Вы находитесь на странице: 1из 4

Case 3:18-cr-00089-MMH-JRK Document 181 Filed 08/09/19 Page 1 of 4 PageID 686

UNITED STATES DISTRICT COURT


MIDDLE DISTRICT OF FLORIDA
JACKSONVILLE DIVISION

UNITED STATES OF AMERICA

v. CASE NO. 3:18-cr-89-J-34JRK

KATRINA BROWN
REGINALD BROWN

UNITED STATES’ PROPOSED STATEMENT OF THE CASE

As directed by the Court, the United States is submitting a statement of

the case to be read to the venire panel. The undersigned conferred with

counsel for Defendant Reginald Brown, who has no objection to this

statement. Pro se Defendant Katrina Brown notified the United States by

email that she will “oppose this statement” and file an “individual statement

in the court.” The United States’ proposed statement of the case is as follows:

The Indictment in this case charges thirty-eight counts. Count One

charges the Defendants, Katrina Brown and Reginald Brown, with conspiracy

to commit mail fraud and wire fraud. Count One alleges, among other

things, that the Defendants engaged in a conspiracy in which they sought to

obtain Small Business Administration (or SBA) loan funds primarily by

submitting fake invoices from Reginald Brown’s businesses to BizCapital, an

SBA-approved lender. The Indictment alleges that the false invoices tricked
Case 3:18-cr-00089-MMH-JRK Document 181 Filed 08/09/19 Page 2 of 4 PageID 687

BizCapital into releasing SBA-loan proceeds to Reginald Brown’s businesses.

Allegedly, a portion of the funds were retained by those businesses and used

for Reginald Brown’s personal benefit. The Indictment further alleges that a

portion of the funds were diverted back to Katrina Brown’s family business,

and used for various purposes, including Katrina Brown’s personal benefit.

Count One further alleges that Reginald Brown’s businesses performed no

legitimate service and sold no equipment or goods, and thus no SBA loan

proceeds should have been paid to those businesses. The conspiracy is

alleged to have spanned from in or about late 2013 through in or about early

2015.

Both Defendants are also charged with thirteen counts of aiding and

abetting mail fraud (Counts Two through Fourteen), thirteen counts of aiding

and abetting wire fraud (Counts Fifteen through Twenty-Seven), and six

counts of aiding and abetting money laundering (Counts Twenty-Eight

through Thirty-Three).

In addition, Katrina Brown is charged with two counts of attempted

bank fraud (Counts Thirty-Four and Thirty-Five) and two counts of making

false statements to a federally-insured financial institution (Counts Thirty-Six

and Thirty-Seven).

2
Case 3:18-cr-00089-MMH-JRK Document 181 Filed 08/09/19 Page 3 of 4 PageID 688

Finally, Reginald Brown is charged with failure to file a federal tax

return (Count Thirty-Eight).

Respectfully submitted,

MARIA CHAPA LOPEZ


United States Attorney

/s/ Michael J. Coolican


Tysen Duva
Assistant United States Attorney
Florida Bar No. 0603511
Michael J. Coolican
Assistant United States Attorney
USA No. 156
300 N. Hogan Street, Suite 700
Jacksonville, Florida 32202
Telephone: (904) 301-6300
Facsimile: (904) 301-6310
Tysen.Duva@usdoj.gov
Michael.Coolican@usdoj.gov

3
Case 3:18-cr-00089-MMH-JRK Document 181 Filed 08/09/19 Page 4 of 4 PageID 689

CERTIFICATE OF SERVICE

I hereby certify that on August 9, 2019, I electronically filed the

foregoing with the Clerk of the Court by using the CM/ECF system, which

will send a notice of electronic filing to the following:

Katrina Brown, pro se

Thomas M. Bell (Counsel for Reginald Brown)

/s/ Michael Coolican


Michael Coolican
Assistant United States Attorney