Indictment — United States v. Heidi Cid et al., Southern District of Florida (Document 1)
Summary
A grand jury Indictment against Heidi Cid, Lazaro Verdecia Hernandez and Yadier Rodriguez Arteaga, Case No. 23-20421-CR-SCOLA/GOODMAN, in the U.S. District Court for the Southern District of Florida, entered on the docket October 26, 2023 as Document 1. Count 1 charges conspiracy to commit wire fraud under 18 U.S.C. § 1349, and Counts 2-14 charge wire fraud under 18 U.S.C. § 1343. It alleges the defendants submitted false PPP loan applications at Lenders 1 and 2 on behalf of entities including Mi Casa, Your Home, LLC, LVH MA Group Inc, Trueba Body Shop Corp and L&G Ready Mix LLC, misstating employees and payroll with false tax records and bank statements. The penalty sheets also list conspiracy to commit money laundering under Section 1956(h) and money laundering under Section 1957(a).
Summary drafted by a model from the text of the original file linked on this page 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
Cite this document
“Indictment — United States v. Heidi Cid et al., Southern District of Florida (Document 1).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-1-23-cr-20421-dkt-1-s-d-fla-82a2172ef9/
, SHA-256 000a7bddffce2a52e87d789d40e7e40144659754075c9942b10f376a517ef4be.Full text
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 1 of 27
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
23-20421-CR-SCOLA/GOODMAN
CASE NO. ------------
18 u.s.c. § 1349
18 u.s.c. § 1343 KAN
18 U.S.C. § 1956(h)
18 U.S.C. § 1957(a) Oct 25, 2023
18 u.s.c. § 2
18 U.S.C. § 982(a)(l)
18 U.S.C. § 982(a)(2)(A) Miami
UNITED STATES OF AMERICA
vs.
HEIDI CID,
LAZARO VERDECIA HERNANDEZ, and
YADIER RODRIGUEZ ARTEAGA,
Defendants.
---------------
INDICTMENT
The Grand Jury charges that:
GENERAL ALLEGATIONS
At various times relevant to this Indictment:
The Paycheck Protection Program
1. The Coronavirus, Aid, Relief, and Economic Security ("CARES") Act is a federal
law enacted in or around March 2020 designed to provide emergency financial assistance to the
millions of Americans who were suffering the economic effects caused by the COVID-19
pandemic. One source of relief provided by the CARES Act was the Paycheck Protection Program
("PPP"), the authorization of up to $349 billion in forgivable loans to small businesses for job
retention and certain other expenses.
2. In order to obtain a PPP loan, a qualifying business had to be in operation on or
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 2 of 27
before February 15, 2020, and had to submit a PPP loan application. The loan application required
the signature of an authorized representative and the business, through its authorized
representative, to acknowledge the program rules and make certain affirmative certifications in
order to be eligible to obtain the PPP loan. In the PPP loan application, the business had to include,
among other things, its average monthly payroll expenses and number of employees. These figures
were used to calculate the amount of money the business was eligible to receive under the PPP. In
support of the application, the businesses were required to provide documentation to the lending
institution in order to show that they qualified for the loan. Typically, businesses would supply
documents showing the amount of payroll taxes reported to the Internal Revenue Service ("IRS")
along with their monthly bank statements. The banks required these records to show that the
company was in existence prior to the enactment of the CARES Act and that the company had
payroll expenses justifying the amount of PPP loan funds requested by the company.
3. A PPP loan application was processed by a participating lender. If a PPP loan
application was approved, the participating lender funded the PPP loan using its own monies.
While it was the participating lender that issued the PPP loan, the loan was 100% guaranteed by
the Small Business Administration ("SBA"). Data from the application, including information
about the borrower, the total amount of the loan, and the listed number of employees, was
transmitted by the lender to the SBA in the course of processing the loan.
4. PPP loan proceeds were required to be used by the business on certain permissible
expenses-payroll costs, interest on mortgages, rent, and utilities. The PPP allowed the interest and
principal on the PPP loan to be entirely forgiven if the business spent the loan proceeds on these
expense items within a designated period of time and used a defined portion of the PPP loan
2
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 3 of 27
proceeds on payroll expenses.
The Financial Institutions
5. Lender 1 was a financial institution based in Salt Lake City, Utah, that was insured
by the Federal Deposit Insurance Corporation ("FDIC"). Lender 1 was an approved SBA lender
of PPP loans.
6. Lender 2 was a financial institution based in Fort Lee, New Jersey, that was insured
by the Federal Deposit Insurance Corporation ("FDIC"). Lender 2 was an approved SBA lender
of PPP loans.
7. Bank 1 was a financial institution based in Charlotte, North Carolina, that was
insured by the FDIC.
8. Bank 2 was a financial institution based in Charlotte, North Carolina, that was
insured by the FDIC.
9. Bank 3 was a financial institution based in Cherry Hill, New Jersey, that was
insured by the FDIC.
10. Bank 4 was a financial institution based in New York, New York that was insured
by the FDIC.
11. Bank 5 was a financial institution based in San Francisco, California, that was
insured by the FDIC.
12. Bank 6 was a financial institution based in Melbourne, Florida, that was insured by
the FDIC.
3
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 4 of 27
The Defendants and Related Entities
13. Mi Casa, Your Home, LLC was a Florida corporation with its listed principal
address in Hialeah, Florida. From on or about June 16, 2016, through on or about January 29,
2020, defendant HEIDI CID, a resident of Miami-Dade County, was the registered agent and sole
officer of the corporation.
14. On or about January 29, 2020, Co-Conspirator 1, a resident of Miami-Dade County,
became the registered agent and sole officer of Mi Casa, Your Home, LLC.
15. LVH MA Group, Inc was a Florida corporation with its listed principal address in
Hialeah, Florida. From on or about February 13, 2019, through on or about December 23 , 2019,
defendant LAZARO VERDECIA HERNANDEZ, a resident of Miami-Dade County, was the
registered agent and sole officer of the corporation.
16. On or about December 23 , 2019, Co-Conspirator 2, a resident of Miami-Dade
County, became the registered agent and sole officer of LVH MA Group, Inc.
17. Yadier Rodriguez Arteaga Corp was a Florida corporation with its listed principal
address in Hialeah Gardens, Florida. From on or about May 17, 2018, through on or about May
21 , 2020, defendant YADIER RODRIGUEZ ARTEAGA, a resident of Miami-Dade County,
was the registered agent and sole officer of the corporation.
18. On or about May 23 , 2020, Co-Conspirator 3, a resident of Miami-Dade County,
became the registered agent and sole officer of Yadier Rodriguez Arteaga Corp.
19. Trueba Body Shop Corp was a Florida corporation with its listed principal address
in Hialeah Gardens, Florida. Jorge Trueba Lopez, a resident of Miami-Dade County, was the
registered agent and sole officer of the corporation.
4
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 5 of 27
20. El Sol Party Rental Corp was a Florida corporation with its listed principal address
in Miami, Florida. Roberto Lopez, a resident of Miami-Dade County, was the registered agent
and sole officer of the corporation.
21. Business Enterprises USA, Inc. was a Florida corporation with its listed principal
address in Miami, Florida. Oreste Ruiz Linares, a resident of Miami-Dade County, was the
registered agent and sole officer of the corporation.
22. Corporation 1 was a Florida corporation with its listed principal address in West
Palm Beach, Florida. Co-Conspirator 4, a resident of Palm Beach County, was an officer of the
corporation.
23. Saavedra A/C Repairs Corp was a Florida corporation registered on or about
February 21 , 2020, with its listed principal address in Miami, Florida. Nancy Saavedra Torres, a
resident of Miami-Dade County, was the registered agent and sole officer of the corporation.
24. Akira Parfums Corp was a Florida corporation with its listed principal address in
Miami, Florida. Barbara Alvarez, a resident of Miami-Dade County, was the registered agent and
sole officer of the corporation.
25 . Cabinet Installations & Sales Corp was a Florida corporation with its listed
principal address in Miami, Florida. Kenia Carrillo, a resident of Miami-Dade County, was the
registered agent and sole officer of the corporation.
26. Global Towing and Repair Corp was a Florida corporation with its listed principal
address in Miami, Florida. Alfredo Contrera, a resident of Miami-Dade County, was the registered
agent and sole officer of the corporation.
5
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 6 of 27
27. L&G Ready Mix LLC was a Texas corporation with its listed principal address
located in Houston, Texas. Leonardo Gonzalez Lopez, a resident of Houston, Texas, was the
registered agent and sole officer of the corporation.
28. Professional Skills, Inc. was a Florida corporation with its listed principal address
in Miami, Florida. Giraldo Caraballo, a resident of Miami-Dade County, was the registered agent
and sole officer of the corporation.
29. Honolio Navarro Concrete Inc was a Florida corporation with its listed principal
address in Miami, Florida. Honolio Navarro Caballero, a resident of Miami-Dade County, was
the sole officer of the corporation.
30. Pico Construction & Remodeling Corp was a Florida corporation with its listed
principal address in Miami, Florida. Javier Pico, a resident of Miami-Dade County, was the
registered agent and sole officer of the corporation.
31. Gonzalez Gomez Remodeling Corp was a Florida corporation with its listed
principal address in West Palm Beach, Florida. Erisbel Gonzalez Gomez, a resident of Palm Beach
County, was the registered agent and sole officer of the corporation.
COUNT 1
Conspiracy to Commit Wire Fraud
(18 u.s.c. § 1349)
1. The General Allegations section of this Indictment is re-alleged and incorporated
by reference as though fully set forth herein.
2. From in or around May 2020, through on or about June 23 , 2020, in Miami-Dade
and Palm Beach Counties, in the Southern District of Florida, and elsewhere, the defendants,
HEIDI CID,
6
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 7 of 27
LAZARO VERDECIA HERNANDEZ, and
YADIER RODRIGUEZ ARTEAGA,
did willfully, that is, with intent to further the object of the conspiracy, and knowingly combine,
conspire, confederate, and agree with each other, and with others known and unknown to the Grand
Jury, to commit wire fraud, that is, to knowingly, and with the intent to defraud, devise, and intend
to devise, a scheme and artifice to defraud, and to obtain money and property by means of
materially false and fraudulent pretenses, representations, and promises, knowing that the
pretenses, representations, and promises were false and fraudulent when made, and, for the purpose
of executing the scheme and artifice, did knowingly transmit and cause to be transmitted, by means
of wire communication in interstate and foreign commerce, certain writings, signs, signals,
pictures, and sounds, in violation of Title 18, United States Code, Section 1343.
PURPOSE OF THE CONSPIRACY
3. It was the purpose of the conspiracy for the defendants and their co-conspirators
to unlawfully enrich themselves by, among other things : (a) submitting and causing the
submission of false and fraudulent applications for loans made available through the SBA to
provide relief for the economic effects caused by the COVID-19 pandemic, including PPP
loans; (b) offering, paying, and receiving kickbacks in return for assisting individuals with the
filing of the false and fraudulent loan applications; and ( c) diverting fraud proceeds for the
defendants ' and co-conspirators ' personal use, the use and benefit of others, and to further the
conspiracy.
MANNER AND MEANS OF THE CONSPIRACY
The manner and means by which the defendants and their co-conspirators sought
7
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 8 of 27
to accomplish the objects and purpose of the conspiracy included, among others, the
following:
4. HEIDI CID, LAZARO VERDECIA HERNANDEZ, YADIER RODRIGUEZ
ARTEAGA, and others known and unknown to the Grand Jury, agreed to submit, and caused the
submission of, online PPP loan applications at Lenders 1 and 2 on behalf of entities that the
defendants and their co-conspirators controlled. These entities included Mi Casa, Your Home,
LLC, LVH MA Group Inc, Yadier Rodriguez Arteaga Corp, Trueba Body Shop Corp, El Sol Party
Rental Corp, Business Enterprises USA, Inc., Corporation 1, Saavedra A/C Repairs Corp, Akira
Parfums Corp, Cabinet Installations & Sales Corp, Global Towing and Repair Corp, L&G
Ready Mix LLC, Professional Skills, Inc. , Honolio Navarro Concrete Inc, Pico Construction &
Remodeling Corp, and Gonzalez Gomez Remodeling Corp.
5. In these PPP loan applications, HEIDI CID, LAZARO VERDECIA
HERNANDEZ, YADIER RODRIGUEZ ARTEAGA, and others known and unknown to the
Grand Jury, made false and fraudulent representations regarding each entity's number of
employees and payroll and submitted false and fraudulent purported tax records and bank
statements in support thereof. The defendants, and others known and unknown to the Grand Jury,
also falsely represented that they and their entities would use the PPP funds for payroll.
6. As a result of the conspiracy' s false and fraudulent loan applications, HEIDI CID,
LAZARO VERDECIA HERNANDEZ, YADIER RODRIGUEZ ARTEAGA, and others
known and unknown to the Grand Jury, caused Lenders 1 and 2 to fraudulently disburse PPP funds
to accounts that the defendants and their co-conspirators controlled.
8
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 9 of 27
7. HEIDI CID, LAZARO VERDECIA HERNANDEZ, YADIER RODRIGUEZ
ARTEAGA, and their co-conspirators thereafter used the funds for their own personal use and
benefit, and to share the proceeds, in furtherance of the fraudulent scheme.
All in violation of Title 18, United States Code, Section 1349.
COUNTS 2-14
Wire Fraud
(18 u.s.c. § 1343)
1. The General Allegations section of this Indictment is re-alleged and incorporated
by reference as though fully set forth herein.
2. From in or around May 2020, through on or about June 23 , 2020, in Miami-Dade
and Palm Beach Counties, in the Southern District of Florida, the defendants,
HEIDI CID,
LAZARO VERDECIA HERNANDEZ, and
YADIER RODRIGUEZ ARTEAGA,
as set forth in each count below, did knowingly, and with the intent to defraud, devise, and intend
to devise, a scheme and artifice to defraud, and to obtain money and property by means of
materially false and fraudulent pretenses, representations, and promises, knowing that the
pretenses, representations, and promises were false and fraudulent when made, and, for the purpose
of executing the scheme and artifice, did knowingly transmit and cause to be transmitted, by means
of wire communication in interstate and foreign commerce, certain writings, signs, signals,
pictures and sounds, in violation of Title 18, United States Code, Section 1343 .
PURPOSE OF THE SCHEME AND ARTIFICE
3. It was the purpose of the scheme and artifice for the defendants and their
accomplices to unlawfully emich themselves by, among other things: (a) submitting and causing
9
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 10 of 27
the submission of false and fraudulent applications for loans made available through the SBA
to provide relief for the economic effects caused by the COVID-19 pandemic, including PPP
loans; (b) offering, paying, and receiving kickbacks in return for assisting individuals with the
filing of the false and fraudulent loan applications; and ( c) diverting fraud proceeds for the
defendants ' and co-conspirators ' personal use, the use and benefit of others, and to further the
fraud.
THE SCHEME AND ARTIFICE
4. The Manner and Means of the Conspiracy section of Count 1 of this Indictment is
re-alleged and incorporated by reference as though fully set forth herein as a description of the
scheme and artifice.
USE OF WIRES
5. On or about the dates specified as to each Count below, in the Southern District of
Florida, and elsewhere, HEIDI CID, LAZARO VERDECIA HERNANDEZ, and YADIER
RODRIGUEZ ARTEAGA, as specified as to each Count below, for the purpose of executing
and in furtherance of the aforesaid scheme and artifice to defraud, and to obtain money and
property by means of materially false and fraudulent pretenses, representations, and promises,
knowing that the pretenses, representations, and promises were false and fraudulent when made,
did knowingly transmit and cause to be transmitted in interstate commerce, by means of wire
communication, certain writings, signs, signals, pictures, and sounds, as described below:
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 11 of 27
Count Approximate Defendant(s) Description of Wire
Date
2 May 26, 2020 HEIDI CID Electronic transmission of a PPP
loan application containing false
information about the number of
employees and monthly payroll
of Mi Casa, Your Home, LLC, a
forged bank statement, and
forged tax documents, causing a
w1re transm1ss10n from the
Southern District of Florida to
outside of the State of Florida
3 May 26, 2020 HEIDI CID and Electronic transmission of a PPP
LAZARO VERDECIA loan application containing false
HERNANDEZ information about the number of
employees and monthly payroll
of Trueba Body Shop Corp, a
forged bank statement, and
forged tax documents, causing a
w1re transm1ss10n from the
Southern District of Florida to
outside of the State of Florida
4 May 27, 2020 HEIDI CID Electronic transmission of a PPP
and loan application containing false
Y ADIER RODRIGUEZ information about the number of
ARTEAGA employees and monthly payroll
of Yadier Rodriguez Arteaga
Corp, a forged bank statement,
and forged tax documents,
causing a wire transmission from
the Southern District of Florida to
outside of the State of Florida
11
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 12 of 27
Count Approximate Defendant(s) Description of Wire
Date
5 May 28, 2020 HEIDI CID and Electronic transmission of a PPP
LAZARO VERDECIA loan application containing false
HERNANDEZ information about the number of
employees and monthly payroll
of El Sol Party Rental Corp, and
forged tax documents, causing a
wire transm1ss10n from the
Southern District of Florida to
outside of the State of Florida
6 May 28, 2020 HEIDI CID Electronic transmission of a PPP
loan application containing false
information about the number of
employees and monthly payroll
of Business Enterprises USA,
Inc. and forged tax documents,
causing a wire transmission from
the Southern District of Florida to
outside of the State of Florida
7 May 29, 2020 HEIDI CID Electronic transmission of a PPP
loan application containing false
information about the number of
employees and monthly payroll
of Corporation 1, a forged bank
statement, and forged tax
documents, causmg a wire
transmission from the Southern
District of Florida to outside of
the State of Florida
12
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 13 of 27
Count Approximate Defendant(s) Description of Wire
Date
8 May 30, 2020 HEIDI CID Electronic transmission of a PPP
loan application containing false
information about the number of
employees and monthly payroll
of Saavedra A/C Repairs Corp, a
forged bank statement, and
forged tax documents, causing a
wire transm1ss10n from the
Southern District of Florida to
outside of the State of Florida
9 June 4, 2020 HEIDI CID Electronic transmission of a PPP
loan application containing false
information about the number of
employees and monthly payroll
of Akira Parfums Corp, and
forged tax documents, causing a
wue transmission from the
Southern District of Florida to
outside of the State of Florida
10 June 15, 2020 HEIDI CID Electronic transmission of a PPP
loan application containing false
information about the number of
employees and monthly payroll
of Cabinet Installations & Sales
Corp, false information that
Kenia Carrillo was not under a
bankruptcy proceeding, and
forged tax documents, causing a
wue transm1ss10n from the_
Southern District of Florida to
outside of the State of Florida
13
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 14 of 27
Count Approximate Defendant(s) Description Of Wire
Date
11 June 15, 2020 HEIDI CID Electronic transmission of a PPP
loan application containing false
information about the number of
employees and monthly payroll
of Global Towing and Repair
Corp, and forged tax documents,
causing a wire transmission from
the Southern District of Florida to
outside of the State of Florida
12 June 16, 2020 HEIDI CID Electronic transmission of a PPP
loan application containing false
information about the number of
employees and monthly payroll
of LVH MA Group, Inc, a forged
bank statement, and forged tax
documents, causmg a w1re
transmission from the Southern
District of Florida to outside of
the State of Florida
13 June 19, 2020 HEIDI CID Electronic transmission of a PPP
loan application containing false
information about the number of
employees and monthly payroll
of L&G Ready Mix LLC, and
forged tax documents, causing a
w1re transm1ss10n from the
Southern District of Florida to
outside of the State of Florida
14 June 23, 2020 HEIDI CID Electronic transmission of a PPP
loan application containing false
info1mation about the number of
employees and monthly payroll
of Professional Skills, Inc., and
forged tax documents, causing a
w1re transm1ss10n from the
Southern District of Florida to
outside of the State of Florida
In violation of Title 18, United States Code, Sections 1343 and 2.
14
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 15 of 27
COUNT 15
Conspiracy To Commit Money Laundering
(18 U.S.C. § 1956(h))
1. The General Allegations section of this Indictment is re-alleged and incorporated
by reference as though fully set forth herein.
2. From in or around May 2020, through in or around January 2021 , in Miami-Dade
and Palm Beach Counties, within the Southern District of Florida, and elsewhere, defendants,
HEIDI CID,
LAZARO VERDECIA HERNANDEZ, and
YADIER RODRIGUEZ ARTEAGA,
did knowingly and voluntarily, that is, with the intent to further the object of the conspiracy,
combine, conspire, confederate, and agree with each other, and others known and unknown to the
grand jury, to violate Title 18, United States Code, Sections 1956(a)(l)(B)(i) and 1957(a), as
follows :
a. to knowingly conduct a financial transaction affecting interstate commerce, which
financial transaction involved the proceeds of specified unlawful activity, knowing the property
involved in the financial transaction represented the proceeds of some form of unlawful activity,
and knowing that such transaction was designed in whole and in part to conceal and disguise the
nature, the location, the source, the ownership, and the control of the proceeds of specified
unlawful activity, in violation of Title 18, United States Code, Section 1956(a)(l)(B)(i); and
b. to knowingly engage in a monetary transaction by, through, and to a financial
institution, affecting interstate commerce in criminally derived property of a value greater than
$10,000 that is derived from specified unlawful activity, in violation of Title 18, United States
15
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 16 of 27
Code, Section 1957(a).
All in violation of Title 18, United States Code, Section l 956(h).
It is further alleged that the specified unlawful activity is wire fraud, in violation of Title
18, United States Code, Sections 1343 and 2.
COUNTS 16-23
MONEY LAUNDERING
(18 U.S.C. § 1957(a))
1. The General Allegations section of this Indictment is re-alleged and incorporated
by reference as though fully set forth herein.
2. On or about the dates set forth in each count below, in Miami-Dade County, in the
Southern District of Florida, HEIDI CID, LAZARO VERDECIA HERNANDEZ, and
YADIER RODRIGUEZ ARTEAGA, as specified in each count below, did knowingly engage
and attempt to engage in a monetary transaction by, through and to a financial institution, affecting
interstate and foreign commerce, in criminally derived property of a value greater than $10,000,
such property having been derived from specified unlawful activity, as more specifically described
below:
Count Approximate Defendant(s) Financial Transaction
Date
16 May 28, 2020 LAZARO Caused a bank transfer of approximately
VERDECIA $46,000 from an account in the name of
HERNANDEZ Trueba Body Shop Corp ending in 5225 at
Bank 1 in the Southern District of Florida
to an account owned and controlled by
LAZARO VERDECIA HERNANDEZ
ending in 6526 at Bank 1
16
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 17 of 27
Count Approximate Defendant(s) Financial Transaction
Date
17 May 29, 2020 LAZARO Caused the wire transfer of approximately
VERDECIA $32,000 from an account ending in 6526 at
HERNANDEZ Bank 1 in the Southern District of Florida
and to an attorney 's escrow account for the
HEIDI CID purchase of property at 5985 W 13th Ave.
Hialeah, FL 33012
18 June 9, 2020 HEIDI CID Caused a wire transfer of approximately
$50,000 from an account in the name of
Yadier Rodriguez Arteaga Corp ending in
4308 at Bank 2 in the Southern District of
Florida to an account owned and controlled
by HEIDI CID ending in 7565 at Bank 3
19 July 9, 2020 HEIDI CID Wire transferred approximately
$19,517.06 from an account ending in
7565 at Bank 3 in the Southern District of
Florida to an attorney's escrow account to
pay off a mortgage for a property located at
16320 NW 37th Ave. Miami Gardens, FL
33054
20 July 2, 2020 YADIER Caused a wire transfer of approximately
RODRIGUEZ $209,000 from an account in the name of
ARTEAGA L&G Ready Mix LLC ending in 9902 at
Bank 4 in Texas to an account owned and
controlled by YADIER RODRIGUEZ
ARTEAGA ending in 1167 at Bank 2
17
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 18 of 27
Count Approximate Defendant(s) Financial Transaction
Date
21 July 7, 2020 YADIER Caused a wire transfer of approximately
RODRIGUEZ $168,000 from an account in the name of
ARTEAGA Professional Skills, Inc. ending in 2390 at
Bank 5 in the Southern District of Florida
to an account owned and controlled by
YADIER RODRIGUEZ ARTEAGA
ending in 1167 at Bank 2
22 November 25, YADIER Caused a wire transfer of approximately
2020 RODRIGUEZ $187,717.93 from an account ending in
ARTEAGA 1167 at Bank 2 in the Southern District of
and Florida to a title company's bank account
LAZARO for the purchase of a property located at
VERDECIA 19820 SW 132 Ct. Miami, FL 33177
HERNANDEZ
23 December 28, YADIER Wire transferred approximately $100,000
2020 RODRIGUEZ from an account ending in 1167 at Bank 2
ARTEAGA to bank account owned and controlled by
and LAZARO VERDECIA HERNANDEZ
LAZARO ending in 1972 at Bank 6
VERDECIA
HERNANDEZ
In violation of Title 18, United States Code, Sections 1957(a) and 2.
It is further alleged that the specified unlawful activity is wire fraud, in violation of Title
18, United States Code, Sections 1343 and (2).
FORFEITURE ALLEGATIONS
1. The allegations of this Indictment are hereby re-alleged and by this reference fully
incorporated herein for the purpose of alleging forfeiture to the United States of America of certain
property in which the defendants, HEIDI CID, LAZARO VERDECIA HERNANDEZ, and
18
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 19 of 27
Y ADIER RODRIGUEZ ARTEAGA have an interest.
2. Upon conviction of a violation of Title 18, United States Code, Section 1343 or
1349, as alleged in this Indictment, the defendants shall forfeit to the United States any property
constituting, or derived from, proceeds obtained, directly or indirectly, as a result of such violation,
pursuant to Title 18, United States Code, Section 982(a)(2)(A).
3. Upon conviction of a violation of Title 18, United States Code, Section 1956 or
1957, as alleged in this Indictment, the defendants shall forfeit to the United States any property,
real or personal, involved in such offense, and any property traceable to such property, pursuant
to Title 18, United States Code, Section 982(a)(l).
4. The property subject to forfeiture as a result of the alleged offenses includes, but is
not limited to:
a. The real property located at 5985 W 13 AVE, HIALEAH, FLORIDA 3301 2.
5. If any of the property subject to forfeiture, as a result of any act or omission of the
defendants:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction of the court;
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be divided without
difficulty,
the United States shall be entitled to the forfeiture of substitute property under the provisions of
Title 21 , United States Code, Section 853(p ). Such substitute property includes, but is not limited
19
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 20 of 27
to, the following:
a. The real property located at 16225 SW 107 CT, MIAMI, FLORIDA 33157; and
b. The real property located at 4211 NW 195 ST, MIAMI GARDENS, FLORIDA
33055 .
All pursuant to Title 18, United States Code, Sections 982(a)(l) and 982(a)(2)(A), and the
procedures set forth in Title 21 , United States Code, Section 853 , as incorporated by Title 18,
United States Code, Section 982(b )(1 ).
EBILL
FOREPERSON
EY
THOMAS HAGGERTY
ASSISTANT UNITED STATES ATTORNEY
20
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 21 of 27
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
UNITED STATES OF AMERICA CASE NO.: - - - - - - -- -- - - - - - - -
v.
CERTIFICATE OF TRIAL ATTORNEY
HEIDI CID, et al.,
I Superseding Case Information:
- -- -- - -
D-e~fe_n_d_a-nt_s__- - - -
New Defendant(s) (Yes or No)
Court Division (select one)
---
Number of New Defendants
~ Miami □ Key West □ FTP Total number of counts
□ FTL □ WPB
I do hereby certify that:
I. I have carefully considered the allegations of the indictment, the number of defendants, the number of probable
witnesses and the legal complexities of the Indictment/Information attached hereto.
2. I am aware that the information supplied on this statement will be relied upon by the Judges of this Court in setting
their calendars and scheduling criminal trials under the mandate of the Speedy Trial Act, Title 28 U.S.C. §3161.
3. Interpreter: (Yes or No) Yes
---
List language and/or dialect: _S._pa_n_i_
sh_ _ __
4. This case wi II take _ 7_ days for the parties to try.
5. Please check appropriate category and type of offense listed below:
(Check only one) (Check on ly one)
I D Oto 5 days D Petty
II ~ 6 to 10 days □ Minor
III D 11 to 20 days D Misdemeanor
IV D 2 1 to 60 days D Felony
V D 61 days and over
6. Has this case been previously filed in this District Court? (Yes or No) _N_o_ _
If yes, Judge _ _ _ _ _ _ _ _ _ _ _ Case No. _ _ _ _ _ _ _ _ _ _ _ _ _ __
7. Has a complaint been filed in this matter? (Yes or No) No
---
Ifyes, Magistrate Case No. _ _ _ _ _ _ _ _ _ _ __
8. Does this case relate to a previously filed matter in this District Court? (Yes or No) _N_o _ _
If yes, Judge _ _ __ _ _ _ _ _ _ _ Case No. _ _ _ _ _ _ _ __ _ _ _ _ __
9. Defendant(s) in federal custody as of _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
10. Defendant(s) in state custody as of _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
11. Rule 20 from the _ _ _ _ District of _ _ _ _ _ __
12. Is this a potential death penalty case? (Yes or No) _ No __
13. Does this case originate from a matter pending in the Northern Region of the U.S. Attorney ' s Office
prior to August 8, 2014 (Mag. Judge Shan iek Maynard? (Yes or No) No
---
14. Does this case originate from a matter pending in the Central Region of the U.S . Attorney' s Office
prior to October 3, 20 19 (Mag. Judge Jared Strauss? (Yes or No) No
---
15. Did this matter involve the participation of or consu ltation with now Magistrate Judge Eduardo I. Sanchez
during his tenure at the U .S . Attorney ' s Office, which concluded on January zi, 2023 ? N__o_ _
By:
THOMAS HAGG
Assistant United States Attorney
FL Bar No. 46136
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 22 of 27
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENAL TY SHEET
Defendant's Name: c!c.-'HE=I==D-"'-I""""Ce..:cI==D'-------- - - -- - - - - - - -- - - --
Case No: - - - - - -- -- -- - - - -- -- -- - -- - - - - -- - --
Count#: 1
Conspiracy to Commit Wire Fraud
Title 18 United States Code Section 1349
*Max.Term oflmprisonment: 20 Years' Imprisonment
* Mandatory Min. Term of Imprisonment (if applicable): None
*Max.Supervised Release: 3 Years
* Max. Fine: $250,000.00
Counts #: 2-14
Wire Fraud
Title 18 United States Code Section 1343
*Max.Term oflmprisonment: 20 Years' Imprisonment
* Mandatory Min. Term oflmprisonment (if applicable): None
* Max. Supervised Release: 3 Years
* Max. Fine: $250,000.00
Count#: 15
Conspiracy to Commit Money Laundering
Title 18, United States Code, Section 1956(h)
* Max.Term oflmprisonment: 20 Years' Imprisonment
* Mandatory Min. Term oflmprisonment (if applicable): None
*Max.Supervised Release: 3 Years
* Max.Fine: $500,000.00 or twice the value of the property involved in the transaction
(whichever is greater)
*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 23 of 27
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Name: ==--=---'=='---
HEIDI CID - - - - - - - - - - - -- - -- - - - - - -
Case No: - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - -
Counts#: 17-19
Money Laundering
Title 18, United States Code, Section 1957(a)
*Max.Term oflmprisonment: 10 Years' Imprisonment
* Mandatory Min. Term of Imprisonment (if applicable): None
* Max.Supervised Release: 3 Years
*Max.Fine: $250,000.00 or up to twice the value of the property involved in the transaction.
*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 24 of 27
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Name: LAZARO VERDECIA HERNANDEZ
Case No: - - - -- - - - -- - - - - -- - - - - - - - - - - - - - - - -
Count#: 1
Conspiracy to Commit Wire Fraud
Title 18 United States Code Section 1349
*Max.Term oflmprisonment: 20 Years' Imprisonment
* Mandatory Min. Term oflmprisonment (if applicable): None
*Max.Supervised Release: 3 Years
* Max. Fine: $250,000.00
Count#: 3
Wire Fraud
Title I 8 United States Code Section 1343
*Max.Term oflmprisonment: 20 Years' Imprisonment
* Mandatory Min. Term of Imprisonment (if applicable): None
*Max.Supervised Release: 3 Years
* Max. Fine: $250,000.00
Count#: 15
Conspiracy to Commit Money Laundering
Title 18, United States Code, Section 1956(h)
*Max.Term oflmprisonment: 20 Years' Imprisonment
* Mandatory Min. Term oflmprisonment (if applicable): None
*Max.Supervised Release: 3 Years
*Max.Fine: $500,000.00 or twice the value of the property involved in the transaction
(whichever is greater)
*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 25 of 27
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Name: LAZARO VERDECIA HERNANDEZ
Case No: - - - -- - - -- - - - - - - - - - - - - - - - - -- - - - - -
Counts #: 16, 17 and 22
Money Laundering
Title 18, United States Code, Section 1957(a)
* Max. Term oflm prisonment: 10 Years ' Imprisonment
* Mandatory Min. Term oflmprisonment (if applicable): None
*Max.Supervised Release: 3 Years
*Max.Fine: $250,000.00 or up to twice the value of the property involved in the transaction.
*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 26 of 27
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Name: YADIER RODRIGUEZ ARTEAGA
Case No: - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Count#: 1
Conspiracy to Commit Wire Fraud
Title 18 United States Code Section 1349
* Max.Term oflmprisonment: 20 Years' Imprisonment
* Mandatory Min. Term oflmprisonment (if applicable): None
*Max.Supervised Release: 3 Years
* Max. Fine: $250,000.00
Count#:4
Wire Fraud
Title 18 United States Code Section 1343
* Max.Term oflmprisonment: 20 Years' Imprisonment
* Mandatory Min. Term oflmprisonment (if applicable): None
*Max.Supervised Release: 3 Years
* Max. Fine: $250,000.00
Count#: 15
Conspiracy to Commit Money Laundering
Title 18, United States Code, Section 1956(h)
* Max.Term oflmprisonment: 20 Years' Imprisonment
* Mandatory Min. Term oflmprisonment (if applicable): None
*Max.Supervised Release: 3 Years
* Max.Fine: $500,000.00 or twice the value of the property involved in the transaction
(whichever is greater)
*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 1:23-cr-20421-RNS Document 1 Entered on FLSD Docket 10/26/2023 Page 27 of 27
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENAL TY SHEET
Defendant's Name: YADIER RODRIGUEZ ARTEAGA
Case No: - - -- -- - - - - - - - - - - - - - - - - - - - - - - - - - -
Counts #: 20-23
Money Laundering
Title 18, United States Code, Section l 957(a)
* Max. Term oflm prisonment: IO Years ' Imprisonment
* Mandatory Min. Term of Imprisonment (if applicable): None
*Max.Supervised Release: 3 Years
*Max.Fine: $250,000.00 or up to twice the value of the property involved in the transaction.
*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable.
File and source
- File
- 1-indictment-heidi-cid-lazaro-verdecia-hernandez-yadier-rodrig.pdf
- Size
- 2,609,943 bytes
- SHA-256
- 000a7bddffce2a52e87d789d40e7e40144659754075c9942b10f376a517ef4be
- Original
- archive.org