alimamy barrie affidavit

8/7/2019 Alimamy Barrie Affidavit

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IN THE UNITED STATES DISTRICT COURT FOR THEEASTERN DISTRICT OF VIRGINIA

Alexandria Division

p Lir MAR 3 1 2011LJLfcHK, U.S. DISTRICT COALEXANDRIA. VIHGIMIA

UNITED STATES OF AMERICAv .

ALIMAMY BARRIE,Defendant .

AFFIDAVIT IN SUPPORT OFCOMPLAINT AND ARREST WARRANT

I, James R. Conner III, being duly sworn, depose and say:1. I am a Special Agent of the Federal Bureau of Investigation (FBI) and have

been so employed since February 1995. I am assigned to the FBI's Washington FieldOffice and work on a squad that investigates bank fraud and identity theft.

2. This affidavit is submitted in support of an application for a complaint andarrest warrant for ALIMAMY BARRIE (BARRIE) for committing Identity Fraud, Title 18United States Code, Section 1028A.

3. The facts and information contained in this affidavit are based upon mypersonal knowledge and observations as well as the knowledge and observations ofother law enforcement agents involved in this investigation. I intend for this affidavit tocontain sufficient information to support probable cause, but not to include every factknown to the government.

4. The victim in this matter is PC, a 64 year old white male who l ives inGainesville, VA. PC's date of birth is February 8,1947. PC was recently diagnosedwith a terminal illness and in-home nurse aides provide 24 hour care. PC has a

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CRIMINAL NO. 1:11MJ250

Case 1:11-mj-00250-IDD Document 3 Filed 03/31/11 Page 1 of 7


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retirement account at T. Rowe Price.5. On December 16, 2010, a representative from T. Rowe Price contacted the

FBI to report a possible identity theft and theft of assets of T. Rowe Price account holderPC. Specifically, on December 10, 2010, T. Rowe Price had received a call from PNCBank in Columbus, Ohio, concerning PNC Bank account holder PC. T. Rowe Pricewastold that PNC Bank customer, PC, had deposited approximately $80,000 in checks fromT. Rowe Price into his account at PNC Bank (account # ending in 5806).

6. PNC Bank account # ending in 5806was opened on October25,2010, by acustomer, known to PNC Bank as PC, who came into the Sharon Woods branch of PNCBank in Columbus, Ohio. Photographs provided by PNC Bank from cameras inside thePNC Bank branch reveal that th e m an known to PNC Bank a s PC is a black male. Bankrecords indicate that this account (# ending in 5806) was opened using Ohio IdentificationCard # ending in 8599 and Republic of Sierra Leone passport # ending in 7242. Thename on both forms of identification was PC, and his date of birth on both forms ofidentification was February 8,1979.

7. At about this time, T. Rowe Price also learned that approximately $500,000from the real PC's T. Rowe Price account had been deposited into account # ending in4448 inthe name PC at JP MorganChase Bank. JP Morgan Chase account # ending in4448 was opened on September 29, 2010, by a customer known to JP Morgan ChaseBank as PC, who came into the Columbus Square branch of JP Morgan Chase Banklocated in Columbus, Ohio. This account was opened using Ohio Identification Card# ending in 8599 and Republic of Sierra Leone passport # ending in 7242. The name onboth forms of identification was PC, and his date of birth on both forms of identification

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was February 8, 1979. Bank records also show JP Morgan Chase Bank account# ending in 5212 in the name PC was opened by the same man using the same forms ofidentification at the same branch on October 25 , 2010.

8. A review of records from T. Rowe Pri ce ind icat es that assets were removedfrom the real PC's T. Rowe P ri ce account in the form of check s t ha t were mail ed to acertain residence in Columbus, Ohio and then deposited into th e new PC bank account atPNC Bank (# ending in 5806). Assets from the real PC's T. Rowe Price account werealso removed in the form of wire transfers to the new PC account at JP Morgan ChaseBank (# ending in 4448).

9. T. Rowe Price determined that the funds sent to PNC Bank and JP MorganChase by checks and wire transfers came out of the retirement account of their client, thereal PC. After years of little activity, on-line access was established to the real PC'saccount at T. Rowe Price in July 2010. At about the same time, th e address for theaccount was changed from that of a residence in Gainesville, Virginia, to a residence inColumbus, Ohio.

10. T. Rowe Price contacted their client, the real PC, by telephone onDecember 10,2010. The real PC told T. Rowe Price t ha t h e had not transferred fundsout of his T. Rowe Price account and had not moved t o Ohio. The real PC stated that hehad not accessed his account by the internet. The real PC gave the phone to his nurse,who stated that the real PC could not have made transfers through the use of the internet.

11. I interviewed the real PC on December 22, 2010, at his home in Gainesville,Virginia. The real PC retired from the FDIC approximately five years ago and wasrecently diagnosed with a terminal disease. The real PC lives alone at his residence in

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Gainesville, Virginia, but is assisted by a nurse aide at all times. The real PC stated thathe has his retirement account at T. Rowe Price but has not made any recent transfersfrom this account. The real PC further stated he has not authorized anyone else to movemoney out of his retirement account at T. Rowe Price. The real PC does not have acomputer and does not access the internet. In his capacity as daytime caregiver, hisnurse aide assists the real PC in paying his bills. The daytime caregiver is from SierraLeone .

12. The Ohio Bureau of MotorVehicles (OBMV) provided a copy of OhioIdentificationCard # ending in8599 inthe name PC issued on September28,2010, at theOBMV branch located at 3481 East Broad Street, Columbus, Ohio. This OhioIdentificationCard contains a photograph of the person to whom itwas issued and listshis date of birth as February 8,1979. It also lists an address in Columbus, Ohio as hisresidence. The man in the photograph is a black male and is much younger than the 64year old white male I interviewed on December 22, 2010.

13. Republic of Sierra Leone passport # ending in 7242 inthe name PCcontains a photograph ofa blackmale. The blackmale in the photograph on thepassport is not the white male I interviewed on December 22, 2010.

14. Ireviewed bank records of two separate accounts held at JP Morgan Chasein the name PC. The two account numbersare # ending in 4448 and # ending in 5212.From October18, 2010 to December 1, 2010, ninewire transfers totaling $476,038.83were wired from the real PC's retirement account at T. Rowe Price to account# ending in 4448. From November 1, 2010 to November 29, 2010, internal transferstotaling $340,500were made from account # ending in4448 to account # ending in 5212.

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Several checks were written from JP Morgan Chase account # ending in 5212 in thename PC, including three payable to ANS Auto Sales ofTeterboro, New Jersey, totaling$127,000.

15. The owner of ANS Auto Sales was interviewed on February 24, 2011. Hestated that an African male visited his car dealership in November 2010, wanting to buycars to ship to Africa. The African male presented Ohio Identification Card (# ending in8599) in the name of PC, but told the owner that the identification card belonged to hisbrother who had recently moved back to Africa. On his first visit, the African male paid$35,000 for a Mercedes Benz, and on his second visit he paid $92,000 for a Hummer, anAudi, and a Range Rover. The African male paid for the vehicles with checks from theJP Morgan account # ending in 5212. The African male paid to have three of the carsshipped to an address in Hyattsville, Maryland. The owner provided vehicleidentification numbers for three of vehicles, and a photocopy of Ohio Identification Card(# ending in 8599). ANS Auto Sales' records list the Vehicle Identification Number (VIN)on the Hummer as 5GTEN13E688124722, th e VIN on the Mercedes Benz as4JGBB86E98A355237, and th e VIN on the Range Rover as SALSF25446A929067.

16. I determined that the address in Hyattsville, Maryland to which the carswere sent is the address of USNAD Import and Export (USNAD). I interviewed theowner of USNAD on March 15, 2011. He recalls shipping several vehicles, including aHummer, a Mercedes Benz, and a Range Rover, on behalf of his customer, ALIMAMYBARRIE. BARRIE has been a repeat customerwho has appeared on numerousoccasions at USNAD to conduct business. The owner was shown the PC photographprovided by the Ohio Department of Motor Vehicles, and several surveillance photos of

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the person conducting banking business as PC provided by PNC Bank. The owner, withcertainty, identified his customer, ALIMAMY BARRIE, as the person in all of the photos.The owner also provided documentation from his files indicating the vehicles from ANSAuto Sales were among vehicles that USNAD has shipped for BARRIE. USNAD'srecords document that it shipped a Hummer with VIN 5GTEN13E688124722, aMercedes Benz with VIN 4JGBB86E98A355237, and a Range Rover with VINSALSF25446A929067, on behalf of BARRIE in November and December 2010.

17. A review of public data bases and law enforcement data bases located aperson named ALIMAMY BARRIE, date of birth June 21,1983. This person was issuedMaryland Driver's License # ending in 3475. Iobtained a copy of this License. A reviewofthe image on this driver's license, in myopinion, shows that it is the same persondepicted on Ohio Identification Card (# ending in 8599) in the name PC, and all of thesurveillance photos from PNC Bank.

18. A query of United States Customs data bases indicates a man namedALIMAMY BARRIE with date of birth June 21,1983, traveled to the United States fromBrussels, Belgium on United States passpor t # ending in 6338 on May 22, 2010. OnDecember 16, 2010, BARRIE flew back to Brussels. I obtained a copy of passport# ending in 6338 and examined the photograph contained on the passport. Inmyopinion, the man depicted on the passport is the same man shown inthe MarylandDriver's License # ending in 3475, Ohio Identification Card (# ending in8599), and thebank surveillance photos from PNC Bank.

19. Persons believed to be friends or relatives ofALIMAMY BARRIE residing inColumbus, Ohio and in Maryland have held or currently hold licenses as nurse aides.

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20. Based on the information contained in the paragraphs above, I believe thatthere is probable cause to believe ALIMAMY BARRIE committed identity fraud and thatprobable cause exists for his arrest. As such, I respectfully request that a complaint andan arrest warrant be issued fo r ALIMAMY BARRIE.

Sworn to and subscribedin my presence this 3/-*day of March ,2011.

M .Ivan D. DavisUnited States Magistrate Judge

le s R. Conner IIIserial AgentFederal Bureau of Investigation


alimamy barrie affidavit

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