8:25-cr-00438-CRI Date Filed 03/11/25 Entry Number 2 Page 1 of 5

IN THE DISTRICT COURT OF THE UNITED STATES

FOR THE DISTRICT OF SOUTH CAROLINA
ANDERSON DIVISION

UNITED STATES OF AMERICA )

)
) 18 U.S.C. § 1349
vs. ) 18 U.S.C. § 1343
) 18 U.S.C. §2
) 18 U.S.C. § 981 (a)(] )(C)
DILLINGER MATSON BOLDEN ) 28 U.S.C. § 246l(c)
MARY ELIZABETH ELLIS )
HAASEAM RAHSHAMEL TIQUAN )
MCCOWAN )
QUANSHUNDA WEBB INDICTMENT
)

COUNT 1

THE GRAND JURY CHARGES:

1. That beginning in or about November 2023 , and continuing until in or about

February 2024, in the District of South Carolina, the Defendants, DILLINGER MATSON

BOLDEN, MARY ELIZABETH ELLIS, HAASEAM RAHSHAMEL TIQUAN MCCOWAN,

and QUANSHUNDA WEBB, together with other co-conspirators, known and unknown to the

Grand Jury, did knowingly and willfully conspire, combine, confederate, and agree to execute and

attempt to execute a scheme and artifice to defraud and to obtain money or property by means of

false and fraudulent pretenses, representations, and promises, and during such period, in the course

of executing said scheme and artifice, did knowingly transmit and cause to be transmitted in

interstate commerce, by means of wire communications, certain electronic signals, such scheme

and artifice and such wire communications being more fully set forth below.

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THE SCHEME AND ARTIFICE

2. It was a part of the scheme and artifice to defraud that DILLINGER MATSON

BOLDEN befriended Michael French while both were incarcerated in the Anderson City Jail.

3. It was a part of the scheme and artifice to defraud that DILLINGER MATSON

BOLDEN offered to help Michael French sell personal items in several homes French owned in

the upstate of South Carolina.

4. It was further part of the scheme and artifice that DILLINGER MATSON

BOLDEN, rather than merely selling personal items as agreed upon, arranged for the creation of

fraudulent documents and a fraudulent email account to facilitate the sale of French' s properties

to ATB Properties & Entertainment, Inc. (an entity owned and controlled by BOLDEN) even

though DILLINGER MATSON BOLDEN knew that Michael French had surrendered the

properties to the Securities and Exchange Commission in a civil action .

5. It was further part of the scheme and artifice that HAASEAM RAHSHAMEL

TIQUAN MCCOWAN created the email address mikefprope1iies83 (@,yahoo .com for use in the

conspiracy.

6. It was further part of the scheme and artifice that MARY ELIZABETH ELLIS

arranged for the transfer of the French properties to A TB Properties & Entertainment, Inc.

7. It was further part of the scheme and artifice that QUANSHUNDA WEBB

transferred documents to HAASEAM RAHSHAMEL TI QUAN MCCOWAN to assist with

forging needed signatures.

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

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COUNTS 2-3

THE GRAND JURY FURTHER CHARGES:

6. The allegations of paragraphs 1 through 7 of this indictment are alleged herein as

setting forth a scheme and artifice to defraud.

7. On each of the dates reflected below, in the District of South Carolina and

elsewhere, the Defendants, DILLINGER MATSON BOLDEN, MARY ELIZABETH ELLIS ,

HAASEAM RAHSHAMEL TIQUAN MCCOWAN, and QUANSHUNDA WEBB , aiding and

abetting each other, for the purpose of executing the scheme and artifice to defraud and to obtain

money and property by means of materially false and fraudulent pretenses, representations, and

promises, as described above, did transmit and cause to be transmitted in interstate commerce by

means of a wire communication, certain signals, writings, and sounds, that is payments as fmther

set forth below:

Count Date Description

1 2/15/2024 An email sent from mikef12ro12erties83 @yahoo.com to a real

estate closing attorney .
2 2/29/2024 An email sent from mikef12ro12e1ties83 @,yahoo.com to a real
estate closing attorney.

All in violation of Title 18, United States Code, Sections 1343 and 2.
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FORFEITURE

CONSPIRACY/WIRE FRAUD:

Upon conviction for violation of Title 18, United States Code, Sections 1343 and 1349 as

charged in this Indictment, the Defendants, DILLINGER MATSON BOLDEN, MARY

ELIZABETH ELLIS , HAASEAM RAHSHAMEL Tl QUAN MCCOWAN, and QUANSHUNDA

WEBB , shall forfeit to the United States all of the Defendants ' rights, title, and interest in and to

any property, real and personal , which constitutes, is traceable to, or is derived from any proceeds

the Defendants obtained , directly or indirectly, as a result of such violations.

PROPERTY:

Pursuant to Title 18, United States Code, Section 98 l(a)( I )(C) and Title 28, United States

Code, Section 2461 (c), the property which is subject to forfeiture upon conviction of the

Defendants for the offenses charged in this Indictment includes, but is not limited to, the following:

Proceeds/Forfeiture Judgment:

A sum of money equal to all proceeds the Defendants obtained, directly or

indirectly, from the offenses charged in this Indictment, and all interest and
proceeds traceable thereto, and/or such sum that equals all property derived
from or traceable to their violation of 18 U.S.C. §§ 1343 and 1349.

SUBSTITUTION OF ASSETS:

If any of the property described above as being subject to forfeiture, as a result of any act

or omission of a Defendant:

(a) cannot be located upon the exercise of due diligence;

(b) has been transferred or sold to, or deposited with, a third person ;
(c) has been placed beyond the jurisdiction of the Court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot be subdivided
without difficulty ;
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it is the intent of the United States, pursuant to Title 21 , United States Code, Section 853(p) to seek

forfeiture of any other property of the Defendant up to an amount equivalent to the value of the

above-described forfeitable property;

Pursuant to Title 18, United States Code, Section 98 l(a)(l )(C) and Title 28, United States

Code, Section 246l(c).

REDACTED

BROOK B. ANDREWS
ACTING UNITED STA TES ATTORNEY

By: U✓
Willia atkins, Jr. ed. ID # 07863)
Assistant United States Attorney
55 Beattie Place, Suite 700
Greenville, SC 2960 I
Tel.: 864-282-2100
Fax: 864-233-3158
Email: bill.watkins@usdoj.gov
8:25-cr-00438-CRI Date Filed 03/11/25 Entry Number 2-1 Page 1 of 1

RECORD OF GRAND JURY BALLOT

CIR 1: .2$"' - l.j J:1,

UNITED STATES OF AMERICA v. DILLINGER MATSON BOLDEN , ET AL.

(SEALED UNTIL FURTHER ORDER OF THE COURT)