Complaint and Affidavit in Support of Arrest Warrant — No. 1:24-cr-00361 (Dkt. 1, E.D.N.Y.)

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A complaint and affidavit in support of arrest warrant, to be filed under seal, in United States v. John Bolden, Anthony Carreira, Jacqueline Johnson and Christian McKenzie, Case No. 24 MJ 487, in the U.S. District Court for the Eastern District of New York, filed August 8, 2024 as Document 1 in Case 1:24-cr-00361-DG. It charges conspiracy under 18 U.S.C. § 1349 to defraud the SBA and financial institutions administering the Paycheck Protection Program through fraudulent online PPP loan applications and supporting tax documents. The affidavit is sworn by FBI Special Agent Kenneth F. Hosey before Magistrate Judge Lara K. Eshkenazi and runs 16 pages.

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Case 1:24-cr-00361-DG Document1 Filed 08/08/24 Page 1 of16 PagelD #: 1

RCH:EWS
F, #2022R00718

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
~-------------------------- xX                  TO BE FILED UNDER SEAL

UNITED STATES OF AMERICA                        COMPLAINT AND
                                                AFFIDAVIT IN SUPPORT
          - against -                           OF ARREST WARRANT

JOHN BOLDEN,                                    (18 U.S.C. § 1349)
ANTHONY CARREIRA,
JACQUELINE JOHNSON, and                         Case No. 24 MJ 487
CHRISTIAN MCKENZIE,

                   Defendants.

eee eee ee eee ee ee eee eee ee eee xX

EASTERN DISTRICT OF NEW YORK, SS:

             KENNETH F. HOSEY, being duly sworn, deposes and states that he is a Special

Agent with the Federal Bureau of Investigation (“FBI’’), duly appointed according to law and

acting as such.

             In or about and between March 2020 and October 2022, both dates being

approximate and inclusive, within the Eastern District of New York and elsewhere, the

defendants JOHN BOLDEN, JACQUELINE JOHNSON, ANTHONY CARREIRA and

CHRISTIAN MCKENZIE, together with others, did knowingly and intentionally conspire to

devise a scheme and artifice to defraud the Small Business Administration (“SBA”) and one or

more financial institutions administering the Paycheck Protection Program (“PPP”), and to

obtain money and property from the SBA and said financial institutions by means of materially

false and fraudulent pretenses, representations and promises, and for the purpose of executing

such scheme and artifice, to transmit and cause to be transmitted, by means of wire

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communication in interstate commerce, one or more writings, signs, signals, pictures and sounds,
which offense occurred in relation to, and involved one or more benefits authorized, transported,
transmitted, transferred, disbursed, and paid in connection with, a presidentially declared
emergency under Section 501 of the Stafford Act, to wit: fraudulent online applications for one
or more PPP loans and emails containing supporting tax documentation for one or more PPP
loans, contrary to Title 18, United States Code, Section 1343.

(Title 18, United States Code, Section 1349)

The source of your deponent’s information and the grounds for his belief are as
follows:!

1. I am a Special Agent with the FBI and have been involved in the
investigation of numerous cases involving public corruption, including fraud, bribery and money
laundering. I have been an FBI Special Agent for 29 years. I am familiar with the facts and
circumstances set forth below from my participation in the investigation; my review of the
investigative file; and from reports of other law enforcement officers involved in the
investigation. Based on my conversations with other law enforcement officers and others; my
review of law enforcement records and information provided by others; and my review of

open-source information, I have learned the following, in substance and in part.

2. At all times relevant to this Complaint, unless otherwise indicated:
I. The COVID-19 Pandemic in the United States and the Paycheck Protection Program
3. In or about December 2019, a novel coronavirus, SARS-CoV-2 (the

“coronavirus”), caused outbreaks of the coronavirus disease COVID-19 that have since spread

Because the purpose of this Complaint is to set forth only those facts necessary to

establish probable cause to arrest, I have not described all the relevant facts and circumstances of
which I am aware.

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globally. On or about January 31, 2020, the Secretary of Health and Human Services declared a
national public health emergency under 42 U.S.C. § 247d as a result of the spread of COVID-19
to and within the United States. On or about March 11, 2020, the Director-General of the World
Health Organization characterized COVID-19 as a pandemic. On or about March 13, 2020, the
President of the United States issued Proclamation 9994 declaring a national emergency
beginning on March 1, 2020, as a result of the rapid spread of COVID-19 within the United
States.

4. On or about March 27, 2020, the President signed into law the
Coronavirus Aid, Relief, and Economic Security (“CARES”) Act to provide emergency financial
assistance to the millions of Americans who were suffering adverse 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 for job retention and
certain other expenses through a program referred to as the PPP. In or around April 2020, over
$300 billion in additional PPP funding was authorized by Congress.

5. To obtain a PPP loan, qualifying businesses were required to submit a PPP
loan application, which was signed by an authorized representative of the business. The PPP
loan application required recipient businesses, through an authorized representative, to
acknowledge the program rules and make certain affirmative certifications to establish eligibility
for the PPP loan. For example, in the PPP loan application, recipient businesses, through an
authorized representative, were required to state, among other things, their average monthly
payroll expenses and number of employees. Average monthly payroll expense figures were

used to calculate the amount of money the businesses were eligible to receive under the PPP.

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The recipient businesses were also required to provide certain documentation supporting the
information contained in the PPP loan application.
6. PPP loan proceeds were required to be used by the recipient businesses on

certain permissible expenses, to wit: payroll costs, interest on mortgages, rent and utilities. The
PPP allowed the interest and principal on a PPP loan to be entirely forgiven if the recipient
businesses spent the loan proceeds on these expense items within a designated period of time
after receiving the proceeds and used a certain percentage for payroll costs.

7. The PPP was overseen by the SBA, which had authority over all PPP
loans. Individual PPP loans, however, were issued and approved by private lenders, who
received and processed PPP loan applications and supporting documentation and, following SBA
approval, made loans using the lenders’ own funds.

Il. The Defendants and Their Co-Conspirators

8. The defendant JOHN BOLDEN, a resident of Valley Stream, New York,
was a full-time New York City Police Department (“NYPD”) detective. BOLDEN also served
as a tax preparer who operated and owned partnership interests in three franchise locations for a
tax preparation business (hereinafter, the “Tax Preparation Business”).

9. The defendant ANTHONY CARREIRA, a resident of Staten Island, New
York, was an NYPD detective who, together with BOLDEN, owned partnership interests in one
or more Tax Preparation Business franchise locations.

10. The defendant JACQUELINE JOHNSON, a resident of Valley Stream,
New York, was BOLDEN’s mother.

11. The defendant CHRISTIAN MCKENZIE, a resident of Wheatley Heights,

New York, was BOLDEN’s cousin.

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12. Co-Conspirator-1, an individual whose identity is known to me,” founded
and operated the Tax Preparation Business, which had multiple franchisees and locations
throughout New York and elsewhere, including the ones operated by JOHN BOLDEN and
ANTHONY CARREIRA.

III. The Fraudulent Schemes

A. Overview of Scheme to Defraud

13. | Between approximately May 2020 and October 2022, the defendant JOHN
BOLDEN engaged in a scheme to defraud the SBA and several financial institutions
administering the PPP of federal COVID-19 emergency-relief funds meant for distressed small
businesses by working with his clients and co-conspirators, including ANTHONY CARREIRA,
JACQUELINE JOHNSON, and CHRISTIAN MCKENZIE, to obtain PPP funds to which they
were not entitled. JOHN BOLDEN helped to obtain PPP funds for himself, ANTHONY
CARREIRA, JACQUELINE JOHNSON, CHRISTIAN MCKENZIE, and more than 65
individuals by submitting, or causing to be submitted, online loan applications that contained
materially false and fraudulent information. As part of the scheme to defraud, BOLDEN
prepared fictitious Department of Treasury — Internal Revenue Service (“IRS”) Form Schedule C

documentation (the “Schedule C forms”),? which contained materially false and fraudulent

As described in greater detail herein, Co-Conspirator-1 admitted to fraudulently

obtaining PPP loans and conspiring with others, including BOLDEN and CARREIRA, to do the
same. He/she has pleaded guilty to disaster relief fraud and wire fraud conspiracy, in violation
of 18 U.S.C. §§ 1040 and 1349. He/She also admitted to falsifying tax returns for certain prior
tax years. Information provided by Co-Conspirator-1 in connection with this investigation has
proven reliable and has been corroborated by, among other items, bank records, witness
interviews, and electronic messages.

3 A Schedule C form is an IRS form used to report the income or loss from a

business operated as a sole proprietorship.

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information concerning his, his co-conspirators’ and his clients’ places of employment, gross
income, and net income. These Schedule C forms, which accompanied the fraudulent PPP loan
applications, included figures that would make it possible for BOLDEN, his co-conspirators, and
his clients to apply for loan forgiveness without having to submit documentation to support the
fraudulent figures used in the fictitious Schedule C forms.

B. BOLDEN’s Adoption of Scheme to Prepare Fraudulent PPP Loans Devised by
Co-Conspirator-1

14. On or about May 9, 2020, the defendant JOHN BOLDEN received an
email from an individual whose identity is known to the affiant, which attached an audio
recording of a meeting between Co-Conspirator-1 and other tax preparers discussing how to
prepare fraudulent PPP loan applications using fictitious Schedule C forms.* The recording
lasted approximately thirty minutes. During the recording, Co-Conspirator-1 recommended that
meeting participants submit PPP loan applications in amounts less than $20,000 to avoid having
to submit proof the money sought was properly used in order to apply for loan forgiveness. As
Co-Conspirator-1 explained, “We all want the bread, but we also want the loan forgiveness.
That’s the big win.”

15. | Co-Conspirator-1 advised the meeting participants to generate fictitious
Schedule C forms to accompany the fraudulent loan applications. Co-Conspirator-1 offered a
formula for how to compute the exact figures on the Schedule C forms, explaining “whatever
amount you want to get the person as a loan” could be calculated by taking the desired loan
amount, dividing that figure by two-and-a-half, and then multiplying it by twelve to generate a

fictitious figure for net profit to be listed on Line 31 on the Schedule C form. Co-Conspirator-1

4 Unless otherwise indicated, all statements described herein are related in sum and

substance and in part.

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suggested that participants “stagger the number a little bit” to make the requested loan amounts
appear legitimate, instructing them to “get creative” as to what occupation to list for their clients.
Co-Conspirator-1 explained, “If you’re gonna do some fake s[**]t, do plumbing, trucking, you
know what I’m saying, something like that.” Co-Conspirator-1 also suggested that participants
devise “some bulls[**]t name” of the business, such as “Mickey House of Toys.”
Co-Conspirator-1 then explained, “So, let’s say some — let’s say you got somebody give ‘em 20
grand and taxing ‘em 3,000, that person’s gonna walk — 17,000 in his pocket and potentially
have to pay a $4,000 loan back. They walking away with 13 grand free of charge.”

16. During the meeting, Co-Conspirator-1 alluded to the criminal
consequences for the conduct being discussed. Co-Conspirator-1 warned, “Now, I would
suggest, [to] y’all mother[*****]s trying to send me to jail for this paper because all y’alls up in
here on my IP address but, I couldn’t figure out a better way to use it.” Co-Conspirator-1 said
that Co-Conspirator-1 did not want to create an electronic record of his/her involvement in the
scheme to prepare fraudulent PPP loan applications, saying, “I'll take all my money in cash, no
Quick Pays on this.”

C. Fraudulent PPP Loans Submitted in the Names of BOLDEN, CARREIRA,
JOHNSON, and MCKENZIE for Their Personal Benefit

17. Over the ensuing months, the defendant JOHN BOLDEN prepared
fictitious Schedule C forms used in the submission of PPP loan applications in the very manner
suggested by Co-Conspirator-1, sometimes with Co-Conspirator-1’s assistance. As described
below, fraudulent PPP applications were submitted on behalf of JOHN BOLDEN, ANTHONY
CARREIRA, CHRISTIAN MCKENZIE, JACQUELINE JOHNSON and others. MCKENZIE
and JOHNSON also acted as intermediaries who referred multiple clients to BOLDEN for the

submission of fraudulent PPP loans.

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i. JOHN BOLDEN’s Fraudulent PPP Loan Applications

18. On or about May 11, 2020, 1.e., two days after the defendant JOHN
BOLDEN received the recorded conversation described above, Co-Conspirator-1 emailed
BOLDEN a fictitious IRS Form 1040° and fictitious Schedule C form for the 2019 tax year.

The fictitious Form 1040 reported that BOLDEN, whose occupation was listed as a “Police
Officer,” only earned $5,866 in wages in 2019, even though NYPD payroll records and
BOLDEN’s bank statements reflect that he earned in excess of $100,000 in wages from the
NYPD that year. The fictitious Schedule C form purported BOLDEN to have earned $129,583
in gross receipts and $99,764 in net profit from his principal business of “Security Services.”
The address listed for BOLDEN’s “Security Services” business was the address of one of
BOLDEN’s tax preparation franchise locations. The section on the Schedule C form where the
business name was to be listed was left blank.

19. On or about May 18, 2020, a $20,785 PPP loan application was submitted
on JOHN BOLDEN’s behalf. In support of the loan application, an IRS Form 1040 and
Schedule C form exactly matching the ones received from Co-Conspirator-1 were submitted.
Three days after BOLDEN’s PPP loan application was submitted, BOLDEN withdrew $3,000 in
cash from his Municipal Credit Union (“MCU”) bank account. BOLDEN’s PPP loan
application was ultimately approved.

20. On or about February 20, 2021, a second draw PPP loan application in the
amount of $20,782 was submitted on JOHN BOLDEN’s behalf. The loan was approved and the

money was credited to BOLDEN’s MCU bank account. The next day, $15,000 was withdrawn

> An IRS Form 1040 is a tax form used to report federal personal income tax by

United States residents.

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from the account and transferred by bank check to another personal bank account controlled by
BOLDEN.

21. Onor about July 17, 2021, an application was submitted seeking
forgiveness of JOHN BOLDEN’s initial $20,785 PPP loan. The SBA forgave the loan on or
about July 30, 2021.

i. ANTHONY CARREIRA’s Fraudulent PPP Loan Applications

22. On or about May 17, 2020, Co-Conspirator-1 emailed JOHN BOLDEN
bearing subject line “Anthony.” The email did not contain a message but attached a Schedule C
form purporting ANTHONY CARREIRA to have earned $108,969 in gross receipts and $97,453
in net income in the principal business or profession of “Armed Security.” The space for the
name of CARREIRA’s business was left blank. The business address listed on the Schedule C
form was CARREIRA’s residence. NYPD records indicate that CARREIRA earned regular and
overtime wages throughout 2019 in excess of $100,000. These records also indicate that
CARREIRA was approved for off-duty employment to operate an ATM business, but not armed
security.

23. That day, JOHN BOLDEN forwarded Co-Conspirator-1’s email and the
attached forms to ANTHONY CARREIRA. On or about the following day, a PPP loan
application for $20,302 was submitted on CARREIRA’s behalf. The application listed an
average monthly payroll of $8,121 and a single employee for the unidentified company. In
support of the loan application, a Schedule C form exactly matching the one received from Co-
Conspirator-1 was submitted.

24. The loan was approved. On or about May 20, 2020, $20,302 was credited

to ANTHONY CARREIRA’s personal bank account. That day, CARREIRA sent $4,000 via

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Zelle to JOHN BOLDEN’s bank account at MCU. The following day, BOLDEN made a
$3,000 cash withdrawal from his MCU bank account.

25. On or about February 22, 2021, ANTHONY CARREIRA placed a call to
the recorded customer service line for the entity that processed CARREIRA’s PPP loan. During
the call, CARREIRA indicated that he would like to confirm that no additional documents were
needed to apply for a second draw PPP loan. The representative informed CARREIRA that he
had only uploaded a Schedule C form but was required to submit his entire 2019 tax return
documentation. Shortly thereafter, a fictitious IRS Form 1040 was submitted on CARREIRA’s
behalf, which did not reflect his occupation as an NYPD detective or list the wages he earned
from the NYPD. This time, the fictitious Schedule C form submitted with the application—
which contained the same fraudulent figures for gross income and net income purportedly earned
by CARREIRA in 2019—listed the name of his business as “Anthony Carreira.”"° CARREIRA
placed a second recorded call to the PPP loan processing entity’s customer service line a few
days later to confirm that he had submitted all the necessary tax documents to apply for a second
draw PPP loan.

26. On or about March 15, 2021, a second draw PPP loan application in the
amount of $20,302 was submitted on ANTHONY CARREIRA’s behalf. The application was

electronically signed by CARREIRA. The loan application included the same Schedule C form

6 The tax preparer listed on the IRS Form 1040 was ANTHONY CARREIRA’s
spouse, who also worked with JOHN BOLDEN as a tax preparer at one of their Tax Preparation
Business franchise locations. A PPP loan application on behalf of CARREIRA’s spouse was
also submitted in the amount of $20,099, which attached a fictitious Schedule C received from
BOLDEN listing her gross income as $109,743 and net income as $96,477. After his spouse’s
PPP loan was approved, CARREIRA paid BOLDEN $3,000 via Zelle. CARRIERA’s spouse
successfully applied for a second draw PPP loan the following year, after which $4,000 in cash
was withdrawn from her joint bank account shared with CARREIRA.

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received from BOLDEN and Co-Conspirator-1. The loan was approved. Approximately two
days after the loan proceeds were received, $4,000 in cash was withdrawn from CARREIRA’s
bank account.

ii. JACQUELINE JOHNSON’s Fraudulent PPP Loan Applications

27. On or about May 12, 2020, Co-Conspirator-1 emailed JOHN BOLDEN
with subject line “Jacqueline.” The email did not include a message but attached a document
titled “2019 Tax Return Documents (JOHNSON JACQUELINE).pdf.” According to the
attached federal tax return, IRS Form 1040, JACQUELINE JOHNSON, whose occupation was
listed as a “LABORER,” earned $24,767 in wages in 2019 but over $169,000 in total income.
According to the Schedule C form accompanying the tax return, JOHNSON earned $122,301 in
gross receipts as a “Beautician” for her purported business “Hair by Jacqueline.” Notably, in or
about June 2020 (i.e., approximately one month later), JOHNSON submitted a credit card
application to HSBC Bank in which she listed her “present employer” as “retired.””, BOLDEN
and JOHNSON’s residence, an address located in Valley Stream, New York, was listed on both
the IRS Form 1040 and Schedule C form as JOHNSON’s business address. BOLDEN and
JOHNSON’ residence is a two-family house.

28. On or about May 13, 2020, a PPP loan was submitted in the amount of
$20,318 on behalf of “Hair by Jacqueline.” The application was electronically signed by
JACQUELINE JOHNSON. The loan application included the same IRS Form 1040 and
Schedule C form received by JOHN BOLDEN. The PPP loan was approved.

29. On or about March 10, 2021, a second draw PPP loan application was
submitted in the same amount of $20,318 and also on behalf of “Hair by Jacqueline.” As

before, the application was electronically signed by JACQUELINE JOHNSON and attached the

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same 2019 Form 1040 and Schedule C form that were submitted with JOHNSON’s initial PPP
loan application. The PPP loan was approved.

30. JACQUELINE JOHNSON successfully applied for loan forgiveness for
both loans.

iv. Defendant CHRISTIAN MCKENZIE’s Fraudulent PPP Loan

31. On or about May 28, 2020, after CHRISTIAN MCKENZIE sent JOHN
BOLDEN multiple emails with his personal and banking information, BOLDEN emailed
MCKENZIE attaching a fictitious Schedule C, which purported MCKENZIE to have operated
“Chris Kicks” and earned $118,698 in gross receipts and $97,067 in net profit during 2019 in his
profession as a “sneaker salesman.”

32. On or about May 28, 2020, a $20,222 PPP loan was submitted on
CHRISTIAN MCKENZIE’s behalf. The application was electronically signed by MCKENZIE.
The loan application included the same fictitious Schedule C prepared by JOHN BOLDEN.

The loan was approved. On or about June 1, 2020, $20,222 was deposited in MCKENZIE’s
bank account. MCKENZIE withdrew $4,000 in cash that day.

33. On or about February 14, 2021, a second draw PPP loan application in the
amount of $20,220 was submitted on CHRISTIAN MCKENZIE’s behalf. The application was
electronically signed by MCKENZIE. The documents submitted in connection with the loan
application included an IRS Form 1099 Miscellaneous,’ which purported MCKENZIE to have
earned $118,698 in non-employee compensation from a footwear business located on Long

Island, New York. The name of the business listed in the IRS Form 1099 Miscellaneous was

7 An IRS Form 1099 Miscellaneous is used to report payments made in the course

of a trade or business to another person or business who is not an employee.

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not “Chris Kicks.” The loan was approved. On or about February 17, 2021, $20,220 was

credited to MCKENZIE’s bank account. MCKENZIE withdrew $4,000 in cash two days later.
34.  Onor about July 28, 2021, an application seeking forgiveness of

CHRISTIAN MCKENZIF’s initial PPP loan was received and subsequently approved.

D. MCKENZIE and JOHNSON Acted as Intermediaries Who Referred Clients to
BOLDEN For the Submission of Fraudulent PPP Loans

35. Defendants CHRISTIAN MCKENZIE and JACQUELINE JOHNSON
acted as intermediaries who referred multiple clients to JOHN BOLDEN.

36. For example, in or about June 2020, Individual-1, an individual whose
identity is known to the affiant, was referred to CHRISTIAN MCKENZIE and JOHN BOLDEN
for the purpose of obtaining a fraudulent PPP loan. On or about June 4, 2020, Individual-1
texted MCKENZIE his/her email address, bank statement, photo identification, and social
security number. MCKENZIE emailed that information to BOLDEN the following day. On or
about June 6, 2020, BOLDEN emailed Individual-1, copying MCKENZIE, with instructions on
how to apply for a PPP loan. The email attached a fictitious Schedule C form purporting that
Individual-1 was a “barber” who worked at an entity called “Fine Cuts” and earned $117,990 in
gross income and $99,385 in net income. Individual-1 did not work as a barber or for Fine Cuts.
Nor did Individual-1 earn the income listed in the Schedule C form prepared by BOLDEN.

37. Acting on JOHN BOLDEN’s instructions, Individual-1 applied for and
received a PPP loan in the amount of $20,705. The Schedule C form attached to Individual-1’s
application was identical to the one received from BOLDEN. In fact, the metadata information
for the fictitious Schedule C attached to Individual-1’s fraudulent PPP loan application listed
BOLDEN as the author of the document. On or about September 8, 2021, Individual-1 applied

for loan forgiveness, which was approved.

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38. Notably, in or about and between June 5, 2020 and June 7, 2020 (ite., the

two-day period when Individual-1 received the fictitious Schedule C form described above),

JOHN BOLDEN emailed Schedule C forms to the following thirteen individuals whose

identities are known to the affiant. These Schedule C forms were prepared by BOLDEN ina

similar fashion described by Co-Conspirator-1 above and include similar figures for gross and

net income. The business addresses associated with the purported businesses listed on the PPP

loan applications all appear to be residential, non-commercial locations. The names starred

below indicate that CHRISTIAN MCKENZIE served as a middleman for those individuals’

applications.
Name Listed Gross | Listed Net | Listed Listed Business Name
Income Income Profession
Individual-2* | $117,120 $97,960 Tutoring services | Tutoring by [Individual-2]
Individual-3* | $118,015 $97,315 Barber [Individual-3’s] Haircuts
Individual-4 $120,120 $98,120 Trucking CJS Express Transport
Individual-5 $118,025 $95,733 Cosmetic Golden Glow Tans
Individual-6 $118,032 $104,532 Taxi [Individual-6’s] Rides
Individual-7* $117,850 $96,652 Hair Care Sweet Hair
Individual-8* | $104,870 $96,570 Ridesharing [Individual-8]
Service
Individual-9* | $107,903 $96,403 Rudolph Austin [Individual-9]
Individual-10* | $116,030 $96,800 Barber Finest Hair
Individual-11* | $105,980 $96,600 Taxi [Individual-1 1]
Individual-12* | $115,530 $95,955 Haircare [Individual-12]
Individual-13 $108,306 $96,011 Taxi [Individual-13’s] car service
Individual-14* | $115,090 $95,243 Animal care [Individual-14’s] dog walking

39. © JACQUELINE JOHNSON likewise referred multiple clients to JOHN

BOLDEN for the preparation of fraudulent PPP loans.

40. For example, on or about June 5, 2020, JACQUELINE JOHNSON

received an email from a family member attaching a driver’s license and bank statements for


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Individual-15, an individual whose identity is known to the affiant. JOHNSON subsequently
forwarded the email to JOHN BOLDEN. Days later, a PPP loan application in the amount of
$20,101 was submitted in the name of a company called “May and June.” The application listed
the point of contact as Individual-15, and the listed business address was the same one that
appeared on Individual-15’s driver license. In support of the loan application, a Schedule C
form was submitted, which falsely purported Individual-15 to have served as an “artist” who
earned $121,087 in gross receipts and $96,487 in net income. Although Individual-15 operated
a business called “May and June,” the company had only earned approximately $2,000 in
revenue.

Al. The PPP loan was approved. On or about June 19, 2020, $20,101 was
credited to Individual-15’s bank account. Individual-15 then wired $4,000 to JACQUELINE
JOHNSON.

42. On or about June 11, 2020, JOHNSON sent an email to Individual-16, an
individual whose identity is known to the affiant, instructing Individual-16 to log onto a PPP
lender’s website using the username and password provided in the email and “upload the
attached document.” Attached to the email was a Schedule C form purporting Individual-16 to
have operated a business called “Financial Literacy” and earned $118,090 in gross receipts and
$95,430 in net income. Individual-16 did not in fact earn the income reflected in the Schedule C
or operate the business listed therein. A PPP loan application in the name of “Financial
Literacy” was submitted, but it was denied. JOHNSON subsequently demanded payment from
Individual-16.

43. In or around October 2022, which was shortly after the FBI interviewed

multiple subjects of the government’s investigation, JACQUELINE JOHNSON left a voicemail

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message with Individual-16 informing him/her that he/she should have received something in the
mail. As JOHNSON promised, Individual-16 was mailed a copy of the Schedule C form
submitted with Individual-16’s PPP loan application along with a document instructing
Individual-16 to sign a form, which read in part, “We are preparing this tax documents and any
additional documents based solely on the information we obtained from the taxpayer.”
Individual-16 was directed to mail the completed form to a post office box controlled by JOHN
BOLDEN and JOHNSON.

WHEREFORE, your deponent respectfully requests that the defendants JOHN
BOLDEN, JACQUELINE JOHNSON, ANTHONY CARREIRA, and CHRISTIAN
MCKENZIE be dealt with according to law.

/s/ Kenneth F. Hosey

KENNETH F. HOSEY
Special Agent, Federal Bureau of Investigation

Sworn to before me this
_8 day of August, 2024

THE HONORABLE LARA K(ESHKENAZI
UNITED STATES MAGISTRATE JUDGE
EASTERN DISTRICT OF NEW YORK

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