Criminal Complaint and Affidavit — United States v. Ganiyu Abayomi Jimoh, No. 4:20-cr-00246

Summary

A Criminal Complaint (AO 91), Document 1, filed on 10/30/19, Case 4:20-cr-00246, United States District Court for the Southern District of Texas, against Ganiyu Abayomi Jimoh for Forgery or False Use of a Passport under Title 18, United States Code, Section 1543. The attached Affidavit in Support of Criminal Complaint by US Postal Inspector A.K. Shadowens states that Chase Bank accounts were opened with counterfeit passports in the names Denzel Zulu (purportedly issued by the Republic of Kenya) and Mikel Johnson (purportedly issued by the Republic of Senegal). It describes an approximate $65,000.00 cashier's check deposited into the Zulu account and an approximate $26,800.00 personal check deposited into the Johnson account, with withdrawals of approximately $3,000.00 and $9,500.00.

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Case 4:20-cr-00246 Document1 Filed on 10/30/19 in TXSD Page 1 of 8

AO 91 (Rev. 11/11) Criminal Complaint

United States Courts
UNITED STATES DISTRICT COURT _ Southern district of texas
F
for the
Southern District of Texas OcT 30 2019
United States of America ) David J. Bradley, Clerk of Court
Vv. )
Ganiyu Abayomi Jimoh Case No.
)
Defendant(s)
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of May 7, 2019 and continuing in the county of Brazos in the
Southern District of Texas , the defendant(s) violated:
Code Section Offense Description

18 U.S.C. 1543 Forgery or False Use of a Passport

This criminal complaint is based on these facts:

See attached Affidavit of US Postal Inspector A.K. Shadowens

@ Continued on the attached sheet.

A IGE

Complainant’ Ss signature

Printed name and title

Sworn to before me and signed in my presence.

Judge’ Ss sighature

City and state: Houston, Tzx ao- biter 8 Kray U.S.M. ‘

Printed name dnd title
Case 4:20-cr-00246 Document 1 Filed on 10/30/19 in TXSD Page 2 of 8

AO 91 (Rev. 11/11) Criminal Complaint

United States Courts
UNITED STATES DISTRICT COURT _ Souther District of Texas
FIL
for the
Southern District of Texas OcT 30 2019
United States of America ) David J. Bradley, Clerk of Court
V. )
Ganiyu Abayomi Jimoh Case No.
) 9 4 af
| HT 036K
)
Defendant(s)
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of May 7, 2019 and continuing in the county of Brazos in the
Southern District of Texas , the defendant(s) violated:
Code Section , Offense Description
18 U.S.C. 1543 Forgery or False Use of a Passport

This criminal complaint is based on these facts:

See attached Affidavit of US Postal Inspector A.K. Shadowens

@ Continued on the attached sheet.

Complainant’ Ss signature

Printed name and title

Sworn to before me and signed in my presence.

Date: |0 ola LAS

Judge’ Ss sighature

City and state: Houston, Tex aor bt 8 Kray USM. J

Printed name dnd title
Case 4:20-cr-00246 Document1 Filed on 10/30/19 in TXSD Page 3 of 8

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

. Your Affiant, A.K. Shadowens, is employed as a federal law enforcement officer by the
United States Postal Inspection Service. Affiant has been employed as a federal law
enforcement officer since 2013 and is assigned to the Financial Crimes team in the Houston
Division of the United States Postal Inspection Service. Affiant is responsible for
conducting and has conducted many investigations into fraud, identity theft, and related
“white collar” types of offenses. Affiant is a Certified Fraud Examiner and has received
training in numerous Postal crimes, but primarily those involving “identity theft” and mail
fraud related offenses. Affiant is authorized to obtain and execute Federal arrest and search
warrants.

. The information contained within this Affidavit is based upon information your Affiant has
gained from his investigation, personal observations, training and experience, and/or
information provided to your Affiant by other Postal Inspectors, law enforcement officers
and/or agents, and fraud investigators.

. This Affidavit is intended to show merely that there is sufficient probable cause for the
requested warrant and does not purport to set forth all of Affiant’s knowledge of or
investigation into this matter. Unless specifically indicated otherwise, all conversations
and states described in this Affidavit are in substance and in part only.

. Affiant knows from training and experience that a “romance scam” is a confidence trick
fraud during which fraudsters create fake online profiles to take advantage of individuals
looking for romantic partners by feigning romantic intentions towards a victim on dating
websites, apps, or social media, gaining the victim’s affection and using that goodwill to
commit fraud by obtaining access to the victim’s money, bank accounts, credit cards,
passports, e-mail accounts, or personal identifying information.

. Affiant solemnly swears and has reason to believe and does believe that GANIYU
ABAYOMI JIMOH, an African-American male, date of birth March 22, 1993
(hereinafter referred to as “DEFENDANT”) on or about May 7, 2019 and September 11,
2019, in the Southern District of Texas, and elsewhere, did willfully and knowingly use,
or attempt to use, a false, forged, counterfeited, mutilated, or altered passport in violation
of Title 18, United States Code, Section 1543 (Forgery or False Use of a Passport).

. On or about October 10, 2019, Affiant was contacted by Dawn Hardwick, whom A ffiant
knows to be an investigator with JP Morgan Chase Bank and finds to be reliable and
credible. Hardwick advised she had identified two (2) Chase Bank accounts opened with
counterfeit passports, which Affiant later found had received funds from reported
fraudulent activity. Hardwick provided supporting documents, which Affiant reviewed
and found the following:

Page 1 of 6
Case 4:20-cr-00246 Documenti1 Filed on 10/30/19 in TXSD Page 4 of 8

Chase Bank Accounts 5817 and 2850 — Denzel Zulu

7. On or about May 7, 2019, Chase Bank checking account ending in 5817 and Chase Bank
savings account ending in 2850 were opened by DEFENDANT posing as Denzel Zulu at
the Chase Bank located at 2000 Texas Avenue South, College Station, Texas 77840,
located within the Southern District of Texas. At the time of account opening
DEFENDANT presented a counterfeit passport in the name of Denzel Zulu purporting to
have been issued by the Republic of Kenya, which is seen below.

aN

REPUBLIC OF KENYA

8. Affiant found from a review of information provided by Hardwick that on or about
September 3, 2019 at the Chase Bank located at 14400 Memorial Drive, Houston, TX
77079 an approximate $65,000.00 cashier’s check payable to Denzel Zulu was deposited
into the Chase account ending in 5817. Affiant was able to determine that Victim P.S., a
resident of Ohio, had purchased the cashier’s check. On or about October 25, 2019, Affiant
spoke with Victim P.S. and learned that she had an online boyfriend, whom she has never
met in-person, using the name “David Miller” and she was led to believe “Miller” was a
USS. soldier in Afghanistan. Victim P.S. further advised that she and “Miller” planned to
purchase real estate upon “Miller’s” return to the U.S., and the approximate $65,000.00
cashier’s check was to serve as a down payment for the real estate. Victim P.S. stated
Miller led her to believe Denzel Zulu was an attorney that was assisting with the purchase
of the real estate, and she purchased the cashier’s check and mailed it to Zulu at a Houston,
TX address under these false pretenses.

9. On or about September 16, 2019, Chase Bank surveillance cameras captured
DEFENDANT conducting an approximate $3,000.00 withdrawal from the Zulu account

Page 2 of 6
Case 4:20-cr-00246 Document 1 Filed on 10/30/19 in TXSD Page 5 of 8

ending in 2850 at a Chase ATM located 15840 FM 529, Houston, Harris County, Texas
77095. An ATM surveillance image of DEFENDANT conducting this transaction is seen
below.

Digital Video Snapshot
Site: JPMorgan Chase/TX/Houston/TX Copperfield West 15840 FM 529 Rd
Camera Name: 4.2 EATM Transaction

9/16/2019 11:37:47 AM (Central Daylight Time)

10. Affiant made contact with Special Agent Katherine Langston, whom Affiant knows to be
employed as a Special Agent with the U.S. Diplomatic Security Service and knows to be
reliable and credible. SA Langston advised Affiant that there is no record of any individual
entering the United States with the above-described Kenyan passport in the name of Denzel
Zulu.

Chase Bank Accounts 1316 and 9222 — Mikel Johnson

11. On or about September 11, 2019, Chase Bank checking account ending in 1316 and Chase
Bank savings account ending in 9222 were opened by DEFENDANT posing as Mikel
Johnson at the Chase Bank located at 2335 Boonville Road, Bryan, Texas 77808, located
within the Southern District of Texas. At the time of account opening, DEFENDANT
presented a counterfeit passport in the name of Mikel Johnson purporting to have been
issued by the Republic of Senegal, which is seen below.

Page 3 of 6
Case 4:20-cr-00246 Document1 Filed on 10/30/19 in TXSD Page 6 of 8

woz O27
2822 Oa aS gb:
SES m ~ bar
SEZ BS g
w > uJ
a [od
REPUBLIQUE DU SENEGAL
MIKEL
JOHNSON ”
SENEGALAISE
22 MARS / MAR "1989
05 JUIL/ JUL 2022
A007038547SEN8903225M22070531895426391864260

12. Affiant learned from a review of information provided by Hardwick that on or about
September 11, 2019, at the Chase Bank located at 2335 Boonville Road, Bryan, TX 77808
and approximate $26,800.00 personal check written on the account of Victim P.S. was
deposited into the Johnson account ending in 9222. In Affiant’s October 25, 2019
conversation with Victim P.S., Affiant was advised “Miller” had led her to believe Mikel
Johnson was also assisting in some capacity with the purchase of real estate, and these
funds were mailed to Mikel Johnson at an address in Houston, TX for this false purpose.

13.On or about September 14, 2019, Chase Bank surveillance cameras captured
DEFENDANT conducting an approximate $9,500.00 withdrawal from the Johnson
account ending in 9222 at a Chase branch located at 2900 W Grand Parkway N, Katy,
Harris County, Texas 77449. An ATM surveillance image of DEFENDANT conducting
this transaction is seen below.

Page 4 of 6
14.

15.

16.

Case 4:20-cr-00246 Document 1 Filed on 10/30/19 in TXSD Page 7 of 8

SA Langston advised Affiant that there is no record of any individual entering the United
States with the above-described Senegalese passport in the name of Mikel Johnson.

On or about October 16, 2019, Hardwick advised she had identified phone number 281-
310-7066 as being associated to the Zulu account. Hardwick stated that according to Chase
records, this phone number was also associated to DEFENDANT’S true name Chase Bank
account. Affiant researched the phone number through the a law enforcement
database and found it is associated to DEFENDANT.

Affiant obtained the known Texas driver’s license image of DEFENDANT, which is seen
below. Hardwick provided Affiant with still surveillance images of DEFENDANT
conducting transactions on his true name account, one of which is seen below. Affiant
further obtained a known immigration photograph from SA Langston of DEFENDANT,
seen below. Affiant reviewed these images in comparison to the bank and ATM
surveillance images above, as well as the images on the counterfeit passports. Affiant
believes and has reason to believe the individual seen in the images posing as Denzel Zulu
and Mikel Johnson is DEFENDANT, Ganiyu Abayomi Jimoh.

Page 5 of 6
Case 4:20-cr-00246 Document 1 Filed on 10/30/19 in TXSD Page 8 of 8

17. Based upon the foregoing, Affiant believes there is probable cause that GANIYU
ABAYOMI JIMOH has committed crimes in violation of Title 18, United States Code,

Section 1543 (Forgery or False Use of a Passport).

A.K. Shadowens
United States Postal Inspector

Sworn and Subscribed to me this? 0 day of October, 2019 and I find probable cause.

fe bor

Peter Bray
United States Magistrate Judge
Southern District of Texas

Page 6 of 6


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