Factual Basis — United States v. Every (Eastern District of Louisiana, Document 30)

Summary

Factual Basis filed March 2, 2023 as Document 30 in United States of America v. Sharnae Every, Case 2:22-cr-00206-CJB-JVM (Criminal No. 22-206), U.S. District Court for the Eastern District of Louisiana. It states what the government would prove at trial on Count I of the Indictment, charging Conspiracy to Commit Mail Fraud in violation of Title 18, United States Code, Section 1349. It states that the case developed from a referral from the Pandemic Response Accountability Committee regarding possible fraudulent Paycheck Protection Program loans and that Every created a fictitious business used on nearly all of the fraudulent PPP loan applications. It states that Every charged $45.00 to $120.00 to prepare and submit an application and then $3,500.00 once loans were funded, and that approximately 110 fraudulent PPP loan applications were submitted.

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“Factual Basis — United States v. Every (Eastern District of Louisiana, Document 30).” Original at ecf.laed.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-usa-v-every-dkt-30-d038784f55/, SHA-256 a9d07bea274efc4a952c3fc1ace7c3fc7f4634a9fc62217b99b8d4b9cf23a870.

Full text

Case 2:22-cr-00206-CJB-JVM Document 30 Filed 03/02/23 Page 1 of 4

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA

UNITED STATES OF AMERICA * CRIMINAL NO. 22-206

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SHARNAE EVERY
a.k.a. "Isabelle Faith"
a.k.a. "Kaitlyn Known"
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FACTUAL BASIS

Should this matter have gone to trial, the government would have proved through the

introduction of reliable testimony and admissible tangible exhibits, including documentary

evidence, the following to support the allegations charged by the govemment in Count I of the

Indictment now pending against the defendant, SHARNAE EVERY ("EVERY"), charging her

with Conspiracy to Commit Mail Fraud in violation of Title 18, United States Code, Section 1349.

The govemment would establish that the case against EVERY developed as a result of a

referral from the Pandemic Response Accountability Committee ("PRAC") on October 18,2021,

regarding possible fraudulent Paycheck Protection Program loans ("PPP"). Investigators

determined there were at least I l0 PPP sole proprietor loan applications in and around the

Thibodeaux area and they all had the same invoice to Shelita White from the "Natural Hair Afro,

LLC, Houma, LA 70360" and federal tax forms ("Schedule C") with the same business and

amounts.

The investigation revealed that EVERY created a fictitious business called "Natural Hair

Afro, LLC, Houma, LA 70360" and used this fictitious business name on nearly all of the

fraudulent PPP loan applications. EVERY advertised under various aliases on Facebook to recruit

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Case 2:22-cr-00206-CJB-JVM Document 30 Filed 03/02/23 Page 2 of 4

individuals to obtain money from the PPP program. EVERY prepared and submitted false and

fraudulent PPP sole proprietor loan applications via various online portals including, but not

limited, to Blueacorn. EVERY created all of the false and fraudulent invoices, bank statements,

and federal tax forms Schedule C. EVERY falsely certified that the applications and the

information provided in the supporting documents were true and accurate when she electronically

submitted the fraudulent PPP loan applications.

EVERY charged $45.00 to $120.00 from the individuals she recruited to prepare and

submit the fraudulent PPP application. EVERY primarily used Cash App to receive the initial

payments. EVERY then charged $3,500.00 once the loans were funded. EVERY received these

funds into her Current account, her Cash App account, or into her boyfriend's Current account,

("Co-Conspirator A"). In total, EVERY, Co-Conspirator A, and others defrauded the Small

Business Administration (SBA) and other designated financial institutions of approximately

$1,142.041.00 through submission of approximately 110 fraudulent PPP loan applications.

Individual A's PPP Loan

On March 15,202l,Individual A, responded to a Facebook posting of EVERY'S and, as

a result, activated and established Current account ending xxxx. That same day, EVERY

completed Individual A's PPP loan application and submitted it to the Blueacorn portal. The loan

application contained a fraudulent invoice and Schedule C in the name of Individual A. As a result

of opening the Current account, Current card ending xxxx was mailed via the USPS from
Nashville, TN to Individual A at C*<t*< Solar Trlr Park, Thibodaux, LA 70301.

On March 21,2021, Blueacorn submitted Individual A's PPP loan applicationto the SBA's

designated financial institution, Capital Plus, and, on March 23,202l,Individual A's PPP loan

application was approved. On March 23,2021, Individual A activated Current card ending xxxx.

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Case 2:22-cr-00206-CJB-JVM Document 30 Filed 03/02/23 Page 3 of 4

On March 25, 202l,Individual A's PPP final loan documents were electronically signed via

DocuSign. On April l, 202I, Capital Plus deposited $20,832.00 into Individual A's Current

account ending xxxx and then Individual A sent Co-Conspirator A $3,500.00 from the proceeds

of the PPP loan.

On April 7, 2022, Veterans Administration, Office of Inspector General ("VA OIG")

Special Agents interviewed Individual A. Individual A said she heard about PPP loans on

Facebook and that her cousin, EVERY, filled out her PPP loan application. She paid EVERY

$3,000 to complete the application. Individual A did not know the PPP money was a loan.

Individual A thought the money was "owed" to her. EVERY told Individual A the money was

"free" and everyone was getting the money because of the pandemic.

Individual B's PPP Loan

On March 78,2}27,Individual B, responded to a Facebook positing of EVERY's and, as

a result, activated and established Current account ending xxxx. That same day, Current mailed

Individual B's Current card ending xxxx via the USPS from Nashville, TN 16 *** Mall Circle Apt.

**, Houma,LA70364. The next day, EVERY submitted Individual B's PPP loan application to

the Blueacom portal containing a fraudulent invoice and Schedule C in the name of Individual B.

Then on March 20,2021, Blueacorn submitted Individual B's PPP loan application to the SBA's

designated financial institution, Capital Plus. On March 23, 2021, Individual B's PPP loan

application was approved by Capital Plus. On March 26, 2021, Individual B's final loan

documents were electronically signed via DocuSign and, on April 2,2027, Individual B activated

her Current card ending xxxx.

On April 2,2021, Capital Plus deposited $20,832.00 into Individual B's Current account

ending xxxx as a result of the submission of the fraudulent PPP application. That same day,

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Case 2:22-cr-00206-CJB-JVM Document 30 Filed 03/02/23 Page 4 of 4

Individual B sent Co-Conspirator A $2,000.00 and sent EVERY $ 1,500.00 via Cash App from the

proceeds of the fraudulent PPP loan.

VA OIG agents interviewed Individual B on April 7,2022. Individual B said she heard

about PPP loans on Facebook. Individual B said EVERY filled out all the paperwork for her.

Individual B paid EVERY approximately $3,000 for completing the PPP loan. According to

Individual B, EVERY signed all of the loan documents.

Limited Nature of Factual Basis and Conclusion

This proffer of evidence is not intended to constitute a complete statement of all facts

known by EVERY and/or the government. Rather, it is a minimum statement of facts intended to

prove the necessary factual predicate for her guilty plea. The limited purpose of this proffer is to

demonstrate that there exists a sufficient legal basis for the plea of guilty to the charged offense by

EVERY.

The above facts come from an investigation conducted by, and would be proven at trial by

credible testimony from, inter alia, VA OIG Special Agents, the victims, other law enforcement

officers, and computer forensic examiners from VA OIG, as well as from admissible tangible

evidence in the custody of VA OIG.

READ AND APPROVED:

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BRIAN M. KLEBBA (Date)
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JO HALL THOMAS (Date)
Counsel for Defendant

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AE EVERY (Date)
Defendant

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D"f"ndunt-JZ
Defense Counsel <I il.
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