Preliminary Order of Forfeiture — United States v. Zachary Kameron Ramyard (Southern District of Florida)

Summary

A Preliminary Order of Forfeiture in United States of America v. Zachary Kameron Ramyar, Case No. 24-CR-20382-DPG, in the United States District Court for the Southern District of Florida, entered on the docket March 27, 2025 as Document 40. It recites that an Information filed August 29, 2024 charged conspiracy to commit wire fraud under 18 U.S.C. § 1349, and that the Court accepted the guilty plea on October 31, 2024. Quoting the factual proffer, it states that from about August 2020 through August 2022 the defendant and co-conspirators submitted fraudulent unemployment insurance claims to the EDD in California, which deposited $1,288,500 onto debit cards they controlled. The order enters a forfeiture money judgment of $1,288,500 and states it is final as to the defendant.

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“Preliminary Order of Forfeiture — United States v. Zachary Kameron Ramyard (Southern District of Florida).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/40-preliminary-order-of-forfeiture-as-to-zachary-kameron-ramyar-d2ad9256e5/, SHA-256 51f0b3382fa3f3776839e00c2bb567a4cb91f463f2ac53c6d5e04150ed5070c1.

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Case 1:24-cr-20382-DPG Document 40 Entered on FLSD Docket 03/27/2025 Page 1 of 4

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO. 24-CR-20382-DPG

UNITED STATES OF AMERICA

ZACHARY KAMERON RAMY ARD,

Defendant.
- - - - - - - - - - - - - - - - -I
PRELIMINARY ORDER OF FORFEITURE

THIS MATTER is before the Comi for entry of a Preliminmy Order of Forfeiture against

the defendant Zachary Kameron Ramyard. Having reviewed the record and the applicable law, the

Cour is otherwise advised in the premises, and finds as follows:

On August 29, 2024, the United States filed an Information charging the defendant with

conspiracy to commit wire fraud in violation of 18 U.S.C. § 1349. DE 4. The Information also

contained forfeiture allegations, which alleged that upon conviction of a violation of 18 U.S.C.

§ 1349, the Defendant shall forfeit any property that constitutes or is derived from proceeds

traceable to the offense See id. at 4-5.

On October 31, 2024, the Court accepted the defendant's guilty plea to the Information.

See Minute Ent1y, DE 14; Plea Agreement ,r 1, DE 16. As pmi of the guilty plea, the defendant

agreed to a forfeiture money judgment in the amount of $1,288,500.

In support of the guilty plea, the defendant executed a Factual Proffer, and the Court found

that there was a factual basis to support the defendant's conviction. See Factual Proffer, DE 15.

The Factual Proffer also provided a basis for the forfeiture of property. See id. at 2.

As the defendant agreed in his factual proffer: Unemployment Insurance ("UI") was a joint
Case 1:24-cr-20382-DPG Document 40 Entered on FLSD Docket 03/27/2025 Page 2 of 4

state and federal program that provided monetaiy 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 Department (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 provide their name, Social Security Number (SSN), and

mailing address, among other things, and to self-certify 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.

From in or around August 2020 through in or around August 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

2
Case 1:24-cr-20382-DPG Document 40 Entered on FLSD Docket 03/27/2025 Page 3 of 4

with co-conspirators and submitting the electronic applications. The Defendant created new

contact email addresses to submit and track fraudulent applications, including

d1john3900@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

different ATMs to withdraw hundreds of thousands of dollars in UI funds from various debit cards.

For example, on November 4, 2020, ATM surveillance shows the defendant withdrawing $980

from a debit card ending in 0371, issued to "M.O.M.," at a Bank of America ATM in Osceola

County, Florida. M.O.M. confirmed that he never filed for unemployment benefits or authorized

anyone to do so on his behalf. The Defendant used the fraudulent UI proceeds to make luxury

purchases in Miami, Florida, and elsewhere.

Accordingly, based on the foregoing, the evidence in the record, and for good cause shown,

it is hereby ORDERED that:

1. Pursuant 18 U.S.C. § 981(a)(l)(C) and Rule 32.2 of the Federal Rules of Criminal

Procedure, a forfeiture money judgment in the amount of $1,288,500 is hereby entered against the

defendant.

3
Case 1:24-cr-20382-DPG Document 40 Entered on FLSD Docket 03/27/2025 Page 4 of 4

2. The United States is authorized to conduct any discovery that might be necessary

to identify, locate, or dispose of forfeited property, and to resolve any third-paiiy petition, pursuant

to Rule 32.2(b)(3), (c)(l)(B) of the Federal Rules of Criminal Procedure and 21 U.S.C. § 853(m).

3. Pursuant to Rule 32.2(b)(4) of the Federal Rules of Criminal Procedure, this Order

is final as to the defendant.

4. The Court shall retain jurisdiction in this matter for the purpose of enforcing this

Order, and pursuant to Rule 32.2(e)(1) of the Federal Rules of Criminal Procedure, shall amend

this Order, or enter other orders as necessary, to forfeit additional specific prope1iy when

identified.

DONE AND ORDERED in Miami, Florida, this 26th day of March 2025.
...

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