Declaration of Postal Inspector Bryan Masmela in Support of Preliminary Order of Forfeiture — U.S. v. Hines

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A declaration by U.S. Postal Inspector Bryan Masmela in support of the government's motion for a preliminary order of forfeiture, entered 03/01/2021 as Document 44-1 in United States v. David Tyler Hines, CASE NO. 21-CR-20011-COOKE, Southern District of Florida. He states that Hines applied for and was approved for three PPP loans for companies he owned and controlled, including Cash in Holdings LLC, Unified Relocation Solutions LLC and Promaster Movers Inc., totaling $3,984,557.00 disbursed in May 2020. He says $400,000.00 was moved between Hines' Bank of America accounts and that on May 18, 2020, $318,497.53 was wired to buy a 2020 Lamborghini Huracan.

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Case 1:21-cr-20011-DPG Document 44-1 Entered on FLSD Docket 03/01/2021 Page 1 of 2

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO. 21-CR-20011-COOKE

UNITED STATES OF AMERICA
V.
DAVID TYLER HINES,

Defendant.

DECLARATION OF POSTAL INSPECTOR BRYAN MASMELA IN SUPPORT OF
PRELIMINARY ORDER OF FORFEITURE

I, BRYAN MASMELA, under penalty of perjury, declare:

1. Tam a United States Postal Inspector and have been employed by the United States
Postal Inspection Service since February 2003. As a U.S. Postal Inspector, your affiant is
responsible for the investigation of violations of United States law, including violations of Title
18 of the United States Code. I am currently assigned to the mail fraud team in the Miami
Division and my duties include investigating cases related to mail fraud, wire fraud, bank fraud,
money laundering, and related financial crimes. I am authorized to obtain and execute federal
arrest, search, and seizure warrants.

2s 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
declaration in support of the United States’ Motion for Preliminary Order of Forfeiture against

David Tyler ines (the “Defendant”). Because this declaration is being submitted for a limited
Case 1:21-cr-20011-DPG Document 44-1 Entered on FLSD Docket 03/01/2021 Page 2 of 2

purpose, it does not include all of the facts that I have learned during the course of the investigation.
All dates and amounts discussed in this declaration are approximate.

3. I have reviewed Paycheck Protection Program (“PPP”) loan applications and
financial records for the Defendant and companies owned and controlled by the Defendant,
including Cash in Holdings LLC (“CIH”), Unified Relocation Solutions LLC (“URS”), and
Promaster Movers Inc. (“PM”) (collectively, the “Companies”).

4, Based on my review of the PPP loan applications and financial records for the
Companies, the Defendant applied for and was approved for three PPP loans that were disbursed

into the following accounts:

Date Account Amount
account number 898105927423 at Bank of America
5/11/2020 (“BOA *7423”) $10,380.00
5/13/2020 account number 898077556016 at Bank of America $794,835.00

(“BOA *6016”)
account number 898099756470 at Bank of America
(“BOA *6470”)

5/26/2020

$3,179,342.00
TOTAL | $3,984,557.00

5. Between May 13 and 14, 2020, $400,000.00 was transferred from BOA *6016 to
account number 898096330857 at Bank of America (“BOA *0857”).

6. Additionally, on May 18, 2020, $318,497.53 was wire transferred from BOA *0857
for the purchase of the 2020 Lamborghini Huracan with vin ZHWUF4ZF3LLA 13255.

I declare under penalty of perjury that the foregoing is true and correct.

6. ,.2=——=

BRYA MASMELA
PostalInspector, USPIS

fla
Executed on February /6 , 2021

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