AO 91 (Rev.

02109) Criminal Complaint

Umf,tedl States Dflstrflc'[ Court

for the
Western District of New York

United States of America

case No. lg_MJ, t/ZZa.
v

DEVIN TRIBUNELLA & WADE SHADDERS

Defendant

CRIMINAL COMPLAINT
I, GIULIO SCOCCIA. the complainant in this case, state that the following is true to the best of my knowledge
and belief.

Beginning on or about January 1,2017, through and including the present date, in the Western District of New
York, the defendants, DEYIN TRIBLJNELLA & WADE SHADDERS violated Title 18, United States Code, Sections
1343 and 1349 (Wire Fraud), Title 18 United States Code Sections 371, 2314 and 2315 (Interstate Transporration and
Sale of Stolen Property), and Title 18 United States Code Section 1957 (Money Laundering); AND beginning on or
about April 5, 2014, through and including on or about February 26,2016, the defendant DEYIN TRIBUNELLA
violated Title 18 United States Code Section 1028A(a)(1) (Aggravated Identity Theft), offenses further described as
follows:

All defendants did knowingly devise and execute and conspire to devise and execute a scheme or artifice to
defraud or to obtain money or property by materially false and fraudulent representations, with specffic intent
to defraud, and in execution of that scheme, used or caused the use of interstate wires, in violation of Title 18,
United States Code, Sections 1343 and 1349;AND

All defendants knowingly transported (or caused to be transported or conspired to transport) in interstate or
foreign commerce goods, wares, and merchandise, the value of which was at least $5,000, that were stolen,
converted, or taken by frald, all while knowing that such property was stolen, converted, or taken by fraud, in
violation of Title 18, United States Code, Sections 37L and2314; AND

A11 defendants sold or conspired to sell goods, wares, or merchandise, the value of which was at least $5,000,
that were stolen, converted, or taken and that, after having been stolen, converted, or taken, crossed a boundary
of a state or of the United States, all while knowing that such property hadbeen stolen, converted, or unlawfully
taken, in violation of Title 18, United States Code, Sections 37L and2315; AND

A11 defendants did knowingly errgage (or attempt to engage) in monetary transactions in or affecting interstate
commerce, each with a value greatff than $10,000, which transactions occurred in the United States and
involved property derived from a specified unlawfully activity-specifically wire fraud and the interstate sale
and transportation of stolen properry-all while knowing that the properry was derived from said specified
unlawfirl activities, in violation of Title 18, United States Code, Section 1957;AND

The defendant DEVIN TRIBTINELLA did knowingly use a means of identification of another person during
and in relation to the offenses of wire fraud and the interstate transportation and sale of stolen goods without
lawful authority to do so, in violation of Title 18, United States Code, Section 10284.

This Criminal Complaint is based on these facts:

 SEE ATTACHED AFFIDAVIT OF SPECIAL AGENT GIULIO SCOCCIA, IRS-CI.

tr Continued on the attached sheet.

_w^h Comp lainant's signature

GIULIO SCOCCIA. 1 Asent. TRS-CT

Pinted name and title
Sworn to before me and signed in my presence.
Date: November lzl .2019 flautcq
Judge's signature

MARIAN W. PAYSON
City and State: Rochester. New York LINITED STATES MAGISTRATE ruDGE
Printed name and title