Affidavit in Support of Criminal Complaint — United States v. Kenneth Patrick Gaughan, No. 1:21-cr-00390-TSC (Dkt. 1-1, D.D.C.)

Summary

IRS-CI Special Agent Charles W. Sublett swore this affidavit in support of a criminal complaint charging Kenneth Patrick Gaughan with theft of government property, wire fraud, bank fraud and money laundering under 18 U.S.C. § 641, § 1343, § 1344 and § 1956. The agent says eleven (11) loan applications in the names of Gaughan and Person 1 listed the same 15th Street UPS box as the business address. SBA and Bank of America records reflect that seven (7) of the eleven (11) loans were disbursed, totaling $2,179,465.00, into accounts in the names of Therapy Dog International or Therapetic Solutions Inc. One application, for Service Animals of America, claimed twenty-five (25) employees and an average monthly payroll of $121,215 and was approved for $303,000. The affidavit says PPP funds were used to buy a residence and watercraft and to pay personal credit cards.

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

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Attachment A
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UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA ) Case No. 1:20-cr-_________
)
v. ) VIOLATIONS:
)
KENNETH PATRICK GAUGHAN, ) 18 U.S.C. § 641 (Theft of Government Property)
) 18 U.S.C. § 1343 (Wire Fraud)
Defendant. ) 18 U.S.C. § 1344 (Bank Fraud)
) 18 U.S.C. § 1956 (Money Laundering)
)
) FILED UNDER SEAL

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

I, Charles W. Sublett, being first duly sworn, hereby depose and state as follows:

PURPOSE OF AFFIDAVIT

1. This Affidavit is submitted in support of a criminal Complaint charging Kenneth

Gaughan (“Gaughan”) with Theft of Government Property, Wire Fraud, Bank Fraud and Money

Laundering, in violation of 18 U.S.C. § 641, 18 U.S.C. § 1343, 18 U.S.C. § 1344, and 18 U.S.C. §

1956. I respectfully submit that the Affidavit establishes probable cause to believe that Gaughan

defrauded the Small Business Administration (“SBA”) Paycheck Protection Program (“PPP”) and

laundered the fraudulently obtained funds. I request that the Court issue an arrest warrant for

GAUGHAN, pursuant to Federal Rule of Criminal Procedure 4(a).

BACKGROUND OF AFFIANT

2. I am a duly sworn and appointed Special Agent with the Internal Revenue Service,

Criminal Investigation (“IRS-CI”) since August 2019. I am currently assigned IRS-CI’s

Washington Field Office in the District of Columbia. I have received 26 weeks of training in

general law enforcement and criminal investigations, including interviewing and interrogation

techniques, arrest procedures, search and seizure, violations of the Internal Revenue Code and
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associated financial crimes, and money laundering investigations. In addition to my law

enforcement training, I am a Certified Public Accountant (CPA), Certified Fraud Examiner (CFE),

and hold a Master’s of Accounting and Information Systems degree from Virginia Tech. Prior to

employment with IRS-CI, I was a Senior Auditor for Deloitte and Touche and a Senior Forensic

Accountant for Deloitte Financial Advisory Services where I advised federal law enforcement

agencies regarding complex third-party money laundering investigations. In the course of my

training and experience, I have become familiar with the methods and techniques associated with

the laundering of criminal proceeds. In the course of conducting investigations, I have been

involved in the use of the following investigative techniques: interviewing subjects and

cooperating witnesses; conducting physical surveillance; analyzing financial records; tracing

funds and illegal proceeds; and preparing and executing search warrants.

3. This affidavit is intended to show only that there is sufficient probable cause for

the requested warrant and does not set forth all of my knowledge about this matter. I am

assigned to this investigation and my involvement has included reviewing SBA PPP and

Economic Disaster Injury Loan (EDIL) borrower applications and supporting documents as well

as other bank records and business records associated with Gaughan.

4. Based on my training and experience and the facts as set forth in this affidavit, I

respectfully submit that there is probable cause to believe that violations of 18 U.S.C. §§ 1343,

(wire fraud), 1344 (bank fraud), 641 (theft of government money or property), and 1956 (money

laundering) have been committed by Gaughan who also goes by the alias “Richard Strauski”.

PAYCHECK PROTECTION PROGRAM

5. As discussed in this affidavit, Gaughan is actively defrauding the federal

Payment Protection Program, which this section briefly describes.

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6. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act is a federal

law enacted in or around March 2020 and designed to provide emergency financial assistance to

the millions of Americans who are suffering the economic effects caused by the COVID-19

pandemic. One source of relief provided by the CARES Act was the authorization of 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 April 2020,

Congress authorized over $300 billion in additional PPP funding. 1

7. In order to obtain a PPP loan, a qualifying business must submit a PPP loan

application, which is signed by an authorized representative of the business. The PPP loan

application requires the business (through its authorized representative) to acknowledge the

program rules and make certain affirmative certifications in order to be eligible to obtain the PPP

loan. In the PPP loan application, the small business (through its authorized representative) must

state, among other things, its average monthly payroll expenses and number of employees. These

figures are used to calculate the amount of money the small business is eligible to receive under

the program. In addition, businesses applying for a PPP loan must provide documentation

showing their payroll expenses.

8. A PPP loan application must be processed by a participating lender. If a PPP loan

application is approved, the participating lender funds the PPP loan using its own money, which

is 100 percent guaranteed by Small Business Administration (“SBA”). Data from the application,

including information about the borrower, the total amount of the loan, and the listed number of

employees, is transmitted by the lender to the SBA in the course of processing the loan.

1
All dates and amounts are approximations. The words “on or about” and “approximately” are
omitted for clarity.

3
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9. The small business must use the PPP loan proceeds on certain permissible expenses,

specifically, payroll costs, interest on mortgages, rent, and utilities. The program allows the interest

and principal on the PPP loan to be entirely forgiven if the business spends the loan proceeds on

the allowable expenses within a designated period of time after receiving the proceeds and uses a

certain amount of the PPP loan proceeds on payroll expenses.

ECONOMIC INJURY DISASTER LOANS

10. As discussed in this affidavit, Gaughan is actively defrauding the federal

Economic Injury Disaster Loan (“EIDL”) program, which this section briefly describes.

11. In response to the COVID-19 pandemic, small business owners and non-profit

organizations in all U.S. states, Washington DC, and territories are able to apply for an EIDL.

EIDL is an existing SBA program designed to provide economic relief to businesses that are

currently experiencing a temporary loss of revenue. EIDL provides loan assistance, including up

to $10,000 advances, for small businesses and other eligible entities for loans up to $2 million.

The EIDL proceeds can be used to pay fixed debts, payroll, accounts payable and other bills that

could have been paid had the disaster not occurred; however, such loan proceeds are not intended

to replace lost sales or profits or for expansion of a business. Unlike certain other types of SBA-

guaranteed loans, EIDL funds are issued directly from the United States Treasury and applicants

apply through the SBA via an online portal and application. The EIDL application process, which

also uses certain outside contractors for system support, collects information concerning the

business and the business owner, including: information as to the gross revenues for the business

prior to January 31, 2020; the cost of goods sold; and information as to any criminal history of the

business owner. Applicants electronically certify that the information provided is accurate and are

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warned that any false statement or misrepresentation to SBA or any misapplication of loan

proceeds may result in sanctions, including criminal penalties.

PROBABLE CAUSE

12. For more than seven years, Kenneth Patrick Gaughan (“Gaughan”), a long-time

employee of the Catholic Archdiocese of Washington, DC (“ADW” or “the archdiocese”),

fraudulently diverted money from ADW to contractors Gaughan surreptitiously owned and that

provided virtually no legitimate services to ADW. In late 2018, a federal grand jury in the District

of Maryland charged Gaughan with mail fraud. In December 2019, that indictment was dismissed

for lack of venue. However, in July 2020, based on the fraud Gaughan executed against ADW, a

grand jury in the District of Columbia indicted Gaughan with mail fraud, wire fraud, and money

laundering.

13. During the investigation of the fraud that Gaughan committed against ADW,

federal agents identified Person 1 as Gaughan’s cohabitant in Gaughan’s former residence and

as the joint account holder on several of Gaughan’s bank accounts and credit cards. That is, your

federal agents learned that Person 1 resided with Gaughan at Gaughan’s U Street residence in

the neighborhood. In May 2018, federal agents obtained a copy of a

article about Person 1 stating that Person 1 “owns a house in with his friend

Ken Gaughan.” Further, bank records for bank and credit card accounts on which Gaughan and

Person 1 were joint accountholders show that Gaughan and Person 1 were joint accountholders

for BB&T accounts ending in 7875, 0952, and 2616. In addition, Gaughan and Person 1 were

cardholders and authorized users on a US Bank credit card ending in 4376, which was opened in

V
-
1

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January 2013, and Barclays Bank credit cards ending in 2023 and 2024, opened in November

2013.2

14. On July 17, 2020, I discovered that Gaughan was attempting to commit fraud on

the EIDL and PPP programs. Specifically, 11 PPP loans from SBA lenders were applied for in

the names of Gaughan and Person 1. Records show that those PPP loan applications were

submitted using the business names of at least eight bogus emotional support animal companies,

including Service Animals of America Incorporated, Service Dog of America Incorporated,

Certapet Incorporated, Official Service Dogs Incorporated, Therapetic Solutions Incorporated,

Therapy Dog Incorporated, Therapy Dog International Incorporated, and ESA Registry

International Incorporated.3

15. Further, according to the PPP loan applications, the purported service animal

companies each have twenty-five (25) employees and are located at a single private mailbox in the

UPS Store at 1030 15th Street, NW, Suite 170-B1, Washington, DC (“the 15th Street UPS box”).

Records from UPS show that Gaughan applied for and rents the 15th Street UPS box. The

evidence detailed in this affidavit otherwise shows that Gaughan made extensive use of the 15th

Street UPS box when defrauding ADW.

16. Gaughan also fraudulently applied for 12 EIDLs. Records show that Gaughan

applied for these loans utilizing nine of the above-mentioned suspected bogus service animal-

2
According to law enforcement databases, Person 1 currently resides at an address different from
the U Street address and , NE, Washington, DC. Thus, your affiant believes that
Gaughan and Person 1 no longer reside together.
3
Person 1 also submitted a loan application under the business name ,
a food science and nutrition consulting firm. According to Person 1’s biography posted on the
website of , where Person 1 is an , Person 1 is the
of .

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number 6270 for proceeds on two (2) EIDLs, the same account provided for proceeds of

at least one (1) PPP loan for Certapet Incorporated.

FRAUD ON THE SBA’S PAYCHECK PROTECTION PROGRAM (PPP)

20. As described above, in July 2020, I learned eleven (11) loan applications in the

names of Gaughan and Person 1 were submitted for businesses listing their address as the 15th

Street UPS box. I know that it is indicative of fraud when multiple businesses are located at a

single address, particularly when that address is a private mailbox, and where numerous loan

applications were submitted for different companies containing the same or similar information,

including the same address and number of employees, and similar average monthly payroll

amounts. Furthermore, I know that those who utilize private mailboxes often use those private

boxes to receive mail, but then store that mail in their homes.

21. Even though all of the businesses were purportedly located at the same private UPS

mailbox, the loan applications listed each business as having twenty-five (25) employees (for a

total of at least 200 employees) and an average monthly payroll exceeding $110,000. The names

of each of these businesses indicates they are engaged in similar business activity—registering

emotional support animals.

22. Gaughan worked full-time for ADW for almost a decade until he resigned in April

2018, and in early 2018, Gaughan’s LinkedIn profile does not reflect any involvement with animal

support services.

23. Further, federal agents reviewed Gaughan’s federal income tax returns for the tax

years 2011 through 2018. In doing so, federal agents found no indication that Gaughan operated

or worked with any animal support companies, or that Gaughan paid employees to work for

animal support companies.

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24. SBA and Bank of America records reflect that seven (7) of the eleven (11) loans

have been disbursed, with a total disbursed amount of $2,179,465.00. All disbursed funds were

deposited into two accounts at Bank of America in the names of Therapy Dog International or

Therapetic Solutions Inc.

25. Specifically, according to SBA records, Gaughan submitted applications for the

following four (4) PPP loans for businesses located at the 15th Street UPS box; three (3) of these

loans were disbursed:

Loan Number 7206: Gaughan applied for Loan Number 7206 through the
lender Fund-Ex Solutions Group LLC under the business name Service Animals of
America, and listed the business address for Service Animals of America as the 15th Street
UPS box. According to the loan application documents, Service Animals of America has
twenty-five (25) employees and an average monthly payroll of $121,215. Gaughan’s
address listed on this loan application is , NE, Washington, DC. The loan
was approved in the amount of $303,000, and the outstanding balance is $303,000. As of
June 6, 2020, the loan status was “past due disbursed” according to SBA records. The email
address listed on the application is @gmail.com.

Loan Number 7308: Gaughan applied for Loan Number 7308 through
Celtic Bank Corporation under the business name Service Dog of America, and listed the
business address for Service Dog of America as the 15th Street UPS box. According to the
loan application documents, Service Dog of America has twenty-five (25) employees and
an average monthly payroll of $121,215. Gaughan’s address listed on this loan is the
NE, Washington, DC. According to SBA records, Celtic Bank cancelled this
loan in May 2020. The email address listed on the PPP loan application is
@gmail.com.

Loan Number 7409: Gaughan applied for Loan Number 7409 through
Radius Bank under the business name Certapet Incorporated, and listed the business
address for Certapet Incorporated as the 15th Street UPS box. According to the loan
application documents, Certapet Incorporated had twenty-five (25) employees and an
average monthly payroll of $121,215. Gaughan’s address listed on this loan is listed as the
15th Street UPS box. The loan was approved in the amount of $303,100, and the
outstanding balance is $303,038. As of June 5, 2020, the loan status was “disbursed.” The
email address listed on the PPP loan application is @gmail.com.

Loan Number 7306: The application for Loan Number 7306 was submitted
to First Bank of the Lake under the business name ESA Registry International, and listed
the business address for ESA Registry International as the 15th Street UPS box. According
to the loan application documents, ESA Registry International has twenty-five (25)

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employees and an average monthly payroll of $151,325. The loan was approved in the
amount of $378,310.00, and the outstanding balance is $378,310. As of June 6, 2020, the
loan status was “disbursed current.” Law enforcement has not yet received information
about what email address was listed on the PPP loan application.

26. In addition, according to SBA records, the following seven (7) loans for businesses,

all of which are purportedly located at the 15th Street UPS box, were applied for in Person 1’s

name; at least four (4) of those PPP loans have been disbursed:

Loan Numbers 7402 & 7807: Loan Number 7402 was applied for
in Person 1’s name through Northeast Bank under the business name Official Service
Dogs. The business address for Official Service Dogs listed on the PPP loan application is
the 15th Street UPS box. According to the loan application documents, Official Service
Dogs has twenty-five (25) employees and an average monthly payroll of $121,215. Loan
Number 7402 was cancelled.

According to information Northeast Bank provided, after Loan Number 7402 was
cancelled, the borrower provided information that had been requested by the bank. As a
result, Northeast Bank approved Loan Number 7807 for business name Official
Service Dogs, with the address listed as the 15th Street UPS box, in the amount of
$303,000. According to the loan application documents, Official Service Dogs has twenty-
five (25) employees and an average monthly payroll of $121,200. Additional
documentation provided included a bogus residential lease agreement signed by tenant
[Person 1] on behalf of Official Service Dogs and landlord . This lease
agreement was a version of the same fraudulent lease documents mentioned above found
on Gaughan’s ADW computer and personally owned MacBook. As of June 5, 2020, this
loan status was “active but undisbursed” according to SBA records. According to
information received from Northeast Bank, this loan was closed and funded on June 9,
2020. The email address listed on the PPP loan application is
@gmail.com.

Loan Number 7709: Loan Number 7709 was applied for in Person 1’s
name through Bank of America under the business name Therapetic Solutions. The
business address for Therapetic Solutions listed on the loan application is the 15th Street
UPS box. According to the loan application documents, Therapetic Solutions has twenty-
five (25) employees and an average monthly payroll of $122,937. The loan was approved
in the amount of $307,342 and, according to Bank of America, was disbursed on May 4,
2020. Bank of America’s PPP loan application did not ask applicants to list an email
address, and none was listed on this application.

Loan Number 7303: Loan Number 7303 was applied for in Person 1’s
name through Kabbage Incorporated under the business name Therapy Dog Incorporated.
The business address for Therapy Dog Incorporated listed on the loan application is the
15th Street UPS box. According to the loan application documents, Therapy Dog

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Incorporated has twenty-five (25) employees and an average monthly payroll of $110,973.
The loan was approved in the amount of $277,432, and the outstanding balance is
$277,432. As of June 9, 2020, the loan status was “disbursed” according to SBA records.
The email address listed on the PPP loan application is @gmail.com.

Loan Number 7708: Loan Number 7708 was applied for in Person 1’s
name through Bank of America under the business name Therapy Dog International. The
business address for Therapy Dog International listed on the loan application is the 15th
Street UPS box. According to the loan application documents, Therapy Dog International
has twenty-five (25) employees and an average monthly payroll of $122,937. The loan was
approved in the amount of $307,343.00 and, according to Bank of America, the loan was
“disbursed” on May 4, 2020. Bank of America’s PPP loan application did not ask
applicants to list an email address, and none was listed on this application.

Loan Number 7901: Loan Number 7901 was applied for in Person 1’s
name through Northeast Bank under the business name Therapy Pet Incorporated. The
business address for Therapy Pet Incorporated listed on the loan application is the 15th
Street UPS box. According to the loan application documents, Therapy Dog Incorporated
has twenty-five (25) employees and an average monthly payroll of $121,215. The loan was
approved in the amount of $303,000. According to information received from Northeast
Bank, the loan was cancelled on July 10, 2020. The email address listed on the PPP loan
application is @gmail.com. Google has informed law enforcement that it has
no record of this email address, so it is not included among those requested in this search
warrant application.

Loan Number 7800: Loan Number 7800 was applied for in Person 1’s
name through Fund-Ex Solutions Group LLC under the business name Therapy Pet
Incorporated. According to SBA records, the borrower’s street address was
, Washington, DC, and the borrower’s physical street address
was the 15th Street UPS box. According to the loan application documents, Therapy Dog
Incorporated has twenty-five (25) employees and an average monthly payroll of $121,215.
As of May 30, 2020, the loan status was “fully cancelled.” Law enforcement has not yet
received information about what email address was listed on the PPP loan application.

a. SBA PPP Loan Application Documents

27. In executing an SBA Form 2483, a form required as part of the process to receive

PPP funding, each Applicant was required to initial and certify that between February 15 and

December 31, 2020, “the Applicant has not and will not receive another loan under the Paycheck

Protection Program.” Here, by receiving at least multiple PPP loans, the Applicant’s signed

certification on each application was false. Elsewhere on the Form 2483, applicants certified that

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29. In addition to the evidence that the applications are fraudulent described above,

there is further evidence in the material provided for various of the loan applications. For example:

Loan Number 7708: Documents provided to Bank of America to support payroll
obligations for Therapy Dog International (EIN: 0847) include Payroll Summary
Reports as of February 1, 2020 for pay period January 1, 2020 through January 31, 2020,
and March 1, 2020 for pay period February 1, 2020 through February 29, 2020. The
employees listed and payroll amounts per the reports are identical other than the report and
check dates. Payroll Details Reports were also provided for the same period. Similar to the
Payroll Summary Reports, the names and numbers on both reports were identical other
than report and check dates. Each report showed twenty-five (25) employees, a total
monthly pay of $144,817.27, employer taxes of $14,570.99, and total payroll costs of
$159,388.26.

Loan Number 7303: Documents provided to Kabbage Inc. to support payroll
obligations for Therapy Dog Incorporated ( 1090) include Payroll Summary
Reports as of February 1, 2020 for pay period January 1, 2020 through January 31, 2020,
and March 1, 2020 for pay period February 1, 2020 through February 29, 2020. Each
report showed twenty-five (25) employees, a total monthly pay of $144,817.27, employer
taxes of $14,570.99, and total payroll costs of $159,388.26. The documents provided were
identical to the Payroll Summary and Payroll Details Reports documents provided to Bank
of America for 7708 except for the entity name in the right-hand corner of the
document being “Therapy Dog Inc” versus “Therapy Dog International.”

Loan Number 7409: Documents provided to Radius Bank included identical
Payroll Summary Reports and Payroll Details Reports for January and February 2020 as
described above, except that “Certapet Inc.” was listed as the entity name in the upper right
corner of the documents. Further, the employees claimed are the same twenty-five (25)
employees as the other applications listed herein.

Loan Numbers 7206 and 7800: Applications were submitted to Fund-Ex
Solutions by the following entities: Service Animals of America, Certapet Incorporated,
and Therapy Pet Incorporated. On June 24, 2020, an employee of Fund-Ex Solutions filed
an SBA Hotline compliant. The compliant noted that while the loans for Service Animals
of America and Certapet Incorporated were applied for by Gaughan, and Therapy Pet
Incorporated was filed by Person 1, all three claimed the same twenty-five (25) employees.
These twenty-five (25) employees are the employees listed above that were utilized on
applications across all of the lending institutions. The compliant further stated that all three
applications included various tax forms with identical numbers for each entity.

Loan Numbers 7807 and 7901: Documents provided to Northeast Bank
included the same twenty-five (25) employees mentioned above. Additionally, bank
statements were provided for two separate entities: Official Service Dogs (Bank of
America account 9804) and Therapy Pet Inc. (Bank of America Account
6270). Several months of statements were provided. All dollar amounts and

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32. A search of the Applicant’s Employer Identification Number (EIN) ( 7450)

yielded no Forms 990. The search did yield a determination letter dated February 25, 2020

determining that the Applicant is a tax-exempt organization. As the below return was not available

on IRS.gov, and since the entity was not determined to be tax exempt until 2020, it is likely the

Form was never filed with the IRS and is likely fraudulent.

33. Of further note, the principal officer listed on the Form 990 is Gaughan. The

application lists Person 1 as the Applicant and principal officer for Official Service Dogs. The

signature on the Form 990 appears to read “Kenneth Gaughan” even though the printed name is

“Kevin Ganglof”. Neither Gaughan nor Ganglof is listed as employees on the employee listing

provided as supporting documentation.

34. 2019 Forms 940 were provided with at least three (3) applications for Official

Service Dogs, Therapy Dog International, and Therapy Dog Incorporated. All three returns were

signed on December 30, 2019 by [Person 1], CFO. Two (2) of the three (3) Forms 940 were

identical other than the EIN and Name. Forms 940 submitted for Therapy Dog International (loan

number 7708) and Therapy Dog Incorporated (loan number 7303) have total

payments to all employees of $1,709,301.97, FUTA tax before adjustments of $2,563.80, and Total

FUTA tax after adjustments of $92,302.31. Based on the training and experience of other federal

agents associated with this investigation, it is unlikely that two businesses would have equal

payments to employees and FUTA tax balances for the same year. Additionally, it is unlikely that

an entity would complete and sign Forms 940 prior to year-end. These irregularities suggest that

the Forms are likely fraudulent.

35. 2019 Forms 941 were provided for the first, second, third, and fourth quarters for

the following entities: Service Animals of America (EIN 2437); Therapy Pet Incorporated

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(EIN 1364); Certapet Incorporated (EIN 1218); and Therapy Dog Incorporated (

1090). These Forms were identical in every way except for EIN, Name, and the signer. Not

only were the Forms identical across entities, all numbers on the Forms were identical across

months and quarters. Based on typical turnover for businesses employing twenty-five (25)

employees, it is unlikely that each entity would consistently employ twenty-five (25) employees

for an entire year with equal and even monthly earnings. It appears as if the Forms 941 were altered

and duplicated to use as support for multiple loan applications.

36. Based on the use of seemingly altered, duplicative Federal Tax Forms, it appears

as if the Applicant utilized bogus documents to obtain PPP funding.

FRAUD ON THE SBA’S ECONOMIC INJURY DISASTER (EIDL) PROGRAM

37. According to SBA records, Gaughan submitted applications for the following

twelve (12) EIDL loans for businesses, which cited the same business address and purported in

several cases to have identical gross revenues and/or costs across different business entities in

other EIDL loan applications:

EIDL Application Number 4152: Application Number 4152 was applied
for by Gaughan directly with the SBA under the name Therapetic Solutions Incorporated.
According to SBA records, the applicant’s business address was the 15th Street UPS box
and the borrower’s physical street address was 2018 4th Street Northeast, Washington, DC.
According to the application, Therapetic Solutions Incorporated has three employees, gross
revenues of $210,000, and Non-Profit costs of operation of $210,000. Gaughan received
a $3,000 advance payment as a result of this application. The email address listed on this
EIDL application is @esapet.org.

EIDL Application Number 2063: Application Number 2063 was applied
for by Gaughan directly with the SBA using the business name Anything Pawsable
Incorporated. SBA records indicate the applicant’s business address was the 15th Street
UPS box and the borrower’s physical street address was Northeast,
Washington, DC. The application stated Anything Pawsable Incorporated has one
employee, $110,000 in revenue, and $110,000 in cost of goods sold. No funds have been
disbursed as a result of this application. The email address listed on this EIDL application
is @aol.com.

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EIDL Application Number 7207: Application Number 7207 was applied
for by Gaughan with the SBA using the business name Therapy Pet Incorporated. SBA
records show that the applicant’s business address was the 15th Street UPS box and the
borrower’s physical address was Northeast, Washington, DC. The
application stated Therapy Pet Incorporated three employees, gross revenues of $210,000,
and Non-Profit costs of operation of $210,000. As of July 22, 2020, no funds were
disbursed as a result of this application. The email address listed on the EIDL application
is @gmail.com.

EIDL Application Number 8932: Application Number 8932 was applied
for by Gaughan with the SBA using the business name Therapy Dog International. SBA
application data show the applicant’s business address was the 15th Street UPS box and
the borrower’s physical address was Northeast, Washington, DC. Therapy
Dog International claimed to have three employees and gross revenues of $210,000 and
Non-Profit costs of operation of $210,000. As of July 22, 2020, no funds were disbursed
as a result of this application. The email address listed on the EIDL application is
@gmail.com.

EIDL Application Number 7566: Application Number 7566 was applied
for by Gaughan with the SBA using business name ESA Registry International. The
applicant’s business address was the 15th Street UPS box and the borrower’s physical
address was Northeast, Washington, DC. ESA Registry International
claimed to have three employees and provided no revenue or cost information. As of July
22, 2020, no funds were disbursed as a result of this application. The email address listed
on the EIDL application is @gmail.com.

EIDL Application Number 1428: Gaughan applied for loan Application Number
1428 under the business name Official Service Dogs and listed the business address
as the 15th Street UPS Box. The borrower address was Northeast,
Washington, DC. Official Service Dogs listed three employees and did not provide gross
revenue or cost information. As of July 22, 2020, no funds were disbursed as a result of
this application. The email address listed on the EIDL application is
@gmail.com.

EIDL Application Number 8301: Gaughan applied for loan Application Number
8301 under the business name Service Dog of America and listed three (3)
employees. Per SBA application data, the business address provided was the 15th Street
UPS Box, and the borrower’s address was Northeast, Washington, DC.
Service Dog of America did not provide gross revenue or cost numbers. As of July 22,
2020, no funds were disbursed as a result of this application. The email address listed on
the EIDL application is @gmail.com.

EIDL Application Number 4874: Gaughan applied for Application Number
4874 under the business name Certapet Inc and listed three (3) employees. The
application stated gross revenue of $210,000 and cost of goods sold totaling $210,000. The

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business address provided was the 15th Street UPS Box and the borrower’s address was
Northeast, Washington, DC. As of July 22, 2020, no funds were disbursed
as a result of this application. The email address listed on the EIDL application is
@gmail.com.

EIDL Application Number 1397: Application Number 1397 was applied
for by Gaughan using the business name Service Animals of America. Service Animals
of America claimed to have three (3) employees and did not provide revenue or cost
information. The business address provided was the 15th Street UPS Box and the
applicant’s address was Northeast, Washington, DC. As of July 22, 2020,
no funds were disbursed as a result of this application. The email address listed on the
EIDL application is @gmail.com.

EIDL Application Number 9829: Gaughan applied for Application Number
3300109829 under the business name International Service Animals. International Service
Animals provided the business address of the 15th Street UPS box and claimed to have
three (3) employees. The borrower’s address was Northeast. International
Service Animals did not provide revenue or cost numbers. As of July 22, 2020, no funds
were disbursed as a result of this application. The email address listed on the EIDL
application is @gmail.com.

EIDL Application Number 3683: Gaughan applied for loan Application Number
3683 using business name Therapy Dog Incorporated claiming to have three (3)
employees. Therapy Dog Incorporated’s business address was the 15th Street UPS Box
and the applicant’s address was Northeast, Washington, DC. There were
no revenue or cost numbers provided. As of July 22, 2020, no funds were disbursed as a
result of this application. The email address listed on the EIDL application is
@gmail.com. As stated above, Google has informed law enforcement that it
has no record of this email address.

EIDL Application Number 2533: Gaughan applied for loan Application Number
2533 using business name US Therapy Dog. US Therapy Dog claimed three (3)
employees and did not provide revenue or cost information. The business address provided
was the 15th Street UPS Box and the applicant’s address was Northeast,
Washington, DC. As of July 22, 2020, no funds were disbursed as a result of this
application. The email address listed on the EIDL application is @gmail.com. As
stated above, Gaughan is known to go by the alias of Richard Strauski, and this email
address was used to register the website for SCY in Gaughan’s scheme against ADW.

38. In addition to the loans described in this affidavit, SBA records reflect that Person

1 applied for a loan in the name , with the address NW,

, Washington, DC. In contrast with the businesses associated with the 15th Street

UPS box, the loan application for shows that has only

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a single employee and an average monthly payroll of $7,818. This loan has been disbursed and the

outstanding balance is $19,545. The email associated with this application was

@gmail.com. Person 1’s LinkedIn profile reflects that he currently has two jobs—

as the of (a position Person 1 has held since January

2016), and as an at . Person 1’s LinkedIn profiles does

not reflect any involvement with animal support services.

EVIDENCE OF FRAUDULENT DOCUMENTATION RELATED TO THE
PURPORTED BUSINESSES USED TO OBTAIN PPP AND EIDL LOANS

39. Records obtained from the internet domain registrar and web hosting company

GoDaddy LLC show that an account with the login name “kennethpgaughan” reserved numerous

internet domains similar to the businesses used to obtain the PPP loans, including:

 servicedogdirectory.com
 usservicedogregistry.net
 certapet.net
 certapets.com
 certapet.org
 certapets.org
 esaregistry.net
 esadirectory.com
 esadogregistry.org
 esadirectory.org
 therapetic.org
 therapetic.us
 therapypetdog.com
 therapypetdog.org

40. The GoDaddy account used to register the foregoing domains listed the customer

name as Richard Strauski, the company name as a company utilized by Gaughan to defraud

ADW, and the customer address as a former UPS address on M Street NW, Washington, DC,

which converted into the 15th Street UPS box.

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41. A search of electronic media seized from Gaughan’s U Street Residence revealed

numerous service or support animal certificates purportedly signed by “Richard Strauski”

certifying an animal as a service or emotional support animal that appeared to be issued by

Therapetic. For example, a fraudulent support animal registration certificate that was purportedly

signed by “Richard Strauski” listed the address of the 15th Street UPS box and stated that a dog

“Tex” was “registered with TheraPetic’s National Registry.” The email address on the certification

has the domain esadirectory.org, which Gaughan registered. Similarly, federal agents discovered

another fraudulent animal support certification, signed by Strauski, for a squirrel named Elly May.

The certificate displayed the email address @therapic.org and a logo for Therapetic

Solutions. Based on this, I believes that Gaughan prepared the fraudulent certificates using the

alias Richard Strauski in order to conceal his involvement.

42. Similarly, while conducting a review of the electronic media seized from Gaughan,

federal agents found an email letter from “Richard Strauski, Senior Legal Advisor” of Therapetic

Solutions to an attorney at the law firm Wilson Sonsini Goodrich & Rosati confirming that

Therapetic Solutions would voluntarily remove the logo of Hawaiian Airlines Incorporated from

its website. I am aware that those who commit service animal fraud often represent that their

certifications can be used to bring animals onto airplanes. I found similar email letters from

“Richard Strauski, Senior Legal Advisor” of Therapetic Solutions to JetBlue Airways

Corporation and Alaska Airlines.

USE OF SBA PPP AND EIDL FUNDS

43. Based on a review of records to date, I suspect that Gaughan received a total of

$2,182,464.00 in combined PPP and EIDL funds. Based on information received from Bank of

America, Gaughan received the funds in two accounts in the name of Therapetic Solutions

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Incorporated and Therapy Dog International between May 4, 2020 and May 26, 2020. As of July

27, 2020, the balance in the two accounts totaled approximately $200,000.

44. I am aware of at least the following purchases and transfers out of the

aforementioned accounts:

 On May 27, 2020, a cashier’s check for $1,130,000 to Allied Title and Escrow LLC

was purchased at Bank of America by Therapy Dog International to fund the

purchase of , NE, Washington, DC.

 On May 27, 2020, Therapetic Solutions Incorporated sent a wire to AYS Marine

Enterprise LLC for $295,550. The wire funded the purchase of a 2020 Cruisers

Yachts 338 CX 33-foot watercraft.

 Between May 16, 2020 and July 15, 2020, at least $42,869.71 in likely proceeds

were transferred to pay a Capital One credit card balance.

45. Form 2483 explicitly states that by signing, the Applicant represents that “[t]he

funds will be used to retain workers and maintain payroll or make mortgage interest payments,

lease payments, and utility payments, as specified under the Paycheck Protection Program Rule: I

understand that if the funds are knowingly used for unauthorized purposes, the federal government

may hold me legally liable, such as for charges of fraud.” The above-mentioned use of PPP funds

to purchase a residence, watercraft, and make personal credit card payments does not meet the

certified use of funds requirements specified under the PPP Rule.

CONCLUSION
Based on the foregoing, I respectfully submit that probable cause exists to believe that

Gaughan committed Theft of Government Property, Wire Fraud, Bank Fraud and Money

Laundering, in violation of 18 U.S.C. § 641, 18 U.S.C. § 1343, 18 U.S.C. § 1344, and 18 U.S.C. §

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1956. I respectfully request that the Court issue an arrest warrant for Kenneth Patrick Gaughan.

The statements above are true and accurate to the best of my knowledge and belief.

________________________
Charles W. Sublett
Special Agent
IRS-CI

___________________________________________
G. Michael Harvey
United States Magistrate Judge

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