k/a “SHA,”
was incarcerated. Between in or about May of 2010 to in or about December of 2010, it
was part of said conspiracy for defendant SHAHEED BILAL, a/k/a “SHA,” to oversee
the operations of this conspiracy by communicating instructions via telephone to
defendant OPHELIA ALLEYNE, a/k/a “PHILLY,” regarding the use of stolen credit
card account information. Between in or about May of 2010 to in or about December of
2010, it was part of said conspiracy for defendants OPHELIA ALLEYNE, a/k/a
“PHILLY,” ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” DARNELL
GIBBS, a/k/a “BUTTER LUV,” and ANTHONY HARPER, a/k/a “ANT,” to acquire the
personal identifying information of identity theft victims, including stolen credit card
account numbers. It was further part of said conspiracy for defendants OPHELIA
ALLEYNE, a/k/a “PHILLY,” ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,”
RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO,” DARNELL GIBBS, a/k/a
“BUTTER LUV,” and ANTHONY HARPER, a/k/a “ANT” to use email accounts to
store and share said stolen credit card information. Specifically, it was part of said
conspiracy for defendant OPHELIA ALLEYNE, a/k/a “PHILLY,” to use the email
account “cakemixp@yahoo.com” to receive, send, and store stolen credit card
information. It was further part of said conspiracy for defendant DARNELL GIBBS,
a/k/a “BUTTER LUV,” to use the email account “boyboutdat@yahoo.com” to receive,
send, and store stolen credit card information. It was further part of said conspiracy for
defendant ANTHONY HARPER, a/k/a “ANT,” to use the email account

“igotnow1@yahoo.com” to receive, send, and store stolen credit card account
information. It was further part of said conspiracy for defendants ALI BILAL, a/k/a
“ACKII,” ISAAC BILAL, a/k/a “I.B.,” and RAHIM BILAL, a/k/a “MARLO,” a/k/a
“STARLO,” and others known and unknown to the Grand Jury to continue to use the
email account “splashin64@yahoo.com” to receive, send and store stolen credit card
information.
It was further a part of said conspiracy for defendants OPHELIA ALLEYNE,
a/k/a “PHILLY,” ISAAC BILAL, a/k/a “I.B.,” DARNELL GIBBS, a/k/a “BUTTER
LUV,” and MARCUS ARTIS, a/k/a “BLING,” to use the credit card account information
of identity theft victims to create counterfeit credit cards.
It was further a part of said conspiracy for defendants OPHELIA ALLEYNE,
a/k/a “PHILLY,” ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” RAHIM
BILAL, a/k/a “MARLO,” a/k/a “STARLO,” and others known and unknown to the
Grand Jury to provide counterfeit credit cards to defendants SHANAYA BETHEA, a/k/a
“NAYA,” TETEE MORRISON, ASHLEY PENNICOTT, TSAIQUAN IRBY-BACON,
JAQUAN WRIGHT, and others known and unknown to the Grand Jury, frequently to
arrange their transportation, and to send them to locations inside of New York County and
elsewhere to purchase goods, such as laptop computers, iPods, iPhones, other electronic
devices, gift cards, and clothing products. It was also part of said conspiracy for defendants
OPHELIA ALLEYNE, a/k/a “PHILLY,” ANTHONY HARPER, a/k/a “ANT,” ISAAC
BILAL, a/k/a “I.B.” and RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO,” to re-sell
fraudulently purchased merchandise to defendant GIL EINHORN and others known and
unknown to the Grand Jury. It was further part of this conspiracy for defendant SHAHEED
BILAL, a/k/a “SHA,” to oversee the sale of fraudulently purchased merchandise by relaying
instructions over the phone to OPHELIA ALLEYNE, a/k/a “PHILLY.” It was further part
of this conspiracy for defendant GIL EINHORN to purchase fraudulently-obtained
merchandise for below retail value and re-sell it at a profit.
In or about December of 2010, SHAHEED BILAL was released from jail. In or
about December of 2010 SHAHEED BILAL resumed leadership of said conspiracy.
OVERT ACTS
In furtherance of said conspiracy and to effect the objects thereof, from on or
about May 7, 2009 to on or about December 3, 2010, the following overt acts, among
others, were committed:
1. On or about May 7, 2009, SHAHEED BILAL, a/k/a “SHA,” possessed stolen
credit card numbers, in part and in substance including a Mastercard credit
card ending in 3040, in an email.
2. On or about May 8, 2009, in the county of New York, inside an Apple store,
defendant DARNELL GIBBS, a/k/a “BUTTER LUV,” used forged
Mastercard credit card ending in 3040 to purchase merchandise costing
$1407.79, including a MacBook laptop computer, as directed by defendant
SHAHEED BILAL, a/k/a “SHA.”

3. On or about October 18, 2009, defendant SHAHEED BILAL, a/k/a “SHA,”
possessed stolen credit card numbers, in part and in substance including a
Mastercard credit card ending in 5913, in an email.
4. On or about October 20, 2009, in the county of New York, inside an Apple
store, defendant ANTHONY HARPER, a/k/a “ANT,” used forged Mastercard
credit card ending in 5913 to purchase merchandise costing $434.41,
including an iPod, as directed by defendant SHAHEED BILAL, a/k/a “SHA.”
Visa credit card ending in 2215, in an email.
store, defendant ANTHONY HARPER, a/k/a “ANT,” used forged Visa credit
card ending in 2215 to purchase merchandise costing $868.82, including an
iPod, as directed by defendant SHAHEED BILAL, a/k/a “SHA.”
Visa credit card ending in 5311 and a Mastercard credit card ending in 7137,
in an email.
card ending in 5311 to purchase merchandise costing $1632.04, including a
MacBook laptop computer, as directed by defendant SHAHEED BILAL,
a/k/a “SHA.”
9. On or about October 25, 2009, in the county of New York, inside a second
Apple store, defendant ANTHONY HARPER, a/k/a “ANT,” used forged Visa
including a MacBook laptop computer, as directed by defendant SHAHEED
BILAL, a/k/a “SHA.”
10. On or about October 26, 2009, in the County of New York, inside an Apple
including an iMac computer, as directed by defendant SHAHEED BILAL,
a/k/a “SHA.”
13. On or about November 17, 2009, defendant SHAHEED BILAL, a/k/a “SHA,”
Mastercard credit card ending in 5500, a Mastercard credit card ending in
3886, and a Mastercard credit card ending in 3893, in an email.
14. On or about November 17, 2009, in the County of New York, inside an Apple
store, defendant TRASHAWN FRAILS, a/k/a “SPOT,” used forged

$206.70, including an iPhone, as directed by defendant SHAHEED BILAL,
a/k/a “SHA.”
17. On or about November 18, 2009, in the County of New York, inside a second
Apple store, defendant TRASHAWN FRAILS, a/k/a “SPOT,” used forged
18. On or about November 18, 2009, in the County of New York, inside a third

21. On or about November 23, 2009, in the County of New York, inside a second
$87.05, including a “Mophie Juice Pack,” as directed by defendant
possessed stolen credit card numbers, including a Mastercard credit card
ending in 9288, in an email.
24. On or about December 3, 2009, defendant SHAHEED BILAL, a/k/a “SHA,”
emailed stolen credit card numbers, in part and in substance including a

Mastercard credit card ending in 5292, to defendants ALI BILAL, a/k/a
“ACKII,” ISAAC BILAL, a/k/a “I.B.,” and RAHIM BILAL, a/k/a
“MARLO,” a/k/a “STARLO.”
25. On or about December 3, 2009, in Wayne, New Jersey, inside an Apple store,
defendant SHANAYA BETHEA, a/k/a “NAYA,” used forged Mastercard
including a MacBook laptop computer, as directed by defendants SHAHEED
BILAL, a/k/a “SHA,” ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a
“I.B.,” and RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO.”
27. On or about December 4, 2009, in Bridgewater, New Jersey, inside an Apple
SHAHEED BILAL, a/k/a “SHA,” and ALI BILAL, a/k/a “ACKII,” ISAAC
BILAL, a/k/a “I.B.,” and RAHIM BILAL, a/k/a “MARLO,” a/k/a
“STARLO.”

29. On or about December 8, 2009, in Paramus, New Jersey, inside an Apple
store, defendant SHANAYA BETHEA, a/k/a “NAYA,” used forged
$2705.98, including a MacBook laptop computer, as directed by defendants
SHAHEED BILAL, a/k/a “SHA,” ALI BILAL, a/k/a “ACKII,” ISAAC
“STARLO.”
Mastercard credit card ending in 7226 and a Mastercard credit card ending
9420, to defendants ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,”
and RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO.”
31. On or about December 8, 2009, in Short Hills, New Jersey, inside an Apple
$319.93, including an iPod, as directed by defendants SHAHEED BILAL,
a/k/a “SHA,” OPHELIA ALLEYNE, a/k/a “PHILLY,” ISAAC BILAL, a/k/a
“I.B,” and RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO.”
32. On or about December 8, 2009, in Short Hills, New Jersey, inside an Apple

$320.95, including Monster Beats headphones, as directed by defendants
SHAHEED BILAL, a/k/a “SHA,” OPHELIA ALLEYNE, a/k/a “PHILLY,”
ISAAC BILAL, a/k/a “I.B,” and RAHIM BILAL, a/k/a “MARLO,” a/k/a
“STARLO.”
33. On or about December 8, 2009, in Edison, New Jersey, inside an Apple store,
defendant TRASHAWN FRAILS, a/k/a “SPOT,” used forged Mastercard
BILAL, a/k/a “SHA,” OPHELIA ALLEYNE, a/k/a “PHILLY,” ISAAC
BILAL, a/k/a “I.B,” and RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO.”
34. On or about December 16, 2009, SHAHEED BILAL, a/k/a “SHA,” sent an
email to defendants ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,”
and RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO,” containing stolen
card ending in 7379, in an email.
35. On or about December 16, 2009, in White Plains, New York, inside an Apple
SHAHEED BILAL, a/k/a “SHA,” ALI BILAL, a/k/a “ACKII,” ISAAC
“STARLO.”
SHAHEED BILAL, a/k/a “SHA, ” ALI BILAL, a/k/a “ACKII,” ISAAC
“STARLO.”
40. On or about December 28, 2009, in the County of New York, inside an Apple

41. On or about January 12, 2010, SHAHEED BILAL, a/k/a “SHA,” emailed
stolen credit card numbers, in part and in substance including a Mastercard
credit card ending in 0606, Mastercard credit card ending in 2910, and Visa
credit card ending in 2011, to defendants ALI BILAL, a/k/a “ACKII,” ISAAC
“STARLO.”
42. On or about January 12, 2010, in the County of New York, inside an Apple
a/k/a “SHA, ” ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” and
RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO.”
43. On or about January 12, 2010, in the County of New York, inside a second
a/k/a “SHA,” ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” and
44. On or about January 12, 2010, in Greenwich, Connecticut, inside an Apple
card ending in 2011 to purchase merchandise costing $633.88, including an

iPod, as directed by defendants SHAHEED BILAL, a/k/a “SHA,” ALI
BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” and RAHIM BILAL,
a/k/a “MARLO,” a/k/a “STARLO.”
45. On or about January 13, 2010, in Short Hills, New Jersey, inside an Apple
including an iPod, as directed by defendants SHAHEED BILAL, a/k/a
“SHA,” ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” and
46. On or about January 13, 2010, in Wayne, New Jersey, inside an Apple store,
defendant ANTHONY HARPER, a/k/a “ANT,” used forged Mastercard credit
MacBook laptop computer, as directed by defendants SHAHEED BILAL,
47. On or about January 13, 2010, in Edison, New Jersey, inside an Apple store,
neoprene laptop case, as directed by defendants SHAHEED BILAL, a/k/a
48. On or about January 18, 2010, defendant SHAHEED BILAL, a/k/a “SHA,”

Mastercard credit card ending in 3184, a Mastercard credit card ending in
9756, a Mastercard credit card ending in 7577, to defendants ALI BILAL,
a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” and RAHIM BILAL, a/k/a
49. On or about January 19, 2010, in White Plains, New York, inside an Apple
50. On or about January 19, 2010, in White Plains, New York, inside an Apple
51. On or about January 19, 2010, in Garden City, New York, inside an Apple

Mastercard credit card ending in 4516, and a Mastercard credit card ending in
3466, in an email.
53. On or about January 20, 2010, in the County of New York, inside an Apple
54. On or about January 20, 2010, in the County of New York, inside a second
Apple store, defendant ANTHONY HARPER, a/k/a “ANT,” used forged
$715.31, including an iPod, as directed by defendant SHAHEED BILAL,
a/k/a “SHA.”
56. On or about January 20, 2010, in Huntsville, Alabama, inside an Apple store,
defendant JAMARA BENNETT, a/k/a “KILLZ,” used forged Mastercard
including an iPod, as directed by defendants SHAHEED BILAL, a/k/a

57. On or about January 27, 2010, SHAHEED BILAL, a/k/a “SHA,” emailed
“STARLO.”
58. On or about January 27, 2010, in Rockaway, New Jersey, inside an Apple
emailed stolen credit card numbers, in part and in substance including a Visa
“STARLO.”
60. On or about January 28, 2010, in Portland, Oregon, inside an Apple store,
defendant JAMARA BENNETT, a/k/a “KILLZ,” used forged Visa credit card
ending in 1187 to purchase merchandise costing $1997, including a MacBook
laptop computer, as directed by defendants SHAHEED BILAL, a/k/a “SHA,”

ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” and RAHIM
BILAL, a/k/a “MARLO,” a/k/a “STARLO.”
61. On or about January 28, 2010, in Portland, Oregon, inside an Apple store,
62. On or about January 28, 2010, in Tigard, Oregon, inside an Apple store,
63. On or about January 28, 2010, in Tigard, Oregon, inside an Apple store,
ending in 1187 to purchase additional merchandise costing $1997, including
an iPod, as directed by defendants SHAHEED BILAL, a/k/a “SHA,” ALI
BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” and RAHIM BILAL,
a/k/a “MARLO,” a/k/a “STARLO.”
64. On or about February 9, 2010, defendants ALI BILAL, a/k/a “ACKII,”
ISAAC BILAL, a/k/a “I.B.,” and RAHIM BILAL, a/k/a “MARLO,” a/k/a
“STARLO” possessed stolen credit card numbers, in part and in substance

including a Visa credit card ending in 7574, and a Visa credit card ending in
0171, in an email.
65. On or about February 10, 2010, in Wauwatosa, Wisconsin, inside an Apple
store, defendant JAQUAN WRIGHT used forged Visa credit card ending in
7574 to purchase merchandise costing $2638.94, including a MacBook laptop
computer, as directed by defendants ALI BILAL, a/k/a “ACKII,” ISAAC
“STARLO.”
66. On or about February 10, 2010, in Wisconsin, inside an Apple store,
defendant JAQUAN WRIGHT used forged Visa credit card ending in 0171 to
purchase merchandise costing $2638.94, including a gift card, as directed by
defendants ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” and
67. On or about February 15, 2010, in the County of New York, inside an Apple
$651.07, including an iPod.
68. On or about February 15, 2010, in the County of New York, inside a second
$651.07, including an iPod.
including a Mastercard credit card ending in 2378, Mastercard credit card
ending in 1556, and a Mastercard credit card ending in 0086, in an email.
70. On or about February 18, 2010, in Indianapolis, Indiana, inside an Apple
store, defendant JAQUAN WRIGHT used forged Mastercard credit card
ending in 2378 to purchase merchandise costing $2612.43, including a
MacBook laptop computer, as directed by defendants ALI BILAL, a/k/a
71. On or about February 18, 2010, in Indianapolis, Indiana, inside an Apple
72. On or about February 19, 2010, in Orlando, Florida, inside an Apple store,
defendant JAQUAN WRIGHT used forged Mastercard credit card ending in
“STARLO.”
73. On or about February 19, 2010, in Orlando, Florida, inside a second Apple

74. On or about February 19, 2010, in Altamonte Springs, Florida, inside an
Apple store, defendant JAQUAN WRIGHT used forged Mastercard credit
card ending in 0086 to purchase merchandise costing $320.95, including head
phones, as directed by defendants ALI BILAL, a/k/a “ACKII,” ISAAC
“STARLO.”
75. On or about February 20, 2010, in Garden City, New York, inside an Apple
store, defendant TRASHAWN FRAILS, a/k/a “SPOT,” used forged Visa
including an iPod.
76. On or about February 20, 2010, in Los Angeles, California, inside an Apple
store, defendant SHAHEED BILAL, a/k/a “SHA,” used forged Mastercard
including head phones.
“STARLO,” emailed stolen credit card numbers, in part and in substance
including a including a Mastercard credit card ending in 6938 to defendant

78. On or about February 24, 2010, in the County of New York, inside an Apple
79. On or about February 24, 2010, in the County of New York, inside a second
including a Mastercard credit card ending in 3243, Visa credit card ending in
7867, Mastercard credit card ending in 8400, and Mastercard credit card
including a Mastercard credit card ending in 6301, in an email.

82. On or about February 25, 2010, defendant SHAHEED BILAL, a/k/a “SHA,”
Mastercard credit card ending in 8212, Mastercard credit card ending in 0476,
and Mastercard credit card ending in 0222, in an email.
83. On or about February 25, 2010, in Marlton, New Jersey, inside an Apple store,
including an iPod, as directed by defendants ALI BILAL, a/k/a “ACKII,”
“STARLO.”
Apple store, defendant JAQUAN WRIGHT used forged Mastercard credit
8400 to purchase merchandise costing $849.87, including an iPod, as directed
by defendants ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” and
86. On or about February 27, 2010 in Short Hills, New Jersey, inside an Apple
store, defendant SHANAYA BETHEA, a/k/a “NAYA,” used forged Visa

including a MacBook laptop computer, as directed by defendants ALI BILAL,
defendant TRASHAWN FRAILS, a/k/a “SPOT,” used forged Mastercard
including a MacBook laptop computer, as directed by defendant SHAHEED
BILAL, a/k/a “SHA.”
88. On or about February 28, 2010, in Orlando, Florida, inside a second Apple
90. On or about March 2, 2010, in Tigard, Oregon, inside an Apple store,

“STARLO.”
91. On or about March 2, 2010, in Atlanta, Georgia, inside an Apple store,
a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” RAHIM BILAL, a/k/a
“MARLO,” a/k/a “STARLO,” and SHAHEED BILAL, a/k/a “SHA.”
92. On or about March 6, 2010, defendant SHAHEED BILAL, a/k/a “SHA,”
93. On or about March 6, 2010, in New York County, inside an Apple store,
defendant TETEE MORRISON used forged Visa credit card ending in 0215
to purchase merchandise costing $2176.41, including a MacBook laptop
computer, as directed by defendant SHAHEED BILAL, a/k/a “SHA.”
94. On or about March 7, 2010, defendants ALI BILAL, a/k/a “ACKII,” ISAAC
BILAL, a/k/a “I.B.,” and RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO”
Mastercard credit card ending in 2378, and a Mastercard credit card ending in
1556, in an email.
95. On or about March 7, 2010, in Short Hills, New Jersey, inside an Apple store,

96. On or about March 7, 2010, in Rockaway, New Jersey, inside an Apple store,
97. On or about March 9, 2010, SHAHEED BILAL, a/k/a “SHA,” emailed stolen
card ending in 0480, to defendants ALI BILAL, a/k/a “ACKII,” ISAAC
“STARLO.”
98. On or about March 11, 2010, in Atlanta, Georgia, inside an Apple store,
99. On or about March 7, 2010, defendants ALI BILAL, a/k/a “ACKII,” ISAAC

“STARLO,” possessed stolen credit card numbers, in part and in substance
including a Mastercard credit card ending in 0040, in an email.
including Monster Beats head phones, as directed by defendants ALI BILAL,
102. On or about April 5, 2010, defendants ALI BILAL, a/k/a “ACKII,” ISAAC
103. On or about April 5, 2010, in Orlando, Florida, inside an Apple store,
purchase merchandise costing $424.94, including an iPod, as directed by
defendants ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” RAHIM

104. On or about April 5, 2010, in Orlando, Florida, inside an Apple store,
purchase merchandise costing $744.44, including an iPad, as directed by
defendants ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” and
Visa credit card ending in 9007, and Visa credit card ending in 0088, in an
email.
106. On or about April 7, 2010 in Las Vegas, Nevada, inside an Apple store,
defendant SHADU WAGNER used forged Visa credit card ending in 9007 to
purchase merchandise costing $2701.42, including a MacBook laptop
“STARLO.”
107. On or about April 7, 2010 in Las Vegas, Nevada, inside an Apple store,
“STARLO.”
Visa credit card ending in 6689, and Visa credit card ending in 7356, in an
email.
109. On or about April 23, 2010, in Wisconsin, inside an Apple store, defendant
JAQUAN WRIGHT used forged Visa credit card ending in 6689 to purchase
merchandise costing $2718.09, including a MacBook laptop computer, as
directed by defendants ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a
“I.B.,” RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO.”
110. On or about April 24, 2010, in St. Louis, Missouri, inside an Apple store,
BILAL, a/k/a “I.B.,” RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO.”
111. On or about May 5, 2010, defendants ALI BILAL, a/k/a “ACKII,” ISAAC
Mastercard credit card ending in 0142, Mastercard credit card ending in 6596,
and Mastercard credit card ending in 3615, in an email.
112. On or about May 5, 2010, in Atlanta, Georgia, inside an Apple store,
defendant SHADU WAGNER used forged Mastercard credit card ending in
0142 to purchase merchandise costing $1707.72, including an iPod, as

“STARLO.”
“STARLO.”
by defendants ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,”

9292 to purchase merchandise costing $1509.84, including an iPad, as
118. On or about May 19, 2010, defendant MARCUS ARTIS, a/k/a “BLING,”
engaged in a telephonic conversation with defendant SHAHEED BILAL,
a/k/a “SHA,” wherein defendant SHAHEED BILAL, a/k/a “SHA,” in part and
in substance gave instructions to defendant MARCUS ARTIS, a/k/a
“BLING,” regarding the purchase of equipment used to manufacture forged
credit cards, and wherein defendant MARCUS ARTIS, a/k/a “BLING,” in
part and in substance agreed to purchase equipment to use to manufacture
forged credit cards.
119. On or about May 25, 2010, defendants OPHELIA ALLEYNE, a/k/a
“PHILLY,” and GIL EINHORN engaged in a telephonic conversation with
defendant SHAHEED BILAL, a/k/a “SHA,” in part and in substance
discussing resale prices for fraudulently obtained merchandise.
120. On or about May 25, 2010, defendant ANTHONY HARPER, a/k/a “ANT,”

121. On or about May 26, 2010, in White Plains, New York, inside an Apple store,
credit card ending in 0169 to purchase merchandise costing $1772.78
including a MacBook laptop computer, as directed by defendant ANTHONY
HARPER, a/k/a “ANT.”
Mastercard credit card ending in 1004, and Visa credit card ending in 4008, in
an email.
123. On or about May 26, 2010, in White Plains, New York, inside an Apple store,
card ending in 1004 to purchase merchandise costing $2161.42 including a
MacBook laptop computer.
124. On or about May 26, 2010, in Stamford, Connecticut, inside an Apple store,
card ending in 1004 to purchase merchandise costing $422.94 including an
iPod.
125. On or about May 26, 2010, in Danbury, Connecticut, inside an Apple store,
defendant ANTHONY HARPER, a/k/a “ANT,” used forged Visa credit card
ending in 4008 to purchase merchandise costing $2155.99 including a
MacBook laptop computer.

127. On or about May 27, 2010, in the County of New York, inside an Apple store,
defendant TETEE MORRISON used forged Visa credit card ending in 5132
to purchase merchandise costing $2219.91 including a MacBook laptop
computer, as directed by defendant ANTHONY HARPER, a/k/a “ANT.”
128. On or about June 5, 2010, OPHELIA ALLEYNE, a/k/a “PHILLY,” emailed
credit card ending in 4229, to defendant ANTHONY HARPER, a/k/a “ANT.”
129. On or about June 7, 2010, in the County of New York, inside an Apple store,
defendant TETEE MORRISON used forged Mastercard credit card ending in
4229 to purchase merchandise costing $1632.04 including a MacBook laptop
computer, as directed by defendants OPHELIA ALLEYNE, a/k/a “PHILLY,”
and ANTHONY HARPER, a/k/a “ANT.”
130. On or about June 15, 2010, defendant OPHELIA ALLEYNE, a/k/a
“PHILLY,” engaged in a telephonic conversation with defendant SHAHEED
BILAL, a/k/a “SHA,” in part and in substance stating that a co-conspirator
successfully purchased a MacBook computer.
131. On or about June 15, 2010, in the County of New York, inside an Apple store,
defendant TETEE MORRISON used forged Mastercard credit card ending in
computer, as directed by defendant OPHELIA ALLEYNE, a/k/a “PHILLY.”

132. On or about July 6, 2010, defendant ANTHONY HARPER, a/k/a “ANT,”
Mastercard credit card ending in 9395, to defendant OPHELIA ALLEYNE,
a/k/a “PHILLY.”
133. On or about July 10, 2010, in the County of New York, inside an Apple store,
card ending in 9395 to purchase merchandise costing $190.42 including a
MacBook laptop computer, as directed by defendant DARNELL GIBBS,
a/k/a “BUTTER LUV.”
134. On or about August 19, 2010, in Rockaway, New Jersey, inside an Apple
credit card ending in 0899 to purchase merchandise costing $369.93 including
an iPod.
135. On or about August 20, 2010, in White Plains, New York, inside an Apple
card ending in 8420 to purchase merchandise costing $832.32 including an
iPad.
136. On or about September 21, 2010, defendant DARNELL GIBBS, a/k/a
“BUTTER LUV,” sent a text message to defendant OPHELIA ALLEYNE,
a/k/a “PHILLY,” in part and in substance informing defendant OPHELIA
ALLEYNE, a/k/a “PHILLY,” that new stolen credit card information was
being offered for sale.

137. On or about September 21, 2010, defendant ISAAC BILAL, a/k/a “I.B.,” sent
a text message to defendant OPHELIA ALLEYNE, a/k/a “PHILLY,” in part
and in substance informing defendant OPHELIA ALLEYNE, a/k/a
“PHILLY,” that new stolen credit card information was being offered for sale.
138. On or about September 22, 2010, defendant OPHELIA ALLEYNE, a/k/a
“PHILLY,” sent an email to defendant DARNELL GIBBS, a/k/a “BUTTER
LUV,” in part and in substance containing a list of shopper names next to
stolen credit card numbers.
139. On or about September 22, 2010, defendant OPHELIA ALLEYNE, a/k/a
“PHILLY,” sent a text message to defendant ALI BILAL, a/k/a “ACKII,” in
part and in substance requesting that defendant ALI BILAL, a/k/a “ACKII,”
email her stolen credit card numbers.
140. On or about September 22, 2010, defendants ALI BILAL, a/k/a “ACKII,”
“STARLO,” emailed stolen credit card numbers, in part and in substance
including a including a Visa credit card ending in 0385, and a Mastercard
credit card ending in 3801, to defendant OPHELIA ALLEYNE, a/k/a
“PHILLY.”
141. On or about September 22, 2010, in the County of New York, inside an Apple
store, defendant TSAIQUAN IRBY-BACON used forged Visa credit card
MacBook laptop computer, as directed by defendants OPHELIA ALLEYNE,
a/k/a “PHILLY,” DARNELL GIBBS, a/k/a “BUTTER LUV,” ALI BILAL,

store, defendant ASHLEY PENNICOTT used forged Mastercard credit card
ending in 3801 to attempt to purchase merchandise including a MacBook
laptop computer, as directed by defendants OPHELIA ALLEYNE, a/k/a
“PHILLY,” DARNELL GIBBS, a/k/a “BUTTER LUV,” ALI BILAL, a/k/a
143. On or about September 22, 2010, defendant ASHLEY PENNICOTT
communicated with defendant OPHELIA ALLEYNE, a/k/a “PHILLY,” in
part and in substance stating that the forged credit card was using was
confiscated at an Apple store.
144. On or about September 22, 2010, defendants ALI BILAL, a/k/a “ACKII,”
including a Mastercard credit card ending in 6618, and Mastercard credit card
145. On or about September 23, 2010, in Wauwatosa, Wisconsin, inside an Apple
ending in 6618 to purchase merchandise costing $842.69 including an iPod,
as directed by defendants ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a

146. On or about September 23, 2010, in Wisconsin, inside an Apple store,
“STARLO.”
147. On or about September 23, 2010, in Wisconsin, inside an Apple store,
6618 to purchase merchandise costing $842.69 including an iPod, as directed
ending in 8320 to purchase merchandise costing $868.82 including an iPod, as

150. On or about September 28, 2010, defendant ISAAC BILAL, a/k/a “I.B.,”
provided his email address via text message to defendant OPHELIA
ALLEYNE, a/k/a “PHILLY.”
151. On or about September 29, 2010, in Brooklyn, New York, defendant
OPHELIA ALLEYNE, a/k/a “PHILLY,” sold Apple merchandise purchased
with forged credit cards to defendant GIL EINHORN.
152. On or about October 6, 2010, defendants ISAAC BILAL, a/k/a “I.B.,” and
OPHELIA ALLEYNE, a/k/a “PHILLY,” communicated via text messages
regarding the creation of counterfeit credit cards.
153. On or about October 12, 2010, defendants ALI BILAL, a/k/a “ACKII,”
including Visa credit card ending in 0887, Mastercard credit card ending in
6704, and Visa credit card ending in 8551, in an email.
“STARLO.”
ending in 6704 to purchase merchandise costing $868.82 including an iPod, as

158. On or about November 10, 2010, defendants ALI BILAL, a/k/a “ACKII,”
including a Visa credit card ending in 2263, in an email.
“STARLO.”
162. On or about November 17, 2010, in Brooklyn, New York, defendants ISAAC
“STARLO,” provided items to defendant GIL EINHORN in exchange for
U.S. Currency.
163. On or about December 2, 2010, defendants MARCUS ARTIS, a/k/a
“BLING,” and ISAAC BILAL, a/k/a “I.B.” transported items from inside a
residence at or near 139-27 247th Street, Rosedale, New York into the trunk of
a vehicle.
164. On or about December 3, 2010, in Bridgewater, New Jersey, inside an Apple

created the email account “rightbackonit@yahoo.com” for the purpose of
receiving, sending, and storing stolen credit card information.

SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses
the defendants OPHELIA ALLEYNE, a/k/a “PHILLY,” MARCUS ARTIS, a/k/a
“BLING,” JAMARA BENNETT, a/k/a “KILLZ,” SHANAYA BETHEA, a/k/a
“NAYA,” ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,” RAHIM
BILAL, a/k/a “MARLO,” a/k/a “STARLO,” SHAHEED BILAL, a/k/a “SHA,”
GIL EINHORN, TRASHAWN FRAILS, a/k/a “SPOT,” DARNELL GIBBS,
a/k/a “BUTTER LUV,” ANTHONY HARPER, a/k/a “ANT,” TSAIQUAN
IRBY-BACON, TETEE MORRISON, ASHLEY PENNICOTT, SHADU
WAGNER and JAQUAN WRIGHT of the crime of GRAND LARCENY IN
THE SECOND DEGREE, in violation of Penal Law §155.40(1), committed as
follows:
The defendants, in the County of New York and elsewhere, during the period
from on or about May 8, 2009 to on or about December 3, 2010, stole property
from Apple and the value of the property exceeded fifty thousand dollars.
THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants DARNELL GIBBS, a/k/a “BUTTER LUV,” and
SHAHEED BILAL, a/k/a “SHA,” of the crime of CRIMINAL POSSESSION
OF A FORGED INSTRUMENT IN THE SECOND DEGREE, in violation of
Penal Law §170.25, committed as follows:
The defendants, in the County of New York and elsewhere, on or about
May 8, 2009, knowing the instrument to be forged and with intent to defraud,
deceive and injure another, uttered and possessed a forged instrument, the same
being and purporting to be, and calculated to become and to represent if
completed, a credit card, and other instrument which does and may evidence,
create, transfer, terminate, and otherwise affect a legal right, interest, obligation
and status, to wit, a MasterCard credit card with account number ending in 3040.
FOURTH COUNT:
accuses the defendants DARNELL GIBBS, a/k/a “BUTTER LUV,” and
SHAHEED BILAL, a/k/a “SHA,” of the crime of GRAND LARCENY IN THE
FOURTH DEGREE, in violation of Penal Law §155.30(1), committed as
follows:
The defendants, in the County of New York, on or about May 8, 2009,
stole property from Apple and the property had a value in excess of one thousand
dollars.
FIFTH COUNT:
accuses the defendants ANTHONY HARPER, a/k/a “ANT,” and SHAHEED
BILAL, a/k/a “SHA,” of the crime of CRIMINAL POSSESSION OF A
FORGED INSTRUMENT IN THE SECOND DEGREE, in violation of Penal
Law §170.25, committed as follows:
October 20, 2009, knowing the instrument to be forged and with intent to defraud,
SIXTH COUNT:
and status, to wit, a Visa credit card with account number ending in 2215.
SEVENTH COUNT:
EIGHTH COUNT:
BILAL, a/k/a “SHA,” of the crime of GRAND LARCENY IN THE THIRD
DEGREE, in violation of Penal Law §155.35, committed as follows:
The defendants, in the County of New York, on or about October 25,
2009, stole property from Apple and the property had a value in excess of three
thousand dollars.
NINTH COUNT:
TENTH COUNT:
BILAL, a/k/a “SHA,” of the crime of GRAND LARCENY IN THE FOURTH
DEGREE, in violation of Penal Law §155.30(1), committed as follows:
2009, stole property from Apple and the property had a value in excess of one
thousand dollars.
ELEVENTH COUNT:
TWELFTH COUNT:
accuses the defendants TRASHAWN FRAILS, a/k/a “SPOT,” and SHAHEED
November 17, 2009, knowing the instrument to be forged and with intent to
defraud, deceive and injure another, uttered and possessed a forged instrument,
the same being and purporting to be, and calculated to become and to represent if
THIRTEENTH COUNT:
The defendants, in the County of New York, on or about November 17,
thousand dollars.
FOURTEENTH COUNT:
FIFTEENTH COUNT:
BILAL, a/k/a “SHA,” of the crime of GRAND LARCENY IN THE THIRD
thousand dollars.
SIXTEENTH COUNT:
SEVENTEENTH COUNT:
thousand dollars.
EIGHTEENTH COUNT:
NINETEENTH COUNT:
thousand dollars.
TWENTIETH COUNT:
December 28, 2009, knowing the instrument to be forged and with intent to
and status, to wit, a MasterCard credit card with account number ending 2489.
TWENTY-FIRST COUNT:
The defendants, in the County of New York, on or about December 28,
thousand dollars.
TWENTY-SECOND COUNT:
accuses the defendants TRASHAWN FRAILS, a/k/a “SPOT,” SHAHEED
BILAL, a/k/a “SHA,” ALI BILAL, a/k/a “ACKII,” ISAAC BILAL, a/k/a “I.B.,”
and RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO,” of the crime of
CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE
SECOND DEGREE, in violation of Penal Law §170.25, committed as follows:
January 12, 2010, knowing the instrument to be forged and with intent to defraud,
TWENTY-THIRD COUNT:
GRAND LARCENY IN THE FOURTH DEGREE, in violation of Penal Law
§155.30(1), committed as follows:
The defendants, in the County of New York, on or about January 12,
thousand dollars.
TWENTY-FOURTH COUNT:
TWENTY-FIFTH COUNT:
TWENTY-SIXTH COUNT:
accuses the defendant TRASHAWN FRAILS, a/k/a “SPOT,” of the crime of
The defendant, in the County of New York and elsewhere, on or about
February 15, 2010, knowing the instrument to be forged and with intent to
TWENTY-SEVENTH COUNT:
accuses the defendant TRASHAWN FRAILS, a/k/a “SPOT,” of the crime of
§155.30(1) committed as follows:
The defendants, in the County of New York, on or about February 15,
thousand dollars.
TWENTY-EIGHTH COUNT:
February 24, 2010, knowing the instrument to be forged and with intent to
TWENTY-NINTH COUNT:
§155.30(1) committed as follows:
The defendants, in the County of New York, on or about February 24,
thousand dollars.
THIRTIETH COUNT:
accuses the defendants TETEE MORRISON and SHAHEED BILAL, a/k/a
‘SHA,” of the crime of CRIMINAL POSSESSION OF A FORGED
INSTRUMENT IN THE SECOND DEGREE, in violation of Penal Law
§170.25, committed as follows:
March 6, 2010, knowing the instrument to be forged and with intent to defraud,
THIRTY-FIRST COUNT:
accuses the defendants TETEE MORRISON and SHAHEED BILAL, a/k/a
‘SHA,” of the crime of GRAND LARCENY IN THE FOURTH DEGREE, in
violation of Penal Law §155.30(1) committed as follows:
The defendants, in the County of New York, on or about March 6, 2010,
dollars.
THIRTY-SECOND COUNT:
accuses the defendants TETEE MORRISON and ANTHONY HARPER, a/k/a
“ANT,” of the crime of CRIMINAL POSSESSION OF A FORGED
May 27, 2010, knowing the instrument to be forged and with intent to defraud,
and status, to wit, a Visa credit card with account number ending 5132.
THIRTY-THIRD COUNT:
accuses the defendants TETEE MORRISON and ANTHONY HARPER, a/k/a
“ANT,” of the crime of GRAND LARCENY IN THE FOURTH DEGREE, in
violation of Penal Law §155.30(1) committed as follows:
The defendants, in the County of New York, on or about May 27, 2010,
dollars.
THIRTY-FOURTH COUNT:
accuses the defendants TETEE MORRISON, OPHELIA ALLEYNE, a/k/a
“PHILLY,” and ANTHONY HARPER, a/k/a “ANT,” of the crime of
June 7, 2010, knowing the instrument to be forged and with intent to defraud,
THIRTY-FIFTH COUNT:
accuses the defendants TETEE MORRISON, OPHELIA ALLEYNE, a/k/a
“PHILLY,” and ANTHONY HARPER, a/k/a “ANT,” of the crime of GRAND
LARCENY IN THE FOURTH DEGREE, in violation of Penal Law §155.30(1)
committed as follows:
The defendants, in the County of New York, on or about June 7, 2010,
dollars.
THIRTY-SIXTH COUNT:
accuses the defendants TETEE MORRISON and OPHELIA ALLEYNE, a/k/a
“PHILLY,” of the crime of CRIMINAL POSSESSION OF A FORGED
June 15, 2010, knowing the instrument to be forged and with intent to defraud,
THIRTY-SEVENTH COUNT:
accuses the defendants TETEE MORRISON and OPHELIA ALLEYNE, a/k/a
“PHILLY,” of the crime of GRAND LARCENY IN THE FOURTH DEGREE,
in violation of Penal Law §155.30(1) committed as follows:
The defendants, in the County of New York, on or about June 15, 2010,
dollars.
THIRTY-EIGHTH COUNT:
accuses the defendants ANTHONY HARPER, a/k/a “ANT,” and DARNELL
GIBBS, a/k/a “BUTTER LUV,” of the crime of CRIMINAL POSSESSION OF
A FORGED INSTRUMENT IN THE SECOND DEGREE, in violation of
July 10, 2010, knowing the instrument to be forged and with intent to defraud,
THIRTY-NINTH COUNT:
accuses the defendants TSAIQUAN IRBY-BACON, OPHELIA ALLEYNE,
a/k/a “PHILLY,” DARNELL GIBBS, a/k/a “BUTTER LUV,” ALI BILAL, a/k/a
“ACKII,” ISAAC BILAL, a/k/a “I.B.,” and RAHIM BILAL, a/k/a “MARLO,”
a/k/a “STARLO,” of the crime of CRIMINAL POSSESSION OF A FORGED
September 22, 2010, knowing the instrument to be forged and with intent to
FORTIETH COUNT:
accuses the defendants TSAIQUAN IRBY-BACON, OPHELIA ALLEYNE,
a/k/a “PHILLY,” DARNELL GIBBS, a/k/a “BUTTER LUV,” ALI BILAL, a/k/a
a/k/a “STARLO,” of the crime of GRAND LARCENY IN THE FOURTH
DEGREE, in violation of Penal Law §155.30(1) committed as follows:
The defendants, in the County of New York, on or about September 22,
thousand dollars.
FORTY-FIRST COUNT:
accuses the defendants ASHLEY PENNICOTT, OPHELIA ALLEYNE, a/k/a
“PHILLY,” DARNELL GIBBS, a/k/a “BUTTER LUV,” ALI BILAL, a/k/a
a/k/a “STARLO,” of the crime of CRIMINAL POSSESSION OF A FORGED
FORTY-SECOND COUNT:
accuses the defendants JAQUAN WRIGHT, ALI BILAL, a/k/a “ACKII,” ISAAC
BILAL, a/k/a “I.B.,” and RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO,” of
the crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN
THE SECOND DEGREE, in violation of Penal Law §170.25, committed as
follows:
FORTY-THIRD COUNT:
the crime of GRAND LARCENY IN THE THIRD DEGREE, in violation of
The defendants, in the County of New York, on or about September 24,
thousand dollars.
FORTY-FOURTH COUNT:
follows:
FORTY-FIFTH COUNT:
follows:
FORTY-SIXTH COUNT:
the crime of GRAND LARCENY IN THE FOURTH DEGREE, in violation of
Penal Law §155.30(1), committed as follows:
thousand dollars.
FORTY-SEVENTH COUNT:
follows:
FORTY-EIGHTH COUNT:
the crime of GRAND LARCENY IN THE THIRD DEGREE, in violation of
thousand dollars.

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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK

THE PEOPLE OF THE STATE OF NEW YORK

OPHELIA ALLEYNE, a/k/a “PHILLY,” INDICTMENT

THE GRAND JURY OF THE COUNTY OF NEW YORK, by this indictment,

“BLING,” JAMARA BENNETT, a/k/a “KILLZ,” SHANAYA BETHEA, a/k/a

TRASHAWN FRAILS, a/k/a “SPOT,” DARNELL GIBBS, a/k/a “BUTTER LUV,”

ANTHONY HARPER, a/k/a “ANT,” TSAIQUAN IRBY-BACON, TETEE

MORRISON, ASHLEY PENNICOTT, SHADU WAGNER and JAQUAN WRIGHT of

the crime of CONSPIRACY IN THE FOURTH DEGREE, in violation of Penal Law

§105.10(1), committed as follows:

crime of GRAND LARCENY IN THE SECOND DEGREE be performed, said crime

cause the performance of such conduct.

During the period of this conspiracy, the defendants engaged in conduct

constituting the crimes of identity theft, forgery, criminal possession of forged

avoiding detection by law enforcement. Defendants engaged in larcenies by obtaining

“oversea2bk@yahoo.com” to receive, send, and store stolen credit card information. It

defendants MARCUS ARTIS, a/k/a “BLING,” JAMARA BENNETT, a/k/a “KILLZ,”

SHANAYA BETHEA, a/k/a “NAYA,” DARNELL GIBBS, a/k/a “BUTTER LUV,”

ANTHONY HARPER, a/k/a “ANT,” TRASHAWN FRAILS, a/k/a “SPOT,” JAQUAN

cards, and clothing products.

Beginning in or about May of 2010, defendant SHAHEED BILAL, a/k/a “SHA,”

was incarcerated. Between in or about May of 2010 to in or about December of 2010, it

the operations of this conspiracy by communicating instructions via telephone to

card account information. Between in or about May of 2010 to in or about December of

RAHIM BILAL, a/k/a “MARLO,” a/k/a “STARLO,” DARNELL GIBBS, a/k/a

account “cakemixp@yahoo.com” to receive, send, and store stolen credit card

a/k/a “BUTTER LUV,” to use the email account “boyboutdat@yahoo.com” to receive,

defendant ANTHONY HARPER, a/k/a “ANT,” to use the email account

It was further a part of said conspiracy for defendants OPHELIA ALLEYNE,

of identity theft victims to create counterfeit credit cards.

It was further a part of said conspiracy for defendants OPHELIA ALLEYNE,

“NAYA,” TETEE MORRISON, ASHLEY PENNICOTT, TSAIQUAN IRBY-BACON,

OPHELIA ALLEYNE, a/k/a “PHILLY,” ANTHONY HARPER, a/k/a “ANT,” ISAAC

of this conspiracy for defendant GIL EINHORN to purchase fraudulently-obtained

merchandise for below retail value and re-sell it at a profit.

In or about December of 2010, SHAHEED BILAL was released from jail. In or

about December of 2010 SHAHEED BILAL resumed leadership of said conspiracy.

In furtherance of said conspiracy and to effect the objects thereof, from on or

others, were committed:

1. On or about May 7, 2009, SHAHEED BILAL, a/k/a “SHA,” possessed stolen

credit card numbers, in part and in substance including a Mastercard credit

card ending in 3040, in an email.

defendant DARNELL GIBBS, a/k/a “BUTTER LUV,” used forged

Mastercard credit card ending in 3040 to purchase merchandise costing

$1407.79, including a MacBook laptop computer, as directed by defendant

SHAHEED BILAL, a/k/a “SHA.”

possessed stolen credit card numbers, in part and in substance including a

Mastercard credit card ending in 5913, in an email.

store, defendant ANTHONY HARPER, a/k/a “ANT,” used forged Mastercard

credit card ending in 5913 to purchase merchandise costing $434.41,

including an iPod, as directed by defendant SHAHEED BILAL, a/k/a “SHA.”

5. On or about October 23, 2009, defendant SHAHEED BILAL, a/k/a “SHA,”

possessed stolen credit card numbers, in part and in substance including a

Visa credit card ending in 2215, in an email.

card ending in 2215 to purchase merchandise costing $868.82, including an

iPod, as directed by defendant SHAHEED BILAL, a/k/a “SHA.”

7. On or about October 25, 2009, defendant SHAHEED BILAL, a/k/a “SHA,”

possessed stolen credit card numbers, in part and in substance including a

card ending in 5311 to purchase merchandise costing $1632.04, including a

MacBook laptop computer, as directed by defendant SHAHEED BILAL,

credit card ending in 5311 to purchase merchandise costing $1632.04,

including a MacBook laptop computer, as directed by defendant SHAHEED