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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).

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

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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/, SHA-256 c746603f96c771ccd77d772c210c7ee4fe719bd80ca1876a4f1d8bafe55c0ecf.

Full text

     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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