Criminal Complaint — No. 1:21-mj-00533 (Dkt. 2, S.D. Ohio)

Summary

A criminal complaint in the U.S. District Court for the Southern District of Ohio, Case No. 1:21-mj-00533, filed as Doc 2 of 8 pages, charging Lashawnda Alexander. The complainant, SA Aaron H. McRorie, U.S. Secret Service, states that on or about a date in 2020 in the county of Hamilton in the Southern District of Ohio the defendant violated 18 U.S.C. § 1343, wire fraud, 18 U.S.C. § 1014, false statements on a loan application, and 18 U.S.C. § 1040, fraud in connection with major disaster or emergency benefits, with the facts in an attached affidavit in support of an application. The complaint was sworn via electronic means, specifically Facetime video, dated Jul 14, 2021, before Stephanie K. Bowman, United States Magistrate Judge, at Cincinnati, Ohio, and the affidavit is sworn at Cincinnati in July 2021.

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

Cite this document

“Criminal Complaint — No. 1:21-mj-00533 (Dkt. 2, S.D. Ohio).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/criminal-complaint-no-1-21-mj-00533-dkt-2-s-d-ohio-a0602deb38/, SHA-256 aabed5b147a1355b868ca30a0d01d2c05a59fea6b782fa4d383ed22c8f94bc95.

Full text

Case: 1:21-mj-00533-SKB Doc #: 2 Filed: 07/14/21 Page: 1 of 8 PAGEID #: 6
AO 91 (Rev. 08/09) Criminal Complaint

UNITED STATES DISTRICT COURT
for the
SouthernDistrict
__________ Districtof
of Ohio
__________

United States of America )
v. )
) Case No. 1:21-MJ-00533
)
LASHAWNDA ALEXANDER
)
)
Defendant(s)

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 6/23/2020 in the county of HAMILTON in the
Southern District of Ohio , the defendant(s) violated:
Offense Description
Code Section

18 U.S.C. § 1343 Wire Fraud
18 U.S.C. § 1014 False Statements on a Loan Application
18 U.S.C. § 1040 Fraud in connection with Major Disaster or Emergency Benefits

This criminal complaint is based on these facts:

SEE ATTACHED AFFIDAVIT

✔ Continued on the attached sheet.
u
Digitally signed by AARON H
AARON H MCRORIE
MCRORIE
Date: 2021.07.14 15:01:04 -04'00'
Complainant’s signature

SA AARON H. MCRORIE, U.S. SECRET SERVICE
Printed name and title

Sworn to before me and signed in my presence.
via electronic means, speci cally Facetime video.

Jul 14, 2021
Date:
Judge’s signature

City and state: CINCINNATI, OHIO Stephanie K. Bowman, United States Magistrate Judge
Printed name and title

fi
Case: 1:21-mj-00533-SKB Doc #: 2 Filed: 07/14/21 Page: 2 of 8 PAGEID #: 7

AFFIDAVIT IN SUPPORT OF
AN APPLICATION FOR A CRIMINAL COMPLAINT

I, Aaron H. McRorie, being first duly sworn, hereby depose and state as follows:

INTRODUCTION

1. I am a Special Agent with the United States Secret Service (USSS) and have been since

June 2019. I am currently assigned to the USSS, Cincinnati Field Office. In this

capacity, I investigate violations of criminal law relating to counterfeit currency, identity

theft, access device fraud, bank fraud, and wire transfer among other offenses. As a

federal agent, I am authorized to investigate violations of laws of the United States and to

execute warrants issued under the authority of the United States. Consequently, I am an

“investigative or law enforcement officer of the United States,” within the meaning of

Section 2510(7) of Title 18, United States Code, that is, an officer of the United States

who is empowered by law to conduct investigations of and to make arrests for offenses

enumerated in Section 2516 of Title 18, United States Code. I received formal training at

the Federal Law Enforcement Training Center (FLETC) in Glynco, GA, and the USSS

Training Academy in Beltsville, MD.

2. I am familiar with the facts and circumstances of this case. The information contained in

this affidavit is either personally known to me, based upon my review of various records

and publicly available information, or has been relayed to me by other agents or sworn

law enforcement personnel. Because this affidavit is being submitted for the limited

purpose of obtaining a criminal complaint, I have not included each and every fact known

to me concerning the investigation. I have set forth only those facts that I believe are

necessary to establish probable cause to support the requested seizure warrant.
Case: 1:21-mj-00533-SKB Doc #: 2 Filed: 07/14/21 Page: 3 of 8 PAGEID #: 8

3. Based on my training and experience and the facts as set forth in this affidavit, there is

probable cause to believe that violations of 18 U.S.C. § 1343 (Wire Fraud), 18 U.S.C.

§ 1014 (False Statements on a Loan Application), and 18 U.S.C. § 1040 (Fraud in

connection with Major Disaster or Emergency Benefits), among other offenses have been

committed by LASHAWNDA ALEXANDER.

PROBABLE CAUSE

A. The government is investigating fraud involving loan programs designed to assist small
businesses during the pandemic.

4. On or about December 15, 2020, the United States Secret Service initiated an

investigation into LASHAWNDA ALEXANDER for suspected violations of 18 U.S.C.

§ 1343 (Wire Fraud) and 18 U.S.C. § 1014 (False Statements on a Loan Application)

based on a review of transactional data showing that deposits stemming from Small

Business Administration (SBA) programs designed to assist small businesses and their

employees during the coronavirus pandemic had been used for purchases and expenses

seemingly unrelated to job retention and other permissible business expenses.

5. Records received via legal process revealed that LASHAWNDA ALEXANDER is the

primary signer for a personal checking account and a business account at PNC Bank.

The accounts in question are as follows: #4157504491 (Business “TressD LLC”)

(Account 1) and #4271676422 (Personal Account “Lashawnda Alexander”) (Account 2).

6. Further review of these records showed that LASHAWNDA ALEXANDER received

three separate deposits, two under Economic Injury Disaster Grant (EIDG) (6/25/2020)

and one under Economic Injury Disaster Loan (EIDL) (6/29/2020) for a total of

$90,900.00. The EIDL and EIDGs were issued by the SBA pursuant to the Coronavirus

Aid, Relief, and Economic Security (CARES) Act, a federal law enacted on March 27,

2
Case: 1:21-mj-00533-SKB Doc #: 2 Filed: 07/14/21 Page: 4 of 8 PAGEID #: 9

2020 designed to provide emergency financial assistance to the millions of Americans

who are suffering the economic effects caused by the COVID-19 pandemic. The EIDL

program is designed to provide economic relief to businesses that are currently

experiencing a temporary loss of revenue due to COVID-19 by supplying working capital

and normal operating expenses such as continuation of health care benefits, rent, utilities,

and fixed debt payments. As part of the SBA’s EIDL program, small businesses could

apply for an EIDG of up to $10,000 that did not need to be repaid. SBA proceeds,

however, must be used by the business on certain permissible expenses, including payroll

costs, interest on mortgages, rent, and utilities. The amount of EIDG and EIDL funds a

business may receive is generally determined by the number of employees and amount of

monthly expenses accrued in the previous year before the pandemic.

B. Alexander’s EIDL applications show significant discrepancies indicative of fraud.

7. Records received from the SBA Office of Inspector General (OIG) confirm that on

6/23/2020 LASHAWNDA ALEXANDER electronically submitted an EIDL application

under the business name “Lashawnda Alexander.” Alexander requested a $46,500.00

loan with a $10,000.00 grant attached. In the application, LASHAWNDA

ALEXANDER stated that the business was an “Agricultural Enterprise” with ten

employees. She further listed the “gross revenues for the 12 months prior to the disaster”

for the business as “$125,000.00,” and the “cost of goods sold for the 12 months prior to

the disaster” as “$12,000.00.” She listed the business address as 1946 Connecticut

Avenue, Cincinnati, OH 45224 and provided an email address of

LAHLAHALEXANDER@GMAIL.COM. The EIDG was approved as an advance on

6/23/2020 and was paid out to “Lashawnda Alexander” (Account 2) on 6/25/2020.

3
Case: 1:21-mj-00533-SKB Doc #: 2 Filed: 07/14/21 Page: 5 of 8 PAGEID #: 10

Shortly thereafter, SBA representatives checked the background of the business and

disqualified the $46,500.00 loan because the business “Lashawnda Alexander” did not

meet eligibility requirements. As a result, bank records show a $10,000 grant related to

this application, but not an EIDL disbursement of $46,500.00.

8. An open source search I conducted confirmed that 1946 Connecticut Avenue, Cincinnati,

OH 45224 is a residential suburban address with no agricultural activity. A search of the

Ohio Secretary of State Registered business listings showed no registration for

“Lashawnda Alexander.” Also, a report I generated using “TLOxd,” a search engine

created by Transunion for law enforcement searches of business, personnel, addresses,

etc. for records. The report showed no businesses associated with that address and listed

the property as “residential.” Based on my training and experience, this is indicative of a

fraudulent loan application using false pretenses and false statements.

9. Further review of the records received from the SBA OIG also show that on 6/24/2020,

LASHAWNDA ALEXANDER electronically submitted a separate application for an

EIDL of $71,000.00 with an EIDG advance of $10,000.00 for the business “TRESSD

LLC.” In the application, LASHAWNDA ALEXANDER stated that the company is a

“Hair & Nail Salon” in the “Personal Services” industry with an open date of 2/23/2018.

She further claimed that the business had 15 employees, had $175,000.00 in gross

revenue the 12 months prior to the disaster, and a “cost of goods sold for the 12 months

prior to the disaster” of $13,000.00. Additionally, the application declares the address of

TRESSD LLC as 4220 Montgomery Rd, Cincinnati, OH 45212. The grant was approved

as an advance on 6/24/2020 and disbursed on 6/24/2020 to Account 1. The loan of

$71,000.00 was then disbursed on 6/25/2020 to Account 1.

4
Case: 1:21-mj-00533-SKB Doc #: 2 Filed: 07/14/21 Page: 6 of 8 PAGEID #: 11

10. A review of PNC Bank records shows that in the initial business checking account

application (Account 1), TRESSD LLC was listed as having an address of 4220

Montgomery Rd, Cincinnati, OH 45212. A search of the Ohio Secretary of State website

found that TRESSD LLC was registered with the Ohio Secretary of State as of

12/29/2019. A TLOxd address report was generated for “4220 Montgomery Rd,

Cincinnati, OH 45212.” According to the report, there have only been three businesses

located at “4220 Montgomery Rd, Cincinnati, OH 45212”: LOUD STYLES BARBER

SALON, RANDYS SPORTS BAR, and THE DEW DROP LOUNGE. The property is

listed as being owned by LOUD STYLES BARBER SALON since 2012. There appears

to be no association between LOUD STYLES BARBER SALON and LASHAWNDA

ALEXANDER. An Experian Credit report pulled by the SBA on 6/23/2020 as part of the

loan application process indicates that LASHAWNDA ALEXANDER has been

employed by a salon called “KOLD CUTS” since December 2013. To date, other than

the SBA loan application, no records have been found to establish a connection between

TRESSD LLC and the listed address. Surveillance on the address shows no indication

that any business other than LOUD STYLES BARBER SALON operates at that address.

11. On or around 3/26/2021, Special Agent James Teuschl and I interviewed the manager of

LOUD STYLES BARBER SALON who stated that he knew LASHAWNDA

ALEXANDER, and that she had previously worked at that business, but did not currently

work there and currently has no affiliations with LOUD STYLES BARBER SALON.

This is further indicative that the EIDL loan application for business “TRESSD”

contained false statements.

5
Case: 1:21-mj-00533-SKB Doc #: 2 Filed: 07/14/21 Page: 7 of 8 PAGEID #: 12

C. EIDL proceeds do not appear to have been used consistent with SBA program rules.

12. Review of Alexander’s associated bank account records show a series of transactions that

do not appear to be business expenses consistent with the EIDL/EIDG program

requirements, including a withdrawal of $9,000.00 in cash from Account 1 by

LASHAWNDA ALEXANDER on 8/3/2020 which appears to be for personal expenses,

an official check from Account 1 on 8/7/2020 for $30,000.00 to “Auto Empire,” a local

car dealership, and a purchase of $1,142.72 from Account 1 to Mercedes Benz Cincinnati

on 8/10/2020. Additionally, records show a series of electronic transfers between

LASHAWNDA ALEXANDER and other individuals that do not appear to be legitimate

payroll expenses, which suggests that others may be involved in the fraud.

13. Notably, between 7/30/2020 and 8/24/2020, LASHAWNDA ALEXANDER spent

approximately $7,954.16 on personal expenses to include flights, hotel rooms,

restaurants, moving companies, home furnishings, and department stores. These do not

appear to be payroll or other covered business expenses and therefore are not expenses

expressly allowed through the loan agreement which further indicates fraud.

D. In addition to SBA loans, Alexander also applied for and received unemployment
assistance.

14. Bank records also show that LASHAWNDA ALEXANDER received approximately

$19,844.00 between 5/21/2020 and 8/26/2020 from the Ohio Department of Jobs and

Family Services (ODJFS) Pandemic Unemployment Assistance (ODJFS-PUA) program.

ODJFS-PUA payments were authorized under the CARES Act to provide unemployment

benefits to support workers suffering as a result of coronavirus pandemic. Based on my

training, knowledge, and experience, I know it is rare for a business owner that has

received funds for two separate businesses large enough to justify SBA grants/loans to

6
Case: 1:21-mj-00533-SKB Doc #: 2 Filed: 07/14/21 Page: 8 of 8 PAGEID #: 13

simultaneously receive unemployment credits as though she was an employee. Based on

my training, knowledge, and experience, I believe this to be a strong indicator of fraud.

CONCLUSION

15. Based on the foregoing facts, I request that the Court issue the proposed criminal

complaint. There is probable cause to believe that LASHAWNDA ALEXANDER

committed violations of 18 U.S.C. § 1343 (Wire Fraud), 18 U.S.C. § 1014 (False

Statements on a Loan Application), and 18 U.S.C. § 1040 (Fraud in connection with

Major Disaster or Emergency Benefits). I, therefore, respectfully request that an arrest

warrant be issued authorizing the arrest of LASHAWNDA ALEXANDER.

Respectfully submitted,

Digitally signed by AARON H MCRORIE
AARON H MCRORIE
____________________________________
Date: 2021.07.14 15:13:25 -04'00'

AARON H. MCRORIE
Special Agent
United States Secret Service

Sworn to and subscribed before me this 14th
______ day of July 2021, at Cincinnati, Ohio.
via electronic means, speci cally Facetime video.

_____________________________________
HONORABLE STEPHANIE K. BOWMAN
UNITED STATES MAGISTRATE JUDGE

File and source

File: 2.pdf
Size: 697,378 bytes
SHA-256: aabed5b147a1355b868ca30a0d01d2c05a59fea6b782fa4d383ed22c8f94bc95
Our copy: 2.pdf
Original: No public link identified.