Criminal Information — No. 2:20-cr-00197 (Dkt. 1, E.D. Wis.)

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A three-page criminal information filed by the United States in the U.S. District Court for the Eastern District of Wisconsin, Case 2:20-cr-00197, as Document 1, charging Tarone La Dale Woods. Count One, false statements under 18 U.S.C. § 1001(a) and 2, charges that in or about May 2020 Woods knowingly made materially false statements in a matter within the jurisdiction of the Small Business Administration: on or about May 18, 2020 he signed, initialed and submitted an SBA Form 2483 Paycheck Protection Program Borrower Application Form knowing it falsely stated that his company was in operation on February 15, 2020, had 23 employees, and had an average monthly payroll of $92,000. A forfeiture allegation under 18 U.S.C. § 981(a)(1)(D) and 28 U.S.C. § 2461(c) follows, and the information is signed for the Department of Justice.

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF WISCONSIN

UNITED STATES OF AMERICA,
Plaintiff, 20 CR l 97
v. Case No.
[18 U.S.C. §1001]
TARONE LA DALE WOODS,
Defendant.

CRIMINAL INFORMATION

The United States of America charges that:
Count One

False Statements
18 U.S.C. § 1001 (a) and 2

1. In or about May 2020, in the Eastern District of Wisconsin and elsewhere, the

defendant,
TARONE LA DALE WOODS (“WOODS”),
did knowingly and willfully make materially false, fictitious, and fraudulent statements and
representations in a matter within the jurisdiction of the executive branch of the Government of
the United States, namely, the Small Business Administration, those being: on or about May 18,
2020, WOODS signed, initialed, and submitted an SBA Form 2483 Paycheck Protection Program
Borrower Application Form knowing the form contained false information regarding his
company’s eligibility for a Paycheck Program loan, including that:
a. The company was in operation on February 15, 2020;

b. The company had 23 employees for whom it paid salaries and payroll taxes; and

c. The company’s average monthly payroll was $92,000.

Case 2:20-cr-00197-BHL Filed 10/23/20 Page1of3 Document 1
All in violation of Title 18 United States Code, Section 1001(a) and 2.

FORFEITURE ALLEGATION

2. Pursuant to 18 U.S.C. § 981(a)(1)(D) and 28 U.S.C. § 2461(c), upon conviction of
an offense in violation of false statements, in violation of 18 U.S.C. § 1001, as alleged in this
Information, the defendant shall forfeit to the United States of America all property, real and
personal, which constitutes and is derived from proceeds traceable to the scheme to defraud. The
property to be forfeited includes, but is not limited to, a money judgment in the amount of the total
loss caused by the defendant’s criminal conduct, as determined by the Court at sentencing.

3, If any of the property described above, as a result of any act or omission of the defendant:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction of the court;
d. has been substantially diminished in value; or has been commingled with other
property which cannot be divided without difficulty;
the United States of America shall be entitled to forfeiture of substitute property pursuant to Title

21, United States Code, Section 853(p), as incorporated by Title 28, United States Code, Section

2461(c).

Case 2:20-cr-00197-BHL Filed 10/23/20 Page 2of3 Document 1
Respectfully submitted,

_~- MATTHEW D. KRUEGER
United States Attéenéy

DANIEL S. KAHN

Acting Chief, Fraud Section
Criminal Division

United States Department of Justice

By:
__/s/Laura Connelly

Laura Connelly

Leslie Garthwaite

Trial Attorneys, Fraud Section
Criminal Division

United States Department of Justice
1400 New York Avenue, N.W.
Bond Building, Fourth Floor
Washington, D.C. 20530

(202) 307-1423 (Connelly)
Laura.Connelly@usdoj.gov

Case 2:20-cr-00197-BHL Filed 10/23/20 Page 3of3 Document 1


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