Indictment — United States v. Earl Lamont Taylor, Eastern District of North Carolina (Document 1)

Summary

A grand jury Indictment in United States v. Earl Lamont Taylor, Case 5:23-cr-00335-D-KS, in the United States District Court for the Eastern District of North Carolina, filed October 18, 2023. It alleges that from in or about August 2020 to in or about September 2021 Taylor conspired with others to defraud the PPP, including through a loan facilitator who charged borrowers a fee. It alleges that PPP applications for Changing the Game Life Coach and Get Me Recruited, LLC each falsely claimed seven employees and an average monthly payroll of $58,333, supported by backdated IRS Forms 940 and 941, and that Taylor received $145,833 and $145,832.50. It further alleges that Taylor wrote purported payroll checks to make the proceeds appear to be payroll. The forfeiture section seeks at least $307,494.07 and at least $291,665.50.

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“Indictment — United States v. Earl Lamont Taylor, Eastern District of North Carolina (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-5-23-cr-00335-dkt-1-e-d-n-c-a3bf27faad/, SHA-256 f0f502d91f677b25d7ea062cc31450d9803738ef605ba577440ece413e46aab3.

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DGB
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NORTH CAROLINA
WESTERN DIVISION

UNITED STATES OF AMERICA )
)
V. ) INDICTMENT
)
EARL LAMONT TAYLOR )

The Grand Jury charges the following:

INTRODUCTORY ALLEGATIONS

1. From in or about August 2020 to in or about September 2021,

Defendant EARL LAMONT TAYLOR (hereinafter "TAYLOR") and others, known

and unknown to the Grand Jury, conspired to defraud-and did defraud-the

United States Government. In some instances, TAYLOR committed these frauds in

his own name or in the names of companies he controlled. In other instances,

TAYLOR facilitated and attempted to facilitate frauds committed in the names of

other persons and entities. These schemes involved frauds upon institutions and

agencies engaged to provide financial assistance to the public arising from the

COVID-19 pandemic. Additionally, in furthei·ance of the foregoing schemes,

TAYLOR laundered the proceeds of the frauds and conspired with others to do so.

2. At all times relevant to this Indictment, TAYLOR was a resident of the

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 1 of 28
Eastern District of North Carolina.

I. PAYCHECK PROTECTION PROGRAM ("PPP") BACKGROUND

3. In March 2020, Congress passed the Coronavfrus Aid, Relief, and

Economic SecU1·ity (CARES) Act, which was designed to provide emergency

financial assistance to millions of Americans who were suffering from the economic

effects caused by the COVID-19 pandemic.
j
4. The United States Small Business Administi·ation (SBA) was an

executive-branch agency of the United States government that provided support to

entrepreneurs and small busin.esses. The mission of the SBA was to maintain and

strengthen the nation's economy by enabling the establishment and viability of

small business and by assisting in the economic recovery of communities after

disasters.

5. One soU1·ce of :relief provided by the CARES Act was the authorization

of up to $349 billion in forgivable loans to small businesses for job retention and

certain other expenses, thmugh a program referred to as the Paycheck Protection

Pmgram (PPP). In or around April 2020, Congress authorized over $300 billion in

additional PPP funding.

6. To obtain a PPP loan, businesses were required to s11bmit a PPP loan

application, signed by an authorized i'epresentative of the business, acknowledging

the program rules. The business was requfred to state (a) its average monthly

payroll expenses and (b) the number of employees. These figures were used to

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 2 of 28
calculate the amount of money the small business was eligible to receive under the

PPP. In addition, businesses applying for a PPP loan were required to provide

documentation showing their payroll expenses.

7. A PPP loan application was requii·ed to be processed by a pa1·ticipating

financial institution ("Lender").· Many Lenders constituted financial institutions, as

that term is defined in Title 18, United States Code, Section 20. If a PPP loan

application was approved, the Lender funded the PPP loan using its own moneys,

which were 100% guaranteed by the SBA. Data from the application, including

information about the borrower, the total amount of the loan, and the listed number

of employees, were transmitted by the Lender to the SBA in the course of processing

the loan.

8. PPP loan proceeds were requii·ed to be used by businesses on certain

permissible expenses: payroll costs, interest on mortgages, rent, and utilities.

Loans provided through the PPP had government-backed guarantees and were

100% forgivable if the borrower submitted documentation to the PPP Lender and

SBA demonstrating that at least sixty percent (60%) of the PPP loan proceeds were

utilized to meet existing payroll obligations and to retain employees.

II. · THE PPP LOAN SCHEME AND ARTIFICE TO DEFRAUD

9. Beginning at least as early as August 2020, through in or about

September 2021, the Defendant, TAYLOR, conspired with E.W, S.C., Q.J., and

others to engage in fraud upon the PPP program. TAYLOR engaged in fraud and

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 3 of 28
attempted to engage in fraud upon the PPP program in the names of Get Me

Recruited, LLC and Changing the Game Life Coach, businesses owned and

controlled by TAYLOR. TAYLOR also engaged in, and attempted to engage in,

fraud upon the PPP program in the name of iConnect2Colleges, LLC. At all

relevant times, TAYLOR was domiciled in Raleigh, North Carolina. Q.J. was

domiciled in Cary, North Carolina within the Eastern District of N01·th Carolina.

E.W. resided in Texas.

10. E.W. and S.C. assisted numerous other companies and individuals

(collectively "Borrowers") located around the country to fraudulently obtain PPP

loans and other COVID-19 loans. In exchange for their assistance in obtaining

COVID-19 loans, the Borrowers, such as TAYLOR, paid E.W. a fee rnpresenting a

percentage of the fraudulent loan pl'Oceeds. In total, E.W. and their spouse, S.C,,

collectively facilitated the fraudulent disbursement of more than $15 Million in

COVID-19 loans.

11. To p1·omote the operation of the scheme, E.W. and S.C. utilized

middlemen to recruit Borrowers. E.W. and S.C caused others to pay these

middlemen a "cut" of the fee charged for secm·ing the fraudulent loans for the

Borrowers.

12. Q.J. was one such Borrower who operated various companies in the

Eastern District of North Carolina. Q.J. utilized E.W. and S.C. to fraudulently

obtain COVID loans in the names of several companies. In addition to being a

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 4 of 28
i

Borrower, Q.J. also served as a middleman, and, directly or indirectly, recruited

additional Borrowers-including Defendant TAYLOR-.fm an agreed-upon fee.

A. PPP Fraud: Changing the Game Life Coach & Get Me
Recruited, LLC

13. Changing the Game Life Coach was a company owned and controlled

by the Defendant, TAYLOR, purportedly engaged in providing life coaching and

counseling services to young athletes. Changing the Game Life Coach had minimal

revenue and operating expenses prior to the COVID-19 pandemic. Changing the

Game Life Coach had no regulru· salaried employees prior to the COVID-19

pandemic.

14. Get Me Recruited, LLC was a company owned and controlled by the

Defendant, TAYLOR, puTportedly engaged in staging basketball toU1·naments and

assisting young athletes to be recruited by professional or collegiate athletic

programs. Get Me Recruited, LLC had meaningful revenue and operating expenses

prior to the COVID-19 pandemic. HowevEir, Get Me Recruited, LLC had no regular

payl'Oll obligations and never paid any of its pill-ported employees more than a few

thousand dollars per year.

15. Q.J., who had already fraudulently received COVID loans with E.W.'s

assistance, connected TAYLOR to E.W. for the same purpose. TAYLOR and E.W.

communicated through interstate text messages, phone calls, and emails. Dming

these contacts, E.W. and TAYLOE discussed the process by which E.W. would assist

TAYLOR to fraudulently secure J;>PP loans. TAYLOR used his email address,

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 5 of 28
coacheltaylor@aol.com, to communicate with E.W., who used the email address

loanstarters@gmail.com. The internet service providers Google, LLC and AOL

house servers outside of North Carolina.

16. TAYLOR supplied E.W. with various information concerning TAYLOR

and his companies to obtain the PPP loans. In furtherance of the PPP applications,

E.W. created documents that falsely reflected such information as the annual

payroll, gross receipts, expenses, number of employees, and/or employee names for

Changing the Game Life Coach and Get Me Recruited, LLC.

17. E.W. then supplied fraudulent documents to TAYLOR via interstate

email transmission for review and signature, such as the Paycheck Protection

Program Borrower Application Form. These documents were fraudulent because,

among oth_er reasons, they grossly and intentionally misrepresented the true

avera_ge monthly and annual payrolls for Changing the Game Life Coach and Get

Me Recruit_ed, LLC. Despite these falsehoods, TAYLOR signed and returned the

fraudulent documents to E.VV.

18. E.W. also supplied to TAYLOR via interstate email certain fraudulent

IRS forms; specifically Form 940 (pertaining to annual payroll for TAYLOR's

business entities) and Form 941 (pertaining to quarterly payroll for TAYLOR's

business entities). The forms were fraudulent because they falsely inflated the

actual annual and quarterly wages for Changing the Game Life Coach and Get Me

Recruited, LLC.

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 6 of 28
19. With respect to Changing the Game Life Coach, TAYLOR 1·eceived,

signed, and returned the fraudulent and backdated Form 940 and Form 941s.

TAYLOR signed four IRS Form 941s (one fo1· each quarter in 2020), each falsely

claiming seven employees and quarterly payroll obligations over $195,000.

TAYLOR had signed each one, which had backdated signature lines, respectively, of

April 27, 2020; July 29', 2020; Octobe1· 27, 2020; and January 28, 2021. TAYLOR

had also signed the IRS Form 940 for 2020 which falsely claimed annual payroll

obligations of $784,29.33. TAYLOR signed the document even though the section

containing the signature block includes the following attestation: "Under penalties

of perjury, I declare that I have examined this return, including accompanying

schedules and statements, and to the best of my knowledge and belief, it is true,

correct, and complete ...."

20. With respect to Get Me Recruited, LLC, TAYLOR received, signed, and

returned the fraudulent and backdated Form 940 and Form 941s. TAYLOR signed

four IRS Forms 941 (one for each quarter in 2019), each falsely claiming seven

employees and quarterly payroll obligations over $200,000. Specifically, TAYLOR

signed the backdatecl Form 941s bearing, respectively, dates of April 30, 2019; July

25, 2019; October 30, 2019; and January 27, 2020. TAYLOR also signed an IRS

Form 940 for 2019 which falsely claimed annual payi·oll obligations of $833,421.88.

TAYLOR signed the document even though the section containing the signature

block included the following attestation: "Under penalties of perjury, I declare that I

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 7 of 28
have examined this return, including accompanying schedules and statements, and

to the best of my knowledge and belief, it is ti·ue, couect, and comI?lete ...."

21. As submitted, the Paycheck P1·otection Program Borrower Application

Form submitted on behalf of Changing the Game Life Coach falsely claimed seven

employees and an average monthly payroll of $58,333 (an approximate. annual

payroll of $700,000) which would yield a PPP loan in an amount of just under

$150,000. TAYLOR signed the application and initialed next to the following

attestation: "I further certify that the information provided in this application and

the information provided in all supporting documents and forms is true and

accurate in all material respects. I understand that knowingly making a false

statement to obtain a guaranteed loan from SBA is punishable under the law .... "

TAYLOR signed the form and sent it to E.W. even though he knew that the loan

application grossly overstated Changing the Game Life Coach's actual employees

and payroll, and even though such representations regarding employees and payroll

were supported by fraudulent and backdated IRS Forms 940 and 941.

22. The Paycheck Protection Program Borrower Application Form

submitted on behalf of Get Me Recruited, LLC also falsely claimed seven employees

and an average monthly payroll of $58;333 (an approximate annual payroll of

$700,000), which would yield a PPP loan just under $150,000. TAYLOR E?igned the

application and initialed next to the following attestation: "I further certify that the

information provided in this application and the information provided in all

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 8 of 28
supporting documents and forms is true and accurate in all material respects. I

understand that knowingly making a false statement to obtain a guaranteed loan

from SBA is punishable under the law ...." TAYLOR signed the form and sent it to

E.W. even though he knew that the loan application grossly overstated Get Me

Recruited, LLC's actual employees and payroll, and even though such

representations regarding employees and payi-oll were supported by fraudulent and

backdated IRS Forms 940 and 941.

23. The PPP loan applications were electronically submitted by E.W. or

S.C. on behalf of TAYLOR, and received through SBA servers located in Virginia or

Oregon, using the fraudulent information described above, by electronically

transmitting the information to the lending institutions via interstate wire

transmission. Harvest Small Business Finance, LLC, which was based in

California, originated the PPP loan for Changing the Ga:m.e Life Coach; and

LendingClub Bank, N.A., which was based in Utah, originated the PPP loan for Get

Me Recruited, LLC. LendingClub Bank, N.A. was an institution whose deposits

were insured by the Federal Deposit Insurance Corporation, and was thus a

financial institution within the meaning of Title 18, United States Code, Section 20.

24. On or about March 2, 2021, TAYLOR received $145,833 in fraudulent

PPP proceeds, which were deposited via interstate wii·e transfer into TAYLOR's

Wells Fargo Bank, N.A. account ending in -7861, associated with Get Me Recruited,

LLC, over which TAYLOR had custody and control.

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 9 of 28
25. On or about April 22, 2021, TAYLOR received another $145,832.50 in

fraudulent PPP proceeds, which were deposited via interstate wire transfer into

TAYLOR's Wells Fargo Bank, N.A. account ending in -7412, associated with

Changing The Game Life Coach, over which TAYLOR had custody and control.

26. After receiving proceeds from the PPP fraud described above, TAYLOR

carried out a series of steps, under the guidance of E.W., to make it appear as

though Changing The Game Life Coach and Get Me Recruited, LLC were paying

biweekly payroll to the "employees."

II. THE MONEY LAUNDERING SCHEMES

A. Money Laundering: Changing the Game Life Coach & Get Me
Recruited, LLC
27. Over an approximately four-to-six-week period following the

disbursement of the fraudulent PPP proceeds into TAYLOR's respective bank

accounts, TAYLOR then wrote purported "payroll" checks to each of the individuals

previously named as purported employees of Changing The Game Life Coach and

Get Me Recruited, LLC when, in fact, such funds did not constitute genuine payroll

payments. Each of the checks contained a memo notation stating a "pay period"

and a two-week interval.

28. The disbursement of these. checks involved the proceeds of fraud upon

the SBA, Harvest Small Business Financ;e, LLC, and LendingClub Bank, N.A

described above. TAYLOR wrote these checks both to conceal and disguise the PPP

proceeds, and to piomote additional fraud upon the SBA, specifically to obtain PPP

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 10 of 28
loan forgiveness under the false pretense that the loan p1·oceeds had been spent to

meet legitimate, preexisting payroll obligations that preceded COVID-19.

29. In total, from on or about April 22, 2021 to on or about May 24, 2021,

TAYLOR wrote at least twenty-one such checks from his Wells Fargo Bank, N.A.

account ending in -7412 associated with Changing the Game Life Coach. TAYLOR
. j
i
wrote the checks to all seven "employees," including himself, in amounts ranging i

from approximately $6,000 to approximately $7,000 each.

30. In total, from on or about March 2, 2021 to on or about Mai·ch 24, 2021,

2021, TAYLOR wrote at least twenty-thi'ee such checks from his ·wells Fargo Bank,

N.A. account ending in -7861 associated with Get Me Recruited, LLC. TAYLOR

wrote the checks to all seven "employees," including himself, in amounts ranging

from approximately $6,000 to approximately $7,000 each.

31. · Collectively, these checks made it falsely appear that each of the check

recipients was engaged in full time work on behalf of Changing the Game Life

Coach and Get Me Recruited, LLC, and receiving regular wages during each of the

stated periods based on annual salaries of over $100,000 each. In reality, none of

the. "employees" who received the checks had previously received wages comparable

to those paid from the PPP proceeds.

32. After TAYLOR had disbm·sed all of the PPP loan proceeds under the

guise of payroll checks, E.W. and S.C., acting on TAYLOR's behalf, successfully

applied for loan forgiveness from the SBA by falsely attesting that the PPP proceeds

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 11 of 28
disbursed to Get Me Recruited, LLC and Changing the Game Life Coach had been

used to pay employee wages.

33. The forgiveness application associated with Changing the •Game Life

Coach was submitted by E.W. and S.C. on TAYLOR's behalf, and transmitted to the

SBA via its .servers in Oregon or .Virginia.

34. The forgiveness Application associated with Get Me Recruited, LLC

was submitted by E.W. and S.C. on TAYLOR's behalf, and transmitted to the SBA

via its servers in Oregon or Virginia.

35. TAYLOR disbursed the checks described above to falsely represent

that he had paid biweekly payroll to employees of his business entities, but, in

reality, the check recipients had previously agreed to return most of the money to

TAYLOR, and in fact, did so. TAYLOR then deposited most of the illicit funds into

his personal Wells Fargo Bank, N.A. account ending in -1091, rather than back into

the accounts associated with the businesses into which the loan proceeds were

deposited.

36. TAYLOR then wrote checks to E.W. for approximately 25% of th~ loan

proceeds-approximately $36,450 per loan-to compensate E.W. for his assistance

in helping TAYLOR to fraudulently obtain the PPP loans.

37. Specifically, between approximately March 2021 and May 2021,

TAYLOR withdrew cashier's checks from his Wells Fargo Bank, N.A. accounts

associated with Get Me Recruited, LLC and Changing the Game Life Coach in

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 12 of 28
amounts under $10,000. Financial transactions of under $10,000 each do not

trigger certain financial institution reporting requirements. 'TAYLOR then

deposited those checks into E.W.'s J.P. Morgan Chase Bank, N.A. account ending in

-7287, associated with ''Vork, LLC," an entity E.W. used for the purpose of receiving

kickbacks in furtherance of the scheme. In total, TAYLOR paid E.W. approximately

$72,917.24, spread oµt over eight tra.nsactions.

B. Money Laundering: iConnect2Colleges, LLC

38. In addition to committing fraud on behalf of his own comparnes,

TAYLOR also facilitated -Q.J. to launder the proceeds of fraudulent PPP loans

obtained on behalf of Q.J.'s company, iConnect2Colleges; LLC.

39. iConnect2Colleges, LLC, was a company owned and controlled by Q.J.,

purportedly engaged in collegiate athletic recruitment .. With E.W.'s assistance, Q.J.

successfully obtained two fraudulent PPP loans on behalf of iConnect2Colleges, LLC

worth $145,800 each, respectively, on or about August 25, 2020 and on or about

February 20, 2021.

40. Much like the fraudulent applications that TAYLOR and E.W.

submitted on behalf of TAYLOR's companies, the applications for these loans

contained false and fraudulent information as to Q.J.'s companies' payroll

obligations prior to the COVID-19 Pandemic. Specifically, the Paycheck Protection

Program Borrower Application Forms submitted with iConnect2Colleges, LLC

falsely claimed seven employees and an annual payroll of approximately $700,000,

figures designed to yield PPP loans in an amount of just under $150,000. E.W.

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 13 of 28
engineered this result because it would enable Q.J. to apply for loan forgiveness

from the SBA more easily than if the loans were over $150,000 ~ach.

41. The PPP loan applications were electronically submitted with E.W.'s

assistance, by, or on behalf of, Q.J, and received through SBA servers located in

Virginia or Oregon, using fraudulent payroll information, by electl'Onically

transmitting the information to the lending institution, LendingClub Bank, N.A., a

financial institution as that term is defined in Title 18, United States Code, Section

20. Those PPP funds were deposited by interstate wfre into Q.J.'s Morgan Stanley

bank account, ending in -8040.

42. In the supporting paperwork accompanying the loan applications, Q.J.

falsely claimed that the Defendant, TAYLOR, was an employee of

iConnect2Colleges, LLC, earning a regular annual salary of over $100,000.

TAYLOR and Q.J. conspired to falsely claim that TAYLOR was an employee of

iConnect2Colleges, LLC, so that TAYLOR could assist Q.J. in laundering the funds

and obtaining loan forgiveness. This money laundering scheme resembled the same

scheme described above in which TAYLOR engaged with respect to Get Me

Recruited, LLC and Changing the Game Life Coach.

43. Specifically, in the period following the disbursement of the fraudulent

PPP proceeds into Q.J.'s Morgan Stanley bank account, Q.J. then wrote "payroll"

checks to each of the individuals previously named - as purported employees of

iConnect2Colleges, LLC. Each of the checks contained a memo notation stating a

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 14 of 28
"pay period" and a two-week interval.

44. Collectively, these checks made it falsely appear that each of the check

recipients was engaged in fulltime work on behalf of iConnect2College, LLC, and

receiving regular wages during each of the stated periods based on annual salaries

of over $100,000 each. In reality, none of the check recipients previously received

wages comparable to those paid from the PPP proceeds.

45. Specifically, ·Q.J. wrote at least two "payroll" checks to TAYLOR from

Q.J.'s Morgan Stanley bank account ending in -8040 for over $7,000 each. TAYLOR

deposited those checks, and then shortly thereafter made cash withdrawals for most

of the funds so that he could retU1·n those funds back to Q.J. TAYLOR retained

small kickback for himself for assisting Q.J. to launder the funds.

46. The disbursement of these checks involved the proceeds of fraud upon

the SBA and LendingClub Bank, N.A described above. Q.J. wrote these checks-

and TAYLOR deposited them-both to conceal and disguise the PPP proceeds, and

to promote additional fraud upon the SBA, specifically to obtain PPP loan

forgiveness under the false pretense that the loan proceeds had been spent to meet

legitimate, preexisting payroll obligat~ons that preceded the COVID-19 pandemic.

47. E.W. and S.C., acting on Q.J.'s behalf, successfully transmitted the

forgiveness applications on Q.J.'s behalf, through SBA servers in Oregon or

Virginia, by falsely attesting that the PPP proceeds disblll·sed to iConnect2Colleges,

LLC were used to pay employee wages.

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 15 of 28
48. The banks utilized by TAYLOR, E.W., and Q.J. to launder fraudulent

PPP proceeds-Wells Fargo Bank, N.A.; J.P. Morgan Chase Bank, N.A.; and

Morgan Stanley Bank, N.A.-were all financial institutions within the meaning of

Title 18, United States Code, Section 20.

COUNT ONE
Conspiracy to Commit Wire Fraltd and Banh Fraltd
18 U.S.C. §§ 1343, 1344, and 1349

49. Introductory paragraphs 1 through 26 are realleged and incorporated

into this Count as factual allegations by reference as if fully set forth herein.

50. From in or about August 2020 through in or about September 2021, in

the Eastern District of North Carolina and elsewhere, Defendant EARL LAMONT

TAYLOR did knowingly combine, conspil.-e, confederate, agree, and have a tacit

understanding with E.W., Q.J., and others known and unknown to the Grand Jury,

to commit offenses against the United States, specifically:

a. Wire Fraud, that is, to knowingly devise and intend to devise a

scheme and a1-tifice to defraud the SBA, Harvest Small Business

Finance, LLC, and LendingClub Bank, N.A., and to obtain money

and property by means of materially false and fraudulent

pretenses, representations, and promises; and for the purpose of

executing the scheme, caused to be transmitted by means of wire

communication in interstate commerce any writings, signals, signs

pictures, and sounds, in violation of Title 18, United States Code,

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 16 of 28
Section 1343; and

b. Bank Fraud, that is to execute and attempt to execute a scheme or

artifice to defraud a financial institution within the meaning of

Title 18, United States Code, Section 20-LendingClub Bank,

N.A.- by obtaining any of the moneys, funds, credits, assets, or

securities owned by, or under the custody or control of,

LendingClub Bank, N.A., by means of false and fraudulent

pretenses, representations, and promises, in violation of Title 18,

United States Code, Section 1344.

Purpose of the Conspiracy

51. The purpose of the conspiracy was for TAYLOR, E.W., Q.J., and others,

known and unknown to the Grand Jm·y, to fraudulently obtain PPP loans, to which

they and their businesses were not entitled, through false and fraudulent

statements, representations, and supporting documents.

Manner and Means of the Conspiracy

52. TAYLOR, E.W., Q.J., and others, known and unknown to the Grand

Jury, carried out the objectives of the conspiracy in the manner and means as set

forth in paragraphs 9 through 26 of this Indictment.

All in violation of Title 18, United States Code, Section 1349.

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 17 of 28
COUNTS TWO THROUGH THREE
Wire Fraud and Aiding & Abetting
18 U.S.C. §§ 1343 and 2

53. Introductory paragraphs 1 through 26 are realleged and incorporated

into these Counts as factual allegations by reference as if fully set forth herein.

The Scheme to Defraud

54. From in or about January 2021 through in or about September 2021,

within the Eastern District of North Carolina and elsewhere, the Defendant, EARL

LAMONT TAYLOR, aiding and abetting others, knowingly devised and intended to

device a scheme and artifice to defraud the Small Business Administration's

Paycheck Protection Program during the COVID-19 pandemic, LendingClub Bank,

N.A., and Harvest Small Business Finance, LLC; and to obtain money and property

by means of materially false and fraudulent representations and promises.

Manner and Means

55. The Defendant, EARL LAMONT TAYLOR, carried out the scheme and

a1'tifice to defraud in the manner and means set forth in paragi·aphs 9 through 26.

Use of The Wires

56. On or about each of the dates set forth below in the Eastern District of

North Carolina and elsewhere, ·the Defendant, EARL LAMONT TAYLOR, for the

pm·pose of executing and attempting to execute the scheme and artifice to defraud

described above, caused to be transmitted by means of wfre communication in

interstate commerce the signals, writings, signs, pictm·es, and sounds described

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 18 of 28
below for each count, each transmission constituting a separate count:
.. ,·· - . . ,. .-
Count Approximate :Pescription ,.
·oate ..
·• ... ~'.

2 3/02/2021 Deposit of $145,833 in PPP funds into TAYLOR'S Well Fargo
Bank, N.A. account ending in -7861 associated with Get Me
Recruited, LLC

3 4/22/2021 Deposit of $145,832.50 in PPP funds into TAYLOR'S Well
Fargo Bank, N.A. account ending in -7412 associated with
Changing the Game Life Coach

Each row of the foregoing table representing a separate violation of Title 18,

United States Code, Sections 1343 and 2.

COUNT FOUR
False Statement to Influence a Banh on a Loan and Aiding & Abetting
18 U.S.C. §§ 1014 and 2

57. Introductmy paragraphs 1 through 26 are realleged and incorporated

into this Count as factual allegations by reference as if fully set forth herein.

58. From in or about Januru.-y 2021 through in or about September 2021,

within the Eastern District of North Carolina and elsewhere, the Defendant, EARL

LAMONT TAYLOR, aiding and abetting others, did knowingly make and cause to

be made false statements and reports, for the purpose of influencing in any way

LendingClub Bank, N.A., whose accounts are insured by the Federal Deposit

Insurance Corporation, upon an application, advance, commitment, and loan for his -

company, Get Me Recruited, LLC, in that the Defendant falsely claimed seven

regularly salru.·ied employees with an average monthly payroll of $58,333, when in

truth and in fact, as the Defendant well knew, Get Me Recruited, LLC did not have

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 19 of 28
any such regular monthly payroll.

All in violation of Title 18, United States Code, Sections 1014 and 2.

COUNT FIVE
Bank Fraud and Aiding & Abetting
18 U.S.C. §§ 1344 and 2

59. Introductory paragraphs 1 through 26 are realleged and inc01·porated

into this Count as factual allegations by reference as if fully set forth herein.

60. LendingClub Bank, N.A. is a "financial institution," as that term is

defined in Title 18, United States Code, Section 20.

61. From in or about January 2021 through in or about September 2021,

within the Eastern District of North Carolina and elsewhere, the Defendant, EARL

LAMONT TAYLOR, aiding and abetting others, executed and attempted to execute

a scheme and artifice to defraud LendingClub Bank, N.A., by causing a loan

application to be submitted to LendingClub Bank, N.A. on behalf of his company,

Get Me Recruited, LLC, which contained false and fraudulent representations as to

that company's payroll, resulting in the disbursement of loan proceeds owned by,

and under the custody and control of, LendingClub Bank, N.A.

All in violation of Title 18, United States Code, Sections 1344 and 2.

COUNTS SIX AND SEVEN
False Statements and Aiding & Abetting
18 U.S.C. §§ 1001(a)(2) and 2

62. Introductory paragraphs 1 through 26 are realleged and incorporated

into these Counts as factual allegations by reference as if fully set forth herein.

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 20 of 28
63. On or about the dates listed in the table below, each entry constituting

a separate count of this Indictment, in the Eastern District of North Carolina, and

elsewhere, the Defendant, EARL LAMONT TAYLOR, aiding and abetting others

known and unknown to the Grand Jm·y, in a matter within the jm·isdiction of the

Small Business Administration, an agency within the Executive Branch of the

Government of the United States, did willfully and knowingly make materially

false, fictitious, and fraudulent statements andrepi-esentations as described in each

row of the table below:
..
,'

Count
.. i\.pproxi)n1:1.t~ •. Description • . '
,.
·nate

6 1/25/2021 IRS Form 940 for 2019 backdated to January 27, 2020, falsely
claiming $784,298.33 in total payments to employees of Get
Me Recruited, LLC submitted with PPP application

7 3/15/2021 IRS Form 940 for 2020 backdated to January 28, 2021, falsely
claiming $833,421.88 ln total payments to employees of
Changing the Game Life Coach submitted with PPP
application

Each row of the foregoing table constituting a separate count, in violation of Title

18, United States Code, Sections 1001(a)(2) and 2.

COUNT EIGHT
Money Laundering and Aiding & Abetting
18 U.S.C. §§ 1956(a)(l)(A)(i) and 2

64. Introductory paragraphs 1 through 48 are re-alleged as factual

allegations and incorporated by refe1·ence as if fully set forth herein.

65. From in or about August 2020 through in or about June 2021, both

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 21 of 28
dates being approximate and inclusiv~, within the Eastern District of North

Carolina and elsewhere, the Defendant, EARL LAMONT TAYLOR, aiding and

abetting others known and unknown to the Grand Jury, did knowingly conduct and

attempt to conduct financial transactions affecting interstate commerce, that is, the

depositing and cashing of purported payroll checks, through a financial institution;

which involved the proceeds of specified unlawful activities, that is:

a. knowingly executing a scheme and artifice to defraud, and to obtain

money and property by means of materially false and fraudulent

pretenses, representations, and promises, and for the purpose of

executing said scheme and artifice, transmitting and causing to be

transmitted by means of wire communication in interstate

commerce, any writing, sign, signal, picture, and sound, in violation

of Title 18, United States Code, Section 1343 ("Wfre.Fraud"); and

b. knowingly executing a scheme or artifice to defraud a financial

institution, and to obtain the money, funds, or other property

owned by or under the control of a financial institution by means of

materially false and fraudulent pretenses, representations 01·

promises, in violation of Title 18, United States Code, Section 1344

("Bank Fraud")

with the intent to promote the carrying on of additional specified unlawful activity

as alleged in the Indictment-that is, Wire Fraud-and that while conducting and

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 22 of 28
attempting to conduct such financial transactions knew that the property involved

in the financial transactions represented the proceeds of some form of unlawful

activity.

All in violation of Title 18, United States Code, Sections 1956(a)(l)(A)(i) and

COUNT NINE
Money Laundering
18 U.S.C. § 1956(a)(l)(B)(i) and 2

66. Introductory paragraphs 1 through 48 are realleged and incorporated

into this Count as factual allegations by reference as if fully set forth herein.

67. From in or about August 2020 thmugh in or about June 2021, both

dates being approximate and inclusive, in the Eastern District of North Carolina

and elsewhere, the Defendant, EARL LAMONT TAYLOR, aiding and abetting

others known and unknown to the Grand Jury, did knowingly conduct and attempt

to conduct financial transactions, that is, the depositing and cashing of purported

payroll checks, affecting interstate commerce, through a financial institution; which

involved the proceeds of specified unlawful activities, that is:

a. knowingly executing and attempting to execute a scheme and

artifice to defraud, and to obtain money and property by means of

mate1·ially false and fraudulent pretenses, representations, and

promises, and for the purpose of executing said scheme and artifice,

transmitting and causing to be transmitted by means of wire

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 23 of 28
communication in interstate commerce, any writing, sign, signal,

picture, and sound, in violation of Title 18, United States Code,

Section 1343 ("Wire Fraud");

b. to knowingly execute a scheme or artifice to defraud a financial

institution, and to obtain the money, funds, or other property

owned by or under the control of a financial institution by means of

materially false and fraudulent pretenses, representations or

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

("Bank F1·a ud")

knowing that the transactions were designed in whole or in part to conceal and

disguise the natui·e, the location, the source, the ownership, and the control of the

PPP proceeds fraudulently obtained by Wire Fraud and Bank Fraud, and that while

conducting and attempting to conduct such financial transactions knew that the

property involved in the financial transaction represented the proceeds of some

form of unlawful activity.

All in violation of Title 18, United State Code, Section 1956(a)(l)(B)(i) and 2.

COUNT TEN
Conspiracy to Commit Money Laundering
18 U.S.C. § 1956(h)

68. Introductory paragraphs 1 through 48 are realleged and incorporated

into this Count as factual allegations by reference as if fully set forth herein.

69, From in or about August 2020 through in or about June 2021, both

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 24 of 28
dates being approximate and inclusive, in the Eastern District of North Carolina

and elsewhere, the Defendant, EARL LAMONT TAYLOR, E.W., Q.J., did knowingly

combine, conspire, confederate, and agree with each other and with other persons

known and unknown to the Grand Jury, to commit offenses against the United

States, in violation of Title 18, United States Code, Section 1956, specifically, to

a. knowingly conduct and attempt to conduct financial transactions

affecting interstate commerce; thmugh a financial institution; such

proceeds having been derived from specified unlawful activities,

that is Wire Fraud, in violation of Title 18, United States Code,

Section 1343 and Bank Fraud in violation of Title 18, United States

Code, Section 1344; with the intent to promote the carrying on of

such specified unlawful activities, and that while conducting and

attempting to conduct stich financial transactions knew that the

property involved in the financial ti'ansactions reptesented the

proceeds of some form of unlaw:ful activity in violation of Title 18,

United States Code, Section 1956(a)(l)(A)(i); and

b. knowingly conduct and attempt to conduct, financial transactions

affecting interstate commerce; through a financial institution; such

proceeds having been derived from specified unlawful activities,

that is Wire Fraud, in violation of Title 18, United States Code,

Section 1343 and Bank Fraud in violation of Title 18, United States

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 25 of 28
Code, Section 1344; and knowing that the transactions were

designed in whole or in part to conceal and disguise the nature, the

location, the source, the ownership, and the control of the proceeds

of specified unlawful activities; and that while conducting and

attempting to conduct such financial transactions, knew that the

property involved in the financial transactions represented some

form of unlawful activity in violation of Title 18, United States

Code, Section 1956(a)(l)(B(i).

Manner and Means

70. TAYLOR, E.W., Q.J., and others, known and unknown to the Grand

Jm-y, carried out the objectives of the conspi.i-acy in the manner and means as set

forth in paragraphs 1 through 48 of this Indictment.

All in violation of Title 18, United States Code, Section 1956(h).

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 26 of 28
FORFEITURE NOTICE

Notice is hereby given that all right, title and interest m the property

described herein is subject to forfeiture.

Upon conviction of any offense chai·ged · herein constituting "specified

unlawful activity" (as defined in 18 U.S.C. §§ 1956(c)(7) and 1961(1)), or a

conspiracy to commit such offense, the defendant shall forfeit to the United States,

pursuant to 18 U.S.C. § 981(a)(l)(C), as made applicable by 28 U.S.C. § 2461(c), any

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

the said offense.

Upon conviction of any violation of 18 U.S.C. §§ 1956, 1957 or 1960 charged

herein, the defendant shall forfeit to the United States, pursuant to 18 U.S.C.

§ 982(a)(l), any prope1·ty, real or personal, involved in such offense, or any property

traceable to such property.

The forfeitable property includes, but is not limited to, the following:

Forfeiture Money Judgment:

a) A sum of money representing the value of the property involved in the

money laundering offense(s) charged herein against EARL LAMONT

TAYLOR, in the amount of at least $307,494.07.

b) A sum of money representing the gmss proceeds of the offense(s) charged

herein against EARL LAl\tIONT TAYLOR in the amount of at least

$291,665.50.

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 27 of 28
If any of the above-described forfeitable property, as a result of any act or

omission of a defendant: cannot be located upon the exercise of due diligence; has

been transferred or sold to, or deposited with, a third party; has been placed beyond

the jU1·isdiction of the coU1·t; has been substantially diminished in value; or has been

commingled with other property which cannot be divided without difficulty; it is the

intent of the United States, plll·suant to Title 21, United States Code, Section

853(p), to seek forfeiture of any other property of said defendant up to the value of

the forfeitable property described above.

MICHAEL F. EASLEY, JR
United States Attorney

BY: ~~
DAVID G. BERAKA
Assistant United States Attorney

Case 5:23-cr-00335-D-KS Document 1 Filed 10/18/23 Page 28 of 28

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