STATE OF OHIO

COUNTY OF GEAUGA

)
) ss:
)
)
)

CHARDON MUNICIPAL COURT

GEAUGA COUNTY, OHIO
AFFIDAVIT FOR
SEARCH WARRANT

BEFORE ME, Judge Terri L. Stupica, of the Chardon Municipal Court, Geauga
County, Ohio, personally appeared Karen Sweet, hereinafter referred to as Affiant, who
has identified herself as a Crminal Investigator for the Geauga County Prosecutor's
Office, and being first duly sworn, states the following:
1. She is employed by the Geauga County Prosecutors Office as a criminal
investigator. She has been an Ohio Peace Officer for over 28 years. She has
previously been employed as a deputy sheriff for the Lake County Sheriffs Office
and as an investigator for the Ohio Attorney Generals Office. Her daily job
description is to investigate criminal offenses/violations of the Ohio Revised Code
that have occurred in and throughout Geauga County.
2. This Affiant was asked to assist Job and Family Services (JFS) fraud investigator
Ashly Hiscox in a criminal fraud investigation against the Mahvi family. The Mahvi
family lives at 14611 Shire Court, Russell Township, Geauga County, Ohio, and the
family consists of the following:
a. father/husband, Ali Paschal Mahvi (DOB:12/05/50)
b. mother/wife, Caryl L. Mahvi (DOB: 10/12/58)
c. son, Alexander Darius Mahvi (DOB:10/10/86)
d. daughter, Jacklyn Roya Mahvi (DOB:02/01/88), and
e. son, Nicholas P. Mahvi (DOB:10/13/90)
3. The Mahvis began receiving food stamp assistance in March of 2014 and Medicaid
on July 9, 2014. Their food stamps were cut off in February of 2016 due to
discrepancies in the familys actual monthly income. The family also applied to a
program called Percentage of Income Payment Plan Plus to receive assistance
through Geauga County for their monthly gas and electricity bills.
4. According to the Mahvi familys initial intake interview with JFS, none of the
children work, Ali is self-employed but has no income, and Caryl works 30 hours a
week for Ali but has no income. Each member of the Mahvi family signed the JFS
Self-Declaration of Income form, stating that all of them have zero income. They
signed this same form in July of 2015, again stating that they all have zero income.
a. This Affiant learned that during this intake interview Ali and Caryl said they
own a condo in Florida and a home in Russell Township but that both are in
foreclosure.
i. This Affiant checked with Geauga County Assistant Prosecutor
Bridey Matheney, who handles foreclosure matters for the Geauga

County Treasurer, and was told that the Mahvi residence was
dismissed from foreclosure in September 23, 2014.
b. This Affiant learned that Ali reported to JFS during this intake interview that
he and his family were living on church donations and loans from friends.
i. According to JFS rules and procedures, any loans given to a person
on food stamps must be accompanied with a letter. On February 21,
2014, JFS received a letter from Ronald G. Pollock, who loaned the
Mahvis $13,400.00. This letter was written on the letter head of
Pollock & Chriswell (Ralph E. Criswell), who are officers/agents of a
business called GFI Holdings Corp., which is registered to Ali. On
February 16, 2016, the Mahvis were given a loan in the amount of
$12,000.00 from Gregory T. Classen, D.O. He sent a letter to JFS
informing them of this loan.
5. Investigator Hiscox explained that in determining whether a family qualifies for food
stamps and/or Medicaid, the only things taken into consideration are their
combined monthly income and the number of family members. Assets are not
taken into consideration.
a. According to the Geauga County Auditors website, the Mahvis current
residence on Shire Court is valued at $800,000.00.
b. In 2013, Ali had the following vehicles registered to him: a 2013 Cadillac
Escalade Luxury, a 2012 Porsche 911 Carrera, and a BMW convertible 325
CI. Ali currently has a 2005 Lexus SC convertible registered to him.
c. Caryl has a 2004 BMW CI registered to her.
d. Jacklyn previously had a 2009 Cadillac Escalade registered to her. The
vehicle registration was not renewed in 2015.
e. Nicholas previously had a 2014 Porsche Cayman registered to him. The
vehicle registration was not renewed in 2015.
6. This Affiant learned that the Mahvi family began receiving food stamps on March
2014 and to date has received on average over $300.00 a month and grand total
of $8,358.00 to date.
7. This Affiant read Ali Mahvis application for food stamps, which was submitted in
April 2014. He claimed that his total net income after taxes and housing costs for
the current month was zero; that his resources in cash, checking and savings
accounts was less than $100.00; and that his monthly mortgage and utilities were
more than his monthly gross income before taxes.
a. This Affiant subpoenaed all of the Mahvi family bank accounts from January
of 2014 through June of 2016. All of the monthly debits and credits were
added together to find the actual combined family net income. The
combined family net income for February 2014 was $5,420.69, and for April
2014 was $3,206.95. This information contradicts the information that Ali
provided on his April 2014 application.

8. In order to receive food stamps and utility assistance from JFS, a familys net
income cannot exceed certain amounts of money over certain periods of time,
depending on how many people are in the family. From March 2014 to September
2014 the net income for the Mahvi family could not be greater than $1,963.00 (4
people, 1 student); from October 2014 through January 2015, their net income
could not be greater than $1,988 (4 people, 1 student); from February 2015
through April 2015 it could not be greater than $1,650.00 (3 people, 2 students);
from May 2015 through September 2015 it could not be greater than $1,988.00 (4
people, 1 student); and from October 2015 through February 2016 it could not be
greater than $2,021.00 (4 people, 1 student).
a. In their first Food Assistance application, the Mahvis provided paperwork
revealing that the 2012 tax return shows a negative income of
$2,990,436.00. The 2013 tax return shows a negative income of
$3,021,512.00, and the 2014 tax return shows a negative income of
$3,084,311.00.
b. This Affiant then calculated the Mahvi family combined net income, based
on bank records, from January of 2014 through June of 2016 and found that
during the following periods of time the Mahvis net income was well over
the threshold amounts: These months were:
i. $5,420.69 in February 2014
ii. $3,206.95 in April 2014
iii. $8,565.99 in March 2015
iv. $3,695.80) 4/2015
v. $6,771.46 10/2015
vi. $4,662.29 2/2016
9. On April 27, 2014, the Mahvis applied for Medicaid through Geauga County JFS.
The Mahvi family again stated that they had zero income because their expenses
exceed their combined family income. The case worker asked to review the family
tax returns to establish eligibility for assistance, but Ali stated that none of them
had filed tax returns in the past two years; therefore he could not provide them.
a. This Affiant learned, however, that Ali provided the 2012, 2013, and 2014
tax returns to the Geauga JFS Food Stamp program on March 4, 2015.
10. This Affiant learned that the Mahvis first application for Medicaid was denied.
They submitted a second application on June 11, 2014. On this new application Ali
stated that he expected to earn more than $300,000 in the next year from his
Indria Energy business and his Exquisite Caribbean Resort business. Caryl listed
her monthly income as $1,200 in rental fees, and another $1,700.00 in other
income. This second application was approved and they began receiving
Medicaid benefits on July 9, 2014.
a. It should be noted that Caryl did not disclose her $2,900.00 monthly income
on the food stamp application.

11. This Affiant obtained the Mahvi familys April 29, 2015 Renewal for Medicaid form
in which they stated again that they had zero income. The family was again
approved to receive Medicaid through April of 2016.
12. In order to be eligible for Medicaid, the Mahvi familys standard income could not
exceed the following amounts:
a. $3,094.00 per month in 2014
b. $3,149.00 per month in 2015
c. $2,694.00 per month in 2016
13. This Affiant calculated the Mahvi family combined net income from January of 2014
through June of 2016 and found that during at least six of the months of this period
of time the Mahvis net income was well over these thresholds and were not
eligible to receive Medicaid during these months. These months were:
a. $5,420.69 in February 2014
b. $3,206.95 in April 2014
c. $8,565.99 in March 2015
d. $3,695.80 in April 2015
e. $6,771.46 in October 2015
f. $4,662.29 in February 2016
14. This Affiant subpoenaed Key Bank, Huntington Bank, and Chase Bank for the
Mahvis bank records. They have one bank account at Chase, thirteen (13)
accounts at Huntington, and their Key Bank account was closed due to suspicious
banking activity.
15. This Affiant learned from subpoenaed documents from Chase Bank that On
January 4, 2016, a check for $1,650.00 was drawn from an account titled to the
University of Alabama. This check was made payable to Ali Pascal Mahvi was
deposited into the Mahviss account ending in 5880. This check was return as
Altered Fictitious. Chase Bank suspected the check to be counterfeit.
16. The documents also showed another occurrence of suspicious activity. On April 29,
2015, Ali received a tax refund in his money market account ending in 9411 in the
amount of $10,761.02. This was done in the name of Mark Badia. On this same
day, he transferred $10,750.00 to his business account ending in 5907, which was
done in the name of Indria Energy. On May 1, 2015, he wired $9,090.00 from his
business account to a Robert E Trade account (ending in 7124), which belongs to
someone named Robert Whited. The wire transfer stated Stamp Duty $3,180.00
and Taxes $5,910.00.
a. The reason this appears odd is that the Mahvis made a previous suspicious
activity report (SAR) in which Indria Energy LLC was the victim of a scam
that resulted in funds being sent to a Robert Whited. The Mahvis apparently
continued to communicate and conduct transactions to Robert Whited after
the report they were scammed by Whited.

17. This Affiant subpoenaed Huntington National Bank for all of the Mahvi family
accounts. I learned from the subpoenaed documents that the Mahvis money
market account #03668669411 showed suspicious activities that gave the
appearance of being structured. Structuring is the act of executing financial
transactions in a specific pattern or in specific amounts as to avoid the creation of
certain records required by law. The times of these deposits and the amounts
tend to show Mahvi was trying to avoid depositing $10,000.00 in cash to avoid
filing a Bank Secrecy Act CTR form. The Mahvis made six (6) cash deposits
totaling $30,000.00 as follows:
a. On February 4, 2014, the Mahvis deposited $4,000.00 at 2:55 p.m. and
$6,000.00 at 2:57 p.m.
b. On April 11, 2014, they deposited $5,000.00 at 3:41 p.m. and $5,000.00 at
3:43 p.m.
i. It should be noted this was the same month that he first applied for
Food Stamps and Medicaid.
c. On May 1, 2014, they deposited $5,000.00 at 2:21 p.m. and $5,000.00 at
2:22 p.m.
18. This Affiant learned through the subpoenaed bank documents that the Mahvis
have the following maximum annual values in their Hunting Bank accounts, which
were not disclosed to JFS in any of the various applications for assistance:
a. Ali Pascal Mahvi, 14611 Shire Court, Russell Township, Ohio: account
#106558101 = $100,000.00
b. First Caribbean International Bank, Bridge Street Castries in St. Lucia:
account #313117254 = $50.00
c. First Caribbean International Bank, Montague Du Parc 3, Brussels, Belgium:
account #106847348 = $4,000.00
d. TD Canada Trust, owners name Caryl Mahvi, Edmonton Centre,
Edmonton, California: account #07015241515, = $7.00
e. UBS,
Route De Forissant 59, Geneva, Switzerland: account
#279C21168930 = $15,000.00
f. PICTEET & CIE BANQUIRES,
Route Des Acacias 60, Geneva,
Switzerland: account #W58636001 = $4,038,000.00
g. Exquisite Caribbean Resorts LLC, 35 River Street, Chagrin Falls, Ohio:
account #106558101 = $32,000.00
h. Exquisite Caribbean Resorts LLC, Jalousie Residence, 35 River Street,
Chagrin Falls, Ohio: account #106558101 = $100,000.00
i. Bk of St. Lucia Bridge St. Castries St. Lucia, account #313117254,
Maximum annual value = $50.00
j. First Caribbean International Barbados LTD, Exquisite Caribbean Resorts
LLC: account #106558101 = $27,800.00
19. This Affiant has seen that the bank records show that the Mahvis are transferring
monies between various accounts online.

20. This Affiant requested more information for Ali Pascal Mahvis money market
account (ending in 9411) in which he stated the primary source of funding was
from salary/wages. The new information showed that his expected total amount of
cash to be deposited per month was $10,000.00. His expected amount of cash to
be withdrawn was $10,000.00 a month. He listed the primary countries involved in
money transfers as: Afghanistan, Aland Islands, Albania, American Samoa,
Andorra, United States, China, Germany, Luxembourg, Saint Lucia, and Sweden.
He states that his expected monthly volume of incoming domestic and international
wires to be from $25,000.00 to $100,000.00. He states his expected monthly
volume of outgoing domestic and international money wires to be between
$25,000 and $100,000.00. He expected his monthly incoming and outgoing ACH
activities to around $3,000.00. This information was last updated in 2012.
21. Inv. Hiscox went through all the debits made to seven of the accounts and added
up the following amounts being spent per month by the Mahvis on non-essential,
non-business related things (restaurants, Redbox, ITunes, alcohol, tanning, movie
tickets, etc.), all but three of which are greater than the threshold limits for the
assistance programs they are involved with:
a. March 2014 = $5,515.83
b. April 2014 = $9,867.25
c. May 2014 = $5,617.00
d. June 2014 = $3,928.11
e. July 2014 = $5,819.85
f. August 2014 = $7,146.00
g. September 2014 = $3,529.26
h. October 2014 = $9,112.66
i. November 2014 = $14,289.91
j. December 2014 = $4,202.71
k. January 2015 = $4,440.71
l. February 2015 = $3,388.48
m. March 2015 = $6,608.68
n. April 2015 = $3,975.59
o. May 2015 = $5,329.81
p. June 2015 = $1,584.75
q. July 2015 = $209.87
r. August 2015 = $4,894.50
s. September 2015 = $3,520.58
t. October 2015 = $11,381.15
u. November 2015 = $6,621.82
v. December 2015 = $11,339.18
w. January 2016 = $16,727.50
x. February 2016 = $4,804.76
y. March 2016 = $13,310.77
z. April 2016 = $3,482.65
aa. May 2016 = $157.56
ab. June 2016 = $97.61

22. The Mahvis residence located at 14611 Shire Court, Russell Township, Geauga
County, Ohio, is described as a two story, brownish stone residence, with a brown
roof, 3 chimney stacks, a four car attached garage, a pool and a horse barn, which
is situated on 5.68 acres.
Based upon the foregoing information, this Affiant has probable cause to believe
that in Russell Township, Geauga County, Ohio, the following criminal offenses have
occurred:

Theft, R.C. 2913.02(A)(3)

Medicaid Eligibility Fraud, R.C. 2913.401
Illegal Use of Supplemental Nutrition Assistance Program or WIC Program
Benefits, R.C. 2913.46(B)

Wherefore, this Affiant respectfully requests a warrant be issued to search the

property, residence, curtilage, outbuildings, and vehicles located at 14611 Shire Court,
Russell Township, Geauga County, Ohio, described as a two story, brownish stone
residence, with a brown roof, 3 chimney stacks, a four car attached garage, a pool and a
horse barn, which is situated on 5.68 acres, for money/currency/gold/precious metals or
other items that monies may have been converted into to avoid reporting as income,
bank/financial records, business records, Medicaid and Food Stamp records, computers
and other electronic devices with the ability to connect to online banking sites . This
Affiant also requests that the warrant authorize law enforcement to enter into the
computers/electronic devices to search for documents/programs/images related to
bank/financial records, business records, and Medicaid and Food Stamp records.
REQUEST FOR MODIFICATION OF 3-DAY EXECUTION DEADLINE.
This Affiant states that the requested search of the electronic media to be performed by
the agent(s) identified above is expected to require more than three (3) days due to
logistical and technical concerns. Hence, the execution of the requested warrant may
require several weeks from beginning to end. If the term execution were deemed to
occur at the completion of the analysis rather than the initiation of the analysis, then it
would be pragmatically impossible for law enforcement officers to comply with the 3-day
deadline and still properly conduct the search. Therefore, pursuant to Criminal Rule 41(C)
(2), this Affiant requests this Court require said seizure and/or search be initiated within
three (3) days, unless and until otherwise authorized by this Court.
FURTHER AFFIANT SAYETH NAUGHT.

___________________________
Karen Sweet, Affiant

Geauga County Prosecutor's Office

Sworn to me and subscribed in my presence this 1st day of September, 2016.

___________________________
Judge Terri L. Stupica
Chardon Municipal Court
Geauga County, Ohio