First Superseding Indictment — United States v. Olamide Olatayo Bello et al. (Document 376)

Summary

First Superseding Indictment filed December 11, 2024 as Document 376 in United States of America v. Olamide Olatayo Bello (1), Olabode Thomas Ajibola (2) and Dumbor Josephine Baribe (11), Case No. 4:23CR136 (4:23-cr-00136-ALM-BD), U.S. District Court for the Eastern District of Texas, Sherman Division. Count 1 charges Conspiracy to Commit Wire Fraud under 18 U.S.C. § 1349 from approximately in or around April 2020, and the Notice of Penalty lists Count Two as Conspiracy to Commit Money Laundering under 18 U.S.C. § 1956(h). The indictment alleges a scheme led by Bello to obtain PPP and EIDL loan proceeds through false applications and fabricated documentation. It alleges that Preferred Oil and Gas Services, LLC submitted a first draw PPP application on or about March 16, 2021, and that $111,332 was sent on or about March 18, 2021.

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“First Superseding Indictment — United States v. Olamide Olatayo Bello et al. (Document 376).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-4-23-cr-00136-dkt-376-e-d-tex-a4ee57b6a3/, SHA-256 2c444d1b0dbd4cc4dde6cb68ba692d39665a440952c3f58c93490f6c15917095.

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Case 4:23-cr-00136-ALM-BD Document 376 Filed 12/11/24 Page 1 of 23 PageID #:
2104 filed
PAC D,STRICTC0URT
E STERN DIST ICT OF TEXAS

IN THE UNITED STATES DISTRICT COURT DEC I 1 2024
FOR THE EASTERN DISTRICT OF TEXAS
by deputy
SHERMAN DIVISION

UNITED STATES OF AMERICA
§
v. § Case No. 4:23CR136
§ Judge Mazzant
OLAMIDE OLATAYO BELLO (1)
OLABODE THOMAS AJIBOLA (2)
DUMBOR JOSEPHINE BARIBE (11) §
FIRST SUPERSEDING INDICTMENT

THE UNITED STATES GRAND JURY CHARGES:

General Allegations

At all times material to the facts set forth in this First Superseding Indictment:

The conspirators and related entities

1. Olamide Olatayo Bello ( Bello ) was an individual residing in McKinney,

Texas, in the Eastern District of Texas. Bello controlled and managed the following

business organizations, which were located and operated in McKinney, Texas, in the

Eastern District of Texas:

a. Ajide Technology Corporation

b. Smooth Multi-Services Platform

c. Obello Solutions Corporation

d. Obello, Inc.

e. Yembell

f. DOBIT

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2. Olabode Thomas Ajibola ( Ajibola ) was an individual residing in

Carlsbad, New Mexico. Preferred Oil & Gas Services, LLC ( Preferred ) was a business

that was organized and operated in Midland, Texas. Ajibola was the managing member

of Preferred.

3. Kehinde Sunday Itiola ( Itiola ) was an individual residing in Midland,

Texas. Kenny Sunny (“Kenny ) was a business organization located and operated in

Midland, Texas. Itiola was the registered agent of Ker y.

4. Bright Nnamdi Uwadileke ( Uwadileke ) was an individual residing in

Spring, Texas. B-Light Services ( B-Lighf ) was a business that was organized and

operated in Frisco, Texas, in the Eastern District of Texas. Uwadileke was a manager

and the registered agent of B-Light.

5. Victor Chibuike N eke ( Nweke ) was an individual residing in Odessa,

Texas. Victor Motor s, LLC (“Victor ) was a business that was organized and operated

in Odessa, Texas. N eke was the managing member and registered agent of Victor.

6. Justice Nzube O ueji ( J. O ueji ) was an individual residing in Dallas,

Texas. Zuby Automobile (“Zuby”) was a business that was organized and operated in

Dallas, Texas. J. O ueji was the owner of Zuby.

7. Nnaemeka Emmanuel Ogueji ( N. Ogueji ) was an individual residing in

McKinney, Texas, in the Eastern District of Texas. Ejico Transportation, LLC (“Ejico ),

also known as Ejico, LLC, was a business that was organized and operated in Garland,

Texas. N. Ogueji was the Chief Executive and registered agent of Ejico.

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8. Sabur Olawale Yusuff ( Yusuff ) was an individual residing in Princeton,

Texas, in the Eastern District of Texas. S-O-Y was a business that was organized in

Colorado. Yusuff was affiliated with S-O-Y.

9. Abdulhakeen Olayinka Salaudeen ( Salaudeen ) was an individual

residing in Katy, Texas. Yinxandpartners ( Yinx ) was a business that was organized in

Colorado and operated in Odessa, Texas. Salaudeen was the incorporator and registered

agent of Yinx.

10. Dumber Josephine Baribe ( Baribe ) was an individual residing in

Wylie, Texas, in the Eastern District of Texas. Josephine Catering Services was a

business that was organized and operated in Dallas, Texas. Baribe was the sole

proprietor of Josephine Catering Services.

The Small Business Administration

11. The United States Small Business Administration ( SBA ) was an

executive-branch 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 and viability of small

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

12. As part of this effort, the SBA enabled and provided for loans through

banks, credit unions, and other lenders. These loans have government-backed

guarantees.

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The Paycheck Protection Program

13. The Coronavirus Aid, Relief, and Economic Security ( CARES ) Act was

a federal law enacted in 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 source of relief provided by the CARES Act was the

authorization of forgivable loans to small businesses for job retention and certain other

expenses, through a program referred to as the Pay check Protection Program ( PPP ).

14. To obtain a PPP loan, a qualifying business was required to submit a PPP

loan application, which was signed by an authorized representative of the business. The

PPP loan application required the 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. In the PPP loan application (SBA Form 2483), the small

business (through its authorized representative) 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.

15. A PPP loan application was processed by a participating lender. If a PPP

loan application was approved, the participating lender funded the PPP loan using its own

monies, which were guaranteed by the SBA. Data from the application, including

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information about the borrower, the total amount of the loan, and the listed number of

employees, was transmitted by the lender to the SBA in the course of processing the loan.

16. PPP loan proceeds were required to be used on certain permissible

expenses, including payroll costs, mortgage interest, rent, and utilities. Under the

applicable PPP rules and guidance, the interest and principal on the PPP loan is eligible

for forgiveness if the business spent the loan proceeds on these expense items within a

designated period of time and used a certain portion of the loan towards payroll

expenses.

The Economic Injury Disaster Loan Program

17. The Economic Injury Disaster Loan ( EIDL ) Program was an SBA

program that provided low-interest financing to small businesses, renters, and

homeowners in regions affected by declared disasters. The CARES Act authorized the

SBA to provide EIDLs up to $2,000,000 to eligible small businesses experiencing

substantial financial disruption due to the COVID-19 pandemic. In addition, the CARES

Act authorized the SBA to issue advances of up to $10,000 to small businesses within

three days of applying for an EIDL. The amount of the advance was determined by the

number of employees the applicant certified having. The advances did not have to be

repaid.

18. In order to obtain an EIDL and advance, a qualifying business was

required to submit an application to the SBA and provide information about its

operations, such as: (1) the number of employees, (2) gross revenues for the 12-month

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period preceding the disaster, and (3) cost of goods sold in the 12-month period

preceding the disaster. The 12-month period for EIDLs for COVID-19 relief was from

January 31, 2019, to January 31, 2020. The applicant was also required to certify that all

the information in the application was true and correct to the best of the applicant s

knowledge.

19. EIDL applications were submitted directly to the SB A and processed by

the agency with support from a government contractor, Rapid Finance. The amount of

the loan, if the application were approved, was detemined based on the information

provided by the applicant about employment, revenue, and cost of goods, as described

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

EIDL 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 funds could not be used for the same purpose

as the PPP funds.

COUNT 1

Violation: 18U.S.C. § 1349
(Conspiracy to Commit Wire Fraud)

20. From approximately in or around April 2020, and continuing through the

date of this First Superseding Indictment, the exact dates being unknown to the Grand

Jury, in the Eastern District of Texas, and elsewhere, the defendants,

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OLAMIDE OLATAYO BELLO,
OLABODE THOMAS AJIBOLA, and
DUMBOR JOSEPHINE BARIBE

along with others, both known and unknown to the grand jury, did knowingly and

willfully conspire and agree to violate 18 U.S.C. § 1343, wire fraud, that is, to transmit

and cause to be transmitted by means of wire communication in interstate and foreign

commerce any writings, signs, signals, pictures, and sounds for the pur ose of executing

a scheme and artifice to defraud and for obtaining money and property by means of false

and fraudulent pretenses, representations, and promises.

Overview of the Conspiracy

21. The defendants, led by Olamide Olatayo Bello ( Bello ), executed a

scheme to defraud lenders and the SBA. Bello recruited co-conspirators submit

applications to obtain PPP funding. Once enlisted, Bello assisted his co-conspirators with

the application paperwork, including fabricating supporting documentation and

submitting the application through the online portals. On the applications, the defendants

and their co-conspirators misrepresented material information, such as the true nature of

their business, the number of employees, and the amount of payroll. Based on these

material misrepresentations, the SBA, and other financial institutions on behalf of the

SBA, approved and issued loans to the defendants and their co-conspirators. Once in

receipt of the fraudulently obtained funds, the defendants and their co-conspirators did

not use the money as intended, such as to pay employee salaries, cover fixed debt and

utility payments, and continue health care benefits for employees. Instead, the

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defendants and their co-conspirators typically paid Bello, transferred money to their

personal accounts, and spent the funds on various personal purchases.

Purpose of the Conspiracy

22. It was the general purpose of the conspiracy for the defendants and their co¬

conspirators to unlawfully and unjustly enrich themselves by obtaining PPP and EIDL

loan proceeds through materially false and fraudulent pretenses, representations, and

promises.

Manner and Me ns of the Conspiracy

23. The maimer and means by which the defendants and their co-conspirators

sought to accomplish the purpose of the conspiracy included, among others, the

following:

a. The defendants and their co-conspirators registered and used sham, non-
operational businesses, and in other instances existing businesses, under
which they could submit PPP and EIDL loan applications.

b. The defendants and their co-conspirators opened bank accounts under their
names and their businesses to receive, deposit, and transfer PPP and EIDL
funds.

c. The defendants and their co-conspirators submitted materially false and
fraudulent PPP and EIDL loan applications, misrepresenting, among other
things, the number of employees and monthly payroll expenses.

d. The defendants and their co-conspirators submitted falsified and fabricated
supporting documentation in support of their loan applications.

e. The defendants and their co-conspirators submitted the applications and
accessed their PPP and EIDL loan accounts using the internet, frequently from
an internet protocol ( IP ) address that resolved back to Bello s residence in
McKinney, Texas, in the Eastern District of Texas.

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f. The defendants and their co-conspirators used the PPP and EIDL funds for
unauthorized personal purposes, including cash withdrawals, making luxury
vehicle purchases, home improvements, and sending the money
internationally via wire transfer.

g. The defendants and their co-conspirators paid a portion of the PPP funds to
co-conspirator Bello.

h. The defendants and their co-conspirators caused transmissions that affected
interstate commerce by sending, and causing to be sent, wire transfers, and by
accessing and submitting the PPP and EIDL applications online.

Acts in Furtherance of the Conspiracy

In furtherance of the conspiracy and to achieve its objects and purpose, the

following acts, among others, were committed in the Eastern District of Texas and

elsewhere.

Preferred Oil and G s Services fraudulent PPP application

24. On or about March 16, 2021, Preferred Oil and Gas Services, LLC,

( Preferred ) submitted a materially false PPP loan application to Amur Equipment

Finance. Olabode Thomas Ajibola ( Ajibola ) signed the PPP application as the

primary contact and designated Wells Fargo Bank account number XXXXXX1473, in

the name of Preferred ( Preferred Account 1473 ), as the account to receive the loan

funds. On the application, Ajibola certified that:

The funds will be used to retain orkers and maintain payroll; or make
payments for mortgage interest, rent, utilities, covered operations
expenditures, covered property damage costs, covered supplier costs, and
covered worker protection expenditures as specified under the Paycheck
Protection Program Rules; I understand that if the funds are knowingly used

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for unauthorized purposes, the federal government may hold me legally
liable, such as for charges of fraud.

The Preferred PPP loan account was accessed electronically from IP address

12.11.136.106.

25. On or about April 8, 2021, Preferred submitted a second materially false

PPP loan application to Amur Equipment Finance to request a second draw on the

original PPP loan. Again, Ajibola signed the second draw loan PPP application as the

primary contact and designated the Preferred Account 1473 as the account to receive the

loan funds. Once again, the Preferred PPP loan account was accessed electronically from

IP address 12.11.136.106.

26. The Preferred PPP application falsely stated that the business had 7

employees and had an average monthly payroll expense of approximately $44,533. In

support of the PPP application, Ajibola submitted documentation, such as a copy of his

driver s license, a voided check, an IRS 1120-S corporate tax return, an IRS 941

Quarterly federal tax document, financial statements, and an invoice.

27. On or about March 18, 2021, Amur Equipment Finance funded the first

draw PPP loan for Preferred and sent $111,332 to Preferred Account 1473.

28. On or about June 14, 2021, Amur Equipment Finance funded the second

draw PPP loan for Preferred and sent $ 111,332 to Preferred Account 1473.

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Misuse of PPP funds

29. On January 11, 2020, Bello opened a business checking account at Wells

Fargo Bank bearing account number XXXXXX0889, in the name of Ajide Technology

Corporation ( Ajide Account 0889 ). The mailing address for the Ajide Account 0889

was Bello s residence in McKinney, Texas, in the Eastern District of Texas. Bello was

listed as the sole signer on Ajide Account 0889.

30. On or about March 19, 2021, approximately one day after obtaining the

first draw of the Preferred PPP loan, Ajibola obtained a cashier s check drawn from

Preferred Account 1473, made payable to Bello s company, Ajide Technology

Corporation ( Ajide ), in the amount of $33,399.60. This amount equaled exactly 30%

of the PPP loan funds provided to Preferred. Bello was not an employee of Preferred.

31. On March 19, 2021, the cashier’s check payable to Ajide was deposited

into Ajide Account 0889. The balance in Ajide Account 0889 prior to the deposit of

$33,399.60 was approximately $6,000.

32. On March 22, 2021, Bello made a $27,795.07 payment to Dovenmuehle

Mortgage, Inc (“Dovenmuehle ). Dovenmuehle was the mortgage company that, at that

time, held the loan for Bello s primary residence in McKinney, Texas, in the Eastern

District of Texas. Without the $33,399.60 deposit from Ajibola, the payment by Bello to

Dovenmeuhle would not have been possible.

33. On April 19, 2021, Bello opened a business checking account at Navy

Federal Credit Union, bearing account number XXXXXX1281, in the name of Ajide,

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( Ajide Account 1281 ). The mailing address for Ajide Account 1281 was in McKinney,

Texas, in the Eastern District of Texas. Bello was listed as the sole signer on Ajide

Account 1281.

34. On or about June 18, 2021, approximately four days after obtaining the

second draw of the Preferred PPP loan, Ajibola obtained a cashier s check from the

Preferred Account, made payable to Ajide, in the amount of $33,399.60. This again

equaled exactly 30% of the PPP loan funds provided to Preferred. Again, Bello was not

an employee of Prefe red.

35. On June 25, 2021, the cashier’s check payable to Ajide was deposited into

Ajide Account 1281. Bello was the sole signer on Ajide Account 1281. The balance in

Ajide Account 1281 prior to the deposit of $33,399.60 was approximately $8,000.

36. On June 28, 2021, Bello sent five intra-bank transfers totaling $25,000 to

Navy Federal Credit Union account number XXXXXX1002 ( Bello Account 1002 ), a

personal checking account held in the name of Bello. The balance in Bello Account 1002

prior to the deposit of $25,000 was approximately $238. Immediately upon deposit into

Bello Account 1002, Bello transferred $20,000 into Navy Federal Credit Union account

number XXXXXX2297, held in the name of Smooth Multi-Services Platform ( Smooth

Account 2297 ). Bello is the sole signer on Smooth Account 2297.

37. On June 30, 2021, $20,000 of the funds that originated from Ajibola, and

transferred through Ajide Account 1281, were combined with other funds that were

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recently deposited into the Smooth Account 2297 by Bello into a $75,000 wire transfer,

which was sent internationally to Nigeria.

Additional PPP loans that paid 30-32% to Bello

38. Further, in support of the scheme, much like the Preferred loan received by

Ajibola, upon receipt of the PPP loans funds, many of the co-conspirators paid

approximately 22-33% of PPP funds received to Bello. For instance:

a. On or about May 6, 2020, Abdulhakeem Olayinka Salaudeen ( Salaudeen )
obtained a PPP loan for approximately $43,750 for his company,
Yinxandpartners. Upon receipt of the PPP loan funds, Salaudeen wrote a
$14,145 check to Ajide, which equaled approximately 32% of the total PPP
loan amount received. Bello was not an employee of Yinxandpartners.

b. On or about May 29, 2020, Kehinde Sunday Itiola ( Itiola ) obtained a PPP
loan for approximately $32,181 for his company Kenny Sunny. Upon receipt
of the PPP loan funds, Itiola wrote a $9,600 check to Ajide, which equaled
approximately 30% of the total PPP loan amount received. Bello was not an
employee of Kenny Sunny.

c. On or about May 30, 2020, Bright Nnamdi Uwadileke ( Uwadileke )
obtained a PPP loan for approximately $89,310 for his company, B-Light
Services. Upon receipt of the PPP loan funds, Uwadileke wrote a $26,793.14
check to Ajide, which equaled 30% of the total PPP loan amount received.
Bello was not an employee of B-Light Services.

d. On or about May 26, 2020, Victor Chibuike Nweke ( Nweke ) obtained a
PPP loan for approximately $53,500 for his company Victor Motor s, LLC.
Upon receipt of the PPP loan funds, Nweke wrote a $16,050 check to Ajide,
which equaled 30% of the total PPP loan amount received. Bello was not an
employee of Victor Motor s, LLC.

e. On or about September 22, 2020, Justice Nzube O ueji ( J. O ueji )
obtained a PPP loan for approximately $62,400 for his company Zuby
Automobile. Upon receipt of the PPP loan funds, J. O ueji obtained a
$18,720 cashier’s check made payable to Smooth Multi-Platform, a company
controlled by Bello, which equaled 30% of the total PPP loan amount received.

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Bello was not an employee of Zuby Automobile.

f. On or about February 18, 2021, J. Ogueji obtained a second draw on the
original PPP loan for approximately $62,400 for Zuby Automobile. Upon
receipt of the PPP loan funds, J. Ogueji obtained a $18,720 cashier s check
made payable to Ajide, which equaled 30% of the total PPP loan amount
received. Again, Bello was not an employee of Zuby Automobile.

g. On or about March 8, 2021, Nnaemeka Emmanuel Ogueji ( N. Ogueji )
obtained a PPP loan for approximately $116,332 for his company Ejico, LLC.
Upon receipt of the PPP loan funds, N. Ogueji wrote a $34,899 check to Bello,
which equaled 30% of the total PPP loan amount received. Bello was not an
employee of Ejico, LLC.

h. On or about March 26, 2021, Sabur Olawale Yusuff ( Yusuff ) obtained a
PPP loan for approximately $106,502 for his company S-O-Y. Upon receipt of
the PPP loan funds, Yusuff obtained a $31,950.06 cashier s check made
payable to Ajide, which equaled 30% of the total PPP loan amount received.
Bello was not an employee of S-O-Y.

i. On or about May 14, 2021, Uwadileke obtained a second PPP loan for
approximately $120,257 for B-Light Services. Upon receipt of the PPP loan
funds, Uwadileke wrote a $37,650 check to Ajide, which equaled 31% of the
total PPP loan amount received. Again, Bello was not an employee of B-Light
Services.

j. On or about June 8, 2021, Dumber Josephine Baribe ( Baribe ) obtained a
PPP loan for approximately $141,373 for her company Josephine Catering
Service. Upon receipt of the PPP loan funds, Baribe obtained a $42,411.90
cashier’s check made payable to Smooth Multi-Services Platform, which
equaled 30% of the total PPP loan amount received. Bello was not an
employee of Josephine Catering Service.

PPP loans obtained by Bello

39. On September 21, 2015, Bello opened a personal checking account at

Community America Credit Union bearing account number XXXXXX1701 ( Bello

Account 1701 ). The mailing address for Bello Account 1701 was Bello’s residence in

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McKinney, Texas, in the Eastern District of Texas. Bello was listed as the sole signer on

Bello Account 1701.

40. On May 18, 2017, Bello opened a personal checking account at Citibank,

N.A., bearing account number XXXXXX3173 ( Bello Account 3173 ). The mailing

address for Bello Account 3173 was Bello s residence in McKinney, Texas, in the

Eastern District of Texas. Bello was listed as the sole signer on Bello Account 3173.

41. On January 13, 2020, Bello opened a personal checking account at Wells

Fargo Bank bearing account number XXXXXX0897 (“Bello Account 0897 ). The

mailing address for Bello Account 0897 was Bello s residence in McKinney, Texas, in

the Eastern District of Texas. Bello was listed as the sole signer on Bello Account 0897.

42. On October 2, 2020, Bello opened a business checking account at BB&T

bearing account number XXXXXX5834, in the name of Obello, Inc. (“Obello Account

5834”). The mailing address for Obello Account 5834 was Bello s residence in

McKinney, Texas, in the Eastern District of Texas. Bello was listed as the sole signer on

Obello Account 5834.

43. Further, in support of the scheme, Bello also obtained multiple PPP loans

for businesses that he owned and controlled. For instance:

a. On or about August 6, 2020, Bello obtained a first draw PPP loan for
approximately $40,100 for his company Yembell, which was deposited into
Bello Account 1701, which was a personal checking account held by Bello, not
a company checking account in the name of Yembell.

b. On or about February 11, 2021, Bello obtained a second draw PPP loan for
approximately $43,800 for his company Yembell, which was deposited into

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Bello Account 5834, an account held in the name of Obello, Inc. In support of
the PPP loan draw, Bello submitted a monthly bank statement that had been
altered.

c. On or about May 29, 2020, Bello obtained a first draw PPP loan for
approximately $52,000 for his company Obello Solutions Corporation, which
was deposited into Bello Account 3173. In support of the second PPP loan
draw, Bello submitted a monthly bank statement that had been altered.

d. On or about February 25, 2021, Bello obtained a second draw PPP loan for
approximately $115,500 for his company Obello Solutions Corporation, which
was deposited into Bello Account 0897. In support of the second PPP loan
draw, Bello submitted a monthly bank statement that had been altered.

EIDL loans obtained by Bello

44. On June 18, 2021, Bello opened a business checking account at Navy

Federal Credit Union bearing account number XXXXXX8123, in the name of DOBIT

( DOBIT Account 8123 ). The mailing address for DOBIT Account 8123 was Bello s

residence in McKinney, Texas, in the Eastern District of Texas. Bello was listed as the

sole signer on DOBIT Account 8123.

45. Further, in support of the scheme, Bello also obtained multiple EIDL loans

for businesses that he owned and controlled. For instance:

a. On or about June 2, 2020, Bello obtained an EIDL loan for approximately
$90,000 for his company Ajide Technology Corporation, which was deposited
into Ajide Account 0889.

b. On or about June 22, 2021, Bello obtained an EIDL loan for approximately
$499,900 for his company DOBIT, which was deposited into DOBIT Account
8123.

c. On or about November 30, 2021, Bello obtained dditional EIDL loan funds in
the amount of $779,500 for his company DOBIT, which were also deposited
into DOBIT Account 8123.

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Misuse of $89,900 in EIDL funds received by Bello

46. On June 2, 2020, the EIDL funds totaling $89,900 were deposited by

the SBA into Ajide Account 0889.

47. In addition, on June 2, 2020, the $26,793.74 check from Uwadileke

(which represented 30% of the PPP loan funds paid to B-Light) was also deposited into

Ajide Account 0889. The balance in Ajide Account 0889 prior to these two deposits was

approximately $20,562.47.

48. On June 5, 2020, Bello wrote a $60,800 check made payable to Dodge

City of McKinney for the purchase of a 2020 Dodge Ram 1500 truck, which is registered

to Ajide Technology Corporation and Bello at Bello s residence, in McKinney, Texas, in

the Eastern District of Texas.

Misuse of $499,900 in EIDL funds received by Bello

49. From June 23, 2021, through June 30, 2021, Bello transferred

approximately $261,000 from DOBIT Account 8123 to other personal and business bank

accounts he controlled. During this time frame, there were no other funds deposited into

DOBIT Account 8123.

50. In addition to the outgoing transfers, Bello also made the following

purchases utilizing the EIDL funds that were deposited into DOBIT Account 8123:

a. $72,064.10 payment to Goodleap, LLC, for the purchase of solar panels,
which were installed on Bello s residence.

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b. $50,000 check made payable to Mercedes-Benz of McKinney for the
purchase of a 2020 Mercedes-Benz G550 luxury automobile, which is
registered to Bello at Bello s residence, in McKinney, Texas, in the Eastern
District of Texas.

c. Two payments totaling $119,891.32 to Ally Bank to pay off two Dodge
Ram trucks that were personally owned by Bello.

51. The $261,000 of transfers to personal and non-af iliated companies owned

and operated by Bello, combined with approximately $241,955.42 in purchases made by

Bello, completed depleted the $499,900 EIDL funds deposited into DOBIT Account

8123

All in violation of 18 U.S.C. § 1349.

COUNT 2

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

52. Paragraphs 1 - 51 of this First Superseding Indictment are realleged and

incorporated by reference as though fully set forth herein.

53. From approximately in or around April 2020, and continuing through the

date of this First Superseding Indictment, the exact dates being unknown to the Grand Jury,

in the Eastern District of Texas and elsewhere, the defendants,

OLAMIDE OLATAYO BELLO,
OLABODE THOMAS AJIBOLA, and
DUMBOR JOSEPHINE BARIBE

along with others, both known and unknown to the grand jury, did knowingly and willfully

conspire and agree to violate to violate 18 U.S.C. § 1957, to knowingly engage and attempt

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to engage in monetary transactions by, through, and to a financial institution, affecting

interstate and foreign commerce, in criminally derived properly of a value greater than

$10,000, such property having been derived from a specified unlawful activity, that is, wire

fraud, a violation of 18 U.S.C. § 1343.

All in violation of 18 U.S.C. § 1956(h).

NOTICE OF INTENT TO SEEK CRIMINAL FORFEITURE

Pursuant to 18 U.S.C. 981(a (1 (C) and 982(a)(1) and 28 U.S.C. § 2461

1. The allegations contained in Counts 1 and 2 of this First Superseding

Indictment are realleged and incorporated by reference as though folly set forth herein for

the purpose of alleging forfeiture to the United States of America of certain property in

which the defendant has an interest.

2. Upon conviction of any violation of 18 U.S.C. § 1349, the defendants shall

forfeit to the United States any prope ly, real or personal, that constitutes or is derived from

proceeds traceable to the offense(s), pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C.

§ 2461(c). The property, which is subject to forfeiture, includes but is not limited to, a

money judgment, and all interest and proceeds traceable thereto, representing the proceeds

of the offenses, for which the defendants are jointly and severally personally liable.

3. Upon conviction of any violation of 18 U.S.C. § 1956, the defendants shall

forfeit to the United States any properly, real or personal, involved in such offense, or any

properly traceable to such property, pursuant to 18 U.S.C. § 982(a)(1), including a money

judgment representing fonds involved in the offense.

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4. Pursuant to 21 U.S.C. § 853(p), as incorporated by reference by 18 U.S.C.

§ 982(b), if any of the forfeitable property, or any portion thereof, as a result of any act or

omission of the defendant:

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 subdivided

without difficulty;

it is the intent of the United States to seek the forfeiture of other property of the defendants

up to the value of the above-described forfeitable properties, including, but not limited to,

any identifiable property in the names of the defendants, pursuant to Title 21, United States

Code, Section 853(p), as incoi orated by Title 28, United States Code, Section 2461(c).

5. By virtue of the commission of the offenses alleged in this First Superseding

Indictment, any and all interest that the defendants have in the above-described property is

vested in the United States and hereby forfeited to the United States pursuant to 18 U.S.C.

§ 981(a)(1)(C), 18 U.S.C. § 982(a)(1), and 28 U.S.C. § 2461(c).

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All pursuant to 18 U.S.C. § 981(a)(1)(C), 18 U.S.C. § 982(a)(1), and 28 U.S.C.

§ 2461(c) and the procedures set forth at 21 U.S.C. § 853, as made applicable through 18

U.S.C. § 982(b)(1).

A TRUE BILL

GRAND JURY FOREPERSON
DAMIEN M. DIGGS
UNITED STATES ATTORNEY

SEAN J. TAYLOR Date
Assistant United States Attorney

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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
SHERMAN DIVISION

UNITED STATES OF AMERICA

v. Case No. 4:23CR136
Judge Mazzant
OLAMIDE OLATAYO BELLO (1)
OLABODE THOMAS AJIBOLA (2)
DUMBOR JOSEPHINE BARIBE (11)

NOTICE OF PENALTY

Count One

Violation: 18U.S.C. § 1349
(Conspiracy to Commit Wire Fraud)

Penalty: A fine of $250,000, or twice the pecuniary gain to the defendant or
loss of the victim(s), whichever is greater; imprisonment for not
more than 20 years; and a term of supervised release of not more
than 3 years.

Special
Assessment: $100

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Count Two

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

Penalty: A fine of $250,000, or twice the pecuniary gain to the defendant or
loss of the victim(s), whichever is greater; imprisonment for not
more than 10 years; and a term of supervised release of not more
than 3 years.

Special
Assessment: $100

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