Information as to Willie Curry (1) count(s) 1 — United States v. Curry (Dkt. 1, S.D. Fla. No. 1:21-cr-20415)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:21-cr-20415-JLK · Doc. 1 · 2021-08-05 · Docket on CourtListener

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.
18 U.S.C. j 1343
18 U.S.C. j 982(a)(2)
UM TED STATES OF AM ERICA
VS.
W ILLIE CURRY,
Defendant.
/
G FORM ATION
The Acting United Sttes Attorney charges that:
GENERAL ALLEGATIONS
At a11 times material to this Information:
The United States Small Business Administration ((6SBA'') was an agency of the
executive branch of the Government of the United States. The mission of the SBA was to maintain
and strengthen the nation's economy by enabling the establishment and viability of sm all
businesses and by assisting in the economic recovery of communities after disasters.
The Coronavirus Aid, Relief, and Economic Security IECCA1tES''I Act was a federal
1aw enacted in or around M arch 2020 and designed to provide emergency financial assistance to
the m illions of Americans who were suffering the economic effects caused by the COVID-19
pandemic. The CARES Act authorized and provided funding to the SBA to provide Economic
l
21-20415-CR-KING/BECERRA
Aug 5, 2021
KS
Case 1:21-cr-20415-JLK   Document 1   Entered on FLSD Docket 08/05/2021   Page 1 of 8

Injury Disaster Loans C&E1DLs'') to eligible small businesses, including sole proprietorships and
independent contractors, experiencing substantial financial disruptions due to the COV1D-19
pandem ic to allow them to m eet financial obligations and operating expenses that could have been
met had the disaster not occurred.
3. 
ln order to obtain a COVlD-19 ED L, a qualifying for-profit business was required
to submit an EIDL application to the SBA and provide inform ation about its operations, such as
the number of employees, gross revenues, and the cost of goods sold for the lz-month period
preceding January 31, 2020. The applicant also was required to certify under penalty of perjury
that all the information in the application was true and correct.
4. 
EIDL applications were submitted directly to and processed by the SBA. The
amount of the loan approved was determined based, in part, on the infonnation provided in the
application concetming the number of employees, gross revenues, and cost of goods sold. Any
EIDL funds were issued directly by the United States governm ent to the applicant's bank account.
Defendant W ILLIE CURRY was a resident of M iami-Dade County, Florida, who
was employed full-time by M iam i-Dade County as a Network M anager.
6. 
Financial Institution 1 was a credit union based in Florida.
COUNT I
W ire Fraud
(18 U.S.C. j 1343)
Paragraphs 1 through 6 of the General Allegations section of this lnform ation are
re-alleged and incorporated by reference as through fully set forth herein.
2. 
From on or about June 24, 2020, and continuing through on or about December 15,
Case 1:21-cr-20415-JLK   Document 1   Entered on FLSD Docket 08/05/2021   Page 2 of 8

2020, in M iam i-Dade County, in the Southem  District of Florida, and elsewhere, the defendant,
W ILLIE CURRY,
did knowingly, and with the intent to defraud, devise, and intend to devise, a schem e and artifk e
to defraud, and to obtain money and property by means of materially false and fraudulent
pretenses, representations, and promises, knowing that the pretenses, representations, and
prom ises were false and fraudulent when made, and, for the purpose of executing the scheme and
artifice, did knowingly transmit and cause to be transm itted, by m eans of wire comm unication in
interstate and foreign commerce, certain writings, signs, signals, pictures and sounds, in violation
of Title 18, United States Code, Section 1343.
PURPO SE OF THE SCHEM E AND ARTIFICE
3. 
The purpose of the scheme and artifice was for W ILLIE CURRY to unlawfully
enrich himself by submitting a false and fraudulent EIDL application to obtain loan proceeds for
his own use and benefit.
THE SCH EM E AND ARTIFACE
The manner and means by which W ILLIE CURRY sought to accomplish the purpose of
the scheme and artifice included, among others, the following:
4. 
W ILLIE CURRY subm itled to the SBA, via interstate wire communications, an
EIDL application stating that he was the 100% owner of a sole proprietorship operating under the
nam e ç$W ill Curry Computers.'' In that application, CURRY falsely and fraudulently certified
that W ill Curry Computers was established on January l , 2015. He also falsely certified that for
the twelve (12) month period prior to January 31, 2020, W ill Curry Computers had gross revenues
3
Case 1:21-cr-20415-JLK   Document 1   Entered on FLSD Docket 08/05/2021   Page 3 of 8

I
of $755,416 and a cost of goods sold of $170,664.
5. 
ln actuality, and as the defendant knew, the defendant established W ill Curry
Computers in 2020, and it had only minimal income and cost of goods sold during the twelve (12)
period prior to January 31, 2020. lnstead, throughout 2019 and 2020, W ILLIE CURRY was a
full-time employee of M iami-Dade County working as a N etwork M anager and receiving a full-
time salary from M iami-Dade County.
6. 
As a result of this false and fraudulent EIDL application, the SBA disbursed a
$10,000 advance via Electronic Funds Transfer to Financial lnstitution 1 intended for deposit to
W ILLIE CURRY'S account at Financial Institution 1, and subsequently disbursed $150,000 in
loan proceeds via Electronic Funds Transfer to Financial Institution 1 intended for deposit to
CURRY'S account there. These Electronic Funds Transfers involved the use of interstate wire
communications.
USE OF W IRES
7. 
On or about the date specifed below, in the Southern District of Florida, and
elsewhere, W ILLIE CURRY, for the purpose of executing and in furtherance of the aforesaid
scheme and artifice to defraud, and to obtain money and property by means of materially false and
fraudulent pretenses, representations, and prom ises, klzowing that the pretenses, representations,
and prom ises were false and fraudulent when made, did knowingly transm it and cause to be
transmitted in interstate and foreign comm erce, by means of wire communication, certain writings,
signs, signals, pictures, and sounds, as described below:
4
Case 1:21-cr-20415-JLK   Document 1   Entered on FLSD Docket 08/05/2021   Page 4 of 8

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Jtme 24, 2020 
Eleckonic trnnqmission of atk Em L application
containing false inform ation about the p'oss
revenues and cost of goods sold of W ill Curt'y
Computers, causing a wire transm ission 9om  the
Southel'n Dishict of Flolida to outside of the
State of Florida
Jn violation of Title 18, United States Code, Sections 1343 and 2.
FORFEITURE ALLEGATIONS
1.
The allegations of this lndicM ent are hereby re-alleged and by this reference fully
illcolporated herein for the purpose of allegzg forfeiture to the United States of Am erica of certain
property in which the defendant, W K LIE CURRY, has an Zterest.
2.
Upon conviction of a violation of Title 18, United States Code, Section 1343, as
alleged i!l this Illdice enta the defendnnt, W ILLIE CURRY, shall forfeit to the United States any
property constituting, or derived from, proceeds obtained,directly or indirectly, as a result of such
violafon, pursuant to Title 18, United StatesCode, Section 982(a)(2)(A).
Al1 pursuant to Title 18, United States Code, Section 982(a)(2)(A), and the procedtlres set
foz'th in Title 21, United States Code,Section 853, as incorporated by Title18, Utzited States Code,
Section 98209(1).
Ju m oxl Goxzvsz
Q, Ac () 'ITE suerssAwouxsv
EDW ARD N . STA>
ASSISTANT UNU ED STATES ATTORNEY
5
Case 1:21-cr-20415-JLK   Document 1   Entered on FLSD Docket 08/05/2021   Page 5 of 8

IJM TED STATESDISTRICT COIJRT
SOUTHERNDISTRICT OFFLORIDA
W
TEDSTATESOFW
W CA
CASE NO.
CERTIFICATE OF T RIAL ATTO RNEY*
Superseding Case lnformation:
W illie Curry
Defendant. 
/
CourtDivision: (Select One) 
New defendantts) I--I Yes I--I No
EZ Miami r-l Key West N FTL 
Numberof new defendants
N WPB F-l FTP 
Totalnumberof cotmts
1. 1 have carefully considered the allegations of the indictm ent, the num ber of defendants, the number of proG ble
witnesses and the legal com plexities of the lndictment/lnform ation attachedhereto.
2. 1 am aware that the information supplied on this statem ent will be relied upon by the Judges of this Coul't in
setting their calendars and scheduling criminal trials under the m andate of the Speedy Trial Act,
Title 28 U.S.C. Section 3161.
3. Interpreter: (Yes or No) N0
List language and/or dialect
4. 'This case will take 0 days for the parties to try.
5. Please check appropriate category and type of offense listedbelow:
(Check only one) 
(Check only one)
I 0 to 5 days 
Ed 
P etty 
E7I
11 6 to 10 days 
EqI 
Minor 
EEI
111 1 1 to 20 days 
g7I 
Misdemeanor 
EEI
IV 21 to 60 days 
I7q 
Felony 
El-
z
V 61 days and over 
(7q1
6. Has this case previously been filed in this District Court? (Yes or No) N0
If yes: Judge 
CaseNo.
(Attach copy of dispositive order)
Has a complaint been filed in this matter? (Yes or No) No
lf yes: M agistrate Case No.
Related m iscellaneous numbers:
Defendantts) in federal custody as of
Defendantts) in state custody as of
Rule 20 from the District of
Is this a potential death penalty case? (Yes or No) No
7. Does this case originate from a m atter pending in the Central Region of the U.S. Attorney's Office priorto
August 9, 2013 (Mag. Judge Alicia 0. Valle)? (Yes or No) No
8. Does this case originate from a m atter pending in the Northern Region of the U .S. Attorney's Oftice prior to
August 8, 2014 (Mag. Judge Shaniek Maynard? (Yes or No) No
9. Does this case originate from a m atter pending in the Central Region of the U.S. Attorney's Office prior to
October 3, 2019 (Mag. Judge Jared Strauss)? (Yes or No) No
Edward N. Stamm
Assistant United States Attorney
FLA Bar No. 
373826
REV 3/19/21
'penalty Sheetts) attachal
Case 1:21-cr-20415-JLK   Document 1   Entered on FLSD Docket 08/05/2021   Page 6 of 8

UM TED STATES DISTRICT COIJRT
SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Nam e: W illie Currv
Case No:
Count 1
W ire Fraud
18 U.S.C. $1343
M ax. Penalty: Twenty years imprisonment; five years supervised release; $250,000 fine
Case 1:21-cr-20415-JLK   Document 1   Entered on FLSD Docket 08/05/2021   Page 7 of 8

AO 455 (Rev. 0 1/09) Waiver of an lndictment
U NITED STATES D ISTRICT COURT
for the
Southern District of Florida
United States of Am erica
V.
l/l/illill () tl r rh/
)
) 
Case No.
)
)
)
W AIVER OF AN INDICTM ENT
I understand that 1 have been accused of one or m ore offenses punishable by imprisonment for more than one
year. I w as advised in open cotu't of my rights and the nature of the proposed charges against me.
Afler receiving this advice, 1 waive my right to prosecution by indictm ent and consent to prosecution by
information.
Date :
De#ndant 's signature
Signature ofde#ndant 's attorney
Rey Dorta, Esq.
Printed name ofdefendant 's attorney
Judge 'sprintedname and title
Case 1:21-cr-20415-JLK   Document 1   Entered on FLSD Docket 08/05/2021   Page 8 of 8

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