UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS ‘AUSTIN DIVISION AFFIDAVIT 4. INTRODUCTION |, JAMES L. NEFF, being duly swom, depose and say: a. |have been a Special Agent with the Internal Revenue Service (JRS) Criminal Investigation Division in Chicago, Illinois, Charlotte, North Carolina, and in Austin, Texas since April of 1988. During this time period, | have investigated violations of the Internal Revenue laws and related offenses. As an IRS Special Agent, | have investigated or been involved in several investigations involving violations of offenses under Titles 18, 21, 26, and 31 of the United States Code. Several Sevures of assets such as real estate, automobiles, currency, computers, and ‘other business equipment have resulted from these various investigations. b. [have provided financial investigative expertise and assistance to various agencies, including the Bureau of Immigration Customs Enforcement (BICE); the Federal Bureau of Investigation (FBI); the Drug Enforcement Administration (DEA); the Bureau of Alcohol, Tobacco, and Firearms (BATF); the Texas Department of Public Safety (DPS), and various other law enforcement units of state, county, and local governments, in their investigations of individuals who Gerive substantial income from wagering, the sale/distribution of narcotics, and through the misappropriation of funds, My assistance has inciuded the documentation and tracing of ilegal and legal proceeds obtained in violation of various Federal and State statutes. c. J have been the affiant on over 200 search/seizure warrants used to secure financial evidence involving narcotics, tax fraud, gambling, and white collar fraud, i have also participated in debriefing/interviewing defendants, witnesses, informants, and other persons who have knowledge of the amassing, spending, converting, transporting, distributing, laundering and concealing the proceeds of wagering, narcotic, terrorism, and other illegal activities. | also have experience: in investigating financial crimes committed by individuals who structure financial transactions, launder money through the use of nominees and shell corporations/businesses, and operate fraudulent schemes and structuring operations including violations of Title 18, 21, 26, and 81 of the United States Code. Your affiant has been assigned to the FBI, Joint Terrorism Task Force (TTF) singe 2004.d. Based on my training and experience, | know that individuals who orchestrateloperate illegal fraud schemes maintain the following: 4. Books, records, receipts, notes, ledgers, logs, bank records, money orders. Computer system hardware including but not limited to word processing equipment, thumb drives, modems, monitors, printers, plotters, encryption circuit boards, optical scanners, and other computer related lectronic devices, and software including floppy disks, hard drives and the data therein, and any other media which is capable of storing magnetic or optical coding, software programs and any other programs or software used to communicate with computer hardware or peripherals either directly or indirectly via telephone lines, radio, or other means of transmission, computer manuals relating to the operation of a computer system, computer software, and/or any device, and other papers relating to the fraud scheme andior records relating to the receipt and disposition of the proceeds of the illegal fraud scheme; 2. Currency, financial instruments, stocks/bonds, bank records, keys to safe deposit box(es), cassette tapes, titles, deeds, notes and/or papers of financial transactions relating to oblaining, transferring, laundering, concealing, or expending of money or other items of value made or derived from the illegal fraud scheme; 3. Telephone, address books, caller ID boxes, digital pagers, and/or papers Which reflect names, addresses, andlor telephone numbers of individuals, businesses, and associates in the fraud scheme and/or individuals and businesses who aid, assist or conceal the disposition of monies from the illegal fraud scheme, and telephone records indicated long distance calls; 4, Photographs and video tapes of individuals, property and other assets; 5, Safes, safe deposit box(es), briefcases, and other types of lock-boxes used to secrete the evidence described above; 2. OFFENSES ALLEGED IN THIS AFFIDAVIT. a. This affidavit provides probable cause to believe that RIAD ELSOLH HAMAD, = PALESTINE CHILDREN'S WELFARE FUND (PCWF), CLEAN AIR ‘OF AUSTIN, KINDER KREATIVE KONSULTANTS (KKi), and others known and unknown to your affiant at this time, are orchestralingloperating an illegal fraud scheme through the use of non- profit organizations, false documents submitted via U.S. Postal Service, false documents transmitted via wire communications, the failure to file federal income tax retums for the years 1999 through 2003 and 2005, and tax evasion for the years 1999 through 2006.b. The above named individuals have conspired and committed overt acts in Rortherance of the conspiracy to commit mail fraud, wire fraud, bank fraud, tex eiion and falure to file federal income tax returns in violation of Title 18, United States Code, Sections 1341, 1343, 1944, and 371; Title 26, United States Code, Sections 7201, and 7203 3. LOCATIONS TO BE SEARCHED Your affiant alleges that probable cause exists to believe that evidence of aforementioned criminal violations is concealed within the following premises crorerived as the residences, businesses, outbuildings, storage unit, safe deposit box and ali motor vehicles located on the curtilage of the following locations pom fined by RIAD ELSOLH HAMAD Gaia oSAMARe AAA ALESTINE CHILDREN'S WELFARE FUND (PCWF), CLEAN IN, KINDER: KREATIVE KONSULTANTS (KKK), and his close business associates end entities: a) 4807 White Elm Drive, Austin, Texas bb) Bank of America 5725 Hwy 200 W, Oak Hill, Texas, safe deposit box #HO21 4, (TEMS TO BE SEIZED ‘The grounds for issuance of this warrant are derived from the information provided by the Federal Bureau of Investigation, the Internal Revenue Services Panik officials, nancial aid officials, surveillance, and documents inspected during this investigation. Based upon the facts contained in this affidavit, your giant submis that there is probable cause to believe that located within the premises, storage unit, and safe deposit box described above in section , and in eftachment A (incorporated herein) there is currently located the folowing evidence relating to RIAD ELSOLH HAMA gummy *\ESTINE CHILDREN'S WELFARE FUND (PCWF), BEEN AIR OF AUSTIN, KINDER KREATIVE KONSULTANTS (KKK), and the inegal fraud scheme. Based on my experience and training, | know the following a, Individuals who engage in fraud andlor money laundering normally maintain 2. orde of ther financial activity, such as receipts for expenditures by cash and schock, bank records, and other financial documents’in their personal residence, storage unis, safe deposit boxes, vehicles, and on their person. Furthermore, individuals engaged in an income-producing business keep records of the financial activities of the business for numerous reasons and often use these documents to complete financial statements and tax returns for their business and personal tax returns. b. Individuals who engage in fraud and/or money laundering maintain books, »- cords, contracts, receipts, notes, ledgers, bank records, money orders, and