Indictment — United States v. Keesa Seaniya Lynn Green — United States v. Kenneth C. Sparks III et al. (E.D. Mo., 2025-03-04)

Record facts

U.S. District Court for the Eastern District of Missouri, Southeastern Division · No. 1:25-cr-00049-SEP · Doc. 2 · 2025-03-04 · Docket on CourtListener

Full text

FILED 
MAR G 4 2025 
IN THE UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF MISSOURI 
SOUTHEASTERN DIVISION 
u. s. OISTRICl COlll'I I 
EASTERN DISTRICT Of MG 
CAPE GIRARDEAU 
UNITED STATES OF AMERICA, 
Plaintiff, 
) 
) 
) 
) 
) 
) 
) 
) 
) 
) 
vs. 
Case No. 
1:25CR00049-JAR-ACL 
KEESA SEANIYA LYNN GREEN, 
Title 18, U.S.C. § 1014. 
Title 18, U.S.C. § 1343. 
Forfeiture allegations. 
Defendant. 
INDICTMENT 
THE GRAND JURY CHARGES THAT: 
At all times material to this Indictment, unless otherwise specified below: 
1. Keesa Seaniya Lynn Green, the defendant herein, was a resident of Caruthersville, 
Pemiscot County Missouri, within the Southeastern Division of the Eastern District of Missouri. 
2. Keesa Green did not own or operate a business registered or incorporated within the 
State of Missouri which was in operation on February 15, 2020. 
The Paycheck Protection Program 
3. 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. 
4. The Coronavirus Aid, Relief, and Economic Security ("CARES") Act, Pub. L. No. 
1 
Case: 1:25-cr-00049-SEP     Doc. #:  2     Filed: 03/04/25     Page: 1 of 7 PageID #: 9

' 
I 
116-136, 134 Stat. 281 (2020), is a federal law that was enacted in or around March 2020 to 
provide emergency financial assistance to the millions of Americans suffering the economic 
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, wages and to provide benefits, such as health insurance coverage, to their employees. 
5. 
To obtain a PPP loan, a qualifying business was required to submit a PPP loan 
application, signed by an authorized representative of the business. The PPP loan application 
required the business to acknowledge the program rules and make certain affirmative 
certifications to obtain the PPP loan. ln the PPP loan application (SBA Form 2483), the small 
business (through its authorized representative) was required to certify: (a) that the small 
business was in operation on February 15, 2020; and (b) the average monthly payroll expenses; 
and ( c) the number of employees. These certifications were used to calculate the amount of 
money the small business was eligible to receive under the PPP. In addition, businesses applying 
for PPP loans were required to submit documentation supporting their payroll expenses. 
7. A PPP loan application was then processed by a paiiicipating lender. If a PPP loan 
application was approved, the paiiicipating 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 bonower's debt from the lending financial institution and 
assume the responsibility for paying back the loan. 
2 
Case: 1:25-cr-00049-SEP     Doc. #:  2     Filed: 03/04/25     Page: 2 of 7 PageID #: 10

' 
I 
8. PPP loan funds were required to be used on ce1iain permissible expenses, 
including payroll costs, mortgage interest, rent, and utilities for the business. In the PPP loan 
application (SBA Form 2483), the bo1Tower must certify that 
11[a]ll SBA loan proceeds will be 
used only for business-related purposes as specified in the loan application and consistent with 
the Paycheck Protection Program Rule. 
11 In that same application, the borrower must also certify 
that 
11[t]he funds will be used to retain workers and maintain payroll or make mortgage interest 
payments, lease payments, and utility payments, as specified under the Paycheck Protection 
Program Rule. 
11 
9. Under the applicable PPP rules and guidance, the interest and principal on the 
PPP loan was eligible for forgiveness if the business spent the loan proceeds on these authorized 
expense items within a designated period of time and used a certain portion of the loan toward 
payroll expenses. 
10. Harvest Small Business Finance, LLC (Harvest), a financial institution headquaitered in 
Laguna Hills, California, was a paiticipating lender and issued PPP loans guai·anteed by the 
SBA. Harvest processed applications for PPP loans that were submitted through an internet-
based web portal, which affected interstate cmmnerce. 
The Scheme to Defraud 
COUNTI 
False Statement (18 U.S.C. § 1014) 
11. Paragraphs 1-10 are realleged and incorporated by reference as if fully set forth herein. 
12. On or about May 27, 2021 , in the Southeastern Division of the Eastern District of Missouri 
and elsewhere, the defendant, Keesa Green, knowingly made a false statement to Harvest Small 
3 
Case: 1:25-cr-00049-SEP     Doc. #:  2     Filed: 03/04/25     Page: 3 of 7 PageID #: 11

Business Finance, LLC, a financial institution, for the purpose of influencing the action of Harvest 
Small Business Finance, LLC upon an application for a SBA backed PPP loan, in violation of Title 
18, United States Code, Section 1014 and punishable under Title 18, United States Code, Section 
1014. 
Manner and Means 
13. It was a part of the scheme that, on or about May 27, 2021, Keesa Green submitted and caused 
to be submitted a fraudulent PPP loan application on behalf of Keesa Green, which falsely stated: 
a) That Keesa Green was the owner / operator of a small business that was in operation in 
Missouri on February 15, 2020. 
b) That any funds received by way of a PPP loan would be spent on permissible expenses, 
such as payroll costs, mortgage interest, rent and utilities for the business which she 
claimed. 
14. Further, Keesa Green knowingly submitted and caused to be submitted certain documents in 
support of the fraudulent PPP loan application, including a materially false and fraudulent Internal 
Revenue Service (IRS) Schedule C (Form 1040) Profit or Loss From Business form (Schedule C) 
for 2019 which falsely represented specified income and expenses. 
When in truth and fact, there was no such business and Keesa Green had not obtained the 
income listed, nor incurred the expenses claimed, and Keesa Green did not spend the proceeds of 
the loan in a manner consistent with the rules of the program. 
COUNT II 
Wire Fraud (18 U.S.C. § 1343) 
15. Paragraphs 1-10 are realleged and incorporated by reference as if fully set forth herein. 
16. On or about May 27, 2021, in the Southeastern Division of the Eastern District of Missouri 
4 
Case: 1:25-cr-00049-SEP     Doc. #:  2     Filed: 03/04/25     Page: 4 of 7 PageID #: 12

' 
I 
and elsewhere, the defendant, Keesa Green voluntarily and intentionally devised or participated in 
a scheme to obtain money by means of material false representations, namely the submission of a 
fraudulent PPP loan application, with the intent to defraud, and the defendant used, or caused to 
be used an interstate wire communication, that is the electronic submission of a fraudulent loan 
application via the internet, for the purpose of obtaining an electronic deposit of funds into a bank 
account of Keesa Green, in furtherance of the scheme, and the scheme affected Harvest Small 
Business Finance, LLC, a financial institution, in violation of Title 18 United States Code, Section 
1343 and punishable under Title 18, United States Code, Section 1343. 
17. It was a part of the scheme that, on or about May 27, 2021 , Keesa Green submitted and caused 
to be submitted a fraudulent PPP loan application on behalf of Keesa Green, which falsely stated: 
a) That Keesa Green was the owner / operator of a small business that was in operation in 
Missouri on February 15, 2020. 
b) That any funds received by way of a PPP loan would be spent on permissible expenses, 
such as payroll costs, mortgage interest, rent and utilities for the business which she 
claimed. 
18. Further, Keesa Green submitted and caused to be submitted certain documents in support of 
the fraudulent PPP loan application, including a materially false and fraudulent Internal Revenue 
Service (IRS) Schedule C (Form 1040) Profit or Loss From Business form (Schedule C) for 2019 
which falsely represented specified income and expenses. 
When in truth and fact, there was no such business and Keesa Green had not obtained the 
income listed, nor incurred the expenses claimed and Keesa Green did not spend the proceeds of 
the loan in a manner consistent with the rules of the program. 
19. As a result of the materially false and fraudulent application for a PPP loan, the lender did 
5 
Case: 1:25-cr-00049-SEP     Doc. #:  2     Filed: 03/04/25     Page: 5 of 7 PageID #: 13

' . 
electronically transfer $19,966.00 to a bank account of Keesa Green. 
Forfeiture Allegations 
The Grand Jury further finds by probable cause that: 
Pursuant to Title 18, United States Code, Section 982(a)(2)(A) and (a)(3)(F), upon 
conviction of an offense in violation of Title 18, United States Code, Section 1014 and/or 
Section 1343, as set forth in the Indictment, the defendant shall forfeit to the United States of 
America any property constituting, or derived from, 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 the 
property, real or personal, constituting or derived from any proceeds traceable to such violation, 
which is at least $19,966.00. 
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 transfen-ed or sold to, or deposited witl1, a third party; 
c. has been placed beyond the jurisdiction of the comi; 
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 853(p). 
A TRUE BILL 
Foreperson 
6 
Case: 1:25-cr-00049-SEP     Doc. #:  2     Filed: 03/04/25     Page: 6 of 7 PageID #: 14

' 
T 
SAYLER A. FLEMING 
United States Attorney 
Tim J. Willis, # 62428MO 
Assistant United States Attorney 
7 
Case: 1:25-cr-00049-SEP     Doc. #:  2     Filed: 03/04/25     Page: 7 of 7 PageID #: 15

File and source

File

gov.uscourts.moed.218644.2.0_Green-Keesa-indictment.pdf

Size

140,917 bytes

SHA-256

808ba0189e9c1d2af3536d53a5198220e385b8123c6c1a35d2f2d828ae0e9338

Our copy

gov.uscourts.moed.218644.2.0_Green-Keesa-indictment.pdf

Original

No public link identified.