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Home Court filings United States v. Eric Dean Sheppard — S.D. Fla., No. 1:22-cr-20290-BB MOTION for Acquittal by Eric Dean Sheppard. Responses due by 1/2/2024 — USA v. SHEPPARD…

Court filing

MOTION for Acquittal by Eric Dean Sheppard. Responses due by 1/2/2024 — USA v. SHEPPARD (Dkt. 162)

Record facts

CourtU.S. District Court for the Southern District of Florida
Filed2023-12-17

U.S. District Court for the Southern District of Florida · No. 1:22-cr-20290-BB · Doc. 162 · 2023-12-17 · Docket on CourtListener

Summary

A memorandum of law supporting a motion for judgment of acquittal under Fed. R. Crim. P. 29, filed by the defendant in USA v. Sheppard, Case No. 22-20290-CR-BLOOM/OTAZO-REYES, in the U.S. District Court for the Southern District of Florida, entered on the docket December 17, 2023 as Document 162. The memorandum recounts that a superseding indictment filed August 24, 2023 grouped the wire fraud counts by loan application and added counts of aggravated identity theft based on five documents said to carry signatures of other persons. It argues under Dubin v. United States, 599 U.S. 110 (2023) that a means of identification must be at the crux of the criminality, and that the documents at issue were not required as part of the loan applications. It also argues that the evidence at trial did not show an intent to defraud the lenders. The filing runs 20 pages.

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FORIDA 
CASE No. 22-20290-CR-BLOOM/OTAZO-REYES 
 
UNITES STATES OF AMERICA, 
 
Plaintiff,  
v.  
ERIC DEAN SHEPPARD, 
 
Defendant. 
____________________________________/ 
DEFENDANT’S MEMORANDUM OF LAW IN SUPPORT OF RULE 29 MOTION FOR 
JUDGMENT OF ACQUITTAL  
 
The Defendant Eric Dean Sheppard submits this Memorandum of Law in support of his 
Rule 29 Motion for Judgment of Acquittal, pursuant to Fed. R. Crim. P. 29, and states:  
BACKGROUND 
Mr. Sheppard was charged in June of 2022 with six counts of Wire Fraud, one count for 
each of the six different loan applications he allegedly applied for through three different 
companies. On August 24, 2023, the Government filed a Superseding Indictment, drastically 
changing the charges against Mr. Sheppard. It charged Mr. Sheppard with six additional Wire 
Fraud counts which were deliberately not charged for an entire year since the original Indictment. 
[D.E. 60 at 7]. Instead of having one count for each of the six loan applications, the Government 
chose to only prosecute three loan applications, but added several counts related to each loan: 
Counts 1-3 relate to the electronic submission of the HM Four’s EIDL loan application, and two 
documents submitted in support of that loan; Counts 4-8 relate to the electronic submissions of 
HM UP Development Alfaya Trails LLC’s (“Alafaya Trails”) PPP loan application, and four 
documents submitted in support of that loan; and Count 9 relates to the electronic submission of 
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HM Management and Development’s (“HMMD”) PPP loan application. Id. Additionally, the 
Government charged Mr. Sheppard with five additional counts of Aggravated Identify Theft, 
which it also deliberately did not include in the original Indictment. In support of their counts for 
Aggravated Identity Theft, the Government contends that Mr. Sheppard forged signatures of other 
persons for five documents submitted in support of the different loan applications. Id. at 8. The 
five documents the Government claims were forged include:  
- 
3 Form 1065 tax returns allegedly submitted in connection with Alafaya Trails’ PPP 
second draw loan application and HMMD’s PPP loan application where the alleged 
identity theft resulted from inserting the name, signature and Preparer Tax 
Identification Number of an accountant at the Cupersmith accounting firm (the “Tax 
Returns”); 
- 
 a lease agreement submitted along with HM Four’s EIDL application, on which the 
Government claims the name, signature and title of the tenant’s representative was 
falsely included (the “Lease”); and 
- 
a letter from a bank to Defendant submitted along with HM Four’s EIDL where the 
Government claims the name, signature and title of the bank employee were falsified 
(the “Bank Letter”). 
Id. at 8.  
For Mr. Sheppard to be convicted of Aggravated Identity Theft, the Government must have 
shown that “the defendant's misuse of another person's means of identification is at the crux of 
what makes the underlying offense criminal.” Dubin v. United States, 599 U.S. 110, 114 (2023) 
(emphasis added).  “In other words, the means of identification specifically is a key mover in the 
criminality[,]” “the locus of [the criminal] undertaking,” rather than merely “passive,” “passing,” 
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or ancillary employment in a crime. Id. at 122-23. The Court clarified that “being at the crux of 
the criminality requires more than a causal relationship, such as ‘facilitation’ of the offense or 
being a but-for cause of its ‘success.’” Id. at 131. The Government failed to do just that.  
During trial, the evidence was consistent: the accountant’s name, signature, and Preparer 
Tax Identification Number was not required for the Tax Returns and was thus immaterial. 
[11.28.23 Trial Tr. 99:23-100:4 (Althea Harris SBA); 11.29.23 AM Trial Tr. 67:21-68:11 (Phillip 
Palmer IRS); 11.30.23 PM Trial Tr. 85:14-86:2 (Jamie Hutchinson PayPal); 12.05.23 AM Trial 
Tr. 50-51 (David Toye Northeast); 12.05.23 PM Trial Tr. 112-113 (Spencer Lord Cross River 
Bank)]. Similarly, the identification of the banker in the Bank Letter and the Tenant on the Lease 
were not material. [12.14.23 Trial Tr. 47-49, 58-59 (Brent Motes SBA)]. As such, the means of 
identification which form the Aggravated Identity Theft charges were not the crux or the key 
mover of the alleged crime and therefore, acquittal is required. Irrespective of the identification, 
there was also no evidence presented at trial for the jury to conclude that the documents themselves 
(the Tax Returns, Lease and Bank Letter) were necessary or required to be submitted as part of the 
loan applications, and therefore, they were not the crux or key mover of the crime. [11.30.23 PM 
Trial Tr. 75:12-76:11, 90:11-91:1, 98:5-99:10, 99:19-100:2 (Jamie Hutchinson PayPal); 12.05.23 
AM Trial Tr. 54 (David Toye Northeast); 12.05.23 PM Trial Tr. 78, 110-111 (Spencer Lord Cross 
River Bank)]. Similarly, the Bank Letter and the Lease were not requested by the SBA nor required 
as part of the SBA loan applications. [12.14.23 Trial Tr. 41-42, 54-57 (Brent Motes SBA)]. In 
other words, the alleged falsification of these documents, even if true, does not serve to prove the 
crime of Aggravated Identity Theft, because, as discussed in detail below, the alleged instances of 
identity theft were not material in the commission of the charged wire fraud. As such, acquittal of 
the Aggravated Identity Theft charges is required on this basis as well.   
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Finally, acquittal of Wire Fraud Counts 4-9, related to the PPP loan applications, is 
appropriate as well because the Government failed to show that Mr. Sheppard intended to cause 
an economic injury or loss to the alleged victims, here, the Banks. See United States v. Takhalov, 
827 F.3d 1307, 1312 (11th Cir. 2016), as revised (Oct. 3, 2016), opinion modified on denial of 
reh'g, 838 F.3d 1168 (11th Cir. 2016) (“to defraud, one must intend to use deception to cause some 
injury”). The testimony presented at trial demonstrates the contrary: Mr. Sheppard intended to be 
compliant1 and the Banks suffered no harm. The PPP loans were fully guaranteed by the 
Government. [11.28.23 Trial Tr. 91 (Althea Harris SBA)].  If the loan proceeds were used 
according to the Rules, it was 100% forgivable and if the Government didn’t forgive the loan, it 
was paid back in five years at 1% interest. [11.28.23 Trial Tr. 76, 78 (Althea Harris SBA)]. The 
victims here, the Banks, could not have suffered any harm and instead, got exactly what they 
bargained for and therefore, acquittal as to the Wire Fraud charges related to the PPP loans is 
appropriate as well.  
ARGUMENT 
I. 
Legal Standard. 
“Federal Rule of Criminal Procedure 29 provides that a defendant is entitled to a judgment 
of acquittal if ‘the evidence is insufficient to sustain a conviction.’” United States v. Moore, 76 
F.4th 1355, 1363 (11th Cir. 2023) quoting Fed. R. Crim. P. 29(a). “When deciding a motion under 
Rule 29, the district court must determine ‘whether the evidence, examined in a light most 
favorable to the Government, was sufficient to support the jury's conclusion that the defendant was 
guilty beyond a reasonable doubt.’” United States v. Fraser, 18-CR-60021, 2018 WL 11251001, 
 
1 For example, as evidenced by Government Exhibit 50-7 at bates 34481-34483, which contains 
an email from Defendant to Graff asking for assurance that everything was filed properly.   
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at *1 (S.D. Fla. July 9, 2018) quoting United States v. Williams, 390 F.3d 1319, 1323–24 (11th 
Cir. 2004). “Thus, the test is whether a reasonable jury could find, beyond a reasonable doubt, that 
Defendant is guilty of violating the crimes alleged in the indictment.” Id. quoting United States v. 
Macko, 994 F.2d 1526, 1532 (11th Cir. 1993) 
II. 
The Government Failed to Provide Evidence of Aggravated Identity Theft. 
To convict Mr. Sheppard of aggravated identity theft, the government needed to prove that 
he (1) knowingly transferred, possessed, or used, (2) without lawful authority, (3) a means of 
identification of another person or a false identification document (4) during and in relation to the 
wire fraud offense. See United States v. Bonilla, 579 F.3d 1233, 1242 (11th Cir. 2009); United 
States v. Presendieu, 880 F.3d 1228, 1240 (11th Cir. 2018) (“To convict for aggravated identity 
theft, the government must prove that the defendant: (1) knowingly transferred, possessed, or used; 
(2) the means of identification of another person; (3) without lawful authority; (4) during and in 
relation to a felony enumerated in 18 U.S.C. § 1028A(c).”).  
In an effort to curb prosecutorial overreach in applying this statute, the Supreme Court 
recently severely limited the application of the Aggravated Identity Theft statute in Dubin v. United 
States, 599 U.S. 110 (2023), and specifically clarified what it means to “use” the means of 
identification of another in the commission of a felony. Justice Sotomayor who authored the 
opinion, clarified that “§ 1028A(a)(1) is violated when the defendant's misuse of another person's 
means of identification is at the crux of what makes the underlying offense criminal.” Id. at 114 
(emphasis added). “In other words, the means of identification specifically is a key mover in the 
criminality[,]” “the locus of [the criminal] undertaking,” rather than merely “passive,” “passing,” 
or ancillary employment in a crime. Id. at 122-23. The Court clarified that “being at the crux of 
the criminality requires more than a causal relationship, such as ‘facilitation’ of the offense or 
being a but-for cause of its ‘success.’” Id. at 131.   
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Ultimately, the Supreme Court reversed the conviction of Healthcare Fraud and 
Aggravated Identity Theft under § 1028A(a)(1) of a defendant who had overbilled the Medicaid 
program by inflating the value of the services provided to patients. Dubin, 599 U.S. at 114-15. In 
submitting for reimbursement, the defendant included the patient's Medicaid reimbursement 
number, a means of identification. Id. at 115. However, this “use” of the patient’s information in 
submitting for reimbursement is not sufficient to satisfy § 1028A(a)(1). The Dubin Court held that 
the words “use” and “in relation to” in § 1028A should not be construed so that the provision 
would “apply automatically any time a name or other means of identification happens to be part 
of the payment or billing method used in the commission of a long list of predicate offenses.” See 
Dubin, 599 U.S. at 117.   The Government’s broad position was that any misuse of identification- 
whether ancillary to the underlying predicate offense, meets the requirement that there be a true 
causal relationship—a genuine nexus - between the misuse of the identification and the underlying 
crime.  The Court disagreed and held that § 1028A applies2 where there is “a genuine nexus” 
between the use of a means of identification and a predicate offense. See Dubin, 599 U.S. at 177. 
A genuine nexus requires that the means of identification be “a key mover in the criminality.” 
Dubin, 599 U.S. at 122-23.  The Court explained that it is not whether the information was used 
that is important to the analysis, but “what the defendant does with the means of identification in 
particular.” Id.  The Court found that the fraud involved “how and when services were provided 
to a patient, not who received the services”; hence, the identity of the individuals was not the crux 
of the crime. Id.  The focus should be on whether “identity” of the victim has been stolen or 
misappropriated. In making the distinction, the Court have examples of the conduct that it would 
 
2 The Court also notes that the very title of § 1028A including the word “Aggravated” suggests 
that Congress had in mind a particularly serious form of identity theft, not just all manner of 
everyday billing. Id. at 120-22. 
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not consider aggravated identity theft, but which would meet the Government’s broad 
interpretation: 
If a lawyer rounds up her hours from 2.9 to 3 and bills her client 
using his name, the name itself is not specifically a source of fraud; 
it only plays an ancillary role in the billing process. The same is true 
for the waiter who substitutes one cut of meat for another; we might 
say the filet mignon's identity was stolen, perhaps, but not the 
diner's. 
*** 
Take an ambulance service that actually transported patients but 
inflated the number of miles driven. The crux of this fraud was 
“how” services were rendered; the patients’ names were part of the 
billing process, but ancillary to what made the conduct fraudulent. 
In contrast, take the pharmacist who swipes information from the 
pharmacy's files and uses it to open a bank account in a patient's 
name. That “misuse of th[e] means of identification” would be 
“integral to” what made the conduct fraudulent, because 
misrepresentation about who was involved was at the crux of the 
fraud. 
Id. at 114-17.  
As this Court explained, “Dubin stands for the proposition that § 1028A does not 
automatically apply merely where a means of identification is used in the commission of an 
underlying crime.” United States v. Sheppard, 22-CR-20290, 2023 WL 7157874, at *4–5 (S.D. 
Fla. Oct. 31, 2023).  However, this Court’s opinion was based on the mere allegations in the 
Superseding Indictment for purposes of considering a Motion to Dismiss before the Court.  At this 
juncture, the Court has now had the benefit of hearing the evidence that, in fact, the alleged 
fraudulent documents were at best merely ancillary to the alleged wire fraud. The undisputed 
evidence before this Court is that the documents at issue of misuse of an identification were not 
even required to be signed and therefore, the Governments allegation of their forgery is misplaced. 
At best, the alleged forgeries are ancillary or incidental to the underlying alleged crime.  Therefore, 
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contrary to the government’s argument on the Motion to Dismiss, there has been no evidence 
before this Court that the Defendant fabricated these alleged forgeries, and thus, this Court should 
no longer rely on Gladden.  The question is not whether unauthorized identification was used, or 
fabricated, but whether the unauthorized identification used was the “key mover” in the underlying 
criminal conduct alleged; here, wire fraud alleged to have occurred in connection with submission 
of the loan applications.  Id. In other words, was the purpose of the crime to steal someone’s 
identity for a nefarious purpose or was the use of the identifying information just incidental to the 
alleged crime.  The alleged misuses of identification in this case is completely analogous to those 
in Dubin.  In fact, Justice Sotomayor explains certain examples of “classic identity theft” the statute 
was meant to protect: 
There is ‘the defendant [who] has gone through someone else’s trash 
to find discarded credit card and bank statements,’ ibid., and thus 
has taken possession unlawfully. There is the bank employee who  
passes along customer information to an accomplice, and  thus  
transfers it unlawfully. Then there is use involving fraud or deceit 
about identity: “a defendant [who] has used  another person’s 
identification information to get access to that person’s bank 
account.” Ibid. 
Dubin, 599 U.S. at 126. Here, it is clear that there was never an intent to steal someone’s identity 
in the traditional sense.  
In reversing the 5th Circuit and the trial court, the Supreme Court held that Dubin’s use of 
the patient information was not the key mover of the crime of Medicaid fraud, because the patient’s 
identification was not stolen in a traditional sense, and “not the crux of what made the 
underlying overbilling fraudulent”. Id. at 132 (emphasis added). Instead, what makes the 
overbilling fraudulent was the inflation of the price and services, not the use of the patient’s 
information in submitting bills for reimbursement. Dubin asks courts to look at more than just the 
unauthorized use, but whether a victim’s identity was stolen to perpetrate a crime. Thus, the 
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patients whose identity was allegedly stolen in Dubin were not the victims of the crime and using 
their information was merely incidental to the crime whose object was to defraud Medicaid. As in 
Dubin, the identity allegedly stolen here was, at best, merely incidental to the crime. For that 
reason, under Dubin, the alleged crime is not traditional identity theft, and the Government has 
failed to prove the crime of Aggravated Identity Theft as a matter of law.   
Two recent 11th Circuit decisions help us understand this distinction: United States v. 
Detling, 22-10630, 2023 WL 6060576, at *1 (11th Cir. Sept. 18, 2023); United States v. Gladden, 
78 F.4th 1232, 1245 (11th Cir. 2023).  
In Detling, the defendant attorney forged his clients’ authorization in obtaining litigation 
funding loans without his clients’ permission, thereby stealing his clients’ identity and defrauding 
the litigation funding company into believing that the clients’ authorized the transaction. The 
lawyer in Detling stole his client’s identity and falsely represented that his client approved the 
transaction, and directly damaged his client by incurring a substantial debt that his client’s 
litigation assets would be now responsible for paying without said client’s approval.  Thus, unlike 
here, Detling involved actual identity theft and the crux of the crime was stealing the client’s 
identity to defraud said client. Unlike in Detling, here, the loans would have been funded 
irrespective of the accountant’s signature on the Tax Returns, the banker’s signature on the Bank 
Letter, or the tenant’s signature on the lease because the identities and signatures of those persons 
were immaterial, and, clearly those documents were not the “crux” of the loan applications, under 
the definition set forth in Dubin. 
In Gladden, defendant Linton falsified prescription requests on behalf of patients who were 
supposedly continuously refilling their prescriptions, but never received the drugs, which went to 
the defendant. In such a circumstance, “[b]ecause the deception centered on the identity of the 
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individual receiving the product [the patient], Linton committed identity theft.”  Gladden, 78 F.4th 
at 1245 citing Dubin, 143 S.Ct. at 1568 (“This central role played by the means of identification, 
which serves to designate a specific person’s identity, explains why we say that the ‘identity’ itself 
has been stolen.”). There, the defendant’s forgeries were at the heart of the deception because the 
defendant used the identities of others to continue refilling prescriptions in their names, even 
though they were neither aware of nor received any drugs. The identity of the patients and doctor 
was what enabled Linton to fill the prescriptions, which is why the court concluded that “the means 
of identification specifically [was] a key mover in the criminality.” Id. at 1244. In contrast, the 
court there ruled that defendant Gladden could not be guilty of identity theft under the standards 
articulated in Dubin, and vacated his conviction. Id. at 1248-49. That was because the only 
deception regarding a prescription obtained for a minor child was whether the prescription was 
medically necessary: “[t]he use of [the] identifying information was merely ancillary to the 
deception; indeed, at no point did [the defendant] [] misrepresent who received the prescriptions. 
. . .”. Id.  
In both Gladden and Detling the alleged use of the identity is what resulted in the crime.  
In both these cases, the identity of a person was stolen to show that such person falsely authorized 
the conduct or was falsely due to receive a benefit, and, therefore, necessary to the commission of 
the charged crime. In Detling, the clients’ authorization in obtaining litigation funding loans was 
necessary in obtaining the loan. Similarly, in Gladden, the patient and doctor’s identifying 
information was necessary to fill the prescriptions. On the other hand, in Dubin, although the 
identity of the patients was used in the overbilling, the identity of the patients was not necessary 
to the charged crime, nor where the patients the victim of a deceitful use of their identity. 
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Here, under the purview of Dubin, the identity of a person was not “stolen” as it was not 
necessary to constitute an unauthorized use that was the crux of the alleged criminal activity. 
Notably, the so called “victims” whose identity was supposedly used, were not necessary or 
required for the commission of the alleged wire fraud in securing the loans, as the patients in 
Gladden or the clients in Detling were. Instead, in the case at bar, there is absolutely no evidence 
that the use of the identity of the CPA in the Tax Returns, the Banker in the Bank Letter, or the 
Tenant in the Lease were the “crux” or “key mover” of the crime.  
In fact, even the most favorable view of the evidence presented shows that the 
identifications were irrelevant. The alleged deception here did not center around the identity of the 
individuals nor did it directly enable Mr. Sheppard to continue the alleged scheme of the approval 
of the loan applications. This point is made even more clear by the evidence presented at trial, 
where the identities of the individuals were irrelevant.  
As to the Tax Returns, Althea Harris from the SBA testified that the Tax Returns did not 
have to have the name of the accountant because not everyone has an accountant who prepares 
their taxes. [11.28.23 Trial Tr. 99:23-100:4]. Phillip Palmer from the IRS also testified that he 
reviewed the tax returns in this case and agreed that you don’t necessarily need an accountant to 
fill our or send in tax returns. [11.29.23 AM Trial Tr. 67:21-68:11]. Jamie Hutchinson from PayPal 
testified that the Tax Returns accepted by PayPal for the PPP loan didn’t need the name or any 
information of an accountant on it. [11.30.23 PM Trial Tr. 85:14-86:2]. In fact, she testified, PayPal 
relies on tax returns submitted, whether or not there’s a name, signature, or PTIN number. [Id.]. 
Similarly, David Toye from Northeast Bank testified that if a tax return was submitted, it did not 
have to be signed by a CPA; there was no requirement that it needed to be signed by a tax preparer 
or that it be prepared by a tax preparer. [12.05.23 AM Trial Tr. 50-51]. In fact, the tax return 
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submitted could be a copy without the preparer’s name on it. [12.05.23 AM Trial Tr. 51-52]. 
Finally, Spencer Lord at Cross River Bank testified that if Cross River ever needed tax returns, it 
didn’t require any information from a CPA; the signature and PTIN number on the Tax Returns 
could have been blank. [12.05.23 PM Trial Tr. 112-113]. This was partially because some people 
file without CPA’s and partially because the bank knows they are getting copies of the tax returns, 
not the originals, which don’t need to have that information. [12.05.23 PM Trial Tr. 113]. 
As to the Bank Letter and Lease Agreement, Brent Montes from the SBA testified that 
there was no request for a bank letter so there wouldn’t be a request for any specific name of a 
specific individual at a bank. [12.14.23 PM Trial Tr. 58-59].  Moreover, the bank letter was 
ignored- and they continued to request a bank statement. [Id. at 56-57].  Additionally, he testified 
that the SBA wasn’t checking to see whether the tenant was a real person – the SBA wasn’t 
checking the identity of the signer for the tenant and that the name of tenant wasn’t the critical 
aspect or crux of the loan application. [Id. at 47-49]. It is therefore clear from the testimony 
presented at trial that since the identities of the individuals were immaterial, irrelevant, and not 
critical, it cannot be said that they were  at the “crux” of the crime. See Dubin, 599 U.S. at 132 
(finding that the identity of the individuals whose identity is allegedly stolen has to be used to 
commit the underlying crime). 
Moreover, irrespective of the identities of the individuals, the documents relied upon by 
the Government as constituting identity theft where neither necessary nor required as part of the 
loan applications at issue. Consequently, the documents that evidence the alleged identity theft 
were not the “crux of the commission of the alleged crime. Accordingly, it cannot be said that the 
alleged unauthorized use of identities in the Tax Returns, the Bank Letter or the Lease was central 
to the alleged fraudulent scheme to have SBA loans approved. Gladden, 78 F.4th at 1245 (holding 
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that use of fraudulent identities has to be “central to the scheme” to satisfy the Aggravated Identity 
Theft statute”); Dubin, 599 U.S. at 122-23 (“This central role played by the means of identification, 
which serves to designate a specific person's identity, explains why we say that the ‘identity’ itself 
has been stolen.”). 
Here, the evidence in the form of unrebutted testimony from PayPal, Northeast Bank, Cross 
River Bank, and the SBA established that the (1) Tax Returns, (2) the Bank Letter or (3) the Lease 
were not necessary documents to be submitted applications and that there was no requirement to 
submit these documents. Unlike Gladden and Detling there is no indication that the use of the 
individuals’ identities had a direct correlation to the crime being committed and to the actual 
benefits received from the fraud. To the contrary, if anything the “use” in the application process 
was merely tangential or superfluous as it was not necessary to obtain the approval of the 
application.  Consequently, the Government has not, and cannot, prove that the Defendant’s 
alleged use of identifying information was the crux of the crime.  To the contrary, the information 
used in this case was neither necessary nor required for the applications which the Government 
argues were fraudulent.  
Specifically, the representatives from PayPal, Northeast Bank, and Cross River Bank all 
consistently testified that the Tax Returns were neither necessary nor required as part of the 
respective PPP loan applications.3 Similarly, there was no requirement to submit Tax Returns for 
 
3 Jamie Hutchinson from PayPal testified that the Tax Returns submitted for 2020 were not relied 
upon in making funding decisions, and the borrower was not required to submit the tax returns. 
[11.30.23 PM Trial Tr. 90:11-91:1]. Further, she testified that Mr. Sheppard elected to prove loss 
of revenue quarter over quarter, and therefore, Tax Returns were not required. [11.30.23 PM Trial 
Tr. 98:5-99:10, 99:19-100:2]. Similarly, David Toye from Northeast Bank testified that there 
was nothing in the documentation provided to indicate that the Tax Returns were relied upon in 
making a decision to fund the loan and for the approval of the loan, Northeast Bank did not require 
any business tax returns to substantiate loss in revenue. [12.05.23 AM Trial Tr. 52-54]. Further, 
he testified that Northeast Bank required the 2020 Tax Returns because the applicant was a 
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the EIDL loans. [12.14.23 PM Trial Tr. 85:4-9]. Consequently, the documents cannot be said to 
be at the crux of the crime. See Dubin, 599 U.S. at 132 (finding that the identity of the individuals 
whose identity is allegedly stolen has to be used to commit the underlying crime). 
Similarly, Brett Motes from the SBA testified that the Bank Letter and Lease Agreement 
were neither necessary nor required as part of the EIDL loan applications. [12.14.23 PM Trial Tr. 
41-42, 54-57]. The Bank Letter and Lease Agreement was not even requested by the loan officer 
to begin with. In fact, after receipt of the Bank Letter, Mr. Motes testified that the SBA sent Mr. 
Sheppard an email stating that what they needed was an account number, clarifying that the Bank 
Letter did not contain any material information necessary to complete the SBA application process. 
Thus, the Bank Letter was clearly not the “crux” or “central” to the alleged crime. [12.14.23 PM 
Trial Tr. 56-57]. Consequently, none of the documents the government claims to have been used 
in the commission of identity theft were necessary, required or considered in connection with the 
SBA loan application process.  Accordingly, they could not be considered the key movers nor the 
crux of the alleged wire fraud charged against Sheppard. Thus, the Government failed to prove a 
necessary element of Aggravated Identity Theft as outlined in Dubin: that the alleged identity 
thefts are the “crux” of the underlying crimes (or even necessary for the alleged crimes to be 
completed). As a result a judgment of acquittal is proper. 
Further, contrary to the allegations in the Superseding Indictment, there is no evidence that 
Mr. Sheppard fabricated the means of identification of others without their knowledge and consent 
 
partnership, but the applicant was an LLC; when looking at the applicant portal, the portal stated 
that the 2019 tax returns were option but it didn’t even suggest an option for 2020 tax returns. 
[12.05.23 AM Trial Tr. 56-65]. Spencer Lord at Cross River Bank testified that there’s nothing 
in the record that shows that the underwriter reviewed or analyzed the 1065 Tax Return. [12.05.23 
PM Trial Tr. 110-111]. None of the documents produced show that a 1065 was requested or that 
anyone at Cross River Bank read the 1065 Tax Return. [12.05.23 PM Trial Tr. 78]. 
Case 1:22-cr-20290-BB   Document 162   Entered on FLSD Docket 12/17/2023   Page 14 of 20

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to obtain a personal benefit. There was no proof presented at trial that these alleged fraudulent 
documents were used to inure to the personal benefit of the Defendant. Instead, the evidence shows 
that the loan money was spent on allowable expenses, such as payroll, materials, and a business 
mortgage.  Essentially, money is fungible, and it was expected that within a time period, the loan 
money would be spent on operating expenses and working capital. [12.14.23 PM 61:18-64:13]. 
Finally, the Government’s position that if the SBA or the Banks knew the documents were 
fraudulent, they wouldn’t have funded the loans, thereby somehow making them the crux of the 
crime is misplaced. In Dubin, if Medicaid knew the defendant was overbilling Medicaid by 
inflating the value of the services provided to the patients, it is axiomatic that Medicaid wouldn’t 
have approved the reimbursement. Yet, in holding that the defendant did not commit aggravated 
identity theft because the crux of the crime was not the misuse of another person’s means of 
identification, Justice Sotomayor did not address this point.  The Court did hold that although the 
defendant’s acts amounted to fraud, it didn’t amount to aggravated identity theft, which carries a 
severe penalty: a mandatory minimum sentence of two years in prison in addition to the 
punishment for the predicate offense.” Dubin, 599 U.S. at 115. Similarly, in Gladden, it is clear 
that the insurance companies would not have covered the prescription filled by Defendant Gladden 
if they knew the prescription wasn’t medically necessary. Despite this, the Eleventh Circuit holds 
that Defendant Gladden did not commit aggravated identity theft under the standards articulated 
in Dubin.4 As such, the Government’s argument is misplaced and should be disregarded.  
 
4 In Detling, the court there noted that the representatives from the financing companies testified 
that “had they known that Mr. Detling’s clients had not authorized the advances or received the 
funds, they never would have approved the funding.” Detling, 2023 WL 6060576, at *2. 
Additionally, in Gladden, the court noted that for Defendant Linton’s use of the doctor’s 
identification to fill a prescription, had the insurance companies known that the doctor had not 
actually authorized the prescription, they would not have provided reimbursement. Gladden, 78 
F.4th at 1246. Yet, this is not the case here. For example, as to the Tax Returns, the trial evidence 
Case 1:22-cr-20290-BB   Document 162   Entered on FLSD Docket 12/17/2023   Page 15 of 20

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III. 
The Government Failed to Provide Evidence of a Necessary Element of Wire Fraud. 
According to the Eleventh Circuit “mail or wire fraud occurs when a person (1) 
intentionally participates in a scheme [or artifice] to defraud another of money or property and (2) 
uses the mails or wires in furtherance of that scheme.” McCulloch v. PNC Bank, Inc., 298 F.3d 
1217, 1225 (11th Cir. 2002). “A scheme to defraud requires proof of a material misrepresentation, 
or the omission or concealment of a material fact calculated to deceive another out of money or 
property.” United States v. Maxwell, 579 F.3d 1282, 1299 (11th Cir. 2009). “A misrepresentation 
is material if it has a natural tendency to influence, or is capable of influencing, the decision maker 
to whom it is addressed.” Id. (quotation marks and alteration omitted).  
However, the “scheme to defraud” under the wire fraud statute is not a scheme that is 
intended to deceive someone only of information needed to make discretionary decisions about 
the use of money or property. Ciminelli v. United States, 598 U.S. 306, 308 (2023).  Instead, “the 
wire fraud statute reaches only traditional property interests.” Id. In Ciminelli, the defendant was 
convicted of wire fraud for essentially paying a former associate of the governor of New York, 
who was then a lobbyist, a large fee to help rig the bidding system for obtaining government 
contracts relating so that Ciminelli’s company was the only one that met the requirements. The 
Government argued that Ciminelli’s scheme deprived that the non-profit company (Fort Schuyler 
Management Corporation) of its ability to control state assets because it was deprived of 
potentially valuable economic information relating to Ciminelli when deciding how to use its 
assets.  In essence, the alleged wire fraud caused Fort Schuyler to award government contracts to 
 
did not show that had the bankers known that the CPA didn’t prepare the Tax Returns, the loan 
would not have been funded. To the contrary, the evidence shows the Banks did not require a 
preparer on the Tax Returns. The same can be said about the Bank Letter and Lease.  
Case 1:22-cr-20290-BB   Document 162   Entered on FLSD Docket 12/17/2023   Page 16 of 20

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Ciminelli.  In reversing the conviction, the Supreme Court explained that the deceptive acts in wire 
fraud must be meant to affect traditional property interests, and that the rights implicated by the 
alleged scheme did not involve traditional property rights but instead related to potentially valuable 
information necessary to make discretionary economic decisions. Such interests, however, were 
not protected by the wire fraud statute.   
Rather, a scheme to defraud is a scheme that is intended to cause an economic harm or loss 
of property on the alleged victim. See United States v. Takhalov, 827 F.3d 1307, 1312 (11th Cir. 
2016), as revised (Oct. 3, 2016), opinion modified on denial of reh'g, 838 F.3d 1168 (11th Cir. 
2016) (“to defraud, one must intend to use deception to cause some injury”); See also United States 
v. Masino, 18-15019, 2021 WL 3235301 at *9 (11th Cir. July 30, 2021) (holding defendants were 
not guilty of a conspiracy to commit wire fraud because “even if there was evidence that the 
Masinos conspired to deceive the charities regarding their compliance with the specified provisions 
of the statute, there was no evidence that the Masinos conspired to harm the charities by taking 
from them money or property to which the Masinos were not entitled). In Takhalov, the defendants 
hired women to pose as tourists, locate visiting businessmen, and lure them into the defendants’ 
bars and nightclubs. 827 F.3d at 1310. The women concealed their relationship with the clubs to 
persuade the men to go to the clubs. Id. In the defendants' story, none of these allegedly swindled 
men were truly victims: they knowingly entered the clubs, bought bottles of liquor, and drank them 
with their female companions. Thus, in the defendants' view, these men got what they paid for—
nothing more, nothing less. Id. at 1311. In acquitting defendants of wire fraud, the court in 
Takhalov explained: “§ 1343 forbids only schemes to defraud, not schemes to do other wicked 
things, e.g., schemes to lie, trick, or otherwise deceive. The difference, of course, is that 
deceiving does not always involve harming another person; defrauding does. That a defendant 
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18 
merely “induce[d] [the victim] to enter into [a] transaction” that he otherwise would have avoided 
is therefore “insufficient” to show wire fraud.” Id. at 1310 (emphasis added). Thus, “[a] jury cannot 
convict a defendant of wire fraud, then, based on ‘misrepresentations amounting only to a deceit[]’ 
. . . even if a defendant lies, and even if the victim made a purchase because of that lie, a wire-
fraud case must end in an acquittal if the jury nevertheless believes that the alleged victims 
“received exactly what they paid for.” Id. at 1314 quoting U.S. v. Shellef, 507 F.3d 82, 108 (2d 
Cir. 2007). 5  
Here, for the PPP loans, the Government claims the victims of Mr. Sheppard’s alleged 
fraud are the Banks, not the SBA. Yet, the Government has failed to provide any evidence that a 
traditional property interest is implicated by the funding of PPP loans by the banks, or that the 
Defendant intended to harm or did harm the banks.  
The Government’s argument that because the information allegedly given to the banks and 
SBA in connection with the loan application process was false, that the Banks and SBA were 
prevented from properly evaluating the application of the Defendant’s entities is irrelevant. The 
Supreme Court in Ciminelli has explicitly held that “potentially valuable economic information” 
“necessary to make discretionary economic decisions” is not a traditional property interest and 
cannot form the basis of wire fraud.  In rejecting the right-to-control theory, the Supreme Court 
explained that Ciminelli could not be convicted of fraud in influencing the bidding process of state 
 
5 Shellef, 507 F.3d at 108 (Because “[m]isrepresentations amounting only to a deceit are 
insufficient to maintain a mail or wire fraud prosecution,” we concluded that such a charge can not 
apply to situations where the alleged victims “received exactly what they paid for” and “there was 
no discrepancy between benefits reasonably anticipated and actual benefits received.”); United 
States v. Kachkar, 19-12685, 2022 WL 2704358, at *4 (11th Cir. July 12, 2022) (holding that “one 
can ‘scheme to defraud’ under Section 1343 only if he ‘intend[s] to harm the victim.’ And we 
reasoned that a defendant displays such intent if he ‘lies about the nature of the bargain itself,’ 
usually by misrepresenting ‘the price’ or ‘characteristics of the good,’ so that the victim does not 
receive ‘what he bargained for.’”) 
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19 
government construction contracts, because wire fraud does not apply to fraud connected with 
obtaining information, but only fraud directly connected to obtaining property. Id. at 316.6 
Moreover, no reasonable juror can conclude that Mr. Sheppard intended to defraud, harm 
or injure the Banks. Further, there was no harm or injury to the Banks. Althea Harris from the SBA 
testified that the monies were allocated and reallocated by congress to the SBA to have available 
to guarantee the loans. [11.28.23 Trial Tr. 91]. In fact, the financial institutions were paid a 5% fee 
for every loan that was successfully funded. [11.28.23 Trial Tr. 82]. Ms. Harris testified that if an 
ineligible company got a loan, it didn’t create a risk of financial harm to the PPP Program. 
[11.28.23 Trial Tr. 93]. Thus, the Government failed to prove a necessary element of Wire Fraud. 
As a result, a judgment of acquittal is necessary. 
WHEREFORE, Defendant, Eric Dean Sheppard, respectfully requests that this Court 
grant enter a judgment of acquittal on all counts related to Aggravated Identity Theft and Wire 
Fraud Counts 4-9, related to the PPP loan applications, and for such other and further relief as may 
be just and proper.  
 
 
 
 
 
 
 
6 Similarly, if the alleged victim was the Government itself, the Government’s policy under the 
rules about who gets the loans would not amount to wire fraud either. 
Case 1:22-cr-20290-BB   Document 162   Entered on FLSD Docket 12/17/2023   Page 19 of 20

20 
Dated: December 17, 2023   
 
 
Respectfully submitted,  
NELSON MULLINS  
One Biscayne Tower, 21st Floor  
2 S. Biscayne Boulevard  
Miami, FL 33131  
Telephone: 305.373.9400  
By: /s/ Christopher Cavallo 
Christopher Cavallo  
Florida Bar No. 0092305 
Jayne C. Weintraub 
Florida Bar No. 320382 
Jonathan Etra  
Florida Bar No. 686905 
 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on December 17, 2023 the foregoing document was filed via 
the Court’s CM/ECF system to all counsel of record.  
/s/ Christopher Cavallo  
Christopher Cavallo 
 
Case 1:22-cr-20290-BB   Document 162   Entered on FLSD Docket 12/17/2023   Page 20 of 20

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