COMMONWEALTH OF POLICE CRIMINAL COMPLAINT PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA. COUNTY OF: Montgomery vs. Magisterial atic Number. 382-06 MOJ:Hon, Henty Sehieson ‘Adress: $25 Montgomery Avenue Narbeth, PA 19072 C1 E-Miscemeanor Pending C2Folony ti hs Felony Pend Tlcwisdemeanor Surounding States] Distance: )2*rolony Surounding States C1AMiodemeanor Full i Dutisdemeancr No Extradition ‘Docket Number Date Fiod | OTNLiveScan Numbor | Complaievincident Number | SID ‘Reauest Lab Services? L BNG0O02I7 Ces BNO pos O20/1991 OB, aacioos 77 Go-Defendantis) El Fst Name dale Nae taatNane Gen EYE COLOR Cet (ave) OMAR (maroon) Cenk (Pinky COMUL (Mtuticatored) 1 Xxx (Unknown) State PA License Number 30 594 207 Expires: Suspended Oyves BNO DNA Location Thves_ (INO Stato | Hasmat | — Rogitration CommviVeh.r] School | Ot. NCIC Voh: Coge [Tg Plate # OC | stormy / ind] “on same as Vin Year Wake Wodet ‘Style Calor a Office ofthe aitorney for the Commonwealth [J Approved [1 Disapproved because: {rhe alomay Tortie Commonweal may requle Ul Tie COMPA, aTOaT WANT AMANO Bathe approve By Wie AMIGY Tar Te ConnmnGTWVSaNT POTTS fling. ‘See Pa.R.Crin.P. 607). fil a Sas) Slane ole ataney brine Commons) —————-_ "gras sf of ‘oa |, Justin E, Clarke _/ Gabriel J, Fabian Wane ofthe Afi) PA Office OF Attorney General ~(Gentty Department or Agency Represented and Poca! Subahislon) “(Polos Agency ORT Numba) do hereby state: (check appropriate box) 1. Bl accuse the above named defendant who lives at the address set forth above (CT accuse the defendant whose name is unknown to me but who is described as Gi accuse the defendant whose name and popular designation or nickname are unknown to me and whom have therefore desianated as John Doe or Jane Doe with violating the penal laws of the Commonwealth of Pennsylvania at__(413] 193 Belmont Ave 19401 and “[SUpaNSTON CoNRy multiple other locations within Montgomery Counties, in Montgomery & [22.&51] on or about 03/21/17 thra 03/24/17 Philadelphia County (Coury Code) OPC 412A — Rey, 0710 Page Lot _a POLICE CRIMINAL COMPLAINT Docket amber: Date Filed | OTWiLiveScan Number | Conpplainvincident Nnibot = tt Ee [Encooos oes is) Fiat Middle Last: Ikeem i Maurice | Starks ‘The acts committed by the acoused are described below with each Act of Assembly or statute violated, if appropriate. When there is more than one offense, each offense should be numbered chronologically (Sot forth a brio summary of the facts suflclont to advise the defendant ofthe nature of the efense(s) charged. citation tothe statutes) violated, without ‘nora ts not aufitont ne summary caso, you nwa cite the apecificeaction(s) and subsecton(s) ofthe statuto(s) or ordinance(s) allegedly vielatod. The lage ofthe victim atthe tine ofthe offense may be Included i Enown. In addition, eocial security numabors and financial Information e.g. PINs) should'not Be itad, if the Monti ofan account must be ostablisheg, st only tho last four digits, 204 PA.Gode §§ 219-1~ 243.7.) TT Attempt Ty Soleitation Ti Gonspiracy 199088 sa002a 18003 | = = TE 7 a [bPeCSA [13 BI. ee ‘ ese? _-Gansst ‘SaSHuIE (Tie) ~Comie Gade NCIC Offers Gods 4 DD Safety Zone CO Work Zone Statute Description (include the name of statute or ordinance): Dealing in proceeds of unlawiul activities ~ counts {through survellance video belag present, taking ‘Kets of the accused associated with this Offense: Commit financial ransaction with knowledge thatthe property involved, including stolen or Tegally obtained property, represents the proceeds of unlawful activity, the person acts withthe intent to promote the carrying on of the unlawful ofthe tnlawl activity TO WIT, Starks id drive co-defendant Smith fo meet a Pennsylvania State Trooper acting in an undercover capacly and reesive 2 Pennsylvania State Employees Visa debit card with the intention to commit fraudulent transactions. Starks then did accompany co-defendant Srith on humerous occasions to various leatlons to compete fraudulent gi card purchases and ATM transactions with co-defendant Smith Starks was observed and ecelving moneyiaft cards as the result of fraudulent gi card transaction. Jackson PSECU Account 03/29/17 (4 Counts) 03/24/17 (4 Counts) Carter PSECU Account 03/23/17 (8 Counts) TT Aime Ti Saictaton Ti Gonspiracy : 5 iasota weave i [Peed EA | TBPACSA |, Pees Soi Pastis (y) “Cans Giods NIC OtlensoCose eee Safety Zan0 1 Work Zone ‘Statute Description (Include the name of statule or ordinance): Receiving Stolen Property — 12 Counts ‘Reis of the accused associated with this Offense: Intentionally receives, retains, or dieposes of movable property of another knowing that it has been stolen, or believing that it has probably been stolen TO WIT: Starks and Co-defendant Smith were ‘observed on video surveillance cameras at multiple locations committing fraudulent transactions with a Pennsylvania State Employees Visa debit card and receiving US Currency or gift cards. Jackson PSECU Account 03/23/17 (A Counts) 03/24/17 (4 Counts) Cartor PSECU Account 03/23/17 ( Counts) G Solicitation | Bl Conspiracy fone a TAG) BM Teh cs 6 Ce oe ee 1 eat Zone wom zone Statute Description (include the name of statute or ordinance): Access Device Fraud — 13 Counts ‘als of the accused associated with this Offense: Uses an Access Device for another reason his use of the access device Is unauthorized by the issuer or the device holder TO WIT: Starks and Co-defendant Smith did use an access device {Pennsylvania State Employees Credit Union Visa debit card) for a reason (fraud) that Is unauthorized by the issuer (Pennsylvania State Employees Credit Union) Jackson PSECU Account 03/20/17 (4 Counts) 03/24/17 (4 Counts) Carter PSECU Account 09/28/17 (5 Counts) \OPC 412A — Rev. 07/10 Page _ofeg POLICE CRIMINAL COMPLAINT Docket Number: | Data Filed: [ OTNiLiveScan Number ‘Gomplaintleident Namber oF u [BNGOOOAIT : iat Ti tast x Ikeem. Maurice Starks “The acts committed by the accused are described below with each Act of Assembly or statute violated, if appropriate. When there is more than one offense, each offense should be numbered chronologically. {Sot forth a brief summary ofthe facts sufciont to advige the detordant ofthe natur of ie ofense(s) charged, A cltatlon tothe statut(s) violated, without voora isnt eafclnt ra summary case, you must cite tho specie seetlon() and subsaction(s) of the statute) or ordinanco(s) allegedly vilated, The meee the victim at the tne ofthe etfense may bo Included i Known. In adaltion, social security numbers an financial information (o.9 PINS) should not ty ofan account must be tablished, het only to last four cts, 204 PA.Gade §§ 213.1 ~ 213.7) [Dr Soteitation Ti Conepiracy 489024 18908 le de Ns ‘Couns [NCIC Offense Code 1 Safety Zone Di Wotk Zone ee ‘UCRIMDRS Coat i A Slatule Description (include the name of statute or ordinance): Affempt - Access Device Fraud — 4 Counts ‘Kals of the accused associated with this Offense: Uses an Access Device for another reason his use of the access device Is unauthorized by the issuer or the device holder to wit: Starks and Co-defendant Smith did also attempt fo use an access device (Pennsylvania State Employees Credit Union Visa debit card) for a reason (fraud) that is unauthorized by the issuer (Pennsylvania State Employees Credit Union) however these transactions were block by the issuer (Pennsylvania State Employees Credit Union). Cartor PSECU Account 03/23/17 (2 Counts) 03/24/17 (2 Counts) seeeeceseecreee Ti Soietaiion ~ TE Conspiracy 189024, 18903, SESS Peas Gade NCIC Offense Code UCRINIERS Code 1 safety Zone Cl Work Zone Slalule Description (include the name of statute or ordinance): Identity Theft — 13 Counts ‘Acts of the accused associated with this Offense: Possess or uses, through any means, identifying information of another person without the consent ofthat other person to further any unlawful purpose TO WIT: Starks and Co-defendant Smith did use the identity of “ava Carter” and "Nofeese Jackson’ while completing fraudulent transactions with Pennsylvania State Employees Credit Union Visa debit cards. Jackson PSECU Account 0229/17 (4 Counts) 03/24/17 (4 Counts) Carter PSECU Account 03/28/47 (5 Counts) Ba Attempt 1D Solicitation 1 Conspiracy fa00ra : osm $8008 ane ere sa a es Susan PRSeu TIC) Cane teasd "NG Oferan Cote 1 satey zene Work zone he name of staiule or ordinance). Attempt Identity Theft — 4 Counts ‘Rais ofthe accused associated with this Offense: Possess of uses, through any means, identifying information of another person without the consent of that other person to further any uniawful purpose TO WIT Starks and Co-defendant Smith did ‘attempt to use the identity of ‘Ava Carter’ and "Nefeese Jackson’ while completing fraudulent transactions with Pennsylvania State Employees Credit Union Visa debit cards however these transactions were blocked by the issuer (Pennsylvania State Employees Credit Union). Carter PSECU Account 03/28/17 (2 Counts) 03/24/17 (2 Counts) {OPC412A—Rev. 0710 Page ofINAL COMPLAINT iene Number) Doekot Number — ‘OTWiLiveScan Number Wide: Last Maurice _ Starks ‘The acts committed by the accused are described below with each Act of Assembly or statute violated, if appropriate. When there is more than one offense, each offense should be numbered chronologically. {Sat ferth novi summary ofthe face ufflfont to aéviee te defendant of he natre ofthe offences) charged, A ciation tothe atatutta violated, without tecte’ts net sutelont ina summery case you must elle the specifi sections) and subsocton() of the etatt(s) or ordnanco() allegedly violated. The ee th victim at he tne of th ones may be Included known n aceon, socal secu numbers and nancial information (og PING) should not Be itd. the dently of ah account must be cetallahed, let onl thos four digs. 204 PA Code 65 249. ~ 243.7) | Monet Tr Solicitation TH Conspiracy 18901 18902 49903 e as ie eos PA Sit ite) Gade NCIC Offense Cede UCRINIBRS Code 1 Satety Zone 1 Work Zone idapplica a ‘Statute Description (include the name of statute or ordinance): Theft by Deception ~ 13 Counts ‘Acie of the accused associated with this Offense: Creates or reinforces a false impression, Including false Impressions as to law, ‘valu, intention or other stato of mind TO WT: Starks and Co-defendant Smith were observed on video surveillance cameras at ‘multiple locations completing fraudulent transactions with two separate Pennsylvania State Employees Visa debit cards and receiving US Currency or gift cards as a result of fraudulent transactions. Uackson PSECU Account 03/23/17 (4 Counts) 03/24/17 (4 Counts) Carter PSECU Account 03/23/17 (5 Counts) TI Solicitation Ci Conspiracy 189024 18.903 oe ee se eet “tones Cisatey zone | Work zone ‘Stalute Description (include the name of statute or ordinance). Alfempt — Theft by Deception ~ 4 Counts — ‘Reta of the accused associated with this Offense: Creates or reinforces a false impression, including false impressions as to aw, Value, intention or other state of mind TO WIT: Starks and Co-defendant Smith were observed on video surveillance cameras attempting to commit fraudulent transactions with two Pennsylvania State Employees Credit Union Visa debit cards however these transactions were blocked by the issuer (Pennsylvania State Employees Credit Union) Carter PSECU Account 03/2/17 (2 Counts) 03/24/17 (2 Counts) Bi Conspiracy 18.903 i eee i “Grade. "NCIC Offense Code. UGRINIERS Coss 1 Satey Zone 1 Work zone ‘Statute Description (Include the name of statute or ordinance): Conspiracy Theft by Deceiption ‘ats of the accused associated with this Offense: In that the Defendant on mullipte occasions did conspire with another person(s) to commit a crime, to wit, Theft by Deception, in that the Defendant intentionally obtained or withheld properly of Another with a value exceeding $2000 by creating or reinforcing @ false impression, including false impressions as to law, value, intention or other state of mind in violation of 18 Pa. C.S. A. § 3922(a)(1)(2) andlor (3). SOPC412A— Rev. 07710 Page of __te POLICE CRIMINAL COMPLAINT ‘Docket Number ‘OTRULNaSean Number Conpaieincident Number BNG000217 i Task Pee Mave Ce STARS 2. | ask that a warrant of arrest or a summons be issued and that the defendant be required to answer the charges | have made. 3. | verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code (18 Pa.C.S. § 4904) relating to unsworn falsification to authorities. 4, This complaint consists ofthe preceding page(s) numbered_1 through 5 . The acts committed by the accused, as listed and hereafter, were against the peace and dignity of the Commonwealth of Pennsylvania and were contrary to the Act(s) of the Assembly, or in violation of the statutes cited. {Before a warrant of arrest can be issued, an affidavit of probable cause m mpleted, sworn to before the issuing authority, and attached.) © LU ry $33 pet 3 cor 4 fan SYR (ate) [ Seoaidstnnies AND NOW, ontisdate QO _FMdy ZOE] | cetitythat tho empl ns boon eroperty completed and vei ‘An affidavit of probable cause must be completed before a warrant can be issued. __ 5 ¥el-of Feeney ea ara iste Court Name) Micron ae ‘OPC 412A — Rev. 07/10 Page S ofSed POLICE CRIMINAL COMPLAINT Docket Number: | DateFiled: [ OTNiLiveScan Number First - Middle: Last: Ikeem Maurice ae it AFFIDAVIT of PROBABLE CAUSE Your Affiant, Justin Clarke #533, (Affiant Clarke) is a sworn Special Agent with the Pennsylvania Office of Attorney General (PAOAG), Bureau of Criminal Investigations Organized Crime Section, located at 1000 Madison Ave, Suite 310, Norristown, Pennsylvania 19403. Affiant Clarke has received training from the Pennsylvania State Police that includes the Class “A” certification course for Wiretapping and Electronic Surveillance conducted by the Pennsylvania State Police and Pennsylvania Office of the Attorney General in 2016, Your Affiant was certified to employ such techniques while conducting criminal investigations, maintaining “A” certification number A-5136. Since obtaining the Class "A" certification, your Affiant has participated in consensual investigations, Your Co-Affiant, Gabriel Fabian #542, (Affiant Fabian) is a sworn Special Agent with the Pennsylvania Office of Attorney General (PAOAG), Bureau of Criminal Investigations Organized Crime Section, located at 1000 Madison Ave, Suite 310, Norristown, Pennsyivania 19403. In February 2016, while monitoring a confidential Instagram Account regarding a separate investigation, Affiant Clarke noticed two separate Instagram users, who were using the Instagram handles "bankroliquaa" and “bankrollkiloooo," posting logos of banks and requesting other Instagram users to contact them (by “liking” photographs or private messaging through Instagram) f the other Instagram users maintained bank accounts with specific financial institutions. After reviewing numerous photographs posted on "bankroliquaa" and "bankrollkiloooo" Instagram's page, it was believed that both live and/or frequent the North Philadelphia area. The profile picture depicted under the "bankrollquaa’” Instagram account was later identified as Quadir James Burley (PA SID 41364408) (Quadir). The profile picture depicted under the "bankrollkiloooo" Instagram account was later identified as Shakour Shalik ‘Smith (PA33919310) (Smith). Instagram users "bankrollquaa” and "bankrollkiloooo" would typically remove or delete posts, which requested other Instagram members to contact about various banking institutions, after they were posted on their respective pages for only a few hours. On Thursday, 02/02/17, Affiant Clarke “liked” a post from “bankrollkiloooo" that requested Instagram users who maintain Pennsylvania State Employee Credit Union (PSECU) bank accounts. Through the “Instagram direct message” (Instagram DM) feature, "bankrollkiloooo” and Affiant Clarke, posing as Instagram user “avatherealonet" (a female), had an online conversation about using his PSECU bank account to make money. “Bankrolikiloooo” explained in the conversation that “avatherealone1” (Affiant Clarke) would have to provide her ‘online banking information, debit card and PIN number to "bankrallkiloooo” and that “bankrollkiloooo" would then mobile deposit a check into the account and then strategically make ATM withdrawals and gift card purchases ‘over two days. After the ATM withdrawals and gift card purchases were completed, "bankrollkiloooo” instructed “avatherealonet” (Affiant Clarke) to report his debit card stolen. “Bankrollkiloooo” also informed “avatherealonet” (Affiant Clarkey that once the ATM withdrawals and gift card purchases were completed; he would receive money in exchange for participation in this fraud scheme. ‘AOPC 411C — Rev. 07/10 Page 1 of 10On Thursday, 03/09/17, Supervisory Special Agent William Ralston (SSA Ralston), Affiant’s Clarke and Fabian met with PSECU Fraud Investigator Matthew Cassel (Cassel) and multiple employees from PSECU at PSECU headquarters. At this time, they discussed multiple fraud investigations that PSECU was currently investigating. At this meeting, PSECU management agreed to provide multiple PSECU fictitious bank accounts and PSECU debit cards to PAOAG investigators to assist in the investigation. On Tuesday, 03/21/17 at approximately 1504 hours, Affiant Clarke began an Instagram DM chat with Instagram user “bankrollquaa" under the Instagram account handle “nef_216g.” The following is the conversation that occurred through Instagram: 1804 Affiant Clarke - Was you the one to talk to if | got a bank acct nd wanna make money 1508 “bankroliqua” — Yes 1513 Affiant Clarke — Wassup wit it? | got an acct what do I need to do. | aint tryin.to get scammed 1514 “bankrollqua” — What bank you with and you won't 1516 Affiant Clarke -PSECU what do | need to do 1548 “bankrollquaa” - What's ya number 1553 “bankroliquaa” - ? 1605 Affiant Clarke — 215-613-4761 1633 Affiant Clarke -? Pennsylvania Office of Attomey General Narcotics Agent Nehemiah Haigler (NA Haigier) was assigned to act in an undercover role and pose as “Nefeese Jackson" while using the Instagram handle "nef__218g." PSECU provided a bank account and Visa debit (4305 8600 1603 0596) in the name of Nefeese Jackson. On Tuesday, 03/21/17, at approximately 1638 hours, NA Haigler received a phone call from 267- 348-7547. NA Haigler missed the phone call and returned the phone call to 267-348-7547. During this phone call an unknown male explained his plan to defraud PSECU to NA Haigler in the following manner: NA Haigler needed to provide his online banking information, his debit card and PIN Number; the unknown male would then deposit a check into his account, and subsequently withdraw the money. The unknown male explained that NA Haigler should report his debit card stolen once all of the transactions were completed and that afterwards they would split the money that the unknown male received. Shortly after this phone call, NA Haigler received the following text from 267-348-7547: 49 -Igotta do it before 6 -Bro NA Hagler responded: j ‘AOPC 411C - Rev. 07/10 Page 2 of 10-Yo trying to hit you from another jack On Tuesday, 03/24/17, at-approximately 1653 hours, NA Haigler called 267- 348-7547 and spoke with the same unknown male as the previous phone conversation. This phone call was recorded. During this phone call, NA Haigler and the unknown male agreed to meet at the in the parking lot of the Chick-Fil-A in the Cheltenham Mall. ‘The unknown male stated that he wanted to get all of NA Haigler’s banking information when they met. At this time, SSA Ralston, Affiant Clarke, Special Agent Joseph Chiaro (SA Chiaro), Narcotic Agents Ashley McAteer, Melissa Tamarro, and Affiant Fabian traveled to the Cheltenham Mall located at 2385 W. Cheltenham Avenue Wyncote, Pa 19095 and began conducting surveillance in the Chick-Fil-A parking lot. ‘On Tuesday, 03/21/17, from 1723 hours through 1905 hours, multiple text messages and phone calls were ‘exchanged between NA Haigler and the same unknown male using the 267-348-7547 phone number. (On Tuesday, 03/21/17, at approximately 1823 hours, NA Haigler arrived at the Chick-Fil-A. On Tuesday, 03/21/17, at approximately 1905 hours, NA Haigler called 267- 348-7547 and spoke with the unknown male. During this phone call the unknown male informed NA Haigler that he was at Chick-Fi-A. This phone call was recorded. At this time, Affiant Clarke and Affiant Fabian observed-a black Chevrolet four door sedan with tinted windows, a distinctive air freshener hanging from the rear view mirror, distinctive scuffs and scrapes on the vehicle, and bearing temporary Pennsylvania registration 2699803. (It was later determined that this vehicle was reported stolen from a location in Philadelphia on 11/04/16) (On Tuesday, 03/21/17, at approximately 1913 hours, the aforementioned Chevrolet sedan pulled near NA. Haigler's vehicle. At this time, a black male who had been identified as Quadir Burley (Quadir) exited the driver's seat of the aforementioned Chevrolet sedan and began speaking with NA Haigler outside of NA Haigler’s vehicle. Approximately half way through the conversation NA Haigler invited Qaudir into his Vehicle. An unidentified person was observed in the front passenger seal of the aforementioned vehicle. Quadir identified the passenger as his “girl.” The entire conversation between NA Haigler and Quadir was recorded. A brief summary of the conversation of the in person meeting can be summarized as follows: Quadir outlined how a check will be deposited into NA Haigler’s account. Quadir detailed how he strategically withdrawals the money out of the account on certain days because the bank's staff isn’t working, After the withdrawals are completed, Quadir will meet up with NA Haigler to split the profits. Quadir instructed NA Haigler to report his debit card lost/stolen to PSECU after Quadir is done making the transactions. Near the end of this, conversation NA Haigler provided Quadir the PSECU Visa debit card (4305 8600 1603 0596) in the name of Nefeese Jackson, the Pin # associated with debit card, the online banking user ID, and the online banking password, Quadir took the PSECU debit card and said, “...!'m about fo call my folks and get some paperwork now. The conversation ended at approximately 1920 hours. Quadir then entered the aforementioned Chevrolet sedan and departed the vicinity of the Cheltenham Mall Surveillance agents followed Qaudir's vehicie until he made an abrupt stop near the intersection of Broad Street and Lindley Street in Philadelphia. Surveillance was then terminated. ‘AOPC 411C— Rev, 07/10 Page 3 of 10(On Tuesday, 03/21/17, at approximately 1936 hours, Quadir’s vehicle made an abrupt stop near the intersection of Broad Street and Lindley Street. At this time, Quacir called NA Haigler from phone number 267-348-7547. This phone call was recorded. During this phone call, Quadir questioned NA Haigler about the passwords needed to og onto his PSECU bank account. ‘On Wednesday, 03/22/17, Matthew Cassel, PSECU Fraud Investigator informed Affiant Clarke through e-mail that the PSECU card assigned to Nefeese Jackson was used at the Sunoco gas station located at 2634 N. Broad ‘Street Philadelphia, Pa 19132 . The debit card was used for a purchase of $1.00; however the purchase was declined due to insufficient funds. The card was then used twice at an ATM, which is located at the same address of the Sunoco for the purpose of a balance inquiry. ‘On Wednesday, 03/22/17 at approximately 1636 hours, a check written from Wells Fargo Bank NA, Routing No. 031000503 Account No. 04411689 to Nefeese C. Jackson in the amount of $6,200.00 was mobile deposited into the PSECU account belonging to Nefeese Jackson. "Work" was written on the memo fine. (Definition of mobile deposit - Using the camera in a phone to deposit a check in a bank. An application in the phone takes a picture of the front and back of the check, and both images, along with the dollar value, are transmitted to the bank.) (On Thursday, 03/23/17 at approximately 1400 hours, Affiant’s Clarke & Fabian, Pennsylvania Office of Attorney General Supervisory SSA Ralston, SA Chiaro, Special Agent Kevin Schofield (SA Schofield) and Pennsylvania State Police Troopers Jovanna Brown (Tpr. Brown) Mark Salemo, Nick Scrivani, Ryan Smith, Jamie Sparenga met at the Pennsylvania State Police Belmont Barracks. At this time, Affiant Clarke and Affiant Fabian explained the investigation to everyone present. ‘pr. Brown was assigned to act in an undercover role and pose as “Ava Carter” while using the Instagram handle “avatherealonet,” PSECU provided a bank account and Visa debit (4305 8600 1691 1233) in the name of Ava M Carter. On Thursday, 03/23/17, at approximately 1518 hours, using the Instagram account handle “avatherealone1,” Affiant Clarke started the following conversation with Instagram user “bankrollkiloooo”: 4518 - CLARKE — Hey | got my new card, Can | get money today 1519 ~"bankrollkiloooo” — What card 1520 - CLARKE - My new PSECU card 1528 —"bankrolikiloooo” ~Yes = What's your number = (screenshot of Nefesse Jackson PSECU account) = Ijust did this one yesterday 1629 ~"bankrollkiloo00" - $6200 cleared today 1630 — bankrollkiloooo - I need ya number though don't like ig talk 1532- CLARKE —| want sum 1532 ~ bankrollkiloooo ~ What's your number AOPC 411C - Rev. 07/10 Page 4 of 102 -And Way = You be playing you played last time 1537 — CLARKE - 3024501533 Work =I gave u my number. This must be a scam, 1537 — bankrollkiloooo- A scam . Naw | just think you playing ganes 138 ~ Ciarke ~ (picture showing PSECU debit card) 4540 — bankrollkiloooo - Okay so Way I just texted you.. If we do it by 6 we can make $6200 .. 1841 —bankrolikilooco- Do you have online banking? - You'll have a $1000 today. “pankrollkiloooo” then began communicating with Affiant Clarke/Tpr. Brown via text messaging from cell phone number 267-630-1462. On Thursday, 03/23/17, at approximately 1550 hours, an unknown: male using phone number 267-630-1462, called Tpr. Brown at telephone number 302-450-1533. The unknown person asked Tpr. Brown how long she had the bank account, if she is able to mobile deposit, and what her spending limits are. ‘The unknown male requested “Tpr. Brown's online banking user name, password, and PIN number. The unknown male identified himself as “Keife.” This phone call was recorded, On Thursday, 03/23/17, at approximately 1557 hours, the same unknown male using phone number 267-630- 1462 called Tpr, Brown at telephone number 302-450-1533. During this phone call, the unknown male informed ‘pr. Brown that her account is ‘not enrolled.’ The unknown male talked about “Ava Carter’ trusting him. The unknown male instructed Tpr. Brown to logon to her PSECU through the website. This phone call was recorded. On Thursday, 03/23/17, at approximately 1619 hours, the same unknown male using phone number 267-630- 41462 called Tpr, Brown at telephone number 302-450-1533. Tpr. Brown informed the unknown person that she enrolled the account online, and the unknown male again asked for Tpr. Brown’s online banking user name and password. The unknown male stated that he had already signed onto Tpr. Brown's account. The unknown male instructed Tpr. Brown to call PSECU and have the mobile deposited set up. This phone call was recorded Through a text message, Tpr Brown and the unknown person agreed to mest at the “Chills parking lot at 175 East City Ave, Bala Cynwd, Pa 19004 at 1710 hours. On Thursday, 03/23/17, at approximately 1730 hours, a silver Nissan Altima bearing PA registration KHJ-3613 artived at the meet site. At this time, a B/M who was been identified as Shakour Smith (Smith) exited the aforementioned vehicle and approached and greeted Tpr. Brown. The vehicle was also occupied by two other B/M's who were later identified as Ikeem Starks (Starks) (driver) and Gregory Nathaniel Jackson (backseat passenger). Tpr Brown and Smith had a conversation that can be summarized as follows: ‘AOPC 411 - Rev. 07/10 Page § of 40‘Smith stated that hewanted to make Tpr. Brown feel comfortable. Smith identified himself as "Kiefe.” Smith stated that he wanted to answer any questions that Tpr. Brown had. Smith explained that he will mobile deposit a check into her PSECU bank account. The amount of the check would be $6,200.00. Smith would take a picture of the front of the check and back of the check to complete the mobile deposit. Smith was not sure if the check will clear right away, but the check would definitely clear by tomorrow. Smith talked about another account with which he was currently committing the fraud, (At this time, Smith was showing screenshot photographs to Tpr. Brown of banks accounts that upon which he had already completed this fraud scheme. It is believed that the account that he referenced and showed screenshot photographs was the Nefeese Jackson PSECU account.) Smith informed ‘Tpr. Brown that he would complete a $300.00 ATM withdrawal and then go to Walmart and purchase (3) three $500.00 gift cards. Smith guaranteed Tpr. Brown that if she did not get $1,000.00 that day, she would receive $1,000.00 by the next day. Smith informed Tpr. Brown that she can monitor the transactions on her account as. ‘Smith completed the transactions, Smith told Tpr. Brown that he would keep her posted. Smith told Tpr. Brown that they would split the money that will be obtained from this fraud scheme by stating, *.../’s just me and you, 1 get the check made, I pay them up front”, Smith instructed Tpr. Brown to call the bank and report the debit card stolen/lost after the transactions. The purpose of reporting the debit card stolen/lost would be to save Tpr. Brown from having to pay the money back. Smith stated that the bank will do a “petty investigation’ and see that it's @ male making the transactions and the bank won't take any further action. Smith stated, “... one thing is for sure, | have been doing this for a long time. I never had nobody go to jail...never. | work with a lot of people....I don't got no job." Tpr. Brown asked Smith if he did it one or two times. Smith responded, “Fuck one or two time, | have done it hundreds of times. | am a pro at what I do..." Smith stated that he is going to leave the meet site and go get the check. Smith told Tpr. Brown that he is from “North’. Smith talked about the possibility of having Tpr. Brown recruit people to participate in this fraud in the future. Smith told Tpr. Brown that he did , “probably 15 cards with them” (PSECU). Smith stated that he goes to Police and Fire ATMs to make ATM withdrawals. ‘The entire in person conversation between Smith and “Carter” (Tpr. Brown) was recorded. Near the end of this conversation Tpr. Brown provided the PSECU Visa debit card (4305 8600 1691 1233) belonging to Ava Carter to Smith. (On Thursday, 03/23/17, a check written from the Freedom Credit Union, Routing No, 236084751 Account No. 0060029733 to Ava M Carter in the amount of $5,400.00 was mobile deposited into the PSECU account belonging to Ava Carter. “Work” was written on the memo line, ‘On Monday, 03/27/17, Matthew Cassel, PSECU Fraud Investigator provided Affiant Clarke with a list of fraudulent transactions that occurred on the Ava Carter PSECU debit card number 4305 8600 1691 1233. The list of transactions are as follows: 03/23/17 19:25:33 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 ATM Withdrawal $280.00 ~ Transaction Blocked (On Thursday, 03/29/17, at 1942 hours, Smith sent Tpr. Brown (302-450-1533) a text message from 267-630- 1482 stating, “My phone on 1% trying to get it off so | need you to move fast”. At this time, Smith was trying to have Tpr. Brown cail PSECU and verify the purchases because the debit issued to Ava Carter was being declined.) (A surveillance photograph was obtained from Walmart that shows Shakour Smith at the ATM inside the Walmart at the above listed time and date) ‘AOPC 411C ~ Rev. 07/10 Page 6 of 1003/23/17 19:51:14 Subway Restaurant Attempted Purchase $14.56 03/23/17 20:13:05 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 ATM Withdrawal $80.00 03/23/17 20:13:44 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 ATM Withdrawal $200.00 03/23/17 20:14:33 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 ATM Withdrawal $200.00 Transaction Exceeded (For these Wal-Mart attempted/successful ATM transactions, Surveillance photographs were obtained from Walmart showing Shakour Smith inside the Wal-Mart store at the time of the successful ATM withdrawals) 03/23/17 20:20:20 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 - POS purchase $498.00 03/23/17 20:21:12 Wal-Mart Store #5103 4600 Roosevelt Boulevard Phitadelphia, Pa 19124 - POS purchase $498.00 03/23/17 20:22:00 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124- POS purchase $498.00 (For these Wal-Mart POS purchases, surveillance photographs were obtained from Wal-Mart showing Ikeem Starks completing gift card purchases.) 03/24/17 00:34:09 PNC Bank ATM (inside of WaWa) 193 Belmont Avenue Bala Cynwyd, Pa 19004. ATM Withdrawal 280.00 Permanent Restriction 03/24/17 00:38:09 PNC Bank ATM (inside of WaWa) 193 Belmont Avenue Bala Cynwyd, Pa 19004. ATM Withdrawal Inquiry (Surveillance video was obtained from inside the WaWa Store where the PNC Bank ATM is located. The video shows Shakour Smith and Ikeem Starks using two separate ATM machines at the same time, It should be noted that a PSECU debit card in the name of Nefeese Jackson was used at the same time. It appears that Starks received the $500.00 from the PNC Bank (WaWVa ATM) from the Jackson PSECU card, while Smith checked the balance on the Carter PSECU card Video surveillance shows Starks operating a silver sedan resembling the Nissan Altima that he was operating at the time of the undercover meet, Smith is a passenger in the vehicle.) 03/24/17 00:54:42 Wal-Mart Store #4687 275 N. Gulph Road King of Prussia, Pa 19406 POS Purchase §.78 Permanent Restriction (Surveillance photographs were obtained from Wal-mart showing Shakour Smith and Ikeem Starks standing at cash register around the time that this transactions was attempted.) (On 03/28/17, the check that was mobile deposited into Ava Carter’s account was returned due PSECU unable.to locate the account, thus creating a loss of approximately $1,780.00 for PSECU. AOPC 411¢— Rev. 07/10 Page 7 of 10On Thursday, 03/23/17 at approximately 0445 hours, Affiant Clarke and Affiant Fabian located the black Chevrolet sedan bearing temporary Pennsylvania registration 2699-803 in the vicinity of 1524 W. Lehigh Avenue Philadelphia, Pa 19132. At this time, Affiant Clarke and Affiant Fabian looked into the vehicle through the front windshield and observed a piece of paper that resembled an ATM receipt in the front cup holder. At this time, the car and VIN number were photographed. The VIN # was partially obscured. (2G1WGSE30D11***** ) (On Friday, 03/24/17 at approximately 1333 hours, NA Haigler attempted to call Quadir (287-348-7547). At this time, Quadir answered the phone call, NA Haigler and Quadir discussed the debit card transactions and Quadir informed NA Haigler that NA Haigler would receive $1,500.00 for participating in the fraud scheme. Quadir and NA Haigler agreed to meet early Sunday morning, 03/26/17. This phone call was recorded. (On Sunday, 03/26/17, NA Haigler attempted to call Quadir multiple times at telephone no. 267- 348-7547. After a few phone calls, it appeared that Quadir blocked NA Haigler’s phone because when NA Haigler attempted to call Quadir, the phone call would go directly to voice mail; however, when Quadir's phone number was called from a different phone, it would not go straight to voicemail. Affiant Clarke also attempted to contact Quadir “bankroliquaa’ through “Instagram Direct Messenger”. Once Affiant Clarke contacted Quadir from the Instagram account “nef__215g, it appeared that Quadir blocked that account, as Instagram user "nef__2159" could no longer view "bankroliquaa's” Instagram page. However, any other Instagram user was still able to view “pankrollquaa’s" Instagram page. ‘On Monday, 03/27/17, Matthew Cassel, PSECU Fraud Investigator provided Affiant Clarke with a list of fraudulent transactions that occurred on Nefeese Jackson PSECU debit card number 4305 8600 1603 0596. ‘The transactions are as follows: 03/21/17 19:48:29 Sunoco Store No. 0363328604 $1.00 NSF (not sufficient funds) (Surveillance video could not be obtained for this transaction) 03/21/17 19:49:55 2634-44 N. Broad Street -0.00 Invalid PIN Entry Balance Inquiry 03/24/17 19:20:23 2634-44 N. Broad Street — 0.000 Approved Balance Inquiry (Surveillance video could not be obtained for these transactions) 03/23/17 12:37:58 2201 Hunting Park Avenue Philadelphia $500.00 ATM Withdraw! (Surveillance could not be obtained for this transaction. This transaction occurred inside the 39” Philadelphia Police District; however the camera inside the district is'not currently operational.) 03/23/17 12:55:29 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 POS Purchase $497.95, 03/23/17 12:56:21 WalMart Store #5103 4600 Roosevelt Boulevard Phitadelphia, Pa 19124 POS purchase $497.95, 03/23/17 12:57:25 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 POS purchase $498.00 AOPC 411€ - Rev. 07/10 Page 8 of 10meet NA Haigler to receive the undercover PSECU Visa debit card. This vehicle was identified by the make, model, rims, tint, and temporary registration, At this time, Affiant Clarke notified Police Officers Carter and Alston of the presence of the aforementioned stolen vehicle. Officers Carter and Alston initiated a traffic stop on the aforementioned vehicle near the intersection of 16" Street and Lehigh Avenue. James Burley (James), Quadir's father was found to be operating the stolen vehicle. Will Bush (PA 25943404) ‘was found to be in the front driver's passenger seat. James was arrested by the Philadelphia Police Department and charged with offense related to driving the stolen vehicle (1614089335). James stated that the vehicle belonged to his son, Quadir. Shortly thereafter, Quadir arrived at the location of the traffic stop and retrieved papers related to the vehicle and handed them to Officer Carter. Your Affiants submits that the information contained herein is sufficient to provide probable cause for the issuance of an arrest warrant for Dealing in Unlawful Proceeds, Forgery, Access Device Fraud, Identity Theft, Theft by Unlawful Taking, Criminal Use of a Communication Facility & Bad Checks, |, Justin E, Clarke / Gabriel J. Fabian, BEING DULY SWORN ACCORDING TO THE LAW, DEPOSE AND SAY THAT THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT | D CORRECT. A THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. . (Signature of Affiant) Swom to me and subscribed beforeme _ “>O7_ day of m be — ZeZ2 7 «30- SD 30-1 Dee LAC —— _ Magisterial District Jucige My commission expires first Monday of January, ZOZ 2— SEAL AOPC 411C - Rev. 07/10 Page 10 of 10,Please provide the following information for each co-dofendant. dah Co-Defendant Data Sheet Desket Number: Dato Filed: ‘OTNiLIveScan Number L First IKEEM Wide: ast MAURICE STARKS, SHAKOUR SMITH (Name) 5450 WISSAHICKON AVENUE ‘Tome Street Address) PHILADELPHIA, PA 19144 (iy, Site, EZIP Codey Coetendant tL ‘Tratephone H NGOOO2 17s: QUADIR JAMES BURLEY Wario} 11524 W. LEHIGH AVENUE ‘CoDefendantt2 (Home Sieat AaaOSS) PHILADELPHIA, PA 19132 (Civ, State, & ZF Code) ‘ietephone CoDetendant# ‘Wamp ‘Home Stat Adarossy (Ciy, State, BZIP Codey eiepione # CoDefendant# Warned lore Stat Address) Tei, Stas, & HIP Coe) ‘CTetephane fy ‘AOPC 412A — Rev. 07/10 Page of __COMMONWEALTH OF POLICE CRIMINAL COMPLAINT PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA | COUNTY OF: Montgomery | vs. Magisterial District Number: 38-1-06 i | Mu: Hon, Henry Schireson DEFENDANT: __ (NAME and ADDRESS): | Address: 925 Montgomery Avenue Shakout ‘Smith ‘Narbeth, PA 19072 FsNane Theat Nene Go Telephone: (610) 664-5262 $450 Wissahickon Avenue y Philadelphia, Pa 19144 SEU SS NGIG Exiditfon Cove Type Pa 3 Feb Fu TD «Felony No ext 1 B-isdereanar Lined T1E-wisdemeanor Pending Dl2Fetony Led (16-Felony Pend, (Cc-Miscemeanor Surrounding States C] distance: O13elony Surrounding States) A-Misdemeanor Full D) D-Misdemeanor No Extradition = ae TIGATION INFORMATIONS =z z ‘Compiaintincident Number | SID ‘Roquost Lab Services? Date Flog BNGO002I7 Cl yes 69 No Docket Number ‘GENDER Dow 11/23/1990 [aaaipos 7 7 [co-befendantis) O 3 Male First Name ‘Widdle Name Last Name Gen. (Female | awa [RAGE wie cE asa aa Perawtciry —CTHssane Ti Nersepanie TI kno THewviGa; Cab Rwin) OlvGam Daueu Creme CARO Genny Eleiceasn Clorciomray macnn) Cox eonessy Coane ese “Daun onde stout) : : Ci atx aon Claw (ee) a0 grown) Diors (ores) Thor (ory | _ Chez eazy Car gam Cl enk en Eh nates Occ (Urinoun Sale PA [License Number 29 966 462 Eiplas: Suspended [EVES BNO | DwALocation Byes ON print Classifications. os BeS EE = ETI DERENDAN ET VERIGLE NEOAMATIONSE z i State | Hazmat | Rogistration ‘Commi Veh School] Oth. NCIC Veh. Code Re. Ch | stcneramury —/ nO] Ven samme as | fear | Make Wodel 7 haa a ha i Office of the attorney for the Commonwealth [] Approved [] Disapproved because! (ifs atari Torre CoMATROTWSaRA Tay VOGUE That TNS COMETS, ATTST WaPTaNTGHIGRVE, or Bot be AppTOVEE By We BOTY TOFU CORTAGRVGGIN Por To = sigue Meh A Gt Sh 20\y |, Justin B. Clarke _/ Gabriel J. Fabian Badge #533 / Badge #542 (ame of the Atfanty (PSPMPOETC “Assigned Aiant IO Number & Badge # PA Office Of Attorney General PA 0222400: (aenily Deparment or Agency a Pola Subawin) (Polen Agency ORI Number) do hereby state: (check appropriate box) 4. Bil accuse the above named defendant who lives at the address set forth above I I accuse the defendant whose name is unknown to me but who is described as Taccuse the defendant whose name and popular designation o nickname are unknown to me and whom | have therefore desianated as John Doe or Jane Doe with violating the penal laws of the Commonwealth of Pennsylvania at__ [413] 193 Belmont Ave 19401 and multiple other locations within Montgomery and Philadelphia Counties. “[SuRoMBONCoREy —TPraSS Ponca SUSaWEIoN———~ in Montgomery & (22&$1] on orabout 03/21/17 thru 03/24/17 Philadelphia County Teamniy Comey SOPC 412A Rev. 07/10 Page Tofa POLICE CRIMINAL COME ANT: Date Filed: | OTNILIveScan Number ‘Gomplainulneident Number = = it BNGODO2 (7 cS eae of Fist Wide: Last | Shakour ___| Shalit ‘Tstien_ aE i ‘The acts committed by the accused are described below with each Act of Assembly or statute violated, if appropriate, When there is more than one offense, each offense should be numbered chronologically {Get forth a brief summary ofthe facts sufficient to advso the dofendan of the nature of the offenso{} charge A citation tothe statutes) violated, without {oro is not euffelent. In. urmaryeaco, you must ile the spect secton(s) ard subeection(s) of to statute) or ordnanco(s) loge vielstod. Tho {age ofthe vitim at the tino ofthe ofonse may be included I Known In aditon, socal security numbers and fnencal Information (e.g PINS) should not bo sted tthe donty ofan account most be established, st only the last four sighs, 204 PA Cod §5 2431 213.) Tr Attempt TD Solicitation Ti Conspiracy 14901 ¥a9024 18003 2 ees AQ) Wreesa [is Ra Sibssa PA Sis le] Cuts Gras ROR Oe ee oat ne fone: cd mops Pee | Oi satoty Zo 1D Wore 2 ‘Statute Description (include the name of statute or ordinance): Dealing In proceeds of unlawful activities — 13 counts UCRNIBRS Code ‘Rats of the accused associated with this Offense: Commit a nancial vansaction with knowledge thatthe propery Involved, including sialon oF lMogally obtained property, ropresents the proceeds of unlawful ectvty, the person acts wth the Intont to promote tho carrying on of th uelawul ofthe Lunlawfl actidly TO WIT: Starks did dive co-defendant Smith to meet a Pennsylvania Stale Trooper acing in an undercover capacly and cecelve a PonrsyWvania Stato Employese Viea debit card with ihe intention to commit fraudulort trancactions. Smith thon dd accompany co-defendant Starks on numerous occasion to varous lcallons to eomlte fraudulent git card purchases and ATM transactions with co-defendant Starks. Smith was observed {trough surveillance video belng present and taking part in raudulont git care transactions Jackson PSECU Account 03/29/17 (4 Counts) 03/24/17 (4 Counts) Carter PSECU Account 03/23/17 (8 Counts). iRGHSAS] CT Aterint Scitation Ti Gonapiracy | (Offense. | 189074 [Piss 18903 o [By yater AG) 18PaCS.A [1 eae : Lead? Offenses Sac ‘Subsection PA Statute (Tile) Counts ‘Grade NCIC Offense Code TUGRUNIBRS Code fr Pammeor baa ee ae ee satay 2 | D wonz Statute Description (include the name of state of ordinance): Forgery ~ 1 count ‘Rais of the accused associated with this Offense: Utters any writing which of another without his authority TO WIT: Smith mobile deposited and or cauised a mobile deposit of a check to the Ava Carter Pennsylvania State Employees Credit Union bank account bearing signatures that were not created by Ava Carte. Carter PSECU Account 03/23/17 (1 count) inehoate™] C) Atompt EF Solicitation 1 Conspiracy we | 189014 taaaza fao0 4106 ACY) 18PaC.SA | 13 F3 : : ‘Oierseb Salen “Secor A Site (ile) cats Crass NeW Ofense Code UCRRIBRE Gogo BO) Dae eee foty Zone Zone _(itapplicabiey | Number Send eine Statute Description (include the name of statute or ordinancs): Access Device Fraud — 13 Counts ‘Acis of the accused associated with this Offense: Uses an Access Device for another reason his use of the access device = Unauthorized by the issuer or the device holder TO WIT: Smith and Co-defendant Starks did use an access device (Pennsylvania State Employees Credit Union Visa debit card) for a reason (fraud) that is unauthorized by the Issuer (Pennsylvania State Employees Credit Union) ~lackson PSECU Account O9/20AT (4 Counts) 08/24/17 (4 Counts) Carter PSECU Account O9720/7 (8 Counts) NOPE 412 — Rev. 07710 alienEJ POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: | OTNiLiveScan Number | Complaintincident Number mn | BNG000217 a ale task | Betenesot Nem Shakour Shalike_ Smit eceeeaatee| ‘The acts committed by the accused are described below with each Act of Assembly or statute violated, if appropriate. When there is more than one offense, each offense should be numbered chronologically. {Seton briaf summary of he acts ufc to ava the defendant fh ar ofthe oferty} charg Actin to he aut vist without ‘mor, isnot auffciant In a eummary caso, you must cite tho specific ecetion(s) and subscetion(s) of tho etatte(s) or ordinanco(s) alogodly violatod. Tho 23g0 of tho viet at het of tho otfonso may bo included known. in ation, social securty numbors and Grancial information (PINs) should not be ito the identity of an account must be established ist enly tho last four digits. 204 PA.Gode §§ 213.1~ 2137) ] Oi Solicitation Ti Conspiracy [vaso 14003 ACY) 18PaCs.A SBS ees Suneion TA Sia (Tie) Couns Gade NENG Ofonso Coe UCUNINS Gao 1 Safety Zone Cl Work zone Statute Description (include the name of stalule or ardinanes). Allempt - Access Device Fraud - 4 Counts ‘Aals of the accused associated with this Offense: Uses an Access Device for another reason his use of the acoass device is Unauthorized by the issuer or the device holder to wit: Smith and Co-defendant Starks did also attempt to use an access device (Pennsylvania State Employees Credit Union Visa debit card) for a reason (fraud) that is unauthorized by the issuer (Pennsylvania State Employees Credit Union) however these transactions were block by the issuer (Pennsylvania State Employees Credit Union). Ti Atompe 7 Solicitation Ti conspiracy 18901A 18.9024 PASabie (ie) Com Gide Fsetey zone | 1D Wik Zone “Statute Description (include the name of statute or ordinance): Identity Theft ~ 13 Counts “Acts of the accused associated with this Offense: Possess or uses, through any moana, iontiving information of another person without the Cconsont ofthat ather person to further any unlawful purpose TO WIT: Smith and Co-defendant Starks id use the lentty of “Ava Carer’ and "Nefeese Jackson’ while completing fraudulent transactions vith Ponnsyhania Siate Employees Groat Union Visa debit cards Jackson PSECU Account 03/23/17 (4 Counts) 03/24/47 (4 Counts) Carter PSECU Account 08/23/17 (5 Counts) RAT & Aenot El Solicitation Ti Conspiracy nse | 18007 yooh 12903 Olé — [4t30 dA 1WPACSA | 4 E3 E sae Ofte 7 Sacto PASille Tie) Com Grade — NCIC Dense Cade UGRATBRS Code i C1 Ssfety Zone. Cl Werk Zone ort _(itapplical Nansen | Statute Description (include the name of staiute or ordinance): Attempt Identity Theft — 4 Counts ‘Rets of the accused associated with this Offense: Possess or uses, through any means, identifying information of another person ‘without the consent of that other person to further any unlawful purpose TO WIT Smith and Co-defendant Starks did attempt to use the Identty of “Ava Carter" and 'Nefeese Jackson" while completing fraudulent transactions with Pennsylvania State Empioyoes Credit Union Visa debit cards however thase transactions were block by the issuer (Pennsylvania State Employees Credit Union). Carter PSECU Account 03/23/17 (2 Counts) 0/24/17 (2 Counts) (OPC 4I2A~ Rev. 07710 Page ofEJ POLICE CRIMINAL COMPLAINT Docket Number. | Date Filed | OTNILiveScan Numbor ‘ComplainUincident Number. I it BNGOOO2I7 Bo ae Sere | Fist Middle: [et me a Shakour | Shalik | Smith The acts committed by the accused are described below with each Act of Assembly or statute violated, if appropriate. When there is more than one offense, each offense should be numbered chronologically (Get forth a brief summery of tho facts sutfiiont to aéviee the defendant ofthe nature of th offenso(s) charged. citation tothe statut(s) violated, without fore Is rot sufficient. in a summary ease, you must ete the specific sections) and subscetion(s) of tho statuto(e) or ordinance(s) allegedly viotatod. Tho £go of tho victim at tho timo of tho offense may ba Included I known. in addilon, social socurlty numbers and inanell information (e.g. PINS) should not be listed, I the identity of an aecount must bo estalizhod ist only the last four digits. 204 PA.Code §§ 213-1 ~213.7) TT Atompt Ti Sotciation Ti Conspiracy fagorA 1a 9008 e903 i 3932 © ee qePACSA | 13 F3 Dee Roe eit ‘Offense ‘PA Statute (Tile) “Couns “Grade ~ NCIC Offense Code UCRINIBRS Code sANDOT Data om ae [ligmieey Di sate 2 Cl Work zone ‘Statute Description (include the name of statute or ordinance). Theft by Deception — 13 Counts ‘Acis of the accused associated with this Offense: Greates or reinforces a false impression, including false impressions as to law, ‘valu, intonton or othor state of mind TO WIT: Smith and Co-defendant Starks were observed on video surveillance cameras at muttipie locations completing fraudulent transactions with two separate Pennsylvania State Employees Visa debit cards and recelving US Currency or gift cards as a result of fraudulent transactions. Jackson PSECU Account 03/23/17 (4 Counts) 03/24/17 (4 Counts) Cartor PSECU Account 03/23/17 (8 Counts) Wieheates] BF Atempt TH Solicitation Ei Conspiracy re ~ | Offensé | 18901 4 89024 Bae 18903 a o [we f3922 [BS teracsa | 4 [rs ee “ ‘Ofienset ‘Sax oa = ‘Subsection. PA Siatuie (Tite) ‘Couns Grade ~UGRINIBRS Code “PennDOT, Data Ana i fork Zone Stiiteppleabiey: cienumeye |_| Salty 2e | Ci Work Zone ‘Statule Description (include the name of statute or ordinance): Attempt — Theft by Deception — 4 Counts TRals of the accused assoclated with this Offense: Greates or reinforces a false impression, including false impressions a8 fo law, value, intention or other state of mind TO WIT: Smith and Co-defendant Starks were observed on video survelllance cameras attempting to commit fraudulent transactions with two Pennsylvania State Employees Credit Union Visa debit cards however these transactions were blocked by the issuer (Pennsylvania State Employees Credit Union). Carter PSECU Account 03/23/17 (2 Counts) 03/24/17 (2 Counts) Jncheate: | C] Attempt Ci Solicitation TO Conspiracy sGrtense | 1050" 199028 LO ese o [o [3025 TA PRB eracsali3 [Fo a ne seat Siaieat— Sbicin PX Sao (ie) — Canis Gin —uce Gen Tare LEONE Coe “PpmDOT Date ne I softy Zone 1 work zone Statute Description (include the name of statute or ordinance): Receiving Stolen Property — 13 Counts ‘Acis of the accused associated with his Offense: Intentionally receives, retains, or disposes of movable property of another knowing that it has been stolen, or believing that it has probably been stolen TO WIT: Smith and Co-defendant Starks were observed on video surveillance cameras at multiple locations committing fraudulent transactions with a Pennsylvania State Employees Visa debit card and receiving US Currency or aft cards. Jackson PSECU Account 03/29/17 (4 Counts) 03/24/17 (4 Counts) Gartor PSECU Account 03/2947 (5 Counts) SOPC 4124 Rey. 07710 Page _of__a8 POLICE CRIMINAL COMPLAINT Docket Numbor [Date Filed: | OTNiLiveScan Number TomplalnVineident Number if -BNG000217 Ree SSESPED| Fst ‘aidaiet [test [Defendant Name | Shakour Shalic __| Smith ‘The acts committed by the accused are described below with each Act of Assembly or statute violated, if appropriate. When there is more than one offense, each offense should be numbered chronologically {Gel forth a bor summary of tha facts sutfclont to advieo the defendant of tho nature of the offonse(s chargod. A citation tothe staute(s) violated. without trove, !s not sufficlont. na summary caso, you must eile the specific soction(s) and eubsection(s) of tho statutes) or ordinance(s) allogedly viola. The ge ofthe viet atte im ofthe offense may be ncludad if known, In addltion, social sacurty numbers and financal information (eg. PINs) should not boa istod I the lent of an account mist bo established ist only tho lat four digs, 204 PA Code §5 243. ~213.7.) TGRERBG] Or Atom aa Ti Solicitation | Ci conspiracy Ofte. o [io [aie 189014 1.9024 | t8903 ABPACSA. | 4 i Sine PA Sala (Ti) Counts NCIC Offense Code UCRINIBRS Code == Painbor baa wT, Salaly Zone Wok Zone 618) poe ae ‘Stalute Description (include the name of statute or ordinance): Criminal Use of Communication Facility — 4 Counts ‘Acts of the accused associated with this Offense: Uses a communicaiion facliy to commit, cause or facillate the commission or the | attempt there of any crime which consttites a felony TO WIT: Defendant Srnith did use a cell phone fo communicate through phone calls, text messages, direct messages through Instagram and remotely deposit a check forthe use of fraudulent transactions. Contact with Tpr. Brown on 02/23/17 (phone calls, text messages and Instagram messages) 03/29/17 (mobile deposit of check into Ava Carter PSECU bank accound) and 03/24/17 (phone cal). TT atompe Ti Sofciaton (conspiracy iesorA isos Peed : o fire yao SAG TePACSA [LMI five ead? “ Gfansat Sexton —~Susicion * pkSatie (Two) Culs—-~iado Wei Cfense Code UGTINIGRE oe = PemDOT DART] Aci er ne Safety Zone Work zone { Statute Description (Include the name of statute or ordinance): Bad Checks ~ 1 Count ‘Rls of the accused associated with this Offense: Commis an offense if he issues or passes a check or similar sight order for the payment of money, knowing that it wil not be honored by the drawee TO WIT: Defendant Smith mobile deposited a check or caused a mobile deposit of a check to be made knowing that the check would be retumed due to non-sulficlent funds, 1 Count Chock deposited into Ava Carter PSECU bank account on 03/23/17 Pineheate=] C1 Atempt i Soliitation TBH Conspiracy Gffonse | 109014 tesa Phoned O [12 [3922 [eae WPAGSA[I [ES | ae ee SR Saute (6) Cans —~-Gai~—Wei otinas ade — USHERS Co * PennDOT DAR] © accuenes eat a =F it applica EEN Gi Satety Zor Work zone ‘Statute Description (include the name of statute or ordinance): Conspiay (Tet by Deception) ‘Aels of the accised associaled with this Offense: In that the Defendant on mulliple occasions did conspire with another person(s) to commit a crime, to wit, Theft by Deception, in that the Defendant intentionally obtained or withheld property of another with a value exceeding $2000 by creating oF reinforcing a false impression, including false impressions as to law, value, intention or other state of mind in violation of 18 Pa. C.S. A. § 3922(a)(1)(2) and/or (3). OPC AIZA~ Rev. 07710Docket Number Dato Filed] OTNLiveScan Number "Complainuineldent Numbor im -BNGOO0217 g Fist ‘aaa Tast Shakour Shalik Smith 2. Lask that a warrant of arrest or a summons be issued and that the defendant be required to answer the charges | have made. 3. | verity that the facts set forth in this complaint are true and correct to the best of my knowledge or information and belie This verification is made subject to the penallies of Section 4904 of the Crimes Code (18 Pa.C.S. § 4904) relating to unsworn falsification to authorities. 4, This complaint consists of the preceding page(s) numbered | through 9 . The acts committed by the accused, as listed and hereafter, were against the peace and dignity of the Commonwealth Cf Pennsylvania and were contrary to the Aci(s) of the Assembly, or in violation of the statutes cited. (Before a warrant of arrest can be issued, an affidavit of probable cause must ae issuing authority, and attached.) ANDNOW, onthisdale 3 ey ZG [77 | tty that the complaint has been propery completed and verted. ‘An affidavit of probable cause must be completed before a warrant can be issued, 36-]-06 ; uu— ‘Magisterial District Court Number) Caf yf Haiboriy) SEAL AOPC4IZA~ Rev. 07/10BS POLICE CRIMINAL COMPLAINT OTNiLiveSean Number Gomplainvine Mane NuMBe BNGOO0217 Docket Number: | Date First Widdie Last: Shakour Shalik Smith AFFIDAVIT of PROBABLE CAUSE Your Affiant, Justin Clarke #533, (Affiant Clarke) is a sworn Special Agent with the Pennsyivania Office of Attorney General (PAOAG), Bureau of Criminal Investigations Organized Crime Section, located at 1000 Madison Ave, Suite 310, Norristown, Pennsylvania 19403. Affiant Clarke has received training from the Pennsylvania State Police that includes the Class “A” certification course for Wiretapping and Electronic Surveillance conducted by the Pennsylvania State Police and Pennsylvania Office of the Attorney General in 2016. Your Affiant was certified to employ such techniques while conducting criminal investigations, maintaining "A" certification number A-5136. Since obtaining the Class "A" certification, your Affiant has participated in consensual investigations. Your Co-Affiant, Gabriel Fabian #542, (Affiant Fabian) is a sworn Special Agent with the Pennsylvania Office of Attorney General (PAOAG), Bureau of Criminal Investigations Organized Crime Section, located at 1000 Madison Ave, Suite 310, Norristown, Pennsylvania 19403. In February 2016, while monitoring a confidential Instagram Account regarding a separate investigation, Affiant Clarke noticed two separate Instagram users, who were using the Instagram handles "bankrollquaa" and "pankrollkiioooo," posting logos of banks and requesting other Instagram users to contact them (by “liking” photographs or private messaging through Instagram) if the other Instagram users maintained bank accounts with specific financial institutions. After reviewing numerous photographs posted on "bankrollquaa” and "bankrollkiloooo" Instagram's page, it was believed that both live and/or frequent the North Philadelphia area. The profile picture depicted under the “pankrollquaa" Instagram account was later identified as Quadir James Burley (PA SID 41364408) (Quadir). The profile picture depicted under the "bankrollkiloooo” Instagram account was later identified as Shakour Shalik Smith (PA33919310) (Smith). Instagram users "bankrollquaa’’ and "bankrollkiloooo" would typically remove or delete posts, which requested other Instagram members to contact about various banking institutions, after they were posted on their respective pages for only a few hours. On Thursday, 03/02/17, Affiant Clarke “liked” a post from “bankrollkiloooo” that requested Instagram users who maintain Pennsylvania State Employee Credit Union (PSECU) bank accounts. Through the “Instagram direct message” (Instagram DM) feature, "bankrollkiloooo" and Affiant Clarke, posing as Instagram user “avatherealonet” (a female), had an online conversation about using his PSECU bank account to make money. “Bankrollkiloooo” explained in the conversation that “avatherealone1” (Affiant Clarke) would have to provide her online banking information, debit card and PIN number to "bankrollkiloooo" and that "bankrollkiloooo” would then mobile deposit a check into the account and then strategically make ATM withdrawals and gift card purchases over two days. After the ATM withdrawals and gift card purchases were completed, "bankrollkiloooo” instructed “avatherealonet” (Affiant Clarke) to report his debit card stolen. *Bankrollkiloooo" also informed “avatherealonet” (Affiant Clarke) that once the ATM withdrawals and gift card purchases were completed; he would receive money in exchange for participation in this fraud scheme, “ROPE 411€- Rev. 07/10 Page 1 of 1On Thursday, 03/09/17, Supervisory Special Agent William Ralston (SSA Ralston), Affiant’s Clarke and Fabian met with PSECU Fraud Investigator Matthew Cassel (Cassel) and multiple employees from PSECU at PSECU headquarters. At this time, they discussed multiple fraud investigations that PSECU was currently investigating. At this meeting, PSECU management agreed to provide multiple PSECU fictitious bank accounts and PSECU debit cards to PAOAG investigators to assist in the investigation, On Tuesday, 03/21/17 at approximately 1504 hours, Affiant Clarke began an Instagram DM chat with Instagram user “bankrollquaa" under the Instagram account handle “nef__215g.” The following is the conversation that occurred through Instagram: 1504 Affiant Clarke - Was you the one to talk to if | got a bank acct nd wanna make money 1508 “bankroliqua” — Yes 1513 Affiant Clarke — Wassup wit it? | got an acct what do | need to do. | aint tryin to get scammed 1514 “bankroliqua” — What bank you with and you won't 1516 Affiant Clarke -PSECU what do I need to do 1548 “bankrollquaa” - What's ya number 1553 “bankrollquaa” - ? 1605 Affiant Clarke ~ 215-613-4761 1633 Affiant Clarke - ? Pennsylvania Office of Attomey General Narcotics Agent Nehemiah Haigler (NA Haigler) was assigned to act in an undercover role and pose as “Nefeese Jackson” while using the Instagram handle “nef_215g.” PSECU provided a bank account and Visa debit (4305 8600 1603 0596) in the name of Nefeese Jackson. On Tuesday, 03/21/17, at approximately 1638 hours, NA Haigler received a phone call from 267- 348-7547. NA Haigler missed the phone call and retumed the phone call to 267-348-7547. During this phone call an unknown male explained his plan to defraud PSECU to NA Haigler in the following manner: NA Haigler needed to provide his online banking information, his debit card and PIN Number; the unknown male would then deposit a check into his account, and subsequently withdraw the money, The unknown male explained that NA Haigler should report his debit card stolen once all of the transactions were completed and that afterwards they would split the money that the unknown male received. Shortly after this phone call, NA Haigler received the following text from 267-348-7547: ig -Igotta do it before 6 -Bro NA Hagler responded: ‘AOPC 411C- Rev. 07/10 Page 2 of 10Yo trying to hit you from another jack (On Tuesday, 03/21/17, at approximately 1653 hours, NA Haigler called 267- 348-7547 and spoke with the same unknown male as the previous phone conversation. This phone call was recorded. During this phone call, NA Haigler and the unknown male agreed to meet at the in the parking lot of the Chick-Fil-A in the Cheltenham Mall ‘The unknown male stated that he wanted to get all of NA Haigler’s banking information when they met At this time, SSA Ralston, Affiant Clarke, Special Agent Joseph Chiaro (SA Chiaro), Narcotic Agents Ashley McAteer, Melissa Tamarro, and Affiant Fabian traveled to the Cheltenham Mall located at 2385 W. Cheltenham Avenue Wyncote, Pa 19095 and began conducting surveillance in the Chick-Fil-A parking lot. (On Tuesday, 03/21/17, from 1723 hours through 1905 hours, multiple text messages and phone calls were exchanged between NA Haigler and the same unknown male using the 267-348-7547 phone number. On Tuesday, 03/21/17, at approximately 1823 hours, NA Haigler arrived at the Chick-Fil-A. On Tuesday, 03/21/17, at approximately 1905 hours, NA Haigler called 267- 348-7547 and spoke with the unknown male. During this phone call the unknown male informed NA Haigler that he was at Chick-Fil-A. This phone call was recorded. At this time, Affiant Clarke and Affiant Fabian observed a black Chevrolet four door sedan with tinted windows, 2 distinctive air freshener hanging from the rear view mirror, distinctive scuffs and scrapes on the vehicle, and bearing temporary Pennsyivania registration 2699803. (It was later determined that this vehicle was reported stolen from a location in Philadelphia on 11/04/16) On Tuesday, 03/21/17, at approximately 1913 hours, the aforementioned Chevrolet sedan pulled near NA Haigler's vehicle. At this time, a black male who had been identified as Quadir Burley (Quadir) exited the driver's seat of the aforementioned Chevrolet sedan and began speaking with NA Haigler outside of NA Haigler's vehicle. Approximately half way through the conversation NA Haigler invited Qaudir into his vehicle. An unidentified person was observed in the front passenger seat of the aforementioned vehicle. Quadit identified the passenger as his “girl” The entire conversation between NA Haigler and Quadir was recorded. A brief summary of the conversation of the in person meeting can be summarized as follows: Quadit outlined how a check will be deposited into NA Haigler’s account. Quadir detailed how he strategically withdrawals the money out of the account on certain days because the bank's staff isn’t working. After the withdrawals are completed, Quadir will meet up with NA Haigler to split the profits. Quadir instructed NA Haigler to report his debit card lost/stolen to PSECU after Quadir is done making the transactions, Near the end of this, conversation NA Haigler provided Quadir the PSECU Visa debit card (4305 8600 1603 0596) in the name of Nefeese Jackson, the Pin # associated with debit card, the online banking user ID, and the online banking password, Quadir took the PSECU debit card and said, *...’m about lo call my folks and get some paperwork now." The conversation ended at approximately 1920 hours, Quadir then entered the aforementioned Chevrolet sedan and-departed the vicinity of the Cheltenham Mall Surveillance agents followed Qaudir's vehicle until he made an abrupt stop near the intersection of Broad Street and Lindley Street in Philadelphia. Surveillance was then terminated, ‘AOPC 411C— Rev. 07/10 Page 3 of 10(On Tuesday, 03/21/17, at approximately 1936 hours, Quadir’s vehicle made an abrupt stop near the intersection of Broad Street and Lindley Street. At this time, Quadir called NA Haigler from phone number 267-348-7547. This phone call was recorded. During this phone call, Quadir questioned NA Haigler about the passwords needed to log onto his PSECU bank account. ‘On Wednesday, 03/22/17, Matthew Cassel, PSECU Fraud Investigator informed Affiant Clarke through e-mail that the PSECU card assigned to Nefeese Jackson was used at the Sunoco gas station located at 2634 N. Broad Street Philadelphia, Pa 19132 . The debit card was used for a purchase of $1.00; however the purchase was declined due to insufficient funds. The card was then used twice at an ATM, which is located at the same address of the Sunoco for the purpose of a balance inquiry. ‘On Wednesday, 03/22/17 at approximately 1636 hours, a check written from Wells Fargo Bank NA, Routing No. 031000503 Account No. 044115689 to Nefeese C. Jackson in the amount of $6,200.00 was mobile deposited into the PSECU account belonging to Nefeese Jackson. "Work" was written on the memo line. (Definition of mobile: deposit - Using the camera in a phone to deposit a check in a bank. An application in the phone takes a picture of the front and back of the check, and both images, along with the dollar value, are transmitted to the bank) ‘On Thursday, 03/23/17 at approximately 1400 hours, Affiant’s Clarke & Fabian, Pennsylvania Office of Attorney General Supervisory SSA Ralston, SA Chiaro, Special Agent Kevin Schofield (SA Schofield) and Pennsylvania State Police Troopers Jovanna Brown (Tpr. Brown) Mark Salemo, Nick Scrivani, Ryan Smith, Jamie Sparenga met at the Pennsylvania State Police Belmont Barracks, At this time, Affiant Clarke and Affiant Fabian explained the investigation to everyone present. ‘Tpr. Brown was assigned to act in an undercover role and pose as “Ava Carter” while using the Instagram handle “avatherealone1.” PSECU provided a bank account and Visa debit (4305 8600 1691 1233) in the name of Ava M Carter. On Thursday, 03/23/17, at approximately 1518 hours, using the Instagram account handle “avatherealonet,” Affiant Clarke started the following conversation with Instagram user “bankrollkiloooo": 1818 - CLARKE ~ Hey | got my new card. Can | get money today 1519 —"bankrolikiloooo" ~ What card 1520 — CLARKE - My new PSECU card 1528 — “bankrollkiloooo” —Yes- = What's your number - (screenshot of Nefeese Jackson PSECU account) ~ — Ijust did this one yesterday 1529 -“bankrollkiloooo” - $6200 cleared today 1530 — bankrollkiloooo - | need ya number though don''t like ig talk 1832- CLARKE — | want sum 1832 — bankrollkiloooo ~ What's your number AOPC 411C- Rev. 07/10 Page 4 of 102 -And Way - You be playing you played last time .. 4887 — CLARKE — 3024501533 Work ~I gave u my number. This must be a scam 1537 ~ bankrolikiloooo- A scam . Naw | just think you playing ganes 1538 ~ Clarke ~ (picture showing PSECU debit card) 1540 — bankrollkiloooo - Okay so Way | just texted you.. If we do it by 6 we can make $6200 .. 1541 — bankrolikiloooo- Do you have online banking? - You'll have a $1000 today. “pankrollkiloooo” then began communicating with Affiant Clarke/Tpr. Brown via text messaging from cell phone number 267-630-1462. ‘On Thursday, 03/23/17, at approximately 1550 hours, an unknown male using phone number 267-630-1462 called Tpr. Brown at telephone number 302-450-1533. The unknown person asked Tpr. Brown how long she had the bank account, if she is able to mobile deposit, and what her spending limits are. The unknown male requested ‘pr. Brown’s online banking user name, password, and PIN number. The unknown male identified himself as “Keife.” This phone call was recorded. (On Thursday, 03/23/17, at approximately 1557 hours, the same unknown male using phone number 267-630- 1462 called Tpr. Brown at telephone number 302-450-1533. During this phone cal, the unknown male informed ‘Tpr. Brown that her account is ‘not enrolled,’ The unknown male talked about “Ava Carter’ trusting him. The unknown male instructed Tpr. Brown to logon to her PSECU through the website. This phone call was recorded. On Thursday, 03/23/17, at approximately 1619 hours, the same unknown male using phone number 267-630- 1462 called Tpr. Brown at telephone number 302-450-1533. Tpr. Brown informed the unknown person that she enrolled the account online, and the unknown male again asked for Tpr. Brown's online banking user name and password. The unknown male stated that he had already signed onto Tpr. Brown's account. The unknown male instructed Tpr. Brown to call PSECU and have the mobile deposited set up. This phone call was recorded. Through a text message, Tpr Brown and the unknown person agreed to meet at the “Chili's” parking lot at 175 East City Ave, Bala Cynwd, Pa 19004 at 1710 hours. ‘On Thursday, 03/23/17, at approximately 1730 hours, a silver Nissan Altima bearing PA registration KHJ-3613 arrived at the meet site. At this time, a B/M who was been identified as Shakour Smith (Smith) exited the aforementioned vehicle and approached and greeted Tpr. Brown. The vehicle was also occupied by two other B/M's who were later identified as Ikeem Starks (Starks) (driver) and Gregory Nathaniel Jackson (backseat passenger). Tpr Brown and Smith had a conversation that can be summarized as follows: “AOPC 411¢— Rev. 07/10 Page 5 of 10Smith stated that hewanted to make Tpr. Brown feel comfortable. Smith identified himself as “Kiefe.” Smith stated that he wanted to answer any questions that Tpr. Brown had. Smith explained that he will mobile deposit a check into her PSECU bank account. The amount of the check would be $6,200.00. Smith would take a picture of the front of the check and back of the check to complete the mobile deposit. Smith was not sure if the check will clear right away, but the check would definitely clear by tomorrow. Smith talked about another account with which he was currently committing the fraud. (At this time, Smith was showing screenshot photographs to Tpr. Brown of banks accounts that upon which he had already completed this fraud scheme. Itis believed that the account that he referenced and showed screenshot photographs was the Nefeese Jackson PSECU account.) Smith informed Tpr. Brown that he would complete a $300.00 ATM withdrawal and then go to Walmart and purchase (3) three $500.00 gift cards. Smith guaranteed Tpr. Brown that if she did not get $1,000.00 that day, she would receive $1,000.00 by the next day. Smith informed Tpr. Brown that she can monitor the transactions on her account as ‘Smith completed the transactions. Smith told Tpr. Brown that he would keep her posted. Smith told Tpr. Brown that they would split the money that will be obtained from this fraud scheme by stating, “..t's just me and you, 1 get the check made, | pay them up front”, Smith instructed Tpr. Brown to call the bank and report the debit card stolen/lost after the transactions. The purpose of reporting the debit card stolen/lost would be to save Tpr. Brown from having to pay the money back. Smith stated that the bank will do a "petty investigation” and see that it's a ‘male making the transactions and the bank won't take any further action. Smith stated, “... one thing is for sure, | have been doing this for a long time. | never had nobody go to jail...never. | work with a lot of people...f don't got no job.” Tpr. Brown asked Smith if he did it one or two times. Smith responded, “Fuok one or two time, I have done it hundreds of times. am a pro at what | do...” Smith stated that he is going to leave the meet site and go get the check. Smith told Tpr. Brown that he is from ‘North’. Smith talked about the possibility of having Tpr. Brown recruit people to participate in this fraud in the future. Smith told Tpr. Brown that he did , ‘probably 18 cards with them’ (PSECU). Smith stated that he goes to Police and Fire ATMs to make ATM withdrawals. The entire in person conversation between Smith and “Carter” (Tpr. Brown) was recorded. Near the end of this conversation Tpr, Brown provided the PSECU Visa debit card (4305 8600 1691 1233) belonging to Ava Carter to Smith. (On Thursday, 03/23/17, a check written from the Freedom Credit Union, Routing No. 236084751 Account No, 0080029733 to Ava M Carter in the amount of $5,400.00 was mobile deposited into the PSECU account belonging to Ava Carter. "Work" was written on the memo line On Monday, 03/27/17, Matthew Cassel, PSECU Fraud Investigator provided Affiant Clarke with a list of fraudulent transactions that occurred on the Ava Carter PSECU debit card number 4305 8600 1691 1233. The list of transactions are as follows: 03/23/17 19:26:33 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 ATM Withdrawal $280.00 ~ Transaction Blocked (On Thursday, 03/23/17, at 1942 hours, Smith sent Tpr. Brown (302-450-1533) a text message from 267-630- 1462 stating, "My phone on 1% trying to get it off so I need you to move fast’. At this time, Smith was trying to have Tpr. Brown call PSECU and verify the purchases because the debit issued to Ava Carter was being declined.) (A surveillance photograph was obtained from Walmart that shows Shakour Smith at the ATM inside the Waimart at the above listed time and date) AOPC 411¢ - Rev. 07/10 Page 6 of 1003/23/17 19:51:14 Subway Restaurant Attempted Purchase $14.56 03/23/17 20:13:05 Wal-Mart Store #5103 4800 Roosevelt Boulevard Philadelphia, Pa 19124 ATM Withdrawal $80.00 03/23/17 20:13:44 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 ATM Withdrawal $200.00 03/23/17 20:14:33 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 ATM Withdrawal $200.00 Transaction Exceeded (For these Wal-Mart attempted/successful ATM transactions, Surveillance photographs were obtained from Walmart showing Shakour Smith inside the Wal-Mart store at the time of the successful ATM withdrawals) 03/23/17 20:20:20 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 - POS purchase $498.00 03/23/17 20:21:12 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 - POS purchase $498.00 03/23/17 20:22:00 Wal-Mart Store #5103 4800 Roosevelt Boulevard Philadelphia, Pa 19124- POS purchase $498.00 (For these Wal-Mart POS purchases, surveillance photographs were obtained from Wal-Mart showing {keem Starks completing gift card purchases.) 03/24/17 00:34:09 PNC Bank ATM (inside of WaWa) 193 Belmont Avenue Bala Cynwyd, Pa 19004. ATM Withdrawal 280.00 Permanent Restriction 03/24/17 00:36:09 PNC Bank ATM (inside of WaWa) 193 Belmont Avenue Bala Cynwyd, Pa 19004. ATM Withdrawal Inquiry (Surveillance video was obtained from inside the WaWa Store where the PNC Bank ATM is located. The video shows Shakour Smith and Ikeem Starks using two separate ATM machines at the same time. It should be noted that a PSECU debit card in the name of Nefeese Jackson was used at the same time. It appears that Starks received the $500.00 from the PNC Bank (WaWa ATM) from the Jackson PSECU card, while Smith checked the balance on the Carter PSECU card Video surveillance shows Starks operating a silver sedan resembling the Nissan Altima that he was operating at the time of the undercover meet, Smith is a passenger in the vehicle.) 03/24/17 00:54:42 Wal-Mart Store #4687 275 N. Gulph Road King of Prussia, Pa 19406 POS Purchase $.78 Permanent Restriction (Surveillance photographs were obtained from Wal-mart showing Shakour Smith and Ikeem Starks standing at cash register around the time that this transactions was attempted.) ‘On 03/28/17, the check that was mobile deposited into Ava Carter's account was returned due PSECU unable to locate the account, thus creating a loss of approximately $1,780.00 for PSECU ‘AOPC 411¢- Rev. 07/10 Page 7 of 10(On Thursday, 03/23/17 at approximately 0445 hours, Affiant Clarke and Affiant Fabian located the black Chevrolet sedan bearing temporary Pennsylvania registration 2699-803 in the vicinity of 1524 W. Lehigh Avenue Philadelphia, Pa 19132. At this time, Affiant Clarke and Affiant Fabian looked into the vehicle through the front windshield and observed a piece of paper that resembled an ATM receipt in the front cup holder. At this time, the car and VIN number were photographed. The VIN # was partially obscured. (2G1WG5E30D11"*"* ) (On Friday, 03/24/17 at approximately 1333 hours, NA Haigler attempted to call Quadir (267-348-7547). At this time, Quadir answered the phone call. NA Haigler and Quadir discussed the debit card transactions and Quadir informed NA Haigler that NA Haigler would receive $1,500.00 for participating in the fraud scheme. Quadir and NA Haigler agreed to meet early Sunday morning, 03/26/17. This phone call was recorded. ‘On Sunday, 03/26/17, NA Haigler attempted to call Quadir multiple times at telephone no. 267- 348-7547. After a few phone calls, it appeared that Quadir blocked NA Haigler’s phone because when NA Haigler attempted to call ‘Quadir, the phone call would go directly to voice mail; however, when Quadir's phone number was called from a different phone, it would not go straight to voicemail. Affiant Clarke also attempted to contact Quadir *bankrollquaa’ through “Instagram Direct Messenger’. Once Affiant Clarke contacted Quadir from the Instagram account "nef__215g', it appeared that Quadir blocked that account, as Instagram user “nef__215g" could no longer view “bankrollquaa’s” Instagram page. However, any other Instagram user was still able to view “bankroliquaa’s” Instagram page. On Monday, 03/27/17, Matthew Cassel, PSECU Fraud Investigator provided Affiant Clarke with a list of fraudulent transactions that occurred on Nefeese Jackson PSECU debit card number 4305 8600 1603 0596. The transactions are as follows: 03/21/17 19:48:29 Sunoco Store No, 0363328604 $1,00 NSF (not sufficient funds) (Surveillance video could not be obtained for this transaction) 03/21/17 19:48:55 2634-44 N, Broad Street -0.00 Invalid PIN Entry Balance Inquiry 03/21/17 19:20:23 2634-44 N. Broad Street - 0.000 Approved Balance Inquiry (Surveillance video could not be obtained for these transactions) 03/23/17 12:37:58 2201 Hunting Park Avenue Phitadelphia $500.00 ATM Withdraw! (Surveillance could not be obtained for this transaction. This transaction occurred inside the 39” Philadelphia Police District; however the camera inside the district is not currently operational.) 03/23/17 12:55:29 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 POS Purchase $497.95 03/23/17 12:56:21 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 POS purchase $497.95 03/23/17 12:87:25 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 POS purchase $498.00 ‘AOPC 411C — Rev. 07/10 Page 8 of 10(For these Wal-Mart POS purchases, surveillance photographs were obtained from Wal-Mart showing Ikeem Starks and Shakour Smith completing gift card purchases.) 03/23/17 14:46:61 Sunoco Store No, 0363171002 $1.00 Approved (Surveillance video could not be obtained for this transaction) 03/24/17 00:34:29 PNC Bank (WaWWa ATM) 193 Belmont Avenue Bala Cynwd, Pa $500.00 ATM Withdrawal (Surveillance video was obtained from inside the WaWa Store where the PNC Bank ATM is located. The video shows Shakour Smith and Ikeem Starks using two separate ATM machines at the same time. It appears that Starks received the $500.00 from the PNC Bank (WaWa ATM) from the Jackson PSECU card, while Smith ‘checked the balance on the Carter PSECU card. It should be noted that a PSECU debit card in the name of Ava Carter was used at the same time. Video surveillance shows Starks operating a silver sedan resembling the Nissan Altima that he was operating at the time of the undercover meet, Smith is a passenger in the vehicle.)) 03/24/17 00:56:20 Wal-Mart Store #4687 275 N. Gulph Road King of Prussia, Pa 19406 POS Purchase $497.95 03/24/17 00:66:48 Wal-Mart Store #4687 275 N. Gulph Road King of Prussia, Pa 19406 POS Purchase $497.95 03/24/17 00:58:14 Wal-Mart Store #4887 275 N. Gulph Road King of Prussia, Pa 19406 POS Purchase $498.00 (Surveillance was obtained for the Wal-Mart purchases that were made on 03/24/17 from 00:55:00 — 00: 58:14.) (Surveillance photographs show Ikeem Starks and Shakour Smith completing gift card purchases.) 03/24/17 01:50:28 Sunoco 0363328604 $1.00 Approved (Surveillance video could not be obtained for this transaction) 03/24/17 02:04:39 — 02:05:09 (five separate transactions from Lyft.com — all denied) (Surveillance video could not be obtained for these transactions) On Wednesday, 03/24/17, the check that was mobile deposited into the Nefeese Jackson's account was returned due to Non-Sufficient Funds, thus creating a loss of approximately $4,000.00 for PSECU. ‘On Wednesday, 03/29/17, PAOAG Analyst Janet Smilowski researched the partial VIN # obtained from the Chevrolet sedan which Quadir was observed operating and which was bearing Pennsylvania registration 2699803. Analyst Smilowski was able to identify the complete VIN # (2G1WGS5E30D1 18403) and determined that the vehicle was listed in NCIC as "stolen." (On Friday, 03/31/17 at approximately 0730 hours, Affiant Clarke and Affiant Fabian began conducting surveillance in the vicinity of 1524 W. Lehigh Avenue Philadelphia, Pa 19132 Philadelphia Police Officers Cedric Carter (6235) and Mark Austin (6876) were positioned nearby to assist Affiant Fabian and Affiant Clarke with surveillance. On Friday, 03/31/17 at approximately, 1040 hours, Affiant Clarke and Affiant Fabian observed the black Chevrolet sedan bearing temporary Pennsylvania registration 2699-803 arrive in the vicinity of 1524 W. Lehigh Avenue. This ‘was the same vehicle that Quadir operated when he arrived at the Cheltenham Mall Chick-FilA on 03/22/17 to ‘AOPC 411 — Rev. 07/10 Page 9 of 10meet NA Haigler to receive the undercover PSECU Visa debit card. This vehicle was identified by the make, model, rims, tint, and temporary registration. Atthis time, Affiant Clarke notified Police Officers Carter and Alston of the presence of the aforementioned stolen vehicle. Officers Carter and Alston initiated a traffic stop on the aforementioned vehicle near the intersection of 16 Street and Lehigh Avenue. James Burley (James), Quadir’s father was found to be operating the stolen vehicle. Will Bush (PA 25943404) was found to be in the front driver's passenger seat. James was arrested by the Philadelphia Police Department and charged with offense related to driving the stolen vehicle (1614089335). James stated that the vehicle belonged to his son, Quadir, Shortly thereafter, Quadir arrived at the location of the traffic stop and retrieved papers related to the vehicle and handed them to Officer Carter. ‘Your Affiants submits that the information contained herein is sufficient to provide probable cause for the issuance of an arrest warrant for Dealing in Unlawful Proceeds, Access Device Fraud, Identity Theft & Theft by Unlawful Taking. 1, Justin &. Clarke / Gabriel J. Fabian, BEING DULY SWORN ACCORDING TO THE LAW, DEPOSE AND SAY THAT THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT ARB TRUE-AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. usc 83> op of Affiant) ‘Sworn to me and subscribed before me day of Be22 B/20 17 one My commission expires first Monday of January, 262 , Magisterial District Judge PC A11C ~ Rev. 07/10 Page 10 of 10lease provide the following information for each co-defendant. toh Co-Defendant Data Sheet Docket Number: Date Filed: ‘OTNiLiveScan Number ‘Complalninedent Nuriber BNGOOO217. 2 Widdie Tast SHALIK MITH "Calta Naber BNG000217- IKEEM MAURICE STARKS ‘Wanie} 5120 KNOX STREET ‘ome Street Adaresay PHILADELPHIA, PA 19144 Gi, State, & iP Codey (ratephone ® Co-Detendantit A co-Detendanit2 QUADIR JAMES BURLEY ware} 1524 W. LEHIGH AVENUE ‘Home Sireat Adress) PHILADELPHIA, PA 19132 ‘Ci, Stale, EAP Codey TTatophone ® ‘Complalnvincident Namber ‘Co-Dofendant #__ ‘Warno) ‘Frome Strest Aaareesy (ei, Stale, EZIP Cod) Takeohone Coetendant Warne) ‘Torna Seat AareSSy (Civ, State, & ZIP Codey Teephone HY ‘AOPC 442A — Rev. 07/10 Page__of __COMMONWEALTH OF POLICE CRIMINAL COMPLAINT PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA COUNTY OF: Montgomery VS. ‘Magisterial District Number: 381-08 MDJ: Hon, Henry Schireson Address: 925 Montgomery Avenue Narbeth, PA 19072, ‘Telephone: (610) 664-5262 a z aE See Scene ae Ba felony Full 1 4-Felony No Et TIE Misdemosnor Limited DE Wiedemeanor Pending 1D 2Felony Lt O5-Fetony Pena. Clcsiisdemeanor Surounding States] Distance: C1 3-Felony Surounding Slates] AMisdemesnor Full CD Misdemeanor No Extradition as aa SESS DEFENDANTIDEN TIFICATION INFORMATION SSE ay Kot Number Dato Filed ‘OTNILiveScan Number | Compiainvincidont Number | SID quest Lab Services? id BNGO0O2I7 yest No oB 01/09/1999 Poa aacivos 7 7 Go-Defendant(s) First Name Last Name EYE COLOR hai tect) ‘Claw ei BQ BRO (rom) HRN (oreen) Leryn Chrinz gasey ———_EXanr atsrcony Cenk ig Thu eutcorey C1 20% (urine ae State PA License Number 32 295 883 ‘Expités: Suspended Serra Ci¥es ENO | puatocation 23 [eee fal [MNO Number] a in ie) Ee a EE Oe oe an Far let eR LE OTR ‘State | Hazmat |” Rogistration ‘Comm’ Veh. Schoo! Pate # | sticker) / nd. | ven, same se vin ‘Yoar | Wake Wiodel ‘Style Color re Office of the attorney for the Commonwealth C Approved [1 Disapproved because: ‘The alorney forthe Cansmonwealh may require That the comlaint,artest warrant affGavl,o” Bath be approved by the aomoy forthe Commonweal prior To fling. See Pa.R.Crin P. 507), Heather Castine AafIG ato, S a9 2017 Se es aamT e Aa maar ae et 1, Sastin E, Clarke _/ Gabriel J. Fabian Ba WaT Baa ‘Ra ae Aa) (SPAIPOETC Asstned Afiart 10 Numbor & Badge F PA Office Of Attorney General TION snare ese s ‘Wanty Deparment or Agency Represenied ard PORIGT SUDaWEER] —(Palen Ageney ORI Numba do hereby state: (check appropriate box) 4, @ I accuse the above named defendant who lives at the address set forth above I accuse the defendant whose name is unknown to me but who is described as C1 accuse the defendant whose name and popular designation or nickname are unknown to me and whom | have therefore designated as John Doe or Jane Doe ith violating the penal [aws of the Commonwealth of Pennsylvania at_—_ [413], 193 Belmont Ave 19401 and ‘multiple other locations within Montgomery and Philadelphia Counties. “uanasor Casey (Pace: Pomtzal Supawsoay— in Montgomery & [22.451] on or about 03/21/17 thru 03/24/17 | Philadelphia County an \OPC4I2A— Rev. 07710 Page ofSEe POLICE CRIMINAL COMPLAINT Docket Number: Date Filed | OTNiLiveScan Number ‘Complaintincident Numb m7 BNGO000217. ee aaa First: Tdi Tast [ Defendant Name =| Quadir James, Burley i 2. ask that a warrant of arrest or a summons be issued and that the defendant be required to answer the charges | have made. 3. | verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code (18 Pa.C.S. § 4904) relating to unswomn falsification to authorities, 4. This complaint consists of the preceding page(s) numbered | through S ‘The acts committed by the accused, as listed and hereaifter, were against the peace and dignity of the Commonwealth of Pennsylvania and were contrary fo the Act(s) of the Assembly, or in violation of the statutes cited. (Before a warrant of arrest can be issued, an affidavit of probable cause m ay , sworn to before the issuing authority, and attached.) if $33 lesen Sue (Sionattidot Afan)) a) avnowontiscate — 4-317 | conty thal the complaint — propety competed and vie nso of probable casa usb completed befor a waren canbe sed 4a Z5.1.08 (Magisterial Disirict Court Number) (issuing Authorit Gi imber) ‘9 y) SEAL OPC 412A — Rev. 07/10 Page 5 of Sa POLICE CRIMINAL COMPLAINT Docket Number: Dato Filed: | OTN/LiveSean Number ‘Gomplainvineident Number - tt BNG000217. a Fist idle Last Quadir James Burley ‘The acts committed by the accused are described below with each Act of Assembly or statute violated, there is more than one offense, each offense should be numbered chronologically. {SotTerth a bref surnmary othe facts suficint to advise the dofondant of th nature of tho offenso(s)chargod A citation to tho statuto() violated, without fnoro; fe not cuftont n'a cummary case, you mist elt the specie section(s) and subsections) ofthe statua(s) or ordinance) allegedly violatod. The tye ofthe victim a the time of tho ofonse may bo included W known. In atin, soctal security numbers snd financial information (0.9. PINS) should not Biistod ithe ldonty ofan account must be ostabliso, st ont tho lst four digits, 204 PA.Codo $§ ) appropriate. When ‘Tnchoate =| Ci Attempt 1 Solicitation Conspira Bre OA 10024 LP fess w fio [site LAG, fisPacsa | [8 g eS veh cian ‘Sued Px Siive (re) —— Cais CIE renee Code Uctunaks Coes > PennDOT Data z | (ifapplicable) | 2 Sie sa Lat alt ‘Statute Description (include the name of statute or ordinance): Dealing in proceeds of unlawful activities — 7 count ‘Rais of ha accused aesoaled wih this Offense! Com a nancial wansaclion with knowledge tal tha propary Involved, ncicing stolen or easly, ‘btained property. represents the proceeds of unlawful activity, th person ats with th intont to premote the carrying on ofthe unlawful ofthe unlawful Setvty TO WAIT: Burlay de erve and meat with a Penasyvaria Offcw of Atomey General Narcotics Agent ating in an undercover capacity to receive a Pennsyivania Slate Employees Credit Union (PSECU) Viea deat card, thatthe dofendant related that he was gong to use in fraudulent transactions. Buley did promise NA faiglor na the amount of money tat was generated from Ue fraudulent transactions, Defendant Burley did cause eight fraudulent. ‘wansactons on the Nefaese Jackson thal caused a loss of appraximately $4,000.00 to PSECU. ‘Jackson PSECU Account 03/23/17 (4 Counts) 03/24/17 (4 Counts) 7 Satetaton Ti conepracy : iea02 feaes g [4@) x igPacSA ll ies z ‘ eae “aaa se BA Siiefi)——Couit ~~ rs Ni oe a — UCB Ee — Fo PaRRDOT ORES) Rass i ———— work zone Statute Description (include the name of statute or ordinance}: Forgery - 1 count ‘als of the accused associated with this Offense: The intent to defraud or with knowledge of facilitating a fraud, ters any writing which of another without his authority TO WAT: Defendant Burley mobile deposited or caused a mobile deposit to be made to the Nefeese Jackson Pennsylvania State Employees Credit Union bank account bearing signatures that were not created by Nefeese Jackson. Jackson PSECU Account 03/20/17 (1 count) Cratenpe Ti Soietaion BE Conapirasy feo0rh wa0024 tava Beeeeeceedees ACA) isPacs.A [8 cee 5 ‘Subsection PA Staiute (File) ‘Counts Grade NCIC Offense Code ‘UCRINIBRS Code. /Sitapeliesble) D1 Safety Zone a Wot ‘Zone ‘Statute Description (include the name of statute or ordinance): Conspiracy to Commit Access Device Fraud - 8 Counts | ‘Rats of the accused associated with this Offense: wns ier otpronaine x ecitaing commission of cr, cd agi wh oe ox mor tar pasens ht ‘hey avon or move fern woud ora ncohe whl conshdes aca oi gee osc her petsn er ears lg o cans of uch cre of aleplo ibaa conn owen case af econ Deven aca ean, te rn fi acoss dees dale ton oa Israels ee Gover TO ‘itt bay aig rout Nefcoe incon teouph anon assur ad nae ener acs ssc a wi te RefeseJesaon Pnnsyvania Sale Eoyees inate ics don soed Detour eaee Sat enn sansacsons oon antha na Inlaon Pamneyvan laa plans Creat Us ark azou cet & {ete ot porn 00.29" Thana ouantransoctns ware ot aan te lsse(Peanyvania Stat Empoyes Crem Us) Jaokeon PSECU Account 0323/7 (4 Counts) 03/24/17 (4 Counts) NOPE 412A ~ Rev. 0710 Page _ ofa8 POLICE CRIMI i - INAL COMPLAINT Docket Number: Date Filed: | OTN/LiveScan Number Coniplaintincident Number ‘ uu BNG000217 : Fist Wide: Tast Quadir James Burley Ts not suifielont Ina surenary ea The acts committed by the accused are described below with each Act of Assembly or statute violated, if appropriate. When there is more than one offense, each offense should be numbered chronologically {Got forth aBrlaf summary ofthe facts sullen to advao tho dafondant ofthe natu of tho ofonso(2)chargod. A citation to the ou must eto the specific section(s) and sulisections) ofthe statute() or ordinancta) allegedly voltod. Tho {ago of tho victim atthe timo of tho effonee may be Included I row. In adation, social securty numbers and arc information (0.9. PINS) should not bo istod. i the identity of an account must bo establishod, list only the last four digits, 20 tuto) violated, withou Moan gga104 2107), SWaeRSate] CI tempt [Er gtetson TB Conspiracy - offense. | 185004 189024 Ee 10909 oO [4eo [ao TA Pac A [8 [RR | ee Lead feist choy Babeeton RSs (ls) Cas —~ Ga — NOW Oe Cone — UCTS Cos Péan yaa ok Zone (itapplicable) || Number C1 Safety Zone 1D Work 26 ‘Stalute Description (include the name of statute or ordinance):Conspiracy to commit Identity Theft- 8 counts ‘Acis of the accused associated with this Offense: with te teat ot poring or faciiating the commision of @ arena, did agree wit one or more other persons at hey oe Cre tes engage mccain soul a ther pa porte be Henge cnmntocaew e a se ‘ostes a ures, ugh ny ean, ening fornia fencer aron wou the conga hat parcours any nul uroes TO WIT Bly dest Nefooso ncsey rou ls aay sco apse sons vosfing sans cel acd wah ha Nefove Jason Pemsyana Sao Erpoyees Cred Uon Ven Befencnt uly se cme et fms! Venachcns acer on Pe Neos lactson Pemsyvara Stale rplayacs Cred Un bank acta Thses evr neocons Were nt ‘Sura byte issuer (Pomayria Ste eyes Cott Ue) TF Atempe Ty Solicitation ] Bi Conspiracy 189094 189024 LE iesas 3922 1 Z 4BPACSA|8 [FS ve : (esc eer a —__ a PA Sia (tt) Couns Grade NGI Conse Code UGTURIARS Code fF PennDOT amin | Asda eee 1D Sataty Zone 1D Wen zone Statute Description (Include the name of statute or ordinance): Conspiracy to Commit Theft by Deception- 8 counts “els of the acaused assoclaled with this Offence: Creates or reinforces a false impression, including false impressions as to law, value, intention of other state of mind TO WIT: ween eyo boii sine as ine psn yn oie hon end ‘engin cond which conser stn dng ouch oe pro feather cen of cei rf ae ole ctl ch ce, ‘Ba By Speromned ib oped ce tbe ne lb sees oto oes fans esi ay neh Sana rans ower oe Nee ken Pej ieEploer Crs Une ea asa easngs oe apacnely 4.0500 | Ssskton PSECU Aceon cau? a Counts) 207 Cour Tiehoatey] Otome Ti soraton Ti conspiracy | Oftense..| ~ tao tao feoed o [e [72 TBPACSA [4 FB : eset oes cin —~Ssoion TA Sas (i) Chan crea ~~ WIE ona Coe UCTS Cos eer , Numbers 1 safety Zone 1D wiotk Zone ‘Statute Description (include the name of statute or ordinance}: Criminal Use of Communication Facility — 4 Counts Jackson PSECU bank account) and 03/24/17 phone cal {count phone calls, 1 count-text messages, 7 count -Instagram messages, 1 count mobile deposit of check into Nefeese Jackson XOPC 4124 Rev. 07/10 ‘Acts of the accused associated with this Offense: Uses a communication facilly to commit, cause oF facilitate the commission or the attempt thereof any crime which constitutes a felony TOIT: Defendant Burley did use a phone to communicate through phone cals, text messages, direct ‘massages through Instagram and remotely Copoat a check forte use of fraudulent transactions. Contact with NA Haigler on 03/21/1 7iphone calls, fxt messages and Instagram messages) 08/22/17 (mobile deposit of check into Nefeese Page of _Ed POLICE CRIMINAL COMPLAINT mor, Is not eutficiont Date Filed! | OTNLiveSean Number | Complainvineidont Numb tt | HEHE BNG000217 Fit aida: Last Quadir James Burley ie soetions) and su ton(s) of the statute). ‘The acts committed by the accused are described below with each Act of Assembly or statute violated, if appropriate, When there is more than one offense, each offense should be numbered chronologically {Set orth a bref summary of tho facts sufficient to advise the defendant of th nature of th offenso(s) charged. A citation to the statut(s) violated, without “a summary aso, you must let ‘age of th victim atte time of tho offense may be Included I know. n addon, social seeurty numbers and financial information hosted tthe lontty ofan account must be established list only te las ow digits, 204 PA.Cade 65 2131 ~ 210.7.) tnance(s) allegedly violatod. The PING) should not TaAttempe 189004 Ti Solictation 789024 TH Conspiracy 18.903 AO ABPACSA i [Re ‘Subsooion “PA Sie (Te) Cee ‘Grade “NGiG Oonse Code UGRINIBAS Goce 1 Satety Zone C1 Work Zone Statule Description (include the name of statute or ordinance): Bad Checks — 1 Count 1 Count Check deposited into Nefoose Jackson PSECU bank account on 03/22/17 ‘Acts of the accused associated with this Offense: Commits an offense if he issues or passes a check or similar sight order for the payment of money, knowing that It will not be honored by the drawee TO WIT: Defendant Burley mobile deposited a check or caused a mobile deposit of a check to be mado knowing that the check would be returned due to non-suficient funds. 1D Sciietation Bi Conspiracy {09024- 18.908 4aPACSA]L | B3. eae PA Stable () Couns Grado ~ NCIC Ofenso Cade UCUNIORS Cate 1 Safety zone 1D Werk zone ‘Statute Description (include the name of statute or ordinance): Conspiracy (Tae by Deception) Rais of the accused associated with this Offense: In that the Defendant on multiple occasions did conspire with another person(s) to commit a crime, to wit, Theft by Deception, in that the Defendant intentionally obtained or withheld property of another with a value exceeding $2000 by oreating or reinforcing a false impression, including false impressions as fo law, value, intention or other state of mind in violation of 18 Pa. C.S. A. § 3922(a)(1)(2) andlor (3). FREER Atop 1 Seiaaton Treonapiacy ‘e904 io fame isa ~~ ae 1a Sia as) ——tos "Sian ones to" —~ Uo ce a : } © (fapplicabley —-| = Number O Setety Zor Dl Work Zone ‘Statute Description (include the name of statute or ordinance) OPC AIA — Rev. 07/1 ‘Rais of the acoused associated with this Offense: Page ofced POLICE CRIMINAL COMPLAINT Docket Number: | Date Filed: ‘OTNiLiveScan Number Complaintincident Number (° BNGOOO217 Middle: Tast James Burley AFFIDAVIT of PROBABLE CAUSE Your Affiant, Justin Clarke #533, (Affiant Clarke) is a sworn Special Agent with the Pennsylvania Office of Attormey General (PAOAG), Bureau of Criminal Investigations Organized Crime Section, located at 1000 Madison Ave, Suite 310, Norristown, Pennsylvania 19403. Affiant Clarke has received training from the Pennsylvania State Police that includes the Class “A" certification course for Wiretapping and Electronic Surveillance conducted by the Pennsylvania State Police and Pennsylvania Office of the Attorney General in 2016. Your Affiant was certified to employ such techniques while conducting criminal investigations, maintaining "A" certification number A-5136. Since obtaining the Class "A" certification, your Affiant has participated in consensual investigations. Your Co-Affiant, Gabriel Fabian #542, (Affiant Fabian) is a sworn Special Agent with the Pennsylvania Office of Attomey General (PAOAG), Bureau of Criminal Investigations Organized Crime Section, located at 1000 Madison Ave, Suite 310, Norristown, Pennsylvania 19403. In February 2016, while monitoring a confidential Instagram Account regarding a separate investigation, Affiant Clarke noticed two separate Instagram users, who were using the Instagram handles "bankroliquaa" and "pankrolkilooco," posting logos of banks and requesting other Instagram users to contact them (by “liking” photographs or private messaging through Instagram) if the other Instagram users maintained bank accounts with specific financial institutions After reviewing numerous photographs posted on "bankrollquaa” and "bankrollkiloooo" Instagram's page, it was believed that both live and/or frequent the North Philadelphia area. The profile picture depicted under the "pankroliquaa" Instagram account was later identified as Quadir James Burley (PA SID 41364408) (Quadir). The profile picture depicted under the "bankrollkilocoo" Instagram account was later identified as Shakour Shalik ‘Smith (PA33919310) (Smith). Instagram users "bankrollquaa” and "bankrollkiloooo" would typically remove or delete posts, which requested other Instagram members to contact about various banking institutions, after they were posted on their respective pages for only a few hours. (On Thursday, 03/02/17, Affiant Clarke “liked” a post from “bankrolikiloooo" that requested Instagram users who maintain Pennsylvania State Employee Credit Union (PSECU) bank accounts. Through the “Instagram direct message” (Instagram DM) feature, “bankrollkiloooo” and Affiant Clarke, posing as Instagram user “avatherealonet” (a female), had an online conversation about using his PSECU bank account to make money. “Bankrollkiloooo” explained in the conversation that "avatherealonet” (Affiant Clarke) would have to provide her online banking information, debit card and PIN number to “bankrollkiloooo” and that "bankrolikilocoo” would then mobile deposit a check into the account and then strategically make ATM withdrawals and gift card purchases over two days, After the ATM withdrawals and gift card purchases were completed, “bankrolikiloooo" instructed “avatherealonet” (Affiant Clarke) to report his debit card stolen. “Bankrolikilooco” also informed “avatherealone1” {(Affiant Clarke) that once the ATM withdrawals and gift card purchases were completed; he would receive money in exchange for participation in this fraud scheme. ‘AOPC 411C— Rev. 07/10 Page 1 of 10On Thursday, 03/09/17, Supervisory Special Agent William Ralston (SSA Ralston), Affiant’s Clarke and Fabian met with PSECU Fraud Investigator Matthew Cassel (Cassel) and multiple employees from PSECU at PSECU headquarters. At this time, they discussed multiple fraud investigations that PSECU was currently investigating. At this meeting, PSECU management agreed to provide multiple PSECU fictitious bank accounts and PSECU debit cards to PAOAG investigators to assist in the investigation. (On Tuesday, 03/21/17 at approximately 1504 hours, A‘fiant Clarke began an Instagram DM chat with Instagram user “bankrollquaa’ under the Instagram account handle ‘nef__215g.” The following is the conversation that occurred through Instagram: 1804 Affiant Clarke - Was you the one to talk to if | got a bank acct nd wanna make money 4508 “bankrollqua” ~ Yes 4513 Affiant Clarke ~ Wassup wit it? | got an acct what do I need to do. | aint tryin to get scammed 1814 “bankrollqua” — What bank you with and you won't 1516 Affiant Clarke -PSECU what do | need to do 1548 “bankrollquaa” - What's ya number 1553 “bankrollquaa” -? 1605 Affiant Clarke ~ 215-613-4761 1633 Affiant Clarke - ? Pennsylvania Office of Attorney General Narcotics Agent Nehemiah Haigler (NA Haigler) was assigned to act in an undercover role and pose as "Nefeese Jackson” while using the Instagram handle “nef__215g.” PSECU provided a bank account and Visa debit (4305 8600 1603 0596) in the name of Nefeese Jackson. On Tuesday, 03/21/17, at approximately 1638 hours, NA Haigler received a phone call from 267- 348-7547. NA Haigler missed the phone call and returned the phone call to 267-348-7547. During this phone call an unknown male explained his plan to defraud PSECU to NA Haigler in the following manner: NA Haigler needed to provide his online banking information, his debit card and PIN Number; the unknown male would then deposit a check into his account, and subsequently withdraw the money. The unknown male explained that NA Haigler should report his debit card stolen once all of the transactions were completed and that afterwards they would split the money that the unknown male received. Shortly after this phone call, NA Haigler received the following text from 267-348-7547: lg -Igotta do it before 6 -Bro NA Hagler responded: Page 2 of 10-Yo trying to hit you from another jack On Tuesday, 03/24/17, at approximately 1653 hours, NA Haigler called 267- 348-7547 and spoke with the same unknown male as the previous phone conversation. This phone call was recorded. During this phone call, NA Haigler and the unknown male agreed to meet at the in the parking lot of the Chick-Fil-A in the Cheltenham Mall The unknown male stated that he wanted to get all of NA Haigler's banking information when they met. At this time, SSA Ralston, Affiant Clarke, Special Agent Joseph Chiaro (SA Chiaro), Narcotic Agents Ashley McAteer, Melissa Tamarro, and Affiant Fabian traveled to the Cheltenham Mall located at 2385 W. Cheltenham ‘Avenue Wyncote, Pa 19095 and began conducting surveillance in the Chick-Fil-A parking lot On Tuesday, 03/21/17, from 1723 hours through 1905 hours, multiple text messages and phone calls were exchanged between NA Haigler and the same unknown male using the 267-348-7547 phone number. (On Tuesday, 03/21/17, at approximately 1823 hours, NA Haigler arrived at the Chick-Fil-A. On Tuesday, 03/21/17, at approximately 1905 hours, NA Haigler called 267- 348-7547 and spoke with the unknown male, During this phone call the unknown male informed NA Haigler that he was at Chick-Fil-A. This phone call was recorded. At this time, Affiant Clarke and Affiant Fabian observed a black Chevrolet four door sedan with tinted windows, a distinctive air freshener hanging from the rear view mirror, distinctive scuffs and scrapes on the vehicle, and bearing temporary Pennsylvania registration 2699803. (|t was later determined that this vehicle was reported stolen from a location in Philadelphia on 11/04/16) On Tuesday, 03/21/17, at approximately 1913 hours, the aforementioned Chevrolet sedan pulled near NA Haigler's vehicle. At this time, a black male who had been identified as Quadir Burley (Quadir) exited the driver’s seat of the aforementioned Chevrolet sedan and began speaking with NA Haigler outside of NA Haigler's vehicle. Approximately half way through the conversation NA Haigler invited Qaudir into his vehicle. An unidentified person was observed in the front passenger seat of the aforementioned vehicle. Quadir identified the passenger as his “girl.” The entire conversation between NA Haigler and Quadir was recorded. A brief summary of the conversation of the in person meeting can be summarized as follows: Quadir outlined how a theck will be deposited into NA Haigler’s account. Quadir detailed how he strategically withdrawals the money out of the account on certain days because the bank’s staff isn’t working. After the withdrawals are completed, Quadir will meet up with NA Haigler to split the profits. Quadir instructed NA Haigler to report his debit card losstolen to PSECU after Quadir is done making the transactions. Near the end of this conversation NA Haigler provided Quadir the PSECU Visa debit card (4305 8600 1603 0596) in the name of Nefeese Jackson, the Pin # associated with debit card, the online banking user ID, and the online banking password, Quadir took the PSECU debit card and said, “...!'m about fo call my folks and get some paperwork now.” ‘The conversation ended at approximately 1920 hours Quadir then entered the aforementioned Chevrolet sedan and departed the vicinity of the Cheltenham Mall Surveillance agents followed Qaudir's vehicle until he made an abrupt stop near the intersection of Broad Street and Lindley Street in Philadelphia. Surveillance was then terminated. AOPC 411C - Rev. 07/10 Page 3of 10On Tuesday, 03/21/17, at approximately 1936 hours, Quadir's vehicle made an abrupt stop near the intersection of Broad Street and Lindley Street. At this time, Quadir called NA Haigler from phone number 267-348-7547. This phone call was recorded. During this phone call, Quadir questioned NA Haigler about the passwords needed to log onto his PSECU bank account. On Wednesday, 03/22/17, Matthew Cassel, PSECU Fraud Investigator informed Affiant Clarke through e-mail that the PSECU card assigned to Nefeese Jackson was used at the Sunoco gas station located at 2634 N. Broad Street Philadelphia, Pa 19132 . The debit card was used for a purchase of $1.00; however the purchase was declined due to insufficient funds. The card was then used twice at an ATM, which is located at the same address of the Sunoco for the purpose of a balance inquiry, ‘On Wednesday, 03/22/17 at approximately 1636 hours, a check written from Wells Fargo Bank NA, Routing No. 031000503 Account No, 044115889 to Nefeese C. Jackson in the amount of $6,200.00 was mobile deposited into the PSECU account belonging to Nefeese Jackson. "Work" was written on the memo line. (Definition of mobile deposit - Using the camera in a phone to deposit a check in a bank. An application in the phone takes a picture of the front and back of the check, and both images, along with the dollar value, are transmitted to the bank.) On Thursday, 03/23/17 at approximately 1400 hours, Affiant’s Clarke & Fabian, Pennsylvania Office of Attorney General Supervisory SSA Ralston, SA Chiaro, Special Agent Kevin Schofield (SA Schofield) and Pennsylvania Stale Police Troopers Jovanna Brown (Tpr. Brown) Mark Salemo, Nick Sorivani, Ryan Smith, Jamie Sparenga met at the Pennsylvania State Police Belmont Barracks. At this time, Affiant Clarke and Afiant Fabian explained the investigation to everyone present. ‘Tpr. Brown was assigned to act in an undercover role and pose as “Ava Carter” while using the Instagram handle “avatherealone1." PSECU provided a bank account and Visa debit (4305 8600 1691 1233) in the name of Ava M Carter. (On Thursday, 03/23/17, at approximately 1518 hours, using the Instagram account handle “avatherealonet,” Affiant Clarke started the following conversation with Instagram user “bankrollkiloooo": 1818 - CLARKE — Hey | got my new card. Can | get money today 4519 ~ "bankrollkiloooo” ~ What card 4620 ~ CLARKE - My new PSECU card 128 — "bankrollkiloooo” ~Yes = What's your number = (screenshot of Nefeese Jackson PSECU account) - [just did this one yesterday 1529 —*bankrollkiloooo" - $6200 cleared today 1530 ~ bankrollkilogoo - | need ya number though don't lke ig talk 1532- CLARKE —| want sum 1532 — bankrollkiloooo ~ What's your number : Page 4 of 10 ‘AOPC 411¢ ~ Rev. 07/102 -And Way - You be playing you played last time .. 1537 — CLARKE - 3024501533 - Work - | gave u my number. This must be a scam. 1537 — bankrollkiloooo- A scam , Naw | just think you playing ganes 1538 — Clarke ~ (picture showing PSECU debit card) 1540 — bankrollkiloooo - Okay so Way | just texted you... If we do it by 6 we can make $6200 .. 1541 — bankrollloooo- Do you have online banking? - You'll have a $1000 today. “bankrollkiloooo” then began communicating with Affiant Clarke/Tpr. Brown via text messaging from cell phone number 267-630-1462 ‘On Thursday, 03/23/17, at approximately 1550 hours, an unknown male using phone number 267-630-1462 called Tpr. Brown at telephone number 302-450-1533. The unknown person asked Tpr. Brown how long she had the bank account, if she is able to mobile deposit, and what her spending limits are, The unknown male requested ‘pr. Brown's online banking user name, password, and PIN number. The unknown male identified himself as “Keife." This phone call was recorded. (On Thursday, 03/23/17, at approximately 1557 hours, the same unknown male using phone number 267-630- 1462 called Tpr. Brown at telephone number 302-450-1533, During this phone call, the unknown male informed ‘pr. Brown that her account is ‘not enrolled.’ The unknown male talked about “Ava Carter’ trusting him. The unknown male instructed Tpr. Brown to logon to her PSECU through the website. This phone call was recorded. On Thursday, 03/23/17, at approximately 1619 hours, the same unknown male using phone number 267-630- 1462 called Tpr. Brown at telephone number 302-450-1533. Tpr. Brown informed the unknown person that she enrolled the account online, and the unknown male again asked for Tpr. Brown's online banking user name and password. The unknown male stated that he had already signed onto Tpr. Brown’s account. The unknown male instructed Tpr. Brown to call PSECU and have the mobile deposited set up. This phone call was recorded. Through a text message, Tpr Brown and the unknown person agreed to meet at the “Chili’s” parking lot at 175 East City Ave, Bala Cynwd, Pa 19004 at 1710 hours. On Thursday, 03/23/17, at approximately 1730 hours, a silver Nissan Altima bearing PA registration KHJ-3613 arrived at the meet site. At this time, a B/M who was been identified as Shakour Smith (Smith) exited the aforementioned vehicle and approached and greeted Tpr. Brown. The vehicle was also occupied by two other B/'s who were later identified as Ikeem Starks (Starks) (driver) and Gregory Nathaniel Jackson (backseat passenger). Tpr Brown and Smith had a conversation that can be summarized as follows: ‘AOPC 411C- Rev. 07/10 Page Sof 10Smith stated that hewanted to make Tpr. Brown fee! comfortable, Smith identified himself as “Kiefe.” Smith stated that he wanted to answer any questions that Tpr. Brown had. Smith explained that he will mobile deposit a check into her PSECU bank account. The amount of the check would be $6,200.00. Smith would take a picture of the front of the check and back of the check to complete the mobile deposit. Smith was not sure if the check will clear right away, but the check would definitely clear by tomorrow. Smith talked about another account with which he was currently committing the fraud. (At this time, Smith was showing screenshot photographs to Tpr. Brown of banks accounts that upon which he had already completed this fraud scheme. It is believed that the account that he referenced and showed screenshot photographs was the Nefeese Jackson PSECU account.) Smith informed ‘Tpr. Brown that he would complete a $300.00 ATM withdrawal and then go to Walmart and purchase (3) three $500.00 gift cards. Smith guaranteed Tpr. Brown that if she did not get $1,000.00 that day, she would receive $1,000.00 by the next day. Smith informed Tpr. Brown that she can monitor the transactions on her account as ‘Smith completed the transactions. Smith told Tpr. Brown that he would keep her posted. Smith told Tpr. Brown that they would split the money that will be obtained from this fraud scheme by stating, “...t’s just me and you, 1 get the check made, | pay them up front’. Smith instructed Tpr. Brown to call the bank and report the debit card stolenvost after the transactions. The purpose of reporting the debit card stolervlost would be to save Tpr. Brown from having to pay the money back. Smith stated that the bank will do a "petty investigation” and see that it's a male making the transactions and the bank won't take any further action. Smith stated, “... one thing is for sure, | have been doing this for a long time. I never had nobody go to jail...never. | work with a lot of people... don't got ‘no job.” Tpr. Brown asked Smith if he did it one or two times. Smith responded, “Fuck one or two time, | have done it hundreds of times. | arn a pro at what I do..." Smith stated that he is going to leave the meet site and go get the check. Smith told Tpr. Brown that he is from North’. Smith talked about the possibility of having Tpr. Brown recruit people to participate in this fraud in the future. Smith told Tpr. Brown that he did , ‘probably 15 cards with them” (PSECU). Smith stated that he goes to Police and Fire ATMs to make ATM withdrawals, ‘The entire in person conversation between Smith and “Carter” (Tp. Brown) was recorded Near the end of this conversation Tpr. Brown provided the PSECU Visa debit card (4305 8600 1691 1233) belonging to Ava Carter to Smith (On Thursday, 03/23/17, a check written from the Freedom Credit Union, Routing No. 236084751 Account No. 0060029733 to Ava M Carter in the amount of $5,400.00 was mobile deposited into the PSECU account belonging to Ava Carter. “Work was written on the memo line, ‘On Monday, 03/27/17, Matthew Cassel, PSECU Fraud Investigator provided Affiant Clarke with a list of fraudulent transactions that occurred on the Ava Carter PSECU debit card number 4305 8600 1691 1233. ‘The list of transactions are as follows: 03/23/17 19:25:33 Wal-Mart Store #8103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 ATM Withdrawal $280.00 — Transaction Blocked (On Thursday, 03/23/17, at 1942 hours, Smith sent Tpr. Brown (302-450-1533) a text message from 267-630- 1462 stating, "My phone on 1% trying to get it off so I need you to move fast’. At this time, Smith was trying to have Tpr. Brown call PSECU and verify the purchases because the debit issued to Ava Carter was being declined.) (A surveillance photograph was obtained from Walmart that shows Shakour Smith at the ATM inside the Walmart at the above listed time and date) Page 6 of 10 ‘AOPC 411 — Rev. 07/1003/23/17 19:51:14 Subway Restaurant Attempted Purchase $14.56 03/23/17 20:13:05 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 ATM Withdrawal $80.00 03/23/17 20:13:44 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 ATM Withdrawal $200.00 03/23/17 20:14:33 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 ATM Withdrawal $200.00 Transaction Exceeded (For these Wal-Mart attempted/successful ATM transactions, Surveillance photographs were obtained from ‘Walmart showing Shakour Smith inside the Wal-Mart store at the time of the successful ATM withdrawals) 03/23/17 20:20:20 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 - POS purchase $498.00 03/23/17 20:21:12 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 - POS purchase $498.00 03/23/17 20:22:00 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124- POS purchase $498.00 (For these Wal-Mart POS purchases, surveillance photographs were obtained from Wal-Mart showing Ikeem ‘Starks completing gift card purchases.) 03/24/17 00:34:09 PNC Bank ATM (inside of WaWa) 193 Belmont Avenue Bala Cynwyd, Pa 19004. ATM Withdrawal 280,00 Permanent Restriction 03/24/17 00:35:09 PNC Bank ATM (inside of WaWa) 193 Belmont Avenue Bala Cynwyd, Pa 19004. ATM Withdrawal Inquiry (Surveillance video was obtained from inside the WaWa Store where the PNC Bank ATM is located. The video shows Shakour Smith and Ikeem Starks using two separate ATM machines at the same time. It should be noted that a PSECU debit card in the name of Nefeese Jackson was used at the same time. It appears that Starks received the $500.00 from the PNC Bank (WaWa ATM) from the Jackson PSECU card, while Smith checked the balance on the Carter PSECU card Video surveillance shows Starks operating a silver sedan resembling the Nissan Altima that he was operating at the time of the undercover mest, Smith is a passenger in the vehicle.) 03/24/17 00:54:42 Wal-Mart Store #4687 275 N. Gulph Read King of Prussia, Pa 19406 POS Purchase $.78 Permanent Restriction (Surveillance photographs were obtained from Wal-mart showing Shakour Smith and Ikeem Starks standing at cash register around the time that this transactions was attempted.) On 03/28/17, the check that was mobile deposited into Ava Carter’s account was returned due PSECU unable to locate the account, thus creating a loss of approximately $1,780.00 for PSECU. ‘AOPC 411¢ — Rev. 07/10 Page 7 of 10(On Thursday, 03/23/17 at approximately 0445 hours, Affiant Clarke and Affiant Fabian located the black Chevrolet sedan bearing temporary Pennsylvania registration 2699-803 in the vicinity of 1524 W. Lehigh Avenue Philadelphia, Pa 19132. At this time, Affiant Clarke and Affiant Fabian looked into the vehicle through the front windshield and observed a piece of paper that resembled an ATM receipt in the front cup holder. At this time, the car and VIN number were photographed, The VIN # was partially obscured. (2G4WGSE30D11***** ) (On Friday, 03/24/17 at approximately 1333 hours, NA Haigler attempted to call Quadir (267-348-7547). At this time, Quadir answered the phone call, NA Haigler and Quadir discussed the debit card transactions and Quadir informed NA Haigier that NA Haigler would receive $1,500.00 for participating in the fraud scheme. Quadir and NA Haigler agreed to meet early Sunday morning, 03/26/17. This phone call was recorded. ‘On Sunday, 03/26/17, NA Haigler attempted to call Quadir multiple times at telephone no. 267- 348-7547. After a few phone calls, it appeared that Quadir blocked NA Haigler’s phone because when NA Haigler attempted to call ‘Quadir, the phone call would go directly to voice mail; however, when Quadir’s phone number was called from a different phone, it would not go straight to voicemail. Affiant Clarke also attempted to contact Quadir “pankroliquaa’ through “Instagram Direct Messenger’. Onee Affiant Clarke contacted Quadir from the Instagram account ‘nef__215q', it appeared that Quadir blocked that account, as Instagram user “nef__215g” could no longer view “bankrollquaa’s” Instagram page. However, any other Instagram user was still able to view “pankrollquaa’s” Instagram page. On Monday, 03/27/17, Matthew Cassel, PSECU Fraud Investigator provided Affiant Clarke with a list of fraudulent transactions that occurred on Nefeese Jackson PSECU debit card number 4305 8600 1603 0596, ‘The transactions are as follows: 03/21/17 19:48:29 Sunoco Store No. 0363328604 $1.00 NSF (not sufficient funds) (Surveillance video could not be obtained for this transaction) 03/21/17 19:49:55 2634-44 N. Broad Street -0.00 Invalid PIN Entry Balance Inquiry 03/21/17 19:20:23 2634-44 N. Broad Street - 0.000 Approved Balance Inquiry (Surveillance video could not be obtained for these transactions) 03/23/17 12:37:58 2201 Hunting Park Avenue Philadelphia $500.00 ATM Withdraw! (Surveillance could not be obtained for this transaction. This transaction occurred inside the 39° Philadelphia Police District; however the camera inside the district is not currently operational.) 03/23/17 12:55:29 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 POS Purchase $497.95 03/23/17 12:58:21 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 POS purchase $497.95 03/23/17 12:87:25 Wal-Mart Store #5103 4600 Roosevelt Boulevard Philadelphia, Pa 19124 POS purchase $498.00 AOPC411¢— Rev. 07/10 Page 8 of 10(For these Wal-Mart POS purchases, surveillance photographs were obtained from Wal-Mart showing Ikeem Starks and Shakour Smith completing gift card purchases.) 03/23/17 14:48:51 Sunoco Store No. 0363171002 $1.00 Approved {Surveillance video could not be obtained for this transaction) 03/24/17 00:34:29 PNC Bank (WaWa ATM) 193 Belmont Avenue Bala Cynwd, Pa $500.00 ATM Withdrawal (Surveillance video was obtained from inside the WaWa Store where the PNC Bank ATM is located. The video shows Shakour Smith and Ikeem Starks using two separate ATM machines at the same time. It appears that Starks received the $500.00 from the PNC Bank (WaVVa ATM) from the Jackson PSECU card, while Smith checked the balance on the Carter PSECU card. It should be noted that a PSECU debit card in the name of Ava Carter was used at the same time. Video surveillance shows Starks operating a silver sedan resembling the Nissan Altima that he was operating at the time of the undercover meet, Smith is a passenger in the vehicle.)) 03/24/17 00:55:20 Wal-Mart Store #4687 275 N. Gulph Road King of Prussia, Pa 19406 POS Purchase $497.95 03/24/17 00:56:48 Wal-Mart Store #4687 275 N. Gulph Road King of Prussia, Pa 19406 POS Purchase $497.95 03/24/17 00:58:14 Wal-Mart Store #4687 275 N. Gulph Road King of Prussia, Pa 19406 POS Purchase $498.00 (Surveillance was obtained for the Wal-Mart purchases that were made on 03/24/17 from 00:55:00 ~ 00:58:14.) (Surveillance photographs show Ikeem Starks and Shakour Smith completing gift card purchases.) 03/24/17 01:50:28 Sunoco 0363328604 $1.00 Approved (Surveillance video could not be obtained for this transaction) 03/24/17 02:04:39 — 02:05:09 (five separate transactions from Lyft.com ~ all denied) (Surveillance video could not be obtained for these transactions) (On Wednesday, 03/24/17, the check that was mobile deposited into the Nefeese Jackson's account was returned due to Non-Sufficient Funds, thus creating a loss of approximately $4,000.00 for PSECU. On Wednesday, 03/29/17, PAOAG Analyst Janet Smilowski researched the partial VIN # obtained from the Chevrolet sedan which Quadir was observed operating and which was bearing Pennsylvania registration 2699803. Analyst Similowski was able to identify the complete VIN # (2G1WG5E30D 118403) and determined that the vehicle was listed in NCIC as “stolen.” On Friday, 03/31/17 at approximately 0730 hours, Affiant Clarke and Affiant Fabian began conducting surveillance in the vicinity of 1524 W. Lehigh Avenue Philadelphia, Pa 19132. Philadelohia Police Officers Cedric Carter (6235) and Mark Austin (6876) were positioned nearby to assist Affiant Fabian and Affiant Clarke with surveillance. On Friday, 03/31/17 at approximately, 1040 hours, Affiant Clarke and Affiant Fabian observed the black Chevrolet sedan bearing temporary Pennsylvania registration 2699-803 arrive in the vicinity of 1524 W. Lehigh Avenue. This was the same vehicle that Quadir operated when he arrived at the Cheltenham Mall Chick-Fil-A on 03/22/17 to ‘AOPC 411C— Rev. 07/10 Page 9 of 10meet NA Haigler to receive the undercover PSECU Visa debit card. This vehicle was identified by the make, ‘model, rims, tint, and temporary registration, At this time, Affiant Clarke notified Police Officers Carter and Alston of the presence of the aforementioned stolen vehicle. Officers Carter and Alston initiated a traffic stop on the aforementioned vehicle near the intersection of 16" Street and Lehigh Avenue. James Burley (James), Quadir’s father was found to be operating the stolen vehicle. Will Bush (PA 25943404) was found to be in the front driver's passenger seat. James was arrested by the Philadelphia Police Department and charged with offense related to driving the stolen vehicle (1614089335). James stated that the vehicle belonged to his son, Quadir. Shortly thereafter, Quadir arrived at the location of the traffic stop and retrieved papers related to the vehicle and handed them to Officer Carter. Your Affiants submits that the information contained herein is sufficient to provide probable cause for the issuance of an arrest warrant for Dealing in Unlawful Proceeds, Forgery, Access Device Fraud, Identity Theft, Theft by Unlawful Taking, Criminal Use of a Communication Facility & Bad Checks. |, Justin E. Clarke / Gabriel J. Fabian, BEING DULY SWORN ACCORDING TO THE LAW, DEPOSE AND SAY THAT THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT ARTE oS CpRRECT cy THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. 2 hoc eye (Signature of Affiant) TP soyet Muy ol) Ltttii-— Sworn to me and subsoribed before me 3, 4-30-17 cae My commission expires first Monday of January, 20 2 2 , Magisterial District Judge SEAL ‘AOPC 411¢ ~ Rev. 07/10 Page 10 of 10Please provide the following information for each co-defendant. tah Co-Defendant Data Sheet Docket Number: Date Filed: ‘OTNiLveScan Number ie First Widder JAMES ‘SHAKOUR SMITH. Wane) 5450 WISSAHICKON AVENUE (Come Steet Adaress} PHILADELPHIA, PA 19144 Ci, State, & IP Code) TTatephione eer Namib pCO IKEEM STARKS ‘amey 5126 KNOXX STREET ‘Tome Srast Aaareas) PHILADELPHIA, PA 19144 (City, Stato, £ ZIP Codey Telephone # Co-Defondant# 2, Ware} (Home Steet Aderessy Toit, Stale, €ZIP Codey ‘(reiephone # Wario} ‘Home Stroat daresay | Ci, Stale, € ZIP Code} (retophons AOPC 412A — Rev. 07/10 Page__of _