Court filing

Rule 5(c)(3) Documents Received as to Gardy Alexandre — USA v. Pierre et al. (Dkt. 11, D. Mass.)

Filed January 27, 2023 in USA v. Pierre et al.; one of 10 filings from this case.

Record facts

Court	U.S. District Court for the District of Massachusetts
Filed	2023-01-27

U.S. District Court for the District of Massachusetts · No. 9:23-mj-08043-WM · Doc. 8 · 2023-01-27 · Docket on CourtListener

Full text

BNDWM,CLOSED
U.S. District Court
Southern District of Florida (West Palm Beach)
CRIMINAL DOCKET FOR CASE #: 9:23−mj−08043−WM−1
Case title: USA v. Alexandre
Other court case number: 23−MJ−8013−JGD District of
Massachusetts
Date Filed: 01/25/2023
Date Terminated: 01/26/2023
Assigned to: Magistrate Judge
William Matthewman
Defendant (1)
Gardy Alexandre
English
TERMINATED: 01/26/2023
represented by Edward Donald Reagan
Edward D Reagan PA
658 West Indiantown Road
Suite 209
Jupiter, FL 33458
561−832−7443
Fax: 683−9970
Email: edward.d.reagan@gmail.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: Temporary
Pending Counts
Disposition
None
Highest Offense Level
(Opening)
None
Terminated Counts
Disposition
None
Highest Offense Level
(Terminated)
None
Complaints
Disposition
18:1349.F (18:1349 and
18:1956(h))
1
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Plaintiff
USA
represented by Daniel E. Funk
U.S. Attorney's Office
101 S. U.S. Highway 1
Fort Pierce, FL 34950
305−905−7509
Fax: 772−466−1020
Email: daniel.funk@usdoj.gov
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Designation: Retained
Date Filed
#
Page Docket Text
01/25/2023
1
Magistrate Judge Removal of Complaint from District of Massachusetts Case
number in the other District 23−mj−05013−JGD as to Gardy Alexandre (1).
(swr) (Entered: 01/25/2023)
01/25/2023
2
NOTICE OF HEARING as to Gardy Alexandre Initial Appearance − Rule
5(c)(3)/40 set for 1/26/2023 at 10:00 AM in West Palm Beach Division before
WPB Duty Magistrate Judge. (swr) (Entered: 01/25/2023)
01/26/2023
3
NOTICE OF TEMPORARY ATTORNEY APPEARANCE: Edward Donald
Reagan appearing for Gardy Alexandre (swr) (Entered: 01/26/2023)
01/26/2023
4
PAPERLESS Minute Order for proceedings held before Magistrate Judge
William Matthewman: Initial Appearance in Rule 5(c)(3)/Rule 40 Proceedings as
to Gardy Alexandre held on 1/26/2023. Defendant present and sworn. Temporary
Notice of Appearance filed. The Court advised the defendant of the charges,
possible maximum penalties, and his rights. The defendant waived removal, form
executed and the Court found the waiver knowing and voluntary. Government
requested $150,000 PSB. Defense agreed. Bond recommendation/set: Gardy
Alexandre (1) $150,000 PSB. Court Ordered Defendant removed. Date of Arrest
or Surrender: 1/26/2023. Total time in court: 25 minutes. Attorney
Appearance(s): Daniel E. Funk, Edward Donald Reagan, (Digital 11:04:13)
Signed by Magistrate Judge William Matthewman on 1/26/2023. (swr) (Entered:
01/26/2023)
01/26/2023
5
$150,000 PSB Bond Entered as to Gardy Alexandre Approved by Magistrate
Judge William Matthewman. Please see bond image for conditions of release.
(swr) (Additional attachment(s) added on 1/26/2023: # 1 Restricted Bond with
7th Page) (swr). (Entered: 01/26/2023)
Main Document
Attachment # 1 Restricted Bond with 7th Page (Not Attached)
01/26/2023
6
WAIVER of Rule 5(c)(3)/Rule 40 Hearing by Gardy Alexandre (swr) (Main
Document 6 replaced on 1/26/2023) (swr). (Entered: 01/26/2023)
01/26/2023
7
ORDER OF REMOVAL ISSUED to District of Massachusetts as to Gardy
Alexandre. Closing Case for Defendant. Signed by Magistrate Judge William
Matthewman on 1/26/2023. See attached document for full details. (swr)
2
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(Entered: 01/26/2023)
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Jan 24, 2023
SDFL Case No. 23-MJ-8043-WM
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AFFIDAVIT
I, Than Trung Nguyen, having been first duly sworn, do hereby depose and state:
INTRODUCTION AND AGENT BACKGROUND
1.
I have been a Special Agent with Internal Revenue Service – Criminal Investigation
(“IRS-CI”) since October 2018. My responsibilities include the investigation of tax fraud, money
laundering, and the illegal structuring of financial transactions. I hold a bachelor’s degree in
economics from Boston College and master’s degrees in accounting and business administration
from the University of Massachusetts, Boston. I have received extensive training in financial
investigative techniques, money laundering, Bank Secrecy Act violations, and the law of search
and seizure under the Fourth Amendment.
2.
I am investigating Wallace Ford (“Ford”), Erin Brown (“Brown”), Adiana Pierre
(“Pierre”) and Gardy Alexandre (“Alexandre”) (together, the “Targets”) for their involvement in
wire fraud, bank fraud, bank and wire fraud conspiracy, false statements to a financial institution,
theft of government funds, concealment money laundering, unlawful financial transactions, and
money laundering conspiracy in violation of 18 U.S.C. §§ 1343, 1344, 1349, 1014, 641,
1956(a)(1)(B)(i), 1956(h), and 1957 (“the Target Offenses”).
3.
I submit this affidavit in support of a criminal complaint charging each of the
Targets with conspiracy to commit wire fraud, in violation of 18 U.S.C. § 1349, and conspiracy to
commit unlawful monetary transactions, in violation of 18 U.S.C. § 1956(h), based on evidence
detailed below that they agreed conspired with each other and with others to submit numerous
fraudulent loan applications to banks to obtain Paycheck Protection Program (“PPP”) loans and to
engage in financial transactions with the fraudulently obtained loan proceeds.
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4.
I also submit this affidavit in support of an application for a warrant under 18 U.S.C.
§§ 2703(a) and Rule 41 of the Federal Rules of Criminal Procedure to search and seize records
and data from the email account identified as docsts2020@gmail.com (the “Target Email
Account”), as described in Attachment A to the proposed warrant to search that account.
5.
The facts in this affidavit come from my personal observations and review of
records, my training and experience, and information obtained from other agents and witnesses.
This affidavit does not set forth all facts developed during the course of this investigation and does
not set forth all of my knowledge about this matter. It is intended to show that there is probable
cause to believe that the Targets have committed the Target Offenses and that there is probable
cause for the requested warrants.
PROBABLE CAUSE TO BELIEVE THAT A FEDERAL CRIME WAS COMMITTED

6.
Ford lived in Palm Beach Gardens, Florida.
7.
Brown, Ford’s spouse, also lived in Palm Beach Gardens, Florida.
8.
Pierre lived in Lake Worth, Florida.
9.
Alexandre lived in West Palm Beach, Florida.
10.
Text Savvy, LLC (“Text Savvy”), Our Virtual Services Inc. (“OVS”), and Billy &
Jayrie’s Miracle, Inc. (“BJM”) were companies or not for profit corporations registered in Florida
and purportedly operated by Ford and Brown.
11.
Palm Beach Community House Inc. (“PBCH”) was a not for profit corporation
registered in Florida and purportedly operated by Alexandre.
12.
Borrower 1 was a used car dealer in Massachusetts.
13.
Borrower 2 purported to operate a property management company in Florida.
14.
Borrower 3 operated an auto body shop in Florida.
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15.
Borrower 4 also operated an auto body shop in Florida.
16.
Borrower 5 purported to operate a private transportation company in Florida.
17.
Borrower 6 purported to operate a cleaning business in Georgia.
18.
Borrower 7 purported to operate an online beauty products business in Maryland.
19.
Borrower 8 purported to operate a warehouse and cargo delivery business in
Massachusetts.
20.
Borrower 9 purported to operate a day care business in New York.1
21.
Co-Conspirator 1 (“CC-1”), an associate of Alexandre’s, lived in Massachusetts.
22.
The U.S. Small Business Administration (“SBA”) was an agency of the United
States government authorized to enable and provide for loans, guaranteed by the government, both
directly and through banks, credit unions, and other lenders.
23.
Kabbage Inc. (“Kabbage”) was based in California. It was an approved lender of
“PPP” loans, which are further described below.
24.
BlueVine was based in California. BlueVine and several approved PPP lenders,
including Celtic Bank and Cross River Bank (collectively referred to as “BlueVine” herein),
partnered to accept PPP applications and to originate and disburse PPP loans.
Overview of Federal COVID-19 Relief Programs
25.
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
Americans suffering the economic effects of the COVID-19 pandemic.
26.
The CARES Act authorized forgivable loans to small businesses and non-profits
for job retention and certain other expenses through the PPP.

1 Each of Borrowers 1 through 9 are “Subject Borrowers,” as defined below.
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27.
In order to obtain a PPP loan, a qualifying business had to submit a PPP loan
application 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 the PPP loan application, the small business, through
its authorized representative, had to state, among other things, its (i) number of employees and (ii)
average monthly payroll expenses. These figures were used to calculate the amount of a PPP loan
the business was eligible to receive; typically, a business was eligible to receive two-and-a-half
times its average monthly payroll expenses. In addition, businesses applying for a PPP loan had
to provide documentation of their payroll expenses.
28.
A PPP loan application had to be processed by an authorized SBA lender. In most
instances, applicants submitted applications and supporting documents to PPP lenders
electronically. Kabbage, Bluevine, and other PPP lenders typically recorded the internet protocol
(“IP”) address from which applications were electronically submitted.
29.
If a PPP loan application was approved, the participating lender funded the PPP
loan using its own monies, which were 100 percent guaranteed by the SBA. Data from the
application was regularly transmitted by the lender to the SBA in the course of processing the loan.
30.
PPP loan proceeds had to be used by the business on certain permissible expenses,
including 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
permissible expenses within a designated period of time and used a certain percentage of the PPP
loan proceeds on payroll expenses.

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Overview of the Conspiracy
31.
Between in or around May 2020 and continuing through at least August 2020, the
Targets conspired with each other and others to obtain PPP loans for numerous borrowers by
submitting fraudulent PPP applications. These applications falsely reported inflated numbers of
employees and total monthly payroll expenses for the borrowers’ businesses in order to obtain
larger PPP loans.
32.
Pierre, Alexandre, and others recruited individuals to apply for PPP loans for their
businesses, non-profits, or sole proprietorships. Pierre, Alexandre, and their “recruiter” co-
conspirators collected information from the borrowing individuals and entities and transmitted this
information to Ford and Brown.
33.
Ford and Brown electronically submitted PPP applications that contained false
information about employees and payroll on behalf of these borrowers to Kabbage, BlueVine, and
other PPP lenders. Ford and Brown also submitted false documentation with the PPP applications
to support false numbers of employees and false amounts of payroll expenses claimed on the PPP
applications by the borrowers.
34.
After borrowers received PPP funds based on these fraudulent applications, the
borrowers paid kickbacks to the Targets and others, commonly as a percentage of the loan
obtained.
35.
Investigators identified at least 27 borrowers (the “Subject Borrowers”) for whom
the Targets obtained approximately $7 million in PPP funds through loan applications that
investigators
have
confirmed
contained
fraudulent
misrepresentations
(the
“Subject
Applications”). Collectively, the Targets received over $1 million in kickback payments from
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Subject Borrowers for the Targets’ submission of the Subject Applications and about $490,000 in
PPP funds from lenders as a result of fraudulent applications for their own businesses.
Submission of Fraudulent PPP Applications
36.
During this investigation, I identified a fraudulent application submitted to
Kabbage on behalf of Borrower 1, described below. Kabbage’s records indicate that the IP address
134.56.24.34 (the “Target IP Address”) was used to submit the PPP application for Borrower 1.
37.
I know based on my experience and training, as well as from information I have
received from other investigators, that an IP address is a unique set of numbers assigned to an
internet or network device, such as a laptop, a computer, or other web-connected device and that
an IP address, in addition to identifying a device, provides geolocation information for the device,
including information such as area code, zip code, and city. Internet service providers also often
keep business records indication the physical address associated with an IP address.
38.
Through business records, investigators identified at least 120 additional PPP
applications that were submitted from the Target IP Address and/or from the same device (based
on common device identification number) to Kabbage or BlueVine between May 2020 and August
2020, including the Subject Applications.
39.
Internet service provider records indicate that the Target IP Address was subscribed
to an address in Florida neighboring Ford’s and Brown’s address during the relevant time period.
Bank records reflect that Ford logged into personal and business bank accounts that he alone
controlled from the Target IP Address.
40.
I have reviewed bank records for numerous recipients of PPP loans from the
applications submitted to the Target IP Address. After receiving PPP funds, several borrowers
transferred money to Text Savvy (Ford and Brown’s business), Pierre or her consulting business,
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and/or Alexandre or PBCH (his business). On several occasions, Alexandre or Pierre transferred
money to Text Savvy or each other after receiving payments from borrowers. In many cases, the
amounts transferred were in round percentages of the amount of the received loan (e.g., 10 or 20
percent).
41.
I have reviewed telephone records for phone numbers subscribed to Ford, Brown,
and Alexandre. Phone records indicate that both Alexandre and Brown had communicated with
Pierre since the beginning of 2020, prior to the passage of the CARES Act. Between late May
2020 and August 2020, when many of the applications were submitted from the Target IP Address,
Alexandre, Brown, and Ford exchanged frequent phone calls and text messages and had multiple
interactions per day nearly every day in June 2020. Throughout this period, Alexandre exchanged
phone calls and text messages with at least 11 of the Subject Borrowers.
42.
Investigators searched an email account associated with Pierre pursuant to a court-
issued warrant. Pierre’s email account contained data showing the following:
a.
Between on or about May 28 and June 2, 2020, Pierre forwarded to Brown several
emails that Pierre received from Kabbage and BlueVine, each addressed to “Adiana” and
requesting additional documentation for a PPP loan application. In one, Pierre wrote, “Good
morning Erin[,] Can your hubby check this out for me please?” Pierre subsequently sent Brown
an email attaching a purported 2019 IRS Form 1040 (U.S. Individual Income Tax Return), with a
Schedule C (Profit or Loss From Business) for a tax preparation business.2

2 I reviewed tax return information for Pierre pursuant to an ex parte order, and I have
determined that the Form 1040 and Schedule C that Pierre sent to Brown were not the forms that
Pierre filed with the IRS for tax year 2019. The tax return that Pierre filed with the IRS for 2019
showed significantly less income for the year and did not include a Schedule C.
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b.
On or about May 30, 2020, Pierre sent Brown an email with the subject “Greg
300k.” The email contained a photograph of Alexandre’s Florida driver’s license and a photograph
of a print-out of the Florida Division of Corporations’ online profile of PBCH (Alexandre’s
business). Handwritten on the print-out were the names of four individuals and the amount
“$300,000.” Shortly after this email, Pierre sent Brown another email with the subject “Push for
300k.” As described further below, a PPP application for PBCH was submitted from the Target
IP Address to Kabbage on or about June 2, 2020, requesting a loan of $300,000.
c.
Also on May 30, Pierre sent Brown an email with the subject line “Joseph 100k.”
The email contained a photograph of a Florida driver’s license for one of the Subject Borrowers
and a screenshot of the online profile of the Subject Borrower’s business. Kabbage’s records
indicate that a Subject Application for this business was submitted from the Target IP Address on
that same day.
d.
On or about June 2, 2020, Pierre sent Brown two emails, each with the names of a
Subject Borrower in the subject line. In one, for Borrower 1 (described further below), Pierre
wrote, “Push for 900k His net worth is 2 million per year!” She attached to this an IRS letter
showing Borrower 1’s business’s EIN, a photocopy of Borrower 1’s Massachusetts driver’s
license, and a license to operate a used articles business.
e.
On or about June 6, 2020, Alexandre sent Pierre an email with the subject
“Information for clients.” The email contained a table listing the following fields: Business Name,
EIN, Business Address, Business Phone Number, Applicant Full Name, Applicant Social,
Applicant D.O.B., Applicant Phone Number, Applicant Address, Requested Amount, Bank Name,
Bank Routing Number, Bank Account Number.
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f.
Between on or about June 6 and June 8, 2020, Pierre forwarded to Brown 20
purported 2019 tax returns that another individual had sent to her. In the June 6 email, Pierre
wrote, “Schedule C for some you may started [sic] already.”
g.
Throughout June and July 2020, Alexandre and other individuals sent to Pierre
articles of incorporation, bank statements, tax returns, copies of checks and utilities bills, and other
documents for businesses or non-profit organizations, and Pierre forwarded those emails to Brown.
For example, on or about June 25, 2020, Pierre forwarded to Brown an email from Borrower 5
containing a certificate of formation and bank statement for Borrower 7’s business. Pierre wrote
to Brown, “600k.” None of the emails that Pierre forwarded to Brown contained information about
the businesses’ or organizations’ employees or payroll expenses, other than any wage information
reported on tax returns.
h.
On or about June 23, 2020, Brown sent Pierre an email with the subject
“Commission Receipt.” The body of this email contained a table with columns for “Applicant,”
“Loan amount,” “10% of Loan,” “20% Pay,” “Agreed Amount,” and “Paid out.” The table listed
10 Subject Borrowers, including Borrower 1, Borrower 2, and Borrower 5, described further
below, for which the row listed loan amounts of $800,000, $500,000, and $600,000, respectively.
Brown sent Pierre an updated version of this table on or about July 1, 2020, which added an
$800,000 loan for Borrower 3 (also described further below) to the table, and wrote, “Hey hun
please see your receipt below and let me know if you have any questions.”
i.
Also on or about June 23, 2020, Brown sent an email to Pierre with the subject
“Applicant status.” Attached to this email was an Excel spreadsheet, labeled “PPP,” which listed
names and corresponding loan amounts for approximately 11 borrowers in a tab labeled
“Approved.” Pierre responded, “Thank you for the update.”
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j.
On or about June 30, 2020, Ford emailed to Pierre “a reconsideration letter for
[borrower name] to send to Kabbage” and told Pierre how to instruct the borrower to submit the
letter to Kabbage. The reconsideration letter was a form letter that contained no information
specific to the borrower.
k.
On or about July 3, 2020, Pierre received an email from the Target Email Account,
which attached a spreadsheet named “Applicant Form.” In Pierre’s emails, the Target Email
Account appears as “Documents TextSavvy” in the email headers. The first tab of the Applicant
Form spreadsheet, labeled “Waiver,” directed applicants to submit documents to the Target Email
Account.3 The second tab, labeled “Applicant Form 1,” includes, among other fields, the questions
“How many employees do you have,” “did you file a W3 Tax form in 2019,” and “Did you file
form a Schedule C Tax Form in 2019[.]” This tab advised, “You will receive a username and
password for a created email to review and manage communication with the lending company.”
Over the following several days, Pierre sent the Applicant Form spreadsheet to four individuals. I
have not located any completed Applicant Form spreadsheet in Pierre’s email account. However,
thereafter, Pierre forwarded various documents that she received from applicants to the Target
Email Account.
l.
On or about July 21, 2020, Brown sent Pierre an email with the subject “Approved.”
The email listed 19 names, including the names of 17 Subject Borrowers.

3 This tab also included the following certification: “I certify that the information and
certifications provided in this application and in all supporting documents and forms continues
[sic] to remain true and accurate in all material respects. I understand that knowingly making a
false statement to obtain a guaranteed loan from SBA is punishable under the law, including under
18 18 USC 1001 and 3571 by imprisonment of not more than five years and/or a fine of up to
$250,000; under 15 USC 645 by imprisonment of not more than two years and/or a fine of not
more than $5,000; and, if submitted to a federally insured institution, under 18 USC 1014 by
imprisonment of not more than thirty years and/or a fine of not more than $1,000,000.” This
language is nearly identical to a certification on the SBA’s official PPP application.
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m.
On or about July 30, 2020, Pierre forwarded to the Target Email Account several
documents relating to another borrower and wrote, “Let’s get her done ASAP! The boss said I’m
not sending enough lol[.]”
n.
Emails indicate that Pierre continued to correspond with the Target Email Account
regarding PPP “second draw” loan applications, loan forgiveness applications, and other pandemic
relief throughout 2021.4 For example, in or around December 2020, one of the Subject
Borrowers—a self-described computer technician who had received a $400,000 PPP loan as a
result of an application submitted by Ford—emailed Pierre an “Expense Report,” itemizing
expenses of over $442,000 for the period between June 5, 2020 (the date that Ford submitted the
PPP application) and November 30, 2020. Pierre forwarded this Expense Report to the Target
Email Account and wrote, “This is for [borrower name]. He wants to do the loan forgiveness
program.” The following day the Subject Borrower emailed Pierre a version of the Expense Report
updated to show purported payroll costs of over $340,000, which, if true, would have qualified his
business for forgiveness of the PPP loan. Pierre forwarded this document to the Target Email
Account and wrote, “[Borrower name] updated expenses.” The Target Email Account replied,
“Hey Addy, Please have [borrower name] do the following,” and provided instructions for the
Subject Borrower to log in to the website of Kabbage’s successor loan servicer.
43.
Based on the foregoing information, I have concluded that Alexandre and Pierre
identified potential applicants for PPP loans and provided those applicants’ information to Brown

4 Emails from the Target Email Account in 2021 instruct Pierre and applicants to provide
applicants’ 2019 or 2020 1040-Schedule C. For example, several emails state, “If you have not
completed 1040 Schedule C for 2019, fill it out and compute the value for line 31. We cannot
accept this form for previous years. If line 31 on the 1040 Schedule C is less than $2,400, your
business is not eligible for a PPP loan.” Investigators have not identified applications submitted
by Ford in 2021 to determine whether those applications also contained fraudulent representations
about borrowers’ payroll expenses.
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and Ford. Ford then submitted applications to Kabbage, BlueVine, and other PPP lenders
electronically, from the Target IP Address. Further, I have determined that applicants who
received PPP loans as a result of applications submitted by Ford paid Alexandre, Pierre, Ford and
Brown, and other kickbacks or “commissions” after receiving loan proceeds.
44.
Ford submitted the Subject Applications on behalf of business or non-profit entities
and self-employed individuals located in Florida, Georgia, Maryland, Massachusetts, and New
York. Fourteen of the Subject Applications resulted in loans in amounts greater than $80,000,
totaling over $6.6 million. Many of the remaining Subject Applications resulted in loans to
purported sole proprietors in amounts generally between $20,000 and $30,000.
45.
For each of the Subject Applications, investigators identified one or more indicia
of fraud based on information provided on the application, supporting documentation submitted
with the application, public records filed by the borrower (or lack thereof), and/or bank records
revealing payment of a kickback and/or improper use of PPP funds.5
a.
Supporting documentation: For each Subject Application, Ford submitted
documents purporting to demonstrate the borrower’s payroll expenses or other business
information. Most commonly, Ford submitted a Form W-3 or a Form 1040 Schedule C that
purported to show total wages in amounts that supported the average monthly payroll expense
amount listed on the PPP application. For 15 of the 16 Subject Applications that resulted in loans
of over $80,000, Ford submitted Forms W-3 that, based on my training and experience, I know
were falsified. I reviewed tax return information for each of these borrowers pursuant to an ex
parte order, and only two of these borrowers filed an IRS Forms 941 (Employer’s Quarterly

5 Investigators have not reviewed information for every PPP application that PPP lenders
have identified as having originated from the Target IP Address. PPP lenders generally did not
maintain full records of applications that they or the SBA rejected.
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Federal Tax Return) reporting information about wages paid to employees.6 With respect to the
two borrowers that filed Forms 941, those forms reported wages paid in amounts significantly
lower than the payroll expenses claimed on the submitted PPP applications. Additionally, the
Forms W-3 exhibited several infirmities, such as amounts of withheld taxes equal to amounts of
corresponding wages (as described specifically with respect to Borrower 1’s application, below),
incorrect Medicare wages amounts, and/or state taxes withheld without any stage wages reported.7
Ford submitted several IRS forms that failed to report any federal income tax, state income tax,
Social Security wages or tax, and/or Medicare wages or tax. Moreover, between on or about June
2, 2020 and on or about June 7, 2020, Ford submitted eight PPP applications for individuals
purporting to be self-employed barbers. Each of these applications stated that the applicant earned
a monthly average income of $8,334. Ford submitted with each of these applications a 2019
Schedule C that stated that the individual earned a net income of $105,236 after expenses in 2019.
These Schedules C were identical with respect to the amount of income reported and, for six of
these Schedules C, every expense deducted. Based on these defects and/or identical submissions,
and the fact that I observed none of these Forms W-3 pass through Pierre’s email account, I
conclude that Ford falsified these IRS forms for the purpose of representing to lenders that
borrowers had previously paid wages corresponding to the monthly average payroll expenses
claimed on their applications.

6 Information that employers file on Forms 941 typically correspond to the employment
data that employers summarize on the Forms W-3 that they submit to the Social Security
Administration.

7 Social Security and Medicare taxes should be a fixed percentage of the associated wages
(6.2% and 1.45% respectively) and should not be the same amount as the associated wages.
Additionally, because there is no cap on the amount of Medicare wages that are taxable, Medicare
wages should be equal to or greater than the gross wages reported; however, the Forms W-3
submitted by Ford reported lower amounts of Medicare wages.
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46.
Public Records: Investigators reviewed public filings submitted by employers to
state authorities in Florida and Massachusetts. These records indicate that borrowers for whom
Ford submitted applications did not previously report having the numbers of employees that were
claimed on the applications, as required by state law. For example, records from the Florida
Department of Revenue indicate that none of the Florida-based borrowers for whom Ford reported
more than one employee on a PPP application had filed Reemployment Tax reports for the
preceding period, as required by Florida law. Similarly, records from the Massachusetts
Department of Revenue indicate that Borrower 1 had reported far fewer employees than the 40
employees claimed on the PPP application and that Borrower 8 (described further below) had not
filed a report regarding any employees for that period in which his PPP loan application stated that
he had 25 employees. Tax return information indicated that at least 16 of the Subject Borrowers
for whom Subject Applications claimed employees in 2019 did not filed employment tax returns
for their businesses for the tax year 2019 with the IRS.
47.
Second Draw Loans: In or around January 2021, the SBA began accepting
applications for “second draw” PPP loans—additional PPP funds for borrowers who previously
received a PPP loan. Pierre’s email correspondence shows that, beginning in or around January
2021, Pierre transmitted to the email address “getmypppnow@gmail.com” business information
for several of the borrowers who received PPP loans through applications submitted by Ford in
June or July 2020. Information that Pierre transmitted for second draw applications conflicted
with information reported on the initial PPP applications. For example, Ford submitted a PPP
application for a computer technician on or about June 5, 2020 and reported on that application
that the technician had 25 employees and average monthly payroll expenses of $160,000. Ford
submitted with this application a purported 2019 Form W-3 that reported gross wages paid of
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$1,920,000. As a result, the technician received a PPP loan of $400,000 on or about June 9, 2020.
However, in January 2021, Pierre forwarded to getmypppnow@gmail.com information for the
technician’s business, including a Schedule C that listed total expenses for 2019 of only $15,775
and no wages paid by the business. These subsequent, inconsistent second draw applications
further show that Ford fabricated the numbers of employees and amounts of monthly payroll
expenses reported on the June through August 2020 PPP applications, as well as the purported
Forms W-3 submitted with those applications.8
48.
Kickbacks and Improper Uses: From a review of select bank records, investigators
also observed that, after receiving PPP funds, several of the borrowers made transfers that were
inconsistent with PPP requirements, such as large transfers to the business owner(s), spouses, and
family members or purchases of vehicles and, in at least one case, a new residence. Further, as
described further below each of these loan recipients paid a kickback or “commission” to at least
one of the Targets, and, in many cases, borrowers made payments to two or three of the Targets or
other recruiters. For example, the purported computer technician Subject Borrower described
above paid $40,000 each to Text Savvy and Alexandre, transferred approximately $60,000 to his
spouse, purchased a Cadillac for approximately $22,000, and diverted over $140,000 for the
benefit of a tropical restaurant that he and his spouse owned.
49.
Several examples of fraudulent loan applications that the Targets caused to be
submitted are provided below.

8 Based on my review of email records, I believe that the subscriber of the
getmypppnow@gmail.com email address is another associate of Pierre’s and that Pierre sent this
associate information for submitting second draw PPP applications on behalf of several of the
borrowers for whom Ford previously submitted an initial PPP application.
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Borrower 1
50.
Bank records shows that Massachusetts-based Borrower 1 received a PPP loan of
$836,800 from Kabbage for his business, a used car dealership, on or about June 5, 2020. The
Subject Application submitted to Kabbage represented that Borrower 1’s business had 40
employees and average monthly payroll expenses of $334,720.
51.
The supporting documentation for the application submitted to Kabbage included
a purported copy of a 2019 Form W-3 (Transmittal of Wage and Tax Statements) for Borrower
1’s business. This form indicated that the business’s gross payroll expenses in 2019 were
$3,840,000 and that the company withheld $384,000 in federal income taxes. The Form W-3 also
reported that the business paid $238,080 in Social Security wages and withheld that same amount
in Social Security taxes, and that it paid $55,680 in Medicare wages and withheld that same amount
in Medicare taxes.
52.
Based on business records and the investigation to date, I have determined that the
application to Kabbage vastly overstated Borrower 1’s employees and payroll expenses:
a.
In two prior PPP applications that Borrower 1 submitted to other PPP lenders, as
well as two applications for Economic Injury Disaster Loan (“EIDL”) funds that Borrower 1
submitted to the SBA in 2020, Borrower 1 stated that his business employed only two to four
individuals and had 2019 payroll expenses of far less than the amount that the Kabbage PPP
application reported.
b.
Records from the Massachusetts Department of Revenue show that Borrower 1’s
business reported, for the second quarter of 2020 (during which Kabbage received the PPP
application), 12 employees and gross wages of $27,616 (approximately $9,205 per month).
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c.
Federal tax return information, which I have reviewed, indicates that Borrower 1
did not file employment tax returns for his business for the tax year 2019.
d.
Further, bank records for Borrower 1 and his business do not reflect the payroll
activity represented on the Kabbage PPP application. The income and expenses reflected in the
bank records are not consistent with a dealership with 40 employees and yearly payroll expenses
of $3.8 million, as represented in the PPP application package.
a.
There is probable cause to believe the Form W-3 that was submitted for Borrower
1’s business was fabricated. The amounts reported on this Form W-3 are inconsistent with IRS
forms that Borrower 1 submitted in support of prior applications, described above. Further, I have
reviewed IRS records with respect to Borrower 1 pursuant to an ex parte order, and those records
do not include any Forms 941 or W-3 reporting employee or wage information. Additionally, the
purported Form W-3 submitted to Kabbage exhibited several of the infirmities common to other
purported Forms W-3 that Ford submitted, including identical amounts listed for Social Security
and Medicare taxes and their associated wages, as well as other errors.
53.
Based on bank records and phone records, there is probable cause to believe that
Alexandre and CC-1 recruited Borrower 1 to apply for a PPP loan through the Targets:
a.
Telephone records indicate that CC-1 regularly communicated with both Alexandre
and Borrower 1 earlier in 2020, before the PPP application for Borrower 1’s business was
submitted to Kabbage. Alexandre contacted Borrower 1 on June 3, 2020—the day that the
application was submitted—after speaking with CC-1. After Alexandre’s initial call to Borrower
1, the two exchanged several more calls and text messages on June 3, 2020, as well as calls and
text messages on several other occasions throughout the remainder of June 2020.
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b.
Bank records demonstrate that, shortly after receiving PPP funds from Kabbage,
Borrower 1 sent two checks totaling $28,000 to PBCH (Alexandre’s business). The memo line on
the first check, dated June 9, 2020, stated “payroll check.” The memo line of the second check,
dated June 12, 2020, read “services.”9
54.
Bank records reflect that, after receiving kickback payments from Borrower 1,
Alexandre transferred a portion of those payments to Ford. Shortly after receiving the first check
from Borrower 1, on or about June 11, 2020, Alexandre issued a check for $8,000 to Text Savvy
(Ford and Brown’s business). After depositing the second check from Borrower 1, on or about
June 15, 2020, Alexandre issued a check for $13,000 to Text Savvy on or about June 18, 2020.
55.
In addition to the kickback payments to Alexandre, bank records reflect that
Borrower 1 used PPP funds for expenses that were inconsistent with PPP requirements. For
example:
a.
Borrower 1 made a series of payments disguised as payroll checks, but at least
$28,857 of these payments were endorsed either to Borrower 1’s brother or sister-in-law, and at
least $25,000 was subsequently transferred back to Borrower 1.
b.
Borrower 1 paid $133,000 for a 2014 Rolls Royce Wraith for his own use.
c.
Borrower 1 also paid $257,049.79 in costs for a new residence that he purchased in
his sister’s name.

9 The “Commission Receipt” table that Brown emailed to Pierre, described above,
indicated that Borrower 1 was expected to pay $80,000 (i.e., ten percent of $800,000).
Investigators have not identified kickback payments from Borrower 1 in addition to the $28,000
that Borrower 1 paid to PBCH.
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Borrowers 2, 3, and 4
56.
On or about June 1, 2020, Pierre sent to a Florida-based individual (“Person 1”) an
email that contained the name, address, and employer identification number (EIN) of a purported
property maintenance business in Miami, Florida; the name and Social Security number of
Borrower 2; and bank account information. Person 1 responded, “You missing the bank
statement[.]” Pierre then emailed Person 1: “He said can y’all create on[e] for him. He doesn’t
have any.” Person 1 replied, on or about June 2, 2020, “No, I can’t. The bank account dont need
to have money[.]” Pierre responded, “He didn’t have the account until last week. Does that
matter?” Pierre’s email account contains no other messages between Pierre and Person 1. Based
on these messages and the investigation to date, I believe that Pierre attempted to cause Person 1
to submit a PPP application on behalf of Borrower 2 before she began coordinating with Ford and
Brown.
57.
Business records indicate that, on or about June 4, 2020, a Subject Application was
submitted to Kabbage from the Target IP Address on behalf of Borrower 2’s business. The
application stated that Borrower 2 had 20 employees and average monthly payroll expenses of
$200,000. The application requested a PPP loan in the amount of $500,000.
58.
Kabbage approved the loan and disbursed $500,000 to the specified bank account
for Borrower 2 on or about June 5, 2020.
59.
On or about June 8, 2020, Borrower 2 purchased a $50,000 cashier’s check payable
to Text Savvy and a $20,000 cashier’s check payable to Pierre.
60.
On or about June 18, 2020, Borrower 2 sent Pierre an email that attached electronic
articles of incorporation for Borrower 3’s auto body shop. Business records indicate that, on that
same day, a Subject Application was submitted to Kabbage from the Target IP Address on behalf
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of Borrower 3. The application requested a loan of $800,000, based on 40 employees and average
monthly payroll expenses of $320,000. Kabbage approved this application and disbursed
$800,000 to an account controlled by Borrower 3 on or about June 24, 2020.
61.
The Florida Department of Revenue did not locate records of any wage reports filed
by Borrower 3 for 2019 or 2020. I reviewed bank records for Borrower 3, and I did not observe
any payroll-related expenses before or after Borrower 3’s receipt of PPP funds.
62.
Within days of receiving PPP funds, Borrower 3 purchased three cashier’s checks,
each for $80,000 (i.e., 10% of the PPP loan amount), payable to Pierre, Text Savvy, and Borrower
4.
63.
On or about June 29, 2020 and July 6, 2020, Borrower 2 purchased a series of
cashier’s checks, totaling $66,190. These checks listed different individual payees and specified
that they were for “payroll” or “backpay payroll.” Two of these checks were issued to Borrower
2 personally, and all the other checks were cashed at a check cashing business. I have reviewed
bank records for accounts for Borrower 2’s business. These account records did not reflect any
payroll-related payments between January 2020 and June 2020. Based on my knowledge of PPP
rules—specifically, the requirement to submit proof of payroll expenses for later forgiveness of
the PPP loan—I believe that Borrower 2 purchased these checks to create the appearance of payroll
expenses.
64.
On or about July 8, 2020, Pierre sent Borrower 2 the “Applicant Form” spreadsheet
(described above) and wrote, “Have client fill this out[.]” Based on my review of Pierre’s emails,
described above, I believe that Ford and/or Brown instructed Pierre to direct potential borrowers
to complete this form, and that Pierre sent this form to Borrower 2 in anticipation of Borrower 2
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referring one or more additional borrowers to Pierre. However, as noted above, I have not
identified any completed forms of this kind in Pierre’s email account.
65.
Investigators interviewed Borrower 3 on or about August 19, 2021. Borrower 3
stated that Borrower 4, for whom Borrower 3 previously worked, offered to assist Borrower 3 with
applying for a PPP loan in 2020. According to Borrower 3, Borrower 4 and another individual,
unknown to Borrower 3, visited Borrower 3’s shop and gathered information about his Social
Security number, contact information, business license, driver’s license, and bank account
information. Borrower 3 stated that he understood that Borrower 4 and the other individual would
apply for a PPP loan for him, but that he did not know what amount of a loan that they would
request or that he would receive. Borrower 3 stated that he had not provided them with information
about his employees, business income, or payroll expenses and that he did not provide them with
articles of incorporation or other documents. He stated that he had never seen the loan application
or supporting documents that were submitted to Kabbage, including the Form W-3, and that he
had never paid $3.8 million in payroll expenses, as the Form W-3 reported. Borrower 3 stated
that, after he received the PPP funds, Borrower 4 accompanied him to the bank and instructed him
to write the three cashier’s checks. I believe that the unknown male with Borrower 4 was Borrower
2, based on Borrower 2’s email transmission of articles of incorporation for Borrower 3’s business
to Pierre.
Borrowers 5, 6, and 7
66.
Business records reflect that, on or about June 9, 2020, a Subject Application was
submitted to Kabbage from the Target IP Address on behalf of Borrower 5. The application stated
that Borrower 5 had 25 employees and average monthly payroll expenses of $240,000 during the
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prior year. Kabbage approved the application and disbursed $600,000 to a bank account for
Borrower 5 on or about June 16, 2020.
67.
The Florida Department of Revenue did not locate any records relating to Borrower
5’s business. I have reviewed bank records for Borrower 5, and I observed no payroll-related
expenses between April 15, 2019, when the account was first opened, and the receipt of PPP funds.
The only receipts I observed between January 2020 and receipt of the PPP funds totaled $29,092,
$26,981 of which came from Uber or Lyft and are consistent with payments for completing trips
for those companies.
68.
Bank records indicate that, on or about June 17, 2020, Borrower 5 purchased two
cashier’s checks, each for $60,000, payable to Pierre and Text Savvy. Over the following week,
Borrower 5 also transferred approximately $225,000 to family members and to himself, via
cashier’s checks and cash withdrawals, as well as $100,000 to another individual by cashier’s
check.
69.
On or about June 18, 2020, Pierre emailed Brown with Borrower 5’s email address
and wrote, “This gentleman wants to apply for the forgiveness program.”
70.
Between on or about June 18, 2020 and July 8, 2020, Borrower 5 sent Pierre
numerous emails with attachments relating to at least 11 different businesses or non-profit
organizations. Pierre forwarded these emails to Brown. Business records indicate that Kabbage
received applications for these businesses or non-profits that were submitted from the Target IP
Address attributed to Ford. Of these, Kabbage approved the loan applications for the following
businesses:
a.
Borrower 6’s business, which received a PPP loan of $300,000, based on 15
employees and average monthly payroll expenses of $120,000 claimed on the application; and
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b.
Borrower 7’s business, which received a PPP loan of $600,000 based on 30
employees and average monthly payroll expenses of $240,000 claimed on the application.
71.
I have reviewed bank records for both of these businesses. Based on these records,
neither business paid any payroll-related expenses in 2019.
72.
On or about June 26, 2020, after receiving PPP funds for his business, Borrower 6
transferred $30,000 to Pierre, $30,000 to Text Savvy (Ford and Brown’s business), as well as
$60,000 to another individual who, based on emails between Borrower 5 and Pierre, I believe
introduced Borrower 6 to Borrower 5.
73.
On or about July 2, 2020, after receiving PPP funds for her business, Borrower 7
transferred $120,000 and $75,000 to two of the businesses whose information Borrower 5 had sent
to Pierre and Pierre had forwarded to Brown, but whose applications Kabbage did not approve.
Based on these payments, I believe that these payees had introduced Borrower 7 to Borrower 5.
Borrower 7 also withdrew over $31,000 in cash.
74.
On or about July 7, 2020, Pierre emailed Borrower 5, attached the “Applicant
Form” spreadsheet (described above), and instructed him, “Please have all clients fill this out.” As
with Borrower 2, I believe that Pierre sent this form to Borrower 5 in anticipation of Borrower 5
referring one or more additional borrowers to Pierre. However, I have not identified any completed
forms of this kind in Pierre’s email account.
Other Subject Borrowers
75.
Ford submitted a Subject Application for Borrower 8’s business on or about June
9, 2020, the day after Borrower 8 spoke by phone with CC-1. Borrower 8’s business was not
registered with Massachusetts until April 2020 and did not open a bank account until June 2020.
Nonetheless, the PPP application stated that Borrower 8’s business had 25 employees and average
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monthly payroll expenses of $125,541. The application was supported by a Form W-3 with defects
consistent with those described above; for example, the Form W-3 indicated that the business paid
$89,280 in Social Security wages and withheld that same amount in Social Security taxes, and that
the business paid $20,880 in Medicare wages and withheld that same amount in Medicare taxes.
Phone records show that Borrower 8 communicated with Alexandre by phone on or about June
13, 2020 and exchanged several phone calls and text messages with Alexandre between on or
about June 13 and 17, 2020. On or about June 15, 2020, Kabbage approved the application.
Kabbage disbursed $313,852 to Borrower 8’s business on or about June 17, 2020. Bank records
demonstrate that, between on or about June 19, 2020 and July 3, 2020, Borrower 8 sent four checks
totaling $62,670 to PBCH (Alexandre’s business). Shortly after receiving the first three of these
checks, Alexandre purchased a cashier’s check for $30,000 payable to Text Savvy. Borrower 8
also sent five checks totaling $45,000 to CC-1 between June 19, 2020 and July 31, 2020.
76.
On or about June 24, 2020, Borrower 9 emailed Pierre with information about her
day care business and instructed Pierre to “please apply for $950k.” Pierre forwarded Borrower
9’s email to Brown with the message “new client.” Business records indicate that Kabbage
received an application for Borrower 9’s business that same day, which stated that the business
had 35 employees and an average monthly payroll of $285,518. Kabbage approved this
application and disbursed $713,793 to the business on or about July 1, 2020. Thereafter, on or
about July 11, 2020, Borrower 9 purchased two cashier’s checks, each for $71,379 (i.e., 10% of
the PPP loan amount), payable to Pierre’s consulting business and to Text Savvy. I reviewed bank
records for Borrower 9’s business, and I did not observe any payroll-related expenses prior to the
loan application. Further, the only individual payees after the receipt of PPP funds were Borrower
9 and her husband.
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Targets’ PPP Loans
77.
Each of the Targets also received PPP loans as a result of fraudulent submissions
to Kabbage by Ford.
78.
Ford submitted a PPP application for Text Savvy to BlueVine on or about April 27,
2020; an application for BJM to Kabbage on or about May 9, 2020; and an application for OVS to
BlueVine on or about May 29, 2020. The Text Savvy and BJM applications each reported that
these businesses had ten employees and average monthly payroll expenses of $11,648 and $15,600
respectively. BlueVine approved the Text Savvy application and disbursed $29,121 to Ford’s bank
account on or about May 1, 2020, while Kabbage approved the BJM application and disbursed
$39,000 to Ford’s bank account on or about May 12, 2020. The OVS application reported that
OVS had five employees and average monthly payroll expenses of $40,000. BlueVine approved
the OVS application and disbursed $100,000 to Brown’s account on or about June 6, 2020. In
total, Ford and Brown obtained $168,121 in PPP funds through these applications.
79.
I have reviewed Ford’s bank records, and they do not support his representations
about his payroll expenses. Based on my review of bank records, there is probable cause to believe
that Ford inflated the employee and payroll information on each of these applications. The Forms
W-3 submitted with the BJM and OVS applications also stated Social Security and Medicare taxes
withheld equal to the corresponding wages, while the employment tax return submitted with the
Text Savvy application was never filed with the IRS.
80.
Alexandre initially submitted a PPP application for PBCH to another PPP lender
on or about April 10, 2020 and requested a PPP loan of $55,332, based on $22,133 in reported
monthly payroll expenses. The PPP lender rejected this application. On or about June 2, 2020
and June 9, 2020, Ford submitted PPP applications for PBCH to Kabbage and BlueVine,
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respectively. Both applications requested a loan of $300,000 and reported that PBCH had 20
employees and average monthly payroll expenses of $120,000. In support of both applications,
Ford submitted a purported 2019 Form W-3 that stated Social Security and Medicare taxes
withheld equal to the corresponding wages, from which I have determined that the Form W-3 was
falsified. I have reviewed PBCH’s bank records, and they do not include show any payments
resembling payroll expenses. Kabbage flagged the application for potential fraudulent activity.
BlueVine approved the applications for PBCH submitted by Ford, and BlueVine disbursed
$300,000 to PBCH on or about July 23, 2020. The same day that PBCH received loan funds,
Alexandre purchased a cashier’s check for $30,000 payable to Text Savvy.
81.
Pierre initially submitted a PPP application to BlueVine on or about May 3, 2020,
which BlueVine rejected. On or about June 2, 2020, Ford submitted a PPP application to Kabbage
for Pierre’s purported financial consulting business. The application reported average monthly
payroll expenses of $8,334 for one employee. In support of this application, Pierre emailed Brown
a purported 2019 Schedule C which reported Gross Income of $111,567. I have reviewed Pierre’s
tax returns and tax return information pursuant to an ex parte order, and the IRS never received
the Schedule C that Pierre attached to this loan application. Further, bank records for Pierre do
not support the monthly payroll expenses or the gross income reported on this application. As a
result of this fraudulent application, Kabbage disbursed a PPP loan in the amount of $20,833 to
Pierre on or about June 4, 2020.
Kickback Payments
82.
I have reviewed bank records with respect to each of the Subject Borrowers. The
bank records show that each Subject Borrower made a payment to at least one of the Targets after
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receiving loan proceeds based on the fraudulent loan applications. In numerous instances, a
Subject Borrower made payments to two or even three of the Targets or other recruiters.
83.
Ford and Brown—through Text Savvy and OVS—received at least approximately
$528,122 from Alexandre and at least 10 Subject Borrowers, including a $40,000 cashier’s check
from the purported computer technician borrower, a $50,000 cashier’s check from Borrower 2, an
$80,000 cashier’s check from Borrower 3, a $60,000 cashier’s check from Borrower 5, a $30,000
transfer from Borrower 6, and a $71,379 cashier’s check from Borrower 9, as described above.
84.
Pierre directly received at least approximately $406,772 from at least nine Subject
Borrowers, including a $20,000 cashier’s check from Borrower 2, an $80,000 cashier’s check from
Borrower 3, a $60,000 cashier’s check from Borrower 5, a $30,000 transfer from Borrower 6, and
a $71,379 cashier’s check from Borrower 9, as described above.
85.
Alexandre received at least approximately $143,760 from at least four Subject
Borrowers, including a $40,000 cashier’s check from the purported computer technician borrower,
two $14,000 checks from Borrower 1, and four checks for $15,690 each from Borrower 8, as
described above.
86.
Additionally, Borrower 4 received the $80,000 kickback from Borrower 3, and
another recruiter received kickbacks totaling $180,000 from two of the Subject Borrowers,
including $120,000 from Borrower 7.
Probable Cause to Search the Target Email Account
87.
There is probable cause to believe that the Target Email Account and associated
data contain evidence, fruits, and instrumentalities of the Target Offenses.
88.
Based on the name associated with the Target Email Account—”Documents
TextSavvy”—I believe that Ford and/or Brown used the Target Email Account in connection with
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submitting PPP applications, under the name of the Text Savvy business that they had previously
registered.
89.
As described above, Pierre’s email records indicate that Pierre corresponded with
the Target Email Account beginning in July 2020 in connection with the submission of PPP
applications by Ford and Brown on behalf of numerous borrowers. Pierre’s correspondence with
the Target Email Account continued through at least in or around February 2022.
90.
Further, the Applicant Form spreadsheet that the Target Email Account emailed to
Pierre, and which Pierre emailed to several individuals, instructed applicants to submit documents
to the Target Email Account.
91.
I am aware, based on my training and experience investigating computer-enabled
crime, that subjects often use email accounts to communicate with coconspirators and to create
and activate financial accounts. I also am aware that subjects often use Google services to store
and transfer images and/or documents, to store contacts, and to maintain calendar entries related
to fraudulent activity.
92.
Based on the emails that I observed in Pierre’s email account, as well as the
connection between the fraudulent PPP applications and the Target IP Address and Ford, there is
probable cause to believe that Ford and/or Brown used the Target Email Account to communicate
with other Targets, recruiters, and borrowers about the submission of fraudulent PPP applications
and to facilitate the submission of those applications and the collection of kickback payments.
93.
On December 3, 2022, Assistant U.S. Attorney David Holcomb sent Google a letter
requesting under 18 U.S.C. § 2703(f) that Google preserve records associated with the Target
Email Account for 90 days.

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TECHNICAL BACKGROUND FOR SEARCH OF TARGET EMAIL ACCOUNT
94.
Based on my training and experience, I understand that Google and other email
providers allow customers to store opened incoming mail and sent mail indefinitely if they choose,
subject to a maximum size limit.
95.
Email providers also typically maintain electronic records relating to their
customers. These records include account application information, account access information,
and email transaction information. Based on my training and experience, I know that this
information can include the date on which the account was created, the length of service, records
of login (i.e., session) times and durations, the types of service utilized, the status of the account
(including whether the account is inactive or closed), the methods used to connect to the account
(such as logging into the account via the provider’s website), and other log files that reflect usage
of the account. Providers such as Google also commonly have records of the IP address used to
register the account and the IP addresses associated with other logins to the account. Because
every device that connects to the Internet must use an IP address, IP address information can help
to identify which devices were used to access the relevant account. Also, providers such as Google
typically collect and maintain location data related to subscriber’s use of Google services,
including data derived from IP addresses and/or Global Positioning System (“GPS”) data.
96.
Based on my training and experience, I know that providers such as Google also
collect information relating to the devices used to access a subscriber’s account – such as laptop
or desktop computers, cell phones, and tablet computers. Such devices can be identified in various
ways. For example, some identifiers are assigned to a device by the manufacturer and relate to the
specific machine or “hardware,” some identifiers are assigned by a telephone carrier concerning a
particular user account for cellular data or voice services, and some identifiers are actually assigned
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by Google in order to track what devices are using Google’s accounts and services. Examples of
these identifiers include unique application number, hardware model, operating system version,
Global Unique Identifier (“GUID”), device serial number, mobile network information, telephone
number, Media Access Control (“MAC”) address, and International Mobile Equipment Identity
(“IMEI”). Based on my training and experience, I know that such identifiers may constitute
evidence of the crimes under investigation because they can be used (a) to find other Google
accounts created or accessed by the same device and likely belonging to the same user, (b) to find
other types of accounts linked to the same device and user, and (c) to determine whether a
particular device recovered during course of the investigation was used to access the Google
account.
97.
Based on my training and experience, I know that providers such as Google use
cookies and similar technologies to track users visiting Google’s webpages and using its products
and services. A “cookie” is a small file containing a string of characters that a website attempts to
place onto a user’s computer. When that computer visits again, the website will recognize the
cookie and thereby identify the same user who visited before. This sort of technology can be used
to track users across multiple websites and online services belonging to Google. More
sophisticated cookie technology can be used to identify users across devices and web browsers.
From training and experience, I know that cookies and similar technology used by providers such
as Google may constitute evidence of the criminal activity under investigation. By linking various
accounts, devices, and online activity to the same user or users, cookies and linked information
can help identify who was using a Google account and determine the scope of criminal activity.
98.
Based on my training and experience, I know that Google maintains records that
can link different Google accounts to one another, by virtue of common identifiers, such as
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common email addresses, common telephone numbers, common device identifiers, common
computer cookies, and common names or addresses, that can show a single person, or single group
of persons, used multiple Google accounts. Based on my training and experience, I also know that
evidence concerning the identity of such linked accounts can be useful in identifying the person or
persons who have used a particular Google account.
99.
Based on my training and experience, I know that Google can also provide the
following additional information associated with a subscriber’s account: address books; buddy
lists; photos, files, data, or other information; and World-Wide Web profiles or homepages.
LEGAL AUTHORITY FOR SEARCH OF TARGET EMAIL ACCOUNT
100.
The government may obtain both electronic communications and subscriber
information from an email provider by obtaining a search warrant. 18 U.S.C. §§ 2703(a) and
2703(c)(1)(A).
101.
Any court with jurisdiction over the offense under investigation may issue a search
warrant under 18 U.S.C. § 2703(a), regardless of the location of the website hosting company or
email provider whose information will be searched. 18 U.S.C. § 2703(b)(1)(A). Furthermore,
unlike other search warrants, § 2703 warrants do not require an officer to be present for service or
execution of the search warrant. 18 U.S.C. § 2703(g).
102.
If the government obtains a search warrant, there is no requirement that either the
government or the provider give notice to the subscriber. 18 U.S.C. §§ 2703(b)(1)(A), 2703(c)(3).
103.
This application seeks a warrant to search all responsive records and information
under the control of Google, a provider subject to the jurisdiction of this court, regardless of where
Google has chosen to store such information. Pursuant to 18 U.S.C. § 2713, the government
intends to require the disclosure pursuant to the requested warrant of the contents of wire or
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electronic communications and any records or other information pertaining to the customers or
subscribers if such communication, record, or other information is within Google’s possession,
custody, or control, regardless of whether such communication, record, or other information is
stored, held, or maintained outside the United States.
REQUEST TO SEAL AND PRECLUDE NOTICE TO THE SUBSCRIBER(S)
104.
I request that this application, the warrant, the order, and any related papers be
sealed by the Court until such time as the Court pursuant to Local Rule 7.2 directs otherwise.
105.
I further request that, pursuant to the preclusion-of-notice provisions of 18 U.S.C.
§ 2705(b), the Court order Google, respectively, not to notify any person (including the subscriber
to whom the materials relate) of the existence of this application or the Court’s Order for the earlier
of one year from the date of the Court’s Order or upon notice by the government within 30 days
of the conclusion of its investigation, unless the Court extends such period under 18 U.S.C. §
2705(b). Non-disclosure is appropriate in this case because the Court’s Order relates to an ongoing
criminal investigation that is neither public nor known to all of the targets of the investigation, and
its disclosure may alert the targets to the existence of the investigation. There is accordingly reason
to believe that notification of the existence of the Order will seriously jeopardize the investigation,
including by giving targets an opportunity to flee or continue flight from prosecution, destroy or
tamper with evidence, or change patterns of behavior. See 18 U.S.C. § 2705(b). Moreover, some
of the evidence in this investigation is stored electronically. If alerted to the existence of the Order,
the targets could destroy that evidence, including information saved to their personal computers,
on other electronic media, or in social media accounts.

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FOURTEEN-DAY RULE FOR EXECUTIONS OF WARRANT
106.
Federal Rule of Criminal Procedure 41(e)(2)(A),(B) directs the United States to
execute a search warrant for electronic evidence within 14 days of the warrant’s issuance. If the
Court issues the applied-for warrants, the United States will execute it not by entering the premises
of Google, as with a conventional warrant, but rather by serving copies of the warrants on Google
and awaiting Google’s production of the requested data. This practice is approved in 18 U.S.C. §
2703(g), and it is generally a prudent one because it minimizes the government’s intrusion onto
Internet companies’ physical premises and the resulting disruption of their business practices.
107.
Based on my training and experience and that of other law enforcement, I
understand that e-mail providers sometimes produce data in response to a search warrant outside
the 14-day period set forth in Rule 41 for execution of a warrant. I also understand that e-mail
providers sometimes produce data that was created or received after this 14-day deadline (“late-
created data”).
108.
The United States does not ask for this extra data or participate in its production.
109.
Should Google produce late-created data in response to the applied-for warrants, I
request permission to view all late-created data that was created by Google, including subscriber,
IP address, logging, and other transactional data, without further order of the Court. This
information could also be obtained by grand jury subpoena or an order under 18 U.S.C. § 2703(d),
neither of which contains a 14-day time limit. However, law enforcement personnel will seek to
avoid reviewing any late-created data that was created by or received by the account-holder(s),
such as e-mail, absent a follow-up warrant.
110.
For these reasons, I request that the Court approve the procedures in Attachment B,
which set forth these limitations.
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CONCLUSION
111.
Based on the information described above, I have probable cause to believe that
that each of the Targets have violated 18 U.S.C. §§ 1349 and 1956(h) in connection with the
submission of fraudulent loan applications and engagement in financial transactions with
fraudulently obtained loan proceeds.
112.
I further have probable cause to believe that evidence, fruits, and instrumentalities
of the Target Offenses, as described in Attachment B to the proposed warrant to search the Target
Email Account, are contained within the Target Email Account described in Attachment A.
Sworn to under the pains and penalties of perjury,

____________________
Than Nguyen
Special Agent
IRS, Criminal Investigation

Sworn to via telephone in accordance with Federal Rule of
Criminal Procedure 4.1 on January ____, 2023:

___________________________________________
Hon. Judith G. Dein
United States Magistrate Judge

Jan 24, 2023
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MIME−Version:1.0
From:cmecfautosender@flsd.uscourts.gov
To:flsd_cmecf_notice
Bcc:
−−Case Participants: Daniel E. Funk (caseview.ecf@usdoj.gov, daniel.funk@usdoj.gov,
gabrielle.brennan−bella@usdoj.gov, jessica.mazari2@usdoj.gov, samantha.l.geer@usdoj.gov,
usafls−brdkt@usdoj.gov, usafls−hqdkt@usdoj.gov), Magistrate Judge William Matthewman
(matthewman@flsd.uscourts.gov)
−−Non Case Participants: United States Pretrial, Probation and PSIunit Office (Court Desk)
(flsp_cd@flsp.uscourts.gov)
−−No Notice Sent:
Message−Id:22923038@flsd.uscourts.gov
Subject:Activity in Case 9:23−mj−08043−WM USA v. Alexandre Notice of Hearing
Content−Type: text/html
U.S. District Court
Southern District of Florida
Notice of Electronic Filing
The following transaction was entered on 1/25/2023 at 12:59 PM EST and filed on 1/25/2023
Case Name:
USA v. Alexandre
Case Number:
9:23−mj−08043−WM
Filer:
Document Number: 2(No document attached)
Docket Text:
NOTICE OF HEARING as to Gardy Alexandre Initial Appearance − Rule 5(c)(3)/40 set for
1/26/2023 at 10:00 AM in West Palm Beach Division before WPB Duty Magistrate Judge. (swr)
9:23−mj−08043−WM−1 Notice has been electronically mailed to:
Daniel E. Funk &nbsp &nbsp daniel.funk@usdoj.gov, CaseView.ECF@usdoj.gov,
Gabrielle.Brennan−bella@usdoj.gov, Jessica.Mazari2@usdoj.gov, Samantha.l.geer@usdoj.gov,
USAFLS−BRDKT@usdoj.gov, usafls−hqdkt@usdoj.gov
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provided by other means. For further assistance, please contact our Help Desk at 1−888−318−2260.:
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From:cmecfautosender@flsd.uscourts.gov
To:flsd_cmecf_notice
Bcc:
−−Case Participants: Edward Donald Reagan (edward.d.reagan@gmail.com, joelle@edrpa.com),
Daniel E. Funk (caseview.ecf@usdoj.gov, daniel.funk@usdoj.gov,
gabrielle.brennan−bella@usdoj.gov, jessica.mazari2@usdoj.gov, samantha.l.geer@usdoj.gov,
usafls−brdkt@usdoj.gov, usafls−hqdkt@usdoj.gov), Magistrate Judge William Matthewman
(matthewman@flsd.uscourts.gov)
−−Non Case Participants: Federal Public Defender (fls_ecf@fd.org)
−−No Notice Sent:
Message−Id:22928026@flsd.uscourts.gov
Subject:Activity in Case 9:23−mj−08043−WM USA v. Alexandre Initial Appearance − Rule
5(c)(3)/Rule 40
Content−Type: text/html
U.S. District Court
Southern District of Florida
Notice of Electronic Filing
The following transaction was entered on 1/26/2023 at 2:58 PM EST and filed on 1/26/2023
Case Name:
USA v. Alexandre
Case Number:
9:23−mj−08043−WM
Filer:
Document Number: 4(No document attached)
Docket Text:
PAPERLESS Minute Order for proceedings held before Magistrate Judge William
Matthewman: Initial Appearance in Rule 5(c)(3)/Rule 40 Proceedings as to Gardy Alexandre
held on 1/26/2023. Defendant present and sworn. Temporary Notice of Appearance filed. The
Court advised the defendant of the charges, possible maximum penalties, and his rights. The
Court questioned the defendant. The defendant waived removal, form executed and the
Court found the waiver knowing and voluntary. Government requested $150,000 PSB.
Defense agreed. Bond recommendation/set: Gardy Alexandre (1) $150,000 PSB. Court
Ordered Defendant removed. Date of Arrest or Surrender: 1/26/2023. Total time in court: 25
minutes. Attorney Appearance(s): Daniel E. Funk, Edward Donald Reagan, (Digital 11:04:13)
Signed by Magistrate Judge William Matthewman on 1/26/2023. (swr)
9:23−mj−08043−WM−1 Notice has been electronically mailed to:
Daniel E. Funk &nbsp &nbsp daniel.funk@usdoj.gov, CaseView.ECF@usdoj.gov,
Gabrielle.Brennan−bella@usdoj.gov, Jessica.Mazari2@usdoj.gov, Samantha.l.geer@usdoj.gov,
USAFLS−BRDKT@usdoj.gov, usafls−hqdkt@usdoj.gov
Edward Donald Reagan &nbsp &nbsp edward.d.reagan@gmail.com, joelle@edrpa.com
9:23−mj−08043−WM−1 Notice has not been delivered electronically to those listed below and will be
provided by other means. For further assistance, please contact our Help Desk at 1−888−318−2260.:
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Rule 5(c)(3) Documents Received as to Gardy Alexandre — USA v. Pierre et al. (Dkt. 11, D. Mass.)

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