Court Filing, Doc. 1 — United States v. Pearson

Summary

A grand jury indictment filed 10/19/22 as Document 1 in Case 3:22-cr-00132-SA-RP in the Northern District of Mississippi charges Robert Pearson, Lakisha Pearson, Glendon Jones and eleven other defendants with conspiracy to commit wire fraud over Paycheck Protection Program loans. It alleges they obtained PPP proceeds by representing that their businesses were operating and employed workers when the businesses did not exist or were not doing business until after February 1, 2020 or February 15, 2020. Counts Two through Fourteen charge wire fraud and Counts Fifteen through Twenty-Eight charge money laundering under 18 U.S.C. § 1957(a), with forfeiture allegations. Businesses named include Unity Tax Express, LLC, owned by Robert Pearson, and Trucking on Faith, LLC.

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Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 1 of 31 PageID #: 1
FILED

UNITED STATES DISTRICT COURT CT.19 2022

FOR THE NORTHERN DISTRICT OF MISSISSIPPI, : K

UNITED STATES OF AMERICA

ROBERT PEARSON
LAKISHA PEARSON
GLENDON JONES
RONEISHA DENNIS
MELVIN HARRIS
DAMETRIS PEARSON
TERRANCE ISOM
DEVONTE SMITH
JALIYAH GODWIN
JACOBY ALEXANDER
KEVIN ANDERSON
DIANNE COX

DORIS PEARSON and
MARECEO HOBSON

Defendants

The Grand Jury charges that:

At all times relevant to this Indictment:

Introduction

A. Paycheck Protection Program

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Deputy

Criminal No. 3:22CR |32.,

Violations:

Count One: Conspiracy to Commit Wire
Fraud
(18 U.S.C. §§ 1343 & 1349)

Counts Two — Fourteen: Wire Fraud
(18 U.S.C. § 1343)

Counts Fifteen — Twenty-Eight: Money

Laundering
(18 U.S.C. § 1957(a))

Wire Fraud Forfeiture Allegation
(18 U.S.C. § 981(a)(1)(C) and

28 U.S.C. § 2461)

Money Laundering Forfeiture Allegation
(18 U.S.C. § 982(a)(1))

INDICTMENT

1. The Paycheck Protection Program ("PPP") was a COVID-19 pandemic relief program

administered by the Small Business Administration ("SBA") that provided forgivable
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loans to small businesses for job retention and certain other expenses. The PPP
permitted participating third-party lenders to approve and disburse SBA-backed PPP
loans to cover payroll, fixed debts, utilities, rent/mortgage, accounts payable and other
bills incurred by qualifying businesses during, and resulting from, the COVID-19
pandemic. PPP loans were fully guaranteed by the SBA.

. To obtain a PPP loan, a qualifying business had to submit a PPP loan application,
which was signed by an authorized representative of the business. The PPP loan
application required the business (through its authorized representative) to
acknowledge the program rules and make certain affirmative certifications to be
eligible to obtain the PPP loan, including that the business was in operation and either
had employees for whom it paid salaries and payroll taxes or paid independent
contractors. A business applying for a PPP loan was required to provide
documentation showing its payroll expenses, such as filed federal income tax
documents.

. The qualifying business had to have been in operation since at least February 15, 2020.
. PPP loan applications were electronically submitted or caused to be submitted by the
borrower and received through SBA servers located in Virginia / Oregon. [Virginia -
PPP Round 1 or 2 or Oregon if submitted after 1/11/2021 in Round 3]. Once
approved, the business received the PPP loan proceeds via an electronic funds transfer
from the third-party lender to a financial account under the control of the business.

. The proceeds of a PPP loan could be used for certain specified items, such as payroll

costs, costs related to the continuation of group health care benefits, or mortgage
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interest payments. The proceeds of a PPP loan were not permitted to be used by the
borrowers to purchase consumer goods, automobiles, personal residences, clothing,
jewelry, to pay the borrower's personal federal income taxes, or to fund the borrower's
ordinary day-to-day living expenses unrelated to the specified authorized expenses.

. In addition, businesses applying for a PPP loan were required to provide
documentation showing their payroll expenses. Businesses applying for PPP loans had
to certify “that the information provided in th[e] application and the information
provided in all supporting documents and forms is true and accurate in all material
respects” and acknowledge “that knowingly making a false statement to obtain a
guaranteed loan from SBA is punishable under the law.”

. A PPP loan application was processed by a participating lender. If a PPP loan
application was approved, the participating lender funded the PPP loan using its own
monies, which were guaranteed by the SBA. Data from the application, including
information about the borrower, the total amount of the loan, and the listed number
of employees, was transmitted by the lender to the SBA while processing the loan.

B. Relevant Individuals and Entities

. Unity Tax Express, LLC, was a business in Mississippi, registered with the Mississippi
Secretary of State on or about February 15, 2021. The company’s purported line of
business included tax preparation services. The defendant ROBERT PEARSON was
the president and owner of many companies, including Unity Tax Express, LLC. The
defendant LAKSIHA PEARSON was the registered agent of Unity Tax Express,

LLC.
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Defendant ROBERT PEARSON was the owner of the Regions Bank business account
of Unity Tax Express, LLC. Defendant LAKSTHA PEARSON had access to the
Regions Bank business account of Unity Tax Express, LLC.

Trucking on Faith, LLC, was a business in Mississippi, registered with the Mississippi
Secretary of State on or about March 23, 2020. Defendant GLENDON JONES was
registered as the registered agent and incorporator of Trucking on Faith, LLC. The
company’s purported line of business included general freight trucking. This business
was dissolved on or about September 7, 2021. On May 5, 2022, the business Trucking
on Faith, LLC, registered with the Mississippi Secretary of State and Defendant
GLENDON JONES was listed at the registered agent and Defendant LAKISHA
PEARSON was listed as a partner.

Alexander and Sons, LLC, was a business in Mississippi, registered with the
Mississippi Secretary of State on or about February 12, 2021. Defendant JACOBY
ALEXANDER was registered as the registered agent and manager of Alexander and
Sons, LLC. The company’s purported line of business included general freight
trucking.

Reliable Brokerage, LLC, was a business in Mississippi, registered with the Mississippi
Secretary of State on or about February 15, 2021. Defendant GLENDON JONES is
registered as the registered agent and organizer of Reliable Brokerage, LLC. The
company’s purported line of business included commodity contracts brokerage.

All in One Brokerage, LLC, was a business in Mississippi, registered with the

Mississippi Secretary of State on or about February 15, 2021. Defendant RONEISHA
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DENNIS was registered as the registered agent and manager of All in One Brokerage,
LLC. The company’s purported line of business included commodity contracts

brokerage.

14. Big Baby Brokerage, LLC, was a business in Mississippi, registered with the

Mississippi Secretary of State on or about February 15, 2021. Defendant MELVIN
HARRIS was registered as the registered agent and manager of Big Baby Brokerage,
LLC. The company’s purported line of business included commodity contracts
brokerage.

3 Love Trucking, LLC, was a business in Mississippi, registered with the Mississippi
Secretary of State on or about February 16, 2021. Defendant MARECEO HOBSON
was registered as the registered agent and manager of 3 Love Trucking, LLC. The
company’s purported line of business included general freight trucking.

DLP Brokerage, LLC, was a business in Mississippi, registered with the Mississippi
Secretary of State on or about February 15, 2021. Defendant DAMETRIS PEARSON
was registered as the registered agent and manager of DLP Brokerage LLC. The
company’s purported line of business included commodity contracts brokerage.
Byhalia Lawn Service, LLC, was a business in Mississippi, registered with the
Mississippi Secretary of State on or about February 16, 2021. Defendant DIANNE
COX is registered as the registered agent and manager of Byhalia Lawn Service, LLC.
The company’s purported line of business included landscaping services.

Grind Time Trucking, LLC, was a business in Mississippi, registered with the

Mississippi Secretary of State on or about February 16, 2021. Defendant DEVONTE
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SMITH was registered as the registered agent and manager of Grind Time Trucking,
LLC. The company’s purported line of business included general freight trucking.

19. Castro Freight, LLC, was a business in Mississippi, registered with the Mississippi
Secretary of State on or about February 24, 2021. Defendant KEVIN ANDERSON
was registered as the registered agent and manager of Castro Freight, LLC. The
company’s purported line of business included commodity contracts brokerage.

20. JJG Brokerage, LLC, was a business in Mississippi, registered with the Mississippi
Secretary of State on or about March 2, 2021. Defendant JALIYAH GODWIN was
registered as the registered agent and manager of JJG Brokerage, LLC. The
company’s purported line of business included commodity contracts brokerage.

21. Trey’s Consolidated Freight, LLC, was a business in Mississippi, registered with the
Mississippi Secretary of State on or about February 15, 2021. Defendant
TERRANCE ISOM was registered as the registered agent and manager of Trey’s
Consolidated Freight, LLC. The company’s purported line of business included
commodity contracts brokerage.

22.A and D Trucking, LLC, was a business in Mississippi, registered with the
Mississippi Secretary of State on or about February 16, 2021. Defendant DORIS
PEARSON was registered as the registered agent and manager of A and D
Trucking, LLC. The company’s purported line of business included general freight

trucking.
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C.

Banks and Paycheck Protection Program

23. Banks that participated as a lender in a program referred to as the Paycheck

Protection Program (PPP) operated by the United States Small Business

Administration (SBA), were authorized to lend funds to eligible borrowers under

the terms of the PPP. To obtain a PPP loan through the banks, customers submitted

a loan application to the banks, and an employee of the bank submitted the loan

information through an SBA loan application portal. Once the SBA approved the

loan, the bank would issue the loan funds to the customer.

24. The following were banks that participated in the PPP relevant to this case:

a.

ReadyCap Lending, LLC, with operation headquarters in New York, New
York.

Capital Plus Financial, with operation headquarters in Bedford, Texas.
Prestamos CDFI, LLC, with operation headquarters in Phoenix, Arizona.
Kabbage, Inc, with operation headquarters in Norcross, Georgia.
Community Federal Savings Bank was a federally insured financial
institution with operation headquarters in Woodhaven, New York.
Transportation Alliance Bank, doing business as TAB Bank, was a federally
insured financial institution headquartered in Ogden, Utah.

Cross River Bank was a federally insured financial institution headquartered
in Teaneck, New Jersey.

Customers Bank was a federally insured financial institution headquartered

in Phoenixville, Pennsylvania.
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i. Trustmark Bank was a federally insured financial institution headquartered
in Jackson, Mississippi.
COUNT ONE

Conspiracy to Commit Wire Fraud
(18 U.S.C. §§ 1343 & 1349)

The Grand Jury charges:
25. The Grand Jury re-alleges and incorporates by reference paragraphs 1-23 of this
Indictment.
26. On or about January 1, 2021, and continuing until at least on or around June 30, 2021,
in the Northern District of Mississippi and elsewhere, the defendants,
ROBERT PEARSON, LAKISHA PEARSON, GLENDON JONES, RONEISHA
DENNIS, MELVIN HARRIS, DAMETRIS PEARSON, TERRANCE ISOM,
DEVONTE SMITH, JALIYAH GODWIN, JACOBY ALEXANDER, KEVIN
ANDERSON, DIANNE COX, DORIS PEARSON, and MARECEO HOBSON,
did knowingly and willfully, that is, with the intent to further the objects of the conspiracy,
combine, conspire, confederate, and agree with each other, and with others known and
unknown to the Grand Jury, to knowingly, and with the intent to defraud, devise, and intend
to devise, a scheme and artifice to defraud, and to obtain money and property by means of
materially false and fraudulent pretenses, representations, and promises, knowing that the
pretenses, representations, and promises were false and fraudulent when made, and for the
purpose of executing the scheme and artifice, did knowingly transmit and cause to be

transmitted, by means of wire communication in interstate commerce, certain writings, signs,

signals, pictures, and sounds, in violation of Title 18, United States Code, Section 1343.
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 9 of 31 PageID #: 9
Purpose of the Conspiracy

27. The purpose of the scheme was for defendants ROBERT PEARSON, LAKISHA
PEARSON, GLENDON JONES, RONEISHA DENNIS, MELVIN HARRIS,
DAMETRIS PEARSON, TERRANCE ISOM, DEVONTE SMITH, JALIYAH
GODWIN, JACOBY ALEXANDER, KEVIN ANDERSON, DIANNE COX,
DORIS PEARSON, and MARECEO HOBSON to obtain PPP loan proceeds
under false and fraudulent pretenses, including representing that their businesses
were viable and ongoing businesses when they were not existing or were not doing
business until after February 1, 2020 or February 15, 2020, and did not employ the
number of persons which the defendants represented to the lenders and SBA were
so employed.

Manner and Means of the Conspiracy

28. Beginning on or about January 10, 2021, and continuing until at least on or around
January 25, 2022, in the Northern District of Mississippi, defendants ROBERT
PEARSON, LAKISHA PEARSON, GLENDON JONES, RONEISHA DENNIS,
MELVIN HARRIS, DAMETRIS PEARSON, TERRANCE ISOM, DEVONTE
SMITH, JALIYAH GODWIN, JACOBY ALEXANDER, KEVIN ANDERSON,
DIANNE COX, DORIS PEARSON, and MARECEO HOBSON devised a
scheme to defraud, and to obtain PPP funds, by filing false and fraudulent PPP
applications and agreements on behalf of their respective businesses, the respective

banks, and the SBA and by falsely agreeing only to use the funds for payroll expenses
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 10 of 31 PageID #: 10
or other permissible expenses for their respective businesses when, in fact, they

intended to use the funds for other purposes, including funding other businesses,

purchasing real and personal property, paying personal expenses, and paying

“kickbacks” to defendants ROBERT PEARSON, LAKISHA PEARSON, and

GLENDON JONES, as follows:

Approximate Date

Applicant

Description

February 16, 2021

DEVONTE SMITH

The Grind Time Trucking, LLC PPP
loan application containing false
information and documents provided
by defendant DEVONTE SMITH and
submitted by DEVONTE SMITH
from Marshall County, Mississippi to
SBA approved lender ReadyCap
Lending, LLC, headquartered in New
York, New York.

February 20, 2021

GLENDON JONES

The Reliable Brokerage, LLC PPP
loan application containing false
information and documents provided
by defendant GLENDON JONES and
submitted by GLENDON JONES
from Marshall County, Mississippi to
SBA approved lender ReadyCap
Lending, LLC, headquartered in New
York, New York.

February 20, 2021

RONEISHA DENNIS

The All in One Brokerage, LLC PPP
loan application containing false
information and documents provided
by defendant RONEISHA DENNIS
and submitted by RONEISHA
DENNIS from Marshall County,
Mississippi to SBA approved lender
ReadyCap Lending, LLC,
headquartered in New York, New
York.
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 11 of 31 PageID #: 11
February 20, 2021

TERRANCE ISOM

The Trey’s Consolidated Freight, LLC
PPP loan application containing false
information and documents provided
by defendant TERRANCE ISOM and
submitted by TERRANCE ISOM
from Marshall County, Mississippi to
SBA approved lender ReadyCap
Lending, LLC, headquartered in New
York, New York.

February 21, 2021

JACOBY ALEXANDER

The Alexander and Sons, LLC PPP
loan application containing false
information and documents provided
by defendant JACOBY
ALEXANDER and submitted by
JACOBY ALEXANDER _ from
Marshall County, Mississippi to SBA
approved lender ReadyCap, Lending,
LLC, headquartered in New York,
New York.

February 25, 2021

KEVIN ANDERSON

The Castro Freight, LLC PPP loan
application containing false
information and documents provided
by defendant KEVIN ANDERSON
and. submitted by KEVIN
ANDERSON from Marshall County,
Mississippi to SBA approved lender
ReadyCap Lending, LLC,
headquartered in New York, New
York.

March 1, 2021

JALIYAH GODWIN

The JJG Brokerage, LLC PPP loan
application containing false
information and documents provided
by defendant JALIYAH GODWIN
and submitted by JALIYAH
GODWIN from Marshall County,
Mississippi to SBA approved lender
ReadyCap Lending, LLC,
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headquartered in New York, New
York.

March 25, 2021 MELVIN HARRIS The Big Baby Brokerage, LLC PPP
loan application containing false
information and documents provided
by defendant MELVIN HARRIS and
submitted by MELVIN HARRIS from
Marshall County, Mississippi to SBA
approved lender Customers Bank,
headquartered in Phoenixville,

Pennsylvania.
March 26, 2021 MARECEO HOBSON The 3 Love Trucking, LLC PPP loan
application containing false

information and documents provided
by defendant MARECEO HOBSON
and submitted by MARECEO
HOBSON from Marshall County,
Mississippi to SBA approved lender
Customers Bank, headquartered in
Phoenixville, Pennsylvania.

April 26, 2021 ROBERT PEARSON The Unity Tax Express, LLC PPP loan
application containing false
information and documents provided
by defendant ROBERT PEARSON
and submitted by ROBERT
PEARSON from Marshall County,
Mississippi to SBA approved lender
Community Federal Savings Bank,
headquartered in Woodhaven, New

York.
April 29, 2021 DAMETRIS PEARSON | The DLP Brokerage, LLC PPP loan
application containing false

information and documents provided
by defendant DAMETRIS PEARSON
and submitted by DAMETRIS
PEARSON from Marshall County,
Mississippi to SBA approved lender
Community Federal Savings Bank,
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 13 of 31 PageID #: 13
headquartered in Woodhaven, New
York.

April 29, 2021 DIANNE COX The Byhalia Lawn Service, LLC PPP
loan application containing false
information and documents provided
by defendant DIANNE COX and
submitted by DIANNE COX from
Marshall County, Mississippi to SBA
approved lender Community Federal
Savings Bank, headquartered in
Woodhaven, New York.

May 24, 2021 DORIS PEARSON The A and D Trucking, LLC loan
application containing false
information and documents provided
by defendant DORIS PEARSON and
submitted by DORIS PEARSON from
Marshall County, Mississippi to SBA
approved lender Community Federal
Savings Bank, headquartered in
Woodhaven, New York.

29.To further the conspiracy and to achieve its purposes, defendants ROBERT
PEARSON, LAKISHA PEARSON, GLENDON JONES, RONEISHA DENNIS,
MELVIN HARRIS, DAMETRIS PEARSON, TERRANCE ISOM, DEVONTE
SMITH, JALIYAH GODWIN, JACOBY ALEXANDER, KEVIN ANDERSON,
DIANNE COX, DORIS PEARSON, and MARECEO HOBSON did commit
numerous overt acts, including, but not limited to the following:
a. On or about February 25, 2021, defendant JACOBY ALEXANDER of
Alexander and Sons, LLC, deposited $84,000.00 in PPP funds into Unity Tax

Express, LLC bank account ending in # 4811 controlled by defendants
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Case

ROBERT PEARSON and LAKISHA PEARSON as a kickback for their
services.

On or about February 25, 2021, defendant JACOBY ALEXANDER
deposited $25,000.00 in PPP funds into Trucking on Faith, LLC bank account
ending in #0315 controlled by defendant GLENDON JONES as a kickback
for his services.

On or about March 8, 2021, defendant DEVONTE SMITH of Grind Time
Trucking, LLC deposited $63,700.00 in PPP funds into Unity Tax Express,
LLC bank account ending in #4811 controlled by defendants ROBERT
PEARSON and LAKISHA PEARSON as a kickback for their services.

On or about March 8, 2021, defendant DEVONTE SMITH of Grind Time
Trucking, LLC deposited $10,000.00 in PPP funds into Trucking on Faith,
INC bank account ending in #0135 controlled by defendant GLENDON
JONES as a kickback for his services.

On or about March 8, 2021, defendant KEVIN ANDERSON of Castro
Freight, LLC deposited $76,312.00 in PPP funds into Unity Tax Express, LLC
bank account ending in #4811 controlled by defendants ROBERT PEARSON
and LAKISHA PEARSON as a kickback for their services.

On or about March 11, 2021, defendant JALIYAH GODWIN deposited
$76,312.00 in PPP funds into Unity Tax Express, LLC bank account ending
in #4811 controlled by defendants ROBERT PEARSON and LAKISHA

PEARSON as a kickback for their services.
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 15 of 31 PageID #: 15
g. On or about March 18, 2021, defendant TERRANCE ISOM deposited
$76,312.00 in PPP funds into GK WTD Trucking, LLC bank account ending
in #3294 controlled by defendants ROBERT PEARSON and LAKISHA
PEARSON as a kickback for their services.

h. On or about March 18, 2021, defendant GLENDON JONES of Reliable
Brokerage, LLC, deposited $76,312.00 in PPP funds into Unity Tax Express,
LLC bank account ending in #4811 controlled by defendants ROBERT
PEARSON and LAKISHA PEARSON as a kickback for their services.

i. On or about March 18, 2021, defendant RONEISHA DENNIS of All in One
Brokerage, LLC, deposited $76,312.00 in PPP funds into Unity Tax Express,
LLC bank account ending in #4811 controlled by defendants ROBERT
PEARSON and LAKISHA PEARSON as a kickback for their services.

j. On or about April 5, 2021, defendant MELVIN HARRIS of Big Baby
Brokerage, LLC, deposited $79,904.00 in PPP funds into Unity Tax Express,
LLC bank account ending in #4811 controlled by defendants ROBERT
PEARSON and LAKISHA PEARSON as a kickback for their services.

k. On or about April 6, 2021, defendant MARECEO HOBSON of 3 Love
Trucking, LLC deposited $53,000.00 in PPP funds into Unity Tax Express,
LLC bank account ending in #4811 controlled by defendants ROBERT
PEARSON and LAKISHA PEARSON as a kickback for their services.

1. On or about May 24, 2021, defendant DORIS PEARSON of A and D

Trucking, LLC deposited $62,000.00 in PPP funds into Unity Tax Express,
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 16 of 31 PageID #: 16
LLC bank account ending in #4811 controlled defendants ROBERT
PEARSON and LAKISHA PEARSON as a kickback for their services.

m. On or about May 26, 2021, defendant DAMETRIS PEARSON of DLP
Brokerage, LLC deposited $58,691.00 in PPP funds into Unity Tax Express,
LLC bank account ending in #4811 controlled by defendants ROBERT
PEARSON and LAKISHA PEARSON as a kickback for their services.

n. On or about May 28, 2021, defendant DORIS PEARSON of A AND D
Trucking, LLC, deposited $100,000.00 in PPP funds into Doris P’s Fast Food
and Catering bank account ending in #8972 controlled by Doris Pearson.

o. On or about June 11, 2021, defendant DORIS PEARSON deposited
$75,000.00 in PPP funds into GKWTD Trucking, LLC bank account ending
in #3294 controlled by defendants ROBERT PEARSON and LAKISHA
PEARSON as a kickback for their services.

30.From on or about February 1, 2021, through on or about April 31, 2021,
substantial monies were transferred by defendants ROBERT PEARSON,
GLENDON JONES, MELVIN HARRIS, DEVONTE SMITH, JACOBY
ALEXANDER, and KEVIN ANDERSON, who misused the PPP funds by
diverting them to other businesses and using them on unauthorized expenses,
including, but not limited to, purchases of personal property, as follows:

a. On or about February 25, 2021, defendant GLENDON JONES did use

$25,000.00 in PPP funds to purchase three off road vehicles, including: a 2021

Polaris ATV VIN/SERIAL: 4XASXE858MB330908; a 2021 CAN AM ATV
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Case

VIN/SERIAL: 3JBLGAR44MJ003270; and a 2021 CAN AM ATV
VIN/SERIAL: 3JBLWAT41MJ001360.

On or about February 27, 2021, defendant JACOBY ALEXANDER did use
$31,245.32 in PPP funds to purchase a 2021 Polaris ATV VIN/SERIAL:
3NSPAL927MF 146645.

On or about March 2, 2021, defendant ROBERT PEARSON did use
$34,987.01 in PPP funds to purchase a 2021 Toyota Camry VIN:
4T1K61AK8MU543622.

On or about March 9, 2021, defendant DEVONTE SMITH did use
$12,000.00 in PPP funds to purchase a 1998 Pontiac Firebird VIN:
2G2FV22G6W2218134.

On or about March 9, 2021, defendant KEVIN ANDERSON did use
$25,081.50 in PPP funds to purchase a 2013 Jaguar XJ VIN:
SAJWJ2GD9D8V47773.

On or about March 18, 2021, defendant GLENDON JONES did use
$86,727.88 in PPP funds to purchase a 2021 F-350 Ford truck VIN:
1FT8W3BTOMEC97502.

On or about March 18, 2021, defendant DEVONTE SMITH did use
$15,000.00 in PPP funds to purchase a Freightliner Colombia 120 VIN:
1FUJA6CV37LW93837.

On or about March 18, 2021, defendant KEVIN ANDERSON did use
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$11,134.79 in PPP funds to purchase two industrial lawn mowers and an

open gate trailer. The items are specifically identified as a 4-Pro Turn Z Lawn
mower VIN/SERIAL: 002290, an Areins Kawasaki Lawn mower VIN/SERIAL:
023368, and a Gate Trailer Open trailer VIN/SERIAL: 46CFB1415MM038394.

i. On or about March 19, 2021, defendant KEVIN ANDERSON did use
$14,840.00 in PPP funds to purchase a 2021 Kawasaki ATV
JKAVFDL35MB509684 and a 2021 CAN AM ATV 3JBLGAR46MJ004100.

j. On or about March 20, 2021, defendant ROBERT PEARSON did use
$55,800.00 in PPP funds to purchase a 2021 Cadillac CTS VIN:
1G6DN5RW9M0127491.

k. On or about March 20, 2021, defendant ROBERT PEARSON did use
$78,801.79 in PPP funds to purchase a 2021 GMC Yukon VIN:
1GKS1GKD8MR295966.

1. On or about March 22, 2021, defendant ROBERT PEARSON did use
$18,927.27 in PPP funds to pay off a 2016 Kenworth semi-truck VIN:
IXKYDP9X1GJ129602.

m. On or about April 5, 2021, defendant MELVIN HARRIS did use $67,394.24
in PPP funds to purchase a 2018 Dodge Ram truck.

n. On or about May 22, 2021, defendant ROBERT PEARSON did use
$71,414.54 in PPP funds to purchase a 2021 GMC Sierra VIN:
1GT49REY8MF125888.

All in violation of Title 18, United States Code, Sections 1343 and 1349.
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 19 of 31 PageID #: 19
COUNTS TWO - FOURTEEN

Wire Fraud
(18 U.S.C. § 1343)

31. The Grand Jury re-alleges and incorporates by reference paragraphs 1-29 of this

Indictment.

32. On or about the dates set forth below, in the Northern District of Mississippi and

elsewhere, the defendants,

ROBERT PEARSON, GLENDON JONES, RONEISHA DENNIS, MELVIN
HARRIS, DAMETRIS PEARSON, TERRANCE ISOM, DEVONTE SMITH,
JALIYAH GODWIN, JACOBY ALEXANDER, KEVIN ANDERSON, DIANNE
COX, DORIS PEARSON, and MARECEO HOBSON,

aided and abetted by one another, having devised and intending to devise a scheme and

artifice to defraud, and for obtaining money and property by means of materially false and

fraudulent pretenses, representations, and promises, that is, to submit applications for PPP

loans containing material misrepresentations regarding numbers of employees, payroll paid,

the nature of their businesses, and false documents, including a falsified bank statement

regarding payroll payments, defendants did transmit and cause to be transmitted by means

of wire communications in interstate commerce, writings, signs, signals, pictures, and

sounds for the purpose of executing the scheme to defraud, as set forth below:

Count | Approximate | Defendant Description
Date

2 February 16, | DEVONTE SMITH | The Grind Time Trucking, LLC PPP loan
2021 application containing false information

and documents provided by defendant
DEVONTE SMITH and submitted by
DEVONTE SMITH from Marshall
County, Mississippi to SBA approved
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 20 of 31 PageID #: 20
lender ReadyCap Lending, LLC,
headquartered in New York, New York.

February 20,

GLENDON JONES

The Reliable Brokerage, LLC PPP loan
application containing false information
and documents provided by defendant
GLENDON JONES and submitted by
GLENDON JONES from Marshall
County, Mississippi to SBA approved
lender ReadyCap Lending, LLC,
headquartered in New York, New York.

February 20,

RONEISHA
DENNIS

The All in One Brokerage, LLC PPP loan
application containing false information
and documents provided by defendant
RONEISHA DENNIS and submitted by
RONEISHA DENNIS from Marshall
County, Mississippi to SBA approved
lender ReadyCap Lending, LLC,
headquartered in New York, New York.

February 20,

TERRANCE ISOM

The Trey’s Consolidated Freight, LLC
PPP loan application containing false
information and documents provided by
defendant TERRANCE ISOM §$and
submitted by TERRANCE JSOM from
Marshall County, Mississippi to SBA
approved lender ReadyCap Lending,
LLC, headquartered in New York, New
York.

February 21,

JACOBY
ALEXANDER

The Alexander and Sons, LLC PPP loan
application containing false information
and documents provided by defendant
JACOBY ALEXANDER and submitted
by JACOBY ALEXANDER from
Marshall County, Mississippi to SBA
approved lender ReadyCap, Lending,
LLC, headquartered in New York, New
York.

February 25,

KEVIN
ANDERSON

The Castro Freight, LLC PPP loan
application containing false information
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 21 of 31 PageID #: 21
and documents provided by defendant
KEVIN ANDERSON and submitted by
KEVIN ANDERSON from Marshall
County, Mississippi to SBA approved
lender ReadyCap Lending, LLC,
headquartered in New York, New York.

JALIYAH
GODWIN

The JJG Brokerage, LLC PPP loan
application containing false information
and documents provided by defendant
JALIYAH GODWIN and submitted by
JALIYAH GODWIN from Marshall
County, Mississippi to SBA approved
lender ReadyCap Lending, LLC,
headquartered in New York, New York.

MELVIN HARRIS

The Big Baby Brokerage, LLC PPP loan
application containing false information
and documents provided by defendant
MELVIN HARRIS and submitted by
MELVIN HARRIS from Marshall
County, Mississippi to SBA approved
lender Customers Bank, headquartered in
Phoenixville, Pennsylvania.

MARECEO
HOBSON

The 3 Love Trucking, LLC PPP loan
application containing false information
and documents provided by defendant
MARECEO HOBSON and submitted by
MARECEO HOBSON from Marshall
County, Mississippi to SBA approved
lender Customers Bank, headquartered in
Phoenixville, Pennsylvania.

March 1,
March 25,
March 26,
April 26, 2021

ROBERT
PEARSON

The Unity Tax Express, LLC PPP loan
application containing false information
and documents provided by defendant
ROBERT PEARSON and submitted by
ROBERT PEARSON from Marshall
County, Mississippi to SBA approved
lender Community Federal Savings Bank,
headquartered in Woodhaven, New York.
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 22 of 31 PageID #: 22
April 29, 2021 | DAMETRIS
PEARSON

The DLP Brokerage, LLC PPP loan
application containing false information
and documents provided by defendant
DAMETRIS PEARSON and submitted
by DAMETRIS PEARSON from
Marshall County, Mississippi to SBA
approved lender Community Federal
Savings Bank, headquartered in
Woodhaven, New York.

April 29, 2021 | DIANNE COX

The Byhalia Lawn Service, LLC PPP loan
application containing false information
and documents provided by defendant
DIANNE COX and submitted by
DIANNE COX from Marshall County,
Mississippi to SBA approved lender
Community Federal Savings Bank,
headquartered in Woodhaven, New York.

May 24, 2021 | DORIS PEARSON

The A AND D Trucking, LLC loan
application containing false information
and documents provided by defendant
DORIS PEARSON and submitted by
DORIS PEARSON from Marshall
County, Mississippi to SBA approved
lender Community Federal Savings Bank,
headquartered in Woodhaven, New York.

Each transmission being a violation of Title 18, United State Code, Section 1343.

COUNTS FIFTEEN - TWENTY-EIGHT
Money Laundering

(18 U.S.C. § 1957)

The Grand Jury further charges:

33.The Grand Jury re-alleges and incorporates by reference paragraphs 1-31 of this

Indictment.
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 23 of 31 PageID #: 23
34. On or about the dates set forth below, in the Northern District of Mississippi and

elsewhere, the defendants,

ROBERT PEARSON, LAKISHA PEARSON, GLENDON JONES, RONEISHA
DENNIS, MELVIN HARRIS, DAMETRIS PEARSON, TERRANCE ISOM,
DEVONTE SMITH, JALIYAH GODWIN, JACOBY ALEXANDER, KEVIN
ANDERSON, DORIS PEARSON, and MARECEO HOBSON,

aided and abetted by one another, knowingly engaged and attempted to engage in the
following monetary transactions by, through, and to a financial institution, in and affecting
interstate commerce, in criminally derived property of a value greater than $10,000, that is,
the deposit, withdrawal, transfer, and exchange of United States currency, such property
constituting and having been derived from a specified unlawful activity, that is, the wire fraud
scheme and artifice alleged herein in paragraphs 1-37 of this indictment, in violation of 18

U.S.C. § 1343:
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 24 of 31 PageID #: 24
Approximate Defendant or Defendants
Count _ Date Description
JACOBY ALEXANDER, Defendant JACOBY ALEXANDER did
ROBERT PEARSON, and transfer $84,000.00 in PPP funds from
LAKISHA PEARSON Alexander and Sons, LLC account ending in
February 25, #1576 to defendants ROBERT PEARSON and
2021 LAKISHA PEARSON’s Unity Tax Express,
15 LLC account.
JACOBY ALEXANDER and | Defendant JACOBY ALEXANDER did
GLENDON JONES transfer $25,000.00 in PPP funds to defendant
February 25, GLENDON JONES’s Trucking on Faith, LLC
16 | 2021 account.
DEVONTE SMITH and Defendant DEVONTE SMITH did transfer
GLENDON JONES $10,000.00 in PPP funds from Grind Time
March 8, Trucking, LLC account ending in #5125
2021 $10,000.00 to defendant GLENDON JONES’
17 Trucking on Faith, LLC account.
DEVONTE SMITH, Defendant DEVONTE SMITH did transfer
ROBERT PEARSON, and $63,700.00 in PPP funds from Grind Time
LAKISHA PEARSON Trucking, LLC account ending in #5125 to
defendants ROBERT PEARSON and
March 8, LAKISHA PEARSON’s Unity Tax Express,
18 | 2021 LLC account.
KEVIN ANDERSON, Defendant KEVIN ANDERSON did transfer
ROBERT PEARSON, and $76,312.00 in PPP funds from Castro Freight,
March 8, ; LAKISHA PEARSON LLC account ending in #5370 to defendants
2021 ROBERT PEARSON and LAKISHA
19 PEARSON ’s Unity Tax Express, LLC account.
JALIYAH GODWIN, Defendant JALIYAH GODWIN did transfer
ROBERT PEARSON, and $76,312.00 in PPP funds from JJG Brokerage,
March 11, | LAKISHA PEARSON LLC account ending in #5540 to defendants
20 | 2021 ROBERT PEARSON and LAKISHA
PEARSON’s Unity Tax Express, LLC account.
GLENDON JONES, Defendant GLENDON JONES did transfer
ROBERT PEARSON, and $76,312.00 in PPP funds from Reliable
LAKISHA PEARSON Brokerage, LLC account ending in #4889 to
March 18, defendants ROBERT PEARSON and
2021 LAKISHA PEARSON’s Unity Tax Express,
2] LLC account.
RONEISHA DENNIS, Defendant RONEISHA DENNIS did transfer
ROBERT PEARSON, and $76,312.00 in PPP funds from Ail in One
LAKISHA PEARSON Brokerage, LLC account ending in #4897 to
March 18, defendants ROBERT PEARSON and
2021 LAKISHA PEARSON’s Unity Tax Express,
22 LLC account.
MELVIN HARRIS, ROBERT | Defendant MELVIN HARRIS did transfer
April 5, 2021 | PEARSON, and LAKISHA $79,904.00 in PPP funds from Big Baby
23 PEARSON Brokerage, LLC account ending in #4900 to
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 25 of 31 PageID #: 25
defendants ROBERT PEARSON and
LAKISHA PEARSON’s Unity Tax Express,
LLC account.

April 6, 2021

MARECEO HOBSON,
ROBERT PEARSON, and
LAKISHA PEARSON

Defendant MARECEO HOBSON did transfer
$53,000.00 in PPP funds from 3 Love Trucking,
LLC account ending in #4986 to defendants
ROBERT PEARSON and LAKISHA
PEARSON’s Unity Tax Express, LLC;

March

DORIS PEARSON,
ROBERT PEARSON, and
LAKISHA PEARSON

Defendant DORIS PEARSON did transfer
$62,000.00 in PPP funds from A AND D
Trucking, LLC account ending in #4803 to
defendants ROBERT PEARSON and
LAKISHA PEARSON’s Unity Tax Express,
LLC account.

May

LAKISHA PEARSON

Defendant LAKISHA PEARSON did transfer
$27,117.58 in PPP funds from the Unity Tax
Express, LLC account to the Bank of Holly
Springs.

May

TERRANCE ISOM,
ROBERT PEARSON, and
LAKISHA PEARSON

Defendant TERRANCE ISOM did transfer
$76,312.00 in PPP funds from Trey’s
Consolidated Freight, LLC account ending in
#4862 to defendants ROBERT PEARSON and
LAKISHA PEARSON’s GK WTD Trucking,
LLC account.

May

DAMETRIS PEARSON,
ROBERT PEARSON, and
LAKISHA PEARSON

Defendant DAMETRIS PEARSON did
transfer $58,691.00 in PPP funds from DLP
Brokerage, LLC account ending in #4838 to
defendants ROBERT PEARSON and
LAKISHA PEARSON’s Unity Tax Express,
LLC account.

Each monetary transaction being a violation of Title 18, United States Code, Section

1957(a).
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 26 of 31 PageID #: 26
WIRE FRAUD FORFEITURE ALLEGATION
(18 U.S.C. § 982(a)(2)(A))

The Grand Jury further finds:

35. Upon conviction of one or more of the offenses in violation of Title 18, United States

Code, Sections 1349 and 1343, set forth in Counts One through Fourteen, the

defendants,

ROBERT PEARSON, LAKISHA PEARSON, GLENDON JONES, RONEISHA
DENNIS, MELVIN HARRIS, DAMETRIS PEARSON, TERRANCE ISOM,
DEVONTE SMITH, JALIYAH GODWIN, JACOBY ALEXANDER, KEVIN
ANDERSON, DIANNE COX, DORIS PEARSON, and MARECEO HOBSON,

shall forfeit to the United States, pursuant to Title 18, United States Code, Section

982(a)(2)(A), any property constituting, or derived from, proceeds he obtained directly or

indirectly, as result of such violations. The property to be forfeited includes, but is not limited

to, the following assets:

a.

$217,569.97 in U.S. currency seized from First South Financial Bank
account ending in #3294.

$275.23 in U.S. currency seized from First South Financial Bank account
ending in #8515.

$15,002.41 in U.S. currency seized from First South Financial Bank
account ending in #8507.

$15,002.41 in U.S. currency seized from First South Financial Bank
account ending in #8509.

$43,269.60 in U.S. currency seized from Bank of Holly Springs account
ending in #5233.

$93,355.30 in U.S. currency seized from Bank of Holly Springs account
ending in #9255.

$14,229.03 in U.S. currency seized from Bank of Holly Springs account
ending in #5233.
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 27 of 31 PageID #: 27
k.

Real property identified as Lot No. 10, Coldwater Hills Subdivison, 1.50
acres, more or less, located in Section 10, Township 2 South, Range 3
West, Marshall County, Mississippi, as recorded in Plat File 1021A filed
for record in the office of the Chancery Clerk of Marshall County,
Mississippi

Real property identified as Lot 57, Section C, Haraway Gardens
Subdivison, located in Section 34, Township 1 South, Range 6 West,
DeSoto County, Mississippi, as recorded in Plat Book 39, Page 1, in the
Chancery Clerk’s Office of DeSoto County, Mississippi

Real property identified as Lot 226, Neighborhood C, Cherry Tree Park
Subdivison, situated in Section 16, Township 2 South, Range 7 West,
DeSoto County, Mississippi, as per plat of record in Plat Book 94, Page
40, in the Chancery Clerk’s Office of DeSoto County, Mississippi

2013 Jaguar XJL SAJWJ2GD9D8V47773

4-Pro Turn Z Lawn mower VIN/SERIAL: 002290

m. Areins Kawasaki Lawn mower VIN/SERIAL: 023368

Nl.

oO.

u.

Vv.

Gate Trailer Open trailer VIN/SERIAL: 46CFB1415MM038394
2021 Kawasaki ATV JKAVFDL35MB509684

2021 CAN AM ATV 3JBLGAR46MJ004100

2007 Freightliner Conventional Semi-Truck VIN: LFUJA6CV37LW93837

1998 Pontiac Firebird VIN: 2G2FV22G6W2218134

2021 Ford 350 VIN: IFT8W3BT0MEC97502

2021 Polaris ATV VIN/SERIAL: 4XASXE858MB330908
2021 CAN AM ATV VIN/SERIAL: 3JBLGAR44MJ003270

2021 CAN AM ATV VIN/SERIAL: 3JBLWAT41MJ001360

w. 2021 Polaris ATV VIN/SERJAL: 3NSPAL927MF 146645
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 28 of 31 PageID #: 28
X.

y.

Zz.

2021 Toyota Camry VIN: 4T1K61AK4MU430881
2021 Toyota Camry VIN: 4T1K61AK8MU543622

2021 Cadillac CTS VIN: 1G6DN5RW9M0127491

aa. 2021 GMC Yukon VIN: 1GKS1IGKD8MR295966

bb. 2021 GMC Sierra VIN: 1GT49REY8MF 125888

cc. 2016 Kenworth Truck Semi-Truck IXKYDP9X1GJ129602

If any of the property described above as being forfeitable pursuant to Title 18, United

States Code, Section 982(a)(2)(A), as a result of any act or omission of the defendant --

a.

b.

cannot be located upon the exercise of due diligence;

has been transferred or sold to, or deposited with, a third party;
has been placed beyond the jurisdiction of the Court;

has been substantially diminished in value; or

has been commingled with other property which cannot be divided without
difficulty;

it is the intention of the United States, pursuant to Title 28, United States Code, Section

2461(c), incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any

other property of the defendant up to the value of the property described above.

All pursuant to Title 18, United States Code, Section 982 (a)(2)(A), and Title 28,

United States Code, Section 2461{c).
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 29 of 31 PageID #: 29
MONEY LAUNDERING FORFEITURE ALLEGATION
(18 U.S.C. § 982(a)(1))

. Upon conviction of one or more of the offenses in violation of Title 18, United States

Code, Section 1957, set forth in Counts 15 through 26, the defendants,

ROBERT PEARSON, LAKISHA PEARSON, GLENDON JONES, RONEISHA
DENNIS, MELVIN HARRIS, DAMETRIS PEARSON, TERRANCE ISOM,
DEVONTE SMITH, JALIYAH GODWIN, JACOBY ALEXANDER, KEVIN
ANDERSON, DIANNE COX, DORIS PEARSON, and MARECEO HOBSON,

shall forfeit to the United States, pursuant to Title 18, United States Code, Section
982(a)(1), any property, real or personal, involved in such offense, or any property
traceable to such property. The property to be forfeited includes, but is not limited to,
the following assets:

a. $217,569.97 in U.S. currency seized from First South Financial Bank account
ending in #3294.

b. $275.23 in U.S. currency seized from First South Financial Bank account ending
in #8515.

c. $15,002.41 in U.S. currency seized from First South Financial Bank account
ending in #8507.

d. $15,002.41 in U.S. currency seized from First South Financial Bank account
ending in #8509.

e. $43,269.60 in U.S. currency seized from Bank of Holly Springs account ending in

f. $93,355.30 in U.S. currency seized from Bank of Holly Springs account ending in

g. $14,229.03 in U.S. currency seized from Bank of Holly Springs account ending in

h. Real property identified as Lot No. 10, Coldwater Hills Subdivison, 1.50 acres,
more or less, located in Section 10, Township 2 South, Range 3 West, Marshall
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 30 of 31 PageID #: 30
County, Mississippi, as recorded in Plat File 1021A filed for record in the office
of the Chancery Clerk of Marshall County, Mississippi

i. Real property identified as Lot 57, Section C, Haraway Gardens Subdivison,
Icated in Section 34, Township 1 South, Range 6 West, DeSoto County,
Mississippi, as recorded in Plat Book 39, Page 1, in the Chancery Clerk’s Office
of DeSoto County, Mississippi

j. Real property identified as Lot 226, Neighborhood C, Cherry Tree Park
Subdivison, situated in Section 16, Township 2 South, Range 7 West, DeSoto
County, Mississippi, as per plat of record in Plat Book 94, Page 40, in the
Chancery Clerk’s Office of DeSoto County, Mississippi

k. 2013 Jaguar XJL SAJWJ2GD9D8V47773
1. 4-Pro Turn Z Lawn mower VIN/SERIAL: 002290

m. Areins Kawasaki Lawn mower VIN/SERIAL: 023368

n. Gate Trailer Open trailer VIN/SERIAL: 46CFB1415MM038394
o. 2021 Kawasaki ATV JKAVFDL35MB509684

p. 2021 CAN AM ATV 3JBLGAR46MJ004100

q. 2007 Freightliner Conventional Semi-Truck VIN: [FUJA6CV37LW93837
r. 1998 Pontiac Firebird VIN: 2G2FV22G6W2218134

s. 2021 Ford 350 VIN: LFT8W3BTOMEC97502

t. 2021 Polaris ATV VIN/SERIAL: 4XASKE858MB330908

u. 2021 CAN AM ATV VIN/SERIAL: 3JBLGAR44MJ003270

v. 2021 CAN AM ATV VIN/SERIAL: 3JBLWAT41MJ001360

w. 2021 Polaris ATV VIN/SERIAL: 3NSPAL927MF 146645

x. 2021 Toyota Camry VIN: 4T1K61AK4MU430881

y- 2021 Toyota Camry VIN: 4T1K61AK8MU543622
Case: 3:22-cr-00132-SA-RP Doc #: 1 Filed: 10/19/22 31 of 31 PageID #: 31
z. 2021 Cadillac CTS VIN: 1G6DNSRW9MO0127491
aa. 2021 GMC Yukon VIN: 1GKSIGKD8MR295966
bb. 2021 GMC Sierra VIN: 1GT49REY8MF 125888

cc. 2016 Kenworth Truck Semi-Truck 1XKYDP9X1GJ129602
If any of the property described above as being forfeitable pursuant to Title 18, United
States Code, Section 982(a)(1), 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 intention of the United States, pursuant to Title 28, United States Code, Section
2461(c), incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any
other property of the defendants up to the value of the property described above.

All pursuant to Title 18, United States Code, Section 982 (a)(1), and Title 28, United

States Code, Section 2461(c).

A TRUE BILL
A , sa’ /s/ Signature Redacted
CLAY Wed i FOREPERSON
UNITED STAVES ATTORNEY


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