Indictment as to Malaina Chapman (1) count(s) 1, 2-5, 6, 7-12 — United States v. Chapman (Dkt. 14, S.D. Fla. No. 1:24-cr-20321)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:24-cr-20321-RAR · Doc. 14 · 2024-07-26 · Docket on CourtListener

Full text

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MP
Jul 25, 2024
MIAMI

3.
The Coronavirus Aid, Relief, and Economic Security ("CARES") Act was a federal
law enacted in or around March 2020 and designed to provide emergency financial assistance to 
the millions of business owners who were suffering the economic effects caused by the COVID-
19 pandemic. One source of relief provided by the CARES Act was the authorization of forgivable 
loans to small businesses, including sole proprietorships, for job retention and certain other 
expenses, through a program referred to as the Paycheck Protection Program ("PPP"). 
4.
In order to obtain a PPP loan, a qualifying sole proprietorship submitted a PPP loan
application, which was signed by an authorized representative of the business. The PPP loan 
application required the sole proprietorship (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 (SBA Form 2483-C), a sole proprietorship without 
employees (through its authorized representative) was required to provide, among other things, the 
total amount of gross income reported on its 2019 or 2020 Internal Revenue Service ("IRS") Form 
1040, Schedule C, line 7 ("Schedule C"). This figure was used to calculate the amount of money 
the sole proprietorship was eligible to receive under the PPP. 
5.
A PPP loan application was processed by a participating lender. If a PPP loan
application was approved, the participating lender funded the PPP loan using its own monies. 
While it was the participating lender that issued the PPP loan, the loan was 100% guaranteed by 
the SBA. Data from the application, including information about the borrower and the total 
amount of the loan, was transmitted by the lender to the SBA in the course of processing the loan. 
6.
PPP loan proceeds were required to be used by the business on certain permissible
expenses-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 
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these expense items within a designated period of time and used a defined portion of the PPP loan 
proceeds on payroll costs. 
7.
In 2021, "Second Draw" PPP loans became available to PPP applicants who used
the full loan amount of their PPP funds on eligible expenses. 
The Economic Injury Disaster Loan Program 
8.
Another related response to the COVID-19 outbreak was an expansion of an
existing disaster-related progrw -the Ec°-nxlilic Injury Disaster Lo':11 ('EIDL")- to proyide for_
loan assistance (including $10,000 advances) for small businesses and other eligible entities for 
loans up to $2 million. The EIDL proceeds could have been used to pay fixed debts, payroll, 
accounts payable, and other bills that could have been paid had the disaster not occurred; however, 
such loan proceeds were not intended to replace lost sales or profits, or for the expansion of a 
business. 
9.
Unlike certain other types of SBA-guaranteed loans, EIDL funds were issued
directly from the United States Treasury, and applicants applied for EIDL funds directly through 
the SBA via an online portal and application. The EIDL application process, which also used 
certain outside contractors for system support, collected information concerning the business and 
the business owner, including: information about the gross revenues for the business prior to 
January 31, 2020; and the cost of goods sold. Applicants electronically certified that the 
information provided was true and accurate and were warned that any false statement or 
misrepresentations to the SBA, or any misapplication of loan proceeds may result in sanctions, 
including criminal penalties. 
10.
EIDL applications were received in and processed using computer servers located
in the states of Iowa, Virginia, and Washington. EIDL disbursement payments were initiated by 
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the SBA using computer servers located in the state of Colorado, which transmitted the payment 
information to the Treasury using computer servers located in the state of Virginia. 
11. 
Loans. 
12. 
13. 
loans. 
14. 
loans. 
The Defendant, Related Individuals, Related Companies and Lenders 
Lender 1, based in Laguna Hills, California, was an SBA- approved lender of PPP 
Lender 2, based in Lake Mary, Florida, was an SBA-approved lender of PPP loans. 
Lender 3, based in New York, New York, was an SBA-approved lender of PPP 
Lender 4, based in Coral Gables, Florida, was an SBA-approved lender of PPP 
15.
Financial Technology Company 1, based in San Francisco, California, provided
identification verification services to PPP lenders. 
16.
MALAINA CHAPMAN, a resident of Miami-Dade County, Florida was
employed by the SBA as a Disaster Relief Specialist from September 28, 2020, until she resigned 
on March 18, 2021. 
17.
DA TRAP LLC ("DA TRAP") was a Florida Corporation that listed its principal
place ofbusiness as 15757 Pines Blvd. Suite 116 Pembroke Pines, Florida, 33027. MALAINA 
CHAPMAN was listed as the Manager of DA TRAP 
18.
UPSCALE CREDIT LOUNGE LLC ("UPSCALE CREDIT LOUNGE") was a
Florida corporation that listed its principal place of business as 5901 NW 183rd St Miami Gardens, 
Florida, 33015. MALAINA CHAPMAN was listed as the Manager of UPSCALE CREDIT 
LOUNGE. 
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19.
Credit Union I was a credit union that extended traditional banking services to
residents of Miami-Dade County and elsewhere. Credit Union I was an institution that is insured 
by the National Credit Union Administration. Credit Union 1 allowed individuals to apply for a 
Home Equity Line of Credit ("HELOC"). 
20.
Museum I was a museum located in Miami-Dade County.
21.
The City ofMiami Emergency Rental Assistance Program was a Covid-19 program
designed to help Miami residents facing economic hardship pay their rent. 
22.
The State of Florida Emergency Rental Assistance Program was a Covid-19
program designed to help Florida residents facing economic hardship pay their rent. 
23.
Individual I was a resident Brevard County, Florida.
24.
Individual 2 was a resident of Miami-Dade County.
25.
Individuals 3 and 4 were residents of Miami-Dade County.
26.
Individual 5, a resident of Miami-Dade County, is the former domestic partner of
MALAINA CHAPMAN. Individual 5 was detained by the Miami-Dade County Department of 
Corrections from June 22, 2020, through August 12, 2022. 
27.
E.J., a resident of Miami-Dade County, was MALAINA CHAPMAN'S mother.
According to the Bureau of Vital Statistics, E.J. died on May 25, 2020. 
28.
Raisha Kelly was a resident Miami-Dade and Palm Beach Counties.
29.
Widny Thibaud was a resident of Miami-Dade and Palm Beach Counties.
30.
Ricky Norwood was a resident of Miami-Dade County.
COUNTl 
Conspiracy to Commit Wire Fraud 
(18 u.s.c. § 1349) 
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1.
Paragraphs 1 through 16 and 23, 24 and 28 through 30 of the General Allegations
Section of this Indictment are re-alleged and incorporated by reference as though fully set forth 
herein. 
2.
From in or around March of 2021, and continuing through on or about December
30, 2021, in Miami-Dade and Broward Counties, in the Southern District of Florida, and 
elsewhere, the defendant, 
MALAINA CHAPMAN, 
- -
-
did willfully, that is, with the intent to further the object of the conspiracy, and knowingly combine, 
conspire, confederate, and agree with Raisha Kelly, Widny Thibaud, Ricky Norwood, Individuals 
1 and 2, and others known and unknown to the Grand Jury, to knowingly, and with the intent to 
defraud, 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, 
knowing that the pretenses, representations, and promises were false and fraudulent when made, 
and, for the purpose of executing the scheme and artifice, did knowingly transmit and cause to be 
transmitted, by means of wire communications in interstate and foreign commerce, certain 
writings, signs, signals, pictures, and sounds, in violation of Title 18, United States Code, Section 
1343. 
PURPOSE OF THE CONSPIRACY 
3.
It was the purpose of the conspiracy for the defendant and her co-conspirators to
unjustly enrich themselves by, among other things: (a) submitting and causing the submission of 
false and fraudulent applications for loans made available through the SBA to provide relief for 
the economic effects caused by the COVID-19 pandemic, including PPP loans; and (b) diverting 
fraud proceeds for their personal use, the use and benefit of others, and to further the conspiracy. 
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MANNER AND MEANS OF THE CONSPIRACY 
The manner and means by which the defendant and her co-conspirators sought to 
accomplish the object and purpose of the conspiracy included, among others, the following: 
4.
MALAINA CHAPMAN, Raisha Kelly, Widny Thibaud, Ricky Norwood and
Individuals 1 and 2 submitted and caused the submission of fraudulent PPP and EIDL loan 
applications, on behalf of themselves and corporate entities that they controlled. 
5.
In furtherance of the scheme, MALAINA CHAPMAN, Raisha Kelly, Widny
Thibaud, Ricky Norwood and Individuals 1 and 2 submitted and caused the submission of false 
and fraudulent information and documentation in support of the PPP loan applications, including 
falsified IRS forms, created by CHAPMAN, that falsely and fraudulently represented the annual 
gross receipts and tentative profits of the sole proprietorships and corporate entities they 
controlled. 
6.
In furtherance of the scheme, MALAINA CHAPMAN prepared false and
fraudulent Schedule C's and emailed them to Raisha Kelly. 
7.
MALAINA CHAPMAN, Raisha Kelly, Widny Thibaud, Ricky Norwood and
Individuals 1 and 2 and their co-conspirators used the proceeds from the scheme to emich 
themselves and others and to further the scheme. 
All in violation of Title 18, United States Code, Section 1349. 
COUNTS2-5 
Wire Fraud 
(18 u.s.c. § 1343) 
1.
Paragraphs 1 through 16 and 23, 24 and 28 through 30 of the General Allegations
Section of this Indictment are re-alleged and incorporated by reference as though fully set forth 
herein. 
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2.
On or about the dates specified below, in Miami-Dade and Broward Counties, in
the Southern District of Florida, and elsewhere, the defendant, 
MALAINA CHAPMAN, 
did knowingly, and with the intent to defraud, 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, knowing that the pretenses, representations, and 
promises were false and fraudulent when made, and, for the purpose of executing the scheme and 
--
-- -·-·· ·----- - ----
. - .. 
 -
artifice, did knowingly transmit and cause to be transmitted, by means of wire communication in 
interstate commerce, certain writings, signs, signals, pictures, and sounds, in violation of Title 18, 
United States Code, Section 1343. 
PURPOSE OF THE SCHEME AND ARTIFICE 
3.
It was the purpose of the scheme and artifice for the defendant and her accomplices
to unlawfully enrich themselves by, among other things: ( a) submitting and causing the submission 
of false and fraudulent applications for loans made available through the SBA to provide relief for 
the economic effects caused by the COVID-19 pandemic, including PPP loans; (b) diverting fraud 
proceeds for her personal use, the use and benefit of others, and to further the scheme and artifice. 
THE SCHEME AND ARTIFICE 
4.
The allegations contained in paragraphs 4 through 7 of the Manner and Means
Section of Count I of this Indictment are re-alleged and incorporated by reference as though fully 
set forth herein as a description of the scheme and artifice. 
USE OF WIRES 
5.
On or about the dates enumerated below, the defendant, MALAINA CHAPMAN,
for the purpose of executing and in furtherance of the aforesaid scheme and artifice to defraud, and 
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to· ·obtain money and property by means of materially false and fraudulent pretenses, 
representations, and promises, knowing that the pretenses, representations, and promises were 
false and fraudulent when made, did knowingly transmit and cause to be transmitted in interstate 
and foreign commerce, by means of wire communication, certain writings, signs, signals, pictures, 
and sounds, as described below: 
COUNT • · APPROXIMATE
DESCRIPTION OF WIRE 
. . . 
2 
..
3 
4 
5 
.. 
DATE 
· April 12, 2021
•. 
, 
April 12 , 2021 
April 13, 2021 .. 
. . 
May 15; 2021. . 
; 
Electronic transmission from the Southern District of 
Florida to outside of the State of Florida of pictures of 
Widny Thibaud to Financial Technology Company 1 
Electronic transmission from the Southern District of 
Florida to outside the State of Florida of pictures of Ricky 
Norwood to Financial Technolog:v Company 1 
Electronic transmission from the Southern District of 
Florida to outside of the State of Florida of pictures of 
Individual 2 to Financial Technology Company 1 . 
Electronic Transmission from the Southern District of 
. Florida to outside the State of Florida of information 
notifying the SBA of the disbursement of a loan to 
Individual 1 by Lender 4. 
In violation of Title 18, United States Code, Sections 1343 and 2. 
COUNT6 
Conspiracy to Commit Wire Fraud 
(18 u.s.c. § 1349) 
1. • 
· Paragraphs 1 through 18 and 25 through 27 of the General Allegations Section of
this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 
2.. 
. From in ·or around April 2020, and continuing through on or about December 30, 
. Q021, in Miami"-Dade and Broward Counties, in the Southern District of Florida, and elsewhere, 
the defendant, 
MALAINA CHAPMAN, 
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did willfully, that is, with the intent to further the object of the conspiracy, and knowingly combine, 
conspire, confederate, and agree with and Individuals 3 and 4, and others known and unknown to 
the Grand Jmy, to knowingly, and with the intent to defraud, 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, knowing that the pretenses, representations, 
and promises were false and fraudulent when made, and, for the purpose of executing the scheme 
and artifice, did knowingly transmit and cause to be transmitted, by means of wire communications 
- -
in interstate and foreign commerce, certain writings, signs, signals, pictures, and sounds, in 
violation of Title 18, United States Code, Section 1343. 
PURPOSE OF THE CONSPIRACY 
3.
It was the purpose of the conspiracy for the defendant and her co-conspirators to
unjustly enrich themselves by, among other things: (a) submitting and causing the submission of 
false and fraudulent applications for loans made available through the SBA to provide relief for 
the economic effects caused by the COVID-19 pandemic, including PPP and EIDL loans; and (b) 
diverting fraud proceeds for their personal use, the use and benefit of others, and to further the 
conspiracy. 
MANNER AND MEANS OF THE CONSPIRACY 
The manner and means by which the defendant and her co-conspirators sought to 
accomplish the object and purpose of the conspiracy included, among others, the following: 
4.
MALAINA CHAPMAN, and Individuals 3 and 4 submitted and caused the
submission of :fraudulent PPP and EIDL loan applications, on behalf of themselves and corporate 
entities that they controlled. 
5.
In furtherance of the scheme, MALAINA CHAPMAN and Individuals 3 and 4
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submitted and caused the submission of false and fraudulent information and documentation in 
support of the PPP loan applications, including falsified IRS forms among other things, that falsely 
and fraudulently represented the annual gross receipts and tentative profits of the sole 
proprietorships and corporate entities they controlled. 
6 
In furtherance of the scheme, on March 31, 2021, MALAINA CHAPMAN 
submitted and caused the submission of a falsified PPP loan application on behalf of Individual 5 
which answered "No" to the question "Is the applicant or the owner of the applicant presently 
- - ---  -----· ··· 
. 
----
incarcerated, or for any felony, subject to an Indictment, Criminal Information or other means by 
which formal criminal charges are brought in any jurisdiction?" when in truth and in fact, as 
CHAPMAN then and there well knew, Individual 5 was incarcerated by the Miami-Dade 
Department of Corrections and charged with a felony by Information in the State of Florida. 
7.
MALAINA CHAPMAN, and Individuals 3 and 4 and their co-conspirators used
the proceeds from the scheme to enrich themselves and others and to further the scheme. 
All in violation of Title 18, United States Code, Section 1349. 
COUNTS 7-12 
Wire Fraud 
(18 u.s.c. § 1343) 
1.
Paragraphs 1 through 18 and 28 through 30 of the General Allegations Section of
this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 
2.
On or about the dates specified below, in Miami-Dade and Broward Counties, in
the Southern District of Florida, and elsewhere, the defendant, 
MALAINA CHAPMAN, 
did knowingly, and with the intent to defraud, devise, and intend to devise, a scheme and artifice 
to defraud, and to obtain money and property by means of materially false and fraudulent 
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pretenses, representations, and promises, knowing that the pretenses, representations, and 
promises were false and fraudulent when made, and, for the pmpose of executing the scheme and 
artifice, did knowingly transmit and cause to be transmitted, by means of wire communication in 
interstate commerce, certain writings, signs, signals, pictures, and sounds, in violation of Title 18, 
United States Code, Section 1343. 
PURPOSE OF THE SCHEME AND ARTIFICE 
3.
It was the pmpose of the scheme and artifice for the defendant and her accomplices
to unlawfully enrich themselves by, among other things: (a) submitting and causing the submission 
of false and fraudulent applications for loans made available through the SBA to provide relief for 
the economic effects caused by the COVID-19 pandemic, including PPP and EIDL loans; (b) 
diverting fraud proceeds for her personal use, the use and benefit of others, and to further the 
scheme and artifice. 
THE SCHEME AND ARTIFICE 
4.
The allegations contained in paragraphs 4 through 7 of the Manner and Means
Section of Count 6 of this Indictment are re-alleged and incorporated by reference as though fully 
set forth herein as a description of the scheme and artifice. 
USE OF WIRES 
5.
On or about the dates enumerated below, the defendant, MALAINA CHAPMAN,
for the pmpose of executing and in furtherance of the aforesaid scheme and artifice to defraud, and 
to obtain money and property by means of materially false and fraudulent pretenses, 
representations, and promises, knowing that the pretenses, representations, and promises were 
false and fraudulent when made, did knowingly transmit and cause to be transmitted in interstate 
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and foreign commerce, by means of wire communication, certain writings, signs, signals, pictures, 
and sounds, as described below: 
COUNT 
.. 
·-
7 
APPROXIMATE 
DATE 
February 10, 2021 
DESCRIPTION OF WIRE 
Electronic transmission from the Southern District 
of Florida to outside of the State of Florida of a 
Schedule 
C 
that falsely 
and 
fraudulently 
misrepresented to Lender 3 that UPSCALE 
CREDIT LOUNGE had gross revenues of 
$103,674 
-·-
8 
February 19, !   Electronic transmission from the Southern District 
· ··--
of Florida to outside of the State of Florida.of a PPP 
. --
loan application in which she falsely mispresented 
to Lender 3 that DA TRAP had four employees and 
an average monthly payroll of $14,191. 
9 
March 9, 2021 
Elecfroriic transmission from the Southern District 
of Florida to outside of the State of Florida of a PPP 
loan application that falsely and fraudulently 
misrepresented to Lender 3 that Individual 5 was 
not incarcerated on March 9, 2021. 
10 
April 10, 2021 
Electronic transmission from the Southern District 
of Florida to outside of the State of Florida a 
Schedule 
C 
that 
falsely 
and 
fraudulently 
misrepresented to Lender 1 that MALAINA 
CHAPMAN had a sole proprietorship property 
management business with gross revenues of 
$123,950. 
11 
May 4, 2021 
Electronic transmission from the Southern District 
of Florida to outside the State of Florida of 
information notifying the SBA of the disbursement 
of a loan to Individual 3 by Lender 4 
12 
June 3, 2021 
Electronic Transmission from the Southern District 
of Florida to outside the State of Florida of 
information notifying the SBA of the disbursement 
of a loan to Individual 4 by Lender 4 
In violation of Title 18, United States Code, Sections 1343 and 2. 
COUNT 13 
Bank Fraud 
(18 u.s.c. § 1344) 
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1.
Paragraphs 16, 19 and 20 of the General Allegations section of this Indictment are
re-alleged and incorporated fully herein by reference. 
2.
From on or about May 11, 2023, through June 11, 2023, in Miami-Dade and
Broward Counties, in the Southern District of Florida, and elsewhere, the defendant, 
MALAINA CHAPMAN, 
did knowingly, and with intent to defraud, execute, and attempt to execute, and cause the 
execution of, a scheme and artifice to defraud one or more financial institutions, including Credit 
·-
--
. --
·- - -- ---·-· 
Union 1, which scheme and artifice employed a material falsehood, and did knowingly, and with 
intent to defraud, execute, and attempt to execute, and cause the execution of, a scheme and artifice 
to obtain moneys and funds owned by, and under the custody and control of one or more financial 
institutions by means of materially false and fraudulently pretenses, representations, and promises, 
relating to a material fact, in violation of Title 18, United States Code, Section 1344(1) and (2). 
PURPOSE OF THE SCHEME AND ARTIFICE 
3.
It was the purpose of the scheme and artifice for the defendant to attempt to
unlawfully enrich herself by submitting false and fraudulent documents in support of a HELOC 
application submitted to Credit Union 1. 
SCHEME AND ARTIFICE 
4.
On May 11, 2023, MALAINA CHAPMAN applied for a HELOC in the amount
of $115,000 for the real property she owned at 7487 NW 167th Hialeah Florida 33015. 
5.
On June 7, 2023, MALAINA CHAPMAN submitted a false and fraudulent
paystub that purported to document wages she purportedly received from Museum I when she was 
never employed by Museum 1. 
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EXECUTION OF THE SCHEME AND ARTIFICE 
6.
On or about June 7, 2023, the defendant, MALAINA CHAPMAN, did execute,
and attempt to execute, and cause the execution of, a scheme and artifice to obtain moneys and 
funds owned by, and under the custody and control of one or more financial institutions by means 
of materially false and fraudulently pretenses, representations, and promises, relating to a material 
fact, to wit, the submission of a false and fraudulent pay stub that purportedly documented the 
income of CHAPMAN. 
In violation of Title 18, United States Code, Sections 1344 and 2. 
COUNT 14 
Wire Fraud 
(18 u.s.c. § 1343) 
I.
Paragraphs 16 and 21 of the General Allegations Section of this Indictment is re-
alleged and incorporated by reference as though fully set forth herein. 
2.
From on or about April 13, 2022, through June 22, 2022, in Miami Dade and
Broward Counties, in the Southern District of Florida, and elsewhere, the defendant, 
MALAINA CHAPMAN, 
did knowingly, and with the intent to defraud, 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, knowing that the pretenses, representations, and 
promises were false and fraudulent when made, and, for the purpose of executing the scheme and 
artifice, did knowingly transmit and cause to be transmitted, by means of wire communication in 
interstate commerce, certain writings, signs, signals, pictures, and sounds, in violation of Title 18, 
United States Code, Section 1343. 
PURPOSE OF THE SCHEME AND ARTIFICE 
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3.
It was the purpose of the scheme and artifice for the defendant and her accomplices
to unlawfully enrich themselves by, among other things: (a) submitting and causing the submission 
of a false and fraudulent application for assistance under the City of Miami Emergency Rental 
Assistance Program; and (b) causing the City of Miami to make payments to the landlord of an 
apartment leased by MALAINA CHAPMAN. 
4. 
THE SCHEME AND ARTIFICE 
On or a`a1:1:t.bEril 13, 2022,  !:,_AINA !!fAPMAN subctted and caused the 
submission of a false and fraudulent application for assistance under the City of Miami Emergency 
Rental Assistance Program. 
5.
In her application, MALAINA CHAPMAN falsely stated that she had no assets
valued at more than $5000 when, in truth and in fact, CHAPMAN was the owner of three single 
family residences that had a tax assessed value of $727,000 in 2022. 
6.
In her application, MALANIA CHAPMAN falsely certified that she received no
rental income from real or personal property when, in truth and in fact, CHAPMAN received 
rental income from several properties she rented out on internet-based rental websites. 
7.
As a result of the false and fraudulent statements in her application, the City of
Miami made payments on behalf of MALAINA CHAPMAN to her landlord. 
USE OF WIRES 
8.
On or about June 22, 2022, the defendant, MALAINA CHAPMAN for the purpose
of executing and in furtherance of the aforesaid scheme and artifice to defraud, and to obtain 
money and property by means of materially false and fraudulent pretenses, representations, and 
promises, knowing that the pretenses, representations, and promises were false and fraudulent 
when made, did knowingly transmit and cause to be transmitted in interstate and foreign 
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commerce, by means of wire communication, certain writings, signs, signals, pictures, and sounds, 
to wit: a wire transmission from the Southern District of Florida to outside the State of Florida 
associated with the remote deposit of a City of Miami Check in the amount of $14,425.00. 
In violation of Title 18, United States Code, Sections 1343 and 2. 
COUNT 15 
Wire Fraud 
(18 u.s.c. § 1343) 
I.
___ J~aragraphsJ6_and-22 of the General Allegations Section.ofthisindictmenLare-re,,,_ ___ -- -
alleged and incorporated by reference as though fully set forth herein. 
2.
From o:ri or about October 13, 2021, through in or around February of 2022, in
Miami Dade and Broward Counties, in the Southern District of Florida, and elsewhere, the 
defendant, 
MALAINA CHAPMAN, 
did knowingly, and with the intent to defraud, 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, knowing that the pretenses, representations, and 
promises were false and fraudulent when made, and, for the purpose of executing the scheme and 
artifice, did knowingly transmit and cause to be transmitted, by means of wire communication in 
interstate commerce, certain writings, signs, signals, pictures, and sounds, in violation of Title 18, 
United States Code, Section 1343. 
PURPOSE OF THE SCHEME AND ARTIFICE 
3.
It was the purpose of the scheme and artifice for the defendant and her accomplices
to unlawfully enrich themselves by, among other things: (a) submitting and causing the submission 
of a false and fraudulent application for assistance under the State of Florida Emergency Rental 
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Assistance Program (b) causing the State of Florida to make payments to a landlord for property 
purportedly leased by the defendant. 
THE SCHEME AND ARTIFICE 
4.
MALAINA CHAPMAN submitted and caused the submission of a false and
fraudulent application for assistance under the State of Florida Emergency Rental Assistance 
Program. 
5.
In support of her application, MALAINA CHAPMAN submitted a lease for the
______ _ 
real property located at 2614 NW 55th Terrace Miami, FL 33142 that was purportedly signed by 
E.J. on October 3, 2020, even though E.J. had died on May 25, 2020. 
6.
On January 20, 2022, in support of her application, MALAINA CHAPMAN
submitted a document titled "FLORIDA THREE (3) DAY NOTICE TO PAY RENT OR QUIT" 
that was purportedly signed by E.J. on December 7, 2021, even though E.J. had died on May 25, 
2020. 
7.
As a result of the misstatements in her application, MALAINA CHAPMAN
received payments into a bank account she controlled that were intended to go to E.J. 
USE OF WIRES 
8.
On or about January 20, 2022, the defendant, MALAINA CHAPMAN for the
purpose of executing and in furtherance of the aforesaid scheme and artifice to defraud, and to 
obtain money and property by means of materially false and fraudulent pretenses, representations, 
and promises, knowing that the pretenses, representations, and promises were false and fraudulent 
when made, did knowingly transmit and cause to be transmitted in interstate and foreign 
commerce, by means of wire communication, certain writings, signs, signals, pictures, and sounds, 
to wit, a wire transmission from inside the Southern District of Florida to outside the State of 
18 
Case 1:24-cr-20321-RAR   Document 14   Entered on FLSD Docket 07/26/2024   Page 18 of 23

Florida associated with the submission of a document titled "FLORIDA TIIREE (3) DAY 
NOTICE TO PAY RENT OR QUIT" to the State of Florida Emergency Rental Assistance 
program. 
In violation of Title 18, United States Code, Sections 1343 and 2 
COUNT16 
Aggravated Identity Theft 
(18 U.S.C. § 1028A(a)(l)) 
District of Florida and elsewhere, the defendant, 
MALAINA CHAPMAN, 
during and in relation to a felony violation of Title 18, United States Code, Section 1343, that is, 
wire fraud, as charged in Count 15 in this Indictment, did knowingly transfer, possess, and use, 
without lawful authority, the means of identification of another person, to wit, the name and 
signature of E.J. 
In violation of Title 18, United States Code, Sections 1028(A)(a)(l) ·and 2. 
FORFEITURE ALLEGATIONS 
1.
The allegations of this Indictment are hereby re-alleged and by this reference fully
incorporated herein for the purpose of alleging forfeiture to the United States of America of certain 
property in which the defendant, MALAINA CHAPMAN, has an interest. 
2.
Upon conviction of a violation of, and/or a conspiracy to violate, Title 18, United
States Code, Section(s) 1343 and/or 1344, as alleged in this Indictment, the defendant shall forfeit 
to the United States any property constituting, or derived from, proceeds obtained, directly or 
indirectly, as a result of such offense, pursuant to Title 18, United States Code, Section 
982(a)(2)(A). 
19 
Case 1:24-cr-20321-RAR   Document 14   Entered on FLSD Docket 07/26/2024   Page 19 of 23

Case 1:24-cr-20321-RAR   Document 14   Entered on FLSD Docket 07/26/2024   Page 20 of 23

Case 1:24-cr-20321-RAR   Document 14   Entered on FLSD Docket 07/26/2024   Page 21 of 23

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
PENAL TY SHEET 
Defendant's Name: 
MALAINA CHAPMAN 
Case No: ------------------------------
Counts #: 1, 6 
Conspiracy to Commit Wire Fraud 
Title 18, Uriited States Code, Section 1349 
* Max. Term of Imprisonment: Twenty (20) years
* Mandatory Min. Term of Imprisonment (if applicable): No
* Max. Supervised Release: Three (3) years
* Max. Fine: $250,000
Counts#: 2, 3, 4, 5, 7, 8, 9, 10, 11, 12, 14, 15 
Wire Fraud 
Title 18, United States Code, Section 1343 
*Max.Term of Imprisonment: Twenty (20) years
* Mandatory Min. Term of Imprisonment (if applicable): No
* Max. Supervised Release: Three (3) years
* Max. Fine: $250,000
Count#: 13 
Bank Fraud 
Title 18, United States Code, Section 1344 
*Max.Term of Imprisonment: Thirty (30) years
. * Mandatory Min. Term of Imprisonment (if applicable): No
* Max. Supervised Release: Five (5) years
* Max. Fine: $250,000
Count#: 16 
Aggravated Identity Theft 
Title 18, United States Code, Section 1028A(a)(l) 
* Max. Term of Imprisonment: Two (2) years
* Mandatory Min. Term of Imprisonment (if applicable): two years consecutive to any
*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable. 
Case 1:24-cr-20321-RAR   Document 14   Entered on FLSD Docket 07/26/2024   Page 22 of 23

other sentence imposed 
*Max.Supervised Release: One (1) year
* Max. Fine: $250,000
*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable. 
Case 1:24-cr-20321-RAR   Document 14   Entered on FLSD Docket 07/26/2024   Page 23 of 23

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