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STATEMENT OF FACTS
The United States and the Defendant, USMAN MUHAMMED, agree that, at trial, the
United States would have proven the following facts beyond a reasonable doubt with admissible
and credible evidence:
1.
From at least in or about the later part of 2010 through in or about June 2011,
USMAN MUHAMMED conspired with William Samuel Martin, Olubunmi Oladapo Komoiafe, Raoul Lycorish, Anthony Danero Thomas and others in an identity theft ring. 2. MUHAMMED and his coconspirators recruited, trained, and paid restaurant servers
to swipe customers' credit cards through a skimmer when those customers paid for their meals.
3. MUHAMMED and his coconspirators used device-making equipment to re-encode
credit cards and gift cards with stolen credit card numbers.
4. MUHAMMED and his coconspirators used re-encoded credit cards and gift cards to
purchase merchandise and gift cards at stores located in Virginia, Maryland, and Pennsylvania.
5.
MUHAMMED and his coconspirators recruited, trained, and paid "runners" to a) use
re-encoded credit cards and gift cards to purchase merchandise and gift cards and b) return
6.
operated device-making equipment, connected to a laptop computer to re-encode credit cards. 7. On or about February 22,2011, MUHAMMED and a coconspirator transferred re-
8.
On or about February 22,2011, CC-3 purchased $500 of gift cards at a Target store
in Wheaton, Maryland. CC-3 paid for the gift cards with a re-encoded credit card. The magnetic
stripon the back of the creditcard was re-encoded with Capital One Bank account number ending
in 2689.
9.
The cost of the February 22,2011 transaction was charged to Capital One Bank
10.
At the time of the transaction, Capital One Bank account number ending in 2689
belonged to Jennifer F., who was an account holder at Capital One Bank. MUHAMMED did not
have lawful authority to use the account number.
11.
On or about July 14, 2011, MUHAMMED had on his person four (4) counterfeit and
12.
On or about July 14, 2011, MUHAMMED possessed one hundred and twenty (120)
skimmed creditcard numbers in the Eastern District of Virginia and elsewhere between January
2010 and June 2011.
14.
All of the credit card numbers used by MUHAMMED and his coconspirators
belonged to real individuals, and MUHAMMED knew that those credit card numbers belonged to
real individuals. MUHAMMED did not have lawful authority to use any of those account numbers
to effect transactions.
15.
victims.
The actions of MUHAMMED and his coconspirators involved more than 250
16.
This Statement of Facts includes those facts necessary to support the Plea Agreement
between the Defendant and the Government. It does not include each and every fact known to the
Defendant or to the Government, and it is not intended to be a full enumeration of all of the facts
17.
The actions of the Defendant, as recounted above, were in all respects knowing and
deliberate, and were not committed by mistake, accident, or other innocent reason. 18. This Statement of Facts signed by the Defendant shall be admissible as a knowing
and voluntary confession in any proceeding against the Defendant regardless of whether the Plea Agreement is presented to, or accepted by, a court. Moreover, the Defendant waives any rights that
the Defendant may have under Fed. R. Crim. P. 11(0, Fed. R. Evid. 410, the United States Constitution, and any federal statute or rule to object to the admissibility of the Statement of Facts in any such proceeding.
Respectfully submitted,
Neil II. MacBridc
By:
/JajLj^j y. &(t
Andrew K. Mann 2100 Jamieson Avenue
^ w/\___
Andrcw.Mann@usdoj .gov
After consulting with my counsel, I hereby stipulate that the above Statement of Facts is true
and accurate, and that had the matter proceeded to trial, the United States would have proved the
same beyond a reasonable doubt.
I am the counsel for USMAN MUHAMMED. I have carefully reviewed the above
Statement of Facts with the Defendant. To my knowledge, the Defendant's decision to stipulate to
these facts is informed and voluntary.
'f>
By:
Peter D. Greenspun
Counsel for the Defendant