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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