Factual Basis — No. 3:25-cr-00106 (Dkt. 64, W.D.N.C.)

Summary

A factual basis filed by the United States in the U.S. District Court for the Western District of North Carolina in United States v. Tijema Brown, defendant (2), Docket No. 3:25-CR-106-KDB, docketed as 3:25-cr-00106, as Document 64 of 5 pages. Filed by Dallas J.E. Kaplan, First Assistant United States Attorney, under Local Criminal Rule 11.2 in support of a plea agreement, it states that it does not set out all facts known to the United States and that the parties agree the facts establish the offense elements. After the plea is accepted the United States will give the Probation Office a Statement of Relevant Conduct under Local Criminal Rule 32.4, to which the defendant may respond within seven days. Defense counsel James Quander certifies no dispute.

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“Factual Basis — No. 3:25-cr-00106 (Dkt. 64, W.D.N.C.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/factual-basis-no-3-25-cr-00106-dkt-64-w-d-n-c-eec6d4d564/, SHA-256 2285c186b4136efd5ccf0ce90272ebbd95fc929262ac0cc268c56ff7964a5704.

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IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF NORTH CAROLINA
CHARLOTTE DIVISION

UNITED STATES OF AMERICA )
) DOCKET NO. 3:25-CR-106-KDB
v. )
) FACTUAL BASIS
(2) TIJEMA BROWN )
)

NOW COMES the United States of America, by and through Dallas J.E. Kaplan1, First
Assistant United States Attorney for the Western District of North Carolina, and hereby files this
Factual Basis in support of the plea agreement filed simultaneously in this matter.

This Factual Basis is filed pursuant to Local Criminal Rule 11.2 and does not attempt to
set forth all of the facts known to the United States at this time. By their signatures below, the
parties expressly agree that there is a factual basis for the guilty plea(s) that the defendant will
tender pursuant to the plea agreement, and that the facts set forth in this Factual Basis are sufficient
to establish all of the elements of the crime(s). The parties agree not to object to or otherwise
contradict the facts set forth in this Factual Basis.

Upon acceptance of the plea, the United States will submit to the Probation Office a
66
Statement of Relevant Conduct” pursuant to Local Criminal Rule 32.4. The defendant may
submit (but is not required to submit) a response to the Government’s “Statement of Relevant
Conduct” within seven days of its submission. The parties understand and agree that this Factual
Basis does not necessarily represent all conduct relevant to sentencing. The parties agree that they
have the right to object to facts set forth in the presentence report that are not contained in this
Factual Basis. Either party may present to the Court additional relevant facts that do not contradict
facts set forth in this Factual Basis.
TB
1. Beginning in or around April 2020 and continuing through in or around at least
September 2021, in Mecklenburg County within the Western District of North Carolina and
elsewhere, Defendant Tijema BROWN (“BROWN”) did knowingly combine, conspire,
confederate, and agree with Tiawana Brown and Antionette Rouse to commit wire fraud, in
violation of Title 18, United States Code, Section 1349. BROWN willfully joined and participated
in the conspiracy while knowing its unlawful purposes and with the intent to further its unlawful
purposes.

TB 2. It was a part and an object of the conspiracy that BROWN, Tiawana Brown, and
Antionette Rouse, with the intent to defraud, did knowingly and intentionally 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 by concealment of material facts, and for the purpose

1 Acting under authority conferred by 28 U.S.C. § 515.

Case 3:25-cr-00106-KDB-DCK Document 64 Filed 03/27/26 Page 1 of 5
of executing such scheme and artifice to defraud, did transmit and cause to be transmitted by means
of wire communications in interstate commerce any writing, signal, picture, and sound, to wit,
electronic loan and loan forgiveness applications to the Small Business Administration and
Paycheck Protection Program lenders, note documents to the same, wire transfers, and other
electronic financial transactions, in violation of Title 18, United States Code, Section 1343.
TB
3. Between April 2020 and September 2021, BROWN, Tiawana Brown, and
Antionette Rouse conspired to execute a wire fraud scheme to defraud the Small Business
Administration’s (SBA) Economic Injury Disaster Loan (EIDL) program and its Paycheck
Protection Program (PPP) to obtain COVID-19 pandemic relief funds through the submission of
loan applications for fake businesses, which contained false information or false documentation.
The false documentation generally included fake and fraudulent tax forms that lied about gross
income and number of employees, among other misrepresentations.

TB 4. On or about June 25, 2020, BROWN submitted and caused to be submitted EIDL
application *8889 to the SBA via an online submission in the name of a fake sole proprietorship
business in the name Tijema Brown. In the application, BROWN falsely represented that her
business was a “personal services” business with 1I employees and $14,300 in gross revenues
from 2019. BROWN certified under penalty of perjury that the information in EIDL application
*8889 was correct and that she would use the funds as directed by the EIDL program. Upon receipt
of EIDL application *8889, the SBA approved a $10,000 advance on the loan application. On or
about June 30, 2020, the SBA wired $10,000 to a bank account in the name of BROWN ending in
*2364 pursuant to the EIDL application.
TB
5. On or about August 31,2020, BROWN submitted and caused to be submitted EIDL
application *1392 to the SBA via an online submission in the name of a fake sole proprietorship
business in the name La’Stephanie Brown. In the application, BROWN falsely represented that
the business was a “health services” business with 5 employees and $134,000 in gross revenues
from 2019 that had operated since March 3, 2017, at the same address as the prior application.
La’Stephanie was the middle name of BROWN. EIDL application *1392, in the name
La’Stephanie Brown, included BROWN’s social security number, BROWN’s bank account
ending in *2364, and Tiawana Brown’s phone number. BROWN certified, as “La’Stephanie
Brown,” under penalty of perjury that the information in EIDL application *1392 was correct and
that they would use the funds as directed by the EIDL program. The SBA rejected this loan
application.

TB 6. On or about August 17,2021, BROWN submitted and caused to be submitted EIDL
application *7105 to the SBA via an online submission in the name of a fake sole proprietorship
business in the name Tijema Brown. In the application, BROWN falsely represented that her
business was an “entertainment services” business with 2 employees and $15,500 in gross
revenues from 2019 that had operated since May 25, 2017. BROWN certified under penalty of
perjury that the information in EIDL application *7105 was correct and that she would use the
funds as directed by the EIDL program. The SBA rejected this loan application.

Case 3:25-cr-00106-KDB-DCK Document 64 Filed 03/27/26 Page 2 of 5
TB 7. Lender 1 was a California-based small business lending company. Lender 1
participated in the SBA’s PPP as a lender and, as such, was authorized to lend funds to eligible
borrowers under the terms of the PPP. On or about April 3, 2021, BROWN submitted and caused
to be submitted a PPP application for a fake business with respect to a PPP loan numbered *8703
to Lender 1. In the application materials, BROWN falsely stated that she operated a sole
proprietorship business in her own name that was established on January 1,2020, which generated
$106,600 in gross income in 2019.

TB 8. As part of the application, BROWN submitted a fake 2019 Internal Revenue
Service (IRS) Schedule C Form for the purported business. The fake Schedule C Form was in the
name of TIJEMA BROWN under the business name Givin Looks By Jema. The form falsely
stated that the business earned $106,600 in gross receipts and had $10,350 in expenses, resulting
in $96,250 in net profits in 2019. This form was fake, as it was never filed with the IRS, and no
such business existed. This fake IRS Schedule C Form was identical to the 2019 Schedule C Form
later submitted for PPP loans by Tiawana Brown and Antionette Rouse, other than business
identity information. BROWN, Tiawana Brown, and Antionette Rouse used the same fake
Schedule C form for their respective PPP applications.

TB 9. In her application, BROWN stated that she would use the loan funds to pay payroll
costs. BROWN certified under penalty of perjury that the information in the PPP application was
true and correct. As a result of PPP loan *8703, Lender 1 wired $20,833 in PPP loan funds to
BROWN to her bank account ending in *2364 on April 16, 2021. On or about August 20, 2021,
the SBA reimbursed Lender 1 and forgave BROWN for this loan based on BROWN’s false
representation under penalty of perjury that she spent $12,500 of the loan funds on payroll costs
for the fake business and complied with all applicable PPP rules, including those regarding the
eligible uses of PPP loan proceeds.

TB 10. On or about April 26, 2021, TIJEMA BROWN submitted and caused to be
submitted a second draw PPP application for a loan numbered *8907 to Lender 1. The application
materials contained the same false information and false documentation as PPP loan *8703 in the
name Tijema Brown and Givin Looks By Jema, including the fake 2019 IRS Schedule C Form in
the name of Givin Looks By Jema. In her application, TIJEMA BROWN stated that she would
use the loan funds to pay payroll costs. TIJEMA BROWN certified under penalty of perjury that
the information in the PPP application was true and correct. As a result of PPP loan *8907, Lender
1 wired $20,833 in PPP loan funds to TIJEMA BROWN to her bank account ending in *2364 on
May 10, 2021. On or about August 24, 2021, the SBA reimbursed Lender 1 and forgave TIJEMA
BROWN for this loan based on TIJEMA BROWN’s false representation under penalty of perjury
that she spent $12,500 of the loan funds on payroll costs for the fake business and complied with
all applicable PPP rules, including those regarding the eligible uses of PPP loan proceeds.

TB 11. On or about April 26, 2021, Tiawana Brown submitted and caused to be submitted
a PPP application for a loan numbered *8906 to Lender 1. Tijema BROWN assisted Tiawana
Brown in the submission of this application. In the application materials, Tiawana Brown falsely
stated that she operated a sole proprietorship business in her own name that was established on

Case 3:25-cr-00106-KDB-DCK Document 64 Filed 03/27/26 Page 3 of 5
January 1,2020, which generated $106,600 in gross income in 2019. As part of the application,
Tiawana Brown submitted and caused to be submitted a fake 2019 IRS Schedule C Form for the
purported business. The fake Schedule C Form was in the name of Tiawana Brown under the
business name TC Collection. The form falsely stated that TC Collection earned $106,600 in gross
receipts and had $10,350 in expenses, resulting in $96,250 in net profits in 2019. This form was
fake, as it was never filed with the IRS. This fake 2019 Schedule C Form was identical to the 2019
Schedule C Forms submitted for PPP loan *8703 and PPP loan *8804 under the business names
Givin Looks By Jema (owned by Tijema BROWN) and Antionette Rouse, respectively, other than
business identity information. In the application, Tiawana Brown stated that she would use the
loan funds to pay payroll costs. Tiawana Brown certified under penalty of perjury that the
information in the PPP application was true and correct. As a result of PPP loan *8906, Lender 1
wired $20,833 in PPP loan funds to Tiawana Brown to her bank account ending in *5776 on May
5, 2021. On or about August 24, 2021, the SBA reimbursed Lender 1 and forgave Tiawana Brown
for this loan based on Tiawana Brown’s false representation under penalty of perjury that she spent
$12,500 of the loan funds on payroll costs for the purported business and complied with all
applicable PPP rules, including those regarding the eligible uses of PPP loan proceeds.
TB
12. As a result of the wire fraud conspiracy, BROWN received $51,666 in fraud
proceeds from the SBA and the PPP lenders. BROWN aided Tiawana Brown in submitting a false
application to a PPP lender, which resulted in Tiawana Brown receiving $20,833 in fraud proceeds.
Thus, the conspiracy, to the extent to which BROWN was involved, caused losses greater than
$40,000 but less than $95,000.

TB 13. BROWN spent the PPP and EIDL funds on personal expenditures, in violation of
the PPP and EIDL loan terms.

DALLAS J.E. KAPLAN
FIRST ASSISTANT UNITED STATES ATTORNEY

MATTHEW WARREN
ASSISTANT UNITED STATES ATTORNEY

Case 3:25-cr-00106-KDB-DCK Document 64 Filed 03/27/26 Page 4 of 5
Defendant’s Counsel's Signature and Acknowledgment

I have read this Factual Basis, the Bill of Indictment, and the plea agreement in this case,
and have discussed them with the defendant. Based on those discussions, I am satisfied that the
defendaj iderstands the Factual Basis, the Bill of Indictment, and the plea agreement. I hereby
certify that the defendant does not dispute this Factual Basis.

DATED:
(James Quander, Attorney for Defendant

Case 3:25-cr-00106-KDB-DCK Document 64 Filed 03/27/26 Page 5 of 5

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