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CourtU.S. District Court for the Northern District of Georgia
Filed2024-11-14

U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00228-MHC-JKL · Doc. 345 · 2024-11-14 · Docket on CourtListener

Summary

A motion by the United States to substitute a restitution payee, with brief in support, in United States v. Daniel Eric Jay, Criminal Action No. 1:20-cr-00228-MHC-02, in the U.S. District Court for the Northern District of Georgia, filed November 14, 2024 as Doc. 345. The motion states that on June 23, 2023 Jay was convicted of conspiracy to commit wire fraud and bank fraud in connection with the Paycheck Protection Program and ordered to pay $4,465,865.55 in restitution, jointly and severally with Maurice Fayne. It states that Jay received a PPP loan of $2,045,300.00 from United Community Bank and that the SBA purchased the guaranty. Citing 18 U.S.C. § 3664(j)(1), the government asks the Court to substitute the Small Business Administration for United Community Bank as payee without changing the restitution balance. It is signed by Assistant United States Attorney Vanessa A. Leo.

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IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA                        
v. 
DANIEL ERIC JAY 
 
Criminal Action No. 
1:20-cr-00228-MHC-02 
 
 
MOTION TO SUBSTITUTE RESTITUTION PAYEE 
 AND BRIEF IN SUPPORT THEREOF 
 
The United States of America, by Ryan K. Buchanan, United States Attorney, 
and Vanessa A. Leo, Assistant United States Attorney for the Northern District of 
Georgia, respectfully requests an order substituting a restitution payee pursuant 
to 18 U.S.C. § 3663A, and in support shows:  
Background Information 
1. 
On June 23, 2023, Defendant Daniel Eric Jay (“Jay”) was convicted of 
conspiracy to commit wire fraud and bank fraud in connection with the Paycheck 
Protection Program (“PPP”) a federal loan program and ordered to pay 
$4,465,865.55 in criminal restitution to the following victims jointly and severally 
with Maurice Fayne (Case No. 1:20-CR-228-01) and Michael Sargent (Case No. 
1:21-CR-219): 
a. United Community Bank;  
b. U.S. Small Business Administrative/DFC;  
Case 1:20-cr-00228-MHC-JKL     Document 345     Filed 11/14/24     Page 1 of 6

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c. Jimia Cain; 
d. Sean Frank;  
e. Laura Wolf; 
f. Robert Tuscana; 
g. Amanda Napier; 
h. Marla Newman; 
i. Jeanne Johnston; 
j. Mike Rubial; 
k. Linda Appleby; 
l. Alejandro Davila; 
m. Edie Lenaburg; 
n. Ruben Azrak; 
o. Terrance Miller; 
p. Ken Pritchett; 
q. Elizabeth Baun; 
r. John Baun; 
s. Tameika Price; 
t. Jamar Rucker; and 
u. Sherrie Odom. 
 
 (Doc. 319.) 
 
2. 
 Individual PPP loans were issued by private/approved lenders 
who received and processed PPP applications and supporting documentation and 
then made loans using the lenders own funds/ which were 100% guaranteed by 
the Small Business Administration (“SBA”).  
Case 1:20-cr-00228-MHC-JKL     Document 345     Filed 11/14/24     Page 2 of 6

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3. 
The SBA is an executive branch agency of the United States 
government that provides support to entrepreneurs and small businesses.  The 
SBA’s mission is to maintain and strengthen the nation’s economy by enabling the 
establishment and viability of small businesses and by assisting in the economic 
recovery of communities after disasters.  As part of this effort, the SBA provides 
relief by enabling and providing loans through banks, credit unions, and other 
lenders.   
4. 
Jay submitted a PPP loan application to United Community Bank 
containing materially false information and received a PPP loan in the amount of 
$2,045,300.00. 
5. 
As evidenced by the Notice of PPP Guaranteed Purchase Payment, 
attached hereto as Exhibit A, the SBA purchased the guaranty on the PPP loan 
obtained and became subrogated to all rights of United Community Bank. 
6. 
The United States agrees that the SBA is entitled to compensation as 
subrogee of United Community Bank. 
7. 
The Clerk of Court should be ordered to immediately begin making 
restitution payments to the SBA.  
Argument and Application of Law 
8. 
18 U.S.C. § 3664(f)(1)(A) requires the Court to order restitution in the 
full amount of each victim’s loss.  The Mandatory Victims Restitution Act defines 
Case 1:20-cr-00228-MHC-JKL     Document 345     Filed 11/14/24     Page 3 of 6

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a victim as “a person directly and proximately harmed as a result of the 
commission of an offense for which restitution may be ordered.” 18 U.S.C. § 
3663A.  The SBA suffered a proven financial loss as result of Jay’s fraud yet 
possesses no hope of being made whole with the judgement as it currently reads.  
Thus, the United States recommends substituting the SBA as restitution payee in 
this matter.  
9. 
The United States does not seek to alter the court’s judgment 
ordering the defendant’s liability to pay the total amount of restitution originally 
imposed.  The United States merely requests an adjustment to the disbursement 
of restitution payments in compliance with 18 U.S.C. § 3664(j)(1), which provides: 
If a victim has received compensation from insurance or any other 
source with respect to a loss, the court shall order that restitution 
be paid to the person who provided or is obligated to provide the 
compensation, but the restitution order shall provide that all 
restitution of victims required by the order be paid to the victims 
before any restitution is paid to such a provider of compensation. 
 
10. 
In this case, United Community Bank has received compensation 
with respect to the loss in this case from the SBA.  Accordingly, the United States 
requests that the Clerk of Court substitute the SBA as victim and disburse all 
restitution payments to the SBA until the awarded restitution has been satisfied.  
11. 
A proposed order is submitted to the Court contemporaneously for 
its consideration. 
Case 1:20-cr-00228-MHC-JKL     Document 345     Filed 11/14/24     Page 4 of 6

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WHEREFORE, the United States respectfully requests that the Court 
substitute the Small Business Administration for United Community Bank as the 
restitution payee in the above-captioned case.  This amendment would not change 
the balance of Defendant’s restitution debts and therefore would not substantively 
alter her criminal sentence. 
Respectfully submitted this 14th day of November 2024. 
 
 
 
 
 
 
RYAN K. BUCHANAN  
 
 
 
UNITED STATES ATTORNEY 
 
 
 
 
 
 
 
/s/ Vanessa A. Leo             
 
VANESSA A. LEO 
ASSISTANT UNITED STATES ATTORNEY 
 
 
 
 
 
 
Georgia Bar No. 410598 
 
 
 
 
 
 
600 U.S. Courthouse 
 
 
 
 
 
 
75 Ted Turner Drive, S.W. 
 
 
 
 
 
 
 
 
Atlanta, Georgia 30303 
404-581-6037 
Vanessa.Leo@usdoj.gov 
 
 
Case 1:20-cr-00228-MHC-JKL     Document 345     Filed 11/14/24     Page 5 of 6

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CERTIFICATE OF COMPLIANCE 
 
I hereby certify, pursuant to Local Rules 5.1B and 7.1D, that the foregoing 
response has been typed using 13-point Book Antiqua font. 
/s/ Vanessa A. Leo             
 
VANESSA A. LEO 
 
 
 
 
 
 
Assistant United States Attorney 
 
 
CERTIFICATE OF SERVICE 
 
This is to certify that on November 14, 2024, the foregoing document was 
electronically filed using the Court’s Electronic Case Filing program, which sends 
a notice of this document and an accompanying link to this document to all parties 
who have appeared in this case under the Court’s Electronic Case Filing program.
 
 
Dated: November 14, 2024. 
 
 
 
 
 
 
 
 
 
 
 
 
/s/ Vanessa A. Leo             
 
VANESSA A. LEO 
ASSISTANT UNITED STATES ATTORNEY 
 
 
 
 
 
 
Georgia Bar No. 410598 
 
 
 
 
 
 
600 U.S. Courthouse 
 
 
 
 
 
 
75 Ted Turner Drive, S.W. 
 
 
 
 
 
 
 
 
Atlanta, Georgia 30303 
404-581-6037 
Vanessa.Leo@usdoj.gov 
 
 
 
 
 
 
 
Case 1:20-cr-00228-MHC-JKL     Document 345     Filed 11/14/24     Page 6 of 6

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