Information — United States v. Damaris Valerio a/k/a Damaris Tineo Abreu (Dkt. 23, D.N.J.)

Summary

A two-count information against Damaris Valerio, a/k/a Damaris Tineo Abreu, filed June 24, 2025 as Document 23 in Case 3:25-cr-00414-RK in the U.S. District Court for the District of New Jersey, before the Hon. Robert Kirsch, after the defendant waived prosecution by indictment. Count One charges wire fraud under 18 U.S.C. § 1343 and Count Two charges money laundering under 18 U.S.C. § 1957. The information alleges that Valerio, owner of La Vogue House of Beauty, LLC, obtained approximately $194,212 through false PPP, EIDL and unemployment insurance applications, including a PPP loan of approximately $122,292 disbursed on or about May 8, 2020 and approximately $61,920 in unemployment benefits. Count Two concerns a transfer of approximately $25,000 on or about June 17, 2020. It seeks forfeiture of $194,212 and is signed by United States Attorney Alina Habba.

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’ Case 3:25-cr-00414-RK Document 23 Filed 06/24/25 Page 1 of 12 PagelD: 56

2024R00501/BDB

UNITED STATES DISTRICT COURT RECE| VED
DISTRICT OF NEW JERSEY JUN 2 f 2005
ROB ”
UNITED STATES OF AMERICA : Hon. Robert Kirsch
V. : Crim. No. 25- CR-414
DAMARIS VALERIO, ; 18 U.S.C. § 1343
a/k/a “Damaris Tineo Abreu” : 18 U.S.C, § 1957

INFORMATION

The defendant having waived in open court prosecution by Indictment, the

United States Attorney for the District of New Jersey charges:

COUNT ONE
(Wire Fraud)
1. At all times relevant to this Information:
a, Defendant Damaris Valerio, a/k/a “Damaris Tineo Abreu”

(“VALERIO’”), resided in Perth Amboy, New Jersey. VALERIO owned and operated
La Vogue House of Beauty, LLC, a/k/a LaVogue House of Beauty (“LA VOGUE”),
located in Perth Amboy, New Jersey.

b. Lender 1 was a financial institution headquartered in San
Francisco, California.

C, Bank 1 was a financial institution headquartered in San
Francisco, California, where LA VOGUE held an account ending in -2583, (“Account
2583”), VALERIO was the sole signatory for Account 2583.

The Paycheck Protection Program
d. The Coronavirus Aid, Relief, and Economic Security Act “CARES

Act”) was a federal law enacted in or around March 2020 designed to provide

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* Case 3:25-cr-00414-RK Document 23 Filed 06/24/25 Page 2 of 12 PagelD: 57

emergency financial assistance to Americans suffering economic effects caused by the
COVID-19 pandemic. One source of relief provided by the CARES Act was the
authorization of up to approximately $349 billion in forgivable loans to small
businesses for job retention and certain other expenses, through a program referred
to as the Paycheck Protection Program (“PPP”), In and around April 2020, Congress
authorized over approximately $300 billion in additional PPP funding.

e. To obtain a PPP loan, a qualifying business had to submit a PPP
loan application, which was signed by an authorized representative of the business.
The PPP loan application required the business (through its authorized
representative) to acknowledge the program rules and to make certain affirmative
certifications to be eligible to obtain the PPP loan. In the PPP loan application, the
business (through its authorized representative) had to truthfully state, among other
things, its: (a) average monthly payroll expenses; and (b) number of employees. These
figures were used to calculate the amount of money the business was eligible to
receive under the PPP. In addition, a business applying for a PPP loan had to provide
truthful supporting documentation, which could include the business’s tax
information, such as Internal Revenue Service (“IRS”) Forms 941 and 940.

f. A PPP loan application had to be processed by a participating
lender. If a PPP loan application was approved, the participating lender funded the
PPP loan using its own money, which was 100% guaranteed by the United States
Small Business Administration (“SBA”). Data from the application, including
information about the borrower, total amount of the loan, and listed number of

employees was transmitted by the lender to the SBA when processing the loan.

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* Case 3:25-cr-00414-RK Document 23 Filed 06/24/25 Page 3 of 12 PagelD: 58

g. PPP money had 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 forgiven entirely if the business spent
the money on these expense items within a designated period (usually eight weeks of
receiving the money) and used at least 75% of the PPP money on payroll expenses.

The Economic Injury Disaster Loan (“EKIDL”) Program

h. Another source of relief provided by the CARES Act was the EIDL
program, which was an SBA program that provided low-interest financing to small
businesses, renters, and homeowners in regions affected by declared disasters.

1. To obtain an EIDL program loan, a qualifying business was
required to submit an application to the SBA and provide truthful information about
its operations, such as the number of employees, gross revenues for the 12-month
period preceding the disaster, and cost of goods sold in the 12-month period preceding
the disaster. In the case of EIDL program loans for COVID-19 relief, the 12-month
period constituted the 12 months preceding January 81, 2020. In addition, the
business entity must have existed in an operational condition on February 1, 2020.

j. The amount of the EIDL program loan was determined partly on
the information the applicant provided regarding the revenue, employees, and cost of
goods of the company. The SBA directly issued any money disbursed under an EIDL
program loan to the applicant company. A company was required to use all EIDL
program money as working capital including for payroll expenses, sick leave,
production costs, and business obligations, such as debts, rent, and mortgage

payments.
” Case 3:25-cr-00414-RK Document 23 _ Filed 06/24/25 Page 4 of 12 PagelD: 59

k. As part of the EIDL program application, applicants could apply
for up to a $10,000 grant, known as an EIDL program advance, which did not need
to be repaid.

Federal Unemployment Insurance Benefits

1, The CARES Act also created a new temporary federal
unemployment insurance program called Pandemic Unemployment Assistance
(“PUA”). PUA provided unemployment insurance benefits ((UIB”) for individuals who
were not eligible for other types of unemployment (e.g., self-employed individuals,
independent contractors, or gig economy workers). The CARES Act also created a new
temporary federal program called Federal Pandemic Unemployment Assistance
(“FPUA”) that provided an additional weekly benefit to those eligible for PUA and
regular unemployment benefits.

m. Applicants were required to complete an application and verify
the applicant’s employment status, among other things, prior to receiving benefits.
The applicant could also direct the applicable department of labor to send any of the
approved benefits to either a specific bank account or a debit card.

n. The state workforce agency (“SWA”) was responsible for
distributing funds provided through the PUA and FPUC programs. These funds were
received by the SWA from the United States Department of the Treasury
(“Treasury”). When an SWA approved an unemployment benefits application, the
SWA caused money to be transferred to the applicant. Here, the SWA was the New

Jersey Department of Labor “NJDOL?”).
’ Case 3:25-cr-00414-RK Document 23 Filed 06/24/25 Page 5 of 12 PagelD: 60

The Scheme to Defraud

2. From in or around April 2020 through in or around December 2021, in
Middlesex County, in the District of New Jersey and elsewhere, the defendant,

DAMARIS VALERIO,
a/k/a “Damaris Tineo Abreu,”

did knowingly and intentionally devise and intend to devise a scheme and artifice to
defraud a victim lender, the SBA, and the NJDOL, and to obtain money and property
by means of materially false and fraudulent pretenses, representations, and
promises, which scheme and artifice was in substance as set forth below.
Goal of the Scheme to Defraud

3. The goal of the scheme was for VALERIO to enrich herself by

fraudulently obtaining and misusing federal COVID-19 emergency relief money.
Manner and Means of Scheme to Defraud

4, It was part of the scheme that:

a. VALERIO submitted and caused to be submitted at least one
falsified and fraudulent PPP loan application; at least two falsified and fraudulent
EIDL Program applications, including for an EIDL Program advance; and at least
one falsified and fraudulent application for UIBs, seeking federal COVID-19
emergency relief money.

b, VALERIO’s fraudulent PPP application included false
information concerning LA VOGUE?’s payroll expenses and number of employees.
VALERIO’s fraudulent EIDL applications included false information concerning LA

VOGUE’s number of employees. VALERIO’s fraudulent UIB application included
* Case 3:25-cr-00414-RK Document 23 Filed 06/24/25 Page 6 of 12 PagelD: 61

false representations about her employment status and employer's operating status.
c. As a result of her fraudulent applications, VALERIO unlawfully
obtained approximately $194,212 in COVID-19 emergency relief funds.

Fraudulent PPP Application

d. On or about April 15, 2020, VALERIO submitted a PPP loan
application to Lender 1 on behalf of LA VOGUE requesting approximately $122,292
(the “PPP Application”). The PPP Application listed VALERIO as LA VOGUE’s sole
owner and primary contact. The PPP Application and its supporting documents
contained materially false and fraudulent information.

@, In particular, in support of the PPP Application, VALERIO falsely
represented that LA VOGUE had an average monthly payroll of $48,917 and 15

employees.

f. On or about May 8, 2020, VALERIO’s false and fraudulent
representations and omissions in the PPP Application caused Lender 1 to disburse
approximately $122,292 into Account 2583 using Bank 1.

Fraudulent KIDL Application

g. On or about April 2, 2020, VALERIO submitted an EIDL Program
application to the SBA on behalf of LA VOGUE (the “EIDL Application”), VALERIO
submitted the EIDL Application from New Jersey via the SBA’s online portal to SBA
servers located in or around Des Moines, lowa. VALERIO listed herself as sole owner
of LA VOGUE and signed the EIDL Application.

h. In support of the EIDL Application, VALERIO falsely represented

that as of January 31, 2020, LA VOGUE had 15 employees, and that she would use
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’ Case 3:25-cr-00414-RK Document 23 _ Filed 06/24/25 Page 7 of 12 PagelD: 62

all the proceeds of the EIDL solely as working capital to alleviate economic injury
caused by the COVID-19 pandemic.

1. Between in or around April 2020 to in or around December 2021,
VALERIO’s false and fraudulent representations in the EIDL Application caused the
transfer of EIDL program money into Account 25838, including $10,000 for and EIDL
program advance. VALERIO did not use all the EIDL program money as working
capital as required, and instead converted some of the proceeds for personal expenses.

Fraudulent UIB Application

j. On or about March 29, 2020, VALERIO submitted on her own
behalf a claim to the NJDOL for UIBs (the “UIB Application”). In the UIB
Application, VALERIO stated that she was self-employed or the owner of LA VOGUE.

k. In support of the UIB Application, VALERIO submitted
materially false and fraudulent information, including that her last date of
employment with LA VOGUE was March 16, 2020; the reason for her separation from
LA VOGUE was that the “Business Closed”; and that she did not expect to be recalled
by LA VOGUE. VALERIO continued to file certifications for UIBs until in or around
August 2021.

L, VALERIO’s false and fraudulent representations and omissions
in the UIB Application caused NJDOL to disburse approximately $61,920 in UIBs to
VALERIO.

Execution of the Scheme to Defraud
5. On or about April 2, 2020, in Middlesex County, in the District of New

Jersey and elsewhere, the defendant,
* Case 3:25-cr-00414-RK Document 23 Filed 06/24/25 Page 8 of 12 PagelD: 63

DAMARIS VALERIO,
a/k/a “Damaris Tineo Abreu,”

for the purpose of executing the scheme described above, transmitted and caused to
be transmitted by means of wire communication in interstate and foreign commerce
certain writings, signs, signals, pictures and sounds, namely, the submission of an
EIDL application for LA VOGUE via an interstate wire that travelled from New
Jersey and Iowa.

In violation of Title 18, United States Code, Section 1343.
‘Case 3:25-cr-00414-RK Document 23 Filed 06/24/25 Page 9 of 12 PagelD: 64

2024R00501/BDB

COUNT TWO
(Money Laundering)

1. The allegations in paragraphs 1, 3, and 4 of Count One of this
Information are realleged here.
2. On or about June 17, 2020, in Middlesex County, in the District of New

Jersey and elsewhere, the defendant,

DAMARIS VALERIO,
a/k/a “Damaris Tineo Abreu,”

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, that is, causing a transfer of
approximately $25,000 from Account 2583 to be deposited into a bank account ending
in -9052, such property having been derived from a specified unlawful activity, that
is, wire fraud, contrary to Title 18, United States Code, Section 13438.

In violation of Title 18, United States Code, Section 1957(a).
‘Case 3:25-cr-00414-RK Document 23 Filed 06/24/25 Page 10 of 12 PagelD: 65

FORFEITURE ALLEGATION AS TO COUNT ONE
Upon conviction of the offense in violation of Title 18, United States Code,
Section 1348, as charged in Count One of this Information, defendant DAMARIS
VALERIO shall forfeit to the United States, pursuant to Title 18, United States Code,
Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c), any property,
real or personal, which constitutes or is derived from proceeds traceable to the

commission of such offense, the value of which totaled $194,212.

FORFEITURE ALLEGATION AS TO COUNT TWO

Upon conviction of the offense in violation of Title 18, United States Code,
Section 1957, as charged in Count Two of this Information, defendant DAMARIS
VALERIO shall forfeit to the United States, pursuant to Title 18, United States Code,
Section 982(a)(1), any property, real or personal, involved in such offense, or any
property traceable to such property.

SUBSTITUTE ASSETS PROVISION
(Applicable to All Forfeiture Allegations)

If any of the above-described forfeitable property, as a result of any act of
omission of the defendant:
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,

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‘Case 3:25-cr-00414-RK Document 23 _ Filed 06/24/25 Page 11 of 12 PagelD: 66

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 2461(c) and Title 18,
United States Code, Section 982(b), to seek forfeiture of any other property of the

defendant up to the value of the forfeitable property described above.

ZA fina. Habba

ALINA HABBA
United States Attorney

District of New Jersey

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‘Case 3:25-cr-00414-RK Document 23 Filed 06/24/25 Page 12 of 12 PagelD: 67

CASE NUMBER: 25- CR-414

United States District Court
District of New Jersey

UNITED STATES OF AMERICA
Vv.

DAMARIS VALERIO,

ak/a “Damaris Tineo Abreu”

INFORMATION FOR

18 U.S.C. § 1343
18 U.S.C. § 1957

ALINA HABBA
UNITED STATES ATTORNEY
FOR THE DISTRICT OF NEW JERSEY

BENJAMIN D. BLEIBERG
ASSISTANT U.S, ATTORNEY
NEWARK, NEW JERSEY
973-645-2700


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