Redacted Complaint, United States v. Jorge Armando Contreras, No. 8:23-cr-00154 (C.D. Cal.), Doc. 12 (October 12, 2023)
Summary
A redacted criminal complaint, Doc. 12 filed October 12, 2023, in United States v. Jorge Armando Contreras, No. 8:23-cr-00154, in the United States District Court for the Central District of California, with an affidavit of FBI Special Agent Timothy W. Bamford. The complaint cites 18 U.S.C. § 666(a)(1)(A), embezzlement concerning programs receiving federal funds. The affidavit alleges that Contreras, the Director and later Senior Director, Fiscal Services, of the Magnolia School District, embezzled over $14 million through over 250 checks from School District funds that were deposited into a personal bank account. The affidavit supports an arrest warrant and search warrants for a residence, a vehicle and persons.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Cite this document
“Redacted Complaint, United States v. Jorge Armando Contreras, No. 8:23-cr-00154 (C.D. Cal.), Doc. 12 (October 12, 2023).”
Original at storage.courtlistener.com. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/redacted-complaint-united-states-v-jorge-armando-contreras-no-8-23-cr-0a711d08ea/
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Case 8:23-cr-00154-FWS Document 12 Filed 10/12/23 Page 1 of 44 Page ID #:68
AO 91 (Rey. 11/11) Crunuial Complanit(Rey. by USAO on 3/1?/20) O Original
REDACTED
❑Duplicate Original
L ODGED
UNITED STATES DISTRICT COURT
FILED
CLERK U.S. DISTRICT COURT C12wc.ua ustacT courtr
for the
10/12/2023 10/12/2023
CENTRAL DISTRICT OF CJILIFORNIA
BY: DVE DEPUTY Cenh•al District of Califon~ia m~n~►L oarocr as cu~mwe
United States of America
v.
Case No. 8:23-mj-00513-DUTY
Jorge Armando Contreras,
Defeudant(s)
CRIMINAL COMPLAINT BY TELEPHONE
OR OTHER RELIABLE ELECTRONIC MEANS
I, the couiplaivaut iu this case, state that the following is true to the best of uiy luiowledge and Uelief.
On or about the dates) of August 24, 2022 to July 26, 2023 iu the comity of Orange in the Central Dish~ict of
California, the defendant violated:
Code SeNion Offense Description
18 U.S.C. ~ 666(a)(1)(A) Eiubezzlemeut couceniing programs
receiving federal fiords
This criiuival complaint is based ou these facts:
Please see al~ncl►ed n~dm~it.
D Continued ou tl~e attached street.
~~
Compininnn►'s signn~rn•e
Tuuothy W. Ba~uford, FBI Special A~tent
Printed Home mid title
Attested to by the applicant in accordance with the requirements of Fed. R. Cri~P. 4.1 U telephone.
Date: October 12, 2023 ~ i
Judge's signnlure
City and state: Santa Ana, CA " -on. -o' u ~. ~ar'y, "".~ ' "aR~strate "u'~e
P~7n~ed »nme nncl tide
AUSA: Billy Joe McLain, 213-894-6702
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ATTACf~II~NT A-1
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ATTACfIMENT A-2
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ATTACFIMENT A-3
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ATTACFII~NT A-4
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AFFIDAVIT
I, Timothy Warren Bamford, being duly sworn, declare and
state as follows:
I. INTRODUCTION
1. I am a Special Agent ("SA") for the Federal Bureau of
Investigation ("FBI") and have been so employed since June 2022.
I am currently assigned to the Los Angeles Field Office's Orange
County Resident Agency. My duties include, investigating
federal fraud crimes, such as wire fraud, mail fraud, honest
services fraud, money laundering, and embezzlement, among other
federal criminal violations. I received about 18 weeks of
formal training in investigative techniques and financial crimes
at the FBI Academy in Quantico, Virginia. Additionally, since
October of 2022, I have worked on a public corruption and health
care fraud squad at the FBI, where I have been working with
other experienced FBI agents and analysts, as well as other law
enforcement agents, while investigating federal fraud and public
corruption offenses. During this time, I've received on-the-job
training while working with these agents and analysts. Prior to
my service with the FBI, I was a police officer for the Federal
Reserve Bank of Boston, Massachusetts for six years. In 2021, I
graduated from New England Law, Boston and passed the
Massachusetts bar exam. I have previously assisted in the
execution of numerous federal search and arrest warrants.
1
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II. PURPOSE OF THE AFFIDAVIT
2. This affidavit is made in support of a criminal
complaint against, and arrest warrant for, JORGE ARMANDO
CONTRERAS ("CONTRERAS") for a violation of Title 18, United
States Code, Section 666(a)(1)(A) (embezzlement concerning
programs receiving federal funds).
3. This affidavit is also made in support of search
warrants for the below premises, vehicle, and persons, further
described in Attachments A-1 to A-4, for the items to be seized
described in Attachment B, which are the evidence, fruits, and
instrumentalities of violations of Title 18, United States Code,
Section 666(a)(1)(A) (embezzlement concerning programs receiving
federal funds); Section 1956 (money laundering); Section 1957
(engaging in monetary transactions in property derived from
specified unlawful activity); and Section 371 (conspiracy to
commit the foregoing crimes)(the "Subject Offenses"):
a. The residence located at
(the ~~SUBJECT PREMISES"), as more
fully described in Attachment A-1;
b. A 2021 BMW X5, ,-
(~~SUBJECT VEHICLE"), as more fully described in
Attachment A-2;
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c. The person of CONTRERAS, as more fully described
in Attachment A-3, including any digital devices found on
CONTRERAS's person or within his immediate reach;
d.
4. The facts set forth in this affidavit are based upon
my personal observations, including documents and data I have
reviewed while investigating this case, my training and
experience, and information obtained from various law
enforcement personnel as well as witnesses who have been
interviewed during the investigation of this case. This
affidavit is intended to show merely that there is sufficient
probable cause for the requested complaint, arrest warrant, and
search warrants, 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, all amounts or sums are approximate, and all
dates and times are on or about those indicated.
III. SUbIl~ARY OF PROBABLE CAUSE
5. The Magnolia School District (the "School District")
is a publicly funded organization that includes numerous schools
in the cities of Anaheim and Stanton, California. These schools
educate children from preschool through the sixth grade - 81
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percent of whom are classified as socio-economically
disadvantaged. Each year, since 2009, the School District has
received millions of dollars in federal funds.
6. Since 2013, CONTRERAS, the Director and then Senior
Director, Fiscal Services, for the School District, managed its
fiscal operations, and has embezzled over $14 million dollars
from the School District by making unauthorized payments to
himself from School District funds. These payments came from
over 250 checks from the School District that were deposited
into CONTRERAS's personal bank account.
7. Focusing just on the last year, between August 24,
2022 and July 31, 2023, CONTRERAS embezzled over $4_.1 million
dollars from the School District. In fact, about 93 percent of
all deposits in CONTRERAS's personal Wells Fargo bank account
ending in 2435 ("CONTRERAS's Wells Fargo Account") during this
time period were from embezzled funds from the School District.
Additionally, during this time period, payments made from
CONTRERAS's Wells Fargo Account included over $1.9 million
dollars paid to American Express, $325,000 withdrawn from ATMs,
and over $130,000 transferred to his partner, who
CONTRERAS recently married in August 2023.
8. In furtherance of this scheme, CONTRERAS used the
SUBJECT VEHICLE, which he purchased with funds from CONTRERAS's
Wells Fargo Account, to deposit embezzled funds from the School
District — at Drive Thru ATMs — into CONTRERAS's Wells Fargo
Account.
n
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9. In 2020, CONTRERAS purchased the SUBJECT PREMISES for
about $1.5 million dollars, paid for over a million dollars of
it via a wire transfer from CONTRERAS's Wells Fargo Account, and
altered bank statements submitted as part of the loan
application to hide funds embezzled from the School District.
IV. STATEMENT OF PROBABLE CAUSE
10. Based on bank records, records and data from the
School District, witness interviews, my training and experience,
and information obtained from law enforcement agents and
analysts investigating this case, I am aware of the following:
A. The School District and CONTRERAS's Management of the
School District's Finds.
11. According to records provided by the School District,
during fiscal years 2020-2021, 2021-2022, and 2022-2023, the
School District received over $10 million dollars in federal
funding for each year. Additionally, the School District
received over $2 million dollars in federal funding each fiscal
year from fiscal year 2008-2009 through fiscal year 2019-2020.1
12. CONTRERAS has worked within the School District since
2006. He was placed on administrative leave without pay in
August 2023.2 Between 2009 and 2022, CONTRERAS's annual salary
1 Embezzlement concerning programs receiving federal funds, 18
U.S.C. ~ 666(a)(1)(A), requires, among other things, that "the
organization, government, or agency [from which "property" is
embezzled] receives, in any one year period, benefits in excess
of $10,000 under a Federal program involving a grant, contract,
subsidy, loan, guarantee, insurance, or other form of Federal
assistance." Id. at ~ 666(b).
2 On August 14, 2023, the School District filed a civil complaint
against CONTRERAS for conversion and fraud, among other things.
In September 2023, CONTRERAS's Wells Fargo Account was frozen
(footnote cont'd on next page)
5
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increased incrementally from about $50,000 per year to about
$220,000 per year.
13. Since about 2013, CONTRERAS has served as the
Director, Fiscal Services, for the School District. In 2017,
his title was changed to Senior Director, Fiscal Services. In
that position, CONTRERAS has managed School District funds and
has written checks from certain funds, including funds in
various School District bank accounts, such as the School
District's revolving cash funds account with Bank of the West
ending in 4043 (the "MSD Cash Funds Account") and the student
body account, also with Bank of the West, ending in 3714 ("MSD
Student Body Account").
14. According to School District Chief Business Official
( ~~CBO-"), checks were often
written from the MSD Cash Funds Account for small payments, such
as payroll mistakes, and the MSD Student Body Account was used
for fundraising.
B. CONTRERAS Embezzled Millions of Dollars from the
School District.
15. According to Wells Fargo bank records, between August
29, 2016 and July 31, 2023, over $14 million dollars was
deposited into CONTRERAS's Wells Fargo Account from the MSD Cash
Funds Account and the MSD Student Body Account. These $14
pursuant to a civil temporary restraining order. On October 10,
2023, an attorney for the School District told FBI Special Agent
Ignacio Ramos that CONTRERAS is represented by Kim Schumann in
the School District's civil suit, and Mr. Schumann had informed
her that CONTRERAS is also being represented by a criminal
lawyer, whose name she does not know. A Google search shows Mr.
Schumann is a partner at the law firm Schumann Arevalo LLP.
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million dollars came from over 250 checks, all of which were
made out to someone other than CONTRERAS. And the money from
these transactions comprised more than 83 percent of all
deposits into CONTRERAS's Wells Fargo Account between August 29,
?016 and July 31, 2023.
16. Focusing on the last year, Wells Fargo Bank records
show that between August 24, 20?? and July 31, 2023, over $4.1
million dollars from the MSD Cash Funds Account was deposited
into CONTRERAS's Wells Fargo Account. These checks ranged from
about $11,000 to about $95,000. And all these checks listed the
payee as "Maria Socorro Dominguez" or "Magnia Socorro
Dominguez." According to CBO and Superintendent _
-("Superintendent -"), there is no record of a
"Maria Socorro Dominguez" or "Magnia Socorro Dominguez" working
at the School District.
17. According to Wells Fargo bank records and Bank i~f the
West records, these checks were deposited via ATM into
CONTRERAS's Wells Fargo Account. In fact, Wells Fargo bank
photographs show an individual, who matches CONTRERAS's DMV
picture, depositing some of these checks into CONTRERAS's Wells
Fargo Account at ATMs. For example, the below photographs of
CONTRERAS making RTM deposits into CONTRERAS's Wells Fargo
Account temporally line up with the following checks from the
School District written to payee "Maria Socorro Dominguez":
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a. On April 27, 2023, ATM Deposit at the Wells Fargo
Branch located on 141 W. Bastanchury Road, Fullerton, CA for
$73,500:
b. On June 8, 2023, ATM Deposit at the Wells Fargo
Branch located on 230 S. State College Blvd., Brea, CA for
$85, 350:
:~
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c. On July 25, 2023, ATM Deposit at the Wells Fargo
Branch located on 230 S. State College Blvd., Brea, CA for
$89,150:3
18. According to CBO-,while he and CONTRERAS were
working together, CONTRERAS would ask for CBO -'s signature
on checks from the MSD Cash Funds Account. CBO -'s
signature was required for checks written from the MSD Cash
Funds Account. But the amounts on those checks were typically
smaller amounts (less than $2,000) consistent with checks from a
petty-cash fund, not tens of thousands of dollars that are seen
on the checks that were ultimately deposited into CONTRERAS's
Wells Fargo Account. Moreover, according to CBO-,the
checks CONTRERAS presented him for signature often listed the
payee as only "M S D" with the letters spaced apart. Based
on this information, it appears that CONTRERAS would, at least
3 The photographs from June 8 and July 25, 2023 show CONTRERAS
making ATM deposits in the SUBJECT VEHICLE.
7
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on several occasions, alter/increase the amount of a check and
modify the payee of a check (e.g., by filling in "M S D"
with "Maria Socorro Dominquez" or a similar name) after
obtaining CBO -'s signature.
C. CONTRERAS Falsified Documents to Cover His
Embezzlement from the School District.
19. According to CBO-,CONTRERAS was responsible for
conducting bank reconciliations of the MSD Cash Funds Account
for the School District. A bank reconciliation is a process by
which the School District compares balances and transactions on
their external bank statements with balances and transactions on
the School District's internal ledgers. As part of his duties
for the School District, CONTRERAS submitted reconciliation
packets to CBO
- for review every six months. The bank
reconciliation packet included a cover sheet, a bank statement
from Bank of the West (which is the School District's bank), and
documentation to justify checks written from the MSD Cash Funds
Account.
20. According to Superintendent-,after Wells Fargo
notified the School District about potential fraud regarding the
MSD Cash Funds Account in August ?023, he searched CONTRERAS's
office and discovered altered MSD Cash Funds Account bank
statements. For example, a comparison of the MSD Cash Funds
Account statement from June ?023 received from Bank of the West
reflected an ending balance of over $1.2 million dollars,
whereas the School District's internal bank statement from the
same MSD Cash Funds Account from June 2023 reflected an ending
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balance of about $50,000. CONTRERAS signed the cover sheet
certifying the accuracy of the internal bank statements, which
were submitted as part of the reconciliation packet.
21. What's more, agents investigating this case and I have
reviewed additional bank reconciliation documentation from the
School District between July 2022 and June 2023. During this
time period, the School District's internal bank statements
regarding the Cash Funds Account were generally around $50,000,
while the Bank of the West statements for the Cash Funds Account
reflected a different ending balance, which were generally much
higher than $50,000, and ranged between about $62,000 and $1.2
million.4 Indeed, the average monthly ending balance of the Bank
of the West statements for the Cash Funds Account over that 11-
month time period was about $317,000. Again, CONTRERAS signed
the cover sheet certifying the accuracy of these internal bank
statements, which were submitted as part of the reconciliation
packet.
22. According to Superintendent and CBO —,
the balance for the MSD Cash Funds Account was not supposed to
exceed about $50,000 — consistent with the MSD Cash Funds
Account's limited purpose of serving as a petty-cash account.
Based on this information, and my training and experience as
well as the training and experience of other agents
investigating this case, it appears that CONTRERAS was
falsifying bank statements that were shown to other School
4 One statement from Bank of the West for the Cash Funds Account
-November 2022 - is an exception. The statement ending balance
for that month was $34,833.82.
11
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District officials during the reconciliation process to reflect
a smaller balance in the MSD Cash Funds Account, which would
help hide his embezzlement of money from the MSD Cash Funds
Account.
D. CONTRERAS Spends Finds from CONTRERAS's Wells Fargo
Account on Cosmetic Treatment, the SUBJECT VEHICLE,
the SUBJECT PREMISES, Designer Clothes, and Transfers
Some of Those Ends to Another Account s
23. According to Wells Fargo records, between August 24,
2022 and July 31, 2023, about $4.4 million dollars in total
deposits (including deposits that were not checks from the MSD
Cash Funds Account) were made to CONTRERAS's Wells Fargo
Account.
24. Of the $4.4 million dollars deposited in CONTRERAS's
Wells Fargo Account, over $4.1 million dollars was deposited
from checks written from the MSD Cash Funds Account to "Maria
Socorro Dominguez" and "Magnia Socorro Dominguez." In other
words, about 93 percent of all deposits in CONTRERAS's Wells
Fargo account between August 24, 2022 and July 31, 2023 were
deposits from the MSD Cash Funds Account.
25. During this same time period (August 24, 2022 to July
31, 2023), Wells Fargo records show the following transactions:
a. Over $25,000 paid to Louis Vuitton,6 over $1.9
5 Money laundering, under 18 U.S.C. ~ 1957(a), requires, among
other things, that a person "knowingly engages or attempts to
engage in a monetary transaction in criminally derived property
of a value greater than $10,000 and is derived from specified
unlawful activity." Id.
6 The beneficiary of the payments, according to bank records, is
listed as ~~LOUIS VUITTON ESER" or ~~Louis Vuitton USA."
12
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million dollars paid to American Express,' and over $325,000
withdrawn from ATMs. Additionally, CONTRERAS made multiple wire
transfers totaling over $190,000 to a medical doctor with the
initials J.E. The wire transfers ranged from about $8,000 to
$90,000. A Google search revealed that J.E. is a cosmetic
dermatologist and surgeon in West Hollywood, California. Based
on this information, it appears that CONTRERAS spent this money
on cosmetic treatment. More still, Wells Fargo bank and JP
Morgan Chase records show that on July 28, 2023, CONTRERAS wrote
check #4829 from the Wells Fargo Account payable to himself for
$150,000. The memo section of the check states for `New
Account." This check was used to open two new bank accounts at
JPMorgan Chase.
26. In addition to the payments directly from CONTRERAS's
Wells Fargo Account, during this same time period (August 24,
2022 to July 31, 2023), CONTRERAS's American Express account was
charged over:
a. $60,000 at Louis Vuitton stores, including the
following transactions:
Date Amount Merchant
11/18/2022 $28,247.15 LOUIS VUITTON
#142
12/29/2022 $28,497.22 LOUIS VUITTON
#142
Multiple payments to American Express exceeded $10,000.
13
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b. $350,000 at Gianni Versace boutiques, including
the following transactions:
Date Amount Merchant
8/26/2022 $36,764.31 GIANNI VERSACE
BOUTIQUE -
9/16/2022 $29,194.87 GIANNI VERSACE
BOUTIQUE -
9/30/2022 $30,350.28 GIANNI VERSACE
BOUTIQUE -
10/16/2022 $26,230.78 GIANNI VERSACE
BOUTIQUE -
11/13/2022 $38,967.80 GIANNI VERSACE
BOUTIQUE -
12/10/2022 $49,713.17 GIANNI VERSACE
BOUTIQUE -
2/26/2023 $50,803.07 GIANNI VERSACE
BOUTIQUE -
3/18/2023 $15,503.41 GIANNI VERSACE
BOUTIQUE -
4/1/2023 $11,525.00 GIANNI VERSACE
BOUTIQUE -
4/16/2023 $18,694.64 GIANNI VERSACE
BOUTIQUE -
4/29/2023 $36,925.95 GIANNI VERSACE
BOUTIQUE -
5/28/2023 $15,462.14 GIANNI VERSACE
BOUTIQUE -
c. $180,000 at David Yurman jewelry store, including
the following transactions:
Date Amount Merchant
6/3/2023 $72,946.75 DAVID YURMAN
RETAIL
6/17/2023 $112,146.20 DAVID YURMAN
RETAIL
E. CONTRERAS Used Finds from CONTRERAS's Wells Fargo
Account to Purchase the SUBJECT VEHICLE.
27. According to Wells Fargo and BMW records, on February
11, 2021, CONTRERAS purchased the SUBJECT VEHICLE for about
14
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$127,000. CONTRERAS made an $80,000 downpayment from
CONTRERAS's Wells Fargo Account, which he also used to pay off
the remaining balance in July 2022.
F. CONTRERAS Used Ends from CONTRERAS's Wells Fargo
Account to Purchase the SUBJECT PREMISES and Falsified
Mortgage Loan Documents.
28. According to Wells Fargo, mortgage records, and escrow
records, on July 27, 2020, CONTRERAS applied for a loan in the
amount of $350,000 to purchase the SUBJECT PREMISES. The
SUBJECT PREMISES was purchased for about $1.5 million dollars.
On the loan application, CONTRERAS stated that his gross monthly
income was $16,507 (about $198,084 a year) as the Senior
Director of the Magnolia School District. On July 24, 2020,
CONTRERAS wire transferred $1,146,500 from CONTRERAS's Wells
Fargo Account to Escrow Experts Inc. Trust account for the final
payment to close escrow and purchase the SUBJECT PREMISES.
29. The loan application included a June 2020 bank
statement from CONTRERAS's Wells Fargo Account. A comparison of
the June 2020 bank statement included in the loan application
and a June 2020 bank statement that agents investigating this
case received from Wells Fargo, shows a discrepancy between the
two bank statements.
30. More specifically, the June 2020 bank statement
submitted as part of the loan application shows, among other
things, an ATM deposit on June 22, 2020 for $8,660.99 and a
total deposit amount for that statement period of $18,911.95.
By contrast, the same June 2020 bank statement received from
Wells Fargo shows an ATM deposit on June 22, 2020 of $98,660.99
15
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and a total deposit amount for that statement period of
$108,911.95. A further review of the source of the June 22,
2020 deposit that was altered in the submission for the loan
application shows that it was three checks from the School
District (check #10125 for $60,802.57, check #10126 for
$25,806.85, and check #10127 for $12,051.57), all of which were
made payable to "Maria S. Dominguez." From my training and
experience, and the experience of other agents investigating
this case, it appears that CONTRERAS altered the bank statement
he submitted as part of the loan application to purchase the
SUBJECT PREMISES. This would help avoid any questions from the
bank about a $98,660.99 ATM deposit, made payable to someone
other than CONTRERAS, which may have uncovered CONTRERAS's
embezzlement scheme.
G. CONTRERAS Transferred Ends to Mexico.
31. Between November 2018 and May 2023, CONTRERAS wired
over $150,000 to multiple banks in Mexico from CONTRERAS's Wells
Fargo Account. Wells Fargo wires include a detail section to
allow the sender to enter a note for each wire. Many of the
notes on CONTRERAS's wires were related to construction
projects, payments for services, and purchases. For example, a
wire transferred in November 2018 in the amount of $3,133.38,
included the memo "building home;" a wire transferred in March
2020 in the amount of $5,000, included the memo "Construction
doors stairs and window;" and a wire transferred in November
2022 in the amount of $5,000, included the memo "luxury
jackets."
E
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H. JC Productions.
32. According to CBO _,JC Productions is CONTRERAS's
musical production company.e On September 29, 2023, the
Instagram page for "Jorge Armando Contreras @JCproductionsl"
(~~CONTRERAS's Instagram Account") had about 2.7 million
Instagram followers and stated, next to a photograph of
CONTRERAS, ~~JCProductions, the best musical productions and live
events."9 The Instagram page showed numerous posts of musical
events along with photographs of CONTRERAS, in designer clothes,
such as that pictured below:
'
f
ur.
.~,~wr
~
~~4
,
e According to Orange County Clerk Recorder website, on October
5, 2018, CONTRERAS filed a fictitious business name with the
Orange County clerk recorder for JC Productions.
9 This is an English translation. The original version states,
`~JCProductions, las mejores producciones musicales y eventos en
vivo."
17
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33. According to CBO-,CONTRERAS appeared to live a
lifestyle beyond the means of someone in his position at the
School District. CBO assumed CONTRERAS's source of
additional income was from JC Productions. For example, CBO
_ explained there had been a billboard of JC Productions
promoting an artist, with the initials W.G., that was within the
School District's territory. CBO also explained that one
year, during the December holidays, CONTRERAS gave school
district employees $25 Starbucks gift cards with writing on the
back of those cards stating they were from JC Productions.
34. Although Wells Fargo records show deposits into
CONTRERAS's Wells Fargo Account that appear to be related to, or
that reference, JC Productions,l~ over 83 percent of deposits
into CONTRERAS's Wells Fargo Account from August 29, ?016 to
July 31, 2023 (over $14 million dollars) were checks from the
MSD Cash Funds Account and MSD Student Body Account.11 Based on
the above facts, as well as my training and experience and that
to For example, agents investigating this case and I have
reviewed Wells Fargo bank records from August 29, 2016 to July
31, 2023, and we have identified transfers from PayPal, Ticketon
Entertainment, M3 Live, and E1 Crillon LLC, among others, some
of which reference JC Productions and some of which do not.
Additionally, I have identified in SchoolsFirst Federal Credit
Union records, September 2018 transfers from M3 Live to a
SchoolsFirst account that belongs to CONTRERAS. These types of
transfers that agents and I have identified at this point in
Wells Fargo and SchoolsFirst records total about $509,000.
11 Other deposits during that timeframe include about $763,378 in
direct deposits (salary) from the School District, about
$613,511 from an escrow deposit, and about $500,000 from
CONTRERAS's Wells Fargo savings account ending in 3046, see
infra.
Case 8:23-cr-00154-FWS Document 12 Filed 10/12/23 Page 35 of 44 Page ID #:102
of other agents investigating this case, it appears that JC
Productions served, at least in part, as a "front" company to
help explain CONTRERAS's apparent wealth and further conceal
CONTRERAS's embezzlement scheme.
I. CONTRERAS Transferred Ends Between His Accounts and
Attempted to Transfer Funds into Another Person's Bank
Account.
35. Between August 1, 2016 and July 31, 2023, over $1.6
million dollars in checks (that came from the MSD Cash Funds
Account and the MSD Student Body Account) were deposited into a
Wells Fargo savings account ending in 3046, which CONTRERAS had
opened in March 1991 ("CONTRERAS's Wells Fargo Savings
Account"). Wells Fargo Bank records show that during this time
period (August 1, 2016 to July 31, 2023),12 CONTRERAS had
transferred hundreds of thousands of dollars between different
Wells Fargo bank accounts belonging to or otherwise associated
with CONTRERAS, including transfers to and from CONTRERAS's
Wells Fargo Account and CONTRERAS's Wells Fargo Savings Account.
36. For example, in October 2018, CONTRERAS opened a Wells
Fargo Advisors brokerage account ending in 9533 (`~CONTRERAS's
Wells Fargo Brokerage Account") with $500,000 of funds, which
were transferred from CONTRERAS's Wells Fargo Savings Account.
37. What's more, on August 4, 2023, Wells Fargo Clearing
Services LLC issued check# 19978649 to CONTRERAS for $519,082.11
from CONTRERAS's Wells Fargo Brokerage Account. According to
information provided by Bank of America, on September 14, 2023,
12 Deposits from other sources were also made into CONTRERAS's
Wells Fargo Savings Account.
19
Case 8:23-cr-00154-FWS Document 12 Filed 10/12/23 Page 36 of 44 Page ID #:103
there was an attempt to deposit check# 19978649 into-
Bank of America account ending in 0508. The back of
check# 19978649 was signed by CONTRERAS and endorsed to-
The check was also signed by But
Bank of America denied the deposit due to CONTRERAS not being a
signor on account ending in 0508.
38. According to information provided by Bank of America,
on September 26, 2023, CONTRERAS and opened a
joint account at Bank of America and deposited check# 19978649
into the newly opened joint account ending in 8232. As of
October 2, 2023, the funds from check# 19978649 were in a
deposit status only and had not been made available.
J. Additional Infora►ation Regarding CONTRERAS, the
SUBJECT PREMISES, the SUBJECT VEHICLE, and Digita Devices.
3 9. According to Superintendent and - —,
CONTRERAS recently married his partner,- According to
CONTRERAS's Facebook Account, which shows photos of a wedding
with individuals I recognize as CONTRERAS and from their
DMV photographs, CONTRERAS married _ on August 26, 2023.
4 0. Wells Fargo bank records show that between September
2 022 to July 2023, CONTRERAS deposited over $130,000 via
multiple peer -to-peer transfers and two wires from CONTRERAS's
Wells Fargo Account to a Wells Fargo account ending in 7733,
which Wells Fargo records show belong to CONTRERAS's partner,
_ One of the wires to _was on or about July 5, 2023,
f or $13,850, and the other wire to _was on or about July 26,
2 023, for $47,500.
20
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41. As for the SUBJECT PREMISES, bank records from JP
Morgan Chase, Wells Fargo, and Barclays Bank, show that
CONTRERAS listed the SUBJECT PREMISES as his home address.
Additionally, CONTRERAS's DMV records list the SUBJECT PREMISES
as his home address. On September 9, 2023, -Instagram
account which includes multiple photographs
that I recognize as _from his DMV photo, posted a video
showing CONTRERAS standing outside of the SUBJECT PREMISES. And
on September 14, 2023, FBI Special Agents Tim Bamford and
Ignacio Ramos observed, through recorded video surveillance,
CONTRERAS opening the door to the SUBJECT PREMISES to greet a
visitor.
42. Regarding the SUBJECT VEHICLE, on September 28, 2023,
FBI surveillance observed CONTRERAS and _traveling in the
SUBJECT VEHICLE to a gym near the SUBJECT PREMISES.
43. Verizon records show that the number ending in 0373
was registered to CONTRERAS in 2012 and listed an iPhone as the
phone for the account. Wells Fargo records show that an iPhone
was utilized to login into CONTRERAS's Wells Fargo Account
approximately 130 times.
44. According to Superintendent and Director of
Technology ("DOT -"), CONTRERAS was assigned
an HP Laptop with School District tag #012183, serial number
5CG0420TWK (the ~~HP Laptop") to conduct School District
business. According to DOT-,as of September 15, 2023,
the HP Laptop had not been returned to the School District.
21
Case 8:23-cr-00154-FWS Document 12 Filed 10/12/23 Page 38 of 44 Page ID #:105
V. TRAINING AND EXPERIENCE ON II~EZZLEMENT, MONEY LAUNDERING,
AND CONSPIRACY.
45. Based on my training and experience and information
obtained from other law enforcement officers and agents who
investigate fraud schemes, such as embezzlement, and money
laundering crimes and conspiracies, I know that individuals
involved in fraud schemes, such as embezzlement, and money
laundering crimes and conspiracies will often:
a. Transfer fraud or embezzlement proceeds through
multiple bank accounts in order to disguise the nature,
location, source, ownership, or control of those proceeds.
b. Work with other coconspirators and individuals to
help facilitate those schemes, by, for example, transferring
embezzled money through another person's bank account, by
working with others to create or operate shell businesses or
other businesses as a "front" to help conceal money laundering
or embezzlement, or by commingling funds from other sources to
create the appearance of legitimate income.
c. Use digital devices, such as cell phones and
computers to facilitate and conduct embezzlement and money
laundering, including for purposes of tracking and transferring
money that is part of those schemes, creating false
documentation or generating documentation regarding shell
businesses or "front" businesses to hide those schemes, and to
communicate with coconspirators and individuals involved in
those schemes.
22
Case 8:23-cr-00154-FWS Document 12 Filed 10/12/23 Page 39 of 44 Page ID #:106
d. Maintain, in digital devices, telephone numbers,
email addresses, and other contact information and
communications with and involving their coconspirators and
others involved in the scheme in order to conduct their
business. Additionally, digital devices such as cellular phones
and computers are often used to store photographs of, and
documentation regarding, items purchased with illegally derived
funds.
e. Maintain records (including financial records,
receipts and documentation of expenditures, notes, mail, and
other correspondence, negotiated instruments, contracts,
ledgers, tax records, and other papers) related to their crimes.
And these records, along with digital devices, cash, and/or
high-value items (i.e., items exceeding $10,000) purchased with
illegally derived funds are often maintained in safe locations,
such as their homes or vehicles.
46. Additionally, based on my training and experience and
information obtained from other law enforcement officers and
agents who investigate fraud schemes, such as embezzlement, and
money laundering crimes and conspiracies, I know that
individuals engaged in such schemes commonly participate in
these activities for profit. It is common for the proceeds of
fraud schemes to be in the form of cash, negotiable instruments,
or other assets. Furthermore, it is common for persons engaging
in fraud schemes to invest the profits in other assets, convert
the profits to other forms of financial instruments, and/or pay
personal expenditures with the profits. I am aware that such
23
Case 8:23-cr-00154-FWS Document 12 Filed 10/12/23 Page 40 of 44 Page ID #:107
transactions, transfers, or expenditures of criminally derived
profits cause the creation of numerous types of documents, which
reflect the fruits of the fraudulent scheme. I am also aware
that documents such as bank records, cashiers' check records,
receipts, invoices, expenditure records, escrow documents, notes
or notations, and other similar documents are generated upon the
transactions, transfers, and/or expenditures of criminally
derived funds. I know from training and experience that these
types of records are also commonly kept in homes or vehicles.
VI. TRAINING AND EXPERIENCE ON DIGITAL DEVICES
47. Based on my training, experience, and information from
those involved in the forensic examination of digital devices, I
know that the following electronic evidence, among other things,
is often retrievable from digital devices:
a. Forensic methods may uncover electronic files or
remnants of such files months or even years after the files have
been downloaded, deleted, or viewed via the Internet. Normally,
when a person deletes a file on a digital device, the data
contained in the file does not disappear; rather, the data
remains on the hard drive until overwritten by new data, which
may only occur after a long period of time. Similarly, files
viewed on the Internet are often automatically downloaded into a
temporary directory or cache that are only overwritten as they
are replaced with more recently downloaded or viewed content and
may also be recoverable months or years later.
b. Digital devices often contain electronic evidence
related to a crime, the device's user, or the existence of
24
Case 8:23-cr-00154-FWS Document 12 Filed 10/12/23 Page 41 of 44 Page ID #:108
evidence in other locations, such as, how the device has been
used, what it has been used for, who has used it, and who has
been responsible for creating or maintaining records, documents,
programs, applications, and materials on the device. That
evidence is often stored in logs and other artifacts that are
not kept in places where the user stores files, and in places
where the user may be unaware of them. For example, recoverable
data can include evidence of deleted or edited files; recently
used tasks and processes; online nicknames and passwords in the
form of configuration data stored by browser, e-mail, and chat
programs; attachment of other devices; times the device was in
use; and file creation dates and sequence.
c. The absence of data on a digital device may be
evidence of how the device was used, what it was used for, and
who used it. For example, showing the absence of certain
software on a device may be necessary to rebut a claim that the
device was being controlled remotely by such software.
d. Digital device users can also attempt to conceal
data by using encryption, steganography, or by using misleading
filenames and extensions. Digital devices may also contain
~~booby traps" that destroy or alter data if certain procedures
are not scrupulously followed. Law enforcement continuously
develops and acquires new methods of decryption, even for
devices or data that cannot currently be decrypted.
48. Based on my training, experience, and information from
those involved in the forensic examination of digital devices, I
know that it is not always possible to search devices for data
25
Case 8:23-cr-00154-FWS Document 12 Filed 10/12/23 Page 42 of 44 Page ID #:109
during a search of the premises for a number of reasons,
including the following:
a. Digital data are particularly vulnerable to
inadvertent or intentional modification or destruction. Thus,
often a controlled environment with specially trained personnel
may be necessary to maintain the integrity of and to conduct a
complete and accurate analysis of data on digital devices, which
may take substantial time, particularly as to the categories of
electronic evidence referenced above. Also, there are now so
many types of digital devices and programs that it is difficult
to bring to a search site all of the specialized manuals,
equipment, and personnel that may be required.
b. Digital devices capable of storing multiple
gigabytes are now commonplace. As an example of the amount of
data this equates to, one gigabyte can store close to 19,000
average file size (300kb) Word documents, or 614 photos with an
average size of 1.5MB.
49. The search warrant requests authorization to use the
biometric unlock features of a device, based on the following,
which I know from my training, experience, and review of
publicly available materials:
a. Users may enable a biometric unlock function on
some digital devices. To use this function, a user generally
displays a physical feature, such as a fingerprint, face, or
e ye, and the device will automatically unlock if that physical
feature matches one the user has stored on the device. To
unlock a device enabled with a fingerprint unlock function, a
26
Case 8:23-cr-00154-FWS Document 12 Filed 10/12/23 Page 43 of 44 Page ID #:110
user places one or more of the user's fingers on a device's
fingerprint scanner for approximately one second. To unlock a
device enabled with a facial, retina, or iris recognition
function, the user holds the device in front of the user's face
with the user's eyes open for approximately one second.
b. In some circumstances, a biometric unlock
function will not unlock a device even if enabled, such as when
a device has been restarted or inactive, has not been unlocked
for a certain period of time (often 48 hours or less), or after
a certain number of unsuccessful unlock attempts. Thus, the
opportunity to use a biometric unlock function even on an
enabled device may exist for only a short time. I do not know
the passcodes of the devices likely to be found in the search.
c. Thus, the warrant I am applying for would permit
law enforcement personnel to, with respect to any device that
appears to have a biometric sensor and falls within the scope of
the warrant: (1) depress the thumb- and/or fingers of CONTRERAS
or _on the device(s); and (2) hold the devices) in front of
face of CONTRERAS or with that person's eyes open to
activate the facial-, iris-, and/or retina-recognition feature.
VII. CONCLUSION
50. For all the reasons described above, there is probable
cause to believe CONTRERAS violated Title 18, United States
Code, Section 666(a)(1)(A) (embezzlement concerning programs
receiving federal funds), and a warrant should issue for his
arrest. Additionally, there is probable cause to find that the
items listed in Attachment B, which constitute evidence, fruits,
Case 8:23-cr-00154-FWS Document 12 Filed 10/12/23 Page 44 of 44 Page ID #:111
and instrumentalities of violations of the Subject Offenses,
will be found in a search of the SUBJECT PREMISES, the SUBJECT
VEHICLE, on the person of CONTRERAS and as well as in
digital devices found on their person, in the SUBJECT PREMISES
or in the SUBJECT VEHICLE.
/s/
Timothy W. Bamford,
Special Agent, FBI
Attested to by the applicant in
accordance with the
requirements of Fed. R. Crim.
P. 4.1 by telephone on this
l~ day of October, 20?3.
RABLE JOHN D. EA
ITED STATES MAGISTRATE JUDGE
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