Information — United States v. Jacqueline Somesso, Southern District of Georgia (Document 1)
Summary
A criminal information in United States of America v. Jacqueline Somesso, No. 4:23-cr-00029-RSB-CLR, filed March 28, 2023 as Document 1 in the U.S. District Court for the Southern District of Georgia, Savannah Division. Count One charges misprision of felony under 18 U.S.C. § 4 for concealing knowledge of a drug-trafficking conspiracy from at least April 2019 to August 2022. Count Two charges bank fraud under 18 U.S.C. § 1344, alleging that Somesso submitted fake Colony Bank statements to Community Federal Savings Bank to obtain a Paycheck Protection Program loan for Liquid Cafe. It alleges that on May 14, 2021 the Liquid Cafe, LLC account received a deposit of $570,736.87, and the forfeiture allegation seeks a money judgment in that amount.
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“Information — United States v. Jacqueline Somesso, Southern District of Georgia (Document 1).”
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Case 4:23-cr-00029-RSB-CLR Document 1 Filed 03/28/23 Page 1 of 4
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION
UNITED STATES OF AMERICA ) INFORMATION NO. 4:23CR-29
)
v. ) 18 u.s.c. § 4
) Misprison of Felony
JACQUELINE SOMESSO )
18 u.s.c. § 1344
FILED
) John E. Triplett, Clerk of Court
United States District Court
) Bank Fraud By JamesBurrell at 4:16 pm, Mar 28, 2023
THE UNITED STATES ATTORNEY CHARGES THAT:
COUNT ONE
Misprison of Felony
18 u.s.c. § 4
Beginning on a date at least as early as April 2019, up to August 2022, the
precise dates being unknown, in Chatham County, within the Southern District of
Georgia, and elsewhere, the Defendant,
JACQUELINE SOMESSO,
had knowledge of the actual commission of a felony cognizable by a court of the United
States, to wit, Conspiracy to Possess with Intent to Distribute Controlled Substances,
did conceal in furtherance of the drug-trafficking conspiracy and having knowledge
of the illegal possession of controlled substances and firearms by her boyfriend,
Dennis Kinchen, at her residence at 325 Westbrook Lane, Pooler, Georgia, and did
not as soon as possible make known the same to some judge or other person in civil
or military authority under the United States.
All in violation of Title 18, United States Code, Section 4.
Case 4:23-cr-00029-RSB-CLR Document 1 Filed 03/28/23 Page 2 of 4
COUNT TWO
Bank Fraud
18 U.S.C. § 1344
On or about May 14, 2021, in the Southern District of Georgia, and elsewhere,
the Defendant,
JACQUELINE SOMESSO,
did knowingly execute and attempt to execute a scheme and artifice to defraud
Community Federal Savings Bank, and to obtain money, funds and property owned
by and under the custody and control of Community Federal Savings Bank, by means
of false and fraudulent pretenses, representations, and promises, which affected a
financial institution, and schemes and artifice being in substance as follows:
THE SCHEME AND ARTIFICE
It was a part of the scheme and artifice that the defendant submitted fake bank
statements to Community Federal Saving Bank, which is a federally insured
financial institution with locations throughout the Southern District of Georgia.
The false documents were submitted for the purpose of obtaining a Paycheck
Protection Program ("PPP') loan for Liquid Cafe, which according to the Georgia
Corporations Division of the Georgia Secretary of State, as of July 23, 2022, list the
defendant as the Registered Agent.
As a part of the scheme and artifice, the defendant made or caused to be made,
fake bank statements for the purpose of falsifying her payroll expenses.
The fake statements purported to be from Colony Bank and ranged from
February 2021 to April 2021. However, the statements were later determined to be
fake, and were allegedly created and submitted to Community Federal Savings Bank
in an application for PPP funds.
Case 4:23-cr-00029-RSB-CLR Document 1 Filed 03/28/23 Page 3 of 4
On May 14, 2021, via a wire transfer from Community Federal Savings Bank,
the defendant's Colony Bank account number 231151752, held in the name of Liquid
Cafe, LLC's, received a deposit of $570,736.87.
All in violation of Title 18, United States Code, Section 1344.
Case 4:23-cr-00029-RSB-CLR Document 1 Filed 03/28/23 Page 4 of 4
FORFEITURE ALLEGATIONS
The allegations contained in Count Two of this Information are hereby re
alleged and incorporated by reference for the purpose of alleging forfeiture pursuant
to Title 18, United States Code, Sections 982(a)(2)(A).
Upon conviction of Count Two set forth in this Information, Defendant,
JACQUELINE SOMESSO,
shall forfeit to the United States pursuant to Title 18, United States Code, Section
982(a)(2)(A), any property constituting, or derived from, proceeds the person obtained
directly or indirectly, as the result of such violation, including but not limited to: a
Money Judgment in the amount of $570,736.87 in U.S. Currency.
If any of the property described above, as a result of any act or commission of
the defendant:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction of the court;
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be divided
without difficulty,
the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title 28,
Marcela C. Mateo
Assistant United States Attorney
*Lead Counsel
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