Blackburn Final Complaint

AO 91 (REV.5/85) Criminal Complaint AUSAs Manish Shah (312) 353-0517 and Stephanie Zimdahl (312) 469-6314

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UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF ILLINOISEASTERN DIVISIONUNITED STATES OF AMERICAv.JEREMY BLACKBURN

CRIMINAL COMPLAINT

CASE NUMBER:

UNDER SEAL

I, the undersigned complainant, being duly sworn on oath, state that the following is true and correct to the best of myknowledge and belief: Beginning no later than in or around March 2009, and continuing until November 2009, at Chicago, inthe Northern District of Illinois, Eastern Division, and elsewhere, JEREMY BLACKBURN, defendant herein:devised, intended to devise and participated in a scheme to defraud and to obtain money and property, bymeans of materially false and fraudulent pretenses and representations, and in furtherance thereof, on orabout July 15, 2009, did knowingly cause to be transmitted in interstate commerce, by means of a wirecommunication, certain signs and signals, namely, a wire transfer of approximately $60,573,249 from Chicago,Illinois to Santa Clara, California;in violation of Title 18, United States Code, Sections 1343 and 2. I further state that I am a Special Agent with the FederalBureau of Investigation, and that this complaint is based on the facts contained in the Affidavit which is attached hereto andincorporated herein. Signature of ComplainantBRENT POTTERSpecial Agent, Federal Bureau of InvestigationSworn to before me and subscribed in my presence,November 30, 2009 atChicago, IllinoisDate City and StateNAN R. NOLAN, U.S. Magistrate JudgeName & Title of Judicial Officer Signature of Judicial Officer

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UNITED STATES DISTRICT COURT)) SSNORTHERN DISTRICT OF ILLINOIS)

AFFIDAVIT

I, Brent Potter, first being duly sworn under oath, hereby depose and state as follows:

Introduction

1.I am a Special Agent of the Federal Bureau of Investigation (“FBI”) assignedto the Chicago Field Division. I have been employed by the FBI as a Special Agent forapproximately twelve years. At this time, I am assigned to an FBI squad dedicated to theinvestigation of federal wire and mail fraud offenses, as well as related financial crimes.2.This affidavit is submitted in support of a criminal complaint alleging thatJEREMY BLACKBURN (“BLACKBURN”) has committed wire fraud, in violation of Title18, United States Code, Sections 1343 and 2. Because this affidavit is being submitted forthe limited purpose of establishing probable cause in support of the attached criminalcomplaint, I have not included each and every fact known to me concerning thisinvestigation. I have set forth only the facts that I believe are necessary to establish probablecause to believe that the defendant committed the offense alleged in the complaint.3.This affidavit is based on my personal knowledge, information obtained fromother law enforcement agents and government employees who have been involved in thisinvestigation, and a review of publicly available documents and websites, financial,accounting and banking documents, and correspondence obtained during the course of thisinvestigation.

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CANOPY FINANCIAL

4.At times material to this Complaint:a.Canopy Financial, Inc. (“Canopy Financial” or “Canopy”) was aDelaware corporation, formed in 2004. Canopy Financial developed and provided programsfor banks and health care payers for payment processing and administration of health-relatedaccounts such as Health Savings Accounts and Flexible Spending Accounts. Canopy’sproducts related to, among other things, expense tracking, online bill payment, AutomatedClearing House processing, and account management for healthcare transactions. Canopymaintained offices in San Francisco, California; Plainsboro, New Jersey; and Chicago,Illinois. Canopy Financial maintained several bank accounts, at least one of which was withthe Northern Trust Company (“Northern Trust”). Northern Trust sent bank statements toCanopy Financial at its Chicago office at 230 W. Monroe, Suite 2330, Chicago, IL 60606.b.JEREMY BLACKBURN was a co-founder of Canopy Financial.BLACKBURN was also the President and Chief Operating Officer of Canopy Financial.According to Canopy’s website, as President and Chief Operating Officer, BLACKBURNled the day-to-day business operations, sales, account management, marketing, engineeringand product development activities of the company. Also according to Canopy’s website,prior to joining Canopy Financial, BLACKBURN had served as a division CEO for anadvanced technology business and as Vice President of Global Professional Services foranother corporation. BLACKBURN had a Masters of Business Administration from theUniversity of Chicago Graduate School of Business.

Category:	Business/Law > Finance
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Upload Date:	12/04/2009
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