Indictment for Conspiracy to Commit Mail Fraud and Mail Fraud — United States v. Every (Dkt. 1, E.D. La.)

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An indictment for conspiracy to commit mail fraud and mail fraud in United States v. Sharnae Every, a.k.a. Kaitlyn Known, Case 2:22-cr-00206-CJB-JVM, in the U.S. District Court for the Eastern District of Louisiana, filed September 9, 2022 as Document 1. Count 1 charges conspiracy under 18 U.S.C. § 1349. It alleges that Every and others defrauded the SBA and lenders of approximately $1,142,041.00 through approximately 110 fraudulent PPP loan applications, and that she charged people she recruited about $45.00 to $120.00 to prepare and submit applications, paid mainly through Cash App. It runs 12 pages.

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Case 2:22-cr-00206-CJB-JVM Document1 Filed 09/09/22 Page 1 of 12

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                     UNITED STATES DISTRICT COURT F a Ke NY
                     EASTERN DISTRICT OF LOUISIANA

                     INDICTMENT FOR CONSPIRACY TO
                  COMMIT MAIL FRAUD AND MAIL FRAUD

 UNITED STATES OF AMERICA           * CRIMINAL NO. 9 9 —9 -         0 6° ray

                Vv.                 *

 SHARNAE EVERY                      *

   a.k.a “Kaitlyn Known”                             18 U.S.C. § 1349
                                    *

                             *      *     *

The Grand Jury charges that:

                                COUNT 1
               (18 U.S.C. § 1349 — Conspiracy to Commit Mail Fraud)

A.   AT ALL TIMES MATERIAL HEREIN:

                               Introduction

      1.   The defendant, SHARNAE EVERY, a.k.a. “Isabelle Faith” and “Kaitlyn

Known” (“EVERY”), was a resident of the Eastern District of Louisiana and the Southern District

of Texas.

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Case 2:22-cr-00206-CJB-JVM Documenti1 Filed 09/09/22 Page 2 of 12

2. Current was a financial technology company that provided financial services
including issuing debit cards.
3. Current debit cards were mailed via the United States Postal Service (“USPS”) from
a processing center located in Nashville, Tennessee.
4. Cash App was a mobile payment service allowing users to transfer money to others
using an electronic platform such as a mobile phone.
5. EVERY maintained accounts with:
a. Current — Account ending and
b. Cash App — Active account token ending mC
6. Co-Conspirator A was the boyfriend of EVERY and he maintained a Current

account ending | |

The Small Business Administration

7. The United States Small Business Administration (“SBA”) was an executive-
branch agency of the United States government that provided support to entrepreneurs and small
businesses. The mission of the SBA was to maintain and strengthen the nation’s economy by
enabling the establishment and viability of small businesses and by assisting in the economic
recovery of communities after disasters.

8. As part of its efforts, the SBA provided business loans through banks, credit unions,
and other lenders. Those loans had government backed guarantees.

The CARES Act

9. The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) was a
federal law enacted in or about March 2020. The CARES Act provided emergency financial

assistance to the millions of Americans suffering the economic effects of the COVID-19 pandemic.

Case 2:22-cr-00206-CJB-JVM Document1 Filed 09/09/22 Page 3 of 12

The Paycheck Protection Program

10. 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”). In or around April
2020, Congress authorized over $300 billion in additional PPP funding.

11. ‘In order to obtain a PPP loan, a qualifying business was required to submit a PPP
loan application, which was signed by an authorized representative of the business. The PPP loan
application required the business (through its authorized representative) to acknowledge the
program rules and make certain affirmative certifications in order to be eligible to obtain the PPP
loan. In the PPP loan application, the small business (through its authorized representative) was
required to state, among other things, its: (a) average monthly payroll expenses; and (b) number
of employees. These figures were used to calculate the amount of money the small business was
eligible to receive under the PPP. In addition, businesses applying for a PPP loan were required
to provide documentation showing their payroll expenses.

12. | Among the types of businesses eligible for a PPP loan were individuals who
operated under a “sole proprietorship” business structure. In order to be eligible to receive such a
PPP loan, individuals had to report and document their income and expenses from the sole
proprietorship, as typically reported to the IRS on Form 1040, Schedule C, for a given tax
year. The lending institution or loan processor used this information to calculate the amount of
money the individual was entitled to receive under the PPP. The maximum PPP loan amount for
a sole proprietor with no employees was $20,833.00.

13. A PPP loan application was required to be processed by a participating lender. Ifa

PPP loan application was approved, the participating lender funded the PPP loan using its own

Case 2:22-cr-00206-CJB-JVM Document1 Filed 09/09/22 Page 4 of 12

monies, which were 100% guaranteed by the SBA. Data from the application, including
information about the borrower, the total amount of the loan, and the listed number of employees,
was transmitted by the lender to the SBA in the course of processing the loan.

14. PPP loan proceeds were required to be used by the business on certain permissible
expenses—payroll costs, interest on mortgages, rent, and utilities. The PPP allowed the interest
and principal on the PPP loan to be entirely forgiven if the business spent the loan proceeds on
these expense items within a designated period of time after receiving the proceeds and used a
certain amount of the PPP loan proceeds on payroll expenses.

15. Capital Plus Financial (“Capital Plus”) was one of many designated financial
institutions authorized to process PPP loans that were guaranteed by the SBA.

16.  Blueacorn was created during the COVID-19 pandemic to assist small businesses
in securing PPP loans.

17. Blueacorn would transmit PPP loan applications to approved lenders including
Capital Plus.

18. | Approved PPP loans were generally funded by wiring the proceeds of the loan into
the applicant’s bank account, Current account, or another designated financial institution.

B. THE CONSPIRACY:

Beginning on or about February 28, 2021, and continuing until the date of this Indictment,
in the Eastern District of Louisiana and elsewhere, the defendant, EVERY, Co-Conspirator A, and
others known and unknown to the Grand Jury, willfully and knowingly did combine, conspire,
confederate, and agree to devise a scheme and artifice to defraud and to obtain money and property
from the SBA and other designated financial institutions by means of materially false and

fraudulent pretenses, representations, and promises, and willfully cause mail matter to be delivered

Case 2:22-cr-00206-CJB-JVM Document1 Filed 09/09/22 Page 5 of 12

by the United States Postal Service and interstate commercial carriers for the purpose of executing
or attempting to execute the scheme and artifice to defraud set forth in Part C below, in violation
of Title 18, United States Code, Section 1341.

C. THE SCHEME AND ARTIFICE TO DEFRAUD:

1. It was part of the scheme and artifice to defraud, that on or about February 28, 2021,
through the date of this Indictment, EVERY, Co-Conspirator A, and others known and unknown
to the Grand Jury defrauded the SBA and other designated financial institutions of approximately
$1,142,041.00 through the submission of approximately 110 fraudulent PPP loan applications.

2. It was further part of the scheme and artifice to defraud that, EVERY recruited
friends and family members primarily via Facebook to send EVERY their personal and bank
information in exchange for “free money.”

3. It was further part of the scheme and artifice to defraud that EVERY created a
fictitious business called “Natural Hair Afro, LLC, Houma, LA 70360” and created invoices in the
name of this fictitious business which were included in nearly all of the fraudulent PPP loan
applications.

4, It was further part of the scheme and artifice to defraud that EVERY prepared and
submitted false and fraudulent PPP sole proprietor loan applications via various online portals
including, but not limited, to Blueacorn.

5. It was further part of the scheme and artifice to defraud that EVERY created false
and fraudulent invoices, bank statements, and federal tax forms (“Schedule C”) in order to prepare

the fraudulent PPP loan applications.

Case 2:22-cr-00206-CJB-JVM Documenti Filed 09/09/22 Page 6 of 12

6. It was further part of the scheme and artifice to defraud that EVERY falsely
certified that the application and the information provided in the supporting documents were true
and accurate when she electronically submitted the fraudulent PPP loan applications.

7. It was further part of the scheme and artifice to defraud that EVERY required an
upfront application fee of approximately $45.00 to $120.00 from individuals she recruited to
prepare and submit the fraudulent PPP application. EVERY received these payments primarily
via Cash App.

8. It was further part of the scheme and artifice to defraud that EVERY required a
payment of approximately $3,500.00 from individuals she recruited when the PPP loan was
funded. EVERY received these funds into her Current account, her Cash App account, or into

Co-Conspirator A’s Current account.

D. OVERT ACTS:

In order to execute the scheme, and to accomplish the purposes of the scheme, EVERY
committed and caused others to commit the following acts, among others, in the Eastern District
of Louisiana and elsewhere, as described in the following paragraphs:

Individual A’s PPP Loan

l. On or about March 15, 2021, Individual A, at the direction of EVERY, activated

and established Current account ending

Case 2:22-cr-00206-CJB-JVM Documenti1 Filed 09/09/22 Page 7 of 12

2. On or about March 15, 2021, EVERY submitted Individual A’s PPP loan
application to the Blueacorn portal containing a fraudulent invoice and Schedule C in the name of
Individual A.

3. On or about March 15, 2021, Individual A’s Current card ending [vas mailed
via the USPS from Nashville, TN to Thibodaux, LA 70301.

4, On or about March 21, 2021, Blueacorn submitted Individual A’s PPP loan
application to the SBA’s designated financial institution, Capital Plus.

5. On or about March 23, 2021, Individual A’s PPP loan application was approved by
the SBA’s designated financial institution, Capital Plus.

6. On or about March 23, 2021, Individual A activated Current card ending S|

7. | On or about March 05, 2021, Individual A’s PPP final loan documents were
electronically signed by an application known as DocuSign.

8. On or about April 1, 2021, Capital Plus deposited approximately $20,832.00 into
Individual A’s Current account ending i: a result of the submission of the fraudulent PPP
application.

9. On or about April 1, 2021, Individual A sent Co-Conspirator A approximately
$3,500.00 from the proceeds of the PPP loan.

Individual B’s PPP Loan

10. On or about March 18, 2021, Individual B, at the direction of EVERY, activated
and established Current account ending

11. On or about March 18, 2021, Individual B’s Current card ending Jyyyvas mailed

via the USPS from Nashville, TN to po Houma, LA 70364.

Case 2:22-cr-00206-CJB-JVM Documenti Filed 09/09/22 Page 8 of 12

12. On or about March 19, 2021, EVERY submitted Individual B’s PPP loan
application to the Blueacorn portal containing a fraudulent invoice and Schedule C in the name of
Individual B.

13. On or about March 20, 2021, Blueacorn submitted Individual B’s PPP loan .
application to the SBA’s designated financial institution, Capital Plus.

14. Onor about March 23, 2021, Individual B’s PPP loan application was approved by
the SBA’s designated financial institution, Capital Plus.

15. On or about March 26, 2021, Individual B’s PPP final loan documents were
electronically signed by an application known as DocuSign.

16. On or about April 2, 2021, Individual B activated Current card ending

17. Onor about April 2, 2021, Capital Plus deposited approximately $20,832.00 into
Individual B’s Current account ending fll os a result of the submission of the fraudulent PPP
application.

18. On or about April 2, 2021, Individual B sent Co-Conspirator A approximately
$2,000.00 from the proceeds of the PPP loan.

19. On or about April 2, 2021, Individual B sent EVERY’s Cash App account an
additional $1,500.00 from the proceeds of the PPP loan.

April 13, 2022 Interview

20.  Onor about April 13, 2022, EVERY lied to federal to federal agents with the U.S.
Department of Veterans Affairs, Office of Inspector General, Criminal Investigations Division,
about her involvement in preparing and submitting fraudulent PPP loan applications.

All in violation of Title 18, United States Code, Section 1349."

Case 2:22-cr-00206-CJB-JVM Documenti1 Filed 09/09/22 Page 9of12

COUNTS 2 - 3
(18 U.S.C. § 1341 — Mail Fraud)

A. AT ALL TIMES MATERIAL HEREIN:

The allegations contained in Parts A, C, and D of Count One are hereby re-alleged and

incorporated herein by reference.
THE OFFENSE:

Beginning on or about February 28, 2021, and continuing until the date of this Indictment,
in the Eastern District of Louisiana and elsewhere, the defendant, EVERY, Co-Conspirator A, and
others known and unknown to the Grand Jury, with the intent to defraud, devised and willfully
participated in, with knowledge of its fraudulent nature, the above-described scheme and artifice
to defraud and obtain money and property from the SBA and other designated financial institutions
by materially false and fraudulent pretenses, representations, and promises.

On or about the approximate dates listed below, in the Eastern District of Louisiana and
elsewhere, EVERY, Co-Conspirator A, and others known and unknown to the Grand Jury, for the
purpose of executing or attempting to execute the aforesaid scheme and artifice to defraud set forth
in Part C of Count 1, did knowingly cause to be delivered by the United States Postal Service and

interstate commercial carriers, according to the directions thereon, the following mail matter:

COUNT DESCRIPTION OF MAILING
March 15, 2021, Individual A’s Current card ending [was mailed via the USPS

2 from Nashville, TN to ibodaux, LA 70301.
March 18, 2021, Individual B’s Current card ending [vas mailed via the USPS

3 from Nashville, TN to ouma, LA 70364.

In violation of Title 18, United States Code, Sections 1341 and 2.

Case 2:22-cr-00206-CJB-JVM Document1 Filed 09/09/22 Page 10 of 12

NOTICE OF FORFEITURE

1. The allegations of Counts 1 through 3 of this Indictment are incorporated by
reference as though set forth fully herein for the purpose of alleging forfeiture to the United States.
As a result of the offenses alleged in Counts 1 through 3, the defendant, SHARNAE EVERY,
a.k.a “Isabelle Faith” and “Kaitlyn Known.”

2. shall forfeit to the United States pursuant to Title 18, United States Code, Section
982(a)(2)(A), any property constituting, or derived from, proceeds obtained, directly or indirectly,

as aresult of such offenses.

3. If any of the above-described property, 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 or 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; or
e. has been commingled with other property which cannot be subdivided
without difficulty;

10

Case 2:22-cr-00206-CJB-JVM Document1 Filed 09/09/22 Page 11 of 12

the United States shall seek a money judgment and, pursuant to Title 21, United States Code,

Section 853(p), forfeiture of any other property of the defendant up to the value of said property.

A TRUE BILL:

DUANE A. EVANS
UNITED STATES ATTORNEY

BRIAN M. KLEBBA
EDWARD J. RIVERA
Assistant United States Attorneys

New Orleans, Louisiana
September 9, 2022

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