Indictment — Case 5:21-cr-00317-PAB, Doc #: 1, United States District Court for the Northern District of Ohio

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Indictment in Case 5:21-cr-00317-PAB, Doc #: 1, in the United States District Court for the Northern District of Ohio, a 4,611,318-byte PDF named 1-indictment.pdf. No public link to an original was identified.

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Case: 5:21-cr-00317-PAB Doc #: 1 Filed: 04/29/21 1 of 19. PagelD #: 1

FILED
IN THE UNITED STATES DISTRICT COURT APR 29 202%
FOR THE NORTHERN DISTRICT OF OHIO — |
EASTERN DIVISION NORTHER CT COURT
NORTHERN OF OHIO
UNITED STATES OF AMERICA, ) INDICTMENT
Plaintiff, ) JU DGE BARKER
) << © ‘Title 18, United States Code,
TERRENCE L. POUNDS, ) Sections 1343, 1349, 1957,
CHARLES B. TILLER, III, ) and 2
TERRI DAVIS, )
RANDOLPH NUNN, )
SAMIRA ABDUL-KARIM, )
QUWAN SIMMONS, )
)
Defendants. )
GENERAL ALLEGATIONS

At all times relevant to this Indictment:
The Defendants

1. Defendant TERRENCE L. POUNDS resided in Holland, Ohio, in the Northern
District of Ohio.

2. Defendant CHARLES B. TILLER, III resided in Columbus, Ohio.

3. Defendant TERRI DAVIS resided in Old Hickory, Tennessee.

4. Defendant RANDOLPH NUNN resided in Canton, Ohio, in the Northern District
of Ohio, Eastern Division.

5. Defendant SAMIRA ABDUL-KARIM resided in New Haven, Connecticut.

6. Defendant QUWAN SIMMONS resided in Hartford, Connecticut.
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The United States Small Business Administration and the CARES Act

7. The United States Small Business Administration (“SBA”) was an executive
branch agency of the United States government. The mission of the SBA was to maintain and
strengthen the nation’s economy by enabling the establishment and viability of small businesses
and assist in the economic recovery of communities after disasters. As part of this effort, the
SBA enabled and provided for loans through banks and other lenders. These loans had
government backed guarantees.

8. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was a
federal law enacted in or around March 2020 and was designed to provide emergency financial
assistance to Americans suffering the economic effects caused by the COVID-19 pandemic. One
source of relief under the CARES Act was authorization for the SBA to issue loans to small
businesses and non-profit entities experiencing revenue loss due to the pandemic.

9. One form of such assistance was the Economic Injury Disaster Loan (“EIDL
loan”) program, which provided loan assistance for certain businesses negatively affected by the
COVID-19 pandemic. To qualify for an EIDL loan, a business had to, among other
requirements, be in operation prior to February 1, 2020.

10. Applicants for EIDL loans used the SBA online portal to submit their application
materials. The SBA servers that processed the EIDL loan applications were based in the state of
Iowa.

11. Applicants had to certify that the information in the application was true and
correct, under the penalty of perjury and applicable criminal statutes. The application process
involved filling out data fields relating to the size and ownership of the affected business entity,

and other information about the relevant business for the 12 months prior to COVID-19
Case: 5:21-cr-00317-PAB Doc #: 1 Filed: 04/29/21 3 0f 19. PagelD #: 3

impacting the national economy, such as the number of employees in the business, the gross
business revenues realized, and the cost of goods sold. This information, submitted by the
applicant, was then used by SBA systems to calculate the amount of money the applicant was
eligible to receive.

12. Non-profit applicants and non-agricultural for-profit applicants were both
generally eligible to receive an EIDL loan of up to $150,000, with a 30-year scheduled
repayment, deferred for 12 months.

| 13. Any funds paid by the SBA under an EIDL loan were processed and issued from
the state of Colorado and sent to the applicant borrower’s financial institution.

14. Pursuant to the provisions governing the EIDL program, loan proceeds could only
be used by the affected business receiving EIDL loans for certain permissible expenses. The
loans could be used by the business to pay fixed debts, payroll, accounts payable, and other bills
that could have been paid had the COVID-19 disaster not occurred.

15. | Another form of assistance provided by the CARES Act was the authorization of
United States taxpayer funds in forgivable loans to small businesses for job retention and certain
other expenses, through a program referred to as the Paycheck Protection Program (“PPP”).

16. To obtain a PPP loan a qualifying business was required to submit a PPP loan
application, signed by an authorized representative of the business. The PPP loan application
required the small business, through its authorized representative, to acknowledge the program
rules and make certain affirmative certifications to be eligible to obtain the PPP loan. In the PPP
loan application, the small business, through its authorized representative, was required to |
provide, among other things, its average monthly payroll expenses and number of employees.

These figures were used to calculate the amount of money the small business was eligible to
Case: 5:21-cr-00317-PAB Doc #: 1 Filed: 04/29/21 4 of 19. PagelD #: 4

receive under the PPP. In addition, businesses applying for a PPP loan were required to provide
documentation showing their payroll expenses,

17. PPP loan applications were processed by a participating financial institution. Ifa
PPP loan application was approved, the participating lender funded the PPP loan using its own
monies, which were 100% guaranteed by the SBA. Data from the application, including
information about the borrower, the total amount of the loan, and the listed number of
employees, was transmitted by the lender to the SBA in the course of processing the loan.

18. PPP loan proceeds could only be used by the business on certain permissible
expenses, such as payroll costs, interest on mortgages, rent and utilities. The PPP allowed the _ |
interest and principal on the PPP loan to be entirely forgiven if the business spent the loan
proceeds on the allowable expenses within a designated period of time and used a certain
percentage of the PPP loan proceeds towards payroll expenses.

Relevant Financial Institutions

19. Bank 1 was a financial institution based in Salt Lake City, Utah, and an approved
SBA lender of PPP loans.

20. Bank 2 was a financial institution based in Fort Lee, New Jersey, and an
approved SBA lender of PPP loans.

21. Bank 3 was a financial institution based in Canton, Ohio. NUNN controlled a
bank account at Bank 3 ending in 8495.

22. Bank 4 was a financial institution based in Hartford, Connecticut. ABDUL-
KARIM controlled bank accounts at Bank 4, including one ending in 4156.

23. Bank 5 was a financial institution based in New York, New York, with bank .

branches in Ohio and Connecticut. POUNDS controlled bank accounts at Bank 5, including
Case: 5:21-cr-00317-PAB Doc #:1 Filed: 04/29/21 5 of 19. PagelD #:5

those ending in 9652 and 8356. SIMMONS controlled a bank account at Bank 5, ending in
2622. |

24. Bank 6 was a financial institution based in The Woodlands, Texas, with bank
branches in Ohio. TILLER controlled a bank account at Bank 6, ending in 6061.

25. Bank 7 was a financial institution based in Cincinnati, Ohio, with bank branches
in Tennessee. DAVIS controlled bank accounts at Bank 7, including an account ending in 4313.

26. Bank Processor | was a third-party company processor, based in Redwood City,
California, that processed PPP loan applications for Bank 1 and Bank 2.

COUNT 1
(Conspiracy to Commit Wire Fraud, 18 U.S.C. § 1349)

The Grand Jury charges:
27. The factual allegations of paragraphs 1 through 26 of this Indictment are re-
alleged and incorporated by reference as if fully set forth herein.

The Conspiracy

28. From on or about March 31, 2020, through on or about December 17, 2020, in the
Northern District of Ohio, Eastern Division, and elsewhere, Defendants TERRENCE L.
POUNDS, CHARLES B. TILLER, UI, TERRI DAVIS, RANDOLPH NUNN, SAMIRA
ABDUL-KARIM, QUWAN SIMMONS, and others known and unknown to the Grand Jury, did
knowingly and intentionally combine, conspire, confederate and agree to devise a scheme and
artifice to defraud and to obtain money and property from the United States Small Business
Administration, and from financial institutions, including Bank 1 and Bank 2, by means of false
and fraudulent pretenses, representations and promises; and for the purpose of executing the

scheme and artifice, transmitted and caused to be transmitted by means of wire communications
Case: 5:21-cr-00317-PAB Doc #: 1 Filed: 04/29/21 6 of 19. PagelD #: 6

in interstate commerce writings, signs, signals, pictures and sounds, in violation of Title 18,
United States Code, Section 1343.

Objects of the Conspiracy

29. The objects of the conspiracy were for the conspirators to unjustly enrich
themselves by obtaining EIDL and PPP loan proceeds under false pretenses, and to prevent
detection of the conspiracy.

Manner and Means of the Conspiracy

30. It was part of the conspiracy that:

a. POUNDS recruited TILLER, DAVIS, NUNN, ABDUL-KARIM,
SIMMONS, and others known and unknown to the Grand Jury, to obtain COVID-19 relief loans
under false pretenses.

b. TILLER, DAVIS, NUNN, ABDUL-KARIM and SIMMONS provided
POUNDS, directly and through others, their personal identifying information, which POUNDS
used to apply for EIDL loans in their names.

c. In exchange for providing POUNDS with their personal identifying
information, TILLER, DAVIS, NUNN, ABDUL-KARIM and SIMMONS paid POUNDS a
portion of the fraudulent loan proceeds that they received.

d. POUNDS created email accounts and used them to submit fraudulent
EIDL loan applications to the SBA in the names of TILLER, DAVIS, NUNN, ABDUL-KARIM
and SIMMONS.

e. POUNDS falsely claimed in the EIDL loan applications that TILLER,

DAVIS, NUNN, ABDUL-KARIM and SIMMONS each operated a non-profit organization that
Case: 5:21-cr-00317-PAB Doc #: 1 Filed: 04/29/21 7 of 19. PagelD #: 7

was a “Faith Based Organization” and “Church” with $1,000,000 in revenue, 15 employees, had
goods that cost between $300,000 and $301,123, and was formed on January 1, 2019.

f. Based on the false information that POUNDS submitted to the SBA, it
approved TILLER’S, DAVIS’, NUNN’S, ABDUL-KARIM’S and SIMMONS’ EIDL loan
applications. The loan proceeds were transmitted from the SBA to bank accounts that TILLER,
DAVIS, NUNN, ABDUL-KARIM and SIMMONS controlled. TILLER, DAVIS, NUNN,
ABDUL-KARIM and SIMMONS then provided portions of the loan proceeds to POUNDS,
directly and through others.

g. TILLER, DAVIS, NUNN, ABDUL-KARIM and SIMMONS used EIDL
loan proceeds for the benefit of themselves and others, and in a manner that was inconsistent
with the purposes of the EIDL program.

h. POUNDS submitted and caused to be submitted a false and fraudulent
EIDL loan application to the SBA in the name of a religious services entity that he purported to
operate. When the SBA approved the application and paid the loan, POUNDS used the loan
funds for purposes inconsistent with those of the EIDL program, including to purchase motor
vehicles.

i. POUNDS and TILLER submitted and caused to be submitted PPP loan
applications in the names of others that contained fraudulent supporting documentation,
including fraudulent Schedule C tax records.

Acts in Furtherance of the Conspiracy

31. In furtherance of the conspiracy and to achieve its objectives, one or more
members of the conspiracy committed the following acts, among others, in the Northern District

of Ohio, Eastern Division, and elsewhere:
Case: 5:21-cr-00317-PAB Doc #:1 Filed: 04/29/21 8 of 19. PagelD #: 8

POUNDS electronically submitted an EIDL loan application, in the name

of NUNN, using the SBA online portal, as set forth below:

Act in Approximate | Description of Originating | Recipient and
Furtherance | Date Transaction Location Location
i. July 19,2020 | Submission of EIDL loan | Florida SBA, Iowa
application in the name
of NUNN
b. POUNDS, together with NUNN, caused the SBA to disburse an EIDL

loan to NUNN, as set forth below:

Act in Approximate | Description of Originating | Recipient
Furtherance | Date Transaction Location and
Location
i. July 21,2020 | Bank transfer from the Colorado NUNN,
SBA of approximately Ohio
$149,800

NUNN, after receiving the EIDL loan described in the preceding

paragraph, wired $30,000 of the loan proceeds to POUNDS and transferred a total of $65,000 of

the funds from a personal bank account in the name of NUNN to a personal bank account at

Bank 3 held in the name of NUNN’s family member, Person 1, as set forth below:

1, ending 4219
Case: 5:21-cr-00317-PAB Doc #: 1 Filed: 04/29/21 9 of 19. PagelD #: 9

of DAVIS, using the SBA online portal, as set forth below:

POUNDS electronically submitted an EIDL loan application, in the name

Act in Approx. Date | Description of Originating | Recipient and
Furtherance Transaction Location Location
i. July 22,2020 | Submission of EIDL loan | Florida SBA, Iowa
application in the name
of DAVIS

loan to DAVIS as set forth below:

POUNDS, together with DAVIS, caused the SBA to disburse an EIDL

Act in Approximate Description of Originating Recipient
Furtherance | Date Transaction Location and
Location
i. July 24, 2020 Bank transfer from | Colorado DAVIS,
the SBA of Tennessee
approximately
$149,700

DAVIS, after receiving the EIDL loan described in the preceding

paragraph, wired $15,000 of the loan proceeds to POUNDS, as set forth below:

Act in Approximate Description of Originating Recipient
Furtherance | Date Transaction Location and
Location
i. August 21, 2020 | Bank wire from Tennessee POUNDS,
DAVIS of Ohio
approximately
$15,000

of ABDUL-KARIM, using the SBA online portal, as set forth below:

POUNDS electronically submitted an EIDL loan application, in the name

July 15, 2020

application in the name
of ABDUL-KARIM

Act in Approx. Date | Description of Originating | Recipient and
Furtherance Transaction Location Location
i. Submission of EIDL loan | Ohio SBA, Iowa
Case: 5:21-cr-00317-PAB Doc #:1 Filed: 04/29/21 10 of 19. PagelD #: 10

h. POUNDS, together with ABDUL-KARIM, caused the SBA to disburse an

EIDL loan to ABDUL-KARIM, as set forth below:

Act in - Approximate Description of Originating Recipient
Furtherance | Date Transaction Location and
Location
i. July 21, 2020 Bank transfer from | Colorado ABDUL-
the SBA of KARIM,
approximately . Connecticut
$149,600

i. ABDUL-KARIM used proceeds from the EIDL loan described in the

preceding paragraph to conduct the following financial transactions, among others:

Act in Approximate | Description of Financial Institution
Furtherance | Date Transaction and Account
i. July 22, 2020 | $50,000 debited by | Bank 4, transaction
cashier check debited from account
ending 4156
il. August 31, Purchase at Bank 4, transaction
2020 Mohegan Sun debited from account
Connecticut $217.35 | ending 4156
iil. September 1, | ATM withdrawal at | Bank 4, transaction
2020 Mohegan Sun debited from account
Connecticut ending 4156
$505.95
j. POUNDS electronically submitted an EIDL loan application in the name

of SIMMONS, using the SBA online portal, as set forth below:

Act in Approx. Date | Description of Originating | Recipient and
Furtherance Transaction Location Location
1. July 15,2020 | Submission of EIDL loan | Ohio SBA, Iowa
application in the name
of SIMMONS

k. POUNDS, together with SIMMONS, caused the SBA to disburse an EIDL

loan to SIMMONS, as set forth below:

10
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Act in Approximate Description of Originating Recipient
Furtherance | Date Transaction — Location and
Location
i. July 21, 2020 Bank transfer from | Colorado SIMMONS,
the SBA of Connecticut
approximately

SIMMONS used proceeds from the EIDL loan described in the preceding

paragraph to carry out the following financial transactions, among others:

Act in Approximate Description of | Financial Institution and

Furtherance | Date Transaction Account

i. July 23, 2020 EWithrawal, Bank 5, transaction debited
$30,000 from account.ending 2622

il. July 30, 2020 © Purchase at Bank 5, transaction debited
Hannoush from account ending 2622
Jewelers,
$957.15

ill. July 31, 2020 Purchase at Bank 5, transaction debited
Louis Vuitton, | from account ending 2622
$627.47

iv. August 10, 2020 | Purchase at Bank 5, transaction debited
Liquor Outlet, | from account ending 2622

| $233.95

Vv. October 13, 2020 | Purchase at Bank 5, transaction debited
Gamestop, from account ending 2622
$117.00

m. | POUNDS electronically submitted an EIDL loan application, in the name

of TILLER, using the SBA online portal, as set forth below:

Act in Approx. Date | Description of Originating | Recipient and
Furtherance Transaction Location Location
i. July 15,2020 | Submission of EIDL loan | Ohio SBA, Iowa
application in the name.
of TILLER

n. POUNDS, together with TILLER, caused the SBA to disburse an EIDL

loan to TILLER, as set forth below:

11
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.Act in Approximate Description of Originating Recipient
Furtherance | Date Transaction Location and
Location
i. July 21, 2020 Bank transfer from | Colorado TILLER,
the SBA of Ohio
approximately
$149,700 |

oO. TILLER, after receiving the EIDL loan described in the preceding:

paragraph, wired $19,000 of the proceeds to POUNDS, as set forth below:

Act in Approximate Description of Orivinati Recipient
Furtherance | Date Transaction mgmanns | and
Location .
Location
i. July 31, 2020 Bank wire from Ohio POUNDS,
TILLER of Ohio
approximately
$19,000

p. On or about May 2, 2020, POUNDS emailed TILLER a fraudulent
Schedule C tax document in the name of TERRI DAVIS for the year 2019, falsely purporting to
demonstrate that DAVIS operated a business that earned $99,500 by providing consulting work
for ‘CBD4Real,’ a business that POUNDS owned and operated in Toledo, Ohio.
| q. TILLER caused to be submitted a loan application in the name of DAVIS,
to Bank Processor 1, seeking a PPP loan from Bank 1 and Bank 2, and which contained false
information, including the fraudulent Schedule C tax document described in the preceding

paragraph, as set forth below:

Act in Approximate Date Description of Transaction

Furtherance

i. May 5, 2020 Submission of PPP loan
application in the name of
DAVIS

r. On or about March 31, 2020, POUNDS electronically submitted and

caused to be submitted to the SBA an EJDL loan application for “Truth Ministries Global Inc.,” a

12
Case: 5:21-cr-00317-PAB Doc #:1 Filed: 04/29/21 13 of 19. PagelD #: 13

purported “Faith Based Organization” and “Church” that POUNDS claimed to operate. In the
loan application, POUNDS claimed, “We feed the less fortunate and underprivileged, we visit
the prisons, we have 24 hours per day and 7 days per week phone line open for prayers and
counseling. We have church services twice per week.”

S. On or about May 22, 2020, the SBA, in response to the application
described in the preceding paragraph, funded an EIDL loan for Truth Ministries Global Inc. in
the amount of $147,900, which POUNDS received from the SBA into an account at Bank 5 that
he controlled, ending in 9652. POUNDS then used portions of these loan proceeds to purchase
and cause to be purchased the following motor vehicles: a 2021 Chevrolet Tahoe, VIN
IGNSKPKD2MR102954; a 2021 Kia Telluride, VIN 5X YPSDHC3MG1 18064; and a 2020
Hyundai Elantra, VIN KMHD84LF6LU024572.

t. On or about August 15, 2020, POUNDS purchased a 2020 BMW X4, VIN
5 YMUJOC09L9B57885, using portions of EIDL loans that he received from others in return for
fraudulently obtaining from the SBA the loans in the names of, and for, these individuals.

32. As a result of the conspiracy described above, POUNDS, TILLER, DAVIS,
NUNN, ABDUL-KARIM and SIMMONS, together with others, submitted and caused to be
submitted fraudulent PPP loan applications, and at least 60 fraudulent EIDL loan applications,
seeking a total of approximately $9 million in PPP and EIDL loan proceeds, and the SBA
approved approximately $3.3 million in loan funds.

All in violation of Title 18, United States Code, Section 1349.

13
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COUNTS 2-10
(Wire Fraud, 18 U.S.C. § 1343)

The Grand Jury further charges:
33. The factual allegations of paragraphs 1 through 14 and paragraphs 21 through 25
of this Indictment are re-alleged and incorporated by reference as if fully set forth herein.

The Fraudulent Scheme

34. From on or about March 31, 2020, through on or about December 17, 2020, in the
Northern District of Ohio, Eastern Division, and elsewhere, Defendants TERRENCE L.
POUNDS, CHARLES B. TILLER, II, TERRI DAVIS, RANDOLPH NUNN, SAMIRA
ABDUL-KARIM and QUWAN SIMMONS knowingly devised, and intended to devise, a
scheme and artifice to defraud the United States Small Business Administration, and to obtain
money and property by means of materially false and fraudulent pretenses, representations, and
promises, by submitting and causing to be submitted false and fraudulent applications for EIDL
funds.

Manner and Means of the Scheme to Defraud

35. To accomplish these objectives, POUNDS, TILLER, DAVIS, NUNN, ABDUL-
KARIM and SIMMONS employed the manner and means described in paragraph 30(a)-(h) of
this Indictment, which are re-alleged and incorporated by reference as if fully set forth herein.

Execution of the Scheme

36. On or about each of the dates set forth below, in the Northern District of Ohio,
Eastern Division, and elsewhere, Defendants TERRENCE L. POUNDS, CHARLES B. TILLER,
II, TERRI DAVIS, RANDOLPH NUNN, SAMIRA ABDUL-KARIM and QUWAN
SIMMONS, for the purpose of executing the scheme and artifice to defraud described above, and

attempting to do so, transmitted, and caused to be transmitted, writings, signs, signals, pictures

14
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and sounds by means of wire communications in interstate commerce, as described below, each

transmission constituting a separate count of this Indictment:

2 May 22, 2020 | Bank transfer Colorado TERRENCE | TERRENCE
from the SBA of L. POUNDS, | L. POUNDS
$147,900 for Ohio
EIDL loan in the
name of Truth
Ministries Global
Inc.

3 July 12,2020 | Electronic Ohio SBA, Iowa TERRENCE
submission of L. POUNDS
EIDL loan

application in the
name of Person 2

4 July 15, 2020 | Electronic Ohio SBA, Iowa TERRENCE
submission of L. POUNDS
EIDL loan

application in the
name of Person 3

5 July 15,2020 | Electronic Ohio SBA, Iowa TERRENCE
submission of L. POUNDS /
EIDL loan SAMIRA
application in the ABDUL-
name of KARIM
SAMIRA
ABDUL-
KARIM

6 July 15, 2020 | Electronic Ohio SBA, Iowa TERRENCE
submission of L. POUNDS /
EIDL loan QUWAN
application in the SIMMONS
name of
QUWAN
SIMMONS

7 July 21,2020 | Bank transfer Colorado RANDOLPH | TERRENCE
from the SBA of NUNN, Ohio | L. POUNDS /
$149,800 for . RANDOLPH
EIDL loan in the NUNN
name of
RANDOLPH
NUNN

15
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Count | Approximate | Description of Originating | Recipient Defendants
Date Transmission Location and Location
8 July 21, 2020 | Bank transfer Colorado CHARLES CHARLES B.
from the SBA of B. TILLER TILLER, III /
$149,700 for III, Ohio _TERRENCE
EIDL loan in the L. POUNDS
name of
CHARLES B.
TILLER, III
9 July 24, 2020 | Bank transfer ~ | Colorado Person 4, TERRENCE
from the SBA of Ohio L. POUNDS
$149,800 for
EIDL loan in the
name of Person 4
10 | August 21, Bank wire from | Tennessee | TERRENCE | TERRENCE
2020 Terri Davis of L. POUNDS, | L. POUNDS /
approximately Ohio TERRI
$15,000 DAVIS

All in violation of Title 18, United State Code, Section 1343.

COUNTS 11-12
(Engaging in a Monetary Transaction
in Property Derived from Criminal Activity, 18 U.S.C. §§ 1957 and 2)

The Grand Jury further charges:

37. The factual allegations of paragraphs | through 26 and paragraph 30(a)-(i) of this
Indictment are realleged and incorporated by reference as if fully set forth herein.

38. On or about the dates set forth below, in the Northern District of Ohio, Eastern
Division, and elsewhere, Defendants TERRENCE L. POUNDS and RANDOLPH NUNN, aiding
and abetting each other, did knowingly engage in and attempt to engage in the following
financial transactions by, through, and to a financial institution, affecting interstate commerce, in
criminally derived property of a value greater than $10,000, such property having been derived
from specified unlawful activity, that is, Conspiracy to Commit Wire Fraud, in violation of Title

18, United States Code, Section 1349, as alleged in Count 1 of this Indictment, and Wire Fraud,

16
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in violation of Title 18, United States Code, Section 1343, as alleged in Count 7 of this

Indictment, each transaction constituting a separate count of this Indictment:

All in violation of Title 18, United States Code, Sections 1957 and 2.

COUNT 13

(Engaging in a Monetary Transaction
in Property Derived from Criminal Activity, 18 U.S.C. §§ 1957 and 2)

The Grand Jury further charges:

39.

The factual allegations of paragraphs 1 through 26, and paragraph 30(a)-(i) of this

Indictment are realleged and incorporated by reference as if fully set forth herein.

40.

elsewhere, Defendants TERRI DAVIS and TERRENCE L. POUNDS, aiding and abetting each

On or about the date set forth below, in the Northern District of Ohio and

other, did knowingly engage in and attempt to engage in the following financial transaction by,

through, and to a financial institution, affecting interstate commerce, in criminally derived

property of a value greater than $10,000, such property having been derived from specified

unlawful activity, that is, Conspiracy to Commit Wire Fraud, in violation of Title 18, United

17
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States Code, Section 1349, as alleged in Count.1 of this Indictment, and Wire Fraud in violation

of Title 18, United States Code, Section 1343, as alleged in Count 10 of this Indictment:

controlled by
DAVIS
ending 4313,
wire transfer

‘In violation of Title 18, United States Code, Sections 1957 and 2.
COUNT 14
(Engaging in a Monetary Transaction
in Property Derived from Criminal Activity, 18 U.S.C. §§ 1957 and 2)
The Grand Jury further charges:
41. The factual allegations of paragraphs 1 through 26, and paragraph 30(a)-(i) of this
Indictment are realleged and incorporated by reference as if fully set forth herein.

42. On or about the date set forth below, in the Northern District of Ohio and
elsewhere, Defendants CHARLES B. TILLER, III and TERRENCE L. POUNDS, aiding and
abetting each other, did knowingly engage in and attempt to engage in the following financial
transaction by, through, and to a financial institution, affecting interstate commerce, in criminally
derived property of a value greater than $10,000, such property having been derived from
specified unlawful activity, that is, Conspiracy to Commit Wire Fraud, in violation of Title 18,

United States Code, Section 1349, as alleged in Count | of this Indictment, and Wire Fraud, in

violation of Title 18, United States Code, Section 1343, as alleged in Count 8 of this Indictment:

18
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Count | Date Approx. | Originating Financial Financial Institution and
Amount | Institution, Account, and | Account of Deposit (Located
Nature of Transaction in Northern District of Ohio)
14 July 31, | $19,000 | Bank 6, account Bank 5, account controlled by
2020 controlled by TILLER POUNDS ending 8356
ending 6061, wire transfer

In violation of Title 18, United States Code, Sections 1957 and 2.
FORFEITURE
The Grand Jury further charges:

43. The allegations of Counts | through 14 are hereby realleged and incorporated
herein by reference for the purpose of alleging forfeiture pursuant to Title 18, United States
Code, Sections 981(a)(1)(C) and 982(a)(1); and Title 28, United States Code, Section 2461(c).
As a result of the foregoing offenses, Defendants TERRENCE L. POUNDS, CHARLES B.
TILLER, I, TERRI DAVIS, RANDOLPH NUNN, SAMIRA ABDUL-KARIM, and QUWAN
SIMMONS, shall forfeit to the United States all property, real and personal, which constitutes or
is derived from proceeds traceable to the commission of the offenses charged herein; and any
and all property, real or personal, involved in the offenses charged herein, or any property
traceable to such property; including, but not limited to, the following:

a. 2020 BMW X4, VIN 5YMUJOC09L9B57885;

b. 2021 Chevrolet Tahoe, VIN 1GNSKPKD2MR102954;

Cc. 2021 Kia Telluride, VIN 5X YP5DHC3MGI1 18064; and,

d. 2020 Hyundai Elantra, VIN KMHD84LF6LU024572.

A TRUE BILL.
Original document - Signatures on file with the Clerk of Courts, pursuant to the E-Government

Act of 2002.

File and source

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Our copy: 1-indictment.pdf
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