Information — United States v. Keandra Carter, Southern District of Florida (Document 1)

Summary

An information in United States v. Keandra Carter, No. 1:23-cr-20475, in the U.S. District Court for the Southern District of Florida, entered on the docket December 12, 2023 as Document 1. Count 1 charges wire fraud under 18 U.S.C. § 1343, and the information seeks forfeiture under 18 U.S.C. § 982(a)(2). It states that Carter, a Public Service Aide with the City of Miami Police Department, submitted a Paycheck Protection Program application through a Financial Technology Company claiming gross income of $1,100,000 in 2019 for a sole proprietorship. The information charges that Carter obtained approximately $20,833 in PPP loan proceeds from the Lender. The signature block names United States Attorney Markenzy Lapointe and Assistant United States Attorney Edward N. Stamm; a penalty sheet and an AO 455 waiver of indictment form follow.

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“Information — United States v. Keandra Carter, Southern District of Florida (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-no-1-23-cr-20475-dkt-1-s-d-fla-f001b85539/, SHA-256 17166c7f8443fae34de5568d769f5d1c762e43ecf2e716e4f37e3b79975e981a.

Full text

Case 1:23-cr-20475-KMW Document 1 Entered on FLSD Docket 12/12/2023 Page 1 of 9

UNITED STATES DISTRICT COURT

23-20475-CR-WILLIAMS/GOODMAN
SOUTHERN DISTRICT OF FLORIDA

CASE NO. - - - - - - - - - - -
18 u.s.c. § 1343 MP
18 U.S.C. § 982(a)(2)
Dec 12, 2023

UNITED STATES OF AMERICA MIAMI

vs.

KEANDRA CARTER,

Defendant.
- - - - - - - - - - - - - -I

INFORMATION

The United States Attorney charges that:

GENERAL ALLEGATIONS

At all times material to this Information:

1. The United States Small Business Administration ("SBA") was an agency of the

executive branch of the Government of the United States. 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 as!iisting in the economic recovery of communities after disasters.

2. The Coronavirus Aid, Relief, and Economic Security ("CARES") Act was a federal

law enacted in or around March 2020 and designed to provide emergency financial assistance to

the millions of Americans who were suffering the economic effects caused by the COVID-19

pandemic. One source of relief provided by the CARES Act was the authorization of forgivable
Case 1:23-cr-20475-KMW Document 1 Entered on FLSD Docket 12/12/2023 Page 2 of 9

loans to small businesses for job retention, including the payment of payroll and certain other

permissible expenses, through a program referred to as the Paycheck Protection Program ("PPP").

3. In order to obtain a PPP loan , a qualifying business, including a so le proprietorship,

submitted a PPP loan application, which was 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 in order to be eligible

to obtain the PPP loan. In the PPP Borrower Application Form for Schedu le C Filers using Gross

Income (SBA Form 2483-C), the small business (through its authorized representative) was

required to provide, among other things, its: (a) total amount of gross income reported on its

Schedule C for either 2019 or 2020; and (b) number of emp loyees. The information on the

application and the supporting documentation submitted therewith were used to calculate the

amount of money the applicant was entitled to receive under the PPP.

4. A PPP loan application was processed by a participating lender. If a PPP loan

application was approved, the participating lender funded the PPP loan using its own monies.

While it was the participating lender that issued the PPP loan, the loan was 100% guaranteed by

the SBA. Data from the application , including information abo ut the borrower, the total amount

of the loan, and the li sted number of emp loyees, was transmitted by the lender to the SBA in the

course of processing the loan .

5. Defendant KEANDRA CARTER was a resident of Miami-Dade County, Florida,

who was employed by the City of Miami Police Department as a Public Service Aide.

6. The Financial Technology Company operated an online platform that received PPP

loan applications from throughout the United States. The Financial Technology Company was not

a PPP lender, but rather was a business that received and processed PPP applications for multiple

2
Case 1:23-cr-20475-KMW Document 1 Entered on FLSD Docket 12/12/2023 Page 3 of 9

SBA-approved PPP lenders. The Financial Technology Company then would make qualified PPP

applications available to one of the lenders that retained its services for the lender's review, final

approval , and funding of the PPP loan.

7. The Lender was an SBA-approved lender for PPP loans, and processed PPP loan

applications from applicants located throughout the United States. The Lender contracted with the

Financial Technology Company to receive PPP applications for funding by the Lender. The

Lender's servers were located outside the state of Florida.

8. The Bank was a bank that did business throughout the United States, including

maintaining branches in the Southern District of Florida.

COUNT 1
Wire Fraud
(18 u.s.c. § 1343)

I. Paragraphs 1 through 8 of the General Allegations section of this Information are

re-alleged and incorporated by reference as through fully set forth herein.

2. From in or around April 2021, and continuing through in or around May 2021 , in

Miami-Dade County, in the Southern District of Florida, and elsewhere, the defendant,

KEANDRA CERTER,

did knowingly, and with the intent to defraud, devise, and intend 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, knowing that the pretenses, representations, and

promises were false and fraudulent when made, and, for the purpose of executing the scheme and

artifice, did knowingly transmit and cause to be tran smitted , by means of wire communication in

interstate and foreign commerce, certain writings, signs, signals, pictures and sounds, in violation

of Title 18, United States Code, Section 1343 .

3
Case 1:23-cr-20475-KMW Document 1 Entered on FLSD Docket 12/12/2023 Page 4 of 9

PURPOSE OF THE SCHEME AND ARTIFICE

3. The purpose of the scheme and artifice was for KEANDRA CARTER to

unlawfully enrich herself by submitting a fa lse and fraudulent PPP application to fraudulently

obtain loan proceeds for her own use and benefit.

THE SCHEME AND ARTIFACE

The manner and means by which KEANDRA CARTER sought to accomplish the purpose

of the scheme and artifice included, among others, the fol lowing:

4. KEANDRA CARTER submitted to the Financial Technology Company, via

interstate wire communications, a fa lse and fraudulent PPP loan application (SBA Form 2483-C)

claiming to be a sole proprietor operating a business under the tradename "Keandra Caiier." That

PPP loan app lication falsely and fraudulently represented the business' 2019 gross income, and as

part of the application process, CARTER submitted a false and fraudulent IRS Form 1040,

Schedule C, for tax year 2019. On both the Form 2483-C and the Schedule C, CARTER falsely

represented that the sole proprietorship had gross income of $1,100,000 in 2019. The Financial

Technology Company then passed this application package to the Lender for final review and

funding.

5. As a result of this false and fraudulent app lication, KEANDRA CARTER obtained

approximately $20,833 in PPP loan proceeds from the Lender that were electronically deposited

by the Lender into CARTER's account at the Bank. This electronic deposit was made via

interstate wire communications.

USE OF WIRES

6. On or about the date specified below, in the Southern District of Florida, and

elsewhere, KEANDRA CARTER, for the purpose of executing and in furtherance of the aforesaid

4
Case 1:23-cr-20475-KMW Document 1 Entered on FLSD Docket 12/12/2023 Page 5 of 9

scheme and artifice to defraud, and to obtain money and property by means of materially false and

fraudulent pretenses, representations, and promises, knowing that the pretenses, representations,

and promises were false and fraudulent when made, did knowingly transmit and cause to be

transmitted in interstate and foreign commerce, by means of wire communication, certain writings,

signs, signals, pictures, and sounds, as described below:

COUNT APPROXIMATE DESCRIPTION OF WIRE
DATE
l April 4, 202 l Electronic submission of a PPP loan application
containing false information about the 2019
gross income of the sole proprietorship using the
tradename Keandra Carter, including a fal se
2019 IRS Form 1040 Schedule C, causing a wire
transmission from the Southern District of
Florida to outside of the State of Florida

In violation of Title 18, United States Code, Sections 1343 and 2.

(remainder of page intentionally left blank)

5
Case 1:23-cr-20475-KMW Document 1 Entered on FLSD Docket 12/12/2023 Page 6 of 9

FORFEITURE ALLEGATIONS

1. The allegations of this Information are hereby re-alleged and by this reference full y

incorporated herein for the purpose of alleging forfeiture to the United States of America of certain

property in which the defendant, KEANDRA CARTER, has an interest.

2. Upon conviction of a violation of Title 18, United States Code, Section 1343 , as

alleged in this Information , the defendant, KEANDRA CARTER, shall forfeit to the United

States any property constituting, or derived from , proceeds obtained, directly or indirectly, as a

result of such violation, pursuant to Title 18, United States Code, Section 982(a)(2)(A).

All pursuant to Title 18, United States Code, Section 982(a)(2)(A), and the procedures set

forth in Title 21 , United States Code, Section 853, as incorporated by Title 18, United States Code,

Section
I
982(b )(1 ).

~MARKENZY LAPOINTE
' -~ ,
UNITED STA TES ATTORNEY

EDWARDN.STAMM
ASSISTANT UNITED STATES ATTORNEY

6
Case 1:23-cr-20475-KMW Document 1 Entered on FLSD Docket 12/12/2023 Page 7 of 9
UNITED ST ATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

UNITED STATES OF AMERICA CASE NO.: _ _ _ _ _ _ _ _ _ _ _ _ _ __

v.
CERTIFICATE OF TRIAL ATTORNEY
Keandra Carter,
-------D-e~fe_n_d~a_n_t._ _ __ I Superseding Case Information:
NewDefendant(s) (Yes or No)
---
Court Division (select one) Number of New Defendants
~ Miami □ Key West □ FTP Total number of counts
□ FTL □ WPB

l do hereby certify that:
I. I have carefully considered the allegations of the indictment, the number of defendants, the number of probable
witnesses and the legal complexities of the Indictment/Information attached hereto.
2. I am aware that the information supplied on this statement will be relied upon by the Judges of this Court in setting
their calendars and scheduling criminal trials under the mandate of the Speedy Trial Act, Title 28 U.S.C. §3 161 .

3. Interpreter: (Yes or No) No
---
List language and/or dialect:
------
4. This case will take _o_ days for the parties to try.

5. Please check appropriate category and type of offense li sted below:
(Check only one) (Check on ly one)
l ~ 0 to 5 days D Petty
11 D 6 to 10 days D Minor
III D 11 to 20 days D Misdemeanor
IV D 21 to 60 days [8'.] Felony
V D 61 days and over

6. Has this case been previously filed in this District Court? (Yes or No) _N_o_ _
If yes, Judge___________ Case No. _ _ _ _ _ _ _ _ _ _ _ _ _ __
7. Has a complaint been filed in this matter? (Yes or No) No
---
lf yes, Magistrate Case No. _ _ _ _ _ _ _ _ _ _ __
8. Does this case relate to a previously filed matter in this District Court? (Yes or No) _N_o_ _
If yes, Judge___________ Case No. _ _ _ _ _ _ _ _ _ _ _ _ _ __
9. Defendant(s) in federal custody as of _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
10. Defendant(s) in state custody as of _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
11 . Rule 20 from the _ _ _ _ District of - - - - - - -
12. Is this a potential death penalty case? (Yes or No) _N_o_ _
13 . Does this case origi nate from a matter pending in the Northern Region of the U.S. Attorney 's Office
prior to August 8, 2014 (Mag. Judge Shaniek Maynard? (Yes or No) No
---
14. Does this case originate from a matter pending in the Central Region of the U.S . Attorney 's Office
prior to October 3, 2019 (Mag. Judge Jared Strauss? (Yes or No) No
---
15. Did this matter involve the participation of or consultation with now Magistrate Judge Eduardo I. Sanchez
during his tenure at the U.S . Attorney's Office, which concluded on January 22, 2023? _N_o_ _

By:
Edward N. Stamm
Assistant United States Attorney
FL Bar No. 373826
Case 1:23-cr-20475-KMW Document 1 Entered on FLSD Docket 12/12/2023 Page 8 of 9

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

PENALTY SHEET

Defendant's Name: =K=-=e=a-'-"n-=d=-=ra"-C==ar=-=t-=-er'------------------------

Case No: - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

Count#: 1

Wire Fraud

18 u.s.c. § 1343
* Max. Term of Imprisonment: 20 years
* Mandatory Min. Term oflmprisonment (if applicable): N/A
*Max.Supervised Release: 5 years
* Max. Fine: $250,000
* Special Assessment: $100

*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 1:23-cr-20475-KMW Document 1 Entered on FLSD Docket 12/12/2023 Page 9 of 9

AO 455 (Rev . 01/09) Waiver of an Indictment

UNITED STATES DISTRICT COURT
for the
Southern District of Florida

United States of America )
V. ) Case No. 23-20475-CR-WILLIAMS/GOODMAN
Keandra Carter, )
)
Defendant )

WAIVER OF AN INDICTMENT

T understand that I have been accused of one or more offenses punishable by impri sonment for more than one
year. I was advised in open court ofmy rights and the nature of the proposed charges against me.

After receiving thi s advice, I waive my right to prosecution by indictment and consent to prosecution by
information.

Date:
Defendant 's signature

Signature of defendant 's allorney

A. Randall Haas, Esq.
Printed name of defendant 's al/orney

Judge 's signature

Judge 's printed name and title

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