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Crim Flsd Unknown Us V Damion Mckenzie Docx Complaint - Us V Damion Mckenzie

Summary

A criminal complaint in United States v. Damion Mckenzie in the U.S. District Court for the Southern District of Florida, dated August 3, 2020, with a 13-page supporting affidavit by an IRS Criminal Investigation special agent. It charges wire fraud, bank fraud, and conspiracy and attempt to commit wire and bank fraud. The affidavit states that the defendant sought a PPP loan for his company, Five Plus, using falsified bank statements and IRS Forms 941 prepared by a cooperating source, and referred other applicants in return for kickbacks. It states that the conspirators planned or prepared at least 90 fraudulent applications worth more than $24 million, with approximately 42 funded for approximately $17.4 million. According to the affidavit, the Five Plus forms showed quarterly payroll of almost $300,000 for 10 employees, and a bank processor rejected the application by letter.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

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W ire Fraud
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18 U.S.C.1 1349

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SEE AU ACHED AFFIDAVIT.

Troy T. Walker

Aug 3, 2020
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A FFID AW T
1,M ichaelBenivegna,being firstduly sworn,hereby depose and state asfollows:
IN TRO D U CU O N A ND A GEN T BAC K G RO UND

I make this Affidavit in support of a crim inal com plaint charging DAM ION

MCKENZIE (ûEM CKENZIE'' or tdDefendant''), with wire fraud, bank fraud, attempt and
conspiracytocornmitwirefraudandbankfraud,inviolationof18 U.S.C.jj1343,1344,l349,
and 2,from on oraboutM ay 15,2020to atleaston orabotltJuly 2,2020,in the Southern D istrict

ofFlorida,andelsewhere(theSç-l-argetOffenses'').
Defendant has participated in a schem e to obtain by fraud m illions of dollars in

forgivable loans through the Paycheck Protection Program (tSPPP'') and other government
programs,conspiringwithapersonnow cooperatingwiththeinvestigation(CSCHS2'')andothers.
Defendant soughta fraudulentPPP loan forhis owm com pany,Five Pluslnvestm ent Group LLC

(ilFive Plus''),with CHS 2 providing falsified documents and subm itting the application on
D efendant's l half. Defendantalso conspired to subm ita num ber ofadditionalfraudulentPPP
loan applications for othercom paniesby recruiting otherconfkdemte loan applicants, in orderto
receive kickbacks from those confedem tes. To intlate the size of these PPP loans, and the
corresponding kickbacks,the conspirators relied on a variety of false statem ents,including by
subm itting falsified bank statements and payrolltax form s. Forexample,the conspirators used

nearly identicalversions ofthe sam e fabricated bank statem entssrecycled in the PPP applications
form ultiple com paniesw ith m inorchanges.
The conspirators in the scheme planned or prepared at least 90 fraudulent
applications,mostofw hich were subm itted. Based on the evidence investigators have reviewed
to date,CH S 2,Defendant,and theirco-conspiratorsapplied forPPP loansthataretogetherworth

more than $24 million dollars,with atleastapproximately 42 ofthose loansapproved and funded
foratotalofapproximately $17.4 million. Certain ofthose loan recipientsthenwireda kickback
of varying am ounts,often approxim ately 25% of the fraudulent loan proceeds, to an account
controlled by CH S 2.

lam a SpecialA gentwith the United StatesDepartm entofThe Treasury,lnternal

RevenueService,CriminalInvestigation(:$lRS-CI'')andhavebeenemployedinthiscapacitysince
October2016. lam presently assigned to the M iam iField Office. M y dutiesasa SpecialA gent

includetheinvestigationofpossiblecriminalviolationsofthelnternalRevenueCode(Title26of
theUnitedStatesCode),theBankSecrecyAct(Title31oftheUnitedStatesCode),andtheMoney
Laundering Statutes (Title l8 of the United States Code).I graduated from the Criminal
InvestigatorTraining Program atthe FederalLaw Enforcem entTraining Centerin April20l7 and
the Special A gent lnvestigative Techniques program at the N ational Crim inal Investigation
Training A cadem y in July 20l7. ln these tw o program s,I sttldied a variety of 1aw enforcement

tactics and crim inalinvestigatorttchniques rtlating to tax and ûnancialcrim es.Sinct becom ing
an IRS-CI SpecialAgent,lhave personally investigated and assisted in investigations relating to
the lnternalRevenue Law sand financialcrim es. Recently,lhave been assigned to work w ith the
U.S.Departm entofJustice and other 1aw enforcementpartners,including the FederalBureau of

Investigation and the Sm allBusiness Adm inistl-ation Offk e of lnspector Genem l,to investigate
possible fraud associated with the stim ulus and econom ic assistance program s created by the
federalgovernm entin response to the COVID-19 program .
The facts in thisA ffsdavit come from my personalobservations,my training and
experience,and inform ation obtained from othermembersof1aw enforcem entand from witnesses.

Page 2 of13

ThisA ffidavit is intended to show m erely thatthere issufficientprobable cause and doesnotset
forth allofmy know ledge aboutthism atter.l
PR O BA BLE CAUSE

TheJv /c/leck Protection Pros am

TheCoronavirusAid,Relief,andEconomicSecurity (iICARES'')Actisafedeml
law enacted in oraround M arch 2020 and designed to provide em ergency financialassistance to

the m illions of A mericans who are suffering the econom ic effects caused by the CO VlD-19

pandemic.One sourceofreliefprovided bytheCARES Actwastheauthorizmtion ofup to $349

billionintbrgivableloanstosmallbusinessesforjobretentionandcertainotherexpenses,through
a prog am referredtoasthePPP.Inoraround April2020,Congressauthorized over$300billion
in additionalPPP funding.
ln order to obtain a PPP loan, a qualifying btlsiness must subm it a PPP loan

application, which is signed by an authorized representative of the business. The PPP loan

application requires the business(through its authorized representative) to acknowledge the
program rulesand m ake certain affirmative certitk ations in orderto be eligible to obtain the PPP

loan. In thePPP Ioan application,thesmallbusiness(through itsauthorizedrepresentative)must

state,amongotherthings,its:(a)averagemonthlypayrollexpenses;and(b)numberofemployees.
These figuresare used to calculate the am ountofm oney the sm allbusiness is eligible to receive
under the PPP. ln addition, busintsses applying for a PPP loan m ust provide docum entation
show ing theirpayrollexpenses.

The conductand charges described in thisA ffidavit are partofa larger investigation that
is being conducted in this D istrict and elsewhere. A s a result,not allnum bered sources and
anonymous individualsand entities are described in every filing. Ihave included in thisAffidavit
only those individualsand entities1have deemed necessary to explain the particularfactssetforth
here.
Page3 of 13

A PPP loan application m ustbe processed by a participating lender. lfa PPP loan

application isapproved,the participating lenderfunds the PPP loan using itsown monies, which

are 100% guaranteedby the SmallBusinessAdm inistration (dçSBA'').Datafrom theapplication,
including information aboutthe borrow er,the totalam ountofthe loan,and the listed num berof
em ployees,istransm itted by the lenderto the SBA in the course ofprocessing the loan.
PPP loan proceeds mustbe used by the businesson certain perm issible expensespayrollcosts,intereston mortgages,rent,and utilities. The PPP allow sthe interestand principal
on the PPP loan to be entirely forgiven ifthe business spendsthe Ioan proceedson these expense

item sw ithin a designated period oftim e afterreceiving the proceedsand usesa certain anzountof
the PPP loan proceeds on payrollexpenses.

The Schem e to Obtain FraudulentPPP Loans

10.

On oraboutM ay l3,2020,Phillip J.Augtlstin (çbAugustin'')and CHS 2 worked

togetherto subm ita fraudulentPPP loan application on behalfofa com pany owned by A ugustin.

Augustin submitted a PPP loan of$84,515toa federally insured bank (hereinafterGsBank 3'5),
through a third-party company processor (hereinafter ççBank Processor 1'').2 The application
included bank statementsthatare clearforgeries,and CHS 2 hasadm itted thatthe application was
based on docum entsthathe fatsified tbrA ugustin.3

2
A11 banks referenced in this AfGdavit are insured by the Federal D eposit lnsurance
Corporation.

On June 25,2020,investigatorsarrested CH S 2 and anotherperson now cooperating with

theinvestigation(tSCHS39')and executed searchwarrantsattheirresidences.Followinghisarrest,
CH S 2 chose to cooperate with the investigation in the hope ofobtaining favorable consideration
in connection with hispending charges. CHS 2 w as interviewed on thatday,and hascontinued to
cooperate w ith the investigation afterobtaining counsel. M ostof his statements related herein
have been corroborated by recordsobtained from third parties or recovered from his electronic
devices.

Page 4 of13

1l.

Follow ingthe successofthatinitialfraudulentPPP application,A ugustin and CH S

2 began to work on obtaining m ore and larger PPP loans fbr Augustin's associates and others,

generally forseveralhundredthousanddollarsforeach loan,up toasmuchasapproximately$1.24
m illion. Based on the evidence investigators have reviewed so far, CH S 2 and Augustin

collectively coordinatedapplicationsforPPP loansthataretogetherworth morethan $24 million

dollars.Theevidencealso showsmanymorePPP loanswereattempted butrejectedbybanksor
their partners,or w ere planned and prepared, but not subm itted before CH S 2's arrest. The
evidence suggests that alI or nearly all of those loan applications were fraudulent, including

Defendant'sloan application and the applicationsDefendantorchestrated by refeningadditional
confederatesto the conspiracy.
Investigators have obtained m any other PPP loan applications that CHS 2 has
adm itted he subm itted aspartofthisschem e,based on falsified docum ents,and have also obtained

draftdocum entsused orintended to be used inthose applicationsorothers. These applicationsa1l
follow the sam e pattern of fraud- m any w ith obviously counterfeit February 2020 bank

statements,and allwith fabricated IRS Forms 94l (titled,CtEmployer's Quarterly FederalTax
Return'')withthesameindiciaoffraudfound in Augustin'sinitialapplication butgenerally with
even larger inflated payrollnum bers,thus yielding m uch larger loans.4 CH S 2 has explained to

investigatorsthatthe figures in the Form s941 were the productofa form ula thatallow ed him to
startw ith a targetloan am ount,and then çûback into''thepayrollfigureson theform . Ht explained
how he used figuresthatwould produce an average m onthly payrollfor2019 that, when m ultiplied
by 2.5,would yield the requested loan amount. ln turn,the num ber ofem ployees reported was

Some loan applications also included voided checksthatappear to be falsitsed, such asa

purportedBank5checkthatappearstohavebeenproducedonacomputerand,asthesubjectline

reads,itconverted to PDF,''ratherthan a scan ofan authentic check.
Page 5 of13

chosen based on tk tionalpayrollfigures,chosen to avoid an average employee salary thatm ight
raise suspicion.

CH S 2 has also explained that he tried to use bank statem ents show ing that the

company had a large balance. Because so few companies had such a statem ent,and likely also
because itw aseasierthan keeping track oftheirtrue statelnents,CH S 2 repeatedly subm itted nearreplicasofthe same falsified bank statements.ln particular,CH S 2 appearsto have recycled one
statementeach from Bank 1,Bank 6,and Bank 7. In recycling a statem ent, CHS 2 generally
changed only the account nunlber and the accotlnt holder's nam e and address,such that each

version ofthe statem enthad identicalfiguresand line itemsthroughoutthe statem ent.
14.

A review ofrecordsforbank accountscontrolled by CH S 2 atBank 5 confirm CH S

2's adm issionsthat he received num erouskickbacks,often ofapproxim ately 25% ofthe am ount
ofthe loans,and thathe regularly w ired A ugustin a share ofthatkickback in the early stagesof
the schem e. CH S 2 explained thatthey were doing so many loans by the end of M ay thathe
changed course,instead w iring larger lump sum s.collecting Augustin's shares of the kickbacks
formultiple loansin one w ire.
Investigators are stillreceiving and analyzing records,butbased on a prelim inary

analysis,asofJuly 24,2020,investigatorshad identified a totalof$2,367,765.82 in transfersto
CH S 2'saccounts from entitiesthat each obtained a sizzble PPP loan and thatwere identified in
the PPP filesseized from CH S 2'sand anotherco-conspirator'sresidences,asdescribed below
orfrom individualsassociated w ith those entities.
The PPP loans identified above as im plicated in the foregoing kickback paym ents
to CH S 2 representonly a fraction of the overallschem e. ln executing search wanants atthe
respective residences of CH S 2 and CHS 3,federalagents found stacksofpaperprinted outand

Page 6 of13

organized by entity,containing an 'sintake form ,''fabricated Form s 941,or both foreach entity.
The intake fbrms contained fields for the information needed to fabricate the docum entsand fill
outother aspectsofthe PPP application:identifying inform ation aboutthe ow ner and company,

aswellasbank accountinform ation forreceivingthe Ioan.A section atthe end m arked (IBELOW
IS OFFICE U SE ON LY''included blank fieldsforthe iix umberofEmployees,''tsM onthly Payroll
Expense,''and tSSBA Loan Pre-ApprovalAm ount.'' Between CH S 2's and CH S 3's residences,
investigatorsseized paperfilesforPPP loan applicationsforapproxim ately 80 differententities.
Data obtained fron: the SBA show ed additional PPP loan applications from

additional entities that text m essage and em ailrecords show had been referred to CH S 2 by

Defendantorotherindividuals.

TheFraudulentPPP Loan to Defendant'sC'
tavlplap:Five#/Iz,
ç

18. AccordingtoFlorida'sDivisionofCorporationswebsite(%ssunbiz''),FivePluswas
incorporated in 20 l8 w ith its listed principaladdress in M iam i,Florida. M CKEN ZIE is listed on
Sunbiz asone offive m anagersofFive Plus w ith a separate address in M iam iGardens,Florida.
According to separate bank records,on or about M ay 26, 2020, M CKENZIE opened a bank
accountin the nam e Five Plusand listed him selfasthe sole signatory on the account.
19.

From on oraboutM ay 16,2020 through on oraboutM ay l9,2020,an application

and supporting documents fora PPP loan w ere electronically subm itted on behalfofFive Plusto

Bank 2 through Bank Processor 1.The submitted documents kw luded,among othtrthings:(1)

purported Forms941forallfourquartersof2019;(2)acompanybank statementforFivePlus;
and (3)twoblank checks.
20.

Thepurported Forms94lshow quarterlypayrollofalmost$300,000each quarter,

for 10 em ployees. Each w as signed by hand w ith the name ttDam ion M cKenzie''asthe com pany

Page 7 of13

ow ner,and also listed M CKEN ZIE asthe com pany'sdesignee and as a %%paid Preparer,''though
he is nota paid tax preparer. The Five Plus Form s 941 fbllow the sam e style and pattern asthe

m any otherfalsified Form s94lthatCH S 2,described above,acknow ledged thathe helped create
and subm itin the course ofthe schem e,including in the indicia offraud.s IR S recordsshow that
Five Plus did not,in fact,file any Folnns 941 forany quarterof2019 orthe firstquarterof 2020,

and Florida Departm ent of Revenue records show that Five Plus did not report any wages or
employeesforthatsame period.
The purported company bank statem ent,w hich was subm itted in electronic,PDF

form at,is a clearforgery. First,the statem entisnotfrom Five Plus'sbank. Second,according to
the docum ent'sfile dtprom rties,''the statem entw ascreated using t'PDFFILLER ,''a program used
to editelectronic PDF Gles,and wasiûmodified using i'Ikxt.''
22.

ln a letterdated June 2,2020,Bank Processorl inform ed M CK EN ZIE thathisPPP

loan application wasrejected. The following reason wasstated on the letterfortherejection:
i'Unable to verify Applicant's identity from docum ents subm itted ordiscrepancies in inform ation
subm itted.''

5
A snoted above,M CK ENZIE waslisted asb0th ownerand paid preparer.D ozensofother
Forms 941 subm itted in this scheme evidence the sam e error. CH S 2 has adm itted thatthese

documentssharethatfeaturebecause hemisunderstood the form,and he (orsomeone following
hisinstructions)prepared alloftheForms941atissue. Thecontentofthe formsalso indicate
falsification. A llfour quarterly form s are nearly identical,and the four form s for Five Plus are
identical,down to thepenny,in reported figures.They also evidence apattern ofpayrollspending
thatislikely false:each ofthe quartersshow sincreases from the firstto second to third month of
the quarter. Foreach identicalform ,the sam e figuresare reported forthe tax liability incurred in

thefirstmonth ofeach quarter,the same figure forthe second month ofeach quarter(increased
from thefirstmonth),and thesameGgureforthethird monthofeach quarter(increased from the
second month). The resultisthatthe company reportsa perfectly rem ating cycle ofascending
payrollcostsw ithin each quarter,dropping dow n again atthe startofthe nextquarter. CHS 2 has
explained thatthiswasdue to a form ula he used,allocating differentpercentagesofthe quarterly
payrolltax liability to each month ofeach quarter.
Page 8 of 13

CHS 2 Confl
-rmedtoLaw EnforcementthattheFive#/1u PppLoanApplication PZ
W,
N
Fraudulent
23.

lnvestigators spoke w ith CHS 2 aboutM CKEN ZIE and the Five Plus PPP loan.

CHS 2 stated thathe had m etM CKEN ZIE through A ugustin. According to CH SZ,the three of
them had discussed M CKEN ZIE'S PPP loan, as well as M CKEN ZIE'S referrals, for which
M CK ENZIE would receive a sm allcut. As stated above,CH S 2 and A ugustin had already agreed
to share the 25% kickback paym entsthatCH S 2 would usually receive from referrals,including
from M CKEN ZIE'Sreferrals.

24.

A s to the Five Plus PPP loan,CH S 2 confirm ed that the loan application w as

fraudulent.CHS2 statedthathe:(1)createdforM CKENZIE anonlineaccountforFivePluswith
Bank Processor 1;(2)created and submitted the fake Five Plusbank statement;and (3)created
and subm itted the false Form s 941. According to CHS 2,however,he em ailed the Form s 941to

M CKENZIE unsigned,andthenMCKENZIE tmailedtheformsbacktohim withsignatures.(As
described below ,1have reviewed em ails that appearto corroborate CHS 2's description of this

emailexchange.)

25. AccordingtoCHS2,MCKENZIE'SPPP loanapplicationwasultimatelyrejected.
IP session records from Bank Processor l corroborate CH S 2's statementthathe

assisted w ith the subm ission oftht Five Plus loan application. Bank Processor1's IP recordsfor

thatloanapplicationshow thatacomputerwithanIPaddress(endingin 170)associatedwithCHS
2'sresidence in Brow ard County,Florida,logged into the Five Plusloan accountasearly asM ay

16,2020. The session recordsalso revealsubsequentloginsby the same IP address(ending in
l70),aswellasby acomputerassociatedwiththeBrowardCountyresidenceofoneofAugustin's

associates,and by mobiledevices.Oneofthostmobiledevices(with an IP addrtssingending in

Page 9 of 13

250)logged into the Five Plus loan accountasearly as M ay 16,2020,and,according to bank
records,also accessed M CKEN ZIE'Spersonalbank accountthatday.
27.

CH S 2 also stated that,in addition to the Five Plus loan,M CK ENZIE referred to

him a num beroffl-iends/associatesforthepurpose ofcreatingand subm itting additionalfraudulent

PPP loans. As stated above,CH S 2 and A ugustin w ould generally share the kickback paynw nts
forthese referm ls.CH S 2 stated that,atsom e pointin the schem e,A ugustin instructed him notto
pay M CKENZIE a portion of the kickback paym ents thatCH S 2 received from M CKEN ZIE'S
referrals.A ccordingto CH S 2,w hen M CKEN ZIE would inquireaboutnotreceiving hiscut,CH S
2 w ould referhim to Augustin.

Emailsand TextM essazesCba/irvlM CKENZIE 'SKnowinq Participation in the Fraud
28.

As partof its investigation,Iaw enforcem ent obtained cornm unications between

CH S 2 and M CKEN ZIE,including textm essagesand emails. lhave reviewed a numberofthese
com m unications,which discuss,among otherthings,M CKENZIE'S PPP loan and the Ioansfor
individuals M CKEN ZIE referred to CH S 2.
29.

On oraboutM ay l5,2020,CH S 2 em ailed M CKEN ZIE Form s 94l forFive Plus

forallfourquartersof20l9. The fonnswere filled out(including stating thatFivePlushad 10
employees and almost $300,000 in quarterly payroll) but were not signed. The same day,
M CKEN ZIE em ailed CH S 2 sir ed copiesofthe fourForm s941.
On or about M ay 16,2020,M CK ENZIE forwarded CH S 2 an em ailfrom Bank
Processor l titled,'ûYour Paycheck Protection Program loan has been subm itted.'' The em ail
stated,in part:llDam ion,Yourapplication w assenttothe SBA to beprocessed. Basedon capacity,
the SBA m ay take up to a few daysto processyourapplication.''

Page 10 of13

31.

On oraboutM ay 20,2020,M CKENZIE texted CHS 2:ûç-rhey said the voided check

isunderreview once they done they w illemail.'' M CK EN ZIE then texted:$(Idonthavea business

accountforthisbusinessiam goingtotrytogetoneopentodayjustincasethey askforit.''
32.

On or about M ay 19, 2020, M CKENZIE texted CH S 2 w ith inform ation that

appearstorelatetoadiffemntfraudulentloanapplication,including:(1)asocialsecuritynumber;
(2)dateofbirth;(3)emailaddress;and (4)employeridentificationnumber(i:EIN'').Laterthat
day,MCKENZIE textedCHS2:ibcanyouget(NAME REDACTEDIat$290k?''
33.

On oraboutM ay 19,2020,CH S 2 separately em ailed M CK EN ZIE a blank intake

inform ation form to be filled outw ith the personaland business inform ation for M CKEN ZIE'S

referrals.Andinaseparatetextmessage,CHS2stated:$iIjustsentyouafonmtof5lloutwitheach
clientitseasierwith usto upload application we are swamped A lso ifthe corp and hom e address

arethesamejustputsameoncorpaddress.'' OnoraboutMay 2l,2020,MCKENZIE emailed
CH S 2 com pleted intake forms regarding two referrals.
During my review ofM CKEN ZIE'S comm unications w ith CH S 2,l found what
appearsto be inform ation pertaining to atleastten differentpeople and corporate entities. Further

investigation, including review of data collected by the SBA and bank records, to date has

identified PPP loanstotaling morethan $3.3 millioncorrespondingtothese namesand entities.
BankRecordsConfirm M CKENZIE'SKnowinz Participation in theFraud
35.

l have reviewed CH S 2's bank records,which reflectpaym ents to CHS 2 from

MCKENZIE'S referrals as wellas payments by CHS 2 to Augustin (who had brought in
M CKENZIE to the scheme). Forexample,on oraboutM ay 26,2020,CHS 2 received a wire
transfkr in the amount of $122,155 related to a PPP application in the name ofa company

(hereinafter'Ecompany 14'')thatM CKENZIE had referred to CHS 2. The same day,from that

Page 11 of13

sameaccount,CHS2wired $39.970into oneofAugustin'sbankaccounts.CHS2 contirmedthat
the paym entto Augustin represented his share ofthe kickback from Company 14.6
Bank recordsand textm essagesalso reflectpaym entsdirectly to M CKEN ZIE from

hisreferrals,follow ed by paym ents from M CKEN ZIE to CHS 2. Forexam ple,on June 8,2020,

CH S 2 provided M CKEN ZIE w ith his bank account inform ation via text m essage and stated:
ltAfter yourm oney send m e 80k.'' M CKENZIE responded,ifOk.'' Separately,on oraboutJune

8,2020,M CKENZIE deposited two checks in the amounts of $85,000 and $90,000 from a
company M CKEN ZIE had referred to CH S 2. On oraboutJune l1,2020,CH S 2 received a wire

transferin theamountof$80,000directly from FivePlus.Thatsameday,from the sameaccount,
CHS 2 wired $40,000 to one ofAugustin'sbank accounts.CHS2 explained to investigatorsthat
the $80,000 tmnsferwasin connection with one ofM CKENZIE'Sreferrals,who had wired the
kickback paym entdirectly to M CK ENZIE instead ofCH S 2.

Other banking records show deposits consistent w ith M CKEN ZIE receiving
additionalkickbacks. Betw een approximately M ay 26,2020 and July 2,2020,M CK EN ZIE

received payments of$20,000,$5,000,and $45,000 from three separate companies. Diflkrent
banking recordsshow CH S 2 received separate paym entsfrom each ofthose three com panies.

Bankrecordsshow thaton M ay 26,2020,thesame day CHS 2 paid $39,970toAugustin,

CHS2alsomadeapurchaseatajewelrystoreintheamountof$73,000.
Page 12 of13

CO NCLUSIO N
Based on the fbrgoing,Irespectfully subm itthatthere isprobable causeto believe

thatDAM ION M CKENZIE committed theTargetOtlknses.
FIJRTHER YOtJR AFFIA NT SA YETIINA UGHT.
M ICHA EL BENIVEGNA
SpecialAgent
IRS-CI

A ttested to by the applicantin accordance
with the rtquirem ents ik
'ed. R.Crim .P.4.1
by telephone on this
Day ot-August, 2020

$x. z

IION.PATRIC K M ,HUNT
UNITED STATES M AGISI'RATF,JU I7Gl:,'

Page 13of13

Troy T. Walker

Aug 3, 2020

File and source

File: CRIM_FLSD_unknown_US-v-Damion-Mckenzie_docX_COMPLAINT.pdf
Size: 823,218 bytes
SHA-256: a59ec6292cabb684ad8a19916cd74721d9cc0c456b9affbc8cc3d5813efbcc80
Our copy: CRIM_FLSD_unknown_US-v-Damion-Mckenzie_docX_COMPLAINT.pdf
Original: www.justice.gov