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UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF VIRGINIA
CHARLOTTESVILLE DIVISION

UNITED STATES OF AMERICA

Case No. ____________________
3:21-mj-21
v.

CHRISTINE FAVARA ANDERSON

AFFIDAVIT IN SUPPORT OF COMPLAINT

I, Special Agent Jane Collins, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I am submitting this affidavit in support of a criminal complaint and a warrant for

the arrest of Christine Favara Anderson (ANDERSON).

2. I am a Special (SA) of the Federal Bureau of Investigation and have been so

employed for thirty (30) years. I am currently assigned to the Richmond Division, Charlottesville

Resident Agency. As a Special Agent for the FBI, I am currently assigned to investigations of

criminal matters including the one set hereinafter.

3. As set forth in this affidavit, there is probable cause to believe that there have been

violations of mail fraud in violation of 18 U.S.C.§ 1341 and wire fraud in violation of 18 U.S.C.

§ 1343 committed by ANDERSON in the Western District of Virginia and elsewhere. This

affidavit is based upon my personal knowledge, publicly available records, my review of

documents and other evidence, my conversations with other law enforcement personnel, and my

training and experience.

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4. This affidavit is intended to show only that there is sufficient probable cause for the

requested warrant and does not set forth all of my knowledge about this matter.

PROBABLE CAUSE

A. Summary of Scheme

5. Christine Favara Anderson (hereinafter “ANDERSON”) currently resides at the

1937 Ridgeview Road, Reva, Virginia 22735, within Madison County and the Western District of

Virginia. As set forth below, probable cause exists to believe that ANDERSON is the perpetrator

of various fraudulent schemes, to include book publishing and real estate schemes, using the wires

and mail in interstate commerce.

6. Based on the below, ANDERSON stole money from book authors by promising to

be their book publisher, requiring money from the authors up front, and failing to pay the authors

their royalties as owed. As mentioned below, ANDERSON often used a false cancer diagnosis to

delay payment to the book authors, while also purporting to maintain vast wealth. I believe her

book publishing scheme started after 2013, when ANDERSON published a memoir about having

bipolar disorder, which is currently available for sale on Amazon, entitled “Forever Different: A

Memoir of One Woman’s Journey Living with Bipolar Disorder.” I believe the victims of this

book publishing scheme include, but are not limited to, M.M., J.T., S.W., F.G., P.Y., B.C., K.G.,

and D.B.

7. Based on the below, ANDERSON also misrepresented her wealth through

fraudulent proof of funds notes and false interest in expensive real estate in order to convince

friends of hers, including R.B. and R.G. (further described below), to “loan” her money, knowing

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that she could not repay anyone, including R.B. and R.G. Law enforcement believes that she used

her promise of providing more money to R.B. and R.G. as well as her fraudulent cancer diagnosis

to garner sympathy and steal money from R.B. and R.G., while also causing losses to real estate

owners who thought she was actually interested in and could purchase their properties, which she

could not.

8. During both the book publishing and the real estate schemes, ANDERSON

exploited R.G. to fund her fraudulent activities and act on her behalf. R.G., aged 74, is a resident

of Sunset Valley, Texas, and is an author, attorney, and self-proclaimed “afterlife expert.”

ANDERSON became acquainted with R.G. after publishing one of R.G.’s books. During the

fraudulent schemes, R.G. purported to be either ANDERSON’s attorney,1 advisor, agent, or

representative of ANDERSON. R.G. often communicated ANDERSON’s false statements and

other misrepresentations on ANDERSON’s behalf, believing herself that ANDERSON had vast

wealth and cancer. R.G. used email to communicate with people on ANDERSON’s behalf. I

know that R.G. has “loaned” ANDERSON close to $1 million since 2015, all while believing

ANDERSON has Stage 4 cancer and vast wealth and that ANDERSON will repay R.G. the loan

plus far more in interest. I know that ANDERSON has used “proof of funds” notes that are

misrepresentations of her wealth in order to convince R.G. of her wealth. I also know that

1
We do not believe that there is an actual attorney-client relationship between R.G. and ANDERSON,
based, in part, on the representations in emails that R.G. is retired from practicing law and the fact that ANDERSON
has hired numerous attorneys to represent her in the transactions. However, if such an attorney-client privilege
relationship exists, this affidavit is based on communications R.G. had with third parties, which would not be
privileged.

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ANDERSON has conveyed to R.G. that she does not have access to her vast wealth due to a variety

of reasons, including that an accountant embezzled money from ANDERSON or that the SEC or

FBI have frozen her accounts, none of which are true. As mentioned below, R.G. still believes

that ANDERSON will not only repay the $1 million but that ANDERSON will give her $19

million upon ANDERSON’s imminent death of Stage 4 cancer.

9. In April 2020, ANDERSON’s fraudulent real estate activities were reported to the

Madison County Sherriff’s Office (MCSO) by R.B., who is a resident of California and a real

estate agent with Sotheby’s International Realty. ANDERSON and R.B. worked together

previously in Los Angeles, California. As described below, in 2020, R.B. also helped facilitate

one of the real estate transactions, while “loaning” money to ANDERSON. R.B. reported to

MCSO that he loaned ANDERSON a total of $17,500, while ANDERSON promised to return that

money plus more, all while misrepresenting to R.B. that she had vast wealth and Stage 4 cancer.

For example, according to R.B., ANDERSON claimed she had two million shares of MGM stock

with a total value of $60 million. R.B. used PayPal to send money to an account called “Milton

Hankins Accounting Services” to loan ANDERSON money. I know that Milton Hankins is

ANDERSON’s boyfriend or fiancé and that he lives with ANDERSON. After a review of

ANDERSON’s bank accounts, I know that she transfers money from the Milton Hankins

Accounting Services Pay Pal account into bank accounts in her name. R.B. reported

ANDERSON’s scheme to MCSO because he no longer believed ANDERSON’s false statements

and thought that she might be defrauding people, including him.

10. As mentioned below, a review of ANDERSON’s bank accounts shows that she

does not have vast wealth, but has little to no income, other than small royalties payments coming
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from Amazon. I also have reviewed her health records at University of Virginia Health, where she

purports to others that she is receiving cancer treatment. According to her health records, she does

not have cancer and does not report a history of having cancer. She is, however, receiving

treatment for diabetes, bipolar disorder, and bandemia.2

B. Book Publishing Scheme

11. Between approximately 2014 and 2017, ANDERSON owned and operated a

publishing company known as Christine F. Anderson Publishing & Media (hereinafter “CFA”).

ANDERSON later renamed CFA to Sage Wisdom Publishing (hereinafter “Sage Wisdom”) and

operated under that entity name from approximately 2017 through 2020. During this time,

ANDERSON used both entities to perpetuate a scheme on book authors wherein the authors were

defrauded of royalties from sales of their published works.

i. M.M.

12. For example, in June 2014,3 ANDERSON was retained by M.M. to publish a book

trilogy. According to their contract, M.M. agreed to pay ANDERSON fees upfront for publishing

and marketing, and, in return, M.M. was to be compensated by ANDERSON with a percentage of

royalties from book sales. Following significant delay and excuses by ANDERSON, in March

2015, M.M.’s books were eventually published. After receiving information from ANDERSON

and vendors about the volume of sales of her books later in 2015, M.M. inquired with ANDERSON

2
I know “bandemia” refers to a condition of having too many white blood cells in the bloodstream, caused
by infection or inflammation, not necessarily from cancer.
3
Although this is outside the statute of limitations, I provide this information as context regarding this book
publishing scheme and lack of mistake in further schemes.

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about her royalties that were owed to her. Over the course of several months, ANDERSON

communicated or caused to be communicated to M.M. a number of reasons for the failure to

provide the royalties funds, including that:

a. ANDERSON had a brain lesion and traveled to the Cancer Treatment Center of
America in Pennsylvania for treatment;

b. The account on which ANDERSON wrote a royalties check to M.M. from was
compromised and had to be closed;

c. A replacement check for royalties had been delivered to a wrong address;

d. An account from which an electronic payment was to drawn was “too new” for
direct disbursements;

e. ANDERSON was stressed by her cancer treatments;

f. There was an unspecified banking error and that ANDERSON was missing
checks;

g. ANDERSON needed time to process “not so good” news from her doctors about
her condition;

h. There was a “hold” on the account from which cashier’s checks were to be drawn;

i. ANDERSON had a tumor that was inoperable; and

j. ANDERSON’s assistant had stolen her credit card information and made
fraudulent purchases.

13. On January 13, 2016, after not receiving her royalties, M.M. sent a certified letter

to ANDERSON demanding missing royalties in the amount of $13,156.28. To date, M.M. has

not received any monies from ANDERSON, despite the book continuing to be sold.

14. M.M. used email to communicate with ANDERSON.

15. On or about March 24, 2016, the MCSO executed a state-level search warrant at

ANDERSON’S residence in connection with ANDERSON’s fraudulent book publishing scheme.

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Among the records seized by authorities at that time was documentation that refuted

ANDERSON’s claims of failing health due to cancer. ANDERSON was later arrested on a state

felony warrant for obtaining money by false pretenses, but the prosecution was discontinued in

November 2016. Soon thereafter, ANDERSON changed the name of CFA to Sage Wisdom, and

continued operating the business. During that search, MCSO saw invoices with cut and taped

information to falsify those documents.

ii. J.T.

16. On January 27, 2016, author J.T. entered into a publishing contract with

ANDERSON for one of her books. That book was published on Amazon, including in a Kindle

format. J.T. agreed to pay ANDERSON a retainer of $1,000 for “marketing and publicity,” and

in return, ANDERSON agreed to pay J.T. a percentage of royalties.

17. On August 20, 2016, J.T. entered into a publishing contract with ANDERSON for

another book. According to the contract, J.T. paid ANDERSON an upfront, refundable retainer

of $3,900 retainer for translation, promotion, and marketing. In return, ANDERSON agreed to

pay J.T. a percentage of royalties and to continue to market and publish J.T.’s book.

18. During the course of the book publishing scheme involving J.T., ANDERSON and

J.T. would directly communicate via email. ANDERSON would make false statements regarding

her health to engender sympathy and excuse delay in contractual obligations to J.T. On September

22, 2016, ANDERSON stated that she had “emergency surgery” and was diagnosed with Stage 2

colon cancer, with “8 weeks of chemo and radiation ahead of me.” On November 1, 2016,

ANDERSON wrote to J.T. that she was having a “health crisis” and that ANDERSON “just got in

from an assessment today and was told the cancer has spread to the lining of my stomach.”
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19. In 2016, J.T. made payments to “Milton Hankins Accounting Services” through

PayPal. Some payments were for purported “foreign translations.”

20. In 2017 to 2020, J.T. made many attempts to obtain royalties and copies of

audiobooks owed to her by ANDERSON. J.T. would communicate with R.G. through email in

order to obtain these royalties. ANDERSON caused R.G. to communicate to J.T. a number of

reasons for the failure to provide J.T. what was owed, including that:

a. Funds were not yet available because the Patriot Act has a ten-day hold on seven-

figure wires;

b. Checks needed to provide funds were coming by private plane, but there was a

“wheel issue” and also that the plane was fogged in a the airport;

c. There was “some sort of transformer problem” that delayed the transfer of funds;

and

d. Religious holidays “created a wire backlog.”

21. According to J.T., ANDERSON owes J.T. over $10,000. To date, there are no

foreign translations of J.T.’s books. J.T. has not received the royalty payments she is owed.

iii. S.W.

22. On April 20, 2017, author S.W. entered into a contract with ANDERSON’s

company to publish her books. Throughout the publishing relationship, S.W. communicated with

ANDERSON at her 91canderson@gmail.com account.4 S.W’s books began selling on Amazon,

4
We sent a preservation notice for this Gmail account to Google.

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but ANDERSON was not paying S.W. her royalties. S.W. communicated with R.G., who

purported to act on behalf of ANDERSON, in order to obtain royalty payments.

23. For example, in December 2017, ANDERSON sent S.W. a check through the mail

for over $3,000 in royalty payments, but the check did not clear with S.W.’s bank because

ANDERSON did not have enough funds. According to emails between ANDERSON, S.W., and

R.G., ANDERSON purported to have vast wealth but currently had issues with banks “closing”

her accounts suddenly and without explanation.

24. According to emails by R.G., ANDERSON’s excuse for not making the royalty

payments was that ANDERSON was, in part, busy working with the White House on the State of

the Union and that Morgan Freeman was spending time with his “friend,” ANDERSON. Based

on my training and experience and investigation in this case, I believe ANDERSON led R.G. to

believe she had vast wealth and power by falsely claiming relationships with famous people, like

President Trump and celebrities. And then R.G. communicated these misrepresentations to

authors, like S.W., in order to convey that ANDERSON would eventually pay the royalties, all

while ANDERSON kept the royalties for herself and was taking money from R.G.

25. In emails between R.G. and S.W., R.G. states: “I gather that you think that I have

been lying to you, or else I am deeply deluded [about ANDERSON]! But actually, I spent a good

deal of time in the beginning testing and checking. That’s what happens when you work with

someone whose story is literally unbelievable…but all true.” Based on my investigation of this

case, I believe ANDERSON provided false representations of her wealth and power to R.G., in

order for R.G. to believe, or “test and check” ANDERSON’s wealth, and that R.G. believed her.

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26. On December 28, 2017, ANDERSON, using her 91canderson@gmail.com

account, emailed S.W. about ending their publishing relationship, thanked S.W. for “firing” her,

and mentioned that she was fighting a medical condition since 2001. On December 19, 2017,

S.W. rescinded her contract with ANDERSON. S.W. has not received any royalty payments for

the book published through ANDERSON.

27. According to S.W., she was never paid any royalties despite being a bestseller on

Amazon, and she has paid attorney’s fees in order to obtain control over her book on Amazon.

iv. Other Authors

28. In the 2017 to 2020 time period, numerous other authors allege similar conduct by

ANDERSON. These authors include but are not limited to F.G., P.Y., B.C., K.G., and D.B. These

authors entered into similar contracts with ANDERSON that called for the payment an upfront

retainer, but rarely if ever received royalties owed to them, nor a refund of the fees paid.

C. Real Estate Scheme

29. In 2019, ANDERSON’s fraudulent activities shifted to real estate. On October 15,

2019, ANDERSON changed or caused to be changed the registered name of Sage Wisdom to the

Roar Charitable Fund, LLC. On March 12, 2020, ANDERSON also created or caused to be

registered a second entity, Roar Real Estate, LLC.

i. Aerie Farm Property

30. In December 2019, ANDERSON tried to purchase Aerie Farm in Orange County,

Virginia, which is worth around $1.8 million. During the course of this sales transaction,

ANDERSON provided two “proof of funds” letters from a purported account with Goldman Sachs,

in which she represented that she had $2,000,000 and $4,459,392 in certain bank accounts. I have
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seen both proof of funds letters, and, based on my training and experience, I believe these to be

photo copies with places taped on by ANDERSON to misrepresent her wealth. Law enforcement

confirmed with Goldman Sachs that no such accounts with that amount of money exists.

31. During the sales transaction for Aerie Farms, ANDERSON used her

91canderson@gmail.com account, in which she and R.G. repeatedly promised that wire transfers

were forthcoming to complete the real estate transaction, none of which materialized.

ANDERSON and R.G. maintained that there were problems with her bank accounts. According

to the attorney for the sellers of Aerie Farms, ANDERSON’s stories became “more and more

outrageous,” to include claiming she was an advisor to President Trump, flying in a private jet,

being grief-stricken over the death of her friend Kobe Bryant, and having Stage 4 cancer. In emails

with the seller’s attorney, ANDERSON and R.G. also claimed ANDERSON was the victim of

identity theft and fraud, which purported to excuse the lack of wire transfers. This real estate

contract was never finalized.

ii. Pin Oak Road Property

32. In March 2020, R.B., mentioned above, travelled to Virginia to visit ANDERSON.

R.B. made the trip because ANDERSON told him that she had Stage 4 cancer and that

ANDERSON wanted R.B.’s help with some real estate transactions.

33. During R.B.’s visit to Virginia, ANDERSON made numerous statements regarding

her purported wealth. ANDERSON told R.B. that she had two million shares of MGM stock that

she received from a trust and over $60 million in total stocks. ANDERSON stated that she has

only been able to access her funds two years ago because of the Securities and Exchange

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Commission (“SEC”) and the “regulations” the SEC had on ANDERSON’s accounts.5

ANDERSON also told R.B. that she was in escrow on three properties totaling nearly $8 million

dollars.

34. During his trip in March 2020, ANDERSON expressed to R.B. her discontent with

her current real estate agents and asked R.B. if he wanted to make money by being her referring

agent. R.B. referred ANDERSON to a property located at 610 Pin Oak Road, Paw Paw, West

Virginia (hereinafter the “Pin Oak Road” property). On or about April 24, 2020, ANDERSON

caused a letter to be sent from her purported accountant to the seller of the Pin Oak Road property,

stating that ANDERSON held a Goldman Sachs savings account solely in her name with a balance

of $6.8 million. ANDERSON also sent this letter to R.B. ANDERSON also caused to be furnished

as part of the transaction a document purporting to be from Goldman Sachs likewise “confirming”

the account in good standing. Both documents were false and fraudulent, as Goldman Sachs later

confirmed to law enforcement that ANDERSON held no such account. I have also seen that letter

and it appears, based on my training and experience, that it is a photocopy of a letter with taped

numbers with the fraudulent balance.

5
In April 2005, ANDERSON was indicted in the Northern District of Illinois for securities fraud. See
United States v. Favara, No. 1:05-CR-340 (N.D.Ill). In June 2009, after a plea of guilty, the district court sentenced
her to 70 months imprisonment and $155,000 in restitution. In July 2005, the Securities and Exchange Commission
(SEC) filed a Complaint for violations of federal securities laws against ANDERSON. See SEC v. Favara, No.
2:05-CV-05486 (C.D. Cal). In March 2006, ANDERSON entered into a consent judgment. On August 14, 2006,
the district court in the Central District of California found that ANDERSON committed violation of federal
securities laws. The district court ordered that ANDERSON pay a civil penalty of $100,000 and pay back $15,000
in ill-gotten gains. In 2013, while on supervised release in this district, she was found in violation of not paying her
restitution. See United States v. Favara, No. 3:12-CR-30 (W.D.V.A) (the federal public defender represented her
during these proceedings). To date, I believe that ANDERSON has not paid a substantial amount of either
judgment.

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35. ANDERSON, operating through an entity called the Roar Real Estate LLC, made

an offer to purchase the Pin Oak Road property. The seller of the Pin Oak Road property accepted

ANDERSON’s offer of $3.7 million. An earnest money deposit (“EMD”) in the amount of

$111,000 was due from ANDERSON on or about May 6, 2020. The closing of the transaction

was scheduled for June 30, 2020. On May 6, 2020, ANDERSON did not pay the EMD as agreed,

and she and/or her agents made further promises to pay the EMD on May 13, May 18, May 19,

and May 20, 2020. ANDERSON never paid the EMD, and the contract for the Pin Oak Road

property was terminated. As a result of this scheme, the Pin Oak Road seller incurred monetary

losses, including losses associated with inspections, attorney’s fees, and the prospective sale of the

property.

36. R.B. also reported that at the same time he was the referring agent for ANDERSON

on a property in Costa Rica with a list price of $5.5 million. ANDERSON reported to him that

she was interested in this property because there were more cancer treatment options.

ANDERSON indicated to R.B. that the transaction was “on hold” due to the pandemic.

37. As mentioned above, in April 2020, R.B. first notified MCSO about ANDERSON’s

potential scheme and the amount she owed him in loans made to ANDERSON concurrent with

the real estate sale.

iii. Walden Hall Property

38. On or about July 17, 2020, ANDERSON, operating through an entity called The

Roar Trust, made an offer to purchase a property at 17440 True Blue Lane, Culpeper, Virginia

22701 (hereinafter the “Walden Hall” property). The offer price for the Walden Hall property was

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$4.5 million. Closing was scheduled for July 30, 2020, and an EMD in the amount of $75,000

from ANDERSON was due on or about July 20, 2020.

39. In connection with the transaction, ANDERSON caused to be sent a proof of funds

purporting to confirm an investment account at Chase Bank with a balance more than $8.4 million.

This proof of funds was false and fraudulent, as Chase Bank later confirmed to law enforcement

that ANDERSON held no such account balance, nor would it provide such a letter. I have seen

this letter. Like the Goldman Sachs note, based on my training and experience, I believe this letter

is a doctored photocopy with taped on lettering regarding ANDERSON’s funds.

40. On or about July 19, 2020, ANDERSON wrote a $75,000 check for Walden Hall

EMD from a Premier Access account affiliated with the Roar Real Estate LLC. The check was

returned due to a stop payment being placed on the check. On or about July 28, 2020,

ANDERSON wrote a second EMD check, this time in the amount of $100,000 from a purported

Bank of New York Melon Account affiliated with The Roar Trust. This check was also returned.

For several weeks thereafter, ANDERSON communicated or caused others to communicate on

her behalf various reasons for the delays in the transfers of funds, including among other things

that:

a. ANDERSON’s health was not well;

b. There were continued issues with her banks and the money transfer;

c. ANDERSON received news of the accidental death of someone close to her;

d. ANDERSON’s prior accountant had committed fraud or embezzled from her

accounts, and there was an ongoing “legal battle”;

e. ANDERSON had upcoming stomach surgery and related appointments;

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f. Doctors had found metastases on ANDERSON’s brain; and

g. The 9/11 anniversary caused her to be depressed and emotional.

41. Ultimately, ANDERSON never paid, and the contract for the Walden Hall property

was terminated. The sellers of the Walden Hall property estimate losses in excess of $477,000,

including refunded bookings for rented rooms and weddings, lost revenue for rentals, attorneys

fees, and other expenses in connection with the fraudulent transaction.

42. During the course of this real estate sale, R.G. and ANDERSON emailed with the

sellers of Walden Hall and their representatives. ANDERSON used another email that we know

she is associated with, namely “theroartrust@gmail.com.”

iv. Lindsay Lane Property.

43. On or about December 3, 2020, ANDERSON, operating through The Roar Trust,

made an offer to purchase a property at 1596 Lindsay Lane, Madison, Virginia 22727 (hereinafter

the “Lindsay Lane” property). The offer price of the Lindsay Lane property was approximately

$4.2 million. Closing was scheduled for December 21, 2020, and an EMD in the amount of

$42,000 from ANDERSON was due five days after the date of contract ratification. In connection

with the transaction, ANDERSON caused to be sent a proof of funds purporting to confirm a

private client banking account at Chase Bank with a balance in excess of $25 million. This proof

of funds was false and fraudulent, as Chase Bank later confirmed to law enforcement that

ANDERSON held no such account balance. I have seen this “proof of funds” letter and, like the

others, based on my training and experience, this letter appears to be a doctored photocopy.

44. On December 3, 2020, ANDERSON cancelled a showing of the Lindsay Lane

property for a third time. ANDERSON’s real estate agent sent an email to the sellers containing
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a purported statement from ANDERSON that ANDERSON’s health was not well because of her

“disease,” which the agent clarified was cancer. On or about December 7, 2020, the sellers of the

Lindsay Lane property learned of ANDERSON’s criminal history background and raised the issue

with ANDERSON’s real estate agent. ANDERSON communicated or caused to be communicated

to the sellers that she was offended that the sellers would even question ANDERSON’s

truthfulness. ANDERSON asked to be released from the contract and the transaction was

thereafter terminated.

D. Bankruptcy Filing

45. On or about July 1, 2020, amidst ANDERSON’s real estate scheme, ANDERSON

filed a Chapter 13 Voluntary Petition for Bankruptcy in the U.S. Bankruptcy Court for the Western

District of Virginia. ANDERSON reported that she was the sole proprietor of the Roar Charitable

Fund, LLC, DBA Sage Wisdom Publishing. In the petition, ANDERSON estimated her total

assets to be worth $0 to $50,000. In a summary of assets filed in the bankruptcy on July 14, 2020,

ANDERSON listed her total assets as $14,554.00, and her total liabilities as $234,735.48.

ANDERSON also admitted that she has previously been identified as “Favara” and that she owed

money to a variety of parties associated with the above schemes, including R.B., and the U.S.

District Court clerk.

46. On or about August 3, 2020, the attorney for the Aerie Farm sellers, mentioned

above, wrote and filed a letter to the bankruptcy court judge, along with supporting documentation,

identifying the discrepancies between ANDERSON’s bankruptcy filing and her representations of

wealth in ANDERSON’s fraudulent real estate transactions.

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47. On August 3, 2020, following this bankruptcy letter, ANDERSON sent a blistering

email, using the 91canderson@gmail.com account, to various relevant parties, starting the message

with “[h]ow dare all of you.” ANDERSON also stated in the email that she had Stage 4 stomach

cancer for three years, and that she has “plenty of proof” from the University of Virginia and

another medical center.

48. In ANDERSON’s August 3, 2020 email, using the 91canderson@gmail.com

account, she also blamed the COVID-19 pandemic for the variance in her finances in the

bankruptcy petition. ANDERSON stated that “I answered the questions on the forms I submitted

honestly for which the time frame they applied.” ANDERSON also provided a myriad of reasons

defending her actions in the real estate transactions, stating that she and her attorneys possessed

“backup” to her claims in the email.

49. In this email, ANDERSON stated, “Roberta is not my attorney Lewis Rhodes is,

Roberta helps me when I get tired and need an extra set of hands and eyes. I am also more hot

headed and her cooler head always prevails.”

50. On or about August 5, 2020, ANDERSON filed a motion to dismiss her bankruptcy

case, which the bankruptcy court granted on or about August 14, 2020.

E. Report by R.G.’s Daughter

51. In March 2021, law enforcement learned from R.G.’s daughter that R.G. had

provided ANDERSON a substantial sum of money, approaching $1 million, over a period of five

to six years. R.G.’s daughter reported that R.G believed ANDERSON’s claims of wealth and

imminent death from cancer. R.G.’s daughter currently lives with her parents in Texas.

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52. R.G.’s daughter stated that R.G. had provided ANDERSON money and assistance

based on ANDERSON’s promise to repay the debt along with promises of generous gifts and

bequests. For example, ANDERSON entered into a promissory note wherein she promised to not

only repay $1 million to R.G., but to also provide an additional $19 million to R.G. R.G. is also a

purported beneficiary of ANDERSON’s trust, which says that upon her death, ANDERSON will

give R.G. $19 million, and that she will give certain personal property to others, including a first

edition copy of To Kill A Mockingbird and a Gustav Klimt painting. R.G. also believed that

ANDERSON was pursuing real estate deals in Texas so that ANDERSON could receive better

“cancer treatment” near M.D. Anderson Hospital.

F. Anderson’s Identity Theft Complaint

53. On March 18, 2021, ANDERSON contacted MCSO to report that she was the

victim of an identity theft. ANDERSON reported that since May 2020, someone had been using

her identity to make purchases from various accounts, including but not limited to PayPal, Venmo,

and Amazon, causing various accounts of hers to have negative balances. Upon information and

belief, ANDERSON had not made any such complaint to law enforcement before this date.

54. On March 18, 2021, in response to her complaint, Inv. Jason Kilby with MCSO

went to the subject ANDERSON’S residence to speak with ANDERSON. ANDERSON invited

Inv. Kilby inside her residence to speak about the issue. ANDERSON indicated that multiple

accounts of hers had unauthorized transactions. ANDERSON claimed that the unauthorized

transactions resulted in her unknowingly writing a check on a closed Chase Bank account.

55. ANDERSON expressed some concern that she would soon be criminally charged

by authorities in Culpeper, Virginia, for a bad check to a car mechanic for $3,900, which she
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claimed she could not pay because of the alleged identity theft. ANDERSON also stated that her

landlords were threatening to evict her due to the problems with her accounts. Furthermore,

ANDERSON reported to Inv. Kilby that she had Stage 4 stomach cancer that had metastasized

into her spine and brain. ANDERSON provided Inv. Kilby some documents pertaining to her

complaint to make copies, but ANDERSON only showed Inv. Kilby a small fraction of paperwork

that she represented contained additional financial records. Based on training and experience, it

appeared ANDERSON had made the report of alleged criminal activity in response to her

immediate concerns of legal jeopardy.

56. During the conversation with Inv. Kilby, ANDERSON stated that a possible

perpetrator of the alleged identity theft could include R.G.’s daughter.

57. At this time, we know, through recorded conversations between R.G. and her

daughter, that ANDERSON knows R.G.’s daughter reported the scheme to Texas law enforcement

and the FBI regional office in Texas. I believe that ANDERSON made this fraudulent identity

theft report to avoid criminal charges with the bad check and to avoid detection from R.G.’s

daughter’s complaint.

58. During the course of this identity theft reporting, ANDERSON used her

91canderson@gmail.com email account to communicate with Inv. Kilby as well as her cell phone,

with a number of (434) 806-6364.

G. R.G.’s Daughter Provides Further Information

59. R.G.’s daughter provided documentation to law enforcement, including notes that

she found, created by her mother, which documents how much money R.G. loaned ANDERSON

over the past five years. This documentation was not found by R.G.’s daughter at the direction of
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law enforcement but was found by R.G.’s daughter separately as she was trying to determine why

her mother no longer could pay her bills.

60. On or about April 19, 2021, R.G.’s daughter reported that her mother continues to

have a genuine belief in ANDERSON’s representations and described R.G.’s belief in

ANDERSON as a “blind loyalty and delusional state.” Based on recorded conversations between

R.G. and her daughter, which her daughter provided to law enforcement, R.G. still believes that

she is on the cusp of receiving a vast amount of money from ANDERSON in return for the money

she “loaned” ANDERSON over the years and money ANDERSON is bequeathing R.G. in her

Will. R.G. also believes that ANDERSON will soon die from cancer.

61. I know that R.G. continues to search for real estate on behalf of ANDERSON,

including properties in Texas. For example, in January 2021, R.G. attempted to enter into a

contract with a property in Koether, Texas, in which ANDERSON mailed a bad check to the title

company in the amount of $67,000. According to R.G.’s daughter, R.G. continues to search for

other properties in Texas for ANDERSON.

62. We also know that ANDERSON has used Steve Hankins’ PayPal account to

transfer funds from the real estate and book publishing schemes into her bank account. During

these schemes, ANDERSON has used multiple ways to communicate, other than through email,

including through Facebook messenger and over her cellular phone.

H. Review of Bank and Health Records

63. I have reviewed many of ANDERSON’s bank accounts, and I have not seen proof

of wealth. ANDERSON does not have large balances in any of her bank accounts. I see that she

transfers money from Steve Hankins’ PayPal accounts into her Chase checking account and she
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also received Zelle transfers from R.G. I see that she often takes cash out from this checking

account in several hundred-dollar denominations. I have spoken with Chase and can confirm that

the “proof of funds” letters from Chase are not real and that Chase would never send such a letter.

Law enforcement has also spoken with representatives from Goldman Sachs and can confirm that

she does not have a large seven figure account with them either.

64. Law enforcement has obtained ANDERSON’s health records from University of

Virginia Health, in which for the past two years she has seen doctors for diabetes, colon cancer

screening through colonoscopy (which was negative), bipolar disorder, and bandemia. According

to her self-reported health history, ANDERSON does not have a history of any type of cancer.

ANDERSON also pays for this health treatment through AETNA Medicaid.

CONCLUSION

65. Based on the foregoing, there is probable cause to believe that there have been

violations of mail fraud in violation of 18 U.S.C.§ 1341 and wire fraud in violation of 18 U.S.C.

§ 1343 committed by Christine Favara ANDERSON from on or about May 2016 to today.

Respectfully submitted,

/s/ Jane Collins

Jane Collins
Special Agent
Federal Bureau of Investigation

27th
Received by reliable electronic means and sworn and attested to by telephone on the ________of
April 2021.

______________
____
____
__ __________
_________ _______ ______
Th
The
he Honorable Joel C. HHo
Hoppe
opp
opp
p pe
United
U it d St
States
t M Magistrate
i t t JJudge
d

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