Criminal Complaint — No. 2:20-mj-05300 (Dkt. 1, D. Ariz.)

Summary

A criminal complaint filed December 14, 2020 in the U.S. District Court for the District of Arizona, No. 2:20-mj-05300, charging Celestine Strong, Ty'zhaun Lewis, Patrick Lewis and Jawuan Polk with conspiracy to commit wire fraud under 18 U.S.C. § 1349 between April 2020 and June 2020. It alleges Paycheck Protection Program loan applications claiming made-up wages and employees, supported by altered bank statements and Internal Revenue Service payroll records. The wire fraud counts under 18 U.S.C. § 1343 list wires to PayPal of $279,165, $300,000, $297,500 and $208,332 dated April 14, 2020 to June 6, 2020. Count 6 charges Strong under 18 U.S.C. § 1957 over a $30,000 cash withdrawal on May 6, 2020. Special Agent Byron Anderton of Homeland Security Investigations swore to the complaint before Magistrate Judge Deborah M. Fine.

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Case 2:20-mj-05300-DMF Document 1 Filed 12/14/20 Page 1 of 19

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA
UNITED STATES OF AMERICA CaseNo: OO- S BOOMS
v. CRIMINAL COMPLAINT

Celestine Strong (Counts 1,2 and 6),
Ty’zhaun Lewis (Counts 1,4),
Patrick Lewis (Counts 1,3); and
Jawuan Polk (Counts 1,5).

I, the undersigned complainant, being duly sworn, state that the following is true
and correct to the best of my knowledge and belief:

Count 1: Conspiracy, 18 U.S.C. § 1349

Between April 2020, through at least June of 2020, within the District of Arizona
and elsewhere, the defendants Celestine Strong, Ty’zhaun Lewis, Patrick Lewis, and
Jawuan Polk, and others known and unknown, did knowingly and willfully agree and
conspire with each other to commit wire fraud.

This conduct is in violation of Title 18, United States Code, § 1349.

Manner/Means of the Conspiracy/Scheme to Defraud

This scheme targeted financial institutions with the intention of defrauding these
institutions of funds in connection to the CARES Act Paycheck Protection Program by
providing material false loan applications claiming seemingly made up wages and
employees for business entities owned and operated by the co-conspirators. In furtherance
of the conspiracy and scheme to defraud, the co-conspirators submitted supporting loan

documents that were similar to one another, and sometimes contained the same

Case 2:20-mj-05300-DMF Document1 Filed 12/14/20 Page 2 of 19

information. These communications were all done by common Internet Protocol addresses
and fraudulently represented altered bank statements and Internal Revenue Service payroll
records. These representations were false and fraudulent. In reality, the co-conspirators
merely made these false and fraudulent representations with the intent to defraud solely to
obtain loan proceeds they were not entitled to.

Count 2 - 5: Wire Fraud, 18 U.S.C. § 1343

Between April 2020 and June 2020, in Maricopa County, in the District of Arizona,
Celestine Strong, Ty’zhaun Lewis, Patrick Lewis, and Jawuan Polk did knowingly and
willfully devise and intend to devise a scheme and artifice to defraud and obtain
money and property by means of materially false and fraudulent promises, pretenses
and representations, and concealment of material facts, in violation of Title 18, US.C.
§ 1343.

On or about the dates specified as to each count below, the defendants Celestine
Strong, Ty’zhaun Lewis, Patrick Lewis, and Jawuan Polk, for the purpose of executing the
aforesaid scheme and artifice, did knowingly transmit and cause to be transmitted, by

means of wire communications in interstate and foreign commerce, certain writings, signs,

signals, pictures and sounds, as more particularly described below.

Count Date Requestor / Originating IP Address | Receiving Server
Amount
2 04/14/2020 Celestine Strong 2600:8800:3880:8f8:: PayPal
$279,165 Phoenix, AZ Wilmington, DE

Conshohocken, PA
or Timonium, MD

3 05/20/2020 Patrick Lewis 173.44.244.196 ’ PayPal
$300,000 Phoenix, AZ Wilmington, DE
Conshohocken, PA


Case 2:20-mj-05300-DMF Document1 Filed 12/14/20 Page 3 of 19

or Timonium, MD

UT
4 05/26/2020 Ty’zhaun Lewis 173.44.244.196 PayPal
$297,500 Phoenix, AZ Wilmington, DE

Conshohocken, PA
or Timonium, MD

5 06/06/2020 Jawuan Polk 173.44.244.196 PayPal
$208,332 Phoenix, AZ Wilmington, DE
Conshohocken, PA
or Timonium, MD

This conduct is in violation of Title 18, U.S.C. § 1343.

Count 6: Transactional Money Laundering, 18 U.S.C. § 1957

On or about May 1, 2020, Strong received a wire in the amount of $279,165.00 into
her Wells Fargo checking account ending in 7989. The wire was initiated by WebBank,
-which utilized Zions Bancorporation wire services to facilitate the wire. This wire deposit
into Strong’s Wells Fargo checking account represents the proceeds of the PPP fraud
scheme described above.

On or about May 1, 2020, the balance in the account ending in 7989 was a negative
$18.70 and had just incurred two overdraft fees of $35.00 each.

On or about May 6, 2020, two cash withdrawals were made at two separate Wells
Fargo branch locations. The first cash withdrawal was in the amount of $30,000.00 and
was made at a branch located in Phoenix, AZ. The second cash withdrawal was in the
amount of $5,000.00 and was made at a branch located in Chandler, AZ.

On or about May 6, 2020, Strong made a cash purchase of the 2016 Mercedes. The
purchase price of the vehicle was $29,200.00. A form 8300 was filed by Mercedes Benz

of Gilbert reflecting the cash purchase by Strong of the 2016 Mercedes.

Case 2:20-mj-05300-DMF Document1 Filed 12/14/20 Page 4 of 19

On or about May 6, 2020, in the District of Arizona and elsewhere, Defendant
Strong knowingly engaged in a monetary transaction by withdrawing $30,000 in U.S.
currency from her checking account ending in 7989, within the United States by, through,
or to a financial institution, namely Wells F argo Bank, affecting interstate commerce, in
criminally derived property that was of a value greater than $10,000, such property having
been derived from wire fraud in violation of Title 18, U.S.C. § 1343.

This conduct is in violation of Title 18, U.S.C. § 1957.
I further state that I am a Special Agent with the Homeland Security Investigations
and this complaint is based on the following facts:

See Attached Statement of Probable Cause Incorporated By Reference Herein.
Continued on the attached sheet and made a part hereof: KlYes TINo

AUTHORIZED BY: Kevin Rapp, AUSA

Digitally signed by BYRON W

Special Agent Byron Anderton BYRON W ANDERTON Date: 2020.12.14 09:26:42 -07'00"
Name of Complainant Signature of Complainant

worn to telephonically

W2U, A ooo @ ?-- 3S p WL at Phoenix, Arizona

Date Ci d State

(i
United States Magistrate Judge ah Us
HONORABLE DEBORAH M. FINE Signature of Judicial Officer

Case 2:20-mj-05300-DMF Document1 Filed 12/14/20 Page 5 of 19

STATEMENT OF PROBABLE CAUSE
I, Byron Anderton, being first duly sworn, hereby depose and state as follows:
I. Affiant’s Background

1. I am a Special Agent with U.S. Immigration and Customs Enforcement
(“ICE”) Homeland Security Investigations (“HSI”) currently serving in the Phoenix Field
Office, Financial Crimes Unit. I have been employed as a federal agent for over fifteen:
(15) years. I have conducted numerous criminal investigations involving violations of
Immigration and Customs law committed against the United States, such Pe financial
crimes, weapons violations, narcotics violations, document and benefit fraud, and human
smuggling. Recently, I have been assigned to work with other law enforcement partners to
investigate possible fraud associated with the stimulus and economic assistance programs
created by the federal government in response to the COVID-19 pandemic.

Il. Purpose of Affidavit

2. This affidavit is made in support of a criminal complaint charging Celestine
Strong, Ty’ zhaun Lewis, Patrick Lewis, and Jawuan Polk with 18, U. S. C. § 1343 (Wire
Fraud) and 18, U.S.C. 1349 (Conspiracy), and Strong with a violation of 18 U.S.C. §1957
(Transactional Money Laundering).

3. This affidavit is based on my personal investigation and investigation by
others, including federal and local law enforcement officials whom I know to be reliable
and trustworthy. The facts contained herein have been obtained by interviewing witnesses

and examining documents obtained in the course of the investigation as well as through

Case 2:20-mj-05300-DMF Document1 Filed 12/14/20 Page 6 of 19

other means. This affidavit does not include every fact known to me about this
" investigation, but rather only those facts sufficient to establish probable cause.
, III. Background Information and Summary of Criminal Activity

4. OnMarch 27, 2020, the U.S. President signed a $2 trillion stimulus bill called
the CARES Act, which was intended to ameliorate the economic impact of the COVID-19
Pandemic. See Pub. L. 116-136. The CARES legislation authorized up to $349 billion in
forgivable loans to small businesses to pay their employees during the pandemic. On or
around April 2020, Congress authorized up to $310 billion of additional funding. See Pub.
L. 116-139. This loan program is known as the Paycheck Protection Program (“PPP”) and
is administered by the U.S. Small Business Administration (“SBA”), a federal government
agency headquartered at 409 3" Street, SW, Washington, D.C. 20416. See 13 C.F.R. Part
120. The PPP provides small businesses with funds to pay up to eight weeks of payroll
costs, including benefits. Funds can also be used to pay interest on mortgages, rent, and
utilities. The SBA provides funds in the form of loans that may be fully forgiven if used
for payroll costs, interest on mortgages, rent, and utilities (the program requires that at least
75% of the loan amount be used for payroll costs to be considered for forgiveness). Under
the PPP, the maximum loan amount for which an applicant may apply is the lesser of $10
million or an amount based upon a payroll-based formula specified in the CARES Act.

5. Small businesses and sole proprietorships have applied for PPP relief through
one of over 4,900 SBA designated lending institutions. To apply, applicants must complete
and transmit to the lender an SBA Form 2483, which requires the applicant to identify the

entity’s average monthly payroll, as calculated according to the requirements of the

Case 2:20-mj-05300-DMF Document1 Filed 12/14/20 Page 7 of 19

CARES Act.

6. Once a borrower provides their application to a lender, the lender underwrites
the loan and transmits the application to the SBA via an electronic platform known as
ETRAN. Before a lender submits a PPP loan through ETRAN, the lender must have
collected the information and certifications set forth in the SBA Form 2483. Loans
guaranteed under the PPP will be 100% guaranteed by the SBA, and the full principal
amount-of the loans may qualify for loan forgiveness.

7. An Internet Protocol Address (“IP Address”) is an address on in which
computers communicate over the internet, similar to that of a street address on your
house. There are two (2) types of IP addresses currently in use, IP address version 4
(“IPv4”)and IP address version 6 (“IPv6”).

a. IPv4 is made up of four numbers (referred to as ‘octets’) separated by the
“period” character. An example of this is 72.200.20.169. Due to the
number of devices on the Internet today, IPv4 was running out of numbers,
so IPv6 addresses were implemented.

b. IPv6 is made up of 8 “chunks” of alpha-numeric values (referred to
‘hextets’) and are separated by the “colon” character. An example of this is
2600:8807:7f£02:0:98f9:68de:f4e4:b618. Unlike IPv4 addresses, there are
plenty of IP addresses that can be assigned and we won’t run out. Because
of this amount, and software/hardware limitations of the Internet, the most
common scenario is for a Internet Service Provider “ISP”, like AT&T or

Cox Communications, is to assign a large amount of IPv6 addresses to one

Case 2:20-mj-05300-DMF Document1 Filed 12/14/20 Page 8 of 19

subscriber. Specially, according to the Regional Internet Registries
providing Internet resource allocations, it is common for ISPs to assign one
half of an IPv6 address (the first 3 or 4 “chunks” or “hextet”) to a specific
subscriber. Meaning, the last 4 “chunks/hextets” don’t matter. This means
that the same subscriber is usually assigned IPv6
2600:8807:7f02:0:98f9:68de:f4e4:b618 and
2600:8807:7f02:0:585F:68de:f4e4:A23.

A. PAYCHECK PROTECTION PROGRAM (PPP) LOAN APPLICATIONS

“Transitions Studio and Spa”

8. WebBank is a Federal Deposit Insurance Corporation (FDIC) financial
institution and is the lender for PayPal Working Capital and PayPal Business Loans.
PayPal has servers for servicing their customers PPP loan applications, located in
Wilmington, DE, Conshohocken, PA, and Timonium, MD. WebBank participates in the
SBA’s PPP loan program as an SBA Preferred Lender. WebBank provided me an SBA
Form 2483 (“the application”) submitted on or about April 14, 2020 and bearing the
signature of Strong; as referenced in Count 2 in the table above. The application sought a
PPP loan for an LLC identified as Transitions Studio and Spa located at 7037 E. 1* Ave.
Scottsdale, AZ. The application identified Strong as owning 100% of the LLC. Strong
listed her address as 2618 W. Spencer Run, Phoenix, AZ 85041. According to the Arizona
Corporation Commission, Transitions Studio and Spa was formed / registered on or about
April 27, 2020 and lists T. Lewis as the statutory agent and T.V. as the manager. In order

to support a PPP loan in the amount of $279,165.00, the application represented that the

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LLC, Transitions Studio and Spa has an average monthly payroll of $111,666.00 and 20
employees.

9, The following information is in support of Count 2 listed above. On or about
May 1, 2020, WebBank, utilizing the wire services of Zions Bancorporation, wired
$279,165.00 to Wells Fargo account 7989. Account 7989 is a personal checking account
in the name Celestine Strong with a mailing address listed as 2618 W. Spencer Run,
Phoenix, AZ 95041.

10. Onor about May 5, 2020, Strong made a withdrawal of $65,010.00 utilizing
the purchase of a bank check.

11. Onor about May 6, 2020, Strong made a withdrawal of $11,310.90 utilizing
the purchase of a bank check.

12. The following information is in support of Count 6 listed above. On or about
May 6, 2020, Strong made a cash withdrawal of $30,000.00 ata Wells Fargo branch located
in Phoenix, AZ.

13. On or about May 6, 2020, Strong made a cash withdrawal of $5,000.00 at a
Wells Fargo branch located in Chandler, AZ.

14. On or about May 6, 2020, Strong made a cash purchase of the 2016
Mercedes. The purchase price of the vehicle was $29,200.00. A form 8300 was filed by
Mercedes Benz of Gilbert reflecting the cash purchase by Strong of the 2016 Mercedes.

15. A review of Strong’s Wells Fargo account ending in 7989 showed no

additional deposits beyond the $279,185.00 made on May 1, 2020.

- Case 2:20-mj-05300-DMF Document1 Filed 12/14/20 Page 10 of 19

16. The funds Strong used to purchase the 2016 Mercedes are traceable to the
PPP fraud scheme described above.

17. Onor about May 7, 2020, Strong made a withdrawal of $17,010.00 utilizing
the purchase of a bank check.

18. According to IRS records, Transitions Studio and Spa LLC was issued an
.Employer Identification Number (“EIN”) in December 2011. Contrary to what Strong
provided on her PPP loan application purporting an average monthly payroll of
$111,660.00 with 20 employees, IRS records did not have any Form 941 Employer’s
Quarterly Federal Tax Return on file under Transitions Studio and Spa LLC’s EIN 45- -
4096434. The Form 941 is used by employers to report the employer and employee share
of social security tax and Medicare tax, withheld federal income tax, and, if applicable,
withheld Additional Medicare tax.

19. |WebBank has provided several documents it received in support of the
Transitions Studio and Spa LLC PPP loan application. A review of those documents and
records obtained from the IRS, demonstrate that several of the documents provided to
WebBank in support of the PPP loan application were falsified and/or included false
statements about Transitions Studio and Spa LLC’s operations:

a. The applicant submitted JP Morgan Chase bank statements for account 1483
in the name Celestine Strong/Transitions Studio and Spa LLC. The
statements appear to be altered with formatting not consistent with legitimate

JP Morgan Chase bank statements.

b. A review of withdrawals on the bank statements show inaccurate totals, for

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Case 2:20-mj-05300-DMF Document1 Filed 12/14/20 Page 11 of 19

example:

| 25-Jan:Online Payment Vendor | $29,250.00 !

(Accurate Sum total is $64,025.68)

c. A review of the Checking Summary section of the statement shows
inconsistencies with checks paid. For example:

e Checks paid for the month of January in the Check Summary, lists 2
checks. In the transactions section of the statement, 3 checks are
listed. In addition, the check numbers have been omitted in the
statements.

d. According to JP Morgan Chase, there is no record of account 1483 in the
name Celestine Strong/Transitions Studio and Spa LLC at their bank.

e. A review of the payroll verification documents provided by Strong, show no
change in payroll expense to include tips and no employee turnover. The
monthly payroll expenditure is $109,084.00 each month over a one-year
period. This amount is not consistent with the loan applications Form 2483,
which lists monthly payroll expenditures as $111,666.00.

f. The application submitted a spreadsheet document, which purported to show
totals of payroll expenditures and tax payments for Transitions Studio and
Spa LLC employees between approximately January 1, 2019, through

December 31, 2019. This document claimed the business had 17 employees;

il

Case 2:20-mj-05300-DMF Document1 Filed 12/14/20 Page 12 of 19

however, the Form 2483 for the loan application lists 20 employees. None
of the employees listed on these files appear to be affiliated with this business
or receiving payroll for Transitions Studio and Spa LLC.

20. A physical site check of the business address for Transitions Studio and Spa
located at 7037 E. 1°' Ave. Scottsdale, AZ 85251, does not list a business matching the
name Transitions Studio and Spa.

21. Areview of the Department of Economic Security (DES) payroll records
for both Strong and Transitions Studio and Spa LLC revealed no records/wages for
Strong or Transitions Studio and Spa.

22.  Strong’s signed Form 2438 Paycheck Protection Program_Borrow
Application Form electronically on April 26, 2020 using DocuSign technologies. As part
of the application, Strong certified by initialing next to an item which read “The Applicant
was in operation on February 15, 2020 and had employees for whom it paid salaries and
payroll taxes or paid independent contracts, as reported on Form (s) 1099-MISC.” Strong
also initialed next to a certification which read, “I further certify that the information
provided in this application and the information provided in all supporting documents and
forms is true and accurate in all material respects. I understand that knowingly making a
false statement to obtain a guaranteed loan from SBA is punishable under the law,
including 18 USC 1001 and 3571 by imprisonment of not more than five years and/or a
fine of up to $250,000.00; under 15 USC 645 by imprisonment of not more than two years
and/or a fine of not more than $5,000.00; and, if submitted to a federal insured institution,

under 18 USC 1014 by imprisonment of not more than thirty years and/or a fine of not

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Case 2:20-mj-05300-DMF Document1 Filed 12/14/20 Page 13 of 19

more than $1,000,000.00..”
“NSIDECONNEX, LLC”

23. The following information is in support of Count 3 of the Complaint. The
investigation determined that between May 12, 2020 and June 20, 2020, P. Lewis applied
for 6 PPP loans with WebBank through PayPal totaling $1,767,920.00. The business loans
were for a logistics trucking company under the name NSIDECONNEX LLC. The
“Business Tax Id Number” listed on the application for the business was shown as “5819.”
IRS records showed the EIN for NSIDECONNEX LLC was 85-1015819 and was issued

in May 2020.

24. The following table outlines PPP loan applications submitted by P. Lewis

for NSIDECONNEX LLC.
‘Date/Time IP Address == RequestedLoan Amount
05/23/2020 at 8:18 a 38.131.113.188 { $297,500
06/15/2020 at 6:57 p|2600:8800:3880:d25:: { $300,000
06/20/2020 at 6:33 a/98.186.221.166 $297,710

25. In support of the PPP loan applications, P. Lewis provided documents that
appeared to be fictitious or were inconsistent with official records kept by financial
institutions, to include:

a. According to the Arizona Corporation Commission, NSIDE CONNEX LLC
was formed/registered on or about May 15, 2020 and lists P. Lewis as the

statutory agent and manager.

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Case 2:20-mj-05300-DMF Document1 Filed 12/14/20 Page 14 of 19

b. Payroll documents for one of the loans showed inconsistencies with regard

to the number of employees listed for the business. An undated document
lists 8 employees, the Form 941 submitted lists 17 employees, and the loan
application lists 10 employees.

. An Excel Spreadsheet was used to provide substantiation of
NSIDECONNEX LLC’s alleged payroll. Of the spreadsheets submitted on
the loans outlined above, 5 were authored by a creator “bitchmode” with the
other being created by author “highly favored.” By default, a spreadsheet’s
author is the username of the individual who created the spreadsheet. In
addition, 3 of the spreadsheets were created on April 13, 2020 at 1:30 pm,
with the other 3 having been created on May 19, 2020 at “16:52.” This same
author and modified by combination was also used on loans submitted for
business entities Flav or Flatline LLC and TL Solutions and Services.

. P. Lewis provided a picture of the first page of a Form 941 ‘in support of a
PPP loan applied for on May 23, 2020. Line 1 on the form listed 17
employees with total wages January, February, and March 2020 of
$109,080.00. The top portion of the form was filled out by hand in blue ink
and contained the EIN 85-1015918, which contained two numbers that
appeared to have been transposed. The correct EIN for NSIDECONNEX
LLC was 85-1015819.

. A picture of the first page of a Form 941 was provided by P. Lewis in support

of a PPP loan applied for on June 20, 2020. This form appeared to be similar

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Case 2:20-mj-05300-DMF Document1 Filed 12/14/20 Page 15 of 19

to a previous submission conducted by P. Lewis, but the top of the form
contained white out over the year 2020, with a change to 2019.

f. IRS Records did not show or reflect any Form 941 having been filed under
NSIDECONNEX LLC’s EIN.

g. No records with USDOT were located with regard to P. Lewis and NSIDE
CONNEX LLC. :

h. Due to the inconsistencies, all 6 loans were declined by WebBank.

“TL Solutions and Services”

26. The following information is in support Count 4 of the Complaint. The
investigation determined that between May 25, 2020 and June 6, 2020, T. Lewis applied
for 4 PPP loans with WebBank through PayPal totaling $1,057,500.00. The loans were for
a business listed as TL SOLUTIONS AND SERVICES LLC. The “Business Tax Id
Number” listed on the application for the business was shown as “9593.” IRS Records
showed the EIN for TL SOLUTIONS AND SERVICE LLC was 81-2649593 and was
assigned in May 2016. IRS Records also do not show or reflect any Form 941 having been

filed by TL SOLUTIONS AND SERVICES LLC.

Date/Time = IP Address_ = Requested Loan Amount __
05/25/2020 at 12:32 am 2600:8800:3880:60b:: $162,500
05/26/2020 at 8:568 pm ——173.44.244.196 — $297,500
06/04/2020 at 12:39 am: 2600:387:8:9:93 $297,500
06/06/2020 at5:52am =—«'173.44.244.196 $300,000

$1,057,500

27. According to the Arizona Corporation Commission, TL SOLUTIONS AND

SERVICES was formed / registered on or about May 22, 2020 and lists T. Lewis as the

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Case 2:20-mj-05300-DMF Document1 Filed 12/14/20 Page 16 of 19

statutory agent, member, and manager. On the loan application, T. Lewis listed his address

as 2618 W. Spencer Run, Phoenix, AZ 85041. 2618 W. Spencer Run, Phoenix, AZ 85041

is the same address listed for Strong on her PPP loan application for Transitions Studio and

Spa.

28.

As part of his PPP loan applications, T. Lewis provided the following

documents that contained irregularities and inconsistencies:

T. Lewis has an Arizona Driver License (D08600171) with a listed address
as 2618 W. Spencer Run, Phoenix, AZ 85041.

As part of his PPP loan application, T. Lewis submitted altered JP Morgan
Chase bank statements for account 8798.

T. Lewis provided statements titled “Chase Business Checking”, however
the format of the statements was JP Morgan Chase personal checking format.
T. Lewis’ name is listed as the account holder and the business name is not
listed on the statements.

The font used on the “Chase Business Checking” is not consistent with font

used by JP Morgan Chase business checking accounts.

JP Morgan Chase confirmed that account 8798 is for a Chase College

Checking account and not a Chase Business Checking account.

_n. Payroll register spreadsheets were similar to that provided for loans

submitted by Strong, P. Lewis, and Polk. The author and modified by names

listed on the spreadsheet was also shown as “bitchmode.”

o. Due to the inconsistencies, the loan was declined.

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Case 2:20-mj-05300-DMF Document1 Filed 12/14/20 Page 17 of 19

“FLAV OR FLATLINE ENTERTAINMENT LLC”

29. The following information is in support of Count 5 of the Complaint. The
investigation determined that between June 06, 2020 and June 25, 2020, Polk applied for
5 PPP loans with WebBank through PayPal totaling $1,374,172.00. The business loans
were for an entertainment company operating under the name FLAV OR FLATLINE
ENTERTAINMENT, LLC. According to the Oregon Secretary of State Corporation
Division, FLAV OR FLATLINE ENTERTAINMENT LLC was formed / registered on or
about November 01, 2019 and lists Polk as the registered agent and member. The EIN

listed for the business was 84-3557805 and was issued by the IRS in November 2019.

‘Date/Time IP Address === RequestedloanAmount =
i 06/ 25/ 2020 at 8:15 aij 98.186.224.144 5 $297,710

a. On or about June 30, 2020, WebBank, utilizing the wire services of Zions

Bancorporation, wired $208,332.00 to NBKC bank account 3521. Account
3521 is a business checking account in the business name FLAV OR
FLATLINE ENTERTAINMENT LLC with a mailing address listed as 73
NE Cook St. Portland, OR 97212. Polk is listed as the owner on the
account and has signatory authority.

30. As part of the aforementioned loan application, Polk provided the following

documents that contained inconsistencies and irregularities:

b. On SBA Form 2483 Paycheck Protection Program Borrower Application

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Form signed by POLK on June 27, 2020, he listed an average monthly
payroll of $83,333.00 for 10 employees. Polk provided a spreadsheet
reflecting payroll expenditures of $119,084.00 a month.
c. A picture of a bank statement from NBKC Bank for account number
9223521, The business name, address, and account number appeared to be
altered on the picture taken of the statement.
‘d. The spreadsheet provided by Polk to substantiate the payroll for Flav or
Flatline Entertainment LLC was consistent with those having been submitted
by Strong, P. Lewis, and T. Lewis. The author listed on the spreadsheet was
shown as “bitchmode.”
_B. Further Investigation of IP Address
31. Internet Protocol (IP) Address 2600:8800:3880:d25:: and 173.44.244.196
referenced above were both used to apply for loans by P. Lewis, T. Lewis, and Polk.
32. IP Address 2600:8800:3880:8f8:: was used by Strong to submit her
application and is consistent with IPv6 IP address 2600:8800:3880:d25:: used by Polk, P.
| Lewis, and T. Lewis. The Internet Service Provider for both IP addresses is Cox
Communications. Please reference IPv6 guidelines as outlined in Paragraph 4(b) above.
IV. Conclusion
33. Based on my training and experience, and the information provided in this
affidavit, I respectfully submit that there is probable cause to believe that beginning on a
date unknown, but from at least in or around April 2020, to June 2020, within the District

of Arizona, Celestine Strong, Ty’zhaun Lewis, Patrick Lewis, and Jawuan Polk committed

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Case 2:20-mj-05300-DMF Document 1. Filed 12/14/20 Page 19 of 19

violations of 18, U.S.C. § 1343 (Wire Fraud), 18, U.S.C. 1349 (Conspiracy), and Strong

with a violation of 18 U.S.C. §1957 (Transactional Money Laundering).

I declare under penalty of perjury that the statements above are true and correct to

the best of my knowledge and belief.

BYRON W Digitally signed by BYRON W
ANDERTON

ANDERTON Date: 2020.12.14 09:27:44 -07°00"

Special Agent Byron Anderton

Homeland Security Investigations

Sworn to and subscribed before me this fea of December, 2020. @ xX 33 Yon

H Left. DEBORAH M. FINE
United States Magistrate Judge

19

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SHA-256

c9acaeb594ca3cdaae0a46e6228ba37a410f4ff8c4297f4af1d51602c508e713

Our copy

1-criminal-complaint-2-20-mj-05300-dmf-strong-et-al-filed-12-1.pdf