Preliminary Order of Forfeiture — United States v. Conrad Brandon Bernard (Southern District of Florida)

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A Preliminary Order of Forfeiture in United States v. Conrad Brandon Bernard, Case No. 24-CR-60168-DIMITROULEAS, in the U.S. District Court for the Southern District of Florida, entered as Document 48 on March 5, 2025. The order grants the government's motion after the Court accepted the defendant's guilty plea on November 15, 2024 to Counts 1, 6, 7, and 8 of a Superseding Information charging bank fraud, access device and aggravated identity theft offenses. Citing the Factual Proffer, it states that the defendant applied for fourteen Economic Injury Disaster Loans using other people's identifying information and moved EIDL funds and unemployment benefits through Wells Fargo and Robinhood accounts. It enters a forfeiture money judgment of $1,083,340 and forfeits assets in listed Robinhood and Wells Fargo accounts.

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Case 0:24-cr-60168-WPD Document 48 Entered on FLSD Docket 03/05/2025 Page 1 of 10

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO. 24-CR-60168-DIMITROULEAS

UNITED STATES OF AMERICA

CONRAD BRANDON BERNARD,

Defendant.

PRELIMINARY ORDER OF FORFEITURE

THIS MATTER is before the Court upon motion of the United States of America (the

"United States") for entry of a Preliminary Order of Forfeiture ("Motion") against Defendant

CONRAD BRANDON BERNARD (the "Defendant"). The Court has considered the Motion, is

otherwise advised in the premises, and finds as follows:

On November 12, 2024, the United States filed a Superseding Information charging the

Defendant in Counts 1-6 with Bank Fraud in violation of 18 U.S.C. § 1344, in Count 7 with

Possession of Fifteen or More Unauthorized Access Devices in violation of 18 U.S.C.

§ 1029(a)(3), and in Counts 8 and 9 with Aggravated Identity Theft in violation of 18 U.S.C.

§ 1028A. Superseding Information, ECF No. 33. The Superseding Information also contained

forfeiture allegations, which alleged that upon conviction of a violation of 18 U.S.C. § 1029, the

Defendant shall forfeit to the United States: (a) any property constituting, or derived from,

proceeds obtained, directly or indirectly, as the result of such offense, pursuant to 18 U.S.C. §

982(a)(2)(B); and (b) any personal property used, or intended to be used, to commit such offense,

pursuant to 18 U.S.C. § 1029(c)(l)(C). See id. at 19. The forfeiture allegations also alleged that

upon a conviction of a violation of 18 U.S.C. § 1344, the Defendant shall forfeit to the United
Case 0:24-cr-60168-WPD Document 48 Entered on FLSD Docket 03/05/2025 Page 2 of 10

States any property constituting, or derived from, proceeds obtained, directly or indirectly, as the

result of such offenses and fraud scheme, pursuant to 18 U.S.C. § 982(a)(2)(A). See id.

On November 15, 2024, the Court accepted the Defendant's guilty plea to Counts 1, 6, 7,

and 8 of the Superseding Information. See Minute Entry, ECF No. 34; Plea Agreement~ 1, ECF

No. 36. As part of the guilty plea, the Defendant agreed to a forfeiture money judgment in the

amount of $1,083,340 and the forfeiture of the assets listed below:

a. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, stored in, accessible via, and/or on deposit in Robinhood Markets, Inc.
account number 895707297, held in the name of S.H.;

b. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, formerly stored in, accessible via, and/or on deposit in Robinhood Markets,
Inc. account number 963802624, held in the name of A.F., approximately
$69,535.12 of which is currently held by the State of Michigan under property
identification number 3083441850;

c. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, formerly stored in, accessible via, and/or on deposit in Robinhood Markets,
Inc. account number 733596985, held in the name of J.K., approximately
$40,579.71 of which is currently held by the State of Michigan under property
identification number 30834359;

d. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, formerly stored in, accessible via, and/or on deposit in Robinhood Markets,
Inc. account number 612984559, held in the name of A.G., approximately
$155,391.29 of which is currently held by the State of Michigan under property
identification number 30814411;

e. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, formerly stored in, accessible via, and/or on deposit in Robinhood Markets,
Inc. account number 566568309, held in the name of C.G., approximately
$98,357.99 of which is currently held by the State of Michigan under property
identification number 30850593;

f. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, stored in, accessible via, and/or on deposit in Robinhood Markets, Inc.
account number 430883090, held in the name of C.R.;

g. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, formerly stored in, accessible via, and/or on deposit in Robinhood Markets,

2
Case 0:24-cr-60168-WPD Document 48 Entered on FLSD Docket 03/05/2025 Page 3 of 10

Inc. account number 881031496, held in the name of K.L., approximately
$70,295.37 of which is currently held by the State of Michigan under property
identification number 30833469;

h. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, stored in, accessible via, and/or on deposit in Robinhood Markets, Inc.
account number 706188737, held in the name of G.R.;

i. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, formerly stored in, accessible via, and/or on deposit in Robinhood Markets,
Inc. account number 616320958, held in the name of M.M., approximately
$87,499.72 of which is currently held by the State of Florida;

J. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, stored in, accessible via, and/or on deposit in Robinhood Markets, Inc.
account number 769545740, held in the name ofR.B.;

k. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, formerly stored in, accessible via, and/or on deposit in Robinhood Markets,
Inc. account number 712854165, held in the name of S.A., approximately
$65,667.08 of which is currently held by the State of Michigan under property
identification number 30823008;

I. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, formerly stored in, accessible via, and/or on deposit in Robinhood Markets,
Inc. account number 440859379, held in the name ofB.P.;

m. All funds formerly on deposit in Wells Fargo Bank NA account number
3313637625, held in the name ofT.H.; and

n. All funds formerly on deposit in Wells Fargo Bank NA account number
7171407062, held in the name ofT.T.

Plea Agreement ,i 13.

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, ECF No.

37. The Factual Proffer also provided a basis for the forfeiture of property. See id. at 2-4.

Beginning as early as in or around May 2020 and continuing through on or about December

2022, the Defendant engaged and executed a scheme to defraud Wells Fargo Bank NA ("Wells

Fargo") and TD Bank, N.A. ("TD Bank") for personal gain by using the name and personal

3
Case 0:24-cr-60168-WPD Document 48 Entered on FLSD Docket 03/05/2025 Page 4 of 10

identification information ("PII") of other individuals without their knowledge or consent to create

accounts at Wells Fargo and TD Bank. See Factual Proffer 2-3. The Defendant then fraudulently

impersonate those individuals for the purpose of transferring or withdrawing funds owned by or

under the custody or contra 1 of Wells Fargo and TD Bank. See id.

The Defendant accomplished this scheme by fraudulently applying for fourteen (14)

separate Economic Injury Disaster Loans ("EDIL") using the PII of other individuals without their

knowledge or consent. See id. at 3. Once the Small Business Administration ("SBA") approved

the fraudulent applications, the SBA transferred the EIDL funds to various Wells Fargo bank

accounts at The Defendant's direction. See id. The Defendant opened and operated these Wells

Fargo accounts using the PII of other individuals without those individuals' knowledge or consent.

See id. The Defendant then transferred those funds from the Wells Fargo bank accounts to other

accounts under his control, including various accounts held with Robinhood Markets, Inc.

("Robinhood")-Robinhood accounts that the Defendant created using the PII of other individuals

without their knowledge or consent. See id. In one instance, on July 28, 2020, the Defendant

transferred $50,000 of EIDL funds from Wells Fargo Account ending in 4245, an account the

Defendant opened and operated using the PII of R.B. without R.B.' s knowledge or consent, to a

Robinhood account ending in 9379, another account the Defendant opened using the PII of B.P.

without B.P.'s knowledge or consent. See Factual Proffer 3.

The Defendant also accomplished his bank fraud scheme by transferring or withdrawing

fraudulently obtained unemployment benefit proceeds from various Wells Fargo accounts that he

opened and operated using the PII of other individuals without their knowledge or consent. See id.

These fraudulently obtained unemployment benefits were paid by several states, including West

Virginia and Arizona. See id. at 3-4. The unemployment benefit proceeds were fraudulently

4
Case 0:24-cr-60168-WPD Document 48 Entered on FLSD Docket 03/05/2025 Page 5 of 10

obtained because the name and PII of other individuals were used to apply for the unemployment

benefits without those individuals' knowledge or consent. See id. at 4.

In all, the Defendant fraudulently obtained $1,083,340 in EIDL proceeds and

unemployment benefits and transferred, and/or withdrew, those criminally derived proceeds to,

and/or from, Wells Fargo accounts ending in 5375, 4245, 5268, 3482, 1 2318, 9488, 9990, 2894,

4172, 7265, 6550, 3644, 0406, 1824, 6920, and 9545-bank accounts that the Defendant opened

and operated using the PII of other individuals without their knowledge or consent. See id. From

there, the Defendant caused at least a portion of the criminal proceeds to ultimately come to rest

in Robinhood Markets, Inc. accounts ending in 7297, 2624, 6985, 4559, 8309, 3090, 1496, 8737,

0958, 5740, 4165, and 9379, and in Wells Fargo accounts ending in 7625 and 7062-accounts that

the Defendant opened and operated using the PII of other individuals without their knowledge or

consent. See id.

Based on the record in this case, the total value of the proceeds the Defendant obtained as

a result of the offenses of conviction and fraud scheme is $1,083,340, which sum may be sought

as a forfeiture money judgment pursuant to Rule 32.2 of the Federal Rules of Criminal Procedure.

In addition, also based on the record in this case, the following specific property is directly

subject to forfeiture, pursuant to 18 U.S.C. § 982(a)(2)(A) and (a)(2)(B).

a. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, stored in, accessible via, and/or on deposit in Robinhood Markets, Inc. account
number 895707297, held in the name of S.H.;

1
The United States determined that the Defendant's Factual Proffer contains a scrivener's error.
The Factual Proffer incorrectly lists "3481" as the last four digits of an account that was used by
the Defendant. See Factual Proffer 4, ECF No. 37. The correct account number ends in "3482" as
listed herein.

5
Case 0:24-cr-60168-WPD Document 48 Entered on FLSD Docket 03/05/2025 Page 6 of 10

of which is currently held by the State of Michigan under property identification
number 3083441850;

c. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, formerly stored in, accessible via, and/or on deposit in Robinhood Markets,
Inc. account number 733596985, held in the name of J.K., approximately $40,579.71
of which is currently held by the State of Michigan under property identification
number 30834359;

e. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, formerly stored in, accessible via, and/or on deposit in Robinhood Markets,
Inc. account number 566568309, held in the name of C.G., approximately $98,357.99
of which is currently held by the State of Michigan under property identification
number 30850593;

f. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, stored in, accessible via, and/or on deposit in Robinhood Markets, Inc. account
number 430883090, held in the name of C.R.;

g. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, formerly stored in, accessible via, and/or on deposit in Robinhood Markets,
Inc. account number 881031496, held in the name ofK.L., approximately $70,295.37
of which is currently held by the State of Michigan under property identification
number 30833469;

h. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, stored in, accessible via, and/or on deposit in Robinhood Markets, Inc. account
number 706188737, held in the name of G.R.;

j. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, stored in, accessible via, and/or on deposit in Robinhood Markets, Inc. account
number 769545740, held in the name ofR.B.;

k. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, formerly stored in, accessible via, and/or on deposit in Robinhood Markets,

6
Case 0:24-cr-60168-WPD Document 48 Entered on FLSD Docket 03/05/2025 Page 7 of 10

Inc. account number 712854165, held in the name of S.A., approximately $65,667.08
of which is currently held by the State of Michigan under property identification
number 30823008;

1. All assets, including any funds, securities, and cryptocurrencies or other digital
assets, formerly stored in, accessible via, and/or on deposit in Robinhood Markets,
Inc. account number 440859379, held in the name ofB.P.;

m. All funds formerly on deposit in Wells Fargo Bank NA account number 3313637625,
held in the name of T.H.; and

n. All funds formerly on deposit in Wells Fargo Bank NA account number 7171407062,
held in the name of T. T.

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

the Motion is GRANTED, and it is hereby ORDERED that:

1. Pursuant to 18 U.S.C. § 982(a)(2)(A) and (a)(2)(B), and the procedures set forth in

21 U.S.C. § 853 and Rule 32.2 of the Federal Rules of Criminal Procedure, a forfeiture money

judgment in the amount of $1,083,340 in U.S. currency is hereby entered against the Defendant.

2. Pursuant to 18 U.S.C. § 982(a)(2)(A) and (a)(2)(B), the following specific property

is hereby forfeited and vested in the United States of America:

a. All assets, including any funds, securities, and cryptocurrencies or other
digital assets, stored in, accessible via, and/or on deposit in Robinhood
Markets, Inc. account number 895707297, held in the name of S.H.;

b. All assets, including any funds, securities, and cryptocurrencies or other
digital assets, formerly stored in, accessible via, and/or on deposit in
Robinhood Markets, Inc. account number 963802624, held in the name of
A.F., approximately $69,535.12 of which is currently held by the State of
Michigan under property identification number 3083441850;

c. All assets, including any funds, securities, and cryptocurrencies or other
digital assets, formerly stored in, accessible via, and/or on deposit in
Robinhood Markets, Inc. account number 733596985, held in the name of
J.K., approximately $40,579.71 of which is currently held by the State of
Michigan under property identification number 30834359;

d. All assets, including any funds, securities, and cryptocurrencies or other
digital assets, formerly stored in, accessible via, and/or on deposit in

7
Case 0:24-cr-60168-WPD Document 48 Entered on FLSD Docket 03/05/2025 Page 8 of 10

Robinhood Markets, Inc. account number 612984559, held in the name of
A.G., approximately $155,391.29 of which is currently held by the State of
Michigan under property identification number 30814411;

e. All assets, including any funds, securities, and cryptocurrencies or other
digital assets, formerly stored in, accessible via, and/or on deposit in
Robinhood Markets, Inc. account number 566568309, held in the name of
C.G., approximately $98,357.99 of which is currently held by the State of
Michigan under property identification number 30850593;

f. All assets, including any funds, securities, and cryptocurrencies or other
digital assets, stored in, accessible via, and/or on deposit in Robinhood
Markets, Inc. account number 430883090, held in the name of C.R.;

g. All assets, including any funds, securities, and cryptocurrencies or other
digital assets, formerly stored in, accessible via, and/or on deposit in
Robinhood Markets, Inc. account number 881031496, held in the name of
K.L., approximately $70,295.37 of which is currently held by the State of
Michigan under property identification number 30833469;

h. All assets, including any funds, securities, and cryptocurrencies or other
digital assets, stored in, accessible via, and/or on deposit in Robinhood
Markets, Inc. account number 706188737, held in the name of G.R.;

i. All assets, including any funds, securities, and cryptocurrencies or other
digital assets, formerly stored in, accessible via, and/or on deposit in
Robinhood Markets, Inc. account number 616320958, held in the name of
M.M., approximately $87,499.72 of which is currently held by the State of
Florida;

j. All assets, including any funds, securities, and cryptocurrencies or other
digital assets, stored in, accessible via, and/or on deposit in Robinhood
Markets, Inc. account number 769545740, held in the name ofR.B.;

k. All assets, including any funds, securities, and cryptocurrencies or other
digital assets, formerly stored in, accessible via, and/or on deposit in
Robinhood Markets, Inc. account number 712854165, held in the name of
S.A., approximately $65,667.08 of which is currently held by the State of
Michigan under property identification number 30823008;

I. All assets, including any funds, securities, and cryptocurrencies or other
digital assets, formerly stored in, accessible via, and/or on deposit in
Robinhood Markets, Inc. account number 440859379, held in the name of
B.P.;

8
Case 0:24-cr-60168-WPD Document 48 Entered on FLSD Docket 03/05/2025 Page 9 of 10

m. All funds formerly on deposit in Wells Fargo Bank NA account number
3313637625, held in the name ofT.H.; and

n. All funds formerly on deposit in Wells Fargo Bank NA account number
7171407062, held in the name ofT.T.

3. Any duly authorized law enforcement agency may seize and take possession of the

forfeited property according to law.

4. The United States shall send and publish notice of the forfeiture in accordance with

Rule 32.2(b)(6) of the Federal Rules of Criminal Procedure and 21 U.S.C. § 853(n).

5. 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-party 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).

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

is final as to the Defendant.

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

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

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

identified.

It is further ORDERED that upon adjudication of all third-party interests, if any, the Court

will enter a final order of forfeiture as to the property in which all interests will be addressed.

Upon notice from the United States that no claims have been filed within 60 days of the first day

of publication or within 30 days of receipt of notice, whichever is earlier, then, pursuant to Rule

32.2(c)(2) of the Federal Rules of Criminal Procedure and 21 U.S.C. § 853(n)(7), this Order shall

become a Final Order of Forfeiture and any duly authorized law enforcement agency shall dispose

9
Case 0:24-cr-60168-WPD Document 48 Entered on FLSD Docket 03/05/2025 Page 10 of 10

of the property in accordance with applicable law.

DONE AND ORDERED in Fort Lauderdale, Florida, this

UNITED STATES DISTRICT JUDGE

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