United States Of America v. Abiola Femi Quadri — Doc. 1

Summary

A criminal complaint, Document 1 in United States v. Abiola Femi Quadri, Case No. 2:24-mj-05734-DUTY, in the United States District Court for the Central District of California, filed September 19, 2024. The complaint lists 18 U.S.C. §§ 1349 and 1028A, with Count One for conspiracy to commit wire and bank fraud, and is signed by Postal Inspector Francisco Solorio Perez. The attached affidavit states that Quadri is associated with at least 72 Unemployment Insurance claims and 19 Disability Insurance claims described as fraudulent, that surveillance video shows ATM withdrawals from at least 38 accounts, and that a bank account wired approximately $503,545 abroad. It also states that Quadri booked a flight departing September 21, 2024, to Dubai.

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Date: 2020-03-12

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“United States Of America v. Abiola Femi Quadri — Doc. 1.” Dated 2020-03-12. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2020-03-12-united-states-of-america-v-abiola-femi-quadri-04d71ca8-1/, SHA-256 04d71ca8fa585d5fab6d1a24942ffd2c4e079afca687c28301b38ecf019276d8.

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Case 2:24-mj-05734-DUTY Document 1 Filed 09/19/24 Page 1 of 15 Page ID #:1
AO 91 (Rev. 11/11) Criminal Complaint (Rev. by USAO on 3/12/20) ‫ ܆‬Original ‫ ܆‬Duplicate Original

UNITED STATES DISTRICT COURT
for the 9/19/2024
Central District of California CGM

United States of America

v.
Case No.
ABIOLA FEMI QUADRI,
2:24-mj-05734-DUTY

Defendant

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: 9/19/24
Judge’s signature

City and state: Los Angeles, California Joel Richlin, U.S. Magistrate Judge
Printed name and title

AUSA Andrew Brown, 11th Floor, x0102
Case 2:24-mj-05734-DUTY Document 1 Filed 09/19/24 Page 2 of 15 Page ID #:2

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.
Case 2:24-mj-05734-DUTY Document 1 Filed 09/19/24 Page 3 of 15 Page ID #:3

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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Case 2:24-mj-05734-DUTY Document 1 Filed 09/19/24 Page 10 of 15 Page ID #:10

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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Case 2:24-mj-05734-DUTY Document 1 Filed 09/19/24 Page 11 of 15 Page ID #:11

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 19th day of
September, 2024.

UNITED STATES MAGISTRATE JUDGE
A. Joel Richlin

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