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AO
9l
(Rev.
I l/l l) Cnmind Complaanl
UNrrgo Srerps
DrsrRrcr
Counr
for
the
Weslem
District of Pennsylvania
Case No
20-1365m
IUNDER
SEALI
DESMOND FODJE BOBGA
Delendan!g
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best ofmy knowledge and belief.
On or about the date(s) of
June
2018 to the
present
in the countv of
Beaver
)
)
)
)
)
)
)
Western
District
of
Pennsylvania
,
the defendant(s) violated:
Ofense
Descriplion
18
U.S.C.
S
1349 Fraud
Conspiracy
18 U.S.C.
S
1343 Wre Fraud
18 U.S.C.
S
505 Forging and Counterfeiting the Seal ofa Courl
oflhe United States
18 U.S.C.
S
1028A Aggravated ldentity Theft
(SEE
ATTACHMENT
A)
(SEE
ATTACHMENT
A)
This
criminal complaint is based on th€se facts:
(See
Affidavit in Support of Complaint)
d Continued on the attached sheet.
/s/ Joseph J. Ondercin
Conplainant's si
gnanre
Joseph J.
Ondercin
Printed nome
and title
Swom
to
before me and signed in my
presence
Date:
Code
Section
in
the
Judge's signahtre
MAUREEN P.
KELLY, U,S. MAGISTRATE
JUDGE
Cily
and state
06t30t2020
Pittsburgh, Pennsylvania
Printed n<rnte and
title
United
States
of
America
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ATTACHMENT A
TO
CRIMINAL COMPLAINT
Count l: From in
and around June 2018. and continuing
to the
present,
in
the countries of
Romania and Cameroon and in
the
Westem District ofPennsylvania and
elsewhere, the
defendant,
DESMOND FODJE
BOBGA, knowingly
and
willfully
did conspire,
combine, confederate, and
agree
with other
persons
to commit an offense
against the United States, that is, wire
fraud,
in
violation
of Title 18.
United States Code,
Section
1343.
As
part
ofthe manner and means
ofthe conspiracy, the conspirators
offered
puppies
and
other
animals
for
sale on
websites
on the Intemet,
the conspirators communicated
by
wire
with
potential
victims
to
induce
the
potential
victims to
purchase
the
puppy
or other
animal,
the
conspirators claimed that
the
transport of the
puppy
or
other animal was delayed
and
needed
additional monies to effectuate
the transport, the conspirators received
money directly and
indirectly through wire communications fiom
the victims, and the conspirators never
delivered the
puppy
or other animal.
In violation
ofTitle 18, United States Code,
Section
1349.
Counts
2-10:
On or
about the
dates set
forth
below, in Romania and in the Westem District of
Pennsylvania
and elsewhere, the defendant,
DESMOND FODJE BOBGA, for
the
purposes
of
executing and attempting
to
execute the scheme and artifice to defraud, did cause to be transmitted
in foreigrt and/or interstate
commerce,
by means of a
wire
communication, monetary wire transfers
with each
wire
transfer being a separate count, the following:
On or about Date
of
Wire
')
3fi3/2020 The defendant,
DESMOND FODJE BOBGA,
caused
Victim-
l to
wire, via Westem
Union,
$950
from Rochester,
Count
Pennsylvania to Romania
l 3^412020
The defendant, DESMOND FODJE BOBGA, caused
Victim-l to wire,
via western
Union,
$1500
lrom New
Brighton,
Pennsylvania
to
Romania
4 311712020 The defendant, DESMOND
FODJE
BOBGA,
caused
Victim- l to wire, via Western Union,
$2000
from Beaver
Falls,
Pennsylvania
to
Romania
5
3/17t2020
The defendant. DESMOND
FODJE
BOBGA. caused
Victim-l to
vvire. via Western
Union.
$950
from Monaca,
Pennsylvania to Romania
6 3/19/2020
The defendant, DESMOND FODJE BOBGA, caused
Victim- l to wire, v ia Western Union,
$600
from Rochester,
Pennsylvania to Romania
7 3/21/2020 The
defendant. DESMOND FODJE BOBGA. caused
Victim-l to wire. via
westem
Union.
$500
from
New
Brighton.
Pennsylvan ia to Romania
8 312912019
The defendant, DESMOND FODJE
BOBGA,
caused
Victim-3 to wire, via MoneyGram.
$600
from Indiana.
Pennsylvania to an individual
with
the
initials J.J. in
Maryland
9 4t24t20t9 The defendant, DESMOND FODJE BOBGA. caused
Victim-5 to wire, via
MoneyGram,
$600
from Frazer
Township, Pennsylvania to an individual
with
the initials
W.M.
in Virginia
l0
4/27t7019
The defendant, DESMOND FODJE BOBGA, caused
Victim-5 to wire, via MoneyGram,
$900
from Frazer
Township, Pennsylvania to an individual with the initials
E.B.
in Florida
In violation
of Title 18. United States Code. Section
1343.
Count 11: On or about
March 29, 201 9, in
the
Westem District
of
Pennsylvania
and
elsewhere, the defendant,
DESMOND FODJE BOBGA,
did knowingly
concur in using. that is,
sending
to
Victim-3 located in the Western District
ofPennsylvania, a lorged and counterfeit seal
of a court ofthe United States, that is, the Supreme Court ofthe United States, and a forged
and
counterfeit signature ofthe Clerk ofthe Supreme Court, a court officer.
on
a document purporting
to have been issued by the Supreme Court of the United States for the
purpose
of authenticating
the document.
knowing
such seal and signature to be forged and
counterfeit, said document
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claiming to
guarantee
the refund of
$850.00
for
the safe delivery of a dog.
In violation
ofTitle 18. United States Code. Section
505.
Count 12: On or about March 29, 2019,
in the Westem District of Pennsylvania and
elsewhere, the defendant,
DESMOND FODJE BOBGA,
during and in relation to the felony
violation of wire fraud did knowingly transfer, without
lawful
authority, a means of identification
of another
person,
namely, the
signature ofthe
former
Clerk
ofthe Supreme
Court ofthe United
States.
ln violation of Title 18, United States
Code, Section
1028A(a)(l).
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IN THE UNITED STATES DISTRICT COUR'T
FOR THE WESTERN DISTRICT OF
PENNSYLVANIA
UNITED
STATES OF AMt]RICA
Magistrate
No.
20-l
365M
DESMOND FODJE BOBCA
AF}'IDAVIT IN SUPPORT OF COMPLAINT
I, Special Agent Joseph J. Ondercin,
being
first duly swom, hereby depose and state as
follows:
INTRODUCTION AND
AGENT BACKGROUND
I . I am a Special Agent
(SA)
with the
Federal Bureau
of Investigation
(FBI)
and
have
been
so employed
since Novemberof2005. I am currently assigned to the Piftsburgh Division of
the FBI, computer intrusion squad. In this capacity,
I
am charged with
investigating possible
violations of federal criminal law. By vi*ue of my FBI employment, I
perform
and
have
performed
a variety of investigative tasks, including
functioning
as a case agent on access device
fraud, computer fraud, and wire
fraud
cases.
I
have
received
training in the conduct of access
device
fraud, computer
fraud, and
wire fraud investigations.
I have also received training and
gained
experience in interviewing and interrogation
techniques, the execution of federal search
warrants
and
seizures, and the identification and collection of computer-related
evidence.
ln
addition, I have
personally
participated in
the
execution of federal search warrants involving the
search and seizure of computer equipment.
2. The information contained in this affidavit is
based upon my
personal
knowledge,
knowledge obtained during my
participation
in this investigation,
knowledge obtained from other
individuals including other law enforcement
personnel
and others who have
personal
knowledge
I
)
)
)
)
)
)
)
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of the events and circumstances described herein, knowledge
obtained from my review of
documents, electronic records, and other evidence related to this investigation, and knowledge
gained
through my
training
and experience.
Because this affidavit is being submitted for the
limited
purpose
of establishing
probable
cause in support of
a criminal complaint, I have not
included
every
detail of every aspect ofthe investigation. Rather, I have
set
forth
only
those facts
that
I
believe
are necessary
to establish
probable
cause.
3. This Affidavit is in suppo(
of
an application
for
a criminal complaint against and
an arrest warrant for DESMOND FODJE
BOBGA. As set forth herein,
there
exists
probable
cause
to believe that DESMOND FODJE BOBGA
has violated Title 18, United States
Code, Sections
1349
(Fraud
Conspiracy), 1343
(Wire
Fraud), 505
(Forging
Seal
of Court), and 1028,{
(Ag$avated
Identity
Theft).
SUBJf,CT IDENTIFIERS
4. DESMOND FODJE BOBGA
C'FODJE
BOBGA"), born in 1992, is a
citizen ofthe
Republic of Cameroon who is
in
the country of Romania on a visa to attend Babeq-Bolyai
University
in
Cluj,
Romania. FODJE
BOBGA
has
a
Republic
of Cameroon
passport,
number
0864425,
expiring
September
19, 2023.
PROBABLE
CAUSE
A. Overview
5.
The FBI is investigating an intemet fraud scheme wherein the criminal actors,
including FODJE BOBGA and co-conspirators, advertise
goods/products/items
online, receive
payment
for the adve(ised
goods/products/items,
and intentionally do not deliver said
goods/products/items. As described below, this scheme, for
years,
involved the
purported
sale of
pets
to the American
public. The
perpetrators
used false and fraudulent
promises
and documents
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regarding shipping
fees,
and
more recently, coronavirus exposure,
to extract successive
payments
from victims.
6. Based on my training
and experience,
your
Affiant knows these
intemet fraud
schemes often
require the use ofnumerous websites
and
email accounts.
After
a
website and email
account are used to defraud a
few individuals, the website and email account are often
reported to
consumer
protection
agencies and flagged as
fraudulent. As a result,
other
potential
consumers
are able to leam that the website or email
account is associated with the fraud and avoid
purchasing
from said website
and/or email
account. Thus, criminal actors involved
in
this type of
intemet
fraud
scheme often use
a
particular
website
and/or email account
for
a
few
customers
and
then
create
and
use
another website and/or email account to target
new
potential
customers.
7. Based on my training and experience,
your
Affiant also knows
that
criminal actors
involved
in this
type
of intemet fraud scheme
prefer
customers to
pay
through
means that can
obscure the
recipient's identity to
avoid law enforcement detection. As a result, criminal actors
involved in this type of intemet fraud scheme
prefer
money transfers
(e.g.,
Westem Union,
MoneyGram, etc.)
or cryptocurrency
(e.g.,
Bitcoin).
These criminal actors often communicate
how
payment
should be made through electronic means with the victim customer.
8. The instant fraud scheme involves the false and fraudulent online sale of
pets
to
American consumers. Because the
fraud
scheme
predominately (though
not exclusively) involves
the
sale of
puppies,
it is
often
known as a
pet
adoption
scam or
puppy
scam. Specifically, the
individuals created websites to advertise
puppies
or other animals
for sale, communicated with
potential
customers, obtained
payment
for alleged sale, and
provided
nothing in
retum.
Using
multiple telephone numbers and email accounts, including
(434)
214-8514
and
sent electronic communications,
through
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interstate and/or foreign
commerce, to hundreds of target
victims across the United States.
Some
of those communications contained
false and fraudulent representations
to induce the
target
victims
to
pay
hundreds ofdollars for
a
puppy. (Attached
exhibit I and
exhibit
2
are screenshots
of a website to which FODJE BOBGA directed numerous
targeted victims to view
puppies
that he
fraudulently claimed to sell. Exhibit I
is a screenshot ofthe website as it fits in
the web browser
when
initially
accessed.
Exhibit
2 captures the entire selection
of advertised
puppies
at the
time
that
your
Affiant inspected the website).
Other communications contained false
and
fraudulent
representations to induce victims who had already
paid
lor
the
"puppy"
to send hundreds,
and
sometimes thousands, of additional dollars in
"refundable
fees" relating
to
the puppy's
shipping,
vaccination, and coronavirus quarantine.
FODJE BOBGA
directed some ofthose
payments
to be
sent
in his own name. He directed
some other
payments
to be sent in the names of fellow African
students in Romania.
9. As
part
ofthis investigation,
your
Affiant has interviewed a number ofvictims
and
potential
victims of this
puppy
scam. Based on intemational and/or interstate electronic
communications obtained
in
this
investigation, from
June
2018
to the
present,
FODJE BOGBA
and
his
co-conspirators
communicated with these victims and
potential
victims
to
fraudulently
induce them to send money, through
intemational
and
or interstate
wires,
for puppies
or other
animals that were never delivered. A
few
of
the victims are highlighted below.
B. Victim-l
10. On two
occasions, with the most recent being May 6,
2020, your
Affiant
interviewed
Victim-1, a resident of New Brighton, Pennsylvania,
which is located in the Western
District
of
Pennsylvania.
I
l.
In March 2020, Victim-l
performed an internet search for a
puppy
to
purchase
for
4
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her mother. Victim- l came upon a web site offering mini dachshunds for sale where she submitted
a form
requesting
information. On approximately
March ll,2020,
Victim-l was contacted by
text
message from
the
phone
number
(832)
843-9680 from
an
individual
purportedly
named
"Hector
CANTU."
*CANTU"
indicated that the dog,
purportedly
named
"Pansy,"
was
still
available and
that
the
price would be
$500
to
include
shipping,
which Iater
changed
to
$600.
As
instructed
by
"CANTU,"
Victim-l obtained
$600
in Walmart
gift
cards and sent
pictures
of the
cards
with
the
PIN number exposed
to'CANTU."
Victim-l
sent
these
pictures
by text message
from her
phone,
which was located in the Westem District of Pennsylvania, to the
phone
number
(832)
843-9680.
r
12. Victim-l then received an email from the email
account
informed that Pansy
would be
shipped
by
plane
through an entity
called
"Pets
Fly America" from
Houston,
Texas to Pittsburgh, Pennsylvania with an expected arrival date of March
13,2020.
provided
Victim- I with a tracking number
for Pets Fly
America's website that allegedly allowed her to monitor the status ofPansy's transport.
13. Victim-l then received text messages from an unnamed subject at
phone
number
(434)
214-8514 indicating that the subject was involved in the shipping ofthe
puppy.
According
to
the text messages, the sender claimed that several issues came up with the
transport of Pansy
which resulted in the dog being stopped over in Oklahoma. According to the sender, one ofthe
issues included Pansy being
quarantined
due to being exposed to COVID-19 on the flight. As a
result, the sender indicated that
Victim-l needed to send
additional
fees
to
ensure
Pansy's safe
transport
including
the need
for
an
air
conditioned
shipping crate and insurance fees.
The false
I
The area code
(832)
is associated
with the Houston, Texas area.
5
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representations contained
in
these
text messages
induced Victim-l
to
send numerous intemational
wire transfer
payments
through Western Union, from locations in the Commonwealth of
Pennsylvania
to receivers located in the country of Romania, in the hopes of having Pansy
transported safely. The below chart lists some of these
international wires.
Ultimately,
no
dog
arrived, and Victim-l received
no refund.
Amount Sent Date Sent Location Reccive
Date
Receive Loc.
Recci\e lnitials
$950
3/13120 Rochester, PA 3ll4/20 Romania A.L.F
$1500
3/14/20
New
Brighton. PA 3ll5/20 Romania N.G.N
$2000:
3/16t20
Rochester. PA 3lt6120 Romania E.N.C
s2000
3/17
/20
Beaver Falls. PA 3117
t20
Romania
B,T.N,
$9s0
3/17 /20 Monaca, PA 3^8/20
Romania B.T,N
$(r00
3/19/20 Rochester. PA 3/t9t20
Romania v.T.F'
s-s00
3/21/20
New
Brighton, PA 3l2t/20 Romania M.G.A
14. As
part
ofthis investigation, law enforcement obtained,
by search warrant, Google
records associated with the email account
15. According to Google subscriber
records, the
joebahTT
@gmail.com
account uses
Google Voice, which is a
voice-over-internet-protocol
("VolP")
product
that
provides
calling and
text messaging services
for
customers
through their Google accounts. Specifically,
joebahTT
@gmail.com
uses Google
Voice with a user
phone
number of
(434)
214-8514. As
part
ofthe records
provided,
Google
provided
over 12,000 inbound and outbound text messages
forthe
Google
Voice
phone
number
(434)
214-8514, including over
900
text messages that were
exchanged
with Victim-l's
phone
number between March
13, 2020, and March
2l,2020, that
fraudulently
induced Victim-l to lose
$9,100.
2
This
transaction
was sent by Victim-l's friend on her behalf.
6
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16. Google subscriber
records for email account
also
listed
a
recovery email
of fodjebobgal
@gmail.com.
Based on
my
training
and experience,
your
Affrant
knows that a recovery email
is a method by which an account user can be reached to, among
other
things, recover access to
an account when the user
forgets
the account
password. Based on my
training
and experience,
your
Affiant knows that an
account
and
its recovery email are likely
controlled by
the same
person
and/or organization.
17. As
part
ofthis investigation,
law
enforcement obtained, by search warrant,
Google
records associated with the email
account fodjebobgal
@gmail.com.
Those records show
the user of the fodjebobgal
@gmail.com
email
account to be FODJE BOBGA in the following
ways, among others:
a. The contents of
the fodjebobgal
@gmail.com
email
account included
numerous emails
relating
to
FODJE BOBGA's attendance of Babeq-Bolyai University. An email
sent
from
fodjebobgal
@gmail.com,
dated October 2, 2019, related to his admission at the
University contained numerous attachments,
including a
photograph
of
FODJE BOBGA's
Cameroonian
passport
and
FODJE
BOBGA's letter of acceptance to Babeq-Bolyai University
from
the Romanian Ministry of National
Education.
b. An
email
was
sent
from fodjebobgal
@gmail.com,
dated February 21,2020,
to an email address with
the
domain for a Romanian bank. The message
indicated that the user's
name was Fodje Bobga Desmond, who was trying to open an account. Attached
to the
message
was
a copy of a
Taxpayer's
Card from the Republic ofCameroon in the
name ofDesmond Fodje
Bobga.
c. An email sent from fodjebobgal
@gmail.com,
dated March I1,2020,
stated
that the user was
"Fodje
Bobga
Desmond," as
"the
representative ofthe
African students."
The
7
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message
provided
a
list
ofthe names
of other classmates. Two
of
those names appear to match
the names of two ofthe receivers
to whom
(434)
214-8514
had directed Victim-l
to send money.
(The
money transfer
to
one
of them is reflected on the above
chart under the
initials V.T.F. Victim-
I's attempted
payment
to the other was
unsuccessful.)
d. An email was sent from fodjebobgal
@gmail.com,
dated March
21,2020,
to
an email address with
the domain for Babeq-Bolyai University,
relating to
"covidl9."
The
message stated that the
sender
was
Fodje Bobga Desmond from
Cameroon, was a
political
science
student, and was
going
to remain in
Cluj.
18. The Google
photos
archive for fodjebobgal
@gmail.com
contained two images of
interest. First,
in a folder named
"2020-01-08-
10," was
a
photo
containing
a
picture
of a
Cameroonian
passport.
The
second, in a folder named
"2020-01-l3,"
contained a
picture
ofa
Universitatea Babes Bolyai social service ID card. The two names
on
the two depicted
documents
appear to
match
the names of two other listed receivers of fraudulently
obtained funds from
Victim-1, as reflected in the above chart under the initials A.L.F.
and
E.N.C., respectively.
C.
Victim-2
19.
On May 7,2020
your
Affiant interviewed Victim-2, who is a resident
of Fruitland,
Iowa.
20. ln March 2020, Yictim-2 was
searching
online
to
purchase
a
puppy
for
herself.
Victim-2 came upon a web site offering mini dachshunds for sale where she submitted a form
requesting
information. On approximately March
4, 2020, Victim-2
was contacted by text
message from the
phone
number
(832)
843-9680
from an individual purportedly named "Hector
CANTU."
"CANTU"
indicated that the
puppy, purportedly
named
"Tina,"
was still available and
that the
price would
be
$600
with shipping. On March 5,2020,
Victim-2
made
a
$300
deposit.
8
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As
instructed by "CANTU," Victim-2
obtained
$300
in
Walmart
gift
cards and sent
pictures
of the
cards with the PIN number exposed to "CANTU."
21.
On
March 6, 2020, Victim-2 received
an email from the email account
containing
a Transfer
of Ownership document for Tina that
needed to be signed and retumed, which Victim-2 did.
On
March
9,
2020, by text messages,
"CANTU" provided
a tracking number that allegedly can be used on the Pets
Fly America
website
to monitor
the status of
Tina's
transport. On March 9,2020,Yictim-2 made the remaining
$300
payment.
As instructed by
"CANTU,"
Victim-2
obtained
$300
in Walmart
gift
cards and sent
pictures
of the cards with the PIN number exposed to "CANTU." However, "CANTU"
advised
that
the
Walmart
gift
cards were not activated. As a result,
on
the
same date, Victim-2 sent an
additional
$300
by Zelle, which is a digital
payment
system
that
is
associated
with numerous U.S.
banks, to an account associated with the email address
22. After this
payment
was made, Victim-2 received
an email from
advising that the
puppy
had arrived in Chicago, Illinois. The email
advised
that
the
puppy was lacking
the appropriate
insurance
coverage, which required a
$950
refundable
payment.
On March 10,2020, Victim-2 made the
$950
payment
through PayPal,
an
electronic
payment
system,
to a PayPal account associated with the email address
of
Victim-2 received
an email
indicating
that
an individual
named Desmond Fodje Bobga refunded this PayPal transaction with the
use ofa
PayPal account
associated with the email
address lovelyteacupchihuahual
@gmai[.com.
According to Victim-2,
she was informed that there
was
an
issue with the PayPal transaction that caused this refund, and
that she must send
payment
by
wire transfer through Western Union. On March 12,2020, Y ictim-
9
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*SEALED*
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of
25
2 sent, from
lowa,
a
wire
transfer through Western Union
in the
amount of
$950
to an individual
named Desmond Fodje Bobga with a destination of Romania.
23. Subsequent to this
payment,
Victim-2 continued communication with the email
account
In addition,
Victim-2 communicated
by
text message with
the
phone number
(434)
214-8514
concerning
the shipment ofTina.
On
March 12,2020, Victim-
2 received another email from
asserting that an additional
$890
was
needed
for vaccines and an AC crate, which would be refunded to Victim-2 upon delivery ofthe
puppy.
On
March 12, 2020, Victim-2
sent,
from Iowa,
a
wire transfer
through Westem Union
in
the amount of$890 to an
individual named Desmond Fodje Bobga with a destination of Romania.
24. Subsequent to this
payment,
the Victim-2 received an additional email from
asserting that another
$
I
,500
was needed
for a USDA
(United
States
Department of Agriculture)
pet
and livestock
permit,
which would be fully refunded to Victim-2
upon delivery. At this
point,
Victim-2
refused to make any additional
payment
and requested a
refund. Victim-2 has not received any refund for the fees
paid,
and no dog was delivered.
25. On May 7, 2020,
your
Affiant reviewed the tracking number
provided
to Victim-2
for
Tina on the web site www.petsflyamerica.com. According to the website associated with this
tracking
number, the shipper
was listed
as
Hector
CANTU
of
Rosenberg, Texas
with the
phone
number of
(832)
shipment information indicated
that
a female dachshund
puppy named
Tina
was
being shipped by
air
freight to Victim-2 in lowa with an
expected
arrival
date of
March
9, 2020.
26. As discussed above,
pursuant
to a search warrant,
Google
provided
records
associated
with
the Google
Voice
number
(434)
214-8514. Among
the inbound and outbound text
messages for Google Voice
phone
number
(434)
214-8514 were over I
00 text messages that were
l0
Case
2:20-mj-01365-MPK
.SEALED*
Document 4 Filed 06130120 Page 11 of 25
exchanged with
Victim-2's
phone
number between March 9,2020,
and March 15, 2020, that
fraudulently induced Victim-2
to
lose
$1,840.
27. Also, as discussed above,
the
Google
subscriber records for email account
listed
a recovery email of fodjebobgal
@gmail.com.
According to Coogle
records, the fodjebobgal
@gmail.com
email
account vr'as
linked by shared cookie
to
lovelyteacupchihuahual
@gmail.com.
Based on my training
and experience,
your
Affiant knows
that a cookie is data issued by a website and then stored
on a user's computer that is recognized
by the issuer
(e.g.,
Google) when a computer visits that
particular
website
or logs into an account
associated with the issuer. Through the use of cookies, Google
can identify various Google
accounts that have been accessed by the same electronic device(s).
Oftentimes, shared cookies
amongst email accounts are evidence that the same
person
or organization controls the email
accounts.
Because
fodjebobgal
@gmail.com
and lovelyeacupchihuahua
I
@gmail.com
are linked
by
a shared cookie, the two email accounts were accessed by the
same electronic device.- The
shared cookies
link
and
the recover email link among the
fodjebobgal
@gmail.com,
accounts
establishes
probable
cause that these email accounts are controlled by the same individual,
that is, FODJE BOBGA.
28. Moreover, outbound
text
messages from
the Google Voice number
(434)
214-8514
directed
two
other
puppy
scam victims to make PayPal
payments
to
"Desmond
Fodje"
at
lovelyteacupchihuahual
@gmail.com.
D. Victim-3
29.
On April
1,2020, your
Affiant interviewed Victim-3, a resident
of Marion Center,
Pennsylvania, which is located in the Westem District of Pennsylvania.
30. In March 2019, Victim-3 searched the Intemet for a tea
cup
Chihuahua
in
hope
of
il
Case 2:20-mj-01"365-MPK
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06130120
Page 72
oI
25
finding
a
pet
to
purchase.
Victim-3 located a
puppy
on a web site and submitted a
form requesting
additional information.
Victim-3 was
contacted
by email and was
provided
a
phone
number for
contact. She agreed to
purchase
a tea
cup Chihuahua for
$600.
Based on the instructions that
she
was
provided,
on March 29,2019, Victim-3 sent,
from
the
Indiana,
Pennsylvania, a
wire
transfer
through MoneyGram
in the
amount of
$600
to an individual named John Jefferson with a
destination
of Maryland.
31. After making this
payment,
Victim-3 was contacted by
email. This email claimed
to be involved in the shipment ofthe Chihuahua and claimed
that
an
additional
$800
payment
was
necessary
for the shipping ofher
puppy.
Victim-3
was suspicious
ofthis
email
and
refused
to
send
additional money. Victim-3 did not
receive
any
refund for fees
paid,
and no dog was delivered.
32.
As part
ofthis
investigation, law enforcement obtained, by search warrant, Google
records associated
with
the Google
Voice
telephone
number
(434)
298-4502 and the email account
unitedpetsafe2009@gmai
l.com.
33. Google
Voice records for
(434)
298-4502 show three calls
with Victim-3's
telephone number on
March 29, 2019. According to the
Google records for the
email account, this account
was
used to
communicate with Victim-
3
conceming the false transport ofa tea
cup Chihuahua
puppy.
Specifically, there was a March
29,2019
email
from [email protected] to
Victim-3 with the subject line
"*
URGENT
CRATE
AND VACCINE
NEEDED FOR YOUR FEMALE TEACUP CHIHUAHUA PUPPY
SNOWWHITE*." The
message
contained a
headerofUnited Petsafe Shippers. The
body ofthe
email, addressed to Victim-3, claimed that an additional
$850
refundable fee
would
be needed for
an AC ventilated crate and vaccine service for the
puppy
in
order
to
facilitate
the air transport.
The
fees would supposedly be refunded upon
pickup
of the
puppy
at the airport. Attachments to the
t2
Case 2:20-mj-01365-MPK
*SEALED*
Document 4 Filed 06/30/20 Page 13 of 25
email
included
pictures
ofpet transport crates. The email was signed "Manager
United
Petsafe
Richard LifIIon TEL:
(361)
441-0347;'
34. Also attached to the
email
from
document entitled,
"Refundable
Crate and Vaccine Guarantee
Document." The document
purported
to have been issued by the
"Supreme
Court
ofthe United States
of
America"
and bore
the seal of the Court, along
with
the signature ol"William K. Suter," as Clerk of the Court. Dated
March 29,2019,
the document claimed that
"with
the
pyramid
insurance in affiliation with
supreme court of the United States
of America
(USA)
and the
(USDA)
ensures
the
refunds
of
850.00USD
to
[name
of Victim-3] and safe delivery of her female teacup Chihuahua
puppy
in
question
at
her
home
address."
35. From my review of information on the official
website ofthe Supreme Court,
your
Affiant knows that William K. Suter was the l9th Clerk of the Court
and that he retired in 2013.
The
Clerk ofthe Supreme Court has since been Scott S. Harris. Therefore,
the document bears a
forged
or counterleit seal ofthe Supreme Court and a forged or counterfeit
signature
(i.e.,
a means
of
identification)
of the Clerk of the Court. Additionally, the
document was forged and
counterfeited for
the
purpose
offalsely authenticating the document
and the demand for
$850.00.
36. Also located in the mailbox of [email protected] was
an unsent
draft
email
that was dated March 17, 2020. This draft email contained
the name, address,
phone,
and
email address of Victim-l as well as
the
name
(i.e.,
"Hector
Cantu"),
address,
phone
number, and
email address ofthe
purported
seller ofthe
puppy
to Victim-1.
37. Google subscriber records for email account [email protected]
list a
recovery email of fodjebobgal
@gmail.com.
Thus, fodjebobga I
@gmail.com
is
the
recovery
email
for both [email protected] and
Again,
based on
my
training
13
Case 2:20-mj-01365-MPK
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Document 4 Filed
06130120
Page L4 oI 25
and
experience,
your
Affiant knows that a recovery email is a method by which an account
user
can be reached to, among other things, recover access to an account
when
the
user
forgets the
account
password.
Based
on my
training
and experience,
your
Affiant knows that an account and
its recovery email
are likely controlled by the same
person
and/or organization. In this
case, that
individual is FODJE BOBGA.
38. Additional
evidence
demonstrates
that the [email protected] email
address is used by
FODJE BOBGA. A message dated approximately October 2, 2019, was sent
from [email protected]
to fodjebobgal
@gmail.com
and
contained a
pdf
titled,
"confirmation
FODJE
BOBGA DESMOND.pdf." The document
was
a confirmation
letter, dated
September
16,2019, from Babeq-Bolyai University in Romania,
for FODJE
BOBGA to
attend
Babeq-Bolyai University.
39.
Furthermore, IP addresses
associated with fodjebobga I
@gmail.com,
joebahTT
@gmail.com,
and
BOBGA's
Cameroonian origin
and current stay in Romania. For example,
on
or about
April 8,2020,
fodjebobgal
@gmail.com
were
accessed,
within
six
seconds
ofeach other, from
the same IP address, which based on an
IP
address
lookup is assigned to Babeq-
Bolyai University. On or about
February 14, 2020, [email protected],
joebahTT@gmaiL
com, and [email protected]
were all accessed, within a ten-second
period,
from the same
IP
address,
which
based
on an IP address lookup is assigned to a Romanian
telecommunications
provider.
Similarly, on
or about January 10, 2020, all three email accounts
were accessed, within
a 38-second
period,
from the same IP address,
which
based on an
lP address
lookup
is
assigned
to a Romanian telecommunications
provider.
And on or about October
12,
20'19, all three
email accounts were accessed at the same time from the same
IP
address,
which
t4
Case 2:20-mj-01365-MPK
.SEALED*
Document 4
Filed
06130120
Page 15 of 25
l5
based on an IP
address lookup is assigned to a Cameroonian telecommunications
provider.
E.
Victim-4
40.
The telephone number
(361)
441-0347,
which
was in the signature block of the
fraudulent
email sent from [email protected]
to Victim-3 on
March
29,2019, as
discussed
above, appears to be controlled by
a co-conspirator of FODJE BOBGA. As described
below,
FODJE BOBGA and the co-conspiratorjoined
together to defraud another victim referred
to below as
"Victim-4."
41. On June 5,2020,
your
Affiant interviewed Victim-4, a resident of
Dallas, Texas.
42.
In February 2020, Victim-4 and his
girlfriend
were
looking
to
purchase
a
dog. The
girlfriend
located a website and completed a
form
to
get
more
information. Victim-4 and his
girlfriend
had contact
with telephone number
(434)
214-8514, which was the individual that was
allegedly selling
the dog. The
pair
agreed upon a dog named Snow White. Victim-4
communicated
with
(434)
214-8514 to complete the sale transaction and used PayPal to send
approximately
$950.
43. The seller claimed to use
a service named Pets Fly America for
shipment
and
provided
a web
site and tracking number. Thereafter,
Victim-4 was
contacted by
a second number,
(361)
441-0347, alleged to be the shipper of the dog. This alleged shipper claimed that
issues
arose in the shipment of the dog and
requesting
an additional
$850
was needed for a
health
certificate. Victim-4
paid
the amount
via Zelle to a
person
with the initials R.P. Thereafter, this
alleged shipper informed Victim-4 that
the
payment
did not
go
through due to the wrong name
being
listed.
Victim-4
confirmed with his bank that the
payment
was successfi.rl, but the alleged
shipper
insisted the
payment
needed to be
resent
with the
proper
name. In an effort to resolve any
issues
conceming the sale and transport ofthe dog,
Victim-4
started
a
group
text to the
two
phone
Case 2:20-mj-01365-MPK
*SEALED"
Document 4 Filed
06130120
Page
16 of
25
numbers
that he communicated with
conceming the dog, which were
the
phone
numbers
(434)
214-8514
and(361) 441-0347. Victim-4
refused to resend the
$850
payment.
Ultimately,
no dog
was
delivered and no refund was received.
44. As
discussed above,
pursuant
to a search warrant,
Google
provided
records
for
Google Voice number
(434)
214-8514.
Among the inbound and
outbound
text messages for
Google Voice
phone
number
(434)
214-8514 were
over 100 text messages that were
exchanged
with Victim-4's
phone
number
between February
26, 2020, and February 28, 2020,
that
fraudulently induced Victim-4 to lose
$1,500.
45. Also among the text messages for Google Voice
phone
number
(434)
214-8514
was
a
group
conversation on
February
28,2020, with Victim-4's
phone
number
and
(361)
441-
0347, wherein Victim-4 inquired
about the excuses for non-delivery of the
puppy.
FODJE
BOBGA, through
(434)
214-8514, falsely claimed delay due Victim-4's
bank, writing,
"i
have
been totally confused stressed up. being accused for something i do not know." The
response
from
(361)
441-0347 to Victim-4 was,
"Can you
be
patient
so we
get
this sorted out?"
46. Separately, call detail records for Google Voice
phone
number
(434)
214-8514
show five calls
from
(361)
441-0347.
One call, on March
14,2020,lasted
33 seconds. Four calls
in April 2020 were missed. These circumstances indicate that
(361)
441-0347 was
controlled by
a subject other than FODJE BOBGA, as
part
ofand in furtherance oftheirjoint
puppy
scam.
F. Victim-S
47. On May 28, 2020 and June
9,2020,
your
Affiant interviewed
Victim-5, a resident
of Cheswick, Pennsylvania, which is located in the Westem District of Pennsylvania.
48. In April
2019,
Victim-s
searched online to
purchase
a chihuahua and located a web
site offering a dog
named
Bentley
for
sale. Victim-S
sent a request for more information via
email
t6
Case 2:20-mj-01365-MPK
.SEALED.
Document
4
Filed 06/30/20
Page
17 of 25
and
provided
her contact
phone
number. Victim-s was contacted
by
telephone number
(434)
298-
4502
and an agreement was made to
purchase
Bentley for
$600.
Based on the alleged seller's
instructions,
on approximately April 24, 2019, Victim-5
sent
$600
via
MoneyGram
from
a
Walmart in Frazer Township, Pennsylvania to a
person
with the initial F.R. in the
Commonwealth
of Virginia.
Upon being
informed
by the seller that there was a
problem
with the
payment,
Victim-
5 cancelled the original
payment.
On approximately Aprll24,20l9, Victim-5
sent a new
payment
of
$600
via MoneyGram
from
a Walmart
in
Frazer Township, Pennsylvania to a
person
with the
initials W.M. in Virginia.
49. Thereafter, Victim-S was contacted by the alleged
shipper through text and voice
call
from
telephone number
(361)
441-0347.
The alleged shipper claimed that
transportation
issues
arose and
indicated that a
payment
of
$900
was needed
to
provide
a special cage for the dog
to breathe in cargo transport.
Pursuant to
the alleged shipper's instruction, on April 27,2019,
Victim-5
sent
$900
via
MoneyGram from a Walmart in Frazer Township, Pennsylvania
to another
individual in Pennsylvania. Based on an unknown issue reported by the alleged shipper, the
payment
had to be resent. OnAprt27,2019, Victim-S sent
$900
via MoneyGram from a Walmart
in Frazer Township, Pennsylvania to an
individual with the initials E.B. in the State of Florida.
Subsequently,
Victim-5 received a
text from an unknown
number indicating that a USDA
permit
was needed
for the chihuahua
puppy
at a cost of$650-$2,200.
Victim-5
refused to
provide
any
additional
payments
and confronted
the alleged
shipper
by
phone.
Nevertheless,
no dog was
delivered
and no refund
was
provided.
50.
As discussed
above,
pursuant
to a
search warrant,
Google
provided records
for
Google
Voice
number
(434)
298-4502.
Among
the
nearly
20,000
inbound
and outbound
test
messages
for
(434)
298-4502
were over
100
messages
exchanged
with victim-5's
phone
number
t1
Case 2:20-mj-01365-MPK
*SEALED*
Document 4
Filed
OGl3Olzo
Page 18 of 25
between April 21,2019, and April
27,2019,
that
induced Victim-5 to lose
$1,500.
G. Victim-6
51. On
May 29, 2020,
your
Affiant interviewed Victim-6,
a resident of Pittsburgh,
Pennsylvania, which is located in the Western
District
of
Pennsylvania.
52. Victim-6
was
searching on-line
to
purchase
a
puppy
in early January
2020
and
located a website that advertised
multiple available dogs for sale.
Victim-6 requested more
information
from the website concerning a
puppy.
Victim-6 was contacted by the alleged seller
and had contact via telephone
and text. Victim-6 became suspicious
of the alleged seller based
upon the communications
and did not send any
payments.
53.
As discussed
above,
pursuant
to a search warrant, Google
provided
records
for
Google Voice number
(434)
214-8514. Among the
inbound
and outbound
text
messages for
Google
Voice
phone
number
(434)
Zl4-8514 were 55 text messages that were exchanged with
Victim-6's
phone
number
between January
23,2020, and January 24,2020, that attempted to
induce Victim-6 to
pay
for a
"puppy."
CONCLUSION
54.
Based on the above information,
your
Affiant submits that
probable
cause exists
that DESMOND FODJE BOBGA has violated Title 18,
United States Code, Sections 1349
(Fraud
Conspiracy), 1343
(Wire
Fraud), 505
(Forging
Seal ofCourt), 1028A
(Aggravated
Identity
Theft).
l8
Case
2:20-mj-01365-MPK
*SEALED*
Document 4 Filed OGl3OlzO Page 19 of 25
The above information is true and correct to the best
ofmy knowledge, information, and
belief.
Respectful
ly subm itted,
/s/ Joseph
J.
Ondercin
Joseph
J.
Ondercin
Special
Agent,
Federal Bureau
of
Investigation
Subscribed and swom to before me
this 30th day ofJune,2020
MAUREEN
P. KELLY
United States Magistrate Judge
t9
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=>
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PU PPITS AIFO ROAETE, NOICHEAT'i"
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Name. . . Nora
Current Status: Avallable
Gender:
Female
Age: 10 Weeks
Prlce
:
1450
All Breed Reglstratlon
papers,FULL
Reglstratlon, Pedlgree, Health record, 1
year
health
guarantee,
Health certlflcate,
puppy
travellng
crate and
play
to)6.Current on
shots/vacclnes and
dewormlng.
Name. Teeny
Llly
Current Status: Avallable
Gender:
Female
Age: 9 Weeks
Prlce :
1450
All Breed Reglstratlon
papers,FULL
Reglstratlon, Pedlgree, Health
record,
I
year
health
guarantee,
Health certlflcate,
puppy
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OGl3Ol20 Page 2L ot 25
Name.
Teeny
Llly
Current Status: Available
Gender:
Female
A8e:
9 Weeks
Prlce
:
$450
All
greed
Reglstration
papers,FULL
Re8lstratlon,
PedlSree,
Health record, 1
year
health
guarantee,
Health certificate,
puppy
traveling
crate and
play
toys(urrent
on
shots/vacclnes
and
daivormlng.
Corltll^r or
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EXHIBTT 2
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Name.
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.
Nora
Current Status: Available
Gender: Female
Age:
I 0
Weeks
Prlce : $45o
All Breed Reglstration
papers,FULL
Reglstratlon, Pedlgree,
Health
record,
1
year
health
guarantee,
Health certlflcate,
puppy
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on
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Case
2:20-mj-01365-MPK
*SEALED*
Document 4 Filed 06130120 Page 22 ot 25
Name:
Snow
Whlte
current Status: Available
Gender:
Female
Age:
9 weeks
Prlce :
$450
All
Breed Reglstratlon
papers,FuLL
Reglstratlon,
Pedlgree, Health record, I
year
health
guarantee,
Health
certlflcatE
puppy
travellng
crate and
play
toys.Current on
shots/vaccines
and
dewormhg,
1
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Name Bentley
Current Status:
Available
Gender: Male
Age: 9 Weeks
Prlce
: $450
All
Breed
Retlstration
papers,FULL
Registration,
PediBree, Health record, 1 year
health
guarantee,
Health
certlficate,
puppy
traveling
crate and
play
toys.Current on
shots/vaccines
and
deworming,
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Name...Leo
current
Status: Avallable
Gender: Mele
A8e:
10
Weeks
Prlce :
3450
All Breed ReBlstratlon
papers,
FULL
Re8lstratlon, Pedlgree, Health record,
1
year
health
guarantee,
Health
certlflcate,
puppy
travellng
crate and
play
toys,Current
on
shots/vacclnes
and derrvormlng.
Case
2:20-mi-01365-MPK
*SEALED*
Document 4 Filed 06130120 Page 23 of 25
\
Name ;
Bentley
Current Status: Available
Gender: Male
Age:
9 Weeks
All
Breed
Registration
papers,FULL
Registration.
Pedigree,
Health
record,
1
year
health
guarantee.
Health
certifi(ate,
puppy
travellng crate and
play
toys.Current
on
shotYvaccines
and deworming.
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Name:
Panda
Current Statu5;
Avallable
Gender:
Male
Age: 8 Weeks
Price
:
3450
All Breed Registratlon
papers,Full
Retistration,
Pedigree, Health record, 1
year
health
guarantee,
Health
certlficate,
puppy
traveling
crate and
play
toys.Current
on
shots/vacclne5 and deworming.
Name
: Tommy
current status: Avallable
Gender:
Male
Age:
l0
Weeks
Prlce
:
$450
All
Breed
Reglstration
papers,FULL
Registratlon, Pedl8ree,
Health
record,
I
year
health
tuarantee,
Health
certlficate,
puppy
traveling
crate
and
play
toys.Current on
shots/vaccines
and
deavormlnB,
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Case 2:20-mj-01365-MPK
*SEALED*
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2:20-mj-01365-MPK
*SEALED*
Document 4 Filed 06/30/20 Page 25
of
25
Age: 9 Weeks
Prlce
:
1450
All
Breed
Registration
papers,FULL
Reglstratlon,
Pedlgree,
Health record, I
year
health
Euarantee,
Health
(erttflcate,
puppy
travellng
crate and
play
toys.Current on
shots/vac(lnes and dewormhg.
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Name: Dan and Melody
sratus:
Avallable
Gender:
Female and Female
Age: 9
Weeks
Prlce :
t45o
All Breed ReSlstration
papers,FULL
Retlstratlon,
Pedltree,
Health
record,
1 year
health
Suarantee,
Health
certlflcate.
puppy
travelint crate
and
play
to)6.Current
on
shots/vacclnes and
dewormlng.
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