Indictment — United States v. Verlynn Jamelah Horne, Middle District of Florida (Document 1)

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An Indictment in United States of America v. Verlynn Jamelah Horne, Case 6:25-cr-00161-JSS-NWH, in the U.S. District Court for the Middle District of Florida, Orlando Division, filed June 4, 2025 as Document 1. It cites 18 U.S.C. § 1343, 18 U.S.C. § 1028A, 18 U.S.C. § 1957 and 26 U.S.C. § 7203, with Counts One Through Nine charging wire fraud. The grand jury alleges that from at least May 2, 2020 through at least April 22, 2021 the defendant submitted false PPP and EIDL applications for Platinum Ego, Inc., Platinum Status Consulting Inc. and Good Neighbor Tax Service Inc., and helped clients apply in exchange for a portion of the proceeds. Listed wires include a $43,000 PPP disbursement to Platinum Ego and a $164,582 disbursement to Entity-2, of which $80,061 was paid to Horne. The forfeiture allegation seeks at least $1,288,886.

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Case 6:25-cr-00161-JSS-NWH Document1 Filed 06/04/25 Page 1of17 PagelD 1

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION

UNITED STATES OF AMERICA
V. CASE NO. 6:25-cr- (@i- 33S-ORM
VERLYNN JAMELAH HORNE 18 U.S.C. § 1343
18 U.S.C. § 1028A
18 U.S.C. § 1957
26 U.S.C. § 7203

INDICTMENT

The Grand Jury charges:

COUNTS ONE THROUGH NINE
(Wire Fraud)

At times material to this Indictment:
A. Defendant, Entities, and Lenders

lL. VERLYNN JAMELAH HORNE was a resident of the Middle District
of Florida.

2 Platinum Ego, Inc. (PEI) was a Florida corporation with Articles of
Incorporation filed with the State of Florida on or about April 11, 2019. In February
2020, HORNE was the CEO of PEI and PEI was located in the Middle District of
Florida.

2. Platinum Status Consulting Inc. (PSC) was a Florida corporation with

Articles of Incorporation filed with the State of Florida on or about June 9, 2020.
Case 6:25-cr-00161-JSS-NWH Document1 Filed 06/04/25 Page 2 of 17 PagelD 2

PSC had no business operations in February 2020. HORNE was the CEO of PSC
and PSC was located in the Middle District of Florida.

4, Good Neighbor Tax Service Inc. (GNTS) was a Florida corporation
with Articles of Incorporation filed with the State of Florida on or about September
4, 2015, that was reinstated with the State of Florida in July 2020. GNTS had no
business operations in February 2020. In July 2020, HORNE was the CFO of
GNTS and GNTS was located in the Middle District of Florida.

5. Persons and entities that HORNE helped to fraudulently apply for
EIDL and PPP loans in exchange for a portion of fraudulently obtained COVID-19

relief (the “COVID Fraud Clients”) included the following:

Entity-1 Orlando, Florida Person-1
Entity-2 Orlando, Florida Person-2
Entity-3 Orlando, Florida Person-3

6. Fifth Third Bank, a financial institution headquartered in Cincinnati,
Ohio, participated in the U.S. Small Business Administration’s Paycheck Protection
Program (“PPP”) as a lender and was authorized to lend funds to eligible borrowers
under the terms of the PPP.

7. WebBank, a financial institution headquartered in Salt Lake City, Utah,
participated in the PPP as a lender and was authorized to lend funds to eligible

borrowers under the terms of the PPP.
Case 6:25-cr-00161-JSS-NWH Document1 Filed 06/04/25 Page 3 of 17 PagelD 3

B. The CARES Act, the Paycheck Protection Program (PPP), and the
Economic Injury Disaster Loan (EIDL) Program

8. 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. 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.
As part of this effort, the SBA enabled and provided for loans through banks, credit
unions, and other lenders. These loans had government-backed guarantees.

9. In March 2020, the Coronavirus Aid, Relief, and Economic Security
Act, or the “CARES Act,” was enacted to provide immediate assistance to
individuals, families, and organizations affected by the COVID-19 pandemic. Two
sources of relief provided by the CARES Act were the expansion of the Economic
Injury Disaster Loan (“EIDL”) program and the establishment of the Paycheck
Protection Program (“PPP”).

10. The EIDL program was an SBA program that provided low-interest
loans to small businesses and individuals in regions affected by declared disasters.
The CARES Act authorized the SBA to provide EIDLs of up to $2 million to eligible
small businesses experiencing substantial financial disruption due to the COVID-19

pandemic.
Case 6:25-cr-00161-JSS-NWH Document1 Filed 06/04/25 Page 4 of 17 PagelD 4

11. Inorder to obtain an EIDL loan, a qualifying business or individual had
to submit an application to the SBA and provide information about its operations,
including its number of employees, gross revenues for the 12-month period preceding
the disaster, and cost of goods sold in that same period. In the case of EIDLs for
COVID-19 relief, that period was specified as the 12 months preceding January 31,
2020. In order to qualify for an EIDL for COVID-19 relief, a business must have
operated during the 12-months preceding January 31, 2020. Businesses created on or
after February 1, 2020, were not eligible for an EIDL.

12. Using the SBA online portal, EIDL applicants submitted personal and
business information in support of each EIDL application. The application process
involved filling out assorted data fields relating to the size of the affected business
entity, the ownership of said business, and other information such as the number of
employees and gross business revenues realized in the 12 months prior to
COVID-19’s impact on the national economy. The application included a paragraph
where the applicant affirmed that the information submitted was true and correct
under the penalty of perjury and applicable criminal statutes.

13. This information furnished by the applicant was then used by SBA
application evaluation systems to calculate the principal amount of money the small
business was eligible to receive in the form of an EIDL. To determine whether an

applicant was eligible for an EIDL, and to determine the amount of an EIDL to
Case 6:25-cr-00161-JSS-NWH Document1 Filed 06/04/25 Page5of17 PagelD5

award an eligible applicant, the SBA relied primarily on the self-reported information
provided by the applicant concerning the operations of the small business, including
the number of people employed by the business, gross revenues for the 12-month
period preceding the disaster, and the cost of goods sold for that same period.

14, EIDL proceeds were required to be used by the applicant to meet
ordinary and necessary financial obligations that could not be met as a direct result
of the disaster, such as payroll costs, salaries, sick leave, production costs, rent, and
mortgage payments.

15. The PPP, established by the CARES Act, was an SBA program that
provided low-interest, forgivable loans to applicants to help fund qualifying
businesses' payroll costs amidst the COVID-19 pandemic.

16. Inorder to obtain a PPP loan, a qualifying business had to submit a
PPP loan application, which had to be signed by an authorized representative of the
business. The PPP loan application required the business, through its authorized
representative, to acknowledge the program rules and make certain affirmative
certifications.

17. To apply for a PPP loan, a potential borrower would electronically
submit an SBA Form 2483 with supporting payroll documentation to a financial
institution that would administer the loan and serve as custodian of the funds. On the

SBA Form 2483, an authorized representative of the business was required to certify,
Case 6:25-cr-00161-JSS-NWH Document1 Filed 06/04/25 Page 6 of 17 PagelD 6

among other things: (i) the applicant was in operation on February 15, 2020 and had
employees for whom it paid salaries and payroll taxes or paid independent
contractors, as reported on a Form 1099-MISC; (ii) current economic uncertainty
made the loan request necessary to support the applicant’s ongoing operations; and
(iii) the PPP funds would be used to retain workers and to maintain payroll or pay
other qualifying expenses.

18. Further, when submitting the SBA Form 2483, the authorized
representative certified his understanding that, should the PPP funds be knowingly
used for unauthorized purposes, the United States could hold him legally liable,
including for charges of fraud. The applicant was also required to certify the truth
and accuracy of any information provided on the SBA Form 2483 and in all
supporting documents, including any documents submitted to verify the applicant’s
payroll expenses. Such supporting documents could include payroll processor
records, bank records, wage records, payroll tax filings with the Internal Revenue
Service, or other records sufficient to demonstrate the qualifying payroll amount.

19. Finally, the applicant was required to certify the following warning

regarding false statements and other criminal penalties:

I understand that knowingly making a false statement to obtain a guaranteed
loan from SBA is punishable under the law, including under 18 U.S.C.

§§ 1001 and 3571 by imprisonment of not more than five years and/or a fine
of up to $250,000; under 15 U.S.C. § 645 by imprisonment of not more than
two years and/or a fine of not more than $5,000; and, if submitted to a
federally insured institution, under 18 U.S.C. § 1014 by imprisonment of not
more than thirty years and/or a fine of not more than $1,000,000.
Case 6:25-cr-00161-JSS-NWH Document1 Filed 06/04/25 Page 7 of 17 PagelD 7

20. A PPP loan application was processed by a participating lender. Ifa
PPP loan application was approved, the participating lender funded the PPP loan
using its own monies, 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, was transmitted by the lender to the SBA in the
course of processing the loan.

21. Inorder to apply for an EIDL or PPP loan, an applicant had to provide
a taxpayer identification number for the business, specifically, either an employer
identification number ("EIN") (for businesses with employees), or a social security
number ("SSN") (for sole proprietorships or independent contractors).

22. The CARES Act benefits described above, including EIDL and PPP
loans, were benefits that were authorized, transported, transmitted, transferred,
disbursed, and paid in connection with a presidentially declared major disaster and
emergency.

C. The Scheme and Artifice

23. Beginning at least as early as May 2, 2020, and continuing through at

least April 22, 2021, in the Middle District of Florida and elsewhere, the defendant,

VERLYNN JAMELAH HORNE,
Case 6:25-cr-00161-JSS-NWH Document1 Filed 06/04/25 Page 8 of 17 PagelD 8

did, knowingly and with intent to.defraud, devise and intend to devise a scheme and
artifice to defraud, and for obtaining money and property by means of materially false
and fraudulent pretenses, representations, and promises.

D. Manner and Means of the Scheme

24. It was part of the scheme to defraud that HORNE would and did
submit and cause the submission of false and fraudulent applications for PPP and
EIDL loans using interstate wires on behalf of entities in HORNE’s control,
including PEI, PSC, and GNTS, and support those applications with false and
fraudulent supporting documentation in support of those loans to reflect employees
and payroll that did not actually exist.

25. It was further part of the scheme to defraud that the materially false,
fraudulent, and misleading representations by HORNE in the-PPP and EIDL loan
applications and the false and fraudulent supporting documentation would and did
cause the SBA and other lenders — including Fifth Third Bank — to approve the loans
for the PEI, PSC, and GNTS and, via interstate wires, disburse funds to bank
accounts for PEI, PSC, and GNTS controlled by HORNE.

26. It was further part of the scheme to defraud that HORNE would and
did falsely and fraudulently certify that the PPP funds acquired from the requested
PPP loans by entities owned or controlled by HORNE would be used to retain

workers, maintain payroll, or make mortgage interest payments, lease payments, and
Case 6:25-cr-00161-JSS-NWH Document1 Filed 06/04/25 Page 9 of 17 PagelD 9

utility payments, when in fact the PPP funds were used for the personal benefit of
HORNE.

27. It was further part of the scheme to defraud that HORNE would and
did cause the COVID Fraud Clients to fraudulently apply for EIDL and PPP loans,
using interstate wires, in exchange for the COVID Fraud Clients providing HORNE
portions of the fraudulently obtained proceeds.

28. It was further part of the scheme to defraud that HORNE would and
did obtain personal identifying information (PII), as well as information about
existing and newly-created businesses from the COVID Fraud Clients for the
purpose of perpetrating this fraudulent scheme.

29. It was further part of the scheme to defraud that HORNE would and
did use the information obtained from the COVID Fraud Clients to apply for and
obtain PPP and EIDL loans on behalf of the COVID Fraud Clients.

30. It was further part of the scheme to defraud that HORNE would and
did use the COVID Fraud Clients’ information in EIDL and PPP applications to
falsely report business revenues, payroll expenses, and employees on EIDL and PPP
applications, when in fact, as HORNE then and there well knew, these revenues,
payroll expenses, and employees did not exist.

31. It was further part of the scheme to defraud that the materially false,

fraudulent, and misleading representations included by HORNE in the EIDL and
Case 6:25-cr-00161-JSS-NWH Document1 Filed 06/04/25 Page 10 of 17 PagelD 10

PPP applications on behalf of the COVID Fraud Clients would and did cause the
SBA and lenders to approve and disburse PPP and EIDL loans, using interstate
wires, to bank accounts controlled by the COVID Fraud Clients.

32. It was further part of the scheme to defraud that the COVID Fraud
Clients would and did provide a portion of the loan proceeds received to HORNE as
payment for HORNE’s assistance.

33. It was further part of the part of the scheme to defraud that HORNE
would and did misrepresent, hide, and conceal, and cause to be misrepresented,
hidden, and concealed, the purpose of acts performed in furtherance of the
conspiracy.

E. Interstate Wires

34. Onor about the dates set forth below, in the Middle District of Florida,

and elsewhere, the defendant,

VERLYNN JAMELAH HORNE,
for the purpose of executing the aforesaid scheme and artifice to defraud and for
obtaining money and property by means of materially false and fraudulent pretenses,
representations and promises, did knowingly, and with intent to defraud, transmit and
cause to be transmitted by means of wire, radio, and television communication in

interstate commerce, the following writings, signs, signals, pictures, and sounds:

10
Case 6:25-cr-00161-JSS-NWH Document 1

Filed 06/04/25

Page 11 of 17 PagelD 11

Submission of PPP loan
application for PEI to Fifth Third | $43,000 disbursement to
ONE | 5/2/2020 Bank, processed using a server PEI bank account
located outside of Florida
Submission of PPP loan $96,650 disbursement to
application for Entity-1 to Entity-1 bank account,
TWO | 6/9/2020 WebBank, processed using a $34,000 of which was
server located outside of Florida | paid to HORNE via PSC
Submission of PPP loan $164,582 disbursement to
HRE application for Entity-2 to Fifth Entity-2 bank account,
qT E) 6/23/2020 Third Bank, processed using a $80,061 of which was
server located outside of Florida | paid to HORNE via PSC
Submission of PPP loan $155,207 disbursement to
application for Entity-3 to Entity-3 bank account,
FOUR | 6/27/2020 WebBank, processed using a $68,687 of which was
server located outside of Florida | paid to HORNE via PSC
Submission of EIDL loan $81,500 disbursement to
application on behalf of Person-2 | Entity-2 bank account,
FIVE | 7/4/2020 to the SBA, processed using a $32,175 of which was
server located outside of Florida | paid to HORNE via PSC
Submission of PPP loan
application for PSC to Fifth Third | $175,000 disbursement to
SIX 17/23/2020 Bank, processed using a server PSC bank account
located outside of Florida
Submission of PPP loan
application for GNTS to Fifth $162,915 disbursement to
SEVEN] 8/3/2020 Third Bank, processed using a GNTS bank account
server located outside of Florida
. $133,332 disbursement to
Sub tion fo ait to Entity-1 bank account,
EIGHT| 4/17/2021 | &PP ty $46,550 of which was
WebBank, processed using a . .
. . paid to HORNE via
server located outside of Florida GNTS

11
Case 6:25-cr-00161-JSS-NWH Document1 Filed 06/04/25 Page 12 of 17 PagelD 12

Submission of PPP loan $164,582 disbursement to

application for Entity-2 to Fifth Entity-2 bank account,
Third Bank, processed using a $60,000 of which was
server located outside of Florida | paid to HORNE via PSC

NINE | 4/22/2021

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

COUNT TEN
(Aggravated Identity Theft)

On or about July 23, 2020, in the Middle District of Florida, and elsewhere,

the defendant,
VERLYNN JAMELAH HORNE,

did knowingly transfer, possess, and use, without lawful authority, a means of
identification of another person, specifically, E.L.’s name and Social Security
number, during and in relation to a felony violation of 18 U.S.C. § 1343, as charged
in this Indictment as Count Six, knowing that such means of identification belonged
to an actual person.

In violation of 18 U.S.C. § 1028A(a)(1).

COUNT ELEVEN
(Transactional Money Laundering)

On or about September 9, 2020, in the Middle District of Florida, the
defendant,

VERLYNN JAMELAH HORNE,

12
Case 6:25-cr-00161-JSS-NWH Document1 Filed 06/04/25 Page 13 of 17 PagelD 13

did knowingly engage and attempt to engage in a monetary transaction by and
through and to a financial institution, affecting interstate and foreign commerce, in
criminally derived property of a value greater than $10,000, such property having
been derived from a specified unlawful activity, that is, the wire fraud alleged in
Counts One, Two, Three, Four, Five, Six, and Seven of this Indictment, by |
purchasing a home at 1922 Black Lake Blvd., Winter Garden, Florida.

In violation of 18 U.S.C. § 1957.

COUNTS TWELVE AND THIRTEEN
(Willful Failure to File Tax Returns)

During the calendar years described below, in the Middle District of

Florida, and elsewhere, the defendant,
VERLYNN JAMELAH HORNE,

who was a resident of Orange County, Florida, had and received gross income at
least in the amounts shown below. By reason of such gross income, she was required
by law, following the closing of the calendar years below, and on or before the
dates shown below, to make an income tax return to a designated Internal
Revenue Service Center, to a person assigned to receive returns at the local office
of the Internal Revenue Service that serves Orange County, or to any other
Internal Revenue Service office permitted by the Commissioner of Internal
Revenue, stating specifically in such return the items of her gross income and

any deductions and credits to which he was entitled. Well knowing and

13
Case 6:25-cr-00161-JSS-NWH Document1 Filed 06/04/25 Page 14 of 17 PagelD 14

believing all of the foregoing, the defendant did willfully fail, on or about the due
dates shown below, in the Middle District of Florida, and elsewhere, to make an

income tax return:

12 2020 $1,955,031.75 | 5/17/2021
13 2021 $298,212.00 | 4/18/2022

Allin violation of 26 U.S.C. § 7203.

FORFEITURE

1. The allegations contained in Counts One through Nine and Eleven are
. incorporated by reference for the purpose of alleging forfeiture pursuant to 18 U.S.C.
§ 981(a)(1)(C), 18 U.S.C. § 982(a)(1), and 28 U.S.C. § 2461(c).

2. Upon conviction of wire fraud, in 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. § 2461(c), any property, real or personal, which constitutes or is derived
from proceeds traceable to the violation.

3. Upon conviction of a violation of 18 U.S.C. § 1957, the defendant shall
forfeit to the United States, pursuant to 18 U.S.C. § 982(a)(1), any property, real or
personal, involved in such offense, or any property traceable to such property.

4, The property to be forfeited includes, but is not limited to, the

following:

14
Case 6:25-cr-00161-JSS-NWH Document1 Filed 06/04/25 Page 15 of 17 PagelD 15

a. The real property titled in the name of HORNE and Terrance L.
Horne located at 1922 Black Lake Blvd., Winter Garden, FL 34787;
and

b. An order of forfeiture in the amount of at least $1,288,886, which

represents the proceeds of the charged wire fraud scheme.

5. If any of the property described above, as a result of any act or omission
of the defendant:
a. cannot be located upon the exercise of due diligence;

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

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,

15
Case 6:25-cr-00161-JSS-NWH Document1 _ Filed 06/04/25 Page 16 of 17 PagelD 16

the United States shall be entitled to forfeiture of substitute property under the
provisions of 21 U.S.C. § 853(p), as incorporated by 18 U.S.C. § 982(b)(1) and 28

U.S.C. § 2461(c).

Foreperson

GREGORY W. KEHOE
United States Attorney

Dana E. Hill
Assistant United States Attorney

Assistant United States Attorney
Deputy Chief, Orlando Division

16
FORM OBD-34
APR 199]

Case 6:25-cr-00161-JSS-NWH Documenti_ Filed 06/04/25

Page 17 of 17 PagelD 17

UNITED STATES DISTRICT COURT
Middle District of Florida
Orlando Division

THE UNITED STATES OF AMERICA
Vs.

VERLYNN JAMELAH HORNE

INDICTMENT

Violations: 18 U.S.C. § 1343
18 U.S.C. § 1028A
18 U.S.C. § 1957
26 U.S.C. § 7203

A true bill,

Foreperson

Filed in open coprt t ay of June, 2025.

Clerk

Bail $


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