Factual Proffer — United States v. Roody Metelus (S.D. Fla.)

Record facts

U.S. District Court, Southern District of Florida · No. 0:26-cr-60019-RKA · Doc. 24 · 2026-04-27 · Docket on CourtListener

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.IJNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.26-CR-60019-ALTM AN
UNITED STATES OF AM ERICA
VS.
RO O DY M ETELU S,
D efendant.
/
FACTUAL PROFFER
The United States of America and Defendant Roody M etelus (tEMETELUS'') agree that
had this case proceeded to trial, the government would have proven, beyond a reasonable doubt,
the following facts, am ong others, pertaining to a violation of Title l 8, United States Code,
Section 37 1, which occurred in the Southem  District of Florida and elsewhere.
From in or around January 2021, through in or around January 2022, M ETELUS, a
resident of Broward County, Florida, willfully and knowingly conspired with others to comm it
wire fraud, and having the intent to defraud, devised and executed a scheme to defraud, by
prepazing false and fraudulent tax fonns for customers to use in the submission of fraudulent
loan applications under the Paycheck Protection Program (ETPP''), a program ftlnded under the
Coronavinzs Aid, Relief, and Economic Security ICICAR-ES''I Act. The PPP loans were funded
by private lenders, but were
(t1SBA'')
100% guaranteed by the U.S. Small Business Administration
M ETELUS was a tax preparer who owned a tax preparation business named JRS Tax
Serdces, LLC, d/b/a Liberty Tax Service, located in Dania Beach, Flolida. JRS Tax Serdces
had a franchise agreem ent with Company 1, which allowed it to use the trademarks, marketing,
Case 0:26-cr-60019-RKA   Document 24   Entered on FLSD Docket 04/27/2026   Page 1 of 5

operating procedures, and operating software of Company l . M ETELUS'S office was located in
Dania Beach, Florida.
Company 1 had arl arrangem ent with Bank 1 for thc franchisecs of Company 1 to submit
PPP applications on behalf of their customers to Bank 1. Starting in January 2021, M ETELUS
recruited his tax custom ers and others to apply for PPP loans. M ETELUS prepared the loan
applications and supporting documents, falsely listing the loan applicants as sole proprietors,
even though many were wage earners who did not have their own business. M ETELUS had the
loan applications submitted to Bank 1 via its on-line system supported by Bank Processor 1.
Both Bank 1 and Bank Processor l were located outside of Florida. The defendant agrees that
the fraud scheme in this case involved the use of interstate wires to further the scheme.
Under the PPP rules, the am ount of annual income that could be reported for an
individual or a sole proprietorship was capped at $100,000, which meant that a PPP loan for a
sole proplietorship would be no more than $20,833 (2.5 x average monthly payroll). A1l of
M ETELUS'S falsified loan applications had the same characteristics: 
the sam e tllree
supporting documents, consisting of a false IRS Schedule C for tax year 2019, a false IRS
Schedule SE for tax year 2019, and a false Self-Employment Ledger for tax year 2020; (2) the
falsified Schedules C listed net incom e from the business in an amount ranging between $95,500
and $99,000, in order to maximize the loan amotmt; (3) the falsified Self-Employment Ledger
listed a breakdown of monthly income and expenses; and (4) the dollar figures on the falsified
Self-Employment Ledger for tax year 2020 were exactly the same as the dollar figures reported
on the falsified Schedule C for tax year 2019.
Between January and M arch of 2021, M ETELUS caused the submission of more than
200 false and fraudulent PPP loan applications to Bank l , which totaled approximately
2
Case 0:26-cr-60019-RKA   Document 24   Entered on FLSD Docket 04/27/2026   Page 2 of 5

$4,151,159 in loan am ounts requested. Bank 1 funded approximately 1 16 PPP loan applications
totaling approximately $2,337,615.
M any of the loan applicants were custom ers of M ETELU S for whom M ETELUS had
prepared tax returns. For instance, A.W . was a customer of M ETELUS going back to 2014.
Company 1 's records indicated that M ETELUS had prepared A.W .'S 2020 tax return and had it
tiled January 23, 2021, three weeks before he prepared the falsified tax docum ents for A.W .'S
PPP loan. A.W .'S 2020 tax return listed that A.W . had earned $38,055 in wages, and had no
Schedule C. For 2019, M ETELUS had prepared A.W .'S tax rettlrn and reported $54,922 in
wages and no Schedule C. Company 1's records also had an unfiled 2019 tax return prepared by
M ETELUS for A.W . with a Schedule C that falsely reported gross income of $121,250 and a net
profit of $96,376.
If called to testify, A .W . would state that when he was at M ETELUS'S offce to have his
taxes prepared, M ETELUS Offered him a PPP loan, and said that it would not need to be paid
back. A.W . would state that METELUS prepared the PPP loan application on his (METELUS'S)
computer and submitled the application on his (A.W .'s) behalf. A.W . would state that he did not
provide M ETELUS any of the false figtzres, and that M ETELUS presented him with the Self-
Employment Ledger containing false amounts, which A.W . proceeded to sign because he wanted
the loan money. On or about February 14, 2021, Bank 1 received a false PPP loan application
subm itted through its on-line portal on behalf of A.W . that contained a false 2019 Schedule C, a
false 2019 Schedule SE, and a false Self-Employment Ledger for 2020. The false Schedule C
listed gross income of $121,250, and net income of $96,376. Bank 1 disbttrsed a PPP loan in the
amotmt of $17,525. A.W . would testify that METELUS charged him $1,500 for the loan
Case 0:26-cr-60019-RKA   Document 24   Entered on FLSD Docket 04/27/2026   Page 3 of 5

application, and that he paid M ETELUS in cash.
M any of the loan applicants were not prior customers of M ETELUS, but people who
were referred to M ETELUS for a PPP loan. These non-lwiberty Tax Service customers were
reflected on Company l 's records as ûtwalk-outs,'' as people for whom M ETELUS had begun to
prepare a tax document, but the tax docum ent had not been completed and filed with the IRS.
For instance, Company 1's records indicated that on M arch 2, 2021, M ETELUS had prepared a
tax docum ent for W .B., but it had not been submitted to the IRS and W .B. was listed as a Elwalk-
out'' from M ETELUS'S office. In fact, on or about M arch 2, 2021, M ETELUS caused the
submission of a false and fraudulent PPP loan application to Bank 1 on behalf of W .B., which
included a falsified 2019 Schedule C for a business with a net income of $97,508, a 2019
Schedule SE, and a Self-Employment Ledger signed M arch 2, 2021. Bank l disbursed a PPP
loan to W .B. in the approximate amount of $20,453.12.
After Bank 1 stopped approving PPP loans submitted by M ETELUS, M ETELUS assisted
W .B. in applying for a fraudulent second draw PPP loan using a different lender. The fraudulent
loan application included a falsified 2020 Schedule C that reported W .B. had net income from a
business in the am ount of $95,156. The Schedules C used for both loans indicated that W .B. was
a personal trainer. On or about M ay 13, 2021, the lender disbursed the am ount of $20,833 to
W .B. The 1RS reported that W .B. had filed no tax returlzs for tax years 2019 or 2020.
If called to testify, W .B. would state that he was put in contact with M ETELUS through a
friend as someone who could get him m oney. W .B. met with M ETELUS at his office, and later
provided his friend with W .B.'S personal identifiers, including his bank account and email
address, which his friend was to pass along to M ETELUS. W .B. understood that he would not
have to pay the loan back. W .B. would deny that he was a personal trainer, or that he had said to
Case 0:26-cr-60019-RKA   Document 24   Entered on FLSD Docket 04/27/2026   Page 4 of 5

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anyone that he was a personal trainer, or that he had a business of any kind. Rcgarding the
second draw loan, W .B. would testify that M ETELUS contacted him about it, and that he did not
need to provide his information again because M ETELUS already had it. W .B. paid some
portion of his loan proceeds to M ETELUS and to the friend who referred him to M ETELUS.
W .B. believes he paid them through a combination of cash and cash app.
M ETELUS'S bank account reflects that between M ay 27, 2021 and June 3, 2021, W .B.
made Zelle paym ents to M ETELUS'S bank account totaling $4,700, including a paym ent of
$1,000 on June 3, 2021 .
The defendant agrees that as part of this wire fraud scheme, he owes restitm ion to the
SBA for loans funded by Bank l in the amount of $2,337,615.
Date: 
7 7 &
By:
Date: 12/15/2025
By :
JASON A. REDW G QUX ONES
UNITED STATES ATTQRNEY
EE C. JIM 
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ASSISTANT 
ITED STATES ATTORNEY
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oAvlo TARRA ,
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A'rrroltxsv Folt THE DEFENDANT
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ROODY TELUS
DEFENDANT
Date: 12/17/2025
By:
Case 0:26-cr-60019-RKA   Document 24   Entered on FLSD Docket 04/27/2026   Page 5 of 5

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