Notice of Related and Similar Actions and Unopposed Motion to Transfer Case — United States v. De Leon

Summary

Notice of Related and Similar Actions and Unopposed Motion to Transfer Case, filed November 10, 2022, by the United States in the Southern District of Florida. It lists cases against Willian Alexander Posada Sandrea, Armando Ariel De Leon, and Daniel Hernandez, which it says stem from the same conspiracy and fraud scheme involving COVID-19 relief and Daniel Hernandez, a former regional manager at Bank 1. The United States moves, unopposed, to transfer the Hernandez case to Hon. Jose E. Martinez, and states that Hernandez's trial is scheduled for December 19, 2022. It is signed /s/ Eli S. Rubin, Assistant United States Attorney.

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“Notice of Related and Similar Actions and Unopposed Motion to Transfer Case — United States v. De Leon.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-s-d-fla-no-1-22-cr-20420-dkt-56-s-d-fla-a0d5fddd50/, SHA-256 a34aaaf1a455a4e12be2812b2ce1fb41c5f6ef18c24099cc305a1fba4bc883d7.

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Case 1:22-cr-20420-JEM Document 56 Entered on FLSD Docket 11/10/2022 Page 1 of 4

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO. 22-20194-CR-MARTINEZ

UNITED STATES OF AMERICA

WILLIAN ALEXANDER POSADA SANDREA,

Defendant.
__________________________________________/

CASE NO. 22-20420-CR-MARTINEZ

UNITED STATES OF AMERICA,

ARMANDO ARIEL DE LEON,

Defendant.
__________________________________________/

CASE NO. 22-20529-CR-MOORE

UNITED STATES OF AMERICA,

DANIEL HERNANDEZ,

Defendant.
__________________________________________/

NOTICE OF RELATED AND SIMILAR ACTIONS
AND UNOPPOSED MOTION TO TRANSFER CASE

The United States of America (the “United States”), pursuant to Local Rule 3.8 and the

Court’s Internal Operating Procedures, Section 2.15.00, hereby notifies the Court of the

following related and similar matters currently pending before the Court:

 United States v. Willian Alexander Posada Sandrea, 22-20194-CR-Martinez;
Case 1:22-cr-20420-JEM Document 56 Entered on FLSD Docket 11/10/2022 Page 2 of 4

 United States v. Armando Ariel De Leon, 22-20420-CR-Martinez; and

 United States v. Daniel Hernandez, 22-20529-CR-Moore (collectively, the

“Related and Similar Cases”).1

The Related and Similar Cases stem from the same conspiracy and fraud scheme

involving COVID-19 relief and Daniel Hernandez, a former regional manager at Bank 1.

Further, the United States moves unopposed to transfer United States v. Hernandez, 22-

20529-CR-Moore, to Hon. Jose E. Martinez, who currently presides over the other two Related

and Similar Cases: United States v. Willian Alexander Posada Sandrea, 22-20194-CR, and

United States v. Armando Ariel De Leon, 22-20420-CR. Defendant Daniel Hernandez does not

oppose or otherwise object to the transfer.

As the Information in United States v. Daniel Hernandez alleges, and the Factual Proffer

in United States v. Armando Ariel De Leon sets forth, Daniel Hernandez, Armando Ariel De

Leon, and others conspired to submit false and fraudulent COVID-19 relief loan applications at,

among other lenders, Bank 1, Hernandez and De Leon’s former employer. Hernandez and De

Leon worked closely in furtherance of the conspiracy: De Leon maintained a spreadsheet

cataloging each of the conspiracy’s fraudulent loans and received cash commissions on behalf of

himself and Hernandez.

Willian Alexander Posada Sandrea was a co-conspirator who conspired to submit over 20

false and fraudulent loan applications through Hernandez. He has pled guilty and is scheduled to

be sentenced before Hon. Jose E. Martinez on November 14, 2022. (22-20194-CR-Martinez,

Dkt. No. 52.)

1
There are two other related and similar actions pending before the Court: United States v.
Erich Javier Alfonso Barata, 22-20487-CR-Bloom, and United States v. Melean Socorro and
Castillo, 22-20458-CR-Gayles. Notice of the related nature of all the cases was filed on each

2
Case 1:22-cr-20420-JEM Document 56 Entered on FLSD Docket 11/10/2022 Page 3 of 4

De Leon has pled guilty and is scheduled to be sentenced before Hon. Jose E. Martinez

on December 28, 2022. (22-20420-CR-Martinez, Dkt. No. 52.)

Hernandez was arraigned on November 4, 2022. (22-20529-CR-Moore, Dkt. No. 16.)

His trial is scheduled for December 19, 2022. (22-20529-CR-Moore, Dkt. No. 17.)

In light of the fact that the defendants participated in the same conspiracy, the subject

matter of the Posada Sandrea and De Leon prosecutions forms “a material part of the subject

matter” of the Hernandez prosecution. SDFL Internal Operating Procedures 2.15.00. Keeping

the cases before two separate Judges “would appear to entail the unnecessary duplication of

judicial labor.” Id. Consequently, the United States, without objection from Defendant Daniel

Hernandez, moves to transfer 22-20529-CR-Moore to Hon. Jose E. Martinez.

Respectfully submitted,

JUAN ANTONIO GONZALEZ
UNITED STATES ATTORNEY

By: /s/ Eli S. Rubin
Eli S. Rubin
Assistant United States Attorney
Court ID No. A5503535
99 N.E. 4th Street
Miami, Florida 33132
(305) 961-9247
Email: Eli.Rubin@usdoj.gov

docket on October 12, 2022.

3
Case 1:22-cr-20420-JEM Document 56 Entered on FLSD Docket 11/10/2022 Page 4 of 4

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on November 10, 2022, I electronically filed the foregoing with
the Clerk of the Court using CM/ECF.

/s/ Eli S. Rubin
Eli S. Rubin

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