Indictment — United States v. Williams et al., Western District of Washington (Document 1)

Summary

A grand jury indictment in United States v. Williams et al., Case No. 2:23-cr-00090-JHC, in the U.S. District Court for the Western District of Washington, filed May 31, 2023 as Document 1, against Paradise Shaw Dreia Williams, Darius Akim Jackson, Jahri Asad Cunningham, Tia Janee Robinson, Rayvon Darnell Peterson and David Jesus Martinez. Counts 1-19 charge wire fraud. The indictment alleges that from about June 2020 until February 2022 the defendants fraudulently sought more than $6.8 million and obtained more than $3.3 million from COVID-19 relief programs, including Emergency Rental Assistance through King County's EPRAP, PPP, EIDL and state unemployment benefits. It alleges that Williams orchestrated the scheme and created fake bank statements, and that proceeds went to luxury cars, trips, jewelry and designer goods. The indictment includes forfeiture allegations.

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Case 2:23-cr-00090-JHC Documenti1 Filed 05/31/23 Page 1 of 23

Presented to the Court by the foreman of the
Grand Jury in open Court, in the presence of
the Grand Jury and FILED in the US.
DISTRICT COURT at Seattle, Washington.

May 31

oR ‘you ian, Clerk
By. Deputy

UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

UNITED STATES OF AMERICA,

Plaintiff

Vv

. PARADISE SHAW DREIA WILLIAMS

aka Shaw Williams
aka Shirley Williams,

. DARIUS AKIM JACKSON

aka Akim Jackson,

. JAHRI ASAD CUNNINGHAM

aka Ale Cartel
aka Ale Cartell
aka Minah Cunning,

. TIA JANEE ROBINSON,
. RAYVON DARNELL PETERSON, and
. DAVID JESUS MARTINEZ.

Defendants.

The Grand Jury charges that:

Indictment - 1
United States v. Williams et al.
USAO No. 2021R00479

no. CR23-090 JHC

INDICTMENT

UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 2:23-cr-00090-JHC Document1 Filed 05/31/23 Page 2 of 23

COUNTS 1-19
(Wire Fraud)

A. Overview

1. From about June 2020 until February 2022, Defendants PARADISE
SHAW DREIA WILLIAMS, D’ARIUS AKIM JACKSON, JAHRI ASAD
CUNNINGHAM, TIA JANEE ROBINSON, RAYVON DARNELL PETERSON,
DAVID JESUS MARTINEZ, and others known and unknown to the Grand Jury,
fraudulently sought more than $6.8 million, and obtained more than $3.3 million, from
various federally-funded COVID-19 pandemic relief programs. They used the funds
intended to assist individuals and businesses suffering from the economic impacts of the
pandemic for extravagant expenses such as luxury cars, lavish trips, cosmetic surgery,
jewelry, and designer goods.

2. Defendants’ scheme targeted the following COVID-19 pandemic relief
programs: U.S. Department of Treasury’s Emergency Rental Assistance program
administered through Washington State grant programs and King County Eviction
Prevention and Rental Assistance Program (EPRAP); the Paycheck Protection Program
(PPP) administered by the U.S. Small Business Administration (SBA); the Economic
Injury Disaster Loan (EIDL) Program administered by SBA; and federally-funded
COVID-19 unemployment benefits administered through various state workforce
agencies, including those in California, South Carolina, and Nevada.

3. WILLIAMS orchestrated the scheme and artifice to defraud. WILLIAMS,
JACKSON, CUNNINGHAM, ROBINSON, and PETERSON, used their own identities,
including numerous aliases and the identities of others, to submit multiple fraudulent
applications to various programs. WILLIAMS, JACKSON, ROBINSON, and
PETERSON received kickback payments for fraudulently obtained benefits.

WILLIAMS created and submitted fake bank statements and other documents to support

Indictment - 2 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
Case 2:23-cr-00090-JHC Document1 Filed 05/31/23 Page 3 of 23

the fraudulent applications she and her associates submitted. WILLIAMS, and others,
also created, used, and maintained multiple email accounts, sometimes using alias names,
to perpetuate the fraudulent scheme. Upon receipt of the fraudulent proceeds, the
Defendants quickly laundered the funds through cash withdrawals, wire transfers, and
expensive purchases.

B. Background

4. Emergency Rental Assistance. In response to millions of Americans
facing deep rental debt, fear of evictions, and the loss of basic housing security as a result
of the COVID-19 pandemic, the U.S. Department of Treasury’s Emergency Rental
Assistance program provided funding directly to state and local governments to assist
households that were unable to pay rent or utilities. From March 2021 through 2022,
Treasury’s Emergency Rental Assistance program allocated over $900 million to
Washington State and local governments, including King County. The Washington
Department of Commerce received and administered the state’s federal funds by
providing grants to county governments and non-profit organizations to support the
homeless crisis response systems in the state. In King County, the Department of
Community and Human Services distributed over $300 million in direct federal funds and
state grants to approximately 30,000 King County households through EPRAP. Non-
Profit Organization 1, which is based in Seattle, also received over $5 million in
federally-funded rental assistance grants from the Washington Department of Commerce
and distributed the funds to approximately 700 households.

5. To qualify for rental assistance, the household must have been low-income,
experiencing financial hardship due to the COVID-19 pandemic, and been at risk of
experiencing homelessness or currently experiencing housing instability. Tenants and
landlords could receive up to 12 months of rental assistance (nine months back or current

rent and three months advance). The administering agencies acknowledged that there

Indictment - 3 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
NY Dn WN BP Ww NYO KF OD O FHF NI Dn FP WY NY YF OC

Case 2:23-cr-00090-JHC Documenti1 Filed 05/31/23 Page 4 of 23

was insufficient funding to help every household who qualified, thus, the screening
criteria was intended to target those most likely to become homeless but for the
assistance.

6. At all times relevant to this Indictment, in King County, a landlord could
initiate an application for EPRAP assistance by submitting a delinquent tenant’s
information, and the tenant and landlord could submit self-attestation forms to document
eligibility. Landlords were also required to submit W-9 forms and, upon request,
evidence of a lease or ledger. After EPRAP calculated the final assistance amount,
landlords received an EPRAP agreement by email that they were required to sign and
return via DocuSign using interstate wire transmissions. The agreement certified that the
signee was authorized to accept the emergency rental assistance payment in satisfaction
of rent owed by a tenant.

7. King County initiated payment of the EPRAP funds by using an interstate
wire to upload payment information to a bank server located outside Washington State.
EPRAP funds were disbursed to landlords via checks or ACH payments using interstate
wire transmissions.

8. Non-Profit Organization 1 followed a similar application process for
distributing rental assistance to community members by requiring a Rent Payment
Agreement signed by the landlord and tenant and a W-9 from the landlord. Applicants
also submitted ledgers and leases. In at least some cases, assistance was disbursed by
check to the landlords.

9. Paycheck Protection Program. PPP was a COVID-19 pandemic relief
program administered by SBA that provided forgivable loans to small businesses for job
retention and certain other expenses. The PPP permitted participating third-party lenders
to approve and disburse SBA-backed PPP loans to cover payroll, fixed debts, utilities,

rent/mortgage, accounts payable and other bills incurred by qualifying businesses during

Indictment - 4 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
DO KPO NYO NYO HN KN RO NO

Case 2:23-cr-00090-JHC Documenti1 Filed 05/31/23 Page 5 of 23

and resulting from the COVID-19 pandemic. PPP loans were fully guaranteed by the
SBA. In the event of default, SBA will fully satisfy the lender for any balance remaining
on the loan. Further, SBA will forgive any loan up to 100 percent if the borrower uses
the funds for specified purposes.

10. To obtain a PPP loan, a qualifying business, which included certain sole
proprietorships, had to submit a PPP loan application, which was signed by an authorized
representative of the business. The PPP loan application required the business (through
its authorized representative) to acknowledge the program rules and make certain
affirmative certifications to be eligible to obtain the PPP loan, including that the business
was in operation on February 15, 2020 and either had employees for whom it paid
salaries and payroll taxes or paid independent contractors. A business applying for a PPP
loan was required to provide documentation showing its payroll expenses, such as filed
federal income tax documents.

11. Individuals who operated a business under a “‘sole proprietorship” business
structure were also eligible fora PPP loan. To qualify for such a PPP loan, individuals
had to report and document their income and expenses from the sole proprietorship, as
typically reported to the Internal Revenue Service on a “Form 1040, Schedule C,” for a
given tax year. As with other PPP loans, this information and supporting documentation
was used to calculate the amount of money the individual was entitled to receive under
the PPP. The maximum loan amount for a sole proprietorship with no employees was
approximately $20,833.

12. Atall times relevant to this Indictment, PPP loan documents were
electronically submitted or caused to be submitted by the borrower to a third-party lender
service provider, which did not have any servers in Washington State. The borrower
signed the loan documents using DocuSign, which has servers within and outside

Washington State, and data for a single customer could reside in multiple locations. The

Indictment - 5 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
Case 2:23-cr-00090-JHC Documenti1 Filed 05/31/23 Page 6 of 23

third-party lender service provider accessed the signed loan documents and caused those
documents to be sent to a third-party lender that did not have any servers located within
Washington State. Therefore, every PPP loan document relevant to this Indictment and
initiated online from Washington State, resulted in an interstate wire communication that
originated in Washington State and traveled to another state.

13. | Once approved, the business received the PPP loan proceeds via an
electronic funds transfer from the third-party lender to a financial account under the
control of the business. The proceeds of a PPP loan could be used for certain specified
items, such as payroll costs, costs related to the continuation of group health care
benefits, or mortgage interest payments. The proceeds of a PPP loan were not permitted
to be used by the borrowers to purchase consumer goods, automobiles, personal
residences, clothing, jewelry, to pay the borrower’s personal federal income taxes, or to
fund the borrower’s ordinary day-to-day living expenses unrelated to the specified
authorized expenses.

14. Economic Injury Disaster Loan Program. SBA also administers the EIDL
Program, which provides low-interest financing to small businesses and non-profit
organizations in regions affected by declared disasters. In March 2020, the Coronavirus
Aid, Relief, and Economic Security (CARES) Act authorized the SBA to provide EIDLs
of up to $2 million to eligible small businesses experiencing substantial financial
disruption due to the COVID-19 pandemic. The CARES Act and subsequent legislation
also authorized the SBA to issue advances of up to $10,000 to small businesses within
three days of applying for an EIDL. EIDL Advances did not have to be repaid. EIDL
funds can be used for payroll expenses, sick leave, production costs, and business
obligations, such as debts, rent, and mortgage payments.

15. A qualifying business, which could include sole proprietorships, that

applied for an EIDL had to submit an application to the SBA and provide information

Indictment - 6 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
Case 2:23-cr-00090-JHC Documenti1 Filed 05/31/23 Page 7 of 23

about its operations, such as the number of employees, gross revenues for the 12-month
period preceding the disaster, and cost of goods sold in the 12-month period preceding
the disaster. The applicant had to certify that all of the information in the application was
true and correct to the best of the applicant’s knowledge.

16. Applicants submitted EIDL applications online directly to the SBA for
processing. SBA directly disbursed EIDL funds to an account identified by the applicant.
In all instances relevant to this Indictment, when an applicant submitted an COVID-19
EIDL application online, SBA received it at a server outside Washington State.
Therefore, every COVID-19 EIDL application relevant to this Indictment and submitted
online from Washington State, resulted in an interstate wire communication that
originated in Washington State and traveled to another state.

17. COVID-19 Unemployment Benefits. The CARES Act also provided
federal funding to expand unemployment benefits eligibility and increased benefits,
including the Pandemic Unemployment Assistance Program (PUA), Federal Pandemic
Unemployment Compensation (FPUC), and the Lost Wages Assistance Program
(LWAP). These benefits were administered through a joint state and federal program that
provided monetary benefits to eligible beneficiaries. Unemployment benefits were
intended to provide temporary financial assistance to lawful workers who were
unemployed through no fault of their own.

18. CARES Act unemployment benefits were funded by the United States
government through the Department of Labor and administered at the state level by state
agencies known as state workforce agencies. Generally, applicants could submit
applications for benefits online to state workforce agencies. Applicants had to answer
specific questions to establish eligibility to receive benefits, including their name, social

security number, and mailing address, among other things. Applicants also had to self-

Indictment - 7 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
Case 2:23-cr-00090-JHC Document1 Filed 05/31/23 Page 8 of 23

certify that they met a COVID-19-related reason for being unemployed, partially
employed, or unable to work.

19. Emergency Rental Assistance, EIDL, PPP funds, and CARES Act
unemployment benefits were authorized, transferred, disbursed, and paid in connection
with a nationwide emergency declared by Presidential Proclamation 9994 (effective as of
March 1, 2020) and a Presidential declaration of a major disaster for the State of
Washington concerning the COVID-19 pandemic that was issued on March 22, 2020.

C. The Scheme and Artifice to Defraud

20. Beginning on or about April 4, 2020, and continuing until at least on or
about February 11, 2022, in King County, within the Western District of Washington,
and elsewhere, Defendants PARADISE SHAW DREIJA WILLIAMS, D’ ARIUS AKIM
JACKSON, JAHRI ASAD CUNNINGHAM, TIA JANEE ROBINSON, DAVID JESUS
MARTINEZ, and others, knowingly devised a scheme and artifice to defraud and to
obtain money and property by means of false and fraudulent pretenses and
representations and the concealment of material facts.

21. The essence of the scheme and artifice to defraud was to fraudulently
obtain federally-funded pandemic-related benefits and assistance by submitting
fraudulent applications, documents, and/or claims to administrating government agencies
and financial institutions and/or lenders. The scheme and artifice to defraud occurred in
relation to, and involved, benefit payments authorized, transmitted, transferred,
disbursed, and paid in connection with a presidentially-declared major disaster and
emergency.

D. Manner and Means

The following conduct was part of the scheme and artifice to defraud:

22. Emergency Rental Assistance. WILLIAMS directed her associates,
including JACKSON, CUNNINGHAM, ROBINSON, PETERSON, MARTINEZ, and

Indictment - 8 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
Case 2:23-cr-00090-JHC Document1 Filed 05/31/23 Page 9 of 23

others to use their true identities and aliases, to pose fraudulently as landlords for
property located within King County, and to obtain rental assistance for non-existent
tenants. Defendants created and used multiple email accounts and Voice over Internet
Protocol (VoIP) phone numbers in furtherance of the scheme. Defendants created and
used fake rental agreements, ledgers, and other documents to support the fraudulent
applications. Defendants impersonated and directed others to impersonate fictitious
tenants and landlords when EPRAP staff contacted them by phone, text, or email. At all
times relevant to this Indictment, the owners of the King County properties listed on the
ERPAP applications were owned by individuals or entities who were not the Defendants
or their aliases. In fact, none of the Defendants owned any property in King County, nor
were they the tenants they impersonated. WILLIAMS, ROBINSON, and PETERSON
received kickback payments for applications they submitted on behalf of other fictitious
landlords. MARTINEZ, and others, paid WILLIAMS kickbacks for the applications she
submitted using their identities.

23. For example, on or about September 27, 2021, WILLIAMS instructed
MARTINEZ how to impersonate a landlord on a fraudulent EPRAP application she

submitted and discussed the kickback payment she expected:

Sender Text Message

| just gave this place your number
WILLIAMS | Your my landlord lol

Behind 6 months

Lol I’ll give you 3k lol

[REDACTED ADDRESS] Seattle WA 98178
Rent is 2200

MARTINEZ, And next month is coming up on the 5th lol & so really 7 months

Yeah and they pay 3 months ahead
WILLIAMS a?

So that’s 10 months
MARTINEZ La @

Yeah lol
WILLIAMS
That’s 22,000 | need 5k minimum lol
MARTINEZ S
Indictment - 9 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
Case 2:23-cr-00090-JHC Document1 Filed 05/31/23 Page 10 of 23

WILLIAMS Lol | got you free bands lol

Lol when did you say rent is due

3rd
WILLIAMS | They won't ask that tho
Just for your email

h

This is your email

WILLIAMS | (Email Address 1]

No
MARTINEZ | REDACTED EMAIL ADDRESS]

Use that one | sent you lol
WILLIAMS | have that one from last time

Oh ok coo
MARTINEZ _| (i give them that email

24. Approximately one week after the texts, on or about October 4, 2021,
MARTINEZ’s business checking account received $21,450 in EPRAP funds for a
fictitious tenant named Laura Johnson who allegedly lived at the Seattle address
referenced in the communications.

25. When EPRAP funds began to run low in January 2022, Defendants learned
that program staffers were prioritizing applications from tenants who had received
eviction notices. In response, in at least one instance, CUNNINGHAM represented that
he evicted fictitious tenants with the intention of expediting the processing and payment
of his EPRAP applications.

26. In total, between on or about August 27, 2021, and February 11, 2022,
Defendants and others submitted over 78 EPRAP applications, seeking over $2.8 million
and obtaining over $2.7 million in federal Emergency Rental Assistance funds by
executing the scheme and artifice to defraud. Non-Profit Organization 1 also disbursed
approximately $29,000 in rental assistance funds to MARTINEZ, posing as a landlord.

27. In addition to the kickback payments WILLIAMS received from her
associates and co-defendants, WILLIAMS received more than $740,000 in EPRAP funds
posing as a landlord on at least 21 EPRAP applications. JACKSON received more than

Indictment - 10 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
Case 2:23-cr-00090-JHC Document 1 Filed 05/31/23 Page 11 of 23

$250,000 in EPRAP funds posing as a landlord on at least seven ERPAP applications.
CUNNINGHAM sought more than $225,000 in EPRAP funds for at least five EPRAP
applications and successfully obtained approximately $125,000 after $100,000 was
recalled. In addition to kickback payments ROBINSON received from her associates,
ROBINSON received more than $150,000 from at least five ERPAP applications. In
addition to kickback payments PETERSON received from his associates, PETERSON
received more than $183,000 from at least five EPRAP applications.

28. Defendants withdrew large sums of fraudulent Emergency Rental
Assistance funds as cash. WILLIAMS used over $90,000 in cash and wire transferred
funds, from the proceeds and kickbacks she received, to buy a 2018 Range Rover sport
utility vehicle and a 2017 Lexus ES Sedan. At least in part to conceal the illegal source
of the funds, JACKSON, CUNNINGHAM, ROBINSON, PETERSON, and MARTINEZ
withdrew large sums of the proceeds as cash for various purposes, including paying
kickback payments to WILLIAMS in the form of cash that could not be traced through
the banking system.

29. EIDL. Beginning no later than June 25, 2020, until at least on or about
August 17, 2021, WILLIAMS, JACKSON, CUNNINGHAM, ROBINSON, and
PETERSON, together with those known and unknown, submitted or authorized to submit
at least 35 fraudulent EIDL applications to SBA using the identities of themselves and
others, seeking a total of approximately $3.7 million. SBA approved and disbursed funds
for two of these fraudulent applications, paying out approximately $300,000 using
interstate wire transmissions. For a third application in PETERSON’s identity, SBA
disbursed a $1,000 EIDL Advance.

30. WILLIAMS, JACKSON, CUNNINGHAM, ROBINSON, PETERSON,
and others, submitted or authorized the submission of knowingly fraudulent EIDL

applications in their identities as sole proprietorships. In many instances, in exchange for

Indictment - 11 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
Case 2:23-cr-00090-JHC Document1 Filed 05/31/23 Page 12 of 23

facilitating and submitting the fraudulent applications, the individuals agreed to pay
WILLIAMS a kickback upon receipt of the funds.

31. Many of the individuals, including CUNNINGHAM and JACKSON, are
WILLIAMS’ relatives or close associates. Defendants CUNNINGHAM and JACKSON,
and others, would provide WILLIAMS with personal identifying information and bank
account numbers to receive the funds. WILLIAMS, and others, would enter false
business information, such as gross revenue and costs of goods and submit the
applications to SBA using interstate wire transmissions.

32. WILLIAMS also submitted at least three fraudulent EIDL applications to
SBA using her own identity.

33. WILLIAMS maintained multiple email accounts and repeatedly used the
same four email addresses—Email Address 1 (which was also subsequently used on
EPRAP applications), Email Address 2, Email Address 3, and Email Address 4—for at
least 29 EIDL applications. Email Address 1 was used for at least 12 applications,
including one in JACKSON’s identity. Email Address 2 was used for at least three
applications, including one in WILLIAMS’ identity. Email Address 3 was used for at
least nine applications, including ones in WILLIAMS’ and CUNNINGHAM’ identities.
Email Address 4 was used for at least five applications.

34. WILLIAMS submitted multiple fraudulent applications with identical or
strikingly similar business information. All of the applicants claimed to be sole
proprietorships, and most of the business or trade names followed the naming convention
of using the accomplice’s first name followed by “LLC.” For instance, the trade name
for JAHRI CUNNINGHAM ’s fraudulent EIDL application was “JahriLLC.” Most of the
fictitious entities, including those of WILLIAMS, CUNNINGHAM, and JACKSON,

claimed to provide hair and nail services.

Indictment - 12 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
DO KR KR KR KN KN KR DR ee eet

Case 2:23-cr-00090-JHC Document 1 Filed 05/31/23 Page 13 of 23

35. Four of the applications claimed to have the exact same amount in gross
revenues—$1,347,232. An additional three applications also claimed approximately
$1.347 million in gross revenues but had slightly different amounts for the last three
digits. In all seven instances, the cost of goods sold were approximately $50,000, with
three of the applications stating the exact same cost of $49,323. These three applications
were all submitted within 35 minutes on July 13, 2020, using the following three business
trade names: “Salon LLC,” “Salon LLC,” and “SalonLLC.”

36. PPP. Between on or about April 10, 2021 and May 23, 2021, after
Congress authorized a third and final round of PPP funding, WILLIAMS, along with
JACKSON, and others, submitted at least 13 fraudulent PPP applications to lenders who
then transmitted the loan files to SBA using interstate wire transmissions, seeking a total
of approximately $253,000. In exchange for facilitating and submitting the fraudulent
applications, the individuals agreed to pay WILLIAMS a kickback upon receipt of the
funds.

37. Atleast 11 of the identities used for fraudulent EIDL applications were also
used for fraudulent PPP applications, and all claimed to be sole proprietorships.
However, this time, instead of claiming to provide hair and nail services, most of the PPP
applications falsely claimed that the individuals were sole proprietorships that began
providing food delivery services on January 1, 2020.

38. WILLIAMS also submitted at least two fraudulent PPP applications using
aliases of her own identity.

39. In multiple instances, WILLIAMS created fictitious bank statements to
submit in support of the loan applications.

40. | WILLIAMS used the fraudulent PPP proceeds and kickbacks she obtained
to fund luxury shopping sprees and travel, including a trip to Miami in June 2021 during

which she rented a Lamborghini.

Indictment - 13 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
N On BP WOW NO KF OD OO ON DOH FP W NYO KF OC

Case 2:23-cr-00090-JHC Document1 Filed 05/31/23 Page 14 of 23

41. Unemployment Benefits. Between on or about April 4, 2020, until at least
on or about August 7, 2021, WILLIAMS along with ROBINSON, CUNNINGHAM, and
others, conspired to submit fraudulent applications to various state workforce agencies
for pandemic unemployment benefits, using their true identities and the identities of
others.

E. Execution of the Scheme and Artifice to Defraud.

42. Onor about the dates set forth below, in King County, within the Western
District of Washington, and elsewhere, for the purpose of executing and attempting to
execute this scheme and artifice to defraud, the defendants specified in each Count, and
others, aiding and abetting each other, did knowingly transmit and cause to be
transmitted, by wire communication in interstate and foreign commerce, the following
writings, signs, signals, pictures and sounds, each transmission of which constitutes a

separate count of this Indictment:

Count On or About Date | Defendant(s) Wire

Interstate wire originating in
Washington to an SBA server
| 1 July 1, 2020 | outside Washington to submit
| PETERSON EIDL application for “Barber”
using PETERSON’s identity

Interstate wire originating in
Washington to an SBA server
2 July 13, 2020 WILLIAMS outside Washington to submit
EIDL application for “Salon
LLC” using L.B.’s identity

Interstate wire originating in
Washington to an SBA server

WILLIAMS . . .
3 July 12, 2020 JACKSON ° outside Washington to submit
EIDL application for “Cut N Up”
_using JACKSON’s identity
Indictment - 14 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
Case 2:23-cr-00090-JHC Document 1 Filed 05/31/23 Page 15 of 23

|

Count | Onor About Date | Defendant(s)

| Wire

4 August 6, 2020 | WILLIAMS

WILLIAMS,
5 August 7, 2020 CUNNINGHAM

| Interstate wire originating in
Washington to an SBA server

_ outside Washington to submit
_EIDL application for
_“ArthurLLC” using A.W.’s

_ identity

Interstate wire originating in
Washington to an SBA server
outside Washington to submit

| EIDL application for “JahriLLC” |

|
|
|
|
6 | April 29,2021 WILLIAMS

WILLIAMS,

Interstate wire originating in
Washington to third-party lender
service provider server outside

bank statement for fraudulent
PPP loan application in Sh.W.’s
identity

Interstate wire originating in
Washington to server outside
Washington to transmit signed
PPP loan documents for loan in
JACKSON’s identity

Washington to upload supporting |

8 May 27,2021 | WILLIAMS

Interstate wire originating in

| Washington to server outside
Washington to transmit signed

PPP loan documents for loan in
J.K.’s identity

9 November 19, 2021 | WILLIAMS

Interstate wire originating in
Washington to bank server
outside Washington to initiate
payment of $83,280 into
WILLIAMS’ bank account for
EPRAP landlord “Shaw
Williams”

|

_ Interstate wire originating in
Washington to bank server
outside Washington to initiate
payment of $76,308 into
ROBINSON’s bank account for

| EPRAP landlord “Tia Robinson”

Indictment - 15
United States v. Williams et al.
USAO No. 2021R00479

UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970
NY HO WN BP W NO KF DO Oo NI Dn FP W NPN KF CO

Case 2:23-cr-00090-JHC

Document 1 Filed 05/31/23 Page 16 of 23

Count

On or About Date

Defendant(s) |

Wire

11

November 12, 2021

WILLIAMS,
PETERSON

| outside Washington to initiate

: PETERSON’s bank account for

Interstate wire originating in
Washington to bank server

payment of $33,300 into

EPRAP landlord “Rayvon
Peterson”

12

December 10, 2021 ' ROBINSON

| WILLIAMS,

Interstate wire originating in
Washington to bank server
outside Washington to initiate
payment of $41,160 into
ROBINSON’s bank account for
EPRAP landlord “Tia Robinson” |

13

' December 30, 2021

WILLIAMS,
CUNNINGHAM

|

| Interstate wire originating in |

Washington to bank server
outside Washington to initiate
payment of $88,260 into
CUNNINGHAW\s bank account
for EPRAP landlord “Minah
Cunning”

14

January 21, 2022

WILLIAMS,
ROBINSON

Interstate wire originating in
Washington to bank server
outside Washington to initiate
payment of $41,580 into A.H.’s
bank account for EPRAP
landlord A.H.

15

|

January 21, 2022

MARTINEZ,
JACKSON

Interstate wire originating in
Washington to bank server
outside Washington to initiate
payment of $86,520 into

| MARTINEZ’s business bank
' account for EPRAP landlord
| “David Martinez”

16

January 21, 2022

WILLIAMS,
CUNNINGHAM

| Washington to bank server
| outside Washington to initiate

Interstate wire originating in

payment of $37,340 into
CUNNINGHAM’s bank account
for EPRAP landlord “Ale Cartel” |

Indictment - 16
United States v. Williams et al.
USAO No. 2021R00479

UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 2:23-cr-00090-JHC Document 1 Filed 05/31/23 Page 17 of 23

|

|
Count | Onor About Date | Defendant(s) Wire

Interstate wire originating in

| Washington to bank server

_ outside Washington to initiate
payment of $80,100 into
PETERSON’s bank account for |
EPRAP landlord “Rayvon
Peterson”

Interstate wire originating in
Washington to bank server

| | WILLIAMS, outside Washington to initiate
| 18 January 28,2022 MARTINEZ, payment of $72,900 into

| JACKSON MARTINEZ’s business bank
| account for EPRAP landlord
“David Martinez”

| | WILLIAMS,
17 January 21, 2021 PETERSON

Interstate wire originating in
Washington to bank server
outside Washington to initiate
payment of $216,825 into
JACKSON’s bank account for
EPRAP landlord “Akim Jackson”

WILLIAMS,

January 28, 2022 JACKSON,

9 |
| MARTINEZ
I

All in violation of Title 18, United States Code, Sections 1343 and 2.
COUNTS 20-24

(Money Laundering—Concealment)

43. | The Grand Jury incorporates by reference Paragraphs 1 through 42 of this
Indictment as if fully set forth herein.

44. On or about the dates listed below, in King County, within the Western
District of Washington, the Defendants specified below did knowingly conduct, and
attempt to conduct, financial transactions affecting interstate and foreign commerce
which involved the proceeds of some unlawful activity, that is, wire fraud, in violation of
Title 18, United States Code, Section 1343.

45. | When the defendants conducted and attempted to conduct these

transactions, they knew that the transactions were designed in whole or in part to conceal

Indictment - 17 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
Case 2:23-cr-00090-JHC Document1 Filed 05/31/23 Page 18 of 23

and disguise the nature, source, ownership, and control of the proceeds of the specified
unlawful activity, and while conducting and attempting to conduct the transactions, knew
that the financial transactions represented the proceeds of some form of unlawful activity.

46. Each of the transactions listed below represents an additional count of this

Indictment:
| Count Defendant On or About Date | Financial Transaction Amount
Second of two cash
withdrawals from
20 PETERSON November 15, 2021 PETERSON’s KeyBank $5,000
account

Cash withdrawal from
21 ROBINSON | November 24, 2021 | ROBINSON’s Bank of $10,000
America account

Cash withdrawal from
22 MARTINEZ December 24, 2021 | MARTINEZ’s BECU $9,700
business bank account

| Cash withdrawal from |
| 23 JACKSON January 24, 2022 JACKSON’s JPMorgan $20,000
Chase Bank account

Second of two cash

| withdrawals from
24 CUNNINGHAM January 26, 2022 CUNNINGHAM ’s $1,000

| JPMorgan Chase

account

All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2.
COUNTS 25-26

(Money Laundering—Spending)
47. The Grand Jury incorporates by reference Paragraphs 1 through 46 of this
Indictment as if fully set forth herein.
48. On or about the dates listed below, in King County, within the Western
District of Washington, Defendant WILLIAMS, did knowingly and willfully engage in a

Indictment - 18 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
Case 2:23-cr-00090-JHC Document1 Filed 05/31/23 Page 19 of 23

monetary transaction affecting interstate commerce, in criminally derived property of a
value greater than $10,000, that is, the withdrawal, deposit, and transfer of funds from
and to the financial institutions identified below, such property having been derived from

specified unlawful activity, that is wire fraud:
Count} Defendant | On or About Date | Monetary Transaction Amount

Wire Transfer from
| WILLIAMS’ Bank of
25 | WILLIAMS | November 22, 2021 America account to Auto gp 343 45
Dealer 1’s Wells Fargo
account for 2017 Lexus ES |
Sedan

| Cash payment to Auto Dealer
26 | WILLIAMS | February 18,2022 | 1 fora 2018 Range Rover $60,000.00
|

Sport Utility Vehicle

All in violation of Title 18, United States Code, Sections 1957 and 2.
FORFEITURE ALLEGATIONS

The allegations contained in Counts 1—26 of this Indictment are hereby realleged
and incorporated by reference for the purpose of alleging forfeiture.

Upon conviction of any of the offenses alleged in Counts 1-19, PARADISE
SHAW DREIA WILLIAMS shall forfeit to the United States pursuant to Title 18, United
States Code, Section 981(a)(1)(C), by way of Title 28, United States Code, Section
2461(c), any property that constitutes or is traceable to proceeds of the wire fraud scheme
described above. This property includes, but is not limited to:

a. ajudgment for a sum of money reflecting the proceeds the defendant obtained

as a result of the wire fraud scheme;

b. one 2018 Range Rover Sport Utility Vehicle; and

c. one 2017 Lexus ES Sedan.

Upon conviction of either of the offenses alleged in Counts 25 and 26,

PARADISE SHAW DREIA WILLIAMS shall forfeit to the United States pursuant to

Indictment - 19 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
DO NO NO KN KR KD DO eee et

Case 2:23-cr-00090-JHC Document1 Filed 05/31/23 Page 20 of 23

Title 18, United States Code, Section 982(a)(1), any property involved in the offense or
traceable to such property. This property includes, but is not limited to:

a. one 2018 Range Rover Sport Utility Vehicle; and

b. one 2017 Lexus ES Sedan.

Upon conviction of any of the offenses alleged in Counts 3, 7, 15, 18, and 19,
D’ARIUS AKIM JACKSON shall forfeit to the United States pursuant to Title 18,
United States Code, Section 981(a)(1)(C), by way of Title 28, United States Code,
Section 2461(c), any property that constitutes or is traceable to proceeds of the wire fraud
scheme described above. This property includes, but is not limited to, a judgment for a
sum of money reflecting the proceeds the defendant obtained as a result of the wire fraud
scheme.

Upon conviction of the offense alleged in Count 23, DDARIUS AKIM JACKSON
shall forfeit to the United States pursuant to Title 18, United States Code, Section
982(a)(1), any property involved in the offense or traceable to such property.

Upon conviction of any of the offenses alleged in Counts 5, 13, and 16, JAHRI
ASAD CUNNINGHAM shall forfeit to the United States pursuant to Title 18, United
States Code, Section 981(a)(1)(C), by way of Title 28, United States Code, Section
2461(c), any property that constitutes or is traceable to proceeds of the wire fraud scheme
described above. This property includes, but is not limited to, a judgment for a sum of
money reflecting the proceeds the defendant obtained as a result of the wire fraud
scheme.

Upon conviction of the offense alleged in Count 24, JAHRI ASAD
CUNNINGHAM shall forfeit to the United States pursuant to Title 18, United States

Code, Section 982(a)(1), any property involved in the offense or traceable to such

property.
Indictment - 20 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
Case 2:23-cr-00090-JHC Document 1 Filed 05/31/23 Page 21 of 23

Upon conviction of any of the offenses alleged in Counts 10, 12, and 14, TIA
JANEE ROBINSON shall forfeit to the United States pursuant to Title 18, United States
Code, Section 981(a)(1)(C), by way of Title 28, United States Code, Section 2461(c), any
property that constitutes or is traceable to proceeds of the wire fraud scheme described
above. This property includes, but is not limited to, a judgment for a sum of money
reflecting the proceeds the defendant obtained as a result of the wire fraud scheme.

Upon conviction of the offense alleged in Count 21, TIA JANEE ROBINSON
shall forfeit to the United States pursuant to Title 18, United States Code, Section
982(a)(1), any property involved in the offense or traceable to such property.

Upon conviction of any of the offenses alleged in Counts 1, 11, and 17, RAYVON
DARNELL PETERSON shall forfeit to the United States pursuant to Title 18, United
States Code, Section 981(a)(1)(C), by way of Title 28, United States Code, Section
2461(c), any property that constitutes or is traceable to proceeds of the wire fraud scheme
described above. This property includes, but is not limited to, a judgment for a sum of
money reflecting the proceeds the defendant obtained as a result of the wire fraud
scheme.

Upon conviction of the offense alleged in Count 20, RAYVON DARNELL
PETERSON shall forfeit to the United States pursuant to Title 18, United States Code,
Section 982(a)(1), any property involved in the offense or traceable to such property.

Upon conviction of the offenses alleged in Counts 15, 18, and 19, DAVID JESUS
MARTINEZ shall forfeit to the United States pursuant to Title 18, United States Code,
Section 981(a)(1)(C), by way of Title 28, United States Code, Section 2461(c), any
property that constitutes or is traceable to proceeds of the wire fraud scheme described
above. This property includes, but is not limited to, a judgment for a sum of money

reflecting the proceeds the defendant obtained as a result of the wire fraud scheme.

Indictment - 21 UNITED STATES ATTORNEY
United States v. Williams et al. 700 STEWART STREET, SUITE 5220
USAO No. 2021R00479 SEATTLE, WASHINGTON 98101

(206) 553-7970
NY Dn Wn FPF Ww NO KF DO OH NI Dn BP W NH KF CO

Case 2:23-cr-00090-JHC Document 1 Filed 05/31/23 Page 22 of 23

Upon conviction of the offense alleged in Count 22, DAVID JESUS MARTINEZ

shall forfeit to the United States pursuant to Title 18, United States Code, Section

982(a)(1), any property involved in the offense or traceable to such property.

Substitute Assets. If any of the above-described forfeitable property, as a result

of any act or omission of the defendants,

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 commingled with other property which cannot be divided

without difficulty,

it is the intent of the United States to seek the forfeiture of any other property of the

a.
b.
c.
d.
e.
//

Indictment - 22

UNITED STATES ATTORNEY

United States v. Williams et al. 700 STEWART STREET, SUITE 5220

USAO No. 2021R00479

SEATTLE, WASHINGTON 98101
(206) 553-7970
—

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Case 2:23-cr-00090-JHC Document 1 Filed 05/31/23 Page 23 of 23

defendant, up to the value of the above-described forfeitable property, pursuant to
Title 21, United States Code, Section 853(p).

A TRUE BILL: «7
DATED: vy: SS g <

Signature of Foreperson redacted pursuant
to the policy of the Judicial Conference of
the United States.

FOREPERSON

PACHOLAS W. BROWN
Unite States Attorney

|, SACH WILKINSON

Assistant United States Attorney

CINDY CHAN
Assistant United\States Attorney

Indictment - 23
United States v. Williams et al.
USAO No. 2021R00479

UNITED STATES ATTORNEY
700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970


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