Natalia Chi
Damian Williams, United States Attorney for the Southern District of New York, and Jocelyn E. Strauber, Commissioner of the New York City Department of Investigation (“DOI”), announced today the unsealing of a Complaint charging RUDEAN WEIR and JEROME WEAH, with conspiracy to commit wire fraud, wire fraud, and aggravated identity theft, in connection with a scheme to defraud a program of the New York City Human Resources Administration (“HRA”) which provides cash assistance to homeless veterans of the United States armed services (“Veterans”) seeking permanent housing. WEAH was presented yesterday in Manhattan federal court before United States Magistrate Judge Valerie Figueredo. WEIR will be presented today in federal court in Atlanta, Georgia.
U.S. Attorney Damian Williams said: “As alleged, the defendants abused a New York City program intended to benefit veterans of the United States armed services seeking permanent housing by submitting hundreds of false applications for benefits and causing more than $5 million in fraudulent payments. Thanks to the efforts of the New York City Department of Investigation, the fraud has been exposed and the defendants will have to answer for their conduct.”
DOI Commissioner Jocelyn E. Strauber said: “The Enhanced One-Shot Deal program provides critical funding to help New York City’s unhoused veterans obtain permanent housing. As alleged, defendants Jerome Weah and Rudean Weir stole millions of dollars from the program by fraudulently claiming entitlement to rent, brokers’ fees and other program payments. I thank the City’s Department of Social Services for referring this investigation to DOI and for their hard work on this matter. DOI is proud to work with DSS, and our federal partners at the U.S. Attorney’s Office for the Southern District of New York and the Office of Inspector General for the U.S. Department of Veterans Affairs, to expose and prevent the theft of precious public funding intended to aid vulnerable New Yorkers.”
As alleged in the Complaint unsealed today in Manhattan federal court
From at least October 2020 through at least May 2022, RUDEAN WEIR and JEROME WEAH submitted more than 340 fraudulent applications seeking cash assistance pursuant to the Enhanced One Shot Deal (“EOSD”) program administered by the HRA. The EOSD is an emergency assistance program pursuant to which HRA makes a one-time cash assistance payment to qualifying individuals. EOSD payments are often used to help individuals move out of homeless shelters and/or other temporary housing into permanent housing. EOSD payments may be used to cover certain costs associated with the move to permanent housing, including rent, moving expenses, security deposits, broker’s fees, and payments for furniture and other household items. The HRA also offers and administers services and programs for Veterans, sometimes referred to as “Veteran’s Initiatives.” In connection with these services, the HRA has a designated group responsible for receiving and reviewing EOSD requests made on behalf of homeless Veterans seeking permanent housing.
Between October 2020 and May 2022, the HRA received at least 340 EOSD applications which claimed that the applicants were homeless Veterans who had entered into a lease agreement with a particular landlord (“Landlord-1”). Each of these applications (the “Landlord-1 EOSD Applications”) claimed that a particular company provided broker’s services in connection with the lease agreement (“Broker Company-1”). HRA paid over $5.4 million in EOSD payments and broker’s fees pursuant to the Landlord-1 EOSD Applications.
Based on a review of approximately 60 of the 340 Landlord-1 EOSD Applications, those applications included, among other things, a completed application for “Emergency Assistance” on an HRA designated form; a copy of a purported lease agreement between a Veteran and Landlord-1; forms requesting payment to Landlord-1 and Broker Company-1 for services provided; personal identifying information, such as copies of identification cards and military and/or employment records for the Veteran; and an identification card issued by the New York Department of State reflecting one of two individuals and purporting that each of those individuals was a “Real Estate Salesperson” with Broker Company-1.
The Landlord-1 EOSD Applications were fraudulent. Specifically, Landlord-1 and the Veterans did not, in fact, enter into the lease agreements submitted to HRA in connection with the Landlord-1 EOSD Applications, and Broker Company-1 did not provide real estate brokerage services to either Landlord-1 and/or the Veterans. Furthermore, the identification cards reflecting purported individual brokers associated with Broker Company-1 were forged, in that those brokers are not affiliated with Broker Company-1 and did not provide any real estate brokerage services to either Landlord-1 and/or the Veterans. Therefore, the Landlord-1 EOSD Applications contained fake documentation and information, and fraudulently induced HRA into making EOSD payments.
HRA made EOSD payments of at least $5.4 million in connection with the Landlord-1 EOSD Applications. Of this $5.4 million, over $3.6 million was deposited into a bank account controlled by WEIR, and over $1 million was deposited into a bank account controlled by WEAH. In addition, during this period, the bank account controlled by WEIR paid over $1 million to a bank account held in the name of WEAH.
WEIR, 37, of Atlanta, Georgia, and WEAH, 46, of Edison, New Jersey, are charged with conspiracy to commit wire fraud and wire fraud, each of which carries a maximum sentence of 20 years in prison, and one count of aggravated identity theft, which carries an additional mandatory consecutive two-year sentence.
The maximum potential sentences in this case are prescribed by Congress and are provided here for informational purposes only, as any sentencing of the defendant will be determined by the judge.
The charges contained in the Complaint are merely accusations, and the defendants are presumed innocent unless and until proven guilty.
Mr. Williams praised the outstanding investigative work of the DOI. Mr. Williams also thanked the DSS and the U.S. Department of Veterans Affairs, Office of Inspector General, for their assistance.
This case is being handled by the Office’s General Crimes Unit. Assistant United States Attorney Matthew Weinberg is in charge of the prosecution.
As the introductory phrase signifies, the entirety of the text of the Complaint and the description of the Complaint set forth in this release constitute only allegations, and every fact described should be treated as an allegation.
executing such scheme and artifice, in violation of Title 18, United States Code, Section 1343.
(Title 18, United States Code, Section 1349 and 2.)
COUNT TWO (Wire Fraud)
3. From at least in or about October 2020 up to and
including May 2022, in the Southern District of New York and
elsewhere, RUDEAN WEIR and JEROME WEAH, the defendants, having
devised and intending to devise a scheme and artifice to
defraud, and for obtaining money and property by means of false
and fraudulent pretenses, representations, and promises,
knowingly transmitted and caused to be transmitted by means of
wire, radio, and television communication in interstate and
foreign commerce, writings, signs, signals, pictures, and
sounds, for the purpose of executing such scheme and artifice,
to wit, WEIR and WEAH caused the electronic submission of
fraudulent applications to the New York City Human Resources
Administration (“HRA”) in connection with an HRA social services
program that provides cash assistance to homeless veterans of
the United States armed services (“Veterans”) seeking permanent
housing, and received payments from HRA in connection with those
fraudulent applications.
(Title 18, United States Code, Section 1343 and 2.)
COUNT THREE
(Aggravated Identity Theft)
4. From at least in or about October 2020 up to and
including May 2022, in the Southern District of New York and
elsewhere, RUDEAN WEIR and JEROME WEAH, the defendants,
knowingly did transfer, possess, and use, without lawful
authority, a means of identification of another person, during
and in relation to a felony violation enumerated in Title 18,
United States Code, Section 1028A(c), to wit, WEIR and WEAH used
names and other identifying information of Veterans and real
estate brokers in connection with fraudulent applications for
cash assistance payments from the HRA made during and in
relation to the conspiracy to commit wire fraud and wire fraud
violations charged in Count One and Count Two of this Complaint.
(Title 18, United States Code, Sections 1028A(a)(1), 1028A(b),
and 2.)
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The bases for my knowledge and for the foregoing charges
are, in part, as follows:
5. I am a Special Investigator with the DOI and I have
been personally involved in the investigation of this matter.
This affidavit is based upon my personal participation in the
investigation of this matter, my conversations with other law
enforcement officers and government employees, as well as my
examination of reports and other records. Because this
affidavit is being submitted for the limited purpose of
demonstrating probable cause, it does not include all the facts
that I have learned during the course of my investigation.
Where the contents of documents and the actions, statements, and
conversations of others are reported herein, they are reported
in substance and in part, except where otherwise indicated.
The HRA Enhanced One Shot Deal Program and Veteran’s Initiatives
6. Based on my review of publicly available information
and my communications with employees of the HRA, I know the
following:
a. HRA is a New York City agency within the city’s
Department of Social Services (“DSS”) and is responsible for
administering social service and cash assistance programs on
behalf of New York City.
b. Among the programs administered by HRA are “One
Shot Deal” and “Enhanced One Shot Deal” (“EOSD”) cash assistance
payments. The EOSD is an emergency assistance program pursuant
to which HRA makes a one-time cash assistance payment to
qualifying individuals.
c. EOSD payments are often used to help individuals
move out of homeless shelters and/or other temporary housing
into permanent housing. In order to be approved for an EOSD,
applicants must first find housing that they can afford on their
own income. After identifying the housing, the applicant may
request an EOSD payment to help cover certain costs, including
rent, moving expenses, security deposits, broker’s fees,
payments for furniture and other household items, and payments
relating to the storage of furniture and other personal
belongings.
d. EOSD applications for permanent housing are
typically completed with the assistance of the shelter and/or
temporary housing provider where the applicant is residing while
seeking to obtain the permanent residence.
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e. The HRA also offers and administers services and
programs for Veterans. In connection with these services,
sometimes referred to as “Veteran’s Initiatives,” the HRA has a
designated group responsible for receiving and reviewing EOSD
requests made on behalf of homeless Veterans seeking permanent
housing.
The Defendants Submit Hundreds of Fraudulent EOSD Applications
and Cause Over $5.4 Million in Fraudulent Payments
The Landlord-1 EOSD Applications
7. Based on my review of bank account statements and
records from the New York State Department of Labor, I know that
RUDEAN WEIR and JEROME WEAH, the defendants, are employed by or
otherwise receive compensation from a New York City based
organization (“Organization-1”) that provides temporary housing
to Veterans experiencing homelessness and assists those Veterans
in finding permanent housing.
8. Based on my review of materials provided by the HRA, I
know that, between October 2020 and May 2022, HRA received at
least 340 EOSD applications which claimed that the applicants
had entered into a lease agreement with a particular landlord
(“Landlord-1”). Each of these applications (the “Landlord-1
EOSD Applications”) claimed that a particular company provided
broker’s services in connection with the lease agreement
(“Broker Company-1”). HRA paid over $5.4 million in EOSD
payments and broker’s fees pursuant to the Landlord-1 EOSD
Applications.
9. Based on my review of approximately 60 of the more
than 340 Landlord-1 EOSD Applications (the “Reviewed Landlord-1
EOSD Applications”), I know the following:
a. The Reviewed Landlord-1 EOSD Applications claim
that the applicant seeking the EOSD payment is a Veteran (the
“Purported Homeless Veterans”).
b. The Reviewed Landlord-1 EOSD Applications were
submitted by email to HRA’s dedicated group for Veterans’
housing programs.
c. The vast majority of the Reviewed Landlord-1 EOSD
Applications were sent from an email address at Organization-1
held in the name of RUDAEN WEIR, the defendant (the “Weir
Organization-1 Email Address”). The applications submitted via
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email by the Weir Organization-1 Email Address also cc’d a
particular email address (“Email Address-1”) maintained by a
provider of Internet and email services (“Email Service
Provider-1”). Certain other of the Reviewed Landlord-1 EOSD
Applications were submitted via email to the HRA by Email
Address-1, rather than by the Weir Organization-1 Email Address.1
d. Each of the Reviewed Landlord-1 EOSD Applications
included, among other things:
i. A completed application for “Emergency
Assistance” on an HRA designated form;
ii. A copy of a purported lease agreement
between the Purported Homeless Veteran and Landlord-1;
iii. Forms requesting payment to Landlord-1 and
Broker Company-1 for services provided;
iv. Personal identifying information, such as
copies of identification cards and military and/or employment
records for the Purported Homeless Veteran; and
v. An identification card purportedly issued by
the New York State Department of State (“DOS”), Division of
Licensing Services, reflecting one of two individuals
(“Purported Individual Broker-1” and “Purported Individual
Broker-2”) and identifying Purported Individual Broker-1 and
Purported Individual Broker-2 as a licensed “Real Estate
Salesperson” with Broker Company-1.
10. The Landlord-1 EOSD Applications were fraudulent.
Specifically, based on my participation in this investigation,
and as detailed below, I know that Landlord-1 and the Purported
Homeless Veterans did not, in fact, enter into the lease
agreements submitted to HRA in connection with the Landlord-1
EOSD Applications, and Broker Company-1 did not provide real
estate brokerage services to either Landlord-1 and/or the
Purported Homeless Veterans. Furthermore, the identification
cards reflecting Purported Individual Broker-1 and Purported
Individual Broker-2 were forged, in that Purported Individual
Broker-1 and Purported Individual Broker-2 are not affiliated
1 Based on my review of records from Email Service Provider-1, I
understand that Email Service Provider-1 does not have email
servers in New York state. Therefore, I understand that emails
sent from Email Address-1 necessarily travelled interstate
before being received by the HRA in New York.
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with Broker Company-1 and did not provide any real estate
brokerage services to either Landlord-1 and/or the Purported
Homeless Veterans.
The Landlord-1 EOSD Applications Contained Fraudulent
Information and False Documents
11. Based on my review of publicly available sources,
including Internet searches, I have identified no evidence that
Landlord-1 owns any residential real estate properties in New
York City, much less that Landlord-1 owns the 60 properties
identified in the Reviewed Landlord-1 EOSD Applications or the
additional properties identified in the over 340 Landlord-1 EOSD
Applications. For example, I have searched for the name of
Landlord-1 in a widely used, publicly available real estate
website which contains information about residential listings in
New York City, and have not identified any buildings, agents,
and/or management companies affiliated with Landlord-1. Nor
have I identified a public website for Landlord-1 advertising
residential real estate listings, as I know that landlords often
use to attract potential tenants. In fact, based on my review
of records provided by the DOS, I understand that the DOS has no
record of Landlord-1 being registered as a business in the state
of New York in any capacity.
12. Based on my review of personnel files obtained from
the United States Department of Veteran Affairs (the “VA”), I
know that at least seven of the Purported Homeless Veterans are
actually employed by the VA. These seven individuals have each
worked outside of New York City for at least the past four
years. According to VA records, they do not presently reside in
New York City and did not reside in New York City during the
time period that the Reviewed Landlord-1 EOSD Applications were
submitted to the HRA.
13. In the course of this investigation, I have
interviewed two of the Purported Homeless Veterans who received
EOSD payments in connection with Landlord-1 EOSD Applications.
These Purported Homeless Veterans both reported that they do not
currently live in New York City and have never lived in New York
City. Both of these Purported Homeless Veterans stated that
they were told by a friend that they could be eligible for
benefits relating to the COVID-19 pandemic available to Veterans
and to contact a particular email address (“Email Address-2”)
maintained by an email service provider (“Email Service
Provider-2”) to apply for those benefits. Specifically:
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a. One Veteran (“Veteran-1”) reported that he was
told by a friend about a COVID-19 relief fund for Veterans. The
friend told Veteran-1 to send an email to Email Address-2 in
order to apply for funds. Veteran-1 contacted Email Address-2
in or about December 2021. Veteran-1 received a check that he
understood to be related to COVID-19 relief funds. Veteran-1
was not familiar with Landlord-1 or Broker Company-1.
b. The second Veteran (“Veteran-2”) reported that he
was told about a COVID-19 relief fund for Veterans by Veteran-1.
Veteran-2 contacted Email Address-2 to apply for the funds in or
about February 2022. Veteran-2 submitted his identification and
proof of veteran status to Email Address-2 and stated that he
was seeking “COVID VA Support.” Email Address-2 responded to
confirm that the materials received from Veteran-2 would be
submitted on his behalf. Veteran-2 was not familiar with
Landlord-1 or Broker Company-1, and did not know why he had
received a check that appeared to be issued by New York City in
connection with rental assistance. Veteran-2 also provided to
the DOI copies of emails he exchanged with Email Address-2 and
another email address (“Email Address-3”) about his application
and receipt of funds.
14. In April 2022, DOI personnel visited six of the
addresses included in the Landlord-1 EOSD Applications as
purportedly being residences subject to a lease agreement
between a Purported Homeless Veteran and Landlord-1. The DOI
personnel identified no evidence suggesting that Landlord-1 was
affiliated with any of the residential addresses and/or that the
Purported Homeless Veteran identified in the EOSD applications
ever lived at any of the addresses. Rather, based on my own
participation in these visits and my communications with other
DOI personnel, I know the following:
a. At two of the six addresses, DOI personnel spoke
to the current tenant. Those tenants were not the Purported
Homeless Veteran and were not familiar with the Purported
Homeless Veteran.
b. At three of the six addresses, DOI personnel
knocked on the door but did not speak to the tenant. At one of
these three addresses, DOI personnel spoke to a neighbor who
provided a name for the tenant that did not match the name of
the Purported Homeless Veteran on the lease agreement for the
address. That neighbor was not familiar with the Purported
Homeless Veteran. At the other two addresses, DOI personnel
reviewed the building intercom and/or directory, and observed
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that the name listed for the tenant(s) of the relevant addresses
did not match the name of the Purported Homeless Veterans.
c. At the sixth address, DOI personnel could not
identify a building bearing the address. DOI personnel spoke to
an individual employed at a nearby building who confirmed that
there is no residential building bearing that address.
d. At the five of the six addresses that DOI
personnel confirmed were actual residential addresses, DOI
personnel either spoke to a tenant of the building or an
employee of the building, and/or otherwise identified
information about the landlord and/or management company of the
building available in the building’s common areas. None of
these sources indicated that Landlord-1 owned or was otherwise
affiliated with the building in any way.
15. Based on my communications with the DOS, I understand
that the name, picture, and license number on the identification
cards submitted for Purported Individual Broker-1 and Purported
Individual Broker-2 were true and correct, that is to say,
Purported Individual Broker-1 and Purported Individual Broker-2
are, in fact, registered real estate brokers. However,
Purported Individual Broker-1 and Purported Individual Broker-2
are not affiliated with Broker Company-1; rather, they are
affiliated with different real estate brokerage companies.
According to the DOS, there are no records reflecting that
Broker Company-1 is licensed to engage in real estate brokerage
services by New York State. Therefore, I understand that the
identification cards submitted to HRA depicting Purported
Individual Broker-1 and Purported Individual Broker-2 were
doctored in order to claim that those real estate agents were
affiliated with Broker Company-1.
16. For the reasons described above, I understand that the
Landlord-1 EOSD Applications contained fake documentation and
information, and fraudulently induced HRA into making EOSD
payments. In addition, I understand that the identities of the
Purported Homeless Veterans, Purported Individual Broker-1, and
Purported Individual Broker-2 were transferred, possessed, and
used without lawful authority during and in relation to the
submission of the Landlord-1 EOSD Applications to the HRA.
The Defendants Control Landlord-1 and Broker Company-1,
Submitted the Fraudulent Applications, and Received the Funds
17. Based on my review of HRA records, I know the
following:
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a. When the HRA approved EOSD payments in connection
with the Landlord-1 EOSD Applications, the payments were
typically issued by check. Specifically, separate checks were
issued to Landlord-1, Broker Company-1, and the Purported
Homeless Veteran. On certain occasions, payments to the
Purported Homeless Veteran were also issued through an
Electronic Benefit Transfer (“EBT”) card.
b. The checks issued in connection with the Reviewed
Landlord-1 EOSD Applications were picked up in person at an HRA
office in Manhattan. At the time that the checks were picked
up, the individual collecting the check was required to present
photographic identification and to sign an HRA form confirming
receipt of the check. For each of the Reviewed Landlord-1 EOSD
Applications, the individual who picked up the check signed in
as “Rudean Weir” and presented a photographic identification
card appearing to depict RUDEAN WEIR, the defendant.
Specifically, the individual picking up the check presented
WEIR’s employee identification card for Organization-1.
18. Based on my review of records for a bank account held
in the name of Landlord-1 (the “Landlord-1 Bank Account”) at a
particular bank (“Bank-1”), I know the following:
a. “Rudean Weir” is the signatory for the Landlord-1
Bank Account.
b. Between October 2020 and March 2022, at least
1,019 checks issued by the DSS totaling at least $3,608,950 were
deposited into the Landlord-1 Bank Account.2
c. Surveillance camera footage taken by ATMs
operated by Bank-1 appear to depict RUDEAN WEIR, the defendant,
accessing the Landlord-1 Bank Account. Specifically,
immediately below is a Georgia Department of Motor Vehicles
(“DMV”) photograph of WEIR. Below that photograph are two
images of WEIR accessing the Landlord-1 Bank Account from ATMs
located in the state of Georgia.
2 As stated supra paragraph 6.a, the HRA is an agency within the
DSS. Based on my training and experience and communications
with employees of the HRA, I understand that EOSD checks are
issued from a bank account held by the DSS.
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19. Based on my review of records for a bank account held
in the name of Broker Company-1 (the “Broker Company-1 Bank
Account”) at a particular bank (“Bank-2”), I know the following:
a. “Jerome Weah” is the signatory for the Broker
Company-1 Account.
b. Between October 2020 and March 2022, at least 335
checks issued by the DSS totaling at least $1,089,227 were
deposited into the Broker Company-1 Bank Account.
c. Surveillance camera footage taken by ATMs
operated by Bank-2 appear to depict JEROME WEAH, the defendant,
accessing the Broker Company-1 Bank Account. Specifically,
below on the left is a New Jersey DMV photograph of WEAH. Below
on the right is an image of WEAH accessing the Broker Company-1
Bank Account at a branch in Staten Island in December 2021.3
3 WEAH is wearing a mask in the photograph of him accessing the
bank account at a branch in Staten Island and, therefore, it is
difficult to compare his appearance to the photograph from the
DMV. However, as noted in paragraph 20, an individual matching
WEAH’s appearance was also captured by ATM footage depositing
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20. Based on my review of records from Bank-1, I know that
a Bank-1 ATM was used to withdraw funds from an EBT card
distributed by the HRA to a Purported Homeless Veteran in
connection with a Landlord-1 EOSD Application. I have reviewed
ATM camera footage taken from a location in New Jersey in
January 2022 depicting the withdrawal of funds from that EBT
card, which reflects the below individual, who I believe to be
JEROME WEAH, the defendant, accessing the account.
21. In addition, based on my review of records from Bank-1
and another bank (“Bank-3”) I know the following:
a. Between approximately December 2020 and March
2022, the Landlord-1 Bank Account at Bank-1 held in the name
“Rudean Weir” issued approximately 133 checks to “Jerome Weah”
totaling at least $1,009,000.
funds which had been sent by the DSS to a Purported Homeless
Veteran on an EBT card. I believe that WEAH is the masked
individual depicted at the branch in the photograph at paragraph
19.c in part because the individual at the branch is wearing the
same distinctive sweater as WEAH is wearing in the ATM footage
depicted in paragraph 20.
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b. The 133 checks issued by the Landlord-1 Bank
Account were all deposited into an account at Bank-3 held in the
name of “Jerome Weah” (the “Bank-3 Weah Account”).4
c. The account opening documents for the Bank-3 Weah
Account include a copy of the driver’s license for JEROME WEAH,
the defendant, which bears the same New Jersey DMV photograph of
WEAH depicted in paragraph 19.c supra.
d. In addition to the 133 checks issued from the
Landlord-1 Bank Account and deposited into the Bank-3 Weah
Account, on or about December 2, 2020, the Landlord-1 Bank
Account sent a wire transfer in the amount of $24,000 to the
Bank-3 Weah Account.
22. In addition, based on my review of records from Email
Service Provider-1, Email Service Provider-2, and cellular phone
service providers, I know the following:
a. The recovery phone number for Email Address-1 –
that is, the phone number which can be used to access Email
Address-1 if the user of the account loses the password – is a
phone number subscribed to by JEROME WEAH, the defendant.5
b. The email address for Email Address-2 is the name
of an individual (“Individual-1”) that I understand based on
publicly available websites and mortgage records to be in a
personal relationship with RUDEAN WEIR, the defendant.6 The
4 Based on my review of HRA records, I know that the checks
issued to Landlord-1 in connection with the Landlord-1 EOSD
Applications were generally in greater amounts than the checks
issued to Broker Company-1. Therefore, based on my training and
experience, I believe that the checks written from the Landlord1 Bank Account to WEAH and the wire transfer from the Landlord-1
Bank Account to the Bank-3 Weah Account were sent in order to
provide WEAH with additional proceeds from the scheme beyond the
amounts he received from the checks issued to Broker Company-1.
5 As noted supra paragraph 9.c, Email Address-1 submitted certain
of the Reviewed Landlord-1 EOSD Applications, and was cc’d on
other applications submitted by the Weir Organization-1 Email
Address.
6 I have identified a publicly available website which advertises
a “baby registry” for “Rudean Weir” and Individual-1. In
addition, based on my review of mortgage records for RUDEAN
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phone number associated with Email Address-2 is subscribed to by
Individual-1.
c. The email address for Email Address-3 includes
the name “Rudean Weir.” The recovery phone number for Email
Address-3 is a phone number subscribed to by RUDEAN WEIR, the
defendant.7
d. As noted above, the email address for Email
Address-3 includes the name “Rudean Weir.” Based on my review
of records from Email Services Provider-1 and a cellular service
provider, I know that the recovery phone number for Email
Address-3 – that is, the phone number which can be used to
access Email Address-3 if the user of the account loses the
password – is a phone number associated with RUDEAN WEIR, the
defendant.
WEIR, the defendant, I understand that Individual-1 is included
on his mortgage application.
As noted supra paragraph 13, Email Address-2 is the email
address which Veteran-1 and Veteran-2 contacted in order to
apply for purported Covid-19 benefits for Veterans.
7 As noted supra paragraph 13.b, Email Address-3 is another email
address which communicated with Victim-2 in connection with his
purported application for Covid-19 benefits for Veterans.
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WHEREFORE, deponent respectfully requests that a warrant be
issued for the arrests of RUDEAN WEIR and JEROME WEAH, the
defendants, and that they be arrested, and imprisoned or bailed,
as the case may be.
__________________________________________
Special Investigator Wai Yu
New York City Department of Investigations
Sworn to me through the transmission of this
Affidavit by reliable electronic means,
pursuant to Federal Rules of Criminal
Procedure 41(d)(3) and 4.1 this 24th day of
June 2022
___________________________________
THE HONORABLE GABRIEL W. GORENSTEIN
UNITED STATES MAGISTRATE JUDGE
SOUTHERN DISTRICT OF NEW YORK
