Information — United States v. Roshon Edward Thomas, No. 2:22-cr-00035-RMP (Dkt. 22, E.D. Wash.)

Summary

This Information Superseding Indictment, filed 05/16/22 in the Eastern District of Washington, charges Roshon Edward Thomas with one count of making a false, fictitious or fraudulent claim under 18 U.S.C. § 287. It alleges that on or about July 6, 2020, Thomas submitted EIDL application number 3308861858 for Thomas Tattoo Parlor, described as a "Tanning and Tattoo" business established on June 15, 2018 with 10 employees and gross receipts of $45,000. The Information says the business did not exist as of January 31, 2020, had no employees and had no receipts. On or about July 7, 2020, the SBA paid a $10,000 advance into a Bank of America account controlled by Thomas and approved additional EIDL funding of $12,500, so that $22,500 in total was disbursed.

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Case 2:22-cr-00035-RMP ECF No. 22

Vanessa R. Waldref

United States Attorney

Eastern District of Washington
Dan Fruchter

Tyler H.L. Tornabene

Assistant United States Attorneys
Post Office Box 1494

Spokane, WA 99210-1494
Telephone: (509) 353-2767

filed 05/16/22 PagelD.46 Page 1 of 4

FILED IN THE
ae U.S. DISTRICT COURT
EASTERN DISTRICT OF WASHINGTON

MAY 16 2022

SEAN F. McAVOY, CLERK

SPOKANE, WASHINGION

UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF WASHINGTON

UNITED STATES OF AMERICA,
Plaintiff,
ROSHON EDWARD THOMAS

Defendant.

The United States Attorney charges:

2:22-cr-00035-RMP

INFORMATION SUPERSEDING
INDICTMENT

Vio: 18 U.S.C. § 287
False, Fictitious, or Fraudulent
Claims

General Allegations

At all relevant times relevant to this Information Superseding Indictment:

l. The Economic Injury Disaster Loan (“EIDL”) program is an SBA

program that provides low-interest funding to small businesses, renters, and

homeowners affected by declared disasters.

Zz. On March 27, 2020, the President signed into law the Coronavirus Aid,

Relief, and Economic Security (“CARES”) Act. That statute, along with the

Coronavirus Preparedness and Response Supplemental Appropriations Act,

authorized the SBA to provide EIDLs to eligible small businesses experiencing

substantial financial disruption due to the COVID-19 pandemic.

Information Superseding Indictment - 1
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Case 2:22-cr-00035-RMP ECF No. 22 filed 05/16/22 PagelD.47 Page 2 of 4

3. In order to obtain an EIDL, a qualifying business was required to submit
an application to the SBA providing information about its operations, such as the
number of employees, gross revenues for the 12-month period preceding the disaster,
and cost of goods sold in the 12-month period preceding the disaster. In the case of
EIDLs for COVID-19 relief, the 12-month period was the year preceding January 31,
2020. The application was also required to certify that the information in the
application was true and correct to the best of the applicant’s knowledge.

4. The amount of an EIDL, if the application was approved, was determined
based, in part, on the information provided in the application about employment,
revenue, and cost of, goods sold. Any funds issued under an EIDL were determined
and issued directly by the SBA. EIDL funds were eligible to be used to payroll
expenses, sick leave, production costs, and business obligations such as debts, rent,
and mortgage payments.

5. In addition to the EIDL loan amount, EIDL applicants could also apply to
obtain cash advances of up to $10,000 within three days of application. Advances,
which were determined based on the number of employees that the applicant certified
having, did not have to be repaid.

6. Onor about July 6, 2020, Defendant ROSHON EDWARD THOMAS
submitted EIDL application number 3308861858 to SBA in the name of his purported
business, Thomas Tattoo Parlor. In the application, Defendant ROSHON EDWARD
THOMAS listed the “primary business address” of the Tattoo Parlor as his residential
address in Spokane, Washington. Defendant ROSHON EDWARD THOMAS stated
that Thomas Tattoo Parlor had been established on June 15, 2018, and was a “Tanning
and Tattoo” business consisting of 10 employees and with gross receipts of $45,000
for the twelve months ending January 31, 2020. Defendant ROSHON EDWARD
THOMAS certified under penalty of perjury and other criminal penalties that this

information was true and accurate.

Information Superseding Indictment - 2
co Oo SN DN rH FF WY NHN —

Case 2:22-cr-00035-RMP ECFNo. 22 filed 05/16/22 PagelD.48 Page 3 of 4

7. The representations made by Defendant ROSHON EDWARD THOMAS
were materially false, and Defendant ROSHON EDWARD THOMAS knew they
were false at the time they were made. In fact, Thomas Tattoo Parlor was not created
on June 15, 2018, and was not a legitimate existing business at the time of Defendant
ROSHON EDWARD THOMAS’ EIDL application. Moreover, Thomas Tattoo
Parlor did not have any employees, and did not even exist as of January 31, 2020, nor
did it have any receipts in the 12 prior months. Accordingly, Thomas Tattoo Parlor
and Defendant were:not eligible for any EIDL funding.

8. Using the above materially false information, Defendant ROSHON
EDWARD THOMAS requested an advance of up to $10,000. On or about the
following day, July 7, 2020, based on and in reliance on the materially false
information submitted by Defendant, SBA provided Defendant ROSHON EDWARD
THOMAS a $10,000 advance electronically paid into a Bank of America account
located in the Eastern District of Washington and owned and controlled by Defendant
ROSHON EDWARD THOMAS. On or about that same day, July 7, 2020, again

based on and relying on the materially false information submitted by Defendant

ROSHON EDWARD THOMAS, SBA also approved additional EIDL funding of

$12,500, such that the total amount disbursed to Thomas Tattoo Parlor was $22,500.
| COUNT 1

9. The allegations set forth in paragraph | through 8 are realleged and
incorporated herein.

10. Onor about July 6, 2020 in the Eastern District of Washington, the
Defendant, ROSHON EDWARD THOMAS, made and presented to the United States
Small Business Administration, a claim upon the United States concerning EIDL
application number p08 858 in the name of Thomas Tattoo Parlor for an EIDL
loan in the amount af $12,500 and additional advance funding of $10,000, knowing
that the claim was false and fraudulent in that Thomas Tattoo Parlor was not an

existing business eligible for EIDL funding, and knowing that the business
Information Superseding Indictment - 3
Case 2:22-cr-00035-RMP ECF No. 22

filed 05/16/22 PagelD.49 Page 4 of 4

information submitted by Defendant ROSHON EDWARD THOMAS in support of

EIDL application number 3308861858 was materially false and fraudulent; all in

violation of 18 U.S.C. § 287.

Dated this Joth day of May, 2022.

Vanessa R. Waldref

United States Attorn

Dan F Ml

Assistant

nited States Attorney

Assistant United States Attorney

Information Superseding Indictment - 4

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