Information — United States v. Salmat Deyji, Southern District of Georgia (Document 1)
Summary
An Information in United States of America v. Salmat Deyji, No. 4:22cr-143, in the U.S. District Court for the Southern District of Georgia, Savannah Division, Document 1, filed 09/22/22 in Case 4:22-cr-00143-LGW-BWC. Count One charges Conspiracy under 18 U.S.C. § 371, alleging that beginning no later than April 2021 and continuing through at least June 2021 the defendant conspired to commit wire fraud under 18 U.S.C. § 1343 and money laundering under 18 U.S.C. § 1956. It alleges that the object was to make false PPP applications, with the defendant creating false IRS Schedule C forms and receiving kickbacks. It alleges that more than twenty PPP applications led to more than $250,000 being deposited into coconspirators' accounts, and that the defendant received a $2,000 wire transfer from Jerrod Bellamy on or about April 26, 2021.
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“Information — United States v. Salmat Deyji, Southern District of Georgia (Document 1).”
Original at ecf.gasd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-usa-v-deyji-dkt-1-0aa99f3798/
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Case 4:22-cr-00143-LGW-BWC Document 1 Filed 09/22/22 Page 1 of 5
FILED
John E. Triplett, Clerk of Court
UNITED STATES DISTRICT COURT
United States District Court
SOUTHERN DISTRICT OF GEORGIA
By jburrell at 1:07 pm, Sep 22, 2022
SAVANNAH DIVISION
UNITED STATES OF AMERICA ) INFORMATION NO. 4:22cr-143
)
v. ) 18 U.S.C. § 371
) Conspiracy
SALMAT DEYJI )
THE UNITED STATES ATTORNEY CHARGES THAT:
COUNT ONE
Conspiracy
18 U.S.C. § 371
1. Beginning no later than April 2021 and continuing through at least June
2021, within the Southern District of Georgia, Northern District of Georgia, and
Western District of Texas, and elsewhere, the defendant,
SALMAT DEYJI,
did knowingly and willfully combine, conspire, confederate, and agree with at least
one other person to:
a. devise or intend to devise a scheme or artifice to defraud, and for
obtaining money or property by means of false or fraudulent pretenses,
representations, or promises, and to transmit or cause to be transmitted by wire
communication in interstate commerce any writings, signs, signals, pictures, or
sounds for the purpose of executing such scheme or artifice, in violation of 18 U.S.C.
§ 1343, and
b. commit money laundering, that is to knowingly conduct and
attempt to conduct a financial transaction affecting interstate and foreign commerce,
Case 4:22-cr-00143-LGW-BWC Document 1 Filed 09/22/22 Page 2 of 5
which involved the proceeds of a specified unlawful activity, that is wire fraud, with
the intent to promote the carrying on of wire fraud, and that while conducting and
attempting to conduct such financial transaction knew that the property involved in
the financial transaction represented the proceeds of some form of unlawful activity,
in violation of 18 U.S.C. § 1956, the conspiracy to commit such offenses being in
violation of 18 U.S.C. § 371.
2. The object of the conspiracy was for Defendant and her coconspirators
to unjustly enrich themselves by making false PPP applications to lenders, to
unlawfully induce the lenders to disburse SBA-backed loans to coconspirators in
amounts to which they were not entitled, and who, in turn, would pay a portion of the
ill-gotten funds to Defendant as a kickback through financial transactions.
3. It was a part of the conspiracy that Defendant and coconspirators,
including Jerrod Bellamy, would perform the following:
a. Defendant and coconspirators utilized cellular devices and the
internet to create fraudulent PPP applications. Some coconspirators would provide
Bellamy with their personal identifying information (PII) to create a false loan.
Bellamy would, in turn, send the PII to Defendant, who would then use the internet
to create fraudulent PPP applications. After a PPP application was approved by a
lender, the conspirators would electronically receive, sign, and submit loan
documents to the lender.
b. To disguise the falsity of such applications, Defendant would
utilize a computer and the internet to create false IRS Schedule C forms. The
2
Case 4:22-cr-00143-LGW-BWC Document 1 Filed 09/22/22 Page 3 of 5
Schedule C forms were submitted as part of the application to dupe lenders. Such
forms inflated revenue and fabricated the existence of businesses.
c. On other occasions, Defendant would directly obtain the PII of
those seeking loans and create false and fraudulent applications on their behalf.
d. In exchange for Defendant completing a fraudulent PPP
application, applicants and coconspirators agreed to pay Defendant several thousand
dollars per PPP application. Once coconspirators received the PPP funds derived
from the false application, they would transmit a kickback to Defendant through
bank transfers to her accounts. Such transmissions were financial transactions
representing the proceeds of a specified unlawful activity, namely wire fraud. In
2021, Defendant received tens of thousands of dollars in her Navy Federal Credit
Union bank account from the fraudulent scheme.
4. On or about April 4, 2021, in the Southern District of Georgia and
elsewhere, Defendant, aided and abetted by others, for the purpose of executing the
scheme and artifice described above, and attempting to do so, caused to be
transmitted in interstate commerce, by means of wire communication, certain signs,
signals, and sounds: that is, on or about April 4, 2021, Defendant transmitted an
electronic PPP application from the Southern District of Georgia to a lender outside
the State of Georgia seeking funds, knowing that such application contained false
information.
5. In reliance on false representations made in more than twenty PPP
applications created by Defendant, lenders headquartered outside the State of
3
Case 4:22-cr-00143-LGW-BWC Document 1 Filed 09/22/22 Page 4 of 5
Georgia, by means of wire communication, deposited more than $250,000 into
coconspirators’ bank accounts resulting from this scheme.
6. On or about April 26, 2021, in the Southern District of Georgia and
elsewhere, Bellamy conducted a financial transaction affecting interstate and foreign
commerce, which involved the proceeds of wire fraud. As part of the conspiracy,
Defendant received a wire transfer of $2,000 from Bellamy on that date, knowing that
the money was obtained from the proceed of a fraudulently obtained PPP application,
and with the intent to promote the carrying on of the wire fraud conspiracy in which
they and others were engaged.
All done in violation of Title 18, United States Code, Section 371.
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Case 4:22-cr-00143-LGW-BWC Document 1 Filed 09/22/22 Page 5 of 5
David H. Estes
United States Attorney Assistant United States Attorney
*Lead Counsel
Patricia G. Rhodes
Assistant United States Attorney
Chief, Criminal Division
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