Indictment — United States v. Artisha Martin (Blueacorn PPP fraud, S.D. Tex.)

Record facts

U.S. District Court for the Southern District of Texas · No. 4:24-mj-00257 · Doc. 1 · 2024-06-11 · Docket on CourtListener

Full text

United States Courts 
Southern District of Texas 
    FILED
Nathan Ochsner, Clerk of Court 
June 11, 2024
                                           
4:24-mj-257
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agency of the United States government that provided support to entrepreneurs and small 
businesses. The mission of the SBA was to maintain and strengthen the nation’s economy 
by enabling the establishment and viability of small businesses and by assisting in the 
economic recovery of communities after disasters. 
2. 
As part of this effort, the SBA enabled and provided for loans through banks, 
credit unions, and other lenders. These loans had government backed guarantees. 
The Paycheck Protection Program (PPP) 
3. 
The Coronavirus Aid, Relief, and Economic Security Act, (“CARES” Act), 
was a federal law enacted in March 2020 and designed to provide emergency financial 
relief to the millions of Americans who were suffering the economic effects caused by 
the COVID-19 pandemic.  One source of relief provided by the CARES Act was the 
authorization of up to $349 billion in forgivable loans to small businesses payroll, 
mortgage interest, rent/lease and utilities, through a program referred to as the Paycheck 
Protection Program (“PPP”).  In April 2020, Congress authorized up to $310 billion in 
additional PPP funding. 
4. 
The PPP allowed qualifying small businesses and other organizations to 
receive PPP loans. Businesses must use PPP loan proceeds for 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 expense items 
within a designated period of time and used a certain percentage of the PPP loan proceeds 
for payroll expenses. 
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5. 
The amount of PPP loan proceeds that a small business may have been 
entitled to receive was determined by the number of employees employed by the business 
and the business’ average monthly payroll costs.  
6. 
The PPP was overseen by the SBA, which had authority over all such 
loans.  Individual PPP loans, however, were issued by private approved lenders (most 
commonly, banks and credit unions), who received and processed SBA Form 2483 (PPP 
loan application) and supporting documentation, and then made loans using the lenders’ 
own funds.   
7. 
To obtain a PPP loan, a qualifying business was required to submit a PPP 
loan application, which was 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 order to be 
eligible to obtain the PPP loan.  In the PPP loan application, the small business (through 
its authorized representative) was required to state, among other things, its: (a) average 
monthly payroll expenses; and (b) number of employees.  These figures were used to 
calculate the amount of money the small business was eligible to receive under the PPP.  
In addition, businesses applying for a PPP loan were required to provide documentation 
showing their payroll expenses.   
8. 
Small businesses and sole proprietorships applied for PPP relief through 
one of over 4,900 SBA designated lending institutions.  To apply, applicants must 
complete and transmit to the lender a PPP loan application, which required the applicant 
to identify the entity’s average monthly payroll, as calculated according to the 
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requirements of the CARES Act.  The PPP loan application also required the applicant to 
certify that: “The Applicant was in operation on February 15, 2020 and had employees 
for whom it paid salaries and payroll taxes or paid independent contractors,” that 
“[c]urrent economic uncertainty makes the loan request necessary to support the ongoing 
operations of the Applicant” and that “[t]he funds would be used to retain workers and 
maintain payroll or make mortgage interest payments, lease payments, and utility 
payments, as specified under the Paycheck Protection Program Rule.” 
9. 
An applicant can submit a PPP loan application directly to an SBA 
approved lender such as a bank or to an SBA intermediary company that reviews the PPP 
loan application and then partners with a bank to fund the loan.  The loan application is 
also transmitted to the SBA via an electronic platform known as ETRAN.  Before 
submitting a PPP loan application through ETRAN, the lender or intermediary company 
must have collected the information and certifications set forth in the PPP loan 
application.  Loans guaranteed under the PPP were 100% guaranteed by the SBA, and the 
full principal amount of the loans may qualify for loan forgiveness if the applicant 
certified that the funds were used as prescribed by the CARES Act. 
10. 
The PPP loan application contained information as to the purpose of the 
loan, average monthly payroll, number of employees, and background of the business and 
its owner.  Applicants were also required to make certain good faith certifications, 
including that economic uncertainty had necessitated their loan request for continued 
business operations, and that they intended to use loan proceeds only for the authorized 
purposes. 
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Social Media Platform 
Artisha Gabriella Dimetrika Martin, aka Rikkita Jones, aka Gabby Martin,  
aka ArtyMar (Martin) utilized the social media platform Instragram to recruit applicants 
to submit fraudulent PPP loan applications. Instragram is a photo and video sharing social 
networking service owned and operated by American company Meta Platform, 
headquartered at 200 Jefferson Dr., Menlo Park, California. 
Loan Application Intermediary 
11. 
Bizz2Credit was a PPP loan application intermediary between the SBA and 
PPP loan applicants during the COVID-19 pandemic.  
12. 
Blueacorn was a PPP loan application intermediary between the SBA and 
PPP loan applicants during the COVID-19 pandemic. 
13. 
WOMPLY was a PPP loan application intermediary between the SBA and 
PPP loan applicants during the COVID-19 pandemic. 
Financial Services Company 
14. 
Itria Ventures LLC (Itria) was a financial services company doing business 
out of New York City, New York, that among other services assisted businesses in 
accessing SBA PPP loans.  
15. 
Prestamos Community Development Financial Institution (Prestamos) was 
a financial services company headquartered in Phoenix, Arizona, that among other 
services assisted businesses in accessing SBA PPP loans.  
16. 
Capital Plus, (Capital Plus) was a financial services company headquartered 
in Bedford, Texas, that among other services assisted in accessing SBA PPP loans. 
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17. 
The Enterprise Center Capital Corp. (Enterprise Capital) was a financial 
services company headquartered in Philadelphia, Pennsylvania, that among other services 
assisted in accessing SBA PPP loans. 
18. 
Amur Equipment Finance, Inc. (Amur) was a financial services company 
headquartered in Grand Island, Nebraska, that among other services assisted in accessing 
SBA PPP loans. 
19. 
Customers Bank was a financial services company headquartered in 
Malvern, Pennsylvania, that among other services assisted in accessing SBA PPP loans. 
20. 
Benworth Capital Partners, LLC (Benworth) was a financial services 
company headquartered in Cora Gables, Florida, that among other services assisted in 
accessing SBA PPP loans. 
21. 
Kabbage, Inc. (Kabbage) was a financial services company headquartered 
in Atlanta, Georgia, that among other services assisted in accessing SBA PPP loans. 
Financial Institutions 
22. 
Bank of America (BOA) was a “financial institution,” as defined by 18 
U.S.C. §§ 20 and 1956.  It was based in Charlotte, North Carolina. 
23. 
Wells Fargo (WF) was a “financial institution,” as defined by 18 U.S.C. §§ 
20 and 1956.  It was based in San Francisco, California. 
24. 
Navy Federal Credit Union (NFCU) was a “financial institution,” as 
defined by 18 U.S.C. §§ 20 and 1956. It was based in Vienna, Virginia. 
25. 
Smart Financial Credit Union (SFCU) was a “financial institution,” as 
defined by 18 U.S.C. §§ 20 and 1956. It was based in Houston, Texas.  
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26. 
Chime Financial, Inc. (CFI) was an American financial technology 
company that provides fee-free mobile banking services that are provided by The 
Bancorp Bank or Stride Bank, N.A. It was based in San Francisco, California. 
27. 
Houston Texas Fire Fighters Federal Credit Union (HTFFFCU) was a 
“financial institution,” as defined by 18 U.S.C. §§ 20 and 1956. It was based in Houston, 
Texas.  
28. 
Regions Bank (RB) was a “financial institution,” as defined by 18 U.S.C. 
§§ 20 and 1956. It was based in Birmingham, Alabama. 
29. 
Capital One Bank (COB) was a “financial institution,” as defined by 18 
U.S.C. §§ 20 and 1956. It was based in Denver, Colorado. 
30. 
Essential Federal Credit Union (EFCU) was a “financial institution,” as 
defined by 18 U.S.C. §§ 20 and 1956. It was based in Baton Rouge, Louisiana.  
31. 
Campus Federal Credit Union (CFCU) was a “financial institution,” as 
defined by 18 U.S.C. §§ 20 and 1956. It was based in Baton Rouge, Louisiana. 
32. 
Pelican State Credit Union (PSCU) was a “financial institution,” as defined 
by 18 U.S.C. §§ 20 and 1956. It was based in Baton Rouge, Louisiana. 
33. 
JP Morgan Chase Bank (JPMCB) was a “financial institution,” as defined 
by 18 U.S.C. §§ 20 and 1956. It was based in New York City, New York. 
34. 
Neighbors Federal Credit Union (Neighbors FCU) was a “financial 
institution,” as defined by 18 U.S.C. §§ 20 and 1956. It was based in Baton Ridge, 
Louisiana.  
 
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Digital Payment Network 
35. 
ZELLE was a United States based digital payment network owned by Early 
Warning Services, LLC, a private financial services company owned by Bank of 
America, Truist, Capital One, JPMorgan Chase, PNC Bank, U.S. Bank, and Wells Fargo. 
36. 
Cash App was a mobile payment service available in the United States and 
the United Kingdom that allows individuals to transfer money to one another using a 
mobile app.  
37. 
Apple Pay was a mobile payment service by Apple Inc. that allows users to 
make payments in person, in iOS apps, and on the web. 
38. 
PayPal was a United States multinational financial technology company 
operating an online payment system in the majority of countries that support online 
money transfers and serves as an electronic alternative to traditional paper methods such 
as checks and money orders.   
39. 
Beginning in or about sometime in February 2021, the conspirators reached 
an agreement to fraudulently transmit fraudulent PPP loan applications. The conspirators 
filed PPP loan applications knowing that the information provided on the PPP loan 
applications regarding the financial records and the Profit or Loss from Business 
Schedule C for tax year 2019 (Schedule C) was fraudulent. The conspirators knew that 
the recruited applicants did not otherwise qualify for PPP funds as intended under the 
CARES Act. 
 
 
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COUNT ONE 
 
Violation:  18 U.S.C. § 1349 
(Conspiracy to Commit Wire 
Fraud) 
 
  40. 
The General Allegations section (Paragraphs 1-39 herein) of this indictment  
is realleged and incorporated by reference as though fully set forth herein. 
 
41. 
Beginning in or about a date unknown, but as early as January 2021, and 
continuing through in or about February 2022, the exact dates being unknown to the Grand 
Jury, in the Eastern District of Texas, and elsewhere, the defendants, Artisha Gabriella 
Dimetrika Martin, aka Rikkita Jones, aka Gabby Martin, aka ArtyMar (Martin)(1), 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 along with others, 
both known and unknown to the Grand Jury, did knowingly and willfully combine, 
conspire, confederate, and agree to violate 18 U.S.C. § 1343, wire fraud, that is defendants 
knowingly devised a scheme to defraud by transmitting and causing to be transmitted 
fraudulent PPP loan applications which employed false material pretenses, false material 
representations and false material promises which defendants transmitted and caused to be 
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transmitted by way of wire communication in interstate commerce any writing, signs, 
signal, picture, or sound for the purposes of executing the scheme. The defendants acted 
with a specific intent to defraud the SBA and lending institutions to obtain money and 
property.  
Overview of the Conspiracy 
 
42. 
From in or about January 2021, and continuing through in or about 
February 2022, in the Eastern District of Texas and elsewhere, Martin, 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 entered into an agreement to 
commit wire fraud, that is, devised and intended to devise a scheme and artifice to 
defraud and to unlawfully obtain money and property by means of false and fraudulent 
material pretenses, false and fraudulent material representations, and false and fraudulent 
material promises, defendants knew the unlawful purpose of the agreement, and the 
defendants joined in the agreement with the intent to further the unlawful purpose of the 
agreement. 
Role of the Conspirators 
 
43. 
Martin executed a scheme to defraud the loan application intermediary, the 
SBA, and financial institutions that would finance an applicant’s PPP loan. Martin 
utilized conspirators to recruit applicants that would submit fraudulent PPP loan 
applications to obtain PPP funds that the applicants would otherwise not qualify to 
receive. Martin would receive between $2,000.00 and $4,000.00 for each fraudulent PPP 
loan application that was approved. The recruiter or the applicant would pay Martin 
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between $45.00 and $80.00 to create either the fraudulent financial records or the 
fraudulent Schedule Cs or the applicant would pay Martin directly. Martin would in 
turn pay the fraudulent document creators between $45.00 and $80.00 to create 
fraudulent financial records. Martin was responsible for the submission of over 100 
fraudulent loan applications and a loss of over $2,400,000.00.  
Fraudulent Document Creators 
 
44. 
 
 
 generated fraudulent financial records and 
fraudulent Schedule C forms utilizing online programs that allowed them to generate 
fraudulent financial documents. 
 
 
 received between $45.00 and 
$80.00 for each fraudulent financial document created. 
Recruiters  
  
45.  
 
 recruited approximately twenty-four applicants and conspired to 
transmit twenty-five fraudulent PPP loan applications for approval. 
 
 provided 
Martin with the necessary personal identifying information of the applicant required to 
apply for the PPP loan application. 
 
 also provided Martin with the applicant’s 
financial records so a fraudulent document creator could falsify the financial records to 
demonstrate that the applicant had business deposits that would qualify the applicant for a 
PPP loan. 
 
 either paid for Martin’s fee on behalf of the applicant or 
 
 provided the applicant with Martin’s Zelle, Cash App, Venmo, Apple Pay, and 
Pay Pal account for the applicant to pay Martin directly.  
 
46. 
 recruited approximately three applicants and conspired to 
transmit four fraudulent PPP loan applications for approval. 
 provided Martin 
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with the necessary personal identifying information of the applicant required to apply for 
the PPP loan application. 
 also provided Martin with the applicant’s financial 
records so a fraudulent document creator could falsify the bank records to demonstrate 
that the applicant had business deposits that would qualify the applicant for a PPP loan. 
 either paid for Martin’s fee on behalf of the applicant or 
 provided 
the applicant with Martin’s Zelle, Cash App, Venmo, Apple Pay, and Pay Pal account 
for the applicant to pay Martin directly.  
 
47. 
 recruited approximately three applicants and conspired to transmit 
four fraudulent PPP loan applications for approval. 
 provided Martin with the 
necessary personal identifying information of the applicant required to apply for the PPP 
loan application. 
 also provided Martin with the applicant’s financial records so a 
fraudulent document creator could falsify the bank records to demonstrate that the 
applicant had business deposits that would qualify the applicant for a PPP loan. 
 
either paid for Martin’s fee on behalf of the applicant or 
 provided the applicant 
with Martin’s Zelle, Cash App, Venmo, Apple Pay, and Pay Pal account for the 
applicant to pay Martin directly.  
 
48. 
 recruited approximately four applicants and conspired to transmit two 
fraudulent PPP loan applications for approval. 
 coordinated communication between 
the recruited applicants and Martin. 
 instructed the recruited applicants to forward 
personal identifying information to Martin to facilitate approval of their PPP loans.  
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49. 
 
 recruited two applicants and conspired to transmit two 
fraudulent PPP loan applications for approval.  
 coordinated communication 
between the recruited applicants and Martin. 
 
50. 
 recruited approximately four applicants and conspired to 
transmit five fraudulent PPP loan applications for approval. 
 provided Martin 
with the necessary personal identifying information of the applicant required to apply for 
the PPP loan application. 
 also provided Martin with the applicant’s financial 
records so a fraudulent document creator could falsify the financial records to 
demonstrate that the applicant had business deposits that would qualify the applicant for a 
PPP loan. 
 either paid for Martin’s fee on behalf of the applicant or 
 provided the applicant with Martin’s Zelle, Cash App, Venmo, Apple Pay, 
and Pay Pal account for the applicant to pay Martin directly. 
 
51.  
 recruited one applicant and conspired to transmit four fraudulent 
PPP loan applications for approval. 
 provided Martin with the necessary 
personal identifying information of the applicant required to apply for the PPP loan 
application. 
 also provided Martin with the applicant’s financial records so a 
fraudulent document creator could falsify the financial records to demonstrate that the 
applicant had business deposits that would qualify the applicant for a PPP loan. 
 
either paid for Martin’s fee on behalf of the applicant or 
 provided the applicant 
with Martin’s Zelle, Cash App, Venmo, Apple Pay, and Pay Pal account for the 
applicant to pay Martin directly. 
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52. 
 recruited approximately three applicants and conspired to transmit 
three fraudulent PPP loan applications for approval. 
 provided Martin with the 
necessary personal identifying information of the applicant required to apply for the PPP 
loan application. 
 also provided Martin with the applicant’s financial records so a 
fraudulent document creator could falsify the financial records to demonstrate that the 
applicant had business deposits that would qualify the applicant for a PPP loan. 
 
either paid for Martin’s fee on behalf of the applicant or 
 provided the applicant 
with Martin’s Zelle, Cash App, Venmo, Apple Pay, and Pay Pal account for the 
applicant to pay Martin directly. 
 
53. 
 recruited one applicant and conspired to transmit two fraudulent PPP 
loan applications for approval. 
 coordinated communication between the recruited 
applicants and Martin. 
 provided the recruited applicant details about Martin’s 
role in obtaining approval of their PPP loan. 
 
54. 
 
 recruited one applicant and conspired to transmit two fraudulent 
PPP loan applications for approval. 
 
 coordinated communication between the 
recruited applicant and Martin. 
 
 provided the recruited applicant details about 
Martin’s role in obtaining approval of their PPP loan. 
 
55. 
On the PPP loan applications, the conspirators misrepresented or caused to 
be misrepresented fraudulent material information such as the company name, IRS 
documents, business financial records, the true nature of their business, the number of 
employees, the date the business was established, and the amount of payroll.  Based on 
these fraudulent material misrepresentations, the SBA and other financial institutions 
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approved and issued loans to the conspirators and applicants. Once in receipt of the 
fraudulently obtained funds, the conspirators and applicants did not use the money as 
intended by the CARES Act, such as to pay employee salaries, cover fixed debt, utility 
payments, or continue health care benefits for employees. Instead, the conspirators and 
applicants typically paid the leaders of the scheme a kickback, transferred money to their 
personal accounts, and spent the funds on various personal expenditures.  
 
56. 
Members of the conspiracy collectively filed more than 100 fraudulent PPP 
loan applications.  In total, members of the conspiracy collectively received more than 
$2,400.000.00 in PPP funds that the conspirators and applicants would not otherwise 
qualify for pursuant to the requirements of the CARES Act. 
Purpose of the Conspiracy 
 
 
57. 
It was the general purpose of the conspiracy for the conspirators to 
unlawfully and unjustly enrich themselves by means of materially false and fraudulent 
material pretenses, representations, and promises, by among other things: (a) submitting 
and causing the submission of false and fraudulent PPP loan applications to obtain funds 
made available through the CARES Act to provide relief for the economic effects caused 
by the COVID-19 pandemic; (b) offering, paying, and receiving kickbacks in return for the 
submission of false and fraudulent PPP loan applications; and (c) diverting fraud proceeds 
for the personal use of the conspirators, the use and benefit of others, and to further the 
conspiracy. 
 
 
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Manner and Means of the Conspiracy 
 
 
58. 
The manner and means by which the conspirators and applicants sought to 
accomplish the object and purpose of the conspiracy included, among others, the 
following: 
 
59. 
Martin promoted the fraudulent PPP loan conspiracy utilizing Instagram 
account: “artymar__” and other social media outlets to recruit applicants to submit 
fraudulent PPP loan applications. Conspirators also recruited applicants by word of 
mouth and various other media outlets. 
 
60. 
Martin informed the recruiter or applicant of the process on how to file a 
fraudulent PPP loan application and the cost to file by transmitting a text message, direct 
message, or other electronic message to the potential recruiter or applicant. The message 
normally entailed the following type of language: 
“I charge 3k out of the 20k that will be deposited. The  
process is taking 3-5 days that’s including the day for  
the bank statement, if you have an EIN that was made  
before February 2020 we can use it if not your social  
is cool as well. Once payment has been made to me I  
will explain how to get your loan forgiven. Full name  
Ss DOB I’d / front to bank Voided check/ direct deposit  
form $45 to make your bank statement.” 
 
  
61.  
Martin utilized 
 
 
 to generate fraudulent financial 
records and Schedule Cs for a fraudulent PPP loan application.   
 
62. 
The recruiters and applicants provided Martin with personal identifying 
information.  Martin provided the personal identifying information to the fake document 
creator.  This allowed the fake document creator to generate fraudulent bank records and 
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fraudulent Schedule Cs for tax year 2019. The fake document creators generated the 
fraudulent documents, that is, a fraudulent Schedule C for tax year 2019 and fraudulent 
bank records to show the applicant had a net profit that was impacted by COVID-19 
which would qualify them for a PPP loan.  
 
63. 
Martin transmitted a false and fraudulent PPP loan application, SBA Form 
2483 – Borrower Application Form, for purposes of applying for a PPP loan. 
 
64.  
The fraudulent PPP loan applications included multiple materially false and 
fraudulent pretenses, representations and promises, such as: 
a. The average monthly payroll and the number of employees; 
b. Listing that the purpose of the loan was to cover payroll costs; 
c. Listing the applicant as the owner of the business; 
d. Certifying that the funds will be used to retain workers and maintain 
payroll; and  
 
e. Certifying the truth of the statements in the loan application.  
 
65.  
The conspirators and applicants alleged to have a business or sole 
proprietorship that was impacted by COVID-19 which would qualify them for PPP funds.   
 
66. 
The conspirators had the funds from the fraudulent PPP loan transmitted 
into a financial institution that handled the applicant’s financial interest in the fraudulent 
business.   
 
67.   The conspirators and applicants would pay a portion of the PPP funds to 
Martin as a kickback for her role in obtaining the PPP funds. The conspirators 
transmitted to Martin’s bank account a kickback fee between $2,000.00 to $4,000.00 
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utilizing a digital payment network, a mobile payment service, and an online payment 
system such as Zelle, Cash App, Venmo, Apple Pay, and Pay Pal. 
 
68.  
The conspirators and applicants submitted a PPP Loan Forgiveness 
Application Form 3508S to have the PPP loan forgiven. The loan forgiveness application 
form submitted certified that the applicant complied with all the PPP requirements 
regarding the use of the PPP funds to include: 
 
 
a. 
eligible uses of PPP loan proceeds; 
 
 
b.  
the amount of PPP loan proceeds that must be used for payroll cost; 
 
 
c.  
the calculation and documentation of the borrower’s revenue   
 
 
 
reduction (if applicable); and  
 
 
 
d.  
the calculation of the borrower’s requested loan forgiveness amount  
 
 
 
and that the information provided in the PPP loan application was  
 
 
 
true and correct in all material respects.  
 
 
69. 
The conspirators and applicants transmitted wire transactions that affected 
interstate commerce by recruiting applicants using various social media outlets, and by 
requesting and receiving personal identifying information by text message, direct 
message, or email. The conspirators also affected interstate commerce by submitting PPP 
loan applications online through a portal set up by the SBA. The conspirators also 
affected interstate commerce by recruiting applicants that were located outside the State 
of Texas. The conspirators also affected interstate commerce by receiving compensation 
via a digital payment network, a mobile payment service, and an online payment system 
such as Zelle, Cash App, Venmo, Apple Pay, and Pay Pal.  
 
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Acts in Furtherance of the Conspiracy 
70. 
In furtherance of the conspiracy and to achieve its object and purpose, 
Martin conspired with 
 
 
 
 
 
 
 
 
 
 
 
 
 to submit and recruit applicants to submit fraudulent 
PPP loan applications that were committed in the Eastern District of Texas and elsewhere 
to include but not limited to the following:  
Martin’s First PPP loan application 
 
71. 
On or about February 3, 2021, Martin transmitted $45.00 to 
 
Cash App. account “$wideroff53.” The subject line on this wire included the name 
Martin’s nickname “gabby”.  This payment was the fee Martin paid 
 to 
develop the fraudulent documents for Martin’s PPP loan application.  
 
72. 
On or about February 11, 2021, Martin opened BOA account ###### 
2795.  
 
 
73. 
On or about February 17, 2021, Martin provided 
 with Martin’s 
business name, ARTYMAR of Fashion, address, bank account, a monthly deposit 
amount, and deposit dates to facilitate 
 fabrication of fraudulent documents. 
 generated the fraudulent documents for Martin and delivered them to 
Martin.  
 
74. 
On or about February 22, 2021, Martin, transmitted PPP loan application # 
2049488506, first draw, to the SBA for approval knowing information on the PPP loan 
application was false. PPP loan application # 2049488506 contained fraudulent bank 
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records and a fraudulent Schedule C. PPP loan application # 2049488506 caused Itria to 
transmit $20,645.00 into Martins’ BOA account number ###### 2795.  
 
75. 
On or about July 8, 2022, Martin transmitted PPP Loan Forgiveness 
Application Form 3058S for PPP loan # 2049488506. Martin certified that she complied 
with the PPP rules and that the PPP loan application is true and correct in all material 
respects.  
 
76. 
On or about July 13, 2021, Martin’s PPP loan # 2049488506 was forgiven 
by the SBA. 
MARTIN’S Second PPP loan application 
 
77. 
On or about April 16, 2021, Martin, transmitted PPP loan application # 
3294728809, second draw, to the SBA for approval knowing information on the PPP loan 
application was false. PPP loan application # 3294728809 contained and referenced 
fraudulent bank records and a fraudulent Schedule C. PPP loan application # 3294728809 
caused Itria to transmit $20,645.00 into Martin’s BOA account number ###### 2795.  
MARTIN and 
 PPP loan application 
 
78. 
On or about February 7, 2021, 
 provided his personal identifying 
information to Martin to begin the fraudulent PPP loan application for 
 
 also 
paid 
 $45.00 to fabricate fraudulent documents to submit with 
 PPP 
loan application. 
 
79. 
On or about February 15, 2021, Martin and 
, transmitted PPP loan 
application # 8733678410, first draw, to the SBA for approval knowing information on 
the PPP loan application was false. PPP loan application # 8733678410 referenced a 
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fictitious business: “Wiley Cutz”, located in Orange, Texas, (purportedly maintained by 
), fraudulent bank records and a fraudulent Schedule C. PPP loan application # 
8733678410 caused Itria to transmit $20,833.33 into 
 COB account number 
###### 2595.  
 
80. 
On or about March 3, 2021, 
 compensated Martin $2,000.00 for 
Martin’s role in filing the PPP loan application referenced in paragraph 79 above. 
 
81. 
On or about June 28, 2021, 
 transmitted PPP Loan Forgiveness 
Application Form 3058S for PPP loan # 8733678410 (“Wiley Cutz”). 
 certified he 
complied with the PPP rules and that the PPP loan application is true and correct in all 
material respects.  
 
82. 
On or about July 1, 2021, 
 PPP loan # 8733678410 was forgiven by 
the SBA. 
MARTIN, 
 
 AND APPLICANTS’ PPP LOAN APPLICATIONS 
Martin and 
 
 PPP loan applications 
 
 First PPP loan application 
 
83. 
On or about February 8, 2021, 
 
 provided her personally 
identifiable information to Martin to begin the fraudulent PPP loan application for 
 
 
 was paid $45.00 to fabricate the fraudulent documents for 
 
 PPP loan application. 
 
84. 
On or about February 15, 2021, Martin and 
 
 transmitted PPP 
loan application # 8728618409, first draw, to the SBA for approval knowing information 
on the PPP loan application was false.  PPP loan application # 8728618409 referenced a 
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Indictment – Page 22 
 
fictitious business: “Chef T gayla” (purportedly maintained by 
 
), fraudulent 
financial records and a fraudulent Schedule C. PPP loan application # 8728618409 
caused Itria to transmit $20,117.50 into 
 
 NFCU account number ###### 
0856. 
 
85. 
On or about July 19, 2021, 
 
 transmitted PPP Loan Forgiveness 
Application Form 3058S for PPP loan # 8728618409 (“Chef T gayla”). 
 
 
certified that she complied with the PPP rules and that the PPP loan application is true 
and correct in all material respects.  
 
86. 
On or about July 26, 2021, 
 
 PPP loan # 8728618409 was 
forgiven by the SBA. 
 
 Second PPP loan application 
 
87. 
On or about April 6, 2021, 
 
 transmitted $65.00 to Martin’s Cash 
App. account $4artymar. The subject line on this wire included “Gayla”.  This payment 
was the fee to develop fraudulent documents for 
 
 PPP loan application.  
 
88. 
On or about April 15, 2021, Martin and 
 
 transmitted PPP loan 
application, # 1625829001, second draw, to the SBA for approval knowing information 
on the PPP loan application was false.  PPP loan application # 1625829001 referenced a 
fictitious business: “Chef T gayla” (purportedly maintained by 
 
, fraudulent 
financial records and a fraudulent Schedule C. PPP loan application # 1625829001 
caused Prestamos to transmit $20,830.00 into 
 
 NFCU account number 
###### 4202. 
 
 
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Indictment – Page 23 
 
 
89. 
Between May 3, 2021, and May 5, 2021, 
 
 compensated Martin, 
via Zelle, $3,000.00 for Martin’s role in filing the PPP loan application referenced in 
paragraph 88. 
 
90. 
On or about October 4, 2021, 
 
 transmitted PPP Loan Forgiveness 
Application Form 3058S for PPP loan # 1625829001 (“Chef T gayla”). 
 
  
certified that 
 
 complied with the PPP rules and that the PPP loan application is 
true and correct in all material respects.  
 
91. 
On or about October 28, 2021, 
 
 PPP loan # 1625829001 was 
forgiven by the SBA. 
Martin  
 
 
 
 PPP loan applications 
 First PPP loan application 
 
92. 
On or about February 17, 2021, 
 
 provided Martin with 
 personal identity information so Martin could process 
 fraudulent 
PPP loan application.  
 
93. 
On or about February 27, 2021, Martin, 
 
, and 
 
transmitted PPP loan application # 4555768509, first draw, to the SBA for approval 
knowing information on the PPP loan application was false.  PPP loan application # 
4555768509 contained a fictitious business: Reynolds Carpet Cleaning Service 
(purportedly maintained by 
), fraudulent bank records and a fraudulent 
Schedule C. PPP loan application # 4555768509 caused Itria to transmit $20,402.00 into 
 NFCU account number ###### 0856.  
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Indictment – Page 24 
 
 
94. 
On or about March 11, 2021, 
 
 compensated Martin $3,000.00 
for Martin’s role in filing 
 PPP loan application referenced in paragraph 93 
above. 
 
95. 
On or about July 20, 2021, 
 transmitted PPP Loan Forgiveness 
Application Form 3058S for PPP loan # 4555768509 (Reynolds Carpet Cleaning 
Service).  
 certified that he complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects. 
 
96.  
On or about July 23, 2021, 
 PPP loan # 4555768509 was 
forgiven by the SBA. 
 Second PPP loan application 
 
97. 
On or about April 6, 2021, 
 
 transmitted $65.00 to Martin’s Cash 
App. account $4artymar. The subject line on this wire included “Jermaine”.   This 
payment was the fee to develop fraudulent documents for 
 PPP loan 
application. 
 
98. 
On or about May 19, 2021, Martin, 
 
 and 
 transmitted 
PPP loan application, # 9647188904, second draw, to the SBA for approval knowing 
information on the PPP loan application was false.  PPP loan application # 9647188904 
referenced a fictitious business: Reynolds Carpet Cleaning Service (purportedly 
maintained by 
, fraudulent financial records and a fraudulent Schedule C. PPP 
loan application # 9647188904 caused Enterprise Center to transmit $20,833.00 into 
 NFCU account number ###### 4202.  
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Indictment – Page 25 
 
 
99. 
On or about May 28, 2021, 
 compensated Martin $3,000.00 for 
Martin’s role in filing the PPP loan application referenced in paragraph 98. 
 
100. On or about September 17, 2021, 
 transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 9647188904 (Reynolds Carpet 
Cleaning Service). 
 certified that he complied with the PPP rules and that the 
PPP loan application is true and correct in all material respects.  
 
101. On or about September 28, 2021, 
 PPP loan # 9647188904 was 
forgiven by the SBA. 
Martin, 
 
, and Applicant E.D.W.’s PPP loan application 
 
102. On or about March 31, 2021, Martin, 
 
 and Applicant E.D.W. 
transmitted PPP loan application # 5000918703, first draw, to the SBA for approval 
knowing information on the PPP loan application was false.  PPP loan application # 
5000918703 referenced a fictitious business: “Motorcycle Mechanic”, fraudulent 
financial records, and a fraudulent Schedule C. PPP loan application # 5000918703 
caused Capital Plus to transmit $20,832.00 into Applicant E.D.W.’s HTFFFCU account 
number ###### 4141.  
 
 
103. On or about September 30, 2021, Applicant E.D.W. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 5000918703 (“Motorcycle 
Mechanic”). Applicant E.D.W. certified that Applicant E.D.W. complied with the PPP 
rules and that the PPP loan application is true and correct in all material respects. 
 
104. On or about October 5, 2021, Applicant E.D.W.’s PPP loan # 5000918703 
was forgiven by the SBA.  
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Indictment – Page 26 
 
Martin, 
 
, and Applicant A.K.B.’s PPP loan application 
 
105. On or about March 29, 2021, Martin, 
 
, and Applicant A.K.B. 
transmitted PPP loan application # 3968948704, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
3968948704 caused Capital Plus to transmit $20,832.00 into Applicant A.K.B.’s RB 
account number ###### 2639.  
 
106. On or about October 3, 2021, Applicant A.K.B. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 3968948704. Applicant A.K.B. 
certified that Applicant A.K.B. complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects. 
 
107. On or about October 6, 2021, Applicant A.K.B.’S PPP loan # 3968948704 
was forgiven by the SBA.  
Martin, 
 
, and Applicant A.D.T.’s PPP loan application 
 
108. On or about March 6, 2021, Martin, 
 
 and Applicant A.D.T. 
transmitted PPP loan application # 7060918508, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
7060918508 caused Itria to transmit $20,833.00 into Applicant A.D.T.’s BOA account 
number ###### 1391.  
Martin, 
 
, and Applicant A.S.B.’s PPP loan application 
 
109. On or about March 20, 2021, Martin, 
 
, and Applicant A.S.B 
transmitted PPP loan application, # 1061448601, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
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Indictment – Page 27 
 
1061448601, caused Itria to transmit $20,695.00 into Applicant A.S.B.’s COB account 
number ###### 3501.  
 
110. On or about August 9, 2021, A.S.B. transmitted PPP Loan Forgiveness 
Application Form 3058S for PPP loan # 1061448601. Applicant A.S.B. certified that 
Applicant A.S.B. complied with the PPP rules and that the PPP loan application is true 
and correct in all material respects.  
 
111. On or about August 12, 2021, Applicant A.S.B.’s PPP loan # 1061448601 
was forgiven by the SBA. 
Martin, 
 
, and Applicant M.K.G.’s PPP loan application 
 
112. On or about April 27, 2021, Martin, 
 
, and Applicant M.K.G. 
transmitted PPP loan application #1415818908, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
1415818908 caused Amur to transmit $20,400.00 into Applicant M.K.G.’s COB account 
number ###### 5191.  
 
113. On September 30, 2021, Applicant M.K.G. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 1415818908. Applicant M.K.G. 
certified that Applicant M.K.G. complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects.  
 
114. On October 5, 2021, Applicant M.K.G.’s PPP loan # 1415818908 was 
forgiven by the SBA. 
 
 
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Indictment – Page 28 
 
Martin, 
 
 and Applicant J.B.P.’s PPP loan application 
 
115. On or about April 2, 2021, Martin, 
 
, and Applicant J.B.P. 
transmitted PPP loan application # 6908648710, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
6908648710 caused Capital Plus to transmit $20,832.00 into Applicant J.B.P.’s Neighbors 
FCU account number ###### 8233. 
 
116. On or about May 5, 2021, Applicant J.B.P. compensated Martin $3,000.00 
for Martin’s role in filing the application referenced in paragraph 115. 
Martin, 
 
 and Applicant B.R.J.’s PPP loan application 
 
117. On or about May 10, 2021, Martin, 
 
 and Applicant B.R.J. 
transmitted PPP loan application # 4161599009, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
4161599009 caused Prestamos to transmit $20,832.00 into Applicant B.R.J.’s BOA 
account number ###### 8492.  
 
118. On or about December 1, 2021, Applicant B.R.J. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 4161599009. Applicant B.R.J. 
certified that Applicant B.R.J. complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects.  
 
119. On or about January 14, 2022, Applicant B.R.J.’s PPP loan # 4161599009 
was forgiven by the SBA. 
 
 
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Indictment – Page 29 
 
Martin, 
 
 and Applicant J.S.S.’s PPP loan application 
 
120. On or about April 2, 2021, Martin, 
 
, and Applicant J.S.S. 
transmitted PPP loan application # 7249298701, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
7249298701 caused Capital Plus to transmit $20,832.00 into Applicant J.S.S.’s COB 
account number ###### 3563.  
 
121. On September 21, 2021, Applicant J.S.S. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 7249298701. Applicant J.S.S. 
certified that Applicant J.S.S. complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects.  
 
122. On September 28, 2021, J.S.S.’s PPP loan # 7249298701was forgiven by 
the SBA. 
Martin, 
 
, and Applicant N.J.W.’s PPP loan application 
 
123. On or about May 25, 2021, Martin, 
 
, and Applicant N.J.W. 
transmitted PPP loan application # 8503208904, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
8503208904 caused Amur to transmit $20,833.00 into Applicant N.J.W.’s JPMCB 
account number ###### 9005.  
 
124. On or about July 18, 2022, Applicant N.J.W. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 8503208904. Applicant N.J.W. 
certified that Applicant N.J.W. complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects.  
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Indictment – Page 30 
 
 
125. On or about July 25, 2022, Applicant N.J.W.’s PPP loan # 8503208904 was 
forgiven by the SBA. 
Martin, 
 
, and Applicant R.S.S.’s PPP loan application 
 
126. On or about April 22, 2021, Martin, 
 
, and Applicant R.S.S. 
transmitted PPP loan application # 7107548807, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
7107548807 caused Amur to transmit $20,833.00 into Applicant R.S.S.’s RB account 
number ###### 1904.  
Martin, 
 
 and Applicant A.A.’s PPP loan application 
 
127.  On or about April 15, 2021, Martin, 
 
, and Applicant A.A. 
transmitted PPP loan application # 3223528803, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
3223528803 caused Amur to transmit $20,832.00 into Applicant A.A.’s COB account 
number ###### 7819.  
 
128. On or about October 12, 2021, Applicant A.A. transmitted and caused to be 
transmitted to PPP Loan Forgiveness Application Form 3058S for PPP loan # 
3223528803. Applicant A.A. certified that Applicant A.A. complied with the PPP rules 
and that the PPP loan application is true and correct in all material respects.  
 
129. On or about October 19, 2021, Applicant A.A.’s PPP loan # 3223528803 
was forgiven by the SBA. 
 
 
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Indictment – Page 31 
 
Martin, 
 
, and Applicant A.K.S.’s PPP loan application 
 
130. On or about April 28, 2021, Martin, 
 
 and Applicant A.K.S. 
transmitted PPP loan application # 2859038905, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
2859038905 caused Amur to transmit $20,833.00 into Applicant A.K.S.’s EFCU account 
number ###### 1595.  
 
131. On or about November 20, 2021, Applicant A.K.S. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 2859038905. Applicant A.K.S. 
certified that Applicant A.K.S. complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects. 
  
132. On or about November 30, 2021, Applicant A.K.S.’s PPP loan # 
2859038905 was forgiven by the SBA. 
Martin, 
 
, and Applicant K.N.C.’s PPP loan application 
 
133. On or about April 19, 2021, Martin, 
 
, and Applicant K.N.C. 
transmitted PPP loan application # 5357178807, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
5357178807 caused Amur to transmit $20,397.00 into Applicant K.N.C.’s CFCU account 
number ###### 0616.  
 
134. On November 15, 2021, Applicant K.N.C. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 5357178807. Applicant K.N.C. 
certified that Applicant K.N.C. complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects. 
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Indictment – Page 32 
 
  
135. On or about July 27, 2022, Applicant K.N.C.’s PPP loan # 5357178807 was 
forgiven by the SBA. 
Martin, 
 
, and Applicant K.B.R.’s PPP loan application 
 
136. On or about May 8, 2021, Martin, 
 
, and Applicant K.B.R. 
transmitted PPP loan application # 2563509008, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
2563509008 caused Prestamos to transmit $20,832.00 into Applicant K.B.R.’s EFCU 
account number ###### 7494.  
 
137. On or about September 30, 2021, Applicant K.B.R. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 2563509008. Applicant K.B.R. 
certified that Applicant K.B.R. complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects.  
 
138. On or about October 28, 2021, Applicant K.B.R.’s PPP loan # 2563509008 
was forgiven by the SBA. 
 
 
Martin, 
 
 and Applicant C.M.’s PPP loan application 
 
139. On or about May 17, 2021, Martin, 
 
, and Applicant C.M. 
transmitted PPP loan application # 4510879009, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
4510879009 caused Prestamos to transmit $ 20,832.00 into Applicant C.M.’s PSCU 
account number ###### 7693.  
 
140. On August 23, 2022, Applicant C.M. transmitted PPP Loan Forgiveness 
Application Form 3058S for PPP loan # 4510879009. Applicant C.M. certified that 
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Indictment – Page 33 
 
Applicant C.M. complied with the PPP rules and that the PPP loan application is true and 
correct in all material respects.  
 
141. On August 29, 2022, Applicant C.M.’s PPP loan # 4510879009 was 
forgiven by the SBA. 
Martin, 
 
, and Applicant L.S.R.’s PPP loan application 
 
142. On or about April 22, 2021, Martin, 
 
, and Applicant L.S.R. 
transmitted PPP loan application # 7143008806, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
7143008806 caused Amur to transmit $20,110.00 into Applicant L.S.R.’s PSCU account 
number ###### 6602.  
 
143. On or about August 3, 2022, transmitted PPP Loan Forgiveness Application 
Form 3058S for PPP loan # 7143008806. Applicant L.S.R. certified that Applicant L.S.R. 
complied with the PPP rules and that the PPP loan application is true and correct in all 
material respects.  
 
144. On or about August 10, 2022, Applicant L.S.R.’s PPP loan # 7143008806 
was forgiven by the SBA. 
MARTIN, 
 AND APPLICANTS’ PPP LOAN APPLICATIONS 
Martin, 
, and Applicant M.R.’s PPP loan application 
 
145. On or about May 3, 2021, Martin, 
, and Applicant M.R. 
transmitted PPP loan application # 5646668906, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
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Indictment – Page 34 
 
5646668906 caused Amur to transmit $20,833.00 into Applicant M.R.’s PSCU account 
number ###### 2326.  
 
146. On or about November 29, 2021, Applicant M.R. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 5646668906. Applicant M.R. 
certified that Applicant M.R. complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects.  
  
147. On or about December 8, 2021, Applicant M.R.’s PPP loan # 5646668906 
was forgiven by the SBA. 
Martin, 
, and Applicant E.W.’s PPP loan application 
 
148. On or about May 5, 2021, Martin, 
 and Applicant E.W. 
transmitted PPP loan application # 1903269000, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
1903269000 caused Prestamos to transmit $20,832.00 into Applicant E.W.’s EFCU 
account number ###### 1402.  
 
149. On or about October 3, 2021, Applicant E.W. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 1903269000. Applicant E.W. 
certified that Applicant E.W. complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects.  
  
150. On or about October 28, 2021, Applicant E.W.’s PPP loan # 1903269000 
was forgiven by the SBA. 
 
 
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Martin, 
, and Applicant K.T.R.’s PPP loan application 
 
151. On or about May 2, 2021, Martin, 
, and Applicant K.T.R. 
transmitted PPP loan application # 1675059004, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
1675059004 caused Prestamos to transmit $20,832.00 into Applicant K.T.R.’s Neighbors 
FCU account number ###### 4952.  
 
152. On or about October 19, 2021, Applicant K.T.R. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 1675059004. Applicant K.T.R. 
certified that Applicant K.T.R. complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects.  
  
153. On or about October 28, 2021, Applicant K.T.R.’s PPP loan # 1675059004 
was forgiven by the SBA. 
MARTIN, 
 AND APPLICANTS’ PPP LOAN APPLICATIONS 
 
Martin, 
, and Applicant B.D.R.’s PPP loan application 
 
154. On or about April 20, 2021, Martin, 
, and Applicant B.D.R. 
transmitted PPP loan application # 1888198901, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
1888198901caused Prestamos to transmit $20,832.00 into Applicant B.D.R.’s WF 
account number ###### 9773.  
 
155. On or about December 1, 2021, Applicant B.D.R. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 1888198901. Applicant B.D.R. 
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Indictment – Page 36 
 
certified that Applicant B.D.R. complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects.  
  
156. On or about January 14, 2022, Applicant B.D.R.’s PPP loan # 1888198901 
was forgiven by the SBA. 
Martin, 
, and Applicant D.C.’s PPP loan application 
 
157. On or about April 20, 2021, Martin, 
, and Applicant D.C. 
transmitted PPP loan application # 4511768801, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
4511768801caused Customers Bank to transmit $20,833.00 into Applicant D.C.’s 
checking account number ###### 8668.  
Martin, 
, and Applicant M.M.’s PPP loan application 
 
158. On or about April 26, 2021, Martin, 
, and Applicant M.M. 
transmitted PPP loan application # 4368708910, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
4368708910 caused Benworth to transmit $20,833.00 into Applicant M.M.’s BOA 
account number ###### 7153.  
MARTIN, 
 AND APPLICANTS’ PPP LOAN APPLICATIONS 
Martin, 
, and Applicant A.B.’s PPP loan application 
 
159. On or about May 18, 2021, Martin, 
 and Applicant A.B. transmitted 
PPP loan application # 7782269000, first draw, to the SBA for approval knowing 
information on the PPP loan application was false. PPP loan application # 7782269000 
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caused Prestamos to transmit $20,832.00 into Applicant A.B.’s JPMCB account number 
###### 9623.  
Martin, 
, and Applicant D.H.’s PPP loan application 
 
160. On or about April 27, 2021, Martin, 
, and Applicant D.H. transmitted 
PPP loan application # 1052608904, first draw, to the SBA for approval knowing 
information on the PPP loan application was false. PPP loan application # 1052608904 
caused Amur to transmit $20,832.00 into Applicant D.H.’s COB account number ###### 
2105.  
 
161. On or about August 6, 2021, Applicant D.H. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 1052608904. Applicant D.H. 
certified that Applicant D.H. complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects.  
  
162. On or about August 25, 2021, Applicant D.H.’s PPP loan # 1052608904 
was forgiven by the SBA. 
MARTIN,  
 AND APPLICANTS’ PPP LOAN APPLICATIONS 
Martin And  
 PPP Loan Application 
 
163. On or about April 12, 2021,  
 transmitted $80.00 to Martin. This 
payment was the fee to develop fraudulent documents for  
 PPP loan 
application.  
 
164. On or about May 27, 2021, Martin and  
 transmitted PPP loan 
application # 7267989010, first draw, to the SBA for approval knowing information on 
the PPP loan application was false.  PPP loan application # 7267989010 referenced a 
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Indictment – Page 38 
 
fictitious business: “Jada Turner Wig Slay” (purportedly maintained by  
), 
fraudulent financial records and a fraudulent Schedule C. PPP loan application # 
7267989010 caused Enterprise Center to transmit $20,832.00 into  
 COB 
account number ###### 1318. 
 
165. On or about June 7, 2021,  
 compensated Martin $3,500.00, for 
Martin’s role in filing the fraudulent application referenced in paragraph 164. 
 
166. On or about February 22, 2023,  
 transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 7267989010.  
 certified 
that she complied with the PPP rules and that the PPP loan application is true and correct 
in all material respects.  
MARTIN,  
, AND APPLICANT J.T’S PPP LOAN APPLICATION 
 
167. On or about May 3, 2021, Martin,  
, and Applicant J.T. 
transmitted PPP loan application # 5957758906, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
5957758906 caused Amur to transmit $20,833.00 into Applicant J.T.’s NFCU account 
number ###### 6267.  
 
168. On or about November 30, 2021, Applicant J.T. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 5957758906 certified that Applicant 
J.T. complied with the PPP rules and that the PPP loan application is true and correct in 
all material respects.  
  
169. On or about December 8, 2021, Applicant J.T.’s PPP loan # 5957758906 
was forgiven by the SBA. 
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Indictment – Page 39 
 
MARTIN, 
 AND APPLICANTS’ PPP LOAN APPLICATIONS 
Martin and 
 PPP loan application 
 
170. On or about April 9, 2021, 
 provided Martin with 
 
personal identity information so Martin could process 
 fraudulent PPP loan 
application.  
 
171. On or about April 9, 2021, 
 transmitted $65.00 to Martin’s 
Cash App. account $4artymar. This payment was the fee to develop fraudulent 
documents for 
 PPP loan application.  
 
172. On or about April 19, 2021, Martin and 
 transmitted PPP loan 
application # 5643198803, first draw, to the SBA for approval knowing information on 
the PPP loan application was false.  PPP loan application # 5643198803 referenced a 
fictitious business: “Michelle Cummings Service” (purportedly maintained by 
), fraudulent financial records, and a fraudulent Schedule C. PPP loan 
application # 5643198803 caused Amur to transmit $20,833.00 into 
 PSCU 
account number ###### 5379. 
 
173. On or about April 28, 2021, 
 compensated Martin $3,000.00, 
for Martin’s role in filing the PPP loan application referenced in paragraph 172. 
 
174. On or about September 24, 2021, 
 transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 5643198803. 
 certified 
that 
 complied with the PPP rules and that the PPP loan application is true and 
correct in all material respects.  
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Indictment – Page 40 
 
 
175. On or about September 30, 2021, 
 PPP loan # 5643198803 was 
forgiven by the SBA. 
Martin, 
, and Applicant M.C.’s PPP loan application 
 
176. On or about May 24, 2021, Martin, 
, and Applicant M.C. 
transmitted PPP loan application # 6771979001, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
6771979001 caused Enterprise Center to transmit $20,833.00 into Applicant M.C. PSCU 
account number ###### 2800.  
 
177. On or about September 27, 2021, Applicant M.C. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 1625829001. Applicant M.C. 
certified that Applicant M.C. complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects.  
  
178. On or about October 5, 2021, Applicant M.C.’s PPP loan # 6771979001 
was forgiven by the SBA. 
Martin, 
, and Applicant D.H.’s PPP loan application 
 
179. On or about May 12, 2021, Martin, 
 and Applicant D.H. 
transmitted PPP loan application # 4612569000, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
4612569000 caused Prestamos to transmit $20,832.00 into Applicant D.H.’s EFCU 
account number ###### 6881.  
 
180. On or about September 25, 2021, Applicant D.H. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 4612569000. Applicant D.H. 
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Indictment – Page 41 
 
certified that Applicant D.H. complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects.  
  
181. On or about October 28, 2021, Applicant D.H.’s PPP loan # 4612569000 
was forgiven by the SBA. 
MARTIN, 
 AND APPLICANTS’ PPP LOAN APPLICATIONS 
Martin and 
 first PPP loan application 
 
182. On or about February 9, 2021, 
 transmitted $45.00 to Martin’s 
Cash App account $4artymar. This payment was the fee to develop fraudulent documents 
for 
 PPP loan application.  
 
183. On or about February 9, 2021, Martin transmitted $45.00 to 
 
Cash App. account $wideroff53. The subject line on this wire included “Texas Ayramis”.  
This payment was the fee to develop fraudulent documents for 
 PPP loan 
application.  
 
184. On or about February 15, 2021, Martin and 
 transmitted PPP loan 
application # 8427488403, first draw, to the SBA for approval knowing information on 
the PPP loan application was false.  PPP loan application # 8427488403 referenced a 
fictitious business: “Texas Carpet Cleaning” (purportedly maintained by 
), 
fraudulent financial records and a fraudulent Schedule C. PPP loan application # 
8427488403 caused Itria to transmit $20,447.50 into 
 SFCU account number 
###### 5450.  
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Indictment – Page 42 
 
 
185. On or about April 5, 2021, through April 6, 2021, 
 compensated 
Martin $2,000.00, for Martin’s role in filing the fraudulent PPP loan application 
referenced in paragraph 184. 
 second PPP loan application 
 
186. On April 3, 2021, 
 transmitted $130.00 to Martin’s Cash App. 
account. This payment was the fee to develop fraudulent documents for 
 and 
Applicant B.B.’s PPP loan application. 
 
187. On or about April 9, 2021, Martin and 
 transmitted PPP loan 
application, # 2098648807, second draw, to the SBA for approval knowing information 
on the PPP loan application was false.  PPP loan application # 2098648807 referenced a 
fictitious business: “Texas Carpet Cleaners” (purportedly maintained by 
), 
fraudulent bank records and a fraudulent Schedule C. PPP loan application # 2098648807 
caused Capital Plus to transmit $20,832.00 into 
 RB account number ###### 
3765.  
 
188. On or about April 23, 2021, 
 compensated Martin $3,000.00, for 
Martin’s role in filing the fraudulent PPP loan application referenced in paragraph 187. 
 
189. On July 5, 2021, 
 transmitted PPP Loan Forgiveness Application 
Form 3058S for PPP loan # 2098648807 (Texas Carpet Cleaners). 
 certified he 
complied with the PPP rules and that the PPP loan application is true and correct in all 
material respects.  
 
190.  On or about July 12, 2021, 
 PPP loan # 2098648807 was forgiven 
by the SBA. 
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Indictment – Page 43 
 
Martin, 
 and Applicant B.B.’s PPP loan application 
Applicant B.B.’s first PPP loan application 
 
191. On or about February 22, 2021, Martin, 
, and Applicant B.B. 
transmitted PPP loan application # 1763668504, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
1763668504 caused Itria to transmit $20,250.00 into Applicant B.B.’s BOA account 
number ###### 8944.  
Applicant B.B.’s second PPP loan application 
 
192. On or about April 14, 2021, Martin, 
, and Applicant B.B. 
transmitted PPP loan application # 7641748808, second draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
7641748808 caused Prestamos to transmit $20,832.00 into Applicant B.B.’s BOA 
account number ###### 8944.  
MARTIN, 
 AND APPLICANTS’ PPP LOAN APPLICATIONS 
MARTIN and 
 PPP loan application 
 
193. On or about February 26, 2021, 
 transmitted $46.00 to Martin for 
the development of fraudulent documents for a PPP loan application. 
 also 
provided Martin with her date of birth, social security number, her bank account 
information, and her address. 
 
 
 
194. On or about February 27, 2021, Martin transmitted $45.00 to 
 
Cash App. account $wideroff53. The subject line on this wire included “arlyssa”.  This 
payment was the fee to develop fraudulent documents for 
 PPP loan application.  
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Indictment – Page 44 
 
 
195. On or about March 27, 2021, Martin and 
 transmitted PPP loan 
application, # 2241818705, first draw, to the SBA for approval knowing information on 
the PPP loan application was false.  PPP loan application # 2241818705 referenced a 
fictitious business: “McGees Travel Agent” (purportedly maintained by 
), 
fraudulent financial records, and a fraudulent Schedule C. PPP loan application # 
2241818705 caused Capital Plus to transmit $20,832.00 into 
 PSCU account 
number ###### 561.  
  
196. On or about September 14, 2021, 
 transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 2241818705 (“McGees Travel 
Agent”). 
 certified that she complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects.  
 
197. On or about September 21, 2021, 
 PPP loan # 2241818705 was 
forgiven by the SBA. 
MARTIN, 
, and Applicant A.R.’s PPP loan application 
 
198. On or about March 6, 2021, Martin, 
 and Applicant A.R. 
transmitted PPP loan application # 7285708505, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
7285708505 caused Itria to transmit $20,833.00 into Applicant A.R.’s PSCU account 
number ###### 5427. 
MARTIN, 
, and Applicant S.K.’s PPP loan application 
 
199. On or about April 18, 2021, Martin, 
 and Applicant S.K. 
transmitted PPP loan application #5399688805, first draw, to the SBA for approval 
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Indictment – Page 45 
 
knowing information on the PPP loan application was false. PPP loan application # 
5399688805 caused Amur to transmit $20,832.00 into Applicant S.K.’s PSCU account 
number ###### 3561. 
 
200. On or about September 14, 2021, Applicant S.K. transmitted and caused to 
be transmitted PPP Loan Forgiveness Application Form 3058S. Applicant S.K. certified 
that S.K. complied with the PPP rules and that the PPP loan application is true and 
correct in all material respects.  
 
201. On or about September 24, 2021, Applicant S.K.’s PPP loan # 5399688805 
was forgiven by the SBA. 
MARTIN, 
 AND APPLICANTS’ PPP LOAN APPLICATIONS 
Martin and 
 PPP loan application  
 
202. On or about April 12, 2021, 
 provided Martin her name, address, 
bank account information, a monthly deposit amount, and deposit dates to facilitate the 
production of a fraudulent financial statements.  
 
203. On or about April 12, 2021, 
 transmitted $80.00 to Martin’s Cash 
App. account $4artymar. The subject line read “For Shemeka”. This payment was the fee 
to develop fraudulent documents for 
 PPP loan application.  
 
204. On or about April 20, 2021, Martin and 
 transmitted PPP loan 
application, # 1106398909, first draw, to the SBA for approval knowing information on 
the PPP loan application was false.  PPP loan application # 1106398909 referenced a 
fictitious business: Hairstylist, fraudulent bank records and a fraudulent Schedule C. PPP 
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Indictment – Page 46 
 
loan application # 1106398909 caused Prestamos to transmit $20,832.00 into 
 
BOA account number ####### 4957.  
  
205. On or about May 11, 2021, 
 compensated Martin $4,000.00 for 
Martin’s role in filing the PPP loan application referenced in paragraph 204. 
  
206. On or about September 21, 2021, 
 transmitted PPP Loan Forgiveness 
Application Form 3058S for PPP loan #1106398909 (“Hairstylist”). 
 certified that 
she complied with the PPP rules and that the PPP loan application is true and correct in 
all material respects.  
 
207. On or about October 13, 2021, 
 PPP loan # 1106398909 was 
forgiven by the SBA. 
Martin, 
, and Applicant T.T.’s PPP loan application  
 
208. On or about May 10, 2021, Martin, 
 and Applicant T.T. transmitted 
PPP loan application, # 4126919003, first draw, to the SBA for approval knowing 
information on the PPP loan application was false.  PPP loan application # 4126919003 
referenced a fictitious business, fraudulent financial records, and a fraudulent Schedule C. 
PPP loan application # 4126919003 caused Prestamos to transmit $ 20,832.00 into 
Applicant T.T.’s RB account number ###### 4453.  
  
209. On or about February 26, 2022, Applicant T.T. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 4126919003. Applicant T.T. 
certified that Applicant T.T. complied with the PPP rules and that the PPP loan 
application is true and correct in all material respects.  
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Indictment – Page 47 
 
 
210. On or about March 9, 2022, Applicant T.T.’s PPP loan # 4126919003 was 
forgiven by the SBA. 
MARTIN, 
 
 AND APPLICANTS’ PPP LOAN APPLICATIONS 
Martin And 
 
 PPP Loan Application 
 
211. On February 10, 2021, 
 
 provided Martin his name, physical 
address, and email address. 
 
 also provided Martin with a copy of his driver’s 
license, bank account, a monthly deposit amount, and deposit dates to facilitate the 
production of a fraudulent financial statements. 
 
 transmitted $45.00 to 
Martin’s Cash App Account $artishamartin95. This payment was the fee to develop 
fraudulent documents for 
 
 PPP loan application.  
 
212. On or about February 15, 2021, Martin and 
 
 transmitted PPP 
loan application, # 8758608407, first draw, to the SBA for approval knowing information 
on the PPP loan application was false.  PPP loan application # 8758608407 referenced a 
fictitious business: “Martin’s Landscaping” (purportedly maintained by 
 
), 
fraudulent financial records, and a fraudulent Schedule C. PPP loan application # 
8758608407 caused Itria to transmit $20,387.50 into 
 
 COB account number 
###### 5897.  
 
213. Between March 11, 2021, and March 14, 2021, 
 
 compensated 
Martin $3,000.00 for Martin’s role in filing the PPP loan application referenced in 
paragraph 212. 
 
 
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Indictment – Page 48 
 
Martin, 
 
 and Applicant A.D.’s PPP loan application 
 
214. On or about February 27, 2021, Martin, 
 
 and Applicant A.D. 
transmitted PPP loan application # 4807428509, first draw, to the SBA for approval 
knowing information on the PPP loan application was false.  PPP loan application # 
4807428509 referenced a fictitious business, fraudulent financial records, and a 
fraudulent Schedule C. PPP loan application # 4807428509 caused Itria to transmit 
$20,677.00 into Applicant A.D.’s NFCU account number ###### 0662. 
 
215. On or about July 27, 2021, Applicant A.D. transmitted PPP Loan 
Forgiveness Application Form 3058S for PPP loan # 4807428509. Applicant certified 
that Applicant A.D. complied with the PPP rules and that the PPP loan application is true 
and correct in all material respects.  
 
216. On or about August 2, 2021, Applicant A.D.’s PPP loan # 4807428509 was 
forgiven by the SBA. 
 
In violation of 18 U.S.C. § 1349. 
 
 
 
 
 
 
 
 
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Indictment – Page 49 
 
Count Two 
 
 
 
 
 
 
 
 
 
 
18 U.S.C. § 1343  
 
 
 
 
 
 
 
 
 
           (Wire Fraud) 
217. The General Allegations section (Paragraphs 1-39 herein) of this indictment  
is realleged and incorporated by reference as though fully set forth herein. 
Purpose of the Scheme and Artifice 
218. From in or about January 2021, and continuing through in or about  
June 2021, in the Eastern District of Texas and elsewhere, Artisha Gabrilla Dimetrika  
 
Martin, aka Rikkita Jones, aka Gabby Martin, aka “Artymar” (1), 
 
  
 
 
 
 
  
 
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 defendants, knowingly devised 
and intended to devise a scheme and artifice to unlawfully and unjustly enrich themselves 
by means of false and fraudulent pretenses, representations, and promises, by among 
other things: (a) submitting and causing the submission of a false and fraudulent PPP loan 
application to obtain funds made available through the CARES Act to provide relief for 
the economic effects caused by the COVID-19 pandemic; (b) offering, paying, and 
receiving kickbacks in return for the submission of a false and fraudulent PPP loan 
application; and (c) diverting fraud proceeds for the personal use of the defendants, and 
the use and benefit of others.  
  
219. During the course of the scheme and artifice, Martin, 
 and 
 transmitted by means of wire communication in interstate and foreign commerce, 
writing, signs, signals, pictures, and sounds for the purpose of executing the scheme and 
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Indictment – Page 50 
 
artifice to defraud and for obtaining money and property by means of false and fraudulent 
material pretenses, representations, and promises, and acted with specific intent to 
defraud. 
Manner and Means of the Scheme and Artifice 
 
220. It was part of the scheme and artifice that Martin promoted the fraudulent 
PPP loan scheme utilizing Martin’s Instagram account: artymar__ and other social 
media outlets to recruit 
 to submit a fraudulent PPP loan application.  
 
221. Martin informed 
 of the process to file a fraudulent PPP loan 
application and the cost to file by transmitting a text message, direct message, or other 
electronic message to 
  
  
222. 
 provided Martin with personal identifying information.  Martin 
provided the personal identifying information to 
  This allowed 
 to 
generate fraudulent financial records and a fraudulent Schedule C. 
 generated 
the fraudulent documents, that is, the fraudulent bank records and a fraudulent Schedule 
C to show that 
 had a net profit that was impacted by COVID-19 which would 
qualify him for a PPP loan.  
 
223. Martin would transmit a false and fraudulent PPP loan application. 
 
represented to have an operational business and that the operational business was 
impacted by COVID-19 which would qualify 
 for PPP loan funds as authorized by 
the CARES Act.   
 
224.  The fraudulent PPP loan application included multiple materially false and 
fraudulent pretenses, representations and promises, such as: 
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Indictment – Page 51 
 
a. The average monthly payroll and the number of employees; 
b. Listing that the purpose of the loan was to cover payroll costs; 
c. Listing the applicant as the owner of the business; 
d. Certifying that the funds will be used to retain workers and maintain 
payroll; and  
 
e. Certifying the truth of the statements in the loan application.  
 
225. 
 had the funds from the PPP loan transmitted into a financial 
institution that handled 
 financial interest in the fictitious business.   
 
226.   
 paid a portion of the PPP funds to Martin as a kickback for her role 
in obtaining the PPP funds. 
 transmitted to Martin’s bank account a kickback fee 
of $2,000.00 by utilizing a digital payment network. 
 
227.  
, with Martin’s assistance, submitted a PPP Loan Forgiveness 
Application Form 3508S to have the PPP loan forgiven. 
 certified that he complied 
with all the PPP requirements regarding the use of the PPP funds to include: 
 
 
a. 
eligible uses of PPP loan proceeds; 
 
 
b.  
the amount of PPP loan proceeds that must be used for payroll cost; 
 
 
c.  
the calculation and documentation of the borrower’s revenue   
 
 
 
reduction (if applicable); and  
 
 
 
d.  
the calculation of the borrower’s requested loan forgiveness amount  
 
 
 
and that the information provided in the PPP loan application is true  
 
 
 
and correct in all material respects.  
 
 
228. Martin transmitted a wire that affected interstate commerce by sending 
wire transfers and by accessing and submitting the PPP loan application online through a 
portal set up by the SBA. 
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Indictment – Page 52 
 
 
229. It was part of the scheme and artifice that Martin submitted a PPP loan 
application utilizing 
 personal identifying information to unlawfully obtain 
money from the CARES Act funds. 
 generated fraudulent bank records and a 
Schedule C to submit with the PPP loan application.  
 
230.  The fraudulent PPP loan application included multiple false and fraudulent 
material pretenses, representations and promises, such as: 
a. The average monthly payroll and the number of employees; 
b. Listing that the purpose of the loan was to cover payroll costs; 
c. Listing the applicant as the owner of the business; 
d. Certifying that the funds will be used to retain workers and maintain 
payroll; and  
 
e. Certifying the truth of the statements in the loan application.  
Execution of the Scheme and Artifice 
 
231.  It was part of the scheme and artifice that defendants conducted the 
following acts to further the scheme and artifice in conducting the following wire 
transaction: 
 
232. On or about February 15, 2021, Martin, 
 and 
, 
transmitted PPP loan application # 8733678410, first draw, to the SBA for approval 
knowing information on the PPP loan application was false. PPP loan application # 
8733678410 referenced a fictitious business: “Wiley Cutz”, located in Orange, Texas, 
fraudulent financial records and a fraudulent Schedule C. PPP loan application # 
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Indictment – Page 53 
 
8733678410 caused Itria to transmit $20,833.33 into 
 COB account number 
###### 2595.  
 
233. On or about March 3, 2021, 
 compensated Martin, $2,000.00 for 
Martin’s role in filing the PPP loan application referenced in paragraph 232. 
 
234. On or about June 28, 2021, 
 transmitted PPP Loan Forgiveness 
Application Form 3058S for PPP loan # 3294728809 (“Wiley Cutz”). 
 certified that 
he complied with the PPP rules and that the PPP loan application is true and correct in all 
material respects.  
In violation of 18 U.S.C. § 1343. 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Indictment – Page 54 
 
NOTICE OF INTENT TO SEEK CRIMINAL FORFEITURE 
Pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c). 
 
235. The allegations contained in Count One and Two are hereby realleged and  
incorporated by reference as though fully set forth herein for the purpose of alleging 
forfeitures to the United States of America of certain property in which the defendants have 
an interest. 
236. Upon conviction of any violation of 18 U.S.C. § 1349 and 18 U.S.C. § 1343,  
the defendants shall forfeit to the United States any property, real or personal, that 
constitutes or is derived from proceeds traceable to a violation of any offense constituting 
“specified unlawful activity,” or a conspiracy to commit such offense, pursuant to 18 
U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c). 
 
237. The property that is subject to forfeiture includes, but is not limited to, the 
following: 
a. 
All funds subject to forfeiture in bank accounts receiving or transferring the 
fraudulently obtained proceeds; and 
 
b. 
A money judgment from: 
 
 
i. 
Artisha Martin in the amount of $2,420,274.30 and all 
 
interest and proceeds traceable thereto, representing the proceeds of 
 
the offenses, for which the defendants are jointly and severally 
 
personally liable. 
 
 
ii.  
 
 in the amount of $296,843.00 and all interest 
 
and proceeds traceable thereto, representing the proceeds of the 
 
offenses, for which the defendants are jointly and severally personally 
 
liable. 
 
 
 
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Indictment – Page 55 
 
 
iii.  
 
 
 in the amount of $298,354.33 and all 
 
interest and proceeds traceable thereto, representing the proceeds of 
 
the offenses, for which the defendants are jointly and severally 
 
personally liable. 
 
 
iv. 
 
 in the amount of $20,833.33 and all interest 
 
and proceeds traceable thereto, representing the proceeds of the 
 
offenses, for which the defendants are jointly and severally personally 
 
liable. 
 
 
v. 
 
 
 in the amount of $392,940.70 and all 
 
interest and proceeds traceable thereto, representing the proceeds of 
 
the offenses, for which the defendants are jointly and severally 
 
personally liable. 
 
 
vi. 
 
 in the amount of $41,235.00 and all 
 
interest and proceeds traceable thereto, representing the proceeds of 
 
the offenses, for which the defendants are jointly and severally 
 
personally liable. 
 
 
vii. 
 
 in the amount of $62,497.00 and all interest 
 
and proceeds traceable thereto, representing the proceeds of the 
 
offenses, for which the defendants are jointly and severally personally 
 
liable. 
 
 
viii. 
 
 in the amount of $41,665.00 and all interest 
 
and proceeds traceable thereto, representing the proceeds of the 
 
offenses, for which the defendants are jointly and severally personally 
 
liable. 
 
 
ix. 
 
 in the amount of $41,664.00 and all interest and 
 
proceeds traceable thereto, representing the proceeds of the 
 
offenses, for which the defendants are jointly and severally personally 
 
liable. 
 
 
x. 
 
 in the amount of $41,665.00 and all interest and 
 
proceeds traceable thereto, representing the proceeds of the 
 
offenses, for which the defendants are jointly and severally personally 
 
liable. 
 
 
 
 
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Indictment – Page 56 
 
 
xi. 
 
 in the amount of $62,498.00 and all 
 
interest and proceeds traceable thereto, representing the proceeds of 
 
the offenses, for which the defendants are jointly and severally 
 
personally liable. 
 
 
xii. 
 
 in the amount of $82,361.50 and all interest 
 
and proceeds traceable thereto, representing the proceeds of the 
 
offenses, for which the defendants are jointly and severally personally 
 
liable. 
 
 
xiii. 
 
 in the amount of $64,275.00 and all interest 
 
and proceeds traceable thereto, representing the proceeds of the 
 
offenses, for which the defendants are jointly and severally personally 
 
liable. 
 
 
xiv. 
 
 in the amount of $41,664.00 and all interest 
 
and proceeds traceable thereto, representing the proceeds of the 
 
offenses, for which the defendants are jointly and severally personally 
 
liable. 
 
 
xv. 
 
 in the amount of $41,064.50 and all interest 
 
and proceeds traceable thereto, representing the proceeds of the 
 
offenses, for which the defendants are jointly and severally personally 
 
liable. 
 
238. Pursuant to 21 U.S.C. § 853(p), as incorporated by reference by 18 U.S.C.  
§ 982(b), if any of the forfeitable property, or any portion thereof, as a result of any act or 
omission of the defendant: 
a. 
cannot be located upon the exercise of due diligence; 
 
b. 
has been transferred or sold to, or deposited with, a third party; 
c. 
has been placed beyond the jurisdiction of the court; 
 
d. 
has been substantially diminished in value; or 
 
e. 
has been commingled with other property which cannot be divided without 
difficulty, 
 
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Indictment – Page 57 
 
it is the intent of the United States to seek the forfeiture of other property of the defendants 
up to the value of the above-described forfeitable properties, including, but not limited to, 
any identifiable property in the name of the defendants. 
239. By virtue of the commission of the offenses alleged in this indictment, any  
and all interest the defendants have in the above-described property is vested in the United 
States and hereby forfeited to the United States pursuant to 18 U.S.C. §§ 981(a)(1)(C) and 
28 U.S.C. § 2461(c). 
240. All pursuant to 18 U.S.C. §§ 981(a)(1)(C) and 28 U.S.C. § 2461(c), and the 
procedures set forth at 21 U.S.C. § 853, as made applicable through 18 U.S.C. § 982(b)(1). 
 
 
A TRUE BILL 
 
 
 
__________________________ 
 
GRAND JURY FOREPERSON  
 
 
 
 
DAMIEN M. DIGGS 
UNITED STATES ATTORNEY 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
REYNALDO P. MORIN  
 
 
  
Date 
ASSISTANT UNITED STATES ATTORNEY 
 
 
Case 4:24-mj-00257   Document 1   Filed on 06/11/24 in TXSD   Page 57 of 59

Indictment – Page 58 
 
IN THE UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF TEXAS 
BEAUMONT DIVISION 
 
UNITED STATES OF AMERICA 
 
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v. 
 
 
 
 
 
 
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No. 1:24-CR- 
 
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JUDGE  
ARTISHA GABRIELLA DIMETRIKA   
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MARTIN aka RIKKITA JONES, aka  
 
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GABBY MARTIN, aka ARTYMAR (1),  
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NOTICE OF PENALTY 
 
COUNTS 1-2 
 
 
VIOLATION:  
18 U.S.C. §§ 1349 and 1343 
 
 
 
Conspiracy to Commit Wire Fraud and Wire Fraud 
 
 
 
Case 4:24-mj-00257   Document 1   Filed on 06/11/24 in TXSD   Page 58 of 59

Indictment – Page 59 
 
PENALTY:  
 Imprisonment of not more than twenty (20) years; a fine not to 
exceed $250,000, or twice the pecuniary gain to the defendant or 
loss to the victim; or both imprisonment and a fine; and a term of 
supervised release of not more than three (3) years. If the violation 
involves any benefit authorized in connection with a presidentially 
declared major disaster or emergency or affects a financial 
institution, the defendant may receive imprisonment of not more 
than thirty (30) years; a fine not to exceed $1,000,000.00, or twice 
the pecuniary gain to the defendant or loss to the victim; or both 
imprisonment and a fine; and a term of supervised release of not 
more than five (5) years. 
 
SPECIAL ASSESSMENT: $100.00 each count. 
 
Case 4:24-mj-00257   Document 1   Filed on 06/11/24 in TXSD   Page 59 of 59

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