Plea Agreement/Factual Proffer Statement — No. 1:25-cr-20131 (Dkt. 52, S.D. Fla.)
Summary
A factual proffer by the United States and defendant Abel Humberto Perla Bonilla in Case No. 25-CR-20131-BECERRA, U.S. District Court for the Southern District of Florida, entered on the docket July 23, 2025 as Document 52. The parties agree the United States would have proven a violation of 18 U.S.C. § 1349, conspiracy to commit wire fraud, involving unemployment insurance claims to the California Employment Development Department. The proffer states that from in or around January 2021 through in or around May 2021, co-conspirators made counterfeit driver's licenses bearing the defendant's face, and the defendant took live selfie photographs to pass ID.me identity verification. It states the defendant verified 344 different fraudulent UI claims in 343 different victims' names and that the EDD paid out $4,863,694 onto debit cards controlled by co-conspirators.
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Cite this document
“Plea Agreement/Factual Proffer Statement — No. 1:25-cr-20131 (Dkt. 52, S.D. Fla.).”
Original at ecf.flsd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/plea-agreement-factual-proffer-statement-no-1-25-cr-20131-dkt-52-s-d-f-9fc786a6e8/
, SHA-256 d99e73b6690af64f9df380fe7755e0948e6c7074cc2792ad72e91066809cc65f.Full text
Case 1:25-cr-20131-JB Document 52 Entered on FLSD Docket 07/23/2025 Page 1 of 3
I
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 25-CR-20131-BECERRA
UNITED ST ATES OF AMERICA
v.
ABEL HUMBERTO PERLA BONILLA,
Defendant.
- - - -- - - - - -- -- - - - -- I
FACTUAL PROFFER
The United States of America and the defendant, Abel Humberto Perla Bonilla, agree that
had this case proceeded to trial, the United States would have proven, beyond a reasonable doubt,
the following facts, among others, pertaining to a violation of 18 U .S.C. § 1349 that occurred in the
Southern District of Florida and elsewhere.
Unemployment Insurance ("UI") was a joint state and federal program that provided
monetary benefits to eligible beneficiaries. UI payments were intended to provide temporary
financial assistance to lawful workers who were unemployed through no fault of their own.
Beginning in March 2020, in response to the COVID-19 pandemic, several federal programs
expanded UI eligibility and increased UI benefits, including the Pandemic Unemployment
Assistance Program, Federal Pandemic Unemployment Compensation Program, and the Lost
Wages Assistance Program. In the State of California, the Employment Development Department
(EDD), based in Sacramento, California, administered the UI program. Those seeking UI benefits
submitted online applications. In order to successfully file an unemployment claim with EDD, the
applicant had to pass an identity verification process with "ID.me" (www.id.me) by submitting the
applicant ' s personal information, a copy of the applicant's driver's license, and a selfie photograph
to ID.me for identity verification. Applicants also had to provide their name, Social Security
Case 1:25-cr-20131-JB Document 52 Entered on FLSD Docket 07/23/2025 Page 2 of 3
Number (S SN), and mailing address, among other things, and to self-certify that they met a COVID-
19-related reason for being unemployed, partially employed, or unable to work. The EDD relied
upon the information in the application to determine UI benefits eligibility. Once an application
was approved, the EDD typically distributed state and fed eral UI benefits electronically to a debit
card, which claimants could use to withdraw funds and /ormake purchases. These debit cards , which
were issued by Bank of America, were sent via the U .S. Postal Service to the address the claimant
provided. Claimants could activate their debit card via telephone or online.
From in or around January 2021 through in or around May 2021, the defendant agreed with
Zachary Kameron Ramyard and other co-conspirators to verify fraud ulent UI claims to the
California EDD on behalf of dozens of individuals without their authorization. In order to verify
the fraudulent applications with ID.me, the defendant 's co-conspirators created counterfeit driver's
licenses with victims' PII and the defendant's face on them. In turn, the defendant, in Miami-Dade
County, took live selfie photographs of himself to match the counterfeit driver's licenses. He did
so by clicking on ID.me links that co-conspirators messaged to a burner phone that the defendant
used throughout his involvement in the wire fraud conspiracy. The defendant 's live-selfie
verifications on ID.me caused the California EDD to accept those fraudulent claims, triggering
interstate wires to EDD and causing Bank of America to mail debit cards to Florida and California
addresses controlled by the defendant's co-conspirators. Once the defendant's co-conspirators
withdrew from the UI debit cards at A TMs, they paid the defendant a small portion of those proceeds
via Cash App .
In total, the defendant uploaded live selfie photographs of himself to verify 344 different
fraudulent UI claims in 343 different victims' names, the vast majority of which were successful.
The defendant's conduct resulted in the California EDD paying out $4,863,694 onto UI debit cards
controlled by the defendant's co-conspirators.
2
Case 1:25-cr-20131-JB Document 52 Entered on FLSD Docket 07/23/2025 Page 3 of 3
The above-detailed facts are corroborated by, among other things, witness interviews,
banking records, ID .me records, A 1M photographs, business records, and other evidence. The
information contained in this proffer is not a complete recitation of the facts and circumstances of
this case, but the parties agree it is sufficient to prove beyond a reasonable doubt a violation of 18
U.S.C. § 1349, conspiracy to commit wire fraud.
HAYDEN P. O'BYRNE
UNITED STA TES ATTORNEY
Date: {J ft ff / 1-. S By:
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ASSISTANT UNITED STA TES ATTORNEY
Date: V) }\1j W U By:
Date: Co { \Jj1,{)'2<5 By:
DEFENDANT
3
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