Affidavit – Page 1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

TYLER DIVISION 

UNITED STATES OF AMERICA § 

Plaintiff, § 

§ 

v. § NO: 6:23-CV-00351

§ 

$1,029,155.26 IN UNITED STATES § 

CURRENCY § 

Defendant. § 

AFFIDAVIT IN SUPPORT OF COMPLAINT FOR FORFEITURE 

I, Brad Schley, after being duly sworn, depose and state as follows: 

INTRODUCTION AND AGENT BACKGROUND

1. I am a Senior Special Agent (SSA) with the United States Secret Service

(USSS) and have been so employed since September 2001. During my tenure with the 

Secret Service, I have been assigned to investigate violations of federal laws, including 

violations of Title 18 of the United States Code, specifically those related to the passing 

of counterfeit United States currency, money laundering, and wire fraud. I received 

criminal investigative training at the Federal Law Enforcement Training Center in 

Glynco, Georgia, and at the James J. Rowley Secret Service Training Center in Beltsville, 

Maryland, pertaining to criminal investigations of counterfeit currency, bank fraud, 

money laundering, wire fraud, access device fraud, and identity theft. During my 

employment with the USSS, I have conducted investigations resulting in the arrest of 

suspects and seizures of criminally derived property. I am an investigative and law 

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enforcement officer of the United States, in that I am empowered by law to conduct 

investigations and to make arrests for felony offenses, under authority of 18 U.S.C. 

§ 3056. 

2. The statements contained in this affidavit are based in part upon my 

experience, my knowledge of the facts and circumstances surrounding this investigation, 

and on information provided to me by other law enforcement personnel and other 

witnesses. 

PROPERTY FOR FORFEITURE 

3. This Affidavit is made in support of a civil forfeiture complaint concerning 

the following personal property: 

a. $1,029,155.26 in Wells Fargo Bank accounts 6945288279 (Target Account 

 1), 2089226720 (Target Account 2), and 9068111294 (Target Account 3), 

 Check No. 0002540888 seized on or about April 6, 2023, in Irving, TX 

 pursuant to a seizure warrant. 

LEGAL AUTHORITY FOR FORFEITURE 

4. The funds to be forfeited represent proceeds of a computer/technical 

support fraud scheme. A technical support scheme often begins when victims browse the 

Internet on electronic devices and receive a “pop-up message” on their device. The “popup message” often sounds a loud audible alarm, displays a message that the device was 

compromised by a computer virus, and instructs the victim to contact a computer 

technician. Victims report that when the message is visible on their screens, their devices 

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do not respond to keyboard inputs. Victims state that the “pop-up message” lists 

telephone numbers by which a technician can be reached. When the victims call the 

telephone number provided in the “pop-up” message, they are asked to provide their 

contact information and are informed that a technician will contact them. When the 

“technician” contacts them, the technician instructs the victim to download remote access 

software. After the victims download the remote access software, the technician is able 

to remotely access the victims’ devices. Victims report that the technicians indicated 

various reasons why their computer was compromised, including an “IP address hack” 

and “computer security issues.” Victims report that the technicians offered to provide 

several different services to ensure that their IP addresses and computers were secured. 

These services included “Lifetime Lifelock,” “Internet Security,” and “Microsoft 

Insurance.” Victims were tricked into thinking they were doing business with a 

legitimate company, such as Microsoft, because the technicians would refer to 

themselves as Microsoft Technicians or Microsoft-Trained Technicians. Victims report 

that once the “pop-up messages” were removed, their payments were requested. Victims 

report that they made payments via checks that were scanned on their computers when 

the technicians had control of their devices, or that were mailed to various addresses 

provided by the technicians.

5. I believe the above-listed property is subject to forfeiture to the United 

States pursuant to 18 U.S.C. § 981(a)(1)(A) because the property was involved in or 

traceable to property involved in money laundering in violation of 18 U.S.C §§ 1956 or 

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1957, or constitutes proceeds from a specified unlawful activity (as defined in 18 U.S.C. 

§ 1956(c)(7) and 18 U.S.C. § 1961(1)). 

6. Any property, real or personal, which was involved in a transaction in 

violation of 18 U.S.C. §§ 1956 or 1957 or any property traceable to such property is 

subject to forfeiture pursuant to 18 U.S.C. § 981(a)(1)(A).

7. 18 U.S.C. § 1956 (a)(1) makes it a crime to knowingly conduct or attempt 

to conduct a “financial transaction” with proceeds from “specified unlawful activity” 

(SUA) with specific intent to: promote the SUA, conceal or disguise the source, origin, 

nature, ownership, or control of the proceeds; or evade reporting requirements.

8. The purpose of “money laundering” as defined by 18 U.S.C. § 1956 is to 

disguise illicit nature of funds by introducing it into legitimate commerce and finance 

thereby making them “clean.” This financial process is most commonly conducted using 

three steps referred to as “placement,” “layering,” and “integration.” Typically, the 

“placement” phase of this financial process takes place when proceeds from illicit sources 

are placed in a financial institution or business entity. “Layering” takes place when these 

funds are then used in seemingly legitimate commerce transactions which makes the 

tracing of these monies more difficult and removed from the criminal activity from which 

they are a source. Finally, the “integration” phase is when these funds are then used to 

promote the unlawful activity or for the personal benefit of the money launderers and 

others. 

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9. I also have probable cause to believe that this property is subject to 

forfeiture to the United States pursuant to 18 U.S.C. § 981(a)(1)(C) because the property 

constitutes or is derived from proceeds traceable to violations of 18 U.S.C. § 1343 or a 

conspiracy to commit such offense. 

10. Any property, real or personal, which constitutes proceeds or is derived 

from proceeds traceable to a violation of 18 U.S.C. § 1343 or a conspiracy to commit 

such is subject to forfeiture pursuant to 18 U.S.C. § 981(a)(1)(C).

11. Under 18 U.S.C. § 984, for any forfeiture action in rem in which the subject 

property consists of cash, monetary instruments in bearer form, or funds deposited in an 

account in a financial institution:

a. The government need not identify the specific funds involved in the

offense that serves as the basis for the forfeiture; 

b. It is not a defense that those funds have been removed and replaced 

by other funds; and

c. Identical funds found in the same account as those involved in the 

offense serving as the basis for the forfeiture are subject to 

forfeiture. 

12. In essence, 18 U.S.C. § 984 allows the government to seize for forfeiture 

identical property found in the same place where the “guilty” property had been kept. 

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FACTS SUPPORTING FORFEITURE

13. The United States is investigating a technical support scheme. The 

investigation concerns possible violations of, inter alia, 18 U.S.C. § 1343 (Wire Fraud), 

18 U.S.C. § 1349 (Conspiracy to Commit Wire Fraud) and 18 U.S.C. §§ 1956 and 1957 

(Laundering of Monetary Instruments). 

14. The case involves the laundering of proceeds obtained from victims of the 

technical support scheme. Part of the money laundering scheme was to funnel proceeds 

from the tech fraud scheme through the various business accounts to a finite number of 

funnel accounts. One business, identified as Red Viking Global LLC, held multiple bank 

accounts that served as funnel accounts and received fraud proceeds from bank accounts 

held in the names of the shell companies that received proceeds derived from the 

technical support scheme. 

15. TARGET ACCOUNT 1 is a business checking account. Bank records 

show JON TAYLOR1

 as the owner of RED VIKING GLOBAL LLC with a business 

address of 405 Lexington Ave, New York, New York 10174. As of February 24, 2023, 

an associated website, www.redvikingglobal.com, stated, “Red Viking Global specializes 

in structuring and originating loans to individuals and institutions seeking leverage, 

liquidity, and hedges for publicly-traded securities, mutual funds, equity portfolios, and 

cryptocurrencies. We customize loans to fit your needs.” The website claimed the 

1 JON TAYLOR a/k/a JONATHAN TAYLOR was released from federal prison on April 7, 2020, after 

serving four years for Sex Trafficking by Force, Fraud, or Coercion. 

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business had offices in New York, England, China, United Arab Emirates, and Mauritius. 

The only contact information provided on the website was an email address. 

16. The opening documents for TARGET ACCOUNT 1 state that RED 

VIKING GLOBAL LLC had six employees and $0 in annual gross sales. From July 14, 

2021, through February 9, 2022, $2,399,647.02 was deposited into TARGET 

ACCOUNT 1. From February 10, 2022, through December 31, 2022, the only 

significant deposit to TARGET ACCOUNT 1 was a $1,000,000 transfer from TARGET 

ACCOUNT 2 on April 7, 2022. This transfer was funded entirely by two incoming wire 

transfers in July 2021 and September 2021 from MKCOGI Water Management in Delhi, 

India. Open-source checks show MKCOGI Water Management was incorporated in 

Delhi, India, on February 29, 2016. The listed business activity is collection, 

purification, and distribution of water. No additional information is known regarding 

MKCOGI Water Management. As of December 31, 2022, the balance in TARGET 

ACCOUNT 1 was $1,335,611.89.

17. From July 2021 through February 2022, there were 67 deposits made into 

TARGET ACCOUNT 1 via wire transfer totaling $2,149,431.75. The deposits made 

via wire transfer included:

Wire Sent By

Domestic / 

International Location

Number 

of 

Wires

Total 

Amount

JM Vacation Private 

Limited International India 31 $1,218,997.00

Summit Kochar International India 1 $204,920.75

Omegainfotek Cloud, International Canada 4 $109,920.00

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Wire Sent By

Domestic / 

International Location

Number 

of 

Wires

Total 

Amount

Inc.

Workgroup, LLC Domestic California 4 $103,150.00

Techisgroup, Inc. International Canada 5 $89,400.00

Wisdom Web Online, 

LLC Domestic Pennsylvania 2 $79,350.00

Shiva Logistics, LLC Domestic Pennsylvania 2 $49,000.00

AG Maritime Private 

Limited International Singapore 1 $40,000.00

JGJ, LLC Domestic Virginia 1 $35,000.00

Webstylers, LLC Domestic New Jersey 2 $33,000.00

Element Softnet, Inc. Domestic California 2 $30,200.00

YTP Tourism, LLC International

United Arab 

Emirates 1 $30,175.00

Holiday Hunger DMC 

Private Limited International India 1 $25,099.00

Sapphire Tech, LLC Domestic California 2 $21,000.00

Ran Ventures, LLC Domestic Nevada 2 $19,500.00

Divine Tech, LLC Domestic New Jersey 1 $15,000.00

Technet Support, LLC Domestic Pennsylvania 1 $15,000.00

Jagroop Singh Domestic Pennsylvania 1 $10,000.00

Pedro Juan Laboy 

Molinari International Puerto Rico 1 $9,720.00

Web Leaders, Inc. Domestic New Jersey 1 $6,000.00

Omegateksol, LLC Domestic Massachusetts 1 $5,000.00

Grand Total 67 $2,149,431.75

18. Complaints have been filed through the FBI’s Internet Crime Complaint 

Center (IC3) alleging computer tech schemes by at least eleven entities that deposited 

funds into the TARGET ACCOUNT 1 from July 2021 through October 2021. These 

entities and the number of associated IC3 complaints are as follows: Technet Support 

(25), Webstylers (3), Omegateksol (6), Ran Ventures (3), Techisgroup (1), Workgroup 

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LLC (6), Wisdom Web Online (10), Sapphire Tech (1), Webleaders (7), Divine Tech 

(22), and Element Softnet (1). There appear to be additional IC3 complaints regarding 

these companies, but misspellings by complainants, multiple complaints filed by 

individual victims, and reported name variations make quantification difficult.

19. On or about August 17, 2022, a federal grand jury in the Eastern District of 

Texas returned an indictment against several individuals who participated in the 

computer tech scheme. A list of those indicted and the shell companies they operated are 

identified in the table below:

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Defendant Shell Company

Fnu Ankush

Jenisha Katuwal

Expert Solutions LLC

Shiva Logistics LLC

Wisdom Web Online LLC

Sukhwinder Sandhu Cyber Secure LLC

IntellectSoftApps LLC

Inder Pal Singh Air Ticket Mode LLC

Edgenet LLC

MS Secure LLC

PC Dynamics LLC

Mukul Khanna Technet Support LLC

Webmatrix LLC

Satinder Singh Commtouch Software LLC

Dialogic Support LLC

Micron Technology LLC

Ramneek Singh Neocyber LLC

Sigma Works LLC

Muninder Singh JGJ LLC

Sandeep Heir Cloudmind Technology LLC

Rachel Mullins

Deepanshu Arora

Himanshu Arora

Angel City Transfer

Unindicted Co-Conspirator 1 Live Onecare LLC

Surface Web Solutions LLC

Worldwide Tradelinks LLC

Unindicted Co-Conspirator 2 Workgroup LLC

Unindicted Co-Conspirator 3 JGJ LLC

Unindicted Co-Conspirator 4 Commtouch Software LLC

20. Paragraph 19 of this affidavit mentions a true bill indictment that was 

obtained in the Eastern District of Texas on or about August 17, 2022. Based on the 

investigation in that case, the following victims in the Eastern District of Texas suffered 

losses as a direct result of a tech support scam. 

21. For example, victim TP who resides in the Eastern District of Texas, wrote 

and mailed approximately 9 checks totaling $23,300.00 to computer tech shell companies 

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that funneled funds to Target Account 1. Between on or about August 26, 2021 and on 

or about November 8, 2021, the payments sent by TP included:

a. On or about August 26, 2021, victim TP wrote and mailed a check payable 

to Cyber Secure LLC in the amount of $800.00. 

b. On or about September 23, 2021, victim TP wrote and scanned a check 

payable to Cyber Secure LLC in the amount of $2,500.00. 

c. On or about October 7, 2021, victim TP wrote and mailed a check payable 

to MS Secure LLC in the amount of $2,999.99. 

d. On or about October 7, 2021, victim TP wrote and mailed a check payable 

to Commtouch Software LLC in the amount of $2,800.00.

e. On or about October 19, 2021, victim TP wrote and mailed a check payable 

to Micron Technology LLC in the amount of $2,596.97. 

f. On or about October 19, 2021, victim TP wrote and mailed a check payable 

to Dialogic Support LLC in the amount of $2,739.86. 

g. On or about October 19, 2021, victim TP wrote and mailed a check payable 

to Commtouch Software LLC in the amount of $2,163.17.

22. Similarly, victim JS who resides in the Eastern District of Texas also 

suffered a loss due to the technical support scam. JS reported that this scheme caused 

him/her to write a check in the amount of $199.99. JS stated this check was made 

payable to Cyber Secure LLC, a computer tech shell company that funneled funds to 

Target Account 1.

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23. In April 2022, a law enforcement officer contacted NH, a 77-year-old 

resident of Richmond, Texas, after analysis indicated that checks written from NH’s 

personal account to Web Leaders and other companies totaled approximately $46,500. 

NH reported that he wrote checks in excess of $60,000. NH advised that he had been 

paying for computer services to “clean out viruses” and recalled speaking to technicians 

from Web Leaders, Webstylers, and another company whose name he could not recall. 

NH also recalled being told to make payment in gift cards. NH recounted traveling to a 

Randall’s grocery store in Richmond, Texas while on the phone with the technician and 

being instructed what to say if anyone inquired about his gift card purchases. NH stated 

he scratched off gift card numbers and provided those numbers as payment. NH stated he 

last paid for such services in October 2021. NH stated he then realized that he “was 

being a fool” after he spent “all his savings” on these services. 

24. In April 2022, a law enforcement officer interviewed SG, a 65-year-old 

resident of California. Financial analysis shows that SG has written numerous checks to 

Web Leaders and other similar companies including Webstylers (the same company 

referenced by NH), Web Micro Solutions, Webfixers, and Hope Technologies. 

Altogether, SG has written checks totaling approximately $114,000 to various companies 

associated with this investigation. SG stated she became concerned that she was being 

scammed because of the number of checks she had written. Consistent with other victims 

who paid Web leaders, SG iterated that she often paid the companies by writing out a 

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check and placing it on the scanner for the technician, who was remotely connected to her 

computer and scanned the check. 

25. Victim PC reported to the FBI that in 2020 or 2021 he found that his 

computer was frozen, and he had been hacked. A company called Technest told PC they 

could fix his computer, and he agreed to a multi-year plan. An “accountant” for Technest 

would virtually log into his computer and type out payment amounts, names, and 

addresses where PC was to send the funds. PC would take the list to the bank and obtain 

cashier’s checks. He mailed cashier’s checks payable to Techis, Digyleap, MS Secure 

LLC, Surface Web Solutions, Technet Support LLC, Webbloft LLC, Omegateksol, 

Skyweb IT Services, and Metconnect Inc totaling approximately $370,000. 

26. Victim CT reported to IC3 that she received a pop-up message on her 

computer stating that her computer had been hacked. CT called the number shown and 

spoke to a purported Apple employee who attempted to sell her computer security. CT 

eventually agreed to a “clean-up” and was instructed to mail a check to Techisgroup Inc. 

27. Victim ER reported that his mother, DT received a pop-up message on her 

computer stating that it was compromised. DT called a phone number listed on the popup message and spoke with someone who sold her a $2,290 subscription for internet 

security software. DT was instructed to mail a check payable to Omegateksol, and she 

was also directed to ship $19,800 to an address in Flushing, New York.

28. Victim PL reported to IC3 that a company called Webfixers, LLC contacted 

her regarding hacking protection in August 2020. Webstylers, LLC took over the 

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“Hacker Protection” in June 2021, followed by Webleaders, Inc. in September 2021. 

Each time PL was contacted, she was advised her computer was hacked. She advised 

that when she hesitated to make additional payments, she was shown her social security 

number to make her fear that she had been the victim of identity fraud. From August 27, 

2020, through November 29, 2021, PL sent 10 cashier’s checks totaling approximately 

$11,000. Valley Bank received three of the cashier’s checks paid to Webleaders, Inc. 

The wire transfer deposited on August 27, 2021, into TARGET ACCOUNT 1 from 

Webleaders, Inc. originated at Valley Bank.

29. From December 2019 through February 2022, at least ten complaints were 

filed with IC3 regarding Wisdom Web Online LLC. Victims reported being defrauded 

by tech support schemes after receiving pop-up messages on their computers. Victim GS 

reported sending cashier’s checks payable to Wisdom Web Online LLC, MS Secure 

LLC, Workgroup LLC, and ESharp Systems LLC.

30. Victim MS reported to the Pine Creek Township Pennsylvania Police 

Department that in January 2021, her computer froze, and she received a message from 

Web Support Solutions. MS called the number on the screen and was told her computer 

could be fixed if she provided remote access. Once the repair service was complete, Web 

Support Solutions told MS she owed them $11,436. MS wrote checks to Digyleap for the 

remote repair of her computer. Between January 2021 and November 2022, IC3 received 

at least 15 complaints regarding Digyleap for computer technical support fraud. In July 

2021, MS was contacted by Divine Tech, who advised her that the invoice for fixing her 

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computer had not been paid in full. MS subsequently wrote five checks totaling 

$21,198.12 to Divine Tech. 

31. Victim JM reported to IC3 that in 2019, she began paying Infotech 

Solutions for security on her computer. She was subsequently offered lifetime computer 

security, for which she paid $10,380.60. She was instructed to call Infotech Solutions 

every month for a check-up. In 2020, she was told her computer had been hacked and 

she would need to pay Infotech Solutions $8,155. An Infotech Solutions employee asked 

JM how much money she had in her bank account, and she realized she had been 

scammed. 

32. Victim KG reported to IC3 that he was the victim of a computer intrusion 

in late 2020. In order to have the computer fixed, KG was advised by Technest Solutions 

that he would have to mail a check for $4,994 to Element Softnet, 2010-A Harbison 

Drive, #457, Vacaville, California. KG realized he had been scammed and stopped 

payment on the check. However, representatives from Element Softnet continued 

contacting him for months. On October 7, 2021, and October 21, 2021, two wires for 

$15,100 each from Element Softnet were deposited into TARGET ACCOUNT 1. The 

address shown on bank records for Element Softnet was 2010-A Harbison Drive, #457, 

Vacaville, California.

33. Victim GS reported to IC3 that between May 2020 and October 2021, he 

was victimized by a computer technical support scam. As a result, GS sent 53 checks 

totaling more than $115,000 to various locations at the direction of the scammers, 

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including to MS Secure LLC, Workgroup LLC, ESharp Systems LLC, and Wisdom Web 

Online at 1712 S. 7th Street, Philadelphia, Pennsylvania, the same address used by Shiva 

Logistics.

34. Shiva Logistics was registered as a transportation company in Pennsylvania 

on February 25, 2021. TARGET ACCOUNT 1 received wire transfers from Shiva 

Logistics on July 15, 2021, and July 20, 2021 totaling $49,000. The reported owner of 

Shiva Logistics is Jenisha Katuwal.2

Additional wire transfers identified.

35. A wire transfer deposited into TARGET ACCOUNT 1 from Webstylers, 

LLC on July 20, 2021, in the amount of $23,000 originated from Columbia Bank account 

ending in 0736. Webstylers LLC is the target of an FBI Newark investigation wherein 

victims are convinced their computers have a virus and offer to repair the computer for a 

fee. Investigators have identified more than 100 deposits made into account ending in 

0736 by fraud victims, including by WGL, who also deposited funds into another account 

uncovered in this investigation.

36. On July 21, 2021, a $5,500 wire transfer from Ran Ventures LLC, 5470 

Kietzke Lane, Suite 300, Reno, Nevada, was deposited into TARGET ACCOUNT 1. 

Between March 2021 and October 2022, at least three complaints were filed with IC3 

regarding Ran Ventures. All three of these complaints involved victims whose 

2 Jenisha Katuwal is a defendant under indictment in 6:22-CR-111 for violating 18 U.S.C § 1349.

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computers were remotely accessed in a tech support fraud scheme. The victims reported 

sending checks to Ran Ventures, 5470 Kietzke Lane, Suite 300, Reno, Nevada, the same 

address used with victims PC and DT.

37. On August 4, 2021, a $35,500 wire transfer from Workgroup LLC was 

deposited into TARGET ACCOUNT 1. From April 2020 through February 2022, at 

least six complaints were filed with IC3 regarding Workgroup LLC. All six victims 

reported being defrauded through tech support schemes after pop-up messages appeared 

on their computers. Victim JR reported sending checks totaling $21,901.16 payable to 

Workgroup LLC, NeoCyber LLC, CommTouch Software LLC, Sigma Workforce LLC, 

Cyber Secure LLC, and MS Secure LLC from June 2, 2021, through August 11, 2021.

38. On August 18, 2021, and August 27, 2021, wire transfers for $15,000 and 

$6,000 respectively, from Sapphire Tech LLC were deposited into TARGET 

ACCOUNT 1. 

39. From July 2021 through February 2022, TARGET ACCOUNT 1 received 

$605,520.00 of confirmed fraud proceeds from shell companies that received victim 

funds of computer tech fraud schemes.

Target account 2 transaction activity.

40. On July 21, 2021, TARGET ACCOUNT 2 was opened with a $1,000 

deposit in the name of RED VIKING GLOBAL LLC. JON TAYLOR was the sole 

owner. The account opening documents claimed that RED VIKING GLOBAL LLC had 

two employees and $3,000,000 in annual gross sales, although no banking activity in 

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support of such sales was observed in any of the TARGET ACCOUNTS prior to July 

2021. Under “Description of Business”, the opening documents state, “Consults with

debts and entities (sp) overseas.” Open-source documents also show that RED VIKING 

GLOBAL LLC was registered as a Florida business on July 21, 2021, although it was 

previously registered as a Wyoming business on May 27, 2020, shortly before TARGET 

ACCOUNT 1 was opened on July 24, 2020. 

41. On July 29, 2021, TARGET ACCOUNT 2 received a $1,892,606.36 wire 

transfer from MKCOGI Water Management in Delhi, India. The note associated with the 

wire transfer states, “ODI Under Equity Purchase.” On September 28, 2021, TARGET 

ACCOUNT 2 received a $228,450 wire transfer from MKCOGI Water Management in 

Delhi, India. The note associated with the wire transfer also states, “ODI Under Equity 

Purchase.” From June 1, 2022, through December 1, 2022, $34,000 was transferred 

from TARGET ACCOUNT 1 to TARGET ACCOUNT 2. No other significant 

deposits were made to TARGET ACCOUNT 2. 

42. On April 7, 2022, a $1,000,000 transfer from TARGET ACCOUNT 2

was made to TARGET ACCOUNT 1. 

43. TARGET ACCOUNT 3 was opened in the name of JON TAYLOR on 

May 8, 2020. On July 8, 2021, the balance in TARGET ACCOUNT 3 was $1.44. 

From July 2021 through November 2022, TARGET ACCOUNT 3 received the following 

transfers:

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Date Amount Source Account

7/15/2021 $10,000.00 TARGET ACCOUNT 1

7/16/2021 $20,000.00 TARGET ACCOUNT 1

7/22/2021 $47,000.00 TARGET ACCOUNT 1

7/30/2021 $200,000.00 TARGET ACCOUNT 2

8/2/2021 $200,000.00 TARGET ACCOUNT 2

8/10/2021 $88,000.00 TARGET ACCOUNT 1

8/23/2021 $93,000.00 TARGET ACCOUNT 2

8/23/2021 $97,000.00 TARGET ACCOUNT 1

9/24/2021 $150,000.00 TARGET ACCOUNT 1

9/24/2021 $300,000.00 TARGET ACCOUNT 2

5/12/2022 $130,000.00 TARGET ACCOUNT 2

8/23/2022 $240,000.00 TARGET ACCOUNT 1

11/17/2022 $35,000.00 TARGET ACCOUNT 1

44. As of January 9, 2023, the balance in TARGET ACCOUNT 3 was 

$41,827.36. As shown above, TARGET ACCOUNT 3 is nearly entirely funded by 

TARGET ACCOUNT 1 and TARGET ACCOUNT 2. 

CONCLUSION 

45. I submit that this affidavit supports probable cause for a warrant to forfeit 

all funds, monies, and other things of value up to $1,029,155.26 seized from Wells Fargo 

Bank accounts 6945288279, 2089226720 and 9068111294 . 

46. Based on my experience and the information herein, I have probable cause 

to believe that the seized $1,029,155.26 constitutes proceeds from a specified unlawful 

activity (as defined in 18 U.S.C. § 1956(c)(7) and 18 U.S.C. § 1961(1)), are traceable to a 

money laundering transaction and are therefore subject to forfeiture pursuant to pursuant 

to 18 U.S.C. § 981(a)(1)(A). 

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47. I also have probable cause to believe that the seized $$1,029,155.26 

constitutes proceeds traceable to a violation of 18 U.S.C. § 1343 and/or 18 U.S.C. § 1349, 

and are therefore is subject to forfeiture pursuant to 18 U.S.C. § 981(a)(1)(C). 

As provided in 28 U.S.C. § 1746, I declare under penalty of perjury that the 

foregoing is true and correct.

Brad Schley, Special Agent 

U.S. Secret Service

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