Information — United States v. Jameela Gross, District of Massachusetts (Document 19)

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A criminal information in United States of America v. Jameela Gross, Criminal No. 1:24-cr-10196-WGY, filed July 8, 2024 as Document 19 in the U.S. District Court for the District of Massachusetts. Count One charges wire fraud under 18 U.S.C. § 1343, tied to a PPP loan application submitted to Prestamos CDFI, LLC on or about April 14, 2021. The information alleges that the application claimed a photography company with 2020 gross income of $90,000 and included a falsified Schedule C, and that $18,750 was disbursed on or about May 11, 2021. It alleges that $17,287 was withdrawn in cash the next day. A forfeiture allegation under 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c) seeks a money judgment of $18,750; the signature block names Acting United States Attorney Joshua S. Levy.

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Case 1:24-cr-10196-WGY Document 19 Filed 07/08/24 Page 1 of 7

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

Criminal No. 24cr10196
UNITED STATES OF AMERICA

Violation:

Count One: Wire Fraud

JAMEELA GROSS, (18 U.S.C. § 1343)

Defendant Forfeiture Allegation:
(18 U.S.C. § 981(a)(1)(C) and

28 U.S.C. § 2461(c))

INFORMATION

At all times relevant to this Information:

General Allegations

1. Defendant JAMEELA GROSS (“GROSS”) was a resident of Massachusetts.

oe Prestamos CDFI, LLC (“Prestamos’) was a financial institution based in Arizona
that facilitated small-business lending.

3. South Shore Bank was a financial institution based in Massachusetts.

4. The United States Small Business Administration (“SBA”) was an agency of the
executive branch of the United States government. 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, guaranteed by the government, through banks, credit

unions, and other lenders.
Case 1:24-cr-10196-WGY Document 19 Filed 07/08/24 Page 2 of 7

The CARES Act and the Paycheck Protection Program

5. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was a
federal law enacted in March 2020 to provide emergency financial assistance to Americans
suffering economic harm as a result of the COVID-19 pandemic. Among other things, the
CARES Act provided funding for forgivable loans to small businesses for job retention and
certain other expenses through the Paycheck Protection Program (“PPP”).

6. PPP loans were required to be used by the business on certain permissible
expense, namely, payroll costs, interest on mortgages, rent, and utilities. The PPP allowed the
interest and principal on the PPP loan to be entirely forgiven if the business spent the loan
proceeds on these expenses within a designated period of time and used at least a minimum
amount of the PPP loan proceeds toward payroll expenses.

4 To obtain a PPP loan, a qualifying business was required to submit a PPP loan
application 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. One
such certification required the applicant to affirm that “[t]he [PPP loan] funds w[ould] be used to
retain workers and maintain payroll; or make payments for mortgage interest, rent, utilities,
covered operations expenditures, covered property damage costs, covered supplier costs, and
covered worker protection expenditures as specified under the [PPP] Rules.” The applicant
(through its authorized representative) was also required to acknowledge that “I understand that
if the funds are used for unauthorized purposes, the federal government may hold me legally
liable, such as for charges of fraud.” In the PPP loan application, the applicant was also required

to state, among other things, its (a) average monthly payroll expenses and (b) number of
Case 1:24-cr-10196-WGY Document 19 Filed 07/08/24 Page 3 of 7

employees. Lenders used these figures to calculate the amount of money the small business was
eligible to receive under the PPP. The applicant was also required to provide documentation
showing its payroll expenses.

8. Participating financial institutions, including Prestamos, received and processed
business’s PPP loan applications. If a PPP loan application was approved, the participating
financial institution would fund the PPP loan using its own monies, which were guaranteed by
the SBA.

Scheme to Defraud

9. Between April and May 2021, in the District of Massachusetts, and elsewhere,
GROSS devised a scheme to defraud and fraudulently obtain pandemic relief funds by filing a
false and fraudulent PPP loan application for her purported photography company (the
“company”’), which resulted in GROSS receiving $18,750. GROSS thereafter misused the loan
proceeds in ways that were not connected to the company’s payroll, utilities, rent, or mortgage
payments.

10. Onor about April 14, 2021, GROSS electronically submitted a PPP loan
application to Prestamos that contained false statements and falsified tax documents. GROSS’
PPP loan application claimed that she was the sole owner and employee of a company
established in 2020 located at an address in Dorchester Center, Massachusetts, and that the
company’s gross income from 2020 was $90,000. As part of her application, GROSS submitted
a falsified Schedule C for the 2020 tax year that bore GROSS’ name and Social Security number.
The Schedule C claimed that GROSS’ principal business was “Photography Studios, Portrait”
and had a 2020 gross income of $90,000, expenses including advertising in the amount of

$25,000 and utilities in the amount of $25,000, resulting in a net profit of $40,000.
Case 1:24-cr-10196-WGY Document 19 Filed 07/08/24 Page 4 of 7

11. In fact, none of the IRS records filed under GROSS’ Social Security number for
tax year 2020 identify any photography business; the Schedule C that GROSS submitted with her
PPP application was not part of her 2020 tax return; and the profits from her purported
photography business that GROSS listed in her PPP application were not mentioned in her 2020
Individual Tax Return Form 1040.

12. Inreliance on GROSS’ PPP application, Prestamos approved the loan, and on or
about May 11, 2021, the loan amount of $18,750 was disbursed into GROSS’ South Shore Bank
account.

13. On or about May 12, 2021 (the day after the $18,750 PPP loan was disbursed into
GROSS’ South Shore Bank account), GROSS withdrew $17,287 in cash - nearly all of the PPP
loan proceeds - from a South Shore Bank branch location in Quincy, Massachusetts. Later that
same day, GROSS withdrew an additional $500 from her South Shore Bank account from two
different ATMs in Avon, Massachusetts and Brockton, Massachusetts. In addition, GROSS
transferred $600 to two CashApp users. These uses of the PPP loan proceeds were not business-
related.

14. Onoor about February 17, 2021 (approximately two months before GROSS filed
her PPP application), law enforcement executed a search warrant at the Dorchester Center
address listed in GROSS’ PPP application as the company’s business address. During the

search, no evidence of a photography studio was observed.
Case 1:24-cr-10196-WGY Document 19 Filed 07/08/24 Page 5 of 7

COUNT ONE
Wire Fraud
(18 U.S.C. § 1343)

The Acting United States Attorney charges:

15.

The Acting United States Attorney re-alleges and incorporates by reference

paragraphs 1-14 of this Information.

16.

defendant,

Between April and May 2021, in the District of Massachusetts, and elsewhere, the

JAMEELA GROSS,

having devised and intending 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, did transmit and cause to be transmitted by means of wire communications in

interstate and foreign commerce, writings, signs, signals, pictures, and sounds for the purpose of

executing the scheme to defraud, as set forth below:

Count

Approximate Date

Description

1

April 14, 2021

Prestamos PPP Application electronically submitted in
Massachusetts and routed interstate through Prestamos’
servers located outside of Massachusetts

All in violation of Title 18, United State Code, Section 1343.
Case 1:24-cr-10196-WGY Document 19 Filed 07/08/24 Page 6 of 7

FORFEITURE ALLEGATION
(18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c))

The Acting United States Attorney further alleges:

17. Upon conviction of the offense in violation of Title 18, United States Code,
Section 1343, set forth in Count One, the defendant,

JAMEELA GROSS,
shall forfeit to the United States, pursuant to Title 18, United States Code, Section 981(a)(1)(C),
and Title 28, United States Code, Section 2461(c), any property, real or personal, which
constitutes or is derived from proceeds traceable to the offense. The property to be forfeited
includes, but is not limited to, the following asset:
a. $18,750, to be entered in the form of a forfeiture money judgment.

18. If any of the property described in Paragraph 17, above, as being forfeitable
pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United States Code,
Section 2461(c), 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;

it is the intention of the United States, pursuant to Title 28, United States Code, Section 2461(c),
incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any other

property of the defendant up to the value of the property described in Paragraph 17 above.
Case 1:24-cr-10196-WGY Document 19 Filed 07/08/24 Page 7 of 7

All pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United

States Code, Section 2461(c).

Date: July 8, 2024

JOSHUA S. LEVY
Acting United States Attorney

Lucy Sun
Assistant U.S. Attorneys


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