Indictment — United States v. Dexter M. Crawford, Jr., et al., Northern District of Illinois (Document 1)
Summary
A sealed indictment filed June 26, 2025 as Document 1 in United States v. Dexter M. Crawford, Jr., Timika Royston, Orlando Patrick and Jermie Miller, Case 1:25-cr-00354, in the U.S. District Court for the Northern District of Illinois, Eastern Division, citing Title 18, United States Code, Sections 1343 and 1957(a). Counts One through Nine charge wire fraud, alleging that from about April 2020 through about August 2022 Crawford submitted PPP and EIDL applications for entities he controlled and helped the other defendants apply, with false employee, revenue and payroll figures. The grand jury charges schemes to obtain approximately $496,525 with Royston, approximately $860,823 with Patrick and approximately $633,796 with Miller. Later counts charge Crawford with monetary transactions including approximately $37,528 in Bitcoin, and Count Thirteen charges Miller over a $10,672 payment.
Summary drafted by a model from the text of the original file linked on this page and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Cite this document
“Indictment — United States v. Dexter M. Crawford, Jr., et al., Northern District of Illinois (Document 1).”
Original at www.justice.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-1-25-cr-00354-dkt-1-n-d-ill-30b071a865/
, SHA-256 938b6b8f8869147060a0b36a586f833d4002bc45b686c8425f26349bf3efff82.Full text
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 JUDGE HARJANI
Page 1 of 28 PageID #:1
ED
MAGISTRATE JUDGE KIM
FIL Random/Cat.3
6/2025
6/2
. BRUTO N UNITED STATES DISTRICT COURT 1:25-CR-00354
THOMA.SDG
IS T R IC T COURT NORTHERN DISTRICT OF ILLINOIS
CLERK, U.S
EASTERN DIVISION
UNITED STATES OF AMERICA No.
v. Violations: Title 18, United States
Code, Sections 1343 and 1957(a)
DEXTER M. CRAWFORD, JR.,
TIMIKA ROYSTON, UNDER SEAL
ORLANDO PATRICK, and
JERMIE MILLER,
COUNTS ONE THROUGH NINE
The SPECIAL JUNE 2024 GRAND JURY charges that:
1. At times material to this indictment:
Individuals and Entities
a. Defendant DEXTER M. CRAWFORD, JR. was a resident of
Woodbridge, Illinois, and was the president and owner of Agnize Incorporated, a
corporation incorporated under the laws of Illinois on or around September 25, 2014;
and was a manager of P & C Auto Group, LLC (“P&C Auto”), a limited liability
company formed under the laws of Illinois on or around June 22, 2016; and was a
manager of Prestigious Rental, LLC (“Prestigious Rental”), a limited liability
company formed under the laws of Illinois on or around May 26, 2016; and was a
president and owner of Annie B’s Bakery, Inc. (“Annie B’s Bakery”), a corporation
incorporated under the laws of Illinois on or around December 8, 2003; and was the
president and owner of Benevento Holdings Corp. (“Benevento Holdings”), a
corporation incorporated under the laws of Illinois on or around January 8, 2018; and
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 2 of 28 PageID #:2
was the manager, chief financial officer, and owner of Dexcorp Consulting LLC
(“Dexcorp Consulting”), a limited liability company formed under the laws of Colorado
on or around August 17, 2008.
b. Defendant TIMIKA ROYSTON was a resident of Chicago,
Illinois, and was the owner and president of THR Lifestyle Consultants, Inc. (“THR
Lifestyle”), a corporation incorporated under the laws of Illinois on or around August
18, 2015.
c. Defendant ORLANDO PATRICK was a resident of Chicago,
Illinois, and was the president and owner of Patrick Capital Group, Inc. (“Patrick
Capital Group”), a corporation incorporated under the laws of Illinois on or around
January 31, 2011, and was the organizer of Patrick Development Group, LLC
(“Patrick Development”), a limited liability company organized under the laws of
Missouri on or around June 9, 2010; and was a manager of P & C Auto.
d. Defendant JERMIE MILLER was a resident of Plainfield,
Illinois, and was the owner and manager of M-Fast LLC (“M-Fast”), a limited liability
company formed under the laws of Illinois on or around July 3, 2019.
e. Certoza Solutions LLC (“Certoza Solutions”) was a limited
liability company formed under the laws of Illinois on or around January 2, 2018.
2
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 3 of 28 PageID #:3
The Small Business Administration
f. The U.S. Small Business Administration (“SBA”) was a United
States government agency that provided economic support to small businesses.
The Paycheck Protection Program
g. The Coronavirus Aid, Relief, and Economic Security (“CARES”)
Act was a federal law enacted in or around March 2020 and designed to provide
emergency financial assistance to the millions of Americans who were suffering the
economic effects caused by the COVID-19 pandemic.
h. One source of relief provided by the CARES Act was the
authorization of up to $349 billion in forgivable loans to small businesses and sole
proprietors for job retention and certain other expenses, through a program called
the Paycheck Protection Program (“PPP”). Congress subsequently authorized an
additional $465 billion in funding for PPP loans, for a total of about $814 billion.
i. To obtain a PPP loan, a business, sole proprietor, or self-employed
individual submitted a PPP loan application, which was signed by the applicant or
an authorized representative of the business. The PPP loan application required the
applicants to acknowledge the program rules and make certain affirmative
certifications regarding the eligibility of the business, proprietorship, or individual.
In the application, businesses, sole proprietors, and self-employed individuals were
required to provide, among other things, their number of employees and average
3
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 4 of 28 PageID #:4
monthly payroll. This figure was used to calculate the applicant’s eligibility and the
amount of money the business could receive under the PPP. Applicants were also
required to make good faith certifications, including that that the business entity was
in operation on February 15, 2020, and that economic uncertainties had necessitated
their loan requests for continued business operations.
j. The PPP allowed the interest and principal on the PPP loan to be
entirely forgiven by the SBA if the business, sole proprietorship, or self-employed
individual spent the loan proceeds on certain expenses within a designated period of
time and used at least a certain percentage of the PPP loan for payroll expenses.
k. To gain access to funds through the PPP, businesses, sole
proprietorships, and self-employed individuals applied to lenders participating in the
PPP and, if approved, received the loans from those lenders, either directly or
thorough loan service providers.
l. Businesses, sole proprietors, and self-employed individuals that
obtained PPP loans and used the full loan amount were allowed to obtain additional
funds through the PPP by submitting a Second Draw Borrower Application Form
(“Second Draw Application”), which was signed by the applicant or an authorized
representative of the business. The Second Draw Application required the applicants
to again acknowledge the program rules and make certain affirmative certifications
regarding the eligibility of the business, and again provide their number of employees
4
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 5 of 28 PageID #:5
and average monthly payroll. These figures were again used to calculate the
applicant’s eligibility and the amount of money the business could receive under the
PPP. Applicants were again required to make good faith certifications, including that
economic uncertainties had necessitated their loan requests for continued business
operations and that the applicants had used the full amount of the initial PPP loan
only for eligible expenses.
m. Participating lenders, loan service providers, and the SBA
required applicants for PPP loans to provide truthful information about the sole
proprietorship, self-employed individual, or business and its owner, including
truthful information about the applicant’s payroll, income, operating expenses, and
how the PPP loan would be used, which information was material to (i) lenders’
approval, terms, and funding of loans and (ii) the SBA’s decision to guarantee and to
forgive the loans.
The Economic Injury Disaster Loan Program
n. Another source of relief provided by the CARES Act and other
pandemic-relief legislation was the expansion of the Economic Injury Disaster Loan
(“EIDL”) Program, which provided loan assistance (including advances of up to
$10,000) for businesses with 500 or fewer employees and other eligible entities. The
EIDL Program was designed to provide economic relief to small businesses that were
experiencing a temporary loss of revenue.
5
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 6 of 28 PageID #:6
o. To gain access to funds through the EIDL Program, small
businesses applied through the SBA via an online portal and application. As part of
the EIDL application process, the SBA required applicants to submit truthful
information about the applying entity, its owner, and its financial condition prior to
the COVID-19 pandemic. This information included the entity’s number of employees
as of January 31, 2020; the entity’s gross revenues and cost of goods sold for the 12-
month period prior to January 31, 2020; and the entity’s type of business (i.e., a
business, an agricultural business, a sole proprietorship, a cooperative, among
others); the date on which the business opened; and the date on which the current
owner assumed ownership of the entity. Applicants were required to electronically
certify that the information provided in the application was true and correct and were
warned that a false statement or misrepresentation to the SBA may result in
sanctions, including criminal penalties.
p. The SBA required applicants for EIDL loans to provide truthful
information about the sole proprietorship, self-employed individual, or business and
its owner, including truthful information about the applicant’s number of employees,
costs of goods sold, and gross revenues, which information was material to the SBA’s
approval, terms, and funding of loans.
6
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 7 of 28 PageID #:7
q. EIDL funds were issued to small-business applicants directly
from the United States Treasury.
r. EIDL Advance was a grant program offered together with the
EIDL Program. EIDL Advance was designed to provide emergency economic relief to
businesses that were experiencing a temporary loss of revenue as a result of the
COVID-19 pandemic. The applicant could request consideration for an EIDL advance
in an application for an EIDL. The amount of the advance issued to the small-
business applicant was determined by the number of employees indicated on the
EIDL application, at $1,000 per employee, up to $10,000. If an EIDL advance was
issued, the advance did not need to be repaid.
s. If an EIDL application was approved by the SBA, the amount of
the EIDL was determined in part based on the statements in the EIDL application
about the entity’s revenues and cost of goods sold for the 12 months prior to January
31, 2020.
t. EIDL Program loan funds could be used to pay for the ordinary
operating expenses and debts of the entity, including payroll, sick leave, production
costs, utilities, rent, mortgage payments, continuation of health care benefits, and
fixed debt payments.
7
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 8 of 28 PageID #:8
Financial Institutions and Lenders
u. American Airlines Credit Union (“AACU”) was a financial
institution with a branch in Chicago, Illinois, the deposit accounts of which were
insured by the National Credit Union Administration Board.
v. Bank of America was a financial institution with branches in
Chicago, Illinois, the deposit accounts of which were insured by the Federal Deposit
Insurance Corporation.
w. BMO Harris Bank was a financial institution which funded PPP
loans to approved borrowers. The deposit accounts of BMO Harris Bank were insured
by the Federal Deposit Insurance Corporation.
x. Capital One Bank (“Capital One”) was a financial institution with
branches in Chicago, Illinois, the deposit accounts of which were insured by the
Federal Deposit Insurance Corporation.
y. Customers Bank was a financial institution which funded PPP
loans to approved borrowers. The deposit accounts of Customers Bank were insured
by the Federal Deposit Insurance Corporation.
z. International Bank of Chicago (“IBOC”) was a financial
institution with branches in Chicago, Illinois, the deposit accounts of which were
insured by the Federal Deposit Insurance Corporation.
8
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 9 of 28 PageID #:9
aa. Kabbage, Inc. was an approved SBA non-bank lender that offered
PPP loans directly and also facilitated loans on behalf of Cross River Bank.
bb. Lakeside Bank was a financial institution with branches in
Chicago, Illinois, the deposit accounts of which were insured by the Federal Deposit
Insurance Corporation.
cc. Navy Federal Credit Union (“NFCU”) was a financial institution,
the deposit accounts of which were insured by the National Credit Union
Administration Board.
dd. JPMorgan Chase Bank, N.A. (“Chase Bank”) was a financial
institution with branches in Chicago, Illinois, the deposit accounts of which were
insured by the Federal Deposit Insurance Corporation.
ee. U.S. Bank was a financial institution with branches in Chicago,
Illinois, the deposit accounts of which were insured by the Federal Deposit Insurance
Corporation.
Electronic Signatures
ff. Docusign was an electronic signature and document management
platform that allowed users to send and electronically sign documents using a
computer or other electronic device.
9
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 10 of 28 PageID #:10
The Scheme to Defraud
2. Beginning in or around April 2020 and continuing through in or around
August 2022, in the Northern District of Illinois, Eastern Division, and elsewhere,
DEXTER M. CRAWFORD, JR.,
TIMIKA ROYSTON
ORLANDO PATRICK, and
JERMIE MILLER
defendants herein, together with others known and unknown to the Grand Jury,
knowingly devised, intended to devise, and participated in a scheme to defraud, and
to obtain money and property, in connection with applications for PPP and loans
submitted to lenders, and EIDLs submitted to the SBA, by means of materially false
and fraudulent pretenses, representations, and promises, which scheme affected a
financial institution, as further described below.
3. It was part of the scheme that CRAWFORD, for the purpose of
fraudulently obtaining and attempting to obtain PPP and EIDL funds, submitted
applications for loans and advances under the PPP and EIDL program on behalf of
entities that he controlled, and he assisted others, including ROYSTON, PATRICK,
and MILLER in fraudulently obtaining and attempting to obtain PPP and EIDL
funds through applications for loans and advances under the PPP and EIDL program
on behalf of entities that they controlled, which applications contained materially
false statements and misrepresentations concerning, among other things, the
entities’ number of employees, gross income, gross revenues, payroll, cost of goods
10
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 11 of 28 PageID #:11
sold, and operating expenses.
4. It was part of the scheme that CRAWFORD and ROYSTON, for the
purpose of fraudulently obtaining approximately $496,525 in PPP loan and EIDL
funds, submitted and caused to be submitted not fewer than four applications for
loans and advances under the PPP and EIDL Programs, on behalf of THR Lifestyle
Consultants and Certoza Solutions, which applications contained materially false
statements and misrepresentations concerning, among other things, the entities’
number of employees, gross income, gross revenues, payroll, cost of goods sold, and
operating expenses.
5. It was part of the scheme that CRAWFORD and PATRICK, for the
purpose of fraudulently obtaining approximately $860,823 in PPP loan funds,
submitted and caused to be submitted not fewer than two applications for loans under
the PPP Program, on behalf of Patrick Capital Group and Patrick Development,
which applications contained materially false statements and misrepresentations
concerning, among other things, the entities’ number of employees and average
monthly payroll.
6. It was part of the scheme that CRAWFORD and MILLER, for the
purpose of fraudulently obtaining approximately $633,796 in PPP loan funds,
submitted and caused to be submitted an application for a loan under the PPP
Program on behalf of M-Fast, which application contained materially false
11
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 12 of 28 PageID #:12
statements and misrepresentations concerning, among other things, the entity’s
number of employees and average monthly payroll.
7. It was part of the scheme that CRAWFORD, for the purpose of
fraudulently obtaining approximately $833,222 in PPP loan and EIDL funds, and
attempting to obtain a further EIDL funds, submitted and caused to be submitted not
fewer than eight applications for loans and advances under the PPP and EIDL
Programs, on behalf of Prestigious Rental, Annie B’s Bakery, Benevento Holdings,
Agnize, Dexcorp Consulting, and P&C Auto, which applications contained materially
false statements and misrepresentations concerning, among other things, the
entities’ number of employees, gross income, gross revenues, payroll, cost of goods
sold, and operating expenses.
THR Lifestyle First Draw PPP Loan
8. It was further part of the scheme that on or around May 5, 2020,
CRAWFORD and ROYSTON submitted and caused to be submitted to BMO Harris
Bank a PPP loan application on behalf of THR Lifestyle in the amount of $88,362.50,
knowing that the application contained false and fraudulent representations
regarding: (a) THR Lifestyle’s number of employees; (b) THR Lifestyle’s average
monthly payroll; and (c) the truthfulness and accuracy of the application and
supporting documents.
9. It was further part of the scheme that, in order to obtain a PPP loan,
12
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 13 of 28 PageID #:13
CRAWFORD and ROYSTON prepared and submitted to BMO Harris Bank a PPP
loan application for THR Lifestyle which falsely represented that THR Lifestyle had
six employees with an average monthly payroll of $35,345, and submitted a
fraudulent Form 1120 tax return for the tax year 2018 that falsely represented that
THR Lifestyle had paid wages and salaries of $424,150.
10. It was further part of the scheme that, through the submission of the
false and fraudulent PPP loan application, CRAWFORD and ROYSTON caused BMO
Harris Bank to disburse a PPP loan in the amount of $88,362.50 into an account at
BMO Harris Bank ending in 0325 (“BMO 0325 Account”) controlled by ROYSTON,
when, as CRAWFORD and ROYSTON knew, neither they nor THR Lifestyle were
entitled to the PPP loan funds.
Prestigious Rental EIDL
11. It was further part of the scheme that on or about June 16, 2020,
CRAWFORD submitted and caused to be submitted to the SBA an EIDL application
on behalf of Prestigious Rental seeking a loan and advance, knowing that the
application contained false and fraudulent representations regarding (a) Prestigious
Rental’s number of employees; (b) Prestigious Rental’s gross receipts and costs of
goods sold; (c) Prestigious Rental’s lost rents; and (d) the truthfulness and accuracy
of the application.
12. It was further part of the scheme that in order to obtain the EIDL and
13
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 14 of 28 PageID #:14
advance, CRAWFORD prepared the loan application falsely representing that for the
12 months ending January 1, 2020, Prestigious Rental had Gross Revenues of
$1,437,354, Cost of Goods of $192,887, and 92 employees as of that date, and
CRAWFORD certified in the Loan Authorization and Agreement that all
representations in the loan application were true, correct, and complete.
13. It was further part of the scheme that, through the submission of the
false and fraudulent EIDL application, CRAWFORD caused the SBA to disburse a
loan and advance totaling $159,900 into an account ending in 5815 that CRAWFORD
maintained and controlled at AACU (the “AACU 5815 Account”), when, as
CRAWFORD knew, neither he nor Prestigious Rental was entitled to the EIDL funds.
EIDL Applications file for Annie B’s Bakery, Benevento Holdings Corp.,
Agnize Incorporated, Dexcorp Consulting, and P&C Auto
14. It was further part of the scheme that on or about June 17, 2020,
CRAWFORD submitted and caused to be submitted to the SBA EIDL applications on
behalf of Annie B’s Bakery, Benevento Holdings Corp., Agnize Incorporated, Dexcorp
Consulting, and P&C Auto, seeking a loan and advance for each of the entities,
knowing that each application contained false and fraudulent representations
regarding (a) the entity’s number of employees; (b) the entity’s gross receipts and
costs of goods sold; and (c) the truthfulness and accuracy of the application.
15. It was further part of the scheme that, through the submission of the
false and fraudulent EIDL applications on behalf of Annie B’s Bakery, Benevento
14
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 15 of 28 PageID #:15
Holdings Corp., Agnize Incorporated, Dexcorp Consulting, and P&C Auto,
CRAWFORD attempted to cause the SBA to approve a loan and advance for each
entity, when, as CRAWFORD knew, neither he nor any of the entity applicants were
entitled to the EIDL funds.
16. It was further part of the scheme that, after the SBA denied the EIDL
applications filed on behalf of Annie B’s Bakery, Benevento Holdings Corp., Agnize
Incorporated, Dexcorp Consulting, and P&C Auto, CRAWFORD contacted the SBA
and sought reconsideration of SBA’s denial of the EIDL applications.
17. It was further part of the scheme that, on or around August 15, 2020,
CRAWFORD contacted Individual B and requested that Individual B prepare a
fraudulent 2019 Form 1120 tax returns for Annie B’s Bakery, Benevento Holdings
Corp., Agnize Incorporated, Dexcorp Consulting, and P&C Auto, reflecting false
revenues that were not realized and expenses that were not incurred, and Individual
B thereafter prepared the fraudulent return and delivered them to CRAWFORD who,
in turn, submitted the fraudulent 2019 Form 1120 tax returns to the SBA in an
attempt to cause the SBA to approve a loan and advance for each of the applicant
entities.
THR Lifestyle EIDL
18. It was further part of the scheme that on or about June 19, 2020,
CRAWFORD and ROYSTON submitted and caused to be submitted to the SBA an
15
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 16 of 28 PageID #:16
EIDL application on behalf of THR Lifestyle, knowing that the application contained
false and fraudulent representations regarding (a) THR Lifestyle’s number of
employees; (b) THR Lifestyle’s gross receipts and costs of goods sold; and (c) the
truthfulness and accuracy of the application.
19. It was further part of the scheme that in order to obtain the EIDL and
advance, CRAWFORD prepared the loan application falsely representing that for the
12 months ending January 1, 2020, THR Lifestyle had Gross Receipts of $1,473,893,
Cost of Goods of $673,920, and 38 employees as of that date, and ROYSTON certified
in the Loan Authorization and Agreement that all representations in the loan
application were true, correct, and complete.
20. It was further part of the scheme that on or around June 26, 2020,
ROYSTON advised CRAWFORD that she had spoken with an SBA employee and
learned that the application had not been approved because it listed the AACU 5815
Account which was tied to multiple other entities’ applications. ROYSTON falsely
told the SBA that her husband mistakenly listed the account when helping her to
complete the EIDL application.
21. It was further part of the scheme that, on or around, July 6, 2020,
CRAWFORD caused ROYSTON to be added as a joint owner of the AACU 5815
Account.
22. It was further part of the scheme that, through the submission of the
16
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 17 of 28 PageID #:17
false and fraudulent EIDL application, CRAWFORD and ROYSTON caused the SBA
to disburse a loan and advance totaling $159,900 into AACU 5815 Account, when, as
CRAWFORD and ROYSTON knew, neither they nor THR Lifestyle were entitled to
the EIDL funds.
Patrick Capital Group First Draw PPP Loan
23. It was further part of the scheme that on or around June 25, 2020,
PATRICK submitted and caused to be submitted to Kabbage a PPP loan application
on behalf of Patrick Capital Group in the amount of $187,501, knowing that the
application contained false and fraudulent representations regarding: (a) Patrick
Capital Group’s number of employees; (b) Patrick Capital Group’s average monthly
payroll; and (c) the truthfulness and accuracy of the application and supporting
documents.
24. It was further part of the scheme that, in order to obtain a PPP loan,
PATRICK prepared and submitted to Kabbage a PPP loan application for Patrick
Capital Group which falsely represented that Patrick Capital Group had 12
employees with an average monthly payroll of $75,001, and submitted a fraudulent
Form W-3 for Patrick Capital Group, which falsely reported that Patrick Capital
Group had issued 12 Forms W-2 for 2019 reflecting total wages of $900,000 paid that
year.
25. It was further part of the scheme that PATRICK informed CRAWFORD
17
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 18 of 28 PageID #:18
as to the submission of the PPP loan application for Patrick Capital Group, and the
identity of the account into which the proceeds were to be disbursed, in an attempt to
evade detection by using a different account for loan disbursement for a PPP loan
that was being sought for Patrick Development.
26. It was further part of the scheme that, through the submission of the
false and fraudulent PPP loan application, PATRICK caused Kabbage to disburse a
PPP loan in the amount of $187,501 into an account controlled by PATRICK at
Lakeside Bank ending in 0052, when, as PATRICK knew, neither he nor Patrick
Capital Group were entitled to the PPP loan funds.
Patrick Development First Draw PPP Loan
27. It was further part of the scheme that on or around June 26, 2020,
CRAWFORD and PATRICK submitted and caused to be submitted to Kabbage a PPP
loan application on behalf of Patrick Development in the amount of $673,322,
knowing that the application contained false and fraudulent representations
regarding: (a) Patrick Development’s number of employees; (b) Patrick Development’s
average monthly payroll; and (c) the truthfulness and accuracy of the application and
supporting documents.
28. It was further part of the scheme that, in order to obtain a PPP loan,
CRAWFORD prepared and submitted to Kabbage a PPP loan application for Patrick
Development which falsely represented that Patrick Development had 33 employees
18
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 19 of 28 PageID #:19
with an average monthly payroll of $269,329, and in support of the fraudulent
application, submitted copies of false IRS and IDOR tax filings (including IRS Forms
W3, 940, and 941, and Illinois Form IL-941) that fraudulently represented that
Patrick Development had paid specified numbers of employees various amounts in
wages, tips, and other compensation in tax years 2019 and 2020.
29. It was further part of the scheme that, in order to obtain a PPP loan,
CRAWFORD advised PATRICK that a bank account other than PATRICK’s existing
account at Lakeside Bank would be needed, and that an account could quickly be
opened with Capital One. On or around June 25, 2020, PATRICK opened an account
ending in 9775 at Capital One (“Capital One 9775 Account”) and provided the account
and routing number to CRAWFORD for inclusion on the Patrick Development PPP
loan application.
30. It was further part of the scheme that, through the submission of the
false and fraudulent PPP loan application, CRAWFORD and PATRICK caused
Kabbage to disburse a PPP loan in the amount of $673,322 into the Capital One 9775
Account, when, as CRAWFORD and PATRICK knew, neither they nor Patrick
Development were entitled to the PPP loan funds.
P&C Auto First Draw PPP Loan
31. It was further part of the scheme that on or around June 29, 2020,
CRAWFORD submitted and caused to be submitted to Kabbage a PPP loan
19
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 20 of 28 PageID #:20
application on behalf of P&C Auto in the amount of $673,322, knowing that the
application contained false and fraudulent representations regarding: (a) P&C Auto’s
number of employees; (b) P&C Auto’s average monthly payroll; and (c) the
truthfulness and accuracy of the application and supporting documents.
32. It was further part of the scheme that, in order to obtain a PPP loan,
CRAWFORD prepared and submitted to Kabbage a PPP loan application for P&C
Auto which falsely represented that P&C Auto had 33 employees with an average
monthly payroll of $269,329, and in support of the fraudulent application, submitted
copies of false IRS and IDOR tax filings (including IRS Forms W3, 940, and 941, and
Form IL-941) that fraudulently represented that P&C Auto had paid specified
numbers of employees various amounts in wages, tips, and other compensation in tax
years 2019 and 2020.
33. It was further part of the scheme that, through the submission of the
false and fraudulent PPP loan application, CRAWFORD caused Kabbage to disburse
a PPP loan in the amount of $673,322 into an account controlled by CRAWFORD at
IBOC ending in 2875 (“IBOC 2875 Account”), when, as CRAWFORD knew, neither
he nor P&C Auto were entitled to the PPP loan funds.
Certoza Solutions EIDL
34. It was further part of the scheme that on or about July 21, 2020,
CRAWFORD and ROYSTON submitted and caused to be submitted the SBA an EIDL
20
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 21 of 28 PageID #:21
application on behalf of Certoza Solutions, knowing that the application contained
false and fraudulent representations regarding (a) Certoza Solutions’ number of
employees; (b) Certoza Solutions’ gross receipts, costs of goods sold, and lost rents; (c)
the ownership history of Certoza Solutions; and (d) the truthfulness and accuracy of
the application.
35. It was further part of the scheme that in order to obtain the EIDL and
advance, CRAWFORD prepared the loan application falsely representing that
ROYSTON had owned Certoza Solutions since January 2, 2018, and that for the 12
months ending January 1, 2020, Certoza Solutions had Gross Revenues of $1,432,354,
Cost of Goods of $756,430, Lost Rents of $42,600, and 17 employees as of that date.
ROYSTON certified in the Loan Authorization and Agreement that all
representations in the loan application were true, correct, and complete.
36. It was further part of the scheme that on or about June 1, 2020,
CRAWFORD and ROYSTON agreed to purchase the Certoza Solutions entity and
split the cost between them.
37. It was further part of the scheme that on or about June 2, 2020,
CRAWFORD purchased an internet domain for Certoza Solutions and set up an email
address for the entity and provided the password to ROYSTON.
38. It was further part of the scheme that on or about June 23, 2020, while
CRAWFORD and ROYSTON were awaiting documentation for Certoza Solutions
21
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 22 of 28 PageID #:22
from the seller, CRAWFORD asked ROYSTON to call the seller, Attorney A, to inform
that she and CRAWFORD had purchased Certoza Solutions but had not heard back
from the seller.
39. It was further part of the scheme that on or around July 18, 2020,
ROYSTON caused a business checking account ending in 8169 to be opened for
Certoza Solutions at U.S. Bank (the “USB 8169 Account”).
40. It was further part of the scheme that, through the submission of the
false and fraudulent EIDL application, CRAWFORD and ROYSTON caused the SBA
to disburse a loan and advance totaling $159,900 into the USB 8169 Account that
ROYSTON maintained and controlled, when, as CRAWFORD and ROYSTON knew,
neither they nor Certoza Solutions were entitled to the EIDL funds.
M-Fast PPP Loan
41. It was further part of the scheme that on or around January 25, 2021,
CRAWFORD and MILLER submitted and caused to be submitted to Customers Bank
a PPP loan application on behalf of M-Fast in the amount of $633,796, knowing that
the application contained false and fraudulent representations regarding: (a) M-
Fast’s number of employees; (b) M-Fast’s average monthly payroll; and (c) the
truthfulness and accuracy of the application and supporting documents.
42. It was further part of the scheme that, in order to obtain a PPP loan,
CRAWFORD prepared and submitted to Customers Bank a PPP loan application for
22
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 23 of 28 PageID #:23
M-Fast which falsely represented that M-Fast had 33 employees with an average
monthly payroll of $253,518, and submitted a fraudulent ADP report that falsely
represented that M-Fast employed 33 individuals throughout 2020 and paid total
wages of $3,042,216.87 for the year.
43. It was further part of the scheme that CRAWFORD and MILLER
devised how to, and did, recruit individuals who allowed their identities to be used
for creation of records reflecting employment with, and wages received from, M-Fast,
when, in reality, the individuals were not employed by M-Fast and had not received
the wages reflected in the records created.
44. It was further part of the scheme that, through the submission of the
false and fraudulent PPP loan application, CRAWFORD and MILLER caused
Customers Bank to disburse a PPP loan in the amount of $633,796 into an account
MILLER controlled at NFCU ending in 1990 (the “NFCU 1990 Account”), when, as
CRAWFORD and MILLER knew, neither they nor M-Fast were entitled to the PPP
loan funds.
45. It was further part of the scheme that on or around August 1, 2022,
CRAWFORD and MILLER caused to be submitted to Customers Bank a fraudulent
PPP Loan Forgiveness Application Form on behalf of M-Fast, which application
falsely represented that (a) M-Fast had 25 employees at the time of the PPP loan and
at the time of submission of the PPP Loan Forgiveness Application Form; (b) that
23
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 24 of 28 PageID #:24
between February 24, 2021, and July 29, 2021, M-Fast had incurred payroll costs of
$767,588.88; and (c) that the $633,796 for which forgiveness was requested was used
to pay business costs eligible for forgiveness.
THR Lifestyle Second Draw PPP Loan
46. It was further part of the scheme that on or around January 28, 2021,
CRAWFORD and ROYSTON submitted and caused to be submitted to BMO Harris
Bank a second-draw PPP loan application on behalf of THR Lifestyle in the amount
of $88,362.50, knowing that the application contained false and fraudulent
representations regarding: (a) THR Lifestyle’s number of employees; (b) THR
Lifestyle’s average monthly payroll; and (c) the truthfulness and accuracy of the
application and supporting documents.
47. It was further part of the scheme that, in order to obtain a PPP loan,
CRAWFORD and ROYSTON prepared and submitted to BMO Harris Bank a PPP
loan application for THR Lifestyle which falsely represented that THR Lifestyle had
six employees with an average monthly payroll of $35,345.
48. It was further part of the scheme that, through the submission of the
false and fraudulent PPP loan application, CRAWFORD and ROYSTON caused BMO
Harris Bank to disburse a PPP loan in the amount of $88,362.50 into the BMO 0325
Account, when, as CRAWFORD and ROYSTON knew, neither they nor THR Lifestyle
were entitled to the PPP loan funds.
24
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 25 of 28 PageID #:25
49. It was further part of the scheme that CRAWFORD, ROYSTEN,
PATRICK, and MILLER used the PPP and EIDL funds obtained through their
submission of fraudulent PPP and EIDL applications to make cash withdrawals and
transfers, all for their personal use and benefit, and not for purposes related to the
business of the entities.
50. It was further part of the scheme that CRAWFORD, ROYSTEN,
PATRICK, and MILLER misrepresented, concealed, and hid, and caused to be
misrepresented, concealed, and hidden, the existence and purpose of the scheme and
the acts done in furtherance of the scheme.
51. On or about the dates set forth below, in the Northern District of Illinois,
Eastern Division, and elsewhere, defendants DEXTER M. CRAWFORD, Jr., TIMIKA
ROYSTON, ORLANDO PATRICK, and JERMIE MILLER, as set forth below, for the
purpose of executing the above-described scheme, knowingly caused to be transmitted
by means of wire communication in interstate or foreign commerce certain writings,
signs, and signals, listed below, each such writing, sign, and signal constituting a
separate count:
Count Defendant(s) Date Description of Act
1 DEXTER M. May 5, 2020 The transmission in foreign
CRAWFORD, Jr. commerce of a Docusign envelope
and for the THR Lifestyle PPP
TIMIKA ROYSTON application
25
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 26 of 28 PageID #:26
Count Defendant(s) Date Description of Act
2 DEXTER M. June 23, 2020 An interstate transfer of
CRAWFORD, Jr. approximately $149,900 to fund an
EIDL approved for Prestigious
Rental
3 ORLANDO PATRICK June 30, 2020 An interstate transfer of
approximately $187,501 to fund a
PPP loan approved for Patrick
Capital Group
4 DEXTER M. June 30, 2020 An interstate transfer of
CRAWFORD, Jr. approximately $673,322 to fund a
and PPP loan approved for Patrick
ORLANDO PATRICK Development
5 DEXTER M. July 2, 2020 An interstate transfer of
CRAWFORD, Jr. approximately $673,322 to fund a
PPP loan approved for P&C Auto
6 DEXTER M. July 6, 2020 An interstate transfer of
CRAWFORD, Jr. approximately $149,900 to fund an
and EIDL approved for THR Lifestyle
TIMIKA ROYSTON
7 DEXTER M. August 11, An interstate transfer of
CRAWFORD, Jr. 2020 approximately $149,900 to fund an
EIDL approved for Certoza
TIMIKA ROYSTON Solutions
8 DEXTER M. February 24, An interstate transfer of
CRAWFORD, Jr. 2021 approximately $633,796 to fund a
and PPP loan approved for M-Fast
JERMIE
MILLER
9 DEXTER M. January 28, The transmission in foreign
CRAWFORD, Jr. 2021 commerce of a Docusign envelope
and for a PPP application in the name
TIMIKA ROYSTON of THR Lifestyle
In violation of Title 18, United States Code, Section 1343.
26
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 27 of 28 PageID #:27
COUNTS TEN THROUGH TWELVE
The SPECIAL JUNE 2024 GRAND JURY further charges:
On or about the dates set forth below, in the Northern District of Illinois,
Eastern Division, and elsewhere,
DEXTER M. CRAWFORD, Jr.,
defendant herein, did knowingly engage and attempt to engage in a monetary
transaction affecting interstate or foreign commerce and involving criminally derived
property of a value greater than $10,000, in the manner described by count below,
such property having been derived from specified unlawful activity, namely, wire
fraud, in violation of Title 18, United States Code, Section 1343:
Count Date Financial Transaction
10 July 21, 2020 Purchase of Cashier’s Check 041503 in the amount
of $12,500 with funds drawn from the IBOC 2875
Account to purchase a 2017 Honda Accord
11 August 5, 2020 Purchase of approximately 3.17724955 Bitcoins for
approximately $37,528 in BitStamp account held by
defendant
12 April 1, 2021 Purchase of Cashier’s Check 66138654 in the
amount of $39,000 with funds drawn from account
ending in 7995 at BMO Harris Bank to purchase a
2016 Cadillac Escalade
All in violation of Title 18, United States Code, Section 1957(a).
27
Case: 1:25-cr-00354 *SEALED* Document #: 1 Filed: 06/26/25 Page 28 of 28 PageID #:28
COUNT THIRTEEN
The SPECIAL JUNE 2024 GRAND JURY further charges:
On or about April 28, 2021, in the Northern District of Illinois, Eastern
Division, and elsewhere,
JERMIE MILLER,
defendant herein, did knowingly engage and attempt to engage in a monetary
transaction affecting interstate or foreign commerce and involving criminally derived
property of a value greater than $10,000, that is, funds paid from the NFCU 1990
Account to Kole Digital in the amount of $10,672, such property having been derived
from specified unlawful activity, namely, wire fraud, in violation of Title 18, United
States Code, Section 1343:
All in violation of Title 18, United States Code, Section 1957(a).
A TRUE BILL:
FOREPERSON
______________________________
Signed by Michelle Petersen, on behalf of the
UNITED STATES ATTORNEY
28
File and source
- File
- 1-indictment.pdf
- Size
- 330,967 bytes
- SHA-256
- 938b6b8f8869147060a0b36a586f833d4002bc45b686c8425f26349bf3efff82
- Our copy
- 1-indictment.pdf
- Original
- www.justice.gov