At various times relevant to this Indictment
- Date
- 2025-02-19
Summary
Criminal information entered February 19, 2025 as Document 1 in United States v. McNeil McKoy Wilson and Tatiana Nicole Lopez, Case No. 0:25-cr-60036-WPD, U.S. District Court for the Southern District of Florida. The United States Attorney charges the two defendants with conspiracy to commit wire fraud under 18 U.S.C. § 371, alleging a scheme to obtain California unemployment insurance benefits using stolen identities and forged driver licenses verified through ID.me. It alleges that the CA-EDD approved at least 57 fraudulent claims paid on Bank of America prepaid debit cards, and lists four ATM withdrawals of $1,000 as overt acts. It seeks forfeiture under 18 U.S.C. § 982(a)(2)(B). The filing also contains a certificate of trial attorney, penalty sheets listing a maximum term of 5 years, and blank waivers of indictment for both defendants.
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Case 0:25-cr-60036-WPD Document 1 Entered on FLSD Docket 02/19/2025 Page 1 of 12
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
25-CR-60036-DIMITROULEAS/HUNT
CASE NO. - - - - - - - - - - -
18 u.s.c. § 371
18 U.S.C. § 982(a)(2)
UNITED STATES OF AMERICA
vs.
BM
MCNEIL MCKOY WILSON and
TATIANA NICOLE LOPEZ, Feb 19, 2025
Defendants.
---------------I MIAMI
INFORMATION
The United States Attorney charges that:
GENERAL ALLEGATIONS
At various times relevant to this Indictment:
Unemployment Insurance
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, 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. Applicants had to answer specific questions to establish eligibility
Case 0:25-cr-60036-WPD Document 1 Entered on FLSD Docket 02/19/2025 Page 2 of 12
to receive UI benefits, including their name, Social Security Number ("SSN"), and 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. In order to successfully file
a UI claim with the CA-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 license, and a selfie photograph to ID.me. In order to submit a selfie photograph,
a text message was sent to the claimant's cellular telephone containing a link that allowed the
claimant to upload the photograph to ID.me. Facial recognition software was then used to compare
the selfie photograph with the photograph on the applicant's driver license. Once an application
was approved, the CA-EDD typically distributed state and federal UI benefits electronically to a
debit card administered by Bank of America, N.A. ("Bank of America"), which claimants could
use to withdraw funds and/or make purchases. These debit cards were sent via the United States
Postal Service to the address the claimant provided. Claimants could activate their debit card via
telephone or online.
3. Visa Debt Processing Solutions ("Visa DPS") was a vendor contracted by Bank of
America to process all transactions on UI prepaid debit cards, including those issued by the CA-
EDD. Visa DPS had two platform processor data centers that housed all of the UI prepaid card
data for Bank of America. Those data centers were located in Ashburn, Virginia and Highlands
Ranch, Colorado. Any transaction made on a Bank of America UI prepaid debit card, including
loading of funds, point of sale transactions, and Automated Teller Machine ("ATM") withdrawals,
passed through one of those two data processor centers.
2
Case 0:25-cr-60036-WPD Document 1 Entered on FLSD Docket 02/19/2025 Page 3 of 12
The Defendants
4. Defendant MCNEIL MCKOY WILSON was a resident of Broward County,
Florida.
5. Defendant TATIANA NICOLE LOPEZ was a resident of Broward County,
Florida.
Relevant Financial Institution
6. Bank of America was a financial institution with offices located throughout the
United States, including in the State of Florida, whose accounts were insured by the Federal
Deposit Insurance Corporation ("FDIC").
CONSPIRACY TO COMMIT WIRE FRAUD
(18 u.s.c. § 371)
From in or around January 202 1, through in or around August 2021 , in Broward and
Miami-Dade Counties, in the Southern District of Florida, and elsewhere, the defendants,
MCNEIL MCKOY WILSON and
TATIANA NICOLE LOPEZ,
did knowingly and willfully combine, conspire, confederate, and agree with each other and with
others known and unknown to the United States Attorney to commit an offense against the United
States, that is, to knowingly, and with 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 they were false and fraudulent when made,
and, for the purpose of executing the scheme and artifice, transmitting and causing to be
transmitted in interstate and foreign commerce, by means of wire communication, certain writings,
signs, signals, pictures and sounds, in violation of Title 18, United States Code, Section 1343 .
3
Case 0:25-cr-60036-WPD Document 1 Entered on FLSD Docket 02/19/2025 Page 4 of 12
PURPOSE OF THE CONSPIRACY
7. It was a purpose of the conspiracy for the defendants and their co-conspirators to
unlawfully enrich themselves by submitting false and fraudulent applications to the CA-EDD for
UI benefits and payments and causing the CA-EDD to issue UI benefits and payments in the form
of prepaid debit cards mailed to residences in the Southern District of Florida and elsewhere.
MANNER AND MEANS OF CONSPIRACY
The manner and means by which the defendants and their co-conspirators sought to
accomplish the object and purpose of the conspiracy included, among others, the following:
8. One or more members of the conspiracy obtained the personally identifiable
information ("PII") of victims without lawful authority. Such PII included, without limitation,
names, dates of birth, and SSNs.
9. One or more members of the conspiracy used the PII to submit fraudulent UI claims
to the CA-EDD under the corresponding persons' identities without their authorization using an
electronic device that could access the Internet.
10. One or more members of the conspiracy also used the PII to create forged driver
licenses with the victims' names and a photograph of MCNEIL MCKOY WILSON, copies of
which were used to create accounts on ID.me. WILSON then submitted selfie photographs of
himself to ID.me in order to fraudulently verify the identities on the forged driver licenses.
11. The UI benefit applications contained false and fraudulent representations,
including, without limitation: 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. In
reliance on these false and fraudulent representations, the CA-EDD approved the fraudulent claims
submitted by one or more members of the conspiracy.
4
Case 0:25-cr-60036-WPD Document 1 Entered on FLSD Docket 02/19/2025 Page 5 of 12
12. Having approved the fraudulent UI claims, the CA-EDD deposited funds into debt
card accounts administered by Bank of America, which involved the use of interstate wires. Bank
of America then mailed the debit cards via the United States Postal Service to residential addresses
in the Southern District of Florida, and elsewhere, that had been provided by one or more members
of the conspiracy.
13. MCNEIL MCKOY WILSON and TATIANA NICOLE LOPEZ obtained
possession of some of the fraudulently obtained debit cards received by members of the conspiracy
and others and used them to make cash withdrawals at ATMs in the Southern District of Florida
and used the money for their own benefit and for the benefit of others who were also not entitled
to the money.
14. Over the course of the conspiracy, the CA-EDD approved at least 57 fraudulent UI
claims submitted by one or more members of the conspiracy resulting in the disbursement of
approximately $463 ,436 in the form of prepaid debit cards issued by Bank of America.
OVERT ACTS
In furtherance of the conspiracy and to achieve the purpose and object thereof, at least one
of the conspirators committed and caused to be committed in the Southern District of Florida and
elsewhere, at least one of the following acts, among others:
15. On or about April 5, 2021 , TATIANA ICOLE LOPEZ withdrew $1,000 from
an ATM in the Southern District of Florida using a fraudulently obtained Bank of America debit
card ending in 4915.
16. On or about April 13, 2021, MCNEIL MCKOY WILSON withdrew $1 ,000 from
an ATM in the Southern District of Florida using a fraudulently obtained Bank of America debit
card ending in 6276.
5
Case 0:25-cr-60036-WPD Document 1 Entered on FLSD Docket 02/19/2025 Page 6 of 12
17. On or about October 19, 2021, TATIANA NICOLE LOPEZ withdrew $1 ,000
from an ATM in the Southern District of Florida using a fraudulently obtained Bank of America
debit card ending in 8654.
18. On or about October 29, 2021, MCNEIL MCKOY WILSON withdrew $1,000
from an ATM in the Southern District of Florida using a fraudulently obtained Bank of America
debit card ending in 7429.
All in violation of Title 18, United States Code, Section 371.
FORFEITURE
(18 U.S.C. § 982(a)(2))
1. The allegations of this Information are re-alleged and by this reference fully
incorporated herein for the purpose of alleging forfeiture to the United States of certain property
in which one or more of the defendants, MCNEIL MCKOY WILSON and TATIANA NICOLE
LOPEZ, have an interest.
2. Upon conviction of a conspiracy to violate Title 18, United States Code, Section
1343, as alleged in this Information, the defendant so convicted shall forfeit to the United States
of America any property constituting, or derived from, proceeds obtained directly or indirectly, as
the result of such violation, pursuant to Title 18, United States Code, Section 982(a)(2)(B).
6
Case 0:25-cr-60036-WPD Document 1 Entered on FLSD Docket 02/19/2025 Page 7 of 12
All pursuant to Title 18, United States Code, Section 982(a)(2)(B), and the procedures set
forth at Title 21 , United States Code, Section 853 , made applicable by Title 18, United States Code,
Section 982(b ).
UNITED STATES ATTORNEY
c ~· SEAN PAUL CRONIN ~
ASSISTANT UNITED STATES ATTORNEY
7
Case 0:25-cr-60036-WPD Document 1 Entered on FLSD Docket 02/19/2025 Page 8 of 12
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
UNITED STATES OF AMERICA 25-CR-60036-DIMITROULEAS/HUNT
CASE NO.: _ _ _ __ __ _ _ _ _ _ __
v.
CERTIFICATE OF TRIAL ATTORNEY
MCNEIL MCKOY WILSON, et al.,
- - - - - - - - - - - - - - - -I Superseding Case Information:
New Defendant(s) (Yes or No) _ _
Court Division (select one) Number of New Defendants
□ Miami □Key West □ FTP Total number of new counts
□ FTL □ WPB
I do hereby certify that:
1. 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, 28 U.S.C. §316 1.
3. Interpreter: (Yes or No) l::::!2._
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 li sted below:
(Check only one) (Check only one)
I El 0 to 5 days □ Petty
II D 6 to 10 days □ Minor
Ill D 11 to 20 days D Misdemeanor
IV □ 21 to 60 days (;31 Felony
V D 61 days and over
6. Has this case been previously filed in thi s District Court? (Yes orNo)l::::!2._
If yes, Judge _ _ _ _ _ _ _ _ _ _ _ Case o.
7. Has a complaint been filed in this matter? (Yes or No)No
------------------
If yes, Judge _ _ _ _ _ _ _ _ _ _ _ Magistrate Case No._ _ _ _ _ _ _ _ _ _ _ _ __
8. Does this case relate to a previously filed matter in this District Court? (Yes or No) l::::!2._
If yes, Judge _ _ _ _ _ _ _ _ _ _ _ Case No. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
9. Defendant(s) in federal custody as of _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
10. Defendant(s) in state custody as of _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
1 I. Rule 20 from the _ _ _ _ _ District of _ _ _ _ _ __
12. Is this a potential death penalty case? (Yes or No) l::::!2._
13. 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 M. Strauss)? (Yes or No) l::::!2._
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? l::::!2._
16. Did this matter involve the participation of or consultation with Magistrate Judge Marty Fulgueira
Elfenbein during her tenure at the U.S. Attorney's Office, which concluded on March 5, 2024?l::::!2._
17. Did this matter involve the participation of or consultation with Magistrate Judge Ellen F. D ' Angelo
during her tenure at the U.S. Attorney's Office, which concluded on October 7, 2024?l::::!2._
C: Qy ; ==~-
Sean Paul Cronin
Ass istant United States Attorney
....:::::::...,
)
SDFL Court ID No. A5500940
Case 0:25-cr-60036-WPD Document 1 Entered on FLSD Docket 02/19/2025 Page 9 of 12
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENAL TY SHEET
Defendant's Name: McNeil McKay Wilson
Case No: - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Count#: 1
Conspiracy to Commit Wire Fraud
Title 18 United States Code Section 371
* Max.Term of Imprisonment: 5 years
* Mandatory Min. Term of Imprisonment (if applicable):
* Max. Supervised Release: 3 years
* Max. Fine: The greater of $250,000 or twice the gross loss or gain
Counts#:
* Max. Term of Imprisonment:
* Mandatory Min. Term of Imprisonment (if applicable):
* Max. Supervised Release:
* Max.Fine:
Count#:
* Max.Term of Imprisonment:
* Mandatory Min. Term of Imprisonment (if applicable):
* Max. Supervised Release:
* Max.Fine:
*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 0:25-cr-60036-WPD Document 1 Entered on FLSD Docket 02/19/2025 Page 10 of 12
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENAL TY SHEET
Defendant's Name: Tatiana Nicole Lopez
Case No : - - - - - - - -- -- - - - - - - - - - - -- -- - - - - - - -
Count #: 1
Conspiracy to Commit Wire Fraud
Title 18 United States Code Section 371
* Max. Term of Imprisonment: 5 years
* Mandatory Min. Term of Imprisonment (if applicable):
* Max. Supervised Release: 3 years
* Max. Fine: The greater of $250,000 or twice the gross loss or gain
Counts#:
* Max. Term of Imprisonment:
* Mandatory Min. Term of Imprisonment (if applicable):
* Max. Supervised Release:
*Max.Fine:
Count #:
* Max.Term of Imprisonment:
* Mandatory Min. Term of Imprisonment (if applicable):
* Max. Supervised Release:
*Max.Fine:
*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution , special assessments, pa role ter ms, or forfeitures th a t may be applica ble.
Case 0:25-cr-60036-WPD Document 1 Entered on FLSD Docket 02/19/2025 Page 11 of 12
AO 455 (Rev. 01/09) Waiver ofan Ind ictment
UNITED STATES DISTRICT COURT
for the
Southern Di stri ct of Florid a
United States of Ameri ca )
V. ) Case No. 25-CR-60036-DIMITROULEAS/HUNT
MCNEIL MCKOY WILSON , )
)
Defendant )
W AIYER OF AN INDICTMENT
I understand th at I have been accused of one or more offenses punishable by imprisonment for more than one
year. I was advised in open court of my rights and the nature of the proposed charges against me.
After rece iving this advice, I waive my right to prosecutio n by indictment and consent to prosecuti on by
informati on.
Date: - - - - - - - -
Defendant's signature
Signature of defendant 's attorney
Printed name of defendant 's attorney
Judge 's signature
Judge 's printed name and title
Case 0:25-cr-60036-WPD Document 1 Entered on FLSD Docket 02/19/2025 Page 12 of 12
AO 455 (Rev. 01 /09) Waiver ofan Indictme nt
UNITED STATES DISTRICT COURT
fo r the
South ern District of Florida
United States of America )
V. ) Case No. 25-CR-60036-DIMITROULEAS/HUNT
TATIANA NICOLE LOPEZ, )
)
Defendant )
WAIVER OF AN INDICTMENT
I und erstand that I have been accused of one or more offenses punishable by imprisonment for more than one
year. I was advised in open co urt of my rights and the nature of the proposed charges against me.
After receiving this advice, I waive my ri ght to prosec uti on 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
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