Court filing

Criminal information — United States v. Takandryia Latrice Cage (E.D. Pa.) (E.D. Pa.)

Filed February 9, 2022 in U.S. v. Cage, the only filing from this case in the archive.

Record facts

Court	U.S. District Court for the Eastern District of Pennsylvania
Filed	2022-02-09

U.S. District Court for the Eastern District of Pennsylvania · No. 2:22-cr-00039-JMG · Doc. 1 · 2022-02-09 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA
:
CRIMINAL NO.

v.
:
VIOLATIONS:

18 U.S.C. § 1349 (conspiracy to commit mail
TAKANDRYIA LATRICE CAGE
:
fraud – 1 count)

18 U.S.C. § 1344 (bank fraud – 1 count)

:
18 U.S.C. § 1343 (wire fraud – 3 counts)

:
Notice of Forfeiture

I N F O R M A T I O N

COUNT ONE

THE UNITED STATES ATTORNEY CHARGES THAT:

At all times relevant to this Information:
1.
Cisco Systems, Inc. (“Cisco”) was a corporation based in San Jose,
California specializing in providing internet networking hardware and software for business,
government, and individuals. Cisco’s core development areas were in switching and routing,
which enabled Cisco customers to communicate through the use of the World Wide Web.
2.
Cisco manufactured, sold, and supported computer networking equipment
on a global scale. Cisco supported its products through two means: (a) a Limited Lifetime
Hardware Warranty Program and Enhanced Limited Lifetime Warranty Program offered with
Cisco hardware and software (hereinafter a “Cisco Warranty”); and (b) a more comprehensive
suite of support offered to customers for a fee (called and referred to by Cisco as “SMARTnet”
Service).
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 1 of 39

3.
The Cisco Warranty and SMARTnet Service were not transferrable. That
means that any purchase of used or secondary-market Cisco equipment was not covered by the
Cisco Warranty or SMARTnet Service even if it was purchased through a Cisco channel partner
or distributor. Before used or secondary-market equipment could be placed under a new support
contract, the requester was required to show proof of a valid software license or pay relicensing
fees and must have had the equipment inspected to confirm that it was in proper working order
and had been maintained appropriately.
4.
When a customer needed technical assistance on a device that was under
Warranty or SMARTnet service, the customer could open a Cisco service request (“SR”) and
report its problem to Cisco in one of the following ways: by telephone, email, or through Cisco’s
website (www.cisco.com).
5.
Cisco maintained Technical Assistance Centers (“TAC”) worldwide to
process these requests for service. All requests for service generated an SR number, which was
used to track the reported problem until it was resolved. Upon creation of the SR, information
about the customer was captured as well as the specific product complaint. Once initiated, the SR
was sent to a Cisco TAC engineer for problem diagnosis and resolution. The TAC engineer
would determine if the customer was entitled to a replacement product under the terms of Cisco's
Limited Warranty Program or SMARTnet service.
6.
If the customer was entitled to a replacement product, TAC would
generate a Return Material Authorization (“RMA”) reference number, initiating the process to
deliver a replacement product to the customer. Under Cisco’s Warranty and SMARTnet Service
Programs, customers could be entitled to advance replacement, meaning that Cisco or one of its
service centers would ship a replacement product to the customer before the customer sent back
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 2 of 39

the faulty part, with the understanding that the faulty part would subsequently be returned to
Cisco upon receipt by the customer of the replacement part. Cisco notified customers who
received advance replacement that they must return the defective product.
7.
Most Cisco warranty replacement products were shipped by Cisco via
commercial interstate carrier Federal Express (“FedEx”) from a Cisco warehouse in either
Roanoke, Texas, or Columbus, Ohio.
8.
Gulfstream Data, LLC (“Gulfstream Data”) of Lenoir City, Tennessee,
was a limited liability company engaged in the reselling of new, used, and refurbished computer
hardware and networking equipment manufactured by Cisco and other companies. Gulfstream
purchased Cisco and other computer networking hardware from individuals and companies, and
resold the hardware. Upon purchasing hardware, Gulfstream Data issued a purchase order
(“P.O.”) number to track and reflect the purchase.
9.
PayPal Holdings Inc. (“PayPal”) was a corporation with its headquarters
in San Jose, California, engaged in the business of operating a worldwide online payment system
that supports online money transfers and serves as an electronic alternative to traditional paper
methods of making payment for goods and services. PayPal operated as a payment processor for
online vendors and auction sites. Individuals and businesses established PayPal accounts that
they could use to make and receive money transfers, including for the purchase or sale of
merchandise or services. These PayPal accounts were typically linked to bank accounts at
financial institutions from which and into which the PayPal customers could transfer funds.
10.
eBay Inc. (“eBay”) was a corporation with its headquarters in San Jose,
California, engaged in the business of electronic commerce. eBay facilitated consumer-to-
consumer and business-to-consumer sales through its website. Individuals and businesses sold
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products through eBay by posting the items to be sold on eBay’s website and offering the items
for sale in either an auction format, a fixed price format, a best offer format, or a combination of
these formats. Sellers could also create eBay “stores” on the eBay website that would allow the
sellers to advertise all of the items they were selling through the eBay website. Purchasers
typically paid for the items they bought on eBay using PayPal.
11.
Defendant TAKANDRYIA LATRICE CAGE maintained a PayPal
account ending in 3089.
12.
Co-conspirator Jerel Andre Williams, charged separately, maintained an
eBay account that was linked to defendant TAKANDRYIA LATRICE CAGE’s PayPal account
ending in 3089.
THE CONSPIRACY

13.
Beginning in or about July 2016 and continuing until in or about January
2018, within the Eastern District of Pennsylvania, the District of Delaware, the Northern District
of Texas, the Western District of Texas, the District of Nevada, the Southern District of
California, and elsewhere, defendant
TAKANDRYIA LATRICE CAGE

conspired and agreed with Jerel Andre Williams to commit offenses against the United States,
that is, to devise a scheme to defraud and obtain money and property by means of materially
false and fraudulent pretenses, representations, and promises, and for the purpose of executing
this scheme knowingly cause to be delivered by mail and commercial interstate carriers,
according to the directions thereon, mail matter in interstate and foreign commerce, in violation
of Title 18, United States Code, Section 1341.
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 4 of 39

MANNER AND MEANS

It was part of the conspiracy that:
14.
Co-conspirator Jerel Andre Williams, charged separately, registered false
domain names, including the false domain name “alphateamcomp.org.”
15.
Co-conspirator Jerel Andre Williams established new email addresses
using false identities, some of which were established using the false domain names, in order to
hide his true identity and mislead Cisco into believing that the email addresses were associated
with other persons who worked for legitimate companies.
16.
Co-conspirator Jerel Andre Williams obtained and ascertained serial
numbers for Cisco computer hardware that neither he nor defendant TAKANDRIYA LATRICE
CAGE owned or possessed.
17.
Co-conspirator Jerel Andre Williams taught defendant TAKANDRYIA
LATRICE CAGE how to establish new email addresses, use false identities and obtain serial
numbers for Cisco computer hardware that neither she nor co-conspirator Williams owned or
possessed.
18.
Defendant TAKANDRYIA LATRICE CAGE obtained cellular phones
(referred to as “burner phones”) that were paired to false names to use to contact Cisco to initiate
and complete false warranty claims.
19.
Defendant TAKANDRYIA LATRICE CAGE and co-conspirator Jerel
Andre Williams contacted Cisco via telephone using burner phones, via email, and via online
chats and initiated false warranty claims by providing legitimate serial numbers for Cisco
products that they did not own or possess, as well as false names, new email addresses they had
created, false shipping addresses, and other false information, and by falsely claiming that they
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and/or the companies they claimed to work for were the owners of the items in question and that
the items were not working properly.
20.
Defendant TAKANDRYIA LATRICE CAGE and co-conspirator Jerel
Andre Williams provided customer service representatives for Cisco with descriptions of the
supposed problems with the items that they claimed were broken that co-conspirator Williams
knew would prevent the customer service representatives from solving the problems through
troubleshooting and would necessarily require the replacement of the supposedly faulty items.
21.
Defendant TAKANDRYIA LATRICE CAGE and co-conspirator Jerel
Andre Williams provided Cisco with addresses at which the fraudulently-obtained replacement
merchandise could be shipped, and caused Cisco to ship via FedEx the computer hardware from
Cisco warehouses to addresses provided by defendant CAGE and co-conspirator Williams.
22.
Defendant TAKANDRYIA LATRICE CAGE personally initiated
approximately 50 false Cisco warranty claims, and assisted co-conspirator Jerel Andre Williams
in initiating others.
23.
Through the submission of false warranty claims and various false
statements, defendant TAKANDRYIA LATRICE CAGE and co-conspirator Jerel Andre
Williams caused Cisco to ship in interstate commerce via commercial interstate carrier at least
approximately 157 warranty replacement products to which they had no legitimate right, each
with a retail value of between approximately $3,693 and approximately $34,500, to addresses
throughout the United States, including addresses in Wynnewood, Pennsylvania, Cherry Hill,
New Jersey, Wilmington, Delaware, Las Vegas, Nevada, Henderson, Nevada, La Jolla,
California, San Diego, California, Arlington, Texas, Dallas, Texas, and Fort Worth, Texas.
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 6 of 39

24.
Defendant TAKANDRYIA LATRICE CAGE and co-conspirator Jerel
Andre Williams tracked the shipments using the FedEx tracking number provided by Cisco, and
often contacted FedEx to change the delivery address to a FedEx store location nearby the false
company address previously provided by defendant CAGE and co-conspirator Williams.
25.
Defendant TAKANDRYIA LATRICE CAGE and co-conspirator Jerel
Andre Williams traveled to the locations, including FedEx store locations, to which they had
instructed Cisco and/or FedEx to deliver the replacement hardware, in order to pick up the
replacement hardware.
26.
Defendant TAKANDRYIA LATRICE CAGE and co-conspirator Jerel
Andre Williams falsely promised Cisco that they would send back the supposedly broken Cisco
hardware, when in fact they never owned the hardware in question and did not ship back the
broken Cisco computer hardware that they had claimed to own.
27.
Co-conspirator Jerel Andre Williams arranged to sell the fraudulently-
obtained Cisco computer hardware to computer resellers, often arranging the sale before
submitting a false warranty claim to Cisco, by falsely representing to the computer resellers that
he already had a particular model of Cisco computer hardware on hand, without disclosing to the
computer resellers that he did not own or possess the item and instead intended to obtain the
computer hardware by fraud. Upon arranging for the sales to computer resellers, co-conspirator
Williams caused the computer resellers to issue Purchase Order (“P.O.”) numbers. If co-
conspirator Williams did not yet possess the items he had agreed to sell as reflected on the P.O.
numbers, co-conspirator Williams submitted false warranty claims to Cisco to obtain the
particular models of computer hardware in question. Then, after obtaining the hardware by fraud
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from Cisco, co-conspirator Williams notified the computer resellers of the serial numbers of the
hardware, and the serial numbers were added to the reseller’s P.O. number.
28.
Co-conspirator Jerel Andre Williams sold most of the fraudulently-
obtained Cisco computer hardware that he obtained during and in furtherance of this scheme to
Gulfstream Data, without disclosing that it had been obtained from Cisco through the submission
of false warranty claims. Co-conspirator Williams shipped fraudulently-obtained Cisco hardware
to Gulfstream Data via commercial interstate carrier, typically FedEx.
29.
Co-conspirator Jerel Andre Williams compensated defendant
TAKANDRYIA LATRICE CAGE for her participation in the scheme by, among other things,
giving her cash, taking her on vacations, giving her gifts, and providing her with money in her
PayPal account ending in 3089 that co-conspirator Williams had generated through his sale of
computer equipment on eBay.
OVERT ACTS
In furtherance of the conspiracy, and to achieve its objects, defendant
TAKANDRYIA LATRICE CAGE and co-conspirator Jerel Andre Williams committed the
following overt acts, among others, in the Eastern District of Pennsylvania and elsewhere:
1.
On or about December 12, 2016, co-conspirator Jerel Andre Williams,
posing as a representative of the company “Relo Systems” of San Bernardino, California, and
using the false name of “Kieth Morrison” and the email address of “relosys@outlook.com,”
submitted a false warranty claim to Cisco and was assigned Cisco SR # 681447437, seeking the
replacement of a supposedly faulty piece of Cisco computer hardware that co-conspirator
Williams falsely claimed to own, namely, a Cisco Model WS-C3850-48F-L.
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2.
On or about December 12, 2016, co-conspirator Jerel Andre Williams,
posing as a representative of the company “Relo Systems” of San Bernardino, California, and
using the false name of “Kieth Morrison” and the email address of “relosys@outlook.com,”
submitted a false warranty claim to Cisco and was assigned Cisco SR # 681444624, seeking the
replacement of a supposedly faulty piece of Cisco computer hardware that co-conspirator
Williams falsely claimed to own, namely, a Cisco Model WS-C3850-48P-L.
3.
On or about December 12, 2016, co-conspirator Jerel Andre Williams
caused Cisco to ship from Roanoke, Texas, to San Bernardino, California, two pieces of Cisco
computer hardware, namely, one new Cisco Model WS-C3850-48F-L, serial number
FCW2043C1PJ, with a retail value of approximately $11,400, and one refurbished Cisco Model
WS-C3850-48P-L, serial number FOC1949X1PM, with a retail value of approximately $6,240,
via FedEx, in response to Cisco SR #s 681447437 and 681444624, respectively.
4.
On or about December 12, 2016, co-conspirator Jerel Andre Williams,
posing as a representative of the company “Smart Tops” of Menifee, California, and using the
false name of “Johnathan Ghram” and the email address of “smarttop1@aol.com,” submitted a
false warranty claim to Cisco and was assigned Cisco SR # 681444396, seeking the replacement
of two supposedly faulty pieces of Cisco computer hardware that co-conspirator Williams falsely
claimed to own, namely, a Cisco Model WS-C3650-48FD-S and a Cisco Model WS-C3650-
48FS-S.
5.
On or about December 12, 2016, co-conspirator Jerel Andre Williams
caused Cisco to ship from Roanoke, Texas, to Menifee, California, two pieces of Cisco computer
hardware, namely, one new Cisco Model WS-C3650-48FD-S, serial number FDO2042E0J6,
with a retail value of approximately $11,900, and one refurbished Cisco Model WS-C3650-
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48FS-S, serial number FDO1919E4C2, with a retail value of approximately $6,240, via FedEx,
in response to Cisco SR # 681444396.
6.
On or about December 13, 2016, co-conspirator Jerel Andre Williams,
posing as a representative of the company “The Hills Group” of San Diego, California, and using
the false name of “Terry Hill” and the email address of “thehills.group@aol.com,” submitted a
false warranty claim to Cisco and was assigned Cisco SR # 681458216, seeking the replacement
of three supposedly faulty pieces of Cisco computer hardware that co-conspirator Williams
falsely claimed to own, namely, two Cisco Model WS-C3750X-48PF-S units and one Cisco
Model WS-C3750X-24U-E.
7.
On or about December 13, 2016, co-conspirator Jerel Andre Williams
caused Cisco to ship from Roanoke, Texas, to San Diego, California, three pieces of Cisco
computer hardware, namely, two new Cisco Model WS-C3750X-48PF-S units, serial numbers
FDO2041F0N3 and FDO2041F1F7, respectively, each with a retail value of approximately
$16,100, and one refurbished Cisco Model WS-C3750X-24U-E, serial number FDO1808R0WZ,
with a retail value of approximately $8,340, via FedEx, in response to Cisco SR # 681458216.
8.
On or about December 14, 2016, co-conspirator Jerel Andre Williams sold
and provided to Gulfstream Data to fulfill P.O. # 5351 the following items, among others, which
were obtained from Cisco through the submission of false warranty claims: (a) the one new
Cisco Model WS-C3850-48F-L, serial number FCW2043C1PJ, shipped to co-conspirator
Williams by Cisco in response to SR #s 681447437; (b) the one refurbished Cisco Model WS-
C3850-48P-L, serial number FOC1949X1PM, shipped to co-conspirator Williams by Cisco in
response to S.R. # 681444624; (c) the one new Cisco Model WS-C3650-48FD-S, serial number
FDO2042E0J6, and one refurbished Cisco Model WS-C3650-48FS-S, serial number
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FDO1919E4C2, shipped to co-conspirator Williams by Cisco in response to SR # 681444396;
and (d) the two Cisco Model WS-C3750X-48PF-S units, serial numbers FDO2041F0N3 and
FDO2041F1F7, respectively, and the one Cisco Model WS-C3750X-24U-E, serial number
FDO1808R0WZ, that Cisco had shipped to co-conspirator Williams in response to Cisco SR #
681458216.
9.
On or about December 20, 2016, co-conspirator Jerel Andre Williams,
posing as a representative of the company “GMX” of Springfield, Pennsylvania, and using the
false name of “Leon Dixon” and the email address of “setupdesign@gmx.com,” submitted a
false warranty claim to Cisco and was assigned Cisco SR # 681496973, seeking the replacement
of a supposedly faulty piece of Cisco computer hardware that co-conspirator Williams falsely
claimed to own, namely a Cisco Model WS-C3750X-48PF-S.
10.
On or about December 20, 2016, co-conspirator Jerel Andre Williams,
posing as a representative of the company “GMX” of Springfield, Pennsylvania, and using the
false name of “Leon Dixon” and the email address of “setupdesign@gmx.com,” submitted a
false warranty claim to Cisco and was assigned Cisco SR # 681492168, seeking the replacement
of a supposedly faulty piece of Cisco computer hardware that co-conspirator Williams falsely
claimed to own, namely, a Cisco Model WS-C3850-48PW-SZ.
11.
On or about December 21, 2016, co-conspirator Jerel Andre Williams,
posing as a representative of the company “GMX” of Springfield, Pennsylvania, and using the
false name of “Leon Dixon” and the email address of “setupdesign@gmx.com,” submitted a
false warranty claim to Cisco and was assigned Cisco SR # 681502880, seeking the replacement
of a supposedly faulty piece of Cisco computer hardware that co-conspirator Williams falsely
claimed to own, namely, a Cisco Model WS-C2960X-48LPD-L.
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12.
On or about December 20, 2016, co-conspirator Jerel Andre Williams
caused Cisco to ship from Roanoke, Texas, to a FedEx store in Wynnewood, Pennsylvania, one
new Cisco Model WS-C3750X-48PF-S, serial number FDO2041F0JQ, with a retail value of
approximately $16,100, and one refurbished Cisco Model WS-C3850-48PW-SZ, serial number
FOC1833X102, with a retail value of approximately $8,700, via FedEx, in response to Cisco SR
#s 681496973 and 681492168, respectively.
13.
On or about December 22, 2016, co-conspirator Jerel Andre Williams
caused Cisco to ship from Roanoke, Texas, to a FedEx store in Wynnewood, Pennsylvania, one
refurbished Cisco Model WS-C2960X-48LPD-L, serial number FOC1951S3ZN, with a retail
value of approximately $4,197, via FedEx, in response to Cisco SR # 681502880.
14.
On or about December 23, 2016, at a FedEx store in Wynnewood,
Pennsylvania, co-conspirator Jerel Andre Williams, posing as “Leon Dixon,” picked up three
pieces of Cisco hardware, serial numbers FDO2041F0JQ, FOC1833X102, and FOC1951S3ZN,
shipped by Cisco in response to Cisco SR #s 681496973, 681492168, and 681502880,
respectively.
15.
On or about December 23, 2016, co-conspirator Jerel Andre Williams sold
and provided to Gulfstream Data to fulfill P.O. # 5374 the three pieces of Cisco hardware, serial
numbers FDO2041F0JQ, FOC1833X102, and FOC1951S3ZN, that had been shipped by Cisco
to co-conspirator Williams in response to the false warranty claims reflected in Cisco SR #s
681496973, 681492168, and 681502880, respectively.
16.
On or about February 21, 2017, defendant TAKANDRYIA LATRICE
CAGE, posing as a representative of the company “Swift Phones” of Monroe, Louisiana, and
using the false name of “Kimberly Johnson” and the email address of
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“swiftphones@protonmail.com,” submitted a false warranty claim to Cisco and was assigned
Cisco SR # 681839660, seeking the replacement of a supposedly faulty piece of Cisco computer
hardware that defendant CAGE falsely claimed to own, namely, a Cisco Model WS-C3850-48U-
L.
17.
On or about February 21, 2017, defendant TAKANDRYIA LATRICE
CAGE caused Cisco to ship from Roanoke, Texas, to a FedEx store in Monroe, Louisiana, a
refurbished Cisco Model WS-C3850-48U-L, serial number FCW2014D05W, with a retail value
of approximately $6,980, via FedEx, in response to Cisco SR # 681839660.
18.
On or about March 7, 2017, co-conspirator Jerel Andre Williams sold and
provided to Gulfstream Data to fulfill P.O. # 5572 the Cisco Model WS-C3850-48U-L, serial
number FCW2014D05W, that was provided by Cisco and shipped to defendant TAKANDRYIA
LATRICE CAGE in response to the false warranty claim SR # 681839660.
19.
On or about March 19, 2017, defendant TAKANDRYIA LATRICE
CAGE, posing as a representative of the company “Sunset Data Network” of Allen, Texas, and
using the false name of “Jerica Stephens” and the email address of “sunsetdatallc@aol.com,”
submitted a false warranty claim to Cisco and was assigned Cisco SR # 681994127, seeking the
replacement of a supposedly faulty piece of Cisco computer hardware that defendant CAGE
falsely claimed to own, namely, a Cisco Model WS-C3750X-24S-S.
20.
On or about March 20, 2017, defendant TAKANDRYIA LATRICE
CAGE, posing as a representative of the company “Sunset Data Network” of Allen, Texas, and
using the false name of “Jerica Stephens” and the email address of “sunsetdatallc@aol.com,”
submitted a false warranty claim to Cisco and was assigned Cisco SR # 681995209, seeking the
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replacement of a supposedly faulty piece of Cisco computer hardware that defendant CAGE
falsely claimed to own, namely, a Cisco Model WS-C3750X-24S-S.
21.
On or about March 20, 2017, defendant TAKANDRYIA LATRICE
CAGE caused Cisco to ship from Roanoke, Texas, to a FedEx store in Allen, Texas, two new
Cisco Model WS-C3750X-24S-S units, serial numbers FDO2034F0FF and FDO2034F0EU,
respectively, each with a retail value of approximately $23,000, via FedEx, in response to Cisco
SR #s 681995209 and 681994127, respectively.
22.
On or about March 20, 2017, co-conspirator Jerel Andre Williams, posing
as a representative of the company “Pivotal Systems” of White Settlement, Texas, and using the
false name of “Alexander Smith” and the email address of “pvtsystems@outlook.com,”
submitted a false warranty claim to Cisco and was assigned Cisco SR # 681999650, seeking the
replacement of a supposedly faulty piece of Cisco computer hardware that co-conspirator
Williams falsely claimed to own, namely, a Cisco Model WS-C3850-24S-S.
23.
On or about March 20, 2017, co-conspirator Jerel Andre Williams caused
Cisco to ship from Roanoke, Texas, to Ft. Worth, Texas, a new Cisco Model WS-C3850-24S-S,
serial number FOC2037U1DE, with a retail value of approximately $12,000, via FedEx, in
response to Cisco SR #s 681999650.
24.
On or about March 20, 2017, co-conspirator Jerel Andre Williams sold
and provided to Gulfstream Data to fulfill P.O. # 5609 the following items, which were obtained
from Cisco through the submission of false warranty claims : (a) the two Cisco Model WS-
C3750X-24S-S units, serial numbers FDO2034F0FF and FDO2034F0EU, respectively, that
Cisco had shipped to defendant TAKANDRYIA LATRICE CAGE in response to Cisco SR #s
681995209 and 681994127, respectively; and (b) the Cisco Model WS-C3850-24S-S, serial
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number FOC2037U1DE, that Cisco had shipped to co-conspirator Williams in response to Cisco
SR #s 681999650.
25.
On or about March 29, 2017, co-conspirator Jerel Andre Williams
arranged to sell to Gulfstream Data two Cisco Model WS-C3850-48P-E units that he did not then
own or possess and was issued P.O. # 5647, intending to thereafter work with defendant
TAKANDRYIA LATRICE CAGE to submit false warranty claims to Cisco in order to receive
those units and then to ship them to Gulfstream Data.
26.
On or about March 30, 2017, defendant TAKANDRYIA LATRICE
CAGE, posing as a representative of the company “Green Networking” of Las Vegas, Nevada,
and using the false name of “Jennifer Lovett” and the email address of
“love.networks@zoho.com,” submitted a false warranty claim to Cisco and was assigned Cisco
SR # 682067447, seeking the replacement of a supposedly faulty piece of Cisco computer
hardware that defendant CAGE falsely claimed to own, namely, a Cisco Model WS-C3850-48P-
E.
27.
On or about March 31, 2017, defendant TAKANDRYIA LATRICE
CAGE, posing as a representative of the company “Green Networking” of Las Vegas, Nevada,
and using the false name of “Jennifer Lovett” and the email address of
“love.networks@zoho.com,” submitted a false warranty claim to Cisco and was assigned Cisco
SR # 682074464, seeking the replacement of a supposedly faulty piece of Cisco computer
hardware that defendant CAGE falsely claimed to own, namely, a Cisco Model WS-C3850-48P-
E.
28.
On or about March 31, 2017, defendant TAKANDRYIA LATRICE
CAGE caused Cisco to ship from Roanoke, Texas, to a FedEx store in Las Vegas, Nevada, one
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new Cisco Model WS-C3850-48P-E, serial number FOC2103X05C, with a retail value of
approximately $21,000, and one refurbished Cisco Model WS-C3850-48P-E, serial number
FOC1936U1T0, with a retail value of approximately $12,600, via FedEx, in response to Cisco
SR #s 682067447 and 682074464, respectively.
29.
On or about April 2, 2017, co-conspirator Jerel Andre Williams sold and
provided to Gulfstream Data to fulfill P.O. # 5647 the two Cisco Model WS-C3850-48P-E, serial
numbers FOC2103X05C and FOC1936U1T0, that were provided by Cisco and shipped to
defendant TAKANDRYIA LATRICE CAGE in response to the false warranty claims SR #s
682067447 and 682074464, respectively.
30.
On or about June 2, 2017, co-conspirator Jerel Andre Williams arranged to
sell to Gulfstream Data one Cisco Model WS-C3850-48F-E unit and one Cisco Model WS-
C3850-48U-S that he did not then own or possess and was issued P.O. # 5810, intending to
thereafter work with defendant TAKANDRYIA LATRICE CAGE to submit false warranty
claims to Cisco in order to receive those units and then to ship them to Gulfstream Data.
31.
On or about June 2, 2017, defendant TAKANDRYIA LATRICE CAGE,
posing as a representative of the company “Global Net Data” of San Antonio Texas, and using
the false name of “Ciara Stevens” and the email address of “t.stevens@gndnow.com,” submitted
a false warranty claim to Cisco and was assigned Cisco SR # 682445714, seeking the
replacement of a supposedly faulty piece of Cisco computer hardware that defendant CAGE
falsely claimed to own, namely a Cisco Model WS-C3850-48F-E.
32.
On or about June 2, 2017, defendant TAKANDRYIA LATRICE CAGE,
posing as a representative of the company “Global Net Data” of San Antonio Texas, and using
the false name of “Ciara Stevens” and the email address of “t.stevens@gndnow.com,” submitted
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 16 of 39

a false warranty claim to Cisco and was assigned Cisco SR # 682445686, seeking the
replacement of a supposedly faulty piece of Cisco computer hardware that defendant CAGE
falsely claimed to own, namely, a Cisco Model WS-C3850-48U-S.
33.
On or about June 2, 2017, defendant TAKANDRYIA LATRICE CAGE
caused Cisco to ship from Roanoke, Texas, to a FedEx store in San Antonio, Texas, one new
Cisco Model WS-C3850-48F-E, serial number FOC2116U21P, with a retail value of
approximately $22,000, and one refurbished Cisco Model WS-C3850-48U-S, serial number
FOC2009U11T, with a retail value of approximately $8,400, via FedEx, in response to Cisco SR
#s 682445714 and 682445686, respectively.
34.
On or about June 5, 2017, at a FedEx store in San Antonio, Texas,
defendant TAKANDRYIA LATRICE CAGE posing as “Ciara Stevens,” picked up two pieces of
Cisco hardware, serial numbers FOC2116U21P and FOC2009U11T, shipped by Cisco in
response to Cisco SR #s 682445714 and 682445686, respectively.
35.
On or after June 5, 2017, co-conspirator Jerel Andre Williams sold and
provided the one new Cisco Model WS-C3850-48F-E, serial number FOC2116U21P, and the
one refurbished Cisco Model WS-C3850-48U-S, serial number FOC2009U11T, that were
provided by Cisco and shipped to defendant TAKANDRYIA LATRICE CAGE in response to
Cisco SR #s 682445714 and 682445686, respectively, to Gulfstream Data to fulfill P.O. # 5810.
36.
On or about August 22, 2017, defendant TAKANDRYIA LATRICE
CAGE, posing as a representative of the company “Dreamworks Dental” of Arlington, Texas,
and using the false name of “Samantha Bucks” and the email address of
“sbucks0054@orthodontist.net” submitted a false warranty claim to Cisco and was assigned
Cisco SR # 682925241, seeking the replacement of a supposedly faulty piece of Cisco computer
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 17 of 39

hardware that defendant CAGE falsely claimed to own, namely, a Cisco Model WS-C3650-
48PD-L.
37.
On or about August 22, 2017, defendant TAKANDRYIA LATRICE
CAGE caused Cisco to ship from Roanoke, Texas, to Arlington, Texas, a new Cisco Model WS-
C3650-48PD-L, serial number FDO2125Q0V0, with a retail value of approximately $9,100, via
FedEx, in response to Cisco SR # 682925241.
38.
On or about August 23, 2017, co-conspirator Jerel Andre Williams sold
and provided to Gulfstream Data to fulfill P.O. # 6011 the one new Cisco Model WS-C3650-
48PD-L, serial number FDO2125Q0V0, that was provided by Cisco and shipped to defendant
TAKANDRYIA LATRICE CAGE in response to Cisco SR # 682925241.
39.
On or about December 29, 2017, co-conspirator Jerel Andre Williams,
posing as a representative of the company “North American Processing Solutions” of Dallas,
Texas, and using the false name of “Larry Sander” and the email address of
“larry_sander@aol.com,” submitted a false warranty claim to Cisco and was assigned Cisco SR
# 683692648, seeking the replacement of a supposedly faulty piece of Cisco computer hardware
that co-conspirator Williams falsely claimed to own, namely, a Cisco Model WS-C3850-12XS-
E.
40.
On or about December 29, 2018, co-conspirator Jerel Andre Williams
caused Cisco to ship from Roanoke, Texas, to a FedEx store in Dallas, Texas, a new Cisco
Model WS-C3850-12XS-E, serial number FCW2145C0J0, with a retail value of approximately
$16,280, via FedEx, in response to Cisco SR # 683692648.
41.
On or about January 3, 2018, co-conspirator Jerel Andre Williams, posing
as a representative of the company “Fortress Computer Pros” of San Diego, California, and using
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 18 of 39

the false name of “Jeffery Gatson” and the email address of “fortresspro.usa.com,” submitted a
false warranty claim to Cisco and was assigned Cisco SR # 683707235, seeking the replacement
of a supposedly faulty piece of Cisco computer hardware that co-conspirator Williams falsely
claimed to own, namely, a Cisco Model WS-C3850-24XS-S.
42.
On or about January 3, 2018, co-conspirator Jerel Andre Williams caused
Cisco to ship from Roanoke, Texas, to a FedEx store in La Jolla, California, a new Cisco Model
WS-C3850-24XS-S, serial number FCW2147C0JY, with a retail value of approximately
$21,000, via FedEx, in response to Cisco SR # 683707235.
43.
On or about January 4, 2018, co-conspirator Jerel Andre Williams, posing
as a representative of the company “Transparent VOIP” of San Diego, California, and using the
false name of “Mark Williams” and the email address of “mark.voip@techie.com,” submitted a
false warranty claim to Cisco and was assigned Cisco SR # 683715027, seeking the replacement
of a supposedly faulty piece of Cisco computer hardware that co-conspirator Williams falsely
claimed to own, namely, a Cisco Model WS-C3850-12X48U-S.
44.
On or about January 5, 2018, co-conspirator Jerel Andre Williams caused
Cisco to ship from Roanoke, Texas, to a FedEx store in San Diego, California, a refurbished
Cisco Model WS-C3850-12X48U-S, serial number FCW2030C08R, with a retail value of
approximately $9,366, via FedEx, in response to Cisco SR # 683715027.
45.
On or about January 7, 2018, at a FedEx store in La Jolla, California, co-
conspirator Jerel Andre Williams, posing as “Jeffery Gatson,” picked up one piece of Cisco
hardware, serial number FCW2147C0JY, shipped by Cisco in response to Cisco SR #
683707235.
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 19 of 39

46.
On or about January 8, 2018, at a FedEx store in San Diego, California,
co-conspirator Jerel Andre Williams, posing as “Mark Williams,” picked up one piece of Cisco
hardware, serial number FCW2030C08R, shipped by Cisco in response to Cisco SR #
683715027.
47.
On or about January 11, 2018, co-conspirator Andre Williams arranged to
sell to Gulfstream Data a Cisco Model WS-C3850-24S-S that he did not then own or possess and
was issued P.O. # 6265, intending to submit a false warranty claim to Cisco in order to receive
that particular unit and then to ship it directly to Gulfstream Data.
48.
On or about January 12, 2018, co-schemer Jerel Andre Williams registered
the domain name “alphateamcomp.org” and created a new email address,
“mark@alphateamcomp.org.”
49.
On or about January 15, 2018, co-schemer Jerel Andre Williams, posing
as a representative of the company “Alpha Team Computer” of Dover, Delaware, and using the
false name of “Mark Williams” and the email address of “mark@alphateamcomp.org,”
submitted a false warranty claim to Cisco and was assigned Cisco SR # 63774408, seeking the
replacement of a supposedly faulty piece of Cisco computer hardware that co-conspirator
Williams falsely claimed to own, namely, a Cisco Model WS-C3850-24S-S.
50.
On or about January 15, 2018, co-conspirator Jerel Andre Williams caused
Cisco to ship from Columbus, Ohio, through Philadelphia, Pennsylvania to a FedEx store in
Wilmington, Delaware, a refurbished Cisco Model WS-C3850-24S-S, serial number
FCW2029F04B, with a retail value of approximately $12,240 via FedEx, in response to Cisco
SR # 63774408.
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 20 of 39

51.
On or about January 17, 2018, at a FedEx store in Wilmington, Delaware,
co-conspirator Jerel Andre Williams, posing as “Mark Williams,” picked up one piece of Cisco
hardware, serial number FCW2029F04B, shipped by Cisco in response to Cisco SR # 63774408.
52.
On or about January 17, 2018, co-conspirator Jerel Andre Williams sold
and provided to Gulfstream Data to fulfill P.O. # 6265 the refurbished Cisco Model WS-C3850-
24S-S, serial number FCW2029F04B, that was provided by Cisco and shipped to co-conspirator
Williams in response to Cisco SR # 63774408.
All in violation of Title 18, United States Code, Section 1349.

Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 21 of 39

COUNT TWO

THE UNITED STATES ATTORNEY FURTHER CHARGES THAT:
At all times relevant to this Information:
1.
The United States Small Business Administration (“SBA”) was an
executive branch 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 in a variety of ways, including by fostering the establishment and viability of small
businesses and aiding in their economic recovery after community disasters.
2.
As part of its efforts, the SBA provided for business loans through banks,
credit unions, and other lenders. Those loans had government-backed guarantees.
3.
The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”)
was a federal law enacted in or about March 2020. The CARES Act provided emergency
financial assistance to the millions of Americans suffering the economic effects of the COVID-
19 pandemic. One source of relief provided by the CARES Act was the authorization of
forgivable loans to small businesses for job retention and certain other expenses, through a
program referred to as the Paycheck Protection Program (“PPP”).
4.
To obtain a PPP loan, a qualifying business had 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 to make affirmative certifications to be eligible for the PPP loan. For example, in the PPP
loan application (SBA Form 2483), the business, through its authorized representative, had to
state its average monthly payroll expenses and number of employees. In addition, businesses had
to provide documentation showing their payroll expenses, as part of the PPP loan application
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 22 of 39

process. These figures were used to calculate the amount of money the small business was
eligible to receive under the PPP.
5.
Once a qualifying business completed a PPP application, a participating
lender, or agent on behalf of the participating lender, processed the application. If a PPP loan
application was approved, the participating lender funded the PPP loan using its own monies,
which the SBA guaranteed. In the course of processing the PPP loan, the lender transmitted data
from the loan application to the SBA, including information about the borrower, the total amount
of the loan, and the identified number of employees.
6.
Proceeds from a PPP loan were legally required to be used only for certain
permissible business expenses, including payroll costs, mortgage interest, rent, and utilities.
Under the applicable PPP rules and guidance, the interest and principal on the PPP loan was
eligible for forgiveness, if the business spent the loan proceeds on permissible items within a
designated period of time and used a certain portion of the loan toward payroll expenses.
7.
Cross River Bank was a financial institution headquartered in Fort Lee,
New Jersey with deposits insured by the Federal Deposit Insurance Corporation (“FDIC”) under
FDIC certificate number 58410. Cross River Bank participated as a lender in the PPP.
8.
BlueVine, Capital, Inc. (“BlueVine”) was a financial technology company
headquartered in Redwood City, California. Among other things, BlueVine provided intake and
review services on behalf of Cross River Bank in connection with PPP loan applications
submitted to Cross River Bank.
9.
Revenued was a small business financing company based in Jersey City,
New Jersey. Revenued’s technology platform included software to manage loan applications,
processing and underwriting for lenders participating in the PPP. Among other things, Revenued
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 23 of 39

provided intake and review services on behalf of Cross River Bank in connection with PPP loan
applications submitted to Cross River Bank.
10.
Defendant TAKANDRYIA LATRICE CAGE was a resident of the
Northern District of Texas.
11.
Defendant TAKANDRYIA LATRICE CAGE operated a business
“Glamour By Kandy,” which generated 2019 revenues of approximately $4,965 and 2019 net
profits of approximately $3,960.
12.
Neighborhood Credit Union (“NCU”) was a financial institution chartered
by the National Credit Union Administration, charter number 68177, whose deposits were
insured by the National Credit Union Share Insurance Fund.
13.
Defendant TAKANDRYIA LATRICE CAGE maintained an account
ending in 1129 at an NCU branch in the Northern District of Texas.
14.
Wells Fargo Bank was a financial institution the deposits of which were
insured by the FDIC under FDIC certificate number 3511.
15.
Defendant TAKANDRYIA LATRICE CAGE maintained an account
ending in 2084 in the name “The Luxury Cage L.C.” at a Wells Fargo Bank branch in the
Northern District of Texas.
16.
Regions Bank was a financial institution the deposits of which were
insured by the FDIC under FDIC certificate number 12368.
17.
Defendant TAKANDRYIA LATRICE CAGE maintained an account
ending in 9197 at a Regions Bank branch in the Northern District of Texas.
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 24 of 39

THE SCHEME
18.
From in or about June 2020, through in or about June 2021, in the District
of New Jersey, the Northern District of Texas, and elsewhere, defendant
TAKANDRYIA LATRICE CAGE
knowingly executed and attempted to execute a scheme and artifice to defraud Cross River Bank
and to obtain money and property under the care, custody and control of Cross River Bank, by
means of materially false and fraudulent pretenses, representations, and promises.
19.
The purpose of the scheme was for defendant TAKANDRYIA LATRICE
CAGE to enrich herself by fraudulently obtaining PPP loan proceeds, including by making false
statements regarding businesses defendant CAGE purported to own and operate, including false
statements about the number of employees, the wages paid, the payroll taxes paid, and the
intended use of the PPP loan proceeds. Once she obtained those PPP loan proceeds, defendant
CAGE caused those funds to be spent on unauthorized purchases.
MANNER AND MEANS
It was part of the scheme that:
20.
On or about June 29, 2020, defendant TAKANDRYIA LATRICE CAGE
caused a false and misleading PPP loan application in her own name doing business as Glamour
By Kandy, to be submitted to Cross River Bank, through Blue Vine, seeking approximately
$5,366 in PPP funds (“the First Cross River PPP Loan” application). The First Cross River PPP
Loan application contained purported payroll data that, if true and accurate, would have
supported the loan request. Defendant CAGE signed the First Cross River PPP Loan application
and falsely certified that both the application and the information provided in the supporting
documents were true and accurate.
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 25 of 39

21.
The information that defendant TAKANDRYIA LATRICE CAGE caused
to be submitted with the First Cross River PPP Loan application falsely represented the number
of employees of Glamour By Kandy, the wages paid to Glamour by Kandy employees, the 2019
revenue and net profits of Glamour By Kandy, and the intended uses of the PPP loan proceeds.
Defendant CAGE included with the First Cross River PPP Loan application a false 2019
Schedule C that falsely represented that Glamour By Kandy had 2019 revenue of approximately
$26,760 and a 2019 net profit of approximately $25,755.
22.
In the First Cross River PPP Loan application, defendant TAKANDRYIA
LATRICE CAGE falsely certified that the PPP loan proceeds “[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.” Defendant CAGE further certified
that she understood that “if the funds [were] knowingly used for unauthorized purposes, the
federal government may hold [her] legally liable, such as for charges of fraud.” Likewise, she
affirmed that the information provided “in this application and the information provided in all
supporting documents and forms is true and accurate in all material respects” and further
affirmed that knowingly making a false statement to obtain a PPP loan could result in
imprisonment, or fines, or both.
23.
On or about June 30, 2020, based on the false information,
representations, and documentation submitted in and in connection with the First Cross River
PPP Loan application, defendant TAKANDRYIA LATRICE CAGE caused Cross River Bank to
approve the First Cross River PPP Loan application and transfer approximately $5,366 via wire
from Fort Lee, New Jersey to the defendant TAKANDRYIA LATRICE CAGE’S account at
NCU ending in 1129 in the Northern District of Texas.
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 26 of 39

24.
Defendant TAKANDRYIA LATRICE CAGE caused proceeds from the
First Cross River PPP Loan that had been deposited into her NCU account ending in 1129 to be
used for personal and unauthorized expenses.
25.
On or about February 18, 2021, defendant TAKANDRYIA LATRICE
CAGE caused a second false and misleading PPP loan application in her own name doing
business as “The Luxury Cage” to be submitted to Cross River Bank through Revenued, seeking
approximately $21,250 in PPP funds (the “Second Cross River PPP Loan” application). The
Second Cross River PPP Loan application contained purported payroll data that, if true and
accurate, would have supported the loan request. Defendant CAGE signed the Second Cross
River PPP Loan application and falsely certified that both the application and the information
provided in the supporting documents were true and accurate.
26.
The information that defendant TAKANDRYIA LATRICE CAGE caused
to be submitted with the Second Cross River PPP Loan application falsely represented the
number of employees of “The Luxury Cage,” the wages paid to “The Luxury Cage” employees,
the 2019 revenue and net profits of “The Luxury Cage,” and the intended uses of the PPP loan
proceeds. Defendant CAGE included with the Second Cross River PPP Loan application a false
2019 Schedule C that falsely represented that “The Luxury Cage” had 2019 revenue of
approximately $106,780 and a 2019 net profit of approximately $99,894.
27.
In the Second Cross River PPP Loan application, defendant
TAKANDRYIA LATRICE CAGE falsely certified that the PPP loan proceeds “[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.” Defendant CAGE
further certified that she understood that “if the funds [were] knowingly used for unauthorized
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 27 of 39

purposes, the federal government may hold [her] legally liable, such as for charges of fraud.”
Likewise, she affirmed that the information provided “in this application and the information
provided in all supporting documents and forms is true and accurate in all material respects” and
further affirmed that knowingly making a false statement to obtain a PPP loan could result in
imprisonment, or fines, or both.
28.
On or about March 1, 2021, based on the false information,
representations, and documentation submitted in and in connection with the Second Cross River
PPP Loan application, defendant TAKANDRYIA LATRICE CAGE caused Cross River Bank to
approve the Second Cross River PPP Loan application and transfer approximately $21,250 via
wire from Fort Lee, New Jersey to the defendant TAKANDRYIA LATRICE CAGE’s account at
Wells Fargo Bank ending in 2084 in the Northern District of Texas.
29.
Defendant TAKANDRYIA LATRICE CAGE caused proceeds from the
Second Cross River PPP Loan that had been deposited into her Wells Fargo Bank account
ending in 2084 to be used for personal and unauthorized expenses.
30.
On or about February 22, 2021, defendant TAKANDRYIA LATRICE
CAGE caused a third false and misleading PPP loan application in her own name to be submitted
to Cross River Bank through Blue Vine, seeking approximately $12,285 in PPP funds (the
“Third Cross River PPP Loan” application). The Third Cross River PPP Loan application
contained purported payroll data that, if true and accurate, would have supported the loan
request. Defendant CAGE signed the Third Cross River PPP Loan application and falsely
certified that both the application and the information provided in the supporting documents
were true and accurate.
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 28 of 39

31.
The information that defendant TAKANDRYIA LATRICE CAGE caused
to be submitted with the Third Cross River PPP Loan application falsely represented the number
of employees of Glamour By Kandy, the wages paid to the Glamour By Kandy employees, the
2020 revenue and net profits of Glamour By Kandy, and the intended uses of the PPP loan
proceeds. Defendant CAGE included with the Third Cross River PPP Loan application a false
2020 Schedule C that falsely represented that Glamour By Kandy had 2020 revenue of
approximately $64,928 and a 2020 net profit of approximately $58,979.
32.
On or about March 8, 2021, based on the false information,
representations, and documentation submitted in and in connection with the Third Cross River
PPP Loan application, defendant TAKANDRYIA LATRICE CAGE caused Cross River Bank to
approve the Third Cross River PPP Loan application and transfer approximately $12,285 via
wire from Fort Lee, New Jersey to the defendant TAKANDRYIA LATRICE CAGE’S account
at Regions Bank ending in 9197 in the Northern District of Texas.
33.
Defendant TAKANDRYIA LATRICE CAGE caused proceeds from the
Third Cross River PPP Loan that had been deposited into her Regions Bank account ending in
9197 to be used for personal and unauthorized expenses.

All in violation of Title 18, United States Code, Section 1344.

Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 29 of 39

COUNTS THREE THROUGH FIVE

THE UNITED STATES ATTORNEY FURTHER CHARGES THAT:
At all times relevant to this Information:
1.
Paragraphs 1 through 6 and 10 through 17 of Count Two are incorporated
here.
2.
American Lending Center, LLC (“American Lending”) was a private
lending company headquartered in Long Beach, California. American Lending provided
commercial loans to eligible small businesses nationwide primarily through SBA programs.
American Lending participated as a lender in the PPP.
3.
MBE Capital Partners, LLC (“MBE Capital”) was a private lending
company institution headquartered in Fort Lee, New Jersey that provided private commercial
loans and funding. MBE participated as a lender in the PPP.
THE SCHEME
4.
From in or about August 2020, through in or about June 2021, in the
District of New Jersey, the Central District of California, the Northern District of Texas, and
elsewhere, defendant
TAKANDRYIA LATRICE CAGE
devised and intended to devise a scheme to defraud and to obtain money and property by means
of false and fraudulent pretenses, representations, and promises.
5.
The purpose of the scheme was for defendant TAKANDRYIA LATRICE
CAGE to enrich herself by fraudulently obtaining PPP loan proceeds, including by making false
statements regarding businesses defendant CAGE purported to own and operate, including false
statements about the number of employees, the wages paid, the payroll taxes paid, and the
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 30 of 39

intended use of the PPP loan proceeds. Once she obtained those PPP loan proceeds, defendant
CAGE caused those funds to be spent on unauthorized purchases
MANNER AND MEANS
It was part of the scheme that:

6.
On or about August 6, 2020, defendant TAKANDRYIA LATRICE CAGE
caused a false and misleading PPP loan application in her own name to be submitted to MBE
seeking approximately $20,833 in PPP funds (“the First MBE PPP Loan” application). The First
MBE PPP Loan application contained purported payroll data that, if true and accurate, would
have supported the loan request. Defendant CAGE signed the First MBE PPP Loan application
and falsely certified that both the application and the information provided in the supporting
documents were true and accurate.
7.
The information that defendant TAKANDRYIA LATRICE CAGE caused
to be submitted with the First MBE PPP Loan application falsely represented the number of
defendant CAGE’s employees, the wages paid to those employees, the 2019 revenue and net
profits of defendant CAGE, and the intended uses of the PPP loan proceeds. Defendant CAGE
included with the First MBE PPP Loan application a false 2019 Schedule C that falsely
represented that defendant CAGE had 2019 revenue of approximately $106,780 and a 2019 net
profit of approximately $99,894.
8.
In the First MBE PPP Loan application, defendant TAKANDRYIA
LATRICE CAGE falsely certified that the PPP loan proceeds “[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.” Defendant CAGE further certified
that she understood that “if the funds [were] knowingly used for unauthorized purposes, the
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 31 of 39

federal government may hold [her] legally liable, such as for charges of fraud.” Likewise, she
affirmed that the information provided “in this application and the information provided in all
supporting documents and forms is true and accurate in all material respects” and further
affirmed that knowingly making a false statement to obtain a PPP loan could result in
imprisonment, or fines, or both.
9.
On or about August 26, 2020, based on the false information,
representations, and documentation submitted in and in connection with the First MBE PPP Loan
application, defendant TAKANDRYIA LATRICE CAGE caused MBE to approve the First
MBE PPP Loan application and transfer approximately $20,833 via wire from Fort Lee, New
Jersey to the defendant TAKANDRYIA LATRICE CAGE’S account at NCU ending in 1129 in
the Northern District of Texas.
10.
Defendant TAKANDRYIA LATRICE CAGE caused proceeds from the
First MBE PPP Loan that had been deposited into her NCU account ending in 1129 to be used
for personal and unauthorized expenses.
11.
On or about January 19, 2021, defendant TAKANDRYIA LATRICE
CAGE caused a false and misleading PPP loan application in her own name to be submitted to
MBE seeking approximately $20,800 in PPP funds (“the Second MBE PPP Loan” application).
The Second MBE PPP Loan application contained purported payroll data that, if true and
accurate, would have supported the loan request. Defendant CAGE signed the Second MBE PPP
Loan application and falsely certified that both the application and the information provided in
the supporting documents were true and accurate.
12.
The information that defendant TAKANDRYIA LATRICE CAGE caused
to be submitted with the Second MBE PPP Loan application falsely represented the number of
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 32 of 39

defendant CAGE’s employees, the wages paid to those employees, the 2019 and 2020 revenue
and net profits of defendant CAGE, and the intended uses of the PPP loan proceeds.
13.
In the Second MBE PPP Loan application, defendant TAKANDRYIA
LATRICE CAGE falsely certified that the PPP loan proceeds “[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.” Defendant CAGE further certified
that she understood that “if the funds [were] knowingly used for unauthorized purposes, the
federal government may hold [her] legally liable, such as for charges of fraud.” Likewise, she
affirmed that the information provided “in this application and the information provided in all
supporting documents and forms is true and accurate in all material respects” and further
affirmed that knowingly making a false statement to obtain a PPP loan could result in
imprisonment, or fines, or both.
14.
On or about February 11, 2021, based on the false information,
representations, and documentation submitted in and in connection with the Second MBE PPP
Loan application, defendant TAKANDRYIA LATRICE CAGE caused MBE to approve the
Second MBE PPP Loan application and transfer approximately $20,800 via wire from Fort Lee,
New Jersey to the defendant TAKANDRYIA LATRICE CAGE’S account at NCU ending in
1129 in the Northern District of Texas.
15.
Defendant TAKANDRYIA LATRICE CAGE caused proceeds from the
Second MBE PPP Loan that had been deposited into her NCU account ending in 1129 to be used
for personal and unauthorized expenses.
16.
On or about April 20, 2021, defendant TAKANDRYIA LATRICE CAGE
caused a false and misleading PPP loan application in her own name doing business as “The
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 33 of 39

Luxury Cage” to be submitted to American Lending seeking approximately $20,833 in PPP
funds (“the American Lending PPP Loan” application). The American Lending PPP Loan
application contained purported payroll data that, if true and accurate, would have supported the
loan request. Defendant CAGE signed the American Lending PPP Loan application and falsely
certified that both the application and the information provided in the supporting documents
were true and accurate.
17.
The information that defendant TAKANDRYIA LATRICE CAGE caused
to be submitted with the American Lending PPP Loan application falsely represented the number
of “The Luxury Cage” employees, the wages paid to those employees, the 2019 revenue and net
profits of defendant CAGE, and the intended uses of the PPP loan proceeds. Defendant CAGE
included with the American Lending PPP Loan application a false 2019 Schedule C that falsely
represented that defendant CAGE had 2019 revenue of approximately $106,780 and a 2019 net
profit of approximately $99,894.
18.
In the American Lending PPP Loan application, defendant
TAKANDRYIA LATRICE CAGE falsely certified that the PPP loan proceeds “[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.” Defendant CAGE
further certified that she understood that “if the funds [were] knowingly used for unauthorized
purposes, the federal government may hold [her] legally liable, such as for charges of fraud.”
Likewise, she affirmed that the information provided “in this application and the information
provided in all supporting documents and forms is true and accurate in all material respects” and
further affirmed that knowingly making a false statement to obtain a PPP loan could result in
imprisonment, or fines, or both.
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 34 of 39

19.
On or about May 4, 2021, based on the false information, representations,
and documentation submitted in and in connection with the American Lending PPP Loan
application, defendant TAKANDRYIA LATRICE CAGE caused American Lending to approve
the American Lending PPP Loan application and transfer approximately $20,833 via wire from
Long Beach, California, to defendant TAKANDRYIA LATRICE CAGE’S account at Wells
Fargo Bank ending in 2084 in the Northern District of Texas.
20.
Defendant TAKANDRYIA LATRICE CAGE caused proceeds from the
American Lending PPP Loan that had been deposited into her Wells Fargo Bank account ending
in 2084 to be used for personal and unauthorized expenses.
WIRE FRAUD
21.
On or about each of the following dates, in the District of New Jersey, the
Central District of California, the Northern District of Texas, and elsewhere, defendant
TAKANDRYIA LATRICE CAGE,

for the purpose of executing the scheme described above, caused to be transmitted by means of
wire communication in interstate commerce the signals and sounds described below, each
transmission constituting a separate count:
COUNT
DATE
ORIGINATION
OF WIRE
DESTINATION
OF WIRE
METHOD AND
DESCRIPTION OF
WIRE

THREE
August 6,
2020
Northern District
of Texas
District of New
Jersey
First MBE PPP Loan
Application submitted by
defendant CAGE via the
internet, seeking
approximately $20,833
PPP loan
Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 35 of 39

COUNT
DATE
ORIGINATION
OF WIRE
DESTINATION
OF WIRE
METHOD AND
DESCRIPTION OF
WIRE

FOUR
January 19,
2021
Northern District
of Texas
District of New
Jersey
Second MBE PPP Loan
Application submitted by
defendant CAGE via the
internet, seeking
approximately $20,800
PPP loan
FIVE
April 20,
2021
Northern District
of Texas
Central District of
California
American Lending PPP
Loan Application
submitted by defendant
CAGE via the internet,
seeking approximately
$20,833 PPP loan

All in violation of Title 18, United States Code, Section 1343.

Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 36 of 39

NOTICE OF FORFEITURE
THE UNITED STATES ATTORNEY FURTHER CHARGES THAT:
1.
As a result of the violations of Title 18, United States Code, Sections
1349, 1344, and 1343, set forth in this Indictment, defendant
TAKANDRYIA LATRICE CAGE

shall forfeit to the United States of America any property constituting, or derived from, proceeds
obtained directly or indirectly from the commission of such offenses, including but not limited to
$139,704 in United States currency (money judgment).
2.
If any of the property described above, 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 to, sold to, or deposited with a third party;
c.
has been placed beyond the jurisdiction of this 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 18, United States Code, Section 928(b)
incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any other
property of the defendant up to the value of the property subject to forfeiture.

Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 37 of 39

All pursuant to Title 18, United States Code, Section 982(a)(2).
JENNIFER ARBITTIER WILLIAMS
UNITED STATES ATTORNEY

Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 38 of 39

No._ _ _ _ _ _ _ _ _ _

UNITED STATES DISTRICT COURT

Eastern District of Pennsylvania

Criminal Division

THE UNITED STATES OF AMERICA

vs.

TAKANDRYIA LATRICE CAGE

INFORMATION

Counts
18 U.S.C. § 1349 (conspiracy to commit mail fraud – 1 count); 18 U.S.C. § 1344 (bank fraud – 1 count);
18 U.S.C. § 1343 (wire fraud – 3 counts); Notice of forfeiture
A true bill.

_____________________________________________________________________
Foreman
Filed in open court this _________________________________day,
Of ________________________A.D. 20_____________
__________________________________________________________________________________________
Clerk
Bail, $___________________________

Case 2:22-cr-00039-JMG Document 1 Filed 02/09/22 Page 39 of 39

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Criminal information — United States v. Takandryia Latrice Cage (E.D. Pa.) (E.D. Pa.)

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