2024-10-25 DOJ SDNY complaint 26,418 chars

United States v. ARSEN LUSHER, Southern District of New York (Oct. 25, 2024) — Complaint

raw: U.s. V. Lusher Complaint

U.s. V. Lusher Complaint (S.D.N.Y. Oct. 25, 2024)

Caption: United States v. Arsen Lusher

Exhibit of New Jersey Man Charged For Multi-Year, Multi-Million Dollar Fraud

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summary

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narrative

Arsen Lusher, a New Jersey resident, has been charged by the U.S. government with wire fraud and aggravated identity theft for running a Ponzi scheme that defrauded over 20 victims, including Victim-1 who invested $3 million and lost $1.7 million, of over $5 million. Lusher used the funds for personal expenses such as gambling and shopping, and provided falsified tax documents and altered bank statements to deceive his victims. He also created fraudulent emails to reassure investors about their investments in his trucking business, and transferred funds from one victim's investment to his own accounts to pay off debts and other expenses. A federal agent has requested a warrant for Lusher's arrest, alleging he failed to return promised investments to a victim. The scheme involved creating fraudulent emails to reassure investors, transferring funds from one victim's investment to his own accounts, and using the funds for personal expenses such as gambling and shopping. The total amount of money defrauded from the victims is over $5 million.

Enriched metadata

Scheme: ponzi (100%)
Court: Southern District of New York

Classified ponzi(confidence 100%). EDGAR detection: forms Form D· recall 35% / precision 15%. detection rule →

Extracted insights

Dollar amounts 23

$40.00M $40 million $10M–$100M
$5.00M $5 million $1M–$10M
$3.00M $3 million $1M–$10M
$2.25M $2.25 million $1M–$10M
$2.00M $2 million $1M–$10M
$1.70M $1.7 million $1M–$10M
$1.30M $1.3 million $1M–$10M
$1.23M $1,228,767 $1M–$10M
$987K $987,320 $100K–$1M
$459K $459,025 $100K–$1M
$300K $300,000 $100K–$1M
$175K $175,000 $100K–$1M

Entities 5

person Arsen Lusher ×2
person Deniele T. Deboer ×2
agency a special agent with the fbi
agency Federal Bureau of Investigation
person Joseph H. Rosenberg

Triples 4

Arsen Lusher engaged in scheme to defraud approximately more than 20 victims of approximately more than $5 million
Arsen Lusher used false statements to obtain money for purported trucking business, but actually to enrich himself and pay earlier investors
Arsen Lusher transferred and used the name and tax preparer information of another person without lawful authority
Deniele T. DeBoer is a Special Agent with the FBI

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U.s. V. Lusher Complaint · Source

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Extracted body text (26,418c)

AUSA: Joseph H. Rosenberg

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA

ARSEN LUSHER,

Defendant.

SEALED COMPLAINT

Violations of 18 U.S.C. §§ 1028A, 1343,
and 2.

COUNTY OF OFFENSE:
NEW YORK

SOUTHERN DISTRICT OF NEW YORK:

DENIELE T. DEBOER, being duly sworn, deposes and says that she is a Special Agent
with the Federal Bureau of Investigation (“FBI”), and charges as follows:

COUNT ONE
(Wire Fraud)

1. From at least in or about 2017 through at least in or about February 2021, in the
Southern District of New York and elsewhere, ARSEN LUSHER, the defendant, knowingly
having devised and intending to devise a scheme and artifice to defraud, and for obtaining money
and property by means of false and fraudulent pretenses, representations, and promises, transmitted
and caused to be transmitted by means of wire, radio, and television communication in interstate
and foreign commerce, writings, signs, signals, pictures, and sounds, for the purpose of executing
such scheme and artifice, to wit, LUSHER engaged in a scheme to make false statements to
numerous individuals to obtain money for the purported purpose of investing that money in a
trucking business, but which LUSHER in fact used primarily to enrich himself and to pay earlier
investors.

(Title 18, United States Code, Sections 1343 and 2.)

COUNT TWO
(Aggravated Identity Theft)

2. In or about December 2020, in the Southern District of New York and elsewhere,
ARSEN LUSHER, the defendant, knowingly transferred, possessed, and used, without lawful
authority, a means of identification of another person, during and in relation to a felony violation
enumerated in Title 18, United States Code, Section 1028A(c), to wit, LUSHER used and
transferred the name and tax preparer information of another person during and in relation to the
wire fraud violation charged in Count One of this Complaint.

(Title 18, United States Code, Sections 1028A(a)(1), 1028A(b), and 2.)

The bases for my knowledge and for the foregoing charges are, in part, as follows:

24 MAG 3662

3. I have been a Special Agent with the FBI since approximately 2011. I am assigned
to an FBI squad that primarily investigates Eurasian organized crime. During my tenure with the
FBI, I have, among other things, participated in the investigation of numerous frauds, including
securities fraud and other white-collar offenses. This affidavit is based upon my personal
participation in this investigation, as well as on my conversations with other law enforcement
officers and my examination of documents, reports, and records. Because this affidavit is being
submitted for the limited purpose of establishing probable cause, it does not include all the facts I
have learned during the investigation. Where the contents of documents or the actions, statements,
or conversations of others are reported herein, they are reported in substance and in part, except
where otherwise indicated.

Overview of the Scheme

4. From at least 2017 to at least in or about February 2021, ARSEN LUSHER, the
defendant, with others known and unknown, engaged in a scheme to defraud approximately more
than 20 victims (the “Victims”) of approximately more than $5 million (the “Scheme”). In the
Scheme, LUSHER and a small group of trusted lieutenants acting at LUSHER’s direction solicited
investments from the Victims, usually by representing that LUSHER had a profitable trucking
business that enjoyed delivery and installation contracts with multiple large retailers. LUSHER
and his lieutenants typically represented that the Victims’ investments would fund the purchase of
trucks, each truck costing around $45,000. Through written and signed investment agreements,
LUSHER and his lieutenants normally guaranteed the Victims that their investments would
generate high rates of return over a fixed period—typically between 30 and 40 percent over one or
two years. In that way, LUSHER succeeded in raising approximately more than $40 million from
the Victims during the Scheme.

5. In fact, though, LUSHER did not have a large trucking business. Instead, based on
my review of records obtained from several large retailers, I have learned that LUSHER had a
small trucking business that performed a small amount of work for one large retailer
(“Retailer-1”)—less than $300,000—between in or about 2019 and in or about 2021. Contrary to
his representations, LUSHER does not appear to have performed any trucking work for other large
retailers. Accordingly, the amount that LUSHER earned from his legitimate trucking business
could not have compensated the Victims and produced the promised returns.

6. Indeed, LUSHER did not use the Victims’ funds to purchase trucks or to grow his
trucking business. Instead, for years, LUSHER engaged in a Ponzi scheme: LUSHER paid earlier
Victims with later Victims’ funds. In that way, LUSHER was able to sustain the Scheme for a
number of years. But in early 2021, the Scheme came crashing down, leaving numerous Victims
with losses exceeding approximately $5 million.

7. To effectuate the Scheme, LUSHER used primarily three companies that he
incorporated and controlled: (a) Xtreme HD, Inc., (b) Install Masters LLC, and (c) Master Installs
LLC (the “LUSHER Companies”). As mentioned above, LUSHER had a small group of trusted
lieutenants—including an individual (“Individual-1”) and another individual who acted as
Individual-1’s assistant—whom LUSHER tasked with soliciting investors; creating companies
(the “Middleman Companies”) to enter into investment contracts with those investors; opening
bank accounts for the Middleman Companies; and funneling the money from those investors
through the Middleman Companies to the LUSHER Companies. Based on my review of financial

records, I have learned that, once a Middleman Company forwarded an investor’s money to one
of the LUSHER Companies, LUSHER would typically, inter alia, (a) transfer that money to the
other LUSHER Companies, (b) transfer that money to other Middleman Companies, and/or (c)
enrich himself, such as by gambling or shopping for high-end goods.

Examples of the Scheme

8. Based on my review of documents provided by Victims, WhatsApp
communications, financial records and other documents provided by financial institutions,
documents provided by Internet service providers, wireless service providers, betting companies
and casinos, and large retailers, publicly available court documents, documents obtained through
law enforcement databases, and my conversations with Victims, witnesses, and law enforcement
officers, I have learned the following, among other things:

Victim-1

a. Victim-1 resides primarily in or around Miami, Florida. Victim-1 met
Individual-1 in approximately 2017 through a mutual friend. Individual-1 told Victim-1, in
substance and in part, that Individual-1’s partner ran a trucking business that enjoyed delivery
contracts with large retailers. Victim-1 later learned from Individual-1 that Individual-1’s partner
was LUSHER. Individual-1 told Victim-1, in substance and in part, that LUSHER’s trucking
business’s contracts with those large retailers were “guaranteed” by the large retailers for 24
months. Based in part on Individual-1’s representations, Victim-1 decided to invest in LUSHER’s
alleged trucking business on several occasions between in or about December 2018 and in or about
October 2020. In addition, over approximately the same period, Victim-1 persuaded several
associates to invest with LUSHER in exchange for the promise of a referral payment. In total,
Victim-1 invested approximately $3 million with LUSHER, and received in return approximately
$1.3 million. Accordingly, Victim-1 was defrauded by LUSHER approximately $1.7 million.

b. Based on my review of financial records, I know that some of the money

that Victim-1 invested into LUSHER’s alleged trucking business flowed through the Middleman
Companies into a particular business bank account at Wells Fargo (the “Xtreme HD Wells Fargo
Account”).1 During the course of Victim-1’s investments into the Scheme, LUSHER appears to
have used the Xtreme HD Wells Fargo Account, in part, to finance LUSHER’s own gambling
habits and high-end shopping. For example, between in or about May 2020 and in or about
October 2020, the Xtreme HD Wells Fargo Account disbursed approximately $459,025 to
FanDuel, an online gambling company. Similarly, between in or about December 2018 and in or
about August 2020, approximately $17,056.89 in ATM withdrawals were made from the Xtreme
HD Wells Fargo Account from an ATM located in the immediate vicinity of or inside the Borgata
Hotel Casino & Spa, a casino in Atlantic City, New Jersey. Furthermore, on or about April 5,

1 Based on my involvement in this investigation and my review of records from Wells Fargo,
I know that the Xtreme HD Wells Fargo Account was one of the accounts LUSHER used to
perpetrate the Scheme. On or about September 19, 2014, LUSHER opened the Xtreme HD Wells
Fargo Account for Xtreme HD, Inc., one of the LUSHER Companies, declaring that LUSHER
was the owner with control of Xtreme HD, Inc., and providing the LUSHER Email Address-2
(defined below).

2019, an American Express card I believe to be used by LUSHER (the “LUSHER AmEx Card”)
racked up thousands of dollars in high-end shopping expenses in Hong Kong, including
approximately $15,000 at luxury retailers.2 In or about April and May 2019, two payments were
made to pay down the balance on the LUSHER AmEx Card; both payments were made from the
Xtreme HD Wells Fargo Account. More generally, between in or about December 2018 and April
2020, the Xtreme HD Wells Fargo Account was used to make more than 20 payments on the
LUSHER AmEx Card, paying down balances totaling more than approximately $175,000.

c. During the course of his investments in the Scheme, Victim-1 met LUSHER

on several occasions. For example, on or about March 11, 2020, Victim-1 met LUSHER and
Individual-1 for a tour of a Retailer-1 distribution and fulfillment facility located in or around
Piscataway, New Jersey. There, a Retailer-1 employee gave LUSHER, Individual-1, and Victim-1
a tour, which left Victim-1 feeling confident that Victim-1’s investments were safe, because
LUSHER’s trucking business appeared to be thriving. LUSHER told Victim-1, in substance and
in part, that LUSHER’s trucking business was booming and encouraged Victim-1 to invest more.
Following that tour, Victim-1 invested approximately $2.25 million more into LUSHER’s trucking
business. On or about December 8, 2020, Victim-1 met LUSHER, Individual-1, and others at the
same Retailer-1 distribution and fulfillment facility in Piscataway, New Jersey, for a similar tour.
Again, the tour left Victim-1 feeling as though his investments in LUSHER’s trucking business
were safe.

d. On or about December 16, 2020, LUSHER created and caused to be sent to
Victim-1 a falsified 2019 tax form for Xtreme HD, Inc., as follows:

i. On or about December 10, 2020, Victim-1 sent Individual-1 a text

message on WhatsApp, asking, in substance and in part, for tax returns for the LUSHER
Companies.

ii. On or about December 14, 2020, an email address I believe to be

controlled by LUSHER (the “LUSHER Email Address-1”) sent an email to an email address I
believe to be controlled by Individual-1 (the “Individual-1 Email Address”), attaching a purported
“income statement” for Xtreme HD, Inc. for the year 2019 (the “2019 Xtreme HD Income
Statement”).3 On or about December 15, 2020, the Individual-1 Email Address forwarded the

2 Based on my review of records obtained from American Express, I know that on or about
December 16, 2017, an individual named “Arsen Lusher” submitted an application to American
Express, providing a date of birth that, based on my review of law enforcement and other records,
I know to be LUSHER’s date of birth, and the LUSHER Home Address (defined below).
3 I believe that LUSHER controls the LUSHER Email Address-1 for several reasons. For
example, records from Google show that the subscriber for the LUSHER Email Address-1
provided a recovery email address and a recovery phone number. Records received from Yahoo
indicate that the subscriber of the recovery email address is “art lusher.” Records obtained from
Verizon indicate that the recovery phone number is subscribed to by “Arsen Lusher,” and with the
business name “Xtreme HD Inc.” I believe that Individual-1 controls the Individual-1 Email
Address for several reasons, including that records from Google indicate that Individual-1 is the
subscriber of the Individual-1 Email Address.

2019 Xtreme HD Income Statement to an email address that I believe, based on my conversations
with Victim-1, to be controlled by Victim-1 (the “Victim-1 Email Address”).

iii. On or about December 15, 2020, after receiving the 2019 Xtreme

HD Income Statement, Victim-1 texted Individual-1 over WhatsApp stating, in substance and in
part, that Victim-1 had asked for tax returns, not a financial statement. Individual-1 then texted
LUSHER, also over WhatsApp, explaining, in substance and in part, that Victim-1 still wanted to
see tax returns for the LUSHER Companies. LUSHER and Individual-1 then exchanged the
following text messages over WhatsApp:

Date Time Sender Recipient Content

Dec. 15, 2020 8:27:03 a.m. LUSHER Individual-1 Ok I’ll request the returns
Dec. 15, 2020 8:27:14 a.m. Individual-1 LUSHER [thumbs up emoji]
Dec. 15, 2020 8:29:02 a.m. LUSHER Individual-1 I hope this doesn’t backfire
Dec. 15, 2020 8:31:08 a.m. Individual-1 LUSHER It won’t
Dec. 15, 2020 8:31:42 a.m. Individual-1 LUSHER What can I do with them???
Dec. 15, 2020 8:32:23 a.m. LUSHER Individual-1 I’m not worried about you.

iv. On or about December 16, 2020, at approximately 1:21 p.m., an

email address I believe to be controlled by LUSHER (the “LUSHER Email Address-2”) emailed
the Individual-1 Email Address, attaching a five-page document titled “XTREME HD 2019,”
which was a purported U.S. Income Tax Return for an S Corporation for the tax year 2019 for
Xtreme HD, Inc. (the “Fraudulent Return”).4 The bottom of page one of the Fraudulent Return
displayed a section called “Paid Preparer Use Only,” which was purportedly completed and signed
by a particular accountant authorized to prepare and file the Fraudulent Return (the “Defrauded
Accountant”). On or about December 16, 2020, at approximately 10:42 p.m., the Individual-1
Email Address forwarded the Fraudulent Return to the Victim-1 Email Address.

v. On or about August 19, 2021, I participated in an interview with the
Defrauded Accountant. In substance and in part, the Defrauded Accountant explained that,
although the Fraudulent Return contained accurate information about the Defrauded Accountant
(such as the Defrauded Accountant’s name, business address, and employer identification
number), the Defrauded Accountant had not provided tax accounting services to LUSHER and
had not prepared or signed the Fraudulent Return.

e. On or about February 16, 2021, LUSHER created and caused to be sent to
Victim-1 a falsified email, in which LUSHER altered the account balances reported to him by an
employee from Signature Bank, as follows:

i. On or about January 15, 2021, LUSHER submitted applications to

open business checking accounts at Signature Bank for (1) Xtreme HD, Inc., and (2) Install Masters

4 I believe that LUSHER controls the LUSHER Email Address-2 for several reasons. For
example, the email address—“[email protected]”—contains a shortened version of
LUSHER’s name. In addition, records from GoDaddy indicate that the domain
“xtremeinstalls.net” was registered in or about 2013 by an individual named “artie lusher.”

LLC. In the application for Xtreme HD, Inc., LUSHER represented that Xtreme HD, Inc., was a
“logistics company” that did “delivery and installation for [Retailer-1] and other retailers.”
LUSHER stated that he owned 100 percent of Xtreme HD, Inc., and provided the LUSHER Email
Address-1 as his contact email. In the application for Install Masters LLC, LUSHER represented
that Install Masters LLC was a “logistics company that delivers and installs for big box retails [sic]
and private customers.” LUSHER also stated that he was a “member” of Install Masters LLC,
who owned 99% of the company. To open the account, LUSHER provided the LUSHER Email
Address-2 as his contact email.

ii. On or about February 14, 2021, Victim-1 texted Individual-1 on
WhatsApp, stating, in substance and in part, that Victim-1 and another investor wanted to see
“actual account balances at the bank” to reassure them that their investments with LUSHER were
safe.

iii. On or about February 16, 2021, at approximately 10:09 a.m., the

LUSHER Email Address-2 emailed an employee of Signature Bank (“Signature Bank
Employee-1”), asking Signature Bank Employee-1, in substance and in part, to “please confirm
what the account balance is on Xtreme and Install Masters.” At approximately 10:26 a.m., i.e.,
approximately 17 minutes after LUSHER sent the email to Signature Bank Employee-1, a different
employee from Signature Bank (“Signature Bank Employee-2”) responded to the LUSHER Email
Address-2 (the “February 16 Email”). The body of the February 16 Email is reproduced below in
Image 1. The signature block in the February 16 Email contained, inter alia, Signature Bank
Employee-2’s work address, which was in Manhattan.

Image 1

iv. Based on conversations I have had with a representative from

Signature Bank, I have learned that both Signature Bank Employee-1 and Signature Bank
Employee-2 were employed at a Manhattan office address, and that the February 16 Email passed
through a server located in Manhattan.

v. On or about February 16, 2021, at approximately 1:03 p.m., i.e., less

than three hours after receiving the February 16 Email, LUSHER forwarded the February 16 Email
from the LUSHER Email Address-2 to Individual-1 at the Individual-1 Email Address (the
“Fraudulent Email”). The body of the Fraudulent Email said “[h]ere you go,” and included what
purported to be a forwarded copy of the February 16 Email, which contained account balances for
Xtreme HD, Inc., and Install Masters LLC. However, the account balances had been altered. More

specifically, as shown in Image 2, which is a portion of the Fraudulent Email, several digits had
been added to the front of the account balances reported by Signature Bank Employee-2. Instead
of “8,767.26,” the Fraudulent Email stated that Xtreme HD, Inc., had an account balance of
$1,228,767.26 (italics and bold added). And instead of “320.76,” the Fraudulent Email stated that
Install Masters LLC had an account balance of $987,320.76 (italics and bold added). In other
words, the Fraudulent Email indicated that the account balances for Xtreme HD, Inc., and Install
Masters LLC at Signature Bank were approximately 140 times (Xtreme HD, Inc.) and 3,078 times
(Install Masters LLC) greater than they actually were.

Image 2

vi. On or about February 16, 2021, at approximately 3:06 p.m., i.e.,

about two hours after receiving the Fraudulent Email from LUSHER, Individual-1 forwarded the
Fraudulent Email to Victim-1 at the Victim-1 Email Address. The altered account balances in the
February 16 Email had the effect of making Victim-1 feel that his investments with LUSHER’s
trucking business remained safe.

Victim-2

f. Victim-2 met LUSHER in or about 2019, when Victim-2 became

LUSHER’s boxing coach at a gym in or around Hamilton, New Jersey. LUSHER eventually hired
Victim-2 to provide boxing lessons to LUSHER and members of LUSHER’s family at LUSHER’s
home in New Jersey. At some point, LUSHER told Victim-2 that Victim-2 could invest in
LUSHER’s trucking business by paying LUSHER approximately $40,000, which would cover
expenses to get one delivery truck up and running.

g. On or about January 4, 2021, Victim-2 (through a company that, based on

conversations with Victim-2, I believe that Victim-2 partially controlled) entered into a written
investment agreement with Install Masters LLC, one of the LUSHER Companies. Under the terms
of that agreement, Victim-2 agreed to pay $45,000 to Install Masters LLC, and Install Masters
LLC agreed to pay $124,800 to Victim-2, in 104 weekly installments of $1,200, with the payments
to begin on or about February 10, 2021. In other words, LUSHER promised Victim-2 returns of
nearly 200 percent over two years. The agreement was guaranteed by Install Masters LLC and
was signed by Victim-2 on behalf of Victim-2’s company, and by LUSHER on behalf of Install
Masters LLC.

h. On or about January 5, 2021, an individual whom I know based on
conversations with Victim-2 to be Victim-2’s business partner wired $45,000 on behalf of
Victim-2’s company to a business bank account at Santander Bank used by LUSHER on behalf of
Install Masters LLC (the “Santander Install Masters Account”). Before that $45,000 transfer, the
Santander Install Masters Account had approximately $65 in it. Based on my review of records
provided by Santander Bank, I know that LUSHER opened the Santander Install Masters Account
on or about December 29, 2020, and provided, among other things, a business mailing address in
New Jersey that I believe to be LUSHER’s home address (the “LUSHER Home Address”).5

i. Based on my review of records provided by Santander Bank, I know that,

rather than using Victim-2’s $45,000 investment to buy a delivery truck (as promised), between
on or about January 5, 2021, and on or about January 8, 2021, i.e., in the three days after LUSHER
received Victim-2’s $45,000 investment, LUSHER moved approximately $44,905 of that $45,000
out of the Santander Install Masters Account in a series of transactions.

j. In several of those transactions, LUSHER appeared to wire or transfer

money from the Santander Install Masters Account to bank accounts of other entities that LUSHER
controlled. For example, on or about January 5, 2021, approximately $6,770 was wired (in two
separate transactions) from the Santander Install Masters Account to beneficiaries named “MS
PROF. INVESTMENT” and “MUCHKO M&A INC.,” both with a beneficiary address of the
LUSHER Home Address. On or about January 6, 2021, approximately $22,950 was transferred
(in two separate transfers) from the Santander Install Masters Account to a business bank account
at Santander Bank that I believe LUSHER used on behalf of Xtreme HD, Inc. (the “Santander
Xtreme HD Account”). Records from Santander Bank confirm that LUSHER opened the
Santander Xtreme HD Account on or about December 29, 2020, providing the LUSHER Home
Address as the account address.

k. In other transactions, LUSHER appeared to be paying down debts that he

owed. For example, on or about January 6, 2021, LUSHER cut an approximately $7,500 check
from the Santander Install Masters Account to a check cashing business (“Business-1”), which
LUSHER signed. Based on my participation in this investigation, my conversations with an
employee of Business-1 and my review of records provided by Business-1, I know that Business-1
is a check cashing business located in or around Hamilton, New Jersey, which is less than
approximately 20 miles from the LUSHER Home Address. Business-1 cashes checks for clients
but charges approximately a 2.2 percent fee on all checks that it cashes. LUSHER authorized
Business-1 to cash checks payable to (1) Xtreme HD, Inc., (2) Install Masters LLC, and (3)
“Mobile Testing Consultants, Inc.,” another company that I believe LUSHER controlled.6

5 I believe that the LUSHER Home Address is LUSHER’s home address for several reasons.
First, as described in the accompanying text, the LUSHER Home Address is the business address
that LUSHER used to open business bank accounts for several companies that LUSHER
controlled. Second, on or about January 21, 2018, LUSHER used the LUSHER Home Address to
open an online betting account with FanDuel. And third, on or about September 13, 2024, a law
enforcement officer drove by the LUSHER Home Address and saw an individual believed to be
LUSHER getting into a car in the driveway.
6 Based on records provided from Wells Fargo, I have learned that, on or about March 22,
2018, LUSHER opened a business checking account for Mobile Testing Consultants, Inc., at Wells

Between in or about 2015 and in or about 2020, LUSHER cashed more than approximately 200
checks at Business-1, totaling approximately more than $2 million. That check cashing activity
generated check fees to Business-1 of approximately more than $45,000. Records from Business-1
show that, as of on or about December 10, 2020, i.e., less than one month before LUSHER cut an
approximately $7,500 check to Business-1 from the Santander Install Masters Account, LUSHER
appears to have owed money to Business-1.

l. While Victim-2 ultimately received back from LUSHER all or nearly all of
Victim-2’s principal investment of $45,000, Victim-2 received none of the promised returns.

WHEREFORE, I respectfully request that a warrant be issued for the arrest of ARSEN
LUSHER, the defendant, and that he be arrested, and imprisoned or bailed, as the case may be.

______________________________
Deniele T. DeBoer
Special Agent, FBI

Sworn to me through the transmission of
this Complaint by reliable electronic means, pursuant to
Federal Rule of Criminal Procedure 4.1,
on this ___ day of October 2024.

___________________________________
THE HONORABLE SARAH L. CAVE
United States Magistrate Judge
Southern District of New York

Fargo, in which LUSHER identified himself as the owner with control of Mobile Testing
Consultants, Inc., and provided the LUSHER Home Address as both the business’s address and
LUSHER’s residential address.

/s Deniele T. DeBoer (By Court with Authorization)

18th

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