Court filing — United States v. Elias Eldabbagh (Dkt. 20-1, D.D.C.)

Summary

Government Exhibit 1, filed January 25, 2022 as Document 20-1 in Case 1:21-cr-00523-TNM, in the case against Elias Eldabbagh. It reproduces a fax transmission of 9/28/2021 from the Fraud Prevention Unit of Citibank Delaware to E-TRADE Bank regarding a forged endorsement. The enclosed collection letter, dated 28-Sep-2021 with reference CIT210928-007950, concerns check number 991536681 dated 04/06/2021, issued to payee Elias Eldabbagh in the amount of $230024.22/USD. The exhibit is 4 pages.

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Case 1:21-cr-00523-TNM Document 20-1 Filed 01/25/22 Page 1 of 4
10/20/2021 22:3[illegible] FAX [illegible] 001
[illegible] 18:43 FAX 3023235250 CITI GCC DE 001
*********************
*** TX REPORT ***
*********************
TRANSMISSION OK
TX/RX NO 2529
CONNECTION TEL 18666500003
SUBADDRESS
CONNECTION ID
ST. TIME 09/28 18:41
USAGE T 02'04
PGS. SENT 5
RESULT OK
citi
Citi Delaware | A Subsidiary of Citigroup
Global Cash Management Services | 1 Penns Way
New Castle, DE 19720-000
To: E TRADE | From: DaPHNNE MINOR
External Phone: | Phone: (302) 324-6624
External Fax: 866-650-0003 | [struck through: Internal Fax: (302) 323-5462]
Date: 9/28/2021 | Number of Pages: [struck through: 3] 4
Regarding: FORGED ENDORSEMENT
Comments:
CIT210928-007950
Adding collection Letter
Daphnne Minor
Fraud Prevention Unit
Citibank Delaware
One Penn's Way
New Castle, DE 19720
302-324-6624
Pls Call
Daphnne Minor Fraud Prevention Unit Citibank Delaware One Penn's Way New Castle, DE 19720 302-324-6624 [printed upside down]
GOVERNMENT EXHIBIT 1
Case 1:21-cr-00523-TNM Document 20-1 Filed 01/25/22 Page 2 of 4
10/20/2021 22:3[illegible] 002
Page 1 of 2
citi
TO:
E-TRADE BANK
671 N. GLEBE RD
16TH FLOOR
ARLINGTON, VA 22203
ATTN FRAUD CHECK CLAIMS
FROM:
De Fraud Prevention And Control
Date: 28-Sep-2021
Our Reference: CIT210928-007950
Your Reference: NONE
Subject: Case Ref : CIT210928-007950 COLLECTION LETTER
Account Number: [redacted]2975
Account Name: CITIBANK NA CUSTOM OCS
Check Number: 991536681
Check Date: 04/06/2021
Issued Payee: ELIAS ELDABBAGH
Modified Payee:
In the amount of: $230024.22/USD
Claim Type: Forged Endorsement
Reference: Check(s) Returned Without Entry
Daphnne Minor Fraud Prevention Unit Citibank Delaware One Penn's Way New Castle, DE 19720 302-324-6624 [printed upside down]
Dear Sir or Madam:
We received the enclosed with advice of the claim type above.
We have enclosed the following information:
____ 1. Paid and cancelled check
__X__ 2. Copy of paid check
__X__ 3. Affidavit/Death Certificate
____ 4. Other Information
We would appreciate your reimbursing us as promptly as possible unless you are in a position to furnish
us with conclusive evidence that the payment has been properly effected.
https://stars-amer.nsroot.net/prweb/SSOServlet/bh0n2xM4-RSrcGzLbeMYQtPTCBPJsHhl... 9/28/2021
Case 1:21-cr-00523-TNM Document 20-1 Filed 01/25/22 Page 3 of 4
10/20/2021 22:3[illegible] 003
Check Image Results Page 1 of 1
CitiDirect Check Image Delivery
citi
Print Close Window
Check Image Inquiry Results
Account # [redacted]2975 | Check # 991536681 | Amount $230,024.22 | Paid Date 04/15/2021 | Sequence # 1200722166
citibank Citibank 1000 Technology Drive, MS 707 O'Fallon, MO 63368 1-800-685-0035
88-20/311 No. 991536681 04/06/21
MEMO CLOSE *******2045
PAY EXACTLY: $230,024.22
PAY EXACTLY: TWO HUNDRED THIRTY T[illegible]WENTY FOUR AND 22/100 DOLLARS
TO THE ORDER OF: ELIAS ELDABBAGH
CITIBANK, N.A. ONE PENNS WAY, NEW CASTLE, DE 19720
[signature] AUTHORIZED SIGNATURE
⑈991536681⑈ ⑆031100209⑆ [redacted]2975⑈
ETRADE FINANCIALS ETRADE
ISN# 019685000006
Date 4/14/2021
46771226
C012-6609CS 10-20
9669560
PAYEE'S ENDORSEMENT (stamp, printed sideways): Elias Eldabbagh / For [illegible] only / to Etrade [illegible] [signature]
PAYEE'S ENDORSEMENT / DO NOT WRITE, STAMP OR SIGN BELOW THIS LINE (stamp legend, small print, partly [illegible])
CIT210928-007950
256072691
Citigroup.com Terms of Use Privacy
Copyright © 2003 -2021 Citigroup Inc.
This is a photographic facsimile of the original item, which is unavailable, destroyed or lost. Upon payment of this facsimile we agree to hold your bank harmless from any loss suffered as a result of payment of this facsimile in lieu of the original. Citibank, N.A.
https://citidirectbeportalnam.citidirect.com/proxy/PRXYSER5/root/AFNEAR85Web/servl... 9/28/2021
Case 1:21-cr-00523-TNM Document 20-1 Filed 01/25/22 Page 4 of 4
10/20/2021 22:3[illegible] FAX [illegible] 004
AFFIDAVIT OF FORGERY, ALTERATION, COUNTERFEIT OR UNAUTHORIZED REMOTELY CREATED CHECK PLEASE PRINT LEGIBLY
citibank
Do not use for counterfeit official checks or money orders.
Claimant Name (Business or Individual): ELIAS ELDABBAGH | Account Number: [redacted]2045
Street Address: 2021 L ST NW STE 101-319 | Home Telephone Number: (202) 746-8000
City, State, Zip, Country: WASHINGTON DC 20036 | Business Telephone Number: ( - X - ) - - - - - - - - -
[illegible]
☐ Remotely Created Check | ● Forgery ○ Alteration ○ Counterfeit
☒ Check | Date: 04/06/21 | Check/Serial #: 991536681 | Amount: $230,024.22 | For additional checks, complete the Addendum to Affidavit of Forgery. Is Addendum attached? ☐ Yes ☒ No
Drawer (i.e., maker): CITIBANK | Payable to the Order of: ELIAS ELDABBAGH
This Claim involves a Substitute Check* ☐ Yes ☒ No
*A substitute check is a paper reproduction of the original check that contains an image of the front and back of the original check and bears a legend, "Is a legal copy of your check."
☐ Official Check ○ Forgery ○ Alteration | Date Purchased: | Check/Serial #: | Purchaser Name:
☐ Money Order ○ Lost / Never Received (Must select "Endorsement Forged/Unauthorized" below) | Amount: $ | Payee Name:
☐ In-Branch Withdrawal | Date: | Amount: $ | For additional withdrawals, complete the Addendum to Affidavit of Forgery. Is Addendum attached? ☐ Yes ☐ No
[illegible]
The items described above were improperly paid because of a(n) (Check all that apply):
☐ Drawer's Signature Forged/Unauthorized
The drawer's signature of ______ (drawer's name) on the check or withdrawal order is a forgery or is unauthorized. I did not sign and I did not authorize the signature.
☒ Endorsement Forged / Unauthorized
The Endorsement of ELIAS ELDABBAGH (payee's name) on the above check is a forgery. I did not write or authorize the endorsement.
☐ Check (or Remotely Created Check) Amount/Payee Name Altered
The amount of the above check was raised from the original amount of $______ (amount) to $______ (amount). I did not raise the amount of the check and I did not authorize that it be raised. I received no part of the amount of item in excess of the original amount, nor was any part of the excess amount applied to any use or purpose on my behalf.
An unknown person altered the payee's name on the check to make it payable to the order of: ______. I did not alter the payee's name and I did not authorize any alteration.
☐ Counterfeit Check
This check is a counterfeit and was not authorized by me. I received no benefit from the payment of this check.
☐ Unauthorized Remotely Created Check
The remotely created check was not authorized by me and I received no benefit from the issuance of this transaction. The person who issued the remotely created check is not authorized to use the account.
[illegible]
1. I did not receive any benefit or value from proceeds of the check/withdrawal order, and proceeds were not used for any purpose on my behalf.
2. I have not arranged with the person(s) who forged/altered the check/withdrawal order to be reimbursed for proceeds of the check/withdrawal order. I do not carry any insurance applicable to the loss resulting from the forgery/alteration. I suspect: UNKNOWN (Suspect Name) of, UNKNOWN (Suspect Address), of having forged or altered the item(s) described in this Affidavit, as I have stated above. I believe this person did this under the following circumstance: UNKNOWN
3. I, the Claimant, was not negligent in contributing to the forgery/alteration and discovered the forgery/ alteration on MAY 1, 2021 (date), under the following circumstances: WHEN REQUESTED CHECK FOR BALANCE OF CLOESED ACCOUNT
4. If applicable, I am the payee of the check(s). The check(s) were delivered to me under the following circumstances: ISSUED FOR CLOSURE OF ACCOUNT #[redacted]2045
5. I understand that Citibank is a federally insured bank and that my making any false statements to Citibank in connection with my claims, or to induce Citibank to rely upon those statements, is a crime. I also understand that Citibank or other persons or entities, such as law enforcement may require my assistance in connection with any criminal or civil prosecution of the wrongdoer(s). Should that arise, I agree to cooperate fully, including the giving of testimony and appearing at a trial. Should I refuse to cooperate, Citibank may revoke any settlement it offered or paid to me, including charging the amount of any settlement to any account I hold at Citibank.
6. I declare under penalty of perjury under the laws of the State of DC (State) that the foregoing is true and correct.
Claimant's Signature: X [signature] | Date: 9/15/2021 | If Claimant is a Business, Print Name/Title of Authorized Signer: —
State of District of Columbia
County of District of Columbia
Subscribed and sworn to (or affirmed) before me on this 15th day of September, 2021
by Elias Eldabbagh, personally known to me or proved to me on the basis of satisfactory evidence to be the person(s) who appeared before me.
Notary Seal: [illegible] HOOD NOTARY PUBLIC DISTRICT OF COLUMBIA MY COMMISSION EXPIRES 11/30/2025
[signature] Notary Public Signature
District of Columbia
Signed and sworn to (or affirmed) before me on 9/15/2021 by Elias Eldabbagh
Date | Name(s) of individual(s) making Statement
[signature] Signature of Notarial Officer
Notary Public
Title of Office
My commission expires: 11/30/2025
© 2013 Citibank
Citibank, N.A. Member FDIC
GOVERNMENT EXHIBIT 1


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