Declaration of Special Agent — United States v. Cassie Will-Darnall (Case 5:24-cr-00292-PCP, Document 44)

Summary

This is the declaration of Special Agent Jennifer C. Barnard of the Federal Bureau of Investigation, filed to support the application of the United States for a preliminary order of forfeiture against Cassie Will-Darnall. She states that Will-Darnall pleaded guilty to fraudulently obtaining two Paycheck Protection Program loans, $968,989 received on or about June 4, 2020, and $1,864,565 received on or about July 22, 2020, and that she traced the proceeds using the lowest intermediate balance rule. She states that $746,372.98 of a $971,504.21 check was directly traceable to the first count, and that the 6846 Account had a balance of $625,952.60 on or about May 31, 2023, all traceable to the two counts.

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“Declaration of Special Agent — United States v. Cassie Will-Darnall (Case 5:24-cr-00292-PCP, Document 44).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-cand-430212-44-0-9aea74aa43/, SHA-256 4a5b117211efd18d7321e6ea340de9fbe0ab2fabf8ce9c73fbfaf94682a2e755.

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Case 5:24-cr-00292-PCP Document 44 Filed 04/09/25 Page 1 of 8

1 PATRICK D. ROBBINS (CABN 152288)
Acting United States Attorney
2
MARTHA BOERSCH (CABN 126569)
3 Chief, Criminal Division

4 GALEN A. PHILLIPS (CABN 307644)
Assistant United States Attorney
5
450 Golden Gate Avenue, Box 36055
6 San Francisco, California 94102-3495
Telephone: (415) 436-7110
7 Email: Galen.Phillips@usdoj.gov

8 Attorneys for United States of America

9 UNITED STATES DISTRICT COURT

10 NORTHERN DISTRICT OF CALIFORNIA

11 SAN JOSE DIVISION

12
UNITED STATES OF AMERICA, ) CASE NO. CR-24-00292-PCP
13 )
Plaintiff, ) DECLARATION OF
14 ) SPECIAL AGENT BARNARD
v. )
15 )
CASSIE WILL-DARNALL, )
16 )
Defendant. )
17 )

18
19

BARNARD DECLARATION 1
CR-24-00292-PCP
Case 5:24-cr-00292-PCP Document 44 Filed 04/09/25 Page 2 of 8

1 I, Jennifer C. Barnard, declare and state as follows:

2 1. I am a Special Agent with the Federal Bureau of Investigation ("FBI"), a position I have

3 held since October 2007. I am a Certified Public Accountant and prior to my employment with the FBI,

4 worked as an accountant.

5 2. The facts set forth in this declaration are based on my personal knowledge and

6 information I received from other law enforcement personnel, or my review of documents and business

7 records related to this investigation. I make this declaration for the limited purpose of supporting the

8 application of the United States for a preliminary order of forfeiture. This declaration does not include

9 everything I know about the investigation.

10 3. As part of this investigation, the FBI obtained financial records for Cassie Will-Darnall

11 (“Will-Darnall”), entities associated with Will-Darnall, and Sandra Will (“Will”), including the

12 following accounts: a Bank of America account in Will’s name with an account number ending in 9108

13 (the “9108 Account”), a Wells Fargo account in the name of Rosswood LLC with an account number

14 ending in 7528 (the “7528 Account”), a Wells Fargo account in the name of Soda Springs LLC with an

15 account number ending in 4912 (the “4912 Account”), a Vanguard account held in the name of Will-

16 Darnall associated with an account number ending in 8205 (the “8205 Account”), and a Vanguard

17 account held in the name of Alternative Health Service Inc associated with an account number ending in

18 6846 (the “6846 Account”).
19 4. On or about February 2, 2018, Will obtained a cashier’s check in the amount of

20 $607,629.02 to be paid to the order of PLM Lender Services Inc. drawn on the 9108 Account. Of the

21 $607,629.02, a portion of the funds came from a loan that Will obtained from Bank of America in

22 January of 2018.

23 5. Per Wyoming Secretary of State records, Serenity Enterprises Family Limited

24 Partnership is a Limited Partnership affiliated with Will-Darnall.

25 6. A Limited Partnership Certificate of Limited Partnership filed with the Wyoming

26 Secretary of State on July 18, 2012, lists Will-Darnall as the general partner of Serenity Enterprises

27 Family Limited Partnership.

28 7. A 2019 Limited Partnership Annual Report filed with the Wyoming Secretary of State on

BARNARD DECLARATION 2
CR-24-00292-PCP
Case 5:24-cr-00292-PCP Document 44 Filed 04/09/25 Page 3 of 8

1 or about August 6, 2019, was signed in Will-Darnall’s name.

2 8. Based on a review of Will-Darnall’s bank records obtained during the course of the

3 investigation, there does not appear to be evidence that Will-Darnall received funds from Serenity

4 Enterprises Family Limited Partnership or Serenity Family Limited Partnership during the period of

5 interest.

6 9. Based on a review of Will-Darnall’s bank records obtained during the course of the

7 investigation, there does not appear to be evidence that Serenity Enterprises Family Limited Partnership

8 or Serenity Family Limited Partnership received funds from Will-Darnall during the period of interest.

9 10. I have reviewed records appearing to relate to Plato Global Ventures LLC, stating it is a

10 Nevis LLC affiliated with Will Darnall.

11 11. Based on a review of Will-Darnall’s bank records obtained during the course of the

12 investigation, there does not appear to be evidence that Will-Darnall received funds from Plato Global

13 Ventures LLC.

14 12. Based on a review of Will-Darnall’s bank records obtained during the course of the

15 investigation, there does not appear to be evidence that Plato Global Ventures LLC received funds from

16 Will-Darnall.

17 13. Will-Darnall fraudulently applied for two Economic Injury Disaster Loans (“EIDLs”) on

18 or about March 31 and April 11, 2020, respectively. Those EIDLs were declined.
19 14. Will-Darnall fraudulently applied for a Paycheck Protection Program (“PPP”) loan on or

20 about April 1, 2020, seeking a loan of $3,312,500. That loan was declined. Will-Darnall fraudulently

21 applied for a PPP loan on or about April 3, 2020, seeking a loan of $3,312,500, using the information

22 she submitted on April 1, 2020, with minor revisions. That loan was also declined.

23 15. Will-Darnall has pleaded guilty to fraudulently obtaining two PPP loans in the amounts

24 of $968,989 received on or about June 4, 2020 and $1,864,565 received on or about July 22, 2020, the

25 proceeds of which have been traced using the lowest intermediate balance rule (“LIBR”).

26 16. On or about June 9, 2020, Will-Darnall transferred $938,000 from the 7528 Account to

27 the 4912 Account. Using LIBR, the $938,000 transferred to the 4912 Account was composed entirely of

28 funds directly traceable to the first count to which Will-Darnall has pleaded guilty.

BARNARD DECLARATION 3
CR-24-00292-PCP
Case 5:24-cr-00292-PCP Document 44 Filed 04/09/25 Page 4 of 8

1 17. On or about June 15, 2020, Will-Darnall wrote a check to Will drawn on the 4912

2 Account in the amount of $971,504.21. Written in the memo line of the check was “111 Bel payoff”.

3 Using LIBR, $746,372.98 of the check amount was composed of funds directly traceable to the first

4 count to which Will-Darnall pleaded guilty.

5 18. The 971,504.21 check was deposited into Will’s 9108 Account. On or about June 22,

6 2020, a payment of $972,094.93 was made from the 9108 Account to a mortgage account in Will’s

7 name at Bank of America ending in 6661. Using LIBR, the $972,094.93 payment included the

8 $746,372.98 in funds directly traceable to the first count to which Will-Darnall pleaded guilty.

9 19. On or about November 10, 2020, Will-Darnall transferred $1,600,000 from the 7528

10 Account to the 8205 Account. On or about November 17, 2020, Will-Darnall transferred $230,000 from

11 the 7528 Account to the 8205 Account. Pursuant to LIBR, except for $54.15, all of the $1,830,000

12 included in these two transfers was directly traceable to the second count to which Will-Darnall pleaded

13 guilty.

14 20. On or about November 27, 2020, Will-Darnall transferred $100,000 from the 4912

15 Account to the 8205 Account. Pursuant to LIBR, all of the $100,000 included in this transfer was

16 directly traceable to the first count to which Will-Darnall pleaded guilty.

17 21. On or about February 2, 2021, Will-Darnall transferred $1,876,616.41 from the 8205

18 Account to the 6846 Account. Pursuant to LIBR, of the $1,876,616.41 transferred to the 6846 Account,
19 all of it constituted funds directly traceable to the two counts to which Will-Darnall pleaded guilty.

20 22. Between on or about February 2, 2021, and on or about May 31, 2023, funds were

21 withdrawn from the 6846 Account and transferred to the 4912 Account in increments ranging from

22 $3,000 to $400,000. Pursuant to LIBR, Will-Darnall transferred approximately $1,027,000 in fraud

23 proceeds from the 6846 Account to the 4912 Account. Will-Darnall dissipated some of those funds at

24 restaurants and transfers to a cryptocurrency exchange and through purchases of various things

25 including items from Amazon and airlines.

26 23. Pursuant to LIBR, Will-Darnall transferred approximately $489,000 in loan proceeds

27 from the 4912 Account back into the 6846 Account.

28 24. As of on or about May 31, 2023, the 6846 Account had a balance of $625,952.60.

BARNARD DECLARATION 4
CR-24-00292-PCP
Case 5:24-cr-00292-PCP Document 44 Filed 04/09/25 Page 5 of 8

1 25. Using LIBR, the entirety of the $625,952.60 in the 6846 Account on or about May 31,

2 2023, consisted of proceeds directly traceable to the two counts to which Will-Darnall has pleaded

3 guilty.

4 26. Attached hereto are true and correct copies, excluding Bates-stamp numbering and

5 redactions, when applicable, of records obtained during the course of the investigation or records pulled

6 from publicly available sources:

7 27. Attached hereto as Exhibit A is a true and correct copy of a promissory note dated

8 January 24, 2018.

9 28. Attached hereto as Exhibit B is a true and correct copy of a deed of trust dated January

10 24, 2018.

11 29. Attached hereto as Exhibit C is a true and correct copy of an affidavit dated January 24,

12 2018.

13 30. Attached hereto as Exhibit D is a true and correct copy of a real estate schedule dated

14 January 24, 2018.

15 31. Attached hereto as Exhibit E is a true and correct copy of a closing statement dated

16 January 23, 2018.

17 32. Attached hereto as Exhibit F is a true and correct copy of an outgoing wire form dated

18 January 29, 2018.
19 33. Attached hereto as Exhibit G is a true and correct copy of an account statement for the

20 9108 Account.

21 34. Attached hereto as Exhibit H is a true and correct copy of an image of a cashier’s check.

22 35. Attached hereto as Exhibit I is a true and correct copy of a promissory note dated

23 February 7, 2018.

24 36. Attached hereto as Exhibit J is a true and correct copy of a deed of trust dated February 7,

25 2018.

26 37. Attached hereto as Exhibit K is a true and correct copy of an interspousal transfer deed

27 dated June 10, 2016.

28 38. Attached hereto as Exhibit L is a true and correct copy of a deed of reconveyance dated

BARNARD DECLARATION 5
CR-24-00292-PCP
Case 5:24-cr-00292-PCP Document 44 Filed 04/09/25 Page 6 of 8

1 February 16, 2018.

2 39. Attached hereto as Exhibit M is a true and correct copy of a civil complaint dated

3 November 19, 2018.

4 40. Attached hereto as Exhibit N is a true and correct copy of an abstract of judgment dated

5 on or about June 8, 2022.

6 41. Attached hereto as Exhibit O is a true and correct copy of a deed of trust dated February

7 26, 2019.

8 42. Attached hereto as Exhibit P is a true and correct copy of a deed of trust dated July 26,

9 2016.

10 43. Attached hereto as Exhibit Q is a true and correct copy of a deed of trust dated June 27,

11 2019.

12 44. Attached hereto as Exhibit R is a true and correct copy of a line of credit agreement dated

13 July 21, 2016.

14 45. Attached hereto as Exhibit S is a true and correct copy of a deed of trust dated August 19,

15 2013.

16 46. Attached hereto as Exhibit T is a true and correct copy of a quitclaim deed dated August

17 14, 2019.

18 47. Attached hereto as Exhibit U is a true and correct copy of a deed of trust dated September

19 25, 2019.

20 48. Attached as hereto as Exhibit V is a true and correct copy of a borrower application form

21 dated May 20, 2020.

22 49. Attached hereto as Exhibit W is a true and correct copy of an account statement for the

23 7528 Account.

24 50. Attached hereto as Exhibit X is a true and correct copy of a business account application

25 for the 7528 Account.

26 51. Attached hereto as Exhibit Y is a true and correct copy of an account statement for the

27 4912 Account.

28 52. Attached hereto as Exhibit Z is a true and correct copy of a business account application

BARNARD DECLARATION 6
CR-24-00292-PCP
Case 5:24-cr-00292-PCP Document 44 Filed 04/09/25 Page 7 of 8

1 for the 4912 Account.

2 53. Attached hereto as Exhibit AA is a true and correct copy of a check image.

3 54. Attached hereto as Exhibit BB is a true and correct copy of an account statement for the

4 9108 Account.

5 55. Attached hereto as Exhibit CC is a true and correct copy of a quitclaim deed dated June

6 20, 2020.

7 56. Attached hereto as Exhibit DD is a true and correct copy of a promissory note dated

8 February 7, 2018.

9 57. Attached hereto as Exhibit EE is a true and correct copy of an account statement for a

10 home loan account in the name of Sandra Will and affiliated with an account number ending in 6661.

11 58. Attached hereto as Exhibit FF is a true and correct copy of a borrower application form

12 dated July 12, 2020.

13 59. Attached hereto as Exhibit GG is a true and correct copy of a lender’s transcript of

14 account dated July 21, 2020.

15 60. Attached hereto as Exhibit HH is a true and correct copy of an account statement for the

16 7528 Account.

17 61. Attached hereto as Exhibit II is a true and correct copy of an account application for the

18 8205 Account.
19 62. Attached hereto as Exhibit JJ is a true and correct copy of an account statement for the

20 8205 Account.

21 63. Attached hereto as Exhibit KK is a true and correct copy of an account statement for the

22 6846 Account.

23 64. Attached hereto as Exhibit LL is a true and correct copy of an account application for the

24 6846 Account.

25 ///

27 ///

BARNARD DECLARATION 7
CR-24-00292-PCP
Case 5:24-cr-00292-PCP Document 44 Filed 04/09/25 Page 8 of 8

1 65. Attached hereto as Exhibit PP is a true and correct copy of a certificate of incumbency

2 and resignation of organization rights.

4 I swear under penalty of perjury that the foregoing is true and correct.

5
Executed on: April 9, 2025 /s/
6 JENNIFER C. BARNARD
Special Agent
7 Federal Bureau of Investigation
8

18
19

BARNARD DECLARATION 8
CR-24-00292-PCP

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