Page:Richard Pinedo Statement of Offense.pdf/1



UNITED STATES OF AMERICA
 * v.

RICHARD PINEDO,
 * Defendant.

______________________________________

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Criminal No.: 18 CR 24. Violation: 18 U.S.C. § 1028 (Identity Fraud) FILED FEB 12 2018 Clerk, U.S. District and Bankruptcy Courts

Pursuant to Federal Rule of Criminal Procedure 11, the United States of America and the defendant, RICHARD PINEDO, stipulate and agree that the following facts are true and accurate. These facts do not constitute all of the facts known to the parties concerning the charged offense; they are being submitted to demonstrate that sufficient facts exist that the defendant committed the offense to which he is pleading guilty.

1. From approximately 2014 through December 2017, the defendant, RICHARD PINEDO, operated an online service called "Auction Essistance." Through Auction Essistance, Pinedo offered a variety of services designed to circumvent the security features of large online digital payment companies, including a large digital payments company hereinafter referred to as Company 1.

2. PINEDO sold bank account numbers through interstate and foreign commerce, specifically over the internet. PINEDO obtained bank account numbers either by registering accounts in his own name or by purchasing accounts in the names of other people through the internet. Many of the bank accounts purchased by PINEDO over the internet were created using stolen identities of U.S. persons. Although PINEDO was not directly involved in the registration