Criminal Complaint and Affidavit — U.S. v. Atta (C.D. Cal.)

Summary

A criminal complaint with supporting affidavit in United States v. Muhammad Noor Ul Ain Atta, Case No. 2:20-mj-06152-DUTY, in the U.S. District Court for the Central District of California, filed December 18, 2020 as Document 1. It charges wire fraud (18 U.S.C. § 1343), aggravated identity theft (18 U.S.C. § 1028A(a)(1)) and conspiracy to commit money laundering (18 U.S.C. § 1956(h)). The affidavit, by Cecilia Braga of the Federal Reserve Board and CFPB Office of Inspector General, states that from about April 2020 to at least July 2020 at least seven fraudulent PPP applications and at least four fraudulent EIDL applications were submitted. Its table of funded loans lists a total of $6,643,540 from Lender A and the SBA. The affidavit states that approximately $6 million was later wired to Pakistan. The filing runs 48 pages.

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Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page1lof48 Page ID #:1

AO 91 (Rev. 11/11) Criminal Complaint (Rev. by USAO on 3/12/20) LC) Original OO Duplicate Original

LODGED UNITED STATES DISTRICT COURT cure, 1 ee count

CLERK, U.S. DISTRICT COURT

12/18/2020 for the 12/18/20

CENTRAL DISTRICT OF CALIFORNIA Central District of California CENTRAL DISTRICT OF CALIFORNIA

BY: JB DEPUTY
BY: J m DEPUTY

United States of America

Vv.
MUHAMMAD NOOR UL AIN ATTA, Case No, 2:20-mj-06152 -DUTY
aka “Muhammad Atta,”

Defendant.

CRIMINAL COMPLAINT BY TELEPHONE
OR OTHER RELIABLE ELECTRONIC MEANS

I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
Beginning in or around April 2020 and continuing until at least in or around July 2020, in the counties of Los

Angeles and Riverside in the Central District of California, the defendant violated:

Code Section Offense Description

Count 1: 18 U.S.C. § 1343 Wire Fraud

Count 2: 18 U.S.C. § 1028A(a)(1) Aggravated Identity Theft

Count 3: 18 U.S.C. § 1956(h) Conspiracy to Commit Money Laundering

This criminal complaint is based on these facts:
Please see attached affidavit.

Continued on the attached sheet.

Attested to by applicant in accordance with the requirements
of Fed. R. Crim. P. 4.1 by telephone
Complainant’s signature

Cecilia Braga, Special Agent
Printed name and title
Attested to by the applicant in accordance with the requirements of Fed. y Crim. P. 4.1 b telephone.

Date: December 18, 2020
Be. ’s “erat re

City and state: Los Angeles, California Hon. tara Kadero, USS. Ve Judge

Printed name and title
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 2of48 Page ID#:2

AFFIDAVIT
I, Cecilia Braga, being duly sworn, declare and state as

follows:

INTRODUCTION

1. I am a Senior Special Agent with the Office of
Inspector General of the Board of Governors of the Federal
Reserve System and Consumer Financial Protection Bureau (“FRB-
CFPB OIG”) and have been so employed since January 28, 2013.
Prior to being employed with the FRB-CFPB OIG, I was a Special
Agent with the Internal Revenue Service - Criminal Investigation
(“IRS-CI”) for 17 years. I am currently assigned to the FRB-
CFPB OIG’s San Francisco Field Office, which is responsible for
investigating complex financial crimes to combat waste, fraud,
and abuse relating to the programs and operations of the FRB and
CFPB in the western region. During my tenure with the FRB-CFPB
OIG and IRS-CI, I have received training in the investigation of
financial crimes and in financial analysis. As part of my
duties as a Special Agent, I have participated in investigations
relating to wire fraud, bank fraud, money laundering, and
various types of complex financial crimes. During my career, I
have been the affiant on applications for search warrants and

arrest warrants in federal criminal investigations.
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 3o0f 48 Page ID#:3

PURPOSE OF AFFIDAVIT

2. This affidavit is made in support of a criminal
complaint against, and arrest warrant for, MUHAMMAD NOOR UL AIN
ATTA (also known as “Muhammad Atta,” and hereinafter, “ATTA”)
for violation of 18 U.S.C. § 1343 (Wire Fraud), 18 U.S.C.

§ 1028A(a) (1) (Aggravated Identity Theft), and 18 U.S.C.
§ 1956(h) (Conspiracy to Commit Money Laundering).

3. The facts set forth in this affidavit are based upon
my personal observations, my training and experience, and
information obtained from various law enforcement personnel and
witnesses. This affidavit is intended to show merely that there
is sufficient probable cause for the requested complaint and
warrant and does not purport to set forth all of my knowledge of
or investigation into this matter. Unless specifically
indicated otherwise, all conversations and statements described
in this affidavit are related in substance and in part only.

SUMMARY OF PROBABLE CAUSE

4. Beginning in or around April 2020 and continuing until
at least in or around July 2020, ATTA, together with other
co-schemers including Co-Schemer 1 (“CS-1”), submitted and
caused to be submitted in the names of certain entities at least
seven fraudulent Paycheck Protection Program (“PPP”) loan
applications and at least four fraudulent Economic Injury

Disaster Loan Program (“EIDL”) applications. Among other
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 4of48 Page ID#:4

things,

these applications misrepresented the number of

employees and payroll data associated with the respective

companies and in most cases submitted fraudulent IRS Forms 941

as support,

and amount of the PPP and EIDL loans.

While all of the

which representations were material to the approval

applications connect either directly to ATTA or indirectly

through emails and IP addresses associated with him,

his co-schemers also submitted a number of these loan

ATTA and

applications using the personal identifying information of M.P.,

an individual with no known involvement in the scheme.

who was incarcerated at the time of the applications,

M.P.,

never

provided ATTA with permission to use M.P.’s name and identity.

As a result of these fraudulent loan applications,

ATTA and his

co-schemers received a total of approximately $6 million in PPP

proceeds from Lender A and approximately $600,000 in EIDL

proceeds from the Small Business Administration (“SBA”).
5. The applications were approved and the PPP and EIDL
loans were subsequently funded as described below:
. Approximate Loan | Approximate
Entity Name Date Funded Lender Type | Loan Amount
Fontana CK June 5, 2020 Lender A |} PPP $1,908,595
Liberty RV LLC May 12, 2020 Lender A| PPP $260,275
Liberty RV LLC July 2, 2020 SBA EIDL $150,000
American Auto Barn May 12, 2020 Lender A| PPP $401,175
American Auto Barn June 12, 2020 SBA EIDL $150,000
Envisioning Future Inc. May 12, 2020 Lender A | PPP $1,267,140
Envisioning Future Inc. June 12, 2020 SBA EIDL $150,000
Wermer Construction Inc. May 13, 2020 Lender A | PPP $326,335
Wermer Construction Inc. July 2, 2020 SBA EIDL $150,000
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 5of48 Page ID#:5

. Approximate Loan | Approximate

Entity Name os Funded Lender Type “ier Amount

CKSB LLC June 3, 2020 Lender A | PPP $1,020,230
Camel and Camel June 3, 2020 Lender A | PPP $859,790
Total: | $6,643,540

6. ATTA, together with CS-1 and other co-schemers, then
directed the fraudulently obtained loan proceeds to accounts
that they owned and/or controlled before ultimately wiring
approximately $6 million to Pakistan for “family support.” In
other words, ATTA, together with CS-1 and other co-schemers,
improperly used those funds for their own personal benefit
rather than for the business expenses for which the loan
applications certified they would be used.

STATEMENT OF PROBABLE CAUSE

7. Based on witness interviews I have conducted, my
review of documents obtained from third parties, reports of
interviews conducted by me and other law enforcement officers,
conversations with other law enforcement officers, and publicly
filed documents, I know the following:

The Small Business Administration

a. The United States SBA was an agency of the United
States government that provided support to entrepreneurs and
small businesses. The mission of the SBA was to maintain and

strengthen the nation’s economy by enabling the establishment
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 6of48 Page ID #:6

and viability of small businesses and by assisting in the
economic recovery of communities after disasters.

The Paycheck Protection Program

b. The Coronavirus Aid, Relief, and Economic
Security (“CARES”) Act was a federal law enacted in or around
March 2020 and designed to provide emergency financial
assistance to the millions of Americans who were suffering the
economic effects caused by the COVID-19 pandemic. One form of
assistance provided by the CARES Act was the authorization of
United States taxpayer funds in forgivable loans to small
businesses for job retention and certain other expenses, through
a program referred to as the Paycheck Protection Program or
“PPP.”

c. In order to obtain a PPP loan, a qualifying
business would be required to submit a PPP loan application
Signed by an authorized representative of the business. The PPP
loan application required the small business (through its
authorized representative) to acknowledge the program rules and
make certain affirmative certifications in order to be eligible
to obtain the PPP loan. One such certification required the
applicant to affirm that “[t]he [PPP loan] funds w[ould] be used
to retain workers and maintain payroll or make mortgage
payments, lease payments, and utility payments.” The

application (through its authorized representative) was also
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 7of48 Page ID#:7

required to acknowledge that “I understand that if the funds are
used for unauthorized purposes, the federal government may
pursue criminal fraud charges.” In the PPP loan application,
the applicant was required to state, among other things, its:

(a) average monthly payroll expenses; and (b) number of
employees. These figures were used to calculate the amount of
money the small business was eligible to receive under the PPP.
In addition, businesses applying for a PPP loan were required to
provide documentation showing their payroll expenses.

d. A business’s PPP loan application would be
received and processed, in the first instance, by a
participating financial institution. If a PPP loan application
was approved, the participating financial institution would fund
the PPP loan using its own monies.

e. PPP loan proceeds were required to be used by the
business on certain permissible expenses, namely, payroll costs,
interest on mortgages, rent, and utilities. The PPP allowed the
interest and principal on the PPP loan to be entirely forgiven
if the business spent the loan proceeds on these expense items
within a designated period of time and used at least a minimum
amount of the PPP loan proceeds on payroll expenses.

The Economic Injury Disaster Loan Program

f. The Economic Injury Disaster Loan Program

(“EIDL”) was a SBA program that provided low-interest financing
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 8 of 48 Page ID #:8

to small businesses, renters, and homeowners in regions affected
by declared disasters.

g. The CARES Act authorized the SBA to provide EIDL
loans of up to $2 million to eligible small businesses
experiencing substantial financial disruption due to the COVID-
19 pandemic.

h. To obtain an EIDL loan, a qualifying business was
required to submit an application to the SBA and provide
information about the business’s operations, such as the number
of employees, gross revenues for the 12-month period preceding
the disaster, and cost of goods sold in the 12-month period
preceding the disaster. In the case of EIDL loans for COVID-19
relief, the 12-month period was the 12-month period from
January 31, 2019, to January 31, 2020. The applicant was also
required to certify that all of the information in the
application was true and correct to the best of the applicant’s
knowledge.

i. EIDL loan applications were submitted directly to
the SBA and processed by the agency with support from a
government contractor. The amount of the loan, if the
application was approved, was determined based, in part, on the
information provided by the applicant about employment, revenue,

and cost of goods sold, as described in paragraph 7(c) above.
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 9of48 Page ID#:9

Any funds issued under an EIDL loan were issued directly by the
SBA.

5. EIDL loan funds could be used for payroll
expenses, Sick leave, production costs, and business
obligations, such as debts, rent, and mortgage payments. If the
applicant also obtained a loan under the PPP, the EIDL loan
funds could not be used for the same purpose as the PPP loan
funds.

Relevant Individuals and Entities

8. Based on my review of identity documents, information
obtained from an investigative database, and open source
research, I know the following:

a. ATTA is a naturalized United States citizen from
Pakistan and a resident of Eastvale, California, within the
Central District of California.

b. Co-Schemer 1 (“CS-1”"), a lawful permanent United
States resident and a resident of La Verne, California, within
the Central District of California, is ATTA’s mother.

Cc. Individual 1 is a resident of La Verne,
California, within the Central District of California, and is
ATTA’s father-in-law.

d. M.P., who is a real person, has been incarcerated
in Illinois since approximately 2008 for a felony offense, and

has no known relationship to ATTA.
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 10of48 Page ID #:10

e. Lender A is a non-bank lender that was an
approved SBA lender of PPP loans.

f. Financial Institutions 1, 2, 3, 4, and 5 are
financial institutions that are insured by the Federal Deposit
Insurance Corporation.

g. Financial Institution 6 is an Islamic bank
located in Pakistan and is a wholly-owned subsidiary of an
Islamic bank headguartered in Dubai, United Arab Emirates.

9. According to charter documents, statements of
information, and other records received from the California
Secretary of State, I know the following:

a. Fontana CK Inc. was incorporated in January 2015
by ATTA. ATTA is listed as the incorporator, CEO, CFO,
President, Secretary, sole director, and agent for service of
process for the entity.

b. Liberty RV, LLC was created in October 2008.
None of the entity’s charter documents or subsequent filings
reference ATTA.

c. American Auto Barn LLC was created in April 2018.
Its Statement of Information filed in May 2018 lists ATTA as its
sole manager/member.

d. Envisioning Future Inc. was incorporated in or

around April 2008 by ATTA. ATTA is listed as the incorporator,
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 11 of 48 Page ID #:11

CEO, CFO, President, Secretary, sole director, and agent for
service of process for the entity.

e. Wermer Construction Inc. was incorporated in
September 2014 by ATTA. ATTA is listed as the incorporator,
CEO, CFO, President, Secretary, sole director, and agent for
service of process for the entity.

f. CKSB, LLC was created in November 2016. None of
the entity’s charter documents or subsequent filings reference
ATTA.

g. Camel and Camel Inc. was incorporated in November
2010 and ATTA was listed as the initial agent for service of
process in the original articles of incorporation. In
subsequent filings, ATTA is also listed as the CEO, CFO,
President, Secretary, and sole director for the entity.

Relevant Accounts Controlled by ATTA & Others

10. According to records from Financial Institution 1,
ATTA controlled and was the sole signatory to the following
accounts at Financial Institution 1:
a. A business checking account in the name of
Fontana CK Inc. ending in 6052 (the “Fontana CK Account”) ;
b. A business checking account in the name of
Envisioning Future Inc. ending in 0859 (the “Envisioning Future

Account”);

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Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 12 of 48 Page ID #:12

c. A business checking account in the name of
American Auto Barn LLC ending in 2143 (the “American Auto Barn
Account”) ;

d. A business checking account in the name of Wermer
Construction Inc. ending in 0251 (the “Wermer Construction
Account”) ;

e. A business checking account in the name of CKSB
LLC ending in 1858 (the “CKSB Account”); and

f. A business checking account in the name of Camel
and Camel Inc. ending in 3333 (the “Camel and Camel Account”).

11. According to records from Financial Institution 1, CS-
1 controlled and was a signatory to the following accounts at
Financial Institution 1:

a. A personal checking account in the name of CS-1
ending in 3283 (“CS-1 Account #1”); and

b. A personal checking account in the name of CS-1
ending in 7764 (“CS-1 Account #2”).

12. According to records from Financial Institution 2, CS-
1 controlled and was a signatory to a personal checking account
in the name of CS-1 ending in 5659 (“CS-1 Account #3”).

13. According to records from Financial Institution 3, CS-
1 controlled and was a signatory to a personal checking account

in the name of CS-1 ending in 4092 (“CS-1 Account #4”).
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 13 of 48 Page ID #:13

14. According to records from Financial Institution 4, CS-
1 controlled and was a signatory to a personal checking account
in the name of CS-1 ending in 5306 (“CS-1 Account #5”).

15. According to records from Financial Institution 5, CS-
1 controlled and was a signatory to a personal checking account
in the name of CS-1 ending in 7346 (“CS-1 Account #6”).

16. According to records from Financial Institution 1,
Individual 1 controlled and was a signatory to a business
checking account in the name of Liberty RV LLC ending in 7526
(“Liberty RV Account”).

Fontana CK PPP Loan

17. Based on my review of loan documents provided by
Lender A, I learned the following:

a. On or about June 1, 2020, Lender A received a PPP
application in the name of Fontana CK Inc. (“Fontana CK”)
seeking a PPP loan in the amount of $1,908,595.

b. The application was electronically submitted
through IP address 64.44.55.84 in the name of M.P., who was
listed on the loan application as the President and 100% owner

of Fontana CK.!

| However, based on my review of documents from the California
Secretary of State, I know that ATTA is listed as Fontana CK’s
President.
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 14 of 48 Page ID #:14

c. The PPP borrower application represented that
Fontana CK had 174 employees, including employees for whom it
paid wages and payroll taxes, and that the purpose of the PPP
loan was to cover payroll, lease/mortgage interest, and
utilities.

d. The email associated with this PPP loan
application was fontanack2015@gmail.com.

18. According to records supplied by Google LLC
(“Google”), I know the following:

a. The email address fontanack2015@gmail.com is
connected to ATTA through the listed “Recovery SMS number” of
190974994262 and a “Recovery e-mail” of attamuh@gmail.com.

b. The subscriber information associated with
attamuh@gmail.com shows that this email is registered to
“Muhammad Noor Atta.” Further, the recovery email associated
with the attamuh@gmail.com is noorlawschool@gmail.com while the

recovery SMS number is 9097499426 (i.e., the same recovery SMS

number associated with the fontanack2015@gmail.com).

* Based on a reverse phone lookup search of the phone number,
(909) 749-9426, through Google, I determined that most recent
owner for this number was “Mohammed LNU” with an address of
Nex****Blazing Star Drive, Corona, CA 92880.” Based my search
of an investigative database, I know that ATTA owns and resides
at 14794 Blazing Star Drive, Eastvale, CA 92880.

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Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 15o0f48 Page ID #:15

Cc. The IP address 64.44.55.84, which was used for
submission of the Fontana CK PPP loan application, was also used
to access both fontanack2015@gmail.com and attamuh@gmail.com.

d. The IP address 104.34.50.159 was also used to
access both fontanack2015@gmail.com and attamuh@gmail.com.

19. Based on my review of loan documents provided by
Lender A, several documents were submitted in support of the
Fontana CK PPP loan application, including:

a. Internal Revenue Service (“IRS”) Employer’s
Quarterly Federal Tax Returns (IRS Form 941) for Fontana CK for
each quarter of 2019 and the first quarter of 2020;

b. Payroll data and documentation for Fontana CK,
including documents purporting to be payroll registers for 2019
and the first quarter of 2020, purporting to show wages paid to
its employees; and

c. An Illinois state driver’s license purportedly
issued to M.P. in February 2019, well after M.P. had been
incarcerated as discussed below in paragraph 21.

20. Based on information from the IRS, I know that the IRS
Forms 941 submitted with the Fontana CK PPP loan were not filed
with the IRS. In fact, IRS records show that Fontana CK had not
filed quarterly federal income tax returns with the IRS for 2019

and the first quarter of 2020. In addition, IRS records show

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Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 16 of 48 Page ID #:16

that Fontana CK’s Employer Identification Number (“EIN”) is
registered to ATTA.

21. Based on an interview with M.P. and records from the
Tllinois Department of Corrections (“IDOC”), I have learned the
following:

a. M.P. was incarcerated with IDOC when the Fontana
CK PPP loan application was submitted in his name.

b. IDOC records show that M.P. has been incarcerated
with IDOC since approximately 2012 after his/her conviction at
trial and that M.P. was held in pretrial detention in county
jail starting in 2008, while awaiting trial.

om During the interview, M.P. confirmed that while
the social security number from the Fontana CK PPP application
was his/hers, s/he did not submit the Fontana CK PPP
application, s/he had never heard of ATTA, CS-1, or Fontana CK
prior to the interview, and said the signature on the Fontana CK
PPP application was not his/hers. During his/her interview,
M.P. further stated that s/he never had an Illinois driver’s
license, s/he did not recognize the photo on the license, the
Signature on the license was not his/hers, and s/he did not
recognize the address listed on the license.

22. Based on a review of a copy of M.P.’s purported
driver’s license submitted in connection with the Fontana CK PPP

loan application, I know that it says it was issued on or about

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Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 17 of 48 Page ID #:17

February 6, 2019. Based on a review of IDOC records, I know
that M.P. was incarcerated in the custody of IDOC at that time.

23. Based on a review of the payroll data and
documentation for Fontana CK provided to Lender A, I know that
the number of employees listed in that data and documentation
did not match the number listed in the IRS Forms 941 that were
submitted to Lender A. Further, there were employees listed in
the payroll data multiple times making it appear that these
employees were paid multiple times within the same pay period.

24. Based on surveillance conducted during business hours
on or about July 22, 2020, by another agent assisting with this
investigation, at that time, Fontana CK appeared to be an active
business (specifically, a Circle K convenience store). Only two
employees were observed on the premises. Even assuming that the
store employed other individuals to cover additional shifts,
based on my training and experience, a business like this would
not be expected to employ anything close to 174 employees, as
the application represented.

25. Based on my review of loan documents provided by
Lender A, I know that it approved Fontana CK’s PPP application
and funded the loan. According to records provided by Lender A
and Financial Institution 1, on or about June 5, 2020, Lender A
transferred via interstate wire approximately $1,908,595 in

proceeds from the Fontana CK PPP loan to the Fontana CK Account,

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Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 18 of 48 Page ID #:18

for which ATTA was the sole signatory. At the time the PPP loan
proceeds were transferred, the Fontana CK Account had $100 on
deposit.

26. According to records provided by Financial
Institution 1, just three days later, on or about June 8, 2020,
a cashier’s check for approximately $1,908,000 -- comprised
mostly, if not entirely, of the Fontana CK PPP loan proceeds --
was purchased from funds drawn on the Fontana CK Account.
According to records provided by Financial Institution 4, on or
about June 8, 2020, the cashier’s check was deposited into CS-1
Account #4.

Liberty RV PPP Loan

27. Based on my review of loan documents provided by
Lender A, I learned the following:
a. On or about April 14, 2020, Lender A received a
PPP application in the name of Liberty RV seeking a PPP loan in
the amount of $260,291.
b. The application was electronically submitted in
the name of M.P., who was listed on tfhe loan application as the

Managing Member and 100% owner of Liberty RV.?

> Based on my review of records from the California Secretary of
State, I know that M.P. is not listed as the Managing Member or
owner of this entity. In fact, the records do not reference
M.P. in any way.
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 19 of 48 Page ID #:19

c. The PPP borrower application represented that
Liberty RV had 37 employees, including employees for whom it
paid wages and payroll taxes.

d. The email associated with this PPP loan
application was libertyrv2009@gmail.com.

28. According to records supplied by Google, I know the
following:

a. The email address libertyrv2009@gmail.com has a
“Recovery e-mail” of eficpa009@gmail.com, which is associated
with the loan application for CKSB, LLC discussed below in
paragraph 69.

b. The IP address 104.34.50.159, the same IP address
used to access ATTA’sS personal Gmail addresses as discussed
above in paragraph 18, was also used to access
libertyrv2009@gmail.com and eficpa009@gmail.com.

29. Based on my review of loan documents provided by
Lender A, several documents were submitted in support of the
Liberty RV PPP loan application, including:

a. IRS Employer’s Quarterly Federal Tax Returns (IRS
Form 941) for Liberty RV for each quarter of 2019 and the first
quarter of 2020;

b. Payroll data and documentation for Liberty RV,

including documents purporting to be payroll registers for 2019

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Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 20 of 48 Page ID #:20

and the first guarter of 2020, purporting to show wages paid to
its employees; and

c. A copy of the same fraudulent Illinois state
driver’s license purportedly issued to M.P. in 2019, described
above in paragraph 22.

30. Based on information from the IRS, I know that the IRS
Forms 941 submitted with the Liberty RV PPP loan were not filed
with the IRS. In fact, IRS records show that Liberty RV had not
filed quarterly federal income tax returns with the IRS for 2019
and the first quarter of 2020.

31. As described above in paragraph 21, M.P. was
incarcerated at the time the Liberty RV PPP loan application was
submitted in his/her name. In his/her interview, M.P. stated
that s/he did not submit the Liberty RV PPP application, s/he
had never heard of Liberty RV prior to the interview, and said
the signature on the Liberty RV PPP application was not
his/hers.

32. Based on a review of the payroll data and
documentation for Liberty RV provided to Lender A, I know that
the number of employees listed in that data and documentation
did not match the number listed in the IRS Forms 941 that were
submitted to Lender A. In addition, based on surveillance of

the address listed in the PPP application for Liberty RV, there

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was no indicia, signage, or other identifiable business markings
for the Liberty RV business at the location.

33. Based on my review of loan documents provided by
Lender A, I know that it approved Liberty RV’s PPP application
and funded the loan. According to records provided by Lender A
and Financial Institution 1, on or about May 12, 2020, Lender A
transferred via interstate wire approximately $260,275 in
proceeds from the Liberty RV PPP loan to the Liberty RV Account.
At the time the PPP loan proceeds were transferred, the Liberty
RV Account had approximately $100 on deposit.

34. According to records provided by Financial
Institution 1, the following day, on or about May 13, 2020,
approximately $260,000, which in substantial part was comprised
of the Liberty RV PPP loan proceeds, was wired from the Liberty
RV Account to the American Auto Barn Account, for which ATTA was
the sole signatory.

Liberty RV EIDL Loan

35. Based on my review of information provided by the SBA,
the SBA received an application in the name of Liberty RV
seeking an EIDL loan in the amount of $150,000. The application
was electronically submitted in the name of M.P. via the SBA’s
online portal.

36. The EIDL application for Liberty RV represented that

it had 37 employees. As described above in paragraphs 29 to 34,
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 22 of 48 Page ID #:22

evidence gathered in the government’s investigation revealed
that this statement is false and the use of M.P.’s name and
identity in connection with Liberty RV was fraudulent.

37. The SBA approved and funded the Liberty RV EIDL loan,
and on or about July 2, 2020, the SBA transferred via interstate
wire approximately $149,900 in proceeds from the Liberty RV EIDL
loan to the Liberty RV Account. At the time the EIDL loan
proceeds were transferred, the Liberty RV Account had
approximately $275 on deposit.

38. According to records provided by Financial
Institution 1, the following day, on or about July 3, 2020,
approximately $149,500, which in substantial part was comprised
of the Liberty RV EIDL loan proceeds, was wired from the Liberty
RV Account to the American Auto Barn Account, for which ATTA is
the sole signatory.

American Auto Barn PPP Loan

39. Based on my review of loan documents provided by
Lender A, I know the following:
a. On or about April 14, 2020, Lender A received a
PPP application in the name of American Auto Barn LLC (“American
Auto Barn”) seeking a PPP loan in the amount of $401,185.
b. The application was electronically submitted in
the name of ATTA, who described himself as the Manager and 100%

owner of American Auto Barn.

-?1-
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 23 of 48 Page ID #:23

c. The PPP borrower application represented that
American Auto Barn had 45 employees, including employees for
whom it paid wages and payroll taxes, and that the purpose of
the PPP loan was to cover payroll.

d. The email associated with this PPP loan
application was americanautobarn@gmail.com.

40. According to records supplied by Google, I know the
following:

a. The email address americanautobarn@gmail.com is
connected to ATTA through the listed “Recovery SMS number” of
19097499426 and “Recovery e-mail” of noorlawschool@gmail.com,
which are the same recovery SMS number and recovery email that
ATTA listed for his personal Gmail account: attamuh@gmail.com.

b. The IP address, 104.34.50.159, was used to access
americanautobarn@gmail.com and ATTA’s personal Gmail account
attamuh@gmail.com in addition to various other entity accounts
tied to false and fraudulent loan applications discussed herein,
including eficpa009@gmail.com, libertyrv2009@gmail.com,
fontanack2015@gmail.com, and wermerconstruction@gmail.com.

41. Based on my review of loan documents provided by
Lender A, several documents were submitted in support of the

American Auto Barn PPP loan application, including:
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 24 of 48 Page ID #:24

a. IRS Employer’s Quarterly Federal Tax Returns (IRS
Form 941) for American Auto Barn for each quarter of 2019 and
the first quarter of 2020; and

b. Payroll data and documentation for American Auto
Barn, including documents purporting to be payroll registers for
2019 and the first quarter of 2020, purporting to show wages
paid to its employees.

42. Based on information from the IRS, I know that the IRS
Forms 941 submitted with the American Auto Barn PPP loan were
not filed with the IRS. In fact, IRS records show that American
Auto Barn had not filed quarterly federal income tax returns
with the IRS for 2019 and the first quarter of 2020.

43. Based on my review of the American Auto Barn PPP loan
application, I know that ATTA answered, “No” to the question:

Has the Applicant, any owner of the Applicant, or any

business owned or controlled by any of them, ever

obtained a direct or guaranteed loan from SBA or any
other Federal agency that is currently delinquent or has

defaulted in the last 7 years and caused a loss to the
government?

Based on my review of SBA records, I know that ATTA is listed as
a principal on a SBA loan for Moval Shopping Center LLC that was
funded on January 5, 2016 and which, according to SBA records,
has been delinquent since at least the beginning of 2019.

44. Based on my review of loan documents provided by

Lender A, I know that it approved American Auto Barn’s PPP
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 25 of 48 Page ID #:25

application and funded the loan. According to records provided
by Lender A and Financial Institution 1, on or about May 12,
2020, Lender A transferred via interstate wire approximately
$401,175 in proceeds from the American Auto Barn PPP loan to the
American Auto Barn Account, for which ATTA was the sole
Signatory. At the time the PPP loan proceeds were transferred,
the American Auto Barn Account had approximately $15,341 on
deposit.

45. According to records provided by Financial
Institution 1, six days later on or about May 18, 2020, a
cashier’s check for approximately $665,000, which in substantial
part was comprised of the American Auto Barn PPP loan proceeds
and the Liberty RV PPP loan proceeds (discussed above in
paragraph 33), was purchased from funds drawn on the American
Auto Barn Account. According to records provided by Financial
Institution 4, on or about May 18, 2020, the cashier’s check was
deposited into the CS-1 Account #5.

American Auto Barn EIDL Loan

46. Based on my review of information provided by the SBA,
the SBA received an application in the name of American Auto
Barn seeking an EIDL loan in the amount of $150,000. The
application was electronically submitted in the name of ATTA via

the SBA’s online portal.

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Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 26 of 48 Page ID #:26

47. The SBA approved and funded the American Auto Barn
EIDL loan, and on or about June 12, 2020, the SBA transferred
via interstate wire approximately $149,900 in proceeds from the
American Auto Barn EIDL loan to the American Auto Barn Account,
for which ATTA is the sole signatory. At the time the EIDL loan
proceeds were transferred, the American Auto Barn Account had
approximately $177,415 on deposit. According to records
provided by Financial Institution 1, on or about July 2, 2020,
approximately $410,000, which in part was comprised of the
American Auto Barn EIDL loan proceeds, was wired from the
American Auto Barn Account to the CS-1 Account #2. Based on my
review of records from Financial Institution 1, the American
Auto Barn EIDL loan proceeds were not used for expenses
permitted under the EIDL loan program as described above in

Envisioning Future PPP Loan

48. Based on my review of loan documents provided by
Lender A, I know the following:
a. On or about April 10, 2020, Lender A received a
PPP application in the name of Envisioning Future Inc. d/b/a
Valero Gas Station (“Envisioning Future”) seeking a PPP loan in

the amount of $1,267,141.
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 27 of 48 Page ID #:27

b. The application was electronically submitted in
the name of ATTA, who described himself as the President and
100% owner of Envisioning Future.

c. The PPP borrower application represented that
Envisioning Future had 73 employees, including employees for
whom it paid wages and payroll taxes, and that the purpose of
the PPP loan was to cover payroll.

d. The email associated with this PPP loan
application was attamuh@gmail.com, ATTA’s personal Gmail
account.

e. The loan application was electronically submitted
to Lender A from the common IP address associated with other
entity email addresses appearing in this investigation and
ATTA’s personal Gmail account, as discussed above:
104.34.50.159.

49. Based on my review of loan documents provided by
Lender A, several documents were submitted in support of the
Envisioning Future PPP loan application, including:

a. IRS Employer’s Quarterly Federal Tax Returns (IRS
Form 941) for Envisioning Future for each quarter of 2019 and
the first quarter of 2020; and

b. Payroll data and documentation for Envisioning

Future, including documents purporting to be payroll registers

-? 6-
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 28 of 48 Page ID #:28

for 2019 and the first quarter of 2020, purporting to show wages
paid to its employees.

50. Based on information from the IRS, I know that the IRS
Forms 941 submitted with the Envisioning Future PPP loan were
not filed with the IRS. In fact, IRS records show that
Envisioning Future had not filed quarterly federal income tax
returns with the IRS for 2019 and the first guarter of 2020.

51. Based on my review of the Envisioning Future PPP loan
application, I know that ATTA answered, “No” to the question:

Has the Applicant, any owner of the Applicant, or any

business owned or controlled by any of them, ever

obtained a direct or guaranteed loan from SBA or any
other Federal agency that is currently delinquent or has

defaulted in the last 7 years and caused a loss to the
government?

Based on my review of SBA records and as discussed above, I know
that ATTA is listed as a principal on a SBA loan for Moval
Shopping Center LLC that was funded on January 5, 2016, and
which, according to SBA records, has been delinquent since at
least the beginning of 2019.

52. Based on my review of loan documents provided by
Lender A, I know that it approved Envisioning Future’s PPP
application and funded the loan. According to records provided
by Lender A and Financial Institution 1, on or about May 12,
2020, Lender A transferred via interstate wire approximately

$1,267,140 in proceeds from the Envisioning Future PPP loan to

-27-
Case 2:20-mj-06152-DUTY Document 1 Filed 12/18/20 Page 29 of 48 Page ID #:29

the Envisioning Future Account, for which ATTA was the sole
Signatory. At the time the PPP loan proceeds were transferred,
the Envisioning Future Account had approximately $10,500 on
deposit.

53. According to records provided by Financial
Institution 1, the next day, on or about May 13, 2020, a
cashier’s check for approximately $1,277,000, which in
substantial part was comprised of the Envisioning Future PPP
loan proceeds, was purchased from funds drawn on the Envisioning
Future Account. According to records provided by Financial
Institution 1, on or about May 13, 2020, the cashier’s check was
deposited into the CS-1 Account #1.

54. Based on my review of emails from a loan officer at
Lender A, I know that on or about November 18, 2020, ATTA
contacted Lender A by email using his personal Gmail address,
attamuh@gmail.com, to inquire about the forgiveness of the
Envisioning Future PPP loan.

Envisioning Future EIDL Loan

55. Based on my review of information provided by the SBA,
the SBA received an application in the name of Envisioning
Future seeking an EIDL loan in the amount of $150,000. The
application was electronically submitted in the name of ATTA via

the SBA’s online portal.
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 30 of 48 Page ID #:30

56. The SBA approved and funded the Envisioning Future
EIDL loan, and on or about June 12, 2020, the SBA transferred
via interstate wire approximately $149,900 in proceeds from the
Envisioning Future EIDL loan to the Envisioning Future Account,
for which ATTA is the sole signatory. At the time the EIDL loan
proceeds were transferred, the Envisioning Future Account had
approximately $660 on deposit.

57. According to records provided by Financial
Institution 1, on or about June 22, 2020, approximately
$150,360, which in substantial part was comprised of the
Envisioning Future EIDL loan proceeds, was wired from the
Envisioning Future Account to the American Auto Barn Account,
for which ATTA is the sole signatory. Based on my review of
records from Financial Institution 1, the Envisioning Future
EIDL loan proceeds were not used for expenses permitted under
the EIDL loan program as described above in paragraphs 7(f)-
7(j).

Wermer Construction PPP Loan

58. Based on my review of loan documents provided by
Lender A, I know the following:
a. On or about April 14, 2020, Lender A received a
PPP application in the name of Wermer Construction Inc. (“Wermer

Construction”) seeking a PPP loan in the amount of $326,335.

-? Q-
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 31 of 48 Page ID #:31

b. The application was electronically submitted
through IP address, 104.34.50.159, in the name of ATTA, who
described himself as the President and 100% owner of Wermer
Construction.

Cc. The PPP borrower application represented that
Wermer Construction had 37 employees, including employees for
whom it paid wages and payroll taxes, and that the purpose of
the PPP loan was to cover payroll.

d. The email associated with this PPP loan
application was wermerconstruction@gmail.com.

59. According to records supplied by Google, I know the
following:

a. The email address wermerconstruction@égmail.com
has a listed “Recovery SMS number” of 19097499426 as well as a
“Recovery e-mail” of attamuh@gmail.com.

60. Based on my review of loan documents provided by
Lender A, several documents were submitted in support of the
Wermer Construction PPP loan application, including:

a. IRS Employer’s Quarterly Federal Tax Returns (IRS
Form 941) for Wermer Construction for each quarter of 2019 and
the first quarter of 2020; and

b. Payroll data and documentation for Wermer

Construction, including documents purporting to be payroll

-30-
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 32 of 48 Page ID #:32

registers for 2019 and the first quarter of 2020, purporting to
show wages paid to its employees.

61. Based on information from the IRS, I know that the IRS
Forms 941 submitted with the Wermer Construction PPP loan were
not filed with the IRS. In fact, IRS records show that Wermer
Construction had not filed quarterly federal income tax returns
with the IRS for 2019 and the first quarter of 2020.

62. Based on a review of the payroll data and
documentation for Wermer Construction provided to Lender A, I
know that the number of employees listed in that data and
documentation did not match the number listed in the IRS Forms
941 that were submitted to Lender A.

63. Based on my review of the Wermer Construction PPP loan
application, I know that ATTA answered, “No” to the question:

Has the Applicant, any owner of the Applicant, or any

business owned or controlled by any of them, ever

obtained a direct or guaranteed loan from SBA or any
other Federal agency that is currently delinquent or has

defaulted in the last 7 years and caused a loss to the
government?

Based on my review of SBA records and as discussed above, I know
that ATTA is listed as a principal on a SBA loan for Moval
Shopping Center LLC that was funded on January 5, 2016 and
which, according to SBA records, has been delinquent since at

least the beginning of 2019.

-31-
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 33 of 48 Page ID #:33

64. Based on my review of loan documents provided by
Lender A, I know that it approved Wermer Construction’s PPP
application and funded the loan. According to records provided
by Lender A and Financial Institution 1, on or about May 13,
2020, Lender A transferred via interstate wire approximately
$326,335 in proceeds from the Wermer Construction PPP loan to
the Wermer Construction Account, for which ATTA was the sole
Signatory. At the time the PPP loan proceeds were transferred,
the Wermer Construction Account had approximately $14,772 on
deposit.

65. According to records provided by Financial
Institution 1, five days later on or about May 18, 2020, a
cashier’s check for approximately $340,000, which in substantial
part was comprised of the Wermer Construction PPP loan proceeds,
was purchased from funds drawn on the Wermer Construction
Account. According to records provided by Financial
Institution 4, on or about May 18, 2020, the cashier’s check was
deposited into the CS-1 Account #5.

Wermer Construction EIDL Loan

66. Based on my review of information provided by the SBA,
the SBA received an application in the name of Wermer
Construction seeking an EIDL loan in the amount of $150,000.

The application was electronically submitted in the name of M.P.

via the SBA’s online portal. As described above in paragraph
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 34 of 48 Page ID #:34

21, M.P. was incarcerated at the time the Wermer Construction
EIDL loan application was submitted in his name. Based on my
training and experience, ATTA’s repeated use of M.P.’s name and
social security number in connection with this loan application
(and others described above), supports the inference that ATTA
knew M.P. was a real person whose credentials would pass
scrutiny.

67. Based on my review of the information provided to the
SBA for the Wermer Construction EIDL loan and IRS records, I
know that the EIN listed for Wermer Construction is registered
to ATTA.

68. The SBA approved and funded the Wermer Construction
EIDL loan, and on or about July 2, 2020, the SBA transferred via
interstate wire approximately $149,900 in proceeds from the
Wermer Construction EIDL loan to the Wermer Construction
Account, for which ATTA is the sole signatory. At the time the
EIDL loan proceeds were transferred, the Wermer Construction
Account had approximately $1,863 on deposit.

CKSB PPP Loan

69. Based on my review of loan documents provided by
Lender A, I learned the following:
a. On or about May 27, 2020, Lender A received a PPP
application in the name of CKSB LLC d/b/a Socal Hand Car Washes

(“CKSB”) seeking a PPP loan in the amount of $1,020,229.
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 35 of 48 Page ID #:35

b. The application was electronically submitted in the
name of Z.B., who was described as the President and 100% owner of

c. The PPP borrower application represented that CKSB
had 127 employees, including employees for whom it paid wages and
payroll taxes, and that the purpose of the PPP loan was to cover
payroll.

d. The email associated with this PPP loan application
was eficpa009@gmail.com.

70. According to records supplied by Google, I know the
following:

a. The email address eficpa009@gmail.com has a
“Recovery e-mail” of libertyrv2009@gmail.com, which is also
associated with the loan application for Liberty RV in the name
of M.P., discussed above in paragraph 27.

b. The common IP address, 104.34.50.159, was used to
access ATTA’s personal Gmail account attamuh@gmail.com as well
as various other entity accounts discussed above including
libertyrv2009@gmail.com, americanautobarn@gmail.com,

fontanack2015@gmail.com, and wermerconstruction@gmail.com.

‘Based on my review of records from the California Secretary of
State, I know that Z.B. is not listed as the President or owner
of this entity. In fact, the records do not reference Z.B. in
any way.
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 36 of 48 Page ID #:36

Cc. ATTA appears to know Z.B., based on travel
itineraries for Z.B. and his/her spouse, appearing in ATTA’s
email messages along with communications with H.B. regarding
Z.B.’s health, real estate transactions, and other unrelated
personal matters.

71. Based on my review of loan documents provided by
Lender A, several documents were submitted in support of the
CKSB PPP loan application, including:

a. IRS Employer’s Quarterly Federal Tax Returns (IRS
Form 941) for CKSB for each quarter of 2019 and the first
guarter of 2020; and

b. Payroll data and documentation for CKSB,
including documents purporting to be payroll registers for 2019
and the first quarter of 2020, purporting to show wages paid to
its employees.

72. Based on information from the IRS, I know that the IRS
Forms 941 submitted with the CKSB PPP loan were not filed with
the IRS. In fact, IRS records show that CKSB had not filed
quarterly federal income tax returns with the IRS for 2019 and
the first quarter of 2020. In addition, IRS records show that
CKSB’s EIN is registered to ATTA.

73. Based on a review of the payroll data and
documentation for CKSB provided to Lender A, I know that the

number of employees listed in that data and documentation did
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 37 of 48 Page ID #:37

not match the number listed in the IRS Forms 941 that were
submitted to Lender A.

74. Based on my review of loan documents provided by
Lender A, I know that it approved CKSB’s PPP application and
funded the loan. According to records provided by Lender A and
Financial Institution 1, on or about June 3, 2020, Lender A
transferred via interstate wire approximately $1,020,230 in
proceeds from the CKSB PPP loan to the CKSB Account, for which
ATTA was the sole signatory. At the time the PPP loan proceeds
were transferred, the CKSB Account had approximately $1,093 on
deposit.

75. According to records provided by Financial
Institution 1, five days later on or about June 8, 2020, a
cashier’s check for approximately $821,000, which in substantial
part was comprised of the CKSB PPP loan proceeds, was purchased
from funds drawn on the CKSB Account. According to records
provided by Financial Institution 2, on or about June 8, 2020,
the cashier’s check was deposited into the CS-1 Account #3.

76. According to records provided by Financial
Institution 1, also on or about June 8, 2020, approximately
$200,000, which in substantial part was comprised of the CKSB
PPP loan proceeds, was wired from the CKSB Account to the

American Auto Barn Account.

-3 6-
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 38 of 48 Page ID #:38

Camel and Camel PPP Loan

77. Based on my review of loan documents provided by
Lender A, I know the following:

a. On or about May 28, 2020, Lender A received a PPP
application in the name of Camel and Camel Inc. d/b/a Mobile
Fleet Maintenance (“Camel and Camel”) seeking a PPP loan in the
amount of $859,790.

b. The application was electronically submitted,
through the IP address 107.181.166.101 (discussed below in
paragraph 78), in the name of S.B., who was described as the
President and 100% owner of Camel and Camel.°

c. The PPP borrower application represented that
Camel and Camel had 92 employees, including employees for whom
it paid wages and payroll taxes, and that the purpose of the PPP
loan was to cover payroll, lease/mortgage interest, and
utilities.

d. The email associated with this PPP loan
application was greenwise2019@gmail.com.

78. According to records supplied by Google, I know the

following:

° Based on my review of records received from the California
Secretary of State, I know that ATTA is listed as the President
of this entity.

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Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 39 of 48 Page ID #:39

a. The email address greenwise2019@gmail.com is
connected to ATTA based on the “Recovery SMS number” of
19097499426 and “Recovery e-mail” of attamuh@gmail.com

b. The email greenwise2019@gmail.com was accessed
through IP address, 107.181.166.101, which was also used to

access eficpa009@gmail.com (i.e., the email account associated

with the loan application for CKSB LLC submitted in the name of
Z.B. as discussed in paragraph 69 above).

Cc. ATTA appears to know S.B. based on travel
itineraries for S.B. and his/her spouse Z.B., appearing in
ATTA’s email messages along with communications with H.B.
regarding Z.B.’s health and other unrelated personal matters.

79. Based on my review of loan documents provided by
Lender A, several documents were submitted in support of the
Camel and Camel PPP loan application, including:

a. IRS Employer’s Quarterly Federal Tax Returns (IRS
Form 941) for Camel and Camel for each quarter of 2019 and the
first quarter of 2020; and

b. Payroll data and documentation for Camel and
Camel, including documents purporting to be payroll registers
for 2019 and the first quarter of 2020, purporting to show wages
paid to its employees.

80. Based on information from the IRS, I know that the IRS

Forms 941 submitted with the Camel and Camel PPP loan were not
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 40 of 48 Page ID #:40

filed with the IRS. In fact, IRS records show that Camel and
Camel had not filed quarterly federal income tax returns with
the IRS for 2019 and the first quarter of 2020. In addition,
IRS records show that Camel and Camel’s EIN is registered to

ATTA.

81. Based on a review of the payroll data and
documentation for Camel and Camel provided to Lender A, I know
that the number of employees listed in that data and
documentation did not match the number listed in the IRS Forms
941 that were submitted to Lender A.

82. Based on my review of loan documents provided by
Lender A, I know that it approved Camel and Camel’s PPP
application and funded the loan. According to records provided
by Lender A and Financial Institution 1, on or about June 3,
2020, Lender A transferred via interstate wire approximately
$859,790 in proceeds from the Camel and Camel PPP loan to the
Camel and Camel Account, for which ATTA was the sole signatory.
At the time the PPP loan proceeds were transferred, the Camel
and Camel Account had approximately $100 on deposit.

83. According to records provided by Financial
Institution 1, five days later on or about June 8, 2020, a
cashier’s check for approximately $850,000, which in substantial
part was comprised of the Camel and Camel PPP loan proceeds, was

purchased from funds drawn on the Camel and Camel Account.

-3 Q-
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 41 of 48 Page ID #:41

According to records provided by Financial Institution 5, on or
about June 8, 2020, the cashier’s check was deposited into CS-1
Account #6.

PPP and EIDL Funds Wired to Pakistan

84. According to records provided by Financial
Institution 1, on or about June 22, 2020, CS-1 caused
approximately $1,376,627 (which in substantial part was
comprised of the $1,267,140 in Envisioning Future PPP loan
proceeds discussed in paragraph 52 above) to be wired from the
CS-1 Account #1 to an account at Financial Institution 6 in the
name of Individuals 2 and 3 with an address in Islamabad,
Pakistan. The wire transfer details included a note that the
wire was “family support.”

85. According to records provided by Financial
Institutions 1 and 2, on or about June 22, 2020, CS-1 caused
approximately $850,000 (which in substantial part was comprised
of the $1,020,230 in CKSB PPP loan proceeds discussed in
paragraph 74 above, of which $821,000 was deposited in CS-1
Account #3 as discussed in paragraph 75 above) to be wired from
CS-1 Account #3 to an account at Financial Institution 6 in the
name of Individuals 2 and 3 with an address in Islamabad,
Pakistan. The wire transfer details included a note that the

wire was “FAMILY SUPPORT.”

-40-
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 42 of 48 Page ID #:42

86. According to records provided by Financial
Institution 1, on or about June 24, 2020, CS-1 caused
approximately $840,000 (which in substantial part was comprised
of the $859,790 in Camel and Camel PPP loan proceeds discussed
in paragraph 82 above) to be wired from CS-1 Account #2 to an
account at Financial Institution 6 in the name of Individuals 2
and 3 with an address in Islamabad, Pakistan. The wire transfer
details included a note that the wire was “family support.”

87. According to records provided by Financial
Institutions 1 and 3, on or about June 26, 2020, CS-1 caused
approximately $1,900,000 (which in substantial part was
comprised of the $1,908,595 in Fontana CK PPP loan proceeds
discussed in paragraph 25 above) to be wired from CS-1 Account
#4 to an account at Financial Institution 6 in the name of
Individuals 2 and 3 with an address in Islamabad, Pakistan. The
wire transfer details included a note that the wire was “FAMILY
SUPPORT PROPERTY PURCHASE.”

88. According to records provided by Financial
Institutions 1 and 4, on or about June 26, 2020, a cashier’s
check for approximately $1,284,000 (which in part was comprised
of the $326,335 in Wermer Construction PPP loan proceeds
discussed in paragraph 64 above) was purchased from funds drawn
on CS-1 Account #5 and deposited in CS-1 Account #2. According

to records provided by Financial Institutions 1, on or about
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 43 of 48 Page ID #:43

July 3, 2020, CS-1 caused approximately $1,700,000 (which in
part was comprised of the $326,335 in Wermer Construction PPP
loan proceeds discussed in paragraph 64 above) to be wired from
CS-1 Account #2 to an account at Financial Institution 6 in the
name of Individuals 2 and 3 with an address in Islamabad,
Pakistan. The wire transfer details included a note that the
wire was “family support.”

Foreign Travel

89. Based on my review of border crossing information, I
know the following:

a. ATTA has a history of foreign travel, including a
recent trip to Dubai® in June 2020, from which ATTA has yet to
return to the United States.

b. ATTA also took two trips abroad in 2019,
including a two-week trip to Abu Dhabi in August 2019 and a two-
week trip to Dubai in January 2019.

c. ATTA also travelled to Dubai in the Fall of 2018
and stayed nearly one month.

d. ATTA’s wife also has a history of foreign travel
in 2020, including a flight from the United States to Paris,

France in July 2020 and a return flight to the United States

6 As noted in paragraph 8 above, Financial Institution 6 is a
wholly owned subsidiary of an Islamic bank headquartered in
Dubai, United Arab Emirates.
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 44 of 48 Page ID #:44

from Paris, France in October 2020. Later in October 2020, she
took an outbound flight from the United States to Amsterdam
(with her ultimate destination unknown) and has not returned to
the United States.

e. CS-1 likewise has history of foreign travel,
including one recent trip to Paris, France this year. CS-1 also
appears to have travelled to Abu Dhabi and Dubai during the same
time periods as ATTA in or around January 2019 and in or around
August 2019.

90. Based on the above information, there is probable
cause to believe that:
[18 U.S.C. § 1343]

a. Beginning in or around April 2020 and continuing
until at least in or around July 2020, in Los Angeles County,
within the Central District of California, and elsewhere, ATTA,
together with others known and unknown, knowingly and with
intent to defraud, devised, participated in, executed, and
attempted to execute a scheme to defraud Lender A and the SBA,
and United States taxpayers as to material matters, and to
obtain moneys, funds, assets, and other property owned by and in
the custody and control of the Lender A and the SBA by means of
material false and fraudulent pretenses, representations, and

promises, and the concealment of material facts.

-43-
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 45 of 48 Page ID #:45

b. For the purpose of executing the above-described
scheme to defraud, ATTA, transmitted and caused the transmission
of the following by means of wire and radio communication in
interstate and foreign commerce: a transfer of approximately
$1,908,595 in PPP loan proceeds from Lender A, sent by means of
an interstate wire, into the Fontana CK Account on or about
June 4, 2020.

[18 U.S.C. § 1028A}

Cc. Beginning no later than in or around April 2020
and continuing until at least in or around July 2020, in Los
Angeles County, within the Central District of California, and
elsewhere, ATTA, together with others known and unknown,
knowingly transferred, possessed, and used, and willfully caused
to be transferred, possessed, and used, without lawful
authority, a means of identification that ATTA knew belonged to
another person, namely, the name and social security number of
M.P., during and in relation to wire fraud, a felony violation
of Title 18, United States Code, Section 1343.

[18 U.S.C. § 1956 (h) ]

d. Beginning in or around April 2020 and continuing
through at least in or around July 2020, in Los Angeles and
Riverside Counties, within the Central District of California,

and elsewhere, ATTA and CS-1, together with co-conspirators

-44-
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 46 of 48 Page ID #:46

known and unknown, knowingly combined, conspired, and agreed to
commit the following offenses against the United States:

1. Transactional Money Laundering, in violation
of Title 18, United States Code, Section 1957, by engaging in
and willfully causing others to engage in monetary transactions,
in and affecting interstate commerce, in criminally derived
property of a value greater than $10,000, which property, in
fact, was derived from specified unlawful activity, namely, wire
fraud, in violation of Title 18, United States Code, Section
1343; and

ii. International Concealment Money Laundering,
in violation of Title 18, United States Code, Section
1956(a) (2) (B) (1), by knowingly transporting, transmitting, and
transferring and causing to be transported, transmitted, and
transferred, monetary instruments and funds from a place in the
United States to and through a place outside of the United
States, knowing that the funds involved in the transportation,
transmission, and transfer represented the proceeds of some form
of unlawful activity and knowing that such transportation,
transmission, and transfer was designed in whole and in part to
conceal and disguise the nature, location, ownership, and
control of the proceeds of specified unlawful activity, namely,
wire fraud, in violation of Title 18, United States Code,

Section 1343.

-45-
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 47 of 48 Page ID #:47

e. The objects of the conspiracy were carried out,
and to be carried out, in substance as follows: ATTA would
apply for Paycheck Protection Program (“PPP”) and Economic
Injury Disaster Loan Program (“EIDL”) loans in his name, the
name of coconspirators, and in the name of stolen identity, M.P.
ATTA would submit false and fictitious documents in support of
the PPP and EIDL loan applications. ATTA would then direct that
the PPP and EIDL loan proceeds be deposited into bank accounts
that ATTA controlled. ATTA would transfer PPP and EIDL loan
proceeds to accounts controlled by CS-1 by means of wire
transfer or cashier’s check. CS-1 would then wire the PPP and
EIDL loan proceeds to coconspirators in Pakistan. ATTA, CS-l,
and their coconspirators, would use the fraudulently obtained
PPP and EIDL loan proceeds for their own personal benefit,
including for expenses prohibited under the requirements of the
PPP and EIDL programs.

//
//

-4 6-
Case 2:20-mj-06152-DUTY Document1 Filed 12/18/20 Page 48 of 48 Page ID #:48

CONCLUSION

91. For the all the reasons described above, there is
probable cause to believe that ATTA violated violation of 18
U.S.C. § 1343 (Wire Fraud), 18 U.S.C. § 1028A(a) (1) (Aggravated
Identity Theft), 18 U.S.C. § 1956(h) (Conspiracy to Commit Money
Laundering.

Attested to by the applicant in
Accordance with the requirements

Of Fed. R. Crim. P. 4.1 by
Telephone on aes 18th day of

December, 202

HONORABLE ie ~“AUDE HO
UNITED STAT te oan ae ea JUDGE

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