Full text
CMM:AT/JRS/SBB:RJK
F. #2022R01048
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
---------------------------------X
UNITED STATES OF AMERICA
- against -
KEITH WILLIAMS,
JANINE DA VIS,
also known as "Holiday Davis,"
MORAIS DICKS,
JAMES HAMES, JR.,
also known as "Poppa J,"
JAMARI LEWIS,
also known as "Mr. Chaketah," and
LOUEWANDA BENJAMIN,
Defendants.
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THE GRAND JURY CHARGES:
FILED
IN CLERK'S OFFICE
U.S. DISTRICT COURT E.D.N.Y.
* NOV 12 2025
*.
LONG ISLAND OFFICE
SUPERSEDING
INDICTMENT
Cr. No. 25-20 (ORB} (S-1}
(T. 18, U.S.C., §§ 371, 981(a)(l)(C},
982(a)(2), 982(b)(l), 1343, 2 and 3551 et
~.; T. 21, U.S.C., § 853{p); T. 26,
U.S.C., § 7206(2); T. 28, U.S.C.,
§ 2461 (c))
INTRODUCTION
At all times relevant to this Indictment, unless otherwise indicated:
I.
The Defendants and Relevant Entities and Individuals
I.
The defendant KEITH WILLIAMS was a resident of West Hempstead,
New York. WILLIAMS owned and controlled Credit Reset Me Inc. ("Credit Reset"), a New
York corporation, which was purportedly a credit repair business located at 683 Hempstead
Turnpike, Franklin Square, New York. WILLIAMS also owned and controlled 109 Super Store
Motors Inc. ("I 09 Super Store"), Babylon Buyers Group Inc. ("Babylon Buyers") and Lucky 13
Sports Bar and Grill Corp. ("Lucky 13"}, each New York corporations.
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2.
The defendant JANINE DA VIS, also known as "Holiday Davis," was a
resident of Wheatley Heights, New York, and worked as a tax preparer. DA VIS owned and
controlled 7 Port LLC ("7 Port") and Holiday's Promise Ltd. ("Holiday's Promise"), each New
Yark corporations.
3.
The defendant MORAIS DICKS was a resident of Dix Hills, New York.
DICKS owned and controlled Progressive Homes and Development Inc. ("Progressive Homes")
and Service Advisors, Inc. ("Service Advisors"), each New York corporations.
4.
The defendant JAMES HAMES, JR., also known as "Poppa J," was a
resident of Campbell Hall, New York. HAMES owned and controlled MJR Enterprise
Consulting Inc. ("MJR"), a New York corporation.
5.
The defendant JAMARI LEWIS, also known as "Mr. Chaketah," was a
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resident of Queens~ New York and Charlotte, North Carolina. LEWIS owned and controlled
Chakeetah, LLC ("Chakeetah"), a Colorado corporation.
6.
The defendant LOUEWANDA BENJAMIN was a resident of Amityville,
New York. BENJAMIN owned and controlled LBA Holdings, Inc. ("LBA"), a New York
corporation.
7.
Company #1 through Company #22, entities the identities of which are
known to the Grand Jury, were companies purportedly owned individually by the defendants and
their co-conspirators and used in furtherance of the defendants' fraudulent scheme.
8.
Co-Conspirator# I, an individual whose identity is known to the Grand
Jury, was an associate of the defendant JAMARI LEWIS.
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9.
Co-Conspirator #2, an individual whose identity is known to the Grand
Jury, was business partners with the defendant KEITH WILLIAMS and controlled Company #1
throug~ Company #3.
10.
Co-Conspirator #3, an individual whose identity is known to the Grand
Jury, was employed at Credit Reset and controlled Company #4.
11.
Co-Conspirator #4, an individual whose identity is known to the Grand
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Jury, was a client of and employee at Credit Reset and controlled Company #5 and Company #6.
12.
Co-Conspirator #5, an individual whose identity is known to the Grand
Jury, was an associate of the defendants KEITH WILLIAMS and JAMARI LEWIS and
controlled Company #7.
13.
Co-Conspirator #6, an individual whose identity is known to the Grand
Jury, was a client of the defendant JAMES HAMES, JR. and controlled Company #8 through
Company #14.
14.
Co-Conspirator #7, an individual whose identity is known to the Grand
Jury, was a client of the defendant JAMES HAMES, JR. and controlled Company #15 and
Company # 16.
15.
Individual #1, an individual whose identity is known to the Grand Jury,
was a client of the defendant MORAIS DICKS and controlled Company #17.
16.
Individual #2, an individual whose identity is known to the Grand Jury,
was an associate of the defendant JAMARI LEWIS and worked at Credit Reset. Individual #2
controlled Company # 18 through Company #20.
17.
Individual #3, an individual whose identity is known to the Grand Jury,
controlled Company #21 and Company #22.
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18.
Individual #4, an individual whose identity is known to the Grand Jury,
controlled Company #23.
19.
Individual #5; an individual whose identity is known to the Grand Jury,
controlled Company #24 and Company #25.
20.
The Tax Preparation Software ("TPS") was a tax return preparation
software accessible via the internet that was used to prepare and electronically file with the
Internal Revenue Service ("IRS") various tax returns and related documents.
II.
Relevant Governmental Agencies and Definitions
21.
The IRS was an agency of the United States Department of the Treasury
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responsible for administering and enforcing federal tax laws, including refundable tax credits, of
the United States and collecting taxes owed to the United States.
22.
Federal law required employers to collect, truthfully account for, and pay
over to the United States certain payroll taxes, including their employees' withheld federal
income taxes, Social Security and Medicare taxes, and the employer's matching portion of the
Social Security and Medicare taxes. A responsible person at a business was required to file,
quarterly, an Employer's Quarterly Federal Tax Return, Form 941 ("Form 941 "), reporting
certain information and assessing payroll taxes for the business and reporting certain
information, including the number of employees working at the business and the wages paid by
the business.
23.
A Wage and Tax Statement, Form W-2 ("Form W-2"), reported wages
paid by an employer to an employee and taxes withheld from those wages. It was issued by
United States employers to employees and filed by employers with the Social Security
Administration ("SSA").
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24.
A Schedule C was a form attached to an Individual Income Tax Return
and filed with the IRS on which the taxpayer reported, among other things, gross receipts,
expenses, and income or loss from a business the taxpayer operated as a sole proprietor.
25.
The Small Business Administration ("SBA") was an executive branch
agency of the United States government that provided support to entrepreneurs and small
businesses. The mission of the SBA was to maintain and strengthen the nation's economy by
enabling the establishment and viability of small businesses and by assisting in the economic
recovery of communities after disasters.
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26.
A tax return was a filing with the IRS which detailed the tax obligations of
the taxpayer or organization. Tax returns in the United States included, among others, Form 941
and Form 1040.
III.
The COVID-19 Pandemic in the United States and Related Tax Credits
27.
In or about December 2019, a novel coronavirus caused outbreaks of the
coronavirus disease COVID-19 that spread globally. On or about January 31, 2020, the
Secretary of the United States Department of Health and Human Services declared a national
public health emergency ur:ider Title 42, United States Code, Section 247d as a result of the
spread of COVID-19 to and within the United States. On or about March 13, 2020, the President
of the United States issued Proclamation 9994, declaring a national emergency beginning on or
about March 1, 2020, as a result of the rapid spread ofCOVID-19.
A.
Employee Retention Credits
28.
The Coronavirus Aid, Relief, and Economic Security Act ("CARES Act"),
enacted on March 27, 2020, provided for an employee retention credit ("ERC"), a refundable tax
credit, which was designed to encourage businesses to keep employees on their payroll during
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the COVID-19 pandemic. The Taxpayer Certainty and Disaster Tax Relief Act of 2020 and the
American Rescue Plan Act ("ARPA") modified and extended the ERC.
29.
For calendar year 2020, eligible employers were authorized to claim an
ERC offsetting certain employment taxes that could not exceed 50 percent of up to $10,000 of
qualified wages paid to each employee from March 13, 2020, through December 31, 2020. The
maximum ERC for 2020 was $5,000 per employee per quarter. For calendar year 2021, eligible
employers were authorized to claim an ERC offsetting certain employment taxes that could not
exceed 70 percent of up to $10,000 of qualified. wages paid to each employee during each
quarter. The maximum ERC for 2021 was $7,000 per employee per quarter.
30.
Generally, businesses and tax-exempt organizations that qualified for the
ERC were those that: (a) were shut down during 2020 or the first three calendar quarters of 2021
by government order due to the COVID-19 pandemic; (b) experienced a specified decline in
gross receipts during the eligibility periods-during 2020 or the first three calendar quarters of
2021; or (c) qualified as a recovery startup business for the third or fourth quarters of 2021.
31.
A recovery startup business was defined in Title 26, United States Code,
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Section 3 l 34(c)(5) as an employer (i) that began carrying on any trade or business after February
15, 2020, (ii) for which the average annual gross receipts of the employer for the three-taxable-
year period ending with the taxable year that precedes the calendar quarter for which the credit is
determined does not exceed $1,000,000, and (iii) that is not otherwise an eligible employer due
to a full or partial suspension of operations or a decline in gross receipts.
B.
Sick and Family Leave Wage Credits
32.
The Families First Coronavirus Response Act provided for eligible
employers to receive refundable tax credits for wages paid to employees while on sick leave to
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recover from any injury, disability, illness or condition resulting from COVID-19 or wages paid
to employees while on family leave to care for a family member who was injured, disabled, ill or
otherwise suffering from a condition due to COVID-19. Together these credits were called the
Sick and Family Leave Wage Credit ("SFLC," and together with the ERC, the "COVID-Related
Tax Credits").
33.
Under the SFLC, employers were entitled to receive a dollar-for-dollar
credit for qualified wages paid to an employee, plus allocable health plan expenses and the
employer's share of Medicare taxes, while that ~mployee was on sick leave ·resulting from
COVID-19. This credit was limited to ten days of sick leave per employee for the period ending
March 31, 2021. That resulted in a maximum credit of $5,110 per employee for that period. The
ARPA provided an identical credit for the period April 1, 2021 through September 30, 2021,
with the same maximum of $5, 110 in credits per employee.
34.
In addition, under the SFLC, employers were also entitled to receive a
credit of up to two-thirds of the qualified wages paid to an employee while that employee was on
family leave to care for a family member suffering from a condition resulting from COVID-19,
plus allocable health plan expenses and the employer's share of Medicare taxes. For the period
ending March 31, 2021, this credit was limited to $200 per day for up to ten weeks, resulting in a
maximum eligible credit of $10,000 per employee. The ARPA provided an identical credit for
the period April 1, 2021 through September 30, 2021, and extended the length of family leave to
twelve weeks, thereby raising the maximum eligible credit for that period to $12,000 per
employee.
35.
An employer claimed COVID-Related Tax Credits by filing a Form 941
with the IRS for the relevant quarter. The Form 941 required an employer to provide to the IRS
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information about the number of employees the business had and the wages paid by the business
during that quarter.
36.
The sa~e wages could not be claimed as both qualified sick leave wages
and qualified family leave wages. Employers were also not eligible to receive both the ERC and
SFLC with respect to the same wages.
C.
The Paycheck Protection Program
37.
The CARES Act also authorized up to $349 billion in forgivable loans to
small businesses for job retention and certain other expenses through a program referred to as the
Paycheck Protection Program ("PPP"). In or around April 2020, Congress authorized over $300
billion in additional PPP funding.
38. • To obtain a PPP loan, a qualifying business was required to submit a "PPP
Loan Application,'' which included an SBA Form 2483 - Borrower Application Form - and
supporting documentation. On the PPP Loan Application, an authorized representative of the
applying business was required to acknowledge the program rules and make certain affirmative
certifications to establish eligibility for the PPP loan. For example, on SBA Form 2483, the
recipient business, through an authorized representative, was required to state, among other
things, its average monthly payroll expenses and number of employees. These figures were used
to calculate the amount of money the business was eligible to receive under the PPP.
39.
The required supporting documentation for the SBA Form 2483 in the
PPP Loan Application frequently included, when the applicant was a sole proprietorship, the
most recent Schedule C, Profit or Loss from Business, filed by the owner of the business
attached to their Individual Income Tax Return.
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40.
The representative of the business who submitted the PPP Loan
Application was required to certify, on SBA Form 2483, that they understood that, should the
PPP funds be knowingly used for unauthorized purposes, the United States could pursue legal
remedies against the authorized representative, including charges of fraud.
41.
Recipient businesses were required to use PPP loan proceeds for certain
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permissible expenses, including, but not limited to, payroll costs, interest on mortgages, rent, and
utilities. The PPP provided that the principal and interest on a PPP loan would be entirely
forgiven if the recipient business spent the loan proceeds on these expense items within a
designated period of time after receiving the proceeds and used a certain percentage for payroll
costs.
42.
The SBA administered PPP loans. Individual PPP loans, however, were
issued and approved by private lenders, who received and processed PPP loan applications and
supporting documentation and, following SBA approval, made loans using the lenders' own
funds.
IV.
The Defendants' Fraudulent Covid-Related Tax Credits Scheme
43.
From in or about and between November 2021 and June 2023, the
defendants KEITH WILLIAMS, JANINE DA VIS, MORAIS DICKS, JAMES HAMES, JR.,
JAMARI LEWIS and LOUEWANDA BENJAMIN, together with others, orchestrated a scheme
to submit more than $600 million in fraudulent requests for COVID-Related Tax Credits
designed to help workers and businesses negatively impacted by the COVID-19 pandemic by
filing more than 8,000 false Forms 941. As a result of the scheme, the United States Treasury
disbursed approximately $45 million to the defendants, their co-conspirators and clients.
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to
44.
The defendants KEITH WILLIAMS, JANINE DAVIS, MORAIS DICKS,
JAMES HAMES, JR., JAMARI LEWIS and LOUEWANDA BENJAMIN and their co-
conspirators and clients were not entitled to the amount of COVID-Related Tax Credits or
resulting tax refunds claimed on the Forms 941 that the defendants and their co-conspirators
prepared and filed. The fraudulent tax returns (including Forms 941) filed by the defendants and
their co-conspirators claimed tax refunds based on falsely reported wages and benefits that the
defendants and their co-conspirators knew had not been paid.
45.
Many of the entities, including Company #1 through Company #22,
reported on the fraudulent Forms 941 that the defendants KEITH WILLIAMS, JANINE DA VIS,
MORAIS DICKS, JAMES HA,MES, JR., JAMARI LEWIS and LOUEWANDA BENJAMIN
and their co-conspirators prepared and filed, and caused to be prepared and filed, were not as
they were represented on the Forms 941. Contrary to the representations made in the Forms 941,
the entities were inactive, had no employees, had not made prior tax return filings, had no
physical business location and/or did not timely file Forms W-2 for wages paid to employees.
46.
Furthermore, nearly all the Forms 941 that the defendants KEITH
WILLIAMS, JANINE DAVIS, MORAIS DICKS, JAMES HAMES, JR., JAMARI LEWIS and
LOUEWANDA BENJAMIN and their co-conspirators prepared and filed, and caused to be
prepared and filed, fraudulently sought more refunds than the ERC or SFLC allowed. For
example, many of the Forms 941 that the defendants and their co-conspirators prepared and filed,
either: (i) claimed an SFLC in excess of the amount of wages reported; (ii) listed the same wages
as both qualified sick leave wages and qualified family leave wages; and/or (iii) claimed an
SFLC and ERC for the same wages. None of these were permitted under the prevailing legal
framework.
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4 7.
Although the defendants carried out their fraudulent scheme using a
number of different physical locations and entities, it was primarily operated out of Credit Reset,
which was owned and controlled by the defendant KEITH WILLIAMS. Many of the defendants
and their co-conspirators either worked at Credit Reset for WILLIAMS for portions of the
scheme or visited Credit Reset in furtherance of the scheme. At Credit Reset and at other
locations, including their residences, which were located in the Eastern District of New York and
elsewhere, WILLIAMS and the defendants JANINE DA VIS, MORAIS DICKS, JAMES
HAMES, JR., JAMARI LEWIS and LOUEWANDA BENJAMIN and others prepared and filed
false tax documents, including, but not limited to, false Forms 941 to obtain ERC or SFLC funds.
48.
The defendants KEITH WILLIAMS, JANINE DA VIS, MORAIS DICKS,
JAMES HAMES, JR., JAMARI LEWIS and LOUEWANDA BENJAMIN and others created a
series of different accounts with TPS, which they used to prepare and file false tax returns, and
some of which they shared with other co-conspirators.
49.
For example, between approximately May 2022 and February 2023, three
different TPS accounts controlled by the defendants KEITH WILLIAMS, JAMES HAMES, JR.
and JAMARI LEWIS and Co-Conspirator #2 were used to prepare and file 22 false Forms 941
for the benefit of Individual #2. The false filings made on behalf of Individual #2 were
purportedly on behalf of Company # 18, Company # 19 and Company #20 and claimed fraudulent
refunds totaling approximately $1.43 million. Each of these filings was fraudulent because,
among other things, they claimed SFLC and ERC for the same wages.
50.
Additionally, between approximately June 2022 and November 2022, a
TPS account controlled by the defendant KEITH WILLIAMS and a TPS account controlled by
the defendant JAMARI LEWIS were used to prepare and file, or attempted to prepare and file,
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nine false Forms 941 for the benefit of Individual #3. The false filings were purportedly on
behalf of Company #21 and Company #22 and claimed fraudulent refunds totaling
approximately $645,848. Each of these filings was fraudulent because, among other things, they
claimed SFLC and ERC for the same wages.
51.
Further, between approximately March 2022 and September 2022, a TPS
account controlled by the defendant KEITH WILLIAMS and a TPS account controlled by the
defendant JANINE DA VIS were used to prepare and file, or attempted to prepare and file, seven
false Forms 941 for the benefit of Individual #4. The false filings were purportedly on behalf of
Company #23 and claimed fraudulent refunds totaling approximately $287,173. Each of these
filings was fraudulent because, among other things, they claimed SFLC and ERC for the same
wages.
52.
In addition, between approximately September 2022 and March 2023, a
TPS account controlled by the defendant KEITH WILLIAMS and a TPS account controlled by
Co-Conspirator #2 were used to prepare and file 15 false Forms 941 for the benefit of Individual
#5. The false filings were purportedly on behalf of Company #24 and Company #25 and
claimed fraudulent refunds totaling approximately $778,172. Each of these filings was
fraudulent because, among other things, they claimed SFLC and ERC for the same wages.
53.
The defendants KEITH WILLIAMS, JANINE DA VIS, MORAIS DICKS,
JAMES HAMES, JR., JAMARI LEWIS and LOUEWANDA BENJAMIN and their co-
conspirators concealed their roles in the preparation of the false Forms 941 by, among other
things, not listing themselves on the returns as the paid preparer of the return as required and, at
times, using Virtual Private Networks ("VPNs") to obscure their computers' true Internet
Protocol address and location to connect to TPS.
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54.
The defendants KEITH WILLIAMS, JANINE DA VIS, MORAIS DICKS,
JAMES HAMES, JR., JAMARI LEWIS and LOUEWANDA BENJAMIN, their co-conspirators
and others profited from the scheme in several different ways. The defendants received tax
refunds, in the form of United States Treasury checks, based on false Forms 941 submitted for
one or more of their own purported companies. The defendants also profited by recruiting clients
to have false Forms 941 prepared by their co-conspirators and receiving a portion of the fee paid
by the client to the co-conspirator. Finally, the defendants charged clients a fee for initially
preparing the false Forms 941 and/or collected a percentage of the fraudulently obtained tax
refund as a fee.
55.
For example, on several occasions, after the defendant KEITH
WILLIAMS received a fee from a client or a United States Treasury check generated by a false
Form 941, WILLIAMS compensated the defendants JAMARI LEWIS, MORAIS DICKS and
JANINE DA VIS, Co-Conspirator #2 and Co-Conspirator #4, for their roles in obtatning the
fraudulent COVID-Related Tax Credits.
56.
To carry out the fraudulent scheme, the defendants and their co-
conspirators communicated using text messages, phone calls, and a WhatsApp group, among
other methods of communication. For example, on or about November 23, 2022, the defendant
KEITH WILLIAMS sent text-based messages to the defendant JAMES HAMES, JR. describing
the false statements that clients of the defendants and their co-conspirators should provide when
they called the IRS to check on the status of their tax refund. On or about November 27, 2022,
HAMES texted the instructions he received from WILLIAMS to Co-Conspirator #6.
57.
Form 941, on which the COVID-Related Tax Credits were claimed by the
defendants and their co-conspirators, required the taxpayer to have an Employer Identification
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Number ("EIN"), which is a nine-digit federal tax identification number assigned by the IRS for
businesses, tax-exempt organizations and other entities. If a prospective client did not have an
EIN, the defendants KEITH WILLIAMS, JANINE DA VIS, MORAIS DICKS, JAMES
HAMES, JR., JAMARI LEWIS and LOUEWANDA BENJAMIN, together with others,
sometimes provided the client with a business with an EIN or facilitated the client's purchase of
one to then be used to file Forms 941 claiming COVID-Related Tax Credits. Often, the entities
that the defendants provided to clients were shell companies or companies that were previously
operational businesses but were· no longer operating.
58.
On occasion, the IRS and SSA requested additional information regarding
the Forms 941 filed by the defendants KEITH WILLIAMS, JANINE DAVIS, MORAIS DICKS,
JAMES HAMES, JR., JAMARI LEWIS and LOUEWANDA BENJAMIN. When that
happened, the defendants and their co-conspirators transmitted and caused to be transmitted false
information to the IRS and prepared and filed with the SSA false Forms W-2 corresponding to
the previously filed false Forms 941. For example, in or about March 2022, LEWIS instructed
Co-Conspirator #5 to submit false information regarding Business #7 to the IRS in response to a
request for taxpayer information.
V.
The Defendants' Fraudulent PPP Loans
59.
From the onset of the COVID-19 pandemic, the defendants KEITH
WILLIAMS, JANINE DA VIS, MORAIS DICKS, JAMES HAMES, JR. and JAMARI LEWIS
also each fraudulently obtained government funds by filing and causing to be filed false PPP
loan applications requesting PPP loans for themselves.
60.
Among other things, in some instances, the defendants provided false
supporting documentation included with their PPP loan applications, including false tax forms
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15
representing, among other falsehoods, that wages were paid that were not paid to employees that
did not exist. Some of the false tax forms that were included in the PPP loan applications were
never filed with the IRS. The PPP loan applications themselves were also fraudulent in that in
some instances, the defendants represented that wages were paid that were not paid to employees
that did not exist.
COUNT ONE
(Conspiracy to Defraud the United States)
61.
The allegations contained in paragraphs one through 60 are realleged and
incorporated as if fully set forth in this paragraph.
62.
In or about and between November 2021 and June 2023, both dates being
approximate and inclusive, within the Eastern District ofNew York and elsewhere, the
defendants KEITH WILLIAMS, JANINE DA VIS, also known as "Holiday Davis," MORAIS
DICKS, JAMES HAMES, JR., also known as "Poppa J," JAMARI LEWIS, also known as "Mr.
Chaketah," and_ LOUEWANDA BENJAMIN, together with others, did knowingly and willfully
conspire to defraud the United States by impeding, impairing, obstructing and defeating the
lawful governmental functions of the IRS, specifically, the administration and distribution of
COVID-Related Tax Credits.
63.
In furtherance of the conspiracy and to effect its objects, within the
Eastern District of New York and elsewhere, the defendants KEITH WILLIAMS, JANINE
DA VIS, also known as "Holiday Davis," MORAIS DICKS, JAMES HAMES, JR., also known
as "Poppa J," JAMARI LEWIS, also known as "Mr. Chaketah," and LOUEWANDA
BENJAMIN, together with others, did commit and cause the commission of, among others, the
following:
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OVERT ACTS
(a)
On or about November 29, 2021, LEWIS directed Co-Conspirator
#1 to file a fraudulent Form 941 claiming an approximately $64,182 tax refund based on
COVID-19-Related Tax Credits for Chakeetah to which it was not entitled.
(b)
On or about January 28, 2022, WILLIAMS and LEWIS directed
Co-Conspirator #1 to file a fraudulent Form 941 claiming an approximately $115,632 tax refund
based on COVID-19-Related Tax Credits for 109 Super Store to which it was not entitled.
( c)
On or about March 18, 2022, DA VIS prepared and filed and
caused to be prepared and filed with the IRS a fraudulent Form 941 claiming an approximately
$54,976.14 tax refund based on COVID-19-Related Tax Credits for Holiday's Promise for which
it was not entitled.
(d)
On or about June 20, 2022, Co-Conspirator #2 caused to be
prepared and filed with the IRS a fraudulent Form 941 claiming an approximately $115,992.14
tax refund based on COVID-19-Related Tax Credits for Company #2 for which it was not
entitled.
(e)
On or about June 23, 2022, HAMES prepared and filed and caused
to be prepared and filed with the IRS a fraudulent Form 941 claiming an approximately
$71,875.94 tax refund based on COVID-19-Related Tax Credits for Company #12 for which it
was not entitled.
(f)
On or about July 14, 2022, WILLIAMS prepared and filed and
caused to be prepared and filed with the I.RS a fraudulent Form 941 claiming an approximately
$57,816.22 tax refund based on COVID-19-Related Tax Credits for Company #6, for which it
was not entitled.
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(g)
On or about September 30, 2022, LEWIS prepared and filed and
caused to be prepared and filed with the IRS a fraudulent Form 941 claiming an approximately
$67,092.02 tax refund based on COVID-19-Related Tax Credits for Chakeetah for which it was
not entitled.
(h)
On or about October 22, 2022, LEWIS and Co-Conspirator #5
prepared and filed and caused to be prepared and filed with the IRS a fraudulent Form 941
claiming an approximately $73,970.67 tax refund based on COVID-19-Related Tax Credits for
Company #7 for which it was not entitled.
(i)
On or about January 5, 2023, DICKS directed Individual #1, who
just days prior had received over $200,000 in tax refund.checks as a result of false Forms 941
prepared and filed by the defendants and their co-conspirators, to write a check for $100,000 to
Progressive Homes.
G)
In or around April 2022, BENJAMIN assisted in transferring
inactive corporate entities to members of the conspiracy for the purpose of filing fraudulent
claims for COVID-19-Related Tax Credits.
(Title 18, United States Code, Sections 371 and 3551 et seq.)
COUNTS TWO THROUGH SEVEN
(Wire Fraud)
64.
The allegations contained in paragraphs one through 60 are realleged and
incorporated as if fully set forth in this paragraph.
65.
On or about the dates set forth below, within the Eastern District of New
York and elsewhere, the defendant KEITH WILLIAMS, together with others, did knowingly and
intentionally devise a scheme and artifice to defraud the IRS and to obtain money and property
from the IRS by means of materially false and fraudulent pretenses, representations and
Case 2:25-cr-00020-GRB Document 85 Filed 11/12/25 Page 17 of 32 PageID #: 396
18
promises, and for the purpose of executing such scheme and artifice did transmit and cause to be
transmitted by means of wire communication in interstate and foreign commerce, writings, signs,
signals, pictures and sounds, to wit: the fol lowing Forms 941, all of which were electronically
fi led with the IRS.
..
Count
TWO
THREE
FOUR
FIVE
SIX
SEVEN
ApJ.jo.Jo~imate
-
11
- ·-
-
·-
II
I
ate
Description ofi Wire Transmission,
A Form 941 for 2021 4th Quarter for l 09 Super Store claiming
1/28/2022
a tax refund of approximately $1 15,632.
A Form 941 for 2021 I st Qua1ter for Lucky 13 claiming a tax
1/3 1/2022
refund of aooroximately $76,0 12.
A Form 941 for 2022 I st Quarter for I 09 Super Store claiming a
5/30/2022
tax refund of approximately $6 1,230.5 I.
A Form 941 for 2022 2nd Quarter for Babylon Buyers claiming
6/30/2022
a tax refund of approximately $63,948.22.
A Form 94 1 for 2022 3rd Quarter for Babylon Buyers claiming
I 0/ 19/2022
a tax refund of approximately $63,948.35.
A Form 94 1 for 2022 2nd Quatter for Lucky 13 claiming a tax
I 0/ 19/2022
refund of approximately $66,576.28.
(Title 18, United States Code, Sections 1343, 2 and 355 1 et seq.)
COUNTS EIGHT THROUGH TEN
(Wire Fraud)
66.
The allegations contained in paragraphs one through 60 are realleged and
incorporated as if fully set forth in this paragraph.
67.
On or about the dates set forth below, within the Eastern District of New
York and elsewhere, the defendant JAMARI LEWIS, also known as "Mr. Chaketah," together
with others, did knowingly and intentionally devise a scheme and artifice to defraud the IRS and
to obtain money and property from the IRS by means of materially false and fraudulent
pretenses, representations and promises, and for the purpose of executing such scheme and
artifice did transmit and cause to be transmitted by means of wire communication in interstate
Case 2:25-cr-00020-GRB Document 85 Filed 11/12/25 Page 18 of 32 PageID #: 397
19
and foreign commerce, writings, signs, signals, pictures and sounds, to wit, the following Forms
941, all of which were electronically filed with the IRS:
Count
EIGHT
NINE
TEN
Approximate
Date
II
Desc'ription
A Form 941 for 2020 2nd Quarter for Chakeetah claiming a
11 /29/2021
tax refund of aooroximatelv $64,182.
A Form 941 for 2021 3rd Quarter for Chakeetah claiming a tax
12/3/2021
refund of aooroximatelv $68,646.97.
A Form 941 for 202 1 2nd Quarter for Chakeetah claiming a
12/4/2021
tax refund of aporoximatelv $85,897.80.
(Title 18, United States Code, Sections 1343, 2 and 3551 et filill.)
COUNTS ELEVEN THROUGH SIXTEEN
(Wire Fraud)
68.
The allegations contained in paragraphs one through 60 are realleged and
incorporated as if fully set forth in this paragraph.
69.
On or about the dates set forth below, within the Eastern District of New
York and elsewhere, the defendant JANINE DA VIS, also known as "Holiday Davis," together
with others, did knowingly and intentionally devise a scheme and artifice to defraud the IRS and
to obtain money and property from the IRS by means of materially false and fraudulent
pretenses, representations and promises, and for the purpose of executing such scheme and
artifice did transmit and cause to be transmitted by means of wire communication in interstate
and foreign commerce, writings, signs, signals, pictures and sounds, to wit, the following Forms
941, all of which were electronically filed with the IRS:
Approximate
"<f::ount
Date
Descrintion,
A form 941 for 2020 2nd Quarter for Holiday's Promise
ELEVEN
3/ 18/2022
claiming a tax refund of approximately $54,976.14.
A Form 941 for 2021 I st Quarter for 7 Port claiming a
TWELVE
5/30/2022
tax refund of approximately $235,084.68.
Case 2:25-cr-00020-GRB Document 85 Filed 11/12/25 Page 19 of 32 PageID #: 398
20
-
- -
Count
THIRTEEN
FOURTEEN
FIFTEEN
SIXTEEN
• Approximate
Date
Description
A Form 941 for 2021 2nd Quarter for 7 Port claiming a
5/30/2022
tax refund of approximately $255,192.60.
A Form 941 for 2021 4th Quarter for Holiday's Promise
6/2/2022
claiming a tax refund of approximately $217,376.71.
A Form 941 for 202 1 3rd Quarter for Janine Davis (sole
proprietorship) claiming a tax refund of approximately
6/2/2022
$ I 45,007.90.
A Form 94 1 for 2020 3rd Quarter for Janine Davis (sole
proprietorship) claiming a tax refund of approximately
6/2/2022
$66,390.90.
(Title 18, United States Code, Sections 1343, 2 and 3551 et seq.)
COUNTS SEVENTEEN THROUGH NINETEEN
(Wire Fraud)
70.
The allegations contained in paragraphs one through 60 are realleged and
incorporated as if fully set forth in this paragraph.
71.
On or about the dates set fo1t h below, within the Eastern District of New
York and elsewhere, the defendant JAMES HAMES, JR., also known as "Poppa J," together
with others, did knowingly and intentionally devise a scheme and artifice to defraud the IRS and
to obtain money and property from the IRS by means of materially false and fraudulent
pretenses, representations and promises, and for the purpose of executing such scheme and
artifice did transmit and cause to be transmitted by means of wire communication in interstate
and foreign commerce, writings, signs, signals, pictures and sounds, to wit, the following Forms
941, all of which were electronically filed with the IRS:
Count
11
.
D
~ pprox1mate ate
Description
A Form 941 for 2022 I st Quarter for MJR claiming a
SEVENTEEN
6/ 15/2022
tax refund of approximately $75,358.3 1.
A Form 941 for 2022 3rd Quarter for MJR claiming a
EIGHTEEN
I 0/24/2022
tax refund of approximately $71,658.75.
Case 2:25-cr-00020-GRB Document 85 Filed 11/12/25 Page 20 of 32 PageID #: 399
Count
NINETEEN
-
.. ,.
Approximate Bate
Descr~ption
A Form 94 1 for 2022 4th Quarter for MJR claiming a
1/ 16/2023
tax refund of aooroximately $78,496.0 I.
(Title 18, United States Code, Sections 1343, 2 and 3551 et~-)
COUNTS TWENTY THROUGH TWENTY-TWO
(Wire Fraud)
21
I 03.
The allegations contained in paragraphs one through 60 are realleged and
incorporated as if fully set fo1th in this paragraph.
104.
On or about the dates set forth below, within the Eastern District of New
York and elsewhere, the defendant LOUEWANDA BENJAMIN, together with others, did
knowingly and intentionally devise a scheme and artifice to defraud the IRS and to obtain money
and property from the IRS by means of materially false and fraudulent pretenses, representations
and promises, and for the purpose of executing such scheme and artifice did transmit and cause
to be transmitted by means of wire communication in interstate and foreign commerce, writings,
signs, signals, pictures and sounds, to wit, the fo llowing Forms 941, all of which were
electronically filed with the IRS:
Approximate
I
II
Count
Date
Desclliption
A Form 941 for 2020 2nd Quarter for LBA claiming a tax
TWENTY
5/2/2023
refund of aooroximatelv $55,228.62
TWENTY-
A Form 941 for 2021 3rd Quarter for LBA claiming a tax
ONE
5/2/2023
refund of aooroximatelv $52 011.44.
TWENTY-
A Form 941 for 2021 4th Quarter for LBA claiming a tax
TWO
5/2/2023
refund of aooroximately $56,263.02.
(Title 18, United States Code, Sections 1343, 2 and 3551 et~-)
Case 2:25-cr-00020-GRB Document 85 Filed 11/12/25 Page 21 of 32 PageID #: 400
COUNTS TWENTY-THREE THROUGH TWENTY-EIGHT
(Aiding and Assisting in the Preparation of False Tax Returns)
22
83.
The allegations contained in paragraphs one through 60 are realleged and
incorporated as if fully set forth in this paragraph.
84.
On or about the dates set fo1ih below, within the Eastern District of New
York, and elsewhere, the defendant KEITH WILLIAMS willfully aided and assisted in, and
procured, counseled, and advised the preparation and presentation to the I RS of a Form 941 ,
Employer's Quarterly Federal Tax Returns, for each of the periods stated below, which were
false and fraudulent as to one or more material matters, and which WILLIAMS did not believe to
be true and correct as to every material matter:
~,ntitv
1'a:xi
Count
Periiod
Approx. Date
False Items
• Line 1, number of employees;
• Line 2, wages, tips, and other
compensation;
• Line 13e, Total deposits and
TWENTY-
2021 I st
refundable credits.
THREE
Company #7
Quarter
1/3 1/2022
• Line 15, Overpayment
• Line 2, wages, tips, and other
compensation;
• Line 13e, Total deposits,
TWENTY-
2020 2nd
deferrals, and refundable credits.
FOUR
Company # I
Quarter
2/1/2022
• Line 15, Overpayment
• Line I, number of employees;
• Line 2, wages, tips, and other
compensation;
• Line 13g, Total deposits and
TWENTY-
2021 3rd
refundable credits.
FIVE
Company #5
Quarter
3/26/2022
• Line 15, Overpayment
• Line 1, number of employees;
• Line 2, wages, tips, and other
compensation;
• Line 13g, Total deposits and
TWENTY-
2021 4th
refundable credits.
SIX
Company #4
Quarter
4/18/2022
• Line 15, Overpayment
-
Case 2:25-cr-00020-GRB Document 85 Filed 11/12/25 Page 22 of 32 PageID #: 401
II
Tax
Count
Entitv
Period
Approx. Date
False Items
• Line I, number of employees;
• Line 2, wages, tips, and other
compensation;
• Line 13e, Total deposits and
TWENTY-
2021 I st
refundable credits.
SEVEN
Company #2
Quarter
6/20/2022
• Line 15, Overpayment
• Line I, number of employees;
• Line 2, wages, tips, and other
compensation;
• Line 13g, Total deposits and
TWENTY-
2022 2nd
refundable credits.
EIGHT
Company #6
Quarter
7/ 14/2022
• Line 15, Overpayment
(Title 26, United States Code, Section 7206(2); Title 18, United States Code,
Sections 3551 et~-)
COUNTS TWENTY-NINE THROUGH THIRTY-SEVEN
(Aiding and Assisting in the Preparation of False Tax Returns)
23
87.
The allegations contained in paragraphs one through 60 are realleged and
incorporated as if fully set forth in this paragraph.
88.
On or about the dates set forth below, within the Eastern District of New
York, and elsewhere, the defendant JAMES HAMES, JR., also known as "Poppa J," willfully
aided and assisted in, and procured, counseled, and advised the preparation and presentation to
the IRS of a Form 941, Employer's Quarterly Federal Tax Returns, for each of the periods stated
below, which were false and fraudulent as to one or more material matters, and which HAMES
did not believe to be true and correct as to every material matter:
-
Tax
Approx.
Count
Entitv
Period
Date
False Items
• Line 2, wages, tips, and other
compensation;
• Line 13e, Total deposits,
deferrals, and refundable
TWENTY-
2020 2nd
credits.
NINE
Company #8
Quarter
6/23/2022
• Line 15, Overpayment
Case 2:25-cr-00020-GRB Document 85 Filed 11/12/25 Page 23 of 32 PageID #: 402
24
liE
J
·itv
-
'Fax
A,ppriox.
- - -
Count
nt1
Period
Date
False Items
• Line 1, number of employees;
• Line 2, wages, tips, and other
compensation;
• Line 13e, Total deposits and
2020 2nd
refundable credits.
THIRTY
Company #9
Quarter
6/23/2022
• Line 15, Overpayment
• Line I, number of employees;
• Line 2, wages, tips, and other
compensation;
• Line 13g, Total deposits and
THIRTY-
2021 4th
refundable credits.
ONE
Company #10
Qua1ter
6/24/2022
• Line 15, Overpayment
• Line 1, number of employees;
• Line 2, wages, tips, and other
compensation;
• Line 13g, Total deposits and
THIRTY-
202 1 3rd
refundable credits.
TWO
Company #14
Quarter
6/26/2022
• Line 15, Overpayment
• Line 1, number of employees;
• Line 2, wages, tips, and other
compensation;
• Line 13e, Total deposits and
THIRTY-
2021 I st
refundable credits.
THREE
Company #13
Quarter
6/26/2022
• Line 15, Overpayment
• Line I, number of employees;
• Line 2, wages, tips, and other
compensation;
• Line 13g, Total deposits and
THIRTY-
2022 I st
refundable credits.
FOUR
Company #12
Quarter
6/26/2022
• Line 15, Overpayment
• Line I, number of employees;
• Line 2, wages, tips, and other
compensation;
• Line 13g, Total deposits and
THIRTY-
202 1 2nd
refundable credits.
FIVE
Company #I 5
Quarter
6/26/2022
• Line 15, Overpayment
• Line 1, number of employees;
•
Line 2, wages, tips, and other
compensation;
• Line 13g, Total deposits and
THIRTY-
2021 2nd
refundable credits.
SIX
Company #16
Quarter
7/4/2022
• Line 15, Overpayment
Case 2:25-cr-00020-GRB Document 85 Filed 11/12/25 Page 24 of 32 PageID #: 403
25
-
Tax
Approx.
-
-~
.,-
Count
Entity
Period
Date
False Items
• Line I, number of employees;
• Line 2, wages, tips, and other
compensation;
• Line 13g, Total deposits and
THIRTY-
2022 4th
refundable credits.
SEVEN
Company #1 I
Quarter
1/22/2023
• Line 15, Overpayment
(Title 26, United States Code, Section 7206(2); Title 18, United States Code,
Sections 355 1 et~-)
COUNTS THIRTY-EIGHT THROUGH FORTY
(Aiding and Assisting in the Preparation of False Tax Returns)
89.
The allegations contained in paragraphs one through 60 are realleged and
incorporated as if fully set forth in this paragraph.
90.
On or about the dates set forth below, within the Eastern District of New
York, and elsewhere, the defendant MORAIS DICKS, willfu lly aided and assisted in, and
procured, counseled, and advised the preparation and presentation to the I RS of a Form 941,
Employer's Quarterly Federal Tax Returns for each of the periods stated below, which were false
and fraudulent as to one or more material matters, and which DICKS did not believe to be true
and correct as to every material matter:
Tax
Appr,ox.
Count
Entitv
Period
Date
False 'Items
• Line I, number of employees;
• Line 2, wages, tips, and other
compensation;
• Line 13g, Total deposits and
THIRTY-
2021 3rd
refundable credits
EIGHT
Company #17
Quarter
11/ 10/2022
• Line 15, Overoavment
• Line I, number of employees;
• Line 2, wages, tips, and other
compensation;
• Line 13g, Total deposits and
THIRTY-
2021 4th
refundable credits
NINE
Company #17
Quarter
11/ 10/2022
• Line 15, Overpayment
Case 2:25-cr-00020-GRB Document 85 Filed 11/12/25 Page 25 of 32 PageID #: 404
~ ntitv
Tax
Approx.
Count
Period
Date
False Items
• Line I, number of employees;
• Line 2, wages, tips, and other
compensation;
•
Line 13g, Total deposits and
2022 1st
refundable credits
FORTY
Company #17
Quarter
11/ 10/2022
• Line 15, Overpayment
(Title 26, United States Code, Section 7206(2); Title 18, United States Code,
Sections 355 1 et gg.)
COUNTS FORTY-ONE THROUGH FORTY-FOUR
(Wire Fraud)
26
91.
The allegations contained in paragraphs one through 60 are realleged and
incorporated as if ful ly set forth in this paragraph.
92.
On or about the following dates, within the Eastern District of New York
and elsewhere, the defendant KEITH WILLIAMS, together with others, did knowingly and
intentionally devise a scheme and artifice to defraud the SBA and one or more financial
institutions administering the PPP program, and to obtain money and property from the SBA and
said financial institutions by means of materially false and fraudulent pretenses, representations
and promises, and for the purpose of executing such scheme and artifice did transmit and cause
to be transmitted, by means of wire communication in interstate and foreign commerce, one or
more writings, signs, signals, pictures and sounds, to wit:
Count
A'
J
oprox. Date
-
-
- -
-
Desc11iption
A PPP loan application filed for KEITH WILLIAMS (sole
FORTY-
proprietorship) requesting a PPP loan of approximately
ONE
4/15/2021
$20,833.
A PPP loan application filed for KEITH WILLIAMS (sole
FORTY-
proprietorship) requesting a PPP loan of approximately
TWO
5/7/2021
$20,833.
Case 2:25-cr-00020-GRB Document 85 Filed 11/12/25 Page 26 of 32 PageID #: 405
Count
FORTY-
THREE
FORTY-
FOUR
Approx. Date
-
- ..
Description
A PPP loan application filed for Co-Conspirator #2 (sole
proprietorship) requesting a PPP loan of approximately
4/ 18/2021
$20,833.
A PPP loan application filed for Co-Conspirator #2 (sole
proprietorship) requesting a PPP loan of approximately
5/5/2021
$20,833.
(Title 18, United States Code, Sections 1343, 2 and 355 1 et ~-)
COUNT FORTY-FIVE
(Wire Fraud)
27
93.
The allegations contained in paragraphs one through 60 are realleged and
incorporated as if fully set forth in this paragraph.
94.
On or about March 18, 2021, within the Eastern District of New York and
elsewhere, defendant JAMAR) LEWIS, also known as "Mr. Chaketah," together with others, did
knowingly and intentionally devise a scheme and artifice to defraud the SBA and one or more
financial institutions administering the PPP program, and to obtain money and property from the
SBA and said financial institutions by means of materially false and fraudulent pretenses,
representations and promises, and for the purpose of executing such scheme and artifice, did
transmit and cause to be transmitted by means of wire communication in interstate and foreign
commerce, one or more writings, signs, signals, pictures and sounds, to wit: a March 18, 2021
PPP loan application fi led for JAMAR! LEWIS (sole proprietorship) requesting a PPP loan of
approximately $20,750.
(Title 18, United States Code, Sections 1343 and 3551 et seq.).
COUNT FORTY-SIX
(Wire Fraud)
95.
The allegations contained in paragraphs one through 60 are realleged and
incorporated as if fully set forth in this paragraph.
Case 2:25-cr-00020-GRB Document 85 Filed 11/12/25 Page 27 of 32 PageID #: 406
28
96.
On or about April 16, 2021, within the Eastern District of New York and
elsewhere, defendant JANINE DA VIS, also known as "Holiday Davis," together with others, did
knowingly and intentionally devise a scheme and artifice to defraud the SBA and one or more
financial institutions administering the PPP program, and to obtain money and property from the
SBA and said financial institutions by means of materially false and fraudulent pretenses,
representations and promises, and for the purpose of executing such scheme and artifice, did
transmit and cause to be transmitted by means of wire communication in interstate and foreign
commerce, one or more writings, signs, signals, pictures and sounds, to wit: an April 16, 2021
PPP loan application filed for JANINE DAVIS (sole proprietorship) requesting a PPP loan of
approximately $20,833.
(Title 18, United States Code, Sections 1343, 2 and 3551 et seq.)
COUNTS FORTY-SEVEN THROUGH FORTY-EIGHT
(Wire Fraud)
97.
The allegations contained in paragraphs one through 60 are realleged and
incorporated as if fully set forth in this paragraph.
98.
On or about the following dates, within the Eastern District ofNew York
and elsewhere, the defendant MORAIS DICKS, together with others, did knowingly and
intentionally devise a scheme and artifice to defraud the SBA and one or more financial
institutions administering the PPP program, and to obtain money and property from the SBA and
said financial institutions by means of materially false and fraudulent pretenses, representations
and promises, and for the purpose of executing such scheme and artifice did transmit and cause
to be transmitted by means of wire communication in interstate and foreign commerce, one or
more writings, signs, signals, pictures and sounds, to wit:
Case 2:25-cr-00020-GRB Document 85 Filed 11/12/25 Page 28 of 32 PageID #: 407
Count
I
FORTY-
SEVEN
FORTY-
EIGHT
-
-
Description • -
Approx. Date
I
A PPP loan application filed for Progressive Homes
5/ 19/2020
requesting a PPP loan of approximately $20,832.
A PPP loan application file for Service Advisors
6/3/2020
requesting a PPP loan of approximately $20,833.
(Title 18, United States Code, Sections 1343, 2 and 355 1 et~.)
CRIMINAL FORFEITURE ALLEGATION
AS TO COUNTS TWO THROUGH TWENTY-TWO
29
-
I 05.
The United States hereby gives notice to the defendants that, upon their
conviction of any of the offenses charged in Counts Two through Twenty-Two, the government
wi 11 seek forfeiture in accordance with Title 18, United States Code, Section 981 (a)( I )(C) and
Title 28, United States Code, Section 2461 (c), which require any person convicted of such
offenses to forfeit any property, real or personal, constituting, or derived from, proceeds obtained
directly or indirectly as a result of such offenses.
I 06.
If any of the above-described forfeitable property, as a result of any act or
omission of the defendants:
(a)
cannot be located upon the exercise of due diligence;
(b)
has been transferred or sold to, or deposited with, a third party;
(c)
has been placed beyond the jurisdiction of the cou1t;
(d)
has been substantially diminished in value; or
(e)
has been commingled with other property which cannot be divided
without difficulty;
Case 2:25-cr-00020-GRB Document 85 Filed 11/12/25 Page 29 of 32 PageID #: 408
30
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to
seek forfeiture of any other property of the defendants up to the value of the forfeitable property
described in this forfeiture allegation.
{Title 18, United States Code, Section 981 (a)(l ){C); Title 21, United States Code,
Section 853(p); Title 28, United States Code, Section 2461(c))
CRIMINAL FORFEITURE ALLEGATION
AS TO COUNTS FORTY-ONE THROUGH FORTY-EIGHT
107.
The United States hereby gives notice to the defendants charged in Counts
Forty-One through Forty-Eight that, upon their conviction any of such offenses, the government
will seek forfeiture in accordance with Title 18, United States Code, Section 982(a)(2), which
requires any person convicted of such offenses, to forfeit any property constituting, or derived
from, proceeds obtained directly or indirectly as a result of such offenses.
108.
If any of the above-described forfeitable property, as a result of any act or
omission of the defendants:
(a)
cannot be located upon the exercise of due diligence;
(b)
has been transferred or sold to, or deposited with, a third 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;
Case 2:25-cr-00020-GRB Document 85 Filed 11/12/25 Page 30 of 32 PageID #: 409
31
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), as
incorporated by Title 18, United States Code, Section 982(b)(I ), to seek forfeiture of any other
property of the defendants up to the value of the forfeitable property described in this forfeiture
allegation.
(Title 18, United States Code, Sections 982(a)(2) and 982(b)()); Title 21, United
States Code, Section 853(p))
A TRUE BILL
/s/
-~~RSON
9. oa.w.:d,"dzk/4 A~tl.S. At::t»
•
;{ JOSEPH NOCELLA, JR.
7
UNITED STATES ATTORNEY
EASTERN DISTRICT OF NEW YORK
Case 2:25-cr-00020-GRB Document 85 Filed 11/12/25 Page 31 of 32 PageID #: 410
INFORMATION SHEET
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
1.
Title of Case: United States v. Keith Williams, et al.
2.
Related Magistrate Docket Number(s): =25;;_-..=..;.M.;;;.::;J__;-1:;;..;;.9..;;;;;;2;...>,(;a...;;A=-RL=----) _________ _
3.
Arrest Date: 1/2212025 for all defendants other than Benjamin; 911712025 for Benjamin
4.
Nature of offense(s):
IZl
Felony
□ Misdemeanor
5.
Related Cases - Title and Docket No(s). (Pursuant to Rule 50.3.2 of the Local E.D.N.Y.
Division of Business Rules): ____________________ _
6.
Projected Length of Trial:
Less than 6 weeks
~
More than 6 weeks
□
7.
County in which crime was allegedly committed:N
--"""""as""-s"""""au ___________ _
(Pursuant to Rule 50.l(d) of the Local E.D.N.Y. Division of Business Rules)
8.
Was any aspect of the investigation, inquiry and prosecution giving rise to the case
9.
10.
pending or initiated before March 10, 2012. 1
□ Yes IZl No
Has this indictment/information been ordered sealed?
□ Yes
~ No
Have arrest warrants been ordered?
□ Yes IZl No
11.
Is there a capital count included in the indictment?
□ Yes IZl No
FILED
IN CLERK'S OFFICE
U.S. DISTRICT COURT E.D.N.Y.
* NOV 12 2025 *
LONG ISLAND OFFICE
JOSEPH NOCELLA, JR.
United States Attorney
By:
Isl James R. Simmons
Adam R. Toporovsky
James R. Simmons
Assistant U.S. Attorneys
James.Simmons@usdoj.gov
718-254-7511
Judge Brodie will not accept cases that were initiated before March 10, 2012.
Rev. 1/11/25
Case 2:25-cr-00020-GRB Document 85 Filed 11/12/25 Page 32 of 32 PageID #: 411