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Date: 05-24-2023

Case Style:

United States of America v. Leronce Suel and Ravae Smith owned Rockstar Dough LLC and Chicken Feed, LLC

Case Number: 23-CR-965

Judge: William V. Gallo

Court: United States District Court for the Southern District of California (San Diego County)

Plaintiff's Attorney: United States Attorney’s Office in San Diego

Defendant's Attorney:

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Description: San Diego, California criminal defense lawyer represented Defendants charged with fraud and money laundering in connection with an alleged scheme to falsify applications for pandemic relief funds.

Leronce Suel and Ravae Smith owned Rockstar Dough LLC and Chicken Feed LLC, both of which operated a series of restaurants in the San Diego area. From March 2020 to June 2022, Suel and Smith allegedly conspired to underreport over $1.7 million in gross receipts on Rockstar Dough LLC’s 2020 corporate tax return (Form 1120S) filed with the IRS in order to qualify for the COVID-related Paycheck Protection Program and Restaurant Revitalization Funding loans.

Suel and Smith also allegedly made materially false certifications on loan applications regarding the use of the money. The indictment charges that Suel and Smith made substantial cash withdrawals from their business bank accounts to launder the fraudulently obtained funds. As part of the conspiracy, Suel and Smith allegedly concealed more than $2.4 million in cash at their residence.

Suel and Smith made their initial court appearance today before U.S. Magistrate Judge William V. Gallo.

“During an unprecedented public health emergency, the United States provided these loan programs to deliver economic relief to Americans,” said U.S. Attorney Randy Grossman. “This office will investigate and prosecute those who exploited the global pandemic to unjustly enrich themselves.” Grossman thanked the prosecution team and the IRS for their excellent work on this case.

“The CARES Act was passed to aid those in need and provide much needed relief during the Covid-19 pandemic,” said Special Agent in Charge Tyler Hatcher of the Los Angeles Field Office. “Unfortunately, there are individuals and organizations who took advantage and targeted these programs to steal funds. Submitting false returns in support of a fraudulent loan application is a crime. IRS-CI is committed to aggressively investigating these crimes and bringing those to justice who stole funds and targeted relief programs during the pandemic.”

The Coronavirus Aid, Relief, and Economic Security (CARES) Act is a federal law enacted on March 29, 2020 and is 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 up to $349 billion in forgivable loans to small businesses for job retention and certain other expenses, through the PPP. In April 2020, Congress authorized over $300 billion in additional PPP funding.

Anyone with general information about allegations of attempted fraud involving COVID-19 can report it by calling the Justice Department’s National Center for Disaster Fraud Hotline at 866-720-5721 or via the NCDF Web Complaint Form at:

The case is being prosecuted by Assistant U. S. Attorney Christopher Beeler and Trial Attorney Julia M. Rugg from the Department of Justice’s Tax Division.

DEFENDANT Case Number 23-CR-0965-RBM

Leronce Suel San Diego Age: 46

RaVae Smith San Diego Age: 45


Conspiracy to Commit Wire Fraud—Title 18, U.S.C., Section 1349

Maximum penalty: Thirty years in prison, $1 million fine; forfeiture and restitution

Wire Fraud—Title 18, U.S.C., Section 1343

Maximum penalty: Thirty years in prison, $1 million fine; forfeiture and restitution

Money Laundering—Title 18, U.S.C. Section 1957

Maximum penalty: Ten years in prison, $1 million fine; forfeiture and restitution


IRS Criminal Investigation

18:1349; 18:982(a)(1)(C), 18:982(a)(1), 28:2461(c) - Conspiracy to Commit Wire Fraud; Criminal Forfeiture
18:1343; 18:2; 18:982(a)(1)(C), 18:982(a)(1), 28:2461(c) - Wire Fraud; Aiding and Abetting; Criminal Forfeiture
18:1343; 18:2; 18:982(a)(1)(C), 18:982(a)(1), 28:2461 - Wire Fraud; Aiding and Abetting; Criminal Forfeiture
18:1957; 18:2; 18:982(a)(1)(C), 18:982(a)(1), 28:2461(c) - Money Laundering; Aiding and Abetting; Criminal

Outcome: he charges and allegations contained in an indictment are merely accusations, and the defendants are considered innocent unless and until proven guilty.

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