Second Superseding Indictment — United States v. David Nathaniel Black et al., Northern District of Georgia
Summary
A second superseding indictment in United States v. David Nathaniel Black, Jr., Chris Elvins Constant, Reginald Douglas, George Thompson, Carson Merice, Yvenord Guerilus, Nicole Cooley, Rise Robinson, Tara Batson, Milan Ham and Matthew Holmes, No. 1:25-cr-00225-ELR-RGV, in the U.S. District Court for the Northern District of Georgia, filed April 29, 2026 as Document 175. It charges wire fraud under 18 U.S.C. § 1343, aggravated identity theft under 18 U.S.C. § 1028A and money laundering under 18 U.S.C. § 1957. The grand jury alleges that companies registered in other states were registered in Georgia without the knowledge or authorization of their officers and used for EIDL and PPP loan applications with fraudulent employee, payroll and revenue information. It states that the SBA and Lender 1 disbursed more than $9.6 million in loan proceeds.
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“Second Superseding Indictment — United States v. David Nathaniel Black et al., Northern District of Georgia.”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-1-25-cr-00225-dkt-175-n-d-ga-704ab82315/
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Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 1 of 29
ORIGINAL
FILED IN CHAMBERS
U.S.D.C. Atlanta
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA APR 2 9 2026
ATLANTA DIVISION
Kev[ ~· ~eimer, Clerk
By: \f""' . eputy Clerk
UNITED ST A TES OF AMERICA
Second Superseding Indictment
V.
No. l:25-CR-225
DAVID NATHANIEL BLACK, JR.,
CHRIS ELVINS CONSTANT,
UNDER SEAL
REGINALD DOUGLAS,
GEORGE THOMPSON,
CARSON MERICE,
YVENORD GUERILUS,
NICOLE COOLEY,
RISE ROBINSON,
TARA BATSON,
MILAN HAM, AND
MATTHEW HOLMES
THE GRAND JURY CHARGES THAT:
COUNTS1THROUGH19
(Wire Fraud)
(18 u.s.c. § 1343)
1. Beginning on a date unknown to the Grand Jury, but from at least in or
about April 2020, and continuing through at least on or about May 3, 2024, in the
Northern District of Georgia and elsewhere, the Defendant, DAVID
NATHANIEL BLACK, JR., aided and abetted by others known and unknown to
the Grand Jury, including Defendants REGINALD DOUGLAS, CARSON
MERICR YVENORD GUERILUS, NICOLE COOLEY, RISE ROBINSON, TARA
BATSON, and MILAN HAM, knowingly devised, intended to devise, and
1
Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 2 of 29
participated in a scheme and artifice to defraud the U.S. Small Business
Administration ("SBA") and authorized SBA lenders, and to obtain money and
property from the SBA and its lenders by means of materially false and
fraudulent pretenses, representations, and promises, and by the omission of
material facts ("the wire fraud scheme").
Background
At times material to this Second Superseding Indictment:
2. The SBA was a government agency that provided assistance to small
businesses, including financial assistance through loans and other funding
programs. SBA' s Economic Injury Disaster Loan ("EIDL") program was a long-
standing disaster loan program that provided direct funding to businesses to
cover operating expenses that could not otherwise be paid because of a disaster's
economic impact.
3. The Coronavirus Aid, Relief, and Economic Security (" CARES") Act was a
federal law enacted in or about March 2020 that was designed to provide
emergency financial assistance to individuals and businesses who were suffering
the economic effects caused by the COVID-19 pandemic.
4. The CARES Act made numerous changes to the SBA' s programs, including
expanded eligibility for EIDLs. The maximum loan amount for COVID-19 EIDLs
varied during the availability of the program, with loans initially capped at
$150,000, which was later increased to $500,000 on or about April 6, 2021, and
then to $2 million on or about October 8, 2021 .
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Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 3 of 29
5. The CARES Act also authorized up to $349 billion in forgivable loans to
small businesses through a program referred to as the Paycheck Protection
Program ("PPP"). The SBA oversaw the PPP but, unlike the EIDL program, did
not provide direct funding. PPP loans were issued by private, approved lenders
who received and processed PPP applications and supporting documentation,
and then made loans using the lender's own funds, which were guaranteed by
the SBA. Eligibility for PPP loans depended on numerous factors, including the
number of employees. The amount of a PPP loan was calculated based on the
small business's average monthly payroll costs. Businesses had to use PPP loan
proceeds for specific business operations, such as payroll costs, utilities, and rent.
6. Lender 1 was an approved SBA lender for PPP loans.
Victim Companies
7. Company 1 was registered with Florida's Division of Corporations as a
Foreign Limited Liability Company on or about June 24, 2004. G.E. was listed as
a company manager for Company 1.
8. Company 2 was registered with the Secretary of the Commonwealth of
Massachusetts as a domestic profit corporation on or about June 26, 2006. J.P.
was listed as Company 2' s president and treasurer.
9. Company 3 was registered with the Ohio Secretary of State as a domestic
profit corporation on or about April 24, 1986. E.D. was listed as an officer of
Company 3.
10. Company 4 was registered with the Ohio Secretary of State as a limited
liability company on or about April 13, 2018. M.C. was listed as an officer of
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Company 4. On or about December 11, 2019, Company 4 was also registered
with Florida's Division of Corporations as a Foreign Limited Liability Company.
M.C. was listed as a company manager.
11. Company 5 was registered with Florida's Division of Corporations as a
Foreign Limited Liability Company on or about August 19, 2013. A.W. was listed
as the company manager for Company 5.
12. Company 6 was registered with the Ohio Secretary of State as a domestic
profit limited liability company on or about February 15, 2017. J.K. was listed as
an officer of Company 6. On or about June 19, 2017, Company 6 was also
registered with Florida's Division of Corporations as a Foreign Limited Liability
Company. J.K. was listed as a company manager.
13. Company 7 was registered with the Illinois Secretary of State as a
domestic corporation on or about October 30, 2006. J.S. was listed as the
president and secretary for Company 7. On or about March 11, 2009, Company 7
was registered with Florida's Division of Corporations as a Foreign Limited
Liability Company . J.S. was listed as a company manager.
14. Company 8 was registered with the Minnesota Secretary of State as a
domestic corporation on or about February 14, 2005. J.B. was listed as the
company manager for Company 8.
15. Company 9 was registered with the Rhode Island Department of State as a
domestic profit corporation on or about February 21, 2011. D.M. was listed as the
president for Company 9.
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Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 5 of 29
16. Company 10 was registered with the Illinois Secretary of State as a
domestic corporation on or about May 14, 2014. J.M. was listed as the president,
director, and secretary of Company 10.
17. Company 11 was registered with the Washington Secretary of State as a
domestic corporation on or about October 1, 2009. W.A. and B.U. were listed as
incorporators for Company 11.
18. Company 12 was registered with the New Jersey Division of Revenue and
Enterprise Services as a domestic corporation on or about November 24, 2010.
W.S. was listed as one of the members/managers for Company 12.
19. Company 13 was registered with the New Jersey Division of Revenue and
Enterprise Services as a domestic corporation on or about October 16, 2004. W.P.
was listed as the member/manager for Company 13.
Scheme and Artifice to Defraud
20. As part of the scheme and artifice to defraud, between in or about
November 2020 and in or about December 2023, Defendants BLACK,
CONSTANT, DOUGLAS, THOMPSON, MERICE, GUERILUS, COOLEY,
ROBINSON, BATSON, HAM, and HOLMES and others registered and caused to
be registered Companies 1 through 13 (" the Companies") with the Georgia
Secretary of State without the knowledge or authorization of the company
officers identified in Paragraphs 7 through 19. Instead, the Georgia Secretary of
State registration listed the person identified below as a company officer:
Company 1 E.C.
Company 2 RISE ROBINSON
Company 3 NICOLE COOLEY
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Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 6 of 29
Company4 NICOLE COOLEY
Company5 CHRIS CONSTANT
Company 6 CARSON MERICE
Company 7 TARA BATSON
Company 7 CHRIS CONSTANT
Company8 GEORGE THOMPSON
Company 9 REGINALD DOUGLAS
Company 10 Rashad Avery
Company 11 YVENORD GUERILUS
Company 12 MILAN HAM
Company 13 MILAN HAM
21. After the Companies were registered in Georgia, between in or about
November 2020 and in or about January 2024, business bank accounts were
opened in each Company's name at financial institutions in the Northern District
of Georgia and elsewhere, which identified the individuals listed below as the
authorized signers on the accounts:
Bank Account Name on Account Signer
SunTrust account ending 4219 Company 1 E.C.
("SunTrust 4219")
SunTrust account ending 7315 Company 2 RISE ROBINSON
("SunTrust 7315")
JP Morgan Chase Bank Company3 NICOLE
account ending 6971 COOLEY
("JPMC 6971")
Wells Fargo Bank Company4 NICOLE
account ending 7224 COOLEY
("Wells Fargo 7224")
Fifth Third Bank Company5 CHRIS
account ending 1824 CONSTANT
("Fifth Third 1824")
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Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 7 of 29
Bank of America Company 6 CARSON
account ending 3517 MERICE
("BOA 3517")
Bank of America
account ending 6087
("BOA 6087" )
JP Morgan Chase Bank Company 7 TARA BATSON
account ending 9572
("JPMC 9572")
PNC Bank account ending 1019 Company 7 CHRIS
("PNC 1019") CONSTANT
PNC Bank account ending 2677 Company8 GEORGE
("PNC 2677") THOMPSON
First Citizens Bank Company 9 REGINALD
account ending 4680 DOUGLAS
("First Citizens 4680")
PNC Bank account ending 2227
("PNC 2227")
Fifth Third Bank Company 10 Rashad Avery
account ending 1472
("Fifth Third 1472")
Truist account Company 11 YVENORD
ending in 1028 GUERILUS
("Truist 1028")
JP Morgan Chase Bank
account ending in 6900
("JPMC 6900")
First Citizens Bank Company 12 MILAN HAM
account ending 3477
("First Citizens 3477")
Synovus Bank Company 13 MILANHAM
account ending 6655
("Synovus 6655")
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Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 8 of 29
22. To fraudulently obtain loan proceeds, Defendant BLACK electronically
submitted and caused others to submit numerous EIDL and PPP loan
applications on behalf of Companies 1 through 13. Defendant BLACK and others
misrepresented that each application was filed by one of the company officers
identified in paragraphs 7 through 19 and, in doing so, used the personal
identification information for these officers. The applications were submitted
without the officers' knowledge.
23. The fraudulent EIDL and PPP applications contained fraudulent
information about the Companies, such as the number of employees, the need for
the loan, the intended use of the funds, average monthly payroll, and gross
revenue. The applications included fraudulent supporting documentation, such
as IRS tax returns, bank statements, and payroll documents. The SBA and Lender
1 relied on the accuracy of the information in the loan applications and
supporting documentation to determine if the loans would be funded.
24. As a result of the misrepresentations in the EIDL and PPP loan
applications, the SBA and Lender 1 disbursed more than $9.6 million in loan
proceeds to the bank accounts identified in paragraph 21.
Execution of the Wire Fraud Scheme
25. On or about the dates set forth below, in the Northern District of Georgia
and elsewhere, the Defendants identified below, aided and abetted by each other
and by others known and unknown to the Grand Jury, for the purpose of
executing the scheme and artifice to defraud described above, with the intent to
defraud, caused to be transmitted by means of wire communication in interstate
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Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 9 of 29
commerce the following wire transmissions described below, each transmission
constituting a separate count:
COUNT DEFENDANT(S) DATE WIRE COMMUNICATION
1 BLACK 11/04/2020 EIDL application for $150,000
electronically submitted to SBA
for Company 1
2 BLACK 12/04/2020 EIDL application for $150,000
ROBINSON electronically submitted to SBA
for Company 2
3 BLACK 1/22/2021 EIDL application for $150,000
COOLEY electronically submitted to SBA
for Company 3
4 BLACK 3/26/2021 PPP application for $148,500
COOLEY electronically submitted to
Lender 1 for Company 4
5 BLACK 4/13/2021 EIDL application for $494,800
COOLEY electronically submitted to SBA
for Company 4
6 BLACK 4/14/2021 PPP application for $221,300
electronically submitted to
Lender 1 for Company 5
7 BLACK 7/27/2021 EIDL application for $486,500
MERICE electronically submitted to SBA
for Company 6
8 BLACK 9/07/2021 EIDL application for $500,000
electronically submitted to SBA
for Company 10
9 BLACK 9/09/2021 EIDL application for $498,800
BATSON electronically submitted to SBA
for Company 7
10 BLACK 9/21/2021 EIDL application for $499,000
electronically submitted to SBA
for Company 8
11 BLACK 10/03/2021 EIDL application for $458,300
DOUGLAS electronically submitted to SBA
for Company 9
9
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12 BLACK 1/03/2022 EIDL application for $629,100
electronically submitted to SBA
for Company 8
13 BLACK 1/18/2022 EIDL application for $798,600
electronically submitted to SBA
for Company 7
14 BLACK 1/18/2022 EIDL application for $1A92,600
MERICE electronically submitted to SBA
for Company 6
15 BLACK 3/05/2022 EIDL application for $669,700
DOUGLAS electronically submitted to SBA
for Company 9
16 BLACK 3/05/2022 EIDL application for $872,000
DOUGLAS electronically submitted to SBA
for Company 9
17 BLACK 5/31/2023 EIDL application for $989,500
GUERILUS electronically submitted to SBA
for Company 11
18 BLACK 10/20/2023 EIDL application for $150A00
DOUGLAS electronically submitted to SBA
HAM for Company 13
19 BLACK 10/25/2023 EIDL application for $500,000
DOUGLAS electronically submitted to SBA
HAM for Company 12
All in violation of Title 18, United States Code, Sections 1343 and 2.
COUNTS20THROUGH38
(Aggravated Identity Theft)
(18 U.S.C. § 1028A)
26. The Grand Jury re-alleges and incorporates by reference the factual
allegations set forth in paragraphs 2 through 24, as if fully set forth herein.
27. From on or about November 4, 2020, and continuing through on or about
October 25, 2023, in the Northern District of Georgia and elsewhere, the
Defendant, DAVID NATHANIEL BLACK, JR., aided and abetted by others
10
Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 11 of 29
known and unknown to the Grand Jury, did knowingly possess and use, without
lawful authority, a means of identification of another person, to wit, the name
and Social Security number of each person identified below, during and in
relation to committing the felony violations identified below:
COUNT PERSON FELONY VIOLATION
20 G.E. Wire Fraud as alleged in Count 1
21 J.P. Wire Fraud as alleged in Count 2
22 E.D. Wire Fraud as alleged in Count 3
23 M.C. Wire Fraud as alleged in Count 4
24 M.C. Wire Fraud as alleged in Count 5
25 A.W. Wire Fraud as alleged in Count 6
26 J.K. Wire Fraud as alleged in Count 7
27 J.M. Wire Fraud as alleged in Count 8
28 J.S. Wire Fraud as alleged in Count 9
29 J.B. Wire Fraud as alleged in Count 10
30 D.M. Wire Fraud as alleged in Count 11
31 J.B. Wire Fraud as alleged in Count 12
32 J.S. Wire Fraud as alleged in Count 13
33 J.K. Wire Fraud as alleged in Count 14
34 D.M. Wire Fraud as alleged in Count 15
35 D.M. Wire Fraud as alleged in Count 16
36 W.A. Wire Fraud as alleged in Count 17
37 W.P. Wire Fraud as alleged in Count 18
38 W.S. Wire Fraud as alleged in Count 19
All in violation of Title 18, United States Code, Sections 1028A(a)(1) and 2.
COUNTS39THROUGH155
(Money Laundering)
(18 u.s.c. § 1957)
28. The Grand Jury re-alleges and incorporates by reference the factual
allegations set forth in paragraphs 2 through 24, as if fully set forth herein.
11
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Background
At times material to this Second Superseding Indictment:
29. BlackFire Technologies, Inc. ("BlackFire") was a Georgia corporation. On
or about October 31, 2018, articles of incorporation for BlackFire were filed with
the Georgia Secretary of State, identifying Defendant BLACK as the incorporator.
30. Ameris Bank business account ending in 4062 (" Ameris 4062") was in the
name of BlackFire, and Defendant BLACK was the authorized signer on the
account.
31. Citizens Trust business account ending in 2612 ("Citizens 2612") was in
the name of BlackFire, and Defendant BLACK was the authorized signer on the
account.
32. Navy Federal Credit Union business account ending in 6927 ("NFCU
6927") was in the name of BlackFire, and Defendant BLACK was the authorized
signer on the account.
33. Coastal Community Credit Union business account ending in 5594
("Coastal 5594") was in the name of BlackFire, and Defendant BLACK was the
authorized signer on the account.
34. Vanguard business account ending in 1887 ("Vanguard 1887") was in the
name of BlackFire, and Defendant BLACK was the authorized signer on the
account.
35. The Patent Trade Corporation ("Patent Trade") was a Georgia corporation.
On or about October 7, 2020, articles of incorporation for Patent Trade were filed
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Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 13 of 29
with the Georgia Secretary of State, identifying Defendant BLACK as the
incorpora tor.
36. Citizens Trust business accounts ending in 2604 ("Citizens 2604") and
ending in 2596 ("Citizens 2596") were in the name of Patent Trade, and
Defendant BLACK was the authorized signer on the accounts.
37. Navy Federal Credit Union account ending in 4889 ("NFCU 4889") was in
the name of Defendant BLACK.
38. De La Noire Limited ("De La Noire") was a Georgia corporation. On or
about August 19, 2021, articles of incorporation for De La Noire were filed with
the Georgia Secretary of State, identifying Defendant BLACK as the incorporator.
39. Navy Federal Credit Union business account ending in 3044 ("NFCU
3044") was in the name of De La Noire, and Defendant BLACK was the
authorized signer on the account.
Deposit of Fraud Proceeds
40. On or about the dates listed below, EIDL and PPP loan proceeds were
deposited into the bank accounts identified:
Date Deposit Bank Account
11/24/2020 $149,900 EIDL for Company 1 SunTrust 4219
12/11/2020 $149,900 EIDL for Company 2 Truist 7315
1/28/2021 $149,900 EIDL for Company 3 JPMC 6971
4/19/2021 $148,500 PPP for Company 4 Wells Fargo 7224
5/05/2021 $494,700 EIDL for Company 4 Wells Fargo 7224
6/11/2021 $221,300 PPP for Company 5 Fifth Third 1824
8/23/2021 $486,400 EIDL for Company 6 BOA3517
10/02/2021 $498,700 EIDL for Company 7 JPMC 9572
10/18/2021 $499,900 EIDL for Company 10 Fifth Third 1472
13
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10/26/2021 $498,900 EIDL for Company 8 PNC2677
11/15/2021 $458,200 EIDL for Company 9 First Citizens 4680
1/20/2022 $629,100 EIDL for Company 8 PNC2677
3/15/2022 $669,700 EIDL for Company 9 PNC2227
3/24/2022 $789,600 EIDL for Company 7 PNC 1019
5/17/2022 $872,000 EIDL for Company 9 PNC 2227
5/18/2022 $1,492,600 EIDL for Company 6 BOA 6087
7/31/2023 $989,500 EIDL for Company 11 Truist 1028
12/21/2023 $500,000 EIDL for Company 12 First Citizens 3477
5/03/2024 $150,400 EIDL for Company 13 Synovus 6655
41. On or about the dates set forth below, in the Northern District of Georgia
and elsewhere, the Defendants identified below, aided and abetted by each other
and by others known and unknown to the Grand Jury, knowingly engaged and
attempted to engage in the monetary transactions identified below in criminally
derived property of a value greater than $10,000, said property having been
derived from specified unlawful activity, namely, the wire fraud scheme alleged
in this Second Superseding Indictment:
COUNT DEFENDANT(S) DATE MONETARY TRANSACTION
39 BLACK 11/25/2020 $58,000 wire transfer from
SunTrust 4219 to Ameris 4062
40 BLACK 12/14/2020 $12,000 cash withdrawal from
ROBINSON Truist 7315
41 BLACK 12/14/2020 Purchase of $42,689.90 official
ROBINSON check from SunTrust 7315 issued to
BlackFire
42 BLACK 1/29/2021 $48,690 wire transfer from JPMC
COOLEY 6971 to Ameris 4062
43 BLACK 1/29/2021 Purchase of $26,500 cashier's check
COOLEY from JPMC 6971 issued to Patent
Trade
44 BLACK 4/23/2021 $39,781 .77 wire transfer from Wells
COOLEY Fargo 7224 to NFCU 4889
14
Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 15 of 29
COUNT DEFENDANT(S) DATE MONET ARY TRANSACTION
45 BLACK 4/24/ 2021 Purchase of $34,468.23 cashier's
COOLEY check from Wells Fargo 7224
issued to Defendant BLACK
46 BLACK 4/29/2021 $30,000 wire transfer from Wells
COOLEY Fargo 7224 to PNC 4958, in the
name of C.C.
47 BLACK 5/06/ 2021 $44,908.52 wire transfer from Wells
COOLEY Fargo 7224 to Citizens 2612
48 BLACK 5/06/ 2021 $36,781.12 wire transfer from Wells
COOLEY Fargo 7224 to Capital One account
ending in 6633, in the name of
Defendant COOLEY
49 BLACK 5/07/2021 Purchase of $40,766.50 cashier's
COOLEY check from Wells Fargo 7224
issued to Patent Trade
50 BLACK 5/07/ 2021 Purchase of $26,000.98 from Wells
COOLEY Fargo 7224 issued to Malcolm
Cunningham Chevrolet
51 BLACK 5/07/ 2021 Purchase of $42,889.76 cashier's
COOLEY check from Wells Fargo 7224
issued to Defendant BLACK
52 BLACK 5/08/ 2021 Purchase of $40,345.50 cashier's
COOLEY check from Wells Fargo 7224
issued to Defendant BLACK
53 BLACK 5/10/ 2021 $30,000 wire transfer from Wells
COOLEY Fargo 7224 to Citizens 2612
54 BLACK 5/10/ 2021 Purchase of $48,409.72 cashier's
COOLEY check from Wells Fargo 7224
issued to Defendant BLACK
55 BLACK 6/15/ 2021 $13,300 cash withdrawal from Fifth
CONSTANT Third 1824
56 BLACK 6/ 15/ 2021 $38,560 cash withdrawal from Fifth
CONSTANT Third 1824
57 BLACK 6/15/ 2021 $45,616.14 wire transfer from Fifth
CONSTANT Third 1824 to NFCU 4889
58 BLACK 6/17/ 2021 $41,970.57 wire transfer from Fifth
CONSTANT Third 1824 to NFCU 6927
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Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 16 of 29
COUNT DEFENDANT(S) DATE MONET ARY TRANSACTION
59 BLACK 6/18/ 2021 $37,600 wire transfer from Fifth
CONSTANT Third 1824 to Bank of America
account ending 7320 ("BOA 7320"),
in the name of Direct Premium
Buys LLC and controlled by
Defendant CONSTANT
60 BLACK 8/27/ 2021 $41,970.57 wire transfer from BOA
MERICE 3517 to NFCU 6927
61 BLACK 8/27/ 2021 Purchase of $32,612.51 cashier's
MERICE check from BOA 3517 issued to
Defendant BLACK
62 BLACK 8/27/ 2021 Purchase of $22,535 cashier's check
MERICE from BOA 3517 issued to
Defendant MERICE
63 BLACK 8/30/ 2021 Purchase of $37,412.80 cashier's
MERICE check from BOA 3517 issued to
BlackFire Technologies Inc
64 BLACK 8/30/ 2021 $98,799.22 wire transfer from BOA
MERICE 3517 to NFCU 3044
65 BLACK 8/30/ 2021 Purchase of $42,604.83 cashier's
MERICE check from BOA 3517 issued to De
La Noire
66 BLACK 8/30/ 2021 $14,860.55 wire transfer from BOA
MERICE 3517 to Truist account ending in
6561 ("Truist 6561"), in the name of
Defendant MERICE
67 BLACK 9/ 01/ 2021 $86,471.11 wire transfer from BOA
CONSTANT 3517 to Fifth Third 1824
MERICE
68 BLACK 9/01 / 2021 $11,530 ACH transfer from BOA
CONSTANT 3517 to BOA 7320
MERICE
69 BLACK 9/01 / 2021 $43,673.30 wire transfer from BOA
CONSTANT 3517 to Fifth Third 1824
MERICE
70 BLACK 9/07/ 2021 $13,848 ACH transfer from BOA
CONSTANT 3517 to BOA 7320
MERICE
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Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 17 of 29
COUNT DEFENDANT(S) DATE MONET ARY TRANSACTION
71 BLACK 10/04/2021 Purchase of $64,764.07 cashier's
BATSON check from JPMC 9572 issued to De
La Noire
72 BLACK 10/13/ 2021 Purchase of $71,644.70 cashier's
BATSON check from JPMC 9572 issue to De
La Noire
73 BLACK 10/13/ 2021 Purchase of $82,412.86 cashier's
BATSON check from JPMC 9572 issued to
BlackFire
74 BLACK 10/ 14/ 2021 $17,500 cash withdrawal from
BATSON JPMC 9572
75 BLACK 10/15/ 2021 $15,000 cash withdrawal from
BATSON JPMC 9572
76 BLACK 10/ 19/ 2021 $15,500 cash withdrawal from
BATSON JPMC 9572
77 BLACK 10/19/ 2021 $41,970.57 wire transfer from Fifth
Avery Third 1472 to NFCU 6927
78 BLACK 10/19/ 2021 Purchase of $32,604.83 cashier's
Avery check from Fifth Third 1472 issued
to De La Noire
79 BLACK 10/ 20/ 2021 $51,471.22 wire transfer from Fifth
Avery Third 1472 to NFCU 3044
80 BLACK 10/20/ 2021 Purchase of $22,677.40 cashier's
Avery check from Fifth Third 1472 issued
to Defendant BLACK
81 BLACK 10/20/ 2021 Purchase of $29,786.42 cashier's
Avery check from Fifth Third 1472 issued
to Avery
82 BLACK 11/ 16/ 2021 $68,456.67 wire transfer from First
DOUGLAS Citizens 4680 to Coastal 5594
83 BLACK 11/17/ 2021 $72,642.23 wire transfer from First
DOUGLAS Citizens 4680 to Navy Federal
Credit Union account ending in
3216 ("NFCU 3216"), in the name
of Defendant DOUGLAS
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Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 18 of 29
COUNT DEFENDANT(S) DATE MONETARY TRANSACTION
84 BLACK 11/18/ 2021 $91,533.46 wire transfer from First
CONSTANT Citizens 4680 to BOA 7320
DOUGLAS
85 BLACK 11/22/ 2021 $81,221.76 wire transfer from BOA
CONSTANT 7320 to Coastal 5594
86 BLACK 11/22/ 2021 $70,173 wire transfer from First
DOUGLAS Citizens 4680 to NFCU 3216
87 BLACK 11/22/2021 $65,000 wire transfer from First
DOUGLAS Citizens 4680 to NT Diamonds LLC
88 BLACK 11/22/ 2021 $40,000 wire transfer from First
DOUGLAS Citizens 4680 to NT Diamonds LLC
89 BLACK 12/17/ 2021 $96,701.44 wire transfer from PNC
CONSTANT 2677 to BOA 7320
THOMPSON
90 BLACK 12/16/ 2021 $54,218.90 wire transfer from PNC
THOMPSON 2677 to Coastal 5594
91 BLACK 12/16/ 2021 $57,331.67 wire transfer from PNC
THOMPSON 2677 to Bank of America account
ending in 3589 ("BOA 3589"), in
the name of MSS Electronic Inc and
controlled by Defendant
THOMPSON
92 BLACK 12/17/2021 $82,745.90 wire transfer from PNC
THOMPSON 2677 to Truist account ending in
7795 ("Truist 7795"), in the name of
MS Support LLC and controlled by
Defendant THOMPSON
93 BLACK 12/21/ 2021 $91,686.98 wire transfer from PNC
THOMPSON 2677 to Coastal 5594
94 BLACK 12/21/ 2021 $91,108.79 wire transfer from BOA
CONSTANT 7320 to Coastal 5594
95 BLACK 12/30/ 2021 $83,561.89 wire transfer from PNC
THOMPSON 2677 to BOA 3589
96 BLACK 1/26/ 2022 $164,201 .92 wire transfer from PNC
THOMPSON 2677 to Coastal 5594
97 BLACK 1/26/ 2022 $119,872.40 wire transfer from PNC
THOMPSON 2677 to Truist 7795
18
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COUNT DEFENDANT(S) DATE MONETARY TRANSACTION
98 BLACK 1/27/2022 $97,641.09 wire transfer from PNC
CONSTANT 2677 to BOA 7320
THOMPSON
99 BLACK 1/27/ 2022 $88,430.55 wire transfer from PNC
THOMPSON 2677 to BOA 3589
100 BLACK 1/31/2022 $42,677.99 wire transfer from PNC
CONSTANT 2677 to JPMC 0680
THOMPSON
101 BLACK 1/31/ 2022 $90,776.14 wire transfer from BOA
CONSTANT 7320 to Coastal 5594
102 BLACK 1/31/ 2022 $40,141.27 wire transfer from BOA
CONSTANT JPMC 0680 to Coastal 5594
103 BLACK 2/01 / 2022 $200,000 wire transfer from Coastal
5594 to Paul Miller Auto Group for
purchase of 2022 Bentley Bentayga
104 BLACK 2/04/ 2022 $101,342.80 wire transfer from PNC
THOMPSON 2677 to Truist 7795
105 BLACK 3/16/ 2022 $112,890.12 wire transfer from PNC
DOUGLAS 2227 to Coastal 5594
106 BLACK 3/17/2022 $50,000 wire transfer from Coastal
5594 to NT Diamonds LLC
107 BLACK 3/17/ 2022 $121,904.72 wire transfer from PNC
DOUGLAS 2227 to NFCU 3216
108 BLACK 3/17/ 2022 $89,417.50 wire transfer from PNC
CONSTANT 2227 to BOA 7320
DOUGLAS
109 BLACK 3/18/ 2022 $82,194.36 wire transfer from BOA
CONSTANT 7320 to Coastal 5594
110 BLACK 3/21/ 2022 $88,632 wire transfer from PNC
DOUGLAS 2227 to NFCU 3216
111 BLACK 3/24/2022 $20,000 wire transfer from PNC
DOUGLAS 2227 to PNC Bank account ending
HAM in 1521 ("PNC 1521"), in the name
of Defendant HAM
112 BLACK 3/24/ 2022 $40,000 wire transfer from PNC
DOUGLAS 2227 to NT Diamonds LLC
113 BLACK 3/25/ 2022 $228,732.86 wire transfer from PNC
CONSTANT 1019 to Coastal 5594
19
Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 20 of 29
COUNT DEFENDANT(S) DATE MONETARY TRANSACTION
114 BLACK 3/25/ 2022 $30,000 wire transfer from Coastal
Avery 5594 to PNC Bank account ending
in 4703 ("PNC 4703"), in the name
of Made Young and controlled by
Avery
115 BLACK 3/26/ 2022 Purchase of $27,000 cashier's check
Avery from PNC 4703 issued to
COOLEY Defendant COOLEY
116 BLACK 3/ 28/ 2022 $192,438.72 wire transfer from PNC
CONSTANT 1019 to BOA 7320
117 BLACK 3/28/ 2022 $173,568.59 wire transfer from PNC
CONSTANT 1019 to BOA 6087
MERICE
118 BLACK 3/30/ 2022 $170,884.06 wire transfer from
MERICE BOA 6087 to Coastal 5594
119 BLACK 3/30/2022 $176,803.70 wire transfer from PNC
CONSTANT 1019 to Coastal 5594
120 BLACK 3/30/ 2022 $350,000 wire transfer from Coastal
5594 to Motorcars of Georgia for
purchase of 2020 McLaren 720S
Convertible
121 BLACK 4/05/ 2022 $133,412.43 wire transfer from PNC
CONSTANT 2227 to BOA 7320
DOUGLAS
122 BLACK 5/18/ 2022 $173,200.15 wire transfer from PNC
DOUGLAS 2227 to NFCU 3216
123 BLACK 5/18/ 2022 $75,022 wire transfer from PNC
DOUGLAS 2227 to Truist account ending in
HOLMES 1962 ("Truist 1962"), in the name of
Branaugh Information Group and
controlled by Defendant HOLMES
124 BLACK 5/19/ 2022 $148,621.07 wire transfer from
DOUGLAS NFCU 3216 to Ocean Auto Center
125 BLACK 5/20/ 2022 $140,045 wire transfer from PNC
DOUGLAS 2227 to Coastal 5594
20
Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 21 of 29
COUNT DEFENDANT(S) DATE MONET ARY TRANSACTION
126 BLACK 5/20/ 2022 $187,322 wire transfer from PNC
DOUGLAS 2227 to Navy Federal Credit Union
account ending in 9153 ("NFCU
9153"), in the name of Oh Mi
Transportation Inc and controlled
by Defendant DOUGLAS
127 BLACK 5/20/ 2022 $227,347.92 wire transfer from BOA
CONSTANT 6087 to JP Morgan Chase account
MERICE ending in 0680 ("JPMC 0680"), in the
name of ER Assist Inc and
controlled by Defendant
CONSTANT
128 BLACK 5/23/ 2022 $240,000 wire transfer from PNC
DOUGLAS 2227 to Coastal 5594
129 BLACK 5/23/ 2022 $20,000 wire transfer from PNC 2227
DOUGLAS to PNC 1521
HAM
130 BLACK 5/23/ 2022 $197,859.37 wire transfer from BOA
HOLMES 6087 to Truist 1962
MERICE
131 BLACK 5/24/ 2022 $173,319.02 wire transfer from BOA
CONSTANT 6087 to JP Morgan Chase account
MERICE ending in 1823 ("JPMC 1823"), in the
name of KZJ Enterprises LLC and
controlled by Defendant
CONSTANT
132 BLACK 5/26/ 2022 $268,211.09 wire transfer from BOA
MERICE 6087 to Coastal 5594
133 BLACK 6/01 / 2022 $153,209.58 wire transfer from BOA
CONSTANT 6087 to JPMC 1823
MERICE
134 BLACK 6/03/ 2022 $173,619.18 wire transfer from BOA
MERICE 6087 to Coastal 5594
135 BLACK 6/ 06/ 2022 $150,000 wire transfer from Coastal
5594 to C.D.T., owner of NT
Diamonds LLC
136 BLACK 6/07/ 2022 $169,962.03 wire transfer from BOA
MERICE 6087 to Coastal 5594
21
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Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 22 of 29
COUNT DEFENDANT(S) DATE MONETARY TRANSACTION
137 BLACK 7/01/2022 $122,309.19 wire transfer from BOA
CONSTANT 6087 to JPMC 0680
MERICE
138 BLACK 8/01/2023 $274,790.75 wire transfer from Truist
GUERILUS 1028 to Vanguard 1887
139 BLACK 8/02/ 2023 $273,090 wire transfer from
Vanguard 1887 to HSBC account
ending in 0638 ("HSBC 0638"t in
the name of Defendant BLACK
140 BLACK 8/02/2023 $273,000 wire transfer from HSBC
0638 to HSBC account ending in
8649 ("HSBC 8649"), in the name of
Defendant BLACK
141 BLACK 8/02/ 2023 $180,645 wire transfer from HSBC
8649 to Dayu Investments LLC for
payment of rent for year 2023-2024
142 BLACK 8/04/ 2023 $174,500 wire transfer from Truist
CONSTANT 1028 to JPMC 0680
GUERILUS
143 BLACK 8/04/ 2023 $142,680 wire transfer from HSBC
0638 to PTG365 LLC for down
payment of 2023 Mercedes Benz G-
Class wagon
144 BLACK 8/08/2023 $112,691.73 wire transfer from Truist
GUERILUS 1028 to JP Morgan Chase account
MERICE ending in 5705 ("JPMC 5705"), in the
name of 49 Productions Inc and
controlled by Defendant MERICE
145 BLACK 8/10/2023 $100,000 wire transfer from Truist
GUERILUS 1028 to JPMC 5705
MERICE
146 BLACK 8/17/2023 $72,688.15 wire transfer from Truist
GUERILUS 1028 to JPMC 6900
22
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COUNT DEFENDANT(S) DATE MONET ARY TRANSACTION
147 BLACK 12/22/ 2023 $187,000.44 wire transfer from First
DOUGLAS Citizens 3477 to NFCU account
HAM ending in 9153 ("NFCU 9153"), in
the name of Oh Mi Transport and
controlled by Defendant
DOUGLAS
148 DOUGLAS 12/22/ 2023 $60,000.01 debit transaction from
NFCU 9153 to Antwerp Diamonds
149 BLACK 12/22/2023 $249,500.22 wire transfer from First
HAM Citizens 3477 to Vanguard 1887
150 DOUGLAS 12/28/2023 $27,000 debit transaction from
HAM NFCU 9153 to Rick Hendrick car
dealership to purchase 2022
Porsche Taycan
151 BLACK 5/06/ 2024 $20,000 wire transfer from Synovus
DOUGLAS 6655 to Vanguard 1887
HAM
152 BLACK 5/07/ 2024 $25,000.22 wire transfer from
DOUGLAS Synovus 6655 to Regions Bank
HAM account ending in 5174 ("Regions
5174"), in the name of Defendant
HAM
153 BLACK 5/08/ 2024 $28,200 wire transfer from Synovus
DOUGLAS 6655 to Vanguard 1887
HAM
154 BLACK 5/09/ 2024 $22,500 wire transfer from Synovus
DOUGLAS 6655 to Regions 5174
HAM
155 BLACK 5/10/ 2024 $25,700 wire transfer from Synovus
DOUGLAS 6655 to Vanguard 1887
HAM
All in violation of Title 18, United States Code, Sections 1957 and 2.
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COUNT156
(Money Laundering Conspiracy)
(18 U.S.C. § 1956(h))
42. The Grand Jury re-alleges and incorporates by reference the factual
allegations set forth in paragraph 29, as if fully set forth herein.
43. Beginning on a date unknown to the Grand Jury, but from at least on or
about May 6, 2020, and continuing through at least on or about May 19, 2020, in
the Northern District of Georgia and elsewhere, the Defendants, DAVID
NATHANIEL BLACK, JR., and CHRIS ELVINS CONSTANT, did knowingly
combine, conspire, confederate, agree, and have a tacit understanding with each
other and others unknown to the Grand Jury, to knowingly conduct and attempt
to conduct financial transactions in and affecting interstate and foreign
commerce, which involved the proceeds of a specified unlawful activity, that is,
wire fraud, in violation of Title 18, United States Code, Section 1343, and theft of
government funds, in violation of Title 18, United States Code, Section 641,
knowing that the property involved in the financial transactions represented the
proceeds of some form of unlawful activity, and knowing that the transactions
were designed in whole and in part to conceal and disguise the nature, location,
source, ownership, and control of the proceeds of specified unlawful activity, all
in violation of Title 18, United States Code, Section 1956(a)(l)(B)(i).
24
: I \ >' Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 25 of 29
Background
At times material to this Second Superseding Indictment:
44. Unemployment Insurance ("UI") was a joint state and federal program
that provided monetary benefits to eligible beneficiaries. UI payments were
intended to provide temporary financial assistance to lawful workers who were
unemployed through no fault of their own. Beginning in or about March 2020, in
response to the COVID-19 pandemic, several federal programs expanded UI
eligibility and increased UI benefits, including the Pandemic Unemployment
Assistance Program ("PUA"), Federal Pandemic Unemployment Compensation
("FPUC"), and the Lost Wages Assistance Program ("LWAP").
45. The Employment Security Department of Washington State ("ESD") was
the state agency that oversaw the UI program in Washington. Through this
agency, unemployment benefits could be issued to Washington residents who
were unemployed because of the COVID-19 pandemic. ESD received federal
funds to distribute in the form of unemployment benefits. In general, a person
seeking unemployment benefits through ESD had to complete an online
application that included, among other things, the claimant's name, date of birth,
Social Security number, and the reason that the claimant was unemployed. If
approved for unemployment benefits, the benefits were most often issued in the
form of a direct deposit into the claimant's designated bank account or
transferred to a prepaid debit card.
25
Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 26 of 29
46. On or about November 12, 2019, Defendant BLACK opened a business
bank account at LGE Community Credit Union ("LGE 1410"), in the name of
BlackFire.
47. Elvins Technology, Corp. ("Elvins") was a Florida corporation. On or
about August 19, 2019, articles of incorporation for Elvins were filed with the
Florida Secretary of State, identifying Defendant CONST ANT as the
incorpora tor.
48. On or about February 24, 2020, Defendant CONSTANT opened a business
bank account at CitiBank ("Citi 3877"), in the name of Elvins.
Purpose of the Conspiracy
49. A purpose of the conspiracy was for Defendants BLACK and CONSTANT
unlawfully to emich themselves and others by obtaining unemployment benefits
issued in the names of unknowing victims and based on fraudulent applications
submitted to ESD. Once the fraudulent unemployment benefits were deposited
into bank accounts that they controlled, Defendants BLACK and CONST ANT
conducted financial transactions involving the fraud proceeds, and did so in a
manner to conceal the nature, location, source, ownership, and control of the
proceeds.
Manner and Means
50. Defendants BLACK and CONST ANT and their co-conspirators used the
following manner and means to accomplish the purpose of the conspiracy:
26
Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 27 of 29
a. Between on or about May 6, 2020, and on or about May 19, 2020, UI
applications were electronically submitted to ESD using multiple
victims' personal identifying information, including their names, dates
of birth, and Social Security numbers, without the victims' knowledge
and authorization.
b. The applications directed ESD to deposit the unemployment benefits
into Citi 3877, in the name of Elvins and controlled by Defendant
. CONSTANT.
c. For example, on or about May 12, 2020, as a result of a fraudulent UI
application in the name of T.D., ESD deposited $10,710 into Citi 3877.
d . On the same day, Defendant CONSTANT wire transferred $9,500 to
LGE 1410, in the name of BlackFire and controlled by Defendant
BLACK.
e. On or about May 14, 2020, at a bank branch in the Northern District of
Georgia, Defendant BLACK withdrew approximately $14,290 in cash,
which included funds from the $9,500 wire transfer.
f. Defendants BLACK and CONSTANT concealed and disguised the
nature, location, source, ownership, and control of the fraud proceeds
by immediately transferring the proceeds between business bank
accounts and then quickly withdrawing the proceeds in cash.
g. Defendants BLACK and CONST ANT engaged in transactions in and
affecting interstate commerce, involving the movement of money by
27
Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 28 of 29
wire and other means, and involving the use of financial institutions
engaged in interstate commerce.
All in violation of Title 18, United States Code, Section 1956(h).
FORFEITURE PROVISION
51. Upon conviction for any of the offenses alleged in Counts 1 through 19 of
the Second Superseding Indictment, the Defendants, DAVID NATHANIEL
BLACK, JR., REGINALD DOUGLAS, CARSON MERICE, YVENORD
GUERILUS, NICOLE COOLEY, RISE ROBINSON, TARA BATSON, and MILAN
HAM, shall forfeit to the United States, pursuant to Title 18, United States Code,
Section 981(a)(l)(C) and Title 28, United States Code, Section 2461(c), any
property, real or personal, which constitutes or is derived from proceeds
traceable to the offense, including, but not limited to, a personal money
judgment equal to the amount of proceeds obtained as a result of the offense.
52. Upon conviction for any of the offenses alleged in Counts 39 to 156 of this
Second Superseding Indictment, the Defendants, DAVID NATHANIEL BLACK,
JR., CHRIS ELVINS CONSTANT, REGINALD DOUGLAS, GEORGE
THOMPSON, CARSON MERICE, YVENORD GUERILUS, NICOLE COOLEY,
RISE ROBINSON, TARA BATSON, MILAN HAM, and MATTHEW HOLMES,
shall forfeit to the United States, pursuant to Title 18, United States Code, Section
982(a)(1), any property, real or personal, involved in such offense, and any
property traceable to such property. The property to be forfeited includes, but is
28
Case 1:25-cr-00225-ELR-RGV Document 175 Filed 04/29/26 Page 29 of 29
not limited to, a money judgment representing the amount of property involved
in the offense.
53. If any of the above-described forfeitable property, as a result of any act or
omission of the Defendants: (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 which
cannot be divided without difficulty, it is the intent of the United States,
pursuant to Title 21, United States Code, Section 853(p ), as incorporated by Title
18, United States Code, Section 982(b)(l) and Title 28, United States Code, Section
2461(c), to seek forfeiture of any other
property of said Defendant up to the value of the forfeitable property described
above.
A BILL
~~
~
FOREPERSON
THEODORE S. H ERT ZBERG
nited States Attorney
, r _a;__
K ELL . CONNORS
A ssi ant United S tates Attorney
Georgia Bar No. 504787
600 U.S. Courthouse
75 Ted Turner Drive SW
Atlanta, GA 30303
404-581-6000; Fax: 404-581-6181
29
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