Criminal Complaint — U.S. v. Darrick Wynell Brazier, No. 2:25-cr-00565 (C.D. Cal.)

Summary

A Criminal Complaint filed June 23, 2025 as Document 1 in United States of America v. Darrick Wynell Brazier, Case 2:25-cr-00565, in the U.S. District Court for the Central District of California, listing 18 U.S.C. § 1341 (Mail Fraud) and attaching an affidavit of Special Agent Moustafa Spector of IRS-CI. The affidavit describes the Credit for Paid Sick and Family Leave Wages and states a belief that Brazier filed seven fraudulent Forms 941 for DWB Holdings LLC claiming refunds of over $1 million; the complaint addresses one of them. That Form 941, filed September 20, 2022, requested a refund of $344,309. The affidavit states that the IRS issued a refund of $332,578 on or about October 18, 2022, in a Treasury check that was mailed, and it is sworn before Magistrate Judge Pedro V. Castillo.

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“Criminal Complaint — U.S. v. Darrick Wynell Brazier, No. 2:25-cr-00565 (C.D. Cal.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-2-25-cr-00565-dkt-1-c-d-cal-bad06ea458/, SHA-256 93b47553e037fb79c6b9e783051e0e084d456a29fe6e814fffb009d1d1f6ce45.

Full text

Case 2:25-cr-00565-MWF Document 1 Filed 06/23/25 Page 1 of 8 Page ID #:1
AO 91 (Rev. 11/11) Criminal Complaint (Rev. by USAO on 3/12/20) ‫ ܆‬Original ‫ ܆‬Duplicate Original

LODGED
CLERK, U.S. DISTRICT COURT UNITED STATES DISTRICT COURT
6/23/2025 for the
CENTRAL DISTRICT OF CALIFORNIA
MMC
BY: ____________BB______ DEPUTY Central District of California 6/23/25
UNITED STATES OF AMERICA,
Plaintiff
v.
Case No. 2:25-MJ-03804-DUTY
DARRICK WYNELL BRAZIER,

Defendant

CRIMINAL COMPLAINT BY TELEPHONE
OR OTHER RELIABLE ELECTRONIC MEANS
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.

On or about the date of September 20, 2022, in the county of Los Angeles in the Central District of California,

the defendant violated:

Code Section Offense Description

18 U.S.C. § 1341 Mail Fraud

This criminal complaint is based on these facts:

Please see attached affidavit.

_ Continued on the attached sheet.

/s/
Complainant’s signature

MOUSTAFA SPECTOR, Special Agent
Printed name and title
Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephone.

Date: +VOF
Judge’s signature

City and state: Los Angeles, California Hon. Pedro V. Castillo, U.S. Magistrate Judge
Printed name and title

AUSA: Robert K. Quealy (213) 894-6874
Case 2:25-cr-00565-MWF Document 1 Filed 06/23/25 Page 2 of 8 Page ID #:2

AFFIDAVIT

I, Moustafa Spector, being duly sworn, declare and state as

follows:

I. INTRODUCTION

1. I am a Special Agent (“SA”) with the Internal Revenue

Service Criminal Investigation (“IRS-CI”), and have been so

employed since February 2022. I graduated from the Criminal

Investigator Training Program (CITP) at the Federal Law

Enforcement Training Center (FLETC), Glynco, Georgia in July

2022. During CITP, I was trained in surveillance techniques,

undercover techniques, search and seizure techniques,

Constitutional Law, interviewing, and other criminal

investigative techniques. I graduated from the Special Agent

Investigative Techniques (SAIT) program at the IRS National

Criminal Investigative Training Academy (NCITA), Glynco, Georgia

in November 2022. During SAIT, I was trained in accounting and

financial investigative techniques, including direct and

indirect methods of proof, criminal tax violations and other

related financial crimes. I have been instructed in

investigative techniques used by IRS-CI to investigate criminal

violations of the Internal Revenue Code and other financial

crimes enumerated in Titles 18, 26, and 31 of the United States

Code (U.S.C.).

2. Before becoming a Special Agent, I was an auditor-

appraiser with the County of Santa Barbara for approximately

nine years. As an auditor-appraiser, I performed examinations of

businesses records to assess real and business personal property
Case 2:25-cr-00565-MWF Document 1 Filed 06/23/25 Page 3 of 8 Page ID #:3

valuation for taxation. I received a Bachelor of Science in

Business Economics from University of California, Santa Barbara

in 2010.

II. PURPOSE OF AFFIDAVIT

3. This affidavit is made in support of a criminal

complaint against, and request for issuance of an arrest warrant

for, DARRICK WYNELL BRAZIER (“BRAZIER”) for a violation of 18

U.S.C. § 1341 (Mail Fraud).

4. The facts set forth in this affidavit are based upon

my personal observations, my training and experience, and

information obtained from various law enforcement personnel and

witnesses. This affidavit is intended to show merely that there

is sufficient probable cause for the requested complaint and

warrant and does not purport to set forth all of my knowledge of

or investigation into this matter. Unless specifically

indicated otherwise, all conversations and statements described

in this affidavit are related in substance and in part only.

5. Unless stated otherwise, all conversations and

statements described in this affidavit are related in substance

and/or in part only; all dates are “on or about” or

approximations; all amounts are rounded or close approximations;

and the words “on or about” and “approximately” are omitted for

clarity.

III. STATEMENT OF PROBABLE CAUSE

A. Tax Credit for Paid Sick and Family Leave Wages

6. In 2020, Congress enacted the Credit for Paid Sick and

Family Leave Wages (“Credit for Sick Leave”) through the
Case 2:25-cr-00565-MWF Document 1 Filed 06/23/25 Page 4 of 8 Page ID #:4

Families First Coronavirus Response Act, Pub. L. No. 116-127,

134 Stat. 177 (2020). Congress extended the applicable tax

periods for the Credit for Sick Leave in subsequent legislation.

7. The Credit for Sick Leave is available to employers

who paid employees for sick leave and/or family leave taken as a

result of the COVID-19 pandemic. The credit is limited to

qualifying wages paid for the second quarter of 2020 through the

third quarter of 2021.

8. The Credit for Sick Leave is a fully refundable credit

against an employer’s federal employment taxes. As a fully

refundable credit, an employer may claim a refund of any portion

of the credit in excess of their employment tax liability.

9. The Credit for Sick Leave may be claimed on Form 941,

Employer’s Quarterly Federal Tax Return. A Form 941 is a

quarterly tax return used by an employer to report quarterly

wages paid to employees, as well as the employer’s employment

tax liabilities. A Form 941 is signed under penalty of perjury

by an individual on behalf of the employer and, if applicable,

by a paid preparer. To file a Form 941, an employer must obtain

an Employer Identification Number (“EIN”). An EIN is obtained

by filing Form SS-4, Application for Employer Identification

Number, on behalf of the entity. The applicant must name a

responsible party on the Form SS-4, which can be either an

individual or another entity.

B. BRAZIER Files Returns Claiming Fraudulent Refund

10. Based on my review of IRS, public, and financial

records, I believe BRAZIER filed seven fraudulent Forms 941 on
Case 2:25-cr-00565-MWF Document 1 Filed 06/23/25 Page 5 of 8 Page ID #:5

behalf of DWB Holdings LLC (“DWB”) claiming fraudulent refunds

of over $1 million of the Credit for Sick Leave. The filed

Forms 941 claimed the credit on behalf of employees that appear

to not exist and for wages that were never paid. This complaint

addresses only one of the fraudulently filed Forms 941, as more

fully described below.

11. Open source/public records of the California Secretary

of State show that DWB was incorporated on May 3, 2016, and that

BRAZIER has continuously been identified on such records as

DWB’s registered agent for service of process. DWB’s most

recent corporate Statement of Information, filed July 7, 2021,

identified BRAZIER as DWB’s “managing member.” DBW’s only other

corporate Statement of Information also identified BRAZIER as

DBW’s managing member.1 A review of IRS records shows DWB was

issued employer identification number 81-2608120, and that DWB

filed its first income tax return in 2017 for tax year 2016 on

Form 1120-S, U.S. Income Tax Return for an S Corporation.

12. My review of IRS records also shows that DWB filed

five Form 1120-S income tax returns, for tax years 2016 through

2020. I reviewed the five tax returns and found that DWB never

reported expenses for compensation to officers or salaries and

wages to employees, consistent with the company never having

employees.

13. I further learned from IRS records that on September

20, 2022, a Form 941 for DWB was filed for the third quarter of

DWB’s 2018 corporate Statement of Information also
1
identified L.S. as a managing member. L.S. is also a target of
this investigation.
Case 2:25-cr-00565-MWF Document 1 Filed 06/23/25 Page 6 of 8 Page ID #:6

2020 requesting a refund of the Credit for Sick Leave of

$344,309 (hereinafter the “2020/09 Form 941”) I reviewed the

2020/09 Form 941, which reported that DWB paid compensation of

$202,246 to twenty (20) employees. An individual identifying

himself as “Darrick Brazier” signed the Form 941 as the owner of

DWB.

14. From a review of IRS records, I also know the

following:

a. Prior to the submission of the 2020/09 Form 941,

there were no records of Forms W-2 filed for DWB or Forms W-2

reported by DWB employees on Forms 1040 for any tax year. 2

b. Prior to the submission of the 2020/09 Form 941,

there were no Federal Tax Deposits 3 made for tax years 2020,

2021, or any earlier tax year on behalf of DWB.

c. Prior to the submission of the 2020/09 Form 941,

there were no records of Forms 941 filed by DWB other than three

2 I know from my training and experience that every employer
engaged in a trade or business who pays remuneration, including
noncash payments of $600 or more for the year (all amounts if
any income, social security, or Medicare tax was withheld) for
services performed by an employee must file a Form W-2 for each
employee (even if the employee is related to the employer) from
whom: (1) Income, Social Security, or Medicare tax was withheld;
or (2) Income tax would have been withheld if the employee had
claimed no more than one withholding allowance or had not
claimed exemption from withholding on Form W-4, Employee's
Withholding Allowance Certificate.
Federal Tax Deposits are funds sent to the IRS by an
3
employer and are comprised of two categories; (1) the Social
Security Taxes, Medicare Taxes, and Income Taxes that employers
withhold from employee paychecks, and (2) the employer’s portion
of Social Security Taxes, Medicare Taxes, and Federal
Unemployment Taxes.
Case 2:25-cr-00565-MWF Document 1 Filed 06/23/25 Page 7 of 8 Page ID #:7

Forms 941 filed on July 22, 2022, which also claimed refunds of

the Credit for Sick Leave.

15. Based on the absence of prior tax filings, including

Forms W-2 and Forms 941, as well as no history of federal tax

deposits, I believe that the claim on the 2020/09 Form 941 that

DWB had employees during the relevant period and paid employee

wages was false.

C. Use of the Mail to Facilitate the Fraud

16. IRS records show that, in reliance on the false

statements in the 2020/09 Form 941, the IRS issued a refund to

DWB in the amount of $332,578 on or about October 18, 2022. The

refund was issued in the form of a Treasury check payable to DWB

and mailed to an address in Los Angeles, California (the “Los

Angeles” address). I know from review of California Department

of Motor Vehicle (“DMV”) records, the Los Angeles address is

listed on BRAZIER’s driver’s license. A review of public

records shows the house is owned by L.S.

17. I know from my training and experience that U.S.

Treasury checks are only mailed using the United States Postal

Service.

D. BRAZIER Obtains Benefit of Fraudulent Refund

18. I reviewed subpoenaed records of Bank of America

account ending in 7338 (“BOA 7338”) and learned the following:

a. The IRS refund check for $332,578 that was issued

based on the above-described fraudulent 2020/09 Form 941 was

deposited into BOA 7338 on October 24, 2022.
Case 2:25-cr-00565-MWF Document 1 Filed 06/23/25 Page 8 of 8 Page ID #:8

b. BOA 7338 was opened in the name of DWB on March

14, 2017.

c. The customer’s signature on the signature/account

opening card for BOA 7338 matches that of BRAZIER’s California

driver’s license. The signature card also identified BRAZIER as

the sole signatory for the account and further included his

driver’s license number and last four digits of his SSN.

IV. CONCLUSION

19. For all the reasons described above, there is probable

cause to believe that BRAZIER has committed a violation of 18

U.S.C. § 1341 (Mail Fraud).

/s/
Moustafa Spector, Special Agent
IRS Criminal Investigations

Subscribed to and sworn before
me this SE day of June, 2025.

HONORABLE PEDRO V. CASTILLO
UNITED STATES MAGISTRATE JUDGE

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