Indictment — United States v. Lashawnda Alexander, Southern District of Ohio (Doc. 24)

Summary

An indictment in United States of America v. Lashawnda Alexander, Case 1:22-cr-00064-MWM, in the U.S. District Court for the Southern District of Ohio, Western Division, filed July 27, 2022 as Doc #: 24. Counts One to Three charge wire fraud under 18 U.S.C. §§ 1343 and 2 over EIDL submissions on or about 6/23/2020, 6/24/2020 and 6/25/2020. The grand jury alleges that Alexander falsely reported 10 employees and $125,000.00 in gross revenues for one application and 15 employees and $175,000.00 for TressD LLC. It alleges that Alexander attempted to obtain at least $137,500 and received approximately $91,000, consisting of one $71,000 EIDL and two $10,000 advances, spent in part on a Mercedes Benz Model GLE 350, flights and hotel rooms. The forfeiture allegation seeks a money judgment equal to at least $91,000.00.

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“Indictment — United States v. Lashawnda Alexander, Southern District of Ohio (Doc. 24).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-1-22-cr-00064-dkt-24-s-d-ohio-f4ce1a3eca/, SHA-256 7d767eff414a4ff8281b1bbe734cc890fc80894d63db4a728087e54f65b1f400.

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Case: 1:22-cr-00064-MWM Doc #: 24 Filed: 07/27/22 Page: 1 of 6 PAGEID #: 89

FILED
RICHARD W. NAGEL
CLERK OF COURT
UNITED STATES DISTRICT COURT 2022 JUL 27 PH 3: 40
SOUTHERN DISTRICT OF OHIO
WESTERN DIVISION U.S. DISTRICT COURT
SOUTHERN DIST OHIO
UNITED STATES OF AMERICA,

Plaintiff,
112
CASE NO. - - - - - - -
2{Ht COG6N4TI
v.
JUDGE J. McFARLAND
INDICTMENT
LASHAWNDA ALEXANDER,
18 U. S. C. § 1343
Defendant.
FORFEITURE ALLEGATION

THE GRAND JURY CHARGES:

At all times relevant to this Indictment:

INTRODUCTION

1. The defendant, LASHAWNDA ALEXANDER, was a Southern District of Ohio

resident who performed hair/beauty _and other professional services under the business names of

"Lashawnda Alexander" and "TressD LLC."

2. The United States Small Business Administration ("SBA") was an executive

branch agency of the United States government that provided support to entrepreneurs and small

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 disasters, including through facilitating loans to small businesses

directly or through participating lenders.

3. In or around March 2020, in response to the economic crisis caused by the

coronavirus pandemic, the United States Congress passed the Coronavirus Aid, Relief, and

Economic Security Act, Pub. L. No. 116-136, 134 Stat. 281 (2020) ("CARES Act"). Among other
Case: 1:22-cr-00064-MWM Doc #: 24 Filed: 07/27/22 Page: 2 of 6 PAGEID #: 90

things, the CARES Act expanded the Economic Injury Disaster Loan ("EIDL") program

administered by the SBA to provide economic relief to businesses that were experiencing a

temporary loss of revenue due to the coronavirus pandemic. The EIDL program provided loan

assistance, including advances up to $10,000, for eligible entities. EIDL proceeds could be used

to pay fixed debts, payroll, accounts payable and other bills that could have been paid had the

disaster not occurred; however, such proceeds were not intended to replace lost sales or profits or

to be used for expansion of a business or the purchase of fixed assets. Unlike certain other types

of SBA-guaranteed loans, EIDL proceeds were issued directly from the United States Treasury

and applicants applied through the SBA via an online portal and application.

4. The EIDL application process, which also used certain outside contractors for

system support, collected information concerning the business and the business owner, which were

used to determine loan eligibility and amounts, including information as to the gross revenues for

the business prior to January 31, 2020; the cost of goods sold; and the number of employees.

Applicants would electronically certify that the information provided was accurate and were

warned that any false statement or misrepresentation to the SBA or any misapplication of loan

proceeds could result in sanctions, including criminal penalties.

COUNTS ONE TO THREE
(Wire Fraud)

5. From at least June 2020 and continuing through at least August 2020, in the

Southern District of Ohio and elsewhere, the defendant, LASHAWNDA ALEXANDER, did

knowingly and willfully devise and intend to devise a scheme and artifice to defraud the SBA and

to obtain money and property by means of materially false and fraudulent pretenses and

representations, as set forth below.

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Case: 1:22-cr-00064-MWM Doc #: 24 Filed: 07/27/22 Page: 3 of 6 PAGEID #: 91

The Purpose of the Scheme to Defraud

6. The purpose of the scheme and artifice to defraud was for the defendant,

LASHAWNDA ALEXANDER, to obtain money and property from the SBA, namely EIDL

proceeds, by means of materially false and fraudulent statements and representations.

Manner and Means of the Scheme to Defraud

7. It was part of the scheme and artifice to defraud that the defendant, LASHAWNDA

ALEXANDER, submitted and caused to be submitted, by interstate wire transmission, false and

fraudulent applications for EIDLs made available through the SBA to provide relief for the

economic effects caused by the coronavirus pandemic.

8. On or about June 23, 2020, the defendant, LASHAWNDA ALEXANDER,

submitted and caused to be submitted, an EIDL application in the name of business "Lawshawnda

Alexander." In the application, the defendant, LASHAWNDA ALEXANDER, falsely

represented, among other things, that she had 10 employees and that her gross revenues for the 12

months prior to the disaster for the business were $125,000.00. As part of the application,

ALEXANDER requested an EIDL advance.

9. That same day, based on her false representations in the EIDL application, the SBA

deposited $10,000 in the form of an EIDL advance into ALEXANDER'S personal bank account.

The SBA later determined that the business "Lashawnda Alexander" did not meet eligibility

requirements and declined to further fund the requested loan.

10. On or about June 24, 2020, the defendant, LASHAWNDA ALEXANDER,

submitted and caused to be submitted, a separate application for an EIDL and advance for the

business "TressD LLC." In this application, the defendant, LASHAWNDA ALEXANDER,

falsely represented, among other things, that she had 15 employees and that her gross revenues for

3
Case: 1:22-cr-00064-MWM Doc #: 24 Filed: 07/27/22 Page: 4 of 6 PAGEID #: 92

the 12 months prior to the disaster for the business were $175,000.00. Based on her false

representations, the SBA deposited $10,000 in the form of an EIDL advance into a business bank

account held by ALEXANDER. Based on her false representations, the SBA additionally

approved the issuance of an EIDL for TressD LLC and transmitted loan documentation to the

email address ALEXANDER listed on the EIDL application.

11. On or about June 25, 2020, the defendant, LASHAWNDA ALEXANDER,

submitted and caused the submission of an EIDL loan authorization and agreement in the

approximate amount of $71,000 for TressD. In the EIDL loan agreement, ALEXANDER falsely

certified that "[ a]ll representations in the Borrower's Loan application (including all

supplementary submissions) are true, correct and complete and are offered to induce SBA to make

this Loan." Based on her false and fraudulent representations, the SBA deposited approximately

$71,000 into the business bank account held by ALEXANDER.

12. As part of the scheme and artifice to defraud, the defendant, LASHAWNDA

ALEXANDER, attempted to obtain at least $137,500 in EIDL program funds and ultimately

received approximately $91,000 in EIDL program funds consisting of one $71,000 EIDL and two

$10,000 advances. ALEXANDER spent the EIDL proceeds for her personal benefit and on

payments and purchases not permissible under the EIDL, including the purchase of a Mercedes

Benz Model GLE 350, flights, hotel rooms, restaurants, home furnishing and department stores.

Use of Interstate Wires

13. On or about the dates set forth below, in the Southern District of Ohio and

elsewhere, the defendant, LASHAWNDA ALEXANDER, for the purpose of executing and

attempting to execute the scheme to defraud, knowingly transmitted and caused to be

4
Case: 1:22-cr-00064-MWM Doc #: 24 Filed: 07/27/22 Page: 5 of 6 PAGEID #: 93

transmitted in interstate commerce by means of wire communications, certain signals, signs,

and sounds, namely:

Date of Wire
Count Description of Wire Transmission
Transmission
Transmission of the EIDL application for business
l 6/23/2020 "Lashawnda Alexander" from ALEXANDER to
the SBA through servers outside of the Southern
District of Ohio.
Transmission of the EIDL application for business
2 6/24/2020 'TressD LLC" from ALEXANDER to the SBA
through servers outside of the Southern District of
Ohio.
3 6/25/2020 lfransmission of the EIDL loan agreement for
business "TressD LLC" from ALEXANDER to the
SBA through servers outside of the Southern District
of Ohio.

All in violation of 18 U.S.C. §§ 1343 and 2.

FORFEITURE ALLEGATION

Upon conviction of any of the offenses set forth in Counts One through Three of this

Indictment, the defendant, LASHAWNDA ALEXANDER, shall forfeit to the United States,

pursuant to 18 U.S.C. § 98l(a)(l)(C) and 28 U.S.C. § 246l(c), any property, real or personal,

which constitutes or is derived from proceeds traceable to the violation, including but not limited

to a money judgment equal to at least $91,000.00, which represents the amount of proceeds the

defendant obtained as a result of the offense(s).

SUBSTITUTE ASSETS

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;

5
Case: 1:22-cr-00064-MWM Doc #: 24 Filed: 07/27/22 Page: 6 of 6 PAGEID #: 94

d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be divided without

difficulty,

it is the intent of the United States, pursuant to 21 U.S.C. § 853(p), as incorporated by 28 U.S.C.

§ 246l(c), to seek forfeiture of any other property of the defendant, up to the value of the property

described above.

A TRUE BILL.

FOREPERSON
Is/
KENNETH L. PARKER
UNITED STATES ATTORNEY

EBUNOLUWA A. TAIWO
ASSISTANT UNITED STATES ATTORNEY

6
f(j

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