Complaint filed as to Defendant Abiola Femi Quadri — United States v. Quadri (Dkt. 1, C.D. Cal. No. 2:24-cr-00617)

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U.S. District Court for the Central District of California · No. 2:24-cr-00617-GW · Doc. 1 · 2024-09-19 · Docket on CourtListener

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AUSA Andrew Brown, 11th Floor, x0102 
AO 91 (Rev. 11/11)  Criminal Complaint (Rev. by USAO on 3/12/20)  
܆Original     ܆Duplicate Original
UNITED STATES DISTRICT COURT
for the
Central District of California
United States of America
v. 
ABIOLA FEMI QUADRI, 
            Defendant
Case No.
CRIMINAL COMPLAINT BY TELEPHONE  
OR OTHER RELIABLE ELECTRONIC MEANS
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.  
As described in the accompanying attachment, defendant violated the following statutes: 
Code Sections
Offense Description
18 U.S.C. §§ 1349 and 1028A 
Conspiracy to commit wire and bank 
fraud.
This criminal complaint is based on these facts:
Please see attached affidavit.
_ Continued on the attached sheet.
/s Francisco Solorio Perez
Complainant’s signature
Postal Inspector Francisco Solorio Perez
Printed name and title
Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephone. 
Date:
Judge’s signature
City and state:
Los Angeles, California
Joel Richlin, U.S. Magistrate Judge
Printed name and title
Judge’s sis gnature
. R. Crim. P. 4.1 by y telephon
9/19/24
2:24-mj-05734-DUTY
9/19/2024
CGM
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Complaint Attachment 
 
Count One, 18 U.S.C. § 1349 
 
Beginning in or before 2020, and continuing through the present, in Los Angeles County, within 
the Central District of California, and elsewhere, defendant ABIOLA FEMI QUADRI, and others, 
conspired to commit wire and bank fraud, in violation of Title 18, United States Code, Sections 1343 
and 1344.  The object of the conspiracy was carried out, and to be carried out, in substance, as follows:   
Defendant and his co-conspirators would steal the personal identifying information of victims, and apply 
for disability and unemployment benefits in their names through the California Employment 
Development Department (“EDD”).  Defendant and his co-conspirators would counterfeit disability 
certifications purportedly issued by real doctors, whose identities were also stolen.  Defendant and his 
co-conspirators would take the EDD debit cards, issued through Bank of America, which were credited 
with the fraudulently obtained disability benefits.  Defendant and his co-conspirators would then use the 
EDD debit cards at ATMs to withdraw in cash the benefits.  As a result of this fraud, defendant and his 
co-conspirators defrauded federally-insured financial institutions including Bank of America.  
Defendant and his co-conspirators used interstate wires to defraud their victims throughout this 
conspiracy. 
 
Count Two, 18 U.S.C. § 1028A 
 
Beginning in or before 2020, and continuing through the present, in Los Angeles County, within 
the Central District of California, and elsewhere, defendant ABIOLA FEMI QUADRI knowingly 
transferred, possessed, and used, without lawful authority, a means of identification of another person 
during and in relation to a felony violation of Title 18, United States Code, Section 1349, Conspiracy to 
Commit Wire and Bank Fraud, as charged in Count One, knowing that the means of identification 
belonged to another actual person. 
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AFFIDAVIT 
I, Francisco Solorio Perez, being duly sworn, hereby depose 
and state as follows:  
I.TRAINING AND EXPERIENCE 
1. 
I am a United States Postal Inspector employed by the 
United States Postal Inspection Service (“USPIS”), Los Angeles 
Division, in Los Angeles, California, where I have served since 
August 2019.  I have completed a fourteen-week basic training 
course in Potomac, Maryland, which included training in the 
investigation of identity theft via the United States Mail.  I 
am currently assigned to the USPIS Los Angeles Division, Mail 
Fraud team where my responsibilities include the investigation 
of crimes against the United States Postal Service (“USPS”) and 
crimes related to the misuse and attack of the mail system, 
including theft of Unites States Mail, fraud, and related 
activity in connection with access devices, identity theft, and 
unauthorized use of other persons’ information for financial 
gain. 
2. 
I am familiar with the facts and circumstances 
described herein.  This affidavit is based upon my personal 
involvement in this investigation, my training and experience, 
and information obtained from various law enforcement personnel 
and witnesses, including information that has been reported to 
me either directly or indirectly.  This affidavit does not 
purport to set forth my complete knowledge or understanding of 
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the facts related to this investigation.  Unless specifically 
indicated otherwise, all conversations and statements described 
in this affidavit are related in substance and part only.  All 
figures, times, and calculations set forth herein are 
approximate. 
II.SUMMARY AND PURPOSE OF AFFIDAVIT: COMPLAINT 
3. 
This affidavit is made in support of a criminal 
complaint and arrest warrant against ABIOLA FEMI QUADRI 
(“QUADRI”), for violation of Title 18, United States Code, 
Sections 1349, and 1028A (Conspiracy to Commit Wire and Bank 
Fraud, and Aggravated Identity Theft). 
III.PROBABLE CAUSE STATEMENT 
A. Summary of Probable Cause  
4. 
Based on an investigation by the State of California’s 
Employment Development Department (“EDD”), QUADRI is associated 
with at least 72 fraudulent Unemployment Insurance (“UI”) and 19 
fraudulent Disability Insurance (“DI”) claims that were 
submitted to EDD beginning since 2020.  The personal identifying 
information (“PII”), including social security numbers (“SSNs”), 
of at least 91 suspected victims was used to file these 
fraudulent UI and DI claims. Investigators identified actual 
losses by the State of California of over $800,000 as to the 
fraudulent UI claims and over $200,000 as to the DI claims.  
5. 
EDD associated the claims by commonalities in their 
online applications, such as the purportedly certifying 
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physician or practitioner for the DI claims was often similar.  
Surveillance video depicts QUADRI physically withdrawing funds 
from at least 38 of the accounts at issue that are not in his 
name. 
B. Background on California Unemployment Insurance 
6. 
Since, 1935, the United States Department of Labor’s 
UI program has provided unemployment benefits to eligible 
workers who become unemployed through no fault of their own.  
This program ensures that at least a significant portion of the 
necessities of life -- most notably food, shelter, and clothing  
-- are met on a weekly basis while the worker seeks employment.  
UI beneficiaries who meet requirements set by their state are 
eligible for this temporary financial assistance.  Each state 
administers a separate UI program within the guidelines 
established by federal law.  In the State of California, EDD 
administers the UI program for residents and others physically 
performing work activities in California. 
7. 
Generally speaking, regular UI claimants must be: 1) 
unemployed through no fault of their own; 2) able to, and 
available for, work; 3) willing to accept suitable work; and 4) 
actively seeking work. 
8. 
On March 13, 2020, the President of the United States 
declared the COVID-19 pandemic an emergency under the Robert T. 
Stafford Disaster Relief and Emergency Assistance Act.  As a 
result, Congress passed the Coronavirus Aid, Relief, and 
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Economic Security Act (“CARES Act”), which the President signed 
into law on March 27, 2020.  The CARES Act provided over $2 
trillion in economic relief protections to the American people 
from the public health and economic impacts of COVID-19. 
9. 
Prior to the enactment of the CARES Act, to be 
eligible for UI administered by EDD, a person had to have been 
employed and working in California and received at least a 
certain amount of wages from an employer in the 18 months 
preceding his or her UI benefits claim.  Because of this 
requirement, self-employed workers, independent contractors, and 
employees with insufficient earnings were not eligible to 
receive regular UI benefits. 
10. 
The CARES Act established a new program -- Pandemic 
Unemployment Assistance (“PUA”) -- to provide unemployment 
benefits during the COVID-19 pandemic to people who did not 
previously qualify for regular unemployment insurance benefits 
including business owners, self-employed workers, independent 
contractors, and those with a limited work history who were out 
of business or had significantly reduced their services as a 
direct result of the pandemic.  UI benefits provided under the 
PUA program are sometimes referred to as PUA benefits. 
11. 
Under the PUA provisions of the CARES Act, a person 
who is a business owner, self-employed worker, independent 
contractor, or gig worker can qualify for PUA benefits 
administered by EDD if he or she previously performed such work 
in California and is unemployed, partially unemployed, unable to 
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work, or unavailable to work due to a COVID-19-related reason. 
C. Background on California Disability Insurance 
12. 
DI is a component of the State Disability Insurance 
(“SDI”) program established in 1946.  DI provides partial wage 
replacement benefits to eligible California workers who are 
unable to work due to a non-work-related illness, injury, or 
pregnancy.  DI benefits may also be paid for work-related 
illness or injuries under certain circumstances prescribed by 
law. 
13. 
A DI claim can be filed over the internet using EDD’s 
SDI Online portal, by submitting a paper claim form, “Claim for 
Disability Insurance Benefits” (form DE2501) via mail, or by 
applying in person at a DI office.  The claimant must complete 
part A, “Claimants Statement” of the form DE2501, and have a 
physician/practitioner complete part B, “Physician/Practitioner 
Certificate,” certifying their disability and stating an 
expected release date to return to regular or customary work. 
D. EDD and UI Benefits Are Paid by Debit Card 
14. 
In most cases, EDD UI and DI benefits are paid by 
means of Electronic Benefit Payments to an EDD debit card.  A 
debit card is automatically mailed to claimants who are 
determined eligible for EDD UI and/or DI benefits.  EDD, through 
Bank of America, provides claimants with a Visa debit card that 
is valid for three years from the date of issue.  EDD benefit 
payments for which claimants are eligible are deposited to the 
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debit card account.  Claimants have access to their funds 24 
hours a day, seven days a week at any location where Visa debit 
cards are accepted and at ATMs.  The claimant’s name appears on 
the debit card as the benefit payment recipient.  Once the card 
is received, the claimant activates the card by calling a phone 
number on a sticker placed on the card or by activating it 
online by providing their card number, expiration date, social 
security number and the three-digit security code on the card.  
The debit card has no daily purchase or withdrawal limits, and 
the claimants have full access to their available balance at any 
time, although individual ATM may limit how much their ATMs will 
dispense in a single transaction. 
E. Fraudulent DI and UI Claims Are Filed Under Different Identities 
15. 
EDD Investigator Ivant Romo reviewed approximately 19 
DI claims filed online under approximately 19 different 
identities for an approximate actual loss of $210,156 and a 
potential loss of approximately $436,488.  Investigator Romo 
noticed the DI claims and the certifying physician/practitioner 
portion of the claims were all submitted online, and the 
claimant’s occupation was often the same, among other 
commonalities. 
16. 
Investigator Romo reviewed approximately 72 UI claims 
filed online with the State of California under approximately 72 
different identities.  The approximate actual loss associated 
with the 72 UI claims is $881,192.    
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17. 
Because this affidavit relies on bank records obtained 
in December, 2023, it necessarily does not cover more recent 
frauds in the same detail.  But QUADRI appears to have continued 
the conspiracy through 2024. 
F. QUADRI is on ATM Video Using at Least 38 other Persons’ Accounts  
18. 
On or about December 2023, Investigator Romo received 
surveillance footage from Bank of America, which showed the same 
individual making withdrawals at ATMs under different accounts 
for different persons.  Investigator Romo compared DMV 
photographs of the claimants with that of the surveillance 
footage, and determined the person who appeared on ATM 
surveillance footage did not match any of the claimants’ DMV 
photographs.  Investigator Romo compared DMV photographs of 
QUADRI with that of surveillance footage and identified QUADRI 
as the individual making the withdrawals under at least 38 
accounts, including those of identity theft victims Michelle 
Davey (“Davey”), Ronald Tung (“Tung”), and Douglas Cost (“Cost”) 
as discussed later. 
19. 
Investigator Romo told me he had reviewed social media 
photographs posted by QUADRI that sometimes show him wearing 
unusual or distinctive clothing, which he has also sometimes 
observed in the ATM surveillance photographs of the fraudulent 
withdrawals.  Further, Investigator Romo has personally observed 
QUADRI on the street.  He explained to me that considering his 
personal observations of QUADRI, and the many ATM surveillance 
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photographs he has reviewed, he is sure that QUADRI conducted 
many fraudulent withdrawals. 
20. 
On or about December 19, 2022, Investigator Romo and I 
spoke with Dr. Lai regarding fraudulent DI claims that listed 
Dr. Lai as the certifying physician/practitioner.  Investigator 
Romo showed Dr. Lai approximately four claims associated to 
QUADRI from 2020 and 2022 submitted to EDD which listed Dr. Lai 
as the certifying physician/practitioner.  Dr. Lai stated he did 
not certify any of the four claims and did not authorize anyone 
to complete them on his behalf.  Included in the four claims 
shown to Dr. Lai were two claims filed on Davey’s behalf filed 
on 2021 and 2022 and a claim filed on Tung’s behalf filed on 
2021.  
21. 
I reviewed the fraudulent DI claims filed on behalf of 
Davey and the DI claim filed on behalf of Tung.  Based on my 
review of Davey’s DI claims, there was an approximate total loss 
of $7,366 and a potential loss of $150,644.  Based on my review 
of Tung’s DI claim, there was an approximate total loss of 
$9,471 and a potential loss of $67,600. 
22. 
On or about May 16, 2023, Investigator Romo and I 
spoke with Davey who stated she has never filed a DI claim with 
EDD.  Davey confirmed her date of birth and SSN listed in the 
claim filed with EDD in 2021 and 2022. 
23. 
I compared video surveillance images of ATM 
withdrawals related to Davey’s DI claim and DMV photographs of 
QUADRI; and I am confident that QUADRI is the person captured on 
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ATM video conducting the following transactions using Davey’s 
identity: 
Date 
Location 
Transaction Amount 
4/22/2021 
Los Angeles, CA 
$1,000.00 
4/26/2021 
Altadena, CA 
$1,000.00 
 
24. 
On May 16, 2023, Davey stated she did not give anyone 
permission to possess or use her SSN or to file any DI claim on 
her behalf. 
25. 
On May 16, 2023, Investigator Romo and I spoke with 
Tung who stated he has never filed a DI claim with EDD.  Tung 
confirmed his date of birth and SSN listed in the claim filed 
with EDD in 2021. 
26. 
I compared video surveillance images of ATM 
withdrawals related to Tung’s DI claim and DMV photographs of 
QUADRI; and I am confident that QUADRI is the person captured on 
ATM video conducting the following transactions using Tung’s 
identity: 
Date 
Location 
Transaction Amount 
4/27/2021 
Los Angeles, CA 
$1,000.00 
4/29/2021 
Inglewood, CA 
$1,000.00 
5/01/2021 
Altadena, CA 
$1,000.00 
 
27. 
On May 16, 2023, Tung stated he did not give anyone 
permission to possess or use his SSN or to file any DI claim on 
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his behalf. 
28. 
I reviewed the fraudulent UI claim filed on behalf of 
Cost.  Based on my review of Cost’s UI claim, there was an 
approximate total loss of $19,500. 
29. 
On April 3, 2024, Investigator Romo and I spoke with 
Cost who stated he has never filed a UI claim with EDD.  Cost 
confirmed his date of birth and SSN listed in the claim filed 
with EDD in 2020.  Cost stated he has not lived nor worked in 
California since about 2005. 
30. 
I compared video surveillance images of ATM 
withdrawals related to Cost’s UI claim and DMV photographs of 
QUADRI; and I am confident that QUADRI is the person captured on 
ATM video conducting the following transactions using Cost’s 
identity: 
Date 
Location 
Transaction Amount 
9/01/2020 
Pasadena, CA 
$1,000.00 
9/02/2020 
Pasadena, CA 
$1,000.00 
9/03/2020 
Pasadena, CA 
$1,000.00 
9/05/2020 
Pasadena, CA 
$1,000.00 
9/07/2020 
Pasadena, CA 
$1,000.00 
9/11/2020 
Pasadena, CA 
$1,000.00 
9/12/2020 
Pasadena, CA 
$1,000.00 
9/13/2020 
Pasadena, CA 
$1,000.00 
9/14/2020 
Pasadena, CA 
$1,000.00 
9/15/2020 
Pasadena, CA 
$1,000.00 
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9/17/2020 
Pasadena, CA 
$1,000.00 
 
31. 
On April 3, 2024, Cost stated he did not give anyone 
permission to possess or use his SSN or to file any UI claim on 
his behalf. 
G. QUADRI IS NOT A U.S. CITIZEN AND WILL BE DEPORTED IF CONVICTED 
32. 
On or about July 8, 2024, Special Agent Daisy Garza 
reviewed QUADRI’s immigration status and informed me that he is 
a permanent alien resident.  AUSA Andrew Brown informed me that 
permanent aliens convicted of an “aggravated felony” under 
immigration law lose their status and are deported.  8 USC 
Section 1227(a)(2)(A)(iii).  He also informed me that fraud 
offenses for which the loss exceeds $10,000 count as “aggravated 
felonies” under immigration law.  8 USC Section 1101(a)(43)(M).  
H. QUADRI’S CO-CONSPIRATOR FLED AFTER HIS RESIDENCE WAS SEARCHED 
33. 
On social media, QUADRI has posted several photographs 
of himself with his co-conspirator Roland Iwhiwhu Otega 
(“Otega”).  On August 3, 2023, I executed a federal search 
warrant at Otega’s residence investigating this scheme, which 
revealed evidence of identity theft.  On August 8, 2023, 
according to flight records, Otega flew from Los Angeles 
International Airport to Doha, Qatar then to Lagos, Nigeria, and 
has not returned to the U.S.  Otega and QUADRI appear to have 
shared at least one victim.  In 2023, the address of a DI claim 
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filed on behalf Rosaly Ferrer (“Ferrer”) was updated to Otega’s 
Residence.  QUADRI appears on video surveillance images of ATM 
withdrawals using Ferrer’s identity.     
I. QUADRI HAS BEEN WIRING FUNDS ABROAD 
34. 
Bank records indicate that a JP Morgan Chase Bank 
account for which QUADRI is the signer has been wiring money 
abroad:  from on or about November 13, 2023, to on or about July 
11, 2024, the account was used to wire transactions totaling 
approximately $503,545 to include funds going to Prinx Chengshan 
Shandong Tire Co LTD (Agricultural Bank of China), Eping City 
Hengxin Trading Co LTD (Industrial and Commercial Bank of 
China), Prachi Exports (Yes Bank LTD) and Shouguang Firemax Tyre 
Co LTD (Jinan Rural Commercial Bank Co., LTD).       
J. QUADRI HAS A ONE-WAY TICKET TO DUBAI 
35. 
On September 19, 2024, HSI Special Agent Garza 
conducted a query of QUADRI’s travel records through DHS 
databases. The query revealed QUADRI booked an outbound flight 
departing on September 21, 2024, from Atlanta, GA arriving on 
September 22, 2024, in Dubai, UAE. There is no record of a 
return flight found for QUADRI.  
36. 
AUSA Andrew Brown informed me that there is no 
extradition treaty between the United States and the United Arab 
Emirates. 
/// 
 
 
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IV.CONCLUSION 
37.
For the reasons stated above, there is probable cause 
to believe that ABIOLA FEMI QUADRI violated 18 U.S.C. Section 
1349 (conspiracy to commit bank and wire fraud), and 1028A 
(aggravated identity theft). 
Attested to by the applicant in 
accordance with the requirements 
of Fed. R. Crim. P. 4.1 by 
telephone on this      day of 
September, 2024. 
UNITED STATES MAGISTRATE JUDGE
ED STATES MAGISTRAT
19th
A. Joel Richlin
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