UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF OHIO

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UNITED STATES OF AMERICA

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ANDREY SHUKLIN,

 

 Defendant.

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 18 Cr. 109 (DRC)

 

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GOVERNMENT’S SENTENCING MEMORANDUM

The defendant was the leader of a criminal enterprise that used a series of moving 

companies to exploit thousands of people across the county by demanding ransom for the personal 

possessions and cherished belongings those people had entrusted the enterprise to transport. For 

the reasons outlined, a Guidelines sentence of 97 to 121 months’ imprisonment is appropriate.

BACKGROUND

I. The Offense Conduct

A. Background on Moving Regulations

The U.S. Department of Transportation (“USDOT”), Federal Motor Carrier Safety 

Administration (“FMCSA”), monitors and enforces regulations governing safety and commerce 

for interstate motor carriers. A portion of the regulations governs the transportation of household 

goods by licensed motor carriers (i.e., moving companies). See 49 C.F.R. Part 375. All household 

goods motor carriers engaged in interstate transportation of household goods must follow the 

regulations. 49 C.F.R. 375.101. Failure to comply with these regulations could result in the 

USDOT ordering the company to cease operating as a mover of household goods.

Interstate movers must also register with the USDOT. In order for a moving company to 

be registered with the USDOT, the moving company must apply to operate as a motor property 

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carrier and receive a USDOT number. The USDOT number is a unique identifier used to monitor 

a company’s safety information acquired during audits, compliance reviews, crash investigations, 

and inspections. A moving company may not lawfully transport household goods without an 

approved USDOT number. During the relevant period, the application to operate as mover of 

household good was known as an OP-1 form, or later, Form MCSA-1, and was available through 

FMCSA. On the OP-1 and MCSA-1 forms, all applicants must disclose, under penalty of perjury, 

any relationship with any other FMCSA-regulated entity within the past three years, including any 

ownership interests or management positions. 

Under those regulations, carriers must provide all moving estimates for household goods 

to potential customers in writing and must indicate clearly whether the estimate is binding or nonbinding. 49 C.F.R. 375.401. With a binding estimate, the customer and the moving company must 

both agree in writing to a fixed charge for all services prior to the start of any work. 49 C.F.R. 

375.403. The moving company may re-negotiate the contract with the customer if the moving 

company believes after an on-site inspection that the weight of the actual shipment significantly 

exceeds the original estimate, but this re-negotiation must be done before any work is commenced 

and with the customer’s full consent and knowledge. 49 C.F.R. 375.403. The moving company 

is expressly barred under the regulations from amending the estimate after loading the shipment. 

49 C.F.R. 375.401. Failure to deliver a customer’s shipment upon the customer’s offer to pay the 

binding estimate amount (plus additional charges not relevant here) constitutes a failure to 

transport a shipment with “reasonable dispatch” under the regulations and subjects the moving 

company to “cargo delay claims.” 49 C.F.R. 375.403. 

Pursuant to federal regulations, movers must deliver household goods “in a timely 

manner.” 49 C.F.R. 375.601. Unless the requirement is waived, movers “must tender a shipment 

for delivery for an individual shipper on the agreed delivery date or within the period specified on 

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the bill of lading.” 49 C.F.R. 375.603. 

Moving companies must follow the regulations and allow for regular inspections by federal 

regulators. Failure to meet the requirements set by USDOT can result in a moving company being 

placed out of service. A company placed out of service is no longer authorized under federal law 

to operate as a mover of household goods. 

B. The Enterprise

The charged criminal enterprise, led by the defendant, flouted these regulations. In doing 

so, over the course of five years, the criminal enterprise presented itself as at least 12 different 

moving companies,1 and profited from the exploitation and manipulation of thousands of victims. 

(See Presentence Report (“PSR”) ¶¶ 31-41, 52). Those victims hired the enterprise to move them, 

based on false representations and assurances by the enterprise members, as well as federal 

certifications obtained through fraud. (See id. ¶ 52). The enterprise lured victims into binding 

contracts, containing square footage estimates that were purposefully low. (See id. ¶¶ 48-49). The 

enterprise then extorted the victims into paying more than contracted for based both on falsely 

inflated square footage numbers, but also by capturing the victims’ goods on moving trucks before 

increasing the price for the moves. (Id. ¶ 48-49). The enterprise then either delivered the goods 

late, or never delivered them at all. (See id. ¶ 44).

Whenever the aftermath of their crimes became too complicated and messy, the enterprise 

simply shed its skin and reincorporated as a new entity, with lies on their websites and documents 

1 The companies, with their authorized operation dates, are: JBR Underground doing business as 

United National Moving and Storage (2008 – 2015); National Relocation Solutions (2014 –

2015); Independent Van Lines (2014 – 2015); National Relocation Van Lines (2014 – 2015); US 

Relocation Systems (2015 – 2016); First National Moving and Storage (2016); Public Moving 

and Storage (2016 – 2017); Public Moving Services (2017); Smart Relocation Solutions a/k/a 

Presidential Moving Services (2017 – 2018); Unified Van Lines (2017 – 2018); and Flagship 

Van Lines (2018). (PSR ¶¶ 31-41).

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about their experience, and lies on their federal forms about ownership and accountability. (See 

id. ¶¶ 30, 47; Indictment at 7-9). They shielded their members by assigning them new names, and 

abandoning the phones and contact information of their tainted prior form. (See Indictment at 8; 

alias list examples attached as Exhibit 1 (listing “aliases,” new phone numbers, and new emails

for employees)).

The completeness of their frauds, the thoroughness of their lies, enriched the enterprise 

handsomely. The conservative loss amount in this case is over $2.4 million. (PSR ¶ 52).

C. The Defendant’s Role

The defendant was one of two leaders of the corrupt moving enterprise. He was in charge 

from the beginning of the conspiracy to its takedown in this case. He, more than anyone else, 

enjoyed the financial spoils of the complex fraud, spending money straight out of the corporate 

bank account on himself. 

He was not a hapless émigré, presented as the front of the company against his will. He 

was one of the bosses running the enterprise. He was one of the select few within the company 

who received hundreds of emails showing the real cubes (i.e., the actual space a customer’s goods 

used during a move) versus the fraudulent, inflated cubes charged to customers. (See examples of 

emails attached as Exhibit 2). He signed the lease for the Florida headquarters of the moving 

enterprise as the Manager. (See lease attached as Exhibit 3). He provided approval of the text that 

appeared on the websites and the press releases. He even contributed some of the false statements. 

For example, in 2017, the defendant sent an email of his edits to a press release for Presidential 

Moving Services, which included adding the false statements that “[t]he company has been 

operating on the market for 20 years” and “[f]or all these years the company has adhered to the 

principles of ‘everything for the customer’ and has a huge number of happy customers!” and 

asserting they had professional crews with “at least 5 years experience[.]” (See examples from 

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websites attached as Exhibit 4 at 4). 

He also repeatedly lied to federal agents and regulators from the Department of 

Transportation about the moving enterprise and his role. This included his efforts “reincarnating” 

into “new companies” through fraud during the time he was the owner, with its main office where 

the defendant worked in Hollywood, Florida. (Plea Agreement at 7-8). When one entity was 

placed out of service by USDOT, the defendant and the enterprise simply started a new company 

under the name of a fake owner and registering the new company in a different state, with listed 

business locations in Ohio, Maryland, North Carolina, Illinois, Texas, California, Connecticut, 

Colorado, and Missouri. (PSR ¶ 47). 

The defendant, along with Serghei Verlan, made new profiles on their moving software 

program with specific jobs prior to compliance reviews by regulators. The new profiles displayed 

a limited number of moving jobs to hide the complete list from the regulators. Then, on June 1, 

2017, during execution of a search warrant of the Florida headquarters of the moving enterprise, 

the defendant claimed, among other lies, that Public Moving Services was owned by Alexis Pistun, 

and Public Moving and Storage was owned by Evgenia Zershcikova (both of whom had fake IDs 

generated for them by members of the enterprise, and transmitted by the defendant). (Interview 

attached as Exhibit 5; see examples of fake IDs attached as Exhibit 6).

Damning in its own right, the fraudulent moves and reincarnations of the moving enterprise 

continued after the interview and search warrant. The defendant made no effort to stop it and no 

effort to walk away. Instead, he continued running the corrupt enterprise and spending the 

proceeds. 

The defendant and his partner Serghei Verlan directed the multi-state, multi-year fraud and 

benefitted handsomely while thousands of victims suffered irreparable harm. The defendant and 

Verlan are the most culpable members of this criminal organization.

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II. The Defendant’s Plea and Guidelines Range

The defendant pleaded guilty before this Court on January 25, 2021. 

Probation has calculated the defendant’s Guideline range as follows (see id. ¶¶ 58-73): 

Count One: 18 U.S.C. § 1962(d) – RICO Conspiracy

• The United States Sentencing Commission Guidelines Manual (“U.S.S.G.”), effective 

Nov. 1, 2018, applies to this conduct.

• Pursuant to U.S.S.G. § 2E1.1, the base offense level is either 19, or the offense level 

applicable to the underlying racketeering activity, whichever is higher. Pursuant to 

U.S.S.G. § 2E1.1, Application Note 1, such determination is made by applying Chapter 3 

Parts A, B, C, and D.

• The underlying racketeering activity applicable to the defendant is wire fraud, which is 

governed by U.S.S.G. § 2B1.1. Pursuant to § 2B1.1(a)(1), the base offense level is 7, 

because wire fraud has a statutory maximum penalty of 20 years’ imprisonment.

• Pursuant to U.S.S.G. § 2B1.1(b)(1), because the loss exceeded $1,500,000, and was less 

than $3,500,000, 16 levels are added.

• Pursuant to U.S.S.G. § 2B1.1(b)(2), because the offense involved 10 or more victims, 2 

levels are added. 

• Pursuant to U.S.S.G. § 2B1.1(b)(10)(C), because the scheme involved sophisticated means, 

two levels are added.

• Pursuant to U.S.S.G. § 2B1.1(b)(11)(B)(ii), because the offense involved the production or 

trafficking of any authentication feature, two levels are added.

• Pursuant to U.S.S.G. § 3B1.1(a), because the defendant was a leader or organizer of a 

criminal activity that involved five or more participants, or was otherwise extensive, four 

levels are added.

• The USAO does not oppose a two-level reduction in offense level pursuant to U.S.S.G. § 

3E1.1 based upon the defendant’s acceptance of responsibility, provided that the 

defendant’s conduct continues to demonstrate compliance with the terms of § 3E1.1. The 

defendant may be entitled to an additional one-level decrease pursuant to § 3E1.1(b) in 

recognition of the defendant’s timely notification of his intention to plead guilty.

In accordance with the above, Probation calculated the total offense level at 30. PSR ¶ 73. 

Probation calculated the defendant’s criminal history as I. Id. ¶ 78. The defendant’s Guideline 

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range then is 97 to 121 months’ imprisonment. (Id. ¶ 92). The Government agrees with 

Probation’s Guidelines calculation. 

DISCUSSION

III. The Contested Enhancements Apply to the Defendant

The defendant has challenged numerous facts in the PSR, as well as the application of 

three Guideline enhancements that the Government and Probation believe apply to the 

defendant’s conduct. 

At bottom, the defendant misapprehends his responsibility as a conspirator in a corrupt 

enterprise. The Guidelines direct that a defendant who participated in “a criminal plan, scheme, 

endeavor, or enterprise undertaken by the defendant in concert with others, whether or not 

charged as conspiracy” is responsible for “all acts and omissions of others that were—(i) within 

the scope of the jointly undertaken criminal activity, (ii) in furtherance of that criminal activity, 

and (iii) reasonably foreseeable in connection with that criminal activity[.]” U.S.S.G. § 

1B1.3(a)(1)(B). The commentary explains that “[i]n order to determine the defendant’s 

accountability for the conduct of others under [the subsection], the court must first determine the 

scope of the criminal activity the particular defendant agreed to jointly undertake (i.e., the scope 

of the specific conduct and objectives embraced by the defendant’s agreement). In doing so, the 

court may consider any explicit agreement or implicit agreement fairly inferred from the conduct 

of the defendant and others.” U.S.S.G. § 1B1.3 comment. (n.(3)(B)). This means that a 

defendant may be “potentially liable for the foreseeable criminal acts of others in furtherance of 

the criminal enterprise even though he did not personally participate in them.” United States v. 

Tocco, 200 F.3d 401, 430 (6th Cir. 2000) (quoting United States v. Carrozza, 4 F.3d 70, 75 (1st 

Cir. 1993) (indicia of alteration omitted)).

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The defendant’s repeated assertions that he did not personally and directly participate in 

various facets of this complex fraud carry little practical weight at this sentencing stage. The 

question for this Court is not whether the defendant himself used Photoshop to make a fake 

license, or himself entered the false address on the moving company website, or micromanaged 

every decision made by every employee, but instead were the particular criminal acts of the 

moving enterprise within the scope of the defendant’s agreement, in furtherance of the criminal 

activity, and reasonably foreseeable to the defendant. Evaluating each of the challenged 

enhancements in turn under this guidance establishes that all of the challenged enhancements 

apply to the defendant.

2

A. The Defendant’s Scheme Involved Sophisticated Means

The defendant claims that “he did not relocate or participate in the relocation of the 

scheme to another jurisdiction to evade law enforcement or regulatory officials” and, regardless, 

argues that “this conduct does not constitute sophisticated means.” (PSR Addendum at 27).

Starting with the second assertion, the defendant is wrong. Under the applicable 

guideline: 

If (A) the defendant relocated, or participated in relocating, a fraudulent 

scheme to another jurisdiction to evade law enforcement or regulatory 

officials; (B) a substantial part of a fraudulent scheme was committed from 

outside the United States; or (C) the offense otherwise involved 

sophisticated means and the defendant intentionally engaged in or caused 

the conduct constituting sophisticated means, increase [the offense level] by 

2 levels.

U.S.S.G. § 2B1.1(b)(10)(C). The Guidelines define “sophisticated means” as “especially 

complex or especially intricate offense conduct pertaining to the execution or concealment of an 

offense,” listing as examples, “locating the main office of the scheme in one jurisdiction but 

2 In addition to the evidence presented here, the Government is prepared to offer witness 

testimony at the sentencing hearing in support of the enhancements.

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locating soliciting operations in another jurisdiction” and “use of fictitious entities, corporate 

shells.” U.S.S.G. § 2B1.1, comment. (n.9).

As to the defendant’s first protestation, he did in fact relocate or participate in relocating 

the corrupt moving enterprise to avoid Department of Transportation scrutiny and furthered the 

enterprise through sophisticated means. As he admitted in his plea, the moving enterprise 

“reincarnated into numerous ‘new companies’ through fraud during the time [the defendant] was 

an owner and worker” for the moving enterprise, and each of these reincarnated entities 

controlled by the enterprise listed addresses in other states throughout the country. (Plea 

Agreement Statement of Facts at 8; PSR ¶ 47 (listing 10 different states out of which the 

reincarnated companies purported to operate)). The enterprise furthered this aim by listing fake 

owners on USDOT documents and registering the new entities in different states, “concealing the 

true owners, operators, employees, and operations of the affiliated companies of the Moving 

Enterprise.” (Plea Agreement Statement of Facts at 7). As the defendant further admitted, this 

fraudulent reincarnation involved “materially false statements to federal regulators,” lies to

customers and third parties, and fraudulent reincarnation occurring “during the time [the 

defendant] was an owner and worker for the Moving Enterprise.” (Id. at 7–8.)

In fact, the reincarnation scheme was in place from the very beginning. The defendant 

and Serghei Verlan purchased the moving company JBR Underground in 2013, with the 

defendant listing himself as the owner on a form filed with DOT. (See ownership documents 

attached as Exhibit 7). The company began doing business under the name United National 

Moving & Storage. Beginning that same year, customers began filing complaints to the FMSCA 

about the company increasing costs for moves above the binding estimate after household goods 

were loaded on the moving truck. 

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FMCSA ordered JBR Underground to cease operating as a household goods carrier and 

placed the company out of service in September of 2015 for failing to pay a penalty assessed 

because the company failed to allow FMCSA personnel to conduct an inspection. 

But by the time JBR Underground was ordered out of service, the moving enterprise had 

already reincarnated as a new entity. In April of 2014—less than six months after the defendant 

took over as the sole owner of JBR Underground—National Relocation Solutions submitted a 

trade name application to Maryland stating that JBR Underground was the full legal name of the 

corporation using the trade name National Relocation Solutions. (See Exhibit 7). That 

application was signed by the defendant as the “Managing Owner” of JBR Underground. In 

June of 2014, before JBR Underground was placed out of service, the defendant filed an OP-1 

form with FMCSA for National Relocation Solutions, certifying under penalty of perjury that he 

did not have any relationship with any other FMCSA-regulated entity within the past three years 

(despite his previous filings as the owner of JBR Underground). (See id.).

Later in 2014, the defendant again submitted an OP-1 form, this time for Independent 

Van Lines, listing himself as the owner and again certifying he had no relationship with any 

other FMCSA-regulated entity within the past three years. (See id.). The defendant admitted 

later to federal agents that he set up Independent Van Lines in order to get a mortgage. 

From there, the iterations of the moving enterprise continued to proliferate, with members 

of the enterprise creating new entities typically a few months before a previous entity was placed 

out of service. After initially appearing on the forms, the defendant and Verlan listed other 

individuals on the ownership documents sent to the regulators—as detailed below—the names 

becoming more obscure as the multi-year fraud continued. 

Throughout the run of the enterprise, while the companies changed names and lied about 

ownership on regulatory forms, the defendant remained one of the few signatories on the various 

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bank accounts. The account names themselves stand as evidence of the reincarnation scheme; 

for example, the defendant and Verlan were the authorized signers of a JPMorgan Chase account 

named “Olympus A&S LLC DBA Public Moving and Storage/President A&S DBA Presidential 

Moving Services.” (Examples of bank records attached as Exhibit 8). The defendant was the 

signatory on Wells Fargo accounts for Olympus A&S, Independent Van Lines, and National 

Relocation Solutions. (Id.). The defendant and his wife were the signatories on a Bank of 

America account called “Moving National Solutions LLC DBA Public Moving and Storage.” 

(Id.). The defendant used the various business bank accounts for his own personal expenses 

throughout the course of the enterprise. (See id.). These accounts received payments from

customers who hired the fraudulently reincarnated affiliated entities.

In September 2015, the defendant signed a lease in the Hollywood, Florida location of the 

government’s premises search warrants in June 2017 and August 2018. (See Exhibit 3). The 

defendant signed the lease as “manager” of National Relocation Solutions; his co-leader Verlan 

also signed the lease as “guarantor.” (Id.). Search warrants at these locations contained files for 

all of the affiliated entities—registered with the USDOT as operating in other states—along with 

records from customers who were fraudulently overcharged from all of these entities. 

If these reincarnations were not intended to avoid Department of Transportation scrutiny, 

why the repeated misrepresentations on the forms submitted to the Department? Why the false 

certifications and the fake owner names? There is no plausible explanation other than an effort 

to avoid regulatory and law enforcement attention on the relationships between the entities shut 

down for abuses and the new entities created to continue the fraud. In any case, this multi-year 

fraud involving fictitious entities and misrepresentations to federal regulators, customers, and 

third parties utilized precisely the type of sophisticated means contemplated by the enhancement. 

Probation was correct that the enhancement applies.

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B. The Defendant’s Offense Involved the Production or Trafficking of an 

Authentication Feature

The defendant asserts that “he did not alter state issued driver’s licenses.” (PSR 

Addendum at 28). But, as previously explained, the defendant’s personal involvement in the 

alteration of authentication features is not required for this enhancement to apply. Under the 

relevant Guideline, two levels are added to the offense level if the offense “involved . . . the 

production or trafficking of any . . . authentication feature[.]” U.S.S.G. § 2B1.1(b)(11)(B)(ii). 

It is hard for the defendant to argue credibly that the use of the fake IDs were somehow 

beyond the scope of his agreement, not in furtherance of the moving enterprise’s scheme, or not 

foreseeable to him. He was directly involved in transmitting the fake IDs. For example, on 

April 18, 2017, the defendant received a copy of a fake ID to his email. (See Exhibit 6). The ID 

was purportedly a Florida driver’s license and credit card for “Alexey Pistun,” the man the 

moving enterprise was claiming was the owner of the reincarnated companies, Public Moving 

Services. (Id.). The defendant forwarded the ID from to the other leader of the enterprise, 

Serghei Verlan. (Id.). 

Another fake ID used in the conspiracy was a doctored Florida driver’s license that 

displayed a photograph of the defendant’s wife—Tatianna Rakhmaninova—presented to a 

company that provided moving job leads. (Id.; see PSR ¶ 94). Like the other fake driver’s 

licenses created to hide the true ownership, documents received from the Florida Department of 

Motor Vehicles concluded that the driver’s license with the photo of the defendant’s wife but in 

the name of a fake owner of the company was fraudulent. (Exhibit 6). The defendant would be 

hard-pressed to pretend he did not know that his wife’s picture appeared on a driver’s license that 

had a different name, which was then submitted to an entity that provided leads for his company.

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Probation was correct that the enhancement applies and the defendant’s objection should 

be overruled.

C. The Defendant was an Organizer or Leader of the Moving Enterprise

The defendant objects to the application of the organizer or leader enhancement with a 

series of excuses including that his “role changed over time” and that he “took responsibility in 

limited areas,” but “did not have a leadership role in training, directing, or supervising 

employees who were traveling to customer homes to load customer goods.” (Def. Letter to 

Probation at 1-2 (March 17, 2021)). 

Even assuming this recitation of the facts is accurate, they are not dispositive. Under the 

Guidelines, a defendant who was “an organizer or leader of a criminal activity that involved five 

or more participants or was otherwise extensive,” receives an offense level increase of four 

levels. When considering whether a defendant was an organizer or leader, the Guidelines 

provide the following suggestions: 

Factors the court should consider include the exercise of decision making 

authority, the nature of participation in the commission of the offense, the 

recruitment of accomplices, the claimed right to a larger share of the fruits 

of the crime, the degree of participation in planning or organizing the 

offense, the nature and scope of the illegal activity, and the degree of control 

and authority exercised over others. There can, of course, be more than one 

person who qualifies as a leader or organizer of a criminal association or 

conspiracy. 

U.S.S.G. § 3B1.1 comment. (n.4). The defendant need not meet all the criteria nor be the “brains 

behind the operation” in order for the enhancement to apply. United States v. Sexton, 894 F.3d 

787, 795-96 (6th Cir. 2018). 

As previously explained, the defendant certified he was the owner of multiple entities of 

the moving enterprise, during which the enterprise fraudulently reincarnated into affiliated 

companies. (Plea Agreement Statement of Facts at 7-8). Even after he began hiding the true 

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ownership of the iterations, he remained one of the three signatories on the various business bank 

accounts – the others being the defendant’s wife and Verlan. (See Exhibit 8). For the length of 

the criminal conspiracy, the defendant spent money on himself and his wife directly from the 

various business bank accounts. (See id.).

The defendant not only profited handsomely from the scheme, but he was involved in the 

day-to-day operations of the enterprise. He personally received numerous emails from moving 

enterprise employees attaching customer documents with the inflated cubic footage charged, and 

also detailing the real cubic footage. (See, e.g., Exhibit 2). It was not an occasional occurrence –

it happened throughout the course of the entire conspiracy. 

Despite fraudulent ownership documents provided to the USDOT, the defendant also 

represented he actually owned the reincarnated companies. For example:

• U.S. Relocations Systems listed co-defendant Phyllis Quincoces as owner on 

USDOT filings (while certifying no prior affiliation with a USDOT registered 

moving company), while Shuklin was listed as the owner in Florida Secretary of 

State filings. (Exhibit 7 at 8, 10).

• First National Moving and Storage listed Evgenia Prus (the identity on a fake 

driver’s license, as set forth above) on USDOT filings, while Shuklin was listed 

as the owner in Florida Secretary of State filings. (Id. at 11-12).

• Public Moving and Storage listed Evgenia Zershcikova (the identity on a fake 

driver’s license, as set forth above) on USDOT filings, while Shuklin was listed 

as the owner in Florida Secretary of State filings. (Id. at 13-14).

• Public Moving Services listed Alexei Pistun Sr. (the identity on a fake driver’s 

license, as set forth above) on USDOT filings, while Shuklin was listed as the 

organizer in North Carolina Secretary of State filings. (Id. at 15-16).

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These are just examples of the documentary evidence that the defendant owned and controlled all

of the affiliated entities. Indeed, evidence seized during the premises search warrants at the 

Hollywood, Florida business location in 2017 and 2018 included records for all of the 

reincarnated companies, with files for customers from each entity, showing the defendant 

remained in charge of all of the affiliated companies, throughout the five-year period of 

operation.

Probation’s application of the four-level leadership enhancement was therefore proper. 

IV. The Defendant’s Conduct Warrants a Guidelines Sentence

The factors that the Court must consider when fashioning a sentence include the nature and 

circumstances of the offense, the need for the sentence to reflect the seriousness of the defendant’s 

offense, the promotion of respect for the law, the need for just punishment for the offense, and the 

need for adequate deterrence. See 18 U.S.C. § 3553(a)(2). All such considerations support a 

Guidelines sentence of incarceration between 97 and 121 months for the defendant’s crimes.

A. The Defendant’s Crimes Harmed Myriad Victims

The nature and circumstances of this offense are serious. Over the course of five years, the 

defendant and his criminal enterprise defrauded and exploited thousands of victims.3 The victims 

vary in age, status, employment, and numerous other metrics, but are united in one simple way –

they all were trying to move safely and efficiently their most precious, personal possessions from 

one home to another. They were seeking new refuge, whether it was down the street or across the 

country, and they entrusted the members of the criminal enterprise to help them reach it. 

The victims were not naïve in hiring the enterprise; it was the enterprise that ruthlessly 

manipulated the means through which even the most diligent customer would seek to investigate 

3 The victim impact statements that have been received by the Government have been provided 

to Probation.

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them before hiring. If victims went to the affiliate companies’ websites, they would see false 

declarations, like the newly-formed company was celebrating its 20th anniversary. (See Exhibit 

4). If the victims went to review websites, they would read glowing missives penned by the 

criminals themselves, describing how “great” and “professional” the company was. Even if the 

victims went to the U.S. Department of Transportation, they would find USDOT numbers for the 

affiliated companies, acquired through misrepresentations and lies. 

After doing their research, the victims were then drawn in by promises of low rates and 

prompt deliveries. They booked binding estimates, which were supposed to be just that. They 

relied on the members of the enterprise, not knowing the people they were speaking to in the sales 

office were using fake names, and the numbers they were calling would one day just stop working, 

the repeated rings ignored by the same people who were offering false assurances. (See Exhibit 

1).

After signing the contracts, the victims then made plans, dependent on their belief that the 

criminal enterprise would do what it claimed it would do. The victims purchased homes, signed 

leases, made arrangements with employers, babysitters, family members. They prepared 

themselves for the stresses and challenges that come from even the most efficient and fair moves.

On the day of the victims’ appointed moves, members of the criminal enterprise came into 

their homes, boxed up their most personal and cherished possessions, and loaded them up on 

trucks. Then they changed the deal. They claimed the loads were bigger than they were. They 

claimed the square footage was off. They demanded payment upfront, and signatures on 

documents falsely asserting that any change had been agreed to prior to loading. They threatened 

to unload, or not deliver, the victims’ possessions.

What were the victims to do then? They stared into loaded trucks containing their 

“household goods,” terms of art that contain much more than those words suggest. Household 

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goods in this case means diplomas, baby books, irreplaceable family heirlooms, even relatives’ 

ashes. In those moments when the victims were at their most vulnerable, they agreed to whatever 

they needed to in a sometimes vain attempt to keep hold of those items that enriched and 

documented their lives. 

Some of those victims received their goods, after paying more than they should have. Some 

of those victims never did, left to seek reimbursement for items that can never be replaced, whose 

value can never be calculated in simple dollars. 

After all this, those victims then had to rebuild their lives in their new home, knowing they 

had been defrauded in their most vulnerable moment, held hostage by an enterprise that viewed 

such violations as a business model. 

These tragedies played out again and again and again. By the case agent’s calculation, 

approximately 90% of moves conducted by the enterprise and subject to the agent’s analysis were 

fraudulent. (See PSR ¶ 52). With deception this pervasive, the members of the enterprise all knew 

what was going on. Together, they profited off of the exploitation of thousands of people. And 

they did it over multiple years.

The defendant was the head of this enterprise. He knew what was happening, and he 

directed it. He financially benefitted more than any other member of the enterprise, spending 

money on himself straight out of the corporate bank accounts. The enterprise operated under his 

leadership and for his benefit. 

B. The History and Characteristics of the Defendant Support a Guidelines Sentence

The defendant is an educated man. The defendant—described by his wife as a “very 

intelligent person”—received a college and advanced degree in law in his native Russia. (PSR ¶¶ 

116-17, 119). He began a PhD program in economics, which he did not finish because he came 

to the United States to seek asylum. (Id. ¶ 117). He is smart enough to understand and execute

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the scheme he led. 

He is also smart enough to succeed without taking advantage of thousands of people. He 

came to the United States to seek asylum, trying to get the safety and opportunity he could not in 

Russia. (See id. ¶¶ 83, 102, 117). But instead of applying his intelligence and education to 

legitimate work, he instead spent years abusing and extorting the citizens of his chosen country, 

profiting from them at their most vulnerable. 

He has demonstrated through his multi-year leadership of the criminal organization—and, 

frankly, the nature of his objections to the PSR—that he does not feel remorse for what he did, he 

does not register the depth of suffering he caused, and he does not accept the level of responsibility 

he should. The defendant deserves a Guidelines sentence.

C. A Guidelines Sentence Deters Other Bad Actors in the Moving Industry

The criminal enterprise defrauded customers in a way the FMCSA labels “common” within 

the moving industry.4 A June 2020 study conducted by the Better Business Bureau reported that 

FMCSA received 4,780 complaints related to moving companies in 2019.5 The Better Business 

Bureau reported “[a]t least 1,335 moving companies have earned an ‘F’ rating from BBB due to 

unresolved or unanswered complaints, unusually large amounts of complaints, and other factors.” 

In their estimation, “[t]he general public is at serious risk of encountering a dishonest moving 

4 FMCSA, “File a Moving Fraud Complaint,” available at: https://www.fmcsa.dot.gov/protectyour-move/file-a-complaint (“There are many kinds of moving fraud. One of the most common

is when a ‘rogue’ mover provides a low cost quote to perform an interstate move, loads your goods 

onto their truck, and then claims your load is over the weight estimate and the additional weight 

will be charged at an exorbitant price per pound. Consumers are forced to pay double or higher 

the original estimate just to get their belongings back.”).

5 BBB, “Know Your Mover,” available at: https://www.bbb.org/globalassets/local-bbbs/council113/media/scam-studies/bbb-movers-scam-study.pdf. 

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operation[.]” 

Only meaningful penalties will possibly deter the numerous bad actors in the moving 

industry. Only serious consequences will possibly prevent fraudsters from preying on a large and 

particularly vulnerable population. Only a term of incarceration will possibly convince other 

corrupt movers to operate in accordance with the federal regulations designed to protect the 

millions of Americans who move each year. 

The need for deterrence and to promote respect for the law supports a Guidelines sentence, 

particularly for the leader of the multi-year criminal enterprise that victimized thousands of people.

CONCLUSION

For the reasons set forth above, the Government respectfully submits that a Guidelines 

sentence in this case is appropriate.

Dated: Cincinnati, Ohio

May 4, 2022

Respectfully submitted,

KENNETH L. PARKER

United States Attorney

s/Megan Gaffney Painter

MATTHEW C. SINGER

MEGAN GAFFNEY PAINTER

Assistant United States Attorneys

221 East Fourth Street, Suite 400

Cincinnati, Ohio 45202

(513) 684-3711

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CERTIFICATE OF SERVICE

The undersigned attorney, duly admitted to represent the United States before this Court, 

hereby certifies that on the below date, she caused the Government’s Sentencing Memorandum to

be served on counsel for the defendant electronically.

Dated: Cincinnati, Ohio

May 5, 2022

Respectfully submitted,

/s/Megan Gaffney Painter_______

Megan Gaffney Painter

Assistant United States Attorney

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