Indictment — United States v. Jabari Kadar Long, Eastern District of Michigan (ECF No. 1)

Summary

A grand jury indictment of Jabari Kadar Long, Case No. 2:25-cr-20579, in the U.S. District Court for the Eastern District of Michigan, filed July 30, 2025 as ECF No. 1. Count One charges conspiracy to commit wire fraud under 18 U.S.C. § 1349, Count Two wire fraud affecting a financial institution under 18 U.S.C. § 1343, and Count Three money laundering under 18 U.S.C. § 1957. The indictment alleges that a PPP application to LCA Bank Corp claimed Priceless Preservations had 50 employees and an average monthly payroll of $875,000, and that a loan of $2,187,500 was transferred on or about May 18, 2020. It further alleges an EIDL deposit of $150,000 on June 15, 2020, a denied second draw application, and a wire transfer of $40,000 in loan proceeds charged as money laundering.

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ase 2:25-cr-20579-BRM-DRG ECF No. 1, PagelD.1 Filed 07/30/25 Page 1 of 15

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

Case:2:25-cr-20579
UNITED STATES OF AMERICA, —_ Judge: MeMiillion, Brandy R.
MJ: Grand, David R.
Filed: 07-30-2025 At 04:07 PM

v. USA V SEALED MATTER (LG)

JABARI KADAR LONG, Violations: 18 U.S.C. § 134

Defendant. 18 U.S.C. § 195/7

/

INDICTMENT

The Grand Jury charges:

GENERAL ALLEGATIONS

At all times relevant to this Indictment:

1. Defendant Jabari Kadar Long was a resident of the Eastern
District of Michigan.
2. Long was the owner of Priceless Preservations Constructions

(“Priceless Preservations”), a purported business in the Eastern District
of Michigan that performed home improvements and structural

remodeling.

3. Long maintained and controlled a bank account ending in X26941

in the name of Priceless Preservations Construction at Community
ase 2:25-cr-20579-BRM-DRG ECF No.1, PagelD.2 Filed 07/30/25 Page 2 of

Choice Credit Union, a federally insured financial institution based
Michigan.

The Small Business Administration and the CARES Act
4. The United States Small Business Administration (“SBA”) was
executive-branch agency of the United States government that provi
support to entrepreneurs and small businesses. The mission of the S$
was to maintain and strengthen the nation’s economy by enabling th
establishment and viability of small businesses and by assistance in
economic recovery of communities after disasters.
5. As part of this effort, the SBA enabled and provided for loans
through banks, credit unions, and other lenders that had governmen
backed guarantees. The SBA also provided direct loans.
6. In or around March 2020, the Coronavirus Aid, Relief, and
Economic Security (“CARES”) Act was enacted to provide emergency
financial assistance to the millions of Americans suffering the econo!
effects caused by the COVID-19 pandemic. The CARES Act establish
several new programs and provided for expansion of others, includin|

programs created and/or administered by the SBA.

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The Paycheck Protection Program

7. The Paycheck Protection Program (“PPP”) was a COVID-19
pandemic relief program administered by the SBA, that provided
forgivable loans to small businesses for job retention and certain oth
expenses. The PPP permitted participating lenders to approve and
disburse SBA-backed PPP loans to qualifying businesses during the
COVID-19 pandemic to be used for certain specified business expens
such as payroll costs, costs related to the continuation of group healt

care benefits, utilities, and lease/mortgage interest.

8. To obtain a PPP loan, a qualifying business had to submit a PRP
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. The PPP loan
application also required the authorized representative to state the
business's average monthly payroll and number of employees. These
figures were used to calculate the amount of money the business wag

eligible to receive under the PPP. In addition, the business applying

ase 2:25-cr-20579-BRM-DRG ECF No. 1, PagelD.3 Filed 07/30/25 Page 3 of 15

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se 2:25-cr-20579-BRM-DRG ECF No.1, PagelD.4 Filed 07/30/25 Page4o

expenses, such as filed federal income tax documents.

9. PPP loan applications were electronically submitted and were
received through SBA servers. Once approved, the business received
PPP loan proceeds via an electronic funds transfer from the
participating lender to a financial account under the control of the
business.

10. LCA Bank Corp was a federally insured financial institution
based in Utah. LCA Bank Corp was a participating PPP lender.

The Economic Injury Disaster Loan Program

a PPP loan was required to provide documentation showing its payroll

15

the

11. The Economic Injury Disaster Loan (““EIDL’) program was an $BA

program that provided loans to help qualifying small businesses that
suffered substantial economic injury recover from declared disasters
12. The CARES Act extended eligibility in the SBA’s EIDL progran
by providing loans and advances to help businesses recover from the
economic impacts of the COVID-19 pandemic.

13. In order to obtain an EIDL for COVID-19 relief, a qualifying
business was required to submit an application to the SBA and prov]
information about its operations, such as the number of employees,
gross revenue for the 12-month period preceding the disaster, and co

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ase 2:25-cr-20579-BRM-DRG ECF No.1, PagelD.5 Filed 07/30/25 Page 5 of 15

of goods sold in the 12-month period preceding the disaster. The
applicant was also required to certify that all the information in the
application was true and correct to the best of the applicant’s
knowledge.
14. EIDL applications were submitted directly to the SBA.
15. The SBA also offered EIDL advance funds, which did not need to
be repaid, to certain eligible small businesses that were affected by the
COVID-19 pandemic. The Targeted EIDL Advance provided up to
$10,000 to applicants who, among other things, were in a low-income
community, could demonstrate more than 30% reduction in revenue
during an eight-week period beginning on March 2, 2020, or later, arid
had 300 or fewer employees. The Supplemental Targeted Advance
provided a supplemental payment of $5,000 to applicants who, among
other things, were in a low-income community, could prove more than
50% economic loss during an eight-week period beginning on March 2,
2020, or later, and had 10 or fewer employees.
COUNT ONE

18 U.S.C. § 1349
Conspiracy to Commit Wire Fraud

16. From on or about May 7, 2020 through on or about March 2021) in
the Eastern District of Michigan, Southern Division, defendant Jabari

5
ase 2:25-cr-20579-BRM-DRG ECF No. 1, PagelD.6 Filed 07/30/25 Page 6 of 15

Kadar Long and other individuals, both known and unknown to the
Grand Jury, did willfully and knowingly combine, conspire, confederate,
and agree with each other to violate Title 18, United States Code,
Section 1343, that is, to devise and execute a scheme and artifice to
defraud and to obtain money and property by means of materially false
and fraudulent pretenses, representations, and promises, knowing stich
pretenses, representations, and promises were false and fraudulent
when made, and the defendant and others transmitted and caused to be
transmitted, by means of wire, radio, and television communication,
writings, signals, pictures, and sounds in interstate and foreign
commerce for the purpose of executing such scheme and artifice, all in
violation of Title 18, United States Code, Section 1349.
Purpose of the Conspiracy

17. The purpose of the conspiracy was for the defendant and others to
illegally obtain money through applications for PPP and EIDL funds|by
means of materially false and fraudulent pretenses, representations,
and promises, with the intent to defraud and with knowledge of the
scheme’s fraudulent nature. To execute the scheme, the defendant and

others attempted to file, filed, and caused the filing of materially false
se 2:25-cr-20579-BRM-DRG ECF No.1, PagelD.7 Filed 07/30/25 Page 7 of

applications and requests for PPP and EIDL funds, which they were

entitled to receive, to unjustly enrich themselves and others.
Manner and Means

18. The manner and means by which the defendant and others sou
to accomplish the purpose of the conspiracy included, among others,
following:

19. It was part of the scheme and artifice that the defendant
submitted PPP and EIDL applications that fabricated or inflated the
number of employees that were employed by the purported business

that was applying for the PPP or EIDL funds.

20. It was part of the scheme and artifice that the defendant falsely

attested that the information presented in the applications for PPP a

EIDL funds, including the number of employees purportedly employed

by the business, was true and accurate.

21. It was further part of the scheme and artifice that the defendant

caused the transmission of information and funds via interstate wire

in connection with the false applications for PPP and EIDL funds.

not

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the

nd

22. As part of the scheme and artifice to defraud, on or about May [3,

2020, the defendant caused to be submitted a false and fraudulent PPP

loan application to lender LCA Bank Corp. (LCA), and the SBA on

7
ase 2:25-cr-20579-BRM-DRG ECF No. 1, PagelD.8 Filed 07/30/25 Page 8 of

electronically signed the false and fraudulent PPP loan application a
the owner and authorized representative of Priceless Preservations.
23. As part of the scheme and artifice to defraud, in support of the
PPP loan application, the defendant caused to be made the false and
fraudulent claim that Priceless Preservations had 50 employees, whe
in truth and fact Priceless Preservations had few, if any, employees.
24. As part of the scheme the scheme and artifice to defraud, in
support of the PPP loan application, the defendant caused to be mad

the false and fraudulent claim that Priceless Preservations had an

average monthly payroll of $875,000, when in truth and fact Priceless

Preservations had little to no payroll expenses.

25. As part of the scheme and artifice to defraud, in support of the
PPP loan application, the defendant caused to be submitted false Foy
940s, Employer's Annual Federal Unemployment Tax Returns, for 2(
and 2020, as well as false Form 941s, Employer’s Quarterly Federal '
Returns, for the first, second, and third quarters of 2020. In these
documents, the defendant falsely claimed that Priceless Preservation

had 50 employees.

behalf of Priceless Preservations, requesting $2,187,500. The defendant

15

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ase 2:25-cr-20579-BRM-DRG ECF No.1, PagelD.9 Filed 07/30/25 Page 9 o1

26. Based on the representations in the application and the
supporting materials, a PPP loan was authorized for Priceless

Preservations in the amount of $2,187,500, which was electronically

transferred on or about May 18, 2020, into the Priceless Preservations

bank account ending in X26941 at Community Choice Credit Union.

15

27. Inthe PPP loan application, the defendant certified that the loan

proceeds would be “used only for business-related purposes as specifi

in the loan application.” But it was part of the scheme and artifice to

defraud that the defendant used the loan proceeds for purposes contr

to the business-related purposes specified in the loan application.
28. It was part of the scheme and artifice that the defendant sough
spend significant amounts of the PPP proceeds shortly after receipt.
or about May 21, 2020, the defendant electronically transferred

$300,000 of the PPP proceeds to another bank account in his name. (

May 21, 2020, June 9, 2020, and June 9, 220, the defendant

electronically transferred a total of $60,000 to a bank account in a co}

conspirator’s name.
29. It was part of the scheme and artifice that on or about June 12,
2020, the defendant submitted or caused to be submitted to the SBA,
via the internet, a materially false EIDL application for Priceless

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se 2:25-cr-20579-BRM-DRG ECF No.1, PagelD.10 Filed 07/30/25 Page 10 q

Preservations. The defendant’s affirmation that the information
presented in the EIDL loan application was true and accurate was fe
The SBA approved the loan and on June 15, 2020, the Community
Choice Credit Union account ending in X26941 in the name of Pricel
Preservations received $150,000.

30. On January 27, 2021, the defendant submitted a second draw |
application to the SBA for Priceless Preservations. The second d

application was flagged for fraud and denied.

COUNT TWO

18 U.S.C. § 1343
Wire Fraud Affecting a Financial Institution

31. Paragraphs 1 through 380 are realleged and incorporated as if fi
set forth here.

32. Onor about May 13, 2020, in the Eastern District of Michigan,
Southern Division, the defendant, Jabari Kadar Long, having devise

and intended to devise a scheme and artifice to defraud, and for

bf 15

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PPP

raw

ally

obtaining money by means of materially false and fraudulent pretenses,

representations, and promises, did knowingly transmit and cause to

transmitted by means of wire communication in interstate commerce,

certain writings, signs, and signals, for the purpose of executing and

be

attempting to execute the scheme and artifice to defraud, which affected

10
se 2:25-cr-20579-BRM-DRG ECF No. 1, PagelD.11 Filed 07/30/25 Page 11 of 15

a financial institution, to wit: the defendant provided false information,
such as false tax forms, to obtain funds from a financial institution and
caused the submission of a false PPP loan application to obtain funds
from a financial institution through the SBA’s PPP program for
Priceless Preservations, and caused the transmission of electronic
signals and messages on interstate wires in connection with the

electronic transfer of PPP loan funds from outside the State of Michi

UM

an
into the Priceless Preservations bank account ending in X26941 at
Community Choice Credit Union, opened and maintained in the
Eastern District of Michigan.

33. Allin violation of Title 18, United States Code, Section 1343.

COUNT THREE

18 U.S.C. § 1957
Money Laundering

34. Paragraphs 1 through 33 are realleged and incorporated as if fully
set forth here.

35. Onor about November 23, 2020, in the Eastern District of
Michigan and elsewhere, the defendant, Jabari Kadar Long, knowingly
engaged and attempted to engage in a monetary transaction by and
through a financial institution, affecting interstate commerce, in

criminally derived property of a value greater than $10,000; that is, a

1]
se 2:25-cr-20579-BRM-DRG ECF No.1, PagelD.12 Filed 07/30/25 Page 12

wire transfer of $40,000 in PPP and EIDL loan proceeds from the

Df 15

Community Choice Credit Union account ending in X26941, held in the

name of Priceless Preservations, to a Navy Federal Credit Union
account ending in x1658, held in the name of Jabari Long, such
property having been derived from a specified unlawful activity, that
wire fraud, in violation of Title 18, United States Code, Section 1343
set forth in Count One.

36. Allin violation of Title 18, United States Code, Section 1957.

FORFEITURE ALLEGATIONS

37. The allegations contained in this Indictment are realleged and

incorporated by reference to allege forfeiture under Title 18, United

is,

as

States Code, Section 981(a)(1)(C), Title 18, United States Code, Section

982(a)(1), and Title 28, United States Code, Section 2461(c).
38. Upon being convicted of the offense in violation of Title 18, Uni
States Code, Section 1343, the defendant shall forfeit to the United

States, under Title 18, United States Code, Section 981(a)(1)(C),

ted

together with Title 28, United States Code, Section 2461, any property,

which constitutes, or is derived from, proceeds obtained directly or

indirectly as a result of such violation.

12
se 2:25-cr-20579-BRM-DRG ECF No. 1, PagelD.13 Filed 07/30/25 Page 13 of 15

39. Upon being convicted of the offense in violation of Title 18, United
States Code, Section 1957, the defendant shall forfeit to the United
States, under Title 18, United States Code, Section 982(a)(1), any
property, real or personal, involved in such offense, or any property
traceable to such property.

40. The forfeiture in this case may include entry of a forfeiture money
judgment in an amount up to the value of the property subject to
forfeiture for the violation of conviction.

41. If, by any act of omission of the defendant, the proceeds of the
offense: cannot be located upon the exercise of due diligence, have been
transferred, sold to, or deposited with a third party, have been placed
beyond the jurisdiction of the court, have been substantially diminished
in value, or have been commingled with other property which cannot} be
divided without difficulty, the United States of America shall seek to
forfeit substitute property under Title 21, United States Code, Section
8538(p), as incorporated by Title 18, United States Code, Section

982(b)(1) and Title 28, United States Code, Section 2461(c).

13
JEROME F. GORGON JR.
United States Attorney

s/John K. Neal

John K. Neal
Chief, Anti-Corruption Unit

s/Sara D. Woodward

Sara D. Woodward
Assistant U.S. Attorney

July 30, 2025

14

se 2:25-cr-20579-BRM-DRG ECF No. 1, PagelD.14 Filed 07/30/25 Page 14 of 15

THIS IS A TRUE BILL.

s/Grand Jury Foreperson
GRAND JURY FOREPERSON
Case 2:25-cr-20579-BRM-DRG ECF No.1, PagelD.15 Filed 07/30/25 Page 15

Case:2:25-cr-20579
Judge: McMillion, Brandy R.

United States District Court Crimi Cc Cc MJ: Grand, David R.
Eastern District of Michigan riminal Case Co Filed: 07-30-2025 At 04:07 PM

USA V SEALED MATTER (LG)

NOTE: It is the responsibility of the Assistant U.S. Attorney signing this form to complete it accurately In an respecis.

Companion Case Information Companion Case Number:

This may be a companion case based upon LCrR 57.10 (b)(4)': Judge Assigned:
L Yes No AUSA’s Initials: sos, )
Case Title: USA v. Jabari Kadar Long
| County where offense occurred: Wayne
Check One: Felony L|Misdemeanor L Petty
V¥_Indictment/ Information --- no prior complaint.
Indictment/ Information --- based upon prior complaint [Case number:
indictment/ Information --- based upon LCrR 57.10 (d) [Complete Superseding section|below].

Superseding Case Information

Superseding to Case No: Judge:

[_]Corrects errors; no additional charges or defendants.
[_]Involves, for plea purposes, different charges or adds counts.
[_]Embraces same subject matter but adds the additional defendants or charges below:

Defendant name Charges Prior Complaint (if applicable)

Please take notice that the below listed Assistant United States Attorney is the attorn
the above captioned case. ,

July 30, 2025 s/ Sara D. Woodard .

Date Sara D. Woodward
Assistant United States Attorney
211 W. Fort Street, Suite 2001
Detroit, MI 48226-3277
Fax: 313-226-2873
E-Mail address: Sara.woodward@usdoj.gov

Attorney Bar #; P73784

1 Companion cases are matters in which it appears that (1) substantially similar evidence will be offered at trial, or
or related parties are present, and the cases arise out of the same transaction or occurrence. Cases may be compan

even though one of them may have already been terminated.

of record for

2) the same
ion cases

5/16


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