Factual Proffer Statement as to Malaina Chapman — United States v. Chapman (Dkt. 37, S.D. Fla. No. 1:24-cr-20321)

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U.S. District Court for the Southern District of Florida · No. 1:24-cr-20321-RAR · Doc. 37 · 2025-03-14 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 24-20321-CR-RAR 
UNITED STATES OF AMERICA 
vs. 
MALAINA CHAPMAN, 
Defendant. 
I 
-------------
STIPULATED FACTUAL BASIS 
IN SUPPORT OF GUILTY PLEA 
MALAINA CHAPMAN (hereinafter referred to as the "Defendant") hereby 
acknowledges that, had this case proceeded to trial, the United States would establish the following 
facts beyond a reasonable doubt: 
The government would have proved, and the Defendant agrees that she participated in 
multiple schemes to defraud various Covid-19 relief programs including the Paycheck Protection 
Program (PPP), Economic Injury and Disaster Loan (EIDL), the City of Miami Emergency Rental 
Assistance Program and the State of Florida Emergency Rental Assistance program. The 
government would have proved that she defrauded these programs by causing the submission of 
false and fraudulent loan applications to the SBA and SBA-approved PPP Lenders and false 
applications to the City of Miami and the State of Florida. The government would have proved 
that she conspired with numerous individuals known and unknown to the grand jury, and 
knowingly caused the submission of false documents in support of the numerous PPP loan 
applications, some of which were in her own name and some of which were in the name of others. 
The government would have proved that the defendant worked at the Small Business 
Administration (SBA) as a disaster relief specialist in 2020 and 2021 . On February I 0, 2021 , while 
Case 1:24-cr-20321-RAR   Document 37   Entered on FLSD Docket 03/14/2025   Page 1 of 3

still employed by the SBA, the defendant submitted a PPP loan application to Lender 3 in the 
name of Upscale Credit Lounge. According to Sun biz, the defendant was listed as the Manager of 
the corporation. In support of her application, the defendant submitted a tax year 2020 Schedule C 
that reported gross revenues of $103,674 and a tentative profit of $81 ,860. Lender 3 relied upon 
the representations in the defendant' s application and on February 11 , 2021 , approved a loan in 
the amount of $17,052.50. Records were obtained pursuant to an Ex-Parte tax order and the actual 
Schedule C fi led with the IRS in her 2020 tax returns showed she reported gross revenues of 
$37,010 and tentative profit of negative $3464. 
On February 19, 2021 , the defendant submitted, via interstate wire communication, a PPP 
loan application with Lender 3 on behalf of DA TRAP LLC ("DA TRAP"). According to 
SUNBIZ, the defendant was listed as the Manager of the company. In her application, she claimed 
DA TRAP had four (4) employees and an average monthly payroll of$14,19l. In support of her 
application, the defendant submitted four (4) IRS Employers Quarterly Tax Return ("Form 941"), 
which purportedly documented the wages paid by DA TRAP. 
Lender 3 relied upon the 
representations in the application and on February 26, 2021 , approved a loan in the amount of 
$35,477.50. Records obtained pursuant to an Ex-Parte tax application for DA TRAP revealed that 
the 941 's filed with the lender were not filed with the IRS at the time she filed her actual tax 
returns. The government would have proved that the defendant submitted and caused the 
submission of false and fraudulent EIDL and other PPP loan applications in her own name other 
than the two mentioned above. 
The government would also have presented evidence that the defendant prepared PPP loan 
applications and forgiveness applications for co-conspirators in return for the payment of 
kickbacks. The defendant sent a March 11 , 2021 , email in which she stated "thank you for allowing 
2 
Case 1:24-cr-20321-RAR   Document 37   Entered on FLSD Docket 03/14/2025   Page 2 of 3

The Upscale Resource to assist with your PPP application. Congratulations on being approved by 
the SBA. Next steps would be to use the funds correctly so that the loan will be forgiven. We also 
provide loan forgiveness." The email further stated, "if you received a loan in the amount of 
$20,833 your payment today will be $2083." Investigation has revealed that the defendant prepared 
loan and forgiveness applications for numerous individuals and the government would have 
introduced tax records for six (6) individuals that the defendant conspired with and in each instance 
a false Schedule C was submitted to back up the false representations contained in the loan 
applications. One of these six (6) individuals for whom the defendant submitted a loan application 
was Individual 5 who was incarcerated at the time he applied for a PPP loan. The defendant 
prepared a PPP loan application that stated that Individual 5 was not incarcerated at the time of the 
application when in truth Individual 5 was incarcerated in the Dade County Jail and the defendant 
knew this because he was the father of her child. The government also would have introduced text 
messages in which the defendant communicated with the applicants she recruited into the scheme 
in which she discussed taking various actions on their behalf and applying for forgiveness. 
All of these events took place in Miami-Dade County, in the Southern District of Florida. 
Date#J 
Date•w)_zs 
3 
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l1riLAINA CHAPMAN 
Defendant 
~ /  
Attorney for MALAINA CHAPMAN 
2{/;E£ifN ~✓ 
Assistant United States Attorney 
Case 1:24-cr-20321-RAR   Document 37   Entered on FLSD Docket 03/14/2025   Page 3 of 3

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