Information — United States v. Denisha Clarice Morrison, Northern District of Iowa (Document 2)

Summary

An information in United States v. Denisha Clarice Morrison, No. 6:25-cr-02001, in the U.S. District Court for the Northern District of Iowa, Eastern (Waterloo) Division, filed January 8, 2025 as Document 2. Count 1 charges wire fraud under 18 U.S.C. § 1343. The information alleges that a PPP application for a $20,000 loan was filed with Lender-1 for Morrison, supported by a fictitious 2019 Schedule C stating $96,000 received from a purported cleaning business. It states that Morrison received $20,000 in PPP loan funds by interstate wire transfer on or about June 8, 2021. The 5-page information is signed by Assistant United States Attorney Timothy L. Vavricek for United States Attorney Timothy T. Duax.

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                   IN THE UNITED STATES DISTRICT COURT
                    FOR THE NORTHERN DISTRICT OF IOWA
                       EASTERN (WATERLOO) DIVISION

 UNITED STATES OF AMERICA,                )     No. 25-CR-2001
                                          )
                                          )
              Plaintiff,                        INFORMATION
                                          )
                                          )
       vs.
                                          )     Count 1
                                          )       18 U.S.C. § 1343:
 DENISHA CLARICE MORRISON,
                                          )       Wire Fraud
                                          )
              Defendant.
                                          )

The United States Attorney charges:

                                      Count 1
                                    Wire Fraud

                                    Introduction

                       COVID-19 and the National Emergency

      1.     According to the United States Centers for Disease Control and

Prevention (“CDC”), Coronavirus Disease 2019 (“COVID-19”) is a respiratory illness

that can spread from person to person. The virus that causes COVID-19 is a novel

coronavirus that was first identified during an investigation into a 2019 outbreak in

Wuhan, China. COVID-19 can attack human lungs and kill infected persons,

especially those who have certain risk factors identified by the CDC.

      2.     On March 13, 2020, President Donald J. Trump issued a Proclamation

on Declaring a National Emergency Concerning the Novel Coronavirus Disease

(COVID-19) Outbreak (“the Emergency Proclamation”). The Emergency

Proclamation noted that “on March 11, 2020, the World Health Organization




    Case 6:25-cr-02001-CJW-MAR        Document 2    Filed 01/08/25      Page 1 of 5
announced that the COVID-19 outbreak can be characterized as a pandemic, as the

rates of infection continue to rise in many locations around the world and across the

United States.” Further, “[t]he spread of COVID-19 within our Nation’s

communities threatens to strain our Nation’s healthcare systems.”

                          The Paycheck Protection Program

      3.     The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act is

a federal law enacted in late March 2020 that provided emergency financial

assistance to the millions of Americans who were suffering the economic effects of

the COVID-19 pandemic. One form of such financial assistance was the

authorization of 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”). Later, in April 2020, Congress authorized

an additional $300 billion in PPP funding and, in March 2021, extended the PPP

application deadline through May 31, 2021.

      4.     In order to obtain a PPP loan, a business submits a PPP loan

application (SBA Form 2483), which must be signed by an authorized

representative of the business. The loan application requires the business, through

its authorized representative, to acknowledge the PPP program rules and to make

certain affirmative certifications regarding its eligibility. In the application, the

small business’s authorized representative must also provide, among other things,

the business’s average monthly payroll expenses and number of employees. These

figures are used to calculate the business’s eligibility and the amount of money it




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    Case 6:25-cr-02001-CJW-MAR         Document 2      Filed 01/08/25    Page 2 of 5
may receive under the PPP. In addition, businesses applying for a PPP loan must

provide documentation showing their payroll expenses.

      5.     A PPP loan application must be processed by a participating lending

financial institution. If a PPP loan application is approved by the participating

financial institution, that institution funds the PPP loan using its own monies,

which are 100% guaranteed by the Small Business Administration (“SBA”).

Participating financial institutions require that the information provided in PPP

loan applications be truthful, including supporting tax forms and information about

the applicant business’s employees and payroll expenses, which is material to the

financial institution’s approval and the terms of the PPP loans.

      6.     Information from the application, including information about the

borrower, the total amount of the loan, and the listed number of employees, is

transmitted by the lending financial institution to the SBA in the course of

processing the loan.

      7.     PPP loan proceeds must be used by the business for certain

permissible expenses – payroll costs, interest on mortgages, rent, and utilities. The

SBA allows the principal and interest on the PPP loan to be entirely forgiven if the

business spends the loan proceeds on these items within a designated period of

time, usually within 24 weeks of receiving the proceeds, and if the business also

uses at least 60% of the PPP loan proceeds for payroll expenses.




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    Case 6:25-cr-02001-CJW-MAR        Document 2     Filed 01/08/25   Page 3 of 5
                               The Scheme to Defraud

      8.     From no later than about May 2021, and continuing through at least

June 2021, in the Northern District of Iowa and elsewhere, defendant DENISHA

CLARICE MORRISON did voluntarily and intentionally (1) participate in a scheme

and artifice to defraud with knowledge of its fraudulent nature and (2) obtain

money and property by means of false and fraudulent pretenses, representations,

and promises (collectively, “the scheme to defraud”).

                     Manner and Means of the Scheme to Defraud

      9.     It was part of the scheme to defraud that a PPP application was filed

electronically with a participating lender outside of the State of Iowa, Lender-1, in

order to obtain a PPP loan for defendant DENISHA CLARICE MORRISON in the

amount of $20,000. It was also part of the scheme to defraud that false, fraudulent,

and fictitious documents and statements were submitted to Lender-1 in support of

defendant’s PPP loan. For example, Lender-1 received a fictitious 2019 Schedule C,

Form 1040, Profit or Loss From Business, which contained false and fraudulent

statements about defendant’s gross receipts/sales and net profit from a purported

cleaning business.

                         Execution of the Scheme to Defraud

      Count 1:       On or about June 8, 2021, for the purpose of executing the

scheme to defraud described above, in the Northern District of Iowa, defendant

received $20,000 in PPP loan funds by means of an interstate wire transfer to an

account ending in 8852 at CU-1, after a false and fraudulent Schedule C was



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    Case 6:25-cr-02001-CJW-MAR         Document 2       Filed 01/08/25   Page 4 of 5
submitted in defendant’s name that stated that defendant DENISHA CLARICE

MORRISON had received $96,000 during calendar year 2019 from a purported

cleaning business.

      10.   This was in violation of Title 18, United States Code, Section 1343.



TIMOTHY T. DUAX
United States Attorney

By: /s/ Timothy L. Vavricek

TIMOTHY L. VAVRICEK
Assistant United States Attorney




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