Complaint — United States v. Eduard Ghiocel (No. 3:23-mj-00474, S.D. Cal.)

Summary

A sealed criminal complaint filed February 10, 2023 as Document 1 in United States v. Eduard Ghiocel et al., Magistrate Case No. 23MJ0474 (3:23-mj-00474-JLB), in the U.S. District Court for the Southern District of California, ordered unsealed on 03/14/2023. Count One charges Eduard, Floarea, Gabriel, Marius and Larisa Ghiocel and Argentina Alexandru with conspiracy under Title 18 U.S.C. § 1956(h) to transport funds abroad to promote wire fraud, mail fraud and robbery. The forfeiture allegations list a 2019 Lamborghini Urus bought for $260,575.00, approximately $733,092 in gold bars and coins, and approximately $119,950 in stolen jewelry, cash and California EDD benefits. The probable cause statement of FBI Special Agent Courtney M. McGuire, attested before Magistrate Judge Michael S. Berg, alleges jewelry thefts from elderly victims and transfers of proceeds to Romania.

Summary drafted by a model from the text of the original file linked on this page 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

Cite this document

“Complaint — United States v. Eduard Ghiocel (No. 3:23-mj-00474, S.D. Cal.).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/complaint-no-3-23-mj-00474-dkt-1-s-d-cal-96ca9b1f9e/, SHA-256 9b5e508294287cc38ddec9e75ad2e879dab02cb7fdc172739443a2af2cb72883.

Full text

Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.51 Page 1 of 34
SEALED
ORDERED UNSEALED on 03/14/2023 s/ JudePetersen

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA

) Magistrate Case No.
UNITED STATES OF AMERICA, ) '23 MJ0474
________________
)
)
) COMPLAINT FOR VIOLATION OF
vs. ) Title 18 U.S.C. § 1956(h)and
) Title 18 U.S.C. § 1956(a)(2)(A)
) — Conspiracy to Transport Funds
EDUARD GHIOCEL (1), ) to Promote Unlawful Activity;
aka Eduard Alexandru, aka )
)
“Filica”, ) Title 18, U.S.C., Sec. 982(a) —
FLOAREA GHIOCEL (2), ) Criminal Forfeiture
aka Floarea Alexandru, )
GABRIEL GHIOCEL (3), ) [UNDER SEAL]
MARIUS GHIOCEL (4), )
)
LARISA GHIOCEL (5), and
ARGENTINA ALEXANDRU (6)

Defendants.
The undersigned complainant being duly sworn states:

Count One

1. Beginning on a date unknown, and continuing to and until

September, 2022, within the Southern District of California and

elsewhere, defendants EDUARD GHIOCEL, aka Eduard Alexandru, aka

"Filica"; FLOAREA GHIOCEL, aka Floarea Alexandru; GABRIEL

GHIOCEL; MARIUS GHIOCEL; LARISA GHIOCEL; and ARGENTINA

ALEXANDRU did knowingly and intentionally combine, conspire,

and agree among themselves to commit the following money

laundering offense, to wit: to transport, transmit and transfer

and attempt to transport, transmit and transfer a monetary

instrument and funds from a place in the United States to and

through a place outside the United States with the intent to

promote the carrying on of specified unlawful activity, that is

violations of Wire Fraud, 18 U.S.C. § 1343; Mail Fraud, 18

U.S.C. §§ 1341 and 1346; Felony First Degree Robbery, California
1
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.52 Page 2 of 34

Penal Code 211; and Felony Second Degree Robbery, California

Penal Code 212.5(c); all in violation of Title 18, United States

Code, Section 1956(a)(2)(A).

All in violation of Title 18, United States Code, Section

1956(h).

Criminal Forfeiture Allegations

2. The allegations contained in Count 1 above are

incorporated herein for purposes of alleging forfeiture to the

United States pursuant to Title 18, United States Code, Sections

982(a) and 982(b).

3. Upon conviction of the offense set forth in Count 1 of

the Complaint, defendants EDUARD GHIOCEL, aka Eduard Alexandru,

aka Filica; FLOAREA GHIOCEL, aka Floarea Alexandru; GABRIEL

GHIOCEL; MARIUS GHIOCEL; LARISA GHIOCEL; and ARGENTINA ALEXANDRU

shall forfeit to the United States of America pursuant to Title

18, United States Code, Section 982(a)(1), any property, real and

personal, involved in Count 1, and any property traceable to such

property. The property to be forfeited includes, but is not

limited to:
a. a white 2019 Lamborghini Urus, Vin ZPBUA1ZL5KLA01530,

purchased by Ionut Alexandru on or about October 14, 2021

for $260,575.00 from Newport Beach Lamborghini (Paragraph 48).

b. a 2020 or 2021 Ferrari Portofino that cost $230,000
registered in Romania on March 23, 2022 (Paragraph 49).
c. approximately $119,950 worth of stolen jewelry, watches,

cash, and money received from applying for California EDD benefits

as detailed in Paragraphs 15-41 of the attached Probable Cause

statement.

2
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.53 Page 3 of 34

d. approximately $733,092 worth of gold bars and coins

purchased as detailed in Paragraphs 45(a)-(m) of the attached

Probable Cause Statement.

e. approximately $24,035.02 worth of cash or financial

instruments from the international transfers (Paragraphs 50(a)-(q)).
4. In the event that any of the property described above,
as a result of any act or omission of the Defendants:
a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a
third party;
c. has been placed beyond the jurisdiction of the court;

d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be
divided without difficulty,

it is the intent of the United States of America, pursuant to Title
18, United States Code, Section 982(b), to seek forfeiture of

substitute property up to the value of forfeitable property

described above.

5. This complaint is based on the facts in the attached
probable cause statement, which is incorporated herein by

reference.

Courtney M. McGuire
______________________________
Courtney M. McGuire
FBI Special Agent

Attested to by the applicant in accordance with the requirements
of Fed. R. Crim. P. 4.1 by telephone, this 9th day of February,
2023.

______________________________
Honorable Michael S. Berg
United States Magistrate Judge

3
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.54 Page 4 of 34

PROBABLE CAUSE STATEMENT
1. I am an investigative or law enforcement officer within

the meaning of Title 18, United States Code, Section 2510 (7);

that is, an officer of the United States, who is empowered by law

to conduct investigations of and to make arrests for offenses

enumerated in Title 18, United States Code, Section 2516. I have

been employed as a Special Agent with the Federal Bureau of

Investigation (FBI) since December of 2021. I am presently assigned

to the FBI San Diego’s Transnational Organized Crime – Global squad

(TOC-G). This squad investigates money laundering and other

derivative financial crimes committed by criminal organizations.

Prior to my assignment with the TOC-G squad, I completed the 17-

week FBI Academy in Quantico, Virginia and was trained in

investigative techniques, procedures and strategies. Prior to my

appointment as a Special Agent, I worked for the FBI as a Tactical

Specialist and administrative support employee for four years. As

a Tactical Specialist, I conducted research and analyzed data in

support of federal criminal and national security investigations.

Prior to my appointment to the FBI, I served as a Jailer for the

Laguna Beach Police Department in Laguna Beach, California. I have

a Bachelor of Science degree in Biology from Boise State

University.

2. As a Tactical Specialist and Special Agent with the FBI,
I have participated in numerous investigations involving

individuals of criminal organizations engaged in money laundering,

4
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.55 Page 5 of 34

drug trafficking, human trafficking and robbery. Through my

investigations, my training and experience, and discussions with

other law enforcement personnel, I have become familiar with the

tactics and methods used by criminal enterprises to collect and

launder the proceeds from specified unlawful activity to include

drug trafficking, interstate transportation of stolen goods, wire

fraud and mail fraud. My knowledge of the matters contained in

this affidavit is based upon my personal knowledge, information

provided to me by other law enforcement officers/agents, and

information provided by one or more Confidential Sources (CS)

and/or Sources of Information (SOI).

A. Background of the Investigation

3. FBI San Diego is currently investigating a criminal

organization, hereinafter the Valcea Crime Ring, comprised of Roma

travelers known to conduct various frauds and thefts throughout

the United States. Members of the Valcea Crime Ring travel from

the Valcea region of Romania to Mexico and/or Canada with the

intent of smuggling themselves into the United States. If

apprehended by United States authorities, members of the Valcea
Crime Ring applied for and were often granted asylum status to

enter the United States. Upon entrance into the United States,

members of the organization were responsible for generating as

much income as possible through theft, begging and other financial

crimes. Members of the Valcea Crime Ring traveled together, driving

rental cars and staying in hotels, and spent a significant amount

of time in California. While in California, members of the Valcea
Crime Ring traveled throughout the San Francisco Bay Area,

Sacramento, Los Angeles, Orange County and San Diego.

5
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.56 Page 6 of 34

Investigators believe members of the Valcea Crime Ring travel

frequently to avoid detection and conceal plans of criminal

activity.

4. The Valcea Crime Ring operates in a consortium of inter-

related sub-groups associated through blood and marriage. The sub-

groups are typically led by a male head of family. Although each

sub-group typically retain their own criminal proceeds, the sub-

groups frequently share and pool resources. Sub-groups travel

together to meet with other sub-groups. The Valcea Crime Ring’s

Roma culture is historically self-governed where sub-group leaders

collectively make decisions for the overall criminal organization,

to include dispute resolution and information sharing. Sub-group

leaders typically publish mass communications via Facebook,

including Facebook live videos. It is known to investigators that

the sub-group members serve in specialized roles to generate income

and launder illicit proceeds for the benefit of each sub-group.

5. The money gained through illicit means is laundered

using various techniques with the goal of repatriating the funds

to Romania. The investigation to date has shown the Valcea Crime
Ring does not typically use the United States banking system to

store their illicit proceeds. Most commonly, Valcea Crime Ring

members purchase luxury vehicles, jewelry and gold bars with the

intent to store the goods in the United States or smuggle the goods

to Romania. Occasionally, Valcea Crime Ring members send

international wire transfers to Romania via Money Service

Businesses (MSBs).
B. Introduction of Valcea Crime Ring and Members of

Ghiocel Sub-Group

6
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.57 Page 7 of 34

6. In September 2021, Romanian law enforcement provided

information to the FBI identifying Eduard Ghiocel as a leader of

an organized criminal group. Investigators discovered Eduard

Ghiocel operated as a sub-group leader within the Valcea Crime

Ring and participated in criminal acts along with sub-group

members, Floarea Ghiocel, Marius Ghiocel, Gabriel Ghiocel,

Argentina Alexandru and Larisa Ghiocel. In November of 2021, the

San Diego Police Department (SDPD) became aware of a series of

felony theft related crimes targeting the elderly population in

San Diego. Throughout SDPD’s investigation, detectives determined

the aforementioned members of the Valcea Crime Ring conducted

numerous jewelry thefts throughout the United States.

7. Eduard Ghiocel, a Romanian citizen born March 18, 1975,

is described as a bald male with a dark beard. Investigators

conducted an interview of cooperating witness F.T.1 in June of

2022. F.T. told investigators that Eduard Ghiocel, (Aka Eduard

Alexandru, aka Filica), is a top “Gypsy” and a “bandit” that makes

millions. Another cooperating witness, L.P.2, identified Eduard as

the leader of a 24 to 50 person family.
8. Floarea Ghiocel, a Romanian citizen born March 29, 1974,

has a large build and gold teeth. Floarea Ghiocel is married to

Eduard Ghiocel. Marius Ghiocel, a Romanian citizen born August 30,

1 F,T. was detained in June of 2022 for suspicion of California Penal Code
(PC) 186.10 (a) money laundering, PC 182(a)(1) conspiracy and PC 532(a)
obtain money under false pretenses. F.T. waived his/her Miranda rights and
provided a voluntary statement to law enforcement. F.T. was not promised
anything in return for his/her cooperation and was ultimately released. F.T.
has prior arrests for alien inadmissibility and driving without a license.
Additionally, as of January 23, 2023 F.T. had an active arrest warrant out of
Georgia for a failure to appear in May of 2022.
2 L.P. was contacted in July of 2022 and provided a voluntary statement to law

enforcement. L.P. was not promised anything in return for his/her
cooperation. In February 2021, L.P. plead guilty to one count of Title 8 USC
1324 (a)(1)(A)(i) – conspiracy to bring in aliens for financial gain.

7
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.58 Page 8 of 34

1989, has one cloudy eye and is the son of Eduard and Floarea

Ghiocel. Argentina Alexandru, a Romanian citizen born June 23,

1991, was a girlfriend of Marius Ghiocel. Gabriel Ghiocel, is a

Romanian citizen born June 16, 1997 and is the son of Eduard and

Floarea. Larisa Ghiocel, a Romanian citizen born January 3, 1999,

is married to Gabriel Ghiocel.

9. Members of the Valcea Crime Ring are often described by

victims as possibly being of Middle Eastern descent. Female members

are often reported to wear long dresses, skirts or scarves. When

encountered by law enforcement, members of the Valcea Crime Ring

self-proclaim to be poor “Gypsies”.

C. Means and Methods of Specified Unlawful Activity by

Valcea Crime Ring

10. The Valcea Crime Ring, are known to conduct various

frauds and thefts throughout the United States. Often, members of

the Valcea Crime Ring operate in pairs or small groups to target

elderly victims in shopping center parking lots or residential

areas. A male suspect frequently waits in a rental vehicle while

a female suspect approaches the victim. Their modus operandi (MO)
is to distract victims and use sleight-of-hand techniques in which

they place inexpensive gold costume jewelry on a victim, while

simultaneously removing the victim’s expensive jewelry. On some

occasions, the Valcea Crime Ring members are also known to use

sleight-of-hand techniques to steal cash from victims.

11. According to a Facebook search warrant obtained by

investigators, in December of 2020 Gabriel Ghiocel (Facebook
profile “Gabriel Piciu,” Facebook unique ID 100006267510581)

communicated with “Angloma Andrei” via Facebook about getting rich

8
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.59 Page 9 of 34

in the United States. Investigators used Google Translate to review

a portion of the communications. On December 13, 2020 at 06:47:05

UTC, Gabriel sent “Here everyone makes money”. Immediately after,

at 06:47:15 UTC, Gabriel Ghiocel sent “They are very gullible”.

Investigators believe Gabriel Ghiocel referred to victims of the

Valcea Crime Ring being gullible.

12. In July 2022, cooperating witness L.P. told

investigators the Ghiocel clan from Valcea are known for selling

fake gold and can make up to $20,000.00 per day. L.P. told law

enforcement each member of the Ghiocel clan rents cars to go out

and commit crimes.

13. In June 2022, M.C.3, a cooperating witness and member of

the Valcea Crime Ring, told investigators they typically sell

$200.00 to $300.00 of fake gold jewelry each day. Once reaching

their goal, they go back to their hotel to sleep. Investigators

believe Valcea Crime Ring members patrol for unsuspecting victims

every day.

14. In December 2017, a Canadian police department issued a

press release to warn citizens of a “notorious crime group”,
involving Floarea Ghiocel, who is known for distraction thefts.

According to the report, “these groups often travel city to city

and province to province to commit their crimes” and they typically

target “individuals who wear gold earrings, necklaces, bracelets

or rings”.

D. Overt Acts by Valcea Crime Ring

3 M.C. was detained in June of 2022 for suspicion of California Penal Code
(PC) 186.10 (a) money laundering, PC 182(a)(1) conspiracy and PC 532(a)
obtain money under false pretenses. C.M. waived his/her Miranda rights and
provided a voluntary statement to law enforcement. C.M. was not promised
anything in return for his/her cooperation and was ultimately released. C.M.
has prior arrests for alien inadmissibility.

9
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.60 Page 10 of 34

15. On March 4, 2020, two suspects approached victim 1 (V1)

in the parking lot of the Westminster Superstore located in

Westminster, California. After exiting his/her vehicle, V1 was

approached by a 2019 silver Jeep Compass driven by a male suspect.

A female suspect exited the vehicle and placed gold colored chains

in V1’s hand and around V1’s neck. The suspects departed in the

Jeep Compass. Shortly thereafter, V1 realized the female suspect

stole V1’s 18 karat gold chain with an attached jade and gold

Buddha. The estimated value of the gold chain and the attached

Buddha was $5,000.00. At the time of the incident, the suspect

vehicle was rented by “Floarea Ghioceo” (believed to be Floarea

Ghiocel). Investigators do not believe the incident was referred

to the Orange County District Attorney’s office for prosecution.

16. On May 14, 2020, victim 2 (V2) was approached by a male

and female suspect in the parking lot of a Walmart located in

National City, California. As V2 was loading items into his/her

vehicle, a black SUV drove up. The driver of the black SUV was

described as a Middle Eastern male that had an “issue” with one of

his eyes. The female suspect was described as a Middle Eastern
female, approximately 30 years old, with black hair, wearing

“Muslim clothing”. The female suspect called V2 to the passenger

window of the suspect vehicle. V2 approached the vehicle and the

female suspect placed several items of gold colored jewelry on

him/her. As the suspects drove away, V2 realized his/her gold chain

and pendant were missing. The estimated value of the gold chain

and pendant was $3,000.00.
17. As a result of a follow-up investigation of the facts in

10
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.61 Page 11 of 34

paragraph 16, Marius Ghiocel plead guilty on May 16, 2022 in

SCD294523 to Felony Conspiracy, PC 182(a)(1) and Grand Theft

Person, PC 487(c)in the Superior Court of California, County of

San Diego and sentenced to two years felony summary probation,

stating “On May 14, 2020 I did conspire with another person to

commit a theft of property over $950 by removing jewelry from the

person of another and in furtherance of that conspiracy, I did

drive a vehicle with another person in order to make contact with

an unsuspecting victim.” Additionally, Marius was ordered to pay

$12,000 in restitution and surrendered $3,917 cash seized toward

restitution to V2.

18. On May 20, 2022, Argentina Alexandru plead guilty to

Felony Conspiracy, PC 182(a)(1) and Grand Theft Person, PC 487(c)in

the Superior Court of California, County of San Diego agreeing to

the factual basis “On May 14, 2020, I did conspire with another

person to commit a theft of property over $950 by removing jewelry

from the person of another and in furtherance of that conspiracy,

I did drive in a vehicle with another person in order to make

contact with an unsuspecting victim and did steal jewelry from the
person of another worth over $950.” Argentina Alexandru was

sentenced to two years summary probation and a stayed fine of $820

with the restitution satisfied by co-Defendant Marius Ghiocel in

SCD294523.

19. On May 28, 2020, victim 3 (V3) was approached by two

suspects driving a black SUV in a residential area of Fountain

Valley, California. V3 described the suspects as “Hindu” or Indian.
The female suspect lured V3 to the passenger side of the SUV to

ask for directions and bless her/him. The female suspect grabbed

11
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.62 Page 12 of 34

V3’s wallet from his/her rear pant pocket. As the female suspect

prayed, she removed $1,800.00 cash from V3’s wallet and placed it

in a sock. At the conclusion of the prayer, the female suspect

gave V3 a sock and a gold colored chain. After the suspects

departed, V3 realized the $1,800.00 was gone. V3 believed the

female suspect performed an illusion or trick with the sock and

gold colored chain. Approximately one month following the

incident, V3 negatively identified subjects in a photo line-up. As

a result, the incident was not referred to the Orange County

District Attorney’s Office for prosecution.

20. On or about June 19, 2020, Eduard and Floarea Ghiocel

were stopped by officers of the Fountain Valley Police Department

for driving a stolen rental vehicle. Eduard and Floarea were

arrested for Felony Driving a Vehicle without Consent, California

Vehicle Code (VC) 10851(a). The charges were ultimately dismissed

for the furtherance of justice. During the investigation, officers

recovered sale slips for Eduard, Floarea and Gabriel from two

different jewelry stores located in Los Angeles, California. Law

enforcement conducted an interview of cooperating witnesses (CW1
& CW2) from the jewelry stores. CW1 recognized and described Eduard

as “bald with a beard”, who appeared to be a “Gypsy” and attempted

to sell stolen jewelry on numerous occasions. CW2 recognized Eduard

and refused to buy items from Eduard because he was a “Gypsy” who

stole jewelry.

21. On October 21, 2020, two suspects in a white sedan

approached victim 4 (V4) as he/she was parked in Fountain Valley,
California. The female suspect exited the vehicle, approached V4

and placed rings and gold colored chains around V4’s neck. After

12
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.63 Page 13 of 34

placing chains around V4’s neck, the female suspect rushed back to

the car. V4 checked his/her neck and discovered his/her 18 karat

gold chain was missing. The following day, V4 identified Floarea

in a line-up as the female suspect that stole his/her gold chain.

The estimated value of the gold chain was $1,900.00. As of May 11,

2021, the investigation was suspended due to the lack of an

independent witness and video footage of the incident. Therefore,

the incident was not referred to the Orange County District

Attorney’s Office.

22. On October 23, 2020, Eduard Ghiocel submitted a

fraudulent application to California Employment Development

Department (EDD) to receive California unemployment insurance (UI)

benefits. As a result of this fraudulent application, Eduard

ultimately received $2,400.00 in UI benefits between November 2,

2020 and June 1, 2021. California UI applicants receive UI benefits

via Bank of America debit accounts which receive interstate wire

transfers of federally funded money from Washington, D.C. to a

Bank of America location in Sacramento, California. On the

fraudulent application, Eduard claimed to have worked as a self-
employed individual for 23 months performing “Take out trash clean

garden cleaner” with an annual salary of $47,000.00. Eduard

fraudulently claimed to be a United States citizen and reported

his social security number as 205-38-7932. According to the United

States Social Security Administration, social security number 205-

38-7932 is not assigned to Eduard Ghiocel. Additionally, in

September 2021 Eduard submitted another EDD application for UI
benefits using a different social security number of 209-38-7932.

13
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.64 Page 14 of 34

Similarly, social security number 209-38-7932 is not assigned to

Eduard Ghiocel.

23. In support of Eduard’s October 2020 EDD application,

Eduard submitted a photo of his valid Washington Driver License

and two earnings statements for Ghiocel Cleaning. The earnings

statements listed a business address of 2412 Associated Rd.,

Fullerton, CA 92385, with assigned employee ID of 7932. The later

of the two earnings statements purported Eduard’s YTD (Year to

Date) Gross pay was $58,800.00 as of October 18, 2019.

Additionally, the earnings statement dated October 18, 2019

purported a total deduction amount of $19,525.80 to include

withholdings for Federal tax, California state tax, and California

SDI tax. As part of his ID.me verification, Eduard submitted photos

of his Washington Driver License, his Romanian passport, another

earnings statement for Ghiocel Cleaning, and an Anthem Blue Cross

insurance card. According to Anthem Blue Cross, the member

identification number listed on Eduard’s insurance card does not

exist. The Ghiocel Cleaning earnings statement submitted to ID.me

was dated February 7, 2020, listed a business address of 2608 2nd
Ave. apt 303, Seattle, WA 98121 and listed assigned employee ID of

123. Additionally, the earnings statement submitted to ID.me was

from a different stock and format than the previously submitted

earnings statements to EDD for the same October 2020 application.

24. On October 26, 2020, Floarea Ghiocel submitted a

fraudulent application to California EDD to receive California UI

benefits. Ultimately, Floarea’s application yielded no UI
benefits. However, on the application, Floarea claimed to have

worked as a self-employed individual for 23 months performing “Take

14
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.65 Page 15 of 34

out trash clean garden clean house” with an annual salary of

$47,000.00. Floarea fraudulently claimed to be a United States

citizen and reported her social security number as 205-38-7931.

According to the United States Social Security Administration,

social security number 205-38-7931 is not assigned to Floarea

Ghiocel. As part of her ID.me verification, Floarea submitted an

earnings statement for Ghiocel Cleaning dated February 7, 2020,

with the business address of 2900 W Lincoln Ave Apt E115, Anaheim,

CA 92801. Floarea and Eduard Ghiocel both submitted earnings

statements for Ghiocel Cleaning dated February 7, 2020 in the same

format but listed different business addresses.

25. On November 4, 2020, three suspects believed to be Marius

and Floarea Ghiocel, and Argentina Alexandru, occupied a Kia

Sorrento SUV with Texas license plate MLW0777. At approximately

12:38 PM, the female suspect, who is believed to be Floarea,

approached victim 5 (V5) in the parking lot of an Indian food

market located in Artesia, California. The female suspect exited

the Kia, hugged V5, placed a gold colored necklace on V5’s neck

and quickly returned to the Kia. Immediately thereafter, V5
realized his/her gold chain and pendant were stolen. The estimated

value of the gold chain and pendant was $7,000.00. On November 5,

2020, officers with the Ontario Police Department conducted a

felony traffic stop of the suspect vehicle bearing Texas license

plate MLW0777. Marius and Floarea Ghiocel, and Argentina Alexandru

were detained for grand theft from a person. Using photo lineups,

V5 identified Marius as the driver of the suspect vehicle and
Floarea as the female suspect responsible for stealing V5’s gold

chain and pendant. According to Hertz Vehicles LLC, the suspect

15
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.66 Page 16 of 34

vehicle was rented to Marius Ghiocel at the time of the crime.

Marius and Argentina were released following detention. Floarea

was arrested and charged with Felony Grand Theft from a Person, PC

487(c). However, in October of 2021 the charge was ultimately

dismissed in furtherance of justice.

26. On February 28, 2021, Gabriel and Larisa Ghiocel were

detained by Milpitas Police Department following a high risk

traffic enforcement stop. Gabriel and Larisa were occupants of a

black Dodge Durango bearing California license plate 8PKD183, that

was wanted by Monterey Park Police Department for its connection

to a robbery. Milpitas Police Department conducted a search of the

vehicle and observed numerous bracelets, rings, necklaces and

assorted jewelry in a red handbag. Gabriel and Larisa were released

at the scene at the request of Monterey Park Police Department.

According to Monterey Park Police Department, the robbery victim

was not desirous of prosecution and could not identify the suspects

that stole his/her $3,000.00 necklace. As a result, investigators

do not believe this incident was referred for prosecution.

27. On April 20, 2021, two suspects, believed to be Eduard
and Floarea, approached an elderly victim (V6) in a residential

neighborhood in La Palma, California and offered him/her gold

colored jewelry. The female suspect used force in an attempt to

take V6’s Rolex watch, resulting in minor injuries to V6. The

female suspect was unsuccessful in stealing V6’s watch, however,

Floarea’s DNA profile was extracted from a swab of the watch after

the encounter. Additionally, GPS location data for Eduard’s
cellular telephone, 206-694-9092, revealed his telephone was near

La Palma approximately 45 minutes prior to the incident. As of May

16
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.67 Page 17 of 34

2021, La Palma Police Department did not have any further

investigative leads. Investigators do not believe this incident

was referred for prosecution.

28. On May 10, 2021, an unknown female suspect approached

victim 7 (V7) in Anaheim, California with her hand on a knife in

her waistband. V7 feared that he/she would be stabbed. The female

suspect subsequently stole V7’s necklace and left V7 with fake

jewelry. Although Floarea was not identified as the female suspect,

Floarea’s DNA profile was recovered from the fake jewelry left at

the crime scene. The estimated value of the stolen necklace was

$600.00. Two other Ghiocel clan members were identified by V7,

however all charges associated to this event were dismissed due to

a lack of evidence.

29. On July 14, 2021, a female suspect exited a black vehicle

and approached victim 8 (V8) in a residential area of Garden Grove,

California. A male driver remained in the running vehicle. The

female suspect was described as wearing a long “Muslim” dress that

covered the female’s hair, but not her face. The female suspect

prayed over V8, hugged him/her, and attempted to give him/her a
gold colored necklace and ring before quickly departing in the

suspect vehicle. A short time later, V8 realized the gold ring and

gold chain necklace he/she was originally wearing was stolen by

the female suspect. On October 29, 2021, V8 identified Marius

Ghiocel from a photo line-up as the driver of the suspect vehicle.

V8 was unable to identify the female suspect from a photo line-up

and told law enforcement it was difficult because the female was
covered up. The estimated value of the stolen jewelry was $900.00.

After a follow-up investigation, on December 15, 2021, Marius was

17
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.68 Page 18 of 34

arrested by Garden Grove Police Department for Felony Grand Theft

from a Person, PC 487(c). In April of 2022, the Orange County

District Attorney’s Office dismissed the case due to a lack of

sufficient evidence. The female suspect was not identified by V8

and thus not charged for the incident.

30. On July 18, 2021, Gabriel Ghiocel submitted a fraudulent

application to California EDD to receive California UI benefits.

Gabriel ultimately received $28,350.00 in UI benefits between

August 3, 2021 and September 12, 2021 as a result of this

fraudulent application. On the fraudulent application, Gabriel

claimed he was employed by L B Construction Co. for one month and

reported an annual income of $47,251.00. However, the California

Franchise Tax Board has no record of L B Construction Co. existing

in the state of California. Gabriel fraudulently claimed to be a

United States citizen and reported his social security number as

205-38-7930. According to the United States Social Security

Administration, social security number 205-38-7930 is not assigned

to Gabriel Ghiocel. In support of his application, Gabriel

conducted a video verification session with ID.me where he
confirmed he was attempting to get “verified for California

unemployment”, stated his name, date of birth, and presented a

valid Washington Driver License. Additionally, Gabriel submitted

a photo of an Anthem Blue Cross insurance card for identification

purposes. According to Anthem Blue Cross, the member

identification number listed on Gabriel’s insurance card does not

exist.
31. On July 21, 2021, three suspects in a sedan approached

victim 9 (V9) in a residential neighborhood of Garden Grove,

18
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.69 Page 19 of 34

California. As V9 was entering his/her vehicle, a female exited

the suspect vehicle and approached V9. All three suspects were

described as Middle Eastern and approximately 45 years old. The

female suspect asked for directions and offered a gold colored

necklace to V9. V9 was wearing a silver and black Rolex watch on

his/her left wrist and the female suspect wrapped the gold colored

necklace around V9’s wrist, which made him/her uncomfortable. V9

was aware that the female was attempting to steal his/her Rolex

watch. To prevent the female suspect from stealing his/her watch,

V9 tossed the watch onto the front seat of his/her vehicle. The

female suspect lunged into V9’s vehicle to grab the watch. As V9

attempted to pull the female suspect out of his/her vehicle, the

driver of the suspect vehicle yelled at V9. Additionally, V9

reported a second male suspect present outside of the suspect

vehicle. The female suspect grabbed the watch, ran back to the

suspect vehicle and departed the scene with the two male suspects.

A DNA profile was obtained from the gold colored necklace left at

the scene, which resulted in a match to Floarea. The estimated

value of the stolen watch was $9,000.00. As a result of a follow-
up investigation, Floarea Ghiocel was charged on January 10, 2023

with Felony 2nd Degree Robbery, PC 211 and 212.5(c) in the Superior

Court of California, County of Orange.

32. On August 4, 2021, two suspects, believed to be Eduard

and Floarea Ghiocel, approached victim 10 (V10) in a Costco parking

lot located in Vista, California. The two suspects worked together

using sleight-of-hand and distraction techniques to steal V10’s
necklace. V10 identified Eduard as the male suspect in a photo

line-up. The suspect vehicle was rented to Eduard at the time of

19
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.70 Page 20 of 34

the crime. GPS location data for Eduard’s cellular telephone, 206-

694-9092, revealed his telephone was at or near the scene of the

crime. The estimated value of the stolen necklace was $2,100.00.

As a result of a follow-up investigation, on January 4, 2023,

Eduard and Floarea Ghiocel were arrested and charged with Felony

First Degree Robbery, PC 211, Felony Grand Theft, PC 487(a),

Conspiracy PC 182, Theft Elder Adult PC 368(d) and Obtain Money on

False Pretenses PC 532(a) in the Superior Court of California,

County of San Diego.

33. On August 4, 2021, two suspects, believed to be Marius

and Argentina, approached victim 11 (V11) in a residential

neighborhood in National City, California. While driving a grey

SUV, the two suspects contacted V11. The female suspect exited the

vehicle, showed V11 gold colored jewelry and placed gold colored

necklaces on V11’s neck. At some point during the interaction, the

female suspect removed V11’s gold chain and returned to the

vehicle. Following the interaction, V11 discovered his/her real

gold necklace was missing. The estimated value of the stolen

necklace was $3,000.00.
34. As a result of a follow-up investigation, Marius plead

guilty on May 16, 2022 in SCD294523 to Felony Conspiracy, PC

182(a)(1) and Grand Theft Person, PC 487(c) in the Superior Court

of California, County of San Diego and sentenced to 25 days jail

and two years of probation. Marius agreed to the factual basis “On

August 4, 2021, I did steal real property from the person of

another in an amount over $950.” Additionally, Marius was ordered
to pay $3,000.00 in restitution to V11. Argentina Alexandru was

also charged for this incident in SCD294732 with Felony Conspiracy,

20
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.71 Page 21 of 34

PC 182(a)(1) and Grand Theft Person, PC 487(c) in the Superior

Court of California, County of San Diego. However, for the purposes

of a plea agreement, Argentina plead guilty to the May 2020

robbery.

35. On or about August 6, 2021, two suspects, believed to be

Eduard and Floarea, approached elderly victim (V12) at a Home Depot

in Lake Forest, California. The female suspect placed gold colored

jewelry around V12’s wrist and neck. The female suspect removed

V12’s Rolex watch and departed the scene. The suspect vehicle was

rented by Eduard at the time of the incident. The estimated value

of the stolen watch was $29,000.00. As a result of a follow-up

investigation, Eduard and Floarea Ghiocel were charged on January

10, 2023 with Felony 2nd Degree Robbery, PC 211 and 212.5(c) Felony

Theft from an Elder, PC 368(d)(1) and Felony Grand Theft Person,

PC 487(c) in 23F01251 by the Superior Court of California, County

of Orange.

36. On September 21, 2021, Larisa Ghiocel submitted a

fraudulent application to California EDD to receive UI benefits.

Larisa ultimately received $1,500.00 in UI benefits on October 10,
2021 as a result of this fraudulent application. On the application

Larisa claimed to have worked as a self-employed mechanic for one

month with an annual income of $99,886.00. Larisa fraudulently

claimed to be a United States citizen and reported her social

security number as 205-38-7929. According to the United States

Social Security Administration, social security number 205-38-7929

is not assigned to Larisa Ghiocel. In support of her application,
Larisa Ghiocel submitted photos of an earnings statement for

Larisa’s Auto Shop, an Anthem Blue Cross insurance card, and a

21
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.72 Page 22 of 34

fraudulent Washington Driver License. Based on the earnings

statement, Larisa’s YTD Gross income was $88,324.15 and reflected

withholding amounts for Federal, California, and California SDI

taxes. According to Anthem Blue Cross, the member identification

number listed on Larisa’s insurance card does not exist.

37. On October 9, 2021, victim 13 (V13) was approached by

two suspects driving a vehicle in the parking lot of the Nam Giao

restaurant in Garden Grove, California. The suspects used hand

motions to get V13 to walk closer to the vehicle. After approaching

the vehicle, a female suspect in the rear passenger seat hugged

and kissed V13. Simultaneously, the female suspect removed V13’s

necklace and replaced it with another necklace. The suspect vehicle

subsequently departed the scene. Approximately five minutes after

the encounter, V13 realized his/her necklace was stolen. On

November 3, 2021, V13 confidently identified Argentina Alexandru

as the female suspect who stole his/her gold and jade Buddha

necklace. The estimated value of the necklace was $2,000.00.

Argentina was charged by the Superior Court of California, County

of Orange, however, Argentina failed to show up for court on
January 23, 2023. Thus, a bench warrant was issued for Argentina’s

arrest.

38. On October 18, 2021, victim 14 (V14) was approached by

a male and female suspect in a light colored mini-van outside of

the Hoa Binh Garden Grove Supermarket in Garden Grove, California.

The female suspect attempted to lure V14 to the suspect vehicle,

but was unsuccessful. The suspects drove to a different location
within the parking lot. Shortly after, the female suspect,

described by V14 as Filipina, approached V14 on foot. The male

22
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.73 Page 23 of 34

suspect was the driver of the vehicle. Without warning, the female

suspect spoke to V14 and touched his/her neck. The female suspect

gave V14 a $100.00 bill, which V14 spent prior to contacting Garden

Grove Police Department. As the suspects fled the scene, V14

realized his/her 18 karat gold necklace with a jade medallion was

missing. On November 3, 2021, V14 identified Floarea in a photo

line-up as the suspect who took his/her necklace. The estimated

value of the necklace was $10,000.00. Ultimately, this case was

rejected by the Orange County District Attorney’s Office for a

lack of sufficient evidence.

39. On January 19, 2022 at approximately 12:45 PM Pacific

Time, victim 15 (V15) was approached by two suspects in a

residential neighborhood of Milpitas, California. The suspects

were driving a silver Ford SUV bearing license plate 8URB024. The

female suspect exited the vehicle and approached V15. The female

suspect attempted to place jewelry around V15’s neck and wrist.

V15 believed the suspect attempted to steal his/her gold bracelet.

The female gave V15 jewelry and returned to the SUV driven by a

light skinned male. The suspect vehicle departed the scene and V15
realized his/her 24 karat gold necklace was stolen. Based on Avis

Budget rental car records, Gabriel Ghiocel was the renter of the

silver Ford SUV at the time of the incident. Additionally,

according to Google location data, Gabriel’s telephone was present

at the scene of the crime on January 19, 2022 at 12:45 PM Pacific

Time. The estimated value of the gold necklace was $1,500.00.

Investigators do not believe charges were filed for this incident.
40. On January 30, 2022 at approximately 8:45 AM Pacific

Time, a silver SUV with two suspects approached victim 16 (V16) in

23
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.74 Page 24 of 34

a residential neighborhood of Fremont, California. The female

suspect told V16 “God would be good” to him/her if he/she put on

the suspect’s necklace. V16 bent at the waist to receive the

blessing. The female suspect removed V16’s gold necklace. The

female suspect subsequently removed V16’s two rings and abruptly

returned to the suspect vehicle. V16 identified Larisa Ghiocel

from a photo line-up, with 80-90% certainty, as the suspect who

stole his/her jewelry. The estimated value of the stolen jewelry

was $4,900.00. On December 9, 2022, a felony arrest warrant for

robbery was issued for Larisa Ghiocel.

41. On January 30, 2022 at approximately 10:09 AM Pacific

Time, victim 17 (V17) and cooperating witness 3 (CW3) were

approached by two suspects driving a silver ford SUV bearing

California license plate 8URB024 in a residential neighborhood of

Fremont, California. The suspect vehicle approached V17 to ask for

directions and offer V17 jewelry. The female suspect exited the

vehicle, grabbed V17 and forcibly removed his/her 22 karat gold

necklace. The female suspect returned to the suspect vehicle, which

fled at a high rate of speed. V17 identified Larisa in a photo
line-up as the suspect who forcibly stole his/her necklace. CW3

identified Gabriel in a photo line-up as the suspect driver of the

silver SUV. The silver SUV was rented by Gabriel at the time of

the incident and used in the January 19, 2022 robbery previously

discussed. Additionally, according to Google location data,

Gabriel’s telephone was present at the scene of the crime on

January 30, 2022. The estimated value of the stolen necklace was
$3,000.00. On December 9, 2022, a felony arrest warrant for robbery

was issued for Gabriel Ghiocel.

24
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.75 Page 25 of 34

E. Laundering of Illicit Proceeds

42. The money gained through illicit means is laundered

using various techniques developed by the criminal organization

with the goal of repatriation of the funds to Romania.

43. Investigators believe the Valcea Crime Ring members pawn

stolen jewelry to convert their illicit proceeds to cash. In June

2020, law enforcement officers recovered sale slips for Eduard,

Floarea, and Gabriel from two different jewelry stores located in

Los Angeles, California. Law enforcement subsequently conducted an

interview of a jewelry store employee who told law enforcement

that Eduard attempted to sell stolen jewelry on numerous occasions.

In February of 2022, law enforcement officers recovered jewelry

receipts from C.C.L. Heng jewelry store and Heang Sang Heng Jewelry

in Gabriel’s possession. In August 2022, law enforcement officers

conducted an interview of B.V.4, a cooperating witness with

knowledge of the Valcea Crime Ring. B.V. told law enforcement

officers Max from C.C.L. Heng is well known, will buy jewelry and

pay cash.

44. Once stolen goods are converted to cash, Valcea Crime
Ring members purchase luxury vehicles, jewelry, and gold bars with

the intent to store the goods in the United States or smuggle the

goods to Romania. Occasionally, Valcea Crime Ring members send

international wire transfers to Romania via Money Services

Businesses (MSBs).

4 B.V. was contacted by law enforcement in August of 2022, waived his/her
Miranda rights and provided a voluntary statement. B.V. was not promised
anything in return for his/her cooperation. In June of 2022, B.V. was
arrested for misdemeanor theft and B.V. failed to appear for court. As such,
the court issued a failure to appear in August of 2022 for B.V. Between 2012
and 2022, B.V. was arrested on four occasions for alien inadmissibility
charges. In 2017 B.V. was arrested for felony larceny, but the charge was
dismissed.

25
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.76 Page 26 of 34

45. Based on reports from the Financial Crimes Enforcement

Network (FinCEN) database and a follow-up interview of Irvine Gold

Mine in Irvine, California, the following cash purchases were made:

a. On August 19, 2021, Eduard Ghiocel purchased a gold bar

for $59,000.00 from Irvine Gold Mine using U.S.

currency. Eduard reported his occupation as a car

dealer.

b. On August 20, 2021, Gabriel Ghiocel purchased a gold bar

for $58,900.00 from Irvine Gold Mine using U.S.

currency. Gabriel reported his occupation was in auto

sales.

c. On August 21, 2021, Gabriel Ghiocel purchased a gold bar

for $58,900.00 from Irvine Gold Mine using U.S.

currency. Gabriel reported his occupation was in auto

sales. On February 2, 2022, law enforcement officers

with the Orange County Auto Theft Task Force recovered

a receipt for this transaction in Gabriel’s possession.

d. On August 23, 2021, Gabriel Ghiocel purchased a gold bar

for $59,700.00 from Irvine Gold Mine using U.S.
currency. Gabriel reported his occupation was in auto

sales. On February 2, 2022, law enforcement officers

with the Orange County Auto Theft Task Force recovered

a receipt for this transaction in Gabriel’s possession.

e. On August 25, 2021, Gabriel Ghiocel purchased a gold bar

for $63,200.00 from Irvine Gold Mine using U.S.

currency. Gabriel reported his occupation was in auto
sales.

26
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.77 Page 27 of 34

f. On August 25, 2021, Gabriel Ghiocel purchased a gold bar

for $55,200.00 from Irvine Gold Mine using U.S.

currency. Gabriel reported his occupation was in auto

sales.

g. On August 26, 2021, Gabriel Ghiocel purchased a gold bar

for $58,785.00 from Irvine Gold Mine using U.S.

currency. Gabriel reported his occupation was in auto

sales.

h. On August 27, 2021, Gabriel Ghiocel purchased a gold bar

for $60,056.00 from Irvine Gold Mine using U.S.

currency. Gabriel reported his occupation was in auto

sales.

i. On August 30, 2021, Gabriel Ghiocel purchased a gold bar

for $59,863.00 from Irvine Gold Mine using U.S.

currency. Gabriel reported his occupation was in auto

sales.

j. On August 31, 2021, Gabriel Ghiocel purchased a gold bar

for $60,000.00 from Irvine Gold Mine using U.S.

currency. Gabriel reported his occupation was in auto
sales.

k. On September 2, 2021, Gabriel Ghiocel purchased a gold

bar for $59,734.00 from Irvine Gold Mine using U.S.

currency. However, a report for this purchase was not

available in the FinCEN database.

l. On September 3, 2021, Gabriel Ghiocel purchased a gold

bar for $59,734.00 from Irvine Gold Mine using U.S.
currency. However, a report for this purchase was not

available in the FinCEN database.

27
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.78 Page 28 of 34

m. On December 14, 2021, Marius Ghiocel purchased gold bars

and coins for a total of $20,020.00 from Irvine Gold

Mine using U.S. currency. Marius reported his occupation

was in auto sales.

46. The auto sales occupations reported by Eduard and

Gabriel Ghiocel are inconsistent with their California EDD

applications filed between October 23, 2020 and September 21, 2021.

On Eduard’s October 23, 2020 EDD application, he reported the

nature of his self-employment to be “take out trash clean garden

cleaner”. On Gabriel’s July 18, 2021 EDD application, he reported

being a bricklayer employed by “L B construction co”. Additionally,

on Eduard’s second EDD application dated September 21, 2021, he

reported the nature of his self-employment to be “I do dry walk

service”.

47. Cooperating witness L.P. told law enforcement the

Ghiocels use cash they earn from fake jewelry to buy vehicles.

L.P. estimated that approximately 70% of the vehicles purchased

are for the purpose of money laundering and then sent to Romania

through ports in New York, Baltimore or Cancun. Eduard goes to the
port approximately one or two times a month while in Romania.

48. On October 14, 2021, Eduard Ghiocel posted a live stream

video, speaking Romanian as he was walking through the Newport

Lamborghini dealership. In the video, several people were present

and appeared to be together. At one point, Eduard entered an office

where a male, later identified as Ionut Alexandru, placed what

appeared to be $200,000.00 in cash on the desk. According to
records from Newport Beach Lamborghini, Ionut Alexandru purchased

a white 2019 Lamborghini Urus, VIN ZPBUA1ZL5KLA01530 on October

28
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.79 Page 29 of 34

14, 2021 for $260,575.00 in U.S. currency. According to records

received from Romania’s Directorate for Combating Organized Crime

(DCCO), the aforementioned Lamborghini Urus arrived to the Port of

Constanta in Romania in September 2022.

49. On January 29, 2022, Eduard conversed via Facebook with

Serafim Gunici regarding a 2020 or 2021 Ferrari Portofino. Eduard

told Gunici the vehicle would arrive from Germany, cost $230,000.00

and that Eduard had paid in full. According to information received

from the Romanian Directorate for Combating Organized Crime, the

Ferrari Portofino was registered in Romania on March 23, 2022. On

an unknown date between March and August 2022, Romanian law

enforcement officials reportedly witnessed Eduard driving the

Ferrari Portofino in Romania.

50. Between February 10, 2020 and March 23, 2021, Argentina

Alexandru and Eduard, Gabriel, Floarea, and Larisa Ghiocel sent

the following 17 wire transactions totaling US$24,035.02. The wire

transactions were sent from locations in California to a variety

of people in Ramnicu, Valcea, Romania. These transactions were

made from businesses such as Walgreens, CVS, Ria, Express Latin,
and Tana Market. Standard practice in Money Service Businesses

(MSBs) requires senders to provide identification verifying their

identity when sending money.

a. On February 10, 2020, Eduard Ghiocel sent $500.00 via

Western Union to Ramnicu, Valcea, Romania. The payee

received the money in Romania on February 11, 2020.

b. On February 18, 2020, Eduard Ghiocel sent $500.00 via
Western Union to Ramnicu, Valcea, Romania. The payee

received the money in Romania on February 19, 2020.

29
Case 3:23-mj-00474-JLB Document 1 Filed 02/10/23 PageID.80 Page 30 of 34

c. On February 28, 2020, Eduard Ghiocel sent $700.00 via

Continental Exchange Solutions to Ramnicu, Valcea,

Romania. The payee received the money in in Romania on

February 29, 2020.

d. On March 18, 2020, Gabriel Ghiocel sent $780.01 via

Continental Exchange Solutions to Ramnicu, Valcea,

Romania. The payee received the money in Romania on March

19, 2020.

e. On April 1, 2020, Eduard Ghiocel sent $700.00 via

Continental Exchange Solutions to Ramnicu, Valcea,

Romania. It is unknown when the payee received the money

in Romania.

f. On June 10, 2020, Floarea Ghiocel sent $2,000.00 via