Information — United States v. Wallace Ford, Adiana Pierre, and Gardy Alexandre (D. Mass.)

Record facts

U.S. District Court, District of Massachusetts · No. 1:24-cr-10007-MJJ · Doc. 38 · 2024-01-16 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 
UNITED STATES OF AMERICA 
v. 
WALLACE FORD, ADIANA PIERRE, 
and GARDY ALEXANDRE, 
 Defendants 
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Criminal No. 
Violations: 
Count One: Conspiracy to Commit Wire Fraud 
(18 U.S.C. § 1349) 
Count Two: Conspiracy to Engage in Unlawful 
Monetary Transactions 
(18 U.S.C. § 1956(h)) 
Wire Fraud Forfeiture Allegation: 
(18 U.S.C. § 981(a)(1)(C) and 
28 U.S.C. § 2461(c)) 
Money Laundering Forfeiture Allegation: 
(18 U.S.C. § 982(a)(1)) 
INFORMATION 
At all times relevant to this Information: 
General Allegations 
1.
Defendant WALLACE FORD (“FORD”) lived in Palm Beach County, Florida.
FORD and his spouse purported to operate two Florida companies, Text Savvy, LLC (“Text 
Savvy”) and Our Virtual Services Inc. (“OVS”).  
2.
Defendant ADIANA PIERRE (“PIERRE”) lived in Palm Beach County, Florida.
3.
Defendant GARDY ALEXANDRE (“ALEXANDRE”) lived in Palm Beach
County, Florida.  ALEXANDRE purported to operate Palm Beach Community House Inc. 
(“PBCH”), a Florida not-for-profit corporation. 
24cr10007
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4. 
Kabbage Inc. (“Kabbage”) was a company based in California that facilitated 
small-business lending. 
5. 
BlueVine was a company based in California.  BlueVine and several lenders, 
including Celtic Bank and Cross River Bank (together, “BlueVine”), partnered to originate and 
disburse loans. 
6. 
The United States Small Business Administration (“SBA”) was an agency of the 
executive branch of the United States government.  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.  As part of this effort, 
the SBA enabled and provided for loans, guaranteed by the government, through banks, credit 
unions, and other lenders. 
The Paycheck Protection Program 
7. 
The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was a federal 
law enacted in March 2020 that was designed to provide emergency financial assistance to 
Americans suffering economic harm as a result of the COVID-19 pandemic.  Among other things, 
the CARES Act provided funding for forgivable loans to small businesses for job retention and 
certain other expenses through the Paycheck Protection Program (“PPP”).   
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 toward payroll expenses. 
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9. 
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 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.  One such 
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 
also required to state, among other things, its (a) average monthly payroll expenses and (b) number 
of employees.  Lenders used these figures to calculate the amount of money the small business 
was eligible to receive under the PPP.  The applicant was also required to provide documentation 
showing its payroll expenses.  
10. 
Participating financial institutions, including Kabbage and BlueVine, received and 
processed PPP loan applications.  If a PPP loan application was approved, the participating 
financial institution funded the PPP loan using its own monies, which were guaranteed by the 
SBA. 
Overview of the Wire Fraud Conspiracy 
11. 
Between in or about May 2020 and in or about August 2020, in the District of 
Massachusetts, the Southern District of Florida, and elsewhere, FORD, PIERRE, and 
ALEXANDRE conspired with each other and others to obtain PPP loans for dozens of borrowers 
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by submitting fraudulent PPP applications.  The applications falsely inflated the borrowers’ 
employee counts and payroll expenses in order to obtain larger PPP loans. 
Object and Purposes of the Wire Fraud Conspiracy 
12. 
The object of the conspiracy was to commit wire fraud by submitting fraudulent 
applications on behalf of PPP borrowers.  The purposes of the conspiracy were to make money 
and to conceal the submission of fraudulent PPP applications from PPP lenders, the SBA, and law 
enforcement authorities. 
Manner and Means of the Wire Fraud Conspiracy 
13. 
Among the manner and means by which FORD, PIERRE, ALEXANDRE, and 
others carried out the wire fraud conspiracy were the following: 
a. 
Recruiting individuals to apply for PPP loans on behalf of their businesses, 
non-profits, or sole proprietorships;  
b. 
Collecting articles of incorporation, bank statements, tax returns, copies of 
checks and utilities bills, and other documents from the borrowers;  
c. 
Electronically preparing PPP applications on behalf of borrowers with 
Kabbage, BlueVine, and other PPP lenders;  
d. 
Making false representations on PPP applications regarding the borrowers’ 
employee counts and average monthly payroll expenses, for the purpose of securing loan amounts 
to which the borrowers were not entitled;   
e. 
Creating false tax documents, including IRS Forms W-3 and 1040, that 
supported the false payroll expenses claimed in the PPP applications;  
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f. 
Causing borrowers to sign and certify the fraudulent PPP applications 
electronically with Kabbage, BlueVine, and other PPP lenders;  
g. 
Causing Kabbage, BlueVine, and other PPP lenders to fund the fraudulent 
PPP loans by interstate wire; and  
h. 
Communicating regarding the status of fraudulent applications. 
14. 
In this fashion, FORD, PIERRE, ALEXANDRE, and others obtained at least 27 
fraudulent PPP loans totaling approximately $7 million for themselves and other borrowers. 
Acts in Furtherance of the Wire Fraud Conspiracy 
15. 
On various dates between in or about May 2020 and in or about August 2020, 
FORD, PIERRE, ALEXANDRE, and others committed and caused to be committed the following 
acts, among others, in furtherance of the wire fraud conspiracy. 
Dessaps Loan 
a. 
On or before June 2, 2020, ALEXANDRE sent PIERRE a photograph of 
the driver’s license of a Massachusetts resident, Bill Dessaps (“Dessaps”), the Employer 
Identification Number (EIN) for Dessaps’s used car dealership, and a copy of Dessaps’s license to 
operate a used articles business. 
b. 
PIERRE emailed these materials to FORD and told FORD, “Push for 900k 
His net worth is 2 million per year!” 
c. 
On or about June 3, 2020, ALEXANDRE exchanged phone calls and text 
messages with Dessaps. 
d. 
On or about June 4, 2020, FORD electronically submitted a PPP application 
to Kabbage on behalf of Dessaps.  FORD sought $836,800 in PPP funds for Dessaps’s business.  
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In the application, FORD falsely claimed that Dessaps’s business had 40 employees and an average 
monthly payroll of $334,720. 
e. 
In support of Dessaps’s application, FORD created a purported copy of a 
2019 Form W-3 (Transmittal of Wage and Tax Statements) for Dessaps’s business, which falsely 
indicated that the business’s gross payroll expenses in 2019 were $3,840,000. 
 
Mathurin Loan 
f. 
On or about June 9, 2020, FORD electronically submitted a PPP application 
to Kabbage on behalf of a Massachusetts resident and purported owner of a warehouse and cargo 
delivery business, Wens Mathurin (“Mathurin”).  FORD sought $313,852 in PPP funds for 
Mathurin’s business.  In the application, FORD falsely claimed that Mathurin’s business had 25 
employees and an average monthly payroll of $125,541. 
g. 
In support of Mathurin’s application, FORD created a purported copy of a 
2019 Form W-3 for Mathurin’s business, which falsely indicated that the business’s gross payroll 
expenses in 2019 were $1,440,000. 
h. 
Between June 13, 2020 and June 17, 2020, ALEXANDRE exchanged 
several phone calls and text messages with Mathurin. 
i. 
On or about June 23, 2020, FORD sent PIERRE a spreadsheet listing 
various PPP borrowers and their application statuses, including Dessaps and Mathurin. 
Borrower 3 Loan 
j. 
On or about June 9, 2020, FORD electronically submitted a PPP application 
to Kabbage on behalf of a Florida resident and purported owner of a private transportation business 
(“Borrower 3”).  FORD sought $600,000 in PPP funds for Borrower 3’s business.  In the 
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application, FORD falsely claimed that Borrower 3’s business had 25 employees and an average 
monthly payroll of $240,000. 
Object and Purposes of the Unlawful Monetary Transactions Conspiracy 
16. 
The object of the conspiracy was to engage in unlawful monetary transactions with 
the proceeds of the wire fraud conspiracy.  The purposes of the conspiracy were to make money 
and to conceal the proceeds of the wire fraud conspiracy from PPP lenders, the SBA, and law 
enforcement authorities. 
Manner and Means of the Unlawful Monetary Transactions Conspiracy 
17. 
Among the manner and means by which FORD, PIERRE, ALEXANDRE, and 
others carried out the unlawful monetary transactions conspiracy were the following: 
a. 
Collecting as kickbacks between 10 and 20 percent of the amount of the 
PPP loans the defendants secured for the borrowers; 
b. 
Using shell companies or dormant entities, including Text Savvy, OVS, and 
PBCH, to receive borrowers’ kickback payments; and  
c. 
Communicating regarding the status of fraudulent kickbacks owed. 
In this fashion, FORD, PIERRE, and ALEXANDER received more than $1 million in borrowers’ 
kickback payments as detailed below. 
Defendant 
Kickbacks Received 
FORD 
$528,122 
PIERRE 
$406,772 
ALEXANDER 
$143,760 
Total 
$1,078,654 
 
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Acts in Furtherance of the Unlawful Monetary Transactions Conspiracy 
18. 
On various dates between in or about May 2020 and in or about August 2020, 
FORD, PIERRE, ALEXANDRE, and others committed and caused to be committed the acts 
below, among others, in furtherance of the unlawful monetary transactions conspiracy.   
Dessaps Kickbacks 
a. 
On or about June 9 and June 12, 2020, respectively, after Kabbage had 
disbursed $836,800 in fraudulent loan proceeds to Dessaps, Dessaps sent ALEXANDRE (through 
PBCH) two checks totaling $28,000 as kickbacks for obtaining the fraudulent loan. 
b. 
On or about June 15 and June 18, 2020, ALEXANDRE issued checks 
totaling $21,000 to FORD’s company, Text Savvy, as kickbacks for obtaining the fraudulent loan 
for Dessaps. 
Mathurin Kickbacks 
c. 
On or about June 17, 2020, after Kabbage disbursed $313,852 in fraudulent 
loan proceeds to Mathurin’s business, Mathurin sent ALEXANDRE (through PBCH) four checks 
totaling $62,760 as kickbacks for obtaining the fraudulent loan. 
d. 
Upon receiving these payments from Mathurin, ALEXANDRE purchased 
a cashier’s check for $30,000 payable to Text Savvy. 
Borrower 3 Kickbacks 
e. 
On or about June 17, 2020, after Kabbage disbursed $600,000 in fraudulent 
loan proceeds to Borrower 3’s business, Borrower 3 sent both PIERRE and FORD (through Text 
Savvy) cashier’s checks for $60,000 as kickbacks for obtaining the fraudulent loan. 
 
 
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COUNT ONE 
Conspiracy to Commit Wire Fraud 
(18 U.S.C. § 1349) 
 
The United States Attorney charges: 
 
19. 
The United States Attorney re-alleges and incorporates by reference paragraphs 1 
through 18(e) of this Information.  
20. 
From at least as early as May 2020 through in or about August 2020, in the District 
of Massachusetts, the Southern District of Florida, and elsewhere, the defendants, 
WALLACE FORD, 
ADIANA PIERRE, and 
GARDY ALEXANDRE, 
 
conspired with each other and others known and unknown to the United States Attorney to commit 
wire fraud, that is, having devised and intending to devise a scheme and artifice to defraud and to 
obtain money and property by means of materially false and fraudulent pretenses, representations 
and promises, to transmit and cause to be transmitted, by means of wire communications in 
interstate and foreign commerce, writings, signs, signals, pictures and sounds, to wit, fraudulent 
applications for PPP loans, for the purpose of executing the scheme to defraud, in violation of Title 
18, United States Code, Section 1343. 
All in violation of Title 18, United State Code, Section 1349. 
 
 
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COUNT TWO 
Conspiracy to Engage in Unlawful Monetary Transactions 
(18 U.S.C. § 1956(h)) 
 
The United States Attorney further charges: 
 
21. 
The United States Attorney re-alleges and incorporates by reference paragraphs 1 
through 18(e) of this Information. 
22. 
From at least as early as May 2020 through in or about August 2020, in the District 
of Massachusetts, the Southern District of Florida, and elsewhere, the defendants, 
WALLACE FORD, 
ADIANA PIERRE, and 
GARDY ALEXANDRE, 
 
conspired with each other and others known and unknown to the United States Attorney to 
knowingly engage in monetary transactions in criminally derived property of a value greater than 
$10,000, where such property was derived from specified unlawful activity, that is, conspiracy to 
commit wire fraud, in violation of Title 18, United States Code, Section 1343, as charged in Count 
One of this Information, in violation of Title 18, United States Code, Section 1957. 
All in violation of Title 18, United States Code, Section 1956(h). 
 
 
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WIRE FRAUD FORFEITURE ALLEGATION 
(18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c)) 
 
The United States Attorney further alleges: 
 
 
23. 
Upon conviction of the offense in violation Title 18, United States Code, Section 
1349, set forth in Count One, each of the defendants, 
WALLACE FORD, 
ADIANA PIERRE, and 
GARDY ALEXANDRE, 
 
shall forfeit to the United States, pursuant to Title 18, United States Code, Section 981(a)(1)(C), 
and Title 28, United States Code, Section 2461(c), any property, real or personal, which 
constitutes or is derived from proceeds traceable to the offense.  The property to be forfeited 
includes, but is not limited to, the following assets: 
a. A Porsche Macan with VIN WP1AA2A52JLB08044, registered to ADIANA 
PIERRE and seized on January 25, 2023 from Lookout Mountain, TN;  
 
b. $696,243 in United States currency, to be entered in the form of an Order of 
Forfeiture (Money Judgment) against WALLACE FORD; 
 
c. $427,605 in United States currency, to be entered in the form of an Order of 
Forfeiture (Money Judgment) against ADIANA PIERRE; and 
 
d. $443,760 in United States currency, to be entered in the form of an Order of 
Forfeiture (Money Judgment) against GARDY ALEXANDRE. 
 
24. 
If any of the property described in Paragraph 23, above, as being forfeitable 
pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United States Code, 
Section 2461(c), as a result of any act or omission of a defendant -- 
a. cannot be located upon the exercise of due diligence; 
 
b. has been transferred or sold to, or deposited with, a third party; 
 
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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; 
 
it is the intention of the United States, pursuant to Title 28, United States Code, Section 2461(c), 
incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any other property 
of that defendant up to the value of the property described in Paragraph 23 above.  
All pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United 
States Code, Section 2461(c). 
 
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MONEY LAUNDERING FORFEITURE ALLEGATION  
(18 U.S.C. § 982(a)(1)) 
 
The United States Attorney further alleges: 
25. 
Upon conviction of the offense in violation of Title 18, United States Code, Section 
1956(h), set forth in Count Two, each of the defendants,  
WALLACE FORD, 
ADIANA PIERRE, and 
GARDY ALEXANDRE, 
 
shall forfeit to the United States, pursuant to Title 18, United States Code, Section 982(a)(1), any 
property, real or personal, involved in such offense, and any property traceable to such property.  
The property to be forfeited includes, but is not limited to, the following assets: 
a. A Porsche Macan with VIN WP1AA2A52JLB08044, registered to ADIANA 
PIERRE and seized on January 25, 2023 from Lookout Mountain, TN;  
 
b. $696,243 in United States currency, to be entered in the form of an Order of 
Forfeiture (Money Judgment) against WALLACE FORD; 
 
c. $427,605 in United States currency, to be entered in the form of an Order of 
Forfeiture (Money Judgment) against ADIANA PIERRE; and 
 
d. $443,760 in United States currency, to be entered in the form of an Order of 
Forfeiture (Money Judgment) against GARDY ALEXANDRE. 
  
26. 
If any of the property described in Paragraph 25, above, as being forfeitable 
pursuant to Title 18, United States Code, Section 982(a)(1), 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; 
 
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d.  
has been substantially diminished in value; or 
 
e. has been commingled with other property which cannot be divided without 
difficulty; 
 
it is the intention of the United States, pursuant to Title 18, United States Code, Section 982(b), 
incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any other property 
of that defendant up to the value of the property described in Paragraph 25 above.  
All pursuant to Title 18, United States Code, Section 982(a)(1).  
 
JOSHUA S. LEVY 
 
 
 
 
 
 
 
Acting United States Attorney 
 
 
 
 
 
 
 
By: 
/s/ David M. Holcomb  
 
 
 
 
 
 
 
 
DAVID M. HOLCOMB 
 
 
 
 
 
 
 
Assistant U.S. Attorney 
 
 
Date: January 16, 2024 
 
 
 
 
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