Criminal Information — United States v. Roody Metelus

Record facts

U.S. District Court, Southern District of Florida · No. 0:26-cr-60019-RKA · Doc. 1 · 2026-01-26 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. _________ _ 
18 u.s.c. § 371 
18 U.S.C. § 982(a)(2)(A) 
UNITED STATES OF AMERICA 
vs. 
ROODY METELUS, 
Defendant. 
I 
--------------
INFORMATION 
The United States Attorney charges that: 
GENERAL ALLEGATIONS 
At all times material to this Information: 
The Small Business Administration, the COVID-19 Emergency, and the CARES Act 
1. 
The Coronavirus Aid, Relief, and Economic Security ("CARES") Act was a federal 
law enacted on March 27, 2020, to provide emergency financial assistance to Americans suffering 
economic harms from the COVID-19 pandemic. To achieve this goal, the CARES Act established 
new temporary programs and expanded existing programs administered by the United States Small 
Business Administration ("SBA"). 
The Paycheck Protection Program 
2. 
One source of relief provided by the CARES Act was the authorization of forgivable 
loans to small businesses, self-employed individuals and certain organizations for job retention 
and other expenses, through a program referred to as the Paycheck Protection Program ("PPP"). 
26-CR-60019-ALTMAN/STRAUSS
BM
Jan 26, 2026
MIAMI
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3. 
Businesses and individuals could apply for PPP loans by submitting a PPP loan 
application (SBA Fo1m 2483). The PPP loan application required that the applicant acknowledge, 
through its authorized representative, the program rules and make certain affirmative certifications 
to be eligible to obtain the PPP loan. In the PPP loan application, the applicant, through its 
authorized representative, had to state its: (a) average monthly payroll expenses, and (b) number 
of employees. An employer's payroll expenses or a self-employed individual's income was used 
to calculate the loan amount, which was determined based on 2.5 times the average monthly 
payroll. The payroll calculation included the wages or salary earned up to $100,000 per employee 
or self-employed individual. 
4. 
In addition, the applicant business had to provide documentation evidencing its 
payroll expenses, or in the case of an individual, his or her gross and net income. Typically, the 
applicant business would supply tax return documents showing the amount of payroll taxes reported 
to the Internal Revenue Service ("IRS"). For a self-employed individual who filed income taxes 
using an IRS Form 1040 (an individual income tax return), the self-employment business income 
would be reflected on an IRS Schedule C. IRS Schedule C was a fonn that taxpayers completed to 
report any earnings or losses arising from any business or a profession as a sole proprietor. 
5. 
The IRS Schedule SE was another tax form that may be attached to a Form 1040 for 
a self-employed individual, which calculated and reported the individual's self-employment tax. 
6. 
A PPP loan application had to be processed by a participating lender or the 
participating lender's delegee. If a PPP loan application was approved, the lender funded the PPP 
loan using its own monies, which were fully guaranteed by the SBA. 
7. 
PPP loan proceeds were required to be used by the business on certain permissible 
expenses-
employee payroll costs, interest on mortgages, rent, and utilities. The PPP allowed 
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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 and used a defined portion of 
the PPP loan proceeds on payroll expenses. 
The Defendant and Relevant Entity 
8. 
Company 1 was a company headquaiiered in Virginia that offered tax preparation 
services to its customers. Company 1 offered individuals the ability to be franchisees, allowing 
them to operate a tax return preparation business using Company 1 's trade name, service marks, 
software and method of operation. 
9. 
Defendant, ROODY METELUS, was a resident of Broward County, Florida, who 
had a franchise agreement with Company 1 to operate a franchise located in Dania Beach, Florida. 
10. 
Liberty Tax Service was a fictitious name registered in Florida that was used by 
ROODY METELUS to operate a tax return preparation business as a franchisee of Companyl. 
11. 
JRS Tax Services, LLC. ("JRS Tax Services") was a Florida corporation that owned 
the fictitious name, Liberty Tax Service. ROODY METELUS was an owner and officer of JRS 
Tax Services. At all relevant times, JRS Tax Services used the name Liberty Tax Service at a tax 
return preparation office located in Dania Beach, Florida. 
12. 
Bank 1 was a financial institution headquartered in Oklahoma that was insured by 
the Federal Deposit Insurance Corporation ("FDIC"). Bank 1 was an approved SBA lender of PPP 
loans. 
13. 
Bank Processor 1 was a third-party company headquartered in North Carolina that 
supplied Bank 1 a platform for applicants to submit their PPP loan application information and 
supporting documents. Bank Processor 1 's server was located in Nmih Carolina. Bank Processor 
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1 utilized other third-party on-line platforms for applicants to sign the PPP loan application, which 
involved servers located in Virginia and Oregon. 
CONSPIRACY TO COMMIT WIRE FRAUD 
(18 u.s.c. § 371) 
1. 
Paragraphs 1 through 13 of the General Allegations section of this Information are 
realleged and incorporated by reference as though fully set forth herein. 
2. 
From in and around January 2021 , through in and around January 2022, in Broward 
County, in the Southern District of Florida, and elsewhere, the defendant, 
ROODY METELUS, 
did willfully, that is, with the intent to further the object of the conspiracy, and knowingly combine, 
conspire, confederate, and agree with co-conspirators known and unknown to the United States 
Attorney, to commit an offense against the United States, that is, to knowingly, and with the intent 
to defraud, devise, and intend to devise, a scheme and artifice to defraud, and to obtain money and 
property by means of materially false and fraudulent pretenses, representations, and promises, 
knowing that the pretenses, representations, and promises were false and fraudulent when made, 
and, for the purpose of executing the scheme and artifice, did knowingly transmit and cause to be 
transmitted, by means of wire communication in interstate and foreign commerce, certain writings, 
signs, signals, pictures, and sounds, in violation of Title 18, United States Code, Section 1343. 
PURPOSE OF THE CONSPIRACY 
3. 
It was the purpose of the conspiracy for ROODY METELUS and his co-
conspirators to unlawfully enrich themselves by, among other things: (a) preparing false and 
fraudulent applications and supporting documents on behalf of PPP loan applicants; (b) submitting 
and causing the submission of false and fraudulent PPP loan applications and supporting 
documents; and (c) receiving kickbacks from the loan applicants for the defendant's personal use, 
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the use and benefit of others, and to further the fraud. 
MANNER AND MEANS OF THE CONSPIRACY 
The manner and means by which the defendant and his co-conspirators sought to 
accomplish the object and purpose of the conspiracy included, among others, the following: 
4. 
ROODY METELUS operated a tax preparation business in which he offered 
existing Liberty Tax Service customers and others interested in applying for PPP loans 
( collectively "customers") his assistance with false and fraudulent PPP loan applications and 
supporting documentation. 
5. 
ROODY METELUS prepared false and fraudulent PPP loan applications on 
behalf of new and existing customers. METELUS prepared false and fraudulent tax forms, mainly 
IRS Schedules C, IRS Schedules SE, and Self-Employment Ledgers, that falsely and fraudulently 
represented the customers as self-employed with income-generating businesses in order to qualify 
for the PPP loans; when, in truth and in fact, the customers were not self-employed with income-
generating businesses. 
6. 
Some ofROODY METELUS' customers were his co-conspirators, as they signed 
the PPP loan applications and Self-Employment Legers knowing that METELUS had prepared 
the loan documents using false figures and information. METELUS and his co-conspirators 
submitted and caused to be submitted false and fraudulent PPP loan applications and supporting 
documents to Bank 1 using Bank Processor 1. METELUS and his co-conspirators caused the 
false and fraudulent PPP loan applications to be transmitted via interstate wire communications to 
Bank 1, using Bank Processor 1. 
7. 
Based on the false and fraudulent PPP loan applications that ROODY METELUS 
and his co-conspirators submitted and caused to be submitted as part of this conspiracy, Bank 1 
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disbursed loan proceeds to bank accounts controlled by METELUS' customers via interstate wire 
transmissions. 
8. 
ROODY METELUS also assisted customers in submitting false and fraudulent 
PPP loan applications to other lenders after Bank 1 denied the false and fraudulent PPP loan 
applications that METELUS and his co-conspirators had submitted and caused to be submitted to 
Bank 1 on the customers' behalf. 
9. 
ROODY METELUS and his co-conspirators submitted and caused to be 
submitted false and fraudulent PPP loan forgiveness applications to Bank 1 and other lenders on 
behalf of customers, via interstate wire communications. 
10. 
ROODY METELUS received kickback payments from the proceeds of the false 
and fraudulent PPP loans that his customers received. 
11. 
ROODY METELUS and his co-conspirators used the proceeds from the fraud 
scheme for their own use, the use of others, and to further the conspiracy. 
OVERT ACTS 
In furtherance of the conspiracy, and to accomplish its object and purpose, at least one of 
the co-conspirators committed and caused to be committed, in the Southern District of Florida and 
elsewhere, at least one of the following overt acts, among others: 
1. 
On or about February 14, 2021 , ROODY METELUS prepared false and fraudulent 
documents ( a 2019 IRS Schedule C, a 2019 IRS Schedule SE, and a Self-Employment Ledger for 
year 2020), to support a PPP loan application on behalf of A.W. that was electronically submitted 
from the Southern District of Florida to Bank Processor 1, which resulted in Bank 1 funding a PPP 
loan in the approximate amount of $17,525. 
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2. 
On or about February 20, 2021 , ROODY METELUS prepared false and fraudulent 
documents (a 2019 IRS Schedule C, a 2019 IRS Schedule SE, and a Self-Employment Ledger for 
year 2020), to support a PPP loan application on behalf of C.T. that was electronically submitted 
from the Southern District of Florida to Bank Processor 1, which resulted in Bank 1 funding a PPP 
loan in the approximate amount of $20,220. 
3. 
On or about March 2, 2021 , ROODY METELUS prepared false and fraudulent 
documents (a 2019 IRS Schedule C, a 2019 Schedule SE, and a Self-Employment Ledger for year 
2020), to support a PPP loan application on behalf of W.B. that was electronically submitted from 
the Southern District of Florida to Bank Processor 1, which resulted in Bank 1 funding a PPP loan 
in the approximate amount of $20,314.15. 
4. 
On or about March 3, 2021 , ROODY METELUS prepared false and fraudulent 
documents (a 2019 IRS Schedule C, a 2019 Schedule SE, and a Self-Employment Ledger for year 
2020), to support a PPP loan application on behalf ofD.W. that was electronically submitted from 
the Southern District of Florida to Bank Processor 1, which resulted in Bank 1 funding a PPP loan 
in the approximate amount of$20,453.12. 
5. 
On or about March 6, 2021 , ROODY METELUS prepared false and fraudulent 
documents (a 2019 IRS Schedule C, a 2019 Schedule SE, and a Self-Employment Ledger for year 
2020), to support a PPP loan application on behalf of H.F.M. that was electronically submitted 
from the Southern District of Florida to Bank Processor 1, which resulted in Bank 1 funding a PPP 
loan in the approximate amount of $20,368.95. 
6. 
On or about March 13, 2021 , ROODY METELUS prepared false and fraudulent 
documents (a 2019 IRS Schedule C, a 2019 Schedule SE, and a Self-Employment Ledger for year 
2020), to support a PPP loan application on behalf of W.S. that was electronically submitted from 
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the Southern District of Florida to Bank Processor 1. Bank 1 declined to approve and fund W.S.'s 
PPP loan application. 
7. 
On or about March 21, 2021, ROODY METELUS prepared false and fraudulent 
documents ( a 2019 IRS Schedule C, a 2019 Schedule SE, and a Self-Employment Ledger for year 
2020), to support a PPP loan application on behalf of K. W. that was electronically submitted from 
the Southern District of Florida to Bank Processor 1. Bank 1 declined to approve and fund K.W. 's 
PPP loan application. 
8. 
On or about June 3, 2021, W.B. made one of several electronic funds transfers in 
the amount of $1 ,000, from his bank account to the bank account of ROODY METELUS as 
payment to METELUS for assisting in the submission of false and fraudulent first and second 
round PPP loan applications on behalf of W.B. 
All in violation of Title 18, United States Code, Section 371. 
FORFEITURE ALLEGATIONS 
1. 
The allegations of this Information are hereby re-alleged and by this reference fully 
incorporated herein for the purpose of alleging forfeiture to the United States of America of certain 
property in which the defendant, ROODY METELUS, has an interest. 
2. 
Upon conviction of a violation, or conspiracy to commit a violation, of Title 18, 
United States Code, Section 3 71, as alleged in this Information, the defendant shall forfeit to the 
United States any property, constituting, or derived from, proceeds the person obtained directly or 
indirectly as a result of such offense, pursuant to Title 18, United States Code, Section 
982(a)(2)(A). 
3. 
If any of the property subject to forfeiture, as a result of any act or omission of the 
defendant: 
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a. 
cannot be located upon the exercise of due diligence; 
b. 
has been transferred or sold to, or deposited with, a third party; 
c. 
has been placed beyond the jurisdiction of the court; 
d. 
has been substantially diminished in value; or 
e. 
has been commingled with other property which cannot be divided without 
difficulty; 
the United States shall be entitled to forfeiture of substitute property under the provisions of Title 
21 , United States Code, Section 853(p). 
All pursuant to Title 18, United States Code, Section 982(a)(2)(A), and the procedures set 
forth in Title 21 , United States Code, Section 853, as incorporated by Title 28, United States Code, 
Section 982(b )(2). 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
UNITED ST ATES OF AMERICA 
CASE NO.: -----------------
v. 
ROODY METELUS 
CERTIFICATE OF TRIAL ATTORNEY 
I 
------------------
Superseding Case Information: 
Defendant. 
Court Division (select one) 
New Defendant(s) (Yes or No) __ 
Number of New Defendants ---
□Miami 
□Key West 
□FTP 
Total number of new counts ---
E]FTL 
□WPB 
I do hereby certify that: 
1. 
I have carefully considered the allegations of the lndictment, the number of defendants, the number of probable 
witnesses and the legal complexities of the Indictment/Information attached hereto. 
2. 
I am aware that the information supplied on this statement will be relied upon by the Judges of this Court in setting 
their calendars and scheduling criminal trials under the mandate ofthe Speedy Trial Act, 28 U.S.C. §3161. 
3. 
Jnterpreter: (Yes or No)~ 
List language and/or dialect: _______ _ 
4. 
This case will take_0_days for the parties to try. 
5. 
Please check appropriate category and type of offense listed below: 
(Check only one) 
I El 0 to 5 days 
II D 6 to I 0 days 
III O 11 to 20 days 
IV D 21 to 60 days 
V D 61 days and over 
(Check only one) 
□Petty 
□Minor 
D Misdemeanor 
E]Felony 
6. 
Has this case been previously filed in this District Court? (Yes orNo)No 
---
If yes, Judge ___________ Case No. _________________ _ 
7. 
Has a complaint been filed in this matter? (Yes or No) No 
---
If yes, Judge ____________ Magistrate Case No. ______________ _ 
8. 
Does this case relate to a previously filed matter in this District Court? (Yes or No)~ 
If yes, Judge ____________ Case No. __________________ _ 
9. 
Defendant(s) in federal custody as of _______________________ _ 
10. 
Defendant(s) in state custody as of _________________________ _ 
11 . 
Rule 20 from the _____ District of ______ _ 
12. 
ls this a potential death penalty case? (Yes or No)~ 
13. 
Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Office 
prior to October 3, 2019 (Mag. Judge Jared M. Strauss)? (Yes or No) _N_o_ 
14. 
Did this matter involve the participation of or consultation with Magistrate Judge Eduardo I. Sanchez 
during his tenure at the U.S. Attorney's Office, which concluded on January 22, 2023? _N_o __ 
15. 
Did this matter involve the participation of or consultation with Magistrate Judge Marty Fulgueira 
Elfenbein during her tenure at the U.S. Attorney's Office, which concluded on March 5, 2024? ~ 
16. 
Did this matter involve the participation of or consultation with Magistrate Judge Ellen F. D' Angelo 
during her tenure at the U.S. Attorney's Office, which concluded on October 7, 2024?~ 
By ~ 
£, __.. 
Aimee C. Jimenez 
r 
l 
Assistant United States Attorney 
SDFL Court ID No. A5500795 
26-CR-60019-ALTMAN/STRAUSS
Case 0:26-cr-60019-RKA   Document 1   Entered on FLSD Docket 01/26/2026   Page 10 of 12

U ITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
PENALTY SHEET 
Defendant's 
ame: ROODY METELUS 
Case No: ______________________________ _ 
Count#: 1 
Conspiracy to Commit Wire Fraud 
Title 18 United States Code Section 371 
*Max. Term of Imprisonment: 5 years 
*Mandatory Min. Term of Imprisonment (if applicable): N/ A 
*Max. Supervised Release: 3 years 
*Max. Fine: $250,000 or twice the gross gain or gross loss resulting from the offense. 
*Refers only to possible term of incarceration, does not include possible fines, restitution, 
special assessments, parole terms, or forfeitures that may be applicable. 
Case 0:26-cr-60019-RKA   Document 1   Entered on FLSD Docket 01/26/2026   Page 11 of 12

AO 455 (Rev. 0 1/09) Wai ver of an Indictment 
UNITED STATES DISTRICT COURT 
United States of America 
V. 
ROODY METELUS, 
Defendant 
for the 
Southern District of Florida 
Case No. 
W AIYER OF AN INDICTMENT 
I understand that I have been accused of one or more offenses punishable by imprisonment for more than one 
year. I was advised in open court of my rights and the nature of the proposed charges against me. 
After receiving this advice, I waive my righL to prosecution by indictment and consent to prosecution by 
information. 
Da~: 
12/ 18/2 025 
Signature of defendant's al/orney 
Printed name of defendant 's attom ey 
Judge 's signature 
Judge's printed name and tirle 
26-CR-60019-ALTMAN/STRAUSS
Case 0:26-cr-60019-RKA   Document 1   Entered on FLSD Docket 01/26/2026   Page 12 of 12

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