Bill of Indictment — U.S. v. Tawana Brown et al. (W.D.N.C.)

Summary

A Bill of Indictment against three defendants, two surnamed Brown and Antionette Rouse, Docket No. 3:25-CR-106 (Case 3:25-cr-00106-KDB-SCR), in the U.S. District Court for the Western District of North Carolina, Charlotte Division, filed May 21, 2025 as Document 1. It cites 18 U.S.C. § 1343 and 18 U.S.C. § 1349. The grand jury alleges that between April 2020 and September 2021 the defendants conspired to defraud the SBA's EIDL program and the PPP through applications with fake tax forms and false statements about gross income and employees, submitting at least fifteen applications. It alleges they obtained at least approximately $124,165, including PPP loans of $20,833 wired by Lender 1 for a purported business, Givin Looks By Jema, and used funds for personal expenses. The grand jury finds probable cause for a forfeiture money judgment of $124,165.

Summary drafted by a model from the text of the original file linked on this page 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

Full text

Text recognized from a scanned document; may contain errors.

FILED

MAY 2 1 2025
IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF NORTH CAROLIN (HS ee ee IST OF NC

CHARLOTTE DIVISION
UNITED STATES OF AMERICA DOCKET NO. 3:25-CR- 106-400

v. BILL OF INDICTMENT

)
)
)
)
) Violations: 18U.S.C. § 1343
(1) TAWANA BROWN, ) 18 ULS.C. § 1349
(2) TITIEMA BROWN, )

(3) ANTIONETTE ROUSE, )

)
)
)
)

Defendants.

THE GRAND JURY CHARGES:
At the specified times and at all relevant times:

Introduction

1. TIAWANA BROWN, TIJEMA BROWN, and ANTIONETTE ROUSE, the
Defendants, were full-time or part-time residents of Mecklenburg County, North Carolina, within
the Western District of North Carolina. TIAWANA BROWN was the mother of TIJIEMA
BROWN and ANTIONETTE ROUSE.

2. Between April 2020 and September 2021, TIAWANA BROWN, TIJEMA
BROWN, and ANTIONETTE ROUSE conspired to execute a wire fraud scheme to defraud the
Small Business Administration’s (SBA) Economic Injury Disaster Loan (EIDL) program and its
Paycheck Protection Program (PPP) to obtain COVID-19 pandemic relief funds through the
submission of loan applications containing false information or false documentation. The false
documentation generally included fake and fraudulent tax forms that lied about gross income and
number of employees, among other misrepresentations. Defendants also submitted false
statements for PPP loan forgiveness. Defendants submitted at least fifteen applications for EIDL

or PPP funds.

3. The Defendants obtained at least approximately $124,165 in funds from their
fraudulent EIDL and PPP loans. Defendants used the fraudulently obtained pandemic relief funds
on, among other things, personal expenses, in violation of the terms of the EIDL program and the
PPP. Approximately one month after receiving $20,833 in PPP loan proceeds, TTAWANA
BROWN spent approximately $15,000 for a birthday party for herself.

1
Case 3:25-cr-00106-KDB-SCR Documenti1 Filed 05/21/25 Page1ofi1i

CHARLOTTE, NC
The CARES Act, EIDL, and PPP

4, On March 13, 2020, the President declared an emergency under Section 501(b) of
the Robert T. Stafford Disaster Relief and Emergency Assistance Act in response to coronavirus
disease 2019 (COVID-19). On March 27, 2020, the President signed into law the Coronavirus Aid,
Relief, and Economic Security (CARES) Act, which was designed to provide emergency financial
assistance to the millions of Americans suffering the economic effects caused by the COVID-19
pandemic. The CARES Act established several new temporary programs and provided for the
expansion of others, including programs created and/or administered by the SBA to administer the
emergency relief.

5, One of the programs expanded by the CARES Act was the EIDL program, which
was an SBA program that provided low-interest financing to qualifying small businesses in regions
affected by declared disasters,

a, EIDL proceeds could only be used for working capital for the small
businesses to alleviate economic injury caused by the disaster (related to the COVID-19
pandemic) occurring in the month of January 2020 and continuing thereafter.

b. EIDL funds were issued directly from the United States Treasury, and an
applicant applied on behalf of their qualifying business through the SBA via an online
portal. In the electronic application, the applicant certified that all of the information in the
application was true and correct to the best of the applicant’s knowledge and was warned
that any false statement or misrepresentation to the SBA or any misapplication of loan
proceeds may result in sanctions, including criminal penalties. The application also stated
that the SBA relies upon the self-certifications in the EIDL application in determining
whether the applicant was eligible for an EIDL.

C. The EIDL application process collected information concerning the
business and the business owner, including information regarding the business’s gross
revenue for the 12-month period preceding the disaster, which for COVID-19 was defined
as January 31, 2020; the cost of goods sold for the 12-month period preceding the disaster;
the number of employees employed by the business at the time of the disaster; information
as to the criminal history of the business owners; and information regarding anyone that
assisted in the preparation of the application.

6. Another source of relief provided by the CARES Act was the authorization of
forgivable loans to small businesses for job retention and certain other expenses, through a
program referred to as the PPP.

a, In order to obtain a PPP loan, a qualifying business submitted a PPP loan
application, which was signed by an authorized representative of the business. The PPP
loan application required the business (through its authorized representative) to
acknowledge the program rules and make certain affirmative certifications to be eligible to
obtain the PPP loan. In the PPP loan application (SBA Form 2483), the small business
(through its authorized representative) was required to provide, among other things, its: (a)
average monthly payroll expenses; and (b) number of employees. These figures were used
to calculate the amount of money the small business was eligible to receive under the PPP.

2
Case 3:25-cr-00106-KDB-SCR Document1 Filed 05/21/25 Page2of11
In addition, businesses applying for a PPP loan were required to provide documentation
showing their payroll expenses.

b. A PPP loan application was processed by a participating lender. If a PPP
loan application was approved, the participating lender funded the PPP loan using its own
monies. While the lender issued the PPP loan, the SBA provided a guarantee that the
financial institution would be reimbursed. 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.

C, PPP loan proceeds were required to be used by the business on certain
permissible business expenses such as payroll costs, interest on mortgages, rent, and
utilities. The PPP allowed the interest and principal on the PPP loan to be entirely forgiven
if the business represented, under penalty of perjury, that it spent the loan proceeds on these
expenses within a designated period of time and used a defined portion of the PPP loan
proceeds on payroll expenses. .

Fraudulent EIDL Applications Submitted by Defendants

7, On or about June 25, 2020, TAWANA BROWN submitted and caused to be
submitted EIDL application *6408 to the SBA via an online submission in the name of a sole
proprietorship business in the name TIAWANA BROWN. In the application, TIAWANA
BROWN falsely represented that her business was a “personal services” business with 11
employees and $14,300 in gross revenues from 2019 that had operated since May 24, 2018. In
the application, TTAWANA BROWN provided a social security number of a third party but
represented that it was the social security number of TAWANA BROWN. TIAWANA BROWN
certified under penalty of perjury that the information in EIDL application *6408 was correct and
that she would use the funds as directed by the EIDL program. The SBA rejected this loan
application.

8. On or about June 25, 2020, approximately 13 minutes after EIDL application
*6408 was submitted to the SBA, TITEMA BROWN submitted and caused to be submitted EIDL
application *8889 to the SBA via an online submission in the name of a sole proprietorship
business in the name TEMA BROWN. In the application, TIIEMA BROWN falsely
represented that her business was a “personal services” business with 11 employees and $14,300
in gross revenues from 2019. EIDL applications *6408 and *8889 falsely: represented that each
business had the same address, the same number of employees, the same 2019 gross revenue, and
the same business description, despite purporting to be two different businesses. TIJEMA
BROWN certified under penalty of perjury that the information in EIDL application *8889 was
correct and that she would use the funds as directed by the EIDL program. Upon receipt of EIDL
application *8889, the SBA approved a $10,000 advance on the loan application. On or about
June 30, 2020, the SBA wired $10,000 to a bank account in the name of TJIEMA BROWN ending
in *2364 pursuant to the EIDL application.

9. On or about June 26, 2020, the day after EIDL applications *6408 and *8889 were
submitted, ANTIONETTE ROUSE submitted and caused to be submitted EIDL application
*2483 to the SBA via an online submission in the name of a sole proprietorship business in the

3
Case 3:25-cr-00106-KDB-SCR Documenti1_ Filed 05/21/25 Page 3of11
name ANTIONETTE ROUSE. In the application, ANTIONETTE ROUSE falsely represented
that her business was a “personal services” business with 12 employees and $11,300 in gross
revenues from 2019 that had operated since April 16, 2018, at the same address as the prior
applications. ANTIONETTE ROUSE certified under penalty of perjury that the information in
EIDL application *2483 was correct and that she would use the funds as directed by the EIDL
program. Upon receipt of EIDL application *2483, the SBA approved a $10,000 advance on the
loan application. On or about June 30, 2020, the SBA wired $10,000 to a bank account in the
name of ANTIONETTE ROUSE ending in *8475 pursuant to the EIDL application. On July 2,
2020, this EIDL application was rejected by the SBA due to a failure to substantiate an economic
injury. EIDL applications *6408, *8889, and *2483 were all submitted to the SBA from the same

IP address.

10. On or about August 31, 2020, Defendants submitted and caused to be submitted
EIDL application *1392 to the SBA via an online submission in the name of a sole proprietorship
business in the name La’Stephanie Brown. In the application, Defendants falsely represented that
the business was a “health services” business with 5 employees and $134,000 in gross revenues
from 2019 that had operated since March 3, 2017, at the same address as the three prior
applications. La’Stephanie was the middle name of TJEMA BROWN. On EIDL application
*1392, in the name La’Stephanie Brown, Defendants provided TITEMA BROWN’s social
security number, TIIEMA BROWN’s bank account ending in *2364, and TAWANA BROWN’s
phone number. Defendants certified, as “La’ Stephanie Brown,” under penalty of perjury that the
information in EIDL application *1392 was correct and that they would use the funds as directed
by the EIDL program. The SBA rejected this loan application.

11. The next day, on or about September 1, 2020, TAWANA BROWN submitted and
caused to be submitted EIDL application *1665 to the SBA via an online submission in the name
of a sole proprietorship business in the name TIAWANA BROWN. In the application,
TIAWANA BROWN falsely represented that her business was a “health services” business with
8 employees and $142,000 in gross revenues from 2019 that had operated since April 4, 2018.
The information provided for this business by TIAWANA BROWN in EIDL application *1665
was inconsistent with the information provided for the same business in EIDL application *6408.
TIAWANA BROWN certified under penalty of perjury that the information in EIDL application
*1665 was correct and that she would use the funds as directed by the EIDL program. The SBA
rejected this loan application. EIDL applications *1392 and *1665 were submitted to the SBA
from the same IP address.

12. On or about August 17, 2021, TEMA BROWN submitted and caused to be
submitted EIDL application *7105 to the SBA via an online submission in the name of a sole
proprietorship business in the name TIIEMA BROWN. In the application, TJIEMA BROWN
represented that her business was a “entertainment services” business with 2 employees and
$15,500 in gross revenues from 2019 that had operated since May 25, 2017. TWTEMA BROWN
certified under penalty of perjury that the information in EIDL application *7105 was correct and
that she would use the funds as directed by the EIDL program. The SBA rejected this loan

application.

4
Case 3:25-cr-00106-KDB-SCR Documenti1 Filed 05/21/25 Page4of11
Tijema Brown’s PPP Loan Applications

13. Lender 1 was California-based a small business lending company. Lender 1
participated in the SBA’s PPP as a lender and, as such, was authorized to lend funds to eligible
borrowers under the terms of the PPP.

14. On or about April 3, 2021, TITEMA BROWN submitted and caused to be
submitted a PPP application for a loan numbered *8703 to Lender 1.

a. In the application materials, TIIEMA BROWN falsely stated that she
operated a sole proprietorship business in her own name that was established on January
1, 2020, which generated $106,600 in gross income in 2019.

b. As part of the application, TTEMA BROWN submitted and caused to be
submitted a fake 2019 Internal Revenue Service (IRS) Schedule C Form for the purported
business. The fake Schedule C Form was in the name of TITEMA BROWN under the
business name Givin Looks By Jema. The form falsely stated that Givin Looks By Jema
earned $106,600 in gross receipts and had $10,350 in expenses, resulting in $96,250 in
net profits in 2019. This form was fake, as it was never filed with the IRS.

C, In her application, TITIEMA BROWN stated that she would use the loan
funds to pay payroll costs. TITEMA BROWN certified under penalty of perjury that the
information in the PPP application was true and correct.

d. As a result of PPP loan *8703, Lender 1 wired $20,833 in PPP loan funds
to TVEMA BROWN to her bank account ending in *2364 on April 16, 2021.

e, On or about August 20, 2021, the SBA reimbursed Lender 1 and forgave.
TIJEMA BROWN for this loan based on TJEMA BROWN’s false representation under
penalty of perjury that she spent $12,500 of the loan funds on payroll costs for the
purported business and complied with all applicable PPP rules, including those regarding
the eligible uses of PPP loan proceeds.

15. On or about April 26, 2021, TEMA BROWN submitted and caused to be
submitted a second draw PPP application for a loan numbered *8907 to Lender 1.

a, The application materials contained the same false information and false
documentation as PPP loan *8703 in the name TIJEMA BROWN and Givin Looks By
Jema, including the fake 2019 IRS Schedule C Form in the name of Givin Looks By Jema.

b. In her application, TEMA BROWN stated that she would use the loan
funds to pay payroll costs. TITEMA BROWN certified under penalty of perjury that the
information in the PPP application was true and correct.

C. As aresult of PPP loan *8907, Lender 1 wired $20,833 in PPP loan funds
to TJEMA BROWN to her bank account ending in *2364 on May 10, 2021,

5
Case 3:25-cr-00106-KDB-SCR Document1- Filed 05/21/25 Page5of11 |
d. On or about August 24, 2021, the SBA reimbursed Lender 1 and forgave
TIJEMA BROWN for this loan based on TEMA BROWN’s false representation under
penalty of perjury that she spent $12,500 of the loan funds on payroll costs for the
purported business and complied with all applicable PPP rules, including those regarding
the eligible uses of PPP loan proceeds.

Antionette Rouse’s PPP Loan Applications

16. Lender 2 was a Florida-based small business lending company. Lender 2
participated in the SBA’s PPP as a lender and, as such, was authorized to lend funds to eligible
borrowers under the terms of the PPP.

17. On or about April 15, 2021, ANTIONETTE ROUSE submitted and caused to be
submitted a PPP application for a loan numbered* 8804 to Lender 2.

a. In the application materials, ANTIONETTE ROUSE falsely stated that she
operated a sole proprietorship business in her own name that was established on January
1, 2019, which generated $106,600 in gross income in 2019.

b. As part of the application, ANTIONETTE ROUSE submitted and caused
to be submitted a fake 2019 IRS Schedule C Form for the purported business. The fake
Schedule C Form was in the name of ANTIONETTE ROUSE for a business with the same
name. The form falsely stated that the business earned $106,600 in gross receipts and had
$10,350 in expenses, resulting in $96,250 in net profits in 2019. This form was fake, as
it was never filed with the IRS. This fake 2019 Schedule C Form was identical to the
2019 Schedule C Form submitted for PPP loan *8703 under the business name Givin
Looks By Jema for TJEMA BROWN, other than business identity information.

c. In her application, ANTIONETTE ROUSE stated that she would use the
loan funds to pay payroll costs. ANTIONETTE ROUSE certified under penalty of perjury
that the information in the PPP application was true and correct.

d. As a result of PPP loan *8804, Lender 2 wired $20,833 in PPP loan funds
to ANTIONETTE ROUSE to her bank account ending in *8475 on May 4, 2021.

e. On or about September 13, 2021, the SBA reimbursed Lender 2 and
forgave ANTIONETTE ROUSE for this loan based on ANTIONETTE ROUSE’s false
representation under penalty of perjury that she spent $12,500 of the loan funds on payroll
costs for the purported business and complied with all applicable PPP rules, including
those regarding the eligible uses of PPP loan proceeds.

18. Lender 3 was California-based a small business lending company. Lender 3
participated in the SBA’s PPP as a lender and, as such, was authorized to lend funds to eligible
borrowers under the terms of the PPP.

6
Case 3:25-cr-00106-KDB-SCR Document1 Filed 05/21/25 Page6of11
19. On or about May 20, 2021, ANTIONETTE ROUSE submitted and caused to be
submitted a second draw PPP application for a loan numbered *9004 to Lender 3.

a. The application materials contained the same false information and false
documentation as PPP loan *8804 in the name ANTIONETTE ROUSE, including the
fake 2019 IRS Schedule C Form in the name of ANTIONETTE ROUSE.

b. In her application, ANTIONETTE ROUSE stated that she would use the
loan funds to pay payroll costs. ANTIONETTE ROUSE certified under penalty of perjury
that the information in the PPP application was true and correct. This loan was then
transferred from Lender 3 to Lender 1.

C. As aresult of PPP loan *9004, Lender 1 wired $20,833 in PPP loan funds
to ANTIONETTE ROUSE to her bank account ending in *8475 on June 4, 2021.

d. On or about August 24, 2021, the SBA reimbursed Lender 1 and forgave
ANTIONETTE ROUSE for this loan based on ANTIONETTE ROUSE’s false
representation under penalty of perjury that she spent $12,500 of the loan funds on payroll
costs for the purported business and complied with all applicable PPP rules, including
those regarding the eligible uses of PPP loan proceeds.

Tiawana Brown’s PPP Loan Application

20. On or about April 26, 2021, TIAWANA BROWN and TEMA BROWN
submitted and caused to be submitted a PPP application for a loan numbered *8906 to Lender 1.

a. In the application materials, TA WANA BROWN and TIIEMA BROWN
falsely stated that TTA WANA BROWN operated a sole proprietorship business in her own
name that was established on January 1, 2020, which generated $106,600 in gross income
in 2019.

b. As part of the application, TAWANA BROWN and TIJEMA BROWN
submitted and caused to be submitted a fake 2019 IRS Schedule C Form for the purported
business. The fake Schedule C Form was in the name of TIAWANA BROWN under the
business name TC Collection. The form falsely stated that TC Collection earned $106,600
in gross receipts and had $10,350 in expenses, resulting in $96,250 in net profits in 2019.
This form was fake, as it was never filed with the IRS. This fake 2019 Schedule C Form
was identical to the 2019 Schedule C Forms submitted for PPP loan *8703 and PPP loan
*8804 under the business names Givin Looks By Jema and ANTIONETTE ROUSE,
respectively, other than business identity information.

on In the application, TAWANA BROWN and TISEMA BROWN stated that
TIAWANA BROWN would use the loan funds to pay payroll costs. TIAWANA
BROWN and TITEMA BROWN certified under penalty of perjury that the information in
the PPP application was true and correct.

7
Case 3:25-cr-00106-KDB-SCR Document1 Filed 05/21/25 Page 7of11
d. As a result of PPP loan *8906, Lender 1 wired $20,833 in PPP loan funds
to TAWANA BROWN to her bank account ending in *5776 on May 5, 2021. Account
*5776 was a non-profit business checking account in the name of a non-profit entity
named Beauty After The Bars and TTAWANA BROWN.

€. On or about August 24, 2021, the SBA reimbursed Lender 1 and forgave
TIAWANA BROWN for this loan based on TIAWANA BROWN’s false representation
under penalty of perjury that she spent $12,500 of the loan funds on payroll costs for the
purported business and complied with all applicable PPP rules, including those regarding
the eligible uses of PPP loan proceeds.

21. Between April 2020 and September 2021, Defendants submitted at least three
additional EIDL applications to the SBA in an unlawful attempt to fraudulently obtain program
funds. Such EIDL applications contained misstatements similar to those set forth above.

22. Defendants spent the vast majority of the PPP and EIDL funds on personal
expenses, including purchases of Louis Vuitton merchandise. Approximately one month after
receiving $20,833 in PPP loan proceeds from loan *8906, TIAWANA BROWN made
approximately $15,000 in personal expenditures on a birthday party for herself using the Beauty
After The Bars *5776 non-profit bank account, which contained the PPP loan funds. The party
expenditures included approximately $3,500 for a venue, $5,000 in catering, $2,300 for
photography and video, a balloon arch, a rose wall, a rented throne, and a horse-drawn carriage.

COUNT ONE
(Wire Fraud Conspiracy — 18 U.S.C. § 1349)

23. The Grand Jury realleges and incorporates by reference herein all of the allegations
contained in paragraphs | through 22 of this Bill of Indictment and further alleges that:

24. Beginning in or around April 2020 and continuing through in or around at least
September 2021, in Mecklenburg County within the Western District of North Carolina and
elsewhere, the Defendants,

(1) TIAWANA BROWN,
(2) TIJEMA BROWN, and
(3) ANTIONETTE ROUSE

did knowingly combine, conspire, confederate, and agree with one another to commit wire fraud
in violation of Title 18, United States Code, Section 1343.

Object of the Conspiracy

25. It was a part and an object of the conspiracy that the named Defendants, with the
intent to defraud, did knowingly and intentionally devise the above-described scheme and artifice
to fraud and to obtain money and property by means of materially false and fraudulent pretenses,
representations, and promises, and by concealment of material facts, and for the purpose of
executing such scheme and artifice to defraud, did transmit and cause to be transmitted by means

8
Case 3:25-cr-00106-KDB-SCR Documenti1_ Filed 05/21/25 Page 8of11
of wire communications in interstate commerce any writing, signal, picture, and sound, fo wit,
electronic loan and loan forgiveness applications to the SBA, Lender 1, Lender 2, and Lender 3,
note documents to the same, wire transfers, and other electronic financial transactions, in violation
of Title 18, United States Code, Section 1343.

Manner and Means

26. The Defendants carried out the conspiracy through the manner and means described
in paragraphs | through 22 of this Bill of Indictment, among others.
All in violation of Title 18, United States Code, Section 1349.

COUNT TWO
(Wire Fraud — 18 U.S.C. § 1343)

27. The Grand Jury realleges and incorporates by reference herein all of the allegations
contained in paragraphs | through 22 of this Bill of Indictment and further alleges that:

28. Onor about April 3, 2021 through August 20, 2021, in Mecklenburg County within
the Western District of North Carolina and elsewhere, the Defendant,

(2) TIIEMA BROWN

with the intent to defraud, did knowingly and intentionally devise a scheme and artifice to defraud
and to obtain money by means of materially false and fraudulent pretenses, representations, and
promises, and for the purpose of executing such scheme and artifice to defraud did transmit and
cause to be transmitted, by means of wire communications in interstate commerce, any writing,
signal, picture, and sound, fo wit, the submission of electronic loan and loan forgiveness
applications to Lender 1 and the SBA, note documents to the same, wire transfers, and other
electronic financial transactions.

All in violation of Title 18, United States Code, Section 1343.

COUNT THREE
(Wire Fraud — 18 U.S.C. § 1343)

29, The Grand Jury realleges and incorporates by reference herein all of the allegations
contained in paragraphs | through 22 of this Bill of Indictment and further alleges that:

30. On or about April 14, 2021 through September 13, 2021, in Mecklenburg County
within the Western District of North Carolina and elsewhere, the Defendant,

(3) ANTIONETTE ROUSE

with the intent to defraud, did knowingly and intentionally devise a scheme and artifice to defraud
and to obtain money by means of materially false and fraudulent pretenses, representations, and
promises, and for the purpose of executing such scheme and artifice to defraud did transmit and
cause to be transmitted, by means of wire communications in interstate commerce, any writing,
signal, picture, and sound, fo wif, the submission of electronic loan and loan forgiveness

9
Case 3:25-cr-00106-KDB-SCR Documenti1 Filed 05/21/25 Page9of11
applications to Lender 1, Lender 2, Lender 3, and the SBA, note documents to the same, wire
transfers, and other electronic financial transactions.

All in violation of Title 18, United States Code, Section 1343.

COUNT FOUR
(Wire Fraud — 18 U.S.C. § 1343)

31. The Grand Jury realleges and incorporates by reference herein all of the allegations
contained in paragraphs 1 through 22 of this Bill of Indictment and further alleges that:

32. On or about April 25, 2021 through August 24, 2021, in Mecklenburg County
within the Western District of North Carolina and elsewhere, the Defendants,

(1) TIAWANA BROWN
(2) TITEMA BROWN

with the intent to defraud, did knowingly and intentionally devise a scheme and artifice to defraud
and to obtain money by means of materially false and fraudulent pretenses, representations, and
promises, and for the purpose of executing such scheme and artifice to defraud did transmit and
cause to be transmitted, by means of wire communications in interstate commerce, any writing,
signal, picture, and sound, to wit, the submission of electronic loan and loan forgiveness
applications to Lender 1 and the SBA, note documents to the same, wire transfers, and other
electronic financial transactions.

All in violation of Title 18, United States Code, Section 1343.
NOTICE OF FORFEITURE AND FINDING OF PROBABLE CAUSE

Notice is hereby given of 18 U.S.C. § 982 and 28 U.S.C. § 2461(c). Under Section 2461(c),
criminal forfeiture is applicable to any offenses for which forfeiture is authorized by any other
statute, including but not limited to 18 U.S.C. § 981 and all specified unlawful activities listed or
referenced in 18 U.S.C. § 1956(c)(7), which are incorporated as to proceeds by Section
981(a)(1)(C). The following property is subject to forfeiture in accordance with Section 982 and/or
2461(c):

a, All property which constitutes or is derived from proceeds of violation set forth in
this Bill of Indictment; and

b. If, as set forth in 21 U.S.C. § 853(p), any property described in (a) cannot be located
upon the exercise of due diligence, has been transferred or sold to, or deposited
with, a third party, has been placed beyond the jurisdiction of the court, has been
substantially diminished in value, or has been commingled with other property
which cannot be divided without difficulty, all other property of the defendant/s to
the extent of the value of the property described in (a).

The Grand Jury finds probable cause to believe that the following property is subject to
forfeiture on one or more of the grounds stated above:

10
Case 3:25-cr-00106-KDB-SCR Document1 - Filed 05/21/25 Page 10 of 11
A forfeiture money judgment in the amount of $124,165, such amount constituting the
proceeds of the violations set forth herein.

A TRUE BILL

GRAND JURY FOREPERSQN @

RUSS FERGUSON
UNITED STATES ATTORNEY

MATTHEW WARREN
ASSISTANT UNITED STATES ATTORNEY

11
Case 3:25-cr-00106-KDB-SCR Document1 Filed 05/21/25 Page 11 of 11


File and source

File

1-bill-of-indictment-tiawana-brown-tema-brown-antionette-rouse.pdf

Size

1,320,337 bytes

SHA-256

2eb3eb2d8787c4d163c705ffd6ea1cc756dc82ab2846a443d057c5973c32c6e2

Our copy

1-bill-of-indictment-tiawana-brown-tema-brown-antionette-rouse.pdf

Original

archive.org