Case ECF No. 1 filed 04/18/19 PageID.1 Page 1 of 27 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION Case22z19-cr-20246 UNITED STATES OF AMERICA, Judge: Hood, Denise Page MJ: Patti, Anthony P. Filed: 04?18-2019 At 04:44 PM Plaintiff, SEALED MATTER (dat) D-l CONOR FREEMAN D-Z RICKY D-3 COLTON JURISIC - Vic: 18 U.S.C. 1349 D-4 REYAD GAFAR ABBAS 18 U.S.C. 1343 D-S GARRETT ENDICOTT 18 U.S.C. 1028A(a)(1) D-6 RYAN STEVENSON 18 U.S.C. 2 Defendants. INDIC TMEN THE GRAND JURY CHARGES: GENERAL ALLEGATION At all times relevant to this Indictment: l. ?The Community? was a loosely organized group of individuals dedicated to online identity theftl A subset of The Community focused on the theft of such as Bitcoin, LiteCoin, and Ethereum. Case ECF No. 1 filed 04/18/19 PageID.2 Page 2 of 27 2. Members of The Community planned and organized their activities on various online forums and over diverse channels of communication. Broader discussions?such as discussing the manner and means of attacks generally, and networking among The Community?s members?typically took place on forums such as ?OGUsers? and ?Hackforums.? Flaming and execution of speci?c attacks, as well as victim selection and recruiting, usually took place via platforms such as Discord, Skype, Signal, Wickr, and Telegram. 3. The Community engaged in Hijacking,? or Swapping.? This tactic enabled The Community to gain control of a victim?s mobile phone number by linking that number to a subscriber identity module card controlled by The Community?resulting in the victim?s phone calls and short message service messages being routed to a device controlled by a member of The Community. 4. Once The Community had control of a victim?s phone number, it was leveraged as a gateway to gain control of online accounts such as the victim?s email, cloud storage, and exchange accounts. Sometimes this was achieved by requesting a password-reset link be sent via SMS to the device controlled by The Community. Sometimes passwords were compromised by other means, and The Community?s device was used to receive two-factor authentication messages sent via SMS intended for the victim. -2- Case ECF No. 1 filed 04/18/19 PageID.3 Page 3 of 27 . 5. Speci?c members of The Community endeavored to gain control of a victim?s wallet or online exchange account and steal the victim?s funds. Stolen funds from a successful attack were divided among members of The Community that participated in that attack. 6. During these attacks, one or more members of The Community would appropriate the online identity of the victim, using means of identi?cation including the Victim?s name, email, and mobile phone number. 7. SIM Hijacking was often facilitated by bribing an employee of a mobile phone provider. 8. Other times, SIM Hijacking was facilitated by ?social engineering?: a member of The Community would contact a mobile phone provider?s customer service-? posing as the victim?and request that the victim?s phone number be swapped to a SIM card (and thus a mobile device) controlled by The Community. - 9. CONOR FREEMAN RICKY (D-2), COLTON JURISIC REYAD GAF AR ABBAS (D-4), GARRETT ENDICOTT (D- 5), and RYAN STEVENSON were members of The Community specializing in the theft of THE SCHEME TO DEFRAUD AND ITS PURPOSE 10. Beginning in approximately December of 2017 and continuing through approximately May of 2018, CONOR FREEMAN RICKY -3- Case ECF No. 1 filed 04/18/19 PageID.4 Page 4 of 27 (D-2), COLTON JURISIC REYAD GAFAR ABBAS (D-4), and GARRETT ENDICOTT (D-S), and RYAN STEVENSON (D-6) defendants herein, in the Eastern District of Michigan and elsewhere did? with the intent to defraud?knowingly participate in a scheme to defraud. The goal of this scheme was to obtain by means of materially false and fraudulent pretenses and representations. COUNT ONE (18 U.S.C. 1349 Conspiracy to Commit Wire Fraud) D-l CONOR FREEMAN D-2 RICKY D-3 COLTON URISIC D-4 REYAD GAFAR ABBAS D-5 GARRETT ENDICOTT D-6 RYAN STEVENSON 11. The allegations of paragraphs 1 through 10 are incorporated herein. 12. Beginning in approximately December of 2017 and continuing through approximately May of 2018, in the Eastern District of Michigan and elsewhere, defendants, CONOR FREEMAN RICKY (D-Z), COLTON JURISIC (D-3), REYAD GAFAR ABBAS (D-4), GARRETT ENDICOTT (D-5), and RYAN STEVENSON (D?6)?along with others known and unknown to the grand jury?did knowingly, intentionally, and willfully combine, conspire, confederate and agree to commit wire fraud. They -4- Case ECF No. 1 filed 04/18/19 PageID.5 Page 5 of 27 knowingly, will?illy, and with the intent to defraud?having devised and intending to devise a scheme and arti?ce to defraud, and to obtain money and property by means of materially false and fraudulent pretenses, representations, and promises, knowing such pretenses, representations, and promises were false and fraudulent when made?transmitted and caused to be transmitted (by means of wire communication) writings, signals, pictures, and sounds in interstate and foreign commerce for the purposes of executing such scheme and arti?ce, in Violation of Title 18, United States Code, Section 1343. OBJECT OF THE CONSPIRACY 13. The object of the conspiracy was the same as the purpose of the scheme to defraud set forth in paragraph 10 of this Indictment, which is incorporated by reference. MANNER AND MEANS OF THE CONSPIRACY 14. In furtherance of the conspiracy, and to accomplish its object, the methods, manner, and means that were used are described in paragraphs 1?9 of this Indictment and are incorporated by reference. All in Violation of Title 18, United States Code, Sections 1349 COUNT TWO (18 U.S.C. 1343 and 2 Wire Fraud, Aiding and Abetting) D-4 REYAD GAFAR ABBAS Case ECF No. 1 filed 04/18/19 PageID.6 Page 6 of 27 15. The allegations of paragraphs 1 through 14 are incorporated herein. 16. On or about February 15, 2018, members of The Community collaborated to activate a SIM card and fraudulently link it to the mobile phone number of GP, permitting them to pose as GP. 17. mobile provider was deceived by social engineering into transferring his mobile phone number to a device controlled by The Community. 18. Using mobile phone number as a starting point, one or more members of The Community proceeded to use identity to seize control of multiple online accounts?including an email address, a DropBox account, a exchange account, and a wallet. 19. One or more members of The Community transferred owned by GP, valued at approximately $114,705, to one or more wallets controlled by The Community. 20. On or about February 15, 2018, REYAD GAFAR ABBAS participated in in an online chat ?thhering the scheme to defraud GP that was transmitted in interstate commerce??including to and from the Eastern District of Michigan. 21. REYAD GAF AR ABBAS (D-4) accessed exchange account and transferred funds stolen from GP. 22. On or about February 15, 2018, in the Eastern District of Michigan and elsewhere, REYAD GAFAR ABBAS (D-4) and other members of The -6- Case ECF No. 1 filed 04/18/19 PageID.7 Page 7 of 27 Community did?with the intent to defraud?knowingly participate in a scheme to defraud GP by means of false or fraudulent pretenses, representations, or promises. 23. On or about February 15, 2018, in the Eastern District of Michigan and elsewhere, REYAD GAFAR ABBAS (D-4) and other members of The Community used transmission of writings, signs, signals, and sounds sent in interstate commerce in furtherance of the scheme to defraud GP. All in Violation of Title 18, United States Code, Sections 1343 and 2. COUNT THREE (18 U.S.C. 1028A(a)(1) and 2 Aggravated Identity Theft, 7 Aiding and Abetting) D-4 REYAD GAFAR ABBAS 24. The allegations of paragraphs 1 through 23 are incorporated herein. 25. On or about February 15, 2018, in the Eastern District of Michigan and elsewhere, REYAD GAFAR ABBAS and other members of The Community knowingly used identi?ers of GP for the purpose of executing the above described scheme to fraudulently obtain during and in relation to Violation of 18 U.S.C. Sections 1343 and 2. All in Violation of Title 18, United States Code, Sections 1028A(a)(l) and 2. Case ECF No. 1 filed 04/18/19 PageID.8 Page 8 of 27 COUNT FOUR (18 U.S.C. 1343 and 2 Wire Fraud, Aiding and Abetting) D-5 GARRETT ENDICOTT 26. The allegations of paragraphs 1 through 14 are incorporated herein. 27. On or about March 6, 2018, members of The Community collaborated to activate a SIM card and fraudulently link it to the mobile phone number of TH, permitting them to pose as TH. 28. Using mobile phone number as a starting point, one or more members of The Community proceeded to use identity to seize control of multiple online accounts?including an email account, a Twitter account, exchange accounts, and a wallet. 29. One or more members of The Community transferred owned by TH, valued at approximately $4,929.37, to one or more wallets controlled by The Community. 30. On or about March 6, 2018, GARRETT ENDICOTT participated in an online chat and voice call ?lrthering the scheme to defraud TH that was transmitted in interstate commerce?including to and from the Eastern District of Michigan. Case ECF No. 1 filed 04/18/19 PageID.9 Page 9 of 27 31. GARRETT ENDICOTT role in The Community was to research Victims and to provide personally identi?able information (PII) associated with Victims to facilitate the theft of their identities. 32. On or about March 6, 2018, in the Eastern District of Michigan and elsewhere, GARRETT ENDICOTT (D-5) and other members of The Community did?with the intent to defraud?knowingly participate in a scheme to defraud TH by means of false or fraudulent pretenses, representations, or promises. 33. On or about March 6, 2018, in the Eastern District of Michigan and elsewhere, GARRETT ENDICOTT (D-5) and other members of The Community used transmission of writings, signs, signals, and sounds sent in interstate commerce in furtherance of the scheme to defraud TH. All in Violation of Title 18, United States Code, Sections 1343 and 2. COUNT FIVE (18 U.S.C. 1028A(a)(1) and 2 Aggravated Identity Theft, Aiding and Abetting) D-5 GARRETT ENDICOTT 34. The allegations of paragraphs 1 through 14 and 26 through 33 are incorporated herein. 35. On or about March 6, 2018, in the Eastern District of Michigan and elsewhere, GARRETT ENDICOTT (D-4) and other members of The Community, -9- Case ECF No. 1 filed 04/18/19 Page 10 of 27 knowingly used identi?ers of TH for the purpose of executing the above described scheme to fraudulently obtain during and in relation to violation of 18 U.S.C. Sections 1343 and 2. All in violation of Title 18, United States Code, Sections 1028A(a)(1) and 2. COUNT SIX (18 U.S.C. 1343 and 2 Wire Fraud, Aiding and Abetting) D- 1 CONOR FREEMAN RICKY D-3 COLTON JURISIC 36. The allegations of paragraphs 1 through 14 are incorporated herein. 37. On or about May 7, 2018, members of The Community collaborated to activate a SIM card and fraudulently link it to the mobile phone number of JP, permitting them to pose as JP. 38. An employee of a mobile phone provider was bribed by JD, a member of The Community, to transfer the mobile phone number of JP to a SIM card controlled by The Community. 39. In or about May of 2018, JD paid the bribe via LocalBitcoins.com and PayPal, using Wire transmissions sent in interstate commerce originating within the Eastern District of Michigan. 40. Using mobile phone number as a starting point, one or more members of the The Community proceeded to use identity to seize control of multiple -10- Case ECF No. 1 filed 04/18/19 PageID.1l Page 11 of 27 online accounts?including an email account, a Twitter account, a exchange account, and a wallet. 41. One or more members of The Community transferred owned by JP, valued at approximately $1,669.56, to one or more wallets controlled by The Community. 42. On or about May 7, 2018, CONOR FREEMAN participated in online chats furthering the scheme to defraud JP that were transmitted in international commerce. 43. CONOR FREEMAN (D-1) provided one or more members of The Community PH of JP that was used to facilitate the attack. 44. On or about May 7, 2018, RICKY (D-2) participated in an online chat furthering the scheme to defraud JP that was transmitted in international commerce. 45. RICKY (D-2) coordinated with JD to further the scheme by prompting JD to bribe an employee of a mobile phone provider to swap the phone number of JP to a device controlled by the Community. 46. The coordination between HANDSHUMACHER and JD was done via an messaging application that transmitted signals in interstate commerce?~including to and from the Eastern District of Michigan?on or about May 7, 2018. -11- Case ECF No. 1 filed 04/18/19 PageID.12 Page 12 of 27 47. On or about May 5, 2018, COLTON JURISIC (D-3) participated in an online chat ?lrthering the scheme to defraud JP that was transmitted in international commerce. 48. COLTON JURISIC provided one or more members of The Community with PII of JP that was used to facilitate the attack. 49. In or about May of 2018, in the Eastern District of Michigan and elsewhere, CONOR FREEMAN RICKY (D-2), COLTON JURISIC and other members of The Community did?with the intent to defraud?knowingly participate in a scheme to defraud JP by means of false or fraudulent pretenses, representations, or promises. 50. In or about May of 2018, in the Eastern District of Michigan and elsewhere, CONOR FREEMAN RICKY COLTON JURISIC (D-3), and other members of The Community did use or cause the use of transmission of writings, signs, signals, and sounds sent in international and interstate commerce in furtherance of the scheme to defraud JP. All in Violation of Title 18, United States Code, Sections 1343 and 2. -12- Case ECF No. 1 filed 04/18/19 PageID.13 Page 13 of 27 COUNT SEVEN (18 U.S.C. 1028A(a)(l) and 2 Aggravated Identity Theft, Aiding and Abetting) CONOR FREEMAN RICKY COLTON JURISIC 51. The allegations of paragraphs 1 through 14 and 36 through 50 are incorporated herein. 52. In or about May of 2018, in the Eastern District of Michigan and elsewhere, CONOR FREEMAN RICKY (D-2), COLTON JURISIC (D-3), and other members of The Community knowingly used identi?ers of JP for the purpose of executing the above described scheme to fraudulently obtain during and in relation to Violation of 18 U.S.C. Sections 1343 and 2. All in Violation of Title 18, United States Code, Sections 1028A(a)(l) and 2. COUNT EIGHT (18 U.S.C. 1343 and 2 Wire Fraud, Aiding and Abetting) REYAD GAFAR ABBAS 53. The allegations of paragraphs 1 through 14 are incorporated herein. -13- Case ECF No. 1 filed 04/18/19 PageID.14 Page 14 of 27 54. On or about May 9, 2018, members of The Community collaborated to activate a SIM card and fraudulently link it to the mobile phone number of AL, permitting them to pose as AL. 55. An employee of a mobile phone provider was bribed by JD, a member of The Community, to transfer the mobile phone number of AL to a SIM card controlled by The Community. 56. In or about May of 2018, JD paid the bribe via LocalBitcoins.com and PayPal, using Wire transmissions sent in interstate commerce originating within the Eastern District of Michigan. 57. Using mobile phone number as a starting point, one or more members of The Community proceeded to use identity to seize control of multiple online accounts?including an email account, a Skype account, and a exchange account. 58. One or more members of The Community transferred owned by AL, valued at approximately $55,493.76, to one or more wallets controlled by The Community. 59. On or about dates between May 9, 2018 and May 13, 2018, REYAD GAFAR ABBAS (D-4) participated in online chats furthering the scheme to defraud AL that were transmitted in interstate commerce?including to and from the Eastern District of Michigan. -14- Case ECF No. 1 filed 04/18/19 PageID.15 Page 15 of 27 60. REYAD GAFAR ABBAS (D-4) accessed email account to facilitate the attack and transferred ?Jnds stolen from AL. 61. In or about May of 2018, in the Eastern District of Michigan and elsewhere, REYAD GAF AR ABBAS (D-4) and other members of The Community did? with the intent to defraud?knowingly participate in a scheme to defraud AL by means of false or fraudulent pretenses, representations, or promises. 62. In or about May of 2018, in the Eastern District of Michigan and elsewhere, REYAD GAF AR ABBAS and other members of The Community used or caused the use of transmission of writings, signs, signals, and sounds sent in interstate commerce in furtherance of the scheme to defraud AL. All in Violation of Title 18, United States Code, Sections 1343 and 2. (18 U.S.C. 1028A(a)(1) and 2 Aggravated Identity Theft, Aiding and Abetting) D-4 REYAD GAFAR ABBAS 63. The allegations of paragraphs 1 through 14 and 53 through 62 are incorporated herein. 64. In or about May of 2018, in the Eastern District of Michigan and elsewhere, REYAD GAFAR ABBAS (D-4) and other members of The Community knowingly used identi?ers of AL for the purpose of executing the above -15- Case ECF No. 1 filed 04/18/19 PageID.16 Page 16 of 27 described scheme to fraudulently obtain during and in relation to violation of 18 U.S.C. Section 1343 and 2. All in violation of Title 18, United States Code, Sections 1028A(a)(1) and 2. COUNT TEN (18 U.S.C. 1343 and 2 Wire Fraud, Aiding and Abetting) 1 CONOR FREEMAN RICKY COLTON JURISIC 65. The allegations of paragraphs 1 through 14 are incorporated herein. 66. On or about May 15, 2018, members of The Community collaborated to activate a SIM card and fraudulently link it to the mobile phone number of DM, permitting them to pose as DM. 67. An employee of a mobile phone provider was bribed by ID, a member of The Community, to provide PII of DM that enabled a member of The Community to impersonate DM and convince a customer service representative to transfer the mobile phone number of DM to a SIM card controlled by The Community. 68. In or about May of 2018, I paid the bribe Via LocalBitcoins.com and PayPal, using wire transmissions sent in interstate commerce originating within the Eastern District of Michigan. 69. Using mobile phone number as a starting point, members of The Community proceeded to use identity to seize control of multiple online -16- Case ECF No. 1 filed 04/18/19 PageID.17 Page 17 of 27 accounts?including an email account, cloud storage accounts, and a wallet. 70. One or more members of The Community transferred owned by DM, valued at approximately $100,000, to wallets controlled by members of The Community, including CONOR FREEMAN RICKY (D-2) and COLTON JURISIC (D-3). 71. On or about May 15, 2018, CONOR FREEMAN RICKY and COLTON URISIC participated in an online chat furthering the scheme to defraud DM that was transmitted in international and interstate commerce?including to and from the Eastern District of Michigan. 72. CONOR FREEMAN provided one or more members of The Community with PII of DM that was used to facilitate the attack. 73. CONOR FREEMAN transferred ?lnds stolen from DM. 74. COLTON JURISIC (D-3), provided one or more members of The Community with PII of DM that was used to facilitate the attack. 75. On or about May 15, 2018, in the Eastern District of Michigan and elsewhere, CONOR FREEMAN RICKY COLTON JURISIC (D-3), and other members of The Community did?with the intent to -17- Case ECF No. 1 filed 04/18/19 PageID.18 Page 18 of 27 defraud?knowingly participate in a scheme to defraud DM by means of false or fraudulent pretenses, representations, or promises. 76. On or about May 15, 2018, in the Eastern District of Michigan and elsewhere, CONOR FREEMAN RICKY (D-Z), COLTON JURISIC and other members of The Community did use or cause the use of transmission of writings, signs, signals, and sounds sent in international and interstate commerce in furtherance of the scheme to defraud DM. All in Violation of Title 18, United States Code, Sections 1343 and 2. COUNT ELEVEN (18 U.S.C. 1028A(a)(1) and 2 Aggravated Identity Theft, Aiding and Abetting) 1 CONOR FREEMAN D-2 RICKY D-3 COLTON JURISIC 77. The allegations of paragraphs 1 through 14 and 65 through 76 are incorporated herein. 1 78. On or about May 15, 2018, in the Eastern District of Michigan and elsewhere, CONOR FREEMAN RICKY COLTON JURISIC and other members of The Community knowingly used identifiers of DM for the purpose of executing the above described scheme to -18- Case ECF No. 1 filed 04/18/19 PageID.19 Page 19 of 27 fraudulently obtain during and in relation to Violation of 18 U.S.C. Section 1343 and 2. All in Violation of Title 18, United States Code, Sections 1028A(a)(1) and 2. COUNT TWELVE (18 U.S.C. 1343 and 2 Wire Fraud, Aiding and Abetting) D-l CONOR FREEMAN D-2 RICKY 79. The allegations of paragraphs 1 through 14 are incorporated herein. 80. On or about May 16, 2018, members of The Community collaborated to activate a SIM card and fraudulently link it to the mobile phone number of SS, permitting them to pose as SS. 81. An employee of a mobile phone provider was bribed by JD, a member of The Community, to facilitate the transfer of the mobile phone number of SS to a SIM card controlled by The Community. 82. In or about May of 2018, JD paid the bribe Via LocalBitcoins.com and PayPal, using wire transmissions sent in interstate commerce originating within the Eastern District of Michigan. 83. Using mobile phone number as a starting point, members of The Community proceeded to use identity to seize control of multiple online -19- Case ECF No. 1 filed 04/18/19 PageID.20 Page 20 of 27 accounts?including an email account, an Evernote account, exchange accounts, and wallets. 84. One or more members of The Community transferred controlled and possessed by SS, valued at approximately $1,921,335.80, to one or more wallets controlled by The Community. 85. On or about May 16, 2018, CONOR FREEMAN (D-1) and RICKY (D-2) participated in an online chat furthering the scheme to defraud SS that was transmitted in international and interstate commerce?including to and from the Eastern District of Michigan. 86. CONOR FREEMAN transferred funds that were stolen from SS. 1 87. On or about May 16, 2018, in the Eastern District of Michigan and elsewhere, CONOR FREEMAN RICKY (D-2), and other members of The Community did?with the intent to defraud-?knowingly participate in a scheme to defraud SS by means of false or fraudulent pretenses, representations, or promises. 88. On or about May 16, 2018, in the Eastern District of Michigan and elsewhere, CONOR FREEMAN RICKY (D-2), and other members of The Community did use or cause the use of transmission of writings, signs, signals, and sounds sent in international and interstate commerce in furtherance of the scheme to defraud SS. -20- Case ECF No. 1 filed 04/18/19 PageID.21 Page 21 of 27 All in Violation of Title 18, United States Code, Sections 1343 and 2. COUNT THIRTEEN (18 U.S.C. 1028A(a)(1) and 2 Aggravated Identity Theft, Aiding and Abetting) D?l CONOR FREEMAN RICKY 89. The allegations of paragraphs 1 through 14 and 79 through 88 are incorporated herein. 90. On or about May 16, 2018, in the Eastern District of Michigan and elsewhere, CONOR FREEMAN RICKY (D-2), and other members of The Community knowingly used identi?ers of SS for the purpose of executing the above described scheme to fraudulently obtain during and in relation to Violation of 18 U.S.C. Section 1343 and 2. All in Violation of Title 18, United States Code, Sections 1028A(a)(1) and 2. COUNT FOURTEEN (18 U.S.C. 1343 and 2 -- Wire Fraud, Aiding and Abetting) D-l CONOR FREEMAN COLTON JURISIC 91. The allegations of paragraphs 1 through 14 are incorporated herein. -21- Case ECF No. 1 filed 04/18/19 PageID.22 Page 22 of 27 92. On or about May 18, 2018, members of The Community collaborated to activate a SIM card and fraudulently link it to the mobile phone number of MT, permitting them to poSe as MT. 93. An employee of a mobile phone provider was bribed by JD, a member of The Community, to transfer the mobile phone number of MT to a SIM card controlled by The Community. 94. In or about May of 2018, JD paid the bribe via LocalBitcoins.com and PayPal, using wire transmissions sent in interstate commerce originating within the Eastern District of Michigan. 95. Using mobile phone number as a starting point, one or more members of The Community proceeded to use identity to seize control of multiple online accounts?including email and exchange accounts. 96. One or more members of The Community transferred owned by MT, valued at approximately $164,972.47, to one or more wallets controlled by The Community. 97. On or about May 18, 2018, CONOR FREEMAN (D-1) and COLTON JURISIC (D-3) participated in an online chat furthering the scheme to defraud MT that was transmitted in international and interstate commerce?including to and from the Eastern District of Michigan. -22- Case ECF No. 1 filed 04/18/19 PageID.23 Page 23 of 27 98. CONOR FREEMAN accessed email and exchange accounts, and transferred ?mds stolen from MT. 99. COLTON JURISIC provided one or more members of The Community with PII of MT that was used to facilitate the attack. 100. On or about May 18, 2018, in the Eastern District of Michigan and elsewhere, CONOR FREEMAN COLTON JURISIC and other members of The Community did?With the intent to defraud?knowingly participate in a scheme to defraud MT by means of false or fraudulent pretenses, representations, or promises. 101. On or about May 18, 2018, in the Eastern District of Michigan and elsewhere, CONOR FREEMAN COLTON JURISIC (D-3), other members of The Community did use or cause the use of transmission of writings, signs, signals, and sounds sent in international and interstate commerce in furtherance of the scheme to defraud MT. All in Violation of Title 18, United States Code, Section 1343 and 2. COUNT IFTEEN (18 U.S.C. 1028A(a)(1) and 2 Aggravated Identity Theft, Aiding and Abetting) D?l CONOR FREEMAN D-3 COLTON JURISIC -23- Case ECF No. 1 filed 04/18/19 PageID.24 Page 24 of 27 102. The allegations of paragraphs 1 through 14 and 91 through 101 are incorporated herein. 103. On or about May 17, 2018, in the Eastern District of Michigan and elsewhere, CONOR FREEMAN COLTON JURISIC (D-3), and other members of The Community knowingly used identi?ers of MT for the purpose of executing the above described scheme to fraudulently obtain during and in relation to violation of 18 U.S.C. Section 1343 and 2. All in violation of Title 18, United States Code, Sections 1028A(a)(1) and 2. FORFEITURE ALLEGATIONS 104. Upon conviction of Wire Fraud, in violation of Title 18, United States Code, Section 1343, as alleged in Counts this Indictment, and Conspiracy to Commit Wire Fraud, in violation of Title 18, United States Code, Section 1349, defendants shall forfeit to the United States, pursuant to 18 U.S.C. 981(a)(1)(C) together with 28 U.S.C. 2461(0), their right, title and interest in any property, real or personal, which constitutes or is derived from proceeds traceable to the offenses. 105. Upon conviction of Aggravated Identity Theft, in violation of Title 18, United States Code, Sections 1028(a)(1), as alleged in Counts this Indictment, defendants shall forfeit to the United States, pursuant to 18 U.S.C. 982(a)(2)(B) and 1028(b), their right, title, and interest in: any -24- Case ECF No. 1 filed 04/18/19 PageID.25 Page 25 of 27 property constituting, or derived from, proceeds the person obtained directly or indirectly, as a result of the offense(s), and (ii) any personal property used or intended to be used to commit the offense(s). 106. Forfeiture Money Judgment: Upon conviction of Wire Fraud, in violation of Title 18, United States Code, Section 1343, as alleged in Counts this Indictment, and/or Aggravated Identity Theft, a violation of Title 18, United States Code, Section 1028(a)(1), as alleged in Counts this Indictment, defendants shall be ordered to pay a sum of money equal to the amount of proceeds obtained as a result of their offense(s). 107. Substitute Assets: Pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title 18, United States Code, Section 982(b), Defendants shall forfeit substitute property, up to the value of the property subject to forfeiture as set forth above, if, by any act or omission of the defendant, property subject to forfeiture cannot be located upon the exercise of due diligence; has been transferred, sold to or deposited with a third party; has been placed beyond the jurisdiction of the court; has been substantially diminished in value; or has been commingled with other property which cannot be divided Without dif?culty. -25- Case ECF No. 1 filed 04/18/19 lPageID.26 Page 26 of 27 THIS IS A TRUE BILL Grand Jury oreperson GRAND JURY FOREPERSON MATTHEW SCHNEIDER UNITED STATES ATTORNEY John K. Neal John K. Neal Assistant United States Attorney Chief, White Collar Crime Unit imothv J. Wyse Timothy J. Wyse Assistant United States Attorney 21 1 West Fort Street, Suite 2001 Detroit, MI 48226 Timothy.Wyse@usdoj . gov (313) 226-9144 Dated: April 18, 2018 -25? Case ECF No.1 filed 04/18/19 PagelD.27 PonlmNAL United States District Court Eastern District of Michigan Criminal Case Judge: Hood, Denise Page MJ: Patti, Anthony P. NOTE: It is the responsibility of the AssistantU.S. Attorney signing this form ti Fi 9d2 04-18-2019 At 04:44 PM SEALED MATTER (dat) Companion Case Number: This may be a companion case based upon 57.10 Judge Assigned: Yes No Initials: Case Title: USA V- Conor Freeman, et al. County where offense occurred Wayne Check One: .Felony DMisdemeanor DPetty Indictment! Information no prior complaint. Indictment! Information based upon prior complaint [Case number: Indictment] Information based upon 57.10 [Complete Superseding section below]. Superseding to Case No: Judge: : Corrects errors; no additional charges or defendants. [j Involves, for plea purposes, different charges or adds counts. Embraces same subject matter but adds the additional defendants or charges below: Defendant name Charges Prior Complaint (if applicable) Please take notice that the below listed Assistant United States Attorney is the attorney of record for the above captioned case. April 18, 2019 Date 2?me fl. Wyse Assis ant United States Attorney 211 W. Fort Street, Suite 2001 Detroit, MI 48226-3277 Phone:(313) 226-9144 Fax: (313) 226-2873 E-Mail address: Timothy.Wyse@usdoj.gov Attorney Bar 1 Companion cases are matters in which it appears that (1) substantially similar evidence will be offered at trial, or (2) the same or related parties are present, and the cases arise out of the same transaction or occurrence. Cases may be companion cases even though one of them may have already been terminated. 5/16