UNITED STATES V. $32,381.00 IN UNITED STATES CURRENCY: 

VERIFIED COMPLAINT FOR FORFEITURE IN REM PAGE 1

 IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

BEAUMONT DIVISION 

UNITED STATES OF AMERICA, § 

Plaintiff, § 

§ 

v. § No. 1:23-CV-00044

§ 

$32,381.00 IN UNITED STATES, § 

CURRENCY, § 

Defendant. § 

VERIFIED COMPLAINT FOR FORFEITURE

In accordance with Fed. R. Civ. P. Supplemental Rule G(2), the United 

States of America, Plaintiff, brings this complaint for forfeiture and alleges as 

follows: 

NATURE OF ACTION 

1. This matter is an in rem action brought against the following

defendant property: $32,381.00 in United States currency seized on July 31, 

2022. 

JURISDICTION AND VENUE 

2. The Court has subject matter jurisdiction over an action

commenced by the United States pursuant to 28 U.S.C. § 1345 and over an 

action for forfeiture pursuant to 28 U.S.C. § 1355(a). 

Case 1:23-cv-00044-MJT-CLS Document 1 Filed 01/31/23 Page 1 of 17 PageID #: 1
UNITED STATES V. $32,381.00 IN UNITED STATES CURRENCY:

VERIFIED COMPLAINT FOR FORFEITURE IN REM PAGE 2

3. The Court has in rem jurisdiction over the defendant property 

pursuant to 28 U.S.C. § 1355(b)(1)(A) because acts or omissions giving rise to 

the forfeiture occurred in the Eastern District of Texas. 

4. Venue is proper pursuant to 28 U.S.C. §1355(b)(1)(A) because 

acts or omissions giving rise to the forfeiture occurred in the Eastern District 

of Texas.

THE PAYCHECK PROTECTION PROGRAM

5. The Coronavirus Aid, Relief, and Economic Security (“CARES”) 

Act was a federal law enacted in March 2020 and designed to provide 

emergency financial assistance to the millions of Americans who are suffering 

the economic effects caused by the COVID-19 pandemic. One source of relief 

provided by the CARES Act was the authorization of forgivable loans to small 

businesses for job retention and certain other expenses, through a program 

referred to as the Paycheck Protection Program (“PPP”). 

6. 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 

Case 1:23-cv-00044-MJT-CLS Document 1 Filed 01/31/23 Page 2 of 17 PageID #: 2
UNITED STATES V. $32,381.00 IN UNITED STATES CURRENCY:

VERIFIED COMPLAINT FOR FORFEITURE IN REM PAGE 3

rules and make certain affirmative certifications in order to be eligible to 

obtain the PPP loan. In the PPP loan application (SBA Form 2483), the 

small business (through its authorized representative) was required 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 is eligible to receive under the PPP. In addition, 

businesses applying for a PPP loan were required to provide documentation 

showing their payroll expenses. 

7. A PPP loan application was processed by a participating lender. 

If a PPP loan application was approved, the participating lender funded the 

PPP loan using its own monies, which were guaranteed by the Small 

Business Administration (“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. 

8. PPP loan proceeds were required to be used on certain 

permissible expenses, including payroll costs, mortgage interest, rent, and 

utilities. Under the applicable PPP rules and guidance, the interest and 

Case 1:23-cv-00044-MJT-CLS Document 1 Filed 01/31/23 Page 3 of 17 PageID #: 3
UNITED STATES V. $32,381.00 IN UNITED STATES CURRENCY: 

VERIFIED COMPLAINT FOR FORFEITURE IN REM PAGE 4

principal on the PPP loan is eligible for forgiveness if the business spent the 

loan proceeds on these expense items within a designated period of time and 

used a certain portion of the loan towards payroll expenses.

FACTUAL BACKGROUND 

9. On August 1, 2022, Homeland Security Investigations Office of 

the Resident Agent in Charge Beaumont, Texas (“HSI Beaumont”) received 

an investigative referral from the Beaumont Police Department (“BPD”) 

regarding a July 31, 2022, encounter with Artisha Gabriella Dimetrika 

Martin in Beaumont. 

July 31, 2022 BPD Traffic Stop of Martin Results in Seizures 

10. On July 31, 2022, BPD conducted a traffic stop on Interstate-10 

of a four-door gray in color Toyota Camry bearing Texas license plate KMW8455. The Toyota Camry was occupied by Martin and two minor children. 

Law enforcement records revealed that the Toyota Camry was registered to 

Martin at a residence in Baytown, Texas. 

11. During the traffic stop, Martin provided BPD a fictious State of 

New Jersey driver’s license that depicted a photograph of Martin and the 

name “Rikkita Jones.” Martin also provided BPD with a fictious social 

Case 1:23-cv-00044-MJT-CLS Document 1 Filed 01/31/23 Page 4 of 17 PageID #: 4
UNITED STATES V. $32,381.00 IN UNITED STATES CURRENCY:

VERIFIED COMPLAINT FOR FORFEITURE IN REM PAGE 5

security number. During the encounter, Martin told BPD that she had been 

a resident of New Jersey approximately six (6) months preceding the 

encounter and stated that she was a resident of Baytown. Law enforcement

databases did not reveal any data and/or information regarding Martin’s 

claimed New Jersey residency.

12. During the traffic encounter with Martin, BPD observed raw 

marijuana and bulk United States currency in plain sight near the front 

passenger area of the Toyota Camry. BPD conducted a probable cause search 

of the Toyota Camry. As a result of the search, BPD seized $32,381.00 in 

bulk cash that is the subject of this civil forfeiture complaint. BPD also 

seized a total of 38 money orders valued at $22,500.00,1 27 financial records 

and bank cards issued to 27 other people who were not present during the 

traffic encounter, four laptop computers, and eleven cellular telephones. BPD 

also discovered and seized Martin’s State of Louisiana identification card that 

depicted a photograph of Martin and her true and correct biographical 

information, Martin’s business records, Martin’s Bank of America financial 

1 These were comprised of nine (9) Rouses Money Orders; twenty-eight (28) Winn 

Dixie Western Union Money Orders; and one (1) Wal-Mart Western Union Money Order.

These money orders were not issued to a specific party, which means they could have been 

endorsed and cashed by any party who physically possessed the financial instruments.

Case 1:23-cv-00044-MJT-CLS Document 1 Filed 01/31/23 Page 5 of 17 PageID #: 5
UNITED STATES V. $32,381.00 IN UNITED STATES CURRENCY: 

VERIFIED COMPLAINT FOR FORFEITURE IN REM PAGE 6

records, and a ledger that contained numerous names, addresses, and bank 

account information for other individuals. 

August 1, 2022 Interview of Martin by BPD 

13. On August 1, 2022, BPD interviewed with Martin. During the 

interview, Martin provided her true and correct biographical information. 

She claimed that she was traveling from Louisiana to Baytown when she was 

pulled over the day prior. 

14. During the interview, Martin claimed to be a rap artist, 

entrepreneur, and Certified Nursing Assistant. She said she owned a 

consulting business called “Generational Wealth Empire Development, LLC”, 

a business she used to conduct consultation services and tax preparation 

services. Martin stated that her business-related fees ranged from $3,000.00 

to $9,000.00 per consultation and stated that she sourced clientele from social 

media platforms. She also claimed to own an apparel company called 

“Artymar Collection/Artymar of Fashion.” 

15. When pressed by BPD about the source of the bulk cash, Martin 

made inconsistent statements for the source of the funds. For example, she 

said that $16,000 of the bulk cash came from her 2021 tax refund of $23,000. 

Case 1:23-cv-00044-MJT-CLS Document 1 Filed 01/31/23 Page 6 of 17 PageID #: 6
UNITED STATES V. $32,381.00 IN UNITED STATES CURRENCY: 

VERIFIED COMPLAINT FOR FORFEITURE IN REM PAGE 7

In other parts of the interview, Martin stated she had only made $50,000 in 

2021. A tax refund of $23,000 would have been 46% of her entire selfreported 2021 income. That’s not how income taxes work. 

16. Martin also claimed that she was in possession of others’ bank 

cards because her clientele had purportedly allowed Generational Wealth 

Empire Development, LLC to charge fees associated with tax preparation 

consultation services and tax filings. Martin admitted that she opened up 

bank accounts using her clients’ personal identifying information. 

17. Following the interview, BPD arrested Martin for felony identity 

theft under Texas law. BPD obtained search warrants for all four of Martin’s 

cellular telephones and extracted that data through a certified forensic 

examiner. 

18. BPD referred the case to HSI Beaumont for further investigation. 

Subsequent Law Enforcement Efforts

19. To facilitate its investigation, HSI Beaumont took possession of 

all relevant evidence from BPD. 

20. A review of the Apple iPhone cellular telephones seized from 

Martin revealed thousands of stored photographs and videos of Martin; 

Case 1:23-cv-00044-MJT-CLS Document 1 Filed 01/31/23 Page 7 of 17 PageID #: 7
UNITED STATES V. $32,381.00 IN UNITED STATES CURRENCY:

VERIFIED COMPLAINT FOR FORFEITURE IN REM PAGE 8

furthermore, law enforcement databases revealed that the cellular telephone 

numbers associated with the Apple iPhone cellular phones were registered to 

or previously registered to Martin. 

21. The investigation revealed that in 2021, Martin orchestrated an 

elaborate scheme to defraud the United States through the exploitation of 

federal funding allocated to small businesses in an effort to combat the 

negative economic impact caused by the COVID-19 pandemic. The 

investigation revealed that Martin and others made false entries on IRS 

financial records, provided inflated and false business revenue data, created 

fraudulent bank statements for legitimate Federal Deposit Insurance 

Corporation financial accounts, and created sham businesses and sole 

proprietorships to facilitate the processing and funding of fraudulent 

Paycheck Protection Program, hereinafter referred to as “PPP” loan 

applications.

22. The investigation revealed that Martin and more than one 

hundred (100) other individuals in the Eastern District of Texas and in other

states conspired to commit loan fraud through the filing of more than onehundred fifty (150) fraudulent PPP loan applications. The investigation 

Case 1:23-cv-00044-MJT-CLS Document 1 Filed 01/31/23 Page 8 of 17 PageID #: 8
UNITED STATES V. $32,381.00 IN UNITED STATES CURRENCY:

VERIFIED COMPLAINT FOR FORFEITURE IN REM PAGE 9

revealed that through Martin’s efforts and those of others, the criminal 

network fraudulently procured approximately $3.2 million dollars in PPP 

loan funding between February 2021 and June 2021. 

23. The investigation revealed that Martin and co-conspirators 

committed wire fraud and bank fraud through the utilization of various 

financial institutions to facilitate domestic wire transfers and utilized peerto-peer financial services to facilitate the transfer of fraudulently procured 

PPP loan funding. The investigation revealed that Martin provided coconspirators instructions on how to properly structure transactions 

associated with the fraudulent PPP loan funds, and how to successfully 

acquire forgiveness of the PPP loans. 

24. The investigation revealed that between May 2022 and August 

2022, Martin used social media to promote a tax fraud scheme. Martin used 

Generational Wealth Empire Development to promote the tax fraud scheme. 

The investigation revealed that Martin and more than one hundred (100) 

others in the Eastern District of Texas and in other states conspired to 

commit tax fraud through the filing of fraudulent IRS tax return documents. 

The investigation revealed that the criminal network procured approximately 

Case 1:23-cv-00044-MJT-CLS Document 1 Filed 01/31/23 Page 9 of 17 PageID #: 9
UNITED STATES V. $32,381.00 IN UNITED STATES CURRENCY:

VERIFIED COMPLAINT FOR FORFEITURE IN REM PAGE 10

$2.2 million dollars in tax refund funding between May 2022 and August 

2022. 

25. The investigation revealed that Martin guaranteed her clientele 

upwards of $29,000.00 tax refunds regardless of their tax filing status or 

employment status. Martin admitted to BPD that she would charge a fee of 

$9,000.00 to $10,000.00 upon successful funding of these bogus tax returns. 

Martin offered to compensate her clientele between $1,500.00 and $2,000.00 

for successfully recruiting additional clientele to participate in the criminal 

conspiracy. 

26. The investigation further revealed that Martin used a weblink 

associated with her company Generational Wealth Empire Development to 

source the following information from her clientele: first name, last name, 

social security number, email address, residential address, bank name, 

account number, routing number, ID.me username and password, and Stateissued identification documents. Martin subsequently used the sourced 

information to prepare/file fraudulent tax related documents.

27. The investigation revealed that Martin’s Apple iPhones contained 

stored copies of co-conspirator’s IRS Form 1040 – U.S. Individual Income Tax 

Case 1:23-cv-00044-MJT-CLS Document 1 Filed 01/31/23 Page 10 of 17 PageID #: 10
UNITED STATES V. $32,381.00 IN UNITED STATES CURRENCY:

VERIFIED COMPLAINT FOR FORFEITURE IN REM PAGE 11

Returns, and stored IRS online refund tracking portal weblinks that 

contained co-conspirators’ personal identifying information. The 

investigation revealed that Martin used similar data entries on others’ tax 

documents to ensure each client received a tax refund in excess of $20,000.00

regardless of whether they were actually entitled to receive such a refund.

28. The investigation revealed that Martin engaged in a scheme to 

fraudulently create bank accounts with co-conspirator’s biographical 

information. Martin primarily created the accounts with GO2BANK. The 

investigation revealed that Martin chose GO2BANK because the financial 

institution permits up to $9,000.00 daily withdrawals. The investigation 

revealed that Martin routed the bank cards associated with her clients’ newly 

created accounts to addresses associated with Martin in Texas and 

Louisiana. The investigation revealed that Martin conspired with relatives 

to receive the bank cards. Upon receipt of the bank cards and notification 

that the tax refunds were deposited into the newly created accounts, Martin

used others’ bank cards to withdraw her compensation. 

29. The investigation revealed that Martin used various money 

service businesses, namely Western Union and Rouses to purchase money 

Case 1:23-cv-00044-MJT-CLS Document 1 Filed 01/31/23 Page 11 of 17 PageID #: 11
UNITED STATES V. $32,381.00 IN UNITED STATES CURRENCY:

VERIFIED COMPLAINT FOR FORFEITURE IN REM PAGE 12

orders with a cash value between $500.00 and $1,000.00. Martin traveled to 

various stores and purchased money orders until she accumulated her tax 

preparation fees of $9,000.00 to $10,000.00. The investigation revealed that 

Martin made these withdrawals without her clients’ knowledge. The 

investigation revealed that Martin committed mail fraud by subsequently 

mailing the clients their newly acquired bank cards following the withdrawal 

of her tax preparation fees. 

30. The investigation revealed that on an occasion, Martin utilized 

one of the co-conspirator’s GO2BANK accounts to transfer $7,500.00 to her 

Artymar Collection/Artymar of Fashion business account. 

31. The investigation revealed that Martin sent co-conspiring 

clientele photographs of money order purchases that were purchased with 

their newly acquired bank cards. The investigation revealed that Martin did 

this to appear transparent to her clientele about how she paid herself their 

tax preparation fees. 

32. The investigation revealed that Martin’s Apple iPhones contained 

identifying documents for more than one hundred (100) co-conspirators, 

Case 1:23-cv-00044-MJT-CLS Document 1 Filed 01/31/23 Page 12 of 17 PageID #: 12
UNITED STATES V. $32,381.00 IN UNITED STATES CURRENCY:

VERIFIED COMPLAINT FOR FORFEITURE IN REM PAGE 13

photographs and videos of bulk United States currency, checks, cashier’s 

checks, and money orders. 

33. The investigation revealed that between 2021 and 2022, Martin

used several financial institutions, including Bank of America, to commit 

money laundering and/or conduct an unlicensed money transmitting 

business. Martin instructed co-conspirators to transfer funds to her Bank of 

America business account and personal account to satisfy payment for her 

services on their behalf in conducting various financial fraud schemes. 

Martin also instructed co-conspirators to compensate her via peer-to-peer 

banking applications. A review of Martin’s Bank of America records revealed 

that co-conspirators made direct transfers to Martin’s personal and business 

accounts and revealed that Martin transferred money received from coconspirators on peer-to-peer banking platforms to her personal and business 

accounts between 2021 and 2022. 

34. Texas Workforce Commission records revealed that Martin

earned a total income of less than $24,000.00 between January 2020 and 

September 2021, and a total income of $0.00 between October 2021 and 

September 2022. Martin’s financial records revealed that one of the bank 

Case 1:23-cv-00044-MJT-CLS Document 1 Filed 01/31/23 Page 13 of 17 PageID #: 13
UNITED STATES V. $32,381.00 IN UNITED STATES CURRENCY:

VERIFIED COMPLAINT FOR FORFEITURE IN REM PAGE 14

accounts that she used to facilitate the PPP loan scheme received more than 

$430,000.00 in deposits between February 2021 and July 2021. The 

investigation revealed that Martin used the same financial account to 

facilitate receipt of funds related to the tax fraud conspiracy and received 

more than $56,000.00 in deposits during the month of July 2022. 

35. Based on information learned during the investigation, to include 

evidence seized during BPD’s July 2022 encounter with Martin, admissions 

made by MARTIN during a BPD interview, information and data sourced 

from Martin’s cellular telephones, and information sourced from Martin’s 

financial records, there is sufficient reason to believe that the $32,381.00 

seized from Martin is forfeitable because of its relation to a financial fraud 

criminal conspiracy.

BASIS FOR FORFEITURE

36. The defendant property, $32,381.00 in United States currency is 

subject to forfeiture pursuant to 18 U.S.C. §§ 981(a)(1)(A), 981(a)(1)(C), and 

981(a)(1)(D) because it constitutes property involved in transactions or 

attempted transactions in violation of 18 U.S.C. §§ 1956, 1957, and 1960 

Case 1:23-cv-00044-MJT-CLS Document 1 Filed 01/31/23 Page 14 of 17 PageID #: 14
UNITED STATES V. $32,381.00 IN UNITED STATES CURRENCY:

VERIFIED COMPLAINT FOR FORFEITURE IN REM PAGE 15

and/or constitutes proceeds traceable to violations of 18 U.S.C. §§ 1028, 1031, 

1341, 1343, 1344, 1952, 1956, 1957, and 1960.

37. The defendant property has been seized and is in the custody of 

U.S. Customs and Border Protection, a Department of Homeland Security 

component.

POTENTIAL CLAIMANT

38. The potential claimant to the defendant property is:

Artisha Gabriella Martin

13031 Ponders Quarters Ln

Amite, Louisiana 70422

CLAIM FOR RELIEF

39. The United States respectfully requests that the Court forfeit the 

defendant property to the United States, award costs and disbursements in 

this action to the United States, and order any other relief that the Court 

deems appropriate.

Case 1:23-cv-00044-MJT-CLS Document 1 Filed 01/31/23 Page 15 of 17 PageID #: 15
UNITED STATES V. $32,381.00 IN UNITED STATES CURRENCY: 

VERIFIED COMPLAINT FOR FORFEITURE IN REM PAGE 16

 Respectfully submitted, 

 BRIT FEATHERSTON 

UNITED STATES ATTORNEY 

 

 /s/ Robert Austin Wells 

 ROBERT AUSTIN WELLS 

 Assistant United States Attorney 

 Texas State Bar No. 24033327

 110 N. College, Suite 700 

 Tyler, Texas 75702 

 Tel: (903) 590-1400

 Fax: (903) 590-1437

 Email: robert.wells3@usdoj.gov

 

ATTORNEYS FOR THE UNITED 

STATES 

Case 1:23-cv-00044-MJT-CLS Document 1 Filed 01/31/23 Page 16 of 17 PageID #: 16
VERIFICATION PURSUANT TO 28 U.S.C. §_ 1746 

I, Quintin Moses, hereby state that: 

1. I am a Senior Special Agent with the United States Homeland 

Security Investigations. 

2. I have read this Complaint, and the information contained herein 

is true and correct to the best of my knowledge. 

3. The information contained in this Complaint comes from the 

official files and records of the United States, statements from 

other law enforcement officers, and my investigation of the case. 

I state and verify under penalty of perjury that the foregoing is true 

and correct. 

Dated: 1/31/2023 

QUINTIN R 

MOSES 

Quintin Moses 

Special Agent 

Digitally signed by QUINTIN R 

MOSES 

Date: 2023.01 .31 09:15:06 

-06'00' 

United States Homeland Security 

Investigations 

UNITED STATES V. $32,381.00 IN UNITED STATES C URRENCY: 

VERIFIED COMPLAINT FOR FORFEITURE IN REM PAGE 17 

Case 1:23-cv-00044-MJT-CLS Document 1 Filed 01/31/23 Page 17 of 17 PageID #: 17