Indictment — United States of America v. Melissa Fireside, Case 3:26-cr-00337-IM (Dkt. 1, D. Or.)

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An indictment, Doc. 1 filed September 2, 2026, in United States of America v. Melissa Fireside, No. 3:26-cr-00337-IM, in the U.S. District Court for the District of Oregon, Portland Division. It alleges that beginning in or about March 2020 Fireside carried out a scheme to defraud the SBA and Amur Equipment Finance, including an EIDL application that sought approximately $150,000 and was declined, and a PPP application submitted March 19, 2021. It alleges that on April 1, 2021 the SBA wired $290,795 to a U.S. Bank account and that three checks diverted $273,930.38 of PPP proceeds. Counts 1-2 charge wire fraud under 18 U.S.C. § 1343, and a forfeiture allegation follows.

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         Case 3:26-cr-00337-IM          Document 1      Filed 09/02/26       Page 1 of 9




                             UNITED STATES DISTRI CT COURT

                                    DISTRICT OF OREGON

                                     PORTLAND DIVISION


UNITED STATES OF AMERICA                             3:26-cr-00337-IM

                v.                                   INDICTMENT

MELISSA FIRESIDE,                                    18 u.s.c. § 1343

                Defendant.                           Forfeiture Allegation


                                THE GRAND JURY CHARGES:

A.      INTRODUCTORY ALLEGATIONS

        At all times relevant to this Indictment:

        1.      Defendant MELISSA FIRES IDE was a resident of Oregon, and owner of

Resolute Consulting POX, Limited Liabil ity Company, a company in Portland, Oregon,

registered with the Oregon Secretary of State in January of 20 18.

        2.      Defendant FIRES IDE owned and/or controlled an entity called CWE Services,

which was not registered with the Oregon Secretary of State.

        3.      Defendant FIRESIDE was G.f.'s caregiver, handled G.f . ' s finances, and

prepared G.f .' s taxes.

        4.      G.f . never owned a business, did not maintain an e-mail address, and did not

regularly use a computer.


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       The Paycheck Protection Program

       5.      The Coronavirus Aid, Relief, and Economic Security ("CARES") Act was a

federal law enacted in or about March 2020 that was designed to provide emergency financial

assistance to Americans suffering economic harm as a result of the COVID-19 pandemic. One

form of assistance provided by the CARES Act was the authorization of up to $349 billion in

United States taxpayer funds in forgivable loans to small businesses for job retention and certain

other expenses, through a program referred to as the Paycheck Protection Program ("PPP"). In

or about April 2020, Congress authorized over $300 billion in United States taxpayer funds in

additional PPP funding.

       6.      To obtain a PPP loan, a qualifying business was required to submit a PPP loan

application signed by an authorized representative of the business. The PPP loan application

required the small business (through its authorized representative) to acknowledge the program

rules and make certain affirmative certifications to be eligible to obtain the PPP loan. One

certification required the applicant to affirm that "[t]he [PPP loan] funds w[ould] be used to

retain workers and maintain payroll or make mortgage interest payments, lease payments, and

utility payments." The applicant (through its authorized representative) was also required to

acknowledge that "I understand that if the funds are used for unauthorized purposes, the federal

government may pursue criminal fraud charges." In the PPP loan application, the applicant 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, the applicant was required to provide

documentation showing its payroll expenses.




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        7.      A business's PPP loan application was received and processed, in the first

instance, by a participating financial institution, then transmitted, for further review, to the Small

Business Administration ("SBA") to assess the applicant's eligibility . If a PPP loan application

was approved, the participating financial institution would fund the PPP loan using its own

monies. The SBA guaranteed the loans funded under the PPP and paid lender fees to financial

institutions for financing the loans.

        8.      PPP loan proceeds were required to be used by the business on certain permissible

expenses, namely, 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 expenses within a designated period of time and used at least a minimum

amount of the PPP loan proceeds towards payroll expenses. Forgiveness of the PPP loan

entailed the SBA paying the full loan amount and accrued interest to fully satisfy the lending

institution.

        9.     The PPP also allowed certain eligible borrowers that had previously received a

PPP loan to apply for a second PPP loan, with the same general loan terms as their first PPP

loan. These "second round" loans could be used for the same purposes as were permitted for the

first PPP loans, including payroll costs, interest on mortgages, rent, and utilities.

        10.     PPP loan applications submitted after January 11, 2021, were transmitted via

interstate wires and received through servers located in Oregon.

        11.    Regardless of date, PPP forgiveness applications were transmitted via interstate

wires and received through servers located in Oregon.

/ II

II I


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       The Economic Iniury Disaster Loan Program

        12.    The Economic Injury Disaster Loan Program ("EIDL") was a United States SBA

program that provided low-interest financing to small businesses, renters, and homeowners in

regions affected by declared disasters.

        13.    The CARES Act authorized the SBA to provide EIDL loans of up to $2 million to

eligible small businesses experiencing substantial financial disruption due to the COVID- 19

pandemic.

       14.     To obtain an EIDL loan, a qualifying business was required to submit an

application to the SBA and provide information about the business's operations, such as the

number of employees, gross revenues for the 12-month period preceding the disaster, and cost of

goods sold in the 12-month period preceding the disaster. In the case of EIDL loans for COVID-

19 relief, the 12-month period was the 12-month period from January 31 , 20 I 9, to January 31,

2020. The applicant was required to self-ce1tify certain information, including criminal history

questions, and was also required to certify all information in the application was true and correct

to the best of the applicant's knowledge. EIDL loan applications were submitted directly to the

SBA over the Internet, using cloud-based platforms hosted on computer servers in several states.

The amount of the loan, if the application was approved, was determined based, in part, on the

infonnation provided by the applicant about employment, revenue, and cost of goods sold. Any

funds issued under an EIDL were issued directly by the SBA. EIDL advances of up to $10,000

were also available to small businesses within three days of applying for an EIDL. The amount

of any EIDL advance was determined based upon the number of certified employees by the

applicant. EIDLs must be repaid, but EIDL advances do not have to be repaid. EIDL loan




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proceeds could be used for payroll expenses, sick leave, production costs, and business

obligations, such as debts, rent, and mortgage payments.

       15.     After July 1 I, 2020, all EIDL applications were transmitted via interstate wires

from state of origination through servers in Iowa.

       Relevant Financial Institutions and Account

       I 6.    U.S. Bank is a federally insured lender headquartered in Minneapolis, Minnesota.

       17.     Amur Equipment Finance is a commercial business headquartered in Grand

Island, Nebraska, that was an approved SBA lender for the PPP.

B.     THE SCHEME TO DEFRAUD

       18.     Beginning in or about March 2020, and continuing until in or about September

202 1, within the District of Oregon, and elsewhere, defendant FIRESIDE knowingly and with

intent to defraud, devised, participated in, executed, and attempted to execute a material scheme

to defraud the SBA and Amur Equipment Finance as to material matters, and to obtain money

and property owned by and in the custody and control of Amur Equipment Finance and the SBA

by means of material false and fraudulent pretenses, representations, and promises, and the

concealment of material facts.

       I 9.    The fraudulent scheme operated and was carried out, in substance, as follows:

       EIDL Application

       20.     Beginning in or about March 2020, defendant F1RESIDE began submitting EIDL

applications to the SBA attempting to obtain funds for several identified businesses. On or about

February 11 , 2021, defendant FIRESIDE, without authorization, used the identity of G.F. to

submit an appl ication in the name of G .F. and "Fireside Construction Services" to the SBA for

an EIDL.


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        21.     In the EIDL application, defendant FIRESIDE falsely represented that G.F was

the sole owner of Fireside Construction Services; that the business was established on April 30,

2018; that the business had 15 employees; that the business had 2019 gross revenues of

$1,795,005; that in 20 I 9 its cost of goods sold was $245,000; and that all the information in the

application was true and correct under penalty of perjury.

        22.    The EIDL application was related to approximately 8 additional EIDL

applications defendant FIRESIDE submitted.

        23.    The EIDL application targeted funding to a U.S. Bank account ending in 7599, in

the name of G.F. and controlled by defendant FIRESIDE, that was not associated with a business

named Fireside Construction Services.

        24.    The EIDL attempted to secure funding totaling approximately $150,000 but was

declined by the SBA.

        PPP Application

        25.    On or about March 5, 2021, defendant FIRESIDE, without authorization, used the

identity of G.F. and an e-mail address with G.F. 's first initial and last name to initiate an

application in the name of G.F. and "CWE Services" with Amur Equipment Finance for a PPP

Loan.

        26.    On March 19, 2021, defendant FIRESIDE submitted a final PPP loan application

(PPP Application) in the name of G.F. and CWE Services, falsely representing that the company

was established January 1, 2020, had 15 employees, and an average monthly payroll of

$ 116,318.

        27.     In the PPP Application, defendant FIRESIDE, using G.F. 's identity, falsely

represented that the applicant was eligible for the loan, that the proceeds of the loan would be


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used for business-related purposes, that the applicant was in operation on February 15, 2020, and

that the proceeds of the loan would be used to retain workers and maintain payroll.

       28.     In support of the PPP Application, defendant FIRESIDE, using G.F. 's identity,

submitted false documentation including a 2020 IRS Form 1040, Schedule C for CWE Services,

reporting $ 1,598,715.79 in gross receipts or sales and $1,395,817.12 in wages paid.

       29.     In support of the PPP Application, defendant FIRESIDE, using G.F. 's identity,

submitted CWE Services' 2020 IRS Form 941, Employer's Quaiterly Federal Tax Return from

January through March 2020, falsely claiming 15 employees for that quarter and wages, tips, and

other compensation reported of $348,954.28, with $145,513.81 in federal income tax withheld

and total taxes after adjustments reported of $44,425.39. Defendant FIRESIDE falsely and

without authorization digitally signed the Form 941 as G.F. on April 1, 2020.

       30.     In support of the PPP Application, defendant FIRESIDE, using G.F.'s identity,

submitted CWE Services' 2020 IRS Form 940, Employer's Annual Federal Unemployment Tax

Return reporting total payments to all employees as $1,395,817.12.

       31 .    In support of the PPP Application, defendant FIRESIDE, without authorization,

submitted a copy of G.F.'s Oregon Identity Card and a voided check for the U.S. Bank account

ending in 7599 in the name of G.F. and CWE Services, LLC.

       32.     In support of the PPP Application, defendant FIRESIDE submitted fictitious bank

account statements for the U.S. Bank account ending in 7599.

       33.     Defendant FIRESIDE, using G.F.' s identity, certified that the information

provided in the March 19, 2021, PPP Application and all supporting documents and forms was

tnie and correct.




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         34.      In reliance on the false representations and certifications, Amur Equipment

Finance and the SBA approved the application and Amur Equipment funded the PPP loan. On

April 1, 2021 , the SBA wired $290,795 to the U.S. Bank account ending in 7599 in the name of

G.F. and controlled by defendant FIRESIDE.

         Use of PPP Loan Proceeds

         35.      On April 1, 2021, defendant FIRESIDE wrote three consecutive checks to divert

$273,930.38 in PPP proceeds for unauthorized purposes from the U.S. Bank account ending

7599 to accounts owned and controlled solely by her, and/or for her own benefit.

                                            COUNTS 1-2
                                            (Wire Fraud)
                                          (18 u.s.c. § 1343)

         36.      The allegations in paragraphs 1 through 35 of this Indictment are incorporated as

though realleged herein.

         37.      On or about the dates set forth below, in the District of Oregon, and elsewhere, for

purposes of executing the above-described scheme to defraud, defendant FIRESIDE transmitted

and caused the transmission of the following items by means of wire and radio communication in

interstate and foreign commerce:

       Count       Approximate Date                    Interstate Wire Transmission
         1         February 11 , 2021     Submission of EIDL application in the name ofG.F. and
                                          Fireside Construction Services through servers located in
                                          the District of Oregon, and elsewhere.
         2          March 19, 2021        Submission of PPP loan application in the name of G.F.
                                          and CWE Services through servers located in the District
                                          of Oregon, and elsewhere.

         All in violation of 18 U.S.C. § 1343.

/ II

I II
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                                FIRST FORFEITURE ALLEGATION

       38.         Upon conviclion of the wire fraud offense alleged in Count 1 of this Indictment

hereof, defendant shall forfeit to the United States pursuant to 18 U.S.C. § 981 (a)(l )(C) and 28

U.S.C. § 246l(c) any property, real or personal, which constitutes or is derived from proceeds

traceable to the offense, including but not limited to a money judgment for a sum of money equal

to the amount of property involved in or derived from that offense.

       39.         If the above-described forfeitable property, as a result of any act or omission of

defendant FIRESIDE:

             (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 d iminished in value; or

             (e)     has been commingled with other property which cannot be divided without

                     difficulty;

it is the intent of the United States, under 21 U.S .C. § 853(p), as incorporated by 28 U.S.C.

§ 2461 (c), to seek forfeiture of any other property of defendant FIRESIDE up to the value of the

forfeitable property described above.

Dated: September l__, 2026                               A TRUE BILL.




Presented by:

SCOTT E. BRADFORD
United States Attorney


~ ~ ~---
Assistant United States Attorney
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