Affidavit For Warrant - Sterling Island

U.S.
District Court
District of New Mexico - Version 6.1 (Albuquerque)
CRIMINAL DOCKET FOR CASE #: 1:15-mr-00664-KBM-1
Case title: USA v. Warrant Date Filed: 10/26/2015
Assigned to: Magistrate Judge Karen B.

Molzen
Defendant (1)
Warrant
5815 Menaul Blvd. Albuquerque, New
Mexico 87110
Pending Counts Disposition

None
Highest Offense Level (Opening)

None
Terminated Counts Disposition

None
Highest Offense Level (Terminated)

None
Complaints Disposition
None
Plaintiff
USA representedby Kristopher N Houghton
United States Attorney
201 3rd Street NW
Suite 900
Albuquerque, NM 87114
505-224-1412
Fax: 505-346-7296
Email: kristopher.houghton@usdoj.gov
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: Retained
Date Filed # Docket Text

10/26/2015 1 Application and Afdavit for Search Warrant before Magistrate Judge Karen B. Molzen.
(nm) (Additional attachment(s) added on 10/27/2015: # 1 Afdavit pt 1, # 2 Afdavit pt 2)
(nm). (Entered: 10/27/2015)
10/26/2015 2 Search Warrant Issued by Magistrate Judge Karen B. Molzen. (nm) (Entered: 10/27/2015)
10/29/2015 3 MOTION to Unseal All Filings Related to the Matter of the Search of the Various Locations
and Vehicles and Seizure of Various Bank Accounts by USA (emr) (Entered: 10/29/2015)
10/29/2015 4 ORDER by Magistrate Judge Karen B. Molzen granting MOTION to Unseal All Filings
Related to the Matter of the Search of the Various Locations and Vehicles and Seizure of
Various Bank Accounts (emr) (Entered: 10/29/2015)
11/02/2015 5 Search Warrant Returned Executed on 10/28/15 (kd) (Entered: 11/02/2015)
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Case 1:15-mr-00664-KBM Document 1 Filed 10/26/15 Page 1 of 7
AO 106 (Rev. 04/10) Applic tion for a Search Warrant
UNITED STATES DISTRICT CO~'feos!'JLED

ATES DISTR
for the Al.BUQUERQUE N ICT COURT
i
District of New Mexico ' EW MEXIC()
In the Mat~er of the Search of Vocr 262015

)
(Briefly describerhe property to be searched
or identify the p rson by name and address)
)
) Case No. MATTHEW J. DYKMAN
58 5 Menaul Blvd. ) CLERK
)
Albuq erque, NM 87110
) /)Mrll'-(
I, a federal It.I
APPLICATION FOR A SEARCH WARRANT
enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury th t I have reason to believe that on the following person or property (ide~tify the person or describe the
property to be searched a d give its location):
SEE ATTACHMEN A, ATTACHED HERETO AND INCOPORATED BY REFERENCE

located in the I District of New Mexico , there is now concealed (identify the
person or describe the pr erty to be seized):
SEE ATTACHMENi B, ATTACHED HERETO AND INCOPORATED BY REFERENCE
The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
~ evid nee of a crime;
~ contr band, fruits of crime, or other items illegally possessed;
~prop rty designed for use, intended for use, or used in committing a crime;
0 a perfon to be arrested or a person who is unlawfully restrained.
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The search is related to a violation of:

Code Secti n Offense Description
18 USC 1159 Sale of items falsely represented to be made by a Native American tribe or
particular Native American artisan (Indian Arts and Craft Act)
The applicati n is based on these facts:
SEE ATTACHFD AFFIDAVIT
~ Continue~ on the attached sheet.

0 Delayed ~~tice of days (give exact ending date if more than 30 days:
under 18 lu.S.C.
3 !03a, the basis of which is set forth ovched she t.
l,l ----1----'---S-p_e_ci~a'---IA-1---ge_n_t_R~u_s_s~e"'-ll+S-ta-n-fo_r_d_ _ _ __
Printed name and title
Sworn to before me ard signed in my presence.
Date: {)r.;t_~ ~J 1
&D/S-
City and state: _A_l_b_u4-+-u_e_r~q_ue_,_N_M_ _ _ _ _ __ Chief United States Magistrate Judge Karen B. Molzen
Printed name and title
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Attachment A
Description of PREMISES to be Searched
The property to be searched is the business of Sheda Khalaf and Jawad Khalaf, located at
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5815 Menaul f lvd., Albuquerque, NM 87110. The prope1iy consists of one commercial
property, as fufther described in Attachment A (hereinafter, the " Subject Premises").
Sheda Khalaf and Jawad Khalaf are listed as the President and Vice President of Sterling
Islands, respedtively.
The lol ation is depicted below and is a ,one-story building, white in color. The name of
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the business, 'lSterling Islands," is depicted on the sign in front of the building. There are two
(2) exterior en rances to the business, one in front (South side) and one at the back (North side)
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of the building.
Subject Premises (Sterling Islands dba National Jewelry Buyers)

Attachment B
l Description of Items to Be Seized

Items be searched, located, and seized from 5815 Menaul Blvd., Albuquerque, NM
87110, and al locked and closed containers therein (the "premises") include the following:
1. Jewel manufactured by FA4U.

2. rds or materials - in whatever form, including digital or electronic, showing
evidence, fruit , and instrumentalities of violations 18 U.S.C. 542 (importation by false or
fraudulent pra tice ), 19 U.S.C. 1304 (failure to mark goods with country of origin), 18 U.S.C.
1159 (violat on of the Indian Arts and Crafts Act), and 18 U.S.C. 371 (conspiracy), including
but not limite to:
a. records that relate to the acquisition, transfer, sale, purchase or shipment of the
above listed it ms, correspondence with buyers and sellers, purchase orders, invoices, financial
ledgers, logs, elephone records, travel documents, wire fund transfers, receipts, notebooks,
memoranda, streadsheets, rolodex or address books, appointment calendars, business and
personal ledg s, internet transactions, such as eBay or Craigslist, Paypal transactions, cancelled
checks and ch ck registers, photographs, videos, DVDs, emails, shipping documents,
certificates, d bank records;
b. Financial documents, including mortgage, loan and lease documents, payment
records for ite s of value, bank and brokerage account statements, check registers, deposit slips,
records of tra sfers, wire transfer instructions and records, safety deposit records, storage unit
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records and rep eipts, cashier's checks, personal checks, and other items demonstrating a business
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purpose, acqusition of property, or transfer of funds to, by, and between the subjects of this
investigation;
c. Corporation and personal income tax information, including both state and
federal, and w rking tax returns, personal (IRS Form 1040) and corporate federal (IRS
Forms1065 a 1120) returns, and state tax returns for tax years 2010 through 2015, including:
tax questionn ires, income and expense logs and records, profit and loss statements, ledgers,
journals, daily receipts, general reports, accounting reports, work papers, correspondence, notes,
financial sche ules and reports, memorandums, loans contracts and agreements, accounting
records, finan ial statements, bookkeeper and accountant records, W-2s, W-4s, 1099s, 1098s,
and all documrnts and records used in the preparation of tax returns; and
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d. Employment Records, including records showing the income S<jllrces for the .t.lhn.../
A ..,.,S('e...-,7,~p/'...,o/~ f.'). f1'0Jr-
subjects as we 1 as employee records for FA4U, such as payroll records, time sheets, employee
applications, p yroll service agreements, payroll tax records, and federal and state income tax
records such a W-2s and W-4s, 1099s, IRS Forms 940 and 941, state EDD (Employment
Development epartment) forms showing quarterly wages and withholding for employees, and
federal and sta ~ partnership/corporate income tax returns.
3. Comp ters or storage media used as a means to commit the violations described above,
including send~ng electronic communications in furtherance of a scheme to violate the Indian

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Arts and Craftf Act.
4. For anf computer or storage medium whose seizure is otherwise authorized by this
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warrant, and ary computer or storage medium that contains or in which is stored records or
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information thft is otherwise called for by this warrant (hereinafter, "COMPUTER"):
a. evifence of who used, owned, or controlled the COMPUTER at the time the things
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desrribed in this warrant were created, edited, or deleted, such as logs, registry
entties, configuration files, saved usemames and passwords, documents, browsing
history, user profiles, email, email contacts, "chat," instant messaging logs,
phfto graphs, and correspondence;
b. evi~ence of software that would allow others to control the COMPUTER, such as
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vir~ses, Trojan horses, and other forms of malicious software, as well as evidence of
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thel presence or absence of security software designed to detect malicious software;
c. ev*ence of the lack of such malicious software;

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d. evi~ence indicating how and when the computer was accessed or used to determine
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thel chronological context of computer access, use, and events relating to crime under
in+stigation and to the computer user;

e. evi ence indicating the computer user's state of mind as it relates to the crime under
inv stigation;
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f. evirence of the attachment to the COMPUTER of other storage devices or similar

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co*ainers for electronic evidence;

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g. ev*ence of counter-forensic programs (and associated data) that are designed to

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eli1finate data from the COMPUTER;

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h. evt ence of the times the COMPUTER was used;
I. pa swords, encryption keys, and other access devices that may be necessary to access
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thel COMPUTER;
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J. do~umentation and manuals that may be necessary to access the COMPUTER or to

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co1duct a forensic examination of the COMPUTER;

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k. recprds of or information about Internet Protocol addresses used by the COMPUTER;

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1. recprds of or information about the COMPUTER's Internet activity, including
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firf wall logs, caches, browser history and cookies, "bookmarked" or "favorite" web
pates, search terms that the user entered into any Internet search engine, and records
of ser-typed web addresses; .

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m. co~textual information necessary to understand the evidence described in this

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att~chment.
5. Routers, modems, and network equipment used to connect computers to the
Internet.
6. As used above, the terms "records" and "information" includes all forms of
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creation or st~rage, including any form of computer or electronic storage (such as hard disks or
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other media t~at can store data); any handmade form (such as writing); any mechanical form
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(such as printi g or typing); and any photographic form (such as microfilm, microfiche, prints,
slides, negativ s, videotapes, motion pictures, or photocopies).
7. The term "computer" includes all types of electronic, magnetic, optical,
electrochemicfl, or other high speed data processing devices performing logical, arithmetic, or
storage functi~ns, including desktop computers, notebook computers, mobile phones, tablets,
server comput~rs, and network hardware.

The tetm "storage medium" includes any physical object upon which computer data can
be recorded. f xamples include hard disks, RAM, tloppy disks, flash memory, CD-ROMs, and
other magnetif or optical media.

Case 1:15-mr-00664-KBM Document 1-1 Filed 10/26/15 Page 1 of 35
DISTRICT OF NEW MEXICO
ALBUQUERQUE, NEW MEXICO
AFFIDAVIT IN SUPPORT OF SEARCH WARRANTS

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I, RUSSELL STANF~RD, having been sworn, depose and state as follows:

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I. AGENT'S B;\CKGROUND
I am a Special Agent (SA) of the Department of Interior, United States Fish and Wildlife Service, Office
of Law Enforcement (USFWS/OLE) and have been so employed since August 2008. Before becoming a
Special Agent, I serve six years as a Wildlife Inspector with the USFWS/OLE at the port of New York. I have
approximately thirtee years of law enforcement experience and am currently assigned to the Albuquerque,
New Mexico field office. I successfully completed the Criminal Investigator Training Program and the USFWS
Special Agent Basic School at the Federal Law Enforcement Training Center (FLETC). I have also attended
many conferences, seminars, and in-service training courses sponsored by a variety of professional
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organizations and la+ enforcement agencies. Prior to my federal service, I earned a Bachelor's Degree in
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Wildlife Managemen1 at Frostburg State University in Frostburg, Maryland. .

As a federal la/W enforcement agent, I am authorized to investigate possible violations of federal law and
to execute search warrants issued under the authority of the United States. I have authored and/or assisted in
numerous search warrant applications and have executed those warrants in the performance of my law
enforcement duties. 1
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II. PURPOSf OF THE SEARCH WARRANTS
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Since 2012, ~e Department of the Interior, USFWS, and the Indian Arts and Crafts Board ("IACB")
have been conducting a nationwide investigation of the sale of counterfeit Native American jewelry. I am the
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lead investigator and have been attached to the IACB since March of 2012. As such, I am responsible for
investigating violatio~is of the Indian Arts and Crafts Act.
Based on this investigation, I know that Sterling Islands esterling"), and other businesses associated
with Sterling ("the terling Coalition"), work in concert to design, import and fraudulently sell counterfeit
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Native American jewblry in violation of the Indian Arts and Crafts Act, specifically 18 U.S.C. 1159. I also
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have discovered that imembers of the Sterling Coalition, including, but not limited to, Jawad Tawfiq Khalaf,
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Sheda Khalaf, Nader Khalaf, Nashat Khalaf, Zaher Mostafa, Arafat H. Nimer, Mohammad Manasra, Nael Ali,
Christina Bowen, Mqhammad Sharifi, Soraya Sharifi, Yousef Nassar, Taha Shawar, Ismael Momeni, and Ala
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Shawabkeh have beep linked to the operation of approximately ten retail and wholesale businesses that sell
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Sterling's counterfeit Native American-style jewelry in New Mexico. These businesses, primarily located in
areas of high tourist activi y, are used by the Sterling Coalition to fraudulently sell Native American-style
jewelry, which was manufactured in the Philippines, as genuine Native American-madejewelry. The following
diagram was produced to visually depict the relationships among the Sterling Coalition that my investigation
has uncovered:
1
Fashion Accessories 4 U
(Philippines)
Jawad Khalaf
IMPORTER MANUFACTURER
WHOLESAliRs
ANJewe~ Al Zuni
Arafat/Marla NashKhafl(
.~.![
Mohammad
"'
RETAIL
MP!'Jlnrs Gallery Gold House Galerle Azul Galery8 Stier Coyote Bulon Jewelers
(GSNM)
lsmaU~,nl Ala:~Jlm.b..Hh t!H!AB ~Al Yousef Mwl(. l!!!!Sba>Yll
.J \. .J \. J \. .;/ .I ~ .,,,
"" I \.
2
This affidavit is submitted in support of applications to search the following premises, described more
particularly in Attacpment A, which is attached hereto and fully incorporated herein. A more complete
description of the faqts .establishing probable cause is set forth in Part V below. There is probable cause to
believe that the items to be seized as described in Attachment B, which is attached hereto and fully incorporated
herein, will be locateq at the premises described in Attachment A, and are evidence, fruits, and instrumentalities
of violations of 18 U.S.C. 542 (importation by false or fraudulent practice), 19 U.S.C. 1304 (failure to mark
goods with country qf origin), 18 U.S.C. 1159 (violation of the Indian Arts and Crafts Act), and 18 U.S.C.
371 (conspiracy).
No. Busine~s Name Search Location/ Pro_p_erty Role

1 Sterlin&, Islands 5815 Menaul Blvd. Albuquerque, NM Importer I
Wholesaler
2 AlZun 1603 West Hwy 66, Gallup, NM Wholesaler
3 Galler~ 8 1919 Old Town Road NW #8, Retailer

Albuquerque, NM
4 Galleri~ Azul 326A San Felipe St., Albuquerque, NM Retailer
87104
5 Mohan1 mad Manasra 2011 Chevrolet Express G 1500 Cargo Van Wholesaler/
(Sole P oprietor) NM license plate number "NHR850" Retailer
VIN "lGCSGAFXOBl 140402"
2005 Dodge Grand Caravan

NM license plate number "MLA224"
VIN "2D4GP44L55R166343"
2002 Mercedes-Benz 500ML

NM license plate number "MWH283"
VIN "4JGAB75E52A323268"
6 A.N. Jtjwelry 2304 Cagua Dr. NE, Albuquerque, NM Wholesaler
7 Sundaqcer Jewelry 202 San Felipe NE, Ste. A, Albuquerque, Retailer

NM
8 Silver oyote 112 Old Santa Fe Trail, Santa Fe, NM Retailer
9 Mome~i's Gallery 222 Old Santa Fe Trail, Santa Fe, NM Retailer

87501
10 Gold House LLC 218 Old Santa Fe Trail, Santa Fe, NM Retailer
87501
The facts con~ained in this affidavit are based upon my training and experience as well as the training
and experience of ot~r law enforcement agents and officers, information related to me by other agents and
officers, and knowle~ge acquired from other sources during the course of this investigation. The investigatory
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techniques include, b tare not limited to, surveillance, undercover operations, forensic analysis, a review of
import documents an declarations, travel documents, bank records and other financial documents, other
interviews and record research, trash recovery operations, and interviews with Native American artists and
industry experts. Thi affidavit is intended to show that there is probable cause for issuance of the search
warrants and does no purport to set forth all of the evidence gathered to date during this three-year-long
investigation.
III. BACKG OUND OF THE INDIAN ARTS AND CRAFTS ACT
On August 27 1935, Congress created the Indian Arts and Crafts Board (IACB) to improve the
economic status of N tive Americans through the development and promotion of authentic Native American
arts and crafts. 49 St t. 891; 25 U.S.C. 1158-1159. The 1935 Act adopted criminal penalties for selling
items misrepresented s Native American made. This provision, which set fines not to exceed $500 or
imprisonment not to xceed six months, or both, proved to be ineffective at stemming the flood of counterfeit
Native American arts and crafts in the market.
In response to growing sales of counterfeit Native American arts and crafts negatively impacting the sale
of authentic Native A erican products, Congress passed the Indian Arts and Crafts Act (IACA) of 1990, P.L.
101-644 (Act). Toda , these counterfeits include a flood of overseas knock-offs, are tied to organized crime,
and severely undercu Native American economies, self-determination, cultural heritage, and the future of an
original American tre sure. This Act is designed as a truth-in-advertising law meant to prevent products falsely
marketed as "Indian ade" when the products are not, in fact, made by Indians as defined by the Act. The
relevant criminal port"on of the Act reads as follows:
(a) It is unlawful o offer or display for sale or sell any good, with or without a Government
trademark, in manner that falsely suggests it is Indian produced, an Indian product, or the
product of a p rticular Indian or Indian tribe or Indian arts and crafts organization, resident
within the Un ted States.
(b) PENALTY. Any person that knowingly violates subsection (a) shall-
( 1) in e case of a first violation by that person-
(A) ifthe appl"cable goods are offered or displayed for sale at a total price of $1,000 or more, or
if the applicable goods are sold for a total price of $1,000 or more-
(i) in the case fan individual, be fined not more than $250,000, imprisoned for not more than 5
years, or both ....
18 U.S.C. 1159. Atubsequent amendment, the Indian Arts and Crafts Amendments Act of2010, P.L. 111-
211, allowed the IAC to refer cases to any federal law enforcement officer for investigation. In 2012, in
response to the growi g problem of counterfeit Native American arts and craft products, the IACB entered into
a Memorandum of A~reement with the USFWS/OLE to develop an investigative unit to pursue violations of
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IACA. I was the first special agent attached to that unit, and the requested search warrants supported by my
investigation are in fl therance of that unit's mission.
IV. THE FE ERAL CHARGES RELATED TO THIS INVESTIGATION

As a result of his long-term investigation, on Tuesday, October 20, 2015, a federal grand jury sitting in
Albuquerque, in the istrict of New Mexico, handed down a 4 count indictment (Criminal No. 14-CR-455
(JCH)), against 3 me bers or associates of the Sterling Coalition, as follows:
Count 1
1. From nor about November 26, 2012, and continuing to on or about June 5, 2014, in
Bernalillo Count in the District of New Mexico and elsewhere, the defendants, NAEL ALI,
CHRISTINA B WEN, and MOHAMMAD MANASRA, knowingly, unlawfully and willfully
combined, conspi ed, confederated, agreed, and acted interdependently with one another and with others
known and unkno n to the Grand Jury to commit violations of the Indian Arts and Crafts Act, contrary
to 18 U.S.C. 11 9.
Manner and Means

2. It was art of the conspiracy that NAEL ALI would make regular payments to
MOHAMMED ANASRA to supply NAEL ALi's jewelry stores with Native American-style
jewelry manufact ed in the Philippines.
3. It was urther part of the conspiracy that at NAEL ALi's jewelry stores, NAEL ALI and his
employees, inclu ing CHRISTINA BOWEN, would display, offer for sale and sell the Filipino-
manufactured, N ive American-style jewelry as genuine Native American-made jewelry.
Overt Acts
4. In furt erance of the conspiracy, and to effect the objects thereof, the following overt acts,
among others, we e committed in the District of New Mexico, and elsewhere:
a. From nor about November 26, 2012, and continuing to on or about June 5, 2014, NAEL
ALI, wned and operated Gallery 8 and Galleria Azul, two distinct Native American-style
arts an crafts retail stores in Old Town Albuquerque, New Mexico;
b. From nor about November 26, 2012, and continuing to on or about June 5, 2014, NAEL
ALI, wned and operated a separate Galleria Azul, a Native American-style arts and crafts
retail ore in Scottsdale, Arizona;
c. From nor about November 26, 2012, and continuing to on or about June 5, 2014, NAEL
ALI, mployed CHRISTINA BOWEN to work at his stores Gallery 8 and Galleria Azul;
d. On th following dates, NAEL ALI purchased from MOHAMMAD MANASRA Native

Ameri an-style jewelry manufactured in the Philippines in the following amounts:
Date Check Signer I Memo Amount Payee

12/10/2012 Nael Ali I Galleria $750 Mohammad Manasra
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Azul (NM)
12/18/2012 Nael Ali I Gallery 8 $750 Mohammad Manasra
1/15/2013 I Nael Ali I Galle~ 8 $750 Mohammad Manasra
4/20/2013 i Nael Ali I Galleria $400 Mohammad Manasra
Azul (NM)
Azul (NM)
6/11/2013 I
Nael Ali I Galleria $500 Mohammad Manasra
Azul (NM)
6121/2013 Nael Ali I Galleria $300 Mohammad Manasra
Azul (NM)
6/25/2013 Nael Ali I Galleria .$1000 Mohammad Manasra
!
Azul (NM)
Azul (NM)
i Azul (NM)
Azul (NM)
Azul (NM)
Azul (AZ)
Azul (AZ)
l Azul (AZ)
3/22/2014 I Nael Ali I Galleria $1500 Mohammad Manasra
Azul (AZ)
Azul (NM)
Azul (AZ)
! Azul (NM)
Azul (AZ)
Azul (AZ)
8/20/2014 I Nael Ali I Galleria $1000 Mohammad Manasra
l Azul (NM)
Azul (NM)
10/6/2014 ! Nael Ali I Gallery $500 Mohammad Manasra
Azul (NM)
4/28/2013 i Nael Ali I Gallery 8 $500 Mohammad Manasra
5/28/2013 i Nael Ali I Gallery 8 $1000 Mohammad Manasra
6/11/2013 l Nael Ali I Gallery 8 $500 Mohammad Manasra
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e. From J or about November 26, 2012, and continuing to on or about June 5, 2014,
MOHl~MAD MANASRA supplied NAEL ALI with Native American-style jewelry
manuf~tured in the Philippines;
f. From opior about November 26, 2012, and continuing to on or about June 5, 2014, NAEL
ALI a~d CHRISTINA BOWEN, and others known and unknown to the Grand Jury,
displayd and offered for sale within Gallery 8 and Galleria Azul, Native American-style
jewelry manufactured in the Philippines in a manner that falsely suggested it was Indian
producfd, an Indian product, and the product of a particular Indian and Indian tribe, and in
excess If $1,000;
g. From oin or about November 26, 2012, and continuing to on or about June 5, 2014, NAEL
ALI pT,vided CHRISTINA BOWEN with a list of Native American artists' names to match
the initrals stamped on the Native American-style jewelry manufactured in the Philippines;
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h. On or q.bout November 26, 2012, an employee of Gallery 8, known to the Grand Jury, sold
for $689.08 two Native American-style rings stamped "CK," and a Native American-style
pendeqt and earring set stamped "BB," all manufactured in the Philippines, to an undercover
federaljagent in a manner that falsely suggested they were Navajo produced, Navajo
products, and the products of a particular Navajo artist and the Navajo tribe;
I. On or~bout November 30, 2012, an employee working at Galleria Azul, known to the Grand
Jury, s Id for $96.30 a Native American-style ring stamped "OY," manufactured in the
Philip ines, to an undercover federal agent in a manner that falsely suggested it was Navajo
produced, a Navajo product, and the product of the Navajo tribe;
J. On or lbout April 23, 2013, NAEL ALI, sold jewelry, from his business Galleria Azul, to
the on1ida Indian Nation in the amount of $28,085 for the purpose of supplying jewelry to
an On~ida tribe gallery in upstate New York and the Oneida's participation in an
interndtional festival;
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k. On or tbout February 26, 2014, CHRISTINA BOWEN, while working at Gallery 8, told an
undercover federal agent that the rings the agent had purchased on November 26, 2012, were
made by the Navajo artist "Calvin Kee";
1. On or}ibout February 26, 2014, CHRISTINA BOWEN called NAEL ALI from the Gallery
8 stor . landline regarding an order of more Calvin Kee rings;
m. On orrbout February 26, 2014, CHRISTINA BOWEN, while working at Gallery 8, told an
under over agent that she spoke with NAEL ALI and he told her he would speak with
Calvi Kee to order more rings;
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n. On or ~bout February 26, 2014, CHRISTINA BOWEN, while working at Gallery 8, told an
underiover agent that Calvin Kee exclusively supplies Gallery 8 with his jewelry;
o. On or ~bout April 2, 2014, CHRISTINA BOWEN, told an undercover federal agent from
her Gdllery 8 store landline that the Calvin Kee rings were still being produced and that she
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did not jwant to rush the artist and interfere with the production of his high quality product;
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p. On or about May 29, 2014, NAEL ALI, while working at Galleria Azul in Scottsdale,
Arizon~, sold for $120.00 a Native American-style ring stamped with a raincloud symbol,
manufabtured in the Philippines, to an undercover federal agent in a manner that falsely
sugges!fd it was Navajo produced, a Navajo product, and the product of the Navajo tribe;
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q. On or ajbout May 29, 2014, NAELALI, made representations to an undercover federal agent
that th~ rings the agent ordered at Gallery 8 on February 26, 2014, had been made by a
Navajol artist, "Calvin Kee," though no such artist exists;
r. On or ~bout May 29, 2014, NAEL ALI, told an undercover federal agent that all the jewelry
in his sfores is made by Native Americans;
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s. On or &bout May 31, 2014, CHRISTINA BOWEN, while working at Gallery 8, told an
underc1 ver federal agent that NAEL ALI had spoken to the artist Calvin Kee about the
agent' order and was informed by Calvin Kee that he could not make all the rings in brown
as orde ed because he ran out of brown stones;
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t. On or dbout August 14, 2014, NAEL ALI, sold jewelry, from his business Galleria Azul, to
the On~ida Indian Nation for the amount of $9,850 for the purpose of supplying jewelry to an
Oneid& tribe gallery in upstate New York and the Oneida's participation in an international
festivat;
I
In violation ofi 18 U.S.C. 371.
I
Count2
I
On or about F~bruary 26, 2014, in Bernalillo County, in the District of New Mexico, the defendant,
CHRISTINA BaWEN, did knowingly display and offer for sale, and did sell for $1,000 and more, a
good, specifically jewelry, in a manner that suggested that the good was Indian produced, an Indian
product, and the . oduct of a particular Indian and Indian tribe, resident within the United States, when
in truth and in fact, as she there and then well knew and believed, the good was not Indian produced, an
Indian product, arrdthe product of a particular Indian and Indian tribe.
In violation of 18 U.S.C. 1159.

I
. Count3
From on or aJout February 26, 2014, and continuing to on or about June 5, 2014, in Bernalillo
County, in the District of New Mexico, the defendants, NAEL ALI and CHRISTINA BOWEN, did
knowingly displatand offer for sale, and did sell for $1,000 and more, a good, specifically: jewelry, in a
manner that sugg sted that the good was Indian produced, an Indian product, and the product of a
particular Indian . d Indian tribe, resident within the United States, when in truth and in fact, as they
there and then weH knew and believed, the good was not Indian produced, an Indian product, and the
product of a partitular Indian and Indian tribe.
I
In violation of 18 U.S.C. 1159, 18 U.S.C. 2.
8
Count 4
On or about ctober 19, 2014, in Bernalillo County, in the District of New Mexico, the defendant,
MOHAMMAD ANASRA, did knowingly display and offer for sale, and did sell for $1,000 and
more, a good, spe ifically: jewelry, in a manner that suggested that the good was Indian produced, an
Indian product, a d the product of a particular Indian and Indian tribe, resident within the United States,
when in truth and in fact, as he there and then well knew and believed, the good was not Indian
produced, an Indi n product, and the product of a particular Indian and Indian tribe.
In violation o 18 U.S.C. 1159.
Federal arrestlwarrants have been issued resulting from the indictment, and are to be served
contemporaneously '11th the service and execution of the proposed search warrants.
9
V. FACTS S PPORTING PROBABLE CAUSE
1. Business Name: Sterling Islands, d.b.a., Rox Fine Silver and National Jewelry
Buyers
Owner Names: Sheda Khalaf and Jawad T. Khalaf
Search Location~ 5815 Menaul Blvd., Albuquerque, N.M. 87110

I
Organizational 1ole: Importer/Wholesaler
Based on my ~nvestigation, I have reason to believe that Sterling, located at 5815 Menaul Blvd.,
Albuquerque, NM 87~ 10, d.b.a., Rox Fine Silver and National Jewelry Buyers, has been importing Native
American-style jewelty from the Filipino company, Fashion Accessories 4 U Corp. (F A4U), for over a decade.
Sheda Khala~nd Jawad Tawfiq Khalaf are listed as the President and Vice President of Stei;ling,
respectively. Furthe ore, research reveals that on November 12, 2006, Jawad Khalaf and Nader Khalaf were
listed as Directors an Officers ofFA4U by the Philippines Securities and Exchange Commission. Consultation
with other agents, an1 general biographical data from law enforcement databases, supports that Jawad Tawfiq
Khalaf is the father 01Nader Jawad Khalaf and Sheda Khalaf.
Sterling is reqpired to declare their commercial importations of jewelry to the USFWS, as the shipments
contain wildlife prod1cts (i.e. shell products). From October 28, 2010, to October 16, 2015, Sterling has
declared to the USF~S, upon importation from FA4U, approximately 300 shipments of jewelry with a total
declared value of apprximately $5 million. This number, however, significantly underrepresents the true value
of the imports becaus of inconsistencies in the declaration method applied by Sterling. My own financial
investigation approxi ates a true declared value of$11.8 million in imported jewelry for the same time period.
All of these shipmen4 listed FA4U as the foreign supplier and Sterling as the US importer, and all of the import
declarations claim sin(lilar products consistent with the importation of Native American-style jewelry. In fact
the UPS declarations ~pecifically list "Fashion accessories jewelry" as the item of import.
An examinatiq n of Sterling's financial records for a similar time period revealed $6,355,599 .89 in
payments from Sterli~g to FA4U from June 18, 2010 to July 17, 2014. The payments were made by
international wire tratjsfer from aSterling account with Bank of America (Acct.# 435017473826) to FA4U's
Philippine-based banl1 account held with the Metropolitan Bank and Trust (Acct. #002236004389).
Date $ender Amount Payee

6/18/2010 $terling ( ... 3826) $55,812.27 FA4U (002236004389)
6/23/2010 ~ terling ( ... 3 826) $40,435.68 FA4U (002236004389)
7/03/2010 ~ terling ( ... 3 826) $61,696.90 FA4U (002236004389)
7110/2010 $terling ( ... 3826) $25,385.60 FA4U (002236004389)
10
l
8/11/2010 $terling ( ... 3826) $24, 123.44 FA4U (0022360043891
8/13/2010 terlin_g_ ( ... 3826) $35,977.04 FA4U (002236004389)
8/18/2010 Sterling ( ... 3 826) $25,211.60 FA4U (002236004389)
9/01/2010 Sterling ( ... 3826) $43,184.01 FA4U (002236004389)
9/03/2010 Sterling( .. .3826) $47,511.49 FA4U (002236004389)
9/16/2010 Sterlin_g_ ( ... 3826) $12,614.95 FA4U (002236004389)
10/17/2010 Sterling ( ... 3 826) $25, 186.62 FA4U (002236004389)
10/23/2010 Sterling( ... 3826) $14,985.00 FA4U (002236004389)
10/26/2010 ~terling ( ... 3826) $33,375.81 FA4U (002236004389)
11107/2010 terling ( ... 3826) $26,684.52 FA4U (002236004389)
11/16/2010 Sterling ( .. .3826) $45,093.92 FA4U (002236004389)
11/23/2010 ~terling ( ... 3826) $26,568.98 FA4U (002236004389)
11/29/2010 ~ terling ( ... 3826) $66,233.00 FA4U (002236004389)
12/02/2010 $terling ( ... 3826) $61,031.60 FA4U (002236004389)
12/06/2010 Sterling( ... 3826) $20,404.20 FA4U (002236004389)
12/10/2010 $terling ( ... 3826) $15,816.00 FA4U (002236004389)
1/09/2011 $terling ( ... 3826) $51,061.89 FA4U (002236004389)
1/12/2011 f terling ( ... 3826) $45,155.49 FA4U (002236004389)
1/14/2011 $terling ( ... 3826) $48,401.12 FA4U (002236004389)
1/24/2011 $terlin_g_ ( ... 3826) $44,061.99 FA4U (002236004389)
1/26/2011 ~terling ( ... 38261 $42,723.03 FA4U (002236004389)
2/15/2011 $terling ( ... 3826) $33,593.05 FA4U (002236004389)
2/16/2011 $terling ( ... 3826) $48,445.39 FA4U (002236004389)
2/24/2011 ~terling ( .. .3826) $38,728.75 FA4U (002236004389)
2/25/2011 $terling ( ... 3826) $30,672.64 FA4U (002236004389)
3/08/2011 $terling ( ... 3 826) $29,358.16 FA4U (002236004389)
3/17/2011 'terlin_g_ ( ... 3 826) $58,899.20 FA4U_(002236004389)
3/24/2011 Sterling ( .. .3826) $58,234.04 F A4U (0022360043891
3/29/2011 Sterlin_g_ ( ... 3 8261 $34,698.04 FA4U (0022:56004389)
4/07/2011 .Sterling( .. .3826) $62,633.24 FA4U (002236004389)
5/06/2011 Sterling ( ... 3826) $57,658.16 FA4U _(002236004389)
5114/2011 Sterling ( .. .3826) $67,228.28 FA4U (002236004389)
6/03/2011 Sterling( ... 3826) $58,911.72 FA4U (0022360043891
6/15/2011 $terling ( ... 3826) $31,420.96 FA4U (002236004389)
6/18/2011 $terlin_g_ ( ... 3826) $49,769.72 FA4U (002236004389)
6/25/2011 Sterling( ... 3826) $34,610.68 FA4U (002236004389)
6/29/2011 Sterling ( ... 3826) $25,580.56 FA4U (002236004389)
7/05/2011 Sterling( ... 3826) $24,828.28 FA4U (002236004389)
7/12/2011 ~terling ( ... 3826) $16,965.76 F A4U (002236004389)
7/17/2011 ~terling ( ... 3826) $23,572.72 FA4U (002236004389)
7/23/2011 ~terling ( .. .3826) $51,662.14 FA4U (002236004389)
7/27/2011 Sterling ( ... 3 826) $59,957.08 FA4U (002236004389)
8/13/2011 Sterling( ... 3826) $49,365.92 FA4U (002236004389)
8/18/2011 Sterling( ... 3826) $21,358.69 FA4U (002236004389)
8/23/2011 Sterling( ... 3826) $49,487.30 FA4U (002236004389)
8/26/2011 Sterling( ... 3826) $28,706.34 FA4U (0022360043891
9/16/2011 ~terling ( ... 3826) $29,253.44 FA4U cooi2360o4389)
9/17/2011 ~terling ( ... 3826) $55,753.44 FA4U (002236004389)
11
I
9/2112011 $terlin_g ( ... 3 826) $52,918.52 FA4U (002236004389)
10/04/2011 $terling ( ... 3 826) $53,848.28 FA4U _{_002236004389)
10/08/2011 terling ( ... 3826) $33,247.48 FA4U (002236004389)
10/09/2011 ~terling ( ... 3826) $33,247.48 FA4U (002236004389)
10/14/2011 Sterling ( .. .3826) $27,855.53 FA4U (002236004389)
10/22/2011 Sterling( ... 3826) $47,986.67 FA4U (002236004389)
11/09/2011 Sterling( ... 3826) $49,383.44 F A4U (002236004389)
12/04/2011 ]:terling ( ... 3 826) $34,390.00 FA4U (002236004389)
12/07/2011 Sterling( ... 3826) $14,675.32 FA4U (002236004389)
1/13/2012 Sterling( ... 3826) $54,093.60 FA4U (002236004389)
1/25/2012 Sterling ( ... 3 826) $51,836.00 FA4U (002236004389)
~
Sterling( .. .3826) $28,957.44 FA4U (002236004389)
I terling ( ... 3826) $29,299.00 F A4U (0022360043891
2/26/2012 ~terling ( ... 3 826) '~~ 0 FA4U (002236004389)
3/15/2012 Sterling ( ... 38261 $25,178.63 FA4U (002236004389)
3/17/2012 Sterling ( ... 3826) $24,835.12 FA4U (002236004389)
3/23/2012 Sterling ( ... 3 826) $57,217.03 FA4U (002236004389)
4/01/2012 terling ( ... 3 826) $26,036.12 FA4U (002236004389)
4/14/2012 Sterling( ... 3826) $56,380.66 FA4U (002236004389)
4/24/2012 $terling ( ... 3826) $70,589.52 FA4U (002236004389)_
512012012 Sterling( ... 3826) $39,112.49 FA4U (002236004389)
5/26/2012 Sterling( ... 3826) $59,075.59 FA4U (002236004389)
6/06/2012 Sterling( ... 3826) $53,944.16 FA4U (002236004389)
6/22/2012 Sterling ( . ., .3826) $38,987.48 F A4U (002236004389)
6/29/2012 Sterling( ... 382~ $51,227.12 FA4U (002236004389)
7/11/2012 Sterling ( ... 3826) $51,829.64 FA4U (002236004389)
7/28/2012 Sterling( ... 3826) $56,491.58 FA4U (002236004389)
8/10/2012 Sterling( ... 3826) $27,796.46 FA4U (002236004389)
8/12/2012 Sterling( ... 3826) $22,577.08 FA4U (002236004389)
8/15/2012 Sterling( ... 3826) $19,670.08 FA4U (002236004389)
::t/V//,Wl2 Sterling ( ... 3826) $70,509.88 FA4U (002236004389)
9/08/2012 Sterling ( ... 3 826) $29,424.70 FA4U (002236004389)
9/13/2012 Sterling ( ... 3826) $69,065.50 FA4U (002236004389)
9/29/2012 $terling ( ... 3826) $38,104.66 FA4U (002236004389)
10/06/2012 terling ( ... 3 826) $19,982.20 FA4U (0022360043891
10/14/2012 Sterling( ... 3826) $52,781.66 FA4U (002236004389)
10/20/2012 $terling ( ... 3826) $66,753.96 F A4U (002236004389)
10/27/2012 $terling ( ... 3826) $50,246.56 F A4U {002236004389)
11/07 Sterling( ... 3826) $44,529.85 FA4U (002236004389)
11114/2012 Sterling( ... 3826) $40,533.80 FA4U (002236004389)
11/28/2012 Sterling ( .. .3826) $58,172.76 FA4U (002236004389)
12/10/2012 Sterling( ... 38261 $76,193.20 FA4U (002236004389)
1/24/2013 Sterling ( ... 3826) $73,440.72 FA4U (002236004389)
1/31/2013 Sterling ( ... 3826) $60,638.27 FA4U (002236004389)
2/13/2013 Sterling( ... 3826) $70,272.93 FA4U (002236004389)
I
3/6/2013 Sterling ( ... 3826) $64,985.00 FA4U (002236004389)
/2013 terling ( ... 3826) $59,985.00 FA4U (002236004389)
/2013 $terling ( ... 3826) $52,016.50 FA4U (002236004389)
12
411012013 $terlin_g_ ( ... 3 826) $74,257.88 FA4U (002236004389)

4/22/2013 ~terling ( ... 3826) $52,267.34 FA4U _(002236004389)
51712013 ~ terling ( ... 3826) $70,107.00 FA4U _(002236004389)
5/22/2013 Sterling ( ... 3826) $60,353.35 FA4U (002236004389)
61212013 ~terling ( ... 3826) $66,469.25 FA4U (002236004389)
6/12/2013 ~terling ( ... 3826) $66,781.45 FA4U (002236004389)
6/27/2013 Sterling ( ... 3826) $73,579.15 FA4U (002236004389)
711012013 Sterling ( .. .3826) $60,888.00 FA4U (002236004389)
7/26/2013 Sterling ( ... 3826) $66,542.40 FA4U (002236004389)
8/10/2013 ~terling ( ... 3826) $80,775.19 FA4U (002236004389)
9/3/2013 ~ terlin_g_ ( ... 3 826) $72,162.60 FA4U (002236004389)
9/18/2013 1 Herling( ... 3826) $72,367.80 FA4U (002236004389)
9/30/2013 Herlin_g_ ( ... 3826) $59,132.20 FA4U (002236004389)
10/17/2013 Herling( ... 3826) $69,703.00 FA4U (002236004389)
11112/2013 Sterling ( ... 3826) $58,777.80 FA4U (002236004389)
12/02/2013 __terling ( ... 3 826) $37,468.40 FA4U (002236004389)
12/04/2013 Sterlin_g_ ( ... 3826) $66,196.00 FA4U (002236004389)
12/10/2013 ~terling ( ... 3826) $82,146.40 FA4U (002236004389)
1/24/2014 Sterling( ... 3826) $40,883.60 FA4U (002236004389)
3/25/2014 Sterling ( ... 3826) $82,150.40 FA4U (002236004389)
3/26/2014 ~terling ( ... 3826) $71,160.40 FA4U (002236004389)
3/2712014 $terlin_gJ .. .3826) $77,127.60 FA4U (002236004389)
3/31/2014 Sterling ( ... 3826) $69,757.20 FA4U (002236004389)
4/1/2014 Sterlin_g_ ( ... 3 826) $70,249.20 FA4U (002236004389)
5/20/2014 Sterling ( ... 3826) $66,952.00 FA4U (002236004389)
5/22/2014 Sterling( ... 3826) $53,276.12 FA4U _{_0022360043891
6/11/2014 ~terling ( ... 3826) $71,600.52 FA4U (002236004389)
6/17/2014 Sterling ( ... 3 826) $80,380.32 FA4U (002236004389)
7/07/2014 ~terling ( ... 3826) $73,308.72 FA4U (002236004389)
7/17/2014 Sterling ( ... 3826) $88,745.48 FA4U (002236004389)
$6,355,599.89
i
USFWS agents and inspectors intercepted and covertly inspected five of Sterling's shipments from its
FA4U factory in the Prilippines. Upon in.spection, these intercepted shipments were found to contain imitation
Native American-sty! jewelry consistent with what agents have observed for sale and purchased as purported
genuine Native Ameri an jewelry at retail stores across New Mexico. And although the invoices confirm that
the imitation Native A~erican-style jewelry was manufactured in the Philippines, none of the jewelry was
indelibly marked with ,its country of origin as required by law. In fact, all of the imported jewelry inspected by
!
USFWS, which was iridelibly stamped with various initials and Native American symbols, was placed inside
plastic bags outfitted f'ith "Handmade in Philippines" decals. The jewelry could be easily separated from the
plastic bags and it wo ld be impossible for an unsuspecting consumer to determine the jewelry's country of
..
ongm.
'
I
13
Case 1:15-mr-00664-KBM
i Document 1-1 Filed 10/26/15 Page 14 of 35
I
For example, ~SFWS Wildlife Inspectors (WI) stationed at the port of Louisville, KY, inspected
Sterling shipments imported from FA4U on May 29, 2012, and July 30, 2012. During these inspections, the
Wls photographed items contained in the shipments for my review. In these cases, I noted that the jewelry
appeared to be NativelAmerican-style. The pieces of jewelry were engraved with symbols or initials and placed
in individual bags, an1 the bags that contained the individually-packaged jewelry were affixed with "Handmade
in Philippines" decals None of the items in the shipment was indelibly marked with country-of-origin
1
information as requir9d by 19 U.S.C. 1304. And the importer ofrecord for the shipments was listed in import
declarations as Sterlinjg/ Sheda Khalaf and the exporter of record was listed as FA4U.
Destination for all F 14Ujewelry imported by Sterling
My review oqhe documentation for each of the approximately 300 shipments Sterling imported from
FA4U,.reveals a singlr destination location: Sterling's registered business location at 5815 Menaul Blvd.,
Albuquerque, NM 87 10. In many cases, the imports were signed as received upon delivery by Sheda Khalaf
herself. Trash recove y operations conducted outside Sterling recovered some of the FA4U shipping boxes,
invoices and other shipping documentation, confirming that the FA4U imports were sent directly to Sterling.
Based on the five insBected shipments from FA4U to Sterling, I was able to note and match the distinct FA4U
I
boxes, which are wra~ped entirely in duct tape, and the FA4U plastic packaging for its jewelry. The plastic
packing is distinctly ~sp, clear and is affixed with "Handmade in Philippines" decals. Additionally, each piece
of jewelry is placed i~side a smaller plastic bag, which is then aggregated in a larger plastic bag with other
individually bagged pt"eces of jewelry.
Sterling's late t import from FA4U was declared on October 16, 2015. The import was declared as
containing 3,055 piec s of jewelry at a declared value of $49, 192. As of October 21, 2015, Sterling continues
to operate its busines~ at 5815 Menaul Blvd., Albuquerque, NM 87110.
Distributio11 poi11t fol( all FA 4 U jewelry imported by Sterli11g
As mentioned above, my investigation has revealed a coalition of businesses and individuals associated
with Sterling. Based .on follow-up investigations of those businesses and individuals associated with Sterling, I
know that Sterling's ~ocation at 5815 Menaul Blvd., Albuquerque, NM 87110, serves as the United States hub
for the distribution <;>f Sterling imported Native American-style jewelry to wholesalers and retailers alike.
I
Electronic communif ations between Sterling and other members of the Sterling Coalition, as well as
surveillance of Sterl~ng's business location, demonstrates that retailers and wholesalers pick-up imported
jewelry directly from Sterling. For example, my examination of emails revealed arrangements for Asad Shawar
1
(a travelling retailerfiand buyer for Bullion Jewelers in Breckenridge, CO), to pick-up an order of imported
jewelry directly fro Sterling. Similarly, surveillance has revealed several known Native American-style
jewelry wholesalers .t Sterling's location with vans used to transport merchandise.
14
Examples ofHow SJling's Imported Jewelry is Sold in Violation of 18U.S.C.1159

My financial iir.vestigation established direct links between Sterling and over ten retail stores that sell
Sterling's Filipino-mate jewelry as genuine Native American-made jewelry. For example, financial records
reveal significant and egular payments to Sterling from Bullion Jewelers, located in Breckenridge, Colorado. I
travelled to Buillon Je elers, at 121 South Main St. in Breckenridge, CO, and observed and cove1tly recorded
Taha Shawar (the owq.er of Bullion Jeweler's) display for sale and sell Sterling-imported jewelry as Native
American-made. 1
Email comm~ications and invoices confirm the relationship between Taha Shawar and Nader Khalaf of
Sterling. One such intoice dated May 31, 2010, from Sterling to Bullion, details one thousand two hundred and
fifty-four (1,254) piec~s of jewelry for a total of$49,548.08. The invoice is titled, "Fashion Accessories 4 U,"
and contains the correr ponding Philippine address, telephone number and other business information.
Additionally, the invo ce contains a statement which reads, "The goods are wholly the manufacture of
Philippines and are di. ferent articles of commerce that have been manufactured in Philippines." The email
exchanges between Bllion and Sterling and then Sterling and FA4U illustrate how retailers request particular
items to be produced ft Sterling's factory and even the specific initials to be stamped on those items. For
example, the email th ead below memorialized Shawar's request that Sterling's FA4U factory stamp the
requested jewelry wit the initials, "E. Y."
1
[FromlShawar To Sterling on July 23, 2013]

"Nadel plea.se make sure they stamp the item with letters E. Y.
Thank. very much
Best Rgards
Taha"
[From Sterling To FA4U]

"Ok, please make but be sure to make initials E.Y. Not urgent, just send
with the next ripment. Thank You!"
I [From FA4U to Sterling ]

"Noted sir, How many the qty & the colors?"
15
Sterling also sent images attached to emails to Taha Shawar from which he could select for replication at
FA4U. The images appear to be from Lazuli Designs, a Gallup-based manufacturer that employs several Native
American artists, including Edison Yazzie.
On August 5, 20 14, I visited Bullion in a covert capacity and determined that Shawar was selling the
"E.Y."-stamped, Firpino jewelry as genuine Native American jewelry, made by "Edison Yazzie." When an
assisting agent asked ubout a butterfly necklace with the
letters, "E.Y.," tamped on the back, Shawar responded that
they stand for, "Edis n Yazzie." The butterfly necklace
matched one of the image sent by Sterling for Shawar' s
selection. Shawar also misrepresented numerous other pieces
of jewelry I knew to be consistent with Sterling' s imports,
including rcpr scn6 ng Sterling's raincloud-stamped rings as
Zuni made.
Lastly, I obs r ed several pueblo scene bracelets which were consistent with Sterling imports, in that
their inlay, and tamp and initials on the inside, were in the exact same location and manner as the Sterling
items.
Shawar told me that the bracelets were Zuni made. I purchased the bracelet and later confim1ed its origin as
Sterling-imported by comparing it to photographs taken during inspections of intercepted Sterling shipments.
Additionally, the ollowing sections of this affidavit, outline how each of the members of the Stefling Coalition
are financially linked o Sterling and the fraudulent sale of Sterling-imported jewelry as real Native American-
made jewelry.
16
Most Recent Activity
Sterling has c ntinued to import shipments of jewelry from its FA4U factory in the Philippines on a
regular basis. The lat shipment declared was on October 16, 2015, destined for delivery at Sterling's business
location on Menaul St. in Albuquerque, N.M. Members of the Sterling Coalition have continued to use
Sterling's location as a distribution point. On September 12, 2015, Mohammad Manasra, whose activities are
detailed below as Tar~et 5, was observed backing-up one of the vans he uses to transport jewelry to the front
doors of Sterling in a banner consistent with loading merchandise. Afterwards, a trash recovery operation at
Sterling revealed packaging consistent with Sterling's imports.
Based on the ~acts related within this affidavit, my training and experience, and the training and
I
experience of agents *nd investigators involved in this investigation, there is probable cause to believe that the
items to be seized as ~escribed in Attachment B, which is attached hereto and fully incorporated herein, will be
I
located at the premis1s described in Attachment A, and are evidence, fruits, and instrumentalities of violations
of 18 U.S.C. 542 Oryiportation by false or fraudulent practice), 19 U.S.C. 1304 (failure to mark goods with
country of origin), 18IU.S.C.
I
1159 (violation of the Indian Arts and Crafts Act), and 18 U.S.C. 371
(conspiracy).
17
Al Zuni
Nashat Khalaf
l 1603 West Hwy 66, Gallup, NM 87301
Search LocatJon:
Organizationpl Role: Wholesaler/Retailer
Financial Link to St~rling

An examinatiJn of Sterling's financial records revealed $1,367 ,461 in payments from Al Zuni to
Sterling from July 16~ 2010 to July 15, 2014. The payments were made from Al Zuni to the Sterling account
with Bank of Americ~ (Acct. # 435017473826).
Date Sender I Memo Amount Payee
7/16/2010 Al Zuni I Jewelry $16,500.00 Sterling Islands
8/16/2010 Al Zuni Global I Jewelry $17,000.00 Sterling Islands
2/11/2011 Al Zuni Global $23,834.00 Sterling Islands
2/22/2011 Al Zuni Global I Credit Cards $48,500.00 Sterling Islands
3/18/2011 Al Zuni Global I Jewelry $46,124.00 Sterling Islands
1 Al Zuni Global 00.00 Sterling Islands
8/19/2011 } Al Zuni Global $63,622.00 Sterling Islands
9/20/2011 - Al Zuni Global $63,622.00 Sterling Islands
10/20/2011 l Al Zuni Global $63,622.00 Sterling Islands
1/6/2012 1
Al Zuni Global $52,000.00 Sterling Islands
2/22/2012 } Al Zuni Global $96,177.00 Sterling Islands
12/24/2012 Al Zuni Global I Jewelry Chain
$2,765.00 Sterling Islands
#1468
1/29/2013
2/19/2013
Al Zuni Global
~00 Sterling Islands
Al Zuni Global .00 Sterling Islands
4/8/2013 Al Zuni Global
! $5,330.00 Sterling Islands
8/2/2013 -'- Al Zuni Global $30,685.00 Sterling Islands
6/16/2014
t
Al Zuni Global
18
$96,607.00 Sterling Islands
7/15/2014 I Al Zuni Global $96,607.00 terling Islands
On August 23, 2015, I observed Nashat Khalaf at Sterling. I observed Khalaf exit the business through
the front door, enter his vehicle, a Mercedes SUV, and leave the location. A registration query of the vehicle
revealed that the Mercedes SUV is registered to Al Zuni Global Jewelry.
On eptember 22, 2015, I again observed Nashat Khalaf, at Sterling. Specifically, I observed Khalaf
engaging in behavior consistent with loading the Mercedes cargo van that he was driving. I observed him close
the rear cargo doors (the vehicle was backed up to the front door of Sterling), get into the driver's seat of the
van, and depart the busines . A registration query revealed that the Mercedes cargo van I saw Khalaf driving is
registered to the bu hi. ss Al Zuni Global Jewelry Inc.
Covert Purchases
On o mber 13, 2014, I visited Al Zuni in a
covert manner. A ma e employee introduced himself to me
as "Zaher," and a. sist d me throughout the contact. I later
identified the subject as Zaher Mostafa, the manager of Al
Zuni. While in the tore I observed a collection of silver
and onyx rings which I recognized as being similar to rings
imported by Sterling on July 30, 2012. I recalled that the
contents of that sl ipment, and specifically the same style
ring, were photographed and documented during the
inspection. In the imported shipment, eighty (80) of the same style rings were bagged together. One of these
rings was labeled, "AL-Zuni sample." The "AL-
Zuni sample," ring was marked with a stamp on the
inside which differed from rest of the items. The
other rings were marked with, "OY," initials. The
bag appeared to contain one original sample and a
series of replicas made from that sample. I looked
at the rings in the store and observed that the
markings appeared to be the same as the, "AL-Zuni
sample," from the Sterling import. Mostafa told me
that the rings were made by the silversmith, Ray
Jack.
19
I then asked Mostafa if they had any small silver canteens in the store. I referred to them as, "Navajo
canteens," as I knew this to be the industry term for them. I had seen these items in the Sterling shipment that I
inspected on September 10, 2012. During that inspection, I also noted that there appeared to be an original
"sample" canteen bagged with twenty exact replicas. Mostafa told me that
they did have some in the store and showed them to me. I observed that
the canteens were consistent with those imported by Sterling.
On November 24, 2014, an assisting USFWS SA and I conducted a
covert contact and purchase of evidence at Al Zuni. Mostafa recognized
me from our previous interaction and assisted us throughout the contact.
Mostafa advised us regarding the system of buying at Al Zuni.
Specifically, Mostafa said, "I carry all kind of jewelry. Navajo, Zuni,
overseas ... " Mostafa said that we could tell him what we were interested
in and he could point us in the right direction. I also observed that Nash
Khalaf was present at the store. New Mexico's Secretary of State records, as well as financial records, confirm
that Nash Khalaf is the owner of Al Zuni. Nash Khalaf spoke to the SAs about the jewelry in the store saying,
"all this jewelry done by individual. .. just by eyes and by hand." I believe Nash Khalaf was refeffing to a
specific tray of jewelry in the store, not the entire store.
I selected four of the canteens that I had observed during the previous contact on November 13, 2014. I
noted that there were several more canteens in separate boxes available and offered for sale. I also selected
several other pieces of jewelry which I knew to be consistent with Sterling impo11ed items.
Upon checking out, Mostafa went through the items that we selected for a possible purchase. I asked
about the canteens and Mostafa explained that, "they' re made here locally .. . Navajo, yes ... That's a Navajo
canteen ... " Mostafa then informed us that the rest of the jewelry we selected for purchase, aside from some
"Effie Calavaza" style jewelry, 1 was imported. Mostafa, once again, pointed out that the canteens were Navajo.
I remarked that the imported jewelry was so nice that it could be sold as Zuni made. Mostafa simply replied,
"mm-lm1m." But then Mostafa clarified, " I have to tell you." Even so, Mostafa sold the "Navajo canteens," as
Navajo-made, alongside the other items, for $1077. The four canteens alone cost $340.
1 Effie Calavaza is a l':uni m1ist who has been producing Native American jewelry for over 60 years. Her
jewelry is distinct in that it incorporates snakes into the design of every piece. Recently, however, a related
investigation has revealed that many "Effie Calavaza" style jewelry pieces on the market in New Mexico are
not actually made by Effie Calavaza though they are sold as genuine.
20
I compared th four canteens to photographs I comparison

taken during the September 10, 2012, Sterling inspection " " '' ~
and determined that the purchased canteens matched the

canteen designs documented during the Sterling-import
inspection. The purchased canteens also correspond to
those depicted in an August 3, 2012 email
. communication betwt1en Nader Khalaf of Sterling and
FA4U. The email references an order placed by Zaher
and contains an attached photograph which depicts three 1 1 !''
canteens (which match those in the inspected, September
10, 2012, shipment) and a plastic bag with the note,
"Nader Can uncle Joe make These in Silver I need 20
[each] Zaher." Furthermore, the canteens purchased at Al
Zuni during the covert contact match the design on the
canteens depicted in this email.
Recent Activity
On October 16, 2015, an assisting federal agent
visited Al Zuni in a covert manner. The agent observed
both Zaher Mostafa and Nash Khalaf working at the
business. Additionally, the agent observed items
displayed for sale which were consistent with Sterling
imports. Specifically, the agent observed a box of small
canteens offered for sale which were consistent with those
replicated and imported by Sterling.
Conclusion
Based on the fact related 'Yithin this affidavit, my training and experience, and the training and
experience of agents and investigators involved in this investigation, there i~ probable cause to believe that the
items to be seized as desc ibed in Attachment B, which is attached hereto and fully incorporated herein, will be
located at the premis s described in Attachment A, and are evidence, fruits, and instrumentalities of violations
of 18 U.S.C. 542 (importation by false or fraudulent practice), 19 U.S.C. 1304 (failure to mark goods with
country of origin), 18 U.S.C. 1159 (violation of the Indian Arts and Crafts Act), and 18 U.S.C. 371
(conspiracy).
21
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3. Busi~ess Na~e: Gallery 8
i
Owner Name~ Nael Ali
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Search Locat(on: 1919 Old Town Rd. NW #8, Albuquerque, NM 87104
Organizational Role: Retailer
4. Business NaJe: Galleria Azul
Owner Name: Nael Ali
Search Locat,on: 326A San Felipe St., Albuquerque, NM 87104

I
Organization~l Role: Retailer
II
Gallery 8 and !Galleria Azul are both located in Old Town Albuquerque. According to the New Mexico
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Secretary of State dafabase, Nael Ali is listed as the President of both Gallery 8 Inc. and Ga1leria Azul Inc.
Additionally, he is th~ signatory on the business accounts related to Gallery 8 and Galleria Azul.
Financial Ties to Ste}ling
I
An examinati~n of financial records revealed approximately $58,000 in payments to Sterling from Nael
Ali, d.b.a. Gallery 8 or Galleria Azul. The payments were made by checks signed by Nael Ali and drawn on
Gallery 8 or Gallerir Azul accounts with Bank of Albuquerque (Acct. # 8092233979 and 8093377451,
respectively). As Stdrling is in the business of importing and subsequently selling their Filipino made Native
American-style jewelry and Ali's stores sell Sterling imported jewelry, it can be presumed that these payments
were made for jewelrt imported from FA4U.
I
Date heck Signer I Notes Amount Payee
3/18/2011 JN'ael Ali ( ... 39791 $1,000 Sterli~435017473826l
4/7/2011 Nael Ali( ... 3979) $2,000 Sterling (435017473826)
4/29/2011 Nael Ali( .. .39791 $1,000 Sterlin_g_ (4350174738261
5/7/2011 Nael Ali( .. .3979) $2,507 Sterling (435017473826)
5/15/2011 Nael Ali( ... 3979) I $2,300 Sterling (435017473826)
6/15/2011 Nael Ali ( ... 3979) [$1,825 Sterling (435017473826)
7/15/2011 Nael Ali ( ... 3979) i $1,825 Sterling (435017473826)
8/112011 Nael Ali( ... 3979) $1,825 Sterling (435017473826)
11/18/2011 JN'ael Ali ( ... 3979) $500 Sterling (435017473826)
11/18/2011 }fael Ali ( ... 3979) $500 Sterling (435017473826)
12/2/2011 Nael Ali ( ... 3979) $416 Sterling (435017473826)
12/2/2011 JN'ael Ali ( ... 3979) $1,000 Sterling (435017473826)
,[T
12110''"'"' ,. ( ... 3979) $1,000 Sterling (435017473826)
22
--- -

12/16/2011 Nael Ali ( ... 3979) $555 Sterling (435017473826)
1/8/2012 Nael Ali ( ... 3979) $1,000 Sterling (435017473826)
1/10/2012 JN"ael Ali ( ... 3979) $1,000 Sterling (435017473826)
3/10/2012 JN"ael Ali( ... 3979) $1,000 Sterling (435017473826)
4/29/2012 JNaelAli ( ... 3979) $500 Sterling (435017473826)
7/5/2012 JN"ael Ali ( ... 3979) $800 Sterling (435017473826)
7/18/2012 JN"ael Ali( ... 3979) $500 Sterling (435017473826)
8/28/2012 Nael Ali( ... 3979) $500 Sterling (435017473826)
1/20/2013 Nael Ali ( ... 7451) $1,500 Sterling (435017473826)
10/7/2014 JN"ael Ali ( ... 7451) $690 Sterling (435017473826)
I $56,964
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Covert Purchases !
During one of the previously mentioned covert inspections, which took place on September 10, 2012
(UPS air waybill H8~6-7699-001), I took note of a package of fifty-two (52) rings (Item# RNG-1325-MAN).
I
All of the rings were ~imilar in design, but twenty (20) of the rings were the same in that they were made in the
"cornrow" style, use~ brown and black stones, and bore the initials, "CK," on the inside.
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23
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Sterling Import
I separated out these twenty (20) rings and applied ultraviolet visible ink to one side of each ring.
Ultraviolet ink
visible under
exposure to black
light
I then confirmed that the ink was visible using an ultraviolet light source after applying the ink. Finally, I
repacked the items and sealed the boxes.
On ep .ember 12, 2012, I conducted a surveillance of Sterling at 5815 Menaul Blvd. in Albuquerque,
NM and at 10:06 AM "KHALAF" signed for five UPS shipments including H896-7699-001.
On ovembel' 26, 2012, I observed several pieces of Native American-style jewelry offered for sale in
the store, Gallery 8, located at 1919 Old Town Road, NW #8 , Albuquerque, NM, which were consistent with
those that were imported by Sterling. None of the jewelry in the store, that was consistent with the Sterling
imports, was marked to notify the customer that it was made in the Philippines. The store employee told me
that everything in the tore was Indian (Native American) made except the amber jewelry. I observed two rings
24
which were identical to the rings I had covertly marked in the September 10, 2012, Sterling shipment (UPS
#H896-7699-001, invoice item number RING-1325). I asked to look at the rings and observed that they were
inscribed with the initials, "CK," just as the Sterling rings had been.
I was told that the rings were Navajo made. The employee told me that the manager would call me with
the name of the "CK" artist. I was then told that the o\Vner of Gallery 8 also owns another gallery, Galleria
Azul, which was located just a few blocks away. I purchased the two rings and other jewelry consistent with
Sterling importations via credit card from Gallery 8 for a total of $689.08. After purchasing the items, I
confirmed that the rings were, in fact, rings from the September 10, 2012, Sterling shipment (UPS #H896-7699-
001) by exposing them to ultraviolet light and confirming the presence of ultraviolet visible ink.
On November 30, 2012, I again visited Gallery 8 in a covert manner. The manager was present at the
store. I told the manager, that I had purchased two rings a few days prior and wanted to know the artist's
identity. The manager told me that she had to get into the owner' s (Nael Ali), computer to get the artist's name.
Independent research confirmed that Ali is the owner of Gallery 8 and Galleria Azul in both Albuquerque and
Scottsdale, AZ.
After leaving Gallery 8 on November 30, 2012, I visited Galleria Azul in a covert manner. I observed
many of the same items that I had seen in Gallery 8, in Galleria Azul. I also saw another ring, identical to those
I had marked in the Sterling shipment, for sale. The store employee explained that Galleria Azul had mostly the
same items as were in Gallery 8. I asked about a turquoise ring which looked consistent to rings imported by
Sterling on July 30, 2012:
Galleria Azul rings consistent with Sterling

Import
Galleria Azul ring - "OY" Initials same as

Sterling Import
25
Photograph taken during Sterling shipment
inspection in Louisville, KY
Photograph taken during Sterling shipment

inspection in Lou isvill e, KY
"OY" initials same as Galleria Azul ring
The employee told me that the ring was made using "Cerillos" turquoise and that it was Navajo made. I
observed that the ing was inscribed with the initials "OY" just as the Sterling rings were. The employee told
me that the galleries (Gallery 8 and Galleria Azul) are owned by the same person and they interchange items
and stock. I purchas _d the ring for a total of $96.30.
On February 26, 2014, I visited Gallery 8 and Galleria Azul in a covert manner. I spoke to the manager
while at Gallery 8. The manager remembered me and told me to pick out the items I was interested in and then
she would call Ali and, "take care of it." I referenced a ring I was wearing (one of the marked rings which I
purchased previously and asked if they had any more in stock. The manager said that she only had a similar
type in stock, but not the same one. I asked if Gallery 8 could contact the artist to get more produced. The
manager said they could contact the artist, "Calvin Kee," and see if that would be possible. I was again told that
all of the jewelry in the store was Navajo-made with the exception of three pieces which were Zuni made. The
manager then said she would call Ali to determine final pricing on the jewelry. The manager also said she
would have Ali contact "Calvin Kee" to see about getting more jewelry. The manager said that "Calvin Kee"
exclusively supplies Ga]lery 8 with his jewelry. I then walked over to Galleria Azul. While in the store, I
observed jewelry, pottery, and paintings for sale. The jewelry was consistent with that which is imported by
Sterling. I was told that all of the jewelry was Navajo made. Another USFWS SA then asked for a list of artists
and the corre pondi1g initials. The store employee told me that she had a list and could make a copy.
Additionally, the employee made the following statements regarding the jewelry and the artists' names
and initials:
o Sometim s I forget and make stuff up. I know that's bad."
o "We make it up. I'm not gonna lie ... You guys are in the business, you have to
26
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underjand." (Agent's Note: This statement was made in response to the SA's
questi n about what they do when artists have the same initials.)
o "It is a}l handmade ... I'm not lying about that ... "
o "It's al~ locally made."
I then returnelto Gallery 8 and the manager told me that they have a third shop, called Galleria Azul, in
Scottsdale, Arizona. he manager told me that she spoke to Ali and she would take a photograph of my "Calvin
Kee" ring and get mo e made. The manager called Ali using the wireless telephone in the store. After getting
off the telephone, the manager told me that Ali said they would get in touch with the artist, "Calvin Kee." At
I
that time, the manage~ told me Calvin Kee was born in 1964. I asked for a key to the symbols on some of the
rings. The manager !explained that the feather symbol is for the Yazzie family, "AA" corresponds to Juan
Armas, the Yucca syfbol corresponds to Ardale, and "OY" corresponds to Olivia Yazzie. I recognized all of
these symbols and in*ials as consistent with symbols on jewelry imported by Sterling. The_ manager then took
I
photographs of my ri1g, using her cell phone, to show to Ali.
I placed an otper for ten copies of the ring that the manager photographed and ten additional "Calvin
Kee" rings. I then p~rchased five rings with "CK" initials, one ring with a Yucca symbol, one ring with "NB"
initials, one ring withl "OY" initials, three rings with raincloud symbols, and one ring with a feather symbol for
$1116. The manager faid that it would take at least three weeks for the ordered rings to be produced.
On April 2, 2p14, a USFWS SA contacted the manager at Gallery 8 via telephone. The SA inquired
about the status of th rings that were ordered on February 26, 2014. The manager told the SA that the rings
were still being prod ced. Additionally, the manager said that she did not want to rush the artist because the
SAs desire a high qua ity product.
Open source r search did not reveal any Navajo artists named Calvin Kee. I also requested the
Department oflnterior, Indian Arts and Crafts Board to confirm any known Native American artists with the
I
name, Calvin Kee. T~eir research returned no results for that name. Finally, the Navajo Nation confirmed that
there were no Navajo !tribal members, named Calvin Kee and born in 1964, on their rolls.
On May 15, 2~14, Sterling imported a shipment of jewelry from FA4U. I reviewed the invoice for that
shipment and noted t~e first item number listed was RING-1325, which was consistent with the item number for
the Sterling-importedlrings that I had first inspected and marked on September 10, 2012, as well as the rings I
had observed and ord red from Gallery 8 on February 26, 2014.
On May 29, 2 14, I visited Galleria Azul in Scottsdale, Arizona, in a covert manner. I entered the store
and observed Ali wor ing behind the counter in the store. I observed jewelry offered for sale in the store which
was consistent with t at imported by Sterling. I introduced myself and told Ali that I had placed an order for
"Calvin Kee" rings at the Albuquerque store. Ali immediately knew what I was referring to. Ali told me that
27
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he had more "Calvin Jleee" rings if I wanted them. Ali told me that the order of rings had arrived a week ago
i
and were currently at ~is Albuquerque store. Ali told me that all of the jewelry in the store is Native made. Ali
told me that people inlAlbuquerque want all Native made items so that is what he carries in his Albuquerque
stores, as well. Finall~, I purchased a ring from Ali which was consistent with those imported by Sterling. Ali
told me that the ring was Navajo made and I purchased the item for a total of$120.
On May 31, 2~ 14, I visited Gallery 8 in Albuquerque, New Mexico, in a covert manner. The manager
told me that Ali got in' touch with the artist and that "Calvin Kee" did not have a lot of the stones available so he
couldn't make them all in broVvn (the color of the original ring to be copied for the order). The manager told me
that "Calvin Kee" ma~e twenty rings in total. The manager told me that the rings retail for $270 but were sold
to me for $90 each. ~he manager told me that she would FedEx the items to New York for me and that this was
'
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a normal business pra~tice for the store. I paid a total of $1800 for the rings and $20 for the shipping by credit
!
card transaction. Thelitems were all sold to me in violation of the IACA (18 U.S.C. 1159).
I
On June 5, 20~4, a USFWS SA stationed in Valley Stream, NY notified me that the Gallery 8 shipment
had been delivered, v~a FedEx. On June 11, 2014, I received a FedEx package from the USFWS SA stationed
in Valley Stream, NY~ The original FedEx package which was sent from Gallery 8 to New York was unopened.
Upon opening the package, I found it to contain twenty rings with the initials "CK" stamped into them.
Recent Activity
On October 1~, 2015, an assisting federal agent visited Gallery 8 in a covert manner. While in the
business, the agent sJc,ke with Ali who said that the jewelry in his store is, "all Navajo ... everything you see in
my store is Navajo ... even the inlay is Navajo." The agent observed jewelry displayed and offered for sale
which was consistentl with Sterling imports. Specifically, the agent observed a ring with a raincloud symbol
stamped into it. Ali ~old the agent that he had a store in Scottsdale, AZ, until recently. When the agent asked
about the Scottsdale ~tore, Ali told the agent that he carried the same merchandise in that store. Ali went on to
say that it made thing~ very difficult in Scottsdale because the consumer "had the image that everything is fake,
everything is bad." ,f\fter leaving Gallery 8, the agent visited Galleria Azul in a covert manner as well and,
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again, observed jewe~ry displayed and offered for sale which was consistent with Sterling imports. During my
review of the video t~ken during the covert contact, I observed several items offered for sale in Galleria Azul
consistent with both ~terling and IJW2 imports.
Co11clusio11 :
Based on thel facts related within this affidavit, my training and experience, and the training and
experience of agents and investigators involved in this investigation, there is probable cause to believe that the
2 Based on my invesdgation, I know that I Jewelers Wholesale d.b.a. Golden Bear ("IJW"), is an importer and (l~.
retail supplier of Fili~ino-made, Native American-style jewelry, located in Calistoga, CA . ..:z::::JVV '- '"<'-- \ '
ur-.-::~ . . ,. .
7 ,2:)0p" ,yor .s~r.> /r-J ~"V.C-1.-~ J<'V;r,o./ r"TE c.:...,._.,...,-.Ly OF=" ~<:;"1.
: 28 ~
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items to be seized as escribed in Attachment B, which is attached hereto and fully incorporated herein, will be
located at the premis s described in Attachment A, and are evidence, fruits, and instrumentalities of violations
of 18 U.S.C. 542 (i portation by false or fraudulent practice), 19 U.S.C. 1304 (failure to mark goods with
country of origin), U.S.C. 1159 (violation of the Indian Arts and Crafts Act), and 18 U.S.C. 371
(conspiracy).
29
5. Business Na~e:
AN. Jewelry
Owner Name[s): Arafat H. Nimer and Maria Nimer
Search Locadon: 2304 Cagua NE, Albuquerque, NM 87110 (Nimer)
6. Business Name: Mohammad Manasra (Sole Proprietor)
Owner Namel: Mohammad Manasra
Search Location: 909 Tumulus Dr. NW in Albuquerque, NM 87120 (Manasra)
Search Prop~rty: 2011 Chevrolet Express G 1500 Cargo Van

NM license plate number "NHR850"
VIN "lGCSGAFXOBl 140402"
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Owner Nam,: Abdel Manasra
Search Propirty: 2005 Dodge Grand Caravan

NM license plate number "MLA224"
VIN "2D4GP44L55R166343"
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I 2002 Mercedes-Benz 500ML
NM license plate number "MWH283"
VIN "4JGAB75E52A323268"
Open source queries of the AN. Jewelry Company indicate that it is listed as operating in the
" ... jewelry, precious stones and precious metals" industry. Furthermore, the Cagua residence and the AN.
Jewelry Company ar~ both listed as being owned by Arafat Nimer. A search of any public or retail outlet for
1
the sale of jewelry by A.N. Jewelry or Nimer returned negative results.

Financial links to St rling
An examinati n of financial records, revealed that Nimer d.b.a. AN. Jewelry Company has purchased
over $15,000 injewe ry from Sterling.
6/7/2011 MariaNimer $1500 Sterling Islands
11 MariaNimer $1500 Sterling Islands
8/15/2011 Maria Nimer I Jewelry $1000 Sterling Islands
9/20/ ria Nimer $1000 Sterling Islands
30
11121/2011 MariaNimer $1,100 Sterling Islands

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12/14/2011 I MariaNimer f$200o Sterling Islands

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7/8/2012 !
Maria Nimer I Jewelry $1500 Sterling Islands
.
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Covert Purchases
On October l~, 2014, I attended the Albuquerque Flea Market located at the intersection of Louisiana
i
Blvd. and Central Av~. I previously obtained information from the observations of another USFWS OLE agent,
Resident Agent in Ch~rge Ariel Vazquez, that jewelry similar to the pieces Sterling had imported, was being
sold by an unidentifie~ vendor at the market.
While walkin~ through the market booths, SA Noel Wagner and I located a male subject, who identified
himself as " ... Mohammad". This individual was later identified through associated Department of Motor
Vehicle (DMV) registration records and photographs, as Mohammad Manasra. I observed Manasra selling
jewelry consistent wi~ the Sterling imported jewelry. Upon closer inspection, I recognized several of the
pieces by their overall design, markings, and stamped initials, as consistent with Sterling imported jewelry.
Manasra had ~everal cases, filled with Native American-style jewelry, displayed at his booth.
Additionally, a white bargo van bearing New Mexico license plate 688NPT was parked immediately behind the
I
area where the jewel+ was being displayed. This van, hereinafter referred to as "Original Market Van," was
subsequently identifi9d as belonging, and registered to Manasra. The registration information for the Original
Market Van revealed pn associated address of: 2304 Cagua Drive Northeast, Albuquerque, New Mexico. This
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address is listed on lar enforcement databases as an older associated property of Manasra. Most importantly,
this address is the sa1*e registered address as the official business address of the "A.N. Jewelry."
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I contacted M~nasra in a covert manner and began to speak with him about his jewelry and the respective
prices. Manasra stated that he supplies jewelry in a" ... wholesale fashion", to locations outside of New Mexico.
Later review of financial records revealed that Manasra and the subject, Abdel A. Manassra (believed to be
Mohammad's brother~, have both sold jewelry to Gallery 8 (NM), Galleria Azul (NM) and Galleria Azul (AZ). (It
should be noted that ~allery 8 and Galleria Azul have purchased jewelry directly from Sterling and also from the
Mohammad Manasra and Abdel Manassra.) All of the checks listed below were written from one of the Gallery 8 or
Galleria Azul accoun~s to Mohammad Manasra or Abdel Manasra.
31

11/11/2013 Nael Ali I Galleria Azul (AZ) $1500 Mohammad Manasra
3/4/2014
1 Nael Ali I Galleria Azul (AZ) $1122 Mohammad Manasra
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5/4/2014 ! Nael Ali I Galleria Azul (AZ) $1500 Mohammad Manasra
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5/16/2014 T Nael Ali I Galleria Azul (AZ) $1500 Mohammad Manasra

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3/7/2011 I Nael Ali I Galleria Azul (NM) $2000 Mohammad Manasra

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7/14/2011 T Nael Ali I Galleria Azul (NM) $564 Mohammad Manasra

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9/7/2011 T Nael Ali I Galleria Azul (NM)
!
$100 Mohammad Manasra
!
9/22/2011 T Nael Ali I Galleria Azul (NM)

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$500 Mohammad Manasra
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10/5/2011 Nael Ali I Galleria Azul (NM) $800 Mohammad Manasra

TI

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11/26/2011 t!
Nael Ali I Galleria Azul (NM) $1000 Mohammad Manasra
12/10/2011
I N ael Ali I Galleria Azul (NM) $450 Mohammad Manasra
5/30/2012 ! Nael Ali I Galleria Azul (NM) $400 Mohammad Manasra

J_
6/26/2012 I
N ael Ali I Galleria Azul (NM) $420 Mohammad Manasra
1
10/3/2012
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J_
N ael Ali I Galleria Azul (NM) $800 Mohammad Manasra
11/13/2012 I
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5/25/2013
1
T Nael Ali I Galleria Azul (NM) $1000 Mohammad Manasra
i
_;_
:
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6/11/2013 ti Nael Ali I Galleria Azul (NM) $500 Mohammad Manasra

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10/23/2013
3/26/2014
t Nael Ali I Galleria Azul (NM)
Nael Ali I Galleria Azul (NM)

$500
$1500
Mohammad Manasra
Mohammad Manasra

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8/20/2014 T Nael Ali I Galleria Azul (NM) $1000 Mohammad Manasra
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9/18/2014 I
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10/6/2014 Nael Ali I Gallery Azul (NM) $500 Mohammad Manasra

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9/22/2011 N ael Ali I Gallery 8 $500 mmad Manasra
10/10/2011 N ael Ali I Gallery 8 $755 Mohammad Manasra
10/18/2011 N ael Ali I Gallery 8 $1000 Mohammad Manasra
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5/30/2012 T Nael Ali I Gallery 8 $1000 Mohammad Manasra

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6/13/2012 I
Nael Ali I Gallery 8 $500 Mohammad Manasra
'
10/3/2012 I Nael Ali I Gallery 8 $1200 Mohammad Manasra
11113/2012 I Nael Ali I Gallery 8 $350 Mohammad Manasra
1/15/2013 I
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3/21/2013 I I Nael Ali I Gallery 8 $851 Mohammad Manasra

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6/1112013 Nael Ali I Gallery 8 $500 Mohammad Manasra
1
6/21/2013 t I
8/20/2013 i
10/8/2013 I'
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l
10/23/2013 I Nael Ali I Gallery 8 $500 Mohammad Manasra
I
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3/26/2014 !
8/20/2014 + Nael Ali I Gallery 8 $1000 Mohammad Manasra

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9/18/2014 1I Nael Ali I Gallery 8 $1000 Mohammad Manasra

L
6/13/2012 Nael Ali I Gallery 8 $150 Abdel A. Manassra
I 612612012 Nael Ali I Gallery 8 $600 Abdel A. Manassra
34
l.
4/28/2013 Nael Ali I Gallery 8 $1000 Abdel A. Manassra
4/15/2014 I Nael Ali I Gallery 8 $1000 Abdel A. Manassra

I
8/19/2014 I Nael Ali I Gallery 8 $1000 Abdel A. Manassra
I
5/12/2012 I Nael Ali I Galleria Azul (NM) $800 Abdel A. Manassra
312112013 I
Nael Ali I Galleria Azul (NM) $500 Abdel A. Manassra
3/21/2013 i Nael Ali I Galleria Azul (NM) $500 Abdel A. Manassra

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4/15/2014
1l Nael Ali I Galleria Azul (NM) $1000 Abdel A. Manassra
4/25/2013 T Nael Ali I Galleria Azul (NM) $1000 Abdel A. Manassra

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5/23/2014 N ael Ali I Galleria Azul (NM) $900 Abdel A. Manassra

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8/18/2014 Nael Ali I Galleria Azul (NM) $1000 Abdel A. Manassra
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9/16/2014 1 Nael Ali I Galleria Azul (NM) $2220 Abdel A. Manassra
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1/12/2014 lII
Nael Ali I Galleria Azul (AZ) $1500 Abdel A. Manassra
i
At the Albuq*rque Flea Market on October 19, 2014, I observed Manasra retrieve several plastic bags
containing jewelry from the Original Market Van. While Manasra was retrieving the items, I observed that the van
contained a large inv~ntory of packaged jewelry, secured in a cardboard box. I also noted that the jewelry Manasra
retrieved from the vaJ was consistent with the Sterling imported pieces I had observed during the July 30, 2012,
Sterling importation i~spection. Specifically, I observed a ring which I knew to be consistent with a Sterling
imported ring. Upon,! handling the item, I observed the "cornrow" design and stamped leaf symbol on the inside of
the ring, which I had pbserved on several Sterling imports, during the July 30, 2012 inspection.
Manasra told me that he gets all his jewelry from Gallup, NM. And he also said that his brother buys the
jewelry. When quest~oned about which tribes make the jewelry, Manasra motioned to jewelry in the cases and
I
pointed out pieces th~t he claimed were made by the Navajo and Zuni. I then asked to see the "cornrow" ring for a
second time. Manasr~ described it as," ... corn cut." I asked if the ring was a Zuni item, but Manasra corrected me
and said, "No, that's Navajo."
I then asked see another ring displayed in one of the cases which I knew to be consistent with a Sterling
import. Specifically, recognized the overall design of the ring and the "OY," initials on the inside of the item.
35
Manasra confirmed that the ring was, "Navajo ... yeah." Again, I recognized this ring as being identical to one
documented during the July 30, 2012 inspection.
Manasra told me that he comes every weekend to the
flea market and has been selling at the flea market and in
Santa Fe for twenty-two (22) years. Manasra then picked out
a Kokopelli (Hopi Deity) design pendant and eaning set and
gave them to me. I examined the pendant and observed a
decal affixed to one side that read, "Made in Philippines."
Without confronting Manasra about the decal, I asked if the
piece was also Zuni to which Manasra replied, " Yeah." I
also observed the same leaf symbol stamped on the inside of the pendant as those observed on the Sterling imports.
Manasra sold the items to me in violation of 18 U.S.C. 1159. I observed several other items offered for sale by
Manasra that were consistent with Sterling Imports before he left the booth.
Connection Between Manasra and A.N. Jewelry's Registered Business Address (the Nimer Property)
On July 2, 2015, RAC Ariel Vazquez conducted surveillance on the Cagua residence, in support of this
investigation. During this surveillance the agent observed a newer model, white cargo van, parked in the driveway oj
the residence, (hereinafter, "New Market Van"). The agent noted and recorded that this van bore New Mexico
license plate NHR850. Subsequent registration queries revealed that the New Market Van is also registered to
Manasra.
On July 4, 2015, I observed Manasra and the New Market Van, parked at the Albuquerque Flea Market, in a
different booth locatiqn. SA Wagner and I both observed that Manasra had the same type of jewelry displayed for
sale in an identical manner as he did during the October 19, 2014 encounter. SA Wagner also noted large cardboard
boxes inside the van, consistent with those observed during the October 19, 2014 encounter.
On August 17, 2015, SA Wagner observed Manasra and the New Market Van parked, again, at the
Albuquerque Flea Market in the same location as observed on July 4, 2015. Manasra was in the process of setting up
his booth in the same manner as previously observed. SA Wagner noted that the New Market Van now had a white,
"C-0-E-X-I-S-T" sticker in the rear (passenger-side) window. SA Wagner also observed large cardboard boxes,
consistent with the October 19, 2014 encounter, within the van.
On August 23, 2015, I conducted surveillance at the Nimer residence. At 7:44am, I observed Manasra
arrive at the location in a black Mercedes SUV which bore New Mexico license plate MWH283. Subsequent
registration queries revealed that this vehicle is registered to Abdel J. Manasra at 7401 Countrywood Ave. NW
in Albuquerque, NM. Based on statements made by Manasra during the October 19, 2014 encounter and
financial and property connections, Abdel Manasra is believed to be the brother of Mohammad Manasra. I
36
! Document 1-2 Filed 10/26/15 Page 2 of 28
i
observed the male su~ect exit the Mercedes SUV and enter Nimer's property. The subject then backed the
New Market Van dow;n the driveway and subsequently retrieved a cardboard box from the Mercedes SUV. The
male subject placed the box in the passenger seat of the New Market Van, entered the vehicle, and exited the
driveway. I observed !the subject drive the New Market Van to the Albuquerque Flea Market located at Central
Ave. and Louisiana Bivd. Later that same day, at approximately 4:30pm, I observed the New Market Van
parked on the Nimer property. Specifically, the New Market Van was parked at the end of the driveway and
I
behind a chain link fence which closes in the side yard of the property. I noted that the Mercedes SUV was no
I
longer at the Nimer p~operty.
Again, on Au~ust 29, 2015, at 7:20am, I observed the Mercedes SUV parked at an intersection close to
Nimer's residence. Apditionally, I observed that the New Market Van was absent from Nimer's property. At
3:00pm that same day! I observed the New Market Van parked behind the fence at Nimer's residence and that
the Mercedes SUV wts gone.
And again, onlAugust 30, 2015, at 6:10am, I observed the New Market Van parked at the Nimer
property. At 8:14am, I observed one male subject fitting Manasra's description, arrive at Nimer's residence.
1
The subject was driving a white Dodge Grand Caravan bearing NM license plate MLA224. Subsequent
I
registration queries re~ealed that this vehicle is registered to Abdel J. Manasra at 7401 Countrywood Ave. NW
in Albuquerque, NM. I I observed the subject retrieve a cardboard box from the Grand Caravan and place the
box in the passenger ~eat of the New Market Van. I then observed the subject leave the property driving the
0
New Market Van. At 1:OOpm, I observed Manasra and one additional male subject at Manasra's booth at the
Albuquerque Flea MJrket. I observed the same Native American-style jewelry in glass cases, setup at
Manasra's booth. I oiserved the New Market Van parked behind Manasra's booth and a cardboard box, placed
in the passenger seat <;>fthe New Market Van. This box was consistent with the box I had seen placed in the
New Market Van at Nimer's residence, previously. At approximately 3:00pm, I observed Manasra outside his
!
residence at 909 TumP.Ius Dr. NW in Albuquerque, NM. I also observed the Grand Caravan parked in the street
I
outside the residence.I I observed Manasra talking on a mobile phone as he appeared to be shuffling vehicles in
his driveway.
On SeptembeIJ 6, 2015, I conducted surveillance at Nimer's residence. At 2:27pm, I observed one male
!
subject, fitting Manasra's description, arrive at the residence driving the New Market Van. I observed the
subject retrieve a car4board box from the New Market Van and place the box in the back of the Grand Caravan.
I then observed the s~bject parking the New Market Van behind a fence of the residence.
On Septembel 12, 2015, at 11 :43am, I observed the Grand Caravan parked in the front parking lot of
Sterling. I then obse7ed a male subject fitting Manasra's description drive the Grand Caravan from Sterling to
Nimer's residence. \fhile following the Grand Caravan, I lost visual contact for approximately two minutes. I
37
I Document 1-2 Filed 10/26/15 Page 3 of 28
I
regained visual conta4 of the van, but the driver had already parked in the driveway ofNimer's residence
directly behind the New Market Van and could no longer be seen outside the residence. The Grand Caravan
!
could not have been parked there for more than 30 seconds before I took up surveillance ofNimer's residence.
I maintained the surv~illance for approximately one hour but saw no further movement. Based on my
I
investigation and exptjrience, there is probable cause to believe the driver of the Grand Caravan was inside the
Nimer residence or in the fenced area behind the Nimer residence.
1
On Septemberli 13, 2015, at 6:43am, I observed the Grand Caravan parked back at Manasra's residence at
909 Tumulus Dr. NW in Albuquerque, NM. The Grand Caravan was backed into the driveway close to the
garage door. Then at ~pproximately 7:30am, I conducted a trash cover at Sterling in an attempt to recover any
evidence of the Gran9 Caravan's visit the previous day. I recovered several large, clear plastic bags, each filled
with the empty jewelrr packaging, which was all consistent with that used in the shipments from FA4U.
On Saturday, ~ctober 24, 2015, SA Wagner conducted a surveillance ofManasra's residence at 909
Tumulus Dr. NW in 41buquerque, NM. Simultaneously, I conducted a surveillance of the Nimer residence at
2304 Cagua NE in Alpuquerque, NM. Both of us initiated our surveillances at approximately 6 am. SA
Wagner initially observed the Grand Caravan and a silver SUV parked side-by-side in the driveway of the
residence. These two/vehicles blocked the garage from vehicle entry and exit. At approximately 7:20am, SA
Wagner left his positipn at the Manasra residence and returned at approximately 7:32am. Upon his return, SA
Wagner observed tha~ the Grand Caravan had been moved onto the street in front of the residence and the spot
that it had been parke~ in the driveway was vacant.
At approxim~tely 6am, I observed the New Market Van parked behind the fence on the Nimer
residence property. Additionally, I observed a white sedan parked in the driveway behind the New Market Van.
At approximately 7:3pam, I observed Manasra arrive at the Cagua residence driving the black Mercedes SUV.
I observed Manasra park the vehicle across the street from the residence and enter the premises. I then observed
!I
an unknown male su~ect move the white sedan from the Cagua residence driveway to clear the way for the
New Market Van. I t~en observed Manasra back the New Market Van down the driveway of the residence,
walk across the street1and retrieve some items from the front passenger seat of the black Mercedes SUV. I then
observed Manasra opfri the rear lift gate of the black Mercedes SUV. Subsequently, I observed Manasra
walking away from t~e black Mercedes SUV with a white colored package and the items he retrieved from the
passenger seat. Man4sra then opened the passenger side door of the New Market Van and placed the items into
the van. This behav~or was consistent with previous surveillance operations in which Manasra was observed
retrieving items from the rear cargo area of his vehicle and placing them into the New Market Van. Manasra
1
then entered the driv~r's side of the New Market Van, exited the driveway and drove in the direction of the
I
Albuquerque Flea Mket.
38
On Sunday, October 25, 2015, SA Wagner conducted a surveillance ofManasra's residence at 909
Tumulus Dr. NW in ~lbuquerque, NM. Simultaneously, I conducted a surveillance of the Nimer residence at
2304 Cagua NE in Aluquerque, NM. SA Wagner observed the Grand Caravan and a silver SUV parked side-
by-side in the drivew y of the residence. These two vehicles blocked the garage from vehicle entry and exit.
At approximately 7:4 am, SA Wagner observed Manasra move the Grand Caravan from the driveway and onto
the street. SA Wagner then observed Manasra exit the garage of the residence driving the black Mercedes SUV
!
and leave the area.

At approxima ly 7:30am, I observed the new market van parked on the Nimer property and a white
sedan parked in the drveway directly behind the new market van. At approximately 7:55am, I observed
Manasra arrive at the imer residence in the black Mercedes SUV and park in front of the residence on the
street. I observed an nown male subject move the white sedan out of the driveway clearing the way for the
new market van. At ~:08am, I observed Manasra backing the new market van down the Nimer residence
driveway. I then observed Manasra exit the new market van and walk to the black Mercedes SUV where he
1
unlocked the rear lift ate. I then observed Manasra remove two cardboard boxes from the cargo area of the
black Mercedes SUV d place them on the front passenger seat of the new market van. The boxes were
consistent with those bserved on previous surveillances of Manasra at the Nimer residence and at the
Albuquerque flea man et. Manasra retrieved an additional item from the front passenger area of the black
Mercedes SUV, placed it in the new market van and drove away at 8: 11 am.
!
At app~oximately 8:30am, I observed Manasra at the Albuquerque flea market setting up his
jewelry booth. I obsefved the new market van parked at the location and the two cardboard boxes in the front
passenger seat. I also observed Manasra organizing Native American-style jewelry on the tables set up in his
booth.
Conclusion
Based on the frets related within this affidavit, my training and experience, and the training and
f
1
located at the premise described in Attachment A, and are evidence, fruits, and instrumentalities of violations
country of origin), 18IU.S.C. 1159 (violation of the Indian Arts and Crafts Act), and 18 U.S.C. 371
(conspiracy).
39
7. Business Na,e: Sundancer Jewelry, d.b.a., GS New Mexico

Owner Namer Mohammad Sharifi, Steve Sharifi, Soraya Sharifi
Search Locat~on: 202 San Felipe NW, Ste. A, Albuquerque, NM

I
Organizational Role: Retailer
Sundancer Jewelry ("Sundancer") is a retail location located at 202 San Felipe NW, Ste. A, in the Old
Town portion of Albufl.uerque, NM. Mohammad R. Sharifi is listed as the President, Zahir Sharifi is listed as
the Vice President an4 Secretary, and Steve Sharifi is listed as the Finance Administrator.
Financial Links to S~rling
I
An examinatidn of financial records revealed approximately $70,255 in payments from Abdul Sharifi
and Soraya Sharifi, d.p.a., Sundancer I GS New Mexico Silver, to Sterling. The payments were made by
I
checks drawn on Sundancer and GS New Mexico Silver accounts with Bank of America (Acct.#
439004433752 and 0~0119600617, respectively). The payments were made to Sterling's Bank of America
I
account, numbered 4~5017473826.
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Date C1eck Signer I Notes Amount Payee
10/2/2012 Sdr~a Sharifi ( ... 3752) I Silver Jewe!!Y $7,000 Sterlin_g_(435017473826)
10/3/2012 Soraya Sharifi ( ... 3752) I Inv. #1447 $5,048 Sterling (435017473826)
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1/19/2013 Ai)dul Sharifi ( ... 3752) $17,656 Sterling (4350174738261
5/19/2013 Abdul Sharifi( ... 0617) I Silver Jewe!!Y $4,506 Sterling (435017473826)
9/17/2013 Arul Sharifi( ... 0617) / Silver Jewelry $6,222 Sterli1!8_ (435017473826)
3/22/2014 ul Sharifi ( ... 0617) I Silver Jewelry $10,737 Sterling (435017473826)
$51,169
I
I
On January 28, 2014,lrecords were obtained which included a partial Sterling receipt titled, "Sold to: Sundancer
Jewelry (GSNM)." The partial receipt detailed two hundred and thirteen (213) pieces of jewelry with a total
I
amount of $9264.
Covert Purcliases
i
On October 17, 2014,1 I visited Sundancer in a covert manner and observed various pieces of jewelry offered for
sale, which were consisteint with jewelry imported by Sterling from the Philippines. None of these items were
i
marked in any way to infPrm the customer that they were manufactured in the Philippines. Soraya Sharifi was
working in the store at the time and helped me during the contact. I asked to look at some bracelets which I
recognized as being consistent with Sterling imports.
40
Sundancer Purchase Sterling Import
Specifically, I r cogni z d the inlaid pueblo design, the unique symbols and the "CR" initials stamped on the on
the inside of the bracelet
I also recognized several rings to be consistent with those imported by Sterling. Specifically, I recognized the
"cornrow" inlaid design and the initials "CK" stamped on the inside of the rings.
Sterling Import
Soraya told me that the rings were Zuni made. She went on to explain that, in general, the inlaid jewelry
was Zuni-made and he single stone jewelry was Navajo-made. I then asked to look at a necklace and earring
set which I rec:OJ,nized as being consistent with a Sterling import. Specifically, I recognized the pendant design
and "NT" initials on rhe back of the item.
41
Sterling Import qT''l'''I ''l'''J 1 I ! Pl \
Soraya told me that the necklace and eanings were Navajo-made. I motioned to the necklace and
confirmed that it was 1 vajo, to which she agreed. I then asked if both the bracelet and ring were Zuni-made
and Sharifi c-0nfirmcd that they were. Soraya went on to say that she has had the store for three years but her
family has been int 1e jewelry business for twenty years. Soraya then explained that she has, "some Navajos in
the back that ... hand make pieces." The items were sold to me for a total of $1001.52, all in violation of 18
U.S.C. 1159.
Recent Activity
On October 16 2015, an assisting federal agent visited Sundancer in a covert manner. The agent
observed jewelry di pla cd in the store and offered for sale which was consistent with Sterling imports. Steve
Sharifi, husband of ora a~ told the agent that some of the jewelry was Native American to include Navajo,
Zuni, and Hopi, some of the jewelry was made in-house, and some was traded with locals and those pieces
could be made l wh re. I reviewed the covert video of the visit and observed several items offered for sale in
the store which were consistent with Sterling imports. Depicted below are two of the pieces I observed in the
video which are cun ~i sre nt with Sterling imports. Additionally, the necklace seen in Sundancer appears to be
consistent with the necklace I purchased on October 17, 2014.
42
Conclusion
Based on the facts related within this affidavit, my training and experience, and the training and
items to be seized as described in Attachment B, which is attached hereto and fully incorporated herein, will be
located at the premises described in Attachment A, and are evidence, fruits, and instrumentalities of violations
(conspiracy).
43
I
8. Business Na~e: Silver Coyote
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OwnerNamef Yousef Nassar

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Search Locadon: 112 Old Santa Fe Trail, Santa Fe, NM 87501
Organizational Role: Retail
Yousef Nass~ is listed as the registered agent of Silver Coyote according to New Mexico Secretary of
State records. Tamar~ Nassar, YousefNassar's wife, is listed as the registered agent of a sister store, Santa Fe
Native Designs.
I
A review of b.nk records revealed that a financial relationship exists between the Nassar's and Sterling.
Over $21,000 in chec~s (many referencing silver jewelry in the memo line) have been written by YousefNassar
and Tamara Nassar Cfousef's wife) from the business accounts of Silver Coyote and Santa Fe Native Design to
Sterling. I
C:overtl'urchases I
I
On August 16~ 2012, HSI SA Mark Phillips and I visited Silver Coyote, located at 112 Old Santa Fe
Trail in Santa Fe, NM in a covert manner. Silver Coyote is a jewelry store which is located in the "plaza"
district of Santa Fe, NM. When I entered the store a salesman, Justin, told me that everything in the store was
60% off in preparatio~ for "Indian Market."
Justin told meithat everything in the store was Native American made. While in the store, I overheard
another employee tell 'Tiger,' the owner of the store (who I later identified as Yousef Nassar), that a "928"
1
stamp on one of the j~welry pieces in a case meant the piece was not made in the United States. The employee
said that three custonfrs had told him about the stamp. At that point Nassar got very angry and told the
employee to shut-up. ,Nassar said he was the boss and if an employee wants to know something he should ask
him. Nassar said, "if ~ere is a snake in the store I'll cut his head off." Nassar went on to say that he had six
I
kids and a wife to takf care of. All of this was said in front of SA Phillips and me, as we walked around the
store. After the exchfge between Nassar and the employee, Nassar told me that some of the items in the store
were imported. None! of the pieces appeared to be marked as imported or stamped with the country of origin.
I observed several pieces of jewelry in the store that were similar in appearance to pieces imported by
Sterling. Nassar gav9 me one of his cards when I expressed interest in buying some jewelry. 3
3 On several occasiotjs, I have observed YousefNassar at the Santa Fe Native Designs store.
I 44
On September 28, 2012, SA Phillips and I once Inspection Photograph

again made a covert oontact with Nassar at Silver
Coyote in Santa Fe, NM. I questioned Nassar about
two bracelets which were consistent in appearance with
those that I had seen imported by Sterling, on May 28,
2012 under UPS H8967696291. Specifically, I
recognized th~ inside of the bracelets have a series of
distinct stamped or engraved symbols as well as the
initials "CR" marked in them. Additionally, it is

apparent from the interior markings on the two
bracelets that they have been stamped using the same
"mold" as the same defects appear in both bracelets in
the same sequence. When asked by whom and where
the bracelets were made, Nassar told the SAs that they
were made in Albuquerque and Gallup at his factory
Purchased Item
and were Indian designed. Nassar told me that the
items were made in America on three separate occasions. I purchased the two bracelets from Nassar for a total
of $932.59. Upon purchasing the items, I compared them to the photographs of those imported by Sterling and
found them to match.
On July 16, 2013, I entered Silver Coyote in a covert manner and observed various cases of Native
American style jewelry and other Native American style crafts for sale in the store. The owner of the store
introduced himself to me as "Tiger," and recognized me from their previous encounters. Nassar's son was also
present in the store. I observed several pieces of jewelry which were consistent with that which had been
imported by Sterling from FA4U. I referenced a visit to the store
that I made approximately a week prior in which I had not seen
Nassar. Nassar told me that his cousin was working in the store at
the time.
I asked about a ring which I had been told was produced by
"GL Miller," by Nassar's cousin during the visit a week prior.
Nassar found the ring and showed it to me. I asked Nassar why
one of the rings appeared to have a hole in one of the inset pieces
of spiny oyster shell. (The hole appears to be drilled into the shell.
45
I speculated at the time that another, filler stone, had fallen out
of the ring.) Nassar told me that the hole was supposed to be
there as that is how the glue is injected under the shell pieces to
adhere them the ring bezel. Nassar's son told me that he would
receive a certificate of authenticity with the ring if I purchased it.
(After the son told me about the certificate, Nassar said
something to his son in Arabic. Upon review, it was found that
Nassar's statement is unintelligible.) I recognized the spiny
oyster ring as being consistent with a Sterling imported item.
Specifically, I recognized the design and raincloud symbol on
the inside of the ring. I had seen this type of ring and the
raincloud symbol in photographs taken during the inspection of a Sterling import on July 30, 2012. Nassar told
me that he would not charge me sales tax for the purchase. Nassar then told me that the ring was Hopi made,
but not made by GL Miller. I observed several rings offered for sale in the store which were of the same design
and appeared to be consistent' with Sterling imported items.
Nassar told me that the Hopi artist that made the ring is 87 years old. Nassar also told me that only
Silver Coyote and another store in Taos carry the artist's work. I asked for the artist's name while referencing
the raincloud symbol on the inside of the ring. Nassar told me that the artist's name was "Koko Bilah," wrote
the name on his business card for me, "Koko Bilah," and gave the business card to me after the purchase was
complete. Nassar sold the "Koko Bilah" ring to me for $195, in violation of 18 U.S.C. 1159.
Recent Activity
On October 14, 2015, an assisting federal agent entered the business in a covert manner. The agent
observed several pieces of jewelry in the store which were consistent with Sterling imports.
Conclusion
Based on the facts related within this affidavit, my training and experience, and the training and
items to be seized as described in Attachment B, which is attached hereto and fully incorporated herein, will be
located at the premises described in Attachment A, and are evidence, fruits, and instrumentalities of violations
(conspiracy).
46
I
9. Business Nanie: Kuchi Gallery, Inc., d.b.a., Momeni's Gallery
Owner Name~I Ismail Momeni

I
Search Location: 222 Old Santa Fe Trail, Santa Fe, NM 87501

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Organization~( Role: Retail
Kuchi Gallery~ Inc., d.b.a., Momeni's Gallery ("Momeni's") is a retail store located at 222 Old Santa Fe
Trail in Santa Fe, NM. Ismail Momeni is listed as the President of Kuchi Gallery, Inc. according to the New
Mexico Secretary of *ate database.
An examinatiJn of Sterling financial records revealed four payments made from Kuchi Gallery, Inc. to
I
Sterling Islands between 5/23/2013 and 6/10/2014.
Date '
Payer/Memo Amount Payee
5/23/2013 Kuchi Gallery $3,122 Sterling
6/24/2013
7/24/2013
l !
Kuchi Gallery
Kuchi Gallery
$7,500
$7,500
Sterling
Sterling
I
6/10/2014 1 Kuchi Gallery $7,985 Sterling
l
T
Recent Covert Purcltase

i
On October 20, 2015, I visited Momeni's in a covert manner and observed jewelry, rugs, pottery and
other items for sale. rhe jewelry offered for sale was displayed in several cases in one section of the business.
I observed several ite~s for sale which were consistent with both Sterling imports and IJW imports.
I
Specifically, I observd pendants, rings, and necklaces which appeared to be consistent with Sterling imports
and several rings, bea~ pendants, and bracelets which appeared to be consistent with IJW imports.
Two male sub~ects were present at the business while I was there. The older subject, who identified
I
himself as Noor LNU~ helped me throughout the contact. The other subject identified himself as Hamed LNU
and assisted me at th~ end of the contact. I asked to look at several of the items which I knew to be consistent
I
with the imported iterps. Among these items were:

A beat pendant which was consistent with the IJW imports in its shape and design. The bear
pendaht was two-sided and the design stamped into the metal on the back side of the bear was
consi~tent with other IJW imports that I have seen from previously documented inspections of
! .
IJW imported jewelry. The bear pendant did not have the "IJ" initials seen in the IJW imports,
howeter. Noor LNU told me the bear pendant was Zuni-made and, "one, only," which I
unde4tood to mean one-of-a-kind. After covert contact, I compared the bear pendant with
i
I
I 47
anof er bear pendant which I documented during the IJW inspection I conducted on February
20, 2 105 . The two items appear to have an identical inlaid design.
48
A butterfly necklace which I knew to be consistent with Sterling imported jewelry.
An inlaid silver cuff br_acelet, marked for $1700, with "IJ" initials stamped in it. The bracelet
was consistent with those imported by IJW, previously.
An inlaid ring which I knew to be consistent with those imported by IJW. The ring was offered
for sale for $1300 and had "IJ" initials stamped in it. I asked Noor LNU if the items were also
Zuni, in reference to the bear pendant which Noor LNU told me was Zuni-made. Noor LNU
responded, "it's the same." I asked about the " IJ" initials and if Noor LNU knew the artist.
Noor L told me that he did know him and that he's, "the guy in Albuquerque."
49
A double bracelet" which I knew to be consistent with IJW imports. I have seen items
con i tent with this bracelet in both the IJW inspection that I conducted on February 20, 2015,
and in photographs taken during the IJW inspection conducted in Louisville, KY by USFWS
Wi ldlife Inspector.s on February 10, f015. The bracelet had the initials "IJ" stamped in it. I
r marked that it was probably made by the same guy, referencing the bracelet and ring, above.
Noor l ' agreed by saying, "yeah."
I walled into another section of the store and asked, "is this Native American stuff too?" Noor
LNU replied, "oh yeah."
A pendant which I knew to be consistent with those imported by Sterling. Specifically, the
pendant was consistent with items documented during prior Sterling import inspection.
Refening to the pendant, I stated that I wanted to make sure I got something Native American
and oor LNU replied, "That's what it is ... "
Momeni's Ga llery
I repeatedly mentioned the jewelry and that I was surprised in the variation of the designs within the
same tribal affiHation. At no time did Noor LNU correct me and tell me the items were imported. In addition,
nothing in the store acl.v.iscd a potential customer that the items were imported and not Native American-made
as claimed by Noor LNU . I asked Noor LNU how long he had been selling Indian jewelry and Noor LNU told
me that he had been elling for sixteen years.
50
I
The ring, brac9let and pendant were all sold to me for $1559.80, in violation of the 18 USC 1159. I
asked Noor LNU one ore time ifhe knew the identity of the artists who made the items. Noor LNU replied
that he did not. I told im it didn't matter as long as my father knew the item was Zuni-made. Noor LNU
replied, "Yeah, he wil know."
Conclusion
Based on the lets related within this affidavit, my training and experience, and the training and
experience of agents d investigators involved in this investigation, there is probable cause to believe that the
I
located at the premise~ described in Attachment A, and are evidence, fruits, and instrumentalities of violations
of 18 U.S.C. 542 (i~portation by false or fraudulent practice), 19 U.S.C. 1304 (failure to mark goods with
country of origin), 18 p.s.c. 1159 (violation of the Indian Arts and Crafts Act), and 18 U.S.C. 371
'
(conspiracy).
51
10. Business Name: Gold House LLC.
I
Owner Name(s): Mark Shaw I Ala Shawabkeh
Target Location: 218 Old Santa Fe Trail, Santa Fe, NM 87501
Organizational Role: Retail
Gold House is a retail jewelry store located at 218 Old Santa Fe Trail in Santa Fe, NM. Ala Shawabkeh
. is listed as the officer for Gold House LLC., according to the New Mexico Secretary of State database.
However, Mark Shaw is listed as the owner of Gold House according to their website,
www.santafegoldhouse.com, and a law enforcement database.
Recent Covert Purchase
On October 20, 2015, I visited Gold House in a covert manner and observed jewelry and other crafts for
sale. Specifically, I observed several pendants, rings, and necklaces, offered for sale, which were consistent
with both Sterling im~orts and IJW imports. I observed two male subjects and one female subject working at
the store. During the contact, the female subject who introduced herself as Christina LNU, and one of the male
employees, Simon LNU showed me the jewelry and sold me two items.
~oughout the contact, I asked to look at items which I knew to be consistent with both IJW imports
and Sterling imports. Specifically, I looked at or was shown: G Id H
o
P h
ouse urc ase
A "cornro"f" silver ring with a feather symbol stamped
on the inside, marked with the price of $300. I
I
recognized the design and the symbol as being

consistent with Sterling imported jewelry documented
previousl)1 in the investigation. When I asked
Christina lNU who made the ring, she referred the question to Simon LNU. Simon LNU explained
that the siJ.iversmith, "signed with feather but I cannot tell. Some of them they use initials ... "
A "spinnet'' necklace and earrings set which I recognized as consistent with items I had seen during
my inspection of an IJW importation of jewelry on February 20, 2015. I also noted that the earrings
I
appeared to be mounted on the same kind of card, which reads, "Sterling Silver," as the IJW
importations.
52
ImportationPage
Photograph
GoldCase
House1:15-mr-00664-KBM
"spinne r" necklace Document 1-2 Filed 10/26/15 18 of 28
--------1---
A silver, inlaid bear pendant, marked with a price of $1500, which I recognized as being
consistent with IJW imported jewelry. Specifically, I recognized the overall inlaid design on the
front of the pendant, the stamped design on the back of the pendant, and the "IJ" initials stamped
in the leg of the bear. Upon closer examination of the bear pendant subsequent to the purchase,
I found that the stamped metal design was identical to a pendant documented during my covert
inspecction of an IJW importation on February 20, 2015.
Gold House Purchase
I agreed to purchase the ring and the bear pendant. Christina LNU, speaking about the good prices they
have in the store, said, "we're able to give you really good prices because we work directly with the artists and
we buy a big amount of whatever they have."
I then asked Simon LNU who the silversmith was that made the bear pendant as I referenced the "IJ"
initials marked in it. Sim.on LNU told me that Ervin Tsosie made the item. (It should be noted that this name
was not written anywhere in the store. As such, the spelling may not be correct.) I asked if he was Navajo, to
which Simon LNU replied, "uh yeah." An open source search of the name, Ervin Tsosie, revealed that Ervin
Tsosie is a Navajo silversmith renowned for his extremely intricate inlay work. Some of this work includes
inlaid bear pendants.
53
Simon LNU d termined the final price of the items to be $1040 (before tax). After I purchased the items
I, once again, asked t e name of the artist who made the bear pendant so I could write it down. Christina LNU
asked Simon LNU w o said, "Ervin Tsosie." I asked how the name was spelled and Simon LNU said, "s-u-s-
i." Simon LNU then ooked for and found another pendant which he said was made by Ervin Tsosie and
explained that it had t e intials, "ET," in the item. I asked Simon LNU about the "IJ'' initials found in the bear
pendant that I had pur hased. Simon LNU agreed that the "I" in "IJ'' might stand for Irvin. Simon LNU then
showed me what appe red to be a genuine Ervin Tsosie pendant and said, "he did this one too."
. ,); /-/'
r.r.~. ~
I then asked S mon LNU;n: he knew who made the ring by referring to the feather symbol. Simon LNU
responded that he did ot know and did not have the book to determine the artist. Simon LNU went on to say
that at the end of the ~ook the symbols corresponding to the silversmiths are listed. In my experience I have
seen these books ofNttive American Artists referenced in other Native American jewelry stores. I said,
"Navajo is good enou h," to which Simon LNU replied, "yeah." Simon LNU sold me two items in violation of
18 USC 1159. Additipnally, within Gold House, there were many more items offered for sale and displayed in
violation of 18 u.s.c.I 1159.
!
Conclusion
Based on the cts related within this affidavit, my training and experience, and the training and
experience of agents nd investigators involved in this investigation, there is probable cause to believe that the
located at the premise described in Attachment A, and are evidence, fruits, and instrumentalities of violations
country of origin), 18 .S.C. 1159 (violation of the Indian Arts and Crafts Act), and 18 U.S.C. 371
(conspiracy). I
54
i
VI. ADDITIONAtTRAINING AND EXPERIENCE
Based on my t aining and experience, involving the import and trafficking of counterfeit and contraband
goods, and related fin cial crimes, including, my involvement in numerous investigations, searches and arrests
1
during my career as a law enforcement officer, as previously described in the background section of this
affidavit; my involveient on a number of occasions in interviewing subject-matter experts, persons closely
associated with the cpunterfeit and contraband industry, witnesses, confidential informants, and cooperating
individuals in prior tr~fficking investigations, as well as wha~ other agents and police officers have advised me
when relating the substance of their similar interviews and the results of their own trafficking investigations;
and other intelligence linformation provided through law enforcement channels, I know the following:
a. Duringl the course of commercial, residential and vehicular searches, it is common to find items
of per onal property that tend to identify the person(s) in residence, occupancy, control, or
owners iip of the subject premises. Such identification evidence is typical of the articles people
comm nly maintain in their residences, such as canceled mail, deeds, leases, rental agreements,
photogtaphs, personal telephone books, diaries, utility and telephone bills, statements,
identi~cation documents, and keys;
b. It is generally a common practice for traffickers of prohibited goods to store their inventory and
related materials (as described above) in their residences and businesses;
c. It is g~nerally a common practice for traffickers of prohibited goods to maintain in their
commercial locations and residences records relating to their trafficking activities. Because
prohibited goods derive value from purported authenticity, in many instances traffickers will
maintatn records of authenticity. It is common practice for traffickers to keep transactional
record~ to show sale and transfer of goods. Additionally, traffickers must maintain telephone
and ad~ress listings of clients and suppliers and keep them immediately available in order to
efficieJtly conduct their business;
d. It is a~so a generally common practice for traffickers to maintain records of wire transfers,
cashie1 s checks, and money orders related to the sale and transfer of prohibited goods. Evidence
of sue~ financial transactions and records relating to income and expenditures of money and
1
wealth in connection with trafficking of prohibited goods would also typically be maintained in
resideQces and businesses; and
e. Eviden~e relevant to the trafficking and importation of counterfeit and contraband goods is
typically recovered from the main physical location of distribution and sale, and in addition,
from vehicles used to transport the prohibited goods, and from other structures on the property
being $earched, as for example, other storage lockers/areas, detached closets, containers, and
I
55
I
I
yard areas associated with the main residence and used in connection with or within the curtilage
1
of saidiesidence.
Based on the oregoing facts, my experience and training, and the experience and training of other
experienced agents w h whom I have consulted, there is probable cause to believe that the following evidence,
as described in Attac1*nent B, for the period 2010 to present will be found at the search locations, as described
in Attachment A.
A. RECORDS AND TANGIBLE ITEMS

1. The prohi 'ted goods themselves;
2. goods rela ed to the packaging, processing, storage, shipping and transportation of those prohibited
goods;
3. books, records, receipts, not<!s, ledgers, correspondence and other records relating to the distribution
of the prohlbited goods;
4. personal bboks and records reflecting names, addresses, telephone numbers, and other contact or
I
ide~tificatipn data relating to the distribution of the prohibited goods;
5. records rel~ting to income and expenditures of money related to the sale and transfer of prohibited
goods, for I example, money orders, wire transfers, cashier's checks and receipts, bank statements,
passbooks, checkbooks, and check registers; and
6. documentsl indicating travelin interstate and foreign commerce such as travel itineraries, motel and
hotel receirts, credit card receipts, and telephone bills.
I
B. COMPUTER ELECTRONIC STORAGE AND FORENSIC ANALYSIS
I
As described above and in Attachment B, this application seeks permission to search for records that
might be found on thd premises, in whatever form they are found. One form in which the records might be
found is data stored ot a computer's hard drive or other storage media. Thus, the warrant applied for would
authorize the seizure Jf electronic storage media or, potentially, the copying of electronically stored
I
information, all underlRule 41(e)(2)(B).
Probable cause
I submit that if a computer or storage medium is found on the premises, there is probable cause to
believe those records rm

I
be stored on that computer or storage medium, for at least the following reasons:
I 56
a. Based jn my knowledge, training, and experience, I know that computer files or remnants of
such filrs can be recovered months or even years after they have been downloaded onto a storage
mediut, deleted, or viewed via the Internet. Electronic files downloaded to a storage medium
can be ftored for years at little or no cost. Even when files have been deleted, they can be
recove+d months or years later using forensic tools. This is so because when a person "deletes"
a file o~ a computer, the data contained in the file does not actually disappear; rather, that data
I
remaint on the storage medium until it is overwritten by new data.
b. Therel{re, deleted files, or remnants of deleted files, may reside in free space or slack space-
that is, ~n space on the storage medium that is not currently being used by an active file-for
long p~riods of time before they are overwritten. In addition, a computer's operating system
may aljo keep a record of deleted data in a "swap" or "recovery" file.
I
I ,
c. Wholli apart from user-generated files, computer storage media-in particular, computers'
internaf hard drives-contain electronic evidence of how a computer has been used, what it has
been u,ed for, and who has used it. To give a few examples, this forensic evidence can take the
form of operating system configurations, artifacts from operating system or application
operati~n, file system data structures, and virtual memory "swap" or paging files. Computer
users t~pically do not erase or delete this evidence, because special software is typically required
for thal task. However, it is technically possible to delete this information.
d. Simila ly, files that have been viewed via the Internet are sometimes automatically downloaded
I
into a tmporary Internet directory or "cache."
e. Based ~n actual inspection of other evidence related to this investigation, spreadsheets, financial
record~, invoices, I am aware that computer equipment was used to generate, store, and print
docum~nts used in the scheme to violate the Indian Arts and Crafts Act. There is reason to
believe! that there is a computer system currently located on the premises.
I s1
Forensic evidence. I
As further desf ribed in Attachment B, this application seeks permission to locate not only computer files
that might serve as d+ct evidence of the crimes described on the warrant, but also for forensic electronic
evidence that establis1es how computers were used, the purpose of their use, who used them, and when. There
is probable cause to b~lieve that this forensic electronic evidence will be on any storage medium in the premises
because: I
a. Data o~ the storage medium can provide evidence of a file that was once on the storage medium
!
but hasi since been deleted or edited, or of a deleted portion of a file (such as a paragraph that has
been dtleted from a word processing file). Virtual memory paging systems can leave traces of
I
inform~tion on the storage medium that show what tasks and processes were recently active.
Web bjowsers, e-mail programs, and chat programs store configuration information on the
I
i
storag, medium that can reveal information such as online nicknames and passwords. Operating
systemf can record additional information, such as the attachment of peripherals, the attachment
of us4 flash storage devices or other external storage media, and the times the computer was in
use. C~mputer file systems can record information about the dates files were created and the
sequen~e in which they were created, although this information can later be falsified.
b. As exp ained herein, information stored within a computer and other electronic storage media
may pr vide crucial evidence of the "who, what, why, when, where, and how" of the criminal
condu1t under investigation, thus enabling the United States to establish and prove each element
or alte+atively, to exclude the innocent from further suspicion. In my training and experience,
i
inform~tion stored within a computer or storage media (e.g., registry information,

i
comminications, images and movies, transactional information, records of session times and
duratiors, internet history, and anti-virus, spyware, and malware detection programs) can
indicatf who has used or controlled the computer or storage media. This "user attribution"
evidente is analogous to the search for "indicia of occupancy" while executing a search warrant
58
I
I
at a re idence. The existence or absence of anti-virus, spyware, and malware detection programs
may 1 icate whether the computer was remotely accessed, thus inculpating or exculpating the
comp er owner. Further, computer and storage media activity can indicate how and when the
comp~er or storage media was accessed or used. For example, as described herein, computers
I
typical~y contain information that log: computer user account session times and durations,
I
comp1er activity associated with user accounts, electronic storage media that connected with the
com pfer, and the IP addresses through which the computer accessed networks and the internet.
Such i~formation allows investigators to understand the chronological context of computer or

!
electroric storage media access, use, and events relating to the crime under investigation.
i
Additifnally, some information stored within a computer or electronic storage media may
i
provid~ crucial evidence relating to the physical location of other evidence and the suspect. For
I
examp~e, images stored on a computer may both show a particular location and have geolocation
infonftion incorporated into its file data. Such file data typically also contains information
indica,ng when the file or image was created. The existence of such image files, along with
I
extem'l device connection logs, may also indicate the presence of additional electronic storage
I
media ~e.g., a digital camera or cellular phone with an incorporated camera). The geographic
I
and titjieline information described herein may either inculpate or exculpate the computer user.
I
Last, ifformation stored within a computer may provide relevant insight into the computer user's
state otmind as it relates to the offense under investigation. For example, information within the
!
comp1er may indicate the owner's motive and intent to commit a crime (e.g., internet searches
I
indica1ng criminal planning), or consciousness of guilt (e.g., running a "wiping" program to
destrot evidence on the computer or password protecting/encrypting such evidence in an effort
to con1eal it from law enforcement).
59
c. A pers n with appropriate familiarity with how a computer works can, after examining this
forensi evidence in its proper context, draw conclusions about how computers were used, the
purpos of their use, who used them, and when.
i
d. The prf cess of identifying the exact files, blocks, registry entries, logs, or other forms of forensic
eviden}e on a storage medium that are necessary to draw an accurate conclusion is a dynamic
proces~. While it is possible to specify in advance the records to be sought, computer evidence is
I
not al ays data that can be merely reviewed by a review team and passed along to investigators.
Wheth r data stored on a computer is evidence may depend on other information stored on the
compu er and the application of knowledge about how a computer behaves. Therefore,
contexjual information necessary to understand other evidence also falls within the scope of the
warranf.
e. Furthet, in finding evidence of how a computer was used, the purpose of its use, who used it, and
ometimes it is necessary to establish that a particular thing is not present on a storage
medi . For example, the presence or absence of counter-forensic programs or anti-virus
s (and associated data) may be relevant to establishing the user's intent.
f. I knowl that when an individual uses a computer to transmit electronic messages to place orders
intendi~g to violate the Indian Arts and Crafts Act, the individual's computer will generally
I
serve b th as an instrumentality for committing the crime, and also as a storage medium for
eviden e of the crime. The computer is an instrumentality of the crime because it is used as a
means f committing the criminal offense. The computer is also likely to be a storage medium
for evifence of crime. From my training and experience, I believe that a computer used to
commit a crime of this type may contain: data that is evidence of how the computer was used;
data thtt was sent or received; notes as to how the criminal conduct was achieved; records of
lntemi discussions about the crime; and other records that indicate the nature of the offense.
' 60
Necessity ofseizing o copying entire computers or storage media.
In most cases, thorough search of a premises for information that might be stored on storage media
often requires the seiz re of the physical storage media and later off-site review consistent with the warrant. In
I
lieu of removing storte media from the premises, it is sometimes possible to make fill image copy of storage
media. Generally spetking, imaging is the taking of a complete electronic picture of the computer's data,
including all hidden stctors and deleted files. Either seizure or imaging is often necessary to ensure the
I
accuracy and comple+ness of data recorded on the storage media, and to prevent the loss of the data either from
accidental or intentio1al destruction. This is true because of the following:

i
a. The ti+e required for an examination. As noted above, not all evidence takes the form of
docum~nts and files that can be easily viewed on site. Analyzing evidence of how a computer
I
has be1n used, what it has been used for, and who has used it requires considerable time, and
I
taking that much time on premises could be unreasonable. As explained above, because the
I
warranf calls for forensic electronic evidence, it is exceedingly likely that it wil~ be necessary to
thoroufhly examine storage media to obtain evidence. Storage media can store a large volume
of infotmation. Reviewing that information for things described in the warrant can take weeks or
month~, depending on the volume of data stored, and would be impractical and invasive to
attempj on-site.
I
b. Technipal requirements. Computers can be configured in several different ways, featuring a

I
variety! of different operating systems, application software, and configurations. Therefore,
searchi g them sometimes requires tools or knowledge that might not be present on the search
e vast array of computer hardware and software available makes it difficult to know
before search what tools or knowledge ~ill be required to analyze the system and its data on
the Pre~ises. However, taking the storage media off-site and reviewing it in a controlled
I
envirorent will allow its examination with the proper tools and knowledge.
61
c. V arie1 of forms of electronic media. Records sought under this warrant could be stored ill a
variet~ of storage media formats that may require off-site reviewing with specialized forensic
i
tools. I
I
I
I
I
Nature of examinatiof.
Based on the 1oregoing, and consistent with Rule 41(e)(2)(B), the warrant I am applying for would
permit seizing, imagi~g, or otherwise copying storage media that reasonably appear to contain some or all of the
!
evidence described inl the warrant, and would authorize a later review of the media or information consistent
with the warrant. Th~ later review may require techniques, including but not limited to computer-assisted scans
i
of the entire medium, Ithat might expose many parts of a hard drive to human inspection in order to determine
whether it is evidence! described by the warrant.

. I
The seizure 01 a company's computers may limit the company's ability to conduct its legitimate
business. As with anyl search warrant, I expect that this warrant will be executed reasonably. Reasonable
execution will likely ifvolve conducting an investigation on the scene of what computers, or storage media,
must be seized or copf ed, and what computers or storage media need not be seized or copied. Where
appropriate, officers tm copy data, rather than physically seize computers, to reduce the extent of disruption.
I
If employees of the c~mpany so request, the agents will, to the extent practicable, attempt to provide the
I
employees with copier of data that may be necessary or important to the continuing function of the company's
legitimate business. I~, after inspecting the computers, it is determined that some or all of this equipment is no
longer necessary to re~rieve and preserve the evidence, the government will return it.
62
VI. CONCLUSiqN
I
Based on the f?regoing facts, my training and experience, and consultation with other experienced
agents in investigatio9s involving the trafficking and importation of counterfeit and contraband goods, and
related financial crim,s, there is probable cause to believe that the items to be seized as described in Attachment
B, which is attached hpreto and fully incorporated herein, will be located at the premises described in
Attachment A, and arievidence, fruits, and instrumentalities of violations of 18 U.S.C. 542 (importation by
false or fraudulent pra tice), 19 U.S.C. 1304 (failure to mark goods with country of origin), 18 U.S.C. 1159
(violation of the India Arts and Crafts Act), and 18 U.S.C. 371 (conspiracy).
It is respectful y requested that this Court issue an order sealing, until further order of the Court, all
papers submitted in s pport of this application, including the application and search warrant. I believe that
sealing this document is necessary because the items and information to be seized are relevant to an ongoing
investigation into the riminal organizations as not all of the targets of this investigation will be searched at this
time. Based upon my training and experience, I have learned that online criminals actively search for criminal
affidavits and search farrants via the Internet, and disseminate them to other online criminals as they deem
appropriate, i.e., post {hem publicly online through the carding forums. Premature disclosure of the contents of
this affidavit and relat~d documents may have a significant and negative impact on the continuing investigation
and may severely jeo~ardize its effectiveness.
I declare under penaltt of perjury that the above statements are true and accurate to the best of my knowledge
and belief.
Special Agent
US Fish & Wildlife Service,
Office of Law Enforcement
Subscribed and swolto before me on this 26th day of October 2015 at Albuquerque, NM. J /:3(fl-'
I
63

Affidavit For Warrant - Sterling Island

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Affidavit For Warrant - Sterling Island

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Case title: USA v. Warrant Date Filed: 10/26/2015

Assigned to: Magistrate Judge Karen B.

Pending Counts Disposition

Highest Offense Level (Opening)

Terminated Counts Disposition

Highest Offense Level (Terminated)

Date Filed # Docket Text

PACER Service Center

UNITED STATES DISTRICT CO~'feos!'JLED

In the Mat~er of the Search of Vocr 262015

SEE ATTACHMEN A, ATTACHED HERETO AND INCOPORATED BY REFERENCE

SEE ATTACHMENi B, ATTACHED HERETO AND INCOPORATED BY REFERENCE

The search is related to a violation of:

~ Continue~ on the attached sheet.

Sworn to before me ard signed in my presence.

property, as fufther described in Attachment A (hereinafter, the " Subject Premises").

Subject Premises (Sterling Islands dba National Jewelry Buyers)

l Description of Items to Be Seized

1. Jewel manufactured by FA4U.

including send~ng electronic communications in furtherance of a scheme to violate the Indian

Arts and Craftf Act.

information thft is otherwise called for by this warrant (hereinafter, "COMPUTER"):

entties, configuration files, saved usemames and passwords, documents, browsing

phfto graphs, and correspondence;

thel presence or absence of security software designed to detect malicious software;

c. ev*ence of the lack of such malicious software;

in+stigation and to the computer user;

f. evirence of the attachment to the COMPUTER of other storage devices or similar

co*ainers for electronic evidence;

g. ev*ence of counter-forensic programs (and associated data) that are designed to

eli1finate data from the COMPUTER;

h. evt ence of the times the COMPUTER was used;

J. do~umentation and manuals that may be necessary to access the COMPUTER or to

co1duct a forensic examination of the COMPUTER;

k. recprds of or information about Internet Protocol addresses used by the COMPUTER;

of ser-typed web addresses; .

m. co~textual information necessary to understand the evidence described in this

5. Routers, modems, and network equipment used to connect computers to the

slides, negativ s, videotapes, motion pictures, or photocopies).

7. The term "computer" includes all types of electronic, magnetic, optical,

server comput~rs, and network hardware.

other magnetif or optical media.

AFFIDAVIT IN SUPPORT OF SEARCH WARRANTS

I, RUSSELL STANF~RD, having been sworn, depose and state as follows:

Wildlife Managemen1 at Frostburg State University in Frostburg, Maryland. .

No. Busine~s Name Search Location/ Pro_p_erty Role

3 Galler~ 8 1919 Old Town Road NW #8, Retailer

2005 Dodge Grand Caravan

2002 Mercedes-Benz 500ML

7 Sundaqcer Jewelry 202 San Felipe NE, Ste. A, Albuquerque, Retailer

9 Mome~i's Gallery 222 Old Santa Fe Trail, Santa Fe, NM Retailer

III. BACKG OUND OF THE INDIAN ARTS AND CRAFTS ACT

IV. THE FE ERAL CHARGES RELATED TO THIS INVESTIGATION

Manner and Means

d. On th following dates, NAEL ALI purchased from MOHAMMAD MANASRA Native

Date Check Signer I Memo Amount Payee

In violation of 18 U.S.C. 1159.

In violation o 18 U.S.C. 1159.

Owner Names: Sheda Khalaf and Jawad T. Khalaf

Search Location~ 5815 Menaul Blvd., Albuquerque, N.M. 87110

Organizational 1ole: Importer/Wholesaler

Date $ender Amount Payee