Application for a Search Warrant — In the Matter of the Search of Information Associated with the Email Address akash@albot.io, No. 2:25-sw-00136-JDP (Dkt. 1, E.D. Cal.)
Summary
An application for a search warrant, Case No. 2:25-sw-00136-JDP (E.D. Cal.), filed 02/18/25, for information associated with an email account stored at premises controlled by Microsoft Corporation. The affidavit of IRS-CI Special Agent Marshall Miller alleges that Akash Kumar Singh, as Chief Executive Officer of Kryptoblocks Inc., obtained more than $3 million in subsequently forgiven PPP loans from KeyPoint Credit Union: a First Draw loan of $1,426,847.00 in or around May 2020 and a Second Draw loan of $1,990,152.00 in or around March 2021. The first application claimed eighty-four employees and an average monthly payroll of over $570,000, while IRS records show Kryptoblocks reported no income, payroll, or employees between 2016 and 2024. Listed uses of the money include home mortgage payments and over $1 million in direct transfers to individuals located in India.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Full text
Case 2:25-sw-00136-JDP
AO 106 (Rev. 04/10) Application for a Search Warrant
Document 1 Filed 02/18/25 Page 1 of 34
UNITED STATES DISTRICT COURT FILED
Feb 28,
Jan 18, 2022
2025
for the CLERK, U.S. DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
SEALED
Eastern District of California
In the Matter of the Search of
)
)
INFORMATION ASSOCIATED WITH THE
EMAIL ADDRESS AKASH@ALBOT.IO THAT
) Case No. 2:25-sw-0136 JDP
)
IS STORED AT PREMISES CONTROLLED BY
)
MICROSOFT CORPORATION USA
)
APPLICATION FOR A SEARCH WARRANT
I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property:
SEE ATTACHMENT A, attached hereto and incorporated by reference,
located in the Western District of Washington , there is now concealed:
SEE ATTACHMENT B, attached hereto and incorporated by reference.
The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more) :
evidence of a crime;
contraband, fruits of crime, or other items illegally possessed;
property designed for use, intended for use, or used in committing a crime;
a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section Offense Description
18 U.S.C. § 1343 Wire fraud
18 U.S.C. § 1344 Bank fraud
18 U.S.C. § 1957 Conducting financial transactions with proceeds of unlawful activity
The application is based on these facts:
SEE AFFIDAVIT, attached hereto and incorporated by reference.
Continued on the attached sheet.
❐
Delayed notice days (give exact ending date if more than 30 days: ) is requested
of
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.
/s/ Marshall Miller
Applicant’s signature
Marshall Miller, IRS-CI Special Agent
Printed name and title
Sworn to and signed telephonically.
Date: February 18, 2025
Judge’s signature
City and state: Sacramento, California Jeremy D. Peterson, U.S. Magistrate Judge
Printed name and title
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 2 of 34
AFFIDAVIT IN SUPPORT OF APPLICATION FOR SEARCH WARRANT
I, Marshall Miller, being first duly sworn, hereby depose and state as follows:
I. INTRODUCTION AND AGENT BACKGROUND
1. I make this affidavit in support of an application for a search warrant for
information associated with a certain account that is stored at premises controlled by Microsoft
Corporation USA (“Microsoft”), an internet service and email service provider headquartered at
1 Microsoft Way, Redmond, Washington 98052. The information to be searched is described in
the following paragraphs and in Attachment A, hereby incorporated by reference. This affidavit
is made in support of an application for a search warrant under 18 U.S.C. §§ 2703(a),
2703(b)(1)(A), and 2703(c)(1)(A) to require Microsoft to disclose to the government copies of
the information (including the content of communications) further described in Section I of
Attachment B. Upon receipt of the information described in Section I of Attachment B (hereby
incorporated by reference), government-authorized persons will review that information to locate
the items described in Section II of Attachment B.
2. I am a Special Agent with Internal Revenue Service-Criminal Investigation, and
have been since 2018. My duties include the investigation of criminal violations of the Internal
Revenue Code, anti-money laundering statutes, and other related offenses. My professional
training consisted of approximately twenty-six weeks of training at the Federal Law Enforcement
Training Center in Glynco, Georgia, which included training in law enforcement techniques,
federal criminal statutes, conducting criminal investigations, and the execution of search, seizure,
and arrest warrants. I have also received training in financial investigative techniques, legal
principles, and statutes representing criminal violations of the United States Code as enumerated
in Titles 18, 26, and 31. Furthermore, I have a master’s degree in accounting from the University
of California at Davis and a bachelor’s degree in criminology from the University of California
at Irvine.
3. I have led or been involved in numerous investigations of money laundering,
health-care fraud, wire fraud, bank fraud, conspiracy, tax evasion, and other related offenses. I
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 3 of 34
have led or participated in numerous interviews, and have been the affiant for multiple federal
search warrants involving suspected criminal violations where records of the type involved in
this investigation were seized. I have personally authored affidavits in support of warrants for the
seizure of property that constituted the proceeds of money laundering or fraud under the
forfeiture statutes found within Title 18 of the United States Code. I have personally traced the
proceeds of fraud between financial accounts, utilizing various accounting methods to determine
the balance of fraud proceeds held within certain accounts on a given date.
4. Based on my training and experience and that of others with whom I work, I am
familiar with the methods and practices used by individuals and organizations engaged in
financial crimes. These individuals often maintain records of their financial activities, such as
bank records, receipts, and documentation of expenditures, notes, or correspondence, negotiated
instruments, contracts, and other financial documents, within their email accounts. I am aware
that individuals engaged in financial crimes commonly participate in these activities for profit. It
is common for the proceeds of financial crimes to be in the form of cash, negotiable instruments,
or other assets. Furthermore, it is common for persons engaging in financial crimes to invest the
profits in other assets, reduce current or long-term liabilities, convert the profits to other forms of
financial instruments, and/or pay personal expenditures. I am aware that such transactions,
transfers, or expenditures of criminally derived profits cause the creation of numerous types of
documents, which reflect the fruits of financial crimes. Documents such as bank records,
cashier’s check records, receipts, invoices, expenditure records, escrow documents, notes or
notations, and other similar documents are generated upon the transactions, transfers, and/or
expenditures of criminally derived funds. I know from training and experience , and the
experience of other law enforcement officers with whom I work, that correspondence or records
related to these financial activities are commonly kept in the email accounts of individuals
engaging in criminal activity.
5. This affidavit is intended to show merely that there is sufficient probable cause
for the requested warrant and does not set forth all of my knowledge about this matter.
AFFIDAVIT 2
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 4 of 34
6. Based on my training and experience and the facts as set forth in this affidavit, I
submit that there is probable cause to believe that violations of 18 U.S.C. §§ 1343, 1344, and
1957 have been committed by Akash Kumar Singh (“Singh”) using the email address
akash@albot.io (the “Target Account”). I further submit that there is probable cause to search the
information described in Attachment A for evidence of these crimes further described in
Attachment B.
7. The Court has jurisdiction to issue the requested warrant because it is “a court of
competent jurisdiction” as defined by 18 U.S.C. § 2711. 18 U.S.C. §§ 2703(a), (b)(1)(A),
(c)(1)(A). Specifically, the Court is a district court of the United States that has jurisdiction over
the offense being investigated. Id. § 2711(3)(A)(i).
II. FACTS ESTABLISHING PROBABLE CAUSE
A. Summary of Investigation and Scope of Requested Warrant
8. Singh purports to be the head of two corporations operating in California :
Kryptoblocks Inc. (“Kryptoblocks”) and Albot Technologies (“Albot”). In summary, evidence
obtained to date by the government indicates that Singh used his status as Chief Executive
Officer of Kryptoblocks to apply for and obtain from a federally insured financial institution
called KeyPoint Credit Union (“KeyPoint”) more than $3 million in subsequently forgiven loans
that were earmarked for COVID-19 relief to small businesses meeting certain requirements. 1
9. In support of his applications, Singh submitted a range of apparently fraudulent
documentation, including Internal Revenue Service (“IRS”) forms that were never actually filed
with that agency, payroll spreadsheets containing names and wages of employees who
apparently resided outside the United States, and more. Singh’s fraudulent loan applications
indicated that the Target Account was the contact email address for Singh in his capacity as CEO
of Kryptoblocks. Additionally, Singh used the Target Account to correspond with KeyPoint
personnel about and in furtherance of his fraudulent loan applications.
1 Per information made available online by the National Credit Union Administration,
KeyPoint is federally insured by that entity.
AFFIDAVIT 3
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 5 of 34
10. After Singh obtained millions of dollars in pandemic loans to Kryptoblocks from
KeyPoint, he transferred much of the proceeds through personal bank accounts and corporate
bank accounts linked to Kryptoblocks and Albot that he controlled. Singh spent a substantial
portion of the loan proceeds he received on expenditures that were not authorized by the
applicable loan program’s rules, such as personal expenses, residential mortgage payments,
luxury goods, travel-related expenses, and transfers to individuals located overseas.
11. The warrant for which I am applying would authorize law enforcement to search
the contents of the Target Account in order to seize evidence relating to Singh’s fraud and
connecting Singh to the use of that account to perpetrate his fraud.
B. Background on Paycheck Protection Program
12. At all relevant times, the United States Small Business Administration (the
“SBA”) operated the Paycheck Protection Program (the “PPP”), a congressionally mandated
program through which third-party lenders like KeyPoint funded forgivable loans to businesses
in the United States affected by the COVID-19 pandemic. These loans were guaranteed by the
United States Treasury and overseen by the SBA.
13. PPP rules required prospective borrowers to certify, among other things:
a) That an applicant business was in operation on February 15, 2020;
b) That it employed workers for whom it paid salaries and payroll taxes or paid
independent contractors as reported on IRS Form 1099-MISC;
c) That the principal places of residence for employees of the applicant business
were in the United States;
d) The accuracy of the average monthly payroll expenses and number of employees
of the applicant business; and
e) The accuracy of information and documents submitted in support of the loan
application.
14. PPP rules provided that loan proceeds could only be used for business payroll
costs, business rent or mortgage costs, business utilities, or other business expenses.
AFFIDAVIT 4
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 6 of 34
15. In general, successful applicants for PPP loans received their loan proceeds
directly from the financial institutions that processed their loan applications, and on terms that
required the loans to be repaid over time at a low interest rate (around 1%). Lo an recipients who
demonstrated that they spent loan proceeds on allowable business expenses could seek to have
their PPP loans entirely forgiven.
16. PPP rules required borrowers seeking forgiveness of their loans to certify, among
other things:
a) That PPP loan proceeds had been used to pay business costs eligible for
forgiveness, such as payroll costs to retain employees, business utility payments,
covered worker protection expenditures, and the like;
b) That at least 60% of the amount for which the borrower sought forgiveness
consisted of payroll costs;
c) That the borrower verified the accuracy of the eligible payroll and nonpayroll
costs for which forgiveness was sought; and
d) The accuracy of information and documents submitted in support of the
forgiveness application.
17. Applicants seeking PPP loans and their subsequent forgiveness generally
submitted their applications directly to third-party financial institutions, such as KeyPoint, using
the internet.
C. Singh successfully applied for a PPP loan of $1.4 million.
18. In or around April 2020, KeyPoint received an application for a PPP loan to
Kryptoblocks (the “First Draw” loan) that purported to be submitted by Singh. In support of this
application, Singh represented the following, among other things:
a) He was the Chief Executive Officer and sole owner of Kryptoblocks;
b) The Target Account was the email address associated with Kryptoblocks’s
application;
///
AFFIDAVIT 5
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 7 of 34
c) The business phone number associated with the application was 650 -391-8550
(the “8550 number”);2
d) The taxpayer identification number associated with the application was Singh’s
personal Social Security Number;
e) The principal place of business for Kryptoblocks was Singh’s residence in
Sacramento;
f) Kryptoblocks employed eighty-four people, with an average monthly corporate
payroll of over $570,000;
g) The United States was the principal place of residence for all employees used to
calculate Kryptoblocks’s payroll; and
h) Any loan proceeds would be used for Kryptoblocks’s payroll, rent or mortgage
interest, or utilities.
19. In support of his application, Singh submitted what purported to be a true and
accurate IRS Form W-3 showing that Kryptoblocks paid employee wages of more than $9
million in 2019 and withheld more than $1.3 million in federal income tax in 2019. However,
according to records maintained by the IRS, Kryptoblocks did not report any income, payroll, or
employees to the IRS between 2016 and 2024.
20. In or around May 2020, KeyPoint approved Singh’s First Draw loan application
and funded a loan of $1,426,847.00 to Kryptoblocks. KeyPoint deposited the First Draw loan
proceeds via interstate wire into a Kryptoblocks corporate bank account held at Bank of
America, the account number for which ended in 8845 (the “8845 account”). 3 According to
records provided by Bank of America, Singh opened the 8845 account in Sacramento in
November 2019 and was the sole signatory on the account. At the time the First Draw loan
2 According to records obtained by investigative personnel from Sprint, Singh was the
owner of the 8550 number through at least April 2020.
3 The investigation indicates this wire was made using Fedwire, a system operated by the
Federal Reserve. I am aware, based upon my training, experience, and consultation with others,
that Fedwire transactions since 2015 involve two separate computer servers, one in Texas, and
the other in New Jersey.
AFFIDAVIT 6
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 8 of 34
proceeds were deposited into the 8845 account, the 8845 account had a balance of less than
$5,000.
21. Between May 2020 and August 2021, according to records provided to
investigators for the 8845 account and for other financial accounts associated with Singh, Singh
spent the majority of the First Draw loan proceeds on a variety of expenditures that were no t
authorized for PPP funds. These expenditures included regular payments on Singh’s home
mortgage; over $1 million in direct transfers to individuals located in India; incidentals such as
food, clothing, transportation, and luxury goods; and other personal expenses.
22. Based on the foregoing, I submit that probable cause exists to believe that Singh
violated 18 U.S.C. §§ 1343 and 1344 by submitting a PPP loan application to a federally insured
credit union that contained material misrepresentations and that involved an interstate wire
transmission.
1. Forgiveness of First Draw Loan
23. In or around October 2021, KeyPoint received an application for forgiveness of
the First Draw loan issued to Kryptoblocks, which again purported to be submitted by Singh. In
support of his forgiveness application, Singh represented the following, among other things:
a) The Target Account was the email address associated with Kryptoblocks’s
application;
b) The 8550 number was the business phone number associated with Kryptoblocks’s
application;
c) The taxpayer identification number associated with the application was
Kryptoblocks’s federal Employer Identification Number;
d) The business address for Kryptoblocks was Singh’s residence in Sacramento;
e) At the time of its application for forgiveness of the First Draw loan, Kryptoblocks
employed ninety people; and
f) Between May and October 2020, Kryptoblocks paid out $1,426,847.00 for payroll
costs to employees whose principal places of residence were in the United States.
AFFIDAVIT 7
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 9 of 34
24. To substantiate the certifications made on the application for forgiveness of the
First Draw loan, Singh used the Target Account to send KeyPoint personnel what purported to be
true and accurate documents, including the following:
a) An IRS Form 940 for 2020 bearing Singh’s name and the 8550 number and
purporting to show that Kryptoblocks paid $9.2 million in wages, requiring it to
remit $3,738 to the IRS in federal unemployment tax that year;
b) An IRS Form 941 for the second quarter of 2020, bearing Singh’s name and the
8550 number and purporting to show that Kryptoblocks paid more than $2 million
in employee wages that quarter and withheld more than $650,000 in federal
income tax that same quarter;
c) An IRS Form 941 for the third quarter of 2020, bearing Singh’s name and the
8550 number and purporting to show that Kryptoblocks paid more than $2 million
in employee wages that quarter and withheld more than $650,000 in federal
income tax that same quarter; and
d) A spreadsheet purporting to show that Kryptoblocks employed eighty -eight
people to whom it paid more than $9 million in wages (along with associated
federal and California taxes) in 2019 and $3 million in wages (along with
associated federal and California taxes) in 2020, including approximately
$110,000 paid to Singh himself, $106,000 paid to Singh’s wife Neelam Singh,
and $95,000 paid to Singh’s brother Neeraj Masih. 4
25. However, according to records maintained by the IRS, Kryptoblocks did not
report any income, payroll, or employees to the IRS between 2016 and 2024 . Additionally,
according to records obtained by investigators from the California Employment Development
Department (the “EDD”), Kryptoblocks did not report any wages paid to employees in California
in 2020. And according to information provided to investigators by the California Franchise Tax
4 Singh reported that Neelam Singh was his spouse and that Neeraj Masih was his brother
on tax returns filed with the IRS that were reviewed as part of this investigation.
AFFIDAVIT 8
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 10 of 34
Board (the “FTB”), Kryptoblocks did not file a corporate tax return in California for 2019 or
2020. Furthermore, according to bank records for the 8845 account, Singh did not make any
payments to tax authorities from this account in 2019 or 2020.
26. In or around October 2021 and based on Singh’s representations in support of his
First Draw loan forgiveness application, KeyPoint requested that the SBA forgive the First Draw
loan previously extended to Kryptoblocks. That same month, the SBA forgave the First Draw
loan in full.
27. Based upon the foregoing, I submit that probable cause exists to believe that
Singh violated 18 U.S.C. § 1344 by submitting the false First Draw loan forgiveness application
to KeyPoint.
D. Singh successfully applied for a second PPP loan of $1.9 million.
28. In or around January 2021, Singh submitted an application to KeyPoint for a
subsequent PPP loan to Kryptoblocks (the “Second Draw” loan). In support of his application,
Singh represented the following, among other things:
a) He was the Chief Executive Officer and sole owner of Kryptoblocks;
b) The Target Account was the email address associated with Kryptoblocks’s
application;
c) The business phone number associated with the application was the 8550 number;
d) The taxpayer identification number associated with the application was
Kryptoblocks’s federal Employer Identification Number;
e) The principal place of business for Kryptoblocks was an address in an office
building on Promenade Circle in Sacramento, which is located less than two miles
from Singh’s residence and which currently houses a lending company doing
business as Regional Finance;
f) Kryptoblocks employed eighty-nine people;
g) Kryptoblocks maintained an average monthly payroll of approximately
$838,911.00;
AFFIDAVIT 9
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 11 of 34
h) Kryptoblocks sought a Second Draw loan to pay for eligible payroll costs,
rent/mortgage interest, utilities, and covered operations expenditures;
i) The United States was the principal place of residence for all employees included
in Kryptoblocks’s payroll calculation; and
j) Kryptoblocks used its First Draw loan proceeds only on eligible expenses.
29. In support of the Second Draw loan application, Singh used the Target Account to
submit a bank statement for the 8845 account displaying Singh’s residential address as the
contact address for Kryptoblocks and demonstrating the withdrawal of approximately $86,000
from that account in January 2021.
30. KeyPoint’s loan file for the Second Draw loan also includes the following
documents:
a) An IRS Form 940 for 2019 displaying Singh’s residence address and the 8550
number, and purporting to show that Kryptoblocks paid $9.2 million in wages;
b) An IRS Form W-3 for 2019 displaying the Target Account and the 8550 number,
and purporting to show that Kryptoblocks paid more than $9 million in wages and
withheld more than $1.3 million in federal income tax that year;
c) A purportedly true and accurate profit-and-loss statement showing that
Kryptoblocks generated more than $17 million in net revenue in 2019 and more
than $12 million in net revenue in 2020; and
d) A purportedly true and accurate spreadsheet showing that Kryptoblocks employed
eighty-eight people to whom it paid more than $9 million in wages (along with
associated federal and California taxes) in 2020, including to Singh himself,
Singh’s wife, and Singh’s brother.
31. However, according to records maintained by the IRS, Kryptoblocks did not
report any income, payroll, or employees to the IRS between 2016 and 2024 . Additionally,
according to records obtained by investigators from the EDD, Kryptoblocks did not report
making any wage payments to California employees in 2020. And according to records obtained
AFFIDAVIT 10
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 12 of 34
by investigators from the FTB, Kryptoblocks did not file a California corporate tax return for
2019 or 2020.
32. In or around March 2021, KeyPoint approved Singh’s Second Draw loan
application and funded a loan of $1,990,152.00 to Kryptoblocks. KeyPoint deposited these
Second Draw loan proceeds via interstate wire into a Kryptoblocks corporate bank account held
at Bank of America, the account number for which ended in 5717 (the “5717 account”). 5
According to records received from Bank of America, Singh opened the 5717 account in
Sacramento in May 2020 and was the sole signatory on the account. At the time the Second
Draw loan proceeds were deposited into the 5717 account, that account had a balance of less
than $2,500.
33. Based upon the foregoing, I submit that probable cause exists to believe that
Singh violated 18 U.S.C. §§ 1343 and 1344 by submitting a PPP loan application to a federally
insured credit union that contained material misrepresentations, and that involved an interstate
wire transmission.
1. Expenditures of Second Draw Loan Proceeds
34. Between March 2021 and February 2022, nearly all of the proceeds Kryptoblocks
received from the Second Draw loan were spent from the 5717 account. According to records
provided to investigators for the 5717 account, Singh spent some of the Second Draw loan
proceeds on expenditures that could qualify as legitimate uses of PPP funds, such as payments to
business solutions providers like Amazon Web Services, Apple, Google, Atlassian, and the like.
35. However, according to records provided to investigators for the 5717 account and
for other financial accounts associated with Singh, Singh spent much of the Second Draw loan
proceeds on a variety of expenditures that do not appear to have been authorized f or PPP funds.
These expenditures included:
///
5 This transaction was made using Fedwire and, accordingly, involved an interstate wire
transmission.
AFFIDAVIT 11
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 13 of 34
a) Hundreds of thousands of dollars in transfers to an Albot corporate bank account
for which Singh was the sole signatory;
b) Transfers to other companies such as engineering and biosciences firms, one of
which issued a press release in or around June 2021 touting its partnership with
Albot to distribute COVID-19 diagnostic testing kits;
c) Tens of thousands of dollars of transfers to a personal banking account held at
Bank of America on which Singh and his wife were the sole signatories;
d) An approximately $500,000 payment to Singh’s home mortgage lender; and
e) Incidentals such as food, clothing, and luxury goods.
36. I conducted a tracing of the proceeds of Kryptoblocks’ Second Draw loan using
an accounting method approved by the Money Laundering and Asset Recovery Section of the
United States Department of Justice. This tracing analysis revealed that the approximately
$500,000 payment to Singh’s mortgage lender necessarily contained greater than $10,000 of the
proceeds of Singh’s fraudulent conduct in obtaining the Second Draw loan. Thus, I submit that
probable cause exists to believe that Singh violated 18 U.S.C. § 1957 by conducting this
financial transaction using more than $10,000 in proceeds from his fraudulent scheme .
2. Forgiveness of Second Draw Loan
37. In or around February 2022, Singh submitted an application to KeyPoint for
forgiveness of the Second Draw loan issued to Kryptoblocks. In support of his forgiveness
application, Singh certified the following, among other things:
a) The Target Account was the email address associated with Kryptoblocks’s
application;
b) The business phone number associated with the application was the 8550 number;
c) The taxpayer identification number associated with the application was
Kryptoblocks’s federal Employer Identification Number;
d) The principal place of business for Kryptoblocks was Singh’s residence in
Sacramento;
AFFIDAVIT 12
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 14 of 34
e) At the times of its applications for the Second Draw loan and for its subsequent
forgiveness, Kryptoblocks employed 101 people;
f) Between March and September 2021, Kryptoblocks paid its employees over $5
million in wages; and
g) Kryptoblocks used its Second Draw loan for payroll costs paid to employees .
38. To substantiate the certifications he made on his application for forgiveness of the
Second Draw loan, Singh used the Target Account to submit to KeyPoint personnel what
purported to be true and accurate copies of various documents, including the following:
a) An IRS Form 941 for the first quarter of 2021, displaying Singh’s residence
address and the 8550 number and purporting to show that Kryptoblocks paid more
than $2.6 million in employee wages that quarter and withheld more than
$744,000 in federal payroll taxes that same quarter;
b) An IRS Form 941 for the second quarter of 2021, displaying Singh’s residence
address and the 8550 number and again purporting to show that Kryptoblocks
paid more than $2.6 million in employee wages that quarter and withheld more
than $744,000 in federal payroll taxes that same quarter;
c) An IRS Form 941 for the third quarter of 2021, displaying Singh’s residence
address and the 8550 number and again purporting to show that Kryptoblocks
paid more than $2.6 million in employee wages that quarter and withheld more
than $744,000 in federal payroll taxes that same quarter; and
d) A spreadsheet purporting to show that Kryptoblocks employed ninety-nine people
to whom it paid more than $10 million in wages (along with associated federal
and California taxes) in 2021, including more than $110,000 paid to Singh
himself, more than $106,000 paid to Singh’s wife, and more than $95,000 paid to
Singh’s brother.
39. However, according to records maintained by the IRS, Kryptoblocks did not
report any income, payroll, or employees to the IRS between 2016 and 2024 . And according to
AFFIDAVIT 13
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 15 of 34
records obtained by investigators from the EDD, Kryptoblocks did not report making any wage
payments to employees in 2021. Additionally, according to information provided to investigators
by the FTB in 2022, Kryptoblocks did not file a corporate tax return with the State of California
for 2021. Furthermore, according to bank records for the 8845 account and the 5717 account,
Singh did not make any payments to tax authorities from these accounts in 2020 or 2021.
40. In or around March 2022 and based on Singh’s representations in support of his
Second Draw loan forgiveness application, KeyPoint requested that the SBA forgive the Second
Draw loan previously extended to Kryptoblocks. In April 2022, the SBA forgave the Se cond
Draw loan in full.
41. Based upon the foregoing, I submit that probable cause exists to believe that
Singh violated 18 U.S.C. § 1344 by submitting a false Second Draw loan forgiveness application
to KeyPoint.
E. The Target Account is associated with loan applications submitted to other
financial institutions.
42. Investigators requested and received records from other financial institutions
regarding financial applications linked to Singh and the Target Account. I reviewed these
records, which, in summary, revealed the following:
a) In or around March 2020, the SBA received an application for an Economic
Injury Disaster Loan to Kryptoblocks that displayed Singh’s home address, Social
Security Number, date of birth, the 8550 number, and the Target Account;
b) In or around April 2020, Singh submitted a PPP loan application from
Kryptoblocks to a financial institution doing business as Ready Capital that
displayed Singh’s name, residential address, the 8550 number, and the Target
Account;
c) In or around March 2021, Singh submitted a PPP loan application to Northeast
Bank on behalf of Albot that displayed his name and Social Security Number, the
Promenade Circle address, the 8550 number, and the Target Account;
AFFIDAVIT 14
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 16 of 34
d) In or around February and March of 2021, the Target Account corresponded with
personnel from a financial lender associated with Northeast Bank regarding a PPP
loan application;
e) In or around March 2021, the SBA received an application for an Economic
Injury Disaster Loan to Albot that displayed Singh’s home address, Social
Security Number, date of birth, the 8550 number, and the Target Account;
f) In or around February 2022, Singh submitted a credit application to Mechanics
Bank for a vehicle loan that displayed Singh’s home address, California driver
license, the purported Kryptoblocks headquarters address on Promenade Circle,
the 8550 number, and the Target Account; and
g) In or around March 2022, the Target Account corresponded with KeyPoint
personnel regarding an application by Kryptoblocks for a small business loan
known as an SBA 7(a) loan.
F. Facts Regarding Relevant Identifiers
43. In or around late 2022, investigators received records from Sprint regarding the
8550 number. These records revealed that the 8550 number was created in 2019 and that for at
least between January and April 2020, the customer of record for the 8550 number was Akash
Singh at an address on Riggs Avenue in Sacramento.
44. According to records maintained by the SBA regarding PPP loan applications
submitted by Kryptoblocks, Singh’s California driver record listed this Riggs Avenue address as
his residence in 2018. In November 2019, Singh also listed this Riggs Avenue address as his
then-current address on his mortgage loan application for his residence on Amelia Earhart
Avenue in Sacramento.
45. In late 2024, investigators received records from Google regarding any Google
accounts associated with the email address akash@albot.io as well as with the email address
///
///
AFFIDAVIT 15
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 17 of 34
akash.labs@gmail.com.6 These records revealed the following about the Google account
associated with the email address akash@albot.io:
a) The account was created on or about March 2, 2020, in the name “akash singh ”
and with the recovery email address of akash.labs@gmail.com;
b) The account was last updated in or around December 2024;
c) In or around October 2024, a number of Google services were removed from th e
account, including Gmail, Google Chat, Google Calendar, Google Drive, and
more; and
d) Google has no record of any communication headers associated with the account.
46. The records received from Google also revealed the following about the Google
account associated with the email address akash.labs@gmail.com:
a) The account was created on or about August 19, 2013, in the name of “Akash
Singh” and with the 8550 number as the associated contact and recovery SMS
number;
b) The account was last updated in November 2024; and
c) Google maintains email header records for the account indicating that it was
copied on emails that were also sent to the Target Account.
47. Google operates a tool on the internet that analyzes email header data and is
publicly available at https://toolbox.googleapps.com/apps/messageheader/. On or about January
30, 2025, I ran the headers of emails sent from the Target Account to KeyPoint personnel in
2021 and 2022 through this header analyzer tool. For some of these emails, the header analyzer
tool did not return an output indicating the source domain of the emails. But for two of the
emails sent from the Target Account to KeyPoint personnel in April 2022, the header analyzer
tool returned an output indicating that the emails sent from the Target Account originated from
6 Singh’s name, the email address akash.labs@gmail.com, and the 8550 number each
appear at the top of a curriculum vitae submitted by the Target Account to KeyPoint personnel in
or around March 2022 in connection with an apparently aborted application for a SBA 7(a) loan.
AFFIDAVIT 16
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 18 of 34
computers associated with domains ending in prod.outlook.com. Based on my training and
experience, I know this domain to be associated with Microsoft’s email communication solutions
such as Outlook and Microsoft Office 365, which is an email communication platform operated
by Microsoft.
48. In or around November 2024, investigators requested and received records
regarding the domain albot.io from an internet hosting provider doing business as Cloudflare.
These records indicated that the domain was created in December 2023 and registered to an
individual with the initials R.G. at an address in Colchester, Great Britain.
49. On or around January 22, 2025, I submitted a preservation request to Microsoft
requesting that it preserve the contents of the Target Account. Based on my training and
experience, I know that in general, an email that is sent to a Microsoft subscriber is stored in the
subscriber’s “mail box” on Microsoft servers until the subscriber deletes the email. If the
subscriber does not delete the message, the message can remain on Microsoft servers
indefinitely. Even if the subscriber deletes the email, it may continue to be available on
Microsoft servers for a certain period of time.
III. BACKGROUND CONCERNING EMAIL
50. In my training and experience, I have learned that Microsoft provides a variety of
on-line services, including email access, to the public. Microsoft allows subscribers to obtain
email accounts at the domain name Microsoft.com and that are associated with a custom domain
name, like the Target Account. This service offered by Microsoft is sometimes referred to as
“Office 365.”
51. Subscribers obtain an account by registering with Microsoft. During the
registration process, Microsoft asks subscribers to provide basic personal information. Therefore,
the computers of Microsoft are likely to contain stored electronic communications (including
retrieved and unretrieved email for Microsoft subscribers) and information concerning
subscribers and their use of Microsoft services, such as account access information, email
transaction information, and account application information. In my training and experience,
AFFIDAVIT 17
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 19 of 34
such information may constitute evidence of the crimes under investigation because the
information can be used to identify the account’s user or users.
52. A Microsoft Office 365 subscriber can also store with the provider files in
addition to emails, such as address books, contact or buddy lists, calendar data, pictures (other
than ones attached to emails), and other files, on servers maintained and/or owned by Microsoft.
In my training and experience, evidence of who was using an email account may be found in
address books, contact or buddy lists, email in the account, and attachments to emails, including
pictures and files.
53. In my training and experience, email providers generally ask their subscribers to
provide certain personal identifying information when registering for an email account. Such
information can include the subscriber’s full name, physical address, telephone n umbers and
other identifiers, alternative email addresses, and, for paying subscribers, means and source of
payment (including any credit or bank account number). In my training and experience, such
information may constitute evidence of the crimes under investigation because the information
can be used to identify the account’s user or users. Based on my training and my experience, I
know that even if subscribers insert false information to conceal their identity, this information
often provides clues to their identity, location, or illicit activities.
54. In my training and experience, email providers typically retain certain
transactional information about the creation and use of each account on their systems. This
information can include the date on which the account was created, the length of service, re cords
of login times and durations, the types of service utilized, the status of the account (including
whether the account is inactive or closed), the methods used to connect to the account (such as
logging into the account via the provider’s website), and other log files that reflect usage of the
account.
55. In addition, email providers often have records of the Internet Protocol address
(the “IP address”) used to register the account and the IP addresses associated with particular
logins to the account. Because every device that connects to the internet must use an IP address,
AFFIDAVIT 18
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 20 of 34
IP address information can help to identify which computers or other devices were used to access
the email account.
56. In my training and experience, in some cases, email account users will
communicate directly with an email service provider about issues relating to the account, such as
technical problems, billing inquiries, or complaints from other users. Email providers typically
retain records about such communications, including records of contacts between the user and
the provider’s support services, as well as records of any actions taken by the provider or user as
a result of the communications. In my training and experience, such information may constitute
evidence of the crimes under investigation because the information can be used to identify the
account’s user or users.
57. As explained herein, information stored in connection with an email account may
provide crucial evidence of the “who, what, why, when, where, and how” of the criminal conduct
under investigation, thus enabling the United States to establish and prove each element or
alternatively, to exclude the innocent from further suspicion. In my training and experience, the
information stored in connection with an email account can indicate who has used or controlled
the account. This “user attribution” evidence is analogous to the search for “indicia of
occupancy” while executing a search warrant at a residence. For example, email
communications, contacts lists, and images sent (and the data associated with the foregoing, such
as date and time) may indicate who used or controlled the account at a relevant time.
58. Further, information maintained by the email provider can show how and when
the account was accessed or used. For example, as described below, email providers typically log
the IP addresses from which users access the email account along with the time and date of that
access. By determining the physical location associated with the logged IP addresses,
investigators can understand the chronological and geographic context of the email account
access and use relating to the crime under investigation. This geo graphic and timeline
information may tend to either inculpate or exculpate the account owner.
///
AFFIDAVIT 19
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 21 of 34
59. Additionally, information stored at the user’s account may indicate the geographic
location of the account user at a particular time (such as location information integrated into an
image or video sent via email). Last, stored electronic data may provide relevant insight into the
email account owner’s state of mind as it relates to the offenses under investigation. For
example, information in the email account may indicate the owner’s motive and intent to commit
a crime (for instance, communications relating to the crime), or consciousness of guilt (for
example, deleting communications in an effort to conceal them from law enforcement).
IV. CONCLUSION AND REQUEST FOR SEALING
60. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not
required for the service or execution of this warrant. The government will execute this warrant
by serving the warrant on Microsoft.
61. Based on the foregoing, I request that the Court issue the proposed search
warrant. Because the warrant will be served on Microsoft, which will then compile the requested
records at a time convenient to it, reasonable cause exists to permit the execution of the
requested warrant at any time in the day or night.
///
///
///
///
///
///
///
///
///
///
///
///
AFFIDAVIT 20
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 22 of 34
62. I further request that the Court order that all papers in support of this application,
including the affidavit and search warrant, be sealed until further order of the Court. These
documents discuss an ongoing criminal investigation that is neither public nor known to all of
the targets of the investigation. Accordingly, there is good cause to seal these documents because
their premature disclosure may seriously jeopardize that investigation.
Respectfully submitted,
/s/ Marshall Miller
Marshall Miller
Special Agent
Internal Revenue Service-Criminal Investigation
Subscribed and sworn to telephonically on: February 18, 2025
THE HONORABLE JEREMY D. PETERSON
United States Magistrate Judge
/s/ Sam Stefanki
Approved as to form by AUSA SAM STEFANKI
AFFIDAVIT 21
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 23 of 34
ATTACHMENT A
Property to Be Searched
This warrant applies to information associated with the email address akash@albot.io that
is stored at premises owned, maintained, controlled, or operated by Microsoft Corporation USA,
a company headquartered at 1 Microsoft Way, Redmond, Washington 98052.
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 24 of 34
ATTACHMENT B
Particular Things to be Seized
I. Information to Be Disclosed by Microsoft Corporation USA (the “Provider”)
To the extent that the information described in Attachment A is within the possession,
custody, or control of the Provider, regardless of whether such information is located within or
outside of the United States, and including any emails, records, files, logs, or information that
has been deleted but is still available to the Provider, or has been preserved pursuant to a request
made under 18 U.S.C. § 2703(f), the Provider is required to disclose the following information to
the government for each account or identifier listed in Attachment A:
1. The contents of all emails associated with the account, including stored or
preserved copies of emails sent to and from the account, draft emails, the source and destination
addresses associated with each email, the date and time at which each email was sent, and the
size and length of each email;
2. All records or other information regarding the identification of the account, to
include full name, physical address, telephone numbers and other identifiers, records of session
times and durations, the date on which the account was created, the length of service, the IP
address used to register the account, login IP addresses associated with session times and dates,
account status, alternative email addresses provided during registration, methods of connecting,
log files, and means and source of payment (including any credit or bank account number);
3. The types of service utilized;
4. All records or other information stored by an individual using the account,
including address books, contact and buddy lists, calendar data, pictures, and files; and
5. All records pertaining to communications between the Provider and any person
regarding the account, including contacts with support services and records of actions taken.
The Provider is hereby ordered to disclose the above information to the government
within fourteen days of service of this warrant.
II. Information to Be Seized by the Government
All information described above in Section I that constitutes evidence of violations of 18
U.S.C. §§ 1343, 1344, or 1957, those violations involving Akash Kumar Singh and occurring
after March 1, 2020, including, for each account or identifier listed on Attachment A,
information pertaining to the following matters:
1. Communications and records that discuss or otherwise show the user(s) of the
target accounts and any company or entity affiliation or employment of that person or persons ,
including all communications and records relating to or purporting to be on behalf of the
following:
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 25 of 34
a) Kryptoblocks;
b) Albot;
c) Akash Kumar Singh;
d) Neelam Singh; or
e) Neeraj Masih.
2. Communications and records that discuss or relate to, in coded or un-coded
language, knowledge of the following:
a) The Paycheck Protection Program;
b) The CARES Act;
c) Economic Injury Disaster Loans;
d) COVID-related tax credits, refunds, or advances from the IRS; or
e) The application processes for any of these loans, credits, refunds, or advances.
3. Communications and records that discuss or relate to, in coded or un-coded
language, the following:
a) Preparation of company books and records for Kryptoblocks, Albot, or any other
business entities associated with Akash Kumar Singh;
b) Preparation of federal personal income tax returns, federal business income tax
returns, federal payroll tax returns, or any other claims for refunds or advances
from the IRS;
c) Preparation of state payroll tax returns (including but not limited to California
Forms DE 9 and DE 9C), refund amounts, methods of payment, bank account
information, status of prepared and/or filed tax returns or their associated claims
for refunds or advances, and knowledge of tax laws and regulations;
d) Financial loans, such as mortgage or vehicle loans; or
e) Personal financial expenditures (such as electronic receipts or other records of
purchases made).
4. Communications and records that discuss or relate to, in coded or un-coded
language, information regarding the acquisition and distribution of funds received from the
violations listed above or the proceeds of other fraud, including:
a) Bank account information;
ATTACHMENT B 2
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 26 of 34
b) Commission payments;
c) Bank account set-up instructions;
d) Identities of individuals listed with access to bank accounts;
e) Method of deposits;
f) Acceptance from federal or financial authorities;
g) Information regarding individuals with ability and access to virtually deposit
checks.
5. Communications and records that discuss or relate to, in coded or un-coded
language, information regarding agreements and business contracts involving Kryptoblocks,
Albot, or any other business entities associated with Akash Singh, Neelam Singh, or Neeraj
Masih, including monetary agreements and non-monetary agreements, employment agreements,
contracting agreements, and the like.
6. Communications and records that discuss or relate to, in coded or un-coded
language, personal identifying information, names, routing numbers, bank account numbers,
addresses, dollar amounts, financial transfers, wiring instructions, pre-paid debit cards, or any
other details related to financial accounts or financial transactions.
7. Records tending to show who created, used, or communicated with the account,
including records about their identities and whereabouts.
8. Records tending to identify other accounts, domains, IP addresses, and computers
owned or controlled by the same individual or individuals controlling the account.
9. Records tending to establish the identity of the person or persons in control of the
account, including identification documents (such as driver licenses or passports), photographs,
bills, receipts, vehicle registration documents, statements, leasing agreements, personal address
books, calendars, daily planners, personal organizers, and the like.
10. Evidence indicating how and when the account was accessed or used, to
determine the geographic and chronological context of account access, use, and events relating to
the crime under investigation and to the email account owner.
11. Evidence indicating the state of mind of each of the users of the account as it
relates to the crime under investigation.
12. The identity of the person(s) who created or used the account, including records
that help reveal the whereabouts of such person(s).
///
///
ATTACHMENT B 3
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 27 of 34
13. Records evidencing the use of the account to communicate with Microsoft mail
servers, including:
a) Records of IP addresses used;
b) Records of internet activity, including firewall logs, caches, browser history and
cookies, “bookmarked” or “favorite” web pages, search terms that the user
entered into any internet search engine, and records of user-typed web addresses.
As used above, the terms “records” and “information” include all of the foregoing items
of evidence in whatever form and by whatever means they may have been created or stored,
including any form of computer or electronic storage (such as flash memory or other media that
can store data) and any photographic form.
This warrant authorizes a review of electronic storage media and electronically stored
information seized or copied pursuant to this warrant in order to locate evidence, fruits, and
instrumentalities described in this warrant. The review of this electronic data may be conducted
by any government personnel assisting in the investigation, who may include, in addition to law
enforcement officers and agents, attorneys for the government, attorney support staff, and
technical experts. Pursuant to this warrant, the investigating agency may deliver a complete copy
of the seized or copied electronic data to the custody and control of attorneys for the government
and their support staff for their independent review.
ATTACHMENT B 4
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 28 of 34
AO 93 (Rev. 11/13) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Eastern District of California
In the Matter of the Search of
)
INFORMATION ASSOCIATED WITH THE EMAIL
)
) Case No.
2:25-sw-0136 JDP
ADDRESS AKASH@ALBOT.IO THAT IS STORED AT
)
SEALED
PREMISES CONTROLLED BY MICROSOFT
)
CORPORATION USA )
SEARCH AND SEIZURE WARRANT
To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Western District of Washington
(identify the person or describe the property to be searched and give its location) :
SEE ATTACHMENT A, attached hereto and incorporated by reference.
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal (identify the person or describe the property to be seized) :
SEE ATTACHMENT B, attached hereto and incorporated by reference.
YOU ARE COMMANDED to execute this warrant on or before March 4, 2025 (not to exceed 14 days)
in the daytime 6:00 a.m. to 10:00 p.m. at any time in the day or night because good cause has been established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the
person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the
property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory
as required by law and promptly return this warrant and inventory to: any authorized U.S. Magistrate Judge in the Eastern
District of California.
Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or wh ose
property, will be searched or seized (check the appropriate box)
for days (not to exceed 30) until, the facts justifying, the later specific date of .
Date and time issued: February 18, 2025 at 4:46 p.m.
Judge’s signature
City and state: Sacramento, California Jeremy D. Peterson, U.S. Magistrate Judge
Printed name and title
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 29 of 34
AO 93 (Rev. 11/13) Search and Seizure Warrant (Page 2) (modified)
Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I swear that this inventory is a true and detailed account of the person or property taken by me on the warrant.
_____________________________________________________________
Subscribed, sworn to, and returned before me this date.
____________________________________________ ______________________________
Signature of Judge Date
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 30 of 34
ATTACHMENT A
Property to Be Searched
This warrant applies to information associated with the email address akash@albot.io that
is stored at premises owned, maintained, controlled, or operated by Microsoft Corporation USA,
a company headquartered at 1 Microsoft Way, Redmond, Washington 98052.
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 31 of 34
ATTACHMENT B
Particular Things to be Seized
I. Information to Be Disclosed by Microsoft Corporation USA (the “Provider”)
To the extent that the information described in Attachment A is within the possession,
custody, or control of the Provider, regardless of whether such information is located within or
outside of the United States, and including any emails, records, files, logs, or information that
has been deleted but is still available to the Provider, or has been preserved pursuant to a request
made under 18 U.S.C. § 2703(f), the Provider is required to disclose the following information to
the government for each account or identifier listed in Attachment A:
1. The contents of all emails associated with the account, including stored or
preserved copies of emails sent to and from the account, draft emails, the source and destination
addresses associated with each email, the date and time at which each email was sent, and the
size and length of each email;
2. All records or other information regarding the identification of the account, to
include full name, physical address, telephone numbers and other identifiers, records of session
times and durations, the date on which the account was created, the length of service, the IP
address used to register the account, login IP addresses associated with session times and dates,
account status, alternative email addresses provided during registration, methods of connecting,
log files, and means and source of payment (including any credit or bank account number);
3. The types of service utilized;
4. All records or other information stored by an individual using the account,
including address books, contact and buddy lists, calendar data, pictures, and files; and
5. All records pertaining to communications between the Provider and any person
regarding the account, including contacts with support services and records of actions taken.
The Provider is hereby ordered to disclose the above information to the government
within fourteen days of service of this warrant.
II. Information to Be Seized by the Government
All information described above in Section I that constitutes evidence of violations of 18
U.S.C. §§ 1343, 1344, or 1957, those violations involving Akash Kumar Singh and occurring
after March 1, 2020, including, for each account or identifier listed on Attachment A,
information pertaining to the following matters:
1. Communications and records that discuss or otherwise show the user(s) of the
target accounts and any company or entity affiliation or employment of that person or persons ,
including all communications and records relating to or purporting to be on behalf of the
following:
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 32 of 34
a) Kryptoblocks;
b) Albot;
c) Akash Kumar Singh;
d) Neelam Singh; or
e) Neeraj Masih.
2. Communications and records that discuss or relate to, in coded or un-coded
language, knowledge of the following:
a) The Paycheck Protection Program;
b) The CARES Act;
c) Economic Injury Disaster Loans;
d) COVID-related tax credits, refunds, or advances from the IRS; or
e) The application processes for any of these loans, credits, refunds, or advances.
3. Communications and records that discuss or relate to, in coded or un-coded
language, the following:
a) Preparation of company books and records for Kryptoblocks, Albot, or any other
business entities associated with Akash Kumar Singh;
b) Preparation of federal personal income tax returns, federal business income tax
returns, federal payroll tax returns, or any other claims for refunds or advances
from the IRS;
c) Preparation of state payroll tax returns (including but not limited to California
Forms DE 9 and DE 9C), refund amounts, methods of payment, bank account
information, status of prepared and/or filed tax returns or their associated claims
for refunds or advances, and knowledge of tax laws and regulations;
d) Financial loans, such as mortgage or vehicle loans; or
e) Personal financial expenditures (such as electronic receipts or other records of
purchases made).
4. Communications and records that discuss or relate to, in coded or un-coded
language, information regarding the acquisition and distribution of funds received from the
violations listed above or the proceeds of other fraud, including:
a) Bank account information;
ATTACHMENT B 2
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 33 of 34
b) Commission payments;
c) Bank account set-up instructions;
d) Identities of individuals listed with access to bank accounts;
e) Method of deposits;
f) Acceptance from federal or financial authorities;
g) Information regarding individuals with ability and access to virtually deposit
checks.
5. Communications and records that discuss or relate to, in coded or un-coded
language, information regarding agreements and business contracts involving Kryptoblocks,
Albot, or any other business entities associated with Akash Singh, Neelam Singh, or Neeraj
Masih, including monetary agreements and non-monetary agreements, employment agreements,
contracting agreements, and the like.
6. Communications and records that discuss or relate to, in coded or un-coded
language, personal identifying information, names, routing numbers, bank account numbers,
addresses, dollar amounts, financial transfers, wiring instructions, pre-paid debit cards, or any
other details related to financial accounts or financial transactions.
7. Records tending to show who created, used, or communicated with the account,
including records about their identities and whereabouts.
8. Records tending to identify other accounts, domains, IP addresses, and computers
owned or controlled by the same individual or individuals controlling the account.
9. Records tending to establish the identity of the person or persons in control of the
account, including identification documents (such as driver licenses or passports), photographs,
bills, receipts, vehicle registration documents, statements, leasing agreements, personal address
books, calendars, daily planners, personal organizers, and the like.
10. Evidence indicating how and when the account was accessed or used, to
determine the geographic and chronological context of account access, use, and events relating to
the crime under investigation and to the email account owner.
11. Evidence indicating the state of mind of each of the users of the account as it
relates to the crime under investigation.
12. The identity of the person(s) who created or used the account, including records
that help reveal the whereabouts of such person(s).
///
///
ATTACHMENT B 3
Case 2:25-sw-00136-JDP Document 1 Filed 02/18/25 Page 34 of 34
13. Records evidencing the use of the account to communicate with Microsoft mail
servers, including:
a) Records of IP addresses used;
b) Records of internet activity, including firewall logs, caches, browser history and
cookies, “bookmarked” or “favorite” web pages, search terms that the user
entered into any internet search engine, and records of user-typed web addresses.
As used above, the terms “records” and “information” include all of the foregoing items
of evidence in whatever form and by whatever means they may have been created or stored,
including any form of computer or electronic storage (such as flash memory or other media that
can store data) and any photographic form.
This warrant authorizes a review of electronic storage media and electronically stored
information seized or copied pursuant to this warrant in order to locate evidence, fruits, and
instrumentalities described in this warrant. The review of this electronic data may be conducted
by any government personnel assisting in the investigation, who may include, in addition to law
enforcement officers and agents, attorneys for the government, attorney support staff, and
technical experts. Pursuant to this warrant, the investigating agency may deliver a complete copy
of the seized or copied electronic data to the custody and control of attorneys for the government
and their support staff for their independent review.
ATTACHMENT B 4
File and source
- File
- gov.uscourts.caed.460924.1.0.pdf
- Size
- 1,129,388 bytes
- SHA-256
- 4c5dcdad856129b68eb62f6b24bb9a0311c35e9efc26157277f86aba449cd9e5
- Our copy
- gov.uscourts.caed.460924.1.0.pdf
- Original
- archive.org