Statement of Offense — United States v. Jewral McIntyre

Record facts

U.S. District Court for the District of Columbia · No. 1:25-cr-00157-RC · Doc. 22 · 2026-04-23 · Docket on CourtListener

Summary

A statement of offense in support of a guilty plea in United States v. Jewral McIntyre, No. 1:25-cr-00157-RC, in the U.S. District Court for the District of Columbia, filed April 23, 2026 (Doc. 22). McIntyre agrees to plead guilty to Count One of the Information, conspiracy to commit bank fraud under 18 U.S.C. § 1349, and stipulates to facts the government would prove. It states that a PPP loan application for his business, Rat Pack Worldwide Security & Consulting, claimed 18 employees and an average monthly payroll of $103,192.35, and that Capital Bank funded $257,980.87 on March 12, 2021. It states that McIntyre wired $30,000 to a Maryland resident who helped arrange the loan, e-signed a forgiveness application on August 8, 2022, and that the loan was forgiven. The statement is dated May 5, 2025 and includes the defendant's acceptance.

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Case 1:25-cr-00157-RC Document 22 Filed 04/23/26 Page1of7

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA : Criminal Number: 25-157 (RC)

JEWRAL MCINTYRE,

Defendant.

STATEMENT OF OFFENSE IN SUPPORT OF GUILTY PLEA

Defendant Jewral McIntyre agrees to admit guilt and enter a plea of guilty to Count One
of the Information, which charges Strauss with Conspiracy to Commit Bank Fraud in violation of
18 U.S.C. § 1349. Pursuant to Federal Rule of Criminal Procedure 11, the Government and
Strauss, with concurrence of his attorney, agree and stipulate that the Government would prove
the following facts at trial beyond a reasonable doubt:

Background
Relevant Persons

l. Defendant JEWRAL MCINTYRE was a resident of the State of Florida and the
owner and operator of Rat Pack Worldwide Security & Consultant.

2. Kelly Winston (“Winston”) was a resident of Maryland and employed as an
accountant for several businesses under the control of Allieu Kamara that operated in the District

of Columbia.
Case 1:25-cr-00157-RC Document 22 Filed 04/23/26 Page2of7

3. Allieu Kamara (“Kamara”) was a resident of Maryland and operated several

businesses in the District of Columbia that provide services to the District.
Relevant Entities

4, Rat Pack Worldwide Security & Consulting (“Rat Pack”), was a security
consulting business registered as a corporation in Florida on May 11, 2018.

5. Capital Bank, N.A. (“Capital Bank”) is a financial institution insured by the Federal
Deposit Insurance Corporation.

The Smatt Business Administration

6. 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 by
enabling the establishment and viability of small businesses and by assisting in the economic
recovery of communities after disasters.

The Paycheck Protection Program

7. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was a federal
law enacted in or around March 2020 and designed to provide emergency financial assistance to
the millions of Americans suffering the economic effects caused by the COVID-19 pandemic. One
source of relief provided by the CARES Act was the authorization of billions in forgivable loans
to small businesses for job retention and certain other expenses, through a program referred to as
the Paycheck Protection Program (“PPP”).

8. In order to obtain a PPP loan, a qualifying business must have submitted a PPP loan
application, which is signed by an authorized representative of the business. The applicant of a

PPP loan was required to acknowledge the program rules and make certain affirmative
Case 1:25-cr-00157-RC Document 22 Filed 04/23/26 Page3of/7

certifications in order to be eligible to obtain the PPP loan. In the PPP loan application, the
applicant must state, 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 is
eligible to receive under the PPP. In addition, businesses applying for a PPP loan must have
provided documentation showing their payroll expenses. To qualify for eligibility, businesses that
applied for a PPP loan needed to be in operation as of February 15, 2020.

9. A PPP loan application must have been processed by a participating financial
institution (the lender). If a PPP loan application was approved, the participating financial
institution funds the PPP loan using its own monies, which are 100% guaranteed by the SBA. Data
from the application, including information about the borrower, the total amount of the loan, and
the listed number of employees, was transmitted by the lender to the SBA in the course of
processing the loan.

10. PPP loan proceeds must have been used by the business for certain permissible
expenses—payroll costs, interest on mortgages, rent, and utilities. The PPP allowed the interest
and principal on the PPP loan to be entirely forgiven if the business spends the loan proceeds on
these expense items within a designated period of time and uses a certain percentage of the PPP
loan proceeds on payroll expenses.

11. On December 27, 2020, the Economic Aid to Hard-Hit Small Business, Nonprofits
and Venues Act provided additional funding for the PPP and extended the application deadline to
March 31, 2021. The act enables borrowers to take a second draw PPP loan under the same general
terms as their first PPP loan up to a maximum loan amount of $2 million. The act reopened the
program to borrowers who did not previously receive a first draw PPP loan. To be eligible for a

second draw, borrowers must employ no more than 300 employees, demonstrate a 25% reduction
Case 1:25-cr-00157-RC Document 22 Filed 04/23/26 Page4of/7

in gross receipts during a calendar quarter in 2020, and have expended the full amount of their
initial PPP loan. Allowable expenses were expanded to include worker protection costs related to
COVID-19, uninsured property damage costs caused by looting or vandalism during 2020, and
certain supplier costs and expenses for operations. The expansion applies retroactively to first draw
PPP loans that have not been forgiven by the SBA.

12. On March 25, 2021, the PPP Extension Act of 2021 extended the application
deadline from March 31, 2021, to May 31, 2021. In addition to extending the PPP application
filing window by 60 days, the Extension Act provided an extra 30 days for the SBA to finish
processing applications received by the May 31, 2021, deadline.

Bank Fraud Conspiracy

13.‘ In January 2021, Kamara approached McIntyre to ask if he wanted to apply, with
Kamara’s assistance, for a PPP loan in the name of Rat Pack.

14. Kamara and McIntyre agreed that Kamara would receive a portion of the PPP
funds if the loan application was approved and funded.

15. In January 2021, McIntyre provided Kamara with basic information for Rat Pack,
including is business license, Internal Revenue Service Employer Identification Number, and the
Articles of Incorporation. At Kamara’s request, Winston then created a PPP loan application for
Rat Pack containing materially false statements, including that Rat Pack had 18 employees and an
average monthly payroll of $103,192.35, when in fact it had no W2 employees and payroll that
was a fraction of the amount claimed. In addition, Winston created false and fraudulent supporting
documents to submit with the loan application, including: false financial payroll reports for 2020
and false Employer’s Quarterly Federal Tax Return (Forms 941), for each quarter of 2020. All of

these documents were provided through an online portal to Capital Bank.
Case 1:25-cr-00157-RC Document 22 Filed 04/23/26 Page5of/7

16. On March 4, 2021, McIntyre e-signed the PPP loan application and it was
submitted to Capital Bank. The PPP loan application sought a $257,980.87 loan. McIntyre
understood that the application and supporting documentation given to him by Kamara had been
prepared by Winston, even though neither Kamara, nor Winston, requested, or received any payroll
information that would be necessary to submit a complete and accurate PPP loan application for
Rat Pack.

17. On March 12, 2021, the SBA and Capital Bank approved McIntyre’s fraudulent
PPP loan application and funded the loan in amount of $257,980.87.

18. On March 12, 2021, the SBA and Capital Bank deposited $257,980.87 into Rat
Pack’s Capital Bank account ending in -8196.

19, On March 16, 2021. and March 22, 2021, McIntyre wired from Rat Pack’s Capital
Bank account ending in -8196 $175,000 and $75,000, respectively, to Rat Pack’s JP Morgan Chase
Bank (“JPMC”) account ending in -6935.

20. On March 23, 2021, McIntyre wired $30,000 from Rat Pack’s JPMC account
ending in -6935 to Kamara’s account at Bank of America, N.A. (“BOA”) ending in -5772.

21. On July 20, 2022, McIntyre forwarded Kamara an email containing a link to
Capital Bank’s PPP loan forgiveness application for Rat Pack.

22. At the behest of Kamara, Winston prepared a loan forgiveness application for Rat
Pack. The application falsely claimed that Rat Pack had |8 employees at the time McIntyre
received the PPP loan. The application also falsely claimed that, for the period of March 12, 2021,
through May 14, 2021, Rat Pack spent the full amount of the loan, $257,980.87, on payroll costs.

On August 8, 2022, McIntyre e-signed and submitted the loan forgiveness application.
Case 1:25-cr-00157-RC Document 22 Filed 04/23/26 Page6of/7

23. Asa result of the false loan forgiveness application, submission and supporting

documentation, Capital Bank and the SBA forgave Rat Pack’s PPP loan.

DATED: May 5, 2025

Respectfully Submitted,

JEANINE FERRIS PIRRO
UNITED STATES ATTORNEY

/s/ Joshua Gold

Joshua A. Gold
Assistant United States Attorney
Tx Bar No. 24103101

Af, by 23,200

S. Rheu KAzA
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Case 1:25-cr-00157-RC Document 22 Filed 04/23/26 Page /7of7

DEFENDANTS ACCEPTANCE

The preceding statement is a summary, made for the purpose of providing the Court with
a factual basis for my guilty plea to the charge against me. He does not include all of the facts
known to me revarding this offense. Lmake this statement knowingly and voluntarily and because
Lam, in fact, guilty of the crimes charred. No threats have been made to me nor am Pounder the
influence of anything that could impede my ability to understand this Statement of Otfense fully,

I have read every word of this Statement of the Offense. Pursuant to Federal Rule of
Criminal Procedure 11, after consulting with my attorney, | agree ang stipulate to this Statyment
of the Offense. and declare under penalty of perjury that itis ite ay corres.

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Jewral Molniyre , ra Ps Y |
Defendant Pd 03 Ji)
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ATTORNEY'S ACKNOWLEDGMEN I

I have read this Statement of Offense and reviewed it with my client fully. Tconcur in my
client's desire to adopt and stipulate to this Statement of the Offense as true and accurate.

Date: 5/20/2025

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