Case 2:23-mj-30370-DUTY ECF No. 1, PageID.

1
 Filed 09/08/23 
J M Page 1 of313
17 226-9759
AO 91 (Rev. 11/11) Crimina Complint      313 965-2323

NITE TATES DISTRIT COUT

 
Easter Distict of Michigan
Case: 2:23−mj−30370
U   A Assigned To : Unassigned

Assign. Date : 9/8/2023
r  T  N Desciption: RE: SEALED MATTER
(EOB)

CRIINAL COMLAINT

                 k  

O    )  M 11 2023   6 2023  h   Wy    
  
E  M   ) 
Code Section Ofense Description
18 u.s.c. § 371 
18 u.s.c. § 2312    V
18  § 2313   R   V
18  § 1341 M Fu
18  § 1343 W Fu

T       

I     

Comlainant's signature

    (BI

Printed nae and title
Swo o befe me a signe in m pesence
ado b elible eleconic meas.

September 8, 2023
e:  _ Judge's signature

Ci a se: Dt, M H R v W,  M Ju
Printed nae and title
 Case 2:23-mj-30370-DUTY ECF No. 1, PageID.2 Filed 09/08/23 Page 2 of 17

AFFIDAVIT

I, Sean Callaghan, being duly sworn, states as follows:

1. I am a Special Agent with the Federal Bureau of Investigation

(FBI) and have investigated a variety of federal criminal violations,

including violent crime, bank robberies, crimes against children and

various financial crimes, for approximately 20 years. I am currently

assigned to the Detroit Metropolitan Identity Theft and Financial Crimes

Task Force (DMIFT).

2. The information contained in this affidavit is based on

reports that I have reviewed, documents and information provided by

witnesses interviewed during this investigation, and materials provided

by the Troy Police Department and the Ohio State Highway Patrol

concerning their investigations. The victims/witnesses who were

interviewed by officers and/or agents pursuant to this investigation

provided complete identification information (none were anonymous

sources). However, I am identifying them in this affidavit, which will

become public, only by their initials to protect their identities. Because

this affidavit is being submitted for the limited purpose of establishing

probable cause, I didn’t include every fact I know concerning this

investigation, but only the facts that I believe are necessary to establish
 Case 2:23-mj-30370-DUTY ECF No. 1, PageID.3 Filed 09/08/23 Page 3 of 17

probable cause to believe that Robert Thomas has engaged in a

conspiracy under 18 U.S.C. § 371 to violate 18 U.S.C. § 2312

(Transportation of stolen vehicles), 18 U.S.C. § 2313 (sale or receipt of

stolen vehicles), 18 U.S.C. § 1341 (mail fraud), and 18 U.S.C. §1343

(wire fraud).

EXECUTIVE SUMMARY

3. I am currently investigating, Robert Clinton Thomas, (DOB:

XX/XX/1978) for a conspiracy under 18 U.S.C. § 371 to violate 18 U.S.C.

§ 2312 (Transportation of stolen vehicles), 18 U.S.C. § 2313 (sale or

receipt of stolen vehicles), 18 U.S.C. § 1341 (mail fraud), and 18 U.S.C.

§1343 (wire fraud). FBI Detroit has been investigating a group of

individuals based in the Toledo and Detroit area that have been involved

with numerous vehicle thefts including many that have been

subsequently transported across state lines. On August 14, 2023, seven

of those subjects were charged via Complaint with conspiracy to

transport/receive/sell stolen vehicles. On August 24, 2023, a grand jury

returned an Indictment against those same individuals. See United

States v. Ronnie Smith, et al Case No. 23-cr-20489-BAF-APP (E.D. Mich.

2023.)

2
 Case 2:23-mj-30370-DUTY ECF No. 1, PageID.4 Filed 09/08/23 Page 4 of 17

4. One of those subjects, Ronnie Smith, was arrested on April

13, 2023, and his cellular telephone was seized and searched pursuant

to a search warrant. Analysis of Smith’s cell phone revealed a

Telegram chat with an individual named “Rob” with a corresponding

telephone number of XXX-XXX-2974. The user of that number was

subsequently identified as Robert Clinton Thomas via Verizon Wireless

records. In addition, a subsequent court authorized electronic location

ping data warrant of XXX-XXX-2974 shows that Thomas was at the

residence located at 6006 Hill Circle Drive, Nashville, Tennessee.

5. The text message exchanges between Thomas and Smith

show that Thomas has been dealing with an auto theft crew in the

Nashville area and has been providing fraudulent identifications,

plates, titles and VINs so that stolen cars can be concealed, transported,

and sold. Thomas also sends Smith vehicles from across the country

that he believes will be easy targets to steal because they are in

ungated dealer lots etc.

6. Thomas reportedly owns Elite Auto Partners, which

purports to be a used automobile dealership with a public-facing

website; however, attempts by investigators to locate a business license

3
 Case 2:23-mj-30370-DUTY ECF No. 1, PageID.5 Filed 09/08/23 Page 5 of 17

or registration with the State of Tennessee have produced no known

records of the business at the time of this Affidavit. A known law

enforcement and public records database lists the name “Elite Auto

Partners” with a DUNS number 07-474-0383 and lists the company’s

Principal contact as Robert Thomas, using a private PO Box at XXX

Thompson Lane in Nashville, Tennessee, which is the same known

mailing address used by Thomas on his official Tennessee Driver’s

License.

7. There are several instances of Thomas sending Smith

fraudulent identifications, plates, titles and VINs so that stolen cars can

be concealed, transported, and sold in March through April of 2023.

PROBABLE CAUSE

Text Messages

8. On March 11, 2023, the chat between Thomas and Smith

shows that Thomas tells Smith “you can trust me.” “Millie, Kash, trust

me with ALL they business.” Thomas then says, “I’ll show you my past

charges if you want proof. Never talked, took my charge.” Smith

responds, “I got you I trust you more better now.” On or about July 10,

4
 Case 2:23-mj-30370-DUTY ECF No. 1, PageID.6 Filed 09/08/23 Page 6 of 17

2019, Thomas entered a no contest plea to Identity Theft charges in

Waukesha County Court in Wisconsin.

9. M.O., aka Millie and T.S., aka Kash are Tennessee

residents. M.O. is currently in custody at the Williamson County Jail in

Franklin, Tennessee on charges stemming from his arrest on April 14,

2023. On April 14, 2023, Brentwood Police Department executed a

search warrant and seized drugs, guns (including one stolen firearm),

cars and nine counterfeit Vehicle Identification Numbers along with

what appeared to be counterfeit temporary registration plates and other

assorted documents. In the above message exchange, Thomas is letting

Smith know that he already does business with Millie and Kash. Smith

then lets Thomas know that his association with those two subjects

establishes his credentials as being involved in prior stolen car schemes

as further illuminated by their continued conversations.

10. Thomas then sends Smith pictures of Vehicle Identification

Numbers (VIN) to which Smith responds, “You get vins?” Thomas

replies, “Yessir. Titles too.” Thomas continues, “My best ones I can get

come from overseas and take 1-2 weeks to get here.” “Other option I can

get here in 2-3 days but not 100 probably 95-97%. Still very good.”

5
 Case 2:23-mj-30370-DUTY ECF No. 1, PageID.7 Filed 09/08/23 Page 7 of 17

Thomas then sends Smith a video of a Certificate of Title for the State

of Illinois and an FCA VIN sticker. Thomas then asks Smith to “Send

me the VINs you want before you leave so I can get them asap.” Smith

then asks, “You can get me a id made rn?” Thomas responds, “Yes” and

then sends Smith an image of a Tennessee driver license. Smith writes,

“Make me a driver license,’ and Thomas responds, “What state you

want? I don’t have them all but I have several.” Smith writes, “Which

ever you think best state is.” Thomas sends an image of a Kentucky

driver license and asks Smith to, “Send me the VINs you want so I can

get them ordered tomorrow.” Smith then sends him a VIN number and

year, make, model of a vehicle.

11. On March 15, 2023, Smith asks Thomas, “What you want for

getting the vins for me.” Thomas responds, “Bro all I want rn is that

Durango. I been watching that bitch for 6-7 weeks now.” Thomas had

previously sent Smith an image of a Durango parked in a lot in St. Louis,

Missouri. Thomas had sent Smith a message, “If you go to STL tho there

are like 5-6 other hellcat Durangos there. I already got a list of places

that we was gonna check out so just let me know.” Smith asks Thomas,

“You not police is you bro?” Thomas responds, “How many times you gotta

6
 Case 2:23-mj-30370-DUTY ECF No. 1, PageID.8 Filed 09/08/23 Page 8 of 17

check my credentials… lol.” “I’ll go out with you when you here if you

want. You just watch and I will take some shit.” Smith writes, “Cause

man most Plp ain’t as cool n a be tryna fucc with sumbody they don’t

know.” Thomas responds, “Naaa.. it’s just tbh.. my little crew sucks. They

lazy, don’t wanna drive, then they get greedy and shit.” “I been asked

them to get that durango but they don’t wanna drive… so I am like fuck

it.. you entered the picture and im like fuck Im gonna take care of this

dude to get him to fwm. That’s all.” Smith responds, “Bet that makes

more sense now.” Thomas continues, “I can’t wait for that bitch to be here

and then they like how/when you get that?? Ahh yea, fuck you.. I got

someone else that fwm now.” “Yea I got all kinds of plays bro, but my

people be getting so lazy and then picky.. I’m like money is money bro..

tf”. Thomas also writes, “They got HC Durangos sitting out in STL…

makes me thing that city ain’t been hit hard yet”. Thomas sends Smith a

picture followed by the message, “You ever seen one of these?” Smith

responds, “He’ll nah what’s that” and Thomas explains, “it’s a lockpick

for dodges. I bought it over a year ago. Ive tried it dozens of times

practicing on my own shit and can’t do t. But mfrs on youtube can pick

7
 Case 2:23-mj-30370-DUTY ECF No. 1, PageID.9 Filed 09/08/23 Page 9 of 17

the door locks in seconds with that bitch.” Thomas then sends the

YouTube video to Smith.

12. On March 16, 2023, Thomas and Smith continue their chat

sending each other possible vehicles to target. After Smith sends Thomas

an image of a 2020 Jeep Grand Cherokee Trackhawk for sale on

CarGurus, Thomas responds, “That bitch will sell fast”. “Let me know

if/when you gonna grab it and I will sent it to a few people. I’ll crop info.

But Kash will definitely have plays on it too. Probably faster than mine.”

Thomas sends Smith an image of a Michigan dealer license plate followed

by the message, “So we ride on shit like this down here bc the paper tags

burnt up and they usually fake. This way if a license plate camera gets

the tag it’s not reported stolen, doesn’t come back to anyone, but most

will leave you alone. Just cover the 20 with a license plate frame.” Smith

responds, “I got some down here but they all reported stolen already”.

Thomas then writes, “These are clean”. “Not stolen, I buy them” and

sends Smith images of three additional dealer plates from other states.

Thomas continues, “I just feel safer with these on a opp… can throw them

away no big deal.” Thomas also writes, “Don’t forget I can pull the

address from tag or VIN so if someone see something out just get a pic”.

8
 Case 2:23-mj-30370-DUTY ECF No. 1, PageID.10 Filed 09/08/23 Page 10 of 17

13. On March 18, 2023, Thomas sends Smith images of dealer

plates with a message that states “plates came in”. Smith sends Thomas

an image of a temporary tag from Oklahoma with the message, “I need

tag like this”. Thomas responds, “I can make that” and “I have TX and

AZ ones like that rn”.

14. On March 19, 2023, Smith talks about coming down to

Tennessee and Thomas asks, “You want me to try to line you up a sale

or two while you here?” Smith responds, “Yeah for track hawk hellcat

charger n SRT Jeep see which one they want”, “$12k track hawk $10k

hellcat $5k SRT Jeep”. Thomas responds, “Helps if I have a couple

pictures.” Thomas sends Smith pictures and video of vehicle frames in a

garage or storage area with the message, “Told you I’m in it bro”.

15. On March 21, 2023 Thomas sends Smith an image of VIN

stickers with the message, “Your 300” and Smith responds, “It got door

sticker too”. Thomas writes back, “Yeah, that was just the preview

before he prints”.

16. On March 26, 2023, Smith writes, “When vins a be here?”

Thomas responds, “Man.. im not sure exactly. They got shipped but they

coming from the Ukraine”. Thomas then sends Smith a screen shot of a

9
 Case 2:23-mj-30370-DUTY ECF No. 1, PageID.11 Filed 09/08/23 Page 11 of 17

DHL shipment that departed from a DHL facility KYIV-UKRAINE on

Saturday, March 25, 2023 at 1:45 PM. Smith writes, “N I need temp tag

asap”. Thomas responds, “I can only make the legit ones M thru F

during business hours…” “I can email to you tomorrow or I can print,

laminate and next day it to you.” Smith answers, “Email it to tmr I’ll

get it printed out”.

17. On March 27, 2023, Thomas writes, “Be a few more minutes

on the tags. Had to fix something”. Smith responds, “Bet once you send

it ima be on road to Nashville”. Thomas then sends Smith a temporary

license plate tag and registration for a 2018 Jeep. Smith has already

been charged with stealing a 2018 Jeep Cherokee from the Pittsburgh

airport on March 25, 2023. Smith writes Thomas, “Email it to me

because idk how to do it” and provides his email address. Thomas

responds, “Sent”.

18. On March 28, 2023, Thomas asks Smith, “You good?” Smith

replies, “Yeah riding around tryna see what’s going on”. Thomas writes,

“Ok.. be careful bro. Don’t push anything. There are plenty of sate plays

down this way.” “You still got the other shit to sell”. Smith responds,

“Yeah”, “Got cat rango SRT Jeep track hawk N Bently”. Smith sends

10
 Case 2:23-mj-30370-DUTY ECF No. 1, PageID.12 Filed 09/08/23 Page 12 of 17

Thomas photos of a black Jeep Cherokee. Smith further describes it as

“Black hawk 2018 25k miles”. Thomas asks for “Price?” Thomas sends

Smith a screen shot of a text message thread where he is attempting to

broker a deal. Thomas writes, “Also I don’t wanna fuck up any sales

Kash got lined up if he expecting them”.

19. On March 31, 2023, Smith sends Thomas a photograph of a

red Jeep Grand Cherokee that he has been charged with stealing from a

dealership in Woodbridge, Virginia around the same time on the same

date. Thomas asks, “You get it?” Smith responds “Yessir”. Thomas then

asks, “Way rn. Got someone that want the red one”. Thomas continues,

“Dude already knew that track. He is 45 mins from where you got it

from”. This conversation continues and Thomas tries to broker a deal.

Thomas and Smith also exchange phone calls during this time. Thomas

even provides an address for the buyer, but the deal ultimately falls

through because Smith is too far away and doesn’t want to turn back.

At 3:38pm, Smith writes, “Just got back up I got another hawk”. Smith

has been charged with stealing a Jeep Grand Cherokee Track Hawk

approximately one hour before that message at the Pittsburgh airport.

11
 Case 2:23-mj-30370-DUTY ECF No. 1, PageID.13 Filed 09/08/23 Page 13 of 17

Smith subsequently sends Thomas a photograph of that vehicle which

has a distinct saddle brown colored interior.

20. On April 4, 2023, Thomas sends Smith a screen shot from

DHL indicating that his shipment has been delivered. Smith sends

Thomas a screen shot of a text message thread between Smith and

Kash. Smith writes to Thomas, “I’m heading to cash today at 5”. Smith

asks, “You Don’t want the red track do you?” Thomas replies, “No but I

can find a buyer if you need me to”.

21. On April 5, 2023, Smith writes, “What dealership I should go

to down here?” Thomas responds, “Imma make you a list. What you got

here that’s still available for sale?” Smith responds, “Track hawk”.

Thomas asks, “the red one right?” Smith writes, “Yeah” and “N 21 22k

miles”. Smith sends Thomas photographs of a vehicle. Smith then

writes, “2022 392 rango 3k miles”. Smith is charged with stealing a

2021 Dodge Durango Hellcat 392 from the Indianapolis airport around

this time on this date.

22. On April 6, 2023, Thomas sends Smith a message, “Oh I got

a good bite on selling the track,” “is the Red one still available?” Smith

responds, “Yeah” and sends Thomas a video of the vehicle. Thomas

12
 Case 2:23-mj-30370-DUTY ECF No. 1, PageID.14 Filed 09/08/23 Page 14 of 17

responds, “Clean af.. dude gonna buy it. Can I send that video? Your

face in the reflection a little.” Smith writes, “Edit it don’t send full

video”.

23. On April 7, 2023, Thomas writes, “Just focus on me.. trust me

bro. My resources gonna 3-4x your bread.” Thomas then sends Smith a

video of the VINs that have arrived and continues, “But fr bruh, you got

a good $100-120k on the floor with me with just those. Fuck what else

you got goin on. This big money right here. And don’t think I’m some duck

bc I’m white and been cool. I aint goin haha. Jump on my shit, make it

happen, get this money bruh!!”

24. On April 9, 2023, Thomas writes, “Bruh if you get that imma

make sure you bring in at least 100k with these ones we gonna flip”.

Smith writes, “Police came we got the key to em the alarm in building

went off”. “My dude got him a g wagon but he ain’t selling it”. Smith then

sends Thomas a picture of a blue Charger that he has been charged for

stealing from a dealership in West Virginia and writes, “I’m tryna trade

him this n. Money for it rn”. Thomas responds, “Instead of money tell him

I already have VIN stickers and I will make a title for it. He will be able

to sell it for 65-70k”.

13
 Case 2:23-mj-30370-DUTY ECF No. 1, PageID.15 Filed 09/08/23 Page 15 of 17

Search Warrant Execution

25. Brentwood Police conducted surveillance at 6006 Hill Circle

Drive and observed several suspects charged and/or suspected of being

involved in stealing motor vehicles arrive and depart from the

residence. Officers observed Thomas interact with these individuals.

The subjects were observed coming and going in high end motor

vehicles.

26. On September 5, 2023, a federal search warrant was signed

by a U.S. Magistrate Judge in Middle District of Tennessee authorizing

a search of Thomas’ residence based on the above listed information.

27. On September 6, 2023, FBI Nashville executed the

aforementioned federal search warrant at Thomas’ residence located at

6006 Hill Circle Drive, Nashville, Tennessee. This search revealed

numerous fraudulent items and the tools to make them including but

not limited to: driver licenses, vehicle titles, manufacturer stickers,

vehicle identification numbers, license plates, printers, heat sealers and

stickers. Window stickers corresponding to stolen vehicles were also

recovered as well as $2,700.00 in cash. Additionally, parked at the

14
 Case 2:23-mj-30370-DUTY ECF No. 1, PageID.16 Filed 09/08/23 Page 16 of 17

residence was a Mercedes G63 Wagen stolen out of Los Angeles,

California and a Dodge Charger stolen out of Phoenix, Arizona.

28. While at the scene, an individual, T.B., drove up in a Ford

Bronco that he indicated he was borrowing from Thomas. Further

investigation revealed that this vehicle had been reported stolen out of

Wisconsin. The search also revealed a large number of receipts

corresponding to mailed items and vehicle registration applications.

Some of these applications were blank and others had been filled out

with other individual’s personal information. (maybe say believed to be

fraudulently obtained) Numerous key fobs were also recovered in

different areas of the residence. Based on my training and experience,

these key fobs are necessary items needed to steal cars and

subsequently possess and sell those vehicles.

29. Based on my training and experience, the presence of all the

above listed items at one residence is indicative of Thomas’ running a

vehicle chop shop out of his residence where he is able to reregister,

retag, retitle, modify and rekey stolen vehicles.

30. Based on the foregoing, there is probable cause to believe

that Robert Thomas was involved in a conspiracy pursuant to 18 U.S.C.

15
 Case 2:23-mj-30370-DUTY ECF No. 1, PageID.17 Filed 09/08/23 Page 17 of 17

§ 371 to violate 18 U.S.C. § 2312 (Transportation of stolen vehicles), 18

U.S.C. § 2313 (sale or receipt of stolen vehicles), 18 U.S.C. § 1341 (mail

fraud), and 18 U.S.C. §1343 (wire fraud).

Respectfully submitted,

____________________________
Sean Callaghan, Special Agent
Federal Bureau of Investigation

Sworn to before me and signed in my presence

and/or by reliable electronic means

____________________________________ September 8, 2023

HON. DAVID R. GRAND
United States Magistrate Judge

16