Court filing
Exhibit - United States v. Tracy and Carolyn Wade
Record facts
| Court | U.S. District Court for the Southern District of Florida |
|---|---|
| Filed | 2024-10-30 |
U.S. District Court for the Southern District of Florida · No. 0:24-cr-60124-RS · Doc. 18 · 2024-10-30 · Docket on CourtListener
Summary
A factual proffer between the United States and a defendant formerly known as Haydee Granados, in the U.S. District Court for the Southern District of Florida. Its stamps show it entered as Document 18 in No. 0:24-cr-60124-RS on September 20, 2024 and as Document 196-3 in No. 0:23-cr-60173-KMW on October 30, 2024. The parties stipulate that the government would prove that from in or around April 2021 through August 2021 she agreed with Carolyn Wade, Tracy Wade and others to obtain PPP loans using false information. The proffer states that she prepared fictitious IRS Schedule C forms for both, uploaded them to their loan application accounts and received $1,000 from Carolyn Wade. The parties agree the facts suffice to prove conspiracy under Title 18, United States Code, Section 371.
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Full text
ï UNITED STATES DISTRICT COURT SOUTkERN DISTRICT OF FLORIDA ! CASE NO.: 24-60124-CR-SM ITH UNITED STATES OF AM ERICA VS. HAYDEE RW ERO, . f/k/a (dHaydee Granados,'' Defendant. / èACTUALPROFFEA The United States of Am erica and HAYDEE RW ERO, f/k/a Haydee Granados, (hereinafter, (r efendanf') hereby stipulate and agree that, wére this case to proceed to trial, the United States would prove beyond a reasonable doubt the following facts, among others, which occurred in Broward County, in the Southern District of Florida, and elsewhere, at all tim es m aterial to the lnformation: Background 1. The Coronavirus Aid, Relief, and Economic Security (IICA1lES'') Act was a federal law enacted iil or around M arch 2020, designed to provide emergency financial assistance to the m illions of Americans who Fere suffering from the economic effects caused by the COW D-19 pandemic. One source of relief that ihe CARES Act provided was the Paycheck Protection Program (iTPP'') which authorized forgivable loans to small businesses' for job retentidn and certain other expenses. 2. lndividuals who were self-employed or operated a business , under a Glsole proprietorship'' business structure could qualify for a PPP loan if their business satisfied the eligibility regulations promulgated by the U.S. Small Business Administration (SBA). To qualify 1 Case 0:24-cr-60124-RS Document 18 Entered on FLSD Docket 09/20/2024 Page 1 of 6 Richard Ramos Oct 1, 2024 23-60173-CR_009237 Case 0:23-cr-60173-KMW Document 196-3 Entered on FLSD Docket 10/30/2024 Page 1 of 6 23-60173-CR 2001 for such a PPP loan, individuals had to report and docum ent their incom: and expenses. Sole proprietorships typically report thgir income and expenses yearly to the lRS on a çTorm 1040, Schedule C.'' As with other PPP loans, this information and supporting documentation was used by the SBA and its lenders to calculate the amount of money the individual was entitled to receive upder the PPP. The maximum PPP loan amount for a sole propriètor with no other employees was $20,833. SBA required that information providej in thePPP loan application, and the information provided in a1l supporting documents and form s, to be true and in a1l m aterial respects. The SBA and its lenders required the borrower to certify that a11 such information was true. Co-conspirators and Relevant Entities ' I . 4. Co-conspirator Carolyn W ade was a resident of Broward County, Florida, and employed as a'Deputy Sheriff by the Broward County Sheriff's Office. . ' Co-conspirator Tracy W ade was a resident of Broward County, Florida, and employed as a Deputy Sheriff by the Broward County Sheriff's Office. Harvest Small Business Finance, LLC (Etl-larvesf') was a participating lender in the PPP, and was located in California. ' Oto Analytics, lnc. dba W omply ((ûW omply'') was a third-palïy service provider that processed PPP loan applications for Harvest, among other paticipating PPP lenders, and was located in California. The Purpose of the C onspiracy 8. From in or around April 2021, and continuing through in or around August 2021, Defendant agreed with Carolyn W ade, Tracy W ade, and others, to try to accomplish a shared and unlawful plan, that is, to obtain PPP loans from the SBA and its lenders based on materially false Case 0:24-cr-60124-RS Document 18 Entered on FLSD Docket 09/20/2024 Page 2 of 6 23-60173-CR_009238 Case 0:23-cr-60173-KMW Document 196-3 Entered on FLSD Docket 10/30/2024 Page 2 of 6 and fraudulent infonnation. The unlawful purpose of the plan was for Defendant, Carolyn W ade, Tracy W ade, and others, to unlawfully elzrich them selves. Defendant knew the unlawful purpose of the plah and willfullyjoined in it. The M anner and M eans of the Conspiracy To accomplish the conspiracy's purpose of fraudulently obtaining PPP loans, Defendant created and prepared false and fictious tax docum ents for her co-conspirators, including Carolyn W ade, Tracy W ade, and others. Specifically, at the direction and with the knowledge of her co-conspirators, including Carolyn W ade and Tracy W ade, Defendant created and prepared false and fictitious lRS Schedule C forms for PPP loan applib' ations of Carolyn W ade, Tracy W ade, and others. Defendant fabricated the information in the 1RS Schedule C forms for her co- conspirators, including Carolyn W ade and Tracy W ade, by populating blank 1RS Schedule C form s with m ade-up numbers for purported income and expenses. Carolyn W ade and Tracy W ade never supplied Defendant with any of theipactual tax inform ation. 10. After Defendant had created the fictious conspirators, including for Carolyn W ade and Tracy W ade, Defendant 1RS Schedule C form s for her co- logged in to her co- conspirators' respective PPP application çccounts on W omply's website to upload the fictitious lRS Schedule C forms. To log in to those accounts for that purpose, Defendant used one-time, short-lived passcodes that her co-conspirators, including Carolyn W ade and Tracy W ade, provided to Defendant. Once logged in with the passcode supplied by her co-conspirators, Defendant uploaded the fictitious IRS Schedule C forms she had created and manually typed in fake income information represented on the fictious fonns. 11. After Defendant uploaded the tk titious IRS Schedule C form s, and typed in the , i fictitious income inform ation, Defendant s co-conspiratoès, including Carolyn W ade and Tracy Case 0:24-cr-60124-RS Document 18 Entered on FLSD Docket 09/20/2024 Page 3 of 6 23-60173-CR_009239 Case 0:23-cr-60173-KMW Document 196-3 Entered on FLSD Docket 10/30/2024 Page 3 of 6 W ade, themselves logged in to their respective PPP application accounts and completed the PPP application process. After the PPP loan application process was completed, W omply sent the borrower of record, via email through Docusign, a completed SBA Form 2843-C PPP Borrower Application, for the borrower to certify that the information provided in the application and in a1l supporting documents and formj was true and âccurate in al1 material respects, and to electronically sign the SBA Form 2483-C PPP Application via Docusign. The completed SBA Form 2483-C PPP Borrower Application that W omply sent to Defendant's co-conspirators, including Carolyn W ade and Tracy W ade, included the fictitious gross incom e infonnation that Defendant h&d fabricated and submitted on the 1RS Schedule C Form . Defendant did not celify and did rfot sign any PPP application (on S. BA Form 2483-C or otherwise) via Docu,sign for Carolyn W ade or Tracy W ade. Overt Acts Related to Tracy W ade's PPP Application 12. W ith respect to .that certain PPP loan application for Tracy W ade assigned ID <'bdcd28a5-a9d0-4141-ba64-ad5ca515cb8b'' (the ts-fracy W ade PPP Application''), Defendant, acting at the direction and with the knowledge of Tracy W ade, created a false and fictious 1RS Schedule C, purportedly for the tax year 2019 (the GTalse Tracy Wade Schedule C''). The False Tracy W ade Schedule C falsely fepre' àented, among oiher things, that the principal business or rofession (in line &&A'') was (C-l-racy D W ade'' and that the gross income (in line çt7'') was P (1$112 430.'' 13. On M ay 6, 2021, Defendant, acting at the direction and with the knowledge of Tracy W ade, logged in to the Tracy W ade PPP Application Loan account on W omply's website using a one-time, shorbkived passcode that Womply sent to Tracy Wade. Once logged in, Defendant uploaded a copy of the False Tracy W ade Schedule C and inputted false tax inform ation 4 Case 0:24-cr-60124-RS Document 18 Entered on FLSD Docket 09/20/2024 Page 4 of 6 23-60173-CR_009240 Case 0:23-cr-60173-KMW Document 196-3 Entered on FLSD Docket 10/30/2024 Page 4 of 6 from the False Tracy W ade Schedule C. 14. On or about M ay 18, 2021, M ay 19, 2021, and M ay 27, 2021, Tracy W ade certifed as true and signed, via Docusign, an SBA Form 2483-C PPP Borrower Application that included the false gross income figure of ::112,430'' from line 7 of the False Tracy W ade Schedule C created by Defendant. 15. On June 3, 2021, Defendant received $1 000 from Tracy W ade, via Zelle transfer, which was a payment for Defendant cfeating and subm itling the False Tracy W ade Schedule C for the Tracy W ade PPP Application. Overt Acts Related to Carolyn W ade's PPP Application 16. W ith respect to that certain PPP loan application for Carolyn W ade assigned ID number $:72d63c08-d94-4a1e-a6497c6c986ad+7'' (the Eicarolyn Wade PPP Application''), ' Defendant, acting at the direction and with the knowledge of Tracy W ade and Carolyn W adè, created a false and fictious IRS Schedule C, purportedly for the tax year 2019 (the i'False Carolyn k ' W ade Schedule C''). The False Carolyn W ade Schedule C falsely represented, among other things, that the principal business or profession (in line ((A'') was itcarolyn W ade'' and that the gross income (in line &C7'') was (6$1 13 560.'' 17. On M ay 13, 2021, Defendant, acting at the direction and with the knowledge of Tracy W ade and Carolyn W ade, logged in to the Carolyn W ade PPP Application Loan accopnt on W omply's website using a one-time, short-lived passcode that W ompty had sent to Carolyn W ade. Orfce logged in, Defendant uploaded a copy of the False Carolyn W ade Schedule C and inputted false tat information from the False Carolyn W ade Schedule C. 18. On or about M ay 18, 2021 and M ay 28, 2021, Carolyn W ade certified as true and signed, via Docusign, an SBA Form 2483-C PPP Borrower Application that included the false Case 0:24-cr-60124-RS Document 18 Entered on FLSD Docket 09/20/2024 Page 5 of 6 23-60173-CR_009241 Case 0:23-cr-60173-KMW Document 196-3 Entered on FLSD Docket 10/30/2024 Page 5 of 6 '# gross income figure of ::113,560'' from line 7 of the False Cam lyn W ade Schedule C created by Defendant. 19. On June 7, 2021, Defendgnt received $1,000 from Carolyn W ade, via Zellqtransfer, which was a payment for Defendant creating and subm itting the False Carolyn W ade Schedule C for the Carolyn W ade PPP Application. 20. The United States and Defendant agree that these facts, which do not include a11 facts known to the United States and Defendant, are sufficient to prove beyond a reasonable doubt the elements of conspiracy to commit offenses against the United States, that is, wire fraud, in violation of Title 18, United States Code, Section 1343, and making false statements to the SBA, in violation of Title 15, United States Code, Section 645(a), and that Defendant is in fact guilty of that offense as charged the lnformation, that is, Title 1 8, United States Code, Section 371. Date : C/z v /x t Date: By : M AIG ENZY LAPOINTE UNITED STATES ATT EY /#t / V1 DAVI A. SN1 ER ASSI TANT UNITED STATES ATTORNEY j t ' FRA HwARTz, EsQ. A oltxsys FOR DEFENDANT N HAYD RIVERO, f/lc/a Haydee Granados DEFEND ANT (I= (z4 Date: Case 0:24-cr-60124-RS Document 18 Entered on FLSD Docket 09/20/2024 Page 6 of 6 23-60173-CR_009242 Case 0:23-cr-60173-KMW Document 196-3 Entered on FLSD Docket 10/30/2024 Page 6 of 6
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