Indictment - US v. Jackson et al.

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U.S. District Court for the Middle District of Georgia, Albany Division · No. 1:24-cr-00035-LAG-TQL · Doc. 1 · 2024-08-14 · Docket on CourtListener

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IN THE UNITED STATES DISTRICT COURT 
FOR THE MIDDLE DISTRICT OF GEORGIA 
ALBANY DIVISION 
UNITED STATES OF AMERICA 
v. 
CRIMINAL NO. 1:24-CR-
SHERRONICA JACKSON, 
TYREEK BROWN, and 
ALANBROWN 
Defendants. 
THE GRAND JURY CHARGES: 
VIOLATION: 
18 u.s.c. § 1349 
18 u.s.c. § 1344(2) 
18 u.s.c. § 2 
----
18 U.S.C. § 982(a)(2)(A) 
GENERAL INTRODUCTION 
At all times relevant to this Indictment: 
1. The United States Small Business Administration (SBA) is an executive-branch agency of 
the United States government that provides support to entrepreneurs and small businesses. 
The mission of the SBA is 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 pa1t of this effort, the SBA enables and provides for loans through banks, credit unions 
and other lenders. These loans have government-backed guarantees. In addition to traditional 
SBA funding programs, The CARES Act, which was signed into law in March 2020, 
established several new temporary programs and provided for the expansion of others to 
address the COVID-19 outbreak:. 
3. One of these new programs is the SBA Paycheck: Protection Program (PPP), which is a loan 
designed to provide a direct incentive for small businesses to keep their workers on the 
payroll. Under this program, the SBA will forgive all or part of loans if all employees were 
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kept on the payroll for eight weeks and borrowers submit documentation confoming that the 
loan proceeds were used for payroll, rent, mortgage interest, or utilities. Interested applicants 
apply through an existing SBA lender or any other participating federally insured financial 
institution. 
4. The PPP application process requires applicants to submit a Bo1rnwer Application Form 
through an SBA-approved financial entity. The application contains information as to the 
purpose of the loan, average monthly payroll, number of employees and background of the 
business and its owner, including questions relating to criminal history. Applicants are also 
required to make good faith certifications, including that economic uncertainties have 
necessitated their loan requests for continued business operations and that they intend to use 
loan proceeds only for the authorized and not any duplicative pmposes. 
COUNT ONE 
(Conspiracy to Commit Bank Fraud) 
The allegations contained in paragraphs 1 through 4 of the General Introduction of this 
Indictment are incorporated by reference as if set forth fully herein. Beginning on or about 
March 26, 2021, to on or about May 16, 2021, in the Albany Division of the Middle District of 
Georgia and elsewhere within this Court's Jurisdiction, 
SHERRONICA JACKSON, 
TYREEK BROWN, AND 
ALANBROWN 
did unlawfully combine, conspire, confederate, and agree together and with each other, and 
persons known and unknown to the Grand Jury, to commit and attempt to c01mnit bank fraud, in 
violation of Title 18, United States Code, Section 1344, by executing and attempting to execute a 
scheme and artifice to defraud a federally insured financial institution, and to obtain the moneys, 
funds, credits, assets, and other property owned by and under the custody and control of said 
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financial institution by means of material false and fraudulent pretenses, representations, and 
promises. In execution of the conspiracy and to affect its objects, the members of the conspiracy 
committed the acts described in Counts Two through Six of this Indictment, which are hereby 
incorporated by reference in this Count. 
All in violation of Title 18, United States Code, Section 1349. 
COUNTS TWO THROUGH SIX 
(Bank Fraud) 
On or about the dates set below, in the Albany Division of the Middle Dish·ict of Georgia 
and elsewhere within this Comt's Jurisdiction, 
SHERRONICA JACKSON, 
TYREEK BROWN, AND 
ALANBROWN 
aided and abetted by each other and by others both known and unknown to the Grand Jury, did 
knowingly and intentionally execute a scheme and aitifice to obtain money and funds under the 
custody and control of the federally insured financial institutions set forth below, by means of 
false and fraudulent pretenses and representations, to wit, by the use of fraudulent applications 
for Paycheck Protection Program assistance. In executing the scheme to defraud, defendants 
subinitted applications containing fabricated gross income figures to qualify for loans under the 
SBA Paycheck Protection Program for which they were not entitled. 
Count 
Date 
Gross Income 
Financial Institution 
Loan Amount 
Claimed 
Received 
2. 
March 26, 
$97,000.00 • 
Capital Plus Financial, 
$20,207.00 
2021 
LLC 
3. 
April 17, 
$101,005.00 
Harvest Small Business 
$20,833.00 
2021 
Finance, LLC 
4. 
April 21, 
$101,005.00 
Harvest Small Business 
$20,833.00 
2021 
Finance, LLC 
5. 
April 14, 
$103,400.00 
Harvest Small Business 
$20,833.00 
2021 
Finance, LLC 
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6. 
April 16, 
2021 
$103,400.00 
Harvest Small Business 
$20,833.00 
Finance, LLC 
In violation of Title 18, United States Code, Section 1344(2) and 2. 
FORFEITURE NOTICE 
(18 U.S.C. § 982(a)(2)(A) - Criminal Forfeiture) 
1. 
The allegations contained in Counts One through Six of this Indictment are hereby 
re-alleged and incorporated by reference into this Notice for the purpose of alleging forfeiture to 
the United States of America, pursuant to the provisions of Title 18, United States Code, Section 
982(a)(2)(A). 
2. 
Upon conviction of the offense(s) in violation of Title 18, United States Code, 
Section 1349 set folih in Count One; and/or Title 18, United States Code, Section 1344(2) set forth 
in Counts Two through Six of the Indictment, the defendant(s), 
SHERRONICA JACKSON, 
TYREEK BROWN, AND 
ALAN BROWN, 
shall forfeit to the United States of America, pursuant to Title 18, United States Code, Section 
982(a)(2)(A), any property constituting, or derived from, proceeds obtained, directly or indirectly, 
as a result of such violation(s), including, but not limited to a money judgment in an amount to be 
determined. 
3. 
If any of the property subject to forfeiture, as a result of any act or omission of the 
defendant: 
(a) 
cannot be located upon exercise of due diligence; 
(b) 
has been transferred, sold to or deposited with, a third person; 
( c) 
has been placed beyond the jurisdiction of the court; 
( d) 
has been substantially diminished in value; or 
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(e) 
has been commingled with other property which cannot be subdivided 
without difficulty, 
the United States of America shall be entitled to forfeiture of substitute property pursuant to Title 
21, United States Code, Section 853(p), as incorporated by Title 18, United States Code, Section 
982(b)(l). 
All pursuant to 18 U.S.C. § 982(a)(2)(A). 
A TRUE BILL. 
s/ Foreperson of the Grand Jury 
FOREPERSON OF THE GRAND .TTJRY 
PETERD. LEARY 
UNITED ST ATES AT ORNEY 
TED STATES ATTORNEY 
Filed in open com1 this I U, day of~ 
AD 2024. 
co~ 
Deputy Clerk 
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