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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
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                                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
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         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
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          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
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  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
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                                           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.


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