
This is an affidavit that was filed in the sentencing of Regina Tatum who was involved in a major scam along with Christian Markert, the notorious con-man who was hired by Ursula Caberta to assist her in her hate campaign against the Church of Scientology.
A F F I D A V I T
I, Carrie A. Beving, being duly sworn, hereby depose and say:
1. I am a Special Agent (“SA”) of the United States Secret Service (“USSS”) assigned to the Los Angeles Field Office, and have been employed by the USS since July 2001. Prior to my employment as a Special Agent, I was an Inspector with the United States Immigration and Naturalization Service. Among my duties is the investigation of financial fraud, including the theft of credit card account information and its fraudulent use.
2. This affidavit is made in support of a criminal complaint charging REGINA TATUM (“TATUM”) with violations of Title 18, United States Code, Section 1029 (a) (5) : effecting fraudulent transactions with another person’s access device in excess of $1,000. The facts set forth in this affidavit are based upon my personal observations, my training and experience, and information obtained from other law enforcement officers and witnesses. This affidavit is intended to show that there is sufficient probable cause to support the issuance of the criminal complaint, and does not purport to set forth all of my knowledge of or investigation into this matter.
3. Based on my training and experience, I know that fraudulent credit card schemes typically operate in the following manner: The suspect obtains credit card information for one or more persons, including the account name, number and expiration date. The suspect uses the credit card information to purchase merchandise or services.
4. On April 24, 2002, Redondo Beach Police Department Detective Peter Grim advised me that Carmela Rodriguez, owner of Riviera Village Travel, 1801 S. Catalina Ave., Redondo Beach, California, filed a police report against her former business partners Matthias Dabrowski and Christian Markert. In the report, Rodriguez stated the following:
a. In October 2001, Rodriguez entered into a business agreement with Dabrowski and Markert that allowed Dabraowski and Markert to rent office space in her building to sell airline tickets at wholesale prices to travel agents and the general public. Rodriquez allowed Dabrowski and Markert to use her Airline Reporting Commission (“ARC”) account to purchase tickets through the various airlines. ARC’s services include :
i. Travel agency accreditation.
ii. Ticket and ticket number assignment distribution and control.
iii. Travel transaction reporting and financial settlements.
iv. Other related travel and industry services.
b. Dabrowski and Markert called their travel agency “Click N Fly” and opened a joint Bank of America checking account, #0456-701594, with Carmela Rodriguez in the name of Riviera Village Travel aka Click N Fly. This joint account was used as an impound account where monies from ticket sales were to be deposited. The funds were then used to pay the airlines for tickets sold by both Riviera Village Travel and Click N Fly.
5. On May 22, 2002, I interviewed Carmela Rodriguez, who proivded the following information:
a. Dabrowski and Markert hired TATUM as an independent travel agent to sell tickets from her home in the Washington DC area for their business Click N Fly. Dabrowski and Markert provided Rodriguez with a copy of a business contract and requested that Rodriguez provided TATUM with access to Rodriguez’s ARC number to enable TATUM to sell tickets. Rodriguez agreed to do so.
b. Between November 2001 and March 2002, Dabrowski and Markert opened six unauthorized accounts in the name Carmela Rodriguez or business name Riviera Village Travel:
i. American Express (“AMEX”) Corporate Platinum accounts # XXXX XXXXX 91001.
ii. AMEX Business Gold account #XXXX XXXXXX 51002.
iii. AMEX Merchant account #XXX XXX 1706,
iv. AMEX Merchant account #XXX XXX 6793,
v. Citibank Officemax account #XXXX XXXXXX 676321,
vi. Citibank Staples account #XXXX XXXXXX 543979.
c. On March 14, 2002, Dabrowski went to Riviera Village Travel after hours and removed all of his and Markert’s personal property, including all records for their business, Click N Fly. Dabrowski left a letter stating that he was going back to France, his home country, and that Markert was not returning from Germany, where he was visiting. Dabrowski and Markert removed all funds from the joint checking account that they shared with Rodriguez.
d. Rodriguez received a call from Monica Bacon, who informed Rodriguez that from February 2002 until March 2002, there were 130 unauthorized charges made to Bacon’s AMEX Platinum account, #XXXX XXXX XXXX 001, for tickets purchased from Click N Fly/Riviera Village Travel. TATUM used her own issuing agent identification number to make all of these charges, which totaled more than $100,000.
e. Rodriguez received several charge backs to Riviera Village Travel/Click N Fly for airline tickets purchased with American Express account #XXXX XXXX XXXX 001. According to Rodriguez, when travel agents purchase tickets for air travel with a credit card, the airline itself charges the credit card provided by the travel agent. If the charge is later rejected and the travel already has occurred, the airline can hold the travel agency that facilitated the transaction liable for the amount of the fare under the agreement between the agencies and airlines.
6. On June 2, 2002, I spoke with Monica Bacon, who informed me that she never purchased tickets from either Riviera Village Travel or Click N Fly. Bacon did not know REGINA TATUM or authorize her to make airline ticket purchases with her AMEX Platinum corporate credit card, XXXX XXXX XXXX 001.
7. On January 7, 2002, I reviewed the court docket and plea agrement for United States v. Regina Tatum, 02-446-A (Eastern District of Virginia, Alexandria Division). According to these documents, on October 21, 2002, TATUM pleaded guilty to violating Title 18, United States Code, Section 1029 (a) (5), in the Eastern District of Virginia. I also have reviewed the complaint, affidavit, and statement of facts filed in that case, which reveals that TATUM had engaged in a airline ticket – credit card scheme very similar to the one in this case.
8. Based on my training and experience, I know that the subject transactions affected interstate commerce, as TATUM operated in the Washington D.C. Area, and the victim business, Riviera Village Travel, was located in Redondo Beach, California.
9. Based on the facts set forth in this affidavit and my experience as a law enforcement agent, I believe there is probable cause that REGINA TATUM violated Title 18, United States Code, Sections 1029 (a) (5) : effecting fraudulent transactions with another person’s access devices.
Carrie A. Beving
Special Agent
United States Secret Service
Subscribed and sworn to before me
On this 7th day of January 2003.
Jennifer T. Lum
UNITED STATES MAGISTRATE JUDGE