Indictment — United States v. Terrell Alexander, Eastern District of Missouri (Doc. 2)

Summary

A grand jury indictment against Terrell Alexander, Case 4:22-cr-00169-JAR-PLC, filed March 30, 2022 as Doc. 2 in the U.S. District Court for the Eastern District of Missouri, Eastern Division. It charges wire fraud under 18 U.S.C. § 1343 over COVID-19 Economic Injury Disaster Loan applications to the Small Business Administration. The indictment alleges the defendant caused EIDL applications to be submitted for real, fictional and inactive businesses, including Direct Management, LLC, Total CPA, LLC and Precision Safe Healthcare, LLC, using Social Security Numbers not assigned to him and false revenue figures. It alleges that the Direct Management application reported gross revenues of $759,000 and that the SBA issued a loan of $150,000 on July 8, 2020. The forfeiture allegation lists funds in bank accounts, and the signature block names United States Attorney Sayler A. Fleming.

Summary drafted by a model from the text of the original file linked on this page 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

Cite this document

“Indictment — United States v. Terrell Alexander, Eastern District of Missouri (Doc. 2).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-4-22-cr-00169-dkt-2-e-d-mo-e64a86d212/, SHA-256 42d9cbc69ef58899ebb5ca164051870835c5dd04048c51fcbd0a408f9f1e4851.

Full text

Case: 4:22-cr-00169-JAR-PLC Doc. #: 2 Filed: 03/30/22 Page: 1 of 17 PageID #: 21

FILED
I MAR 3O20~
UNITED STATES DISTRICT COURT
t::Aus. s. DISTRICT'COURT
EASTERN DISTRICT OF MISSOURI _,, TERN DISTRICT OF MO
EASTERN DIVISION ST. LOUIS

UNITED STATES OF AMERICA, )
)
_Plaintiff, )
)
v .. )
) No. 4:22-CR-00169-JAR-PLC
)
TERRELi,, ALEXANDER, )
I
)
Defendant. )

INDICTMENT

The Grand Jury Charges:
BACKGROUND·

At all times relevant to the Indictment:

1. The defendant Terrell Alexander resided in the Ea~tem District of Missouri.

2. The Small Business Administration was part of the executive branch of the .

Government of the United States.
\

3. The Small Business Administration (SBA) provided COVID-19 Economic Injury

Disaster Loans (EIDL), pursu~t to the Coronavirus Aid, Relief, and Economic Security Act (the

CARES Act) which was signed into law in March 2020. The CARES Act, in conjunction with an

officially declared disaster by the United States Government, allowed for the SBA to offer the

EIDL funding to business owners negatively affected by the COVID-19 pandemic.

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4. EIDL applications were submitted,via the SBA online portal. Applicants submitted

their personal and business information in support of each EIDL application, including the size of

the affected business, the ownership of the business, number of employees for the business, and

gross business revenues realized in the 12 months prior to COVID-19 impact on the national

economy.

5. In addition to EIDL funding, applicants could also request and receive up to

$10~000.00 in an EIDL Cash Advance Grant, based on the number of employees claimed. That

grant was not required to be repaid.
\.
6. EIDL applications included a paragraph wherein the applicant affirmed that the

information submitted is true and correct under the penalty of perjury and applicable criminal

statutes.

7. The servers receiving the EIDL applications via the SBA online portal were located.

in Virginia, Iowa, and Washington state.

8. All of the loans and other payments referenced herein were1 made by the Small

Business Administration (SBA).

COUNTSlTHROUGHl0
18 U.S.C. § 1343: Wire Fraud

THE SCHEME TO DEFRAUD '
(
9. The allegations in Paragraphs 1 through 8 are hereby realleged and incorporated

herein.

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10. The defendant, TERRELL ALEXANDER, caused to be prepared and submitted to

. the Small Business Administration multiple applications for EIDL loans for multiple bus~esses,

said businesses representing real businesses, fictional businesses, and new or inactive businesses.

'i 11. The defendant caused the electronic submission of these applications from the

Eastern District of Missouri via the SBA portal for EIDL loans.

12. Following the submission of these applications as described below, the SBA issued

the EIDL funding, either as.Jan advance or as a loan, which was electronically t~ansmitted from the-

SBA to bank accounts controlled by the defendant.

13. Following the transmission of the EIDL funding to the bank accounts under the

defendant's control, __ the money was then wire transferred or otherwise moved among the

defendant's multiple bank accounts.

MANNER AND MEANS

14. It was part of the scheme that on or about June 25, 2020, the defendant, TERRELL
'
ALEXANDER, caused the submission of an EIDL loan application in the name of Direct

Management, LLC. In the application, the defendant falsely stated that the Social Security Number

assigned to him by the Commissioner of the Social Security Administration was ***-**-2710

when, in truth and in fact, that Social Security Number was assigned to a minor child and, as the

defendant well knew, the number was not his assigned Social Security Number. Additionally, the
I
defendant stated that Direct Management, LLC, had gross revenues of $759,000 for the 12 months

prior· to the pandemic when, in truth and in fact and as the defendant well knew, Direct

Management, LLC, had much smaller gross revenues. As a result of the false and fraudulent

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representations submitted by the defendant in the Direct Management, tLC loan application, the

SBA approved an advance of $1,000 on June 27, 2020, and the SBA issued a loan of $150,000 on

July 8, 2020. The advance and the loan were deposited into Regions Bank Account *****1334.

The defendant was the signatory for this bank account.

15. It was further part of the scheme that on or about July 4, 2020, the defendant,

TERRELL ALEXANDER, caused the submission of an EIDL loan application in the name of

Ferrell Thomas. In the application, the defendant falsely stated that he was Ferrell Thomas, and

the Social Security Number assigned to him by the Commissioner of the Social Security

Administration was ***-**-9003 when, in truth and in fact, that Social Security Number is

assigned to another individual and, as the defendant well knew, Ferrell Thomas is a fictitious

individual and the Driver's License submitted by the defendant as part of the EIDL loan application

was fi1lse and fraudulent. Additionally, the defendant repres~nted that Ferrell Thomas's busin_ess

had gross revenues of $108,435 for the 12 months prior to the pandemic, and 27 employees when,

in truth and in fact and as the defendant well knew, Ferrell Thomas did not operate a legitimate

business. As a result of the false and fraudulent representations submitted by the defendant in the

Ferrell Thomas loan application, the SBA issued a loan of$25,300 on July 22, 2020. The loan was
I

deposited into Alli8:Ilt Credit Union Account ***** *****997. The defendant was signatory on that

account using the name Ferrell Thomas.

16. It was further part of the scheme that on or about July'28, 2020, the defendant,

TERRELL ALEXANDER, caused the submission of an EIDL loan application in the name of

Qutumn Management, LLC. In the application, the defendant falsely stated that the Social Security

4
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Number assigned to him by the Commissioner of the Social Security Administration was***-**-

8320 when, in truth and in fact and as the defendant well knew, the number was not his assigned

Social Security Number. Additionally, the defendant stated on the EIDL application that he was

the owner and manager of Qutumn Management, LLC when, in truth and in fact as the Defendant

well knew, Qutumn Management, LLC was registered with the Secretary of State of Missouri by

another individual, T.A. Additionally, the defendant submitted as part of this application a

Missouri driver's license that was not his properly issued Missouri driver's license, and a false and

:fraudulent Social Security Card containing the defendant's name, and the sbcial Security as

enumerated above. Additionally, the defendant stated on the EIDL application that the detailed

business activity for Qutumn Management, LLC, was restaurant/fine dining with a business

address of 193 9 Wentzville Parkway, Suite 23, Wentzville, Missouri when, in truth and in fact,

that address is the address of a UPS store. As a result of the false and :fraudulent representations

submitted by the defen~ant in the Qutumn Management, LLC loan application, the SBA issued a

loan of $150,000, ·however, the loan was returned to the SBA. The d~fendant contacted the SBA
'
in October 2020, requesting the loan be deposited into Regions Bank Account *****9847. The

defendant was the signatory for this bank account.

17. It was further part of the scheme that on or about August 7, 2020, the defendant,

TERRELL ALEXANDER, caused the submission of an EIDL loan application in the name of

Total CPA, LLC. In the application, the defendant falsely stated that the Social Security Number

assi'gned to him by th~ Commissioner of the Social Security Administration was ***-**-5499
\

whe~, in truth.and in fact and as the defend~t well knew, the number was not his assigned Social

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Security Number. Additionally, the defendant alleged that Total CPA, LLC had been in business

since April 2017 when, in truth and in fact, the Articles of Organization for Total CPA, LLC was

filed with the Secretary of State of Missouri in April 2019. Additionally, the defendant represented

on the EIDL loan application that Total CPA, L~C, had gross revenues of $303,177 for the 12

months prior to the pandemic, and 9 total employees when, in truth and in fact and as the defendant

well knew, Total CPA, LLC, was not an active business with employees. As a result of the false

and fraudulent representations submitted by the defendant in the Total CPA, LLC loan application,

the SBA issued a loan of $1.11,900 on August 9, 2020. The loan was deposited into Regions Bank

Account *****9987. The defendant was the signatory for this bank account.
I
18. It was further part of the scheme that on or about August 10, 2020, the defendant,

TERRELL ALEXANDER, caused the submission of an EIDL loan application in the name of

Precision Safe Healthcare, LLC. In the application, the defendant falsely stated that the Social

Security Number assigned to him by the Commissioner of the Social Security Administration was

***-**-8318 when, in truth and in fact and as the defendant well knew, the number was not his

assigned Social Security Number. Additionally, the defendant represented that Precision Safe

Healthcare, LLC had been in business since August 2, 2017 when, in truth and in fact and as the
',

defendant well knew, the Articles of Organizati6n for Pr~cision Safe Healthcare, LLC was filed

with the Secretary of State of Missouri on August 2, 2020. Additionally, th~ defendant stated- on

the EIDL loan application that Precision Safe Healthcare, LLC, had gross revenues of $312,789

, for the 12 months prior to the pandemic, and 17 total employees when, in truth and in fact and as

the defendant well knew, Precision Safe Healthcare, LLC was not an active business with any

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employees as of the date of the application. As a result of the false and fraudulent representations
)

submitted by the defendant in the Precision Safe Healthcare, LLC loan application, the SBA issued
' I

a loan of $115,800 on August 10, 2020. The loan was sent for deposit to Regions Bank Acco~t

******0012. The defendant was the signatory for this bank account.

19. It was further part of the scheme that on or about June 25, 2020, the defendant,

TERRELL ALEXANDER, caused the submission of an EIDL -loan application in the name of

Florentine Investment, LLC. In the application, the defendant falsely represented himself as S.W.,
I
who is the registered. agent of Florentine
.
Investment, LLC. In falsely representing himself as S. W.,

the defendant caused S.W.'s Personally Identifiable Information, specifically S.W.'s name and

Social Security Number, to be submitted on the application. Additionally, the defendant

represented that Florentine Investment, LLC had gross revenues of $375,000 for the 12 months

prior to the pandemic, and 8 total employees when, in truth and in fact and as the defendant·well
I

knew, Florentine Investment, LLC had significantly smaller gross revenues and 2 total employees.
I
As a result of the false and fraudulent representations submitted by the defendant in the Floreritine

Investment, LLC loan application, the SBA approved an _advance of $8,000 o~ June 25, 2020, and

a loan of $107,000 on July 9, 202b. The loan was deposited into Regions Bank Account

*****9539.

20. It was further .part of the scheme that on or ?,bout July 4, 2020, the defendant,

TERRELL ALEXANDER, caused the submission of an EIDL loan application in the name of

S.W. In the application, the defendant falsely represented himself as S.W. In falsely representing

himself as S.W., the defendant caused S.W.'s Personally Identifiable Information, particularly

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S.W.'s name and Social Security Number, to be submitted on the application. Additionally, the

defendant represented that S.W. 's business had grnss revenues of $137,900 for the 12 months prior

to the pandemic, and 57 total employees when, in truth and in fact and as the defendant well knew,
'
\ '

this information was false. As a result of the false and fraudulent representations submitted by the

defendant in the S.W. loan application, the SBA approved an advance of $10,000 on July 4, 2020,

and a loan of $50,500 on July 22, 2020. The loan was deposited into Regions Bank Account

*****2315.
Ji
21. It was further part of the scheme that on or about July 4, 2020, the defendant,

TERRELL ALEXANDER, caused the submission of an EIDL loan application in the name of

E.M. In the application/ the defendant falsely represented himself as E.M. In falsely representing

himself as E.M., the defendant caused E.M.'s Personally Identifiable Information, specifically

E.M.'s name and date of birth, to be submitted on the application. Additionally, the defendant

represented E.M.'s assigned Social Security Number to be ***-**-3633, which is not E.M.'s

assigned Social Security Number. Additionally, the defendant represented that E.M. had gross

revenues of $112,700 for the 12 months prior to the pandemic, 14 employees, and that E.M.'s

business provided medical services when, in truth and in fact and as the defendant well knew, E.M.

did not run any such business, did not have employees, and had significantly smaller gross

revenues than reported. As a result of the false and fraudulent representations submitted by the

defendant in the E.M. loan application, the. SBA approved an advance of $10,000 on July 4, 2020;

and a loan of $38,000 on July 5, 2020. The advance and the loan were deposited into Pentagon

Federal Credit Union Acco,unt ******4024, a bank account of which E.M. had no knowledge. On

8
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July 10, 2020, $40,000 was;wired from a second Pentagon Federal Credit Union Account, in

E.M.'s name and of which E.M. had no knowledge, Account *****8446, to Regions Bank

Account ******7809. The defendant was a,signatory for this bank account.

22. It was further part of the scheme that on or about July 30, 2020, and August 7, 2020,

the defendant, TERRELL ALEXANDER, caused the submission of two EIDL loan applications,

in the names of JCC Personnel Management, LLC and Top Knotch Marketing, LLC. In the
I

applications, the defendant falsely represented himself as J.C. In falsely representing himself as

J.C., the defendant caused J.C.'s Personally IdentifiableJnformation, particularly J.C.'s name and

Social, Security Number, to be submitted on the applications. Additionally, the defendant
--
represented that JCC Personnel Management Company had gross revenues of$339,899 for the 12
\I ,

months prior to the pandemic, and 37 employees, and the defendant represented that Top Knotch

Marketing, LLC had_gross revenues of $279,999 for the 12 months prior to the pandemic, and 12

employees when, in truth and in fact and as the defendant well knew, these two businesses had no

employees and significantly lower gross revenues. As a_ result of the false and fraudulent

representations submitted by the defendant in the JCC Personnel Management, LLC and Top

Knotch Marketing, LLC loan applications, the SBA issued a loan of $121,200 on August 10, 2020,

and a loan 0{$110,1000 on August 27, 2020. These loans were deposit~d into Regions Bank

Accounts ******9855 and ******9979, respectively. J.C. was the signatory for these bank

accounts. After the deposit of these loans, J.C. sent $21,000 on August 13, 2020 to Direct

Management, LLC, and $32,645 on September 1, 2020 to Florentine Investment, LLC. The

defendant was associated with both businesses.

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THE WIRE TRANSMISSIONS
(

23. On or about the dates set forth. below, in the Eastern District of Missouri and

elsewhere, the defendant,

TERRELL ALEXANDER,
I

having devised and intended to devise a scheme to obtain money by means of materially false and

fraudulent pretenses, representations and promises, as specifically described in the paragraphs

above, for the purpose of executing the scheme described above, and in attempting to do so, caused

to be transmitted by means of wire communication in interstate commerce the signals and sounds

described below for each count, each transmission constituting a separate count:

COUNT DATE LOAN APPLICANT LOAN AMOUNT ·

1 6/25/2020 Direct Management, LLC $150,000

2 7/4/2020 Ferrell Thomas $25,300

( 3 7/28/2020 Qutumn Management, LLC $150,000

4 8/7/2020 Total CPA, LLC $111,900

5 8/10/2020 Precision Safe Healthcare, LLC $115,800

6 6/25/2Q20 Florentine Investment, LLC $107,000

7 7/4/2020 s.w. $50,500

8 7/4/2020 E.M. I
$37,900

9 7/30/2020 JCC Personnel Management, LLC $121,200

10 8/7/2020 Top Knotch Marketing, LLC $110,100

All in violation of Title 18, United States Code, Section 1343.
10
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COUNTS11THROUGH15
18 U.S.C. § 1028A: Aggravated Identity Theft

24. Paragraphs 1 through 23 of this Indictment are realleged and incorporated herein.

25. On or about the dates listed below, within the Eastern District of Missouri, the

defendant,

TERRELL ALEXANDER,

'( did knowingly possess, transfer, and use, without lawful authority, the below listed means of

identification of another person, knowing that the means of identification belonged to another

actual person, during and in relation to the commission of the felony offense of wire fraud, Title

18, United States Code, Section 1343:

COUNT DATE PERSON MEANS OF USE OF
IDENTIFICATION IDENTIFICATION

11 6/25/2020 S.W. Name and SSN Florentine Investment, LLC
EIDL Lo~ Application
12 7/4/2020 s.w. Name and SSN S.W. EIDL Loan Application

13 7/4/2020 E.M. Name and date of birth
.,
E.M. EIDL Loan Application

14 7/30/2020 J.C. NameandSSN ' JCC Personnel Management,
I
LLC EIDL Loan Application
15 8/7/2020 J.C. Name and SSN Top Knotch Marketing, LLC
EIDL Loan Application

All in violation of Title 18, United States Code, Section 1028A.

(

11
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COUNTS 16 AND 17
18 U.S.C. § 1028(a)(2): Unlawful Transfer of an Identification Document

26. Paragraphs 1 through 23 of this Indictment are realleged a:nd incorporated herein.

27. On or about the dates listed below, within the Eastern District of Missouri, the

defendant,

': TERRELL ALEXANDER,

knowingly transferred identification documents, authentication features, or false identification

documents, to wit: false and fraudulent driver's licenses, knowing that such do.cument or feature

was produced without lawful authority, and the production or transfer of the identification

document, authentication feature, or false identification document was in or affected interstate or

foreign commerce, and the offense involved the production or transfer of an identification

document, authentication feature, or false identification document that is or appears to be driver's

licenses or personal identification card, to wit:

COUNT DATE NAME ON FORM OF IDENTIFICATION
FRAUDULENT ID FRAUDULENT ID TRANSFEREE
16 7/4/2020 Ferrell Thomas Driver's License SBA

17 7/28/2020 Terrell Alexander Driver's License SBA

All in violation of Title 18, United States Code, Section 1028(a)(2).

/
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COUNTS18THROUGH22
42 U.S.C. § 408(a)(7)(B): Misuse of Social Security Number

28. Paragraphs 1 through 23 of this Indictment are realleged and incorporated herein.

29. On or about the dates listed below, within the Eastern District of Missouri, the

defendant,

TERRELL ALEXANDER,

with the intent to deceive, and for the purpose of obtaining anything of value from another person

and for any other purpose, falsely and fraudulently represented their Social Security Numbers to

be one of the Social Security Numbers enumerated below, or falsely and fraudulently represented

another person's Social Security Number to be one of the Social Security Numbers enumerated

below, when in fact these Social Security Numbers were either unassigned or assigned to unrelated

individuals:

COUNT DATE APPLICANT BUSINESS SSNUSED

18 6/25/2020 Direct Management, LLC ***-**-2710

19 7/28/2020 Qutumn!Management; LLC ***-**-8320

20 8/7/2020 Total CPA, LLC ***-**-5499

21 8/10/2020 Precision Safe Healthcare, LLC ***-**-8318
/

22 7/4/2020 E.M. ***-**-3633

All in violation of Title ·42, United States Code, Section 408(a)(7)(B).

13
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COUNT23
18 U.S.C. § 641: Theft of Government Property

30. Paragraphs 1 through 23 of this Indictment are realleged and incorporated herein.

31. On or about the dates listed below, within the Eastern District of Missouri, the

defendant,

TERRELL ALEXANDER, .
I
did embezzle, steal, purloin, or knowingly convert to his or her use and the use of another, money

of the United States or of any department or agency thereof, or any property made or being made

. under contract for the United States or any department or agency thereof, to wit: EIDL loans and

advances paid by the Small Business Administration in connection with. the COVID-19 national

emergency declaration, in excess of $740,000, creating a total l9ss to the government in excess of

$1,000.00.

In violation of Title 18, United States Code, Section 641.

FORFEITURE ALLEGATION

The Grand Jury further finds by probable cause that:
I
1. Pursuant to Title 18, United States Code, Sections 981(a)(l)(C) and 982(a)(2) and

Title 28, United States Code, Section 2461 (c), upon conviction of an offense in violation of Title

18, United States Code, Section 1343 as set forth in Counts 1 through 10, the defendant shall forfeit

to .the United States of America any property, real or personal, constituting or derived from

proceeds traceable to said violation. Subject to forfeiture is a sum of money equal to the total

value of any property, real or personal, constituting or derived from any proceeds traceable to said

violation, which is at least $740,000.
14
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2. Pursuant to Title 18, United States Code, Sections 982(a)(2)(b) and 1028(b), upon

conviction of an offense in violation of Title 18, United States Code, Section 1028 as set forth in

Counts 16 and 17, the defendant shall forfeit to the United States of America any property

constituting, or derived from, proceeds the defendant obtained, directly or indirectly, as a result of

such violation and any personal property used or intended to be used to commit said offense.

Subject to forfeiture is a sum of money equal to the total value of the property constituting, or
I
derived from, proceeds the defendant obtained directly or indirectly, as a result of such:violation.

3. Pursuant to Title 18, United States Code, Sections 981(a)(l)(C) and Title 28, United

States Code, Section 2461, upon conviction of an offense in violation of Title 18, United States
'
Code, Section 641 as set forth in Count 23, the defendant shall forfeit to the United States of

America any property, real or personal, which constitutes or is derived from proceeds traceable to

said violation. Subject to forfeiture is a sum of money equal to the total value of any property, real

or personal, constituting or derived from any proceeds traceable to said violation.

4. - Specific property subject to forfeiture includes, but is not limited to, the following:

a. $22,000.00 in funds from Busey Bank Account ending in 2239 in the name of
Florentine Investments LLC

b. $3,467.18 in funds from Regions Bank Account ending in 3014 in the name of
Prime Corporate Investments

c. $25,775.33 in funds from Regions Bank Account ending in 3294 in the name
of Prime Corporate Investments

d. $131,645.95 in funds from Regions Bank Account ending in 6045 in the name
of Corporate Enterprise Investments

e. $6,585.94 in funds from Regions Bank Account ending in 6053 in the name of
Corporate Enterprise Investments
15
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f. $707 .11 in funds from Regions Bank Account ending in 3227 in the name of
Jones Corporate Manufacturing

g. $52,424.74 in funds from Regions Bank Account ending in 3359 in the name
• of Jones Corporate Manufacturing

h. $2,970.63 in funds from Regions Bank Account ending in 3243 in the name of
Black Enterprise Corporation

1. $19,533.29 in funds from Regions Bank Account ending in 3286 in the name
of Black Enterprise Corporation

J. $1,803.19 in funds from Regions Bank Account ending in 2315 in the name of
S.W.

k. $56,234.68 in funds from Regions Bank Account ending in 9855 in tl;ie name
of ICC Personnel Management Corporation

I. $34,884.22 in funds from Regions Bank Account ending in 9979 in the name
of Top Knotch Marketing LLC

m. $67,864.48 in funds from Regions Bank Account ending in 7809 in the name
of Direct Management LLC

n. $68,319.07 in funds from Regions Bank Account ending in 1334 in the name
of Direct Management LLC

o. $12,286.00 in funds from Regions Bank Account ending in 9987 in the name
of Total CPA LLC

p. $100,486.00 in funds from Regions Bank Account ending in 9995 in the name
1
of Total CPA LLC

q. $1,045.01 in funds from Regions Bank Account ending in 9539 in the name of
Florentine Investments LLC

r. $5,438.17 in funds'irom Regions Bank Account ending in 8583 in the name of
Florentine Investments LLC

16
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s. $13,072.34 in funds from Regions Bank Accobnt ending in 8621 in the name
of Florentine Investments LLC

t. $52,613.18 in funds from Bank Account #296213,183 in the name ofl.C. d/b/a
Carter Corporate Healthcare LLC at Regions Bank, O'Fallon, MO

4. If any of the property described above, as a result of any act or omission 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;
I
c. has beeµ placed beyond the jurisdiction of the court;

d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be divided

without difficulty,
I
the United States of America will be entitled to the forfeiture of substitute property pursuant to
"

Title 21, United States Code, Section 853(p).

A TRUE BILL.

FOREPERSON

SAYLER A. FLEMING,
United States Attorney

DIANE E.H. KLOCKE, #61670MO
Special Assistant United States Attorney

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