Stipulated Factual Basis — United States v. Conrad Brandon Bernard (S.D. Fla., Dkt. 37)

Summary

Stipulated Factual Basis in United States of America v. Conrad Brandon Bernard, Case No. 24-60168-CR-DIMITROULEAS/HUNT, in the U.S. District Court for the Southern District of Florida, entered 11/15/2024 as Document 37. The United States and the Defendant agree that, had the case proceeded to trial, the United States would have proven the facts described, which meet the elements of the offenses charged in the Superseding Information. The stipulation states that beginning as early as in or around May 2020 the Defendant engaged in a scheme to defraud Wells Fargo Bank NA and TD Bank, N.A. by using the name and personal identification information of other individuals without their knowledge or consent. It states that the Defendant fraudulently applied for fourteen (14) separate EIDLs and fraudulently obtained $1,083,340 in EIDL funds and unemployment benefits.

Summary drafted by a model from the document's text below 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

Full text

Case 0:24-cr-60168-WPD Document 37 Entered on FLSD Docket 11/15/2024 Page 1 of 6




                            UNITED STATES DISTRICT COURT
                            SOUTHERN DISTRICT OF FLORIDA

                        CASE NO.   24-60168-CR-DIMITROULEAS/HUNT

     UNITED STATES OF AMERICA

           Plaintiff,
     vs.

     CONRAD BRANDON BERNARD,

·\        Defendant.
     _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _!

                              STIPULATED FACTUAL BASIS

           The United States of America and CONRAD BRANDON BERNARD

     ("Defendant") agree that, had this case proceeded to trial, the United States would

     have proven the facts described below, among others, beyond a r~asonable doubt, and

     that the described facts are true and correct and meet the elements of the offenses

     .charged in the Superseding Information.

                         COVID-19 Economic Injury Disaster Loans

           One of the government's responses to the COVID-19 outbreak was an

     expansion of an existing disaster-related program-the Economic Injury Disaster

     Loan (EIDL)-to provide for loan assistance for small businesses and other eligible

     entities for loans. Intially, the loans were capped at $150,000.   EIDL funds were

     issued directly from the United States Treasury, and applicants applied through the

     SBA via an online portal and application. To obtain an EIDL and advance, a

     qualifying business was required to submit an application to the ,Small Business
                                          Page 1 of 6
Case 0:24-cr-60168-WPD Document 37 Entered on FLSD Docket 11/15/2024 Page 2 of 6




    Administration (SBA) and provide information about its identity and operations.

    Applicants electronically certified that the information provided was accurate a.nd '

    were warned that any false statement or misrepresentation to the SBA or any

    misapplication of lo an proceeds may result in sanctions, including criminal penalties.

    Applicants also completed loan agreements with the SBA to receive the EIDL funds.

                                Unemployment Insurance

          The U.S. Department of Labor's unemployment insurance programs provide

    unemployment benefits to eligible workers who become unemployed through no fault
                                                                         )

    of their own and meet certain other eligibility requirements.            Unemployment

    insurance is a joint _state-federal program that provides cash benefits to eligible

    workers. Each state administers a separate unemployment insurance program, but

    all states follow the same guidelines established by federal law.

          To receive unemployment insurance benefits, an individual generally files a

    claim with the unemployment insurance program in the state where that individual

    worked. When a claim is filed, an applicant will be asked for certain information

    including the applicant's personal identification information, such as name, date of

    birth, and social security number.

                                   Bank Fraud Scheme

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

    about December 2022, the Defendant, Conrad Brandon BERNARD (BERNARD)

    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
                                          Page 2 of 6
      Case 0:24-cr-60168-WPD Document 37 Entered on FLSD Docket 11/15/2024 Page 3 of 6
,,.
•



          identification information (PII) of other individuals without their knowledge or

          consent to create accounts at Wells Fargo and TD Bank and then fraudulently

          impersonate those individuals for the purpose of transferring or withdrawing funds

          owned by or under the custody or control of Wells Fargo ans! TD Bank.

                BERNARD accomplished this scheme by fraudulently applying for fourteen

          (14) separate EIDLs using the name and PII of other individuals without their

          know ledge or consent. Once the SBA approved the fraudulent applications, the SBA

          transferred the EIDL funq.s to various Wells Fargo bank accounts at BERNARD's

          direction. BERNARD opened and operated these Wells Fargo accounts with the

          name and PII of other individuals without those individuals' knowledge or consent.

          BERNARD then transferred those funds from the Wells Fargo bank accounts to other

          accounts under his control including various Robinhood accounts he created using the

          name and PII of other individuals without their knowledge or consent.        In one

          instance, on July 28, 2020, BERNARD transferred $50,000 ofEIDL funds from Wells

          Fargo Account ending in 4245, which BERNARD opened and operated using the

          name and identity ofR.B. without R.B.'s knowledge or consent to a Robinhood account

          ending in 9379, which was opened using the name and PII of B.P. without B.P.'s

          knowledge or consent.

                BERNARD also accomplished his scheme by transferring or withdrawing

          fraudulently obtained unemployment benefit funds from Wells Fargo accounts he :

          opened and operated using the name and PII of other individuals without their

          knowledge or consent. These unemployment benefits were paid from several states
                                               Page 3 of 6
    Case 0:24-cr-60168-WPD Document 37 Entered on FLSD Docket 11/15/2024 Page 4 of 6

i



                                              ,
        including West Virginia and Arizona. The unemployment benefit funds were

        fraudulently obtained because the name and PII of other individuals were used to

        apply for the unemployment benefits without those individuals' knowledge or

        consent.

              In all, BERNARD fraudulently obtained $1,083,340 in EIDL funds and

        unemployment benefits and transferred and/or withdrew those criminally derived

        proceeds to and/or from Wells Fargo accounts ending in 5375, 4245, 5268, 3481, 2318,

        9488, 9990, 2894, 4172, 7265, 6550, 3644, 0406, 1824, 6920, and 9545, which

        BERNARD opened and operated using the name and PII of other individuals without

        their knowledge or consent. From there, BERNARD 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, which BERNARD opened and

        operatep. using the name and PII of other individuals without their knowledge or

        consent.

                     Traffic Stop, Vehicle Search, and Search Warrants

              On 05/13/2022, law enforcement conducted a lawful traffic stop of BERNARD·

        and search of BERNARD's vehicle. In BERNARD's vehicle, BCSO officers found two

        TD Bank debit cards in the name of D.E. and U.S, which were opened and used by

        BERNARD without the knowledge or consent of D.E. and U.S.           Specifically, TD

        Bank debit card ending in 9603, which was in the name of U.S., was able to withdraw

        funds from a TD Bank account ending in 9833, which also was in the name of U.S.
                                             Page 4 of 6
Case 0:24-cr-60168-WPD Document 37 Entered on FLSD Docket 11/15/2024 Page 5 of 6




    and opened without U.S.' knowledge or consent. BERNARD defrauded TD Bank by

    impersonating U.S. when using TD Bank debit card ending in 9603 to withdraw

    $1,003.00 from TD Bank account ending in 9833 on July 5, 2022.

           During the vehicle search, law enforcement found numerous items including

    several laptops and iPhon~s, a Zebra ZXP Series 7 printer with approximately 16

    blank cards contained within a partially closed black bag, an HP Envy 4520

    scanner/printer with a counterfeit U.S. Passport Card in the scanner bed of the HP

    Envy 4520.

           Later that day, law enforcement obtained a lawful search warrant to search a

    Broward County residence that BERNARD leased.             During that search, law

    enforcement found numerous items including, but not limited to:

       •   2 Counterfeit U.S. Passport Cards;

       •   2 Social Security Cards in the names of other individuals;

       •   43 Florida Identification Cards or Driver's Licenses containing a photograph
                                                 '
           of a black male with various identities;

       •   33 Florida Identification Cards or Driver's Licenses containing a photograph

           of a second black male with various identities;

       •   29 Humana Insurance cards in the name of different individuals;

       •   31 W-2s in different identities;

       •   501 blank cards;

       •   1 Blue HP Laptop; and

       •   1 Rose Gold Apple iPhone (SIN: unknown).
                                          Page 5 of 6
Case 0:24-cr-60168-WPD Document 37 Entered on FLSD Docket 11/15/2024 Page 6 of 6




            Law enforcementlaterobtainedsearch warrants to search the electronic items

    seized from BERNARD's vehicle and leased residence.         The search showed that

    these devices contained the PII of several thousand separate individuals, including

    their name, date of birth, social security number, and bank account numbers. Many

   • of these individuals resided outside the State of Florida, and several of their names

    and PII were used to obtain the aforementioned EIDLs and unemployment benefits.

            Wells Fargo Bank and TD Bank are financial institutions with deposits

    insured by the Federal Deposit Insurance Corporation.

                                            MARKENzy LAPOINTE
                                            UNITED STATES ATTORNEY


    Date:




    Date:                            By:        C/12---
                                            CHAD PIOTROWSKI   '? ~ ~ a 7-
                                            ATTORNEY FOR DEFENDANT


    Date:                            By:
                                            CONRAD BRANDON BERNARD
                                            DEFENDANT




                                           Page 6 of 6


File and source

File

37-major-prep-tsv-rank-79.pdf

Size

94,819 bytes

SHA-256

47dcd5b276f78e98d2f8ae700808045617542c1a186475225859477f862c783a

Our copy

37-major-prep-tsv-rank-79.pdf

Original

PACER (login required)