Superseding Indictment — United States v. Shaquandra Woods et al., Southern District of Georgia (Document 87)
Summary
Superseding Indictment filed June 9, 2022 as Document 87 in United States of America v. Shaquandra Woods, Courtney Gilchrist and Kenneth Jackson, No. 4:22-cr-016 (4:22-cr-00016-RSB-CLR), U.S. District Court, Southern District of Georgia, Savannah Division. Count One charges conspiracy to commit wire fraud under 18 U.S.C. § 1349, alleging that beginning in or around May of 2020 and continuing through in or around May of 2021 the defendants conspired to obtain EIDL proceeds by making false statements about their purported businesses' dates of establishment and gross revenues. The manner and means paragraphs allege EIDL applications, including a loan agreement to receive $149,900 and another to receive $150,000. Counts Two through Four charge false claims under 18 U.S.C. § 287 and Counts Five and Six charge false documents under 18 U.S.C. § 1001(a)(3).
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“Superseding Indictment — United States v. Shaquandra Woods et al., Southern District of Georgia (Document 87).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-4-22-cr-00016-dkt-87-7711f9b8f1/
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Case 4:22-cr-00016-RSB-CLR Document 87 Filed 06/09/22 Page 1 of 18
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION CCUIT
mi jm -q p 12: S3
UNITED STATES OF AMERICA SUPERSEDING INDICTMENT NO.
4:22-cr-016 CLER:
U:c L ! r •. '• H-
18 U.S.C. § 1349
V. Conspiracy to Commit Wire Fraud
18 U.S.C. §287
False, Fictitious, or Fraudulent
SHAQUANDRA WOODS, Claims
COURTNEY GILCHRIST,and
KENNETH JACKSON 18 U.S.C. § 1001(a)(3)
False Document
18 U.S.C. § 1001(a)(2)
False Statement
THE GRAND JURY CHARGES THAT:
At times relevant to this Superseding Indictment:
Background
1. The Coronavirus Aid, Relief, and Economic Security("CARES")Act was
a federal law enacted in or about March 2020 that was designed to provide emergency
financial assistance to the milhons 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 87 Filed 06/09/22 Page 2 of 18
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 limited 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 87 Filed 06/09/22 Page 3 of 18
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 small 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 87 Filed 06/09/22 Page 4 of 18
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 aU 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 87 Filed 06/09/22 Page 5 of 18
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 Superseding 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
Case 4:22-cr-00016-RSB-CLR Document 87 Filed 06/09/22 Page 6 of 18
under false and fraudulent pretenses and representations, including by making false
statements about their purported businesses' dates of establishment and gross
revenues for the twelve-month period prior to the date of the disaster.
Manner and Means
20. The manner and means by which WOODS, GILCHRIST, and
JACKSON, and others, sought to accomplish the object of the conspiracy included,
among others, the following:
a. On or about June 17, 2020, WOODS submitted, or caused to be
submitted, an electronic application for an EIDL from the SBA on
behalf of EZ Legal Solutions, LLC ("EIDL Application -6118"). In
connection with EIDL Application -6118, WOODS falsely affirmed
that EZ Legal Solutions, LLC was established February 1, 2019 and
had $300,000 in gross revenue in the twelve months prior to January
31, 2020.
b. On or about June 23, 2020, WOODS submitted, or caused to be
submitted, an electronic application for an EIDL from the SBA on
behalf of Company 1("EIDL Application -7005"). In connection with
EIDL Application -7005, WOODS falsely affirmed that Company 1
was established January 1, 2001 and had $325,000 in gross revenue
in the twelve months prior to January 31, 2020,
c. On or about July 3, 2020, in connection with EIDL Application -7005,
WOODS uploaded to the SBA a fake Form 1099-MISC tax document
Case 4:22-cr-00016-RSB-CLR Document 87 Filed 06/09/22 Page 7 of 18
that showed that Co-Conspirator 1 had 2019 nonemployee
compensation of $325,000.
d. On or about July 12, 2020, WOODS and JACKSON submitted, or
caused to be submitted, an electronic application for an EIDL from
the SBA on behalf of Company 3 ("EIDL Application -0870"). In
connection with EIDL Application -0870, WOODS and JACKSON
falsely affirmed that the Company 3 had $220,000 in gross revenue
in the twelve months prior to January 31, 2020.
e. On or about July 14, 2020, WOODS and GILCHRIST submitted, or
caused to be submitted, an electronic application for an EIDL from
the SBA on behalf of Company 2 ("EIDL Application -1901"). In
connection with EIDL Application -1901, WOODS and GILCHRIST
falsely affirmed that Company 2 had $330,000 in gross revenue in
the twelve months prior to January 31, 2020.
f. On or about July 21, 2020, in connection with EIDL Application -
6118,WOODS uploaded to the SBA a fake operating agreement that
falsely claimed that EZ Legal Solutions, LLC was formed in 2019 and
filed its Articles of Organization with the State of Florida on
February 1, 2019.
g. On or about July 21, 2020, in connection with EIDL Application-
6118,WOODS signed a loan agreement to receive $149,900 from the
SBA on behalf of EZ Legal Solutions, LLC,in which WOODS falsely
Case 4:22-cr-00016-RSB-CLR Document 87 Filed 06/09/22 Page 8 of 18
certified that all representations in EZ Legal Solutions, LLC's loan
application, and all supplementary submissions to the SBA, were
true, correct, and complete.
h. On or about July 30, 2020, in connection with EIDL Application -
0880, WOODS paid Co-Conspirator 2 to create a fake Form 1099-
MISC tax document that showed that JACKSON had 2019
nonemployee compensation of $220,000. WOODS, knowing the
document to be fake, then uploaded the fake tax document to the
SBA.
i. On or about August 18, 2020, in connection with EIDL Application -
1901, GILCHRIST and WOODS uploaded to the SBA a fake Form
1040 Schedule C tax document that showed that GILCHRIST had
2019 gross receipts of $330,000 to match GILCHRIST's EIDL
application that had falsely claimed GILCHRIST had a business
with $330,000 in gross revenue in the twelve months prior to
January 31, 2020.
j. On or about August 27, 2020, in connection with EIDL Application -
1901, GILCHRIST signed a loan agreement to receive $150,000
fi:om the SBA on behalf of Company 2, in which GILCHRIST falsely
certified that all representations in Company 2's loan application,
and all supplementary submissions to the SBA, were true, correct,
and complete.
Case 4:22-cr-00016-RSB-CLR Document 87 Filed 06/09/22 Page 9 of 18
k. On or about September 4, 2020, after receiving $150,000 from the
SBA on behalfof Company 2, GILCHRIST wrote a check for $10,000
to WOODS as compensation for WOODS helping GILCHRIST
obtain Company 2's EIDL.
All done in violation of Title 18, United States Code, Section 1349.
Case 4:22-cr-00016-RSB-CLR Document 87 Filed 06/09/22 Page 10 of 18
COUNT TWO
False, Fictitious, or Fraudulent Claims
18 U.S.C. § 287 and 2
21. The Grand Jury re-alleges and incorporates by reference the allegations
in paragraphs 1 through 16 of this Superseding Indictment.
22. On or about July 12, 2020, in the Southern District of Georgia, and
elsewhere, the Defendant
SHAQUANDRA WOODS
aided and abetted by others, made and presented to the SBA a claim upon the United
States and the SBA, that is, an application for an EIDL on behalf of Company 3 in
which WOODS falsely stated that Company 3 had $220,000 in gross revenue in the
twelve months prior to January 31, 2020, knowing that the claim was false in that,
as WOODS then and there well knew. Company 3 did not have $220,000 in gross
revenue in the twelve months prior to January 31, 2020.
All in violation of Title 18 United States Code, Sections 287 and 2.
10
Case 4:22-cr-00016-RSB-CLR Document 87 Filed 06/09/22 Page 11 of 18
COUNT THREE
False, Fictitious, or Fraudulent Claims
18 U.S.C. § 287 and 2
23. The Grand Jury re-alleges and incorporates by reference the allegations
in paragraphs 1 through 16 of this Superseding Indictment.
24. On or about July 14, 2020, in the Southern District of Georgia, and
elsewhere, the Defendants
SHAQUANDRA WOODS
and
COURTNEY GILCHRIST
aided and abetted by each other and others, made and presented to the SBA a claim
upon the United States and the SBA,that is, an application for an EIDL on behalf of
Company 2 in which WOODS and GILCHRIST falsely stated that Company 2 had
$330,000 in gross revenue in the twelve months prior to January 31, 2020, knowing
that the claim was false in that, as WOODS and GILCHRIST then and there well
knew. Company 2 did not have $330,000 in gross revenue in the twelve months prior
to January 31, 2020.
All in violation of Title 18 United States Code, Sections 287 and 2.
11
Case 4:22-cr-00016-RSB-CLR Document 87 Filed 06/09/22 Page 12 of 18
COUNT FOUR
False, Fictitious, or Fraudulent Claims
18 U.S.C. § 287 and 2
25. The Grand Jury re-alleges and incorporates by reference the allegations
in paragraphs 1 through 16 of this Superseding Indictment.
26. On or about August 27, 2020, in the Southern District of Georgia, and
elsewhere, the Defendant
COURTNEY GILCHRIST
aided and abetted by others, made and presented to the SBA a claim upon the United
States and the SBA, that is, a loan agreement with the SBA on behalf of Company 2
in which GILCHRIST certified that Company 2's EIDL application and
supplementary submissions were true, correct, and complete, knowing that the claim
was false in that, as GILCHRIST then and there well knew. Company 2's EIDL
application reported a false gross revenue figure and that the conspirators had
submitted a falsified tax document as a supplementary submission to the SBA.
All in violation of Title 18 United States Code, Sections 287 and 2.
12
Case 4:22-cr-00016-RSB-CLR Document 87 Filed 06/09/22 Page 13 of 18
COUNT FIVE
False Document
18 U.S.C. §§ 1001(a)(3) and 2
27. The Grand Jury re-alleges and incorporates by reference the allegations
in paragraphs 1 through 16 of this Superseding Indictment.
28. On or about July 30, 2020, in the Southern District of Georgia, and
elsewhere, the Defendant
SHAQUANDRA WOODS
aided and abetted by others, did willfully and knowingly make and use a false writing
and document, knowing the same to contain a materially false, fictitious, and
fraudulent statement and entry in a matter within the jurisdiction of the executive
branch of the Government of the United States, by transmitting to the SBA a tax
document that falsely stated that KENNETH JACKSON had 2019 nonemployee
compensation of $220,000, when in fact, as WOODS then and there well knew, the
transmitted tax document contained false data.
All in violation of Title 18, United States Code, Section 1001(a)(3) and 2.
13
Case 4:22-cr-00016-RSB-CLR Document 87 Filed 06/09/22 Page 14 of 18
COUNT SIX
False Document
18 U.S.C. §§ 1001(a)(3) and 2
29. The Grand Jury re-alleges and incorporates by reference the allegations
in paragraphs 1 through 16 of this Superseding Indictment.
30. On or about August 18, 2020, in the Southern District of Georgia, and
elsewhere, the Defendants
SHAQUANDRA WOODS
and
COURTNEY GILCHRIST
aided and abetted by each other and others, did willfully and knowingly make and
use a false writing and document, knowing the same to contain a materially false,
fictitious, and fi'audulent statement and entry in a matter within the jurisdiction of
the executive branch of the Government of the United States, by transmitting to the
SBA a tax document that falsely stated that GILCHRIST had 2019 gross receipts of
$330,000, when in fact, as WOODS and GILCHRIST then and there well knew, the
transmitted tax document contained false data.
All in violation of Title 18, United States Code, Section 1001(a)(3) and 2.
14
Case 4:22-cr-00016-RSB-CLR Document 87 Filed 06/09/22 Page 15 of 18
COUNT SEVEN
False Statement
18 U.S.C. §§ 1001(a)(2)
31. The Grand Jury re-alleges and incorporates by reference the allegations
in paragraphs 1 through 16 of this Superseding Indictment.
32. On or about August 13, 2021, in the Southern District of Georgia, and
elsewhere, the Defendant
COURTNEY GILCHRIST
did willfully and knowingly make a materially false, fictitious, and firaudulent
statement and representation in a matter within the jurisdiction of the executive
branch of the Government of the United States, to wit, during an interview in
Savannah, Georgia with federal agents about GILCHRIST's purported business
with $330,000 in gross revenue, GILCHRIST falsely stated that she operated a
business independent of her employment with a law firm that involved GILCHRIST
speaking at seminars, workshops, an continuing legal education events; that her
business hired an employee who acted as the business's secretary; and that she only
knew of SHAQUANDRA WOODS in passing, when in truth and fact as
GILCHRIST then and there knew, GILCHRIST did not operate such a business,
did not employ a secretary, and knew WOODS personally and communicated with
WOODS regularly.
All in violation of Title 18, United States Code, Section 1001(a)(2).
15
Case 4:22-cr-00016-RSB-CLR Document 87 Filed 06/09/22 Page 16 of 18
COUNT EIGHT
False Statement
18 U.S.C. §§ 1001(a)(2)
33. The Grand Jury re-alleges and incorporates by reference the allegations
in paragraphs 1 through 16 of this Superseding Indictment.
34. On or about October 4, 2021, in the Southern District of Georgia, and
elsewhere, the Defendant
KENNETH JACKSON
did willfully and knowingly make a materially false, fictitious, and fraudulent
statement and representation in a matter within the jurisdiction of the executive
branch of the Government of the United States, to wit, during an interview with a
Special Agent firom the Savannah Office of the Federal Bureau of Investigation,
JACKSON stated that he operated a business that generated $220,000 in gross
revenue prior to the COVID-19 pandemic and that SELAQUANDRA WOODS had no
involvement with his EIDL Application, when in truth and fact as JACKSON then
and there knew, JACKSON did not operate such a business that generated $220,000
in gross revenue and that WOODS had been involved in JACKSON'S EIDL
Application.
All in violation of Title 18, United States Code, Section 1001(a)(2).
16
Case 4:22-cr-00016-RSB-CLR Document 87 Filed 06/09/22 Page 17 of 18
FORFEITURE ALLEGATIONS
The allegations contained in Counts One through Eight of this Superseding
Indictment are hereby re-alleged and incorporated by reference for the purpose of
alleging forfeitures pursuant to Title 18, United States Code, Sections 981(a)(1)(C),
982(a)(3), and Title 28, United States Code, Section 2461(c).
Upon conviction of the offense set forth in Count One of the defendant,
SHAQUANDRA WOODS, COURTNEY GILCHRIST, and KENNETH
JACKSON, shall forfeit to the United States pursuant to Title 18, United States
Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c), any
property, real or personal, which constitutes or is derived from proceeds traceable to
a violation.
Additionally, upon conviction of the offenses set forth in Counts Two through
Eight defendants, SHAQUANDRA WOODS, COURTNEY GILCHRIST, and
KENNETH JACKSON, shall forfeit to the United States pursuant to Title 18,
United States Code, Section 982(a)(3), any property, real or personal, which
represents or is traceable to the gross receipts obtained, directly or indirectly, as a
result of the violation.
If any of the property described above, as a result of any act or commission of
the 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
17
Case 4:22-cr-00016-RSB-CLR Document 87 Filed 06/09/22 Page 18 of 18
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 Title 21, United States Code, Section 853(p), as incorporated by Title 28,
United States Code, Section 2461(c).
A True Bill.
)
Fore
David H. Estes Joiiath^ A. Porter
United States Attorney Assistant United States Attorney
*Lead Counsel
Patricia G. Rhodes Patrick J. Schwedler
Assistant United States Attorney Assistant United States Attorney
Chief, Criminal Division *Co-lead Counsel
18
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