Court filing

Exhibit E — USA v. Sheppard (Dkt. 83-5, S.D. Fla.)

Summary

Exhibit E to Document 83-5 in United States v. Sheppard, Case 1:22-cr-20290-BB, entered on the Southern District of Florida docket 09/15/2023, is a Justice Department press release of September 15, 2022 announcing that the South Florida U.S. Attorney's Office will lead one of three COVID-19 Fraud Strike Force Teams. The release says the district had charged 23 COVID-19 relief fraud cases in recent weeks, with "scheme amounts totaling over $150 million," had charged over 80 cases since the CARES Act and had seized over $23.5 million in stolen relief funds. Among the cases it lists, it states that Eric Dean Sheppard was charged by indictment with six counts of wire fraud and that the indictment alleges Sheppard obtained EIDL and PPP loan proceeds in excess of $900,000 through three entities.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Filed September 15, 2023 in USA v. Sheppard; one of 304 filings from this case.

Record facts

Court	U.S. District Court for the Southern District of Florida
Filed	2023-09-15

Cite this document

“Exhibit E — USA v. Sheppard (Dkt. 83-5, S.D. Fla.).” U.S. District Court for the Southern District of Florida, No. 1:22-cr-20290-BB, Doc. 83-5, filed 2023-09-15. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-eric-dean-sheppard-flsd-615773/2023-09-15-gov-uscourts-flsd-615773-83-5-doc-83-5/, SHA-256 1a3336083584bda7ef592cc10d580800dbf075e43b0b852362154588482e06f8.

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Full text

Case 1:22-cr-20290-BB Document 83-5 Entered on FLSD Docket 09/15/2023 Page 1 of 16
EXHIBIT “E”
Case 1:22-cr-20290-BB Document 83-5 Entered on FLSD Docket 09/15/2023 Page 2 of 16
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PRESS RELEASE

South Florida U.S. Attorney’s Office to Lead COVID-19 Fraud
Strike Force Team Against Pandemic Relief Fraud

Thursday, September 15, 2022

For Immediate Release

U.S. Attorney's Office, Southern District of Florida

More Than 20 Cases Recently Charged

MIAMI - Recognized as a leader in pandemic relief fraud prosecutions, the Southern District of
Florida’s U.S. Attorney’s Office has been selected to head one of three COVID-19 Fraud Strike
Force Teams nationally. In recent weeks alone, the district has charged 23 COVID-19 relief fraud
cases, with scheme amounts totaling over $150 million.

The Department of Justice established the Strike Force to enhance the department’s existing
efforts to combat and prevent COVID-19 related fraud.

“Over the years, the South Florida U.S. Attorney’s Office and its law enforcement partners have
developed robust domestic and international anti-fraud and money laundering practices.” said
Juan Antonio Gonzalez, U.S. Attorney for the Southern District of Florida. “Our experie’ )
these data-driven financial prosecutions allowed us to launch an early and aggressive a !
Case 1:22-cr-20290-BB Document 83-5 Entered on FLSD Docket 09/15/2023 Page 3 of 16
COVID-19 relief fraud by holding accountable those who tried to capitalize on an unprecedented
crisis. We are proud to have been selected to lead one of three COVID-19 Fraud Strike Force
Teams and look forward to continuing to advance this important Department of Justice effort.”

In total, the South Florida U.S. Attorney’s Office has charged over 80 cases since the CARES Act
was passed. It has seized over $23.5 million in stolen relief funds. The Strike Force Team will
build on this momentum.

“These Strike Force Teams will build on the Department’s historic enforcement efforts to deter,
detect, and disrupt pandemic fraud wherever it occurs,” said Attorney General Merrick B.
Garland. “Since the start of this pandemic, the Justice Department has seized over $1.2 billion in
relief funds that criminals were attempting to steal and charged over 1,500 defendants with
crimes in federal districts across the country, but our work is far from over. The Department will
continue to work relentlessly to combat pandemic fraud and hold accountable those who
perpetrate it.”

Anticipating the need to protect the integrity of these taxpayer funds and to otherwise protect
South Floridians from financial fraud related to the COVID-19 pandemic, the Southern District
of Florida established multiple efforts to identify, investigate, and prosecute such fraud. This
multifaceted approach has proven invaluable in going after those who have cheated the system.

“The Strike Force Teams are the latest example of the Justice Department’s commitment to
fight pandemic fraud,” said Associate Deputy Attorney General Kevin Chambers, who serves as
the department’s director for COVID-19 Fraud Enforcement. “The work being done by our
prosecutors, trial attorneys, agents and partners on our COVID-19 Fraud Enforcement Task
Force has been extraordinary. We're going a step further with the announcement of strike force
teams to support, enhance, and continue the great work being done across the department.”

“Our investigations of schemes to defraud federal pandemic relief programs have continued
and will continue even as the pandemic itself evolves,” said Federal Deposit Insurance
Corporation Office of Inspector General Special Agent in Charge Kyle A. Myles. “The cases
described in this announcement reflect collaboration with our law enforcement partners and
specific progress made in the fight to identify, investigate, and prosecute financial crime
affecting FDIC-insured institutions.”

The Southern District of Florida’s Strike Force Team will be comprised of dedicated
prosecutors, working together with agents from Department of Labor Office of Inspector
General, Small Business Administration Office of Inspector General, Federal Deposit Insurance
Corporation Office of Inspector General, Department of Homeland Security Office of Insr-ctor
General, FBI, U.S. Secret Service, Homeland Security Investigations, Internal Revenue

Criminal Investigations, U.S. Postal Inspection Service, Federal Reserve System C f
Case 1:22-cr-20290-BB Document 83-5 Entered on FLSD Docket 09/15/2023 Page 4 of 16
Inspector General, Treasury Inspector General for Tax Administration, and U.S. Coast Guard
Investigative Service. The Pandemic Response Accountability Committee and Special Inspector
General for Pandemic Recovery will assist the Strike Force.

“OIG stands firm in the fight to hold persons that commit fraud responsible in collaboration with
our law enforcement partners,” said SBA OIG’s Inspector General Hannibal M. Ware. “OIG
remains committed to rooting out bad actors and protecting the integrity of SBA programs
every day. | want to thank the U.S. Attorney’s Office and our law enforcement partners for their
dedication and pursuit of justice.”

A group effort is needed to address this problem and that is exactly what these agencies and
departments have committed to doing.

“This announcement is the culmination of hard work by numerous agencies,” said Wayne Rosen,
Assistant Special Agent in Charge, Miami Regional Office, Office of Inspector General for the
Board of Governors of the Federal Reserve System and the Bureau of Consumer Financial
Protection. “It sends a clear message that federal law enforcement is watching and will
relentlessly pursue fraudsters and bring them to justice. We are proud to work with our law
enforcement partners in this endeavor.”

Although these COVID-19 loan programs have ended, guilty parties should not get a false sense
of security. Their capture certainly remains a priority.

“The CARES Act provided vital funds to thousands of small businesses impacted by the COVID-
19 pandemic economic downturn,” said Jason J. Carley, Assistant Special Agent in Charge, FBI
Miami. “While those loan programs have ended, the FBI’s commitment to seeking out those who
defrauded the government continues. Millions of taxpayer dollars earmarked for CARES Act
programs were diverted away from the intended recipients by illegal activity. If you defrauded
these programs, know that our investigators will continue to follow the money right to your
doorstep.”

The actions of fraudsters have basically taken money from struggling people doing their best to
endure the pandemic.

“These defendants are alleged to have defrauded a program intended to assist hardworking
Americans who have been unfairly impacted as a result of this unprecedented and challenging
health crisis,” said Special Agent in Charge (SAC) Anthony Salisbury, HSI Miami. “HSI remains
committed to working with our law enforcement partners to bring every asset to bear against
anyone who seeks to take advantage of the pandemic to deliberately harm and deceive others
for their own profit.”

That fraudsters have taken advantage of a critical health situation only seems to bo
efforts to take them down.
Case 1:22-cr-20290-BB Document 83-5 Entered on FLSD Docket 09/15/2023 Page 5 of 16
“It is very unfortunate that criminals have seized on the COVID-19 pandemic as a money-making
opportunity and created fraudulent schemes to steal from federal programs designed to assist
law-abiding Americans,” said Matthew D. Line, Special Agent in Charge, IRS-Criminal
Investigation (IRS-Cl), Miami Field Office. “We continue relentlessly committed to working with
our law enforcement partners to aggressively pursue criminal investigations and hold crooks
accountable for fraudulently profiting from CARES Act programs.”

“The allegations in these matters are very disturbing,” said J. Russell George, Treasury Inspector
General for Tax Administration. “Exploiting some of the most vulnerable people in our society
will not be tolerated. The Treasury Inspector General for Tax Administration aggressively
investigates abuse of the Federal tax system. We are committed to working with our law
enforcement partners to ensure that those who endeavor to corrupt federal tax administration
are prosecuted to the fullest extent of the law.”

As much success as the agencies pursuing this type of criminal activity have had, there still
remains work to be done.

“An important mission of the U.S. Department of Labor, Office of Inspector General is to
investigate allegations of fraud related to the unemployment insurance program,” said Mathew
Broadhurst, Special Agent-in-Charge, Atlanta Region, U.S. Department of Labor, Office of
Inspector General. “The DOL-OIG fully supports the Department of Justice’s COVID-19 Strike
Force Team program. Through collaboration and leveraging of resources, the federal law
enforcement community has made great strides in holding COVID-19 fraudsters accountable
but there is more work to be done. We will continue to work closely with the U.S. Attorney’s
Office and our strike team partners to safeguard unemployment compensation benefit
programs for those who most need them.”

lt is a team effort that everyone should take pride in.

“The DHS Office of Inspector General thanks the U.S. Department of Justice and our law
enforcement partners for significant collaboration within the COVID-19 Fraud Strike Force,” said
Dr. Joseph V. Cuffari, Inspector General of the Department of Homeland Security. DHS OIG will
continue to investigate these crimes and to help ensure the integrity of DHS programs.”

Criminal enforcement in the Southern District of Florida to combat COVID-19/CARES Act-
related financial fraud schemes have proceeded on numerous fronts, including:

e Paycheck Protection Program (PPP) fraud: Prominent among the District’s efforts have
been cases involving attempts to obtain PPP loans through fraud. These loans were
intended to help small businesses financially survive the COVID-19 pandemic. The cases
charged in the district involve a range of conduct, from individual business owner” ‘ho
have inflated their payroll expenses to obtain larger loans than they otherwise wo
qualified for to serial fraudsters who revived dormant corporations and purchas 4
companies with no actual operations to apply for multiple loans. They then falsely stated
Case 1:22-cr-20290-BB Document 83-5 Entered on FLSD Docket 09/15/2023 Page 6 of 16
they had significant payroll to organized criminal networks submitting identical loan
applications and supporting documents under the names of different companies.

e Economic Injury Disaster Loans (EIDL) fraud: Another type of fraud charged in the district
has been fraud against the EIDL program, which was designed to provide loans to small
businesses, agricultural, and non-profit entities. Fraudsters have targeted the program by
applying for EIDL advances and loans on behalf of ineligible, newly-created shell or non-
existent businesses and diverting the funds for illegal purposes.

e Unemployment Insurance (UI) fraud: Due to the COVID-19 pandemic, more than $860

billion in federal funds has been appropriated for Ul benefits through September 2021.

People looking to exploit UI benefits during the pandemic use stolen identities to
fraudulently file for Ul benefits.

RECENT PROSECUTIONS

In recent weeks, the district has charged 23 COVID-19 relief fraud cases, with scheme amounts
totaling over $150 million. It is alleged that the defendants in these cases received over $35
million.

United States v. Hernandez, Case No. 22-mj-03333

The Southern District of Florida recently charged Daniel Hernandez, 50, a Market Manager for a
top national bank, with orchestrating a $30 million COVID-19 relief fraud scheme. According to
the criminal complaint affidavit, Hernandez - who oversaw 80 bank employees and more than
20 branches throughout South Florida - recruited bank customers and at least one former bank
employee to submit over 90 fraudulent PPP loan applications. It is alleged that Hernandez
advised the recruits on how to file the applications and what to include in them, then used his
position at the bank to ensure the fraudulent loans were reviewed and, when possible,
approved. The applications sought over $30 million in fraud proceeds. The investigation to
date has identified over $15 million in fraudulent loans issued.

In addition to Hernandez, the Southern District has charged others with participating in the
fraud. Willian Alexander Posada Sandrea pled guilty and is scheduled to be sentenced on
October 24, 2022 (22-cr-20194).

Armando De Leon, who worked at the bank with Hernandez, was charged with conspiracy to
commit wire fraud (22-20420-CR-KMM). Javier Alfonso Barata (22-mj-3095), and Alvaro
Enrique Castillo along with Douglas David Melean Socorro (22-mj-2928) have also been
charged.

FDIC-OIG, FBI Miami, SBA-OIG, and the Florida Department of Revenue investigated this matter.

Assistant U.S. Attorney Eli S. Rubin of the Southern District of Florida is prosecuting t
which charges Hernandez with conspiracy to commit bank fraud.
Case 1:22-cr-20290-BB Document 83-5 Entered on FLSD Docket 09/15/2023 Page 7 of 16
Assistant U.S. Attorney Joshua Paster is handling forfeiture.

United States v. Emile, Case No. 22-cr-60176

The Southern District recently charged Herbert Emile, 41, with participating in a $100 million
COVID-19 relief fraud scheme. In 2019, the FDIC-OIG began investigating a group of individuals
who were using shell companies, stolen personal identification information - including stolen
social security numbers-- and synthetic identities to commit fraud against several federally-
insured banks in the United States.

When the CARES Act was enacted in 2020, members of the conspiracy used their pre-
established shell companies to steal millions of dollars from the Act’s programs. In total,
members of this conspiracy and their associates are responsible for stealing over $100 million
from U.S. banks and PPP/CARES Act programs.

In addition to Emile, others were also charged in this district with participating in the fraud
scheme. These defendants have pled guilty: Hasan Hakim Brown, 46; Jean Renald Fleuridor, 42;
Raul Mauricio Gonzalez, 48; and Lorin George Saunders, 40.

FDIC-OIG and the United States Secret Service investigated the case. SBA-OIG and FBI Miami
assisted.

Assistant U.S. Attorney Brooke Watson is prosecuting the case.
United States v. Philossaint Case No. 22-cr-08336

United States v. Tollinchi, 22-cr-08337

United States v. Shazier, et al., 22-cr-08357

In cases alleging PPP fraud, EIDL fraud, and loan forgiveness application fraud, a South Florida
federal grand jury recently charged Joff Stenn Wroy Philossaint, 32, of Miramar, Florida; Mariel
Tollinchi, 35, of Miramar, Florida; Maurice Shazier, 50, of Fort Pierce, Florida; David Andre
Johnson, 52, of Lauderhill, Florida; Regine Marie Rene, 32, of Boynton Beach, Florida; and
Brianna Monique Gayle, 23, of Riviera Beach, Florida, with conspiring to commit wire fraud and
money laundering, as well as with aggravated identity theft. Philossaint also was charged with
obtaining U.S. citizenship through fraud.

It is alleged that Philossaint and Gayle, working through one of Philossaint’s businesses, worked
with others to prepare PPP and EIDL loan applications, as well as loan forgiveness applications,
on behalf of dozens of companies that falsely certified their number of employees, their
revenue, and their business expenses. As alleged, to support the EIDL and PP” xn
applications, and the PPP loan forgiveness applications, the defendants prepa

submitted fake IRS documents and created payroll accounts with a national payroll prov iF
Case 1:22-cr-20290-BB Document 83-5 Entered on FLSD Docket 09/15/2023 Page 8 of 16
company using stolen identities to make it appear that the companies had paid wages, which
they never did.

According to the allegations, Philossaint charged a kickback of 10 percent of the funded loans
and required others to disguise the kickback payments by splitting them into smaller amounts
and writing “advertising” on the memo lines of the checks.

It is alleged that Philossaint and his fiancée, Tollinchi, directly received PPP and EIDL loans of
nearly $500,000, in addition to kickback payments; Shazier received PPP and EIDL loans
totaling $873,328; Johnson received PPP and EIDL loans totaling $443,792; and Rene received
PPP and EIDL loans totaling $183,906. It is also alleged that the 26 companies for which
Philossaint and Gayle set up payroll processing received at least 33 PPP and EIDL loans
totaling more than $4.8 million.

SBA-OIG, U.S. Secret Service, FBI Miami, IRS-Cl Miami (West Palm Beach), and HSI Miami are
investigating the case. The West Palm Beach U.S. Attorney’s Office is prosecuting it.

United States v. Almaguer, et al., Case No. 22-cr-80118

According to the indictment, Defendants Leiner Pena Infante, Yandre Garcia Hernandez,
Eduardo Ramos Leyva and others gave Yunior Barrera Almaguer information about companies
they controlled so that Barrera could use the information to fraudulently apply for PPP loans.
The conspirators received approximately $8 million in PPP funds and spent much of the loan
proceeds for their personal use and benefit. After receiving the loans, the defendants named
above laundered the funds along with co-defendants Jorge S. Alvarez, Dariel Garcia Carmona,
and Jose Raul Amaro —-who had separately obtained their own fraudulent PPP loans, according
to the charges. FBI Miami investigated the case. Assistant U.S. Attorney Susan Osborne is
prosecuting the case.

United States v. Diaz, et al., Case No. 22-cr-20354

Aisladys Diaz, 45, of Miami, Florida, her daughter Ailensy Buron Diaz, 29, of Miami, Florida,
Berto Omar Rodriguez Fonseca, 33, of Cutler Bay, Florida, and husband and wife Yandys Diaz,
29, and Yainelis Perez Diaz, 33, of Hialeah, Florida, were charged in an indictment with
conspiracy to commit access device fraud, use of an unauthorized access device, aggravated
identity theft, conspiracy to commit wire fraud and wire fraud. According to allegations in the
indictment, in May 2020, Aisladys Diaz, a former aide employed at a nursing home in
Homestead, Florida, stole the personal identifying information (“PII”) of two elderly residents in
her care. The conspirators used the Pll of these elderly victims in several schemes including
one where a fraudulent Economic Disaster Injury Disaster Loan, an SBA loan under the CARES
Act was applied for. FBI Miami and TIGTA investigated the case. Assistant Unitec 3
Attorney Lois Foster-Steers is prosecuting it.
Case 1:22-cr-20290-BB Document 83-5 Entered on FLSD Docket 09/15/2023 Page 9 of 16
United States v. Ferguson, Case No. 22-cr-60164

Ego Ferguson, 53, of Pompano Beach, Florida, was charged by indictment with wire fraud and
engaging in financial transactions in criminally derived property. The indictment alleges that
Ferguson caused the preparation of false/fraudulent PPP loan applications on behalf of various
companies that falsely certified number of employees and employee payroll. As alleged,
Ferguson caused the submission of these fraudulent PPP loan applications to a loan processor
and Ferguson also provided fraudulent IRS forms that falsely indicated that these companies
had paid employee wages and taxes that the companies had not actually paid. The indictment
alleges that that Ego Ferguson charged a fee of twenty percent for these loans and that
Ferguson maintained a spreadsheet showing the submission of apparent PPP loans totaling
over S6 million. IRS-Cl Miami, FDIC-OIG, FRB and the U.S. Postal Inspection Service
investigated the case. Assistant U.S. Attorney Michael Berger is prosecuting the case.

United States v. Carrillo et al., Case No. 22-cr-20368

Kenia Carrillo, 45, Roberto Lopez, 50, Lester Hedman Safont, 51, Oreste Ruiz Linares, 51,
Honolio Navarro Caballero, 39, Barbara Alvarez, 44, Javier Pico, 56, Alfredo Contrera, 50, and
Erisbel Gonzalez Gomez, 43, have been charged by indictment with conspiracy to commit wire
fraud, wire fraud, conspiracy to commit money laundering, and money laundering. The
indictment charges that the group, and others, participated in a conspiracy to submit fraudulent
PPP applications and obtained over $2.6 million in fraudulent loan proceeds. Once they
obtained the money, instead of spending it on payroll and other permissible business expenses,
the group laundered the funds by issuing checks to each other to conceal the fraud. The U.S.
Secret Service and SBA-OIG, with the assistance of the Miami-Dade Police Department,
investigated the case. Assistant U.S. Attorney Thomas Haggerty is prosecuting it. Assistant U.S.
Attorney Peter Laserna is handling asset forfeiture.

United States v. Hermoso, Case No. 22-cr-20360

Maritza Morales Hermoso, 57, Miami, Florida, was charged by Indictment with conspiracy to
commit wire fraud, wire fraud, and money laundering. The Indictment charges that Hermoso
and others participated in a conspiracy to submit fraudulent PPP and EIDL applications and
obtained approximately $1.5 million in fraudulent loan proceeds. Specifically, the Indictment
charges that Hermoso submitted six PPP loan applications and two EIDL applications for eight
different businesses. The Indictment also alleges that once Hermoso obtained the loan
proceeds, instead of spending it on payroll and other permissible business expenses, she used
it for cosmetic surgery, gambling, and to buy a Cadillac. She often disguised her misuse of
funds by laundering the proceeds through multiple unrelated business accounts or
withdrawing the money in cash, it is alleged. U.S. Secret Service and the SBA-OIG inves’” —-+d
the case. Assistant U.S. Attorney Joseph Egozi is prosecuting it.
Case 1:22-cr-20290-BB Document 83-5 Entered on FLSD Docket 09/15/2023 Page 10 of 16
United States v. Joseph, Case No. 22-cr-60162

Sherry Joseph, 33, of New York, was charged by indictment with wire fraud conspiracy and wire
fraud. The indictment alleges that Joseph, while on federal pretrial release in a separate case in
the District of New Jersey, participated in a conspiracy to submit millions of dollars of
fraudulent PPP loan applications. Specifically, the indictment alleges that Joseph used aliases
to hide her identity while coordinating between the scheme ringleader and several individuals
she recruited to seek fraudulent PPP loans through the scheme. Joseph also demanded and
received kickbacks from recruits who received fraudulent PPP loans through the scheme, it is
alleged. IRS-Cl Miami investigated the case. Assistant U.S. Attorney Kiran N. Bhat and
Department of Justice (DOJ) Trial Attorney Philip B. Trout are prosecuting it.

United States v. Sheppard, Case No. 22-cr-20290

Eric Dean Sheppard, 53, of Bal Harbour, Florida, was charged by indictment with six counts of
wire fraud. The indictment alleges that Sheppard, through three different entities that he
controlled, applied for and obtained EIDL and PPP loan proceeds in excess of $900,000. He
falsified tax forms and misrepresented the borrowing entities’ revenues, monthly payroll, and
numbers of employees. FBI Miami investigated the case. Assistant U.S. Attorney Marty
Fulgueira Elfenbein is prosecuting it.

United States v. Jacquez, Case No. 22-cr-60171

Florencio Jacquez, 41, of Cape Coral, Florida, was charged by information with conspiracy to
commit wire fraud. The information against Jacquez alleges that Jacquez participated in a
conspiracy to submit millions of dollars in fraudulent PPP loan applications. Specifically, the
information alleges that Jacquez received a fraudulent PPP loan of $801,250 for his own
company, Next Auto Body, LLC. The U.S. Secret Service, IRS-Cl Miami, and SBA-OIG
investigated the case. Assistant U.S. Attorney Amanda Perwin is prosecuting it.

United States v. Harricharan, Case No. 22-cr-60173

Keegan Harricharan, 39, of Coral Springs, Florida, was charged by information with conspiracy
to commit wire fraud. The information against Harricharan alleges that Harricharan
participated in a conspiracy to submit millions of dollars in fraudulent PPP loan applications.

Specifically, the information alleges that Harricharan received a fraudulent PPP loan of
$840,827 for his own company, World Scientific Industrial and Medical, Inc. The U.S. Secret
Service, IRS-Cl Miami, FB! Miami, and SBA-OIG investigated the case. Assistant U.S. Attorney
Amanda Perwin is prosecuting it.

United States v. Sales, Case No. 22-cr-60172
Case 1:22-cr-20290-BB Document 83-5 Entered on FLSD Docket 09/15/2023 Page 11 of 16
Abdolrahman Sales, 26, of Lake Elsinore, California, was charged by information and pled guilty
to conspiracy to commit an offense against the United States. He is scheduled to be sentenced
on November 7, 2022, before Judge William P. Dimitrouleas of the United States District Court
for the Southern District of Florida. In pleading guilty, Sales admitted that he participated in a
conspiracy to obtain a fraudulent PPP loan. Specifically, Sales admitted that he received a
fraudulent PPP loan of $407,727 for his company, Kyng Simba, Inc. His loan application
included falsified bank statements and payroll tax forms that overrepresented the company’s
number of employees and monthly payroll. Sales also admitted that he paid kickbacks to co-
conspirators for their roles in helping him obtain this fraudulent PPP loan. IRS-Cl Miami
investigated the case. Assistant U.S. Attorney Kiran N. Bhat and DOJ Trial Attorney Philip B.
Trout are prosecuting it.

United States v. Kelly, Case No. 22-cr-20168

Randy Kelly, 35, of Miami, was charged by information and pled guilty to conspiracy to commit
an offense against the United States. He was sentenced August 19, 2022, before Judge Robert
N. Scola of the United States District Court for the Southern District of Florida. In pleading
guilty, Kelly admitted that he participated in a conspiracy to obtain a fraudulent PPP loan.
Specifically, Kelly admitted that he received a fraudulent PPP loan of $495,822 for his
company, Connected Forever LLC, after submitting a loan application that included falsified
bank statements and payroll tax forms that overrepresented the company’s number of
employees and monthly payroll. Kelly also admitted that he paid kickbacks to a co-conspirator
who helped obtain this fraudulent PPP loan. IRS-Cl Miami and FBI Miami investigated the case.
Assistant U.S. Attorney Kiran N. Bhat and DOJ Trial Attorney Philip B. Trout prosecuted it.

United States v. Rojas, Case No. 22-cr-20364

Yadira Escobar Rojas, 34, of Homestead, Florida, was charged by information with wire fraud.

The information alleges that Escobar Rojas submitted two false and fraudulent EIDL
applications and one false and fraudulent PPP loan application on behalf of two different
entities she controlled, Los Molinos Trucking, Inc. and Molino Fish Inc. She received over
$495,000 in fraud proceeds. FBI Miami investigated the case. Assistant U.S. Attorney Eli S.
Rubin is prosecuting it.

United States v. Floradin, Case No. 22-cr-20361

Elie Floradin, 59, of Miami, Florida, was charged by indictment with wire fraud and money
laundering in connection with the alleged repeated submission of fraudulent Paycheck
Protection Program (“PPP”) applications on behalf of his purported hiring agency business,
You’re Hired Employment Agency, LLC (“You’re Hired”). The indictment alleges that, ir "uly
2020, Floradin caused the submission of a false and fraudulent PPP application on f :
You’re Hired, which resulted in the disbursement of approximately $199,999 in federal
Case 1:22-cr-20290-BB Document 83-5 Entered on FLSD Docket 09/15/2023 Page 12 of 16
19 assistance funds directly into Floradin’s personal bank account. Shortly thereafter, the
government alleges that Floradin transferred approximately $177,000 of those funds into a
different account that he controlled, knowing that the PPP funds were derived from unlawful
activity. The indictment further alleges that Floradin then filed multiple (unsuccessful) “second
draw” applications, attempting to once again fraudulently obtain COVID-19 assistance funds in
the year 2021, including through the use of falsified federal tax forms, all in an effort to
continue to enrich himself and others. TIGTA and the Florida Office of Financial Regulations
investigated the case. Assistant United States Attorney Eduardo Gardea, Jr., is prosecuting it.

United States v. 1zzo, Case No. 22-cr-60155

Jennifer Pamela Izzo, 34, of Coral Springs, Florida, was charged by indictment with wire fraud
and aggravated identity theft for her alleged months-long embezzlement scheme against her
former employer’s company, through which she misappropriated company funds and attempted
to personally enrich herself from a COVID-relief loan submitted on behalf of the Broward-based
company. The indictment charges that from October 2019 to April 2020, Izzo abused her
position as the company’s bookkeeper and accounts payable clerk by creating fictitious
accounts in the names of the company’s real vendors, to carry out fraudulent charges using the
company’s credit cards, ultimately funneling the funds into her own personal bank account.
The indictment further charges that Izzo abused her position by filing an Economic Injury
Disaster Loan, which she had been asked to file on behalf of the company to apply for federal
COVID-assistance funds, but which she submitted with her own personal bank account
information to personally enrich herself. The U.S. Secret Service and the Fort Lauderdale Police
Department investigated the case. Assistant United States Attorney Eduardo Gardea, Jr. is
prosecuting it.

United States v. Hyppolite, Case No. 22-cr-20394

Mackinson Hyppolite, 33, of Miami, was charged by indictment with using someone else’s
identity to fraudulently apply to the U.S. Small Business Administration (“SBA”) for a COVID-19
relief advance grant and low-interest Economic Injury Disaster Loan (“EIDL”) loan for a company
to which Hyppolite had no connection. According to the indictment, the loan application falsely
certified, among other things, that an individual named “D.A.” owned the company and had
suffered economic injury due to the COVID-19 pandemic. In reality, Hyppolite, not D.A., filed the
application and neither Hyppolite nor D.A. had any relationship to the company. The indictment
alleges that Hyppolite possessed and used D.A.’s personal identifying information without her
knowledge or authorization, including her social security number. As a result of the fraudulent
application, the SBA preapproved Hyppolite for a $26,600 federal loan.

The Indictment charges Hyppolite with one count of wire fraud, one count of access 7e
fraud, and three counts of aggravated identity theft. The Office of Treasury Inspector
for Tax Administration (TIGTA) and FBI Miami investigated the case. Assistant U.S. Attori. tl
Case 1:22-cr-20290-BB Document 83-5 Entered on FLSD Docket 09/15/2023 Page 13 of 16
J. Rosenzweig is prosecuting the case. Assistant U.S. Attorney Peter Laserna is handling asset
forfeiture.

United States v. Potokri, Case No. 22-cr-60147

Obukowho Potokri, 36, of Fort Lauderdale, Florida, was charged by indictment with theft of
government funds. Potokri is alleged to have fraudulently received unemployment insurance
benefits that were issued to an individual named “D.M.” The Department of Labor Office of
Inspector General investigated the case. Assistant U.S. Attorney Karla Albite of the Southern
District of Florida is prosecuting the case. Assistant U.S. Attorney Joshua Paster is handling
forfeiture.

United States v. Hilaire, Case No. 22-cr-60175

Chirac Hilaire, 41, of Broward County, Florida, was charged by indictment with wire fraud and
money laundering. The indictment against Hilaire alleges that Hilaire participated in the
submission of several fraudulent EIDL and PPP loan applications. Specifically, the indictment
alleges that Hilaire received fraudulent PPP loan proceeds amounting to approximately
$150,000 for his own company, Hilaire LLC. FBI Miami investigated the case. Assistant U.S.
Attorney Lauren A. Astigarraga is prosecuting it.

United States v. Sarmiento Carrion, Case No. 22-mj-03412

Yoliesse Sarmiento, 39, of Miami, Florida, has been charged by criminal complaint with bank
fraud. Sarmiento conspired with others to file a fraudulent PPP loan application. In May of
2020, he re-instated a company that had been dissolved in 2019 and listed himself as the sole
officer of the company. Two weeks later, a co-conspirator submitted a fraudulent PPP loan
application for the company and included a forged bank statement with the application.
Sarmiento received $255,000 in PPP funds and, over two weeks, depleted the entirety of the
funds. The U.S. Secret Service and SBA-OIG, with the assistance of the Miami-Dade Police
Department, investigated the case. Assistant U.S. Attorney Thomas Haggerty is prosecuting it.
Assistant U.S. Attorney Peter Laserna is handling asset forfeiture.

PLEASE NOTE: Criminal complaints, informations, and indictments contain mere allegations
and all defendants are presumed innocent until proven guilty beyond a reasonable doubt in a
court of law.

HHH

Contact
Public Affairs Unit
U.S. Attorney’s Office
Case 1:22-cr-20290-BB Document 83-5 Entered on FLSD Docket 09/15/2023 Page 14 of 16
Southern District of Florida
USAFLS.News@usdoj.gov

Updated September 15, 2022

Topics

CORONAVIRUS DISASTER FRAUD

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USAO -Florida, Southern

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