Criminal information — U.S. v. Rose (PPP conspiracy, D. Ariz.)

Record facts

UNITED STATES DISTRICT COURT · No. 2:25-cr-01188-SPL · Doc. 2 · 2025-08-27 · Docket on CourtListener

Full text

1
2
3
4
5
6
7
8
9
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20
21 
22 
23 
24 
25 
26 
27 
28 
TIMOTHY COURCHAINE 
United States Attorney 
District of Arizona 
ARON KETCHEL 
Assistant United States Attorney 
Arizona State Bar No. 038421 
Two Renaissance Square 
40 N. Central Ave., Suite 1800 
Phoenix, Arizona 85004 
Telephone: 602-514-7500 
Email: aron.ketchel@usdoj.gov 
Attorneys for Plaintiff 
IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF ARIZONA 
United States of America, 
Plaintiff, 
vs. 
Shakia Michelle Rose, 
Defendant. 
No. 
I N F O R M A T I O N 
VIO: 
18 U.S.C. § 371 
(Conspiracy) 
Count 1 
THE UNITED STATES ATTORNEY’S OFFICE CHARGES: 
INTRODUCTION 
1.
At all times relevant to this Information, defendant SHAKIA ROSE
conspired and schemed with others to prepare and submit false and fraudulent Paycheck 
Protection Program (“PPP”) loan applications to various lending institutions, including 
Harvest Small Business Finance, LLC; BSD Capital, LLC, doing business as Lendistry; 
Capital Plus Financial, LLC; Benworth Capital; and Fountainhead SBF LLC, participating 
lenders helping to provide government-backed, emergency financial assistance to 
businesses suffering from the economic impact of the COVID-19 pandemic. Defendant 
submitted loan applications replete with false and fraudulent information, including false 
CR-25-01188-PHX-SPL (ESW)
FILED
LODGED
CLERK U.S. DISTRICT COURT 
DISTRICT OF ARIZONA
Aug 27 2025
Case 2:25-cr-01188-SPL     Document 2     Filed 08/27/25     Page 1 of 16

 
- 2 - 
 
1
2
3
4
5
6
7
8
9
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20
21 
22 
23 
24 
25 
26 
27 
28 
 
income amounts. As a result of the fraud conspiracy, defendant personally received more 
than $40,000 in government-guaranteed loans and defendant conspired with others to 
obtain over $300,000 in government-guaranteed loans, which should have gone to real 
businesses that were harmed by the COVID-19 pandemic.  
SMALL BUSINESS ADMINISTRATION 
2. 
The United States Small Business Administration (“SBA”) was an executive-
branch agency of the United States government that provided financial 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. As 
part of this effort, the SBA facilitated loans through banks, credit unions, and other lenders. 
These loans had government-backed guarantees if certain requirements were met.   
PAYCHECK PROTECTION PROGRAM BACKGROUND 
3. 
The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was a 
federal law enacted in March 2020 and was designed to provide emergency financial 
assistance to the millions of Americans suffering from the economic effects caused by the 
COVID-19 pandemic. One source of relief the CARES Act provided, through a program 
referred to as the Paycheck Protection Program (“PPP”), was authorization of up to $349 
billion in potentially forgivable loans to small businesses for payroll, job retention, 
mortgage interest, rent/lease, utilities, and certain other applicable expenses.  
4. 
The first phase of the PPP loan process was implemented between March 
2020 and March 31, 2021. PPP loans had an interest rate of one percent. Loans issued prior 
to June 5, 2020, had a maturity of two years, while loans issued after June 5, 2020, had a 
maturity of five years. Each loan draw had a specific application process and requirements. 
SBA would forgive PPP loans if all employee retention criteria were met, and the funds 
were used for eligible expenses within a designated period as set forth in the PPP.  
Case 2:25-cr-01188-SPL     Document 2     Filed 08/27/25     Page 2 of 16

 
- 3 - 
 
1
2
3
4
5
6
7
8
9
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20
21 
22 
23 
24 
25 
26 
27 
28 
 
PPP LOAN APPLICATION PROCESS
5. 
The SBA oversaw the entire PPP and fully guaranteed every legitimate PPP 
loan. The individual PPP loans, however, were issued by private, SBA-approved lenders 
who received and processed the PPP applications. Thus, the loans were made from the 
lenders’ own funds.  
6. 
To apply for a PPP loan, a qualifying business was required to submit a PPP 
loan application to a participating lender. The lender then transmitted the relevant data for 
processing the loan to the SBA. This included the borrower’s information, the total amount 
of the loan, and the listed number of employees.   
7. 
In the PPP loan application (SBA Form 2483-C), an individual claiming to 
operate a sole proprietorship had to verify the business’s gross income and the purpose of 
the loan. The gross income figure was used to calculate the amount of money the business 
was eligible to receive under the PPP. The maximum PPP loan amount a sole proprietorship 
business could receive was 2.5 times the business’s average gross monthly income costs, 
up to $20,833. 
8. 
 The PPP loan application required the applicant to make several affirmative 
certifications. Among them, the applicant was required to certify, in pertinent part, that 
each of the following statements were true: 
a. The Applicant was in operation on February 15, 2020, and was an 
eligible self-employed individual, independent contractor, or sole 
proprietorship with no employees; 
b. Current economic uncertainty makes this loan necessary to support 
the ongoing operations of the Applicant; 
c. The funds would be used to make mortgage interest payments, rent, 
utilities, covered operations expenditures, covered property damage 
costs, and covered supplier costs, as specified under the PPP Rules, 
and; 
Case 2:25-cr-01188-SPL     Document 2     Filed 08/27/25     Page 3 of 16

- 4 -
1
2
3
4
5
6
7
8
9
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20
21 
22 
23 
24 
25 
26 
27 
28 
d. The information provided in the application and information provided
in all supporting documents and forms was true and accurate in all
material respects.
PPP LOAN FORGIVENESS APPLICATION PROCESS 
9.
Under the applicable PPP rules, the full principal of the PPP loan and any
accrued interest was eligible for forgiveness if, during the 8-to-24-week period following 
loan disbursement, the applicant used the PPP loan on permissible business-related 
expenses. To apply for loan forgiveness for sole-proprietor loans, the borrower was 
required to complete a Loan Forgiveness Application (SBA Form 3508S) and submit it to 
its lender, or the lender that was servicing the PPP loan.  
10.
At any time up to the maturity date of the loan, a borrower could apply for
loan forgiveness so long as all the loan proceeds for which the borrower was requesting 
forgiveness had been used. 
11.
If borrowers did not apply for forgiveness within ten months after the last
day of the covered period, then PPP loan payments were no longer deferred, and borrowers 
were required to repay their loans to their PPP lender. 
12.
Like the PPP loan application, the PPP Loan Forgiveness Application
required the applicant to make several affirmative certifications. Among them, the 
applicant was required to certify the following pertinent statements were true: 
a. The Borrower complied with all requirements in the PPP Rules,
including rules related to eligible uses of PPP loan proceeds; and
b. “The information provided in this application is true and correct in all
material respects.”
FINANCIAL INSTITUTIONS AND PARTICIPATING PPP LENDERS 
13. Harvest Small Business, LLC; BSD Capital, LLC, doing business as 
Lendistry; Capital Plus Financial, LLC; Benworth Capital; and Fountainhead SBF LLC, 
all participated in the SBA’s PPP as lenders, and as such, were authorized to lend funds to 
eligible borrowers under the terms of the PPP.  
Case 2:25-cr-01188-SPL     Document 2     Filed 08/27/25     Page 4 of 16

 
- 5 - 
 
1
2
3
4
5
6
7
8
9
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20
21 
22 
23 
24 
25 
26 
27 
28 
 
COUNT 1 
Conspiracy
[18 U.S.C. § 371] 
14. 
The factual allegations in the preceding paragraphs are incorporated by 
reference and re-alleged as though fully set forth herein. 
15. 
Beginning in or about March 2021, and continuing through on or about 
February 2023, in the District of Arizona and elsewhere, defendant SHAKIA ROSE did 
conspire, confederate, and agree with others known to the U.S. Attorney’s Office, to 
willfully and knowingly devise a scheme and artifice to defraud several financial 
institutions that were authorized to lend funds to eligible borrowers under the terms of the 
PPP, including Harvest Small Business Finance, LLC; BSD Capital, LLC, doing business 
as Lendistry; Capital Plus Financial, LLC; Benworth Capital; and Fountainhead SBF LLC, 
each participating lenders helping to provide government-backed, emergency financial 
assistance to businesses suffering from the economic impact of the Covid pandemic, and 
under the auspices of the United States Small Business Administration, by means of false 
and fraudulent pretenses, representation, and promises, including preparing and submitting 
false and fraudulent PPP loan applications in order to obtain approximately $351,237 in 
government-guaranteed loans through the Paycheck Protection Program (PPP).   
OBJECT OF THE CONSPIRACY 
16. 
It was the object of the conspiracy for defendant and her co-conspirators to 
commit wire fraud in violation of 18 U.S.C. § 1343, and transactional money laundering 
in violation of 18 U.S.C. § 1957.  
MANNER AND MEANS OF THE CONSPIRACY AND FRAUD SCHEMES 
17. 
The manner and means by which the defendant and her co-conspirators 
sought to accomplish the objectives of the conspiracy and fraud schemes included, among 
other things, the following:     
a. 
Submitting PPP loan applications containing false IRS Form 1040, Schedule 
Cs purporting to show that in 2019, multiple individuals operated sole 
Case 2:25-cr-01188-SPL     Document 2     Filed 08/27/25     Page 5 of 16

 
- 6 - 
 
1
2
3
4
5
6
7
8
9
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20
21 
22 
23 
24 
25 
26 
27 
28 
 
proprietorships in which they each earned over $100,000. In fact, these same 
individuals did not operate sole proprietorships but instead many were 
employed by the federal government or served as federal government 
contractors in 2019. Moreover, no such Schedule Cs were ever filed with the 
IRS on behalf of these individuals. 
b. 
Defendant and her co-conspirators falsely claimed that these entities needed 
these PPP loans to support their ongoing operation and were operating in 
February 2020.  In fact, at the time these applications were filed, none of the 
entities were operating in February 2020 in a manner that made them eligible 
for a PPP loan. 
c. 
Defendant and her co-conspirators filed PPP forgiveness applications in 
which they sought forgiveness of the full amounts of the loans and attested 
that the PPP loans had been used for eligible purposes, including funding 
ongoing operations of the sole proprietorships.  
d. 
After each PPP loan was funded and deposited, defendant and her co-
conspirators used the funds for personal expenses and transferred funds 
between co-conspirators.   
e. 
Defendant received payments from her co-conspirators after her co-
conspirators received fraudulent PPP loans. 
OVERT ACTS 
18. 
In furtherance of the conspiracy, and to effect the objects thereof, the 
following overt acts, among others, were committed in the District of Arizona, and 
elsewhere:    
a. 
On or about March 16, 2021, defendant prepared and submitted, or caused to 
be prepared and submitted, a fraudulent PPP application for herself that was 
submitted to Fountainhead SBF LLC. The application sought a loan in the 
amount of approximately $20,833. Among other things, the PPP application 
Case 2:25-cr-01188-SPL     Document 2     Filed 08/27/25     Page 6 of 16

 
- 7 - 
 
1
2
3
4
5
6
7
8
9
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20
21 
22 
23 
24 
25 
26 
27 
28 
 
included false representations about defendant’s employment status and 
defendant’s gross income from her business in 2019. 
b. 
On or about April 5, 2021, defendant prepared and submitted, or caused to 
be prepared and submitted, a fraudulent PPP application for co-conspirator 
J.M. that was submitted to Harvest Small Business Finance, LLC. The 
application sought a loan in the amount of approximately $20,437. Among 
other things, the PPP application included false representations about J.M.’s 
employment status and the gross income from J.M.’s business in 2019. 
c. 
On or about April 12, 2021, after receiving her PPP loan, co-conspirator J.M. 
wrote a check in the amount of $20,437 to a business entity controlled by co-
conspirators C.H. and A.F. 
d. 
On or about April 5, 2021, defendant prepared and submitted, or caused to 
be prepared and submitted, a fraudulent PPP application for co-conspirator 
C.H. that was submitted to Harvest Small Business Finance, LLC. The 
application sought a loan in the amount of approximately $20,833. Among 
other things, the PPP application included false representations about C.H.’s 
employment status and the gross income from C.H.’s business in 2019. 
e. 
On or about April 5, 2021, defendant prepared and submitted, or caused to 
be prepared and submitted, a fraudulent PPP application for co-conspirator 
A.F. that was submitted to Harvest Small Business Finance, LLC. The 
application sought a loan in the amount of approximately $20,806. Among 
other things, the PPP application included false representations about A.F.’s 
employment status and the gross income from A.F.’s business in 2019. 
f. 
On or about April 9, 2021, defendant prepared and submitted, or caused to 
be prepared and submitted, a second fraudulent PPP application for co-
conspirator C.H. that was submitted to Harvest Small Business Finance, 
LLC. The application sought a loan in the amount of approximately $20,833. 
Among other things, the PPP application included false representations about 
Case 2:25-cr-01188-SPL     Document 2     Filed 08/27/25     Page 7 of 16

 
- 8 - 
 
1
2
3
4
5
6
7
8
9
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20
21 
22 
23 
24 
25 
26 
27 
28 
 
C.H.’s employment status and the gross income from C.H.’s business in 
2019. 
g. 
On or about April 9, 2021, defendant prepared and submitted, or caused to 
be prepared and submitted, a second fraudulent PPP application for co-
conspirator A.F. that was submitted to Harvest Small Business Finance, 
LLC. The application sought a loan in the amount of approximately $20,806. 
Among other things, the PPP application included false representations about 
A.F.’s employment status and the gross income from A.F.’s business in 2019. 
h. 
On or about April 10, 2021, defendant received a payment through Venmo 
in the amount of $2,500 from a bank account controlled by co-conspirators 
C.H. and A.F. 
i. 
On or about April 10, 2021, defendant prepared and submitted, or caused to 
be prepared and submitted, a second fraudulent PPP application for co-
conspirator J.M. that was submitted to Harvest Small Business Finance, 
LLC. The application sought a loan in the amount of approximately $20,437. 
Among other things, the PPP application included false representations about 
J.M.’s employment status and the gross income from J.M.’s business in 2019. 
j. 
On or about April 27, 2021, after receiving her second PPP loan, co-
conspirator J.M. wrote a check in the amount of $20,437 to a business entity 
controlled by co-conspirators C.H. and A.F. 
k. 
On or about April 12, 2021, defendant prepared and submitted, or caused to 
be prepared and submitted, a second fraudulent PPP application for herself 
that was submitted to Fountainhead SBF LLC. The application sought a loan 
in the amount of approximately $20,833. Among other things, the PPP 
application included false representations about defendant’s employment 
status and defendant’s gross income from her business in 2019. 
l. 
On or about April 14, 2021, defendant prepared and submitted, or caused to 
be prepared and submitted, a fraudulent PPP application for co-conspirator 
Case 2:25-cr-01188-SPL     Document 2     Filed 08/27/25     Page 8 of 16

 
- 9 - 
 
1
2
3
4
5
6
7
8
9
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20
21 
22 
23 
24 
25 
26 
27 
28 
 
L.T. that was submitted to Harvest Small Business Finance, LLC. The 
application sought a loan in the amount of approximately $20,697. Among 
other things, the PPP application included false representations about L.T.’s 
employment status and the gross income from L.T.’s business in 2019. 
m. 
On or about April 17, 2021, defendant received a payment through Venmo 
in the amount of $2,500 from a bank account controlled by co-conspirators 
C.H. and A.F. 
n. 
On or about April 25, 2021, defendant received a check in the amount of 
$10,000 from co-conspirator A.F. 
o. 
On or about April 29, 2021, after receiving his PPP loan, co-conspirator L.T. 
wired $10,000 to a business entity controlled by co-conspirators C.H. and 
A.F. 
p. 
On or about April 15, 2021, defendant prepared and submitted, or caused to 
be prepared and submitted, a fraudulent PPP application for co-conspirator 
J.D. that was submitted to Benworth Capital. The application sought a loan 
in the amount of approximately $20,445. Among other things, the PPP 
application included false representations about J.D.’s employment status 
and the gross income from J.D.’s business in 2019. 
q. 
On or about April 24, 2021, after receiving her PPP loan, co-conspirator J.D. 
wrote a check in the amount of $9,500 to co-conspirator A.F. 
r. 
On or about April 16, 2021, defendant prepared and submitted, or caused to 
be prepared and submitted, a fraudulent PPP application for co-conspirator 
A.J. that was submitted to Benworth Capital. The application sought a loan 
in the amount of approximately $20,833. Among other things, the PPP 
application included false representations about A.J.’s employment status 
and the gross income from A.J.’s business in 2019. 
Case 2:25-cr-01188-SPL     Document 2     Filed 08/27/25     Page 9 of 16

 
- 10 - 
 
1
2
3
4
5
6
7
8
9
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20
21 
22 
23 
24 
25 
26 
27 
28 
 
s.
On or about April 26, 2021, after receiving her PPP loan, co-conspirator A.J. 
made an electronic payment in the amount of $10,000 to a bank account 
jointly controlled by co-conspirators C.H. and A.F. 
t. 
On or about April 17, 2021, defendant prepared and submitted, or caused to 
be prepared and submitted, a second fraudulent PPP application for co-
conspirator L.T. that was submitted to Harvest Small Business Finance, LLC. 
The application sought a loan in the amount of approximately $20,697. 
Among other things, the PPP application included false representations about 
L.T.’s employment status and the gross income from L.T.’s business in 2019. 
u. 
On or about May 21, 2021, after receiving his second PPP loan, co-
conspirator L.T. wired $10,000 to a bank account jointly controlled by co-
conspirators C.H. and A.F. 
v. 
On or about April 20, 2021, defendant prepared and submitted, or caused to 
be prepared and submitted, a fraudulent PPP application for co-conspirator 
A.H. that was submitted to Benworth Capital. The application sought a loan 
in the amount of approximately $20,472. Among other things, the PPP 
application included false representations about A.H.’s employment status 
and the gross income from A.H.’s business in 2019. 
w. 
On or about May 3, 2021, after A.H. received her PPP loan, co-conspirator 
A.H. wired $10,000 to a business entity controlled by co-conspirators C.H. 
and A.F. 
x. 
On or about April 27, 2021, defendant prepared and submitted, or caused to 
be prepared and submitted, a fraudulent PPP application for co-conspirator 
P.H. that was submitted to Harvest Small Business Finance, LLC. The 
application sought a loan in the amount of approximately $20,485. Among 
other things, the PPP application included false representations about P.H.’s 
employment status and the gross income from P.H.’s business in 2019. 
Case 2:25-cr-01188-SPL     Document 2     Filed 08/27/25     Page 10 of 16

 
- 11 - 
 
1
2
3
4
5
6
7
8
9
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20
21 
22 
23 
24 
25 
26 
27 
28 
 
y.
On or about May 12, 2021, after P.H. received his PPP loan, co-conspirator 
P.H. wired $10,000 to a bank account jointly controlled by co-conspirators 
C.H. and A.F. 
z. 
On or about May 3, 2021, defendant received a payment through Venmo in 
the amount of $2,500 from a bank account controlled by co-conspirators C.H. 
and A.F. 
aa. 
On or about May 13, 2021, defendant received a payment through Venmo in 
the amount of $2,500 from a bank account controlled by co-conspirators C.H. 
and A.F. 
bb. 
On or about May 20, 2021, defendant prepared and submitted, or caused to 
be prepared and submitted, a second fraudulent PPP application for co-
conspirator A.H. that was submitted to BSD Capital, LLC dba Lendistry. The 
application sought a loan in the amount of approximately $20,472. Among 
other things, the PPP application included false representations about A.H.’s 
employment status and the gross income from A.H.’s business in 2019. 
cc. 
On or about June 8, 2021, after receiving her second PPP loan, co-conspirator 
A.H. wired $9,980 to a business entity controlled by co-conspirators C.H. 
and A.F. 
dd. 
On or about May 22, 2021, defendant received a payment through Venmo in 
the amount of $2,500 from a bank account controlled by co-conspirators C.H. 
and A.F. 
ee. 
On or about May 28, 2021, defendant prepared and submitted, or caused to 
be prepared and submitted, a second fraudulent PPP application for co-
conspirator P.H. that was submitted to BSD Capital, LLC, doing business as 
Lendistry. The application sought a loan in the amount of approximately 
$20,485. Among other things, the PPP application included false 
representations about P.H.’s employment status and the gross income from 
P.H.’s business in 2019. 
Case 2:25-cr-01188-SPL     Document 2     Filed 08/27/25     Page 11 of 16

 
- 12 - 
 
1
2
3
4
5
6
7
8
9
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20
21 
22 
23 
24 
25 
26 
27 
28 
 
ff.
On or about July 7, 2021, after receiving his second PPP loan, co-conspirator 
P.H. wired $9,980 to a bank account jointly controlled by co-conspirators 
C.H. and A.F. 
gg. 
On or about May 29, 2021, defendant received a payment through Venmo in 
the amount of $2,500 from a bank account controlled by co-conspirators C.H. 
and A.F. 
hh. 
On or about June 6, 2021, defendant received a payment through Venmo in 
the amount of $2,500 from a bank account controlled by co-conspirators C.H. 
and A.F. 
ii. 
On or about June 11, 2021, defendant prepared and submitted, or caused to 
be prepared and submitted, a fraudulent PPP application for co-conspirator 
A.J. that was submitted to Capital Plus Financial, LLC. The application 
sought a loan in the amount of approximately $20,833. Among other things, 
the PPP application included false representations about A.J.’s employment 
status and the gross income from A.J.’s business in 2019. 
jj. 
On or about June 15, 2021, defendant received a payment through Venmo in 
the amount of $2,500 from a bank account controlled by co-conspirators C.H. 
and A.F. 
kk. 
On or about June 24, 2021, defendant received a payment through Venmo in 
the amount of $2,500 from a bank account controlled by co-conspirators C.H. 
and A.F. 
ll. 
On or about July 7, 2021, defendant received a payment through Venmo in 
the amount of $2,500 from a bank account controlled by co-conspirators C.H. 
and A.F. 
mm. On or about July 15, 2021, defendant received a payment through Venmo in 
the amount of $2,500 from a bank account controlled by co-conspirators C.H. 
and A.F. 
Case 2:25-cr-01188-SPL     Document 2     Filed 08/27/25     Page 12 of 16

 
- 13 - 
 
1
2
3
4
5
6
7
8
9
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20
21 
22 
23 
24 
25 
26 
27 
28 
 
nn.
On or about August 28, 2021, defendant prepared and submitted, or caused 
to be prepared and submitted, a fraudulent PPP Loan Forgiveness 
Application related to defendant’s PPP loan submitted on or about March 16, 
2021. In the Loan Forgiveness Application, defendant falsely attested that 
she complied with the PPP Rules. 
oo. 
On or about September 3, 2021, defendant prepared and submitted, or caused 
to be prepared and submitted, a fraudulent PPP Loan Forgiveness 
Application for co-conspirator C.H. related to C.H.’s PPP loan submitted on 
or about April 5, 2021. The Loan Forgiveness Application falsely stated that 
that C.H. complied with the PPP Rules. 
pp. 
On or about September 3, 2021, defendant prepared and submitted, or caused 
to be prepared and submitted, a fraudulent PPP Loan Forgiveness 
Application for co-conspirator A.F. related to A.F.’s PPP loan submitted on 
or about April 5, 2021. The Loan Forgiveness Application falsely stated that 
that A.F. complied with the PPP Rules. 
qq. 
On or about September 6, 2021, defendant prepared and submitted, or caused 
to be prepared and submitted, a fraudulent PPP Loan Forgiveness 
Application for co-conspirator J.M. related to J.M.’s PPP loan submitted on 
or about April 5, 2021. The Loan Forgiveness Application falsely stated that 
that J.M. complied with the PPP Rules. 
rr. 
On or about September 6, 2021, defendant prepared and submitted, or caused 
to be prepared and submitted, a fraudulent PPP Loan Forgiveness 
Application for co-conspirator A.H. related to A.H.’s PPP loan submitted on 
or about April 20, 2021. The Loan Forgiveness Application falsely stated that 
that A.H. complied with the PPP Rules. 
ss. 
On or about September 6, 2021, defendant prepared and submitted, or caused 
to be prepared and submitted, a fraudulent PPP Loan Forgiveness 
Application for co-conspirator L.T. related to L.T.’s PPP loan submitted on 
Case 2:25-cr-01188-SPL     Document 2     Filed 08/27/25     Page 13 of 16

 
- 14 - 
 
1
2
3
4
5
6
7
8
9
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20
21 
22 
23 
24 
25 
26 
27 
28 
 
or about April 14, 2021. The Loan Forgiveness Application falsely stated that 
that LT. complied with the PPP Rules. 
tt. 
On or about September 6, 2021, defendant prepared and submitted, or caused 
to be prepared and submitted, a fraudulent PPP Loan Forgiveness 
Application for co-conspirator J.D. related to J.D.’s PPP loan submitted on 
or about April 15, 2021. The Loan Forgiveness Application falsely stated that 
that J.D. complied with the PPP Rules. 
uu. 
On or about September 11, 2021, defendant prepared and submitted, or 
caused to be prepared and submitted, a fraudulent PPP Loan Forgiveness 
Application for co-conspirator P.H. related to P.H.’s PPP loan submitted on 
or about April 27, 2021. The Loan Forgiveness Application falsely stated that 
that P.H. complied with the PPP Rules. 
vv. 
On or about September 12, 2021, defendant prepared and submitted, or 
caused to be prepared and submitted, a fraudulent PPP Loan Forgiveness 
Application for co-conspirator A.J. related to A.J.’s PPP loan submitted on 
or about April 16, 2021. The Loan Forgiveness Application falsely stated that 
that A.J. complied with the PPP Rules. 
ww. On or about September 29, 2021, defendant prepared and submitted, or 
caused to be prepared and submitted, a fraudulent PPP Loan Forgiveness 
Application for co-conspirator J.M. related to J.M.’s PPP loan submitted on 
or about April 10, 2021. The Loan Forgiveness Application falsely stated that 
that J.M. complied with the PPP Rules. 
xx. 
On or about September 29, 2021, defendant prepared and submitted, or 
caused to be prepared and submitted, a fraudulent PPP Loan Forgiveness 
Application for co-conspirator P.H. related to P.H.’s PPP loan submitted on 
or about May 28, 2021. The Loan Forgiveness Application falsely stated that 
that P.H. complied with the PPP Rules. 
Case 2:25-cr-01188-SPL     Document 2     Filed 08/27/25     Page 14 of 16

 
- 15 - 
 
1
2
3
4
5
6
7
8
9
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20
21 
22 
23 
24 
25 
26 
27 
28 
 
yy.
On or about September 29, 2021, defendant prepared and submitted, or 
caused to be prepared and submitted, a fraudulent PPP Loan Forgiveness 
Application for co-conspirator L.T. related to L.T.’s PPP loan submitted on 
or about April 17, 2021. The Loan Forgiveness Application falsely stated that 
that L.T. complied with the PPP Rules. 
zz. 
On or about September 29, 2021, defendant prepared and submitted, or 
caused to be prepared and submitted, a fraudulent PPP Loan Forgiveness 
Application related to defendant’s PPP loan submitted on or about April 12, 
2021. In the Loan Forgiveness Application, defendant falsely attested that 
she complied with the PPP Rules. 
aaa. 
On or about October 9, 2021, defendant prepared and submitted, or caused 
to be prepared and submitted, a fraudulent PPP Loan Forgiveness 
Application for co-conspirator C.H. related to C.H.’s PPP loan submitted on 
or about April 9, 2021. The Loan Forgiveness Application falsely stated that 
that C.H. complied with the PPP Rules. 
bbb. On or about October 9, 2021, defendant prepared and submitted, or caused 
to be prepared and submitted, a fraudulent PPP Loan Forgiveness 
Application for co-conspirator A.F. related to A.F.’s PPP loan submitted on 
or about April 9, 2021. The Loan Forgiveness Application falsely stated that 
that A.F. complied with the PPP Rules. 
ccc. 
On or about December 10, 2021, defendant prepared and submitted, or 
caused to be prepared and submitted, a fraudulent PPP Loan Forgiveness 
Application for co-conspirator A.H. related to A.H.’s PPP loan submitted on 
or about May 20, 2021. The Loan Forgiveness Application falsely stated that 
that A.H. complied with the PPP Rules. 
ddd. On or about December 10, 2021, defendant prepared and submitted, or 
caused to be prepared and submitted, a fraudulent PPP Loan Forgiveness 
Application for co-conspirator A.J. related to A.J.’s PPP loan submitted on 
Case 2:25-cr-01188-SPL     Document 2     Filed 08/27/25     Page 15 of 16

 
- 16 - 
 
1
2
3
4
5
6
7
8
9
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20
21 
22 
23 
24 
25 
26 
27 
28 
 
or about June 11, 2021. The Loan Forgiveness Application falsely stated that 
that A.J. complied with the PPP Rules. 
All in violation of Title 18, United States Code, Section 371. 
 
Dated this 26th day of August, 2025. 
TIMOTHY COURCHAINE 
United States Attorney 
District of Arizona 
 
 
 
 
 
 
 
 
 
ARON KETCHEL
Assistant U.S. Attorney 
Case 2:25-cr-01188-SPL     Document 2     Filed 08/27/25     Page 16 of 16

File and source

File

doc-002-Rose.pdf

Size

609,291 bytes

SHA-256

310eb3cb91c51362d4553ff3f40c0afcf24613010a6f51102072337de052a0a0

Our copy

doc-002-Rose.pdf

Original

No public link identified.