82. In the above exchange, E. Gabbey is encouraged to travel to Europe with T. Tate by none other than her own mother, M. Gabbey, which is noteworthy given that M. Gabbey later becomes a material participant in the effort to destroy the lives of the Tate Brothers. Furthermore, E. Gabbey confirms that she had been planning to travel to the United Kingdom before ever having met the Tate Brothers. It is thus, glaringly obvious that E. Gabbey viewed T. Tate as the perfect vehicle upon which she could accomplish many of her goals. Therefore, even at this early stage, E. Gabbey viewed the Tate Brothers as not ends in themselves, but as means to transactionally help bring about her goal of visiting — and potentially even reestablishing her identity — in Europe.
83. After spending a few days at the Tate estate in Bucharest, E. Gabbey’s unrealistic expectations about living a glamorous life in Europe were forced to come to terms with the mundane, day-to-day realities of successful businessmen. Although T. Tate and A. Tate offered E. Gabbey free-range of their home and many luxuries throughout the duration of her visit, the Tate Brothers themselves spent most of their days preoccupied with work, rather than entertaining and spending time with guests. E. Gabbey refused to adjust her expectations to meet the Tate Brothers’ work-focused lifestyle: she expected a European tour immediately, and basically wanted to live and be treated like royalty. Her patience quickly wore thin; despite having access to their pool, vehicles, and other high-end amenities, E. Gabbey became bored and restless at the Tate estate. She no longer wanted to pursue opportunities in Romania as an e-model. Instead, E. Gabbey began conjuring ways to exploit the Tate Brothers, which, in accordance with her manipulative nature, could only ever be the one source of true pleasure for her.
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84. E. Gabbey proceeded to survey the other female friends of the Tate Brothers who visited their estate for potential accomplices. Although the overwhelming majority of female guests were quite happy with the lifestyle, E. Gabbey dialed in on one guest, A. Untila, who appeared similarly bored with the experience — and, like E. Gabbey, was looking for newfound excitement. E. Gabbey conscripted A. Untila, using similar methods of manipulation, to convince her to go along with E. Gabbey’s new scheme to defraud the Tate Brothers — and ultimately accuse them of human trafficking and other grave crimes. Afterward, being rescued by the United States Embassy and Romanian Police for human trafficking, E. Gabbey and A. Untila would travel together to the French Riviera and London to have the glamorous European experience E. Gabbey had always envisioned.”
85. E. Gabbey and A. Untila started off by using a private group chat to plot their conspiracy against the Tate Brothers — upon information and belief, at the heart of the conspiracy was the motive to defraud A. Tate of $200,000.00 euros of money. On April 10, 2022, E. Gabbey and A. Untila initiated their plot to obtain money from A. Tate by false pretenses. Although they were ultimately unsuccessful, the following exchange provides insight into how E. Gabbey and A. Untila had planned to defraud and extort A. Tate of money and potentially other luxuries:
Quote:
E. Gabbey: “I’m talking to my friend
E. Gabbey: “about it now.”
E. Gabbey: “she is saying you should try to get $ from
andrew.”
E. Gabbey: “where is your sister in london babe.”
A. Untila: “I’m not good at this lol.”
A. Untila: “I have never asked anyone for money.”
E. Gabbey: “she’s saying if you tell him you have something
important that you need money for, he will give it to you.”
A. Untila: “Okay I will think about it like what to say.”
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86. The two women, E. Gabbey and A. Untila, then go on to take matters to the next level and have the following conversation, in text messages and in pertinent part, in which they describe how they will employ matters of deception against the Tate Brothers to carry out the criminal act:
Quote:
E. Gabbey: “cover tracks.”
E. Gabbey: “always.”
E. Gabbe: “your phone might be visible.”
A. Untila: : “You are a good actress [unknown emoji].”
E. Gabbe: « i practiced.”
A. Untila: erfecto, ”
A. Untila: “for now change my name in your phone.”
E. Gabbey: “okay.”
E. Gabbe: ‘you too, »
A. Untila: : “Just play it cool.”
E. Gabbe: got it ”
A. Untila: ike you don’t know anything.”
A. Untila: ‘play dumb.”
E. Gabbey: “i’m going to pull some tears out.”
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87. It is clear from the above exchange that neither E. Gabbey nor A. Untila believed they were victims. Rather, they simply did not want to be held responsible for attempting to defraud A. Tate of money and devised a whole scheme, using false pretenses, to trick him. Further evidence of their chicanery is found in the fact that E. Gabbey even goes so far as to laugh when A. Untila speaks about “playing the victim.” Afterward, E. Gabbey and A. Untila joke about contacting Netflix and other streaming services to recount their “golden Oscar” performances, which they apparently considered Hollywood worthy. The following exchange took place between E. Gabbey and Untila and demonstrates their cavalier, flippant attitudes towards committing fraud:
Quote:
E. Gabbe: “we are writing a movie asap.”
A. Untila: ”
ep.
A. Untila: ‘or sure. ”
A. Untila: ‘We have too. ”
E. Gabbe: T’m dying inside.”
A. Untila: et’s email Netflix.”
A. Untila: ‘Asap. ”
E. Gabbe: hulu, amazon prime.”
A. Untila: “Yep. 331
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88. In making light of a very serious accusation — it is patently clear from the above exchange that neither E. Gabbey nor A. Untila believed they were ever in real danger, let alone in a situation even remotely close to “human trafficking” or being “falsely imprisoned,” which they would later allege. Indeed, the very opposite is true: rather than being victims, E. Gabbey and A. Untila are in fact perpetrators of a crime of moral turpitude to commit fraud against the Tate Brothers. Upon failure to execute their conspiracy, instead of taking responsibility for their actions like any morally competent and self-aware adult, E. Gabbey, consistent with her character, doubled down to inflict maximum damage.