Indictment — United States v. Keith Williams (E.D.N.Y.)

Summary

A grand jury in the Eastern District of New York indicted Keith Williams, Janine Davis, Morais Dicks, James Hames Jr., Jamari Lewis, Ewendra Mathurin and Tiffany Williams in case 2:25-cr-00020. The indictment alleges the defendants orchestrated a plan to submit more than $600 million in fraudulent requests for COVID-19 related tax credits by filing more than 8,000 false Forms 941. As a result, it says, the United States Treasury disbursed approximately $45 million to the defendants, their co-conspirators and clients. It also describes fraudulent Paycheck Protection Program loans obtained by the defendants. The counts include conspiracy to defraud the United States and wire fraud, and the indictment seeks forfeiture.

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

Full text

Text recognized from a scanned document; may contain errors.

Case 2:25-cr-00020-GRB Document 1

CMM:AT/JRS/SBB:RJK
F. #2022R01048

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA
- against -

KEITH WILLIAMS,
JANINE DAVIS,

also known as “Holiday Davis,”
MORAIS DICKS,
JAMES HAMES, JR.,

also known as “Poppa J,”
JAMARI LEWIS,

also known as “Mr. Chaketah,”
EWENDRA MATHURIN,

also known as “Rayda Mathurin,” and
TIFFANY WILLIAMS,

also known as “Joy Williams,”

Defendants.

THE GRAND JURY CHARGES:

Filed 01/15/25 Page 1 of 34 PagelD #: 1

FILED
IN CLERK'S OFFICE
U.S. DISTRICT COURT E.D.N.Y.

w JAN 15 202

LONG ISLAND OFFICE

(T. 18, U.S.C., §§ 371, 981(a)(1\(O),
982(a)(2), 982(b)(1), 1343, 2 and 3551 et
seq.; T. 21, U.S.C., § 853(p); T. 26,
U.S.C., § 7206(2); T. 28, U.S.C.,

§ 2461(c))

SEYBERTE J.

INTRODUCTION

At all times relevant to this Indictment, unless otherwise indicated:

I. The Defendants and Relevant Entities and Individuals

l. The defendant KEITH WILLIAMS (“K. WILLIAMS”) was a resident of

West Hempstead, New York. K. WILLIAMS owned and controlled Credit Reset Me Inc.

(“Credit Reset”), a New York corporation, which was purportedly a credit repair business

located at 683 Hempstead Turnpike, Franklin Square, New York. K. WILLIAMS also owned

and controlled 109 Super Store Motors Inc. (“109 Super Store”), Babylon Buyers Group Inc.
Case 2:25-cr-00020-GRB Documenti1_ Filed 01/15/25 Page 2 of 34 PagelD #: 2

(“Babylon Buyers”) and Lucky 13 Sports Bar and Grill Corp. (“Lucky 13”), each New York
corporations.

2 The defendant JANINE DAVIS, also known as “Holiday Davis,” was a
resident of Wheatley Heights, New York, and worked as a tax preparer. DAVIS owned and
controlled 7 Port LLC (“7 Port”) and Holiday’s Promise Ltd. (“Holiday’s Promise”), each New
York corporations.

ef The defendant MORAIS DICKS was a resident of Dix Hills, New York.
DICKS owned and controlled Progressive Homes and Development Inc. (“Progressive Homes”)
and Service Advisors, Inc. (“Service Advisors”), each New York corporations.

4. The defendant JAMES HAMES, JR., also known as “Poppa J,” was a
resident of Campbell Hall, New York. HAMES owned and controlled MJR Enterprise
Consulting Inc. (“MJR”), a New York corporation.

5. The defendant JAMARI LEWIS, also known as “Mr. Chaketah,” was a
resident of Queens, New York and Charlotte, North Carolina. LEWIS owned and controlled
Chakeetah, LLC (““Chakeetah”), a Colorado corporation.

6. The defendant EWENDRA MATHURIN, also known as “Rayda
Mathurin,” was a resident of Queens Village, New York. MATHURIN owned and controlled
Island Stream Inc. (“Island Stream”) and Rich n’ Yummy Ine. (“Rich n’ Yummy”), each New
York corporations.

7. The defendant TIFFANY WILLIAMS (“T. WILLIAMS”), also known as
“Joy Williams,” was resident of Brooklyn, New York, and worked as a tax preparer.

T. WILLIAMS owned and controlled J 2nd Power Trucking Company (“J2”), a Delaware

corporation, and Joy the Bookkeeper Corp. (“Joy the Bookkeeper”), a New York corporation.
Case 2:25-cr-00020-GRB Documenti_ Filed 01/15/25 Page 3 of 34 PagelD #: 3

8. Company #1 through Company #22, entities the identities of which are
known to the Grand Jury, were companies purportedly owned individually by the defendants and
their co-conspirators and used in furtherance of the defendants’ fraudulent scheme.

9, Co-Conspirator #1, an individual whose identity is known to the Grand
Jury, was an associate of the defendant JAMARI LEWIS.

10. Co-Conspirator #2, an individual whose identity is known to the Grand
Jury, was business partners with the defendant KEITH WILLIAMS and controlled Company #1
through Company #3.

11. | Co-Conspirator #3, an individual whose identity is known to the Grand
Jury, was employed at Credit Reset and controlled Company #4.

12. | Co-Conspirator #4, an individual whose identity is known to the Grand
Jury, was a client of and employee at Credit Reset and controlled Company #5 and Company #6.

13. | Co-Conspirator #5, an individual whose identity is known to the Grand
Jury, was an associate of the defendants KEITH WILLIAMS and JAMARI LEWIS and
controlled Company #7.

14. Co-Conspirator #6, an individual whose identity is known to the Grand
Jury, was a client of the defendant JAMES HAMES, JR. and controlled Company #8 through
Company #14.

15. | Co-Conspirator #7, an individual whose identity is known to the Grand
Jury, was a client of the defendant JAMES HAMES, JR. and controlled Company #15 and
Company #16.

16. Individual #1, an individual whose identity is known to the Grand Jury,

was a client of the defendant MORAIS DICKS and controlled Company #17.
Case 2:25-cr-00020-GRB Documenti_ Filed 01/15/25 Page 4 of 34 PagelD #: 4

17. Individual #2, an individual whose identity is known to the Grand Jury,
was an associate of the defendant JAMARI LEWIS and worked at Credit Reset. Individual #2
controlled Company #18 through Company #20.

18. Individual #3, an individual whose identity is known to the Grand Jury,
controlled Company #21 and Company #22.

19. Individual #4, an individual whose identity is known to the Grand Jury,
was a client of the defendant TIFFANY WILLIAMS and controlled Company #23.

20. — Individual #5, an individual whose identity is known to the Grand Jury,
controlled Company #24 and Company #25.

21. The Tax Preparation Software (“TPS”) was a tax return preparation
software accessible via the internet that was used to prepare and electronically file with the
Internal Revenue Service (“IRS”) various tax returns and related documents.

Il. Relevant Governmental Agencies and Definitions

22. The IRS was an agency of the United States Department of the Treasury
responsible for administering and enforcing federal tax laws, including refundable tax credits, of
the United States and collecting taxes owed to the United States.

23. Federal law required employers to collect, truthfully account for, and pay
over to the United States certain payroll taxes, including their employees’ withheld federal
income taxes, Social Security and Medicare taxes, and the employer’s matching portion of the
Social Security and Medicare taxes. A responsible person at a business was required to file,
quarterly, an Employer’s Quarterly Federal Tax Return, Form 941 (“Form 941”), reporting
certain information and assessing payroll taxes for the business and reporting certain
information, including the number of employees working at the business and the wages paid by

the business.
Case 2:25-cr-00020-GRB Documenti1 - Filed 01/15/25 Page 5 of 34 PagelD #: 5

24. A Wage and Tax Statement, Form W-2 (“Form W-2”), reported wages
paid by an employer to an employee and taxes withheld from those wages. It was issued by
United States employers to employees and filed by employers with the Social Security
Administration (“SSA”).

25. A Schedule C was a form attached to an Individual Income Tax Return
and filed with the IRS on which the taxpayer reported, among other things, gross receipts,
expenses, and income or loss from a business the taxpayer operated as a sole proprietor.

26. The Small Business Administration (“SBA”) was an executive branch
agency of the United States government that provided support to entrepreneurs and small
businesses. The mission of the SBA was to maintain and strengthen the nation’s economy by
enabling the establishment and viability of small businesses and by assisting in the economic
recovery of communities after disasters.

27. A tax return was a filing with the IRS which detailed the tax obligations of
the taxpayer or organization. Tax returns in the United States included, among others, Form 941
and Form 1040.

Ill. The COVID-19 Pandemic in the United States and Related Tax Credits

28. In or about December 2019, a novel coronavirus caused outbreaks of the
coronavirus disease COVID-19 that spread globally. On or about January 31, 2020, the
Secretary of the United States Department of Health and Human Services declared a national
public health emergency under Title 42, United States Code, Section 247d as a result of the
spread of COVID-19 to and within the United States. On or about March 13, 2020, the President
of the United States issued Proclamation 9994, declaring a national emergency beginning on or

about March 1, 2020, as a result of the rapid spread of COVID-19.
Case 2:25-cr-00020-GRB Documenti_ Filed 01/15/25 Page 6 of 34 PagelD #: 6

A. Employee Retention Credits

29. The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”),
enacted on March 27, 2020, provided for an employee retention credit (“ERC”), a refundable tax
credit, which was designed to encourage businesses to keep employees on their payroll during
the COVID-19 pandemic. The Taxpayer Certainty and Disaster Tax Relief Act of 2020 and the
American Rescue Plan Act (“ARPA”) modified and extended the ERC.

30. For calendar year 2020, eligible employers were authorized to claim an
ERC offsetting certain employment taxes that could not exceed 50 percent of up to $10,000 of
qualified wages paid to each employee from March 13, 2020, through December 31, 2020. The
maximum ERC for 2020 was $5,000 per employee per quarter. For calendar year 2021, eligible
employers were authorized to claim an ERC offsetting certain employment taxes that could not
exceed 70 percent of up to $10,000 of qualified wages paid to each employee during each
quarter. The maximum ERC for 2021 was $7,000 per employee per quarter.

31. Generally, businesses and tax-exempt organizations that qualified for the
ERC were those that: (a) were shut down during 2020 or the first three calendar quarters of 2021
by government order due to the COVID-19 pandemic; (b) experienced a specified decline in
gross receipts during the eligibility periods during 2020 or the first three calendar quarters of
2021; or (c) qualified as a recovery startup business for the third or fourth quarters of 2021.

32. A recovery startup business was defined in Title 26, United States Code,
Section 3134(c)(5) as an employer (i) that began carrying on any trade or business after February
15, 2020, (ii) for which the average annual gross receipts of the employer for the three-taxable-
year period ending with the taxable year that precedes the calendar quarter for which the credit is
determined does not exceed $1,000,000, and (iii) that is not otherwise an eligible employer due

to a full or partial suspension of operations or a decline in gross receipts.
Case 2:25-cr-00020-GRB Documenti1 Filed 01/15/25 Page 7 of 34 PagelD #: 7

B. Sick and Family Leave Wage Credits

33. The Families First Coronavirus Response Act provided for eligible
employers to receive refundable tax credits for wages paid to employees while on sick leave to
recover from any injury, disability, illness or condition resulting from COVID-19 or wages paid
to employees while on family leave to care for a family member who was injured, disabled, ill or
otherwise suffering from a condition due to COVID-19. Together these credits were called the
Sick and Family Leave Wage Credit (“SFLC,” and together with the ERC, the “COVID-Related
Tax Credits”).

34. | Under the SFLC, employers were entitled to receive a dollar-for-dollar
credit for qualified wages paid to an employee, plus allocable health plan expenses and the
employer’s share of Medicare taxes, while that employee was on sick leave resulting from
COVID-19. This credit was limited to ten days of sick leave per employee for the period ending
March 31, 2021. That resulted in a maximum credit of $5,110 per employee for that period. The
ARPA provided an identical credit for the period April 1, 2021 through September 31, 2021,
with the same maximum of $5,110 in credits per employee.

35. In addition, under the SFLC, employers were also entitled to receive a
credit of up to two-thirds of the qualified wages paid to an employee while that employee was on
family leave to care for a family member suffering from a condition resulting from COVID-19,
plus allocable health plan expenses and the employer’s share of Medicare taxes. For the period
ending March 31, 2021, this credit was limited to $200 per day for up to ten weeks, resulting in a
maximum eligible credit of $10,000 per employee. The ARPA provided an identical credit for

the period April 1, 2021 through September 31, 2021, and extended the length of family leave to
Case 2:25-cr-00020-GRB Documenti1 _ Filed 01/15/25 Page 8 of 34 PagelD #: 8

twelve weeks, thereby raising the maximum eligible credit for that period to $12,000 per
employee.

36. | Anemployer claimed COVID-Related Tax Credits by filing a Form 941
with the IRS for the relevant quarter. The Form 941 required an employer to provide to the IRS
information about the number of employees the business had and the wages paid by the business
during that quarter.

37. | The same wages could not be claimed as both qualified sick leave wages
and qualified family leave wages. Employers were also not eligible to receive both the ERC and
SFLC with respect to the same wages.

G. The Paycheck Protection Program

38. | The CARES Act also authorized up to $349 billion in forgivable loans to
small businesses for job retention and certain other expenses through a program referred to as the
Paycheck Protection Program (“PPP”). In or around April 2020, Congress authorized over $300
billion in additional PPP funding.

39. To obtain a PPP loan, a qualifying business was required to submit a “PPP
Loan Application,” which included an SBA Form 2483 — Borrower Application Form — and
supporting documentation. On the PPP Loan Application, an authorized representative of the
applying business was required to acknowledge the program rules and make certain affirmative
certifications to establish eligibility for the PPP loan. For example, on SBA Form 2483, the
recipient business, through an authorized representative, was required to state, among other
things, its average monthly payroll expenses and number of employees. These figures were used

to calculate the amount of money the business was eligible to receive under the PPP.
Case 2:25-cr-00020-GRB Document1 Filed 01/15/25 Page 9 of 34 PagelD #: 9

40. | The required supporting documentation for the SBA Form 2483 in the
PPP Loan Application frequently included, when the applicant was a sole proprietorship, the
most recent Schedule C, Profit or Loss from Business, filed by the owner of the business
attached to their Individual Income Tax Return.

41. The representative of the business who submitted the PPP Loan
Application was required to certify, on SBA Form 2483, that they understood that, should the
PPP funds be knowingly used for unauthorized purposes, the United States could pursue legal
remedies against the authorized representative, including charges of fraud.

42. Recipient businesses were required to use PPP loan proceeds for certain
permissible expenses, including, but not limited to, payroll costs, interest on mortgages, rent, and
utilities. The PPP provided that the principal and interest on a PPP loan would be entirely
forgiven if the recipient business spent the loan proceeds on these expense items within a
designated period of time after receiving the proceeds and used a certain percentage for payroll
costs.

43. | The SBA administered PPP loans. Individual PPP loans, however, were
issued and approved by private lenders, who received and processed PPP loan applications and
supporting documentation and, following SBA approval, made loans using the lenders’ own
funds.

IV. The Defendants’ Fraudulent Covid-Related Tax Credits Scheme

44. From in or about and between November 2021 and June 2023, the
defendants KEITH WILLIAMS, JANINE DAVIS, MORAIS DICKS, JAMES HAMES, JR.,
JAMARI LEWIS, EWENDRA MATHURIN and TIFFANY WILLIAMS, together with others,

orchestrated a scheme to submit more than $600 million in fraudulent requests for COVID-
Case 2:25-cr-00020-GRB Documenti Filed 01/15/25 Page 10 of 34 PagelD #: 10

Related Tax Credits designed to help workers and businesses negatively impacted by the
COVID-19 pandemic by filing more than 8,000 false Forms 941. As a result of the scheme, the
United States Treasury disbursed approximately $45 million to the defendants, their co-
conspirators and clients.

45. The defendants KEITH WILLIAMS, JANINE DAVIS, MORAIS DICKS,
JAMES HAMES, JR., JAMARI LEWIS, EWENDRA MATHURIN and TIFFANY
WILLIAMS, their co-conspirators and clients were not entitled to the amount of COVID-Related
Tax Credits or resulting tax refunds claimed on the Forms 941 that the defendants and their co-
conspirators prepared and filed. The fraudulent tax returns (including Forms 941) filed by the
defendants and their co-conspirators claimed tax refunds based on falsely reported wages and
benefits that the defendants and their co-conspirators knew had not been paid.

46. | Many of the entities, including Company #1 through Company #22,
reported on the fraudulent Forms 941 that the defendants KEITH WILLIAMS, JANINE DAVIS,
MORAIS DICKS, JAMES HAMES, JR., JAMARI LEWIS, EWENDRA MATHURIN and
TIFFANY WILLIAMS and their co-conspirators prepared and filed, and caused to be prepared
and filed, were not as they were represented on the Forms 941. Contrary to the representations
made in the Forms 941, the entities were inactive, had no employees, had not made prior tax
return filings, had no physical business location and/or did not timely file Forms W-2 for wages
paid to employees.

47. Furthermore, nearly all the Forms 941 that the defendants KEITH
WILLIAMS, JANINE DAVIS, MORAIS DICKS, JAMES HAMES, JR., JAMARI LEWIS,
EWENDRA MATHURIN and TIFFANY WILLIAMS and their co-conspirators prepared and

filed, and caused to be prepared and filed, fraudulently sought more refunds than the ERC or
Case 2:25-cr-00020-GRB Documenti- Filed 01/15/25 Page 11 of 34 PagelD #: 11

SFLC allowed. For example, many of the Forms 941 that the defendants and their co-
conspirators prepared and filed, either: (i) claimed an SFLC in excess of the amount of wages
reported; (ii) listed the same wages as both qualified sick leave wages and qualified family leave
wages; and/or (iii) claimed an SFLC and ERC for the same wages. None of these were
permitted under the prevailing legal framework.

48. Although the defendants carried out their fraudulent scheme using a
number of different physical locations and entities, it was primarily operated out of Credit Reset,
which was owned and controlled by KEITH WILLIAMS. Many of the defendants and their co-
conspirators either worked at Credit Reset for K. WILLIAMS for portions of the scheme or
visited Credit Reset in furtherance of the scheme. At Credit Reset and at other locations,
including their residences, which were located in the Eastern District of New York and
elsewhere, the defendants K. WILLIAMS, JANINE DAVIS, MORAIS DICKS, JAMES
HAMES, JR., JAMARI LEWIS, EWENDRA MATHURIN and TIFFANY WILLIAMS and
others prepared and filed false tax documents, including, but not limited to, false Forms 941 to
obtain ERC or SFLC funds.

49. The defendants KEITH WILLIAMS, JANINE DAVIS, MORAIS DICKS,
JAMES HAMES, JR., JAMARI LEWIS, EWENDRA MATHURIN and TIFFANY WILLIAMS
and others created a series of different accounts with TPS, which they used to prepare and file
false tax returns, and some of which they shared with other co-conspirators.

50. For example, between approximately May 2022 and February 2023, three
different TPS accounts controlled by the defendants KEITH WILLIAMS, JAMES HAMES, JR.,
JAMARI LEWIS and Co-Conspirator #2 were used to prepare and file 22 false Forms 941 for

the benefit of Individual #2. The false filings made on behalf of Individual #2 were purportedly
Case 2:25-cr-00020-GRB Documenti1- Filed 01/15/25 Page 12 of 34 PagelD #: 12

on behalf of Company #18, Company #19 and Company #20 and claimed fraudulent refunds
totaling approximately $1.43 million. Each of these filings was fraudulent because, among other
things, they claimed SFLC and ERC for the same wages.

51. Additionally, between approximately June 2022 and November 2022, a
TPS account controlled by the defendant KEITH WILLIAMS and a TPS account controlled by
the defendant JAMARI LEWIS were used to prepare and file, or attempted to prepare and file,
nine false Forms 941 for the benefit of Individual #3. The false filings were purportedly on
behalf of Company #21 and Company #22 and claimed fraudulent refunds totaling
approximately $645,848. Each of these filings was fraudulent because, among other things, they
claimed SFLC and ERC for the same wages.

52. Further, between approximately March 2022 and September 2022, a TPS
account controlled by the defendant KEITH WILLIAMS and a TPS account controlled by the
defendants JANINE DAVIS and TIFFANY WILLIAMS were used to prepare and file, or
attempted to prepare and file, seven false Forms 941 for the benefit of Individual #4. The false
filings were purportedly on behalf of Company #23 and claimed fraudulent refunds totaling
approximately $287,173. Each of these filings was fraudulent because, among other things, they
claimed SFLC and ERC for the same wages.

53. In addition, between approximately September 2022 and March 2023, a
TPS account controlled by the defendant KEITH WILLIAMS and a TPS account controlled by
Co-Conspirator #2 were used to prepare and file 15 false Forms 941 for the benefit of Individual
#5. The false filings were purportedly on behalf of Company #24 and Company #25 and
claimed fraudulent refunds totaling approximately $778,172. Each of these filings was

fraudulent because, among other things, they claimed SFLC and ERC for the same wages.
Case 2:25-cr-00020-GRB Documenti1 - Filed 01/15/25 Page 13 of 34 PagelD #: 13

54. The defendants KEITH WILLIAMS, JANINE DAVIS, MORAIS DICKS,
JAMES HAMES, JR., JAMARI LEWIS, EWENDRA MATHURIN and TIFFANY WILLIAMS
and their co-conspirators concealed their roles in the preparation of the false Forms 941 by,
among other things, not listing themselves on the returns as the paid preparer of the return as
required and, at times, using Virtual Private Networks (“VPNs”) to obscure their computers’ true
Internet Protocol address and location to connect to TPS.

55. The defendants KEITH WILLIAMS, JANINE DAVIS, MORAIS DICKS,
JAMES HAMES, JR., JAMARI LEWIS, EWENDRA MATHURIN, TIFFANY WILLIAMS,
their co-conspirators and others profited from the scheme in several different ways. The
defendants received tax refunds, in the form of United States Treasury checks, based on false
Forms 941 submitted for one or more of their own purported companies. The defendants also
profited by recruiting clients to have false Forms 941 prepared by their co-conspirators and
receiving a portion of the fee paid by the client to the co-conspirator. Finally, the defendants
charged clients a fee for initially preparing the false Forms 941 and/or collected a percentage of
the fraudulently obtained tax refund as a fee.

56. For example, on several occasions, after the defendant KEITH
WILLIAMS received a fee from a client or a United States Treasury check generated by a false
Form 941, K. WILLIAMS compensated the defendants JAMARI LEWIS, MORAIS DICKS,
JANINE DAVIS and EWENDRA MATHURIN, and Co-Conspirator #2 and Co-Conspirator #4,
for their roles in obtaining the fraudulent COVID-Related Tax Credits.

Sh To carry out the fraudulent scheme, the defendants and their co-
conspirators communicated using text messages, phone calls, and a WhatsApp group, among

other methods of communication. For example, on or about November 23, 2022, the defendant
Case 2:25-cr-00020-GRB Documenti Filed 01/15/25 Page 14 of 34 PagelD #: 14

KEITH WILLIAMS sent text-based messages to the defendant JAMES HAMES, JR. describing
the false statements that clients of the defendants and their co-conspirators should provide when
they called the IRS to check on the status of their tax refund. On or about November 27, 2022,
HAMES texted the instructions he received from K. WILLIAMS to Co-Conspirator #6.

58. Form 941, on which the COVID-Related Tax Credits were claimed by the
defendants and their co-conspirators, required the taxpayer to have an Employer Identification
Number (“EIN”), which is a nine-digit federal tax identification number assigned by the IRS for
businesses, tax-exempt organizations and other entities. If a prospective client did not have an
EIN, the defendants KEITH WILLIAMS, JANINE DAVIS, MORAIS DICKS, JAMES
HAMES, JR., JAMARI LEWIS, EWENDRA MATHURIN and TIFFANY WILLIAMS,
together with others, sometimes provided the client with a business with an EIN or facilitated the
client’s purchase of one to then be used to file Forms 941 claiming COVID-Related Tax Credits.
Often, the entities that the defendants provided to clients were shell companies or companies that
were previously operational businesses but were no longer operating.

59. | On occasion, the IRS and SSA requested additional information regarding
the Forms 941 filed by the defendants KEITH WILLIAMS, JANINE DAVIS, MORAIS DICKS,
JAMES HAMES, JR., JAMARI LEWIS, EWENDRA MATHURIN and TIFFANY
WILLIAMS. When that happened, the defendants and their co-conspirators transmitted and
caused to be transmitted false information to the IRS and prepared and filed with the SSA false
Forms W-2 corresponding to the previously filed false Forms 941. For example, in or about
March 2022, LEWIS instructed Co-Conspirator #5 to submit false information regarding

Business #7 to the IRS in response to a request for taxpayer information.
Case 2:25-cr-00020-GRB Documenti Filed 01/15/25 Page 15 of 34 PagelD #: 15

V. The Defendants’ Fraudulent PPP Loans

60. From the onset of the COVID-19 pandemic, the defendants KEITH
WILLIAMS, JANINE DAVIS, MORAIS DICKS, JAMES HAMES, JR., JAMARI LEWIS,
EWENDRA MATHURIN and TIFFANY WILLIAMS also each fraudulently obtained
government funds by filing and causing to be filed false PPP loan applications requesting PPP
loans for themselves.

61. | Among other things, in some instances, the defendants provided false
supporting documentation included with their PPP loan applications, including false tax forms
representing, among other falsehoods, that wages were paid that were not paid to employees that
did not exist. Some of the false tax forms that were included in the PPP loan applications were
never filed with the IRS. The PPP loan applications themselves were also fraudulent in that in
some instances, the defendants represented that wages were paid that were not paid to employees
that did not exist.

COUNT ONE
(Conspiracy to Defraud the United States)

62. The allegations contained in paragraphs one through 61 are realleged and
incorporated as if fully set forth in this paragraph.

63. In or about and between November 2021 and June 2023, both dates being
approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendants KEITH WILLIAMS, JANINE DAVIS, also known as “Holiday Davis,” MORAIS
DICKS, JAMES HAMES, JR., also known as “Poppa J,” JAMARI LEWIS, also known as “Mr.
Chaketah,” EWENDRA MATHURIN, also known as “Rayda Mathurin,” and TIFFANY
WILLIAMS, also known as “Joy Williams,” together with others, did knowingly and willfully

conspire to defraud the United States by impeding, impairing, obstructing and defeating the
Case 2:25-cr-00020-GRB Documenti_- Filed 01/15/25 Page 16 of 34 PagelD #: 16

lawful governmental functions of the IRS, specifically, the administration and distribution of
COVID-Related Tax Credits.

64. In furtherance of the conspiracy and to effect its objects, within the
Eastern District of New York and elsewhere, the defendants KEITH WILLIAMS, JANINE
DAVIS, also known as “Holiday Davis,” MORAIS DICKS, JAMES HAMES, JR., also known
as “Poppa J,” JAMARI LEWIS, also known as “Mr. Chaketah,” EWENDRA MATHURIN, also
known as “Rayda Mathurin,” and TIFFANY WILLIAMS, also known as “Joy Williams,”
together with others, did commit and cause the commission of, among others, the following:

OVERT ACTS

(a) On or about November 29, 2021, LEWIS directed Co-Conspirator
#1 to file a fraudulent Form 941 claiming an approximately $64,182 tax refund based on
COVID-19 Related Tax Credits for Chakeetah to which it was not entitled.

(b) On or about January 28, 2022, K. WILLIAMS and LEWIS
directed Co-Conspirator #1 to file a fraudulent Form 941 claiming an approximately $115,632
tax refund based on COVID-19-Related Tax Credits for 109 Super Store to which it was not
entitled.

(c) On or about February 8, 2022, MATHURIN prepared and filed and
caused to be prepared and filed with the IRS a fraudulent Form 941 claiming an approximately
$59,966.39 tax refund based on COVID-19-Related Tax Credits for Island Stream for which it
was not entitled.

(d) On or about March 18, 2022, DAVIS prepared and filed and

caused to be prepared and filed with the IRS a fraudulent Form 941 claiming an approximately
Case 2:25-cr-00020-GRB Documenti- Filed 01/15/25 Page 17 of 34 PagelD #: 17

$54,976.14 tax refund based on COVID-19-Related Tax Credits for Holiday’s Promise for which
it was not entitled.

(e) On or about March 18, 2022, T. WILLIAMS prepared and filed
and caused to be prepared and filed with the IRS a fraudulent Form 941 claiming an
approximately $45,989.12 tax refund based on COVID-19-Related Tax Credits for J2 for which
it was not entitled.

(f) On or about June 20, 2022, Co-Conspirator #2 caused to be
prepared and filed with the IRS a fraudulent Form 941 claiming an approximately $115,992.14
tax refund based on COVID-19-Related Tax Credits for Company #2 for which it was not
entitled.

(g) On or about June 23, 2022, HAMES prepared and filed and caused
to be prepared and filed with the IRS a fraudulent Form 941 claiming an approximately
$71,875.94 tax refund based on COVID-19-Related Tax Credits for Company #12 for which it
was not entitled.

(h) On or about July 14, 2022, K. WILLIAMS prepared and filed and
caused to be prepared and filed with the IRS a fraudulent Form 941 claiming an approximately
$57,816.22 tax refund based on COVID-19-Related Tax Credits for Company #6, for which it
was not entitled.

(i) On or about September 30, 2022, LEWIS prepared and filed and
caused to be prepared and filed with the IRS a fraudulent Form 941 claiming an approximately
$67,092.02 tax refund based on COVID-19-Related Tax Credits for Chakeetah for which it was

not entitled.
Case 2:25-cr-00020-GRB Document1 Filed 01/15/25 Page 18 of 34 PagelD #: 18

(j) On or about October 22, 2022, LEWIS and Co-Conspirator #5
prepared and filed and caused to be prepared and filed with the IRS a fraudulent Form 941
claiming an approximately $73,970.67 tax refund based on COVID-19-Related Tax Credits for
Company #7 for which it was not entitled.

(k) On or about January 5, 2023, DICKS directed Individual #1, who
just days prior had received over $200,000 in tax refund checks as a result of false Forms 941
prepared and filed by the defendants and their co-conspirators, to write a check for $100,000 to
Progressive Homes.

(Title 18, United States Code, Sections 371 and 3551 et seq.)

COUNTS TWO THROUGH SEVEN
(Wire Fraud)

65. The allegations contained in paragraphs one through 61 are realleged and
incorporated as if fully set forth in this paragraph.

66. On or about the dates set forth below, within the Eastern District of New
York and elsewhere, the defendant KEITH WILLIAMS, together with others, did knowingly and
intentionally devise a scheme and artifice to defraud the IRS and to obtain money and property
from the IRS by means of materially false and fraudulent pretenses, representations and
promises, and for the purpose of executing such scheme and artifice did transmit and cause to be
transmitted by means of wire communication in interstate and foreign commerce, writings, signs,

signals, pictures and sounds, to wit: the following Forms 941, all of which were electronically

filed with the IRS.

De SCrip 18 10n 0 f Wire Tra insSmIssion —

A Form 941 om 2021 4th Quarter for 109 Super Store claiming
TWO 1/28/2022 a tax refund of approximately $115,632.
Case 2:25-cr-00020-GRB Document1 Filed 01/15/25 Page 19 of 34 PagelD #: 19

| A Form 941 for 2021 Ist Quarter for Lucky 13 claiming a

10n 0} iSSion

THREE 1/31/2022 refund of approximately $76,012.
A Form 941 for 2022 Ist Quarter for 109 Super Store claiming a
FOUR 5/30/2022 tax refund of approximately $61,230.51.
A Form 941 for 2022 2nd Quarter for Babylon Buyers claiming
FIVE 6/30/2022 a tax refund of approximately $63,948.22.
A Form 941 for 2022 3rd Quarter for Babylon Buyers claiming
SIX 10/19/2022 a tax refund of approximately $63,948.35.
A Form 941 for 2022 2nd Quarter for Lucky 13 claiming a tax
SEVEN 10/19/2022 refund of approximately $66,576.28.

(Title 18, United States Code, Sections 1343, 2 and 3551 et seq.)

COUNTS EIGHT THROUGH TEN

(Wire Fraud)

67. The allegations contained in paragraphs one through 61 are realleged and

incorporated as if fully set forth in this paragraph.

68. On or about the dates set forth below, within the Eastern District of New

York and elsewhere, the defendant JAMARI LEWIS, also known as “Mr. Chaketah,” together

with others, did knowingly and intentionally devise a scheme and artifice to defraud the IRS and

to obtain money and property from the IRS by means of materially false and fraudulent

pretenses, representations and promises, and for the purpose of executing such scheme and

artifice did transmit and cause to be transmitted by means of wire communication in interstate

and foreign commerce, writings, signs, signals, pictures and sounds, to wit, the following Forms

941, all of which were electronically filed with the IRS:

| A Form 941 for 2020 2nd Quarter for Chakeetah claiming x |

EIGHT 11/29/2021 tax refund of approximately $64,182.
A Form 941 for 2021 3rd Quarter for Chakeetah claiming a tax
NINE 12/3/2021 refund of approximately $68,646.97.
Case 2:25-cr-00020-GRB Document1 Filed 01/15/25 Page 20 of 34 PagelD #: 20

A Form 941 for 2021 2nd Quarter for Chakeetah claiming a
TEN 12/4/2021 tax refund of approximately $85,897.80.

(Title 18, United States Code, Sections 1343, 2 and 3551 et seq.)

COUNTS ELEVEN THROUGH FOURTEEN
(Wire Fraud)

69. The allegations contained in paragraphs one through 61 are realleged and
incorporated as if fully set forth in this paragraph.

70. On or about the dates set forth below, within the Eastern District of New
York and elsewhere, the defendant EWENDRA MATHURIN, also known as “Rayda,” together
with others, did knowingly and intentionally devise a scheme and artifice to defraud the IRS and
to obtain money and property from the IRS by means of materially false and fraudulent
pretenses, representations and promises, and for the purpose of executing such scheme and
artifice did transmit and cause to be transmitted by means of wire communication in interstate

and foreign commerce, writings, signs, signals, pictures and sounds, to wit, the following Forms

941, all of which were electronically filed with the IRS:

| A Form 941 for 2021 Ist Quarter for Island Stream

ELEVEN 2/8/2022 claiming a tax refund of approximately $59,966.39.
A Form 941 for 2021 4th Quarter for Island Stream
TWELVE 4/5/2022 claiming a tax refund of approximately $74,834.13.
A Form 941 for 2020 2nd Quarter for Rich n’ Yummy
THIRTEEN 10/26/2022 claiming a tax refund of approximately $89,807.51.
A Form 941 for 2021 3rd Quarter for Rich n’ Yummy
FOURTEEN 10/26/2022 claiming a tax refund of approximately $100,500.13.

(Title 18, United States Code, Sections 1343, 2 and 3551 et seq.)
Case 2:25-cr-00020-GRB Document1 Filed 01/15/25 Page 21 of 34 PagelD #: 21

71.

COUNTS FIFTEEN THROUGH TWENTY

(Wire Fraud)

The allegations contained in paragraphs one through 61 are realleged and

incorporated as if fully set forth in this paragraph.

On or about the dates set forth below, within the Eastern District of New

York and elsewhere, the defendant JANINE DAVIS, also known as “Holiday Davis,” together

with others, did knowingly and intentionally devise a scheme and artifice to defraud the IRS and

to obtain money and property from the IRS by means of materially false and fraudulent

pretenses, representations and promises, and for the purpose of executing such scheme and

artifice did transmit and cause to be transmitted by means of wire communication in interstate

and foreign commerce, writings, signs, signals, pictures and sounds, to wit, the following Forms

941, all of which were electronically filed with the IRS:

FIFTEEN

3/18/2022

| A form 941 for 2020

Quarter for Holiday’s Promise
claiming a tax refund of approximately $54,976.14.

SIXTEEN

5/30/2022

A Form 941 for 2021 Ist Quarter for 7 Port claiming a tax
refund of approximately $235,084.68.

SEVENTEEN

5/30/2022

A Form 941 for 2021 2nd Quarter for 7 Port claiming a
tax refund of approximately $255,192.60.

EIGHTEEN

6/2/2022

A Form 941 for 2021 4th Quarter for Holiday’s Promise
claiming a tax refund of approximately $217,376.71.

NINETEEN

6/2/2022

A Form 941 for 2021 3rd Quarter for Janine Davis (sole
proprietorship) claiming a tax refund of approximately
$145,007.90.

TWENTY

6/2/2022

A Form 941 for 2020 3rd Quarter for Janine Davis (sole
proprietorship) claiming a tax refund of approximately
$66,390.90.

(Title 18, United States Code, Sections 1343, 2 and 3551 et seq.)
Case 2:25-cr-00020-GRB Document1 Filed 01/15/25 Page 22 of 34 PagelD #: 22

COUNTS TWENTY-ONE THROUGH TWENTY-FOUR
(Wire Fraud)

73. The allegations contained in paragraphs one through 61 are realleged and
incorporated as if fully set forth in this paragraph.

74. Onor about the dates set forth below, within the Eastern District of New
York and elsewhere, the defendant TIFFANY WILLIAMS, also known as “Joy Williams,”
together with others, did knowingly and intentionally devise a scheme and artifice to defraud the
IRS and to obtain money and property from the IRS by means of materially false and fraudulent
pretenses, representations and promises, and for the purpose of executing such scheme and
artifice did transmit and cause to be transmitted by means of wire communication in interstate
and foreign commerce, writings, signs, signals, pictures and sounds, to wit, the following Forms

941, all of which were electronically filed with the IRS:

TWENTY- A Form 941 for 2021 Ist Quarter for J2 claiming a tax
ONE 3/18/2022 refund of approximately $45,989.12.
TWENTY- A Form 941 for 2020 4th Quarter for J2 claiming a tax
TWO 4/1/2022 refund of approximately $53,519.40.
A Form 941 for 2021 Ist Quarter for Joy the
TWENTY- Bookkeeper claiming a tax refund of approximately
THREE 4/8/2022 $41,436.35.
A Form 941 for 2020 3rd Quarter for Joy the
TWENTY- Bookkeeper claiming a tax refund of approximately
FOUR 4/9/2022 $44,337.38.

(Title 18, United States Code, Sections 1343, 2 and 3551 et seq.)

COUNTS TWENTY-FIVE THROUGH TWENTY-SEVEN
(Wire Fraud)

75. The allegations contained in paragraphs one through 61 are realleged and
incorporated as if fully set forth in this paragraph.
76. | Onor about the dates set forth below, within the Eastern District of New

York and elsewhere, the defendant JAMES HAMES, JR., also known as “Poppa J,” together
Case 2:25-cr-00020-GRB Document1 Filed 01/15/25 Page 23 of 34 PagelD #: 23

with others, did knowingly and intentionally devise a scheme and artifice to defraud the IRS and
to obtain money and property from the IRS by means of materially false and fraudulent
pretenses, representations and promises, and for the purpose of executing such scheme and
artifice did transmit and cause to be transmitted by means of wire communication in interstate
and foreign commerce, writings, signs, signals, pictures and sounds, to wit, the following Forms

941, all of which were electronically filed with the IRS:

TWENTY- | - ai A Form 941 for 2022 Ist Quarter for claiming tax

FIVE 6/15/2022 refund of approximately $75,358.31.
TWENTY- A Form 941 for 2022 3rd Quarter for MJR claiming a tax

SIX 10/24/2022 refund of approximately $71,658.75.
TWENTY- A Form 941 for 2022 4th Quarter for MJR claiming a tax

SEVEN 1/16/2023 refund of approximately $78,496.01.

(Title 18, United States Code, Sections 1343, 2 and 3551 et seq.)

COUNTS TWENTY-EIGHT THROUGH THIRTY-THREE
(Aiding and Assisting in the Preparation of False Tax Returns)

83. The allegations contained in paragraphs one through 61 are realleged and
incorporated as if fully set forth in this paragraph.

84. On or about the dates set forth below, within the Eastern District of New
York, and elsewhere, the defendant KEITH WILLIAMS willfully aided and assisted in, and
procured, counseled, and advised the preparation and presentation to the IRS of a Form 941,
Employer’s Quarterly Federal Tax Returns, for each of the periods stated below, which were
false and fraudulent as to one or more material matters, and which K. WILLIAMS did not

believe to be true and correct as to every material matter:
|

TWENTY-
EIGHT

1
|

|
|

Company
#7

Case 2:25-cr-00020-GRB Document 1

2021 Ist
Quarter

Filed 01/15/25

1/31/2022

Line 2, wages, tips, and other
compensation

Line 13e, Total deposits and
refundable credits

Line 15, Overpayment

Page 24 of 34 PagelD #: 24

TWENTY-
NINE

Company
#1

2020 2nd
Quarter

2/1/2022

Line 2, wages, tips, and other
compensation
Line 13e, Total deposits,

deferrals, and refundable credits

Line 15, Overpayment

THIRTY

Company
#5

2021 3rd
Quarter

3/26/2022

Line 1, number of employees
Line 2, wages, tips, and other
compensation

Line 13g, Total deposits and
refundable credits

Line 15, Overpayment

THIRTY-
ONE

Company
#4

2021 4th
Quarter

4/18/2022

Line 1, number of employees
Line 2, wages, tips, and other
compensation

Line 13g, Total deposits and
refundable credits

Line 15, Overpayment

THIRTY-
TWO

Company
#2

2021 Ist
Quarter

6/20/2022

Line 1, number of employees
Line 2, wages, tips, and other
compensation

Line 13e, Total deposits and
refundable credits

Line 15, Overpayment

THIRTY-
THREE

Company
#6

2022 2nd
Quarter

7/14/2022

Line 1, number of employees
Line 2, wages, tips, and other
compensation

Line 13g, Total deposits and
refundable credits

Line 15, Overpayment

(Title 26, United States Code, Section 7206(2); Title 18, United States Code,

Sections 3551 et seq.)
Case 2:25-cr-00020-GRB Document1 Filed 01/15/25 Page 25 of 34 PagelD #: 25

COUNTS THIRTY-FOUR THROUGH FORTY-TWO
(Aiding and Assisting in the Preparation of False Tax Returns)

87. The allegations contained in paragraphs one through 61 are realleged and
incorporated as if fully set forth in this paragraph.

88. On or about the dates set forth below, within the Eastern District of New
York, and elsewhere, the defendant JAMES HAMES, JR., also known as “Poppa J,” willfully
aided and assisted in, and procured, counseled, and advised the preparation and presentation to
the IRS of a Form 941, Employer’s Quarterly Federal Tax Returns, for each of the periods stated

below, which were false and fraudulent as to one or more material matters, and which HAMES

did not believe to be true and correct as to every material matter:

e Line 2, wages, tips, and other
compensation
e Line 13e, Total deposits,
deferrals, and refundable
THIRTY- 2020 2nd credits
FOUR Company #8 | Quarter 6/23/2022 e Line 15, Overpayment
e Line 1, number of employees
e Line 2, wages, tips, and other
compensation
e Line 13e, Total deposits and
THIRTY- 2020 2nd refundable credits
FIVE Company #9 | Quarter 6/23/2022 e Line 15, Overpayment
e Line 1, number of employees
e Line 2, wages, tips, and other
compensation
e Line 13g, Total deposits and
THIRTY- 2021 4th refundable credits
SIX Company #10 | Quarter 6/24/2022 e Line 15, Overpayment
e Line 1, number of employees
e Line 2, wages, tips, and other
compensation
e Line 13g, Total deposits and
THIRTY- 2021 3rd refundable credits
SEVEN Company #14 | Quarter 6/26/2022 e Line 15, Overpayment
THIRTY-
EIGHT

Case 2:25-cr-00020-GRB

Company #13

Document 1

2021 Ist
Quarter

Filed 01/15/25

6/26/2022

Page 26 of 34 PagelD #: 26

Line 1, number of employees
Line 2, wages, tips, and other
compensation

Line 13e, Total deposits and
refundable credits

Line 15, Overpayment

THIRTY-
NINE

Company #12

2022 Ist
Quarter

6/26/2022

Line 1, number of employees
Line 2, wages, tips, and other
compensation

Line 13g, Total deposits and
refundable credits

Line 15, Overpayment

FORTY

Company #15

2021 2nd
Quarter

6/26/2022

Line 1, number of employees
Line 2, wages, tips, and other
compensation

Line 13g, Total deposits and
refundable credits

Line 15, Overpayment

FORTY-
ONE

Company #16

2021 2nd
Quarter

7/4/2022

Line 1, number of employees
Line 2, wages, tips, and other
compensation

Line 13g, Total deposits and
refundable credits

Line 15, Overpayment

FORTY-
TWO

Company #11

2022 4th
Quarter

1/22/2023

Line 1, number of employees
Line 2, wages, tips, and other
compensation

Line 13g, Total deposits and
refundable credits

Line 15, Overpayment

Sections 3551 et seq.)

89.

(Title 26, United States Code, Section 7206(2); Title 18, United States Code,

COUNTS FORTY-THREE THROUGH FORTY-FIVE

(Aiding and Assisting in the Preparation of False Tax Returns)

incorporated as if fully set forth in this paragraph.

The allegations contained in paragraphs one through 61 are realleged and
Case 2:25-cr-00020-GRB Document 1

Filed 01/15/25

Page 27 of 34 PagelD #: 27

90. On or about the dates set forth below, within the Eastern District of New

York, and elsewhere, the defendant MORAIS DICKS, willfully aided and assisted in, and

procured, counseled, and advised the preparation and presentation to the IRS of a Form 941,

Employer’s Quarterly Federal Tax Returns for each of the periods stated below, which were false

and fraudulent as to one or more material matters, and which DICKS did not believe to be true

and correct as to every material matter:

FORTY-
THREE

2021 3rd
Company #17 | Quarter

11/10/2022 |e

Line 1, number of employees
Line 2, wages, tips, and other
compensation

Line 13g, Total deposits and
refundable credits

Line 15, Overpayment

FORTY-
FOUR

2021 4th
Company #17 | Quarter

11/10/2022 |e

Line 1, number of employees
Line 2, wages, tips, and other
compensation

Line 13g, Total deposits and
refundable credits

Line 15, Overpayment

FORTY-
FIVE

2022 Ist
Company #17 | Quarter

11/10/2022 |e

Line 1, number of employees
Line 2, wages, tips, and other
compensation

Line 13g, Total deposits and
refundable credits

Line 15, Overpayment

(Title 26, United States Code, Section 7206(2); Title 18, United States Code,

Sections 3551 et seq.)

COUNTS FORTY-SIX THROUGH FORTY-NINE

(Wire Fraud)

91. The allegations contained in paragraphs one through 61 are realleged and

incorporated as if fully set forth in this paragraph.
Case 2:25-cr-00020-GRB Document1 Filed 01/15/25 Page 28 of 34 PagelD #: 28

On or about the following dates, within the Eastern District of New York

and elsewhere, the defendant KEITH WILLIAMS, together with others, did knowingly and

intentionally devise a scheme and artifice to defraud the SBA and one or more financial

institutions administering the PPP program, and to obtain money and property from the SBA and

said financial institutions by means of materially false and fraudulent pretenses, representations

and promises, and for the purpose of executing such scheme and artifice did transmit and cause

to be transmitted, by means of wire communication in interstate and foreign commerce, one or

more writings, signs, signals, pictures and sounds, to wit:

FORTY- proprietorship) requesting a PPP loan of approximately
SIX 4/15/2021 $20,833.
A PPP Loan Application filed for KEITH WILLIAMS (sole
FORTY- proprietorship) requesting a PPP loan of approximately
SEVEN 5/7/2021 $20,833.
A PPP Loan Application filed for Co-Conspirator #2 (sole
FORTY- proprietorship) requesting a PPP loan of approximately
EIGHT 4/18/2021 $20,833.
A PPP Loan Application filed for Co-Conspirator #2 (sole
FORTY- proprietorship) requesting a PPP loan of approximately
NINE 5/5/2021 $20,833.

(Title 18, United States Code, Sections 1343, 2 and 3551 et seq.)

COUNT FIFTY
(Wire Fraud)

The allegations contained in paragraphs one through 61 are realleged and

incorporated as if fully set forth in this paragraph.

On or about March 18, 2021, within the Eastern District of New York and

elsewhere, defendant JAMARI LEWIS, also known as “Mr. Chaketah,” together with others, did

knowingly and intentionally devise a scheme and artifice to defraud the SBA and one or more
Case 2:25-cr-00020-GRB Document1 Filed 01/15/25 Page 29 of 34 PagelD #: 29

financial institutions administering the PPP program, and to obtain money and property from the
SBA and said financial institutions by means of materially false and fraudulent pretenses,
representations and promises, and for the purpose of executing such scheme and artifice, did
transmit and cause to be transmitted by means of wire communication in interstate and foreign
commerce, one or more writings, signs, signals, pictures and sounds, to wit: a March 18, 2021
PPP loan application filed for JAMARI LEWIS (sole proprietorship) requesting a PPP loan of
approximately $20,750.

(Title 18, United States Code, Sections 1343 and 3551 et seq.)

COUNTS FIFTY-ONE THROUGH FIFTY-TWO
(Wire Fraud)

95. The allegations contained in paragraphs one through 61 are realleged and
incorporated as if fully set forth in this paragraph.

96. | Onor about the following dates, within the Eastern District of New York
and elsewhere, defendant EWENDRA MATHURIN, also known as, “Rayda,” together with
others, did knowingly and intentionally devise a scheme and artifice to defraud the SBA and one
or more financial institutions administering the PPP program, and to obtain money and property
from the SBA and said financial institutions by means of materially false and fraudulent
pretenses, representations and promises, and for the purpose of executing such scheme and

artifice, did transmit and cause to be transmitted by means of wire communication in interstate

and foreign commerce, one or more writings, signs, signals, pictures and sounds, to wit:

A PPP loan application filed for EWENDRA MATHURIN
FIFTY- (sole proprietorship) requesting a PPP loan of approximately
ONE 4/18/2021 $20,833.
Case 2:25-cr-00020-GRB Document1 Filed 01/15/25 Page 30 of 34 PagelD #: 30

A PPP loan application filed for EWENDRA
FIFTY- (sole proprietorship) requesting a PPP loan of approximately
TWO 5/8/2021 $20,833.

(Title 18, United States Code, Sections 1343, 2 and 3551 et seq.)

COUNT FIFTY-THREE
(Wire Fraud)

97. The allegations contained in paragraphs one through 61 are realleged and
incorporated as if fully set forth in this paragraph.

98. On or about April 16, 2021, within the Eastern District of New York and
elsewhere, defendant JANINE DAVIS, also known as “Holiday Davis,” together with others, did
knowingly and intentionally devise a scheme and artifice to defraud the SBA and one or more
financial institutions administering the PPP program, and to obtain money and property from the
SBA and said financial institutions by means of materially false and fraudulent pretenses,
representations and promises, and for the purpose of executing such scheme and artifice, did
transmit and cause to be transmitted by means of wire communication in interstate and foreign
commerce, one or more writings, signs, signals, pictures and sounds, to wit: an April 16, 2021
PPP loan application filed for JANINE DAVIS (sole proprietorship) requesting a PPP loan of
approximately $20,833.

(Title 18, United States Code, Sections 1343, 2 and 3551 et seq.)

COUNT FIFTY-FOUR
(Wire Fraud)

99. The allegations contained in paragraphs one through 61 are realleged and

incorporated as if fully set forth in this paragraph.
Case 2:25-cr-00020-GRB Documenti- Filed 01/15/25 Page 31 of 34 PagelD #: 31

100. On or about June 29, 2020, within the Eastern District of New York and
elsewhere, defendant TIFFANY WILLIAMS, also known as “Joy Williams,” together with
others, did knowingly and intentionally devise a scheme and artifice to defraud the SBA and one
or more financial institutions administering the PPP program, and to obtain money and property
from the SBA and said financial institutions by means of materially false and fraudulent
pretenses, representations and promises, and for the purpose of executing such scheme and
artifice, did transmit and cause to be transmitted by means of wire communication in interstate
and foreign commerce, one or more writings, signs, signals, pictures and sounds, to wit: a June
29, 2020 PPP loan application filed for Joy the Bookkeeper requesting a PPP loan of
approximately $88,152.

(Title 18, United States Code, Sections 1343, 2 and 3551 et seq.)

COUNTS FIFTY-FIVE THROUGH FIFTY-SIX
(Wire Fraud)

101. The allegations contained in paragraphs one through 61 are realleged and
incorporated as if fully set forth in this paragraph.

102. Onor about the following dates, within the Eastern District of New York
and elsewhere, the defendant MORAIS DICKS, together with others, did knowingly and
intentionally devise a scheme and artifice to defraud the SBA and one or more financial
institutions administering the PPP program, and to obtain money and property from the SBA and
said financial institutions by means of materially false and fraudulent pretenses, representations
and promises, and for the purpose of executing such scheme and artifice did transmit and cause
to be transmitted by means of wire communication in interstate and foreign commerce, one or

more writings, signs, signals, pictures and sounds, to wit:
Case 2:25-cr-00020-GRB Document1 Filed 01/15/25 Page 32 of 34 PagelD #: 32

FIFTY- A PPP loan application filed for Progressive Homes
FIVE 5/19/2020 requesting a PPP loan of approximately $20,832.
FIFTY- A PPP loan application file for Service Advisors
SIX 6/3/2020 requesting a PPP loan of approximately $20,833.

(Title 18, United States Code, Sections 1343, 2 and 3551 et seq.)

CRIMINAL FORFEITURE ALLEGATION
AS TO COUNTS TWO THROUGH TWENTY-SEVEN

103. The United States hereby gives notice to the defendants that, upon their
conviction of any of the offenses charged in Counts Two through Twenty-Seven, the government
will seek forfeiture in accordance with Title 18, United States Code, Section 981(a)(1)(C) and
Title 28, United States Code, Section 2461(c), which require any person convicted of such
offenses to forfeit any property, real or personal, constituting, or derived from, proceeds obtained
directly or indirectly as a result of such offenses.

104. Ifany of the above-described forfeitable property, as a result of any act or
omission of the defendants:

(a) cannot be located upon the exercise of due diligence;

(b) has been transferred or sold to, or deposited with, a third party;

(d) has been substantially diminished in value; or

(e) has been commingled with other property which cannot be divided
without difficulty;

it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to
Case 2:25-cr-00020-GRB Documenti - Filed 01/15/25 Page 33 of 34 PagelD #: 33

seek forfeiture of any other property of the defendants up to the value of the forfeitable property
described in this forfeiture allegation.

(Title 18, United States Code, Section 981(a)(1)(C); Title 21, United States Code,
Section 853(p); Title 28, United States Code, Section 2461(c))

CRIMINAL FORFEITURE ALLEGATION
AS TO COUNTS FORTY-SIX THROUGH FIFTY-SIX

105. The United States hereby gives notice to the defendants charged in Counts
Forty-Six through Fifty-Six that, upon their conviction of any of such offenses, the government
will seek forfeiture in accordance with Title 18, United States Code, Section 982(a)(2), which
requires any person convicted of such offenses to forfeit any property constituting, or derived
from, proceeds obtained directly or indirectly as a result of such offenses.
106. Ifany of the above-described forfeitable property, as a result of any act or
omission of the defendants:
(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;
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), as

incorporated by Title 18, United States Code, Section 982(b)(1), to seek forfeiture of any other
Case 2:25-cr-00020-GRB Documenti_ Filed 01/15/25 Page 34 of 34 PagelD #: 34

property of the defendants up to the value of the forfeitable property described in this forfeiture
allegation.
(Title 18, United States Code, Sections 982(a)(2) and 982(b)(1); Title 21, United

States Code, Section 853(p))

A TRUE BILL

CAROLYN POKORNY
ACTING UNITED STATES ATTORNEY
EASTERN DISTRICT OF NEW YORK

File and source

File: f6-02261-1386206.pdf
Size: 6,943,772 bytes
SHA-256: c00114201caf7aac891b69c8faa0eb99c0b0ed224cf24fe67885e655409d294f
Our copy: f6-02261-1386206.pdf
Original: No public link identified.