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Affidavit — U.S. v. Lonnie Smith-Matthews (D. Mass.)

Summary

An affidavit by an IRS Criminal Investigation special agent in support of a criminal complaint and arrest warrant against Lonnie Smith-Matthews, Case 1:25-mj-07245-JCB (D. Mass.), filed June 4, 2025 as Document 1-3. It supports one count of theft of government funds under 18 U.S.C. § 641 and one count of bank fraud under 18 U.S.C. § 1344(1). The affiant states that on or about June 25, 2024 a U.S. Treasury check for $150,000.00, which IRS records show was issued to a married couple in North Carolina, was deposited into a credit union account for Members Only The Family Clothing. It states that on or about August 26, 2024 a law firm check for $232,588.55 was deposited into the same account and that the firm reported a different true payee. The affidavit was sworn before a United States Magistrate Judge on June 4, 2025.

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Cite this document

“Affidavit — U.S. v. Lonnie Smith-Matthews (D. Mass.).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-25-mj-07245-dkt-1-d-mass-51f462617d/, SHA-256 aad83f32756951e7fb300b6386860064cff7e7b60ee396d23ee041f53125dc0c.

Full text

       Case 1:25-mj-07245-JCB           Document 1-3        Filed 06/04/25      Page 1 of 6




                                           AFFIDAVIT

       I, Robert Quan, state:

                       INTRODUCTION AND AGENT BACKGROUND

       1.      I have been a Special Agent with the Internal Revenue Service, Criminal

Investigation (“IRS-CI”) since 2019. I am assigned to the IRS-CI Boston, Massachusetts Field

Office, where I investigate various forms of financial crime, including tax violations, theft of

government funds, and investment frauds.

       2.      I submit this affidavit in support of an application for a criminal complaint charging

LONNIE SMITH-MATTHEWS (“SMITH-MATTHEWS”) with one count of theft of government

funds, in violation of 18 U.S.C. § 641, and one count of bank fraud, in violation of 18 U.S.C. §

1344(1), and for a warrant for SMITH-MATTHEWS’ arrest.

       3.      The facts in this affidavit come from my personal knowledge, information that other

law enforcement agents provided, information I obtained through witness interviews, and my

review of records described below. This affidavit is not intended to set forth all of the information

that I have learned during this investigation and includes only the information necessary to

establish probable cause for the requested complaint and arrest warrant.

   PROBABLE CAUSE TO BELIEVE THAT A FEDERAL CRIME WAS COMMITTED

       Background

       4.      The “Credit Union” is a financial institution in Massachusetts.

       5.      According to Massachusetts Registry of Motor Vehicle (“RMV”) records, SMITH-

MATTHEWS lives at                        in Hyde Park, Massachusetts 02136. Below is his photo

from RMV records:




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       6.      On or about May 7, 2021, SMITH-MATTHEWS opened a checking account at the

Credit Union in the name of MEMBERS ONLY THE FAMILY CLOTHING INC. with an account

number ending in 1664 (the “1664 Account”). On the account application that he signed, SMITH-

MATTHEWS listed himself as the owner of the business.

       7.      On or about the same day, SMITH-MATTHEWS registered MEMBERS ONLY

THE FAMILY CLOTHING LLC as a Massachusetts limited liability corporation (“MEMBERS

ONLY”). Corporate filings for MEMBERS ONLY list SMITH-MATTHEWS as the company’s

only officer and agent.

       8.      Documents from the Massachusetts Secretary of State show that the

Commonwealth administratively dissolved MEMBERS ONLY on December 29, 2023.

       9.      In about 2022, the IRS received a Form SS-4 requesting an Employer Identification

Number (“EIN”) for MEMBERS ONLY. The form referenced the Social Security number

  -2260, which belongs to SMITH-MATTHEWS. The IRS assigned MEMBERS ONLY the EIN

       8515.

       Theft of Government Funds

       10.     On or about June 25, 2024, SMITH-MATHEWS entered the Credit Union branch



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      Case 1:25-mj-07245-JCB         Document 1-3      Filed 06/04/25    Page 4 of 6




       Bank Fraud

       15.      On or about August 26, 2024, SMITH-MATTHEWS entered the Credit Union

branch in Roslindale and deposited a check numbered 686652, from a New York law firm payable

to MEMBERS ONLY THE FAMILY CLOTHING LLC in the amount of $232,588.55, into the

1664 Account.

       16.      Bank surveillance captured images of SMITH-MATTHEWS in the branch at or

around the time of the deposit. Images from this surveillance appear below. I have included a

close-up of SMITH-MATTHEWS’ head and shoulders.




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