william martin/usman muhammed affidavit

8/3/2019 William Martin/Usman Muhammed Affidavit

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n iN THE UNITED STATES DISTRICT COURT FOR THEEASTERN DISTRICT OF VIRGINIA : !.TJ jAlexandria Division i\\ JUL H 2011 \Y. . .JUNITED STATES OF AMER ICA

Crim.No. l : l l -MJ-556 :i cL^v"irs^iS'RiCTCOUn"

WILLIAM SAMUEL MARTIN,aka "Awbasa,"aka "Brandon,"aka "BrandonArthur,"

USMAN MUHAMMED,aka "Ush,"aka "Moe,"

Defendants.

UNDER SEAL

A F F I D A V I T I N S UP P O R T O F CRIMINAL C O M P L A I N TAND ARREST WARRANTS

I,Morgan West, Special Agentof theUnitedStatesSecretService, beingduly sworn,s t a t e :

I n t r oduc t i on

1. I submit this affidavit in support of a criminal complaint charging WILLIAMSAMUEL MARTIN andUSMAN MUHAMMED withconspiracy to commit access device fraudin violation of 18 USC 1029(b)(2). I also respectfully request that arrest warrants be issued forMARTIN and MUHAMMED.

2. I have been a Special Agent of the United States Secret Service since 2007. I am

currently assigned to the Washington Field Office inWashington, D.C. My duties as a SpecialAgent include the investigation ofcounterfeiting and financial fraud. During the course ofmy lawenforcement career, I have investigated multiple cases of financial fraud. In addition, inpreparation for my duties asa Special Agent, I received extensive training in the investigation ofcounterfeiting and financial institution fraud, including training inthe investigation and

Case 1:11-cr-00388-AJT Document 2 Filed 07/14/11 Page 1 of 11 PageID# 2


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enforcement of criminal law at the Federal Law Enforcement Training Center. I am authorized toinvestigate violationsof the lawsof the United States.

3. I amcurrently assignedto investigate individualswho illegallyuse creditcardinformation (access devices) to defraudmerchants and financial institutions.

4. The facts and information contained in this affidavit are based upon my trainingand experience, participationin similar investigations, personalknowledge, interviews ofwitnesses, as well as the observations of other officials involved in this investigation, includingfederal, state and local law enforcement officials whom I know to be reliable and trustworthy. All

observations not personallymadeby mewere related to me by the individualswho madethemorwere conveyed to me by my review of records, documents, and other physical evidence obtainedduringthe courseof this investigation. This affidavit containsinformation necessary to supportprobable cause and is not intendedto include eachand every fact and matterobserved bymeorknown to th e Government.

Background

5. Credit card re-encoding is a form of access device fraud, and it beginswith stealinga credit card number. Credit card numbers can be stolen in many ways. A common method ofstealing credit card numbers is by "skimming," whereby a victim's card is run through a smallelectronic device that captures the number from the magnetic strip. Skimming can occur duringthe course of a legitimate transaction, and the victim whose card has been skimmed gets theircredit card back (as opposed to having it stolen, as by a pickpocket). Another method of stealingcredit card numbers is through electronic means, such as using the Internet to hack into a retailer'scomputer system and stealing credit card numbers used at the retailer. A common factor inskimming cases and computer hacks is that the victim has possession of their card when itsnumber is being used for unauthorized purchases. Once a credit card number has been stolen by

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skimming or computer hacking, it is often re-encodedto a card with a magnetic strip that canfunction as a credit card. The end result is a card whose number on th e front does not match th enumber encoded on the magnetic strip. A stolen credit card number can be re-encoded manytimes on many different cards with magnetic stripes, and the stolen number can be used by asuspect until the victim or the victim's servicing financial institution detects the fraud and disablesthe card number. Suspects sometimes use re-encoded cards to purchase merchandise that is laterreturned for cash. More frequently, suspects use re-encoded cards to purchase gift cards. Thesuspects then use the gift cards to purchase merchandise that is later returned for cash. Once a giftcard's value is exhausted, it is still useful to a criminal, who can re-encode it with a stolen creditcard number. Once the gift card is re-encoded with a stolen credit card number, a suspect can useit to purchase merchandise or more gift cards, and the cycle begins again.

6. MARTIN and MUHAMMED have been friends since they attended middle schooltogether in the late 1990s. They commit access device fraud both together and separately.

De t a i l s of the S c h eme

Th e Illegally Re-encoded Access Devices7. On or about January 30,2010, MARTIN attempted to make a purchase at Macy's

in Arlington, Virginia, using gift cards that had been re-encoded or purchased using a stolen creditcard number. Due to his suspicious use of gift cards, a Macy's employee called the ArlingtonCounty Police Department ("ACPD"). An ACPD officer located MARTIN andbriefly detainedhim for questioning. MARTIN wasquestioned by theofficer insidethe security officeat theMacy's. MARTIN consented to a cursory search ofhis person, and the officer found several giftcards. MARTIN voluntarily surrendered the cards to the officer. MARTIN said that he hadobtained the gift cards from his roommate.



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8. The ACPD officer who stopped MARTIN sent MARTIN on his way because therewasnothing obviously fraudulent about the gift cards, andMARTIN's purchases wentthrough.Later, the officergavethe cards to anACPDdetective, who ran the cards through a BankIdentificationNumber ("BIN") reader. A BIN reader visually displays the card number on themagnetic strip of a card. When the detective swiped the cards MARTIN had surrendered to policethrough the BIN reader, it showed that all of the cards had been re-encoded.

9. I researched the numbers that came up on the BIN reader and found that all of themwere issued to victims living outside ofVirginia. Many charges were made using the card

numbers after MARTIN voluntarily surrendered his re-encoded cards. The charges includerepeated purchases of gift cards at various merchants, many of them within severalmiles ofMARTIN ' s residence.

10. I have researched the stolen credit card numbers on the car ds t ha t MARTINvoluntarily surrendered. From approximately January 26,2010 through approximately February8,2010, the fraudulent use of those card numbers caused approximately $5,875 in fraud loss, plusapproximately $811 in attempted loss to four separate financial institutions.

11. MARTIN did not surrender all of the cards in his possession to ACPD when he wasdetained. The receipt for MARTIN's purchase at Macy's shows that MARTIN made the purchaseusing a gift card. Bank and merchant records show that this gift card was purchased on January16, 2010 in Temple Hills, Maryland using a stolen credit card number. The number on the gift

card, however, was not on any of the magnetic strips on any of the cards that MARTIN voluntarilysurrendered. This indicates that MARTIN had at least one more re-encoded card on his personwhen he was stopped by the ACPD officer.

12. On June 15, 2010,1 interviewed MARTIN. When asked about the cards MARTINsurrendered to the ACPD officer on January 30,2010,MARTIN stated that he purchased the re-

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encoded gift cardsdescribed above from a person MARTIN knewonlyas "Mike." MARTINstated that he had just graduated from BowieState University ("BSU") in Bowie,Maryland andthatMikehangsout on the BSUcampus. MARTIN indicated that many students knewthat Mikewasdealingin fraudulent creditcards. MARTIN statedthat he purchased the cards fromMikefor$250 each with the understanding that each card had a value of$500. MARTIN initially statedthat Mike claimed to have received the cards as gifts but later admitted that he knew there wassomething illegal about the cards.

Going on "Moves"

13. On or about February 22, 2011, law enforcement conducted surveillance asMUHAMMED led a criminal scheme where gift cards were purchased with forged access devices,and merchandise purchased with fraudulently obtained gift cards was returned for cash.

14. Confidential Informant 1 ("CI 1") is an associate ofMUHAMMED's. I know CI1to be credible from their track record, the fact that they have made statements against their owninterest, and my corroboration ofCI1 's statements. "Moves" is a term MUHAMMED and othersuse to collectively refer to the purchasing of gift cards with forged access devices and the return ofmerchandise purchased with fraudulently obtained gift cards. CI1 has worked as a "runner" forMUHAMMED many times. Runners help criminals conceal their activity. Runners fill manyroles in credit card fraud cases. Some runners will be given a forged access device and directed tobuy gift cards. Other runners will be directed to purchase merchandise with the gift cards. Stillother runners will be given the fraudulently obtained merchandise and directed to return it to aretailer for cash. Nordstrom is particularly favored by criminals committing access device fraudbecause Nordstrom has a lenient return policy and will accept returns and give the customer cash.CI1 's return history at Nordstrom totals approximately $24,774 and is mostly confined to returnsmade at stores in Fairfax County and Arlington, Virginia, within the Eastern District ofVirginia.

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15. On or about February 21,2011, MUHAMMED called CI1 and asked that CI1 goon "moves." MUHAMMED also told CIl that CIl would be returning a pair of expensive shoesto a Nordstrom store.

16. On or about February 22, 2011, law enforcement observed MUHAMMED pick CIlup at CIl's residence. MUHAMMEDwas driving a vehicle registered to Olubunmi Komolafe,who was also in the car. CIl had an audio recording device on their person. MUHAMMEDdrove CIl and Komolafe to a Target store in Bowie, Maryland. This particular Target store's ownreceipts, however, show it in Lanham, Maryland.

17. CIl told me that when they arrived at the Target, MUHAMMED gave CIl severalgift cards, which CIl understood had been re-encoded with stolen credit card numbers. CIlentered the Target store and used the cards MUHAMMED had provided to purchaseapproximately $2,500of gift cards. While CIl was inside the Target making the purchases,Komolafe was also inside, watchingCI l and conducting counter-surveillance. When CIl returnedto the car, CIl gave the gift cards to MUHAMMED.

18. Next, MUHAMMED drove CIl and Komolafe to a Target store in Wheaton,Maryland. Along the way, Komolafe made comments to MUHAMMED about how relaxed CIlseemed.

19. When the car arrived at the Wheaton Target store, CIl observed MUHAMMEDoperate a laptopcomputer. CIl told me later that theywatched MUHAMMED type a fewkeystrokes intoa program, and then a namewouldappearwith a longstringof numbers.MUHAMMEDwould delete the name, and then swipe a credit card through a piece of electronichardware attached to the computer. CIl said that this was MUHAMMED's process to re-encodecards. CIl said thatMUHAMMED woulddeletethe name from the screenbecause that preventedthe name from being printed on any receipts. A printed nameon a receipt might arouse the



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suspicions ofa store clerk if the name did not appear to match the customer making the purchase(e.g., awoman's name and amale customer). I know from training and experience thatCIl'sdescription ofMUHAMMED's swiping ofcards isan accurate description ofthe process bywhich access devices are re-encoded with stolen credit card numbers.

20. AfterMUHAMMED illegally re-encoded several accessdevices, he gave theforged access devices to CIl. The re-encoded access devices were to beused for purchasing giftcards.

21. Law enforcement watched as all three people exited Komolafe's car.

MUHAMMED putan object inthe trunk ofthecar, which CIl told me later was theelectronicdevice that MUHAMMED was using to re-encode cards.

22. Law enforcement watched all three people as they entered the Wheaton Targetstore. Inside, CIl purchased approximately $1,750 of gift cards. WhenCIl returned to the car,CIl gave the gift cards to MUHAMMED.

23. In the Wheaton Target,MUHAMMED becamesuspicious that storepersonnel hadcaught onto CIl. MUHAMMED toldCIl thatMUHAMMED was going to leave Komolafe, andthat MUHAMMED and CIl would continue on. MUHAMMED then drove CIl on Interstate 495acrossthe Maryland-Virginia state line. OnceMUHAMMED had crossed into Virignia, he droveto the Nordstromat the Tyson's Corner Mall. CIl entered the Nordstrom with a shoebox, but CIlwas unable to mak e a retu rn for cash.

24. MUHAMMED paid CIl in gift cards forCIl's work as a runner. CIl gave thosegift cards to me, along with a number of receipts from both the Lanham and WheatonTargetstores. I researched some of the credit card numbers associated with the receipts and found thatthey were used without the authorization of the genuine cardholder, and that the genuinecardholder still had the card in their possession when the unauthorized purchases were made.

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Skimming25. On April 1,2011,1 interviewed Confidential Informant 2 ("CI2"). I located CI2

through a contact I found on two phones, both belonging to MARTIN, incident to an arrest inNovember 2010. MARTIN sometimes uses the aliases "Brandon Arthur" or "Brandon" whenengaging incriminal activity. The contact was named "[CI2's name] Ms Grill" onMARTIN'sprimary phone and "[CI2'sname] msgrill" on"Brandon's" phone. There were text messages on"Brandon's" phone that showed that CI2 may have been involved in access device fraud. Ilearned through investigation, thata person with CI2'sname was working at the McCormick&Schmick's restaurant in Oxon Hill, Maryland.

26. CI2 told me that in or about October 2010, CI2 was working as a server at theMcCormick& Schmick's restaurantin OxonHillwhena couplewas seatedat one of CI2's tables.Themale inthecouple identified himselfas"Moe." At theconclusion of theirmeal, "Moe" askedCI2 if CI2was interested in makingmoremoney. CI2 told"Moe" "yes." "Moe" paidfor themealwith a creditcard and had CI2 put CI2's phone numberon the receipt so that "Moe" couldcontactCI2 lateraboutmaking moremoney. "Moe"contacted CI2 the following day, eitherbyphone call ortextmessage. "Moe" told CI2 that"Brandon" would be contacting CI2 on"Moe's"behalfabout making more money.

27. "Brandon" contacted CI2 and they arranged to meet in the parking lot of aMcDonald's in Maryland. "Brandon" arrived in a white BMW. "Brandon" got intoCI2's vehicleand provided CI2 witha black box. "Brandon"toldCI2 to swipeCI2's customer's creditcardsthrough the black box when they paid for their meal. "Brandon" said hewould collect the box atthe end of the week and pay CI2 based on the number ofcredit cards found on the black box."Brandon" offered to pay CI2 $20 per card numberfoundon the black box. "Brandon" claimedthat he sends the black box overseas and also gets paid for each card number that he provides.

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28. CI2's description of the small black box described above is consistent with what Iknow from training and experience to be a credit card "skimmer." A skimmer is a small electronicdevice that a suspect uses to swipe and store victims' credit card numbers.

29. "Moe" followed-up with CI2 by text message to see if CI2 was using the black box.CI2 told "Moe" that CI2 was not using it and that CI2 did not want to be involved. "Brandon" metCI2 in the same McDonald's parking lot and collected the black box back from CI2. CI2 saidBrandon acted indifferent when he took the black box back and acted as though he had anotherserver to give it to. "Moe" contacted CI2 again a fewdays later to make sure CI2 was not

interested in participating, and CI2 again declined.30. CI2 identified a photo ofMUHAMMED as the man she knows as "Moe" in an

individual photo. CI2 also identified a photo ofMARTIN as the man she knows as "Brandon" ina photo line-up.

31. I have reviewed textmessages sent between MARTIN andMUHAMMED datingfrom October 2010. I alsoreviewed textmessages from CI2's phone. I found textmessages thatcorroborated CI2's recollection and showthatMARTIN andMUHAMMED conspired together toprovide CI2witha skimmer. Some of the textmessages are excerpted here:MUHAMMED to CI2

MUHAMMED to CI2

CI2 t o MUHAMMED

MUHAMMED to CI2

CI2 to MUHAMMED

10/25/1001:15:20 Wasup thisMOE. I wasjust in there. Howu(GMT)10/25/10 03:53:13 Yea and what I was talkin about . U wanna(GMT) make$

10/25/10 03:54:16 Lol ok. What's the plantomake money(GMT)10/25/10 04:51:55 So u wanna make money(GMT)10/25/10 04:52:33 Yea how?(GMT)



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MUHAMMED to CI2

CI2 to MUHAMMED

MUHAMMED to CI2

MUHAMMED toMARTINMUHAMMED toMARTINMARTIN toMUHAMMEDMUHAMMED toMARTIN

MARTIN toMUHAMMEDMARTIN toMUHAMMEDMARTIN to CI2

MUHAMMED to C I2

MUHAMMED to CI2

MUHAMMED to C I2

MUHAMMED to CI2

CI2 to MUHAMMED

10/25/10 04:53:48(GMT)10/25/10 04:55:42(GMT)10/26/10 01:43:12(GMT)10/26/10 03:01:26(GMT)10/26/10 03:12:27(GMT)10/26/10 03:13:00(GMT)10/26/10 03:21:56

(GMT)

10/26/10 03:33:58(GMT)10/26/10 04:26:44(GMT)10/26/10 04:29:07(GMT)

10/26/10 22:17:54(GMT)10/27/10 16:30:03(GMT)10/27/10 23:30:55(GMT)10/28/10 01:58:57(GMT)10/28/10 02:07:19(GMT)

In the restaurant. Somethin easy

I'm listening?

Yo call me when uget of f

Thatgirl should b hittinme soon. Shegetoffa t 11Aytell her 20$

Ok

Fucksonmyphone about to die. I willhaveto charge it tommorow. Email me herresponse

Ok

She sound sexy. Pulln up now

Its arena dr if u aint figure it out yet. Comingfrom 495 u gon make a right by theapplebeesEverything good on ur end???

Get it poppin today!! $$

Call me when u get off

Any progress today

Im not getting involved with that

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"Brandon" to CI2 10/29/10 03:17:37 Ima come get that thing from u tomm. What(GMT) time r u free? This brandon,3Conc lu s i on

32. Based on the information contained in this affidavit, there is probable cause tobelieve that in or about January 2010, through February 2011, in the Eastern District ofVirginiaand elsewhere, WILLIAM SAMUEL MARTIN and USMAN MUHAMMED, conspired tocommit access device fraud in violation of 18 U.S.C. 1029(b)(2).

/

Sworn to and subscr ibed before methis 14th day ofJuly, 2011/s/Thomas Rawlea Jones, Jr.Hon. T. Rawles Jones, Jr. rUnited States Magistrate JudgeAlexandria, Virginia

/MorganWestSpecial Agent

k-United States Secre t Service

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william martin/usman muhammed affidavit

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