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Criminal Complaint — U.S. v. Judlex Jean Louis (S.D. Fla.)

Summary

A criminal complaint and supporting affidavit against Judlex Jean Louis, Case 0:20-mj-06328-PMH, in the United States District Court for the Southern District of Florida, entered on the docket August 6, 2020. The complaint charges bank fraud, false statements to a federally insured institution and aggravated identity theft. In the affidavit, United States Secret Service Special Agent Vernon Poindexter states that Louis used bank accounts opened with a false social security number to receive proceeds of three PPP loans from Bank A: $20,833.00 in Louis's name, $19,412.00 in an accomplice's name and $19,988.00 in the name of a victim, totaling $60,233.00. It states that the Louis application certified that he was not subject to pending criminal charges when he was, and that video showed Louis withdrawing loan proceeds.

Summary drafted by a model from the text of the original file linked on this page and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Criminal Complaint — U.S. v. Judlex Jean Louis (S.D. Fla.).” Original at ecf.flsd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-0-20-mj-06328-dkt-1-s-d-fla-fc658421df/, SHA-256 ffe49971ea19ec562dedf9659c2a1d914c1cd0c9f2032a0878290c0d0b8e3594.

Full text

  Case 0:20-mj-06328-PMH Document 1 Entered on FLSD Docket 08/06/2020 Page 1 of 12


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18 U.S.C.â 1344                                                             BankFraud
18 U.S.C.j 1014                                                             Fal
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18U.S.C.5 1028A(a)(1)                                                       Aggravated Identity Theft




              Thiscriminalcomplaintisbased on these facts:

See attached Amdavit.



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Case 0:20-mj-06328-PMH Document 1 Entered on FLSD Docket 08/06/2020 Page 2 of 12




                   AFFIDA VIT IN SUPPO R T O F A CRIM INA L C O M PLAINT

           1,VernonPoindexter,being tlrstduly sworn,state:

                        AG ENT BA CK G RO U ND AN D IN TR O DU CTIO N

                  lam aSpecialAgentwiththeUnited StatesSecretService(($USSS''),and have
    been so employed since June2019.Icurrently serve ontheSouth Florida Organized Fraud Task

    Force(SASFOFTF'')inM iami,Florida.lhavereceived extensivetrainingin theinvestigation of
    counterfeit currency,check fraud,bank fraud,access device fraud,wire fraud and cybercrime,

    am ong otherthings.As a federallaw enforcem entofficer ofthe United States,Iam em pow ered

    by law to conductinvestigationsand to m ake arrestsforfelony offenses,undertheauthority of 18

    U.S.C.j3056.lhavereceivedspecializedtraininginnumerousaspectsofcriminalinvestigations,
    in particular,investigationsinto financialfraud and methodsand techniquesused by individuals

    thatcom m itfraudulentactivity to avoid detection by law enforcem entofficers.

                  This Affidavit is m ade in support of a crim inal com plaint charging Judlex Jean

    Louis($iLOU1S'')with violationsofTitle 18,United StatesCode,Sections1344 (Bank Fraud),
    1014(FalseStatementtoaFederally lnsured lnstitution),and 1028A(a)(1)(Aggravatedldentity
    Theft).
           3.     This A txdavit is based on m y personalinvestigation and investigation by others,

    including federaland locallaw enforcem entofficialsw hom Iknow to be reliableand trustworthy.

    The facts contained herein have been obtained by interview ing w itnesses and exam ining

    documents obtained in the course of the investigation aswellas through othermeans. This

    Affidavitdoes notinclude every factknown to m e aboutthis investigation,butratheronly those

    factssufGcientto establish probable cause.
Case 0:20-mj-06328-PMH Document 1 Entered on FLSD Docket 08/06/2020 Page 3 of 12




                                        PRO BABLE CA USE

                            Overview ofthePaycheckProtectionProgram
           4.     TheCoronavirusAid,Relief,and Econom icSecurity (ACCARES'')Actisa federal
    law enacted M arch 27,2020 to provide financial assistance to Am ericans suffering econom ic

    harmsfrom thtCOVlD-l9 pandemic.Onesource ofreliefprovided through the CARES Actis

    theauthorization offorgivableloanstobusinessesforjob retention andcertain otherexpenses,
    through aprogram called thePaycheck Protection Program ($$PPP'').
                  The types of businesses eligible for a PPP loan under the CA RES A ct include

    individuals who operated under a sole proprietorship business structure. For the period from

    February l5,2020 through June 30,2020,such individuals were eligible to receive a m axim um

    PPP loan ofup to $20,833to coverlostcompensation orincom efrom the soleproprietorship.ln
    orderto beeligibleto receive such aPPP Ioan,individualshad to reportanddocum enttheirincom e

    and expenses from the sole proprietorship,as typically reported to the InternalRevenue Service

    on Form 1040,Schedule C.for a given tax year.The lending institution used these reports and

    docum entsto calculate the am ountofm oney the individualw asentitled to receive underthe PPP.

                  A PPP loan application m ustbe processed by a participating lender. lfa PPP loan

    application isapproved,the participating lenderfunds the PPP loan using its own m onies,w hich

    are fully guaranteed by Sm all Business Adm inistration. Data from the application, including

    inform ation aboutthe borrow er,the totalam ountofthe loan,and the listed num berofelnployees,

    istransm itted by the Ienderto the SBA in the course ofprocessing the loan.

                  PPP loan proceedsm ustbe used by the businesson certain penmissible expenses-

    payrollcosts,intereston m ortgages,rent,and utilities. The PPP allows the interestand principal

    on the PPP Ioan to be entirely forgiven ifthe business spendsthe loan proceeds on these expense
Case 0:20-mj-06328-PMH Document 1 Entered on FLSD Docket 08/06/2020 Page 4 of 12




    item sw ithin adesignated period oftim e afterreceiving the proceedsand usesa certain am ountof

   the PPP loan proceedson payrollexpenses.

                                    Overview ofL0UIS'sScheme
           8.     LOUISusedbankaccountsopenedwithfalsesocialsectlritynumbers($$SSNs'')to
   receiveproceeds from three fraudulentPPP loans.

           9.     ln the applications for these loans, the applicants used false SSN S and other

   peoples' identities, thereby concealing from the lender bank that LO UIS was the true loan

    recipient.ln one PPP loan application,LOU IS used his true name,butan SSN thatthe Social

    Security Administration (içSSA'')conf-irmed wasnotassigned tohim.ln thatsameapplication,
    LOUISalsocertifiedthathewasnotthesubjectofpendingcriminalchargeswhen,infact,hewas.
    ln a second PPP loan application,the applicantlisted A ccom plice 1'snam e,butan SSN thatthat

   the SSA confirm ed w asnotassigned to A ccom plice 1.ln athirdPPP loan application,theapplicant

   used a true nam e and SSN belonging to V ictim l,w ho had no relationship to LO UIS.

           10.    The PPP lenderbank approved and funded these three loan applicationsinto three

    depository accounts at three separate banks.Two of these depository accounts w ere opened in

    LOUIS'S nam e using the sam e false SSN he used to subm ita loan application in his nam e.The

   third accountw asopened in A ccom plice l'snam e,also using a false SSN dit-
                                                                              ferentfrom the false

    SSN used in the PPP loan in Accom plice l's nam e.A s established by the facts below ,LO U IS

    accessed orattem pted to accesstheproceedsfrom allthree loans.
Case 0:20-mj-06328-PMH Document 1 Entered on FLSD Docket 08/06/2020 Page 5 of 12




                                   RelevantEntities andA ccounts

           11.    Bank A w as a federally insuredltsnancialinstitution locattd in SaltLake City,

    Utah.Bank A w as a participating lender in SBA 'S PPP,authorized to lend funds to eligible

    borrowers underthe term softhe PPP.

           l2.    Bank A offered ctlstom ers in Florida the ability to apply forand receive PPP loans

    electronically through Bank ProcessorA.Bank ProcessorA was a financialtechnology com pany

    located in Redw ood City,California,thatenabled businessesto apply online forPPP loans.

           l3.    Bank B w asa federally insured creditunion located in M cLean,V irginia.Bank B

    records showed thatLO UIS held an accountat Bank B in his nam e and an SSN ending 6488,

    which SSA confirm ed w as notassigned to LO UIS.The account was registered to the m ailing

    address 7208 SW 4th Street, North Lauderdale, Florida 33068 (the ddNorth Lauderdale
    Residence''),Accomplice l'sregistered residence in Florida DepartmentofHighway Safety and
    MotorVehicles(':FLHSMV'')records.From onoraboutDecemberl3,2019throughonorabout
    M ay 13,2020,LO UIS'Sregistered residence in FLH SM V recordsw asalso the North Lauderdale

    Residence.

                  Bank C was a federally insured bank located in Birm ingham ,A labam a.Bank C

    recordsshow ed thatLOU IS held an accountatBank C in hisnam e and thefalse SSN ending 6488.

    Theaccountw asregistered to the m ailing address8551N W 50th Street,Lauderhill,Florida 33351

    (theSdlaauderhillResidence''),LOUIS'ScurrentregisteredresidenceinFLHSMV records.




    1Them eaningoftheterm ltfederally insured''asused inthisA ffidavitisthattheentity had deposits
    insured by the FederalDepositInsurance Corporation.
Case 0:20-mj-06328-PMH Document 1 Entered on FLSD Docket 08/06/2020 Page 6 of 12




                 Bank D wasa federally insured bank located in New York,New York.Bank D

    advised law enforcem entthatAccomplice lheld an accountatBank D in Accom plice 1's nam t

   and an SSN ending 4312,w hich the SSA confirm ed was notassigned to Accom plice 1.

                 Bank E was a federally insured bank located in N ew Castle,D elaware.Bank E

   recordsshowedthatLOUISheld anaccountatBank E inhisnameandthefalseSSN ending6488.

   The accountlisted the LauderhillResidence asa m ailing address.

                                 LO UIS '
                                        S FraudulentPPP Loans

           l7.   The governm ent has obtained records related to three fraudulent PPP loan

   applicationssubm itted onlineoverathree-day period to Bank A through Bank ProcessorA .Bank

   A approved and depositedthethreePPP loansinto threeseparateaccountsheld atthreedifferent

   banks.Thetable below sum m arizesthe detailsofeach loan.

       L         Approxim ate
        oan      A                  Claim ed Loan           A m ount        D epositA ccount
     N             pplication
       um ber       D                 A pplicant         Sought/Funded           Bank
                       ate
        G1''      June 1,2020          LOUIS               $20,833.00            Bank C
        <t2''     June3.2020         Accomplice1           $19,412.00            BankD
        ç<3''     June3,2020           Victim 1            $19,988.00            Bank E
                                        Total:             $60,233.00

                  Severalfactsaround these loanstied them to each otherand back to LO UIS:

       * The application for Loan 1 listed LOU IS'Strue nam e as the (dBusiness LegalN am e''and
           thefalseSSN ending6488astheBusiness'sTaxpayerIdentificationNumber(1iTlN'').The
           proceeds ofLoans l and 3 both w entto accountsopened in LOUIS'Snam e w ith the sam e
           false SSN ending 6488.

       @ The applications forLoans 1 and 3 both listed the N orth Lauderdale Residence- w hich is
           Accom plice I's registered address per FLH SM V records and where I have observed
           LO UIS as recently as A ugust 3,2020- as the applicant's ttBusiness Address.''A gents
           observed two vehiclesregistered to LO UIS in FLHSM V records parked outsidetheN orth
           LauderdaleResidenceon m ultipleoccasions.Video surveillance depicted LOU IS,in these
           sam etwo vehicles,repeatedly withdrawing funds from the accountinto w hich the Loan 2
           proceedswere deposited soon afterLoan 2 wasfunded.
Case 0:20-mj-06328-PMH Document 1 Entered on FLSD Docket 08/06/2020 Page 7 of 12




       @ The applications for Loans 2 and 3 included virtually identical em ail addresses and
         fraudulent supporting bank statem ents purportedly from Bank B.These statem ents had
         transactions,dates,and a mem ber num ber thatm atvhed LOU IS'S true Bank B account
         records.LO UIS'SBank B accountwas opened w ith the false SSN ending 6488 and listed
         theN orth LauderdaleResidence m ailing address.

       * Loans 2 and 3,and LOUIS'S Bank E accotlnt- the depository accountforLoan 3- were
           all accessed using a common Internet Protocol C1IP'') address.This IP address was
           registeredtoasubscriptioninAccomplice 1'snam eatanaddress,10 SW 7thStreet,Delray
           Beach,Florida 33444 (the kr elray Beach Residence''),where an agentobserved both
           LO UIS and A ccom plice 1 togetheron August2,2020.

                   A dditionalevidence connected LOU IS to the false SSN ending 6488,which isin

    turn tied to allthree loans as described above.Specifically,in an attemptto access the Loan 3

    proceeds,LOUIS placed a recorded callto Bank E in which he used histrue SSN ending 6411in

    an effortto validate ownership ofhisaccountatBank E.Thiseffbrtfailed,asLOU IS had used the

    false SSN ending in 6488 to open his Bank E account.Accordingly,Bank E asked LO UIS to

    provide a photograph ofhis driver's license to Bank E through the internet.LO UIS did so and

    provided aphotograph ofhisvalid Florida driver'slicense.Separately,Bank A advised thaton or

    aboutM ay 29,2020,LOU IS'SaccountatBank B- w hich,likethe accountatBank E,w asopened

    with the false SSN ending 6488- received a $10,117 PPP loan thatLOUIS obtained through an
    application thatused histrue name and histrue SSN ending 64ll.

                 Loan 1:Subm itted in LO UIS'SN am e with the False SSN Ending 6488

           20.     Recordsfrom Bank A showedanapplicationfora$20,833PPP loan subm itted on
    or about June 1, 2020, for LOU IS'S wholly-ow ned Ssbarber shop'' sole proprietorship. The

    Borrow erApplication Form listed LOU IS'Strue nam e asthe l'Business LegalN am e,''the N orth

    Lauderdale Residence asthe téBusinessAddress,''and thefalse SSN ending 6488 asthe iEBusiness

    TlN .''The Loan lapplication also included a supporting bank statem entthatlisted LOU IS'Snam e

    and the addressoftheN orth Lauderdale Residence.


                                                  6
Case 0:20-mj-06328-PMH Document 1 Entered on FLSD Docket 08/06/2020 Page 8 of 12




                   The applicantcertified thatLOUIS wasnotSssubjectto an indictment,criminal
    inform ation,arraignm ent,or other m eans by which form alcrim inalcharges are brought in any

   jurisdiction,orpresentlyincarcerated,oronprobation orparole.''Atthetime,however,LOUIS
   wasthesubjectofacriminalinformationintheSeventeenthJudicialCircuitinandforBroward
    CountyinStateqfFloridav.fouis,CaseNo.16001l54CFIOA.Thestatecoul'tarraignedLOUIS
    on thistheft,m oney laundering,and fraud inform ation on oraboutFebruary 4,2016.

                   OnoraboutJune2,2020,BankA deposited Loan 1for$20,833 into an accountin
    LOUIS'S nam e atBank C,which was opened w ith the sam e false SSN ending 6488 used in the

    application.

    Loan 2:LO&f,
               5'Capturedon VideoM aking Cash WithdrawalsSoonAjterPPP Loan Deposit
           23.     Recordsfrom BankA showed an applicationfora$19,412PPP loan subm ittedon
    oraboutJune 3,2020,forAccom plice 1'sw holly-ow ned çsprofservices''sole proprietorship.The

   Borrow erApplication Form Iisted Accom plice l'strue name as the ViBusiness LegalN am e''and

    an SSN ending 4312 thatthe SSA confirm ed wasnotassigned to Accom plice 1 asthe iiBusiness

    TlN.''The application listed theemailaccountvalue33069@gmail.com.W ith theapplication,
    Bank A received a copy ofa dated version ofA ccom plice 1'strue Florida driver's Iicense,which

    Accom plice lhad replaced to listtheN orth Lauderdale Residence in oraround January 2020.The

    application also included a fh udulent supporting bank statement that pum orted to be for an

    accountheld by Accom plice 1 atBank B,butthathad transactions,dates,and a m em bernumber

    thatm atched LOU IS'Strue Bank B accountrecords.

           24.     On oraboutJune4,2020,Bank A deposited Loan 2 for$19,412 into Accomplice
    l'saccountatBank D ,w hich wasopened using anotherSSN ending 4312 thatthe SSA confirm ed
Case 0:20-mj-06328-PMH Document 1 Entered on FLSD Docket 08/06/2020 Page 9 of 12




   w asnotassigned to Accom plice 1,butthatwas one digitofffrom the false SSN also ending 4312

   used in the application.

           25.    V ideos of subsequent transactions involving A ccomplice l's Bank D account

   depicted LOU IS w ithdraw ing fundson oraboutJune 5,6,9,10,11,and 12,2020.Thevideo froln

   on orabotltJune 9,2020,also depicted a person lbelieveto be A ccom plice 1 with LOU IS.

           26.    Each ofthese videosfeatured oneoftw o vehiclesregistered to LOUIS in FLHSM V

   records.The firstvehicle w as a white A cura TLX bearing Florida license plate N VG-PIZ.On or

   aboutJune 9,July 28,and A ugust3,2020,agentsobserved this vehicle parked outside the North

   Lauderdale Residence.On oraboutA ugust3,2020,Iobserved am an m atching LOU IS'Sphysical

   description entering thisvehicle outside the North Lauderdale Residence,driving aw ay,and then

    returning in this vehicle to the North Lauderdale Residence.The second vehicle w as a lightblue

    HondaA ccord bearing Florida license plate L3FHX .2On oraboutJune9, 2020,and July 28,2020

    agentsobserved thissam e vehicle parked outside theN orth Lauderdale Residence.

       Loan3:LOUISRecordedConfrmingHisf#ca/f?y andAttemptingtoAccessProceeds
           27.    Recordsfrom Bank A showedan applicationfora$19,988PPP loan subm itted on
   or aboutJune 3,2020,for Victim 1's w holly-ow ned '%preparation doc''sole proprietorship.The

   Borrow er Application Form listed V ictim l's true nam e as the S'Business N am er''the North

    Lauderdale Residence as the ttBusiness Address.''and V ictim 1's true SSN ending 0358 as the

    ttBusinessTIN.''Theapplication also includedthe emailaccountvalue33068@gmail.com,one
    characterofffrom the em ailaddress Iisted in the Loan 2 application.The application included a

    supporting 2019 Fonm 1040,Schedule C,bearing V ictim 1's name.The application also included



    2FLHSM V records indicated thatthe vehicle w asblack,butsurveillance and video surveillance
    confirm ed thatthe vehicle,which had the sam e m ake and m odeland bore the sam e license plate
    aslisted in FLHSM V records,w as Iightblue.
                                                  8
Case 0:20-mj-06328-PMH Document 1 Entered on FLSD Docket 08/06/2020 Page 10 of 12




    a fraudulent supporting bank statement from Bank B virtually identical to the bank statem ent

    subm itted with the Loan 2 application,exceptthatthe bank statem entsubm itted w ith the Loan 3

    application purported to be foran accountheld by Victim 1.ThisfraudtllentBank B statem entalso

    had transactions,dates,and a m em bernum berthatm atched LO UIS'S Bank B accountrecords.

           28.    Victim l confirmed that Victim 1 had not submitted this application,had not

    authorized LO UIS to subm itthe application on V ictim 1's behalf,did notknow LOU IS,had no

    connection to the N orth Lauderdale Residence,and had notseen the fraudulentBank B statem ent

    orfiled the Form 1040,Schedule C docum entsubm itted with the application.

           29.    On oraboutJune 3,2020,Bank A deposited Loan 3 for$19,998 into LOUIS'S
    accountatBank E opened usingthe falseSSN ending 6488.Soon afterthedeposit,Bank E blocked

    w ithdraw alsfrom thisaccountdue to suspected fraud.asBank E had been the victim ofthe fraud

    forw hich LOUIS faced pending crim inalcharges in the Seventeenth JudicialCircuit in and for

    Brow ard County.Afterthis w ithdrawalfreeze,LOU IS called Bank E to requesthelp unfreezing

    the Loan 3 proceeds,which is when LO UIS confirm ed his identity by using his true SSN and

    providing histrue Florida driver'slicense in an attem ptataccountvalidation asdescribed above.

           30.    A dditionally,an electronic device or devices using the sam e IP address accessed

    both the Loan 3 application and the Bank E accountinto which Loan 3 w as deposited,asw ellas

    the Loan 2 application.Recordsfrom the internetservice providerassociated w ith this IP address

    show ed thatthesubscriberassigned thisIP addresswasA ccolnplice l,and thatthe service address

    w as the Delray Beach Residence.On August 2,2020,an agent surveilling the D elray Beach

    Residenceobserved both LO UIS and A ccom plice 1together,pulling into the drivew ay and exiting

    LOUIS'SA curaTLX bearing Florida license plateN VG -PIZ.
Case 0:20-mj-06328-PMH Document 1 Entered on FLSD Docket 08/06/2020 Page 11 of 12




                                             Conclusion

           31.    Based on m y training and experience, and the infonmation provided in this

    Affidavit,Irespectfully subm itthatthere isprobable cause to believethat:

           @      On oraboutJune 1,2020,in the Southern D istrictof Florida and elsew here,the
                  defendant,JU DLEX JEAN LOU IS,did know ingly, and w ith intent to defraud,
                  execute,and attemptto execute,and causetheexecution of,a schemeand artifqce
                  to defraud a Gnancialinstitution,which schem e and artifice em ployed a m aterial
                  falsehood,and did know ingly,and w ith intentto defraud,execute,and attem ptto
                  execute,and cause the execution of a schem e and artitsce to obtain m oneys and
                  funds owned by,and under the custody and controlof a fm ancialinstitution,by
                  m eansoffalse and fraudulentpretenses,representations,and prom isesrelating to a
                  materialfact,that is,by causing Bank A to deposit$20,833.00 into an account
                  controlled by the defendant,in violation ofTitle 18,United States Code,Section
                  1344 and 2.
           @      0n oraboutJune 1,2020,in the Southern D istrict of Florida and elsewhere,the
                  defendant,JUD LEX JEAN LO UIS, did know ingly m ake a false statem ent and
                  reportfor the purpose of intluencing the action of a financialinstitution w hose
                  deposits are insured by the FederalDeposit Insurance Corporation in connection
                  w ith a loan application,in thatthe defendant falsely represented that he w as not
                  subjecttoptnding criminalcharges,inviolation ofTitle18,United StatesCode,
                  Section 1014 and 2.
           *      On oraboutJune 3,2020,in the Southern D istrict ofFlorida and elsewhere,the
                  defendantsJUDLEX JEAN LO UIS,did know ingly,and w ith intent to defraud,
                  exectlte,and attem ptto execute,and cause the execution of,a schem e and artifice
                  to defraud a financialinstitution,which schem e and artifsce em ployed a m aterial
                  falsehood,and did knowingly,and w ith intentto defraud,execute,and attem ptto
                  execute,and cause the execution of a schem e and artifice to obtain m oneys and
                  funds owned by,and underthe custody and controlofa financialinstitution,by
                  m eansoffalse and fraudulentpretenses,representations,and prom isesrelating to a
                  material fact,that is,by causing Bank A to deposit $19,412 into an account
                  controlled by Accom plice 1,in violation ofTitle 18,United StatesCode,Sections
                  1344 and 2.

           *      O n oraboutJune 3,2020,in the Southern D istrictof Florida and elsew here,the
                  defendant,JUD LEX JEAN LO UIS, did know ingly,and w ith intent to defraud,
                  execute,andattemjttoexecute,andcausetheexecutionof,aschemeandartifice
                  to defraud a financlalinstitution,w hich schem e and artifice em ployed a m aterial
                  falsehood,and did know ingly,and w ith intentto defraud,execute,and attem ptto
                  execute,and cause the execution of a schem e and artifice to obtain m oneys and
                  funds owned by,and underthe custody and controlof a financial institution,by
                  meansoffalseand fraudulentpretenses,representations,andpromisesrelatingto a
                  m aterialfact,thatis,by causing Bank A to deposit$19,998.00 into an account
Case 0:20-mj-06328-PMH Document 1 Entered on FLSD Docket 08/06/2020 Page 12 of 12




                 controlled by the defendant.in violationofTitle 18,United StatesCode, Sections
                 I344 and 2.

          *      On oraboutJune 3.2020,in the Southem DistrictofFlorida and elsewhere. the
                 derendant.JUDLEX JEAN LOUIS,during and in relation to a felony violation of
                 Title 18.United StatesCode.Section 1344, thatis,knowingly,and with intentto
                 delh ud.executing.and attempting to execute.and causing the execution of, a
                 scheme and artilice to defraud a lsnancialinstittltion,which scheme and artifice
                 employed a material t-   alsehood, and knowingly- and with intent to defmud.
                 executing.and attempting to cxecute,and causing the execution of-a scheme and
                 artilice to obtain m oneys and tkndsowned by.and undtrthe custody and control
                 oih a isnancial institution, by means of false and lh udulent pretenses,
                 representations.and prom isesrelating toamaterialfact.thatis.bycausing Bank A
                 to deposit$19.988.00 into an accountcontrolled by thedelkndant. did knowingly
                 transfer.possess.and use.withoutIawlblauthority,the name and socialsecurity
                 numberending0358 issued toVictim 1.inviolationofTitle l8,UnitedStatesCode.
                 Sectionsl028A(a)(1)and2.



                                                     kemonàoindexter
                                                     United StatesSecretService.SpecialAgent


    Attestedto inaccordancewith therequirements
    ofFedi Crim.R 4.lby telephone
    this @    dayofAugust.2020.



    HON.PATRICK M . UN1*
    UNITED STATES M AGISTM TE JUDGE


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