A complaint obtained by NBC Philadelphia says couple Mark D’Amico and Kate McClure made up a GoFundMe campaign in honor of Johnny Bobbitt Jr. so that all three could raise money by deceiving generous donors. They kept up the ruse by preventing donors from acquiring information that would affect their judgment about the campaign and “by failing to correct their story,” the complaint added.

The three are expected to face charges that include conspiracy and theft by deception, a source familiar with the case told NBC Philadelphia, adding that D’Amico and McClure surrendered to authorities on Wednesday.