Grand jury indictment — US v. Sanders et al.

Record facts

UNITED STATES DISTRICT COURT FOR THE · No. 4:24-cr-00029-BP · Doc. 1 · 2024-02-06 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT FOR THE 
WESTERN DISTRICT OF MISSOURI 
WESTERN DIVISION 
 
 
UNITED STATES OF AMERICA, 
Plaintiff,
 
v. 
 
DAISHA SANDERS (01), 
[DOB:  10/17/1991] 
 
JOEL WRIGHT (02), 
[DOB: 02/19/1989] 
 
DENISE SANDERS (03), 
[DOB: 01/12/1964] 
 
RASHONDA GOLDEN (04), 
[DOB:  09/25/1989] 
 
ROXANNE NAZIR (05), 
[DOB: 08/05/1985] 
 
KIANDRA CROWE (06), 
[DOB:  08/03/1990] 
 
JEFFERY CHILLIS II (07), 
[DOB:  07/02/1993] 
 
SHAQUILLE FIELDER (08), 
[DOB:  12/22/1992] 
 
ALFRED HAYES IV (09), 
[DOB:  03/10/1994] 
 
LUANA McNURLIN (10), 
[DOB:  07/05/1987] 
 
JORDAN NICHOLS (11), 
[DOB:  08/21/1993] 
 
Defendants. 
Case No.   
 
COUNT ONE: 
18 U.S.C. § 1349 
(Conspiracy to Commit Wire Fraud) 
NMT 20 Years Imprisonment 
NMT $250,000 Fine 
NMT 3 Years Supervised Release 
Class C Felony 
 
COUNTS TWO - TWELVE: 
18 U.S.C. § 1343 
(Wire Fraud) 
NMT 20 Years Imprisonment 
NMT $250,000 Fine 
NMT 3 Years Supervised Release 
Class C Felony 
 
COUNT THIRTEEN: 
18 U.S.C. § 1957 
(Money Laundering) 
NMT 10 Years Imprisonment 
NMT $250,000 Fine 
NMT 3 Years Supervised Release 
Class C Felony 
 
ALLEGATION OF CRIMINAL 
FORFEITURE
18 U.S.C. § 981(a)(1)(C) 
28 U.S.C. § 2461 
 
$100 Mandatory Special Assessment Each 
Count 
24-00029-01/11-CR-W-BP
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DEFENDANT NO.
DEFENDANT NAME 
COUNTS CHARGED
1
DAISHA SANDERS 
1 - 13 and Forfeiture 
Allegation
2
JOEL WRIGHT 
1 & 3 
3
DENISE SANDERS  
1 & 4  
4
RASHONDA GOLDEN  
1 & 5   
5
ROXANNE NAZIR 
1 & 6  
6
KIANDRA CROWE  
1 & 7  
7
JEFFERY CHILLIS II
1 & 8 
8
SHAQUILLE FIELDER 
1 & 9 
9
ALFRED HAYES IV 
1 & 10 
10
LUANA McNURLIN 
1 & 11 
11
JORDAN NICHOLS 
1 & 12 
I N D I C T M E N T 
THE GRAND JURY CHARGES THAT: 
COUNT ONE 
At all times material to this Indictment: 
Introduction 
1. 
Beginning no later than on or about February 2021, and continuing until at
least July 2022, in Jackson County, within the Western District of Missouri and elsewhere,
DAISHA SANDERS, JOEL WRIGHT, DENISE SANDERS, RASHONDA GOLDEN, 
ROXANNE NAZIR, KIANDRA CROWE, JEFFERY CHILLIS II, SHAQUILLE FIELDER, 
ALFRED HAYES IV, LUANA McNURLIN, and JORDAN NICHOLS, defendants herein, 
conspired, confederated and agreed with each other and persons known and unknown to the
grand jury, to electronically submit false and fraudulent applications for Paycheck 
Protection Program (PPP) loans affecting interstate commerce. The scheme caused over $220,000 
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in fraudulent PPP loans to be issued to ineligible borrowers, some of which were forgiven even 
though the funds were not used for the purposes specified in the PPP. 
2. 
Defendant DAISHA SANDERS, a resident of Blue Springs, Missouri, prepared 
and filed fraudulent PPP loan applications on behalf of other persons. Generally, she charged fees 
of up to $5,000 for her assistance in filing false and fraudulent PPP loans. DAISHA SANDERS 
would create or work with a person known to the Grand Jury to create counterfeit bank records 
and IRS Forms Schedule C for nonexistent businesses or with inflated income for existing 
businesses to qualify the borrower for a PPP loan. DAISHA SANDERS submitted and caused to 
be submitted false and fraudulent PPP loan applications and counterfeit IRS Forms Schedule C to 
the Small Business Administration (SBA) and lenders outside the State of Missouri. 
I.
THE PAYCHECK PROTECTION PROGRAM 
3. 
On March 27, 2020, the President signed into law the Coronavirus Aid, Relief, and 
Economic Security Act (“The Cares Act”), an economic stimulus bill that, among  other things, 
provided emergency assistance to small business owners, including agricultural businesses,
and nonprofit organizations in all U.S. states, Washington D.C., and territories affected by 
the COVID-19 pandemic. One source of relief provided by the CARES Act was the
authorization of up to $349 billion in forgivable loans to small businesses for job retention and 
certain other expenses, through a program referred to as the Paycheck Protection Program (“PPP”).
Additional PPP funding was authorized in legislation enacted on or about December 27, 2020, and 
March 11, 2021. 
4.
As discussed more fully below, the PPP program, which is operated by the 
Small Business Administration (“SBA”) provided small businesses with funding to meet specific
business obligations, including payroll and rent. The PPP permitted participating third-party 
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lenders to approve and disburse SBA-backed PPP loans to cover payroll, fixed debts, utilities, 
rent/mortgage, accounts payable and other bills incurred by qualifying businesses during, and 
resulting from, the COVID-19 pandemic. PPP loans are fully guaranteed by the SBA. In the event 
of default, SBA will fully satisfy the lender for any balance remaining on the loan. Further, SBA
will forgive any loan up to 100 percent if the borrower establishes it utilized 60 percent of the loan 
on payroll costs in the 24-week period post-disbursement, with the remaining 40 percent going 
toward covered mortgage interest payments, covered rent payments, covered utilities, covered 
operations expenditures, covered property damage costs, covered supplier costs, and covered 
worker protection expenditures. Whatever portion is not forgiven is serviced as a loan. 
5. 
The SBA promulgated regulations concerning eligibility for a PPP loan. Individuals 
who operated a business under a “sole proprietorship” business structure were eligible for a 
PPP loan. To qualify for a PPP loan, individuals had to report and document their income and 
expenses from the sole proprietorship, as typically reported to the Internal Revenue Service on a 
“Form 1040, Schedule C,” for a given tax year. As with other PPP loans, this information and 
supporting documentation was used to calculate the amount of money the individual was entitled 
to receive under the PPP. The maximum loan amount for a sole proprietor with no employees 
was $20,833. 
6. 
A PPP loan application was processed by the third-party participating lender with 
whom the application was filed. If a PPP loan application was approved, the participating lender 
would fund the PPP loan; in order to encourage PPP loans to be issued, the loan was guaranteed 
by the SBA. Data from the application, including information from 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. 
 
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7. 
The proceeds of a PPP loan could be used only for certain specified items, such as 
payroll costs, costs related to the continuation of group health care benefits, or mortgage interest 
payments. The proceeds of a PPP loan were not permitted to be used by the borrowers to purchase 
consumer goods, automobiles, personal residences, clothing, jewelry, to pay the borrower’s 
personal federal income taxes, or to fund the borrower’s ordinary day-to-day living expenses 
unrelated to the specified authorized expenses. 
8. 
The following lenders funded the PPP loans: 
 
Itria Ventures LLC was a national, non-bank, direct commercial lender based in New York 
that funded PPP loans; 
 
Harvest Small Business headquartered in California; 
 
Prestamos CDFI, LLC (Prestamos) was a Community Development Financial Institution 
(CDFI) headquartered in Arizona; and  
 
Capital Plus Financial, LLC was a CDFI headquartered in Bedford, Texas. 
 
COUNT ONE 
The Scheme 
9. 
The allegations set forth in paragraphs 1 through 8 are hereby incorporated in full. 
10.
Beginning on or about February 2021, and continuing through on or 
about July 2022, in Jackson County, within the Western District of Missouri and elsewhere,
the defendants 
DAISHA 
SANDERS, 
JOEL 
WRIGHT, 
DENISE 
SANDERS, 
RASHONDA GOLDEN, ROXANNE NAZIR, KIANDRA CROWE, JEFFERY CHILLIS II, 
SHAQUILLE FIELDER, ALFRED HAYES IV, LUANA McNURLIN, and JORDAN NICHOLS
did knowingly combine, conspire, confederate, and agree with each other and with persons known 
and unknown to the Grand Jury, to 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, 
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representations, and promises, and by omission of material facts, well knowing and having reason 
to know that said pretenses were and would be false and fraudulent when made and caused to made 
and that said omissions were and would be material, and in furtherance thereof transmitted and 
caused to be transmitted interstate wire communications, contrary to Title 18, United States Code, 
Section 1343. 
Manner and Means: 
11.
DAISHA SANDERS created PPP loan applications for each of the co-conspirators
in exchange for a payment from the loan proceeds. The applications falsely stated either the 
existence of a sole proprietorship prior to the pandemic or greatly inflated the revenues of any 
“businesses” that did exist in 2019. 
12. 
DAISHA SANDERS worked with a person known to the Grand Jury to create 
fictitious bank records and IRS Forms Schedule C and other false financial documents to support 
the fraudulent PPP loan applications that would be submitted to various third-party lenders 
designated by the SBA to participate in the PPP. These IRS Forms Schedule C falsely stated that 
the person in whose name the loan was submitted had operated a sole proprietorship in 2019 or 
2020. The IRS Forms Schedule C included false statements of income and expenses attributed to 
the business in whose name the PPP loan application was submitted. The PPP loan applications 
also certified that the information provided in the application and in supporting documents was 
true and accurate in all respects.
13.
DAISHA SANDERS submitted the PPP loan applications on behalf of each of the 
co-conspirators. DAISHA SANDERS submitted the applications from a computer using internet
service located in Blue Springs, Missouri.
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14.
Once 
the 
PPP 
loans 
were 
funded, 
the 
co-conspirators 
would 
pay 
DAISHA SANDERS up to $5,000 for making and submitting the false loan applications. 
15. 
On or about the dates listed below, DAISHA SANDERS electronically created loan 
accounts, submitted false PPP loan applications, or checked the status of the loans to the SBA’s 
servers in Oregon or to the lenders in the states listed below: 
DATE 
BORROWER 
FINANCE COMPANY & 
LOCATION 
Amount
of PPP Loan 
a. 
02/06/2021 
Daisha Sanders 
Itria Ventures, LLC –
New York 
$20,832.50
b.
02/07/2021 
Joel Wright 
Itria Ventures, LLC –
New York 
$20,832
c. 
05/27/2021 
Denise Sanders 
Harvest Small Business – 
California 
$20,833
d.
02/18/2021 
Rashonda Golden 
Itria Ventures, LLC –
New York 
$20,833.33
e. 
03/06/2021 
Rashonda Golden 
Itria Ventures, LLC –
New York 
$20,833
f. 
04/18/2021 
Roxanne Nazir 
Prestamos – Arizona 
$20,830
g.
05/13/2021 
Kiandra Crowe 
Prestamos – Arizona 
$20,832
h.
03/20/2021 
Jeffery Chillis II
Itria Ventures, LLC –
New York 
$20,833
i.
03/20/2021 
Shaquille Fielder
Itria Ventures, LLC –
New York 
$20,833
j.
03/23/2021 
Alfred Hayes IV 
Capital Plus – Texas 
$20,832
k.
04/05/2021 
Luana McNurlin 
Capital Plus – Texas 
$20,832
l.
04/13/2021 
Jordan Nichols 
Prestamos – Arizona 
$20,832
Contrary to the provisions of Title 18, United States Code, Section 1349. 
COUNTS TWO - THIRTEEN 
16.
Paragraphs 1 through 15 of the Indictment are hereby realleged and incorporated 
into Counts Two through Thirteen. 
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COUNT TWO 
17.
On or about February 6, 2021, defendant DAISHA SANDERS created an 
application to apply for a PPP loan under the CARES Act for her business. 
18. 
The application and supporting documents were submitted on February 6, 
2021, and stated that the defendant DAISHA SANDERS was a sole proprietor of a business which 
had an average monthly payroll of $8,333. As part of the application, a 2019 Schedule C for the 
defendant DAISHA SANDERS was submitted listing gross receipts of $203,186 and profit of 
$83,751. 
19. 
In fact, the defendant DAISHA SANDERS did not have a business in 2019 with 
those gross receipts and profit. DAISHA SANDERS’ 2019 tax return listed $20,179 in wages 
and other income of $6,204. 
20. 
On or about the date set forth below, in Blue Springs, Missouri, in the Western 
District of Missouri, the defendant, DAISHA SANDERS having devised and intended to devise a 
scheme to obtain money by means of materially false and fraudulent pretenses, representations, 
and promises, for the purpose of executing the scheme described above, caused to be transmitted 
by means of wire communication in interstate commerce the signals and sounds described below: 
Count 
Date 
Wire From 
To 
Amount 
2 
02/11/2021 
Itria Ventures 
Navy Federal Credit Union
$20,832.50 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
COUNT THREE
21. On or about February 7, 2021, defendant DAISHA SANDERS, aided and abetted by 
defendant JOEL WRIGHT, completed and sent an application and supporting documents to 
Blue Acorn to apply for a PPP loan under the CARES Act for his business. 
 
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22. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
JOEL WRIGHT was a sole proprietor of a business that was established on April 12, 2017. 
The application stated that in 2019 the business had a monthly payroll of $8,333. As part of the 
application, a 2019 tax return Form Schedule C was submitted listing gross receipts of $144,080 
and a net profit of $99,982. 
23.. 
In fact, the defendant JOEL WRIGHT did not have a business in 2019 with those 
gross receipts and profit. JOEL WRIGHT’s 2019 tax return listed $10,139 in wages and no 
business income or expenses. 
24.. 
On or about the date set forth below, in Kansas City, Missouri, in the Western 
District of Missouri, the defendant, DAISHA SANDERS, aided and abetted by defendant 
JOEL WRIGHT, having devised and intended to devise a scheme to obtain money by means of 
materially false and fraudulent pretenses, representations, and promises, for the purpose of 
executing the scheme described above, caused to be transmitted by means of wire communication 
in interstate commerce the signals and sounds described below: 
Count 
Date 
Wire From 
To
Amount 
3 
03/09/2021 
Itria 
Navy Federal Credit Union 
$20,832.50 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
COUNT FOUR 
21.
On or about May 27, 2021, defendant DAISHA SANDERS, aided and abetted by 
defendant DENISE SANDERS, completed and sent an application and supporting documents to 
Harvest Small Business to apply for a PPP loan under the CARES Act for DENISE SANDERS’
business. 
 
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22.
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
DENISE SANDERS was a sole proprietor of a business established January 1, 2015, and that had 
gross receipts of $144,080. As part of the application, a 2019 Form Schedule C was submitted 
listing gross receipts of $144,080 and a profit of $99,982. 
23. 
In fact, the defendant DENISE SANDERS did not have a business in 2019 
with those gross receipts and profit. DENISE SANDERS’ personal 2019 tax return reported 
$63,532 in wages and no other income. 
24. 
On or about the date set forth below, in Blue Springs, Missouri, in the 
Western District of Missouri, the defendant, DASHIA SANDERS, aided and abetted by 
defendant DENISE SANDERS, having devised and intended to devise a scheme to obtain money 
by means of materially false and fraudulent pretenses, representations, and promises, for the 
purpose of executing the scheme described above, caused to be transmitted by means of wire 
communication in interstate commerce the signals and sounds described below: 
Count 
Date 
Wire From 
To
Amount 
4 
06/25/2021  
Harvest Small 
Business 
Navy Federal Credit Union 
$20,833 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
COUNT FIVE 
25.
On or about March 6, 2021, defendant DANISHA SANDERS, aided and abetted 
by defendant RASHONDA GOLDEN, completed and sent an application and supporting 
documents to apply for a PPP loan under the CARES Act for GOLDEN’s business, Gorgeous girl 
extensions. 
26. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
RAHONDA GOLDEN was a sole proprietor of a business established March 1, 2011, and that had 
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average monthly payroll of $10,657. As part of the application, a 2019 Form Schedule C was 
submitted listing gross receipts of $62,356 and a net income of $50,296. 
27.
In fact, the defendant RASHONDA GOLDEN did not have a business in 2019 with 
those gross receipts and profit. RASHONDA GOLDEN’s personal 2019 tax return listed 
Schedule C gross receipts of $17,730 and net profit of $16,240. 
28. 
On or about the date set forth below, in Blue Springs, Missouri, in the 
Western District of Missouri, the defendant, DAISHA SANDERS, aided and abetted by defendant 
RASHONDA GOLDEN, having devised and intended to devise a scheme to obtain money by 
means of materially false and fraudulent pretenses, representations, and promises, for the purpose 
of executing the scheme described above, caused to be transmitted by means of wire 
communication in interstate commerce the signals and sounds described below: 
Count 
Date 
Wire From 
To 
Amount 
5 
03/10/21 
Itria Ventures LLC
Bank of America 
$20,833 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
COUNT SIX 
29.
On or about April 18, 2021, defendant DAISHA SANDERS, aided and abetted by 
defendant ROXANNE NAZIR, completed and sent an application and supporting documents to
Blue Acorn to apply for a PPP loan under the CARES Act for NAZIR’s business. 
30.
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
ROXANNE NAZIR was a sole proprietor of a business established August 7, 2017, and that had 
gross receipts of $144,080 and net income of $99,982. As part of the application, a 2019 Form 
Schedule C was submitted listing the same amounts. 
 
 
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31.
In fact, the defendant ROXANNE NAZIR did not have a business in 2019 with 
those gross receipts and profit. ROXANNE NAZIR’s 2019 personal tax return listed $38,198 in 
wages and no other income. 
32. 
On or about the date set forth below, in Blue Springs, Missouri, in the Western 
District of Missouri, the defendant, DAISHA SANDERS, aided and abetted by defendant 
ROXANNE NAZIR , having devised and intended to devise a scheme to obtain money by means 
of materially false and fraudulent pretenses, representations, and promises, for the purpose of 
executing the scheme described above, caused to be transmitted by means of wire communication 
in interstate commerce the signals and sounds described below: 
Count 
Date 
Wire From 
To 
Amount 
6 
05/13/2021 
Prestamos 
Bank of America 
$20,830 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
COUNT SEVEN 
33.
On or about May 12, 2021, defendant DAISHA SANDERS, aided and abetted by 
defendant KIANDRA CROWE, completed and sent an application and supporting documents to 
Blueacorn to apply for a PPP loan under the CARES Act for her business. 
34.
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
KIANDRA CROWE was a sole proprietor of a business that was established on October 2, 2017. 
The application stated that in 2019 the business had gross receipts of $144,080 and a net profit of 
$99,982. As part of the application, a 2019 tax return Form Schedule C was submitted listing gross 
receipts of $144, 080 and a net profit of $99,982. 
 
 
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35.
In fact, the defendant KIANDRA CROWE did not have a business in 2019 with 
those gross receipts and profit. KIANDRA CROWE’s 2019 tax return listed $28,355 in wages and 
no business income or expenses. 
36. 
On or about the date set forth below, in Blue Springs, Missouri, in the Western 
District of Missouri, the defendant, DAISHA SANDERS, aided and abetted by defendant 
KIANDRA CROWE, having devised and intended to devise a scheme to obtain money by means 
of materially false and fraudulent pretenses, representations, and promises, for the purpose of 
executing the scheme described above, caused to be transmitted by means of wire communication 
in interstate commerce the signals and sounds described below: 
Count 
Date
Wire From 
To 
Amount 
7 
06/04/2021 
Prestamos 
Navy Federal Credit Union 
$20,832 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
COUNT EIGHT
37. 
On or about March 20, 2021, defendant DAISHA SANDERS, aided and abetted by 
defendant JEFFERY CHILLIS II, completed and sent an application and supporting documents to 
Itria Ventures to apply for a PPP loan under the CARES Act for his business. 
38. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
JEFFERY CHILLIS II was a sole proprietor of a business that was established on January 1, 2017. 
As part of the application, a 2019 tax return with a Form Schedule C was submitted listing gross 
receipts of $144, 080 and a net profit of $99,982. 
39. 
In fact, the defendant JEFFERY CHILLIS II did not have a business in 2019 with 
those gross receipts and profit. JEFFERY CHILLIS II’s 2019 tax return listed $5.245 in wages and 
no business income or expenses. 
 
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40. 
On or about the date set forth below, in Kansas City, Missouri, in the Western 
District of Missouri, the defendant, DAISHA SANDERS, aided and abetted by defendant 
JEFFERY CHILLIS II, having devised and intended to devise a scheme to obtain money by 
means of materially false and fraudulent pretenses, representations, and promises, for the 
purpose of executing the scheme described above, caused to be transmitted by means of 
wire communication in interstate commerce the signals and sounds described below: 
Count 
Date 
Wire From 
To
Amount 
8 
04/08/2021 
Itria Ventures 
Bank of America 
$20,833 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
COUNT NINE
41. 
On or about March 20, 2021, defendant DAISHA SANDERS, aided and abetted by 
defendant SHAQUILLE FIELDER, completed and sent an application and supporting documents 
to Itria Ventures to apply for a PPP loan under the CARES Act for his business. 
42. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
SHAQUILLE FIELDER was a sole proprietor of a business that was established on January 5, 
2017, and had $177,996 gross income in 2019. As part of the application, a 2019 tax return with a 
Form Schedule C was submitted listing gross receipts of $144, 080 and a net profit of $99,982. 
43. 
In fact, the defendant SHAQUILLE FIELDER did not have a business in 2019 with 
those gross receipts and profit. SHAQUILLE FIELDER’s  2019 tax return listed $17,243 in wages 
and no business income or expenses.
44. 
On or about the date set forth below, in Kansas City, Missouri, in the Western 
District of Missouri, the defendant, DAISHA SANDERS, aided and abetted by defendant 
SHAQUILLE FIELDER, having devised and intended to devise a scheme to obtain money by 
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means of materially false and fraudulent pretenses, representations, and promises, for the purpose 
of executing the scheme described above, caused to be transmitted by means of wire 
communication in interstate commerce the signals and sounds described below:
Count 
Date 
Wire From 
To
Amount 
9
04/13/2021
Itria Ventures
Navy Federal Credit Union
$20,833
Contrary to the provisions of Title 18, United States Code, Section 1343. 
COUNT TEN
45. 
On or about March 23, 2021, defendant DAISHA SANDERS, aided and abetted by 
defendant ALFRED HAYES IV, completed and sent an application and supporting documents to 
Blueacorn to apply for a PPP loan under the CARES Act for his business. 
46. 
The application and supporting documents stated that the defendant 
ALFRED HAYES was a sole proprietor of a business that was established on October 3. 2016. 
The application stated that the business had gross receipts of $144,080 and a net profit of $99,982. 
As part of the application, a 2019 tax Form Schedule C was submitted listing gross receipts of 
$144, 080 and a net profit of $99,982. 
47. 
In fact, the defendant ALFRED HAYES IV did not have a business in 2019 with 
those gross receipts and profit. ALFRED HAYES’ 2019 tax return listed $1 in wages and no 
business income or expenses.
48. 
On or about the date set forth below, in Kansas City, Missouri, in the 
Western District of Missouri, the defendant, DAISHA SANDERS, aided and abetted 
by defendant ALFRED HAYES IV, having devised and intended to devise a scheme to obtain 
money by means of materially false and fraudulent pretenses, representations, and promises, for  
 
 
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the purpose of executing the scheme described above, caused to be transmitted by means of 
wire communication in interstate commerce the signals and sounds described below: 
Count 
Date 
Wire From 
To
Amount 
10 
04/08/2021 
Capital Plus
Navy Federal Credit Union 
$20,832 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
COUNT ELEVEN
49. 
On or about April 4, 2021, defendant DAISHA SANDERS, aided and abetted by 
defendant LUANA McNURLIN, completed and sent an application and supporting documents to 
Blueacorn to apply for a PPP loan under the CARES Act for her business. 
50. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
LUANA McNURLIN was a sole proprietor of a business that was established on November 1, 
2016. The application stated that the business had gross receipts of $144,080 and a net profit of 
$99,982. As part of the application, a 2019 tax Form Schedule C was submitted listing gross 
receipts of $144, 080 and a net profit of $99,982. 
51. 
In fact, the defendant LUANA McNURLIN did not have a business in 2019 with 
those gross receipts and profit. LUANA McNURLIN’s 2019 tax return listed $41,258 in gross 
receipts and a $26,238 profit for “Lulus Hair Boutique”. 
52. 
On or about the date set forth below, in Kansas City, Missouri, in the Western 
District of Missouri, the defendant, DAISHA SANDERS, aided and abetted by defendant 
LUANA McNURLIN, having devised and intended to devise a scheme to obtain money by 
means of materially false and fraudulent pretenses, representations, and promises, for the purpose 
of executing the scheme described above, caused to be transmitted by means of wire 
communication in interstate commerce the signals and sounds described below: 
 
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Count 
Date
Wire From 
To 
Amount 
11
07/06/2021
Capital Plus
Bank of America
$20,832
Contrary to the provisions of Title 18, United States Code, Section 1343. 
COUNT TWELVE
53. 
On or about April 16, 2021, defendant DAISHA SANDERS, aided and abetted by 
defendant JORDAN NICHOLS, completed and sent an application and supporting documents to 
Blueacorn to apply for a PPP loan under the CARES Act for his business. 
54. 
The 
application 
and 
supporting 
documents 
stated 
that 
the defendant 
JORDAN NICHOLS was a sole proprietor of a business that was established on July 5, 2017. The 
application stated that the business had gross receipts of $144,080 and a net profit of $99,982. 
As part of the application, a 2019 tax Form Schedule C was submitted listing gross receipts of 
$144,080 and a net profit of $99,982. 
55. 
In fact, the defendant JORDAN NICHOLS did not have a business in 2019 with 
those gross receipts and profit. JORDAN NICHOLS’ 2019 tax return listed $ 17,173 in wages and 
no business income or expenses. 
56. 
On or about the date set forth below, in Kansas City, Missouri, in the Western 
District of Missouri, the defendant, DAISHA SANDERS, aided and abetted by defendant 
JORDAN NICHOLS, having devised and intended to devise a scheme to obtain money by means 
of materially false and fraudulent pretenses, representations, and promises, for the purpose of 
executing the scheme described above, caused to be transmitted by means of wire communication 
in interstate commerce the signals and sounds described below:  
 
 
Case 4:24-cr-00029-BP     Document 1     Filed 02/06/24     Page 17 of 19

18 
Count 
Date
Wire From 
To 
Amount 
12
05/11/2021
Prestamos
Community America 
Credit Union 
$20,832
 
Contrary to the provisions of Title 18, United States Code, Section 1343. 
COUNT THIRTEEN
57. 
Paragraphs 1 through 56 are hereby realleged, as if fully set forth herein. 
58. 
On or about the dates listed below, in the Western District of Missouri, and 
elsewhere, the defendant DAISHA SANDERS, did knowingly engage and attempt to engage 
in the following monetary transactions by, through and to a financial institution, affecting 
interstate commerce, in criminally derived property of a value greater than $10,000, such 
property having been derived from a specified unlawful activity, that is, the proceeds of the 
wire fraud scheme, in violation of Title 18, United States Code, Section 1343, the monetary 
transaction constituting a separate count of this indictment: 
Count 
Date 
Monetary Transaction from Navy Federal Credit Union 
account number XXX3772 
13
02/11/2021 
$20,832 
transfer 
to 
Navy 
Federal 
Credit 
Union 
account number XXX 3207 
Contrary to the provisions of Title 18, United States Code, Section 1957. 
FORFEITURE ALLEGATION 
59. 
The statements and allegations contained in counts One through Twelve of this 
Indictment are realleged and incorporated by reference for purposes of alleging forfeiture to the 
United States, pursuant to provisions of Title 18, United States Code, Section 981(a)(1)(C) and 
Title 28, United States Code, Section 2461. 
60. 
As a result of the offenses alleged in counts One through Twelve of the Indictment, 
defendant DAISHA SANDERS, shall forfeit all property, real and personal, constituting, or 
derived from, proceeds traceable to the offense, directly or indirectly, as a result of the violations 
Case 4:24-cr-00029-BP     Document 1     Filed 02/06/24     Page 18 of 19

19 
of law set out in Counts One through Twelve of this Indictment, including, but not limited to, the 
following property: a money judgment in the amount of at least $70,832.50. 
Substitute Assets 
61. 
If any of the property described in the above paragraph, as a result of any act or 
omission of the defendant, 
(A) 
cannot be located upon the exercise of due diligence;
(B) 
has been transferred to, 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; and/or 
 
(E) 
has been commingled with other property that cannot be subdivided 
without difficulty; 
 
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), which 
is incorporated by Title 18, United States Code, Section 982(b)(1) and Title 28, United States Code, 
Section 2461(c), to seek forfeiture of any other property of the defendant up to the value of the 
forfeitable property. 
A TRUE BILL. 
2/6/2024 
 
 
 
 
 
/s/ Kimberley Deardorff
DATE 
FOREPERSON OF THE GRAND JURY 
 
 
/s/ Paul S. Becker
Paul S. Becker 
Assistant United States Attorney 
Western District of Missouri 
Case 4:24-cr-00029-BP     Document 1     Filed 02/06/24     Page 19 of 19

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