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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK
-

- X

UNITED STATES OF AMERICA

COMPLAINT

- against -

(18 U.S.C. 287)

YITZCHOK IZIEL SOFER,

also known as "Isaac Sofer"
Defendant.

-X
EASTERN DISTRICT OF NEW YORK, SS:
JOHN VOURDERIS, being duly sworn, deposes and states that he is a Special
Agent with the Federal Bureau oflnvestigation, duly appointed according to law and acting as
such.
In or about and between December 2012 and June 2016, both dates being
approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendant, YITZCHOK IZIEL SOFER, also known as "Isaac Sofer," made and caused to be
presented a claim upon and against the United States Department of Agriculture ("USDA"), a
department of the United States, for food stamp assistance under the Supplemental Nutritional
Assistance Program ("SNAP"), knowing that the claim was false, fictitious and fraudulent.
(Title 18, United States Code, Sections 287 and 2)

The source of your deponent' s information and the grounds for his/her belief
are as follows: 1
1.

I am a Special Agent with the Federal Bureau oflnvestigation ("FBI")

and have been with the FBI for approximately two and a half years. Through my training
and experience, I have been involved in the investigation of numerous cases involving, among
other things, theft of government funds, welfare benefits fraud and false statements. Also
through my training and experience, I have become familiar with various public assistance
programs administered by New York City. I am familiar with the facts and circumstances set
forth below from my participation in the investigation; my review of the investigative file;
conversations with witnesses; and from reports of other law enforcement officers involved in
the investigation.
Background
I.

The Defendant
2.

The defendant, YITZCHOK IZIEL SOFER, also known as "Isaac

Sofer," is a resident of Brooklyn, New York.

3.

SOFER has been a recipient of state and federally funded benefits,

including SNAP benefits since approximately January 2010.

II.

New York City Human Resources Administration

4.

Based on my training and experience, my review of documents and

conversations with others, I am aware that the New York City Human Resources

Because the purpose of this Complaint is to set forth only those facts necessary
to establish probable cause to arrest, I have not described all the relevant facts and
circumstances of which I am aware.

Administration ("HRA") is the department of the government of New York City that
administers many of the city' s social services programs. It provides temporary help to
individuals and families with social service and economic needs to assist them in reaching
self-sufficiency. Its services include, among other things, administering SNAP, commonly
known as the "food stamp" program.
III.

The Supplemental Nutrition Assistance Program

5.

Based on my training and experience, my review of documents and

conversations with others, I am aware that SNAP benefits are fully funded by the USDA, and
that SNAP offers nutrition assistance to millions of eligible, low-income individuals and
families throughout the United States ("SNAP recipients"). Through SNAP, certain preapproved retail stores are authorized to sell eligible food items in exchange for funds
presented to the stores by SNAP recipients. Through SNAP, the USDA provides more than a
billion dollars per year in SNAP benefits to beneficiaries in New York City.
6.

In New York City, eligibility for SNAP benefits is determined, and

distribution of those benefits made, by HRA, which processes applications for SNAP benefits
at its local office located in New York, New York.
7.

SNAP benefits are provided to households that meet eligibility

requirements that are based on, among other criteria, household income and the number of
people living in the household.
8.

In order to apply for SNAP benefits, an applicant must complete and

sign an application form listing, among other things, the applicant' s name, social security
number, date of birth, address, sources of income and financial assets. The applicant must

4
also provide information pertaining to persons living with the applicant, including whether
such persons earn income.
9.

To qualify for SNAP benefits administered through HRA, a person must

live within the geographic area served by the local department in which they file an
application for food stamps and have an annual household income (before taxes) that is less
than or equal to a specified amount, given the applicant' s household composition. Once an
applicant qualifies for SNAP, the amount of benefits the applicant is entitled to is determined,
in part, based on the applicant's reported household income and family composition. For
example, in 2016, based on HRA' s eligibility requirements, for a one-person household with
earned income to qualify for SNAP benefits, the gross monthly income for that household
must not exceed $1 ,287. In 2016, a household like that of SOFER' s-namely, a married
couple with five children2-the family' s collective monthly income could not exceed $3 ,980. 3
IV.

The Defendant' s SNAP Omissions and False Statements

10.

Based on my review of documents maintained by HRA and my

discussions with other law enforcement agents and employees of HRA, the investigation has
revealed that SOFER has made false statements in applications submitted in 2012, 2013 ,
2014, 2015 and 2016 for SNAP benefits.

From 2013 to 2015, SOFER' s household had six persons. Starting in 2016,
SOFER' s household became a seven-person household.
3

For 2013 through 2015 , the monthly income thresholds for a one-person
household were $1 ,245, $1 ,265 and $1 ,276, respectively. For those same years, the monthly
income thresholds for a six-person household were $3,423 , $3 ,464 and $3 ,529, respectively.

5
A. SOFER' s SNAP Applications

11.

Since in or about January 2010, SOFER has been a recipient of SNAP

benefits. 4 In connection with his receipt of SNAP benefits, SOFER has submitted annual
declarations and re-certifications of information pertinent to his application to BRA. As set
forth further below, beginning on or about December 27, 2012 until on or about June 16,
2016, SOFER has repeatedly made false presentations to BRA. Since on or about December
27, 2012 through the present, SOFER has received approximately $30,516.00 in SNAP
benefits.
B. SOFER' s False Statements

a. False Statements Concerning Undisclosed Life Insurance, Income

and Assets
12.

Based on the investigation, which included a review of SOFER' s SNAP

benefits applications and re-certifications between December 27, 2012 5 and June 2016, it is
the undersigned' s belief that SOFER submitted declarations that contained false statements
regarding whether he had a life insurance policy and the true amount of his household income
and assets.
13.

On or about February 11 , 2013 , SOFER submitted to BRA a signed

application form declaring that he did not have life insurance. The SNAP application
instructed the applicant to "[i]ndicate if you or anyone who lives with you who is applying . ..

BRA records indicate that SOFER received SNAP benefits on two distinct BRA
accounts during the relevant time period.
5

Although this application was signed by SOFER on December 27, 2012, BRA lists
the "application date" as January 18, 2013. For the purposes of this Complaint, I will refer to
this application as the December 27, 2012 application.

has life insurance." In response to this question, SOFER checked the box indicating "No."
SOFER's electronic signature appears on the application, declaring under penalty of perjury
that the information he provided was correct. Every subsequent recertification SOFER
submitted has contained the same assertion.
14.

A review of SOFER' s financial transactions during the relevant time

period, however, indicated that SOFER had been making regular payments to a life insurance
company (the "Insurer"). Subsequent investigation into these payments revealed that SOFER
acquired a life insurance policy in his own name with the Insurer on December 1, 2012, just
months prior to signing the SNAP applications and re-certifications described above. This
insurance policy insured SOFER for $1 ,000,000.00 based on quarterly payments of $312.55.
SOFER continues to hold this policy to the present date: the most recent payment, due on
December 1, 2016, was made on October 17, 2016.
15.

The investigation obtained the hand-written application SOFER used to

obtain this life insurance policy. A number of statements made by SOFER to the Insurer
during the application process contradict statements made by SOFER in his SNAP
applications. For example, in his October 29, 2012 application to obtain life insurance,
SOFER represented that he believed he had "the financial ability to continue making premium
payments on this policy" and that he earned $100,000 the prior year. He further represented
that he owned $600,000 in assets. 6 Less than two months later, on or about December 27,
2012, SOFER represented to HRA in his SNAP application that he was the only person in his

The application signature page- which SOFER signed-required SOFER to

agree that "all of the statements that are part of the application are correctly recorded, and are
complete and true to the best of the knowledge and belief of those persons who made them."

7
household earning income, and that his weekly salary was $250-equivalent to an annual
income of approximately $13,000. 7 In this same application, he stated that he had no "other
financial assets," including any that fit into any of the following categories: "stocks, bonds,
retirement accounts, savings bonds, mutual funds, IRAs, trust funds, money market
certificates."
16.

Each of the SNAP applications and re-certifications signed by SOFER

required him to accurately state his household income. For instance, the section entitled
"Income" in the December 27, 2012 SNAP application submitted by SOFER reads: "List
ALL your income and the income of anyone living with you. This includes, but is not
limited to wages, income from self-employment (for example: babysitting, cleaning, income
from a roomer or boarder) child support, pensions, veterans ' benefits, disability, social
security or SSI, grant for scholarships for rent or food, Public Assistance, and income from
friends or relatives." The multiple re-certifications submitted by SOFER in the years that
followed all required him to disclose all "Wages, Salary, including Overtime, Commissions,
Training Programs, Tips" earned by him anyone else who lived with him."
17.

Based on a review of SOFER' s SNAP applications and re-certifications

to HRA submitted between December 27, 2012 and June 16, 2016, SOFER has stated that his
monthly gross total household income varied from $0 to approximately $25,500 per year,
depending on whether he and his wife had been employed. SOFER indicated that the source
of his or his wife's income, when he had any, was "Bais Ruchel Dsatmar." Bais Ruchel

If $13 ,000 was SOFER' s true income, his life insurance premiums would
amount to nearly 10% of his salary. Additionally, as noted above, an annual income of
$100,000 would have made SOFER and his family ineligible for any SNAP benefits.

8
D ' Satmar and Central United Talmudic Academy are commonly used names for Keren
Habinyan Hachudosh D'Rabeinu Yoel of Satmar BP, SOFERs employer. 8 SOFER' s
signature appears on the December 27, 2012 application, declaring under penalty of perjury
that the information he provided was correct. His electronic signature appears on the
February 11 , 2013 application, as well as subsequent re-certifications filed on August 23 ,
2013 , May 21 , 2014, June 11 , 2015 and June 16, 2016.
18.

The SNAP application and re-certifications also require the applicant to

indicate whether he/she has possessions fitting into various asset classes. For example, the
application filled out on February 11 , 2013 asked SOFER to state whether he/she "has cash on
hand," "has stocks, bonds, certificates or mutual funds," has savings bonds," "has real estate,"
"has own home," or "has an annuity," among various other questions. Further, it asked
SOFER whether he had "any other resources other than those listed above." SOFER did not
indicate anything that would constitute $600,000 in assets: rather, he answered "NO" to each
and every question.
19.

Based on discussions with representatives ofHRA regarding SOFER' s

eligibility for SNAP benefits, it is the undersigned' s belief that, among other things, SOFER' s
misrepresentations concerning his life insurance policy and his actual income and assets
affected HRA' s ability to make an accurate determination of SOFER's true financial
condition. These misstatements thus adversely impacted HRA' s ability to make an accurate
assessment of SOFER' s eligibility for the SNAP benefits he has received since January 2013 ,
including whether he was entitled to any SNAP benefits at all.

The investigation has revealed that SOFER works for his employer in a
governmental relations capacity.

b. False Statements Concerning Additional Cash Expenditures

20.

Based on the investigation to date, including a review of SOFER's

SNAP benefits re-certification signed June 16, 2016, it is the undersigned's belief that SOFER
submitted declarations that contained additional false statements regarding whether SOFER
had given away cash during the prior 36 months. The June 16, 2016 SNAP application
instructed that the applicant " [i]ndicate if you or anyone who lives with you who is applying
. . . (including your spouse, even if not applying or living with you) [has] given away any
cash, or sold/transferred any real estate income or personal property in the past 36 months."
In response to this question, SOFER checked the box indicating "No." SOFER' s signature
appears on the application, declaring under penalty of perjury that the information he
provided was correct.
21.

A review of a report received from the New York State Board of

Elections ("NYSBE") reveals that on or about July 7, 2015, SOFER made two cash donations
totaling $525: a donation of $500.00 to "Friends of Phil Goldfeder," the campaign committee
of a member of the New York State Assembly, and a donation of $25.00 to "Leticia James,"
the New York City Public Advocate.
22.

Based on discussions with representatives of HRA regarding SOFER' s

eligibility for SNAP benefits, it is the undersigned' s belief that, among other things, SOFER' s
misrepresentation concerning these cash donations would also have affected HRA' s ability to
make an accurate determination of SOFER' s actual financial condition, and adversely
impacted HRA' s ability to make an accurate assessment of SOFER' s eligibility for SNAP
benefits.

10

WHEREFORE, your deponent respectfully requests that the defendant

YITZCHOK IZIEL SOFER, also known as "Isaac Sofer," be dealt with according to law. I
further request that the Court order this application, including the affidavit and the arrest
warrant, be sealed until further order of the Court. These documents discuss an ongoing
criminal investigation. Disclosure of this application and these orders would seriously
jeopardize the ongoing investigation, as such disclosure would give the targets of the
investigation an opportunity to destroy evidence, harm or threaten victims or other witnesses,
change patterns of behavior, notify confederates and flee from or evade prosecution.

JqjlN VOURDERIS

y~fDL

Special Agent, Federal Bureau of Investigation

Sworn to before me this

21st

T
HONORABLE LOIS BLOOM
UNITED STATES MAGISTRATE JUDGE
EASTERN DISTRICT OF NEW YORK