Criminal Complaint — No. 8:21-mj-01294 (Dkt. 1, M.D. Fla.)

Summary

Criminal complaint and affidavit by FBI Special Agent John E. Herman charging Julio Enrique Lugo, also known as Rick Williams, and Rosenide Venant with conspiracy to defraud the Small Business Administration and false statements to a lending institution over Paycheck Protection Program and EIDL loans. According to the affidavit, approximately 70 fraudulent applications seeking at least approximately $5.8 million were traced to IP addresses at their home in the Middle District of Florida. Lugo was listed as the applicant on at least four loans seeking about $321,485, and Venant on at least 13 seeking about $1.2 million. Lugo is also charged with illegal monetary transactions for using relief funds to pay off a note on a luxury vehicle. The affidavit notes his 2015 conviction for conspiracy to defraud the government and aggravated identity theft.

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“Criminal Complaint — No. 8:21-mj-01294 (Dkt. 1, M.D. Fla.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/criminal-complaint-no-8-21-mj-01294-dkt-1-m-d-fla-de7ba9d95d/, SHA-256 fb1126d02dc56454a52ba1fcfbb2cd761c37a9d576324a758277a75baa6d31fa.

Full text

Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 1 of 32 PageID 1

/\091 ( Rev. 11/11 ) Criminal C.:omplaint

UNITED STATES DISTRICT COURT
for the
Middle District ofFlorida

United States of America
V.
Case No.
Julio Enrique Lugo,
a/k/a "Rick Williams"
8:21MJ1294AAS
Defe11dm,1(s)

CRIMINAL COMPLAINT
1, 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 __March 2020 to August 2020 _ in the county of _ _ _ Polk_ _ _ _ in the
Middle District of Florida , the defendant(s) violated:

Code Section Offense Description
18 U.S.C. s. 371; Conspiracy; False Statement to a Financial Institution; Illegal Monetary
18 u.s.c. s. 1014; Transactions
18 u.s.c. s. 1957

This criminal complaint is based on these facts:

See Affidavit.

0 Continued on the attached sheet.

SA John E. Herman, FBI
Printed 11ame a11d tille
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Sworn to before me and signed iii my p,cscuee. ~• ~ ~ 1'-1- '-, , \ (J.,,.Jj., '-i id) .
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Date: M.c.l<tl--- Llo~~ \ - - ,4~- '
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City and state: AMANDA A. SANSONE, U.S. Magistrate Judge
Printed 11ame and 111/e

I
I

I
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 2 of 32 PageID 2

AFFIDAVIT IN SUPPORT OF WARRANT

I, John E. Herman, being duly sworn, hereby depose and state as follows:

1. I am a Special Agent with the Federal Bureau of Investigation ("FBI"),

and have been since 2007. Prior to joining the FBI, I was Captain in the United States

Army. My duties include investigating federal crimes, including conspiracy, bank

fraud, and wire fraud.

2. As an FBI agent, I am charged with enforcing the laws of the United

States of America, and possess the authority to request, to obtain, and to execute

orders of the United States Courts, including search warrants issued under federal

authority. I have extensive training in investigations, particularly for fraud.

3. This Affidavit supports an application for a criminal complaint and

arrest warrant for JULIO ENRIQUE LUGO, a/k/a "Rick Williams," and

ROSENIDE VENANT, a/k/a "Rose Lugo." As detailed below, LUGO and

VENANT conspired to defraud the Small Business Administration ("SBA") and to

commit other offenses by submitting false and fraudulent information to steal and

attempt to steal coronavirus relief funds from the SBA's Paycheck Protection Program

("PPP") and Economic Injury Disaster Loan ("EIDL") program. In total,

approximately 70 fraudulent loan applications seeking at least approximately $5.8

million in SBA coronavirus relief funds were traced back to Internet Protocol

addresses ("IP-Addresses") assigned to LUGO and VENANT's home in the Middle

District of Florida. LUGO, himself, was listed as the applicant on at least four of the

fraudulent EIDL/PPP loans, which sought a total of approximately $321,485. As for
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 3 of 32 PageID 3

VENANT, she was listed as the applicant on at least 13 fraudulent EIDL/PPP loans,

which sought a total of approximately $1.2 million. Additionally, as detailed later,

LUGO and VENANT had access to and misused EIDL/PPP funds, including to pay

off a note on a luxury vehicle .in violation of 18 U.S.C. § 1957.

4. Based on these acts, as set forth more fully below, probable cause exists

to believe. that LUGO and VENANT violated 18 U.S.C. §§ 371 (conspiracy to

defraud the SBA) and 1014 (false statements to a lending institution). Further,

probable cause exists to believe that LUGO violated 18 U.S.C. § 1957 (illegal

monetary transactions). This Affidavit is intended to show merely that there is

sufficient probable cause for the requested warrant and does not set forth all ofmy

knowledge about this matter.

PROBABLE CAUSE

Overview

5. In 2015, JULIO ENRIQUE LUGO, a/k/a "Rick Williams," was

convicted of conspiracy to defraud the federal government (18 U.S.C. § 286) and

aggravated identity theft (18 U.S.C. § 1028A). United States v. Julio Lugo, Case No.

0:14-cr-60105 (S.D. Fla.), Doc. 59. Then, LUGO had filed 48 fraudulent federal

income tax returns using tax-preparation businesses-including, pertinently, The

Number One Tax Specialist, LLC ("NOTS")-to steal at least $279,000 from the

United States Treasury using the stolen identities of unknowing victims. See id. at

Docs. 33-34. For that conviction, LUGO remains on supervised release. See id. at

2
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 4 of 32 PageID 4

Doc. 59. Now, LUGO is working with new conspirators to steal federal funds-this

time, coronavirus relief funds offered by the SBA-using small businesses and shell

companies like NOTS, which LUGO had used in his previous crimes.

6. The ongoing investigation has revealed that LUGO and VENANT are

conspiring to defraud the SBA with several other close family members. Other

associates and relatives also appear to be involved. The conspirators publicly hold

Florida-registered corporations (the "Lugo Family Companies,,) that have

fraudulently secured coronavirus relief funds. As detailed herein, fraudulent loan and

grant applications for the Lugo Family Companies were electronically filed from IP-

Addresses1 associated with the home where LUGO and VENANT live. The Lugo

Family Companies' fraudulent loan applications sought approximately $2.5 million in

EIDL/PPP funds, resulting in at least $1.6 million of theft as set forth on the below

table. In addition, the same IP-Addresses were the origin for at least 48 other

suspicious EIDL applications for third-party companies. Altogether, the fraudulent

EIDL applications electronically submitted from LUGO and VENANT's house

sought at least approximately $5.8 million from the SBA.

1
Specifically, the IP-Addresses 47.200.4.123 and 47.200.25.251 were assigned to the home
on Preston Avenue in Davenport, Florida, where LUGO and VENANT live. The associated
account for internet service was in VENANT's name.
3
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 5 of 32 PageID 5

Lugo Family SBA EIDL/PPP Loan Applications
Relative Ill Re lative 112

f1
Julio
Rosenide Total Applications
Total Applications
Enrique Applied for 3 SBA EIDL loans
Venant using 2 Florida LLCs
Applied for 2 SBA UDL loans
Lugo using 2 Florida LLCs
Total Applications Claimed LLCs
Total Applications Claimed LLCs
Diamond Taxes and Multi Services;
Applied for 4 SBA loans Applied for 13 SBA loans The Number One To" Specialist;
Consumer Dispute Services
(3 EIDL, 1 PPP) using (8 EIDL, 5 PPP) using Rose Compassionate Care
2 Florida LLCs 5 Florida LLCs EIDL/PPP funding attempted
EIDL/PPP funding attempted
$400,700
and secured:
Lugo's Claimed LLCs Venant's Claimed LLCs
EIDL/PPP funding secured $294,700
Universal Property Vision; Rosenide Tox Consulting;
$273,200
Focerick Cntertainment Rose Garden Recovery Living;
Sisters Compossionote Core;
Lysal-Ceniral, Inc.;
Diamond Taxes and Mu/Ii Services Relative 113 Re lative 114
Applicant for SBA EIDL loan
Applicant for SBA EIOL loan
EIDL/PPP funding attempted for H & C Community
EIDL/PPP funding attempted for H & C Mortgage
$321,485 Development, Inc. and Western
$1,209,553 lnvestmenrs Realty Inc.
Shores Mortgage Investment, Inc.
EIDL/PPP funding secured EIDL/PPP funding secured EIDL funds secured:
$256,485 EIDL funds secured:
$413,742 $121,500.
$249,900

See also, infra, Appendix 1 (Table of Lugo Family PPP /EIDL Loans).

7. Once the EIDL or PPP funds were disbursed, the conspirators

exchanged checks with one another that were falsely labeled as " payroll" and other

qualified expenses. These transactions were designed, at least in part, to conceal the

nature, ownership, and control of the fraud proceeds. The "payroll" checks were

merely pretextual beca use the conspirators ultimately misused the stolen EIDL and

PPP funds, including approximately $47,000 to pay off a note on a 2017 BMvV 7-

Series sedan, over $49,000 in charges at casinos, at least $13,500 spent at weight loss

centers, questionable Zelle transfers exceeding $200,000, and ATM and counter

withdrawals exceeding $320,000. LUGO even publicized his misuse of the SBA funds

in a nearly eight-minute-long video that he posted to his Facebook account2 o n July 1,

2 T he stills on the following page were from a video posted to the Facebook profile named

"Rick W illiams." T he proftle includes numerous depictions of LUGO, VENANT, and h is
4
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 6 of 32 PageID 6

2020. The video featured LUGO and VENANT at a hotel room littered with $100

bills and several items from Louis Vuitton, including, as LUGO stated in the video, a

$5,000 watch. Sample stills from the video are depicted below:

8. This conduct establishes probable cause that LUGO and VENANT

conspired to defraud the SBA in violation of 18 U.S.C. § 371 and violated multiple

federa l criminal statutes, including 18 U.S.C. §§ 1014 and 1957.

Background Regarding the PPP

9. In March 2020, the Coronavirus Aid, Relief, and Economic Security

Act, or the "CARES Act," was enacted to provide immediate assistance to

individuals, families, and organizations affected by the COVID-19 emergency.

conspirators/ relatives. "Rick Williams" is believed to be an alias that pairs his middle name
"Enrique" (for "Rick") with a family surname "Williams."

5
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 7 of 32 PageID 7

Among its various provisions, the CARES Act authorized the SBA to guarantee PPP

loans, the full principal amount of which could qualify for forgiveness.

10. Borrowers were required to use PPP loan proceeds for enumerated

purposes, including payroll costs, 3 rent and utilities, and mortgage interest payments.

Knowing misuse of PPP funds subjected the borrower to additional liability, such as

charges for fraud.

11. Under the PPP, the maximum loan amount is the lesser of $10 million

or an amount calculated using a payroll-based formula specified in the CARES Act.

The payroll-based formula principally considers the borrower's aggregate payroll costs

from the preceding twelve months for all domestic employees. 4 Once an average

monthly payroll cost is established, the borrower multiplies that amount by 2.5 to

arrive at the total maximum PPP loan amount.

12. To apply for a PPP loan, potential borrowers could electronically submit

the SBA Form 2483 with supporting payroll documentation to a financial institution

that administers the loan and serves as custodian of the funds. On the SBA Form

3
Payroll costs consist of compensation to employees (whose principal place of residence is
the United States) in the form of salary, wages, commissions, or similar compensation; cash tips or
the equivalent (based on employer records of past tips or, in the absence of such records, a
, reasonable, good-faith employer estimate of such tips); payment for vacation, parental, family,
medical, or sick leave; allowance for separation or dismissal; payment for the provision of employee
benefits consisting of group health care coverage, including insurance premiums, and retirement;
payment of state and local taxes assessed on compensation of employees; and for an independent
contractor or sole proprietor, wages, commissions, income, or net earnings from self-employment, or
similar compensation.
4
The payroll-based formula expressly excluded (i) any compensation of an employee whose
principal place of residence is outside of the United States; and (ii) the compensation ofan
individual employee in excess of an annual salary of$100,000, prorated as necessary.
6
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 8 of 32 PageID 8

2483, an authorized representative must make several certifications about his business

operations and related information. Those certifications include that: (i) the applicant

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 a Form 1099-MISC;

(ii) current economic uncertainty made the loan request necessary to support the

applicant's ongoing operations; and (iii) the PPP funds would be used to retain

workers and to maintain payroll or pay other qualifying expenses. Upon submitting

the SBA Form 2483, the authorized representative certifies that, should he knowingly

use the PPP funds for unauthorized purposes, the United States could hold ~im

legally liable, including for charges of fraud.

13. Additionally, the applicant must respond to questions regarding his

personal history, including whether he was convicted of a felony and/ or placed on

probation within the previous five years. The PPP loan application expressly states

that, should the applicant respond "yes,,, the PPP loan would "not be approved." The

applicant must also certify the truth and accuracy of any information provided on the

SBA Form 2483 and in all supporting documents. 5 Such supporting documents could

include tax filings with the Internal Revenue Service ("IRS"), such as the IRS Form

W-3 (Transmittal of Wage and Tax Statements), IRS Form 940 (Employer's Annual

5
Borrowers must submit supporting documents to establish loan eligibility for PPP. Such
support could include payroll tax filings (e.g., IRS Forms 940 and 941), payroll processor records,
bank records, or other records sufficient to demonstrate the qualifying payroll amount.

7
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 9 of 32 PageID 9

Federal Unemployment Tax Return), or the IRS Form 941 (Employer's Quarterly

Federal Tax Return).

14. Finally, the applicant must certify the following warning regarding false

statements and other criminal penalties:

I understand that knowingly making a false statement to obtain a
guaranteed loan from SBA is punishable under the law, including under
18 U.S.C. §§ 1001 and 3571 by imprisonment of not more than five
years and/or a fine of up to $250,000; under 15 U.S.C. § 645 by
imprisonment of not more than two years and/ or a fine or' not more
than $5,000; and, if submitted to a federally insured institution, under
18 U.S.C. § 1014 by imprisonment of not more than thirty years and/or
a fine of not more than $1,000,000.

The Conspirators' Fraudulent PPP Loans

15. The ongoing investigation has established that, since March 2020, the

conspirators have fraudulently applied for at least approximately 25 EIDL and PPP

loans using the Lugo Family Companies. These fraudulent loan applications sought

at least $2.5 million in coronavirus relief funds, resulting in over $1.6 million of

disbursed program funds. Of this, at least approximately $378,000 derived from

fraudulent PPP loan applications from LUGO or VENANT as set forth below:

Onor
Approx.
About Associated
# Applicant Company Name Amount
., Application Email Account(s)
Requested
Date
Universal Property
1 Julio Lugo Vision LLC 4/20/2020 $59,485 julioenriquelugo@gmail.com
("UPV")

Rose Garden $60,000
Rosenide
2 Recovery Living 4/8/2020 (loan rosel ugo3 l 80@gmail.com
Venant
Inc. ("RGR") denied)
Rose Garden
Rosenide
3 Recovery Living 4/24/2020 $40,000 roselugo3 l 80@gmail.com
Venant
Inc. ("RGR")

8
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 10 of 32 PageID 10

Sisters
Rosenide
4 Compassionate 5/6/2020 $101,242 rose1ugo3180@gmail.com
Venant
Care LLC (' 1 SCC 11 )
Diamond Taxes
Rosenide
5 and Multi Services 4/20/2020 $40,208 roselugo3180@gmail.com
Venant
Inc. ("DTMS 11 )
Diamond Taxes $77,303
Rosenide
6 and Multi Services 4/28/2020 (loan roselugo3 l 80@gmail.com
Venant
Inc. ("DTMS") denied)

UPV's False and Fraudulent PPP Loan Application

16. On or about April 20, 2020, LUGO electronically submitted a fraudulent

SBA Form 2483 to Bank-I, a federally insured financial institution, for a construction

company named UPV. In turn, Bank-I awarded LUGO approximately $59,485 in

PPP funding. On the PPP loan application, LUGO was identified as UPV's

"authorized representative" and sole owner. He cited "Payroll," "Lease/Mortgage

Interest," and "Utilities" as the purposes for the PPP loan.

17. . According to the PPP loan application and Florida corporate records,

UPV was purportedly located at a commercial address on Ambersweet Way in

Davenport, Florida, which is within.the Middle District of Florida. That address,

however, is merely a drop-box site at a United Parcel Service ("UPS") store. 6 While

the UPS store served as UPV's purported business address, LUGO claimed to reside

at a home on Pinecrest Loop in Davenport, Florida (the "Pinecrest Loop Address").

The Pinecrest Loop Address, it bears noting, would later also serve as the purported

6
In prior years, UPV was registered at a residential property on Calabria Avenue, in
Davenport, Florida, which is a residential property. According to open source research, LUGO
resided at the address in the past, but the property is now occupied by another individual.

9
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 11 of 32 PageID 11

business address on at least six other fraudulent PPP /EIDL applications submitted by

his family members-including Relative #2's EIDL application for NOTS, the tax

preparation company central to LUGO's 2015 fraud conviction.

18. On the fraudulent PPP loan application, LUGO claimed that UPV had

16 employees with an Average Monthly Payroll demand of $47,588-or, annualized,

$571,056. As the investigation has revealed, that was false. UPV had reported no

wages for any employees to the State of Florida in 2019. In Florida, employers must

report quarterly wage and hour returns to state agencies. Records from the Florida

Department of Economic Opportunity ("FDOE") showed a complete lack of

reporting for UPV in 2019.

19. Further, a preliminary review of available financial records for UPV

showed no payroll activity prior to the coronavirus pandemic. UPV held accounts at

two different banks: Bank-2 (-6251) and Bank-I (-0385). According to the available

bank records, prior to March 2020, UPV made no payments to the IRS for payroll

taxes or otherwise to payroll processors. Nor did UPV consistently pay wages directly

to steady employees. UPV only began issuing checks to purported "employees" after

LUGO secured PPP funds from Bank-I. After securing the PPP funds, UPV issued

checks labeled as "payroll" to his immediate family members, including conspirator

VENANT, and others. And, in turn, their respective companies-which likewise had

no payroll activity prior to the pandemic-issued similarly labeled "payroll" checks to

conspirators LUGO, VENANT, and many of the same family members.

10
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 12 of 32 PageID 12

20. On the SBA Form 2483, LUGO also lied about his status as a convicted

felon on supervised release, which would have automatically disqualified him as a

PPP borrower. As noted previously, the SBA Form 2483 asked borrowers, "Within

the last 5 years, [have you] been placed on any form of parole or probation?,, The

application expressly warned that, by answering "YES," the PPP loan would be

denied. LUGO checked "NO," even though he was actively serving a term of

supervised release from his 2015 tax conviction. He remains on supervision today.

LUGO affirmed his false answer by entering his electronic initials "J.E.L."

21. The SBA Form 2483 also reflected LUGO's initials ("J.E.L.") beside all

required certifications for the PPP loan, including those set forth verbatim below:

a. "The funds will be used to retain workers and maintain payroll or make
mortgage interest payments, lease payments, and utility payments, as
specified under the Paycheck Protection Program Rule; I understand that
if the funds are knowingly used for unauthorized purposes, the federal
government may hold me legally liable, such as for charges of fraud.,,

b. "I further certify that the information provided in this application and the
information provided in all supporting documents and forms is true and
accurate in all material respects. I understand that knowingly making a
false statement to obtain a guaranteed loan from SBA is punishable under
the law, including under 18 USC 1001 and 3571 by imprisonment of not
more than five years and/or a fine of up to $250,000; under 15 USC 645
by imprisonment of not more than two years and/ or a fine of not more
than $5,000; and, if submitted to a federally insured institution, under 18
USC 1014 by imprisonment of not more than thirty years and/ or a fine
of not more than $1,000,000."

22. Along with the SBA Form 2483, LUGO executed an electronic PPP

Loan Promissory Note ("Note") with Bank-I on or about May 7, 2020. The email

address "julioenriquelugo@gmail.com" was also identified on the note. In the section

11
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 13 of 32 PageID 13

titled "Use of Proceeds," the Note advised that the "Borrower"-meaning LUGO-

"shall use the proceeds of this loan only for eligible expenses under the terms of the

PPP." It further warned that "[t]he Borrower shall use the funds received under this

Note for business purposes only and not for personal, family or household purposes."

(Emphasis added.) LUGO, however, ignored these warnings.

23. Additionally, in the Note, LUGO certified the truth and accuracy of the

information he had provided. Section 12, sub-section 17 of the certification stated:

I further certify that the information provided in this application and the information
provided in all supporting documents and forms is true and accurate in all material
respects. I understand that knowingly making a false statement to obtain a guaranteed
loan from SBA is punishable under the law, including under 18 USC 1001 and 3571
by imprisonment of not more than five years and/or a fine of up to $250,000; under
15 USC 645 by imprisonment of not more than two years and/or a fine of not more
than $5,000; and, if submitted to a federally insured institution, under 18 USC 1014
by imprisonment of not more than thirty years and/ or a fine of not more than
$1,000,000.

24. This conduct establishes probable cause that LUGO violated multiple

federal criminal statutes, including 18 U.S.C. § 1014.

VENANT's Fraudulent PPP Loan Applications

25. The ongoing investigation has also revealed that LUGO,s wife,

ROSENIDE VENANT, lied on applications seeking SBA-guaranteed funds. Using

one of her known email addresses (i.e.,"roselugo3180@gmail.com',), VENANT

electronically submitted at least five fraudulent PPP loan applications for companies

held in her name to federally insured financial institutions as detailed in the following

table. VENANTs loan applications are discussed next.

12
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 14 of 32 PageID 14

On or About Approx.
Financial Associated
# Company Name Application Amount
Institution Email Account(s)
Date Disbursed

Sisters Compassionate
I Bank-2 5/6/2020 $101,242 roselugo3 l 80@gmail.com
Care LLC (SCC)
Rose Garden Recovery $60,000
2 Bank-3 4/8/2020 rose1ugo3 l 80@gmail.com
Living Inc. (RGR) (denied)
Rose Garden Recovery
3 Bank-3 4/24/2020 $40,000 rose1ugo3180@gmail.com
Living Inc. (RGR)
Diamond Taxes and Multi
4 Bank-1 4/20/2020 $40,208 roselugo3180@gmail.com
Services Inc. (DTMS)
Diamond Taxes and Multi $77,303
5 Bank-1 4/28/2020 roselugo3 l 80@gmail.com
Services Inc. (DTMS) (denied)

Sisters Compassionate Care LLC

26. On or about May 6, 2020, VENANT electronically submitted a

fraudulent PPP loan application for Sisters Compassionate Care LLC ("SCC") to

Bank-2, a federally insured financial institution. According to open source research,

SCC is a home health care service with only one Google review. The review, posted

by the user "JULIO LUGO," stated: "the place is a home for any elderly that needs

love an (sic) care." SCC also maintained a website describing residential facilities for

the elderly and disabled.

27. VENANT listed the Pinecrest Loop Address as SCC's business address

on documents supporting the application. This address, as noted previously, appeared

on several of the conspirators' fraudulent EIDL/PPP loan applications.

28. VENANT served as SCC's "authorized representative" on the PPP loan

application. As such, she certified that SCC "had employees for whom it paid salaries

and payroll taxes." VENANT further advised that, for 2019, SCC's Average Monthly

13
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 15 of 32 PageID 15

Payroll was approximately $40,497.13-or, annualized, $485,965.56. By entering this

substantial figure into the payroll calculator, SCC requested approximately $101,242

in SBA-guaranteed PPP funds. Bank-2 funded the loan on or about May 8, 2020.

29. SCC's purported payroll amount, however, required supporting

documentation. Accordingly, VENANT sent Bank-2 a bogus IRS Form 940 for 2019.

The IRS confirmed, however, that SCC had made no filings at all for Tax Year 2019.

Further, SCC had reported no wages to the State of Florida for the same period.

Additionally, the IRS Form 940 that VENANT uploaded had plain badges of fraud,

including a backdated signature. See Excerpt Below.
~ ~ign here. You MUST complete both P.!g~s of this form and SIGN It.

Under penalties of pe~ury. I declare that I have examined this return, Including accompanying schedules and statements. and to the
best or my knowledge and belief, it is true. correct, ai,d complete, and that no part of any payment made to a slate unemployment
fund claimed as a credit was, or is to bo, deducted from the payments made to omployeos. Declamtion of preparer (other than

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taxpayer) is based on all information of which preparer has any knowledge•
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30. As reflected above, VENANT manually dated the form "12/27/2019"

while the automated date stamp beside her electronic signature read "05/04/2020,"

only two days before she submitted the PPP loan application to Bank-2.

31. VENANT also supplied a purported IRS Form 941 and related payroll

processing records for the first quarter of 2020. A preliminary review of available bank

records for-SCC, however, showed no corresponding payroll activity prior to the

coronavirus pandemic. And, again, once the PPP funds were disbursed, SCC issued a

flurry of checks labeled as "payroll" to other conspirators, including LUGO.
14
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 16 of 32 PageID 16

32. Finally, VENANT certified that the PPP funds awarded to SCC would

"be used to retain workers and maintain payroll or make mortgage payments, lease

payments, and utility payments." VENANT also acknowledged her understanding

that she could be charged with fraud for the knowing use of PPP funds for

unauthorized purposes. The conspirators, however, disregarded these mandates,

including with extensive spending at casinos, large cash withdrawals, and the use of

the EIDL/PPP funds at weight loss centers.

33. This conduct establishes probable cause that VENANT violated multiple

federal criminal statutes, including 18 U.S.C. § 1014.

Rose Garden Recovery Living Inc.

34. VENANT also applied for two PPP loans for Rose Garden Recovery

Living Inc. ("RGR") from Bank-3, a federally insured financial institution. She again

used one of her known email addresses (i.e., "roselugo3180 @gmail.com'l According

to its website, RG R offers sober-living housing to recovering addicts. On RGR's PPP

loan applications, VENANT listed the Pinecrest Loop Address as its purported

business location, which, as noted before, appeared on many of the subject fraudulent

PPP and EIDL applications.

35. VENANT attempted to secure PPP loan funds for RGR twice. The first

PPP loan application for RGR was submitted on or about April 8, 2020. Notably, that

day, the Lugo Family Companies had collectively applied for at least seven different

15
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 17 of 32 PageID 17

SBA loans using their family members as applicants to request over $600,000 in funds

using IP-Addresses associated with LUGO and VENANT's house:

Onor
Associated Email About EIDL/ Amount
# Applicant Company Name
Account(s) Application PPP Requested
Date
Diamond Taxes
and Multi
I Relative #1 d********2797@gmail.com 4/8/2020 EIDL $127,500
Services Inc.
(DTMS)

julioenriquelugo@gmail.com;
2 Julio Lugo UPV 4/8/2020 EIDL $65,000
rickrose8376@gmail.com

Lysal-Central,
Rosenide rosetaxconsultingllc@gmail.com;
3 Inc. 4/8/2020 EIDL $92,500
Venant roselugo3 l 80@gmail.com
(Lysal)

Rosenide
4 RGR rose1ugo3 l80@gmail.com 4/8/2020 EIDL $110,000
Venant

Rosenide $60,000
5 RGR rose1ugo3 l80@gmail.com 4/8/2020 PPP
Venant

Rosenide Tax
Rosenide 4/8/2020 EIDL $76,800
6 Consulting LLC roselugo3 l80@gmail.com
Venant
(RTC)

Rosenide
7
Venant
sec rose1ugo3180@gmail.com 4/8/2020 EIDL $79,000

Total: $610,800

36. When Bank-3 denied VENANT's first request for RGR, she tried again

on April 24, 2020. The second loan attempt was successful. On or about May 1, 2020,

Bank-3 disbursed $40,000 in PPP funds to RGR's bank account (-0956). Again,

VENANT had agreed this money would only be used for qualified PPP expenses. A

review ofRGR's account (-0956) at Bank-3, however, revealed that the funds were

instead used for other purposes, including large transfers to other Lugo Family

16
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 18 of 32 PageID 18

Companies. For example, on or about May 4, 2020, UPV received approximately

$12,500 from the RGR Account (-0956). Similarly, on or about June 3, 2020, RGR

wired approximately $17,000 to SCC's account (-3292) at Bank-2.

37. Later, the RGR account (-0956) reflected other suspicious activity, such

as large wire transfers from some third-party companies that had submitted EIDL

applications from LUGO's confirmed IP-addresses. For example, on or about July 9,

2020, the RGR account (-0956) received an incoming wire of $48,500 from Company-

! in Indiana. That same week, Company-I had received approximately $150,000

from the SBA based on an EIDL application electronically filed from LU GO and

VENANT's home. Similarly, in July 2020, the RGR account (-0956) received two

incoming wires totaling $43,500 from Company-2. Again, that same month,

Company-2 had received approximately $150,000 from the SBA based on an EIDL

application also sent from LUGO and VENANT's home. Neither EIDL application

disclosed a "preparer" as required by the SBA.

38. Finally, in under one month, RGR sought EIDL/PPP funding at least

four times-and each application reported different information for RGR. According

to the fraudulent applications, RGR had anywhere from 5 to IO employees and at

least 2 different business addresses as set forth on the table below. Notwithstanding,

while the RG R applications asserted upwards of 10 different employees with as much

as $20,000 in payroll per month, it had reported no wages to the State of Florida for

2019.

17
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 19 of 32 PageID 19

On or About Reported
RGR's Purported EIDL/ Requested
Application Number of RGR
Business Address PPP LoanAm.ount
Date Employees

3/30/2020 Ambersweet Way.
EIDL $150.000 10
Davenport, FL

4/8/2020 Ambersweet Way.
EIDL $110.000 5
Davenport. FL

Pinecrest Loop
4/8/2020 PPP $60.000 7
Davenport, FL

Pinecrest Loop
4/24/2020 PPP $40,000 6
Davenport, FL

39. This conduct establishes probable cause that VEN ANT violated multiple

federal criminal statutes, including 18 U.S.C. § 1014.

Diamond Taxes and Multi Services Inc.

40. Finally, VENANT also sought PPP funding from Bank-I, a federally

insured financial institution, for Diamond Taxes and Multi Services Inc. ("DTMS").

In April 2020, she submitted two PPP loan applications for DTMS to Bank-I using

the email account "roselugo3180@gmail.com." Metadata provided by Bank-I

revealed that the fraudulent PPP loan applications were electronically filed from an

IP-Address associated with LUGO and VENANT's home. Ultimately, Bank-I

approved one of the PPP loans, disbursing approximately $40,208 in funds to DTMS

for authorized PPP expenses.

41. Like the other Lugo. Family companies that sought PPP funds, DTMS

also appeared to be ineligible. For 2019, DTMS had reported no wages for any

18
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 20 of 32 PageID 20

employees to the State of Florida. Nor had DTMS filed any business or payroll tax

returns for 2019, which were required filings. Given that DTMS is a purported tax-

preparation company, it should be on notice of its IRS filing requirements.

42. Further, the dearth of federal and state wage reporting undermines the

legitimacy of supporting documentation that DTMS sent Bank-I as part of its PPP

loan applications. Specifically, VENANT sent a copy of a purported IRS Form W-3

(Transmittal of Wage and Tax Statements) for DTMS with each application. The

IRS, however, has no record of having received a Form W-3 from DTMS. Worse yet,

the Forms W-3 for the DTMS applications did not match. The Forms W-3 reflected

VENANT's electronic signature dated "12/27/2019" with the unique EIN (i.e.,

employer identification number) assigned to DTMS. Notwithstanding, the forms

reflected different purported business addresses as well as different numbers in Box C

(Total Number of Forms W-2) and Box 16 (State wages, tips, etc.). Critically, because

DTMS did not report wages to the IRS or the State of Florida, the figures reported on

either version of the Form W-3 appear to be specious.

43. This conduct establishes probable cause that VENANT violated multiple

federal criminal statutes, including 18 U.S.C. § 1014.

Background regarding EIDL

44. The CARES Act also allowed the SBA to offer EIDL funding to

businesses affected by the coronavirus pandemic. The businesses, importantly, must

have been in operation as of February 1, 2020.

19
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 21 of 32 PageID 21

45. EIDL funds came directly from the United States Treasury. The money

was only for certain expenses, such as fixed debts, payroll, accounts payable, and

other bills that could have been paid had the pandemic not occurred. EIDL funds

were not for business expansion or to replace lost sales or profits.

46. To have sought EIDL funding, applicants were required to send the SBA

information about their bu·sinesses through an online portal. The required information

included, pertinently, (a) the number of employees as of January 31, 2020 (t'.e., the

declared date for the COVID-19 disaster); (b) the gross revenues and the cost of goods

for the business for the twelve months prior to January 31, 2020; (c) the names and

other identifying information regarding all owners (including email address); and (d)

contact information, banking information, and other identifying details for the

business. Applicants were also required to disclose whether, in the last five years, they

had been convicted of a crime (other than a minor vehicle violation) or placed on any

form of probation.

4 7. Once the SBA received the EIDL application, an automated evaluation

system would perform various checks, including for duplicate loan requests. Also,

using the operational data provided, the system calculated the amount ofEIDL

funding available to the borrower. Should the application not clear the SBA's

automated evaluation, the application's progress would be halted and the applicant

would be notified. The applicant could then work with the SBA for reconsideration.

20
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 22 of 32 PageID 22

48. Finally, applicants had to certify that the information provided to the

SBA was true and correct under penalty of perjury. They also had to acknowledge the

below warning regarding civil liability and criminal offenses:

WARNING: Whoever wrongfully misapplies the proceeds of an SBA disaster
loan shall be civilly liable to the Administrator in an amount equal to one-and-
one halftimes the original principal amount of the loan under 15 U.S.C. §636(b),
In addition, any false statement or misrepresentation to SBA may result in
criminal, civil or administrative sanctions including, but not limited to: 1) fines
and imprisonment, or both, under 15 U.S.C 645, 18 U.S.C. 1001, 18 U.S.C.
1014, 18 U.S.C 1040, 18 U.S.C. 3571, and any other applicable laws; 2) treble
damages and civil penalties under the False Claims Act, 31 U.S.C. 3729; 3)
double damages and civil penalties under the Program Fraud Civil Remedies
Act, 31 U.S.C. 3802; and 4) suspension and/or debarment from all Federal
procurement and non-procurement transactions. Statutory fines may increase if
amended by the Federal Civil Penalties Inflation Adjustment Act Improvements
Act of 2015.

The Conspirators' Fraudulent EIDL Loans

49. From March 2020 through August 2020, the SBA traced approximately

70 fraudulent EIDL applications back to LUGO and VENANT's confirmed IP-

addresses. The EIDL applications sought at least $5.8 million from the SBA.

50. The Lugo Family's Companies accounted for at least 19 of these EIDL

applications, as identified below. The conspirators' EIDL applications-which had

been filed from IP-Addresses assigned to LUGO and VENANT's home-sought over

$2.2 million from the SBA, resulting in at least $1.3 million of theft. As detailed in the

following sections, the Lugo Family Companies and their EIDL applications reflected

numerous badges of fraud, including that none had reported wages to the State of

Florida for 2019. Based on these acts, as described below, probable cause exists to

believe that LUGO, VENANT, and their conspirators committed additional overt

21
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 23 of 32 PageID 23

acts, in violation of 18 U.S.C. § 371 (conspiracy to defraud the SBA), with regard to

the respective EIDL applications below:

On or About Date of Amount,
# Applicant Company Name
EIDL Application Bold if Approved

Diamond Taxes and Multi Services
1 Relative #1 3/29/2020 $127,500
Inc. (DTMS)

Universal Property Vision LLC
2 Lugo 3/29/2020 $92,000
(UPV)

Lysal-Central, Inc.
3 Venant 3/29/2020 $150,000
(Lysal)

4 Rosenide Tax C~sulting LLC
Venant 3/29/2020 $150,000
(RT )

Sisters Compassionate Care LLC
5 Venant 3/29/2020 $82,500
(SCC)

Rose Garden ·Recovery Living
6 Venant 3/30/2020 $150,000
LLC (RGR)

Diamond Taxes and Multi Services
7 Relative #1 4/8/2020 $127,500
Inc. (DTMS)

Universal Property Vision LLC
8 Lugo 4/8/2020 $65,000
(UPV)

Lysal-Central, Inc.
9 Venant 4/8/2020 $92,500
(Lysal)

Rose Garden Recovery Living
10 Venant 4/8/2020 $110,000
LLC (RGR)

Rosenide Tax Consulting LLC
11 Venant 4/8/2020 $76,800
(RTC)

Sisters Compassionate Care LLC
12 Venant 4/8/2020 $79,000
(SCC)

H & C Mortgage Investments
13 Relative #3 6/16/2020 $121,500
Realty Inc. (HCM)

Facerick Entertainment LLC
14 Lugo 6/16/2020 $105,000
(Facerick)

H & C Community Development,
15 Relative #4 6/22/2020 $120,:mo
Inc. (HCC)

22
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 24 of 32 PageID 24

Western Shores Mortgage
16 Relative #4 6/22/2020 $129,600
Investment, Inc.

The Number One Tax Specialist
17 Relative #2 7/13/2020 $144,700
LLC(NOTS)

Consumer Dispute Services LLC
18 Relative #1 7/24/2020 $145,700
(CDS) 7

Rose Compassionate Care LLC
19 Relative #2 7/27/2020 $150,000
(RCC)

Operational Status ofthe Lugo Family Companies

51. To qualify for EIDL funds, as detailed earlier, the business must have

been in operation as of February 1, 2020. Further, applicants were required to

disclose, among other information, the number of employees it had as of January 31,

2020, along with the gross revenues and costs of goods for the twelve months prior to

that date. Here, as to number of employees per company, the conspirators claimed

that the Lugo Family Companies had anywhere between 5 and 28 employees, with a

median of 10 employees. These assertions appear specious, however, as the

companies had reported no payroll to the State of Florida for 2019.

52. Additionally, the IRS has provided research regarding the 2019 tax

filings for a subset of the Lugo Family Companies, namely, SCC, Rosenide Tax

Consulting ("RTC"), and Diamond Taxes and Multi Services Inc. ("DTMS"). The

7
Only one EIDL application on the above table traced back to an alternate IP Address.
Specifically, the EIDL application for Consumer Dispute Services LLC ("CDS") was filed from the
IP Address 98.21.160.188, which resolved back to a hotel in Indiana where LUGO held a confirmed
reservation on or about the date of application, i.e., July 24, 2020. As detailed herein, CDS was only
established as a registered Florida corporation in Relative #1 's name on or about July 12, 2020-
meaning approximately 12 days before seeking EIDL funds.

23
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 25 of 32 PageID 25

research revealed that, for 20 19, these companies had not filed payroll tax returns-or

any tax returns for that matter. The failure to file was particularly egregious here as

VEN ANT has training in tax preparation. And, further , DTMS and RTC were

purported to be companies specialized in tax preparation.

53. In addition to the dearth of state and federal payroll reporting, the

conspirators' EIDL applications were even facially fraudulent as to their purported

personnel. As the above table reflects, the conspirators submitted multiple EIDL

applications for nearly half of the Lugo Family Companies, including UPV, SCC,

RGR, DTMS, and Lysal-Central, Inc. ("Lysal"). Each respective company's EIDL

applications reflected inconsistent respo nses to Question 33 , which asks for the

"Number of E mployees (As of January 31, 2020)." The applications also reported

varying figures fo r gross revenues (Question 14) and the cost of goods (Question 15).

Each company's responses should have been uniform as the EIDL application seeks

information relative to a fixed d~te (i.e., January 31, 2020). Not once were the

responses consistent across multiple EIDL applications, as reflected below:

On or About # of Gross
Company Name Costs of Goods
Application Date Employees Revenues

Diamond Taxes an d Multi 3/29/2020 10 $350,000 $75 ,000
Services Inc. (DTMS) 4/8/2020 15 $285,000 $114,000
Lysal-Central, Inc. 3/29/2020 26 $750,000 $125,000
(Lysal) 4/8/2020 28 $350,000 $145,000
Rose Ga rden Recovery Living 3/ 30/2020 10 $695,000 $205,200
LLC (RGR) 4/8/2020 5 $350,000 $120,000
Roscnidc Tax Consulting LLC 3/29/2020 6 $450,000 $150,000
(RTC) 4/8/2020 10 $275,000 $102,000
Sisters Compassionate Care 3/29/2020 6 $265,000 $ 100,000
LLC (SCC) 4/ 8/2020 8 $279,000 $ 105,000
3/29/2020 8 $275,000 $75,000
24
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 26 of 32 PageID 26

Universal Property Vision 4/8/2020 5 $250,000 $110,000

54. Furthermore, as detailed earlier, EIDL eligibility required that the

business was in operation as of February 1, 2020. The bank account and corporate

registration histories for some of the Lugo Family Companies support that the

companies were not operating then:

Onor
About Corporate Registration and/ or
Company Name
Application Banlc Account History
Date
CDS registered on or about 7/12/2020, i.e., 12 days before its
Consumer Dispute EIDL application. On 7/24/2020, i.e., the date of application,
Services LLC 7/24/2020 Relative # 1 opened CDS Account -4812 at Bank- I, where she
(CDS) received EIDL funds.

Facerick Facerick registered in 201 O; remained in "inactive" status since
Entertainment 6/16/2020 2012. Facerick's EIDL application listed LUGO's UPV Account
LLC (Facerick) -6251 at Bank-2 for receipt of SBA funds.

H&C Relative #4 amended HCC's corporate registration on or about
Community 6/22/2020 (i.e., the application date) to remove other officers.
6/22/2020 That same day, Relative #4 opened an HCC Account -0447 at
Development, Inc.
(HCC) Bank-I, where he received EIDL funds.

Rose VENANT voluntarily dissolved RCC in 2018. RCC's corporate
Compassionate 7/27/2020 registration reinstated in Relative #2's name on or about
Care LLC (RCC) 7/13/2020, i.e., two weeks before EIDL application.
NOTS registration went inactive in 2015. On or about
The Number One 7/12/2020 (i.e., the day before the application), NOTS was
Tax Specialist 7/13/2020 reinstated in Relative #2's name. The next day, Bank-I account
LLC(NOTS) (-5287) was opened for NOTS using Relative #2 as signor.
WSM's corporate registration went inactive in 2013. On or about
Western Shores
6/22/2020 (i.e., the application date), Relative #4 reinstated
Mortgage
6/22/2020 WSM. He also opened WSM's bank accpunt (-6110) at Bank-1,
Investment, Inc.
(WSM) where he received EIDL funds.

25
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 27 of 32 PageID 27

55. For example, as described above, the corporate registration for NOTS

expired in 2015. Back then, LUGO had used NOTS, a purported tax-preparation

business, to commit tax fraud related to his 2015 federal conviction. Despite having

used the entity to pursue criminal activity, the conspirators reinstated NOTS as a

Florida corporation on July 12, 2020-meaning one day before they submitted its

EIDL application. The Sunbiz registration for NOTS identified only one individual as

an owner or manager (i.e., Relative #2). The next day (i.e., the EIDL application

date), Relative #2 opened a bank account for NOTS (-5287) at Bank-I. The timing of

certain corporate registrations and account openings in relation to the EIDL

applications supports that the conspirators used and established these entities to

defraud the SBA's EIDL program. This pattern establishes probable cause for, among

other violations, 18 U.S.C. § 371.

56. Finally, as noted previously, applicants were required to disclose

whether, in the last five years, they had been convicted of a crime or placed on any

form of probation. As he did on the PPP loan applications, LUGO again concealed

his supervised release status when he sought EIDL funds from the SBA for Facerick

and UPV.

57. The acts described above establishes probable cause to believe that

LUGO and VENANT violated 18 U.S.C. §§ 371 (conspiracy to defraud the SBA).

26
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 28 of 32 PageID 28

Use ofFraudulent EIDL Funds to Purchase BMW

58. According to purchase documents, on or about May 19, 2020,

VENANT and Relative #1, purchased a 2017 BMW from a dealership in Hollywood,

Florida. The purchase price for the vehicle was $51,055. At the time of the purchase,

VENANT and Relative # 1 financed a total of approximately $54,595 with a lender.

As will be detailed below, a majority of this loan was later paid off with fraudulently

obtained EIDL funds.

59. According to records obtained from the lender, VENANT and Relative

#1 were co-applicants on loan account number 62062722847831001 (Loan 1001),

which was used to purchase the BMW in May 2020. While there were a few smaller

payments made towards Loan 1001, the largest payment was a $47,000 wire on June

26, 2020, from LUGO's UPV bank account (-6251) at Bank-2. This wire was funded

just days before with fraudulently obtained EIDL proceeds.

60. As detailed above, on or about June 16, 2020, LUGO had submitted an

EIDL application on behalf of Facerick Entertainment, LLC, seeking approximately

$105,000 (the "Facerick SBA EIDL"). Facerick was formed and registered in 2010;

however, according to corporate filings, it has remained in "inactive" status since

2012. Facerick's SBA EIDL application listed UPV Account -6251 for receipt of the

SBA funds.

27
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 29 of 32 PageID 29

61. According to account records, UPV Account -6251 was opened on or

about December 21, 2018, by LUGO, and is held in the name ofUPV. LUGO is the

sole signatory on the account.

62. On June 22, 2020, UPV Account -6251 had a balance of approximately

$1,324.44. On or about June 23, 2020, $104,900 from the Facerick SBA EIDL was

deposited into UPV Account -6251, leaving a balance of $106,224.44.

63. Immediately following the Facerick SBA EIDL deposit, on June 23,

2020, there were two outgoing Zelle transfers totaling $6,000. On June 24, 2020, there

was an unexplained counter credit of $15,000 to the account, leaving a balance of

$115,224.44. On June 26, 2020, $47,0008 was transferred from UPV Account-6251 to

Loan 1001 to pay down the balance owed. According to the loan documents, Loan

1001 was ultimately paid off in or around August 2020.

64. Because the June 24, 2020 wire that substantially satisfied Loan 1001

involved more than $10,000 in criminally derived funds, LUGO made this

transaction in violation of 18 U.S. C. § 1957.

8
Even assuming, arguendo, that the unexplained June 23, 2020 counter credit of$15,000 to
UPV Account 6251 came from untainted sources, those funds would not have been sufficient, on
their own, to fund the $47,000 wire to Loan 1001 on June 24, 2020. Therefore, at least $32,000 of
this wire is traceable to the proceeds of the fraudulently obtained Facerick SBA EIDL.
28
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 30 of 32 PageID 30

CONCLUSION

Based on the forego ing facts, probable cause ex ists to believe that, from at

least in or around March 2020, through and including A ugust 2020, JULIO

ENRIQUE LUGO (a/k/a "Rick W illiams") and ROSENIDE VENANT (a/ k/a

"Rose Lugo") violated 18 U.S.C. §§ 371 (conspiracy to defra ud the SBA) and l0 14

(false statements to a lending institution). Further, probable cause exists to believe

that, on or about June 24, 2020, LUGO violated 18 U.S .C. § 195 7 (illegal monetary

transactions).

FURTHER AFFIANT SA YETH NAUGHT.

--,;>'/ I'
~ ):AC~ - - -===---
~T H erman, Special Agent, FBI
Sworn to by the applicant in accordance with
the requirements offed. R. Crim. P. 4.1 and &. il -lJ
~ ) via telephone this __tu day of
March 202 1.

A
h~sAfoN
~
United States Magistrate Judge

I
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 31 of 32 PageID 31

Appendix 1: Lugo Family Companies' SBA Loans

On or About EIDL/ Amount
# Applicant Company Name Approved?
Application Date PPP Requested

H & C Mortgage
1 Relative #3 Investments Realty Inc. 6/16/2020 EIDL $121,500 Yes
(HCM)

Consumer Dispute Services
2 Relative #1 7/24/2020 EIDL $145,700 Yes
LLC (CDS)

Diamond Taxes and Multi
3 Relative #1 3/29/2020 EIDL $127,500 Yes
Services Inc. (DTMS)

Diamond Taxes and Multi
4 Relative #1 4/8/2020 EIDL $127,500 No
Services Inc. (DTMS)

H & C Community
5 Relative #4 6/22/2020 EIDL $120,300 Yes
Development, Inc. (HCC)

Western Shores Mortgage
6 Relative #4 6/22/2020 EIDL $129,600 Yes
Investment, Inc.

Rose Compassionate Care
7 Relative #2 7/27/2020 EIDL $150,000 Yes
LLC (RCC)

The Number One Tax
8 Relative #2 7/13/2020 EIDL $144,700 Yes
Specialist LLC (NOTS)

Facerick Entertainment
9 Julio Lugo LLC 6/16/2020 EIDL $105,000 Yes
(Facerick)

Universal Property Vision
10 Julio Lugo 3/29/2020 EIDL $92,000 Yes
LLC (UPV)

Universal Property Vision
11 Julio Lugo 4/8/2020 EIDL $65,000 No
LLC (UPV)

Universal Property Vision
12 Julio Lugo 4/20/2020 PPP $59,485 Yes
LLC (UPV)

30
Case 8:21-mj-01294-AAS Document 1 Filed 03/26/21 Page 32 of 32 PageID 32

Rosenide Diamond Taxes and Multi
13
Venant Services Inc. (DTMS)
4/20/2020 PPP $40,208 Yes

Rosenide Diamond Taxes and Multi
14
Venant Services Inc. (DTMS)
4/28/2020 PPP $77,303 No

Rosenide Lysal-Central, Inc.
15 3/29/2020 EIDL $150,000 No
Venant (Lysal)

Rosenide Lysal-Central, Inc.
16 4/8/2020 EIDL $92,500 No
Venant (Lysal)

Rosenide Rose Garden Recovery
17 3/30/2020 EIDL $150,000 No
Venant Living LLC (RG R)

Rosenide Rose Garden Recovery
18 4/8/2020 EIDL $110,000 No
Venant Living LLC (RGR)

Rosenide Rose Garden Recovery
19
Venant Living LLC (RG R)
4/8/2020 PPP $60,000 No

Rosenide Rose Garden Recovery
20
Venant Living LLC (RGR)
4/24/2020 PPP $40,000 Yes

Rosenide Rosenide Tax Consulting
21 3/29/2020 EIDL $150,000 Yes
Venant LLC (RTC)

Rosenide Rosenide Tax Consulting
22 4/8/2020 EIDL $76,800 No
Venant LLC (RTC)

Rosenide Sisters Compassionate Care
23 3/29/2020 EJDL $82,500 Yes
Venant LLC (SCC)

Rosenide Sisters Compassionate Care
24 4/8/2020 EJDL $79,000 No
Venant LLC (SCC)

Rosenide Sisters Compassionate Care
25 Venant LLC (SCC)
5/6/2020 PPP $101.242 Yes
I

Total Attempted Amount: $2,597,838
Total Funded Amount: $1,609,735

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