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First Superseding Indictment — United States v. David Nathaniel Black et al., Northern District of Georgia

Summary

A first superseding indictment in United States v. David Nathaniel Black, Jr., Chris Elvins Constant and others, No. 1:25-cr-00225, in the U.S. District Court for the Northern District of Georgia, filed July 22, 2025 as Document 8. It alleges that Black and others registered Companies 1 through 11 with the Georgia Secretary of State without the knowledge of their listed officers, opened bank accounts in their names and submitted EIDL and PPP applications using the officers' identities. The indictment states that the SBA and Lender 1 disbursed more than $9 million in loan proceeds. Counts 1 through 17 charge Black with wire fraud, Counts 18 through 34 with aggravated identity theft under 18 U.S.C. § 1028A, and Counts 35 through 140 charge money laundering. The 27-page indictment seeks forfeiture and is signed by Assistant United States Attorneys Kelly K. Connors and Sarah Klapman.

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“First 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-8-n-d-ga-7e6e52d8a0/, SHA-256 38b5a11013e9ede9c3aa610ff9cacfc89b06510e91b803bca72faeb24f908bae.

Full text

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 QORIGINAL

                                                                         FILED IN OPEN COURT
                 IN THE UNITED STATES DISTRICT COURT                          U.S.D.C. -Atlanta
                FOR THE NORTHERN DISTRICT OF GEORGIA
                          ATLANTA DIVISION                                    JUL 2 2 2025
                                                                      KEVI~ ~
                                                                         By   c:;v         R, Clerk
                                                                                        ueputy Clerk
   UNITED ST ATES OF AMERICA
                                              First 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,
   RASHAD AVERY,
   RISE ROBINSON, AND
   TARA BATSON


THE GRAND JURY CHARGES THAT:

                             COUNTS1THROUGH17
                                 (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 July 31, 2023, 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, knowingly devised, intended to devise, and 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,

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representations, and promises, and by the omission of material facts ("the wire

fraud scheme").

                                   Background
At times material to this First 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.

   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

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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

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.


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   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 from 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.

   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.


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   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.

                         Scheme and Artifice to Defraud

   18. As part of the scheme and artifice to defraud, between in or about

November 2020 and in or about June 2023, Defendant BLACK and others

registered and caused to be registered Companies 1 through 11 (" the

Companies") with the Georgia Secretary of State without the knowledge or

authorization of the company officers identified in Paragraphs 7 through 17.

Instead, the Georgia Secretary of State registration listed the person identified

below as a company officer:
                Companyl                               E.C.
                Company2                         RISE ROBINSON
                Company3                         NICOLE COOLEY
                Company4                         NICOLE COOLEY
                CompanyS                        CHRIS CONSTANT
                Company6                         CARSON MERICE
                Company?                          TARA BATSON
                Company8                       GEORGE THOMPSON
                Company9                       REGINALD DOUGLAS
                Companyl0                        RASHAD AVERY
                Companyll                      YVENORD GEURILIS

   19. After the Companies were registered in Georgia, between in or about

November 2020 and in or about June 2023, 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:

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            Bank Account               Name on Account            Signer
    SunTrust account ending 4219         Company 1                 E.C.
          ("SunTrust 4219")
    SunTrust account ending 7315            Company2         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")
           Bank of America                  Company6             CARSON
        account ending 3517                                      MERICE
             ("BOA 3517")

          Bank of America
        account ending 6087
            ("BOA 6087")
      JP Morgan Chase Bank                  Company?          TARA BATSON
        account ending 9572
           ("JPMC 9572")
   PNC Bank account ending 2677             Company8             GEORGE
            ("PNC 2677")                                        THOPSON
         First Citizens Bank                Company9            REGINALD
        account ending 4680                                     DOUGLAS
       ("First Citizens 4680")

   PNC Bank account ending 2227
          ("PNC 2227")
         Fifth Third Bank                   Companyl0        RASHAD AVERY
       account ending 1472
       ("Fifth Third 1472")




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             Truist account                  Companyll           YVENORD
             ending in 1028                                      GUERILUS
             ("Truist 1028")

         JP Morgan Chase Bank
         account ending in 6900
             ("JPMC 6900")



   20. To obtain loan proceeds that he was not entitled to receive, Defendant

BLACK electronically submitted and caused others to submit numerous EIDL

and PPP loan applications on behalf of Companies 1 through 11. Defendant

BLACK and others misrepresented that each application was filed by one of the

company officers identified in paragraphs 7 through 17 and, in doing so, used

the personal identification information for these officers. The applications were

submitted without the officers' knowledge.

   21. 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 .

   22. As a result of the misrepresentations in the EIDL and PPP loan

applications, the SBA and Lender 1 disbursed more than $9 million in loan

proceeds to the bank accounts identified in paragraph 19.


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                      Execution of the Wire Fraud Scheme

   23. On or about the dates set forth below, in the Northern District of Georgia

and elsewhere, the Defendant, DAVID NATHANIEL BLACK, JR., aided and

abetted by others known and unknown to the Grady 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

commerce the following wire transmissions described below, each transmission

constituting a separate count:


 COUNT           DATE                     WIRE COMMUNICATION
   1           11/04/2020        EIDL application for $150,000 electronically
                                 submitted to SBA for Company 1
     2         12/04/2020        EIDL application for $150,000 electronically
                                 submitted to SBA for Company 2
     3          1/22/2021        EIDL application for $150,000 electronically
                                 submitted to SBA for Company 3
     4          3/26/2021        PPP application for $148,500 electronically
                                 submitted to Lender 1 for Company 4
     5          4/13/2021        EIDL application for $494,800 electronically
                                 submitted to SBA for Company 4
     6          4/14/2021        PPP application for $221,300 electronically
                                 submitted to Lender 1 for Company 5
     7          7/27/2021        EIDL application for $486,500 electronically
                                 submitted to SBA for Company 6
     8          9/07/2021        EIDL application for $500,000 electronically
                                 submitted to SBA for Company 10
     9          9/09/2021        EIDL application for $498,800 electronically
                                 submitted to SBA for Company 7
    10          9/21/2021        EIDL application for $499,000 electronically
                                 submitted to SBA for Company 8
    11         10/03/2021        EIDL application for $458,300 electronically
                                 submitted to SBA for Company 9

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    12          1/03/2022         EIDL application for $629,100 electronically
                                  submitted to SBA for Company 8
    13          1/18/2022         EIDL application for $798,600 electronically
                                  submitted to SBA for Company 7
    14          1/18/2022         EIDL application for $1,492,600 electronically
                                  submitted to SBA for Company 6
    15          3/05/2022         EIDL application for $669,700 electronically
                                  submitted to SBA for Company 9
    16          3/05/2022         EIDL application for $872,000 electronically
                                  submitted to SBA for Company 9
    17          5/31/2023         EIDL application for $989,500 electronically
                                  submitted to SBA for Company 11
   All in violation of Title 18, United States Code, Sections 1343 and 2.

                              COUNTS18THROUGH34
                            (Aggravated Identity Theft)
                                (18 U.S.C. § 1028A)

   24. The Grand Jury re-alleges and incorporates by reference the factual

allegations set forth in paragraphs 2 through 22, as if fully set forth herein.

   25. From on or about November 4, 2020, and continuing through on or about

May 31, 2023, 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, 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
     18              G.E.                  Wire Fraud as alleged in Count 1
     19              J.P.                  Wire Fraud as alleged in Count 2
     20              E.D.                  Wire Fraud as alleged in Count 3
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      21             M.C.                 Wire Fraud as alleged in Count 4
      22             M.C.                 Wire Fraud as alleged in Count 5
      23             A.W.                 Wire Fraud as alleged in Count 6
      24             J.K.                 Wire Fraud as alleged in Count 7
      25             J.M.                 Wire Fraud as alleged in Count 8
      26              J.S.                Wire Fraud as alleged in Count 9
      27              J.B.                Wire Fraud as alleged in Count 10
      28             D.M.                 Wire Fraud as alleged in Count 11
      29              J.B.                Wire Fraud as alleged in Count 12
      30              J.S.                Wire Fraud as alleged in Count 13
      31             J.K.                 Wire Fraud as alleged in Count 14
      32             D.M.                 Wire Fraud as alleged in Count 15
      33             D.M.                 Wire Fraud as alleged in Count 16
      34             W.A.                 Wire Fraud as alleged in Count 17
      All in violation of Title 18, United States Code, Sections 1028A(a)(l) and 2.

                             COUNTS35THROUGH140
                              (Money Laundering)
                                (18 u.s.c. § 1957)

   26. The Grand Jury re-alleges and incorporates by reference the factual

allegations set forth in paragraphs 2 through 23, as if fully set forth herein.
                                    Background

At times material to this First Superseding Indictment:

   27. 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.

   28. 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.



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   29. 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.

   30. 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.

   31. 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.

   32. Vanguard business account ending in 1887 ("Vanguard 1887") was in the

name of BlackFire, and Defendant BLACK was the authorized signer on the

account.

   33. The Patent Trade Corporation ("Patent Trade") was a Georgia corporation.

On or about October 7, 2020, articles of incorporation for Patent Trade were filed

with the Georgia Secretary of State, identifying Defendant BLACK as the

incorpora tor.

   34. 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.

   35. Navy Federal Credit Union account ending in 4889 ("NFCU 4889") was in

the name of Defendant BLACK.




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   36. 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.

   37. 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

   38. 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                 JPMC9572
 10/18/2021         $499,900 EIDL for Company 10              Fifth Third 1472
 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                  PNC1019
  5/17/2022          $872,000 EIDL for Company 9                  PNC2227
  5/18/2022         $1,492,600 EIDL for Company 6                 BOA6087
  7/31/2023         $989,500 EIDL for Company 11                 Truist 1028

   39. 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

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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 First Superseding Indictment:


 COUNT DEFENDANT(S)    DATE        MONETARY TRANSACTION
   35      BLACK    11/25/2020 $58,000 wire transfer from
                                 SunTrust 4219 to Ameris 4062
   36      BLACK    12/ 14/ 2020 $12,000 cash withdrawal from
         ROBINSON                Truist 7315
   37      BLACK    12/ 14/2020 Purchase of $42,689.90 official
         ROBINSON                check from SunTrust 7315 issued to
                                 BlackFire
   38      BLACK     1/29/2021 $48,690 wire transfer from JPMC
          COOLEY                 6971 to Ameris 4062
   39      BLACK     1/29/2021 Purchase of $26,500 cashier's check
          COOLEY                 from JPMC 6971 issued to Patent
                                 Trade
   40      BLACK     4/23/2021 $39,781.77 wire transfer from Wells
          COOLEY                 Fargo 7224 to NFCU 4889
   41      BLACK     4/24/ 2021 Purchase of $34,468.23 cashier's
          COOLEY                 check from Wells Fargo 7224
                                 issued to Defendant BLACK
   42      BLACK     4/29/2021 $30,000 wire transfer from Wells
          COOLEY                 Fargo 7224 to PNC 4958, in the
                                 name of C.C.
   43      BLACK     5/06/2021 $44,908.52 wire transfer from Wells
          COOLEY                 Fargo 7224 to Citizens 2612
   44      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


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COUNT DEFENDANT(S)               DATE          MONETARY TRANSACTION
  45      BLACK                5/07/2021     Purchase of $40,766.50 cashier's
         COOLEY                              check from Wells Fargo 7224
                                             issued to Patent Trade
   46           BLACK          5/07/2021     Purchase of $26,000.98 from Wells
               COOLEY                        Fargo 7224 issued to Malcolm
                                             Cunningham Chevrolet
   47           BLACK          5/07/2021     Purchase of $42,889.76 cashier's
               COOLEY                        check from Wells Fargo 7224
                                             issued to Defendant BLACK
   48           BLACK          5/ 08/2021    Purchase of $40,345.50 cashier's
               COOLEY                        check from Wells Fargo 7224
                                             issued to Defendant BLACK
   49           BLACK          5/10/2021     $30,000 wire transfer from Wells
               COOLEY                        Fargo 7224 to Citizens 2612
   50           BLACK          5/ 10/ 2021   Purchase of $48,409.72 cashier's
               COOLEY                        check from Wells Fargo 7224
                                             issued to Defendant BLACK
   51          BLACK           6/15/ 2021    $13,300 cash withdrawal from Fifth
             CONSTANT                        Third 1824
   52          BLACK           6/ 15/2021    $38,560 cash withdrawal from Fifth
             CONSTANT                        Third 1824
   53          BLACK           6/ 15/2021    $45,616.14 wire transfer from Fifth
             CONSTANT                        Third 1824 to NFCU 4889
   54          BLACK           6/17/2021     $41,970.57 wire transfer from Fifth
             CONSTANT                        Third 1824 to NFCU 6927
   55          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
   56          BLACK           8/27/ 2021    $41,970.57 wire transfer from BOA
               MERICE                        3517 to NFCU 6927
   57          BLACK           8/ 27/ 2021   Purchase of $32,612.51 cashier's
               MERICE                        check from BOA 3517 issued to
                                             Defendant BLACK



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COUNT DEFENDANT(S)               DATE          MONETARY TRANSACTION
  58     BLACK                 8/ 27/2021    Purchase of $22,535 cashier's check
         MERICE                              from BOA 3517 issued to
                                             Defendant MERICE
   59          BLACK           8/30/2021     Purchase of $37,412.80 cashier's
               MERICE                        check from BOA 3517 issued to
                                             BlackFire Technologies Inc
   60          BLACK           8/30/2021     $98,799.22 wire transfer from BOA
               MERICE                        3517 to NFCU 3044
   61          BLACK           8/ 30/ 2021   Purchase of $42,604.83 cashier's
               MERICE                        check from BOA 3517 issued to De
                                             La Noire
   62          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
   63          BLACK           9/01/2021     $86,471.11 wire transfer from BOA
             CONSTANT                        3517 to Fifth Third 1824
              MERICE
   64          BLACK           9/ 01/2021    $11,530 ACH transfer from BOA
             CONSTANT                        3517 to BOA 7320
              MERICE
   65          BLACK           9/01/2021     $43,673.30 wire transfer from BOA
             CONSTANT                        3517 to Fifth Third 1824
              MERICE
   66          BLACK           9/ 07/ 2021   $13,848 ACH transfer from BOA
             CONSTANT                        3517 to BOA 7320
              MERICE
   67          BLACK           10/04/2021 Purchase of $64,764.07 cashier's
              BATSON                       check fromJPMC 9572 issued to De
                                           La Noire
   68           BLACK          10/ 13/2021 Purchase of $71,644.70 cashier's
               BATSON                      check from JPMC 9572 issue to De
                                           La Noire
   69           BLACK          10/ 13/2021 Purchase of $82,412.86 cashier's
               BATSON                      check from JPMC 9572 issued to
                                           BlackFire
   70           BLACK          10/14/2021 $17,500 cash withdrawal from
               BATSON                      JPMC9572

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COUNT DEFENDANT(S)   DATE                     MONETARY TRANSACTION
  71     BLACK     10/15/2021               $15,000 cash withdrawal from
         BATSON                             JPMC 9572
  72     BLACK     10/19/ 2021              $15,500 cash withdrawal from
         BATSON                             JPMC9572
  73      BLACK    10/ 19/2021              $41,970.57 wire transfer from Fifth
          AVERY                             Third 1472 to NFCU 6927

   74           BLACK         10/19/2021 Purchase of $32,604.83 cashier's
                AVERY                      check from Fifth Third 1472 issued
                                           to De La Noire
   75           BLACK         10/ 20/ 2021 $51,471.22 wire transfer from Fifth
                AVERY                      Third 1472 to NFCU 3044

   76           BLACK         10/20/2021 Purchase of $22,677.40 cashier' s
                AVERY                      check from Fifth Third 1472 issued
                                           to Defendant BLACK
   77           BLACK         10/ 20/ 2021 Purchase of $29,786.42 cashier's
                AVERY                      check from Fifth Third 1472 issued
                                           to Defendant AVERY
   78          BLACK          11/ 16/ 2021 $68,456.67 wire transfer from First
              DOUGLAS                      Citizens 4680 to Coastal 5594
   79          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
   80          BLACK          11/ 18/2021 $91,533.46 wire transfer from First
             CONSTANT                      Citizens 4680 to BOA 7320
             DOUGLAS
   81          BLACK          11/22/2021 $81,221.76 wire transfer from BOA
             CONSTANT                      7320 to Coastal 5594
   82          BLACK          11/ 22/ 2021 $70,173 wire transfer from First
             DOUGLAS                       Citizens 4680 to NFCU 3216
   83          BLACK          11/ 22/ 2021 $65,000 wire transfer from First
              DOUGLAS                      Citizens 4680 to NT Diamonds LLC
   84          BLACK          11/ 22/ 2021 $40,000 wire transfer from First
             DOUGLAS                       Citizens 4680 to NT Diamonds LLC


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COUNT DEFENDANT(S)    DATE                      MONETARY TRANSACTION
  85     BLACK     12/ 17/2021                $96,701.44 wire transfer from PNC
       CONSTANT                               2677 to BOA 7320
       THOMPSON
  86     BLACK     12/ 16/2021                $54,218.90 wire transfer from PNC
       THOMPSON                               2677 to Coastal 5594
  87     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
   88          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
   89          BLACK          12/21/2021      $91,686.98 wire transfer from PNC
             THOMPSON                         2677 to Coastal 5594
   90          BLACK          12/21/2021      $91,108.79 wire transfer from BOA
             CONSTANT                         7320 to Coastal 5594
   91          BLACK          12/ 30/ 2021    $83,561.89 wire transfer from PNC
             THOMPSON                         2677 to BOA 3589
   92          BLACK           1/ 26/ 2022    $164,201.92 wire transfer from PNC
             THOMPSON                         2677 to Coastal 5594
   93          BLACK           1/ 26/ 2022    $119,872.40 wire transfer from PNC
             THOMPSON                         2677 to Truist 7795
   94          BLACK           1/ 27/ 2022    $97,641.09 wire transfer from PNC
             CONSTANT                         2677 to BOA 7320
             THOMPSON
   95          BLACK           1/ 27/ 2022    $88,430.55 wire transfer from PNC
             THOMPSON                         2677 to BOA 3589
   96          BLACK           1/ 31 / 2022   $42,677.99 wire transfer from PNC
             CONSTANT                         2677 to JPMC 0680
             THOMPSON
   97          BLACK           1/ 31 / 2022   $90,776.14 wire transfer from BOA
             CONSTANT                         7320 to Coastal 5594
   98          BLACK           1/ 31 / 2022   $40,141.27 wire transfer from BOA
             CONSTANT                         JPMC 0680 to Coastal 5594

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COUNT DEFENDANT(S)               DATE          MONETARY TRANSACTION
  99     BLACK                 2/01/2022     $200,000 wire transfer from Coastal
                                             5594 to Paul Miller Auto Group for
                                             purchase of 2022 Bentley Bentayga
  100          BLACK           2/ 04/ 2022   $101,342.80 wire transfer from PNC
             THOMPSON                        2677 to Truist 7795
  101          BLACK           3/ 16/2022    $112,890.12 wire transfer from PNC
              DOUGLAS                        2227 to Coastal 5594
  102          BLACK           3/17/2022     $50,000 wire transfer from Coastal
                                             5594 to NT Diamonds LLC
  103          BLACK           3/ 17/ 2022   $121,904.72 wire transfer from PNC
             DOUGLAS                         2227 to NFCU 3216
  104          BLACK           3/ 17/ 2022   $89,417.50 wire transfer from PNC
             CONSTANT                        2227 to BOA 7320
             DOUGLAS
  105          BLACK           3/18/ 2022    $82,194.36 wire transfer from BOA
             CONSTANT                        7320 to Coastal 5594
  106          BLACK           3/ 21/ 2022   $88,632 wire transfer from PNC
             DOUGLAS                         2227 to NFCU 3216
  107          BLACK           3/ 24/ 2022   $20,000 wire transfer from PNC
             DOUGLAS                         2227 to PNC Bank account ending
                                             in 1521 ("PNC 1521"), in the name
                                             ofM.H.
  108          BLACK           3/ 24/ 2022   $40,000 wire transfer from PNC
             DOUGLAS                         2227 to NT Diamonds LLC
  109          BLACK           3/ 25/ 2022   $228,732.86 wire transfer from PNC
             CONSTANT                        1019 to Coastal 5594
  110          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
                                             Defendant AVERY
  111          BLACK           3/ 26/ 2022   Purchase of $27,000 cashier's check
               AVERY                         from PNC 4703 issued to
              COOLEY                         Defendant COOLEY
  112          BLACK           3/ 28/ 2022   $192,438.72 wire transfer from PNC
             CONSTANT                        1019 to BOA 7320



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COUNT DEFENDANT(S)   DATE                   MONETARY TRANSACTION
 113      BLACK    3/28/2022                $173,568.59 wire transfer from PNC
       CONSTANT                             1019 to BOA 6087
         MERICE
 114      BLACK    3/ 30/ 2022          $170,884.06 wire transfer from BOA
         MERICE                         6087 to Coastal 5594
 115      BLACK    3/30/2022            $176,803.70 wire transfer from PNC
        CONSTANT                        1019 to Coastal 5594
 116      BLACK    3/ 30/ 2022          $350,000 wire transfer from Coastal
                                        5594 to Motorcars of Georgia for
                                        purchase of 2020 McLaren 720S
                                        Convertible
  117          BLACK          4/05/2022 $133,412.43 wire transfer from PNC
             CONSTANT                   2227 to BOA 7320
             DOUGLAS
  118          BLACK          5/ 18/2022 $173,200.15 wire transfer from PNC
             DOUGLAS                      2227 to NFCU 3216
  119          BLACK          5/ 19/ 2022 $148,621.07 wire transfer from
             DOUGLAS                      NFCU 3216 to Ocean Auto Center
  120          BLACK          5/20/2022 $140,045 wire transfer from PNC
             DOUGLAS                      2227 to Coastal 5594
  121          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
   122         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
   123         BLACK          5/ 23/2022 $240,000 wire transfer from PNC
              DOUGLAS                     2227 to Coastal 5594
   124         BLACK          5/23/2022 $20,000 wire transfer from PNC 2227
              DOUGLAS                     to PNC 1521



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COUNT DEFENDANT(S)   DATE                MONETARY TRANSACTION
 125     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
  126          BLACK          5/ 26/2022 $268,211.09 wire transfer from BOA
              MERICE                     6087 to Coastal 5594
  127          BLACK          6/ 01/2022 $153,209.58 wire transfer from BOA
             CONSTANT                    6087 to JPMC 1823
              MERICE
  128          BLACK          6/03/2022 $173,619.18 wire transfer from BOA
              MERICE                      6087 to Coastal 5594
  129          BLACK          6/ 06/ 2022 $150,000 wire transfer from Coastal
                                          5594 to C.D.T., owner of NT
                                          Diamonds LLC
  130          BLACK          6/07/ 2022 $169,962.03 wire transfer from BOA
              MERICE                      6087 to Coastal 5594
  131          BLACK          7/01/2022 $122,309.19 wire transfer from BOA
             CONSTANT                     6087 to JPMC 0680
              MERICE
  132          BLACK          8/ 01 / 2023 $274,790.75 wire transfer from Truist
             GUERILUS                      1028 to Vanguard 1887
  133          BLACK          8/02/ 2023 $273,090 wire transfer from
                                           Vanguard 1887 to HSBC account
                                           ending in 0638 ("HSBC 0638"), in
                                           the name of Defendant BLACK
  134           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
  135           BLACK         8/02/ 2023 $180,645 wire transfer from HSBC
                                           8649 to Dayu Investments LLC for
                                           payment of rent for year 2023-2024
  136          BLACK          8/ 04/ 2023 $174,500 wire transfer from Truist
             CONSTANT                      1028 to JPMC 0680
             GUERILUS


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COUNT DEFENDANT(S)   DATE      MONETARY TRANSACTION
 137     BLACK     8/04/2023 $142,680 wire transfer from HSBC
                               0638 to PTG365 LLC for down
                               payment of 2023 Mercedes Benz G-
                               Class wagon
 138     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
 139     BLACK     8/ 10/ 2023 $100,000 wire transfer from Truist
        GUERILUS               1028 to JPMC 5705
         MERICE
 140     BLACK     8/ 17/2023 $72,688.15 wire transfer from Truist
        GUERILUS               1028 to JPMC 6900
   All in violation of Title 18, United States Code, Sections 1957 and 2.

                                   COUNT141
                         (Money Laundering Conspiracy)
                              (18 U.S.C. § 1956(h))

   40. The Grand Jury re-alleges and incorporates by reference the factual

allegations set forth in paragraph 27, as if fully set forth herein.

   41. 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,


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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).

                                    Background

At times material to this First Superseding Indictment:

   42. 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").

   43. 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

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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.

   44. 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.

   45. 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 CONSTANT as the

incorpora tor.

   46. 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

   47. A purpose of the conspiracy was for Defendants BLACK and CONST ANT

unlawfully to enrich 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



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manner to conceal the nature, location, source, ownership, and control of the

proceeds.

                                 Manner and Means

   48. Defendants BLACK and CONSTANT and their co-conspirators used the

following manner and means to accomplish the purpose of the conspiracy:

      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.




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      f. Defendants BLACK and CONST ANT 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 CONSTANT engaged in transactions in and

         affecting interstate commerce, involving the movement of money by

         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

   49. Upon conviction for any of the offenses alleged in Counts 1 through 17 of

the First Superseding Indictment, the Defendant, DAVID NATHANIEL BLACK,

JR., 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.

   50. Upon conviction for any of the offenses alleged in Counts 35 to 140 of this

First Superseding Indictment, the Defendants, DAVID NATHANIEL BLACK,

JR., CHRIS ELVINS CONSTANT, REGINALD DOUGLAS, GEORGE

THOMPSON, CARSON MERICE, YVENORD GUERILUS, NICOLE COOLEY,

RASHAD AVERY, RISE ROBINSON, and TARA BATSON, shall forfeit to the

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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 not limited to, a

money judgment representing the amount of property involved in the offense.

   51. 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)(1)




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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         -
                                                    lru c                     BILL




 THEODORE S. HERTZBERG
                                              /~~
  United States Attorney

  /s/ Kelly K. Connors
 KELLY K. CONNORS
  Assistant United States Attorney
 Georgia Bar No. 504787

/s/ Sarah Klapman
 SARAH KLAPMAN
  Assistant United States Attorney
 Georgia Bar No. 437221

 600 U.S. Courthouse
 75 Ted Turner Drive SW
 Atlanta, GA 30303
 404-581-6000; Fax: 404-581-6181




                                         27


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