Exhibit - United States v. David T. Hines

Record facts

U.S. District Court for the Southern District of Florida · No. 1:21-cr-20011-DPG · Doc. 56-1 · 2021-05-11 · Docket on CourtListener

Summary

Doc. 56-1 in United States v. David T. Hines, No. 1:21-cr-20011-DPG, in the U.S. District Court for the Southern District of Florida, entered May 11, 2021, is a two-page letter from the defendant to the Honorable Marcia Gail Cooke ahead of his sentencing. In the letter he states that he is guilty of applying for PPP funds in excess of his business's entitlement and of using funds for purposes not permitted, and says he accepts the consequences. He describes owning and operating interstate household-goods moving businesses from May 2015 through April 2020 and assisting the Federal Motor Carrier Safety Administration in investigations. The letter also refers to his ten months of home confinement since his arrest, his plea agreement, and his plans to pursue education and training programs while in prison.

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Full text

The Honorable Marcia Gail Cooke, 
  
     
My name is David Tyler Hines. On May 12th you will impose a sentence against me for the 
crime I committed. I am guilty and deeply remorseful for my actions. I illegally applied for PPP 
funds well in excess to what my business was entitled. I fraudulently completed the paperwork 
and deserve to be punished. I have deeply embarrassed my wife, family and friends, set an 
awful example for my son, and wronged American taxpayers and other struggling business 
owners who could have benefitted from the use of those funds.   
  
While it is no excuse, I panicked in the face of desperation. My business was completely 
decimated by the onset of the Covid pandemic, and I feared for the worst, afraid I wouldn’t be 
able to support my family. I offer this up not as a justification but so that your Honor may better 
understand my mindset when I committed my crime. 
  
I otherwise saw businesses in the news receiving PPP funds based upon larger requests. I 
shamefully applied for a much larger amount than to which my business was entitled and then 
greedily applied for even more once I saw how quickly and easily the money arrived. I also 
illegally used funds for personal use and other purposes not permitted by Congress under the 
PPP program.     
  
I am deeply ashamed by what I have done and readily accept the consequences.  However, 
your Honor, this unlawful act represents but a part of my life and I hope that you may take 
additional factors into consideration.       
  
From May 2015 through April 2020, I owned and operated several businesses providing 
interstate transportation of household goods. All of my companies have been featured 
by consumeraffairs.com and consumersadvocate.orgas among the “Top 10 Best Moving 
companies in the Country” based on consumer reviews and independent editorial reviews.  
  
I attribute the success my businesses achieved in the moving industry to the honorable values I 
instilled in my employees, setting us apart from the competition. The moving industry is filled 
with irresponsible and opportunistic operators. My companies built a reputation and 
trustworthiness in helping the thousands of customers who used our services throughout the 
years. 
  
My companies, moreover, retained an exemplary status with the Department of Transportation 
as we logged millions of miles in consumer moves. I personally assisted the Federal Motor 
Carrier Safety Administration (FMCSA) in multiple investigations, throughout the years, helping 
them to locate and take action against companies engaging in moving fraud, helping to maintain 
integrity in the marketplace. 
  
Separately, I have struggled with drug and alcohol addiction throughout my adult life. My recent 
illicit and excessive use of Adderall and Xanax over the past few years have deeply impacted 
my ability to function and make good decisions. My addiction, in no way excuses my behavior. I 
chose to take drugs and elected to commit my crime. It is, however, something I intend to tackle 
head on during my time in prison. It may be difficult to believe, but part of me is thankful for 
getting arrested and being forced to come to terms with my addiction. The alternative of letting it 
run its course could have landed me in even more dire trouble.   
  
Case 1:21-cr-20011-DPG   Document 56-1   Entered on FLSD Docket 05/11/2021   Page 1 of 2

I have been on home confinement for the past ten months since my arrest. During this time, I 
have thought a lot about my past decisions. I find myself wondering who I had become, 
wondering how I could commit such a grievous crime. I see just how deeply my selfish and 
careless decisions impact the ones I love. I also understand how my fraud plays a much larger 
role in negatively impacting society.   
  
I also realize that part of this process requires me to make amends. For that reason, I quickly 
accepted guilt and signed a plea agreement. Beginning to tackle my addiction has been the next 
step in the process. With this letter, I follow through on this ongoing commitment which I will 
continue during my sentence and beyond. I plan on using my time in prison to improve myself 
through education and training programs in order to return to my family as a productive member 
of society.  
  
I have faith that this experience is a part of God’s master plan and that it will only yield positive 
results in my life going forward. I pray that you can feel my sincerity expressed in this letter.  
 Respectfully,  
  
  
David Tyler Hines 
  
 
Case 1:21-cr-20011-DPG   Document 56-1   Entered on FLSD Docket 05/11/2021   Page 2 of 2

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