Information — United States v. Gladys Harun (3:23-cr-3)

Summary

A one-count criminal information in United States v. Gladys Harun, No. 3:23-cr-00003-DHB-BKE, filed March 29, 2023 as Document 1-1 in the U.S. District Court for the Southern District of Georgia, Dublin Division. It charges the defendant with making false statements under 18 U.S.C. § 1001(a)(2). The information describes the CARES Act and the SBA's Economic Injury Disaster Loan program, including EIDL Advances of up to $10,000.00. Count One alleges that on or about July 27, 2021, in Dodge County, the defendant submitted a false EIDL application claiming that another individual had a business opened on December 1, 2019 with $2,114.00 in gross revenues and $165.00 in cost of goods sold in 2019. It is signed for the United States Attorney for the Southern District of Georgia by Assistant United States Attorneys.

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Case 3:23-cr-00003-DHB-BKE Document1-1 Filed 03/29/23. Page1of5

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF GEORGIA

DUBLIN DIVISION
UNITED STATES OF AMERICA _—+)—«SXINFORMATION NO.__©R 323-003
)
Vv. ) False Statements
) 18U.S.C. § 1001
GLADYS HARUN )
alk/a “GLADYS CHEGE” )

THE UNITED STATES ATTORNEY CHARGES THAT:

Introduction:

At all times material to this Information:

The COVID-19 Pandemic and the CARES Act

1. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was
a federal law enacted in or about March 2020 designed to provide emergency financial
assistance to the millions who suffered economic effects caused by the COVID-19
pandemic.

z. Among other relief efforts, the United States sought to provide financial
support to eligible businesses that could be used to offset certain business expenses.

3B. At all times material to this Information, the Small Business
Administration (“SBA”) was an executive branch agency of the United States
government that provided support to entrepreneurs and small businesses. The SBA
was headquartered in Washington, DC, and maintained its computer servers outside
of the State of Georgia. The SBA’s mission 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.

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Case 3:23-cr-00003-DHB-BKE Document1-1 Filed 03/29/23 Page 2of5

4. 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. In addition, the SBA provided loans that came directly from the U.S.
Government.

Economic Injury Disaster Loans

5. One source of relief provided by the CARES Act was the authorization
for the SBA to provide Economic Injury Disaster Loans (“EIDLs’”) to eligible small
businesses experiencing substantial financial disruption due to the COVID-19
pandemic.

6. In order to obtain an EIDL, a qualifying business had to submit an
online application to the SBA and provide information about its operations, such as
the number of employees, gross revenues for the twelve-month period preceding the
disaster, and the cost of goods the business sold in the twelve-month period preceding
the disaster. In the case of EIDLs, the twelve-month period was that preceding
January 31, 2020. The applicant also had to certify that all the information in its
application was true and correct to the best of the applicant’s knowledge.

7. In addition, the CARES Act authorized the SBA to issue advances of up
to $10,000.00 to small businesses within three days of applying for an EIDL “EIDL
Advance”). The amount of the EIDL Advance was determined by the number of
employees the applicant certified having.

8. EIDL applications were submitted directly to the SBA online at

https://covid19relief.sba.gov/#/ and processed by the agency with support from a

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Case 3:23-cr-00003-DHB-BKE Document1-1 Filed 03/29/23 Page 3of5

government contractor, Rapid Finance. The amount of each loan was determined
based, in part, on the information provided by the application about employment,
revenue, and cost of goods. Any funds issued under an EIDL were issued directly by
the SBA. EIDL funds could be used for payroll expenses, sick leave, production costs,

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

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Case 3:23-cr-00003-DHB-BKE Document1-1 Filed 03/29/23 Page4of5

COUNT ONE
False Statements
18 U.S.C. § 1001(a)(2)

8. Paragraphs 1 through 8 of the Information are incorporated by reference
as if fully set forth herein.

10.  Onor about July 27, 2021, in Dodge County, in the Southern District of
Georgia, in a matter within the jurisdiction of the SBA, an independent
establishment within the executive branch of the United States Government,
Defendant GLADYS HARUN did willfully and knowingly make and cause to be made,
and use and cause to be used, a false writing or document knowing the same to
contain a materially false, fictitious, and fraudulent statement. Defendant GLADYS
HARUN submitted a false EIDL application by falsely claiming that an individual
with the initials K.E.W. had a business opened on December 1, 2019, and that such
business generated $2,114.00 in gross revenues in 2019 and had $165.00 in cost of
goods sold in 2019, when Defendant GLADYS HARUN did in fact know and believe
that K.E.W. did not own any business in 2019.

All in violation of Title 18, United States Code, Section 1001(a)(2).

{signatures on the following page}

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Case 3:23-cr-00003-DHB-BKE Document 1-1

JILL E. STEINBERG
UNITED STATES ATTORNEY
SOUTHERN DISTRICT OF GEORGIA

2 D-QYMon

PATRICIA G. RHODES
Assistant United States Attorney
Chief, Criminal Division

a

(L-ALEXANDER HAMNER
‘Aasiotavt United States Attorney
*Lead Counsel

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Filed 03/29/23

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