Affidavit in support of criminal complaint — No. 1:21-mj-04190 (Dkt. 3-3, D. Mass.)

Summary

An affidavit by a Special Agent of the Federal Bureau of Investigation in No. 1:21-mj-04190 (D. Mass.), filed April 1, 2021 as Document 3-3, supporting applications for a criminal complaint and arrest warrant against Raquel Pena and for search warrants for her person and residence. It alleges wire fraud, conspiracy to commit wire fraud and aggravated identity theft under Title 18, United States Code, Sections 1343, 1349, and 1028A, through fraudulent Pandemic Unemployment Assistance claims filed with the Massachusetts Department of Unemployment Assistance using other people's PII. The affidavit states that the FBI identified more than $300,000 in unemployment claims in May 2020 connected to Pena. It also asks to use Pena's fingers or face to unlock seized devices.

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