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Criminal Complaint — United States v. Sarkis Sarisyan et al. (Central District of California, May 23, 2025)

Summary

A criminal complaint, Document 1 in a United States case against Sarkis Sarkisyan, aka Samuel Shaw, Mikhael Mikhaelyan, Arsen Terzyan, aka Steven Terzaki, Sarkis Yemenejian and Marianna Sarkisyan, No. 2:25-cr-00456-MWC, in the U.S. District Court for the Central District of California, filed May 23, 2025. The AO 91 form cites 18 U.S.C. §§ 286, 287, 1343, 1344, 1956(h), 1956(a)(1) and 1957 for conduct between April 1, 2020 and June 30, 2022, and is signed /s/ Eric Ley, Special Agent, Office of Inspector General, U.S. Small Business Administration. An attached affidavit by Eric Ley covers the Paycheck Protection Program, the Economic Injury Disaster Loan program and Restaurant Revitalization Fund grants, then sets out probable cause allegations of wire fraud, bank fraud and money laundering involving businesses it calls Prime, Cornwall, Nairi, Rest, Tiny Tots, Grub House and Rustwood.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Criminal Complaint — United States v. Sarkis Sarisyan et al. (Central District of California, May 23, 2025).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/1-16da324f12/, SHA-256 b35040599f6149f573a0eaf7f10e70f338221de5ead8cb5f1e9529ad6e73af28.

Full text

          Case 2:25-cr-00456-MWC             Document 1       Filed 05/23/25      Page 1 of 49 Page ID #:1
AO 91 (Rev. 11/11) Criminal Complaint (Rev. by USAO on 3/12/20)          ‫ ܆‬Original   ‫ ܆‬Duplicate Original

               LODGED
        CLERK, U.S. DISTRICT COURT
                                        UNITED STATES DISTRICT COURT                                               FILED
                                                                                                         CLERK, U.S. DISTRICT COURT



                                                                                                           
        5/22/2025                                         for the                                      CENTRAL DISTRICT OF CALIFORNIA
                                                                                                                    ,9
                                                                                                         BY: ___________________ DEPUTY


     CENTRAL DISTRICT OF CALIFORNIA
                  MMC
      BY: ____________BB______ DEPUTY         Central District of California

 United States of America

                       v.

 SARKIS SARISYAN,
  aka “Samuel Shaw,”
 MIKHAEL MIKHAELYAN,
                                                                    Case No. 2:25-MJ-03138-DUTY
 ARSEN TERZYAN,
  aka “Steven Terzaki,”
 SARKIS YEMENEJIAN, and
 MARIANNA SARKISYAN,

                       Defendants


                                      CRIMINAL COMPLAINT BY TELEPHONE
                                     OR OTHER RELIABLE ELECTRONIC MEANS

           I, the complainant in this case, state that the following is true to the best of my knowledge and belief.

On or about the dates of between April 1, 2020 and June 30, 2022, in the county of Los Angeles in the Central

District of California, and elsewhere, the defendants violated:

              Code Section                                          Offense Description

              18 U.S.C. § 286                                       Conspiracy to Defraud Government with Respect
                                                                    to Claims
              18 U.S.C. § 287                                       False, Fictitious or Fraudulent Claims
              18 U.S.C. § 1343                                      Wire Fraud
              18 U.S.C. § 1344                                      Bank Fraud
              18 U.S.C. § 1956(h)                                   Money Laundering Conspiracy
              18 U.S.C. § 1956(a)(1)                                Laundering of Monetary Instruments
              18 U.S.C. § 1957                                      Engaging in Monetary Transactions in Property
                                                                    Derived from Specified Unlawful Activity

//

//

//

AUSAs: Mark Aveis (x4477), Gregg Marmaro (x8500)
        Case 2:25-cr-00456-MWC            Document 1       Filed 05/23/25     Page 2 of 49 Page ID #:2

        This criminal complaint is based on these facts:

         Please see attached affidavit.

        _ Continued on the attached sheet.


                                                                            /s/ Eric Ley, Special Agent
                                                                             Complainant’s signature

                                                                Eric Ley, Special Agent, Office of Inspector
                                                                General, U.S. Small Business Administration
                                                                              Printed name and title



Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephone.

Date:              0D\
                                                                              Judge’s signature

City and state: Los Angeles, California                    BBBHon. 3DWULFLD'RQDKXH, U.S. Magistrate JudgeBBBB
                                                                            Printed name and title




AUSAs: Mark Aveis (x4477), Gregg Marmaro (x8500)
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 3 of 49 Page ID #:3



                                Contents
I.    INTRODUCTION..........................................3

II.   PURPOSE OF AFFIDAVIT..................................4

III. SUMMARY OF PROBABLE CAUSE.............................7

IV.   PROBABLE CAUSE........................................7

      A.   The Paycheck Protection Program..................7

      B.   The Economic Injury Disaster Loan Program........9

      C.   PPPL Forgiveness................................11

      D.   Restaurant Revitalization Fund Grants...........12

      E.   SUBJECT SHAW: Wire Fraud, Bank Fraud, and Money
           Laundering re “Prime” PPPL......................13

           1.    SHAW’s Background..........................13

           2.    Offense Conduct re “Prime” PPPL............15

           3.    Wire Fraud re Prime’s PPPL Forgiveness
                 Application................................19

      F.   SUBJECT MIKHAELYAN: Wire Fraud, Bank Fraud, and
           Money Laundering re “Cornwall” PPPL.............20

      G.   SUBJECT MIKHAELYAN: Wire Fraud and False Claim re
           Cornwall EIDL...................................24

      H.   SUBJECTS MIKHAELYAN and YEMENEJIAN: Wire Fraud,
           False Claim, and Money Laundering re “Nairi” RRF
           ................................................25

      I.   MIKHAELYAN: Wire Fraud and False Claim re “Rest”
           EIDL Modification...............................28

      J.   SUBJECT YEMENEJIAN: Wire Fraud and False Claim re
           “Tiny Tots” EIDL................................30

      K.   SUBJECT TERZYAN: Wire Fraud, False Claim, and
           Money Laundering re “Grub House” EIDL and EIDL
           Modification....................................34

      L.   SUBJECT TERZYAN: Wire Fraud, False Claim, and
           Money Laundering re “Grub House” RRF............37

      M.   SUBJECT MARIANNA: Wire Fraud, False Claim, and
           Money Laundering re “Rustwood” EIDL.............42


                                      1
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 4 of 49 Page ID #:4



     N.    SUBJECT MARIANNA: Wire Fraud and False Claim re
           Personal EIDL...................................45

V.   CONCLUSION...........................................47




                                      2
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 5 of 49 Page ID #:5



                                AFFIDAVIT

     I, Eric Ley, being duly sworn, declare and state as

follows:

                            I. INTRODUCTION

     1.    I have been a federal agent for more than 12 years.

Since May 2021, I have been a Special Agent of the U.S. Small

Business Administration (“SBA”), Office of Inspector General

(“SBA-OIG”).    Before that, I was a Special Agent with the United

States Secret Service for eight years.

     2.    Since graduating from the Criminal Investigator

Training Program conducted at the Federal Law Enforcement

Training Center, I have over ten years of experience

investigating various criminal offenses including bank fraud,

wire fraud, and money laundering.         As such, I have interviewed

hundreds of witnesses and targets, participated in the execution

of numerous search and arrest warrants relating to financial

crimes, and worked with federal prosecutors to prepare

investigations for prosecution.

     3.    For the past four years, I have focused on

investigating crimes associated with SBA-related loan and

guarantee programs including pandemic stimulus funding,

sometimes referred to as Covid-19 fraud.          From reviewing dozens

of pandemic stimulus loan files and documents associated with

those files such as subpoenaed bank records and public records,

I have become familiar with the processing and vetting of

applications under the Paycheck Protection and Economic Injury



                                      3
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Disaster Loan programs, among other pandemic-related funding

programs.

     4.     Through my investigations, my training and experience,

and discussions with other law enforcement personnel, I have

become familiar with the tactics and methods employed by those

who conduct wire fraud schemes using fraudulent loan statements

and fabricated documents, money laundering, and identity theft,

among other federal offenses.         These methods include, but are

not limited to, the use of wireless communications technology,

such as encrypted messaging platforms such as “WhatsApp;” the

creation or purchase of corporate “shells,” i.e., corporations

that have been formed through the filing of articles of

incorporation but conduct no business and are used solely to

create the appearance of legitimacy; fabricating bank statements

or other business documents to satisfy lender underwriting

requirements to qualify for loans; and moving funds through

multiple accounts to promote and conceal fraud.

                         II. PURPOSE OF AFFIDAVIT

     5.     This affidavit is made in support of a criminal

complaint against, and request for issuance of arrest warrants

for, the following individuals (also, where context requires, by

“SUBJECT [NAME],” or collectively, the “SUBJECTS”), for

violations of 18 U.S.C. §§ 286/287 (conspiracy to defraud the

government with respect to claims/make false claims), 1343 (wire

fraud), 1344 (bank fraud), 1956(h) (money laundering

conspiracy), 1956(a)(1) et seq. (money laundering), 1957

(engaging in monetary transactions in property derived from

                                       4
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specified unlawful activity), and/or 31 U.S.C. §§ 5313, 5324

(structuring) (collectively, the “Subject Offenses”) as more

fully described below:

     SARKIS SARKISYAN, AKA SAMUEL SHAW (“SHAW”);

     MIKHAEL MIKHAELYAN (“MIKHAELYAN”);

     ARSEN TERZYAN, AKA STEVEN TERZAKI (“TERZYAN”);

     SARKIS YEMENEJIAN (“YEMENEJIAN”); and

     MARIANNA SARKISYAN (“MARIANNA”).

     6.    The facts set forth in this affidavit are based on my

personal observations; my training and experience; witness

interviews that I have conducted; reports that I have read of

interviews conducted by other law enforcement agents; my review

of documents obtained from third parties, either by way of

subpoena or voluntary submission, such as bank or business

records; my review of publicly-filed documents such as corporate

filings; Internet searches for open source information;

financial analyses or financial records summaries prepared by a

SBA analyst who told me that she reviewed and prepared such

analyses and summaries from bank and other financial records

obtained in this investigation, and whom I believe to be

qualified to make such analyses and summaries from having worked

with her for several years and having reviewed her work product

in other matters; and my review of documents created or amassed

by the SBA in connection with providing funding for the various

loans and grants more fully described below.           Accordingly,

absent mention below of specific attribution from any of the




                                      5
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above-summarized evidence, I have, solely for clarity, generally

omitted attribution for a specific fact.

     7.    Whenever I refer herein to a bank, I mean a financial

institution whose deposits were insured by the Federal Deposit

Insurance Corporation.     Whenever I refer herein to bank records,

I have done so by identifying each account by an abbreviation

for the bank followed by the account’s last four digits, e.g.,

“JPMC 1234.”    Whenever I refer to the substance or content of

such accounts, such reference is based on my review of the

records of the account(s), including bank statements, signature

card/account application documents, canceled checks, offset and

credits, and other records provided by each bank pursuant to a

grand jury subpoena.     Similarly, unless stated otherwise,

whenever I refer to records of or relating to the SBA, I am

referring to SBA records that I have reviewed as accessible to

me in my capacity as a Special Agent of the SBA-OIG.

     8.    My description of the offense conduct below is based

on my review of the above-summarized evidence and is provided

solely for the purpose of establishing probable cause to believe

that one or more of the above-stated offenses were committed by

the SUBJECTS.    Accordingly, I have not described all of the

evidence that I have reviewed during the course of this

investigation and my omission of evidence or mention of other

subjects or targets of this investigation should be considered

in that light.

     9.    Unless stated otherwise, all conversations and

statements described in this affidavit are related in substance


                                      6
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and/or in part only; all dates are “on or about” or

approximations; all amounts are rounded or close approximations;

and the words “on or about” and “approximately” are omitted for

clarity.

                    III. SUMMARY OF PROBABLE CAUSE

       10.   I have probable cause to believe that the SUBJECTS

committed the Subject Offenses by creating, purchasing, or using

corporations for use in name only, i.e., as “shells”; opening

and assisting others in opening one or more bank accounts in the

names of those shells; submitting and assisting others to submit

fraudulent applications to obtain millions of dollars in

pandemic stimulus funding; creating and submitting fake

documents in support of those fraudulent applications; and

laundering and directing others to launder the proceeds of such

funding through multiple bank accounts for, ultimately, personal

use.

                          IV. PROBABLE CAUSE

       A.    The Paycheck Protection Program

       11.   The Coronavirus Aid, Relief, and Economic Security

(“CARES”) Act was a federal law enacted in or about March 2020

that was designed to provide emergency financial assistance to

Americans suffering economic harm as a result of the COVID-19

pandemic.    One form of assistance provided by the CARES Act was

the authorization of United States taxpayer funds in the form of

loans to small businesses for job retention and certain other

expenses, through a program referred to as the Paycheck

Protection Program (“PPP;” loans under that program are

                                      7
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 10 of 49 Page ID #:10



 sometimes referred to herein as a “PPPL” or “PPPLs”).             PPPL

 proceeds were required to be used by the applicant business to

 pay certain expenses such as payroll costs, interest on

 mortgages, rent, and utilities.

         12.   In order to obtain a PPPL, a qualifying business was

 required, among other things, to submit a PPPL application that

 required the applicant business (through its authorized

 representative) to acknowledge PPP program rules and make

 certain affirmative certifications that the applicant business

 would comply with all such rules to be eligible to obtain a

 PPPL.    Such certifications required, among other things, that

 the applicant affirm that “[PPP] funds will be used to retain

 workers and maintain payroll or make mortgage interest payments,

 lease payments, and utility payments,” and that the “loan

 proceeds will be used only for business-related purposes as

 specified in the [PPPL application]” and consistent with PPP

 rules.    The authorized representative of the applicant was also

 required to certify that “the information provided in th[e] PPP

 application and the information provided in all supporting

 documents and forms is true and accurate in material respects,”

 and that “I understand that if the funds are knowingly used for

 unauthorized purposes, the federal government may hold me

 legally liable, such as for charges of fraud.”

         13.   A PPPL applicant’s representative was also required

 to state, among other things, the applicant’s average monthly

 payroll expenses and number of its employees.           These figures

 were used to calculate the amount of money that the business was


                                      8
Case 2:25-cr-00456-MWC    Document 1   Filed 05/23/25   Page 11 of 49 Page ID #:11



 eligible to receive under the PPP.         In addition, the applicant’s

 representative was required to provide documentation showing its

 payroll expenses and such other documentation as the SBA or the

 lender requested.

       14.   A PPPL application and supporting documents were

 submitted online through a portal and processed by a

 participating lender.      The applicant’s representative confirmed

 his/her true identity through a variety of means including

 providing personal identifying information, uploading a copy of

 that person’s driver’s license and/or Social Security card,

 and/or executing loan documents via a document authentication

 platform such as DocuSign.       If a PPPL application was approved,

 the participating lender would fund the PPPL using its own funds

 and would wire-transfer those funds to a bank account designated

 by the applicant.       By wire-transferring the loan proceeds to

 that designated account, the lender, the SBA and, ultimately,

 law enforcement would have yet another way to ensure that the

 application was sought by the stated applicant through his/her

 duly acting representative and that the applicant received and

 used those funds in accordance with PPP rules.

       15.   If PPP lending criteria were followed by the lender,

 the SBA, in turn, guaranteed the borrower’s repayment in the

 event of that borrower’s default.

       B.    The Economic Injury Disaster Loan Program

       16.   In addition to the PPP, the CARES Act authorized

 taxpayer funds under the Economic Injury Disaster Loan program

 (individually, an “EIDL,” or collectively, “EIDLs”).              The EIDL


                                       9
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 12 of 49 Page ID #:12



 program provided low-interest funding to small businesses,

 renters, and homeowners affected by the COVID-19 pandemic.

       17.   In order to obtain an EIDL, a qualifying business was

 required to submit an application to the SBA, typically through

 an online portal, and provide information about its operations,

 such as the nature of the applicant’s business, e.g.,

 “agriculture,” the number of employees, and gross revenues for

 the 12-month period preceding the Covid-19 pandemic.             Like

 PPPLs, EIDL applicants were required to certify that all

 information in the application as provided by the applicant or

 on behalf of the applicant by their authorized representative

 was true and correct.

       18.   An EIDL “Loan Authorization and Agreement” (“LA&A”)

 was executed by the applicant’s authorized representative as a

 condition of receipt of EIDL proceeds that stated that.             The

 LA&A required that the applicant use the EIDL proceeds only for

 purposes stated in EIDL rules, such as for employee payroll

 expenses, employee sick leave, and business obligations and

 expenses such as business debts, rent, and mortgage payments.

 EIDL funds could not be used other than for those purposes,

 including that such funds could not be deposited or held for

 future business operations, used to capitalize a new business or

 for business start-up expenses, or used for purposes not

 associated with the operation of a going concern.

       19.   The amount of an EIDL was determined, in part, by the

 applicant’s representations in the EIDL application about the

 nature of the applicant’s business and the applicant’s


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Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 13 of 49 Page ID #:13



 statements about employees, and revenue.          Any funds paid under

 an EIDL were issued directly by the SBA from CARES Act

 appropriations by Congress.

       20.   If the EIDL applicant also obtained a PPPL, EIDL

 proceeds could not be used for the same purpose as the PPP loan

 proceeds.

       21.   PPP and EIDL applicants were also obligated to

 provide true and correct information in response to requests by

 PPP lenders or the SBA as part of the PPPL and EIDL vetting

 process, such as requests to clarify business ownership and

 requests to provide genuine payroll tax documents such as IRS

 Forms 940, 941, or W3 “Transmittal of Wage and Tax Statements.”

       C.    PPPL Forgiveness

       22.   Under certain circumstances, PPPL borrowers were

 entitled to forgiveness of their PPP obligations.            As a

 condition of forgiveness, borrowers were required to complete a

 “PPP Loan Forgiveness Application” on which their authorized

 representative represented and certified that the borrower had

 complied with all PPP rules “including the rules related to              . .

 . eligible uses of PPP loan proceeds[]” and that “[t]he

 information provided in th[e forgiveness application was] true

 and correct in all material respects.”         The forgiveness

 application warned that ”knowingly making a false statement to

 obtain forgiveness was a federal crime, punishable by

 imprisonment and/or a fine.”

       23.   I know from my training and experience, and from

 evidence gathered in this case, that PPPL lenders and the SBA


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 relied on an applicant’s truthfulness in statements made on

 applications and related documents, and on the genuineness of

 documents submitted by applicants in support of applications, to

 determine whether to approve PPPLs or EIDLs.

       D.    Restaurant Revitalization Fund Grants

       24.    In March 2021, the American Rescue Plan Act became

 law and established the Restaurant Revitalization Fund (“RRF”)

 for which Congress appropriated $28.6 billion for the SBA to

 award emergency assistance to qualifying businesses that served

 food or drink, essentially restaurants.          Entitlement was

 substantially based on pandemic-caused revenue loss.             The RRF

 was a conditional grant program, meaning that RRF recipients

 were not required to repay the funds so long as those funds were

 used for specific expenses and by a certain deadline.

       25.   RRF applicants submitted personal and business

 information, typically through an online SBA portal, in support

 of each RRF application.      Among other things, applicants were

 required to list all owners of 20% or more of the business.              The

 listing for each owner required the owner’s Employer

 Identification Number (“EIN”), Social Security number, or

 “Individual Taxpayer Identification Number.”

       26.   The SBA prioritized RRF awards to small businesses at

 least 51% owned and controlled by women, veterans, and/or the

 socially and economically disadvantaged.



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Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 15 of 49 Page ID #:15



         27.   RRF recipients were required to certify that they

 would use RRF proceeds for normal business operations such as

 for payroll costs, health care, business mortgages or rent.

 Recipients were then required to submit a “post-award report” in

 which they certified that their RRF proceeds were used in

 compliance with the program.

         E.    SUBJECT SHAW: Wire Fraud, Bank Fraud, and Money
               Laundering re “Prime” PPPL
               1.   SHAW’s Background
         28.   In 2011, SHAW, under his given name Sarkis

 Gareginovich Sarkisyan, was convicted in Santa Clara Superior

 Court, case no. B1151803, of unauthorized access to computers

 (Cal.Pen.C. sec. 502(c)(1)), theft of credit card information

 (Cal.Pen.C. sec. 484e), counterfeiting credit cards (Cal.Pen.C.

 sec. 484i), and conspiracy (Cal.Pen.C. sec. 182).            In 2023, SHAW

 changed his name from Sarkis Gareginovich Sarkisyan to Samuel

 SHAW.    Genuine images of SHAW’S prior and latest driver’s

 license are below:




         29.   SHAW is the brother-in-law of SUBJECTS MIKHAELYAN and

 TERZYAN.

                                      13
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 16 of 49 Page ID #:16



       30.    SHAW has fraudulently claimed that he is the victim

 of identity theft by lying about his income and employment to

 obtain credit, failing to pay such debt, and then years later

 claiming the debts were not his.          I reviewed documents provided

 by BMW Financial Services (“BMW”), and spoke with Homeland

 Security Investigations analyst Michael Reid, and learned the

 following:

              a.   In 2014, SHAW financed the purchase of a new BMW,

 in connection with which he provided his true Social Security

 number and listed his true residence address (the same address

 that, as more fully discussed below, he provided in connection

 with several fraudulent loan applications).           He claimed an

 annual salary of $876,000 as an employee of “Nairi Restaurant”

 (a business for which, as more fully discussed below, SHAW’s

 brother-in-law, MIKAELYAN, and another SUBJECT, YEMENEJIAN,

 fraudulently obtained an RRF and by which SHAW was never

 employed).    I know from other documents in this case, also more

 fully discussed below, that SHAW during that same time period

 (2012 to 2020) fraudulently claimed that he was an “IT

 Specialist.”

              b.   SHAW paid loan installments on the BMW loan for

 approximately five years from a bank account that he controlled.

              c.   In 2018, SHAW submitted a report under penalty of

 perjury to the Federal Trade Commission that he was the victim

 of identity theft with respect to the BMW loan and other debts.

              d.   SHAW then sent a letter to Equifax (a credit

 reporting agency) in which he claimed that he was the victim of


                                      14
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 identity theft relating to credit accounts (e.g., Macy’s and

 Bloomingdale’s).     Attached to SHAW’s letter to Equifax was what

 appeared to be a Long Beach Police Department (“LBPD”) report

 that indicated that SHAW had reported his identity theft to

 LBPD.    The report indicated that SHAW provided to LBPD the same

 purportedly misused credit accounts, including BMW (an account

 on which SHAW had paid installments for several years before

 claiming that his identity was stolen).

               e.   HSI Analyst Reid told me that he provided LBPD a

 copy of the purported LBPD report that SHAW had sent to Equifax.

 An LBPD employee responded that the purported report that SHAW

 had sent to Equifax was fake as the LBPD number on the purported

 report did not match the genuine report number in LBPD’s files

 and that the purported report appeared to have been altered.

               2.   Offense Conduct re “Prime” PPPL

         31.   Prime Funding, Inc. (“Prime”) was incorporated in

 2018 and, in January 2021, its business address was updated in

 California corporation records to 7011 Liberty Drive, Van Nuys,

 CA (the “Liberty Address”), an address that I know from SHAW’s

 driver’s license and other sources to be SHAW’s personal

 residence at all times relevant to this affidavit.

         32.   Three months later, in April 2021, an application was

 submitted online for a PPPL on behalf of Prime.            The application

 identified SHAW as Prime’s authorized representative and

 contained SHAW’s driver’s license, Social Security number, and

 the Liberty Address.     The stated reason for the PPPL was to

 cover Prime’s payroll costs for 57 employees at an average

                                      15
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 monthly payroll of $314,583.         The applicant submitted what

 appeared to be genuine Internal Revenue Service (“IRS”) Forms

 941 (quarterly payroll tax returns) that identified the Liberty

 Address as Prime’s business address.

       33.    I reviewed a response from the IRS pursuant to a law

 enforcement “Fact of Filing” request that is commonly used in

 these investigations to determine if IRS-related documents were

 actually filed with the IRS.         I learned that none of the Forms

 941 submitted on behalf of Prime in connection with the PPPL was

 actually filed with the IRS.

       34.    I also know from my training and experience that the

 California Employment Development Department (“EDD”) maintains

 records of wages paid to employees.         I reviewed EDD records for

 Prime and learned that Prime had never reported the payment of

 any wages.

       35.    The applicant for the Prime PPPL also provided as

 part of the PPP underwriting process what purported to be

 payroll reports prepared by a third-party payroll processor

 called “Paylocity,” an entity that I know to be similar to

 payroll processor ADP.     The reports listed 56 names of

 individuals who were purportedly employed by Prime with titles

 like “customer service,” “sales,” or “admin.”            I received

 information from Paylocity that Paylocity never did any payroll

 work for Prime and that the reports were fake.            Below is an

 image of one such report, showing gross wages of $1,539,526,

 that was submitted by the applicant for the Prime PPP:




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       36.     The applicant for the Prime PPPL designated a
 JPMorgan Chase Bank (“JPMC”) account ending in 6026 (the “JPMC

 6026”) to receive the proceeds of Prime’s PPPL.            I know that

 PPPL, EIDL, and RRF applicants were required to designate a bank

 account to which funds would be wire-transferred to the

 applicant.

       37.     An individual identifying himself as SHAW

 electronically, via the DocuSign authentication platform,

 acknowledged and then electronically transmitted to the lender,

 JPMorgan Chase, a standard form PPPL certification that stated,

 among other things, that PPPL proceeds would solely be used by

 Prime to retain employees and for certain of its business

 expenses.

       38.     Prime’s PPPL was approved and funded by JPMorgan

 Chase in April 2021, for $786,457, with a wire transfer in that

 amount.     I reviewed bank records for JPMC 6026 that showed the

 wire-transfer deposit of the Prime PPPL proceeds, and learned

 the following:




                                      17
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 20 of 49 Page ID #:20



            a.     The balance in the JPMC 6026 was $173 before the

 PPP proceeds were deposited.

            b.     SHAW was the sole signatory on the 6026 Account.

 The signature card/account application identified SHAW by his

 true name, Social Security number, and date of birth.             His

 signature matched that of his driver’ license.

            c.     Within six weeks of the deposit, substantially

 all of the Prime PPPL proceeds were withdrawn or transferred out

 of the account.

            d.     SHAW made more than $50,000 in cash withdrawals

 from the JPMC 6026 following the PPPL proceeds deposit,

 including four such withdrawals just under $10,000.             Based on my

 training and experience, I believe that those transactions

 indicated that transactions were structured to ensure that the

 bank did not submit Currency Transaction Reports to the U.S.

 Treasury Department. 1

            e.     There were no payments to any payroll company for

 Prime, nor were there any checks or transfers to any of the

       1  The following legal authority was provided by the AUSA:
      Federal law requires banks and other financial institutions
 to file reports with the Secretary of the Treasury whenever they
 are involved in a cash transaction or exchange of currency that
 exceeds $10,000. “A person who willfully violates this law is
 subject to criminal penalties.” 31 U.S.C. §§ 5313, 5324; 31 CFR
 § 103.22(a),(b)(2006 Ed.); Ratzlaf v. United States, 510 U.S.
 135, 136 (1994); see also, United States v. Turner, 400 F.3d
 491, 497 (7th Cir. 2005)(in case charging conspiracy to launder
 money, “we know that certain types of transactions may be
 indicative of a design to conceal. These include transactions
 surrounded in unusual secrecy, structured transactions,
 depositing ill-gotten funds into another’s bank accounts, using
 third parties to conceal the real owner, or engaging in unusual
 financial moves which culminate in a transaction.”).


                                      18
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 21 of 49 Page ID #:21



 names of purported Prime employees listed on the “Paylocity”

 reports.

              f.   Out of PPPL proceeds, SHAW wrote a $49,569 check

 (the signature on the check matches that of SHAW’s driver’s

 license) to “Humboldt Wholesale, Inc.,” which, on further

 investigation, appeared to be a supplier of items to cultivate

 marijuana.    See, e.g., https://www.dnb.com/business-

 directory/company-

 profiles.humboldt_wholesale_inc.cd260285658c4f8a89458e6c479d928e

 .html.

              g.   Out of the Prime PPPL proceeds in the JPMC 6026,

 SHAW also made large online payments to individuals whom I

 identified as friends or neighbors of SHAW’s father and who were

 not identified on either the fake Paylocity or EDD records as

 associated with or employed by Prime:

              April 29, 2021 – June 8, 2021 - $90,000.00          to E.T.

              May 24, 2021 – June 9, 2021 - $17,468.00         to T.T.

              May 24, 2021 – June 9, 2021 - $17,532.00         to A.T.

              3.   Wire Fraud re Prime’s PPPL Forgiveness
                   Application

       39.     In June 2022, an application was submitted online to

 forgive Prime’s PPPL.     “Sarkis G. Sarkisyan” (whose name matches

 that on SHAW’s previous driver’s license, depicted above) was

 identified as the “primary contact” on the forgiveness

 application and the Liberty Address was provided as Prime’s

 “business address.”     The forgiveness application was

 electronically signed by “Sarkis Sarkisyan” as Prime’s


                                      19
Case 2:25-cr-00456-MWC   Document 1    Filed 05/23/25   Page 22 of 49 Page ID #:22



 “authorized representative.”         Based on this evidence and the

 evidence that shows that SHAW controlled and misused the Prime

 PPPL proceeds, described above, I have probable cause to believe

 that SHAW submitted this forgiveness application and will refer

 to that application as such.

       40.    SHAW was required to certify that the Prime PPPL

 proceeds were “used to pay business costs that are eligible for

 forgiveness,” such as payroll costs to retain employees.               SHAW

 stated that Prime’s payroll costs were $1,539,526.58, an amount

 that matched that of the payroll costs on the phony Paylocity

 payroll report submitted to support the PPPL, as described

 above.

       41.   Again, in reviewing bank records showing the wire

 transfer of the Prime PPPL proceeds to the JPMC 6026, I did not

 see any withdrawals or transfers that appeared to be for Prime’s

 payroll.

       F.    SUBJECT MIKHAELYAN: Wire Fraud, Bank Fraud, and Money
             Laundering re “Cornwall” PPPL

       42.   On May 20, 2020, an application for a PPPL was

 submitted on behalf of the “Cornwall Group, Inc.” (“Cornwall”).

       43.   Public records show that MIKAELYAN was Cornwall’s

 sole officer and director, and at various times in public

 records its stated business was “management” or “water

 restoration.”

       44.   Contrary to the above-described public records,

 Cornwall’s PPPL application stated that Cornwall was a




                                       20
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 23 of 49 Page ID #:23



 “miscellaneous store retailer,” had 81 employees, and had an

 average monthly payroll of $357,541.

       45.   The applicant also submitted various documents in

 support of the application, including, similar to SHAW’s PPPL

 application for Prime, an IRS Form 941.          Here, that form

 reported that Cornwall had paid wages in the first quarter of

 2020 in excess of $1 million.

       46.   I submitted an IRS Fact of Filing request for

 Cornwall and from that response confirmed that no such form was

 actually submitted to the IRS.

       47.   The applicant also submitted a payroll report

 purportedly from Paylocity, the same payroll company whose

 payroll report SHAW had fabricated.        The report listed purported

 Cornwall employees and their wages.        I learned from EDD that EDD

 has no record of the purported employees and from Paylocity that

 it had no records for Cornwall.

       48.   An individual identifying himself as MIKHAELYAN

 electronically, via the DocuSign authentication platform,

 acknowledged and then electronically transmitted to the lender,

 Bank of America, a standard form PPPL certification that stated,

 among other things, that PPPL proceeds would solely be used by

 Cornwall to retain employees and for certain of its business

 expenses.

       49.   Bank of America approved the Cornwall PPPL

 application and funded the loan of $893,852 in May 2020.              I

 reviewed records from Bank of America for a Bank of America




                                      21
Case 2:25-cr-00456-MWC   Document 1    Filed 05/23/25   Page 24 of 49 Page ID #:24



 account ending in 7587 (the “BofA 7587”) into which the Cornwall

 PPP proceeds were deposited.         I learned the following:

               a.   An individual identifying himself as MIKHAELYAN

 opened the BofA 7587 in 2017.        The signature card/account

 application identified MIKHAELYAN by his true date of birth and

 genuine Social Security and driver’s license numbers.

               b.   MIKHAELYAN was the sole signatory on the BofA

 7587.    The signature on the signature card matches that of

 MIKHAELYAN on his genuine driver’s license.
               c.   The balance just before the deposit of the

 Cornwall PPP loan proceeds was de minimus.

               d.   Substantially all of the Cornwall PPPL proceeds

 were withdrawn in the form of checks within about a week of the

 proceeds’ deposit, including a $40,000 check to the Los Angeles

 Rams.    The signatures on that check (and each check) matched

 that of MIKHAELYAN’s driver’s license:




         50.   In August 2021, an application was submitted for

 forgiveness of the entire Cornwall PPPL.           The application

 electronically certified, in a manner similar to the initial

 PPPL certification, that Cornwall had 82 employees at the time




                                       22
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 25 of 49 Page ID #:25



 of the forgiveness application and that the PPPL proceeds were

 used for Cornwall’s business expenses including 60% for payroll.

       51.   I also saw a check within the BofA 7587 records, that

 I believe bore MIKHAELYAN’s genuine signature, for $479,000.

 The check bore the notation “PPP payroll” (the “PPP Payroll

 Check”):




       52.   The balance in the BofA 7587 at the time of the PPP

 Payroll Check consisted substantially of unspent Cornwall PPPL

 loan proceeds.    I traced the deposit of the PPP Payroll Check to

 a different Cornwall account, at HSBC bank (the “HSBC Account”).

 I reviewed records of that account and learned that the HSBC

 Account was opened three months before the date that the

 Cornwall PPPL application was submitted.          The signature

 card/account application identified the sole signatory as

 MIKHAELYAN, by his true personal identifying information.              I

 also learned from reviewing bank statements for the HSBC Account

 that there were no checks or withdrawals to any person named as

 a Cornwall employee on the Paylocity report, nor were there any

 payments to Paylocity or other transfers consistent with paying

 wages or compensation to others at least for the operation of a




                                      23
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 26 of 49 Page ID #:26



 “miscellaneous store retailer” as MIKHAELYAN had represented on

 the Cornwall PPPL application.

       G.    SUBJECT MIKHAELYAN: Wire Fraud and False Claim re
             Cornwall EIDL

       53.   On July 14, 2020, an EIDL application was submitted

 to SBA for a $150,000 EIDL on behalf of Cornwall.            The standard

 form application identified MIKHAELYAN as the contact person,

 giving his correct address, and stating that Cornwall had 2019

 calendar year revenue of $478,000 (nearly the same number as the

 PPP Payroll Check that MIKHAELYAN had signed a few weeks

 earlier); had two employees (compared to 82 as MIKHAELYAN had

 stated on the Cornwall PPP application only two months earlier);

 and had zero revenue for 2020 (compared to over $1 million as

 stated on the Form 941 for the first quarter of 2020 that

 MIKHAELYAN had submitted in support of the Cornwall PPPL

 application).

       54.   A person who identified himself as MIKAELYAN signed

 the standard form Loan Authorization and Agreement (“LA&A”) via

 the DocuSign online authentication platform in which he

 represented that Cornwall would, in pertinent part, “use all the

 proceeds of this [l]oan solely as working capital to alleviate

 economic injury caused by disaster occurring in the month of

 January 31, 2020[.]”

       55.   On the basis of the applicant’s representations,

 above, the EIDL was approved and its proceeds ($149,900, net of

 fees) wire-transferred to the HSBC Account.           MIKHAELYAN promptly

 signed checks to spend-down substantially all of those proceeds,



                                      24
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 27 of 49 Page ID #:27



 including checks to MIKHAELYAN’s sister, SUBJECT MARIANNA

 SARKISYAN and to others not identified on the Paylocity report

 as “employees” of Cornwall.

       H.    SUBJECTS MIKHAELYAN and YEMENEJIAN: Wire Fraud, False
             Claim, and Money Laundering re “Nairi” RRF

       56.     In May 2021, an application for an RRF for a

 restaurant called “Nairi Meat & Deli” in Hollywood, CA (“Nairi”

 and the “Nairi RRF”) was submitted to the SBA.           The email

 contact on the application was “mikaelyanmike@gmail.com.”

       57.     RRFs were offered to support the restaurant industry

 by providing funding to offset significant pandemic-related

 revenue loss.    RRFs had specific requirements to ensure

 equitable distribution to small business concerns owned by

 women, veterans, and socially and economically disadvantaged

 applicants.

       58.     The Nairi RRF application identified L.D., a woman,

 as the president and 100 percent owner.          I interviewed L.D.      She

 told me that she did not own Nairi at the time of the RRF

 application and that she gave up ownership to MIKHAELYAN and her

 ex-husband, YEMENEJIAN, in the early 2000’s.           L.D. also stated

 that she could not recall whether she or MIKHAELYAN submitted

 the Nairi RRF application, but in any event that she gave

 MIKHAELYAN permission to do so.       MIKHAELYAN was previously

 identified as Nairi’s sole owner on an EIDL application.

       59.     In further support of the Nairi RRF, the applicant

 submitted a 2019 federal income tax return for Nairi that,

 according to IRS transcripts that I reviewed, was filed



                                      25
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25    Page 28 of 49 Page ID #:28



 approximately two weeks before the RRF application was

 submitted, thus indicating that the return was untimely (i.e.,

 it should have been filed in 2020) and prepared to facilitate

 the Nairi RRF as opposed to reporting financial activity to

 comply with tax laws.

       60.    The SBA approved the Nairi RRF and in May 2021 wire-

 transferred the RRF grant proceeds of $1,905,824 to a JPMC

 account ending in 5870 (the “JPMC 5870”).             I reviewed records

 for the JPMC 5870 and learned the following:

             a.    L.D. was removed as a signatory before the RRF

 was sought, and MIKHAELYAN was replaced as the sole signatory.

             b.    Within about two weeks after the Nairi RRF

 proceeds were deposited into the JPMC 5870, YEMENEJIAN, who was

 not a signatory on the account, wrote 16 checks to MIKHAELYAN

 (and confirmed as such during an interview), each in the amount

 of $4,567.50, totaling $73,072. 2         I know from my training and

 experience that individuals frequently transact in amounts below

 $10,000 for fear of drawing suspicion for structuring.              The

 detail of those checks is as follows:

  Date of Check               Amount             Payee
  March 15, 2020              $9,135             Mikael Mikaelyan
  March 31, 2020              $9,135             Mikael Mikaelyan
  April 3, 2020               $4,567.50          Mikael Mikaelyan
  April 10, 2020              $4,567.50          Mikael Mikaelyan
  April 17, 2020              $4,567.50          Mikael Mikaelyan
  April 24, 2020              $4,567.50          Mikael Mikaelyan




       2The bank still honored the checks, even though signed by a
 non-signatory.
                                      26
Case 2:25-cr-00456-MWC   Document 1    Filed 05/23/25   Page 29 of 49 Page ID #:29



             c.    L.D.’s ex-husband, SUBJECT YEMENEJIAN, wrote

 numerous checks on the account, again even though he was not a

 signatory, including to “Express Restoration.”            I know from

 reviewing evidence in this case that “Express Restoration” was a

 purported corporation – likely just a shell – whose president

 was identified on public records as MIKHAELYAN.

             d.    YEMENEJIAN also wrote a $36,504 check to

 “Humboldt Wholesale,” the same entity that SHAW paid out of PPPL

 funds and that I believe from open sources to be a marijuana

 cultivation supply business.         I have found no information that

 Nairi was a marijuana dispensary in addition to being a

 restaurant.

             e.    L.D. also told me that she was remodeling her

 residence during the time that the Nairi RRF proceeds were

 received and that a check signed by YEMENEJIAN out of those

 proceeds, to Bank of America for $104,044, was to pay off a

 secured loan that she had obtained for home improvements that

 had nothing to do with Nairi’s operation.

             f.    All told, YEMENEJIAN signed over 150 checks

 totaling more than $1.2 million out of the RRF proceeds to a

 variety of payees, some of which appeared to be shells or, at

 least, not restaurant suppliers or Nairi employees according to

 EDD records and the absence of related IRS records.

       61.     The SBA required that all RRF recipients submit

 annually a “post award report” in which the RRF recipient’s

 representative was required to certify that the RRF funds had

 been used as required, i.e., for restaurant-related expenses.


                                       27
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 30 of 49 Page ID #:30



       62.   I reviewed a post-award report for Nairi that was

 submitted via email from the same email account that identified

 on the Nairi RRF application: “mikhaelyanmike@gmail.com.”              The

 report certified that all RRF proceeds were used for permissible

 business-related expenses.      The post-award report did not

 mention or separately itemize the $73,072 payments to

 MIKHAELYAN, the $104,044 payment to pay off L.D.’s loan from

 Bank of America, or the $36,504 payment to the marijuana

 cultivation supply business.

       63.   In June 2024, during this investigation and shortly

 after I first spoke to L.D., MIKHAELYAN called me.            He told me

 that he owned Nairi and that he wanted to participate in an

 interview that I had scheduled with L.D.          I told MIKHAELYAN that

 he could not participate in the interview of L.D. but that I

 would separately interview him.       He stated that he should be

 present during L.D.’s interview because they “were family.”              He

 then stated that he only “managed the operations” of Nairi and

 would not answer when I asked if he “owned” Nairi.            He repeated

 that he was “in charge” of operations and added that YEMENEJIAN

 was also involved in running Nairi.

       I.    MIKHAELYAN: Wire Fraud and False Claim re “Rest” EIDL
             Modification

       64.   In May 2020, an EIDL application for $150,000 was

 submitted online on behalf of Rest Assured Restoration (“Rest”).

 The EIDL application showed MIKHAELYAN’s true name, date of

 birth, and email address that matched that of the RRF

 application and related RRF documents.         The applicant stated



                                      28
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 31 of 49 Page ID #:31



 that Rest was in the “personal services” industry, had 18

 employees, and had gross revenues for calendar year 2019 of

 $754,000.

       65.   Per records that I obtained from EDD, Rest had no

 employees and no filings at all.

       66.   Per an IRS Fact of Filing request, the IRS had no

 records of payroll tax returns for Rest.

       67.   The Rest EIDL was approved and its proceeds were

 deposited into an account whose sole signatory was MIKHAELYAN.

       68.   In late 2021, the SBA received an application to

 modify the Rest EIDL by increasing the loan by $350,000.              The

 Rest EIDL file “notes” section (that I know contained summaries

 of communications between borrowers and SBA loan officers,

 including requests for additional financial information)

 reflected that MIKAELYAN was advised that he needed to provide

 genuine federal income tax returns for Rest for calendar years

 2019 and 2020 to justify the modification and to authorize the

 SBA to confirm that such returns were filed with the IRS.

       69.   I reviewed in the Rest EIDL file what appeared to be

 Rest calendar year 2019 and 2020 federal income tax returns

 signed by MIKHAELYAN and IRS transcripts that reflected the

 filing of such returns.     The transcripts showed that the returns

 had not been timely filed but, instead, were filed together in

 December 2021, just before the Rest EIDL modification request

 was made.   The transcripts reflected that Rest had gross income

 for each year of more than $1 million and that Rest owed tens of




                                      29
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 32 of 49 Page ID #:32



 thousands of dollars in income taxes.         No taxes were actually

 paid. 3

       70.    The SBA ultimately denied the Rest EIDL modification

 request by concluding that Rest had filed its income tax returns

 solely to qualify for the EIDL modification rather than to

 reflect genuine financial activity.

       J.    SUBJECT YEMENEJIAN: Wire Fraud and False Claim re
             “Tiny Tots” EIDL

       71.    In August 2020, an application was submitted online

 for an EIDL for Tiny Tots Childcare, Inc. (“Tiny Tots”) for

 $150,000.    The applicant described Tiny Tots as providing

 “educational services” and “daycare” since its “start date” of

 January 1, 2019.

       72.    An individual identified as YEMENEJIAN electronically

 signed an EIDL LA&A for the Tiny Tots EIDL on August 7, 2020, in

 which the applicant promised to “use all the proceeds of this

 Loan solely as working capital to alleviate economic injury

 caused by disaster occurring in the month of January 31,

 2020[.]”    Thus, by the terms of the LA&A, TTCI had to be in

 existence “in the month of January [], 2020.”

       73.    The Tiny Tots EIDL was funded and, based on my review

 of SBA records relating to this EIDL, its proceeds were wire-




       3  As more fully described in the concurrently submitted
 request for issuance of arrest and search warrants for SUBJECT
 MCGRAYAN, et al., I have probable cause to believe that SUBJECTS
 submitted fraudulent tax returns to obtain loans in a somewhat
 creative manner where the returns fraudulently reported
 substantial income and tax due in order to create the appearance
 of legitimacy. No tax was ever paid.
                                      30
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 33 of 49 Page ID #:33



 transferred into California Credit Union Account ending in 8996

 (the “CCU 8996”).

       74.    I reviewed records for the CCU 8996 and learned the

 following:

              a.   The signature card/account application identified

 YEMENEJIAN as Tiny Tot’s authorized representative and provided

 his true name, date of birth, and driver’s license number.              The

 account was opened with $200 on August 5, 2020, or one day

 before the Tiny Tots EIDL application was submitted to the SBA.

              b.   YEMENEJIAN was identified on the signature

 card/account application as the CEO and 100% owner of Tiny Tots.

 I recognized the signature on the signature card/account

 application as matching that of YEMENEJIAN’s driver’s license, a

 copy of which was also included in the CCU records.

              c.   CCU records also contained a “Statement of

 Information” (“SOI”) for “Tiny Tots Childcare, Inc.,” filed with

 the California Secretary of State on July 31, 2020, or five days

 before the CCU 8996 was opened.       The SOI, which I confirmed had,

 in fact, been publicly filed, identified YEMENEJIAN as the sole

 officer and director of Tiny Tots at the same address for Tiny

 Tots that YEMENEJIAN had given when he opened the CCU 8996.

              d.   CCU 8996 records show that the Tiny Tots EIDL

 proceeds of $149,900 (net of fees) were deposited into that

 account on August 10, 2020.      The prior balance was $200, an

 amount credited to the account when it was opened days earlier.

 There was no other deposit activity.




                                      31
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 34 of 49 Page ID #:34



             e.   As more fully described below, none of the EIDL

 proceeds was used “solely as working capital to alleviate

 economic injury caused by disaster occurring in the month of

 January 31, 2020” because, as described below, Tiny Tots never

 opened.

       75.   An application for an EIDL modification for Tiny Tots

 was later sought to obtain another $349,900.           In connection with

 that application, as required and requested by SBA to underwrite

 the EIDL, the applicant provided a 2019 federal income tax

 return for Tiny Tots that indicated it had been prepared by C.H.

 I interviewed C.H., who told me the following:

             a.   He is a tax preparer.

             b.   He prepared the Tiny Tots return that I saw in

 the SBA’s Tiny Tots EIDL modification file.

             c.   YEMENEJIAN came to C.H.’s office and presented a

 small piece of paper with line items for purported business

 income and expenses for Tiny Tots.        YEMENEJIAN directed C.H. to

 prepare Tiny Tots’s 2019 federal income tax return using that

 information.

             d.   YEMENEJIAN did not provide any other information

 to C.H. for the preparation of the return.

             e.   C.H.’s practice was to prepare returns for

 clients based on information provided by clients.            C.H. did not

 personally verify or audit any such information.            C.H. would

 simply instruct clients, including by providing cover letters

 for returns, that the returns that he prepared for clients based




                                      32
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 35 of 49 Page ID #:35



 on client’s information were simply, in essence, as reliable and

 accurate as that information.

              f.   YEMENEJIAN signed Tiny Tots’s 2019 federal income

 tax return in C.H.’s presence.

        76.   I reviewed that return and learned that, among other

 things, YEMENEJIAN reported that Tiny Tots had gross revenue

 from operations for calendar year 2019 of $356,640.             Based on my

 training and experience, and review of the totality of the

 evidence gathered in this investigation, I have probable cause

 to believe that YEMENEJIAN submitted made up numbers to C.H.

 with the intent that C.H. prepare a false income tax return to

 fraudulently facilitate obtaining this EIDL.

        77.   I served a grand jury subpoena on YEMENEJIAN as Tiny

 Tots’s custodian of records and agent for service of process.

 Through counsel, YEMENEJIAN produced a building lease in

 response to the subpoena’s request for that and other records.

 I reviewed the lease and learned the following that the lease

 was executed on August 30, 2018.          The lessor was identified as

 S.B.

        78.   I interviewed S.B. and learned the following:

              a.   S.B. told me that he was the lessor for the

 subject property and that he met YEMENEJIAN to negotiate the

 lease on behalf of Tiny Tots.

              b.   S.B. stated that the lease with Tiny Tots never

 took effect because the City of Los Angeles refused to issue

 Tiny Tots a permit to operate.




                                      33
Case 2:25-cr-00456-MWC   Document 1    Filed 05/23/25   Page 36 of 49 Page ID #:36



             c.    S.B. gave me a copy of the lease from his

 (S.B.’s) files.    The lease was similar to the copy that

 YEMENEJIAN had produced pursuant to the grand jury subpoena.

 However, S.B. also produced an “amendment” to the lease that

 YEMENEJIAN had not produced.         The “amendment” was dated June

 2019 and signed by S.B. and by YEMENEJIAN (his signature plainly

 matched that of known exemplars).          The “amendment” stated that

 it related to the lease “between [S.B.’s business] and Sarkis

 Yemenejian dated August 30, 2018,” and that “lessee and lessor

 her[e]by agree to cancel such lease[.]”           The “amendment” also

 stated that YEMENEJIAN’s previously paid security deposit of

 $30,472 was to be repaid, at YEMENEJIAN’s direction, to L.D.

 (YEMENJIAN’s ex-wife).

       79.   I reviewed the CCU 8996 records and confirmed that

 YEMENEJIAN had written S.B.’s company a deposit check of $30,472

 out of proceeds of the Tiny Tots EIDL.

       80.   Based on my review of the TTCI EIDL records provided

 by SBA, I learned that YEMENEJIAN paid nothing toward repayment

 of the Tiny Tots EIDL and concealed from the SBA that Tiny Tots

 never operated.

       K.    SUBJECT TERZYAN: Wire Fraud, False Claim, and Money
             Laundering re “Grub House” EIDL and EIDL Modification

       81.   In January 2021, an application was submitted to SBA

 for a $150,000 EIDL on behalf of “Grub House, Inc.” (“Grub

 House” or the “Grub House EIDL”).          TERZYAN 4 was identified on the


       4 In 2016, TERZYAN was convicted in this district of
 conspiracy to possess 15 or more unauthorized access devices, in
                                    (footnote cont’d on next page)

                                       34
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 37 of 49 Page ID #:37



 Grub House EIDL application by his true name, Social Security

 number, and driver’s license number.

       82.    The application claimed that Grub House’s revenue for

 the 12 months preceding January 31, 2020, was $433,441.

       83.    In March 2021, an individual identified as “Arsen

 Terzyan owner/officer” e-signed the standard form EIDL “Loan

 Authorization and Agreement” (“LA&A”) on behalf of Grub House.

 Like that of substantially all other EIDL LA&As, the signer

 promised that “[b]orrower will use all the proceeds of this Loan

 solely as working capital to alleviate economic injury caused by

 disaster occurring in the month of January 31, 2020 and

 continuing thereafter[.]”

       84.     The Grub House EIDL application also identified a

 JPMC account ending in 3502 (the “JPMC 3502”) as the bank

 account into which EIDL proceeds should be wire-transferred.

       85.    On April 2, 2021, the Grub House EIDL proceeds of

 $149,900 (net of fees) were wire transferred from the SBA to the

 JPMC 3502.    I reviewed records for the JPMC 3502 and learned the

 following:

              a.   The account was opened in October 2019.

              b.   The signature card/account application showed

 that an individual identified as TERZYAN opened the account by

 providing his true name and genuine Social Security and driver’s

 license numbers.    The signature on the signature card/account

 application matched that of TERZYAN’s driver’s license.


 violation of 18 U.S.C. section 1029(b)(2) and sentenced to three
 years in prison. United States v. Nazar Daniyelyan, et al., CR
 15-621-GW.
                                      35
Case 2:25-cr-00456-MWC      Document 1    Filed 05/23/25   Page 38 of 49 Page ID #:38



              c.      The balance in the account before the deposit of

 the Grub House EIDL proceeds was $1,361.

       86.      Substantially all of the Grub House EIDL proceeds

 were spent in 30 days as the balance in the JPMC 3502 at the end

 of the statement period for the deposit (approximately April

 2021) was $524.

       87.      I traced the use of the Grub House EIDL proceeds.              I

 saw 17 checks totaling $102,070, each bearing a signature of

 TERZYAN that matched that of his driver’s license, in amounts

 consistent with structuring.            None appeared consistent with use

 as working capital to alleviate damage caused by the Covid-19

 pandemic, and at least one such payment was to TERZYAN’s sister-

 in-law, SUBJECT MARIANNA:



  Date Range                     Amount             Payee
  April 2, 2021                  $8,500.00          Terzyan Personal Account
  April 2, 2021                  $9,892.00          Terzyan Personal Account
  April 1 – April 3, 2021        $50,000            No Limit Cargo
  April 6 – April 9, 2021        $17,700.00         A        Gi
  April 7, 2021                  $9,150.00          Home Energy Rating
  April 7, 2021                  $9,150.00          Hers Raters
  April 14, 2021                 $14,000.00         Marianna Sarkisyan


       88.      In April 2021, an application was made for a

 modification to the Grub House EIDL to increase the total EIDL

 to $500,000.

       89.      I know from my training and experience that the SBA

 at that time commonly required that applicants submit tax

 returns and/or provide the SBA with permission (via an IRS Form




                                          36
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 39 of 49 Page ID #:39



 4506-T) to obtain directly from the IRS transcripts for the

 applicant as well as the applicant’s tax returns.

       90.     The Grub House EIDL file contained an IRS Form 4506-T

 bearing the electronic signature of TERZYAN.

       91.     I reviewed the transcripts that the SBA obtained for

 federal income tax returns for the calendar years 2018 and 2019.

 The transcripts showed that Grub House’s income tax returns for

 those years were untimely, submitted on the same day in February

 2021, and prepared by the same tax preparer, L.F., whom I know

 from the evidence in this case was identified as the tax

 preparer for several other targets including SHAW and

 MIKHAELYAN.

       92.     The chronological activity section on the EIDL

 application (“note” section) indicated that the SBA declined the

 EIDL modification because Grub House’s tax returns were obtained

 to qualify for the EIDL modification as opposed to submitted to

 report genuine financial activity.

       L.    SUBJECT TERZYAN: Wire Fraud, False Claim, and Money
             Laundering re “Grub House” RRF

       93.     In May 2021, an application was submitted to the SBA

 for an RRF on behalf of Grub House, Inc. (“Grub House” and the

 “Grub House RRF”).      The “100%” owner was identified as TERZYAN,

 and provided his residence address at 16719 Lahey St., Granada

 Hills, CA, as Grub House’s business address.

       94.     I recently listened to a recording between a creditor

 and TERZYAN that was made as part of that creditor’s

 underwriting for a loan to TERZYAN.        During that recording,



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Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 40 of 49 Page ID #:40



 TERZYAN identified himself by providing the last four digits of

 his (true) Social Security number that matched that on the Grub

 House RRF application and the EIDLs described above.             He also

 gave as his residence address and phone number the same

 residence address and phone number shown on the Grub House RRF

 application.    I therefore believe that TERZYAN made the

 representations on and submitted the Grub House RRF application

 and will refer to that application as such.

       95.   TERZYAN claimed on the Grub House RRF that Grub

 House’s 2019 calendar year gross receipts were $1,423,441 and

 that he expected to report $463,792 for gross receipts for Grub

 House for 2020.

       96.   On the January 2021 EIDL application for Grub House

 that TERZYAN submitted, as described above, TERZYAN claimed that

 Grub House’s “Actual 2019 gross revenue” was exactly one million

 dollars less than the amount now claimed on the Grub House RRF

 application, or $423,441.

       97.   On the Grub House RRF application, TERZYAN identified

 the JPMC 3502 as the business bank account into which proceeds

 of the RRF should be wire-transferred (the same account into

 which the Grub House EIDL proceeds were transferred).

       98.   TERZYAN represented on the Grub House RRF application

 that RRF proceeds would be used solely for Grub House’s business

 expenses such as payroll costs, rent, utilities, food and

 beverage purchases, construction of outdoor seating, supplies,

 and other operating expenses.




                                      38
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 41 of 49 Page ID #:41



       99.    TERZYAN further represented on that same application

 that Grub House was at least 51 percent owned and controlled by

 “[a] socially and economically disadvantaged individual[].”

       100.    On May 28, 2021, having approved the Grub House RRF

 application, the SBA wire-transferred proceeds of $1,864,830 to

 the JPMC 3502.

       101.    I reviewed records for the JPMC 3502 and learned the

 following:

              a.   As stated above, I believe that TERZYAN opened

 and controlled that account.

              b.   The balance in the account was $524 before the

 RRF proceeds were credited on May 28, 2021.           As described above,

 substantially all of the deposits to the account from April 2,

 2021, to the date of deposit of the RRF proceeds came from the

 Grub House EIDL proceeds.

              c.   Substantially all of the Grub House RRF proceeds

 were paid out within about three months of the deposit of the

 RRF proceeds.     Below is a chart that shows the date ranges,

 amounts, and payees for the first six weeks of activity in the

 JPMC 3502 following the RRF proceeds deposit, totaling

 approximately $1.2 million:




                                      39
Case 2:25-cr-00456-MWC        Document 1   Filed 05/23/25   Page 42 of 49 Page ID #:42




  Date Range                          Amount(s)      Payee
  June 4 – August 6, 2021             $286,084.00    Humboldt Wholesale (Hydroponics)
  June 8 – June 9, 2021               $219,804.79    Hawthorn Hydroponics
  May 28 – December 31, 2021          $160,000.00    Arsen Terzyan’s Personal Account
  July 13, 2021                       $40,000.00     Ikon Development (Koko Polosajian)
  July 13, 2021                       $60,000.00     Standard Home Lending (K
                                                     P         )
  July 21, 2021                       $50,000.00     M        L    J
  July 22 – August 11, 2021           $50,000.00     Pre-Packaging and Moving Service
  July 13, 2021                       $50,000.00     Aykem, LLC
  August 4, 2021                      $50,000.00     Woodland Shane Matthew
  June 21 – July 19, 2021             $14,000.00     Maria Sarkisyan
  July 16, 2021                       $13,671.31     Macy’s
  July 15, 2021                       $3,145.00      Express Restoration (Mikael Mikaelyan)


              d.     The first two line items refer to payments to

 what I believe were marijuana cultivation supply businesses, one

 of which (Humboldt Wholesale) was the same such business to

 which SUBJECT SHAW paid out of PPPL proceeds as described above.

 SUBJECT MARIANNA received $14,000.

       102.      RRF recipients were required to certify that RRF

 proceeds were used in compliance with RRF rules.                  Such

 compliance was required via a “post-award report.”

       103.      Acknowledging on the post-award report that “[a]ny
 false statement or misrepresentation to SBA may result in
 criminal, civil or administrative sanctions including, but not
 limited to: 1) fines and imprisonment[,]” an individual
 identified as TERZYAN electronically signed and submitted that
 report in December 2021 and represented that all of the Grub
 House RRF proceeds were used for Grub House business expenses,
 as follows:




                                           40
Case 2:25-cr-00456-MWC     Document 1     Filed 05/23/25      Page 43 of 49 Page ID #:43




  Amount                      Eligible Categories
  $ 317,204.00                Payroll (including paid sick leave)
  $ 94,563.00                 Rent / Mortgage
  $ 31,202.00                 Utilities
  $ 87,750.00                 Debt Service
  $ 45,673.00                 Construction of Outdoor Seating
  $ 16,185.00                 Maintenance
  $ 16,831.00                 Supplies
  $ 928,686.00                Food and Beverage (including raw materials)
  $ 48,874.00                 Covered Supplier Costs
  $ 277,862.04                Business Operating Expenses
  $ 1,864,830.04              TOTAL


       104.        EDD records show that Grub House’s payroll

 commenced during the third quarter of 2019 and that it

 maintained five employees through the first quarter of 2020.

 Grub House maintained one employee from Q2 2020 to Q4 2020.

 There was no EDD record of payroll during calendar year 2021.

 Grub House’s EDD account ceased on March 31, 2022.

       105.        Based on my review of the JPMC 3502, I have probable

 cause to believe that TERZIAN at least fraudulently misused and

 misrepresented on the RRF post-award report payments of $317,204

 as payroll expenses, if not in excess of $600,000 more to

 marijuana cultivation suppliers that he fraudulently

 mischaracterized as other purported business-related expenses.




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Case 2:25-cr-00456-MWC    Document 1   Filed 05/23/25   Page 44 of 49 Page ID #:44



       M.     SUBJECT MARIANNA: Wire Fraud, False Claim, and Money
              Laundering re “Rustwood” EIDL

       106.    On May 30, 2020, an EIDL was submitted on behalf of

 a shell called “Rustwood Enterprises, Inc.” (“Rustwood”) for

 $150,000.    MARIANNA was identified as the contact person by her

 true name, Social Security number, date of birth, and residence

 address (the same address as SHAW).         The application identified

 MARIANNA as the owner of Rustwood and stated that Rustwood had

 2019 calendar year gross revenue of $1.6 million and 14

 employees.    The application identified a California Credit Union

 (“CCU”) account ending in 7905 (the “CCU 7905”) as the account

 to which the EIDL proceeds should be wire-transferred/deposited.

       107.    EDD records and IRS Fact of Filing information

 showed that Rustwood did not have any employees for the period

 covered by the EIDL application.

       108.    On May 30, 2020, an individual identified as

 MARIANNA electronically signed the LA&A and, like that of

 substantially all other EIDL LA&As, the signer promised that

 “[b]orrower will use all the proceeds of this Loan solely as

 working capital to alleviate economic injury caused by disaster

 occurring in the month of January 31, 2020 and continuing

 thereafter[.]”

       109.    I reviewed the records for CCU 7905 and learned the

 following:

              a.     The signature card/account application was signed

 on April 1, 2020, or about two months before the Rustwood EIDL

 was sought.       It contained MARIANNA’s true name, Social Security



                                       42
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 45 of 49 Page ID #:45



 number, and driver’s license number, each of which matched that

 on the Rustwood EIDL application. 5       I compared the signature on

 the signature card with that of MARIANNA’s driver’s license and

 believe the signatures were written by one and the same person:

 MARIANNA.   The signature card stated that Rustwood was involved

 in “landscape design.”

             b.   There was minimal activity in the CCU 7905 for

 the months of April and May 2020, such as a transfer from

 another account in the name of MARIANNA for $500 to open the

 account and a withdrawal at a Walgreen’s store in Van Nuys

 (which I know was in the vicinity of MARIANNA’s residence).              For

 May 2020, there were approximately $300 in what appeared to be

 personal expenses (e.g., “Tigranakert Meat Marke[t]” in Van

 Nuys).

             c.   The EIDL proceeds of $149,900 (less $100 fees)

 were deposited on June 29, 2020, followed by the deposit of an

 EIDL advance of $10,000 on July 7, 2020.          (I know from my

 training and experience that the SBA commonly paid EIDL

 applicants an advance of $1,000 for every claimed employee, up

 to $10,000, to hold them over until EIDL proceeds were paid;

 this situation was slightly different as the advance was paid

 after the proceeds.)

             d.   There was no significant activity in the account

 until October, when approximately $100,000 – substantially, if


       5 The signature card contained MARIANNA’s prior residence
 address that MARIANNA verified in mid-2021 in connection with
 seeking an increase/modification of the Rustwood EIDL, as
 discussed below.
                                      43
Case 2:25-cr-00456-MWC     Document 1    Filed 05/23/25   Page 46 of 49 Page ID #:46



 not solely, EIDL proceeds – was withdrawn in the form of checks

 or electronic transfers.          Below is a summary of the payments

 that show use of the EIDL proceeds, none of which is consistent

 with the operation of a “landscape design” business or with

 payment of payroll:



  Date Range                        Amount(s)      Payees
  October 1 – October 3, 2020       $46,495.00     Express Restoration (Mikael Mikaelyan)
  October 6, 2020                   $18,500.00     M      K
  October 16 – December 16, 2020    $26,565.00     A         G
  October 19, 2020                  $17,860.00     Macy’s Online Payment
  November 4, 2020                  $15,122.00     Ranchito Investments
  November 25, 2020                 $3,190.00      Body Design Rejuvenation
  December 4, 2020                  $5,800.0       Cornwall Group (Mikael Mikaelyan)
  December 4 – January 6, 2021      $22,634.00     Toluca Commercial, Inc.
  December 5, 2020                  $15,000.00     American Mobile Power Solution
  December 11, 2020                 $7,000.00      Maria Sarkisyan
  December 17, 2020                 $17,901.60     First Bank
  January 4, 2021                   $49,200.00     Best Tudor


       110.     In April 2021, MARIANNA applied for a modification

 to increase the Rustwood EIDL to $500,000.               The SBA “note”

 summary for this application described a detailed conversation

 between an SBA representative and MARIANNA, the relevant parts

 of which are summarized as follows:

              a.    The representative (identified as the “LO” (loan

 officer)) stated that the LO “called and spoke w/Marianna

 Sarkisyan @ 818-747-5007.”         That was the same number that was

 provided on the Rustwood EIDL in 2020.

              b.    The LO “asked applicant PII questions to verify

 information from the initial EIDL, including “date business

 established, verified home & business address, verified business


                                         44
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 47 of 49 Page ID #:47



 entity—stated C corp-business Agriculture.”           I know from my

 training and experience that SBA loan officers commonly verified

 applicant’s personal identifying information from EIDL

 applications in connection with vetting modification requests.

              c.   The LO also verified MARIANNA’s identity by

 confirming that MARIANNA had received a bankruptcy discharge in

 August 2019 and previously lived at the same address that

 MARIANNA had provided when she opened the CCU 7906.

              d.   In response to the LO’s question about why the

 EIDL application stated $1.6 million in gross revenue for 2019

 “versus the 2019 [$570,338 in gross revenue] reported on [a tax

 transcript that was provided pursuant to a tax information

 release form signed by MARIANNA],” MARIANNA explained the more

 than $1 million discrepancy by stating that “she completed the

 [EIDL] application without her tax accountant.”

              e.   The LO explained that the variance was too great

 to approve the modification and that “applicant stated she

 understood.”

       N.     SUBJECT MARIANNA: Wire Fraud and False Claim re
              Personal EIDL

       111.     SBA records show that, on July 13, 2020, fewer than

 two months after MARIANNA applied for the Rustwood EIDL, an

 online application was submitted for a $150,000 EIDL for

 “Marianna Sarkisyan” as a “Sole-Proprietorship” (the “MARIANNA

 EIDL”).    The MARIANNA EIDL application contained not only

 MARIANNA’s true name but her true Social Security number and the

 same residence address she had provided when she applied for the



                                      45
Case 2:25-cr-00456-MWC   Document 1   Filed 05/23/25   Page 48 of 49 Page ID #:48



 Rustwood EIDL in May 2020.      The application claimed that

 MARIANNA was in the business of “property management/realty” and

 also stated that MARIANNA’s “gross revenues for the twelve

 months prior to [] January 31, 2020” was $357,000,” but

 mentioned nothing about her association with, or any income

 derived from, Rustwood.     The MARIANNA EIDL application

 identified a California Credit Union account ending in 0956 (the

 “CCU 0956”) to which EIDL proceeds should be wire-transferred.

       112.    The MARIANNA EIDL was approved and funded in the

 amount of $150,000 in August 2020.        In July 2021, an application

 was submitted online to modify the MARIANNA EIDL by increasing

 it to $500,000 (a net increase of $350,000).           An LA&A for this

 modification was e-signed by “Marianna Sarkisyan” on July 26,

 2021 and, similar to other EIDL requirements at that time, the

 applicant agreed that “[applicant] will use all the proceeds of

 this Loan solely as working capital to alleviate economic injury

 caused by disaster occurring in the month of January 31, 2020

 and continuing thereafter[.]”

       113.    I reviewed records of the CCU 0956 and learned the

 following:

              a.   The account was opened in 2013.        The signature

 card/account application identified the account holder as

 MARIANNA based on her true date of birth, Social Security

 number, and driver’s license number.         The signature on the card

 matches that of her driver’s license and the numerous checks on

 accounts associated with her that I have seen during this

 investigation.


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Case 2:25-cr-00456-MWC     Document 1   Filed 05/23/25   Page 49 of 49 Page ID #:49



              b.     The proceeds of the MARIANNA EIDL modification

 were deposited into the CCU 0956 on July 30, 2021.

              c.     The beginning balance in that account (as of July

 1, 2021) was $8,234.       For the several months preceding that

 date, the account appeared to be largely used for personal

 expenses (e.g., substantial Amazon and Postmates payments,

 recurrent $1,820 Chase Auto Lease payments).

              d.      The bulk of the EIDL proceeds were used for a

 variety of expenses not associated with “working capital” for a
 business including the same substantial Amazon payments,

 recurrent Chase Auto Lease payments, $8,298 in Aeroflot plane

 tickets, $55,000 to Rustwood, $15,000 to Pacific BMW, $4,862 to

 Louis Vuitton, $24,000 to Mercedes Benz of Beverly Hills, and

 $2,090 to Monolo Blahnik Intl London (high-end shoes).

                                V. CONCLUSION

       114.        For all the reasons described above, there is

 probable cause to believe that SARKIS SARKISYAN, AKA SAMUEL

 SHAW; MIKHAEL MIKHAELYAN; ARSEN TERZYAN, AKA STEVEN TERZAKI; and

 MARIANNA SARKISYAN committed the Subject Offenses.


 Attested to by the applicant in
 accordance with the requirements
 of Fed. R. Crim. P. 4.1
 by telephone on this BBBB
                       UG day of
 May, 2025.



 HONORABLE 3$75,&,$'21$+8(
 UNITED STATES MAGISTRATE JUDGE




                                        47


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