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Indictment — United States v. Cheryl Lee Labrie, District of Alaska (Document 2)

Summary

A grand jury indictment in United States of America v. Cheryl Lee Labrie, No. 3:24-cr-00009-JMK-MMS, filed January 18, 2024 as Document 2 in the U.S. District Court for the District of Alaska. It charges wire fraud under 18 U.S.C. § 1343, bank fraud under 18 U.S.C. § 1344 and money laundering under 18 U.S.C. § 1957, with forfeiture allegations. The indictment alleges that from April 2020 through August 2022 Labrie, manager of AKBS, LLC, obtained EIDL loans and first and second draw PPP loans from Alaska USA Federal Credit Union with false statements about a prior felony conviction, payroll and employee counts. It alleges a first draw application for $200,000 and a second draw application for $292,573.00, and that EIDL funds went to personal uses including a home purchase. The signature block names Assistant U.S. Attorney Michael J. Heyman.

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Cite this document

“Indictment — United States v. Cheryl Lee Labrie, District of Alaska (Document 2).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-3-24-cr-00009-dkt-2-b96b32330a/, SHA-256 3959ffca5230be98ca094cd2323258c9c356694c543f39c80efd32c2e73cedd4.

Full text

S. LANE TUCKER
United States Attorney

MICHAEL J. HEYMAN
Assistant U.S. Attorney
Federal Building & U.S. Courthouse
222 West Seventh Avenue, #9, Room 253
Anchorage, AK 99513-7567
Phone: (907) 271-5071
Email: michael.heyman@usdoj.gov

Attorneys for Plaintiff

                     IN THE UNITED STATES DISTRICT COURT

                           FOR THE DISTRICT OF ALASKA

UNITED STATES OF AMERICA,                  No.   3:24-cr-00009-JMK-MMS

                     Plaintiff,            COUNT 1-4
                                           WIRE FRAUD
      vs.                                    Vio. of 18 U.S.C. § 1343
CHERYL LEE LABRIE,                         COUNT 5-6
                                           BANK FRAUD
                     Defendant.              Vio. of 18 U.S.C. § 1344

                                           COUNT 7-12
                                           MONEY LAUNDERING
                                             Vio. of 18 U.S.C. § 1957

                                           CRIMINAL FORFEITURE
                                           ALLEGATION 1
                                               18 U.S.C. § 981(a)(1)(C)

                                           CRIMINAL FORFEITURE
                                           ALLEGATION 2
                                              18 U.S.C. § 981(a)(1)(A)



                                     INDICTMENT

      The Grand Jury charges that:



     Case 3:24-cr-00009-JMK-MMS Document 2 Filed 01/18/24 Page 1 of 16
                           INTRODUCTORY ALLEGATIONS

       At all times relevant to this Indictment:

       1.      Defendant Cheryl Lee Labrie (“Defendant”) was a resident of Anchorage,

Alaska.

       2.      Defendant was the manager and sole member of AKBS, LLC (“AKBS”),

doing business as Liberty Tax Services and Alaska’s Bookkeeping Services, an Alaska

entity organized to provide bookkeeping, payroll and bill pay services.

       3.      Defendant was the 50% member of M & C Enterprises, LLC (“M&C”), an

Alaska entity organized to provide payroll services.

       4.      In 2013, Defendant was convicted of 1st Degree Theft, a felony, in the

Superior Court for the State of Alaska, Third Judicial District, case number 3AN-13-

01139CR. The sentence was suspended, and Defendant was placed on five years’

probation and ordered to pay $70,000 restitution. In January 2019, despite the five years

expiring, the court extended the probationary term because Defendant had not repaid the

restitution.

                              COVID Disaster-Relief Loans

       5.      On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security

(“CARES”) Act became law. The CARES Act created the Paycheck Protection Program

(“PPP”) and Economic Injury Disaster Loans (“EIDLs”).

       6.      The PPP authorized the Small Business Administration (“SBA”) to

guarantee loans of up to $10,000,000 to qualifying employers without collateral or

personal guarantees from the borrowers. The Act required lenders making loans under

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the PPP to defer all repayment obligations for not less than six months on such loans and

required borrowers to certify, among other things, that the borrowed “funds [would] be

used to retain workers and maintain payroll or make mortgage payments, lease payments,

and utility payments.” Pursuant to the CARES Act, the amount of PPP funds a business

is eligible to receive is determined by the number of employees employed by the business

and their average payroll costs. The PPP allows qualifying small businesses and other

organizations to receive unsecured SBA-guaranteed loans. PPP loan proceeds must be

used by businesses on payroll costs, mortgage interest, rent, and/or utilities, among other

specified expenses. The PPP allows the interest and principal to be forgiven if businesses

spend the proceeds on these expenses under certain conditions. Businesses applying for a

PPP loan must provide documentation to confirm that they have in the past paid

employees the compensation represented in the loan application. The PPP is overseen by

the SBA, which has authority over all PPP loans, but individual PPP loans are issued by

approved commercial lenders who receive and process PPP applications and supporting

documentation. The first round of PPP closed to new applications on August 8, 2020.

       7.     The EIDL program is an SBA program providing low-interest financing to

small businesses, renters, and homeowners affected by declared disasters. The CARES

Act and Coronavirus Response and Relief Supplemental Appropriations Act of 2021

authorized the SBA to issue EIDLs (and additional EIDL advances of up to $10,000) to

small businesses within three days of applying for an EIDL. EIDLs must be repaid and

are determined based upon the number of certified employes by the applicant. EIDL

advances do not have to be repaid. To obtain an EIDL and/or an EIDL advance,

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qualifying businesses must submit an application to the SBA and provide information

about business 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; in the case of EIDLs for COVID-19 relief, the 12-month period

preceding January 31, 2020. The applicant must also certify all application information

submitted is true and correct to the best of the applicant’s knowledge.

       8.     On December 27, 2020, the Consolidated Appropriations Act of 2021,

which included the Economic Aid to Hard-Hit Small Businesses, Nonprofit, and Venues

Act (the “Relief Act”) was signed into law, providing additional funding for the PPP.

Under the Relief Act, certain businesses that already obtained a PPP loan under the

original PPP were eligible for an additional “second draw” PPP loan, provided they met

certain requirements. The Relief Act also re-opened the application period for “first

draw” PPP loans to businesses that had not been approved for a “first draw” loan prior to

August 8, 2020, or who may have been eligible to receive more funds during the “first

draw” period than they actually received. Borrowers through the PPP second draw

program are also eligible to apply for loan forgiveness once all loan proceeds for which

forgiveness is requested have been used.

       9.     In order to obtain a PPP loan, an applicant was required to provide

information about the subject business’s operations, such as the date of opening, number

of employees, and past revenues. The applicant was also required to certify all the

information in the application was true and correct to the best of the applicant’s

knowledge. PPP loan applications were submitted over the Internet by participating

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lenders via the SBA’s computer servers. Regardless of originating location, all PPP

applications submitted through August 8, 2020, were received by servers located in

Virginia. PPPs applications submitted after January 11, 2021, were received through

servers located in Oregon, and subsequently transmitted to servers in Virginia.

       10.    PPP Forgiveness Loan Applications were submitted over the Internet via

SBA’s computer servers. Regardless of originating location, all PPP Forgiveness

Applications were received through servers located in Oregon, and subsequently

transmitted to servers in Virginia.

       11.    EIDL applications were submitted over the internet via SBA’s computer

servers and transited via interstate wires depending upon their date of application. Prior

to July 11, 2020, applications originating in any state beginning with prefix 36 transited

via wires to Washington, before being routed to Colorado, and subsequently Virginia.

                                      The General Scheme

       12.    From no later than April 2020, and continuing through August 2022,

Defendant Cheryl Lee Labrie knowingly and willfully executed a scheme and artifice to

defraud the SBA and financial institutions, including Alaska USA Federal Credit Union

(“Alaska USA”), a participating PPP lender, and to obtain money and property by means

of materially false and fraudulent pretenses, representations, and promises.

       13.    Specifically, Defendant applied for and obtained an EIDL advance, two

EIDL loans, two PPP loans, and the forgiveness of two PPP loans (first and second draw)

for AKBS by means of materially false and fraudulent pretenses, representations, and



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promises, and, in some instances, intended to convert the proceeds of those loans for

unauthorized purposes, including for personal use.

                                      Manner and Means

       14.    As part of the scheme and artifice to defraud, Defendant committed or

participated in the following acts:

The First EIDL

       15.    On April 1, 2020, Defendant submitted an EIDL application to the SBA on

behalf of AKBS seeking $110,500.00, plus a $6,000 advance.

       16.    The EIDL application contained the following false statement: In response

to the question of whether Defendant had ever been convicted, pled guilty, or been placed

on any form of probation, Defendant responded, “No.” In truth, Defendant had been

convicted in 2013 for 1st Degree Theft, a felony, and placed on probation. At the time of

the EIDL application, Defendant remained on probation and was aware of her conviction

and current probationary status, but knowingly and willfully provided false information

about the conviction and probation.

       17.    Based at least in part on the material false Statements, the SBA approved

the EIDL advance and dispersed it to AKBS’s Alaska Federal Credit Union business

account on April 23, 2020, and the EIDL was subsequently approved and funded on June

3, 2020.




                                        Page 6 of 16
      Case 3:24-cr-00009-JMK-MMS Document 2 Filed 01/18/24 Page 6 of 16
The Second EIDL

        18.   In April 2021, Defendant requested a $349,500 increase of the EIDL (for a

total of $460,000.00) on behalf of AKBS. Defendant falsely represented to the SBA that

all statements in the initial application were true and that the funds would be used “solely

as working capital to alleviate economic injury” caused by COVID.

        19.   Based at least in part on the material false Statements, the SBA approved

the second EIDL and funded it to AKBS’s Northrim Bank business account on July 12,

2021.

        20.   However, the representation about her criminal history in the original loan

application was not true and Defendant obtained the second draw not for working capital

as a result of economic injury caused by COVID, but primarily for personal expenses,

including, without limitation, to facilitate the purchase of a new home (including

obtaining a downpayment, satisfying an outstanding federal tax lien of M&C, and

satisfying an outstanding student debt lien), and to pay the outstanding restitution order

from her 2013 conviction.

        21.   On the date she received the EIDL funds, Defendant, among other things,

immediately satisfied the M&C tax lien, a condition required by her mortgage lender to

qualify for the home loan. Defendant paid the M&C tax lien in three payments,

$11,401.92, $20,831.48, and $65,005.04.

        22.   The next day, July 15, 2021, Defendant opened a new personal account at

Northrim Bank and transferred $80,000 in EIDL proceeds from the AKBS business

account to her new personal account.

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        Case 3:24-cr-00009-JMK-MMS Document 2 Filed 01/18/24 Page 7 of 16
      23.    Shortly thereafter, Defendant opened two new AKBS accounts at Northern

Skies Bank. Defendant then obtained two cashier’s checks from Northrim Bank in the

amounts of $150,000 and $76,012.36 and deposited them into the new Northern Skies

accounts on July 20, 2021, and August 2, 2021, respectively. Defendant did not use those

proceeds deposited into the new Northerns Skies accounts as working capital to alleviate

economic injury caused by COVID, but for, at least in part, unrelated purposes,

including, without limitation, for payroll expenses of a marijuana dispensary.

The First Draw PPP Loan

      24.    On April 29, 2020, Defendant submitted a PPP loan application (loan

number 53187473-01) to Alaska USA on behalf of AKBS seeking a PPP loan in the

amount of $200,000.

      25.    The PPP loan application contained material false statements. Defendant

represented that AKBS’s average monthly payroll was $80,000 and further submitted an

IRS Form W3 claiming that AKBS’s 2019 employee payroll was $1,631,335. According

to filings certified by Defendant to the Alaska Department of Labor (“DOL”), Alaska

Department of Revenue (“DOR”), and Internal Revenue Service (“IRS”), AKBS’s total

payroll for the entirety of 2019 was approximately $67,000.

      26.    Defendant further represented that the total number of AKBS employees

was 32 and submitted a 2019 IRS Form W3 claiming that AKBS had 86 employees.

According to filings certified by Defendant to the DOL, DOR, and IRS, AKBS had, at

most, 18 employees.



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      Case 3:24-cr-00009-JMK-MMS Document 2 Filed 01/18/24 Page 8 of 16
       27.    Defendant also certified that she was not engaged in any activity that is

illegal under federal, state or local law, and further certified the information provided in

the first draw PPP loan application and the information provided in all supporting

documents and forms is true and accurate in all material respects.

       28.    Based at least in part on these material false statements, Alaska USA

approved the loan and dispersed the funds on May 14, 2020. In addition, following

Alaska USA funding of the PPP loan, on June 22, 2020, the SBA paid Alaska FCU

$10,000 in lender fees to finance the PPP loan.

The Second Draw PPP Loan

       29.    On January 27, 2021, Defendant submitted a PPP loan application (loan

number 8334898300) to Alaska USA on behalf of AKBS seeking a second draw PPP

loan in the amount of $292,573.00.

       30.    The second draw PPP application contained material false statements.

Defendant represented that AKBS’s average monthly payroll was $118,416 and further

submitted four IRS Form 941s for 2020 claiming that AKBS’s quarterly employee

payroll was $341,383, $337,506.14, $346,764, and $425,613, respectively. Defendant

further submitted a certified 2019 profit and loss statement representing that yearly

payroll was $570,446 ($47,537 average monthly), and a statement representing that

payroll for the first quarter of 2020 was $424,677. According to filings certified by

Defendant to the DOL, AKBS’s total payroll for the entirety of 2020 was approximately

$85,579.



                                        Page 9 of 16
      Case 3:24-cr-00009-JMK-MMS Document 2 Filed 01/18/24 Page 9 of 16
       31.    Defendant further represented that the total number of AKBS employees

was 75 and submitted four quarterly IRS Form W3s for 2020 representing that AKBS had

37, 32, 34, and 41 employees per quarter, respectively. According to filings certified by

Defendant to the DOL, AKBS had, at most, 11 employees in 2020.

       32.    Defendant also certified she was not engaged in any activity that is illegal

under federal, state or local law, and further certified the information provided in the

second draw PPP Loan application and the information provided in all supporting

documents and forms is true and accurate in all material respects.

       33.    Based at least in part on these material false statements, Alaska USA

approved the second draw loan and dispersed the funds on February 3, 2021. In

addition, following Alaska USA funding of the second draw PPP loan, on March 15,

2021, the SBA paid Alaska USA $14,628.65 in lender fees to finance the PPP loan

increase.

Forgiveness of the First PPP Loan

       34.    On February 23, 2021, Defendant submitted a PPP Loan Forgiveness

Application for the first PPP loan (covered period of 5/14/2020 to 10/22/2020). The

application contained material false statements. Defendant represented that that payroll

expenses for the applicable five-month period were $658,473.72 when, according to

filings certified by Defendant to the DOL, payroll expenses for the entire 2019 were

$67,270 and payroll expenses for the entire 2020 were approximately $80,000.




                                       Page 10 of 16
     Case 3:24-cr-00009-JMK-MMS Document 2 Filed 01/18/24 Page 10 of 16
      35.    Defendant further represented that the total number of AKBS employees

was 71, but according to filings certified by Defendant to the DOL, DOR, and IRS,

AKBS had, at most, 19 employees.

      36.    The SBA approved the first PPP Loan Forgiveness Application on March

10, 2021, and paid Alaska USA a total of $201,643.84 in principal and interest payments.

But for the false statements, the SBA would not have approved the loan forgiveness.

Forgiveness of the Second PPP Loan

      37.    On July 8, 2021, Defendant submitted a PPP Loan Forgiveness Application

for the second draw PPP loan (covered period of 2/3/2021 to 6/30/2021). The application

contained material false statements. Defendant represented that payroll expenses for the

applicable period were $752,550.45 when, according to filings certified by Defendant to

the DOL, payroll expenses for the entire 2020 were approximately $80,000 and payroll

expenses for the first and second quarter of 2021 were $138,549.

      38.    Defendant further represented that the total number of AKBS employees

was 54, but, according to filings certified by Defendant to DOL, AKBS had five

employees.

      39.    The SBA approved the second PPP Loan Forgiveness Application on July

20, 2021, and paid Alaska USA a total of $293,911.62 in principal and interest payments.

But for the false statements, the SBA would not have approved the loan forgiveness.




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     Case 3:24-cr-00009-JMK-MMS Document 2 Filed 01/18/24 Page 11 of 16
                                        COUNTS 1-4
                               (Wire Fraud - 18 U.S.C. § 1343)

         40.    The allegations contained in paragraphs 1 to 39 are hereby incorporated by

reference.

         41.    On or about the dates set forth in the separate counts below, within the

District of Alaska, Defendant did knowingly, and with intent to defraud, devise and

intend to devise a scheme and artifice to defraud as to a material matter and to obtain

money and property by means of materially false and fraudulent pretenses,

representations, and promises, and by concealment of material facts, and, for the purpose

of executing such scheme and artifice and attempting to do so, did transmit and cause to

be transmitted, by means of wire communication in interstate commerce, certain writings,

signs and signals, namely:

 COUNT              DATE                        DESCRIPTION OF WIRE
                                                   COMMUNICATION
     1         April 1, 2020     EIDL Application from servers in the State of Alaska to
                                 SBA servers in the State of Washington
     2         April 24, 2021    EIDL Increase Application from servers in the State of
                                 Alaska to SBA servers in the State of Washington
     3         February 23, 2021 PPP Loan (1st Draw) Forgiveness Application from
                                 servers in the State of Alaska to SBA servers in the State
                                 of Oregon
     4         July 8, 2021      PPP Loan (2nd Draw) Forgiveness Application from
                                 servers in the State of Alaska to SBA servers in the State
                                 of Oregon

         All in violation of Title 18, United States Code, Section 1343.




                                        Page 12 of 16
     Case 3:24-cr-00009-JMK-MMS Document 2 Filed 01/18/24 Page 12 of 16
                                      COUNT 5
                            (Bank Fraud - 18 U.S.C. § 1344)

      42.    The allegations contained in paragraphs 1 to 39 are hereby incorporated by

reference.

      43.    On or about April 29, 2020, within the District of Alaska, Defendant did

knowingly execute said scheme or artifice to defraud Alaska USA, a federally insured

financial institution, of something of value, and obtain money or property from Alaska

USA by means of materially fraudulent pretenses and representations, in that Defendant

applied for and obtained a PPP loan of $200,000 from Alaska USA while knowingly and

willfully misrepresenting AKBS’s average monthly payroll and number of employees.

      All in violation of Title 18, United States Code, Section 1344.

                                      COUNT 6
                            (Bank Fraud - 18 U.S.C. § 1344)

      44.    The allegations contained in paragraphs 1 to 39 are hereby incorporated by

reference.

      45.    On or about January 27, 2021, within the District of Alaska, Defendant did

knowingly execute said scheme or artifice to defraud Alaska USA, a federally insured

financial institution, of something of value, and obtain money or property from Alaska

USA by means of materially fraudulent pretenses and representations, in that Defendant

applied for and obtained a PPP loan of $292,573.00 from Alaska USA while knowingly

and willfully misrepresenting AKBS’s average monthly payroll and number of

employees.

      All in violation of Title 18, United States Code, Section 1344.

                                     Page 13 of 16
     Case 3:24-cr-00009-JMK-MMS Document 2 Filed 01/18/24 Page 13 of 16
                                     COUNTS 7-12
                           (Money Laundering – 18 U.S.C. § 1957)

         46.    The allegations contained in paragraphs 1 to 39 are hereby incorporated by

reference.

         47.    On or about the dates set forth in the chart below for Counts 7-12, in the

District of Alaska, Defendant did knowingly engage and attempt to engage in a monetary

transaction by, through or to a financial institution, affecting interstate or foreign

commerce, in criminally derived property of a value greater than $10,000, to wit: the

withdrawal, deposit, and transfer of EIDL proceeds from and to the financial institutions

identified below, such property, having been derived from specified unlawful activity,

that is, wire fraud and bank fraud:

 COUNT      DATE                   DESCRIPTION OF MONETARY TRANSACTION
   7   July 14, 2021             Defendant transferred the amount of $11,401.92 from
                                 AKBS’s Northrim Bank account -3595 to the IRS to
                                 satisfy M&C’s federal tax lien
     8         July 14, 2021     Defendant transferred the amount of $20,831.48 from
                                 AKBS’s Northrim Bank account -3595 to the IRS to
                                 satisfy M&C’s federal tax lien
     9         July 14, 2021     Defendant transferred the amount of $65,005.04 from
                                 AKBS’s Northrim Bank account -3595 to the IRS to
                                 satisfy M&C’s federal tax lien
    10         July 15, 2021     Defendant transferred the amount of $80,000 from
                                 AKBS’s Northrim Bank account -3595 to Northrim Bank
                                 account -7636
    11         July 20, 2021     Defendant obtained a cashier’s check from AKBS’s
                                 Northrim Bank account -3595 in the amount of $150,000
                                 and deposited it into AKBS’s new Northern Skies account
                                 -588
    12         August 2, 2021    Defendant obtained a cashier’s check from AKBS’s
                                 Northrim Bank account -3595 in the amount of $76,012.36
                                 and deposited it into AKBS’s new Northern Skies account
                                 -588


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     Case 3:24-cr-00009-JMK-MMS Document 2 Filed 01/18/24 Page 14 of 16
       All in violation of Title 18, United States Code, Section 1957.

                      CRIMINAL FORFEITURE ALLEGATION 1

       48.    Upon conviction of the wire fraud and bank fraud offenses alleged in

Counts 1 through 6 of this Indictment, defendant shall forfeit to the United States

pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c) any and all property, real

or personal, involved in or derived from said offense and all property traceable to such

property, including but not limited to a money judgment for a sum of money equal to the

amount of property involved in or derived from that offense.

                      CRIMINAL FORFEITURE ALLEGATION 2

       49.    Upon conviction of the money laundering offenses alleged in Counts 7

through 12 of this Indictment, defendant shall forfeit to the United States pursuant to

18 U.S.C. § 981(a)(1)(A) and 28 U.S.C. § 2461(c) any property, real or personal,

involved in a transaction or attempted transaction in violation of 18 U.S.C. § 1957, or any

property traceable to such property

       50.    If the above-described forfeitable property identified in Criminal Forfeiture

Allegations 1 or 2, as a result of any act or omission of defendant:

              a.     cannot be located upon the exercise of due diligence;

              b.     has been transferred or sold to, or deposited with, a third party;

              c.     has been placed beyond the jurisdiction of the court;

              d.     has been substantially diminished in value; or




                                       Page 15 of 16
     Case 3:24-cr-00009-JMK-MMS Document 2 Filed 01/18/24 Page 15 of 16
            e.     has been commingled with other property which cannot be divided

            without difficulty; the United States of America shall be entitled to

            forfeiture of substitute property pursuant to 21 U.S.C. § 853(p), as

            incorporated by 28 U.S.C. § 2461(c)


      A TRUE BILL


                                             s/ Grand Jury Foreperson
                                             GRAND JURY FOREPERSON



s/ Michael J. Heyman
MICHAEL J. HEYMAN
Assistant U.S. Attorney
United States of America




s/ S. Lane Tucker
S. LANE TUCKER
United States Attorney




DATE:        1/16/2024




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