10. In an effort to further corroborate the
information provided by the CS, I have reviewed bank records for
a b a n k account- in the name of QAT
Consulting Group, Inc. (the "First QAT Account"). According to
the bank records, in 2006, the CS in fact received a check for
more than $1,000 from the First QAT Account. As discussed in
further detail below, the defendants have directed clients of the
Emperors Club to make payments for prostitution services to the
and also to a second bank account a t bank
accountQA-in the name of QAT International, Inc. (the
First
"Second QAT Account" ) .
C. The Undercover
11. In the course of this investigation, I have worked
with an agent acting in an undercover capacity (the
"Undercover"). The Undercover posed as a potential client of the
Emperors Club prostitution business, and made arrangements over
the telephone with TEMEKA RACHELLE LEWIS, a/k/a "Rachelle, " the
defendant, for an appointment with an Emperors Club prostitute.
He then coordinated over e-mail with CECIL SUWAL, a/k/a 'Katie,"
a/k/a "Kate," the defendant, to make a deposit of more than
$1,000 towards the appointment in the Second QAT Account.
12. The Undercover initially went on the Internet and
accessed a website located at URL www.emperorsclubvip.com. (the
"Website"). The Website included photographs of Emperors Club
prostitutes' bodies, with their faces hidden, along with hourly
rates for different categories of prostitutes. The Website
ranked the prostitutes using a ranking system from one to seven
diamonds, and charged hourly rates according to the assigned
ranking. For example, according to the Website, the Emperors
Club charged $1,000 per hour for a three-diamond prostitute, and
$3,100 per hour for a seven-diamond prostitute. The Website
offered the Emperors Club's most valued clients 'membership" in
the 'Icon Club," a status which allowed the clients to access
restricted areas of the Website and permitted them to schedule
appointments for illegal prostitution services with the most
highly-ranked prostitutes whose fees started at $5,500 per hour.
According to the Website, in certain circumstances, the Emperors
Club also offered its clients the opportunity to exercise a "buy-
out clause," which permitted them to purchase direct access to
one of the Emperors Club's prostitutes without having to contact
the agency. The Website listed (212) 812-2114 (the "2114
Number") as one of the numbers for clients to use to contact the
Emperors Club.
13. On or about October 20, 2007, at approximately
9:30 p.m., the Undercover placed a call to the 2114 Number, which
I have determined from toll records was forwarded to a cellular
telephone assigned call number 6 5 8 7 (the "6587
Number"). The call was answered by TEMEKA RACHELLE LEWIS, a/k/a
"Rachelle," the defendant.' During the conversation, the
Undercover and LEWIS discussed an appointment the Undercover
wanted to arrange for October 25, 2007. The Undercover explained
that he was hoping to have a "good night" for himself. LEWIS
asked the Undercover which particular woman he wanted to see, to
which the Undercover responded that all the women on the Website
were 'beautiful." The Undercover requested an appointment with
"Helena" -one of the women depicted on the Website -but LEWIS
told him that "Helena" was "based in London." The Undercover
then asked for an appointment with "Drew," to which LEWIS
4
As discussed below, I have determined that telephone
calls placed to the 2114 Number were typically forwarded to
various cellular telephones used by CECIL SUWAL, a/k/a 'Katie,"
a/k/a "Kate," TEMEKA RACHELLE LEWIS, a/k/a "Rachelle," and TANYA
HOLLANDER, a/k/a "Tania Hollander, " the defendants.
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