Indictment — United States v. Tucker

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UNITED STATES DISTRICT COURT 
WESTERN DISTRICT OF MICHIGAN 
SOUTHERN DIVISION 
 
UNITED STATES OF AMERICA, 
 
 
 
 
Plaintiff, 
 
 
 
 
 
 
 
vs. 
 
 
 
 
 
  
 
SHAKAYLA LORRENE TUCKER, 
 
 
 
 
 
 
 
 
INDICTMENT 
 
 
 
Defendant. 
_________________________________/ 
 
The Grand Jury charges: 
COUNTS 1-8 
(Wire Fraud) 
 
Between on or about March 22, 2021 and on or about September 13, 2021, in 
Berrien County, in the Southern Division of the Western District of Michigan, 
SHAKAYLA LORRENE TUCKER,
having knowingly devised a scheme and artifice to defraud, and to obtain money by 
means of false and fraudulent pretenses and representations, caused signs, sounds, 
and signals to be transmitted by wire in interstate commerce for the purpose of 
executing the scheme. 
The defendant electronically submitted Paycheck Protection Program (PPP) 
loan applications and supporting documents for “Shakayla Tucker,” a fictitious sole 
proprietorship, which resulted in the transfer of $20,832 in first-draw loan proceeds 
from Capital Plus Financial LLC (“Capital Plus”), a community development 
financial institution in Texas, and the transfer of $20,832 in second-draw loan 
Case 1:24-cr-00167-PLM     ECF No. 2,  PageID.6     Filed 11/06/24     Page 1 of 5

proceeds from Prestamos CDFI LLC (“Prestamos”), a community development 
financial institution in Arizona, to an account controlled by the defendant in 
Michigan.  
The defendant reported fictitious income and expenses to qualify for the 
loans, and certified that she would use the funds only for business related purposes 
as authorized by PPP, when in fact, she spent the money on personal goods and 
services. She then falsely certified that she had spent 100% of her first draw loan on 
payroll costs, to induce the SBA to forgive her loan and repay Capital Plus on her 
behalf. 
For the purpose of executing the scheme and artifice, the defendant 
knowingly and intentionally transmitted, and caused to be transmitted, by means of 
wire communications in interstate commerce the following writings, signs, signals, 
pictures, and sounds: 
COUNT 
DATE 
DESCRIPTION 
1 
March 22, 2021 
Borrower’s application to SBA for PPP first draw 
loan no. 8288178610. 
2 
March 29, 2021 
Lender’s application by Capital Plus to SBA for PPP 
first draw loan no. 8288178610. 
3 
April 2, 2021 
Deposit of PPP first draw loan disbursement from 
Capital Plus for loan no. 8288178610, in amount 
$20,832, to defendant’s PNC Bank account ending in 
4596. 
4 
April 24, 2021 
Borrower’s application to SBA for PPP second draw 
loan no. 1240699009. 
5 
April 24, 2021 
Lender’s application by Prestamos to SBA for PPP 
second draw loan no. 1240699009. 
6 
May 28, 2021 
Deposit of PPP second draw loan disbursement from 
Prestamos, in amount $20,832, to defendant’s PNC 
Bank account ending in 4596. 
7 
September 6, 
2021 
Application to SBA for loan forgiveness for PPP first 
draw loan no. 8288178610. 
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8 
September 13, 
2021 
Transfer of $20,832 from SBA to Capital Plus in 
repayment of PPP first draw loan no. 8288178610. 
18 U.S.C. § 1343 
 
Case 1:24-cr-00167-PLM     ECF No. 2,  PageID.8     Filed 11/06/24     Page 3 of 5

COUNTS 9-12 
(Wire Fraud)
Between on or about November 28, 2020 and on or about February 1, 2022, in 
Berrien County, in the Southern Division of the Western District of Michigan, and 
elsewhere, 
SHAKAYLA LORRENE TUCKER,
having devised a scheme and artifice to defraud, and to obtain money by means of 
false and fraudulent pretenses and representations, caused signs, sounds, and 
signals to be transmitted by wire in interstate commerce for the purpose of 
executing the scheme. 
The defendant electronically submitted an initial application and weekly 
claims for Unemployment Insurance (UI) benefits to the Indiana Department of 
Workforce Development (IDWD), and thereby caused IDWD to deposit 
approximately $32,175 to an account she controlled. The defendant falsely 
represented that she had been laid off by an employer in Indiana due to the COVID 
pandemic, when in fact she had never worked for that employer.  
The defendant also failed to disclose that she was already receiving UI 
payments at the same time from the Michigan Unemployment Insurance Agency 
(UIA). When IDWD suspended her benefits and sent her a notice of overpayment, 
the defendant appealed, and falsely represented that she had never filed for UI in 
any other state. 
 
 
 
 
Case 1:24-cr-00167-PLM     ECF No. 2,  PageID.9     Filed 11/06/24     Page 4 of 5

For the purpose of executing the scheme and artifice, the defendant 
knowingly and intentionally transmitted, and caused to be transmitted, by means of 
wire communication in interstate commerce the following writings, signs, signals, 
pictures, and sounds: 
COUNT DATE 
DESCRIPTION 
9 
November 28, 2020 
Application for Indiana UI benefits, claim no. 
91498392. 
10 
November 15, 2021 
Two letters faxed to Indiana DWD appealing 
suspension of UI benefits. 
11 
November 30, 2021 
Deposit of $24,244 lump sum Indiana UI benefits 
for claim no. 914983392 to defendant’s Bancorp 
Bank account ending in 4673. 
12 
February 1, 2022 
Deposit of $3,143 lump sum Indiana UI benefits 
for claim no. 914983392 to defendant’s Bancorp 
Bank account ending in 4673. 
18 U.S.C. § 1343 
A TRUE BILL 
__________________________________________ 
GRAND JURY FOREPERSON 
MARK A. TOTTEN 
United States Attorney 
___________________________________ 
NILS R. KESSLER 
Assistant United States Attorney 
____________________________________
G A
O
SO
Case 1:24-cr-00167-PLM     ECF No. 2,  PageID.10     Filed 11/06/24     Page 5 of 5

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