Criminal information — United States v. David Tyler Hines

Record facts

U.S. District Court, Southern District of Florida · No. 1:21-cr-20011-MGC · Doc. 29 · 2021-01-08 · Docket on CourtListener

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.
18 U.S.C. j 1343
18 U.S.C. j 2
18 U.S.C. j 982(a)(2)(A)
UNITED STATES OF AM ERICA
DAVID TYLER H INES,
Defendant.
INFORM ATION
The United States Attorney charges that:
GENER AL ALLEGATIONS
At all tim es relevant to this lnfonnation:
The defendant, DAVID TYLER H INES, was a resident of M iam i-Dade County,
Florida.
The defendant, DAVID TYLER HINES, served asmanaging member of (a)
Cash in Holding LLC; (b) Promaster Movers, lnc.; (c) Unified Relocation Solutions LLC; and
(d) We-pack Moving LLC (together, the ttl-lines Companies'). The Hines Companies
m aintained barlk accotmts at Bank A in M iami, Florida.
3. 
Bank A was a participating lender of ftmds to sm all businesses under the
Paycheck Protection Program ($1PPP'') in 2020. Under the PPP, the Small Business
Administration agreed to guarantee loans provided by participant lenders under certain
conditions.
21-20011-CR-COOKE/O'SULLIVAN
Jan 8, 2021
SL
Case 1:21-cr-20011-MGC   Document 29   Entered on FLSD Docket 01/08/2021   Page 1 of 8

In order to obtain a PPP loan, an applicant had to subm it an application listing the
number of em ployees and average m onthly payroll expenses for the applicant's company.
Furthennore, the applieant had to eertify that the funds would be used for payroll and other
authorized expenses for the applicant's com pany.
W ire Fraud
(18 U.S.C. j 1343)
From in or around M areh 2020, through in or around June 2020, in M iam i-Dade Cotmty,
in the Southern District of Florida, and elsewhere, the defendant,
DAVID TYLER HINES,
did knowingly, and with intent to defraud, devise and intend to devise a scheme and artifice to
defraud and to obtain money and property by m eans of materially false and fraudulent pretenses,
representations, and promises, knowing that the pretenses, representations, and promises were
false and fraudulent when made, and for the purpose of executing such scheme and artifice to
defraud, did knowingly transmit and cause to be transm itted by means of wire comm unications
in interstate and foreign comm erce, certain writings, signs, signals, pictures, and sounds.
PURPOSE OF THE SCHEM E AND ARTIFICE
lt was the purpose of the schem e and artifice for the defendant and his accomplices to
unjustly enrich themselves by submitting and causing others to submit false and fraudulent PPP
loan applications to financial institutions, including Bank A which falsely certified em ployee
payroll amounts and falsely certified that the funds would be used for payroll and other
authorized expenses- and then using the subsequent loan proceeds for their own personal
benefit.
Case 1:21-cr-20011-MGC   Document 29   Entered on FLSD Docket 01/08/2021   Page 2 of 8

M ANNER AND M EAN S OF THE SCHEM E AND ARTIFICE
The m anner and means by which the defendant, DAVID TYLER HINES, sought to
accom plish the schem e and artitk e to defraud induded, am ong others, the following:
DAVID TYLER H INES subm itted PPP loan applications for each of the Hines
Companies to Bank A seeking several million dollars in funds. HINES falsely claimed in these
loan applications that the Hines Companies had dozens of employees and m illions of dollars in
monthly payroll. H INES submitted false and fraudulent Internal Revenue Service form s as
support fOr those payroll expenses.
6. 
DAVID TYLER HINES received approximately $3.9 million in funds from
Bank A through the PPP loan applications in accounts for the Hines Companies based on the
false and fraudulent loan applications.
DAVID TYLER HINES used the funds received from  the PPP loan applications
for his own personal purposes, including for the purchase of a Lam borghini luxury car and other
personal expenses.
V$E OF THI! W IR:S
On or about M ay 13, 2020, the defendant, for the purpose of executing the aforesaid
scheme and artitice to defraud and to obtain m oney and property by m eans of m aterially false
and fraudulent pretenses, representations, and prom ises, knowing that the pretenses,
representations, and prom ises were false and fraudulent when m ade, did knowingly cause to be
transm itted by m eans of wire com munications in interstate and foreign com merce, certain
writings, signs, signals, pictures and sounds, that is, a wire transfer of approximately $794,835
from Bank A to the account of Cash in Holding LLC at Bank of Am erica in M iami, Florida, in
Case 1:21-cr-20011-MGC   Document 29   Entered on FLSD Docket 01/08/2021   Page 3 of 8

violation of Title 18, United States Code, Sections 1343 and 2.
FORFEITURE
(18 U.S.C. j 982(a)(2)(A))
The allegations of this lnformation are hereby re-alleged and by this reference
fully incorporated herein for the purpose of alleging forfeiture to the United States of America of
certain property in which the defendant, DAVID TYLER HINES, has an interest.
Upon convidion of a violation of Title 18, United States Code, Section 1343, as
alleged in this lnformation, the defendant , shall forfeit to the United States any property
constituting, or derived from , proceeds the defendant obtained directly or indirectly, as the result
of such violation pursuant to Title 18, United States Code, Section 982(a)(2)(A).
The property subject to forfeiture includes, but is not limited to, the following:
a. 
All funds held by Bank of Am erica formerly on deposit in account number
898077556016 held in the nam e of Cash in Holdings LLC;
All funds held by Bank of Am erica fonnerly on deposit in accotmt number
898096330857 held in the nam e of Unified Relocation Solutions, LLC;
A11 funds held by Bank of Am erica formerly on deposit in account number
898099756470 held in the nam e of Prom aster M overs, lnc.;
Al1 funds held by Bank of Am erica formerly on deposit in account number
898105927423 held in the nam e of Unified Relocation Solutions LLC; and
A 2020 Lamborghini Huràcén with vin ZHW UF4ZF3LLA 13255.
d.
e.
Case 1:21-cr-20011-MGC   Document 29   Entered on FLSD Docket 01/08/2021   Page 4 of 8

A1l ptlrsuant to Title 1 8. United States Code. Section 982(a)(2)(A), and the procedures set
for'th at 'Fitle 2 1 - tlnited States Code, Sectitln 853 as incorporated by 'l'itle 1 8. t
.J nited States
Code. Section 982(b)( 1 ).
A IANA I' A 1)() (.)RSl IAN
F x
- ' l 1 A E I . N . B l.t' R f; i)l7- Ii
N1) 1(..,
ASSISTANT trN ITED STATES ATTORNEY
q E :
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DEPARTM ENT OF Jt-r S' I'IC E
Case 1:21-cr-20011-MGC   Document 29   Entered on FLSD Docket 01/08/2021   Page 5 of 8

UNITED STATES DISTRIG  COURT
SOUTHERN DISTRICT OF FLORIDA
UNITED STATES OF AM ERICA
VS.
DAVID TYLER HINES,
Defendant.
/
Court Division: (select one)
X 
Miami 
Key W est
FTL 
W PB 
FTP
y'
I do hereby certify that:
New Defendantts)
Number of New Defendants
Total number of counts
CASE NO.
CERTIFICATE OF TRIAL AU ORNEY*
Superseding Case Information:
Yes
No
I have carefully considered the allegations of the indictment, the number of defendants, the number of
probable witnesses and the Iegal complexities of the Indictment/lnformation attached hereto.
I am aware that the information 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.
Section 3161.
3. 
lnterpreter: 
(Yes or No) 
No
List Ianguage and/or dialect
This case will take 0 days for the parties to try.
5. 
Please check appropriate category and type of offense Iisted below:
(Check only one) 
(Check only one)
I 
0 to 5 days 
X 
Petty
11 
6 to 10 days 
Minor
11 
11 to 20 days 
Misdem.
IV 
21to 60 days 
Felony 
X
V: 
61 days and over
6. 
Has this case been previously filed in this District Court? (Yes or No) 
No
If yes:
Judge: 
Case No.
(Attach copy of dispositive order)
Has a complaint been filed in this matter? 
(Yes or No) 
Yes
If yes:
Magistrate Case No. 
20-MJ-3237-Becerra
Related Miscellaneous numbers:
Defendantls) in federal custody as of
Defendantts) in state custody as of
Rule 20 from the 
Dlstrlct o
Is this a potential death penalty case? (Yes or No) 
No
Does this case originate from a matter pending in the Northern Region of the U.S. Attorney's Office prior to
October 14, 2003? 
Yes 
X 
No
Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Office prior to
September 1, 2007? 
Yes 
X 
No
8.
*penalty Sheetls) attached
M ICHAEL N. BERGER
ASSISTANT UNITED STATES AITORNEY
Court ID No. 5501557
REV 4/8/08
Case 1:21-cr-20011-MGC   Document 29   Entered on FLSD Docket 01/08/2021   Page 6 of 8

iUNITED STATES DISTRICT COURT
SO UTH ERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Nam e: DAVID TYLER HINES
Case No:
Count #: 1
W ire Fraud
Title l 8. United States Code, Section 1343
* Max.penalty: Twenty (20) Years' lmprisonment
*Refers only to possible term  of incarceration, does not include possible fines, restitution,
special assessm ents, parole term s, or forfeitures that m ay be applicable.
Case 1:21-cr-20011-MGC   Document 29   Entered on FLSD Docket 01/08/2021   Page 7 of 8

AO 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.
DAVID TYLER HINES,
)
) 
Case No.
)
)
bepnilant 
)
W AIVER OF AN INDICTM ENT
l understand that l have been accused of one or more offenses punishable by imprisonm ent for m ore than one
year. I was advised in open coul't of my rights and the nature of the proposed charges against me.
After receiving this advice, l waive my right to prosecution by indictm ent and consent to prosecution by
information.
Date: 
01/04/2021
Case 1:21-cr-20011-MGC   Document 29   Entered on FLSD Docket 01/08/2021   Page 8 of 8

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