UNITED STATES DISTRICT COURT 

MIDDLE DISTRICT OF FLORIDA 

FEDERAL TRADE COMMISSION, and 

OFFICE OF THE ATTORNEY 

GENERAL, 

STATE OF FLORIDA, 

DEPARTMENT OF LEGAL AFFAIRS, 

Plaintiffs, 

v. 

TREASHONNA P. GRAHAM, a/k/a 

SHONNA GRAHAM, a/k/a 

TREASHONNA LEE WILLIAMS, a/k/a 

SHONNA LEE WILLIAMS, also d/b/a 

The GRANT BAE, GRANT BAE, and 

GRANT BAE CONSULTING AND 

MORE, individually and as a member, 

manager, or owner of C LEE 

ENTERPRISES LLC, and 

C LEE ENTEPRISES LLC, a Florida 

limited liability company, also d/b/a 

GRANT BAE and GRANT BAE 

CONSULTING AND MORE, 

Defendants. 

COMPLAINT FOR 

PERMANENT INJUNCTION, 

MONETARY RELIEF, AND 

OTHER RELIEF 

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Plaintiffs, the Federal Trade Commission ("FTC"), and the Office of the 

Attorney General, State of Florida, Department of Legal Affairs ("Florida Attorney 

General") for their Complaint allege: 

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1. The FTC brings this action under Sections 13(b) and 19 of the Federal 

Trade Commission Act ("FTC Act"), 15 U.S.C. §§ 53(b) and 57b, and Section 

1401 ( c )(1) of the COVID-19 Consumer Protection Act of the 2021 Consolidated 

Appropriations Act, Pub. L. No. 116-260, 134 Stat. 1182, Title XIV, § 140l(c)(l), 

15 U.S.C. § 45 note (Prohibiting Deceptive Acts or Practices in Connection With the 

Novel Coronavirus ("CCPA") § 1401(c)(l)) ("COVID-19 Consumer Protection 

Act" or "CCP A"), which authorizes the FTC to seek, and the Court to order, 

temporary, preliminary, and permanent injunctive relief, an asset freeze, the 

appointment of a receiver, immediate access to the Defendants' business premises 

and documents, an accounting of assets, monetary relief, and other relief, for 

Defendants' acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. 

§ 45(a), and Section 1401(b)(2) of the CCPA. 

2. The Florida Attorney General brings this action under the Florida 

Deceptive and Unfair Trade Practices Act, Chapter 501, Part II, Florida Statutes 

("FDUTP A"), which authorizes the Florida Attorney General to seek, and the Court 

to order, permanent injunctive relief, recission or reformation of contracts, consumer 

restitution, the refund of monies paid, disgorgement of ill-gotten monies, attorneys' 

fees, the appointment of a receiver, civil penalties and other equitable relief for 

Defendants' acts or practices in violation of FDUTP A. The Florida Attorney General 

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has conducted an investigation and all conditions precedent to filing as required by 

Section 501.207(2), Florida Statutes, have been satisfied. 

SUMMARY OF CASE 

3. Defendants C Lee Enterprises LLC ("Grant Bae") and its owner 

Treashonna P. Graham induce struggling minority-owned small businesses to use 

Grant Bae' s grant writing and business consulting services by falsely representing 

to these businesses that they will receive guaranteed funding as the result of retaining 

Defendants' services. 

4. While Defendants represent to these businesses that Grant Bae's 

mission is to assist them in obtaining capital through Defendants' grant writing 

services, Grant Bae' s true purpose is to enrich Defendants at the expense of 

unsuspecting business owners. 

5. Grant Bae takes large fees, sometimes of more than $5,000, from 

minority-owned small business owners in exchange for false promises of guaranteed 

grant funding. 

6. However, rather than obtaining funding on behalf of these businesses 

as promised, Defendants leave countless minority-owned small business owners 

without the money they paid for Grant Bae' s illusory grant writing and business 

consulting services and the capital they were guaranteed. 

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7. Moreover, Grant Bae, started with seed money from wrongfully 

acquired COVID-19 relief funds, represented to consumers that it would secure for 

them government funds designed for small businesses impacted by COVID-19. 

JURISDICTION AND VENUE 

8. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 

1331, 1337(a), and 1345. 

9. This Court has supplemental jurisdiction over the Florida Attorney 

General's claims pursuant to 28 U.S.C. § 1367. 

10. Venue is proper in this District under 28 U.S.C. § 1391(b)(l), (b)(2), 

(c)(l), (c)(2), and (d), and 15 U.S.C. § 53(b). 

PLAINTIFFS 

11. The FTC is an independent agency of the United States Government 

created by the FTC Act, which authorizes the FTC to commence this district court 

civil action by its own attorneys. 15 U.S.C. §§ 41-58. The FTC enforces Section 5(a) 

of the FTC Act, 15 U.S.C. § 45(a), which prohibits unfair or deceptive acts or 

practices in or affecting commerce. The FTC also enforces the COVID-19 Consumer 

Protection Act, 15 U.S.C. § 45 note (CCPA § 1401), which prohibits, among other 

things, deceptive acts or practices associated with a government benefit related to 

COVID-19 for the duration of the COVID-19 public health emergency. 

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12. The Florida Attorney General is an enforcing authority under the 

FDUTP A, Section 501.203(2), Florida Statutes, and is authorized to pursue this 

action to enjoin violations of the FDUTPA and to obtain equitable or other 

appropriate relief, including recission or reformation of contracts, consumer 

restitution, the appointment of a receiver, the refund of monies paid, disgorgement 

of ill-gotten monies, or any other appropriate relief pursuant to Section 501.207, 

Florida Statutes. 

DEFENDANTS 

13. Defendant C Lee Enterprises LLC, also doing business as Grant Bae 

and Grant Bae Consulting and More, is a Florida limited liability company with its 

principal place of business at 129 N.E. Fryer St., Lake City, Florida 32055. 

Defendant C Lee Enterprises LLC transacts or has transacted business in this District 

and throughout the United States. C Lee Enterprises LLC and its d/b/a Grant Bae 

and Grant Bae Consulting and More are also associated with the address, 2172 S.E. 

Baya Ave, Lake City, Florida, 32055, which at times includes the suite number 103. 

14. Defendant Treashonna P. Graham, a/k/a Shonna Graham, a/k/a 

Treashonna Lee Williams, a/k/a Shonna Lee Williams, also d/b/a The Grant Bae and 

Grant Bae Consulting and More is the managing member of Defendant C Lee 

Enterprises LLC, which also does business as Grant Bae and Grant Bae Consulting 

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and More. At all times relevant to this Complaint, acting alone or in concert with 

others, she has formulated, directed, controlled, had the authority to control, or 

participated in the acts and practices of Defendant C Lee Enterprises LLC, also d/b/a/ 

Grant Bae and Grant Bae Consulting and More, including the acts and practices set 

forth in this Complaint. Defendant Graham resides in this District and, in connection 

with the matters alleged herein, transacts or has transacted business in this District 

and throughout the United States. 

COMMERCE 

15. At all times relevant to this Complaint, Defendants have maintained a 

substantial course of trade in or affecting commerce, as "commerce" is defined in 

Section 4 of the FTC Act, 15 U.S.C. § 44 and as "trade or commerce" is defined in 

Florida Statutes Section 501.203(8). 

DEFENDANTS' BUSINESS ACTIVITIES 

16. Since at least October of 2020, Defendants C Lee Enterprises LLC and 

Treashonna Graham, who refers to herself as "The Grant Bae," have marketed grant 

writing and consulting services to minority-owned small businesses through the 

Grant Bae brand. 

1 7. Grant Bae operates through a call center and a multifaceted online 

presence, including its website www.GrantBae.com, and presence on social media 

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sites, including Facebook, Instagram, and the audio-based platform Clubhouse. 

Defendants use these and other methods to communicate their claims to the public. 

18. Grant Bae markets two types of services: (1) securing grant funding for 

small businesses; and (2) business consulting to help grow small businesses. 

19. Grant Bae claims its services are "designed to help minority small 

businesses eliminate the stress and headache of running a small business with the 

lack of capital." 

20. In reality, Grant Bae causes minority business owners to lose time and 

money. 

Defendants' Deceptive Claims of Business and Grant Writing Expertise 

21. Defendant Graham holds herself out as an expert in securing grants for 

minority-owned small businesses. 

22. Defendant Graham uses her personal story to highlight this expertise, 

claiming that "After 10+ years as an entrepreneur and even with collateral the banks 

always said NO to funding for the expansion of my businesses. So I hit the ground 

running and begin [sic] my research for applying for grants." Defendant Graham 

represents that she has "been mastering this 'gift' for the past 8 years." 

23. Defendant Graham promotes her supposed experience and expertise on 

various forums designed to reach minority business owners. For example, Graham 

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promoted herself and Grant Bae's services at empowerment meetings held following 

the death of George Floyd, on Black news and media outlets like BlackNews.com, 

and on minority business affinity groups on social media, such as Black Girls in Real 

Estate on Facebook. 

24. Defendant Graham also associates herself and her services with 

influential figures in the entrepreneurship and entertainment world and has appeared 

in Clubhouse rooms with author and entrepreneur Grant Cardone and marketing 

coach "CEO Matty J." Graham additionally sat for an interview with Jason Lee of 

Hollywood Unlocked and collaborated on a "how to" article with Hello Alice. 

25. Contrary to Defendant Graham's false claims, she does not have 8 years 

of experience developing the "gift" of grant writing. In fact, she has little to no 

experience either writing grant applications or securing grant money. 

26. Further, Graham's last known employment was in late 2018 at a Krystal 

fast-food restaurant, and she pied guilty to two felony counts of theft as a result of 

stealing cash deposits from the restaurant. In January 2021, Graham began a threeyear term of probation for these offenses. 

27. On June 30, 2020, Defendant Graham filed Articles of Organization to 

establish Defendant C Lee Enterprises. Less than a month later, on July 22, 2020, C 

Lee Enterprises was approved for a forgivable $8,013 loan under the Paycheck 

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Protection Program ("PPP"), a government benefit designed to stabilize the payroll 

of businesses impacted by COVID-19. Graham was the sole employee of the 

company at the time. 

28. On August 5, 2020, Graham individually was approved for a $22,990 

PPP loan as an "independent contractor." 

29. Using the PPP loans, Defendants set up Grant Bae to deceptively 

market grant writing and consulting services, inducing nearly 100 minority-owned 

businesses to pay her thousands of dollars within just months. 

30. Defendant Graham later claimed to have over 8,200 clients by the end 

of calendar year 2021. 

31. Defendants' deceptive grant writing and consulting services were in 

large part funded through the proceeds of these PPP loans. 

Defendants Misrepresent Expected Results of Their Grant Writing Scheme to 

Consumers 

32. To entice small business owners to sign up for Grant Bae's grant 

writing service, Defendants make numerous false claims regarding the likelihood 

consumers will receive grant funding. 

33. For example, Defendants represent that any minority-owned business 

qualifies for grant funding of at least $25,000. 

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34. Defendants also "guarantee" consumers will receive a mm1mum 

amount of grant funding based upon the package chosen and after they make an 

upfront payment. 

35. The amount of the upfront fee and resulting "guaranteed" grant funding 

has changed over time. Most recently, Defendants guarantee the "Basic" package 

costing $1,799 will yield at least $25,000 in grant funds; the "Standard" package 

costing $2,699 will yield at least $50,000 in grant funds; the "Premium" package 

costing $4,499 will yield at least $100,000 in grant funds; and the "Elite" package 

costing $6,999 will yield at least $250,000 in grant funds. 

36. Grant Bae guarantees consumers would receive at least four grants over 

the course of one year. 

3 7. Defendant Graham also claims some consumers receive larger than 

expected grant proceeds, for instance stating, "You got people who sign up for the 

program for the $25,000 package and they are getting $120,000," or "I have people 

sign up for the $250,000 package, and they are almost at, you know, a half a million 

dollars in grant funding." 

38. On her Instagram page, Defendant Graham told consumers Grant Bae 

secured $32 million in funding during the three months preceding August 24, 2021, 

secured $75 million during calendar year 2021, and has 8,200 clients. 

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39. Defendant Graham also claims she has special access to $268 million 

in grant funds that she states Grant Bae will distribute to clients, for instance stating: 

"There's $268 million. It's going to be in conjunction with one ofmy financial teams 

that we're working with, and we're going to take that 268 and we're going to be able 

to disperse that throughout all of our great clients." 

40. To support their claims of "guaranteed" success, Defendants claim 

Grant Bae has a "top-tier team of grant writers," including "twelve grant writers who 

have a PhD," and that Grant Bae applies for numerous grants for which consumers 

are eligible. 

41. Moreover, Defendants claim to have "secured funding from" the Bill 

and Melinda Gates Foundation, the U.S. Small Business Administration, the Federal 

Communications Commission, and KKR, a global investment firm. 

42. In numerous instances, Defendants also represented to consumers that 

Grant Bae could and would apply on their behalf for funds, which would not have 

to be repaid, under the federal government's COVID-19 Economic Injury Disaster 

Loan ("EID L") program, and which is designed to provide financial support to small 

businesses impacted adversely by COVID-19. 

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43. Finally, Grant Bae purports to offer a "money-back guarantee." 

Defendant Graham said she "wholeheartedly stand[s] by the money back guarantee," 

which she said meant that Grant Bae presented "no risk" to prospective clients. 

Defendants Create a False Impression Among Consumers that They Have Been 

Awarded Grants and Will Receive Funds 

44. Defendants tell consumers interested in Grant Bae's grant service to 

schedule a 15-minute phone "consultation." Most recently Defendants advertised the 

fee for this call as $12. Defendants claim that during the consultation, consumers 

will learn what level of package they "qualify for." 

45. In some instances, consumers who pay for the initial phone consultation 

never receive the promised consultation at the appointed time and are unable to 

reschedule their consultation, yet their money is never refunded. 

46. Consumers who do connect with a Grant Bae representative and want 

to move forward select a package for which they are told they qualify. 

4 7. Defendants then provide these consumers with access to a portal where 

they are required to upload documentation, including articles of incorporation, 

business bank account information, the business's Employee Identification Number, 

and a mission statement describing what the money will be used for. 

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48. Defendants bill consumers for the upfront fee, which they typically 

must pay within a certain number of days. 

49. Defendants typically inform consumers their portal will be updated 

within 45 to 60 days to notify them they have been awarded grants and it takes on 

average 90 days to receive a deposit. 

50. Through email communications and updating consumers' portals, 

Defendants represent to consumers they have been "awarded" grants for specific 

amounts of money. 

51. Once a consumer's portal shows a grant has been awarded, the 

consumer is asked to verify they want to move forward with the grant. If they say 

yes, the grant is considered "pending" deposit. 

52. Defendants promise consumers it is only a matter of time before a 

pending grant will be fulfilled. For instance, Defendant Graham stated in an August 

2021 Instagram Live video, "Any time you are awarded a grant and it is the pending 

stage, the only thing that can stop that actually happening is whoever signed up for 

you to get that grant. So if you're just waiting for that grant to be deposited, rest 

assured your money is coming, is going to be deposited." 

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53. However, Defendants never deposit pending funds into consumers' 

accounts because Defendants claim funds are pending when they have not, in fact, 

secured any such grants. 

54. When consumers ask Grant Bae about the source of the "grant" awards 

shown in their portals to see if they could contact the source to learn more 

information, Defendants refuse to disclose that information. 

55. By the time consumers learn no money has been deposited in their 

accounts, it is typically outside the 60-to-90-day window that most financial 

institutions set to allow charge backs for fraudulent transactions. 

Defendants String Consumers Along with False Promises that Their Money Will 

Arrive Soon 

56. To reassure consumers about the status of their promised funds, 

Defendants make numerous false claims regarding the number of consumers who 

they say received funding from Grant Bae and when additional deposits will be 

made. 

57. For instance, on August 10, 2021, Defendant Graham claimed in an 

lnstagram Live video that 846 Grant Bae clients had been awarded grants on July 

19, 2021, and that over 700 of those actually received funds within five to seven 

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days, which Defendants say is the typical amount of time after a grant's "closing" 

date for clients to receive funds. 

58. Defendant Graham also stated during that video, "if you are waiting on 

your July 19th grant, you better understand that that funding is coming. Do not be 

alarmed, do not be frustrated .... Everyone will be funded through the Grant Bae 

portal. I promise you that." Graham further stated, "[i]f you have a pending grant 

with Grant Bae, please rest assured that those funds will be deposited into your 

business bank account." 

59. Funds Defendant Graham promised in the August 10, 2021 video did 

not materialize. 

60. In the fall of 2021, Defendant Graham moved the goal posts again, 

asserting Grant Bae clients would receive a substantial amount of their promised 

funds by the end of 2021. For instance, in a September 2, 2021, Instagram Live 

video, Defendant Graham stated that by the end of the year, "70% of your contract 

is going to be fulfilled." 

61. Later, in a January 25, 2022, Instagram Live video, Defendant Graham 

claimed consumers would receive their promised grants by the end of the first quarter 

of 2022. 

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62. Few, if any, consumers received the "guaranteed" funding Defendants 

promised. 

63. Using its own metrics, it is impossible for Grant Bae to deliver on its 

promises. 

64. As noted above, Grant Bae stated it employed twelve grant writers, 

claimed to have over 8,200 clients, and offered a base package guaranteeing it would 

obtain for each client at least 4 grants per year totaling at least $25,000 in grant 

funding per client. Even if every Grant Bae client purchased only the base package 

(many packages guaranteed more money), Grant Bae's twelve grant writers would 

have to write a minimum of 32,800 grants in a year in order to obtain the $205 

million dollars in "guaranteed" grant money. In other words, over the course of the 

year, each grant writer would need to draft 2,733 grants at a minimum-that is an 

average of 52.5 grant applications each week per grant writer. With anything less 

than a 100% success rate, each grant writer would need to prepare even more 

applications to yield the "guaranteed" funds. 

65. Typically, it takes an experienced grant writer a minimum of 15-25 

hours to write a grant application. Therefore, to write 52.5 grant applications per 

week, each grant writer would have to spend at least 788 hours per week writing 

grants, a physical impossibility given that there are only 168 hours in a week. 

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66. Defendants have provided money to only a select few people-social 

media influencers with large followings of potential Grant Bae clients, and those 

closely related to them. 

Defendants Deceptive Business Consulting Services 

67. Grant Bae also offers programs such as the "Longevity Pilot," which it 

claims is a "six month course of action that will allow clients to have access to 

different factors to secure their SUCCESS," including legal, accounting, branding, 

and consulting services. 

68. Existing Grant Bae clients paid $199, and potential Grant Bae clients 

paid $299, for the opportunity to be selected for the Longevity Pilot. 

69. In fact, Defendants do not operate a Longevity Pilot program that 

provides consumers with access to legal, accounting, branding, and consulting 

services. 

70. When confronted by consumers who have lost money, Defendants 

either go silent or block those consumers from communicating with them on social 

media. Defendant Graham herself acknowledges this practice, noting in a video, 

"I'm going to be one thousand percentage authentic with you guys. I will block 

anyone and everyone who feels that they are investing their money in a scam." 

71. Additionally, Grant Bae routinely rejects consumers' refund requests. 

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72. As a result of Defendants' conduct, consumers in numerous states have 

lost substantial sums of money, in some cases thousands of dollars each. 

73. Based on the facts and violations of law alleged in this Complaint, the 

FTC has reason to believe Defendants are violating or are about to violate laws 

enforced by the Commission, including that: 

a) Defendants have continued to promise non-existent grant 

funding in exchange for payment; 

b) Defendants continued their unlawful acts or practices despite 

knowledge of numerous complaints; 

c) Defendants engaged in their unlawful acts and practices 

knowingly; 

d) Defendant Graham has a history of dishonest conduct-stealing 

cash deposits from her former employer-that resulted in a three-year 

term of probation; and 

e) Defendants continue to advertise grant writing services on their 

website. 

VIOLATIONS OF THE FTC ACT 

74. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits "unfair or 

deceptive acts or practices in or affecting commerce." 

75. Misrepresentations or deceptive omissions of material fact constitute 

deceptive acts or practices prohibited by Section 5(a) of the FTC Act. 

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76. On January 31, 2020 the Secretary of Health and Human Services, 

pursuant to his authority under Section 319 of the Public Health Service Act, 

declared that COVID-19 had caused a public health emergency. As of the date of 

this filing, this public health emergency declaration remains in effect. 

77. For the duration of the ongoing COVID-19 public health emergency, 

the COVID-19 Consumer Protection Act makes it unlawful for any person, 

partnership, or corporation to engage in a deceptive act or practice in or affecting 

commerce in violation of Section 5(a) of the FTC Act, 15 U.S.C. 45(a), that is 

associated with a government benefit related to COVID-19. 15 U.S.C. § 45 note 

(CCPA § 1401(b)(2)). 

78. Pursuant to Section 1401(c)(l) of the CCPA, 15 U.S.C. § 45 note 

(CCPA § 1401(c)(l)), a deceptive act or practice in violation of Section 5(a) of the 

FTC Act, as described in Section 1401 (b) of the CCP A is treated as a violation of a 

rule defining an unfair or deceptive act or practice prescribed under Section 

18(a)(l)(B) of the FTC Act, 15 U.S.C. § 57a(a)(l)(B). Section 140l(c)(2) of the 

CCPA, 15 U.S.C. § 45 note (CCPA § 1401(c)(2)), provides that the FTC "shall 

enforce" the CCP A in "the same manner, by the same means, and with the same 

jurisdiction, powers, and duties as though all applicable terms and provisions of the 

Federal Trade Commission Act (15 U.S.C. 41 et seq.) were incorporated into and 

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made a part of this Act." Section 19(a)(l) of the FTC Act, 15 U.S.C. § 57b(a)(l), 

provides that the FTC may commence a civil action against "any person, partnership, 

or corporation" who "violates any rule ... respecting unfair or deceptive acts or 

practices." Section 19 of the FTC Act, 15 U.S.C. § 57b, and Section 1401(c)(l) of 

the CCP A authorize this Court to grant such relief as the Court finds necessary to 

redress injury to consumers resulting from Defendants' violations of the CCP A, 

including the rescission or reformation of contracts, and the refund of money. 

79. Pursuant to the Coronavirus Aid, Relief, and Economic Security Act of 

2020 ("CARES Act"), Public Law 116-136 §§ 1107 & 1110, and the 2021 

Consolidated Appropriations Act, Public Law 116-260 §§ 323 & 331-33, the U.S. 

Small Business Administration is authorized to provide eligible small businesses 

suffering from COVID-19-related economic loss with both repayable and 

nonrepayable loans and grants. These government benefits are provided through the 

COVID-19 Economic Injury Disaster Loan ("EIDL") program, the Targeted EIDL 

Advance and Supplemental Targeted Advance program, and related programs. 

80. Pursuant to the CARES Act, Public Law 116-136 §§1102 & 1106, the 

Small Business administration is authorized under the Paycheck Protection Program 

(PPP) to provide eligible businesses with forgivable loans designed to avoid payroll 

reductions during COVID-19-related economic uncertainty. 

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Count I 

(By Plaintiff FTC) 

81. In numerous instances in connection with the advertising, marketing, 

promotion, offering for sale, or sale of consulting or grant writing services, 

Defendants represent, directly or indirectly, expressly or by implication, that: 

a. Defendants guarantee Grant Bae clients will receive grant 

funding; 

b. Defendants guarantee any minority-owned business will receive 

a minimum of$25,000 in grant funding; 

c. Defendants secured $32 million in grant funding between May 

24, 2021, and August 24, 2021; 

d. Defendants secured $7 5 million in grant funding during calendar 

year 2021; 

e. most Grant Bae clients will receive funds within five to seven 

days of a grant's "closing" date; 

f. Defendants provide a "money-back guarantee"; 

g. Defendants operate a Longevity Pilot program that provides 

consumers access to legal, accounting, branding, and consulting 

services; and 

h. Defendants will apply for EIDL funds for clients. 

82. In truth and in fact, in numerous instances in which Defendants have 

made the representations set forth in Paragraph 81: 

a. Grant Bae's clients do not receive grant funding; 

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b. minority-owned businesses do not receive a m1mmum of 

$25,000 in grant funding; 

c. Defendants did not secure $32 million in grant funding between 

May 24, 2021, and August 24, 2021; 

d. Defendants did not secure $75 million in grant funding during 

calendar year 2021; 

e. most Grant Bae clients do not receive funds within five to seven 

days of a grant's "closing" date; 

f. Defendants do not provide consumers' money back when 

requested; 

g. Defendants do not operate a Longevity Pilot program that 

provides consumers access to legal, accounting, branding, and 

consulting services; and 

h. Defendants did not apply for EIDL funds for clients. 

83. On or after December 27, 2020 Defendants made the representations 

set forth in paragraph 81, which are associated with one or more government benefits 

related to COVID-19. 

84. The representations set forth in Paragraph 81 are false, misleading, or 

were not substantiated at the time the representations were made. 

85. Therefore, Defendants' representations as set forth in Paragraph 81 

constitute deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 

U.S.C. § 45(a). 

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VIOLATIONS OF THE FLORIDA DECEPTIVE AND 

UNFAIR TRADE PRACTICES ACT 

86. Section 501.204(1), Florida Statutes, declares that "unfair or deceptive 

acts or practices in the conduct of any trade or commerce are hereby declared 

unlawful." 

87. Section 501.203(8), Florida statutes, defines "trade or commerce" as: 

the advertising, soliciting, providing, offering, or distributing, whether by 

sale, rental or otherwise, of any good or service, or any property, whether 

tangible or intangible, or any other article, commodity, or thing of value, 

wherever situated. "Trade or commerce" shall include the conduct of any trade 

or commerce, however denominated, including any nonprofit or not-for-profit 

person or activity. 

88. The provisions of FDUTPA shall be "construed liberally" to promote 

and "protect the consuming public and legitimate business enterprises from those 

who engage in unfair methods of competition, or unconscionable, deceptive or unfair 

acts or practices in the conduct of any trade or commerce." Section 501.202, Florida 

Statutes. 

89. A person that willfully engages in a deceptive or unfair act or practice 

is liable for a civil penalty of Ten Thousand Dollars ($10,000) for each such 

violation, pursuant to Section 501.2075, Florida Statutes, and Fifteen Thousand 

Dollars ($15,000) for each violation victimizing a senior citizen or a person who has 

a disability or that is directed at a military servicemember, pursuant to Section 

23 

Case 3:22-cv-00655-MMH-JBT Document 1 Filed 06/13/22 Page 23 of 30 PageID 23 
501.2077, Florida Statutes. Willful violations occur when a person knew or should 

have known that the conduct in question was deceptive or unfair or prohibited by 

rule, pursuant to Section 501.2075, Florida Statutes." 

Count II 

(By Plaintiff Florida Attorney General) 

90. Plaintiff, State of Florida, adopts and incorporates herein, and re-alleges 

Paragraphs 11 through 73 above, which allegations are incorporated as if set forth 

herein, and further alleges: 

91. In the course of Defendants' trade or commerce, Defendants have 

committed acts or practices that are unfair or deceptive in violation of the FDUTPA. 

92. In numerous instances in connection with the advertising, marketing, 

promotion, offering for sale, or sale of services related to grant writing and business 

consulting services, including through the means described in Paragraphs 11 through 

73 above, Defendants misrepresent, directly or indirectly, expressly or by 

implication, that: 

a. Defendants guarantee Grant Bae clients will receive grant 

funding; 

b. Defendants guarantee any minority-owned business will receive 

a minimum of$25,000 in grant funding; 

c. Defendants secured $32 million in grant funding between May 

24, 2021, and August 24, 2021; 

24 

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d. Defendants secured $7 5 million in grant funding during calendar 

year 2021; 

e. most Grant Bae clients will receive funds within five to seven 

days of a grant's "closing" date; 

f. Defendants provide a "money-back guarantee"; 

g. Defendants operate a Longevity Pilot program that provides 

consumers access to legal, accounting, branding, and consulting 

services; and 

h. Defendants will apply for EIDL funds for clients. 

93. Defendants' representations set forth in Paragraph 92 are false and 

misleading and were not substantiated at the time that the representations were made. 

94. The making of the false representations set forth in Paragraph 92 

constitute a deceptive act or practice in violation of Section 501.204( 1 ), Florida 

Statutes. 

95. Graham is personally liable for the unlawful acts and practices of 

Corporate Defendant Grant Bae as Graham has the authority and power to control 

or direct the conduct at issue herein and/or actually participated in and directed the 

conduct at issue herein. 

96. Grant Bae and Graham are subject to civil penalties for willful violation 

of FDUTPA in the amount of Ten Thousand Dollars ($10,000) for each violation 

25 

Case 3:22-cv-00655-MMH-JBT Document 1 Filed 06/13/22 Page 25 of 30 PageID 25 
pursuant to Section 501.2075, Florida Statutes, and Fifteen Thousand Dollars 

($15,000) for each violation that victimized or attempted to victimize a senior citizen 

or person who has a disability pursuant to Section 501.2077, Florida Statutes. 

97. The above-described acts and practices of Grant Bae and Graham have 

injured and will likely continue to injure and prejudice the public. 

98. The acts and practices of Grant Bae and Graham as set forth herein are 

misleading or deceptive and likely to mislead consumers acting reasonably, and 

consumers within the State of Florida and elsewhere were actually misled by the acts 

and practices of Defendants Grant Bae and Graham recited herein. 

99. Defendants Grant Bae and Graham have willfully engaged in the acts 

and practices alleged herein when they knew or should have known that such acts 

and practices were unfair or deceptive or otherwise prohibited by law. 

100. Unless Defendants Grant Bae and Graham are permanently enjoined 

from engaging further in the acts and practices complained of herein, Defendants' 

actions will result in irreparable injury to the public for which there is no adequate 

remedy at law. 

CONSUMER INJURY 

101. Consumers are suffering, have suffered, and will continue to suffer 

substantial injury as the result of Defendants' violations of the FTC Act, the CCP A, 

26 

Case 3:22-cv-00655-MMH-JBT Document 1 Filed 06/13/22 Page 26 of 30 PageID 26 
and the FDUTPA. Absent injunctive relief and other relief by this Court, Defendants 

are likely to continue to injure consumers and harm the public interest. 

PRAYER FOR RELIEF 

Wherefore, Plaintiffs, the FTC, pursuant to Sections 13(b) and 19 of the FTC 

Act, 15 U.S.C. §§ 53(b) and 57b, and Section 140l(c)(l) of the CCPA, and the 

Court's own equitable powers; and the State of Florida, pursuant to the Florida 

Deceptive and Unfair Trade Practices Act, Chapter 501, Part II, Florida Statutes, and 

the Court's own equitable powers, respectfully request that the Court: 

A. Enter a permanent injunction to prevent future violations of the FTC 

Act and the CCP A by Defendants in accordance with Section 13 (b) of the FTC Act, 

15 U.S.C. § 53(b); 

B. Grant preliminary injunctive and ancillary relief as may be necessary 

to avert the likelihood of consumer injury during the pendency of this action and to 

preserve the possibility of effective final relief, including, but not limited to, 

temporary and preliminary injunctions; an order freezing Defendants' assets; the 

appointment of a receiver; immediate access to Defendants' business premises and 

documents; and an accounting of assets; 

C. Award monetary and other relief within the Court's power to grant, 

including, but not limited to, rescission or reformation of contracts, the refund of 

27 

Case 3:22-cv-00655-MMH-JBT Document 1 Filed 06/13/22 Page 27 of 30 PageID 27 
money, the return of property, public notification, or other relief necessary to redress 

injury to consumers resulting from Defendants' violations of the FTC Act and the 

CCPA in accordance with Section 19 of the FTC Act, 15 U.S.C. § 57b; 

D. Award Plaintiff, State of Florida, Final Judgment against Defendants, 

jointly and severally, ordering full restitution to consumers harmed by Defendants' 

unfair and deceptive acts in violation of FDUTP A; disgorgement; repatriation of 

assets to satisfy any judgment; and any other relief deemed appropriate pursuant to 

Section 501.207(3), Florida Statutes; 

E. Assess against Defendants, jointly and severally, civil penalties in the 

amount of Ten Thousand Dollars ($10,000) for each violation of FDUTP A in 

accordance with Section 501.2075, Florida Statutes, and Fifteen Thousand Dollars 

($15,000) for each violation that victimized or attempted to victimize a senior citizen 

or person who has a disability in accordance with Section 501.2077, Florida Statutes; 

F. Permanently enjoin Defendants, their officers, agents, servants, 

employees, attorneys, and those persons in active concert or participation with them, 

who receive actual notice of the injunction, from engaging in the acts and practices 

in violation of FDUTPA as specifically alleged above and any similar acts and 

practices relating to the relaying of false or misleading statements to consumers; 

28 

Case 3:22-cv-00655-MMH-JBT Document 1 Filed 06/13/22 Page 28 of 30 PageID 28 
G. Award Plaintiff, State of Florida, reasonable attorney's fees and costs 

pursuant to the provisions of Sections 501.2105 and 501.2075, Florida Statutes, and 

as otherwise allowable by applicable statutes or law; 

H. Award Plaintiff, State of Florida, such other and further relief as the 

Court deems just and proper, including all equitable relief allowed pursuant to 

Sectio~ 501.207(3), Florida Statutes; and 

I. Award any additional relief as the Court determines to be just and 

proper. 

Dated: June, 13, 2022 

Respectfully submitted, 

Miriam Lederer 

Daniel Wilkes 

Federal Trade Commission 

600 Pennsylvania Avenue, N.W. 

Mail Drop CC-9528 

Washington, D.C. 20580 

(202) 326-2975 (Lederer), -3679 (Wilkes) 

mlederer@ftc.gov; dwilkes@ftc.gov 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

29 

Case 3:22-cv-00655-MMH-JBT Document 1 Filed 06/13/22 Page 29 of 30 PageID 29 
Dated: June, 13, 2022 

ASHLEY MOODY 

Attorney General State of Florida 

Isl Carol E.A. DeGraffenreidt 

Carol E.A. DeGraffenreidt 

Office of the Attorney General 

Consumer Protection Division 

1300 Riverside Boulevard, Suite 405 

Jacksonville, FL 32207 

Carol.DeGraffenreidt@myfloridalegal.com 

Attorney for Plaintiff 

OFFICE OF THE ATTORNEY GENERAL 

STATE OF FLORIDA DEPARTMENT OF 

LEGAL AFFAIRS 

30 

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JS 44 (Rev. 04/21)Case 3:22-cv-00655-MMH-JBT Document 1-1 Filed 06/13/22 Page 1 of 3 PageID 31 CIVIL COVER SHEET

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as 

provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the

purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS

Please see attached Complaint header

(b) County of Residence of First Listed Plaintiff

(EXCEPT IN U.S. PLAINTIFF CASES)

(c) Attorneys (Firm Name, Address, and Telephone Number)

See attachment

DEFENDANTS

Please see attached Complaint header

County of Residence of First Listed Defendant Columbia County

(IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF

THE TRACT OF LAND INVOLVED.

Attorneys (If Known)

II. BASIS OF JURISDICTION (Place an “X” in One Box Only)

1 U.S. Government 3 Federal Question

Plaintiff (U.S. Government Not a Party)

2 U.S. Government 4 Diversity

Defendant (Indicate Citizenship of Parties in Item III)

III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff

(For Diversity Cases Only) and One Box for Defendant)

PTF DEF PTF DEF

Citizen of This State 1 1 Incorporated or Principal Place 4 4

of Business In This State

Citizen of Another State 2 2 Incorporated and Principal Place 5 5

of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country

IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.

CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act

120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC

130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))

140 Negotiable Instrument Liability 367 Health Care/ 400 State Reapportionment

150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust

& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking

151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce

152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent - Abbreviated 460 Deportation

Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer Influenced and

(Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations

153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR 880 Defend Trade Secrets 480 Consumer Credit

of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards Act of 2016 (15 USC 1681 or 1692)

160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 485 Telephone Consumer

190 Other Contract Product Liability 380 Other Personal 720 Labor/Management SOCIAL SECURITY Protection Act

195 Contract Product Liability 360 Other Personal Property Damage Relations 861 HIA (1395ff) 490 Cable/Sat TV

196 Franchise Injury 385 Property Damage 740 Railway Labor Act 862 Black Lung (923) 850 Securities/Commodities/

362 Personal Injury - Product Liability 751 Family and Medical 863 DIWC/DIWW (405(g)) Exchange

Medical Malpractice Leave Act 864 SSID Title XVI 890 Other Statutory Actions

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation 865 RSI (405(g)) 891 Agricultural Acts

210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 893 Environmental Matters

220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act FEDERAL TAX SUITS 895 Freedom of Information

230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act

240 Torts to Land 443 Housing/ Sentence or Defendant) 896 Arbitration

245 Tort Product Liability Accommodations 530 General 871 IRS—Third Party 899 Administrative Procedure

290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION Act/Review or Appeal of

Employment Other: 462 Naturalization Application Agency Decision

446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration 950 Constitutionality of

Other 550 Civil Rights Actions State Statutes

448 Education 555 Prison Condition

560 Civil Detainee -

Conditions of 

Confinement

26 USC 7609

INTELLECTUAL

V. ORIGIN (Place an “X” in One Box Only)

1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 8 Multidistrict

Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -

(specify) Transfer Direct File

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

FTC Act 15 USC §§ 53(b) and 57b; CCPA 15 USC § 45 note § 1401(c)(1); FDUPTA Chapter 501, Part II, Florida Statutes

VI. CAUSE OF ACTION Brief description of cause:

Grant writing & business consulting scheme engaged in illegal and deceptive practices with COVID relief funds.

VII. REQUESTED IN

COMPLAINT:

VIII. RELATED CASE(S)

IF ANY

CHECK IF THIS IS A CLASS ACTION

UNDER RULE 23, F.R.Cv.P.

(See instructions):

JUDGE

DEMAND $ CHECK YES only if demanded in complaint:

JURY DEMAND: Yes No

DOCKET NUMBER

DATE

June 13, 2022

FOR OFFICE USE ONLY

SIGNATURE OF ATTORNEY OF RECORD

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE
UNITED STATES DISTRICT COURT 

MIDDLE DISTRICT OF FLORIDA 

FEDERAL TRADE COMMISSION, and 

OFFICE OF THE ATTORNEY 

GENERAL, 

STATE OF FLORIDA, 

DEPARTMENT OF LEGAL AFFAIRS, 

Plaintiffs, 

v. 

TREASHONNA P. GRAHAM, a/k/a 

SHONNA GRAHAM, a/k/a 

TREASHONNA LEE WILLIAMS, a/k/a 

SHONNA LEE WILLIAMS, also d/b/a 

TheGRANTBAE,GRANTBAE,and 

GRANT BAE CONSUL TING AND 

MORE, individually and as a member, 

manager, or owner ofC LEE 

ENTERPRISES LLC, and 

C LEE ENTEPRISES LLC, a Florida 

limited liability company, also d/b/a 

GRANTBAEandGRANTBAE 

CONSULTING AND MORE, 

Defendants. 

Case No. -----

COMPLAINT FOR 

PERMANENT INJUNCTION, 

MONETARY RELIEF, AND 

OTHER RELIEF 

Plaintiffs, the Federal Trade Commission ("FTC"), and the Office of the 

Attorney General, State of Florida, Department of Legal Affairs ("Florida Attorney 

General") for their Complaint allege: 

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List of Attorneys:

Attorneys for Plaintiff Federal Trade Commission

Miriam Lederer

Tel: 202-326-2975

Fax: 202-326-3768

Email: mlederer@ftc.gov

FEDERAL TRADE COMMISSION

600 Pennsylvania Avenue NW, CC 9528

Washington, DC 20580

Daniel Wilkes

Tel: 202-326-3679

Fax: 202-326-3768

Email: dwilkes@ftc.gov

FEDERAL TRADE COMMISSION

600 Pennsylvania Avenue NW, CC 9528

Washington, DC 20580

Attorney for Plaintiff Office Of The Attorney General

Carol E.A. DeGraffenreidt

Tel: 904-456-6519

Fax: 904-838-6183

Email: Carol.DeGraffenreidt@myfloridalegal.com

OFFICE OF THE ATTORNEY GENERAL

Consumer Protection Division

1300 Riverside Boulevard, Suite 405

Jacksonville, FL 32207