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

p Li

IN THE UNITED STATES DISTRICT COURT FOR THE

r MAR 3 1 2011 i
LJLfcHK, U.S. DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA ALEXANDRIA. VIHGIMIA

Alexandria Division

UNITED STATES OF AMERICA

v. CRIMINAL NO. 1:11 MJ250

ALIMAMY BARRIE,

Defendant.

AFFIDAVIT IN SUPPORT OF
COMPLAINT AND ARREST WARRANT

I, James R. Conner III, being duly sworn, depose and say:

1. I am a Special Agent of the Federal Bureau of Investigation (FBI) and have

been so employed since February 1995. I am assigned to the FBI's Washington Field

Office and work on a squad that investigates bank fraud and identity theft.

2. This affidavit is submitted in support of an application for a complaint and

arrest warrant for ALIMAMY BARRIE (BARRIE) for committing Identity Fraud, Title 18

United States Code, Section 1028A.

3. The facts and information contained in this affidavit are based upon my

personal knowledge and observations as well as the knowledge and observations of

other law enforcement agents involved in this investigation. I intend for this affidavit to

contain sufficient information to support probable cause, but not to include every fact

known to the government.

4. The victim in this matter is PC, a 64 year old white male who lives in

Gainesville, VA. PC's date of birth is February 8,1947. PC was recently diagnosed

with a terminal illness and in-home nurse aides provide 24 hour care. PC has a
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retirement account at T. Rowe Price.

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

FBI to report a possible identity theft and theft of assets of T. Rowe Price account holder

PC. Specifically, on December 10, 2010, T. Rowe Price had received a call from PNC

Bank in Columbus, Ohio, concerning PNC Bank account holder PC. T. Rowe Price was

told that PNC Bank customer, PC, had deposited approximately $80,000 in checks from

T. Rowe Price into his account at PNC Bank (account # ending in 5806).

6. PNC Bank account # ending in 5806 was opened on October 25,2010, by a

customer, known to PNC Bank as PC, who came into the Sharon Woods branch of PNC

Bank in Columbus, Ohio. Photographs provided by PNC Bank from cameras inside the

PNC Bank branch reveal that the man known to PNC Bank as PC is a black male. Bank

records indicate that this account (# ending in 5806) was opened using Ohio Identification

Card # ending in 8599 and Republic of Sierra Leone passport # ending in 7242. The

name on both forms of identification was PC, and his date of birth on both forms of

identification was February 8,1979.

7. At about this time, T. Rowe Price also learned that approximately $500,000

from the real PC's T. Rowe Price account had been deposited into account # ending in

4448 in the name PC at JP Morgan Chase Bank. JP Morgan Chase account # ending in

4448 was opened on September 29, 2010, by a customer known to JP Morgan Chase

Bank as PC, who came into the Columbus Square branch of JP Morgan Chase Bank

located in Columbus, Ohio. This account was opened using Ohio Identification Card

# ending in 8599 and Republic of Sierra Leone passport # ending in 7242. The name on

both forms of identification was PC, and his date of birth on both forms of identification

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was February 8, 1979. Bank records also show JP Morgan Chase Bank account

# ending in 5212 in the name PC was opened by the same man using the same forms of

identification at the same branch on October 25, 2010.

8. A review of records from T. Rowe Price indicates that assets were removed

from the real PC's T. Rowe Price account in the form of checks that were mailed to a

certain residence in Columbus, Ohio and then deposited into the new PC bank account at

PNC Bank (# ending in 5806). Assets from the real PC's T. Rowe Price account were

also removed in the form of wire transfers to the new PC account at JP Morgan Chase

Bank (# ending in 4448).

9. T. Rowe Price determined that the funds sent to PNC Bank and JP Morgan

Chase by checks and wire transfers came out of the retirement account of their client, the

real PC. After years of little activity, on-line access was established to the real PC's

account at T. Rowe Price in July 2010. At about the same time, the address for the

account was changed from that of a residence in Gainesville, Virginia, to a residence in

Columbus, Ohio.

10. T. Rowe Price contacted their client, the real PC, by telephone on

December 10,2010. The real PC told T. Rowe Price that he had not transferred funds

out of his T. Rowe Price account and had not moved to Ohio. The real PC stated that he

had not accessed his account by the internet. The real PC gave the phone to his nurse,

who stated that the real PC could not have made transfers through the use of the internet.

11. I interviewed the real PC on December 22, 2010, at his home in Gainesville,

Virginia. The real PC retired from the FDIC approximately five years ago and was

recently diagnosed with a terminal disease. The real PC lives alone at his residence in

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Gainesville, Virginia, but is assisted by a nurse aide at all times. The real PC stated that

he has his retirement account at T. Rowe Price but has not made any recent transfers

from this account. The real PC further stated he has not authorized anyone else to move

money out of his retirement account at T. Rowe Price. The real PC does not have a

computer and does not access the internet. In his capacity as daytime caregiver, his

nurse aide assists the real PC in paying his bills. The daytime caregiver is from Sierra

Leone.

12. The Ohio Bureau of Motor Vehicles (OBMV) provided a copy of Ohio

Identification Card # ending in 8599 inthe name PC issued on September 28,2010, at the

OBMV branch located at 3481 East Broad Street, Columbus, Ohio. This Ohio

Identification Card contains a photograph of the person to whom it was issued and lists

his date of birth as February 8,1979. It also lists an address in Columbus, Ohio as his

residence. The man in the photograph is a black male and is much younger than the 64

year old white male I interviewed on December 22, 2010.

13. Republic of Sierra Leone passport # ending in 7242 in the name PC

contains a photograph of a black male. The black male in the photograph on the

passport is not the white male I interviewed on December 22, 2010.

14. Ireviewed bank records of two separate accounts held at JP Morgan Chase
in the name PC. The two account numbers are # ending in 4448 and # ending in 5212.

From October 18, 2010 to December 1, 2010, nine wire transfers totaling $476,038.83
were wired from the real PC's retirement account at T. Rowe Price to account

# ending in 4448. From November 1, 2010 to November 29, 2010, internal transfers

totaling $340,500 were made from account # ending in 4448 to account # ending in 5212.
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Several checks were written from JP Morgan Chase account # ending in 5212 in the

name PC, including three payable to ANS Auto Sales of Teterboro, New Jersey, totaling

$127,000.

15. The owner of ANS Auto Sales was interviewed on February 24, 2011. He

stated that an African male visited his car dealership in November 2010, wanting to buy

cars to ship to Africa. The African male presented Ohio Identification Card (# ending in

8599) in the name of PC, but told the owner that the identification card belonged to his

brother who had recently moved back to Africa. On his first visit, the African male paid

$35,000 for a Mercedes Benz, and on his second visit he paid $92,000 for a Hummer, an

Audi, and a Range Rover. The African male paid for the vehicles with checks from the

JP Morgan account # ending in 5212. The African male paid to have three of the cars

shipped to an address in Hyattsville, Maryland. The owner provided vehicle

identification numbers for three of vehicles, and a photocopy of Ohio Identification Card

(# ending in 8599). ANS Auto Sales' records list the Vehicle Identification Number (VIN)

on the Hummer as 5GTEN13E688124722, the VIN on the Mercedes Benz as

4JGBB86E98A355237, and the VIN on the Range Rover as SALSF25446A929067.

16. I determined that the address in Hyattsville, Maryland to which the cars

were sent is the address of USNAD Import and Export (USNAD). I interviewed the

owner of USNAD on March 15, 2011. He recalls shipping several vehicles, including a

Hummer, a Mercedes Benz, and a Range Rover, on behalf of his customer, ALIMAMY

BARRIE. BARRIE has been a repeat customer who has appeared on numerous

occasions at USNAD to conduct business. The owner was shown the PC photograph

provided by the Ohio Department of Motor Vehicles, and several surveillance photos of

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the person conducting banking business as PC provided by PNC Bank. The owner, with

certainty, identified his customer, ALIMAMY BARRIE, as the person in all of the photos.

The owner also provided documentation from his files indicating the vehicles from ANS

Auto Sales were among vehicles that USNAD has shipped for BARRIE. USNAD's

records document that it shipped a Hummer with VIN 5GTEN13E688124722, a

Mercedes Benz with VIN 4JGBB86E98A355237, and a Range Rover with VIN

SALSF25446A929067, on behalf of BARRIE in November and December 2010.

17. A review of public data bases and law enforcement data bases located a

person named ALIMAMY BARRIE, date of birth June 21,1983. This person was issued

Maryland Driver's License # ending in 3475. I obtained a copy of this License. A review

of the image on this driver's license, in my opinion, shows that it is the same person

depicted on Ohio Identification Card (# ending in 8599) in the name PC, and all of the

surveillance photos from PNC Bank.

18. A query of United States Customs data bases indicates a man named

ALIMAMY BARRIE with date of birth June 21,1983, traveled to the United States from

Brussels, Belgium on United States passport # ending in 6338 on May 22, 2010. On

December 16, 2010, BARRIE flew back to Brussels. I obtained a copy of passport

# ending in 6338 and examined the photograph contained on the passport. In my

opinion, the man depicted on the passport is the same man shown in the Maryland

Driver's License # ending in 3475, Ohio Identification Card (# ending in 8599), and the

bank surveillance photos from PNC Bank.

19. Persons believed to be friends or relatives of ALIMAMY BARRIE residing in

Columbus, Ohio and in Maryland have held or currently hold licenses as nurse aides.

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20. Based on the information contained in the paragraphs above, I believe that

there is probable cause to believe ALIMAMY BARRIE committed identity fraud and that

probable cause exists for his arrest. As such, I respectfully request that a complaint and

an arrest warrant be issued for ALIMAMY BARRIE.

les R. Conner III

serial Agent
Federal Bureau of Investigation

Sworn to and subscribed

in my presence this 3/-*
day of March ,2011.

M.
Ivan D. Davis
United States Magistrate Judge