Information as to Angelo Stephen (1) count(s) 1 and Forfeiture. (ogn1) — United States v. Stephen (Dkt. 1, S.D. Fla. No. 1:25-cr-20014)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:25-cr-20014-CMA · Doc. 1 · 2025-01-16 · Docket on CourtListener

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UM TED STATES DISTRICT COURT
SOUTHERN DISTW CT O F FLORIDA
CASE NO .
18 U.S.C. j 1343
18 U.S.C. j 981(a)(1)(C)
18 U.S.C. j 982(a)(2)(A)
UM TED STATES OF AM ERICA
VS.
ANGELO STEPHEN,
Defendant.
/
INFORM ATION
The United States Attorney charges that:
G ENER AL ALLEGATIONS
At al1 times material to this Information:
The United States Small Business Administration (:$SBA'') was an agency of the
executive branch of the Government of the United States. The m ission of the SBA was to m aintain
and strengthen the nation's economy by enabling the establishment and viability of sm all
businesses and by assisting in the econom ic recovery of com mllnities after disasters.
Economic Injury Disaster Loans
The Coronavims Aid, Relief, and Economic Security (GGCAlkES'') Act was a federal
law enacted in or around M arch 2020 and designed to provide em ergency Enancial assistance to
the millions of small business owners who were suffering the economic effects caused by the
COVID-19 pandemic. One source of relief provided by the CARES Ad w as the authorization and
provision of funds to the SBA to provide Economic Injury Disaster Loans (tçEIDLs'') to eligible
25-20014-CR-ALTONAGA/REID
Jan 16, 2025
AW
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sm all businesses, including independent contractors and sole proprietors, experiencing substantial
financial disruptions due to the COVID-19 pandemic to allow them to m eet financial obligations
and operating expenses that could have been met had the disaster not occurred. These COVlD-19
EIDLS included the possibility of an advance of up to $10,000 for qualifying applicants. The
applicant was not obligated to repay this advance.
In order to obtain a COV1D-19 EIDL, a qualifying for-profit business was required
to submit an EIDL application to the SBA and provide inform ation about its operations, including
its gross revenues and number of em ployees, for the lz-m onth period preceding January 31, 2020.
The applicant also was required to certify under penalty of perjury that a1l the information in the
application was tnle and correct.
4. 
EIDL applications were submitted directly to and processed by the SBA. The
am otmt of the loan approved and any advance provided was determ ined based, in part, on the
infonuation provided in the application concerning the gross revenues, cost of goods sold, and
nllmber of employees of the business or individual applying for the EIDL. Any EIDL funds were
issued directly by the United States governm ent to the applicant's bank account.
The Paycheck Protection Program
5. The CARES Act also authorized forgivable loansto small businesses for job
retention and certain other expenses, through a program referred to as the Paycheck Protection
Program (GTPP''). ln order to obtain a PPP loan, a qualifying business, including a sole
proprietorship, submitted a PPP loan application, which was signed by an authorized
representative of the. business. The PPP loan application required the business (through its
autholized representative) to acknowledge the program nzles and make certain affirmative
certifications in order to be eligible to obtain the PPP loan. ln the PPP Borrower Application Form
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for Schedule C Filers using Gross Income (SBA Form 2483-C), the small business (through its
authorized representative) was required to provide, among other things, its: (a) total nmount of
gross income reported on its Schedule C for either 2019 or 2020; and (b) number of employees.
The infonnation on the application and the supporting documentation subm itted therewith were
used to calculate the amount of money the applicpnt was entitled to receive under the PPP.
6. 
The PPP also allowed a qualifying business that had obtained a first draw PPP loan
and experienced a required revenue reduction in 2020 to obtain a second PPP loan in 2021. These
second PPP loans were also known as Gtsecond draw'' loans. Starting on or about M arch 4, 2021,
small businesses, including sole proprietorships, that filed an IRS Fonn 1040, Schedule C, could
apply for this second draw loan based on their gross income by using the PPP Second Draw
Bolwwer Application Form for Schedule C Filers Using Gross Income (SBA Form 2483-SD-C)
that provided their gross incom e from either 2019 or 2020 and their num ber of employees. This
second draw application and the suppoling documentation submitted were used to calculate the
am ount of second draw m oney the applicant was entitled to receive under the PPP.
A PPP loan application was processed by a participating lender. If a PPP loan
application was approved, the participating lender funded the PPP loan using its own monies.
W hile it was the participating lender that issued the PPP loan, the loan was 100% guaranteed by
the SBA. Data from the application, including inform ation about the borrower, the total nmotmt
of the loan, and the listed nlzmber of em ployees, was transmitted by the lender to the SBA in the
colzrse of processing the loan.
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@
The D efendant and the Relevant Individuals and Entities
8. 
Defendant ANGELO STEPH EN was a resident of M iam i-Dade Colmty, Florida,
who at a11 tim es relevant to this Infbrm ation was employed by the Federal Bureau of Prisons as a
Correctional Officer.
Credit Union 1 was a credit union that did business, including maintaining brmw hes,
in the Southenz District of Florida.
10. Credit Union 2 was a éredit union that did business, including m aintaining branches,
in the Southem  Distrid of Florida.
Bnnk 1 was a bank that did business tlzroughout the United States, including
m aintaining branches in the Southez'n District of Florida.
The Financial Technology Company operated an online platform that received PPP
loan applications from throughout the United States. The Financial Teclmology Company was not
a PPP lender, but rather was a business that received and processed PPP applications for m ultiple
SBA-approved PPP lenders. The Financial Teclmology Company then would m ake qualified PPP
applications available to one of the lenders that retained its senices for the lender's review, final
approval, and funding of the PPP loan.
Lender 1 was all SBA-approved lender for PPP loans with its headquarters in
California. Lender 1's servers were located outside the state of Florida. Lender 1 contracted with
the Financial Technology Company to receive PPP applications for funding by Lender 1.
Lender 2 was an SBA-approved lender for PPP loans with its headquarters in Texas.
Lender 2's selvers were located outside the state of Florida. Lender 2 contracted with the Financial
Technology Company to receive PPP applications for funding by Lender 2.
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15. Bnnk 2 was a bank that did business throughout the United States, including
m aintaining branches in Virginia and the Southern District of Florida.
16. Victim 1 was an individual residing in the state of Virginia who maintained all
account (the Etvictim 1 Account'') at Bank 2.
Credit Union 3 was a credit union that did business, including m aintaining branches,
in the Southern District of Florida.
18. Victim 2 was an individual residing in the cotmtry of Pannm a who maintained an
account (the Esvictim 2 Accotmf') at Credit Union 3.
At al1 relevant times, ANGELO STEPTTEN m aintained accounts at Bank 1, Credit
Urlion 1, and Credit Union 2.
W ire Fraud
(18 U.S.C. j 1343)
From  in or around August 2020, and continuing tllrough in or arotmd July 2023, in
M iam i-Dade County, in the Southem  District of Florida, and elsewhere, the defendant,
ANGELO STEPHEN,
did knowingly, and with the intent to defraud, devise, and intend to devise, a scheme and artifice
to defraud, and to obtain m oney and property by m eans of m aterially false and fraudulent
representations, and
W etensesy Cepccsefltatitms, and prom ises, knowing that the pretenses,
promises were false and fraudulent when m ade, and, for the purpose of executing the schem e and
al'tifice, did knowingly transm it and cause to be transm itted, by m eans of wire com mllnication in
interstate and foreign com merce, certain writings, signs, signals, pictures and sounds, in violation
of Title 18, United States Code, Section 1343.
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PURPOSE OF THE SCHEM E AND ARTIFICE
21. The purpose of the scheme and M ifice was for ANGELO STEPH EN to unlawfully
enrich him self by using his personal bank and credit union accotmts and the United States financial
institution system to unlawfully obtain m oney fw m  num erous victim s, including the United States
government, PPP lenders, and individual victims, by (1) submitting false and fraudulent EIDL and
PPP applications to obtain loan proceeds for his own use and benefit; and (2) participating in
fraudulent bnnk and credit union account takeover activity to unlawfully obtain funds from
accounts belonging to Victim 1 and Victim 2 without their consent or knowledge.
TH E SCHEM E AND ARTIFICE
The m anner and m eans by which ANGELO STEPHEN sought to accomplish the pup ose
of the scheme and artifice included, am ong others, the following:
The EIDL Fraud
22. ANGELO STEPHEN subm itted to the SBA, via interstate wire comm unications, a
false and fraudulent EIDL application in his own name claiming to be an independent contractor
and the 100% owner of a business that did tçevent planning'' and çsentertainm ent services'' and had
ten em ployees as of January 31, 2020. STEPHEN 'S fraudulent EIDL application also falsely
certified that for the twelve (12) month period prior to Januaty 31, 2020, his business had gross
revenues of approximately $62,018 and a cost of goods sold of $0.
23. As a result of this false and fraudulent EIDL application, ANGELO STEPHEN
obtained from the SBA approximately $20,000 in EIDL loan proceeds. These fraudulently
obtained EIDL funds were provided via Electronic Ftmds Transfer to STEPH EN'S account at
Credit Union 1. 
This Electronic Funds Transfer involved the use of interstate wire
commllnications.
6
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The PPP Fraud
24. ANGELO STEPHEN subm itted to the Financial Technology Com pany, via
interstate wire communications, a false and fraudulent PPP first draw loan application (SBA Form
2483-C) claiming to be a sole propdetor operating a business under the tradename ûlAngelo
Stephen.'' That PPP loan application falsely and fraudulently represented that the business' 2020
gross income was $106,554, and as part of the application process, STEPHEN submitted a
fraudulent lRS Form 1040 Schedule C for tax year 2020 that included the sam e false gross incom e
figure. STEPH EN'S first draw PPP application was then provided by the Financial Technology
Company to Lender 1 for final review and funding.
As a result of this false and fraudulent application, ANGELO STEPHEN obtained
approximately $20,833 in first draw PPP loan proceeds from Lender 1 that were electronically
deposited by Lender 1 into STEPHEN 'S accotmt at Credit Union 2. This electronic deposit was
made via interstate wire communications.
ANGELO STEPHEN subsequently submitted to the Financial Technology
Company, via interstate wire communications, a false and fraudulent PPP second clraw loan
application (SBA Form 2483-SD-C), again claiming to be a sole proprietor operating a business
under the tradennme of tçAngelo Stephen.'' This second draw PPP loan application also falsely
and fraudulently represented the business' 2020 gross income to be $106,554, and as part of this
second draw application process, STEPHEN submitted the snm e false and fraudulent IRS Form
1040 Schedule C for tax year 2020 that was used in the fraudulent first-draw PPP application.
STEPHEN'S second draw PPP application was then provided by the Financial Teclmology
Com pany to Lender 2 for final review and funding.
As a result of this false and fraudulent application, ANGELO STEPHEN obtained
Case 1:25-cr-20014-CMA   Document 1   Entered on FLSD Docket 01/16/2025   Page 7 of 13

approximately $20,833 in second draw PPP loan proceeds from Lender 2 that were electronically
deposited by Lender 2 into STEPHEN 'S account at Credit Union 2. This electronic deposit was
made via interstate wire communications.
The Account Takeover Frauds
ANGELO STEPHEN participated in a scheme to gaudulently obtain m oney from
the bank accotmt of Victim 1 through the use of interstate wire comm llnications. STEPH EN and
his accomplices caused a wire transfer of $20,000 from the Victim 1 Accotmt in Virginia into
STEPHEN 'S recently opened account at Bank 2 without the knowledge or consent of Victim 1.
Upon receipt of this fraudulent $20,000 wire transfer, STEPHEN quiclcly made numerous large
withdrawals and Zelle payments removing a11 of the stolen $20,000 from his accotmt. Tllis
incoming wire transfer containing the stolen $20,000 and the subsequent Zelle payments made by
STEPHEN all involved the use of interstate wire communications in furtherance of the fraud.
29. ANGELO jTEPHEN participated in a scheme to fraudulently obtain money from
the credit union accotmt of Victim 2 tluough the use of interstate wire com munications. W ithout
the knowledge or consent of Victim 2, STEPHEN and his accomplices caused Credit Union 3 to
send blank checks for the Victim 2 Account to a new address selected by STEPH EN and his
accom plices that was unassociated with Victim 2.
30. Afler the new checks for the Victim 2 Account were âaudulently obtained from
Credit Union 3, ANGELO STEPHEN cashed one of these checks, m ade out to çlAngelo Stephen''
and bearing an account holder signatlzre falsely purporting to be that of Victim 2, in person at a
branch of Credit Union 3 in the Southern District of Florida, fraudulently obtaining $8,500 in cash
from  the Victim 2 Account. This fraudulently obtained check was not issued, signed, or authorized
to be issued in any way by Victim  2.
8
Case 1:25-cr-20014-CMA   Document 1   Entered on FLSD Docket 01/16/2025   Page 8 of 13

USE OF W IRES
On or about August 4, 2020, in the Southern District of Florida, and elsewhere,
AN GELO STEPHEN, for the purpose of executing and in furtherance of the aforesaid scheme
and artifice to defraud, and to obtain m oney and property by means of m aterially false and
fraudulent pretenses, representations, and prom ises, ltnowing that the pretenses, representations,
and prom ises were false and fraudulent when m ade, did knowingly transmit and cause to be
transm itted in interstate and foreign com merce, by means of wire comm tmication, certain m 'itings,
signs, signals, pictures, and sounds, that is, the electronic transmission of an EIDL application
containing false information about the gross revenues of ANGELO STEPHEN 'S business during
the 'twelve (12) month period prior to January 3 1, 2020, causing a wire transmission from the
Southern District of Florida to outside of the State of Florida.
In violation of Title 18, United States Code, Sections 1343 and 2.
FORFEITURE ALLEGATIONS
The allegations of this Infonnation are hereby re-alleged and by this reference fully
incop orated herein for the purpose of alleging forfeiture to the United States of America of certain
property in which the defendant, ANGELO STEPHEN, has an interest.
2. 
Upon conviction of a violation of Title 18, United States Code, Section 1343, as
alleged in this Information, the defendant shall forfeit to the United States any property, real or
personal, which constitutes or is derived from  proceeds traceable to such offense, pursuant to Title
18, United States Code, Section 981(a)(1)(C).
Upon conviction of a violation of Title 18, United States Code, Section 1343,
relating to any fraud affecting a fnancial institution, as alleged in this lnformation, the defendant
shall forfeit So the United States any property constitm ing, or derived f'rom, proceeds obtained,
9
Case 1:25-cr-20014-CMA   Document 1   Entered on FLSD Docket 01/16/2025   Page 9 of 13

directly or indirectly, as the result of such offense, pursuant to Title 18, United States Code, Section
982(a)(2)(A).
A1l pursuant to Title 18, United States Code, Sections 981(a)(1)(C) and 982(a)(2)(A), and
the procedures set forth in Title 21, United States Code, Section 853, as incorporated by Title 28,
Urlited States Code, Section 2461(c) and Title 18, Ulzited States Code, Section 982(b)(1).
5
/ 
e
ARM NZZ LAPOINTE
UNITED STATES ATTORN EY
....' *
('
- - -- -  /*-7
EDW ARD N. STAM M
ASSISTANT UNITED STATES ATTORNEY
10
Case 1:25-cr-20014-CMA   Document 1   Entered on FLSD Docket 01/16/2025   Page 10 of 13

UM TED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
UNITED STATES OF AM ERICA
V.
ANGELO STEPHEN,
/
Defendant.
Court Division (select one)
E1 M iami 
E! Key West 
E! FTP
E1 F TL 
E1
. WP B
1 do hereby certify that:
1. 
I have carefully considered the allegations of the indictment, the number of defendants, the number of probable
witnesses and the legal com plexities of the lndictment/lnformation attached hereto.
l am aware that the inform ation supplied on this statement will be relied upon by the Judges of this Court in setting
their calendars and scheduling criminal trials under the mandate of the Speedy Trial Act, Title 28 U.S.C. j3161.
CASE NO.:
CERTIFICATE OF TRIAL ATTORNEY
Superseding Case lnform ation:
New Defendantts) (Yes or No)
Num ber of New Defendants
Total number of new counts
Interpreter: (Yes or No) No
List language and/or dialect:
0 days for the parties to try.
This case will take
Please check appropriate category and type of offense listed below :
(Check only one) 
(Check only one)
I F:I 0 to 5 days 
L' Petty
11 E:1 6 to 10 days 
E1 M inor
III E-E1 1 1 to 20 days 
E-I M isdemeanor
EZ 21 to 60 days 
FEI Felony
Iv
I:'I 61 days and over
V
Has this case been previously tsled in this District Court? (Yes or No) No
If yes, Judge 
Case No.
Has a complaint been filed in this matter? (Yes or No) No
If yes, M agistrate Case No.
8. Does this case relate to a previously tiled matter in this District Court? (Yes or No) N0
If yes, Judge 
Case No.
9. Defendantts) in federal custody as of
l0. Defendantts) in state custody as of
1 1. Rule 20 from the 
District of
12. ls this a potential death penalty case? (Yes or No) NO
13. Does this case originate from a matter pending in the Northern Region of the U.S. Attorney's Office
prior to August 8, 2014 (M ag. Judge Shaniek Maynard? (Yes or No) No
14. Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Oftqce prior
to October 3, 2019 (Mag. Judge Jared Strauss? (Yes or No) No
15. Did this matter involve the participation of or consultation with M agistrate Judge Eduardo 1. Sanchez
during his tenure at the U.S. Attorney's Office, which concluded on Januay 22, 2023? No
16. Did this matter involve the participation of or consultation with now M aglstrate Judge M arta Fulgueira
Elfenbein during her tenure at the U.S. Attorney's Office, which concluded on M arch 5, 20247 No
6,- .>
Edward N. Stamm
By :
Assistant United States Attorney
FL Bar N o. 
373826
Case 1:25-cr-20014-CMA   Document 1   Entered on FLSD Docket 01/16/2025   Page 11 of 13

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Nam e: Angelo Stephen
Case N o:
Cotmt #: 1
W ire Fraud
18 U.S.C. j 1343
* M ax. Term of Im prisonm ent: 20 years
* M andatory Min. Term of lmprisonment (if applicable): N/A
* M ax. Supervised Relea' se: 3 years
* M ax. Fine: $250,000
* Special Assessm ent: $100
*R efers only to possible term of incarceration, supervised release and lines. It does not include
restitution, special assessm ents, parole term s, or forfeitures that may be applicable.
Case 1:25-cr-20014-CMA   Document 1   Entered on FLSD Docket 01/16/2025   Page 12 of 13

A0 455 (Rev. 01/09) Waiver of an Indictment
U NITED STATES D ISTRICT COURT
for the
Southern District of Florida
United States of America
V.
ANGELO STEPHEN,
Case No.
W AW ER OF AN INDICTM ENT
I understand that 1 have been accused of one or more offenses punishable by imprisonment for m ore than one
year. l was advised in open coul't of my rights and the nature of the proposed charges against m e.
After receiving this advice, 1 waive my right to prosecution by indictm ent and consent to prosecution by
information.
Date:
Signatul'e ofdefendant 's attorney
Juan Berrio, Esq.
Printed name ofdefendant 's attorney
Judge 's printed name and title
Case 1:25-cr-20014-CMA   Document 1   Entered on FLSD Docket 01/16/2025   Page 13 of 13

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