Information — United States v. Tyrone Brimage (District of Massachusetts)
Summary
An Information in United States of America versus Tyrone Brimage, Criminal No. 25-cr10020, in the United States District Court for the District of Massachusetts, dated January 16, 2025. Counts One and Two charge bank fraud under 18 U.S.C. § 1344, and Counts Three through Five charge wire fraud under 18 U.S.C. § 1343. The Information alleges that Brimage submitted fraudulent Pandemic Unemployment Assistance applications and received $21,279 and $21,879, and submitted a fraudulent PPP application with falsified statements about criminal history and received $20,832. It also alleges an Eastern Bank account opened to deposit a fraudulent check, and seeks forfeiture including $83,449 as a forfeiture money judgment. It is signed by Assistant United States Attorney Lucy Sun for United States Attorney Joshua S. Levy.
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“Information — United States v. Tyrone Brimage (District of Massachusetts).”
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Case 1:25-cr-10020-PBS Document 116 Filed 01/16/25 Page 1 of 17
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
) 25-cr10020
Criminal No.
UNITED STATES OF AMERICA )
) Violations:
v. )
) Counts One and Two: Bank Fraud
TYRONE BRIMAGE, ) (18 U.S.C. § 1344)
)
Defendant ) Counts Three through Five: Wire Fraud
) (18 U.S.C. § 1343)
)
) Forfeiture Allegation:
) (18 U.S.C. § 981(a)(1)(C) and
)
28 U.S.C. § 2461)
)
INFORMATION
The United States Attorney charges:
General Allegations
1. Defendant TYRONE BRIMAGE (“BRIMAGE”) is a resident of Massachusetts.
2. FAST Enterprises is a company that provided software and data hosting services
in Colorado and Virginia for the Massachusetts Department of Unemployment Assistance
(“DUA”) for administration of its Pandemic Unemployment Assistance (“PUA”) program.
3. Capital Plus Financial (“CPF”) is a financial institution based in Texas. It is an
approved lender of Paycheck Protection Program (“PPP”) loans.
4. The affected banks are financial institutions within the meaning of 18 U.S.C.
§ 20, including Eastern Bank and Citizens Bank, N.A.
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Pandemic Unemployment Assistance and Paycheck Protection Program Background
5. The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) was a
federal law enacted on March 29, 2020, designed to provide emergency financial assistance to
the millions of Americans who were suffering the economic effects caused by the COVID-19
pandemic. The CARES Act in part created a temporary federal unemployment insurance
program, PUA, which provided unemployment benefits for individuals who were not eligible for
other types of unemployment benefits, including those who were self-employed, independent
contractors, or gig economy workers.
6. The Massachusetts DUA administered and managed the PUA program in
Massachusetts.
7. Massachusetts residents applied to DUA for PUA benefits through an online
portal over which they submitted personally identifiable information (“PII”), including their first
and last name, Social Security number (“SSN”), date of birth, and residential and mailing
address. In addition, claimants selected a preferred payment method: direct deposit or payment
of their benefit onto a debit card. Claimants also provided a phone number and email address to
be used by DUA to provide updates, contact the claimant, and for authentication purposes.
Claimants had to certify that the information in the PUA application was accurate and that
answers to all questions were true and correct. PUA claims submitted to DUA online were
processed via servers located in Colorado.
8. The CARES Act also authorized forgivable loans to small businesses and non-
profits for job retention and certain other expenses through the PPP.
2
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9. To obtain a PPP loan, a qualifying business had to submit a PPP loan application
signed by an authorized representative of the business. The PPP loan application required the
business, through its authorized representative, to acknowledge the program rules and make
certain affirmative certifications. In the PPP loan application, the small business, through its
authorized representative, had to state, among other things, its number of employees and its
average monthly payroll expenses. These figures were used to calculate the amount of a PPP
loan that the business was eligible to receive; typically, a business was eligible to receive a loan
equal to two-and-a-half times its average monthly payroll expenses. In addition, businesses
applying for a PPP loan had to provide documentation of their payroll expenses.
10. A PPP loan application had to be processed by a lender authorized by the U.S.
Small Business Administration (“SBA”). If a PPP loan application was approved, the
participating lender funded the PPP loan using its own monies, which were 100 percent
guaranteed by the SBA. Data from the loan application was transmitted regularly by the lender
to the SBA in the course of processing the loan.
11. PPP loan proceeds had to be used by the recipient business on certain permissible
expenses, including payroll costs, interest on mortgages, rent, and utilities. The PPP allowed the
interest and principal on the PPP loan to be forgiven entirely if the business spent the loan
proceeds on these permissible expenses within a designated period and used a certain percentage
of the PPP loan proceeds on payroll expenses.
3
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Overview of the Multiple Schemes to Defraud
12. On or about July 23, 2020, BRIMAGE submitted a fraudulent PUA application
with falsified employment information, and from on or about August 6, 2020, to November 25,
2020, BRIMAGE received $21,279 in funds.
13. On or about October 21, 2020, BRIMAGE attempted to mobile deposit a
fraudulent City of Boston check for $16,427.23 into his Citizens Bank, N.A. account.
14. On or about November 16, 2020, BRIMAGE submitted a fraudulent PUA
application with a false social security number, and on or about November 18, 2020, BRIMAGE
received $21,879 in funds.
15. On or about May 13, 2021, BRIMAGE submitted a fraudulent PPP application
with falsified statements regarding his criminal history, and on or about June 8, 2021,
BRIMAGE received $20,832 in funds.
16. From on or about July 19, 2023, to July 25, 2023, BRIMAGE, and others known
and unknown to the United States Attorney, opened a bank account at Eastern Bank to deposit a
fraudulent check; BRIMAGE, and others known and unknown to the United States Attorney,
then withdrew the fraud proceeds from the account at a bank ATM.
Schemes to Defraud
First PUA Claim
17. Beginning on or about July 23, 2020, to November 16, 2020, BRIMAGE devised
and executed a scheme to defraud and to fraudulently obtain pandemic relief funds by submitting
false and fraudulent PUA applications to DUA for unemployment benefits.
4
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18. On or about July 23, 2020, BRIMAGE submitted a PUA claim through the DUA
portal with BRIMAGE’s name, date of birth, address, and other personal identifying information,
including his social security number.
19. BRIMAGE’s application falsely stated that BRIMAGE’s employment was first
impacted by COVID-19 pandemic on March 3, 2020, and certified that “a member of [his]
household has been diagnosed with COVID-19” and that he [‘didn’t’] have a recent history of
full-time work and [he] was scheduled to start a job with a new employer. [He] cannot start that
job, or the offer was withdrawn as a result of COVID-19.” BRIMAGE certified that his total
income in 2019 was $0.
20. At the time that BRIMAGE alleged that his employment was impacted by
COVID-19, BRIMAGE was incarcerated at the Norfolk County Jail in Massachusetts, from
February 25, 2020, to June 25, 2020.
21. BRIMAGE’s application further requested that the PUA benefits be deposited
into his Citizens Bank account ending in 3134. According to Citizens Bank, the account ending
in 3134 was in the name of “Tyrone Brimage,” with BRIMAGE’s SSN and address.
22. On or about the same day, July 23, 2020, DUA placed an Identity Verification
Issue on the claim. On or about July 27, 2020, BRIMAGE responded to the Issue and uploaded
additional identifying information: (1) a picture of the front and back of his social security card;
(2) a picture of the front and back of his Massachusetts Identification Card; and (3) a selfie
picture of BRIMAGE holding his Massachusetts Identification card.
23. Based on the information submitted to DUA, BRIMAGE’s claim was approved
on or about August 6, 2020.
5
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24. On or about October 27, 2020, the payment preference in BRIMAGE’s DUA
claim was updated to request that benefits be deposited into a Stride Bank account ending in
8654. According to Stride Bank, the account ending in 8654 was in BRIMAGE’s name, SSN,
and address.
25. In total, from on or about August 6, 2020, to November 25, 2020, DUA paid
BRIMAGE $21,279.
26. On or about December 2, 2020, DUA denied the claim, noting, “Claimant has
multiple fraudulent claims with different SSNs.” On or about December 3, 2020, DUA issued a
Notice of Non-Monetary Issue Redetermination—Identity Verification, informing BRIMAGE
that he did not meet the eligibility requirements for PUA.
27. Based on this determination, DUA stopped all payments on BRIMAGE’s claim.
28. On or about April 15, 2021, DUA placed an incarceration issue on the claim
identifying that BRIMAGE was incarcerated as of March 3, 2020.
City of Boston Check
29. On or about August 8, 2020, BRIMAGE opened a Citizens Bank account ending
in 5429. According to Citizens Bank, the account ending in 5429 was in the name “Tyrone
Brimage,” with BRIMAGE’s SSN and address.
30. On or about October 21, 2020, BRIMAGE attempted to mobile deposit a check
from the City of Boston for $16,427.23 into his Citizens Bank account ending in 5429.
31. On or about October 22, 2020, Citizens Bank confirmed the check to be
fraudulent.
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32. According to the City of Boston, the sequence on the check is not a valid City of
Boston sequence number. Moreover, the account number on the check is from the City’s payroll
account, and BRIMAGE has never been an employee of the City of Boston.
Second PUA Claim
33. On or about November 16, 2020, BRIMAGE submitted a second PUA claim
through the DUA portal with his name, date of birth, address, and other PII, including a falsified
SSN with altered second and third digits.
34. In this application, BRIMAGE claimed that on March 2, 2020, he “was diagnosed
with Coronavirus Disease 2019 (COVID-19) or was experiencing symptoms of COVID-19.” In
contrast to his first application, BRIMAGE certified that his income in 2019 was $10,000.
35. BRIMAGE requested his PUA benefits be deposited into an Eastern Bank
account ending in 6399. According to Eastern Bank, the account ending in 6399 is in
BRIMAGE’s name, real SSN, and address.
36. On or about the same day, November 16, 2020, DUA placed an Identity
Verification Issue on the claim. In response to the Issue, BRIMAGE uploaded additional
identifying information: (1) a picture of the front and back of an altered social security card; (2) a
picture of the front and back of his Massachusetts Identification Card; and (3) a selfie picture of
BRIMAGE holding his Massachusetts Identification card, different than the selfie in Paragraph
22.
37. On or about November 17, 2020, DUA approved BRIMAGE’s claim. On or about
November 18, 2020, DUA paid BRIMAGE $21,879.
7
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38. On or about December 2, 2020, DUA stopped the claim and noted, “Claimant has
multiple fraudulent claims with different SSNs.” On or about December 3, 2020, DUA Issued a
Monetary Issue Redetermination—Identity Verification informing BRIMAGE that he does not
meet the eligibility requirements for PUA. Based on this determination, MA DUA stopped all
payments on this claim.
PPP Claim
39. On or about May 13, 2021, BRIMAGE submitted a PPP loan to CPF for “payroll
costs, rent/mortgage interest, utilities” for what he claimed was his barber shop. BRIMAGE
further provided his business’ total gross income in 2019 was $101,063.
40. CPF approved the loan, and on or about June 8, 2021, $20,832 was deposited into
BRIMAGE’s Eastern Bank account ending in 6399, which is the same account BRIMAGE used
to receive his funds from his second PUA claim.
41. Question six (6) of the application read, “Within the last 5 years, for any felony
involving fraud, bribery, embezzlement, or a false statement in a loan application or an
application for federal financial assistance, has the Applicant (if any individual) or any owner of
the Applicant 1) been convicted; 2) pleaded guilty; 3) pleaded nolo contendere; or 4) commenced
any form of parole or probation (including probation before judgement)? Initial here to confirm
your response to question 6.”
42. BRIMAGE digitally selected “NO” to answer question six (6) and digitally
initialed “tb.” BRIMAGE also signed the application in the “Signature of Authorized
Representative of Applicant” section “tyrone brimage.”
8
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43. According to BRIMAGE’s Board of Probation record, BRIMAGE has been
previously convicted of the following felonies:
a. Credit card fraud over $1,200 in the Central Division of the Boston
Municipal Court on February 28, 2020 (Dkt 1901CR002708A); and
b. 4 counts of forgery of a promissory note in the Roxbury Division of the
Boston Municipal Court on February 13, 2020 (Dkt 1902CR001182C-F).
44. Moreover, prior to the PPP funding, the majority of debits in his Eastern Bank
account ending in 6399 do not appear business related. From November 2020 to June 2021, the
debits include numerous CashApp transfers, purchases at Target and Saks, cash withdrawals,
food purchases, and rideshare fares. The credits include PUA funds.
45. After receiving the $20,832 on or about June 8, 2021, BRIMAGE used the money
for CashApp transfers, food purchases, purchases at GameStop, Sneaker Junkies, hotel rooms,
and jewelry. By June 30, 2021, BRIMAGE’s account balance was -$7.97. These charges are
not consistent with expenses for “payroll costs, rent/mortgage interest, utilities.”
Fraudulent Check
46. On or about July 19, 2023, A.C. opened an Eastern Bank account and provided a
phone number ending in 6850 and an address in Boston as the home address.
47. At that time, BRIMAGE lived at that Boston address.
48. On various occasions from on or about July 22, 2023, to July 25, 2023, A.C.’s
Eastern Bank account was accessed by BRIMAGE’s IP address, 73.218.226.108, which was
leased to BRIMAGE’s Boston address.
9
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49. On or about July 24, 2023, at approximately 1:32 p.m., a co-conspirator messaged
BRIMAGE on Instagram, “Let’s do that eastern.”
50. On or about that same day, at approximately 7:25 p.m., a fraudulent check
belonging to Victim 1 was deposited into A.C.’s Eastern Bank account. The check was made
payable to A.C. for $3,032.50.
51. According to Victim 1, Victim 1 mailed the check in a USPS collection box
outside the Grove Street Post Office in Wellesley on or about June 19, 2023. Victim 1
confirmed that Victim 1 did not write the check to A.C.
52. On or about July 25, 2023, at approximately 4:15 a.m., BRIMAGE and a co-
conspirator entered the Eastern Bank at 1413 Tremont Street in Boston and withdrew $200 from
A.C.’s account at the ATM. According to Eastern Bank, limited funds were available for
immediate withdrawal because Victim 1’s check had a non-local routing number.
10
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COUNT ONE
Bank Fraud
(18 U.S.C. § 1344)
The United States Attorney charges:
53. The United States Attorney re-alleges and incorporates by reference paragraphs 1-
16 and 46-52 of this Information.
54. From on or about July 19, 2023, to July 25, 2023, in the District of
Massachusetts, the defendant,
TYRONE BRIMAGE,
did knowingly execute, and attempt to execute, a scheme and artifice to defraud a financial
institution, that is, Eastern Bank, and to obtain moneys, funds, credits, assets, securities and other
property owned by and under the custody and control of Eastern Bank, by means of materially
false and fraudulent pretenses, representations, and promises.
All in violation of Title 18, United States Code, Sections 1344.
11
Case 1:25-cr-10020-PBS Document 116 Filed 01/16/25 Page 12 of 17
COUNT TWO
Bank Fraud
(18 U.S.C. § 1344)
The United States Attorney further charges:
55. The United States Attorney re-alleges and incorporates by reference paragraphs 1-
16, and 29-32 of this Information.
56. On or about August 8, 2020, in the District of Massachusetts, the defendant,
TYRONE BRIMAGE,
did knowingly execute, and attempt to execute, a scheme and artifice to defraud a financial
institution, that is, Citizens Bank, and to obtain moneys, funds, credits, assets, securities and
other property owned by and under the custody and control of Citizens Bank, N.A., by means of
materially false and fraudulent pretenses, representations, and promises.
All in violation of Title 18, United States Code, Sections 1344.
12
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COUNT THREE
Wire Fraud
(18 U.S.C. § 1343)
The United States Attorney further charges:
57. The United States Attorney re-alleges and incorporates by reference paragraphs 1-
16 and 39-45 of this Information.
58. On or about May 13, 2021, in the District of Massachusetts, and elsewhere, the
defendant,
TYRONE BRIMAGE,
having devised and intending 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, did transmit and cause to be transmitted by means of wire communications in
interstate and foreign commerce, writings, signs, signals, pictures, and sounds for the purpose of
executing the scheme to defraud, to wit, a fraudulent Paycheck Protection Program loan
application that contained materially false information for the purpose of executing the scheme
to defraud.
All in violation of Title 18, United State Code, Section 1343.
Case 1:25-cr-10020-PBS Document 116 Filed 01/16/25 Page 14 of 17
COUNT FOUR
Wire Fraud
(18 U.S.C. § 1343)
The United States Attorney further charges:
59. The United States Attorney re-alleges and incorporates by reference paragraphs 1-
28 of this Information.
60. On or about July 23, 2020, in the District of Massachusetts, and elsewhere, the
defendant,
TYRONE BRIMAGE,
having devised and intending 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, did transmit and cause to be transmitted by means of wire communications in
interstate and foreign commerce, writings, signs, signals, pictures, and sounds for the purpose of
executing the scheme to defraud, to wit, a fraudulent Pandemic Unemployment Assistance loan
application that contained materially false information for the purpose of executing the scheme
to defraud.
All in violation of Title 18, United State Code, Section 1343.
Case 1:25-cr-10020-PBS Document 116 Filed 01/16/25 Page 15 of 17
COUNT FIVE
Wire Fraud
(18 U.S.C. § 1343)
61. The United States Attorney re-alleges and incorporates by reference paragraphs 1-
16, 33-38 of this Information.
62. On or about November 16, 2020, in the District of Massachusetts, and elsewhere,
the defendant,
TYRONE BRIMAGE,
having devised and intending 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, did transmit and cause to be transmitted by means of wire communications in
interstate and foreign commerce, writings, signs, signals, pictures, and sounds for the purpose of
executing the scheme to defraud, to wit, a fraudulent Pandemic Unemployment Assistance loan
application that contained materially false information for the purpose of executing the scheme
to defraud.
All in violation of Title 18, United State Code, Section 1343.
Case 1:25-cr-10020-PBS Document 116 Filed 01/16/25 Page 16 of 17
FORFEITURE ALLEGATION
(18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c))
The United States Attorney further alleges:
63. Upon conviction one or more of the offenses in violation of Title 18, United
States Code, Section 1344, set forth in Counts One and Two, and Title 18, United States Code,
Section 1343, set forth in Counts Three through Five, the defendant,
TYRONE BRIMAGE,
shall forfeit to the United States, pursuant to Title 18, United States Code, Section 981(a)(1)(C),
and Title 28, United States Code, Section 2461(c), any property, real or personal, which
constitutes or is derived from proceeds traceable to the offenses. The property to be forfeited
includes, but is not limited to, the following assets:
a. $83,449, to be entered in the form of a forfeiture money judgment;
64. If any of the property described in Paragraph 65, above, as being forfeitable
pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United States Code,
Section 2461(c), 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;
c. has been placed beyond the jurisdiction of the Court;
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be divided without
difficulty;
Case 1:25-cr-10020-PBS Document 116 Filed 01/16/25 Page 17 of 17
it is the intention of the United States, pursuant to Title 28, United States Code, Section 2461(c),
incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any other
property of the defendant up to the value of the property described in Paragraph 65 above.
All pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United
States Code, Section 2461(c).
Respectfully Submitted,
JOSHUA S. LEVY
United States Attorney
By: /s/ Lucy Sun
Lucy Sun
Philip C. Cheng
Assistant United States Attorneys
Date: January 16, 2025
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