Approved: 

MART N/s. EELL ANDREW D. GOLDSTEIN
Assistant United States Attorneys

Before: THE HONORABLE KEVIN NATHANIEL FOX
Chief United States Magistrate Judge
Southern District of New York


.

UNITED STATES OF AMERICA
. SEALED COMPLAINT


Violations of
DAVID POLOS and I 18 U.s.c. 1001
GLEN GLOVEE, 
COUNTY OF OFFENSE:
Defendants. . NEW YORK

- 
SOUTHERN DISTRICT OF NEW YORK, SS:

HANNAH M. BUCH, being duly sworn, deposes and says that she
is a Special Agent with the Federal Bureau of Investigation, and
charges as follows:

COUNT ONE
(False Statement POLOS)

1. On or about September 7, 2011, DAVID POLOS, the
defendant, in a matter within the jurisdiction of the executive
branch of the Government of the United States, willfully and
knowingly did falsify, conceal, and cover up by trick, scheme,
and device material facts, and made materially false,
fictitious, and fraudulent statements and representations, to
wit, POLOS falsely affirmed in a national security form that, as
of that date, he did not have outside employment beyond his work
with the Drug Enforcement Administration, when in truth and in
fact, and as POLOS well knew, he had outside employment in the
form of regular work at an adult entertainment establishment he
had an ownership interest in located in South Hackensack, New
Jersey.

(Title 18, United States Code, Section 1001.)

COUNT TWO
(False Statement GLOVER)

2. On or about August 1, 2011, GLEN GLOVER, the
defendant, in a matter within the jurisdiction of the executive
branch of the Government of the United States, willfully and
knowingly did falsify, cOnceal, and cover up by trick, scheme,
and device material facts, and made materially false,
fictitious, and fraudulent statements and representations, to
wit, GLOVER falsely affirmed in a national security form that,
as of that date, he did not have outside employment beyond his
work with the Drug Enforcement Administration, when in truth and
in fact, and as GLOVER well knew, he had outside employment in
the form of regular work at an adult entertainment establishment
he had an ownership interest in located in South Hackensack, New
Jersey.

(Title 18, United States Code, Section 1001.)

The bases for my knowledge and for the foregoing charges
are, in part, as follows:

3. I am currently employed as a Special Agent with
the Federal Bureau of Investigation I have been so
employed for approximately ten years. I base this affidavit on
my training and experience as a Special Agent, as well as on my
conversations with law enforcement agents and others, and my
examination of various reports and records. Because this
affidavit is being submitted for the limited purpose of
establishing probable cause, it does not include all the facts
that I have learned during the course of my investigation.
Where the contents of documents and the actions, statements and
conversations of others are reported herein, they are reported
in substance and in part, except where otherwise indicated.

The Defendants

 

4. I have reviewed records made available to me by
the Bepartment of Justice?s Office of the Inspector General
and have spoken to agents with 
mission is to detect and deter waste, fraud, and misconduct in
Department of Justice programs and personnel, including those of
the DEA.

5. I am aware from my review of records (the
Review"), and conversations with investigators
that DAVID POLOS, the defendant, was from in or about 1991 until
on or about April 18, 2015 employed by the DEA, most recently as
an Assistant Special Agent?in~Charge, responsible for
supervising the New York Organized Crime and Drug Enforcement
Strike Force (the ?Strike Force?). The Strike Force is a joint
task force consisting of dozens of enforcement officers from
numerous federal, state, and local law enforcement agencies,
including the DEA, which together target large suppliers and
distributors of illegal narcotics. Likewise, beginning in or
about 1998 and continuing to the present, GLEN GLOVER, the
defendant, works for the DEA as a Telecommunications Specialist.
At one point, approximately ten years ago, POLOS directly
supervised GLOVER. I am further aware that, at all points
relevant to the Complaint, POLOS and CLOVER typically worked
regular business hours at the DEA, with their daily workdays
generally covering at least the hours between 9 a.m. and 5 p.m.

Overview of Offenses

 

6. Based on the information provided herein, I
respectfully submit that there is probable cause to believe that
DAVID POLOS and GLEN CLOVER, the defendants, made false
statements to the federal government regarding their outside
employment in September 2011 and August 2011, respectively.
Specifically, and among other things, POLOS and CLOVER falsely
represented in documents they filed and certified in connection
with the review of their national security clearances that they
had no employment outside of the DEA. In fact, and at the time
the forms were certified, POLOS and GLOVER worked at an adult
entertainment establishment in South Hackensack, New Jersey (the
?Club"), which GLOVER owned in partnership with another
individual and in which POLOS possessed a convertible ownership
interest. As POLOS and CLOVER knew, the Club employed workers
who were not lawfully in the United States. POLOS and CLOVER
supervised the continuing operations of the Club, including at
times during which they appeared to also be working on paid
shifts with the DEA. On some occasions, POLOS used his status
as a law enforcement officer to facilitate the Club?s
operations, including displaying his firearm in connection with
a dispute among those operating the Club.

The Security Clearance Forms

 

7. From the DOJHOIG Review, I am aware that since at
least the year 2011, DAVID POLOS and GLEN GLOVER, the
defendants, have been required periodically to fill out a
specific national security form issued by the United States
government (?Form in order to maintain security
clearances they need to be able to access sensitive materials.as
a part of their work with the DEA. Each Form lists the
purpose of the form, specifically that the United States
Government conducts background investigations and
reinvestigations of persons under consideration for or retention
in national security positions and for positions requiring
access to sensitive law enforcement information. Among other
reasons, the United States Government conducts these background
investigations to ensure that individual.Federal employees with
access to classified or otherwise sensitive information are not
vulnerable to blackmail.

8. The Forms also contain the following
warning:

Penalties for Inaccurate or False Statements
The U.S. Criminal Code (title 18, section
1001) provides that knowingly falsifying or
concealing a material fact is a felony which
may result in fines and/or up to 5 years of
imprisonment. In addition, Federal agencies
generally fire, do not grant a security
clearance, or disqualify individuals who
have materially and deliberately falsified
these forms, and this remains a part of the
permanent record for future placements.

Your prospects of placement or security
clearance are better if you answer all
questions truthfully and completely. You
will have adequate opportunity to explain
any information you give to us on this form
and to make your comments part of the
record.

(Emphasis in original).

9. Each Form also contains a section in which
the disclosing employee is asked to list ?all employment
activities." That prompt reads, in relevant part, as follows:

Section 13: Employment Activities

List all your employment activities,
beginning with the present and working
back 7 years (if an SSBI go back 10 years).
You should list all full?time and partwtime 
work, paid or unpaid, consulting/contracting
work, all military.service duty locations,
temporary military duty locations (TDY) over
90 days, self?employment, other paid work,
and all periods of unemployment. The entire
period must be accounted for without breaks.

(Emphasis in original). For each employment activity listed by
the individual filling out the form, the form requires that the
individual fill out dates of employment, whether the work was
full? or partwtime, the name, address, and telephone number of
the employer, the physical location of the employer, and contact
informatiOn for a supervisor.

10. The Forms contain a certification that the
statements on the form and on any attachments to it are

true, complete, and correct to the best of
my knowledge and belief and-are made in good
faith. I have carefully read the foregoing
instructions to complete this form. I
understand that a knowing and willful false
statement on this form can be punished by
fine or imprisonment or both (18 U.S.C.
1001). I understand that intentionally
withholding, misrepresenting, or falsifying
information may have a negative effect on my
security clearance, employment prospects, or
job status, up to and including denial or
revocation of my security clearance, or my
removal and debarment from Federal service.

Both GLEN GLOVER and DAVID POLOS, the defendants, certified
their forms.

11. From the DOJWOIG Review, I am aware of the
following:

a. On or about August 1, 2011, GLEN GLOVER, the
defendant, electronically filled out and certified a Form SF-86.
In that form, GLOVER did not list any employment other than his

job at the DEA when prompted to list all of his employment.
GLOVER did not make reference, at any point in his form, to
employment at or ownership of the Club or an interest in an
entity known as Corp.,? which, as explained below, is the
legal entity owned by GLOVER and others that was used to
purchase the Club. -

b. GLOVER listed DAVID POLOS, the defendant, as
a reference on his Form 

c. On or about September 7, 2011, EOLOS
electronically filled out and certified a Form SFMBE. In that
form, EOLOS did not list any employment other than his job at
the DEA when prompted to list all of his employment. POLOS did
not make reference, at any point in his form, to employment at
or ownership of the Club or an interest in an entity known as
Corp.?

12. I know from the DOJ-OIG that, once the applicant
submits a form in connection with DEA employment, that
form is reviewed by an investigator, who uses the information on
the form and other investigative tools to perform a background
check on the applicant, including with respect to outside
employment of the applicant, in order to determine whether the
applicant is suitable for a national security position and/or
access to classified information.

13. From the DOJ-OIG Review, and based on
conversations with DOJMOIG personnel and a review of data from
the Forms submitted by DAVID POLOS and GLEN GLOVER, the
defendants, I have learned that Form was certified
by POLOS in the borough of Manhattan, and that GLOVER took
actions in furtherance of his false statement in Manhattan. In
particular:

a. POLOS and GLOVER worked primarily out of DEA
office buildings located next to each other in Manhattan.

b. POLOS and GLOVER received by ewmail prompts
with links to complete the Forms at computer workstations
in their DEA offices, but could have forwarded those e~mails to
another computer and completed the forms elsewhere.

c. The DEA office at which worked retains
timestamp data from when employees enter and leave the building,
and from when they park vehicles in an associated parking

complex, also located in Manhattan (together ?Retained Employee
Tradking Data?). a

d. The Forms indicate the exact time on
or about August 1, 2011 when Form was submitted,
and the exact time on or about September 7, 2011 when 
Form was submitted.

e. Retained Employee Tracking Data indicate
that POLOS was at his DEA office in Manhattan when he submitted
his Form This data is not available for GLOVER.

f. As part of the national security background
check, GLOVER and POLOS were interviewed by investigators.
GLOVER's interview took place on or about August 18, 2011 at the
DEA office in Manhattan. During that interview, GLOVER was
asked whether he owned a stake in a dog grooming spa business.
According to DEA personnel records, GLOVER responded that he had
forgotten that business when filling out his Form but
that it was operated solely by his wife. GLOVER also was asked
about $18,000 that was deposited into his bank account by a
particular individual GLOVER stated that
Contractor?1 deposited the money into account in order
to compensate him for a ?business investment" (which as set
forth below, related to the Club). At no point during this
interview did GLOVER mention ownership of or employment at a
Club, or of a corporate entity called ?sass Corpz?

14. From the Review, I know that as part of
the background investigation of GLEN GLOVER, the defendant,
references, including DAVID POLOS, the defendant, were
interviewed. During that interview, POLOS stated that GLOVER is
employed full~time at the DEA, and that in his free time, GLOVER
exercises and spends time with his spouse.

15. From the Review, I know that the
background investigation of GLEN GLOVER, the defendant, was
officially completed on September 30, 2011 and the background
investigation of DAVID POLOS was officially completed on January
13, 2012. Both defendants passed the background investigation
and were permitted to remain in their law enforcement positions
with the DEA.

The Defendants? Ownership Interest in the Club

 

16. Based on surveillance by myself and other law
enforcement agents, databases available to law enforcement

agents, and witness interviews, I know that ?Twins Plus Lounge?
or ?Twins Plus GowGo Lounge? (hereinafter ?Twins Plus? or the
?Club?) is an adult entertainment establishment located in South
Hackensack, New Jersey featuring scantily clad and sometimes
topless women (?dancers?) and offers private stalls for what are
supposed to be limitedwcontact dances between patrons and those
dancers, commonly called ?lap dances.?l The Club also offers a
full bar and kitchen.

17. I have interviewed an individual who has assisted
in the management of the Club (?Co?Manager and whose wife isv
a co?owner of the Club. From my conversations with Co?Manager,
l, I have learned the following:

GLEN GLOVER, the defendant, and Co?Manager 
originally met as fellow frequent customers of a similar adult
entertainment establishment in Northern New Jersey. Buying
Twins Plus was idea. Co?Manager 1 did not want to
become an owner in the Club, but his wife (?Co?Manager 1's
Wife?) wanted to purchase a stake in a business. In part by
using money Co-Manager 1 obtained by selling his ownership in a
different CowManager ifs Wife bought Twins Plus with
CLOVER in a transaction that closed in November 2010. A
Corporate entity called Corp. was created entirely for the
purpose of owning the Club, where the stood for another
'would?be co?owner who ultimately backed out, the stood for
CowManager 1?s Wife?s first initial, and the stood for
?Glen.? GLOVER has maintained an ownership interest in Twins
Plus continuously since he and Co?Manager l?s Wife purchased it
in 2010. A

b. At around the time the Club was purchased,
and pursuant to a written agreement between Twins Plus's owners
and QAVZD POLOS, the defendant, POLOS lent Twins Plus?s owners
approximately $50,000 in return for an option to formally
'purchase an ownership stake in the Club. POLOS preferred this
arrangement in part because he did not want to have his name on
any documents directly associated with ownership of Twins Plus.

 

1 I am aware that ?adult-entertainment establishment? refers to a somewhat
broad array of venues, with different rules and local laws governing what
takes place at each such establishment. In this case, I am aware that under
New Jersey law, dancers at Twins Plus must cover all private areas, including
nipples, in order for the Club to be able to serve alcohol. I am also aware
from citations that Twins Plus has been cited by the State of New Jersey,
Office of the Attorney General, Department of Law and Public Safety, Division
'of Alcoholic Beverage Control for lewdness. I further know from witness
interviews, and from my review of surveillance footage, that New Jersey?s
rules regarding the coverage of private areas have not always been observed.

-8-

c. GLOVER did not make it known around.the Club
that he worked in law enforcement, but POLOS often did. Once,
during an argument with Co-Manager 1?s Wife, POLOS lifted up his
pant leg, pointed to a gun on his ankle, and said, in sum and
substance, ?This is the boss. I am the boss.?2

18. I have also interviewed Co?Manager 1's Wife, who
has stated that GLEN GLOVER, the defendant, was a co-owner in
?the Club and that an individual she knew as ?Dave? had loaned
money for the purchase of the club and had a convertible
ownership interest but preferred that his name be off the
ownership paperwork.

Records Reflecting GLEN GLOVER's Ownership Interest

19. From my review of bank records and paperwork in
the possession of and filed with the New Jersey Department of
-State, am aware that Corp. (hereinafter is a
corporation that was incorporated in the state of New Jersey in
2010. certificate of incorporation and related papers
indicate that one of the corporate officers is GLEN GLOVER, the
defendant, and that GLOVER has been a corporate officer of sass
since the time of its incorporation. i am also aware that sass
'has held, over its corporate existence, at least two bank
accounts, one at JP Morgan Chase (the Chase Account?) and
one at Valley National Bank (the ?sass Valley National
Account").

20. I have reviewed bank records indicating that the
Chase Account was opened following the execution of opening
paperwork signed by GLEN GLOVER, the defendant, on September 23,
2010. In that opening paperwork, only two individuals are given
depository and withdrawal authorization GLOVER, who is listed
as ?President,? and Co?Manager 1, who is listed as ?Signer.?
ComManager 1?s Wife is listed as a ?Vice President? and also as
an ?individual to be added later? with respect to signing
authority.

2l; From my review of databases available to law
enforcement and DEA personnel records, I know that in 2011 GLEN
GLOVER, the defendant, lived at a specific address in New Jersey
Residence?).

22. Based on my review of bank records and local
government records, I am aware that Twins Plus was purchased in

 

2 Co Managerwl?s Wife confirms this account.



2010 by The purchase of Twins Plus involved the issuance
of a bank check in the amount of $180,000 drawn on the bank?s
funds at the direction of sass. Of that $180,000, $45,000 is
traceable to a trading account owned by GLEN GLOVER, the
defendant, and $18,000 is traceable to an amount transferred
from a bank account owned by CLOVER, which in turn had only
recently been obtained from a known individual, Contractorml.
It appears that this is the same deposit GLOVER was asked about
in his interview at the offices in Manhattan as part of
his security clearance.

23. From my review of additional records, I know that
in or around December 2011, submitted paperwork to a tax
reporting and payment processing agent (the ?Payment Company")
so that the Payment Company could file tax returns and make and
receive payments to the IRS on behalf. On this form, the
contact was listed as GLEN GLOVER, the defendant, whose.title
was listed as ?Owner.? On the form, ?Twins Plus Lounge" was
listed as a trade name or for The mailing,
delivery, payment and W2 addresses were listed as 
Residence. I also know that on or about March 18, 2014, CLOVER
submitted paperwork to the Payment Company in which he stated
that business with the Payment Company was being
terminated. The paperwork was signed by GLOVER and listed his
title as ?Owner? of and provided Residence as the
address to which all further correspondence concerning 
should be sent.

24. From my review of bank records, I know that
between at least May 2011 and August 2014, sass bank accounts
received frequent cash deposits in large amounts, totaling
approximately $600,000 over that time. I am aware from my
conversations with other law enforcement agents that businesses
like Twins Plus deal primarily in cash.

Records Reflecting DAVID POLOS's Convertible Ownership Interest

 

25. From my review of bank records, I have learned
that of the $180,000 in an bank account used to purchase
Twins Plus, $20,000 is from a wire transfer of $20,000 from a
Morgan Stanley bank account owned by DAVID POLOS, the defendant,
to the sass account.

26. I have reviewed two documents signed by GLEN
GLOVER, the defendant, and others, which reflect that DAVID
POLOS, the defendant, likewise had, at least until June 2013, an
ownership interest in the Club. In particular:

~10_

 

a. The first document (the ?First Note") is
dated May 24, 2011. It is signed by listed borrowers GLOVER and
Co?Manager 1?s Wife and lists POLOS as the ?Lender.". In sum and?
substance, the First Note memorializes an agreement by GLOVER
and Co?Manager 1?s Wife to repay $50,000 plus interest to POLOS,
and gives POLOS an option to exchange the note for a 25 percent
ownership interest in sass. -The first page of the First Note
contains a handwritten notation that reads, AND
REPLACED BY NOTE DATED 6/17/13?; adjacent to that notation is
the handwritten name of ?David Polos" and a signature that
appears to be that of ?David Poles.?

b. The second document (the ?Second Note?) is
dated June 17, 2013, and signed by CLOVER and Co?Manager 1?s
Wife. In sum and substance, the Second Note memorializes an

agreement by to pay $85,000, styled as a loan repayment, to
POLOS in the form of one $10,000 payment on or before June 26,
2013, and forty~eight payments of $1,795.97 thereafter.

27. From my review of the bank records, I am also
aware that on or about June 28, 2013, DAVID POLOS, the
defendant, was_issued a check in the amount of $10,000 from the
sass Valley National account with the description ?Loan.? On'
twelve occasions in the ensuing months, between on or about
August 5, 2013 and on or about August 20, 2014, and at 
intervals, POLOS was issued checks in the amount of $1,795.97.

The Defendants? Employment at and Involvement
in the Management of the Club

 

 

28. From my conversations with Co?Manager 1, I have
learned that both DAVID POLOS and GLEN CLOVER, the defendants,
worked at the Club and actively participated in its management.
In particular:

a. At the time Twins Plus was purchased by

it was badly in need of renovations. GLOVER oversaw the
subsequent renovation of Twins Plus with the help of POLOS and
others. The lead contractor was Contractor?l, who was
introduced to CowManager 1 as a friend of POLOS. Co~Manager 1
had never met Contractor~1 before, but Contractor?1 agreed to
give CLOVER, POLOS, Co~Manager l, and Co~Manager 1?s Wife a good
price for the needed renovations.

b. The renovated Twins Plus opened in or around
February 2011.' Once opened, Co-Manager I started taking shifts

-11-

at Twins Plus. During his shifts, Co-Manager 1 would supervise
dancers, bouncers, and barkeepers; pay the bartender and
bouncer; man the office in the back of Twins Plus (the ?Back
Office?) to which only employees had access; shut down the Club
at the end of the night; and generally manage the Club?s affairs
as needed.

c. Since the opening of the renovated club,
GLOVER regularly supervised shifts in the same manner as Co?
Manager 1 and generally was the person in charge of the day?tow
day affairs of Twins Plus. POLOS also worked at the Club from
its post?renovation opening in early 2011 until POLOS and CLOVER
had a falling out in 20l3. Buring that time, POLOS regularly
supervised shifts in the same manner as GLOVER and Co?Manager i.
In addition to supervising one or two shifts per week, POLOS
arranged for Twins Plus?s advertising.3

d. Twins Plus also employed another_individual
(?Co~Manager who originally was merely a regular patron of
Twins Plus, later was brought on as an employee, and ultimately
bought a share of the Club.

e. The Back Office of Twins Plus contained,
among other things, a computer that was used by GLOVER, POLOS,
Co~Manager i, and Co?Manager 2, while they worked shifts at
Twins Plus.

f. Twins Plus contained a video surveillance
system that CowManager l, POLOS, GLOVER, and others could access
remotely via desktop computer or via smartphone ?app,? such that
authorized persons could view the goings-on at the club remotely
via computer or phone. GLOVER and POLOS frequently called Twins
Plus, addressing and remarking on events that were happening
there live during the day when they were not present at the Club
(and when, based on witness accounts of the timing and frequency
of the calls, they were likely on duty with the DEA).

29. I have spoken to two individuals who worked as
bouncers for Twins Plus (hereinafter, ?Bouncer?l? and ?Bouncerw
Bouncer?1 worked at Twins Plus from 2010 until 2014,

including the renovation of the Club under Contractorwl.

 

3 involvement in club advertising is corroborated by bank
records. In particular, bank records refiect that POLOS was issued
several checks from the Chase Account with ?Steppin Out" or
?advertising? referenced in the memo line. ?Steppin Out" is a New
Jersey nightlife periodical that carries advertising for
establishments like Twins Plus.

-12-

Bouncer?2 began working at the Club in November 2012 and remains
employed there. From these conversations, I have learned the
following:

a. GLEN GLOVER, the defendant, was generally in
charge of running Twins Plus. Initially, GLOVER wanted Bouncer?
to be in charge of the liquor after Twins Plus re?opened after
its renovation, but DAVID POLOS, the defendant, said that he
would do it. Based on statements made by CLOVER and POLOS,
along with others at the Club, Bouncerwl and Bouncerez
understood that GLOVER and POLOS worked at the SEA, although
POLOS would sometimes claim to others at the Club that he worked
for the FBI. Sometimes, badge was visible. On at least
one occasion, GLOVER wore a bulletproof vest to Twins Plus.

b. CLOVER was in charge of dealing with the
dancers and managing the bartending staff. He also collected
the house fees from dancers, who typically paid between $10 and
$30 per night in order to dance at Twins Plus.4 The dancers were
brought to Twins Plus by a number of drivers who, in turn, were
also paid by the dancers on a daily basis. Most of the dancers
were undocumented immigrants from either Brazil or Russia. The
dancers? status as undocumented immigrants was widely known at
the Club in part because dancers spoke about it and in part
because the dancers had to sign in using employee sign?in sheets
that asked, among other things, whether the employees were
,United States citizens. The dancers frequently indicated that
they were not.5

c. The Bouncers? duties included occasionally
checking the lap dance rooms due to the fact that patrons and
dancers sometimes engaged in sexual activity, which the Bouncers
halted if detected. On at least one occasion, GLOVER chastised
.Bouncer?l for too aggressively checking the lap dance area for
wrongdoing and disrupting inwprogress lap dances in the process.

d. In the fall of 2012, Bouncer?2 was asked by
a friend who worked at the Club whether he would be interested
in a job there. Soon after, he received a telephone call from,
and met, POLOS. Later, GLOVER met him and gave him a full tour
of the Club, and officially hired him.

 

4 GLOVER's role in managing Twins Plus was further confirmed by CowManager 1?s
Wife, who stated that GLOVER handled Twins Plus?s finances, managed the bar,
and paid employees.

5 Additionally, I know from law enforcement and immigration databases as well

as witness interviews that certain of the dancers were undocumented and not
lawfully in the United States.

-13-

30. I have reviewed text messages between and amongst
several Twins Plus employees that were routed through a
messaging program on the Back Office computer between and
amongst GLEN GLOVER and DAVID POLOS, the defendants, Co?Manager
1, CowManager 2, and others. These messages were retrieved
during a judicially authorized search of the Back Office
computer. From my review of these messages, including those
below, it is apparent that both POLOS and GLOVER played an
active role in managing the affairs of the Club:

a. On or around June 23, 2011, at around 5:33
POLOS sent a text message from his DEA work cell phone to
Co?Manager 2 that stated: ?Tunnel traffic is messed up, cover,
the shift for 

b. On or around June 30, 2011, beginning at
around 2:14 POLOS had a text message exchange with Co
Manager?2 in which he stated: ?Currently on a train to
Washington, DC not looking good in regard to working tonight.
Let me know your status..? CowManager 2, in two texts,
responded: ?Your going to jail in and ?What are the
charges?" POLOS replied: ?Work related." Co Manager~2
responded: ?Just joking, ok I can work tonight, I be there at
1830.? Polos then stated: ?Great, thanks brother.?

c. On or around July 7, 2011, at around 3:40
POLOS sent Co-Manager 2 a text message, stating: ?In a
meeting, finish in 15 min.? 'Co-Manager 2 responded: ?You
working tonight?? At or around 3:49 POLOS responded:
?Yes, my flight lands in NY at 6:15, then I will drive over. If

you could do the change over that would be great.? Co Managerm2
stated: no problem.? POLOS responded, ?You?re the 
d. On or around August 11, 2011, beginning at

around 5:28 POLOS and CowManager 2 had the following
conversation via text message:

POLOS: President is in town, traffic
is all cooked up leaving the
city, can you cover the shift



Co~Manager 2: President in town to meet
with you?

POLOS: Not me 

?14.

Co?Manager 2 and POLOS then joked about bringing the President
to the Club so that he could ?check out? certain of the Dancers.

e. On or around August 18, 2011, beginning at
around 2:27 POLOS sent texts from his DEA work cell phone
to CowManager 2 that stated: ?Bring your cooler to the 
and ?We need to move ice machine."

f. On or around August 23, 2011, beginning at
around 8:31 GLOVER texted Co?Manager 2: ?E?m coming with
two state trooper they don't know I own the bar"; CowManager 2
replied: ?Copy, 1 will brief [other employee].?

g. On or about August 25, 2011, at around 3:21
Co-Manager 2 sent the following text message to GLOVER: 
fixed the can you tell [other person affiliated with

the Club] to stop having sex with [a dancer hereinafter referred
to as ?Dancer?1?] on the chair, it?s just not built to handle
all the added weight she is carrying.?

h. On or around October 3, 2011, POLOS and Co-
Manager 2 had the folloWing conversation via text message:

POLOS: [Co?Manager in the future
make sure you send notes and
ring totals to everyone. I?m
sure last night was an
oversight.., Thanks.

Co?Manager 2: It's not an oversight, it?s
because sometimes I am doing
other's jobs and I don?t want
it to appear as though I?m

bitching.
Co?Manager 2: Don?t want to offend anyone
Co?Manager 2: Except the colored
POLOS: So you?re telling me it?s ok

to just send it to Glen..

Co?Manager 2: 

POLOS: Nevertheless, I shouldn?t
have to find out from Glen
what you have to 

POLOS: Not 

i. On or about December 19, 2011, at around
10:56 GLOVER sent the following message to ComManager 2:
?It?s nice to see your not checking the lap dance room condoms
everywhere.?

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31. I have reviewed e?mails between DAVIE POLOS and
GLEN GLOVER, the defendants, Co~Manager 1, Co?Manager 2, and
others affiliated with the management of Twins Plus6 that were
retrieved from the Back Office computer during a judicially
authorized search of Iwins Plus and computers therein. My
review of these materials, including those identified below,
reflects that POLOS and GLOVER played an active role in managing
the Club's operations:

a. There was a series of e?mail communications on
August 11, 2011 and August 12, 2011 between Co~Manager 1, Co?
Manager 2, another person affiliated with the Club (?Individual?

POLOS, and GLOVER. On or about August 11, 2011, at 10:23
POLOS e-mailed the others on the chain with the subject
line ?Twins.? The resulting e?mail thread included the

following e?mails:

i. POLOS stated: ?Lucky me I have 13 girls
and the girls are complaining that there too many 
POLOS complained that ?Fucking Glen is goin on vacation
POLOS also stated: ?Don?t worry [Co?Manager l] the
sweat suit look will be back in style soon."

ii. Not long after, at 11:42 Com
Manager 1 responded that ?Sweat suits are more convenient than
for getting lap dances. No buttons or zippers pull em down in
the front and go" and stated that he ?didn?t think anyone at the
DEA actually went to work.?

The next day, at 7:38 GLOVER
wrote an e-mail that included the following:

Gentleman I?m proud to say that under my
tutelage Dave has managed to make [a
bartender] quit I?m so proud of him he?s
such a fast learner on how to be mean to
bartenders. Even though I think this will
probably be better for us in the long run it
does create an immediate problem we need
someone for today and I?m getting on a plane
at 930 and won?t land till 1 so someone
needs to get a bartender today I would

 

5 Co?Manager 1 authenticated the e?mail addresses as belonging to the relevant
senders and recipients of the e~mails. Further, the e?mail accounts
attributed to GLOVER and POLOS are the same e-mail addresses listed by GLOVER
and POLOS as personal e?mail address in their respective Forms 

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rather it be [a second bartender] because
she is doing the book and I need [CowManager
2] to go over everything with her.

b. On or about October 17,.20ll at 4:02 
ComManager 2 sent POLOS, GLOVER, Co-Manager 1, Co-Manager 2, and
another individual involved in the Club?s management an e?mail
with the subject line ?Sunday notes? that read, in part:

2 hope someone has $800 singles to bring in
as we are short once again with singles.
Please leave a note on the inside of the
safe door so we know the disposition of the
singles in house versus the singles outside
the building. The beer cooler nearest the
front door is no longer keeping the beer
cold; the bottles are warm and sweating.
[Co?Manager could you contact Al to have
a look? I picked up twenty cases of water
and placed in the walk in box. I ordered
the food from Walmart from Monday until
I spoke to our
exterminator, and told him our problem with
the pillbugs. He will visit this week and
eliminate them. Maybe he can eliminate some
of the colored girls? [Dancer?s name] was a
pain in the ass; she worked a double and by
200 was useless, she either slept in her car
or in a lap dance booth so I dismissed her
at 2330.

To which POLOS replied, on or about October 17, 2011, at 7:29


STOP, hold up on contacting Al, we will go
to the poor house if we keep using that guy.
You mentioned to me about buying those
coolers from the firemen who closed the bar.
That cooler is from Temps and is very old.
Just a suggestionthose coolers for the price you mentioned to
me, it might be better to replace it 

GLOVER then responded, on or about October 17, 2011, at 9:16
in part:

117"

I have the singles I had to hide them in my
car after I went to the bank because I had
to stop at Walmart and pick up a sandwich
from 2 days ago that no one ever I
hope you guys enjoyed your weekend! [Co?
Manager you can get rid of all the black
girls if you want if you go find other ones
Maybe if you take some time 
We need to fix this cooler I?ve seen how
this operation works we don?t have another
cooler in there for a month. So we?ll be
serving warm beers the whole time? The.
coolers were at temps but they weren?t even
used they were only used for 8 months. Oh
and by the way there are absolutely no mop
heads so they cant mop the floor today.

POLOS then responded, on or about 9:25 a.m. on October 17, 2011,
?Wow, I just love 

c. On or about April 3, 2012, POLOS forwarded
CowManager 2 an e?mail that had been sent from an individual at
Steppin Out magazine (?Steppin Out Rep?1?) with the subject line
?Proof for Dave? and a picture file attachment. The picture
file depicts a ?Twins Go-Go Lounge? logo and two women in
bikinis holding each other and staring out at the viewer, with

lettering stating: ?Save The Thurs., April 19 1 Year
Anniversary Bash of Twins GoGo Lounge!? and DOMESTIC BOTTLES
Coupon Valid on Mondays Wednesdays Thru April 18.? I am

generally aware that in publishing, a ?proof? is a draft form of
a page or page element before it is finalized.

d. On or about August 3, 2012, at 2:50 
GLOVER e~mailed Co?Manager 1 and copied POLOS and CowManager 2,
writing:

As far as [a named dancer] goes there were
several problems leading up to the decision
to let her go however you wouldn?t know that
because no one ever here?s from you. We?re
not intentionally leaving you out or picking
on you were making these decisions with each
other. We have no problem with you only
coming around once a week. But this bar
needs to be run still and we?ve made a lot
of changes to the place and made a lot more
rules that everyone has to follow so don't

-18..

tell me that the 3 of us can?t get rid of a
dancer that we believed called the cops on
us last night because you are friends with
her. can have a meeting but I?m
letting you know right now the 3 of us are
all on the same page.

e. On or about September 23, 2012, at 8:27
POLOS forwarded Co?Manager 2 e?mail exchanges between
himself, Steppin Out Rep?1, and a representative from a web
design company with the instruction, ?Forward to Frank.? Among
the exchanges contained within the forwarded e-mails were a
psecond proof ad for Twins Plus Lounge with two women in bikinis
and an advertisement for $1 Miller Lite drafts on Sunday,

September 3o?t

32. I have spoken to Dancer?1. From this
conversation, I have learned the following:

a. Dancerwl was a dancer at Twins Plus, and now
dances at another club. She is originally from Brazil, and is
an undocumented immigrant, as are many of the dancers at Twins
Slus. The owners of the Club, including POLOS, were familiar
with her status, and allowed her to work double shifts because
they knew she needed the money to pay back the smugglers who
arranged for her unlawful entry into the United States. 

b. POLOS loaned Dancer?1 money to bail herself
out of jail following a 2012 arrest for assault and criminal
mischief after an altercation with a member of the local police
department that took place outside of Twins Plus.

33. I have viewed several hours of surveillance
footage taken from Twins Plus during a judicially authorized
search, including footage from the private lap dance area from
the Club recorded in late 2914. In the footage I have seen,
there appear to be multiple instances of sexual contact between
dancers and patrons, with money exchanged afterwards.

Impact of the False Statements

34. I have Spoken to a Special Agent with DOJWOIG
Agent?l?). He has worked for for three years,
and prior to that was a Special Agent with the DEA for 15 years.
Based on his training, experience, and familiarity with 
security clearance policies, procedures, and disciplinary
mechanisms, Agentwl informed me of the following:

-19..



a. Had DAVIS POLOS and GLEN GLOVER, the
defendants, informed the federal government via the Forms 
of ongoing employment at the Club, their ownership and
involvement in the affairs of the Club would have been
investigated and their security clearance would most likely have
?been denied. Among other reasons, this is due to the
possibility of employee blackmail and other concerns attendant
to such establishments, such as relatively frequent incidents of
prostitution and human trafficking and persons involved in such
criminal activities.

b. Had POLOS and GLOVER been denied security
clearance, they would not have been able to continue to work as
DEA personnel in their respective positions.

WHEREFORE, deponent prays that defendants be imprisoned, or
bailed, as the case may be. 

L: Mix

HANNAH M. BUCH
Special Agent
Federal Bureau of Investigation

r"worn to before me this
gig??aay of May, 2015

/;22;mf
FOX

Ng?igysk
CHIEF UNITED STATES ISTRATE JUDGE

SOUTHERN DISTRICT OF NEW YORK

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