Declaration of Special Agent Rickey - United States v. Cassie Will-Darnall (Document 80)
Summary
Declaration of Special Agent Rickey, Document 80 in United States v. Cassie Will-Darnall, Case No. 5:24-cr-00292-PCP, in the U.S. District Court for the Northern District of California, filed July 25, 2025. The declarant, a Special Agent with the Internal Revenue Service, Criminal Investigation, states that the agent worked on the investigation of Reed and his company, Asset Protection Group (APG), and reviewed certain investigation files on July 18, 2025. The declaration states that Cassie Will is listed as an APG consultant in some of those files, including for Westward Properties, and separately for Louis Holdings and Wealth Protection, entities associated with APG "friendly liens" created or purchased from June 2004 through October 2005. It also states what an APG consultant is.
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“Declaration of Special Agent Rickey - United States v. Cassie Will-Darnall (Document 80).”
Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-cand-430212-80-0-a4841b991e/
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Case 5:24-cr-00292-PCP Document 80 Filed 07/25/25 Page 1 of 2
1 CRAIG H. MISSAKIAN (CABN 125202)
United States Attorney
2
MARTHA BOERSCH (CABN 126569)
3 Chief, Criminal Division
4 GALEN A. PHILLIPS (CABN 307644)
Assistant United States Attorney
5
450 Golden Gate Avenue, Box 36055
6 San Francisco, California 94102-3495
Telephone: (415) 436-7110
7 Email: Galen.Phillips@usdoj.gov
8 Attorneys for United States of America
9 UNITED STATES DISTRICT COURT
10 NORTHERN DISTRICT OF CALIFORNIA
11 SAN JOSE DIVISION
12
UNITED STATES OF AMERICA, ) CASE NO. CR-24-00292-PCP
13 )
Plaintiff, ) DECLARATION OF
14 ) SPECIAL AGENT RICKEY
v. )
15 )
CASSIE WILL-DARNALL, )
16 )
Defendant. )
17 )
SANDRA WILL, )
18 )
)
19 Third Party Petitioner. )
)
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RICKEY DECLARATION
CR-24-00292-PCP
Case 5:24-cr-00292-PCP Document 80 Filed 07/25/25 Page 2 of 2
1 I, Ryan D. Rickey, declare and state as follows:
2 1. I am a Special Agent with the Internal Revenue Service, Criminal Investigation, a
3 position I have held since 2007.
4 2. The facts set forth in this declaration are based on my personal knowledge and
5 information I received from other law enforcement personnel. In my role as a Special Agent, I worked
6 on the investigation of William S. Reed and his company, Asset Protection Group (APG).
7 3. On Friday, July 18, 2025, I reviewed certain files collected during the investigation of
8 Reed and APG.
9 4. Cassie Will is listed as a consultant of APG in some of those files, including for
10 Westward Properties, Inc.
11 5. Cassie Will is separately listed in APG’s files as serving as a consultant for Louis
12 Holdings and Wealth Protection, Inc—entities associated with APG “friendly liens” that were created or
13 purchased from June 2004 through October 2005.
14 6. I know from my work on the investigation that an APG consultant is someone who paid
15 for access to APG’s marketing materials. Consultants could sign up clients for APG and sell them
16 APG’s various products and services directly, receiving a cut of the sales for their referrals.
17
18 I swear under penalty of perjury that the foregoing is true and correct.
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Executed on: July 25, 2025
20 RYAN D. RICKEY
Special Agent
21 Internal Revenue Service,
Criminal Investigation
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RICKEY DECLARATION
CR-24-00292-PCP 1
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