Indictment — No. 1:24-cr-00449 (Dkt. 1, N.D. Ill.)

Summary

An indictment filed September 24, 2024 as Document #1 in United States v. Marvin Reed, Case No. 1:24-cr-00449, in the U.S. District Court for the Northern District of Illinois, Eastern Division. Counts One through Fifteen are captioned Wire Fraud under 18 U.S.C. § 1343. The indictment describes the CARES Act and the Paycheck Protection Program and alleges that the defendant was the owner, registered agent, banking signatory, or otherwise affiliated with 13 named entities formed between about April 2020 and August 2020. A table headed Count, Wire, Applicant Entity and Approx. lists the counts, and forfeiture allegations seek a money judgment.

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“Indictment — No. 1:24-cr-00449 (Dkt. 1, N.D. Ill.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-1-24-cr-00449-dkt-1-n-d-ill-9abcdf3276/, SHA-256 73d3197390b327160524f21a8bd70abe70d102beef96fe9b8c1f65986c8dfe4e.

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1:24-cr-00449
Case: 1:24-cr-00449 Document #: 1 Filed: 09/24/24 Page 1 of 9 PageID #:1

ED
Judge Matthew F. Kennelly

FIL
4/2024
KSR
UNITED STATES DISTRICT COURT
Magistrate Judge Maria Valdez
RANDOM/CAT 3
9/2
. BRUTO N NORTHERN DISTRICT OF ILLINOIS
THOMA.SDG
IS T R IC T COURT EASTERN DIVISION
CLERK, U.S

UNITED STATES OF AMERICA Case No.:

v. Violations: Title 18, United States
Code, Section 1343
MARVIN REED
FILED UNDER SEAL
Defendant.

_________________________________/

INDICTMENT

COUNTS ONE through FIFTEEN

(18 U.S.C. § 1343 – Wire Fraud)

THE SPECIAL MAY 2024 GRAND JURY CHARGES:

1. At all times material to this Indictment:

Payroll Protection Program Loans

a. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act

was a federal law enacted in or around March 2020 and designed to provide

emergency financial assistance to the millions of Americans who were suffering the

economic effects caused by the COVID-19 pandemic. One source of relief provided by

the CARES Act was the authorization of up to $349 billion in forgivable loans to small

businesses for job retention and certain other expenses, through a program referred

to as the Paycheck Protection Program (“PPP”). In or around April 2020, Congress

authorized over $300 billion in additional PPP funding.

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b. In order to obtain a PPP loan, a qualifying business was required to

submit a PPP loan application, which was signed by an authorized representative of

the business. The PPP loan application required the business (through its authorized

representative) to acknowledge the program rules and make certain affirmative

certifications in order to be eligible to obtain the PPP loan. In the PPP loan

application, the small business (through its authorized representative) was required

to state, among other things, its: (a) average monthly payroll expenses; and

(b) number of employees. These figures were 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 showing their

payroll expenses.

c. A PPP loan application had to be 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 100% guaranteed by the Small Business

Administration (“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.

d. PPP loan proceeds had to be used by the business on certain

permissible expenses—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 these expense items within a designated period

of time after receiving the proceeds and used a certain amount of the PPP loan

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proceeds on payroll expenses.

The Defendant and Relevant Entities

e. Defendant Marvin REED (“REED”) was a resident of Cook County

within the Northern District of Illinois.

f. REED was the owner, registered agent, banking signatory, and/or

otherwise affiliated with the following entities: (1) Everything Is Everything, LLC;

(2) Friendship Matters, LLC; (3) Go Get It Then, LLC; (4) Let The Truth Be Told,

LLC; (5) ( Just To Be Close, LLC; (6) Save The World, LLC; (7) Full Disclosure

Multimedia, LLC; (8) Better Life Now, LLC; (9) Almost There Yet, LLC; (10) Crazy

About You, LLC; (11) Change The World Investments, LLC; (12) Do Your Job Now,

LLC; and (13) Divine Revelation Entertainment LLC (collectively, the “Defendant

Entities”). Each of the Defendant Entities were registered in the State of Illinois and

located within the Northern District of Illinois. Each of the Defendant Entities were

formed between in or around April 2020 and August of 2020.

g. The 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 the economic

recovery of communities after disasters.

h. Lending Entity 1 was an online financial technology company based

in San Francisco, California. The company provided loans and funding to small

businesses.

i. Lending Entity 2 was an online financial technology company based

in Atlanta, Georgia. The company provided loans and funding to small businesses.

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j. Lending Entity 3 was a private lender based in Coral Gables, Florida.

The company provided loans to small businesses.

k. Banking Entity 1 was a financial institution based in Cincinnati,

Ohio.

l. Banking Entity 2 was a financial institution based in Boston,

Massachusetts.

m. Banking Entity 3 was a financial institution based in San Francisco,

California.

n. Banking Entity 4 was a financial institution based in Detroit,

Michigan.

o. Banking Entity 5 was a financial institution based in New York, New

York.

p. Banking Entity 6 was a financial institution based in Columbus,

Ohio.

q. Banking Entity 7 was a financial institution based in Chicago,

Illinois.

r. Banking Entity 8 was a financial institution based in Atlanta,

Georgia.

s. Banking Entity 9 was a financial institution based in Pittsburgh,

Pennsylvania.

t. Banking Entity 10 was financial institution based in Charlotte,

North Carolina.

u. Banking Entity 11 was a financial institution based in Minneapolis,

Minnesota.

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v. Banking Entity 12 was a financial institution based in Chicago,

Illinois.

2. From at least in or around May 2020 through at least in or around April

2021, in the Northern District of Illinois, and elsewhere,

MARVIN REED,

defendant herein, and others known and unknown to the Grand Jury, knowingly

participated in a scheme to defraud the Small Business Administration, Lending

Entity 1, Lending Entity 2, and Lending Entity 3 and to obtain money by means of

materially false and fraudulent pretenses, representations, and promises,

transmitted over wire communication in interstate commerce, which scheme is

further described below.

Purpose of the Scheme and Artifice

3. It was the purpose of the scheme and artifice for defendant REED to

unlawfully enrich himself by: (a) submitting and causing the submission of false and

fraudulent loan applications to the Small Business Administration and SBA

sponsored lenders, including Lending Entity A, (b) obtaining money by means the

false and fraudulent loan applications, and (c) concealing and causing the

concealment of the scheme.

The Scheme and Artifice

4. It was part of the scheme and artifice that REED submitted at least 15 false

and fraudulent PPP loan applications for entities he owned and controlled and for

himself. These applications contained false statements and representations

regarding whether the businesses (except for Full Disclosure Multimedia, LLC) were

actually operational, the businesses’ number of employees and average monthly

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payroll, and whether the businesses issued wage statements to the Internal Revenue

Service (“IRS”).

5. It was further part of the scheme that REED created numerous entities, all

of which shared an address with REED’s home.

6. It was further part of the scheme that REED requested Employer

Identification Numbers (“EIN”) from the IRS for the entities and misrepresented each

entity’s number of employees.

7. It was further part of the scheme that REED opened bank accounts that he

controlled with Banking Entities 1 through 12 for the fraudulent entities.

8. It was further part of the scheme that the funds for the PPP loans were

disbursed to REED into the bank accounts that he owned and controlled with

Banking Entities 1 through 12.

9. It was further part of the scheme that, as a result of the fraudulent PPP

applications submitted by REED, the PPP and the SBA and its approved lenders

suffered a loss of more than $750,000.

10. It was further part of the scheme that, as a result of the fraudulent PPP

applications and loans, REED obtained at least approximately $750,000.

11. It was further part of the scheme that REED concealed and caused to be

concealed the steps taken in furtherance of the scheme.

12. The false and fraudulent payroll information contained in the PPP loan

applications was material insofar as it induced Banking Entities 1 through 3 to

disburse funds to REED which he was not eligible to receive. Each of the false PPP

loan applications set forth herein were submitted through wire communications used

in interstate commerce.

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Acts in Furtherance of the Scheme and Artifice

13. On or about the dates set forth as to each count below, in the Northern

District of Illinois, and elsewhere,

MARVIN REED,

defendant herein, as set forth below, for the purpose of executing the above-described

scheme, knowingly caused to be transmitted by means of wire communication in

interstate commerce certain writings, signs, and signals, listed below, each such

writing, sign, and signal constituting a separate count:

COUNT Wire Applicant Entity Approx. Loan Lender
Transmission Amount
1 May 8, 2020 Full Disclosure $52,083 Lending
PPP loan Multimedia LLC Entity 1
application
2 July 9, 2020 Divine Revelation $53,125 Lending
PPP loan Entertainment LLC Entity 2
application
3 July 15, 2020 Let The Truth Be $53,229 Lending
PPP loan Told LLC Entity 2
application
4 July 18, 2020 Save The World $53,229 Lending
PPP loan LLC Entity 2
application
5 July 21, 2020 Better Life Now $53,229 Lending
PPP loan LLC Entity 2
application
6 July 21, 2020 Almost There Yet $53,229 Lending
PPP loan LLC Entity 2
application
7 July 22, 2020 Crazy About You $53,229 Lending
PPP loan LLC Entity 2
application
8 July 24, 2020 Change The World $53,229 Lending
PPP loan Investments LLC Entity 2
application
9 July 26, 2020 Do Your Job Now $53,229 Lending
PPP loan LLC Entity 2
application
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10 July 30, 2020 Everything Is $53,229 Lending
PPP loan Everything LLC Entity 2
application
11 July 30, 2020 Friendship Matters $53,229 Lending
PPP loan LLC Entity 2
application
12 August 1, 2020 Go Get It Then LLC $53,229 Lending
PPP loan Entity 2
application
13 August 7, 2020 Just To Be Close $53,229 Lending
PPP loan LLC Entity 2
application
14 February 27, Full Disclosure $52,083 Lending
2021 PPP loan Multimedia Entity 1
application
15 April 28, 2021 Marvin Reed $20,833 Lending
PPP loan Entity 3
application

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

FORFEITURE ALLEGATIONS

14. The allegations contained in paragraphs 1 through 13 of this Indictment

are incorporated by reference as if set forth fully herein for the purpose of alleging

forfeiture pursuant to the provisions of 18 U.S.C. § 928(a)(2)(a).

15. As a result of violating 18 U.S.C. § 1343, as set forth in this Indictment,

the defendant shall forfeit to the United States any property, real or personal,

which represents or is traceable to the gross proceeds obtained, directly or

indirectly, from the offenses charged in Counts One through Fifteen and the

following:

16. Money Judgment. A sum of money equal to an amount as is proved at

trial in this matter, representing the total amount of gross proceeds obtained as a

result of the defendant’s violations as alleged in this Indictment.

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17. Substitute Assets: If all or any of the forfeitable 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;

d. has been substantially diminished in value; or

e. has been commingled with other property that cannot be subdivided

without difficulty;

it is the intent of the United States, pursuant to § 853(p), as incorporated by

18 U.S.C. § 982(b), to seek forfeiture of any other property of the defendant up to

the value of the forfeitable property described above.

A TRUE BILL

FOREPERSON

GLENN S. LEON
U.S. Department of Justice
Criminal Division, Fraud Section
Chief

AARON I. HENRICKS
U.S. Department of Justice
Criminal Division, Fraud Section
Trial Attorney

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