Criminal Complaint Case Number: 1:20-MJ-22
Criminal Complaint Case Number: 1:20-MJ-22
I, Jared Sikorski, the undersigned complainant being duly sworn, state the following is true and correct to
the best of my knowledge and belief. From in or about May 2019 until in or about October 2019, in Fulton
County, in the Northern District of Georgia, and elsewhere, defendant MARQUAVIOUS DEONTE BRITT
did intentionally access a computer, without authorization and exceeding authorization, and thereby
obtained information and attempted to obtain information from a protected computer for the purposes of
commercial advantage and private financial gain; with the value of the information obtained exceeding
$5,000; in violation of Title 18, United States Code, Section 1030(a)(2)(C), Section 1030(c)(2)(B)(i), and
Section 1030(c)(2)(B)(iii).
I further state that I am a Special Agent with the Federal Bureau of Investigation and that this complaint
is based on the following facts:
e of Complainant
Jared Sikorski
Based upon this complaint, this Court finds that there is probable cause to believe that an offense has
been committed and that the defendant has committed it. Sworn to before me, and subscribed in my
presence
(FBI), being first duly sworn, depose and state under oath as follows:
INTRODUCTION
computer for the purposes of commercial advantage and private financial gain;
with the value of the information obtained exceeding $5,000; in violation of Title
18, United States Code, Section 1030(a)(2)(C), Section 1030(c)(2)(B)(i), and Section
AFFIANT BACKGROUND
Title 18, United States Code, Section 2510(7), that is, an officer of the United
for offenses enumerated in Title 18, United States Code, Section 2516.
3. I am a Special Agent with the FBI, assigned to the Atlanta Field Office, and
have been so employed since May 2019. Prior to becoming a Special Agent with
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located in Chicago, IL, for approximately five years. In this role, I investigated
computers, e-mail accounts, and the Internet. I have also participated in the
search warrant applications, the execution of searches and seizures, and various
familiar with the means by which individuals use computers and information
I have learned from discussions with other investigators. The facts related in this
merely the amount needed to establish probable cause. Unless otherwise noted,
wherever in this affidavit I asserted that a statement was made, the information
was provided by another law enforcement officer or witness who may have had
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others have spoken. I do not rely upon facts not set forth herein in reaching my
conclusion that a complaint should be issued, nor do I request that this Court
rely upon any facts not set forth herein in reviewing this affidavit.
PROBABLE CAUSE
company (hereinafter VICTIM-i) for a short period of time from May 6, 2019
Cloud services to store its clients’ data. Only one VICTIM-i employee possessed
VICTIM-i, a second administrator account had been created on or about May 14,
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10. On October 10, 2019, an FBI confidential source (CHS)1 responded to the
post, and expressed interest in purchasing the MSP access. In response, wOzniak
emailed the CHS a screenshot of the Vuift administrator panel. The CHS and
wOzniak then negotiated a price of $450.00, and the CHS sent 0.05254621 Bitcoin
11. After the purchase, the FBI reviewed the account sold to the CHS. The
that the stolen administrator account was in fact that of VICTIM-i. Agents also
confirmed that 7816 is the last four digits of BRITT’S social security number.
Coinbase provided the FBI an uploaded scan of BRITI’S Florida driver’s license,
name, SSN, email address, home address, and date of birth — all of which
matched the identifiers for BRITT. There was also a Chase bank account linked
‘The CR5 has provided reliable and corroborated information to the government for
over two years. CHS reporting has continually been timely, detailed, and accurate. CHS
has provided information on multiple occasions that has resulted in open investigations
and identified subjects. CHS has also successfully identified multiple victims which
were positively confirmed during victim notifications. CHS has no criminal history and
no known Ciglio issues.
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69.73.104.77 and 75.76.203.92. The FBI confirmed that 75.76.203.92 was the IP
security number, phone number, birthdate, and email address also matched
BRITT which shows both his VICTIM-i paycheck direct deposit in June 2019, and
a transfer from PayPal of $436.59 on October 10, 2019 — which is consistent with
the funds that the CHS paid for the VICTIM-i’s admThistrator account.
15. On October 10, 2019, BRITT’S PayPal account received $44i.00 USD from
Coinbase. That same day, funds were transferred from BRITT’S PayFal account
to BRITT’S Chase Bank account. Moreover, the IP address 75.76.203.92 was used
16. Open source research revealed Twitter and Instagram profiles that
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“Marq” and, the social media profiles and posts appear to depict BRITT in the
photos.
17. Agents also confirmed that the IP address 75.76.203.92 was utilized to
login to the Twitter account @_WOz approximately 50 times between October 18,
2019 and November 25, 2019. The IF address 75.76.203.92 matches the IF address
provided by Coinbase and FayPal for the transaction in which wOzniak sold
18. According to VICTIM-i, its Vultr access logs show: On October 1, 2019,
account. On October 12, 2019, the IP address 75.76.203.92 was used to login to
address which accessed BRITT’S Coinbase, FayFal, and Twitter accounts. The IP
$5,000 in value to VICTIM-i, and BRITT obtained the information for his own
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21. Based upon the foregoing, I submit there is probable cause to believe that
and attempted to obtain information from a protected computer for the purposes
of commercial advantage and private financial gain; with the value of the
Code, Section 1030(a) (2) (C), Section 1030(c) (2)(B) (i), Section 1030(c) (2) (B) (iii).