Criminal Information — United States v. Felicia Stanley

Record facts

U.S. District Court, Northern District of Florida, Tallahassee Division · No. 4:22-cr-00032-MW-MAF · Doc. 1 · 2022-06-17 · Docket on CourtListener

Full text

Case 4:22-cr-00032-MW-MAF Document1 Filed 06/17/22 Page1of21

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF FLORIDA
TALLAHASSEE DIVISION

(MHF
UNITED STATES OF AMERICA Lp: 220° 3l- pri]

v. INFORMATION

FELICIA JACKSON STANLEY
and
WILBERT JEAN STANLEY III
/

THE U.S. ATTORNEY CHARGES:
COUNT ONE
A. INTRODUCTION

At all times material to this Indictment:

1. The United States Small Business Administration (“SBA”) was an
executive-branch agency of the United States government that provides support to
entrepreneurs and small businesses. The mission of the SBA was to maintain and
strengthen the nation's economy by enabling the establishment and viability of
small businesses and by assisting in the economic recovery of communities after
disasters.

2. As part of this effort, the SBA enabled and provided for loans through
banks, credit unions, and other lenders. These loans had government-backed

guarantees.

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The Paycheck Protection Program

3, The Coronavirus Aid, Relief, and Economic Security ("CARES") Act
was a federal law enacted in or around March 2020 and was designed to provide
emergency financial assistance to the millions of Americans who are suffering the
economic effects caused by the COVID-19 pandemic. One source of relief
provided by the CARES Act was the authorization of up to $349 billion in
forgivable loans to small businesses for job retention and certain other expenses,
through a program referred to as the SBA Paycheck Protection Program ("PPP").
In or around April 2020, Congress authorized over $300 billion in additional PPP
funding.

4, In order to obtain a PPP loan, a qualifying business was required to
submit a PPP loan application, called an SBA Form 2483. The PPP loan
application required the business (through its authorized representative) to |
acknowledge the program rules and make certain affirmative certifications in
order to be eligible to obtain the PPP loan. In the PPP loan application, the small
business (through its authorized representative) was required to certify, among
other things, its: (a) average monthly payroll expenses, and (b) number of
employees. These figures were used to calculate the amount of money the small

business was eligible to receive under the PPP. In addition, businesses applying

for a PPP loan were required to provide documentation showing their payroll
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expenses and that they were in business as of February 15, 2020. Further,
businesses applying for a PPP loan were required to make good faith
certifications, including that economic uncertainties had necessitated their loan
requests for continued business operations, and that they intended to use loan
proceeds only for the authorized, and not any duplicative, purposes.

5. PPP loan applications were required to be signed by an authorized
representative of the business. By signing PPP loan applications, applicants
attested that the information provided in the application and in all supporting
documents and forms was true and accurate, and that the applicant understood that
knowingly making a false statement to obtain a PPP loan was a crime.

6. PPP loan proceeds must have been used by the business on certain
permissible expenses- payroll costs, interest on mortgages, rent, and utilities. The
SBA allowed the interest and principal on the PPP loan to be entirely forgiven if
the business spent the loan proceeds on these expense items within a designated
period of time (usually eight weeks of receiving the proceeds) and used at least
75% of the PPP loan proceeds on payroll expenses.

7. A PPP loan application was required to be processed by a
participating financial institution (“the lender”). Ifa PPP loan application was

approved, the lender funded the PPP loan using its own monies, which were 100%

guaranteed by the SBA. Data from the loan application, including information
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about the borrower, the total amount of the loan, and the listed number of
employees, was electronically transmitted by the lender to the SBA in the course
of processing the loan.

Economic Injury Disaster Loans

8. Another related response to the COVID-19 outbreak was an
expansion of an existing disaster-related program — the Economic Injury Disaster
Loan (“EIDL”) — to provide for loan assistance (including $10,000 advances) for
small businesses’and:other eligible entities for loans up to $2 million. The EIDL
proceeds could have been used to pay fixed debts, payroll, accounts payable, and
_ other bills that-could have been paid had the disaster not occurred; however, such
loan proceeds *werenot’ intended-to replace lost sales or profits, or for the
expansion of a business.

9.  Unlike'‘certain other types of SBA-guaranteed loans, EIDL funds were
issued directly from.the United States Treasury, and applicants applied for EIDL
funds directly through the SBA via an online portal and application. The EIDL
application process, which also used certain outside contractors for system support,
collected information:concerning the business and the business owner, including
information about the gross revenues for the business prior to January 31, 2020,
and the cost of goods sold. Applicants electronically certified that the information

provided was true and accurate and were warned that any false statement or
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misrepresentation to the SBA, or any misapplication of loan proceeds may result in
sanctions, including criminal penalties.

10. EIDL applications were received in and processed using computer
servers located in the states of Iowa, Virginia, and Washington. EIDL
disbursement payments were initiated by the SBA using computer servers located
in the state of Colorado, which transmitted the payment information to the
Treasury using computer servers located in the state of Virginia.

-»Shuttered Venue Operators Grant

11. The Shuttered Venue Operators Grant (““SVOG”) program was
established by the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and
Venues Act;:and:amended by the American Rescue Plan Act. The program
included over $16 billion in grants to shuttered venues, to be administered by
SBA’s Office of Disaster Assistance.

12. | Eligible applicants could qualify for grants equivalent to 45% of their
gross earned revenue, with the maximum amount available for a single grant award
of $10 million.

13. SVOG provided emergency assistance for eligible performing arts
businesses affected:.by COVID-19. The SVOG program’s mission is to support the
ongoing operations of eligible live venues and operators, live venue promoters,

theatrical producers, talent representatives, live performing arts organization
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operators, museums, and motion picture theaters during the uncertain economic
conditions caused by the COVID-19 pandemic.

14. SVOG applications were received in and processed using computer
servers located outside of the state of Florida.

Financial Institutions and Lenders

15. First Home Bank and Cross River Bank were financial institutions,
the deposits of which were federally insured by the Federal Deposit Insurance
Corporation. First Home Bank and Cross River Bank offered PPP loans to its
customers.

16. Fountainhead SBF, LLC (“Fountainhead”); Kabbage, Inc.
(“Kabbage”); Readycap Lending, LLC (“Readycap”); BSD Capital, LLC d/b/a
Lendistry (“Lendistry”); Itria Ventures, LLC (“Itria’”); and Capital Plus Financial,
LLC (“Capital Plus”) were non-bank lenders that.offered SBA PPP loans to
owners of small to midsize businesses.

17. To process PPP loan applications for its clients and customers, First
Home Bank, Cross River Bank, Fountainhead, Kabbage, Readycap, Lendistry,
Itria, and Capital Plus used computer servers located outside of Florida and

interstate wire communications.

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B. THE CHARGE
Between on or about March 1, 2020, and on or about September 1, 2021, in
the Northern District of Florida and elsewhere, the defendants,
FELICIA JACKSON STANLEY
WILBERT JEAN STANLEY Ii,
did knowingly and willfully combine, conspire, confederate, and agree with other
persons to devise, and intend to devise, a scheme to defraud and for obtaining
money and property by means of materially false and fraudulent pretenses,
representations, and promises, and to cause wire communications to be transmitted
in interstate commerce for the purpose of executing such scheme, in violation of
Title 18, United States Code, Section 1343.
C. MANNER AND MEANS
The manner and means by which this. conspiracy was committed included
the following:
1. FELICIA JACKSON STANLEY and WILBERT JEAN
STANLEY III used the Internal Revenue Service’s (IRS) Modernized Internet
Employer Identification Number (EIN) system to obtain EINs for business entities

which were later fraudulently used in applications for SBA benefit programs. For

some of the business entities, such as Scream Loud, Inc. and Nationwide Law

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Consulting Firm, LLC, the EINs that were obtained from the IRS helped create the
appearance of legitimacy in the SBA benefit applications.

2. FELICIA JACKSON STANLEY and WILBERT JEAN
STANLEY III made and caused to be made false and fraudulent representations in
SBA PPP loan applications and in supporting loan documents submitted to First
Home Bank, Cross River Bank, Fountainhead, Kabbage, Readycap, Lendistry,
Itria, and Capital Plus in the names of business entities, namely, Yep We Kan
Promotions, Inc.; A Call Away Transportation, LLC; PlaySports Bar, LLC; You
Hurt, Inc.; and of individuals, in order to falsely qualify for SBA PPP loans.

3. FELICIA JACKSON STANLEY and WILBERT JEAN
STANLEY III specifically attempted to cause and caused First Home Bank, Cross
River Bank, Fountainhead, Kabbage, Readycap, Lendistry, Itria, and Capital Plus
to issue SBA PPP loans and disburse SBA PPP loan proceeds to them based upon
loan applications, loan documents, and emails that falsely represented the number
of employees and average monthly payroll expenses for Yep We Kan Promotions,
Inc.; A Call Away Transportation, LLC; PlaySports Bar, LLC; You Hurt, Inc.; and
of individuals.

4, FELICIA JACKSON STANLEY and WILBERT JEAN
STANLEY III electronically mailed and submitted, and caused to be

electronically mailed and submitted, false and fraudulent documentation to First
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Home Bank, Cross River Bank, Fountainhead, Kabbage, Readycap, Lendistry,
Itria, and Capital Plus for the SBA PPP loan applications.

5. FELICIA JACKSON STANLEY and WILBERT JEAN
STANLEY III communicated, via email and telephone, with First Home Bank,
Cross River Bank, Fountainhead, Kabbage, Readycap, Lendistry, Itria, and Capital
Plus at which they applied for SBA PPP loans about the loan applications and their
status, and the funding of such loans.

6. FELICIA JACKSON STANLEY and WILBERT JEAN
STANLEY III made and caused to be made false and fraudulent representations in
EIDL applications and in supporting loan documents submitted to the SBA in the
names of business entities, namely, Yep We Kan Promotions, Inc.; A Call Away
Transportation, LLC; PlaySports Bar, LLC; Yep She Kan Network; Island
Daiquiris Bar & Grill, LLC; USA United Law Firm, LLC; Unique Xpressions;
Scream Loud, Inc.; Jackson Family Produce; Credit Repair & Tradelines, LLC;
Aldrena Jackson Health; Family First Assisted Living, LLC; Zelific, LLC;
Richanti Jefferson Care; Tanisha Hampton Care; and Porter Cleaning Service; and
of individuals, in order to falsely qualify for EIDL funds.

7. FELICIA JACKSON STANLEY and WILBERT JEAN
STANLEY III specifically attempted to cause and caused the SBA to issue EIDLs

and disburse EIDL proceeds to them based upon loan applications, loan
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documents, and emails that falsely represented the number of employees, revenue,
and expenses for Yep We Kan Promotions, Inc.; A Call Away Transportation,
LLC; PlaySports Bar, LLC; Yep She Kan Network; Island Daiquiris Bar & Grill,
LLC; USA United Law Firm, LLC; Unique Xpressions; Scream Loud, Inc.;
Jackson Family Produce; Credit Repair & Tradelines, LLC; Aldrena Jackson
Health; Family First Assisted Living, LLC; Zelific, LLC; Richanti Jefferson Care;
Tanisha Hampton Care; and Porter Cleaning Service; and of individuals.

8. FELICIA JACKSON STANLEY and WILBERT JEAN
STANLEY III electronically mailed and submitted, and caused to be
electronically mailed and submitted, false and fraudulent documentation to the
SBA for the EIDL applications.

9. FELICIA JACKSON STANLEY and WILBERT JEAN
STANLEY III made and caused to be made false and fraudulent representations in
EIDL applications and in supporting loan documents submitted to the SBA in the
names of business entities, namely, Yep We Kan Promotions, Inc.; A Call Away
Transportation, LLC; PlaySports Bar, LLC; Yep She Kan Network; Island
Daiquiris Bar & Grill, LLC; USA United Law Firm, LLC; Unique Xpressions;
Scream Loud, Inc.; Jackson Family Produce; Credit Repair & Tradelines, LLC;

Aldrena Jackson Health; Family First Assisted Living, LLC; Zelific, LLC;

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Richanti Jefferson Care; Tanisha Hampton Care; and Porter Cleaning Service; and
of individuals, in order to falsely qualify for EIDL funds.

10. FELICIA JACKSON STANLEY and WILBERT JEAN
STANLEY III received as a fee, by cash, check, and wire transfer, a portion of
PPP loan and EIDL proceeds that they fraudulently obtained in the names of
individuals from such individuals.

11. FELICIA JACKSON STANLEY and WILBERT JEAN
STANLEY III specifically attempted to cause and caused the SBA to issue
SVOGs and disburse SVOG proceeds to them based upon grant applications,
supporting documents, and emails that falsely represented revenues for Yep We
Kan Promotions, Inc.; PlaySports Bar, LLC; and Scream Loud, Inc.

12. FELICIA JACKSON STANLEY and WILBERT JEAN
STANLEY III electronically mailed and submitted, and caused to be
electronically mailed and submitted, false and fraudulent documentation to the
SBA for the SVOG applications.

13. FELICIA JACKSON STANLEY and WILBERT JEAN
STANLEY III fraudulently obtained and attempted to obtain more than $400,000
in PPP loan funds from First Home Bank, Cross River Bank, Fountainhead,

Kabbage, Readycap, Lendistry, Itria, and Capital Plus, more than $3,500,000 in

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EIDL funds from the SBA, and more than $3,350,000 in SVOG funds from the
SBA by this conduct.
All in violation of Title 18, United States Code, Section 1349.
COUNT TWO
A. INTRODUCTION
The allegations contained in sections A and C of Count One of this
Information are realleged and incorporated as if fully set forth herein.
B. THE CHARGE
Between on or about March 1, 2020, and on or about September 1, 2021, in
the Northern District of Florida and elsewhere, the defendants,
FELICIA JACKSON STANLEY
WILBERT JEAN STANLEY III,
did knowingly and willfully combine, conspire, confederate, and agree together
and with other persons to engage and attempt to engage in a monetary transaction
by, through, and to a financial institution, affecting interstate and foreign
commerce, in criminally derived property of a value greater than $10,000, to wit,
receiving deposits of PPP, EIDL, and SVOG proceeds into bank accounts owned
and controlled by the Defendants, and depositing cash and checks into bank

accounts owned and controlled by the Defendants, and transferring such funds

from bank accounts owned and controlled by the Defendants, such property having
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been derived from a specified unlawful activity, to wit, conspiracy to commit wire
fraud, in violation of Title 18, United States Code, Section 1349, as charged in
Count One of this Information, all in violation of Title 18, United States Code,
Section 1957.

In violation of Title 18, United States Code, Section 1956(h).

COUNT THREE
A. INTRODUCTION |

The allegations of Sections A and C of Count One are hereby realleged and

incorporated by reference as if fully set forth herein.
B. THE CHARGE

Between on or about March 1, 2020, and on or about September 1, 2021, in
the Northern District of Florida, in a matter within the jurisdiction of the executive
branch of the Govérnment of the United States, that is, the SBA’s administration of
its PPP, EIDL, and SVOG programs, the defendant,

FELICIA JACKSON STANLEY

did knowingly and willfully falsify a material fact; make materially false, fictitious,
and fraudulent statements and representations; and make and use a false document
knowing the same to contain any materially false, fictitious, or fraudulent

statement or entry, to wit, the defendant falsely stated in an SBA PPP loan

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application (SBA Form 2483) that she submitted to Kabbage to obtain an SBA PPP
loan that:

a. A Call Away Transportation, having an EIN ending in 0930,
had an average monthly payroll of approximately $8,320;

b. A Call Away Transportation, having an EIN ending in 0930,
had 1 employee;

C. all SBA loan proceeds will be used only for business-related
purposes as specified in the loan application and consistent with the
Paycheck Protection Program Rule;

d. A Call Away Transportation, having an EIN ending in 0930,
was in operation on February 15, 2020, and had employees for whom it paid
salaries and payroll taxes or paid independent contractors, as reported on
Form(s). 1099-MISC;

e. Current economic uncertainty made the SBA PPP loan
necessary to support ongoing operations of A Call Away Transportation;

f. the SBA PPP loan funds will be used to retain workers and
maintain payroll or make mortgage interest payments, lease payments, and

utility payments, as specified under the PPP Rule; and

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g. the information provided in the SBA PPP loan application and
the information provided in all supporting documents and forms was true
and accurate in all material respects,
whereas, in truth and in fact, and as the defendant well knew, such representations
were untrue, as A Call Away Transportation had issued no payroll, all SBA loan
proceeds were not used only for business-related purposes as specified in the loan
application and consistent with the Paycheck Protection Program Rule, A Call
Away Transportation was not in operation on February 15, 2020, and the
information provided in the SBA PPP loan application and the information
provided in all supporting documents and forms was not true and accurate in all
material respects.

In violation of Title 18, United States Code, Section 1001(a).

COUNT FOUR
A. INTRODUCTION

The allegations of Sections A and C of Count One are hereby realleged and

incorporated by reference as if fully set forth herein.
B. THE CHARGE
Between on or about August 1, 2021, and on or about September 1, 2021, in

the Northern District of Florida, in a matter within the jurisdiction of the executive

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branch of the Government of the United States, that is, the SBA’s administration of
its PPP, EIDL, and SVOG programs, the defendant,
WILBERT JEAN STANLEY II,
did knowingly and willfully falsify a material fact; make materially false, fictitious,
and fraudulent statements and representations; and make and use a false document
knowing the same to contain any materially false, fictitious, or fraudulent
statement or entry, to wit, the defendant falsely stated in an SBA SVOG
application that he submitted to the SBA to obtain an SBA SVOG that:
a. Play Sports Bar, LLC, having an EIN ending in 4134, had gross
revenue of $6,001,000.00 in year 2019;
b. Play Sports Bar, LLC, having an EIN ending in 4134, had gross
revenue of $1,000,000.00 in year 2020;
oF Play Sports Bar, LLC, having an EIN ending in 4134, had 44
employees;
d. all SVOG grant proceeds will not be used for real estate
purchases or to invest; and
e. the information provided in the SBA SVOG application and the
information provided in all supporting documents and forms was true and

accurate in all material respects,

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whereas, in truth and in fact, and as the defendant well knew, such representations
were untrue, as Play Sports Bar, LLC did not have gross revenue of $6,001,000.00
in year 2019 and did not have gross revenue of $1,000,000.00 in year 2020, Play
Sports Bar, LLC did not have 44 employees, some SVOG grant proceeds were
used for real estate purchases or to invest, and the information provided in the SBA
SVOG application and the information provided in all supporting documents and
forms was not true and accurate in all material respects.

In violation of Title 18, United States Code, Section 1001(a).
CRIMINAL FORFEITURE

The allegations contained in Counts One through Four of this Information
are hereby realleged and incorporated by reference for the purpose of alleging
forfeiture. From their engagement in the violations alleged in Counts One through

Four of this Information, the defendants,

FELICIA JACKSON STANLEY
WILBERT JEAN STANLEY Ill,
(A) pursuant to Title 18, United States Code, Section 982(a)(2), and Title
28, United States Code, Section 2461(c), upon conviction of an offense in violation

of Title 18, United States Code, Sections 1349 and 1014, as alleged in Counts One

and Three of this Information, respectively, any and all of the Defendants’ right,

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title, and interest in any property, real and personal, constituting and derived from
proceeds traceable to such offenses;

(B) pursuant to Title 18, United States Code, Section 982(a)(1), upon
conviction of an offense in violation of Title 18, United States Code, Section 1956,
as alleged in Count Two of this Information, any and all of the Defendants’ right,
title, and interest in any property, real and personal, involved in such offenses, and
any property traceable to such property.

The United States will also seek a forfeiture money judgment for a sum of
money equal to the value of any property, real or personal, which: 1) constitutes or
is derived from proceeds traceable to these offenses, and 2) is involved in such
offenses and any property traceable to such property. The property subject to
forfeiture includes, but is not limited to, the following:

r 1. Real property located and situated in Leon County, Florida, located at
1660 Kay Avenue, Units 1,2,3,4,5,6,7,and 8, Tallahassee, FL 32301, and all areas
designated as common elements of Greenside Condominiums, further described in
Leon County Official Records Book 5470 and Page 79, and known to the Leon
County Property Appraiser as Parcel Identification #s 3108360000010,
3108360000020, 3108360000030, 3108360000040, 3108360000050,
3108360000060, 3108360000070, 3108360000080, respectively.

2. Real property located and situated in Leon County, Florida:
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Lot 10, Block C, Tallahassee Ranch Club, according to the plat thereof,
recorded in Plat Book 18, Page(s) 1 through 35, of the inclusive, Public
Records of Leon County, Florida,
and further described in Leon County Official Records Book 5496 and Page 1308,
and known to the Leon County Property Appraiser as Parcel Identification #
332525 C0100.
3. Real property located and situated in Leon County, Florida, located at

3770 Laurel Trace Way, Tallahassee, FL 32303, described as:

Lot 6, Block D of Laurel Trace, According to the Plat thereof as Recorded in
Plat Book 16, Page 75, of The Public Records of Leon County, Florida,

and further described in Leon County Official Records Book 5510 and Page 39,
and known to the Leon County Property Appraiser as Parcel Identification
4210929D0060.

4, The Coinbase account with user identification number ending in
9b775ae, held in the name of WILBERT STANLEY and/or associated with email
address yepwekan@gmail.com.

5. The Coinbase account with user identification number ending in
8d710141, held in the name of FELICIA STANLEY and/or associated with email
address liciapooh01@hotmail.com.

6. The Robinhood account ending in 2819, held in the name of FELICIA

STANLEY.

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7. The Robinhood account ending in 1939, held in the name of
WILBERT STANLEY.
8. The TD Ameritrade account ending in 1466, held in the name of
FELICIA JACKSON-STANLEY.
If any of the property described above as being subject to forfeiture, as a
result of acts or omissions of the defendants:
1. cannot be located upon the exercise of due diligence;
ii. has been transferred, sold to, or deposited with a third party;
iii. has been placed beyond the jurisdiction of this Court;
iv. has been substantially diminished in value; or
v. has been commingled with other property that cannot be

subdivided without difficulty,

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it is the intent of the United States, pursuant to Title 21, United States Code,
Section 853(p), as incorporated by Title 28, United States Code, Section 2461(c),
to seek forfeiture of any other property of said defendant up to the value of the

forfeitable property.

W/vs, VE
/

J NR. COQDY DATE

i) (yl 71/022
JUSTIN M. KEEN J! DATE”
Assistant United States Attorney

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