Indictment — United States v. Shaquandra Woods et al., Southern District of Georgia (Document 1)
Summary
An Indictment in United States of America v. Shaquandra Woods, Courtney Gilchrist, and Kenneth Jackson, Case 4:22-cr-00016-RSB-CLR, in the U.S. District Court for the Southern District of Georgia, Savannah Division, Document 1, filed 02/02/22. The caption lists 18 U.S.C. § 1349 Conspiracy to Commit Wire Fraud, 18 U.S.C. § 1014 False Statement on a Loan Application, 18 U.S.C. § 1001(a)(3) False Document and 18 U.S.C. § 1001(a)(2) False Statement. It alleges that the defendants fraudulently sought and collectively received hundreds of thousands of dollars in relief payments by making false representations to the SBA. Count One alleges a conspiracy beginning in or around May of 2020 and continuing through in or around May of 2021 to obtain EIDL proceeds.
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“Indictment — United States v. Shaquandra Woods et al., Southern District of Georgia (Document 1).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-4-22-cr-00016-dkt-1-438ea3308d/
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Case 4:22-cr-00016-RSB-CLR Document 1 Filed 02/02/22 Page 1 of 19
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION CR
INDICTMENT NO,
42^-0016
UNITED STATES OF AMERICA
18 U.S.C. § 1349
Conspiracy to Commit Wire
V. Fraud
18 U.S.C. § 1014
False Statement on a Loan
SHAQUANDRA WOODS, Application
COURTNEY GILCHRIST, and
KENNETH JACKSON 18 U.S.C. § 1001(a)(3)
False Document
18 U.S.C. § 1001(a)(2)
False Statement
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THE GRAND JURY CHARGES THAT: c.o
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At times relevant to this Indictment:
Background /r -q
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1. The Coronavirus Aid, Relief, and Economic Security AREg)A5t was
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a federal law enacted in or about March 2020 that was designed to provide emergency
financial assistance to the millions who were suffering the economic effects caused by
the COVID-19 pandemic.
2. Among other relief efforts, the United States sought to provide financial
support to eligible businesses that could be used to offset certain business expenses.
3. Defendants SHAQUANDRA WOODS, COURTNEY GILCHRIST,
and KENNETH JACKSON fraudulently sought and collectively received hundreds
Case 4:22-cr-00016-RSB-CLR Document 1 Filed 02/02/22 Page 2 of 19
of thousands of dollars in relief payments by making false and fraudulent
representations to the Small Business Administration ("SBA").
The Defendants
4. SHAQUANDRA WOODS was an individual residing in Jacksonville,
Florida. WOODS was an attorney licensed to practice law in the States of Georgia
and Florida. WOODS conspired with COURTNEY GILCHRIST and KENNETH
JACKSON to submit fraudulent loan applications to the SBA.
5. COURTNEY GILCHRIST was an individual residing in Savannah,
Georgia, in the Savannah Division of the Southern District of Georgia. GILCHRIST
was an attorney licensed to practice law in the State of Georgia. GILCHRIST
conspired with SHAQUANDRA WOODS to submit a fraudulent loan application to
the SBA.
6. KENNETH JACKSON was an individual residing in Savannah,
Georgia, in the Savannah Division of the Southern District of Georgia. JACKSON
conspired with SHAQUANDRA WOODS to submit a fraudulent loan application to
the SBA.
Defendants' Purported Businesses
7. "EZ Legal Solutions, LLC" was a hmited liability company that was
registered with the State of Florida on or around June 16, 2020. SHAQUANDRA
WOODS was the registered agent of"EZ Legal Solutions, LLC."
Case 4:22-cr-00016-RSB-CLR Document 1 Filed 02/02/22 Page 3 of 19
8. Company 1 was a limited liability company that was registered with the
State of Florida on or around May 19, 2020. Co-Conspirator 1 was the registered
agent of Company 1.
9. Company 2 was a Savannah, Georgia-based unincorporated business
services company purportedly established on May 13, 2016. Company 2 was
purportedly owned by COURTNEY GILCHRIST.
10. Company 3 was a Savannah, Georgia-based unincorporated personal
services company purportedly established on May 23, 2001. Company 3 was
purportedly owned by KENNETH JACKSON.
The Coronavirus Aid. Relief, and Economic Securitv Act
11. The SBA was an executive branch agency of the United States
government that provided support to entrepreneurs and smaU businesses. The SBA
was headquartered in Washington, DC and maintained its computer servers outside
of the State of Georgia. The SBA's mission was to maintain and strengthen the
nation's economy by enabling the establishment and viability ofsmall businesses and
by assisting in the economic recovery of communities after disasters.
12. As part of this effort, the SBA enabled and provided for loans through
banks, credit unions, and other lenders. These loans had government-backed
guarantees. In addition, the SBA provided loans that came directly from the U.S.
Government.
13. One source of relief provided by the CARES Act was the authorization
for the SBA to provide Economic Injury Disaster Loans ("EIDL") to eligible small
Case 4:22-cr-00016-RSB-CLR Document 1 Filed 02/02/22 Page 4 of 19
businesses experiencing substantial financial disruption due to the COVID-19
pandemic.
14. In order to obtain an EIDL, a qualifying business had to submit an
online application to the SBA and provide information about its operations, such as
the number of employees, gross revenues for the twelve-month period preceding the
disaster, and the cost of goods the business sold in the twelve-month period preceding
the disaster. In the case of EIDLs, the twelve-month period was that preceding
January 31, 2020. The applicant also had to certify that all the information in its
application was true and correct to the best of the applicant's knowledge.
15. EIDL applications were submitted directly to the SBA online at
https://covidl9relief.sba.gOv/#/ and processed by the agency with support from a
government contractor, Rapid Finance. The amount of each loan was determined
based, in part, on the information provided by the application about employment,
revenue, and cost of goods, as described above. Any funds issued under an EIDL were
issued directly by the SBA.
16. EIDL funds could be used for payroll expenses, sick leave, production
costs, and business obligations, such as debts, rent, and mortgage payments.
Case 4:22-cr-00016-RSB-CLR Document 1 Filed 02/02/22 Page 5 of 19
COUNT ONE
Conspiracy to Commit Wire Fraud
18 U.S.C. § 1349
17. The Grand Jury re-alleges and incorporates by reference the allegations
in paragraphs 1 through 16 of this Indictment.
18. Beginning in or around May of 2020, and continuing through in or
around May of 2021, in Chatham County, within the Southern District of Georgia,
and elsewhere, the defendants,
SHAQUANDRA WOODS,
COURTNEY GILCHRIST,
and
KENNETH JACKSON
did conspire and agree with each other, and others known and unknown to the Grand
Jury, to commit an offense against the United States, that is, to knowingly and with
the intent to defraud, devise and intend to devise a scheme and artifice to defraud,
and for obtaining money and property by means of materially false and fraudulent
pretenses, representations, and promises, knowing the pretenses, representations,
and promises were false and fraudulent when made, and for the purpose of executing
the scheme and artifice, did knowingly transmit and cause to be transmitted by
means of wire communication in interstate commerce, certain writings, signs,
signals, pictures, and sounds for the purpose of executing such scheme and artifice to
defraud, in violation of Title 18, United States Code, Section 1343.
Object of the Consniracv
19. It was the object of the conspiracy for WOODS, GILCHRIST, and
JACKSON,and others, to unlawfully enrich themselves by obtaining EIDL proceeds
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