Exhibit A. Declaration of Special Agent Hernandez — USA v. Lorquet (Dkt. 51-1, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:22-cr-20326-KMM · Doc. 51-1 · 2023-02-22 · Docket on CourtListener

Full text

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO. 22-CR-20326-KMM 
 
 
UNITED STATES OF AMERICA 
 
v.  
 
ANDRE LORQUET,  
 
 
 
Defendant. 
 
 
 
 
 
 
 
 
DECLARATION OF JOSE HERNANDEZ 
IN SUPPORT OF FORFEITURE  
 
I, JOSE HERNANDEZ, under penalty of perjury, declare: 
 
1. 
I am a Special Agent with the Department of Homeland Security, Homeland 
Security Investigations (“HSI”), and have been since 2020.  I am currently assigned to the Identity 
Document & Benefit Fraud Taskforce (“IDBFTF”).  As a Special Agent and member of the 
IDBFTF, I have participated in and directed numerous investigations involving identity theft, wire 
fraud, bank fraud, and theft of government property.  I have also had training in investigating 
various types of fraud committed using stolen identities, including fraud tactics, methods, and 
techniques.   
2. 
The information contained in this declaration is based upon my personal knowledge 
and my review of documents and records gathered during the course of this investigation, as well 
as information obtained, directly or indirectly, from other sources and agents, including 
information provided to me by other agents who are involved in the investigation.  I make this 
sworn declaration in support of the United States’ Motion for Preliminary Order of Forfeiture.  
Case 1:22-cr-20326-KMM   Document 51-1   Entered on FLSD Docket 02/22/2023   Page 1 of 4

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Because this declaration is being submitted for a limited purpose, it does not include all of the facts 
that I have learned during the course of the investigation. 
3. 
Law enforcement has reviewed financial records for Miami ENT, LLC (MEL) and 
the Defendant. Based on a review of those and other records, law enforcement determined that on 
or about August 18, 2021, an SVOG application for MEL was submitted online to the SBA. The 
SVOG application for MEL was fraudulent, containing a fraudulent IRS form for 2019 which 
listed MEL’s gross revenue as $5,444,292. On November 12, 2021, a letter was sent to the SBA 
appearing to be from C.D., a tax preparer, confirming that MEL had filed its taxes in 2019. The 
letter attached a fraudulent tax transcript and a copy of the Form 1120-S. That form listed C.D. as 
the tax prepared and included her IRS E-FIN. The SBA awarded MEL the SVOG grant and, on 
November 22, 2021, $2,501,259.34 was deposited by the SBA into Account 2431. Before those 
funds were deposited, that account had a balance of less than $800. On November 30, 2021, a 
supplemental SVOG award in the amount of $1,358,451.70 was deposited into Account 2431. 
4. 
On December 1, 2021, the Defendant transferred $400,000 of the SVOG grant from 
Account 2431 to Account 3570, and from there wired $329,195 to Elite Motor Cars of Miami LLC 
with reference “2022 URUS.” Also on December 1, 2021, the Defendant signed purchase 
documents for Lamborghini Urus VIN# ZPBUA1ZL1NLA16143. Five days later, on December 
6, 2021, the Defendant transferred $158,653.33 of the SVOG grant from Account 2431 to Tesla 
Motors. The Defendant also spent $30,900 of the SVOG grant on a diamond Audemars Piguet 
watch, a rose gold and diamond pendant with MEL’s logo, a gold chain with 70 carats of diamonds, 
and another gold chain.   
5. 
On or about October 7, 2022, law enforcement placed a title hold on the 
Lamborghini with the Florida Department of Highway Safety and Motor Vehicles.  
Case 1:22-cr-20326-KMM   Document 51-1   Entered on FLSD Docket 02/22/2023   Page 2 of 4

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6. 
On or about November 15, 2022, the Defendant sold the Lamborghini for $240,000 
in U.S. currency, in a transaction where title did not transfer. The buyer took possession of the 
Lamborghini. 
7. 
Law enforcement learned from its investigation that the Defendant instructed the 
buyer to wire the funds to Bank of America account number 8981 0729 7999 in the name of The 
B Murray Group. On November 15, 2022, the buyer wired $240,000 to buy the Lamborghini to 
Account 7999 in the name of The B Murray Group. Account 7999 was nearly empty, with less 
than $500 on deposit, before it received the Lamborghini sales proceeds on November 15, 2022. 
8. 
Within one week of receiving the proceeds from the sale of the Lamborghini, 
Account 7999 transferred $115,000, to Account 6905, which was also in the name of Bernard H 
Murray. This left approximately $125,000 in fraud proceeds in Account 7999, which were spent 
on check card and Zelle transactions until only $92,000 remained Account 7999, which represents 
proceeds from the sale of the Lamborghini.   
9. 
As for the $115,000 in proceeds deposited in Account 6905, on November 16, 2022, 
$92,000 was withdrawn from that account, and various check card and Square transactions spent 
down the remainder.  
10. 
In the course of the investigation law enforcement reviewed financial records, 
queried available databases, and conducted due diligence to locate forfeitable property traceable 
to the count of conviction in this case.  After investigating the Defendant’s assets, it is the 
conclusion of the declarant that due to the Defendant’s acts or omissions, other directly forfeitable 
property either cannot be located upon the exercise of due diligence; has been transferred or sold 
to, or deposited with, a third party; or has been commingled so proceeds cannot be divided without 
difficulty.  
Case 1:22-cr-20326-KMM   Document 51-1   Entered on FLSD Docket 02/22/2023   Page 3 of 4

Case 1:22-cr-20326-KMM   Document 51-1   Entered on FLSD Docket 02/22/2023   Page 4 of 4

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