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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. ----------
18 u.s.c. § 1349
18 U.S.C. § 981(a)(l)(C)
UNITED STATES OF AMERICA
v.
ZACHARY KAMERON RAMY ARD,
Defendant.
-----------------
INFORMATION
The United States Attorney charges that:
GENERAL ALLEGATIONS
At all times relevant to this Information:
California Unemployment Insurance During the COVID-19 Pandemic
1.
Unemployment Insurance ("UI") was a joint state and federal program that
provided monetary benefits to eligible beneficiaries. UI payments were intended to provide
temporary financial assistance to lawful workers who were unemployed through no fault of their
own. Beginning in or around March 2020, in response to the COVID-19 pandemic, several federal
programs expanded UI eligibility and increased UI benefits, including the Pandemic
Unemployment Assistance Program, Federal Pandemic Unemployment Compensation Program,
and the Lost Wages Assistance Program.
2.
In the State of California, the Employment Development Department ("CA-EDD"),
based in Sacramento, California, administered the UI program. Those seeking UI benefits
submitted online applications. In order to receive benefits, applicants were required to provide
their personally identifying information ("PU"), such as their name, social security number, and
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Case 1:24-cr-20382-DPG Document 4 Entered on FLSD Docket 08/30/2024 Page 1 of 9
MP
Aug 29, 2024
Miami
mailing address, among other things. Applicants also had to self-certify that they met a COVID-
19-related reason for being unemployed, partially employed, or unable to work. The CA-EDD
relied upon the information in the application to determine UI benefits eligibility.
3.
In order to successfully file an unemployment claim with CA-EDD, the applicant
had to pass an identity verification process with the online service provider "ID.me" (www.id.me)
by submitting the applicant's PII, a copy of the applicant's driver's license, and a real-time
photograph ofthemselfto ID.me for identity verification.
4.
Once an application was approved, the CA-EDD typically distributed state and
federal UI benefits electronically to a debit card, which claimants could use to withdraw funds
and/or make purchases. These debit cards, which were issued by a bank headquartered in North
Carolina, with locations in the Southern District of Florida (hereinafter, "Bank 1"), were sent via
the U.S. Postal Service to the address the claimant provided. Claimants could activate their debit
card via telephone or online.
The Defendant and Co-Conspirator 1
5.
ZACHARY KAMER ON RAMY ARD was a resident of Orange County, Florida.
6.
Co-Conspirator 1 was a resident of Miami-Dade County, Florida.
Conspiracy to Commit Wire Fraud
(18 u.s.c. § 1349)
7.
From at least as early as in or around August 2020 and continuing through in or
around August 2022, in Miami-Dade County, in the Southern District of Florida, and elsewhere,
the defendant,
ZACHARY KAMERON RAMY ARD,
did willfully, that is, with the intent to further the object of the conspiracy, and knowingly combine,
conspire, confederate, and agree with Co-Conspirator 1 and others known and unknown to the
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United States Attorney to commit wire fraud, that is, to knowingly, and with the intent to defraud,
devise and intend 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, 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
transmitted, by means of wire communication in interstate and foreign commerce, certain writings,
signs, signals, pictures and sounds, in violation of Title 18, United States Code, Section 1343.
PURPOSE OF THE CONSPIRACY
8.
It was a purpose of the conspiracy for the defendant and his co-conspirators to
unlawfully enrich themselves by, among other things: (a) submitting false and :fraudulent
applications to the CA-EDD for UI benefits and payments in the form of prepaid debit cards mailed
to residences in the Southern District of Florida and elsewhere; (b) diverting the CA-EDD debit
cards and fraud proceeds for the defendant's and co-conspirators' personal use, the use and benefit
of others, and to further the fraud; and ( c) concealing the commission of the offense and the use of
the fraud proceeds.
MANNER AND MEANS OF THE CONSPIRACY
The manner and means by which the defendant and his co-conspirators sought to
accomplish the object and purpose of the conspiracy included, among others, the following:
9.
ZACHARY KAMERON RAMYARD and co-conspirators purchased the PII of
victims without lawful authority and created counterfeit driver's licenses that listed the victims'
PII alongside the photographs of co-conspirators.
10.
ZACHARY KAMERON RAMY ARD and co-conspirators, usmg electronic
devices connected to the Internet, submitted false and fraudulent applications for UI benefits to the
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CA-EDD under the corresponding victims' identities without their authorization. The UI benefit
applications contained false and fraudulent representations, including: the claimants' contact
information; that the claimants lived in a particular state; that the claimants were available to work
during the prescribed periods; and that the claimants were newly unemployed due to a disaster,
including the COVID-19 pandemic, among other misrepresentations.
11.
Co-Conspirator 1 conducted identity verification on ID.me for fraudulent UI
benefit applications in victims' names by taking live photographs of himself that matched
counterfeit driver's licenses that contained his face along with PU belonging to victims.
12.
Over the course of the conspiracy, the CA-EDD approved at least 68 fraudulent UI
benefit applications submitted by ZACHARY KAMERON RAMYARD, resulting in the
disbursement of approximately $1,288,500 in the form of prepaid debit cards issued by Bank 1.
13.
ZACHARY KAMERON RAMYARD used the fraudulent UI debit cards to
withdraw money at ATMs in Florida, Maryland, and California.
14.
ZACHARY KAMERON RAMYARD used the fraudulent UI proceeds to make
luxury purchases in Miami, Florida, and elsewhere, including the purchase of diamond-studded
teethjewelry, colloquially referred to as "grills."
All in violation of Title 18, United States Code, Section 1349.
FORFEITURE ALLEGATIONS
1.
The allegations of this Information are hereby re-alleged and by this reference fully
incorporated herein for the purposes of alleging forfeiture to the United States of America of
certain property in which the defendant, ZACHARY KAMERON RAMY ARD, has an interest.
2.
Upon conviction of a violation of Title 18, United States Code, Section 1349, as
alleged in this Information, the Defendant, ZACHARY KAMERON RAMY ARD, shall forfeit
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to the United States any property, real or personal, which constitutes or is derived from proceeds
traceable to such offense, pursuant to Title 18, United States Code, Section 981(a)(l)(C).
3.
If any property subject to forfeiture 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;
the United States shall be entitled to the forfeiture of substitute property under the provisions of
Title 21, United States Code, Section 853(p).
All pursuant to Title 18, United States Code, Section 981(a)(l)(C) and the procedures set
forth in Title 21, United States Code, Section 853, as incorporated by Title 28, United States Code,
Section 2461(c).
MARKENZY LAPOINTE
UNITED STATES ATTORNEY
91[lc
·
JOSEPH EGOZIc
ASSISTANT UNITED STATES ATTORNEY
5
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
UNITED STATES OF AMERICA
CASE NO.: ____________ _
v.
CERTIFICATE OF TRIAL ATTORNEY
ZACHARY KAMERON RAMY ARD,
I
----------------
Defendant.
Court Division (select one)
IE! Miami
□ Key West
□FTL
□WPB
I do hereby certify that:
□FTP
Superseding Case Information:
New Defendant(s) (Yes or No) __
Number of New Defendants
Total number of new counts
l.
I have carefully considered the allegations of the indictment, the number of defendants, the number of probable
witnesses and the legal complexities of the Indictment/Information attached hereto.
2.
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. §3161.
3.
Interpreter: (Yes or No) No
List language and/or dialect: -------
4.
This case will take _0_ days for the parties to try.
5.
Please check appropriate category and type of offense listed below:
(Check only one)
I
ml O to 5 days
II □ 6 to 10 days
III □ 11 to 20 days
IV □ 21 to 60 days
V □ 61 days and over
(Check only one)
□ Petty
Cl Minor
IC! Misdemeanor
IE!Felony
6.
Has this case been previously filed in this District Court? (Yes or No) No
If yes, Judge ___________ Case No. ______________ _
7.
Has a complaint been filed in this matter? (Yes or No) No
If yes, Magistrate Case No. __________ _
8.
Does this case relate to a previously filed matter in this District Court? (Yes or No) Yes
If yes, Judge__________ Case No. 23-mj-3910-Otazo-Reyes
9.
Defendant(s) in federal custody as of 1/25/2024
---------------------
10.
Defendant(s) in state custody as of
11.
Rule 20 from the ____ District of _________ _
12.
Is this a potential death penalty case? (Yes or No) No
13.
Does this case originate from a matter pending in the Northern Region of the U.S. Attorney's Office
prior to August 8, 2014 (Mag. Judge Shaniek Maynard? (Yes or No) No
14.
Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Office prior
to October 3, 2019 (Mag. Judge Jared Strauss? (Yes or No) No
15.
Did this matter involve the participation of or consultation with Magistrate Judge Eduardo I. Sanchez
during his tenure at the U.S. Attorney's Office, which concluded on January 22, 2023? No
16.
Did this matter involve the participation of or consultation with now Magistrate Judge Marta Fulgueira
Elfenbein during her tenure at the U.S. Attorney's Office, which concluded on March 5, 2024? No
a ..
By:
--L-=llJ
Joseph Egozi
Assistant United States Attorney
Court ID No.
A5502707
24-20382-CR-GAYLES/GOODMAN
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Name:
ZACHARY KAMERON RAMY ARD
Case No: -------------------------------
Count #1:
Conspiracy to Commit Wire Fraud
Title 18, United States Code, Section 1349
*Max.Term of Imprisonment: Twenty (20) Years
* Mandatory Min. Term of Imprisonment (if applicable): NIA
* Max. Supervised Release: Three (3) Years
* Max. Fine: $250,000 or Twice the Gross Gain or Loss Resulting from the Offense
*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 1:24-cr-20382-DPG Document 4 Entered on FLSD Docket 08/30/2024 Page 7 of 9
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NUMBER: ----------
BOND RECOMMENDATION
DEFENDANT: Zachary Kameron Ramyard
Pre-Trial Detention
(Personal Surety) (Corporate Surety) (Cash) (Pre-Trial Detention)
By:
L
Kn
Addr
ast
own
ess:
What Facility:
FCI Miami, 15801 S.W. 137th
Ave. Miami, FL 33177
Agent(s):
SIA Joseph Hernandez, HSI
(FBI) (SECRET SERVICE) (DEA) (IRS) (ICE) (OTHER)
1226 NW 20th St., Miami, FL 33172
24-20382-CR-GAYLES/GOODMAN
Case 1:24-cr-20382-DPG Document 4 Entered on FLSD Docket 08/30/2024 Page 8 of 9
AO 455 (Rev. 01/09) Waiver of an Indictment
UNITED STATES DISTRICT COURT
United States of America
v.
Zachary Kameron Ramard,
Defendant
for the
Southern District of Florida
)
)
)
)
)
Case No.
WAIVER OF AN INDICTMENT
I understand that I have been accused of one or more offenses punishable by imprisonment for more than one
year. I was advised in open court ofmy rights and the nature of the proposed charges against me.
After receiving this advice, I waive my right to prosecution by indictment and consent to prosecution by
information.
Date: --------
Defendant's signature
Signature of defendant's attorney
Printed name of defendant's attorney
Judge 's signature
Judge's printed name and title
24-20382-CR-GAYLES/GOODMAN
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