Professional Documents
Culture Documents
Usa V Mizuhara Complaint
Usa V Mizuhara Complaint
LODGED
CLERK, U.S. DISTRICT COURT
UNITED STATES DISTRICT COURT
FILED
4/11/2024 for the CLERK, U.S. DISTRICT COURT
v.
Case No. 2:24-mj-02125-DUTY
,33(,0,=8+$5$
Defendant(s)
I, the complainant in this case, state that the following is true to the best of my knowledge and
belief. 2Q Rr about -XQH in the county of Los Angeles in the Central District of California
V&KULV6H\PRXU
Complainant’s signature
&KULV6H\PRXU6$,56&,
Printed name and title
Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephone.
$86$'DQ%R\OH[
AFFIDAVIT
follows:
I. PURPOSE OF AFFIDAVIT
1. This affidavit is made in support of a criminal
Fraud).
and part only, all amounts or sums are approximate, and all
dates and times are on or about those indicated.
of the Internal Revenue laws, the Bank Secrecy Act, and Money
1
Laundering Control Act. Many of these investigations focused on
accounting.
2
5. In an interview with law enforcement, Victim A stated
Account.
that during the same time period, the contact information on the
mobile phone.
associates of BOOKMAKER 1.
3
9. Finally, on March 20, 2024, MIZUHARA sent BOOKMAKER 1
following:
and have multiple targets, not all of whom are related to each
4
B. Evidence Seized from BOOKMAKER 1 Confirmed BOOKMAKER 1’s
Bookmaking Business
following:
BOOKMAKER 1 had over 600 bettors, but sent the apparent bettor
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Colorado, as payment for gambling losses incurred by the
apparent bettor.
that BOOKMAKER 1 “takes big action and can give you whatever u
need.”
6
a. On or about September 8, 2021, BOOKMAKER 2
Sunday night you pay or receive[.] Last week you were down and
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recipient’s] full address including city state and zip. As soon
said I can’t send that much money since I’m in Japan right now.”
Account.
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j. On or about November 9, 2021, MIZUHARA told
looks like this method word [sic] but I can only send 40k at a
time.”
days.”
service via PayPal. I will let you know once they accept it.”3
n. On or about January 2, 2022, MIZUHARA asked
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[BOOKMAKER 1] if he can bump me 50k? That will be my last one
made another transfer for 300k today since I lost the other 100k
weekend. Other wire still hasn’t been received. Can u just wire
the 200” and then provided MIZUHARA with the x1911 Account
stating, “I will give you the FreePlay that I was going to give
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300k?” BOOKMAKER 1 responded, “U mean lower credit to 100?”
BOOKMAKER 1 stating, “I sent out 500 just now. I tried 1000 but
BOOKMAKER 1 stating, “It looks like I can only send 500 per
you?”
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fact registered in the name of MIZUHARA (hereinafter, the
“MIZUHARA Account”).
day. I was just confirming that you received the ach [wire
transfer] for the 47,260? Also just confirming you still want me
to wire more before I do? I see your [sic] down now so Lmk? Ty
thank you very much. And no you do not need to wire anymore
17. After May 2022, the text messages from the MIZUHARA
huh? Lol . . . Any chance u can bump me again?? As you know, you
this will be the last ask before I pay it off once I get back to
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the states. Sorry for keep on asking. . . .” BOOKMAKER 1
responded the same day stating, “Np done bud. Merry Christmas.”
June 1.”
chance I can get one last bump? This will be my last one for a
will be sent every week I can do the bump to whatever you want?
It’s just imperative that the 500 is sent every week as you can
imagine the figures are very high and just don’t want to not be
able to deliver what I tell him[.] FYI I have already paid out
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last last last bump? This one is for real. . . . Last one for
long as you can guarantee the 500 every Monday I’ll give you as
much as you want because I know you’re good for it[.] again I
Newport Beach and I see [Victim A] walking his dog. I’m just
gonna go up and talk to him and ask how I can get in touch with
immediately.”
lot of money on crypto the last couple years and I took a huge
there any way we can settle on an amount? I’ve lost way too
don’t care what time or how late it is.” MIZUHARA responded the
busy . . . and I’ve got other issues on the side going on too. .
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. everything has just been really really tough recently. I don’t
going to get out of control. If I don’t hear from you by the end
responded the same day, stating “My bad man. . . . I just got
back from Japan two days ago and I’m leaving tomorrow again
really struggling right now and I need some time before I start
to make payments.”
account 35966 for the period December 2021 through January 2024.6
As previously described, I understand that MIZUHARA was assigned
MIZUHARA’s Phone.
6 The source has not yet been charged for his role in the
illegal gambling business, but I believe he is cooperating with
law enforcement in hopes of receiving benefits at the time of
sentencing on any future charges.
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19. I have reviewed an Excel spreadsheet with the betting
the following:
baseball games.
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a. The x5848 Account was held in the name of Victim
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noted above in paragraph 15(u), on or about this date, MIZUHARA
the x5848 Account wired more than one million dollars to the
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F. Account Records Produced by Bank A Connect MIZUHARA to the
spoken with have reviewed account records for the x5848 Account
number ending in x0373 regarding both the x5848 Account and the
Phone.
and October 27, 2021, there was no online access activity for
internet for the first time since 2018. Approximately two weeks
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e. Each device that is used to access a Bank A
instances include:
i. Between October 30, 2021, and November 3,
The 9282 DeviceID also accessed the x5848 Account multiple times
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Account using IP address 136.52.16.173. This IP address was
same IP address.
G. MIZUHARA Lied to Bank A Employees to Circumvent Bank A’s
Account
following:
Account.
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associated with the MIZUHARA Phone, regarding the suspension of
himself as Victim A.
email address for the x5848 Account were the x0373 phone number
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MIZUHARA Phone associated Email Address 1 with a PayPal account
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In this capacity, MIZUHARA’s responsibilities were to translate
for Victim A.
account details.
(K.F.).
recalled that there were only one or two such meetings. None of
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Japanese and Victim A relied on MIZUHARA to translate the
investment profile.
Address 1 that was listed as the primary email address for the
x5848 Account.
did not understand most of what was said in English, but Victim
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A was able to understand there was an issue involving MIZUHARA.
issue was, and MIZUHARA told Victim A that they needed to speak
privately.
had been paying his bookmaker with funds from the x5848 Account.
had falsely told Agent 1 and others that Victim A had agreed to
for Victim A.
approximately 2018.
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c. In addition to negotiating sports contracts for
Victim A.
Agent 1 that the x5848 Account was “private” and that Victim A
MIZUHARA.
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b. J.C. monitors a range of Victim A’s business
but stated that he/she had never been given access to this
account, and did not know its balance or have any insight into
MIZUHARA had stated that Victim A wanted the x5848 Account kept
private and that he understood that the x5848 Account did not
and assets.
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b. B.L. has been working for Victim A for
investments or assets.
x5848 Account private and did not want anyone else to view that
account.
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for the meeting. MIZUHARA stated that Victim A was sick, and
private from everyone, and that the x5848 Account did not bear
interest and that there were no gifts from the x5848 Account.
January 2024, and asked that Club Employee 1 receive and set
that the MIZUHARA Phone was used to access an email account and
the device.
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1. Certain of these package had already been opened when I
cards for baseball players Yogi Berra, Juan Soto, and Victim A.
baseball cards from eBay and Whatnot with the intent to resell
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a. As noted above, I and/or members of the
BOOKMAKER 1.
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aware of and authorized these wires. If that were the case,
x5848 Account.
His Phone
spoken with reviewed a forensic image Victim A’s phone and did
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not find any evidence to suggest that Victim A was aware of, or
debts.
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a. On or about March 17, 2024, MIZUHARA messaged
you think there is any way to find out the details of the
him although he tried[.] And all my attorney did was give him
those facts I told you and told him the rest she won’t talk
about and can’t confirm or deny anything. He did say his source
steal from him. I understand it’s a cover job I totally get it.”
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V. CONCLUSION
37. Based on the foregoing, there is probable cause to
18 U.S.C. § 1344(2).
6&+5,66(<0285
CHRIS SEYMOUR, Special Agent
Internal Revenue Service
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