Exhibit B — USA v. Crowther (Dkt. 79.2)

Summary

Pages 5 and 6 of 10 of the Casey Crowther Document Production Cover Letter, filed as Document 79-2 in Case 2:20-cr-00114. The letter argues that the Corporation and Crowther had sufficient funds to cover the expense of the boat, and that general accounting principles contradict the government's theory of specifically earmarked funds during the PPP time period. It states that money is fungible and that there is nothing in the Cares Act about opening a separate bank account or segregating the proceeds from a PPP Loan. It says that when the wire was sent to Sara Bay Marina, Target Roofing had ample funds in its operating account, shown in a chart of funds available to the Company. It adds that jobs under contract would generate approximately $750,000 to $1,000,000 as a rolling average.

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Case 2:20-cr-00114-JES-M_M Document 79-2 Filed 03/11/21 Page 1 of 2 PagelD 312

Casey Crowther
Document Production Cover Letter

September 21,2020 | Page 5 of 10

C. The Corporation and Mr. Crowther had sufficient funds to cover the expense of the boat.

General accounting principles also wholly contradict the government’s theory of specifically
earmarked funds for utilization during the PPP time period. Money is fungible and the assets of a
corporation, whether contained in one bank account or hundreds of bank accounts, are all corporate
funds under the same umbrella, with the same owner. For general accounting purposes, all of the
funds are recorded in the books and ledgers of the Company and are utilized to generate financial
statements, profit and loss statements, and account receivables. Moreover, there is nothing in the
Cares Act about opening a separate bank account, segregating the proceeds from a PPP Loan or
the commingling of funds with other business funds or working capital.

When the wire was sent to Sara Bay Marina, Target Roofing had ample funds in its operating
account for the expense. Below is a chart of the funds available to the Company as of that date:

Name of Owner of Account Company Funds Company Funds w/out
account account Number Available on 4/24 use of "PPP Account" 2
$131,768.58 $2,468.58

Operating Target Roofing
account

LOC Target Roofing | J = [$600,000.00 $ 500,000.00

Petty Cash | Target Roofing | Office Safe - $59,702.30 $59,702.30
On Books
Chase Target Roofing | Mill $110,357.00 $110,357.00
rewards
Petty Cash Casey Office Safe $400,000.00 $400,000.00
Crowther

2 Funds transferred from the PPP Account were subtracted here to illustrate the availability of funds other than those
from the proceeds of the loan that were deposited into the PPP Account.

ATLANTA | AUSTIN | BOSTON | CHARLOTTE | CHICAGO | CINCINNATI | CLEVELAND | COLUMBUS | DALLAS
DENVER | DETROIT | HOUSTON | LONDON | LOS ANGELES | MIAMI | NAPLES | NEWYORK | PALO ALTO
PHILADELPHIA | PRINCETON | SALTLAKECITY | SEATTLE | WASHINGTON DC.
Case 2:20-cr-00114-JES-M_M Document 79-2

Casey Crowther

Document Production Cover Letter

September 21,2020 | Page 6 of 10

Filed 03/11/21 Page 2 of 2 PagelD 313

TOTAL Target &
AVAILABLE | Crowther
FUNDS

NOT "PPP"
FUNDS

$1,301,827.88

$1,072,527.88

In addition to the available funds, a review of the contracts provided in the document production
shows that the Company had a pipeline of jobs that would generate consistent revenue,
approximately $750,000 to $1,000,000 as a rolling average at any given time during the time period
in question. Although the revenue stream had been lower than it had been in prior months due to
the pandemic, there was still a steady and known stream of income. Thus, the whole of the
Company operated with sufficient money, had a healthy pipeline of projects and was paying its
bills and payroll on time. The bank would view these financials in their totality to determine the
Company’s available cash flow.

ATLANTA | AUSTIN | BOSTON

CHARLOTTE | CHICAGO

DENVER | DETROIT | HOUSTON | LONDON | LOS ANGELES | MIAMI

PHILADELPHIA

CINCINNATI | CLEVELAND | COLUMBUS | DALLAS

NAPLES | NEWYORK | PALO ALTO

PRINCETON | SALTLAKECITY | SEATTLE | WASHINGTON D.C.


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