Indictment — United States v. Tequisha Solomon, District of Minnesota (Doc. 1)

Summary

Indictment filed June 30, 2022 as Doc. 1 in United States of America v. Tequisha Solomon, Case 0:22-cr-00131-ECT-DTS, U.S. District Court for the District of Minnesota. The grand jury charges that from at least in or about June 2020 through in or about January 2022 the defendant engaged in a fraud scheme to obtain pandemic-related unemployment benefits and small business loans, which the indictment alleges resulted in the payment of at least approximately $4.2 million in fraud proceeds. The indictment alleges that the defendant filed fraudulent unemployment claims with California's Employment Development Department, the Illinois Department of Employment Security and Minnesota's Department of Employment and Economic Development, and applied for EIDL and PPP loans using false payroll information and tax records.

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“Indictment — United States v. Tequisha Solomon, District of Minnesota (Doc. 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-0-22-cr-00131-dkt-1-d-minn-5830b9e837/, SHA-256 e49f0771964f0dc6287a6c7ef246372abbf7c60a0ea6af25f98c01e6e2be9bee.

Full text

CASE 0:22-cr-00131-ECT-DTS Doc. 1 Filed 06/30/22 Page 1 of 12

cR s"r -,3 Ecrlbtl
UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA

UNITED STATES OF AMERICA, )
) INDICTMENT
Plaintiff, )
) 18 U.S.C. S 1343
v.) 18 U.S.c. S e81(a)(1)(C)
) 28 U.S.C. $ 2a61(c)
TEQUISIIA SOLOMON, )
)
Defendant. )

The UMTED STATES GRAND JURY charges:

General Allegations

At times material to this Indictment:

The Defendant

1. Defendant TEQUISIIA SOLOMON was a resident of Woodbury and

South Saint Paul, in the State and District of Minnesota, as well as a /esident of Las

Vegas and. North Las Vegas in the State of Nevada.

2. From at least in or about June 2Ot2lthrough in or about January 2022,

defendant SOLOMON capitalized on the COVID-19 pand.emic to exploit emergency

funding for needy, eligible unemployed workers and small businesses by engaging in

a fraud scheme to obtain and spend benefits and loan proceeds that defendant

SOLOMON knew that she, and others, were not entitled to receive. Defendant

SOLOMON used false and fraudulent pretenses, representations, promises, and

concealment of material facts to apply for pand,emic-related unemployment benefits

and small business loans for herself and others, which resulted in the payment of at

Ieast approximately $4.2 million in fraud proceeds. SCANNED
JUN 3 020?2
U.S. DISTRICT COURT ST, PAUL
CASE 0:22-cr-00131-ECT-DTS Doc. 1 Filed 06/30/22 Page 2 of 12

P an demic-Rel ate d Unemp loyment B enefits

3. The Social Security Act of 1935 initiated the federal and state
unemployment ('UI") system, which provided benefi.ts to individuals who were

unemployed for reasons beyond their control. The UI system's purpose was to lessen

the effects of unemployment through cash payments made directly to laid-off workers,

and to ensure that life necessities were met on a weekly basis while the workers seek

employment. The UI system was administered through the states' respective

workforce agencies, such as California's Employment Development Department

(*EDD'), Minnesota's Department of Employment and Economic Development

("DEED"), and similar agencies in other states.

4. Beginning in or about March 2020 and continuing through in or about

Septembe r 202L, the /fed,eral government provided. significant supplemental UI
benefits that flowed to and through the states to offset the historic need for

unemployment benefi.ts by the American workforce due to the COVID-l9 pandemic.

Through such legislation as the Coronavirus Aid., Retief, and Economic Security Act

('CARES Act") enacted in March 2020, the Consolidated Appropriations Act 202I,

and the American Rescue Plan enacted in March 2021, the federal government

extended and expanded these UI programs in a number of ways, including by:

lengthening the eligibility period for UI benefits; increasing the amount of UI benefi.ts

individuals could, receive; and extending UI to workers impacted by the COVID-l9

pandemic who were not ordinarily eligible for unemployment benefits.
CASE 0:22-cr-00131-ECT-DTS Doc. 1 Filed 06/30/22 Page 3 of 12

5. UI funds through these pandemic-related programs were received by

state workforce agencies, such as California's EDD and Minnesota's DEED, from the

United States Department of Treasury through a prograrn known as the Automated

Standard Application for Payments, which was an electronic system that federal

agencies used to transfer funds to recipient organizations.

6. UI claimants were required to answer certain questions to establish
their eligibility for UI benefi.ts and to certifii that they met one of the COVID-l9

related reasons for being unemployed, partially unemployed, or unable or unavailable

to work. Although various states' UI applications had their own format and content,

they nonetheless generally required. that the applicants certifii certain information,

such as, that the applicants provided true and accurate information, that the

applicants were eligible to receive UI from a certain state, and that the applicants

had not previously applied for UI from a different state. The state workforce agencies

relied upon the information provided. by UI claimants in determining eligibility for

UI benefits.

7. One way in which some states provided UI benefits to claimants, such

as California's EDD, was through the use of Bank of America-issued. debit cards that

were mailed through the U.S. Postal Service to claimants at the ad.dresses provided

in the UI claims. 4ft.r claimants received. their Bank of America debit cards, they

could activate it online or over the phone and could use the card to withdraw cash

and pay expenses. Alternatively, claimants could provide the state agency with a
CASE 0:22-cr-00131-ECT-DTS Doc. 1 Filed 06/30/22 Page 4 of 12

bank routing number and bank account, and unemployment benefits were directly

d.eposited to that account.

8. If a state workforce agency approved a UI claim, claimants were
required to certifr every two weeks via telephone or Internet, under penalty of

perjury, that they remained unemployed and eligible to receive UI benefits. Upon

receipt of that periodic certifi.cation, then the state workforce agency authorized and

deposited payment to the claimants' debit cards, which, for California's EDD, melant

Bank of America debit cards. or to their bank.account.

Pandemic-Related Loans to Small Businesses

9. The United States Small Business Administration ('SBA") was an

executive-branch agency of the United States government that provided support to

entrepreneurs and sma$ businesses. The mission of the SBA was to maintain and

Strengthen the nation's economy by enabling the establishment and viability of small

businesses and by assisting in the economic recovery of communities after d.isasters.

As part of this effort, the SBA enabled. and provided for loans through banks, credit

unions, and other lenders. These loans had government-backed guarantees.

10. An additional source of funding authorized by the CARES Act,. and
subsequently, by the American Rescue Plan Act of 202L, was the authorization of

forgivable loahs to small businesses for job retention and certain other expenses,

which included a program referred to as the Paycheck Protection Program ("PPP").

To obtain a PPP loan, a quali$ring business was required to submit a PPP loan

application, which was signed by an authorized representative of the business. The

4
CASE 0:22-cr-00131-ECT-DTS Doc. 1 Filed 06/30/22 Page 5 of 12

PPP loan application required the business (through its authorized representative)

to acknowledge the program rules and make certain affi.rmative certifications in ord.er

to be eligible to obtainthe PPP loan. In the PPP loan application, the small business

(through its authorized, representative) was required. to certify, among other things,

average monthly payroll expenses, which was used, to calculate the amount of money

the small business was eligible to receive under the PPP. In addition, businesses

applying for a PPP loan were required to provide documentation, such as a tax returni

showing their payroll expenses.

11. A PPP loan application was processed by a participating lender. If a
PPP loan application was approved, the participating lender funded the PPP loan

using its own monies, which were guaranteed by the SBA. PPP loan proceeds were

required to be used. on certain permissible expenses, includ,ing payroll costs, mortgage

interest, rent, and utilities.

12. In addition, the SBA provided. direct loans to applicants through the
Economic Injury Disaster Loan (EIDL) program, which was also funded by such

legislation as the CARES Act to help small businesses facing financial difficulties

during the COVID-l9 pandemic. EIDL funds were offered in low-interest rate loans,

designated for specific business expenses, such as fixed debts, payroll, and business

obligations. Eligible EIDL applicants must have suffered. "substantial economic

injury'' from COVID-19 based. on a company's actual economic injury determined by

the SBA.

5
CASE 0:22-cr-00131-ECT-DTS Doc. 1 Filed 06/30/22 Page 6 of 12

13. To qualifir for an EIDL loan, applicants were required to submit
applications to the SBA, generally through the SBA s website, wherein the applicant

provided information including the business's: name, EIN (or social security number

for sole proprietorships), gross revenues and cost ofgoods for the prior year, address,

email, date of establishment, number of employees, and bank account information.

Appticants were required. to certifi, under penalty of perjury that the information

provided in the EIDL application was true and correct.

o**o*,
"o*or*r
74. From at least June 2020 through at least in or around January 2022,tn
the District of Minnesota, and elsewhere, the defend.ant,

TEQUISHA SOLOMON,

did knowingly and intentionally devise and execute a scheme and artifice to defraud

and to obtain money by means of materially false and fraud.ulent pretenses,

representations, and promises, and by concealment of material facts.

15. The purpose of the scheme and artifi.ce to defraud was to obtain money
and property from states, such as California's EDD and Minnesota's DEED, among

others, as well as from the United States, in the form of UI benefi.ts and small

business loans by submitting fraudulent claims and applications.

16. As part of her scheme to d.efraud, defendant SOLOMON filed fraudulent
claims seeking UI benefits from states where she had no lawful basis to receive UI

benefi.ts because, in fact, she neither resided. nor worked in those.states. For example,

while defendant SOLOMON resided in Minnesota and Nevada, she caused, the
CASE 0:22-cr-00131-ECT-DTS Doc. 1 Filed 06/30/22 Page 7 of 12

fraud.ulent submission of claims to California's EDD, in which she falsely claimed,

among other things, that she resided at an add.ress in Los Angeles, California, and

that she previously earned income as a "hairstylist" in California, all of which
defendant SOLOMON knew was false. As a result of defendant SOLOMON's false

and fraud.ulent claims, California's EDD paid defendant SOLOMON at least $37,000

in periodic UI payments between approximately JuIy 2020 and April 202L, d.uring

which time SOLOMON actually resided in either Minnesota or Nevada.

. 17. It was further part of defendant SOLOMON's scheme that she
unlawfully "d,ouble-dipped'by obtaining fraudulent UI benefits from multiple states

simultaneously. For instance, in or about October 2020, defendant SOLOMON

caused the submission of a fraudulent claim for UI to the Illinqis Department of

Employment Security at which time she was actually residing in Minnesota and was

already fraudulently receiving UI benefits from California's EDD, all of which

defendant SOLOMON concealed. In"her fraudulent claims to Illinois, d,efendant

SOLOMON falsely claimed she was entitled to UI because she had purportedly been

self-employed while living at a residence in Chicago. As a result of defendant

SOLOMON's false and fraudulent claims, the Illinois Department of Employment

Security paid defendant SOLOMON approximately $25,000 in periodic UI payments

between approximately Novembe r 2020and Febru ary 202L. In addition, in or about

March 2021, defendant SOLOMON fraudulently applied for UI from Minnesota's

DEED, and concealed. her fraudulent receipt of UI benefi.ts from California and

Illinois. As a result of defendant SOLOMON's false and fraudulent claims,
CASE 0:22-cr-00131-ECT-DTS Doc. 1 Filed 06/30/22 Page 8 of 12

Minnesota's DEED paid defendant SOLOMON approximately $18,000 in periodic UI

payments between approximately March 2021and September 202L.

18. It was further part. of defendant SOLOMON's scheme that she also
fraudulently applied for EIDL and PPP small business loans that were based, among

other falsehood.s, upon fake payroll information and bogus tax records to deceive

lenders. For instance, defendant SOLOMON applied for a $70,000 EIDL in or about

June 2020, in which she falsely claimed,. among other things, that she owned a

supposed cleaning service that had gross revenues of approximately $67,000 in

Nevada. In addition, defendant SOLOMON submitted fraudulent PPP loans in

March 2O2I and April 202'l-, both of which were based upon fraudulent
misrepresentations. More specifically, defendant SOLOMON falsely claimed in her

202I PPP loan applications that she was the sole proprietor of a business established,

in January 2019 with average monthly payroll of $8,333. Defendant SOLOMON
supported her fraudulent PPP applications with bogus tax records, namely, IRS

Schedule C tax forms for tax year 2020, in which she falsely purported to be a

"Business Consultant" with gross receipts or sales of approximately $108,550. As a

result of defend.ant SOLOMON's false and fraudulent claims for small business loans,

the PPP paid her approximately $41,666 in loan proceeds throughout March and

April 202t.
19. In ad,dition to fraudulently obtaining pandemic-related benefi.ts for
herself, it was further part of defendant SOLOMON's scheme that she tfraudulently

obtained pandemic-related funds for others in exchange for a fee in an amount that
CASE 0:22-cr-00131-ECT-DTS Doc. 1 Filed 06/30/22 Page 9 of 12

varied but that was at times approximately $2,000. More specifi.ca1ly, defendant

SOLOMON submitted on behalf of others at least 200 false and fraudulent

applications for UI benefits.

20. The various fraudulent UI applications that defend.ant SOLOMON
submitted in the names of other claimants contained false and fraudulent

representations, including that the claimants had worked for particular employers,

had specific annual incomes, worked during particular time periods; worked in

particular states, were self-employed in various occupations, or were laid off and had

no work due to the COVID-19 pandemic but were otherwise available to work.

Defendant SOLOMON knew that these claims were false. Defend.ant SOLOMON

urcf knew that these applications regarding the claimants' employment and
availability to work were false at the time they were made. For example, in at least

one instance, defendant SOLOMON caused the submission of a fraudulent UI claim

to California's EDD in or about July 2020 in thii name of Individual A, whom
defendant SOLOMON knew was not entitled to received UI from any state because,

among other things, Individual A was an inmate incarcerated at a Minnesota prison

at the time.

21. As a direct result of defendant SOLOMON's material falsehoods and
omissions, defendant SOLOMON caused the United" States and multiple state

agencies to pay out at least $4.1 million in fraudulent UI benefits and small business
j

loan proceeds to herself and others.

I
CASE 0:22-cr-00131-ECT-DTS Doc. 1 Filed 06/30/22 Page 10 of 12

22. Thereafier, as part of her scheme to defraud, defendant SOLOMON
received proceeds, either in the form of the fee that she charged. others for submitting

fraudulent claims on their behalf or in the form of UI benefits andloan proceeds that

defend.ant SOLOMON fraudulently obtained for herself. Defendant SOLOMON

maintained these frauduleni pro.""ds in either cash or in bank accounts that she

controlled. Defendant SOLOMON used these fraudulent funds to benefit herself and

others, which included such purchases ur'follo*.'

(a) on orAugust 20,2020, defendant SOLOMONpurchased a 2017 Land

Rover Range Rover Evoque vehicle for approximately $43,778.50 (the "20L7 Evoque");

@) on or about April 27,2021, d.efendant SOLOMON purchased. a 2OI8

Land Rover Velar ("2018 Velar") for approximately $65,371.30 funded, in part, by her

trad.e-in of the 2lll Evoque; and

20tG Jaguar Sed.an, bearing VIN: SAJBD4BV5GCY21649 and temporary Nevada

Iicense plate number NX-672-282 for approximately $26,391.55 funded by her trade-

in of the 2018 Velar. a transaction which also resulted in defendant SOLOMON
{- receiving a payment back from the car dealer of $25,000.

COUNTS 1-6
(Wire Fraud)

23. Paragraphs 1 through 22 are incorporated by reference as if fully set
forth herein.

10
CASE 0:22-cr-00131-ECT-DTS Doc. 1 Filed 06/30/22 Page 11 of 12

24. On or about the dates set forth below, in the State and District of
Minnesota and elsewhere, the defendant,

TEQUISHA SOLOMON,

for the purpose of executing and attempting to execute the above-described scheme

and artifi.ce to defraud, knowingly transmitted and caused to be transmitted by

means of wire communications in interstate and foreign commerce, certain writings,

signs, signals, and sounds, as described below:

Date of Wire Wire
Count (on or about)
1 June 24,2020 Electronic submission from Minnesota of an
application for an EIDL loan for defendant
SOLOMON, which was routed through servers
located outside of Minnesota.
2 July 16, 2020 Electronic submission from Minnesota by d.efendant
SOLOMON of a claim for UI benefi.ts to California's
EDD for Individual A, an incarcerated inmate at a
Minnesota prison facility, which was routed through
servers located outside of Minnesota.
3 August 17,2020 Electronic submission from Minnesota in the form of
a telephone call to Bank of America regarding
defendant SOLOMON's fraudulent .claim forUl
benefits from California's EDD.
4 October 19.2020 Electronic submission from Minnesota of a claim for
UI benefits to the Illinois Department of
Employment Security for defendant SOLOMON,
which was routed, through servers located outside of
Minnesota.
5 March 24,2027 Electronic submission from Minnesota concerning a
Iender's note issued in response to defendant
SOLOMON's fraudulent application for a PPP loan,
which was routed through servers located outside of
Minnesota.
6 August 3I,2021 Electronic submission from Nevada to Minnesota's
DEED of defendant SOLOMON's weekly
certifi.cation of entitlement to UI benefi,ts, which was
routed throush servers located outside of Minnesota.

11
CASE 0:22-cr-00131-ECT-DTS Doc. 1 Filed 06/30/22 Page 12 of 12

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

FORFEITURE ALLEGATIONS

25. -' Counts 1 through 6 of this Indictment are incorporated by reference for
the purpose.of alleging forfeiture pursuant to Title 18, United States Code, Section

981(a)(1)(C), in conjunction with Title 28, United States Code, Section zalIir,).

26. . Upon conviction of any of the offenses alleged in Counts 1- through 6, as
set forth in this Indictment, defendant shall forfeit to the United States of America

any property, real or personal, which constitutes or is derived. from proceeds traceable

to the violation, as provided in Title 18, United States Code, Section 9S1(a)(1)(C) and

Title 28, United States Cod.e, Section 2461(c),including but not limited to:

a. 20!6 Jaguar Sedan, bearing VIN:
SAJBD4BV5GCY21649 and temporary Nevada license
plate number NX-672-282; and

b. $25,000 in funds seized. from Comerica Bank account x9341
in the name of 'Auto Mall Automotive DBA Tobin Dodge
Ram."

27. If any of the above-described forfeitable property is unavailable for
forfeiture, the United States intends to seek the forfeiture of substitute property as

provided, for in Title 21, United States Code, Section 853(p), as incorporated by Title

28, United States Code, Section za6t@).

A TRUE BILL

UNITED STATES ATTORNEY FOREPERSON

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