Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 1 of 81 Unsealed 10/27/16 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION UNITED STATES - V. HGLOBAL, CALL MAN-TRA, Robust 1m, Raythepn International, WORLDWIDE SOLUTION, ZORIION COMMUNICATIONS PVT. LTD., SHARMA BPO SERVICES, HITESH PATEL, a.k.a, Hitesh Hinglaj?, HARDIK PATEL, JANAK GANGARAM SHARMA, [10] SAURIN JAYESHKUMAR RATHOD, {11] TARANGRANCHHODBHAI [12] KARAN JANAKBHAI [14] MANISH RAJPAL SHAH, SAGAR TIIAKAR, a.k.a. Shaggy, Shahagir Thakkar, CYRIL DANIEL, [18] VIJAYBHAI SOLANKI, [19] James News, IV, PATEL, [21] MITESI-IKUMAR PATEL, 3.1m. Mi'tesh, PAT-EL, [24] FAHAD ALI, [235] JAGDISHKUMAR aka. Jagdish, [26] PATEL, a.k.a. Bharat, [27] PATEL, [28] VIJAYKUMAR PATEL, [29] MONTU Monty Barot, [30] PATEL, [31] KABARIA, [32] PATEL, United States Courts Southern District of Texas FILED October 19, 2016 David J. Bradley, Clerk of Court SEALED CRIMINAL 4:116a-cr-385-S 18 U.S.C1.. 3171 Conspiracy- ?(Count 18 U..-.S-.-C. 1349 Wire Fraud Conspiracy (Count 2) 18 195661) Money Laundering'Conspiracy (Count 3) '18 U.S.C. 1952 False Statement .in Application for Pas-Sport (Counts 2461 Forfeiture Allegations TRUE I CERTIFY ?v - DAVID J. Clerk'of Court d'DeputyClei-k Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 2 of 81 [33] NILAM PARIKH, [34] DILIPKUMAR-AMBAL PATEL, a.k.a. Don Patel, [35] VIRAJ PATEL, [36] ABHISHEKRAJDEVTRIVEDI, [37] PATEL, [38] [39] PAH-IAN, [40] JAYKUMAR RAJANIKANT-JOSHI, [.141] ANJANEE .SHETH, KUNAL NAGRANI, [43] SURENRAN a.k.a. Chris Whiods, [44] TAR . I. I aeka. [45] JOSHI, a.k.a. .Sharad Ishwarla'l Joshi, Sunny Mahas-ha'nker Joshi, [46] RAJE-SHBHATT, Manoj Joshi, Mike Joshi, [47] NILE-SH PANDYA, [48] TARUN [49] RAVI GOUNDER, a.k.a. ishal Gounder, [50] BHAVESH PATEL, PATEL. [52] RAJESH KUMAR UN, [53] IRUDDH CHAUHAN, [54] TILAKTVIJAY DZOGRA, [55] VICKY JACOB. CHRI-SSTIAN, a.k.a. Clintwin Jacobehristian, [57] ONY PJADIPURIKAL, a.k.a. Ances'h Anthony, [58] JATANKUNIAR a.k.a. Jat'an 02:2, {59] SHARMA, [60] VINEET a.k.a. Vineet Shanna, Vineet'Vashistha, and [61] GOPAL VENKATESAN PILLAI, - - TSUREJA, Defendants. Case Document 6 Filed in TXSD on 10/19/16 Page 3 of 81 SUPERSEDIN-G INDICTMENT THE GRAND-RY CHARGES: GeneralAllegations ?Telefraud?? Scam, 1. As used'in this Indictment, a ?call center? was an org'aniZation or group of organization-swat defendants used in connection with a scheme to defraud U.VS-. resident-s by misleading into sendingmoney utilizing a number of different con?dence seams, to include": a. IRS scam: India'sbased call centers impersonated U.S.. Internal Revenue Service (IRS) of?cers and de?auded U. residents by misleading them into: believing that'they owed money to the IRS and would be arrested and ?ned if they did not pay their alleged back taxes immediately. b. USCIIS scam: India-based call centers impersonat'ed US. Citizen and Immigration Services (USCIS) of?cers and defrauded US. residents by misleading them into believing that paperwork. c. Pay- day loan scam; India-based call centers defrauded US. residents by- misleading- them into believing thatxthe callers were loan o?icersend that the" US. residents were eligible'fer? a ?ctitious ayday loan? (small, short-term, unsecured loan in which repayment is 1 Telefraud is term describing. fraud activity Via Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 4 of 81 generally linked to a borroWer?s next paycheck or regular income payment, such as a social security check), The India-based caller?s directed the" US. residents to pay an upfront "?worthine'ss- fee.? to demonstrate an ability to repay-the loan. The victims-received nothing in return. d. Government glint scam: India-based call centers defrauded residents by misleadingthem into believing that they" were eligiblefor a ?ctitious government grant.- Callers directed the residents-to payjan-s-up??ont IRS taxnr'pmce'sSing fee. The vict-ims- received nothing in return. Roles 'in'the Operation 2., The defendants. held one orrnore of the following retesin furtherance of the conSpiracy: a. Runner: The defendants referred to below as ?Runners? 'were located-in the United States and. ty?i'cal'ly operated regionally, Runners purchased temporary general purpose reloadabler the unique-.GP-R card numbers to the Payment Processors purChased money orders using GPR cards funded with fraud proceeds; retrieved cash payments of scammed funds via money transmitters such as Western Union and MoneyGram using fake identi?cation documents; and deposited scammed funds into'bank accounts Runners were often'directed by Domestic 'Managers. b. Domestic Manager": The defendants referred to below as ?Domestic Managers? were located in the United States and directed runners? activities and at times provided runners with resources and supplies, such as vehicles and credit cards-fer travel expenses. Domestic Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 5 of 81 Managers were often the-direet-points of contact with the Call Center Operators and Payment Processors in India, including-"to negotiate their crew?s payout of seammed "funds. 0. Call Center Operator: The defendants referred to below as-?Call Center Operators? were. located in" India__and overSaW and managed the day~to~day operations of the call centers, sash keeping time and attendance; maintaining the include "acquiring telephone numbers .from'Whichi scamcalls would be made; maintaining expense sheets for respective call centers; Obtaining and distributing ?lead lists?;2 and creating invoices for Payment Processors regarding how much was owed to the call centers based on the amount of scam funds the call centers accrued. In some cases, the Call Center Operators had equity shares in the call centers. (1. The individuals referred to as ?Callers? received lead list information and call scripts. Callers made fraudulent and 'extortionate calls tovictims in the'U'.S. and elsewhere, purporting to be US. order to extract scammed funds from "victims. e. Payment. Processor-: The defendants referred to below ?Payment Processors? were located in India, were Often af?liated with particular call centers, and were the intermediaries-between the call centers. and the Runners; For-example, they facilitated overseas payments forhawaladars, --actiVated-(0r managed individuals who activated) GPR cards with 2 A, short-form ?lead list? contained personally; identi?able inferm'atiOn-suc'h as name, address, and telephone numbers. A longs-form ?lead list?r--contained personally as name, address, telephone numbers, dates or birth, and social security-numbers, among: other piecesof identifying Case 4:16?cr?00385 Document 5 Filed in TXSD on 10/19/16 Page 6 of 81 unwitting U.S. citizens? personally identi?able information communicated with and instructed Runners to liquid-ateGPR cards,- transferred scammed funds from prepaid Stored value cards to GPR cards, and liaised with call Centers that made the scam calls. "Data Broker: The defendants referred to below as ?Data Brokers? identi?ed and contacted US. and ferei'gn lead generators and marketing companies to purchase names and PII for registering GPR.1.cards and? targeting potential victims. Data Brokers also facilitated payment for PII through domestic Runners. g. The defendant referred a i?Hawalad_ar? was located in India and liaised betweim shawalada'rs in cities outside India and the India-based Call centers to obtain requests for funds which would be ful?lled by the call centers. Hawala'd'ar is iaperson who operates a ?hawala?. A hawala is an underground banking system based on trust through which money-can be made-available internationally without actually moving it or leaving a record of the transaction.- In a hawal'asystem, a. person wanting to send money abroad contacts a broker-(the hawaladar), and gives him rnOne?y, a fee, name, location- of the person to Whom he wants. the money delivered; The hawalaidar contacts another hawaladar .in'the recipient?s country, and the second hawaladardelivers the money'to the recipient. The ?rst hawaladar then owes the transferred amount to the second, and the debt. is frequently repaid by transactions conducted. in the r'eVe'rSC direction. Call Centers 3. In this Indictment, there are ?vemaj or conglomerates of call centers, all located in India: H?rlpbal-a Call Mantra, Worldwide Solution, Zoriion- Case Document 6 Filed in TXSD on 10/19/16 Page 7 of 81 Communications, (Business Process Outsourcing). During the course of the conspiracy-,the call center conglomerates often acted together to effect the Scheme, to include: sharing call scripts and lists of-potential victims, processing payments for each other, and liquidating victim .iscammed. funds. Honors ?unnumnnv Rate toe-Anon HIT-ESH nine LAJ) Call Center Operator India HARDIK PATEL Call Center Operator India JANAK SHARMA Payment Processor India TILAK I Call Center Operator 8t Payment Pro'c?'smr Hindia I SAURIN RATHOD I Data Broker India TARANG PATEL Deta Broker India KUSHAL SHAH Payment Processor India I THAKKAR I Payment Processor I I tndia BHARAJ can Center Operator India RAJ Can Center Operator Runner: I I India SAGIAR THAKAR I Call Center-Operator 8: Payment Processor indie? JHON DANIEL Payment Processor India JATIN Payment Processor India . JERRY NORRIS Runner Oakland, CA NISARG PATEL Runner Warner Robbins, GA Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 8 of 81 ITESHKUMAR PATEL Domestic Manager Wiliowbrook, IL Domestic Manager Willowbrook, IL ANIANEE SHETH Runner Louisiana and Texas ALI Runner Dyer, IN JAGDISH CHAUDHARI Runner Sarasota, FL PATEL Runner Midiot?hian, IL ASIVIITABEN PATEL Runner Willowbrook, IL VIJAYKUMAR PATEL Runner SchiIIer Park, IL MONTU BAR-OI Runner Glendale Heights, IL I 7' UL PATEL Runner Fort Meyers, FL ASHWIN I Bradenton, FL I .DILIPKUMAR RAMANLAL PATEL RUnner Ocala, Florida NILAM Runner PeIh'am, AL I I Runner Corona, CA PATEL Payment Processor Anaheim, CA ABHISHEK TRIVEDI Payment Processor - India SAMARTH PATEL - Payment. Processor- India PATEL Runner New Ierse'y AALAMKHAN PATHAN Call Center Operatnr India Center Operator India ..CaiiI-C-enter Operator India I Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 9 of 81 PRIMARYROLE Lemma: I KUNAL CaH?Center Operator India SUB-15H EZHAVA Call Center Operator India SUNNY SURE-JA- CalltenterOperatcr India Domestic Manager I. Sugar Land, TX RAJESH-I MANOJ Domestic Manager Sugar Land, TX NILESH PANDYA Runner ?Stafford, TX ?ne. I ROLE LOCATION TARUN SADHU Call center Operator India I Payment Processor Endia SHAVE-SH PATEL Domestic Manage-r Phoenix, AZ RAMAN PATEL Runner Phoenix, AZ RAJESH KUMAR UN Runner Phoenix-AZ TARGET PRLMARV- ROLE LOCATION A-NIRUDDH CHAUHAN Can Center Operator india RAHUL DOG-RA Cali Center-Operator 8: Payment Processor Indi? Case Document 6 Filed in TXSD on 10/19/16 Page 10 of 81 VICKY VICKY Call ?Center?Operato-r India CLINTWIN JACOB Call Center Operator India ANTHONY Cali Cen'ter'O'p'erator India JATAN OZA Payment Processor India RAJKAMAL SHARMA Hawaiadar India ?mw VINEET-ZVASISHTHA Call Center opener I India Call Center Operator India De?nitions 4. Atall times relevant to this. IndiCtment: a. ?Prepaid. stored value cards? were cards that had monetary value placed :onto them by purchasers and could be used to fund G-PR cards. They were also called ?MoneyPaks?, ?Reloadit?, etc., depending on b. cards? nor-general purpose reloadable cards were cards that hadmoneta'ry value and could be used like .a debit without being associated with. a personal bank account. GPR cards were. funded and can be reloaded using prepaid stored value card's. c. Green Dot Corporation (?Green Dot?) was an entity that, among other things, sold GPR cards. (?Green Dot cards?). Green Dot card's, once funded, ceuld be used to make purchases. 10 Case Document 6 Filed in TXSD on 10/19/16 Page 11 of 81 i. 'In order to :aGre?cin. Dot card, ind'i-V'idu'als using the cards were ?rst required-to" register the card telephoni?ca?lly or online by providing, among other things, a name, address; 'teIEphonernumber, date of birth, and social security number. ii. There werejseveral ways to a Green Dot'1eard.. One purchase of a MoneyPa'k' card from retail "stores such as CVS and 'Walagre'ens in amounts from $20- to Once purchased, the! customer-could, using a code(PIN or personal identi?cation number) on the back ofthe Money?Pak card, authorize a transfer? of funds from the MoneyPak card to card, For instance, a customer that purchased a $5 00. MoneyP-ak. ?ould provide the PIN code associated with their MoneyPak to an individual had aGreeii card. The Green Dot card holder-oeuld then: effect the transfer through Green Dot?s website or by calling Green Dot?sstol'l free number and providing 'bbth the Green Dot card number-and the MoneyPak PIN code. d. Blackhawk Network Holdings an entity-that, among other things, sold ?Reloadi?? prepaid stored value cards which Operated similarly to Green'Dot MeneyPaks. e. Personally identi?able information. or sensitive personal information is information that-can be used on. its own or with other information to'identify, contact, orilocate'a person. f. The terms-?accessing? and ?accessed? "refer to: .1) electronically or telephonically regiStering GPR- cards with misappropriated el'ectroniCa-Ily or telephonically transferring victim scammed. funds from Stored value cards to or 3) electronically or telephonically 11 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 12 0f 81 checking balanCes of cards. g. A ?money services- business? transferred funds ;on behalf of the public to other locations within the US. or to locations abroad. by means-of wire transfers, Such as Western Union or MoneYGram. These businesses .also sell money-orders. h. Voice?over: Internet? Protocol (VoIP-)was- a telephone connection over the internet; the data was sent digitally" using the internet protocol instead of analog telephone lines. i. ?Spoo?ng? was amec'han'i'sm Whereb'y callers- could deliberately falsify the information transmitted "to a- victimi?s-rcaller ID and;.;thereby disguise their identity or location. j. YMax Corporation or ?Magic Jack? phone numbers utilized physical devices which employed to allow users to make unlimited. local or long distance phone calls to US. and Canadian telephone. numbers "using.- an: existing internet connection; users could make and receive calls usinga computer orp'phone. No additional telephone-service was required. A Magic Jack application-(or computer program) couldsubstitute as the physical device. Users were permitted to choose thephene number associated with the Magic Jack. k. A lead generator was an individual or company which used proprietary methods to prodnCe leads usually .inmass quantities to sell to other businesses. Pertinent Phone. Numbers 5. During the course of the investigation, the conspirators used approximately 1,500 Magic JaCk numbers to defraud victims and to facilitate the transfer of victim funds. The Magic Jack numbers'bel-ow were some of?the most active numbers used to. perpetrate the scheme. 6. Targets of "the investigation were involved in the bulk purchasing of Magic Jack 12 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 13 of 81 devices. OniN'ovember- 18,2011, KABARIA using emailed HITESH PATEL and The email and attached shipping label indicated that ASHWIN KABARIA shipped via UPS 20 Magic Jack. devices to an HGLOBAL conspiratorsin India. Orr-March 7, 2012, ASHWIN KABARI-A using? emailed PATEL at hiteshhin la' maileom indicating that 41 Magic Jack devices had been shipped via UPS to JOSHI in India. On September 25, 2012, ASHWIN using acs.wun@gmail.com emailed HITESH PATEL and ANAK SHARMA who operated email address gr_n 'ail.-com. The email indicated that .ASHWIN shipped 40 Magic Jack devices using UPS to a conspiratori in Hoffman E'Sta?tes?, IL. 7. (7153) 370?3224 Magic Jack: (713) 370-3224 was a YMax Communications telephone number 3 Magic-Jack?) registered in?the name-9f an individual at anaddress 'in Waco, TX, by individualism Ahmedabad, Gujarat, India. This; phone number accessed more than-45000 Green Dot GPR cards that' were registered in -'rr'ior'e than..1,200 different misappropriated identities in the: year 2013.- (713) 370-33224 was-controlledby HITESH PATEL included the entail address JHS.Hinglai24@vahoo.coni. In a Google chat on March '12, 2013 (Saved as-..an.email in the acs-g? 'lobal3@gmail.com account) between HITESH PATEL and ASHWIN KABARIA, HITESH- provided the 713 Magic Jack phone number during a conversation about transferring money. The subscriber .infonnation for-acsglobaB @nmaileom - mail-com and Indian phone" listsithe' recovery email account as-ihiteshhin lair number 98 79090909, which. HITESH listed on his US. visa. application. 13 Case Document 6 Filed in TXSD on 10/19/16 Page 14 of 81 .8. (630) 974-1367 Magic Jack: (630) 974-1367 was a Communications telephone number (?630 Magic Jack?) registered to. a person. at. an. address in Aurora,'Il'linois by individuals in Ahmedabad, Gujarat, India. This phone number accessed more than 990 Green Dot. cards that were registered more than .776. different misappropriated identities. -. from December?Z-S, 20123 throughDeoember 23', 2014. The 630 Magic Jack was controlled by HITESH PATEL, JANAK SHARMA, and other __HGLOBALassociates. The 630 Magic "Jack. replaced the 713 Magic Jack and accessed the same. IP address. The. 630 Magic Jack was- registered on January 13', 2014 using .IP address 216.169.138.203. 0n. the ewe day, the 713 Magic Jack placeda phone call to a Green Dot customer service telephone number from IP address 216.169.138.203. The subscriber information associated with 63 0. Magic Jack listed the password for account as Between March 18, 2013 and November-7, 2013., email account iobalOl mailcem sent at. least-five emails containing GP-R cards that utilized the-password or 9. 78.51.340-9064 Magic Jack: (785) 340?9064 was a YMax. Communications Magic Jack") reglstered to apersonat ans-address in Columbus,- KS by individuals in. Ahmedabad, Gujarat, India. This phone number accessed at least 4,163 Green Dot GPR cards that were registered in at least 1,903 different misappropriated identities from September 23, 2013 through October 18, 2014. The 785 Magic Jack Was controlled by JATAN OZA. On or about October 15, 2013, JATAN OZA using -iatan-_ gnocketmailcom draftedan email in which. the body contained the email address that was-used to registerthe "785 Magic Jack. T116785 Magic Jack subscriber records show that its Magic Jack application was 14- Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 15 of 81 installed on an iPhene titled ?jatan__oza?sfiphone?. On October 31, 2013, email account iatan was utilized to send an email originating from IP address 122.179.140.176. This same IP address. was the eri'gin-ating IP address for all calls using the 785 Magic Jack on the same day. Scope of Conspiracy 10. The defendants have perpetrated an enormous and Complex fraud scheme that has resulted in hundreds cfmiliion?s of?dolla'rs of Victim. loss-es .derived..-from persons located throughout the-United States. The design of the scheme and the rapid movement of victim funds o?en resulted in Victims being unable ,to'repor't- the fraud in time-fer their. funds to'b'e. recovered. Over 15,000 known victims with leisses attributable to scam calls have been identi?ed thus far, and upwards $50,000 individuals have had their identities misappropriated based. On the unauthorized use of their register" GPR cards used to move telefraud victim ?mds._ COUNT ONE 18' U.S.-C. 371 (Conspiracy) 11.. Beginning in or about January 2012, the exact date being unknown to the Grand. Jury, and in or about the date of the Indictment, in "the Southern District of Texas and elsewhere, the defendants: HGLOBAL, CALL MANTRA, WORLDWIDE COMMUNICATIONS PVT. LTD., [51' BPO HITESH MADHUBHAI PATEL, JANAK TILAK JOSHI, [10] SAURIN JAYESHKUMAR RATHOD, TARANG RANCHHODBHAI 15 Case 4:16?cr?00385 Document 6 Filed in TXSD on 10/19/16 Page 16 of 81 PATEL, [12] SHAH, KARAN JANAKBHAI THAKKAR, MANISH BALKRISHNA BHARAJ, [15] RAJPAL VASTUPAL SHAH, SAGAR CYRIL. JHON DANIEL, [18] JATIN SOLANKI, [19] NORRIS, [20] NISARG- PATEL, MITESHKUMAR PATEL, [22] RAJUBHAIBHOLABHAI PATEL, ASHVINBHAICHAUDHARI, [24] FAHAD ALI, [25] JAGDISHKUMAR CHAUDHARI, [26] BHARATKUMAR PATEL, [27] ASMITABEN PATEL, VIJAYKUMAR PATEL, [29] MONTH BAROT, [30] PRAFUL PATEL, RAMANLAL PATEL, [33] NILAMPARIKH, [34] PATEL, [35] VIRAJ PATEL, [36] ABHISHEK TRIVEDI, .SAMARTH KAMLESHBHAI PATEL, [38] HAR-SH PATEL, [40] JAYKUMAR RAJANIKANT ANJANEE PRADEEPKUMARSHETH, [42] KUNAL CHATRABHUJ NAGRANI, [43] SURENRAN EZHAVA, [44] SUNNY TARUNKUMAR SUREJA, [45] SUNNY JOSHI, BHATT, [47] NILESH TARUNDEEPAKBHAI VISHALKUMAR RAVI GOUNDER, [so] BHAVESHPATEL, RAMAN PATEL, [52] RAJESH KUMAR UN, [53] ANIRUDDH RAJESHKUMAR-CHAUHAN, [54] RAHUL TILAK DOGRA, VICKY RAJKAMAL CLINTWIN JACOB CHRISSTIAN, [57] ANTONY PADIPURIKAL, JATANKUMAR [59] RAJKAMAL OMPRAKASH SHARMA, [60] VINEET VASISHTHA, and GOPAL VENKATESAN knowingly and intentionally conspire and I6 Case Document 6 Filed in 10/19/16 Page 17 of 81 agree with each other and others known and unknOwn, to commit-offenses against" the United States, namely: to'knowingly and with intent to defraud, devise, (and intend. to devise, a scheme and arti?ce to defraud, and to obtain money and-property by means offalse and fraudulent pretenses, repreSentations, and premises, and, forthepurpose of executing arti?ce, would and did transmit and cause to be transmitted bymeans of wire, radio, and television communication in interstate and foreign commerce, any writings, signs, signals, pictures, and sounds for the purpose of executing such scheme or arti?ce, to Windefendants?eand others known and unknown-missed telephone. calls from a place outside of the United States to victims/in the United States to represent themselves to be of?cers of a US. federal agency and thereby extort the-payment of?mds through the use of interstate electronic payments, in violation of Title 18, United States Code, Section 1343; . to falsely assume- and'pretend to be an of?cer and employee acting under the authority of the United States and a department, agency, and of?cer thereof and WOuld and did act as such, and in "such pretended character, demand and obtain money, paper, ducument's', and-things of'V-al'ue, in violation of Title 18, United States Code, Section912; . to transfer, possess, or use, without lanul authority, a means of identi?cation of another-person with the intent to commit, and to. aid or abet, and?inrconnection with, any unlaw?il activity-that constitutesi'a. violationof Federal law, and that constitutes a felony under any applicable State and: local law, including the wire'ifraud subsection and money launderingralleged? in subsection in violation of Title 18,, United States-Code, Section . to knoviringly, andiwith interit't?o defraud, traf?c in and use one or more unauthorized access devices, that during. any one~year period, andiby such conduct. obtain anything. of value aggregating $1,000. or more during that. period, said conductaffecting inter-staterand foreign commerce, in violation of Title 18, United States Code, Section 1029(a)(2); and . to knowingly conductor attempt to conduct ?nancial transactions commerce and foreign commerce, which tranSactions- 17 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 18 of 81 involved the proceeds of speci?ed'unlawful activity, that is, the wire fraud ._alleged in subsection knoWi-ng thatjthe transactions were designed in whole or in to conceal and disg'uiSe" the nature, location, source, ownership, and centrol ofthe proceeds-(of speci?ed unlawful activity,- and that while attempting-to conduct such ?nancial transaetions,"knew that the property involved in the ?nancial transactions represented the proceeds of some form of'unlaw?il activity, in violation'of Title United States Code, SectiOn Pu_rpo.se of the Conspiracy 12-. It was .a purpose of the conspiracy that the defendants and-their conspirators unjustly enriched themselves and others by fraudulently inducing victims to pay the defendants? and their conspirat?Ors? alleged ?nes and fees and by concealingand disguising the proceedsof the conspirators? unlawful activities, Manner and Means ofthe Cons-piracy 13,. It was partjof the conspiracy that the defendants and their conspirators engaged in a scheme involving extorting money ?crn victims; oftentimes by purporting to be US. government of?cials, rapidlymeving victim scammed funds through different monetary devices, and using those preceeds to.- ?hawala transfers from Indiaiandether fereign countries tothe US. 14. It was further part of the conspiracy that the defendants and their conspirators operated call centersl'ocated primarily in and around Ahmedabad, Gujarat, India, obtained. and distributedscripts and lead lists from data brokers which contained for the purpose of contacting defrauding potential. victims. 1-5- It was ?ll-'thel? Par-t 01f the conspiracy that the defendants and their conspirators, at 18 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 19 of 81 times using ?spoofed? numbers to make their calls appear to originate from a federal agency, telephoned purporting to be US. government of?cials or lenders and threatened victims-with prosecution or arrestfor purported- immi-gr-ation or tax violations unless the victims paid alleged ?nes or fees immediately. '16. It was further of the conspiracy that the defendants and their conspirators instructed victims to :go to banks or ATMs to Withdraw money, use this money to purchase prepaid stored value" cards from retail stores, and then provide the unique serial? number of the prepaid stared. value cards. 17. It'was. ?n?ther part of the conspiracy that U..S..-based defendants-and their cronsp-irators obtained GPR cards, each assigned a uniquenumber, and transmitted these numbers to India-based defendants. and their'conspirators who: activated the. GPR cards? by registering them using misappropriated-P11 of U.S-.-2based. persons. It further part of the conspiracy that the defendants and their conspirators transferred victim funds from the stored value Cards to the GPR cards in the possession of US.- .l conspiratur-S? 19, 'It was further part of the conspiracy that the U.S.-based defendants and their conspirators-usedthe GPR cards loaded with victim scammed funds to purchase money orders and then deposited the money orders into US. bank- acCount-s of individuals or businesses. 20. It; was ?lrther part of the conspiracy that India-based defendantsand their conspirators accepted payments and orders from foreign-based hawaladars and defrauded victim "funds so. as to ?ll?ll hawala transfers to U.S.-based recipients. 1'9 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 20 of 81 21. It was further part of?the'COnspiracy that the India-based defendants and their conSpiratcrs directed victims to wire scammed'?mds to meney-Pservices businesses, such as Western union, to the attention of ?ctitiOus names and defendants and their conspirators retrieved the moneyesing false identi?cation in the ?ctitious names and subsequently deposited the victim scammed fundsinto US. bank acco?untsof individuals and businesses Overt Acts 2012 and 2013 W- On 'or' about October 29 and 30, 20-13, Callers "-te-lephonically .cxtorted victim-Mama S.., arresiident of Ban Francisco, CA, by fraudulently purporting-to be state and federal agents, demanding-payment for alleged immigration and tax violations. 23. On or about-October 29'and directed victim Mamta S. to 86 prepaid MoneyPak cards with the stored-value. and transmit the PINS-associatedwith those MoneyPaks to the. Callers. 24. Between October 28,2013 and October 30, 2013, MITESHKUMAR PATEL electronically transmitted 20 of the 27 GPR card numbers to a conspirator to be registered, HGLOBAL conspirators registered all 27 GPR cards with misappropriated P11. 225. On or about October 29 and 3:0, '20'13,- conspirators transferred victim Mamta S.?s extorted $43,000 from 8.6 MoneyPak'rcards to '27 GPR. cards. The 713 Magic Jack accessed 24 of the 27 GPR cards and transferred the funds. from 1-9 of victim Mamta S.?s 20 Case Document 6 Filed in TXSD on 10/19/16 Page 21 of 81 MoneyPaks to 17 of the GPR cards. JANAK his Indian cell phone number transferred. the funds from one of Victim Mamta S.?s MoneyPaks to one ofthe GPR cards. On October-2:9 and 30, conspirator sent emails to. SHARMA at .h ?lebail i: maileom containing MoneyPak PINS purchased by victimMamta S-., to which ANAK .reSponded'?Approved?. ?Approved? is believed to be an indication that the "stored value cardfunds had been successfunytransferred to reloadable GPR cards. 27. An HGLOBAL conspirator registered at least seven-(7) of the 27 GPR cards containing money using the. misappropriated PII of Amanda B. On or about October 29, 2013 and continuing through October 30, 2013, MITESH electrOnically communicated all "seven. (7) of those GPR card numbers to conspirators. 2'8. On er'about Octdber .239, 2013, MITESH and ASMITABEN PATEL purchased money orders in a grocery store in Illinois usingtwo' of'the GPR cards containing victim antans money. Both of. these were-registered With-.--Amanda B,?s misappropriated. 29. Between on or about October 29am! 31, 20.13, MITESH sent'i?str?ctions via messaging to ASM-ITABEN PATEL and RAJUBHAI PATEL to dep-oSit Mamta money into at least ten separate bankaccoun'ts. 310. On or aboutOctober'BO, 2013, a conspire.th electronically messaged MITESH instructing himt'o- deposit intoja speci?c Bank oflAman'Ca (BOA) account. On that. same day, BHARATKUMAR PATEL deposited $5,000, a portion of which was victim Mamta money, into?the BOA account. 21 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 22 of 81 31. On or about October '3 2013,: BHARAT received by deposit $5,000 in money orders primarily funded by victim Mainta?s scammed funds. .32. On or- about October 29' and 30, 2013, DILIPKUMAR PATEL (FL) sent a series of emails SHARMA at hglObalOl@gmail..com containing'lists of GPRcards to be activated and leaded. Shortly afterward, JANAK emailed DILIPKUMAR (FL) directing him to convert $1,700 011-0116 GPR card into money orders. This GPR card was funded primarily with Mamta scammedfunds. This card was also funded by MeneyPaks purchased by unknown victims Sini'N'erth Carolina and Texas. 33?. On or about October. 30:, 201.3,. DIL-IPKUMAR (FL) responded to JANAK, in. sum and substance: ?Done?. Shashikant P. 34. On or abdut December 9, 2013, ZORIION COMMUNICATIONS Callers, "telephonically extorted victim Sihashikant P., residing in. Niles, IL, of $3,683- by fraudulently purporting to. be IRS employees, demanding payment-hr alleged ?nes and. fees for allegedftax violations and threatening anesmnd deportation.- 35. On or about Dec-ember 5, 2013, prior to Shashikant P.?s fraud Icall, ANIRUDDH CHAUHAN received an email containing the account number and" password. for the toll-free telephone number (866) 9783-75 77' that was-"used to. contact. victim .S'hashikantP. 361. Onor about December 2013,..a ZORIION conspiratdr emailed a. lead list to AN EESH ANTONY PADIPURIKAL at aecount titled indicating that the contacts were intended to be used for the IRS scam. The 22 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 23 of 81 lead list contained Shashikant Pris PH. 37.. On Ctr-about a ZORIION Caller "representing-rhimself to be ?Peter? usedtdlI?free 'nur'niber (86.6) 9789.757 7 to extort Shash?ikant P. ?Peter? is a known alias of ANTONY PADIPURIKAL. 38. On or :abom December 9, 2013, ANEESH directed Shashikant P. to purchase. eight- (8.) prepaid MoneyPak cards with the staredvalue of $3,683? and transmit the PINS associated with-thosefMoneyPaks to the Callers. 39. On or about December 9, 2013, AN EESH sent Google chatmessag?es to RAHUL DOGRA containing at least four (4) of the Mone'yPak numbers purchased by Shashikant P. for processing Shash?ikiant- R?s payments, transferring the MoneyPak?. funds to" cards. 40. On or about Decembe'r;;93, 2013, conspirators transferred the MoneyPak victim funds to four (4) GPR cards. 41. On or about December 19,. 2201 OZA, using the 785' Magic Jack number, accessed three "of the GPR cards'that were ?lnded by victim two onto the same GPR cards. 42. On or about December 9, 52013,. MITESHKUMAR PATEL Created a draft email containing the last feur digits-of one (1) of the GPR cards funded by Shashikant'P. and-the amount on the card 43. On or about December 9, 2013, conspirators liquidated all four (4) GPR Cards at- retail' locations in Las Vegas, NV. 23- Case Document 6 FiIed in TXSD on 10/19/16 Page 24 of 81 44. On or about December 13., 2013, HON DANIEL sent an email to a. conspirator. with. an attached spreadsheet?containing a list :ef? cards and the identities used to activate-them including the four (4) GPR cards funded by victim Shashikant .45. On or about May 1 1, 2012, HGLOBAL Callers telephonieally defrauded victim Celia V., a CA, of $192 by representing that she would receive a loan of an unspecified amount 192 via. Western Union wire transfer. 46. A On or about. .May 11, 12012, Callers directed victim Celia V. to send $192 via Western Union wire transfer to an individual with the initials AM. 47, Ono?r about May 11, 2012, HARDIK PATEL using by JAK and HITESH. The email message Ieontain?eid victim Celia V.?s name, a Western Union Money'Transfer Control Number (MTCN), and the-amount of $1592. 48. On or about May 1 I, 2012, ?an eonsp'irator using acs- tubal-3 'aiiwscomwforward?ed? srwemail? to an" address acawnm mailcom who operated a Western Union terminal in Pittsburg, PA. 49. 011 0r about May 11,2012, the conspirator at I mailconii. indicating that the money was received; and responded, ?Approved? to ace? loba?l3 vrmailimm subsequently noti?ed HARDIK of the same by- emailing, ?Approved?, Sever-all months later, HGLOBAL Callers contacted victim Celia that she had defaulted? on the loan. despite the fact that victim Celia V. had never received any 24 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 25 of 81 money. Victim Celia V. did not. sendadditional funds. _Wade 51. On oraboutAugust 3, 2012, HGLOBAL Callers telephonically defrauded victim Wade a resident of. Houston, TX, (of $195 by representing that he' WOuld receive a $1,000 loan if he made an upfront payment of $195 via Western Unionwi're transfer. 52. On or about. August 3, 20.12, Callers directed victim Wade C. to send $195 via Western Union to an individual with the initials D-.R. Victim Wade C. reported that the loan Was never received and he lost his $195 upfront payment; 53.- On or about August 3.927012, HARDIK PATEL using hardik..323@gmail.com emailed mn10b313@gn1ail.com operated -.JANAK.. The email contained victim Wade C.?s name, an the amoant of $195, the receiVer name With'the initial-s and an attached image :ofa driver?s license in the. name of DR. 54. On or about AuguSt 3., 2012, acsglobal3 @gmai-l.cem forwarded the'email to a ail.com who'iis believed to have operated a conspirator'using email addresnwe'st' ram..tradin . . Western Union terminal in Delaware. 55. On. or about August: 23, 20.12, the conspirat'or at mailcom maileom, indicating that the money had been received.5 and responded ?Done? to ace lobalB noti?edl-SIARDIK of the same byiema'iling, ?Approved?. 56. On or about November 30, 2012, SAGAR sent an email to HARDIK instructing him to ?process as max as you Gang-?IF DC [debt collection], then tell them cops are on way to arrestryou. and ?Lets make-huge money and huge cash!? 25 Case Document 6 Filed in TXSD on 10/19/16 Page 26 of 81 57. On or? about December .171, 201:2, BPO Callers 'te-lephonically defrauded victim Ruth M., a resident of Indianapolis, IN. SHARMA Callers offered victim RuthM, a ?ctitious loan and demanded an upfront processing fee. 58. On or about December 11., 3201.2,- Callers directed victim Ruth M. to make a payment of $250 via Western Union money transfer. BPO Callers contacted victim Ruth M. on several subsequent occasions after the initial call, threatening her witharrest if additional payments-were not made. Victim Ruth M. did not receive a loan. 59], On or-ahout December 10, 2012, prior to victim Ruth scam call; HGLOBAL conspirator TILAK using tilak'._ unldinccom emailed .a lead list to ABHISHEK mail.com containing victim Ruth 60-. On or about December 10, TRIVEDI emailed parts ofthe lead list-inel't'Iding Ruth M. PII to conspiratcr GOPAL PILLAI. 61. .On' or ab'out'December .1 1, 2.012, GOPAL PILLAI using :money.gak20] 2@ mailemn sent an email to ABHISHEK TRIVEDI at pawnent.8226@gg1ail.60m containing- name, the Western Union MTCN, the amount $250, a note "indicating the recipient of the transfer was an. individual with the initials and an image ofa-Califomia Driver?s License for MP. 62. On or abOut December 11, 2012, ABISHEK TRIVEDI forwarded the email to email address Operated by JANAK SHARMA and HITESH PATEL who forwarded the message to ASHWIN at; ac-s.-wun' 26 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 27 0f 81 63 . 0n December 1 1., .2012, ASHWIN who operated a Western Union terminal, responded ?got it? to "the message, indicating 'that.hehad Obtained the ?nds. 64-. On or about? December 11, 2012, JANAK using acs "mai .com emailed TRIVEDI that" the payment. was approved and subsequently using emailed GOPAL mone. mailieom, indicating that the payment had been picked up. Patricia 65. On or about November '19, 201-3, ZORIION Callers-telephoni'cally? extorted victim Patricia T., residing irerous'ton, "by ?'audulently purporting to be IRS employees, threatening a?rres't and demanding payment for alleged tax violations. 66. On or about November 18 and .19, 2013, CYRIL HON DANIEL at cvrilhm2426@gmail.com received emails from a conspirator requesting that two ofthes-GIPRS cards ?mde?d bylPatricia T. be activated and CYRIL responded with the GPR numbers and the PH he used to register the cards. 67. On or about November 1-9, 2013,- KAMAL SHARMA sentan email to a con-spirator at requesting that at. least oneof the GPR cards funded by victim Patricia T. be activated. .68. On or about: November 119, Callers directed victim Patricia to purchase six (6.) prepaid .MoneyPak cards? with the stored value of $3,400" and transmit the PINS. assotiated with those MoneyP'aks to the Cellar. On the same day, conspiratOrs- transferred the MoneyPak cards funded by victim Patricia T. to three GPR cards. 2-7 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 28 of 81 69,. orrabout November I-?9-and 20, 2013, conspirators liquidated the GPR cards containing-victim Patricia TFS: scammed funds in Virginia and Maryland. 70. On or about Nevember 25, 2013, a conspirato-r- sent an email from dpate1-.73 12@grnail.com to with an attached spreadsheet containing 93 activated GPR cards including one: funded by- Patricia T. 71. From on? or about 7F eb'ru'ary- .2012 through at least O'Ctober 2014,, RAJKAMAL SHARMA sent over 1,000 emails to conspirators directing deposits of funds into various bank accounts. Belg 72. On or about August 9, 2013, Callers telephoniCally extorted Raj D., residingjin. Chicago, Illinois, by fraudulently purporting to be USCIS and Illinois State Police employees, threatening arrest and-deportation. and demanding payment for- alleged immigration ViOlations 73. "On or about August 9, 20.113, HGLOBAL Callers directed victim Raj D. to with the MoneyPaks to the Caller. 74.. On or about August 20137, HGLOBALsconfspiIatOrs ?transferred Vic-"timRaj' D.?s scammed funds to three GPR cards which were purchased in Norwalk, CA, Perry, GA, and Fort Valley, GA. andreg'iste'red with the. misappropriated PII of Timothy (3., Christopher T.- and Kristie- I. 75. On. or about August 9, 20.13, VIRAJ PATEL sent an email to RATHOD 28 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 29 of 81 leads? titled ?Viraj_50-__leads? Which. included detail-ed P'II'belon-ging to potential US. citizen victims, including Kristie IQ, Christopher T. and Timothy G. 76.. On or'abou?t August 9, 2013,. the three (3) GPR cards loaded with victim Raj scammed funds were all accessed by the 713 Magic Jack controlled by HITESH and 77. On or" 'abOut August 9, 2013, HGLOBA-LconsPirators vacated the three GPR cards loaded with victim. Raj S'cmed funds for MoneyGram and Western Union money orders purchased in Warner Robbins, GA and Anaheim, CA. P. andKomal 78. On orabout September ll, 2.013, Callers separately telephonically extorted victims Druv P. and Komal. C-., residing in San Diego, CA, of a. total of approximately $30,000 by fraudulently-purporting to be USCIS and California, State Police employees, threateningarrest and deportation and demanding payments for allegedfimmigjration Violations. 79. On or about September 11, 2013, Callers directed victims Dgruv P. and Kom'al Cite purchase 457 Green Dot MoneyPaks and transmit the PINS to the Callers. .conspirators'transferred victim Komal C. and Druv P."s Money Packs to different GPR. cards registered on the same dates using misappropriated PII 10f individuals. 81. On or abetit September 11, 2013 and September 12', 2013, JANAK SHARMA using email. account received emails from a conspirath at- ail.com containing all aofrt'he. 47 MoneyPak purchased by victims Druv a m'ent.sk99 P. and Komal C. JANAK SHARMA responded, ?Approved? to each of the ten (1 0) emails, 29 Case Document 6 Filed in TXSD on 10/19/16 Page 30 of 81 indicating-that the scammed funds had been transferred to GPR- cards. 82. On or'about August 19, 2013-, SAURIN RATHOD using saurin2407@amaiLoom sent an email containing 1a..lead listwith the Pilot" 211 individuals to HARDIK PATEL at i" On the same date, HARDIK PATEL sent. the-same lead-Hm to JANAK. at tho'balO] @gmailtcom. Eight (8) of the GPR cards that received funds. from victims. Druv P. and Kotnal Were registered'using the misappropriated PII of eight (8) of the individuals on the data list. I 8.3.. Onor ?1 1, 2013, HITESH India?based cellular phone numbers. accessed one of the GPR cards funded by victims-..Druv P. and Komal C. and loaded funds from an unrelated victim in Twin Falls, 84. On oraboutiScptember11', 20-13 and September 12, 201.3,. the 713' Magic, Jack accessed 14: of?the .15 GPR cards ?mded by victims Druv? and Kom'al 85. On orabout September 11, 2013, MITE-SHKUMAR PATEL using email account 'mitesh37@gmail.com drafted 'an email which Containeda list of 2-0. cards, expiration dates, and CCV numbers. Six. (6) of the GPR cards were loaded with Druv P. and ,Korn-al C.?s scammed 86, From on or about September 10, 2013 through September 11, 2013, DILIPKUMAR RAM-ANLAL PATEL (FL) emailed JANAK SHARMA at The emails contained "seven (7) of the GPR card numbers funded by victims Druv P. and Komal From on or about September 11,2013 through September 12,- 2013, JANAK emailed? DILIPKUMAR (F L) directing him to purchase money orders the 30 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 31 of 81 GPR cards. DILIPKUMAR PATEL responded ?done?. 87. 5012- or about. October" 24, 2013, CALL MANTRA Callers telephonically extorted victim Gary residing in Ukiah, CA of $9,930 by fraudulently purporting to employees, threatening legal action and demanding payment for alleged tax violations. 88,. On or about October 24, 2013, CALL. MANTRA Callers directed victim Gary B. to purchase 13 Green Dot MoneyPaks and transmit-the PINS to the." Callers. :89. On or about Octdber24, 2013,. CALL conspirators transferred victim Gary B.?s MoneyPaks to ?ve (5) different GPR cards registered using appropri-ate-d?PII of four- (4) individuals. '90, Door about October 24, 201.3, the GPR cards loaded with Gary BBS-scammed funds were used; to make purchases in Southgate, MI, Houston, TX, and "Stafford, TX. CALL TRA conspirators used a GPR card to purchase $2,000 inmoney orders that were subsequently deposited, on October 30, 2013, into a BOA account for HSHM LLC. 91. On or about November 1,2013, SUBISHEZHAV-A using emailed. at sunnvl43sq@vahoo.com, The email showed in GPR card purchases by SUNNY JOSHI during :tihemomh of October 2013. Included on the list were three (3) GPR cards funded by victim Gary B. 92-.- On or about Nevember _1 .2013, SUBISH EZHAVA using _.chrislast902 an email to RAJESH MANOJ JOSHI) at The email showed $293,874.90 in GPR card purchases .311 Case Document 6 Filed in TXSD on 10/19/16 Page 32 of 81 BHATT during? themmth of OCtober2013. Included on the list was a GPR card funded by victim Gary B. 93, On or: about November 14, 2013, CALL MANTRA conspirators wire transferred $22,500 from the BOA account to INTERNATIONAL located in Ahmedabad, India. 94. On or about. anuary' 22,. 2014, KUNAL using kun'alna rani.8i4 ail?..cnm received an email from. anindivid?uali-at 333.112 The. -.email identi?ed telephonenumber-as; the Contact number for RAYTHEON INTERNATIONAL. 95. On or about May 12-, 2014., KUNAL NAGRANI, using kunal-na rani84l ail-corn receiVe'd- an email from anindividua'l at. 3112@yahoo.com containing the wire transfer records of the. $22,500 from HSHM INTERNATIONAL. I Anup U. 9-6-.- On or?about July 18, 201.3, an HGLOBAL Caller telephonically'extoned victim Anup TX resident, of $2,785 by fraudulently purporting to be an immigration agent, demanding payment for alleged immi-gratiOn violations and threatening that Anup U. would berdcported "within 24 hours. The HGLOBAL Caller appeared to be calling from 1?800- 375-5283, the? national call center for USCIS. .971.- On or about July 18, 2013, the HGLOBAL Call-er directed victim Anup? U. to purchase six (6) MoneyPaks totaling $2,785 and to transmit the PIN 3- associated with those 32 Case Document 6 Filed in TXSD on 10/19/16 Page 33 of 81 MoneyP'aks-to the Caller. 98. On?. or about-July 18', 20133, JANAK SHARMA using hglobalOl@gmail.com received "email messages, from-a conspirator with the MoneyPak PINSI'purchased 'by victim Anup U. 99. On 0r about July 16,2013, JANAK SHARMA- sent an email from hglobalOl @gmailcomto hispersonal email with an attachment: depicting anA-merican flag and a graphic superimposed money, dollar Sign, and the text, CALM AND 100. On or about July 18, 2.013, HGLOBAL conspirators transferred the funds from the Mon-eyPaks to three (3) different-GPR cards that were used to purchase money orders in Illinois, Georgia and Florida by ZHGLOBAL conspirators. 101. Additionally, on July HGLOBAL conspirator using the. 713 Magic Jack number accessed all three (3 GPR cards receiving Anup U. ?73 funds.- A conspirator using that same Magic ack number transferred two (2) of victim Anup U.?s MoneyPak scammed era was. 102. On or about July 128, 2011.3, MONTU SHARMA an email from fourteen (14) GPR card numbers, two (2) of. which were funded by victim Anup E?s-scammed ?mds, 103. On or about July 18, 2013,, JANAK MONTU BAROT two emails directing MONTU to liquidate two (2) of the GPR card-s funded by victim Anup U. and MONTU BAROT responded, ?Done.? to each of the emails. 33 Case Document 6 Filed in TXSD on 10/19/16 Page 34 of 81 104. On or about July" 18', 2.0.13, sent an email to mailcom?. directing PAL to liquidate one of the GPR cards account lobal__ .a ments- funded by victim Aan U. and PAL responded, ?Done for 1136,? indicating that he purchasad {trolley-orders. 105.. On or about July 25, 2013, MONTU BAROT sent an email to JANAK witha FedEx shipping label addressed to JANAK SHARMA using the Florida residential address of ASHWINBHAI The subject line of the email: read, ?Parcel sent for $70,000?,- which is believed to mean the parcel centained $70,000" of money orders. JANAK forwarded the email to 1106. On or about July 29, 2701.3, ASHWINBHAI or a conspirator deposited two (2) money orders purchased with GPR cards funded by victim-Anup U. into a irsthank account belonging to a conspirator. ASHWINBHAI isa signatory on the bank-account for the conspirator. Andrew - Andrew S), resident of Plymouth, PA, of $750 by fraudulently purporting to be IRS employees, demanding-payment for alleged tax violations. 108-.- On or about October 30, 2013, ZORIION Callers directed victim Andrew S. to purchase-two (2) MoneyP-ak cards with the stored value of $750 and t0 tran'smitjthe PINS associated with the Men-eyPak cards to the Caller. 109. On or about October 0, 2013-, ZORIION c-onspirators transferred victim Andrew 34 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 35 of 81 S.?s scammed funds from the MoneyPak'sfto a GPR card. .1. 10. On or about October 30,2013, JACOB using inmbolalola@gmail.com. emailed'TARUN at The email subject line was ?Card Block Details_$82l .63? andthe email contained an attached spreadsheet with the GPR card number and registered user information fer the GPR Card funded by victim Andrew S. 111. On or aboutOctober 30, 2013-, Indian cell phone number. 9196621144952 accessed the-.GPR card funded by victim?Andrew S. and loaded two (2) MoneyPaks funded by an unrelated victim onto that card. __Niesha' .J. 112. On" or about September 4, 2013, HGLOBAL Callers telephonically extorted victim Niesha 1., a; resident of Warrenton,NC, of $180 by fraudulently purporting to "be- employees of the US. Treasury, demanding payment for alleged tax viOIationS. .113. On or about September 4, 2013, HGLOBAL Callers directed victim Niesha J. to purchase a Money-Eek card-with the stored value of $180 and to transmit the PIN associated with the MoneyPak card to the Caller. 114. On or about september 4, .2013, HGLO-BAL conspirators registered a Green Dot GPR card (-5132) using misappropriated PH. 115. On or about September 4,201.3, SAGAR THAKAR using email account provided the-GPR card number ending in 5132 that was later ?tnded by victim Niesha J. towat least two (2) conspirators during a Google chat?. On at least one 35 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 36 of 81 occasion, SAGAR THAKAR respondedto .a censpirator atibijlif 11331191 1 GPR card ?inded by victim Niesh-a . with the message, "?S-uec-es-5132 code ii?, indicating that THAKAR had to the GPR card. 116; On or aboutTS'eptemfber an HGLOBAL conspirator-used the GPR, card I funded by vi?e?mNiesha-J. to purchase alt-money order in NJ. Anthony W. 117.. On or about-.-October 10, 2013-, HGLOBAL:Callersitelephomeally defrauded victim Anthony W., residing in Joliet, IL, by representingthat?hes-would receive a government grant -ef$10,000 if he made upfront payments of $550. 118. On or about october 10, 2013, HGLOBAL Callers directed Anthony W. to -_purehase"itwo? (2) MoneyP-?aks withthe'combined stored value of $550 and provide the PINS to the Callers. I 119. On or about October 10, 2013, HGLOBAL conspirators transferred Anthony W.?s MoneyP-aks to two (-2) GPR cards- and liquidated one of. the GPR cards in Ocala, FL. 120.. On or about October 10, 2013, the H-GLOBAL Callers. contacted victim Anthony W. a second time identifying themselves as IRS employees and-demandedadditional payments, but victim Anthony W. did not make additional payments. 12-1. 0n 0r: aout October 10, 2013, JANAK using lobalOlr ?301.com received. two (2) emails froma conspirator at The emails;- contained both of Anthony Wis MoneyPa'k PINS and the amount of the MoneyPaks purchased by victim Anthony W. JANAK.-Subsequently responded, ?Approved? to both emails, indicating that the 36 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 37 of 81 GPR cards had been loaded with victim? funds, "122. On? or about October 10,2013, RAMANLALEPATEL (FL) using sent an email to JANAK SHARMA at loba101.__ _,aol.c.om containing ten (10) GPR cards including both of the cards funded by victim Anthony W. On the same date, ANAK sent two emails to DILIPKUMAR (FL) directing DILIPKUMAR (FL) to purchase money" orders with victim Anthony W.?s funds. DILIPKUMAR (FL) re'Sponded, ?Done? to one of the. emails; - Sarika C. 123. On or about October 30, 2013, HGLOBAL Callers telephonically extor?ted victim S'arika C.,.resi.ding: in Santa Clara, CA, of $16,000 by fraudulently purporting to be employees, threatening arrest; and deportation and demanding payments for alleged immigration violations. 1' 24. On or about October 30, 2013', HGLOBAL Callers directed Sarika C. to purchase 21 MoneyPaks with the stored value and transmit the PIN-s to the Callers. 12.5.. On? or about Oet?ober 30, 2013, HGLOBAL conspirators transferred Sarika 21 MoneyPaks. to 11 GPR used the GPR cards to purchase 24 money orders. 126.- On or about November 5., 201-3, TARANG PATEL "using email address targang _p.atel@vahoo.co.in sent an email ?to' a lead broker. The subject line of the email was ?Re 1800' deposit done? {and included the message, . . I already paid 1800 ?ve-days ago and .110va am more 1800.. 127. On tor-about November 5., 201.3, TARANG PATEL using 37 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 38 0f 81 Mr sent an email to ANAK SHARMA at hgmbalo @amaileom. The email contained the'subject line,- ?Fwd: $1800 Deposit~ Data. very very "very Urgent? and the message included the name Dart Data Inc. and its associated bank account number. 128. On 'or'about November 6, 2013, HBLOBAL eonspiratOr-de?posited $1 ,800 of mOney' orders, partially funded by victim Sarika scamrned funds, into the lead broker?s bank account. Kim-sea. S. - 129. Between on orabout August 12, 2013 through August. 13,2013, CALL MANTRA Callers telephonic-ally extorted victim Kimsea S., a resident of San Jose, CA, of $6,500 by "purporting to be: IRS employees, threatening her and her husband?s arrest and demandingjpayment for alleged tax violations. 130.} From on or about August '12, .2013 through August 13,2013, CALL MANTRA Callers directed victim Kimsea S. to purchase seven (7) MoneyPak. cards with the. stored value of $65,500 and to-prDVide the MoneyP'ak. PINs'to the Callers. 131 -. conspirators transferred v'liC'tim scammed fund's fromj?ie MoneyPaks to six (6) GPR cards registered using misappropriated PII of ?ve (5.) citizens-i. 132. On :or. aboutAugust 14, 2013, SUNNY SUREJAaccessed one. of the GPR cards containing victim Kim'sea S.'s Scammed fund-s using his Magic. Jack number to load funds. from an unidenti?ed victim from Woodside, NY. 133. On or about September 2, 2013, SUB-ISH EZHAVA using- 38.- 7% Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 39 of 81 chrisl?ast902 . ah'oocont emailed. SUNNY JOSHI at sunn 14-38. ahoo.com. The email containeda spreadsheet detailing $24 ?1,479.80 in GPR card transactions; processed. by SUNNY using- 118 GPR card-s. during the-month. of August 2013'. Included on the list was a GPR card funded by victim .Kimsea S, ending in number 1773. 134. On-or about August" 13,2013, CALL MANTRA conspirators used GPR card? ending in 1773 in two (2)"transaeti0ns in MiSsouri City, 13.5. On or. about September 2, 2013, EZHAVA using chrislast902@yahoo.com emailed BHATT MAN-OJ JOSHI) at The email contained a. spreadsheet detailing $239,180.79 in GPR card trans-aetions' processed by RAIESH BHATT using 116 different GPR. cards during the month of August 2013?. Included on the listwere. two of the GPR by victim Kimsea which were used in three transactions in Houston, TX on August 12, 2013. Humaira .1336. rent on. or aboutJan'uar-y 27, 201.22" thronghMarch- .18, .2013, TILAK JOSHI victim money through various merchant accounts for India-based conspirators. 1. 3-7.. From on or about Febmary 25, 2013 through March 1, 2013.,? HGLOBAL Callers telep?honically- defrauded victim Hnmaira residing in Houston Callers offered Humaira L. an. auto loan but she was instructed to make $1,325. in payments in advance of the loan. Callers directed victim Humaira L. to purchase ?ve (5) GPR cards and provide the card numbers as payment. 39' Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 40 of 81 From on .or-about February 25, '2013 through March 1, 20133, the operators of - ail'.c.om and HITESH PATEL, sent ?ve (5) emails to- TILAK containing the. ?ve (5) card numbers purchased by Humaira L. ILAK QSHI responded, ?Approved?, indicating-that the GPR card-s had been vacated. At least four (4) of the. cards were: processed by a conspirator operating a merchant terminal in-Milpitas, CA from February'22'6, 201.3- thmugh March 4,2013. 139-.- On .01? about April 22, 2013,, TILAK JOSHI emailed .HITESH PATEL at la'f mail..eom a spreadsheet titled The spreadsheet covered December 1. 2, :20 1'2'through April 19, 2013 and detailed 1,199 GPR and MoneyPak cards totaling $314,396.31 in value and purchased by .8 52 victim-s. Included On this. list-were all ?ve (5) G?P-Ri-ciards purchased by victim Humaira L. 2014 140. From on or'about approximater January 9., 201.4- thmugh January 29, 2014, WORLDWIDE SOLUTION Callers extorted Suresh M., a resident of Hayward, CA, of approximately 136,000 by fraudulently'purperting to be IRS agents demanding payment for alleged tax violations. 141. From onor about betweenlanuary 9, 2014 through January 2-9, 2014, WORLDWIDE SOLUTION Callers directed victim Suresh M. to purchase 276 MoneyPak's with- .the stored Value of approximately $136,000 and transmit the PINS-associated with those MeneyPaks to the Callers, 40. Case Document 6 Filed in TXSD on 10/19/16 Page 41 of 81 142. From on or aboutapproximatelylanuary 9, 2014 through January 29', 2014, conspiratO'rs transferred" victim {Suresh Money Pak scammed funds to at least .93 GPR Cards. 143-.- ?From on or about 9., 2014 through January 10, 2014, KUSHAL SHAH sent emails to CYRIL I HON DANIEL containing images of ?ve (5) of the GPRca'rds that-were funded with victim SureSh M.?s MoneyPaks. "144. From on or about January 9, 2014 through January 10,. 20.14, CYRIL JHON DANIEL sent two (2) "emails to KU-SHAL SHAH and JA-T-AN OZA with- lists detailing GPR cards and. the used to activate the GPR cards; included on these lists were eight (.8) of the. GPR cards funded by victim Suresh M, 145. On. or about April 14, 20.1.4, JATIN SOLANKI created a ?le which was subsequentle stored on his Goggle drive cloud storage Included on this ?le were the same eight (.38) GPR cards funded by victim Suresh M. 146,, On or about January 10, 2014, JATAN OZA, using the 785 Magic Jack telephone: number, accessed one of the GPR card's funded by victim SnrezShM. OZA, using the Same Magic Jack-number, transferred an unidenti?ed victim?s funds from. a MoneyPakto the same" GPR card funded by'vict-im Suresh From on: or'about? 12-, 2014 through anuaryg27, 2014, VISHAL used PH stolen from aprivate- New York State-company?s database, for which VISHAL operated as aan contractor, to activate 29 of the GPR cards leaded with scammed funds from victim" S'u're'sh M. called into Green Dot using the telephone number of the private Yerk State company that'sempIOyed activate-the 29 GPR- cards, 41 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 42 of 81 148. From. on or about January 12', 2014 through January 26, 20124, VISHAL GOUNDER Sent nine (9) emails to TARUN SADHU containing 29ef the card numbers funded by victim. suresh M. and the P11 used to activate the cards. '1 On or aboutJ'anuary 28, 2014, VISHAL GOUNDER sent an email to himself containing GPR cardnumbers funded by victim Suresh M. 15.0. On or about January 13, 2014], at approximately 11:37? am, a. censpirator used a. GPR card fundEd by victim 'Suresh M. aria. gas station in Racine, WI which was owned by MITESHKUMAR and On the same day at 12:46 a conspirator used the Same GPR card at a grocery store in Las 151. On or--.about January 14-, 1'6, and 17, 2014, SADHUContacted Green Dot using his Indian cell. phone and accessed four (4) of the GPR cards funded by victim Sure'sh M. 1' 52. On or about October 15, 2014, TARUN SADHU emailed. a conspirator a log covering card _proces:Sing activity between December 13, 2013 and. October 15, "2014. Entries infthe: log for. anuary'23, 724', and 27 of 2014 included. the last-four (4) digits of seven (7) GER cards that: were funded by victim suresh M. on the same dates. 153. Gnu-or about January 23, 24, and '27, 2014, WORLDWIDE SOLUTION conspirators liquidated. in Ari20na the seven (7) GPR cards ?om TARUN log that were funded by victim Suresh M. 154. On or about January 23 and 24, 2014, TARUN. SADHU and, BHAVES-H PATEL contacted each. other phone 0n multiple occasions. 4?2 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 43 of 81 Inaiben. 155. 7 On or?abOut November 2014, an Caller'te?lephonicall?y .ex-torte'd victim of Sugar Land, to bean employee of USCIS, demanding payment. for alleged immigration violations. The Caller'represented that Inaben.D., a' US. citizen, would be deported if she did not pay. 156. On or about November 5, 2014', JANAK busing- hgloba101@gmail.com sent a lead list containing the PH of 4,463 individuals including-victim Inab'en D. to a conspirator mailcom. who was using email account tastib'rwardOI - 157. On or about November 6, 2014, an Caller directed Inaben D. to wire $17,786 to the Chase bank account of an owner-of a Sunnyvale, CA check cashing business. On November 6, 2014, JAN-AK two emails from fastforward01@gmail.com advising that amounts of $8,800 and $8,986 were wired into the Chase Bank account. 158. On or about November 2014, an HGLOBAL Caller? directed Inaben D. to purchase two 'MoneyPaks, totaling $1,386 and to provide the PINS-from the cards. 159: an email from fastfoward01@gmail.com containing the two MoneyPak PINS purchased by victim Inaben D. I responded ?Approved?:to the email on the same- that. the funds had been transferred to GPR card's. 160. On or about November 6, 2014, the GPR card that'received the: MoneyPak was purchased in Illinois and was registered using the P11 of an individual with the initials DR 161. On or about November 6, 2014-, CHAUDHARI purchased- two (2.) 43 Case Document 6 Filed in TXSD on 10/19/16 Page 44 of 81 MoneyGra-m money orders inthe name of an individual with-theinitials using the DP. card funded by victim. Inaben 162. On or about November 7, 2014, a conspirator deposited the two ERG. money orders into a Chase bank account. Jeffrey. G. 16.3.. On. or abol?Jt September 30, 2014,- CALL- Callers telephonically extortezd "victim Jeffrey residing in San Diego, CA, of $4,176 by fraudulently purporting to be IRS employees, threatening his-arrest and demanding ?nes and fees for alleged tax violations. 16.4. On or. about September 30, 2014, Callers directed victim Jeffrey G, ?to-purchase ?ve Blackhawk Network Reloadit cards with the stored Valued of $4,176 the PINrsi associated with. those Re?loadit cards to the Callers. 165:. On or about September 30, 2014, CALL MANTRA conSpirators transferred victim Jeffrey G. extorted $4,176 from the five (5) Reloadit cards to-two (2) PayPowe'r GPR cards which had been purchased at a Randall?s Store inSugar Land, TX on September 29, 20-14 and regifsteredtin?theme l66. or about'Septemiber-30, 2-014, NILESH liquidated one of the GPR cards (-1817) .at-a Walmart-store in Pearland, for three. (3) Monemen money- orders totaling The second GPR card was not vacated, 167. On or about October 3, 2014, EZHAVA using ehrislast902@vahoo.com sent an email to SUNNY JOSHI at sunny 1- titled ?Report-fer the Month of September 2014?. The email stated, ?Hello Sir, Reportefor the Month of September 2014 44 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 45 of 81 attached. Thank included an Excel spreadsheet attachme?ntititled Report for Sep 2014?. The Excel spreadsheet-contained a list of 290- (HR cards which were-vacated between September 1, 2014 and September 30, 2014 for a total: of $169,394.30. The spreadsheet also contained both GPR cards which received victim Jeffrey G.?s extorted' funds. The spreadsheet indicated. that the liquated card 817) was ?picked? on September 30, 2014 for the none-vacated ?blocked? on the same? date. 168.. On or about October 5, 2014, SUNNY OSHI, using sunnj 1435 ?a .ahoo._co_rn, sent SUBISH EZHAVA an email at titled ?Final report 09-01-14 to .The text of the email contained :anaccounting of SUNNY?sactivities for the month of September 2014 to include totals, balance, deposits made and expenses. JCS-HI listed .50 pc,mail,money order ,m=ney order fees,gas? (sic) as expenses. Prixankaben S. 169. On or aboutAugustQS, 2014;, telephonieally extorted Priyankaben S., a Sunnyvale, CA resident, $7,600hy fraudulently purporting to be employees and threatening her with deportation for failure to pay alleged ?nes. 1' 70. On or.-ab0ut August 28, 2014, HGLOBAL Callers directed-victim Priyankaben S. to purchase eight (8) Reloadit cards with the stored value of $7 ,600 and'transmit the PINS associated with those Reloadit cards to the Callers. 171. On or about August 27, 2014, prior to Priyankaben fraud call, HGLOBAL conspire-tars purchased four PayPower GPRcards at aHome Depot in Tulsa", OK and registered the cards using the misappropriated PII of .R., and 45 Case Document 6 Filed in TXSD on 10/19/16 Page 46 of 81 172.. On or'about August 28, conspirators transferred Priyankaben S.?s scammed funds from the seven (7) Reloadit cards to four (4) PayPOWer GPR cards. 1.73. On or about? August 28, 2014;, FAHAD ALI and JAGDISH CHAUDHARI purchased money orders using the GPR Cards. containing Priyankaben S. scammed. funds at two Walmart stores in Oklahoma, 174. Previously, on or about'Adgt'ist 24, "2014, MITESHKUMAR PATEL booked a hotel room for two adults in the name of AHAD Oklahoma City, OK fer August? 24, 2014 through August 27, 20.14. American Express credit card was used to pay for the hotel room. 175-. On or about. September 11, conspirators reloaded the four (4) GPR cards which previously held victim Priyankaben S.?s scammed funds. 176'. On or-about September. 11, 2014,- RAJUBHAI PATEL purchased Western Union money orders-amn- Ultra Sup'ennarket in Joliet, IL using the reloaded. GPR card registered to .C. 177. On or'ab'out August 27 and 28, 2.0114 and September 11, 2014,. HGLOBAL conspirators occupying a 2013 Black Honda (IL 832.1792) registered to ASMITABEN PATEL drove to at least six (6) of the locations in OK and IL where the G-PR cards which received Priyankaben S. and-another victim?s-scammed ?mds-g-werepurchased or Vacated. 178. On or about August 23, 2014, FAHAD ALI and JAGDISH CHAUDHARI, occupying the 2013 Black Honda, diSposed of a plastic bag containing 55 vacated GPR cards in - the dumpster of the?Extended Stay America Dallas, 179. Previously, tin-or aboutAu?gust. 10, 2014, PATEL used '46 Case 4:16-cr-OO385 Document 6 Filed in TXSD on 10/19/16 Page 47 of 81 RAJUBHAI credit card to back and pay fora hotel room at the Extended Stay America Dallas in Dallas, TX for the period August 10., 2014 through August 23, 2014 in the name of FAHAD: ALI. Ru-shikesh B. 180.. On or about?. March 24, 2-014, Callers te-lephonically extorted victim Rushike's-h 13., a. resident of. Naperville, IL, of $14,400 by fraudulently purporting to bathe Illinois State. Police, threatening Rushikesh B. with arrest and demanding payment for. alleged immigration violations. 181. On or about March 2-4., "20-14, HGLOBAL Callers directed victim Rushikesh B. to purchase 29 Reloadit cards" With the stored value of $500 each, and transmit the Ple associated with those Reloadit cards to the Callers. 182.. On or about March 24, 2014, HGLOBAL conspirators transferred victim- Rushikesh scammed funds 'from'the Reloadit cards to several GPR cards. 1-83. On orabout MarCh 24, 2014, conspirators purchased money orders at Fort-Myers, FL-area' Wal'mart storesusing somei'of't-he' Cardsl'o'aded with ?v?ictim' Rushikesh B.?fs scammed funds. 184. Between onor-about March. 24, 2014 and April 4-, .2014, PRAFUL PATEL deposited the money orders purchased with victim Rushikesh scammed funds. into several different bank accounts. 185. On or about-March- 2014, the same day victim Rushikesh B. was Conspirator using email-account sent at least one email to 47 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 48 of 81 JANAK SHARMA containing ?ve of the-:29 Reloadit card numbers provided by victim RushikeSh to the HGLOBAL Caller. 186. On or about March 24., 2014, HGLOBAL conspirators using the" 630 Magic Jack number called PRAFUL apprOXimate-ly ten (10) times and. PRAF UL PATEL called the 630 Magic Jack number once. 1837'. On November 24, 2014, WORLDWIDE SOLUTION Callers tel-ephonically'extorted victim Diana of Hernando, MS, of $19,625 by fraudulently purporting-to be IRS employees, threatening arrest and. demandingpayment. for alleged violations. 18.8. On or about November 24, 20-14., WORLDWIDE SOLUTION Callers di'reCted victim Diana D. to purchase 21 prepaid MoneyPak cards with the Stored value of $19,625 and transmit the Ple- associated those MoneyPaks the Callers. 189. On or abbiit-?Novcmber24, 20.14, WORLDWIDE conspirators transferred victim Diana Dis scammed funds from the. Moneyl?aks to .12 GPR cards. The GPR cards Were regiStered using the miSappropriated PII of seven individuals. 190. On or. about N-0vember 24, 2014, in a Mesa, AZ Walmart store, RAJESH KUMAR purchasedtwo (2) money orders using one of the GPR cards loaded with victim Dian-a scammed funds. 191. On or about November 24, 2014, WORLDWIDE SOLUTION conspirators vacated the other 11 GPR card-s. loaded with victim Diana D. ?s scammed .?m'ds in Arizonaand. 48 Case Document 6 Filed in TXSD on 10/19/16 Page 49 of 81 Maryland ?ea?K- 192. On or about September? I 1, 2014, WORLDWIDE SOLUTION Callers telephonically --extorte.d victim Ana. a resident of Centennial, C0, of $7,599 by fraudulently purporting to lie-IRS employees, threatening arrest and demanding immediate payment for alleged tax violations. 193. On or about September 11, 2014, WORLDWIDESOLUTION Callers directed victim Ana to purchase-nine (9)'prepai'd- Reloadit cards with the stored value. of $7,599 and transmit the. PINS associated with those Reloadit cards to the Callers. 194. Ohm abOut September 11, 2014, WORLDWIDE SOLUTION conspirators transferred" victim Ana K."is scammed funds from the Reloadit cards to ?ve (5) PayPower GPR cards. 195.. Between on orabout "September?4, 2014 and September 311 2014, WORLDWIDE SOLUTION conspirators registered the GPR cards loaded with Ana 'K.l"s.seammed ?mds using- 196.. On 'or about september 11, 2014, WORLDWIDE SOLUTION conspirators vacated-the ?ve GPR cards loaded with victim Ana K?s-scammed funds in Marylandiand Arizona. 197. On or about Octdber 15, 2014, SADHU emailed a WORLDWIDE SOLUTION conspirator a logeoife?ri?iig card-"processing activity occurring between December 13, 2013 and October 15., 2014.. Entries .i-ni'th'e leg for September 1, 2014 included 4.9 Case 4:16-cr-00385 Document 6 I Filed in TXSD on 10/19/16 Page 50 of 81 the amounts?95'0? and the last four (4) digits of one-of the GPR cards (465100) that'was ?mded by Victim Ana K. on the samedate. "The card number "was under the column heading ?Bhavesh Transact-ion records for one of the GPR cards funded by Victim Ana K. showed that the Card was used in a transactionin Mesa, AZ on September 11, 2014 in-ithe amount-of $949.70. .198. On Var-about October 22, 2014, PATEL purchased two-(2) money orders at a Walmart store in Mesa, using one of the GPR cards (+6500) loaded with victim Ana K. scammed Faigy H. 199. From on or about August. '19, 2014 through on or about August 22, 2014, HGLOBAL Callers telephonically e?xtorted victim Fairy H., an 85?year-old woman residing in San Diego, of $12,300 by fraudulently purporting to be employees of IRS, threatening arrest" and demanding payment-for alleged. tax vidlations. 200.. From on or abi'Out. August 19, 2014'through on or about August 22, 2014., HGLOBAL Callers directed victim Fairy H. to purchase 18 MoneyPaks and 14 Reloadit "cards with the stored value of $12,3'005and to transmit the PINS associated with the cards to the Callers. 201. Between on or about August 19,2014 and on or: about August '25, 2014, HGLOBAL conspirators transferred victim Fairy H.?s scammed funds from the stored value cards to at least 16 GPR cards. 202.. Previously, on or about August 1' 8, 2014, SAMARTH PATEL using ._anask ail.corn emailed JATIN SOLANKI at solanki.jatin93@gmail.com a spreadsheet of 46 GPR card's activated using?the misappropriated PII of 16 US. citizens. Included on the list 50 7% Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 51 of 81 was one of the GPR eards funded by Vietim Fairy H, on August 319', 201-4. 203.. On or about August 19, 2014., JATIN using. solanki.iatin93@gmailroom emailed KUSHAL SHAH at a spreadsheet of .43 GPR cards activated using the misappropriated PII of 15 US. citizens. Included. on? the listwere two (2) of the GPR cards funded by victim Fairy H. 204.. On or about August 19, 2014-, CHAUDHARI .used one of "the GPR cards funded With victim airy H.?s scammed funds to purchase three (3) money orders at a Walmart store-3 in "Frisco, TX. The GPR card used by was included on the spreadsheet sent by JATIN SOLANKI to SHAH on August 19, 2014. Diana N. 2015.. On or about February 10, 2014, CALL MANTRA Callers telephonieally extorted? victim Diana.N., a resident of Monroe, NY, of $3,562 by purporting to be Treasury Inspector General for Tax Administration (TIGTA) employees,- threateningher-"and her husband?s arrest and demanding payment for alleged tax violations. 206'. On orabout February 10,. 20.1 4, CALL MANTRA Callers directed victim Diana N. to purchase eight Mon'eyPaks with the stored value off-133,562 and to provide the MoneyPak the Callers. 1207. On or about February 10;, 2014, CALL MANTRA conspirators transferred Diana N.?s scarrirned funds from theMoneyPaks to two (2) GPR cards registeredwith misappropriated PII of two citizens. 208. On or about February 2014, conspirators vacated the GPR cards with Diana. Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 52 of 81 N.?s scammed ?mds in Houston,TX-, Nashville, TN, and Racine, WI. The transaction in Racine?, occurred at MITESHKUMAR and gas station. 209., On'or aboutMarch. 1,201.4, SUBISH cihrisla?st902@ yahooco'm emailed JOSHI.atZ.sunn__ 1433 j: The:..email contained a spreadsheet detailing approximately $308,927.53 in GPR card. transactions processed by SUNNY using 179 GPR cards in-F?ebruary 2014. Included on the" list was. one of the GPR card-s funded by victim Diana N. 210. On or about Mar-eh 2-014, OSHI "using sunny. emailed KUNAL NAGRANI The subject line of the email was ?Final Report (02/01/2014 SUNNY JOSHI reported $308,920 in GPR card transactions during this periodand receiving a commission SUNNY JOSHI also reported making various deposits. during the period-i'ncludinga $50,000 payment to 21.1. On' or about February 10, 20"14, SUNNY JOSHI mailed via USPS a package to PATEL, 'consiste?ti'WiIH'SUNNY?s report that he paid money in February 2014. 212. On. or about February 20, 2014, SUNNY OSHI mail-ed Via USPS a package to MITESH PATEL, consistent with report that he paid MI-TESH a sum of money in February 2014. 'Gokul 2131. 'Ormr about May 1,2014, HGLOBAL Callers telephonically extorted victim 521 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 53 of 81 Gokul T., residing in San Jose, CA, of $10,154, by fraudulently purporting to be IRS employees, demanding payment for alleged tax vidlaticns. 214. On or about Aspri128, 2014, prior to Gokul T.?s scam call, the-operators of mailicom AALAMKHAN PATHAN, ANJANEE SHETH, and AYKUMAR OSHI, emailed-a conspirator at The email contained a. lead list titled indicating that its contents were intended-to be used-for the IRS scam. The lead list contained Victim Gokul PH. 215. On or about May 1, 2014, HGLO-B-AL- Callers directed victim Gckul'T. t0} purchase 14 prepaindn?eyP'etk cards with the stored value and transmit the PINS associated with those .MoneyPaks to the Callers. "216.. On or. about May? 1, 2.014, conspirators transferred victim Gokul T.?s 54 fret-1114 MoneyPak cards to four (4) GPR cards which were activated the day prior, April 30, 2014. 217. From on or about March 6, 2014 through May 3, 2014, RAJPAL SHAH, participatedin a WhatsApp chat-discussing the processing of MoneyPak PINS. provided the 14 MoneyPak P.le purchased by- victim Gokul T. in chats datedMay l, 2014. 218. On or about July'3'0, 2015, DILIPKUMAR AMBAL PATEL (CA) possessed on his cellphone images of 5,1562 different GPR cards, including the four (4) GPR card numbers funded by victim Gokul T. The four-GPR cards were used in transactions occurring on May 1, 5'3 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 54 of 81 2014 and May 2, 2.0114 in Corona, CA and" Pomona, CA. When interviewed by investigators, DILIPKUMAR PATEL to liquidating GPR cards for--?-individuals perpetrating the IRS impersonation scheme and admitted that he worked SHAH and PATEL, among .dthers. Daxeshkumar 2.19.. On" or- about February 19, 2014, HGLOBAL Callers telephonically ext'orte'd Daxe'slikumar R, an Illinois resident, of $1,472 by fraudulently-purporting.to be IRS agents demanding payment for-alleged violations. HGLOBAL Callers appeared to be using an IRS telephone assistance number, l-800?829?1040. 220. One: about February 19, 2014, HGLOBAL Callers directed victim Daxeshkum-ar to purchase three-(3) MoneyBaks with the stored value of $1,472 and transmit the PINS associated with those. MoneyPal?S to the Callers. 221. On or abeutr February 19, 2014-, HGLOBAL censpiratOrs funded. two (2) GPR cards with Vietim. Dexeshku'mar P.?s scammed ?i-nds; both GPR cards were purchased between 19, 2014 in Pe-lham, AL and Mishawaka, IN and were. registered .in the name-s- of individuals with the "initials RM, and 222'. On or about February 1-9, 2014, KUSHAL SHAH using emailed CYRIL-JHON DANIEL at 'ey'rilhm2426ga2gmailcom requesting to activate: a GPR card, In, his email CYRIL attached a spreadsheet titled ?Cards_19th Feb? which listed 38 GPR cards regiS'tered with the PH of eight (8) citizens. Among the cards listed on the spreadsheet were the th> (2) GPR Cards which :54 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16. Page 55 of 81 received the" ?mds. of Victim. Daxes?hkuma'r P. . On or about ebruary: 19,- 2014, one ofthe GPR cards ?mded. by Daxeshkum-ar funds wasi'acce3sed by the 7 8S MagieJack controlled OZA. 224. On or about February 19, 201.4, NILAM P-ARIKH was observed leaving the Walmart in Hoover, AL after using the GPR card registered to. a. PARIKH purchased three (3) MoneyGram money orders totaling $2,220 with Daxeshkumar P. ?s scammed funds. 225'. On or about February 1- 9, 2014, an HGLOBAL conspiratOr' purchased MoneyGram money order at at Walmart store in Fishers, IN using-the T.F, GPR card-and deposited the money order into the BOA account of an individual "with the. initials E.D. The same bank account received additional money orders on February [19, 2014 which were "purchased-at at Walmart store in Carmel, IN with a card loaded with funds exterted-fro-rnanother call; scam victim. The same-GPR. card Was-[later vacated at the Racine, WI Exxon-Mobil gas station-owned by MITESHKUMAR and ASMITABEN PATEL.- 226. On. or about July 1-0, 2014, WORLDWIDE extorted victim Aisha Si, residing in Austin, TX, 72 by 'fraudulently'purportin? to be IRS employees, demanding payment for alleged tax violations. 227. On or about July 10, 2014, WORLDWIDE SOLUTION Callers directed victim Aisha S. to purchase ?ve (5-) with the stored value of $2,372 and provide the PINS associated with those MoneyPa?ks to the Callers. 228. On or about July .10, 2014, WORLDWIDE SOLUTION conspirators transferred 55 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 56 of 81 victim Aisha extorted funds from ?ve (5) MoneyPaks to two (2) GPR cards which were subsequently vacated in Michigan. and .229. On-or about: June 19,- "prior to Vietim Aisha scarn call, GOPAL PILLAI man-1.00m emailed TARUN SADHU at. mailcom. The email, contained-the subject line ?Tarun 20000 tax worldwide-solutionZOl 2 indicating that the Contents Were. intended to be used for the IRS scam, and contained the PH and ethnicity of 20,000 individuals. Included on this liSt Was the phone number and address of victim Aisha S. Naraxianlal R. 2:30.. On or about May 9, 2014, HGLOBAL Callers telephonically extorted victim residing in Jackson Heights, NY, of $865 byfraudulentlyipumorting to be IRS employee's, threatening arrest-and demanding payment fer alleged'tax violations. 231. Onor about-May 9,2014, HGLOBAL Callers directed victim Narayanlal R. to purchase two (2) MoneyPak-s with the stored value of $865 and to transmit the MoneyPak PINS tenths callers-t 232. Door about May 9, 2014., conspirators transferred victim Narayanlal MoneyPakzs transferred to. a GPR card registered on May 9., 2013.4 using misappropriated PII and vacated-the GPRcard at-a?Kro-ger Store-in Arlington, 233.. On 0r. about May 9, 2014, .ANJANEE SHETH using ganeshinfosolutionsll emailed a lead list to a conspirator at The lead list contained the P11 of victim Narayanlal R. 56 Case Document 6 Filed in TXSD on 10/19/16 Page 57 of 81 234. On or aboutMarch 4, 2015, the operators AALAMKHAN..PATHAN, SHE-TH, and .J-AYKUMAR res-5H1, emailed :g3306656@gmail.com. The subject lineof'the email was "Fwd: IRS Customers Ipayment details with name". The. list included the ofvictim Narayanlal R. and the MoneyPak PINS purchased by Narayanla'l R. with a payment date listed as May 9,2014. Constantine'F. 235. On or about January 6, 201-4, ZORIION Callers, using telephone number (866) 978-8046, extorted victim Constantine .., a. resident of San Francisco, CA, of $1,588 by fraudulent-1y. pUrporting to be IRS agents,.demanding immediate paymentfor alleged tax violations and threatening arrest within One hour if she did not make the payments. 236?. or about December 2-, 2.013, prior'to victim Constantine R?s 'se'ammw call, VICKY using bharadwai.vickv@amail.com received an email containing a lead list from a conspirator using-'thomasalviro 15 of mail.com. The lead victim :C'onstantine with. arr-additional column titled ?Total Tax Debt '35? with the amount ?50000? listed next to victim Constantine F.?s name. 237.. On or about January 6, 2014, ANIRUDDH CHAUHAN using aniruddhc8'4 . ai'l.eOm received an email from business.voicemaster@gmail.eom with the subjeet?line ?new toll?'ee?. The email message contained the telephone number (-866) 978-8046,. the. same phone number used to contact victim Constantine F. 23 8. On or about January 65 2014, ZQRIION Callers directed victim Constantine F. to. purchase four (4) MoneyPaksvalued. at $1,588 and provide the PINS. to the Callers. 57 Case Document 6 Filed in TXSD on 10/19/16 Page 58 of 81 239. on Or- about January 6, 2014, ZORIION conspirators transferred victim Constantine F.?s scammed funds to three?: (3.) GPR cards- WhiCh were used intransacti'ons in Decatur, GA, Bridgeview, IL, Evergreen Park, IL. 240. On or about. February 17, 20.14, a conspirator using Zoriionnewway??omailcom emailed VICKY BHARDWAJ a spreadsheet detailing victims? payments receiVed from. Nevember 2013 .thrOugh February 2-014, Included? on the Jan? 2014 tab wast victim Constantine R?s name, the Mo.neyPak PINS purchased by Victim Censtantine F., and the .GPR card-numbers loaded with victim ConstantineF.?s funds. Hassan K. 241. On or about April 1-1, 2014, HGLOBAL victim Hassan K., Houston, TX, of $1,348 by fraudulently purporting to be IRS employees, threatening arrest and. demanding immediate payment for alleged violations. 242. On or about April 11, 2014, HGLOBAL Callers directed. victim Hassan K. to purchase three (3) MoneyPaks'tOtaling. $1,348 and provide the PINS to the Callers. 24-37 K.?s.MoneyPaks to a' GPR card and liquidated the funds. at a Walmart store in Norwalk, CT. 244-. On or about May 15, 2014, the operators of geneshi'nfosolutionsl ll@gmail.com, AALAMKHAN PATHAN, ANJANEE SHETH, and J-AYKUMAR JOSHI, sent an email to themselves with two attached ?les. The attached ?les" were a WhatsApp chat and a spreadsheet titled On or about April 11, 2014, RAJPAL SHAH, PATHAN, JAYKUMAR OSHI, ANJANEE STHETH, and. PATEL participated in a 58' Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 59 of 81 WhatsApp chat discussing the )TMoneyPak PINS purchased by Hassan K. Hassan K.?s MoneyPak PINS and amounts were included on the spreadsheet. The column directly next to the purchased by Hassan K. read, sent by ay?. ?ling.- 245. On or. about February 27, 2014, CALL MANTRA Callers, using. phone number (202) 7'54u8635, te'l'ephonieally extorted victim Dilip G., residing in. Plano, TX, of $3,500. by fraudulently purporting to be IRS employees, threatening immediate police action and demandingimmediate payment for alleged tax violations. 246:, On or about February 27, .2014, CALL MAN TRA Callers directed victim Dilip G. to purchase seven (7) MoneyPak cards with the stored value of $3,500 and provide the PINS to the Callers. I 247. On or about February .27., 2014,- CALL conspirators transferred victim Dilip MoneyPak cards to two (2) GPR cards liQuida'ted the funds atretail locations in SOuth Euclid, OH and Crofton, MD. received an email from a conspirator at Raghu The email contained the telephone number (202) 754-8635, user name, and password to the: account. 249. On or about February 28, 2014, SUNNY SUREJA using received an email from a conspirator at davidcooper23191@amail;cnrn. The email? contained an attached Spreadsheet detailing 59 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 60 of 81 payments received in the month of February 2014, including victim Dilip name and the MoneyPak PINS purchased. by victim 'Di'l'ip G. 39x2: 250. On or about December 8, 201.4, HGLOBAL Callers telephonically extorte'd victim Troy residing ianilleen, TX, of $3,675 by fraudulently purporting to be .IRS employees, threatening arrest and demanding payment for alleged taxvi'olations. 251.. On or about December .2014, HGLOBAL Callers directed victim Troy P. to purchaser-eight (8) MoneyPaks? which were transferred to four (4) GPR cards registered on I December 8, 2014 using the misappropriated PII of four. (4) individuals. 252. On or about'December to the scam call, THAKKAR using. karan received an email from a conSpirator using email address The-email contained a lead list with. the P11 of. 550 individuals, inel'udi'ng the P11 of the four_(4) U.S. cit-ideas "used to. register the GPR cards funded with Troy P.?s scammed funds. 253. On or about-December 7, 2014, JERRY NORRIS messaged KARAN THAKKAR on WhatsApp "with the four (4) GPR cards funded by victim Troy P. .254. On or aboutDecember. 8, 2014, KARAN THAKKER sent to JERRY NORRIS the last four digits of the cards hinded'hy victim Troy.P.., a PIN- fo-r each, the. date of birth. of the registered card holder, the zip code of theregistered cardholder, and the last four digits of the registered cardholders? Social Security number. KARAN THAKKAR immediately followed. with, ?James "send me newig'dots" 6'0 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 61 of 81 25 5., On December 8, 2014, JERRY NORRIS accessed all of the GPR cards funded by victim Troy telephone number. (510) 776-8220. 256. On-or aboutDecember 22, 201.4, KARAN THAKKAR using karan thakkar84@vahoo.in emailed karat: WhatsApp chats between THAKKAR and JERRY NORRIS from November 14 through December 17, 2014. Israfi?l M. 257. On or- about July 2014, ZORIION Callers, using telephone number (888)373- 05'92, extorted victim Isra?l in Tukwila, WA, of $1,290 by fraudulently purporting to be IRS arrest and demandingimmedi?ate payment for alleged violations. 258. On or about My 2014,- ZORIION Callers directed victim ISra?l M. to purchase three (3) MoneyPak Cards with the stored valued of $1,290 and provide thePINs to the Callers. 2519. On or about-July 3t, 2014, IZORIION conspirators transferred the three (3) MoneyPa'ks to two (2) GPR. cards which were registered with misappropriated PII and vacated those GPR cards On July 3, 2014 and July 4, 2014 in Thornton, CO, Arlington, TX, and Pantego, TX. 260. On or about July 20.14, JATIN created a ?le in his Google drive titled A GPR card funded by victim Isra?l M. was listed on'the spreadsheet. 261. On or about June to I'sra?l M?s scam call, RAHUL DOGRA using rahultdo ra mailco'm received enema-i1 from a. conspirator Containing 6-1 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 62 of 81 ?ve (5) toll-?ee telephone: numbers and Telephone number- (828-8) 37 3- .0592 was listed in. this email. 262. Onf'e'r. about November 33, .2014, RAHUL DOGRA using rahultdogra@gmail.com received an email from a conspirath at mano.i2884@gmail.eom with- the' message, ?Due to some illegal Activites the (sic) are some issue to allot new DID numbers and active old. DID for 2 days so I request you all. too" kindly support andmanag'e'it for 2 days. . .The complaint states. that this number is being used'as part of "an scam.? Khemwattie-Gf. 263.. On or about: July 28, 2014:, HGLOBAL Callers telephonically extorted victim Khemwattie Gr, residing in Ozone Park, of $786 by fraudulently "purporting :to be IRS employee?s, threatening arrest and deportatiOn and demanding payments for alleged "taxes. 264. On or about July 28, 2014., Callers directed victim Khemwattie G. to purchase Me (2) iMoneyPaks- with the stored value of $786 and transmit. the PINS to the Callers. 26.5.. On or about luly28, 2014, HGLOBAL conspirators transferred victim - KhemwattieG?s. Money-Paksto a GPR-card registered on July ?28, 2014 using misappropriated PII. At least one of the MoneyPaks was transferred to the GPR card by the 630 Magic ack number operated by .JANAK S-HARMA. 266. On or about July MANISH using manish.bharai@gmail.com emailed JANAK SHARMA at The subject line of the email was 62 I Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 63 of 81 ?Payment of [Khemwattie and the email message contained Khemwattie two (2) Money-Pak PIN JANAK SHARMA responded, the same date, indicating that the MoneyPak PINS were transferred to a GP-R card. 267, On or about June 28, 2014-and June 29, 2014, PATEL (CA) processed the GPR car-d funded by victim-Khemwattie CIR-s at his business located in Corona, CA. gig Halina S. Maria .268. On orabout April 2, 2015, HGLOBAL Callers telepho'niCall-y extorted Halina S.-, a Hartford, CT :r?esident,?of $4,176 by to'be IRS employees, threatening arrest and a jail sentence. "if victim Halina S. did not depoSi-t'money into. NISARG Wells Fargo Bank account ending in 96.49 for alleged tax violations. 269. On or'about, April-59am. 10, 2015., HGLOBAL Callers. telephonically extorted Maria Hills, CA resident, of $41,000 by fraudulently purporting to be IRS unpaid taxes directly into bank accounts including a? CITI-BANK account number ending in. 8148 registered in the name of PATEL. 2-70.- etween on or about April 7-, 2015 and April 10,; 2015, RAJPAL SHAH received ?ve (5) wire transfers in the name of an individual with the initials L.D. and eight (8) wire 3- Thefull name-of thervictim listed the subject line of the email has been redacted 63 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 64 of 81 transfers in the name-of? individual withthe initials P.L. using Western Union. 271. On about April 13, 2015, RAJPAL SHAH. and NISARG PATEL possessed the following items: two fraudulent Lawful Permanent Resident cards both with RAJPAL image and in the names of L.D.Iand PL. and two fraudulent Social Security cards in the names of and GPR cards, wire receipts from ACE Cash Services, receipts, Western Un?iOn trensaction EMS in the names of LE. and NISARG BO-A and Wells Fargo debit cards, and MoneyGram money- order receipts. 272. From at least February 24, 2015 through March 31, 201.5, RAJPAL communicated about card and money order purchases via text message With MITESHKUMAR exchanged GPR card numbers via WhatsApp with JAGDISHKUMAR 273. From at least March 17, 2015 though March 31, 201.15, NISARG PATEL texted conspirators with-details of purchasing GPR cards and money order-s,- deposit instructions, images ofbank deposit slips, and images of GPR cards. 274. 011 or about May 4, 2.015, in a text message, SHAH referenced his familiarity withthe pre-payment for services :or products know what i am into this types of Since last 5 years if need'to- learn. more: come up -i will teach you Juliette B. 275 . On or about-April 8, 2015, HGLOBAL Callers telephonically' extorted Juliette B., a resident of of approximately $3,980 by "fraudulently purporting to be IRS employees, threatening arrest if she-did not pay ?nes an?d'fees" for alleged tax violations. A.202- 64 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 65 of 81 area code phone'number'and the words Government? appeared on Juliette caller ID. 276.- On or about April 8,2015, HGLOBAL Callers directed victim JulietteB. to purchase ?ve (5) Reloadit cards in the amount of $2,446.26 and three (3 Green Dot GPR cards in the Mount and transmit .thefPINsV associated with those 277. On or about April 8, 12015, HGLOBAL conspirators transferred the scammed funds from the Reloadit cards to three (3) GPR cards serviced by American'Express. 278. On or about April 8, Callers also directed. Juliette B. to pay a ?warrant eancellat-ion?-fee of $8,500 by depositing money into VIRAJ J. BOA account numberending in 343 7. Victim Juliette B. did hot wire. the money to VIRAJ after the bank teller informed her that she was likely ther?vi.ctim of a scam. William G. 279. Between or about April 2, 20.15 and April 6, 2015, HGLOBAL Callers 'te'lephonically extorted victim William G., a resident of Naperville, IL, of more than $37,000 by fraudulently" purporting to be employees of. the US. Treasury and the IRS and demanding payment for alleged tax violations. 280. BetWee-n on or about April 2, 20115 andApril 6, 2015, HGLOBAL Callers directed} victim William G. to purchase approximately 72 prepaid Reloadit cards with the stored value of more than $3 7,000 and transmit-the PINS associated with those Reloadit cards. to the Callers. 281. Bet-ween on elf-about. April 2015 and April 20.15, HGLOB-AL conspirators transferred victim William G. ?s scammed fund's toiapproximately 38 cards. 65 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 66 of 81 282, Between onor about April 3., 2015 andAjpril 2015, HGLOBAL conspirators "vacated the cards in Ca'li'fomia, Colorado, Illinois, and Texas; i "283. On or about April 3, 2015, at approximately 1:53 ASHVINBHAI CHAUDHARI purchased MotleyGram money orders at a Walmart'Store "in Katy, TX using one ofthe-GPR cards loaded with Victim. William G.?s scammed ?inds. 284. On or about April 3, 2015, at approximately 4:23 ASHVINBHAI CHAUDHARI purchased "a MoneyGram money" order at a Walmart Store in Houston, using one of the GPR cards loaded with victim William G.?s scammed funds. 285. On or about. April 3, 2015', at approximately 1:38 HARSH PATEL deposited some of victim William (1?s seamined funds into a BOAaccount. 286. On or about April 6, 2015, at approximately 1:44 PATEL used oneof the GPR cards loaded with victim William G.?s scammed funds to withdraw cash at an ATM in Littletong, C0. BHAI PATEL drove up to the ATM in-a 2013 White Honda (IL. to MITESHKUMAR PATEL and another person. VIJAY PATEL was in the passenger seat of the white Honda. .287. On or about April .6, 2015,} at approximately 8:01 VIJ purchased a MoneyGram money order at a Walm'art'rStorerin (Littleton, CO using a GPR card loaded with victim William G.?s scammed funds. 288. On or about. April 7-, 2015,: at approximately 1:17 RA-JUBHAI PATEL purchased -a'.MQHeYGram money order in the amount of $500 in Denver, CO using a GPR card loaded with victim William G.?s scammed 66 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 67 of 81 239.. On: or about. April 20.15, at'aBO'A branch in: Hinsdal'e, IL, ASMITABEN PATEL deposited the money order purchased by RAJPATEL into a BOA account; 290. Otter about" April 8, 2015, at approximately 6:59 p.111, PATEL purchased a MoneyGram-mon'jey order at a in Lakewood,-CO using a- GPR card loaded with victim scammed- funds. 291. On or ab0ut April 9., 2.015, VIJAY PATEL deposited a portion of victim William G.?rs scammed funds into 21' Chase bank account at a branch in Firestone, CO. 292. Previously,? on or abeut March 26', PATEL used- RAJ UBH-AI American Express, credit card to "book and pay for a hotel room in GreenWbod Village, for the period April 2, 2015' through April 7, 2015-. 293. On or-about August 27, 2015, HGLOBAL Callers teleph'oriically extorted Victim Luis. D.., a resident of Will-ijamstown, NJ, of $?6g500-by fraudulently purporting to be employees of the IRS and a local "county sheriff?s department, threatening arrest and demanding'payment for alleged tax violations. 2914. On or about iAugust 27, 2015', HGLOBAL Callers "directed?victirn'Luis D. to wire feur (4) separate money $1,900, and $1,900) via MeneyGram to an individual with the initials .D. to four (4) different locations in the FortMeyers, FL area. 295. on or about March. 3, 201.6, HARSH PATEL possessed onhi-s phone an image of two fraudulent Mississippi driver?s licenses, one in'the name of JD. and one 'in- the name of an individual with the initials R.P. Both driver?s licenses contained the same photograph of 67 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 68 of 81 PRAFUL PATEL. 296. On or. about June 4, 2015 and continuing through on or about October 17, 2015, WORLDWIDE SOLUTION Callers telephonica-lly extorted victim Carlo C., residing in 7 Brooklyn, NY, of purporting to be IRS employees, threatening arrest. and demanding payment for alleged tax-violations. 297. From on or about June 4, 2015 through October 16, 2015, WORLDWIDE SOLUTION Callers directed Victim Carlo to payments into approximately 20 different bank accounts and'to send two wire-tran'strs via Western Union. 298. On era-about August 6, 2015, WORLDWIDE SOLUTION Callers also directed victim Carlo to purchase. a $8,000 payable to PATEL and to deposit the-Check into BHAVESH bank account. 299. On or about October 17, 20115;, WORLDWIDE SOLUTION Callers told victim Carlo C. to send copies of and money orders to (sic), 1.100 Riata BHAVESH Antonio S. Tina E. 300. :On or about March. 2015, VINEET VINEET SHARMA) using sharmabposervices@vahoocom received an email from a conspirator Operating The. email contained the user name, password, :andDOmain IP address for ?ve (5) Vol? telephone numbers, all of which? Contained the 202 area code. The user name and password for one of the telephone numbers, (202) 602-1426, were both listed as- 68 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 69 of 81 ?Vinitsharma006?. The user name and" password fer another of: the-telephone numbers, (202)- 602-1339, were listed as ?vinitsharma007?. 301. On or about March 16, 201 5,1 SHARMA BPO Callers,- using telephone number (202) 602-1426, exto?rted victim Antonio 3., residing in North Las Vegas, by fraudulently purportingtgo employees, threatening arrest and demanding payment. for alleged tax violations. 302.. On or about March 16, 2015, SHARMA BPO Callers directed victim Antonio S. to send three MoneyGram wire transfers-in the amounts of $500, $499,. and $300 to a GPR Card. 303. From on .or-jabout March 19, 2015 to on or about March 20, 2015, SHARMA BPO Callers using telephone number (202) 602-1339 extorted victim Tina residing in Auburn, MB, of $195232 by fraudulently purporting 120: be IRS employees, threatening arrest and demanding payment for alleged tax violation-s. 304. From on or about March 19, 2015 to on or about March 20, 20.15, SHARMA BPO conspi'rator totaling $12,432. BPO Callers directed victim Tina B. to purchase $6,300 in money orders andimail them. to a conspirator in Greenwood, SC. 69 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 70 of 81 COUNT TWO 18 1349' (Wire Fraud Conspiracy) 1. Paragraphs 1 to 10 and 132 to 72:31 of Count One and of this Indictment are realleged and incorporated as-though fully set forth-herein. 2. Beginning-in or abOUt' January 2012, the exact date being unknown to the-- Grand Jury, and continuing through in or about the date of the Indictment, in the Southern District of and elsewhere,'the defendant's, HGLOBAL, CALL MANTRA, WORLDWIDEISOLUTIGN, ZORIION COMMUNICATIONS PVT.- LTD., SHARMA BPO SERVICES, HITESH MADHUBHAI PATEL, HARDIK ARVINDBHAI PATEL, JANAK GANGARAM SHARMA, TILAKV SANJAYBHAI JOSHI, [18] SAURIN JAYESHKUMAR RATHOD, [l 1] RANCHHOD-BHAI PATEL, [l2] KUSHAL [13] JANAKBHAI THAKKAR, MANISH. BALKRISHNA RAJ PAL VASTUPAL SHAH, SAGAR THAKAR, CYRIL JHON DANIEL, [18] JATIN WJAYBHAI SOLAN KI, [19] NORRIS, NISARG- PATEL, MITESHKUMAR PATEL, [22] .RAJUBHAI PATEL, ASHVINBHAI CHAUDHARI, [24] .FAHAD ALI, JAGDISHKUMAR CHAUDHARI, [26] BHARATKUMAR PATEL, 7] ASMITABEN PATEL, [28] VIJAYKUMAR PATEL, [29] MONTU BAROT, [30] .PRAFUL PATEL, [31] ASHWINBHAI KABARIA, [32] .DILIPKUMAR RAMANLAL PATEL, [33] .NILAM PARIKH, .DILIPKUMAR-AMBAL PATEL, [35] VIRAJ PATEL, ABHISHEK RAJDEV TRIVEDI, [37] SAMARTH KAMLESHBHAI 70 Case Document 6 Filed in TXSD on 10/19/16 Page 71 of 81 HARSH PATEL, [3915' AALAMKHAN [40] JAYKUMAR [431] ANJANEE. PRADEEPKUMAR SHETH, [42] KUNAL - CHATRABHUJ NAGRANI, [43] SUBISH [44] SUNNY [45] SUNNY JOSHI, [46] RAJESH BI-I-ATT, PAN DYA, [48] TARUN DEEPAKBHAI SADHU, [49] VISHALKUMAR RAVI BHAVESH PATEL, RAMAN PATEL, [52] RAJESH KUMAR UN, [53] ANIRUDDH RAJ ESHKUMAR CHAUHAN, [54] RAHUL TILAK VIJAY DOGRA, [55] RAJKAMALBHARDWAJ, [56] CLINTWIN JACOB CHRISSTIAN, [57] .ANEESH PADIPURIKAL, [58] JATANKUMAR HARESHKUMAR OZA, RAJKAMAL OMPRAKASH SHARMA, [60] VINEET DHARMENDRA and GOPAL VENKATESAN PILLAI, unlaw?illy and knowingly did combine, conspire, confederate and agree to gether, and with eachother and others known- and unknown, tO-v'iolate Title 18, United States code, Section 1343. 3. It was a part and an obj-eet of the conspiracy- that the defendants, and others known and unknown, having devised and intending to devise a scheme-and arti?ce to defraud, and for "obtaining money and property by means of false, and fraudulent pretenses, representatiOns or promises, would and did transmit and cause to be transmitted by means of wire,- radio, and television. communication in interstate and foreign commerce writings, signs, signals, pictures, and sounds for the purpose of executing such seneme and arti?ce, to wit, defendants and others known and telephone calls ?om a place outside of the United States to victims inside: the United States to represent themselves to be of?cials of state 71 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 72 of 81 and federal agencies and thereby extort the'payment of funds thmugh the use of interstate electronic payments. All 'in violation of Title 18, United States Code, Section 1349. 72 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 73 of 81 COUNT THREE 18 U.S.C. 1956(h) (Money Laundering Conspiracy) 1. Paragraphs Count One of this Indictment are_.realleged..and incorporated though fully-set forth herein.0 .2. Beginning in orabout January 2012, the exact date being unknown'to the Grand and continuing through in or about the date of the Indictment, in the Southern District of Texas and elsewhere, the defendants, HGLOBAL, CALL MANTRA, LTD., SHARMA. HITESH MADHUBHAI PATEL, PATEL, ANAK GANGARAM TILAK SANJAYBHAI JOSHI, [10] SAURINJAYESHKUMAR RATHOD, RANCHHODBHAI PATEL, [12] KUSHAL NIKHILBHAI SHAH, [13] THAKKAR, MANISH. BALKRISHNA BHARAJ, RAJPAL VASTUPAL SHAH, [16] SAGAR THAKAR, [l7] CYRIL DANIEL, [18] JATIN VIJAYBHAI SOLANKI, [19] .. RAJUBI-IAI BHOLA-BHAI PATEL, [23] ASHVINBHAI CHAUDHARI, ALI, JAGDISHKUMAR .CHAUDHAR-I, [26] BHARATKUMAR PATEL, [27] PATEL, [28] VIJAYKUMAR PATEL, [29] MONTU BAROT, [30] .PRAFUL PATEL, ASHWINBHAI KABARIA, [32] DILIPK-UMAR RAMANLAL PATEL, [33] NILAMTPARIKH, DILIPKUMAR .AMBAL PATEL, [35] VIRAJ PATEL, [36] ABHISHEK SAMARTH KAMLESHBHAI 73 Case 4:16-cr-00385 Documents Filed in TXSD on 10/19/16 Page 74 of 81 PATEL, [38] HARSH PATEL, [39] AALAMKHANSIKANDERKHAN, [40] JAYKUMAR JOSHI, ANJANEE PRADEEPKUMAR SHETH, [42] KUNAL CHATRABHUJ NAGRANI, [43] SUBISH [44] SUNNY TARUNKUMAR SUREJA, [46] RAJESH BHATT, [47] PANDYA, TARUN DEEPAKBHAI SADHU, [49] VISHALKUMAR RAVI GOUNDER, [50] BHAVESH PATEL, 1] RAMAN PATEL, RAJESH KUMAR UN, [53] ANIRUDDHV RAJESHKUMAR CHAUHANs RAHUL DOGRA, VICKY RAJKAMAL BHARDWAJ, {56] CLINTWIN JACOB CHRISSTIAN, ANTONY PADIPURIKAL, JATANKUMAR HARESHKUMAR OZA, [59] RAJKAMAL OMPRAKASH SHARMA, [60] VINEET DHARMENDRA. VASISHTHA, and [61] GOPAL PILLAI, knowingly combined, conspired, confederated and agreed with each: other and with other persons, both known and unknown to the Grand Jury, to commit offense against the United States in violation of Title 18, United States Code, Section 1956, to wit: To knu affecting; interstate commerce and foreign. commerce, which transactions involved the proceeds of speci?ed- unlawful activity, that is, the scheme to commit wire fraud in violation of Title 18, United States Code, Section 1343,..knowing that the transactions were designed in Whole or in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds (if-Speci?ed unlanul activity, and that while conducting and attempting to. conduct such ?nancial "transactions, knew that the property involved in? the ?n-anci-altransactions represented the 74 Case 4:16?cr?00385 Document 6 Filed in TXSD on 10/19/16 Page 75 of 81 proceeds of some farm ofunlaw?ll activity, in violation of Title 18, United States Code, Section - Allin violation of "l United States Code, Sections 1956(h) and 7.5 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 76 of 81 COUNT FOUR 18 U.S.C. 15.42 (False Statement in Application for- Passport) Otter about April 29, 2008,?within the Southern District of'Texas, SUNNY MAHASHANKAR OSHI ISHWARLAL did. willfully and lmowingl'y makieafalse statement-in an application for apassp'ort'with intent to induce and secure. for his-own use the issuance of a passport under'the authority of the United States, contrary to the laws regulating the issuance of such passports and th'eirul'es prescribed pursuant to such laws, in that__in such U.S. Passport Book application the defendant stated ?no? to the quest-ion of whether. he had ever used a different name, which statement he knew to be false, in violation of Title 1.8, United States. Code, Section 1.542. 76' Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 77 of 81 COUNT FIVE 18. U3.S.C. 11542 (False Statement: in Use of Passport) 1. On or about October 5, 2010, within the Southern Distri-Ct of Texas, SUNNY MAHASHA-NKAR JOSHI a;k.a. did willfully and knowingly use and attempt to use any passport, theissue of which was secured in any way by reason of any false-statement, namely-that in art-application for a US. Car-d the defendant provided passport number 444824645, which the defendant knew to be the nmnber of a passport fraudulently obtained, in violation of Title 18, United States Code, Section 1542. 77 Case Document 6 Filed in TXSD on 10/19/16 Page 78 of 81 orfeiturei Allegations. NOTICE OF CRIMINAL (18 use. and 28 use. 1. Pursuant t-oTitle "185-, United States Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c), the Uni-ted States gives notice to the defendants charged in Counts One, Two, Four and Five of this Indictment, that upon conviction of the conspiracy Charged in Count One, the Wire fraud conSpi'racy charged in Count Two, or a violation of 18 ?'15:42 as charged in Counts Four-and Five, all property, real orpersonal, which constitutes or is derived from proceeds traceable to such offenses, is subject to forfeiture. NOTICE on CRIMINAL (reuse. 2. Pursuant to Title 18, United States Code, Section the United States gives notice to the defendants charged in Count One that upon conviction of a conspiracy to violate 18 U..S..-C. 10282 or 18 U3.SV.C. ?1029, all property constituting, or.derived from, proceeds, obtained. directly or indirectly, as-a result of such conSp'iracy is subject to forfeiture. NOTICE OF CRIMINAL FORFEITURE 982(a)(1)) 3. Pursuant to Title 18, United States Code, Section the United States - gives notice'to the defendants-charged in Gaunt Three that upon conviction ofa money laundering conspiracy in violationof 18 U.S.C. all property, real or personal, involved in such conspiracy, and all property traceable to such preperty, is subject to forfeiture. 78 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 79 of 81 (1-8 use. 4. Pursuantto Title318, United States Code, Section the United States gives OSHI, a.k.a. upon. cenviction of a violation of Title 18, United States Code, Section 1542 as charged in Counts Four-and Five, the following is subject to forfeitme: all conveyances, including vessels, vehicles, and aircraft, used in the commission of the effense(s); (ii) all real and personal property that constitutes, or is derived from or is traceable to the proceeds obtained directly or indirectly from the commission of the and all real andpersonal. Used to facilitate, or intended to be used to facilitate, the commission of the offense(s). Money Judgment 5. jDefendant's-qare noti?ed that upon -.eon-v.ietion, a money judgment may be: imposed equal to the tetal value of the property subject to forfeiture. I I Substitute Assets 6. Defendants are noti?ed that in the "event thatproperty Sabject to forfeiture, as a result ofany' act or omission. of defendants, cannot be located upon the exercise of due diligence; (ii) has been transferred. or sold to, or deposited with, a third party; has-been placed beyond the jurisdiction of the court; 79 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 80 of 81 has been substantially diminished in value; or (V) has been commin-gjled with other property that cannot be divided without dif?culty, the United States will seek to forfeit any other property of the defend-ants up to the total value of the property subject to forfeiture pursuant to Title 21-, United States Code, Section 853(p), as incorporated by reference in Title 18, United States Code, Section 982(b) and Title 28:, United States Code, Section 24610;). A TRUE BILL: ORIGINAL SIGNATURE ON FILE POREPERSON KENNETH MAGIDSON UNITED STATES ATTORNEY cf 7 7G M. Assistant United States Attorney?s. LESLIE R. CALDWELL ASSISTANT . .TTORNEY GENERAL- HOP 7 DS 1. MICHAEL SHECKELS Trial Attorneys US. Department of Justice Criminal Division, Human Rights and Special Prosecutions- 80 Case 4:16-cr-00385 Document 6 Filed in TXSD on 10/19/16 Page 81 of 81 Trial omey US, Department of Justice Criminal Division, Asset Forfeiture-andMoney Laundering Houston, Texas 7 October 19., .201 6 8'1