Robert Thomas Complaint
Robert Thomas Complaint
Robert Thomas Complaint
1
Filed 09/08/23
J M Page 1 of313
17 226-9759
AO 91 (Rev. 11/11) Crimina Complint 313 965-2323
CRIINAL COMLAINT
k
O ) M 11 2023 6 2023 h Wy
E M )
Code Section Ofense Description
18 u.s.c. § 371
18 u.s.c. § 2312 V
18 § 2313 R V
18 § 1341 M Fu
18 § 1343 W Fu
Comlainant's signature
September 8, 2023
e: _ Judge's signature
Ci a se: Dt, M H R v W, M Ju
Printed nae and title
Case 2:23-mj-30370-DUTY ECF No. 1, PageID.2 Filed 09/08/23 Page 2 of 17
AFFIDAVIT
by the Troy Police Department and the Ohio State Highway Patrol
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
(wire fraud).
EXECUTIVE SUMMARY
individuals based in the Toledo and Detroit area that have been involved
2023.)
2
Case 2:23-mj-30370-DUTY ECF No. 1, PageID.4 Filed 09/08/23 Page 4 of 17
13, 2023, and his cellular telephone was seized and searched pursuant
show that Thomas has been dealing with an auto theft crew in the
plates, titles and VINs so that stolen cars can be concealed, transported,
and sold. Thomas also sends Smith vehicles from across the country
3
Case 2:23-mj-30370-DUTY ECF No. 1, PageID.5 Filed 09/08/23 Page 5 of 17
enforcement and public records database lists the name “Elite Auto
License.
fraudulent identifications, plates, titles and VINs so that stolen cars can
PROBABLE CAUSE
Text Messages
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
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
search warrant and seized drugs, guns (including one stolen firearm),
Smith know that he already does business with Millie and Kash. Smith
then lets Thomas know that his association with those two subjects
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
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
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
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
12. On March 16, 2023, Thomas and Smith continue their chat
sending each other possible vehicles to target. After Smith sends Thomas
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.”
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
plates with a message that states “plates came in”. Smith sends Thomas
tag like this”. Thomas responds, “I can make that” and “I have TX and
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
garage or storage area with the message, “Told you I’m in it bro”.
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”.
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
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
laminate and next day it to you.” Smith answers, “Email it to tmr I’ll
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
license plate tag and registration for a 2018 Jeep. Smith has already
been charged with stealing a 2018 Jeep Cherokee from the Pittsburgh
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
“Black hawk 2018 25k miles”. Thomas asks for “Price?” Thomas sends
broker a deal. Thomas writes, “Also I don’t wanna fuck up any sales
red Jeep Grand Cherokee that he has been charged with stealing from a
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
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
11
Case 2:23-mj-30370-DUTY ECF No. 1, PageID.13 Filed 09/08/23 Page 13 of 17
DHL indicating that his shipment has been delivered. Smith sends
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
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
2021 Dodge Durango Hellcat 392 from the Indianapolis airport around
a good bite on selling the track,” “is the Red one still available?” Smith
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”.
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
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
13
Case 2:23-mj-30370-DUTY ECF No. 1, PageID.15 Filed 09/08/23 Page 15 of 17
The subjects were observed coming and going in high end motor
vehicles.
numerous fraudulent items and the tools to make them including but
14
Case 2:23-mj-30370-DUTY ECF No. 1, PageID.16 Filed 09/08/23 Page 16 of 17
investigation revealed that this vehicle had been reported stolen out of
Some of these applications were blank and others had been filled out
these key fobs are necessary items needed to steal cars and
15
Case 2:23-mj-30370-DUTY ECF No. 1, PageID.17 Filed 09/08/23 Page 17 of 17
Respectfully submitted,
____________________________
Sean Callaghan, Special Agent
Federal Bureau of Investigation
16