Indictment as to Te Dora Brown (1) count(s) 1-4, 6-14, Christopher Scott — USA v. Brown, et al. (Dkt. 1, N.D. Ill.)

Record facts

U.S. District Court for the Northern District of Illinois · No. 1:23-cr-00097 · Doc. 1 · 2023-02-15 · Docket on CourtListener

Full text

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Ta? rs 1:23-cr-00097
a 5 — D Judge Elaine E. Bucklo
Magistrate Judge M. David Weisman
FEB 152023
THOMAS G. BRUTON 9
CLERK, U.S. DISTRICT COURT UNITED STATES DISTRICT COURT Feb 15, 2023
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA
UNDER SEAL
No.

Violations: Title 18, United
States Code, Section 13438
TE DORA BROWN, and

CHRISTOPHER SCOTT

COUNT ONE

The SPECIAL OCTOBER 2022 GRAND JURY charges:
1, At times material to this Indictment:
The Small Business Administration
a. The U.S. Small Business Administration (“SBA”) was a United
States government agency that provided economic support to small businesses.
The Paycheck Protection Program
b. 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 Americans who were suffering the
economic effects caused by the COVID-19 pandemic.
c. One source of relief provided by the CARES Act was the
authorization of up to $349 billion in forgivable loans to small businesses and sole

proprietors for job retention and certain other expenses, through a program called
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the Paycheck Protection Program (“PPP”). In or around April 2020, Congress
authorized over $320 billion in additional funding for PPP loans.

d. To obtain a PPP loan, a business, sole proprietor, or self-employed
individual submitted a PPP loan application, which was signed by the applicant or
an authorized representative of the business. The PPP loan application required the
applicants to acknowledge the program rules and make certain affirmative
certifications regarding the eligibility of the business, proprietorship, or individual.
In the application, businesses, sole proprietors, and self-employed individuals were
required to provide, among other things, their number of employees and average
monthly payroll. This figure was used to calculate the applicant’s eligibility and the
amount of money the business could receive under the PPP. Applicants were also
required to make good faith certifications, including that economic uncertainties had
necessitated their loan requests for continued business operations.

e. PPP loan proceeds were required to be used by the sole
proprietorship, self-employed individual, or business for 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 by the SBA if the
sole proprietorship, self-employed individual, or business spent the loan proceeds on
these items within a designated period of time and used at least a certain percentage

of the PPP loan for payroll expenses.
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f. To gain access to funds through the PPP, businesses, sole
proprietorships, and self-employed individuals applied to financial institutions
participating in the PPP and received the loans directly from those financial
institutions as the lender.

g. Businesses, sole proprietors, and self-employed individuals that
obtained PPP loans and used the full loan amount were allowed to obtain additional
funds through the PPP by submitting a Second Draw Borrower Application Form
(“Second Draw Application”), which was signed by the applicant or an authorized
representative of the business. The Second Draw Application required the applicants
to again acknowledge the program rules and make certain affirmative certifications
regarding the eligibility of the business, and again provide their number of employees
and average monthly payroll. These figures were again used to calculate the
applicant’s eligibility and the amount of money the business could receive under the
PPP. Applicants were again required to make good faith certifications, including that
economic uncertainties had necessitated their loan requests for continued business
operations and that the applicants had used the full amount of the initial PPP loan
only for eligible expenses.

h. Participating lenders required applicants for PPP loans to provide
truthful information about the sole proprietorship, self-employed individual, or

business and its owner, including truthful information about the applicant’s payroll,
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income, operating expenses, and how the PPP loan would be used, which information
was material to lenders’ approval, terms, and funding of loans.
The Economic Injury Disaster Loan Program

i. Another source of relief provided by the CARES Act and other
pandemic relief legislation was the expansion of the Economic Injury Disaster Loan
(“EIDL”) Program, which provided loan assistance (including advances of up to
$10,000) for businesses with 500 or fewer employees and other eligible entities. The
EIDL Program was designed to provide economic relief to small businesses that are
experiencing a temporary loss of revenue.

j. To gain access to funds through the EIDL Program, small
businesses applied through the SBA via an online portal and application. As part of
the EIDL application process, the SBA required applicants to submit truthful
information about the applying entity and its owner, and its condition prior to the
COVID-19 pandemic. This information included the entity’s number of employees as
of January 31, 2020; the entity’s gross revenues and cost of goods sold for the 12-
month period prior to January 31, 2020; rental losses incurred “due to the disaster”
(as of January 31, 2020); the entity’s type of business (i.e., a business, an agricultural
business, a sole proprietorship, or a cooperative, among others); the date on which
the business opened; and the date on which the current owner assumed ownership of
the entity. Applicants were required to electronically certify that the information

provided in the application was true and correct and were warned that any false
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statement or misrepresentation to the SBA may result in sanctions, including
criminal penalties.

k, EIDL funds were issued to the small business applicants directly
from the United States Treasury.

1. EIDL Advance was a grant program offered together with the
EIDL program. EIDL Advance was designed to provide emergency economic relief to
businesses that were experiencing a temporary loss of revenue as a result of the
COVID-19 pandemic. The applicant could request consideration for an EIDL advance
in an application for an EIDL loan. The amount of the advance issued to the small
business applicant was determined by the number of employees indicated on the
EIDL application, $1,000 per employee, up to $10,000. If an EIDL advance was
issued, the advance did not need to be repaid.

m. If the application was approved by the SBA, the amount of the
EIDL loan was determined in part based on the statements in the EIDL application
about the entity's revenues and cost of goods sold for the 12 months prior to
January 31, 2020.

n. EIDL Program funds could be used to pay for the ordinary
operating expenses and debts of the entity, including payroll, sick leave, production

costs, utilities, rent, and mortgage payments.
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Employer Identification Numbers
Oo. An Employer Identification Number (EIN) is a unique number
assigned to business entities by the Internal Revenue Service, upon request from the
owner or operator of the business, and is used to identify a business entity for tax
administration purposes. Entities that have one or more employees are required to
obtain an EIN.
Lenders
p. Bank A was a financial institution that funded PPP loans to
approved borrowers. Bank A maintained computer servers that were located outside
of Illinois.
The Scheme to Defraud
2. Beginning on or about March 30, 2020, and continuing until at least
March 10, 2021 at Chicago, in the Northern District of Illinois, Eastern Division, and
elsewhere,

TE DORA BROWN, and
CHRISTOPHER SCOTT

defendants herein, knowingly devised, intended to devise, and participated in a
scheme to defraud, and to obtain money and property, in connection with applications
for PPP and EIDL funds, by means of materially false and fraudulent pretenses,
representations, and promises, as further described below.

3. It was part of the scheme that BROWN and SCOTT (together, the

“defendants”), for the purpose of fraudulently obtaining approximately $742,500 in

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PPP and EIDL funds, submitted approximately 15 applications for loans and
advances under the PPP and EIDL Programs, on behalf of businesses and entities
purportedly owned and operated by the defendants, including Little Shepherd’s
Academy, Inc.; Little Shepherd’s Beginners, Inc.; EZ Link Golf LLC; Naper
Montessori Academy, Inc.; and OLG Financing, Inc. (together, the “Fictitious
Entities”); which applications contained materially false statements and
misrepresentations concerning, among other things, the purported entities’ number
of employees, gross revenues, payroll, operating expenses, type of business, and
existence as companies with ongoing operations.
The PPP Loans

4, It was further part of the scheme that BROWN and SCOTT prepared,
and submitted to Bank A, PPP loan applications on behalf of the Fictitious Entities,
in which applications BROWN and SCOTT falsely and fraudulently represented that
the Fictitious Entities were S Corporations or Limited Liability Companies (“LLCs”)
that employed specified numbers of employees and had specified average monthly
payrolls and that all PPP loan proceeds would be used only for business related
purposes. BROWN and SCOTT knew at the time that the Fictitious Entities had no
employees or payroll, and that they intended to use the loan funds for their personal
use and benefit.

5. It was further part of the scheme that, to substantiate the claimed

number of employees and payroll of the Fictitious Entities, BROWN and SCOTT
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prepared and submitted to Bank A copies of false IRS Form 941 filings that
fraudulently represented that the Fictitious Entities had paid specified numbers of
employees various amounts in wages, tips, and other compensation in tax years 2019
and 2020, and that the IRS had assigned each Fictitious Entity an EIN. BROWN
and SCOTT knew at the time that the Fictitious Entities had no employees or payroll,
and that the IRS had not assigned an EIN to any of the Fictitious Entities.

6. It was further part of the scheme that, between on or about January 22,
2021, and on or about March 9, 2021, BROWN and SCOTT prepared, and submitted
to Bank A, several Second Draw PPP Applications on behalf of the Fictitious Entities,
in which applications BROWN and SCOTT again falsely and fraudulently
represented that the Fictitious Entities were S Corporations or LLCs that employed
specified numbers of employees and had specified average monthly payrolls, that all
PPP loan proceeds would be used only for business related purposes, and that they
had used the full amount of the initial PPP loans awarded to each Fictitious Entity
only for business related purposes. BROWN and SCOTT knew at the time that the
Fictitious Entities had no employees or payroll, that they intended to use the Second
Draw loan funds for their personal use and benefit, and that they had used the
proceeds of the initial PPP loans for their personal use and benefit.

7. It was further part of the scheme that BROWN and SCOTT opened
business bank accounts in the names of several of the Fictitious Entities, including

including Little Shepherd’s Academy, Little Shepherd’s Beginners, EZ Link Golf
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LLC, Naper Montessori Academy, and OLG Financing; and directed Bank A to
deposit the proceeds of fraudulently obtained PPP loans into those bank accounts,
which the defendants controlled. BROWN and SCOTT opened these accounts in the
names of those entities to induce the SBA, Bank A, and others to falsely believe that
the accounts belonged to a legitimate and operational business.

8. It was further part of the scheme that, through the submission of the
false and fraudulent PPP loan applications, BROWN and SCOTT caused Bank A to
disburse approximately $465,500 in PPP loan proceeds into bank accounts that they
controlled.

9. It was further part of the scheme that BROWN and SCOTT used the
PPP funds that Bank A disbursed based on the fraudulent PPP applications to make
cash withdrawals, to write checks to themselves and to each other and to entities they
controlled, to obtain cashier’s checks payable to each other, and to purchase goods
and services, all for their personal use and benefit.

The EIDL Loans

10. It was further part of the scheme that BROWN and SCOTT prepared,
and submitted to the SBA, numerous EIDL loan applications on behalf of several of
the Fictitious Entities, including Little Shepherd’s Academy, Little Shepherd’s
Beginners, Naper Montessori Academy, and OLG Financing, in which applications
they made false statements regarding their ownership of those entities, the dates on

which those entities opened for business, the entities’ gross revenues and costs of
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goods sold for the 12 months prior to January 31, 2020, the number of employees
employed by those entities as of January 31, 2020, and the entities’ rental losses “due
to the disaster” (as of January 31, 2020). BROWN and SCOTT knew at the time that
the Fictitious Entities were not operating companies, had no employees, and did not
have the revenues or cost of goods stated in the applications.

11. It was further part of the scheme that BROWN and SCOTT opened
business bank accounts in the names of several of the Fictitious Entities, including
including Little Shepherd’s Academy, Little Shepherd’s Beginners, Naper Montessori
Academy, and OLG Financing; and directed the SBA to deposit the proceeds of
fraudulently obtained EIDL loans into those bank accounts, which the defendants
controlled. BROWN and SCOTT opened these accounts in the names of those entities
to induce the SBA and others to falsely believe that the accounts belonged to a
legitimate and operational business.

12. It was further part of the scheme that, through the submission of the
false and fraudulent EIDL loan applications, BROWN and SCOTT caused the SBA
to disburse approximately $277,000 in EIDL loan proceeds and advances into bank
accounts that they controlled.

13. It was further part of the scheme that BROWN and SCOTT used the
funds that had been disbursed by the SBA based on the fraudulent EIDL applications
to make cash withdrawals, to write checks to themselves and to each other and to

entities they controlled, to obtain cashier’s checks payable to each other, and to

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purchase goods and services, all for their personal use and benefit, and not to pay for
the ordinary operating expenses and debts of the applying entities.

14. It was further part of the scheme that BROWN and SCOTT
misrepresented, concealed, and hid, and caused to be misrepresented, concealed, and
hidden, the existence and purpose of the scheme and the acts done in furtherance of
the scheme.

15. On or about March 30, 2020, at Chicago, in the Northern District of
Illinois, Eastern Division, and elsewhere,

TE DORA BROWN,
defendant herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communications in interstate commerce certain
writings, signs, signals, and sounds, namely, an internet transmission of an EIDL
loan application on behalf of “Little Shepherd’s Academy, Inc.,” through an SBA
server located outside of Illinois;

In violation of Title 18, United States Code, Section 13438.

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COUNT TWO
The SPECIAL October 2022 GRAND JURY further charges:

1. Paragraphs 1 through 14 of Count One are incorporated here.

2. On or about May 4, 2020, at Chicago, in the Northern District of Illinois,
Eastern Division, and elsewhere,

TE DORA BROWN,

defendant herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communications in interstate commerce certain
writings, signs, signals, and sounds, namely, an internet transmission of a PPP loan
application on behalf of “Little Shepherd’s Academy, Inc.,” to Bank A’s computer
servers located outside of Illinois;

In violation of Title 18, United States Code, Section 1348.

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COUNT THREE
The SPECIAL OCTOBER 2022 GRAND JURY further charges:

1. Paragraphs 1 through 14 of Count One are realleged and incorporated
here.

2. On or about May 138, 2020, at Chicago, in the Northern District of
Illinois, Eastern Division, and elsewhere,

TE DORA BROWN,

defendant herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communications in interstate commerce certain
writings, signs, signals, and sounds, namely, an internet transmission of a PPP loan
application on behalf of “Little Shepherd’s Beginners, Inc.,” to Bank A’s computer
servers located outside of Illinois;

In violation of Title 18, United States Code, Section 13438.

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COUNT FOUR
The SPECIAL OCTOBER 2022 GRAND JURY further charges:

1. Paragraphs 1 through 14 of Count One are realleged and incorporated
here.

2. On or about June 8, 2020, at Chicago, in the Northern District of Illinois,
Eastern Division, and elsewhere,

TE DORA BROWN,

defendant herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communications in interstate commerce certain
writings, signs, signals, and sounds, namely, an internet transmission of an EIDL
loan application on behalf of “Little Shepherd’s Beginners, Inc.” through an SBA
server located outside of Illinois;

In violation of Title 18, United States Code, Section 1343.

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COUNT FIVE

The SPECIAL OCTOBER 2022 GRAND JURY further charges:

1. Paragraphs 1 through 14 of Count One are realleged and incorporated
here.

2. On or about June 10, 2020, at Chicago, in the Northern District of
Illinois, Eastern Division, and elsewhere,

CHRISTOPHER SCOTT,

defendant herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communications in interstate commerce certain
writings, signs, signals, and sounds, namely, an internet transmission of a PPP loan
application on behalf of “EZ Link Golf LLC,” to Bank A’s computer servers located
outside of Illinois;

In violation of Title 18, United States Code, Section 1343.

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COUNT SIX
The SPECIAL OCTOBER 2022 GRAND JURY further charges:
1. Paragraphs 1 through 14 of Count One are realleged and incorporated
here.
2. On or about June 27, 2020, at Chicago, in the Northern District of
Illinois, Eastern Division, and elsewhere,

TE DORA BROWN and
CHRISTOPHER SCOTT,

defendants herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communications in interstate commerce certain
writings, signs, signals, and sounds, namely, an internet transmission of an EIDL
loan application on behalf of “OLG Financing, Inc.,” through an SBA server located
outside of Illinois;

In violation of Title 18, United States Code, Section 13438.

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COUNT SEVEN
The SPECIAL OCTOBER 2022 GRAND JURY further charges:
1. Paragraphs 1 through 14 of Count One are realleged and incorporated
here.
2. On or about June 28, 2020, at Chicago, in the Northern District of
Illinois, Eastern Division, and elsewhere,

TE DORA BROWN and
CHRISTOPHER SCOTT,

defendants herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communications in interstate commerce certain
writings, signs, signals, and sounds, namely, an internet transmission of a PPP loan
application on behalf of “OLG Financing, Inc.,” to Bank A’s computer servers located
outside of Illinois;

In violation of Title 18, United States Code, Section 1343.

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COUNT EIGHT
The SPECIAL OCTOBER 2022 GRAND JURY further charges:
1. Paragraphs 1 through 14 of Count One are realleged and incorporated
here.
2. On or about July 8, 2020, at Chicago, in the Northern District of Illinois,
Eastern Division, and elsewhere,

TE DORA BROWN and
CHRISTOPHER SCOTT,

defendants herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communications in interstate commerce certain
writings, signs, signals, and sounds, namely, an internet transmission of a PPP loan
application on behalf of “Naper Montessori Academy, Inc.,” to Bank A’s computer
servers located outside of Illinois;

In violation of Title 18, United States Code, Section 13438.

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COUNT NINE
The SPECIAL OCTOBER 2022 GRAND JURY further charges:
1, Paragraphs 1 through 14 of Count One are realleged and incorporated
here.
2. On or about July 14, 2020, at Chicago, in the Northern District of
Illinois, Eastern Division, and elsewhere,

TE DORA BROWN and
CHRISTOPHER SCOTT,

defendants herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communications in interstate commerce certain
writings, signs, signals, and sounds, namely, an internet transmission of an EIDL
loan application on behalf of “Naper Montessori Academy, Inc.,” through an SBA
server located outside of Illinois;

In violation of Title 18, United States Code, Section 1343.

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COUNT TEN
The SPECIAL OCTOBER 2022 GRAND JURY further charges:
1. Paragraphs 1 through 14 of Count One are realleged and incorporated
here.
2. On or about July 30, 2020, at Chicago, in the Northern District of
Illinois, Eastern Division, and elsewhere,

TE DORA BROWN and
CHRISTOPHER SCOTT,

defendants herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communications in interstate commerce certain
writings, signs, signals, and sounds, namely, an internet transmission of a PPP loan
application on behalf of “OLG Financing, Inc.,” to Bank A’s computer servers located
outside of Illinois;

In violation of Title 18, United States Code, Section 1343.

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COUNT ELEVEN
The SPECIAL OCTOBER 2022 GRAND JURY further charges:
1. Paragraphs 1 through 14 of Count One are realleged and incorporated
here.
2. On or about January 22, 2021, at Chicago, in the Northern District of
Illinois, Eastern Division, and elsewhere,
TE DORA BROWN,
defendant herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communications in interstate commerce certain
writings, signs, signals, and sounds, namely, an internet transmission of a PPP loan
application on behalf of “Little Shepherd’s Academy, Inc.,” to Bank A’s computer
servers located outside of Illinois;

In violation of Title 18, United States Code, Section 1343.

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COUNT TWELVE
The SPECIAL OCTOBER 2022 GRAND JURY further charges:
1. Paragraphs 1 through 14 of Count One are realleged and incorporated
here.
2. On or about January 22, 2021, at Chicago, in the Northern District of
Illinois, Eastern Division, and elsewhere,
TE DORA BROWN,
defendant herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communications in interstate commerce certain
writings, signs, signals, and sounds, namely, an internet transmission of a PPP loan
application on behalf of “Little Shepherd’s Beginners, Inc.,” to Bank A’s computer
servers located outside of Illinois;

In violation of Title 18, United States Code, Section 1348.

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COUNT THIRTEEN
The SPECIAL OCTOBER 2022 GRAND JURY further charges:
1. Paragraphs 1 through 14 of Count One are realleged and incorporated
here.
2. On or about January 22, 2021, at Chicago, in the Northern District of
Illinois, Eastern Division, and elsewhere,

TE DORA BROWN and
CHRISTOPHER SCOTT,

defendants herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communications in interstate commerce certain
writings, signs, signals, and sounds, namely, an internet transmission of a PPP loan
application on behalf of “OLG Financing, Inc.,” to Bank A’s computer servers located
outside of Illinois;

In violation of Title 18, United States Code, Section 1343.

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COUNT FOURTEEN
The SPECIAL OCTOBER 2022 GRAND JURY further charges:
1. Paragraphs 1 through 14 of Count One are realleged and incorporated
here.
2. On or about February 19, 2021, at Chicago, in the Northern District of
Illinois, Eastern Division, and elsewhere,

TE DORA BROWN and
CHRISTOPHER SCOTT,

defendants herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communications in interstate commerce certain
writings, signs, signals, and sounds, namely, an internet transmission of a PPP loan
application on behalf of “Naper Montessori Academy, Inc.,” to Bank A’s computer
servers located outside of Illinois;

In violation of Title 18, United States Code, Section 1343.

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COUNT FIFTEEN

The SPECIAL OCTOBER 2022 GRAND JURY further charges:

1. Paragraphs 1 through 14 of Count One are realleged and incorporated
here.

2. On or about March 9, 2021, at Chicago, in the Northern District of
Illinois, Eastern Division, and elsewhere,

CHRISTOPHER SCOTT,

defendant herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communications in interstate commerce certain
writings, signs, signals, and sounds, namely, an internet transmission of a PPP loan
application on behalf of “EZ Link Golf LLC,” to Bank A’s computer servers located
outside of Illinois;

In violation of Title 18, United States Code, Section 1343.

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FORFEITURE ALLEGATION

The SPECIAL OCTOBER 2022 GRAND JURY further alleges:

1. Upon conviction of an offense in violation of Title 18, United States Code,
Section 1348, as set forth in this Indictment, defendants shall forfeit to the United
States of America any property which constitutes and is derived from proceeds
traceable to the offense, as provided in Title 18, United States Code, Section
981(a)(1)(C), and Title 28, United States Code, Section 2461(c).

2. The property to be forfeited includes, but is not limited to a personal
money judgment in an amount equal to the proceeds derived from the offenses in
violation of Title 18, United States Code, Section 1343, estimated to be approximately
$742,600.

3. If any of the property described above, as a result of any act or omission
by defendant: cannot be located upon the exercise of due diligence; has been
transferred or sold to, or deposited with, a third party; has been placed beyond the
jurisdiction of the Court; has been substantially diminished in value; or has been

commingled with other property which cannot be divided without difficulty, the

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United States of America shall be entitled to forfeiture of substitute property, as

provided in Title 21, United States Code Section 853(p).

A TRUE BILL:

FOREPERSON

Signed by Erika L. Csicsila, on behalf of the
UNITED STATES ATTORNEY

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