Indictment — United States v. Mohamed Kamara, District of New Jersey (Document 16)
Summary
An indictment in United States of America v. Mohamed Kamara, Crim. No. 22-167-ES, in the U.S. District Court for the District of New Jersey, filed March 1, 2022 as Document 16, before the Hon. Esther Salas. Count One charges conspiracy to commit wire fraud under 18 U.S.C. § 1349, alleging that from in or about March 2020 through in or about October 2020 Kamara and others used other people's information to obtain more than $750,000 in Economic Injury Disaster Loans. Count Two charges wire fraud under 18 U.S.C. § 1343 and 2, alleging that Kamara obtained more than $150,000 in New Jersey unemployment insurance benefits with applications sent from Maryland, including one on or about May 10, 2020. Count Three charges aggravated identity theft under 18 U.S.C. § 1028A, and forfeiture is sought on Counts One and Two.
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“Indictment — United States v. Mohamed Kamara, District of New Jersey (Document 16).”
Original at www.justice.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-2-22-cr-00167-dkt-16-d-n-j-f09be9baf0/
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Case 2:22-cr-00167-ES Document 16 Filed 03/01/22 Page 1 of 9 PageID: 38
2022R00089 / ADK
By Stephen Bond at 2:14 pm, Mar 01, 2022
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
UNITED STATES OF AMERICA Hon. Esther Salas
Crim. No. 22-167-ES
v.
18 U.S.C. § 1349
18 U.S.C. § 1343 and 2
MOHAMED KAMARA 18 U.S.C. § 1028A
INDICTMENT
The Grand Jury in and for the District of New Jersey, sitting
at Newark, charges as follows:
COUNT ONE
(Conspiracy to Commit Wire Fraud)
Introduction
1. From in or around March 2020 to m or around October 2020,
defendant Mohamed Kamara ("KAMARA") conspired with others to fraudulently
obtain more than $750,000 in Economic Injury Disaster Loans ("EIDLs"). In
addition, from in or around January 2020 to in or around September 2020,
KAMARA fraudulently obtained more than $150,000 in unemployment
insurance benefits ("UIBs") from the State of New Jersey. As part of his UIB
scheme, KAMARA committed aggravated identity theft by using the names, dates
of birth, and social security numbers belonging to other individuals to
fraudulently obtain the UIBs.
Relevant Background
2. At various times relevant to this Indictment:
a. Defendant Kamara was a resident of New Jersey or Maryland.
Case 2:22-cr-00167-ES Document 16 Filed 03/01/22 Page 2 of 9 PageID: 39
that typically set additional state-specific requirements for eligibility, benefit
amounts, and duration of payments. Generally, UIB amounts were based on a
percentage of earnings over a fixed period.
e. The SWA for the State of New Jersey was the New Jersey
Department of Labor ("NJ DOL''), which administered an online portal for
collecting UIB applications. The servers for the portal were located in Mercer
County, New Jersey.
The Conspiracy
3. From in or about March 2020 through in or about October 2020,
in Bergen County, in the District of New Jersey, and elsewhere, defendant
MOHAMED KAMARA
did knowingly and intentionally conspire with others to devise, and intend to
devise, a scheme and artifice to defraud the SBA and others, and to obtain
money and property by means of materially false and fraudulent pretenses,
representations, and promises, and, for the purpose of executing and
attempting to execute such scheme and artifice to defraud, did transmit and
cause to be transmitted by means of wire communications in interstate and
foreign commerce, certain writings, signs, signals, pictures, and sounds,
contrary to Title 18, United States Code, Section 1343.
Goal of the Conspiracy
3. The goal of the conspiracy was for KAMARA and his conspirators to
enrich themselves by fraudulently obtaining EIDL loans.
3
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Manner and Means of the Conspiracy
4. It was part of the conspiracy that:
a. KARMARA and his conspirators submitted applications for
EIDLs using information belonging to other individuals and entities without
their knowledge and consent.
b. KAMARA and his conspirators opened bank accounts using
fraudulent documents ("the Fraud Bank Accounts"}.
c. KAMARA and his conspirators caused the SBA to grant the
fraudulent EIDL applications and to send the proceeds of the EIDLs to the
Fraud Bank Accounts by wire communication. At least one of the EIDL wire
transfers to a Fraud Bank Account involved a wire communication from a
location outside of New Jersey to a location in Bergen County, New Jersey.
d. KAMARA then deposited or attempted to deposit checks from
the Fraud Bank Accounts into a bank account in his name.
e. KAMARA and his conspirators' fraudulent EIDL applications
caused the SBA to provide more than $750,000 in EIDLs.
In violation of Title 18, United States Code, Section 1349.
4
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COUNT TWO
(Wire Fraud)
1. The allegations in paragraphs 1 and 2 of Count 1 of this
Indictment are realleged here.
The Scheme to Defraud
2. From on or about January 1, 2020, through on or about
September 30, 2020, in Mercer County, in the District of New Jersey, and
elsewhere, defendant
MOHAMED KAMARA
did knowingly and intentionally devise, and intend to devise, a scheme and
artifice to defraud the State of New Jersey, and to obtain money and property
from the State of New Jersey by means of materially false and fraudulent
pretenses, representations and promises, and, for purposes of executing and
attempting to execute such scheme and artifice to defraud, did knowingly a nd
intentionally transmit and cause to be transmitted by means of wire
communications in interstate and foreign commerce certain writings, signs,
signals, pictures and sounds, including a wire communication from Maryland
to New Jersey, as more fully set forth below.
Goal of the Scheme to Defraud
3. The goal of the scheme and artifice to defraud was for KAMARA to
enrich himself by obtaining money from the State of New Jersey by submitting
fraudulent UIB a pplications in the names of other individuals.
5
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Manner and Means of the Scheme to Defraud
4. It was part of the scheme and artifice to defraud that:
a. KAMARA obtained personal identification, including names,
dates of birth, and social security numbers, belonging to other individuals ("the
PII").
b. KAMARA submitted applications for UIBs to the NJ DOL
from his residence in Maryland using the PII ("the Fraudulent Applications").
c. KAMARA caused the State of New Jersey to approve and
distribute more than $150,000 in response to the Fraudulent Applications.
Execution of the Scheme
5. On or about May 10, 2020, for the purpose of executing the
scheme and artifice to defraud, in the District of New J ersey, and elsewhere,
defendant
MOHAMED KAMARA
knowingly and intentionally transmitted and caused to be transmitted by
means of wire communication in interstate and foreign commerce, certain
writings, signs, signals, pictures, and sounds, namely, an application for UIBs
in the name of F.K., from a location in Maryla nd to a location in New Jersey.
In violation of Title 18, United States Code, Section 1343 and Section 2.
6
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COUNT THREE
(Aggravated Identity Theft)
1. The allegations in paragraph 1 through 5 of Count 2 of this
Indictment are realleged here.
2. On or about May 10, 2020, in Mercer County, in the District of
New Jersey, and elsewhere, the defendant
MOHAMED KAMARA
during and in relation to a felony violation of 18 U.S.C. § 1343 as set forth in
Count Two of this Indictment, did knowingly and intentionally transfer,
possess, and use, without lawful authority, a means of identification of another
person, to wit, the name, date of birth, and social security number of F.K.,
knowing that the m eans of identification belonged to another actual person.
In violation of Title 18, United States Code, Section 1028A.
7
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FORFEITURE ALLEGATIONS AS TO COUNTS ONE AND TWO
1. Upon conviction of the offenses charged in Counts One and Two
of this Indictment, the government will seek forfeiture from d efendant
KAMARA, in a ccorda nce with Title 28, United Sta tes Code, Section 246l(c), and
Title 18, United States Code, Section 98l(a){l)(C), of any an d all property, real
or personal, tha t constitutes or is d erived from proceeds tracea ble to the
viola tions of Title 18, United States Code, Section s 1343 and 1349.
Su bstitute As sets Provision
2 . If by any act or omission of defendant KAMARA any of the
property subject to forfeiture herein:
a . cannot be located u pon t he 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 cou rt;
d . has been substantially diminis hed in value; or
e. has been commingled with other p roperty which cannot
be subdivided without difficulty,
8
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it is the intent of the United States, pursuant to Title 21, United States Code,
Section 853(p), as incorporated by Title 28, United States Code, Section
246l(c), to s eek forfeiture of any other property of defendant KAMARA up to the
value of th e property described in this forfeiture allega tion .
A TRUE BILL
PHILIP R. SELLINGER
United States Attorney
9
CASE NUMBER: -----
United States District Court
District of New Jersey
UNITED STATES OF AMERICA
v.
MOHAMED KAMARA
22-cr-167-ES
INDICTMENT FOR
18 U .S.C. §§ 1028A, 1343 and 1349
PHILIP R. SELLINGER
UNITED STATES ATIORNEY
FOR THE D ISTRICT OF NEW JERSEY
A NDREW K OGAN
ASSISTANT U .S. ATIORNEY
NEWARK, NEW J ERSEY
973.645.2700
Case 2:22-cr-00167-ES Document 16 Filed 03/01/22 Page 9 of 9 PageID: 46
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