Statement of Facts — United States v. Felicia Grace, No. 1:24-cr-00017 (Northern District of Florida)

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A Statement of Facts filed October 15, 2024 as Document 31 in United States v. Felicia Grace, Case No. 1:24-cr-00017-AW-MAL, in the U.S. District Court for the Northern District of Florida, Gainesville Division. The United States states that it provides the factual basis for acceptance of the guilty plea of Defendant Felicia Grace. It states that on or about December 28, 2020 the Defendant created an account with the California Employment Development Department (CA EDD) and that the application contained material false statements, including that the Defendant had worked in Fresno, California as a taxi driver. It states that the Defendant received $17,456 in CA EDD UI funds. It closes with the elements of the offense for Count One.

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Case 1:24-cr-00017-AW-MAL Document31_ Filed 10/15/24 Page1of3

IN THE UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF FLORIDA
GAINESVILLE DIVISION
UNITED STATES OF AMERICA
Vv. Case No: 1:24cr17-AW-MAL

FELICIA GRACE
/

STATEMENT OF FACTS

THE UNITED STATES OF AMERICA, by and through the undersigned
Assistant United States Attorney, provides this factual basis for the acceptance of
the guilty plea of Defendant Felicia Grace (“Defendant”). Should this case proceed
to trial, the government is prepared to present evidence as follows:

In or around March 2020, the Coronavirus Aid, Relief, and Economic
Security (CARES) Act was enacted. It was designed to provide emergency
financial assistance to the millions of Americans who were suffering from the
economic effects caused by the COVID-19 pandemic. During the period of time
including April of 2021, the California Employment Development Department
(“CA EDD”) Unemployment Insurance program was funded in part by the federal
CARES Act.

On or about December 28, 2020, the Defendant created and caused the

creation of an account with the CA EDD. As part of the application process, the

File fi Open Court
Clerk, U.S. District Court
Northern District of Florida
Case 1:24-cr-00017-AW-MAL Document 31 Filed 10/15/24 Page 2of3

Defendant underwent verification by a third party company, ID.me, which was
designed to verify the identity of applicants, and provided a phone number, date of
birth, photograph of herself, and a photograph of her driver’s license. Following
verification, the Defendant caused to be submitted an application in support of
unemployment insurance benefits through the CA EDD. The submission of the
Defendant’s unemployment insurance application was completed via the internet,
and as such the submission of this application constituted a wire communication
transmitted in interstate commerce.

The Defendant’s CA EDD unemployment insurance application contained
material false statements, including representations that the Defendant had worked
in Fresno, California as a taxi driver and was forced to stop working due to the
COVID-19 pandemic. In reality, and as the Defendant knew, the Defendant has
never lived or worked in the state of California, and was not entitled to
unemployment insurance benefits from the CA EDD. Through the false statements
contained in her application, the Defendant received $17,456 in CA EDD UI funds
to which she was not entitled.

ELEMENTS OF THE OFFENSE-COUNT ONE
(1)the Defendant knowingly devised or participated in a scheme to defraud, or

to obtain money or property by using false pretenses, representations, or

2
Case 1:24-cr-00017-AW-MAL Document 31 Filed 10/15/24 Page3of3

promises;
(2) the false pretenses, representations, or promises were about a material fact;
(3)the Defendant acted with the intent to defraud; and
(4)the Defendant transmitted or caused to be transmitted by wire some

communication in interstate commerce to help carry out the scheme to

defraud.

JASON R. COODY
United States Attorney

DARREN JOHNSON, ESQ. DAVID P. BYRON

Attorney for Defendant Florida Bar No. 0105777
Assistant United States Attorney
Northern District of Florida

jo/15 [aa 24 401 SE First Ave, Ste 211
Date Gainesville, Florida 32601
(352) 378-0996
David.byron@usdoj.gov
FELICIA GRACE (o/1s [2024
Defendant Date


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