Case 0:25-mj-06212-PAB Document 1 Entered on FLSD Docket 04/08/2025 Page 1 of 9

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
SM
CASE NO. 25-mj-6212-PAB

UNITED STATES OF AMERICA Apr 8, 2025

v.
FTL

VITALII STEFURAC,

Defendant.
____________________________________/

CRIMINAL COVER SHEET

1. Did this matter originate from a matter pending in the Central Region of the United States
Attorney=s Office prior to October 3, 2019 (Mag. Judge Jared M. Strauss)? No.

2. Did this matter involve the participation of or consultation with Magistrate Judge Eduardo
I. Sanchez during his tenure at the U.S. Attorney’s Office, which concluded on January 22,
2023? No.

3. Did this matter involve the participation of or consultation with Magistrate Judge Marty
Fulgueira Elfenbein during her tenure at the U.S. Attorney’s Office, which concluded on
March 5, 2024? No.

4. Did this matter involve the participation of or consultation with Magistrate Judge Ellen F.
D’Angelo during her tenure at the U.S. Attorney’s Office, which concluded on October 7,
2024? No.

Respectfully submitted,

HAYDEN P. O’BYRNE
UNITED STATES ATTORNEY

By: /s/ Nicholas Y. Carré

Nicholas Y. Carré
Assistant United States Attorney
FL Bar No. 1022177
99 NE 4th Street
Miami, Florida 33132
Telephone: (305) 961-9189
Email: [email protected]
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SM

Apr 8, 2025

FTL
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AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

I, Gary M. Jones, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I am a Special Agent with the Federal Bureau of Investigation (FBI) and have been

since April 23, 2023. I am presently assigned to the Miami Division Complex Financial Crime

Squad, which investigates numerous criminal violations, including those relating to conspiracy to

defraud, wire fraud, attempt and conspiracy crimes, and money laundering. Prior to that, I served

in local law enforcement for approximately six (6) years where I engaged in a variety of criminal

investigations, including fraud investigations. I have experience and have received training in

investigations of various violations of federal law, including white-collar crime. I have

investigated and collected evidence of all types of crimes, including those perpetuated in-persons

and by cellular devices, telecommunication networks, computers, and information systems. I have

been involved in numerous investigations concerning complex financial matters and other fraud

schemes. All dates, amounts, and locations described in my affidavit are my approximation.

2. This affidavit is made in support of a criminal complaint charging Vitalii Stefurac

(“STEFURAC”) with conspiracy to commit wire fraud, in violation of Title 18, United States

Code, Section 1349.

3. The facts in this affidavit come from my personal observations, training, and

experience, as well as information obtained from other law enforcement personnel and witnesses.

Since this affidavit is being submitted for the limited purpose of obtaining criminal complaints, I

have not included each and every fact obtained during the investigation. This affidavit is only

intended to show merely that there is sufficient probable cause for the requested warrant and does

not show all the facts, circumstances, and knowledge of the matters at hand.
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OVERVIEW OF THE INVESTIGATION

4. Dream Auto Collection INC (“Dream Auto”) was a Florida Profit Corporation

located at 3837 Pembroke Road, Hollywood, Broward County, Florida and incorporated in

October 2020. STEFURAC and his co-conspirators utilized Dream Auto to facilitate their

fraudulent activities, primarily using the business to conduct “non-delivery schemes,” where a

victim believes they are purchasing an item, sends money via a wire from a financial institution to

the recipient financial institution, and never receives the item in return. This scheme described

below originated in the Southern District of Florida and caused one or more interstate wire

communications in interstate commerce.

FINANCIAL INSTITUTIONS

5. Dream Auto and STEFURAC used Bank 1, a Federal Deposit Insurance

Corporation (“FDIC”) member with a headquarters located in Pittsburgh, Pennsylvania, to receive

fraudulent wire payments in furtherance of the conspiracy. Based on my training and experience,

I know that Bank 1 is a “financial institution” as defined in Title 18, United States Code, Section

20.

6. As explained in more detail below, A.S. (“Victim”) sent two wires to Dream Auto

from his accounts located at Bank 2, a financial institution insured by the FDIC, that has a

headquarters registered to Honolulu, Hawaii, and Bank 3, a financial institution insured by the

National Credit Union Administration, that has a headquarters registered to Honolulu, Hawaii.

PROBABLE CAUSE

7. On or about April 8, 2024, Victim, a resident of the state of Hawaii, observed a

2023 Mercedes Benz G-63 (“Subject Vehicle”) outfitted with a customized Brabus package

(Vehicle Identification Number: W1NYC7HJ0PX461919) on Dream Auto’s website,

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dreamautocollection.com. 1 The Victim initially spoke on the phone with someone who identified

himself as “Viktor,” the owner of Dream Auto. The Victim told Viktor that he intended to purchase

the Subject Vehicle. The Victim further communicated with Viktor via text messages.

8. Based upon information and evidence gathered by law enforcement, the individual

named “Viktor” was later determined to be STEFURAC. 2

9. On or about April 10, 2024, the Victim and STEFURAC agreed on a purchase price

of $275,000 USD for the Subject Vehicle. STEFURAC, who continued to identify himself as

“Viktor,” texted the Victim the email address for Dream Auto, [email protected]

(“Subject Email Account”), to receive a copy of the Victim’s license. The Subject Email Account

was also used in Dream Auto’s filing paperwork with the Florida Division of Corporations.

10. On or about April 11, 2024, STEFURAC emailed the Victim from the Subject

Email Account with a bill of sale and wire transfer instructions to Dream Auto’s Bank 1 account.

According to bank records, on or about October 5, 2023, STEFURAC opened the Bank 1 account

in Dream Auto’s name and listed himself as Dream Auto’s President.

11. On or about April 12, 2024, the Victim wired $145,000 from his Bank 2 account to

Dream Auto’s Bank 1 account. The Victim later wired the remaining $130,000 from his Bank 3

account to Dream Auto’s Bank 1 account, thereby completing the Victim’s financial responsibility

for the sale of the Subject Vehicle.

1
Brabus GmbH (“Brabus”) is a limited liability company duly organized and existing under the laws of Germany with
its principal place of business at Bottrop, Germany. Brabus is an automobile tuning company that enhances, modifies
and configures a vehicle (to include the exterior, interior and/or engine) to provide an enhanced appearance and
performance when compared to the conventional specification for the vehicle. Brabus’ automobile tuning can add to
the value of an automobile.
2
According to AT&T records, the phone number Viktor used to communicate with the Victim via text message is
registered to STEFURAC. Moreover, Dream Auto’s Florida Division of Corporation filing records listed this phone
number as STEFURAC’s phone number. STEFURAC was, and remains, the president and registered agent of Dream
Auto. STEFURAC was also the sole account holder, listed president, and signatory to Dream Auto’s BANK 1 account
at the time the account was created and throughout the conspiracy. STEFURAC is also identified in images sent to
the Victim via text message.

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12. According to bank records, Dream Auto’s Bank 1 account received both wires,

totaling $275,000, from the Victim’s Bank 2 and Bank 3 accounts. On or about April 17, 2024, the

Victim asked STEFURAC via text message if STEFURAC had received the wires. STEFURAC

replied yes and explained that he was outside of the United States.

13. On or about April 29, 2024, STEFURAC told the Victim via text message that he

returned to the United States and would arrange shipping for the Subject Vehicle. On or about May

1, 2024, STEFURAC explained to the Victim via text message that he booked a transport company

to ship the Subject Vehicle to California, where the Subject Vehicle would then be transported to

Hawaii by a carrier of the Victim’s choosing. STEFURAC also indicated that the Subject Vehicle

could be picked up on May 2, 2024, and then sent the Victim an image of a certificate of liability

insurance, listing the transport company and insurance policy information.

14. On or about May 2, 2024, while Dream Auto and the Victim coordinated

transportation of the Subject Vehicle to the Victim, Dream Auto sold the Subject Vehicle to K.R.,

an individual residing in Illinois. Documents from the state of Illinois show that the Subject

Vehicle was titled and registered to K.R. The Victim was unaware of the sale and the sale was not

disclosed to the Victim until a later date.

15. On or about May 10, 2024, STEFURAC told the Victim via text message that

STEFURAC would call his partner for updates. On or about May 16, 2024, the Victim sent a text

message to STEFURAC asking for an update. STEFURAC told the Victim that his partner was

waiting for the title. Over the next few weeks, STEFURAC told the Victim that the deadline for

shipping the Subject Vehicle to the Victim would need to be pushed back.

16. On or about May 22, 2024, STEFURAC sent the Victim a text message, explaining

that STEFURAC was in Europe and that his “partner” would respond to the Victim by the

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following morning. On or about May 23, 2024, the Victim received an email from the Subject

Email Account, signed by a man named Alex, explaining that Viktor was away in Eastern Europe

and that the “ETA” for picking up the Subject Vehicle was May 28 or 29, 2024, with an “ETA

arrival to San Diego May 2-3.” The email also stated, “I will forward you title copy and transporter

info after car picked up. We still processing CA title to flip it to FL, takes about 2-3 weeks

usually.” 3

17. The Victim spoke with the transport company and learned that the Subject Vehicle

never arrived in California. The Victim tried contacting STEFURAC and Dream Auto, but did not

receive a response.

18. After a local news station published a news segment regarding Dream Auto,

STEFURAC sent the Victim a text message stating, “we working hard to refund your money

back.” As of the date of this affidavit, the Victim has not been refunded his money.

19. On or about April 7, 2025, STEFURAC was scheduled as a passenger on American

Airlines flight number 2699, departing from Miami, Florida, to Havana, Cuba. STEFURAC was

encountered by law enforcement at Miami International Airport and taken into custody.

[THIS SECTION LEFT INTENTIONALLY BLANK]

3
Typographical and scrivener’s errors included in the original text.

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