Criminal Complaint — United States v. Christina Anasi (No. 2:23-mj-30217, E.D. Mich.)

Summary

A sealed criminal complaint (AO 91) filed May 26, 2023 as ECF No. 1 in United States v. Christina Anasi, Case 2:23-mj-30217, in the U.S. District Court for the Eastern District of Michigan, charging conspiracy under 18 U.S.C. § 371, wire and bank fraud, conspiracy under 18 U.S.C. § 1349, money laundering under 18 U.S.C. § 1957, aggravated identity theft and false statements for April-December 2020. The affidavit of FBI Special Agent Brent Nida, sworn before Magistrate Judge Elizabeth A. Stafford, states the case began when Fundbox, Inc. reported nine PPP applications from one IP address traced to a doctor's office. It states the investigation identified over $3,300,000 in fraudulent PPP loans disbursed to Anasi and associates, plus at least $8,700,000 more sought. It details a $564,032 loan to D&H Market Inc. listing 28 employees for a store the affidavit says had no more than two.

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Full text

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AO 91 (Rev. 11/11) Criminal Complaint Special Agent: Brent Nida, FBI Telephone: (313) 919-1520

UNITED STATES DISTRICT COURT

for the

Eastern District of Michigan

United States of America Case: 2:23—mj-30217
* Assigned To : Unassigned
Assign. Date : 5/26/2023
CMP: SEALED MATTER (MAW)

Christina Anasi

CRIMINAL COMPLAINT

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

On or about the date(s) of April-December 2020 in the county of Macomb in the
Eastern District of Michigan , the defendant(s) violated:
Code Section Offense Description
18 U.S.C. § 371 Conspiracy to Commit an Offense Against the United
ates.

18 U.S.C. §§ 1343,1344
18 U.S.C. § 1349
18 U.S.C. § 1957
18 U.S.C. §§ 1028A, 1014

Wire Fraud, Bank Fraud.

Conspiracy to Commit Wire Fraud and Bank Fraud.
Money Laundering.

Aggravated Identity Theft; False Statements

This criminal complaint is based on these facts:

Continued on the attached sheet.

Brent Nida, Special Agent, FBI

Printed name and title

Sworn to before me and signed in my presence

and/or by reliable electronic means. CO < a ¢ | 1
Date: May 26, 2023 Judge’s signature an

City and state: Detroit, MI Hon. Elizabeth A. Stafford, United States Magistrate Judge

Printed name and title
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.2 Filed 05/26/23 Page 2 of 55

AFFIDAVIT IN SUPPORT OF AN APPLICATION FOR A CRIMINAL
COMPLAINT

I, Brent Nida, Special Agent of the Federal Bureau of Investigation (FBI),
being duly sworn, state that:

INTRODUCTION AND AGENT BACKGROUND

1. I make this affidavit in support of a criminal complaint and arrest
warrant for CHRISTINA ANASI.

2. I am an investigative or law enforcement officer of the United States
within the meaning of Section 2510(7) of Title 18 of the United States Code. I am
empowered to conduct investigations of and to make arrests for offenses enumerated
in Title 18 of the United States Code.

3. I have been employed by the FBI as a Special Agent since January
2018. During my employment with the FBI, I have investigated federal crimes
including mail fraud, wire fraud, tax fraud, and various other criminal matters. Prior
to being employed by the FBI, I was a Police Officer for approximately nine years.
At all times during the investigation described in this affidavit, I have been acting in
an official capacity as a Special Agent of the FBI.

4. The facts in this affidavit come from my personal observations, my
training and experience, and information obtained from other agents, from

contractors, and from witnesses. This affidavit is intended to show only that there
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.3 Filed 05/26/23 Page 3 of 55

is sufficient probable cause for to secure a criminal complaint and arrest warrant for
CHRISTINA ANASI and it does not set forth all of my knowledge about this matter.

5. In light of the facts described below, as well as my training and
experience, I submit that there is probable cause to believe that CHRISTINA ANASI
has committed federal crimes, including, but not limited to, violations of the
following statutes: 18 U.S.C. § 371 (Conspiracy to Commit an Offense Against the
United States); 18 U.S.C. § 1343 (Wire Fraud), 18 U.S.C. §1344 (Bank Fraud); 18
U.S.C. § 1349 (Conspiracy to Commit Wire Fraud and Bank Fraud); 18 U.S.C. §
1957 (Money Laundering), 18 U.S.C. § 1028A (Aggravated Identity Theft) and 18
U.S.C. § 1014 (False Statements in Connection with a Bank Loan).

BACKGROUND OF THE PAYCHECK PROTECTION PROGRAM

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
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.
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.4 Filed 05/26/23 Page 4 of 55

7. In order to obtain a PPP loan, a qualifying business was required to
submit a PPP loan application, which was to be signed by an authorized
representative of the business. The PPP loan application required the business
(through its authorized representative) to acknowledge the program rules and make
certain affirmative certifications in order to be eligible to obtain the PPP loan. In the
PPP loan application, the business (through its 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. In addition, businesses applying
for a PPP loan often provided documentation supporting their purported payroll
expenses.

8. A PPP loan application was processed by a participating lender. Ifa
PPP loan application was approved, the participating lender funded the PPP loan
using its own monies, which were generally guaranteed by the 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, was
transmitted by the lender to the SBA in the course of processing the loan.

9. PPP loan proceeds were required to only be used by the business on
certain permissible expenses—generally payroll costs, interest on mortgages, rent,

utilities and other explained business expenses. The PPP allowed the interest and
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.5 Filed 05/26/23 Page 5 of 55

principal on the PPP loan to be entirely forgiven if the business spent the loan
proceeds on these expense items within a designated period of time after receiving
the proceeds and used a certain amount of the PPP loan proceeds on payroll

expenses.

PROBABLE CAUSE

Summary of Investigation

10. In or around August 2020, a representative of Fundbox, Inc. informed
law enforcement of suspected fraudulent PPP loan applications submitted for
Different Flavors 14355, INC. (“FLAVORS”), JD Hydro, LLC., Detroit Prime
Liquor, LLC, Andrew Shallal, INC., and AAB Restaurant, INC. A total of nine PPP
loan applications were submitted to Fundbox using internet protocol (IP) address
96.85.123.41. An IP address is a unique string of characters that identifies each
computer using the Internet Protocol to communicate over a network.

11. Since nine applications were submitted from the same IP address, they
were likely completed using the same computer and/or internet connection. The IP
address is assigned to Comcast and records were requested regarding the IP Address.
Comcast identified the account assigned the IP address as a doctor’s office located
in Clinton Township, Michigan (“Doctor’s Office’). Eight of the nine PPP loan
applications using the IP address were rejected. Fundbox rejected the loans due to

suspected fraud. The JD Hydro loan application was accepted and the loan was
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.6 Filed 05/26/23 Page 6 of 55

funded. Records for all nine applications have been reviewed by Affiant and all
were fraudulent attempts to receive PPP loans.

12. A PPP loan was later provided for FLAVORS which will be described
in further detail later in this affidavit. The PPP funds for FLAVORS were deposited
into an account titled C&S Liquor (CS), with SK and CHRISTINA ANASI
(“ANASIT’) as signers on the account. SAMER KAMMO (“SAMER’”) is SK’s son
and ANASI’s husband.

13. The Small Business Administration provided records showing SAMER
received a $557,807 PPP loan through Harvest Small Business Finance, LLC.
(Harvest), for Wireless Plus Cellular (WPC). Records show SK received PPP a
$75,500 PPP loan through CRF Small Business Loan Company for CS and a
$564,032 PPP loan for D&H Market Inc. (DH) through Celtic Bank.

14. On November 27, 2020, your affiant executed a seizure warrant issued
by this court and seized $498,027.99 of remaining funds from the WPC PPP loan
and $205,898.76 of remaining funds from the FLAVORS PPP loan.

15. On December 3, 2020, at approximately 9:45 AM, affiant conducted
surveillance at the Doctor’s Office. A black Cadillac CTS bearing a Michigan
Registration ending in 3303 was parked in front of the business. That same CTS
was also observed at the business on December 5, 2020, at approximately 1:00 PM;

December 9, 2020, at approximately 9:19 AM; and, December 9, 2020, from
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.7 Filed 05/26/23 Page 7 of 55

approximately 2:30 PM through 9:00 PM. The CTS is registered to RITA SHABA

16. The Small Business Administration provided documents identifying
three PPP loans issued to SHABA: $240,000 for Green Gold Rush, LLC., through
Cross River Bank; $561,450 for Queen of the Green, LLC., through Harvest; and,
$90,074 for Forever Beauty, LLC. through Celtic Bank. The investigation has
determined that all of these loans were approved based on fraudulent representations.

17. On December 22, 2020, your affiant executed a seizure warrant issued
by this court and seized $50,247.23 of remaining funds from the Forever Beauty PPP
loan and $845,617.05 of remaining funds from the Queen of the Green and Green
Gold Rush PPP loans. Search warrants issued by this court were also executed at
the Doctor’s Office and SHABA’s residence on that date.

18. The FBI and Homeland Security Investigations (HSI) are investigating
fraud involving the PPP loan applications submitted by FLAVORS, WPC, CS, DH
and the other related entities. The investigation has identified over $3,300,000 in
fraudulent disbursed PPP loans associated with ANASI, SHABA, and SAMER. The
group also attempted to obtain at least an additional $8,700,000 in fraudulent
COVID relief loans that were not funded due to suspected fraud or applications
withdrawn.

D&H Market (DH) PPP loan
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.8 Filed 05/26/23 Page 8 of 55

19. The SBA provided documentation for a PPP loan issued to D&H
MARKET, INC (DH). SBA loan 52222474-08 was issued to DH by Celtic Bank
Corporation (Celtic) in the amount of $564,032 on or about May 12, 2020. The
business address listed on the loan application is 2134 Martin Luther King, Flint,
Michigan. The loan was approved on May 12, 2020. In SBA loan records, DH is
listed as a meat market with 28 employees established on March 1, 1993. SK is
listed as DH’s authorized representative for the loan.

20. Headquartered in Salt Lake City, Utah, Celtic is a privately owned
industrial bank chartered by the State of Utah. Celtic specializes in small business
finance, helping business owners with working capital, expansion, acquisition,
construction, equipment financing, real estate, and more.

21. Celtic was subpoenaed for records regarding the DH PPP loan. Celtic
provided an SBA Paycheck Protection Program Borrower Application Form. DH is
listed as the business name with an address of 2134 Martin Luther King, Flint,
Michigan. SK is listed as the primary contact with an email address of
gH AES | ()@email.com and a business phone number ending in x6664. SK
is listed as 100% owner of the company with an address of 5XXXX Highbury Ct,
Shelby Township, Michigan. The form lists an average monthly payroll of

$225,613. The PPP application is signed in the name of SK on May 11, 2020.
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.9 Filed 05/26/23 Page 9 of 55

22. Your affiant knows that the address on Highbury Ct is the home address
of SAMER and ANASI. Both of their Michigan Drivers Licenses list this as their
address. SK’s driver’s license lists an address in Davison, Michigan. SHABA’s cell
phone was seized during the execution of a search warrant on December 22, 2020.
Phone number x6664, the phone number provided for SK on the DH PPP
application, is saved as “Samer” in SHABA’s phone.

23. Affiant interviewed SK in February of 2021. She advised her phone
number ended in x4489. SK advised she owns DH and works there with her
husband. She stated, since 2019, there have not been more than two employees
working for her at the business. She did not know of any PPP loans in her name at
the time of the interview and did not give anyone permission to get a PPP loan in
her name. SK provided a voided check showing what bank account she used for
DH, the account ended in x6067. SK indicated that she did not have an email
address.

24. The Michigan Department of Licensing and Regulatory Affairs
(LARA) system shows DH was incorporated in February 1993. SK was the only
person listed on the business at incorporation and in all filings on the LARA website.
The registered office address in all online filings was 2134 Martin Luther King,
Flint, Michigan. The 2020 report lists SK as president of the company with the same

address.
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.10 Filed 05/26/23 Page 10 of 55

25. DH is a beer, wine, and liquor store operating at 2134 Martin Luther
King, Flint, Michigan. It does not appear to be operating as a meat market with 28

employees as indicated on SBA documents. Below is a Google Maps image of the

business.

26. Celtic provided IRS Tax Form 941s for all four quarters of 2019 and
the first quarter of 2020 that were submitted in connection with DH’s PPP
application. IRS Form 941 is used by businesses to report their quarterly number of
employees, wages paid, federal income tax withholdings, and other similar business
expenses. All five forms show 28 employees and quarterly total wages, tips, and
other compensation of $669,368.10. All forms show to have been completed by a

CPA who will be referred to as CB. SK is listed as President of the company on the
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.11 Filed 05/26/23 Page 11 of 55

forms with a phone number ending in x6664; however, as noted above, that is
SAMER’s phone number.

27. Your Affiant spoke with Accountant CB who purportedly completed
the forms. The CPA advised he has done work for the Kammo family in the past.
CB was served with a subpoena for documents prepared for DH, CS, SAMER,
ANASI, SK, and others.

28. CB provided records he prepared for certain of the subpoenaed entities.
Records were provided for CS, but CB did not produce any tax documents for DH.

29. Celtic provided a Chase statement for account x370 from February
2020 that was submitted in connection with the DH PPP application. Below is an

image captured from the statement:

10
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.12 Filed 05/26/23 Page 12 of 55

Cl ‘SE ft A February 01, 2020through February 28, 2020
organ Chase Bank, N.A. .
P O Box 182051 Account Number: [es70

Columbus, OH 43218-2051

CUSTOMER SERVICE INFORMATION

Web site: Chase.com
Service Center: 1-800-242-7338
HOLD - RETURN MAIL Paraespandl 1-886-622-4273
D&H MARKET INC International Calls: 1-713-262-1679
2134 MARTIN LUTHER KING
FLINT MI 48503
CHECKING SUMMARY | Chase Total Business Checking
INSTANCES AMOUNT
Beginning Balance $2411,299.32
Deposits and Additions 83 28,565.51
ATM & Debit Card Withdrawals 29 -25,665.36
Electronic Withdrawals 4 -2,218.77
Fees 1 -15.00
Ending Balance 117 $2,383,400.19

30. Chase was issued a subpoena and provided records for account x9370
referenced in this purported bank statement. Below is an image capture from the

February 2020 statement provided by Chase:

11
Case 2:23-mj-30217-DUTY

ECF No. 1, PagelD.13 Filed 05/26/23 Page 13 of 55

CHASE Oo Fetruary 01, 2020 through February 28, 2020
JPMorgan Chase Dank, N.A N [E370
PO Box 182051 eka

Columbus, OH 43216 - 2051

CUSTOMER SERVICE INFORMATION

Web site Chase.com
Service Center 1-800-242-7338
00023363 DRE 021 060 08020 NNNNNNNNNNN 1 000000000 64 Co89 Deat and Hard of Hearing: 1-800-242-7383
HOLD - RETURN MAIL Para Espanot 1-888-622-4273
ANASI DETROIT PROPEATY, LLC International Calls: 1-713-262-1679

17333 W 8 MILE RD
DETROIT MI 48235-2141

|CHECKING SUMMARY |_“hs2 To!a! Business Checking

INSTANCES AMOUNT
Beginning Balance $1,299,32
Deposits and Additions 83 28,565.51
ATM & Debit Card Withdrawals 29 -25,665.36
Electronic Withdrawals 4 -2,218.77
Fees 1 «15.00
Ending Balance 117 $1,965.70

|DEPOSITS AND ADDITIONS!

The records provided by Chase show the statement submitted to Celtic in
connection with the DH loan was altered. The beginning balance in the account was
$1,299.32, not “$2411,299.32.” Moreover, the balance entered on the statement
submitted to Celtic was not in the proper format — were it issued by Chase, it would
have read $2,411,299.32.

31.

Celtic provided an image of a voided check that was submitted in

connection with the DH PPP loan application. Below is an image of the check:

12
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.14 Filed 05/26/23 Page 14 of 55

D & H MARKET, INC 399
2134 ML KING AVE.
FLINT, MI 48503-1028 DATE

PAY TO THE
ORDER OF

VOIDED

CHASE &

JPMorgan Chase Bank, N.A.
www.Chase.com

MEMO

[A 370" 03990

32. Chase provided checks drawn on account x9370. Below is an image of

an actual check drawn on the account:

4057
ANAS! DETROIT PROPERTY, LLC .
CHASE On | i,
wow. Chase.com
“0 r 4370 40 5
0? 20004 26h

It is clear that the check submitted to Celtic for the DH PPP loan was altered, the

account name, address and check sequence number were not accurate.

13
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.15 Filed 05/26/23 Page 15 of 55

33. Celtic provided ACH deposit records showing that on May 21, 2020,
$564,032 in PPP loan funds for DH were deposited into account x370, which, as
noted above, was in the name of Anasi Detroit Property, LLC.

34. Chase Bank was issued a subpoena for records associated with ANASI
and SAMER. Chase records show on May 22, 2020, $564,032 was received into
account x9370 from Celtic Bank, with a reference to D&H Market, Inc.. The same
days as the deposit, the $50,000 check displayed above was written to ANASI; a
$45,000 check was written to ANASI on this date as well, and a $50,000 check was
also written to C&S Liquor. The stamps on the back of the check all indicate they
were deposited into Comerica Bank accounts. Between May 22, 2020 and
November 12, 2020, there were 43 withdrawals from the account totaling $371,000.
It is evident the PPP funds were not being spent on DH nor were they being spent
on authorized PPP expenses.

35. Celtic provided Blue Cross Blue Shield of Michigan statements which
were submitted as part of the DH PPP loan application. The statement below was

submitted to Celtic (filename provided by Celtic: “Invoice _04-27-2020 02-10-12”):

14
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.16 Filed 05/26/23 Page 16 of 55

D&H MARKET INC

Lam Blue Cross 5B HIGHBURY CT
S SHELBY TOWNSHIP MI 483152877
e . of Micnigan
Coverage Contract #: 893459370 [Us ys") $2,802.06
Account # 8934593700003710 | Date Billed: 02/18/2020 | Invoice Number: 082282120 | Billing Due 03/31/2020

Period: 03/01/2020-03/31/2020 | Paid Through Date:03/31/2020

Coverage details

lm ii $475.27
Last Name: KE] | First Name: S|! Contract Number: 89345937000037 10 | Billed

From: 03/01/2020 | Billed Through: 03/31/2020 | Current Charges: $475.27 | Contract Type:

Business | Benefit Description: BLUE CROSS PREMIER PPO SILVER SAVER

STEVEN KAMMO $475.27
Last Name: KAMMO | First Name: STEVEN | Middle Initial: L | Contract Number: .
89345937000037 10 | Billed From: 03/01/2020 | Billed Through: 03/31/2020 | Current

Charges:$475.27 | Contract Type: Business | Benefit Description: BLUE CROSS PREMIER

PPO SILVER SAVER

Whee — $475.27

Last Name: [| First Name: TIM[E) Contract Number: 8934593700003710 | Billed From:
03/01/2020 | Billed Through: 03/31/2020 | Current Charges: $475.27 | Contract Type:
Business |Benefit Description: BLUE CROSS PREMIER PPO SILVER SAVER

SAMER KAMMO $475.27
Last Name: KAMMO | First Name: SAMER | Contract Number: 8934593700003710 | Billed From: .
(01/2020 | Billed Through: 03/31/2020 | Current Charges: $475.27 | Contract Type: Business |
Benefit Description: BLUE CROSS PREMIER PPO SILVER SAVER
if we do not receive full payment by the due date, you may not be able to use your benefits.
it may take 2-3 businees days for your payment to reflect in your updated amount due.
AR ADJUSTMENTS $0.00
PRIOR AMOUNT BILLED $1,901.38
PAYMENTS RECEIVED 1,901.08
CURRENT ADJUSTMENTS $0.00
CURRENT PREMIUM AMOUNT 1,901.08
ADVANCED PREMIUM TAX CREDIT CURRENT ($900.98)
TOTAL AMOUNT DUE $2,802.06
UPDATES TO BILL
PAID THROUGH DATE 03/31/2020
et-ess) AMOUNT DUE $2,802.06

15
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.17 Filed 05/26/23 Page 17 of 55

36. During the search warrant executed on December 22, 2020 at SHABA’s
residence, her cell phone was seized. Examination of the phone revealed ANASI
sent SHABA an attachment named “Invoice_04-27-2020_ 02-10-12” on April 27,
2020 (which is the same file name provided by Celtic for the image above). Below

is the attachment ANASI sent SHABA:

16
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.18 Filed 05/26/23 Page 18 of 55

KAMMO, SAMER

SHE HIGHBURY CT
Fal () Blue UD) Bite Stet SHELBY TOWNSHIP MI 483152877

Coverage Contract #: 893459370 [Ug ViS8)
Account #: 8934593700003710 | Date Billed: 12/02/2018 | Invoices Number: 082282120 | Billing
Period: 01/01/2019-01/31/2019 | Paid Through Date: 01/31/2019

$0.00
Dus 12/28/2018

Coverage details

CHRISTINA ANASI $475.27

Last Name: ANASI| Firet Name: CHRISTINA | Contract Number: 8934593700003770 | Billed

From: 01/01/2019 | Billed Through: 01/31/2019 | Current Charges: $475.27 | Contract Type:

Family | Benefit Description: BLUE CROSS PREMIER PPO SILVER SAVER

Last Name: KAMMO | First Name: AGE]! Middle Initis!- [J]! Contract Number:

8934593700003710 | Billed From: 01/01/2019 | Billed Through: 01/31/2019 | Current Charges:

$324.92 | Contract Type: Family | Benefit Description: BLUE CROSS PREMIER PPO SILVER

SAVER

Last Name: KAMMO | First Name: AR]! Contract Number: 8934593700003710 ! Billed From:

01/01/2019 | Billed Through: 01/31/2019 | Current Charges: $324.92 | Contract Type: Family |

Benefit Description: BLUE CROSS PREMIER PPO SILVER SAVER

SAMER KAMMO $529.21

Last Name: KAMMO | First Name: SAMER | Contract Number: 8934593700003710 | Billed From:

01/01/2019 | Billed Through: 01/31/2019 | Current Charges: $529.21 | Contract Type: Family |

Benefit Description: BLUE CROSS PREMIER PPO SILVER SAVER

i we do not receive full payment by the due date, you may not be able to use your bene*ne.
it may take 2-3 busineee aye for your payment to refect in your updated amount dus.

AR ADJUSTMENTS $0.00
PRIOR AMOUNT BILLED $1,349.58
PAYMENTS RECEIVED ($674.79)
CURRENT ADJUSTMENTS $0.00
CURRENT PREMIUM AMOUNT $1,654.32

ADVANCED PREMIUM TAX CREDIT CURRENT ($900.98)

TOTAL AMOUNT DUE $1,428.13
UPDATES TO BILL

PAID THROUGH DATE 01/31/2019
ess] AMOUNT DUE $0.00

The document submitted to Celtic had been altered. The documents are similar but

names, dates, addresses and amounts were altered.

17
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.19 Filed 05/26/23 Page 19 of 55

37. SHABA’s cell phone also had text messages regarding the BCBS
invoice above. Text Messages involving SHABA and phone number ending in
x8866 that is saved as Christina Tantune. Messages contain numerous references
made to SAMER being the husband of phone number x8866. SAMER is ANASI’s
husband, and I believe SHABA’s contact saved as Christina Tantune is, in fact, the
contact for ANASI.

38. SHABA’s seized phone contained a group chat with SHABA, ANASI
and SAMER. There were thousands of messages regarding the various PPP loans
involved in this investigation in that group chat. Below are some of the messages
regarding sending the insurance document saved as “Invoice 04-27-2020 02-10-
12”:

e 4/27/2020: Sent by SHABA- Do you have your bcbs detailed billing
for the whole year? So I can edit and make it look like you pay
employee health care insurance

e 4/27/2020: Sent by SAMER- We don’t have Health care do We??

e 4/27/2020: Sent by SAMER - A lot of stores don’t

e 4/27/2020: Sent by SHABA- Your family does

e 4/27/2020: Sent by SAMER - Personal

e 4/27/2020: Sent by SHABA- Yeah send me the invoice but in pdf file

18
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.20 Filed 05/26/23 Page 20 of 55

e 4/27/2020: Sent by SHABA- Bro if you have it send it you might as
well abuse this forgivable loan I’m trying to help you get everything

e 4/27/2020: Sent by ANASI- We got our own insurance

e 4/27/2020: Sent by SHABA- I’m already up I know it’s late but I get
it.....free money

e 4/27/2020: Sent by ANASI- It’s not from the business

e 4/27/2020: Sent by SHABA- I know I’m going to edit the names and
put the employees names

e 4/27/2020: Sent by ANASI- U want every month

e 4/27/2020: Sent by SHABA- Yes please and this year

e 4/27/2020: Sent by ANASI:

+15867188866 Tantune Christina
Attachments:

Size: 571977

Invoice 04-27-2020 02-10-12.pdf

Status: Read
Read: 4/27/2020 6:10:35 AM(UTC+0)

4/27/2020 6:10:34 AM(UTC+0)

(Affiant note: ANASI sent another 35 BCBS statements to SHABA after sending
the one that was altered and submitted to Celtic.)

e 5/4/2020: Sent by ANASI- IMG_3904:

19
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.21 Filed 05/26/23 Page 21 of 55

Hi Sahira

Thank you for applying to the Paycheck Protection Program
with Funding Circle! As an approved PPP lendar, actively
working with Ine SBA, we are ready to do our part,

Thank you for uploading your documents! In order to
prevent any delays in processing your application, please
make sure you have uploaded all required documents in
their entirety

Please note: There is overwhelming Gemand by
businesses to participate in the Paycheck Protection
Prograrn anc government funds are available only for a
limited tme, Funcing Circle is working hard to process your
application in order to submit it to the SBA. However. we
can not quarantee that you will receive 4 PPP loan,

Here is the checklist of required documents:

® Copy of voided check {for the business checking
accounl)

¢ Valid ID or Driver's License for every owner above
20% (picture of front/back in color)

® 2019 Business Tax Return

'f your 2079 Business tax return is not yet filed, we will

® Payroll Verification, one of the following:

° $41 of O1 2020 or G4 2019

o $44 0f 2079

° Statement from Payroll Service Provider (PEO)
* Ownership Verification - Capiialization lable

(attached)

| will begin reviewing your application, and will reach out
wilh any questions.

(Affiant note: Celtic partnered with Funding Circle for PPP loans and would have
been communicating with email address s**********8]1Q@gmail.com, the email
account they had on file for the loan. This shows ANASI was communicating with
the lender as SK, without SK’s knowledge and consent.)

e 5/4/2020: Sent by SAMER- Ohh Yaaa

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.22 Filed 05/26/23 Page 22 of 55

5/4/2020: Sent by ANASI- Rita what documents are u missing from the
list

e 5/4/2020: Sent by SHABA- I submitted everything

e 5/4/2020: Sent by SHABA- I sent you the documents via email

e 5/4/2020: Sent by ANASI- Ok should we reply email

e 5/4/2020: Sent by SHABA- I submitted everything yeah reply
(Affiant note: The conversations above show ANASI was communicating with the
lender as if she were SK. It also shows ANASI, SAMER and SHABA all conspired
creating fake insurance documents to submit to the lender. It also shows all three
knew DH did not actually provide health insurance to employees and SHABA was
going to fraudulently edit the actual insurance records for SAMER and ANASI.)

39. SHABA and ANAS also sent text messages regarding the loan that did

not include SAMER. Below are some of those messages:

e 4/25/2020- Sent by SHABA to ANASI- After this loan I’m blocking
Samer. Bro I’m not going to lie I’m scared about this whole process.
Because his mom hasn’t filed taxes. And I don’t like his mom but I still
don’t want anything to happen to her. I talked to Douglas loan officer
and I had him look over the paperwork I told him I think my accountant
has covid-19 I told him I was the mom. I was so nervous talking to

him. Christina I made her taxes up. It’s basically a fake ass application

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.23 Filed 05/26/23 Page 23 of 55

40.

and that’s why I have a ughh feeling Anddddddd I’m praying to God
they don’t find out about D&H store.

4/25/2020- Sent by SHABA to ANASI - Here’s another loan request.
4/25/2020- Sent by ANASI to SHABA- Nooo no more loans.
4/27/2020- Sent by SHABA to ANASI- Lol I’m sorry but I can’t half
ass his application is already fishy with his mom and I have to make
sure everything is perfect. You better take a lot of that money for
yourself and the kids. I know that’s why I didn’t want you in the
application. Just in case they come after us.

4/27/2020- Sent by ANASI to SHABA- Yesterday he goes let’s see
what happens and we can switch the name to D&H and apply for my
moms store and keep the money.

Celtic provided records showing the DH PPP loan was submitted

through IP address 68.46.155.171 (Comcast IP address). Comcast was subpoenaed

for records regarding this IP address. Because of retention practices, Comcast only

had records from January 28, 2021 through June 12, 2021. During this timeframe,

the subscriber was Christina Kammo (ANASJ) and the IP was assigned to her home

address in Shelby Township, Michigan. Phone number ending in x8866 was

assigned to the account; this was the number communicating in text messages

detailed above with SAMER and SHABA as “Christina Tantune’’. Comerica Bank

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.24 Filed 05/26/23 Page 24 of 55

also provided IP records associated with ANASI’s accounts and there were hundreds
of logins through this IP address, multiple from account anasichristina@gmail.com
during April of 2020. Based on the Comerica and Comcast IP information, I believe
this IP address was assigned to SAMER’s and ANASI’s residence during the time
of the DH PPP loan application submission.

41. SHABA texted that she submitted all of the documents requested by the
lender. The loan process typically consists of submitting the initial SBA PPP Loan
Application to a lender, which it appears was done by ANASI for this loan. After
receiving the PPP Loan Application, lenders typically ask for supporting documents
and this did occur. It appears ANASI was operating the email account and that
SHABA submitted the requested documents while ANASI was communicating with
the lender.

42. Affiant reviewed thousands of SHABA’s text messages with ANASI
and SAMER. There were numerous text messages indicating SAMER had minimal
if any computer skills and abilities. Text messages indicated ANASI handled almost
all computer related activities for SAMER. Based on the messages it is unlikely any
PPP loans applications were submitted from ANASI and SAMER’s residence by

SAMER rather than ANASIT.

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.25 Filed 05/26/23 Page 25 of 55

43. During the investigation $233,583.08 of the remaining DH PPP loan
proceeds were seized from multiple bank accounts pursuant to a seizure warrant

issued by this court.

C&S Liquor (CS) PPP loan

44. The SBA provided records for a PPP loan issued to C&S Liquor (CS).
PPP Loan 45597073-07 that was approved through CRF Small Business Loan
Company (CRF). The loan amount was $75,500 and was approved on or about April
29, 2020. The mailing address and project address for the loans is 1XXXX West 8
Mile Rd, Detroit, Michigan. The CS average monthly payroll listed on the
application form is $30,602. The application form indicated the proceeds were to
be used for payroll costs. In SBA loan records, CS is described as a convenience
store with four employees. SK is listed as the authorized representative for CS with
a Grand Blanc, Michigan address listed. A phone number ending in x9790 and email
address of f********##****7 1 O@omail.com is listed for SK.

45. LARA records indicate CS was dissolved on July 15, 2020. LARA lists
1XXXX Baldwin Circle, Holly, Michigan as the company address. The registered
agent of the business is SK. The business was incorporated on May 22, 2012.
Annual reports for CS were filed through 2017; nothing has been filed since March
9, 2017. The 2017 annual report lists SK as the president, secretary, and treasurer of

the company.

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.26 Filed 05/26/23 Page 26 of 55

46. CRF was issued a subpoena for records regarding the CS PPP loan.
CRF provided an SBA PPP Borrower Application Form that was submitted for the
CS PPP loan. The form lists phone number ending in x6664 as the phone number
for the loan; as noted above, this is SAMER’s cell phone. The form lists SK as the
primary contact and 100% owner of the company. SAMER and ANASI’s address
is listed for SK. The form lists four employees and a monthly payroll of $30,602.
The application form purports to have been signed by SK on May 6, 2020.

47. CRF provided records showing the PPP loan was submitted through IP
Address 96.85.123.41. This IP is assigned to the Doctor’s Office SHABA works at.

48. CRF also provided W-2s that were submitted as supporting documents
for the CS PPP loan. A submitted 2019 W-2 shows SAMER received wages of
$90,130.92 and SK received wages of $104,746.43. The Michigan Department of
Treasury provided records pursuant to a subpoena. SAMER and ANASI’s joint
returns show they were paid total wages of $26,000 by CS in 2018, $45,500 by CS
in 2019 and $37,000 by CS in 2020 (with no differentiation of which of them
received the wages.). The State of Michigan Treasury was not able to locate any tax
records for SK. The Treasury return shows the W-2s were fictitious. The text
message between SHABA and ANASI on April 25, 2020 listed above confirms they
knew SK had not filed taxes and stated SHABA made up SK’s tax documents.

ANASI was aware these fictitious tax documents were used to obtain the PPP loan.

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.27 Filed 05/26/23 Page 27 of 55

49. CRF also provided emails regarding the PPP loan for CS. The emails

below were provided by CRF:

From: Rita Shaba <ritashaba13 @gmail.com>
Sent: Wednesday, April 29, 2020 1:05 PM

To: Douglas (yy @crfusa.com>
Cc: samer kammo <samerkammo@gmail.com>
Subject: Re: Link for Spark PPP Program

Please make si

Hi Douglas,

Just following up with the status of my application, did you by any chance hear anything back?

Thank you,

Sahira Kammo
586.907.6762
Mon 5/25/2020 8:12 PM

Rita Shaba <ritashaba13@gmail.com>

Forgiveness
To samer kammo; — anasichristina@gmail.com; _ Rita Shaba; Douglas

PPP Interim Final Rule_O.pdf _

https://www.sba.gov/sites/default/files/2020-04/PPP%20Interim%20Final%20Rule=0. pdf

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.28 Filed 05/26/23 Page 28 of 55

This first email shows SHABA was communicating with the lender, acting as SK
and SAMER was cc’d on the email. The phone number at the bottom of the email
is SHABA’s, it was the number assigned to the cell phone seized from her person
during the search warrant at her residence and subpoenaed Verizon records confirm
the number is assigned to SHABA. The second email shows SHABA emailed the
lender with SAMER and ANASI cc’d on the email. All three knew about the PPP
loan and were part of the process.

50. CRF also provided health insurance records that were submitted with
the PPP loan application. The version of the altered BCBS document discussed
above that was submitted for the DH PPP loan was also submitted for this loan. The
only difference was this fictitious document listed C & S LIQUOR INC as the
business name. SAMER and ANASIJ also both acknowledged in their text messages
with SHABA that CS does not provide health insurance.

51. CRF provided a 2019 IRS Form 1120s that was submitted in connection
with the CS PPP loan application. The form lists CPA CB as the preparer. This
form lists many of the exact same amounts and preparer that SHABA submitted to
obtain a PPP loan for her company Forever Beauty. The only notable difference was
the business information. CB was interviewed and advised he did not complete

either of these forms.

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.29 Filed 05/26/23 Page 29 of 55

52. Comerica records for account x9259, in the name of C&S Liquor, Inc.,
show the account received a $75,500 deposit on May 7, 2020. SBA records show
this deposit was an SBA PPP loan issued to C&S Liquor. On May 8, 2020, check
3128 was made out for $50,000 to ANASI, and on May 9, 2020, check 3129 was
made out for $25,500 to ANASI. Stamps on the back of both checks indicate they
were deposited into a Comerica account.

53. SHABA’s cell phone contained the following messages between her
and ANASI:

e 5/2/2020- Sent by ANASI- Dude it says void check for C&S

e 5/2/2020- Sent by SHABA- Do you know how to do that

e 5/2/2020- Sent by ANASI- Yeah but it’s not C&S

e 5/2/2020- Sent by SHABA- Fuck

e 5/2/2020- Sent by ANASI- Mine is my personal

e 5/2/2020- Sent by SHABA- What should we do

e 5/2/2020- Sent by ANASI- We should put it in C&S and I'll write a

check from there

e 5/2/2020- Sent by SHABA Okay whatever works

e = 5/2/2020- Sent by ANASI- Or should I edit the name
This exchange shows ANASI was reviewing what documents were needed for the
CS PPP loan and needed a voided CS check. ANASI indicates that she wants to

28
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.30 Filed 05/26/23 Page 30 of 55

have the funds deposited into the CS account and that said she would “write a check

from there,” which is what she did with the PPP proceeds.

54. SHABA’s cell phone also contained the following image sent by

ANASI:
Available Balanc
Current Bal:
Account: SAVINGS (****** 5175) .

From: 4/9/2020 © Es) * To: 59/2
View: All Transactions -

ing/Authorized Transactions (Transaction amounts are reflected |

~ Date ¢ Description

MAY 11 2020 PENDING - DEPOSIT MEMO TELLER AUTHORIZED

This image shows ANASI was monitoring Comerica account x5175. Records
provided by Comerica show account x5175 is titled “Christina Anasi ITF Samer L
Kammo”. On May 11, 2020, this account received a $25,500 deposit of a check
from CS’s X9259 account written to ANASI. Account x5175 also received a
$50,000 check deposit on May 8, 2020. This was also a check written to ANASI

from x9259 consisting of CS PPP loan proceeds. In summary, the entire CS PPP

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.31 Filed 05/26/23 Page 31 of 55

loan, $75,500, was transferred to ANASI’s personal account until it was seized
during this investigation. The loan proceeds were not spent on any SBA PPP loan
authorized expenses.

55. It is clear the PPP loan to CS is based on fraudulent representations,
based on actual CS records completed by CPA CB, CS reported to the IRS quarterly
wages, tips, and other compensation of $6,500 to $16,900, during 2019 and 2020.
The company did not have a monthly payroll of $30,602, and there is no evidence
of this amount of payroll in the CS bank account. ANASI, SAMER and SHABA
conspired to obtain this PPP loan based on fraudulent representations and ANASI

received the fraudulent loan proceeds.

Different Flavors 14355 (FLAVORS) PPP loan

56. As noted above, a PPP loan application for FLAVORS was previously
denied by Fundbox due to suspected fraud. FLAVORS later submitted a PPP loan
application to First Home Bank (FHB) in July 2020. FHB is an FDIC insured bank
that handles personal and business banking. FHB has five locations, all within the
state of Florida. This PPP loan was approved. The SBA was contacted and provided
documentation for a PPP loan issued to FLAVORS by FHB.

57. According to the SBA documents, Loan 9434978 1-06 was approved to
be funded to FLAVORS on July 28, 2020. The loan was approved for $520,800.00.

The loan mailing address and project address provided to the SBA was 14355

30
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.32 Filed 05/26/23 Page 32 of 55

Cloverdale Street, Detroit, Michigan 48238. The SBA documents identified
FLAVORS as an “Ice Cream and Frozen Dessert Manufacturing” business with 17
employees. SBA records show FLAVORS was established on October 19, 2018,
and identify an individual who will be referred to as “BA” as the only principal
associated with the business.

58. The Michigan Department of Licensing and Regulatory Affairs
(LARA) system shows BA as the registered agent for FLAVORS; BA 1s also listed
as the president, treasurer, secretary, and director of the company. 14355 Cloverdale
Street, Detroit, Michigan 48238, is listed as BA’s address and the mailing address
for FLAVORS.

59. Section 5 of the LARA annual report requires businesses to “Describe
the general nature and kind of business in which the corporation is engaged in during
the year covered by this report.” The answer provided by FLAVORS on March 17,
2020, reads “MEDICAL MARIJUANA FACILITY PREPARATION. THIS
COMPANY IS ENGAGED IN THE APPLICATION PROCESS WITH THE
STATE OF MICHIGAN TO BE A MEDICAL MARIJUANA FACILITY.” This
directly contradicts the statement that FLAVORS is operating as an “Ice Cream and
Frozen Dessert Manufacturing” company as noted in SBA loan records for

FLAVORS.

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.33 Filed 05/26/23 Page 33 of 55

60. The internet search did locate a State of Michigan, Marijuana Licensing
Report for July 27, 2020, through July 31, 2020. The report lists FLAVORS as a
“Grower Class C,” located at 14355 Cloverdale Street, Detroit, Michigan with a
status of “Prequalification Approval.” BA and his spouse are listed as the
supplemental applicants. This shows FLAVORS is a company operating in the
marijuana industry. SBA rules indicate marijuana businesses were not eligible to
receive PPP loans.

61. On Friday, October 16, 2020, at approximately 10:00 AM, HSI Special
Agent David Green took photographs of 14355 Cloverdale. Below are some of the

photographs.

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Case 2:23-mj-30217-DUTY ECF No. 1, PagelD.34 Filed 05/26/23 Page 34 of 55

33
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.35 Filed 05/26/23 Page 35 of 55

62. Special Agent Green advised the building appeared to be abandoned.
He did not observe any vehicles parked around the building or in the area suggesting
a business was in operation. The building was boarded up and the only identifiable
entrance had two large padlocks securing it. The boarded up entrances appeared to
be weathered and vegetation was growing in front of them. Based on the
photographs and observations by Special Agent Green, there did not appear to be an
“Ice Cream and Frozen Dessert Manufacturing” business operating at this location.

63. First Home Bank was subpoenaed for records regarding the FLAVORS
PPP loan. Bank statements and a voided check were provided as part of the
application for the PPP loan. Below is a statement and the check that was provided

for the PPP loan application for FLAVORS:

EC

DIFFERENT FLAVORS 4355 INC, BL opi2
14355 CLOVERDALE ST i
DETROMT Mi 48238 som:

ue
PAY

=
H Comenc Bank } CS . :
u

34
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.36 Filed 05/26/23 Page 36 of 55

Come
June 1, 2020 through June 30, 2020
Comerica Bank Account Number: OOO000,EP250
P O Box 75000

Detroit, MI 48275-7612
CUSTOMER SERVICE INFORMATION

vieb site: Comerica.com
Service Center. 1-800-822-6546
00212212 DRE 021 210 06020 NNNNNNNNNNN 1 000000000 Deaf and Hard of Hearing: 1-800-589-1400
Para Espanotl: international 1-868-622-4273
DIFFERENT FLAVORS 14355 INC anes aa
14355 CLOVERDALE ST
DETROIT MI 48238
CHECKING SUMMARY Comerica Total Business Checking BASIL ANASI
Card 0113
INSTANCES AMOUNT
Beginning Balance $94,107.49
Deposits and Additions 29 117,649.16
[DEPOSITS AND ADDITIONS]
DATE DESCRIPTION AMOUNT
o6/01 Merchants Bank Transaction PPD ID: 9424311302 $5584.20
06/02 Merchants Bank Transaction PPD ID: 9424300002 5462.55
06/02 Merchants Bank Transaction PPD ID: 9424300002 7681.60
06/03 Merchants Bank Transaction PPD ID: 9424300002 5500.00
06/03 Merchants Bank Transaction PPD ID: 9424300002 3282.10
06/07 Merchants Bank Transaction PPD ID: 9424300002 1282.10
06/10 Merchants Bank Transaction PPD ID: 9424300002 447229
o6/tT Merchants Bank Transaction PPD ID: 9424300002 3146.00
O6/11 Merchants Bank Transaction PPD ID: 9424300002 5500.00
oe/tt Merchants Bank Transaction PPD ID: 9424300002 3843.73
o6/12 Merchants Bank Transaction PPD ID: 9424300002 4411.60
06/13 Merchants Bank Transaction PPD ID: 9424300002 6550.00
06/13 Merchants Bank Transaction PPD ID: 9424300002 3200.00
O6/t7 Merchants Bank Transaction PPD ID: 9424300002 1200.00
a6/18 Merchants Bank Transaction PPD ID: 9424300002 2400.00
06/21 Merchants Bank Transaction PPD ID: 9424300002 3100.00
06/21 Merchants Bank Transaction PPD ID: 9424300002 3500.00
06/21 Merchants Bank Transaction PPD ID: 9424300002 4800.00
06/22 Merchants Bank Transaction PPD ID: 9424300002 1700.00
06/22 Merchants Bank Transaction PPD ID: 9424300002 5500.00
06/22 Merchants Bank Transaction PPD ID: 9424300002 3282.10
Oorz3 Merchants Bank Transaction PPD ID. 424300002 1200.00
06/23 Merchants Bank Transaction PPD ID: 9424300002 4000.29
06/24 Merchants Bank Transaction PPD ID: 9424300002 7600.60
06/25 Merchants Bank Transaction PPD ID: 9424300002 5500.00
06/26 Merchants Bank Transaction PPD ID: 9424300002 3220.00
06/27 Merchants Bank Transaction PPD ID: 9424300002 1200.00
06/27 Merchants Bank Transaction PPD ID: 9424300002 4400.00
06/27 Merchants Bank Transaction PPD ID: 9424300002 5100.00
Total Deposits and Additions $ 139,649.16

64. After being issued a subpoena, Comerica provided the actual June 2020
statement and checks for account ending in x9259. Below is the actual statement

and check:

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.37 Filed 05/26/23 Page 37 of 55

80246
C & SLIQUOR INC
17321 W8 MILE RD
DETROIT MI 48235-2141
Basic Business Checking
statement
June 1, 2020 to June 30, 2020
Account number M259
Account summary Cal —
a
(800) 643-4418
Beginning balance Hearing impaired (TDD 800 822-6546)
on June 1, 2020 $4,019.33 Visit our web site
Plus deposits WWW COMENCS. COM
Electronic deposits $15,878.40 Write to us
Paper deposits. $123, 045. 16 PO BOX 75000
Less withdrawals
Checks -$94 736.64
Fees and service charges -$321.54 The Account Balance Fee for this statement
period for this account is $0.00/$1,000.
. The Account Balance Fee for this statement
no 0 $17,105.85 period for this account is $0.00/$1,000.

The x9259 documents provided by Comerica show the documents submitted to First

Home Bank were fraudulent. The name and address on the account were completely

36
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.38 Filed 05/26/23 Page 38 of 55

different and the balances were not the same. The transactions during this statement
period were also different from the actual x9259 statement.

65. First Home Bank also provided 2019 IRS Form 941s that were
submitted in connection with the FLAVORS PPP loan application. The forms for
all four 2019 quarters list 17 employees and $621,664 in quarterly wages, tips and
other compensation. The form lists CPA MF as the preparer. The Michigan
Department of Treasury was subpoenaed and could not locate any tax records for
FLAVORS from 2015 through 2019.

66. CPA MF was interviewed by your Affiant. MF had never heard of this
company and indicated that he did not complete the IRS Form 941s that purport to
be prepared by him. MF had been contacted by SAMER but did not do any work
for him. MF indicated that he did create tax documents for SHABA and her
company Forever Beauty.

67. Your Affiant interviewed BA, the purported applicant for the
FLAVORS PPP loan. BA did not know about the loan and did not give anyone
consent to apply for a loan in his name. BA indicated that he previously was going
to start a marijuana business with SAMER. BA indicated that he had purchased the
property on Cloverdale Street but the business was never in operation.

68. SHABA’s phone contained the following messages regarding BA and

the FLAVORS PPP loan:

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.39 Filed 05/26/23 Page 39 of 55

e 8/11/2020- Sent by ANASI- What about b****?
(Affiant note: b**** is BA, the FLAVORS applicant.)

e 8/11/2020- Sent by ANASI- Dude bank was that with

e 8/11/2020- Sent by SHABA- C&S account

e 8/11/2020- Sent by ANASI- Rejected To?

e 8/11/2020- Sent by SHABA- No (BA) got approved last night

e 8/11/2020- Sent by SHABA- $520,800
The FLAVORS PPP loan was deposited into the CS account, it is clear ANASI knew
about the loan. ANASI also stated in text messages above regarding the CS PPP
loan that she could write checks out of the CS account, showing he had access to the
account.

69. $205,898.76 of the remaining PPP loan proceeds for FLAVORS were

seized during the investigation pursuant to a seizure warrant issued by this court.

Wireless Plus Cellular PPP loan

70. The SBA located a $557,807 PPP loan for Wireless Plus Cellular
(WPC) issued by Harvest Small Business Finance, LLC. The authorized
representative and signor for WPC’s PPP loan application was SAMER.

71. SBA records identify PPP loan 17884678-08 was approved for WPC in
the amount of $557,807. The loan was entered with the SBA on May 22, 2020, and

showed a status of “Disbursed Current” on June 6, 2020. The mailing address and

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.40 Filed 05/26/23 Page 40 of 55

project address provided to the SBA is 17317 W 8 Mile Road, Detroit, Michigan. In
SBA records, the business nature is listed as “Wireless Telecommunications
Carriers” and lists 28 current employees. SBA documents identify SAMER as the
president and 100% owner of the company.

72. LARA records show SAMER as the registered agent for WPC. His
name is the only name associated with the business. The address listed for the
company is 17317 W 8 Mile Road, Detroit, Michigan. LARA indicates WPC was
organized in November 2018. The initial filing for WPC and a 2020 annual
statement are the only records in LARA for WPC. The 2020 annual report was filed
on May 15, 2020, a week before a PPP loan was applied for by WPC.

73. Below is a Google Maps image of 17301 and 17321 W 8 Mile Road,
Detroit, Michigan. There does not appear to be any building with an address of

17317 W 8 Mile Road.

WEIGHTLoss
PROGRAM

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.41 Filed 05/26/23 Page 41 of 55

74. ALARA search for business entities owned by SAMER indicates he is
the owner of 17321 W 8 Mile Road. It is operating as ANASI DETROIT
PROPERTY, LLC (ADP). There have not been any filings in LARA since 2018
when the ADP address was changed to this location from a location in Grand Blanc,
Michigan. The actual location of CS is 17321 W 8 Mile Road.

75. There does not appear to be a “Wireless Telecommunications Carriers”
company with 28 employees operating at any of these listed locations.

76. Harvest was served with a subpoena for records regarding the WPC
PPP loan. Harvest provided IRS Form 941s submitted with the PPP loan application
for WPC. A total of five forms were submitted: all four quarters of 2019 and the
first quarter of 2020. All forms list 28 employees and $669,368.10 in quarterly
wages, tips, and other compensation. SAMER is listed as the President of the
company and CPA CB is listed as the preparer on all the submitted IRS Form 941s
for WPC. These exact employee and wage numbers were also submitted to
fraudulently obtain the DH PPP loan. The same wage amount was also listed on an
IRS Form 941 submitted by SHABA to obtain a PPP loan for Queen of the Green
but this form listed CPA MF as the preparer.

77. CPA CB was interviewed and advised he did not complete these forms

and had never heard of the company. The Michigan Department of Treasury

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.42 Filed 05/26/23 Page 42 of 55

determined WPC had not filed any state tax returns for tax years 2018 and 2019,
indicating the company was not in business.

78. In August 2022, a grand jury records subpoena was served to Wireless
Plus requiring the production of business records from January 1, 2019 onwards. On
August 23, 2022, counsel for SAMER, who accepted service of the subpoena on
behalf of the company, indicated in an email that “[a]fter speaking to my client, he
states that this business has not been in existence since 2016 or 2017, and therefore
there are no records that fall within the time frame of your request.”

79. Harvest provided a SBA PPP Borrower Application form for WPC. The
form lists SAMER as the President and 100% owner of the company. The form lists
28 employees with an average monthly payroll of $233,122.70 and appears to have
been signed by SAMER on May 21, 2020. Because the business was not actually
operational, these are false representations.

80. IP Address records provided by Harvest show the WPC PPP loan was
submitted through IP Address = 174.230.129.110, email address
sammerkammo@gmail.com and the record was created on May 15, 2020.
Comerica Bank later provided IP Address records for ANASI and SAMER account
logins. Records show this IP Address was used on May 14, 2020 by
anasichristina@gmail.com to access ANASI’s personal bank accounts x4936 and

x5175.

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.43 Filed 05/26/23 Page 43 of 55

81. Harvest provided a bank statement that was submitted in connection
with the WPC PPP loan application. The February 2020 statement lists “WIRLESS
PLUS CELLULAR 17317 W 8 Mile RD Detroit MI 48234-2141” with an account
number of x9267 and an ending balance of $319,013.99.

82. Pursuant to a subpoena, Comerica provided the actual statements for
account x9267. The account did not have a statement for specifically February of
2020 but there was a statement for December 1, 2019 through May31, 2020. The
account is actually titled “C & S DETROIT PROPERTY LLC 17321 W 8 MILE RD
DETROIT MI 48235-2141” and had a balance of $29.34 prior to receiving the WPC
PPP loan proceeds. The statement submitted to Harvest had been altered, in
February of 2020 the account was dormant with only $29.34. The x9267 records
also show the PPP loan proceeds were not spent on authorized expenses.

83. SHABA’s cell phone contained text messages between ANASI,
SAMER and SHABA regarding the WPC PPP loan, below is a summary of
messages:

e 5/5/2020- Sent by SHABA- Give me check info
e 5/5/2020- Sent by SHABA- for wireless

e 5/5/2020- Sent by SHABA- Bank name

e 5/5/2020- Sent by SHABA- Should I just use c&s

e 5/5/2020- Sent by ANASI- Use my bank account

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Case 2:23-mj-30217-DUTY ECF No. 1, PagelD.44 Filed 05/26/23 Page 44 of 55

e 5/5/2020- Sent by ANASI- IMG_3921

1.
(Affiant note: This image lists bank account ending in x4936, this is a Comerica

account held in ANASI’s name in trust for SAMER.)
e =5/22/2020- Sent by SHABA- Why aren’t you guys checking emails wtf

e 5/22/2020- Sent by ANASI- IMG_4187

harvestppp2 - Lupe a

Dear Borrower,

Congratulations! Your PPP loan request has been approved
by the SBA.

Please review and execute the attached PPP Note and ACH
Authorization, We are working extremely hard on your
behalf and anticipate disbursing funds within 10 days of

IMPORTANT: Please be sure to send all of the items
below, in the same email to lupe(@ harvestcref.com:

® Executed PPP Note (docusign or physical
“wet” signature)

® Completed ACH Authorization (Vendor
Contact is you or your company info)

© Copy of voided check’ letter from
bank (including Account Name.

Account#, Routing?)

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.46 Filed 05/26/23 Page 46 of 55

(Affiant note: The conversation above shows ANASI, SAMER and SHABA were
all involved in the process of applying for the fraudulent WPC PPP loan.)

ANAST Financial Summary

84. Comerica and JPMorgan Chase Banks provided records for multiple
accounts associated with SAMER and ANASI, pursuant to a subpoena. The table

below shows CS and WPC PPP loan proceeds being transferred into ANASI’s

personal accounts:

PPP Funds Transferred to Christina Anasi ITF Samer Kammo x5175 (Comerica)

Account
Date From Disbursed To Tier 1 Tier 2
CRF PPP Loan C&S Liquor x9259
5/07/2020 (CS) (Comerica) $75,500
C&S Liquor
x9259 Christina Anasi x5175
5/08/2020 (Comerica) (Comerica) $50,000
C&S Liquor
x9259 Christina Anasi x5175
5/11/2020 (Comerica) (Comerica) $25,500
Celtic Bank
PPP Loan Anasi Detroit Property
5/22/2020 (WPC) x9370 (JPMC) $564,032
Anasi Detroit
Property Christina Anasi x5175
5/22/2020 x9370 (JPMC) (Comerica) $50,000
Total
x5175= $125,500
PPP Funds Transferred to Christina Anasi ITF Samer Kammo x4936 (Comerica) Account
Date From Disbursed To Tier 1 Tier 2 Tier 3
Celtic Bank
PPP Loan Anasi Detroit Property
5/22/2020 (WPC) x9370 (JPMC) $564,032
Anasi Detroit
Property Christina Anasi x4936
5/22/2020 x9370 (JPMC) (Comerica) $45,000
Christina
Anasi x4936 Kammo, Steve (Gift
5/22/2020 (Comerica) for Home) $30,000

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.47 Filed 05/26/23 Page 47 of 55

Total
x4936= $45,000

From December 2019 through the end of April 2020 ANASI’s checking account
x4936 maintained a balance of $20,000 or less and her savings account x5175
maintained a balance of about $3,000. $125,500 in fraudulently obtained PPP loan
proceeds were transferred to ANASI’s savings account and $45,000 to her checking
account. Within a day of the $45,000 being transferred to ANASI’s checking
account, a $30,000 check was written to Steven Kammo (SAMER KAMMO’s
Brother) noting “Gift For Home”. The check appears to have been endorsed by
ANASI. These funds are not being used for PPP authorized purposes, Steven
Kammo was in the process of purchasing a home and was provided PPP proceeds to
use for that purchase. The $125,500 transferred into x5175 remained in the account
until 1t was seized during this investigation.

85. All ofthe fraudulently obtained CS PPP loan proceeds were transferred
into ANASI’s personal account shortly after being received. Text messages
discussed above between ANASI and SHABA indicate that ANASI wanted the
money in her personal account. ANASI ended up with all of the CS PPP loan
proceeds transferred into her personal account as she indicated in the text messages.
The messages also showed ANASI had access to the accounts and stated the

accounts were in fact her accounts. Also an additional $50,000 of the WPC PPP

46
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.48 Filed 05/26/23 Page 48 of 55

loan proceeds were transferred into ANASI’s account. These PPP loan proceeds
were not used for PPP authorized expenses.

Additional SHABA Phone Evidence

86. ANASI and SHABA exchanged thousands of text messages, many
regarding fraudulent activities. Below are additional messages between ANASI and
SHABA:

e 4/15/2020- Sent by SHABA- Samer wants me to fill out these forms
but I don’t feel comfortable asking for the business banking account
information and I don’t want to have that personal information. So you
can fill out this application. I will send you the answers.

e 4/15/2020- Sent by ANASI- They just act dumb...?’ve showed him
how to forward an email about 500 times and he still don’t know how
to do it.

e 4/15/2020- Sent by ANASI- Girl....don’t get married

(Affiant Note: These last two messages indicate SAMER does not know how to
forward an email, speaking to his lack of computer abilities.)

e 4/15/2020- Sent by ANASI- Yea but samer doesn’t have a personal
banking account

e 4/15/2020- Sent by SHABA- So when he files for taxes does the refund

check come in the mail

47
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.49 Filed 05/26/23 Page 49 of 55

e 4/15/2020- Sent by ANASI- Yup
(Affiant Note: These last three messages confirm accounts x4936 and x5175 are
ANASTI’s accounts and not under SAMER’s control.)

e 4/15/2020- Sent by SHABA- I wish I was getting unemployment I
seriously tried every scam possible to get some type of check and I got
denied for everything.

e 4/21/2020- Sent by SHABA- Can you check Samer’s email for me and
see if he received anything from DEGC small business program please.

e 4/21/2020- Sent by ANASI- Hey babe.. no I don’t see anything

e 4/23/2020- Sent by SHABA- Do you want direct deposit or have a card
like samer

e = 4/23/2020- Sent by ANASI- Direct

e = 4/23/2020- Sent by SHABA- Login and enter you bank information

e 4/23/2020- Sent by SHABA- Can you apply for that loan again please.

e 4/23/2020- Sent by ANASI- I checked on it yesterday and I just did
again

e 4/24/2020- Sent by ANASI- What kind of self employed work do I do?
Cashier?

e 4/24/2020- Sent by SHABA- No say assistant manager and Samer is
the manager.

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.50 Filed 05/26/23 Page 50 of 55

4/24/2020- Sent by SHABA- Because I backed dated it so you can get
more money.

4/24/2020- Sent by ANASI- And I added by bank account info... samer
can wait for his check that’s never gonna come

4/24/2020- Sent by SHABA- Don’t let him take any loans out under
your name

4/24/2020- Sent by ANASI- I got my own bank account.... And
whatever goes in don’t come out

4/24/2020- Sent by ANASI- Samer isn’t cheap that’s whyyyy I don’t
trust him cuz he blows all his money

4/25/2020- Sent by SHABA- It’s basically a fake ass application and
that’s why I have a ughhhh feeling

4/25/2020- Sent by ANASI- Andddddd I’m praying to God they don’t
find out about D&H store

4/28/2020- Sent by SHABA- And the total is...$75,500.

(Affiant note: as discussed above, CS received a fraudulent$75,500 PPP loan.).

5/2/2020- Sent by ANASI-We should put it in C&S and I'll write a
check from there.
10/9/2020- Sent by SHABA- They caught us.

10/9/2020- Sent by SHABA- Slewai

49
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.51 Filed 05/26/23 Page 51 of 55

e 10/9/2020- Sent by SHABA -They caught him.

e 10/9/2020- Sent by SHABA - I’m talking to Samer.
(Affiant note: This exchange on October 9, 2020 occurred after a seizure warrant
was executed on October 9, 2020 for proceeds of a fraudulent PPP loan to JD Hydro
LLC. The JD Hydro PPP loan was submitted from the Doctor’s Office and the loan
was in the name of SA, SAMER’s cousin. SHABA communicated with ANASI and
SAMER regarding the seizure. Seizing these funds was the first overt investigative
activity during the investigation.)

Unemployment Insurance Fraud

87. The text messages above along with many other messages not included
in this affidavit, appear to also show SHABA instructed ANASI on how to
fraudulently obtain Unemployment Insurance benefits.

88. Records from the State of Michigan show that ANASI applied for
unemployment insurance benefits in April 2020. As part of the application, ANASI
submitted a purported 1099 tax form for 2019 showing that she had earned $78,350
in nonemployee compensation from C & S Liquor, Inc. ANASI also indicated on
the unemployment insurance benefit application the same income information.
ANASI requested that her unemployment benefits be paid to account x4936, which,

as noted above, is an account in her name.

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.52 Filed 05/26/23 Page 52 of 55

89. Tax records from CPA CB demonstrate that C&S did not, in fact, issue
a 1099 tax form to ANASI for tax year 2019 and the only income reported jointly
by ANASI and Samer that year was $45,500 from C&S Liquor, which was the
amount paid to Samer Kammo, not ANASI, as reflected in a W-2 tax record issued
to Samer Kammo.

90. State of Michigan records show that ANASI’s unemployment
insurance claim was accessed by the .171 IP addressed associated with her home and
the .41 IP address associated with the Doctor’s office that employs Shaba—both of
which are discussed above.

91. After submission of her fraudulent application for unemployment
insurance benefits, ANASI continued to falsely certify her entitlement to benefits.

92. State of Michigan records indicated that ANASI received over $26,000

in improper unemployment insurance benefits in 2020.

Summary

93. There were also PPP loan applications for DH, WPC and multiple other
business entities associated with ANASI, SHABA, and SAMER involved in this
investigation which were submitted to Kabbage which were not approved. It appears
that ANASI, SAMER and SHABA applied at multiple lenders for various business
entities, seeing which lender would approve a PPP loan. After the group found a

lender that would approve their PPP loan, they often submitted multiple other loans

51
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.53 Filed 05/26/23 Page 53 of 55

to the same lender using the same and/or slightly altered documents used for the
approved loan.

94. Your Affiant has identified a total of 18 different businesses associated
with ANASI, SAMER and SHABA that submitted fraudulent PPP loan applications
to the SBA. Text messages show ANASI had knowledge and/or was a part of
submitting other fraudulent PPP loan applications not addressed in this affidavit.
Nine of the businesses linked to these individuals received PPP loans, totaling
$3,384,872.50 in fraudulent PPP loans. A total of $2,102,065.33 of the PPP loan
proceeds have been seized during this investigation. ANASI was involved with the
PPP loans explained in this affidavit and many more loans that were not mentioned.

95. It is evident that CPA’s MF and CB did not fill out the tax forms that
list them as preparer or give anyone consent to use their names on the forms. Based
on interviews and a review of electronic evidence, SK and BA did not give ANASI,
SHABA or SAMER consent to apply for PPP loans in their names. ANASI, SHABA
and SAMER used the identities mentioned in this paragraph as part of a fraudulent
scheme to defraud the government without the consent of these individuals.

96. PPP loan applications submitted to Harvest, Celtic, First Home Bank
and CRF were submitted electronically through interstate wires. These loan
applications were submitted from IP addresses associated with locations in

Michigan. These lenders do not appear to have any locations in Michigan; Celtic

52
Case 2:23-mj-30217-DUTY ECF No.1, PagelD.54 Filed 05/26/23 Page 54 of 55

(Utah), CRF (Minnesota), First Home Bank (Florida) and Harvest (California and
New York). Any communications with lenders and submission of PPP loan
paperwork involved interstate wires. Also the wire transfer of funds that funded the

PPP loans and ANASI’s unemployment assistance involved interstate wires.

CONCLUSION

97. Based on the foregoing, there is probable cause to believe that
CHRISTINA ANASI has committed federal crimes, including, but not limited to,
violations of the following statutes; 18 U.S.C. § 1343 (Wire Fraud), 18 U.S.C. §1344
(Bank Fraud); 18 U.S.C. § 1349 (Conspiracy to Commit Wire Fraud and Bank
Fraud); 18 U.S.C. § 1957 (Money Laundering), 18 U.S.C. § 1028A (Aggravated
Identity Theft) and 18 U.S.C. § 1014 (False Statements in Connection with a Bank
Loan).

REQUEST FOR SEALING

98. It is respectfully requested that this Court issue an order sealing, until
further order of the Court, all papers submitted in support of this application,
including the application and search warrant. I believe that sealing this document is
necessary because the items and information to be seized are relevant to an ongoing
investigation into the criminal organization as not all of the targets of this

investigation will be searched at this time. Premature disclosure of the contents of

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Case 2:23-mj-30217-DUTY ECF No.1, PagelD.55 Filed 05/26/23 Page 55 of 55

this affidavit and related documents may have a significant and negative impact on

the continuing investigation and may severely jeopardize its effectiveness.

Respectfully submitted,
et las

Special Agent Brent Nida
Federal Bureau of Investigation

Sworn to before me and signed in my presence
And/or by reliable electronic means.

4 , a. Sot hoed. Dated: May 26, 2023

Hon. Elizdveth A. Stafford
United States Magistrate Judge

Dated: May 26, 2023

54


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