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Source: US State of California

SAN FRANCISCO – Brooke Campbell Solis appeared today in U.S. Magistrate Court for arraignment and an initial federal court appearance on a criminal complaint charging her with wire fraud in connection with a scheme to embezzle funds from her former employer announced United States Attorney David L. Anderson and FBI Special Agent in Charge John F. Bennett.  She appeared before U.S. Magistrate Judge Virginia K. DeMarchi.

According to the complaint, Solis, 49, of Austin, Texas, is a licensed attorney.  From January 2018 until July 2019, Solis was the General Counsel and then Chief Business Officer of a financial technology company registered to do business in the State of California.  While employed with the technology company, Solis telecommuted from her home in Austin to her employer’s principal place of business in San Francisco. 

The complaint describes how Solis allegedly diverted funds from her employer and paid the diverted funds to shell companies and entities controlled by Solis and her husband.  For example, Solis controlled a shell company named The Paralegal Group LLC. The company was incorporated in Delaware and Solis was listed as the sole member.  Bank records and additional vendor records identify Solis as the person controlling The Paralegal Group.  The complaint alleges Solis submitted fraudulent invoices in the name of The Paralegal Group and then arranged for her employer to pay the invoices to the shell company.  According to the complaint, there is no evidence The Paralegal Group ever provided any services to Solis’s employer and certain records typically associated with running a true business do not exist for The Paralegal Group.

In another aspect of the embezzlement scheme, Solis used “super administrative privileges” to receive an illegitimate reimbursement payment from her employer.  The super administrative privileges had been granted by her employer to assist Solis to exercise her legitimate job responsibilities.  Nevertheless, Solis used the privileges to improperly submit and approve payment for expenses without review from other employees or executives working for the employer.  For example, in July of 2019, two days after Solis’s employment was terminated, she submitted a personal expense of $4,575 for “Jackson and Oliver boarding.”  In this example, Solis self-approved expenses for 61 days of dog boarding.  The criminal complaint explains that Solis used her access to her employer’s expense approval software even after her employment was terminated and, as of the signing of the complaint, no records for the boarding company could be found.

In sum, Solis is charged with two counts of wire fraud, in violation of 18 U.S.C. § 1343.

Solis pleaded not guilty.  Magistrate Judge DeMarchi ordered Solis released on a $150,000 bond and scheduled her next court appearance for October 22, 2020, at 10:30, for a preliminary examination.

A complaint merely alleges that crimes have been committed, and all defendants are presumed innocent until proven guilty beyond a reasonable doubt. If convicted, Solis faces a maximum statutory penalty of twenty years in prison for each count of wire fraud. The court also may order an additional term of supervised release, fines and restitution.  However, any sentence following conviction would be imposed by the court after consideration of the U.S. Sentencing Guidelines and the federal statute governing the imposition of a sentence, 18 U.S.C. § 3553. 

The case is being prosecuted by the Corporate Fraud Strike Force. The prosecution is the result of an investigation by the FBI.  

MIL OSI USA News