Complaint — No. 2:21-mj-30462 (Dkt. 1, E.D. Mich.)

Summary

A criminal complaint (AO 91) filed September 28, 2021 in United States v. Rapheal Jarrell Smiley, Case 2:21-mj-30462, in the U.S. District Court for the Eastern District of Michigan, charging fraud involving agency seals under 18 USC 506(a)(3), identity document fraud under 18 USC 1028(a)(6) and trafficking in counterfeit goods under 18 USC 2320(a)(1) for August 3, 2021 to September 2, 2021. The affidavit of Homeland Security Investigations Special Agent Bryan V. Randall alleges that Smiley imported counterfeit CDC COVID-19 vaccination record cards from China to sell. It states that CBP officers in Memphis found 52 fraudulent cards bearing an unauthorized copy of the CDC seal in a parcel addressed to Smiley. After a controlled delivery on September 2, 2021, agents seized 48 additional counterfeit cards and phones, and the affidavit quotes social media posts offering cards.

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