United States v. April Watson, Indictment (Northern District of Texas, Dallas Division)
Summary
Sealed indictment in the Northern District of Texas, Dallas Division, against April Watson, also known as April Watson Horton and April Shawnette Watson, who owned Exotic Bliss Beauty LLC and Brain Evolution LLC and co-owned Southern Home Ventures, LLC. Counts one through four charge wire fraud, alleging that in 2020 she submitted false payroll and tax documents to Kabbage for PPP loans and inflated revenue on EIDL applications. According to the indictment, Kabbage paid about $210,698.00 in PPP funds and the SBA paid about $299,800.00 in EIDL funds to accounts she controlled. Counts five and six charge bank fraud over 2021 PPP applications to JPMorgan Chase that brought about $169,994.00, and further counts charge monetary transactions in criminal proceeds. A government motion to keep the indictment sealed until her arrest is attached.
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IN TTM UNITED STATES DISTRICT COURT
FOR T}TE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
*-8 6CR- 688 X
LTNITED STATES OF AMEzuCA
No.
FILED UNDER SEAL
APRIL WATSON
a.k.a. "April Watson Horton"
a.k.a. "April Shawnette Watson"
INDICTMENT
The Grand Jury charges:
At times material to this Indictment:
Background
t. The Coronavirus Aid, Relief, and Economic Security ("CARES") Act
was a federal law enacted on or about March 27,,2020, to provide emergency financial
assistance to Americans suffering economic harms from the COVID-19 pandemlc.
2. One source of relief provided by the CARES Act was the authorization of
forgivable loans to small businesses forjob retention and certain other expenses, through
the Paycheck Protection Program ("PPP"). The PPP loan application required that
businesses acknowledge, through authorized representatives, the program rules and make
certain affrmative certifications to be eligible to obtain the PPP loan.
3. PPP loan applications were submitted through the U.S. Small Business
Administration C'SBA') website portal for initial review and sent to financial institutions
for processing. The SBA would preliminarily approve the loan packet and forward it to a
Indictment-Page I
designated financial institution. After the SBA approval, the financial institution would
review and process the packet, fund the loan, and deposit the proceeds into the
applicant's bank account. The SBA, however, guaranteed the loans.
4. Ln2020, the CARES Act expanded the SBA's long-standing Economic
Injury Disaster Loans ("EIDL") by recognizirg a nationwide COVID EIDL. Unlike PPP
loans, which were made through private and nonprofit lenders and guaranteed through
the federal govemment, the SBA EIDL were made directly by the federal government
through the SBA website portal
5. In order to obtain a COVID-l9 EIDL, a qualifuing business was required to
submit an EIDL application to the SBA and provide information about its operations.
The amount of the advance and the loan, if the application was approved, was determined
based, in part, on the information provided in the application conceming the number of
employees, gross revenues, and cost ofgoods sold for the l2-month period preceding
January 31,2020. The borrower sigaed an agreement that it would use all of the
proceeds "solely as working capital to alleviate economic injury caused by" the COVID-
l9 pandemic.
The Defendant. Related Entities, and Individuals
6. Defendant April Watson, also known as April Watson Horton and April
Shawnette Watson ("Watson"), was a resident of Dallas and DeSoto and later of
Arlington and Cedar Hill, all within the Northem District of Texas. Watson was the
owner and manager of the following entities:
Indictment-Page 2
a. Exotic Bliss Beauty LLC ("Exotic Bliss"), a Texas limited liability
company located in Dallas;
b. Brain Evolution LLC ("Brain Evolution"), a Texas limited liability
company located in Duncanville, Texas.
7. Southern Home Ventures, LLC ("Southem Home Ventures") was a Texas
Limited Liability Company located in Dallas that remodeled residential homes. Southern
Home Ventures was co-owned by Watson and another individual known to the grand
Jury.
Financial titutions
8. JPMorgan Chase ("JPMC") was a financial institution as defined in 18
U.S.C. $ 20 whose deposits were insured by the Federal Deposit Insurance Corporation
C'FDIC').
9. Kabbage, Inc. ("Kabbage") was a financial institution headquartered in
Atlanta, Georgia that participated in the Paycheck Protection Program as a third-party
lender and disbursed PPP loans to Exotic Bliss and Southern Home Ventures.
[Remainder of Page Intentionally Left Blank]
Indictment-Page 3
Counts One Through Four
Wire Fraud
(18 U.S.C. $ 1343)
10. The Grand Jury realleges paragraphs I through 9 ofthis indictment as
thoush fullv set lorth herein.
Scheme
11 . From in or around April2020 and continuing to at least on or about June
22,2020, in the Northem District of Texas and elsewhere, the defendant, April Watson,
knowingly and with intent to defraud, devised and intended to devise a scheme and
artifice to defraud the SBA, and to obtain money and property from the SBA by means of
materially false and fraudulent pretenses, representations, and promises.
12. The scheme to defraud operated, in substance, as follows:
a In or around May 2020, in support of PPP loan applications for
Exotic Bliss and Southem Home Ventures, Watson caused to be prepared and submitted
to Kabbage false Intemal Revenue Service ("IRS") and payroll documents, such as IRS
Form W-2s and W-3s, purportedly prepared by a payroll company. In fact, no business
tax retums related to the wages of Southem Home Venfures or Exotic Bliss were ever
filed with the IRS for 2019 or 2020, and no payroll forms were prepared by the company
purportedly used.
b. In order to obtain EIDL funds from the SBA, Watson prepared and
caused the submission of applications on behalf of Exotic Bliss and Southern Home
Ventures that falsely inflated each entity's gross revenues for the l2-month period ending
Indictment-Page 4
January 31,2020. In reality, no business tax returns related to the gross revenues for
Exotic Bliss or Southern Home Ventures were ever filed with the IRS for 2019 or 2020.
13. As a result of Watson's scheme to de{iaud, Kabbage disbursed
approximately $210,698.00 in PPP funds to accounts Watson controlled, and the SBA
disbursed approximately $299,800.00 in EIDL funds to accounts Watson controlled.
Use of the Wires
14. On or about the following dates, in the Northem District of Texas and
elsewhere, for the purpose of executing the scheme and artifice described above, Watson
hansmitted and caused to be transmitted, by means of wire communication in interstate
commerce, the following writings, signs, signals, pictures, and sounds:
Count Date Description of Wire
I 05/20/2020 Wire transfer in the amount of $66,221.00 from
Kabbage through servers outside ofTexas to an Exotic
Bliss JMPC account endirg in 8401 in the Northem
District of Texas.
2 0s/28t2020 Electronic transmission of the Southem Home Ventures
PPP application from the Northern District of Texas to
Kabb e throu servers outside of Texas.
3 06/18t2020 Electronic transmission of the Exotic Btiss EIDL
application from the Northern District of Texas to the
SBA through servers outside ofTexas.
4 06/19/2020 Electronic transmission of the Southern Home Ventures
EIDL application from the Northern District of Texas to
the SBA tkough servers outside ofTexas.
All in violation of l8 U.S.C. g 1343.
Indictment-Page 5
Counts Five Throueh Six
Bank Fraud
[Violation of 18 U.S.C. $ 1344(2)]
15. The Grand Jury realleges paragraphs I through 9 ofthis indictment as
though fully set forth herein.
The Scheme
16. Beginning no later than on or about March 5,2021, and continuing through
on or about October 12,2021, in the Northern District ofTexas and elsewhere, defendant
Watson, knowingly and with intent to defraud, executed a scheme and artifice to obtain
moneys, funds, credits, assets, securities, and other property owned by, and under the
custody and control of, JPMC, by means ofmaterially false and fraudulent pretenses,
representations, and promises.
17. The scheme operated, in substance, as follows:
a. Defendant Watson submitted, and caused to be submitted, ppp loan
applications to JPMC on behalf of Exotic Beauty Bliss and Brain Evolution that provided
false information conceming the businesses' average monthly payroll.
b. In support ofthe fraudulent loan applications, Watson prepared and
caused to be submitted to JPMC false IRS documentation and false payroll summaries.
18. As a result of her scheme to defraud, Watson caused JPMC to disburse
approximately $169,994.00 in PPP funds to accounts she controlled.
Indictment-Page 6
Executions
19. On or about the following dates. in the Northem District of Texas and
elsewhere, defendant April Watson, caused the following acts to be committed, each of
which constituted an execution of the fraudulent scheme:
Application Amount
Count Entity Amount Funded
Date Requested
5 310512021 Exotic Bliss $74,432 $74,432
6 3126/2021 Brain Evolution s9s,s62 $9s,s62
All in violation of 18 U.S.C. 5 1344(2).
[Remainder of Page Intentionally Left Blank]
Indictment-Page 7
Counts Seven Throueh Ten
Engaging in Monetary Transactions in Property
Derived from a Specified Unlawful Activity
(Violation of 18 U.S.C. $ 1957)
20. The Grand Jury realleges paragraphs 1 through 9 ofthis indictment as
though fully set lorth herein.
2l . On or about the dates set forth below. in the Northern District of Texas and
elsewhere, defendant April Watson, knowing that the property involved represented the
proceeds of some form of unlawful activity, knowingly engaged in the following
monetary transactions in criminally derived property ofa value greater than $10,000,
such property having been derived from specified unlawful activity, that is wire fraud, in
violation of l8 U.S.C. $ 1343:
Count Date Transaction
7 tt/03/2020 Wire transfer of $50,000 from Exotic Bliss' JPMC account
ending in 8401 to Perry and Legacy Acres Development LLC
for the construction of a personal residence
8 1112712020 Wire transfer of $50,000 from Exotic Bliss' JPMC account
ending in 8401 to Perry and Legacy Acres Development LLC
for the construction of a personal residence
9 t2/0312020 Wire transfer of $14,850 from Exotic Bliss' JPMC account
ending in 8401 to Perry and Legacy Acres Development LLC
for the construction of a personal residence
10 12t04/2020 Wire transfer of $40,000 from Exotic Bliss' JPMC account
ending in 8401 to Max Horton
Each in violation of 18 U.S.C. $ 1957.
Indictment-Page 8
Notice of Criminal Forfeiture
(18 U.S.C. $ 981(a)(1)(C), (l)(2), and 28 U.S.C. $ 2a6l(c))
Upon conviction ofany ofCounts One through Four, the defendant, April
Watson, shall forfeit to the United States, pursuant to 18 U.S.C. $ 981(a)(1)(C) and 28
U.S.C. $ 2461(c), any property, real or personal, that constitutes or is derived from
proceeds traceable to the offenses, including, but not limited to, a forfeiture money
judgment representing the amount ofproceeds traceable to the offenses.
Pursuant to l8 U.S.C. $ 982(a)(2), upon conviction of either Count Five or Count
Six, the defendant, April Watson, shall forfeit to the United States any property
constituting, or derived from, proceeds the defendant obtained directly or indirectly, as
the result of such violation.
Pursuant to l8 U.S.C. $ 982(a)(1), upon conviction of any ofCounts Seven
through Ten, the defendant, April Watson, shall forfeit to the United States any property,
real or personal, involved in such offense, or any property traceable to such property.
The property subject to forfeiture includes but is not limited to all that lot or parcel
of land, together with buildings, improvements, fixtures, attachments, and easements
located at 324 Tenace Lane, Cedar Flill, Texas 75 104 owned by April Shawnette
Watson, more fully described as follows:
Lot 13, Block A, The Terraces, an addition to the City of Cedar Hill,
Dallas County, Texas, according to the map or plat thereof recorded
in/under Volume 2005158, Page 61, Pat Records, Dallas County,
Texas.
The properry to be forfeited includes, but is not limited to, a "money judgment" in
the amount ofU.S. currency constituting the gross proceeds traceable to the offense.
Indictment-Page 9
Pursuant to 2l U.S.C. $ 853(p), as incorporated by 28 U.S.C. $ 2a6l(c), if any of
the property described above, as a result of any act or omission ofthe defendant;
a. cannot be located upon the exercise ofdue diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond thejurisdiction ofthe court;
d. has been substantially diminished in value: or
e. has been commingled with other property which cannot be divided
without difficultv.
the United States intends to seek forfeiture ofany property ofthe defendant up to the
value ofthe forfeitable property described above.
A TRI]E BILL
F
RYAN RAYBOT]LD
UNITED STATES ATTORNEY
,]
ELISEALDENDIFER
Assistant United States A
Texas Bar No. 24124103
I 100 Commerce Street, Third Floor
Dallas, Texas 7 5242-1699
Telephone: 214-659-8600
Fax: 214-659-8805
Email : Elise.Aldendifer@usdoj.gov
Indictment-Page 10
COPY SEALED (A
IN THE UNITED STATES DISTzuCT COTIRT FILED-USDC-}IDTN-DA
FOR THE NORTHERN DISTRICT OF TEXAS '26 0CT ? pri4:23
DALLAS DIVISION
UNITED STATES OF AMEzuCA
FILED UNDER SEAL
CR]MINAL NO.
APRIL WATSON
a.k.a. "April Watson Horton"
a.k.a. "April Shawnette Watson"
a- 26
GOVERIIMENT'S MOTION TO SEAL INDICTMENT
The United States of America ("the Government"), by and through the United
States Attomey for the Northem District of Texas and the undersigned Assistant United
States Attomey, moves for an order sealing the indictment retumed by the grand jury in
the above-captioned criminal case. The Govemment requests that the indictment remain
sealed until such time as the defendant is apprehended, or until further order ofthe Court
The Govemment believes that the public release of the name of the indicted defendants
before they have been apprehended would undermine the pursuit ofjustice. The
Govemment, however, requests that the case against each defendant be unsealed upon the
apprehension and appearance of that defendant.
INO FURTmR INFORMATTON ON THrS PAGE]
I
Respectfully submitted,
RYANRAYBOT]LD
UNITED STATES ATTORNEY
Elise B. Aldendif'er
Assistant United States Attomey
Texas Bar No. 24124103
1100 Commerce Street, Third Floor
Dallas, Texas 7 5242-1699
Telephone: (2 14) 659-88 14
Facsimile: (2 1 4) 659-8808
elise. aldendi fer@usdo-i. eov
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