Criminal Complaint — United States v. Shyteek L. Stevenson, Mag. No. 21-9182 (D.N.J.)
Summary
IRS Special Agent Paul D. Bataille attested to this criminal complaint against Shyteek L. Stevenson by telephone before U.S. Magistrate Judge Cathy L. Waldor on March 24, 2021 (Mag. No. 21-9182, D.N.J.). Count One charges wire fraud over the deposit of approximately $117,900.00 from the Small Business Administration to the bank account of Heroes to Helpers LLC on July 20, 2020. Count Two charges money laundering over an interstate wire of approximately $16,000 on or about August 20, 2020. The affidavit alleges that Stevenson's EIDL application of June 29, 2020 certified gross revenue of $250,000 and seven employees for Heroes to Helpers, a purported construction company. It says the listed business address was a strictly residential apartment complex and that the funds paid for personal expenses such as ATM withdrawals, retail shopping and travel.
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United States District Court
District of New Jersey
UNITED STATES OF AMERICA Hon. Cathy L. Waldor
V. Mag. No. 21-9182
SHYTEEK L. STEVENSON CRIMINAL COMPLAINT
I, Paul D. Bataille, being duly sworn, state the following is true and
correct to the best of my knowledge and belief:
SEE ATTACHMENT A
I further state that I am a Special Agent for the Internal Revenue Service,
and that this Complaint is based on the following facts:
SEE ATTACHMENT B
Continued on the attached page and made a part of this Complaint.
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Paul D. Bataille
Special Agent
Internal Revenue Service
Attested to me by telephone pursuant to FRCP 4. l(b)(2)(A),
March 24, 2021, in the District of New Jersey
HONORABLE CATHY L. WALDOR ( '0 ;:{~ L. W,Jldl,n
UNITED STATES MAGISTRATE JUDGE Signate of Judicial Officer
ATTACHMENT A
Count One
(Wire Fraud)
From at least as early as in or around June 2020 through in or around
November 2020, in the District of New Jersey and elsewhere, defendant
SHYTEEK L. STEVENSON,
knowingly and intentionally devised and intended 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, for the purpose of
executing and attempting to execute such scheme and artifice, did transmit and
cause to be transmitted by means of wire, radio, and television communication
in interstate and foreign commerce, the following writings, signs, signals,
pictures, and sounds, to wit:
~,
Count Annroximate Date Descriotion
1 July 20, 2020 STEVENSON caused to be deposited
approximately $117,900.00 from the
Small Business Administration to
Heroes to Helpers LLC's bank account at
Bank-1, resulting in an interstate wire
transmission.
In violation of Title 18, United States Code, Sections 1343 and 2.
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Count Two
(Money Laundering)
On or about August 20, 2020, in the District of New Jersey and elsewhere,
defendant,
SHYTEEK L. STEVENSON,
did knowingly engage and attempt to engage in a monetary transaction by,
through, and to a financial institution, affecting interstate and foreign commerce,
in criminally derived property of a greater value than $10,000, that is, an
interstate wire of approximately $16,000 from an account at Bank-1 to a an
account at Bank-2, such property having been derived from a specified unlawful
activity, that is, wire fraud, in violation of Title 18, United States Code, Section
1343.
In violation of Title 18, United States Code, Section 1957 and Section 2.
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ATTACHMENT B
I, Paul D. Bataille, am a Special Agent with the Internal Revenue Service.
I have knowledge about the facts set forth below from my involvement in the
investigation, my review of reports, documents, pictures, videos, witness
interviews, and discussions with other law enforcement officials. Because this
affidavit is submitted for the limited purpose of establishing probable cause, I
have not set forth each and every fact that I know concerning this investigation.
All statements described herein are relayed in substance and in part. In
addition, where I assert that an event took place on a particular date, I am
asserting that it took place on or about the date alleged.
Background
THE EcONOMIC INJURY DISASTER LoANS PROGRAM
1. The Coronavirus Aid, Relief, and Economic Security ("CARES") Act is
a federal law enacted in or around March 2020 designed to provide emergency
financial assistance to the millions of Americans who are suffering the economic
effects caused by the COVID-19 pandemic.
2. The provisions of the CARES Act, in conjunction with an officially
declared disaster by the United States Government, allowed for the Small
Business Association ("SBA") to offer funding through the COVID-19 Economic
Injury Disaster Loans ("EIDL") program to business owners negatively affected
by the COVID-19 pandemic. More specifically, the EIDL program is an SBA
program that provides low-interest financing and advances (or grants) to small
businesses, renters, and homeowners in regions affected by declared disasters.
3. In order to obtain an EIDL, a qualifying business must submit an
application to the SBA and provide information about its operations, such as the
number of employees, gross revenues for the 12-month period preceding the
disaster, and cost of goods sold in the 12-month period preceding the disaster.
In the case of EIDLs for COVID-19 relief, the 12-month period is that preceding
January 31, 2020. The business entity must have existed in an operational
condition on February 1, 2020.
4. Using the SBA online portal, EIDL applicants submit personal and
business information in support of each EIDL application. The EIDL
loans/ advances process required minimal documentation and information from
small businesses to process the loan/ advances for approval. The application
includes a paragraph in which the applicant affirms that the information
submitted is true and correct under the penalty of perjury and applicable
criminal statutes.
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5. EIDL applications are submitted directly to the SBA and processed
by the agency with support from a government contractor. The amount of the
loan/ advance, if the application is approved, is determined based, in part, on
the information provided by the applicant about employment, revenue, and cost
of goods, as described above. As a general matter, the loan amount for most
businesses, other than rental businesses and non-profit and agricultural
businesses, is calculated the same way: gross revenue reported, less cost of
goods sold reported, divided by two. The maximum loan amount is capped at
$150,000 per entity.
6. Pursuant to the prov1s1ons governing the EIDL program,
loan/ advance proceeds must be used by the receiving business only on certain
permissible expenses. More specifically, the EIDL funding may be used by the
business to pay fixed debts, payroll, accounts payable, and other bills that could
have been paid had the COVID-1 9 disaster not occurred.
THE RELEVANT ENTITIES AND INDIVIDUALS
7. At various times relevant to the complaint:
a. Defendant Shyteek L. Stevenson ("Stevenson") resided m
Pennsylvania.
b. Heroes to Helpers LLC ("Heroes to Helpers") was a purported
construction company established in Pennsylvania and believed to be owned by
Stevenson.
c. Bank-1 was a financial institution headquartered in
Greenville, Pennsylvania. Stevenson maintained a business account at Bank-1
for Heroes to Helpers (the "7891 Account"), which he opened on or about June
2, 2020.
d. Bank-2 was a financial institution headquartered in San
Francisco, California.
e. Stevenson's associate ("Individual-I") owned a company
("Company-I") established in New Jersey. Individual-I maintained a business
account for Company-I at Bank-2.
The Scheme to Defraud
FALSE EIDL APPLICATIONS TO SBA
8. On or about June 29, 2020, Stevenson submitted an EIDL application
("Application-I") on behalf of Heroes to Helpers. Stevenson listed himself as
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100% owner and described the company as "Construction & Contractors." In
Application-1, Stevenson certified that Heroes to Helpers had a gross revenue of
$250,000 for the 12-month period preceding the COVID-19 pandemic and that
its costs of goods sold during this period was $0. Stevenson further certified
that Heroes to Helpers had seven employees as of Januruy 31, 2020 .
Stevenson listed the 7891 Account as the account to which the EIDL funding
should be disseminated.
9. The SBA approved Application-1. Based on the gross revenue
Stevenson certified, as well as the fact that Stevenson reported no cost of
goods, Stevenson qualified for approximately$ 117,900. On or about July 14,
2020, Stevenson electronically signed the Loan Authorization and Agreement.
10. Application-1 contained false and/or misleading statements and
misrepresentations.
11. As an initial matter, based on the investigation to date, Heroes to
Helpers does not appear to generate revenue as a legitimate business. In
Application-1, Stevenson listed Heroes to Helpers' business address as a location
in Hummelstown, Pennsylvania (the "Hummelstown Address"). Law
enforcement's physical surveillance of the Hummelstown Address revealed that
it was a strictly residential apartment complex. There is no identifiable online
presence for Heroes to Helpers. Stevenson opened the 7891 Account on or
about June 2, 2020-amid the COVID-19 pandemic and only a few weeks before
he filed Application-1. Accordingly, 7891 Account records do not (and could
not) support the gross revenue Stevenson certified. Law enforcement has not
identified any bank records demonstrating Heroes to Helpers conducts legitimate
business. Further, according to the IRS, Stevenson has never filed a tax return
for Heroes to Helpers, nor did he file a personal tax return in 2019.
12. Leguen also misstated that Heroes to Helpers had seven employees
as of Januruy 31, 2020. In addition to the above-referenced evidence, according
to the Pennsylvania Department of Labor ("PADOL") Heroes to Helpers has never
paid wages in Pennsylvania.
13. On or about July 20, 2020 the SBA transferred approximately
$117,900 to the 7891 Account, resulting in an interstate wire.
Use of the EIDL Loan Proceeds
14. Bank records for the 7891 Account demonstrate that Stevenson used
the EIDL funding provided to Heroes to Helpers for improper, non-business
purposes. On or about July 17, 2020, the 7891 Account's balance was
approximately $3,333.88. The following day, the SBA wired approximately
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$117,900 to the 7891 Account, resulting m a balance of approximately
$121,233.88.
15. For instance, Stevenson used the EIDL funding for myriad personal
expenses, including, but not limited to: ATM withdrawals, cash application
transfers to Stevenson, retail shopping (including Levi's, Polo, Walmart, and
liquor stores), restaurants and convenience store expenses, transportation
expenses (including Lyft and Uber), and travel expenses (including
entertainment, lodging, and airfare) .
16. In addition to these expenditures, on or about August 20, 2020,
Stevenson wired from the 7891 Account at Bank-1 approximately $16,000 to
Company-1 's account at Bank-2 , which is maintained by Individual-1.
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