Court filing

Sealed Complaint — United States v. Lewis (Dkt. 1, S.D.N.Y.)

Summary

A sealed complaint in United States v. Russell Dwayne Lewis, Case 1:23-cr-00032-LTS (S.D.N.Y.), filed August 16, 2022. Joseph Strawman, a Special Agent with the Federal Bureau of Investigation, charges three counts of wire fraud and one count of aggravated identity theft for conduct from about 2016 to 2020. The complaint alleges that Lewis claimed to be a billionaire investor to solicit at least approximately $3 million from Victim-1 and at least approximately $555,000 from Victim-2, and claimed to be the president of a purported family office trust to induce Corporation-1 to sell its assets to Lewis. It lists aliases including Clifford Ari Getz and Aryeh Getz and alleges that Lewis used the name and date of birth of another person, Victim-3, in credit card applications and in client documents submitted to a bank. The 14-page complaint asks that Lewis be arrested.

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Filed August 16, 2022 in Russell Dwayne Lewis; one of 1 filings from this case.

Record facts

Court	U.S. District Court for the Southern District of New York
Filed	2022-08-16

Cite this document

“Sealed Complaint — United States v. Lewis (Dkt. 1, S.D.N.Y.).” U.S. District Court for the Southern District of New York, No. 1:23-cr-00032, Doc. 1, filed 2022-08-16. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/nysd-1-23-cr-00032/2022-08-16-sealed-complaint-dkt-1/, SHA-256 569b598a69d3fcfab8ac4a23e4b41ac0fb83b605bbab382eb445d6775b11035f.

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Full text

Case 1:23-cr-00032-LTS Document 1 Filed 08/16/22 Page 1 of 14

Approved:
/ MATTHEW PODOLSKY
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Assistant United States Atto:lC'neys
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Before: HONORABLE BARBARA MOSES
United States Magistrate Judge
Southern District of New York
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UNITED STATES OF AMERICA SEALED COMPLAINT

- v. - Violations of
RUSSELL DWAYNE LEWIS, 18 u.s.c. §§ 1343,
a/k/a "Clifford Ari Getz," 1028A, and 2
a/k/a "Clifford Ari Getz Cohen,"
a/k/a "Ari Getz," COUNTY OF OFFENSE:
a/k/a "Aryeh Getz," NEW YORK

Defendant

SOUTHERN DISTRICT OF NEW YORK, ss.:

JOSEPH STRAWMAN, being duly sworn, deposes and says
that he is a Special Agent with the Federal Bureau of
Investigation, and charges as follows:

COUNT ONE
(Wire Fraud)

1. From in or about 2016, up to and including in or
about 2020, in the Southern District of New York and elsewhere,
RUSSELL DWAYNE LEWIS, a/k/a "Clifford Ari Getz," a/k/a "Clifford
Ari Getz Cohen," a/k/a "Ari Getz," a/k/a "Aryeh Getz," the
defendant, knowingly, having devised and intending to devise a
scheme and artifice to defraud, and for obtaining money and
property by means of false and fraudulent pretenses,
representations, and promises, did transmit and cause to be
transmitted by means of wire, radio, and television
communication in interstate and foreign commerce, writings,
signs, signals, pictures, and sounds for the purpose of
executing such scheme and artifice, to wit, LEWIS falsely
claimed to an individual ("Victim-1") that he was a billionaire
investor in in order to solicit purported loan and investment
payments of at least approximately $3 million from Victim-1,
virtually none of which was ever paid back to Victirn-1.

(Title 18, United States Code, Sections 1343 and 2.)

Case 1:23-cr-00032-LTS Document 1 Filed 08/16/22 Page 2 of 14

COUNT TWO
(Wire Fraud)

2. In or about 2020, in the Southern District of New
York and elsewhere, RUSSELL DWAYNE LEWIS, a/k/a "Clifford Ari
Getz," a/k/a "Clifford Ari Getz Cohen," a/k/a "Ari Getz," a/k/a
"Aryeh Getz," the defendant, knowingly, having devised and
intending to devise a scheme and artifice to defraud, and for
obtaining money and property by means of false and fraudulent
pretenses, representations, and promises, did transmit and cause
to be transmitted by means of wire, radio, and television
communication in interstate and foreign commerce, writings,
signs, signals, pictures, and sounds for the purpose of
executing such scheme and artifice, to wit, LEWIS falsely
claimed to employees and representatives of a corporate entity
engaged in a sale of its assets and intellectual property
("Corporation-1") that he was a billionaire and the president of
a purported family office trust that invested in distressed
organizations, in order to fraudulently induce Corporation-1 to
engage in a sale of its intellectual property and assets to
LEWIS.

(Title 18, United States Code, Sections 1343 and 2.)

COUNT THREE
(Wire Fraud)

3. In or about 2020, in the Southern District of New
York and elsewhere, RUSSELL DWAYNE LEWIS, a/k/a "Clifford Ari
Getz," a/k/a "Clifford Ari Getz Cohen," a/k/a "Ari Getz," a/k/a
"Aryeh Getz," the defendant, knowingly, having devised and
intending to devise a scheme and artifice to defraud, and for
obtaining money and property by means of false and fraudulent
pretenses, representations, and promises, did transmit and cause
to be transmitted by means of wire, radio, and television
communication in interstate and foreign commerce, writings,
signs, signals, pictures, and sounds for the purpose of
executing such scheme and artifice, to wit, LEWIS falsely
claimed to a second individual ("Victim-2") that he was a
billionaire investor in order to solicit a purported real estate
investment of at least approximately $555,000, virtually none of
which was ever paid back to Victim-2.

(Title 18, United States Code, Sections 1343 and 2.)

Case 1:23-cr-00032-LTS Document 1 Filed 08/16/22 Page 3 of 14

COUNT FOUR
(Aggravated Identity Theft)

4. From in or about 2016, up to and including in or
about 2020, RUSSELL DWAYNE LEWIS, a/k/a "Clifford Ari Getz,"
a/k/a "Clifford Ari Getz Cohen," a/k/a "Ari Getz," a/k/a "Aryeh
Getz," the defendant, knowingly did transfer, possess, and use,
without lawful authority, a means of identification of another
person, during and in relation to a felony violation enumerated
in Title 18, United States Code, Section 1028A(c), to wit, LEWIS
used, transferred, and possessed the name of another individual
in connection with the wire fraud offenses charged in Counts
One, Two, and Three of this Complaint.

(Title 18, United States Code, Sections 1028A(a) (1),
1028A(b), and 2.)

The bases for my knowledge and for the foregoing
charges are, in part, as follows:

5. I am a Special Agent with the Federal Bureau of
Investigation, and I have been personally involved in the
investigation of this matter. I am familiar with the
information contained in this affidavit based on my own personal
participation in the investigation, my review of documents, and
conversations that I have had with other law enforcement
officers and other individuals. Because this affidavit is being
submitted for the limited purpose of establishing probable
cause, it does not include all the facts I have learned during
the course of my investigation. Where the contents of documents
and the actions, statements, and conversations of others are
reported herein, they are reported in substance and in part,
except where otherwise indicated.

Overview of the Fraudulent Schemes

6. As set forth below, since at least 2016, and up
to and including at least 2020, RUSSELL DWAYNE LEWIS, a/k/a
"Clifford Ari Getz," a/k/a "Clifford Ari Getz Cohen," a/k/a "Ari
Getz," a/k/a "Aryeh Getz," the defendant, engaged in a series of
brazen schemes to misrepresent his identity, his wealth, and his
professional and personal background in order to defraud
multiple individuals and at least one corporate entity. For
years, LEWIS has been living under assumed names, using the
birth date of a real individual with the name of one of his
aliases, and utilizing the social security number of yet another
individual. As opportunities arose, LEWIS told increasingly
outrageous and damaging lies to individuals around him,
including a close friend of many years; an individual who turned

Case 1:23-cr-00032-LTS Document 1 Filed 08/16/22 Page 4 of 14

to him for his claimed expertise in astrology; employees and
representatives of a major company he falsely purported to
intend to purchase; and employees he "hired" with no intent or
ability to pay.

7. In total, RUSSELL DWAYNE LEWIS, a/k/a "Clifford
Ari Getz," a/k/a "Clifford Ari Getz Cohen," a/k/a "Ari Getz,"
a/k/a "Aryeh Getz," the defendant, swindled the victims
described herein out of more than $3.5 million, driving both
Victim-1 and Victim-2 into destitution and bankruptcy, and
wasting weeks of time and thousands of dollars of Corporation-1
as it attempted to exit bankruptcy proceedings.

Fraud Against Victim-1

8. Based on my participation in this investigation,
including my review of records, such as electronic
communications obtained voluntarily as well as pursuant to
judicially-authorized search warrants; financial, payment, and
banking records; and my interviews of individuals, including
Victim-1, and my discussions with other law enforcement
officers, I have learned the following:

9. Over the course of approximately four years,
RUSSELL DWAYNE LEWIS, a/k/a "Clifford Ari Getz," a/k/a "Clifford
Ari Getz Cohen," a/k/a "Ari Getz," a/k/a "Aryeh Getz," the
defendant, befriended Victim-1, became his close friend and
confidant, hired him purportedly to help operate and manage a
family office worth billions of dollars, and defrauded him out
of more than $3 million.

LEWIS and Victim-l's Personal Relationship

a. Until he met LEWIS, Victim-1 was a
successful businessman living and working in Southern
California. In or about 2016, Victim-1 met LEWIS, whom Victim-1
knew as Clifford Ari Getz Cohen. Victim-1 had been working for
many years at his family's business. LEWIS and Victim-1 first
came to know each other through exercising at the same gym, and
they quickly became friends. In the coming months, the
friendship between LEWIS and Victim-1 deepened, becoming
essentially familial. LEWIS was extremely charismatic, and
Victim-1 confided in him about challenges in his personal life
and his professional career. In turn, shortly after they met,
LEWIS told Victim-1 that he was worth approximately $30 billion,
but that he was highly secretive and kept a low profile.

b. LEWIS claimed to Victim-1, in sum and
substance, that his wealth was all in trusts and that he did not

Case 1:23-cr-00032-LTS Document 1 Filed 08/16/22 Page 5 of 14

himself own anything directly. LEWIS further claimed that his
wealth came from real estate investments and from standby
letters of credit, which he said were highly lucrative. LEWIS
told Victim-1 that he directed much of his income to charitable
causes, and that he invested the rest in ways that returned
profits multiple times over. He stated or implied that all of
his assets were overseas, due to the international nature of his
claimed businesses, and he occasionally said there were issues
with getting his money into domestic accounts.

c. LEWIS also confided to Victirn-1, falsely,
that he had worked for the Central Intelligence Agency, that he
had been born in London, United Kingdom, that he had lived in an
Orthodox Jewish community, and that he was a rabbi. Victim-1
attempted to find information about "Getz" online; when he was
unsuccessful, LEWIS told him that the lack of online footprint
was intentional. LEWIS claimed, in sum and substance, to be
extremely private and reclusive.

d. As part of their increasingly close
friendship, and believing that LEWIS was a successful
businessman, Victim-1 solicited professional and investment
advice from LEWIS. In approximately July 2016, LEWIS told
Victim-1, in sum and substance, that a partner of LEWIS was
working on a particular app for businesses. In response,
Victim-1 gave LEWIS a significant amount of money for the first
time, providing $25,000 for additional development of the
purported app and other potential projects. LEWIS drafted a
"Memorandum of Understanding" reflecting Victim-l's investment.

e. During approximately the second half of
2016, LEWIS and Victim-1 began to discuss a possible further
business relationship. In particular, they discussed Victim-l's
corning to work for LEWIS and sourcing business opportunities in
which LEWIS could invest some of his supposedly vast wealth. In
approximately early 2017, Victirn-1 left his job and began
working for LEWIS, including more formally in approximately late
2017 at an office LEWIS appeared to rent. During that time,
Victim-1 observed that LEWIS's work was largely unstructured,
and he understood that it was his role to, in part, focus
LEWIS's attention on worthwhile business opportunities.

f. During 2017, LEWIS continued to ask Victim-1
for "loans" or investments, and Victim-1 complied. Over time,
the relationship between LEWIS and Roberts became closer, to the
level of family, and eventually Victim-1 trusted LEWIS
completely. Victirn-1 viewed LEWIS as a mentor and spiritual
guide and started regularly joining LEWIS for religious services

Case 1:23-cr-00032-LTS Document 1 Filed 08/16/22 Page 6 of 14

and meals, as well as leaning heavily upon LEWIS for support and
advice in his personal life.

g. At the same time, Victim-1 was working
extensively to explore opportunities in business and finance, to
be able to assist LEWIS in identifying productive investment
opportunities. LEWIS also continued to ask Victim-1 for money,
which was characterized as investments and/or loans, and which
Victim-1 routinely provided. Victim-1 believed that LEWIS
always had a business reason for asking for money, and
Victim-l's belief that the money was being utilized for
investment projects was at times bolstered by the very specific
amounts LEWIS requested. Victim-1 repeatedly asked about being
repaid, and LEWIS consistently promised that Victim-1 would be
reimbursed eventually.

Victim-l's "Employment" for LEWIS

h. Victim-1 worked for LEWIS between
approximately 2017 and 2020. Victim-l's role was to find
investment opportunities for LEWIS, particularly in the fashion
and retail spaces, in which LEWIS appeared interested. During
much of that time, LEWIS had office space in Beverly Hills,
California, including two rented suites in the same office
building.

i. LEWIS also employed, or appeared to employ,
other individuals at his offices. In addition to several
individuals who appeared to be working on fashion-related
projects, LEWIS, with the assistance of Victim-1, hired an
individual in approximately March 2020 ("Individual-1").
Individual-1 had a background in business administration,
including auditing and work in finance and operations for
startup companies. Individual-1 initially was hired as Chief
Accounting Officer for LEWIS, who described the job
responsibilities as including helping with due diligence,
tracking financial investments, and researching and evaluating
investment opportunities. In particular, LEWIS told
Individual-1 that he was looking for high-growth opportunistic
investments. LEWIS told Individual-1, in sum and substance,
that his company was funded entirely by his and his family's
money, and that there was plenty of liquidity to make
investments and purchases. Shortly after Individual-1 was
hired, Individual-1 was promoted to Chief Financial Officer.
LEWIS falsely represented to Individual-1 that he was worth more
than $10 billion. LEWIS promised Individual-1 an annual salary
of hundreds of thousands of dollars; she was never actually
paid.

Case 1:23-cr-00032-LTS Document 1 Filed 08/16/22 Page 7 of 14

j. Victim-1 and Individual-1 both worked on
evaluating possible investments and acquisitions. Neither one
had visibility into any accounts in the name of "Getz" or any of
his purported companies. However, they believed he had the
money to make the investments they researched, some of which he
suggested and some of which they proposed. Victim-1 undertook
due diligence on several possible deals between 2018 and 2020;
although none of the deals came to fruition, LEWIS always had a
reason or explanation. In 2020, at LEWIS's direction, both
Victim-1 and Individual-1 spent time working directly with
representatives of companies for possible investments,
undertaking significant efforts to, for example, review and edit
term sheets, examine data, and perform due diligence. When a
payment date would approach for a deal, however, LEWIS would say
that his money was tied up abroad, and that he was unable to
access his wealth. LEWIS also blamed the COVID pandemic, which
he said made international banking difficult.

k. In particular, and as further described
below, both Victim-1 and Individual-1 were involved with the
negotiations regarding Corporation-1. Victim-1 saw an article
online about the bankruptcy proceedings of Corporation-1 and
brought it to LEWIS's attention. LEWIS claimed to be interested
in purchasing Corporation-1, and Victim-1 and Individual-1
contacted representatives of Corporation-1 to convey LEWIS's
offer to purchase the company for approximately $290 million.

1. In the following weeks, Victim-1 and
Individual-1 both spent significant time and effort to pursue
the bid and to undertake due diligence. That included, but was
not limited to, reviewing relevant Corporation-1 leasing deals,
real estate holdings, and cash flow information, as well as
other financial and business materials and records. Victim-1
and Individual-1 also interacted extensively with
representatives from Corporation-1. Nevertheless, as described
below, LEWIS never went through with that offer.

m. Individual-1 continued working for LEWIS
through approximately late 2020 or early 2021. Individual-1 was
never paid any of the promised salary, and eventually stopped
working for LEWIS and ceased contact with him in early 2021.
Similarly, Victim-1 was never paid any meaningful amount of
money and no longer had contact with LEWIS after approximately
spring 2021.

n. By 2020, Victim-1 had transferred more than
$3 million of loan and/or investment funds to LEWIS in less than
three years. Those payments were made on approximately more
than 25 occasions, including via wire and bank transfers

Case 1:23-cr-00032-LTS Document 1 Filed 08/16/22 Page 8 of 14

occurring in the Southern District of New York. That total was
essentially all of Victim-l's liquid assets, including money
from his retirement savings and proceeds from the sale of his
house. Even as Victim-1 lost all liquidity, including taking
cash advances on his credit cards and considering bankruptcy, he
continued paying for certain LEWIS-related expenses through at
least in or about June 2021, including certain business
expenses. Following that period, Victim-1 was evicted from his
apartment and ultimately filed for personal bankruptcy. 1

Fraud Against Corporation-1

10. Based on my participation in this investigation,
including my review of records, such as electronic
communications obtained voluntarily as well as pursuant to
judicially-authorized search warrants; financial, payment, and
banking records; my review of consensually-recorded phone calls;
and my interviews of individuals, including Victim-1 and
representatives of Corporation-1, and my discussions with other
law enforcement officers, I have learned the following:

11. In or about August and September 2020, RUSSELL
DWAYNE LEWIS, a/k/a "Clifford Ari Getz," a/k/a "Clifford Ari Getz
Cohen," a/k/a "Ari Getz," a/k/a "Aryeh Getz," the defendant,
fraudulently tried to acquire Corporation-1 and its assets. As
described above, that offer resulted in weeks of due diligence
processes, legal discussions, and negotiations, including through
which Getz, Victim-1, and Individual-1 had access to certain of
Corporation-l's internal business records and materials.
Corporation-1 and its representatives dedicated significant time
and resources to the purported offer. Those efforts were based on
the false premise that LEWIS intended to, and could, pay hundreds
of millions of dollars for Corporation-1.

1 Victim-1 was first interviewed by Special Agents of the Federal
Bureau of Investigation in approximately April 2021. In that
initial interview, as Victim-1 has subsequently acknowledged, he
was not candid. In particular, he claimed not to have attempted
to purchase any companies with LEWIS, not to have worked with
him for approximately a year and a half prior to the interview,
and not to know if LEWIS had substantial wealth. In subsequent
interviews, Victim-1 acknowledged this lack of candor and
expressed remorse; Victim-1 has said that during the first
interview, he still felt a strong bond with LEWIS and wanted to
protect him. Victim-1 has since provided information to law
enforcement that has been independently corroborated, and he has
entered into a non-prosecution agreement with the United States
Attorney's Office for the Southern District of New York.

Case 1:23-cr-00032-LTS Document 1 Filed 08/16/22 Page 9 of 14

Initial Contact With Corporation-1

a. In or about early August 2020, Corporation-1
initiated bankruptcy proceedings and solicited bids for its
business, including with the assistance of counsel. On
approximately August 4, 2020, Victim-1 emailed counsel to
Corporation-1, stating that he was the President of "Neviim
Equity," a "family office trust looking to invest in distressed
organizations." The email expressed possible interest in
purchasing the assets of Corporation-1, and it copied "C. Ari
Getz" as well as Individual-1, who was identified as the Chief
Financial Officer of Neviim. Days after that introduction,
LEWIS made a purported all-cash offer to purchase Corporation-1
and a related entity for $290 million.

b. Shortly thereafter, Victim-1 and
Individual-1 began engaging in due diligence proceedings with
counsel and strategic advisors to Corporation-1. Following
extensive communications regarding the offer and related due
diligence, on or about August 12, 2020, representatives of
Corporation-1 had a videoconference call with Victim-1,
Individual-1, and "Clifford Getz." During the videoconference,
LEWIS, purporting to be Getz, said in sum and substance that he
was worth approximately more than $18 billion, which he said he
had made primarily through the sale of real estate assets.

c. On or about August 13, 2020, as part of the
due diligence process, a representative of Corporation-1
requested, among other materials and documentation, a bank
statement from a U.S. bank showing sufficient funds to complete
the acquisition. Due diligence and negotiations also continued
during the following days.

The Fraudulent Bank Letter and Additional False Statements

d. On or about August 21, 2020, LEWIS sent to
Individual-1, and copying himself, a letter appearing to be from
a multinational bank headquartered abroad (the "Fraudulent Bank
Letter"). In sum and substance, the Fraudulent Bank Letter
purported to confirm the existence of an account at the bank for
the benefit of "Rabbi Clifford Getz" holding cash in the amount
of €300 million. In particular, the Fraudulent Bank Letter
stated that the bank was "ready, willing and able to issue cash-
backed Standby Letter of Credit in the amount [of €300 million]
for the benefit or Rabbi Clifford Getz, Trustee to the
designated beneficiary account immediately upon your
instruction." The Fraudulent Bank Letter was dated "20th August
2020" and appeared to be signed by two bank employees.
Approximately 30 minutes after LEWIS emailed the Fraudulent Bank

Case 1:23-cr-00032-LTS Document 1 Filed 08/16/22 Page 10 of 14

Letter, Individual-1 sent it to representatives of
Corporation-1. Upon receipt of the Fraudulent Bank Letter,
those representatives attempted to confirm its legitimacy by
contacting one of the bank's representatives, who stated in sum
and substance that the letter was fraudulent. Indeed, the
relevant account identified was not associated with LEWIS, or
with any of his aliases, and its actual holdings were
dramatically less than the amount stated in the Fraudulent Bank
Letter. The representatives of Corporation-1 then contacted law
enforcement and began cooperating with the investigation.

e. In the following weeks, LEWIS continued to
proceed as if the purchase offer was legitimate but repeatedly
refused to provide any additional proof of funds information.
In one call between LEWIS, Victim-1, Individual-1, and
representatives of Corporation-1, which was recorded, LEWIS made
representations that, among other things, Neviim "buy[s]
hundreds of millions of dollars from pharmaceuticals" and that
he engaged in "very humanitarian projects around the globe."
LEWIS also stated that his funds were being routed through, and
had been delayed by, "banks all around the globe."

f. During the recorded call, LEWIS further
claimed to be 68 years old, to have grown up in London, and to
have a PhD in theoretical mathematics and statistics, a master's
degree in neurophysics, a master's degree in genetics, and a
master's degree in quantum physics. None of those claims were
true. Additionally, a representative of Corporation-1 on the
call stated to LEWIS that he understood LEWIS was worth $18
billion, and LEWIS did not deny or correct the statement, but
rather referenced his desire for privacy. Shortly thereafter,
LEWIS and his associates stopped communicating with
representatives of Corporation-1, a~d the deal was never
completed.

Fraud Against Victim-2

12. Based on my participation in this investigation,
including my review of records, such as electronic
communications obtained voluntarily as well as pursuant to
judicially-authorized search warrants; financial, payment, and
banking records; and my interviews of individuals, including
Victim-2, and my discussions with other law enforcement
officers, I have learned the following:

13. In addition to his purported business activities,
RUSSELL DWAYNE LEWIS, a/k/a "Clifford Ari Getz," a/k/a "Clifford
Ari Getz Cohen," a/k/a "Ari Getz," a/k/a "Aryeh Getz," the
defendant, also charged some individuals for astrological

Case 1:23-cr-00032-LTS Document 1 Filed 08/16/22 Page 11 of 14

readings and analyses that he performed for them. One such
individual was a widow with four children who met LEWIS in or
about 2018 ("Victim-2"). Victim-2 continued to have contact
with LEWIS in the coming years, including for astrological
readings. In or about 2020, over the course of serval months,
LEWIS defrauded Victim-2 out of approximately $555,000 by
pressuring her into paying him money for a purported investment
opportunity. In truth, there was no such investment
opportunity, and LEWIS spent Victim-2's money on personal
expenses, including office supplies that facilitated and
promoted LEWIS'S other schemes.

a. In early 2020, Victim-2 met LEWIS, who
purported to be able to provide astrology readings. Victim-2
paid LEWIS for that service, and over the course of several
months he provided her with readings and advice. LEWIS told
Victim-2 that he was a billionaire, and that it was in her chart
to get her mortgage paid off and to obtain financial freedom.
LEWIS also claimed, among other things, that he had previously
been in the U.S. military and had worked for the Secret Service
for most of his career, that he worked for and had friends in
the Los Angeles Police Department and Beverly Hills Police
Department, that he performed astrological readings for police
officers and for a particular tech company billionaire, and that
he assisted in picking the jury for the OJ Simpson trial based
on his astrological readings and charts.

b. Some time thereafter, in approximately late
March 2020, LEWIS offered Victim-2 a "guaranteed" investment
opportunity in connection with a purported real estate
development. Specifically, he said the deal involved a real
estate project that was in progress but unfinished, and he said
the investment opportunity would help Victim-2 escape her
financial troubles. LEWIS told her that in exchange for an
investment of $300,000, she would get back $575,000, and he
provided her with a post-dated check for that amount as the
"guarantee."

c. Victim-2 initially declined, explaining that
she could not afford the investment. LEWIS told her she would
be paid back within two weeks, and that he already had committed
to the investment so she could not back out. LEWIS ultimately
convinced Victim-2 to agree, and she wired him $300,000, to an
account with a bank headquartered in New York City (the "Lewis
Account") on or about March 30, 2020. LEWIS gave her a check
for $575,000, post-dated for April 15, 2020 (the "First Post-
Dated Check"), written from the Lewis Account, and he told her
she could deposit it then.

Case 1:23-cr-00032-LTS Document 1 Filed 08/16/22 Page 12 of 14

d. When Victim-2 expressed concern about the
First Post-Dated Check, LEWIS laughed and said, in substance,
that he was a billionaire and would not risk going to jail over
writing a bad check. When LEWIS wrote the First Post-Dated
Check in late March, prior to receiving the $300,000 from
Victim-2, the Lewis Account held less than $10,000. On or about
April 15, 2020, the date for which the First Post-Dated Check
was written, and following extensive transfers and expenditures
by LEWIS after receiving $300,000 from Victim-2, the Lewis
Account held less than $7,000.

e. On or about April 15, 2020, LEWIS told
Victim-2 that the real estate investment was short by an
additional $255,000. He said that if Victim-2 gave him that
amount, he could get her back an additional $1,000,000. When
Victim-2 hesitated, LEWIS told her, in sum and substance, that
he had organized the investment for her, and had put his neck
out for her, and that she was being ungrateful. Victim-2
acquiesced, and she wired LEWIS the additional $255,000 on April
16, 2020. At approximately the same time, LEWIS gave Victim-2 a
check for $1,000,000, post-dated for April 28 (the "Second Post-
Dated Check"). At the time Victim-2 sent the $255,000, the
Lewis Account held less than $7,000; on April 28, it held less
than $1,000.

f. On or about April 27, 2020, LEWIS told
Victim-2 not to deposit the checks he had given her, and that
instead he would wire her the money directly. He subsequently
claimed he had the money in an account, and that he had
transferred it to Victim-2; he also claimed that a new check
would be sent to her instead. As days and weeks went by,
Victim-2 became increasingly desperate to be repaid. Over the
course of the following weeks and then months, LEWIS told
Victim-2 not to cash the post-dated checks, for a variety of
reasons, assuring her that she would eventually get the money
she was owed. LEWIS falsely claimed, among other things, that
he was suing banks for failing to release his vast funds.

g. On or about July 29, 2020, LEWIS told
Victim-2 that LEWIS's son had gone to a branch of a New York
bank to have a check drawn. LEWIS said his son would sign the
check and that the bank would mail it to Victim-2. On or about
August 1, Victim-2 received texts from a New York phone number,
with the prefix 917, purporting to be LEWIS's daughter and
claiming that a check was being sent via FedEx; no such check
ever arrived.

h. In or about September 2020, LEWIS told
Victim-2 she could deposit the First Post-Dated Check, for

Case 1:23-cr-00032-LTS Document 1 Filed 08/16/22 Page 13 of 14

$575,000; when she attempted to, it bounced due to insufficient
funds. On or about September 18, when LEWIS told Victim-2 she
could deposit the check, the account from which the check was
written contained less than $1,000.

i. LEWIS subsequently told Victim-2, in sum and
substance, that if she went to the police over the check
bouncing, he would get a slap on the wrist and then would
declare bankruptcy so she would never recover her money.
Victim-2 continued to attempt to communicate with LEWIS to get
back her stolen funds through the end of 2020, after which she
reported the fraud to law enforcement.

False Identifying Information and Identity Theft

14. Based on my participation in this investigation,
including my review of records, such as electronic
communications obtained voluntarily as well as pursuant to
judicially-authorized search warrants; financial, payment, and
banking records; and my interviews of individuals including
those described above, and my discussions with other law
enforcement officers and public officials, I have learned that
the person who perpetrated these offenses under a variety of
aliases is in fact RUSSELL DWAYNE LEWIS, a/k/a "Clifford Ari
Getz," a/k/a "Clifford Ari Getz Cohen," a/k/a "Ari Getz," a/k/a
"Aryeh Getz," the defendant.

a. In communications including certain of those
described above, LEWIS has identified himself as, or been
referred to by others as, among other names, "Ford Getz," "Ari
Getz," "Clifford Ari Getz," and "Aryeh Getz." He appears to
have been using a combination of similar aliases since at least
in or about 2016.

b. In a 2018 credit card application with a
bank headquartered in New York City, LEWIS listed his name as
"Clifford Getz" and his date of birth as a particular date in
1982 (the "Fraudulent DOB"). Based on my review of documents, I
have learned that there is an individual residing in the United
States who has that same first and last name, with a different
middle name, and who was in fact born on the Fraudulent DOB date
("Victim-3"). In the same credit card application, LEWIS listed
his social security number as a particular number (the
"Fraudulent SSN"). The Fraudulent SSN was not issued to anyone
with the last name Lewis or Getz; rather, it is the social
security number of an approximately 13-year-old child residing
in Ohio.

Case 1:23-cr-00032-LTS Document 1 Filed 08/16/22 Page 14 of 14
..

c. LEWIS also used the Fraudulent SSN and the
Fraudulent DOB in applications for at least two additional
credit cards. Similarly, in client information documents
submitted by LEWIS to a bank in or about February 2020 (the
"Fraudulent Client Documents Submission"), his name is listed as
"Clifford Getz" and the document lists his social security
number as the Fraudulent SSN and his date of birth as the
Fraudulent DOB.

d. The Fraudulent Client Documents Submission
also included a photocopy of a passport (the "Fraudulent
Passport") in the full name of Victim-3, including Victim-3's
middle name, and listing the Fraudulent DOB. The Fraudulent
Passport contains a photograph that I believe, based on a review
of photos of Victim-3, is not a photograph of that individual
and instead is a photo of LEWIS. The Fraudulent Passport was
issued by the U.S. Government based on an application that
included, among other information, the full name of Victim-3 and
the Fraudulent DOB.

WHEREFORE the deponent prays that RUSSELL DWAYNE
LEWIS, a/k/a "Clifford Ari Getz," a/k/a "Clifford Ari Getz
Cohen," a/k/a "Ari Getz," a/k/a "Aryeh Getz," the defendant, be
arrested and imprisoned or bailed, as the case may be.

STRAWMAN
ecial Agent
Federal Burau of Investigation

Sworn to before me this
16th day of August 2022.

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TH2 HONORABLE BA~BARA MOSES __,
UNITED STATES MAGISTRATE JUDGE
SOUTHERN DISTRICT OF NEW YORK

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Sealed Complaint — United States v. Lewis (Dkt. 1, S.D.N.Y.)

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