UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF OHIO

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UNITED STATES OF AMERICA

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SERGHEI VERLAN, 

 

 Defendant.

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 Case No.: 1:18-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 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 

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

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”) ¶¶ 22–33, 38, 39). 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. ¶ 38). The enterprise lured victims into binding 

contracts, containing square footage estimates that were purposefully low, and then revised 

contracts upward during the move. (Change of Plea Hearing, Doc. 268, PageID 1868–70.) 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. (PSR ¶ 40–41). 

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 ¶¶ 22-32).

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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 

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

id. ¶ 38; 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; 

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 ¶ 45). 

C. The Defendant’s Role

The defendant was one of the two bosses running the enterprise. (Doc. 268, PageID 1852–

53.) He ran the enterprise with Andrey Shuklin principally out of the headquarters in Hollywood, 

Florida; however, the enterprise managed warehouses throughout the United States, including in 

the Southern District of Ohio. (Doc. 268, PageID 1853–54.) The defendant’s name was on bank 

account and financial information, he controlled money into the enterprise, and he received 

documents and emails relating to the crimes set forth in the Indictment. (PSR ¶ 42.) Along with 

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

corporate bank account on himself. (Id. ¶ 42; Doc. 268, PageID 1855.) 

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. (Doc. 268, PageID 1858–

59, 1866.) 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 registered the new company in 

a different state, with listed business locations in Ohio, Maryland, North Carolina, Illinois, Texas, 

California, Connecticut, Colorado, and Missouri. (PSR ¶ 39; Doc. 268, PageID 1859, 1866). 

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He knew it was part of the scheme to give customers an “unprofitable rate” on the front 

end to induce them to hire the company and then increase the price through fraud during the move. 

(Doc. 268, PageID 1872.) The defendant incentivized the fraudulent overcharging of customers 

by tying the foreman’s compensation to the amount of cubic feet charged by the enterprise. (Id. 

at PageID 1868.) He knew that employees of the enterprise justified new charges to customers by 

purposefully packing the truck to make it appear that the customer’s goods took up more space 

than was actually being used. (Doc. 268, PageID 1869.) This defrauded the customers by tricking 

them to pay for more cubic space during the moves. (Id. at PageID 1870–71.) 

The defendant was one of the select few within the company who received 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. (PSR ¶ 40.) The defendant knew this was central to the 

scheme. (Doc. 268, PageID 1864.) He knew the enterprise was overcharging customers during 

moves, and instructed employees to cap the overcharge at 20% to keep customer complaints down. 

(Id. at PageID 1864–65.) 

The defendant also furthered the enterprise by paying employees to write “fake positive 

reviews” of moves performed by the moving enterprise to create the misimpression to customers 

that the company provided high-quality services. (Id. at PageID 1856–57.) As the enterprise 

received negative reviews from customers, the defendant was involved in changing the enterprise’s 

name and making false statements to customers and federal regulators as to the identity of the true 

owners—namely, the defendant and Shuklin. (Id. at PageID 1857–59.) The defendant would pay 

employees in order to use their names and identifying information so they could falsely represent 

that these employees actually owned the enterprise. (Id. at PageID 1859–60.) He was directly 

responsible for opening “new” affiliated companies and managing the companies’ “online image”

through false statements. (Id. at PageID 1866–67.) The defendant conspired with other members 

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of the enterprise to secure leads through a third-party company by creating and using fraudulentlyaltered images of driver’s licenses. (PSR ¶ 41.) 

On June 1, 2017, agents from the DOT and FBI executed a search warrant at the Florida 

headquarters of the moving enterprise, and both the defendant and Shuklin were interviewed. 

Nevertheless, 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, until fleeing the 

country in response to the Indictment in August 2018. (PSR ¶ 44.) 

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

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

Shuklin are the most culpable members of this criminal organization.

II. The Defendant’s Plea and Guidelines Range

The defendant pleaded guilty before this Court on October 17, 2022. 

Probation has calculated the defendant’s Guideline range as follows (see id. ¶¶ 53-68): 

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. 

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• 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, and the defendant 

does not object to this calculation. (Id. ¶ 68.) Probation calculated the defendant’s criminal history 

as I. (Id. ¶ 74.) The defendant’s Guideline range then is 97 to 121 months’ imprisonment. (Id. ¶ 

104). The Government agrees with Probation’s Guidelines calculation. 

DISCUSSION

III. The Contested Facts in the PSR

The defendant has challenged facts in three paragraphs in the PSR. “In resolving any 

dispute concerning a factor important to the sentencing determination, the court may consider 

relevant information without regard to its admissibility under the rules of evidence applicable at 

trial, provided that the information has sufficient indicia of reliability to support its probable 

accuracy.” U.S.S.G. § 6A1.3(a). 

Paragraph 44 (PSR at page 1, 10): Verlan fled to the Bahamas. Paragraph 44 states 

that, following the Indictment in this case, in September 2018, the defendant fled to the Bahamas 

through a charter boat, then flew to Panama, where he intended to fly to Turkey, before landing in 

his home country, Moldova. (PSR ¶ 44.) The defendant contests the notion that he “fled” the 

United States. The government’s position is that leaving the country after learning of a 

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racketeering Indictment that shut down the company he owned (a copy of which was found on his 

phone), in the manner he left, is proof of his flight. (See Doc. 19, Doc. 43, Doc. 44 (motion and 

orders relating to post-Indictment restraining order precluding enterprise from disposing of 

household goods) To the extent the defendant contests this fact at sentencing, the government 

intends to introduce witness testimony and the defendant’s proffer statements.

Paragraph 36 (PSR at page 7): Extortion and Theft of Goods. Paragraph 36 states, in 

relevant part, that “customers were extorted and their household goods, at times, were stolen.” 

(PSR ¶ 36.) As set forth in the Indictment, the enterprise furthered the scheme by “extort[ing]

customers into paying money to the Moving Enterprise by increasing the cost of moves after 

loading customers' household goods and by refusing to relinquish customers' household goods 

until customers paid an inflated price for delivery of the household goods.” (Indictment, Doc. 3, 

PageID 30, 33); see 18 U.S.C. § 1951(b)(2) (defining extortion as “obtaining of property from 

another, with his consent, induced by wrongful use of actual or threatened force, violence, or 

fear”); United States v. Campbell, 761 F. App’x 476, 480 (6th Cir. 2019) (explaining “‘fear’

includes the ‘fear of economic harm’—which means that ‘the victim believes that the defendant 

can exercise his or her power to the victim’s economic detriment’”) (quoting United States v. 

Kelley, 461 F.3d 817, 826 (6th Cir. 2006)). 

The enterprise would extort victims by threatening to keep their goods—after loading the 

goods on the moving truck, and then jacking up the price of the move—if the victims did not pay 

the fraudulent price. See, e.g., Exhibit 2, Exhibit 3 (moving documents and reports detailing two 

moves). The foreman who loaded the goods and then the business personnel in Hollywood, 

Florida, demanded the higher price after the goods were loaded. (See, e.g., Plea Agreement V. 

Pestereanu, Doc. 136, PageID 696 (“[A]s a foreman, PESTEREANU knew that the Moving 

Enterprise was refusing delivery of some customers’ household goods based on the fraudulent 

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charges that were added after customers signed binding estimates.”); Plea Agreement P. Ricci 

Quincoces, Doc. 183, PageID 908 (admitting “the Moving Enterprise would refuse delivery of 

customers’ household goods until after customers paid the inflated amount, wrongfully obtaining 

property from customers through fear of economic harm”). During execution of search warrants 

following the Indictment in this case, agents recovered the household goods of over 50 victims 

whose goods the enterprise refused to deliver from moves dating as far back as 2015. (PSR ¶ 45.)

All of the defendants who have pleaded guilty to the Indictment have agreed to this

conduct. Their plea colloques bear sufficient indicia of reliability for this Court to rely on their 

accuracy. See, e.g., United States v. Moncivais, 492 F.3d 652, 658-60 (6th Cir. 2007) (no error 

where district court relied on coconspirator’s proffer statements during defendant’s sentencing); 

see also United States v. Katzopoulos, 437 F.3d 569, 576 (6th Cir. 2006) (noting “long-settled rule 

of law that Confrontation Clause permits the admission of testimonial hearsay evidence at 

sentencing proceedings”). Beyond these sworn statements, to the extent the defendant contests 

these facts, the government intends to present witness testimony at sentencing. 

Paragraph 43 (PSR at page 9-10): Baltimore Threat. As set forth in the Indictment, 

“[o]n or about June 15, 2017, during a telephone call to a third-party company located in Maryland, 

VERLAN threatened to blow up a building owned by the third-party company and shoot the thirdparty company’s employees.” (Indictment, Doc. 3, PageID 36.) This is based on an interview of 

a witness who worked for the company that leased a Baltimore, Maryland warehouse to the 

enterprise and was threatened by the defendant, and is corroborated by police reports documenting 

the threat. (See Exhibit 4 (report of witness interview and police report).) To the extent the 

defendant contests these facts, the government intends to present witness testimony at sentencing. 

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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 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.2 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 

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 Exhibits 

to Gov.’s Sentencing Memo A. Shuklin, Doc. 231-3, PageID 1457–59.) 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. 

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

Probation. 

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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. (See Exhibit 2, Exhibit 3).

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 

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. 

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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 ¶ 45). 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 other members 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. He graduated from university in Moldova and studied 

“management, engineer, and international transportation.” (PSR ¶ 97). 

He was more than capable of succeeding in business without taking advantage of thousands 

of people. But instead of applying his intelligence and education to legitimate work, he instead 

spent years abusing and extorting victims when they were at their most vulnerable. 

Then, when he realized he was caught in the act, he fled. He took a boat to the Bahamas; 

he then flew to Panama, where he intended to ultimately flee to his home country. After years of 

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taking advantage of others, he would have rather become a fugitive than be held to account for his 

criminal activities. 

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

During his change of plea, the defendant attempted to put blame on the “industry,” as if he 

was forced to commit fraud and extortion because everyone else was doing it. (Doc. 268, PageID 

1861.) He even implored, “something needs to be done about it.” (Id. at PageID 1862.) This case 

is what is being done about it—the general deterrence that results when the bad actors in the 

moving industry who defraud and extort unknowing victims recognize the consequences of these 

actions. 

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

the moving industry.3

 A June 2020 study conducted by the Better Business Bureau reported that 

FMCSA received 4,780 complaints related to moving companies in 2019.4 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 

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 

3 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.”). 

4 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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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. 

Respectfully submitted, 

 

KENNETH L. PARKER

United States Attorney

 /s/Matthew C. Singer 

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, he caused the Government’s Sentencing Memorandum to

be served on counsel for the defendant electronically. 

 

Dated: Cincinnati, Ohio 

 December 12, 2022 

 

Respectfully submitted,

 

/s/Matthew C. Singer 

 Matthew C. Singer 

Assistant United States Attorney

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