Indictment — United States v. Daragjati

Record facts

U.S. District Court, Middle District of Florida (Jacksonville Division) · No. 3:23-cr-00048-TJC-LLL · Doc. 1 · 2023-03-22 · Docket on CourtListener

Full text

FILED

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA 3 HAR22 PM 3:18

JACKSONVILLE DIVISION ny yn punwiay envi

UNITED STATES OF AMERICA JACKSONVILLE FLORIDA
v. ‘CASE NO. 3:23-cr-4-8-~T JC
CHRISTOPHER LEO DARAGJATI 18 U.S.C. § 1343

18 U.S.C. § 1028A

42 U.S.C. § 408

18 U.S.C. § 641

INDICTMENT
The Grand Jury charges:

COUNTS ONE - THREE
(Wire Fraud)

A. Introduction

At all times relevant to this Indictment:

Ls The defendant resided in the Middle District of Florida.

2. Itria Ventures LLC (‘“Itria”) was a financial services company that
among other services assisted businesses in accessing the Small Business
Administration Paycheck Protection Program.

>. Itria utilized a loan application portal in the state of New York, as part
of conducting nationwide business operations.

4. Prestamos Community Development Financial Institution
(“Prestamos”) was a financial services company that among other services assisted

businesses in accessing the Small Business Administration Paycheck Protection
Program. Prestamos worked with Blue Acorn to access the Small Business
Administration Paycheck Protection Program.

o Blue Acorn was a lending service that among other services worked
with companies to assist businesses in accessing the Small Business Administration
Paycheck Protection Program.

6. Blue Acorn utilized computer servers / data centers in the state of
Virginia, as part of conducting nationwide business operations.

7. Cross River Bank (“Cross River’) was a financial services company
with computer servers located in Pennsylvania that among other services assisted
businesses in accessing the Small Business Administration Paycheck Protection
Program. Cross River worked with Revenued to access the Small Business
Administration Paycheck Protection Program.

8. Revenued was a lending service headquartered in New Jersey that
among other services worked with companies to assist businesses in accessing the
Small Business Administration Paycheck Protection Program.

The Small Business Administration

9. The United States Small Business Administration (“SBA”) was an
executive branch agency of the United States government that provided support to
entrepreneurs and small businesses.

10. The SBA enabled and provided for loans through banks, credit unions,
and other lenders. These loans had government-backed guarantees. In addition to

traditional SBA funding programs, The CARES Acct, established several new
temporary programs and provided for the expansion of others to address the
COVID-19 outbreak.

The Paycheck Protection Program

11. One of the new programs was the SBA Paycheck Protection Program
(“PPP”), which was a loan designed to provide a direct incentive for small businesses
to keep their workers on the payroll. Under this program, the SBA could forgive all
or part of a loan, if employees were kept on the payroll for eight weeks and
borrowers submitted documentation confirming that the loan proceeds were used for
certain qualifying business expenses (i.e., payroll, rent, mortgage interest, or utilities).

12. The PPP application process required interested applicants to
electronically submit a SBA Form 2483 - Borrower Application Form (“SBA Form
2483”). The application contained information as to the purpose of the loan, average
monthly payroll, number of employees, and background of the business and its
owner. Applicants were also required to make certain good faith certifications,
including that economic uncertainties had necessitated their loan requests for
continued business operations, and that they intended to use loan proceeds only for
the authorized purposes.

13. Further, when submitting the SBA Form 2483, the authorized
representative certified his understanding that, should the PPP funds be knowingly
used for unauthorized purposes, the United States could hold him legally liable,
including for charges of fraud. The applicant was also required to certify the truth

and accuracy of any information provided on the SBA Form 2483 and in all
supporting documents, to include any documents intended to verify the applicant’s
payroll expenses. The applicant was required to certify an understanding that
knowingly making a false statement to obtain a guaranteed loan from the SBA is
punishable under the law and subject to criminal penalties.

B. The Scheme and Artifice

14. Beginning on an unknown date, but no later than in or around February
2021, and continuing through at least in or around June 2021, in the Middle District
of Florida and elsewhere, the defendant,
CHRISTOPHER LEO DARAGJATI,
knowingly devised and intended to devise a scheme and artifice to defraud, and to
obtain money and property by means of materially false and fraudulent pretenses,
sepriventariemy, and promises.

C. Manner and Means of the Scheme and Artifice

15. |The manner and means by which the defendant sought to accomplish
the scheme to defraud included, among others, the following:

Itria Ventures LLC

a. It was part of the scheme and artifice that the defendant would
and did fraudulently complete an IRS Form 940 for 2019: Employer’s Annual
Federal Unemployment Tax Return (“IRS Form 940”) for purposes of applying for a

PPP loan to which he was not entitled;
b. It was further a part of the scheme and artifice that when
fraudulently completing the IRS Form 940 the defendant used the identity of another
person, J.W.;

Ci; It was further a part of the scheme and artifice that when
fraudulently completing the IRS Form 940 the defendant, using the identity of
another person, J.W., declared under penalties of perjury that the IRS Form 940 was
true, correct, and complete;

d. It was further part of the scheme and artifice that the defendant
would and did fraudulently complete an IRS Form 941 for 2020: Employer’s
Quarterly Federal Tax Return (“IRS Form 941”) for purposes of applying for a PPP
loan to which he was not entitled;

e; It was further a part of the scheme and artifice that when
fraudulently completing the IRS Form 941 the defendant used the identity of another
| person, J.W.;

f. It was further a part of the scheme and artifice that when
fraudulently completing the IRS Form 941 the defendant, using the identity of
another person, J.W., declared under penalties of perjury that the IRS Form 941 was
true, correct, and complete;

g. It was further part of the scheme and artifice that the defendant
would and did fraudulently complete an Itria “Loan Agreement for Paycheck
Protection Program Loan” (“Loan Agreement”) for purposes of applying for a PPP

loan to which he was not entitled;
h. It was further a part of the scheme and artifice that when
fraudulently completing the Loan Agreement the defendant used the identity of
another person, J.W.;

i. It was further a part of the scheme and artifice that when
fraudulently completing the Loan Agreement the defendant, using the identity of
another person, J.W., stated that he truthfully answered all of the questions and
certifications on the borrower application;

i? It was further part of the scheme and artifice that the defendant
would and did fraudulently complete an Itria “Paycheck Protection Program
Promissory Note” (“Promissory Note”) for purposes of applying for a PPP loan to
which he was not entitled;

k. It was further a part of the scheme and artifice that when
fraudulently completing the Promissory Note the defendant used the identity of
another person, J.W.;

1. It was further part of the scheme and artifice that the defendant
would and did fraudulently complete an Itria “Authorization for PPP Loan
Disbursement and ACH Debits” (“Authorization for Disbursement”) for purposes of
applying for a PPP loan to which he was not entitled;

m. __ It was further a part of the scheme and artifice that when
fraudulently completing the Authorization for Disbursement the defendant used the

identity of another person, J.W.;
n. It was further part of the scheme and artifice that the defendant
would and did fraudulently complete a PPP loan application, that is, a SBA Form
2483 - Borrower Application Form for purposes of applying for a PPP loan to which
he was not entitled;

O. It was further a part of the scheme and artifice that when
fraudulently completing the SBA Form 2483 - Borrower Application Form the
defendant used the identity of another person, J.W.;

p. It was further a part of the scheme and artifice that when
fraudulently completing the SBA Form 2483 - Borrower Application Form, using the
identity of another person, J.W., the defendant falsely represented his Social Security
number as a certain Social Security number ending in XXX-XX-5692;

q. It was further a part of the scheme and artifice that, in order to
induce the SBA and Itria to fund a PPP loan, the defendant would and did submit,
using the identity of another person, J.W., a false and fraudulent PPP loan
application that included multiple materially false and fraudulent representations and

pretenses, such as:

1. the average monthly payroll and the number of employees;
. di listing that the purpose of the loan was ‘to cover payroll
costs; |
ill. listing himself as the owner of the business;
iv. certifying that the funds will be used to retain workers and

maintain payroll; and
V. certifying the truth of the statements in the loan
application;

r. It was further part of the scheme and artifice that the defendant
would and did send Itria a copy of a fraudulently obtained Florida Identification
Card in the identity of another person, J.W., but with a picture of the defendant on
it;

S. It was further a part of the scheme and artifice that the defendant
would and did send Itria information about an account at Middlesex Federal Savings
that the defendant fraudulently opened in the identity of J.W. into which the
fraudulently obtained PPP loan proceeds, money, could be transferred via an ACH
payment/wire transfer;

t. It was further a part of the scheme and artifice that the defendant
would and did cause Itria to send PPP loan proceeds, money, via an ACH/wire
transfer to an account at Middlesex Federal Savings that he fraudulently opened in
the identity of J.W.;

Prestamos Community Development Financial Institution

u. It was further a part of the scheme and artifice that the defendant
would and did fraudulently complete an IRS Form W-9 Request for Taxpayer
Identification Number and Certification (“IRS Form W-9”) for purposes of applying

for a PPP loan to which he was not entitled;
V. It was further a part of the scheme and artifice that when
fraudulently completing the IRS Form W-9 the defendant used the identity of
another person, C.H.;

w. _ It was further a part of the scheme and artifice that when
fraudulently completing the IRS Form W-9 the defendant, using the identity of
another person, C.H., certified under penalties of perjury that the number shown on
the form was his correct taxpayer identification number;

Ki It was further part of the scheme and artifice that the defendant
would and did fraudulently complete an IRS Form 1040 Schedule C Profit or Loss
From Business (“IRS Form 1040”) for purposes of applying for a PPP loan to which
he was not entitled;

y. It was further a part of the scheme and artifice that when
fraudulently completing the IRS Form 1040 the defendant used the identity of
another person, C.H.;

Z. It was further part of the scheme and artifice that the defendant
would and did fraudulently complete a PPP loan application, that is, a SBA Form
2483-SD Second Draw Borrower Application Form for purposes of applying for a
PPP loan to which he was not entitled;

aa. It was further a part of the scheme and artifice that when
fraudulently completing the SBA Form 2483 — SD Second Draw Borrower

Application the defendant used the identity of another person, C.H.;
bb. It was further a part of the scheme and artifice that when
fraudulently completing the SBA Form 2483 — SD Second Draw Borrower
Application, using the identity of another person, C.H., the defendant falsely
represented his Social Security number as a certain Social Security number ending in
XXX-XX-1703;
Gc. It was further a part of the scheme and artifice that, in order to
induce the SBA and Prestamos to fund a PPP loan, the defendant would and did
submit, using the identity of another person, C.H., a false and fraudulent PPP loan
application that included multiple materially false and fraudulent representations and
pretenses, such as:
L, the average monthly payroll and the number of employees;
ii. listing that the purpose of the loan was to cover payroll

costs, rent/mortgage interest, utilities, and covered operations expenditures;

ill. listing himself as the owner of the business;
iv. certifying that the funds will be used to retain workers and
maintain payroll;
V. certifying the truth of the statements in the application;

and

dd. It was further part of the scheme and artifice that the defendant
would and did send Prestamos a copy of a fraudulently obtained Florida
Identification Card in the identity of another person, C.H., but with a picture of the

defendant on it;

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ee. It was further part of the scheme and artifice that the defendant
would and did send Prestamos a picture of himself, but using the identity of C.H.;

ff. It was further a part of the scheme and artifice that the defendant
would and did send Prestamos information about an account at Fairwinds Credit
Union that the defendant fraudulently opened in the identity of C.H. into which the
fraudulently obtained PPP loan proceeds, money, could be transferred via an ACH
payment/wire transfer;

gg. It was further a part of the scheme and artifice that the defendant
would and did cause Prestamos to send PPP loan proceeds, money, via an
ACH/wire transfer to an account at Fairwinds Credit Union that he fraudulently
opened in the identity of C.H.;

hh. It was further a part of the scheme and artifice that the defendant
would and did retain fraud proceeds from the three above referenced PPP loans for
the defendant’s personal enrichment and entertainment;

il. It was further a part of scheme and artifice that the defendant
would and did perform acts, and make statements to promote and achieve the object
of the scheme and artifice and to misrepresent, hide, and conceal, and cause to be
misrepresented, hidden, and concealed, the purpose of the scheme and artifice and
the acts committed in furtherance thereof.

Cross River Bank

jj. It was further part of the scheme and artifice that the defendant

would and did fraudulently complete an IRS Form 1040 Schedule C Profit or Loss

ll
From Business (“IRS Form 1040”) for purposes of applying for a PPP loan to which
he was not entitled;

kk. It was further a part of the scheme and artifice that when
fraudulently completing the IRS Form 1040 the defendant used the identity of
another person, C.H.;

Il. It was further part of the scheme and artifice that the defendant
would and did fraudulently complete a PPP loan application, that is, a SBA Form
2483 - Borrower Application Form for purposes of applying for a PPP loan to which
he was not entitled;

mm. It was further a part of the scheme and artifice that when
fraudulently completing the SBA Form 2483 - Borrower Application Form the
defendant used the identity of another person, C.H.;

nn. It was further a part of the scheme and artifice that when
fraudulently completing the SBA Form 2483 - Borrower Application Form, using the
identity of another person, C.H., the defendant falsely represented his Social Security
number as a certain Social Security number ending in XXX-XX-1703;

00. It was further a part of the scheme and artifice that, in order to
induce the SBA and Cross River to fund a PPP loan the defendant would and did
submit, using the identity of another person, C.H., a false and fraudulent PPP loan
application that included multiple materially false and fraudulent representations and

pretenses, such as:

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1. the average monthly payroll and the number of employees;
il. listing that the purpose of the loan was to cover payroll;
ill. listing himself as the owner of the business;
iv. certifying that the funds will be used to retain workers and
maintain payroll;
V. certifying the truth of the statements in the application;

and

pp. It was further part of the scheme and artifice that the defendant
would and did send Cross River a copy of a fraudulently obtained Florida
Identification Card in the identity of another person, C.H., but with a picture of the
defendant on it;

qq. It was further a part of the scheme and artifice that the defendant
would and did send Cross River information about an account at Metropolitan
Commercial Bank in the identity of C.H. into which the fraudulently obtained PPP
loan proceeds, money, could be transferred via an ACH payment/wire transfer;

rr. It was further a part of the scheme and artifice that the defendant
would and did cause Cross River to send PPP loan proceeds, money, via an
ACH/wire transfer to an account at Metropolitan Commercial Bank in the identity

of C.H.;

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D. Execution of the Scheme and Artifice

16. Onor about the dates set forth below in each count, in the Middle
District of Florida, and elsewhere, for the purpose of executing the aforesaid scheme
and artifice, and attempting to do so, the defendant,

CHRISTOPHER LEO DARAGJATI,
did knowingly transmit and cause to be transmitted by means of wire in interstate

commerce the following:

COUNT DATE ACH/ WIRE TRANSACTION
ONE February 5, Transfer of PPP loan proceeds from Itria to an account at
2021 Middlesex Federal Savings that the defendant controlled

in the amount of $111,107.50

TWO March 3, 2021 | Transfer of PPP loan proceeds from Cross River to an
account at Metropolitan Commercial Bank that the
defendant controlled in the amount of $19,733

THREE June 10,2021 | Transfer of PPP loan proceeds from Prestamos to an
account at Fairwinds Credit Union that the defendant
controlled in the amount of $19,732

In violation of 18 U.S.C. § 1343.

COUNTS FOUR - SIX
(Aggravated Identity Theft)

17. Onor about the dates set forth below, in the Middle District of Florida,

and elsewhere, the defendant,
CHRISTOPHER LEO DARAGIJATI,

did knowingly possess and use without lawful authority, a means of identification of

another person, that is, the Social Security number of the individuals listed below,

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Case 3:23-cr-00048-TJC-LLL

Document 1

Filed 03/22/23

Page 15 of 25 PagelD 15

during and in relation to a felony enumerated in 18 U.S.C. § 1028A, that is, wire

fraud, in violation of 18 U.S.C. § 1343, and falsely representing a Social Security

number, in violation of 42 U.S.C. § 408(a)(7)(B), as described below:

COUNT DATE PPP LOAN SOCIAL SECURITY | INDIVIDUAL .
LENDER NUMBER

FOUR February 2, Itria XXX-XX-5692 LW.
2021

FIVE March 1, Cross River XXX-XX-1703 CH

2021 _

SIX May 10, 2021 Prestamos XXX-XX-1703 CH.

In violation of 18 U.S.C. § 1028A(a)(1).
COUNTS SEVEN & EIGHT

18.

and elsewhere, the defendant,

(Falsely Representing a Social Security Number)

On or about the dates set forth below, in the Middle District of Florida,

CHRISTOPHER LEO DARAGJATI,

for the purpose of obtaining something of value and for other purposes, did

knowingly and with the intent to deceive another person and organization, falsely

represent to the Florida Highway Safety and Motor Vehicles, Lake County Tax

Collector, and the Orange County Tax Collector, his Social Security number to be a

certain Social Security number, when in fact, as the defendant well knew, that the

certain Social Security number was not assigned to the defendant, as set for below:

15

COUNT DATE LOCATION SOCIAL SECURITY
NUMBER
SEVEN September 11, Lake County XXX-XX-5692
2019 Tax Collector
EIGHT January 20, Orange County XXX-XX-1703
2021 Tax Collector

In violation of 42 U.S.C. § 408(a)(7)(B).

COUNTS NINE EN
(Aggravated Identity Theft)

19. .Onor about the dates set forth below, in the Middle District of Florida,
and elsewhere, the defendant,
CHRISTOPHER LEO DARAGJATI,
did knowingly possess and use without lawful authority, a means of identification of |
another person, that is, the Social Security number of the individuals listed below,
during and in relation to a felony enumerated in 18 U.S.C. § 1028A, that is, falsely
representing a Social Security number, in violation of 42 U.S.C. § 408(a)(7)(B), as

described below:

COUNT DATE LOCATION | SOCIAL SECURITY | INDIVIDUAL
NUMBER
NINE September Lake County XXX-XX-5692 lw.
11, 2019 Tax Collector
TEN January 20, | Orange County XXX-XX-1703 CH
2021 Tax Collector a

In violation of 18 U.S.C. § 1028A(a)(1).

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COUNT ELEVEN
(Theft of Government Property, More Than $1,000)

20. Beginning in or about January 2022, and continuing through in or
about February 2022, in the Middle District of Florida, and elsewhere, the
defendant,

CHRISTOPHER LEO DARAGJATI,
did knowingly and willfully embezzle, steal, purloin, and convert to the defendant’s
use and the use of another, more than $1,000 of money and a thing of value of the
United States and Internal Revenue Service, a department and agency of the United
States, that is, money, with intent to deprive the United States and Internal Revenue
Service of the use and benefit of the money and thing of value by filing a false tax
return using the identity of another person, J.W., and subsequently receiving a tax
refund of more than $1,000 from the Internal Revenue Service.

In violation of 18 U.S.C. § 641.

COUNT TWELVE
(Aggravated Identity Theft)

21. Onor about the date set forth below, in the Middle District of Florida,
and elsewhere, the defendant,
CHRISTOPHER LEO DARAGJATI,
did knowingly possess and use without lawful authority, a means of identification of
another person, that is, the Social Security number of the individual listed below,

during and in relation to a felony enumerated in 18 U.S.C. § 1028A, that is,.theft of

17
government property, the amount being greater than $1,000, in violation of

18 U.S.C. § 641, as described below:

COUNT | DATE OF FALSE | SOCIAL SECURITY | INDIVIDUAL
TAX RETURN NUMBER

TWELVE | January 26, 2022 XXX-XX-5692 IW.

In violation of 18 U.S.C. § 1028A(a)(1).

COUNTS THIRTEEN - SIXTEEN
(Wire Fraud)

A. Introduction

At all times relevant to this Indictment:
22. The defendant resided in the Middle District of Florida.

National Crime Information Center

23. The National Crime Information Center (“NCIC”) is a criminal records
database allowing criminal justice agencies to enter or search for information about
stolen property, missing or wanted persons, and domestic violence protection orders;
to get criminal histories; and to access the National Sex Offender Registry. Criminal
justice agencies to include local, state, and federal law enforcement can enter arrest
warrants for individuals into NCIC.

Sunbelt Rentals

24. Sunbelt Rentals is an equipment rental business that operates
internationally throughout North America. Sunbelt Rentals rents a variety of

equipment ranging from air compressors to different kinds of tools.

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25. Sunbelt Rentals offered customers the ability to apply online for a
commercial credit account. If approved, the commercial credit account authorized
customers to use a line of credit to rent equipment from Sunbelt Rentals.

26. Sunbelt Rentals utilized a credit portal server located in South Carolina,
as part of conducting nationwide business operations.

B. The Scheme and Artifice

27. Beginning on an unknown date, but no later than in or around April
2022, and continuing through at least in or around August 2022, in the Middle
District of Florida and elsewhere, the defendant,
CHRISTOPHER LEO DARAGJATI,
knowingly devised and intended to devise a scheme and artifice to defraud, and to
obtain money and property by means of materially false and fraudulent pretenses,
representations, and promises.

Cc. Manner and Means of the Scheme and Artifice

28. The manner and means by which the defendant aout to accomplish
the scheme to defraud included, among others, the following:

a. It was part of the scheme and artifice that the defendant would
and did fraudulently complete an online application using the identity of another
person, J.W., for a commercial credit account with Sunbelt Rentals for the purposes
of using a line of credit to fraudulently rent equipment from Sunbelt Rentals

involving the business, Master Seal Asphalt;

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D; It was further a part of the scheme and artifice that when
fraudulently completing the online application with Sunbelt Rentals, using the
identity of another person, J.W., the defendant falsely represented his Social Security
number as a certain Social Security number ending in XXX-XX-5692;

ren It was further a part of the scheme and artifice that the defendant
would and did fraudulently complete an online application using the identity of
another person, G.M., for a commercial credit account with Sunbelt Rentals for the
purposes of using a line of credit to fraudulently rent equipnient from Sunbelt
Rentals involving the business, Mix Bros Inc.;

d. It was further a part of the scheme and artifice that when
fraudulently completing the online application with Sunbelt Rentals, using the
identity of another person, G.M., the defendant falsely represented his Social
Security number as a certain Social Security number ending in XXX-XX-4450;

e It was further a part of the scheme and artifice that the
defendant would and did fraudulently complete an online application using the
identity of another person, C.E., for a commercial credit account with Sunbelt
Rentals for the purposes of using a line of credit to fraudulently rent equipment from
Sunbelt Rentals involving the business, Mastermore Properties;

f. It was further a part of the scheme and artifice that when
fraudulently completing the online application with Sunbelt Rentals, using the
identity of another person, C.E., the defendant falsely represented his Social Security

number as a certain Social Security number ending in XXX-XX-9710;

20
g. It was further a part of the scheme and artifice that the defendant
would and did fraudulently complete an online application using the identity of
another person, P.T., for a commercial credit account with Sunbelt Rentals for the
purposes of using a line of credit to fraudulently rent equipment from Sunbelt
Rentals involving the business, Torkelson Inc;

h. It was further a part of the scheme and artifice that when
fraudulently completing the online application with Sunbelt Rentals, using the
identity of another person, P.T., the defendant falsely represented his Social Security
number as a certain Social Security number ending in XXX-XX-3605;

1. It was further a part of the scheme and artifice that, after Sunbelt
Rentals approved the fraudulent online applications for Master Seal Asphalt, Mix
Bros Inc, Mastermore Properties, and Torkelson Inc, the defendant would and did
feaudutlaatly rent a variety of equipment ranging from air compressors to different
kinds of tools, using the identities of J.W., G.M., C.E. and P.T.;

be It was further a part of the scheme and artifice that after the
defendant fraudulently rented a variety of equipment ranging from air compressors to
different kinds of tools, using the identities of J.W., G.M., C.E., and P.T., the
defendant would not return the rented equipment, instead, pawning said fraudulently
rented equipment, resulting in a felony arrest warrant for P.T. being entered into

NCIC by a member of law enforcement;

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E. Execution of the Scheme and Artifice

29. Onor about the dates set forth below, in the Middle District of Florida,
and elsewhere, for the purpose of executing the aforesaid scheme and artifice, and
attempting to do so, the defendant,

CHRISTOPHER LEO DARAGJATI,
did knowingly transmit and cause to be transmitted by means of wire in interstate

commerce the following:

COUNT DATE SUNBELT RENTALS CREDIT PORTAL SERVER

THIRTEEN March 10, Submission of “Application for Credit and Rental
2022 Agreement” in the identity of P.T. for Torkelson Inc

FOURTEEN | March 23, | Submission of “Application for Credit and Rental
2022 Agreement” in the identity of G.M. for Mix Bros Inc

FIFTEEN | April 11, 2022 | Submission of “Application for Credit and Rental
Agreement” in the identity of J.W. for Master Seal
Asphalt

SIXTEEN May 6, 2022 | Submission of “Application for Credit and Rental
Agreement” in the identity of C.E. for Mastermore
Properties

In violation of 18 U.S.C. § 1343.

COUNTS SEVENTEEN - TWENTY
(Aggravated Identity Theft)

30. Onor about the dates set forth below, in the Middle District of Florida,
and elsewhere, the defendant,
CHRISTOPHER LEO DARAGJATI,
did knowingly possess and use without lawful authority, a means of identification of

another person, that is, the Social Security number of the individuals listed below,

22

during and in relation to a felony enumerated in 18 U.S.C. § 1028A, that is, wire
fraud, in violation of 18 U.S.C. § 1343, and falsely representing a Social Security

number, in violation of 42 U.S.C. § 408(a)(7)(B), as described below:

COUNT DATE SOCIAL SECURITY | INDIVIDUAL
NUMBER
SEVENTEEN | March 10, 2022 XXX-XX-3605 P.T.
EIGHTEEN | March 23, 2022 XXX-XX-4450 G.M.
NINETEEN | April 11, 2022 XXX-XX-5692 JW.
TWENTY May 6, 2022 XXX-XX-9710 CA.

In violation of 18 U.S.C. § 1028A(a\(1).

FORFEITURE

Li The allegations contained in Counts One through Three, Eleven,
Thirteen through Sixteen are incorporated by reference for the purpose of alleging
forfeiture pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c).

2. Upon conviction of a violation of 18 U.S.C. § 1343 and/or 18 U.S.C. §
641(c) the defendant shall forfeit to the United States, pursuant to 18 U.S.C. §
981(a)(1)(C) and 28 U.S.C. § 2461(c), any property, real or personal, which

constitutes or is derived from proceeds traceable to the violation.

3. If any of the property described above, as a result of any act or omission
of the defendant:
a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third party;

23
Cc. has been placed beyond the jurisdiction of the court;
d. has been substantially diminished in value; or
é, has been commingled with other property which cannot be

divided without difficulty,
the United States shall be entitled to forfeiture of substitute property pursuant to 21
U.S.C. § 853(p), as incorporated by 28 U.S.C. § 2461(c).
A TRUE BILL,

Foreperson

ROGER B. HANDBERG
United States Attorney

By: a (Wed

KEVIN C. FREIN
Assistant United States Attorney

KELL¥S. KARASE
Assistant United States Attorney
Deputy Chief, Jacksonville Division

24
FORM OBD-34
3/22/23 Revised

Case 3:23-cr-00048-TJC-LLL Document1 Filed 03/22/23 Page 25 of 25 PagelD 25

No.

UNITED STATES DISTRICT COURT
Middle District of Florida
Jacksonville Division

THE UNITED STATES OF AMERICA

VS.

CHRISTOPHER LEO DARAGJATI

INDICTMENT

Violations: CTs 1-3 and 13-16: 18 U.S.C. § 1343
CTs 4-6, 9-10, 12 and 17-20: 18 U.S.C. § 1028A(a)(1)
CTs 7-8: 42 U.S.C. § 408(a)(7)(B)
CT 11: 18 U.S.C. § 641

A true bill,

Foreperson

Filed in open court this _=.=—day

of March, 2023.

Clerk

Bail $

GPO 863 525

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