Indictment — No. 7:22-cr-00131 (Dkt. 1, N.D. Ala.)

Summary

An indictment filed April 27, 2022 as Document 1 in United States v. Quincy Terrell Doss, Case 7:22-cr-00131-LSC-GMB, in the U.S. District Court for the Northern District of Alabama, Western Division. Counts One and Two cite 18 U.S.C. §§ 1343 and 2. The indictment alleges that from no later than in or around April 2021 through at least in or around November 2021 the defendant purported to own and operate a small business that was nonoperational and submitted false applications for Paycheck Protection Program loans. The notice of forfeiture states a money judgment of at least $220,833.

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

Cite this document

“Indictment — No. 7:22-cr-00131 (Dkt. 1, N.D. Ala.).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-7-22-cr-00131-dkt-1-n-d-ala-9bd6826411/, SHA-256 b148d189f2a708842465f785b6736a5ecbefcaaf61a97a68a48b6b4788148e09.

Full text

Case 7:22-cr-00131-LSC-GMB Document 1 Filed 04/27/22 Page 1 of 6 FILED
2022 Apr-28 PM 02:51
U.S. DISTRICT COURT
N.D. OF ALABAMA

PFE/JRH: May 2022
GJ # 18

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ALABAMA
WESTERN DIVISION

UNITED STATES OF AMERICA )
) Case No.:
v. )
)
QUINCY TERRELL DOSS )

INDICTMENT

The Grand Jury charges that:

COUNTs ONE and TWO
18 U.S.C. §§ 1343 and 2

Introduction

At all times relevant to this Indictment:

1. The defendant resided in Tuscaloosa County within the Northern

District of Alabama.

2. The United States Small Business Administration (“SBA”) was an

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

entrepreneurs and small businesses.

3. The SBA enabled and provided for loans through banks, credit unions,

and other lenders. These loans had government-backed guarantees. In addition to

traditional SBA funding programs, The Coronavirus Aid, Relief, and Economic

1
Case 7:22-cr-00131-LSC-GMB Document 1 Filed 04/27/22 Page 2 of 6

Security (“CARES”) Act, established several new temporary programs and provided

for the expansion of others to address the COVID-19 pandemic, which was declared

a nationwide disaster by the President on March 13, 2020.

4. One of the new programs was the SBA Paycheck Protection Program

(“PPP”), which was a loan designed to provide a direct incentive for small businesses

to keep their workers on the payroll. Under this program, the SBA could forgive all

or part of loans if employees were kept on the payroll for eight weeks and borrowers

submitted documentation confirming the loan proceeds were used for certain

qualifying business expenses, such as payroll.

5. Interested applicants applied through an existing SBA lender or any

other participating federally insured financial institution. The PPP application

process required applicants to submit a Borrower Application Form through an

SBA-approved financial entity. The application contained information as to the

purpose of the loan, average monthly payroll, number of employees, and background

of the business and its owner. Applicants were also required to make certain good

faith certifications, including that economic uncertainty had necessitated their loan

requests for continued business operations, and that they intended to use the loan

proceeds only for the authorized purposes.

2
Case 7:22-cr-00131-LSC-GMB Document 1 Filed 04/27/22 Page 3 of 6

The Scheme and Artifice

6. Beginning on an unknown date, but no later than in or around April

2021, and continuing through at least in or around November 2021, in the Northern

District of Alabama and elsewhere, the defendant,

QUINCY TERRELL DOSS,

knowingly devised and intended to devise a scheme and artifice to defraud, and to

obtain money and property by means of materially false and fraudulent pretenses,

representations, and promises.

Manner and means of the Scheme and Artifice

7. The manner and means by which the defendant sought to accomplish

the scheme to defraud included, among others, the following:

a. It was a part of the scheme and artifice that the defendant would

and did purport to own and operate a small business when in fact the business was

nonoperational.

b. It was further a part of the scheme and artifice that, to induce the

SBA and financial institutions to fund PPP loans for the nonoperational business,

the defendant would and did prepare and submit, and cause to be prepared and

submitted, false and fraudulent applications to financial institutions and the SBA that

included several materially false and fraudulent representations and pretenses, such

as:

3
Case 7:22-cr-00131-LSC-GMB Document 1 Filed 04/27/22 Page 4 of 6

i. stating a business name, owner, address, telephone

number, number of employees, gross revenue, and payroll costs suggesting that the

company was an operating business;

ii. including fraudulent supporting documentation, such as

fabricated and misleading tax records;

iii. making several false certifications regarding his eligibility

to apply for a PPP loan, the operation of the business, and the use of PPP loan funds;

and,

iv. affirming the truth of the statements in the application.

c. It was further a part of the scheme and artifice that the defendant

would and did open and cause to be opened financial institution accounts into which

the fraudulently obtained PPP loan funds would be transferred via interstate wires;

d. It was further a part of the scheme and artifice that the defendant

would and did cause federally-insured financial institutions to send PPP loan

proceeds via interstate wire transfers; and,

e. It was further a part of the scheme and artifice that the defendant

would and did perform acts and make statements to promote and achieve the object

for the scheme and artifice to misrepresent, hide, and conceal, and cause to be

misrepresented, hidden, and concealed, the purpose of the scheme and artifice and

the acts committed in furtherance thereof.

4
Case 7:22-cr-00131-LSC-GMB Document 1 Filed 04/27/22 Page 5 of 6

Execution of the Scheme and Artifice

8. On or about the dates set forth below in each count, in the Northern

District of Alabama and elsewhere, the defendant, QUINCY TERRELL DOSS, for

the purpose of executing the aforesaid scheme and artifice, knowingly and

intentionally transmitted and caused to be transmitted by means of wire

communication in interstate and foreign commerce the writings, signs, signals,

pictures, and sounds described below, each transmission constituting a separate

count:

COUNT DATE OF WIRE DESCRIPTION OF WIRE

A wire transfer in the amount of $110,416 in
PPP loan funds, sent from outside of Alabama to
ONE April 13, 2021
a financial institution account in the defendant’s
name within the Northern District of Alabama.
A wire transfer in the amount of $110,417 in
PPP loan funds, sent from outside of Alabama to
TWO July 6, 2021
a financial institution account in the defendant’s
name within the Northern District of Alabama.

All in violation of 18 U.S.C. §§ 1343 and 2.

NOTICE OF FORFEITURE

9. The allegations contained in Counts One and Two are incorporated by

reference for the purpose of alleging forfeiture pursuant to 18 U.S.C. § 981(a)(1)(C)

and 28 U.S.C. § 2461(c).

10. Upon conviction of a violation of 18 U.S.C. § 1343, the defendant shall

forfeit to the United States, pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. §
5
Case 7:22-cr-00131-LSC-GMB Document 1 Filed 04/27/22 Page 6 of 6

2461(c), any property, real or personal, which constitutes or is derived from proceeds

traceable to the violation.

11. The property to be forfeited includes, but is not limited to, a money

judgment of at least $220,833, representing the proceeds obtained from the offense.

12. If any of the property described above, because 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;

c. has been 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,

the United States shall be entitled to forfeiture of substitute property pursuant to 21

U.S.C. § 853(p), as incorporated by 28 U.S.C. § 2461(c).

A TRUE BILL
/s/ Electronic Signature_______________
FOREPERSON OF THE GRAND JURY

PRIM F. ESCALONA
United States Attorney

/s/ Electronic Signature____________
JONATHAN “JACK” HARRINGTON
Assistant United States Attorney

File and source

File: 1.pdf
Size: 219,116 bytes
SHA-256: b148d189f2a708842465f785b6736a5ecbefcaaf61a97a68a48b6b4788148e09
Our copy: 1.pdf
Original: archive.org