Criminal cover sheet + criminal complaint — United States v. Chapman (Dkt. 1, S.D. Fla.)
Summary
A criminal cover sheet and sealed criminal complaint against Malaina Chapman in the U.S. District Court for the Southern District of Florida, magistrate Case No. 1:24mj03358, dated July 3, 2024 and entered on the docket of Case 1:24-cr-20321-RAR as Document 1 on July 8, 2024. The complaint charges conspiracy to commit wire fraud, wire fraud and bank fraud. A supporting affidavit by a special agent of the U.S. Postal Service Office of Inspector General states that Chapman worked as a Disaster Relief Specialist with the SBA and alleges she supplied false Schedule C forms for PPP loan applications prepared by others. It also alleges false PPP applications in her own and her companies' names, forged pay stubs for a home equity line of credit, and false claims to City of Miami and State of Florida emergency rental assistance programs. The 12-page filing is attested before a magistrate judge.
Summary drafted by a model from the text of the original file linked on this page 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
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“Criminal cover sheet + criminal complaint — United States v. Chapman (Dkt. 1, S.D. Fla.).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/criminal-cover-sheet-criminal-complaint-united-states-v-chapman-dkt-1-643d1785a5/
, SHA-256 b781e0d1b5d67caebe84f19f2f09af1d129e6eeab00ba1993d290f87e0253780.Full text
Case 1:24-cr-20321-RAR Document 1 Entered on FLSD Docket 07/08/2024 Page 1 of 12
TS
UNITED STATES DISTRICT CO UR T Jul 3, 2024
SOUTH ERN D ISTRICT O F FL OR ID A
CA SE N O. 1:24mj03358 Goodman Miami, Fl
IN RE SEA LED CO M PLAINT
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CR IM INAL CO VER SH EET
1. D id tl
nisnnatteroriginate frolm a lmatterpending in theN ol
-thern Region oftlne United States
Attorney'sOfficepriorto August8,2014 (klag.JbldgeShaniek kl,M aynardl? No
D id thism atteroriginatefrom a m atterpending in the CentralRegion ofthe United States
Attorney'sOfficepriortoOctober3,2019(Mag.JudgeJaredM.Strauss)? No
D id thism atterinvolve theparticipation oforconsultation w ith M agistrate Judge Edblardo
I.Sanchez during histenure attheU ,S.Attorney'sO ffice,w hich concluded on January 22,
20237 No
Did this m atterinvolve the participation of orconsuhation now M agistrate Judge M arty
Fulgueira Elfenbein during hertenure atthe U.S.A ttorney's Office,w hich concluded on
M arch 5,20247 N o
Respectfully subm itted,
M A RK EN ZY LA PO IN TE
UN ITED STA TES A TTO RN EY
ZD
DanielBernstein
AssistantU nited StatesAttorney
Florida BarN o.0017973
United StatesA ttorney's Office
99 N ortheastFotlrth Street
M iam i,Florida 33l32-2111
Tel.:(305)961-9169
Email:Daniel.Bel-nstein@ usdoj.gov
Case 1:24-cr-20321-RAR Document 1 Entered on FLSD Docket 07/08/2024 Page 2 of 12
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18U.S.C.j1344 BankFraud
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Case 1:24-cr-20321-RAR Document 1 Entered on FLSD Docket 07/08/2024 Page 3 of 12
AFFIDAV IT IN SUPPORT O F CRIM INA L CO M PLA INT
1,CurtisW ilkins,being duly sw orn,depose and state asfollows'
.
lntroduction
Purpose oftheA ffidavis
I am a SpecialA gent w ith the United States Postal Service-o ffice of Inspector
General(USPS-OIG) and have been since 20l4. Prior to working at USPS-OIG,l was
em ployed as a SpecialAgentw ith the United States Departm entof1-1ea1th and l-lblm an Services,
Office ofInspectorGeneral(HHS-OIG)fron; 2005 to 2014.ln these positions Ihave been
involved in hundreds offraud investigations involving 14ea1th care fraud,money laundering and
Federal workers com pensation frabld. I al'
n currently assigned to a group that investigates
worl
kers col
-npensation fraud and other federaloffenses colum itted by USPS employees.1 have
been the affianton num erous prior search warrants and have been involved in the executiol
'lof
DLIm CI-OL1SSeal
*clnW arrants.
This affidavit is m ade in support of a crim inalcomplaint charging M A LA IN A
CHAPMAN (hereinafterreferredtoastheECCHAPMAN').
The inform ation contained in this Affidavitis based on,al-nong other things,m y
participation in the investigation described herein, lmy reviesv of the relevant doculments and
em ails,inform ation obtained from law enforcement officers and others,and know ledge gained
from my training and experience. Because 1 subm it this Affidavit for the lim ited purpose of
establishing probable cause,itdoesnotsetfbrth a1Iofl
'ny knowledge aboutthis m atter.
4. Based on m y training and experience)and the facts set forth in this Affidavit,J
subm itthatthere is probable cause to believe thatthe defendant com m itted a num berof federal
'
y
offenses including conspiracy to colum itwire fraud,in violation ofTitle 18,United States Code,
Case 1:24-cr-20321-RAR Document 1 Entered on FLSD Docket 07/08/2024 Page 4 of 12
and bank frabld in violation ofTitle 18,United StatesCode,Section l344.
PR O BA BLE CA USE
The Coronavirtls Aid, w as a
federallaw enacted in oraround M arch 2020 designed to provide em ergency Gnancialassistancc
to tlne m illions of A mericans who suffered the econom ic effects caused by the COV ID-l9
pandem ic.
One soblrce of relief provided by the CA RES A ct was a progralm called the
P,aycheck Protection Program (((PPP'
'),whichauthorizedforgivableloanstosmallbusinessesfor
jobretentionandcel
-tainotherexpenses.InordertoobtainaPPP loan,aqualifyîngbusinesswas
reqtlired to subm ita PPP loan application,which w as signed by an authorized representative of
thebusiness.ThePPP loan apjlication requiredthebusinesstoacknowledgetheprogram rules
and certif'
y its eligibility.A sole proprietorship was likewise required to subm it a PPP loan
application, which w as signed by an authorized representative of the business.The PPP Ioan
applications required the sole proprietorship (throtlgh its authorized representative)
acknowledge the progral'
n rules and m ake certain affirmative certifications in orderto be eligible
to obtain a PPP loan. ln the PPP loan application (Sma1lBusinessAdm inistration (SBA)Form
2483-C,a sole proprietorslnip withoutemployees (through its authorized representative)was
required to provide, am ong other things,the totalalmount of gross incolme as reported on the
2019 or2020 1RS Form 1040 Schedule C,line 7 (çcschedule C'').This figure was used to
calculatethe amountofm oney the sole proprietorship w aseligibie to receive underthe PPP.
The PPP allow ed the interestand principalon the PPP loan to be entirely forgiven
ifthe btlsiness spentthe loan proceeds on certain perm issible expense item s within a designated
Case 1:24-cr-20321-RAR Document 1 Entered on FLSD Docket 07/08/2024 Page 5 of 12
period oftim e aftel-receiving tlne proceeds and used a certain am ountof the PPP loan proceeds
on payrollexpenses.
8. W hen a PPP lender disburses a PPP loan, the lender sends an electronic
transmission fiom one(1)oftw0(2)SBA computerserverslocatedintheState(?f-Virginia.
The City of M iam iEm ergency RentalAssistance program w as a Covid-19 relief
program designed to help M iam i residents facing econom ic hardship caused by the Covid-l9
pandem ic to pay theirrent.
The State of Florida also had an Em ergency RentalAssistance Program thatw as
adm inistered by the Florida Departm entof Children and Fam ilies and designed to help Residents
ofthe State of Florida facing econom ic hardship caused by the Covid-l9 pandem ic to pay their
rent.
Credit Union 1 w as a credit union that extended traditional banking services to
residents ofM iam i-Dade County and elsewhere.CreditU nion 1 wasan institution thatis insblred
by the N ationalCreditU nion Adm inistration.
Lender 1,based in Laguna H ills,California,and w as an SBA-approved lenderof
PPP Leans.
Lender 2,based in Lake M ary,Florida,and was an SBA-approved lenderof PPP
loans.
Lender 3,based in N ew York,N ew York,and w as an SBA-approved lender of
PPP loans.
Lender 4,based in CoralG ables,Florida, and was an SBA -approved lelpder of
PPP loans.
FinancialTechnology Com pany 1,based in San Francis'
co,California, provided
Case 1:24-cr-20321-RAR Document 1 Entered on FLSD Docket 07/08/2024 Page 6 of 12
identification verification servîces to Lenders l,2 and 4.
Individblal lw asa residentofBrevard Coblnty,Florida.
M blseum 1was a l
'nuseum located in M iam i-Dade Coblnty,Florîda.
CHAPM A N was em ployed as a Disaster Relief Specialist w ith the SBA from
Septem ber28,2020,through herresignation on M arch 18,202l.
20. DA TRAP LLC (CIDA TRAP'')wasacorporationorganizedunderthelawsofthe
State ofFlorida. According to SUN BIZ,CHAPM AN was listed asthe M anagerofthe com pany.
Upscalc Credit Lounge, LLC (ttupscale Credit Lounge'') was a corporation
organized underthe laws ofhthe State ofFlorida.According to Sblnbiz,CHA PM AN was listed as
the M anagerofthe corporation.
22. lndividual2,w aq CHA PM AN 'S m otherwho died on M ay 2O,2020.
Individblal3 w as a residentofM iam i-D ade County.
CH APM AN 'S RO LE IN W IRE FR AUD CO NSPIM C Y CH AR G ED IN
CASE N O .24-20079-C R-FAM
24. 0nMay30.2024,agrandjurysitling intheSoutlnern Districtof-Floridarettlrned
aSblpel-sedil
-
lg IndictlmentagainstRaishaKelly and five(5)otherindividualsincasenunnber24-
20079-CR-FAM(s). ln sulm,the Superseding Indictment clnarged that Kelly submitted al'
ld
caused the subm ission offalse and fraudulent inforluation and docum entation in supportofPPP
loan applications, including falsified Internal Revenue Service (ç$lRS'') forlus, among other
thingsthatfalsely and frakldulently represented the annualgross receipts and tentative profits of
purported sole proprietorships.Thisconspiracy,1ed by Kelly,w asresponsible forthe subm ission
qfoverforty(40)falseandfraudulentloanapplicationsthatcausedPPPlenderstomakeIoansin
excessof$800,000toborrowerswho were netqualified to receive thelm.Through theexecution
ofanemailsearchwarrantontheel-
nailaccountIlAfo.wealthvlnoldincs@-xl
mail.colm,yourAffiant
4
Case 1:24-cr-20321-RAR Document 1 Entered on FLSD Docket 07/08/2024 Page 7 of 12
learned that CI-IA PM AN played a crucialrole in aiding Kelly's conspiracy by providing false
and fraudulent Schedule C's that w ere later subm it-ted to PPP lenders. Specifically, your
Affiant'sreview Ofthe emailaccountrevealed thatthere were ten (10)separate instances in
which CHA PM AN sentfalse and fraudulentSchedule C's în the nam es of individuals forw holm
Kelly prepared PPP loan applications.
For exam pie, on M arch 31, 2021, CI-IAPM AN sent an em ail to Kelly that
contained a tax year 2020 Schedule C for a sole pl-oprietorship owned by W idny Tlnibaud
(i(Thibaud''),one ofKelly'sco-defendantsin CaseNo.24-20079-CR-FAM(s).Thibaud cablsed
thesubmission oftwo (2)PPP loan applicationsto Lender2 and Lender4 respectively.Portions
of these applications were subm itted via interstate w ire com munications. The Schedblle C's
prepared by CHAPM A N were subm itted in support of Thibaud's applications stated that
Lusinesshad annualgrossrevenue of$99,802 and profits gf$52,039.The lenders accepted the
representationsin the loan application and on oraboutA pril23,202l,Thibaud received a loan in
the amoblntof$20,792frolm Lender2 and on M ay 27,2021,he received a loan in tl
neamountof
$20,792 from Lender 4. Ftlrther investigation revealed that the Schedtlled C attached to
Thibaud's Ioan applicationswasfalse and fraudulent.
CHAPM AN'S SUBM ISSION OF HER OW N FIU UDULENT PPP LOAN
A PPLICATIO NS
26. O n Febrtlary 10, 2021, CHA PM AN , again w hile em ployed by the SBA ,
'
subm itted,via interstate w ire colnm unication,a loan application in the nalme of Upscale Credit
k
Lounge to Lender 3. ln support of her application, CHAPM AN subm itted a tax year 2020
SchedblleC thatreported grossrevenuesof$103,674 and atentativeprofitof$81,860. Lender3
relied upon the l
-epresentations in CHA PM AN 'S application and on February 11,202 1,approved
Case 1:24-cr-20321-RAR Document 1 Entered on FLSD Docket 07/08/2024 Page 8 of 12
a loan in tl4eannotlntof$17,052.50.Furtlnerinvestigationrevealed thatthe Schedblled C attacl
ned
to thisapplication w asfalse and fraudulent,
O n February 19, 202l, Chapm an, again while still em ployed by tl
3e SBA ,
sublnitted,via interstate w ire com m unication,a PPP loan application w ith Lender3 on behalfof
DA TRAP.ln herapplication,CHAPMAN claimed thatshe had four (4)employees and an
average monthly payrollof$14,l91. In stlpportofherapplication,CHAPM AN submitted four
1RS ElmployersQual
-terly Tax Return tilFol-nn 941''),which pblrportedly docbll
mented the
w ages paid by DA TRAP. Lender 3 relied upon the representations in the application and on
February 26,2021,approved aloan in the aluountof$35,477.50. Furtherinvestigation revealed
tlatthe lmultiple IRS Form s 941 attached to CHA PM AN 'S application w ere false and fraudtllent.
28. O n Apri1l0,2021,CHA PM AN subl
m itted,via intel
-state w ire transm ission,a loan
application to Lender 1 for a sole proprietorship property l
m anagel
m entbusiness. In support of
herapplication,CI
-IA PM AN stlbm itted a Schedule C in w hich sl4e stated hergrossrevenues were
$123,950, and her tentative profits were $78,187. Lender 1 captured the IP Address
98.203.44.206 in connection w ith the filing of this loan application.Lender l relied upon the
representations in the loan application and on April15,2021,approved a loan in the am ountof
$20,833. Further investigation revealed thatthe Scheduled C attached to this application was
falseand fraudulent.
CHA PM AN 'SA TTEM PTED FR AU D IN CO NN ECTIO N W ITII OBTAINING A
HOM E EOUITY LINE OF CREDIT
Throblgh the review of financial records,your Affiant learned tlnat CHA PM AN
appliedfora Home Equity LineofCredit(HELOC)from CreditUnion 1and submitted falsified
docum ents in suppol'
t of thexapplication.Specifically,on M ay 11,2023,CHAPM AN subm itted
6
Case 1:24-cr-20321-RAR Document 1 Entered on FLSD Docket 07/08/2024 Page 9 of 12
her application and requested a HELOC in the amount of $115,000. typical in all
residential loan applications, Credit Union reqblired CHA PM AN to subm it proof of her
employm entand on June 3,2023,CHAPM A N subm itted pay stubs from M useblm 1 tllatstated
she wasemployed by M tlseum 1and received a bi-weel
tly paycheck of$1827.66. Pursblantto
the issuance of grand jury subpoenas issued to Museum 1, your Affsant confirmed that
CHAPM AN w as never em ployed by M useum l and thatthe pay stubs she subm itted to Credit
U nion 1 were forged. On Jtlne l1, 2023, Credit Union 1 denied CHA PM AN 'S I
-IELO C
application.
CH A PM AN 'S PREPA IG TIO N O F FALSE AN D FR AUD ULEN T PPP LOA N
A PPLICATION S IN RETURN FO R A K ICBAC K
Nvarrant 013 the el
-nail account
infor/up
.scalecredit.netyourAffiantlearnedthatinadditionto preparing PPP loan applications
in her ow n nam e,CHAPM AN also prepared PPP loan applicationson behalfofother people in
return for a payl
ment of a kickback. Specifically,your Affiant review ed one el-nail in
CHAPM AN wrote:
Hey there, thank you for allow ing The Upscale Resource to assist w ith your PPP
application.Congratuiationson being approved by the SBA .N extsteps would be foryourto tlse
the funds con-ectly so that the loan will be forgiven. W e also provide loan forgiveness
assistance.Please see below to processforpaymentforfunds received.''
The same em ailthen had a heading that stated,CCPPP & 2020 Schedtlle C draft-
l0% back end''and tl
nen stated kcifyou received a loan in the amountof$20,833 yourpayment
today will be $2083.''Through a review of the calendar appointments in the emailaccount
il-
kfclrrl
jl,upscaleçret
:liy,peyyotlrAffiantfoundseveralindividualswhohad appointmentsscheduled
w ith CHAPM AN that wet'e titled (IPPP forgiveness.''Your A ffiant then took several of-those
nam es and ran them in a PPP loan database and determ ined thatt13e individuals applied fbr and
Case 1:24-cr-20321-RAR Document 1 Entered on FLSD Docket 07/08/2024 Page 10 of 12
aboutPPP forgiveness and investigation revealed thaton M ay 20,202 l,a PPP loan application
was sblbm itted on behalfoflndividtlal3 to Lender l. A Schedule C w assubm it
-ted in supportof .
that application that stated in tax year 2020 Individual3 had a sole proprietorship w ith gross
revenuesof$98,588 and tentative profitsof$9,409. On M ay 27,2021,Lender 1 accepted the
representations in the applicytion and approved a loan in the amountof$20,539,lnvestigation
l
nasreve'
aled thatthe Schedule C attached to this application w as false.D blring the subnnission of
thisloan application one ofthe IP addresses captured by Lender l was 98.203.44.206.Tlnis isthe
sam e IP address that w as captured when CH APM AN subm itted lner own loan application to
Lender 1,w hich isdiscussed in nnore detailin paragraph 29 above.
CHAPMAN'SW IRE FIG UD IN CONNECTION W ITH THE CITY OF M IAM I
EM ERG ENCY RENTAL ASSISTA NC E PR O G RA M
O n A pril l3,2022,CHA PM AN applied forem ergency rentalassistance from the
application, CHA PM AN answered Cç
N o'' to the question 'tdo you have any assets valued in
excessof$50007:' A search ofM iam i-Dadeproperty appraisersoffsce recordsby yotlrAffiant
revealedthatonDecember31,2021,CHAPMAN becametheownerofthree(3)separatesingle
fam ily hom es in M iam i-Dade County.A ccording to M iam i-Dade County property records,the
tax year 2023 assessed of these thme (3) single fam ily homes is $727,299. In the same
application, CHAPM AN certified that she did not receive any rental incom e from real
persol:alpl-operty. Your A ffiant has obtained CHA PM A N 'S bank records and an analysis of
tl
nem revealed that CHA PM AN from Septem ber 20, 2021, through April 2022, received
approxil
mately $24,1l5 in payments from an internet-based home rentalwebsite prior to the
8
Case 1:24-cr-20321-RAR Document 1 Entered on FLSD Docket 07/08/2024 Page 11 of 12
filing of this application.This includes a totalof $3723 in payments fronn the salue internet-
based hom e rentalwebsite during the m onth ot
-A pril2022. The City of M iam irelied upon the
repl-esentationsin theapplication and onJune 21,2022,itsenta check in the aluountof$14,525
to tl:e landlord of 1480 N . River D rive 5/1ialni, FL 33125. This check svas then relmotely
deposited,via interstate w ire connm tlnication,into a bank in tlne State ofUtah. A ftersigning her
application clailming she received no rentalincolne CHAPkIAN received $5,971 in payl
nents
from the salme intelmet-based holme rentalw ebsite.
W ire Fraud lnvolvin: State ofFlorida O ur Florida Em eraency R entalAssistanceProcram
in or around Febrblary of 2022,
CHAPM AN engaged in a schem e to defraud tlne State of Florida Em ergency RentalAssistance
Program .On O ctober 13,2021,CHA PM AN began the pfocess ofapplying fbrbenefits underthe
State ofFlorida's Emergency RentalA ssistance program . CHA PM AN was purportedly a tenant
at2614 N W 55TH Terrace M iam i, FL 33142.CHA PM AN subm itted required inform ation and
docum ents through an online portalsettlp to distribtlte benelits under the program .On January
20,2022,CHA PM AN subm itted a w ritten docum ent titled ût3-day notice to pay rent or quit.''
These docum ents were dated Decelnber 7,2021, and purportedly signed by Individual 2,the
defendant's mother.Investigatioi'by yourAffiantrevealed thatIndividtlal2 died on M ay 25,
2020. The State of Florida accepted the l
'epresentations in CHAPM AN 'S application and
approved payments totaling $15,000. These payments were made into a bank account
controlled by CHA PAM AN .
9
Case 1:24-cr-20321-RAR Document 1 Entered on FLSD Docket 07/08/2024 Page 12 of 12
fzollclt1si()ll
31. lsublmitthattllereisprollat
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oonll
nittt!d violationsof-l8U.S.C.jj l349,1343ald I344 (conspiracy to con)n'
litvvirefraud.
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-efratldaltlbankfratld),Ace()l
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'tlbyreqtlestiSstlanccOf'al/al
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CIIA PM AN .
FIJRTHER A FFIANT SAY ETH N AUG 1'1-1-.
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'UR S W lLK IN S
SPEClAL AGENT
UN ITED STATES POSTAL SERVICE
O17FICE O1
7INSPECTOR GENERAL
Attested to bytheapplicantinaccordancewitl
ètherequirementsof-Fed.R.Crim.P.4.l
by FaceTimcthis 3rd dayof-July2024.
/
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HONORA LE JONATHAN CJOODMAN
UN ITED S-I'ATES M AGIS-I'RATE JUDGE
1û
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