Rodericque Jarmaine Thompson — Criminal Indictment

Summary

A criminal indictment in the U.S. District Court for the Northern District of Georgia, Case 1:21-cr-00011, filed 01/12/21, against Rodericque Jarmaine Thompson, listed with several aliases, along with Micah K. Baisden, Travis C. Crosby, Keith A. Maloney, Jr., Tabronx W. Smith and Thomas D. Wilson. Its background sets out the Paycheck Protection Program, including up to $310 billion in additional funding authorized in April 2020 and the rules on use and forgiveness of loan proceeds. Counts One, Two and Three charge conspiracy to commit bank fraud under 18 U.S.C. § 1349, pairing Thompson with Baisden, Crosby and Maloney respectively, from about March 2020 through about June 2020.

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Case 1:21-cr-00011-UNA Document1i F

IN THE UNITED STATES DIS
FOR THE NORTHERN DISTRIC
ATLANTA DIVISI

UNITED STATES OF AMERICA

RODERICQUE JARMAINE

THOMPSON A/K/A
RODRIQUEZ THOMPSON,
RODRICQUE THOMAS,
JAMMIGE TROY THOMASON,
JAMMIE TROY THOMPSON,
JUNIOR THOMPSON

MICAH K. BAISDEN

TRAVIS C. CROSBY

KEITH A. MALONEY, JR.

TABRONX W. SMITH

THOMAS D. WILSON

THE GRAND JURY CHARGES THAT:

Background

At times relevant to this Indictment:

Crin

No.

led 01/12/21 Page1lo

FILED IN OPEN COURT
U.S.DB.C. - Atlanta

TRICTCOURT JAN 42 2024

CT OF GEORGIA eneclerk
ON By: SO ED Clerk

ninal Indictment

1 21-CR-gil

The Defendants and Related Entities

1. RODERICQUE JARMAINE THOMPSON A/K/A
RODRIQUEZ THOMPSON, RODRICQUE THOMAS, JAMMIGE TROY
THOMASON, JAMMIE TROY THOMPSON, JUNIOR THOMPSON

(‘THOMPSON’) was an individual residing in the Northern District of

Georgia.
Case 1:21-cr-00011-UNA Document1i F

2.
in the Northern District of Georgia who claimed
Sports Academy, LLC (“PowerHouse”), a Georg

3. TRAVIS C. CROSBY (“CROSBY’
the District of South Carolina who claimed sole ¢
Services, LLC (“Faithful”), a South Carolina Lim:

4. KEITH A. MALONEY, JR. (“MAL
residing in the District of South Carolina who cle
Transport, LLC (“KMJ”), a South Carolina Limit

5. TABRONX W. SMITH (“SMITH”) v
Northern District of Georgia who claimed sole o
LLC (“Market Yourself”), a Georgia Limited Lial

6. THOMAS D. WILSON (“WILSON”

led 01/12/21 Page 2 of 23

MICAH K. BAISDEN (“BAISDEN”) was an individual residing

sole ownership of PowerHouse
ia Limited Liability Company.

) was an individual residing in
»wnership of Faithful Transport
ited Liability Company.
.ONEY”) was an individual
aimed sole ownership of KMJ
ed Liability Company.

vas an individual residing in the
wnership of Market Yourself,
bility Company.

was an individual residing in

the Northern District of Georgia who claimed sole ownership of Rare Breed

Nation, LLC (“Rare Breed”), a Georgia Limited Liability Company.

Additional Co-Consp
7. Antonio D. Hosey (“Hosey”) was a1

Northern District of Georgia.

irators

1 individual residing in the

The Small Business Administration

8. The United States Small Business A

dministration (“SBA”) was an

executive branch agency of the United States government that provided support

to entrepreneurs and small businesses. The mis

and strengthen the nation’s economy by enablin

2

sion of the SBA was to maintain

g the establishment and viability
Case 1:21-cr-00011-UNA Document1 Filed 01/12/21 Page 3 of 23

of small businesses and by assisting in the economic recovery of communities
after disasters.
9. As part of this effort, the SBA enabled and provided for loans
through banks, credit unions, and other lenders. These loans had government-
backed guarantees.
The Paycheck Protection Program
10. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act
was a federal law enacted in or about March 2020 and was designed to provide

emergency financial assistance to the millions of Americans who are suffering

the economic effects caused by the COVID-19 pandemic.
11. One source of relief that the CARES Act provided for was the

authorization of up to $349 billion in forgivable loans to small businesses for

payroll, mortgage interest, rent/lease, and utilities, through a program referred
to as the Paycheck Protection Program (“PPP”). In April 2020, Congress
authorized up to $310 billion in additional PPP funding.

12. The PPP allowed qualifying small businesses and other
organizations to receive PPP loans. Businesses must use PPP loan proceeds for
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 expense items within a designated period of time and

used a certain percentage of the PPP loan proceeds for payroll expenses.
Case 1:21-cr-00011-UNA Document1 Filed 01/12/21 Page 4 of 23

13. The amount of a PPP loan that a small business may have been

entitled to receive was determined by the number of employees employed by the

business and the business’s average monthly payroll costs.

14. Inorder to obtain a PPP loan, a qualifying business was required to
submit a PPP loan application, which was 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. In the PPP loan application, the small business (through its authorized

representative) had to state, among other things, its (a) average monthly payroll
expenses and (b) number of employees. These figures were used to calculate the
amount of money the small business was eligible to receive under the PPP. In
addition, businesses applying for a PPP loan had to provide documentation
showing their payroll expenses.

15. The SBA oversaw the PPP. However, individual PPP loans were
issued by private, approved lenders who received and processed PPP
applications and supporting documentation, and then made loans using the
lenders’ own funds, which were 100% guaranteed by the SBA. Data from the
application, including information about the borrower, the total amount of the

loan, and the listed number of employees, was transmitted by the lender to the

SBA in the course of processing the loan.
Case 1:21-cr-00011-UNA Document1i F

led 01/12/21 Page 5 of 23

Relevant Entities

16.

Financial Institution 1 was a Federal Deposit Insurance Corporation

(“FDIC”) insured financial institution headquartered in Fort Lee, New Jersey.

Financial Institution 1 participated in the PPP as

a lender, and as such, was

authorized to lend funds to eligible borrowers under the terms of the PPP.

17.

Financial Institution 2 was an FDIC-insured financial institution

headquartered in Salt Lake City, Utah. Financial Institution 2 participated in the

PPP as a lender, and as such, was authorized to lend funds to eligible borrowers

under the terms of the PPP.
18.

Company 1 paired PPP applicants with lenders by collecting

applications, performing underwriting tasks, and submitting approved

applications to SBA-approved lenders such as Financial Institutions 1-2 for

funding.
19.

Francisco, California with branches throughout

20.

North Carolina with branches throughout the U

21.

Bank 1 was an FDIC-insured financ

Bank 3 was an FDIC-insured financ

ial institution based in San

the United States.

Bank 2 was an FDIC-insured financial institution based in Charlotte,

nited States.

ial institution based in Vienna,

Virginia with branches throughout the United States.

22.

North Carolina with branches throughout the U

Bank 4 was an FDIC-insured financ

ial institution based in Charlotte,

nited States.
Case 1:21-cr-00011-UNA Document1i F

The Scheme to Fraudulently Ob

23.

SMITH, and others known and unknown to the

that they were not eligible to receive.

Under THOMPSON’s direction, BA

24.

MALONEY, WILSON, and SMITH, each kno

THOMPSON recruited BAISDEN, €

tain PPP Loans
"ROSBY, MALONEY, WILSON,

ISDEN, CROSBY,

led 01/12/21 Page 6 of 23

Grand Jury, to obtain PPP loans

wingly submitted, and assisted

in the submission of an SBA Form 2483 PPP Loan Application to Banks 1-4,

through Company 1, that THOMPSON had partially completed, bearing their

respective signatures, and containing false and f

their respective businesses, as set forth in the chart below.

raudulent information about

Approx. Date Amount of # of Monthly
Defendant/Business | | fe beission Loan Employees | Payroll Lender
Requested | Indicated | Indicated
Financial
MALONEY/KMJ May 4, 2020 $300,000 16 $120,000 Institution 1
SMITH / Market Financial
Yourself May 6, 2020 $300,000 16 $120,000 Institution 2
Financial
WILSON/ Rare Breed May 8, 2020 $300,000 16 $120,000 Institution 1
. Financial
Crosby / Faithful May 16, 2020 $300,000 16 $120,000 Institution 1
Financial
BAISDEN/PowerHouse | May 20, 2020 $300,000 16 $120,000 Institution 1

25.

As set forth in the chart below, included with each loan

application were false and fraudulent IRS Form 941s (Employer’s

Quarterly Federal Tax Returns) for each bu
reflected that the business had paid wages

of $358,819.00 to 16 employees in the quarter(s)

6

indicated.

siness, which falsely

tips, and other compensation
Case 1:21-cr-00011-UNA Document1i F

led 01/12/21 Page 7 of 23

. 1 2019 Q2 2019 3 2019 4 2019
Defendant/Business jen - Mar Apr - Jun ri - Sep Ou - Dec
MALONEY/KMJ $358,819.00 $358,819.00 $358,819.00 $358,819.00
SMITH/ Market Yourself N/A $358,819.00 N/A N/A
WILSON/ Rare Breed N/A $358,819.00 N/A N/A
CrosBY/ Faithful $358,819.00 N/A N/A N/A
BAISDEN/ Powerhouse $358,819.00 $358,819.00 $358,819.00 N/A

26. Based on the false and fraudulent representations and submissions

in the PPP loan applications, the IRS Form 941s (Employer's Quarterly Federal

Tax Returns), and other supporting documentation, submitted by BAISDEN,

CROSBY, MALONEY, WILSON, and SMITH, with THOMPSON'S assistance

and direction, Financial Institutions 1-2 funded t

the requested PPP loans as

follows:
: Approximate Date Amount of PPP Location of
Defendant/Business PP Funded Loan Deposit Account
MALONEY / KMJ May 4, 2020 $300,000 Bank 3
SMITH/ Market Yourself May 6, 2020 $300,000 Bank 3
WILSON/ Rare Breed May 8, 2020 $300,000 Bank 4
Crosby / Faithful May 16, 2020 $300,000 Bank 2
BAISDEN/ PowerHouse May 20, 2020 $300,000 Bank 1

27. BAISDEN, CROSBY, MALONEY, V

VILSON, and SMITH had agreed

to pay THOMPSON a percentage of the loan amount, after the funds were

deposited into their respective businesses’ check
28. After the PPP loan funds were dep«
businesses’ checking accounts at Banks 1-4, BAI

WILSON, and SMITH, acting in part on ins

7

<ing accounts at Banks 1-4.
»sited in their respective
SDEN, CROSBY, MALONEY,

tructions from THOMPSON,
Case 1:21-cr-00011-UNA Document1 Filed 01/12/21 Page 8 of 23

used the PPP loan funds for non-qualifying, non-business-related
purposes, including by making checks out to individuals who did not work

for their respective businesses, in violation of the terms of the PPP loan program.

Count One

Conspiracy to Commit Bank Fraud
18 U.S.C. § 1349
(THOMPSON and BAISDEN)

29. The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 28 of this Indictment as if fully set

forth herein.

30. From in or about March 2020 through in or about June 2020, in the
Northern District of Georgia and elsewhere, THOMPSON and BAISDEN did
knowingly and willfully combine, conspire, confederate, agree, and have a tacit
understanding with each other and with others known and unknown to the
Grand Jury, to execute a scheme and artifice to defraud a financial institution, the
deposits of which were insured by the FDIC, and to obtain money, funds, and
credits owned by and under the custody and control of the aforementioned
financial institution by means of materially false and fraudulent pretenses,
representations, and promises and by the omission of material facts, in violation
of Title 18, United States Code, Section 1344.

Object of the Conspiracy

31. The object of the conspiracy was for THOMPSON, BAISDEN, and

others to fraudulently obtain a PPP loan, and to conceal the conspiracy.
Case 1:21-cr-00011-UNA Document1 Filed 01/12/21 Page 9 of 23

Manner and Means

32. The manner and means by which THOMPSON, BAISDEN, and

others sought to accomplish the objects of the conspiracy included, among
others, the following:

33. | THOMPSON and BAISDEN conspired to submit and cause to be
submitted false and fraudulent documents, including an SBA Form 2483 PPP
Loan Application and IRS Form 941s (Quarterly Federal Tax Returns), to
Financial Institution 1 to obtain a $300,000 PPP loan for PowerHouse.

34, Asa result of and based on THOMPSON and BAISDEN’s false
representations and certifications and falsified supporting documents, Financial
Institution 1, a federally insured lender, issued a $300,000 PPP loan to
PowerHouse.

35. THOMPSON and BAISDEN further conspired to use the PPP loan
funds for non-business expenses, including by making payments to themselves
and individuals who did not work for PowerHouse, in violation of the terms of
the PPP loan agreement.

All in violation of Title 18, United States Code, Section 1349.
Case 1:21-cr-00011-UNA Document1 Fi

Count Two

ed 01/12/21 Page 10 of 23

Conspiracy to Commit Bank Fraud

18 U.S.C. § 1349

(THOMPSON and CROSBY)

36. The Grand Jury re-alleges and incor

porates by reference the factual

allegations contained in paragraphs 1 through 28 of this Indictment as if fully set

forth herein.

37. From inor about March 2020 through in or about June 2020, in the

Northern District of Georgia and elsewhere, THOMPSON and CROSBY did

knowingly and willfully combine, conspire, confederate, agree, and have a tacit

understanding with each other and with others known and unknown to the

Grand Jury, to execute a scheme and artifice to defraud a financial institution, the

deposits of which were insured by the FDIC, and to obtain money, funds, and

credits owned by and under the custody and control of the aforementioned

financial institution by means of materially false

and fraudulent pretenses,

representations, and promises and by the omission of material facts, in violation

of Title 18, United States Code, Section 1344.

Object of the Consp

iracy

38. The object of the conspiracy was for

THOMPSON, CROSBY, and

others to fraudulently obtain a PPP loan, and to conceal the conspiracy.

Manner and Means

39. The manner and means by which T]
others sought to accomplish the objects of the co

others, the following:

10

HOMPSON, CROSBY, and

nspiracy included, among
Case 1:21-cr-00011-UNA Document1 Filed 01/12/21 Page 11 of 23

40. THOMPSON and CROSBY conspired to submit and cause to be

submitted false and fraudulent documents, including an SBA Form 2483 PPP

Loan Application and IRS Form 941s (Quarterly Federal Tax Returns), to

Financial Institution 1 to obtain a $300,000 PPP loan for Faithful.
41. Asa result of and based on THOMPSON and CROSBY’s false

representations and certifications and falsified supporting documents, Financial

Institution 1, a federally insured lender, issued a

$300,000 PPP loan to Faithful.

42. THOMPSON and CROSBY further conspired to use the PPP loan

funds for non-business expenses, including by making payments to themselves

and individuals who did not work for Faithful, in violation of the terms of the

PPP loan agreement.

All in violation of Title 18, United States Code, Section 1349.

Count Three

Conspiracy to Commit Bank Fraud

18 U.S.C. § 1349

(THOMPSON and MALONEY)
43. The Grand Jury re-alleges and incorporates by reference the factual

allegations contained in paragraphs 1 through 28 of this Indictment as if fully set

forth herein.

44. From in or about March 2020 through in or about June 2020, in the

Northern District of Georgia and elsewhere, THOMPSON and MALONEY did

knowingly and willfully combine, conspire, confederate, agree, and have a tacit

understanding with each other and with others known and unknown to the

Grand Jury to execute a scheme and artifice to defraud a financial institution, the

11
Case 1:21-cr-00011-UNA Document1 Filed 01/12/21 Page 12 of 23

deposits of which were insured by the FDIC, and to obtain money, funds, and
credits owned by and under the custody and control of the aforementioned
financial institution by means of materially false and fraudulent pretenses,
representations, and promises and by the omission of material facts, in violation
of Title 18, United States Code, Section 1344.

Object of the Conspiracy

45. The object of the conspiracy was for THOMPSON, MALONEY, and

others to fraudulently obtain a PPP loan, and to conceal the conspiracy.

Manner and Means

46. |The manner and means by which THOMPSON, MALONEY, and
|

others sought to accomplish the objects of the conspiracy included, among

others, the following: |

47. THOMPSON and MALONEY conspired to submit and cause to be
submitted false and fraudulent documents, including an SBA Form 2483 PPP
Loan Application and IRS Form 941s (Quarterly Federal Tax Returns), to
Financial Institution 1 to obtain a $300,000 PPP loan for KMJ.

48. Asa result of and based on THOMPSON and MALONEY ’s false
representations and certifications and falsified supporting documents, Financial
Institution 1, a federally insured lender, issued a $300,000 PPP loan to KMJ.

49. THOMPSON and MALONEY further conspired to use the PPP loan
funds for non-business expenses, including by making payments to themselves
and individuals who did not work for KMJ, in violation of the terms of the PPP

loan agreement.

12
Case 1:21-cr-00011-UNA Document1 Filed 01/12/21 Page 13 of 23

All in violation of Title 18, United States Code, Section 1349.

Count Four

Conspiracy to Commit Bank Fraud
18 U.S.C. § 1349
(THOMPSON and SMITH)

50. The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 28 of this Indictment as if fully set
forth herein.

51. From in or about March 2020 through in or about June 2020, in the
Northern District of Georgia and elsewhere, THOMPSON and SMITH did
knowingly and willfully combine, conspire, confederate, agree, and have a tacit
understanding with each other and with others known and unknown to the
Grand Jury to execute a scheme and artifice to defraud a financial institution, the
deposits of which were insured by the FDIC, and to obtain money, funds, and
credits owned by and under the custody and control of the aforementioned
financial institution by means of materially false and fraudulent pretenses,
representations, and promises and by the omission of material facts, in violation

of Title 18, United States Code, Section 1344.

Object of the Conspiracy

52. The object of the conspiracy was for THOMPSON, SMITH, and

others to fraudulently obtain a PPP loan, and to conceal the conspiracy.

13
Case 1:21-cr-00011-UNA Document1 Filed 01/12/21 Page 14 of 23

Manner and Means

53. The manner and means by which THOMPSON, SMITH, and others
sought to accomplish the objects of the conspiracy included, among others, the

following:

54. THOMPSON and SMITH conspired to submit and cause to be
submitted false and fraudulent documents, including an SBA Form 2483 PPP
Loan Application and IRS Form 941s (Quarterly Federal Tax Returns), to
Financial Institution 2 to obtain a $300,000 PPP loan for Market Yourself.

55. Asa result of and based on THOMPSON and SMITH’s false
representations and certifications and falsified supporting documents, Financial
Institution 2, a federally insured lender, issued a $300,000 PPP loan to Market
Yourself.

56. THOMPSON and SMITH further conspired to use the PPP loan
funds for non-business expenses, including by making payments to themselves
and individuals who did not work for Market Yourself, in violation of the terms

of the PPP loan agreement.
All in violation of Title 18, United States Code, Section 1349.

14
Case 1:21-cr-00011-UNA Document1 Fi

Count Five

ed 01/12/21 Page 15 of 23

Conspiracy to Commit Bank Fraud

18 U.S.C. § 1349

(THOMPSON and WILSON)

57. The Grand Jury re-alleges and incorporates by reference the factual

allegations contained in paragraphs 1 through 28 of this Indictment as if fully set

forth herein.

58. From in or about March 2020 through in or about June 2020, in the

Northern District of Georgia and elsewhere, THOMPSON and WILSON did

knowingly and willfully combine, conspire, confederate, agree, and have a tacit

understanding with each other and with others known and unknown to the

Grand Jury to execute a scheme and artifice to defraud a financial institution, the

deposits of which were insured by the FDIC, and to obtain money, funds, and

credits owned by and under the custody and control of the aforementioned

financial institution by means of materially false

and fraudulent pretenses,

representations, and promises and by the omission of material facts, in violation

of Title 18, United States Code, Section 1344.

Object of the Conspiracy

59. The object of the conspiracy was for

THOMPSON, WILSON, and

others to fraudulently obtain a PPP loan, and to conceal the conspiracy.

15
Case 1:21-cr-00011-UNA Document1 Filed 01/12/21 Page 16 of 23

Manner and Means

60. The manner and means by which THOMPSON, WILSON, and
others sought to accomplish the objects of the conspiracy included, among
others, the following:

61. THOMPSON and WILSON conspired to submit and cause to be
submitted false and fraudulent documents, including an SBA Form 2483 PPP
Loan Application and IRS Form 941s (Quarterly Federal Tax Returns), to
Financial Institution 1 to obtain a $300,000 PPP loan for Rare Breed.

62. Asaresult of and based on THOMPSON and WILSON’s false
representations and certifications and falsified supporting documents, Financial
Institution 1, a federally insured lender, issued a $300,000 PPP loan to Rare
Breed.

63. THOMPSON and WILSON further conspired to use the PPP loan
funds for non-business expenses, including by making payments to themselves
and individuals who did not work for Rare Breed in violation of the terms of the
PPP loan agreement.

All in violation of Title 18, United States Code, Section 1349.

Counts Six to Ten
Bank Fraud ©
18 U.S.C. § 1344 and § 2

64. The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 28 this Indictment as if fully set

forth herein.

16
Case 1:21-cr-00011-UNA Document1 Filed 01/12/21 Page 17 of 23

65. Onor about the dates set forth in the chart below, in the Northern
District of Georgia and elsewhere, BAISDEN, CROSBY, MALONEY,
WILSON, SMITH, and THOMPSON, and others known and unknown to the

Grand Jury, did knowingly execute and attempt to execute a scheme and artifice

to defraud Financial Institutions 1-2, the deposits of which were then insured by
the FDIC, and to obtain, by means of materially false and fraudulent pretenses,
representations, and promises, and by omission of material facts, certain moneys,

funds, credits, assets, securities, and other property owned by and under the

custody and control of Financial Institutions 1-2.

THOMPSON, Submission of
6 MALONEY May 4, 2020 PPP Loan Financial Institution 1
(KMJ) Application
THOMPSON, .
SMITH Submission of
7 May 6, 2020 PPP Loan Financial Institution 2
(Market Application
Yourself) Pp
THOMPSON, Submission of
8 WILSON May 8, 2020 PPP Loan Financial Institution 1
(Rare Breed) Application
THOMPSON, Submission of
9 CROSBY May 16, 2020 PPP Loan Financial Institution 1
(Faithful) Application
THOMPSON, Submission of
10 BAISDEN May 20, 2020 PPP Loan Financial Institution 1
(PowerHouse) Application

All in violation of Title 18, United States Code, Section 1344 and Section 2.

17
Case 1:21-cr-00011-UNA Document1 Filed 01/12/21 Page 18 of 23

Counts Eleven to Fifteen

False Statement to a Federally Insured Bank
18 U.S.C. § 1014 and § 2

66. The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 28 this Indictment as if fully set
forth herein.

67. Onor about the dates set forth in the chart below, in the Northern
District of Georgia and elsewhere, BAISDEN, CROSBY, MALONEY,
WILSON, SMITH, and THOMPSON, and others, known and unknown to the

Grand Jury, knowingly made, and caused to be made, a false statement for the

purpose of influencing the actions of Financial Institutions 1-2, financial

institutions the accounts of which were insured by the FDIC, in connection with

PPP loan applications, as follows: |

AL , | May4, False statements in the PPP Borrower 1
THOMPSON | 2020 Application Form and other documents
submitted with the KMJ loan application
12 SMITH, May 6, False statements in the PPP Borrower 2
THOMPSON | 2020 Application Form and other documents
submitted with the Market Yourself loan
application
13 WILSON, May 8, False statements in the PPP Borrower 1
THOMPSON 2020 Application Form and other documents
submitted with the Rare Breed loan
application
14 CROSBY, | May 16, False statements in the PPP Borrower 1
THOMPSON 2020 Application Form and other documents
submitted with the Faithful loan application
15 BAISDEN, | May 20, False statements in the PPP Borrower 1
THOMPSON | 2020 Application Form and other documents
submitted with the Powerhouse loan
application
18
Case 1:21-cr-00011-UNA Document1 Filed 01/12/21 Page 19 of 23

All in violation of Title 18, United States Code, Section 1014 and

Section 2.

Counts Sixteen to Twenty
Money Laundering
18 U.S.C. § 1956(a)(1)(B)(i) and § 2

68. The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 28 of this Indictment as if fully set
forth herein.

69. Onor about the dates set forth in the chart below, in the Northern
District of Georgia and elsewhere, BAISDEN, CROSBY, MALONEY,
WILSON, SMITH, and THOMPSON, and others known and unknown to the
Grand Jury, knowingly conducted and attempted to conduct a financial
transaction affecting interstate commerce, which involved the proceeds of a
specified unlawful activity, that is, bank fraud, in violation of Title 18, United
States Code, Section 1344, and wire fraud, in violation of Title 18, United States
Code, Section 1343, knowing that the transaction was designed in whole and in
part to conceal and disguise the nature, location, source, ownership, and control
of the proceeds of specified unlawful activity, and while conducting and
attempting to conduct such financial transaction knowing that the property

involved in the financial transaction represented the proceeds of some form of

unlawful activity:

check b g Baisden’s signature made out to
an individual who did not work for defendant's
company was cashed at a bank in the Northern

District of Georgia

BAISDEN

19
Case 1:21-cr-00011-UNA Document1 Filed 01/12/21 Page 20 of 23

17 SMITH, May 11, 2020 A check bearing Smith’s signature made out to an
THOMPSON individual who did not work for defendant's
company was cashed at a bank in the Northern
District of Georgia
18 MALONEY, May 12, 2020 A check bearing Maloney’s signature made out to
THOMPSON an individual who did not work for defendant's
company was cashed at a bank in the Northern
| District of Georgia
19 WILSON, May 14, 2020 A check bearing Wilson’s signature made out to an
THOMPSON individual who did not work for defendant's
company was cashed at a bank in the Northern
District of Georgia
20 CROSBY, May 28, 2020 A check bearing Crosby’s signature made out to an
THOMPSON individual who did not work for defendant's
company was cashed at a bank in the Northern
District of Georgia

All in violation of Title 18, United States Code, Section 1956(a)(1)(B)(i) and

Section 2.

Forfeiture

Upon conviction of one or more of the offenses alleged in Counts One

through Fifteen of this Indictment, the defendants, THOMPSON, BAISDEN,

CROSBY, MALONEY, SMITH, and WILSON, shall forfeit to the United States,

pursuant to Title 18, United States Code, Sections 982(a)(2), any property

constituting, or derived from, proceeds the person obtained directly or indirectly

as the result of such violation, including but not limited to the following:

(a)

MONEY JUDGMENT: A sum of money in United States currency,

representing the amount of proceeds obtained as a result of the

offenses alleged in Counts One through Ten of this Indictment.

20
Case 1:21-cr-00011-UNA Document1 Filed 01/12/21 Page 21 of 23

(b)

(a)

FUNDS:
$3 990.89 in funds from Bank Account Number ending 1965 held

1.

in the name of Rare Breed Nation LLC, at Bank of America,

Atlanta, Georgia (20-FBI-004483)

$99,002.09 in funds from Bank Account Number ending 4940

held in the name of Rare Breed Nation, LLC at Bank of America,

Atlanta, Georgia (20-FBI-004535);

$88,298.05 in funds from Bank A

ccount Number ending 2822

held in the name of Faithful Transport Services LLC, at BB&T

Bank, Atlanta, Georgia (20-FBI-004611);

$46,244.93 in funds from Bank Account Number ending 1484

held in the name of Powerhouse

Fargo Bank, Chamblee, Georgia

including but not limited to the following:

Sports Academy, LLC at Wells
20-FBI-004770).

Upon conviction of one or more of the offenses alleged in Counts Sixteen
through Twenty of this Indictment, the defendants, THOMPSON, BAISDEN,
CROSBY, MALONEY, SMITH, and WILSON, shall forfeit to the United States,
pursuant to Title 18, United States Code, Sections 982(a)(1), any property, real or

personal, involved in such offense, or any property traceable to such property,

MONEY JUDGMENT: A sum of money in United States currency,

representing the amount of proceeds obtained as a result of the

offenses alleged in Counts One through Ten of this Indictment.

21
Case 1:21-cr-00011-UNA Document1 Fi

(b)

FUNDS:

1.

ed 01/12/21 Page 22 of 23

$3,990.89 in funds from Bank Account Number ending 1965 held

in the name of Rare Breed Nation LLC, at Bank of America,

Atlanta, Georgia (20-FBI-004483);

$99,002.09 in funds from Bank Account Number ending 4940

held in the name of Rare Breed Nation, LLC at Bank of America,

Atlanta, Georgia (20-FBI-004535);

$88,298.05 in funds from Bank Account Number ending 2822

held in the name of Faithful Transport Services LLC, at BB&T

Bank, Atlanta, Georgia (20-FBI-004611);

$46,244.93 in funds from Bank A
held in the name of Powerhouse

Fargo Bank, Chamblee, Georgia

ccount Number ending 1484.
Sports Academy, LLC at Wells

If, as a result of any act or omission of a defendant, any property subject to

forfeiture:

(a)
(b)
(c)
(d)
(e)

cannot be located upon the exercise

of due diligence;

has been transferred or sold to, or deposited with, a third party;

has been placed beyond the jurisdic

tion of the Court;

has been substantially diminished in value; or

has been commingled with other property which cannot be divided

without difficulty;

the United States intends, pursuant to Title 21, United States Code, Section

853(p), as incorporated by Title 18, United States Code, Section 982(b)(1), to

22
Case 1:21-cr-00011-UNA Document1 Filed 01/12/21 Page 23 of 23

seek forfeiture of any other property of the Defendants up to the value of the

forfeitable property.

BOBBY L. CHRISTINE

Pea E§ United States Attorney
NE C. 6b Sms

Special Assistant United States Attorney
Georgia Bar No. 497764

600 U.S. Courthouse

75 Ted Turner Drive SW
Atlanta, GA 30303
404-581-6000; Fax: 404-581-6181

DANIEL S. KAHN
Acting Chief, Fraud Section
U.S. Department of Justice
Ny a Negros
MICHAEL P. MCCARTHY
Trial Attorney, Fraud Section

U.S. Department of Justice
D.C. Bar No. 1020231

1400 New York Ave, NW

Bond Building, 11th Floor
Washington, DC 20005
202-514-2000; Fax: 202-514-3708

BILL


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