SECOND SUPERSEDING INDICTMENT as to Carla Jackson (5) count(s) 46ss-47ss, Ricky Dixon… — USA v. Thomas et al (Dkt. 290)

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U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 290 · 2021-08-10 · Docket on CourtListener

Summary

Second Superseding Indictment in United States v. Ricky Dixon et al., No. 1:20-CR-296, filed August 10, 2021 as Document 290 in the U.S. District Court for the Northern District of Georgia. The defendants include Ricky Dixon, Meghan Thomas, Jesika Blakely, Teldrin Foster, Amanda Christian and Carla Jackson. The grand jury alleges that defendants submitted, or assisted in submitting, PPP loan applications for listed businesses, such as one for Bellator Phront Group Inc. dated April 21, 2020 reporting average monthly payroll of $319,982.14 and 66 employees. It alleges the applications included falsified IRS Form 941s for each quarter of 2019. The 82-page indictment closes with forfeiture allegations covering currency, vehicles and jewelry and the signature block of Acting United States Attorney Kurt R. Erskine.

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ORIGINAL
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IN THE UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF GEORGIA ~ P We ~r
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ATLANTA DIVISION
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UNITED STATES OF AMERICA
v.
Criminal Indictment
RICKY DIXON,
No. 1:20-CR-296
MEGHAN THOMAS,
JESIKA BLAKELY,
TELDRIN FOSTER,
Second Superseding
AMANDA CHRISTIAN,
Indictment
DwAN ASH0NG A/K/A DwAN GILPIN,
JOHN GAINES A/K/A MARTY GAINES,
CHARLES PETTY A/K/A CHARLES KNIGHT,
JERRY BAPTISTE,
CARLA JACKSON,
DEREK PARKER,
DAVID BELGRAvE II,
CHARLES HILL IV,
RYAN WHITTLEY,
EL HADJ SALL, AND
RICK MCDuFFIE
THE GRAND JURY CHARGES THAT:
Background
At all times relevant to this First Superseding Indictment:
The Defendants and Their Co-Conspirators
1.
RICKY DIXON (“DIXON”) was an individual residing in the State of
Michigan who claimed ownership of RK Painting Co., a Michigan corporation.
2.
MEGHAN THOMAS was an individual residing in the State of Georgia
who was associated with Bellator Phront Group Inc. and Elite Executive Services
Inc., which were Georgia corporations.
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3.
JEsIKA BLAKELY (“BLAKELY”) was an individual residing in the State
of Georgia.
4.
TELDR1N FosTER (“FosTER”) was an individual residing in the State
of Georgia.
5.
AMANDA CHRIsTIAN (“CHRIsTIAN”) was an individual residing in the
State of South Carolina who claimed ownership of Advertising and Then Some
Inc., a South Carolina corporation.
6.
DwAN ASHONG A/K/A DwAN GILPIN (“AsHoNG”) was an individual
residing in the State of Florida who claimed ownership of Richland Property
Investors Group LLC, a Florida corporation, and DA Gilpen Enterprises LLC, a
Florida corporation.
7.
JOHN GAINES A/K/A MARTY GAINES (“JoHN GAINES”) was an
individual residing in the State of Georgia.
8.
CHARLES PErry A/K/A CHARLES KNIGHT (“PErn”) was an
individual residing in the State of Georgia.
9.
JERRY BAPTISTE (“BAPTISTE”) was an individual residing in the State
of California.
10.
CARLA JACKSON (“JACKsoN”) was an individual residing in the State
of Georgia who claimed ownership of Management Resource Services Inc., a
Georgia corporation.
11.
DEREK PARKER (“PARKER”) was an individual residing in the State of
Michigan who claimed ownership of D Parker Holdings Inc., a Michigan
corporation.
2
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12.
DAvID BELGRAvE II (“BELGRAvE”) was an individual residing in the
State of South Carolina who claimed ownership of Continuing Success Inc., a
South Carolina corporation.
13.
CHARLES HILL IV (“HILL”) was an individual residing in the State of
Georgia who claimed ownership of Infinite Education Services Inc., a Georgia
corporation.
14.
RYAN WHITFLEY (“WHITTLEY”) was an individual residing in the
State of Illinois who claimed ownership of ML Exotic Customs Inc., an Illinois
corporation.
15.
EL HADJ SALL (“SALL”) was an individual residing in the State of
Florida who claimed ownership of Bellevie Corp., a Florida corporation.
16.
RIcK McDuFFIE (“McDuFFIE”) was an individual residing in the
State of South Carolina who claimed ownership of Mickies Auto and Tires LLC,
a South Carolina corporation.
17.
Darrell Thomas was an individual residing in the State of Georgia
who claimed ownership, and was the Chief Financial Officer, of Bellator Phront
Group Inc. As of May 21, 2020, Darrell Thomas claimed to be the Chief
Executive Officer, Secretary, and registered agent of Elite Executive Services Inc.
18.
Denesseria Slaton was an individual residing in the State of Georgia.
19.
Bern Benoit was an individual residing in the State of California who
claimed ownership of Transportation Management Services Inc., a Minnesota
corporation.
20.
Kahlil Gibran Green, Sr. was an individual residing in the State of
Ohio who claimed ownership of Impact Creations LLC, an Ohio corporation.
3
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21.
Charmaine Reddirig was an individual residing in the State of
Michigan who claimed ownership of All Star Room and Board Services of
Michigan Inc., a Michigan corporation.
The Small Business Administration
22.
The United States Small Business Administration (“SBA”) was an
executive branch agency of the United States government that provided support
to entrepreneurs and small businesses. The mission of the SBA was to maintain
and strengthen the nation’s economy by enabling the establishment and viability
of small businesses and by assisting in the economic recovery of commuiiities
after disasters.
23.
As part of this effort, the SBA enabled and provided for loans
through banks, credit unions, and other lenders. These loans had government-
backed guarantees.
The Paycheck Protection Program
24.
The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act
was a federal law enacted in or about March 2020 that was designed to provide
emergency financial assistance to the millions of Americans who are suffering
the economic effects caused by the COVID-19 pandemic.
25.
One source of relief that the CARES Act provided was the
authorization of up to $349 billion in forgivable loans to small businesses for
payroll, mortgage interest, rent/lease, and utilities, through a program referred
to as the Paycheck Protection Program (“PPP”). Congress has since authorized
additional PPP funding.
4
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26.
The PPP allowed qualifying small businesses and other
organizations to receive PPP loans. Businesses must use PPP loan proceeds for
payroll costs, interest on mortgages, rent, and utilities. The PPP allowed the
interest and principal on the PPP loan to be entirely forgiven if the business spent
the loan proceeds on these expense items within a designated period of time and
used a certain percentage of the PPP loan proceeds for payroll expenses.
27.
The amount of a PPP loan that a small business may have been
entitled to receive was determined by the number of employees employed by the
business and the business’s average monthly payroll costs.
28.
In order to obtain a PPP loan, a qualifying business was required 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
make certain affirmative certifications in order to be eligible to obtain the PPP
loan. In the PPP loan application, the small business (through its authorized
representative) had to 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 small business was eligible to receive under the PPP. In
addition, businesses applying for a PPP loan had to provide documentation
showing their payroll expenses.
29.
The SBA oversaw the PPP. However, individual PPP loans were
issued by private, approved lenders who received and processed PPP
applications and supporting documentation, and then made loans using the
lenders’ own funds, which were 100% guaranteed by the SBA. Data from the
5
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application, including information about the borrower, the total amount of the
loan, and the listed number of employees, was transmitted by the lender to the
SBA in the course of processing the loan.
Relevant Financial Institutions and Affiliates
30.
Financial Institution 1 was a Federal Deposit Insurance Corporation
(“FDIC”) insuied financial institution headquartered in Fort Lee, New Jersey.
Financial Institution 1 participated in the SBA’s PPP as a lender, and, as such,
was authorized to lend funds to eligible borrowers under the terms of the PPP.
31.
Financial Institution 2 was an FDIC-insured financial institution
headquartered in Salt Lake City, Utah. Financial Institution 2 participated in the
SBA’s PPP as a lender, and, as such, was authorized to lend funds to eligible
borrowers under the terms of the PPP.
32.
Financial Institution 3 was an FDIC-insured financial institution
headquartered in Phoenixville, Pennsylvania. Financial Institution 3 participated
in the SBA’s PPP as a lender, and, as such, was authorized to lend funds to
eligible borrowers under the terms of the PPP.
33.
Financial Institution 4 was a non-bank financial institution
headquartered in Lagtina Hills, California. Financial Institution 4 participated in
the SBA’s PPP as a lender, and, as such, was authorized to lend funds to eligible
borrowers under the terms of the PPP.
34.
Financial Institution 5 was a non-bank financial institution
headquartered in San Diego, California. Financial Institution 5 participated in
the SBA’s PPP as a lender, and, as such, was authorized to lend funds to eligible
borrowers under the terms of the PPP.
6
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35.
Company 1 was a publicly traded company that specialized in
small-business lending. Company 1 was based in Redwood City, California.
Company 1 participated in the SBA’s PPP by, among other things, acting as a
service provider between small businesses and certain banks, including Financial
Institution 1 and Financial Institution 2. Small businesses seeking PPP loans
could apply through Company 1 for PPP loans. Company 1 would review the
loan applications. If a loan application received by Company 1 was approved for
funding, a partner bank, such as Financial Institution 1 or Financial Institution 2,
disbursed the loan funds to the applicant.
36.
Bank 1 was an FDIC-insured financial institution based in New
York, New York with branches throughout the United States.
37.
Bank 2 was an FDIC-insured financial institution based in
Cincinnati, Ohio with branches throughout the United States.
38.
Bank 3 was an FDIC-insured financial institution based in
Pittsburgh, Pennsylvania with branches throughout the United States.
39.
Bank 4 was an FDIC-insured financial institution based in Charlotte,
North Carolina with branches throughout the United States.
40.
Bank 5 was an FDIC-insured financial institution based in San
Francisco, California with branches throughout the United States.
41.
Bank 6 was an FDIC-insured financial institution based in
Birmingham, Alabama with branches throughout the United States.
42.
Bank 7 was an FDIC-insured financial institution based in Dallas,
Texas with branches throughout the United States.
7
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43.
Bank 8 was an FDIC-insured financial institution based in Sioux
Falls, South Dakota with branches throughout the United States.
44.
Bank 9 was an FDIC-insured financial institution based in Gulfport,
Mississippi with branches throughout the United States.
45.
Bank 10 was an FDIC-insured financial institution based in McLean,
Virginia with branches throughout the United States.
46.
Bank 11 was an FDIC-insured financial institution based in
Charlotte, North Carolina with branches throughout the United States.
47.
Bank 12 was a credit union based in Auburn Hills, Michigan with
branches throughout the United States.
48.
Bank 13 was an FDIC-insured financial institution based in Deland,
Florida with branches throughout Florida.
49.
Bank 14 was an FDIC-insured financial institution based in Tupelo,
Mississippi with branches throughout the United States.
50.
Bank 15 was an FDIC-insured financial institution based in Chicago,
Illinois with branches throughout the United States.
51.
Bank 16 was an FDIC-insured financial institution based in Ann
Arbor, Michigan with branches throughout Michigan.
52.
Bank 17 was an FDIC-insured financial institution based in Cherry
Hill, New Jersey with branches throughout the United States.
The Fraudulent PPP Loan Applications and Supporting Documentation
53.
On or about the dates listed below, the defendants identified below
submitted, or assisted in the submission of, a PPP loan application for the
businesses identified below with the reported average monthly payroll and
8
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number of employees listed below, to a lender approved by the SBA to issue PPP
loans:
Defendants
Business
Date Signed
Avg.
Employees
Lender
(on or about)
Monthly
Fin. Inst.
Payroll
(“Fl”)
MEGHAN THOMAS,
Beilator Phront
April 21, 2020
$319,982.14
66
Fl 4
FOSTER
Group Inc.
BLAKELY,
Impact Creations
May 17, 2020
$332,000
67
Fl 1
FoSTER
LLC
BLAKELY,
Gaines
May 18, 2020
$322,684
69
Fl 1
FOSTER,
Reservation and
JoHN GAINES
Travel
FOSTER,
Transportation
May 20, 2020
$332,167
66
Fl 1
CHRISTIAN,
Management
PErry,
Services Inc.
BAPTIsTE
DIXON,
Lee Operations
May 20, 2020
$322,325.20
63
Fl 2
FOSTER
LLC
DIxoN,
RK Painting Co.
May 15, 2020
$320,000
66
Fl 3
BLAKELY,
FOSTER
DIxoN,
D Parker
June 12, 2020
$327,241
65
Fl 4
FOSTER,
Holdings Inc.
PARKER,
MEd-IAN THOMAS,
Continuing
June 12, 2020
$299,250
63
Fl 3
FOSTER,
Success Inc.
CHRISTIAN,
BELGRAvE
DIXON,
All Star Room &
June 11, 2020
$295,186.25
59
Fl 4
FOSTER
Board Services of
Michigan Inc.
MEGHAN THOMAS,
Infinite Education
July 11, 2020
$341,992
66
Fl 5
BLAKELY,
Services Inc.
FOSTER,
CHRISTIAN,
HILL
DIXON,
ML Exotic
June 19, 2020
$318,909.83
65
Fl 5
FOSTER,
Customs Inc.
WHITPLEY
FOSTER,
Bellevie Corp.
June 26, 2020
$329,434
60
Fl 5
ASHONG,
SALL
FOSTER,
Advertising and
June 26, 2020
$304,038
65
Fl 5
CHRISTIAN
Then Some Inc.
9
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• FOSTER,
Mickies Auto and
August 10, 2020
$314,864
67
Fl 5
CHRISTIAN,
Tires LLC
McDuFn~
54.
Each PPP Borrower Application Form was electronically signed on
or about the dates listed above.
55.
In addition, the loan applications contained the respective initials of
each purported business owner to certify each of the following representations:
a.
The Applicant business was in operation on February 15, 2020
and had employees for whom it paid salaries and payroll
taxes or paid independent contractors, as reported on Form(s)
1099-MISC;
b.
The funds will be used to retain workers and maintain payroll
or make mortgage interest payments, lease payments, and
utility payments; and
c.
The information provided in the application and in all
supporting documents and forms is true and accurate in all
material respects.
56.
The defendants identified above each submitted, or assisted in the
submission of, falsified IRS Form 941s for each quarter of 2019 included with the
PPP loan applications listed below. The Form 941s submitted on behalf of the
businesses reported the following payroll figures for each quarter of 2019:
Business
Qi 2019
Q2 2019
Q3 2019
Q4 2019
Jan - Max
Apr - Jun
Jul - Sep
Oct - Dec
Bellator Phront
57 employees
59 employees
61 employees
63 employees
Group Inc.
$815,954.00
$865,954.00
$895,923.00
$905,132.00
Impact Creations
57 employees
59 employees
63 employees
63 employees
LLC
$815,954.00
$865,954.00
$905,132.00
$905,132.00
10
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Gaines Reservation
57 employees
59 employees
63 employees
63 employees
and Travel
$815,954.00
$865,954.00
$905,132.00
$905,132.00
Transportation
57 employees
59 employees
63 employees
63 employees
Management
$815,954.00
$865,954.00
$905,132.00
$905,132.00
Services Inc.
Lee Operations LLC
57 employees
59 employees
63 employees
63 employees
$815,954.00
$865,954.00
$905,132.00
$905,132.00
RK Painting Co.
57 employees
59 employees
63 employees
63 employees
$815,954
$865,954
$905,132
$905,132
D Parker Holdings
53 employees
55 employees
58 employees
62 employees
Inc.
$927,116
$947,814
$963,247
$998,896
Continuing Success
57 employees
59 employees
63 employees
63 employees
Inc.
$815,954
$865,954
$905,132
$905,132
All Star Room &
50 employees
53 employees
59 employees
59 employees
Board Services of
$855,927
$864,247
$897,814
$924,247
Michigan Inc.
Infinite Education
66 employees
63 employees
65 employees
66 employees
Services Inc.
$1,167,755.86
$973,277
$998,785
$1,167,755.86
ML Exotic Customs
55 employees
57 employees
61 employees
65 employees
Inc.
$936,387
$947,909
$963,257
$979,365
Bellevie Corp.
55 employees
57 employees
59 employees
60 employees
$971,407.67
$981,437.67
$993,300.67
$1,007,057.40
Advertising and
54 employees
57 employees
63 employees
65 employees
Then Some Inc.
$877,116
$905,852
$925,741
$940,291
Mickies Auto and
59 employees
63 employees
65 employees
67 employees
Tires LLC
$969,715.17
$985,954
$1,009,618
$1,034,306
57.
The PPP loan applications for Gaines Reservation and Travel,
Impact Creations LLC, Transportation Management Services Inc., and Lee
Operations LLC also included falsified bank statements. Specifically:
a.
The applications for Gaines Reservation and Travel,
Impact Creations LLC, and Transportation Management
Services Inc. included substantially identical falsified bank
statements purporting to show the businesses’ purported
balances at Bank 1 for February 2020. In fact, the Bank 1
accounts for Impact Creations LLC and Transportation
11
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Management Services, Inc. were not opened t.mtil April 2020,
and the Bank 1 account statement for Gaines Reservation and
Travel for February 2020 was materially different from the
falsified statement that Gaines Reservation and Travel
submitted.
b.
The application for Lee Operations included a falsified bank
statement that purported to show Lee Operations LLC’s
balance at Bank 2 for February 2020. In fact, the Bank 2
account statement for Lee Operations LLC for February 2020
was materially different from the falsified statement that Lee
Operations submitted.
58.
The PPP applications for RK Painting Co., D Parker Holdings Inc.,
Continuing Success Inc., All Star Room and Board Services of Michigan Inc.,
Infinite Education Services Inc., ML Exotic Customs Inc., Bellevie Corp.,
Advertising and Then Some Inc., and Mickies Auto and Tires LLC included
falsified payroll documentation, including purported payroll spreadsheets.
PPP Loan Funding and Transfers ofMoney
59.
Based on the fraudulent and false representations and submissions
made by the defendants identified above, the PPP lenders that received the
applications funded the PPP loans as follows:
a.
On or about May 19, 2020, approximately $799,955.35 in PPP
loan funds was distributed by Financial Institution 4 to
Bellator Phront Group Inc.
12
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b.
On or about May 19, 2020, approximately $830,000 in PPP loan
funds was distributed by Financial Institution 1, through
Company 1, to Impact Creations LLC.
c.
On or about May 18, 2020, approximately $806,710 in PPP loan
funds was distributed by Financial Institution 1, through
Company 1, to Gaines Reservation and Travel.
d.
On or about May 21, 2020, approximately $830,417 in PPP loan
funds was distributed by Financial Institution 1, through
Company 1, to Transportation Management Services Inc.
e.
On or about May 21, 2020, approximately $805,813 in PPP loan
funds was distributed by Financial Institution 2, through
Company 1, to Lee Operations LLC.
f.
On or about June 8, 2020, approximately $775,000 in PPP loan
funds was distributed by Financial Institution 3 to RK
Painting Co.
g.
On or about June 17, 2020, approximately $818,102 in PPP loan
funds was distributed by Financial Institution 4 to D Parker
Holdings Inc.
h.
On or about June 30, 2020, approximately $727,000 in PPP loan
funds was distributed by Financial Institution 3 to Continuing
Success Inc.
i.
On or about June 30, 2020, approximately $737,965 in PPP loan
funds was distributed by Financial Institution 4 to All Star
Room and Board Services of Michigan Inc.
13
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j.
On or about July 11, 2020, approximately $854,805 in PPP loan
funds was distributed by Financial Institution 5 to Infinite
Education Services Inc.
k.
On or about July 17, 2020, approximately $797,275 in PPP loan
funds was distributed by Financial Institution 5 to ML Exotic
Customs Inc.
1.
On or about August 7, 2020, approximately $823,585 in PPP
loan funds was distributed by Financial InstitutionS to
Bellevie Corp.
m.
On or about July 23, 2020, approximately $760,207 in PPP loan
funds was distributed by Financial Institution 5 to Advertising
and Then Some Inc.
n.
On or about August 12, 2020, approximately $787,160 in PPP
loan funds was distributed by Financial Institution 5 to
Mickies Auto and Tires LLC.
60.
After the PPP loan proceeds were deposited in the businesses’
accounts, the defendants transferred, received, or directed the transfer or receipt
of some of the PPP proceeds to other individuals and entities known and
unknown to the Grand Jury, in an effort to conceal and disguise the ownership
and control of the fraudulent loan proceeds, except for the loan proceeds for
Advertising and Then Some Inc. and Mickies Auto and Tires LLC, which were
frozen shortly after disbursement.
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Count One
Conspiracy to Commit Wire Fraud — 18 U.S.C. § 1349
(Defendants MEGHAN THOMAS and FOSTER)
61.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 of this First Superseding
Indictment as if fully set forth herein.
62.
From in or about April 2020 through in or about May 2020, the exact
dates unknown, in the Northern District of Georgia and elsewhere, the
Defendants,
MEGHAN THOMAS and
TELDRIN FOSTER,
did knowingly and willfully combine, conspire, confederate, agree, and have a
tacit understanding with each other, Darrell Thomas, and others known and
unknown to the Grand Jury, to devise and intend to devise a scheme and artifice
to defraud, and to obtain money and property, by means of materially false and
fraudulent pretenses, representations, and promises, and by the omission of
material facts, well knowing and having reason to know that said pretenses were
and would be false and fraudulent when made and caused to be made and that
said omissions were and would be material, and, in so doing, caused interstate
and foreign wire communications to be made, in furtherance of the scheme and
artifice to defraud, in violation of Title 18, United States Code, Section 1343.
Manner and Means
63.
MEGHAN THOMAS and FOSTER, together with Darrell Thomas and
with others known and unknown to the Grand Jury, conspired to submit false
15
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materials, such as a false PPP loan application and false IRS Form 941s to a
financial institution to obtain PPP loan funding.
64.
Throughout the conspiracy, MEGHAN THOMAS and FOSTER utilized
interstate wires to submit and assist in the submission of false documents to a
lender when applying for a PPP loan, including fabricated IRS Form 941s listing
falsified payroll information and false loan application documentation that listed
false payroll information, false employment information, and a false purpose for
the loan funding.
65.
As a result of and based on MEGHAN THOMAS’s and FOSTER’s false
representations and certifications and falsified supporting documents, a financial
institution issued an approximately $799,955.35 PPP loan to Bellator Phront
Group Inc.
All in violation of Title 18, United States Code, Section 1349.
Count Two
Wire Fraud - 18 U.S.C. § 1343 and § 2
(Defendants MEGHAN THOMAS and FOSTER)
66.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 63 through 65 of this First
Superseding Indictment as if fully set forth herein.
67.
On or about April 21, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
MEGHAN THOMAS and
TELDRIN FOSTER,
aided and abefted by each other, Darrell Thomas, and others known and
unknown to the Grand Jury, for the purpose of executing and attempting to
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execute the aforementioned scheme and artifice to defraud, and to obtain money
and property by means of materially false and fraudulent pretenses,
representations, and promises, and by omission of material facts, did, with intent
to defraud, cause to be transmitted by means of a wire communication in
interstate and foreign commerce certain writings, signs, signals, and sounds,
namely, a PPP Borrower Application Form containing false information related
to Bellator Phront Group Inc.’s payroll expenses and the purpose of the applied-
for PPP loan and attaching falsified tax documentation for each quarter of 2019.
All in violation of Title 18, United States Code, Section 1343 and Section 2.
Count Three
Conspiracy to Commit Bank Fraud and Wire Fraud - 18 U.S.C. § 1349
(Defendants BLAKELY and FOSTER)
68.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 of this First Superseding
Indictment as if fully set forth herein.
69.
From in or about April 2020 through in or about May 2020, the exact
dates unknown, in the Northern District of Georgia and elsewhere, the
Defendants,
JESIKA BLAKELY and
TELDRIN FOsTER,
did knowingly and willfully combine, conspire, confederate, agree, and have a
tacit understanding with each other, Kahlil Gibran Green, Sr., Darrell Thomas,
and others known and unknown to the Grand Jury, to:
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(a)
execute a scheme and artifice to defraud a financial institution, the
deposits of which were insured by the FDIC, and to obtain moneys,
funds, credits, assets, securities, and other property owned by and
under the custody and control of the aforementioned financial
institution by means of materially false and fraudulent pretenses,
representations, and promises and by the omission of material facts,
in violation of Title 18, United States Code, Section 1344; and
(b)
devise and intend to devise a scheme and artifice to defraud, and to
obtain money and property, by means of materially false and
fraudulent pretenses, representations, and promises, and by the
omission of material facts, well knowing and having reason to know
that said pretenses were and would be false and fraudulent when
made and caused to be made and that said omissions were and
would be material, and, in so doing, caused interstate and foreign
wire communications to be made, in furtherance of the scheme and
artifice to defraud, in violation of Title 18, United States Code,
Section 1343.
Manner and Means
70.
BLA~LY and FosTER, together with Kahlil Gibran Green, Sr., Darrell
Thomas, and others known and unknown to the Grand Jury, conspired to submit
false materials, such as a false PPP loan application, false IRS Form 941s, and a
false bank account statement, to a financial institution to obtain PPP loan
funding.
18
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71.
Throughout the conspiracy, BLAKELY and FosTER utilized interstate
wires to submit and assist in the submission of false documents to a lender when
applying for a PPP loan, including a fabricated bank statement listing inflated
account balances and non-existent transactions, fabricated IRS Form 941s listing
falsified payroll information, and false loan application documentation that listed
false payroll information, false employment information, and false purposes for
the loan funding.
72.
As a result of and based on BLAKELY’s and FOSTER’s false
representations and certifications and falsified supporting documents, a federally
insured lender issued an $830,000 PPP loan to Impact Creations LLC.
All in violation of Title 18, United States Code, Section 1349.
Count Four
Bank Fraud - 18 U.S.C. § 1344 and § 2
(Defendants BLAKELY and FOSTER)
73.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 70 through 72 of this First
Superseding Indictment as if fully set forth herein.
74.
On or about May 17, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
JESIKA BLAKELY and
TELDRIN FosTER,
aided and abetted by each other, Kahlil Gibran Green, Sr., Darrell Thomas, and
others known and unknown to the Grand Jury, did knowingly execute and
attempt to execute a scheme and artifice to defraud Financial Institution 1, the
19
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deposits of which were then insured by the FDIC, and to obtain, by means of
materially false and fraudulent pretenses, representations, and promises, and by
omission of material facts, certain moneys, funds, credits, assets, securities, and
other property owned by and under the custody and control of Financial
Institution 1.
Execution of the Bank Fraud Scheme
75.
On or about May 17, 2020, in the Northern District of Georgia and
elsewhere, Defendants BLAKELY and FOSTER, aided and abetted by each other,
Kahlil Gibran Green, Sr., Darrell Thomas, and others known and unknown to the
Grand Jury, did knowingly execute and attempt to execute the above-described
scheme to defraud by causing false IRS Form 941s and a false bank statement for
Impact Creations LLC to be transmitted to Financial Institution 1 and making
false representations and certifications to Financial Institution 1 regarding Impact
Creations LLC’s payroll costs, the number of employees, and the purposes of the
applied-for PPP loan.
All in violation of Title 18, United States Code, Section 1344 and Section 2.
Count Five
Wire Fraud
— 18 U.S.C. § 1343 and § 2
(Defendants BLAKELY and FOsTER)
76.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 70 through 72 of this First
Superseding Indictment as if fully set forth herein.
77.
On or about May 17, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
JESIKA BLAKELY and
20
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TELDRIN FosTER,
aided and abetted by each other, Kahlil Gibran Green, Sr., Darrell Thomas, and
others known and unknown to the Grand Jury, for the purpose of executing and
attempting to execute the aforementioned scheme and artifice to defraud, and to
obtain money and property by means of materially false and fraudulent
pretenses, representations, and promises, and by omission of material facts, did,
with intent to defraud, cause to be transmitted by means of a wire
communication in interstate and foreign commerce certain writings, signs,
signals, and sounds, namely, a PPP Borrower Application Form containing false
information related to Impact Creations LLC’s payroll expenses and the
purposes of the applied-for PPP loan, and attaching falsified tax documentation
for each quarter of 2019 and a falsified bank statement.
All in violation of Title 18, United States Code, Section 1343 and Section 2.
Count Six
Conspiracy to Commit Bank Fraud and Wire Fraud
— 18 U.S.C. § 1349
(Defendants BLAKELY, FOSTER, and JOHN GAINES)
78.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 of this First Superseding
Indictment as if fully set forth herein.
79.
From in or about April 2020 through in or about May 2020, the exact
dates unknown, in the Northern District of Georgia and elsewhere, the
Defendants,
JESIKA BLAKELY,
TELDRIN FOSTER, and
JOHN GAINES,
21
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did knowingly and willfully combine, conspire, confederate, agree, and have a
tacit understanding with each other, Darrell Thomas, and others known and
uiiknown to the Grand Jury, to:
(a)
execute a scheme and artifice to defraud a financial institution, the
deposits of which were insured by the FDIC, and to obtain moneys,
funds, credits, assets, securities, and other property owned by and
under the custody and control of the aforementioned financial
institution by means of materially false and fraudulent pretenses,
representations, and promises and by the omission of material facts,
in violation of Title 18, United States Code, Section 1344; and
(b)
devise and intend to devise a scheme and artifice to defraud, and to
obtain money and property, by means of materially false and
fraudulent pretenses, representations, and promises, and by the
omission of material facts, well knowing and having reason to know
that said pretenses were and would be false and fraudulent when
made and caused to be made and that said omissions were and
would be material, and, in so doing, caused interstate and foreign
wire communications to be made, in furtherance of the scheme and
artifice to defraud, in violation of Title 18, United States Code,
Section 1343.
Manner and Means
80.
BLAKELY, FOSTER, and JOHN GAINES, together with Darrell Thomas
and with others known and imknown to the Grand Jury, conspired to submit
false materials, such as a false PPP loan application, false IRS Form 941s, and a
22
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false bank account statement, to a financial institution to obtain PPP loan
funding.
81.
Throughout the conspiracy, BLAKELY, FOSTER, and JOHN GAINES
utilized interstate wires to submit and assist in the submission of false
documents to a lender when applying for a PPP loan, including a fabricated bank
statement listing inflated account balances and non-existent transactions,
fabricated IRS Form 941s listing falsified payroll information, and false loan
application documentation that listed false payroll information, false
employment information, and false purposes for the loan funding.
82.
As a result of and based on BLAKELY’s, FOSTER’s, and JOHN GAINES’s
false representations and certifications and falsified supporting documents, a
federally insured lender issued an $806,710 PPP loan to Gaines Reservation and
Travel.
All in violation of Title 18, United States Code, Section 1349.
Count Seven
Bank Fraud -18 U.S.C. § 1344 and § 2
(Defendants BLAKELY, FOSTER, and JOHN GAINES)
83.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 80 through 82 of this First
Superseding Indictment as if fully set forth herein.
84.
On or about May 18, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
JESIKA BLAKELY,
TELDRIN FOSTER, and
JOHN GAINES,
23
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aided and abetted by each other, Darrell Thomas, and others known and
unknown to the Grand Jury, did knowingly execute and attempt to execute a
scheme and artifice to defraud Financial Institution 1, the deposits of which were
then insured by the FDIC, and to obtain, by means of materially false and
fraudulent pretenses, representations, and promises, and by omission of material
facts, certain moneys, funds, credits, assets, securities, and other property owned
by and under the custody and control of Financial Institution 1.
Execution of the Bank Fraud Scheme
85.
On or about May 18, 2020, in the Northern District of Georgia and
elsewhere, Defendants BLAKELY, FOSTER, and JOHN GAINEs, aided and abetted by
each other, Darrell Thomas, and others known and unknown to the Grand Jury,
did knowingly execute and attempt to execute the above-described scheme to
defraud by causing false IRS Form 941s and a false bank statement for Gaines
Reservation and Travel to be transmitted to Financial Institution 1 and making
false representations and certifications to Financial Institution 1 regarding Gaines
Reservation and Travel’s payroll costs and the purposes of the applied-for PPP
loan.
All in violation of Title 18, United States Code, Section 1344 and Section 2.
Count Eight
Wire Fraud - 18 U.S.C. § 1343 and § 2
(Defendants BLAKEIx, FOSTER, and JOHN GAINES)
86.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 80 through 82 of this First
Superseding Indictment as if fully set forth herein.
24
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87.
On or about May 18, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
JESIKA BLAKELY,
TELDRIN FOSTER, and
JOHN GAINES,
aided and abetted by each other, Darrell Thomas, and others known and
unknown to the Grand Jury, for the purpose of executing and attempting to
execute the aforementioned scheme and artifice to defraud, and to obtain money
and property by means of materially false and fraudulent pretenses,
representations, and promises, and by omission of material facts, did, with intent
to defraud, cause to be transmitted by means of a wire communication in
interstate and foreign commerce certain writings, signs, signals, and sounds,
namely, a PPP Borrower Application Form containing false information related
to Gaines Reservation and Travel’s payroll obligations and the purposes of the
applied-for PPP loan, and attaching falsified tax documentation for each quarter
of 2019 and a falsified bank statement.
All in violation of Title 18, United States Code, Section 1343 and Section 2.
Count Nine
Conspiracy to Commit Bank Fraud and Wire Fraud — 18 U.S.C. § 1349
(Defendants FOSTER, CHRISTIAN, PErrY, and BAPTISTE)
88.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 of this First Superseding
Indictment as if fully set forth herein.
89.
From in or about April 2020 through in or about May 2020, the exact
dates unknown, in the Northern District of Georgia and elsewhere, the
Defendants,
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TELDRIN FOSTER,
AMANDA CHRISTIAN,
CHARLES PETTY, and
JERRY BAPTISTE,
did knowingly and willfully combine, conspire, confederate, agree, and have a
tacit understanding with each other, Bern Benoit, Darrell Thomas, Denesseria
Slaton, and others known and unknown to the Grand Jury, to:
(a)
execute a scheme and artifice to defraud a financial institution, the
deposits of which were insured by the FDIC, and to obtain moneys,
funds, credits, assets, securities, and other property owned by and
under the custody and control of the aforementioned financial
institution by means of materially false and fraudulent pretenses,
representations, and promises and by the omission of material facts,
in violation of Title 18, United States Code, Section 1344; and
(b)
devise and intend to devise a scheme and artifice to defraud, and to
obtain money and property, by means of materially false and
fraudulent pretenses, representations, and promises, and by the
omission of material facts, well knowing and having reason to know
that said pretenses were and would be false and fraudulent when
made and caused to be made and that said omissions were and
would be material, and, in so doing, caused interstate and foreign
wire communications to be made, in furtherance of the scheme and
artifice to defraud, in violation of Title 18, United States Code,
Section 1343.
26
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Manner and Means
90.
FosTER, CHRISTIAN, PETTY, and BAPTIsTE, together with Bern Benoit,
Darrell Thomas, and Denesseria Slaton, and with others known and unknown to
the Grand Jury, conspired to submit false materials, such as a false PPP loan
application, false IRS Form 941s, and a false bank account statement, to a
financial institution to obtain PPP loan funding.
91.
Throughout the conspiracy, FosTER, CHRISTIAN, PErrY, and BAVnsTE
utilized interstate wires to submit and assist in the submission of false
documents to a lender when applying for a PPP loan, including a fabricated bank
statement listing inflated account balances and non-existent transactions,
fabricated IRS Form 941s listing falsified payroll information, and false loan
application documentation that listed false payroll information, false
employment information, and false purposes for the loan funding.
92.
As a result of and based on FOSTER’s, CHRISTIAN’s, PETTY’s, and
BAPTISTE’s false representations and certifications and falsified supporting
documents, a federally insured lender issued an $830,417 PPP loan to
Transportation Management Services Inc.
All in violation of Title 18, United States Code, Section 1349.
Count Ten
Bank Fraud —18 U.S.C. § 1344 and § 2
(Defendants FosTER, CHRISTIAN, PETTY, and BAPTIsTE)
93.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 90 through 92 of this First
Superseding Indictment as if fully set forth herein.
27
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94.
On or about May 20, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
TELDRIN FOSTER,
AMANDA CHRISTIAN,
CHARLES PETTY, and
JERRY BAPTISTE,
aided and abetted by each other, Bern Benoit, Darrell Thomas, Denesseria Slaton,
and others known and unknown to the Grand Jury, did knowingly execute and
attempt to execute a scheme and artifice to defraud Financial Institution 1, the
deposits of which were then insured by the FDIC, and to obtain, by means of
materially false and fraudulent pretenses, representations, and promises, and by
omission of material facts, certain moneys, funds, credits, assets, securities, and
other property owned by and under the custody and control of Financial
Institution 1.
Execution of the Bank Fraud Scheme
95.
On or about May 20, 2020, in the Northern District of Georgia and
elsewhere, Defendants FOSmR, CHRISTIAN, PErrY, and BAPTISTE, aided and
abetted by each other, Bern Benoit, Darrell Thomas, Denesseria Slaton, and
others known and unknown to the Grand Jury, did knowingly execute and
attempt to execute the above-described scheme to defraud by causing false IRS
Form 941s and a false bank statement for Transportation Management Services
Inc. to be transmitted to Financial Institution 1 and making false representations
and certifications to Financial Institution 1 regarding Transportation
Management Services Inc.’s payroll costs and the purpose of the applied-for PPP
loan.
28
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All in violation of Title 18, United States Code, Section 1344 and Section 2.
Count Eleven
Wire Fraud—18 U.S.C. §1343and~2
(Defendants FOSTER, CHRISTIAN, PErn, and BAPTISTE)
96.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 90 through 92 of this First
Superseding Indictment as if fully set forth herein.
97.
On or about May 20, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
TELDRIN FOSTER,
AMANDA CHRISTIAN,
CHARLES PETTY, and
JERRY BAPTISTE,
aided and abetted by each other, Bern Benoit, Darrell Thomas, Denesseria Slaton,
and others known and ur&nown to the Grand Jury, for the purpose of executing
and attempting to execute the aforementioned scheme and artifice to defraud,
and to obtain money and property by means of materially false and fraudulent
pretenses, representations, and promises, and by omission of material facts, did,
with intent to defraud, cause to be transmitted by means of a wire
communication in interstate and foreign commerce certain writings, signs,
signals, and sounds, namely, a PPP Borrower Application Form containing false
information related to Transportation Management Services Inc.’s payroll
obligations and the purposes of the applied-for PPP loan, and attaching falsified
tax documentation for each quarter of 2019 and a falsified bank statement.
All in violation of Title 18, United States Code, Section 1343 and Section 2.
29
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Count Twelve
Conspiracy to Commit Bank Fraud and Wire Fraud - 18 U.S.C. § 1349
(Defendants DIXON and FosTER)
98.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 of this First Superseding
Indictment as if fully set forth herein.
99.
From in or about April 2020 through in or about May 2020, the exact
dates unknown, in the Northern District of Georgia and elsewhere, the
Defendants,
RIcKY DIXON and
TELDRIN FOsTER,
did knowingly and willfully combine, conspire, confederate, agree, and have a
tacit understanding with each other, Darrell Thomas, and others known and
unknown to the Grand Jury, to:
(a)
execute a scheme and artifice to defraud a financial institution, the
deposits of which were insured by the FDIC, and to obtain moneys,
funds, credits, assets, securities, and other property owned by and
under the custody and control of the aforementioned financial
institution by means of materially false and fraudulent pretenses,
representations, and promises and by the omission of material facts,
in violation of Title 18, United States Code, Section 1344; and
(b)
devise and intend to devise a scheme and artifice to defraud, and to
obtain money and property, by means of materially false and
fraudulent pretenses, representations, and promises, and by the
omission of material facts, well knowing and having reason to know
30
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that said pretenses were and would be false and fraudulent when
made and caused to be made and that said omissions were and
would be material, and, in so doing, caused interstate and foreign
wire communications to be made, in furtherance of the scheme and
artifice to defraud, in violation of Title 18, United States Code,
Section 1343.
Manner and Means
100.
DixoN and FosTER, together with Darrell Thomas and others
known and unknown to the Grand Jury, conspired to submit false materials,
such as a false PPP loan application, false IRS Form 941s, and a false bank
account statement, to a financial institution to obtain PPP loan funding.
101.
Throughout the conspiracy, DIxON and FOSTER utilized interstate
wires to submit and assist in the submission of false documents to a lender when
applying for a PPP loan, including a fabricated bank statement listing inflated
account balances and non-existent transactions, fabricated IRS Form 941s listing
falsified payroll information, and false loan application documentation that listed
false payroll information, false employment information, and false purposes for
the loan funding.
102.
As a result of and based on DIXON’s and FOSTER’s false
representations and certifications and falsified supporting documents, a federally
insured lender issued an $805,813 PPP loan to Lee Operations LLC.
All in violation of Title 18, United States Code, Section 1349.
31
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Count Thirteen
Bank Fraud -18 U.S.C. § 1344 and § 2
(Defendants DIXON and FOSTER)
103.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 100 through 102 of this
First Superseding Indictment as if fully set forth herein.
104.
On or about May 20, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
RICKY DIXON and
TELDRIN FOSTER,
aided and abetted by each other, Darrell Thomas, and others known and
unknown to the Grand Jury, did knowingly execute and attempt to execute a
scheme and artifice to defraud Financial Institution 2, the deposits of which were
then insured by the FDIC, and to obtain, by means of materially false and
fraudulent pretenses, representations, and promises, and by omission of material
facts, certain moneys, funds, credits, assets, securities, and other property owned
by and under the custody and control of Financial Institution 2.
Execution of the Bank Fraud Scheme
105.
On or about May 20, 2020, in the Northern District of Georgia and
elsewhere, Defendants DIXON and FOSTER, aided and abetted by each other,
Darrell Thomas, and others known and unknown to the Grand Jury, did
knowingly execute and attempt to execute the above-described scheme to
defraud by causing false IRS Form 941s and a false bank statement for Lee
Operations to be transmitted to Financial Institution 2 and making false
32
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representations and certifications to Financial Institution 2 regarding Lee
Operations’ payroll costs and the purposes of the applied-for PPP loan.
All in violation of Title 18, United States Code, Section 1344 and Section 2.
Count Fourteen
Wire Fraud — 18 U.S.C. § 1343 and § 2
(Defendants DIXON and FOSTER)
106.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 100 through 102 of this
First Superseding Indictment as if fully set forth herein.
107.
On or about May 20, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
RICKY DIXON and
TELDRIN FOSTER,
aided and abetted by each other, Darrell Thomas, and others known and
unknown to the Grand Jury, for the purpose of executing and attempting to
execute the aforementioned scheme and artifice to defraud, and to obtain money
and property by means of materially false and fraudulent pretenses,
representations, and promises, and by omission of material facts, did, with intent
to defraud, cause to be transmitted by means of a wire communication in
interstate and foreign commerce certain writings, signs, signals, and sounds,
namely, a PPP Borrower Application Form containing false information related
to Lee Operations’ payroll obligations and the purposes of the applied-for PPP
loan, and attaching falsified tax documentation for each quarter of 2019 and a
falsified bank statement.
All in violation of Title 18, United States Code, Section 1343 and Section 2.
33
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Count Fifteen
Conspiracy to Commit Bank Fraud and Wire Fraud
— 18 U.S.C. § 1349
(Defendants DIxoN, FOsTER, and BLAKELY)
108.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 of this First Superseding
Indictment as if fully set forth herein.
109.
From in or about April 2020 through in or about May 2020, the exact
dates unknown, in the Northern District of Georgia and elsewhere, the
Defendants,
RIcKY DIXON,
TELDRIN FOSTER, and
JESIKA BLAKELY,
did knowingly and willfully combine, conspire, confederate, agree, and have a
tacit understanding with each other, Darrell Thomas, and others known and
unknown to the Grand Jury, to:
(a)
execute a scheme and artifice to defraud a financial institution, the
deposits of which were insured by the FDIC, and to obtain moneys,
funds, credits, assets, securities, and other property owned by and
under the custody and control of the aforementioned financial
institution by means of materially false and fraudulent pretenses,
representations, and promises and by the omission of material facts,
in violation of Title 18, United States Code, Section 1344; and
(b)
devise and intend to devise a scheme and artifice to defraud, and to
obtain money and property, by means of materially false and
fraudulent pretenses, representations, and promises, and by the
omission of material facts, well knowing and having reason to know
34
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that said pretenses were and would be false and fraudulent when
made and caused to be made and that said omissions were and
would be material, and, in so doing, caused interstate and foreign
wire communications to be made, in furtherance of the scheme and
artifice to defraud, in violation of Title 18, United States Code,
Section 1343.
Manner and Means
110.
DixoN, FosTER, and BLAKELY, together with Darrell Thomas and
others known and unknown to the Grand Jury, conspired to submit false
materials, such as a false PPP loan application, false IRS Form 941s, a false profit
and loss statement, and a false payroll spreadsheet, to a financial institution to
obtain PPP loan funding.
111.
Throughout the conspiracy, DIXON, FOSTER, and BLAKELY utilized
interstate wires to submit and assist in the submission of false documents to a
lender when applying for a PPP loan, including a fabricated profit and loss
statement that listed inflated financial information, fabricated IRS Form 941s
listing falsified payroll information, a fabricated payroll spreadsheet listing non
existent employees and payroll expenses, and false loan application
documentation that listed false payroll information, false employment
information, and false purposes for the loan funding.
112.
As a result of and based on DIXON’s, FOSTER’s, and BLAKELY’s false
representations and certifications and falsified supporting documents, a federally
insured lender issued a $775,000 PPP loan to RK Painting Co.
All in violation of Title 18, United States Code, Section 1349.
35
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Count Sixteen
Bank Fraud -18 U.S.C. § 1344 and § 2
(Defendants DIxoN, FosTER, and BLAKELY)
113.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 110 through 112 of this
First Superseding Indictment as if fully set forth herein.
114.
on or about May 15, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
RIcKY DIXON,
TELDRIN FOSTER, and
JESIKA BLAKELY,
aided and abetted by each other, Darrell Thomas, and others known and
unknown to the Grand Jury, did knowingly execute and attempt to execute a
scheme and artifice to defraud Financial Institution 3, the deposits of which were
then insured by the FDIC, and to obtain, by means of materially false and
fraudulent pretenses, representations, and promises, and by omission of material
facts, certain moneys, funds, credits, assets, securities, and other property owned
by and under the custody and control of Financial Institution 3.
Execution of the Bank Fraud Scheme
115.
On or about May 15, 2020, in the Northern District of Georgia and
elsewhere, Defendants DIxoN, FOSTER, and BLAKELY, aided and abetted by each
other, Darrell Thomas, and others known and unknown to the Grand Jury, did
knowingly execute and attempt to execute the above-described scheme to
defraud by causing false IRS Form 941s, a false profit and loss statement, and a
false payroll spreadsheet to be transmitted to Financial Institution 3 and making
36
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false representations and certifications to Financial Institution 3 regarding RK
Painting Co.’s payroll costs and the purposes of the applied-for PPP loan.
All in violation of Title 18, United States Code, Section 1344 and Section 2.
Count Seventeen
Wire Fraud — 18 U.S.C. § 1343 and § 2
(Defendants DIXON, FOSTER, and BLAKELY)
116.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 110 through 112 of this
First Superseding Indictment as if fully set forth herein.
117.
On or about May 15, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
RIcKY DIXON,
TELDRIN FOSTER, and
JESIKA BLAKELY,
aided and abetted by each other, Darrell Thomas, and others known and
unknown to the Grand Jury, for the purpose of executing and attempting to
execute the aforementioned scheme and artifice to defraud, and to obtain money
and property by means of materially false and fraudulent pretenses,
representations, and promises, and by omission of material facts, did, with intent
to defraud, cause to be transmitted by means of a wire communication in
interstate and foreign commerce certain writings, signs, signals, and sounds,
namely, a PPP Borrower Application Form containing false information related
to RK Painting Co.’s payroll obligations and the purposes of the applied-for PPP
loan, and attaching falsified tax documentation for each quarter of 2019, a
falsified profit and loss statement, and a falsified payroll spreadsheet.
37
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All in violation of Title 18, United States Code, Section 1343 and Section 2.
Count Eighteen
Conspiracy to Commit Wire Fraud - 18 U.S.C. § 1349
(Defendants DIXON, FOSTER, and PARKER)
118.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 of this First Superseding
Indictment as if fully set forth herein.
119.
From in or about April 2020 through in or about June 2020, the exact
dates unknown, in the Northern District of Georgia and elsewhere, the
Defendants,
RIcKY DIXON,
TELDRIN FOSTER, and
DEREK PARKER,
did knowingly and willfully combine, conspire, confederate, agree, and have a
tacit understanding with each other, Darrell Thomas, and others known and
unknown to the Grand Jury, to devise and intend to devise a scheme and artifice
to defraud, and to obtain money and property, by means of materially false and
fraudulent pretenses, representations, and promises, and by the omission of
material facts, well knowing and having reason to know that said pretenses were
and would be false and fraudulent when made and caused to be made and that
said omissions were and would be material, and, in so doing, caused interstate
and foreign wire communications to be made, in furtherance of the scheme and
artifice to defraud, in violation of Title 18, United States Code, Section 1343.
38
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Manner and Means
120.
DIXON, FOSTER, and PARKER, together with Darrell Thomas and
others known and unknown to the Grand Jury, conspired to submit false
materials, such as a false PPP loan application, false IRS Form 941s, and false
payroll spreadsheets, to a financial institution to obtain PPP loan ftmding.
121.
Throughout the conspiracy, DIxoN, FOSTER, and PARKER utilized
interstate wires to submit and assist in the submission of false documents to a
lender when applying for a PPP loan, including fabricated IRS Form 941s listing
falsified payroll information, fabricated payroll spreadsheets listing non-existent
employees and payroll expenses, and false loan application documentation that
listed false payroll information, false employment information, and false
purposes for the loan funding.
122.
As a result of and based on DIXON’s, FOSTER’s, and PARKER’s false
representations and certifications and falsified supporting documents, a financial
institution issued an $818,102 PPP loan to D Parker Holdings Inc.
All in violation of Title 18, United States Code, Section 1349.
Count Nineteen
Wire Fraud — 18 U.S.C. § 1343 and § 2
(Defendants DIXON, FOsTER, and PARKER)
123.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 120 through 122 of this
First Superseding Indictment as if fully set forth herein.
124.
On or about June 12, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
39
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RIcKY DIXON,
TELDRIN FOSTER, and
DEREK PARKER,
aided and abetted by each other, Darrell Thomas, and others known and
unknown to the Grand Jury, for the purpose of executing and attempting to
execute the aforementioned scheme and artifice to defraud, and to obtain money
and property by means of materially false and fraudulent pretenses,
representations, and promises, and by omission of material facts, did, with intent
to defraud, cause to be transmitted by means of a wire communication in
interstate and foreign commerce certain writings, signs, signals, and sounds,
namely, a PPP Borrower Application Form containing false information related
to D Parker Holdings Inc.’s payroll obligations and the purposes of the applied-
for PPP loan, and attaching falsified tax documentation for each quarter of 2019
and falsified payroll spreadsheets.
All in violation of Title 18, United States Code, Section 1343 and Section 2.
Count Twenty
Conspiracy to Commit Bank Fraud and Wire Fraud - 18 U.S.C. § 1349
(Defendants MEGHAN THOMAS, FOSmR, CHRISTIAN, and BELGRAvE)
125.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 of this First Superseding
Indictment as if fully set forth herein.
126.
From in or about April 2020 through in or about June 2020, the exact
dates unknown, in the Northern District of Georgia and elsewhere, the
Defendants,
MEGHAN THOMAS,
TELDRIN FOSTER,
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AMANDA CHRISTIAN, and
DAVID BELGRAVE II,
did knowingly and willfully combine, conspire, confederate, agree, and have a
tacit understanding with each other, Darrell Thomas, Denesseria Slaton, and
others known and miknown to the Grand Jury, to:
(a)
execute a scheme and artifice to defraud a financial institution, the
deposits of which were insured by the FDIC, and to obtain moneys,
funds, credits, assets, securities, and other property owned by and
under the custody and control of the aforementioned financial
institution by means of materially false and fraudulent pretenses,
representations, and promises and by the omission of material facts,
in violation of Title 18, United States Code, Section 1344; and
(b)
devise and intend to devise a scheme and artifice to defraud, and to
obtain money and property, by means of materially false and
fraudulent pretenses, representations, and promises, and by the
omission of material facts, well knowing and having reason to know
that said pretenses were and would be false and fraudulent when
made and caused to be made and that said omissions were and
would be material, and, in so doing, caused interstate and foreign
wire communications to be made, in furtherance of the scheme and
artifice to defraud, in violation of Title 18, United States Code,
Section 1343.
Manner and Means
127.
MEGHAN THOMAS, FOSTER, CHRISTIAN, and BELGRAVE, together with
Darrell Thomas, Denesseria Slaton, and others known and unknown to the
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Grand Jury, conspired to submit false materials, such as a false PPP loan
application, false IRS Form 941s, and false payroll spreadsheets, to a financial
institution to obtain PPP loan ftmding.
128.
Throughout the conspiracy, MEGHAN THoMAs, FOsmR, CHRIsTIAN,
and BELGRAvE utilized interstate wires to submit and assist in the submission of
false documents to a lender when applying for a PPP loan, including fabricated
IRS Form 941s listing falsified payroll information, fabricated payroll
spreadsheets listing non-existent employees and payroll expenses, and false loan
application documentation that listed false payroll information, false
employment information, and false purposes for the loan funding.
129.
As a result of and based on MEGHAN THOMAS’s, FOSTER’s,
CHRISTIAN’s, and BELGRAVE’s false representations and certifications and falsified
supporting documents, a federally insured lender issued a $727,000 PPP loan to
Continuing Success Inc.
All in violation of Title 18, United States Code, Section 1349.
Count Twenty-One
Bank Fraud -18 U.S.C. § 1344 and § 2
(Defendants MEGHAN THOMAS, FOsTER, CHRISTIAN, and BELGRAvE)
130.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 127 through 129 of this
First Superseding Indictment as if fully set forth herein.
131.
On or about June 12, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
MEGHAN THOMAS,
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TELDRIN FOSTER,
AMANDA CHRISTIAN, and
DAVID BELGRAvE II,
aided and abetted by each other, Darrell Thomas, Denesseria Slaton, and others
known and umknown to the Grand Jury, did knowingly execute and attempt to
execute a scheme and artifice to defraud Financial Institution 3, the deposits of
which were then insured by the FDIC, and to obtain, by means of materially false
and fraudulent pretenses, representations, and promises, and by omission of
material facts, certain moneys, frmds, credits, assets, securities, and other
property owned by and under the custody and control of Financial Institution 3.
Execution of the Bank Fraud Scheme
132.
On or about June 12, 2020, in the Northern District of Georgia and
elsewhere, Defendants MEGHAN THOMAS, FOSTER, CHRISTIAN, and BELGRAVE,
aided and abetted by each other, Darrell Thomas, Denesseria Slaton, and others
known and unknown to the Grand Jury, did knowingly execute and attempt to
execute the above-described scheme to defraud by causing false IRS Form 941s
and false payroll spreadsheets to be transmitted to Financial Institution 3 and
making false representations and certifications to Financial Institution 3
regarding Continuing Success Inc.’s payroll costs and the purposes of the
applied-for PPP loan.
All in violation of Title 18, United States Code, Section 1344 and Section 2.
43
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Count Twenty-Two
Wire Fraud-18 U.S.C. §1343and~2
(Defendants MEGHAN THOMAS, FOSTER, CHRIS’nAN, and BELGRAVE)
133.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 127 through 129 of this
First Superseding Indictment as if fully set forth herein.
134.
On or about June 12,2020, in the Northern District of Georgia and
elsewhere, the Defendants,
MEGHAN THOMAS,
TELDRIN FOSTER,
AMANDA CHRIS~nAN, and
DAvID BELGRAvE II,
aided and abetted by each other, Darrell Thomas, Denesseria Slaton, and others
known and unknown to the Grand Jury, for the purpose of executing and
attempting to execute the aforementioned scheme and artifice to defraud, and to
obtain money and property by means of materially false and fraudulent
pretenses, representations, and promises, and by omission of material facts, did,
with intent to defraud, cause to be transmitted by means of a wire
communication in interstate and foreign commerce certain writings, signs,
signals, and sounds, namely, a PPP Borrower Application Form containing false
information related to Continuing Success Inc.’s payroll obligations and the
purposes of the applied-for PPP loan, and attaching falsified tax documentation
for each quarter of 2019 and falsified payroll spreadsheets.
All in violation of Title 18, United States Code, Section 1343 and Section 2.
44
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Count Twenty-Three
Conspiracy to Commit Wire Fraud — 18 U.S.C. § 1349
(Defendants DIXON and FOSTER)
135.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 of this First Superseding
Indictment as if fully set forth herein.
136.
From in or about April 2020 through in or about June 2020, the exact
dates unknown, in the Northern District of Georgia and elsewhere, the
Defendants,
RICKY DIXON and
TELDRIN FOSTER,
did knowingly and willfully combine, conspire, confederate, agree, and have a
tacit understanding with each other, Charmaine Redding, Darrell Thomas, and
others known and unknown to the Grand Jury, to devise and intend to devise a
scheme and artifice to defraud, and to obtain money and property, by means of
materially false and fraudulent pretenses, representations, and promises, and by
the omission of material facts, well knowing and having reason to know that said
pretenses were and would be false and fraudulent when made and caused to be
made and that said omissions were and would be material, and, in so doing,
caused interstate and foreign wire communications to be made, in furtherance of
the scheme and artifice to defraud, in violation of Title 18, United States Code,
Section 1343.
45
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Manner and Means
137.
DIXON and FosmR, together with Charmaine Redding, Darrell
Thomas, and with others known and miknown to the Grand Jury, conspired to
submit false materials, such as a false PPP loan application, false IRS Form 941s,
and false payroll spreadsheets, to a financial institution to obtain PPP loan
funding.
138.
Throughout the conspiracy, DIXON and FosTER utilized interstate
wires to submit and assist in the submission of false documents to a lender when
applying for a PPP loan, including fabricated IRS Form 941s listing falsified
payroll information, fabricated payroll spreadsheets listing non-existent
employees and payroll expenses, and false loan application documentation that
listed false payroll information, false employment information, and false
purposes for the loan funding.
139.
As a result of and based on DIXON’s and FOSTER’s false
representations and certifications and falsified supporting documents, a financial
institution issued a $737,965 PPP loan to All Star Room and Board Services of
Michigan Inc.
All in violation of Title 18, United States Code, Section 1349.
Count Twenty-Four
Wire Fraud - 18 U.S.C. § 1343 and § 2
(Defendants DIXON and FOSTER)
140.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 137 through 139 of this
First Superseding Indictment as if fully set forth herein.
46
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141.
On or about June 11, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
RICKY DIXON and
TELDRIN FOsTER,
aided and abetted by each other, Charmaine Redding, Darrell Thomas, and
others known and unknown to the Grand Jury, for the purpose of executing and
attempting to execute the aforementioned scheme and artifice to defraud, and to
obtain money and property by means of materially false and fraudulent
pretenses, representations, and promises, and by omission of material facts, did,
with intent to defraud, cause to be transmitted by means of a wire
communication in interstate and foreign commerce certain writings, signs,
signals, and sounds, namely, a PPP Borrower Application Form containing false
information related to All Star Room and Board Services of Michigan Inc.’s
payroll obligations and the purposes of the applied-for PPP loan, and attaching
falsified tax documentation for each quarter of 2019 and falsified payroll
spreadsheets.
All in violation of Title 18, United States Code, Section 1343 and Section 2.
Count Twenty-Five
Conspiracy to Commit Wire Fraud
— 18 U.S.C. § 1349
(Defendants MEGHAN THOMAS, BLAKELY, FOSTER, CHRISTAN, and HILL)
142.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 of this First Superseding
Indictment as if fully set forth herein.
47
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143.
From in or about April 2020 through in or about July 2020, the exact
dates unknown, in the Northern District of Georgia and elsewhere, the
Defendants,
MEGHAN THOMAS,
JESIKA BLAKELY,
TELDRIN FOSTER,
AMANDA CHRISTIAN, and
CHARLES HILL IV,
did knowingly and willfully combine, conspire, confederate, agree, and have a
tacit understanding with each other, Darrell Thomas, Denesseria Slaton, and
with others known and unknown to the Grand Jury, to devise and intend to
devise a scheme and artifice to defraud, and to obtain money and property, by
means of materially false and fraudulent pretenses, representations, and
promises, and by the omission of material facts, well knowing and having reason
to know that said pretenses were and would be false and fraudulent when made
and caused to be made and that said omissions were and would be material, and,
in so doing, caused interstate and foreign wire communications to be made, in
furtherance of the scheme and artifice to defraud, in violation of Title 18, United
States Code, Section 1343.
Manner and Means
144.
MEGHAN THOMAS, BLAKELY, FOSTER, CHRISTIAN, and HILL, together
with Darrell Thomas, Denesseria Slaton, and others known and unknown to the
Grand Jury, conspired to submit false materials, such as a false PPP loan
application, false IRS Form 941s, and false payroll spreadsheets, to a financial
institution to obtain FPP loan funding.
48
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145.
Throughout the conspiracy, MEGHAN THOMAS, BLAKELY, FosTER,
CHRISTIAN, and HILL utilized interstate wires to submit and assist in the
submission of false documents to a lender when applying for a PPP loan,
including fabricated IRS Form 941s listing falsified payroll information,
fabricated payroll spreadsheets listing non-existent employees and payroll
expenses, and false loan application documentation that listed false payroll
information, false employment information, and false purposes for the loan
funding.
146.
As a result of arid based on MEGHAN THOMAS’s, BLAKELY’s,
FOSTER’s, CHRISTIAN’s, and HILL’s false representations and certifications and
falsified supporting documents, a financial institution issued an $854,805 PPP
loan to Infinite Education Services Inc.
All in violation of Title 18, United States Code, Section 1349.
Count Twenty-Six
Wire Fraud -18 U.S.C. § 1343 and § 2
(Defendants MEGHAN THOMAS, BLAKELY, FoSTER, CHRIsTIAN, and CHARLES HILL)
147.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 144 through 146 of this
First Superseding Indictment as if fully set forth herein.
148.
On or about July 11, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
MEGHAN THOMAS,
JESIKA BLAKELY,
TELDRIN FOSTER,
AMANDA CHRISTIAN, and
CHARLES HILL IV,
49
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aided and abetted by each other, Darrell Thomas, Denesseria Slaton, and others
known and unknown to the Grgand Jury, for the purpose of executing and
attempting to execute the aforementioned scheme and artifice to defraud, and to
obtain money and property by means of materially false and fraudulent
pretenses, representations, and promises, and by omission of material facts, did,
with intent to defraud, cause to be transmitted by means of a wire
communication in interstate and foreign commerce certain writings, signs,
signals, and sounds, namely, a PPP Borrower Application~ Form containing false
information related to Infinite Education Services Inc.’s payroll obligations and
the purposes of the applied-for PPP loan, and attaching falsified tax
documentation for each quarter of 2019 and falsified payroll spreadsheets.
All in violation of Title 18, United States Code, Section 1343 and Section 2.
Count Twenty-Seven
Conspiracy to Commit Wire Fraud — 18 U.S.C. § 1349
(Defendants DIXON, FOSTER, and WHITTLEY)
149.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 of this First Superseding
Indictment as if fully set forth herein.
150.
From in or about April 2020 through in or about June 2020, the exact
dates unknown, in the Northern District of Georgia and elsewhere, the
Defendants,
RIcKY DIXON,
TELDRIN FOSTER, and
RYAN WHITTLEY,
did knowingly and willfully combine, conspire, confederate, agree, and have a
50
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tacit imderstanding with each other, Darrell Thomas, and others known and
unknown to the Grand Jury, to devise and intend to devise a scheme and artifice
to defraud, and to obtain money and property, by means of materially false and
fraudulent pretenses, representations, and promises, and by the omission of
material facts, well knowing and having reason to know that said pretenses were
and would be false and fraudulent when made and caused to be made and that
said omissions were and would be material, and, in so doing, caused interstate
and foreign wire communications to be made, in furtherance of the scheme and
artifice to defraud, in violation of Title 18, United States Code, Section 1343.
Manner and Means
151.
DIXON, FOSTER, and WHITrLEY, together with Darrell Thomas and
others known and unknown to the Grand Jury, conspired to submit false
materials, such as a false PPP loan application, false IRS Form 941s, and false
payroll spreadsheets, to a financial institution to obtain PPP loan funding.
152.
Throughout the conspiracy, DIxoN, FoSTER, and WHITmEY utilized
interstate wires to submit and assist in the submission of false documents to at
least two lenders when applying for a PPP loan, including fabricated IRS Form
941s listing falsified payroll information, fabricated payroll spreadsheets listing
non-existent employees and payroll expenses, and false loan application
documentation that listed false payroll information, false employment
information, and false purposes for the loan funding.
153.
In one submission of a false application for a PPP loan to a financial
institution, DIXON listed in the application stolen personally identifiable
information belonging to “S.R.”
51
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154.
As a result of and based on DIXON’s, FOSTER’s, and WHITrLEY’s false
representations and certifications and falsified supporting documents, a different
financial institution issued a $797,275 PPP loan to ML Exotic Customs Inc.
All in violation of Title 18, United States Code, Section 1349.
Count Twenty-Eight
Wire Fraud — 18 U.S.C. § 1343 and § 2
(Defendants DIXON, FOSTER, and WHflTLEY)
155.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 151 through 154 of this
First Superseding Indictment as if fully set forth herein.
156.
On or about June 19, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
RIcKY DIXON,
TELDRIN FOSTER, and
RYAN WHITTLEY,
aided and abetted by each other, Darrell Thomas, and others known and
unknown to the Grand Jury, for the purpose of executing and attempting to
execute the aforementioned scheme and artifice to defraud, and to obtain money
and property by means of materially false and fraudulent pretenses,
representations, arid promises, and by omission of material facts, did, with intent
to defraud, cause to be transmitted by means of a wire communication in
interstate and foreign commerce certain writings, signs, signals, and sounds,
namely, a PPP Borrower Application Form containing false information related
to ML Exotic Customs Inc.’s payroll obligations and the purposes of the applied
52
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for PPP loan, and attaching falsified tax documentation for each quarter of 2019
and falsified payroll spreadsheets.
All in violation of Title 18, United States Code, Section 1343 and Section 2.
Count Twenty-Nine
Aggravated Identity Theft - 18 U.S.C. § 1028A and § 2
(Defendant DIXON)
157.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 151 through 154 of this
First Superseding Indictment as if fully set forth herein.
158.
On or about June 19, 2020, in the Northern District of Georgia and
elsewhere, the Defendant,
RIcKY DIXON,
aided and abetted by Darrell Thomas and others known and unknown to the
Grand Jury, did knowingly possess and use, without lawful authority, a means
of identification of another person, that is, a social security number and date of
birth belonging to “S.R.,” during and in relation to a felony offense, that is,
Conspiracy to Commit Wire Fraud, in violation of Title 18, United States Code,
Section 1349, as alleged in Count Twenty-Seven of this First Superseding
Indictment.
All in violation of Title 18, United States Code, Section 1028A(a)(1) and
Section 2.
53
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Count Thirty
Conspiracy to Commit Wire Fraud - 18 U.S.C. § 1349
(Defendants FOsmR, A5H0NG, and SALL)
159.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 of this First Superseding
Indictment as if fully set forth herein.
160.
From in or about April 2020 through in or about June 2020, the exact
dates unknown, in the Northern District of Georgia and elsewhere, the
Defendants,
TELDRIN FOSTER,
DwAN AsH0NG, and
EL HADJ SALL,
did knowingly and willfully combine, conspire, confederate, agree, and have a
tacit understanding with each other, Darrell Thomas, and others known and
unknown to the Grand Jury, to devise and intend to devise a scheme and artifice
to defraud, and to obtain money and property, by means of materially false and
fraudulent pretenses, representations, and promises, and by the omission of
material facts, well knowing and having reason to know that said pretenses were
and would be false and fraudulent when made and caused to be made and that
said omissions were and would be material, and, in so doing, caused interstate
and foreign wire communications to be made, in furtherance of the scheme and
artifice to defraud, in violation of Title 18, United States Code, Section 1343.
Manner and Means
161.
FOSTER, ASHONG, and SALL, together with Darrell Thomas and
others known and unknown to the Grand Jury, conspired to submit false
54
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materials, such as a false PPP loan application, false IRS Form 941s, and false
payroll spreadsheets, to a financial institution to obtain PPP loan funding.
162.
Throughout the conspiracy, FosmR, AsH0NG, arid SALL utilized
interstate wires to submit and assist in the submission of false documents to a
lender when applying for a PPP loan, including fabricated IRS Form 941s listing
falsified payroll information, fabricated payroll spreadsheets listing non-existent
employees and payroll expenses, and false loan application documentation that
listed false payroll information, false employment information, and false
purposes for the loan funding.
163.
As a result of and based on FOSTER’s, ASHONG’s, and SALL’s false
representations and certifications and falsified supporting documents, a financial
institution issued an $823,585 PPP loan to Bellevie Corp.
All in violation of Title 18, United States Code, Section 1349.
Count Thirty-One
Wire Fraud - 18 U.S.C. § 1343 and § 2
(Defendants FOSTER, ASH0NG, and SALL)
164.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 161 through 163 of this
First Superseding Indictment as if fully set forth herein.
165.
On or about June 26, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
TELDRIN FOSTER,
DwAN ASHONG and
EL HADJ SALL,
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aided and abetted by each other, Darrell Thomas, and others known and
unknown to the Grand Jury, for the purpose of executing and attempting to
execute the aforementioned scheme and artifice to defraud, and to obtain money
and property by means of materially false and fraudulent pretenses,
representations, and promises, and by omission of material facts, did, with intent
to defraud, cause to be transmitted by means of a wire communication in
interstate and foreign commerce certain writings, signs, signals, and sounds,
namely, a PPP Borrower Application Form containing false information related
to Bellevie Corp.’s payroll obligations and the purposes of the applied-for PPP
loan, and attaching falsified tax documentation for each quarter of 2019 and
falsified payroll spreadsheets.
All in violation of Title 18, United States Code, Section 1343 and Section 2.
Count Thirty-Two
Conspiracy to Commit Wire Fraud - 18 U.S.C. § 1349
(Defendants FosTER and CHRISTIAN)
166.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 of this First Superseding
Indictment as if fully set forth herein.
167.
From in or about April 2020 through in or about June 2020, the exact
dates unknown, in the Northern District of Georgia and elsewhere, the
Defendants,
TELDRIN FOSTER and
AMANDA CHRISTIAN,
did knowingly and willfully combine, conspire, confederate, agree, and have a
tacit understanding with each other, Darrell Thomas, Denesseria Slaton, and
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others known and unknown to the Grand Jury, to devise and intend to devise a
scheme and artifice to defraud, and to obtain money and property, by means of
materially false and fraudulent pretenses, representations, and promises, and by
the omission of material facts, well knowing and having reason to know that said
pretenses were and would be false and fraudulent when made and caused to be
made and that said omissions were and would be material, and, in so doing,
caused interstate and foreign wire communications to be made, in furtherance of
the scheme and artifice to defraud, in violation of Title 18, United States Code,
Section 1343.
Manner and Means
168.
FoSTER and CHRIsTIAN, together with Darrell Thomas, Denesseria
Slaton, and others known and unknown to the Grand Jury, conspired to submit
false materials, such as a false PPP loan application, false IRS Form 941s, and
false payroll spreadsheets, to a financial institution to obtain PPP loan funding.
169.
Throughout the conspiracy, FosTER and CHRISTIAN utilized
interstate wires to submit and assist in the submission of false documents to a
lender when applying for a PPP loan, including fabricated IRS Form 941s listing
falsified payroll information, fabricated payroll spreadsheets listing non-existent
employees and payroll expenses, and false loan application documentation that
listed false payroll information, false employment information, and false
purposes for the loan funding.
170.
As a result of and based on FOSTER’s and CHRISTIAN’s false
representations and certifications and falsified supporting documents, a financial
institution issued a $760,207 PPP loan to Advertising and Then Some Inc.
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All in violation of Title 18, United States Code, Section 1349.
Count Thirty-Three
Wire Fraud - 18 U.S.C. § 1343 and § 2
(Defendants FOSTER and CHRISTIAN)
171.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 168 through 170 of this
First Superseding Indictment as if fully set forth herein.
172.
On or about June 19, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
TELDRIN FOSTER and
AMANDA CHRISTIAN,
aided and abetted by each other, Darrell Thomas, Denesseria Slaton, and others
known and unknown to the Grand Jury, for the purpose of executing and
attempting to execute the aforementioned scheme and artifice to defraud, and to
obtain money and property by means of materially false and fraudulent
pretenses, representations, and promises, and by omission of material facts, did,
with intent to defraud, cause to be transmitted by means of a wire
communication in interstate and foreign commerce certain writings, signs,
signals, and sounds, namely, a PPP Borrower Application Form containing false
information related to Advertising and Then Some Inc.’s payroll obligations and
the purpose of the applied-for PPP loan, and attaching falsified tax
documentation for each quarter of 2019 arid falsified payroll spreadsheets.
All in violation of Title 18, United States Code, Section 1343 and Section 2.
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Count Thirty-Four
Conspiracy to Commit Wire Fraud — 18 U.S.C. § 1349
(Defendants FosTER, CHRISnAN and McDuFFIE)
173.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 of this First Superseding
Indictment as if fully set forth herein.
174.
From in or about April 2020 through in or about August 2020, the
exact dates unknown, in the Northern District of Georgia and elsewhere, the
Defendants,
TELDRIN FOSTER,
AMANDA CHRISTIAN and
RICK MCDuFFIE,
did knowingly and willfully combine, conspire, confederate, agree, and have a
tacit understanding with each other, Darrell Thomas, Denesseria Slaton, and
others known and unknown to the Grand Jury, to devise and intend to devise a
scheme and artifice to defraud, and to obtain money and property, by means of
materially false and fraudulent pretenses, representations, and promises, and by
the omission of material facts, well knowing and having reason to know that said
pretenses were and would be false and fraudulent when made and caused to be
made and that said omissions were and would be material, and, in so doing,
caused interstate and foreign wire communications to be made, in furtherance of
the scheme and artifice to defraud, in violation of Title 18, United States Code,
Section 1343.
Manner and Means
175.
FOSTER, CHRIsTIAN, and MCDuFFIE, together with Darrell Thomas,
Denesseria Slaton, and others known and unknown to the Grand Jury, conspired
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to submit false materials, such as a false PPP loan application, false IRS Form
941s, and false payroll spreadsheets, to a financial institution to obtain PPP loan
funding.
176.
Throughout the conspiracy, FosTER, CHRISTIAN, and McDuFFIE
utilized interstate wires to submit and assist in the submission of false
documents to a lender when applying for a PPP loan, including fabricated IRS
Form 941s listing falsified payroll information, fabricated payroll spreadsheets
listing non-existent employees and payroll expenses, and false loan application
documentation that listed false payroll information, false employment
information, and false purposes for the loan funding.
177.
As a result of and based on FOSTER’s, CHRISTIAN’s, and MCDUFFIE’s
false representations and certifications and falsified supporting documents, a
financial institution issued a $787,160 PPP loan to Mickies Auto and Tires LLC.
All in violation of Title 18, United States Code, Section 1349.
Count Thirty-Five
Wire Fraud-18 U.S.C. §1343and~2
(Defendants FosTER, CHRIST[AN, and MCDUFFIE)
178.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 175 through 177 of this
First Superseding Indictment as if fully set forth herein.
179.
On or about August 10, 2020, in the Northern District of Georgia and
elsewhere, the Defendants,
TELDRIN FOSTER,
AMANDA CHRISTIAN, and
RICK MCDUFFIE,
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aided and abetted by each other, Darrell Thomas, Denesseria Slaton, and others
known and unknown to the Grand Jury, for the purpose of executing and
attempting to execute the aforementioned scheme and artifice to defraud, and to
obtain money and property by means of materially false and fraudulent
pretenses, representations, and promises, and by omission of material facts, did,
with intent to defraud, cause to be transmitted by means of a wire
communication in interstate and foreign commerce certain writings, signs,
signals, and sounds, namely, a PPP Borrower Application Form containing false
information related to Mickies Auto and Tire’s payroll obligations and the
purposes of the applied-for PPP loan, and attaching falsified tax documentation
for each quarter of 2019 and falsified payroll spreadsheets.
All in violation of Title 18, United States Code, Section 1343 and Section 2.
Counts Thirty-Six Through Forty-One
False Statement to a Federally Insured Bank — 18 U.S.C. § 1014 and § 2
(Defendants Identified Below)
180.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60, 70 through 72, 80 through 82,
90 through 92, 100 through 102, 110 through 112, and 127 through 129 of this
First Superseding Indictment as if fully set forth herein.
181.
From in or about April 2020 through in or about June 2020, the exact
dates unknown, in the Northern District of Georgia and elsewhere, the
Defendants identified below, aided and abetted by each other, Darrell Thomas,
Denesseria Slaton, Khalil Gibran Green, Sr., Bern Benoit, and others known and
unknown to the Grand Jury, knowingly made a false statement for the purpose
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of influencing the actions of the financial institutions identified below, the
accounts of which were insured by the FDIC, in connection with PPP loan
applications by the businesses identified below, in that the Defendants did the
following:
JESIKA BLAKELY
TELDRIN FosTER
JOHN GAINEs
known and unknown to the
Grand Jury, signed and
initialed a PPP Borrower
Application Form for Impact
Creations LLC falsely certifying
that (a) Impact Creations LLC
was in operation on February
15, 2020 and had employees for
whom it paid salaries and
payroll taxes or paid
independent contractors; (b)
the funds wifi be used to retain
workers and maintain payroll
or make mortgage interest
payments, lease payments, and
utility payments; and (c) the
information provided in the
application and in all
supporting documents and
forms is true and accurate in all
material respects.
BLAKELY, FOSTER, and JOHN
GAINES, aided and abetted
by each other and by others
known and unknown to the
Grand Jury, signed and
initialed a PPP Borrower
Application Form for Gaines
Reservation and Travel falsely
certifying that (a) Gaines
Reservation and Travel was in
operation on February 15, 2020
and had employees for whom it
Financial
Institution
1
36
JESIKA BLAKELY
May 17, 2020
BLAKELY and FOSTER, aided
Financial
TELDRIN FOSTER
and abetted by others
Institution
1
37
May 18, 2020
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paid salaries and payroll taxes
or paid independent
contractors; (b) the funds will
be used to retain workers and
maintain payroll or make
mortgage interest payments,
lease payments, and utility
payments; and (c) the
information provided in the
application and in all
supporting documents and
forms is true and accurate in all
_______
_____________________
material respects.
____________
38
TELDRIN FOSTER
May 20, 2020
FOSTER, CHRISTIAN, PETTY,
Financial
AMANDA CHRISTIAN
and BAPTISTE, aided and
Institution
CHARLEs PErrY’
abetted by each other and
JERRY BAPTISTE
by others known and
unknown to the Grand
Jury, signed and initialed a
PPP Borrower Application
Form for Transportation
Management Services Inc.
falsely certifying that (a)
Transportation Management
Services Inc. was in operation
on February 15, 2020 and had
employees for whom it paid
salaries and payroll taxes or
paid independent contractors;
(b) the funds will be used to
retain workers and maintain
payroll or make mortgage
interest payments, lease
payments, and utility
payments; and (c) the
information provided in the
application and in all
supporting documents and
forms is true and accurate in all
material respects.
39
RIcKY DIXON
May 20, 2020
DIxON and FOSTER, aided
Financial
TELDRIN FOSTER
and abetted by others
Institution
known and unknown to the
2
Grand Jury, signed and
initialed a PPP Borrower
Application Form for Lee
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Operations LLC falsely
certifying that (a) Lee
Operations LLC was in
operation on February 15, 2020
and had employees for whom it
paid salaries and payroll taxes
or paid independent
contractors; (b) the funds will
be used to retain workers and
maintain payroll or make
mortgage interest payments,
lease payments, and utility
payments; and (c) the
information provided in the
application and in all
supporting documents and
forms is true and accurate in all
______
____________________
_____________
material respects.
____________
40
RICKY DIXON
May 15, 2020
DIXON, BLAKELY, and
Financial
JESIKABLAKELY
FOSTER, aided and abetted
Institution
TELDRINFOSmR
by each other and by others
3
known and unknown to the
Grand Jury, signed and
initialed a PPP Borrower
Application Form for RK
Painting Co. falsely certifying
that (a) RK Painting Co. was in
operation on February 15, 2020
and had employees for whom it
paid salaries and payroll taxes
or paid independent
contractors; (b) the funds will
be used to retain workers and
maintain payroll or make
mortgage interest payments,
lease payments, and utility
payments; and (c) the
information provided in the
application and in all
supporting documents and
forms is true and accurate in all
material respects.
41
MEGHAN THOMAS
June 12, 2020
MEGHAN THOMAS, FOSTER,
Financial
TELDRIN FOSTER
CHRISTIAN, and BELGRAvE,
Institution
AMANDA CHRISTIAN
aided and abetted by each
3
DAVID BELGRAVE II
other and by others known
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and unknown to the Grand
Jury, signed and initialed a
PPP Borrower Application
Form for Continuing Success
Inc. falsely certifying that (a)
Continuing Success Inc. was in
operation on February 15, 2020
and had employees for whom it
paid salaries and payroll taxes
or paid independent
contractors; (b) the funds will
be used to retain workers and
maintain payroll or make
mortgage interest payments,
lease payments, and utility
payments; and (c) the
information provided in the
application and in all
supporting documents and
forms is true and accurate in all
material respects.
All in violation of Title 18, United States Code, Section 1014 and
Section 2.
Counts Forty-Two through Fifty-Nine
Money Laundering -18 U.S.C. § 1956 and § 2
(Defendants Identified Below)
182.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60, 63 through 65, 80 through 82,
90 through 92, 100 through 102, 110 through 112, 120 through 122, 127 through
129, and 144 through 146 of this First Superseding Indictment as if fully set forth
herein.
183.
From in or about May 2020 through in or about September 2020, in
the Northern District of Georgia and elsewhere, the Defendants identified below,
aided and abetted by each other, by Darrell Thomas, and by others known and
unknown to the Grand Jury, knowingly conducted and attempted to conduct a
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financial transaction affecting interstate commerce, which involved the proceeds
of a specified unlawful activity, that is wire fraud, in violation of Title 18, United
States Code, Section 1343, knowing that the transaction was designed in whole
and in part to conceal and disguise the nature, location, source, ownership, and
control of the proceeds of specified unlawful activity, and while conducting and
aftempting to conduct such financial transactions knowing that the property
involved in the financial transaction represented the proceeds of some form of
unlawful activity:
43
RICKY DIXON
June 2, 2020
Approximately $102,000 wire transfer
from Bank 4 account ending in 4823, held
in the name of Elite Executive Services
Inc., to Bank 2 account ending in 2768,
held in the name of AF Holdings Inc.
44
JOHN GAINES
May 29, 2020
Approximately $93,785 check withdrawn
from Bank 1 account ending in 6500, held
in the name of Gaines Reservation and
Travel, and deposited into Bank 4 account
ending in 3940, held in the name of
Bellator Phront Group Inc.
45
JOHN GAINES
June 16, 2020
Approximately $169,998.72 check
withdrawn from Bank 1 account ending in
6500, held in the name of Gaines
Reservation and Travel, and deposited
into Bank 4 account ending in 4823, held in
the name of Elite Executive Services Inc.
46
JOHN GAINES
June 8, 2020
Approximately $155,252.50 wire transfer
CARLA JACKSON
from Bank 1 account ending in 6500, held
in the name of Gaines Reservation and
Travel, to BankS account ending in 1207,
held in the name of Management Resource
Services Inc.
42
Approximately $~, ~J0 wire transfer from
Bank 6 account ending in 6131, held in the
name of Bellator Phront Group Inc., to
Bank 2 account ending in 2768, held in the
name of AF Holdings Inc.
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47
JOHN GAINES
June 22, 2020
Approximately $179,985.72 wire transfer
CARLA JACKSON
from Bamk 3 account ending in 5124, held
in the name of Gaines Reservation and
Travel, to Bank 5 account ending in 1207,
held in the name of Management Resource
Services Inc.
48
CHARLES PETTY
May 29, 2020
Approximately $185,000 check withdrawn
JERRY BAPTISTE
from Bank 1 account ending in 6415, held
in the name of Transportation
Management Services Inc., and deposited
into Bank 4 account ending in 3940, held in
the name of Bellator Phront Group Inc.
49
CHARLES PETTY
June 15, 2020
Approximately $100,000 check withdrawn
JERRY BAPTISTE
from Bank 1 account ending in 6415, held
in the name of Transportation
Management Services Inc., and deposited
into Bank 4 account ending in 3940, held in
the name of Bellator Phront Group Inc.
50
CHARLES PETTY
June 15, 2020
Approximately $169,998.72 wire transfer
JERRY BAPTISTE
from Bank 1 account ending in 6415, held
in the name of Transportation
Management Services Inc., to Bank 4
account ending in 4823, held in the name
~________
of Elite Executive Services Inc.
51
RICKY DIXON
May 21, 2020
Approximately $803,775.89 wire transfer
from Bank 2 account ending in 5085, held
in the name of Lee Operations, to Bank 4
account ending in 4823, held in the name
of Elite Executive Services Inc.
52
RICKY DIXON
June 9, 2020
Approximately $175,000 check from Bank
7 Bank account ending in 5594, held in the
name of RK Painting Co., deposited into
Bank 4 account ending in 3940, held in the
name of Bellator Phront Group Inc.
53
RICKY DIXON
June 19, 2020
Approximately $163,625 wire transfer
DEREK PARKER
from Bank 4 account ending in 9593, held
in the name of D Parker Holdings Inc., to
Bank 6 account ending in 6131, held in the
name of Bellator Phront Group Inc.
54
JESIKA BLAKELY
September 18, 2020
Approximately $5,000 ACH transfer from
DAVID BELGRAVE II
Bank 8 account ending in 4647, held in the
name of J.L., to Bank 6 account ending in
5550, held in the name of Manchester
Alliance.
55
JESIKA BLAKELY
July 21, 2020
Approximately $282,633 wire transfer
CHARLES HrLL IV
from BankS account ending in 5633, held
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in the name of Infinite Education Services
Inc., to Bank 8 account ending in 6687,
held in the name of Rapid Pay Card.
56
JESIKA BLAKELY
August 11, 2020
Approximately $281,496 wire transfer
CHARLES HILL IV
from Bank 5 account ending in 5633, held
in the name of Infinite Education Services
Inc., to Bank 8 account ending in 6687,
held in the name of Rapid Pay Card.
57
DwAN ASH0NG
July 21, 2020
Approximately $134,873 wire transfer
from Bank 5 account ending in 5633, held
in the name of Infinite Education Services
Inc., to Bank 9 account ending in 9950,
held in the name of Richiand Property
Investment Group.
58
DwAN ASH0NG
June 2, 2020
Approximately $47,400 check from Bank 4
account ending in 4823, held in the name
of Elite Executive Services Inc., deposited
into Bank 1 account ending in 1813, held in
the name of DA Gilpen Enterprises LLC.
59
TELDRIN FoSTER
June 11, 2020
Approximately $10,560 check from Bank 4
account ending in 3940, held in the name
of Bellator Phront Group Inc., deposited
into Bank 4 account ending in 3668, held in
the name of Pyfrom Exclusive Consulting.
All in violation of Title 18, United States Code, Section 1956(a)(1)(B)(i) and
Section 2.
Count Sixty
Conspiracy to Commit Money Laundering - 18 U.S.C. § 1956(h)
(Defendants BLAKELY, AsH0NG, and BELGRAvE)
184.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 127 through 129 of this
First Superseding Indictment as if fully set forth herein.
185.
From in or about June 2020 through in or about September 2020, in
the Northern District of Georgia and elsewhere, the Defendants,
JESIKA BLAKELY
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DwAN AsH0NG, and
DAvID BELGRAvE II,
did knowingly combine, conspire, and agree with each other, with Darrell
Thomas and Denesseria Slaton, and with others known and anknown to the
Grand Jury to commit offenses against the United States in violation of Title 18,
United States Code, Section 1956, to wit, to knowingly conduct and attempt to
conduct financial transactions affecting interstate commerce and foreign
commerce, which transactions involved the proceeds of specified unlawful
activity, that is, bank fraud in violation of Title 18, United States Code, Section
1344, and wire fraud, in violation of Title 18, United States Code, Section 1343,
knowing that the transactions were designed in whole and in part to conceal and
disguise the natuie, location, source, ownership, and control of the proceeds of
specified unlawful activity, and while conducting and attempting to conduct
such financial transactions, knowing that the property involved in the financial
transactions represented the proceeds of some form of unlawful activity, in
violation of Title 18, United States Code, Section 1956(a)(1)(B)(i).
Manner and Means
186.
BLAKELY, ASHONG, and BELGRAvE, together with Darrell Thomas and
Denesseria Slaton and with others known and unknown to the Grand Jury,
conspired to engage in financial transactions with the proceeds of Continuing
Success Inc.’s PPP loan proceeds that were designed in whole and in part to
conceal and disguise the nature, location, source, ownership, and control of
Continuing Success Inc.’s PPP loan proceeds.
187.
Throughout the conspiracy, BLAKELY, ASHONG, and BELGRAvE
conducted and attempted to conduct various financial transactions, including:
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a.
On or about June 30, 2020, August 5, 2020, and September 11,
2020, wire transfers of approximately $168,875.35 each from
Bank 11 account ending in 4282, held in the name Continuing
Success Inc., to Bank 8 account ending in 6687, held in the
name of Rapid Pay Card;
b.
On or about June 30, 2020, a wire transfer of approximately
$195,000 from Bank 11 account ending in 4282, held in the
name of Continuing Success Inc., to Bank 1 account ending in
1588, held in the name of Richiand Property Investors Group.
All in violation of Title 18, United States Code, Section 1956(h).
Count Sixty-One
Conspiracy to Commit Money Laundering
— 18 U.S.C. § 1956(h)
(Defendants DIxoN, BLAKELY, arid AsH0NG)
188.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 137 through 139 of this
First Superseding Indictment as if fully set forth herein.
189.
From in or about June 2020 through in or about September 2020, in
the Northern District of Georgia and elsewhere, the Defendants,
RIcKY DIxON,
JESIKA BLAKELY, and
V
DwAN AsH0NG,
did knowingly combine, conspire, and agree with each other, with Darrell
Thomas and Charmaine Redding, and with others known and unknown to the
Grand Jury to commit offenses against the United States in violation of Title 18,
United States Code, Section 1956, to wit, to knowingly conduct and attempt to
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conduct financial transactions affecting interstate commerce and foreign
commerce, which transactions involved the proceeds of specified unlawful
activity, that is, wire fraud, in violation of Title 18, United States Code, Section
1343, knowing that the transactions were designed in whole and in part to
conceal and disguise the natare, location, source, ownership, and control of the
proceeds of specified unlawful activity, and while conducting and attempting to
conduct such financial transactions, knowing that the property involved in the
financial transactions represented the proceeds of some form of unlawful
activity, in violation of Title 18, United States Code, Section 1956(a) (1) (B) (i).
Manner and Means
190.
DIXON, BLAKELY, and AsH0NG, together with Darrell Thomas and
Charmaine Redding and with others known and unknown to the Grand Jury,
conspired to engage in financial transactions with the proceeds of All Star Room
and Board Services of Michigan Inc.’s PPP loan proceeds that were designed in
whole and in part to conceal and disguise the nature, location, source,
ownership, and control of All Star Room and Board Services of Michigan Inc.’s
PPP loan proceeds.
191.
Throughout the conspiracy, DIXoN, BLAKELY, and AsH0NG
conducted and attempted to conduct various financial transactions, including:
a.
On or about July 1, 2020, August 17, 2020, and September 28,
2020, wire transfers of approximately $153,825.28 from Bank
12 account ending in 4672, held in the name of All Star Room
& Board Services of Michigan, Inc., to Bank 8 account ending
in 6687, held in the name of Rapid Pay Card;
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b.
On or about July 1, 2020, a wire transfer of approximately
$175,800 from Bank 12 account ending in 4672, held in the
name of All Star Room & Board Services of Michigan, Inc., to
Bank 1 account ending in 1588, held in the name of Richiand
Property Investors Group.
All in violation of Title 18, United States Code, Section 1956(h).
Count Sixty-Two
Conspiracy to Commit Money Laundering — 18 U.S.C. § 1956(h)
(Defendants DIxoN, BLAKELY, and WHITI’LEY)
192.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 151 through 154 of this
First Superseding Indictment as if fully set forth herein.
193.
From in or about July 2020 through in or about November 2020, in
the Northern District of Georgia and elsewhere, the Defendants,
RIcKY DIXoN,
JESIKA BLAKELY, and
RYAN WHmTEY,
did knowingly combine, conspire, and agree with each other, with Darrell
Thomas, and with others known and unknown to the Grand Jury to commit
offenses against the United States in violation of Title 18, United States Code,
Section 1956, to wit, to knowingly conduct and attempt to conduct financial
transactions affecting interstate commerce and foreign commerce, which
transactions involved the proceeds of specified unlawful activity, that is, wire
fraud, in violation of Title 18, United States Code, Section 1343, knowing that the
transactions were designed in whole and in part to conceal and disguise the
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nature, location, source, ownership, and control of the proceeds of specified
unlawful activity, and while conducting and attempting to conduct such
financial transactions, knowing that the property involved in the financial
transactions represented the proceeds of some form of unlawful activity, in
violation of Title 18, United States Code, Section 1956(a)(1)(B)(i).
Manner and Means
194.
DIXON, BLAKEIX, and WHrFrLEY, together with Darrell Thomas and
with others known and unknown to the Grand Jury, conspired to engage in
financial transactions with the proceeds of ML Exotic Customs Inc.’s PPP loan
proceeds that were designed in whole and in part to conceal and disguise the
nature, location, source, ownership, and control of ML Exotic Customs Inc.’s PPP
loan proceeds.
195.
conducted
Throughout the conspiracy, DIxoN, BLAKELY, and WHITmEY
and attempted to conduct various financial transactions, including:
a.
On or about July 29, 2020 and August 27, 2020, wire transfers
of approximately $289,441 from Bank 15 account ending in
3842, held in the name of ML Exotic Customs Inc., to Bank 8
account ending in 6687, held in the name of Rapid Pay Card;
b.
On or about October 20, 2020, a wire transfer of approximately
$92,000 from a bank account held in the name of ML Exotic
Customs Inc., to Bank 13 account ending in 6020, held in the
name of Cronus Capital Acquisitions; and
c.
On or about October 26, 2020, a $23,000 check from Bank 13
account ending in 6020, held in the name of Cronus Capital
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Acquisitions, cashed at the New Dolton Currency Exchange in
Chicago, Illinois.
All in violation of Title 18, United States Code, Section 1956(h).
Count Sixty-Three
Conspiracy to Commit Money Laundering — 18 U.S.C. § 1956(h)
(Defendants BLAKELY, ASH0NG and SALL)
196.
The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 60 and 161 through 163 of this
First Superseding Indictment as if fully set forth herein.
197.
From in or about August 2020 through in or about October 2020, in
the Northern District of Georgia and elsewhere, the Defendants,
JESIKA BLAKELY,
DwAN AsH0NG, and
EL HADJ SALL,
did knowingly combine, conspire, and agree with each other, with Darrell
Thomas, and with others known and unknown to the Grand Jury to commit
offenses against the United States in violation of Title 18, United States Code,
Section 1956, to wit, to knowingly conduct and attempt to conduct financial
transactions affecting interstate commerce and foreign commerce, which
transactions involved the proceeds of specified unlawful activity, that is, wire
fraud, knowing that the transactions were designed in whole and in part to
conceal and disguise the nature, location, source, ownership, and control of the
proceeds of specified unlawful activity, and while conducting and attempting to
conduct such financial transactions, knowing that the property involved in the
financial transactions represented the proceeds of some form of unlawful
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activity, in violation of Title 18, United States Code, Section 1956(a) (1) (B) (i).
Manner and Means
198.
BLAKELY, ASH0NG, and SALL, together with Darrell Thomas and with
others known and unknown to the Grand Jury, conspired to engage in financial
transactions with the proceeds of Bellevie Corp.’s PPP loan proceeds that were
designed in whole and in part to conceal and disguise the nature, location,
source, ownership, and control of Bellevie Corp.’s PPP loan proceeds.
199.
Throughout the conspiracy, BLAKELY, AsH0NG, and SALL conducted
and attempted to conduct various financial transactions, including:
a. On or about September 1, 2020, a wire transfer of approximately
$535,000 from Bank 1 account ending in 5393, held in the name of
Bellevie Corp., to Bank 8 account ending in 6687, held in the name of
Rapid Pay Card;
b. On or about September 21, 2020, a wire transfer of approximately
$200,000 from Bank 1 account ending in 5393, held in the name of
Bellevie Corp., to Bank 1 account ending in 1813, held in the name of
DA Gilpen Enterprises LLC;
c. On or about September 21, 2020, a wire transfer of approximately
$143,000 from Bank 1 account ending in 1813, held in the name of
DA Gilpen Enterprises LLC, to Bank 17 account ending in 6801, held
in the name of Hgreg Lux for the purchase of a 2019 Land Rover
Range Rover vehicle.
All in violation of Title 18, United States Code, Section 1956(h).
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Forfeiture
Upon conviction of one or more of the offenses alleged in Counts One
through Forty-One of this First Superseding Indictment, the Defendants,
RIcKY DIXON,
MEGHAN THOMAS,
JESIKA BLAKELY,
TELDifiN FoSTER,
AMANDA CHRISTIAN,
DwAN ASHONG,
JOHN GAINES,
CHARLES PETTY,
JERRY BAPTISTE,
DEREK PARKER,
DAVID BELGRAvE II,
CHARLES HILL IV,
RYAN WHITTLEY,
EL HADJ SALL, and
RICK MCDuFFIE,
shall forfeit to the United States, pursuant to Title 18, United States Code, Section
982(a) (2), any property constituting, or derived from, proceeds the person
obtained directly or indirectly as the result of such violation, including but not
limited to the following:
(a)
MONEY JUDGMENT: A sum of money in United States currency
equal to the amount of proceeds the Defendant obtained as a result
of the offense for which the Defendant is convicted.
(b)
FUNDS:
1.
$1,113,113.97 in funds seized from Bank 4 account
number XXXXXXXX4823 held in the name of Elite
Executive Services, Inc.
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2.
$536,875.00 in funds seized from Bank 4 account
number XXXXXXXX81O2 held in the name of Bellator
Phront Group, Inc.
3.
$431,408.28 in funds seized from Bank 1 account
number XXXXX6415 held in the name of Transportation
Management Services Inc.
4.
$341,151.47 in funds seized from Bank 4 account
number XXXXXXXX394O held in the name of Bellator
Phront Group, LLC.
5.
$295,717.61 in funds seized from Bank 5 account
number XXXXXX12O7 held in the name of Management
Resource Services.
6.
$177,828.46 in funds seized from Bank 1 account
number XXXXX6500 held in the name of Gaines
Reservation and Travel.
7.
$160,025.00 in funds seized from Bank 16 account
number XXXXX7522 held in the name of RK Painting
Company.
8.
$107,878.14 in funds seized from Bank 7 account
number XXXXX5594 held in the name of RK Painting
Co.
9.
$30,025.08 in funds seized from Bank 1 account number
XXXXXX9428 held in the name of Bern Benoit.
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10.
$9,314.28 in funds seized from Bank 3 account number
XXXXXX5124 held in the name of Gaines Reservation
and Travel.
11.
$256.67 in funds seized from Bank 2 account number
XXXXXX5085 held in the name of Lee Operations LLC.
12.
$131,610.00 in United States Currency.
(c)
VEHICLES:
1.
One 2018 Land Rover Range Rover, \TIN
SALGW2SE2JA5O3793.
2.
One 2017 Acura NSX, VIN 19UNC1BO8HY000536.
3.
One 2018 Mercedes Benz S-Class S65 AMG, VIN
WDDUG7KB5JA4O8O46.
4.
One 2019 Land Rover Range Rover, VIN
SALGW2SE2KA516948.
(d)
JEWELRY:
1.
One men’s yellow gold Rolex with diamond bezel and dial.
2.
One 18K yellow gold Cuban link necklace with diamonds in
clasp.
3.
One 18K yellow gold Cuban link bracelet with diamonds in
clasp.
Upon conviction of one or more of the offenses alleged in Counts
Forty-Two through Sixty-Three of this First Superseding Indictment, the
Defendants,
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RIcKY DIXON,
JESIKA BLAKELY,
TELDifiN FOsmR,
DwAN AsH0NG,
JOHN GAINES,
CHARLES PETTY,
JERRY BAPTISTE,
CARLA JACKSON,
DEREK PARKER,
DAVID BELGRAVE II,
CHARLES HILL IV,
RYAN WHITTLEY, and
EL HADJ SALL,
shall forfeit to the United States, pursuant to Title 18, United States
Code, Section 982(a)(1), any property, real or personal, involved in the
offense and any property traceable to such property, including but not
limited to the following:
(a)
MONEY JUDGMENT: A sum of money in United States currency
equal to the amount of proceeds the Defendant obtained as a result
of the offense for which the Defendant is convicted.
(b)
FUNDS:
1.
$1,113,113.97 in funds seized from Bank 4 account
number XXXXXXXX4823 held in the name of Elite
Executive Services, Inc.
2.
$536,875.00 in funds seized from Bank 4 account
number XXXXXXXX81O2 held in the name of Bellator
Phront Group, Inc.
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3.
$431,408.28 in funds seized from Bank 1 account
number XXXXX6415 held in the name of Transportation
Management Services Inc.
4.
$341,151.47 in funds seized from Bank 4 account
number XXXXXXXX3940 held in the name of Bellator
Phront Group, LLC.
5.
$295,717.61 in funds seized from Bank 5 account
number XXXXXX12O7 held in the name of Management
Resource Services.
6.
$177,828.46 in funds seized from Bank 1 account
number XXXXX6500 held in the name of Gaines
Reservation and Travel.
7.
$160,025.00 in funds seized from Bank 16 account
number XXXXX7522 held in the name of RK Painting
Company.
8.
$107,878.14 in funds seized from Bank 7 account
number XXXXX5594 held in the name of RK Painting
Co.
9.
$30,025.08 in funds seized from Bank 1 account number
XXXXXX9428 held in the name of Bern Benoit.
10.
$9,314.28 in funds seized from Bank 3 account number
XXXXXX5124 held in the name of Gaines Reservation
and Travel.
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11.
$256.67 in funds seized from Bank 2 account number
XXXXXX5O85 held in the name of Lee Operations LLC.
12.
$131,610.00 in United States Currency.
(c)
VEHICLES:
1.
One 2018 Land Rover Range Rover, VIN
SALGW25E2JA503793.
2.
One 2017 Acura NSX, VIN 19UNC1B08Hy000536.
3.
One 2018 Mercedes Benz S-Class S65 AMG, VIN
WDDUG7KB5JA4O8O46.
4.
One 2019 Land Rover Range Rover, \TIN
SALGW2SE2KA516948.
(d)
JEWELRY:
1.
One men’s yellow gold Rolex with diamond bezel and dial.
2.
One 18K yellow gold Cuban link necklace with diamonds in
clasp.
3.
One 18K yellow gold Cuban link bracelet with diamonds in
clasp.
If, as a result of any act or omission of the Defendants, any property subject to
forfeiture:
(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
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(e)
has been commingled with other property which cannot be divided
without difficulty,
the United States intends, pursuant to Title 21, United States Code, Section
as incorporated by Title 18, United States Code, Section 982(b), to seek
forfeiture of any other property of the Defendants up to the value of the
forfeitable property described above.
FO ~t PEW ON
KURT R. ERsKINE
Acting United States Attorney
7~iCIa6~
TAL C. CHAIKEN
Assistant United States Attorney
Georgia Bar No. 273949
NATHAN P. KITcHENs
Assistant United States Attorney
Georgia Bar No. 263930
600 U.S. Courthouse
75 Ted Turner Drive SW
Atlanta, GA 30303
404-581-6000; Fax: 404-581-6181
JOSEPH BEEMSmRB0ER
Acting Chief Fraud Section
U.S. Department ofJustice
SIJI MooRE
Trial Attorney, Fraud Section
U.S. Department ofJustice
1400 New York Ave. NW
Bond Building, 11th Floor
Washington, DC 20005
202-514-2000; Fax: 202-514-3708
BILL
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