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AO
91 (Rev.
11
/
11
) Criminal Complaint
UNITED STATES DISTRICT
COURT
for the
FILED
No1them District
of
Ohio
2:38
pm
Jan
09
2020
Clerk U.S. District Court
United
St.
ates
of
America
V.
)
)
)
)
)
)
)
Northern District
of
Ohio
Cas
eNo.
l:20mj3016
Cleveland
JAMIE KIDD-DUNBAR
Defendant(s)
CRIMINAL COMPLAINT
I, the complaina
nt
in this
ca
se, state that the following is trne to the best
of
my knowledge a
nd
belief.
On or about the date(s)
of
Janaury, 2018, to June, 2019 in the county
of
Lorain
Northern
District
of
Ohio, and elsewhere , the defendant(s) violated:
Code Section
18 U.S.C., Section 1343
Wire Fraud
This criminal complaint is based on these facts:
See attached affidavi
t,
whi
ch
is incorporated herein by reference
'if
Continued on the attached sheet.
Sworn to via telephone after submission by reliable
electronic means. Fed.
R.
Crim. P. 4.1 a
nd
4l (d)(3).
Da
te:
01
/09/2020
Off
ense Description
Com
pl
aina
nt
's signature
Matt Richter, FBI Special Agent
P
ri
nt
ed
name a
nd
title
in the
---
City a
nd
state:
Cleveland, Ohio
Thomas M. Parker, U.S. Magustrate Judge
P
ri
nt
ed
name a
nd
title
AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT
I, Matt Richter, being duly sworn, do hereby state as follows:
I. INTRODUCTION
1. I am a Special Agent with the Federal Bureau of Investigation (“FBI”) and have
been so employed since March of 2019. I graduated from the FBI Academy in Quantico,
Virginia, where I received extensive training in the area of criminal investigations conducted by
the FBI, including the investigations of financial crimes. I am currently assigned to the FBI
Cleveland Division Headquarters and its White Collar Crimes Squad. I am empowered to make
arrests for federal offenses. I am presently assigned to work a variety of criminal matters,
including financial crimes, which include bank fraud, securities fraud, corporate fraud, mail
fraud, wire fraud, money laundering, and other violations of Federal Law. Before becoming a
Special Agent for the FBI, I was a Certified Public Accountant, working at General Electric for
three years and Deloitte for three years.
2. As a Special Agent, I am a Federal Law Enforcement Officer within the meaning
of Rule 41(a) of the Federal Rules of Criminal Procedure: that is a government agent engaged in
the enforcement of criminal laws of the United States and, thereby, authorized to request the
issuance of federal search warrants. As a Special Agent, I have participated in complex financial
investigations. I have participated in the execution of arrest warrants.
3. The statements contained in this Affidavit are based upon, among other things, the
information provided by witnesses, public records, and my experience and training. Unless
otherwise indicated, all conversations and statements described in this Affidavit are related in
substance and part. This Affidavit is intended only to establish sufficient probable cause for the
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2
requested criminal complaint and arrest warrant and therefore does not set forth all of my
knowledge about this matter.
4. This Affidavit is made in support of an application for a criminal complaint and
an arrest warrant for JAMIE KIDD-DUNBAR for violations of Title 18, United States Code,
Sections 1343 (Wire Fraud).
II. THE INVESTIGATION
5. The investigation revealed that KIDD-DUNBAR, the Home Health Aide of
VICTIM-1, devised a scheme to defraud VICTIM-1 and VICTIM-1’s aunt, VICTIM-2 out of
$347,000.00 from their bank accounts. VICTIM-1 is a resident of Elyria, Ohio. VICTIM-1 has
suffered multiple strokes, is legally blind, and confined to a wheelchair. DUNBAR became the
Home Health Aide for VICTIM-1 in March of 2016. DUNBAR had access to VICTIM-1’s
Huntington Bank debit card for the sole purpose of purchasing groceries and other necessities on
VICTIM-1’s behalf. VICTIM-1 and DUNBAR were the only individuals who had access to this
card.
6. VICTIM-1 contacted the Elyria Police Department (“EPD”) on June 25, 2019,
because she suspected DUNBAR had made unauthorized transactions on VICTIM-1’s
Huntington Bank debit card. VICTIM-1 provided copies of her Huntington Bank statements to
the EPD from November 2018 to June 2019. VICTIM-1 indicated unauthorized transactions on
these bank statements totaling $97,614.94 for this period. The transactions, among others,
included purchases at retailers, including but not limited to Macy’s, Wal-Mart, Flingers Market,
Aldi, Lowes, Midview Local Schools, North Ridgeville Animal Clinic, Rent-A-Center, Metro
PCS, Olive Garden, Red Lobster, ATM withdrawals, and other transfers. VICTIM-1 also
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suspected DUNBAR had unauthorized transactions related to her aunt, VICTIM-2. DUNBAR
was also a Home Health Aide for VICTIM-2. VICTIM-2 passed away in 2017.
7. One category of unauthorized transactions was noted as “Discover Phone Pay” on
the Huntington Bank statements. “Discover Phone Pay” is an option to pay off a Discover Bank
Credit Card. VICTIM-1 did not have an account with Discover Bank, nor did she make any
payments to Discover Bank. The “Discover Phone Pay” amounts and dates matched to payments
made on VICTIM-2’s Discover Credit Card. The charges made on VICTIM-2’s Discover Credit
Card were after VICTIM-2’s death.
8. VICTIM-1 identified fraudulent ATM withdrawals on her Huntington Bank
Statements. Surveillance footage of four of these withdrawals matches the description of
DUNBAR.
9. Through the review of information provided by retailers, other fraudulent charges
made to Rent-A-Center, Midview Local Schools, First Energy Corp., TruGreen Lawn Care, and
AT&T were all made by DUNBAR. EPD obtained a copy of the Rent-A-Center customer
contract related to the fraudulent purchases. The contract agreement was for a customer named
Jamie Dunbar at the address 1316 New Mexico Ave, Lorain, Ohio, which is a known address of
DUNBAR. EPD also spoke to the Treasurer of Midview Local Schools, who confirmed that the
charges were made on an account for DUNBAR. EPD obtained returned subpoenas from First
Energy Corp., which showed the charges were under account CHARLES DUNBAR, the
husband of DUNBAR, at address 12314 Alton Drive, Grafton, Ohio, 44044, which is the
residences the DUNBAR’s purchased in August of 2018. EPD also received subpoena responses
from TruGreen Lawn Care and AT&T, which showed charges were related to a customer
account belonging to DUNBAR. Other purchases VICTIM-1 claimed she would never make,
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including but not limited to auto loan payments, Kay Jewelers, Elyria Liquor, and Wal-Mart
purchases.
10. On August 20, 2019, Elyria Police Detectives arrested DUNBAR for Theft (F-
4) and Misuse of Credit Cards (F-4) charges. Atfer the arrest, Elyria Police Detectives conducted
a recorded interview of DUNBAR. DUNBAR confessed to using VICTIM-1 and VICTIM-2’s
debit and credit cards to make unauthorized transactions. DUNBAR stated that VICTIM-2
passed away in November of 2017, and DUNBAR began using her Discover credit card in
January of 2018. DUNBAR reviewed the list of unauthorized transactions noted by VICTIM-1
for the period of November 2018 to June 2019 for a total of $97,614.94 and admitted to
committing the purchases and transactions.
11. On August 28, 2019, VICTIM-1 notified Elyria Police Detectives that her same
Huntington Bank debit card had unauthorized charges since January of 2018. The total amount
of unauthorized transactions for the period of January 2018 to October 2018 was $249,618.04,
bringing the total charges to 347,232.50. Many of these charges were to the same vendors as
those DUNBAR admitted to using from November 2018 to June of 2019, including Rent-A-
Center, Dish Network, North Ridgeville Animal Clinic, Metro PCS, “Discover Phone Pay,” First
Energy Corp., and auto loan payments.
12. For the purpose of executing and attempting to execute the scheme and artifice to
defraud described above, KIDD-DUNBAR transmitted and caused to be transmitted by means of
wire communication in interstate commerce, writings, signs, signals, pictures, and sounds, to wit:
KIDD-DUNBAR made payments via “Discover Phone Pay” that crossed state lines.
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II. CONCLUSION
13. Based upon the totality of the facts and circumstances set forth herein, and based
upon my training and experience, there is probable cause to believe that JAMIE KIDD-
DUNBAR committed violations of Title 18, United States Code, Section 1343 (Wire Fraud).
Accordingly, I respectfully request that the Court issue a warrant authorizing the arrest of JAMIE
KIDD-DUNBAR.
______________________________________
Matt Richter, Special Agent
Federal Bureau of Investigation
2:28 PM, Jan 9, 2020
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Sworn
to
via telephone
after
submission by reliable electronic
means. Crim.Rules. 4.1; 41(d)(3)
United States Magistrate Judge
