Revised Declaration of Special Agent Christina Clyburn — United States v. Park (Dkt. 86, C.D. Cal.)

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A revised declaration of FBI Special Agent Christina Clyburn, submitted under 28 U.S.C. § 1746 in United States of America v. Abraham Park, No. 8:23-CR-00132, in the U.S. District Court for the Central District of California, filed August 4, 2025. The declaration revises one submitted to the Court on July 23, 2025. The agent states having been employed with the FBI since March 2019 and is assigned to the Los Angeles Office, and sets out loss calculations based on the attached exhibits. It states that the total that could have been paid out on fraudulent applications that were not funded, listed in Exhibit B, was approximately $5,469,946, and that the total actual and intended loss was approximately $12,463,646. The exhibits follow the declaration.

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Case 8:23-cr-00132-FWS   Document 86   Filed 08/04/25   Page 1 of 15 Page ID #:495



 1    LORINDA I. LARYEA
      Acting Chief, Fraud Section
 2    Criminal Division, U.S. Department of Justice
      BRANDON BURKART
 3    Trial Attorney, U.S. Department of Justice                     AUG 4, 2025
      Criminal Division, Fraud Section
 4         1400 New York Avenue NW, 3rd Floor                            rrp

           Washington, DC 20530
 5         Telephone: (202) 341-6287
           Email:     brandon.burkart@usdoj.gov
 6    ANDREW JACO
      Trial Attorney, U.S. Department of Justice
 7    Criminal Division, Fraud Section
           1400 New York Avenue NW, 3rd Floor
 8         Washington, DC 20530
           Telephone: (202) 740-0953
 9         Email:     andrew.j.jaco@usdoj.gov

10
      Attorneys for Plaintiff
11    UNITED STATES OF AMERICA

12                            UNITED STATES DISTRICT COURT

13                      FOR THE CENTRAL DISTRICT OF CALIFORNIA

14    UNITED STATES OF AMERICA,                 No. 8:23-CR-00132

15               Plaintiff,                     Revised Declaration of
                                                Special Agent Christina Clyburn
16                     v.

17    ABRAHAM PARK,

18               Defendant.

19

20          I, Special Agent CHRISTINA CLYBURN, submit this revised
21    declaration under penalty of perjury pursuant to 28 U.S.C. § 1746.
22    The declaration revises the declaration previously submitted to the
23    Court on July 23, 2025.      I declare as follows:
24          1. I am a Special Agent with the Federal Bureau of Investigation
25             (“FBI”), and I have been employed with the FBI since March
26             2019.   I am currently assigned to the Los Angeles Office,
27             Orange County Resident Agency.        Since joining the FBI, I have
28             received extensive training in the investigation of federal

     Case 8:23-cr-00132-FWS   Document 86   Filed 08/04/25   Page 2 of 15 Page ID #:496



 1             crimes, including fraud and money laundering.            Prior to

 2             becoming a Special Agent with the FBI, I was a Senior

 3             Investigator with the City of New York Department of

 4             Investigation (“DOI”).       During my tenure with DOI, I

 5             investigated state level criminal offenses related to

 6             governmental fraud, waste, and corruption.

 7          2. I was involved in the investigation and prosecution of

 8             Abraham Park, and the defendants in the related cases.              As

 9             part of the investigation, I interviewed witnesses and

10             reviewed and analyzed financial records, internet provider

11             records, records from the United States Small Business

12             Administration (“SBA”), the United States Internal Revenue

13             Service (“IRS”), the California Franchise Tax Board (“FTB”),

14             the Employment Development Department of California (“EDD”),

15             and other records related to Park’s involvement in the scheme

16             to defraud the SBA’s Economic Injury Disaster Loan program

17             (“EIDL”).

18          3. After reviewing and analyzing those records, reviewing the

19             other investigative files, and conferring with defense

20             counsel and other agents investigating the case, I prepared

21             the summary charts attached to this declaration at Exhibit A

22             and Exhibit B, which detail the fraudulent EIDL applications

23             that were submitted to the SBA as part of Park’s scheme.              The

24             purpose of this analysis was, among other things, to

25             determine the actual and intended losses from the fraudulent

26             applications.

27          4. Regarding EIDL loans, the loan amount was based on the gross

28             revenues and cost of goods sold for the 12 months prior to
                                               2

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 1             the declaration of the disaster.         For all the loans relevant

 2             for this case, the basic loan entitlement was to cover six

 3             months of gross profit, which was calculated by subtracting

 4             the cost of goods sold from the gross revenues for the 12

 5             months prior to January 31, 2020.         Gross revenues and cost of

 6             goods sold were required fields on the EIDL loan application.

 7             So, for example, if the gross revenue was reported on the

 8             application as being $100,000, and the cost of goods sold was

 9             reported as being $50,000, the gross profit would be $50,000.

10             The loan amount, therefore, would have been $25,000 ($50,000

11             divided by two, to cover only six months).

12          5. Exhibit A lists the fraudulent applications that were funded

13             by the SBA as part of the charged scheme.           The information in

14             the columns titled “Application Date”, “Application Number”,

15             “Applicant Name”, “Business Name”, and “Amount of the

16             Proceeds” came from SBA records that I reviewed.

17          6. Exhibit B lists the fraudulent applications that were not

18             funded by the SBA even though they were submitted as part of

19             the scheme.    The information in the columns titled

20             “Application Date”, “Applicant Name”, and “Business Name”

21             came from SBA records that I reviewed.           Additionally, using

22             the information contained on the application, and the

23             formulas listed in paragraph 4 above, I calculated the

24             maximum loan amount that would have been funded had the loans

25             been approved.

26          7. For all of the applications listed in Exhibits A and B, the

27             evidence obtained as part of the investigation indicates that

28             the applications were fraudulent because either: (1) the
                                               3

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 1             company listed as the applicant did not have any tax filings

 2             for the relevant period, including to the IRS, FTB, and EDD,

 3             which indicates that the company did not exist; (2) witnesses

 4             confirmed that the application was fraudulent; or (3) the

 5             application was submitted in the name of the defendant and/or

 6             one of his family members as part of the scheme.

 7          8. Each of these fraudulent applications is also connected to

 8             the defendant.     The last column in each Exhibit, titled

 9             “Connection to Park”, details the evidence connecting the

10             application to the defendant’s scheme, including one or more

11             of the following as to each loan:

12                a. During plea negotiations, the defendant did not contest

13                   that he had knowledge of or was deliberately ignorant to

14                   the application at issue, as shown in Exhibit C.

15                b. As part of the investigation we interviewed several of

16                   the applicants who informed us that the defendant or

17                   others in the scheme were involved in processing their

18                   applications.

19                c. When available, the SBA collects the IP address from

20                   where an application was submitted. I reviewed IP

21                   address records from internet service providers and

22                   compared those with the available IP address information

23                   from the fraudulent applications, and several of the

24                   applications were submitted from the IP address

25                   associated with the defendant’s business address.             This

26                   indicates that the defendant was involved in submitting

27                   the fraudulent application.

28
                                               4

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 1                d. I included all applications that were submitted in the

 2                   name of the defendant’s relatives, including his wife,

 3                   his daughters, and his sons-in-law.

 4                e. The SBA records contain the address information that was

 5                   included for each individual entity applicant. I

 6                   compared those records with the defendant’s business

 7                   address, and when those addresses matched, I included

 8                   those applications.     If the addresses matched that

 9                   indicated that the defendant was involved in the

10                   application.

11                f. I included all applications submitted in the name of the

12                   defendant and co-defendants since they have pleaded

13                   guilty to committing fraud related to the scheme,

14                   including to falsifying information on applications for

15                   fake companies and otherwise legitimate businesses.

16          9. Furthermore, for each of the applications connected to Park

17             only by “IP address” or “Same Adress,” the applicant entity

18             did not have tax filings with the IRS, FTB, and EDD, which

19             indicates that the companies did not exist.

20          10.   Exhibits A and B also include the total value of the funded

21             and unfunded applications, respectively.           The total amount

22             paid out by the SBA on the fraudulent applications listed in

23             Exhibit A was approximately $6,993,700.           The total amount

24             that could have been paid out on the fraudulent applications

25             that were ultimately not funded, as listed in Exhibit B, was

26             approximately $5,469,946.       Adding these two amounts together,

27             the total actual and intended loss was approximately

28             $12,463,646.
                                               5

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                                  EXHIBIT $

Case 8:23-cr-00132-FWS   Document 86   Filed 08/04/25   Page 8 of 15 Page ID #:502

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                                EXHIBIT %

Case 8:23-cr-00132-FWS   Document 86 Filed 08/04/25   Page 11 of 15 Page ID
                                   #:505

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                                EXHIBIT &

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                                   #:508

Case 8:23-cr-00132-FWS   Document 86 Filed 08/04/25   Page 15 of 15 Page ID
                                   #:509

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