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Firm”) lost approximately $922,857.76. The messages reflected that part of the
scheme, including acts in furtherance of the conspiracy, occurred while
Coconspirator 2 was physically present in the Central District of California.
20. Records obtained from JPMorgan Chase Bank (“Chase”) for a bank
account held in the U.S. (the “Chase Account”) reflect that the Chase Account
received a wire transfer on October 15, 2019 for approximately $922,857.76 from
the Victim Law Firm. On October 17, 2019, there was a wire transfer from the
Chase Account to an account at Canadian Imperial Bank of Commerce (“CIBC”),
in Toronto, Ontario, for approximately $396,050. Bank records reflect that the
specific account at CIBC ended in 1716 (the “CIBC Account”), consistent with
what is discussed below in paragraphs 21, 24, and 25. The remaining funds in the
Chase Account were transferred to other accounts.
21. Based on review of data from Coconspirator 1’s iPhone, on or around
October 17, 2019, ABBAS, using what appeared to be the Snapchat account
“hushpuppi5,” sent an image of a Chase wire confirmation to Coconspirator 1.
The image appeared to show a wire transfer form related to a transfer of
approximately $396,050 from the Chase Account to the CIBC Account, which,
based on other messages on Coconspirator 1’s iPhone, appears to have been held
by Coconspirator 2.
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22. On April 14, 2020, I interviewed S.R., owner of the Victim Law Firm,
about the above-referenced wire sent on October 17, 2019. On April 16, 2020, I
interviewed N.C., who was an attorney and co-worker of S.R., and on May 21,
2020, I interviewed K.C., a paralegal of the Victim Law Firm. Based on these
interviews, I learned the following:
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The “Sender” information in the image was blocked by a Chase bank
business card, but other bank records show that this transaction involved the Chase
Account.