Indictment — No. 1:23-cr-00078 (Dkt. 2, D. Del.)

Summary

An indictment, Dkt. 2, in United States v. Crandall Speights, Criminal Action No. 23- (Case 1:23-cr-00078), in the U.S. District Court for the District of Delaware, dated September 14, 2023. It alleges that between June 13, 2019 and October 12, 2021 the defendant deposited approximately twenty-four checks stolen from the mail and altered, obtaining or attempting to obtain approximately $345,250, and that between June 21, 2020 and April 26, 2021 he submitted six fraudulent CARES Act loan applications for five entities, obtaining approximately $559,999. The counts are captioned bank fraud for the stolen checks, wire fraud for loans including a Cantera Music Foundation EIDL, conspiracy to commit wire fraud, and money laundering, and the indictment ends with forfeiture allegations.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Text recognized from a scanned document; may contain errors. Page 5 of 17 is not shown because the text could not be recognized reliably.

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA

v.
Criminal Action No. 23-

CRANDALL SPEIGHTS,
Defendant. )

INDICTMENT

The Grand Jury for the District of Delaware charges that:
Background Relevant to All Counts

lic Between on or about June 13, 2019, and October 12, 2021, Crandall SPEIGHTS
schemed to fraudulently obtain money in two ways. As set fon below, one of those methods
involved depositing checks which were stolen out of the mail and altered, and the other involved

submitting applications for federal loans for companies that did not exist.

2. To obtain one of the fraudulent loans, SPEIGHTS conspired with an unindicted co-
conspirator.
3; SPEIGHTS deposited, or directed others to deposit, fraudulently obtained funds

into nine bank accounts. SPEIGHTS then made efforts to conceal the fact that the funds were
obtained through fraud by transferring fraudulently obtained funds between bank accounts.

4, In the course of these schemes, SPEIGHTS used another person’s identity without
his knowledge or permission. SPEIGHTS used the name of an individual referred to herein as
“JL. in bank account opening documents for an account at Discover Bank, which received

fraudulently obtained loan funds.

[FULED
SEP 14 2023

U.S. DISTRICT COUR
DISTRICT GE EEL
Scheme to Alter and Deposit Stolen Checks

5. Between on or about June 13, 2019, and October 12, 2021, Crandall SPEIGHTS
deposited approximately twenty-four (24) checks into four (4) bank accounts he controlled. Those
checks were stolen from United States Postal Service CUSPS”) mail collection boxes and
receptacles and altered to look like they were made out to other individuals or businesses.

6. In total, SPEIGHTS obtained or attempted to obtain approximately $345,250
through this scheme.

Scheme to Obtain Fraudulent CARES Act Loans

7. During an overlapping timeframe, between on or about June 21, 2020, and on or
about April 26, 2021, SPEIGHTS submitted six (6) fraudulent applications for federal loans
through the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”).

8. The CARES Act provides for sources of funding for small businesses affected by
the economic downturn associated with the Coronavirus Pandemic, Paycheck Protection Program
Loans, and Shuttered Venue Operators Grants. The date of disaster for CARES Act purposes is
January 31, 2020 (“Date of Disaster”).

9. The Paycheck Protection Program Loans (“PPP”) are designed for payroll costs,
mortgage interest and rent, and utilities. To be eligible for a PPP Loan, borrowers must have been
in operation on February 15, 2020, had fewer than 500 employees, and had monthly payroll
expenses. Approved PPP borrowers receive a loan amount equal to up to 2.5 times the monthly
payroll stated in the borrower’s application. Applicants for PPP Loans submit applications through
traditional lenders, many who already participate in other U.S. Small Business Administration

(“SBA”) guaranteed loan programs.
10. Economic Injury Disaster Loans (“EIDL”) are designed for working capital
needs—broadly defined as short-term business expenses, such as accounts payable and interest on
fixed debts. A business may apply for both PPP and EIDL, but cannot hold funds from both
programs for the same purpose. Applicants for EIDLs submit an online application directly to the
SBA.

11. | Between on or about June 21, 2020, and on or about April 26, 2021, SPEIGHTS
submitted six (6) fraudulent applications to the SBA and its authorized lenders to obtain loans
through the small business loan programs established by the CARES Act. Speights conspired with
an unindicted co-conspirator to submit one of those fraudulent applications on or about February
21, 2021.

12. These six (6) loan applications were made on behalf of five (5) entities controlled
by SPEIGHTS: Abbey Plumbing & HVAC LLC; Santolubes Manufacturing LLC; a sole
proprietorship in the name of an individual referred to herein as “W.T”; Crandall SPEIGHTS —
Sole Proprietorship; and Cantera Music Foundation. Each of the loan applications falsely asserted
the existence of a small business or sole proprietorship that did not in fact exist, along with false
information about, for example, the number of employees of the business, the business’s start date,
or revenues or payroll expenses of the business.

13. As a result of these false applications, SPEIGHTS obtained approximately
$559,999. The six (6) loans were deposited into six (6) bank accounts which SPEIGHTS and/or
an unindicted co-conspirator controlled. Some of those bank accounts are the same bank accounts

where stolen checks were deposited.
COUNT 1
(Bank Fraud — Scheme to Deposit Stolen Checks)

14. From on or about June 13, 2019, through on or about October 12, 2021, SPEIGHTS
deposited twenty-four (24) checks into the following federally insured financial institutions and
accounts:

a. HSBC Checking Account Number XXXXX0291, in the name of W.T. (“HSBC
0291”);

b. HSBC Checking Account Number XXXXX0712, in the name of W.T. (“HSBC
0712”);

c. Bank of America Checking Account Number XXXXXXXX4939, in the name of
Abbey Plumbing & HVAC LLC (“BOA 4939”);

d. Bank of America Checking Account Number XXXXXXXX0990, in the name of
an individual referred to herein as “T.G.” (“BOA 0990”).

15. | The checks SPEIGHTS deposited were stolen from USPS mail collection boxes
and receptacles in Delaware and elsewhere, and were altered to appear as if they had been made
out to other individuals or businesses.

16. | Thechecks ranged in amount from approximately $300 to approximately $101,453,
and originated from M&T Bank, Wells Fargo Bank, Fulton Bank, Bryn Mawr Trust, TD Bank,
Bank of America, Truist Bank, and Charles Schwab Bank, each of which is a federally insured
financial institution. In total, SPEIGHTS obtained or attempted to obtain approximately $345,250

through this scheme, as set forth below:
Bank of America BOA 4939 10/5/2021 426 $1,727.80
TD Bank BOA 4939 10/5/2021 2729 $13,054.50
TD Bank BOA 4939 10/5/2021 1024 $4,201.29
Truist Bank BOA 4939 10/6/2021 552 $4,010.20
Charles Schwab BOA 4939 10/8/2021 50 $700.00
Bank
Wells Fargo Bank BOA 4939 10/12/2021 139] $5,922.75
Bank of America BOA 4939 10/12/2021 119 $300.00
Wells Fargo Bank BOA 0990 6/13/2019 20033 $3,937.50
Wells Fargo Bank BOA 0990 6/14/2019 10552 $4,267
Wells Fargo Bank BOA 0990 6/14/2019 10553 $8,800
Wells Fargo Bank BOA 0990 6/14/2019 10554 $35,334
Charging Paragraph

17. From on or about June 13, 2019, through on or about October 12, 2021, in the
District of Delaware and elsewhere, Crandall SPEIGHTS, defendant herein, did knowingly
execute and attempt to execute a scheme and artifice to defraud M&T Bank, Wells Fargo Bank,
Fulton Bank, Bryn Mawr Trust, TD Bank, Bank of America, Truist Bank, and Charles Schwab
Bank, federally insured financial institutions, and to obtain moneys, funds, and other property

under the custody and control of those financial institutions, by means of material false and
fraudulent pretenses, representations, and promises, as described more fully in paragraphs 14-16
above, incorporated herein by reference.
All in violation of Title 18, United States Code, §§ 1344 and 2.
COUNT 2

(Wire Fraud — Cantera Music Foundation EIDL)

18. Onor about June 21, 2020, SPEIGHTS created a fraudulent online application for
an EIDL to the SBA in the name of Cantera Music Foundation, a business purportedly located in
Philadelphia, Pennsylvania and whose Chief Executive Officer was purportedly J.L. In this
application, SPEIGHTS stated Cantera Music Foundation had an entity start date of October 15,
2018, had twenty (20) employees, and $150,000 in gross revenues in 2019.

19. Contrary to the fraudulent representations made by SPEIGHTS, Cantera Music
Foundation is not an actual business entity with J.L. as Chief Executive Officer, did not have an
entity start date of October 15, 2018, did not have twenty (20) employees, did not have $150,000
in gross revenues in 2019, and therefore was not eligible to receive an EIDL.

20. Asaresult of this fraudulent application made by SPEIGHTS, on or about June 25,
2020, the SBA approved the EIDL and deposited $100,000 into Discover Bank Checking Account
Number XXXXXX1038, in the name of J.L. (“Discover 1038”).

Charging Paragraph

21. From on or about June 21, 2020, through on or about June 25, 2020, in the District
of Delaware and elsewhere, SPEIGHTS, defendant herein, having devised and intending to devise
a scheme and artifice to defraud and to obtain money and property by means of materially false
and fraudulent pretenses, representations and promises, as described in paragraphs 18 through 20

above, incorporated herein by reference, and for the purposes of executing such scheme, did
knowingly transmit and cause to be transmitted by means of a wire communication in interstate
and foreign commerce, the following:

° On or about June 21, 2020, an electronic loan application submitted to the SBA
by SPEIGHTS from his home in Delaware.

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

(Aggravated Identity Theft — J.L.)

22. Onor about March 31, 2020, SPEIGHTS opened the Discover 1038 bank account
using J.L.’s name, date of birth, and social security number. SPEIGHTS did so knowing J.L. was
areal person, but without J.L.’s knowledge or permission.

23. The Discover 1038 bank account later received the fraudulent EIDL for Cantera
Music Foundation as alleged in Count 2.

Charging Paragraph

24. Onor about March 31, 2020, in the District of Delaware and elsewhere, SPEIGHTS
did knowingly transfer, possess, and use, without lawful authority, a means of identification of
another person during and in relation to a felony violation enumerated in Title 18, United States
Code, Section 1028A(c), to wit, wire fraud, as alleged in Count 2, and as described in paragraphs
22 through 23 above, knowing that the means of identification belonged to another actual person,
in violation of Title 18, United States Code, Section 1028A(a)(1).

COUNT 4
(Conspiracy to Commit Wire Fraud — Santolubes Manufacturing LLC Loan)
25. On or about February 22, 2021, SPEIGHTS and an unindicted co-conspirator

conspired together to create a fraudulent online application for a PPP loan to Customers Bank, a
federally insured banking corporation headquartered in Phoenixville, Pennsylvania, in the name
of Santolubes Manufacturing, LLC, a business purportedly located in Wilmington, Delaware. In
this application, SPEIGHTS and the unindicted co-conspirator stated that Santolubes
Manufacturing LLC was owned by the unindicted co-conspirator, had eighteen (18) employees,
that the entity was established in 2018, and that it had approximately $63,333 in average monthly
payroll expenses.

26. Contrary to the fraudulent representations made by SPEIGHTS and the unindicted
co-conspirator, Santolubes Manufacturing is not an actual business entity owned or represented by
the unindicted co-conspirator, did not have eighteen (18) employees, did not have an entity start
date in 2018, did not have approximately $63,333 in average monthly payroll expenses, and
therefore was not eligible to receive a PPP loan.

27. As aresult of this fraudulent application made by SPEIGHTS and the unindicted
co-conspirator, on or about March 31,2021, Customers Bank approved the PPP loan and deposited
$179,167 into Ocean First Bank Checking Account Number XXXXXXX4661, in the name of the
unindicted co-conspirator (“Ocean First 4661”).

28. OnApril 6, 2021, Speights and the unindicted co-conspirator conspired together to
open Ocean First Bank Business Checking Account Number XXXXXXXX1378, in the name of
Santolubes Manufacturing LLC (“Ocean First 1378”). That same day, the unindicted co-
conspirator wrote a check to withdraw $122,000 in cash from the Ocean First 4661 account. Ocean
First Bank cancelled the check and closed Ocean First 4661 and 1378 on April 8, 2021.
Charging Paragraph

29. From on or about February 22, 2021, through on or about April 6, 2021, in the

District of Delaware and elsewhere, SPEIGHTS, defendant herein, and an unindicted co-
conspirator, did knowingly and intentionally conspire and agree to devise a scheme and artifice to
defraud and to obtain money and property by means of materially false and fraudulent pretenses,
representations and promises in violation of Title 18, United States Code, Section 1343, as
described in paragraphs 25 through 28 above, incorporated herein by reference, and for the
purposes of executing such scheme, did knowingly transmit and cause to be transmitted by means
of a wire communication in interstate and foreign commerce, the following:

e On or about February 22, 2021, an electronic loan application initiated with
Customers Bank by SPEIGHTS and an unindicted co-conspirator, from his home in Delaware.

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

COUNT 5
(Wire Fraud — Abbey Plumbing & HVAC LLC Loan)

30. Onor about March 31, 2021, SPEIGHTS submitted a fraudulent online application
for a PPP loan to Blue Ridge Bank, a federally insured banking corporation headquartered in
Martinsville, Virginia, in the name of Abbey Plumbing & HVAC LLC, a business purportedly
located in Philadelphia, Pennsylvania. In this application, SPEIGHTS stated Abbey Plumbing &
HVAC LLC was owned by W.T., had twenty-seven (27) employees, an entity start date of 2018,
and $71,667 in average monthly payroll expenses.

31. Contrary to the fraudulent representations made by SPEIGHTS, Abbey Plumbing
& HVAC LLC is not an actual business entity owned or represented by W.T., did not have twenty-
seven (27) employees, did not have an entity start date of 2018, did not have $71,667 in average

monthly payroll expenses, and therefore was not eligible to receive a PPP loan.

10
32. Asa result of this fraudulent application made by SPEIGHTS, on or about April
12, 2021, Blue Ridge Bank approved the PPP loan and deposited $200,000 into the HSBC 0712
Account, a business account held in the name of W.T.
Charging Paragraph

33. From on or about March 31, 2021, through on or about April 12, 2021, in the
District of Delaware and elsewhere, SPEIGHTS, defendant herein, having devised and intending
to devise a scheme and artifice to defraud and to obtain money and property by means of materially
false and fraudulent pretenses, representations and promises, as described in paragraphs 30 through
32 above, incorporated herein by reference, and for the purposes of executing such scheme, did
knowingly transmit and cause to be transmitted by means of a wire communication in interstate
and foreign commerce, the following:

® On or about March 31, 2021, an electronic loan application sent to Blue Ridge
Bank by SPEIGHTS, from his home in Delaware.

All in violation of Title 18, United States Code, Section 1343.
COUNT 6

(Wire Fraud - SPEIGHTS Self-Employment Loan)

34. On or about March 28, 2021, SPEIGHTS submitted a fraudulent online application
for a PPP loan to Fountainhead SBF, in the name of Crandall SPEIGHTS, a purportedly self-
employed individual located in Wilmington, Delaware. In this application, SPEIGHTS stated he
had been self-employed since January 1, 2017, and had gross income of $125,000 in 2019.

35. Contrary to the fraudulent representations made by SPEIGHTS, he has not been a
self-employed individual located in Wilmington, Delaware since January 1, 2017, did not have

gross income of $125,000 in 2019, and therefore was not eligible to receive a PPP loan.

11
36. Asa result of this fraudulent application made by SPEIGHTS, on or about April
13, 2021, Fountainhead SBF approved the PPP loan and deposited $20,833 into Aspiration
Checking Account Number XXXXXXXX2884, in the name of Crandall SPEIGHTS (“Aspiration
2884”).
Charging Paragraph

37. | From onor about March 28, 2021, through on or about April 13, 2021, SPEIGHTS,
defendant herein, having devised and intending to devise a scheme and artifice to defraud and to
obtain money and property by means of materially false and fraudulent pretenses, representations
and promises, as described in paragraphs 34 through 36 above, incorporated herein by reference,
and for the purposes of executing such scheme, did knowingly transmit and cause to be transmitted
by means of a wire communication in interstate and foreign commerce, the following:

° On or about March 28, 2021, an electronic loan application sent to Fountainhead
SBF by SPEIGHTS, from his home in Delaware.
All in violation of Title 18, United States Code, Section 1343.

COUNT 7

(Wire Fraud — W.T. Self-Employment Loan)

38. Onor about April 10, 2021, SPEIGHTS submitted a fraudulent online application
for a PPP loan to Fountainhead SBF, an SBA-guaranteed non-bank direct lender headquartered in
Lake May, Florida, in the name of W.T., a purportedly self-employed individual located in
Philadelphia, Pennsylvania. In this application, SPEIGHTS stated W.T. had been self-employed

since January 1, 2014, and had gross income of $100,000 in 2019.

12
39. Contrary to the fraudulent representations made by SPEIGHTS, W.T. has not been
a self-employed individual located in Philadelphia, Pennsylvania since January |, 2014, did not
have gross income of $100,000 in 2019, and therefore was not eligible to receive a PPP loan.

40. As aresult of this fraudulent application made by SPEIGHTS, on or about April
21, 2021, Fountainhead SBF approved the PPP loan and deposited $20,833 into Discover Bank
Checking Account Number XXXXXX5363, in the name of W.T. (“Discover 5363”).
Charging Paragraph

41. | From onor about April 10, 2021, through on or about April 21, 2021, in the District
of Delaware and elsewhere, SPEIGHTS, defendant herein, having devised and intending to devise
a scheme and artifice to defraud and to obtain money and property by means of materially false
and fraudulent pretenses, representations and promises, as described in paragraphs 38 through 40
above, incorporated herein by reference, and for the purposes of executing such scheme, did
knowingly transmit and cause to be transmitted by means of a wire communication in interstate
and foreign commerce, the following:

e On or about April 10, 2021, an electronic loan application sent to Fountainhead
SBF by SPEIGHTS, from his home in Delaware.
All in violation of Title 18, United States Code, Section 1343.

COUNT 8
(Wire Fraud — Second W.T. Self-Employment Loan)

42. On or about April 26, 2021, SPEIGHTS submitted a fraudulent online application
for a second-draw PPP loan to Fountainhead SBF in the name of W.T., a purportedly self-
employed individual located in Philadelphia, Pennsylvania. In this application, SPEIGHTS stated

W.T. had been self-employed since January 1, 2014, and had gross income of $100,000 in 2019.

13
43. Contrary to the fraudulent representations made by SPEIGHTS, W.T. has not been
a self-employed individual located in Philadelphia, Pennsylvania since January 1, 2014, did not
have gross income of $100,000 in 2019, and therefore was not eligible to receive a PPP loan.

44. As arresult of this fraudulent application made by SPEIGHTS, on or about May 5,
2021, Fountainhead SBF approved the PPP loan and deposited $29,166 into Bank of America
Checking Account Number XXXXXXXX4955, in the name of Abbey Plumbing & HVAC LLC
(“BOA 4955”).
Charging Paragraph

45. From on or about April 26, 2021, through on or about May 5, 2021, in the District
of Delaware and elsewhere, SPEIGHTS, defendant herein, having devised and intending to devise
a scheme and artifice to defraud and to obtain money and property by means of materially false
and fraudulent pretenses, representations and promises, as described in paragraphs 42 through 44
above, incorporated herein by reference, and for the purposes of executing such scheme, did
knowingly transmit and cause to be transmitted by means of a wire communication in interstate
and foreign commerce, the following:

e On or about April 26, 2021, an electronic loan application sent to Fountainhead
SBF by SPEIGHTS, from his home in Delaware.
All in violation of Title 18, United States Code, Section 1343.

COUNTS 9-10
(Money Laundering)
46. Paragraphs | — 45 are fully incorporated herein.
47. | SPEIGHTS used the following federally insured financial institutions and accounts

to conduct financial transactions:

14
48.

Discover Bank Checking Account Number XXXXXX 1038, in the name of

IL. (“Discover 1038”);

Aspiration Checking Account Number XXXXXXXX2884, in the name of

Crandall SPEIGHTS (“Aspiration 2884”);

HSBC Checking Account Number XXXXX0712, in the name of W.T.

Bank of America Checking Account Number XXXXXXXX4939, in the name

of Abbey Plumbing & HVAC LLC (BOA 4939”);

On or about the following dates, in the District of Delaware and clsewhere,

SPEIGHTS knowingly engaged in and attempted to engage in a monetary transaction affecting

interstate and foreign commerce, in criminally derived property of a value greater than $10,000,

that is, the withdrawal, deposit, and transfer of funds from and to the financial institutions

identified below, such property having been derived from specified unlawful activity, that is wire

fraud, as set forth in Counts 2 and 5:

Count On or About Transfer From Transfer To Amount |
9 7/13/2020 Discover 1038 | Aspiration 2884 $25,000
10 4/12/2021 HSBC 0712 BOA 4939 $35,000

All in violation of Title 18, United States Code, Section 1957.

NOTICE OF FORFEITURE

Bank and Wire Fraud Involving Financial Institutions (Counts 1, 4-8)

Upon conviction of the offenses in violation of 18 U.S.C. § 1343 set forth in Counts 1, and

4-8 of the Indictment the defendant, CRANDALL SPEIGHTS shall forfeit to the United States of

America, pursuant to 18 U.S.C. § 982(a)(2)(A) and 28 U.S.C. § 2461(c), any property, real or

15
personal, which constitutes or is derived from proceeds obtained directly or indirectly as a result
of the offenses. The property to be forfeited includes, but is not limited to, a sum of money equal
to the proceeds derived from the offense.

Wire Fraud Involving Theft of Government Funds (Count 2)

Upon conviction of the offense in violation of 18 U.S.C. § 1343 set forth in Count 2 of this
Indictment, the defendant, CRANDALL SPEIGHTS, shall forfeit to the United States of America,
pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c), any property, real or personal,
which constitutes or is derived from proceeds traceable to the offenses. The property to be
forfeited includes, but is not limited to, a sum of money equal to the proceeds derived from the
offense.

Money Laundering (Counts 9-10)

Upon conviction of the offenses in violation of Title 18, United States Code, Section 1957
set forth in Counts 9 - 10 of this Indictment, the defendant, CRANDALL SPEIGHTS, shal! forfeit
to the United States of America, pursuant to 18 U.S.C. § 981(a)(1), any property, real or personal,
involved in the offenses, and any property traceable to such property. The property to be forfeited
includes, but is not limited to, the following:

Money Judgment: a sum of money equal to the proceeds derived from the offense; and

Personal Property: Contents of (a) Discover Bank Checking Account Number

XXXXXX 1038; (b) Aspiration Checking Account Number XXXXXXXX2884; (c) HSBC

Checking Account Number XXXXX0712; and (d) Bank of America Checking Account

Number XXXXXXXX4939.

16
Substitute Property

If any of the property described above, as a result of any act or omission of the defendant:

cannot be located upon the exercise of due diligence;

has been transferred or sold to, or deposited with, a third party;

has been placed beyond the jurisdiction of the court;

has been substantially diminished in value; or

has been commingled with other property which cannot be divide without
difficulty,

the United States of America shall be entitled to forfeiture of substitute property pursuant to 21
U.S.C. § 853(p), as incorporated by 28 U.S.C. § 2461(c),

A ‘TRUE BILL:

DAVID C. WEISS
UNITED STATES ATTORNEY

BY: Ul
Assistant United States Attorneys

Dated: September 14, 2023


File and source

File

2.pdf

Size

906,755 bytes

SHA-256

b641ce0cc0114cb44e2cff74ec1ec029b42ce12068bcb8dacc2a8744e5266a6b

Our copy

2.pdf

Original

No public link identified.