AO 91 (Rev.

11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

for the
Middle District of Tennessee

United States of America

V.

AMY BRESCIA
KAYLA SAYEGH
Case No.
19 - M J- 4 2 8 9

Defendant(s)

CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of 5/5/19 through 8/17/19 in the county of Davidson in the
Middle District of Tennessee , the defendant(s) violated:

Code Section Offense Description

Title 18 U.S.C. 1344 and 2; Bank Fraud in violation of 18 U.S.C. 1344 and 2; Aggravated Identity Theft in
Title 18 U.S.C. 1028(A)(a)(1) and 2; violation of 18 U.S.C. 1028(A)(a)(1) and 2; Conspiracy to Commit Bank Fraud
Title 18 U.S.C. 1349 in Violation of 18 U.S.C. 1349.

This criminal complaint is based on these facts:

Please see the attached statement in support of criminal complaint.

9( Continued on the attached sheet.

Complainant's i Zatu

FBI S/A Stephen T. Fogarty

Printed name and title

Sworn to before me and signed in my presence.

Date 08/30/2019
Judge's signature

City and state: NASHVILLE, TN Alistair Newbern, United States Magistrate Judge
Printed name and title

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 AFFIDAVIT OF FBI SPECIAL AGENT STEPHEN FOGARTY IN SUPPORT OF A

CRIMINAL COMPLAINT AND ARREST WARRANT

INTRODUCTION

I, Stephen Fogarty, hereinafter being duly sworn, depose and say:

I am a Special Agent (SA) of the Federal Bureau of Investigation (FBI) assigned to the

FBI Memphis Division, Nashville Resident Agency. I have been employed as a Special Agent

for approximately 21 years and my current assignment includes the investigation of white collar

criminal offenses including identity theft and fraud related matters. I have investigated

organized fraud groups for approximately 7 years including Felony Lane Gang (FLG) crews.

I make this affidavit in support of an application for an arrest warrant for AMY

BRESICA and KAYLA SAYEGH. The information contained in this affidavit is based on my

personal knowledge and observations during the course of this investigation including reviewing

written reports, surveillance photographs, social media postings and having numerous

conversations with other law enforcement officers and civilians.

Except where otherwise noted, the information set forth in this affidavit has been

provided to me directly or indirectly by Special Agents of the FBI or other law enforcement

officers. Unless otherwise noted, wherever I state that a statement was made, the information

was provided by a law enforcement officer or confidential source of information (who may have

had either direct or hearsay knowledge of the statement) with whom I have spoken or whose

report I have read. All statements related herein, whether of law enforcement officers or others,

are related in substance and in part, unless otherwise indicated. Information resulting from

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surveillance sets forth either my personal observations or information provided directly or

indirectly through other law enforcement officers who conducted such surveillance.

This affidavit is being submitted for the limited purpose of establishing probable cause in

obtaining an arrest warrant. Therefore, I have not set forth each and every fact that I have

learned during the course of this investigation, but just those sufficient to establish probable

cause to believe that AMY BRESCIA and KAYLA SAYEGH engaged in bank fraud, conspiracy

to commit bank fraud and aggravated identity theft, in violation of Title 18 U.S.C. Sections 2,

1344, 1349 and 1028A.

SCHEME

This investigation involves a criminal scheme commonly referred to as the "Felony Lane

Gang" hereafter referred to as FLG. FLG crews are normally based in the Fort Lauderdale,

Florida area and they travel the country committing their crimes utilizing rental vehicles. FLG

crews normally consist of several male members and at least one female member. FLG suspects

target locations such as gyms, parks, daycare centers and sporting events frequented by women

who are likely to leave their purses in their vehicles at these locations. The suspects conduct

surveillance at these locations and unlawfully enter victim vehicles through unlocked doors, or

by using force to break the window of a locked victim vehicle. Having accomplished a car

break-in, the suspects then focus on purses or pocket books and specifically look for

identification such as driver licenses, social security cards, debit cards and credit cards.

Additionally, suspects look for checks to further the bank fraud scheme. The males typically

commit the auto burglaries and the female(s) then typically commit the bank fraud transactions,

as most victims in this scheme are female. Female crew members then assume the identities of

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the theft victims and use identification taken from the above described auto burglaries in order to

cash stolen checks belonging to other victims. FLG crews will normally supply the illegal

check cashers with wigs in order to create a physical appearance similar to that of the victims

whose identification was stolen. The check cashers normally use the farthest open drive thru

lane from the bank building to conduct the fraudulent transactions. Hence, this lane became

known as the "felony lane", it is from this nickname that the group's name was derived. The

suspects normally conceal the identity of the vehicles used during the banking transactions

(which are often rental vehicles) by placing a stolen license plate over the original license plate

assigned to the (rental) vehicle. When these crews travel through an area, they normally stay

overnight at motels near the interstate for easy access to locations.

INVESTIGATION

On May 5, 2019, Lenexa, Kansas police officers encountered KAYLA SAYEGH and

AMY BRESCIA at a Motel 6 in Lenexa, Kansas. SAYEGH and BRESCIA were associated

with a rental vehicle in the motel parking lot. Further investigation revealed that SAYEGH and

BRESCIA were travelling with several males who provided addresses in the Fort Lauderdale

area. As a result of field interviews, the police learned that one of the males was wanted on

fraud charges in Florida and that male was arrested. The police contacts with SAYEGH,

BRESCIA and the males were captured on the officers' body cameras. The Lenexa Police

Department subsequently issued an email to other law enforcement officers and agencies

regarding the above contact as the police believed they may have encountered a FLG crew.

On or about June 6 through June 8, 2019, two white females operating a blue Ford Edge

conducted numerous fraudulent bank drive thru transactions at Regions Bank branches in the

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Nashville, Tennessee area while impersonating an auto burglary victim (C.M.) and using that

victim's identification to negotiate stolen checks from another victim (B.W.) against C.M.'s

account to withdraw funds from C.M.'s account. Regions Bank notified area law enforcement

agencies of the activity and provided bank surveillance photographs of the two female suspects.

Regions Bank is a federally insured financial institution.

On June 11, 2019, Edmond, Oklahoma police officers responded to a fraud in progress

call at a local bank in Edmond, Oklahoma where two female suspects were attempting to

impersonate a bank customer with the customer's stolen identification to withdraw funds from

that customer's account by negotiating stolen check from another auto burglary victim. The

police responded very quickly, but the suspects had left the bank. The bank did not have

surveillance cameras at the drive thru location.

On June 26, 2019, a business owner in Edmond, Oklahoma contacted the Edmond

Police Department about an abandoned vehicle that had been parked at his business

approximately two weeks. The police responded and located a blue Ford Edge with a temporary

license plate. This is the same type of vehicle used in the fraudulent banking transactions with

the two female suspects in Nashville between June 6 and June 8, 2019. Additionally, it matched

the description of the suspect vehicle in the attempted bank fraud in Edmond on June 11, 2019.

The vehicle was abandoned approximately 11 blocks from the bank. The Edmond Police

subsequently searched the vehicle and located numerous wigs, the stolen identification used in

the fraudulent banking transaction on June 11, 2019 in Edmond and personal items associated

with KAYLA SAYEGH and AMY BRESCIA. Officers contacted the rental car company and

determined that the Ford Edge was rented to KAYLA SAYEGH in Nashville, Tennessee on June

11

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5, 2019.

The police in Edmond, Oklahoma created two photo line-ups, one with SAYEGH's

photograph and one with BRESCIA's photograph. The teller that handled the June 11, 2019

transaction identified BRESCIA as the female suspect driver in the drive thru transaction. The

same teller identified another female from the lineup containing SAYEGH's photograph.

On July 18, 2019, two white females driving a dark colored Jeep attempted a

fraudulent banking transaction at a bank in the Knoxville, Tennessee area. The females

attempted to impersonate a bank customer using the customer's stolen identification taken in a

previous auto burglary. The females attempted to negotiate a stolen check taken from another

victim in another auto burglary. The female suspect driving the suspect vehicle had a very

distinctive tattoo on her left arm. The word "LOVE" was spelled using a handgun as the letter

L, a grenade as the letter O, two bullets as the letter V, and a rifle as the letter E.

On July 19, 2019, the same two females driving the dark colored Jeep attempted another

fraudulent banking transaction at a bank drive thru in Hendersonville, Tennessee. This

transaction involved a Knoxville victim's stolen identification taken in an auto burglary in

Knoxville. On July 22 and July 23, 2019, the same two females conducted numerous fraudulent

banking transactions in the Nashville, Tennessee area at First Tennessee Bank branches by

impersonating account holders using the account holder's stolen identification.

On July 24, 2019 at approximately 7:45 a.m., T.N. stopped at a daycare in Franklin,

Tennessee to drop off her child. When she returned to her vehicle, she observed her front

passenger window had been broken and her purse was missing. T.N. contacted the Franklin

Police Department to file an incident report.

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 On August 14, 2019, A.H. parked her vehicle at a school in Hendersonville, Tennessee

to attend a youth sports game. When A.H returned to her vehicle, a vehicle window was broken

and her purse was missing.

Between August 15, 2019 and August 17, 2019, two females operating a silver

Mitsubishi SUV withdrew approximately $17, 920.00 from T.N.'s First Tennessee Bank (FTB)

account by impersonating T.N. using T.N.'s stolen identification obtained from the earlier auto

burglary at the daycare location. The two female suspects negotiated A.H.'s stolen checks

against T.N.'s FTB account to obtain the funds. A.H.'s stolen checks were taken during the

earlier auto burglary of A.H.'s vehicle in Hendersonville. These fraudulent banking transactions

occurred at FTB branches located at 7082 Bakers Bridge Road, Franklin, Tennessee, 1214

Murfreesboro Road, Franklin, Tennessee, 3038 Columbia Avenue, Franklin, Tennessee, 2200

Hillsboro Road, Franklin, Tennessee, 231 Public Square, Franklin, Tennessee, 330 Mayfield

Drive, Franklin, Tennessee, 154 Cason Lane, Murfreesboro, Tennessee, 808 South Church

Street, Murfreesboro, Tennessee, 305 West Northfield Blvd., Murfreesboro, Tennessee, 471 Sam

Ridley Blvd. West, Smyrna, Tennessee. First Tennessee Bank is a federally insured financial

institution.

Further investigation revealed that KAYLA SAYEGH was registered as a guest at the

Comfort Inn and Suites in Antioch, Tennessee this year on June 4, July 18 through July 21,

August 14 and August 16. SAYEGH used her Pennsylvania Driver's License as identification

to register at the hotel. Hotel surveillance video has images of SAYEGH and BRESCIA at the

hotel. Additionally, the hotel surveillance footage associated SAYEGH and BRESCIA with a

silver SUV in the parking lot of the hotel. Hotel surveillance footage captures the unique

rel

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"LOVE" tattoo on SAYEGH's left arm. This tattoo is the same tattoo seen in the body camera

video in Kansas and the bank surveillance photograph from the Knoxville area.

During the course of this investigation, I reviewed bank surveillance photographs

provided by the financial institutions and other law enforcement agencies regarding the two

female suspects. I located and reviewed Facebook pages associated with BRESCIA and

SAYEGH that posted numerous photographs of both women. The social media postings

indicate that BRESCIA and SAYEGH know each other well. Additionally, I reviewed the body

camera footage from Lenexa, Kansas. After reviewing the photographs and video, I submit that

there is more than sufficient probable cause to believe that BRESCIA and SAYEGH are the two

women depicted in bank surveillance photographs committing bank fraud and aggravated

identity theft in the Nashville area on or around June 6 through June 8, 2019, July 19, 2019, July

22 through July 23, 2019 and August 15 through August 17, 2019.

CONCLUSION

Based upon the facts stated above, I believe there is probable cause that from on or about

August 15 to August 17, 2019 in the Middle District of Tennessee, AMY BRESCIA and KAYLA

SAYEGH and others unknown, did knowingly execute, or attempt to execute, a scheme or artifice

to defraud a financial institution by unlawfully obtaining cash under the care, custody and control

of First Tennessee Bank in violation of Title 18, United States Code 1344 and 2. Furthermore, I

believe there is probable cause to believe that from August 15, 2019 to August 17, 2019, in the

Middle District of Tennessee, AMY BRESCIA and KAYLA SAYEGH, did commit aggravated

identity theft by knowingly possessing, transferring, using and causing to be possessed, transferred

and used, without lawful authority, the means of identification of another person in relation to bank

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fraud in violation of 18 USC Title 1028A(a)1 and 2.

Additionally, I believe there is probable cause to believe that from May 5, 2019 through

August 17, 2019, AMY BRESCIA and KAYLA SAYEGH and others conspired to commit bank

fraud in the Middle District of Tennessee and elsewhere in violation of 18 U.S.C. Title 1349.

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