Indictment — No. 1:25-cr-00382 (Dkt. 5, N.D. Ill.)

Summary

A sealed indictment filed July 9, 2025 as Document 5 in United States v. George Kavroulakis, Athanasios Intzes, Adam Jaber, Hassan Kurdi and Abdallah Issa, No. 1:25-cr-00382, Northern District of Illinois, returned by the Special April 2024 Grand Jury. Counts One through Sixteen charge wire fraud under Title 18, United States Code, Section 1343, alleging that from around May 2020 through around August 2021 the defendants submitted dozens of PPP and EIDL applications with false employee, payroll, revenue and tax figures, and spent the proceeds on luxury vehicles and watches. Counts Seventeen through Twenty-Five allege a scheme by Kavroulakis, Jaber and Intzes from around April 2020 to at least around September 2021 to obtain Pandemic Unemployment Assistance funds through applications sent to IDES and CA EDD. Forfeiture allegations seek a money judgment, vehicles and a watch.

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Case: 1:25-cr-00382 *SEALED* Document #: 5 Filed: 07/09/25 Page 1 of 24 PagelD #30 wy

ILED

7/19/2025

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

UNITED STATES OF AMERICA Te INS

No. MAGISTRATE JUDGE VALDEZ

Vv. RANDOM/Cat.3

Violation: Title 18, United States
GEORGE KAVROULAKIS, Code, Section 1343
ATHANASIOS INTZES, a/k/a “Tommy,”
ADAM JABER,
HASSAN KURDI, and
ABDALLAH ISSA

COUNTS ONE THROUGH SIXTEEN
The SPECIAL APRIL 2024 GRAND JURY charges that:
1. At times material to this indictment:
The Small Business Administration
a. The U.S. Small Business Administration (“SBA”) was a United
States government agency that provided economic support to small businesses.
The Paycheck Protection Program
b. 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.
Cc. 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
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the Paycheck Protection Program (“PPP”). Congress subsequently authorized an
additional $465 billion in funding for PPP loans, for a total of about $814 billion.

d. 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
monthly payroll or gross income. These figures were used to calculate the applicant’s
eligibility and the amount of money the sole proprietor, self-employed individual, or
business could receive under the PPP. Applicants were also required to make good
faith certifications, including that the business entity was in operation on February
15, 2020, and that economic uncertainties had necessitated their loan requests for
continued business operations.

e. 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 through
loan service providers.

f. Businesses, sole proprietors, and self-employed individuals that

obtained PPP loans and used the full loan amount were allowed to obtain additional
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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
and average monthly payroll or gross income. 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.

g. 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 Social Security Number, payroll, income,
operating expenses, and how the PPP loan would be used, which information was
material to @) lenders’ approval, terms, and funding of loans and (ii) the SBA’s
decision to guarantee the loans.

The Economic Injury Disaster Loan Program
h. Another source of relief provided by the CARES Act and other

pandemic-relief legislation was the expansion of the Economic Injury Disaster Loan
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(““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.

i. 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.

j. 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,
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costs of goods sold, and gross revenues, which information was material to the SBA’s
approval, terms, and funding of loans.

k, EIDL funds were issued to small-business applicants directly
from the United States Treasury.

1. 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 loan. 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. The number of employees
reported by the business was material to the SBA’s funding of an EIDL Advance and
determination of the amount of the EIDL Advance. If an EIDL advance was issued,
the advance did not need to be repaid.

m. Ifan EIDL application was approved by the SBA, the amount of
the EIDL loan 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.

n. EIDL loan funds could be used to pay for the ordinary operating

expenses and debts of the entity, including payroll, sick leave, production costs,
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utilities, rent, mortgage payments, continuation of health care benefits, and fixed
debt payments.
Individuals

O. Defendant GEORGE KAVROULAKIS was a resident of the
Northern District of Illinois.

p. Defendant ATHANASIOS INTZES, a/k/a “Tommy,” was a
resident of the Northern District of Illinois. INTZES was the registered agent of
Thanasis Exotic Rentals Inc, which was incorporated in Illinois on or about August
10, 2020.

q. Defendant ADAM JABER was a resident of the Northern District
of Illinois. JABER was the registered agent of Jaber Wholesale, Inc., which was
incorporated in Illinois on or about August 14, 2020.

r. Defendant HASSAN KURDI was a resident of the Northern
District of Illinois.

8. Defendant ABDALLAH ISSA was a resident of the Northern
District of Illinois. ISSA was the registered agent of Second Road, Inc., which was
incorporated in Illinois on or about June 14, 2019.

Loan Service Providers

t. Bluevine Inc. was a financial technology company which

processed PPP applications on behalf of financial institutions, including Cross River

Bank.
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u. Blueacorn was a financial technology company which processed
PPP applications on behalf of financial institutions, including Capital Plus Financial

and Prestamos, CDFI, LCC.

Vv. Bluevine Inc. and Blueacorn are together, the “Loan Service
Providers.”
Lenders
w. Itria Ventures was a financial technology company which

processed PPP applications and funded PPP loans to approved borrowers.

x. Capital Plus Financial was a financial technology company which
processed PPP applications and funded PPP loans to approved borrowers.

y. Cross River Bank was a FDIC-insured financial institution which
funded PPP loans to approved borrowers.

Z. Prestamos CDFI, LLC was a community development financial
institution which funded PPP loans to approved borrowers.

aa. Itria Ventures, Capital Plus Financial, Cross River Bank, and
Prestamos CDFI, LLC are together, the “Lenders.”

The Scheme to Defraud
2. Beginning in or around May 2020 and continuing through in or around
August 2021, in the Northern District of Illinois, and elsewhere,
GEORGE KAVROULAKIS,
ATHANASIOS INTZES, a/k/a “Tommy,”

ADAM JABER,
HASSAN KURDI, and

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ABDALLAH ISSA,
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 EIDL
funds, by means of materially false and fraudulent pretenses, representations, and
promises, as further described below.

3. It was part of the scheme that defendants GEORGE KAVROULAKIS,
ATHANASIOS INTZES, a/k/a “Tommy,” ADAM JABER, HASSAN KURDI,
ABDALLAH ISSA, and others for the purpose of fraudulently obtaining millions of
dollars in PPP and EIDL funds, submitted, and caused to be submitted to Loan
Service Providers, Lenders, and the SBA, dozens of loans and advance applications
under the PPP and EIDL Programs, on behalf of businesses and entities purportedly
owned and operated by the defendants and others, including on behalf of purported
businesses and other entities, which defendants knew contained materially false
statements and misrepresentations concerning, among other things, the purported
entities’ number of employees, gross income, gross revenues, payroll, cost of goods
sold, operating expenses, type of business, and existence as companies with ongoing
operations.

4. It was further part of the scheme that defendants knowingly caused
false and fraudulent PPP and EIDL loan applications, and supporting

documentation, to be submitted on behalf of dozens of purported businesses and
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entities, which in some cases, defendants themselves purported to operate, including

the following:
a. GEORGE KAVROULAKIS, a purported sole proprietor;
b. ADAM JABER, a purported sole proprietor;
c. HASSAN KURDI, a purported sole proprietor;
d. ATHANASIOS INTZES, a purported sole proprietor;
e. Individual K.K., a purported sole proprietor;
f. Individual E.G., a purported sole proprietor;
g. Individual M.A., a purported sole proprietor;
h. Individual D.P., a purported sole proprietor;
i. Individual V.M., a purported sole proprietor;
j. Individual 8.M., a purported sole proprietor;
k. HASSAN KURDI, a purported independent contractor;
1. Individual S.C.-A., a purported self-employed individual;
m. Thanasis Exotic Rentals Inc;
n. Jaber Wholesale Inc.; and
Oo. Second Road Inc.
5. It was further part of the scheme that defendants solicited or caused to

be solicited other individuals’ personal identifying information, such as addresses,

birthdates, social security numbers, and bank account information, which

information defendants used to prepare and submit, and to cause others to prepare

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and submit, false and fraudulent PPP and EIDL applications and supporting
documents on behalf of those other individuals in exchange for a share of the
approved loans’ proceeds.

6. It was further part of the scheme that, in exchange for obtaining
fraudulent PPP and EIDL funds for other individuals, defendants knowingly
collected and caused others to collect, fees from those other individuals through,
among other things, peer-to-peer payment networks, including Zelle and Apple Cash.

7. It was further part of the scheme that defendants 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.

The PPP Loans

8. It was further part of the scheme that the defendants and others,
prepared and submitted, and caused to be prepared and submitted, to loan service
providers and lenders, including Loan Service Providers and the Lenders, PPP loan
applications on behalf of certain purported entities, in which applications the
defendants falsely and fraudulently represented that the purported entity was a
business that employed a specified number of employees, paid a specified average
monthly payroll, and was in operation on February 15, 2020, and that all PPP loan
proceeds would be used only for business related purposes. Defendants knew at the
time that those statements were false, that the purported entities had no income or

payroll and were not in operation on February 15, 2020, and that the defendants

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intended to use the loan funds for their personal use and benefit.

9. It was further part of the scheme that, to substantiate the number of
employees and payroll of the purported entities, the defendants prepared and
submitted, and caused to be prepared and submitted, to the Lenders and Loan Service
Providers copies of false IRS tax filings (including IRS Form 1040, Schedule C) that
fraudulently represented that the purported entities had earned income in the tax
year 2019. Defendants knew at the time that the purported entities had earned no
income for which federal taxes were paid during that period.

10. It was further part of the scheme that, through the submission of the
false and fraudulent PPP loan applications, defendants, and others, caused the
Lenders to disburse millions of dollars in PPP loan proceeds into bank accounts,
including bank accounts that the defendants controlled.

11. It was further part of the scheme that defendants, and others, used the
PPP funds that the Lenders disbursed based on the fraudulent PPP applications to
make cash withdrawals, to purchase goods and services, including luxury vehicles
and watches, and to transfer funds between various accounts that they controlled, all
for their personal use and benefit.

The EIDL Loans

12. It was further part of the scheme that the defendants prepared, and

submitted, and caused to be prepared to submitted to the SBA, numerous

applications for EIDL loans and advances on behalf of several of the purported

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entities in which applications they made false statements regarding the dates on
which those entities opened for business, the entities’ gross revenues and costs of
goods sold for the 12 months prior to January 31, 2020, and the number of employees
employed by those entities as of January 31, 2020.

13. It was further part of the scheme that defendants knowingly solicited
other individuals to take part in the scheme to fraudulently obtain EIDL loan funds.

14. It was further part of the scheme that, through the submission of the
false and fraudulent EIDL loan applications, defendants caused the SBA to disburse
approximately millions of dollars in EIDL loan proceeds into bank accounts, including
bank accounts that they controlled.

15. It was further part of the scheme that the defendants used the EIDL
funds obtained through their submission of fraudulent 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 purported entities.

16. Onor about the dates set forth below, in the Northern District of Illinois,
Eastern Division, and elsewhere, defendants, as set forth below, for the purpose of

executing the above-described scheme, knowingly caused to be transmitted by means

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of wire communication in interstate commerce certain writings, signs, and signals,

listed below, each constituting a separate count:

Count

Defendants

Date...

_ Description of Act .

One

GEORGE
KAVROULAKIS

July 14, 2020

an interstate wire transmission of
$10,000 from the SBA to a Byline
Bank account ending in 8773,
which funds represented the
proceeds of an EIDL advance to
the sole proprietorship in the
name of K.K.

Two

HASSAN KURDI

July 14, 2020

an interstate wire transmission of
$56,200 from the SBA to a
Huntington Bank account ending
in 8840, which funds represented
the proceeds of an EIDL to
independent contractor “HASSAN
KURDI”

Three

GEORGE
KAVROULAKIS

July 15, 2020

an interstate wire transmission of
approximately $20,100, from
Cross River Bank to a Discover
account ending in 4779, which
funds represented the proceeds of
a PPP loan to a sole
proprietorship in the name of
“GEORGE KAVROULAKIS”

Four

ATHANASIOS
INTZES, a/k/a
“Tommy,” and
GEORGE
KAVROULAKIS

September 9,
2020

an interstate wire transmission of
$114,900 from the SBA to a
PenFed account ending in 4021,
which funds represented the
proceeds of an EIDL to the S-
Corporation “Thanasis Exotic
Rentals Inc”

Five

ADAM JABER
and GEORGE
KAVROULAKIS

September 15,
2020

an interstate wire transmission of
$89,900 from the SBA to a BMO
Harris account ending in 8097,
which funds represented the
proceeds of an EIDL to the S-
Corporation “Jaber Wholesale
Inc.”

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Count Defendants |. -<Date_ . |. Description of Act
Six HASSAN KURDI | February 9, | an interstate wire transmission of
2021 approximately $20,185 from Cross

River Bank to a J.P. Morgan
Chase Bank account ending in
9631, which funds represented the
proceeds of a PPP loan to the self-
employed individual S.C.-A.
Seven ADAM JABER February 23, | an interstate wire transmission of
2021 approximately $20,312.50 from
Itria Ventures to a BMO Harris
account ending in 8097, which
funds represented the proceeds of
a PPP loan to a sole
proprietorship in the name of

“ADAM JABER”
Bight ADAM JABER February 24, | an interstate wire transmission of
2021 approximately $20,000 from Itria
Ventures to a BMO Harris

account ending in 1850, which
funds represented the proceeds of
a PPP loan to a sole
proprietorship in the name of E.G.
Nine HASSAN KURDI | February 24, | an interstate wire transmission of
2021 approximately $20,165 from Itria
Ventures to a Huntington Bank
account ending in 8840, which
funds represented the proceeds of
a PPP loan to a sole
proprietorship in the name of

“HASSAN KURDI”
Ten GEORGE March 10, | an interstate wire transmission of
KAVROULAKIS 2021 $20,187 from Itria Ventures to a

Chime bank account ending in
9741, which funds represented the
proceeds of a PPP loan to a sole
proprietorship in the name of
“GEORGE KAVROULAKIS”

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Count

‘Defendants

- Date

Description of Act

Eleven

ATHANASIOS
INTZES, a/k/a
“Tommy,” and
GEORGE
KAVROULAKIS

April 1, 2021

an interstate wire transmission of
approximately $20,207 from
Capital Plus Financial to a Chime
account ending in 7620, which
funds represented the proceeds of
a PPP loan to a sole
proprietorship in the name of
“ATHANASIOS INTZES”

Twelve

ABDALLAH ISSA

April 2, 2021

an interstate wire transmission of
$20,165 from Capital Plus
Financial to a Bluevine account
ending in 0954, which funds
represented the proceeds of a PPP
loan to a sole proprietorship in the
name of M.A.

Thirteen

ATHANASIOS
INTZES, a/k/a
“Tommy,” and
ABDALLAH ISSA

April 29, 2021

an interstate wire transmission of
approximately $20,165 from
Capital Plus Financial to a J.P.
Morgan Chase Bank account
ending in 2093, which funds
represented the proceeds of a PPP
loan to a sole proprietorship in the
name of D.P.

Fourteen

HASSAN KURDI

May 11, 2021

an interstate wire transmission of
$20,165 from Prestamos CDFI,
LLC to a Capital One, N.A. bank
account ending in 9098, which
funds represented the proceeds of
a PPP loan to a sole
proprietorship in the name of
“HASSAN KURDI”

Fifteen

ATHANASIOS
INTZES, a/k/a

“Tommy” and
ABDALLAH ISSA

May 13, 2021

an interstate wire transmission of
approximately $19,930 from Cross
River Bank to a J.P. Morgan
Chase Bank account ending in
7127, which funds represented the
proceeds of a PPP loan to a sole
proprietorship in the name of
V.M.

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Count . Defendants Date | _. Description of Act
Sixteen ABDALLAH ISSA | May 20, 2021 | an interstate wire transmission of
approximately $20,832 from
Capital Plus Financial to a J.P.
Morgan Chase Bank account
ending in 7094, which funds
represented the proceeds of a PPP
loan to “Second Road Inc”

In violation of Title 18, United States Code, Section 1343.

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COUNTS SEVENTEEN THROUGH TWENTY-FIVE
The SPECIAL APRIL 2024 GRAND JURY further charges:
17. Paragraphs 1(b), (0), (p), and (q) of Counts One through Sixteen are
incorporated here.
18. At times material to this indictment:
Pandemic Unemployment Assistance

a. In 1935, the federal Social Security Act established the dual
program of federal and state unemployment benefits. Under the Act, each state
administers its own unemployment program through their State Workforce Agency,
within the guidelines of federal law. The state unemployment benefits are financed
in part by state payroll taxes, which are held in trust by the United States Treasury’s
Federal Unemployment Trust Fund. During periods of high unemployment, the
federal government has also funded or augmented state unemployment benefits.

b. The CARES Act also expanded individual states’ ability to provide
assistance to workers impacted by COVID-19, including for workers who were not
ordinarily eligible for unemployment insurance benefits. One of the temporary
programs established by the CARES Act is Pandemic Unemployment Assistance
(“PUA”).

c. PUA provided for benefits to individuals who were: (1) self-
employed, seeking part-time employment, or otherwise would not qualify for regular

unemployment insurance or extended benefits under state or federal law or Pandemic

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Emergency Unemployment Compensation; and (2) unemployed, partially
unemployed, unable to work, or unavailable to work due to specific COVID-19 related
reason(s).

d. Under the PUA provisions of the CARES Act, business owners,
self-employed workers, independent contractors, and gig workers qualified for PUA
benefits administered by the State Workforce Agency if they previously performed
such work and were unemployed, partially unemployed, unable to work or
unavailable to work due to a COVID-19 related reason.

e. PUA claimants were required to answer specific questions related
to their eligibility, and to provide their name, Social Security Number, and mailing
address. Claimants were also required to self-certify that they met one of the COVID-
19 related reasons for being unemployed, partially unemployed, or unable or
unavailable to work.

f. The Illinois Department of Employment Security (“IDES”) was
the designated State Workforce Agency of the State of Illinois.

g. The California Employment Development Department (“CA
EDD”) was the designated State Workforce Agency of the State of California.

The Scheme to Defraud
19. Beginning in or around April 2020 and continuing through to at least in
or around September 2021, in the Northern District of Illinois, and elsewhere,

GEORGE KAVROULAKIS,
ADAM JABER, and

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ATHANASIOS INTZES, a/k/a “Tommy,”
defendants herein, knowingly devised, intended to devise, and participated in a
scheme to defraud, and to obtain money and property, in connection with applications
for PUA funds, by means of materially false and fraudulent pretenses,
representations, and promises, as further described below.

20. It was part of the scheme that defendants prepared and submitted, and
caused to be prepared and submitted, to the IDES applications for unemployment
insurance and PUA on behalf of themselves and others, which applications contained
materially false statements and misrepresentations, including that claimants had
recently worked for a specific employer and were unemployed as a result of the
COVID-19 pandemic. Defendants knew at the time that the claimants had not
recently worked for those employers and were not unemployed as a result of the
COVID-19 pandemic.

21. It was further part of the scheme that defendants prepared and
submitted, and caused to be prepared and submitted, to the CA EDD applications for
PUA on behalf of themselves and others, which applications contained materially
false statements and misrepresentations, including that claimants lived and had
worked in California and were unemployed as a result of the COVID-19 pandemic.
Defendants knew at the time that the claimants did not live and had not worked in

California and were not unemployed as a result of the COVID-19 pandemic.

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22. It was further part of the scheme that the defendants submitted and
caused to be submitted to the IDES and CA EDD fraudulent documents, including
fraudulent statements of earnings and false IRS Form 1040, Schedules C, knowing
that these documents were false and fraudulent.

23. It was further part of the scheme that, through the submission of the
false and fraudulent PUA applications, defendants caused the disbursement of more
than at least approximately $750,000 in PUA benefits to claimants who, as
defendants knew, were not entitled to such benefits.

24. It was further part of the scheme that the defendants caused the
disbursement of PUA benefits to bank accounts and debit cards that they controlled,
and used the funds for their personal use and benefit.

25. It was further part of the scheme that the defendants 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.

26. Onor about the dates set forth below, in the Northern District of Illinois,
Eastern Division, and elsewhere, defendants, as set forth below, for the purpose of
executing the above-described scheme, knowingly caused to be transmitted by means

of wire communication in interstate commerce certain writings, signs, and signals,

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namely, internet transmissions of applications for PUA funds, listed below, each

constituting a separate count:

Count

Defendants

Date

~ Description of Act

Seventeen

GEORGE
KAVROULAKIS

November 30,
2020

an internet transmission to IDES

of an application for PUA funds in
the name of E.G., through servers
located outside of Illinois

Eighteen

GEORGE
KAVROULAKIS

February 7,
2021

an internet transmission to IDES
of a fictitious statement of
earnings in support of continued
receipt of PUA funds in the name
of GEORGE KAVROULAKIS,
through servers located outside of

Nineteen

ATHANASIOS
INTZES, a/k/a
“Tommy” and
GEORGE
KAVROULAKIS

February 7,
2021

an internet transmission to IDES
of a fictitious statement of
earnings in support of continued
receipt of PUA funds in the name
of ATHANASIOS INTZES,
through servers located outside of
Illinois

Twenty

ADAM JABER

July 14, 2021

an internet transmission to CA
EDD of an application for PUA
funds in the name of ADAM
JABER, through servers located
outside of Illinois

Twenty-
One

ADAM JABER

August 6,
2021

an internet transmission to CA
EDD of an application for PUA
funds in the name of P.M.,
through servers located outside of

Twenty-
Two

ADAM JABER

August 6,
2021

an internet transmission to CA
EDD of an application for PUA
funds in the name of P.K.,
through servers located outside of
Illinois

21
Case: 1:25-cr-00382 *SEALED* Document #: 5 Filed: 07/09/25 Page 22 of 24 PagelD #:52

Count Defendants _ Date | _ Description of Act
Twenty- ADAM JABER August 6, an internet transmission to CA
Three 2021 EDD of an application for PUA

funds in the name of R.K.,
through servers located outside of
Illinois
Twenty- ADAM JABER August 12, an internet transmission to CA
Four 2021 EDD of an application for PUA

funds in the name of S.C.-A.,
through servers located outside of
Illinois

Twenty- ADAM JABER August 25, an internet transmission to CA
Five 2021 EDD of an application for PUA
funds in the name of T.S.F.,
through servers located outside of

In violation of Title 18, United States Code, Section 1348.

22
Case: 1:25-cr-00382 *SEALED* Document #: 5 Filed: 07/09/25 Page 23 of 24 PagelD #:53

FORFEITURE ALLEGATIONS

The SPECIAL APRIL 2024 GRAND JURY further alleges:

1. Upon conviction of an offense in violation of Title 18, United States Code,
Sections 1348 as set forth in this Indictment, defendants shall forfeit to the United
States of America any property which constitutes and is derived from proceeds
traceable to the offense, as provided in Title 18, United States Code, Section
981(a)(1)(C), and Title 28, United States Code, Section 2461(c).

2. The property to be forfeited includes, but is not limited to:

a. a personal money judgment in an amount equal to the proceeds
derived from the offenses in violation of Title 18, United States Code, Section 1343;

b. a White 2020 Mercedes-Benz G Class, VIN:
W1NYC7HJ9LX358346;

Cc. a White 2020 Mercedes-Benz G Class, VIN:
WINYC7HJXLX364558;

d. a White 2015 Mercedes-Benz S Class, VIN:
WDDUGS8FB5FA189239;

e. Rolex Submariner 41 mm Watch, Serial Number Z73929P3.

3. If any of the property described above, as a result of any act or omission
by a defendant: cannot be located upon the exercise of due diligence, has been
transferred or sold to, or deposited with, a third party, has been placed beyond the

jurisdiction of the Court; has been substantially diminished in value; or has been

23
Case: 1:25-cr-00382 *SEALED* Document #: 5 Filed: 07/09/25 Page 24 of 24 PagelD #:54

commingled with other property which cannot be divided without difficulty, the
United States of America shall be entitled to forfeiture of substitute property, as

provided in Title 21, United States Code, Section 853(p).

A TRUE BILL:
FOREPERSON
MICHELLE Digitally signed by MICHELLE
PETERSEN Date: 202507.09 1022:28-05100
Signed by MICHELLE PETERSEN, on behalf of the
UNITED STATES ATTORNEY

24


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