Indictment — United States v. Williams et al., No. 2:25-cr-00020 (E.D.N.Y. Jan. 15, 2025) (E.D.N.Y. No. 2:25-cr-00020)

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U.S. District Court, Eastern District of New York · No. 2:25-cr-00020-GRB · Doc. 1 · 2025-01-15 · Docket on CourtListener

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CMM:AT/JRS/SBB:RJK 
F. #2022R0 l 048 
UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF NEW YORK 
---------------------------------X 
UNITED STATES OF AMERICA 
- against -
KEITH WILLIAMS, 
JANINE DA VIS, 
also known as "Holiday Davis," 
MORAIS DICKS, 
JAMES HAMES, JR., 
also known as "Poppa J," 
JAMAR! LEWIS, 
also known as "Mr. Chaketah," 
EWENDRA MATHURIN, 
also known as "Rayda Mathurin," and 
TIFFANY WILLIAMS, 
also known as "Joy Williams," 
Defendants. 
---------------------------------X 
THE GRAND JURY CHARGES: 
FI L ED 
IN CLERK'S OFFICE 
U.S. DISTRICT COURT E.D.N.Y. 
* JAN 1 5 2025 * 
LONG ISLAND OFFICE 
.20 
(T. 18, U.S.C., §§ 371, 981 (a)(l )(C), 
982(a)(2), 982(b)(l ), 1343, 2 and 3551 et 
~.; T. 21, U.S.C., § 853(p); T. 26, 
U.S.C., § 7206(2); T. 28, U.S.C., 
§ 246l(c)) 
SEYBER~J. 
t i~CIONE, M.J. 
INTRODUCTION 
At all times relevant to this Indictment, unless otherwise indicated: 
I. 
The Defendants and Relevant Entities and Individuals 
I. 
The defendant KEITH WILLIAMS ("K. WILLIAMS") was a resident of 
West Hempstead, New York. K. WILLfAMS owned and controlled Credit Reset Me Inc. 
("Credit Reset"), a New York corporation, which was purportedly a credit repair business 
located at 683 Hempstead Turnpike, Franklin Square, New York. K. WILLIAMS also owned 
and controlled I 09 Super Store Motors Inc. (" I 09 Super Store"), Babylon Buyers Group Inc. 
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("Babylon Buyers") and Lucky 13 Sports Bar and Gri II Corp. ("Lucky 13"), each New York 
corporations. 
2. 
The defendant JANINE DA VIS, also known as "Holiday Davis," was a 
resident of Wheatley Heights, New York, and worked as a tax preparer. DA VIS owned and 
controlled 7 Port LLC ("7 Port") and Holiday's Promise Ltd. ("Holiday's Promise"), each New 
York corporations. 
3. 
The defendant MORAIS DICKS was a resident of Dix Hills, New York. 
DICKS owned and controlled Progressive Homes and Development Inc. ("Progressive Homes") 
and Service Advisors, Inc. ("Service Advisors"), each New York corporations. 
4. 
The defendant JAMES HAMES, JR., also known as "Poppa J," was a 
resident of Campbell Hall, New York. HAMES owned and controlled MJR Enterprise 
Consulting Inc. ("MJR"), a New York corporation. 
5. 
The defendant JAMARJ LEWIS, also known as "Mr. Chaketah," was a 
resident of Queens, New York and Charlotte, North Carolina. LEWIS owned and controlled 
Chakeetah, LLC ("Chakeetah"), a Colorado corporation. 
6. 
The defendant EWENDRA MA THORIN, also known as "Rayda 
Mathurin," was a resident of Queens Village, New York. MATHUR1N owned and controlled 
Island Stream Inc. ("Island Stream") and Rich n' Yummy Inc. ("Rich n' Yummy"), each New 
York corporations. 
7. 
The defendant TIFFANY WILLIAMS ("T. WILLIAMS"), also known as 
"Joy Williams," was resident of Brooklyn, New York, and worked as a tax preparer. 
T. WILLIAMS owned and controlled J 2nd Power Trucking Company ("J2"), a Delaware 
corporation, and Joy the Bookkeeper Corp. ("Joy the Bookkeeper"), a New York corporation. 
2 
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8. 
Company #1 through Company #22, entities the identities of which are 
known to the Grand Jury, were companies purportedly owned individually by the defendants and 
their co-conspirators and used in fu11herance of the defendants' fraudulent scheme. 
9. 
Co-Conspirator # I, an individual whose identity is known to the Grand 
Jury, was an associate of the defendant JAMAR! LEWIS. 
I 0. 
Co-Conspirator #2, an individual whose identity is known to the Grand 
Jury, was business partners with the defendant KEITH WILLIAMS and controlled Company # I 
through Company #3. 
11. 
Co-Conspirator #3, an individual whose identity is known to the Grand 
Jury, was employed at Credit Reset and controlled Company #4. 
12. 
Co-Conspirator #4, an individual whose identity is known to the Grand 
Jury, was a client of and employee at Credit Reset and controlled Company #5 and Company #6. 
13. 
Co-Conspirator #5, an individual whose identity is known to the Grand 
Jury, was an associate of the defendants KEITH WILLIAMS and JAMARJ LEWIS and 
controlled Company #7. 
14. 
Co-Conspirator #6, an individual whose identity is known to the Grand 
Jury, was a client of the defendant JAMES HAMES, JR. and controlled Company #8 through 
Company # 14. 
15. 
Co-Conspirator #7, an individual whose identity is known to the Grand 
Jury, was a client of the defendant JAMES HAMES, JR. and controlled Company #15 and 
Company # 16. 
16. 
Individual #1, an individual whose identity is known to the Grand Jury, 
was a client of the defendant MORAIS DICKS and controlled Company # 17. 
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17. 
Individual #2, an individual whose identity is known to the Grand Jury, 
was an associate of the defendant JAMARI LEWIS and worked at Credit Reset. Individual #2 
controlled Company # 18 through Company #20. 
18. 
Individual #3, an individual whose identity is known to the Grand Jury, 
controlled Company #21 and Company #22. 
19. 
Individual #4, an individual whose identity is known to the Grand Jury, 
was a client of the defendant TIFF ANY WILLIAMS and controlled Company #23. 
20. 
Individual #5, an individual whose identity is known to the Grand Jury, 
controlled Company #24 and Company #25. 
21. 
The Tax Preparation Software ("TPS") was a tax return preparation 
software accessible via the internet that was used to prepare and electronically file with the 
Internal Revenue Service ("IRS") various tax returns and related documents. 
II. 
Relevant Governmental Agencies and Definitions 
22. 
The IRS was an agency of the United States Department of the Treasury 
4 
responsible for administering and enforcing federal tax laws, including refundable tax credits, of 
the United States and collecting taxes owed to the United States. 
23. 
Federal law required employers to collect, truthfully account for, and pay 
over to the United States certain payroll taxes, including their employees' withheld federal 
income taxes, Social Security and Medicare taxes, and the employer's matching portion of the 
Social Security and Medicare taxes. A responsible person at a business was required to file, 
quarterly, an Employer's Quarterly Federal Tax Return, Form 94 1 ("Form 941 "), reporting 
certain information and assessing payroll taxes for the business and reporting certain 
information, including the number of employees working at the business and the wages paid by 
the business. 
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24. 
A Wage and Tax Statement, Form W-2 ("Form W-2"), reported wages 
paid by an employer to an employee and taxes withheld from those wages. It was issued by 
United States employers to employees and filed by employers with the Social Security 
Administration ("SSA"). 
25. 
A Schedule C was a form attached to an lndividual Income Tax Return 
and filed with the IRS on which the taxpayer reported, among other things, gross receipts, 
expenses, and income or loss from a business the taxpayer operated as a sole proprietor. 
26. 
The 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. 
5 
27. 
A tax return was a filing with the IRS which detailed the tax obligations of 
the taxpayer or organization. Tax returns in the United States included, among others, Form 941 
and Form I 040. 
Ill. 
The COVID-19 Pandemic in the United States and Related Tax Credits 
28. 
In or about December 2019, a novel coronavirus caused outbreaks of the 
coronavirus disease COVID-19 that spread globally. On or about January 31, 2020, the 
Secretary of the United States Department of Health and Human Services declared a national 
public health emergency under Title 42, United States Code, Section 247d as a result of the 
spread of COVID-19 to and within the United States. On or about March 13, 2020, the President 
of the United States issued Proclamation 9994, declaring a national emergency beginning on or 
about March I, 2020, as a result of the rapid spread of COVID-19. 
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A. 
Employee Retention Credits 
29. 
The Coronavirus Aid, Relief, and Economic Security Act ("CARES Act"), 
enacted on March 27, 2020, provided for an employee retention credit ("ERC"), a refundable tax 
credit, which was designed to encourage businesses to keep employees on their payroll during 
the COVID-19 pandemic. The Taxpayer Certainty and Disaster Tax Relief Act of 2020 and the 
American Rescue Plan Act ("ARPA") modified and extended the ERC. 
30. 
For calendar year 2020, eligible employers were authorized to claim an 
ERC offsetting certain employment taxes that could not exceed 50 percent of up to $10,000 of 
qualified wages paid to each employee from March 13, 2020, through December 31, 2020. The 
maximum ERC for 2020 was $5,000 per employee per quarter. For calendar year 202 1, eligible 
employers were authorized to claim an ERC offsetting certain employment taxes that could not 
exceed 70 percent of up to $10,000 of qualified wages paid to each employee during each 
quarter. The maximum ERC for 2021 was $7,000 per employee per quarter. 
31. 
Generally, businesses and tax-exempt organizations that qualified for the 
ERC were those that: (a) were shut down during 2020 or the first three calendar quarters of2021 
by government order due to the COVTD-19 pandemic; (b) experienced a specified decline in 
gross receipts during the eligibility periods during 2020 or the first three calendar quarters of 
2021; or ( c) qualified as a recovery startup business for the third or fourth qua11ers of 202 1. 
32. 
A recovery startup business was defined in Title 26, United States Code, 
Section 3 l 34(c)(5) as an employer (i) that began carrying on any trade or business after February 
15, 2020, (ii) for which the average annual gross receipts of the employer for the three-taxable-
year period ending with the taxable year that precedes the calendar quarter for which the credit is 
determined does not exceed $1,000,000, and (iii) that is not otherwise an eligible employer due 
to a full or partial suspension of operations or a decline in gross receipts. 
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B. 
Sick and Family Leave Wage Credits 
33. 
The Families First Coronavirus Response Act provided for eligible 
employers to receive refundable tax credits for wages paid to employees while on sick leave to 
recover from any injury, disability, illness or condition resulting from COYID-19 or wages paid 
to employees while on family leave to care for a family member who was injured, disabled, ill or 
otherwise suffering from a condition due to COVID-1 9. Together these credits were called the 
Sick and Family Leave Wage Credit ("SFLC," and together with the ERC, the "COVID-Related 
Tax Credits"). 
34. 
Under the SFLC, employers were entitled to receive a dollar-for-dollar 
credit for qualified wages paid to an employee, plus allocable health plan expenses and the 
employer' s share of Medicare taxes, while that employee was on sick leave resulting from 
COVID-1 9. This credit was limited to ten days of sick leave per employee for the period ending 
March 31, 202 1. That resulted in a maximum credit of $5,110 per employee for that period. The 
ARP A provided an identical credit for the period April l, 202 1 through September 31, 2021, 
with the same maximum of $5, 1 IO in credits per employee. 
35. 
In addition, under the SFLC, employers were also entitled to receive a 
credit of up to two-thirds of the qualified wages paid to an employee while that employee was on 
fami ly leave to care for a family member suffering from a condition resulting from COYID-19, 
plus allocable health plan expenses and the employer's share of Medicare taxes. For the period 
ending March 31, 2021, this credit was limited to $200 per day for up to ten weeks, resulting in a 
maximum eligible credit of$ I 0,000 per employee. The ARP A provided an identical credit for 
the period April 1, 2021 through September 31, 2021, and extended the length of fami ly leave to 
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twelve weeks, thereby raising the maximum eligible credit for that period to $12,000 per 
employee. 
36. 
An employer claimed COVID-Related Tax Credits by filing a Form 941 
8 
with the IRS for the relevant quarter. The Form 941 required an employer to provide to the IRS 
information about the number of employees the business had and the wages paid by the business 
during that quarter. 
37. 
The same wages could not be claimed as both qualified sick leave wages 
and qualified family leave wages. Employers were also not eligible to receive both the ERC and 
SFLC with respect to the same wages. 
C. 
The Paycheck Protection Program 
38. 
The CARES Act also authorized 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. 
39. 
To obtain a PPP loan, a qualifying business was required to submit a "PPP 
Loan Application," which included an SBA Form 2483 - Borrower Application Form - and 
supporting documentation. On the PPP Loan Application, an authorized representative of the 
applying business was required to acknowledge the program rules and make certain affirmative 
certifications to establish eligibility for the PPP loan. For example, on SBA Form 2483, the 
recipient business, through an authorized representative, was required to state, among other 
things, its average monthly payroll expenses and number of employees. These figures were used 
to calculate the amount of money the business was eligible to receive under the PPP. 
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40. 
The required supporting documentation for the SBA Form 2483 in the 
PPP Loan Application frequently included, when the applicant was a sole proprietorship, the 
most recent Schedule C, Profit or Loss from Business, filed by the owner of the business 
attached to their Individual Income Tax Return. 
41. 
The representative of the business who submitted the PPP Loan 
Application was required to ce1tify, on SBA Form 2483, that they understood that, should the 
PPP funds be knowingly used for unauthorized purposes, the United States could pursue legal 
remedies against the authorized representative, including charges of fraud. 
42. 
Recipient businesses were required to use PPP loan proceeds for ce1tain 
9 
permissible expenses, including, but not limited to, payroll costs, interest on mortgages, rent, and 
utilities. The PPP provided that the principal and interest on a PPP loan would be entirely 
forgiven if the recipient business spent the loan proceeds on these expense items within a 
designated period of time after receiving the proceeds and used a certain percentage for payroll 
costs. 
43. 
The SBA administered PPP loans. Individual PPP loans, however, were 
issued and approved by private lenders, who received and processed PPP loan applications and 
supporting documentation and, following SBA approval, made loans using the lenders' own 
funds. 
IV. 
The Defendants' Fraudulent Covid-Related Tax Credits Scheme 
44. 
From in or about and between November 2021 and June 2023, the 
defendants KEITH WILLIAMS, JANINE DAVIS, MORAIS DICKS, JAMES HAMES, JR., 
JAMAR! LEWIS, EWENDRA MATHURIN and TIFF ANY WILLIAMS, together with others, 
orchestrated a scheme to submit more than $600 million in fraudulent requests for COVID-
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Related Tax Credits designed to help workers and businesses negatively impacted by the 
COYID-19 pandemic by filing more than 8,000 false Forms 941. As a result of the scheme, the 
United States Treasury disbursed approximately $45 million to the defendants, their co-
conspirators and clients. 
45. 
The defendants KEITH WILLIAMS, JANINE DA VIS, MORAIS DICKS, 
JAMES HAMES, JR., JAMARI LEWIS, EWENDRA MATHURIN and TIFFANY 
WILLIAMS, their co-conspirators and clients were not entitled to the amount of COVID-Related 
Tax Credits or resulting tax refunds claimed on the Forms 941 that the defendants and their co-
conspirators prepared and filed. The fraudulent tax returns (including Forms 94 l) filed by the 
defendants and their co-conspirators claimed tax refunds based on falsely reported wages and 
benefits that the defendants and their co-conspirators knew had not been paid. 
46. 
Many of the entities, including Company # l through Company #22, 
reported on the fraudulent Forms 941 that the defendants KEITH WILLIAMS, JANINE DA VIS, 
MORAIS DICKS, JAMES HAMES, JR., JAMAR! LEW[S, EWENDRA MA THURrN and 
TIFF ANY WILLIAMS and their co-conspirators prepared and filed, and caused to be prepared 
and filed, were not as they were represented on the Forms 941. Contrary to the representations 
made in the Forms 941, the entities were inactive, had no employees, had not made prior tax 
return filings, had no physical business location and/or did not timely file Forms W-2 for wages 
paid to employees. 
4 7. 
Furthermore, nearly all the Forms 941 that the defendants KEITH 
WILLIAMS, JANINE DA VIS, MORAIS DICKS, JAMES HAMES, JR., JAMARJ LEWIS, 
EWENDRA MATHURIN and TIFF ANY WTLLIAMS and their co-conspirators prepared and 
filed, and caused to be prepared and filed, fraudulently sought more refunds than the ERC or 
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SFLC allowed. For example, many of the Forms 941 that the defendants and their co-
conspirators prepared and filed, either: (i) claimed an SFLC in excess of the amount of wages 
reported; (ii) listed the same wages as both qualified sick leave wages and qualified fami ly leave 
wages; and/or (iii) claimed an SFLC and ERC for the same wages. None of these were 
permitted under the prevailing legal framework. 
48. 
Although the defendants carried out their fraudulent scheme using a 
number of different physical locations and entities, it was primarily operated out of Credit Reset, 
which was owned and controlled by KEITH WILLIAMS. Many of the defendants and their co-
conspirators either worked at Credit Reset for K. WILLIAMS for portions of the scheme or 
visited Credit Reset in fu1therance of the scheme. At Credit Reset and at other locations, 
including their residences, which were located in the Eastern District of New York and 
elsewhere, the defendants K. WlLLIAMS, JANfNE DA VIS, MORAIS DICKS, JAMES 
HAMES, JR., JAMARJ LEWlS, EWENDRA MA THURTN and TIFF ANY WILLIAMS and 
others prepared and filed false tax documents, including, but not limited to, false Forms 941 to 
obtain ERC or SFLC funds. 
49. 
The defendants KEITH WILLIAMS, JANTNE DA VlS, MORAIS DICKS, 
JAMES HAMES, JR., JAMAR! LEWIS, EWENDRA MATHURIN and TIFF ANY WILLIAMS 
and others created a series of different accounts with TPS, which they used to prepare and file 
false tax returns, and some of which they shared with other co-conspirators. 
50. 
For example, between approximately May 2022 and February 2023, three 
different TPS accounts controlled by the defendants KEITH WILLIAMS, JAMES HAMES, JR., 
JAMARI LEWIS and Co-Conspirator #2 were used to prepare and fi le 22 false Forms 941 for 
the benefit of Individual #2. The false filings made on behalf of Individual #2 were purportedly 
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on behalf of Company #18, Company #19 and Company #20 and claimed fraudulent refunds 
totaling approximately $1.43 million. Each of these filings was fraudulent because, among other 
things, they claimed SFLC and ERC for the same wages. 
51. 
Additionally, between approximately June 2022 and November 2022, a 
TPS account controlled by the defendant KEITH WILLIAMS and a TPS account controlled by 
the defendant JAMAR! LEWIS were used to prepare and file, or attempted to prepare and file, 
nine false Forms 941 for the benefit oflndividual #3. The false filings were purportedly on 
behalf of Company #21 and Company #22 and claimed fraudulent refunds totaling 
approximately $645,848. Each of these filings was fraudulent because, among other things, they 
claimed SFLC and ERC for the same wages. 
52. 
Further, between approximately March 2022 and September 2022, a TPS 
account controlled by the defendant KEITH WILLIAMS and a TPS account controlled by the 
defendants JANINE DAVIS and TIFFANY WILLIAMS were used to prepare and file, or 
attempted to prepare and file, seven false Forms 94 1 for the benefit of Individual #4. The false 
filings were purportedly on behalf of Company #23 and claimed fraudulent refunds totaling 
approximately $287,173. Each of these fil ings was fraudulent because, among other things, they 
claimed Sf LC and ERC for the same wages. 
53. 
In addition, between approximately September 2022 and March 2023, a 
TPS account controlled by the defendant KEITH WILLIAMS and a TPS account controlled by 
Co-Conspirator #2 were used to prepare and file 15 false Forms 941 for the benefit of Individual 
#5. The false filings were purportedly on behalf of Company #24 and Company #25 and 
claimed fraudulent refunds totaling approximately $778,172. Each of these filings was 
fraudulent because, among other things, they claimed SFLC and ERC for the same wages. 
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54. 
The defendants KEITH WILLIAMS, JANINE DAVIS, MORAIS DICKS, 
JAMES HAMES, JR., JAMARJ LEWIS, EWENDRA MATHURIN and TIFFANY WILLIAMS 
and their co-conspirators concealed their roles in the preparation of the false Forms 941 by, 
among other things, not listing themselves on the returns as the paid preparer of the return as 
required and, at times, using Virtual Private Networks ("VPNs") to obscure their computers' true 
Internet Protocol address and location to connect to TPS. 
55. 
The defendants KEITH WILLIAMS, JANINE DA VIS, MORAIS DICKS, 
JAMES HAMES, JR., JAMARI LEWIS, EWENDRA MATHURIN, TIFFANY WILLIAMS, 
their co-conspirators and others profited from the scheme in several different ways. The 
defendants received tax refunds, in the form of United States Treasury checks, based on false 
Forms 941 submitted for one or more of their own purp01ted companies. The defendants also 
profited by recruiting clients to have false Forms 941 prepared by their co-conspirators and 
receiving a po1tion of the fee paid by the client to the co-conspirator. Finally, the defendants 
charged clients a fee for initially preparing the false Forms 941 and/or collected a percentage of 
the fraudulently obtained tax refund as a fee. 
56. 
For example, on several occasions, after the defendant KEITH 
WILLIAMS received a fee from a client or a United States Treasury check generated by a false 
Form 941, K. WILLIAMS compensated the defendants JAMARI LEWIS, MORAIS DICKS, 
JANINE DA VIS and EWEN ORA MATHURIN, and Co-Conspirator #2 and Co-Conspirator #4, 
for their roles in obtaining the fraudulent COVID-Related Tax Credits. 
57. 
To carry out the fraudulent scheme, the defendants and their co-
conspirators communicated using text messages, phone calls, and a WhatsApp group, among 
other methods of communication. For example, on or about November 23, 2022, the defendant 
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KEITH WILLIAMS sent text-based messages to the defendant JAMES HAMES, JR. describing 
the false statements that clients of the defendants and their co-conspirators should provide when 
they called the IRS to check on the status of their tax refund. On or about November 27, 2022, 
HAMES texted the instructions he received from K. WILLIAMS to Co-Conspirator #6. 
58. 
Form 941 , on which the COVrD-Related Tax Credits were claimed by the 
defendants and their co-conspirators, required the taxpayer to have an Employer Identification 
Number ("EIN"), which is a nine-digit federal tax identification number assigned by the IRS for 
businesses, tax-exempt organizations and other entities. If a prospective client did not have an 
EJN, the defendants KEITH WILLIAMS, JANINE DA VIS, MORAIS DICKS, JAMES 
HAMES, JR., JAMAR! LEWIS, EWENDRA MATHURIN and TIFF ANY WILLIAMS, 
together with others, sometimes provided the client with a business with an EIN or facilitated the 
client's purchase of one to then be used to file Forms 941 claiming COVID-Related Tax Credits. 
Often, the entities that the defendants provided to clients were shell companies or companies that 
were previously operational businesses but were no longer operating. 
59. 
On occasion, the IRS and SSA requested additional info1mation regarding 
the Forms 941 filed by the defendants KEITH WILLIAMS, JANINE DAVJS, MORAIS DICKS, 
JAMES HAMES, JR., JAMAR! LEWIS, EWENDRA MATHURIN and TIFFANY 
WILLIAMS. When that happened, the defendants and their co-conspirators transmitted and 
caused to be transmitted false information to the IRS and prepared and filed with the SSA false 
Forms W-2 corresponding to the previously fi led false Forms 941. For example, in or about 
March 2022, LEWIS instructed Co-Conspirator #5 to submit false information regarding 
Business #7 to the ]RS in response to a request for taxpayer information. 
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V. 
The Defendants' Fraudulent PPP Loans 
60. 
From the onset of the COVID-19 pandemic, the defendants KEITH 
WILLJAMS, JANINE DA VIS, MORAIS DICKS, JAMES HAMES, JR., JAMARl LEWIS, 
EWENDRA MATHURIN and TIFFANY WILLIAMS also each fraudulently obtained 
government funds by filing and causing to be filed false PPP loan applications requesting PPP 
loans for themselves. 
61. 
Among other things, in some instances, the defendants provided false 
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supporting documentation included with their PPP loan applications, including false tax forms 
representing, among other falsehoods, that wages were paid that were not paid to employees that 
did not exist. Some of the false tax forms that were included in the PPP loan applications were 
never filed with the IRS. The PPP loan applications themselves were also fraudulent in that in 
some instances, the defendants represented that wages were paid that were not paid to employees 
that did not exist. 
COUNT ONE 
(Conspiracy to Defraud the United States) 
62. 
The allegations contained in paragraphs one through 61 are real leged and 
incorporated as if fully set forth in this paragraph. 
63. 
In or about and bet\veen November 202 1 and June 2023, both dates being 
approximate and inclusive, within the Eastern District of New York and elsewhere, the 
defendants KEITH WILLIAMS, JANINE DAVIS, also known as "Holiday Davis," MORA IS 
DlCKS, JAMES HAMES, JR., also known as "Poppa J," JAMARl LEWIS, also known as "Mr. 
Chaketah," EWENDRA MA THURJN, also known as "Rayda Mathurin," and TIFF ANY 
WILLIAMS, also known as "Joy Williams," together with others, did knowingly and willfully 
conspire to defraud the United States by impeding, impairing, obstructing and defeating the 
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lawful governmental functions of the IRS, specifically, the administration and distribution of 
COYID-Related Tax Credits. 
64. 
In furtherance of the conspiracy and to effect its objects, within the 
Eastern District of New York and elsewhere, the defendants KEITH WILLIAMS, JANINE 
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DA VIS, also known as "Holiday Davis," MO RATS DICKS, JAMES HAMES, JR., also known 
as "Poppa J," JAMA RT LEWIS, also known as "Mr. Chaketah," EWENDRA MATHURIN, also 
known as "Rayda Mathurin," and TIFF ANY WJLLlAMS, also known as "Joy Williams," 
together with others, did commit and cause the commission of, among others, the following: 
OVERT ACTS 
(a) 
On or about November 29, 2021, LEWIS directed Co-Conspirator 
#1 to file a fraudulent Form 941 claiming an approximately $64,182 tax refund based on 
COVID-1 9 Related Tax Credits for Chakeetah to which it was not entitled. 
(b) 
On or about January 28, 2022, K. WILLIAMS and LEWIS 
directed Co-Conspirator #1 to file a fraudulent Form 941 claiming an approximately $ 11 5,632 
tax refund based on COVID-19-Related Tax Credits for 109 Super Store to which it was not 
entitled. 
(c) 
On or about February 8, 2022, MATHURIN prepared and filed and 
caused to be prepared and filed with the IRS a fraudulent Form 941 claiming an approximately 
$59,966.39 tax refund based on COYID-19-Related Tax Credits for Island Stream for which it 
was not entitled. 
(d) 
On or about March 18, 2022, DAVIS prepared and filed and 
caused to be prepared and filed with the IRS a fraudulent Form 941 claiming an approximately 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 16 of 34 PageID #: 16

17 
$54,976.14 tax refund based on COVID-19-Related Tax Credits for Holiday's Promise for which 
it was not entitled. 
(e) 
On or about March 18, 2022, T. WILLIAMS prepared and filed 
and caused to be prepared and filed with the IRS a fraudulent Form 941 claiming an 
approximately $45,989.12 tax refund based on COVTD-19-Related Tax Credits for J2 for which 
it was not entitled. 
(f) 
On or about June 20, 2022, Co-Conspirator #2 caused to be 
prepared and filed with the IRS a fraudulent Form 941 claiming an approximately $ 11 5,992.14 
tax refund based on COVID-19-Related Tax Credits for Company #2 for which it was not 
entitled. 
(g) 
On or about June 23, 2022, HAMES prepared and filed and caused 
to be prepared and filed with the IRS a fraudulent Form 94 1 claiming an approximately 
$7 1,875.94 tax refund based on COVID-19-Related Tax Credits for Company # 12 for which it 
was not entitled. 
(h) 
On or about July 14, 2022, K. WJLLIAMS prepared and filed and 
caused to be prepared and filed with the IRS a fraudulent Form 941 claiming an approximately 
$57,816.22 tax refund based on COVID-19-Related Tax Credits for Company #6, for which it 
was not entitled. 
(i) 
On or about September 30, 2022, LEWIS prepared and filed and 
caused to be prepared and filed with the IRS a fraudulent Form 94 1 claiming an approximately 
$67,092.02 tax refund based on COVID-19-Related Tax Credits for Chakeetah for which it was 
not entitled. 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 17 of 34 PageID #: 17

U) 
On or about October 22, 2022, LEWIS and Co-Conspirator #5 
prepared and filed and caused to be prepared and filed with the IRS a fraudulent Form 941 
claiming an approximately $73,970.67 tax refund based on COYlD-19-Related Tax Credits for 
Company #7 for which it was not entitled. 
(k) 
On or about January 5, 2023, DICKS directed Lndividual # I, who 
just days prior had received over $200,000 in tax refund checks as a result of false Forms 94 1 
prepared and filed by the defendants and their co-conspirators, to write a check for $I00,000 to 
Progressive Homes. 
(Title 18, United States Code, Sections 371 and 3551 et seq.) 
COUNTS TWO THROUGH SEVEN 
(Wire Fraud) 
18 
65. 
The allegations contained in paragraphs one through 61 are realleged and 
incorporated as if fully set forth in this paragraph. 
66. 
On or about the dates set forth below, within the Eastern District of New 
York and elsewhere, the defendant KEITH WlLLIAMS, together with others, did knowingly and 
intentionally devise a scheme and artifice to defraud the IRS and to obtain money and property 
from the IRS by means of materially false and fraudulent pretenses, representations and 
promises, and for the purpose of executing such scheme and artifice did transmit and cause to be 
transmitted by means of wire communication in interstate and foreign commerce, writings, signs, 
signals, pictures and sounds, to wit: the following Forms 941, all of which were electronically 
filed with the IRS. 
Approximate 
Count 
Date 
Description of Wire Transmission 
A Form 94 1 for 2021 4th Quarter for 109 Super Store claiming 
TWO 
1/28/2022 
a tax refund of approximately $115,632. 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 18 of 34 PageID #: 18

Count 
THREE 
FOUR 
FIVE 
SIX 
SEVEN 
19 
Approximate 
Date 
Description of Wire Transmission 
A Form 94 1 for 2021 I st Quarter for Lucky 13 claiming a tax 
1/3 1/2022 
refund of approximately $76,012. 
A Form 941 for 2022 l st Quarter for I 09 Super Store claiming a 
5/30/2022 
tax refund of approximately $61,230.51. 
A Form 94 1 for 2022 2nd Quarter for Babylon Buyers claiming 
6/30/2022 
a tax refund of approximately $63,948.22. 
A Form 941 for 2022 3rd Quarter for Babylon Buyers claiming 
I 0/ 19/2022 
a tax refund of approximately $63,948.35. 
A Form 94 1 for 2022 2nd Quarter for Lucky 13 claiming a tax 
I 0/ 19/2022 
refund of approximately $66,576.28. 
(Title 18, United States Code, Sections 1343, 2 and 3551 et~-) 
COUNTS EIGHT THROUGH TEN 
(Wire Fraud) 
67. 
The allegations contained in paragraphs one through 61 are realleged and 
incorporated as if fully set forth in this paragraph. 
68. 
On or about the dates set forth below, within the Eastern District of New 
York and elsewhere, the defendant JAMARI LEWIS, also known as "Mr. Chaketah," together 
with others, did knowingly and intentionally devise a scheme and artifice to defraud the IRS and 
to obtain money and property from the IRS by means of materially false and fraudulent 
pretenses, representations and promises, and for the purpose of executing such scheme and 
artifice did transmit and cause to be transmitted by means of wire communication in interstate 
and foreign commerce, writings, signs, signals, pictures and sounds, to wit, the following Forms 
941, all of which were electronically filed with the IRS: 
Approximate 
Count 
Date 
Description 
A Form 941 for 2020 2nd Quarter for Chakeetah claiming a 
EIGHT 
11/29/202 1 
tax refund of approximately $64,182. 
A Form 941 for 2021 3rd Quarter for Chakeetah claiming a tax 
NINE 
12/3/202 1 
refund of approximately $68,646.97. 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 19 of 34 PageID #: 19

Count 
TEN 
Approximate 
Date 
Description 
A Form 941 for 2021 2nd Quarter for Chakeetah claiming a 
12/4/2021 
tax refund of approximately $85,897.80. 
(Title 18, United States Code, Sections 1343, 2 and 3551 et~-) 
COUNTS ELEVEN THROUGH FOURTEEN 
(Wire Fraud) 
20 
69. 
The allegations contained in paragraphs one through 61 are realleged and 
incorporated as if fully set forth in this paragraph. 
70. 
On or about the dates set forth below, within the Eastern District of New 
York and elsewhere, the defendant EWENDRA MA THURlN, also known as "Rayda," together 
with others, did knowingly and intentionally devise a scheme and artifice to defraud the IRS and 
to obtain money and property from the IRS by means of materially false and fraudulent 
pretenses, representations and promises, and for the purpose of executing such scheme and 
artifice did transmit and cause to be transmitted by means of wire communication in interstate 
and foreign commerce, writings, signs, signals, pictures and sounds, to wit, the following Forms 
941, all of which were electronically filed with the IRS: 
Count 
Annroximate Date 
Description 
A Form 94 l for 2021 I st Quarter for Island Stream 
ELEVEN 
2/8/2022 
claiming a tax refund of approximately $59,966.39. 
A Form 941 for 202 1 4th Quarter for Island Stream 
TWELVE 
4/5/2022 
claiming a tax refund of approximately $74,834.13. 
A Farm 94 l for 2020 2nd Quarter for Rich n' Yummy 
TIDRTEEN 
10/26/2022 
claiming a tax refund of approximately $89,807.51 . 
A Farm 941 for 2021 3rd Quarter for Rich n' Yummy 
FOURTEEN 
10/26/2022 
claiming a tax refund of approximately$ I 00,500.13. 
(Title 18, United States Code, Sections 1343, 2 and 3551 et~-) 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 20 of 34 PageID #: 20

COUNTS FIFTEEN THROUGH TWENTY 
(Wire Fraud) 
21 
71. 
The allegations contained in paragraphs one through 61 are realleged and 
incorporated as if fully set forth in this paragraph. 
72. 
On or about the dates set forth below, within the Eastern District of New 
York and elsewhere, the defendant JANINE DAVIS, also known as "Holiday Davis," together 
with others, did knowingly and intentionally devise a scheme and artifice to defraud the IRS and 
to obtain money and property from the IRS by means of materially false and fraudulent 
pretenses, representations and promises, and for the purpose of executing such scheme and 
artifice did transmit and cause to be transmitted by means of wire communication in interstate 
and foreign commerce, writings, signs, signals, pictures and sounds, to wit, the following Forms 
941, all of which were electronically filed with the IRS: 
Approximate 
Count 
Date 
Deserio ti on 
A form 941 for 2020 2nd Quarter for Holiday's Promise 
FIFTEEN 
3/ 18/2022 
claiming a tax refund of approximate Iv $54,976. I 4. 
A Form 941 for 202 1 I st Quarter for 7 Port claiming a tax 
SIXTEEN 
5/30/2022 
refund of approximately $235,084.68. 
A Form 941 for 202 1 2nd Quarter for 7 Port claiming a 
SEVENTEEN 
5/30/2022 
tax refund of annroximately $255,192.60. 
A Form 941 for 202 1 4th Quarter for Holiday's Promise 
EIGHTEEN 
6/2/2022 
claiming a tax refund of approximately $217,376.71. 
A Form 941 for 2021 3rd Quarter for Janine Davis (sole 
proprietorship) claiming a tax refund of approximately 
NINETEEN 
6/2/2022 
$ 145,007.90. 
A Form 941 for 2020 3rd Quarter for Janine Davis (sole 
proprietorship) claiming a tax refund of approximately 
TWENTY 
6/2/2022 
$66,390.90. 
(Title I 8, United States Code, Sections 1343, 2 and 3551 et~-) 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 21 of 34 PageID #: 21

COUNTS TWENTY-ONE THROUGH TWENTY-FOUR 
(Wire Fraud) 
22 
73. 
The allegations contained in paragraphs one through 61 are realleged and 
incorporated as if fully set forth in th is paragraph. 
74. 
On or about the dates set forth below, within the Eastern District of New 
York and elsewhere, the defendant TIFFANY WILLIAMS, also known as "Joy Williams," 
together with others, did knowingly and intentionally devise a scheme and artifice to defraud the 
IRS and to obtain money and property from the IRS by means of materially false and fraudulent 
pretenses, representations and promises, and for the purpose of executing such scheme and 
artifice did transmit and cause to be transmitted by means of wire communication in interstate 
and foreign commerce, writings, signs, signals, pictures and sounds, to wit, the following Forms 
941, all of which were electronically fi led with the IRS: 
Count 
TWENTY-
ONE 
TWENTY-
TWO 
TWENTY-
THREE 
TWENTY-
FOUR 
Annroximate Date 
Descriotion 
A Form 941 for 202 1 I st Quarter for J2 claiming a tax 
3/18/2022 
refund of approximatelv $45,989.12. 
A Form 94 l for 2020 4th Quarter for J2 claiming a tax 
4/1/2022 
refund of approximately $53,519.40. 
A Form 94 l for 202 1 I st Quarter for Joy the 
Bookkeeper claiming a tax refund of approximately 
4/8/2022 
$41,436.35. 
A Form 94 l for 2020 3rd Quarter for Joy the 
Bookkeeper claiming a tax refund of approximately 
4/9/2022 
$44,337.38. 
(Title 18, United States Code, Sections 1343, 2 and 355 1 et seq.) 
COUNTS TWENTY-FIVE THROUGH TWENTY-SEVEN 
(Wire Fraud) 
75. 
The allegations contained in paragraphs one through 61 are realleged and 
incorporated as if fully set forth in this paragraph. 
76. 
On or about the dates set forth below, within the Eastern District of New 
York and elsewhere, the defendant JAMES HAMES, JR., also known as "Poppa J," together 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 22 of 34 PageID #: 22

23 
with others, did knowingly and intentionally devise a scheme and artifice to defraud the IRS and 
to obtain money and property from the IRS by means of materially false and fraudulent 
pretenses, representations and promises, and for the purpose of executing such scheme and 
artifice did transmit and cause to be transmitted by means of wire communication in interstate 
and foreign commerce, writings, signs, signals, pictures and sounds, to wit, the following Forms 
94 1, all of which were electronically filed with the IRS: 
Count 
TWENTY-
FIVE 
TWENTY-
STX 
TWENTY-
SEVEN 
Aooroximate Date 
Descriotion 
A Form 941 for 2022 1st Quarter for MJR claiming a tax 
6/15/2022 
refund of approximately $75,358.31. 
A Form 941 for 2022 3rd Quarter for MJR claiming a tax 
10/24/2022 
refund of approximately $71,658.75. 
A Form 941 for 2022 4th Quarter for MJR claiming a tax 
l/16/2023 
refund of approximately $78,496.01. 
(Title 18, United States Code, Sections 1343, 2 and 3551 et~-) 
COUNTS TWENTY-EIGHT THROUGH THIRTY-THREE 
(Aiding and Assisting in the Preparation of False Tax Returns) 
83. 
The allegations contained in paragraphs one through 61 are realleged and 
incorporated as if fully set forth in this paragraph. 
84. 
On or about the dates set forth below, within the Eastern District of New 
York, and elsewhere, the defendant KEITH WILLIAMS willfully aided and assisted in, and 
procured, counseled, and advised the preparation and presentation to the IRS of a Form 941, 
Employer' s Quarterly Federal Tax Returns, for each of the periods stated below, which were 
false and fraudulent as to one or more material matters, and which K. WILLIAMS did not 
believe to be true and correct as to every material matter: 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 23 of 34 PageID #: 23

Tax 
Approx. 
Count 
Entity 
Period 
Date 
False Items 
• Line 1, number of employees 
• Line 2, wages, tips, and other 
compensation 
• Line 13e, Total deposits and 
TWENTY-
Company 
2021 1st 
refundable credits 
EIGHT 
#7 
Quarter 
1/3 1/2022 • Line 15, Overpayment 
• Line 2, wages, tips, and other 
compensation 
• Line 13e, Total deposits, 
TWENTY-
Company 
2020 2nd 
deferrals, and refundable credits 
NfNE 
#1 
Quarter 
2/1 /2022 
• Line 15, Overpayment 
• Line I, number of employees 
• Line 2, wages, tips, and other 
compensation 
• Line 13g, Total deposits and 
Company 
2021 3rd 
refundable credits 
THIRTY 
#5 
Quarter 
3/26/2022 • Line 15, Overpayment 
• 
Line 1, number of employees 
• 
Line 2, wages, tips, and other 
compensation 
• Line 13g, Total deposits and 
THIRTY-
Company 
2021 4th 
refundable credits 
ONE 
#4 
Qua1ter 
4/18/2022 • Line 15, Overpayment 
• Line 1, number of employees 
• Line 2, wages, tips, and other 
compensation 
• Line l 3e, Total deposits and 
THIRTY-
Company 
2021 1st 
refundable credits 
TWO 
#2 
Quarter 
6/20/2022 • Line 15, Overpayment 
• Line 1, number of employees 
• Line 2, wages, tips, and other 
compensation 
• Line 13g, Total deposits and 
THIRTY-
Company 
2022 2nd 
refundable credits 
THREE 
#6 
Quarter 
7/14/2022 • Line 15, Overpayment 
(Title 26, United States Code, Section 7206(2); Title 18, United States Code, 
Sections 3551 et filill.) 
24 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 24 of 34 PageID #: 24

COUNTS THIRTY-FOUR THROUGH FORTY-TWO 
(Aiding and Assisting in the Preparation of False Tax Returns) 
25 
87. 
The allegations contained in paragraphs one through 61 are realleged and 
incorporated as if fully set forth in this paragraph. 
88. 
On or about the dates set forth below, within the Eastern District of New 
York, and elsewhere, the defendant JAMES HAMES, JR., also known as "Poppa J," willfully 
aided and assisted in, and procured, counseled, and advised the preparation and presentation to 
the IRS of a Form 941, Employer's Quarterly Federal Tax Returns, for each of the periods stated 
below, which were false and fraudulent as to one or more material matters, and which HAMES 
did not believe to be true and correct as to every material matter: 
Tax 
Approx. 
Count 
Entity 
Period 
Date 
False Items 
• Line 2, wages, tips, and other 
compensation 
• Line 13e, Total deposits, 
deferrals, and refundable 
THIRTY-
2020 2nd 
credits 
FOUR 
Company #8 
Quarter 
6/23/2022 
• Line 15, Overpayment 
• Line 1, number of employees 
• Line 2, wages, tips, and other 
compensation 
• Line 13e, Total deposits and 
THIRTY-
2020 2nd 
refundable credits 
FIVE 
Company #9 
Quarter 
6/23/2022 
• Line 15, Overpayment 
• Line I, number of employees 
• Line 2, wages, tips, and other 
compensation 
• Line 13g, Total deposits and 
THIRTY-
202 1 4th 
refundable credits 
SIX 
Company # IO 
Quarter 
6/24/2022 
• Line 15, Overpayment 
• Line 1, number of employees 
• Line 2, wages, tips, and other 
compensation 
• Line 13g, Total deposits and 
THIRTY-
2021 3rd 
refundable credits 
SEVEN 
Company #14 
Quarter 
6/26/2022 
• Line 15, Overpayment 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 25 of 34 PageID #: 25

Tax 
Approx. 
Count 
Entitv 
Period 
Date 
False Items 
• Line l, number of employees 
• Line 2, wages, tips, and other 
compensation 
• Line I 3e, Total deposits and 
THIRTY-
202 I 1st 
refundable credits 
EIGHT 
Company # 13 
Quarter 
6/26/2022 
• Line I 5, Overpayment 
• Line I , number of employees 
• Line 2, wages, tips, and other 
compensation 
• Line I 3g, Total deposits and 
THIRTY-
2022 I st 
refundable credits 
NINE 
Company # 12 
Quarter 
6/26/2022 
• Line 15, Overpayment 
• Line 1, number of employees 
• Line 2, wages, tips, and other 
compensation 
• Line 13g, Total deposits and 
2021 2nd 
refundable credits 
FORTY 
Company #15 
Quarter 
6/26/2022 
• Line I 5, Overpayment 
• Line I, number of employees 
• Line 2, wages, tips, and other 
compensation 
• Line 13g, Total deposits and 
FORTY-
2021 2nd 
refundable credits 
ONE 
Company # 16 
Quarter 
7/4/2022 
• Line 15, Overpayment 
• Line I, number of employees 
• Line 2, wages, tips, and other 
compensation 
• Line I 3g, Total deposits and 
FORTY-
2022 4th 
refundable credits 
TWO 
Company # 11 
Quarter 
1/22/2023 
• Line 15, Overpayment 
(Title 26, United States Code, Section 7206(2); Title I 8, United States Code, 
Sections 3551 et seq.) 
COUNTS FORTY-THREE THROUGH FORTY-FIVE 
(Aiding and Assisting in the Preparation of False Tax Returns) 
26 
89. 
The allegations contained in paragraphs one through 61 are realleged and 
incorporated as if ful ly set forth in this paragraph. 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 26 of 34 PageID #: 26

27 
90. 
On or about the dates set forth below, within the Eastern District of New 
York, and elsewhere, the defendant MORAIS DICKS, willfully aided and assisted in, and 
procured, counseled, and advised the preparation and presentation to the IRS of a Form 941, 
Employer's Quarterly Federal Tax Returns for each of the periods stated below, which were false 
and fraudulent as to one or more material matters, and which DICKS did not believe to be true 
and conect as to every material matter: 
Tax 
Approx. 
Count 
Entitv 
Period 
Date 
False Items 
• Line 1, number of employees 
• Line 2, wages, tips, and other 
compensation 
• Line 13g, Total deposits and 
FORTY-
2021 3rd 
refundable credits 
THREE 
Company #17 
Quatter 
l 1/ 10/2022 • Line 15, Overpayment 
• Line I, number of employees 
• Line 2, wages, tips, and other 
compensation 
• Line 13g, Total deposits and 
FORTY-
202 1 4th 
refundable credits 
FOUR 
Company #17 
Qua1ter 
11/10/2022 
• 
Line 15, Overpayment 
• Line l, number of employees 
• Line 2, wages, tips, and other 
compensation 
• Line 13g, Total deposits and 
FORTY-
2022 1st 
refundable credits 
FIVE 
Company #17 
Quaiter 
11/10/2022 • Line 15, Overpayment 
(Title 26, United States Code, Section 7206(2); Title 18, United States Code, 
Sections 355 l et~-) 
COUNTS FORTY-SIX THROUGH FORTY-NINE 
(Wire Fraud) 
91. 
The allegations contained in paragraphs one through 61 are realleged and 
incorporated as if fully set forth in this paragraph. 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 27 of 34 PageID #: 27

28 
92. 
On or about the fo llowing dates, within the Eastern District of New York 
and elsewhere, the defendant KEITH WlLLIAMS, together with others, did knowingly and 
intentionally devise a scheme and artifice to defraud the SBA and one or more financial 
institutions administering the PPP program, and to obtain money and property from the SBA and 
said financial institutions by means of materially false and fraudulent pretenses, representations 
and promises, and for the purpose of executing such scheme and artifice did transmit and cause 
to be transmitted, by means of wire communication in interstate and foreign commerce, one or 
more writings, signs, signals, pictures and sounds, to wit: 
Count 
FORTY-
SIX 
FORTY-
SEVEN 
FORTY-
EIGHT 
FORTY-
NINE 
Approx. Date 
Description 
A PPP Loan Application filed for KEITH WILLIAMS (sole 
proprietorship) requesting a PPP loan of approximately 
4/15/2021 
$20,833. 
A PPP Loan Application filed for KEITH WILLIAMS (sole 
proprietorship) requesting a PPP loan of approximately 
5/7/2021 
$20,833. 
A PPP Loan Application filed for Co-Conspirator #2 (sole 
proprietorship) requesting a PPP loan of approximately 
4/18/2021 
$20,833. 
A PPP Loan Application filed for Co-Conspirator #2 (sole 
proprietorship) requesting a PPP loan of approximately 
5/5/2021 
$20,833. 
(Title 18, United States Code, Sections 1343, 2 and 3551 et~-) 
COUNTFIFTY 
(Wire Fraud) 
93. 
The allegations contained in paragraphs one through 61 are realleged and 
incorporated as if fully set forth in this paragraph. 
94. 
On or about March 18, 202 1, within the Eastern District of New York and 
elsewhere, defendant JAMARI LEWIS, also known as "Mr. Chaketah," together with others, did 
knowingly and intentionally devise a scheme and artifice to defraud the SBA and one or more 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 28 of 34 PageID #: 28

29 
financial institutions administering the PPP program, and to obtain money and property from the 
SBA and said financial institutions by means of materially false and fraudulent pretenses, 
representations and promises, and for the purpose of executing such scheme and a1tifice, did 
transmit and cause to be transmitted by means of wire communication in interstate and foreign 
commerce, one or more writings, signs, signals, pictures and sounds, to wit: a March 18, 2021 
PPP loan application filed for JAMARI LEWIS (sole proprietorship) requesting a PPP loan of 
approximately $20,750. 
(Title 18, United States Code, Sections 1343 and 3551 et~-) 
COUNTS FIFTY-ONE THROUGH FIFTY-TWO 
(Wire Fraud) 
95. 
The allegations contained in paragraphs one through 61 are realleged and 
incorporated as if fully set forth in this paragraph. 
96. 
On or about the following dates, within the Eastern District of New York 
and elsewhere, defendant EWENDRA MATHURIN, also known as, "Rayda," together with 
others, did knowingly and intentionally devise a scheme and artifice to defraud the SBA and one 
or more financial institutions administering the PPP program, and to obtain money and property 
from the SBA and said financial institutions by means of materially false and fraudulent 
pretenses, representations and promises, and for the purpose of executing such scheme and 
attifice, did transmit and cause to be transmitted by means of wire communication in interstate 
and foreign commerce, one or more writings, signs, signals, pictures and sounds, to wit: 
Count 
Approx. Date 
Description 
A PPP loan application filed for EWENDRA MATHURIN 
FIFTY-
(sole proprietorship) requesting a PPP loan of approximately 
ONE 
4/18/2021 
$20,833. 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 29 of 34 PageID #: 29

Count 
FIFTY-
TWO 
30 
Approx. Date 
Description 
A PPP loan application filed for EWENDRA MATHURIN 
(sole proprietorship) requesting a PPP loan of approximately 
5/8/202 L 
$20,833. 
(Title 18, United States Code, Sections 1343, 2 and 355 1 et~-) 
COUNT FIFTY-THREE 
(Wire Fraud) 
97. 
The allegations contained in paragraphs one through 61 are realleged and 
incorporated as if fully set forth in this paragraph. 
98. 
On or about April 16, 2021, within the Eastern District of New York and 
elsewhere, defendant JANINE DA VIS, also known as "Holiday Davis," together with others, did 
knowingly and intentionally devise a scheme and artifice to defraud the SBA and one or more 
financial institutions administering the PPP program, and to obtain money and property from the 
SBA and said financial institutions by means of materially false and fraudu lent pretenses, 
representations and promises, and for the purpose of executing such scheme and artifice, did 
transmit and cause to be transmitted by means of wire communication in interstate and foreign 
commerce, one or more writings, signs, signals, pictures and sounds, to wit: an April 16, 2021 
PPP loan application fi led for JANINE DA VIS (sole proprietorship) requesting a PPP loan of 
approximately $20,833. 
(Title 18, United States Code, Sections 1343, 2 and 3551 et~-) 
COUNT FIFTY-FOUR 
(Wire Fraud) 
99. 
The allegations contained in paragraphs one through 61 are realleged and 
incorporated as if fully set forth in this paragraph. 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 30 of 34 PageID #: 30

31 
100. 
On or about June 29, 2020, within the Eastern District of New York and 
elsewhere, defendant TIFFANY WILLIAMS, also known as "Joy Williams," together with 
others, did knowingly and intentionally devise a scheme and artifice to defraud the SBA and one 
or more financial institutions administering the PPP program, and to obtain money and property 
from the SBA and said financial institutions by means of materially false and fraudulent 
pretenses, representations and promises, and for the purpose of executing such scheme and 
artifice, did transmit and cause to be transmitted by means of wire communication in interstate 
and foreign commerce, one or more writings, signs, signals, pictures and sounds, to wit: a June 
29, 2020 PPP loan application filed for Joy the Bookkeeper requesting a PPP loan of 
approximately $88,152. 
(Title 18, United States Code, Sections 1343, 2 and 3551 et~-) 
COUNTS FIFTY-FIVE THROUGH FIFTY-SIX 
(Wire Fraud) 
I O 1. 
The al legations contained in paragraphs one through 6 1 are real leged and 
incorporated as if fully set forth in this paragraph. 
I 02. 
On or about the following dates, within the Eastern District of New York 
and elsewhere, the defendant MORAIS DICKS, together with others, did knowingly and 
intentionally devise a scheme and artifice to defraud the SBA and one or more financial 
institutions administering the PPP program, and to obtain money and property from the SBA and 
said financial institutions by means of materially false and fraudulent pretenses, representations 
and promises, and for the purpose of executing such scheme and artifice did transmit and cause 
to be transmitted by means of wire communication in interstate and foreign commerce, one or 
more writings, signs, signals, pictures and sounds, to wit: 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 31 of 34 PageID #: 31

Count 
FIFTY-
FIVE 
FIFTY-
SIX 
Approx. Date 
Description 
A PPP loan application filed for Progressive Homes 
5/19/2020 
requesting a PPP loan of approximately $20,832. 
A PPP loan application file for Service Advisors 
6/3/2020 
requesting a PPP loan of approximately $20,833. 
(Title 18, United States Code, Sections 1343, 2 and 355 1 et ~-) 
CRIM INAL FORFEITURE ALLEGATION 
AS TO COUNTS TWO THROUGH TWENTY-SEVEN 
32 
103. 
The United States hereby gives notice to the defendants that, upon their 
conviction of any of the offenses charged in Counts Two through Twenty-Seven, the government 
will seek forfeiture in accordance with Title 18, United States Code, Section 981 (a)(l)(C) and 
Title 28, United States Code, Section 2461 (c), which require any person convicted of such 
offenses to forfeit any property, real or personal, constituting, or derived from, proceeds obtained 
directly or indirectly as a result of such offenses. 
I 04. 
If any of the above-described forfeitable property, as a result of any act or 
omission of the defendants: 
(a) 
cannot be located upon the exercise of due diligence; 
(b) 
has been transferred or sold to, or deposited with, a third pa1ty; 
(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 divided 
without difficulty; 
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 32 of 34 PageID #: 32

33 
seek forfeiture of any other property of the defendants up to the value of the forfeitable property 
described in this forfeiture allegation. 
(Title 18, United States Code, Section 98l(a)(l)(C); Title 21, United States Code, 
Section 853(p); Title 28, United States Code, Section 2461(c)) 
CRlMINAL FORFEITURE ALLEGA TTON 
AS TO COUNTS FORTY-SIX THROUGH FIFTY-SIX 
105. 
The United States hereby gives notice to the defendants charged in Counts 
Forty-Six through Fifty-Six that, upon their conviction of any of such offenses, the government 
will seek forfeiture in accordance with Title 18, United States Code, Section 982(a)(2), which 
requires any person convicted of such offenses to forfeit any property constituting, or derived 
from, proceeds obtained directly or indirectly as a result of such offenses. 
106. 
If any of the above-described forfeitable prope1ty, as a result of any act or 
omission of the defendants: 
(a) 
cannot be located upon the exercise of due diligence; 
(b) 
has been transferred or sold to, or deposited with, a third party; 
(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 divided 
without difficulty; 
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), as 
incorporated by Title 18, United States Code, Section 982(b)(I), to seek forfeiture of any other 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 33 of 34 PageID #: 33

34 
property of the defendants up to the value of the forfeitable property described in this forfeiture 
al legation. 
(Title 18, United States Code, Sections 982(a)(2) and 982(b)(l); Title 21 , United 
States Code, Section 853(p)) 
~Dav-d/J~ A<t-aC tl.S. At:tu7 
CAROLYN POKORNY 
ACTING UNITED STATES ATTORNEY 
EASTERN DISTRJCT OF NEW YORK 
A TRUE BILL 
Case 2:25-cr-00020-GRB     Document 1     Filed 01/15/25     Page 34 of 34 PageID #: 34

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