Superseding Indictment — No. 3:24-cr-50011 (Dkt. 39, N.D. Ill.)

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A superseding indictment returned by the Special March 2024 Grand Jury and filed February 11, 2025 in United States v. Absalom Hall, a.k.a. "Andrew Hall," "Alex Carter" and "Jordan Thomas," No. 24 CR 50011, in the U.S. District Court for the Northern District of Illinois, Western Division. Counts One through Five allege a scheme in which Hall and others submitted approximately five PPP loan applications for purported sole proprietorships in the names Absalom Hall, Andrew Hall, Alex Carter and Jordan Thomas to obtain approximately $85,401. Count Six charges that on or about June 27, 2022 Hall willfully aided in the preparation of a false return under Title 26, Section 7206(2). The indictment also cites Title 18, Section 1957 and seeks forfeiture, including substitute property.

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Case: 3:24-cr-50011 Document #: 39 Filed: 02/11/25 Page 1 of 18 PagelD #:94

FILED

UNITED STATES DISTRICT COURT FEB 11 2025
NORTHERN DISTRICT OF ILLINOIS THOMAS G
. BRUTON
WESTERN DIVISION CLERK, U.S. DISTRICT COURT
UNITED STATES OF AMERICA
No. 24 CR 50011
V.
Violations: Title 18, United States
ABSALOM HALL, Code, Sections 1348, Title 26,
a.k.a “Andrew Hall,” “Alex Carter,” United States Code, Section
“Jordan Thomas” 7206(2), and Title 18, United States
Code, Section 1957
SUPERSEDING INDICTMENT

COUNTS ONE THROUGH FIVE

The SPECIAL MARCH 2024 GRAND JURY charges that:
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
applicant 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 business, sole
proprietorship, or self-employed individual 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 business, sole
proprietorship, or self-employed individual 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,

income, operating expenses, and how the PPP loan would be used, which information

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was material to (i) lenders’ approval, terms, and funding of loans and (ii) the SBA’s
decision to guarantee and to forgive the loans.
Lenders
i, Lender A and Lender B were third-party lenders that processed
PPP applications and funded PPP loans to approved borrowers. Lender A and Lender
B maintained computer servers that were located outside of Illinois.
The Scheme to Defraud

2. Beginning in or around June 2020 and continuing through in or around

June 2021, in the Northern District of Illinois, and elsewhere,

ABSALOM HALL,
a.k.a “Andrew Hall,” “Alex Carter,” “Jordan Thomas”

defendant herein, together with others known and unknown to the Grand Jury,
knowingly devised, intended to devise, and participated in a scheme to defraud, and
to obtain money and property, in connection with applications for PPP funds, by
means of materially false and fraudulent pretenses, representations, and promises,
as further described below.

3. It was part of the scheme that ABSALOM HALL and others, for the
purpose of fraudulently obtaining approximately $85,401 in PPP funds, submitted
approximately five applications for loans under the PPP Program on behalf of
purported sole proprietorships doing business under the names Absalom Hall,

Andrew Hall, Alex Carter, and Jordan Thomas (together, the “Fictitious

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Proprietorships”); which applications contained materially false statements and
misrepresentations concerning, among other things, the purported entities’ owner,
gross income, type of business, payroll, operating expenses, and existence as entities
with ongoing operations.

4. It was further part of the scheme that ABSALOM HALL, and others,
prepared PPP loan applications that were submitted to Lenders A and B (together,
the “Lenders”), on behalf of the Fictitious Proprietorships, in which applications the
defendant falsely and fraudulently represented that each Fictitious Entity was a sole
proprietorship that was owned by him or a fictitious person, had earned income in
2020, and was in operation on February 15, 2020, and that all PPP loan proceeds
would be used only for business related purposes. HALL knew at the time that the
Fictitious Proprietorships were not ongoing operations, that neither he nor any of the
fictitious persons identified in the applications owned or operated the Fictitious
Proprietorships, that the Fictitious Proprietorships had no income and were not in
operation on February 15, 2020, and that he intended to use the loan funds for his
personal use and benefit.

5. It was further part of the scheme that, to substantiate the claimed loss
of income, ABSALOM HALL, and others, prepared, and submitted to the Lenders,
copies of false IRS tax filings Gncluding IRS Forms 1040 Schedule C) that
fraudulently represented that the Fictitious Proprietorships had earned income and

other compensation in tax years 2019. Defendant knew at the time that the Fictitious

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Proprietorships had earned no income or other compensation for which federal taxes
were paid during that period.

6. It was further part of the scheme that ABSALOM HALL, and others,
opened bank accounts and credit cards in the names of several of the fictitious owners
of the Fictitious Proprietorships, including “Andrew Hall”, “Alex Carter” and “Jordan
Thomas’; and directed the Lenders to deposit the proceeds of fraudulently obtained
PPP loans into those bank accounts, as well as his own bank accounts, all of which
defendant controlled. Defendant opened these accounts in the names of those
fictitious persons to induce the SBA, the Lenders, and others to falsely believe that
the accounts belonged to legitimate and operational sole proprietorships.

7. It was further part of the scheme that, through the submission of the
false and fraudulent PPP loan applications, ABSALOM HALL, and others, caused
the Lenders to disburse approximately $85,401 in PPP loan proceeds into bank
accounts that he controlled.

8. It was further part of the scheme that ABSALOM HALL, and others,
used the PPP funds that the Lenders disbursed based on the fraudulent PPP
applications to make cash withdrawals, to purchase goods and services, to purchase
a vehicle and a house, and to transfer funds between various accounts that he
controlled, all for his personal use and benefit.

9. It was further part of the scheme that ABSALOM HALL, and others,

misrepresented, concealed, and hid, and caused to be misrepresented, concealed, and

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hidden, the existence and purpose of the scheme and the acts done in furtherance of

the scheme.

10.

On or about the dates set forth below, in the Northern District of Illinois,

Western Division, and elsewhere, defendant, as set forth below, for the purpose of

executing the above-described scheme, knowingly caused to be transmitted by means

of wire communication in interstate commerce certain writings, signs, and signals,

listed below, each such writing, sign, and signal constituting a separate count:

a.k.a. “Jordan
Thomas”

Count |. Defendant "|... Date." |... Description. of Act.
One ABSALOM HALL | March 10, | an internet transmission of a PPP
2021 loan application on behalf of
“Absalom Hall,” to Lender A’s
computer servers located outside
of Illinois
Two ABSALOM HALL, | March 22, | an internet transmission of a PPP
a.k.a “Andrew 2021 loan application on behalf of
Hall” “Andrew Hall,” to Lender B’s
computer servers located outside
of Illinois
Three ABSALOM HALL | March 25, | an internet transmission of a PPP
a.k.a “Alex Carter” | 2021 loan application on behalf of “Alex
Carter,” to Lender B’s computer
servers located outside of Illinois
Four ABSALOM HALL | March 31,| an internet transmission of a
2021 second draw PPP loan application
on behalf of “Absalom Hall,” to
Lender A’s computer servers
located outside of Illinois
Five ABSALOM HALL, | April 9, 2021 | an internet transmission of a PPP

loan application on behalf of
“Jordan Thomas,” to Lender B’s

computer servers located outside
of Illinois

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

7


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COUNT SIX

The SPECIAL MARCH 2024 GRAND JURY further charges:

On or about June 27, 2022, in the Northern District of Illinois, Western
Division, and elsewhere,

ABSALOM HALL,

defendant herein, willfully aided and assisted in, and procured, counseled, and
advised, the preparation and presentation to the IRS of an individual return and
claim on behalf of Taxpayer T.S., namely, a U.S. Individual Income Tax Return, Form
1040, for tax year 2021. The return was false and fraudulent as to material matters
including that: (a) Taxpayer T.S. did not qualify for education credits in 2021 in the
amount of $1,000 on line 8 of Form 8863; (b) Taxpayer T.S. did not qualify for
qualified sick and family leave credits totaling $29,080 in 2021 on lines 13b and 13h
of Schedule 3; (c) Taxpayer T.S. did not operate a business in 2021 as listed on
Schedule C and did not earn a net profit of $7,452 on line 31; and (d) Taxpayer T.S.
did not overpay $30,087 as listed on line 34 of Form 1040; when as defendant HALL
knew at the time, these statements were false;

In violation of Title 26, United States Code, Section 7206(2).

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COUNT SEVEN
The SPECIAL MARCH 2024 GRAND JURY further charges:
On or about June 28, 2022, in the Northern District of Illinois, Western
Division, and elsewhere,
ABSALOM HALL,
defendant herein, willfully aided and assisted in, and procured, counseled, and
advised, the preparation and presentation to the IRS of an individual return and
claim on behalf of Taxpayer H.H., namely, a U.S. Individual Income Tax Return,
Form 1040, for tax year 2021. The return was false and fraudulent as to material
‘matters including that: (a) Taxpayer H.H. did not qualify for qualified sick and family
leave credits totaling $29,680 in 2021 on lines 13b and 13h of Schedule 3; (b) Taxpayer
H.H. did not operate a business in 2021 as listed on Schedule C and did not earn a
net profit of $5,776 on line 31; and (c) Taxpayer H.H. did not overpay $29,686 as listed
on line 34 of Form 1040; when as defendant HALL knew at the time, these statements
were false;

In violation of Title 26, United States Code, Section 7206(2).

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COUNT EIGHT
The SPECIAL MARCH 2024 GRAND JURY further charges:
On or about July 20, 2022, in the Northern District of [linois, Western
Division, and elsewhere,
ABSALOM HALL,
defendant herein, willfully aided and assisted in, and procured, counseled, and
advised, the preparation and presentation to the IRS of an individual return and
claim on behalf of Taxpayer A.S., namely, a U.S. Individual Income Tax Return, Form
1040, for tax year 2021. The return was false and fraudulent as to material matters
including that: (a) Taxpayer A.S. did not qualify for qualified sick and family leave
credits totaling $30,040 in 2021 on lines 13b and 13h of Schedule 3; (b) Taxpayer A.S.
did not operate a business in 2021 as listed on Schedule C and did not earn a net
profit of $3,160 on line 31; and (c) Taxpayer A.S. did not overpay $28,115 as listed on
line 34 of Form 1040; when as defendant HALL knew at the time, these statements
were false; .

In violation of Title 26, United States Code, Section 7206(2).

10 ©

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COUNT NINE

The SPECIAL MARCH 2024 GRAND JURY further charges:

On or about August 4, 2022, in the Northern District of Illinois, Western
Division, and elsewhere,

ABSALOM HALL,

defendant herein, willfully aided and assisted in, and procured, counseled, and
advised, the preparation and presentation to the IRS of an individual return and
claim on behalf of Taxpayer C.S., namely, a U.S. Individual Income Tax Return, Form
1040, for tax year 2021. The return was false and fraudulent as to material matters
including that: (a) Taxpayer C.S. did not qualify for education credits in 2021 in the
amount of $1,000 on line 8 of Form 8863; (b) Taxpayer C.S. did not qualify for
qualified sick and family leave credits totaling $29,000 in 2021 on lines 13b and 13h
of Schedule 3; (c) Taxpayer C.S. did not operate a business in 2021 as listed on
Schedule C and did not earn a net profit of $5,187 on line 31; and (d) Taxpayer C.S.
did not overpay $30,005 as listed on line 34 of Form 1040; when as defendant HALL
knew at the time, these statements were false;

In violation of Title 26, United States Code, Section 7206(2).

11

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COUNT TEN

The SPECIAL MARCH 2024 GRAND JURY further charges:

On or about July 15, 2022, in the Northern District of Illinois, Western
Division, and elsewhere,

ABSALOM HALL,

defendant herein, willfully aided and assisted in, and procured, counseled, and
advised, the preparation and presentation to the IRS of an individual return and
claim on behalf of Taxpayer H.S., namely, a U.S. Individual Income Tax Return, Form
1040, for tax year 2021. The return was false and fraudulent as to material matters
including that: (a) Taxpayer H.S. did not qualify for qualified sick and family leave
credits totaling $20,010 in 2021 on lines 13b and 13h of Schedule 3; (b) Taxpayer H.S.
did not operate a “Mechanic” business in 2021 as listed on Schedule C and did not
earn a net profit of $4,554 on line 31; and (c) Taxpayer H.S. did not overpay $20,012
as listed on line 34 of Form 1040: when as defendant HALL knew at the time, these
statements were false;

In violation of Title 26, United States Code, Section 7206(2).

12

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COUNT ELEVEN
The SPECIAL MARCH 2024 GRAND JURY further charges:
On or about April 15, 2023, in the Northern District of Illinois, Western
Division, and elsewhere,
ABSALOM HALL,
defendant herein, willfully aided and assisted in, and procured, counseled, and
advised, the preparation and presentation to the IRS of an individual return and
claim on behalf of Taxpayer S.M., namely, a U.S. Individual Income Tax Return,
Form 1040, for tax year 2022. The return was false and fraudulent as to material
matters including that: (a) Taxpayer S.M. did not qualify for education credits in 2022
in the amount of $1,000 on line 8 of Form 8863; (b) Taxpayer S.M. did not qualify for
fuel tax credits of $29,866 in 2022 on line 17 of Form 4136; and (c) Taxpayer S.M. did
not overpay $30,558 as listed on line 34 of Form 1040; when as defendant HALL knew
at the time, these statements were false;

In violation of Title 26, United States Code, Section 7206(2).

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COUNT TWELVE
The SPECIAL MARCH 2024 GRAND JURY further charges:
On or about April 15, 2023, in the Northern District of Illinois, Western
Division, and elsewhere,
ABSALOM HALL,
defendant herein, willfully aided and assisted in, and procured, counseled, and
advised, the preparation and presentation to the IRS of an individual return and
claim on behalf of Taxpayer A.S., namely, a U.S. Individual Income Tax Return, Form
1040, for tax year 2022. The return was false and fraudulent as to material matters
including that: (a) Taxpayer A.S. did not qualify for education credits in 2021 in the
amount of $1,000 on line 8 of Form 8863; (b) Taxpayer A.S. did not operate a business
in 2022 as listed on Schedule C and did not incur a loss of $7,750 on line 31; and (c)
Taxpayer A.S. did not over pay $1,825 as listed on line 34 of Form 1040; when as
defendant HALL knew at the time, these statements were false;

In violation of Title 26, United States Code, Section 7206(2).

14

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COUNT THIRTEEN
The SPECIAL MARCH 2024 GRAND JURY further charges:
On or about June 1, 2021, in the Northern District of Illinois, Western Division,

and elsewhere,

ABSALOM HALL,
a.k.a “Andrew Hall,” “Alex Carter,” “Jordan Thomas”

defendant herein, did knowingly engage in a monetary transaction, in and affecting
interstate and foreign commerce, in criminally derived property of a value greater
than $10,000, that is the payment of approximately $23,060, via wire transfer, to
Rosen Hyundai in Algonquin, Illinois, for the purchase of a 2021 Hyundai Venue SEL,
hatchback, bearing VIN: KMHRC8A36MU082221, such property having been
derived from a specified unlawful activity, namely, wire fraud;

In violation of Title 18, United States Code, Section 1957.

15

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COUNT FOURTEEN
The SPECIAL MARCH 2024 GRAND JURY further charges:
On or about June 28, 2021, at Rockford, in the Northern District of Illinois,

Western Division, and elsewhere,

ABSALOM HALL,
a.k.a “Andrew Hall,” “Alex Carter,” “Jordan Thomas”

defendant herein, did knowingly engage in a monetary transaction, in and affecting
interstate and foreign commerce, in criminally derived property of a value greater
than $10,000, that is the payment of approximately $34,200 to FAV Investments in
Rockford, for the purchase of a residence located at 323 Alliance Avenue in Rockford,
such property having been derived from a specified unlawful activity, namely, wire
fraud;

In violation of Title 18, United States Code, Section 1957.

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FORFEITURE ALLEGATION

The SPECIAL MARCH 2024 GRAND JURY further alleges:

1. Upon conviction of an offense in violation of Title 18, United States Code,
Sections 1343, as set forth in this Indictment, defendant 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 any property involved in such offense, and any property traceable
to such property, as provided in Title 18, United States Code, Section 982(a)(1).

2. The property to be forfeited includes, but is not limited to:

a. a personal money judgment in an amount equal to the proceeds
derived from the offenses in violation of Title 18, United States Code, Section 1348,
estimated to be approximately $85,401.

b. A 2021 Hyundai Venue SEL, hatchback, bearing VIN:
KMHRC8A36MU082221; and

c. real property located at 323 Alliance Avenue, Rockford, Illinois.

3. If any of the property described above, as a result of any act or omission
by a 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 U

Mo Karun’ y fab hi

ACTING UNITED STATES ATTORNEY

18

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