Court filing
Exhibit 2 to Dkt. 291 — United States v. Baver (D. Utah)
Summary
Exhibit 2 to Dkt. 291 in United States v. Baver, Case 2:21-cr-00520-JNP, in the U.S. District Court for the District of Utah, filed September 9, 2025 as Document 291-2. The 30-page exhibit is a set of emails, most of them between Allison Baver and Lendio, about a PPP loan application for Allison Baver Entertainment in April 2020. The messages include instructions for editing the application and verifying business details, updates on PPP funding and on Congress adding funds, and an update dated April 21, 2020. One message states that Lendio reviewed the PPP application and found it missing critical information.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Filed September 9, 2025 in Allison Marie Baver; one of 66 filings from this case.
Record facts
| Court | U.S. District Court for the District of Utah |
|---|---|
| Filed | 2025-09-09 |
Cite this document
“Exhibit 2 to Dkt. 291 — United States v. Baver (D. Utah).”
U.S. District Court for the District of Utah, No. 2:21-cr-00520, Doc. 291-2, filed 2025-09-09. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-allison-marie-baver-utd-129379/2025-09-09-gov-uscourts-utd-129379-291-2-doc-291/
, SHA-256 e72ce176fa6624cd60d7e5ec809162361cd8570ec0852e54d109ab02ab3c8f27.Full text
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4240 Page 1
of 30
From: Allison Baver allison@allisonbaver.com
Subject: Allison Baver Entertainment
Date: April 13, 2020 at 1:21 PM
To: jason.kirkham@lendiolocal.com
Hi Jason,
My entertainment company was referred to you by the WBC. We need to apply for the PPP loan ASAP. I know you are busy. Can you
please call me?
Thank you,
Allison Baver
Sent from my iPhone
408
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4241 Page 2
of 30
From: Jason Kirkham jason.kirkham@lendiolocal.com
Subject: Re: Allison Baver Entertainment
Date: April 13, 2020 at 1:25 PM
To: Allison Baver allison@allisonbaver.com
Allison
I am too busy processing existing applications at this time to take calls. You can apply on my website at www.lendiolocal.com/utah
Attached is how to calculate the amounts and the documents we need.
Jason Kirkham 801-675-8914 | 801-900-6962
Franchise Owner jason.kirkham@lendiolocal.com
Lendio Utah www.lendiolocal.com/utah
On Mon, Apr 13, 2020 at 1:21 PM Allison Baver <allison@allisonbaver.com> wrote:
Hi Jason,
My entertainment company was referred to you by the WBC. We need to apply for the PPP loan ASAP. I know you are busy. Can
you please call me?
Thank you,
Allison Baver
Sent from my iPhone
Calculating your Lendio Utah
loan a…(1).pdf PPP Lo…nts.pdf
409
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4242 Page 3
of 30
Thanks for submitting yo...
Sent via Marketing
Apr 13
Lendio sent: April 13, 2020 2:05 PM via Marketing
to allison@allisonbaver.com
April 13, 2020, 2:05 PM
Thanks for submitting your application!
You are one step closer to getting your share of funds from the SBA Paycheck Protection
Loan Program (PPP).
Our next step in the process is to submit your application to lenders. As you know, demand
for this government program is very high. Our lenders will work hard over the coming days
to provide you an offer as soon as possible.
We will stay in touch with you throughout the funding process. While you wait to hear
back, we invite you to take advantage of the other available COVID-19 relief programs.
Other Available Resources
FI-LE-ABE-01-00001
412
AB0459
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4243 Page 4
of 30
413
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4244 Page 5
of 30
URGENT: Additional items...
Sent via Marketing
Apr 14
Lendio sent: April 14, 2020 11:09 AM via Marketing
to allison@allisonbaver.com
April 14, 2020, 11:09 AM
Hi {{ contact.firstname }},
Good news—we are ready to process your application and submit it to the SBA
for approval, but we need your help on a few remaining items. Please complete all
the steps below by today at 5pm ET (4/14/20). If it helps, please reference this blog
post to show you exactly how and where to enter the information.
1. Log back in to your application using the email address you used previously
2. Click on the “Edit application” button
3. Verify the following items on the “Business” tab of your application:
a. Business Address is correct (including a 5 digit zip code)
b. Business Tax ID is correct—it should be 9 digits long and can be either
your Employer Identification Number (EIN) or Social Security Number
(SSN)
c. Loan Amount is 2.5x your average monthly payroll costs (must be
greater than $0—helpful calculator if you need it)
d. Number of Employees is between 1 and 500 (1 if you are a sole
proprietor)
4. Add the following items to your application on the “Business” tab:
a. Business Start Date: The start date for your business that should match
the date on your Secretary of State filing
b. Industry: Enter the most appropriate option for your business
5. Verify the following information on the “Ownership” tab of your application:
a. Ownership percentage is greater than 0%
b. Any other owners with at least 20% share are listed and all details are
completed in the “Additional owner” section (including date of birth)
FI-LE-ABE-01-00001
414
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4245 Page 6
of 30
6. Verify you have uploaded all the items below in the “Documents” section of your
application:
a. Current, unexpired driver’s license image in color (front and back)—this
must be uploaded for all owners with 20% shares and above
b. One of the following payroll documents:
i. 941 Quarterly Tax Filings (2019, 2020 Q1)
ii. 944 Annual Tax Filings (2019)
iii. Payroll Register for the previous 12 months
iv. 12 Months Most Recent Bank Statements
7. Verify the following information on the “E-sign” section of your application:
a. Ensure your full legal name is shown
b. Ensure your Social Security Number (SSN) is correct
c. Add your date of birth in mm/dd/yyyy format
d. Enter your gender (this information is required and collected by the SBA
program reporting)
After completing the items above, please re-certify, re-sign, and re-submit the application
to have any changes saved and updated.
You are almost there!
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4246 Page 7
of 30
415
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4247 Page 8
of 30
Your Daily PPP Applicati...
Sent via Marketing
Apr 15
Lendio sent: April 15, 2020 7:37 PM via Marketing
to allison@allisonbaver.com
April 15, 2020, 7:37 PM
Hi {{ contact.firstname }},
We have sent tens of thousands of Paycheck Protection Program applications this
week that will be submitted to the SBA for approval. If your file has not been submitted,
it's likely that your application is not complete and ready for a lender. One of the best
things you can do right now is ensure that you have the correct documents attached to your
application.
The rumors are still swirling that Congress will pass an additional $250 billion for the
program. We are hoping that it passes early to mid next week.
We will continue to encourage Congress, the Treasury, and SBA to add additional funds
because millions of business owners still need relief from the devastation of COVID-19. We
would encourage you to also reach out and encourage your representatives to help pass
these additional funds.
We are in this together.
FI-LE-ABE-01-00001 416 AB0456
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4248 Page 9
of 30
417
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4249 Page 10
of 30
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4250 Page 11
of 30
PPP Funds Fully Depleted...
Sent via Marketing
Apr 16
Lendio sent: April 16, 2020 7:21 PM via Marketing
to allison@allisonbaver.com
April 16, 2020, 7:21 PM
Hi {{ contact.firstname }},
The SBA has notified banks that the $350B in initial funds for the Paycheck Protection
Program (PPP) have been exhausted. We’re proud to say that we have been able to help
over 27,000 small businesses get approved for funding -- many of which had no
opportunity to get access to PPP funds through their local bank. Unfortunately, it
appears your application was either missing data or had invalid information and
we were not able to submit it for approval. We know that this is frustrating, but the
fight is not over.
Additional funding for the program is currently under review by Congress, and it appears
there is strong bipartisan support to provide this funding. Unfortunately, Congress has
delayed the allocation of additional funds to the program. In an effort to accelerate the
approval, we have put together a petition to encourage them to take action. We invite you
to join us by signing the petition and sharing it with friends, family, and other small
business owners that have also been negatively impacted.
Given that, what should you do next? We believe additional funds will come. To take
advantage when they do, we need you to make absolutely sure your application contains
valid information and all necessary documents. Here is a brief guide on how to do that.
In terms of the way forward once your app is fully complete, our CEO, Brock Blake, will
be doing a YouTube LIVE tomorrow April 17, 2020 at 12:30 pm PT / 3:30 pm ET. We
invite you to join in for further clarity.
Tune In
We encourage you to reach out to your Senator and Representative to ask them to take
action by allocating additional funds to the PPP program. We’ve put together a blog
FI-LE-ABE-01-00001
418
AB0454
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4251 Page 12
of 30
post with a sample script to use. You can also use ResistBot to send them an email, fax or
letter. Text ‘resist’ to 50409 to make sure they know how important it is to act now.
We haven’t given up and are still in your corner!
FI-LE-ABE-01-00002 AB0455
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4252 Page 13
of 30
Update On Your PPP Loan ...
Sent via Marketing
Apr 21
Lendio sent: April 21, 2020 6:01 PM via Marketing
to allison@allisonbaver.com
April 21, 2020, 6:01 PM
Hi {{ contact.firstname }},
If you are receiving this email, you have either (1) started and not submitted a Paycheck
Protection Program (PPP) loan application via Lendio.com or (2) have submitted your
application to Lendio.com but there is incomplete information and we cannot forward your
application to our trusted lenders.
We are not giving up hope that your business can receive funding through the CARES Act
and we hope you don’t either. We’re in this together. We’re proud to say that we have been
able to help over 70,000 small businesses get approved for PPP funding. Most of our
applicants represent very small businesses that would have otherwise not had access to
these funds due to their own bank being unable or unwilling to participate in the program.
Sources on Capitol Hill are saying that Congress has reached a deal on a second round of
funding for the Paycheck Protection Program (PPP). Although the SBA notified banks that
the $350B of initial funds for the PPP were exhausted, this new round will add more
funding for businesses who desperately need it.
Given that, what can I do now to get my application ready to be submitted to a
lender when the funds are released?
Please make absolutely sure your application is complete and contains all the necessary
documents. Here are a couple of links to our blog that can help:
What You Can Do to Prepare for the Second Round of SBA Funding
Step-by-Step Guide: Complete the Paycheck Protection Program (PPP) Loan Application
Revise or complete your application
FI-LE-ABE-01-00001
419
AB0451
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4253 Page 14
of 30
What else can I do while waiting for a second round of PPP funding?
GET INFORMED - Watch this video by our CEO, Brock Blake. While developments are
happening quickly, our live stream event from last Friday, April 17, 2020, on the CARES Act
will tell you what you should expect for this next round. We invite you to watch the
video for additional information.
STAY INVOLVED - We encourage you to reach out to your Senator and Representative to
ask them to take action. The Senate is voting on it later this afternoon and the House later
this week. We’ve put together a blog post with a sample script to use. You can also
use ResistBot to send them an email, fax or letter. Text ‘resist’ to 50409 to make sure they
know how important it is to act now.
Stay healthy. Stay safe. And please stay in business! We are in your corner!
FI-LE-ABE-01-00002 AB0452
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4254 Page 15
of 30
420
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4255 Page 16
of 30
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4256 Page 17
of 30
422
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4257 Page 18
of 30
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4258 Page 19
of 30
424
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4259 Page 20
of 30
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4260 Page 21
of 30
425
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4261 Page 22
of 30
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4262 Page 23
of 30
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4263 Page 24
of 30
426
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4264 Page 25
of 30
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4265 Page 26
of 30
Thanks for submitting yo...
Sent via Marketing
Apr 25
Lendio sent: April 25, 2020 7:05 PM via Marketing
to allison@allisonbaver.com
April 25, 2020, 7:05 PM
We’ve received your PPP application!
Thank you for submitting your Payroll Protection Program (PPP) loan application to
Lendio. You’ve taken the right first step to secure a portion of the CARES Act funding for
your business.
Your application has been received and registered with Lendio. We will review your
application for completeness and will let you know that your application either (1) has
been submitted to one of our lender partners for funding, OR (2) needs additional
information.
Applications with complete documentation get approved faster. Please review
this application guide to ensure that you have submitted everything. If you have any doubts
or feel that your application could use some more attention, please log back in to add it.
Stay Healthy. Stay Safe. Stay in Business. Save the American Dream!
FI-LE-ABE-01-00001
429 AB0448
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4266 Page 27
of 30
From: Allison Baver allison@allisonbaver.com
Subject: Allison Baver Entertainment New Business/Seasonal
Date: April 25, 2020 at 7:43 PM
To: Jason Kirkham jason.kirkham@lendiolocal.com
Hello Jason,
Just wanted to let you know all of the files for Allison Baver Entertainment have been updated. I probably didn’t need to send the
project details, but you have them anyway to confirm my new and seasonal business was in operations prior to Feb. 15th.
Since the prior payroll is not applicable, I used the payroll season affected by COVID-19 for the calculation. There is more
information confirming this calculation on the treasury website. Used the PPP calculator and uploaded that as well.
Thanks so much for pushing to get this in before the flood gates open!
Best,
Allison Baver
430
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4267 Page 28
of 30
You might miss out on PP...
Sent via Marketing
Apr 26
Lendio sent: April 26, 2020 6:35 PM via Marketing
to allison@allisonbaver.com
April 26, 2020, 6:35 PM
PPP funds are disappearing! Your application needs some love.
Your PPP application has been reviewed by Lendio and is missing critical
information. We cannot submit your application to our lenders until the missing
information is supplied.
Based on how quickly funds evaporated in the previous round of PPP funding, it’s critical
that you review this blog post for a list of the required information and documents
and then log back in to supplement anything that was missing.
We’re proud to say that we have been able to help over 70,000 small businesses get
approved for PPP funding. Most of our applicants represent very small businesses that
would have otherwise not had access to these funds due to their own bank being unable or
unwilling to participate in the program. We’re on your side and want you to get the PPP
relief you need!
Log in and supplement your application
Stay Healthy. Stay Safe. Stay in Business. Save the American Dream!
FI-LE-ABE-01-00001
431
AB0447
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4268 Page 29
of 30
We’ve Submitted Your PPP...
Sent via Marketing
Apr 27
Lendio sent: April 27, 2020 4:15 AM via Marketing
to allison@allisonbaver.com
April 27, 2020, 4:15 AM
Your PPP Application Has Been Submitted To A Lender
What does this mean? This means, your PPP application has been sent to one of our lenders
who works directly with the SBA for approval - which usually happens within 24-48
hours. Once approved, we will notify you and provide your PPP reservation
number.
In the meantime, we recommend setting up a plan on how you will use the funds once they
are received. Since the PPP loan is different from traditional loans, make sure
you understand how you can use the funds so you are eligible for loan forgiveness that is
part of this program. Set up your plan now.
Approved uses for PPP loans
Stay healthy. Stay safe. Stay in business. We are always in your corner!
FI-LE-ABE-01-00001
432
AB0446
Case 2:21-cr-00520-JNP Document 291-2 Filed 09/09/25 PageID.4269 Page 30
of 30
Allison Baver Entertainment PPP Loan Application
Table of Contents
Allison Baver Entertainment Good Faith Letter
Allison Baver Entertainment Operations Disabled due to COVID - 19
430 Total Jobs
Budget: $13.4M - 3 projects (America’s Angels, Dead Princess, Monsters)
Project Timeline - 3 Months, Spring/Summer 2020
PPP Loan Request: $10,000,000
PPP Loan Calculation: Monthly Payroll Budget = $4,770,583 x 2.5 = $11,926,456
Allison Baver Entertainment Payroll Budget - Spring 2020
Allison Baver Entertainment Payroll Audit 4-22-20
Oct. 2019
Allison Baver Entertainment EIN
Allison Baver Entertainment Articles of Incorporation
Allison Baver Entertainment Business Registration
Allison Baver Entertainment Form 2553 S-Corp Election pending approval for 2019 Tax Filing
Allison Baver Driver License Front/Back
Nov. 25, 2019
ABE - AMERICA'S ANGELS DISTRIBUTION OFFER 11_25_2019_ FYI_Lifetime Digital_4Q20
ABE - America's Angels Budget - $4.1M / 80 Employees
ABE - America's Angels Format Edits 8-23-2019
ABE - America's Angels Overview
FYI At-A-Glance 3Q19
LIFETIME At-A-Glance 3Q19
Dec. 2019
ABE Dec. 2019 Entertainment Attorney Engagement Receipt .pdf
Jan. 2020
Allison Baver CC Receipt 1-2-20 for ABE Entertainment Attorney.pdf
Jan. 7th, 2020
ABE - January 7th, 2020 Production Engagement for Dead Princess
ABE - April 7, 2020 Dead Princess Castel Studio Production Proposal Apology for COVID-19 Delays
ABE - Dead Princess Budget - $6.3M / 215 Employees
ABE - Dead Princess Script
ABE - Dead Princess Film Presentation
ABE - Dead Princess Locations
ABE - Dead Princess Purchase Agreement
Feb. 2, 2020
ABE - Monsters Engagement Letter
ABE - Monsters Budget V3 - $3M / 135 Employees
ABE - Monsters Script _01_02_2020_R1
ABE - Monsters Film Presentation
ABE - Monsters Purchase Agreement
March 2020
All productions disabled due to COVID - 19
PPP Loan usage, for Allison Baver Entertainment to continue employment and operations
437-AFile and source
- File
- gov.uscourts.utd.129379.291.2.pdf
- Size
- 2,879,557 bytes
- SHA-256
- e72ce176fa6624cd60d7e5ec809162361cd8570ec0852e54d109ab02ab3c8f27
- Original
- archive.org