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Criminal Information — Charmaine Redding (Northern District of Georgia, Atlanta Division)

Summary

Criminal information filed 05/27/21 in the Northern District of Georgia, Atlanta Division, charging Charmaine Redding in Count One with Conspiracy to Commit Wire Fraud. It alleges that Redding and co-conspirators used interstate wires to submit a PPP loan application for All Star Room and Board Services of Michigan, Inc. to Financial Institution 1, representing that the company had 59 employees and an average monthly payroll of $295,186.25. The conspiracy is alleged from in or about April 2020 through in or about June 2020, with Thomas named as a co-conspirator. It states that Redding assisted in submitting falsified Form 941s and W-2 payroll spreadsheets, and it includes a forfeiture provision.

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“Criminal Information — Charmaine Redding (Northern District of Georgia, Atlanta Division).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/crim-gand-1-21-cr-00178-u-s-v-charmaine-redding-doc1-information-2021-252b9e8dd3/, SHA-256 41c2c3c8f16c9e773d4079eeadce1f603040db922b59cbc8cf9068f9d1231869.

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        Case 1:21-cr-00178-JPB Document 1 Filed 05/27/21 Page 1 of 7
                                                                         FILED IN OPEN COURT
                                                                            U.S.D.C. Atlanta



                                                                            MAY 'L 1 2021

V^sv<.i^»"                   tiy:         /^<^^^De^Cterk


                   IN THE UNITED STATES DISTRICT COURT
                  FOR THE NORTHERN DISTMCT OF GEORGIA
                            ATLANTA DIVISION


     UNITED STATES OF AMERICA
                                               Criminal Information

     CHARMAINE REDDING I No- 1:21-CR-178



  THE UNITED STATES ATTORNEY CHARGES THAT:

                                     Background

        At all times relevant to tins Information:

  The Defendant and her Co-Conspirator

        1. CHARMAINE REDDING (//REDDING//) was an individual residing in

  the State of Michigan who claimed sole ownership of All Star Room and Board

  Services of Michigan/ Inc./ a Michigan corporation.

        2. DarreU Thomas was an individual residing in the State of Georgia

  who claimed ownership/ and was the Chief Financial Officer, of BeUator Phront

  Group Inc., a Georgia corporation. As of May 21,2020, Thomas claimed to be the

  Chief Executive Officer, Secretary/ and registered agent of Elite Executive

  Services Inc./ a Georgia corporation.

  The Small Business Administration

        3. The United States Small Business Administration (//SBA//) was an

  executive branch agency of the United States government that provided support

  to entrepreneurs and small businesses. The mission of the SBA was to maintain

  and strengthen the nation's economy by enabling the establishment and viability
       Case 1:21-cr-00178-JPB Document 1 Filed 05/27/21 Page 2 of 7




of small businesses and by assisting in the economic recovery of communities

after disasters.

      4. As part of this effort/ the SBA enabled and provided for loans

through banks, credit unions/ and other lenders. These loans had govermnent-

backed guarantees.

The Pay check Protection Program

      5. The Coronavirus Aid/ Relief/ and Economic Security ("CARES") Act

was a federal law enacted in or about March 2020 and was designed to provide

emergency financial assistance to the millions of Americans who are suffering

the economic effects caused by the COVID-19 pandemic.

      6. One source of relief that the CARES Act provided for was the

authorization of up to $349 billion in forgivable loans to smaU businesses for

payroll, mortgage interest, rent/lease/ and utilities, through a program referred

to as the Paycheck Protection Program (//PPP//). Congress subsequently

authorized additional PPP funding.

      7. The PPP allowed qualifying small businesses and other

organizations to receive PPP loans. Businesses were required to use PPP loan

proceeds for 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 spent the loan proceeds on these expense items within a designated

period of time and used a certain percentage of the PPP loan proceeds for payroll

expenses.
        Case 1:21-cr-00178-JPB Document 1 Filed 05/27/21 Page 3 of 7




      8. The amount of a PPP loan that a small business may have been

entitled to receive was determined by the number of employees employed by the

business and the business/s average monthly payroll costs.

      9. In order to obtain a PPP loan/ a qualifying business was required to

submit 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 adEfirmative certifications in order to be eligible to obtain the PPP

loan. In the PPP loan application/ the small business (through its authorized

representative) had to state/ among other thmgs/ 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. In

addition/ businesses applying for a PPP loan had to provide documentation

showing their payroU expenses.

      10. The SBA oversaw the PPP. However/ individual PPP loans were

issued by private/ approved lenders who received and processed PPP

applications and supporting documentation/ and then made loans using the

lenders' own funds/ which were 100% guaranteed by the 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 title

SBA in the course of processing the loan.

      11. Financial Institution 1 was a non-bank financial institution

headquartered in Laguna Hills, California. Financial Institution 1 participated in
        Case 1:21-cr-00178-JPB Document 1 Filed 05/27/21 Page 4 of 7




the SBA/s PPP as a lender/ and as such/ was authorized to lend funds to eligible

borrowers under the terms of the PPP.



                                     Count One

                           Conspiracy to Commit Wire Fraud

      12. The United States Attorney re-alleges and incorporates by reference

the factual allegations contained in paragraphs 1 through 11 of this Information

as if fuUy set forth herein.

      13. From in or about April 2020 through in or about June 2020, the exact

dates unknown/ in the Northern District of Georgia and elsewhere/ the

defendant/

                               CHARMAINE REDDING/

did knowingly and willfully combine, conspire/ confederate/ agree/ and have a

tacit understanding with Darrell Thomas and with others known and unknown,

to devise and intend to devise a scheme and artifice to defraud/ and to obtain

money and property/ by means of materially false and fraudulent pretenses,

representations, and promises/ and by the omission of material facts/ well

knowing and having reason to know that said pretenses were and would be false

and fraudulent when made and caused to be made and that said omissions were

and would be material/ and/ in so doing, with intent to defraud/ caused interstate

and foreign wire communications to be made/ in furtherance of the scheme and

artifice to defraud/ in violation of Title 18, United States Code, Section 1343.
        Case 1:21-cr-00178-JPB Document 1 Filed 05/27/21 Page 5 of 7




                                Manner and Means

      14. On or about June II/ 2020, REDDING and her co-conspirators utilized

interstate wires to submit and assist in the submission of/ a PPP loan application

for All Star Room and Board Services of Michigan, Inc. to Financial Institution 1.

REDDING signed/ or authorized another individual to sign/ All Star Room and

Board Services of Michigan/ Inc. s PPP loan application.

      15. On the PPP loan application for All Star Room and Board Services of

Michigan/ Inc./ REDDING and her co-conspirators falsely and fraudulently

represented that the company had 59 employees and an average monthly payroll

of $295,186.25.

      16. The PPP loan application contained REDDING'S initials to certify each

of the following representations:

             a. The Applicant business was in operation on February 15, 2020

                   and had employees for whom it paid salaries and payroll

                   taxes or paid independent contractors/ as reported on Form(s)

                   1099-MISC;

             b. The funds will be used to retain workers and maintain payroU

                   or make mortgage interest payments/ lease payments/ and

                   utility payments, as specified under the Paycheck Protection

                   Program Rule; and

             c. The information provided in the application and the

                   information provided in all supporting documents and forms

                   is true and accurate in all material respects.
        Case 1:21-cr-00178-JPB Document 1 Filed 05/27/21 Page 6 of 7




       17. REDDDSTG assisted in the submission of falsified IBS Form 941s for

each quarter of 2019 included with All Star Room and Board Services of

Michigan/ Inc/s PPP loan application and falsified W-2 payroll spreadsheets for

January 1 through December 31, 2019 and for January 1 through May 31,2020.

       18. Based on the false and fraudulent representations and submissions

made by REDDING and her co-conspirators/ Financial Institution 1 distributed

approximately $737/965 to AU Star Room and Board Services of Michigan/ Inc.

   All in violation of Title 18, United States Code/ Section 1349.

                                Forfeiture Provision

   Upon conviction of the offense alleged in this Information/ the defendant,

CHARMAINE REDDING, shall forfeit to the United States, pursuant to Title 18,

United States Code/ Section 982(a)(2)/ any property/ real or personal/ constituting

or derived from proceeds obtained/ directly or indirectly/ as a result of the

violation/ including/ but not limited to/ the following:

   i. Money Judgment: A sum of money in United States currency representing

     the amount of proceeds obtained as a result of each offense, or conspiracy to

     commit such offense, for which each defendant is convicted.

   If/ as a result of any act or omission of the defendant(s)/ any property subject

to forfeiture/

   (a) cannot be located upon the exercise of due diligence;

   (b) has been transferred or sold to/ or deposited with/ a third party;

   (c) has been placed beyond the jurisdiction of the court;

   (d) has been substantially diminished in value; or
       Case 1:21-cr-00178-JPB Document 1 Filed 05/27/21 Page 7 of 7




   (e) has been commingled with other property which cannot be divided

   without difficulty/

the United States intends/ pursuant to Title 21, United States Code/ Section

853(p)/ as incorporated by Title 18, United States Code/ Section 982(b)/ to seek

forfeiture of any other property of the defendant up to the value of the forfeitable

property described above.




KURT R. ERSKINE DANIEL S. KAHN
Acting United States Attorney Acting Chief, fraud Section
                                         LT.S. Department of Justice


Ta^C^^ 5^%^&
TALC.CHAIKEN Slfl MOORE
  Assistant United States Attorney Trial Attorney, Fraud Section
Georgia Bar No. 273949 U.S. Department of Justice




NATHAN p. KITCHENS
 Assistant United States Attorney
Georgia Bar No. 263930



600 U.S. Courthouse 1400 New York Ave/NW
75 Ted Turner Drive SW Bond Building/ llth Floor
Atlanta, GA 30303 Washington/ DC 20005
404-581-6000; Fax: 404-581-6181 202-514-2000; Fax: 202-514-3708


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