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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 24-CR-20382-DPG
UNITED STATES OF AMERICA
v.
ZACHARY KAMERON RAMYARD,
Defendant.
I
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FACTUAL PROFFER
The United States of America and the defendant, Zachary Kameron Ramyard, agree that
had this case proceeded to trial, the United States would have proven, beyond a reasonable doubt,
the following facts, among others, pe1iaining to a violation of 18 U.S.C. § 1349 that occurred in the
Southern District of Florida and elsewhere.
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 (PUA), Federal Pandemic Unemployment Compensation Program (FPUC), and
the Lost Wages Assistance Program (L WAP).
In the State of California, the Employment
Development Depaiiment (EDD), based in Sacramento, California, administered the UI program.
Those seeking UI benefits submitted online applications.
In order to successfully file an
unemployment claim with EDD, the applicant had to pass an identity verification process with
"ID.me" (www.id.me) by submitting the applicant's personal information, a copy of the applicant's
driver's license, and a selfie photograph to ID.me for identity verification. Applicants also had to
Case 1:24-cr-20382-DPG Document 15 Entered on FLSD Docket 11/01/2024 Page 1 of 3
provide their name, Social Security Number (SSN), and mailing address, among other things, and
to self-ce1iify that they met a COVID-19-related reason for being unemployed, partially employed,
or unable to work. The EDD relied upon the information in the application to determine UI benefits
eligibility. Once an application was approved, the 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 Bank of America, were sent via the U.S. Postal
Service to the address the claimant provided. Claimants could activate their debit card via telephone
or online.
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From in or around August 2020 through in or around .laHumy, 2022, the defendant agreed
with co-conspirators to submit fraudulent UI claims to the EDD on behalf of dozens of individuals
without their authorization.
To do so, the defendant purchased their personal identifiable
information ("PII") online and used burner phones to disguise his identity when communicating
with co-conspirators and submitting the electronic applications. The defendant created new contact
email addresses to submit and track fraudulent applications, including drjohn3900@yahoo.com. In
order to verify the fraudulent applications with ID.me, the defendant and co-conspirators created
counterfeit driver's licenses with victims' PII and the faces of Co-Conspirator 1 and other co-
conspirators. In turn, the defendant instructed Co-Conspirator 1, a Miami-Dade County resident, to
take selfie photographs of himself to match the counterfeit driver's licenses. The fraudulent UI
claims triggered interstate wires to EDD and caused Bank of America to mail debit cards to Florida
and California addresses controlled by the defendant and co-conspirators.
As a result of 68 of the defendant's fraudulent applications in different victims' names, the
California EDD deposited $1,288,500 in UI claims onto fraudulent debit cards controlled by the
defendant and co-conspirators. The defendant used rental cars to travel throughout Florida to
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Case 1:24-cr-20382-DPG Document 15 Entered on FLSD Docket 11/01/2024 Page 2 of 3
different ATMs to withdraw hundreds of thousands of dollars in UI funds from various debit cards.
Fdrexa1nple, on November 4, 2020, ATM surveillance shows the defendant withdrawing $980from
a debit card ending 'in 0371, issued to "M.O.M.," at a Bank of America ATM in Osceola County,
F)qrida. M.O.M. confirmed that he never filed for unemployment benefits or authorized anyone to
dq so on his behalf. The defendant ·used the fraudulent UI proceed_s to make 1-uxury purchases in
Miami, .Florida, and elsewhere.
The above~detailed facts are corroborated by, among other things, witness interviews,
.banking records, A TM photographs, business records, and other evidence.
The information
contained in this proffer is not a complete recitation of the facts and circumstances of this case, but
the parties agree it is sufficient to prove beyond a reasonable doubt a violation of I 8 U.S.C. § 1349
(conspfracy to commit wire fraud), as charged in the Information.
Date:
M.ARKENZY LAPOINTE
UNITED STA TES ATTORNEY
By: - JO-~_..h
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STATES ATTORNEY
By:-----~~---------
ANAM. DAViD'.E
ATTORN'EYFOR DEFENDANT
By:
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ZAC,:::HARY KAMERON -RAMY ARD
DEFENDANT
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