Indictment — United States v. Kenneth C. Sparks III et al. — United States v. Kenneth C. Sparks III et al. (E.D. Mo., 2024-07-17)

Record facts

U.S. District Court for the Eastern District of Missouri, Eastern Division · No. 4:24-cr-00374-JAR-SRW · Doc. 2 · 2024-07-17 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF MISSOURI 
EASTERN DIVISION 
UNITED ST A TES OF AMERICA, 
Plaintiff, 
FILED 
JUL 1 7 2024 
U S DISTRICT COURT 
EASTE.RN DISTRICT OF MO 
ST. LOUIS 
V. 
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4:24CR374 JAR/SRW 
KENNETH C. SPARKS IIL 
JEFFREY C. OBOITE, 
HAROLD G. LONG, 
MY AM. MCCLAIN, and 
JA VONTE D. LONG, 
Defendants. 
INDICTMENT 
The Grand Jury charges that, at all times relevant to the Indictment: 
INTRODUCTION 
1. 
During the scheme to defraud outlined below, Defendant Kenneth C. Sparks III 
("Defendant Sparks") and his co-conspirators, including Defendant Jeffrey C. Oboite ("Defendant 
Oboite''), Defendant Harold G. Long ("Defendant H. Long"), Defendant Mya M. McClain 
("Defendant McClain''), and Defendant Javonte D. Long ("Defendant J. Long''), used Faith Walk 
Ministry and other entities to fraudulently obtain over $1 million in taxpayer money that was 
reserved for struggling small businesses during the pandemic. Instead of using the fraudulently 
obtained taxpayer dollars for permissible purposes, Defendant Sparks used the funds that he took 
to compensate his co-conspirators and to purchase designer clothing, luxury merchandise, and 
expensive cars for himself. 
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2. 
Defendant Sparks worked as a visiting minister at Faith Walk Ministry-a church 
in Paris, Missouri. Defendant Sparks was convicted of a felony offense on or about May 23, 2014, 
and was placed on parole for that felony offense on or about July 26, 2017. Defendant Sparks was 
indicted for another felony offense on or about October 30, 2019. 
3. 
Defendant Oboite resided in the District of Maryland, and he operated businesses 
called Angel's Management Group, LLC. Emerald Score LLC, and O&S Construction LLC. 
Through those businesses, Defendant Oboite participated in a scheme to fraudulently obtain 
pandemic assistance loans. 
4. 
Defendant H. Long resided within the Eastern District of Missouri. and he worked 
as the lead minister and chief executive officer at Faith Walk Ministry. 
5. 
Defendant McClain resided within the Eastern District of Missouri, and she worked 
as an administrative assistant at Faith Walk Ministry. 
6. 
Defendant J. Long resided within the Eastern District of Missouri, and he was a 
member at Faith Walk Ministry. 
7. 
The United States Small Business Administration ("SBA") is an executive-branch 
agency of the United States government that provides support to entrepreneurs and small 
businesses. The mission of the SBA is to maintain and strengthen the nation's economy by 
enabling the establishment and viability of small businesses and by assisting in economic recovery 
after disasters. 
The Paycheck Protection Program 
8. 
The Coronavirus Aid, Relief, and Economic Security ("CARES'") Act, Pub. L. No. 
116-136, 134 Stat. 281 (2020), was a federal law that was enacted in or around March 2020 to 
provide emergency financial assistance to the millions of Americans suffering the economic 
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impact caused by the COVID-19 pandemic. One source of relief provided for in the CARES Act 
was the authorization of forgivable loans to small businesses for job retention and certain other 
expenses, through the Paycheck Protection Program ("PPP"). The purpose of loans issued under 
the PPP was to enable small businesses suffering from the economic downturn to continue to pay 
salary or wages to their employees. 
9. 
The types of small businesses eligible for a PPP loan included individuals who 
operated as a sole proprietorship and did not have any employees. Such individuals were eligible 
to receive a maximum PPP loan of up to $20,833 to cover their lost compensation or income from 
the sole proprietorship. To obtain a PPP loan, a qualifying individual was required to submit and 
sign a PPP loan application. The PPP loan application required the applicant to acknowledge the 
program rules and make certain affirmative certifications to obtain the PPP loan. In the PPP loan 
application, the applicant was required to certify, among other things, (a) that the small business 
was in operation on February 15, 2020; and (b) the annual income and expenditures for the sole 
proprietorship, as reported to the Internal Revenue Service on Form I 040, Schedule C, for a given 
tax year. These certifications were used to calculate the amount of money the sole proprietorship 
was eligible to receive under the PPP. In addition, the individual applying for a PPP loan was 
required to submit valid documentation supporting the sole proprietorship's annual income. 
I 0. 
For businesses that were not sole proprietorships, a qualifying business was 
required to submit a PPP loan application. signed by an authorized representative of the business. 
In the PPP loan application for those businesses. the small business (through its authorized 
representative) was required to certify: (a) that the small business was in operation on February 
15. 2020; (b) the average monthly payroll expenses: and (c) the number of employees. These 
certifications were used to calculate the amount of money that the small business was eligible to 
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receive under the PPP. 
11. 
For all of the PPP loan applications submitted as part of the scheme outlined below, 
the application asked whether ''the Applicant (if an individual) or any owner of the Applicant [is] 
presently incarcerated or, for any felony, presently subject to an indictment, criminal information, 
arraignment, or other means by which formal criminal charges are brought in any jurisdiction?" 
Applicants were required to certify a "yes" or "no" response to that question. 
12. 
PPP loan applications were processed by participating lenders. If a PPP loan 
application was approved, the participating lender funded the loan using its own monies, which 
were then guaranteed by the SBA. Generally, in the event that the borrower defaulted on a PPP 
loan, the SBA would purchase the borrower's debt from the lending financial institution and take 
on the responsibility for paying back the loan. 
13. 
PPP loan funds were required to be used on certain permissible expenses, including 
payroll costs. mortgage interest, rent, and utilities for the business. In the PPP loan application. the 
borrower must certify that "[ a ]II loan proceeds will be used only for business-related purposes ... 
as specified in the loan application and consistent with the Paycheck Protection Program Rules." 
In that same application, the borrower must also certify that "[t]he funds will be used to retain 
workers and maintain payroll: or make payments for mortgage interest, rent, utilities. covered 
operations expenditures, covered property damage costs, covered supplier costs, and covered 
worker protection expenditures as specified under the Paycheck Protection Program Rules.•· 
14. 
The lenders that received the PPP loan applications as a result of the fraudulent 
scheme outlined below were third-party participating lenders in the Paycheck Protection Program. 
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COVID-19 EIDL Loans 
15. 
The COVID-19 Economic Injury Disaster Loan ("EIDL") program was 
administered by the SBA. Unlike PPP loans, which were issued by participating lenders, COVID-
19 EIDL loans were issued directly by the SBA and were not eligible for forgiveness. 
16. 
To obtain a COVID-19 EJDL loan, an applicant had to submit an EIDL loan 
application electronically. All EIDL loan applications were submitted online. Prior to July 11, 
2020, applications were submitted through three different servers located in either Boydton, 
Virginia, West Des Moines, Iowa, or Quincy, Washington. Beginning on July 11, 2020, 
applications were handled by an SBA contractor with servers located in Des Moines, Iowa. 
17. 
In the EIDL loan application, the applicant was required to, among other things, 
provide their personal information, as well as their business information, including, but not limited 
to, their business's number of employees as of January 31, 2020. their business's gross revenues 
for the 12 months prior to January 31, 2020, and their business's cost of goods sold for the 12 
months prior to January 31, 2020. The applicant was also required to certify, under penalty of 
perjury, that all information contained in, and submitted with, the application was "true and 
correct." 
18. 
As part of the EIDL loan application. the applicant was also required to certify that 
"[ n ]o principal of the Applicant with a 50 percent or greater ownership interest is more than sixty 
(60) days delinquent on child support obligations.'· In addition, the application also required the 
applicant to answer whether the applicant was "presently subject to an indictment[?]" Furthermore, 
the application also required the applicant to answer whether, "[ w ]ithin the last five years, for any 
felony, have you ever been ... placed on any form of parole[?]" 
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19. 
Prior to April 2021, an applicant was eligible to receive a COVID-19 EIDL loan up 
to an amount equal to 50% of the applicant's gross profit (i.e., gross revenues minus cost of goods 
sold) for the 12 months prior to January 31, 2020. 
20. 
If an EIDL loan application or advance request was approved, the SBA 's Denver 
Finance Center located in Denver, Colorado created payment files and authorized payments of 
EIDL funds. The disbursement of EIDL funds was transmitted by the FMS to the Treasury and 
then to the recipient's bank account. 
21. 
EIDL funds were pennitted to be used for payroll expenses, sick leave, production 
costs, and business obligations, such as debts, rent, and mortgage payments. 
COUNT ONE 
(Wire Fraud Conspiracy: 18 U.S.C. § 1349) 
22. 
Each of the above allegations is hereby incorporated by reference as if fully set 
forth herein. 
23. 
Beginning in or about September 17, 2018, and continuing through at least in or 
about July 17, 2024, in the Eastern District of Missouri and elsewhere, the defendants, 
KENNETH C. SP ARKS III, 
JEFFREY C. OBOITE, 
HAROLD G. LONG, 
MY A M. MCCLAIN, and 
JA VONTE D. LONG 
voluntarily and intentionally combined, conspired, confederated, and agreed with each other and 
others known and unknown to the Grand Jury, to commit the following offense against the United 
States: 
(a) 
Having devised and intended to devise a scheme and artifice to defraud and obtain 
money and property by means of materially false and fraudulent pretenses and 
representations and for the purpose of executing such scheme, and attempting to do 
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so, did knowingly cause and attempt to cause to be transmitted by means of wire 
communication in interstate commerce, writings, signs, and signals in the form of 
interstate electronic communications, in violation of Title 18. United States Code, 
Section 1343. 
All in violation of Title 18, United States Code, Section 1349. 
Manner and Means of the Scheme and the Conspiracy 
24. 
The primary purpose of the conspiracy was to execute a wire fraud scheme and 
artifice to defraud and obtain money, specifically, pandemic assistance dollars from lenders, by 
means of materially false and fraudulent pretenses, representations, and promises. 
25. 
The conspiracy to execute a wire fraud scheme and artifice to defraud and obtain 
money and property by means of materially false and fraudulent pretenses, representations, and 
promises was carried out by Defendants in the following manner: 
I. 
Defendant Sparks and Defendant Oboite Unlawfully Obtained At Least $200,000 in 
Pandemic Assistance Money Through Fraudulent Loan Applications Submitted in 
Their Own Names. 
26. 
As part of the conspiracy, Defendant Sparks and Defendant Oboite both submitted 
or caused to be submitted fraudulent loan applications for pandemic assistance dollars in their own 
names. Defendant Oboite taught Defendant Sparks and Defendant McClain how to submit 
fraudulent PPP loan applications and he coached them through the process of obtaining fraudulent 
PPP loans based on his experience obtaining fraudulent PPP loans for himself. 
27. 
Specifically, in furtherance of the scheme to defraud, on or about August 5. 2020, 
Defendant Oboite submitted a fraudulent sole proprietor PPP loan application to Cross River Bank, 
a participating PPP lender. In his fraudulent PPP loan application. Defendant Oboite inflated his 
average monthly payroll that he purportedly made as a ''consultant" to receive the maximum 
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amount in his PPP loan. Among other material misrepresentations, Defendant Oboite also falsely 
and fraudulently represented in that same PPP loan application that he was not "an owner of any 
other business.'' In truth and fact, as Defendant Oboite knew full well, Defendant Oboite was the 
I 00% owner of Angels Management Group, which had already received a previous PPP loan. In 
support of his fraudulent PPP loan application, Defendant Oboite also submitted a false and 
fraudulent Schedule C, which included gross receipts that he did not earn as a consultant sole 
proprietor. Based on Defendant Oboite·s material misrepresentations. Cross River Bank wired 
approximately $20,833.32 into Defendant Oboite·s bank account. 
28. 
Furthermore, on or about February 23. 2021, Defendant Oboite submitted another 
fraudulent sole proprietor PPP loan application to Cross River Bank. Like his previous fraudulent 
PPP loan application, Defendant Oboite once again inflated his average monthly payroll that he 
purportedly made as a "consultant" to receive the maximum amount in this PPP loan. In addition, 
Defendant Oboite also falsely and fraudulently represented that he was not "an owner of any other 
business.'' Further, in support of his fraudulent PPP loan application. Defendant Oboite submitted 
a false and fraudulent Schedule C, which included gross receipts that he did not earn as a consultant 
sole proprietor. Based on Defendant Oboite's material misrepresentations, Cross River Bank wired 
an additional $20,833.32 into Defendant Oboite's bank account. 
29. 
After obtaining his own fraudulent PPP loans, Defendant Oboite coached 
Defendant McClain and Defendant Sparks on how to obtain fraudulent PPP loans under Defendant 
Sparks' name. For his work, Defendant Oboite expected a cut of the proceeds that Defendant 
Sparks received as a result of Defendant Sparks' fraudulent PPP loan applications. To obtain the 
proceeds of his fraudulent PPP loans, Defendant Sparks had Defendant McClain create and submit 
Defendant Sparks' fraudulent PPP loan applications in furtherance of the scheme to defraud. 
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30. 
Specifically, on or about April 2, 2021, in the Eastern District of Missouri-and 
with the assistance of Defendant Oboite and Defendant McClain-Defendant Sparks submitted or 
caused to be submitted a fraudulent sole proprietor PPP loan application. In that fraudulent PPP 
loan application, Defendant Sparks falsely and fraudulently represented that he made $98,700 in 
gross annual income from a sole proprietorship consulting business that he purportedly owned. In 
truth and fact, however, Defendant Sparks did not own a sole proprietorship consulting business. 
Also, in that same fraudulent PPP loan application, Defendant Sparks falsely and fraudulently 
stated that he was not subject to a felony indictment. In truth and fact, as Defendant Sparks knew 
full well, he had been subject to an indictment for a felony offense since on or about October 30, 
2019. In addition, in support of his fraudulent PPP loan application, Defendant Sparks submitted 
or caused to be submitted a false and fraudulent Schedule C-which was never filed with the 
IRS-and which included gross receipts that he did not earn from a sole proprietorship consulting 
business. To verify his identity as a PPP loan applicant, Defendant Sparks was required to upload 
selfies during the PPP loan processing period. As required, Defendant Sparks took and uploaded 
the following selfies, which he took at Faith Walk Ministry, in the Eastern District of Missouri. 
Selfies 
Based on Defendant Sparks' material misrepresentations, the participating PPP lender 
(Fountainhead SBF LLC) wired $20,562.00 into Defendant Sparks' bank account on or about April 
21, 2021. 
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31. 
On or about April 22, 2021, in the Eastern District of Missouri-and with the 
assistance of Defendant Oboite and Defendant McClain-Defendant Sparks submitted or caused 
to be submitted another fraudulent sole proprietor PPP loan application. In that fraudulent PPP 
loan application, Defendant Sparks once again falsely and fraudulently represented that he made 
$98.700 in annual gross income from a sole proprietorship consulting business that he purportedly 
owned. In truth and fact, however, Defendant Sparks did not own a sole proprietorship consulting 
business. Also, in that same fraudulent PPP loan application, Defendant Sparks falsely and 
fraudulently stated that he was not subject to a felony indictment. In truth and fact, as Defendant 
Sparks knew full well, he had been subject to an indictment for a felony offense since on or about 
October 30, 2019. In addition, as a supporting document to his fraudulent PPP loan application, 
Defendant Sparks submitted or caused to be submitted a false and fraudulent Schedule C-which 
was never filed with the IRS-and which included gross receipts that he did not earn from a 
consulting sole proprietorship business. Based on Defendant Sparks' material misrepresentations, 
the participating PPP lender (Benworth Capital Partners, LLC) wired $20,562.00 into Defendant 
Sparks' bank account on or about May 26, 2021. 
32. 
Also in furtherance of the scheme to defraud, on or about June 16, 2020, in the 
Eastern District of Missouri-and with the assistance of Defendant McClain-Defendant Sparks 
submitted or caused to be submitted a fraudulent EIDL application to the SBA for an entity called 
The Miracle Place International. In his fraudulent EIDL application for The Miracle Place 
International Church, Defendant Sparks vastly inflated the entity's gross annual revenue. In that 
same fraudulent EIDL application, Defendant Sparks falsely and fraudulently represented that he 
was not "presently subject to an indictment[.]" In truth and fact, as Defendant Sparks well knew, 
he was subject to a felony indictment that was returned on or about October 30. 2019. Among 
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other material misrepresentations in the EIDL application, Defendant Sparks also falsely and 
fraudulently represented that he had not been ·'placed on any form of parole'' within the last five 
years for a felony offense. In truth and fact, as Defendant Sparks well knew, he was placed on 
parole for a separate felony offense on or about July 26, 2017. Based on Defendant Sparks' 
material misrepresentations, the SBA wired $147,900 into Defendant Sparks' bank account on or 
about July 6, 2020. Instead of using the EIDL money for legitimate business expenses, Defendant 
Sparks used the proceeds of his fraud to make payments to Gold Coast Bentley (a luxury car 
dealership in Chicago, Illinois) and to purchase designer shoes, among other impermissible 
expenses. 
33. 
All told, between 2020 and 2021, Defendant Sparks and Defendant Oboite received 
at least $200,000 in pandemic assistance money by submitting-or causing to be submitted-
fraudulent loan applications in their own names. 
II. 
Defendants Unlawfully Obtained Over One Million Dollars in PPP Loan Proceeds 
Through Fraudulent Loan Applications Submitted in the Names of Faith Walk 
Ministry Members. 
34. 
To execute the scheme to defraud, Defendant Sparks obtained-and then 
subsequently abused-his position of authority as a minister at Faith Walk Ministry. In that 
position of authority, Defendant Sparks worked to secure the trust of Faith Walk Ministry church 
members so that he could have fraudulent PPP loans taken out in their names and enrich himself 
with the proceeds. In an attempt to conceal his fraud scheme from parishioners, Defendant Sparks 
often told them that he was an "Apostle" of God, whose decisions and decrees could not be 
questioned. Defendant Sparks also had Defendant H. Long assure Faith Walk Ministry 
parishioners that Defendant Sparks could be trusted with their personal and financial information. 
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35. 
To have fraudulent PPP loans taken out in the names of his church members, 
Defendant Sparks and his co-conspirators obtained church members' personal and financial 
information through various lies and falsehoods. For instance, Defendant Sparks often told church 
members that they needed to provide their information so that his co-conspirators could fix their 
credit scores. On other occasions, Defendant Sparks told church members that his co-conspirators 
needed their information to secure funding for Faith Walk Ministry. Despite these representations, 
Defendant Sparks and his co-conspirators used Faith Walk Ministry church members' personal 
and financial information to take out fraudulent PPP loans in their names for the personal 
enrichment of Defendant Sparks and Defendant Oboite. 
36. 
As another step in the scheme to defraud, Defendant Sparks directed Defendant 
McClain to create email addresses in the names of Faith Walk Ministry church members. As 
directed, Defendant McClain created email addresses in the names of church members so that 
those email addresses could be used to apply for the fraudulent loans without alerting church 
members to the full scope of the fraud. As another step in the fraud scheme, Defendant Sparks 
encouraged Faith Walk Ministry parishioners to open new bank accounts at Navy Federal Credit 
Union, where the fraudulent PPP loan proceeds were later deposited at his and Defendant Oboite's 
direction. Additionally, Defendant Sparks commissioned the creation of false and fraudulent tax 
documents in the names of Faith Walk Ministry church members. Those fraudulent tax documents, 
which were later submitted to the lenders in support of the fraudulent PPP loans, included fictitious 
earnings for the church members that were never reported to the IRS. 
37. 
To execute the fraudulent scheme, Defendant Sparks and Defendant Oboite 
directed Defendant McClain to submit the fraudulent sole proprietorship PPP loans in the names 
of Faith Walk Ministry church members. Defendant Oboite specifically coached Defendant 
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McClain on how to fill out these fraudulent PPP loan applications. As directed by Defendant 
Sparks, Defendant McClain either submitted or substantially assisted in the submission of 
fraudulent sole proprietorship PPP loan applications in the names of Faith Walk Ministry church 
members. Each of those fraudulent PPP loan applications listed businesses that did not exist or 
included revenues that were never earned. The vast majority of the fraudulent PPP loans completed 
by Defendant McClain-including the fraudulent PPP loan that she submitted in her own name-
were submitted via interstate wiring from Faith Walk Ministry, within the Eastern District of 
Missouri. 
38. 
In furtherance of the scheme to defraud. Defendant J. Long-a church member at 
Faith Walk Ministry-caused the submission of a fraudulent sole proprietorship PPP loan in his 
own name on or about April 2, 2021. Like many of the fraudulent Faith Walk Ministry PPP loan 
applications, Defendant J. Long's application was for a '·consultant'' business that did not exist. 
Defendant J. Long personally participated in the application process by signing the promissory 
note from his personal residence, within the Eastern District of Missouri. In addition, Defendant 
J. Long pocketed at least $8,000 of the PPP loan proceeds for himself. 
39. 
In addition to taking out fraudulent sole proprietorship PPP loans in the names of 
Faith Walk Ministry church members. Defendant Sparks and Defendant Oboite also directed 
Defendant McClain and Defendant H. Long to submit fraudulent PPP loan applications for 
businesses purportedly owned by Defendant H. Long. For example, on or about April 4. 2021, 
Defendant McClain-with the assistance of Defendant H. Long-submitted a fraudulent PPP loan 
application for a company called "Jabin II.'' Included in the fraudulent PPP loan application for 
Jabin II was the material misrepresentation that the company paid an average monthly payroll of 
$64,657.00. In truth and fact, as Defendant McClain and Defendant H. Long well knew, Jabin II 
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had little to no payroll expenses. In support of the fraudulent PPP loan application that Defendant 
McClain submitted for Jabin 11, Defendant McClain also submitted false and fraudulent tax forms, 
which were approved and signed by Defendant H. Long. Included in Defendant H. Long's false 
and fraudulent tax documents for Jabin 11 was the misrepresentation that Jabin II earned 
$1,989,000.00 in gross receipts or sales during 2019. In truth and fact, as Defendant H. Long and 
Defendant McClain well knew, this figure was vastly inflated. Despite Defendant H. Long's 
knowledge that the Jabin II tax documents were false and fraudulent, he approved and signed those 
documents to ensure that the lender provided Jabin II with a substantial PPP loan. Based on the 
material misrepresentations made by Defendant H. Long and Defendant McClain as part of the 
Jab in II PPP loan application, the participating PPP lender (TAB Bank) wired a total of 
$161,642.00 into a bank account controlled by Defendant H. Long. 
40. 
Based on the material misrepresentations included in the dozens of fraudulent PPP 
loan applications that were completed and submitted at the direction of Defendant Sparks and 
Defendant Oboite, participating PPP lenders paid out more than one million dollars in government-
backed funds. Defendant Oboite-for his role in the conspiracy----expected to receive a percentage 
of the fraudulent PPP loan proceeds. 
41. 
After Faith Walk Ministry church members received the fraudulent PPP loan 
proceeds in their newly-created Navy Federal Credit Union bank accounts, Navy Federal Credit 
Union froze several of the church members' bank accounts based on suspected fraud. In an effort 
to conceal the scheme to defraud and reopen the church members' bank accounts, Defendant 
Sparks and Defendant Oboite coached the church members on the lies that they should tell Navy 
Federal Credit Union. For example, on or about June 14, 2021, Defendant Oboite emailed 
Defendant Sparks and Defendant McClain a "script" for Defendant J. Long to use when he spoke 
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with a representative of Navy Federal Credit Union. Defendant Oboite's false and fraudulent script 
for Defendant J. Long included the following information: 
Javonte long 
Question 1: What is the purpose of you taking out the loan? Why did you get the loan? 
Your Answer: 
I am a sole proprietor and I applied for the sole proprietor PPP loan 
a) I am the one who applied using my computer. 
b) Nobody stole my identity to apply 
c) I used my social security number and I have been a sole proprietor for the last few years 
d) I was reviewed by the SBA approved lender called HARVEST SMALL BUSINESS and they and 
the SBA approved my application for the sole proprietor 
e) So seems to be the problem? 
Question 2: If they ask how long you've been a sole proprietor? 
Answer: about 3 years 
42. 
After Faith Walk Ministry church members received the unfrozen fraudulent PPP 
loan proceeds in their bank accounts, Defendant Sparks and others directed them on where to send 
the proceeds. Unbeknownst to many Faith Walk Ministry church members, Defendant Sparks 
ultimately received hundreds of thousands of dollars from the fraudulent PPP loans that were 
submitted in their names. Instead of providing that money to Faith Walk Ministry or his 
parishioners, Defendant Sparks spent the fraudulently obtained loan proceeds on himself-paying 
for designer clothing, luxury merchandise, and expensive cars. 
43. 
When Faith Walk Ministry church members questioned Defendant H. Long about 
the loans proceeds in their bank accounts or where the money was going, Defendant H. Long 
assured those parishioners that they should trust Defendant Sparks. When those same questions 
were posed by church members to Defendant Sparks, he would threaten church members with 
"curses from God." Defendant Sparks also regularly scolded church members who inquired about 
his fraudulent scheme for questioning a "man of God." 
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COUNTS TWO - NINE 
(Wire Fraud: 18 U.S.C. § 1343) 
44. 
Each of the above allegations is hereby incorporated by reference as if fully set 
forth herein. 
45. 
Beginning by at least on or about September 17, 2018, and continuing through at 
least on or about July 17, 2024, in the Eastern District of Missouri, the defendants listed below, 
with the intent to defraud, devised and intended to devise a scheme and artifice to defraud lenders 
and to obtain money and property from lenders by means of material false and fraudulent pretenses, 
representations, and promises, as described further herein. 
46. 
On or about the dates set forth below. in the Eastern District of Missouri, and 
elsewhere. for the purpose of executing the above-described scheme and artifice to defraud and 
obtain money and property by means of false and fraudulent pretenses, representations and 
promises and for the purpose of executing the same, the defendants specified below did knowingly 
transmit and cause to be transmitted by means of wire communication in and affecting interstate 
commerce, certain writings, signs, signals, pictures. or sounds, to wit: 
2 
3 
4 
5 
Defendant Sparks 
Defendant Sparks 
Defendant Oboite 
Defendant McClain 
Defendant H. Lon 
Defendant Sparks 
Defendant Oboite 
Defendant McClain 
Defendant J. Lon 
Defendant Sparks 
Defendant Oboite 
Defendant McClain 
6/16/2020 An electronic EIDL application submitted for The 
Miracle Place International through an out-of-state 
server from the Eastern District of Missouri. 
4/1/2021 
An electronic PPP loan application submitted for 
Defendant H. Long through an out-of-state server from 
the Eastern District of Missouri. 
4/2/2021 
An electronic PPP loan application submitted for 
Defendant J. Long through an out-of-state server from 
the Eastern District of Missouri. 
4/2/2021 
An electronic PPP loan application submitted for 
Defendant Sparks through an out-of-state server from 
the Eastern District of Missouri. 
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6 
7 
8 
9 
Defendant Sparks 
4/2/2021 
An electronic PPP loan application submitted for 
Defendant Oboite 
Parishioner J.F. through an out-of-state server from the 
Defendant McClain 
Eastern District of Missouri. 
Defendant Sparks 
4/3/2021 
An electronic PPP loan application submitted by 
Defendant Oboite 
Defendant McClain in her own name, which traveled 
Defendant McClain 
through an out-of-state server from the Eastern District 
of Missouri. 
Defendant Sparks 
4/4/2021 
An electronic PPP loan application for Jabin II Inc., 
Defendant Oboite 
which traveled through an out-of-state server from the 
Defendant McClain 
Eastern District of Missouri. 
Defendant H. Lon2 
Defendant Sparks 
4/10/2021 
An electronic PPP loan application submitted for 
Defendant Oboite 
Parishioner R.L. through an out-of-state server from the 
Defendant McClain 
Eastern District of Missouri. 
All in violation of Title 18, United States Code. Sections 1343 and 2. 
COUNTS TEN - ELEVEN 
(Aggravated Identity Theft: 18 U.S.C. § 1028A) 
4 7. 
Each of the above allegations is hereby incorporated by reference as if fully set 
forth herein. 
48. 
On or about the dates listed below, within the Eastern District of Missouri. the 
defendant, 
KENNETH C. SP ARKS III, 
did knowingly use. without lawful authority. a means of identification of another person during 
and in relation to a felony violation enumerated in 18 U .S.C. § 1028A( c ). to wit. wire fraud. in 
violation of 18 U.S.C. § 1343, knowing that the means of identification belonged to another actual 
person, as described below. in that Defendant Sparks used or caused to be used the means of 
identification listed below in order to submit or cause to be submitted fraudulent loan applications. 
10 
11 
4/2/2021 
The name of Parishioner J.F. included in a PPP loan application. 
4/10/2021 
The name of Parishioner R.L. included in a PPP loan application. 
All in violation of Title 18, United States Code. Sections 1028A(a)(l) and 2. 
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FORFEITURE ALLEGATION 
The Grand Jury further alleges there is probable cause that: 
1. 
Pursuant to Title 18, United States Code, Sections 982(a)(2), upon conviction of an 
offense in violation of Title 18, United States Code, Sections 1343 and 1349, as set forth in Counts 
One through Nine, the defendant shall forfeit to the United States of America any property 
constituting, or derived from, any proceeds obtained, directly or indirectly, as a result of such 
violation. Subject to forfeiture is a sum of money equal to the total value of any property, real or 
personal, constituting or derived from any proceeds traceable to such violation. 
2. 
If any of the property described above, as a result of any act or omission of the 
defendant: 
a. 
cannot be located upon the exercise of due diligence; 
b. 
has been transferred or sold to, or deposited with, a third party; 
c. 
has been placed beyond the jurisdiction of the court; 
d. 
has been substantially diminished in value; or 
e. 
has been commingled with other property which cannot be divided without 
difficulty, 
the United States of America will be entitled to the forfeiture of substitute property pursuant to 
Title 21, United States Code, Section 85 3(p ). 
SAYLER A. FLEMING 
United States Attorney 
DEREK J. WISEMAN, #67257MO 
Assistant United States Attorney 
A TRUE BILL. 
FOREPERSON 
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