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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/, SHA-256 bd89134affe9827945de5474e2d6494b8e461e8efecad20710131345f8f229ec.

Full text

   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
  Case 2:22-cr-00167-ES Document 16 Filed 03/01/22 Page 3 of 9 PageID: 40




                    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
  Case 2:22-cr-00167-ES Document 16 Filed 03/01/22 Page 4 of 9 PageID: 41




                                  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
   Case 2:22-cr-00167-ES Document 16 Filed 03/01/22 Page 5 of 9 PageID: 42




                   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
  Case 2:22-cr-00167-ES Document 16 Filed 03/01/22 Page 6 of 9 PageID: 43




                               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
  Case 2:22-cr-00167-ES Document 16 Filed 03/01/22 Page 7 of 9 PageID: 44




        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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