Indictment-. — United States v. Phillip Michael Valcin Jr. (companion docket to United States v. Lindsley Chambers Jr. et al., 0:25-cr-60273-PCH)

Source document: Indictment-; document type: Factual proffer (guilty plea).

Full text

UNITED STATES DISTRICT COURT
SOUTH ERN DISTRICT OF FLORIDA
CASE NO. 25-CR-60273-H UCK
UNITED STATES OF AM ERICA
VS.
PH ILLIP M ICHAEL VALCIN .11:9
Defendant.
/
FACTUAL PROFFER
The United States of America and PHILLIP MICHAEL VALCIN JR (hereinafter,
lrefendanf') hereby stipulate and agree that, were this case to proceed to trial, the United States
would prove beyond a reasonable doubt the following facts, nm ong others, which occurred in
Broward County, in the Southern District of Florida, and elsewhere, at all tim es material to the
Indictment-.
Backzround
1.
Bank of America, N.A. (EtBank of America'') was a tinancial illstitution whose
accounts were insmed by the Federal Deposit lnsumnce Corporation (çTDlC'').
2.
Unemployment lnstlrance (ççUl'') was a joint state and federal progrnm that provided
m onetary benefhs to eligible beneficiaries. U1 benefits were intended to provide temporary financial
assisfnnce to lawful workers who were unemployed through no fatllt of their own.
3.
Beginning in or arotmd M arch 2020, in response to the COVID-19 pandem ic, the
Coronavirus Aid, Relietl and Economic Security ICARESI Act of 2020 created several federal
program s, including the Pandemic Unemployment Assistance Program, Federal Pandemic
Unemploym ent Compensation, and the Lost W ages Assistance Program, which expanded U1
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eligibility and increased U1 benefits to individuals who were unemployed because of the COV1D-l9
pandemic (éépandemic UI Benefits'').
4.
The California Employment Development Depar% ent (EECA-EDD'') was an agency
of the State of Califomiathat adm inistered UI benefits for residents of California, including Pandemic
Ul Benefits. Persons applying for Ul benefits in California, including Pandemic UI Benefits, were
required to reside in the State of California and subm it to CA-EDD an application for the benefits.
Applications for Pandemic Ul Benefits were submitted online.
A claimant for Pandemic Ul Benetits was required to answer various questions on the
claimant's application to esublish the claimant's eligibility for the benefits. Among other things, the
claimant was required to provide personally identifiable information (ûûP11''), including the claimant's
name, date of birth, and social security number, and certify to CA-EDD under penalty of perjury that
the COVlD-l9 pandemic had directly and adversely affected the claimant's employment. Claimants
applying for Pandem ic U1 Benefits did not need to submit any supporting documents to CA-EDD
with their applications. lndividuals who were employed, retired, or incarcerated were not eligible for
U1 benefits, including Pandemic U1 Benefits. The CA-EDD relied upon the information in the
application to determine the claimant's eligibility for benefits.
Additionally, to successfully t5le a claim for Pandemic Ul Benefits with CA-EDD, the
claimant had to pass an identity veritication provided by lD.me, Inc. (dt1D.me''), a third-party online
identity verification service. The lD.me. identity verification process required the claimantto provide
the claimant's PlI, a government-issued form of identification, and a selfie photograph Gken in real-
time. During the lD.me identity verification process, a text message was sent to the phone number
provided by the applicant that contained a link that allowed the claimant to provide the required
photograph of the claimant's government-issued form of identification and take a real-time selfie
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photograph. ID.me's facial recognition software was then used to compare the applicant's real-time
selfie photograph with the photograph on the claimant's government-issued form of identification.
If CA-EDD approved an application and granted Pandem ic Ul Benefits to the
claimant, Bank of America created a prepaid debit account in the claimant's name (EIBOA Debit
Accounf') into which CA-EDD deposited the claimant's Pandemic U1 Benetits. The Pandemic Ul
Benefks deposited in the BOA Debit Account were moneys and funds under the custody and control
of Bank of America.
8.
To access the Pandemic Ul Benefits that were deposited in the BOA Debit Account,
Bank of America issued a debit card (<ûBOA Debit Card'') in the name of the claimant that was linked
to the claimant's BOA Debit Account conuining the money and funds from the Pandemic Ul
Benefits. Bank of America mailed the BOA Debit Card to an address provided by the claimant and
could be activated by telephone or online. Once activated, the BOA Debit Card could be used to
withdraw Pandemic U1 Benefits from the BOA Debit Account in the form of cash dispensed from
automated teller machines (û1ATMs''), including ATMS that Barlk of America operated. The BOA
Debit Cards could also be used to make purchases by debiting the claimant's Pandem ic Ul Benefits
from the BOA Debit Account in point-of-sale transactions.
Visa Debt Processing Solutions Ctvisa DPS'') was a vendor contracted by Bank of
America to process all transactions on Ul prepaid debit cards, including those issued by the CA-EDD.
Visa DPS had two platform processor data centers that housed all of the Ul prepaid card dat'z for Bank
of America. Those dat centers were located in Ashburn, Virginia and Highlands Ranch, Colorado.
Any transaction made on a Bank of America Ul prepaid debit card, including loading of funds, point-
of-sale transactions, and ATM  withdrawals, passed through one of those two dat'z processor centers.
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The Conspiracv
l 0.
From in and around September 2020, and continuing through in or around M ay
2022, Defendant agreed with co-defendants Lindsley Chambers Jr., Robert M cKinley Thomas,
Justin Anthony Seivright, Tacaveon Travon Carson, Brandon Jerome Snider, Patrick M arquis
Ayton Jr., and others, to accomplish a common and unlawful plan to comm it bank fraud and wire
fraud. The purpose of the unlawful plan was for Defendant and his co-conspirators to enrich
themselves by fraudulently obtaining Ul benefits, including Pandemic UI Benefits, from CA-EDD
that were under the custody and control of financial institutions, including Bank of America.
Defendant knew the unlawful purpose of the plan and willfully joined in it.
1 1 .
Defendant and his co-conspirators carried out the conspiracy in multiple steps,
including, but not limited to, the following:
a.
One or more co-conspirators obtained without lawful authority PII of
victims of identity theft (dçldentity Theft Victims''), including names, dates
of birth, and social security numbers.
One or more co-conspirators created counterfeit driver licenses and other
fictitious fonns of identification (collectively, ûûcounterfeit 1Ds'') by
combining unlawfully obtained Pll of ldentity Theft Victim s and
photographs of co-conspirators, including co-defendants Chambers and
Thom as.
b.
One or more co-conspirators subm itted and caused the subm ission of false
and fraudulent applications to CA-EDD for Pandemic Ul Benefits using the
unlawfully obtained Pll and Counterfeit lDs. These applications were
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submitted online and caused information to be transmitted by wire in
interstate conznlerce.
W hen prompted to verify the identity of the purported applicant through
ID.me, Chambers and one or more co-conspirators subm itted for
comparison a real-time selfie photograph of Chambers' face and a
photograph of a Counterfeit ID bearing a picture of Chambers's face and
Pl1 of the purported applicant (i.e., an ldentity Theft Victim).
d.
Defendant and his co-conspirators possessed and used BOA Debit Cards
issued in the names of ldentity Theft Victims to fraudulently access and
receive Pandemic Ul Benefits, in the form of money and funds under the
custody and control of Bank of America, by making cash withdrawals at
ATM S and debit purchase.
12.
ln total during the conspiracy, the co-conspirators subm itted and caused the
subm ission of false and fraudulent applications to CA-EDD for Pandem ic Ul Benefits on
behalf of at least 146 unique Identity Theft Victims. As a result of these false and fraudulent
applications, the co-conspirators caused CA-EDD to pay Pandemic UI Benefits in the
approximate amount of $2,095,831, which CA-EDD disbursed to BOA Debit Accounts under
the custody and controlof Bank of America.
Defendant's R ole in the C onspiracy
13.
Defendant's role in the conspiracy included, among other things, making cash
withdrawals of fraudulently obtained Pandemic Ul Benefits at Bank of America ATM S in Broward
County using BOA Debit Cards issued in the names of ldentity Theft Victim s. ATM  surveillance
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photographs show that, from approximately April 12, 2021 through November 1 7, 2021,
Defendant m ade at least l 1 separate withdrawals of fraudulently obtined Pandemic UI Benefits
at Bank of America ATM S in Broward County using BOA Debit Cards issued to at least 8 unique
ldentity Theft Victim s. Four of the BOA Debit Cards that Defendant used were also used by co-
defendant Thomas to make withdrawals of fraudulent Pandem ic Ul Benefits. Additionally,
Defendant used his phone number ending in 6465 to activate four BOA Debit Cards, two of which
Defendant used to withdraw fraudulent Pandemic Ul Benefits.
l4.
In particular, on M ay 18, 2021, at approximately 7:50 p.m., during and in relation
to a felony violation of Title 18, United States Code, Section 1344 (bank fraud), Defendant
knowingly possessed and used without lawful authority the means of identification of another
person. That is, Defendant possessed and used the BOA Visa Debit Card ending num ber 2734 of
J.E., an Identity Theft Victim, to withdraw $1,000 of fraudulently obtained Pandemic Ul Benefsts
from a Bank of Am erica ATM  located in Lauderhill, Florida. J.E. did not file any application for
any UI benefits with CA-EDD, did not give anyone pennission to file for UI benefits with CA-
EDD, did not provide or authorize his Pll to be possessed or used by Defendant for any purpose,
and did not know Defendant or anyone else used J.E.'S identity to f5le for Ul benefts and withdraw
fraudulent Ul benefits.
15.
As a result of Defendant's own conduct in the conspiracy, and the conduct of his
co-conspirators reasonably foreseeable to him, Defendant is responsible for causing an intended
loss greater than $1,500,000 and less than $3,500,000.
LRemainder ofpage lntentionally Blankj
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16.
The United States and Defendant agree that these facts, which do not include all
facts known to the United States and Defendant, are sum cient to prove beyond a reasonable doubt
the elements of conspiracy to bank fraud and wire fraud, in violation of Title 18, United States
Code, Section 1349, as charged in Count l , and aggravated identity theh, as charged in Count 30,
and that Defendant is in fact guilty of those oFenses.
-5/1: i
Date: (
oate: i =G
By :
QUIRONES
UNITED STATES ATTORNEY
#
DAV A. SNID
ASSI TAN UNITED STATES ATTOIW EY
JA ES A . S
ATTORNE
R DEFENDANT
JASON A . REDING
PHILLIP M ICHAEL VALCIN JR
DEFENDANT
Xlav
oate, ;
Case 0:25-cr-60273-PCH   Document 153   Entered on FLSD Docket 03/19/2026   Page 7 of 7

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