Indictment — United States v. Tyesha Bowman (Northern District of Illinois)

Summary

An indictment filed July 22, 2025 as Document 3 in United States of America versus Tyesha Bowman, Libra Martin, Lamont Foster, Khadijah Brown and Sieta Carrington, Case 3:25-cr-50036, in the United States District Court for the Northern District of Illinois, Western Division. The SPECIAL MARCH 2024 GRAND JURY charges violations of Title 18, United States Code, Sections 1341 and 1343. It alleges that Tyesha Bowman and Libra Martin submitted over 25 PPP and EIDL applications with false statements about employees, revenues and payroll, for the purpose of obtaining over $500,000, including applications to Benworth Capital Partners, LLC and Harvest Small Business Finance, LLC. The forfeiture allegation seeks a personal money judgment estimated to be over $500,000.

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Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 1 of “EVLED

JUL 2 2 2025
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS — tyomas G. BRUTON

WESTERN DIVISION CLERK, U.S. DISTRICT COURT
UNITED STATES OF AMERICA
Violations: Title 18, United States
TYESHA BOWMAN, Code, Sections 1341, 1343
LIBRA MARTIN, a .
LAMONT FOSTER, | SUDGE JOHNSTON
KHADIJAH BROWN, and
SIETA CARRINGTON

Magistrate Judge Schneider
COUNTS ONE THROUGH SIXTEEN

The SPECIAL MARCH 2024 GRAND JURY charges that:
1. At times material to this indictment:
The Small Business Administration
a. The U.S. Small Business Administration (“SBA”) was a United
States government agency that provided economic support to small businesses.
The Paycheck Protection Program
b. The Coronavirus Aid, Relief, and Economic Security (“CARES”)
Act was a federal law enacted in or around March 2020 and designed to provide
emergency financial assistance to the millions of Americans who were suffering the
economic effects caused by the COVID-19 pandemic.
c. One source of relief provided by the CARES Act was the
authorization of up to $349 billion in forgivable loans to small businesses and sole

proprietors for job retention and certain other expenses, through a program called
Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 2 of 26 PagelD #:29

the Paycheck Protection Program (“PPP”). Congress subsequently authorized an
additional $465 billion in funding for PPP loans, for a total of about $814 billion.

d. To obtain a PPP loan, a business, sole proprietor, or self-employed
individual submitted a PPP loan application (SBA Form 2483), which was signed by
the applicant or an authorized representative of the business. The PPP loan
application required the applicants to acknowledge the program rules and make
certain affirmative certifications regarding the eligibility of the business,
proprietorship, or individual. In the application, businesses, sole proprietors, and
self-employed individuals were required to provide, among other things, their number
of employees and average monthly payroll. This figure was used to calculate the
applicant’s eligibility and the amount of money the business, sole proprietor, or self-
employed individual could receive under the PPP. Applicants were also required to
make good faith certifications, including that the business entity was in operation on
February 15, 2020, and that economic uncertainties had necessitated their loan
requests for continued business operations.

e. To gain access to funds through the PPP, businesses, sole
proprietorships, and self-employed individuals applied to lenders participating in the
PPP and, if approved, received the loans from those lenders, either directly or through
loan service providers, and the loans were 100% guaranteed by the SBA.

f. PPP loan proceeds were required to be used by the business, sole

proprietorship, or self-employed individual for certain permissible expenses—payroll
Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 3 of 26 PagelD #:30

costs, interest on mortgages, rent, utilities, and a limited amount of income paid to
the owner. The PPP allowed the interest and principal on the PPP loan to be entirely
forgiven by the SBA if the business, sole proprietorship, or self-employed individual
spent the loan proceeds on these items within a designated period of time and used
at least a certain percentage of the PPP loan for payroll expenses.

g. Participating lenders, loan service providers, and the SBA
required applicants for PPP loans to provide truthful information about the sole
proprietorship, self-employed individual, or business and its owner, including
truthful information about the applicant’s payroll, income, operating expenses, and
how the PPP loan would be used, which information was material to (i) lenders’
approval, terms, and funding of loans and (ii) the SBA’s decision to guarantee and to
forgive the loans.

The Economic Injury Disaster Loan Program

h. Another source of relief provided by the CARES Act and other
pandemic-relief legislation was the expansion of the Economic Injury Disaster Loan
(“EIDL”) Program, which provided loan assistance (including advances of up to
$10,000) for businesses with 500 or fewer employees and other eligible entities. The
EIDL Program was designed to provide economic relief to small businesses that were
experiencing a temporary loss of revenue.

i. To gain access to funds through the EIDL Program, small

businesses applied through the SBA via an online portal and application. As part of
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the EIDL application process, the SBA required applicants to submit truthful
information about the applying entity, its owner, and its financial condition prior to
the COVID-19 pandemic. This information included the entity's number of employees
as of January 31, 2020; the entity’s gross revenues and cost of goods sold for the 12-
month period prior to January 31, 2020; and the entity’s type of business (i.e., a
business, an agricultural business, a sole proprietorship, a cooperative, among
others); the date on which the business opened; and the date on which the current
owner assumed ownership of the entity. Applicants were required to electronically
certify that the information provided in the application was true and correct and were
warned that a false statement or misrepresentation to the SBA may result in
sanctions, including criminal penalties.

j. The SBA required applicants for EIDL loans to provide truthful
information about the sole proprietorship, self-employed individual, or business and
its owner, including truthful information about the applicant’s number of employees,
costs of goods sold, and gross revenue, which information was material to the SBA’s
approval, terms, and funding of loans.

k, EIDL loan applications were submitted directly to and processed
by the SBA, and funds were issued to small-business applicants directly from the
United States Treasury through the SBA. |

lL. EIDL Advance was a grant program offered together with the

EIDL Program. EIDL Advance was designed to provide emergency economic relief to
Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 5 of 26 PagelD #:32

businesses that were experiencing a temporary loss of revenue as a result of the
COVID-19 pandemic. The applicant could request consideration for an EIDL advance
in an application for an EIDL loan. The amount of the advance issued to the small-
business applicant was determined by the number of employees indicated on the
EIDL application, at $1,000 per employee, up to $10,000. The number of employees
reported by the business was material to the SBA’s funding of an EIDL Advance and
determination of the amount of the EIDL Advance. If an EIDL advance was issued,
the advance did not need to be repaid.

m. Ifan EIDL application was approved by the SBA, the amount of
the EIDL loan was determined in part based on the statements in the EIDL
application about the entity’s revenues and cost of goods sold for the 12 months prior
to January 31, 2020.

n. EIDL loan funds could be used to pay for the ordinary operating
expenses and debts of the entity, including payroll, sick leave, production costs,
utilities, rent, mortgage payments, continuation of health care benefits, and fixed
debt payments.

Defendants

O. Defendant TYESHA BOWMAN was a resident of Rockford,

Illinois and Janesville, Wisconsin. TYESHA BOWMAN was the owner and registered

agent of FlyGirlWigs and Customs, LLC, an Illinois limited liability company
Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 6 of 26 PagelD #:33

registered on or about June 23, 2020. TYESHA BOWMAN had a Facebook page in
the name of “Ninha Brown.”

p. Defendant LIBRA MARTIN was a resident of Rockford, Illinois.
LIBRA MARTIN had a Facebook page in the name of “Libra Martin.”

q. Defendant LAMONT FOSTER was a resident of Rockford,
Illinois. LAMONT FOSTER had a Facebook page in the name of “Lito Foster.”

r. Defendant KHADIJAH BROWN was a resident of Rockford,
Illinois. KHADIJAH BROWN had a Facebook page in the name of “Khadijah
Singleton.”

s. Defendant SIETA CARRINGTON was a resident of Rockford,
Illinois. SIETA CARRINGTON had a Facebook page in the name of “Nalla
Carrington.”

Lenders

t. Lender A (Benworth Capital Partners, LLC) was a financial
technology company which funded PPP loans to approved borrowers and was
headquartered in Florida. Lender A maintained computer servers that were located
outside of Illinois.

u. Lender B (Capital Plus Financial, LLC) was a financial
technology company which funded PPP loans to approved borrowers and was
headquartered in Texas. Lender B maintained computer servers that were located

outside of Illinois.
Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 7 of 26 PagelD #:34

v. Lender C (Harvest Small Business Finance, LLC) was a financial
technology company which funded PPP loans to approved borrowers and was
headquartered in California. Lender C maintained computer servers that were
located outside of Illinois.

Ww. Lender D (Prestamos CDFI, LLC) was a community development
financial institution which funded PPP loans to approved borrowers and was
headquartered in Arizona. Lender D maintained computer servers that were located
outside of Illinois.

The Scheme to Defraud
2. Beginning no later than in or around June 2020 and continuing until at
least in or around July 2021, in the Northern District of Illinois, and elsewhere,

TYESHA BOWMAN, and
LIBRA MARTIN,

defendants herein, together with others known and unknown to the Grand Jury,
knowingly devised, intended to devise, and participated in a scheme to defraud and
to obtain money and property, in connection with applications for PPP and EIDL
funds, by means of materially false and fraudulent pretenses, representations, and
promises, as further described below.

3. It was part of the scheme that TYESHA BOWMAN and LIBRA
MARTIN (together, the “defendants”), for the purpose of fraudulently obtaining over
$500,000 in PPP and EIDL funds, submitted and caused to be submitted over 25

applications for loans under the PPP and EIDL Programs, on behalf of businesses

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Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 8 of 26 PagelD #:35

and entities purportedly owned and operated by the defendants and others known
and unknown to the grand jury, including FlyGirlWigs and Customs LLC, Libra
Martin, Cinny Nailed It, J&R Foods, Dimes Dimes Customs, Our Ventures, and
Young S-D Funeral and Cremation Service (together, “the purported borrowers”);
which applications and supporting documentation contained materially false
statements and misrepresentations, concerning, among other things, the purported
borrowers’ number of employees, gross revenues, payroll, cost of goods sold, operating
expenses, type of business, and existence as companies with ongoing operations.

4, It was further part of the scheme that TYESHA BOWMAN solicited
from other individuals, often through social media, personal identifying information
(“PII”), such as addresses, birthdates, social security numbers, and bank account
information, which information TYESHA BOWMAN used to prepare and submit
false and fraudulent PPP and EIDL applications on behalf of the individuals, in
exchange for a share of the approved loans’ proceeds.

5. It was further part of the scheme that TYESHA BOWMAN prepared
and submitted to Lenders A, B, C, and D (together, the “Lenders”), false and
fraudulent PPP loan applications on behalf of the purported PPP borrowers, in which
applications BOWMAN falsely and fraudulently represented that each purported
PPP borrower was a business that employed a specified number of employees, paid a
specified average monthly payroll, and was in operation on February 15, 2020. The

defendants knew at the time that the purported borrowers had no employees or
Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 9 of 26 PagelD #:36

payroll and were not in operation on February 15, 2020, and in many cases the
purported PPP borrowers did not exist at all.

6. It was further part of the scheme that, to substantiate the claimed
number of employees and payroll of the purported PPP borrowers, TYESHA
BOWMAN and LIBRA MARTIN prepared and submitted, and caused to be prepared
and submitted, to the Lenders, copies of false IRS tax filings (including IRS Form
1040, Schedule C) that fraudulently represented the purported PPP borrowers’
principal businesses and professions, yearly net profits, and total expenses. The
defendants knew at the time that the purported PPP borrowers had no payroll or
employees for which federal taxes were paid during that period.

7. It was further part of the scheme that, through the submission of the
false and fraudulent PPP loan applications and false and fraudulent supporting
documentation, TYESHA BOWMAN and LIBRA MARTIN caused the Lenders to
disburse over $500,000 in PPP and EIDL loan proceeds into bank accounts that were
controlled by the defendants and by the individuals for whom the defendants
prepared the false and fraudulent applications and supporting documentation.

8. It was further part of the scheme that after the PPP funds were
disbursed, TYESHA BOWMAN met with the other individuals for whom she
prepared and submitted false and fraudulent PPP loan applications and received a
portion of the fraudulently-obtained loan proceeds in exchange for her preparation

and submission of the applications.
Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 10 of 26 PagelD #:37

9. It was further part of the scheme that TYESHA BOWMAN and LIBRA
MARTIN misrepresented, concealed, and hid, and caused to be misrepresented,
concealed, and hidden, the existence and purpose of the scheme and the acts done in
furtherance of the scheme.

10. It was further part of the scheme that, after the PPP loans were
disbursed, in order to fraudulently obtain forgiveness of the PPP loans they obtained
for themselves and others, TYESHA BOWMAN and LIBRA MARTIN submitted and
caused to be submitted to the SBA or to the Lenders, loan forgiveness applications,
knowing that the forgiveness applications contained false and fraudulent
representations regarding the payroll costs for the purported sole proprietorships in
the PPP applications and the truthfulness and accuracy of the loan application and
supporting documents.

11. Onor about the dates set forth below, in the Northern District of Illinois,
Western Division, and elsewhere, the defendants, as set forth below, for the purpose
of executing the above-described scheme, knowingly caused to be transmitted by
means of wire communication in interstate commerce certain writings, signs, and

signals, listed below, each such writing, sign, and signal constituting a separate

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Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 11 of 26 PagelD #:38

count:

One

& LIBRA MARTIN

An internet transmission of ¢ a
PPP loan application on behalf
of “FlyGirlWigs and Customs,
LLC,” to Lender C’s computer
servers located outside of

Two

TYESHA BOWMAN
& LIBRA MARTIN

July 9, 2021

Wire transfer of approximately
$15,000 in PPP loan proceeds

from Lender C to BOWMAN’s
account ending in x9172

Three

LIBRA MARTIN

April 11, 2021

An internet transmission of a
PPP loan application on behalf
of “Libra Martin,” to Lender D’s

computer servers located
outside of Illinois

Four

LIBRA MARTIN

May 10, 2021

Wire transfer of approximately
$14,025 in PPP loan proceeds

from Lender D to MARTIN’s
account ending in x1071

Five

TYESHA BOWMAN
& LIBRA MARTIN

April 15, 2021

An internet transmission of a
PPP loan application on behalf
of “Cinny Nailed It,” to Lender
A’s computer servers located
outside of Illinois

Six

TYESHA BOWMAN
& LIBRA MARTIN

April 22, 2021

Wire transfer of approximately
$20,833 in PPP loan proceeds
from Lender A to C.B.’s account
ending in x0771

Seven

TYESHA BOWMAN
& LIBRA MARTIN

April 14, 2021

An internet transmission of a
PPP loan application on behalf
of “J&R Foods,” to Lender C’s
computer servers located
outside of Illinois

Eight

TYESHA BOWMAN
& LIBRA MARTIN

April 27, 2021

Wire transfer of approximately
$20,833 in PPP loan proceeds

from Lender C to J.G-F.’s
account ending in x4183

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Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 12 of 26 PagelD #:39

Count

Defendant(s).

Date

Description of Act

Nine

TYESHA BOWMAN
& LIBRA MARTIN

April 1, 2021

An internet transmission of a
PPP loan application on behalf
of “Dimes Dimes Customs,” to
Lender B’s computer servers
located outside of Illinois

Ten

TYESHA BOWMAN
& LIBRA MARTIN

May 6, 2021

Wire transfer of approximately
$20,832 in PPP loan proceeds
from Lender B to L.G.’s account
ending in x3098

Eleven

TYESHA BOWMAN
& LIBRA MARTIN

April 22, 2021

An internet transmission of a
PPP loan application on behalf
of “Our Ventures,” to Lender
A’s computer servers located
outside of Illinois

Twelve

TYESHA BOWMAN
& LIBRA MARTIN

May 18, 2021

Wire transfer of approximately
$20,833 in PPP loan proceeds
from Lender A to S.H.’s account
ending in x1400

Thirteen

TYESHA BOWMAN
& LIBRA MARTIN

April 8, 2021

An internet transmission of a
PPP loan application on behalf
of “Young S-D Funeral and
Cremation Service,” to Lender
B’s computer servers located
outside of Illinois

Fourteen

TYESHA BOWMAN
& LIBRA MARTIN

May 20, 2021

Wire transfer of approximately
$20,832 in PPP loan proceeds
from Lender B to K.Y.’s account
ending in x7135

Fifteen

TYESHA BOWMAN

June 28, 2020

An internet transmission of an
EIDL loan application on behalf
of “Our Ventures” through an
SBA server located outside of
Illinois

Sixteen

TYESHA BOWMAN

June 30, 2020

Wire transfer of approximately

$10,000 in EIDL loan proceeds

from the SBA to S.H.’s account
ending in x1470

In violation of Title 18, United States Code, Section 1343.

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Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 13 of 26 PagelD #:40

COUNTS SEVENTEEN THROUGH THIRTY-NINE
The SPECIAL MARCH 2024 GRAND JURY further charges that:
12. The allegations in paragraphs 1(b) and (0), (q), (7), and (s), and Counts
One through Sixteen are incorporated here.
13. Furthermore, at times material to the indictment:
Unemployment Insurance /Pandemic Unemployment Assistance

a. The Social Security Act established the dual program of federal
and state unemployment benefits (UI). Under the Act, each state administered its
own unemployment program through their State Workforce Agency (SWA), within
the guidelines of federal law.

b. State unemployment benefits were financed in part by state
payroll taxes, which were held in trust by the United States Department of Treasury’s
Unemployment Trust Fund. State unemployment systems and benefits are largely
financed by taxes on private employers located in that state. When state
unemployment benefits are exhausted, they may be supplemented by federal funds
appropriated by the U.S. Department of Labor. At times relevant to this indictment,
the federal government was providing significant supplemental benefits to the states
as a result of the COVID-19 pandemic.

c. The CARES Act expanded states’ ability to provide
unemployment insurance for many workers impacted by the COVID-19 pandemic,

including workers who were not ordinarily eligible for unemployment benefits. The

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Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 14 of 26 PagelD #:41

Pandemic Unemployment Assistance (“PUA”) Program allowed individuals who do
not qualify for regular unemployment compensation and were unable to continue
working as a result of COVID-19, such as self-employed workers and independent
contractors, to file for unemployment benefits. PUA provided benefits to qualifying
individuals who were otherwise able to work and available for work within the
meaning of applicable state law, except that they were unemployed, partially
unemployed, or unable or unavailable to work due to COVID-19 related reasons, as
defined in the CARES Act. Unemployment benefit payments under PUA were
retroactive for weeks of unemployment, partial employment, or inability to work due
to COVID-19 reasons starting on or after January 27, 2020.

d. Normally, an unemployed worker initiates a UI claim in person,
over the telephone, or on the Internet. The overwhelming majority of UI claims are
filed online through a state website. Applicants have to answer specific questions to
determine their eligibility to receive benefits, including their name, Social Security
number, and mailing address. The amount of unemployment benefits that a UI
claimant might be eligible for depends on several factors, including but not limited to
previous employment and the amount of wages he or she earned. Generally, in
Illinois, once a UI claimant was determined to be monetarily ineligible for regular UI,
a claimant could then file for PUA benefits. Ifa PUA application was approved, PUA
benefits could be distributed onto the debit cards that had already been mailed in

connection with the UI applications. For PUA claims, applicants also had to self-

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Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 15 of 26 PagelD #:42

certify that they met a COVID-19-related reason for being unemployed, partially
employed, or unable to work.

e. The SWA would make a determination about a UI claimant’s
eligibility for a UI claim based on the application made by the unemployed worker.
If the SWA approved a UI claim, the claimant was required to periodically certify the
claim via telephone or Internet at various times during the life of the claim, usually
on a weekly or bi-weekly basis. The worker must also certify that he or she is still
unemployed, is able to work, and is actively seeking work.

f. Residents of Illinois, California or Wisconsin, or individuals who
resided in another state but worked primarily in Illinois, California, or Wisconsin
respectively, and who became unemployed through no fault of their own, had the
option of initiating their unemployment claim electronically via the website for their
SWA, including the Illinois Department of Employment Security (DES), the
California Employment Development Department (EDD), and the Wisconsin
Department of Workforce Development (DWD) respectively.

g. For approved claims, IDES paid the benefits via debit card issued
by KeyBank. The debit cards were mailed to the claimant’s mailing address via
United States mail or a private or commercial interstate carrier.

h. For approved claims, EDD paid the benefits via debit card issued
by Bank of America. The debit cards were mailed to the claimant’s mailing address

via United States mail or a private or commercial interstate carrier.

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i. For approved claims, DWD paid the benefits via debit card issued
by U.S. Bank. The debit cards were mailed to the claimant’s mailing address via
United States mail or a private or commercial interstate carrier.

j. The unemployment benefits were loaded onto the debit card
electronically. Additional benefits are loaded electronically by the banks at intervals
thereafter.

k. When a claimant using an internet protocol (IP) address
registered to a physical address in Illinois filed a claim with an SWA, the servers used
to process those claims were located outside the state of Illinois. For example, a
California or Wisconsin claim filed from an IP address registered to an Illinois
residence would be processed through a server located outside the state of Illinois.
The servers IDES used to process PUA claims were located in Virginia.

The Scheme to Defraud
14. Beginning no later than in or around July 2020 and continuing through
at least in or around September 2021, in the Northern District of Illinois, and
elsewhere,
TYESHA BOWMAN,
LAMONT FOSTER,
KHADIJAH BROWN, and
SIETA CARRINGTON,

defendants herein, knowingly devised, intended to devise, and participated in a

scheme to defraud, and to obtain money and property, in connection with applications

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for PUA funds, by means of materially false and fraudulent pretenses,
representations, and promises, as further described below.

15. Itwas part ofthe scheme that TYESHA BOWMAN, LAMONT FOSTER,
KHADIJAH BROWN, and SIETA CARRINGTON (together, the “defendants”), for
the purpose of fraudulently obtaining over $500,000 in UI (including PUA funds),
prepared and submitted, and caused to be prepared and submitted, to the IDES,
EDD, and DWD, over 50 applications for UI and PUA on behalf of themselves and
sther individuals, which applications contained materially false statements and
misrepresentations concerning, among other things, whether the claimants actually
worked at the businesses claimed in the applications, the dates on which those
claimants worked at the businesses, and whether they were unemployed for a
COVID-19-related reason. The defendants knew at the time that the claimants did
not work at the businesses specified in the applications or were not unemployed for a
COVID-19-related reason.

16. It was further part of the scheme that BOWMAN acquired, often
through social media, the names, social security numbers, and other PII of
individuals, for the purpose of submitting false and fraudulent UI and PUA
applications, sometimes with their knowledge and consent and sometimes without
their knowledge or consent.

17. It was further part of the scheme that BOWMAN or her co-schemers

periodically certified that the individuals claimed in the fraudulent applications

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continued to be eligible for PUA benefits in order for BOWMAN and her co-schemers
to continue to obtain PUA benefits from the relevant SWAs.

18. It was further part of the scheme that defendants opted to have the
fraudulent unemployment benefits paid via debit cards that were mailed to
residences connected to defendants and others involved in the scheme.

19. It was further part of the scheme that TYESHA BOWMAN, LAMONT
FOSTER, KHADIJAH BROWN, and SIETA CARRINGTON received via the United
States Postal Service and private or commercial interstate carriers debit cards that
were mailed by the SWAs as a result of the false and fraudulent UI and PUA
applications, including in the names of other unnamed co-schemers, as well as in the
names of unwitting individuals whose PII BOWMAN had obtained.

20. It was further part of the scheme that, through the submission of the
false and fraudulent UI and PUA applications, the defendants caused the SWAs to
disburse over $500,000 in UI (including PUA benefits) onto the debit cards that were
mailed to TYESHA BOWMAN, LAMONT FOSTER, KHADIJAH BROWN, SIETA
CARRINGTON, and to other individuals.

21. It was further part of the scheme that, after receiving fraudulently
obtained debit cards in the mail, KHADIJAH BROWN and SIETA CARRINGTON
provided the debit cards to TYESHA BOWMAN.

22. It was further part of the scheme that other individuals who received

fraudulently obtained debit cards in the mail paid a portion of the fraudulently-

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obtained PUA benefits to TYESHA BOWMAN, in exchange for BOWMAN submitting
the false and fraudulent UI and PUA applications on their behalf.

23. It was further part of the scheme that TYESHA BOWMAN and
LAMONT FOSTER withdrew PUA funds from fraudulently-obtained debit cards via
automated teller machines (“ATMs”) and used the fraudulently-obtained PUA funds
for their personal] use and benefit. These ATM withdrawals were accomplished by
utilizing computer servers that were operating in interstate commerce.

24. It was further part of the scheme that TYESHA BOWMAN, LAMONT
FOSTER, KHADIJAH BROWN, and SIETA CARRINGTON misrepresented,
concealed, and hid, and caused to be misrepresented, concealed, and hidden, the
existence and purpose of the scheme and the acts done in furtherance of the scheme.

25. Onor about the dates set forth below, in the Northern District of Illinois,
Western Division, and elsewhere, defendants, as set forth below, for the purpose of
executing the above-described scheme, and attempting to do so, knowingly caused to
be delivered by the U.S. mail or commercial interstate carrier, namely, FedEx,
according to the direction thereon, envelopes addressed to the individuals listed below
at the locations listed below, which envelopes contained debit cards designed to
receive unemployment benefits Gncluding PUA benefits) from SWAs, as listed below,

each mailing constituting a separate count:

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Seventeen TYESHA August 31, Mailed debit card in the name of
BOWMAN and 2020 LAMONT FOSTER from Bank
LAMONT Ato an address in Rockford,
FOSTER Illinois
Eighteen TYESHA September 11, | Mailed debit card in the name of
BOWMAN and 2020 P.C. from Bank A to BROWN’s
KHADIJAH address in Love’s Park, Illinois
BROWN
Nineteen TYESHA September 11, | Mailed debit card in the name of
BOWMAN and 2020 T.B. from Bank A to BROWN’s
KHADIJAH address in Love’s Park, Illinois
BROWN
Twenty TYESHA March 10, Mailed debit card in the name of
BOWMAN and 2021 J.M. from Bank A to
SIETA CARRINGTON’s address in
CARRINGTON Rockford, Illinois
Twenty- TYESHA September 7, | Mailed debit card in the name of
One BOWMAN and 2021 LAMONT FOSTER from Bank
LAMONT B to an address in Rockford,
FOSTER Illinois
Twenty- TYESHA September 7, | Mailed debit card in the name of
Two BOWMAN 2021 E.E. from Bank B to an address

in Rockford, Illinois

In violation of Title 18, United States Code, Section 1341.

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Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 21 of 26 PagelD #:48

26.

On or about the dates set forth below, in the Northern District of Illinois,

Western Division, and elsewhere, the defendants, as set forth below, for the purpose

of executing the above-described scheme, knowingly caused to be transmitted by

means of wire communication in interstate commerce certain writings, signs, and

signals, listed below, each such writing, sign, and signal constituting a separate

count:
. Count: |= Defendant = Date. =| Interstate Wire ‘Transmission...
Twenty- | TYESHA BOWMAN | August 3, Online submission of PUA claim
Three 2020 to IDES in the name of S.A.
through servers located outside
Illinois
Twenty- | TYESHA BOWMAN | August 3, Online submission of PUA claim
Four 2020 to Wisconsin DWD in the name of
S.A. through servers located
outside Illinois
Twenty- | TYESHA BOWMAN | September | Online submission of PUA claim
Five and LAMONT 30, 2020 to IDES in the name of LAMONT
FOSTER FOSTER through servers located
outside Illinois
Twenty- | TYESHA BOWMAN | October 2, Online submission of PUA claim
Six 2020 to IDES in the name of P.C.
through servers located outside
Illinois
Twenty- | TYESHA BOWMAN | October 12, | Online submission of PUA claim
Seven 2020 to IDES in the name of T.B.
through servers located outside
Illinois
Twenty- | TYESHA BOWMAN | December Online submission of PUA claim
Eight |. 15, 2020 to IDES in the name of J.M.
through servers located outside
Illinois
Twenty- | TYESHA BOWMAN | August 25, | Online submission of PUA claim
Nine and LAMONT 2021 to California EDD in the name of
FOSTER LAMONT FOSTER through
servers located outside Illinois

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Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 22 of 26 PagelD #:49

Count Defendant Date Interstate Wire Transmission
Thirty | TYESHA BOWMAN | August 31, Online submission of PUA claim
2021 to California EDD in the name of

E.E. through servers located
outside Illinois

In violation of Title 18, United States Code, Section 1343.

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Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 23 of 26 PagelD #:50

27. Onor about the dates set forth below, in the Northern District of Illinois,
Western Division, and elsewhere, the defendants, as set forth below, for the purpose
of executing the above-described scheme, knowingly caused to be transmitted by
means of wire communication in interstate commerce certain writings, signs, and
signals, listed below, each such writing, sign, and signal constituting a separate

count:

1 LAMONT FOSTER | November | An electronic request to withdraw
5, 2020 approximately $503 from a Bank
of America ATM located in
Rockford, Illinois, using a
KeyBank debit card issued in the
name of T.B. and ending in x9620
Thirty- | TYESHA BOWMAN | November Electronic requests to withdraw
Two 6, 2020 approximately $986 from a Bank
of America ATM located in
Rockford, Illinois, using a
KeyBank debit card issued in the
name of T.B. and ending in x9620
Thirty- | LAMONT FOSTER | November Electronic requests to withdraw
Three 9, 2020 approximately $1,006 from a
Bank of America ATM located in
Rockford, Illinois, using a
KeyBank debit card issued in the
name of T.B. and ending in x9620
Thirty- | TYESHA BOWMAN | November Electronic requests to withdraw
Four 11, 2020 approximately $1,006 from a
Bank of America ATM located in
Rockford, Illinois, using a
KeyBank debit card issued in the
name of T.B. and ending in x9620

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Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 24 of 26 PagelD #:51

Thirty- | TYESHA BOWMAN | December 2, | An electronic request to withdraw
Five 2020 approximately $503 from a Chase
Bank ATM located in Rockford,
Illinois, using a KeyBank debit
card issued in the name of P.C.

and ending in x4578

Thirty- | TYESHA BOWMAN | December 6, | An electronic request to withdraw
Six 2020 approximately $503 from a Chase
Bank ATM located in Rockford,
Illinois, using a KeyBank debit
card issued in the name of P.C.
and ending in x4578

Thirty- | LAMONT FOSTER | December 7, | An electronic request to withdraw

Seven ~ and TYESHA 2020 approximately $483 from a Chase

BOWMAN Bank ATM located in Rockford,

Illinois, using a KeyBank debit

card issued in the name of P.C.
and ending in x4578

Thirty- | LAMONT FOSTER | December Electronic requests to withdraw
Eight 11, 2020 approximately $2,097.50 from a
PNC Bank ATM located in
Rockford, Illinois, using a
KeyBank debit card issued in the
name of P.C. and ending in x4578

Thirty- | TYESHA BOWMAN | December Electronic requests to withdraw

Nine 12, 2020 approximately $987 from a PNC

Bank ATM located in Rockford,

Illinois, using a KeyBank debit

card issued in the name of P.C.
and ending in x4578

In violation of Title 18, United States Code, Section 1343.

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Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 25 of 26 PagelD #:52

FORFEITURE ALLEGATION

The SPECIAL MARCH 2024 GRAND JURY further alleges:

1. Upon conviction of an offense in violation of Title 18, United States Code,
Sections 1341 and 1343, as set forth in this Indictment, defendants shall forfeit to the
United States of America any property which constitutes and is derived from proceeds
traceable to the offense, as provided in Title 18, United States Code, Section
981(a)(1)(C) and Title 28, United States Code, Section 2461(c).

2. The property to be forfeited includes, but is not limited to a personal
money judgment in an amount equal to the proceeds derived from the offenses in
violation of Title 18, United States Code, Sections 1343 and 1341, estimated to be
over $500,000.

3. If any of the property described above, as a result of any act or omission
by a defendant: 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, the

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Case: 3:25-cr-50036 Document #: 3 Filed: 07/22/25 Page 26 of 26 PagelD #:53

United States of America shall be entitled to forfeiture of substitute property, as

provided in Title 21, United States Code, Section 853(p).

A TRUE BILL:

UNITED STATES ATT

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