Case 2:21-mj-00172-MAT Document 1 Filed 03/26/21 Page 1 of 9

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7 UNITED STATES DISTRICT COURT FOR THE
8 WESTERN DISTRICT OF WASHINGTON
AT SEATTLE
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UNITED STATES OF AMERICA, CASE NO. MJ21-172
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Plaintiff,
COMPLAINT FOR VIOLATION
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13 Title 42, United States Code, Section
v.
408(a)(7)(B) (Social Security Number Misuse)
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ALIEU DRAMMEH,
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Defendant.
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19 BEFORE the Honorable Mary Alice Theiler, United States Magistrate Judge, U.S.
20 Courthouse, Seattle, Washington.
21 The undersigned complainant being duly sworn states:
22 COUNT 1
23 Social Security Number Misuse
24 On or about March 22, 2017, within the Western District of Washington, ALIEU
25 DRAMMEH, with intent to deceive, falsely represented a number to be the Social Security
26 account number assigned by the Commissioner of Social Security to him, when in fact such
27 number is not the Social Security account number assigned by the Commissioner of Social
28 Security to him, to wit: ALIEU DRAMMEH used the name, date of birth, and Social

COMPLAINT/DRAMMEH - 1 UNITED STATES ATTORNEY

700 STEWART ST, SUITE 5220
SEATTLE, WA 98101
(206) 553-7970
 Case 2:21-mj-00172-MAT Document 1 Filed 03/26/21 Page 2 of 9

1 Security account number belonging to A.K., a real person, on a background check

2 authorization form that was submitted to the Washington State Department of Social and
3 Health Services.
4 All in violation of Title 42, United States Code, Section 408(a)(7)(B) and Title 18,
5 United States Code, Section 2.
6 INTRODUCTION
7 1. I am a Special Agent with the Social Security Administration, Office of the
8 Inspector General (“SSA-OIG”), assigned to the Seattle, Washington Field Office, and have
9 been so since 2014. I am a graduate of the Criminal Investigator Training Program and
10 Inspector General Investigator Training Program at the Federal Law Enforcement Training
11 Center and have received regular training in the enforcement of laws of the United States,
12 including the preparation, presentation, and execution of criminal complaints, arrests, and
13 search warrants. As a SSA-OIG Special Agent, my duties include investigating fraud, waste,
14 and abuse related to the Social Security Administration (“SSA”) and its programs. During
15 my tenure as a Special Agent, I have conducted numerous investigations of criminal activity
16 including identity theft, government benefits fraud, mail theft, bank fraud, wire fraud, and
17 other related crimes.
18 2. As set forth in this affidavit, there is substantial evidence supporting probable
19 cause to believe that ALIEU DRAMMEH committed the felony violation of Social Security
20 Number Misuse in violation of Title 42, United States Code, Section 408(a)(7)(B) within the
21 Western District of Washington and within the last five years. As such, I am seeking a
22 warrant for the arrest of ALIEU DRAMMEH for the above crime.
23 3. The information contained in this affidavit is based on my own personal
24 knowledge and observations, as well as information conveyed to me by other law
25 enforcement officers; my review of documents and records related to this investigation; and
26 information gained through my training and experience. Because this affidavit is submitted
27 for the limited purpose of establishing probable cause, it does not set forth every fact that I,
28 or others, have learned during the course of this investigation.

COMPLAINT/DRAMMEH - 2 UNITED STATES ATTORNEY

700 STEWART ST, SUITE 5220
SEATTLE, WA 98101
(206) 553-7970
 Case 2:21-mj-00172-MAT Document 1 Filed 03/26/21 Page 3 of 9

1 STATEMENT OF FACTS SUPPORTING PROBABLE CAUSE

2 4. The SSA-OIG, United States Department of Health and Human Services
3 Office of Inspector General, and the Federal Bureau of Investigation are investigating
4 ALIEU DRAMMEH (“DRAMMEH”) for identity theft and other federal criminal offenses
5 related to his unlawful use of the identity of A.K., which belongs to another real individual.
6 5. On or about October 4, 2019, the SSA Field Office in Seattle, Washington
7 received a letter from an individual whose company oversees management of Washington
8 Care Services (“WCS”), a skilled nursing care facility located in Seattle, Washington with
9 approximately 40 licensed nurses and up to 165 residents. In the letter, it was alleged that
10 DRAMMEH worked at WCS since at least 2013 under the false name A.K. and that he used
11 a false Social Security number (“SSN”) while serving as the Director of Nursing Services.
12 Additionally, it was alleged that DRAMMEH worked at the WCS facility without a valid
13 nursing license, as his own licenses were previously revoked in Oregon and Washington.
14 Following receipt of this letter, a federal criminal investigation was initiated.
15 6. According to a WCS Administrator, on or about September 18, 2019,
16 DRAMMEH left a signed resignation letter on the WCS Administrator’s desk which stated
17 in part: “The main reason, I am leaving is that I have used another person’s, identity to work
18 here. [sic] We have the same [first] name. The reason why I could not use my name is
19 because of the disciplinary action taken against my nursing license. I have tried many times
20 and wasted substantial amount of money in legal fees to remove the hold on my license but it
21 is still revoked. . . . Please share . . . my apologies for my misconduct of taking someone
22 else’s identity to practice nursing.”
23 7. After receiving DRAMMEH’s resignation letter, WCS personnel initiated an
24 internal investigation and later discovered the individual who they knew as A.K. was an
25 imposter who they identified as DRAMMEH. A review of DRAMMEH’s nursing license in
26 Washington showed it had been revoked. WCS senior management advised there is no
27 indication that DRAMMEH provided substandard care in his role at WCS, despite his
28 revoked nursing license.

COMPLAINT/DRAMMEH - 3 UNITED STATES ATTORNEY

700 STEWART ST, SUITE 5220
SEATTLE, WA 98101
(206) 553-7970
 Case 2:21-mj-00172-MAT Document 1 Filed 03/26/21 Page 4 of 9

1 8. I have reviewed records provided by the Oregon State Nursing Board (“OR
2 Nursing Board”) and the Washington State Department of Health’s Nursing Care Quality
3 Assurance Commission (“WA Nursing Commission”), which revealed the following:
4 a. In 2007, DRAMMEH became a licensed Registered Nurse (“RN”) in Oregon
and Washington.
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6 b. In 2010, the OR Nursing Board discovered a discrepancy in DRAMMEH’s RN
license paperwork and later determined through an administrative investigation
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that DRAMMEH had forged the signature of his clinical preceptor.
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c. In 2011, due to the findings of the OR Nursing Board’s investigation,
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DRAMMEH’s Oregon RN license was revoked and his Washington RN
10 license was suspended.
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d. In March 2012, DRAMMEH’s employer, ManorCare Health Services in
12 Lynnwood, Washington, discovered during a routine license check that his
Washington RN license was suspended and that DRAMMEH had nonetheless
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continued to practice nursing. As a result, DRAMMEH was terminated.
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e. In March 2012, approximately two weeks after this termination, DRAMMEH
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applied to work as a nurse at Everett Transitional Care Services using A.K.’s
16 identity. During the application process, the potential employer discovered the
identity fraud and did not hire him. DRAMMEH later provided a written
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statement in April 2012 to the WA Nursing Commission in which he admitted
18 he “stole the ID of my friend and attempted to seek a job at Transitional Care
because they wanted to hire me.”
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20 f. In or around May 2012, DRAMMEH began working as a nurse under his real
identity at Advocate Nursing Services in Washington, despite the suspension
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of his Washington RN license.
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g. In September 2012, the WA Nursing Commission revoked DRAMMEH’s
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Washington RN license due to the forgery in his Oregon RN license paperwork
24 and his practice of nursing while his Washington RN license was suspended.
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h. In approximately March 2017, DRAMMEH submitted an application to the
26 OR Nursing Board to reinstate his Oregon RN license. During a subsequent
interview with an OR Nursing Board investigator, DRAMMEH admitted that
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he had worked in Washington under a suspended Washington RN license and
28 that he had applied for a nursing position using A.K.’s identity without A.K.’s

COMPLAINT/DRAMMEH - 4 UNITED STATES ATTORNEY

700 STEWART ST, SUITE 5220
SEATTLE, WA 98101
(206) 553-7970
 Case 2:21-mj-00172-MAT Document 1 Filed 03/26/21 Page 5 of 9

1 permission. DRAMMEH stated that he became acquainted with A.K. because

they attended the same community college, and explained that they had each
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other’s personal information. DRAMMEH told the investigator that he has a
3 passion for nursing and that he had not practiced nursing for the last five years
(even though it appears that he was working under A.K.’s identity at WCS at
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the time).
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9. According to SSA and United States (“US”) Citizenship Immigration Services
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records:
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a. DRAMMEH was born in The Gambia in 1976 and traveled to the US in
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2000 on a student visa. In 2000, DRAMMEH legally applied for a SSN and
9 was assigned SSN XXX-XX-3894 with authorization to work.
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b. A.K. was born in The Gambia in 1974 and traveled to the US in 1995 on a
11 student visa. In 1995, A.K. legally applied for a SSN and was assigned SSN
XXX-XX-5093 with authorization to work. A.K. became a US citizen in
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2013.
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10. During separate interviews with federal agents on November 7, 2019, the WCS
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Administrator and another WCS senior manager were shown a photograph of DRAMMEH.
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Both individuals positively identified DRAMMEH as the person who they knew as A.K. and
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who served as the WCS Director of Nursing Services up until his resignation. According to
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the WCS Administrator, WCS personnel were previously unaware that DRAMMEH was
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working at WCS under a false identity and his resignation came as a surprise.
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11. WCS voluntarily provided employment records related to DRAMMEH (posing
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as A.K.) to assist with this investigation. I have reviewed these records, which revealed the
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following:
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a. First Application for Employment: A handwritten application for a nurse
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position containing A.K.’s true name and SSN was signed on March 13,
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b. Form I-9: A handwritten employment eligibility verification form
26 containing A.K.’s true name, date of birth, SSN, and Washington state
driver’s license number was signed on March 22, 2013. Additionally, a
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scanned image of a supporting identity document shows handwritten
28 alterations were made to a Social Security card to reflect A.K.’s true name

COMPLAINT/DRAMMEH - 5 UNITED STATES ATTORNEY

700 STEWART ST, SUITE 5220
SEATTLE, WA 98101
(206) 553-7970
 Case 2:21-mj-00172-MAT Document 1 Filed 03/26/21 Page 6 of 9

1 and SSN.
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c. Second Application for Employment: A handwritten application for the
3 Director of Nursing Services position containing A.K.’s true name and SSN
was signed on September 24, 2015.
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5 d. Form W-2: Wage and tax statements for tax years 2014-2018 list A.K.’s
true name and SSN.
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7 e. Background Checks: Background Check Authorization forms were
completed on March 13, 2013; March 4, 2015; March 22, 2017; and April
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19, 2019. Each form lists A.K.’s true name, date of birth, and SSN (except
9 for the March 4, 2015 form, in which the SSN field was left blank). The
authorization form dated March 22, 2017 was handwritten and signed.
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WCS submitted these forms to the Washington Department of Social and
11 Health Services for screening purposes.
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f. All of the WCS records described above listed the following address for the
13 employee: 1208 117th Pl SW, Everett, WA 98204.
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12. According to Washington State Department of Licensing records, DRAMMEH
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obtained a driver’s license in 2006 using his true name, date of birth, and SSN. Beginning in
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2011 and continuing through at least April 2016 (the most recent license issued),
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DRAMMEH reported his address as 1208 117th Pl SW, Everett, WA 98204, which matches
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the address provided for A.K. in WCS employment records.
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13. On November 20, 2019, federal agents interviewed A.K. at his Washington
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residence. According to A.K., he is employed as a RN at a large medical center in the
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Seattle, Washington area, where he has worked for over 13 years. A.K. first met
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DRAMMEH in approximately 2001-2003, when they both took prerequisite courses for
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nursing school at a local community college. A.K. stated he and DRAMMEH are originally
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from The Gambia, but they did not know each other prior to meeting in college. A.K. added
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that he does not consider DRAMMEH to be a friend and reported they have had limited
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contact over the years. A.K. reviewed DRAMMEH’s most recent Washington state driver’s
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COMPLAINT/DRAMMEH - 6 UNITED STATES ATTORNEY

700 STEWART ST, SUITE 5220
SEATTLE, WA 98101
(206) 553-7970
 Case 2:21-mj-00172-MAT Document 1 Filed 03/26/21 Page 7 of 9

1 license photo and confirmed that the individual depicted is the person A.K. knows as
2 DRAMMEH.
3 14. A.K. first discovered he was a victim of identity theft in 2017, when he
4 received a tax debt letter from the Internal Revenue Service (“IRS”) informing him that he
5 had underreported his income since approximately tax years 2012/2013. A.K. stated the IRS
6 letter referenced multiple nursing homes, including WCS, as one of his reported employers.
7 A.K. stated he has never worked at WCS or any other nursing home.
8 15. When A.K. discovered someone had been working under his identity, he began
9 to suspect that DRAMMEH had stolen his identity because, aside from employers or
10 government agencies, A.K. has only ever disclosed his SSN to one individual: DRAMMEH,
11 who A.K. was aware had worked as a nurse. A.K. explained that DRAMMEH was working
12 as a life insurance salesperson in approximately 2009, and that they met around this time to
13 discuss A.K.’s potential purchase of life insurance. During their meeting, A.K. provided
14 DRAMMEH with his SSN and Washington state driver’s license number in order to
15 purchase the insurance. DRAMMEH never followed up with A.K. regarding his intended
16 purchase, and A.K. did not think much of their meeting until he learned of the identity theft.
17 16. A.K. subsequently arranged a meeting at a local coffee shop with DRAMMEH
18 in 2017 and confronted DRAMMEH about his suspicions. According to A.K., DRAMMEH
19 admitted to using A.K.’s identity to work and was very apologetic during their meeting.
20 DRAMMEH also agreed to repay A.K. for the IRS debt incurred and provided A.K. with a
21 cashier’s check payable to the IRS in the amount of approximately $11,000. A.K. then sent
22 this cashier’s check to the IRS to repay part of his tax debt, which he estimated to be $17,000
23 in total. A.K. explained that he now regrets not contacting law enforcement authorities at the
24 time to pursue the issue further. A.K. acknowledged that DRAMMEH’s conduct has likely
25 cost him several thousands of dollars due to tax refunds that were withheld to pay off the IRS
26 tax debt.
27 17. In September 2019, a Washington Department of Health investigator contacted
28 A.K. regarding his alleged involvement in a theft of cash from a WCS resident. Through that

COMPLAINT/DRAMMEH - 7 UNITED STATES ATTORNEY

700 STEWART ST, SUITE 5220
SEATTLE, WA 98101
(206) 553-7970
 Case 2:21-mj-00172-MAT Document 1 Filed 03/26/21 Page 8 of 9

1 contact, A.K. discovered that DRAMMEH had apparently continued to use A.K.’s identity to
2 work even after their 2017 meeting. A.K. then contacted DRAMMEH and they met at a local
3 coffee shop later that month. According to A.K., DRAMMEH admitted during this meeting
4 that he had continued to use A.K.’s identity to work and promised A.K. that he would stop
5 doing so.
6 18. A.K. stated that he routinely checks his credit report and has not discovered
7 any suspicious credit activity that would indicate DRAMMEH has opened up lines of credit
8 in his identity.
9 19. A.K. confirmed the SSN assigned to him is XXX-XX-5093. A.K. stated he
10 never consented to, nor had any knowledge of or involvement in, DRAMMEH’s use of his
11 identity to work at WCS or other places of employment.
12 20. I have also reviewed a recorded telephone conversation that took place
13 between A.K. and DRAMMEH on January 11, 2020. During that call, DRAMMEH
14 implicitly acknowledged having used A.K.’s identity without his permission by repeatedly
15 apologizing and stating “there’s really no good reason” why DRAMMEH had done so.
16 Additionally, in the context of discussing DRAMMEH’s prior employment under A.K.’s
17 identity at an unidentified nursing facility, DRAMMEH stated, “I did not have any of your
18 [A.K.’s] papers; I just remembered maybe your Social Security number.”
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COMPLAINT/DRAMMEH - 8 UNITED STATES ATTORNEY

700 STEWART ST, SUITE 5220
SEATTLE, WA 98101
(206) 553-7970
 Case 2:21-mj-00172-MAT Document 1 Filed 03/26/21 Page 9 of 9

1 Based on the foregoing facts, I believe probable cause exists that ALIEU
2 DRAMMEH committed the felony violation of SSN Misuse in violation of Title 42, United
3 States Code, Section 408(a)(7)(B).
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5 ____________________________
SCOTT JONES, Complainant
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Special Agent
7 Social Security Administration
Office of the Inspector General
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Based on the Complaint and affidavit sworn before me, and subscribed in my
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11 presence, the Court hereby finds that there is probable cause to believe that the Defendant
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committed the offenses set forth in the Complaint.
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26th
DATED this _____ day of March, 2021.
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____________________________
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THE HONORABLE MARY ALICE THEILER
17 United States Magistrate Judge
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COMPLAINT/DRAMMEH - 9 UNITED STATES ATTORNEY

700 STEWART ST, SUITE 5220
SEATTLE, WA 98101
(206) 553-7970