Superseding Information — United States v. Annette Bryant, No. 3:22-CR-00419-S (Northern District of Texas)

Summary

A Superseding Information in United States of America v. Annette Bryant, No. 3:22-CR-00419-S, Document 26, filed July 7, 2023, in the U.S. District Court for the Northern District of Texas, Dallas Division. The United States Attorney charges Count One, Conspiracy to Make a False Statement to a Bank, citing 18 U.S.C. § 371 and 18 U.S.C. § 1014, for a period from at least in or about April 2020 through in or about April 2021. The information alleges that false and fraudulent Paycheck Protection Program loan applications were submitted for businesses owned by Annette Bryant, with inflated employee numbers and monthly payroll. It also alleges that IRS tax forms were submitted to financial institutions without having been filed with the IRS, and lists overt acts with application dates and bank names.

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“Superseding Information — United States v. Annette Bryant, No. 3:22-CR-00419-S (Northern District of Texas).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-txnd-369457-26-0-38166e614f/, SHA-256 ab4fa8efedfc02c5c5eee73e6e3aef812948ff7163cf444037e169d91b05feda.

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Case 3:22-cr-00419-S Document 26 Filed 07/07/23. Pageilof5 PagelD 62

8) IN THE UNITED STATES DISTRICT COURT FILED
FOR THE NORTHERN DISTRICT OF TEXAS 1023 JUL -7 py fp. 07

DALLAS DIVISION
UNITED STATES OF AMERICA NO. 3:22-CR-00419-S Seamer
Vv.
ANNETTE BRYANT (01)

SUPERSEDING INFORMATION

The United States Attorney charges:

Count One
Conspiracy to Make a False Statement to a Bank
(Violation of 18 U.S.C. § 371 (18 U.S.C. § 1014))

1. From at least in or about April 2020 through in or about April 2021, the
defendant, Annette Bryant, and others both known and unknown to the United States
Attorney, in the Northern District of Texas and elsewhere, did willfully and knowingly
combine, conspire, confederate, and agree together and with each other to make a false
statement for the purpose of influencing the actions of financial institutions, the deposits
of which were insured by the Federal Deposit Insurance Corporation (FDIC), in violation
of 18 U.S.C. § 1014.

Introduction and Parties

2. The defendant, Annette Bryant, was a resident of Waxahachie, Texas, in

the Dallas Division of the Northern District of Texas.

Superseding Information—Page 1
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3. Processing Services, Inspirational Tax Services LLC (Processing) was a
Texas limited liability company. Annette Bryant was Processing’s registered agent and
sole owner.

4. Neighborhood Tx Inspections LLC (Neighborhood) was a Texas limited
liability company. Annette Bryant was Neighborhood’s registered agent and sole
owner.

5. JJ&JJ Remodeling and Roofing LLC (JJ&JJ) was a Texas limited liability
company. Annette Bryant was JJ&JJ’s registered agent and sole owner.

6. JAM Business & Tax Services LLC (JAM) was a Texas limited liability
company. Annette Bryant was JAM’s registered agent and sole owner.

Ve Community National Bank & Trust of Texas, Interbank, Regions Bank,
Comerica Bank, and First Bank of the Lake were financial institutions the accounts of
which were insured by the FDIC.

8. The Paycheck Protection Program (PPP), implemented by the Small
Business Administration, was a COVID-19 relief program that, among other things,
provided small businesses with forgivable loans to pay for payroll and certain other
expenses. Under the PPP, participating third-party lenders approved loan applications
and disbursed PPP loans to qualifying businesses.

9. To obtain a PPP loan, a business was required to submit a PPP loan
application to a third-party lender. In the PPP loan application, the business was required

to state, among other things, the business’s average monthly payroll expenses and its

Superseding Information—Page 2
Case 3:22-cr-00419-S Document 26 Filed07/07/23. Page3of5 PagelD 64

number of employees. This payroll information was used to calculate the amount of
funds that the business was eligible to receive as a PPP loan.

Object of the Conspiracy

10. It was a part and object of the conspiracy for Annette Bryant and her
coconspirators to unlawfully enrich themselves by submitting and causing the submission
of false and fraudulent applications for PPP loans and using the proceeds of the fraud for
their personal use.

Manner and Means of the Conspiracy

11. The manner and means by which the defendants sought to effect the objects
of the conspiracy included, among others, the following:

a. It was part of the conspiracy that Annette Bryant, conspiring with
others, prepared and submitted, and caused to be prepared and submitted, false and
fraudulent PPP loan applications on behalf of businesses owned and controlled by
Bryant to financial institutions in which she made multiple materially false and
fraudulent representations, such as: (i) falsely stating and inflating the business’s number
of employees; (ii) misstating and inflating the business’s monthly payroll; and (iii) falsely
stating the number of businesses that Bryant owned or with which she was affiliated.

b. Additionally, Annette Bryant, conspiring with others, prepared and
submitted, and caused to be prepared and submitted, Internal Revenue Service (IRS) tax
documents that were purportedly filed on behalf of her individually and her businesses,
including IRS Forms 1040 Individual Income Tax Returns, IRS Forms 940 Employer’s
Annual Federal Unemployment Tax Returns, and IRS Forms 941 Employer’s Quarterly

Superseding Information—Page 3
Case 3:22-cr-00419-S Document26 Filed07/07/23. Page4of5 PagelD 65

Federal Tax Returns. However, the forms submitted to the financial institutions had not
been filed with the IRS and contained false information regarding Bryant’s businesses
and her personal income.

Overt Acts in Furtherance of the Conspiracy

12. In furtherance of the conspiracy and to effect its object, Annette Bryant,
conspiring with others, submitted and caused to be submitted PPP loan applications to the
financial institutions described below, on or about each of the dates listed below and on
behalf of her businesses as listed below, that falsely stated the monthly payroll of the
respective entities in order to induce the financial institutions to approve the PPP loans

and maximize the amount of each loan:

5/7/2020 $102,687.50 | Community National —

All in violation of 18 U.S.C. § 371 (18 U.S.C. § 1014).

Superseding Information—Page 4
Case 3:22-cr-00419-S Document26- Filed07/07/23. Page5of5 PagelD 66

LEIGHA SIMONTON
UNITED STATES ATTORNEY

MARTY BASU

Assistant United States Attorney
Illinois State Bar No. 6302360
FABIO LEONARDI

Assistant United States Attorney
New York State Bar No. 4902938
1100 Commerce Street, Third Floor
Dallas, Texas 75242

Tel: 214-659-8600

Fax: 214-659-8812

Email: marty.basu@usdoj.gov
Email: fabio.leonardi@usdoj.gov

Superseding Information—Page 5

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