Exhibit B - Memorandum of Investigation — USA v. Ilori et al. (Dkt. 26-2, S.D.N.Y.)

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U.S. District Court for the Southern District of New York · No. 1:21-cr-00746-MKV · Doc. 26-2 · 2022-05-12 · Docket on CourtListener

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DEP ARTM EN T OF JUSTICE | O FFICE O F T HE INSP ECTO R GENERAL
MEMORANDUM OF INVESTIGATION
Prepared By: 
Preparer Title: 
Reviewed By: 
Reviewer Title: 
Damjan S. Hezir
Special Agent
Harry A. Lidsky
Assistant Special Agent in Charge
Signature: 
Signature: 
OIG Form III-210/4 (09/06/2018)   This document contains neither recommendations nor conclusions of the IG. It is the property of the IG 
and is loaned to your agency; it and its contents are not to be distributed outside of your agency.
Case Number:  
Reporting Office: 
2021-009252
Cyber Investigations Office
Execution of Search Warrant and Arrest of Adedayo ILORI on October 8, 2021
Background
On October 7, 2021, at approximately 9:30 PM, Department of Justice, Office of the Inspector General (OIG), 
Cyber Investigations Office Assistant Special Agent in Charge Harry Lidsky and Special Agent Kerwin John
obtained a warrant from the District Court for the Eastern District of New York to search the person of Adedayo 
ILORI, for the seizure of certain evidentiary items related to an ongoing OIG investigation into bank and loan 
fraud involving identity theft (Attachment 1).
Prior to the issuance of the warrant, the OIG observed ILORI operating a White 2021 Mercedes Sedan bearing 
New York registration KMT-9862.  At approximately 9:30 PM on October 7, 2021, ILORI was observed entering
the Mercedes in the area of Purves Street in Long Island City, New York.  The OIG was not able to execute the 
warrant before 10 PM on October 7.
On the morning of October 8, at approximately 8:30 AM, Lidsky, along with OIG Senior Special Agent Gary 
Popadowski and Special Agent Damjan Hezir established surveillance on the parked Mercedes which was 
located on Hannibal Street at Elmira Avenue in the Saint Albans area of Queens, New York.
Evidence Recovery
At approximately 10:15 AM, ILORI was observed approaching and entering the Mercedes.  At that time, marked 
law enforcement agents approached ILORI in an unmarked vehicle and made contact and detained him without 
incident.  ILORI complied with commands and exited the driver’s seat of the Mercedes.  Lidsky informed ILORI 
that he was not under arrest but that the OIG had a search warrant for his person and effects.  ILORI complied
and agents performed a check of his person for weapons.  ILORI was not handcuffed.
Lidsky photographed ILORI’s state issued identification card and returned it to him along with other items 
deemed non-responsive to the warrant.
From the search of ILORI’s person, Lidsky seized the following items:
Digitally signed by DAMJAN HEZIR 
DN: c=US, o=U.S. Government, ou=Dept of 
Justice, ou=OIG, cn=DAMJAN HEZIR, 
0.9.2342.19200300.100.1.1=15001000747083 
Date: 2021.10.25 15:39:51 -04'00'
Digitally signed by HARRY LIDSKY 
DN: c=US, o=U.S. Government, ou=Dept of 
Justice, ou=OIG, cn=HARRY LIDSKY, 
0.9.2342.19200300.100.1.1=1500100230027
3 
Date: 2021.10.25 15:44:09 -04'00'
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Memorandum of Investigation 
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1. Key and key fob believed to be associated with an apartment on Purves Street in Long Island City: 
 
 
 
2. Debit cards in multiple names, FedEx card, New York State debit card, business card, storage unit card, claim 
tickets: 
 
     
 
 
 
 
 
 
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3. Three phones (2 iPhones and 1 Motorola): 
 
     
 
 
From the search of the Mercedes passenger compartment, Hezir located and seized the following items: 
 
1. Samsung cell phone and parking receipt: 
 
 
 
 
From the search of the Mercedes trunk, Hezir located and seized the following items: 
 
1. LG cell phone: 
  
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2. Tax form with handwritten note on back: 
 
 
 
3. Paper bag containing two Pennsylvania driver’s licenses bearing the same photo but different names, 
corresponding debit cards in different names, Nordstrom gift cards, and a business card: 
 
      
 
   
 
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ILORI was provided with a copy of the search warrant with the return section completed serving as an inventory 
of all items seized. 
 
The phones located during the search were evaluated by OIG Senior Digital Investigative Analyst Nathan Wiery 
and Brian O’Neil.  Pursuant to the warrant, Wiery and O’Neil attempted to unlock the seized cell phones using 
ILORI’s face.  ILORI complied during the process. 
 
Arrest and Transport 
 
Following the completion of the search and after reporting cursory findings to Assistant United States Attorney 
Daniel Nessim, Lidsky was instructed to arrest ILORI based on probable cause to believe he had violated the 
conditions of release from his existing case in the Southern District of New York (SDNY).  ILORI was taken into 
custody without incident, was placed into an OIG vehicle, advised of his Miranda rights and was transported 
without questioning.  ILORI was offered the opportunity to make phone calls to advise his family or attorney 
about his arrest and he opted to do so.  ILORI was reminded to advise the callee(s) he was on speaker phone and 
in the presence of government agents and that he should not discuss legal or private matters.  A copy of the 
arrest warrant is included as Attachment 2 and a copy of the phone calls ILORI requested to make as Attachment 
3.   
 
Agents retained possession of the key for the Mercedes to secure the vehicle due to the arrest and transport of 
ILORI.  ILORI’s personal property was kept separate from the items seized during the execution of the warrant. 
 
All law enforcement personnel departed the area of the search at approximately 11:17 AM and arrived at the 
SDNY Courthouse at approximately 12:15 PM.  After waiting in the parking garage for over an hour, agents were 
instructed by Nessim to transport ILORI to the Metropolitan Detention Center (MDC) in Brooklyn, New York.  
Agents arrived with ILORI at MDC at approximately 2:30 PM.  Agents were subsequently instructed by Nessim to 
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refrain from lodging ILORI at MDC pending a potential hearing at SDNY.  Agents waited with ILORI outside of the 
MDC and afforded him the opportunity to make additional calls, which he did, with the same caveats as before.  
Agents were instructed by Nessim to return ILORI to SDNY and did so, arriving at approximately 3:30 PM.  A 
listing of the calls placed on ILORI’s behalf while at MDC is included as Attachment 4. 
 
ILORI’s personal property was provided to his Attorney, Brook Cucinella following completion of ILORI’s bond 
revocation hearing. 
 
Attachments 
 
1. Copy of Search Warrant 
2. Copy of Arrest Warrant 
3. Copy of Calls ILORI Requested to Make During Transport to SDNY 
4. Copy of Calls ILORI Requested to Make While at MDC 
 
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